v1946-201

No. 7965

In the United States Circuit Court of Appeals

For the Ninth Circuit

Security-Fikst Nation.vl Bank of Los Angeles

(a corporation), as Trustee under a Trust Deed

whereby the Debtor conveyed all of its prop-

erty to the said Trustee to secure a bond issue

of $1,820,000, and Pacific States Savings and

Loan Company (a corporation), the owner of

$1,750,000 face value First Mortgage Bonds of

the Debtor, which with $31,000 additional out-

standing bonds and $39,000 reserved for under-

lying liens make up the entire issue,

Appellants,

vs.

EiNDGE Land and Navigation Company (a corpo-

ration). Debtor, Samuel Frankenheimer,

Samuel Frankenheimer, as Trustee, Marble-

head Land Company (a corporation), Kindge

Company, et al.,

Appellees.

Upon Appeals from the District Court of the United States for

the Northern District of California, Southern Division,

in a Proceeding for Corporate Reorganization

Under Section 77B of Bankruptcy Act.

REPLY OF PACIFIC STATES TO DEBTOR'S

COUNTER=STATEMENT OF NEGOTIATIONS ETC.

FILE

PAUL P. O'SftlEN,

Orrick, Palmer & Dahlquist,

Fin,a,nc-ial Center Building, San Firincisco,

Garret W. McEnerney,

Hobart Building, San Francisco,

Al cnir Attorneys for Appellant,

Pacific States Savings & Loan Company.

PHRNAn-WALSH ritlNTINOCO., SAN FUANCItSCO

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