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10/21-Called and advised (redacted) that it is a Premerger Office position (and not that of the Commission) regarding filing or non-filings for apartment bldgs.

[note 1-Attachment A-]

9/27 checked with Wayne. At his suggestion checked CA cites. Advised (redacted) that Redevelopment Agency does not appear to be a corporation and thus not an entity.

This transaction appears reportable if the size requirements are met

None noted

The writer was advised that the transaction involving the (redacted) might qualify as exempt under 802.63 as well as possibly 802.1 if the sale were to a person which does not compete in the same...

I informed the writer that the burden is on the acquiring person to determine the fair market value of the assets being acquired separately from each of the 12 persons and the unallocated value of the...

OK - Limited to the facts. 8/5/88

OK-8/4/88-Limited to the facts.

I concur with this letter - also reviewed by (redacted) - Attempted to call three times noanswer last call 8-18-88

Talked to (redacted) 8/18 confirmed that these were both asset transactions; advised that if fair market value or, if higher, the acquisition price, is $15MM or less for assets of each entity, then...

None noted