Lord of War Part2

F0.340 (Rev.
4-286)
Field File No.

Serial
# of Originating Document
00 and File No.

Date Received
1/1~11?
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(Name of Contributor)
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of Criminal Procedure 0 Yes 0 No
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Title:
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Field File No.
Serial # of Originating Document \ - - - - - - -
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Universal Case File Number
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Field Office Acquiring Evidence _ _ _ _ _ _ _ _ _ _ _ _---.:._

Serial# of Originati~q D o c u m e n t - - - - - - - - - - - - - Date Received
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From __________~~~~~~-------------(Name of Contributor)
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Reference: -----...,_-:-=---:-:--;-:----;:=--;--:-----..,-,--.,-.,..--------(Communication Enclosing Material)
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Universal Case File NumberQ?8'/ f/
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FD-340 (Rev. 8-7-97)
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Field Office Acquiring E v i d e n c e - - - - - - - - - - - - - Serial# of Originatinp Dpc~ment

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Receipt Given 0 Yes 0 No
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Field Office Acquiring E v i d e n c e - - - - - - - - - - - - - - Serial# of Originating D o c u m e n t - - - - - - - - - - - - - Date R e c e i v e d - - - - - - - - - - - - - - : - - - - - - - - - From _ _ _ _ _ _ _ _ _~~~~~~---~~----. (Na'rpe of Contributor)
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FED ER..A.L BUREAU 0 F INVEST! GATIO N

FOIPA
DELETED PAGE INFORMATION SHEET
No Duplication Fees are charged for Deleted Page Information Sheet(s).
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FD-340a (Rev. 11-12-89)
!Title)
!File No.)
Date
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Field Office Acquiring E v i d e n c e - - - - - - - - - - - - - Serial# of Originating Document _ _ _ _ _ _ _ _ _ _ _ _ __

Date Received ;;/Jo/99
From----------;:-:---;-:::--:-;;-,---,----------(Name of Contributor)
(City and State)
By _______________-=~~~~==~--------------(Name of Special Agent)
To Be Returned 0 Yes tsl. No

Receipt Given 0 Yes 0 No
0 Yes 0 No
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UNITED STATES DEPARTMENT OF JUSTICE

FEDERAL BUREAU OF INVESTIGATION
Refeipt for Property Received/Returned/Released/Seized
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--
-----.-------------
FD-597 (Rev 8-11-94)
File#
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item(s) listed below were:

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Date Received
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FD-340 (Rev: 8-7-97)

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Date Received
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FD-340 (Rev.S-7-97)
'
Field Office Acquiring E v i d e n c e - - - - - - - - - - - - - - Serial # of Originating D o c u m e n t - - - - - - - - - - - - - Date Received
2--1 )- HI QO
From _______~--------~-~~~~---------(Name of Contributor)

By~
To Be Returned 0 Yes 'EJ...No
Receipt Given 0 Yes '8-No
Grand Jury Material - Disseminate Only Pursuant to Rule 6 (e)
Fe.deral Rules of Criminal Procedure
Title:
b
b
I
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. , '
...:
.1
' I'
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..- ..,-
~....,.
tJ
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FD-340 (Rev. 87-97)
J.<J '
It- h. /f -
l'r'f 1 ~
Al4
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Field Office Acquiring Evidence--------------Serial #of Originating Document-------------Date Received ---"'-f/.,_.,.W~P=()O"'----------------
From ___________-=~~~~~~----------(Name of Contri\)utor)
By
S'f
(City and State)
]' l. Speo~l
of
pf
b6
b7C
Ageot)
To Be Returned 0 Yes
No
Receipt Given D Yes
No
Grand Jury Material - Diseminate Only Pursuant to Rule 6 (e)

0 Yes
No
Title:
t1
Reference: ----,..----;;::--:---~:-:-:-::-:--:=-:o=-:--o-:;-.---:;-;;---------
"" i
. l
; :~
Description:
~Original
notes re interview of
~.______--~~
zza~re/ca..f.U.-!-=b~-
'. :
,.
:
.-;
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:',. .'!
. l.f
: 1
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()~/ I-/-Uf-/7f1s-~- ~bo
_j
Z,.
b7
b7D
(12/31/1995)

ROUTINE
Precedence:
To:
From:
Date:
03/31/1998
Los Angeles
Los Angeles
Drafted By:
I
~----------~fLP
Case ID #:
281H-LA-199755
Approved By:
~======::::;-----'
!:;6
b7C
(Pending)
Title:~~----------------~
ET ALi
OC/DI - Russian/Eurasian Organized Crime
OO:Los Angeles
Synopsis:
Request to open sub file
Details: It is requested that sub file 302 be opened.

i
--
f2oTIJ
d-ol r-\, (A. tcrq
7n S'<Ar?
~'-.
J2 I~ -t.lt- /917- 3oow-S

IH ... _ _ - - -
If ;I
L..,..__
l~::o
_____.
;;
b6
_.-
b7C
b7D
;J& I f-f - J..{l- jlt q 7Z"- 3 oP...-
+-
bE
b7C
b7D
~81H-LA-19~~
SLP/slp
...._
_ _ _ _ __J
~~-----1
I.
bD
b3
r
(12~31/1995)

Precedence:
To:
Date:
ROUTINE
01/30/1997
Los Angeles
From:
Los Angeles
Approved By:
....=====:::::;-----l
Drafted By:
~------------~~LP
case ID #:
281H-LA-199755
(Pending)
~----------------~
b6
b7C
Title:l
ET AL;
OO:Los Angeles
Synopsis:
Request to Change Title
Previous Title:
ET AL;
00: Los Angeles
Details: In cooperation with the Miami office, it is requested
that SARKIS SOGHANALIAN be removed from the title as a subject .
'
1
..' .
---- ..... - . ..
_ _...:..~',~lL:.i ~.
,.
281H-LA-199755
SLP/slp
On 1/6/97,
I(CI) provided the following
informationl........:-t-o-s=A::-....---1---~=tl
~
/, p
~--------~----~~----------------~~
b
b
b D
(09/19/94)
Precedence: ROUTINE
Date:
08/12/1996
To: Los Angeles

From: Los Angeles
CE-4
Contact: sAl
.----~==::::::;-------'r
Approved
By:~~----------------~
Drafted By:~~----------~lslp
Case ID #: 281H-LA-
b6
b/C
(Pending)
~~-------'~
Titl_e:l
ET AL;
00: Los Angeles
Synopsis: Opening Memo
Details:!
b3
The cashier's check was stolen from GREAT WESTERN BANK. Two
checks were stolen at the same tim~- The check was made payable
to a Panamanian company, TIDR, ndwas deposited into a T.I.D.R.
account at SQCIETE GENERAL B
, Paris, France. T.I.D.R is ownea
by SOGHANALIAN. A stop p
en was p ace on-the check by
SOCIETE GENERAL an~d
the heck was returned to SOGHANALIAN.
SOGHANALIAN in order o avoid suspicion, turned the _check over to
the Secret Service t the u.s. Embassy in Paris,. ~ranc~. He ..
cli:limed that the check was given "i:o him <1~ a p~:.:-t....o:.. ~ . . lagi:ti:m,&te.
,)
.28{ 1-;--Uf -{9-? 7_f'_)- (
(09/19/94)
To: Los Angeles From: Los Angeles

281
Re:
H-LA-
'FWBEfiAt ed~~~u OF INVESTIGATION
business deal.
The second stolen c
was made out in the
~------~~~~--------------~----------~GREAT WESTERN BANK

incurred the loss.
It is believed that these checks as well as several

other checks identified are a part of a money laundering scheme
operated
~OGHANALIAN.
It is recommended that this case be opened and

assigned to SAl
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21 ~Duplicate Serial4, PG 11
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Page 84
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MM
196A-1056
~AL-p db
The following truAsHvat-:fan was conducted at .Miami,

Florida, by Special AgentL
On February 13, 1981, Special Agen~~----------~1

ATF, Miami, Flor,ida, was contacted in reference 'to investigation he had previously conducted into: fir:arms transaction involving Sarkis Soghanalian. I _
Jadvised that
his investigation .had concerned the pure ase of a large
number of handguns by a Lebanese nationalr----n--r-~~~.
white male, date of birthl
I
purchased about :70 handguns in January,
, from the
Tamiami Gun Store iq Miami.
subsequently shipped them
out ot tbe country. [ _
_invj;tilation led bim to
Soghanalian based on the fact that
had listed
Soghanalian's address on Hibesus Is an as 'his place of
on certain forms u~ed to purc~as~ the hand~s
nterviewed Soghanal'ian who advised him that
was on y an acquaintance of his and had perhaps staye
at his house for a few days.l
ladyised that he
had also interviewed
a.nf
Ireside;e,
__
was advised that the Federal Bureau

received information thatl
bad accompanied Soghanalian to the Tam~ir.am~i~~
~G-u-n~S~h~0-p~n late 1977 and had provided identification
analian to use :in the pur.chase of some handguns.

stated that he was unaware of this information.
advised that he had information tha
ami ami Gun Shop, I
Iwas engagi;L-n-g----..--.........,. ,. . . ,e. .,.g. .,.a_.
s of handguns .and that it was possible that
ad
not provided the required forms to A F re arding t e
purchase by Soghanalian of handguns.
tated that
he had checked ATF records prior to con uct ng his
investigation 1 and had determined that there was no record
of soghanalian or I
I having purchased any
handguns. Notification ~s required on th~ purchase by
any individual of more than one bandgun at a time.
~.L..~~ZaittJ,rg,..,...a,....,t....,...,o,...,n,.....-4,_ad
bG
b7C

}4M 196!-1056
HAL-pdb
2
IU.S. Atfor.ney's
Istated that
'his :investigation' "is currently in the
Office awaiting,a prosecutive opinion.
hi;
_advised that upon receiying

:rosecut:ve opinion,
he will consider r e i n t e r v i e w i n g L J a n d
that he has no objection to:the Federa : ureau o -Investi_gation (FBI) acco~panying him on that .interview.!
stated that he wi-ll recontact the 'FBI when a'prosL...e~c--u-:::t"7i~v-e_ _...J
opinion is ~eached.
tha
b6
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'
!added by way of information and background

his investigation had develop,dl
I
So hanalian b thename of
I
I ,
..
'
'
I'
1
Date of tr:.Onscrlptlon~-~~---
3/3/81
President, .Air Taxi Service, Inc.,

4471 North~w~e~s~t~3~6~th~s~tLr~e~eLt~, -Suite 222, .Miami, Florida,
Telephone
provided the followin,g information:
II
Iadvised that his busine'ss ,, Air Taxi. Service,

Inc. , spe._c..,l,...a....l..,l....z--e--s--Jin ..the chartering and 'brokering of aircraft.
In connection with his-business, he made.tlieacquain'tance of
Sarkis Soghanalian, approximately two to three years ago'! ,
~-~~~~advised that he actedas.a broker in the

-sale of a North 'American Rockwell Sabreliner, Sabre 40,
Tail #40GP, to Soghanalian ~pproximately e_ight months ago.
The seller of this aircraft was the Robey. smith Company,,
located at ~::1 B;ic~ell .Avenue, Miami, F._1o:rida, Telephone
#374-1515 .
Jstated that during negotiati9ns for
e .a rcraft, he .dealt primar.ily_ withL

I
lnobey.Smith. Soghanalian paid $570,000 for
e a rcra t .. -The:aircraft, when in the,United States,
.is,based at Butler-Aviation, at Miami International Airport.
!stated that this aircraft is a s~~ll passenger
L.. . .,e=x"""e'"""c=u'""t"""l=v:-::!e type aircraft, which. currently :,has a value
greater than the,$570,000 Soghanalian pai,d 'for it.
.,
e. s:Je o: L__
::
I!'
I
, , .
, '
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1n~5t191t1on
on---..,...,....,l"'<rT..,.....---t -"'1T:lr.::;:.r--,7T":~r.r.::-----.;;_-
2/19/81
Uiaml, Florida
.SAl
SA
L-----------~
~.~ .:....---.
..
'
---"
..... . ....
'
'
'[""
; . . . . . . .,_.-
_._]<
-,..
<-.flot'-'
'
.......
~A
BEST AVAILABLE COPY
1:;6
l:;7C
MAR '1
.u!.'
'19~1
,
i \''f
-~--~------------------~~
L __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.J
'
Vl. CZ CHQOe3 7
pp
M~
DE
HQ
z~~t
~037
0831431
uuuuu
b6
P 24 l326Z fiA R 81
b7C
'
FM D.IRECTOR FBI
TO F.BI MIMli PR IORI!Y
AS FOLL.01.'1S:
REBUTEL DATED .MARCH 20', '1981.
LEGAT ,. PAR.IS FORESEES :.JO PROSLEMBS WITH Tf INVESTIGATIVE
TRAVEL oF AUSA
~SIS
OF
U~FORMAT IO:'
Iso r, A
tv'D
SE!
FO~TH
IN RETEL.
MIA~1l
CASE AGE In oN
CONTACT \{ITH FRENCH
Pa. ICE JUDICIAIR.E Pet. ICE NATIONAL E <PJP N> DETERMINED THIS SERVICE
1-hS
rw INFORMATiotJ lJJUCH w~ULD ASSIST THEM 'IN IDENTIFYING

IESCRIBED
o~LY
.AS FRENCtt
sustr~ESSMEtl,
REPORTEDLY W.ILLHm TO BE INTERVIE'AED .IN .THIS MATTER.
'wHO ARE
r~-,
PAGE 'T\~0 DE HQ 003 7 UNCLAS

IDENTIFYING DATA, IF AVAILABLE, TOGETHER WITH CONCREET ADDRESS Atm
tLL TELEPHONE CONTACT POI tiTS SHOULD BE FURNISHED TO PJPN

AS EXPED.IT,IOUSLY AS POSSIBLE SO T,HAT INTERVIE\i ~MY BE ARRANGED.
EI'
0037
'I
'!
NNNN
0831433
M:'1 1 PB
MA~ ~4 1981
b6
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--
r--~....~------- ~.,;~----=-
ANDUEWS &: LUIH3E_HS
f>.O.e_Ol<
$$_~&
2 _601 I:AST OAIILANO f>ARIO; e_OU~I:VARO
IL"'R"X' X.AUD_EDDAX.E, ZO:LORlDA 33310'
~arc_h_
16, _1_9 81_
IE_sq. ,_Limited
Con_su1 tan_t
~B~o~c~a~I~n~v~e~s~tments
-c/o: .K_eepe:r. ' s co-tta-g e_ _l1'_l_imwell, East_ Suss e_x_

Engl_a n4
b6
b7C
Re :- Boca tnves tmen_ts Limited vs.

sark-i s'. G.-- soghana lian,- et al
_Deatc=J
T_his wi_l_l: be a _follow-up to te_lephon_e_ call whi_c_h __I wi_l_1 I> lace
t _o you t_h_is afte_r_noon .
.......,_ _ _ _........~lca_l_l_ed .tbls mqrni_n g to inf-or_m . _t_h_at_ t _h _e y we_r _e going
to' have lett;; rogator: i _ssu_ed conce_r_ning _the i _nterv_iew of both _
theJ
.,__
Jin Paris._ ije_ anticii>ates t_hat_ reali_sti~al_l_)'
_thi_s_ tr_l.l) w_l.__ _ not occur unt_i l somet_ime_ n_e_xt mont_b .
He requ_e_s ts t _h at you cal_~
Iand reconfirm their
wil_l_ingne_ss t~ merely ta_l_~ with the FBI_ an_d_ he wou_ld__l_ik_e you' to
: &~in -f!"Qn} ~h~~ -- ~ .precise .time in which he might te_l~pho.~e gi_t_h~_r:
one or: th.e ot_h _e r -_in the very- n~:a~ Jiit)lre, "pr'ep'ar_a t_o ry _t_o . h~lding
a cqnfe_r _e_n ce_ wi_th th_em.
ha_s re_ite_r -a ted to me__t _h at_ they j._n no way wish t _o i_n~ve_st_igat_e or ca_s t d_ispe_rsions on. I
)but_ me_re_ly wi_sh
tQ di_s cuss a:nd veri_fy wit_h them ce_rt_a _in act_ivip._e s of Sa_r_~_i_s G-.
Sogbana_l_ian as t_twse a:ct_ivit_ies atte_n de_d your t_ransact_i~_'Q wit_h
Mnurctanin :
. Please attempt to contact

land get bac_k to me
the requi_red tnformat:io_n ...._a t _ime _in-- wh_ic_hl
~might convenie_n _
t lt
ca_ll one or tbe oth_e r of them an~terminat_io"Q t _h at t_h_~y are
wi_l_l_ing to vohmtar_il)' talk wit_h L___in Pa_r i_s .
J ,.
Sincerely
yours~:
----
II'.,,:
'
------.--------1~'
L...--1
' . --= =--== = ,__ - - - ---~--- --~- ~ -.--- - --- ..
.DAjp
II
I
-~~
'
MAR
2B.,
'
_:,~"~-
:. j
'"
-J9ttt, ~rnJRc~s;,' t;iKAH~~.
HOST G(}.!Jf:R~MFMT SI!CURIT~ AGtniCY

~
-u. . .,.;s,. f,l$ A

0NF'
.~
rLIBHt
cr Si'IURtE s MEN~: A .r-11\ikli::l~E AHTICLE
<
"", ,<
~'(:
'
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. T~ E D~:c $.,1 , 198? ft H{!H

M' wv: :~ L:UF1 F c,S~ PI]..OT
~------------------~
,,.
'
'
- FC>-302 -(AEV, 3-$-77)
'FEDERAL BUREAU OF INVESTIGATION
.Qat of Jr~n~rl~;>tlon
Marc,h 2 5 c 19 81
Clerk, Delaware Department of State,

Division ~o~f~c~o~r~po~r7
a~t7
e~_Recor~s, provided certified exemplified
copies of Del'aw~re corporate file concerning'Browning Precision
Tool_ company and United -Trade InternationaL
'
..
'
'
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-,
'
''
'
''
Mtlo\Jet(DA-16S~ ~ /0-7
lnv~st~ltlon on,_.....,;:3..:.1..;:1;;.;2;;;.:/;...8.;..:;l:..-_ _ _ at _ _....:::;D~o:.:v;.::e~r;.,..,t-,iD~q.llll~9Y:W~~~-r""'____
e
Filo
B ~ '] 9 6A- 4 3 9
by _ _:S:.~:.q__ _ _ _ _ _ _ _ _ _ _ _J-----------~te c!i<:tt~<I--3.;1,/./..Jl..;9~/,_o8..&]_ _ _ _ _ __

'
''
'Tt>is c:tocu,.,.nt c:on~ln$ t~either rec:omme..d,uons nor ~onc:l<.~sions of ui~ FSI. It Is t~ ~ropertY of the FBI 1n<1 is fOII'Ie<l to vour,genc:v:
It 1n<1 its c:ontents Ire not to 1;>e <list(ibut~d O\ltsi<le yo..tr 19enc:y,
f'
FC>-302 (REV. 3-$-77):

