Investment Research Associates - Page 581




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          Seven months after the initial meeting with Ballard, Prudential             
          bought the building.  Schaffel received a fee from brokering the            
          sale of the building and paid half of the fee to IRA.                       
               Some of the projects Schaffel assisted Torcivia in obtaining           
          with Prudential included the Parsippany Business Campus, the                
          Parsippany Hilton Hotel (located outside of Newark, New Jersey),            
          the Gateway (located in Newark, New Jersey), and the Interplex              
          Complex (located in Princeton, New Jersey).                                 
               Walters agreed to pay Schaffel a finder's fee with respect             
          to two joint ventures that Walters helped negotiate with                    
          Prudential.  Schaffel entered into separate written agreements              
          dated October 19, 1981, with Cherry Creek Place Associates II               
          (Prudential funding of $15.6 million) and Aurora Plaza &                    
          Conference Center, Ltd. (Prudential funding of $17 million), with           
          respect to the joint ventures.  In each agreement, the                      
          partnership acknowledged that Prudential's participation in the             
          venture was primarily the result of Schaffel's efforts and that             
          Schaffel was entitled to be compensated.                                    
               From 1979 through 1983, pursuant to his arrangement with               
          Kanter, Schaffel shared with IRA fees from these business deals             
          with Prudential.  Schaffel paid the following amounts from                  
          Prudential transactions to IRA from 1979 through 1983:                      










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