Richards Asset Mgmt. Trust, et al. - Page 6




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          discovery) in each of the cases at docket Nos. 10765-003 and                
          10766-00.  In respondent’s motions to compel discovery in each of           
          those cases, respondent represented, inter alia, that counsel of            
          record in each such case, i.e., Ms. Jackson and Mr. Wise, had               
          informed respondent’s counsel that they no longer represented Mr.           
          Richards.  Respondent further represented in respondent’s respec-           
          tive motions to compel discovery in the cases at docket Nos.                
          10765-00 and 10766-00, inter alia, that respondent’s counsel                
          advised both Ms. Jackson and Mr. Wise that respondent would                 
          continue to recognize them as counsel for petitioner in each such           
          case unless otherwise notified by the Court.                                
               Respondent attached as exhibits to respondent’s respective             
          motions to compel discovery in the cases at docket Nos. 10765-00            
          and 10766-00 respondent’s discovery requests.  Those respective             
          discovery requests included the following interrogatories:                  
               Interrogatory No. 5:                                                   
                    Please identify all trusts by name, address and                   
               EIN, for which either petitioner, or both, were the                    
               creator, grantor, settlor, director or beneficiary or                  
               any trust in which petitioners[1] were involved with                   
               [sic] in any way.  For each trust identified, please                   
               state whether the trust has been modified or amended;                  
               and if so, answer the following with regard to each                    
               modification or amendment for each trust:                              


               3Respondent filed discovery motions in the case at docket              
          No. 10765-00 before respondent filed on Oct. 1, 2001, respon-               
          dent’s motion to dismiss that case for lack of jurisdiction as to           
          Joy A. Richards, deceased, and to change caption, which the Court           
          granted on Oct. 12, 2001.                                                   





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