Wednesday, February 15. 2006
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PETITION FOR THE ISSUANCE OF CITATION FOR RECOVERY
On Friday, March 11, 2005, the Petitioner, the Jay E. Hayden Foundation, by and through its attorneys, Frederick E. Roth of Roth Law Firm and Bruce A. Aukerman of Mann Law Firm, and pursuant to Section 16-1 of the Probate Act (755ILCS 5/ 16-1) seeks the recovery from Respondents the "Country Estate", as described below and states the following:
1. On May 25, 1985 Jay E. Hayden ("Jay"), a Greenup, Illinois business man, dies.
2. Robert B. Cochonour ("Cochonour") accessed the Greenup National Bank safety deposit box of Jay and the safety deposit box of Jay's mother, Martha L. Hayden ("Martha"), on June 5,1985 with no legal authority.
3: The Estate of Jay E. Hayden was opened on June 11, 1985 upon the admission to probate of the Will of Jay E.Hayden; Case No. 5-P-21.
4. Cochonour was appointed executor of the Estate of Jay E. Hayden on June 11,1985 and continued to serve as executor until his forced resignation on June 19,2002.
5. The law firm of Cochonour and Simonton was counsel to the Estate of Jay E. Hayden commencing June 11,1985. No withdrawal or resignation of Cochonour and Simonton appears of record.
6. Cochonour, as executor, took control and managed the assets of the Estate of Jay E. Hayden, including funds placed on deposit with Casey National Bank (n/k/a Casey State bank) in the Estate's account no. 198-900.
7. First National Bank in Toledo ("FNBT") made multiple loans to Cochonour and Cochonour related entities at all times relevant herein. Cochonour, as executor for the Estate of Jay E. Hayden, borrowed in excess of $300,000 from FNBT. The first loan made to Jay's Estate, in the amount of $100,000 on July 17,1985, funded a payment of a similar amount days later to Cochonour's Triple C Oil.
8. On December 3, 1990 Cochonour was sworn in as the Cumberland County Resident Circuit Judge for the Fifth Judicial District.
9. To comply with the residency requirement, Cochonour claimed R.R. #3, Casey, Illinois in Cumberland County as his residence. Cochonour also claimed a residence at 201 E. Edgar, Casey, Illinois in Clark County with his wife, Judith A. Cochonour.
10. On August 19, 1992 Cochonour, with knowledge and assistance from Carol Jo Fritts, President of FNBT, took $312,901 from Martha, and used the funds to pay a personal debt obligation to First City Bank of Houston, TX.
11. On August 20, 1992 Cochonour, with the knowledge and assistance of Carol Jo Fritts, President of FNBT, took $382,000 from the Estate of Jay E. Hayden and used the funds to pay a Cochonour debt obligation to First City Bank of Houston, TX.
12. John Cutright performed legal service for Cochonour and FNBT in regard to the transaction, which closed at Effingham Title Company on August 20, 1992. The transaction included $312,901.07 taken from Martha, $382,000 taken from the Estate of Jay E. Hayden, and Cochonour loan proceeds of $261,085.91 from FNBT for a payment of $ 1,800,000 to First City Bank of Houston, TX.
13. Clark Cochonour, father of Robert B. Cochonour, died September 11, 1992 and the Estate of Clark Cochonour was opened on December 22, 1992; Case Number 92-P-59. Counsel for the Estate was John Cutright.
14. On February 9,1993 Martha was brought to the law office of John Cutright at the request of Cochonour. John Cutright had prepared a will for Martha and, in the presence of Robert and Joe Cochonour, she purportedly signed the will. On August 13, 2004, this Will of Martha L. Hayden was declared invalid as a result of a lack of testamentary capacity.
15. On February 9,1993 Martha also purportedly signed a Cancellation of Note, which purported to be the forgiveness of a loan, allegedly made on August 20,1992, in the amount of $312,000 to Cochonour, his father Clark Cochonour, brothers Joe and Don Cochonour and related entities. Robert and Joe Cochonour were present at John Cutright's office when Martha, who lacked testamentary capacity, purportedly signed the Cancellation of Note.
16. On February 9,1993 Cochonour opened an account, 32-044-8, with FNBT in the name of Maurine Johnson or Mary L. Johnson ("FNBT M&M account").
17. Cochonour had no legal authority of any kind to sign the name of Maurine Johnson or Mary L. Johnson or open an account in their names.
