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August 31, 2001


NOTICE: To all the heirs of Jose Manuel Ballí Villarreal

RE: Cause No. 1261; The John G. and Marie Stella Memorial Foundation v. Sylvia Menchaca Ballí Aguilera, In the 105th District Court of Kenedy County, Texas.

A change of venue has been filed by Ballí family member and attorney, Hector Cárdenas. The purpose of the motion is to remove the case from Kenedy County to a county where all the heirs of Jose Manuel Ballí Villarreal can receive a fair and impartial trial.

The following is a summary of Mr. Cárdenas' arguments in the motion:

1. In Kenedy County, there exists so great a prejudice that the heirs of Jose Manuel Ballí Villarreal cannot obtain a fair and impartial trial.

2. The influence of the Kenedy Foundation and their predecessors, the Kenedy family, is so strong in Kenedy County that the entire county was named Kenedy County. Several towns in Kenedy County are named after the first names of members of the Kenedy family, i.e. the town of Mifflin was named after Mifflin Kenedy. Sarita, the seat of Kenedy County was named after Sarita Kenedy East, the person who created the Kenedy Foundation.

3. There are simply not enough people in Kenedy County to conduct a trial of this magnitude. The 2000 census shows that only 414 live in the county, including children. Thus, there are less than 300 adults from which to pick a jury - and they all rely upon the Kenedy Foundation to earn a living.

4. Our family would also not be able to get a fair trial in either Kleberg County or Nueces County if the change of venue of this case was changed to either county, because the same prejudice against our family exists in both counties. There is also a combination against the heirs of Jose Manuel Ballí Villarreal in both Kleberg County and in Nueces County that would prevent us from obtaining a fair and impartial trial. For example, the patriarchs of Kenedy County and Kleberg County were once business partners, i.e. Mufflin Kenedy and Richard King, respectfully. Kleberg County is named after Robert Kleberg, the son-in-law of Richard King, the founder of the King Ranch. Many of the people in Kleberg County and Nueces County either directly and/or indirectly depend on the King Ranch to earn a living, and the King Ranch is very influential in Kleberg County as well as in Nueces County, both politically and economically.

5. A fair and impartial trial is simply not possible in either Kleberg County or Nueces County for other reasons. The beneficiary of the Kenedy Foundation is the Catholic Diocese of Corpus Christi, the headquarters of which is in Nueces County.

Our cousin is fighting to get the venue of the case changed to one of the adjacent counties in the following order of preference: Hidalgo County, Brooks County or Willacy County.

Please pray that Mr. Cárdenas is successful so that we can get a fair trial.