~
'FEDERAL BUREAU OF INVESTIGATION
Oat of transc.rlptlon
3/3 / Sl
lwas interviewed at hi~ plac~

employment, Air Taxi Service, Inc., 447~ Northw,~e~sut~----36+h s+rejt, Suite 222, Miami,. Florida, TeleJ?hone
_and provided the following information:...J
...__
.....
.-------'----.....LS:La..l:!..1.-'l~d th~t he_ works with !-I....,....------!
Air Taxi Service, and i~ primarily
~~~~~~~-=~~~~consultant in the Aviation Field
As fdentification ,_ I
Ifurnishe~ _
~.w..~..........'""'"""""'"".s;;...,~----.._u....e"'d...,~~e t::m!lderal Aviation A:injstration,
lorida. Tlii's Ia:ent1f'1cat on card_
r-".............:..__ _ _ _...____...,___jwas a white male, date of birth
,
inches tall, 173 pounds with black
a r .an
aze eyes. I
!advised_ that he owns a .horJe.
in Key Largo which is located at the. 100- mile-~r~er on_
U.S. 1.
also maintains ali .apartment in tlle Miami
area._
o~
__
L.__ _ _
.----~---.
_I
.... ~
Ifirst
met Sarkis Soghanalian :sometime

uri
1977 whenl
Iwas employed for Southeast Airlines._
stated that he.does not-consider that he has ever
. directly for Soghanalian;- however, h_e-ha~. performed'
a numbel" of services for Soghanalian sine~ 1977-~-j,or~ which
he ha~ been paid. These services include rep.airfLand
modifications. to various aircraft owned or controlled_ by
Soghanalian.
b6
b7C
Sometime dUring the latter part o~ 1977,1

acted as a broker for the purchase by Soghanalian_ o~f..._"""'a=--------l
Boeing 707 aircraft, Tail #NSllUT ._ This aircraft was
purchased by Soghanalian or by a company or business
controlled by Soghanalian fol" ~ total purchase price o~
approximately $190,000. This price included_ certain
modifications that were made to .the aircraft prior--to
delivery. These modifications ent~iled_ converting the
aircraf_t from a_ passenger aircraft to a cargo type aircraft.
For the modification process,!
acted .as a general
Investigation on~-'204lr....l...,9"-~lt..li8"'1.._____ ., Miami, florida
.. ~ " "
I~pdb
File
MM 199A-)056/c:1 ,y
Date ClictatecS-----.!:12'.1./~2~5:J./~8ul._______
This cS~vrnent cO...talns neither recornrnencSatlofts I'IOt' col'lduslons of tr>e FBI. It Is the proc>ertlf of ttle FBI ancS Is ~l'le<l to lfOUl.ttei'ICY:
ancS IU"cOntenu are not too. Clistrlbvteel 011Ui<le your atencv.
.
it
,.
11H_ 196A-1056
.2
contractor ov~rseeing the work performed by vai"ious s ubcont-ractors._

Payment fol' the aircraft and_modifications wa s effected in the
followi_ng manner:Soghanalian would writ~ personal checks tol
corporation, .I .c. s., Inc .for all tlodifications. Uon~ir:e=-:s;::------'
which_were actually applied . to the pur~has~ pric~ of the
ai rcra ,_t were :pa_id . either in the form of personal_ checks to
I
_or cashier's checks whichJ
!disbursed_ to the
seller of the aircraft, IsraeliA1rcraft Industries. During
this period of tir.le, Israeli Aircraft !nd\tstries .was
represented by F Q a n, of Miami Beach, Jilorida, who
is_now deceased. .
was. shown a photostatic copy of
a checl:: drawn on . e account of. Sarkis G. Soghanalian_ at
the Iryin_g Trust Bani~, New Yoi"k Cifv New York. {!364.
dated January lC, 1978, pj~:ble :~~n the ~ount o.f $65,000.
stated that he recalled
this particulal' chec_k and_ at
was used as a deposit
towards the purchase of the above noeing _707_. I
I
further recalled that .be had some diffic~lties in
obtaining tbfs dcposi t from Soghana'!ian ._[
!explained
that to the best of his recollect_ion he received a previous
rom Soghanal_ian. which he had been unable to negotiate._
recalled~hat h& took the check to the SoUtheast
ich :is .located near h-i s of~ice on Northwest 36th
.Street in !.U_an11._ U~ reca_lled being told by the tel_ler
who served him that eithel' .there were insufficient funds
.to cover t h Q
. r tb~ check simply could not be _
. _
negotiated.
advised Soghanalian soently furnished
him_Check #
n t e ar.1ount. of $65 ,'000.
recalled
taking.Check #364 back to the sax:1e branch_ o
ou heast
Banl:, and was able to convel't it .t o a_ cas_hier' s check.
lsubsQdisbursed th~ monef ,to I.si"ael Aircr-a ft
Industries.
further advised that any checks payable
to ICS, Inc. were or r.1odi_fication woi"k. done to th~ ai_r craft :
ICS, Inc., which stands' for Interarnerican
~
vices,
is a Panananian_ Corporation_
solely
forth~ r.lodif.ication WOI"k on
stated that
ICS, Inc. i~ now defunc~ and_a
1e on y worl: ever
conducted; through -ICS, _Inc. was fo~ _ the _tlodification to
this aircraft. I
Istated that he believed that he had
b6
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UM 196A-1056
3
a~
another location_ all_ the records .fo~ ICS, lnc : including

bank: _statements, invoices and othe~ documentation. I
I
.was_ instructed to safeguard the originals of these ilocuments,
which_ b.e agreed to do._. I
!'also stated that he believed_
that he ropproximately $78, ooo in. payment .through_
ICS, .lnc..
advised_ that he realized_. approxir~ately
~-fr 5 00
or his work: in the: sa~e a:nd modification
yo
advised th3:t to tile: .best of_ his knowledge_

l l w a s _subsequent~y .sold bt Soghanal_~an _to_ Brian Hardt,_
'wuu--wm!_ subsequently l::illed in_ a. ca~ ~wreck in Miami._. Upon
'!tardy s d-eath~ it was determined that he. had been. usingthe: alia~ of I
lstated. that it was
suspected that. Hardy had been. involved in some. so~t. of
illicit activity, but. he. had no personal_ knowledge: of what'
this activity was_ compx-ised of: Afte~ Hardy's death,
lbelievec:f that the aircraft was finally taken
L.....,p'""o..,.s'""'s'"""e'"""s.,..sion_ of by Hardyl
further stat~d_ that he :recalled_ that

another aircraft owned_ by Soc:;natian_ ox- bt Soghana.lian S:
wife, .a. Boeing 707, TailL
__ _was: used to fe~ry food
supplies
ua:n, Puerto
co, during the latte~ months
of 1977.was aware of this fact because ot his
employment w t
fCA_ .Leasing, in_ Miami, which le-ased the:
aircraft .from Sogha:nalian. -
h:t-.
~I
!stated that.. in reference to the ownershijl

of_
. he. had once ask-ed_ Soghanalian why he_ did_ .not
own_ the a rcraft outright instead: of in his. wife.' s name.Soghanalian .replied to
he: had. kept_ his name. off '
of the registration. for
because he was. not a_
citize~ of the. United S a es, and at that time. a: non-citizen
could_' not. registe~ a: United. states aircraft.
t::.:t
I
ladviseci that he still_ has periodic contact
with_ Soghanalian_ and_ that he did some work. fo~ Soghanalian
as recently as one month_ ago-: .Soghanalian owns a_ '1966
SaberliP.er which is_ .currentlt based outside the country.
~nstalled_ a:. fuel gauge_ fo~ Soghanalia:n on_ this aircraft
L...-------1
bE
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,._.~-
-- -'
--~
.
~li
196A-1056
'
approximately one month ago.
~advised t_hat he was aware of an alleged

fraud perpetrate by Soghanalian concerning the delivery
:fifty caliber machine guns to the country of :Mauri tani ._
stated that all- of his knowledge was_ derived from
us newspaper articles concerning this matter and
that he had no direct knowledge whatsoever. He stated
that Soghanalian had never made any statements to him
concerning the alleged fraud.
b6
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'
I
_J
FP-36 '(Rev. ~2~78>

~
..
,.-:,__ ;:,
~--
,,
, ..
I
TRANSMIT VIA:
OTeletype
0 Facsimile
'FBI
.PRECEDENCE:
0 Immediate
0 Priority
0 Ro'Otine
rn ll I:B.TEL
I
I
I
I
I
I
I
I
CLASSIFICATION:
0 TOP SECRET
0 SECRET
0 CONFIDENTIAL
0 UNCLAS E F T 0
0 UNCLAS
3/25/Bl
Date
I
I
I
I
I
I
I
I
I
I
-----------------------------------~----------------TO:
SAC, .MIAMI (196A-1056)
.
'FROM:
SACf. .MORE (196A-439)
(SQ 7,)
b6
b7C
(RUC)
Re Miami tel to BA, 2/26/81.

\
.~
Enclosed forMiami are certified exemplified copies

elaware corporate file concerning Browning .Precision Tool
Company and United Trade Ineernational and FD-302 reflecting
receipt of same.
pw\o
;~
~- Miami (Enc. 3) . (REGIS. MAIL)
MAR 2 8 1981
1 - Baltimore
JPB:bjd
(3)
ORIGINAL DOCUMENT($) E,NCLOSEO

_.....:::::..DO,NOT BLOCK STAMP
Approved:----------
Transmitted
<Numbe")
(Time)
Per - - - - -
'C' U.'$, :GOVERNMENT f'RINTING Orf"ICE1 1980'3057~/S402
'/
-~-'--------'-'-=---=------
--
AIRTEL
3/25/81
b6
b7C
'l'O:
SAC, MIAMI
FROM:
SAC, BALTIMORE (196A-439) (SQ 7) (ROC)
SUBJECT:
.SARKIS GARABET SOGHANALINA;

DBA United Trade Internationa~;
~196A-1.056)
FBW; MF; ITS

00: Miami
~VICTIM;
Re Miami tel to BA, 2/26/81.

Enclosed for Miami are certified exemplified copies
of Delaware corporate file concernin9 Browning Precisio~ Tool
Company and United -Trade International and FD-302 reflecting
receipt of same.
CJD-
Miami (Enc. 3) (REGIS. MAIL)

1 - Baltimore
JPB:bjd
(3)
_MAR 2 8 1981
'~'10008 1000409Z
RR HI
DE MM
R 090409Z APR 81
FM MIAMI 'Cl96A-1055) P
TO DIRECTOR ROUTINE
ATTENTION:
I
BUREAU SUPERVISOR
L . . . I_
....J
BT
b6
b/C
SOGHANALIAN ,. DBA UN !TED .TRADE INTERNATIONAL;

VICTIM; FBW; MF; ITSP; 00:
MIAMI.
REFERENCE TELCALL BETWEEN BUREAU SUPERV.ISOR

'SPECIAL AGENT
~PRIL
L . . l_ _ _ _ _ _ _ ,
8, 1981; MIAMi TELETYPE TO
BUREAU,.JANUARY2, 1981, AUD MARCH19, 1981; LEGAT, LOfWON,

TELETYPE TO BUREAU,. JANUARY 1.7., '1981; AND LEGAT, 'PARIS, TELETYPE
TO BUREAU,, MARCH 24,. 1981.
ON APRIL 8, 1981 , ....
~-------.~DESK OFFICER, WEST AFRICAN
AFFAIRS, UNITED STATES DEPARTMENT OF STATE, ADVISED THAT PER
UNITED STATES EMBASSY, NOUATCHOTT, MAURITANIA, THE GOVERNMENT.
OF MAURITANIA HAS EXPRESSED A DESIRE TO FULLY. COOPERATED IN THIS
MATTER..
..
l"iAURITANIAN OFFICIALS ARE WILLING TO MEET WITH BUREAU
-~----.
-,,
PAGE TWO 'MM 196A-1056.UNCLAS

AGENT/AUSA IN,CAPITAL CIT Ofi NOUATCHOTT AND WILL PRODUCE
WITNESSES FOR JNTERVIEW AS SET OUT IN RE MIAMI TELET'fPE, . JANUAR'f.
2, '1981.1
!ADVISED WRITTEN CONFIRMAT.ION TO
FOLLO~I.
b6
b7C .
INASMUCH AS 'coNCURRENCE OF EACH COUNTRY JNVOLVED HAVE NOW

BEEN OBTAINED,. APPROVAL FOR FOREIGN TRAVEL 'IS REQUESTED AS SET
FORTH IN JANUARY2, 1981, TELET'fPE,. TO COMMENCE ON:OR ABOUT
APRIL
30, 1981.
IT IS NOTED THAT .t1IAMI HAS BEEN UNABLE TO VERIF'f
AVAILABILIT'f Ofi TWO WITNESSES IN PARIS TO THIS DATE.
'
ACCORDINGLY,
TENTATIVE APPROVAl; FOR TRAVEL TO 'PARIS IS REQUESTED CONTINGENT

'
'
.UPON 1VERIFICATIONOfi WITNESSES AND FINAL APPROVAL OFFRENCH

AUTHORITIES., PER RE LEGAl, PARIS, 'TELET'fPE.
BT
I'
I t
FD-t~ev. 5-22-78)
,.,
i
I
~oJ
TRANSMIT VIA:
G Teletype
0 Facsimile
PRECEDENCE:
Cl Immediate
Cl Priority
fXJ 'Routine
0------
:/ ,.-
'_,\,
.4.
~0~1
FBI
CLASSIFICATION:
Cl TOP SECRET
0 SECRET
0 CONFJDENTIA L
OUNCLAS.E F T-0
QI] UNCLAS
Date APRIL .9, 1981'
-----------~----------------------------------------'FM Ml"AMI (196A-1056) p
*TO DIRECTOR ROUTINE

ATTENT.ION:
BUREAU SUPERVISOR L-1_ _ _ _ _ _ ___J
BT
b6
b7C
GARABET SOGHANALIAN1 DBA 'UNITED TRADE INTERNATIONAL;
r---------.1-
VICTIM; FBW; MF; iTSP; 00:
.MIAMI.
REFERENCE TELCALL BETWEEN BUREAU SUPERVISOR

SPECIAL AGENTI
IAPRIL 8, :1981; MIAMI TELL-E-TY_P_E_T_O_ _...J
BUREAU, JANUARY 2, 1981, 'AND MARCH 19, 1981; LEGAT, LONDON,

TE-LETYPE TO BUREAU, JANUARY .17, 1981; AND LEGAT, PARIS, TELETYPE
TO BUREAU, MARCH
24, 1981.
ON APRIL 8, 1981,._I_ _ _ _...JIDESK OFFICER, WEST AFRICAN

AFFAIRS, UNITED STATES DEPARTMENT OF STATE, ADVISED THAT .PER
UNITED STATES EMBASSY, NOUATCHOTT, MAURITANIA, THE GOVERNMENT
'
OF MAURITANIA HAS EXPRESSED A DESIRE .TO FULLY COOPERATED IN 'I'HIS

MATTER.
MAURITANIAN OFFICIALS ARE WILLING TO MEET WITH BUREAU
! ":', ~~ :-':";~!~:) ,-,~,"', . .,onTan--'!n"

1;~!1.~:~;~:~,.,,'
0)-
Miami
HAL:cjr
( 1)
'' ~ .-..'l!. "~
S'di.!i'\.L1Zi:r1 t.- H!.i1

FILI.0 .. ... "' ......, .. --11!
TRANSMIT VIA:
0 Teletype
Cl Facsimile
CJ-----
,)1 . ,-;.. . ._
.1
!"
'FBI
PRECEDENCE:
0 Immediate
CJ .Priority
C) Routine
CLASSIFICATION:
0 TOP SECRET
Cl SECRET
CJ CONFIDENTIAL
0 UNCLAS .E F T 0
0 UNCLAS
Date-------;
----------------------------------------------------PAGE TWO MM 196A-1056 UNCLAS

AGENT/AUSA .IN CAPITAL CI1'Y OF NOUATCHOTT AND WILL PRODUCE
WITNESSES FOR INTERVIEW.AS SET OUT IN RE MIAMI TELETYPE, JANUARY
2, 1981.1
!ADVISED WRIT'I'EN CONFIRMATION TO FOLLOW.
be
b7C
INASMUCH AS CONCURRENCE OF EACH COUNTRY INVOLVED HAVE NOW

BEEN OBTAINED, APPROVAL FOR FOREIGN TRAVEL IS REQUESTED AS SET
'FORTH rN JANUARY 2, 1981, TELETYPE, TO COMMENCE ON OR ABOUT
APRIL 30, 1981.
'IT IS NOTED THAT .MIAMI HAS BEEN UNABLE TO VERIFY
AVAILABILITY OF TWO WITNESSES IN PARIS TO THIS DATE.
ACCORDINGLY,
TENTATIVE APPROVAL FOR .TRAVEL TO PARIS IS REQUESTED CONTINGENT

UPON VERIFICATION OF
WI~NESSES
AND .FINAL APPROVAL OF FRENCH
AUTHORITIES, PER RE LEGAT, PARIS, TELETYPE.

BT
Approved:-------
Transmitted ~~~---==:-~(Number>
(Time)
Per-----
~~-----------~------~----~
'J
''
..
~t of tr~nscrlptlon,
3/12/81
b3
b6
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I'
\_'\ '- 1\-._ \'~S\,_.
~i!l~o-.ro~tN~~EO_ -_-- -~
SER:AUiED~_,,.- fiHD~.c-<;....-'"1-
,.
1 nvosu9~uon on--..:::3:...c./..::l:.:l;.c./.;::;8.::1---~t ---Be=t:::h::.:;e::;S::.;da~,L..:M..:.:d::.:::..-----.'";... _.:;;;BA~.:;;;1~9.;.6~A-1:;.0.;.,3;.,6;.,_

llY ;
'
S~L-----------_j-l._.:~g~mbu,----O.te Olttlte<1--.-=3:.t./.:1~1J-/8:::.;1=----
"',
"
---
5-2Z..78)
FBI
TRANSMIT VIA:
Cl Teletype
0 Facsimile
It) .AIRTEL
PRECEDENCE:
0 Immediate
0
0
Priority
Rootine
CLASSIFICATION:
0 TOP SECRET
C) SECRET
CJ CONFIDENTIAL
C) UNCLAS .E F T 0
UNCI~AS
Date
3/20/81
------------------------------------------------------TO:
SAC I MIAMI (196A-1o_(s)

b3
SAC, BALTIMORE (196A-439) (Sq .#7) (P)
b7C
SARKIS G. SOGHANALIAN,
~::;n:~e:~l~~~T~:ternaUonal;
Reference Mirli airtrl to Baltimore 2/26/81, and
Baltimore telcon of SA
to SAl
~Miami.
Enclosed for Miami original and one copy of FD-302
and executed copy .of subp~d 2/26/81.
po~na
onl Encl:e: ~D-302 ,ljn-i;;ts selvice of
enclosed
Bethesda, Mary n )
by SA
of the Silv~r ~pring Resident Agency.
62M1nr.:ti '(Encl. 3)
l_.Bal t imore
~IYI~
I'''"
..
~RMP:taa
(3)
~
~~----------------------~--~
Approved:
Transmitted
<Nilmber>
(Time)
L--
Per-------
'Cr U.S. GOVERNWE:NT PRINTING Off'lct1 19S03057S0/540~
,,
'
FD-350 (ReV'. 12578)

(lndicat~ p4g~, r:~M~e
ot
newsp4pe.r, city and state.)
THE WASHINGTON POST
jt:wm,
=. . . .
-----~-:-t~-:--~-::-::~<M~o~u~"'~cs.!'~'!.e!l!;"~'"ts~..~.... ~R;s'-~'~~i~~?;;~~r--1 Date:

n ~~:;;.i~ '* ' '"'-~ ~~t.~ w .
J g\!.:~~!f '-~'"fr,Wt&~.,
Edition:
,.(~A{
"%'' - ,. .
{ .....
t-
%~~ W14fl~~.:. ::::t& 2:'

ec.{Tr. amm
.,. gt,.~;::/1~r
-
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, .. f
.. ~.....
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it''
'
\1
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'
~~
"
...
" ... :-
,.~
t1
>
'";
'
Title:
196-A-1056
.fl,
A
... ,f...
i
'
,"41_
IT
r'r,~. 1
l~ ... -=--~-t~~..f'o~.~.~=-3---~o:
.I
,.
tf
:.........:
~
~-~I
f
,'
March 22, 1981
OX'
Clauit'ication:
, . ,: It
Submitting Office:
And\S,ijpar.,.~.p~l ::.r ~~,. ~~~~~~k'jTetjOr~'~

';.~'!'
' >
fl Ste.phen
'.~~-
--
.~ . .. :~~:.,.,\~: t-~~~~'t.--~~~
Kurk~.. ,~.;~{~j~*~._~~~.~~~~/
~Beta Bl'fldlee lr.
-f. ~
.S A GREEN BERET, he was accus-.:. $'

. A tomed to clandestine assignments in ex
} ,
..
~is .sto~ ~lls"~:;;;;:~~.:I
At ita simplest,
ing ~d of merce~es, . many of them:
Amencans, eold the1r darmg and special .:knowledge to the highest bidder - in this: ~
instance, the forces of international terror '-\:
ism. But eome of the Americana invOlved in l~ ,
the Libyan proj~ - including the Green \ /,
Beret who was giVen a leave of absence by, '
his superiors to take part in the operation-
are convinced that the U.S. government
knew full well what they were doing, and' ,
may have let it continue longer than it. \
should have, in hopes of intiltratL'lg the'in a
ternational .terrorist movemeilt. 1 Qaddafi, ~~; '
after all, has open]y rmanced such groups as~.:1~
,the" gaiestine Liberation Organization,\~~
Italy'ajRed Brigades, the. Irish Republican i~
A.rmy,. the Japanese Red Army~ Germany''~':'
Baadef~elnhoff gang, and otherS.
,.
Ey~n..mo!~J,r.?ublinr.~-the State Depart... .
.m.entl4wbl"..Anmf.l~...ma.vt~~~bJ~
J..,ibya,'today.
.,t~f~,.;~' ~ . ~f. ~ :t~
At present, accordmg to State Department: :4
intelligence there ~tre more than a dozen; '
and perhaps u many as 50, Americans not necessarily connected to the Americans
in. t?e following ~port- in Libya providing
~~It~ auppo~,:to the government.'
,....,
'1
~
1!
otio places. But this was different.
.... .('
9
Before, whether in Southeast Asia or the-~
~
Dominican Republic,. he'd alw!lYS known:~;
c
that he was working for tl)e Umted States. '{\:.
...........1
But now he was in Libya, an avowed enemy~~
~--:
of the United States, working. forJ~ terror-~
-"
iat-prone mUitary.t.' (! .-~.. ,"v.'f.'~ 1' .,. ~
c. -j
~ He had been,in Tripoli Iesathan a week:fi';
~
when he was rlrSt taken to see the base of
~
operations for the group he had joined. With.f
~
another American at the wheel, they drove . :
-'-~
about 20 miles south of their luxury seaside
C.....
hotel until the sandy stretches of North Afri . 1
>can desert gave way to a. lush orange grove. ....
c::.')
The cu stopped at the end of the grove in f:.1:
front of the palace of the former king of~~
c.....,
Libya. who had been' ousted' in 1969 by 't
~
,,Muammar Qaddafi, the Libyan leader.
, .
c::.l
):;6
Behind a set of locked doors in the base .'J,
tb7C
ment of the servants' quarters was located,~ ::t
C!.:l
In effect, a small American munitions facto-'
:Z::
ry, atocked with explosives shipped from the' t
c:::::J
Uni~ Statee. There!- group of Americana..~.
c::a
~wu~ buey camoutlagmg small bombs !aa-:)*r:
"'lamps.candlee,briefcasesandasbtrays.
'l.~'fi '"''\
- .
!
1 The' Green Beret, who less than 10 da)'S! 1:~ i
''
See LIBYA, Pag~ D5 1'!'
earlier bad been going through routine Army ' .
.
.
..
. ,J ~
drillt at FortBragg, N.C., was now part of an I ~Stephen Kurkjian and 'Ben Bradlee Jr.~?~, :
going opera,tion which, from 1976.throughli;1 a inve~tigative reporter~ With the'Spot- 1 : I
l.eaat 1~9, as alleged to. have proVIde~ ter I ht Team of "''M Bolton Globe, 'from.; ;,_..__,_.:;..'P~--..$-J!~-\-l~c...t.<
nst trammg anft~plosi.ves for the Ltbyan .
ich thi$_ article il reprinted. Dale Van: . . ;AnrEO--.., 'DEX0
-.overnment.""~-..."'--..._
__ . ..,. . .,..--~. Hfrt " "',..-.: ......... ; ....... ,. '
' '.
~"'tZEO-~f-1"EO '-:JIr--t
1....
-r,..., ,.;..~~-,~ON,.
:r
tn
t:=
/A
I
I
.... 1/00J
FD-350 (Rev. 12678)
(Indicate page, name ot

~ewspaper, city and state.)
THE WASHINGTON "POST

(Mo..,nt
March 22, 1981

'
Edition:
Title:
196-A-1056
Character:
or
Classification:
Submitting Office:
'I\t
. undercutting the .~~ClmWI

speculation that the Un1ted..S
eti.)nea WilsOn's an4.T~rt>il's eviti~-!act that wnen:.on 0
:
rlrit.Americans ~~!~r.
...it:iJ.'""' ~- c.... -.... .. ~- ....
.
1 ~ ":'t..:. i:Q Septem~ 1976, the!
.:. w. QnANwu!l
,..;: th
~~
,
"-!'\'- -'- C'"D'Otmecl t&e
V.ll 0 0\IJ.t!l\
;.,.";;':'to_,_.! ,=~-:""operatiolt:"contin~ "att
least until late December. 1979,~ ~
~ to a federal investigators Z'6i
port - more than three years, after!
the FBI investigation was begun. '-f'-1~
Up to that point, federal investiga-t
tors now allege: t '
!-l :t:,!
More than 20 Americans, m~~-:
v e former CIA employee,3'
Beret on leave, five ex-G
ta, five former Army explosiv

e
and ~ civilian naval e ;
neers, Were flown to Ll"bya to pe_rt:o~;
a wide variety of support a~~ties, '
for ~addafi's military. i .... '.Ji'>J-1' '
Some of the Americans Were pllt;
to wort camoutlaging te~rist bo~be.
- n1e United States, in effect, ~~
w~ others trained Libyan com-
i.become
a major supplier of (mili.ti
mandoe in everything from bomb.
: tary) hardware and technology 'm,
detonation to parachute jumping.
LIBYA, From Page Dl , .~.. :.~:.. ~~~
support of worldwide terrorism. Far '
And the shipping to.Libya of mil-,
. State Department sources f~l
mer Central ..Intellig~n~ Age :
lions of dollars' worth of military!:-- l
that some Americans may have had.
'pel'SOnne~ military Special .Force i
hardWare, including 215,(1$) ~ds ot. .!
a hand in training the Libyan com- i
personnel, and U.S. corP<>ratio I
explosives and a ground-,W-m Red.S
mandoa believed responsible for lutj
combme to supply products and ex-r
eye missile, was contracted for with:' .
year's execution of 11 Libyan e'lileaj
pertise to whomever can pay thej
:living in Europe.
: .
t the required approval of ~e 1
price.'~
.~
If
Department. The Libyans will~
: Potentially more damaging is thej
,... . ,_;'!.
~:t\1~ -,
.
paid tlie enormous, marked:uP:;
:indication from State Departmen~.
that their American suppliers;. ,:.:
.
u .u
.~\..<-\.
1
~sources that the Libyans have sud~~
dwgedforthehardware.J..'t
.r
denly shown a ..certain sophisticated
:1 There is little doubt that the proj- :
awareness of U.S. intelligence capa. :
ett the 'Green Beret found ~If in '
bi.ltties and the nature of U.S. opera-1
volved in was a scheme hatched by
tions worldwide." It is another indi-l1
qvo
(.ormer . Central Intellig~n~~
cation that U.S.-trained mercenarieS Agency employes, ~wm P. W !I'
:are selling their skills and knowledge II
and Francis F. Terpil, who ~ 11;
abroad.
expertise to de~ign . a p~am
t:
The problem of the involvement! .
su~plied e~pl<>;'I~ and ~.le .to
of Americans in supporting intematram terrorlSts m Libya. , ;. ,,.
tional terrorist. "is much greater~
than recognized," according to other!
\ federal investigators. On the rusti:
,page. of one confidential r.eport, th~f.
'officialswrote:

., ~r
.,..,. ..._.
.
I
- _.
. . . . .\
..
. 1---'
/v
!I
<;;
FD-350 (Rev. 12578)
<Indicate page, n@le ot

new$paper, ity and state.)
THE WASHINGTON POST

(Mount Clipping In Spou Below)
~----------------------~~~~~~~~~~-----------;Date:
Last spring, Terpil and. Wilsoo?'x~

indicted by a f!Jderal ~and~.:/.C
Washington in conn~on Wl ,.,
elf Lloyan dealings. Netther
. ":
appeared for trial and both are
; },
Ueved to have fled the coontry. A r.
third man, Jerome~ B~. head ot.:
a California explos1ves supply (ll'Ill,
'was also indiCted in the Libyan ~
scheme. He pleaded guilty in Decem .
ber to a charge of conspiracy to violate federal arms transportaqo~ ~~.t..,.
and is ~peratin~; with the. gQ,_,_ve:n
ment while he awa~ts sentenctng!,t. ~
'eri)U could not be located for_ an;
interview, and .BrOwer refused 'spy
._.. t. WilsoD. reached by phone
would,88Y only that be is:"f
.....; .. -erican bUsinessman .here on:.~
..... ,rw.L " be iefuS8d to speak about-"' '
~0~ preSent ~ealinp in Libya.~=
i:Tritli,
\If
WJ.lson joined the CIA some

-after1erving in the Korean War as,l;;.
Marine. While his exact duties with~
the agency tl1'e not known, t~J
sources familiar with his work iden!l,~~
tied him 84 involved in two impor~
tant '60s covert operations: the!
sprawling, post-Bay of Pigs, anti-.
Castro operation ~ in Miamt!
code-named JM Wave; and the.
1/ search for the_ CUban revolutionaiy;'
leader Che Guevara in Bolivia~.lin; 1
1967.
'
W-t~:- 41 :~
t.ft-r
Sojnetime ~n 1~1, WilSon l~ft th,i;
CIA aiid epenffive ~ wwliiig tor~(
the UA NtWvy'a .Task rce 15'7:8-
~j .,._,..,."'' -.ri t,!j~r .,....~-: "-'
_, cariy. on CoVert operauc
iotei'Da4
.... ,
.,
Character:
:* '
196-A-1056
or
Classification:
Sub=itting Office:
In the spring of 1976, Terpil and \
tol' '
\V.i~n traveled to Pomona, Calif.,

m. with Brower. who; besides being l
a eral.lylicensed explosives manu 'f
fat er, was also a member of a con .
gressional explosives advisory panel

I
Brower, '61, agreed in principle to
supply Terpil and Wilson with. the '
explosives they needed to satisfy a
contract with tbe Libyan govern
ment, authorities assert. 4'
Federal investigators say that i~
through Terpil's contacts in Brit-
that the Libyan deal was ob. '
ed. Terpil, who owns a toWn
o.t
exai
ana::
Title:
~wneone-WoJ.k-m~ --~
. one
the foUr. or five compt.nies
("proprietarie'a"' uSed to pay agents
~~~ '"'
~~
~;f. ~~k".._.,.itA..:
in the field and ;ship support equiP':'
"""
. .y"nr..
..,, tr~"'f:;,.
. z;nent to them.::t.q ;~.';, :~r '/~i:.t...
..: ..m~.-~
.J; . Terpil
- "'"""'
iere an~iS~ :.
Wilson's. involVement with the~;
~ !"'1it:'~~p.
.
force was suddenly terminated,
f
~ _.,. ~ ~ contacts an
ever, in- April 1976, when he in
.~'";,.,<~~
~.
creetly approached Adm. Bobby
:
nman, then director of naval intelli
with a business proposition: If
~
would channel Navy contracts
Etyles. of 'living were aimost
ilson's private company, Wilson. 1

