February 22, 2011

Dan Little, Esq.

Little, Little, Little, Winder, Oliver,
Landgraf & Gallagher, PLLC
P.O. Box 618
Madill, OK 73446

Dear Mr. Little:

Firstly, as I previously indicated to you any settlement would have to include Mr. Huffman
removing his fence and gate from our property as shown by his surveyors report. It would further have
to include at least the amount for which he was sued, $110,000.00 (one-hundred ten thousand) dollars,
as I believe the jury will have the authority to award more. Based on your letter I believe that you
should ready your calendar for trial in this matter and notify your witnesses that they will have to be
present for deposition during the discovery process as well as at trial.

Also, I am a professional and my personal life is not pertinent in this litigation and is thus
irrelevant to any settlement discussion I would have with you. As you have likely done your due
diligence, you have no doubt discovered that I do not shy from threats of, or actual litigation. Charles
Hamilton Houston, the NAACP's first Special Counsel indicated the need for Black lawyers in the
South because White lawyers cannot be trusted to represent the true interest of Black people. So, then
on my experience and knowledge, I would neither trust you nor any other White lawyer to represent the
true interest of me and my family in this matter and you would do well not to intimate that such
motivation precipitates these settlement communications.

Again, my personal aspirations, peace, health or well-being is neither here nor there as to the
instant litigation. And, I would appreciate it, should you choose to continue to attempt to settle this
matter that you not refer to anything pertaining to me or my family's personal interests. This is a real
property case and as professionals let us keep all negotiations germane to that singular issue.

I will prove that all 23 acres are Laura Ayers' through adverse possession, Essie Conway's as
sole heir and myself and my brother, as titled owners, through tacking. Unless you and/or Mr. Huffman
are willing to unequivocally admit these facts and negotiate from there we will be unable to reach any
tenable settlement. My counter-offer is contained in the first paragraph and first sentence of this letter.
To wit, "Mr. Huffman removing his fence and gate from our property as shown by his surveyors report.
It would further have to include at least the amount for which he was sued, $110,000.00 (one-hundred
ten thousand) dollars."

Short of these terms I will see you in court.

Very truly yours,

Lucious Clarence Conway, Jr.