OMNI: OMNI QUANTUM MERUIT

OMNI: OMNI QUANTUM MERUIT

OMNI: OMNI QUANTUM MERUIT

OMNI: OMNI QUANTUM MERUIT

Hoblit told David McCall that “…if we (the McCalls) went forward, we were going to find out what it’s like to piss off a billionaire (Rowling).”

In a bill of exception hearing during the trial of this case, which
testimony was not offered at trial, David McCall testified that he spoke by phone
with R. Clay Hoblit, Tana’s lead attorney, who yelled and screamed at him. (RR
Vol. 3, pp. 107-108). During the conversation, Hoblit told David McCall that “…
if we (the McCalls) went forward, we were going to find out what it’s like to piss
off a billionaire (Rowling).” (Emphasis added; RR Vol. 3, pp. 109-110). David
McCall also received a letter from R. Clay Hoblit stating, in relevant part, that “If
you choose to proceed with the lawsuit, we will obviously avail ourselves of all
legal remedies against you and your clients.” (Emphasis added; P. Ex. 4).
On November 2, 1995, the fax machine in McCalls’ office started running
and Tom McCall saw that Tana had filed a lawsuit in Nueces County, Texas. (RR
Vol. 3, p. 129, l. 1-25). After reading Tana’s allegations that the McCalls and
Niemeyers had breached their contract and lease with Tana, Tom McCall thought
Tana was trying to play a joke or intimidate the McCalls.