September 28, 2005 Time: 9:55 AM Brian is watching over my best interest and appropriately requests that Darland

d confirms in writing what he agreed to before I would agree to sign the SA!
----- Original Message ----From: Darrel Ellis To: Kim Bailes Sent: Wednesday, September 28, 2005 9:55 AM Subject: SuppMemo Agree - Leclezio/Darland Kim: Attached is memo which I prepared summarizing what I understand to be the related agreement between Louis and Mike. Please circulate for review to Mike Darland, Louis Leclezio and Doug. Thanks, Brian Dorsey

Fw: SuppMemo Agree - Leclezio/Darland

From: Kim Bailes (kbailes@eburglaw.com) Sent: Wed 9/28/05 10:12 AM Michael Darland (michael@southernchilexp.com); Louis Leclezio (leclezio@hotmail.com); Doug Nicholson To: (dnicholson@eburglaw.com) 1 attachment SuppMemoA...doc (22.5 KB) If you're having problems downloading attachments, please sign in again and select "Remember me on this computer". Sign in again

September 28, 2005 Time: 3:22PM Darland ignores Dorseys Supplemental Memo Tries to Bulldoze me into signing. Need your signature
From: Michael L Darland (michael@southernchilexp.com) Sent: Wed 9/28/05 3:22 PM To: Louis Leclezio (leclezio@hotmail.com) 1 attachment Rev4final...doc (61.0 KB) If you're having problems downloading attachments, please sign in again and select "Remember me on this computer". Sign in again
Dear Louie: I need your signature on this document. Best regards, Michael

September 28, 2005 Time: 6:37PM I refuse to be bulldozed by Darland & our joint attorney Nicholson. They corrupted my personal attorney Brian J. Dorsey. Dorsey had no business not sticking to Darlands agreement in court and to the Supplemental Memo he had prepared. MY JUSTIFIED REACTION: Confirmation of Settlement Instructions
From: Louis Sent: Wed 9/28/05 6:37 PM kbailes@eburglaw.com; dorsey@julin-mcbridelaw.com; To: dnicholson@eburglaw.com Cc: michael@southernchilexp.com; myrna@southernchilexp.com

In retrospect, I should have sent you all and all of your self serving advices to hell and stuck to my guns.

The chronology of the mail sequence is most revealing.

September 28, 2005 Dear Brian and Doug, This serves to confirm our telephone conversation this afternoon. During our conversation, I specifically requested that if the terms of the settlement agreement were not good enough for Michael and Myrna Darland to Quit Claim my 26 acres to me or my assigns then: No CR No.? Stipulation should or could be filed with the court stating that the case has been settled! From Mikes conversation in court yesterday I believe that we ALL understood that Mike agreed that upon reaching a settlement I would be entitled to my 26 acres per our agreement! I was aghast to hear today that Michael refused to confirm in writing what he agreed to verbally yesterday!!! I further advised that if and when Michael and Myrna signed off on Brians Memo, ONLY THEN WOULD I KNOW THAT THE TERMS OF THE SETTLEMENT AGREEMENT ARE INDEED ACCEPTABLE TO ALL PARTIES.

In that event and in that event alone Brian would be authorized to sign off on my behalf and Doug and Brian could then stipulate to the court that the deal had been settled to the satisfaction of ALL parties involved. Yours sincerely, Louis Leclezio.

September 29, 2005 Time: 4:52AM Darland caves in Actions to preserve the SPUD Agreement
From: Michael L Darland (michael@southernchilexp.com) Sent: Thu 9/29/05 4:52 AM To: Doug Nicholson (dnicholson@eburglaw.com) Cc: Louis Leclezio (leclezio@hotmail.com) 1 attachment Bellevue.doc (23.5 KB) If you're having problems downloading attachments, please sign in again and select "Remember me on this computer". Sign in again
Dear Doug: I have thought this over and believe that the attached provides the best hope for preserving the SPUD agreement, gives Louie what he is demanding, without passing judgment on or taking into account the actual facts and circumstances, and with the signing of the SPUD agreement by all parties, will avoid the several years lost in appeals when we commence the litigation with the SPUD and any other litigation which may ensue in the interim. This is not how I envisioned this all working out. It is ironic. On the eve of our great victory and with the opportunity to move aggressively forward in hand, this tragic set of circumstances unexpectedly unfolded. Who would have imagined? Should this not be possible today then we shall survive and pick up the pieces and proceed from where we left off. Best regards, Michael

