-70-                                                   
            Kanter and his related entities, which respondent claimed was                               
            part of the kickback scheme.40                                                              
                  (5) Essex Hotel Management Co. (Essex Partnership).  The                              
            Essex Partnership had the following partners holding the                                    
            partnership interests indicated:                                                            
                                                             Percentage                                 
                  Partner                                    partnership interest                       
                  IRA                                        26.125                                     
                  THC                                        21.375                                     
                  Motor Hotel Management Co.(MHM)            47.500                                     
                  John Connolly                              5.000                                      
            John Eulich was the majority shareholder of Motor Hotel                                     
            Management Co. (MHM), a corporation, that was engaged in the                                
            hotel management business.  John Connolly’s hotel management                                
            company managed two hotels that were owned by Prudential.  The                              
            partnership agreement for the Essex Partnership is dated January                            
            l, 1982.  One of the Essex Partnership’s purposes was to provide                            
            consulting and liaison services to some of its partners in                                  
            connection with their management of certain hotels.  A                                      
            substantial portion of the management fees earned by John                                   
            Connolly and MHM was paid to the Essex Partnership, which                                   
            respondent contends was a part of the kickback scheme.                                      
                  40  There is no evidence that any PMS fees were shared with                           
            Kanter and his related entities.                                                            
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