Fifth Circuit Issues New Decision on Personal

WINTER 2007
Fifth Circuit Issues New
Decision on Personal
Jurisdiction Based on
Specific Conduct of a
Defendant
Texas Insurance Law:
The Status of
Reimbursement of the
Insurer by the
Policyholder After Noncovered Claims are
Settled
The Issue of Indemnity
for Component Part
Manufacturers
I Can Appeal Even If I
am Not A Named
Party?: Texas’s Virtual
Representation
Doctrine and What It
Means to Litigants
A New Look for the
Texas Judiciary
Texas Supreme Court
Weighs In Again on
Punitive Damages and
Attorneys’ Fees Awards
Upcoming Aviation
Events
Fifth Circuit Issues New Decision on Personal
Jurisdiction Based on Specific Conduct of a
Defendant
since the owner did not expect that the lessee would
Addressing
what
it
transport the helicopter to Mississippi.
characterized as a holding of
The plaintiff asserted four claims against the
first impression with regard
designer of the helicopter platform: defective design,
to
specific
personal
failure to warn, negligence, and negligence per se.
jurisdiction, the Fifth Circuit
The Court, in analyzing whether jurisdiction could
Court of Appeals recently
be maintained over the designer, held (in what it
issued its opinion in Seiferth
characterized as a holding of first impression) that
v.
Helicopteros
Atuneros,
Inc.,
BRAD BROWN
when a plaintiff alleges causes of action against a
04-05-00856-CR (5th Cir.
defendant who challenges personal jurisdiction and
Dec. 11, 2006), a wrongful death case filed in
the asserted basis of personal jurisdiction is specific
Mississippi arising out of the failure of a helicopter
(as opposed to general) conduct in the forum state,
external work platform during an aerial inspection
the plaintiff must demonstrate specific jurisdictional
of power lines. Generally, in diversity cases, in order
facts as to each cause of action. Otherwise, the Court
to establish personal jurisdiction a court must find
wrote “[p]ermitting the legitimate exercise of specific
that (1) the forum state’s long-arm statute must confer
jurisdiction over
personal
one claim to justify
jurisdiction;
It would be prudent to conduct an in-depth the exercise of
and (2) the
jurisdictional analysis of each cause of action specific jurisdiction
exercise of
asserted by the plaintiff to determine which over a different
jurisdiction
causes of action might not satisfy the Fifth claim that does not
must
not
Circuit’s personal jurisdiction test.
arise out of or relate
exceed the
to the defendant’s
boundaries of
forum contacts would violate the Due Process
the Due Process Clause of the Fourteenth
Clause.” Consequently, upon analysis, the Fifth Circuit
Amendment. Here, two defendants, the owner of
found that the plaintiff ’s claims of failure to warn,
the helicopter, and the designer of the work platform,
negligence, and negligence per se properly invoked
contested personal jurisdiction. Upon its analysis,
jurisdiction because the defendant engaged in work
the Fifth Circuit found that Mississippi’s long-arm
testing and inspecting the platform in Mississippi
statute reached both defendants. However, as for
(where the accident occurred), but rejected as outside
the helicopter’s owner, which had leased the helicopter
the Due Process Clause’s scope of permitted personal
to another entity, the Court not only found that the
jurisdiction the claim of design defect since the
owner did not have minimum contacts with
design work took place in another state (Florida).
Mississippi so as to confer jurisdiction over it, but
Therefore, based on this new opinion, in cases
the Court rejected the plaintiff ’s argument that by
filed in Federal Court (at least in the Fifth Circuit
placing the helicopter into the stream of commerce,
states) where jurisdiction is based on specific conduct
the owner “purposefully directed its activities at
of a defendant, it would be prudent to conduct an
Mississippi and thus subjected itself to the jurisdiction
in-depth jurisdictional analysis of each cause of action
of Mississippi courts.” While the stream of
asserted by the plaintiff to determine which causes
commerce theory applies to the purchase, not lease,
of action might not satisfy the Fifth Circuit’s personal
of products, the Court nevertheless found that the
jurisdiction test.
stream of commerce theory would not apply here
Aviation FlyerTM is published periodically by the law firm of Jackson Walker L.L.P. to inform readers of recent developments in aviation law and related areas. It is not intended nor should it be used as a substitute for legal advice or
opinion, which can be rendered only when related to specific fact situations.
