          -47-

decisions, including awards of construction contracts, financing

transactions, development projects, and related business.

Ballard, Transcr. at 215; Strum, Transcr. at 511, 521-522; Knab,

Transcr. at 606-609.

       E.   Kanter-Related Entities

       1.   Investment Research Associates, Ltd. (IRA) (STJ report
            at 15-17)

       IRA was incorporated as a subchapter C corporation in the

State of Delaware on August 26, 1974, originally under the name

Cedilla Co.    In the annual franchise tax report for IRA filed

with the State of Delaware, dated March 1, 1979, the name of

Cedilla Co. was changed to InvestmentIRA and

Weisgal was vice president.27    From 1980 to 1989, the president

of IRA was Lawrence Freeman (Freeman), an attorney in Miami,

Florida, and a friend and business associate of Kanter.     Although

Freeman was not paid for serving as IRA’s president, Freeman and

his law firm received significant legal business by referrals

from Kanter.     Although Freeman was IRA’s president and director

for most of the 1980s, he characterized his role as primarily

that of a bookkeeper/accountant and administrator.     Freeman,

Transcr. at 1819.

     In 1989, Kanter became IRA’s acting president.      Until 1989,

Kanter had never been an officer or employee of IRA.     Exhs. 4,




     27
  