Exhibit D
TRUST AGREEMENT
This Agreement is made this 17th day of March, 2000 (the "Agreement"),
between and among Larch, LLC, having an address at 000 Xxxxx Xxxxxxx Xxxx, Xx.
Xxxxx, Xxx Xxxx 00000 ("Larch"), Cyprus, LLC, having an address at 000 Xxxxx
Xxxxxxx Xxxx, Xx. Xxxxx, Xxx Xxxx 00000 ("Cyprus") (together, the "Applicants"),
and Xxxxxxxxx Xxxxxx X. Xxxxxxxx, having an office at 1300 Mt. Xxxxxx Avenue,
P.O. Box 2075, Morristown, New Jersey 07962-2075 (the "Trustee").
RECITALS
1. GREATE BAY HOTEL & CASINO INC. ("GBH&C"), trading as THE SANDS
CASINO HOTEL, is a corporation organized under the laws of the State of New
Jersey and is the holder of a plenary casino license under the New Jersey Casino
Control Act, N.J.S.A. 5:12-1 to -190 (the "Act").
2. GB Property Funding Corp., a Delaware corporation ("GBPF") and GBH&C
are wholly-owned subsidiaries of GB Holdings, Inc., a Delaware corporation ("GB
Holdings") (GB Holdings together with its subsidiaries and any successors or
assigns of any thereof are referred to collectively herein as "GB Group").
3. GBH&C owns the Sands Hotel and Casino located in Atlantic City, New
Jersey (the "Casino").
4. GBPF was organized during September 1993 as a special purpose
subsidiary of GB Holdings for the purpose of borrowing funds through the
issuance of bonds, which were unconditionally guaranteed by GBH&C and GB
Holdings.
5. Larch and Cyprus are the owners of certain Guaranteed First Mortgage
Notes of GBPF (hereinafter "GBPF Bonds" as further defined hereafter).
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On January 5, 1998, GB Holdings, GBPF and GBH&C each filed a petition
for relief under Chapter 11 of the United States Bankruptcy Code in the United
States Bankruptcy Court for the District of New Jersey (the "Court"). On June 1,
1999, GB Holdings, GBPF and GBH&C filed with the Court a plan of reorganization
and disclosure statement which provides for, among other things, the
distribution to holders of GBPF Bonds of $80 million, principal amount of new
First Mortgage Notes and one hundred (100) percent of the new Common Stock of GB
Holdings. The plan requires confirmation by the Court and approval by the New
Jersey Casino Control Casino Commission (the "Casino Commission"). 6. Cyprus and
Larch desire to obtain certain licenses that will permit them to own, operate
and manage the Casino, upon their possible attainment of a potential controlling
interest in GBH&C. 7. The Applicants will be required to qualify under the Act
as holding and/or intermediary companies of GB, a New Jersey casino licensee.
8. The interim casino authorization provisions of the Act, N.J.S.A. 5:12-95.12
through 95.16 inclusive ("ICA") require that every application for qualification
under the ICA be accompanied by a fully executed and approved trust agreement
meeting the requirements of the ICA.
9. The Applicants have determined that it is in their best interests to submit a
trust agreement that complies with the requirements of the ICA as a required
part of their application for interim authorization and qualification pursuant
to the ICA.
10. The Applicants and the Trustee recognize in general and without limitation
that the following are the purposes of an ICA Trust Agreement:
a. to designate a person qualified to casino key licensure standards,
except for residency and casino experience, to hold all property owned by the
Applicant related to GB,
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including that currently owned by the Applicant and any hereafter acquired by
the Applicant, by any means;
b. to ensure after an occurrence of an "ICA Event," as that term is
hereinafter defined, that a Trustee, who has been qualified by the New Jersey
Casino Control Commission (the "Commission"), shall exercise all rights
attendant to the property that is the subject of this Trust, and that the
Trustee shall act independently of the Applicant;
c. to ensure after the occurrence of an ICA Event that (i) the
Applicant shall have no right to participate in the earnings of the Trust
Property or receive any return on its investment, and (ii) the Applicant
realizes nothing above the "Actual Cost" of the "Trust Property," as those terms
are defined by this Agreement, until such time the Applicant is found qualified
by the Commission or as may be otherwise permitted by the Commission in
accordance with the Act and this Agreement;
d. to establish mechanisms for the expeditious disposition of the Trust
Property that is the subject of this Trust in the event that the Applicant is
found unqualified by the Commission; and
e. to interpret the Agreement to carry out all of the policies of the
Act, including the ICA, and the regulations promulgated under the Act.