More information regarding Jackson Walker may be found on the Internet at www.jw.com.
TRADITION
AND
INNOVATION
SINCE
1887
© 2007 Jackson Walker L.L.P.
Texas Insurance Law: The Status of Reimbursement of the Insurer
by the Policyholder After Non-Covered Claims are Settled
Excess Underwriters at Lloyd’s, London v. Frank’s
further held that under circumstances where coverage is disputed,
Casing Crew & Rental Tools, Inc., WL
the insurer is presented with a reasonable settlement demand within
1252321 (Tex. May 27, 2005) is undoubtedly
policy limits and the insurer funds the settlement, the insurer is
the most important insurance law decision
precluded from seeking reimbursement for the non-covered claims
handed down by the Texas Supreme Court
that were settled unless it has first obtained the policyholder’s “clear
in several years because of its effect on an
and unequivocal consent” to both the settlement and its right to
ANDREW D. GRAHAM
insurer’s reimbursement rights. The majority
seek reimbursement. Id. at 135.
opinion in Frank’s Casing granted insurers
In Frank’s Casing, however, the Texas Supreme Court
an extensive right of reimbursement against policyholders when
dramatically departed from Matagorda County and declared that “a
claims for which coverage is disputed are settled. Notably, the
right of recoupment can arise even absent an insured’s express agreement
majority opinion was authored by Justice Owen, now a member of
to reimburse settlement payments made by an insurer if there is no
the Fifth Circuit Court of Appeals. On January 6, 2006, the Texas
coverage…” Frank’s Casing, WL 1252321, at *1 (emphasis added).
Supreme Court granted rehearing. The Court’s opinion on rehearing
More particularly, the majority held that an insurer may seek
has not yet been handed down.
reimbursement when the insurer has timely asserted its reservation
The issue in Frank’s Casing, as framed by the Court, was whether
of rights, notified the policyholder that it intends to seek
certain excess insurance carriers that disputed coverage, but that
reimbursement, paid to settle non-covered claims, and: (1) a
settled third-party claims against their insured, were entitled to
policyholder has demanded that its insurer accept a settlement offer
recoup the settlement payments from their insured when it was
within policy limits or (2) when an insured expressly agrees that the
later determined that the claims against the
settlement offer should be accepted.
insured were not covered.
Id. at *3. As to the first
The majority opinion in
Briefly stated, the facts before the Court
circumstance, the majority
Frank’s Casing granted
were these: Frank’s Casing, the policyholder,
reasoned that if a policyholder
insurers an extensive right of
was sued after the collapse of an offshore
demands that its insurer pay a
reimbursement against
platform. Excess Underwriters, Frank’s
settlement offer within policy
policyholders when claims
excess liability carrier, disputed coverage.
limits, the settlement offer is
for which coverage is
Frank’s sent the plaintiff ’s settlement offer
deemed reasonable. As to the
disputed are settled.
to Excess Underwriters and demanded that
second, the Court explained that
it pay the settlement in full or risk exposure
“[a]n insured who agrees to the
to liability beyond the policy limits under the Stowers doctrine. In
settlement and benefits by having claims against it extinguished
response, Excess Underwriters stated that it would pay the settlement
cannot complain that it must reimburse its insurer if the claims
amount only if Frank’s agreed that all coverage issues could be
against [it] were not covered by its policy.” Id. at *5. It should also
resolved at a later date. Frank’s declined. Afterwards, Excess
be noted that the Court, without explanation, announced that “there
Underwriters informed Frank’s that it would pay the full settlement
are additional circumstances that will give rise to a right of
demand and then seek reimbursement for all non-covered claims.
reimbursement.” Id. at *6.
The trial court entered a take-nothing judgment for Frank’s on
In reaching its holding, the majority markedly concluded that a
the reimbursement issue, and the court of appeals reluctantly
right to reimbursement is “[i]mplied by law. It is quasi-contractual.”
affirmed. Both courts concluded that the Texas Supreme Court’s
Id. at *5. In so holding, the Court made clear that an insurer’s right
decision in Texas Association of Counties County Government Risk
to reimbursement does not have to be expressly set out in the policy.