Bellevue, WA September 29, 2005 Dear Doug: I do not want to lose this deal. I know Louies position is not correct in this matter but I do not control Louies actions and cannot cause him to do the right thing now or in the future. Accordingly, draft a document that Louie must sign together with the SPUD agreement no later than 10:00 AM this morning.

This agreement should give him all that he has requested in Bryans memo including the quitclaim of the 26 acres, as it was never my intent to not perform on the quitclaim deed release once his commitments were fulfilled and at this date they are not. However, I want to save this deal. Our personal agreement should have had the time to be thought out and written out in a thorough manner but this will have to do in order to give Louie what he is demanding. Louie must also agree, however, to honor other written commitments he has made to me. In return and before I release the quit claim, he must also agree to:

1. Sign the SPUD agreement, together with the new agreement, before 10:00 AM this morning.
2. Provide me with a 60-foot road and utilities easement through his property, the precise location to be determined within the 18-month period assigned to this task by the SPUD agreement. 3. Agree to pay, and commit any party, who may purchase the property, to pay, the pro rata share, (based on his ownership percentage of the 76 acres), of the water and sewer line extension costs being brought through his property to my southern property boundary as required by the SPUD agreement, in the event it is decided to run the water and sewer lines from their present location to my southern property boundary and any other costs of the agreement as may apply to both parties jointly. 4. Repay to me all monies I have loaned and advanced to him to date. 5. Repay to me all monies for all legal fees that should have been paid by him to secure the SPUD Settlement Agreement as set forth in the quitclaim agreement for release of the 26 acres. (Do not include your fees for this new agreement in that amount) 6. Pay any and all legal fees that have been incurred by his attorneys in any and all aspects of this litigation. I do not demand that he pay me today, but to do so at his earliest convenience so that I may provide him immediately thereafter with the quitclaim deeds that he is demanding. I want only the best for Louie and I hope this makes him happy. These were not the terms I intended for release of the quitclaim, but it fits the current circumstances. The only other agreements that I shall honor with Louie are those set forth in the original sale documents. Should Louie choose not to perform on the above by 10:00AM, or decide to make any additional demands on me, I request that you inform Bryan that at one minute past 10:00AM this morning, you are instructed to withdraw this new agreement and to take any and all actions you deem necessary to preserve the Settlement Agreement on my behalf, which has been obtained at great personal and financial cost to me. Best regards, Michael

September 29, 2005 Time: 8:11AM Nicholson chooses NOT to respect my best interest, NOT to follow Darlands instructions, NOT to discuss those instructions with me and to put untold pressure on me to forego what had been agreed to by Darland, Dorsey and I in Nicholsons presence in Court the previous day! As time would tell, Doug W. Nicholsons violation of his fiduciary duty towards me has cost me a fortune with much heartache, pain and suffering.

I hope Doug and all spend many more a sleepless night. I have had my fair share of them since that disastrous mail of Nicholsons. Re: Confirmation of Settlement Instructions
From: Doug Nicholson (dnicholson@eburglaw.com) Sent: Thu 9/29/05 8:11 AM To: Louis Leclezio (leclezio@hotmail.com)

Dear Louis, I spent a sleepness night worrying about the consequences of this most unfortunate set of circumstances. I am asking you to please reconsider your position, and sign the Settlement Agreement with the District. The agreement between you and Michael is completely separate and distinct. We have come too far, and worked to hard, to bring the District in line only to lose now. The Settlement Agreement is a great deal, better than what we could expect at trial. Mallove convinced the District to sign because he was not ready for trial, and he was extremely worried about the documents we had for exhibits. Once he learns that you will not sign the agreement, the District is off the hook. We will not get another trial date for several months. Meanwhile, Mallove will have time to force us to turn over all of our exhibits, to depose Kloss and Moffett, and to better prepare our case. Please don't throw the baby out with the bathwater by not signing the agreement with the District. Yours truly,

