Defendants. the officers charged with carrying out the trust obligations of the United States, and their predecessors, have grossly mismanaged, and continue grossly to mismanage, such trusts and trust assets in at least the following respects, among others: (a) They have failed to keep adequate records and to install an adequate accounting system, including but not limited to their failure to install an adequate accounts receivable system; (b) They have destroyed records bearing upon their breaches of trust;
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Samples: Class Action Settlement Agreement, Class Action Settlement Agreement, Class Action Settlement Agreement