Management Pool v. Matagorda County, 52 S.W.3d 128 (Tex. 2000),
In sum, at least for the time being, Frank’s Casing has dramatically
which had been handed down only five years earlier, controlled the
changed the legal landscape regarding an insurer’s right to recover
reimbursement issue.
funds expended to extinguish non-covered claims. We will provide
In Matagorda County, the Court held that if no right of
an update on this case once the Court issues its opinion on
rehearing.
reimbursement is provided for in the policy, an insurer cannot
unilaterally create a reimbursement right. Id. at 131-32. The Court
Andrew D. Graham is an associate in Jackson Walker’s trial and appellate sections. Mr. Graham’s
practice focuses on complex commercial and tort litigation. Additionally, Mr. Graham handles
appeals in both state and federal appellate courts.
2
The Issue of Indemnity for Component Part
Manufacturers
In General Motors Corp. and Rawson-Koenig,
component part thereof in the stream of commerce.” The Court
Inc. v. Hudiburg Chevrolet, Inc. and Hudiburg
clarified these definitions by stating that while all manufacturers
Chevrolet Holding, Inc., the Texas Supreme
are also sellers, not all sellers are manufacturers. The only exception
Court attempted to clarify the role of
to the ability of one person being able to be classified as both a
indemnity when component part
seller and a manufacturer is “a wholesale distributor or retail seller
manufacturers are involved. In General
who completely or partially assembles a product in accordance with
Motors, one plaintiff purchased a truck from
the manufacturer’s instructions shall be considered a seller.” The
CRYSTAL L. WORTHEN
Hudiburg Chevrolet. The chassis, which was
fact that the definitions cause overlap becomes important under the
manufactured by General Motors, was
statute because it creates a duty of indemnity for the manufacturer
attached to a Rawson-Koening service bed. The bed and chassis
of a component to an innocent seller/manufacturer of a finished
had been attached by B&M Truck Equipment, at the direction of
product for defects arising from the component part. It also creates
Hudiburg. Approximately seven years later, plaintiff Seaton was
a duty for the manufacturer of the finished product to indemnify an
driving the vehicle when it was struck from behind by another
innocent seller/manufacturer of a component part for the same loss.
driver. In the accident, the trailer broke away, causing the truck’s
If neither are innocent, the claims for indemnity of both will fail. If
fuel systems to separate and
both are innocent, the claims will offset
spill fuel. The other driver
each other.
was killed, and another person
The Court further explored what
The Court wrote that “a seller who invokes the right to indemnity. The
injured, by the resulting fire.
has a product altered in a way that Court ultimately held that the plaintiff ’s
Mr. Seaton and the estate of
causes loss is not, at least in relation pleadings must “fairly allege a defect in
the other driver filed suit
to the manufacturer, innocent, even the component itself, not merely a defect
against Hudiburg and GM,
if the seller cannot be held liable to in the seller’s product of which the
but did not file suit against
an injured plaintiff for its conduct.” component was part.” In the instant
Rawson-Koening. Hudiburg
filed cross-claims for
case, the plaintiffs did not specifically
contribution and indemnity
plead any defect in the component part.
against Rawson-Koening. Hudiburg and GM both settled with the
The mere reference to the service body was not enough in and of
plaintiffs. Hudiburg then brought suit against GM, Rawsonitself to be considered an allegation that the service body was
Koening, and B&M for indemnity under common law and §82.002
defective. Because there was no assertion by the plaintiffs that they
of the Texas Civil Practice and Remedies Code. B&M eventually
considered the service body itself to be defective, the Court held
filed for bankruptcy and was nonsuited.
that Hudiburg was not entitled to indemnity from Rawson-Koening.
The Texas Supreme Court began its opinion by distinguishing
While the Court agreed with Hudiburg that merely selling a
between common law and statutory indemnity. “Under common
defective truck does not create independently liability, if B&M’s
law, a person is entitled to indemnity for products liability only if
faulty assembly of the truck caused the injuries, that fault is
his liability is entirely vicarious, and he himself is not independently
attributable to Hudiburg because they hired B&M to assemble the
culpable. The indemnitor must be liable or potentially liable for the
truck. The Court wrote that “a seller who has a product altered in
product defect, and his liability must be adjudicated or admitted.”
