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Manor Land Development Company, % Byron L. Stubbs, 1414 Walker
Bank Building, Salt Lake City, Utah.


Swe of Section 10 and the Nwe of Section 15, T2N, RIOE, SLB & M,
Summit County, Utah, according to plat recorded in Summit County
Recorder's Office, entry No. 102696.

Approximately 18 miles North of Mirror Lake on Highway 150 and
29 miles South of Evanston, Wyoming. Said property is situated
on the East side of the Bear River in Summit County, State of Utah.



According to Special Warranty Deed, Book M2, Pages 69-75 recorded
on July ?, 1965 in the office of the County Recorder, Summit
County, State of Utah, said title is vested in the Western States
Title Company as trustee for William W. St. Clair, James McCollister,
Wilbur C. Donaläson, Yukus Inouye and F. Leor Griffiths. Buyer
should understand my liens, if any, encumbrances, reservations,
defects, etc. as setforth in said title report.


Ample soring and surface waters are available which have been appropriated for irrigation by the previous owners of the land. These waters have been approved for use by the Utah State Health Department. An escrow agreement wherein the developers intend to escrow a percentage of the sales to insure a full, complete water development is on file.


Sales will be through title policy written by Western States Title Company and upon full payment for said property, a special warranty deed will be issued to the buyer.


No proposal made. Check with the State Board of Health Department for requirements on use of septic tanks, etc.


Bridger Valley Electric Company has indicated that electricity will be available in the area and it is speculated to be in use in June 1966. As to cost, purchaser should check with company.


Roads are of two types--main roads and collector roads. Main roads will be graded and covered with two layers of mid free materials and will have a width of twenty feet with a right of way of fifty feet. The collector streets will be graded and will be sixteen feet wide with a right of way of thirty feet and covered with one layer of mud free material. These requirements are in accord with the specifications as outlined by the Summit County Planning Commission and the Summit County Board of Commissioners.


Schools, shopping and civic facilities are available at Evanston, Wyoming, 29 miles away. This report is not an approval or disapproval of said subdivision. It is merely compiled from information in the files for the benefit of the buyer. This department recommends that buyer make his own inspection of said property before purchasing in orier to know what he is getting.


Buyer should be aware of restrictive covenants covering this subdivision which are recorded in the Summit County Recorder's office, State of Utah.





Miami, Fla., August 13, 1966. Senator HARRISON A. WILLIAMS, New Senate Office Building, Washington, D.C.:

Your telegram of 8/2/66 received. To answer questions propounded therein would take considerable time so that it could not possibly be available for hearing tomorrow. We feel information requested could best be given by oral testimony of Leonard Rosen upon his return from Europe. Advise what dates available for his appearance.


Vice President.


Miami, Fla., August 15, 1966. Senator HARRISON A. WILLIAMS, Senate Office Building, Washington, D.C.:

Either Leonard Rosen, chairman of the board of Gulf American Land Corporation, or its representative will be present for hearing on Thursday, August 25, 1966. Request time for testifying be set at 2 p.m. or later on that date. Please confirm.


Vice President.

MIAMI, FLA., August 17, 1966. Senator HARRISON A. WILLIAMS, Senate Office Building, Washington, D.C.:

As result my absence of over one month, airline problems, urgent business matters requiring my attention, impossible for me and members of my staff to be present for hearing on Aug. 18. Written statement was mailed to you yesterday for record (see below). Any written request for additional information desired will be promptly furnished.



Miami, Fla., August 16, 1966. Senator HARRISON A. WILLIAMS, Senate Office Building, Washington, D.C.

DEAR SENATOR WILLIAMS: I welcome your invitation to furnish to you and members of your committee any pertinent information relative to Gulf American Land Corporation and its operation and hope that any information so furnished will be of assistance to your committee in making a determination as to the need for Federal legislation in the land installment sales field.

First, let me state that Gulf American Land Corporation is not opposed to Federal legislation regulating its activities. We do however feel that the bill as presently presented is not adequate and will not do the job or accomplish the desired results. It is my opinion that if Federal legislation is to be enacted, it should completely usurp the various State regulatory bodies and take complete jurisdiction of all interstate land sales including jurisdiction of salesmen, advertising, and financial responsibility of all companies engaged in interstate land sales.

