William J. Cutts - Page 7

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               During the 1997 year, ATV conducted its Mobile, Alabama,               
          office business activities in the main house and accounting                 
          activities in the carriage house.  It employed 23 or 24 people in           
          Mobile.  During 1997, Mr. Cutts resided in the main house and had           
          a reserved parking space in back of the main house.                         
               Mr. Cutts’s minor son, Justin Cutts (Justin), was 7 or 8               
          years old in 1997.  Under Mr. Cutts’s custody agreement with his            
          former wife, Justin visited Mr. Cutts every other weekend and for           
          1 month each summer.  Mr. Cutts supervised Justin during these              
          visits.  Occasionally, Justin had friends over for visits at                
          Landmark Hall.                                                              
               Mr. Cutts resides on the third floor of the main house, as             
          did Justin during his visits.  There are 10 rooms on the third              
          floor of the main house, including a den at the back, four                  
          bedrooms, three bathrooms, a tax office, and a storage room.                
          Mr. Cutts used the den and one bedroom for himself, and another             
          bedroom for Justin.  They used the bathroom next to Mr. Cutts’s             
          room, and Justin also occasionally used the bathroom next to the            
          den.  To enter the den, Mr. Cutts must walk through the bedroom             
          between the den and Justin’s bedroom.  The bedroom next to the              
          tax office was used as a company bedroom for ATV employees.  Mr.            
          Cutts and Justin entered the third floor using a back entrance              
          near Mr. Cutts’s parking space that is separate from the front              
          entrance used by other ATV employees.                                       






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Last modified: May 25, 2011