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writings, of sound mind and memory or in any reopect capable of making a willy nor was he capable of executing a valid decd or contract. 2. _ 10, The said paper writings purporting to be the last will(s) and teatament and codicils of said decedent were obtaine: and the execution thereof procured from the said Clyde A. Tolson by fraud and deceit exercised upon him by the defendant or some other person or persons unknown to the plaintiff. — 7. 11. Said paper writings purporting to be the last vill (s} and testament and codicils of said decedent were obtained and the execution thereof procured from the said Clyde A. Tolson by the undue influence, duress and coercion exercised upon him by the defendant or some other person or persons unknown to the plaintiff. .12, As a result of the decedent's weakened condition, physically and mentally, the defendant and those in collaboratic with him prevented others including the plaintiff, the decedent’ brother and closest relative, from seeing the decedent who became a virtual reciuse. 13. ‘Before June of 1972, and for many years prior theret< the decedent was and had been seriously ill and suffered from many ailments which resulted in hia permanent physical and ment: debility. Prier to June of 1972, the decedent had undergone a serious aortic replacement; he had several hemipl hie left and right sides; he suffered from extremely high blood te ee cee ere er ee ee me — - : — ee ee es ee ee