11. The Trustee satisfies the qualification criteria applicable to him under the
ICA.
12. The Trustee has indicated that he is willing and able to serve as the
Applicant's Trustee pursuant to a trust agreement that meets the requirements
of the ICA.
NOW, THEREFORE, IN CONSIDERATION OF THE FOREGOING PREMISES AND MUTUAL
AGREEMENTS AND COVENANTS HEREINAFTER CONTAINED, THE PARTIES AGREE AS FOLLOWS:
1. Definitions.
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a. "Actual Cost" shall mean the cost of all debt securities or
securities into which they may be converted, reduced by any return obtained by
the Applicant on the Trust Property, regardless of whether such return is in the
form of dividends, interest, or any other payment, including proceeds of any
partial or total sale of Trust Property permitted by this Agreement, and
regardless of whether any such return occurred before or after the execution of
this Agreement.
b. "ICA Event". An ICA Event shall be deemed to have occurred on:
1. A denial of interim authorization of the Applicant by the
Commission under the ICA; or
2. A finding by the Commission, after interim authorization has
been granted to the Applicants by the Commission, that reasonable cause exists
to believe that the Applicants or any individual required to be qualified in
connection with the qualification of the Applicants may be found unqualified and
a stay of the effect of either one or both of these findings is not granted by
either the Commission or a court of competent jurisdiction.
c. "Trust Property" shall mean all of the Applicants' present and
future right, title, and interest in the Guaranteed First Mortgage Notes of GBPF
("GBPF Bonds"), bearing interest at 10 7/8% per annum, due and payable January
15, 2004, and all Proceeds thereof.
d. "Proceeds" shall mean any and all cash, property, securities, rights
or other proceeds which the holder of GBPF Bonds receives in respect thereof or
in exchange therefor, whether or not in connection with the reorganization at GB
Group under Chapter 11 of the United States Bankruptcy Code and/or in connection
with any recapitalization of GB Group.
2. Transfer Of Trust Property. On the execution of this Agreement, the
Applicants shall transfer all of their present and future right, title and
interest in the Trust Property to the
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Trustee, subject to the terms and conditions and for the use and purposes of
this Agreement. The Applicants give to the Trustee, now and hereafter, all
powers necessary to carry out his duties and responsibilities under this
Agreement. Subject to the provisions of the Act and this Agreement, the
Applicants shall be the beneficiaries of the Trust.
3. Trustee's Acceptance Of The Trust. The Trustee accepts the Trust
Property and agrees to hold the Trust Property, subject to the terms and
conditions of this Agreement.
4. Fiduciary Duty Of Trustee.
a. Pre-ICA Event. Except as otherwise provided herein, prior
to the occurrence of an ICA Event, the Trustee shall be required to follow the
Applicants' instructions regarding the holding and management of the Trust
Property pursuant to the terms of this Agreement.
b. Post-ICA Event. After the occurrence of an ICA Event, the
Trustee shall exercise his rights and powers and use the same degree of care and
skill in their exercise as a prudent man would exercise or use under the
circumstances in the conduct of his own affairs.
5. Duties Of The Trustee. Upon execution of this Agreement, the Trustee
shall have the duty (a) to provide the issuer of the Trust Property with an
executed copy of this Agreement, (b) to take all necessary steps to have all of
the Applicants' interest in the Trust Property transferred to his name, (c) to
have that transfer duly recorded on the register and records of the issuer, and
(d) to ascertain any payments with respect to the Trust Property that have been
made to the Applicants prior to the execution of this Agreement. The parties
recognize and agree that the purpose of this Agreement is to allow the
Applicants to comply with the ICA, and to that end some of the duties and
responsibilities of the Trustee under this Agreement relating to the control and
management of the Trust Property may change from
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time to time, as provided in this Agreement, to ensure the Applicants' continued
compliance with the requirements of the ICA.
6. Duties of the Applicant. The Applicants shall notify the Trustee
immediately on the occurrence of an ICA Event.
