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Exchange Commission (SEC), provided tax services, and performed
certified audits on a monthly and annual basis. Bach & Co.
performed accounting services for approximately 50 brokerage
houses during Bach's tenure and employed five accountants at its
peak. Over the course of his career, Bach reviewed a large
number of prospectuses and offering circulars that were filed
with the SEC, as well as private placements that had been
suggested to clients.
Like petitioner, Bach learned of the Plastics Recycling
transactions and Plymouth in 1981 from Bramnick. Bond Richmond
was a longstanding client of Bach & Co., and Bramnick was Bach's
primary contact at Bond Richmond. On occasion, Bramnick
forwarded private placement memoranda to Bach, "just to look at".
In this instance, Bramnick sent Bach the Plymouth offering
memorandum and asked him what he thought about it. Bach reviewed
the offering memorandum for approximately 3 hours. He found the
economic projections "very lucrative", to the investor, even if
reduced "by 50-percent". Bach then met with Bramnick and told
him that he thought the situation was interesting and that it
warranted further investigation. He also received a phone call
from petitioner asking for his thoughts about Plymouth.
Next, Bach contacted Peter Gardino (Gardino), a broker who
had traded for one of Bach & Co.'s former accounts. During 1981
Gardino was working in the syndicate department of a brokerage
house. Gardino reviewed the Plymouth offering memorandum and
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