William W. Howard - Page 6

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               The record includes 28 promissory notes in varying amounts             
          totaling in excess of the amounts of income charged to petitioner           
          in the statutory notice, dated from June 30, 1987, through                  
          June 10, 1988, with stated interest of 10 percent, "To be paid              
          at the time the Estate of Zelda Willey Putman is closed", signed            
          by petitioner in connection with purported loans to petitioner              
          from the estate.  Petitioner signed the notes and made the                  
          purported loans to himself without the knowledge or consent                 
          of any of the beneficiaries of the Putman estate.  Petitioner               
          pledged no collateral to secure any of the alleged loans or any             
          of the other payments he made to himself from the estate.                   
               On September 13, 1989, following pleas of nolo contendere,             
          petitioner was convicted on three counts of grand theft in the              
          Circuit Court of Polk County, Florida.  In addition to receiving            
          a prison sentence, petitioner was ordered to pay restitution in             
          the amount of $516,091 to the estate of Mrs. Putman and $48,978             
          to Mr. Putman.  In compliance with the judgment and order of                
          probation, petitioner for a period of 5 years has made timely               
          monthly payments in the amount of $230 per month toward                     
          restitution to the Putman estate.  In 1990, the Circuit Court of            
          Polk County entered a civil judgment against petitioner in favor            
          of each of the Putmans individually in an aggregate amount,                 
          including treble damages, substantially in excess of the Circuit            
          Court's restitution order in the criminal proceeding, with                  
          interest at 12 percent from July 1, 1988.  In 1990, Petitioner              



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