7. Applicants' Right To Instruct Trustee Regarding Management Of Trust
Property. Except as otherwise provided in this Agreement and prior to the
occurrence of an ICA Event, the Trustee shall be subject to and fully comply
with the instructions of the Applicants as the Applicants' agent for the holding
and management of the Trust Property. Unless and until an ICA Event occurs, and
subject to the terms of this Agreement, the Trustee shall follow all of the
Applicants' instructions regarding the holding and management of the Trust
Property, and the Applicants shall have all of the rights afforded them by the
Trust Property including, by way of illustration and not limitation, the right
to sell or distribute all or any part of the Trust Property and to vote any
securities that are part of the Trust Property, subject to the requirements of
the ICA. Prior to the occurrence of an ICA Event, the Trustee may distribute any
funds received in connection with the Trust Property to the Applicants, or to
any third party, subject to the terms of Section 19 of this Agreement; provided
that, unless the Trust Agreement is terminated in accordance with Section 23 of
this Agreement, the Trustee shall not distribute any amount that exceeds the
Actual Cost of the Trust Property without the approval of the Commission.
All instructions from the Applicants to the Trustee shall be in
writing, with a copy of the instructions to be furnished to the Commission and
the Division.
8. Qualification Of Trustee.
a. The Trustee warrants and represents that he meets all
of the criteria necessary to qualify as a casino key employee, except for
residency and casino experience,
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under the Act and that he shall continue to meet such criteria throughout the
duration of this Agreement.
b. The Trustee agrees that if he commits an act or
becomes aware of any information that would cause a reasonable person to
believe that he will ultimately not be able to meet the qualification
criteria required of a casino key employee under the Act, he will notify the
Applicants, the Commission, and the Division within two (2) business days of
becoming aware of such information, in a writing that sets forth the details of
his action or knowledge. The Trustee further agrees that if he becomes aware of
any information that would cause a reasonable person to believe that the
Applicants have violated or will violate the terms of the Act or this
Agreement, he will immediately notify the Commission and the Division.
9. Removal Of Trustee. The Applicants shall have the right to petition the
Commission on an emergent basis to remove the Trustee immediately from his
position as Trustee under this Agreement, for cause, and to replace him with a
qualified Successor Trustee, as that term is defined in this Agreement.
10. Resignation Of Trustee. The Trustee shall have the right to resign as
Trustee under this Agreement on ten (10) days' notice to both the Applicants and
the Commission; provided, however, that the resignation by the Trustee shall not
be effective unless and until a Successor Trustee has been appointed, installed,
and approved by the Commission.
11. Successor Trustee. The Applicants may at any time propose a Successor
Trustee, subject to the approval of the Commission. If no such Successor Trustee
is proposed within five (5) business days of the death, disability,
disqualification, resignation, or removal of the Trustee pursuant to this
Agreement, the Commission shall be empowered to appoint as Successor Trustee any
qualified person. The Successor Trustee shall promptly execute and deliver to
the Applicants and the Commission a copy of this Trust Agreement.
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On the death, disability, disqualification, resignation, or removal of the
Trustee pursuant to this Agreement, the Trust Property shall be transferred to
the Successor Trustee, and he shall hold the Trust Property subject to the terms
of this Agreement.
12. Liability Of Trustee. The Trustee shall incur no responsibility to the
Applicants, as holder of Trust Property, Trustee, or otherwise, except in
instances in which an action or omission constitutes gross negligence or willful
misconduct. The Trustee shall serve without bond .
13. Records. The Trustee agrees to keep records of all of his business and
transactions as Trustee. These records shall include a detailed listing of the
time spent by the Trustee in attending to trust business and the expenses
incurred in connection with such business. The Trustee shall send the Applicants
a monthly statement that lists every transaction made by the Trustee and the
time spent and expenses incurred by him in completing each transaction in the
month previous to the date of the statement.
The Trustee agrees to make his records available to the Division and
Commission. The Applicants expressly consent to the Trustee allowing the
Division and Commission to view the Trustee's records of his transactions and
business as Trustee.
