in the circuit court of jackson county, missouri, at independence

fund about Medical Supply being considered as a venture
capital candidate.
56. SAMUEL LIPARI was instructed to send an executive
summary of his business plan via email. (Exb 1.)
57. SAMUEL LIPARI sent the summary and financial
projections for Medical Supply with a restriction on
disclosure notice.
58. Piper Jaffray made no response to the receipt of the
executive summary and financial projections from Medical
Supply’s business plan.
59. SAMUEL LIPARI again telephoned the Minneapolis offices
of the Piper Jaffray venture fund managers and his calls
were not taken and not returned.
60. SAMUEL LIPARI also attempted to speak to a Piper
Jaffray venture fund manger in their San Francisco office
but again, his calls were not taken or returned.
61. On 7/9/02 SAMUEL LIPARI and Medical Supply were
visited by a Merger and Acquisitions attorney for another
San Francisco venture capital firm and after extensive
discussions with her at Medical Supply’s Blue Springs, MO
headquarters on the need to quickly enter the healthcare
supply chain market and take advantage of the opportunity
created by the healthcare industry’s sudden willingness to
reject the existing Group Purchasing Organizations, and
14