Jerry and Patricia A. Dixon, et al. - Page 10

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          Hedges, in addition to the appellate work, would “represent the             
          Committee with regard to counsel and assistance in terminating              
          its relationship with its present lawyer, Michael Louis Minns,              
          and * * * assist * * * in obtaining a refund of attorneys’ fees             
          and expenses paid to Mr. Minns or at his direction”.  The                   
          engagement is on an hourly fee basis, with the Defense Fund                 
          agreeing to advance $120,000 for application against expected               
          billings.  Three members of the steering committee--all nontest             
          case petitioners--are jointly and severally liable for the                  
          Defense Fund’s obligations under the agreement, which are not               
          limited by the $120,000 estimate and required advance.                      
               From December 12, 2001 to April 5, 2002, the Dixons and 43             
          nontest case petitioners (hereafter, the group of 43)--36 of whom           
          are also part of the group of 112--made contributions to the                
          Defense Fund (all but three in the amount of $1,500) totaling               
          $66,050 in connection with the hiring of Porter & Hedges.  In               
          addition, from December 2001 through April 2002, 37 members of              
          the group of 43 made smaller contributions to the Defense Fund              
          totaling $18,150.  Thus, total contributions to the Defense Fund            
          from December 2001 through April 2002 by the Dixons and the group           
          of 43 amounted to $84,200.  Porter & Hedges has received only               
          $60,000 from the Defense Fund to date, with the last payment                
          occurring in April 2002.                                                    







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