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                                                                      EXHIBIT 13

   INDEPENDENT ACCOUNTANTS' REPORT


   To the Board of Directors and Shareholders of
   Anthony & Sylvan Pools Corporation and Subsidiary
   Mayfield Village, Ohio


   We have reviewed the accompanying condensed consolidated balance sheet of
   Anthony & Sylvan Pools Corporation and Subsidiary (the "Company") as of
   September 30, 1999, and the related condensed consolidated statements of
   operations for the three-month and nine-month periods ended September 30,
   1999 and 1998, and it's cash flows for the nine-month periods ended September
   30, 1999 and 1998. These financial statements are the responsibility of the
   Company's management.

   We conducted our reviews in accordance with standards established by the
   American Institute of Certified Public Accountants. A review of interim
   financial information consists principally of applying analytical procedures
   to financial data and making inquiries of persons responsible for financial
   and accounting matters. It is substantially less in scope than an audit
   conducted in accordance with generally accepted auditing standards, the
   objective of which is the expression of an opinion regarding the financial
   statements taken as a whole. Accordingly, we do not express such an opinion.

   Based on our reviews, we are not aware of any material modifications that
   should be made to such condensed consolidated financial statements for them
   to be in conformity with generally accepted accounting principles.

   We have previously audited, in accordance with generally accepted auditing
   standards, the balance sheet of the Company as of December 31, 1998, and the
   related statements of operations, shareholders' equity, and cash flows for
   the year then ended (not presented herein) and in our report dated February
   19, 1999, we expressed an unqualified opinion on those financial statements.
   In our opinion, the information set forth in the accompanying condensed
   consolidated balance sheet as of December 31, 1998 is fairly stated, in all
   material respects, in relation to the balance sheet from which it has been
   derived.


   DELOITTE & TOUCHE LLP

   Cleveland, Ohio
   November 11, 1999





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