14. Compensation Of Trustee. On approval by the Commission, the Applicants
shall pay the Trustee the sum of $25,000.00 on the execution of this Agreement,
and the sum of $25,000.00 on the termination of this Agreement; provided,
however, that the Trustee shall forfeit this final payment if the Commission
directs his removal for cause, which shall include the following by way of
illustration and not limitation:
a. Disqualification under the Act;
b. Mental incapacity;
c. Prior to the occurrence of an ICA Event,
continued neglect, after notice from the Applicants, of any of his duties
and responsibilities under this Agreement; and
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d. Breach of his fiduciary duty as set forth in this
Agreement. On approval by the Commission, the Applicants shall pay the
Trustee $350.00 per hour for all time spent reasonably by the Trustee in
administering the trust business and the Applicants shall reimburse the Trustee
for all reasonable expenses incurred in fulfilling his duties under this
Agreement, including the retention of any necessary financial and/or legal
advisors. Expenses incurred by the Trustee in remaining qualified under the
Act shall be deemed to be reasonable expenses incurred in his fulfilling
duties under this Agreement.
15. Indemnification Of Trustee. The Applicants agree to indemnify and hold
harmless the Trustee to the fullest extent permitted by law from and against all
taxes (other than taxes based on income), suits, actions, claims, losses,
damages, expenses (including reasonable legal fees), penalties, assessments,
liabilities, or other charges incurred by or assessed against the Trustee
arising out of any action or omission in connection with the performance of his
duties under this Agreement, except in instances in which an action or omission
constitutes gross negligence or willful misconduct. The rights of the Trustee
under this Section 15 shall survive the termination of this Agreement regardless
of whether any taxes (other than taxes based on income), suits, actions, claims,
losses, damages, expenses, penalties, assessments, liabilities, or other charges
are incurred or assessed prior or subsequent to the termination of this
Agreement.
16. Trustee Control Over The Trust Property. If an ICA Event occurs, the
Trustee shall exercise all rights incident to the ownership of the Trust
Property, and shall be vested with all powers, authority, and duties necessary
to the unencumbered exercise of such rights, as provided in N.J.S.A. 5:12-130.1
through 130.11, inclusive, and the Applicants shall have no right to receive any
return on its investment in excess of its Actual Cost after an ICA Event has
occurred. Except as otherwise provided herein, there shall be no communication 9
between the Applicants and the Trustee after an ICA Event occurs, unless prior
approval has been received from the Commission for such communications to take
place. The Trustee agrees to adhere to the provisions of this Agreement and,
among other things, the following guidelines in exercising his powers under this
Section 16 following the occurrence of an ICA Event:
a. Investment Of Funds. The Trustee agrees to place any funds
received on account of the Trust Property in bonds or other obligations,
maturing in not more than 180 days, that as to principal and interest constitute
direct obligations of, or are unconditionally guaranteed by, the United States
of America;
b. Voting Rights. The Trustee shall have the unencumbered right
to vote any securities that are part of the Trust Property; and
c. Notification. The Trustee agrees to notify the Division and
Commission in writing of any action he takes pursuant to subsections (a) and (b)
of this Section 16 within two (2) business days of his having taken such action.
The Trustee shall report to the Division and Commission any attempt by the
Applicants to influence or exercise control over his actions following the
occurrence of an ICA Event.
17. Applicants' Discretion Regarding Trust. If an ICA Event shall not have
then occurred, the Applicants shall have the right, in their sole discretion, to
declare that the Trustee shall have the rights and powers over the Trust
Property contained in Section 16 of this Agreement. The Applicants shall
exercise their right to have the Trustee assume the powers over the Trust
Property contained in Section 16 by sending a written notice to the Trustee
requesting that he assume such a role. If the Applicants make such a request,
the Trustee agrees to notify the Division and Commission of the Applicants'
request and of his assumption of the powers over the Trust Property contained in
Section 16.
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18. Restoration Of Applicant Control. If the Trustee has assumed the powers
over the Trust Property contained in Section 16 because of an election made by
the Applicants under Section 17, the Applicants shall have the right to resume
control over the Trust Property consistent with Sections 3(a) and 6 by sending
the Trustee, the Commission, and the Division notice of their intent to do so
five (5) business days before it resumes control.
19. Applicants' Right To Petition The Commission To Direct The Trustee To
Sell The Trust Property Prior To A Determination Regarding Qualification. After
the occurrence of an ICA Event and prior to a determination by the Commission of
the Applicants' qualification under the Act, the Applicants shall have the right
to petition the Commission to direct the Trustee to dispose of the Trust
Property, or any part thereof, in accordance with the terms of the ICA. After a
sale or other transfer pursuant to this Section 19 of this Agreement, the
Applicants may petition the Commission to direct the Trustee to distribute any
consideration received for the sold or transferred Trust Property, up to but not
exceeding the Actual Cost of the Trust Property to the Applicant. The Applicants
may similarly petition the Commission to direct the Trustee to distribute any
earnings or return received by the Trustee in connection with the Trust Property
prior to the occurrence of an ICA Event, up to but not exceeding the Actual Cost
of the Trust Property unless approval of the Commission is obtained or the Trust
Agreement is terminated in accordance with Section 23 of the Agreement.
