Richards Asset Mgmt. Trust, et al. - Page 8




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          requests for production of documents:                                       
                    With respect to Interrogatory No. 5, including all                
               of its subparts and subparagraphs, please provide                      
               complete and correct copies of all original trust                      
               documents and subsequent modifications or amendments                   
               which substantiate or support your response.                           
                  *       *       *       *       *       *       *                   
                    With respect to Interrogatory No. 10, including                   
               all of its subparts and subparagraphs, please provide                  
               all documents and materials which support or substanti-                
               ate your response.                                                     
               Respondent also attached to respondent’s respective discov-            
          ery motions in the cases at docket Nos. 10765-00 and 10766-00 the           
          so-called Branerton letter dated June 22, 2001, that respondent             
          had sent to Ms. Jackson, one of petitioners’ then two attorneys-            
          of-record in these cases.  That Branerton letter requested, inter           
          alia:                                                                       
               All receipts for income and expenditures for the tax-                  
               able years 1996 and 1997, and any other records of                     
               income received by the above-referenced petitioners                    
               [petitioners in the cases at docket Nos. 10764-00                      
               through 10767-00] or member of their immediate family                  
               (if applicable) or any related party or entity, in                     
               which they exercised control or received an economic                   
               benefit * * *                                                          
          Respondent sought similar information in respondent’s discovery             
          requests that were attached to respondent’s respective discovery            
          motions in the cases at docket Nos. 10765-00 and 10766-00.                  
               On July 30, 2001, respondent sent a letter to Mr. Wise,                
          which respondent attached to respondent’s discovery motions in              
          the cases at docket Nos. 10765-00 and 10766-00 and in which                 






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