Memorandum to File

RE: Petit

FROM: REP

DATE: 1-02-96

Re: Conference with Paula Silsby / Petit criminal referral

1. Provide Paula with background information.

1. My representation covered period from 2/82 through early part of 1985
2. Outline history of her acquisition of amusement park and Old Orchard Ocean Pier and other assets in 1979.

1. Represented by Bernstein Shur, mainly Herbert H. Sawyer
2. Bride endorsement 1979
3. Marco De Salle and Lenny Nelson ____ in April, 1979 re: ownership interest and Petit assets in return for further financing from Depositors.
4. Key Bank Pepperrel Trust/Mitchel loan, September, 1982; our counterclaim, December, 1982;
5. Pier construction in 1979-1980, loans from PPI/SBA
6. Forclosure by Pepperrel Trust, September, 1982; our counterclaim, December 1982;
7. Repossesion of amusement park by Pepperell Trust, 3-15-83
8. Chapter 11 cases, 1983
9. Global settlement, November 1, 1983 leaving Petit with ownership of the Pier and her 4^th Avenue property in Old Orchard Beach subject to outstanding mortgages and liens.

1. Initial Poazi scheme involving grocery store franchises working with Leroy Ellison, Peter Bishop and others, and also engaging in other highly speculative business ventures with Simpson, Yorks and P&M Associates, Inc.
2. Major lawsuit against Bernstein Shur, Key Bank, November, 1986 with Looney & Grossman and paul Redman as Key lawyers. Poulos joins legal team in April, 1988.