Theodore A. Andros and Joan B. Andros - Page 6

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          Illingworth’s goal was to build Manhattan Metals into a commission          
          merchant that would compete with Merrill Lynch.                             
               Initially, Manhattan Metals brokered relatively small                  
          transactions in metals, including copper. Manhattan Metals then             
          expanded its operations to include trading in the futures markets,          
          primarily in copper, gold, and silver.                                      
               By 1980, Manhattan Metals had seven employees, including two           
          traders--Mr. Illingworth and Herbert Weiss.  Mr. Weiss was the main         
          trader for Manhattan Metals.  He was authorized to make trades              
          without discussing them with Mr. Illingworth.  One of Mr. Weiss’            
          responsibilities was to evaluate the prices that were being paid by         
          Manhattan Metals for option spreads.                                        
               Mr. Illingworth held seats on the New York Mercantile Exchange         
          and the New York Futures Exchange. Mr. Weiss was a member of the            
          Commodities Exchange, Inc. (COMEX).  Manhattan Metals was not a             
          member of any exchange.                                                     
               In addition to Manhattan Metals, Mr. Illingworth was a partner         
          in several partnerships that were involved in option spreads and            
          commodities trading activities.                                             
          Petitioner’s Investigation of Mr. Illingworth                               
               In considering the possibility of entering into an investment          
          relationship with Mr. Illingworth, petitioner engaged attorneys at          

               2(...continued)                                                        
          then wife and a third-party investor.                                       





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