ppS1tes. .
..: '
.
would lobby his congressional COD
: Terpil, 41, was born in Brookl .
tacts to assist Inman in having Con
d retained the tough look
1 gress approve his budget requests. In~
awagg~ of the New York streets. e;
addition, Wilson proposed that:
boasted of his work for the CIA, and i
Inman comider disbanding ~Task.:
, although some people knew it wasn't
Force 157 as it: was then structured
true, Terpil would allude tO covert~
and setting up 4 new operation with ;,
operatioM in Latin America as it he
' had participated in them.
;: _\Yilson in.chaqe._;. ...~~ J~::
, A~ to federal- oftici81$.
But by most accounts, Terpil waS,
Inman, who went on to become dir.ecactually one of the agency's lessei.:l
lights. According to sources, he re1i ~ tor of th~ National Security Ageney:,.
before recently accepting President
paired code-breaking, equipmen~.
Reagan's appointment as deputy di
until he was rued in 1971, reportedl;l"
rector of the CIA, wa8 "astounded".
for failing to keep the low prorlle ex
by Wilson's roposals: He. immedi~,
peded of CIA agents.
,.
ately informJ the FBI of the conver.:1

By contrast, Wilson, an imposin'
sation, ordered that Wilson be rued '
figure standing about 6 'feet_ 6 an f.
,from Task Force 157, and, a short.
weighing 240 pounds, epitomized th
time later, recommended that the en;. .
(meat in Washington manners.
tire
organization be 'dissolved_;.;.
member of the Georgetown 'and Untir.
~,. ~1 ,, ...... ~ .. ~ . .
. ."'
versity clubs, he tit in ~mfonabl~
with congressmen, businessmen,
entagon and CIA executives, ~ _
t whom he invited out to his $6 llll ~
on, 3,000-acre Fauquier County el :
earms as weD as numerous mterJ
with both federal officials and
te for weekends of hunting, ho
'
participants in the Libyan operaiion,
back riding and barbecue& , . ..Jt!
. ~scheme worked this way: .;\ ~
t '
Edition:
't~.....
March 22, 1981
i..-
q-"
..,,... .-
'
..... . , _ _ , , _ _ ._ _ _.....
-:.1
Use in London, was introduced~
to Qaddafi's cOUsin, Sayid Q'

then the chief buyer of sophiSt
electronic equipment for 'th
.Libyanarmy.~
.
~~
On Aug. 13, 1976, Terpil, Wi1Son,
Brower arid seVeral others met in
Washington at the offices of Inter
technology Inc., a new TerpilWilson
company. There, officials allege, the
three formally agreed to ship quantities of explosives to Libya without se
curing the requisite State; Depart.
ment approval. Authorit!~. ~efer to .
I this session as the compuacy meet :
ing
'. ..l_f,
Th& same day, Brower's~bOmp 1
- Califom~J.S. Brower and
.
~bi~ ~ rll8t)oad ~exp
w ...
....- - "" ......... ...
J
{
1. were packed
In black 50-~ 'i.tt
1
dr1mia'marked 1nduat.rial Solvent." 'J
,.~
~!;~~To~~i
3.
FD-SSO (Rev. 12578)
<Indicate page, name o!
newspaper, city and state.,
ntE WASHINGTON POST

March 22, l98l
(Mount Clipping in Sp~_ Be_!~~)_ :-r--:~-:---1 Date:
U1.~--:-.~t;;,~-...~-~~
p~ recruits toe.~
imdplemer._~. the ~nrie! q8inin_g \

Ap expJ.W~ve mapw&:~PrcM~
Slona of theu agreement wtth~Qad~

fi. Amo~ them were John
~
e~,. a re~ CIA ordnance techiii
~ ~ his aon, John Jr., ~ ~-
V1rg;ma. who hel~ eet up e ex~l,._,
P~OSl~ manufacturing p!an~"l.ln the
!-t
"'"'Pies: ~. the<
fba~J~~ ~-v:!'rttor:~-
IAbyon pal..,.
paid-f'l',~
Ll])ya, fot which he was

fle constrUcted 25 Ccincealed bOmbs.~?:
~~""--
--
~ ~- -~
~ ""-~- -
However, he said Jle ~hit fathe~

bandoned the project becauserg
'knew [~e bombs) were forte
.
.
and umocent lives would be 1oe ..
Douglas M. Schlacter of Up ..
ville, V&;, a friend 'and ~- ~j
sociate of Wilson's, was also reCruited I
-during the early stages of the opera
tion, but, unlike the Harpers, he~~~ed in Ll'bya, for the most ~ !
.acting as Wilson's and TeipU's go-be;i~
'tween with the other AmericaDS''If f
r tfley arrived. .~
,,.w_,~ ~ ~t,":
' Apparently dissatisfied with the~
explosives ID8llufacturing done bi \
Libya by the Harpers, Wilson p1revaned upon Brower to 'recruit oth .. :
ratives. Brower fOUDd four men,
,
from the West Coast. Two
em, Robert E. Swallow and Denrui-.
Wilson, were engineers assigned td~
the China Lake Naval Weapons Sta~, 1
tion, a remote installation in Califor
nia'a Mojave Desert that conducts.
top-secret research in ~e develop:.''
ment of new weapons systems for the
United States. .