18. All transactions into payments from the FNBT M&M account were made by Cochonour, all without the knowledge or consent of Maurine Johnson or Mary L. Johnson, from February 9, 1993 through at least January 18,2002.
19. Cochonour, as executor, signed checks from the Estate of Jay E. Hayden account 198-900 at the Casey National Bank payable to Mary L. Johnson. The total of these checks was $185, 000.
20. Cochonour deposited the checks, which totaled $185,000 payable to Mary L.' Johnson, into the FNBT M&M account.
21. Cochonour wrote checks and made payments from the FNBT M&M account totaling $ 141,245.76, to pay for construction of a home located at 725 County Road 2350E, Cumberland County, Illinois; hereinafter referred to as the "Country Estate."
22. Cochonour wrote checks and made payments from the FNBT M&M account to Robert Cochonour totaling at least $36,050, and to Judith Cochonour totaling at least $20,000, with no explanation given for the use of such funds.
23. Cochonour wrote checks and made payments from the FNBT M&M account to Cochonour related entities, Triple C. Oil, Triple C.
Thorostock, Triple C Oil Producers, Inc. and Casey Thoroughbred Farms, totaling at least $85,477.00.
24. FNBT had no direct contact with either Maurine Johnson or Mary L. Johnson between February 9, 1993 and November 2001 in regard to the FNBT M&M account. All checks and bank statements were sent by FNBT to Robert Cochonour.
25. OnOctober31,1994 The First National Bank of Danville (as Land Trustee for Trust Agreement dated October 1,1981 known as Land Trust 5100 A and C), conveyed the land and improvements (i.e. the Country Estate) to Robert B. Cochonour and Judith A. Cochonour as Joint Tenants. A copy of said Trustee's Deed is attached as Exhibit A.
26. Neither Cochonour nor his wife, Judith A. Cochonour, paid any monetary consideration for the conveyance to them of the Country Estate. The Trustee's Deed was declared exempt pursuant to the Real Estate Transfer Tax Act under Provision Paragraph e. Section 4.
27. Cochonour and Juditn A. Cochonour use the County Estate for entertainment purposes and as the basis for Cochonour to claim residence in Cumberland County to satisfy his residency requirement as the Cumberland County Resident Circuit Judge.
28. Mary L. Johnson ("Mary") was first informed of the possible existence of the FNBT account in the name of Maurine Johnson or Mary during September 2001 as a result of a conversation with Robert Doerr, then an employee of FNBT and a former employee of Cochonour related entities.
29. Mary first approached FNBT through her attorney, Frank Weber, during October 2001 to ascertain the existence of and transaction history involving the FNBT M&M account.
30. Carol Jo Fritts, President of FNBT, abruptly terminated Robert Doerr's employment with FNBT during October 2001.
31. Mary confirmed to FNBT and her attorney, Frank Weber, during October 2001 that she had no knowledge or information concerning the so called Maurine Johnson or Mary L. Johnson bank account established at ' FNBT on February 9,1993 by Robert Cochonour, the FNBT M&M account.
32. No funds deposited into the FNBT M&M account were used to benefit either Maurine Johnson or Mary.
33. Maurine Johnson died on October 31, 2002. On May 1, 1992, Maurine Johnson, due to declining health, had appointed Mary as her agent pursuant to a power of attorney.
34. Carol Jo Fritts, President FNBT, and her assistant, Linda K. Simpson of FNBT, received inquiries from Frank Weber, attorney for Mary, during October and November 2001 regarding the possible existence of the FNBT M&M account. FNBT had access to copies of all bank statements, checks and account information, which clearly confirmed that Cochonour had established the account, made payments from the account to his and Judith A. Cochonour's benefit and received all bank statements and related correspondence regarding the account.
35. Despite requests for all FNBT M&M account information, including checks, deposits, statements, etc., FNBT refused to provide any such documentation until Mary signed a new account form.
36. From the date of the conveyance of the Country Estate on October 31, 1994 through December 27,2001 there were no mortgages or encumbrances placed against the property.
37. Based upon information and belief, Carol Jo Fritts, President FNBT, had throughout the 1990's told and' reminded Cochonour and his brothers that they should always try to mortgage their personal residential properties with FNBT because she would never foreclose on them.
38. On October 16,2000 Cochonour signed the name of Martha on a promissory note in the amount of $89,235.20 payable to FNBT with the full knowledge of June Hayden, a loan officer for FNBT, and the co-signer, Frank Rook ("Rook"). Martha and Rook were equal partners in Hayden's IGA, a general partnership.
