Jacob R. Ramsburg, Jr. and Norma J. Ramsburg - Page 4

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               When Kildare Timmy was formed, its business activities,                
          except for some minor horse breeding activities, were limited to            
          racing horses.  At all relevant times, Kildare Timmy hired                  
          trainers, including Dane Snyder and Dave Dempster (Kildare                  
          Timmy’s trainers), to maintain, care for, and train its race-               
          horses at stables located in Washington, Pennsylvania.                      
               In 1986, Kildare Timmy became more involved in horse breed-            
          ing activities.  At all relevant times, Kildare Timmy’s                     
          broodmares were maintained and cared for by Mr. Ramsburg at                 
          stables located on his farm in Thurmont, Maryland.                          
               At all relevant times until at least 1995, Mr. Stottlemeyer            
          generally performed day-to-day management services for Kildare              
          Timmy (Mr. Stottlemeyer’s management services).  Those services             
          included attending horse sales, selecting horses to buy, and                
          dealing with Kildare Timmy’s trainers.  In return for Mr.                   
          Stottlemeyer’s management services, Mr. Stottlemeyer did not                
          receive any salary from Kildare Timmy or increases in his Kildare           
          Timmy capital account.                                                      
               During at least 1987 through 1996, Mr. Stottlemeyer made               
          cash capital contributions to Kildare Timmy totaling nearly                 
          $300,000 (i.e., approximately $282,187).  He made most of those             
          contributions from the salary that he received as an employee of            









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