Orneal and Martha Kooyers, et al. - Page 9

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          The OMK Company Trust also paid the education expenses of                   
          petitioners’ grandchildren.                                                 
          C.   Investments in Ponzi Schemes                                           
               Minutes of the OMK Company Trust trustees meeting, dated May           
          29, 1996, state that the trust contracted with William Joe Little           
          (Little) of NTS to act as “Agent Trustee” to handle investments.            
          Little was also affiliated with Fountainhead Global Trust                   
          (Fountainhead).  During the course of his relationship with                 
          petitioners, Little exploited their strong religious motivations            
          and convinced them that he was a “keen Christian”.                          
               In February 1997, petitioners traveled to Grand Cayman                 
          Island to attend meetings conducted by Little, Fritts, and Lewis            
          Rowe (Rowe) of Zephyr International Ltd. (Zephyr).  The meetings            
          were to explain the NTS/Zephyr relationship and to promote                  
          investing through an offshore entity.  Little, Fritts, and Rowe             
          convinced petitioners that the proposed investments were sound,             
          that Little, Fritts, and Rowe were highly qualified and licensed            
          professionals, and that the “operation is completely legal,                 
          honest, upright and is run by men of highest integrity.  Only               
          these kind of men are so licensed under the authority of the                
          Caymanian government which operates under British law.”                     
               As advised by Fritts, Little, and Rowe, petitioners                    
          contracted with Zephyr to form Tamarisk Operations Ltd.                     
          (Tamarisk), through which the OMK trusts invested $550,000.                 






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