39. On October 24, 2000 Hayden's IGA in Greenup, Illinois was destroyed by fire.
40. During December 2000 Cochonour corresponded directly on behalf of Martha with Steve Heine, attorney for Argonaut Great Central Insurance Company, the insurer for Hayden's IGA, in response to Steve Heine's written request to Martha for information.
41. During December 2000, upon the recommendation of Cochonour, Rook retained William A. Sunderman ("Sunderman") as his attorney in regard to the Hayden's IGA fire claim.
42. Between December 2000 and March 2001 Sunderman conversed directly with Cochonour regarding Hayden's IGA and the fire claim.
43. Between December 2000 and March 2001 Rook informed Sunderman that Cochonour had signed Martha's name to loan documents with FNBT and other legal documents. Sunderman was also informed by Rook that Cochonour had no power of attorney and was not appointed guardian for Martha and that she was totally incapacitated.
44. Rook told Sunderman the signatures of Martha on loan documents with FNBT were forgeries. Sunderman has admitted that he believed Rook.
45. Rook testified under oath at a deposition taken during March 2001 that Cochonour had signed Martha's name to legal documents without a power of attorney or appointment as guardian. The deposition was taken by Steve Heine with Sunderman present representing Rook.
46. Steve Heine learned prior to taking the March 2001 deposition of Rook that Cochonour, who had corresponded directly with Heine on behalf of Martha, was a sitting Fifth Circuit Judge. During 1998-1999, Steve Heine's law firm, Heyl, Royster, Voelker & Allen, had represented Martha L. Hayden and Frank Rook d/ b/a Hayden's IGA in defense of a lawsuit which was pending before Judge Robert B. Cochonour.
47. Sunderman and his law firm, the Brainard Law Office, represented FNBT at the time of the Hayden's IGA fire. Rook was first informed of the common representation during June 2001 and then advised by Sunderman that there was no conflict even though there was a dispute regarding the FNBT loan with Hayden's IGA and the insurance certificate.
48. On December 18, 2001 Martha died.
49. On December 19,2001 Rook and FNBT entered into a new loan arrangement to fund a new IGA store. Sunderman reviewed the loan documents for Rook and prepared a certain assignment for FNBT to be signed by Rook as part of the transaction. The assignment was an attempt to assign all fire insurance proceeds due to Rook to FNBT.
50. Following Martha's death, despite several visits to her home during December 2001 and early January 2002, neither Cochonour nor her niece, Bobbie Goodman, could locate Martha's Will.
51. Carol Jo Fritts, President FNBT, consulted Sunderman as FNBT's attorney in regard to the FNBT M&M account and the Hayden's IGA fire claim.
52. On December 28,2001 FNBT purportedly loaned Cochonour and Judith A. Cochonour $175,000 pursuant to a six-month promissory note secured by a first mortgage on the Country Estate. A copy of said Mortgage is attached as Exhibit B.
53. The purported loan of $175,000 to Cochonour and Judith A. Cochonour was per a demand note with no principal or interest due until June 28, 2002. A copy thereof is attached as Exhibit C. The use of the loan proceeds is unknown.
54. On January 11,2002 a Corrective Trustee's Deed was executed by First National Bank of Danville, as Land Trustee, and filed purportedly to correct the prior Trustee's Deed attached as Exhibit A. hereto. A copy of the Corrective Trustee's Deed is attached as Exhibit D.
55. On or about January 14, 2002 Cochonour informed Bobbie Goodman that he found Martha's Will in a secret compartment next to the bathtub in Martha's home. The possible location of the will had been made known to Cochonour by his niece, Kim Eckerty, who had a "vision."
56. The Will of Martha was admitted to probate on January 15,2002; Case Number 02-P-2. Counsel for the Estate was John Cutright. The executor was Joe Cochonour.
57. On January 17, 2002 Cochonour met with Mary and admitted he had set up and used the FNBT M&M account but claimed to Mary that all funds except $82,000 that passed through the FNBT M&M account were his. Cochonour signed a promissory note for $82,000 payable to Mary and gave it to her on the condition that she confirms to FNBT that the M&M account was hers..
58. A transfer of $82,000 (consisting of checks for $67,000 and $ 15,000) had been deposited by Cochonour into the FNBT M&M account. The funds came from Maurine Johnson's Edward D. Jones account on or about February 9, 1993 at a time when
59. On January 17,2002 a meeting was held to discuss the Hayden's IGA fire claim. Present were Sunderman, Rook, Cochonour and Brent Holmes (as counsel to Joe Cochonour, executor for Martha L. Hayden). Bobbie Goodman had originally been invited but was later told not to attend.
