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SrNT BY~Xerox Telecopier 7021 1- 7-93 5~07PM ~ 3038256525aC0 MINED LAND REC'L :tt B <br />quarter of the $300,000 cash payment to DeFellippie and three- <br />quarters of such cash payment to Soseph Vento, leaving no portion <br />oP the settlement funds to go to the Dominic A. Vanto trust or the <br />Irene C. Coulter trust. A copy of a March 14, 1985 memorandum to <br />file prepared by Lucius Woods outlining Mr. Vento`s proposal, as <br />discussed in a telephone conversation of the rams date, is attached <br />hereto as Exhibit R, and is incorporated herein by this reference. <br />Also, a copy of Mr. Vento's handwritten notes of the game telephone <br />conversation is attached hereto as Exhibit S, and is incorporated <br />herein by this reference. Because the Trustee could not <br />accommodate Mr. Vento`s demand since it required the Trustee to <br />ignore its obligations to the trust beneficiaries other than <br />Plaintiffs, the Trustee was forced to proceed with the transaction <br />over Mr. Vento`s objection, based upon the recommendations and <br />advice of its counsel. The Trustee divided the $300,000 payment <br />from Dorchester among the four trusts in equal shares of $75,000. <br />Soseph A. Vento deposition transcript at p. 322, 11. 16-21. A copy <br />of the relevant portions of Mr. Vanto's deposition transcript is <br />attached hereto as ~ibit T, and is incorporated herein by this <br />reference. Thus, Mr. vento, as well as the other beneficiaries, <br />received and have enjoyed the benefit of the proceeds of the <br />March 22, 1985 transaction. <br />Mr. Vento threatened to sue the Trustee if it proceeded <br />with the March 22, 1985 transaction. Mr. Vento followed through on <br />such threats, the result of which is this lawsuit. <br />xfo~o.i ewe oi,oTao am ~ <br />