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Petitioner’s April 21, 2004, Deposition
In connection with additional litigation in the Louisiana
courts, this time in a suit to rescind the 1986 sale of LPP stock
by Julian E. to petitioner (together with the first Louisiana
litigation, the Louisiana litigation), petitioner was deposed on
April 21, 2004, by plaintiffs’ counsel. During the deposition,
petitioner testified that she executed a promissory note to
Julian E. in consideration for 19 shares of LPP stock. In
testifying as to the manner in which she made payments on that
note, the following exchanges occurred between petitioner and
plaintiffs’ counsel:
A [Petitioner]: Okay, the payments to my father
were made on my behalf through
Long’s Preferred Products.
Q [Counsel]: In other words, you are saying that
the corporation paid your note, is
that correct, that was owed to your
father?
A [Petitioner]: He -- the stock that I purchased
from my father was paid on my
behalf through the corporation, and
that was the way that my father and
my brother and myself talked about
having it done.
* * * * * * *
Q [Counsel]: So you, as of this date -- have
you, yourself, personally, made any
payment towards the retirement of
this note?
A [Petitioner]: I have through the corporation of
Long’s Preferred Products.
* * * * * * *
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