Michael J. Downing and Sandra M. Downing - Page 19

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          petitioners told Klimkiewicz that there was a box in which the              
          proceeds from the Newman property and other cash savings were               
          kept, and that only Michael had access to this box.  Michael told           
          Klimkiewicz that he alone had a key to the box, and that he alone           
          knew the amount of cash in the box.  He also provided to                    
          Klimkiewicz a typed statement he had prepared, indicating that,             
          as of January 1, 1994, he had accumulated a cash hoard of roughly           
          $180,000 in the box.  When Klimkiewicz asked petitioners at this            
          meeting how much cash remained in the box at that time, Michael             
          told her that, while he did not know the exact amount of cash               
          remaining in the box, she could determine the amount by                     
          subtracting out--presumably from the roughly $180,000 cash hoard            
          that he said at this meeting had been in the box at the beginning           
          of 1994--the amount that she was proposing as an understatement;            
          the resulting amount would be the amount of cash remaining in the           
          box as of that date.  At trial, Michael testified that there was            
          roughly $60,000 to $70,000 in the box at the beginning of 1994,             
          and that he ran out of money in the box a year after he bought              
          the Metairie Court property.                                                
               Also at the July 1997 meeting, Michael provided to                     
          Klimkiewicz a written statement in which he indicated that he did           
          not use any of his cash savings from the time he was 12 until the           
          beginning of 1994.                                                          








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