'!'!....
SwalloW and Wilson took leaves
from China Lak(l to gQ to _Liby&.
When their work was done in Libya,'
they ret~ed to their jobs at C~ .
Lake.
:'It!.
Another of the West Coast recruits, 1
who agreed to a telephone interview i
on the condition that his name not be 1
used, said he went Libya as a fawr
to Brower and because he thought he
was participating in a CIA operation.
wever, no~ explicitly indicf:4 I
agen~ ~~olvemen~ ~ men
ed to him. . ;'.
~ -~: .r, ~ I. .
to
1----------.:..f-
wo~, =u:~~a i~ cov

e..M "the recruit said.".\'i';1 ~:.. ~.
' "tO
: ~ b;,mg brieie{i; ~
Edition:
1:
.Washington, the four men flew to'

Libya. where Schlatter picked them
up and drove them. to what he said. -
would be their operations center, the,
palace of the former king. A~
the palace was a sinaller buil<ling~ '
which had been the servants' qUM-: .
Thi8 --when> the AmericaoO
~ ~t ~~~be. ~ ;.: . ' -;
Terpil. .WilsOD 8nd Brower each\
e a few visits to Tripoli dlll'ins;
the tin:ie he W8s there, according to
rtlie-~'Hesaici~ WiliOn~ offtie(t~

hi:ol a'raiettmd aabd him to itay ~
'-~-' ~.-:. ~ -~ ~._, .,............~
i &nd ~ ~ W&~ to sec hom&.~ ~"-$:

v._"I regn.t the whole thin& the:.'
".Welt CoMl reerwt Nfd."I Wish rd1
. never neard of Wi1eoli 'and Teipil. I:=
thlnt theY'r8 ciut plowing up a whol!:'.A.

bunch of cash~ not afraid of whOi~
they have to step on to do it! I~. But'.
there's still a questfon in .r# mind
- ~the role of the CIA. No one's evert .
wered that question. How db
eclc out something like that? EveDi
1
you ask the right people, you're.
t goingtogetthewronganswer."-:lt ;t.:~
~Jd:;~~ifi.; . - ~-~ . : t"!': ~ f . - r . I : I
-.!
100i"'l
~~~
:r.-t~~~'?zt~~- ,9 ...~:::~;;'_ .'"'~
:~' ~
U Aoi:ording-to the feder81 reports, o

"> evening of July 21, 1977, Luke
m~ a Green Beret maate
:
I
sergeant at Fort Bragg, received a:

phone caU in his Fayetteville, N.C."
home from a man identifying himseJ11
t~&PatLoomia.
. :'
l
... Loomis and another man, it turn&, .
out, had been rued from the CIA 6yl
agency director Stansfield Turnei .
Jess than three months before for a};.y
legedly assisting Wilson in buying ~l
p!oelve d~ces bound for Ll'bya. d~1
\'lee& that Could only legally be pur~.
chased by the U.S. government.
1
-
'Thompson later told federal au_.
thorities that Loomis asked him if~
would be available to recruit an
head a four-maxi team to undertake?
an assignment overseas for whichf
S~ Forces skills would be re-:
qwred.
\ .~
(The fo~ng day, TbompeoDf
cilled Loorms to say that he 8D4i til.
''group of four ex-Green Berets he~
. 'Viou$ly served with would
. I
ailable. Loomis asked to m .1
~pson and his team at the F .;__
teville Sheraton.
~.. ,._,; 1
...
Title:
Character: 196-A-1056
or
Clusification:
S10bto.itting Office:
Before this meet1ng, one of the ~~

..~
'ts, nervous that Loomis might
:
agent provocateur {or aCboetiJ ign power, informed .milltary in
~e~:~cials at Fort~~ !{,.(
ti w8s told they bad checked~:"
operation out and there was nothing.~
wrong with it," said the Green Beret,.:;
. who agreed to an inteniew recen~~.
on the condition that his name not
r~ed. "I assumed that they mean .I ., ~~ _to, d~ a job for th! Age~ 1
<
C)~:~ -:"_ : .
V'_
, ,
~l
J.!
' ?:-i ..t.
'J
C;.f::i:: .'" ' ..
~, ~ :~-: ~,
..
. ,
participate iD the ~jeet.;j:

G
Beret asked Cor and 'was _
m
ly granted a 3()..day leeve.
the Green .Berett
"Loomis began by SAying: 'My name
is Pat Loomis and I'm with the CIA. '
I'Ve juat come out of deep Ct1'M in
tlie aircraft industry In Indonesia. r '
don't know any of you people. One
man here has been thoroughly inveetipted. I don't know.the rest ot you
and I don't want to knOw you.'
.
Loomis told the men they would be
paid $4,500 a mon.th plus a
b9nus at the end of ~ year.
d provide no. further. details
mission, bisi!ting that that in1i .
tiOn wOuld have to be Wen out-
. e the country.
-,
$151
P'BI/OOJ
FD-350 (Rev. 12-5-78)

<Indicate page. nan:te or
newspaper, city and state.)
Title:
196-A-1056
or
Classification:
Sub~~:~itticg
Office:
'1 .Hecause it was' too soon to ~ve I

'thout arousing suspicio
e.
;ireen Beret source said that
d
" team spent most of the next
u eeks in their hotel rooms mappmg* out a comprehensive terrorist train.

'j#ing program: . . '
..
e-_ After a month, he said. he ap-:,.
" proached Schlacter and. citing Prel38ing personal business at home, told
~. biin he would have to return to the..
. Up.ited States. Schlacter offered no
argument and, within a few hours,
J>r.esented him with a round-trip air-:
lirie ticket.
. , ~: :~
-' .
~e
p~~~
:~!~
~port&f'e~ I:l:m~;~:~~.a~t~:
bea~t.
7
'
'f.:.'
his return
theextensively
United StatesJ}
e Green
BerettoWas
deb 'efed by military intelligence per-
ed them with'
hotel, where
one was $1,000 m cash but m
accommOdations had been
:.
visas, according to the iOurce.,...._ ~;' 'd ,by the_ Li~ govemmen f,
.n.. was .not until the following They were given a list ol stores .a
zAoming, when Pat tOOmii llandeCJ:
them. their plane ~cketa, that the

Green Berets learned they were.
bOund for Tripoli, via Zurich. Loomis
Said they would have no trouble spot.
t1ng their contact becaUse he was a
tall man who would be wearing a red
't'and a gold Rolex:watch.
airport, Ed Wilson was -.
'
t1y recognizable 0 theui:\ . ;
r arriving in Libya the

introduced to the chief of Libyan
sign,f'~r
which they could simply

anyi:-s:
thing- they wanted. ~~~I! ~~1
available, and they: were ~~.

Libyan driver's licenses. G~ W}~~:
. machine guns were stationed...,~ .~
their hotel room doors.~'""' :o-~--... ,.~ ..
1 Two days later, Schla~ ~P:'~
ileared at.the hotel,. seemmgJy.m~ .
~hurry.
ordered the group to t'"'";
ready quickly for ~.!t* me6cbi~
with Senussi, the inte""'6.,nce ~ -":
~ Senusei directed the. G~ Be~
.intelligence, Abdul &nUMi, ala? a to establish ~ traiDiDg ~~.
. member of the country's ~ gram for Libya_a collliDindoe.:~Bere.;;_:~lc..
CounciL .
: .... : .. ';
..At
the Green.
v.
mint tea, Senussi begau ten- source

"it became clear
ill the Americana of . problem : .me that we Were Working foi hostile~

m
ten:
..ence." Y.>: ,
- m'th
auuu.
""'6
.. ~..
FcYPtiazi
.. ,o~Jgn
Concemed that they were now .. '
All:
=t,"
.-
'
.-;."~"'
.I
ft
imel at Fort .Bragg. Then, a~
'
-- ~ - -
He
wu
~
~ ~A~of'---"
to~.
~~"~~~t~ll}~~
tly wanting reassurance that

byan operation was in fact .1
te, Fort Bragg off'JCials decld to

call in the FBL
. . . . . . ::
In a telephone interview, Robert R
Caverly, then a resident agent (or'the
bureau in Fayetteville but now retired, said he told Fort Bragg miJi.
tary offidats he would seek "clarifica.
ti~" from the Justice.Departme~:t
de rmine' if it was a CIA operati
.Bu the clarification from Was
to ever came.
.
'"'
,' faf~t!". ~.:.;;~!b;ct~.~~~~. ~~;~elide~::~~=~~
! best
-~to~accornp~Jl!Q
~ ~!.-~.
_-~~!!- $he
and ..the
otherandGreen.
~ I
Will'. Q\:~~ q
(o ulated
escape
evwon
ted the Ameri~ ~~-'a
p
in aiSe they had to. get ~
t could put the EgYptians to &Jeep "'the country quickly. " ~ .
en the Americans politely, scoffed
:;~
'a 'thls idea, Senussi abruptly ended'
them
~'L ' ,;,'i"'
. ee.;
..................
........
"6',:fto1'
...~~ '*--;..
'"'"' ~ ;~:
.
.
~
f'ei/OOJ
, ... . . '
\
FD-350 (Rev. 12-578)
(Indicate page .na:ne of

newspaper, city ao.d state.)
. THE WASHINGTON POST

(Mount Clipping In Spoce Below)
~----------------------~~~~~~~~~~----------~D~e:
Ureen Beret began recei~'
~~....:.....
ed ....~to
I ho~a1t.:
tote.!topP
.t .
-~
..
~
thorities. At. a precaution, mill
ciaJs moved him from Fort B
totheNavalSpedalWarf'areDePment in Little Creek, Va., where he
serVed 88 an "unconventional Warfare
adviser.."
,:~ !f, ~~. '
His superiors at Fort Bragg,: he
. said, ordered
th him to continue
.... Pi#iei
1 ne
" ................ lied to by. tile....... e"n ,!,
A!eou-bim
pare~;..~ toeTri~pepo~~tiF~,~~thoutthe':,
~~~the a;.n"&;,t1greed-
to act 88 the operation's stipplyoffi

c:er in the United States, and he i:ec:ruited three more ex-Green Berets
to go toLI.'bya. \ >!i ~- f ... ': ,(
Requests for supplies were sent (0
. him in code. Among th8~supplies: ne
.~provided in at least two large shipmenta were teclmical training man.u
als and military boot& Fort: Br8gg
. military ofticials carefully cataiogUed
the items before they were 8ent to
Loomis, who then forwarded thetn~6
-to Tripoli
.;.l.".; J~ -'9- . '
m--.
'~ -\ '..\' C1.r
"rmonly:.:z~itll' ;. a.;
:.>. , .
t .
..
ed, "but ,I believe Ed
ue conQU
Wilson: was
._l
-
.I
"turned loOSe tcr get:'a handle on

LI.Dya. He \Vas allowed to establish a
: very profitable private.. enterj>riSe
with a co-allegiance to the C~ We
. were the low-paid infiltrators. We'
were,.......expendable.".
. ,.. -){
-~ . '~~.u...
Editioo:
r-rch 22
1981
u ...
Title:
196-A-1056
Character:
or,
Clas$ific~ion:
.. .. ""..,
Submitting Office:
t;'-,~~~~-ro~, .tr ~ ' .. ,.:.-;.

Fed~- l>~iO~ Sa; ihat~~
both Terpil and Wilson are the tar-'

geta of international manhunt& T~-:
'pil is believed to be biding In eith" r :
Ll.'bya or syng (which .do
extradition treaties with the United1
States). Wilson, on the other h8xid,
ipotted and briefly detained laBt
not' h8Zi
t' ~ -~~
"!h~re .~e ~ a~~ 11
cco:\~iJ'to'~~:!IS'tan{r.;1}t1UJ.8. _.A.~i-r'. ~
4
....
N~~~
~w
ney E. Lawrence BarCella; the 'Amer '

ican C:onsulate in
was notified'
by local police' and told a meeting
' At. his involvement in the L'i .t ' ~d be set' up shortlY to arrange
! aftair_began to wind down, the G
deportation of Wilson to the United
Beret source said be learned 'tlllt StJtes. However, at a hearing orlli.ut
WiJsog had been subpoenaed fa fes.
28. a. police inSpector inf'ormed tfie
tify in WasbingtoJi before a federal
court: magistrate that Wilson ha4
d ' that
tig ~ ma
been released from jail the 'nig&t b&.Cn:witlr-~~Fe~
fore. and placed on
romnielci81
'~1978, ~ieOUrc.::irecel~~hW own
flight to London. AlthoughMal~
,. ..~ '"""<1.-...
....'-r.:itfd>/..:l;j;'
1.ri' .~
authonu- ha~ taken_V/ilson's ..,_
Y....M.
''".! .,t;;r.,;..,_v-~:;;>.
~". - t-~,.!'... ,_,
u..IWI....,.:ona:
"''f'r .s..:....
.... _,.,_,_.t.:l:t-.
port, by ""
the time he .d-pped
off the'
~- """' ' ..,._1-~ -y....,v '1:"-ti ....Y"'M'_ '
......:;
be 'vieited C!A~ headqtiaitert' At his plane at London's Heathrow A.izP<>rt;~
~...req~]iloldzif:ici:!'guidance~he had another one to get ~
~as to how mu~ be .should tell the:
customJ:IV.\,\4~. "'~;t'!t~~~~.....,,~
~jury.~red:~~ o~~ m.
.~~lla is tight-lippeda~( U1e
the, c!andes~ .o~ sectiOh;: slipup m Malta. "We've never gotten
the sodrce wd he Was introduCed~
a satisfaetoiy explanation .,from:
an offiCial. who tolerbiD 'that .fl-.
;
about. what hap~ned," he ;
the Libyan o~~tiori bad nothing .
d recently...I don't knOW' 'it~
with the CIA, he was tree~ to U
er ~t another Chance at him lie
grand jury anything li8 wis
t." .~ ':"' fk , "i.~ t.r .. ' .. ":
G~n Beret's skepticisni re-
?f~
~~:-.:~~>:J.:::,:i_-1;...
'L.. _,._ ~L-o.~ ...,, .
~ver.
:tt.:~~...-~~~
\
....
ed,
Malta
>
:a
'I .
I
'Eta
we'll :
<
_,..
l-
<. . . . . . . .
If IE
1"81/00J
b6
I
~~L
_ _ _ _ ___.
~-~
,,,
...
'
-,.
~ J ,
.... H
lAWYCRS
P.o.eox sezs
2601 t:AST OAIH.ANO ,.ARI': BOULtVAI'!O
l"'R'I' l.AUDBRDA:t.Z:, :rLORXDA. OO:Uo

UUf>HON (~OS) 58~2:$41
Apri_l 17, 1981

PERSONAL AND CONF!DENTIAL
O.E.G.D.
Bureau 724
33 Rue de Franqueville
Par-is 16
Re:
Boca Investments vs. Sarkis G. Soghanalian, et al
Dear
l.. . . . ,_ _ _ _,..l_t_e_l-ep-h-on_e_.d me today to inform of hi_s personal conference with you yesterday i~ Paris.
At the instance of
the Just_ice Department is in the
midst of a fraud invest1.gat_1.on concerning t _h e act_ivit_ies of Sarki_s
G. Soghanalian in the Mauretanian cont:ractual matte_r. Special
AgentL
lof the Federa_l Bureau of 'Invest_igat_ion has current
plans to visit Europe early next month for purpos~s of conferring
with people such as yoursel_f, who are in any way knowledgeable of
matters -leading up to and sur-rounding Soghana_l_ian' s fa_i_lure to del _iver the merc_h andise viewed and ordered by t _h e Mauretanian government.
,......_.....Q.Io........u~~,......""""t)e
of certain matters will corroborate information

has previously -furn_ished to the Just_ice Department .
r-----L.--....,...-h-a...ls suggested that your meet_ing wit_hl

might
be more conven_iently effected in London. He will be in further
cornmunicat_ion with you to coordinate the most convenient time and
place.
Thank you for your cooperat_ion in this matter.
"
Sincerely yours,
By
DA/jp
Bee:
1~......-_
__.
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2.
IN COURSE OF CONVERSATION WITH PRIME MINISTER BNEIJARA
FEBRUARY 7, CHARGE BROUGHT UP SUBJECT CASE AND DESIRE GIRM
COOPERATION IN THIS MATTER.
PRIM MINISTER BNEIJARA SAID
HE WAS KNOWLEDGEABLE OF THE CASE ANO THAT THE ~ILES WERE
STILl. AT' THE CENTRAL BAN~.
CHARGE SUMMARIZED GIST REFTEl.,
MUCH OF WHICH BNEIJARA KNEW, AND SUGGESTED, AS PER PARA G)
REFTEL, THAT A REPRESENTATIVE OF U.S. ATTORNEY'S OFFICE
COME TO MAURITANIA TO GATHER INFORMATION AND MAJOR
GO TO THE U.S. FOR THE TRIAL.
BNEIJARA GRATEFULLY
D SUGGESTION AND THANKED U.S. FOR PURSUING MATTER
OF POSSIBLE FRAUD.
DIPlOMATIC NOTE OFFICIALLY REQUESTING SAME IS NOW
TRANSLATED AND IN PROCESS OF BEING TYPED AND WILL BE
SUBMITTED THROUGH OFFICIAL FOREIGN MINISTRY CHANNELS
WITHIN SEVERAl DAYS.
EMBASSY SHOULD THEN RECEIVE OFFICIAL
RESPONSE SECONDING PRIME MINISTER'S UNOFFICIAL ACCEPTANCE
OUR PROPOSITION.
EMBASSY WILL NOTIFY DEPARTMENT WHEN OFFICIAL RESPONSE RECEIVED.
UNLESS SOM~ONE HAS SECOND THOUGHTS,
RESPONSE SHOULD BE POSITIVE ALONG LINES EXPRESSED BY PRIME
MINISTER.
3.
'
; '
I
RE PARA C7) OUESTirNs

1AITH WOULD CREATE
PROBLEMS ANO, GIVEN
IXeCEPiAI'fCE OF PROPOSITION,
DO NOT FORESEE ANY PROBLEM XN A~RANGING VISA FOR FBI
I
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(M6ASSY HAS JUS-T RECEIVED OFFICIAL NOTE FROM

MINISTRY GIVING GO-AHEAD FOR VISIT TO MAURITANIA
REPRESENTATIVE OF U.S. ATTORNEY'S OFFICE AND FBI
GATHER INFORMATION ON SUBJECT FRAUD CASE CAS PER
MINISTER'S RESPONS.E REF TEL 8),
2.
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FOREIGN
OF
TO
PRIME
3.
NOTE ALSO SAYS THAT MAJORI
I CAN GO
TO UNITED STATES TO TE.STXFY ....- - - - - - - - - - - - - '
~.
WE NOT FROM ORIGINAL CABLE ~EFTEL A) THAT OFFICIALS
WANTED TO TRAVEL TO MAURITANIA END Of MARCH
ALTHOUGH
AIRPORT STI~L CLOS0 TO INTERNATIONAL FLIGHTS WE BELIEVE
ZT SHOULD SOON BE OPEN, ALTHOUGH AIR AFRlOU FLIGHT
THROUGH PARIS, WHICH RETURNS AT 2300 HOURS MAY BE
AFFECTED BECAUSE 0~ CURFEW STILL IN EFFECT.'
5.
RECOMMEND OFFICIALS TRAVEL NEW YORKOAKAR VIA PAN AM
FLIGHT; XF DAKAR/NOUAKCHOTT DAILY FLIGHTS NOT RESUMED BY
THAT TIME, EMBASSY WILL SEND CAR TO DAKAR TO TRANSPORT TO
NOUAKCHOTT.
OFFICIALS SHOULD OBTAIN MAURITANIAN VISAS IN
ADVANCE: IF THERE IS ANY PROBLEM. LET US KNOW
P'EASE
AQYXSE' ET,.
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0083 12823000
ZNR.UUUUU
R 081746Z MAY 81
"FM DIRECTOR FBI
TO FBI MIAMI <l96A-l056) ROUTINE
BT
UNCLAS
SARKIS GARABET
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DBA'UNITED TRADE INTERNATIONAL;

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REURTEL TO THE DIRECTOR DATED APRIL 9, 1981, AND BUTELCAL

TO MIAMI ON MAY 7, 1981.
FBIHQ APPROVES :rRAVEL FOR SA IL--_ _____.1 MIAMI DIVISION,
TO TRAVEL, TO LONDON, ENGLAND;
L!S~.9N,
PORTUGAL; AND NOUATCHOTT,
ISLAMIC REPUBLIC OF MAURITANIA, FOR THE PURPOSE AS SET, FORTH

IN RETEL.
BT
0083,
SEARCBED----L\~EXED
SERIALIZED..:::..rzu:D ~
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BOCA ;INVESTM~S 'LIMITED

