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CONFIDENTIAL

Jan. 18, 2001

Probate and Trusts
Real Property
Dissolution

Confidential

Settlement –  $2,750,000

Court

L.A. Superior Central


Attorneys

Plaintiff

Cynthia Miller

Allan Bloom


Defendant

Steven S. Davis

Peter Steinman


Facts

Mr. and Mrs. S were divorced 20 years ago. Mr. S is a real estate developer with numerous, diverse holdings. At
the time of the divorce, various trusts were established and interests in real property were divided between Mr.
and Mrs. S through the trusts and through other arrangements. Through these various arrangements, Mr. and
Mrs. S continued to hold interests in the same parcels of real property.
Over the years, accounting and other disputes arose between Mr. and Mrs. S. Mrs. S brought this action for an
accounting, for partition, for dissolution of whatever partnerships may have existed between the parties and for
damages. Mrs. S alleged numerous acts of wrongdoing on the part of her ex-husband which warranted this
relief. Mr. S denied all allegations.

Settlement Discussions

On Nov. 29, 2000, a mediation took place with mediator Jeff Kichaven, which lasted four and a half hours. Before the mediation, Mrs. S had demanded $3.9 million in exchange for a transfer to Mr. S of all her interests in the real properties, trusts and partnerships, but Mr. S had offered $2.225 million. The case settled for $2.75 million, with Mrs. S agreeing to transfer all of her real property, trust and partnership interests and also agreeing to release all other claims she might have against Mr. S. Of the $2.75 million, $1 million will be paid in January 2001, while the remainder will be payable in January 2003. Mr. S will pay Mrs. S interest at 8 percent per year (payable quarterly) on the unpaid principal until it is paid, and the unpaid amounts will be secured by deeds of trust on certain of the parcels of real property which were the subject of this litigation.


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