Bixby Me James Tammy

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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 co7a3695/8199.8 BURNS & 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 ooresaesra00140 BURNS & 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 DICTATED BUTNOT READ

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