John L. Sullivan - Page 5




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          court which has jurisdiction over the marital assets."  On the same         
          day (May 25, 1989), the family court entered a Consent Order,               
          appointing Richard MacAdams (Mr. MacAdams) as Mr. Sullivan's                
          guardian ad litem and restraining Mr. Sullivan from negotiating or          
          attempting to negotiate with South Isle or its insurance company.           
          Issuance of Judgment Proceeds                                               
               On November 1, 1989, Messrs. MacAdams, Thomas Tarro III (Mr.           
          Tarro), and Leo Dailey (Mr. Dailey)1 held a conference call to              
          discuss steps to be taken following receipt of the judgment award.          
          They agreed that the settlement proceeds would be deposited in a            
          daily interest-bearing account in the names of Messrs. Tarro and            
          MacAdams at the Rhode Island Central Credit Union (Credit Union).           
          The settlement proceeds would be available at the offices of                
          Richard Van Tienhoven (Mr. Van Tienhoven), the attorney for South           
          Isle, on November 6, 1989, and would include interest through that          
          date.                                                                       
               On November 2, 1989, Continental Insurance Co. (Continental),          
          the insurance carrier for South Isle, issued a check for                    
          $1,248,778.12, in satisfaction of the judgment.  The check was made         
          payable to "John L. Sullivan, Richard MacAdams, Guardian-ad-Litem,          
          and Thomas Tarro III, His Attorney." The check represented                  


               1    Mr. Tarro was one of Mr. Sullivan's attorneys in the              
          personal injury action filed in U.S. District Court.  Mr. Dailey            
          represented Mr. Sullivan in his divorce action.                             





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