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No written comments

Note: It has not been determined that the cooperative share is a voting security. amerger normally means an acquisition of all of the v/s. However, this may or may not be one of the exceptions. It is...

Wrong, exempt under 802.20

Not exempt under 802.30 must file. Wayne, Kaplan, Andy, Suzzanne & Danaconcur. called (redacted) 2-26-85. This transaction is not exempt under 802.30and you must file if it meets the size requirements...

OK AMScanlon 1/28/85

Are they buying this retail space to operate or as an investment? They are buyingthese rental building in order to resell as condominiums. Who is making theacquisition? We are not sure yet. Perhaps a...

comments: Wayne Kaplan said contingent payments should be estimated according to 801.10 of the rules and included in transaction price. Andy Scanlon agrees and added that they indicate a face value...

The FTC staff has historically said that the acquisition of office buildings is generally exempt (no retail space or other income producing properties included) under § 802.1 of the rules. Is this...

12/6/84 (redacted) 2d letter. Pg1 1. Refers to acquisitions plural – if so newly formed entity rule will not protect 2d etc acquisitions Pg2 2. refers to several sellers – if they are outside. Pg3 3...

See diagram. We examine the 802.20 & 802.50 by issuer. Accordingly, thesetransactions are exempt given the information provided. [Note: No Facts, dollar values given, but enough info (less than $15 mm...

But must consolidate unconsolidated cos [indecipherable]. A [indecipherable].

Comments in body of letter only (See below)

See attached note re [indecipherable] of advice transmitted by telephone to(redacted) on 11/30. [Indecipherable] and by W.E.K. on 11/26/84. The fact thatB is making loans and guarantees to the newly...

11/6/84 Called [indecipherable] - He is not available. told his secy that we do notrespond by mail but that I agree with the statements in this letter & confirm his understanding AMS 11/6/84

I concur. called (redacted) and left message with his secretary.