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In 1995, Mae Roundy began working for petitioner. In 1995
or 1996, petitioner requested that Ms. Roundy pick up boxes of
law firm records for her to organize. Ms. Roundy’s husband
picked up 18 to 19 boxes of law firm records from petitioner and
took them to their home. Ms. Roundy organized documents, by
year, for the years in issue.
Petitioner later told Ms. Roundy that she needed Ms.
Roundy’s declaration for petitioner’s attorney in her criminal
tax case. Petitioner prepared a declaration and asked Ms. Roundy
to sign it. The declaration stated that while sorting the law
firm’s records Ms. Roundy found Merrill Lynch statements attached
to memoranda addressed to Mr. Reiter for 1989, 1990, and 1991.
Ms. Roundy did not find Merrill Lynch statements attached to
memoranda addressed to Mr. Reiter for 1989, 1990, and 1991. Ms.
Roundy signed the declaration prepared by petitioner without
reading it based on petitioner’s misrepresentations regarding
what the declaration stated and because she trusted petitioner.
Ms. Roundy would not have signed the declaration had she read it.
Ms. Roundy was sorry that she signed the declaration without
reading it.
In early 1996, petitioner contacted Veronica Wilson, a
former employee of the law firm, and asked her to sign a
declaration that petitioner prepared stating that Ms. Wilson had
copied Merrill Lynch statements to be sent to Mr. Reiter. Ms.
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