ELLEN SMITH FICTIONALIZED EXHIBIT 3 TIMELINE OF EVENTS SCHEDULED TO DATE 8/19/03 PER PRIVATE INVESTIGATOR, ESE STAFF NOTES, AND FORENSIC ACCOUNTING RECORDS

CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 1935 Approx. year Angie Long started as Charles Smith's secretary. Bates #E000471-Hinman Interview-ES (Per ES, worked 40 yrs. for CL & 4 yrs. for ES) 4/8/38 Date ES signed checking account signature card--BNT formerly Precedes Bates #A000001 from Smith & Northeastern National Bank of Boston. Hines, attorneys for BNT 1946 Joe Jones became a Christian with the Church of God while in Bates #E000461 Joe Jones Biography high school (age 17). dated 3-21-72 found in ES's documents Jul-51 Joe Jones pastor of New Christian Church of God in Iowa for five Bates #E000461 Joe Jones Biography years. Previous to that Jones Asst. Pastor of Church of God in dated 3-21-72 found in ES's documents Ohio, under Rev. Myers. 1952 or 1952 Approximate date Jean and Herman Green moved back from FAC/Jean Green interview 10/8/01 California. Considered Smiths "Aunt" and "Uncle"--Smiths were friends of Jean's parents. (Jean Green est. 19 years younger than ES.) 1964 Joe Jones elected to the Board of Trustees of Northeastern Bates #E000461 Joe Jones Biography Christian College. Served on Board until elected President in dated 3-21-72 found in ES's documents 1966. 9/9/1965 Date of Charles & Ellen Smith Charitable Trust Paul Harvey Declaration 1/21/00, p.1 1966 Joe Jones appointed President of Northeastern Christian Northeastern Christian College Yearbook/ College. ME paper 1/2/79/M. Jones's narrative

1966 Joe Jones elected to the presidency of Northeastern Christian Bates #E000461 Joe Jones Biography College. (Served 12 1/2 years) dated 3-21-72 found in ES's documents 4/25/1966 Charles Smith retired from company. 9/1/1967 Date of Smith Marital Trust, per Charles's Smith's last will. Paul Harvey Declaration 1/21/00, p.1 1967 In Boston National Bank litigation, Joe Jones claimed he'd met Rose Williams report, pg. 15. the Smiths in 1967 and that he personally attended Mr. Smith. (This is inconsistent w/Jones's own correspondence in 1970s-- See ltr dtd 12/5/73 that Mr. Jones was "looking forward" to meeting Mr. Smith when he was sick.) Ltr. dtd. 1989 from JJ to E000477 JJ word-processed ltr. copy found ES claimed they'd known each other "over twenty years." w/JJ's Green Acres address.

1968 Approx. year Charles first required nursing care (part-time at Bates #E000471 Hinman interview of ES first.) 1970's 5/18/1970 Letter from Wilma Meyer to Joe Jones enclosing a $10,000.00 RW Bates #000192 loan to Northeastern Christian College. 1971 Approx. year ES had 24-hr. nurses to care for Charles who had a Bates #E000471 Hinman interview of ES fatal disease. (CS had year-round nursing 4.5 yrs.) Sometime in Dr. Ralph Turner resigned as Senior pastor of 1st Methodist "History of Jones-Smith Friendship" per the early to church in Boston and moved to Portland, ME to become "Scholar- Mary Jones-from Oliver's files. mid- 1970's in-Residence" at Northeastern Christian College--Mrs. Jones's quote: "After Mr. Smith's death and at his request, Ellen very generously built Smith Hall to house Dr. Turner's extensive religious library." 1973 First evidence that Mrs. Smith had met Joe Jones, then Rose Williams report, pg. 20. President of Northeastern Christian College, based on Dr. Turner's move to Maine to work for the college. 7/1/1973 Northeastern Christian College Board, Executive Committee RW Bates #001147 approved employment contract for Joe Jones dated July 1, 1973.

10/1/1973 Smiths donated $3,000 to Northeastern Christian College-to be 7153 3,000.00 Bates #D000003 used at Dr. Ralph Turner's direction. (FIRST DONATION TO Oliver's files-10/1/77 ltr fm. Mr. & Mrs. COLLEGE) Smith to Northeastern Christian College 12/5/1973 Ltr. fm. Joe Jones (as President of Northeastern Christian) to Bates #D000004 Oliver's files-12/5/73 Mrs. Charles L. Smith: "The December 4th evening with you and copy of ltr fm J. Jones, Pres. of the Turners in the Christian fellowship of enjoying Handel's Northeastern Christian to ES (Letter copy "Messiah" will long be remembered by Mary and me. Your w/ no letterhead-typed by "eg") graciousness in hosting us at dinner, your delightful sense of humor, and radiant spiritual commitment were indeed refreshing. We look forward to being with you again and having the pleasure of meeting Mr. Smith. We send our best wishes for an enjoyable Christmas season. Blessings on you both."

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CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 1974 Charles L. and Ellen S. Smith Trust is established. 9/18/1974 Mr. & Mrs. Smith donated $17,000 to Northeastern Christian 7310 17,000.00 Bates #D000005 College towards building project and Turner Hall--noted that ES Oliver's files-9/18/93 ltr fm. Mrs. Smith to knew that J. Jones required surgery. (Ltr to "Dr. Jones" from Northeastern Christian College 12/20/1974 SEmS)i.ths donated $3,000 to Northeastern Christian College for ? 3,000.00 Bates #D000006 library building fund, based on letter from "Northeastern National Oliver's files-12/20/74 ltr fm. Robin Bank of Maine" (predecessor bank to 1st Interstate & BNT). Bank Hopkins, Pac Natl Bank of WA Trust Officer paid this check, most likely through their trust account. 3/11/1975 Copy of letter indicating J. Jones spent time at Smiths' house: Bates #D000007 Oliver-s files-3/11/75 "As the days pass, the beauty of the lovely day spent in your copy of ltr fm. J. Jones to Mr. & Mrs. Smith home and presence lingers with inspiration. We have continued (Letter copy w/ no letterhead-typed by "eg") to remain very close with Ralph and Anne. They both attended the Edith Green reception at our home last Saturday evening. Your love and friendship are deeply appreciated. I look forward to visiting with you again. Blessings on you both. /s/ Joe Jones, President." Note: This letter addressed to both Mr. & Mrs. Smith, but no specific mention of Charlese specifically.

