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#357 Motion for Relief from Stay filed by Michael G. Colvard for Creditor International Bank of Commerce.
EXHIBIT AND WITNESS LIST
AO !87 (REV. 4/82)
International Bank of Commerce V. Delta Produce, LP
DISTRICT COURT
Western (San Antonio)
PLAINTIFF'S ATTORNEY DEFENDANT'S ATTORNEY DOCKET NUMBER
12-50073
Michael Colvard Craig Stokes
TRIAL DATE(S)
1112/12
PRESIDING JUDGE ELECTRONIC COURT COURTROOM DEPUTY
JOHN C. AKARD RECORDING OPERATOR JOYCE GUTIERREZ
VIDAL RODRIGUEZ
PLF, DEF DATE MARKED ADMITTED
DESCRIPTION OF EXHIBITS * AND WITNESSES
l\0 NO OFFERED
1-24 11/2/12 XX XX EXHIBITS 1-24 (SEE ATTACHED FOR DESCRIPTION)
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I ;lude notation to the location of exhibit not held with the tile not because of size.
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International Bank of Commerce ("IBC") submits the following Witness & Exhibit
List for the October 30, 2012 hearing in the referenced case.
I. WITNESSES
1. Eugene Hernandez
2. IBC reserves the right to call any witnesses designated or called by Debtor, as well
as to call witnesses to rebut the testimony of any witness.
II. EXHIBITS
JBC designates the exhibits listed on the following that may be offered:
Ex.# Descri12tion Offered Obj'n Admitted Diseosition
1. Delta Produce Marketing, Inc.-
Loan Agreement dated July 17,
'
1998
2. Delta Produce, LP - Promissory
Note dated April 1, 2007 (Account
No. ******9455)
3. Delta Produce, LP - Promissory
Note dated June 4, 2010 (Account
No. ******1270)
4. Delta Produce, LP - Security
Agreement dated March 24, 2006
5. Delta Produce, LP - Security
Agreement dated February, 2008
6. Delta Produce, LP - Security
Agreement dated June 4, 2010
7. Delta Produce, LP - Real Estate
Lien Note dated April 23, 2007
(Account No. ******3788)
8. Delta Produce, LP - Extension
and/or Modification Agreement
Residential Real Estate Lien
I..,..!. ,L .J,
II'"'""""'"""''
1
2010 (Accmmt N(). ~ 7 8 8 )
I
I I
9. Delta Prod LP Exten
and/or Modification Agreement
Commercial Indebtedness dated
April15, 2011 (Account No.
******3788)
10 St(3Ci Properties. Ltd Deed of
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Trust, Assignment of Rents,
Security Agreement and Financing
Statement
11. Staci Properties, Ltd. -Assignment
of Leases and Rents dated April 6,
2007
12. Staci Properties, Ltd. d/b/a Superior
Tomato-Avocado, Ltd.- Promissory
Note dated March 2, 2005 (Account
No. 1400
13. Staci Produce, Ltd.- Extension
and/or Modification Agreement
Commercial Indebtedness dated
April 15, 2011 (Account No.
******1400
14. Staci Produce, Ltd.- Security
A reement dated March 2, 2005
15. Staci Produce, Ltd. Security
Agreement dated December 9,
2005
16. Staci Properties, Ltd. - Real Estate
Lien Note dated March 2, 2005
Account No. ******1397
17. Staci Produce, Ltd., Staci
Properties, Ltd., Delta Produce, LP
and Atled, Ltd.- Loan Agreement
dated March 2, 2005
18. Staci Properties, Ltd. - Deed of
Trust, Assignment of Rents,
Security Agreement and Financing
Statement mated March 2, 2005
19. Atled, Ltd. - Real Estate Lien Note
Account No. ******3709
20. Atled, Ltd.- Extension and/or
Modification Agreement
Commercial Indebtedness dated
April 15, 1 (Account
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12007
24. IBC Account Report
IBC requests that the Court take judicial notice of all filed pleadings, orders,
schedules, and reports.
IBC reserves the right to designate any exhibits presented by any other party.
IBC also reserves the right to designate exhibits not listed here for impeachment
or rebuttal purposes at the hearings.
IBC reserves the right to supplement or amend its Witness and Exhibit Lists any
time prior to the hearings.
IBC requests that the Court take judicial notice of all pleadings and records filed
within this bankruptcy proceeding.
CERTIFICATE OF SERVICE
hereby certify that on October 23, 2012, a true and correct copy of the
foregoing Witness and Exhibit List was served electronically by the Court's PACER
system.


/s/
Michael G. Colvard