UNITED STATES BANKRUPTCY COURT

DISTRICT OF MAINE

IN RE: CATHERINE D. PETIT Chapter 11

93-20821

DEPOSITION OF: RICHARD E. POULOS, taken before Doreen J. Boyce, RPR, at Caron & Sullivan, 25 Pool Street, Biddeford, Maine, on July 25, 1995, commencing at 1:43 P.M.

APPEARANCES:

STEPHEN F. GORDON, ESQ.

JOSEPH S.U. BODOFF_,ESQ.

ALSO PRESENT: Catherine Duffy Petit

Shirley LeBlanc

Doreen J. Boyce, RPR

BOYCE & LEIGHTON

Post Office Box 954

Scarborough, Maine 04074

(207) 883-0378

INDEX

WITNESS PAGE

RICHARD E. POULOS

Examination by ATTY. GORDON

11 EXHIBITS DESCRIPTION PAGE

12 1 Letter dated 6/2/95 26

13 2 Supreme court decision 48

17 (Exhibits included in original and copies.)

. 24

A. Yes.

Q. Do you know the grounds for that being granted?

A. I know the stated grounds.

Q. What were the stated grounds?

A. Apparently there was no causal relation -- linkage between anything that Mitchell did in relation to what Key Bank did.

Q. Did you depose Robert Mitchell?

A. No, I didn't. I was asked not to.

Q. Do you recall meeting with Ron Caron last fall on the subject of a release for Mrs. Petit?

A. I don't think I asked for any release.

Q. Do you recall meeting with Ron Caron?

A. Yes.

Q. What was the subject?

A. Basically I told him that I had a first mortgage on Cathy Petit's house, that I thought her veiled attacks on me were totally unjustified, it could be harmful to her, very much so, and I didn't want to see her get harmed anymore than she has already been harmed. And I said I didn't -- really didn't want her property. If push came to shove, I'd keep it. And maybe we could talk about resolving this thing all the way around including that -- resolving the alleged malpractice case that she was harboring filing against us.

Q. Did you make a proposal in that regard?

A. I did not.

Q. Did Mr. Caron make a proposal in that regard?

A. He did not.

Q. How did you leave it?

A. I said for him to talk with Cathy Petit and get back to me. He came back and said he never heard from her after he outlined basically what I had said.

MR. GORDON: I'd like to take a break. (A short break was taken.)

MR. GORDON: I don't have any further questions. Do you have any questions?

THE DEPONENT: No, I don't.

(The deposition ended at 2:59 P.M.)