4/2/1975 Ltr from Ellen and Charlese Smith (signed by ES)--greeting to 7419 12,000.00 Bates #D000008 "Dr. Jones"): Enclosed is our check, in the amount of $12,000, Oliver's files-ltr fm. Mrs. Smith to made payable to Northeastern Christian College toward the Northeastern Christian College building program at Northeastern Christian- for the proposed Turner library and residence. It was a real pleasure visiting with Mrs. Jones and you recently and talking with you of future plans for Northeastern Christian. With warm personal regards-Most sincerely, E & C Smith." 4/3/1975 JJ, as President of Northeastern Christian, ltr. to Mr. & Mrs. Bates #D000009 Smith: "Your kindness in having Mary and me in your home with Oliver's files-Ltr fm. J. Jones, Pres. the Turners is so very much appreciated. Mary was especially Northeastern Christian College to Smiths. pleased with your graciousness and the beauty of your home and (no letterhead) garden. The generous gift received in today's mail toward the Turner library-residence is also acknowledged with heart-felt thanks. Hopefully in the near future I can share with you more of the details as we progress on the plans for this project. We send our love in the Christian faith for good health and the joy of His blessings. Faithfully, JJ, Pres." 10/20/1975 Charles Smith died. FAC notes: Per R. Williams's interviews Sherman notes. #H267 with Jean Green and others, no one could recall JJ being at Mr. Smith's funeral. Interviews w/Rev. Turner may shed light on how well JJ may have known Charlese. In all the Northeastern Christian letters provided by JJ to show this long friendship, nothing was provided to indicate any individual friendship or sympathy for Mr. Smith's passing to ES. This lack of friendship is inconsistent w/all the statements by JJ to ES in the 2/23/00 video tape about how JJ "helped" Mr. Smith in his last days and JJ's inference of how Mr. Smith was the one who told Mrs. Smith that she could "trust Joe," as indicated in the 2/23/00 video. 1976 Mrs. Smith and Dr. Stan Cramer on the Advisory Board of Rose Williams report, pg. 26. Northeastern Christian College, Portland, ME, where Joe Jones was President.

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CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 11/8/1976 ES 11/10/76 ltr. to JJ (con't.): I enclose the receipted statement Bates #D000016 from Thunderbird for our rooms #380-382. ThES rooms were Oliver's files-11/8/76 ltr fm. ES to "Joe most satisfactory in every respect. Please give my affectionate Jones"--letterhead has Lakewood Av. regards to Mary. I do Pray The Lord will lead you and give you address, but typos and different font/format Wisdom and Strength to meet the daily challenge at Northeastern make this letter unusual. ES gave receipt Christian College, all to His Glory. Sincerely, /s/Ellen." FAC note: for rooms to J. Jones for her and Ms. Per Prestrud, Angelica Lind was Mr. Smith's personal secretary Angelica Lind. through his retirement. After Mr. Smith died, Ms. Lind continued w/ES. She should be interviewed, since she would know of JJ's relationship with Mr. Smith and whether they were "close," as asserted by JJ. 2/11/1978 Letter from Norma Franks (Modesto, CA) to Mark Deffenbacher RW Bates #000014-000017 at Northeastern Christian re gift to Northeastern Christian.

2/23/1978 May Bowers had given at least $18,000.00 toward the purchase RW Bates #000897 of the organ for the McGuire Auditorium at Northeastern Christian. 6/29/1978 Joe Jones acknowledged gifts totaling $1,200.00 from May RW Bates #000895 Bowers. Other correspondence to Ms. Bowers at 000894 and 000896 and following. 1979 (date In an undated letter to Joe and Mary, Wilma Meyer stated “I am RW Bates #000002 unknown) glad to enclose a small check to help Sue through school and will send another $1,000 the last of November.” Letter noted that the Minnesota Trust has finally decided to finance the Institute.

1/3/1979 Letter from Norma Franks and Mrs. W.R. McLaughlin re letter to RW Bates #000018 them acknowledging loan to Institute for $10,000.00. 01/05/79 Jones resigned at Northeastern Christian after receiving vote The Oregonian Newspaper, 1/16/79 of no confidence for his treatment of faculty and abuses of RW Bates #0000575 power at college. 3/6/1979 Joe Jones wrote to Wilma Meyer requesting her financial support RW Bates #000267 for his new International Institute for Spiritual Fellowship. "All gifts are legal charitable tax deductions through the Fellowship Foundation" located in Washington, DC. 4/6/1979 In undated handwritten copy of letter to Al and May Bowers, RW Bates #000891-892 Jones noted he left the office of NECC President and has established ISF with Senator Mike Horton's support. He states: "It is important to me for a few of my friends to help with some interim support. If you would consider a portion of the budget I have outlined and included in the enclosed report I would be extremely grateful." 06/26/79 Copy of letter to "Ellen" written after JJ no longer with Bates #D000020 Northeastern Christian College--resigned Jan 1979: I send you Oliver's files-6/26/79 personal letter fm. this note in the hope that your spirits are lifted and the Grace of Jones (not signed by JJ but inferred from the Lord is sufficient, even in the small things such as car him) to "Ellen." accidents. I was relieved to know that you were not hurt. Cars can always be fixed, easier than people. All the times I have observed you while driving you have been extremely alert and a most careful drive, so I know this must have caught you unaware. (ES nearly 78 at this time) I certainly wish I was close enough to help out at times like this.

