- 6 - discovery) in each of the cases at docket Nos. 10765-003 and 10766-00. In respondent’s motions to compel discovery in each of those cases, respondent represented, inter alia, that counsel of record in each such case, i.e., Ms. Jackson and Mr. Wise, had informed respondent’s counsel that they no longer represented Mr. Richards. Respondent further represented in respondent’s respec- tive motions to compel discovery in the cases at docket Nos. 10765-00 and 10766-00, inter alia, that respondent’s counsel advised both Ms. Jackson and Mr. Wise that respondent would continue to recognize them as counsel for petitioner in each such case unless otherwise notified by the Court. Respondent attached as exhibits to respondent’s respective motions to compel discovery in the cases at docket Nos. 10765-00 and 10766-00 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 either petitioner, or both, were the creator, grantor, settlor, director or beneficiary or any trust in which petitioners[1] were 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: 3Respondent filed discovery motions in the case at docket No. 10765-00 before respondent filed on Oct. 1, 2001, respon- dent’s motion to dismiss that case for lack of jurisdiction as to Joy A. Richards, deceased, and to change caption, which the Court granted on Oct. 12, 2001.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011