Registered Office:
Direots:
Osprey irouse.
5, Ok!Street,
St.Belier.
'Jersey, Channel blands.
:P.E.Ralph (Au~tral~)
.M. Rall)h '(AU$tralia)
Exu.tive Director$:
Adll'iini~ra.tk>n:
:telephone:
!u.esdayApril 28th
Attention
~f S.AI
1981.
IEsg .
F.l3.I.
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~ents
and will
Federal Bureau of .Investigation,

_3801 ::Bise~.e .:Boulevard,
-
'Miami,
.Plorida 33137
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ANDREWS & LUBBERS

~WYCR.$
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2~;"01 CAST OAKI,ANO PAFIK BOU_L..;VAFl-0
J'O:al'
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LA~E:nDA,_;:e, li"X.ORlDA 33310

T!:~!:IOMONI: (30_$) $-<5_~~$41
May 5, 198:1
I Federal Bureau: _ofIInve'stigation

3801 Biscayne Blvd.
Miami, FL 33137
RE:.
Dea~
Sarkis G. Soghanalian
The attached was received fr_oml

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Ithis dat_e and :x forward same
for evaluation.
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With best regards, _I am
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tf.AiiCHEO- INOEXEO
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MAY 8 198J
.. FBI- MIAMI
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FBI
TO:
~IRECTOR,
FROM:
LEGAT, ROME' { 196A40.J (P)
SUBJECT:
SARKIS GARABET SOGHMJAL1AU

~t~rWu Atlo ..at;
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Vu:ti119 Au.Utalt:t Leg4t Jtoad :U,L~t~- : ;

$/30/11, Regional Se~y 0&6ie~ (RSOJ[
Am~ean fb~4y, B~ut, advi4td ~hat inq
~~ m~~oug
Int~nat Seeu4lty fo~e~ (ISF) o6 Lebanon eone~King ~

TAade (UTI) Limited and Un~d 1ndu4~t4 have m~ w~h
negativt ~e4u~ ba4td on ln6o~mdtton 6u~nl4hed. Inqu~le4
~Lth ~he Leban~e Chamb~ o6 Comme~ce in '8el4Ut have been
ntgatlve 6o~ 4ng ~aee4 ~6 United .Indu~~e4.
1nq~e4
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AIRCRAFT hne a glamoor whkh

1-\ prevents peQple- thin~g of ,
them as they do cars. But bOth are
commooit~ wbk'h start .life with
shiny paint and pl'Qgl"eS$ through lhe
.h~!l~S of many more or le$$ .reputab.le
(>WQef$ bef<'~:-e finithi:: on lh<: S<:X'"-P
l)eap. ~\'iatio.n, for all its $hiny image,
has its share of questionable bu$~
lles.s.'Witt\ this story ol a p;~rticular
aeroplane's dotage arid . eventual
demise we remin<l our readers that
tbese'~i~s exist, and leave tbem
to draw ~h~lr own concli.lsi<>q$ about
the effectiveness of current international contl'QI$,
,,
On Octe>ber 11 last year a Boeing
707-~21 displaying false Zai.ro ~egis.tra
tion took off from Bristol Lulsgate fO('
Kuwait. The G,OOOft runway pt'oved
insufficient to allow the aeropl~ne to
~me airl>orne, althougb under the
prevailing oeo~ditions a 707 in good
shape should not have. required the
extra ground trampled by tl;ii$ one.
The ai.rcr,.rt extensively 'damaged
approoch ll~hting, cartied a quantity
of bedgo and tree with it to Kuwait,
a_nd left bebi~ at Lutsg ate Jaree s.eo.
tJons of both inne-r tlaps. Fuel l().ld
was ~~ut 1SS,()90lb, but the fJJselage
was Vlt'Wallf empty.
Tho 7W's eventual destination WM
Bombay, where kssee Richard Rashid
KhaD Sr had to mt a contract fO('
livestoclZ airfreighting. The crew
siste<l or Khan's .sOn '(Khan. Jr}, a
Briti$h tpilot,' and .a 707-qualified
ft/ght engineer (FE). The Lulsgate iri
con
DAVID LEARMOUtT
CTRU) failed, acotber wu m~unc

tioning, and most of the engineer's
instru~ots followed ~he compa$SOS
into partial or total un~tviceability,
Khan reportedly has
agile style
wit~ official {)4perwwk, as initially
evillenced by tne pil()('s li<'eoces. He
hM apparently used
Dan AU'
s.tationery to !:>.Kk \IP maintenan<Je
-and registration dai.n:l$; insurance
company letterheads to daim 'rover
that di<l not exis1; arui called h.i$ ~~lr
line" variously Cargo Air, Air Union,
Nr Tran~ and, in llomb:iy only,
Khan Air. Ail' .Tran.~ SA is the' real
n~me of a 'Brus~ls-boased 'ai.rcraft
bl'Qker ~'bich bad , been iti.volved
In Khans acq1.1isition of the AU
lease. A~ing to tbe FE the Air
Transco chairman had made some
small investment in Khan's venture
and be was a passenger OQ ' tho Lubgate departure; bt:Lt a few week$ after
Klun began operations Air Trans.co
withdrew all suppq.rt. Khan. however,
b3od reportedly made unauthorised
use or Trans.co's name, ~ati-ooery,
and claimed ~t one stage to be the
finn's operati-ons di:rectO('.
- Here , is the in$ide story of that
LuJ$(3te take-olf as told to Flight by
the engineer. F.our days befoore t
parture, Ridlard Rashid Khan Jr
uked the fE to travel to Lu~ate
and help hun fuel the aircnft. The
engineer refused, saying refilelliog
rould take place on the day or deParture. Khan Jr has ai.rline piloting
experience and a revoked US commer
cial pilot's lioonce. Khan looded
7(),()()()1b of fuel anyway, filling tbe
centre tan!< with the remaipder in
rnain tanks-the wroog order for tlrls
operaHQO..' . , '
' '
On de-part~- day the FE $upervi:s.ed
cident detail reconied above i$ (11

firmed by UK Civil Aviation Avthority
records; the majority o! the rern.tio.der comes from .conversation$
betwn Fli9ht and the Boeing's FE,
who now works as 41\ enginr with
an
a D~>tah comp...uy,
Before proceeding witb the $aga,

here is how the ~ircra!t arrhed at
Lulsgate. n started life with Pan
Anieri~;an. in Jate l~ as .N723PA.
Pan Am sold the 1W in 1974 to Ail'
U~ion A.G of Switzerland (AU), which,
accoiding to the .fE, ~a$e<l the aira-aft to indivi<!ual ope.rators in
Nkaragu~ and other co~trieS pndeT
the US registration,.-N711UT, or
marked with Swaziland" or 9uioslav
registration u requested. Khan Sr
leased the aircraft from AU in mid
1979, and used the false Zaire reg.
stration 9Q..CRY by which the aircraft
was identified inlhe Lul~gate a<:ciderit
report. The aircraft was at Jlelsinki
when Khan acquired it, and 'it w-as
flown from Ua~re to J..asham In
southern England where Dan-Air
Epgineering was ' ta$ked with carry;
int out some maintel'lanre. The FE
tells Flight that the mahitenan<:e brief
to Dan-Air was some 62 ddect$ Short
of wbat wa.s required to make the
aircraft' fully ftt, including maio '
problems.
Afte.r 26 days at wham the &it'
craft was Tequi.reQ to m,ove, aod Khan
elected to fly It to Lulsga.re. 1'he No 4
generat()t' failed a.oii had to be rep.lired1before tir.,J, dep-ifturefor tbe
west country. 1'be FE reports that
compa$50$ were functiooing PQ<)rly
and neitllel' Ht' r<tdio worked. This
wa$ $tiU the $ituation OQ departure
for Kuwait. but dari.ng the Middle
East flight a traosformeNeoctitier unit
'ear
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fl'&,/(1
J~wl>ft-, :7 ~...,,.:, It~
1 f'uelling to 1S2.000lb:' an'd Khan
told him to dd the- takt-otf ('ai<:'IJI~

tJons. ~ FE, becoming prognos.shC"Iy
~ ('Urjous about the crew's
apparent Jack of expertise dC'-~pite
~heir paper qua!Jtications, did the
~ms Crom the Pan Am IT)anual
emerge<l with .a' take-off c;li$tante
r~uirtd of 7,600ft. Khan adviS(-d tiim
the runway wu 7,SOOft. A~ual <!~
tance is 6,600:h betwe-en the two sets
of plano keys. The British copilot,
real q\lalifications appear to
amount to a PPL and as.slst&Jit in
stn.~ctor's ~tin_g, took no part ill
pl'eparations.
The FE rtad all the staft and taxi
c::heck~ and call~ fo<' captain's take
off bnefing. Khan said "normal takeoff." Daring tbe final stages of taxiing,
as the captain was changing ~~
stabillser setting, the FE asked
whether this would be a rolling takeoff or a spool-up against the br~kes.
Khan. replied by en;ering the (Unway,
setting takeoff poweT and calling the
eniineer to trim t~ throttle$ 0 p. th.e
Nil. 1be copilot gne no speed calls.
Khan rotated
the far threshold and
the aircraft staggered airborne; with
audible relief he reported "aicbofne''
to' tbe tov.er. The .aircraft. hit almOS1
.II the ap~roadl lights, $Orne hedges
.and trees, and .rate of climb at 400ft
wa$ minimal.
A !ew $econtJ$ .aftef Khan~ ajfborne
~~; Bi'jstol Tower' transrn1tted
"S1r, do you realise what you have
done.?" To Khan's negative, the tower
re~lied "You. 'have damagerj the
runway lights, sir. 'Thtre seem to be
~ pie<"es oC aim-aft as well. We
will report ba('k." Some dme later the
tower reported ' finding honeycomb
str-Ucture from t~ ftaps attd SWidiy
other pietes. Khan's react ion to the in
formation was to order tb~ crew not
to tell the Air TranSCC? chap.
On arrival at Kuwait, Khan led the
~Mer rapi~ly away from the a~
cnft, reaving tbo engin~t' and
..Pilot to study the 'damage. There was
more than the FE had expe~ed. He
had exPerienced prol>lem.s with th.e
pres:WrisaHon durlng the ftigh't, b!Jt
tbi~ -~is a leaky Ship any-Way, and
there had been no apparent aerodynamk probleiTI$. Metal b.trs we.re
banting out of the fu.sdate' undel"'
.side ' which. bad mum debris em
bedded in it: a ~ft long metal bar
protn.~ded from a. wing; the landing
g<iar was festooned with tree
branches. and the unde~rriage bay
doors and lcx;k$ were damaged;
finally, the ail" condi~ioning bay wu
full of metal debris.
The engineer walked round the
Kuwait Ainvays }Janga" trying to
get some a.s.si$tance in ('arrying out
rempora'ry rep.iirs.' Some help to
patch holes was evtntually fortb.
cOming, .and aft~r the FE had worl<.eci
lOhi' hours.
the aidran'le and the
TRUs Khan reappeared ready
leave
and
whose
'
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w.
on
to
fof BoriJ6ay.
.De$pite ~s.suran~ before d~~f1ure

frolf\ VK that th~re wc>uld be m.lill
'
"
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~trou[*d
",W~
' ,,
in th.e h.ote! lobby to
ttnnce f.Jolit~ at Bornb.ty, kMn 'sr ...
take the bus to t~ .t.i~. .Both
. as...<:ettt-d that tbtre \\ere r:one
Kh.ms w~re there. their wi\es, a c!lild.
~rnnged (()(' tbi$ .air(t'aft. Lap.~.tng
a hotel emplo~ee who w~ted a lift to
ge-ar Pf'ob~rn.s had become a{i:ste.
Europe. and t~ engineer. Destination
Senral sub$equent ftigllts out ~
was to be L1.ncembQurg. On artival at
b.ly to the United Arab Emirates
the aircraft. the FE chked and ser. '
(UAE) were made with the Jdt puin
viced the landing gear olt>~ ~nd par.
gear dowq bC'cause n would not re
tiC\Ilarly the faulty ldt ma~ ~ear
tract. Khan's rep.lies tq ~rtled air
levelling cylinder-the mai~ cause of
tr.d!ic controlle!'$ who .na,de observa
failure to retract.
tions oo this were intended to make
the A TC mea believe they were
Khall Sr .t$lc.ed if e~rytbing was
"Seeinl( thine~." But thi.s happened
ready for ~pnt'ure, and when
sufficiently oftu that the gear prof>.
a.ss\lred it wa.s he made treat play
!em, combined with the gener~l
of the opportunity the FE now had
appeu:nce or the aircraft, caused the
to buy at the duty free shop. 'V'lhen
UAE authorities to take an interest
the engineer did not want to go, Khan
{ave him $20 to buy with: the FE
in Khan's o~ra~ion. I<ha". allege<lly
f'endl olf thl$ mte~st Wltl;l forged
WC"nt. Wben the engioeer returned,
papers a.nd licences and auempted
everyone was on board 'ready foe d~
parture. Engines v;ere ~arted, and
bribery.
Two methods were uled to stop the
Khan Sr. in the ('aptain's ~~. wu
crew e<>operatfng with any interested
warned that take-off must be (Om
e~ternal parties like the UAE authorj.
plele within lSmin if he wanted the
tres, and, to keep them flying. Khan
ldt main gear to retract. Check$ and
l<ept tbem poor; saluy wu always
tal(iing were qukkly finished and
due tomorrow. And w~erever he
Khan exe<:'IJted a rQUing tal\e-off run.
could get away vdth it .he wou.l<l dis
About 2 12 hours inio the Bight tbe
~redit the FE by blaming him 'for
FE n()ticed ~me vibration, tollowed
te~nkal prpblems.
by illumination of N'o. ~ engine low

oil Jlght. Jle retarded the throttle but
vlbration ~ontin"ued to incre.se, and
'
within a few second$, the encine
tiMr Khan told me several seized.
Khan looked p~nid:y. The
tl,es abou~ five
six
vibration reilu~d but dl<i Mt ~top
before dep~rture that some,. with 1'\o. :S's involuntary shutdown.
ono is going to sabotage our This time No. 4 was $baking:. and the
gauge$ $hOWtd it W&S lo$inf oil rs.st,
aircraft. I asked him who and The
elected to sh>.:t this one
why but never received a downere~
before it seized. The ~irnaft,
reply."-The Flight Engineer. overh-ad Turl<fy's white~p:w-d m~uo.
tains at flight level :530 (~.OOOft)
when No. 3 failed, h"'d drifted down
to FL290 by the time No. 4 had to
Jlu.si[)(!SS began to dry up, and the
oo put out. Driftdown continued to
aircraft remained on the ground it
l'Ll60 and Apkara was ch*n a:s the
Bombay for some weeks. The FE wa.s
diversion. Hypoxia wa$ becoming a
looking for ways of returning to t~
problem be<:ause there was .no oxygen
UK but had no mcmey to l~uy a ti<ket.
on board; engine$ 1 and 2 coyld not
~rly in the morn~ng at t~e l:let~inning
pressurise a leaky tu.1ll as well as
of January, tl)e e11.gineer wn wo.ken
keeping it flying. An\! N9. 2 was
~ an -agitated Khan Sr who told him
beginning to vibrate S<:verely. Ankara
to prepare the oiirqaft for depirture
was ti()Udcovered, a.nd wb.ile gi\'lng
to Shar;ah. \\.'heQ h~ nrhed. at the
vectors ror a radar approach .c\TC
airport the F.E found Khan' Sr' sur
went ,3ead for five minutes with total
roundec;l by airport offici-als, but Khn
ground power f.1ilu!'tl. There was
told him to {o away whe~~e~ .he
pani<: on the flightdeck becau~ the
approached the frpup. the aircrdt
crew did not know what bad caused
finally dt!>arted, captained this tirrie
che sudden silence. IJut the control.
by Khan Sr.
ler's voice c~me 'Qat"k, arid the air
The aircraft Sta)ed at Sharj.1h until
daft lan~ed with both. remaining
January 25, during wh;,-n time there
wu considerable argument about engines ~>{".'fating.
The FE found No. 4'$ llgal oil tank
salary ~ue and other matters. the
almost empty. Engine~ 2 and 4 wotJhl
British e<>pilot was ~nt home.
tumJ,y hand, but with difficulty: No.3
Two days before final departure
was seized and No. 1 seemed good.
from Sharjah _the FE was told that
On checking the oil t'tlter$ the FE_
departure was imminent and he
found far more $and and small metal
shoul-d remain in his hotel. ;rhe
r>ieces in them than he considered
destination w.as not menti~ned, txcept
rould have got there by accident.
that it wu in Europe. 1lle {()Jlowing
Khan says it must hav;: come about
day he was tol~ tO prep~re the airby intake ingestion: si.nce thi$ .is .no~
craft, and $pecifi~ally ordered to
possible. the FE wonders what ha}>chcd~ aU filters. oil q,u:t:<tity, and to
pened while he was b1.1ying duty-free~
supervi.~ t~ rd~ellin~. tlavlnf done
atShujlh.
thi$. t~ engineer was told In the
Th<: 107 is S-till ft Ankar.l, and '
evenint that take-otf 'f\'~uld be vtry
lot 'of people are looking fOl' the
earl)' n.ext day.
At dayb.rea~ the crew and pas~n
Khan.s.
D
'
.Born
or
days
.~
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AIRTEL
l-lay
ll, 1'981
Director, FBI
SAC, Miami (196A-1056)
.-db: U:ted
:lade International;
______ VICTIM;
SARKIS GARABE'I' SOGHANALIAN
FB ;
00:
b6
b7C
; I.T
Miami
ReRome airte1 to FBIHQ fated 4/15/81, cop"ies enc1~sed

herewith, and Butelcal to SA_
Miami, on 4/28/81.
Enclosed for Miami are the four

reairtel.
~tems
described in
Inasmuch as the Translation Staff at FBIHQ has no

translator :roficient in the Greek language, it is requested
that!
_
your office_ translate this
mate 1a1 pe 1USttactxons in referenced communication.
Upon co~pletion, ,a copy of the 'translation should be

forwarded to Legat, Rome and 'FBIHQ, attention 'I'ranslations,
~Technical Evaluation Unit, Iiab.
'
Enc'losures (6)
l - Rome (info) (l96A-40)
.W--.
0~ (Rev. 81679)
'
..
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I~
-~
l
,;-:-,,
AIRTEL
TRANSMIT VIA:
CLASSIFICATION: - - - - - - - - -
DATE: __~M~ay~l~l~~1~9~81__
/.
FROM: Dl._7ctor, FBI
TO: ~C, Miami (l96A~l056)

SARKIS GARABET SOGHANALlAN
(oba nni ted

/
Tf~~~Ti~~ernational;
FBW; MF; ITSP

00: Miami
ReRome airtel to FBIHQ dated 4/15(81, copies enclosed
herewith, and Bute.lcal to .s~
~iami, on 4/28/81.
Enclosed for Miami are the four items described i/ 31
reairtel.
~
~
"Inasmuch as the 'l'ranslation Staff at FBIHQ has no
translator proficient in the Greek language, -it is requested
thatl
lof your office translate this
materl.al per l.nstructions in referenced communication.
Upon completion, a copy of the translation should be
forwarded to Legat, Rome and "FB!HQ, attention Translations,
Technical,Evaluation Unit, Lab.
Enc-losures ( 6) )}\)
t'(
1 - Rome (info) (196A-40)
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. . . ...
, .,.
.... ;, . . . . : . ' ~,-;~c,-c: .~ .: -
FD-36 (Rev. 5-22-78)
FBI
TRANSMIT VIA:
CJ Teletype - ..
,o:"
D Facsimile_
r:x. Airt:l - -- . "
PRECEDENCE:
0 Immediate '
D Priority -
D Rooti;ne ,-
CLASSIFICATION:
0 TOP SECRET --- . ,,,
l--'
t:J SECRET , .
'
,,., ,... ~
0 CONFIDENTIAL . _
0 UNCLAS E F T 0
0 UNCLAS c
- -..-.
1
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1
I
5/12/81
----------------------------------------------------TO:
SAC, MIAMI (196A-1056)
FROM:
SAC, OKLAHOMA CI1Y (196A-664) (RUC)
SARKIS GARABET SOGHANALINA, dba. ,

International;
I
lvicTIM;
FBW; MF; ITSP;
00: Miami
ITnitod Trade
Re Miami.teletypeto Baltimore, 2/27/81.

