John L. Sullivan - Page 6




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          $942,112.50 in principal, $2,816.92 in costs, and $303,848.70 in            
          interest.  (It is the $303,848.70 in interest that is the subject           
          matter of this proceeding.)                                                 
               On November 6, 1989, Messrs. Sullivan, MacAdams, and Tarro             
          went to Mr. Van Tienhoven's office to receive the check and sign            
          documents to be filed with the U.S. District Court indicating that          
          the judgment had been satisfied in full.  Mr. Sullivan refused to           
          endorse the check unless his name was on the Credit Union account.          
          Mr. MacAdams told Mr. Sullivan that because he was Mr. Sullivan's           
          guardian, it was inappropriate and unnecessary for Mr. Sullivan's           
          name to be on the account.  Mr. MacAdams informed Mr. Sullivan that         
          the latter's refusal to sign the check would prevent the check from         
          being deposited.                                                            
               On November 8, 1989, Mr. MacAdams filed a motion for                   
          instructions with the family court.  Thereafter, and before any             
          action by the family court, Mr. Sullivan endorsed the check.                
          Following Mr. Sullivan's endorsement of the check, a meeting was            
          held at the Credit Union.  The proceeds of the Continental check            
          were later disbursed as follows:                                            
          American Universal                              $41,958.53                  
          (Worker's compensation)                                                     
          Attorney Valletta (fees)                        214,108.94                  
                                                                                     
          Attorney Tarro (fees)                           214,113.94                  
          Attorneys Tarro, Valletta, DiPippo              184,399.37                  
          and Dailey (disputed fees)                                                  





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