v0820-545

No. 2273

IN THE

United States Circuit Court of Appeals

For the Ninth Circuit

Paul I. Welles, and John Daniel, Trustee

of Metropolis Construction Company (a

corporation), Bankrupt,

Appellants,

vs.

Portuguese-American Bank of San Fran-

cisco (a corporation),

Appellee.

APPELLEE'S REPLY TO NEW MATTER AND ERRONEOUS

STATEMENTS IN APPELLANTS' REPLY BRIEF.

(Divisions refer to those of Appellants' Reply Brief.)

ERRONEOUS STATEMENTS UNDER DIVISION I.

Under the title "Off the Record", appellants'

counsel in their reply brief accuse counsel for ap-

pellee of a sophisticated attempt to prevent the con-

sideration of a legal argument.

Counsel for appellants admit the use of the follow-

ing language, quoted by us from page 16 of the

brief of Mr. Welles (who was the sole complainant

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