a way that causes loss is not, at least in relation to the manufacturer,
With §82.002, the indemnitee must be innocent; however, to escape
innocent, even if the seller cannot be held liable to an injured plaintiff
the duty to indemnify, “the indemnitor must prove the indemnitee’s
for its conduct.” Therefore, GM did not have a statutory or common
independent culpability.” The duty under §82.002 is triggered by
law duty to indemnify Hudiburg for losses that are attributable to
the plaintiff ’s pleadings. Therefore, only the manufacturer of a
Hudiburg, and GM was only liable at common law to the extent
product claimed in plaintiff ’s petition to be defective has a duty of
that GM was at fault. If Hudiburg followed GM’s instructions for
indemnity.
assembling the truck, GM was liable to indemnify Hudiburg for
Section §82.002 defines seller and manufacturer. A seller is
the loss, except for that loss which is attributable to Hudiburg. If
defined as “a person who is engaged in the business of distributing
Hudiburg did not follow GM’s instructions, then GM and Hudiburg
or otherwise placing, for any commercial purpose, in the stream of
are liable to each other for indemnity under the statute except for
commerce for use or consumption a product or any component
losses attributable to the other. The Court reiterated its holdings in
part thereof.” Manufacturer is defined as “a person who is a
earlier decisions and stated that §82.002 does not allow a finisheddesigner, formulator, constructor, rebuilder, fabricator, producer,
product manufacturer to shift the burden to component-product
compounder, processor, or assembler of any product or any
manufacturers whose products are not related to the defects alleged
component part thereof and who places the product or any
by the plaintiff.
Crystal L. Worthen is a graduate of Baylor University Law School and an associate in the
litigation section at Jackson Walker. Ms. Worthen’s practice includes representation of airlines
in personal injury matters.
3
I Can Appeal Even If I am Not a Named Party?: Texas’s Virtual
Representation Doctrine and What It Means to Litigants
The Texas Supreme Court recently
named – party status.” 184 S.W.3d at 722. One may be entitled to
determined that the Texas Court of Appeals
invoke the doctrine even after the judgment being appealed has
abused its discretion by refusing to let an
been rendered.
insurance company, not originally named as
In most cases, only a party of record with the court may appeal
a party, intervene under the equitable virtual
a trial court’s judgment. However, if the three requirements of the
representation doctrine. The facts behind the
virtual representation doctrine are met, a non-named party may
dispute
in
In
re
Lumbermens
Mutual
Casualty
appeal. The Court explained that the third factor, whether there is
MEGAN HONEY
Company, 184 S.W.3d 718 (Tex. 2006), began
an identity of interest between the entity and a named party, does
with the explosion of a gas well in Louisiana,
not require the exact same interest to be held by both entities. In
which resulted in seven deaths. Four of the decedents were
fact, the Court recognized that the position of the entity attempting
employees of a company named Cudd Pressure Control, which
to invoke the doctrine and the named party will have often diverged
provided certain services during well-servicing procedures. The
to some extent by the time the doctrine is invoked.
families of these
Nevertheless, the party wishing to intervene must do so in a
employees brought
timely fashion. In determining
suit against Cudd and
timeliness, a court must
The virtual representation doctrine
the owner of the gas
examine the petition under the
allows a party that is affected by a
wells,
Sonat
Fifth Circuit’s four-factor test.
judgment, but not as a named
Exploration Company.
The considerations under this
party, to appeal the judgment even
However,
Cudd
test are (1) the length of time
after it has been rendered. Thus,
refused to indemnify
during which the would-be
an appeal may be allowed after
Sonat.
Sonat’s
intervenor should have known
judgment by a non-named party in
insurance company,
of its interest in the case before
certain circumstances.
Lumberman’s Mutual
attempting to intervene; (2) the
Casualty Company,
extent of prejudice that the
did not provide coverage to Sonat. As a result, Sonat filed a claim
existing parties may suffer as a result of the would-be intervenor’s
against Cudd for indemnification.
failure to apply for intervention as soon as it actually knew or should
One of the issues presented to the trial court was whether Texas
have known of its interest in the case; (3) the extent of prejudice
or Louisiana law applied to the indemnity claim, an issue that would
the would-be intervenor would suffer if intervention is denied; and
potentially determine the outcome of the entire case. The court
(4) the existence of unusual circumstances militating either for or
concluded Texas law applied, and the case went to trial on the
against a determination that the application is timely.
damages issue alone. Cudd appealed the adverse verdict, and
The Texas Supreme Court was careful to emphasize that
Lumberman’s actually posted the appellate security.
