I am today delivering to Mr. Kenneth R. Harkins, Chief Counsel of your Antitrust and Monopoly Subcommittee:

1. Two files relative to the acquisition by
National General Corporation of Educational
Film Productions, Inc.;

2.

a third file containing the following:

(1) State of New York Insurance Department
Report dated April 2, 1969, on Report on
Special Examination of Declaration of
Extraordinary Dividend on January 14,
1969, with covering letter from said
Department dated April 23, 1969;

(2)

statement by Marvin Finell, partner in the
above law firm and member of Board of
Directors of Great American Insurance
Company, before the Antitrust & Monopoly
Subcommittee, Committee on the Judiciary,
United States Senate, March 5, 1969;

(3)

(4)

sundry correspondence relative to
Great American Insurance Company
and the Insurance Departments of

the States of New York and California;
and

1966-1967 Combined Calendar Year Loss
Ratios Great American Compared with

Twelve Companies, 40 National Companies,

and All Companies (Source: Best's Executive Data Service).

The first two files relative to the acquisition of Educational Film Productions, Inc. contain confidential business information, in the opinion of our client, and are delivered to your committee staff counsel with the understanding that the committee will keep them confidential.

K: r

Enclosures

Very sincerely yours,

Ditt. Noche

THOMAS H. KUCHEL

On May 6, Mr. Frederick Jett of your staff requested ocuments and a status report in connection with litigation in he Superior Court of the State of California for the County of os Angeles, entitled Joseph Elsant v. Great American Insurance Company, et al.

The following documents and information are supplied in response to that request:

1. The Summons and Complaint in Case No. 947,254, entitled Joseph Elsant v. Great American Insurance Company, et al., filed in the Superior Court of the State of California for the County of Los Angeles. This was the original action in which Elsant sought to enjoin the issuance of the stock dividend by Great American. The petition for injunction was successfully opposed by our firm and thereafter the plaintiff dismissed this action. Also enclosed for your files, in addition to the Complaint, are the following:

(a) Order to Show Case re Preliminary Injunction and Temporary Restraining Order, Memorandum of Points and Authorities in Support Thereof.

(b) First Memorandum of Points and Authorities and Declaration of Allan Comrie in Opposition to Plaintiff's Application for a Preliminary Injunction.

(c) Supplemental Declaration of Allan Comrie and
Supplemental Memorandum of Points and Authorities in
Opposition to Plaintiff's Application for a Preliminary
Injunction.

(d) Affidavit of Daniel F. Kruger in Opposition to Application for Preliminary Injunction.

2. A second action was filed by the same plaintiff, same attorneys, entitled B. Joseph Elsant v. Great American Insurance Company, et al. (No. 947,860), in the Superior Court of the State of California, for the County of Los Angeles. That Complaint is a shareholder's derivative action for damages on behalf of Great American Insurance Company. It was filed on February 11, 1969, and simply stated, it is contended that the declaration of the divident was improper. A motion to dismiss and a demurrer to the Complaint have been filed. The hearing on these motions is currently scheduled for July 16, 1969. Enclosed are the following documents:

(a) Summons and Complaint (Shareholder's Derivative Action for Damages, for Return of Misappropriated Property and for Declaratory Relief).

(b) Demurrer to Complaint and Memorandum of Points

and Authorities in Support Thereof.

(c) Notice of Motion for Dismissal of Defendants Great American Insurance Company and National General Corporation, and Memorandum of Points and Authorities in Support Thereof.

3.

A third action, bearing Case No. 949, 210, entitled B. Joseph Elsant v. Great American Insurance Company, is a class action on behalf of all minority stockholders of Great American Insurance Company. This seeks damages on behalf of the class

iscussed. In connection with that action we have filed a emurrer and it is scheduled for hearing on July 23, 1969. nclosed are the following documents in connection therewith:

(a)

Damages.

Summons and Stockholder's Class Action for

(b) Demurrer to Complaint and Memorandum of Points and Authorities in Support Thereof.