Epic Associates 84-III, William C. Griffith, Jr. - Page 15




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             subsidiaries "was both the seller and purchaser".                        
             Respondent argues that the outside appraisers were not                   
             independent because EPIC "influenced their appraisals with               
             guidelines and requests that precluded the use of bulk sale              
             methods in purchases of multiple units."  According to                   
             respondent, "EPIC, through CAG, influenced the inflated                  
             appraisals related to the properties and determined the                  
             stated purchase price."                                                  
                  Respondent also argues that the participation of                    
             secondary lenders and mortgage insurers does not establish               
             that the value of the properties approximated the debt                   
             because there is no evidence that they engaged in due                    
             diligence.  According to respondent:  "the lack of due                   
             diligence by secondary lenders and mortgage insurers                     
             demonstrates that [the] lenders ignored or did not                       
             understand the realities of the EPIC transactions."  At                  
             the same time, respondent notes the fact that some mortgage              
             insurers refused to insure "newly-created debt on EPIC                   
             properties."                                                             
                  The following is a list of the 51 properties purchased              
             by EA 83-XII (viz 12 single-family residences and 39                     
             condominium units) together with the amount of each loan,                
             the value of each property as determined by respondent's                 








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