the application of this doctrine is equitable in nature and not a
Cudd and Sonat then entered into an agreement whereby Cudd
hard-fast rule. Therefore, a court must consider all factors that may
agreed to forego any further challenge of the trial court’s choice of
weigh for or against the application of the doctrine. Furthermore,
law ruling, among other things. Ten weeks after Cudd filed its
the tone of the Court in its opinion implies that the doctrine will
appellate brief on the remaining issues, Lumberman’s asked the
not be freely applied.
court to intervene, or to become a party, under the virtual
Nevertheless, the virtual representation doctrine is an important
representation doctrine to preserve the choice of law issue. The
device to be aware of and may be extremely useful to a party in
court of appeals denied Lumberman’s request, and the Texas Supreme
some situations. The doctrine allows a party that is affected by a
Court reviewed the decision under an abuse of discretion standard.
judgment, but not as a named party, to appeal the judgment even
Under the virtual representation doctrine, an entity is deemed a
after it has been rendered. Thus, an appeal may be allowed after
party if (1) it will be bound by the judgment, (2) its privity of
judgment by a non-named party in certain circumstances. Moreover,
interest appears from the record before the court, and (3) there is
parties must be aware of both non-named entities that may have a
an identity of interest between the entity and a named party to the
virtual representation argument and situations in which an entity
judgment. Although an entity may have already been “deemed” a
may appeal a judgment under this doctrine. Parties should be mindful
party under the circumstances, it must still take “some timely,
of this doctrine when determining what parties to name in a suit
appropriate action [for example, a motion to intervene] to attain
and whether or not to intervene at the trial court level.
Megan Honey is an associate in the litigation practice group. Ms. Honey graduated from Wake
Forest School of Law and has worked with the aviation practice group since joining Jackson
Walker.
4
A New Look for the Texas Judiciary
Whether it is a Texas Supreme Court justice
or the local Justice of the Peace, every nonfederal judge in Texas must run for election:
every six years for appellate judges and every
four years for trial judges. Until President
Reagan came into office in 1980, the majority
of the judges of Dallas County and throughout
BOB RUCKMAN
Texas ran as Democrats. However, most of
the Democratic judges were swept out of
office with the Reagan landslide, and until this past November, the
majority of the sitting judges in Dallas County and most of the
major Texas metropolitan areas were Republican.
This past November, all 42 Dallas County Republican judges
that were up for re-election lost to their Democratic opponents. As
a result, many highly experienced trial judges left the bench January
1, 2007. The 42 new judges are now settling in and bringing
varying degrees of experience. Some have been former judges and
should take no time to get up to speed, while others have little or no
judicial experience and, in some cases, limited experience as trial
attorneys. Many are simply not known to the attorneys who will
practice in their courts.
While there were some changes in judges in other major cities,
nothing was as dramatic as Dallas County. Further, in the only
contested race on the nine member Texas Supreme Court for this
year, the Republican incumbent was successful in defeating his
Democratic challenger, and the Texas Supreme Court remains
Republican.
For years, individuals such as former Supreme Court Chief
Justice Tom Phillips and Justice John Hill have campaigned to alter
the method of judicial selection in Texas, but have met with little
success in the Texas legislature. Prospective judges usually affiliate
with a political party in order to get elected and often must solicit
campaign contributions from the same attorneys who will appear
in their courts. With the recent events in Dallas County, however,
it has given a new emphasis to remove the selection of judges from
partisan politics and move on to some other system. While it still
may be workable to elect judges in rural areas where the voters have
an opportunity to actually know the judge, the system is obviously
not working in our metropolitan areas where even the attorneys do
not know all of the judges whose names appear on the ballot and a
shift in national politics can cause an upheaval in what is considered
to be a non-partisan office.
Bob Ruckman heads the aviation practice group for the firm. He specializes in aviation
negligence and product liability cases and has over 25 years of experience. His practice
primarily involves representation of airlines, aircraft or aircraft component part manufacturers,
and aviation insurers or individuals involved in aviation or related business.
Texas Supreme Court Weighs In Again on Punitive Damages and
Attorneys’ Fees Awards
In Tony Gullo Motors v. Chapa, 04-0961 (Tex.
