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Does Intermediary get beneficial ownership at any time? No Intermediary is not acquiring anything. The acquisition by purchaser (a REIT) is exempt under 802.1 or C-1. Talked to (redacted) 9/22/95

9/19 - Called writer, confirmed above

Called (redacted) 9/18/95 - Transaction 1 - Appears to be reportable (if size-thresholds are met for the size-of person test). It is the purchase of $25mm worth of assets. It goes beyond letter #139...

confirmed on Sept. 14, 1995 (by phone)

9/13/95 - Writer confirmed that not-for-profit would make purchase before its next regularly prepared balance sheet was issued and then the cash provided to make the acquisition would not be included...