Countryside Limited Partnership, CLP Holdings, Inc., Tax Matters Partner - Page 9




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          percent general partner, and Mr. Wollinger became an 83.3-percent           
          limited partner in Countryside.                                             
               On or about January 26, 2001, Countryside and Stone Ends               
          Apartments L.L.C. (Stone Ends) executed a purchase and sale                 
          agreement for Countryside’s sale to Stone Ends of the Manchester            
          property.  That agreement was the culmination of negotiations               
          between Countryside and Stone Ends that began with an unsolicited           
          inquiry, in May or June 2000, from a representative of Stone                
          Ends.  The sale of the Manchester property closed on or about               
          April 19, 2001, and, on that date or soon thereafter, Countryside           
          repaid to CB&T the $8.55 million loan plus accrued interest.                
               The AIG notes were redeemed from MP by AIG on or about April           
          30, 2003.                                                                   
               CB&T’s $3.4 million loan to MP was repaid in full on or                
          about January 5, 2004.                                                      
          Respondent’s Motion To Compel Production of Documents                       
               Respondent has moved the Court to compel petitioner (CLP               
          Holdings, Inc.) to produce certain documents (the motion to                 
          compel production) as follows:                                              
                    1.  Provide all explanatory or promotional                        
               materials related to the proposed and/or actual                        
               transactions including but not limited to:                             
                         (a) educational, instructional, and                          
                    informational material;                                           
                         (b) schematics, diagrams, and charts;                        
                         (c) economic, financial, and tax analyses;                   
                         (d) documents discussing potential risks                     
                    and/or benefits associated with the proposed                      






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