20. Trustee's Duties On A Finding That The Applicants Are Qualified. After
a determination by the Commission that the Applicants are qualified, the Trustee
shall, not later than the business day next following being informed of the
determination, transfer the Trust Property to the Applicants or an assignee to
which their rights under this Agreement are assigned pursuant to Section 25 of
this Agreement.
21. Trustee's Duties On Applicants' Disqualification. If the Commission
denies qualification to the Applicants, the Trustee shall endeavor and be
authorized to sell, assign,
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convey, or otherwise dispose of all property subject to the Trust to such
person(s) as shall be appropriately licensed or qualified or shall obtain
interim casino authorization in accordance with the Act. The disposition of
Trust Property by the Trustee shall be completed within 120 days of the denial
of qualification, or within such additional time as the Commission may for good
cause allow, and shall be conducted in accordance with the provisions of
N.J.S.A. 5:12-130.1 through -130.11, inclusive, except that the proceeds of such
disposition shall be distributed to the Applicants only in an amount not
exceeding the Actual Cost of the Trust Property, and any excess remaining
proceeds shall be paid to the Casino Revenue Fund, as defined by N.J.S.A.
5:12-145.
22. Rights of the Trustee. The Trustee shall have no duties or
responsibilities except those expressly set forth herein. The Trustee may rely
on any notice, instruction, certificate, statement, request, consent,
confirmation, agreement, or other instrument that is authorized or permitted by
this Agreement and that he believes to be genuine and to have been signed or
presented by a proper person or persons. As a condition to the taking,
suffering, or omitting of any action by him hereunder, the Trustee may consult
with counsel, and the written advice of such counsel or any Opinion of Counsel
shall be full and complete authorization and protection in respect of any action
taken, suffered, or omitted by him hereunder in good faith and in reliance
thereon.
23. Termination Of Agreement. This Agreement and the trust that it creates
shall terminate automatically on the transfer of the Trust Property and any
funds acquired in connection therewith to the Applicants following the
qualification of the Applicants under the Act, or on approval by the Commission
of an application to terminate the Agreement.
24. Benefits of Agreement. Nothing in this Agreement, expressed or implied,
shall give to any person, other than the parties hereto and their successors
hereunder and the
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Commission and Division, any benefit or any legal or equitable right, remedy, or
claim under this Agreement.
25. Assignability. The Applicants shall have the right to assign their
rights under this Agreement, but only with the prior approval of the Commission.
26. Amendment; Waiver. This Agreement may not be amended, modified, or
supplemented, nor may any provisions of this Agreement be waived, discharged, or
revoked, without the prior written consent of the Applicants and the Trustee. No
amendment, modification, or supplement to this Agreement shall be effective
without the prior approval of the Commission after notice to the Commission and
Division of any proposed amendment, modification, or supplement.
27. Headings. The various headings of the Sections of this Agreement are
for reference purposes only and shall in no way affect the meaning or
interpretation of this Agreement.
28. Invalidity. The invalidity of any provision of this Agreement shall not
be deemed to impair or affect in any manner the validity or enforceability of
the remainder of this Agreement.
29. Notices. Any notice or other communication required to be given under
this Agreement shall be given by telephone, telex, facsimile, or other similar
means of electronic communication and by a writing sent by Federal Express or
any equivalent overnight delivery service. Notice shall be deemed to be given on
transmission or on its being delivered to Federal Express or any other
acceptable overnight delivery service. The numbers and addresses for providing
notice under this Agreement shall be those contained in Exhibit A to this
Agreement. The numbers and addresses used for providing notice under this
Agreement may be changed by giving notice pursuant to this Section 29 of this
Agreement.
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30. Counterparts. This Agreement may be executed in counterparts, each of
which when executed and delivered shall be an original and both of which
together will constitute the same Agreement.
31. Variations In Pronouns. All pronouns and any variations thereof refer
to the masculine, feminine, or neuter, singular or plural, as the identity of
the person or persons may require.