12/28/1979 Letter from Norma Franks to Joe Jones enclosing $10,000.00 RW Bates #000036-000037 loan sent to Joe’s house. 1980's 1980 Ellen Smith gifted Joe Jones $6,000.00 Jones's representation to the court. 7/10/1980 ISF received $3,000.00 check from Bob Dark. RW Bates #001064 8/6/1980 In a letter to Wilma Meyer, Joe Jones thanked Ms. Meyer for RW Bates #000271 financial assistance provided for Sue Jones's college expenses. 8/23/1980 Joe Jones wrote in a letter to Wilma Meyer- thanked Ms. Meyer RW Bates #000272 for "the generous support you are willing to give related to the children's' college expenses." File: EX-2-Timeline-Basic-Exploitation(1).xls Page 3 of 11 Tab: Sample 9-05 ELLEN SMITH FICTIONALIZED EXHIBIT 3 TIMELINE OF EVENTS SCHEDULED TO DATE 8/19/03 PER PRIVATE INVESTIGATOR, ESE STAFF NOTES, AND FORENSIC ACCOUNTING RECORDS

CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 10/6/1980 In a letter to Ms. Meyer, Joe Jones thanked Wilma Meyer for RW Bates #000273 college financial assistance for Sue. "With what you committed, she will make it though the year." 1981 Ellen Smith gifted Joe Jones $6,800.00. Jones's representation to the court. 1981 ES listed as an advisor to the Institute for Spiritual Fellowship Rose Williams report, pg. 21. and Renewal, run by Mr. Jones. 1981 John Storm, English minister, first met Mrs. Smith in Montreal Rev. Dr. John Storm interview 9/19/01 through dinner w/Dr. James Houston of Regent College. A female companion was with ES at dinner in Canada. 1/4/1982 Letter from Mary Jones to Norma Franks acknowledging a total of RW Bates #000093 $3,000.00 in gifts for the year 1982. 3/10/1982 Letter from Ms. McLaughlin and Ms. Ferguson to the Joness RW Bates #000113 “We’re enclosing a check for $1,000.00 for the Institute’s President’s children’s education.” 10/20/1982 Letter from Norma Franks to Institute for Spiritual Fellowship. Ms. RW Bates #000129 Ferguson enclosed a check in the amount of $1,000.00- restricted gift for President’s salary. 1983 Ellen Smith donated $6,000 to Jones's "Institute for Spiritual 6,000.00 Bates #C000175-ES 1040 tax return Renewal." (first year ES tax returns available--it is unclear Contributions Schedule whether this was part of $9,500 clamed as "gifts" to Jones, per his list to court.) ES gifted $19,000 to Lincoln Foundation and $10,000 to the Christian School in San Diego this year and total $60,830 in contributions 1983. 1/10/1983 Letter from Mary Jones to Norm Banks, CPA enclosing a RW Bates #000139 $1,000.00 check from Norma Franks for deposit to our (Institute) account. Spring-83 Lydia Pederson, at age 66, started working as personal secretary FAC/Lydia Pederson Interview 8/9/01 for ES. LP had retired as legal secretary from Taylor Callow & Taylor in 1980. Did firm's taxes and accounting. Typed all ES's tax schedules for CPA each year (didn't use computers). ES very private-wouldn't let her balance check book.

5/4-9/83 Ellen/Joe in San Diego Bates #D000024 "Calendar Record 83-99" 5/10/1983 Ellen/Joe to Boston Bates #D000024 "Calendar Record 83-99" Jun-83 Rev. John Storm met ES in Montreal Bates #F000009 Storm Record-Lincoln 6/8/1983 Letter from Norma Franks to the Joness enclosing a check to the WR Bates #000147 Institute “for designated giving as previously indicated. Is there a special reason for $1,500.00 that keeps pounding away at me? Last night the Lord told me again to send it to you and trust him for the result.” (FAC Note: In 3/82, N. Ferguson sent $1,000 for WR Bates #000113 &129 Sue's college and 10/82 NF sent $1,000 for JJ's salary.)

7/13-8/3/83 Ellen, Joe, Mary to England--Jones family accompanied ES on a Bates #D00024 "Calendar Record 83-99" trip to London. ES hired a driver to show them the sights while "History of Jones-Smith Friendship" per the Jones's "primary responsibility was for Ellen's care and Mary Jones-from Oliver's files. welfare." 1984 Ellen Smith donated $3,000 to Jones's "Institute for Spiritual 3,000.00 Bates #C000185-ES 1040 tax return Renewal." (It is unclear whether this was part of $10,000 clamed Contributions Schedule as "gifts" to Jones, per his list to court.) ES gifted $12,500 to Lincoln Foundation and $500 to the Christian School in San Diego this year, with a total $29,578 in contributions 1984.

1984 Estimated time Jean Green first met Joe Jones. Rose Williams report, pg. 18. 1985 Taxes No gift tax returns filed for ES -Total understated if "gifts" to FAC Ex. Z-Comparison of CR 2A to Gift Joness, per their representation was $25,400 less $20,000 Tax returns exemption = $5,400 taxable gifts. 1985 Sue Jones accompanied ES to England "for Ellen's care, welfare Bates #D000037 "History of Jones-Smith and companionship." Per Mrs. Jones's narrative, ES proposed Friendship" per Mary Jones-from Oliver's that Sue leave college to become ES's permanent companion. files. Per Mary's narrative, Joness persuaded ES to let Sue remain in college. (FAC note: By 1985, Sue was nearly 25 years old--B.D. 12/19/60--must have been in graduate school if college since 18?)

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CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 3/1/1985 In letter to Mrs. Al Bowers, Joe Jones indicated that ISF has RW Bates #000885 received 5 grants from the Minnesota Trust totaling $585,000.00. He stated that he seeks her assistance in purchasing the Norton, ME property. Her purchase would restore "the personal investment made by Mary and me," allow ISF to use the property as a retreat center, and the funds would be counted as necessary matching funds for this year's Minnesota grant.

