ROSE, MEEK, HOUSE, BARRON, NASH & WILLIAMSON

ATTORNEYS AT LAW

720 WEST THIRD STREET

LITTLE ROCK, ARKANSAS 72201

January 14, 1965

Frank Lyon Company

65th & Scott Hamilton Drive

Little Rock, Arkansas

Attention: Mr. O. W. Morrow

Gentlemen:

I attach hereto certain enclosures; and the receipt of this letter you should regard as a joyful event.

I don’t want to engage in rodomontado or thrasonical bombast in recounting the excellence (or I may say ‘grandeur’) of my efforts on your behalf in this Jack Edwards fracas. Nevertheless I do modestly suggest that you and your employees should declare each anniversary of the date of this letter to be ‘Meek Day’, to be celebrated by feasting, fan dancing, and bull fights and things.

When I first peeped in on this Edwards holocaust, all I saw was various and divers claiments (including an evil attaching creditor), armed with writs, mortgages and liens, all clamoring for your inventory and your dough. In fact, John Roby and Company had tied up some of your pledged inventory; and it was fast in the clutches of a two-gun sheriff.

;Even at the beginning the picture, from you standpoint, was dark and miasmic; but when the government intervened with priority tax liens, I gave you about as much chance as the proverbial tallow-legged dog chasing the asbestos rabbit through the Plutonian realms.

But undaunted, I strove mightily on your behalf. First, I smote down John Roby Company, the Chancellor decreeing that Roby’s juridical levy was null and void and not worth a damn.

Then I boldly challenged the tax claim of the United States. The Federal Supreme Court (that exhalted 5 to 4 tribunal) has held that a previously filed consensual lien will not take priority over a subsequent federal tax lien unless the contract lien is in all respects choate; and with all of its billing and cooing about ‘choateness’ this supreme tribunal has spread desolation and woe among contractual lienors.

But, on bended knee, I fervently contended before Chancellor Love that your floating lien on merchandise was ‘choate’ and so entitled to priority over the federal tax liens; and, after I had concluded my peroration, the judge solemnly declared that your lien was the choatest lien he had even seen!

So the government that whipped Germany and Japan could not whip me.

Just before the receivership was proceeding was instituted, Mr. Morrow was able to pick up all of Lyon’s inventory then remaining in Mr. Edwards’ store. I enclose the Receiver’s check for $1,727.94 representing you interest in the proceeds from the sale of the remaining inventory. I also enclose a receiver’s assignment to you of various receivables and accounts on which you are decreed to have a first lien, together with a check for $8.00 representing a collection on one of these accounts.

Other enclosures are -

My services in this matter involved six trips to El Dorado; and an additional trip to El Dorado was made by our Mr. Pat Reilly, who appeared pro hac vice as your attorney one day when I was sick in bed with my kidneys. I have charged no expense account on account of my personal trips because each one permitted me to have a visit with my daughter and her family. I am charging you $700 for my services in this matter. At your convenience you can send me a check for this miserable pittance.

Statement covering our fee and expense is also enclosed.

Your Mr. Morrow helped me and sustained me during this litigation; and he has represented you ably in this matter.

Yours truly,

Harry E. Meek

HEM/h

enclosures

cc: Mr. Frank Lyon