James P. Shea and Patricia H. Shea - Page 11




                                       - 11 -                                         

               We expect Michael to come out of Russia this weekend                   
               and should then be able to get an up date on these                     
               funds.                                                                 
               We believe that the prospects are still favourable and                 
               have every confidence in our part of the operation even                
               though we are working with only half truths.                           
               At some point during 1992, James was repaid $42,000 out of             
          the funds that he had transferred to Quotum.  James asked Brian             
          Wilcox to take steps to obtain a refund of the $250,000 insurance           
          deposit paid by Quotum.  He also attempted to obtain information            
          regarding the deposit himself, but the insurance company refused            
          to provide any information.                                                 
               By letter dated August 14, 1992, Thomas Ziegler, James’                
          lawyer, wrote to Sarah L. Argyle, a British barrister, setting              
          forth some of the background information regarding James’ claim             
          for return of his funds.  Although Ms. Argyle wrote back,                   
          outlining her fee arrangements and enclosing a list of questions,           
          the record does not indicate whether any legal action was taken             
          to recover additional amounts from Brian Wilcox, Wilcox                     
          Engineering, or Houlder Insurance Services (Aviation) Limited.              
               On September 4, 1992, Donnelly filed a chapter 7 bankruptcy            
          petition which listed an unsecured claim by James in the amount             
          of $650,000.  On December 10, 1993, the bankruptcy proceeding was           
          closed.                                                                     









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