3/1-12/85 Ellen/Joe in San Diego Bates #D000025 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" Apr-85 ES donated $5,000 to Rev. John Storm Fund 5,000.00 Bates #F000009 Storm Record-Lincoln Jun-85 ES donated $4,000 to Rev. John Storm Fund 4,000.00 Bates #F000009 Storm Record-Lincoln 1986 Taxes No gift tax returns filed for ES -Total understated if "gifts" to FAC Ex. Z-Comparison of CR 2A to Gift Joness, per their representation was $32,290 less $20,000 Tax returns exemption = 12,290. 1986 Ellen Smith donated $1,000 to Jones's "Institute for Spiritual 1,000.00 Bates #C000224-ES 1040 tax return Fellowship." ES gifted $28,000 to Lincoln Foundation this year Contributions Schedule and $40,000 to the Christian School in San Diego, with a total $153,679 in contributions 1986.(This was the last year ES donated anything to "Institute for Spiritual Renewal" as charitable donation deduction. 3/11/1986 Per IRS notice to ISF, ISF owed $1,128.42 in taxes and tax penalties and interest. See also 000819-826. 1987 Taxes No gift tax returns filed for ES -Total understated if "gifts" to FAC Ex. Z-Comparison of CR 2A to Gift Joness, per their representation was $49,484 less $20,000 Tax returns exemption = $29,484. 1987 Ellen Smith donated nothing to Jones's "Institute for Spiritual Bates #C000205-ES 1040 tax return Fellowship." ES gifted $39,500 to Lincoln Foundation and Contributions Schedule $30,000 to the Christian School in San Diego this year, with a total $86,720 in contributions 1985. Sep-87 ES donated $10,000 to Rev. John Storm Fund 10,000.00 Bates #F000009 Storm Record-Lincoln Oct-87 ES donated $5,000 to Rev. John Storm Fund 5,000.00 Bates #F000009 Storm Record-Lincoln Aug-88 Gift schedule showed $3,000 JJ (medical surgery) & No Cks. 3,000 Bates #C000027 LP Typed Schedule-88 $4,000 to MG. Available 4,000 (Also see Bates #006065-RW-same) 1990 Taxes Harper Bancroft CPA firm filed Form 709 Gift Tax return 4/12/91 Bates #C000036-39 1990 Gift tax return and reported $20,000 each gifted to Joe Jones and Mary Jones. FAC note: This tax return as originally filed understated the amount Joe claimed to the Court by $46,700 and overstated the FAC Ex. Z-Comparison of CR 2A to Gift amount claimed by Mary by $8,000, plus understating the in-kind Tax returns car gift of $28,000 if amounts were "gifts". (See Jones representation amounts above.) 1990 Witnesses, including Dr. William Watts, ES's physician until his Rose Williams report, pgs. 8 & 21. retirement in 1990, reported that by 1990, ES showed clear signs of dementia, confusion, and short-term memory loss. Jul-Aug 90 Mrs. Jones accompanied ES to England for six week stay in "History of Jones-Smith Friendship" per London. "This was a constant vigil of looking after Ellen's needs, Mary Jones-from Oliver's files. but Mary was glad to do it." Per Mrs. Jones's narrative.

9/18/1990 Ellen had a car accident Bates #D000027 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" Sep-Nov 90 Ellen Smith had car accident at 90 years old (actually 89) and "History of Jones-Smith Friendship" per had difficulty passing her driver's test. Per Mary Jones's Mary Jones-from Oliver's files. narrative, Joe convinced ES to give up driver's license two years later (est. 1992). 10-15-16/90 Joe in Boston for Ellen's driver test #1 Bates #D000027 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 10/22-23/90 Joe in Boston for Ellen's driver test #2 Bates #D000027 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record"

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CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 11/6/1990 Joe in Boston for Ellen's driver test #3 Bates #D000027 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 11/8-12/90 Ellen in Maine Bates #D000027 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 11/29/1990 Joe in Boston for Ellen's driver test #4 Bates #D000027 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 8/13-18/92 Ellen/Joe/Mary to Calgary/Banff Bates #D000028 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 1993 Ellen Smith gifted Joe Jones $171,00.00. Jones's representation to the court. 1993 taxes Gary Cooper, long-time CPA-Cooper, Baines & Arthur CPAs ltr Bates #C000069 Ltr fm. Harper, CPA to ES dtd 3/30/94 to ES. Specifically stated: "This is just a reminder to 3/30/94 about gift tax implications. you concerning tax data for 1993. Be sure to list any gifts made to friends or relatives in 1993 which aggregate more than $10,000 to any individual. In the case of your friends Mr. and Mrs. Jones, your gifts for 1993 will not have to be reported unless the total exceeds $20,000." FAC note:--NO GIFT TAX RETURN FILED FOR 1993. If truly gifts, this understated the gift tax return FAC Ex. Z-Comparison of CR 2A to Gift by the Jones's representation to the Court (above) by $171,000 Tax returns for Joe and $13,300 for Mary, for a total tax understatement of $184,500 less $20,000 exemption = $164,500.

1993 Jones approached ES's Atty. John Price to prepare POA giving Rose Williams report, pg. 50. him control over all ES's properties and asked about provisions of ES's will. Price responded it was "inappropriate" to inquire about ES's estate. Jones dropped POA request. 2/28/1993 Fee statement from Shuck Attorneys to Institute c/o Rick RW Bates #002245-002246 Mayberry at Green Acres Drive. Entries include drafting articles and bylaws for the corporation 12/2/92 and organizational minutes 1/22/93. 4/16/1993 Shuck Attorneys bill for ISF sent to Green Acres Dr. property, RW Bates #001727 Attn Rick Mayberry. Services include drafting IRS form 1023 and letter to Mayberry for $504.48. Aug-93 (Joe dislocated shoulder) Bates #D000029 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 12/10-13/93 Ellen in Maine Bates #D000029 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 1994 1994 Ellen Smith gifted Joe Jones $180,765.00. 1994 Ellen Smith gifted Mary Jones $86,100.00. Jones's representation to the court. 1994 Taxes Gary Cooper, CPA ltr dtd 2/20/95 to ES again reminding ES of Bates #C000070 Ltr fm G. Harper to ES gift tax requirement: "I want to remind you, as I do each year, 2/20/95 C275 that a gift tax return will be required for all gifts to individuals for amounts exceeding the annual $10,000 exclusion. This means that joint gifts, if any, to your friends the Joness in excess of $20,000 for the year 1994 must be reported. FAC note: If truly gifts, this understated the gift tax return by the Jones's FAC Ex. Z-Comparison of CR 2A to Gift representation to the Court (above) by $180,765 for Joe and Tax returns $86,100 for Mary, for a total of $266,865 less $20,000 exemption = $246,845. 3/17/1994 Per JJ's Wall Calendar, MMG's surgery 8:00-Bess Kaiser Hosp. Bates #G000003 JJ Mar Wall Calendar

