Greg William Gouveia, a.k.a. Greg W. Gouveia, a.k.a. Greg Gouveia & Carol Ann Gorveia, a.k.a. Carol Gouveia, et al. - Page 7

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          but Mr. Gragg was not experienced in that area.  In addition,               
          petitioner conducted his own independent research on the topic of           
          trusts.                                                                     
               After deciding to form the trusts, petitioner asked Phillip            
          Norton7 to serve as trustee of the Pago Trust.  Mr. Norton had              
          met petitioner in 1986 when they were neighbors in the same                 
          office park, and Mr. Norton later rented office space from                  
          petitioner in 1989 or 1990.  Mr. Norton was involved in the                 
          communications business; he had no experience managing a trust or           
          developing real property.  Petitioner then approached Jeffrey               
          Jeter and asked for his help in creating a trust.  Mr. Jeter had            
          been a business acquaintance of petitioner since approximately              
          1989 and had performed some tool and die work for Brassworks.               
          Mr. Jeter had no prior experience with trusts.  Mr. Jeter and Mr.           
          Norton did not know each other personally but were introduced by            
          petitioner during discussions about forming the trust.                      
               On May 1, 1993, Mr. Jeter and Mr. Norton executed a contract           
          entitled “Pago Trust, A Contractual Fiduciary Trust”.  The                  
          contract contained a declaration of trust and a trust indenture             
          which together set forth the terms governing the administration             
          of the trust.                                                               



               7Phillip Norton’s name erroneously appears as “Norton                  
          Phillip” on the notice of deficiency issued to the Pago Trust, on           
          the petition filed in the name of the Pago Trust, and on all                
          subsequent filings.                                                         




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