UNITED STATES OF AMERICA
Before the
SECURITIES AND EXCHANGE COMMISSION

   SECURITIES EXCHANGE ACT OF 1934
   Release No. 42047 / October 21, 1999

   ACCOUNTING AND AUDITING ENFORCEMENT
   Release No. 1196 / October 21, 1999

   ADMINISTRATIVE PROCEEDING
   File No. 3-10085
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  In the Matter of      ORDER INSTITUTING PUBLIC
                        PROCEEDINGS AND OPINION
 STEPHEN J.KESH, CPA,   AND ORDER PURSUANT TO RULE
                        102(e) OF THE COMMISSION'S
     Respondent         RULES OF PRACTICE

______________________


   I.

   The Securities and Exchange Commission ("Commission") deems it
   appropriate and in the public interest that public administrative
   proceedings be, and hereby are, instituted against Stephen J. Kesh
   ("Kesh"), a certified public accountant, pursuant to Rule 102(e)(3) of
   the Commission's Rule of Practice.

   II.

   In anticipation of the institution of these public administrative
   proceedings, Kesh has submitted an Offer of Settlement which the
   Commission has determined to accept. Solely for the purposes of these
   proceedings and any other proceedings brought by or on behalf of the
   Commission or in which the Commission is a party, and without
   admitting or denying the findings, except that he admits to the
   Commission's finding that a Final Judgment of Permanent Injunction
   ("Final Judgment") has been entered against him as set forth in
   Section III.C., and admits the jurisdiction of the Commission over him
   and over the subject matter of this proceeding, Kesh consents to the
   entry of this Order Instituting Public Proceedings and Opinion and
   Order Pursuant to Rule 102(e) of the Commission's Rules of Practice
   ("Order").