60. On January 18,2002 Mary visited FNBT and signed a new account form for the FNBT M&M account. As a January 18,2002 FNBT had not provided Mary with any bank account statements or checks for the FNBT M&M account despite her repeated requests, The account balance on January 18,2002 was approximately $1,400.00.
61. Cochonour met with the Jay E. Hayden Foundation Trustee of February 4,2002 to inform them he was filing a Notice of a February 19,2002 court hearing to approve the annual reports in the Estate of Jay E. Hayden from l986 throug mid2001 .He left a signed original of the intended filing with the Trustees.
62. On February 13,2002 the; Jay E. Hayden Foundation Trustees presented a Request for Accounting in the Jay E. Hayden estate to the Cumberland County Circuit Clerk for filing, only to learn that Cochonour 's Notice of the February 19 2002 hearing had not been filed.
63. Cochonour entered the Circuit Clerk's office on February 13,2002 as the Trustees, William Wylde and Hugh Eubank, were attempting to file their Request for Accounting in the Jay E. Hayden estate. The Trustees requested Cochonour to authorize the Clerk to file the February 19 Notice of hearing, which he did. Cochonour then asked for a meeting with the Trustees.
64. Trustees Wylde and Eubank met with Cochonour on February 13,2002 in chambers. Cochonour explained that if the Trustees were seeking money for the Jay E. Hayden Foundation, there was none.
65. Cochonour approached Carol Jo Fritts, President of FNBT, to intervene with the Trustees of the Jay E. Hayden Foundation. On Cochonour's request, Carol Jo Fritts did approach Hugh Eubank.
66. On or about March 11,2002 Carol Jo Fritts, President FNBT, visited Hugh Eubank in his Greenup office and claimed to have papers in her hand that Cochonour would file in court if the Trustees refused to meet and asked if Mr. Eubank wanted her to read them. Ms. Fritts attempted to answer one of the Trustees' questions posed in the Request for Accounting by reading from the papers in her hand. The response read did not answer the questions posed and shortly thereafter, Ms. Fritts left.
67. After consultation with Sunderman, and based upon information and belief, following the meeting between Carol Jo Fritts and Hugh Eubank, FNBT purportedly filed a Suspicious Activity Report concerning the FNBT M&M account identifying Cochonour.
68. Sunderman purportedly filed a referral concerning Cochonour to the Illinois Judicial Inquiry Board's outside counsel in either late February or early March 2002 after news articles concerning the disputed accounting for the Estate of Jay E. Hayden appeared in local newspapers.
69. Pursuant to the $82,000 promissory note dated January 17,2002 delivered to Mary, Cochonour for warded check no. 8607 dated April 29, 2002 payable from the joint account of Robert and Judith Cochonour in the amount of $4,400 to Mary. Mary received the check but did not deposit it.
70. On April 24,2002 The Charitable Trust Division of the Attorney General's office filed a Petition to Intervene in the Estate of Jay E. Hayden. On April 29,2002 the matter was set for hearing on May 7,2002.
71. On April 30,2002 Cochonour and Judith A. Cochonour executed and placed a second mortgage on th Country Estate in favor of FNBT in the amount of $1,609,110.36 to secure three (3) existing loans made to Robert B. Cochonour related entities. A copy of said mortgage is attached as Exhibit E.
72. The FNBTNoteof$175,000 made December 28, 2001 and secured by the Country Estate has been modified such that FNBT has repeatedly extended the term (purportedly with interest only payments) from
73. On October 24,2002 Cochonour conveyed the Triple C office building, 107 NW 1st Street, Casey, Illinois to FNBT as part of a Loan Restructuring Agreement entered into on the same date which also provided and evidences that
74. Carol Jo Fritts of FNBT and Sunderman attempted to visit with Mary at her home during December 2002 to have her sign a hold harmless agreement in regard to FNBT. Mary refused to allow them to enter her house and refused to sign the agreement.
75. On June 27,2003 this Court disallowed the $185,000, which purportedly were payments from the Estate of Jay E. Hayden to Mary and included said amount in the judgment entered. Said amount was not paid to Mary or used for her benefit but rather used by the Respondents for their benefit.
Cochonour & Judith A. Cochonour Count I 1-75. Petitioner hereby incorporates Common Allegations 1 through 75 as allegations herein.
