Jerry and Patricia A. Dixon, et al - Page 20




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          Bigelow the "equity" in a mortgage funding program and that                 
          Mr. Provan knew other airline pilots who were "shocked and angry            
          that Kersting would attempt to collect these notes after he had             
          assured them the notes would not be collectable."  Both draft               
          affidavits alleged that Mr. Kersting had sued Mr. Alexander for             
          over $500,000 on the basis of promissory notes with respect to              
          which Mr. Alexander "never received any money whatsoever or                 
          anything of value in exchange for the promissory notes."  Mr.               
          Alexander's draft affidavit alleged that:  (1) Mr. Alexander was            
          in litigation with Mr. Kersting "over funds Kersting supposedly             
          was to invest in auto leasing and factoring at Universal Leasing            
          and Federal Finance & Mortgage", and that "Kersting refused to              
          pay the yield or return the funds"; (2) "no client of Kersting's            
          has ever repaid a promissory note * * * with funds other than               
          provided by Kersting through his closed circulation of funds from           
          one Kersting controlled entity to another"; and (3) Mr. Alexander           
          believed that Mr. Kersting's only legitimate business was the               
          purchase of First Savings, in which Mr. Alexander was a                     
          shareholder.                                                                
               Mr. Alexander's affidavit reveals that Mr. Alexander                   
          expected a "quid pro quo" for his testimony, as follows:                    
          "9.  Affiant is ready and willing to testify to the above facts             
          or any others within his knowledge concerning Kersting provided             
          an agreement quid pro quo can be worked out through affiant's               
          representatives, Charles R. Kozak and Gilbert Matsumoto."                   



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