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"Under Hillwood's ownership, the team was deemed the 'worst franchise' in all of professional sports," the brief states. "Under Cuban's stewardship the Mavericks have become one of the league's most successful and are now NBA champions. Accordingly, there can be no genuine question that Hillwood's claims of mismanagement lack merit and Hillwood's claims should be disposed of on summary judgment."Original Mavericks owner Don Carter, a courtside season ticket holder whom Cuban invited on stage to accept the Larry O'Brien Trophy from commissioner David Stern after the Game 6 win over the Miami Heat, is included in the photograph. Perot still owns five percent of the franchise but doesn't attend games.The brief includes the words "World Champion Dallas Mavericks" eight times, including twice in the one-sentence conclusion."For the reasons detailed above, the World Champion Dallas Mavericks and [Radical Mavericks Management] request this court grant summary judgment in their favor on all of Hillwood's claims and award the World Champion Dallas Mavericks and RMM such further relief they are entitled (although they are quite content at the moment)," the conclusion states.