76. Cochonour and Judith A. Cochonour knowingly took and/or received monies from the Estate of via the phony FNBT M&M account and used the monies to fund the construction of a new house at 725 County Road 2350E, Cumberland County, Illinois.
77. Cochonour and Judith A. Cochonour had no legal right to take monies without consideration from the Estate of Jay E. Hayden.
78. Cochonour, as executor, was a fiduciary of the Estate of Jay E. Hayden.
79. Cochonour's spouse, Judith A. Cochonour, knew Cochonour was the executor for the Estate of Jay E. Hayden.
80. Cochonour's conversion of funds from the Estate of Jay E. Hayden to construct a new house does not transfer title of Estate assets to Cochonour and Judith A. Cochonour.
81. The Country Estate is property of the Estate of Jay E. Hayden not Cochonour or Judith A. Cochonour.
82. Section 16-1 provides, in relevant part, for the recovery of property which belongs to the estate but is in the possession of or being concealed by others as a result of conversion or embezzlement.
WHEREFORE, Petitioner prays that this Court will enter an Order directing Robert B. Cochonour and Judith A. Cochonour to immediately vacate the Country Estate and Convey title thereto, free and clear of all encumbrances, to the Jay E. Hayden Foundation.
First National Bank in Toledo
1-82. Petitioner hereby incorporates Allegations 1 through 75 and allegations 75 through 82 of Count I as allegations herein.
83. FNBT had actual knowledge that Cochonour was serving as executor of the Estate of Jay E. Hayden at all relevant times herein.
84. FNBT had actual knowledge that Cochonour established and operated the FNBT M&M account for the benefit of Cochonour, Judith A. Cochonour and Cochonour related entities and that Cochonour used said account as a depository for money transferred from the Estate of Jay E. Hayden.
85. FNBT had actual knowledge that Cochonour was handling all matters pertaining to the FNBT M&M account without any power of attorney or guardianship appointment on behalf of either Maurine Johnson or Mary L. Johnson.
86. FNBT had actual knowledge of the conveyance of the Country Estate from Land Trust 5100 A&C to Cochonour and Judith A. Cochonour.
87. FNBT had actual knowledge that Cochonour's funding for the construction of improvements of approximately $200,000 to the Country Estate was done without mortgage financing.
88. FNBT had actual knowledge of the fact that neither Maurine Johnson nor Mary L. Johnson had any knowledge of the FNBT M&M account prior to October 2001.
89. Despite the actual knowledge of Cochonour's actions involving the Estate of Jay E. Hayden, Martha L. Hayden, Mary L. Johnson and Maurine Johnson as detailed in the foregoing allegations, on December 28,2001 FNBT provided a $175,000 loan secured by a mortgage placed against the Country Estate.
90. FNBT continued to make modifications each time the $175,000 loan term matured such that no repayment of principal is required until January 11,2007.
91. FNBT's placement of a second mortgage on the Country Estate of $1,609,110.36 eliminated the Country Estate's unencumbered value.
92. FNBT and its counsel had actual knowledge of Cochonour's taking assets from Martha L. Hayden and the Estate of Jay E. hayden to fund personal debt obligations of Cochonour.
92. FNBT and its counsel had actual knowledge of Cochonour's taking assets from Martha L. Hayden and the Estate of Jay E. hayden to fund personal debt obligations of Cochonour
93. FNBT withheld all information in regard to the FNBT M&M account from those named on the account, Maurine Johnson and Mary L. Johnson while having actual knowledge that Cochonour had such information.
94. FNBT knowingly accepted Cochonour as Martha L. Hayden's signatory even though FNBT had knowledge that Martha L. Hayden was incapacitated and Cochonour was neither Martha's power of attorney, guardian nor trustee.
95. FNBT had actual knowledge that Cochonour's actions with respect to its elderly customers, Maurine Johnson, Mary L. Johnson and Martha L. Hayden, were being done without providing FNBT and evidence of a power of attorney, guardianship or trusteeship.
96. FNBT, with actual knowledge and direct involvement in transactions with Cochonour, assisted Cochonour in using monies from the Estate of Jay E. Hayden knowing all benefits resulting therefrom were accruing to Cochonour and FNBT to the detriment of the state of Jay E. Hayden.
97. On behalf of Cochonour, FNBT attempted to persuade the Trustees of the Jay E. Hayden Foundation not pursue their accounting request while having actual knowledge of the fact that Cochonour had taken significant amounts of money from the Estate of Jay E. Hayden for the benefit of Cochonour, Judith A. Cochonour and Cochonour related entities.
