Madeline A. Coblenz and William J. Mason - Page 3

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          Acquisition of Radio Station                                                
               In late 1987, petitioner located a radio station in                    
          Beaumont, Texas, struggling financially and in bankruptcy.                  
          Petitioner developed a business plan for acquiring, upgrading,              
          and profitably operating the radio station (the venture).                   
               In December 1988, petitioner met Mark W. White, Jr. (Mr.               
          White), a former Texas Governor, and discussed the venture.                 
          After their meeting, petitioner negotiated favorable contracts              
          and organized Modern World Media, Inc. (Modern World) with Mr.              
          White, to acquire the radio station.3  In the beginning of 1990,            
          using his many contacts, Mr. White obtained bank financing for              
          the venture from First City, Texas-Houston, N.A. (First City                
          Bank).  As a condition for the financing, First City Bank                   
          required a letter of credit to secure $5.5 million in bank loans.           
              Mr. White introduced petitioner to various wealthy Texas               
          business people.  Through these introductions, Mr. White and                
          petitioner convinced H. Ross Perot (Mr. Perot) to commit a $2.5             
          million letter of credit for the venture through one of Mr.                 
          Perot’s companies, Gnat Robot Corp.                                         
               During 1990, First City Bank advanced funds in an amount               
          less than $5.5 million.  With the funds that Mr. White and                  
          petitioner received from First City Bank, they acquired the radio           

               3  Because Mr. White was seeking the Democratic nomination             
          for the Texas governorship, Mr. White did not initially take an             
          equity interest in Modern World.                                            

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