Enclosed for Miami are certified copies of
registration documents obtained from the Federal Aviation
Administration Aeronautical Center, Will Rogers World
Airport, Oklahoma Cttv. Oklahoma. concerning aircraft
reaistratior numbers~-----------------~
Since~~ further investigation remains for the
Oklahoma City Division, this matter is being considered RUC.
_/Jk --I os=b ~JdS

.. -.-_'tEO
(3)
Approved: - - - - - - - -
~DU~D
SEI\tALIZED_...EH ED
@Miami (Enc.-3)
l - Oklahoma City
WJV:wjv
'
Transmitted
MAY 15 1981
~~--:----==:---:---
Per-----
<Number>
<Time)
vu.S, GOVERNMENT PRINTING OFFICE: 19e030$7S0/5402
b6
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:~-.
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FP-36 (Rev. 5-22-78)
TRANSMIT VIA:
FBI
PRECEDENCE:
0 .Innnediate
Cl Priority
Ro-o.tine
CJ :Teletype
Cl Facsimile
rn Airtel
..
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CLASSIFICATION:
0 TOP SECRET
0 SECRET
Cl CONFIDENTIAL
Cl UNCLAS E F T 0
C) UNCLAS
Date
I
I
I
I
I
I
s/12LB1
----------------------------------------------------TO:
SAC, MI~~-~~~A-1056)
FROM:
~~)>JL~u~I1Y (196A-664) (RUC)
SARKIS
&AiW(trlSOGHANALINA,
1 ::;;o:;;r;:;~~~~tional;
dba. ,
b6
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00: Miaml
Re Miami teletype to Baltfmore, 2/27/81.
'
Enclosed, for Miami are certified copies of
'fi.C4-/'
registration documents obtained from the Federal Aviation t "'~ b ...
Administration Aeronautical Center, Will Rogers World
~
Airport, Oklahoma Ci tv. Oklahoma. concerning aircraft
/
registration numbers!
) IS"
Since:~
further investigation remains for the

Oklahoma City Division, this matter is being considered RUC.
r2).
Miami (Enc.-3)
1
:1- Oklahoma City
W'JV:wjv
(3)
Approved:--------
Transmitted __,,.....,.__,....__=---<Number>
~U.$,
<Time)
GOVERNMENT PRINTING
Per----~FICE1
1980305(50/5402
Jey
I
Memoranduni'
SAC, MtAZ-fi (l96A-1056)
To
Date
'5/15/81'
s~ L~------,.------1
From
SARKIS G. -SOGHANALIAN
-FBW; .MAIL -FRAUD

( 00:
'NIAMI)
on '3/5/81, :Federal Grand Jury subpoenas were

served on the -f'ollowing persons:
b3
bo
b7C
las Custodian.of"Records, Peat,

Marwick, ""'M,.,..l....
t...,..ch.-e"""l....l.--a"""'n,...d,...._Cornpany ,, Barnett Bank Bui~ding,
,SE .8th .st._ 'and Brickell /Ave., Miami, Flot:ida.
!advised- .the writer that he was the

reviewing_ partn:r concerning the .'ac~ount for Sarkis
Soghanalian._l_ ~
jadv'isfd"that- hp was{)ersonally .
familiar wit:fi, -t e ~account. L
... ~lso. stated that
his fir -'
' --
- -_ or the Jaw
firm
had, in . fact,
. hired
to- per- orm-:account1.ng services
~or Sog
-
~ Niami
- ~AL:klj
~i-- <l>Oho
/~6-IIJ~-;:b- /~
________-l
ERIAI.Il0-----JIUO .;:;.-_-- - - l
.a~~(0~1N0XEO
MAY 1.8 1981
Memorandum'
To
'
9tfc._ 1
From :
~ (fq(,I\-(Qn,)
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~~~it-~(
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Date
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-THE F.OLLOUING IS COPYRIGHTED 1981 BY D&Br INC., AND IS PROVIDED EXCLUSIVELY-----FOR SUBSCRIBER 061-0015091 UNDER TERHS OF SUBSCRIPTION AGREEMENT.
DUNS: 00-284-8638
ALASKA INTERNATIONAL AIR INC
<SUBSIDIARY OF BERGT
CORPORATION, ANCHORAGE AK>
FAIRBANKS INTERNATIONAL AIRPORT
AND BRANCHCES) OR DIVISIONCS>
FAIRBANKS AK 99701
TEL: 907 452-7171
DATE PRINTED
HAR 09 1981
CONTRACT AIR
CARRIER HEAVY
CONSTRUCTION OIL
FIELD SERVICES
ENGINEERING HOTEL
SIC NOS.
45 21
16 29
89 11 70 11
C~IEF
-- I
FINANCE
021'02/01
'"UISTORY
1021'021'01
,I
',,
STARTED
PAYMENTS
EMPLOYS
SEE BELOW
HISTORY
INCOHPL~TE,
1980
400-500
<400 HERE>
~ ~-. ;~"
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EXECOTIVE: NEIL BERGTr CHB
SPECIAL
EVENTS
SUHHARY
RATING
NoV 1980 o nQw c::orf'Oor<ltion was f'oraoedr DERGT CORPORATION to

OPerate as a holdins c::o~Panv of' Aloska International Air Inc.
The former Parvnt co~Panu o' Alska International Industries Inc:
was ~ersed with another cOrPoration in order to ac::auire outstandins
stock bu Nel Berstr and transform corPoration into a Privatelu owned
corP
Then in SePt 1979 Alaska International Industries Inc was
mersed with and into Alanka Int'l Air Inc and from SePt 1979 until Nov
1980 Aloska International Air Inc::r Privatelw owned bv Neil Borst,
OPerated as tor c::omPanv.
On 020381L~-----------'~ COIIIPtrollerr declined financial

statunent.
I
lstatod it is Nail Derutr Chm of Board's P011c::v since
bu~iness 1s now a Privatelw owned c::orroration to not disclose
financiol statemonts.
Howeverr based on "financial state~~aent of' Doc 31 1979 on Alaska
Interna~ion~l Air Inc: rePorter e~~i&a~es annual ~ales a~ $~5rOOOrOOO+.
Nl:I L [tERGT, CtW

ROBERT HEATHr V PRES
RON~~~ :~R:T ~ ~RES
DIR~
oR s : H cg=:J~~~~=~
FRANK HOOLINr PRES

ALEX HILLERr V PRES
CHARLES COLEr SEC
,,
IncorPorated Alaska Hau 21 1953.

Authorized caPital conGist of ,
2r500r000 ~hares common ~toc::kr 10 cents Par valuo.
Name wa~
oriuinallv Interior Airgayg Inc.
1972 name chan~ed to Present.
Bu5inuss ~tarted 1946 bvl
~s ProPrie~orshiP
100X of
caPital stock is owned bY Berst CorPorat~on.
,.
1. SeP t'.'79 r.ul;>Jttct. u~r!feci ith the t.lwn . P'fr.(tnJ. . coll'\tr;>ar,. ..... ,.,(\lrt!>ka
~0". I\'U0 lll:.r.ll ~IOIJ\'Ir,r.;t.t.,.\' ~ .. u 1'u\lllltH'lu OIJe\J\,.\"'b!.t''flb\'lU'o~ 1 .\ti~j1o!q1"fi'l1
t'
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ALA~K~ INTERNATIONAL AIR INC

FAIRBANKS AK
;.MAR 09 1981
./
H'IST~R~
(Cont.#d)
';:.
Ala~l-.a
C:O!IIIr>ar:av of'
International Air Inc.
"r
''
NEIL (cERGT bor:n 1935 ~arried . Attended Ohu:.r>ic Colle:l'ler'
i,
Brca~ertoro WA.
.Joined Iroterior~Airwo'v's 19S7r which .. later becal!le Alaska
Iroternati_onal Air Inc.
Worl-.ed as Pilot. director of' OPeratior~-v
Pres; of' oPerations, e'>:ec'utive v J>res and in _Mall 197,5 beca111e .~rellident
and then .chai r'_11111an of board in 1980.
Iro 1979 becae sole stockholder
an, ip ~9BO forDII:l'd this corPoration.

E .. r>lo\~e;fd b'll Atlantic Richf':i.eld Co Ir:ac unti 1 1973 when he ..
w'a5 a~5utnod to Alvess-.a PiPeliJ'Ie Servic'o Co~r~r>anv as ~enior Pr'oJect
ll'lal"'o<f!Oier in charse Of PiPel iroe c'onstr'u'ction.
1'973 becacr.e associated
wltll sub.Ject concerns. Pl''edecessor Ala'sk.a Inter-national Industries Inc.
I
lborn 1937 ll'oarr1ed.
Graduated U o.f Houston 1960r BIA .
Ac'e'oyl"'ot1n~.
Prior to Joinintt Interior Air'w<iv's Ine 1971 was f'inancial
vicu Pr'tfs of' I<u'rtle'ss Const Co Inc Fairb;:u~l-.s AK.
Prior to that was
C:CI(\,t.r't'll~fl:
1'\_ru:horu:lc.l N.r.t.ural Ga:n on~J Tr'unkl11\U Oa1~r llo~ioton,:TX.
.
I ___ b()rn 1'?2:!. '1'15'4-70 de1111ocr~tic ~\atioroal coaiur.ittQe 197073 sP.l1C1U
<3Ssist.an.t to uowvenor of' Ala'ska.
.Joinc'd. rredecessor. .
..
collllr>a'n\1, 1973.
Docacr.o an off'ic'er in or'J~Dni::Dt.ion in, ;977 ~, ,,,,..,,,~ ,,.
R.ONALD (cERGT tiorn 1935.
.Joif)ed:Ala'i!l-.a Xnt.'l .Air, Ine . ~97~. ;o19,75-
76 ':"os., rrtt'&ident. of' Wea~er D,J:'O& Inc., Ar,c:~orase AJ< a *'(IJ~kf!"!~-"'1~
bus1ne .. s.
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I
~b'orn 1927. ~ Honr)t.oined Priv'ato . l'!w .rn,a~ticQ ,ir,.:F,~irbaflk.& AK
&it)C:Cl 195 .
Adlfli}t.ed .. tp Ala'sk.a Bar 1953.
Attended Stanford u, Palo
., Altor CA abt.aini.n:t law des.ree.
I
IActiv'e here in account.infl f'or J>ast. couPle vears.
Oeta~ied anlac~ents a~o ~ndotorined.
Ru 1 ated Concorns:
ALASKfl, XNTERNI'\TIONI'IL--UWlJ'STRIES INC, ([reloware CorP) AnchoY.a'f.le

AK.
1990.
lfoldinfl COIIIPan\1 wit.h two s'ubsidiarie5. both involved in
tho oil induGtrv in Al<fska.

~t =
, .-,.:
.
~. ALASKA INTERNATIONAlJ OI'I... INC.
1980 Anehoraf.ler .AK. Oil
"relat.od on:tinoQrinss l'Oor'vic:Q-.so
B , ALAS.KA INTERNATIONAL ENERG'Y CORP.
1980 Ancho'rase, .AK; ;
Orerct.es ~:ln, the oi 1 woll ond exPloration f'ield and owns .one wh'oll:w
ownad ~>ubsidiar\1 which is:
(1)
Ar'ctic Ala'ska D.rillinu Co Inc.
1980 Anchorasut AKo
0PtJr<.~t4h> ~-f~ <~'n oi 1 d r i l l :l.nu eont.rnctor in Alo,.l-.a.
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Sub'sidiarl~ of\ ItQrSt. Cor.roration, Arochoraset AK start.ed 1980 which
oPorat.es ~$ ~ol~inu c~DP~nw. i.Parent ~ODP.anw own~ 100~ of' caP-ital
stoc&-..
P.nrf.tnt. coii\P:Dnl.l J:)as one ot.her S'-lbsidiar'ies~
.
Opeotos o's a cont.ract air carrierr heo'vv conet.ruction contract.or
oi 1 f'iold '.ler'vices r enl'linoerin1 Ser'vices hot.ol OPOrat.Orf &QUiPIII&nt.
loi3'lJintl and Wat.or and ,POWer distribution serV'iC:Eto
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Tt1r-ritorv Ala'ska.
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FhCILITlCDI
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305' 'N .; Hibiscus' .Dr ..
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EXI:C:UTOAS, ADMINISTRATOR$, AND ASSIGNS TO HAVC AND TO HO\:O ,
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MM00031491759Z
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RI491759ZMAYSI
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TO 0 IRECT OR ROUT IN?:

ATTENTION:
HEADQUARTERS~ SUPERVISORL..~--~-___.
8T
UNCL.A S
KIS GAR ABET SOGHANAL IAN, DBA UNITED TRADE INTER NATIONAL, ETC.;
VICTIM; FBW; MF; ITSP;- 00:
RE
~IAMI
.MIAMI .
TEL TO BUREAU, JANUARY 2, 1981; BUTEL TO MIAMI,
MAY 8, 1981; MIAMI TELCALLS TO LEGAlS, LONDON AND PARIS, MAY 8,

1981.
FOR INFORMATION
.. OF BUREAU A NO LEGAlS, LONDON AND PARIS,
~
ITINERARY OF MIAMI CASE AGENT AND AUSA FOR TRAVEL AUTHORIZED IN

RE BUTEL IS AS FOLLO\~S:
~RRIVE
JUNE 7, 1S81, DEPART MIAMI; JUNE 8, 1981,
NOUAKCHOTT, MAURETANIA; JUNE 10 OR 11TH, 1981, DEPART
.NOUARCHOTT.; JUNE
ll
OR 12TH, 1981, ARRIVE LISBON; JUNE 15 OR 16,
1981, DEPART LISBOtl/ARRIVE LONDON.

ACCOMMODATIONS AND INITIAL INTRODUCTION TO LISBON POLICE
sEARCHED ....~.,..-...,......INDf.XED .~..,
sEm~tJ;;.c.o~ .-:.d
FILED. ~,...,~ ..... ~ . . ~:... : . . ..__
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P~GE
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TWO MM ( 196A': 1056) UNCLAS
AUTHORITIES 'IS BEIOO HANDLED BY SECURITY OFFICER, U.s.

LISBON.
E~lBASSY,
MIAMI WILL FURUISH LEGAT, PARIS, WITH IDENTITY OF INTERPOL
CONTACT AT LISBON PER RETELCALL.

FOR INFORMATION OF LEGAT, LONDON, EXACT ARRIVAL DATE AND
'
TIME IN LONDON WILL , BE CABLED FROi1 U.S. EMBASSY, LISBON, AS SOON

AS POSSIBLE. PER RETELCALL TO LEGAT, ALL INTERV.U:ws WILL BE
CONDUCTED AT U.s~ EMBASSY.
UliERVIEWS 0~ IJITNESSES HAVE BEEN
SCHEDULED THROUGH ATTORNEY REPRESENT I 00 VICTIM IN PARALLEL CIVIL

ACT ION.
INTERVIEt~S
'IN LONDON \!ILL I,NCLUDE TWO FRENCH NATIO.NALS,
lwHO HAVE EXPRESSED DESIRE TO BE INTERVIEWED

L--I_N_L-_O_N_ID_O_U_H_JS_T_E-AD_O_F_PA.....RIS. PURPOSE OF INTERVIEW
WAS SET FORTH IN RE MIAMI TEL, JANUARY 2, 1981.

L..-_ _ _ _
PARIS 16.
_.bN
PARIS IS OE.CO, 0724, 33, RUE DE
ADDRESS OF
FR~NQUEZILLE,
:tHIS JS FURNISHED T0 ASSIST IN MAKING NOT.I FI CAT ION TO

.
b6
S:UTISH AUTHORITIES OF INTERVIEW OF FOREIGN NATiqNALS AS DEEMED
b 7C
APPROPRIATE BY LE_GAT, .LONDON.

