-186-
personally involved in substantial farming operations
individually as well as in partnership form. Family trusts
control two corporations which are similarly involved.” Exh.
9072. At trial, Ballard testified that the family trusts
referred to in his disclosure statement to Goldman Sachs were the
Bea Ritch Trusts, which purportedly owned IRA (and ostensibly
TMT), and the two corporations he was referring to were TMT and
Fairfield. Ballard, Transcr. at 235-236.
Ballard’s testimony on this point is inconsistent with his
earlier testimony and is not credible. In particular, Ballard
testified that, as of 1987, he owned Fairfield–-there is no
evidence that a trust owned Fairfield. The family trusts and two
corporations mentioned in Ballard’s disclosure statement were the
Orient Trust (which owned TMT) and Mary Family Trust (which owned
Seabright Corp.).
On June 13, 1989, Goldman Sachs issued a memorandum
regarding “Outside Business Activities and Private Investment”
reminding Goldman Sachs personnel of NYSE and NASD rules that
required each general partner and employee to obtain prior
written approval with respect to outside business activities and
private investments. Exh. 5938, at 11. In response to this
reminder, on August 2, 1989, Ballard submitted to the Goldman
Sachs compliance department a Request for Approval of Outside
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