Estate of Lillie Rosen, Deceased, Ilene Field and Herbert Silver, Co-Personal Representatives - Page 13

                                        -13-                                          
          of July 31, 1996, the date that the LRFLP was established,                  
          decedent was suffering from “full-blown Alzheimer’s”, and                   
          decedent’s daughter knew as much.  Also as of that date, Feldman            
          had never spoken to decedent’s daughter or decedent’s son-in-law            
          about decedent’s health or about her potential for tort or other            
          personal liability.                                                         
               On July 31, 1996, decedent’s children signed a partnership             
          agreement for the LRFLP (LRFLP agreement).  Decedent’s daughter             
          signed the LRFLP agreement in Illinois in the presence of                   
          Feldman, who notarized her signature.  She signed once as a                 
          general partner of the LRFLP in her capacity as trustee of the              
          Ilene Field Trust and a second time as the limited partner of the           
          LRFLP in her capacity as cotrustee of the Lillie Investment                 
          Trust.  Decedent’s son signed the LRFLP agreement in Florida,               
          outside Feldman’s presence.  Decedent’s son signed the LRFLP                
          agreement individually as a general partner of the LRFLP and a              
          second time as the limited partner of the LRFLP in his capacity             
          as cotrustee of the Lillie Investment Trust.  When decedent’s son           
          signed the LRFLP agreement, he had never met or spoken with                 
          Feldman.  Upon signing the LRFLP agreement, decedent’s children             
          (and Feldman) were unaware of the dollar amount of any partner’s            
          contribution to the capital of the LRFLP.  On either October 11             
          or 14, 1996, Feldman calculated all of those amounts and attached           
          that calculation to the LRFLP agreement as “Exhibit A”.  On the             






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