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characterization of a few token interest payments is inaccurate, and in fact what did occur was that each and every named lender received each and every interest payment that she was due until the negative publicity in the spring of 1986 that was alluded to in the trial made that repayment more difficult. Repayments were 100 percent made, and although they were often a matter of weeks late, they were made until the spring of '86 in total. They were not token payments.
I would suggest to Your Honor that paragraph 17 contains the sentence beginning. The individual responsible for distributing the organization's limited loan repayment funds during 1984 testified that he had conversations with Billington. It goes on to say in the following sentence that in the course of those conversations there was never sufficient money to pay all of the requests for repayment. Indeed, repayments were made only to those lenders who might be the source of additional moneys.
I would suggest, Your Honor, that that apparently refers to the testimony of Mr. Yepez, who the Court may recall preceded Wayne Hintz in coordinating loan repayments. I would suggest, Your Honor, that that sentence is belied by Mr. Hintz' testimony, Mr. Yepez' testimony contained in Volume VII, page 38 and 39 of the trial transcript. I won't read it to the Court, but in summary, Mr. Yepez was asked who the leading phone organizers were. He named several, not

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