ASSURED MANAGEMENT, INC.
                QUALITY INVESTMENTS PROPERTY MANAGEMENT
                        434 S. EUCLID STREET
                ANAHEIM, CALIFORNIA 92802-1247
                        [714] 520-9432 EXT:214/215
                          FAX [714] 520-0620

March 17, 1992

Office on the American with
Disabilities Act
Civil Rights Division
U.S. Dept. of Justice
P.O. Box 66118
Washington, D.C. 20035-6118

Dear Sir:

We contacted Benny Howard (415) 556-4592 who indicated that "All
public accommodations have to be wheel chair accessible but not
the apartments themselves, but possibly the rental office." He
indicated this was a gray area and not quite sure "whether rental
offices are considered public accommodations."

Are rental offices in an apartment project public accommodations?

In addition, certain apartments which we manage were constructed
about 10-20 years ago and it may be physically impossible to run
a ramp up elevated areas which involve landscaping and parking.
It is the case that, at the time of construction, the City
required a certain percentage of site to remain landscaping and
parking. Is there any "grandfathering" of older buildings?

Thank you.
                                Most sincerely,

                                Edward B. Frankel, M.D.

EBF:1dm

cc: Property Managers
c:office