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9/2/99 Proposal in 9/1/99 letter discussed by MB, MV and RBS. Agreed to make repurchase of C by A non-reportable since we had already reviewed As purchase of B (which included C)and D's proposed...

SEE STAFF COMMENTS to Letter dated 9/2/99 (File #9909003)

9/1/99 - Left phone mail for writer advising that the Premerger Office (MV also reviewed earlier letter) agreed with his conclusions except for last paragraph on page 3. In that paragraph, control of...

I agree that other than the miscellaneous equipment, all of these assets are exemptunder 802.2(d).