Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 53

                                                -139-                                                   
            a large hotel through Kanter’s efforts.  Eulich, Transcr. at                                
            1647-1648.                                                                                  
                  Kanter and Eulich were aware Connolly would need assistance                           
            organizing a hotel management company for the Gateway Hilton.                               
            Ballard was also aware of Connolly’s needs, and he introduced                               
            Eulich to Connolly as someone who would assist Connolly with the                            
            support services he needed to properly manage the Gateway Hilton.                           
            Connolly, Transcr. at 2620-2621, 2631.  Ballard believed Connolly                           
            also met with Kanter.  Ballard, Transcr. at 184.  As discussed                              
            below, Eulich (probably with Kanter’s assistance) organized                                 
            Gateway Hotel Management Co. (GHM) for Connolly.68                                          
                  In 1981, Eulich and Kanter organized a corporation called                             
            Essex Hotel Management Co. (Essex Corp.).  Formby, Transcr. at                              
            1502-1503; Eulich, Transcr. at 1650; Clifford, Transcr. at 1669-                            
            1670.  By letter dated October 16, 1981, Eulich informed Connolly                           
            that (1) GHM had been organized, (2) GHM was capitalized with                               
            $10,000, and (3) Connolly would be expected to pay $2,000 to                                
            Eulich from GHM’s first distribution to cover his share (20                                 


                  68  The STJ report, at 55, included a recommended finding of                          
            fact that Mr. Connolly, nevertheless, proceeded to organize a                              
            hotel management company and incorporated Gateway Hotel                                     
            Management Corp. (GHM) some time in 1981.”  This recommended                                
            finding of fact is manifestly unreasonable.  As discussed in the                            
            Court’s additional findings of fact in the text that follows,                               
            John Connolly did not organize a hotel management company, and he                           
            was largely ignorant of the existence and function of the various                           
            business entities with which he was associated.                                             



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