River City Ranches #4 - Page 87

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               During either the examinations respondent conducted or                 
          pretrial discovery, petitioners further provided respondent with            
          annual flock recap sheets on the breeding sheep each of these               
          partnerships (excluding OGT 90) owned from 1981 through 1991 that           
          had been prepared by Mr. Hoyt's organization.  As indicated                 
          previously, these annual flock recap sheets are inconsistent with           
          the above bills of sale for the partnerships that petitioners               
          provided to respondent.  Unlike the bills of sale (which list               
          some rams as being initially acquired by the partnerships), the             
          annual flock recap sheets reflect only ewes as being acquired and           
          owned by each partnership from the date when that partnership and           
          Barnes Ranches entered into their transaction, through December             
          31, 1991.  The 1981 through 1991 flock recap sheets are contained           
          infra in Appendix F to this Opinion.                                        
               During pretrial discovery, respondent also sought to inspect           
          and count the partnerships' sheep.  From October 7, 1992, through           
          February 2, 1993, respondent's expert Kempton Clark (Mr. Clark)             
          counted, at nine different locations, all of the sheep                      
          petitioners contend were then owned by the partnerships, as well            
          as some sheep owned by others.  Mr. Clark counted a total of 131            
          adult male sheep and 5,469 adult female sheep.  Of the total                
          5,600 sheep counted by Mr. Clark, approximately 2,600 were lower            
          quality commercial sheep, as opposed to registered purebred                 
          breeding sheep that had been purchased by the partnerships in               

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