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David's father. At the end of their conversation, Ms. Sutton gave
Mr. Richardson her business card to relay to David. David failed
to contact her. Accordingly, on April 1, 1992, she made a third
visit to Baum’s office, in order to serve a summons on David. (The
summons requested all available information relating to Sloan's
income or any estate, trust, or other fiduciary of Sloan for 1987
through 1991.) When Ms. Sutton arrived at Baum’s offices, she was
informed that David was not there. She then drove to David's
residence to serve the summons, but the outer gate was padlocked.
Ms. Sutton subsequently returned to Baum’s offices, and by
happenstance, met David. David asked Ms. Sutton to meet him later
that afternoon at his accountant's office to discuss the summons;
they so met. Ms. Sutton served the summons on David, explaining
that he was to appear at her office on April 13, 1992, with the
requested information. Ms. Sutton asked David when his father
died; David replied that he did not know the date of Sloan’s death.
Ms. Sutton further asked David whether his father's estate was
probated; David responded by stating that information could be
obtained by looking at the county court records. Ms. Sutton told
David that it would be difficult ascertaining information about
Sloan’s estate without knowing Sloan’s date of death. David
replied by stating that he did not have much information about his
father. The meeting then concluded.
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