32 Waivers. No delay on the part of any party in exercising any right,
power, or privilege hereunder shall operate as a waiver thereof, nor shall any
waiver on the part of any party of any right, power, or privilege hereunder, nor
any single or partial exercise of any right, power, or privilege hereunder
preclude any other or further exercise thereof or the exercise of any other
right, power, or privilege hereunder. The rights and remedies provided herein
are cumulative and are not exclusive of any rights or remedies that any party
may otherwise have at law or in equity.
33. Governing Law. The parties agree that this Agreement shall be governed
and construed in accordance with the laws of the State of New Jersey, including
the Casino Control Act, N.J.S.A. 5:12-1 to -190, and the regulations promulgated
thereunder, and nothing herein shall be construed to limit the rights of the
Commission or Division to take any action required or permitted by law.
34. Effective Date Of Trust. The Trust instituted by this Agreement shall
become effective on the execution of this Agreement by the parties and final
approval of the Agreement by the Commission and delivery of all necessary
documents and Trust Property in accordance with the terms of this Agreement.
35. Exhibits. The following Exhibits are attached to this Agreement and are
made an integral part hereof. A. Addresses and Telephone Numbers for Notice.
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IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be
executed and delivered as of the date first above written.
LARCH, LLC
By:
Xxxx X. Icahn, President
CYPRUS, LLC
By:
Xxxx X. Icahn, President
TRUSTEE
Xxxxxxxxx Xxxxxx X. Xxxxxxxx
[Trust Agreement - Greate Bay Hotel & Casino, Inc.]
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Exhibit A - Notice
Trustee Xxxxxxxxx Xxxxxx X. Xxxxxxxx
XxXxxxx, Xxxxxx & Xxxxxxxx
1300 Mt. Xxxxxx Avenue
P.O. Box 2075
Morristown, NJ 07962-2075
Applicant Xxxx X. Icahn
000 Xxxxx Xxxxxx, 00xx Xxxxx
Xxx Xxxx, XX 00000
Telephone: (000)000-0000
Telecopier: (000)000-0000
With a copy to:
Xxxxxx & Xxxxxxxx, A Professional Corporation
00 Xxxx Xxxxx Xxxxxx
X.X. Xxx 0000
Xxxxxxx, XX 00000-0000
Telephone: (000)000-0000
Telecopier: (000)000-0000
Attention: Xxxx X. X'Xxxx, Esquire
and
Berlack, Israels & Xxxxxxxx, LLP
000 Xxxx 00xx Xxxxxx
Xxx Xxxx, XX 00000
Telephone: (000)000-0000
Telecopier: (000)000-0000
Attention: Xxxxxx X. Xxxxxxxxxx, Esquire
Xxxx Xxxxxxx, Esq.
Gordon, Altman, Butowsky
Xxxxxxx, Xxxxxx & Xxxx
000 Xxxx 00xx Xxxxxx
00xx Xx.
Xxx Xxxx, XX 00000-0000
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New Jersey Casino Control Commission
Xxxx X. Xxxxxxxxx, General Counsel
Casino Control Commission
Tennessee Avenue and Xxx Xxxxxxxxx
Xxxxxx Xxxxxxxx
Xxxxxxxx Xxxx, Xxx Xxxxxx 00000
Telephone: (000) 000-0000
Telecopier: (000) 000-0000
Xxxxxxx XxXxxxxxx, Assistant General Counsel
Casino Control Commission
Tennessee Avenue and Xxx Xxxxxxxxx
Xxxxxx Xxxxxxxx
Xxxxxxxx Xxxx, XX 00000
Telephone: (000) 000-0000
Telecopier: (000) 000-0000
New Jersey Division of Gaming Enforcement
Xxxx X. Xxxxxx, Director
Division of Gaming Enforcement
000 Xxxx Xxxxx Xxxxxx
XX-000
Xxxxxxx, Xxx Xxxxxx 00000
Telephone: (000) 000-0000
Telecopier: (000) 000-0000
Xxxxx Xxxxxx XX, Deputy Attorney General
Division of Gaming Enforcement
000 Xxxx Xxxxx Xxxxxx
XX-000
Xxxxxxx, Xxx Xxxxxx 00000
Telephone: (000) 000-0000
Telecopier: (000) 000-0000
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