William P. Short, Jr. and Mary E. Short - Page 4

                                         -4-                                          
          The State Court Action                                                      
               On August 3, 1987, F. Michael Parkowski, special counsel and           
          attorney for the State of Delaware, initiated a proceeding against          
          petitioner in the Delaware Chancery Court for Sussex County (the            
          State court action) seeking to quiet title to the disputed land, as         
          well as other relief. The State of Delaware argued that the                 
          disputed land (including the 1988 gift land) had been abandoned by          
          any record title owner or heirs dating back to at least 1914 and            
          had then been acquired by the State through adverse possession long         
          before petitioner began taking action to establish a claim.                 
          Moreover, State surveys conducted in 1914, 1926, 1929, 1955, and            
          1977 consistently showed the disputed land as part of the Delaware          
          Seashore State Park.  Maps also showed the disputed land as part of         
          State park lands.                                                           
               On October 6, 1987, petitioners responded to the State's               
          complaint by an answer and counterclaim.  Petitioners argued that           
          they had legal title to the property based on the 1982 quitclaim            
          deed as well as through adverse possession.  In essence, the State          
          considered petitioners' claim of title frivolous.                           
          Petitioners' Appraisal                                                      
               In November 1988, appraiser Laurence P. Moynihan valued the            
          disputed land for petitioners "in order to facilitate a possible            
          donation of the property" to the State of Delaware.  Mr. Moynihan           
          valued an unencumbered fee simple interest in the disputed land at          
          $30,130,000, including $5,810,000 for the 1988 gift land.                   




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