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ot CNL ETAAT ane UPC ros, © 6 eee HOGAN @RARTSON 32. MeOQt paragrart 13 ef th: Complaint: (a) Identify each Person on whose testimony you intens to rely at trial to Support your contention that ‘the decedent sufferca “mental acbhility.* (b) Identify each communication, document or Paper writing of which you are aware which bears on the 6aid contention made by you in Paragraph 13 and identify the Person or persons having Possession, Custody or control of any such communication (if in writing), document Or paper writing. fc) Identify each person that you claim acted "in Concert with the defendant® in exhibiting undue influence and coercion upon the decedent, Clyde A. Tolson, as stated in said Paragraph 13, Identify each written communication, document or Paper writing known ‘to You, your agents or your attorneys, other than those already identified in response to the previous interrogatories propounded herein, that was (a) signea by the late Clyde A. Tolson or tb) was sent or addressed to or intended to be received by the late Clyde aA. Tolson Or {c) in any manner related te the late Clyde A. Tolson or his estate. In each case identify tho person or persons having possession, Custody or control of each such written conumunication, document or Paper writing. - 168 -»