Investment Research Associates - Page 241




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          relationships with the Pritzkers, Ballard, and Lisle, to assist             
          individuals and/or entities in obtaining business opportunities             
          or in raising capital for business ventures.  Kanter established            
          a complex organization of corporations, partnerships, and trusts            
          to receive, distribute, and disguise the payments from these                
          arrangements.                                                               
               Some of these arrangements involved payments from a group of           
          individuals referred to by the parties as "the Five".  The Five             
          made payments for Ballard's and Lisle's influence in awarding               
          contracts with Prudential (the Prudential transactions), for                
          Lisle's influence in awarding contracts with Travelers (the                 
          Travelers transactions), and for Kanter's influence in                      
          transactions that did not involve Prudential or Travelers (the              
          Kanter transactions).  The payments most often were made to                 
          corporations controlled by Kanter and then distributed through              
          various means to Kanter, Ballard, and/or Lisle, their family                
          members, or to entities established for the benefit of their                
          families.                                                                   
               Most of the payments made in the Prudential transactions               
          were paid through IRA or one of its subsidiaries.  Those made in            
          the Travelers and Kanter transactions generally were made through           
          another corporation controlled by Kanter, The Holding Co.                   
          (Holding Co.) or one of its subsidiaries.  Funds received by IRA            
          and its subsidiaries and Holding Co. and its subsidiaries, as               






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