3/28/1994 Per JJ's Wall Calendar, JJ-Stitches out Bates #G000003 JJ Mar Wall Calendar Mar-May/94 (Mary-cancer surgery & chemo) Bates #D000029 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record"

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CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 4/12/1994 Joe in Boston Bates #D000029 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 4/18/1994 Joe in Boston (Per Wall Calendar EE Apr 18-20-Flew TWA) Bates #D000029 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" Bates #G000004 JJ Apr Wall Calendar 4/28/1994 Joe in Boston Bates #D000029 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 4/29/1994 Ltr. typed by L. Pederson (ES:p) from ES to Lincoln Foundation No Cks. 10,000.00 Bates #E000492 Ltr. 4/29/94 fm. ES to in Illinois--$10,000 donation for use at direction of Dr. John Available Lincoln Foundation Storm. Sep-94 Sandra Sherman employed as Ellen Smith's housekeeper. Sherman notes; DeSmet GAL report 4/00 JJ Decl 1/11/02 Ex. 70-Sherman Affidavit 4/30/01 (Bates #J111-159--R. Kohn Declaration 5/1/01, Ex. 6-Guardian Ad Litem report filed by Ervin DeSmet 4/28/00)

Nov-94 Rev. John Storm stayed w/ES for the weekend. David Jones, Storm Record of gifts-Lincoln Foundation Pres. of Lincoln Foundation, Philadelphia, met ES in Boston FAC/David Jones Interview 9/12/01 when Storm spoke at United Presby. Church. Nov-94 David Jones recalled ES "very lucid" in 1994. She made it clear FAC/David Jones interview 9/12/01 that she was leaving a bequest in her will. ES had a great deal of respect for Rev. Storm's work. (Per interview, Jones believes they are currently in ES's will.) Chided John about how he could still travel, since he was so much "younger." (ES was 91 and Storm was approx. 78). 12/29/1994 ES Check to Joe Jones while in Boston. Memo marked: "Travel 8294 1,265.00 Bates #B000330 copy of check-No Stubs Expenses." Clrd. 1/5. (FAC note: JJ just got "Travel Expense 12/16 for $15,000 this same month.) 12/30/1994 Letter from Robert D. Dayton at Shuck Attorneys to Joe Jones RW Bates #002266 enclosing Settlement Proposal providing that all the charitable beneficiaries of the Johnston Estate receive a net of 66.29% of the amount of the bequest under the terms of the 1980 Will.

1995 1995 Ellen Smith gifted Joe Jones $64,065.00. Jones's representation to the court. 1995 Ellen Smith gifted Mary Jones $30,800.00. Jones's representation to the court. 1995 taxes FAC note:--NO GIFT TAX RETURN FILED FOR 1995. FAC note: If truly gifts, this understated the gift tax return by the Jones's representation to the Court (above) by $64,065 for Joe and FAC Ex. Z-Comparison of CR 2A to Gift $30,800 for Mary plus $47,000 for the purchase of a new Cadillac- Tax returns -Total understated gift amount for tax return was $141,865 less $20,000 exemption = $121,865. 1995 Lydia Pederson stated ES's short-term memory loss was so Rose Williams report, pg. 11. severe by 1995 that she couldn't remember how to write a check, what checks she'd signed, or what bills she'd paid. She could not balance her checkbook. 3/7/1995 ES Check to Joe Jones--Memo: "Happy Birthday"--however, JJ's 8358 1,000.00 Bates #B000341 copy of check-No Stubs B.D. is in Sep., ES in Maine, clrd. 3/10. 5/24/1995 ES Check to cash for ES, on way back from Maine., ES's Dr. Lic. 8412 1,000.00 Bates #B000557 copy of check-No Stubs on back of ck., clrd 5/24. (FAC note: ES cashed $1,000 ck. just 1 wk. earlier before Maine. trip.) 7/12/1995 Macy's purchase: Women's Hosiery @store #004 Belmont, ME. 12.98 Macy's bill ref. #186255074 probably for ES. 7/12/1995 Macy's purchase: Women's Dress Shoes @store #004 78.93 Macy's bill ref. #186529233 Belmont, ME. probably for ES. 7/12/1995 Macy's purchase: Men's Hand sewn & Penny Shoes/ Mens 256.38 Macy's bill ref. #186706656? Casual Shoes @store #004 Belmont, ME. Appears to be for JJ who is in Boston and shopping w/ES. Macy's bill paid by ES on Bates #B000351-Copy of check #8541 9/4/95-$1,123. File: EX-2-Timeline-Basic-Exploitation(1).xls Page 7 of 11 Tab: Sample 9-05 ELLEN SMITH FICTIONALIZED EXHIBIT 3 TIMELINE OF EVENTS SCHEDULED TO DATE 8/19/03 PER PRIVATE INVESTIGATOR, ESE STAFF NOTES, AND FORENSIC ACCOUNTING RECORDS

CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 7/12/1995 Macy's purchase: Womens Gloves@store #004 Belmont, ME. 12.98 Macy's bill ref. #186933611 ES expense. Bates #B000351-Copy of check #8541 7/12/1995 Macy's purchase: Mens Furnishings @store #004 Belmont, ME. 119.02 Macy's bill ref. #186955973 Appears to be for JJ who is in Boston and shopping w/ES. Macy's bill paid by ES on 9/4/95-$1,123. Bates #B000351-Copy of check #8541 7/12/1995 Macy's purchase: Mens Furnishings @store #004 Belmont, ME. 97.38 Macy's bill ref. #186955974 Appears to be for JJ who is in Boston and shopping w/ES. Macy's bill paid by ES on 9/4/95-$1,123. Bates #B000351-Copy of check #8541 7/12/1995 Macy's purchase: Mens Neckwear @store #004 Belmont, ME. 86.56 Macy's bill ref. #187329986 Appears to be for JJ who is in Boston and shopping w/ES. Macy's bill paid by ES on 9/4/95-$1,123. Bates #B000351-Copy of check #8541 7/12/1995 ES Check to Joe Jones while in Boston. Clrd. 7/14. 8448 5,000.00 Bates #B000569 Copy of check Bates #E000244-Stub 7/12/1995 ES Check to Joe Jones while in Boston. Memo marked: "Travel 8450 500.00 Bates #B000571 Copy of check Expenses." Clrd. 7/14. Bates #E000244-Stub 7/12/1995 ES Check to Payless Drug Store--must have been taken by JJ 8451 46.34 Bates #B000048 while in Boston shopping w/ES. Bates #E245-Per Stub 7/13/1995 Macy's purchase: Checkbook Wallets @store #001 Boston, MA-- 183.94 Macy's bill ref. #133732318 Unclear if for ES or JJ. JJ is in Boston and shopping w/ES. Macy's bill paid by ES on 9/4/95-$1,123. Bates #B000351-Copy of check #8541 7/13/1995 ES Check for cash to ES, dated 7/12, but clrd. 7/13, JJ in Boston. 8447 2,000.00 Bates #B000568 copy of check This check first of two checks to cash 7/13. Bates #E000243-Stub 7/13/1995 ES Check for cash to ES, dated 7/12, but clrd. 7/13. This check 8449 4,000.00 Bates #B000570 copy of check sandwiched between two checks to JJ--2nd ck. same day while Bates #E000244-Stub JJ in Boston. ThES funds attributed to JJ. SUM 12,394.51 6/5/1996 Check Stub #8771 to ES for Certified check-Car/Damarow (sic) 8771 7,000.00 Bates #E000352 Stub #8771 Ford-ck. Changed from $7,000 to $26,853, never clrd. Nevr clrd 26,853.00 "Replacement" Ck. #8977 payable to First Interstate cleared for 8977 26,853.00 Bates #B000283 Check #8977 $26,853. Purchased Van for Jones family--not on ES's 1996 tax return filed in 1997 or on amended return in 1999--Per ES Ck. 26,853.00 Bates #B000705 Cashier's check Cashier's check for this purchased at Private Client Services. Supervisor Mary Darby signed Cashier's Check. Although not on JJ's calendar, it appears that JJ was in Boston to get the cashier's check fro the Ford Van. Jones claimed as $25,000 van FAC Exhibit X-Jones "Gift" List "gift" on CR 2A list for 1996. Categorized this check as "major purchase" as part of van for Joness, based on ES's memo of "car.". 6/5/1996 ES "Counter Check" for Canadian Currency, cashed at main Counter 2,227.80 Bates #B000594 copy of Counter Check branch, JJ in Boston. This was for the Montreal trip 6/13-16 in the Check Bates #E000364 Deposit Record w/ amt. of new van. ES noted this amount on a page in her check stubs Counter Check noted marked "Deposit Record," but nothing was deducted from her balance. 8/21-26/96 Ellen in Maine Bates #D000030 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 8/23/1996 ES Check to Vic Alfonso Cadillac (Maine.)-This check was "Refer 8825 47,828.51 Joe and Mary Jones's statement to Maker," because bank called ES when check prESnted, since Bates #B000713 Copy of check for Cad. writing was odd. ES said she didn't write it, so it didn't clear. ES's stub not deducted. This eventually clrd. 9/6-See notes below. Bates #E000373 Stub-not ded. fm. bal. (FAC note: Jones's claimed they received a $47,000.00 Cadillac in 1995, per Joness' Court statement. However, ES's check for Cadillac not written until 8/23/96 for $47,828.51--This was a 1996 purchase, same year as $26,000 van for Joness & Carsons Bates #B000283 Copy of check for van purchased 6/5/96.)

11/22/1996 Sherman notes: John Price to house - discuss estate, E First Sherman notes. Bates #H163 "upsetting news." Said someone has gone to great lengths to find out her income.

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CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 3/25/1997 Sherman notes: Joe took E to P(ortland). He told me last week it Sherman notes. Bates 3H171 would be 3/28, but today he said she wants to go during the week and he would bring her back Fri or Sat and "don't mention Easter". Sherman thinks Joe came to take her & new attorney to Hennis (sic) at Bank and didn't want to go home & back again on Friday to get her. Joe drove his own car again.

Mar-97 Ellen Smith and Jones JJ John Price, Ellen's longtime Estate Harvey Declaration 1/21/00 Attorney from Perkins Coie. (Harvey found out 4/97.) 3/25/1997 Sherman notes (Con't.): Letter from Davis Wright Tremaine - Sherman notes. Bates #H059, H172 unopened. Lydia called. Said she doesn’t like how he has taken over her affairs and asked me what I'm to do in case of an emergency. I said call 911; I don't know of a doctor. Joe said I'm to call him & Lydia said that isn't a good idea since he's 200 miles away. We agreed to call 911, then Maudie, then Joe.

