 Prudential was not involved in either the Lakewood or the

535 North Michigan Avenue conversion projects.   Frey, Transcr. at

663-677.

     The first condominium conversion project that Frey undertook

involving Prudential was in connection with a 1,000 unit

townhouse apartment complex called Village of Kings Creek at

Miami, Florida.   In late 1979 or early 1980, Frey approached a

Prudential real estate department executive working in

Prudential’s Miami, Florida, regional office about purchasing the

Village of Kings Creek apartment complex.   The apartment complex

was owned by a pension fund managed by Prudential.   Frey offered

to purchase the apartment complex for a cash price of about $20
                     to a limited partnership Frey organized to

undertake conversion of the property to condominiums.      Zeus and

Zion participated as limited partners in this partnership,

contributing $100,000 and $108,014, respectively, to the Village

of Kings Creek partnership.     Exh. 5800.   Kanter also brought in

another investor, First Illinois Enterprises, that made a

substantial investment in the project.       Wold, Transcr. at 2854.

        During the Village of Kings Creek conversion process,

Ballard visited the property “to see what was going on down

there”, and he met Wold.     Ballard, Transcr. at 178.   During this
                 