Here comes Turn Coat Doug War Nicholson. No wonder he had to change law firms recently!!! Someone as unethical as Douglas Warr Nicholson should be disbarred. RE: Final Revised Draft I referred to earlier
From: dnicholson@eburglaw.com Sent: Thu 9/25/08 9:53 AM 'Louis Leclezio' (leclezio@hotmail.com); 'Jim McBride' (mcbride@julin-mcbridelaw.com); 'Brian Dorsey' To: (dorsey@julin-mcbridelaw.com); kbailes@eburglaw.com Cc: 'Michael L Darland' (michael@southernchilexp.com)

Gentlemen:

There are several statements in Mr. Leclezios proposed letter regarding my involvement in this matter that are inaccurate and need to be corrected. First, I was not, and am not, his attorney in the litigation with SPUD. On the contrary, I was brought in for the sole purpose of representing the Darlands. Second, I did not put untold pressure on Mr. Leclezio to sign the settlement agreement with SPUD, nor did I ever guarantee that there was no way Mr. Leclezio could lose his investment, or that I would testify in Court if need be as to the additional verbal guarantees [by] Darland. Not only would this be a conflict of interest, but I have no knowledge of any verbal guarantees. In fact, I was not involved in the discussions between Mssrs. Darland and Leclezio that culminated in their various agreements. I will also point out the present dispute between Mssrs. Darland and Leclezio places both Brian Dorsey and me in a conflict of interest which precludes either of us from getting involved; accordingly, both Mssrs. Darland and Leclezio need to get new and separate counsel to handle this matter. This conflict aside, I will offer the following comments and suggestions. At this point, WSDOT is refusing to allow the 20 easement to be expanded to 60, which is necessary in order to utilize the water and sewer hook-ups available from SPUD. It is SPUDs position that it does not have the authority to condemn a 60 access easement; thus, although SPUD could run the water and sewer lines under the 20 easement, this would be of no benefit the Leclezio/Darland, since the lack of a 60 easement would preclude development of the property to utilize the hook-ups that have been granted. As such, it makes no economic sense to pay to run utility lines to the property. Given these facts, it makes sense to sell the property if the right price can be obtained - which I understand Mr. Darland is attempting to do - rather than pursuing further litigation that would be extremely costly and potentially unavailing. However, if Mr. Leclezio sends the letter as he has stated he intends to do, this could potentially undermine any sale, as well as any other future options available to the parties. Subject to the Darlands approval, therefore, it would seem to make sense to allow a sale of the property to go forward, assuming a buyer exists and the price is right, and have Darlands deposit 34% of the proceeds into an escrow account that cannot be accessed until such time as the Darlands and Mr. Leclezio resolve their dispute, whether by litigation or settlement. I believe this proposal addresses Mr. Leclezios concern that his claimed interest in the property be protected, while at the same time ensuring that the best return on the property be realized. In my opinion, the alternative could lead to costly litigation with third parties that would prevent a resolution of the disposition of the property for years; and any resolution of the present dispute between Mr. Darland and Mr. Leclezio would probably not be resolved until sometime thereafter. This proposal would eliminate all interim steps and delays, leaving only the resolution of the Darland/Leclezio dispute. Very truly yours, Doug

From: Louis Leclezio [mailto:leclezio@hotmail.com] Sent: Thursday, September 25, 2008 4:43 AM To: Jim McBride; Doug Nicholson; Brian Dorsey; kbailes@eburglaw.com Subject: Final Revised Draft I referred to earlier Dear Jim, Doug & Brian, Please find attached final revised draft I referred to this morning. Any further suggestions?

Enjoy! Good luck.

The WSBA should have a lot of fun sorting out all the above pending my getting a committed enthusiastic lawyer on board even if that needs my return to the US agains my doctors advice.