LEGAT, LONDON, .IS REQUESTED TO ASCERTAIN AVAILABILITY FOR
INTERVIEW oN OR ABOUT JUri:: 16, 1981, .oFI
SUBJECT EMPLOYED AT THE. U.s. EMBASSY.
I A BRITISH
PURPOSE OF INTERVIEW OF
---
-- ----"-"'--....;...:;:...;--'-----------
b6
b7
PAGE THREE MM Cl96A- 1056) UNCLA S

I
'
~....-_
____.I tiS SET FORTH IN RE
~ANUARY
2 TELETYPE IS TO CLARIFY
CERTAIN STATE DEPARTMENI' CABLES RESULTING FROM CONTACT BETWEEN
____JI ND VICTIM.:
L..__
BUREAU IS REQUESTED
10 RETRANSMIT THE ABOVE TO LEGATS,
LONDON A~'0 PAR IS.
8T
.,,
/'!"? /? <>c /'7'q /

1-Q THAT IS IT .THE OTHER ONE HAS TO BE' CORRECTED
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PRECEDENCE:
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SECRET
CONFIDENTIAL
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fMMI-1! (196A-l056) P
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ATTENTION:
HEADQUARTERS
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GARABET SOGHANALIAN, DBA UNITED TRADE
___ _ _---11 VICTIM;

L
RE MIAMI
~EL
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FBW; MF; ITSP; 00:
~NTERNATIONAL,
ETC.;
MIAMI.
TO BUREAU, JANUARY 2, 1981; BUTEL TO MIAMI,
MAY 8, 1981; MIAMI TELCALLS TO LEGATS, LONDON AND PARIS, MAY 8,

1981.
FOR INFORMATION OF BUREAU AND LEGATS, LONDON AND PARIS,
c.-..
iTINERARY OF MIAMI CASE AGENT AND AUSA FOR TRAVEL AUTHORIZED IN

RE BUTEL IS AS FOLLOWS:
JUNE 7, 1981, DEPART MIAMI; JUNE 8, 1981,
ARRIVE NOUAKCHOTT, MAURETANIA; JUNE 10 OR 11TH, 1981, DEPART

NOUARCHOTT; JUNE 11 OR 12TH, 1981, ARRIVE LISBON;' JUNE 15 OR 16,
1981, DEPART -LISBON/ARRIVE LONDON.
ACCOMMODATIONS AND INITI-AL -INTRODUCTION TO LISBON.,. .....PO~
......
~,.ncl'(E0 ...
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(Number)
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9
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GOVERNMENT PRINTING OFFICE 1980305750/5402
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0 UNCLAS
Date-------;
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(l96A-'1056~
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----------------------------------------------------,: 'Pl;.GE TWO MM

'UNCLAS
AUTHORITIES
LISBON.
~S
BEING HANDLED BY SECURITY OFFICER, U.S. EMBASSY,
MIAMI WILL FURNISH LEGAT, PARIS, WITH IDENTITY OF INTERPO
CONTACT AT
~LISBON
PER RETELCALL.
FOR INFORMATION OF LEGAT, LONDON, EXACT ARRIVAL DATE AND
TIME IN LONDON WILL BE CABLED FROM U.S. EMBASSY, LISBON, AS SOON

AS POSSIBLE.
PER RETELCALL TO LEGAT, ALL INTERVIEWS WILL BE
CONDUCTED AT U.S. EMBASSY.
INTERVIEWS OF WITNESSES HAVE BEEN
SCHEDULED THROUGH ATTORNEY REPRESENTING VICTIM 'IN PARALLE4 CIVIL
/,..
'
i
I
INTERVIEWS IN LONDON WILL INCLUDE TWO FRENCH NATIONi~-;_'
ACTION.
IWHO HAVE
L-IN_L_O_N_D_O_N_I_N-:-ST_E_A_D_O_F_P....JARIS.
EXPRESSED DESIRE TO BE INTER;IEWE

PURPOSE OF INTERVIEW OFI
I
WAS SET FORTH 'IN RE MIAMI TEL, JANUARY 2, 1981.
~N
PARIS
ADDRESS OF
ITHIS IS FU~ISHED TO ASSIST I~ MAKING,NOTIFICATION TO
BRITISH AUTHORITIES OF INTERVIEW OF FOREIGN NATIONALS AS DEEMED
...
'
.APPROPRIATE BY LEGAT 1 .LONDON
~
:;
#.'
:; :.,':.-o.,
_ .. L:.~,;.,LEG!'T_,.
:LONDON, IS RE_QUESTED TO ASCERTAIN AVAILABILITY FOR
.... ~l j_...
11
::.:iN~*RV.:i:EW
ON OR .ABOUT JUNE 16, .1981,
0~
SUBJECT EMPLOYED AT THE U.S. EMBASSY.
' Approved:---~----
lA BRITISH
.PURPOSE OF .INTERVIEl-1 OF
Transmitted-----=-----CNumber)
Per _ _ _ __
CTime)
otrU.S. GOVERt-M:NT PRINTING OfF'IC1
.
~~-"-----~-~-~----
1980305.;750/540~
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0 SECRET
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0 UNCLAS E F T 0
UNCI~AS
Date --------1
----------------------------------------------------, :PAGE 'THREE MM
uNCLAS
(-l9GA~105&)
><"
CLASSIFICATION:
lAs
SET FORTH IN RE JANUARY 2 TELETYPE
~s
TO CLARIFY
b6
b7C
CERTAIN STATE DEPARTMENT CABLES RESULTING FROM CONTACT BETWEEN

c=JAND VICTIM.
BUREAU IS.REQUESTED TO RETRANSMIT THE ABOVE TO LEGATS,
LONDON AND PARIS.
BT
t"
..
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Approved:--------
Per _ _ _ _ __
Transmitted~:--:~--":=':"-.-(Number)
<Time)
~U.S. GOVERNMENT PRINTING OFfiCEt 1980305750/5402
Memorandu~
To
s~, ~' ~ \
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Su~ject
( \q~'A .. forc.) (P y
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c;{J /tl l
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O.t of trnserlptlon,_......;::6;.c./...:2::..c/;..:8~1:;__ _
!customer -relations supervlsor. Western

Union, M o e n , New Jersey., -telephone number
exstentio
was telephonically contacted and iurnished the
fol~owing J.n _ormation:
lstated that the normal porcedure to send an

overseasestern Union mailgram was _for the sender to contact
the Western Union toll-free number ,listed in the te1ephone
'director;sr.. -At -that time, the operator normally asks the
sender .for his or her telephone number-. 'the sender of the
mailgrammay bill the charge -for mailgram to his or her
home telephone number, another telephone number, or directly
to a speci-f-ic addre-ss. 'I'he sender then .furnishes the text
of tne mailgram. !l'here are a :number .of _mai-lgram centers in
the United States, one being at the Mailgram Service Center,
Middletown, Vi;rginia, 22645. An overseas mailgram would
be transmitted from the Middletown facility via :radio
communication.
I: the custome.r reguests a conf.irma'tion copy, a
true carbon copy of the mai1gram message :is :forwarded via
the United States mai.l to the sender. 'I'he mailgram under
those circumstances will bear a phrase similar to, "'I'his
mai-lgram -i:s a confirmation copy of 'the fol~owing message.~
'
b6
b7::::
'
!further advised that in the event that direct

testimonya....,.J..,s_r__e..,.q.,.,~uired of Western Union personne1 concerning
the details of the mailgram system_, then the Western Uni.on
Distrlct Manager -in Miaml should "be cont"acted. I
tiden:mfi ed
district manager as
!'telephone nurciber
tb:J
,i.. Miami
1 nvesu~uon on _ _ __..;S~(;...2;;.;;;.0/~8.;;1;...._ 1 _ _ _.;.;M;;;;i;.;;a;:;;;m;;;i;..,::....;F;..;;l;;,o.;;.;;.r;;;i.;;d:;;a:.-_ _
~96A-1056 /)> (,
.All,
bY-----.::s:.A.A~~----------......------~~e 41(tted---::.5t..I.::2~7J../..::8:.-:l=----Yt>IS 4ocuMet>\ (o"tlns l'leitl'ler rtcom-l'ldtloM l'l<>t'C.OI'ICh,lsions of tl'le FSI. I\ Is tl'\e property of tl'\e f'SIn4 fs ro.l'led to yovragen(y:
1\ al\4 IU contents r not to 1> d istril>uted outside your fQency,
7/6/81
~:
SAC, HONOLULU (163-307)
FROM:
SAC, 1-liAMX (163-2547) (RUC)
FPC
(00 aBUREAU)
Re Honolulu letter to Miami, dated 5/22/81.

.
Enclosed for the Honolulu. Division is a copy of an article
from the 6/29/81. Time Magazine entitled Trafficking in Terror
for Libya.
to open a
l:t- is noted that in referenced colllllunication a . request
new !'PC case was not made to the Bureau.
Bureau. is oftice of origin in all FPC cues.

Also for the information o Honolulu, PPC: investigations
are predicated upon a request to the FBl: from a foreign police
agency desiring ~t investigation be conducted within the criteria
enumerated for PPC matters. :rt appears that Australian authorities
have not made such a request.
A. review of Miami indices
waa
negative re the following:
Nasco Arabia, Ltd.

Languis "trust, Ltd. Bank
Miami indices re Nuqan-Hand Bank reflects Miami. main case
163-2191 1 entitled "HUGAN-HAND BANK, PPc, 00 :BUREAU". InvesU-
2 - Honolulu (Enc. l)
C!f Miami
(2 - 163-2547)
196A-l056)
'l'BO: J91D
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(5)
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,.
m( 163-2547
'I
gation in this case originated. at the Bureau and was requested
,by the COmmercial. Crime Bureau, RoyaL. Hong Kong. PoLic.e (lUIXP).f
in April of' 1980.
Miami-'s involvement. was of a secondary nature

The results of investiqa.tion
conducted by the Pl)I. were furnished by the Bureau to Hong Rene;
Legat (file number 55-4) . A. review of Miami main case 163-2191
reflects that the HonolulU: Division at Guam was alsO involved in
this investigation..
'
and was closed in OctOber~ 1980.
b.
Miami' indices regarding

current reference (196-1056-114 , -
ag~
lr~flects a
S) in Miiiiit main case entitled_
sARKTS- GAR{l.VET SOGHANALIAN, dba UNI'l"ED lf'RADE INTERNATIONAL, E'r AL;
J-: VIC'l'IM: FBW; MF; I'rSP: oo :MIAMI.-. This is a major

investigation currently being conducted within the Miami Division _
and it is anticipated in the near- future that Soghanalian wi11 be
indicted at MiaJd on Praud By Wire charges (arms sales)' .
Ma;aad n:_lis.article
to some extent sni'III!Ylrizes
current1y. a fugitive. of, the'
- -~loser 'l'J.me
the activities oL
_
' Alexandria Office of.:the .FB
r----------,
'- I .
Iis
na ura of charges' not. known at Miami.

'
'
-,
known
to
the Miami Office. via road trip
b6
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to Nassau.-1
tan-'American.: businessman, has been residing and.
working in Nassau for: approximately 1~ yeu-s. He is involved in a
variety of business endeavors in the Bahamas. By his own statement,
he is wanted by the securities .Exchange Commission in Washington, D.C.;
however, this statement. has not been_ verified and. NCIC negative .
'
i .
' Soghanalian s whereabOuts curren~y unknown .

1
LEADS
'
' HOUOLOLU
A'r HONOLULU, HAWAII
. 1. Reinte~iev Wilcox regarding knowledge and/or

whereabouts o~
~and f~ish_ same to Alexandria Division.
.
- .2.
ofl
Soghanilian
form.
:n::l
an~
~Tegardirig illegaL criminal activt+-.;

Jknowledge and/or ~hereabouts of
L,-,...,...,.,.----____.
same
Miami main case 196A-l056 inFD-3 2
MIAM!
. I
AT NASSAU,. BAHAMAS '
Wil.L through the Department of Registry (companies)

determine corporate. structure of Nasco. Arabia, Ltd.
'
'
' ,
..
2 . '
!voluntarily appeared .at the' united States

Embassy, London, Erigl~d. and. in the presence of A~sistant
United _States Attorn~YL
1 furnished the
fo"llowing .information:
On June 22, 1981, ~--lturnished the original of

his desk dl
he yea~ A review of this diary
was made i
-presence and note was made of each entry
which
erpreted as _referring to _a telephone conversation
between
in London and .Sarkis Soghanalian in Miami Beach,
Florida.
a1so furnished the :following documents;
~
Carbon copy of letter, September 20, L977, mailed
'.b~L---.....fo _Soghanal-ian.
2.
~elex,
3.
Telex, May 6, lcy{7, from I
May 27-, lcy{7, .from
At~ington,
Virginia to
~----~~confirming availability of .50 caliber machine guns.
.-.._}.{
bG
Ito ".Achievers".
b7C
.
4. .Carbon copy of Certi'ficate de Non-Reexportation,
_August 29, ~977
.5 . Carbon copy of contract, August 29, 1981-.
'
.
On June 23, 198l,~reappeared at the Unitef states
Embassy, -London, and furni~'s desk diary .for 1978.
also provided the following ~ocuments:
L-------....1
1~
Telex to Soghanalian in Miami Beach referencing
197 tripods.
2. Telex to Soghanalian, Miami Beach_, :March 20, 1978,
.referencing. packing for tripods.
3. Telex, February 6, '1978, to "Achievers'.' asking -for

assistance and summarizing efforts.
4.
of credit.
Bank ~ocuments, November 15,
1977; amending letter
tnv,sti9~tron on--6~/2::.:2=..--:2::.3u./:..:::8::1=---t _...:L::.:o:;.::n:;.;d:;.;o:.::n:L,-=En~g=-lan:;;:;:;;.d;:__ _ _ .Fi~ Miami 196A-1056jj&J

./lAd /
b~--&JL_______.f~; .; ;}?. . __ _ _ _~---~tedi<tlt~---6.;;../_29....;/-.8_1_____

'rl'lis <:IIJMOtll contliM ~ither recomrt~en'dtiotls l'IOt Coftelusi<>ns of ~M 1"81, II i$ \Pie 'pro~rty _of the f'SI
it -.no its <:Qntents e not to~ -~li$tribU\ed 9\ol~si<le vowt 9<~'1'1<Y
:.n4 11 ro.ned to yo11 r -. 9 ency:

MM .196A-1056
s.
Letter, October 19, 1977, to Arlington, Virginia,

user certificates.
6.
Letter of charges, January 12, 1977, Banque Bruxel:les
enclosing~and
Lambert.
7. Telegram to Soghanalian at Prairie des Chien,

Wisconsin, February 28, ~1978.
8. Telegram to Soghanalian at Miami 'Beach, February 28,
1978, referencing writ of attachment.
9. Telegram, March 9, 1978, to Miami Beach, referencing
availability .of "197 tripods.
4
10. Telegram, Februa~ 6, 1978, to Miami, requesting

immediate delivery from Portugal.
'The above items are all "being retained as evidence by
the Miami Office of the Federal Bureau of ~nvestigation.
.)

Memorandum
UNITED STATES GOVERNMENT

'
TO
:- ~At-1 ~ ( 1~C?A-tC>5G.~~).
FROM
:- 5ft
suBJECT:-
S ~.~ rs
DA'l'E:-
? ,, I
1&1
s t> 6 ~frr.>fh..(AN
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A ~\e<..J
of'
Rs-:f -t> ...)..
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dis~s.-J ~+ r~ h:ve..- b~t

~bf,A.~ V\.~
~C\lf\ lA. -ft...c.. 6-.r~ ~ ~.s ~ l '(1\...) 'S .....
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.SEARCHED_I~EXED
SERIALIZED__FILED -
JUL l
Buy U.S. Savings Bonds Regularly on the
Payr~ll
Savings Plan
'!
1981
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'
Memorandum
To
FROM
SUBJECT:-

FEDERAL BUREAU OF INVEStiGATION
Skl- 1 ~ (t&t~A-toS\D)CPj
DATE:
I l<f 1
"7 I')
JA
SA-n.~ cS
s Dl.. AArJ ~ ~
~w
~,ty:.-._~
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JUt 1 'i' 1981
Buy U.S. Savings Bonds Regularly on the
Payr~ll
Savings Plan
--
'
---
--
--
----
--
Memorandum

TO
'S'~ 1 ~
FROM
: SA-l
SUBJECT:-
(,
wA-ton;.)
DATE:
~~t:1s
)on~t~
fflv
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\...-{1G.A--~O({e
>
Buy U.S. Savings Bonds Regularly onthe Payrol

,,
.HJL 91~81

!Lieutenant Colonel,
Militar ue
Braco de Prata., .was interviewed in the Poftuguese language
with the assistance ofl ~
_~nvestigator,
uni.ted States Embassy, L~shon, Portugal, who .served as
translator. .A. lso present dur.iFfa the ; nterui ex.r s.zas
Assistant u.s. Attorney (AUSA)L
advised as follows:
~--------------------------~
Portugues~e~A~rm~_y~,~c~o~mm~e~r~c~~~a~I-M~a~n~a~g~e~r~,~:Fabrica
stated that Fabrica ~Militar de Braco de

Prata (FMB~P~)r-u-n~t~i'l approximately 'two weeks agowas
military factory under the control of the Portuguese
military. Currently this faci'lity has become a civil:ianized facility and .is doing business under the name
lndustras .Nacionais de Defesa-E;P. I
!advised that
within the warehouse are stored 300 .so ca!iber ANM3
machine guns. These 300 .50 caliber machine guns 'were
placed under constructive seizure ~Y the Judiciary .Pollee
of -Lisbon, .Portugal, on December 10, 1978. These machine
guns have .remained.in'the same warehouse since they were
delivered to .FMBP prior to December, ..1978, and are in
essentially the same condition as when delivered.
I
lstated that a modification of these
machine guns into HBM2 .SO caribermachine guns,had
been considered in .1978, but that it.had been determined
that for technical .rea~ a modification was not
commercially feasible.
stated that the impossibility of this modificat~on a been com:rnunicated to the
-Lisbon ~firm Avitexti1, which was the firm which had expressed interest ~n obtaining the modification.
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I
!advised that lndustras Nacionais de
'
Defesa-E:P. fiad .no objection .to photographs being taken
by the Federal Bureau of lnvestigation (FBI) of the
weapons in their current location.
on June 16, .l;.98l,J
hurnished to
s~
~--~Ia declaration written in the Portuguese .langu~a~g~e~w~h~~~c~h~~
he stated confirmed the information which heprovided concerning the location and condition of the 300 machine guns
1nvesti9~tton on
l:IY
6L.!S-16L81
s~
~t
Lisbon, PQ;rtugal
llj
~te
f'ne
Cktted
Yr>is CIOCuMel'lt ~ontalns neitl'ler reeornmendatlons I'IOr c:onc:h,Js!Ons of tl'le f'81. It Is tl'le J)ro~rty of tM F61
an.:t .ltJ c:ontei'IU ~re not to be diStr>b~.>te(l outside your ;ag~neY.
i'
Miami l96A-l056-/'f';..
6Ll9!8l
o~~nd
is lOaned to your a9eney:

MM .196A-J.056
and the attempt~d modification. 'l'his decl~ration is being.

retained as evidence by the Miami Office of the FBI. ,
'
- 2 -
'
.,....._
f! Fe>-302 (REV. 3-$77)
""\
~t of transcription
,6 I 19/SJ,.
'
IMajor, Army of the Islamic

Rep:ubl'ic o.f Maur1.tan1.a, was l.ntervie'i.V'ed at his gove.rnment
office :in Nouakchott, Mauritania, .in the .French language.
Also present during the interview were Assistant u.s.
Attorney CAUSA) I
US AID, U.S. -E:mbL...a-~-s-y-,--:":.N:-o-u-a....k-c....h-e"""t""'t.---,"""M,...a-u.r-....i.,..t_a_n_l._a_,-w"""h_o___,..s_e_r_v_e_d______J
as translator. Present during a portion of the .interview
wasl~harge d'Affaires, Emb~ssy of the
Uni~ed Sta~es, . Nouakcn~tt, Maur_itania. 1
~furnishea
the ;followl.ng ;I.n forma t1.on:
.. I
!currently occ;upies the position of_ .
.
Controlleur General D'.Etat, w1.t h the government of Isl.am1c
RepubLic of Mauritania, .and :formeily was Minister of Equipment and Transportation.
nur.ing the y.ear 1977, 'Mauritania was involved
1n .fighting a war against Polisario ~uer:r.i:llas in its
.northern provinces. ~he Mauritanian .Army had an urgent
:requirement :for machine guns during that period of time.
The Mauritanian .Army .had been engaged in continuous fi9hting
since December, 1975.
.
The Mauritanian Embassy ~n 'Paris advisedl
at some point durira l977. that a supplier of machine guns
.had been located. _
kas ad;zisecLthat :ris .supplier
was an Englishman by the name of[:
These machine
guns were to be
.so
cal~ber ,B"jwn:n~;bjavyarrel
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machine
of new U.s. manufacture.

