- 53 -
772871 lack registration certificates. See infra Appendices H
and I, indicating those of these "breeding sheep" to which a
certificate was matched.
None of petitioners' witnesses (including Mr. Barnes and
Randy) elaborated as to why so many of these above breeding sheep
that RCR #4 and RCR #6 purportedly purchased (which sheep
petitioners and their experts argue were high quality
Rambouillets and Suffolks having values ranging from $500 to
$2,130) were never ultimately registered. Indeed, the Court
believes that, in all likelihood, these allegedly "registerable
Rambouillets and Suffolks" were never registered with national
sheep breed associations because (1) such "breeding sheep" were
fictitious and did not exist and (2) the bill of sale parentage
asserted for them was patently dubious.
Petitioners' matching efforts have not convinced the Court
of the actual existence of anywhere close to the stated total
number of breeding sheep that purportedly were sold each
partnership. We do not accept petitioners' claims that their
problems in substantiating each partnership's breeding sheep stem
merely from "sloppy data entry" in preparing the original bills
of sale that Mr. Barnes issued. Indeed, we do not believe that
these many bill of sale "errors" (which petitioners have now
acknowledged) were inadvertently made without Mr. Barnes' and Mr.
Hoyt's knowledge. The RCR #4 bill of sale that Mr. Barnes issued
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