Angela Schwimmer - Page 5

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                In 1983, one of Martin's controlled partnerships made a                      
          $615,000 payment representing a contribution into a split-funded                   
          defined benefit retirement plan trust.  Pursuant to the plan,                      
          life insurance policies on Martin's and petitioner's lives were                    
          to be purchased, and funds were to be deposited into a separate                    
          investment account, to be invested at the discretion of Martin,                    
          the plan's trustee and administrator.  Martin and petitioner, as                   
          participants in the plan, were each a beneficiary on each other's                  
          life insurance policies and were entitled to retirement benefits                   
          upon reaching retirement age.  Before Martin and petitioner                        
          reached retirement age or received any benefits, all assets of                     
          the plan's trust were forfeited to the U.S. Government, as                         
          described below.                                                                   

          Martin's Embezzlement Activity                                                     
                During 1981, 1982, 1983, and 1984, Martin and a co-                          
          conspirator, taking advantage of their relationship with First                     
          United, illegally transferred in excess of $16 million from the                    
          bank accounts of two labor unions’ employee benefit plan trusts                    
          to private bank accounts for the personal use of Martin and his                    
          co-conspirator.                                                                    
                In June of 1987, Martin was indicted for racketeering,                       
          embezzlement, unlawful acceptance of pension kickbacks,                            
          conspiracy to defraud the U.S. Government, and income tax                          
          evasion.                                                                           





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