BURNS & LEVINSON LLP
Counsellors at Law
125 summer Street, Boston,MA 02110-1624
Telephone 617-345-3000 Facsicalle 617-345-299
BRIAND. BIXBY
617-345-3360
[BBiaby@bumslevcom
August 27, 2003
Mr, David R. Amos
153 Alvin Avenue
Milton, MA 02186
Re: James M. McLaughlin, Trustee vs. Francis Kickham, et al,
Dear Mr. Amos:
This is to acknowledge receipt of your letter and enclosures on August 26, 2003. I did
not retum your telephone call last week because the message did not request a return call, but
rather indicated that you would be sending me material to look at, which you have now done.
Accordingly, I am responding to that.
Tam interested in your statement that Francis Kickham “is not entitled to support while
he has a great deal of assets of his own.” What information do you have as to assets of Francis
Kickham outside of the Trust, including amounts and locations? The nature and extent of those
assets might be an issue, as would the Trustee’s knowledge or lack of knowledge about that
information,
Sincerely yours,
A 4 me
Brian D. Bixby
BDB/tmh
co7a3695/8199.8BURNS & LEVINSON LLP
Counsellors st Law
125 Summer Street, Boston, MA 02110-1624
Telephone 6 17-345. 3000 Facsimile 617-345-3299
BRIAN D. Bixay
(617-345-3360,
Bixby @bursiv.com
August 28, 2003
Tammy L. Richardson, Esq.
Deutsch, Williams, Brooks, DeRensis,
and Holland, P.C.
99 Summer Street
Boston, MA 02110-1213
Re: James M. McLaughlin, Trustee vs. Francis Kickham, et al.
Norfolk Probate #02E 0094
Dear Attomey Richardson:
Thave reviewed the material sent to me by Attomey McLaughlin with his August 21,
2003 letter.
Please let me know within seven (7) days whether you agree that the two issues framed
by the plaintiff are correctly portrayed, whether there are any other issues that should be
addressed in the case, and whether you have any documents, facts, or arguments that you believe
Tas Guardian ad Litem should be aware of before filing a Report. Some information that is not
available to me yet includes:
1. Why William Kickham was removed as Trustee,
2. Itemization of any legal fees for William Kickham for which a claim against the Trust
is being made.
3. Approximate size of Trust and estimated annual income.
Sincerely yours,
Maen Yhig
Brian D.Bixby A
BDB/dae
ce: James A. McLaughlin, Bsq
Ms. Barbara Kickham
Ms. Jean F. O'Meara
ooresaesra00140BURNS & LEVINSON LLP
Coe ne oer eee et ate
125 Summer Street, Boston,MA 02110-1624
Telephone 617-345-3000 Facsinile 617-345-3299
BRIAN D. BIXBY
(7-345-3360
ish @bumsle.com
September 2, 2003
James A. McLaughlin, Esq.
Goguen, McLaughlin, Richards & Mahaney, LLP
‘Two Pleasant Street
South Natick, MA 01760
Re: Elaine G. Kickham Trust
cket No. 0260094
Norfolk Probate & Family Court D
Dear Jim
Ihave completed my review of the Complaint and Trust. Ihave also done some legal
research on the relevant issues. Tam presently awaiting any further information or comments
that Attomey Richardson, or the other Trust beneficiaries, may want to supply to me before
proceeding further.
Tote that the current Complaint has been on file for almost a year. Could you please
give me an idea as to whether there are any Court dates pending or anticipated, what the
approximate value of the Trust is currently, and whether you do yet have any information
regarding financial resources available to Francis Kickham outside of the Trust? In addition, do
you have a copy of the invoice referred to in the Prayers for Relief? Ican get my end of the job
done as quickly as the patties want or need, once I have a bit more information.
Sincerely yours,
Brien D. Bixby
BDB/tmh
consensisio08
cc: Tammy L, Richardson, Esq.
Ms. Barbara J. Kickham
Ms. Jean F. O'Meara
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