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have failed to manage the Trusts’ assets in a fashion
designed to generate income for the Trusts in an amount
sufficient to enable the Trustees to distribute di-
rectly to all adult beneficiaries (and to the par-
ent/guardians of beneficiaries who are minors) income
in an amount sufficient to meet the “standard” as set
forth in Article II and Article III as the 1976 Decla-
ration of Trust to each and every beneficiary each
year, such “standard” being stated in such 1976 Trust
as follows:
(1) “reasonable health care”
(2) “support in his or her accustomed manner
of living”
(3) “maintenance”
Since 1976, the Trustees have produced no
income whatsoever to the Trusts from Trust investments
and have made no distributions to the beneficiaries to
meet the “standard” for such annual distributions as
quoted above.
* * * * * * *
26. Notwithstanding the substantial net earnings
of Stone Manufacturing Company, Inc., * * * the Direc-
tors have neglected, failed and refused to ever declare
a dividend for distribution of profits to shareholders.
* * * * * * *
28. While Respondents, E.E. STONE, IV and C.
RIVERS STONE, as officers and directors of Stone Manu-
facturing Company, Inc., have taken and received sub-
stantial income and benefits for themselves, from
Stone Manufacturing Company, Inc., they have, in their
positions as Trustees, withheld and denied any similar
income and benefits to the shareholders of the company
and the beneficiaries of the Trusts.
On April 28, 1992, Ms. Morris, Ms. Fraser, and their respec-
tive children filed a motion in the Probate Court for immediate
restraining orders precluding Eugene Earle Stone, IV, C. Rivers
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