Edward Clasby and C.T. Garrahan Insurance Agency, Inc. - Page 6




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          Player to Murray in the spring of 1982.                                     
               Andrew Fantasia (Fantasia) was the certified public                    
          accountant for the FUH plan.  In 1982, on the basis of                      
          conversations between petitioner and Murray, Fantasia promoted              
          the program to FUH.  In the summer of 1982, petitioner asked                
          Fantasia to do preliminary tax research regarding the program.              
               3.   The July 15, 1982, Presentation to FUH                            
               On July 15, 1982, Murray, Player, and Fantasia presented to            
          the FUH pension committee a proposal to invest FUH plan assets in           
          the program.  Petitioner did not attend the July 15 presentation            
          because he wanted to avoid the appearance of a conflict of                  
          interest.  However, petitioner frequently met with Murray and               
          Player at petitioner's offices to discuss the July 15                       
          presentation.                                                               
               Petitioner helped to prepare a document describing the                 
          program dated July 15, 1982, which was given to FUH at the July             
          15 presentation.  The document contained information that was               
          discussed in the meetings with petitioner, Murray, and Player.              
          Petitioner did not discuss the document with any representative             
          of FUH.                                                                     
               After the July 15, 1982, presentation, Player and petitioner           
          had many meetings at the Garrahan Agency to discuss the program.            
          Murray attended some of these meetings.  Player used the Garrahan           
          Agency's letterhead in correspondence sent to FUH about the                 
          program.  Petitioner did not tell Walckner or Talbot that he met            
          with Murray and Player before and after the July 15 presentation.           

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