Herbst Asset Mgmt. Trust, et al. - Page 7




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          and 10002-00 respondent’s discovery requests.  Those respective             
          discovery requests included the following interrogatories:                  
               Interrogatory No. 5:                                                   
                    Please identify all trusts by name, address and                   
               EIN, for which petitioner was the creator, grantor,                    
               settlor, director or beneficiary or any trust in which                 
               petitioner was involved with [sic] in any way.  For                    
               each trust identified, please state whether the trust                  
               has been modified or amended; and if so, answer the                    
               following with regard to each modification or amendment                
               for each trust:                                                        
                         (a) when the modification or amendment oc-                   
                    curred,                                                           
                         (b) who authorized the modification or amend-                
                    ment,                                                             
                         (c) who made the modification or amendment,                  
                         (d) why the modification or amendment was                    
                    made, and                                                         
                         (e) how each modification or amendment was                   
                    made.                                                             
                  *       *       *       *       *       *       *                   
               Interrogatory No. 10:                                                  
                    For the period from the inception of the identi-                  
               fied trusts through the present, list and identify each                
               trust officer, trustee, trust protector, investment                    
               manager and other person who had any directory or                      
               management responsibility of any kind for each of the                  
               trusts.  For each person identified, please answer the                 
               following:                                                             
                         a.  List and identify the beginning and end                  
                    of each person’s tenure.                                          
                         b.  Describe the nature of each person’s                     
                    directory or management responsibility.                           
                  *       *       *       *       *       *       *                   





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