Dec. 22, 2006), the Texas Supreme Court
reviewed, among other things, whether the
exemplary damages awarded to plaintiff were
constitutional. The underlying claim began
as a lawsuit about a car dealership’s alleged
“bait and switch” tactics. However, the case
BRAD BROWN
ultimately developed into a suit that presented
the Court with numerous issues, including
the constitutional limits on an award of exemplary damages.
Upon first review, the court of appeals previously halved
plaintiff ’s exemplary damages award. However, the reduced
exemplary damages still exceeded four times plaintiff ’s total
compensatory award and was more than 17 times plaintiff ’s
economic damages. After conducting a thorough analysis, the Texas
Supreme Court, while finding that defendant’s conduct merited
exemplary damages, concluded that the amount of punitive damages
awarded to plaintiff (as reduced by the court of appeals) was
unconstitutional.
The Court further went on to discuss the awarding of attorneys’
fees and reaffirmed the long standing rule that if attorneys’ fees
related to a claim for which no fees are legally recoverable, a plaintiff
must segregate recoverable from unrecoverable fees. The Court
wrote that merely having “intertwined facts [giving rise to both
contract and tort claims] do not [necessarily] make tort fees
recoverable; it is only when discrete legal services advance both a
recoverable and unrecoverable claim that they are so intertwined
that they need not be segregated.”
Brad Brown is a partner in the aviation practice group. Mr. Brown’s primary practice focuses
on aviation related claims, including litigating negligence, personal injury/wrongful death, product
liability, toxic tort, commercial and cargo cases for domestic and international airlines, insurance
companies, manufactures, business entities, and individuals in both state and federal courts.
Mr. Brown also frequently handles DTPA and insurance coverage matters.
5
Upcoming Aviation Events
February 22 - 23, 2007
Journal of Air Law and Commerce
41st Annual SMU Air Law Symposium
Hotel Intercontinental
Dallas, Texas
www.smu.edu/lra/symposia/als/overview.asp
April 28 - May 1, 2007
AIA 2007 Annual Conference
Hyatt Grand Champions Resort & Spa
Indian Wells, California
www.aiaweb.org
June 19 - 22, 2007
Air Race Classic
www.airraceclassic.org
February 28 - March 1, 2007
31st Annual FAA Aviation Forecast Conference
Washington Convention Center
Washington, D.C.
apo.faa.gov/Conference/welcome.htm
June 21, 2007
State Bar of Texas Aviation Law Section Annual Meeting
Marriott River Center and Convention Center
San Antonio, Texas
February 29 - March 4, 2007
Lawyer Pilot’s Bar Association Winter 2007 Meeting
Rancho Bernardo Inn
San Diego, California
www.lpba.org
July 23 - 29, 2007
EAA AirVenture
Oshkosh, Wisconsin
www.eaa.org
March 1 - 3, 2007
HELI-EXPO 2007
Orange County Convention Center
Orlando, Florida
www.heliexpo.com
August 1 - 5, 2007
Lawyer Pilot’s Bar Association Summer 2007 Meeting
Chateaux at Silver Lake Resort
Park City, Utah
www.lpba.org
March 11 - 13, 2007
ISTAT 24th Annual Conference
JW Marriott Desert Ridge
Phoenix, Arizona
www.istat.org
Austin
100 Congress Avenue, Suite 1100
Austin, Texas 78701
(512) 236-2000 • fax (512) 236-2002
Dallas
901 Main Street, Suite 6000
Dallas, Texas 75202
(214) 953-6000 • fax (214) 953-5822
September 12 - 16, 2007
The Ninety-Nines, Inc. 2007 International Convention
Omni Interlocken Resort
Boulder / Denver, Colorado
www.ninety-nines.org
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AND
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1887
901 Main Street
Suite 6000
Dallas, Texas 75202
Fort Worth
301 Commerce Street, Suite 2400
Fort Worth, Texas 76102
(817) 334-7200 • fax (817) 334-7290
Houston
1401 McKinney Street, Suite 1900
Houston, Texas 77010
(713) 752-4200 • fax (713) 752-4221
San Angelo
301 West Beauregard, Suite 200
San Angelo, Texas 76903
(915) 481-2550 • fax (915) 481-2552
San Antonio
112 East Pecan Street, Suite 2400
San Antonio, Texas 78205
(210) 978-7700 • fax (210) 978-7790
6