4/23/1997 Sherman notes: ES seeing things..like she called to Sherman, Sherman notes. Bates #H045, H173 "Joe! Who is that man sitting at my desk?" ES saw smoke in hall, so Sherman assisted her into hall and kitchen--no smoke. Delirium?? Mid-Sep-97 Lydia Pederson stopped working as secretary for ES late FAC/Lydia Pederson Interview 8/9/01 summer. Stated ES would ask her to come over for work, but drink tea and never conduct business. ES insisted on paying LP, even when no work done. Mrs. Pederson could no longer take her money and not provide services, per LP interview. ES's memory very sharp in earlier times, but had declined over last 2-3 years. Checkbook was a mess, but wouldn't let LP fix it. LP suggested that ES's checks to Jones go to a church so she could take deductions. That never happened--he was conning her, per LP. ES asked her if LP thought Joe was taking advantage of her- Lydia said yes, and ES said she wouldn't give him more money-- but then she would give in. ES could not remember how to write a check by 1997, per Lydia. 9/15/1997 Sherman notes: “At 5:15 p.m. I got her to write a check for IRS 9273 30,000.00 Sherman notes. Bates #H061, H188 quarter[ly] payment due 9/15 for $30,000.00. I drove to main Bates #A000507-Overdraft History P.O. to mail 7:30 p.m.”--ES in overdraft. 9/15/1997 ES check to IRS--Per OD notice, Nancy D note says "taxes,"-ck. 9273 30,000.00 Bates #A000507-OD notice clrd. 9/18, No Stub. Bates #B000138-Stmt. 09/15/1997 Trust transfer-No Stubs. Deposit 13,070.55 Bates #B000139-Stmt. 09/15/1997 company/Exxon Dividend checks-No Stubs. Div. 2,157.00 Bates #B000138-Stmt. Bates #B000665 company & Exxon copies of deposit 9/15/1997 Letter from McAdams's office to ES on ES's delinquent account Bates #EE000005 Shuck Attorneys ltr. dtd past due by $3,564--signed by Christina Hansen, Acct. Rec. 9/15/97 Specialist in Shuck Attorneys office. 9/18/1997 Sherman notes: He (JJ) came on Thurs.--not Wed like I was led Sherman notes. Bates #H189 to believe. Around noon-Bob said -took her to dinner--Bob had to jumpstart her car. Bob made comment to ES in front of Joe that ES should stay out of poison oak, so Joe must have been aware of condition of her legs. Obviously not concerned since he went home Friday. Jones had said he would take ES to podiatrist next week when he left. That was 4-5 wks. ago.

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CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 5/14/1997 ES Check #9177 for $10,000 to Sue Carson, cleared 5/19. See 9177 10,000.00 Sherman notes. Bates #H186 Sherman note 7/29/97: Note in safe - $10,000 to Bob Carson Bates #B000496 copy of check dated 5/97; she said "loan" and he hasn't mentioned it since! Need to interview Carsons for possible repayment. Also note: Carson's CR 2A disclosure stated, adjacent to this $10,000 CR 2A Agreement 12/6/00 Exhibit-Gifts to amount, thES funds were for, "Gift to buy furniture for Mrs. Jones Family Members Smith's room in our house. We purchased a queen size bed and bedding, dresser, lamps and accessories. We also had the room painted and window treatments installed. This is a direct conflict with the "loan" ES wrote up and stored in her safe.

9/29/1997 Sherman notes: “Monday 11:50 AM . . .[Joe] called E and said Sherman notes. Bates #H062, H190-H191 he’d found a house in AZ for $375,000.00. Later in day she said to me, ‘Did I say anything to you about buying a house in AZ?’ I said, Joe called this morning. She said, ‘I’m not buying him another house. I don’t like AZ!’” 9/30/1997 Sherman notes: Told Jean about house deal. . . Jean told Hennis Sherman notes. Bates #H062, H191 (sic) about house. 09/30/1997 ES check to ES-Ck. clrd. 9/30 Boston PCS (no date on ck.)-JJ to 9293 500.00 Bates #B000526 copy of check WA, DC conf., A510-OD notice, No Stub 09/30/1997 OD charges for 3 checks. OD 63.00 Bates #A000510 Overdraft statement 9/30-10/17/97 On 8/15/97, first class airline tickets were purchased for JJ and Bates EE000944-946--VISA stmt. & AAA Mary Jones on ES's VISA card. Total charged $5,110.80 for flight itinerary flights 9/30/97-10/17/97. Travel was from Maine, ME to WA, DC, then Chicago & Indianapolis, then return to Maine. ES did not have tickets--only JJ & MG. These charges paid by ES on 9/20/97 w/Ck. #9288. Acct. in overdraft.--(FAC note: JJ must Bates #B000312-Check copy (in OD) have changed the reservation dates, since he was back in Boston to take ES to Maine on 10/13/97--See entries below.)

Oct-97 Social Security check for $748 not deposited to ES's acct. 748.00 Bates #A000003 Oct. BNT stmt. 10/1/1997 Ltr. fm. John Storm to ES thanking her for phone call that day & Bates #E000489 Ltr. fm. J. Storm-England reminder she was going to make an annual donation.--Also, ltr. Bates #E000490 Ltr. dtd. 7/10/97 fm. Dr. from Dr. Wolf concerned about Storm's flying economy class-- Wolf to ES at Spring St. mailed from Storm--Orig. ltr. sent to ES's condo. 7/10/97. 10/03/1997 Trust Transfer -No Stubs. Deposit 15,000.00 Bates #A000003/B000142-Stmt. 10/08/1997 ES check to Cooper, Baines & Arthur (CPA) -Memo: income tax 9301 3,580.00 Bates #A000013 copy of check prep, No Stub. 10/09/1997 ES check to Copeland Associates--Ck. Memo: Sept 9, 1997, No 9302 831.77 Bates #A000009 copy of check Stub 10/09/1997 ES check to Copeland Associates--Ck. Memo: balanced owed, 9303 831.77 Bates #A000009 copy of check No Stub--FAC note: This was the second check to Copeland. ES must have forgot she paid this. ES deposited $831.77 on 12/8/97- Ref. 831.77 See Bates #B---669-672 copy of deposited -this must have been the refund for her double payment. refund 10/13/1997 Joe in Boston Bates #D000031 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 10/13/1997 ES Check # 9478 for $5,000 to Ellen Smith (chk. cashed 10/14, 9478 5,000.00 Bates #A000015 copy of check the day ES left w/JJ for Maine). This check is out of sequence and the Stub is missing. 10/14-21/97 Ellen in Maine Bates #D000031 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record" 10/15/1997 Trust transfer-No Stubs. Deposit 13,816.66 Bates #A000003/B000142-Stmt. 10/19/1997 ES Check # 9245 for $1,000 to Mary Jones (out of seq.) 9245 1,000.00 Bates #A000015 copy of check 10/20/1997 McAdams: Prepare Durable General Power of Attorney. 1 hrs 190.00 JJ Decl 1/11/02-Ex. 37-McA's billings-p.52 SWW Inv. #705949-p.1 10/22-24/97 Joe in Boston Bates #D000031 J.J. Decl 1/11/02-Ex. 45-JJ "Calendar Record"

