- 14 -
brothers and sister, and they wanted to equalize matters by
helping Scott also. The Kudos' relatives also sent cash gifts
for family occasions such as Christmas and birthdays.
Scott made one or two trips to Japan in 1990 and one trip in
1991.
From time to time tenants at Toraya Apartments or restaurant
employees would give Motomi cash, and she would write checks on
their behalf for rent and other bills. However, the record is
devoid of specific names, dates, or amounts of any of those
transactions.
When the Takaos went on trips, Motomi sometimes paid their
bills, and she was reimbursed by them in cash. For instance, in
1991 Motomi wrote checks totaling $770 to her parents' gardener.
In 1991 Motomi wrote checks totaling $6,009.49 to or on
behalf of her brother, Junichi, who needed money at the time
because he was going through a divorce.
During 1990 and 1991, Motomi often made separate, multiple
cash deposits on a single day, several times per week. For
example, on January 28, 1991, Motomi made three deposits for
$100, $140, and $200. All of the deposits were made at the same
time; i.e., on a single trip to the bank. Motomi purportedly
made deposits in that manner because she put cash from different
8(...continued)
letters), refer to Nicholas as "Takao". The exhibit was received
in evidence for the nonhearsay purpose of showing the relatives'
knowledge.
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