James P. Shea and Patricia H. Shea - Page 9




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          through an insurance broker, M. B. Quin-Harkin of Houlder                   
          Insurance Services (Aviation) Limited.                                      
               By the end of February 1992, the airplanes still had not               
          been delivered to Quotum.  In a letter dated February 28, 1992,             
          James’ secretary wrote to Ian Yemm requesting, among other                  
          things, “a complete accounting to date of * * * [James’] original           
          $650,000 investment.”  By telefax dated March 4, 1992, Yemm                 
          provided the following accounting:                                          
                    Deposited                $650,000.00                              
                    Less:                                                             
                    Bank charges                  69.71                               
                    Houlder insurance        250,000.00                               
                    Truemax Sweden           72,000.00                                
                    Michael E. Donnelly                                               
                    airplane deposit          281,000.00                              
                    Balance                  $ 46,930.29                              
               James continued to send and receive various correspondence             
          regarding the status of the venture throughout March and April              
          1992.  By letter dated April 1, 1992, on Quotum stationery, James           
          replied to a communication from Michael Donnelly as follows:                
                    Surprised, but glad, to hear from you.  $100,000                  
               is a lot of money to waste.  $700,000 is a fortune.                    
               The $700,000 from me was for a three day guaranteed                    
               purchase of existing planes per your representation and                
               a 25% ownership in the company purchasing the planes.                  
               Legally, this money was not to fund your personal                      
               schemes.  * * *  None of my money was ever to be at                    
               risk and for a two year period every, repeat, every                    
               transaction was to be approved by me.  Can I go to the                 
               bank and get my funds?                                                 
                    I want the written proof from Lloyds that the                     
               $250,000 deposit is refundable.  I also want a                         





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