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CHECK # CHECK OR OR BILLED DATE EVENT HOURS AMOUNT REFERENCE/ SOURCE 10/22/1997 McAdams: Phone call from Jones; conference with same; 5.40 hrs 1,026.00 JJ Decl 1/11/02-Ex. 37-McA's billings-p.52 prepare Durable POA - Jones; Revocation of POA - Harvey; SWW Inv. #705949-p.1 promissory note - Jones; ltr to CPA; conference with client and Jones at Sheraton; revision of Note and POA; copies and deliver to Sheraton. 10/22/1997 Durable Power of Attorney to Jones, witnessed by McAdams. Harvey Declaration 1/21/00, Ex. S 10/22/1997 Promissory note for $380,000.00. McAdams drafted this strongly See Bates #C000131 in favor of Joness: 3.94% interest rate, required semi-yearly Rose Williams report, pg. 30. interest only payments, all was to be forgiven if ES died.

10/22/1997 Ellen Smith signed Durable General Power of Attorney to Joe -DPOA (Copy in Harvey Decl Jones. (GAL stated ratification of Durable Power of Attorney 1/21/00, back of Ex. S) signed by Mrs. Smith in month of December 1998--Copy of DeSmet GAL Report dtd 4/28/00, pg. 3 DPOA shows ES signed 10/22/97, but McAdams did not -Harvey Decl 1/21/00-Ex. S-w/McAdams notarize until 6/1/98). ltr to Harvey dtd 11/9/98

10/22/1997 Ellen Smith signed Revocation of Power of Attorney for Paul A. Harvey Decl 1/21/00, back of Ex. L, w/ltr fm Harvey on 10/22/97, but McAdams did not notarize until 6/1/98). McAdams to Price dtd 6/15/98

10/22/1997 Macy's purchase: Town Square Coats @store #001 Boston-- 190.05 Macy's ref. #133112221 unclear if for ES or JJ who was in Boston. 10/22/1997 Macy's purchase: Handbags/Handbags @store #001 Boston 117.18 Macy's ref. #133664639 probably for ES. Billed pd. by ES 12/6/97. 9340 307.25 Bates #A000047/48 Copy of check 10/24/1997 ES Check # 9306 for $2,000 to Joe Jones. JJ in Boston--signing 9306 2,000.00 Bates #A000015 copy of check DPOA w/ McAdams. Estimated Sherman information (no date): Copy of note in Joe's writing Sherman notes. Bates #H133 (Typed Mid Oct found by Sherman in ES's trash, "Ellen agreed to make a loan in version H062), J.J. Decl. 1/11/02, Ex. 18 1997 the amount of $380,000.00 for purchase of house. EE instructed Paul Harvey to sell stock and transfer this amount to her checking account - There will be capital gains tax - this is normal for all profit made on stock - Ellen will call Harvey Friday afternoon about 1:30 to tell him to make this transfer $380,000. Harvey to call EE as soon as funds are ready - Then EE will write check for $380,000 to Joe. Joe has already signed the loan note- " (Underlining on hand-written note.) Estimated Sherman information (no date)-second note from EE trash--Copy Sherman notes. Bates #H133 (Typed 10/24/1997 of note in JJ's writing: "If anyone says something about capital version H062), J.J. Decl. 1/11/02, Ex. 18 gains tax - say everyone pays that - I have $11 million in my trust & can afford it. Pay the tax and make the transfer of $380,000 to my checking account." Estimated Ellen Smith met with Paul Harvey and Mark Davis, her portfolio Paul Harvey Declaration 1/21/00, p. 4 10/24/1997 manager at her apartment. She wanted $380,000.00 transferred to buy Jones a house in his name in Arizona. Jones was present. ES asked them about 5 times in 45 minute period if BNT representatives had been introduced to Jones. The bank complied. (Unsecured promissory note signed by Joe Jones Two versions of note from CPA workpapers found for this purchase.) at Bates #C000131-132 10/24/1997 McAdams: Phone call from Jones re Boston National/Harvey; 1.5 hrs 285.00 McAdams billings-#705949-p.1 review of trust agreements w/bank. (J.J. Decl. 1/11/02-Ex. 37-p.52) 10/24/1997 Ellen Smith (with Jones in the background) called the bank directing a transfer of $380,000.00. (ES most likely had her "script" --above two notes in JJ's writing--when making this phone call. 10/27/1997 Letter to Boston National Bank directing Boston National to sell Letter to Boston National Bank. securities from her trust portfolio to purchase a house in "her name" in Arizona. (ES's 1997 tax return reflected capital gain of $355,777 reported for ES's Revocable Trust, resulting in over $70,000 taxes. Then 45% gift taxes on $380,000 when debt relieved in 1999.) 10/27/1997 McAdams: Phone call from Jones re meeting with Harvey. .30 hrs 57.00 McAdams billings-#705949-p.1 (J.J. Decl. 1/11/02-Ex. 37-p.52)

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