Richards Asset Mgmt. Trust, et al. - Page 17




                                       - 17 -                                         
          Richards, and Richards Charitable Trust.                                    
               At the conclusion of the trial in these cases on October 15,           
          2001, the Court orally ordered respondent to file on or before              
          November 2, 2001, a written motion to dismiss for lack of prose-            
          cution in each of these cases.  Thereafter, the Court granted               
          respondent’s motion to extend the time within which to file each            
          such motion.  By Order dated October 15, 2001 (October 15, 2001             
          Order), the Court ordered the parties in these cases to file                
          simultaneous opening briefs on or before November 29, 2001.                 
               On November 13, 2001, respondent timely filed a written                
          motion to hold petitioner in default in each of the cases at                
          docket Nos. 10764-00 and 10767-00 and a written motion to dismiss           
          for lack of prosecution and to impose sanctions under section               
          6673 in each of the cases at docket Nos. 10765-00 and 10766-00.             
          (For convenience, we shall refer to each of the latter two                  
          motions as respondent’s motion to dismiss for lack of prosecu-              
          tion.)                                                                      
               On December 3, 2001, the Court sua sponte issued separate              
          Orders (December 3, 2001 Show Cause Orders) directing each party            
          in the case at docket No. 10764-00 in which Richards Asset                  
          Management Trust is named as petitioner and in the case at docket           
          No. 10767-00 in which Richards Charitable Trust is named as                 
          petitioner to                                                               
               show cause in writing why the Court has jurisdiction                   
               over this case, including the identity of any purported                





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