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To: Sarab J. Jihad who wrote (4834)9/12/1998 1:57:00 AM
From: Icabod  Read Replies (1) | Respond to of 26163
 
September 2, 1998

Securities and Exchange Commission
Washington, D.C. 20549

RE: United States Of America vs. WellRich & Company

Attention: xxxxxxxxx xxxxxxxx
Division of Enforcement

RE: WellRich & Company

Dear xxxxxxxx:

As always it was indeed a great pleasure speaking with you today. Please find the
requested information, I hope this will help you with your action.

1.xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

2.xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

3. WellRich is not a licensed broker/dealer, but may be functioning as such in violation
of Section 15(a)(1) of the Securities Exchange Act of 1934 (the "Exchange Act"). See
Polannin, John, Jr., "Finder's Exception From Federal Broker-Dealer Registration,"
CATHOLIC UNIVERSITY LAW REVIEW, Vol. 40, summer 1991, Number 4.

4. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

5. WellRich has not or does not have the ability to indemnify any company, In the event
that the company is sued as a result of Wellrichs's actions.
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx WellRich does not
have adequate financial resources to compensate any company in the event of a
judgment.

6. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

7. WellRich receives compensation predicated upon a percentage of the sales price of
the stock that they SOLICIT to people over the phone.xx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx. This establishes that WellRich is
functioning as a broker/dealer. See SIDNEY MARKS, SEC No-Action Letter, 1977
No-Act LEXIS 2057 (July 7, 1977); JOHN DIMENO, SEC No-Action Letter, 1978
No-Action. LEXIS 2188 (Oct. 11, 1978); and RICHARD S. APPEL, SEC
No-Action Letter, 1983 No-Act. LEXIS 2035 (Jan. 13, 1983).

8. All of the issues raised by this letter is enough to indite and convict WellRich of all
charges. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx.

Yours Truly,

xxxxxxxxxx xxxxxxxx ESQ.
Attorney and Counselor At Law
xxxxxx xxxx xxxxxxx
Washington, D.C. xxxxx

cc: State of California Securites And Exchange Commission
State of Califirnia Office Of The Attorney General, Telemarketing Division.

EFS:rab

GOOD LUCK YOU ARE GOING TO NEED IT.



To: Sarab J. Jihad who wrote (4834)9/12/1998 10:18:00 AM
From: bmart  Respond to of 26163
 
Mr. Jihad,
You never answered my questions. What was your relationship with Mr. Schurer? Was Mr. Schurer an employee of Wellrich? Was he acting as a broker/dealer? Did he performs transactions for AZNT stock through Wellrich? Did AZNT provide you with a 'lead list'? Who is rightfully due the $50K commission on stock sold through Wellrich? Was Mr. Schurer an employee of Wellrich when the transaction(s) took place? If not, then Wellrich could not legally perform such transactions, could they? Will you post the "judgement" from the "arbitration hearing" that Ms. Shell & Mr. Mitchell posted they were "procuring & scanning".

TIA

RB