98. FNBT placed mortgages totaling $1,784,110.36 against the Country Estate with actual knowledge that the mortgagors, Cochonour and Judith A. Cochonour, had built the Country Estate with funds taken from the Estate of Jay E. Hayden.
99. FNBT was not an innocent bona fide third party.
100. Section 16-1 of the Probate Act of 1975 provides, in part:
WHEREFORE, Petitioner prays that this Court will declare the FNBT first and second mortgages to be null and void and enter an appropriate order compelling FNBT to forfeit to Petitioner any security interest it may claim in the County Estate
. JURY DEMAND
Petitioner hereby demands a jury for this recovery proceeding pursuant to Section 16-3 of the Probate Act of 1975.
On March 11,2005 this statement was filed in the Cumberland County Circuit Clerk's office. The statement reads as follows:
I, R. Glen Wright, make the following statement:
1. That I have been contacted by attorney Rick Halprin, who asked questions about a conversation I had with him in 2004; that I have not reviewed my notes from the time period; and that this statement is made without benefit of refreshing my memory as to exact details and is to the best of my recollection at this time;
2. That I was employed as an Assistant State's Attorney of Cumberland County, Illinois, working under States Attorney Barry Schaefer, from approximately January, 1,2004 to November 15,2004;
3. That my duties were to conduct an investigation into the activities of former Judge Robert ■Cochenour, who had previously been convicted of felony theft pursuant to a charge filed by the Attorney General's Office and a plea agreement. The primary purpose was to determine if there was a proper basis for filing additional charges, either against Judge Cochenour or other persons;
4. That, among other things and during the course of my employment, I reviewed materials and information made available to me by Mr. Schaefer and other sources; that I had questions as to why some things had previously been done in certain ways, including the terms and manner of Judge Cochenour's plea agreement;
5. That, with the knowledge and assistance of Mr. Schaefer, a meeting was scheduled for me with the Assistant Attorney General who had prosecuted the case, whose name I believe was Edward Carter. Upon arrival at his Office, I was informed that his supervisor, whose name I do not recall, would be sitting in on the meeting;
6That,at this meeting in the Attorney General's Office, I inquired, among other things, if they had had a separate agreement with Judge Cochenour and/or his attorney to the effect, or had they made statements to them which reasonably led Defendant to believe, that if he accepted their plea proposal in the form and manner as presented, there would be no further prosecutions against him for offenses arising out of the same circumstances? The Assistant A.G. did not immediately answer, but his supervisor stated "Yes," and the Assistant then nodded his head in the affirmative. During the course of our meeting they raised a question as to how the States Attorney intended to proceed on that; to which I replied that, insofar as it was within my power, I did not intend to renege on what they had told me the State had agreed to;
7. That, upon my return, I informed Mr. Schaefer of the substance of the above-described meeting; alternatives were reviewed; and that it is my understanding that the decision was made to honor the A.G.'s representation(s) to the Defendant; and that a decision was further made to seek to have Judge Cochenour as a cooperating State witness in our investigation;
8. That at a later date, which Mr. Halprin informs me was on or about July 9, 2004, being a date when he appeared before the Honorable Judge Stephen R. Pacey in a Hayden Estate matter in Cumberland County, I met with Mr. Rick Halprin, the attorney for former Judge Cochenour, and an other man whose name I do not recall, but who was represented to me to be an associate of Mr. Halprin; and that this meeting was held in the "Jury Room" across the hall from the States Attorney's Office in the Cumberland County Courthouse; it is further my understanding that my supervisor, Mr. Shaefer, understood that I was going to discuss the matters described below with Mr. Halprin, though he did not yet know what issues, if any, Mr. Halprin might bring up;
9. That my recollection of the substance of that meeting and conversation, generally and not verbatim, was that I informed Mr. Halprin of the following:
10. That thereafter I had numerous conversations with Mr. Schaefer about the substance of the foregoing matters, including my meeting with Mr. Halprin; I do not recall the dates from memory; but, they occurred prior to my leaving the Office in November of 2004.
11. That I have no knowledge as to whether Mr. Schaefer did or did not have further comunications with the Attorney General's Office as to the existence or details of any such prior agreement(s) of the Attorney General's Office to Mr. Halprin and or Judge Cochenour.
Nothing further at this time.
R. Glen Wright
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