Investment Research Associates - Page 133




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         C.   Payments to Holding Co. and Its Subsidiaries                             
              After Ballard and Lisle left Prudential, Lisle began working             
         for Travelers.  Schaffel paid IRA $213,750, 50 percent of the                 
         fees he earned from the first Travelers' financing approved by                
         Lisle.  After the first payment, Schaffel failed to pay Kanter on             
         succeeding projects financed by Travelers.  After discussions                 
         with Lisle, Schaffel agreed to make payments to Kanter, but under             
         a different arrangement.  Kanter directed Schaffel to make the                
         payments to Holding Co.  Schaffel paid Holding Co. $600,000 in                
         1984, $1,160,000 in 1985, and $1,003,500 in 1986 for transactions             
         with Travelers.                                                               
              Frey and Essex made the following payments to Holding Co.,               
         during the years 1981 through 1989:                                           
                   Year        Frey          Essex           Total                     
                   1981       $80,616        –-             $80,616                    
                   1982       --        $70,538             70,538                     
                   1983       16,200         64,125         80,325                     
                   1984       113,827     109,013          222,840                     
                   1985       256,557        98,325         354,882                    
                   1986       --             65,835         65,835                     
                   1987       33,570         98,753         132,323                    
                   1988       --             96,188         96,188                     
                   1989        --        42,332            42,332                      
                   Total      500,770     645,099      1,145,879                       
              The following diagram shows the money paid to IRA and                    
         Holding Co. by Schaffel for the Travelers financing transactions,             
         and by Essex and Frey to Holding Co. and Zion:                                










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