Tarragon Trust - Page 7




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          the trust’s beneficiary as S&T Management Trust, which                      
          “surrendered” its “beneficial” interest in favor of Rosaria A.              
          Jablonski, Gaynor Paul Jablonski, and Dolan Richard Jablonski.              
          These three latter individuals are Paul Jablonski’s wife and two            
          sons, respectively.                                                         
               Attached to petitioner’s supplemental response, filed May              
          15, 2001, is a document, purportedly executed by Zola Sheehan on            
          July 24, 1994, reflecting Cypress Management’s resignation                  
          as Tarragon’s trustee.  During the evidentiary hearing in this              
          case, petitioner offered to the Court another document                      
          purportedly reflecting Cypress Management’s resignation as                  
          Tarragon’s trustee.  This latter document, which differed in                
          material respects (including signatories and typeface) from the             
          former document, was not admitted into evidence.  Considering the           
          inconsistencies in the two documents, we give no weight to the              
          document attached to petitioner’s supplemental response, filed              
          May 15, 2001.                                                               
               On July 24, 1994, Paul Jablonski and Tarragon purportedly              
          executed a document entitled “INDEPENDENT COMMON-LAW CONTRACTOR             
          CONTRACT”, in which Paul Jablonski and Tarragon were identified             
          as contractor and client, respectively.                                     











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