Joseph S. U. Bodoff, Esq.

Hinckey Allen & Snyder

One Financial Center

Boston, MA 02111-2625

Re: State of Maine, et al. V HER, Inc., et al., Docket No. CV-96-134

Dear Mr. Bodoff:

In connection with the upcoming hearing concerning the proposed settlement between Paul Richard and the bankruptcy trustee, we would appreciate it if you would identify the source of the $70,000 that Paul Richard intends to use to effectuate the proposed settlement, including the source's name, address, and telephone number. Also, if you could provide us with the documents relating to any financial transaction between Paul Richard and the source, it would be appreciated.

We understand that you have decided against seeking an in camera hearing and that you now have no objection to identifying the source of the $70,000. Since confidentiality is no longer an issue, since it would expedite matters, and since it would better enable the participants to focus on the issue of the legitimacy of this proposed transaction, we request that you voluntarily provide this information well in advance of the date for filing objections as evidence of Paul Richard's good faith.

Thank you for your cooperation in this matter.