Bruce Berg, Stuart Cartner, Kevin Doyle, Walter Haydock, Edward Leh, Kevin Murphy, Philip Schantz, DAIS Partners, L.P., Singer Bros., L.L.C., Skeleton Lake, L.L.C. and Wildcat Lake Partners v. Halo Companies, Inc., Halo Asset Management, L.L.C., Halo Portfolio Advisors, L.L.C., B. Cade Thompson, Paul Williams, Reif Chron, Tony Chron, Halo Asset Management Genpar II, LLC, and Halo Group, Inc.

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ACCEPTED 06-14-00021-CV SIXTH COURT OF APPEALS TEXARKANA, TEXAS 10/30/2015 11:23:51 AM DEBBIE AUTREY CLERK COURT OF APPEALS FILED IN FOR THE SIXTH DISTRICT OF TEXAS 6th COURT OF APPEALS AT TEXARKANA, TEXAS TEXARKANA, TEXAS 10/30/2015 11:23:51 AM DEBBIE AUTREY Clerk NO. 06-14-00021-CV BRUCE BERG, ET AL., Plaintiffs-Appellants, v. HALO COMPANIES, INC., ET AL., Defendants-Appellees. MOTION FOR INVOLUNTARY DISMISSAL Bobby M. Rubarts State Bar No. 17360330 bobby.rubarts@koningrubarts.com Bart Sloan (Of Counsel) State Bar No. 00788430 bart.sloan@koningrubarts.com KONING RUBARTS LLP 1700 Pacific Avenue, Suite 4500 Dallas, Texas 75201 Telephone: (214) 751-7900 Facsimile: (214) 751-7888 ATTORNEYS FOR APPELLANTS TO THE HONORABLE COURT: Plaintiffs/Appellants, through undersigned counsel, pursuant to Texas Rule of Appellate Procedure, Rule 42.3(a), hereby move this Court for an Order that the Appeal brought by Bruce Berg, Stuart Cartner, Kevin Doyle, Walter Haydock, Edward Leh, Kevin Murphy, Philip Schantz, Dais Partners, LP, Singer Bros., LLC, Skeleton Lake, LLC, Wildcat Lake Partners, et al. (collectively referred to as the “Appellants”) be dismissed. The reason for this involuntary dismissal is that the United States District Court, Eastern District of Texas, Sherman Division (Case No. 4:11-CV-655), entered an Order [Dkt. 337] permanently barring all Stewardship Creditors from continuing and/or or asserting or prosecuting any claims or causes of action against Halo. That Order is now a final order. Because the Appellants in this action fall within the definition of “Stewardship Creditors” and because Appellants’ claims relate to investments made in the Stewardship Investment Plan, it appears that Appellants are forever barred from pursuing this appeal thereby divesting this Court of jurisdiction over this appeal. WHEREFORE, Appellants respectfully request that the Court grant this Motion for Involuntary Dismissal and that they have such other relief to which they may be entitled. MOTION FOR INVOLUNTARY DISMISSAL – Page 2 Respectfully submitted, /s/ Bobby M. Rubarts Bobby M. Rubarts State Bar No. 17360330 bobby.rubarts@koningrubarts.com Bart Sloan (Of Counsel) State Bar No. 00788430 bart.sloan@koningrubarts.com KONING RUBARTS LLP 1700 Pacific Avenue, Suite 4500 Dallas, Texas 75201 214.751.7900 (telephone) 214.751.7888 (facsimile) ATTORNEYS FOR APPELLANTS CERTIFICATE OF CONFERENCE I hereby certify that, on August 20-27, 2015, and multiple times thereafter, that counsel for Appellants conferred with counsel for Appellees about the merits of the foregoing motion. Counsel for Appellants stated that Appellees are in agreement with the involuntary dismissal. /s/ Bobby M. Rubarts CERTIFICATE OF SERVICE I hereby certify that a copy of this document was served upon the attorneys of record of all parties to the above cause in accordance with the Texas Rules of Appellate Procedure on this _____ day of October 2015. /s/ Bobby M. Rubarts MOTION FOR INVOLUNTARY DISMISSAL – Page 3