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| | As to paragraph 9 of the Complaint herein, ddentily | each person, On where tertinany you intend ta r at the time of trial, to support your contentions or any pert thereof that the decedent wzs not, at the times indicated in said paragraph, “of sound mind . and memory or in any respect capable of making a will; nor was he capable of making or executing a walid deed or contract," As to said contentions or part thereof, identify each person known to you, your agents or attorneys, trial, who has information bearing on such conten- tions or part thereof. As to paragraph 9 of the Complaint herein, identify each communication, document or paper writing which you are aware which bears on the contentions contentions, and in each case identify the person or persons having custody, possession or control of any on whose testimony you do not intend to rely at buch communication {if in writing), document. or | _ : made by you in said paragraph or on any part of such an paper writing. each person, on whose testimony you intend to rely at trial, to support your contentions or any part thereof that the paper writings deseribcd in said paragraph 10 were obtaincd and the execution thereof - 26. (a) As to paragraph 16 of the Complaint herein, identify Procured from Clyde A. Tolson “by fraud and deecit Be person or persons unknown to the plaintiff.* Me er ry ake - 15 ~ ; af ga ° | exercised upon him by the defendant or some other