Robert A. Stanford and Susan Stanford - Page 5

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          names to bank accounts with commercial banks in Montserrat with             
          which Guardian Bank maintained correspondent relationships.                 
               On October 16, 1986, petitioner formed Guardian Services as            
          a Montserrat corporation for the stated purpose, as indicated in            
          its articles of association or charter, of engaging primarily in            
          real estate transactions and real estate development.                       
               The charter of Guardian Services makes no mention of                   
          Guardian Bank or of Stanford Financial.                                     
               Under a written service agreement between Guardian Bank and            
          Guardian Services, Guardian Services provided marketing and                 
          advertising services to Guardian Bank.  The service agreement               
          does not indicate that Guardian Services was to act as a nominee            
          of or agent for Guardian Bank.  The service agreement specified             
          only that Guardian Services would perform routine marketing                 
          activities, such as the dissemination of information regarding              
          Guardian Bank's activities.  Nowhere in the service agreement is            
          Guardian Services granted the authority to act in the name of or            
          for the account of, or to bind by its actions, Guardian Bank.               
          Guardian Services held itself out to the public as a separate               
          affiliate of Guardian Bank, and when asked by customers of                  
          Guardian Bank for financial statements, Guardian Services                   
          presented its own financial statements to the customers, not the            
          financial statements of Guardian Bank.                                      
               On February 3, 1987, Stanford Financial was incorporated as            
          a Montserrat corporation.  Upon incorporation of Stanford                   

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