IN THE UNITED STATES BANKRUPTCY COURT

FOR THE DISTRICT OF MAINE

CATHERINE DUFFY PETIT,

Chapter 7

Debtor, Case No. 93-20821

NOTICE OF OPPORTUNITY TO OBJECT TO PROPOSED ACTION BY TRUSTEE

Notice is hereby given that two applications have been filed by the Trustee and which seek Court approval of the sale and disposition of certain assets of this bankruptcy estate. The two motions are as follows:

The Application to Compromise was filed by the Trustee on September 24, 1996. It seeks approval of the terms of a settlement agreement dated August 8, 1996, between the Trustee and Paul Richard. The Application to Compromise is on file with the Bankruptcy Court. The August 8, 1996, Settlement Agreement is attached. Both the Application and the Settlement Agreement are available for review, inspection, and copying through the offices of the Clerk of the Bankruptcy Court, 537 Congress Street. Portland, Maine 04101-3318.

In summary, the Application seeks to compromise several pending adversary proceedings against Paul B. Richard. Ronald Caron, Esq., Dennis Petit, Edward Simpson and Tweed Management Corp., Robert Paradis and Sherrie Girrard. Those adversary proceedings will be compromised upon payment of the sum of $70,000 by Paul Richard and. in exchange for which. the Trustee will also assign 75 % of the estate's interest in a cause of action now pending in the courts of Maine against Key Bank of Maine. Pursuant to the compromise, the Trustee will retain 25 % of the gross proceeds of that cause of action. and of any cause of action which may arise therefrom against the Debtor's attorneys representing her in that matter. Unlike an earlier application to compromise, filed in March. this compromise reserves to the Trustee the right to seek denial of the debtor's discharge. This compromise also expressly reserves all causes of action which the estate may have to recover assets of the estate which, heretofore, may not have been disclosed. Pursuant to the compromise. the debtor and her business associates will grant to this Trustee. the predecessor trustee. and their respective attorneys a complete release.

Finally, pursuant to the compromise. the Trustee will sell his right, title and interest in and to the Debtor's personal residence which is the subject to the other application pending before the Court.

The second Application is a Joint Application for Authority to Sell Property and for Approval of Compromise regarding the disposition of sale proceeds which represents an agreement among the Trustee, P&M Associates, Inc., and Richard B. Poulos. It contemplates the sale of the Debtor's residence in exchange for which the Trustee will be paid the sum of $5,000 from the proceeds of sale. This latter application to sell is inconsistent with the terms of the amended application to compromise. If the Application to Compromise is approved by the Court, the Trustee will withdraw the Application to Sell. On the other hand, in the event that the Application to Compromise is denied by the Court. the Trustee will bring on for hearing the Application to Sell.

The Joint Application to Sell is currently on file with the Clerk's office. It is available for review, inspection and copying through the office of the Clerk. U.S. Bankruptcy Court 527 Congress Street, Portland Maine, 04101.

NO HEARING DATE HAS BEEN SCHEDULED WITH RESPECT TO EITHER APPLICATION AT THIS TIME. Hearing will be scheduled upon expiration of the time within which objections may be filed in regards to either application.

Objections to the allowance of the Application to Compromise must be filed and delivered as prescribed below on or before October 18, 1996. Objections shall be in written form specifying the grounds for said objection and filed with the Clerk, U.S. Bankruptcy Court. 537 Congress St., Portland, Maine 04101-3318 with a copy delivered to Stephen G. Morrell, Esq.. Eaton. Peabody, Bradford & Veague. P.A., attorney for the trustee. P.O. Box 9, Brunswick. Maine 04011 and to Joseph S.U. Bodoff, attorney for Paul B. Richard, Hinckly, Allen & Snyder, 1 Financial Center, Boston, MA 02111-2625.

Objections to the allowance of the Application to Sell must be filed and delivered as prescribed below on or before October 23, 1996. Objections shall be in written form and specify the grounds for said objection. They must be filed with the Clerk. U.S. Bankruptcy Court, 537 Congress St.. Portland, Maine 04101-3318 with a copy delivered to Stephen G. Morrell. Esq., Eaton. Peabody, Bradford & Veague, P.A.. attorney for the Trustee, P.O. Box 9, Brunswick, Maine 04011, U. Charles Remmell, Esq., Kelly Remmel & Zimmerman. P.O. Box 597. Portland. Maine 04112-0597. attorney for P&M Associates and to Richard B. Poulos. Esq., Poulos & Campbell. P.A.. P.O. Box 369, Portland. Maine 04112.

All timely objections will be brought on for hearing at the next available court date after October 23, 1996. In the absence of timely objections. the relief requested in the Application to Compromise may be granted without further notice. In the event that the Application to Compromise is denied. the relief requested in the Application to Sell may be granted without further notice in the absence of a timely objection. The Court will notify all parties of the date and place of hearing on both the Application to Compromise and the Joint Motion to Sell by separate notice issued by the clerk.

DATED this 23rd day of September, 1996.

Stephen G. Morrel

Eaton, Peabody, Bradford & Veague, P.A