There is nothing secretive about Gulf American Land Corporation or any of its operation. Gulf is probably one of the most regulated companies in the United States today. From the time that we first submit our pla for recording with the various county agencies, they tell us the form in which they must be submitted, the way in which they must be submitted, the amount and type of bonds which must be posted, and any other type of information that they think relevant to the particular filing. This information is then filed with the Florida Installment Land Sales Board, which constantly reviews our entire operation, the type of offering being made, and the manner in which sales are being handled. Being a public-owned company, Gulf is directly regulated by the Securities Exchange Commission in all aspects of its dealings.

In your telegram of August 2nd, you asked specific questions relative to our operation. For purposes of clarification, I set forth below the questions which you asked and my answers thereto.

Question 1: Many buyers of Gulf American property apparently anticipate great increases in value and almost automatic resale of land when desired. What are your instructions to salesmen on these matters?

Answer: The prelude to the question is an assumption not based on fact. Our instructions to salesmen are that we believe history has shown that as an area grows and develops and the population of a particular area increases, the price of the adjacent land will rise. We have instructed our salesmen to make this perfectly clear to the purchaser and that they should anticipate having to hold the property for a minimum of five years before the opportunity of resale at increased value would occur.

Question 2: What is the current resale situation in connection with land far removed from the developed areas of Cape Coral and Golden Gate Estates? What is the difference in sales prices between lots close to developed areas and those far distant?

Answer: The resale of undeveloped property far removed from the developed area is not as great as that in the developed area. This is true in any development until such time as the area around this property is developed and people move in. The return on the investment of undeveloped property if sold prior to development would not be as great. When new areas are opened for sale the selling price is lower. As the development of the property approaches the undeveloped area, the prices of the latter will become more or less equal with the former.

Question 3: How many prospective buyers actually set foot on the land they buy?

Answer: There are very few prospective buyers, other than purchasers of developed sites and houses, who actually set foot on the land that they buy. However, they are told at the time of purchase that their land is undeveloped at the present time.

Question 4: What is the relationship between Gulf American and the Travel Guild of America ?

Answer: Gulf American has entered into an agreement with Travel Guild of America whereby Gulf Sponsors, and Travel Guild attempts to sell to its members, tours to Gulf's properties.

Question 5: Many of the Gulf American sales apparently are begun in other states by salesmen who have not necessarily seen the property. What methods are employed to keep such salesmen objective and informed?

Answer: Through various programs we attempt to have as many as possible of our salesmen make personal visits to our project in order that they may acquire product knowledge. In addition to this, we constantly hold sales meetings where discussions of our products are had, progress reports given, and other data furnished in order that they may keep themselves informed as to the status of our various properties.

Question 6: Under what terms are prospective buyers brought to Florida by Gulf American planes for tours of Cape Coral and Golden Gate Estates?

Answer: There are no terms other than the payment which the prospect has paid for the tour. This charge covers only our actual cost of ground services. They are clearly told prior to buying the tour that it is being sponsored by Gulf and that they are under no obligation to buy once they reach the property.

Question 7: What portion of Gulf American income is devoted to promotional activity? What portion is devoted to sales promotion by telephone?

Answer: During the past fiscal year, approximately 1/5 of our income was spent on advertising. We do not have any way of determining what portion of this figure would have been utilized in sales promotion by telephone.

Question 8: Some buyers seem confused about the amount of interest due on outstanding payments. What is Gulf American's policy?

Answer: We are not aware that any confusion exists. All of our contracts clearly state in bold type on the face: “Time payment contracts are subject to a 6% per annum charge on the unpaid balance only. Monthly payments amortize principal and interest".

The remainder of the questions contained in your telegram of August 2nd related to the recent series of articles in the Miami Herald. I do not feel that it is proper to ask me to reply in detail to the various statements made in these articles. We believe that any reporter, when writing an article for a newspaper, does the best job possible within the limits of his ability. We all recognize the freedom of the press in America. As I am sure you are aware, there are those newspapers in the United States that abuse this freedom with the purpose of creating sensational headlines and thereby increasing the volume of their sales. It is possible that the Miami Herald series would fall within this category.

As an illustration, I call to your attention the quote allegedly made by the Collier County Assessor as set forth in your question 9(f). I attach hereto and by reference make a part hereof the sworn affidavit of the Collier County Tax Assessor, Sam Colding, which you will note categorically denies having made this statement. We submit that this is typical of the misstatements and exaggerations contained in the articles.

You have previously asked for an explanation of our report showing $440,000.00 in forfeited income.

