 The Hyatt Embarcadero Hotel had been developed and

was owned by a joint venture in which Prudential was a

participant.    The commission payments, respondent contends,

constituted part of the kickback scheme.

     (2) Bruce J. Frey, D.M. Interstate, the B.J.F. Development

Co. Partnership, and BJF, Inc.    Bruce J. Frey was the principal

in each of these latter entities.       Mr. Frey, through these

entities, managed apartments, office buildings, and commercial
                                -69-

properties.   He and these entities were also heavily involved in

a number of condominium conversion projects invarious cities

around the country, in many of which Prudential held interests.

Mr. Frey and his related entities shared certain fees with Kanter

and his related entities, which respondent also contends

constituted part of the kickback scheme.

     (3) William D. Schaffel.   Mr. Schaffel was a mortgage broker

and real estate developer.    Mr. Schaffel also assisted a New

Jersey general contracting company to obtain certain construction

contracts.    From 1979 through 1986, he had extensive business

dealings on behalf of individuals he represented with Prudential

and Travelers.   Mr. Schaffel shared with Kanter and his related

entities brokerage and development fees, which respondent claimed

was part of the kickback scheme.

     (4) Property Management Systems, Inc. (PMS).   The chairman

and chief executive officer of