Exhibit 99





Commercial Property Corporation
9005 Cobble Canyon Lane
Sandy, Utah 84093

Interwest Transfer Co., Inc.
1981 East Murray-Holladay Rd.
Salt Lake City, Utah 84117

Re:       Registration Agreement respecting certain shares of
          common stock of Commercial Property Corporation, a
          Delaware corporation (the "Company"), and related
          instructions to Interwest Transfer Co., Inc. ("TA")

Dear Ladies and Gentlemen:

          In furtherance of compliance with the Securities Act of 1933, as
amended (the "Securities Act"), the General Rules and Regulations promulgated
thereunder by the United States Securities and Exchange Commission (the
"Commission") and the letter dated January 20, 2000, of Richard K. Wulff, who
was the Chief of the Commission's Office of Small Business, that was addressed
to Ken Worm, the Assistant Director of the OTC Compliance Unit of NASD (the
"Wulff letter"), the undersigned person agrees as follows:

          (1)  That the following stock certificate and the shares of
               common stock of the Company represented thereby shall not be
               publicly sold unless and until:  (i) there is a Registration
               Statement filed with the Commission covering this stock
               certificate and the shares of common stock represented
               thereby, which has become effective; or (ii) the Commission
               provides a "no action" letter which indicates that
               registration prior to resale of this stock certificate and
               the shares of common stock represented thereby is not
               required under Section 5 of the Securities Act as there is
               an available exemption for the resale of these securities by
               the undersigned; or (iii) there is a finding by a United
               States District Court having original jurisdiction or a
               state court having concurrent jurisdiction regarding the
               Securities Act, to the effect that this stock certificate
               and the shares of common stock represented thereby can be
               resold by the undersigned or successors without registration
               under the Securities Act.

          (2)  The undersigned person agrees and does hereby advise the
               Company and TA that they are hereby authorized to place a
               restriction on the stock certificate referred herein below
               on its presentation, reflecting the terms and conditions of
               this Registration Agreement, and that the Company and TA
               shall make appropriate notations in the transfer records
               maintained for and on behalf of the Company to the effect
               that the following stock certificate has "stop transfer"
               instructions until one of the foregoing conditions has been
               met.

          (3)  The undersigned shall promptly courier to TA the following
               stock certificate for the imprinting of an appropriate
               legend reflecting this Registration Agreement.  The stock
               certificate subject to this Registration  Agreement is as
               follows:

                                         Stock            Number of
Name and Address                        Certificate No.     Shares

Chiricahua Company*                       1004              820,000
9005 Cobble Canyon Lane
Sandy, Utah 84093

          *  David C. Merrell is the sole owner of Chiricahua Company and is
deemed to be the beneficial owner of these shares.

                              CHIRICAHUA COMPANY


Date: 11/01/04                    By/s/David C. Merrell
                                    David C. Merrell