First, let me point out to you that Gulf American Land Corporation and all of its subsidiaries are reported on a consolidated basis. A substantial portion of the $440,000.00 income accrued to Gulf from many sources other than land contracts. Under SEC regulations, we cannot report a sale until we have received the equivalent of a down payment plus two monthly payments. During this same period of time, we made actual cash refunds of $1,589,890.00. Our rate of forfeiture amounted to slightly less than 30 of 1% of our total sales. This did not cover the actual cost of commissions paid on these sales, nor other costs involved. We attempt to contact all of our purchasers direct as soon as possible after they have signed a contract to determine if they clearly understand all of the terms and conditions and whether or not they are financially able to make the payments. If these conditions are not met a refund in full is made. We have found from experience that we save money by never putting these people on our books.

Quite obviously, in an organization as large as Gulf American Land Corporation, it is impossible for me to have all of the answers to technical questions and I must rely upon various persons in my organization to furnish me with this information. I have just returned to my office after more than a month's absence and find myself completely swamped. This, coupled with the complexities of the airline situation, makes it impossible for me and members of my organization to be present for your hearing on August 18.

I, therefore, request that this statement be read into the Minutes of your meeting and that you will feel free to call upon me for any additional written information that you feel is necessary and pertinent to the information you seek. We are most desirous of assisting you in any way possible. Yours very truly,


Chairman of the Board. P.S.-I am enclosing herewith for your information two copies of an Economic Survey made, showing the opact of our business in Lee and Collier Counties in the State of Florida (a copy of this material can be found in the committee files).

County of Collier:

Before me, an officer duly authorized to administer oaths and take acknowledgments, personally appeared Samuel Colding, Tax Assessor in and for Collier County, Florida, who, being first duly sworn, deposes and sayeth:

1. The Affiant is Tax Assessor for Collier County, Florida, and has held said constitutional office since August, 1960, through date hereof.

2. That an article appeared in the Miami Herald on January 22, 1966, written by Herald staff writer, Juanita Green, who quoted the Affiant as saying the following.

“The Collier County Assessor sits with pad and pencil and adds up the acreage being sold of Golden Gate Estates and a number of lots into which, according to Gulf American's sales pitch, it could be divided. He comes up with two and one half million sites, figures three people to a home. That is room for seven and one half million people." "Like many others in Collier, Colding asks :"

“How long will it take to build up populated pressure that will scatter through Golden Gate Estates more people than now live in all of Florida." 3. The Affiant, Samuel Colding, hereby states under oath that the above and foregoing quotation by Juanita Green was not made by Samuel Colding, Tax Assessor for Collier County, Florida. Further the affiant sayeth not.

SAMUEL COLDING. Sworn to and subscribed before me this 11 day of August, 1966.

HELEN M. MILLER, My Commission Expires Aug. 4, 1969.

Notary Public.

(Additional correspondence between chairman and Mr. Rosen begins on p. 488.) ITEM 2-OTHER CORRESPONDENCE


Cape Coral, Fla., August 22, 1966. Scratc Builling, Washington, D.C.

DEAR SENATOR WILLIAMS: Having read reports that your committee is charged to investigate land sales in our nation and will no doubt focus on Florida and Gulf American Land Corporation, I write this letter to give my experience of five and a half years in Cape Coral, Florida.

First, I do not wish to intimate that we are a community without problems. We have problems normal to any community. Obviously, where there are people there will be problems. My experience has been that GALC has done all within reason and within their power to make adjustments in “people problems” when they were directly concerned. I have known instances where they have gone beyond "second mile” of their responsibility.

Secondly, your committee will focus attention on the retirees of our nation, As a pastor I go into many homes of retirees in Cape Coral. A recent survey of our congregation revealed 50% of our people are of this group. I believe this figure to be representative of Cape Coral also. The easiest thing for me to say is, “Come to any group meeting at Christ Lutheran Church and I'll show you some satisfied people.” Often they tell me they are satisfied because they know GALC made good promises and made their promises good. Many of us feel that a retiree in Cape Coral gains many advantages not ordinarily in regular community experience.

Thirdly, I believe the dealings with the churches and synagogue in Cape Coral to be superb. GALC makes no “hand outs” to us—suits me because then we are not obligated. But they have given every reasonable co-operation that has made it possible for eight good congregations to organize and flourish. I would establish a mission in any GALC development any day.

I hope your committee will recognize these as few of the many reasons why Cape Coral has succeeded under the development of Gulf American Land Corporation. Very sincerely yours,



Cape Coral, Fla., August 23, 1966. Hon. HARRISON WILLIAMS, Jr., U.S. Senate, Washington, D.O.

SIR: I am writing to you as a spiritual leader and as a citizen of Cape Coral, Florida.

Cape Coral, developed by the Gulf American Land Corporation has been my home for nearly two years.

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