stated that .so :cal"iber
:Browning machine guns were des1..re s1.nce Mauritanian officers
were fami~iar with this type of machine gun .based on their
training with the French Ar~y. .It was des~rable that- the
machine guns be of U.'S. manufacture since the Mauritanians
:~new or believed that .Browninkmachine CJ'uns. were manufactured
1.n the United States .. !
_was q~estl.oned as to why new
machine guns were re O:xrea ra er than new or refurbished
machine guns.
epl-ied that .his country-'s soldiers
were dying on t e attle field and "one takes .Qnly new
weapons to the battle field'' I L
!reiterated that under
no cir~umstances would the Mauritanian .Army have been ~atis
fied with anything other than newly manufactured machine guns.
guns.~
Nouakchott, .Islamic
of Mauritania
lnve$tf:9~tton on _ _.6""[-.9~..,/..;;.8.;:;l_ _ _ _ ~tReEubi'ic
bY _ _ _ _
l'l'lis
f'ile~iami l-9.6A-_1056 -1'/:J
--.;S~A~!________tlk;.;.l:;;.J"'-'------lOate <liCtft~d---6~/..;.1;...5-./..;8..;;1;___ _ __
CIOC'Imet'lt contlns neittter "comm~n~tions nor con<:lusions of tl'le F61, It Is tl'l' property of tl'le F81 nd Is 10fne4 to your ~ger~cy:
"' not.to b' o;listribute<l outside y0 ur gency,
l.t ~tl<llts <:ont~nu
..
.M.M 196A-l056
Sometime during the summer c o

in either
August, 1 977., to -~he best of
recol;lection,
jwas 'i n the United states atternp 1.ng to procure -military
equ1.pment other t o 5 0 caliber -machine guns. ;While in
the united states,
received a signal .from - the M~uritanian "Embassy ~n _ ar1.s 1.ndicating that he was ;to meet[
I
I
~in Wash~ngton, D.C., and ~roceed to mak~ a ~iewing
of weapons wh1.ch ~ere to be dell.vered to Maur1.tan1.a.
Julv
mr
Subsequently.,!
~arkis
Soghanalian and a~ assohiate of Soghanal:.l.'ans, "Bl-:11",
in Washington, D.C. ~hey spent one night and the following day left :for_an arms _ p~ant .ip -:he nqrtheast~rn
United States. ~o 'the best ofl
T
Jrecollection,
they flew =to this arms
pr1.vate ~harter or privately owned aircraft.
did not :recall the name
of the plant but stated 1. was -located somewhe_re in
.a wooded setting - and was only a short -flight .from Washington, D.C. They were met at the plant of-f.ic es -by several
_people who were employees of the plant.
!conversed in French with Soghanalian and

. questioned. Soghanau -an about ,the machine guns in question.
Soghanalian :indicated :to ,_him .. that this particular arms
plant was producing . _SO - ca'l~ber machine g uns- ~nd that the
machini auns dfstined for Mauritania woula come :from this plant._
_and Soghanalian discussed the rate of .manufacture of the FaChine quns, the delivery dates, productjon
schedules, etc._
~ Jclearly understood ;rom ~e con~
text of his conversatl.ons with Soghanarian that Sogh~nalian
was, in fact, the supplier of the machine guns and that .
-hine guns were coming :from this particular factory.
stated that they re~'!rained at 'th~ plant :for approxiY one .to two hours. While at the plant,l
~aw
being . manufactured, tripods and new spare parts.
understood -that -the production schedule cal-ied :for
ivery of 200 machine qpps wj t:in two months. aoth
Soghanali an - andl
j of the above delivery
schedule.
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0
0
I
!.further adviseathat in addition to
Soahanalian and Ralpn.', a Frenchman .by ,the name of
.
r-----,...~,.......,~~1- was present on the trip to the :arms n')ant:
.___ _.....lexp.lal.ned that Sigaignon andL---------~------'
I_;
- 2 I
l--~--------~------------~----~~~----------
MM 196A-1056
were 'the ..intermediaries who had brought the

-Embassy :in -Paris into contact with ~...I
Maur~tanian
_ _ _ _ _
___,J
I
stated that after viewing t~e weap?ns
he a've arms plant, he,l
1Soghanal1an, and
eft and went to ohe or possibly two more arms
,: :c:oro.1e . _
a going to the Boston area and
observing weapons.
had no ,interest :in any of the
weapons he observe a er eaving the plant ~here the
.SO caliber machine 9uns were apparently .being produced.
However, Soghanalian :insisted on displaying the additional
weapons, which c o c f , among .o thers, possibly M-_16
and M-60 weapons.
recal-led that after they .left
the :Boston area, t ey returned to tbe New York area, and
thereafter took a plane to Mia.mi.l
!stated that his
government was also .interested in obtaining 30 caliber
machine guns ~n addition to the .50 caliber ~achine guns.
Once :in Miami, Soghanalian stated that they could view
30 ca~ib;; ma::~:e 9uns i~ Santo Domingo. .Acc<;>rdingly,
_ -.
__ JSoghanal1an went to Santo Dom1ngo.
r------ht:-:o~~e::-Jbest o1
l r e c e : J 'n, returned
to ParJ...S rom Miami. :In Santo Domingo
observed
.30 caliber machine guns ~hich were wa er coo ed and of
1917 vintage. He also observed that 'the ordinance ,for
these weapons was outdated.
stated that these
weapons were o_f no .interes
aur-itanian government
because they were not new.
advised that he made
this quite clear to
oghanalian at the time,
emphasizing 'to them
at on y new weapons were desired.
so_g hanalian wanted!
to p r o c
ew him to Venezuela
to .look .a t addi tiona! weapons, :but
dec1.ined to do
so. From Santo Domingo 'they -returne 'to Mi'ami.
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Mi;m;
bile in
I
!dined at Soghanalians
hamel
I
r:recallea .t hat there
were a n
er of peop e present, including a' Cuban
physician who had played a role at -the behest of the
United States ~o:ernm~t in the .Dominican revol't some
years earlier. l _
--~ecalled a s
t y known to
him as "Coco" an ano er .female.
did _not _recall
the name of the second female.
was asked -if the
name I
lwas -famiiiar to .him.
stated that this
was possibly the name of the other - ema e who was 't-lorking
at Soghanalians .residence.
3 -
l ----------------~----------~------~--~
MM l96A--l056
Subsequently ,I
left Miami
together for 'Lisbon, portugal, where they viewed 81
millimeter motor rounds. Soghanalian was originally to
go to .Lisbon with them but subsequently cancelled his
travel.
t a Portuguest h~ the
believed that
I
-~an s represen a ~ve in Portuga
I
I
~iewed certain 81 mi1limeter mortar
Iounds together. Subsequently, an agreement was entered
-into ,for the purchase of these mortar rounds. The Mauritanian government subsequently purchased 5,000 of these
mortar rounds ~hich were del'ivered to Mauritania.
name of
was Soq ana
I
!advised that subsequent to his tr-ip :to
the United States, :a contract was si:ned between the
lat the Mauritanian
government of Mauritania andl
Embassy ,in .Paris I
!stated tna t e actual negotiations
concerning the contract w~thl
land the signing of
the contract were not within .h1s purview and he had no
direct involvement with the contract -itse~f.
I
lstated tbat as time began to pass and
no machine guns were de-livered, he .began to ,feel more and
more that the display o'f the weapons in the U n i t e d s
was a mere sham. In approximately February, 1978,
was dispatched by his government to .Paris to contact
to try to determine why the .machine guns had ;not been : eJ.ivered. Subsequently, . f r c aximate1y February 8
through February 21, .1978,
was either -in Paris or
Lisbon t't'ying to follow up on e non-delivery of 'the
machine guns.
On or about .February 9, 1978 ~
lcalled
Soghanalian :from the embassy :in Paris. 'I'h1S telephone
call was _placed to s:ghanatian who, at that time, was
in Miami, Flor-ida. 1
inquired of Soghanal-ian why
the we~pons had not een del;ivered. Soghanali'an replied
that the weapons were currently tranfiting ,rtugal and
that .some problems had arisen there.
asked
Soghanalian -to .go to Lis-bon as soon as poss1. le to ar:range
del'ivery of the weapons. on or about February 9,
,1978,
went .from Paris to Lisbon to .meet Soghanalian.
At Lis
was told that Soghanallan would not .be
6
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~.
~.
'.
MM 196A-:l056
able to meet him :in Lisbon

"Bill" had died in an
airplane accident. .Instead,
was met by I
who could not or would not a Vl.Se l.m where the~w~e~a~p~o~n~s=-------'
were stored. Subsequently,
told him
weapons were stored with -the or uguese Navy.
then
went to a Navy warehouse and observed about 3
oxes of
new weapons. One of these boxes of weapons was open and
~~~~o~b~s~e~r~ved a new .SO caliber machine gun.
At this
had become extremely suspicious because he
questl.""'o"""n"""'e,...,.......,-1.,.-,!n his own mind why the 50 cal-iber machine guns
would be 'stored .in a Portuguese Navy warehouse when, in '
fact, 'they were to have come from the United States.
Nevertheless ,I
Icontinued t: g:e:;ion I
about the delivery of the machine guns. lwoul'a...d.--r~e~p~l~y::---'
only that there were a thousand and one
" jh~gi
~be
done
.before these we~pons could be delivered.

returned
to Paris and shortly thereafter came back aga n to Lisbon.

Soghanalian arrived in Lisbon on February 16, ~978.1
I
told Soghanalian on February 16, "1978 1 that either ~o_ghanal:i.an
had-the weapons or he did not and that :if he had the weapons
they should be delivered immedia tely. Soghanalian replied
only that he had to 90 to .Madrid to handle an administrative
mat:er. sqghanalian left subsequent to that conversation,
andLT
Jfound out that Soghanalian did not go to Madrid
but 1.nstead returned to the United States.
I I cted,at
with Sogha~
"for rea~iny direct
w~
ro
he had no cfurther dealings
advised that his only
Soghanalian "insteaa "o f
as
that
appeared to be "scared stiff" of conta c ;.ng
Soghana l .an. :B_y .Febru~ry, 1978t the Mauritani~n Army was
desperate .for the _xna7h1.ne. guns._
lemphas1.2ed that
there were people bel.ng kl.'lled n hl.s .c ountry ever_y day
and the need .for these machine guns was an immediate one.
I
!recalled making one .f inal trip to Paris
.i n :February 1 :97lt. He tried to withdraw 'the funds which
.Mauritania had paid for the weapons but determined that
the Credit Commercial de France had already transferred
the funds.
Subsequently,!
lwas advised by the Credit
commercial de France that Soghanalian had submitted
.fraudulent letters of transit indicating that a certain
- 5 -
- -
-------------------------------------------------
b6
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MM 1.96A-1056
aircraft had the weapons on board. -I t was I

Iunderstanding that this letter .o f transit and other documents
had been used by Soghanalian to obtain _payment -for the
machine guns.
ladvisea that his.gove~nment had conside~ed

var..1ous way13 to .recoup the money l.t had lost on the mach..1ne
d a'l, which amounted -to approximatel:y 1.6 million do'll-ars.
stated that his government was told by the Credit
omme cilll de .france that the only ray he crula get its money
was to go to arbitration ~n Geneva.
stated that
this was an expensive proposition f r a government with
few resources and a nation of starving people.
was asked i f the question of accepting

isned or xnodified machine 9uns had ever ar.isen.
:responded -that :in February, 1978, ;in Lisbon,
g
alian had brought up to .him the guestion o_f furnishing modified machine guns. I
I stated that he
told Soghanal ian that rnodi.f ied or refurbished machine
guns would absolutely not be acceptable to the government
of Mauritania and that -they had .t o have new macbine guns
as _c al-led :for by the contract.
o.
de.livere
~stated thaf no machinl guns were ever
by Sog anal-ian or
to .Maur:itania.
did subsequently t..1nd some machine guns .from
another source, but this did not involve a commercial
contract.
~auritania
,I
At the c onclusion of the .interview

furnished a -Xerox copy of a trlp .report which he wrote
concerning his actlviti~s .from the 8th of February until
the 24th of March, 1978.
6 --
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__ f.0..302-, (REV, '3-$-'1 71
.. -
'-b
O.te of tr~nser1Ptlon,_ _.J;61.J./:...42u61.,/./:...18J...1a..__
.Portugal,
!advised that he .'f-irst met Sarkis
Sometime during .1977,
So9hanalian contacted him in .reference to obtaining
,wea:~ns for "the country of Mauritania . At no time did
I _ !possess or purchase for S o g h o ny new or
use BBM2 .so caliber machine guns.
did become
involved .in the. purchase of 300 ANM3 surp us aircraft
machine guns from the Portuguese Air Force.
Soghanalia~-n--s_o_m_e~t~ime uuring 1976.
~~~--~!advised that Soghanalian had .read about

the availab1Iity of 300 ANM3 machine 9uns ~n a lis~ng
of surplus defense material publ-ished by the Portuguese
military. I
I accompanied Soghana1ian to a mi1i tary
warehouse where Soghanai-tan observed the .machine guns and
picked them out.l
Iadvised that Soghanalian paid
.for the JOO ANM3 mach.1.ne guns with certif-ied bank checks
p~yable directly to the military.
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At that point dur.ing the interv-iew,

was shown a check dated oecember 21, 1977, in the amount
_of $641,787, drawn on the .Irving Trust Com:anv. :ew York
City,' account of Sarkis .G. soghanalian.l
Jadvised
that he recognized this check as a check w ich Soghanalian
~im at the 'time of the purchase of the machine guns.
~vi~ed that the Portuguese military would not
cept j l.S check or .any personal check, and therefore,
~
_returned this check to Soghanalian. I
I was
- ::en as ed specif.ically .if he had deposited thls check
into a bank known as Banco PoVu1ar -in either Madrid., Spain,
or .Lisbon, .Portugal. I . .
Jdenied having deposited the
check or otherwise hav.1.ng ne9otiated it at any barik whatsoever.
I:::: :a
I
1 n~t~~uon on--~6.L./~1~6.L./~8:.=1.____ 1
'Lisbon, Portugal
f'il
Miami ., 96A-'J 056-
.PO/
cy...;__ _ _ _ _
.::s~A~~--------~~....l..;j_____o.te c:uet~ted. _ _ _6~/c..::.2.:::.2/t..:::.8.:l_____
T,.lS <lo<:ument <:ont~lns neitnet reeomtnendtlons nor <:onelusions of tr>e FBI, It rs tr.e proper_ty of tne FSI n4 is
it ~nd Its tontents re no~ to 1>e distribUted outside your ~geney,
lo~ned
to your ~gen<:Y:
1yj
q
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t:
i.
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MM .196A-1056
~---:____.~further denied any :knowledge of Soghanalian having
'
deposited the check.
!advised that after the 300 machine guns

had been p'":a:-:!1"":'dr-.~f~o~r~, t;hey -wer~ del'i vered to the military
;actory in 'Lisbon :known as -Fabrica Militar de -Braco de
Prata -(FMBPh 1
l~avised -that . under portuguese -law,
all weapons of th1s type .must remain 1n military warehouses or :facil'ities even though they -were purchased ~y
a commercial concern
.Actin_g uncier Soghanalian' s -instructions,~
attempted -to coordinat;:e -'t he modification of these :
ANM3 machine gun~ to HBM2 standards. Subsequentl~,
was ~nformed ~ by FMBP that the modification could not e
done.
:e:ter
~was
~y
then shi:n "a

jigned
Brigadier
Sous~ de .F~r-e~1~'r_e_,____.addressed to~=~ which stated in
the Portuguese J.anguage that ~e mo 1 .1 cation of the -ANM3
h
guns to 'HBM2 machine guns was not ;technically _possible.
advised ~hat he recogn~zed this lette~ and stated
merety conf-irmed what F~P :had verbally a5lvi~ed hlm.
added that :it was his understanding that FMBP .at first
at rthe modification was possible, but then later determined that it could :not be done.
l:further advised that 'in .a ppx:oximately

February '=o=r-M~a:-::r::-:c:"th:::-', 1978_, So_ghanalian <;ontacted him and
_requested that he arr_a nge a viewi~g 'of certain HBM2 .50
caliber machine guns 'located ;in a , Na~ _warehouse :in !Portugal. Soghanal'ian diq not -tell -him the _purpose of the viewing. Soghanalian .had a pparently learned of the avai'lJ:o; tv
of 'these weapons by reviewing a commercial brochure. ~
a rranged -the viewing and accompanied Soghanalian to t
warehouse w~ere the we~pons were observed and one box of
. the weapons was ?Pen. T~ere were ~ther people ,present at
the viewing, -butL_
Jadvised he did .not :recall their
~dentities.
'
sho;n :
1
lwas
a ~ett;r dated :1a December., :1 97.7-,
.bearing the signature
I addressed to
United !l'rade Internat1ona T isetter was -in -the English
ianguage and :it confirmed that 197 .50 caliber HB machine
, I
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MM 196A-1056
guns were being held for United Trade International in a

military warehouse ;in t.isbon. 'l'he letter also states that
the weapons would be shipped -immediately upon receipt of a
"renewed export Hcense "for ship~nt
;1e i terns to the
:xslamic Republic of Mauritania.
advised that he
:reco:nized this Qetter and recal ed av n9 signed ~t.
~~~~~laavised that-he does not .read, speak or understan-tile English language. !I'he J.e~ter was com sed and
written by SoghanaH.an and was typed by
secretary.
Soghanalian, who speaks some Spanish, as does
~~~~~~~~~~ter :from-English to Spanish~o~r~_a~~y~_~o~r
advised that ,in :his mind tbe -1,97 ~pieces"
~r-e__
e_r_e_n_c_e~~~n~~~
were part of the 300 ANM3 machine
, guns ,-which he,
':lnderstood would 'be modijfi:d
HBM standards . _y .
Soghanalian explained tC1
that. the .letter shoqld l;?e written in .English in or er o
expedite the:movement of the guns out of FMBP.
:f
t:
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lwas asked if_ he had any kx:owle_ge. of' any

weapons or~~m~u~~~l."'Tt~l.~ons or other .defense suppll.es :havl.ng been
shipped from Portugal -to .Libya, or Nicaragua .by or at the
behest of Soghanalian.l
!denied having any knowledge
whatsoever of such a shipment.
-
TP,is interview was initiated withl

tat
4:l0 PM after a discussion withl
1
attorney. At approxirnate~y 5:00 PMI
!attorney
advised that the interview would have to be 'terminated.
-The interview was teJ;ininatedat 5:00 pM andl
la~a
:his attorney departed the offices of the O'u~i~.t'ary :Po-lice.
approximate~y
' ~
'L
7/1/81'
.'l'o:
Director, FBI
From:
Legat Rome
(196A-40)
(P)
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ReMiami alrtel 5/11/81

.On
7/1/81 American Embassy, Ankara, a dvised that on
6/24/81 Dr. Riza Turman, Director, Department of Maritime and
Aviation .Affairs, Ministry of Foreign A ffairs (MPA), Ankara,

_provided the foDbwing i nformation from MFA files:
an l/23/80 a Boeing 707, white -in color and bearing

.Zaire !rail Number 90CRY or 9QRCY (variously shown i n the files)
requested permission to fly at l ow altitude and 'to lllake an
emergency landing at Ankara due to failure of engine number four.
-Permission was ciranted and the aircraft landed safely at Esenbog'a
Airport. P.reWlusly, the aircraft had requested pexmission to
overfly Turkey advising .that it was coming .f roa Sharjah, united Arab
Emirates, and destined for 'Luxembourg. 'l'he occupants of .the aircraft,
wboae :ilmnber an4 identities are not contained in the file, departed
.the same day via Lufthansa for an unknown destination. This was,
, apparently, after Turkish officials found no contraband on .b oard the
aircraft.
Upon exud nation of the ~ircraft at Eaenboga by Turkish

mechanics, , an oil leak was discovered and the '.turkish authorities
requested that the Government of Zaire pay 'the repair expenses. It
was learned at this time that the aircraft was a pirate as Zaire
notified Turkish authorities that the aircraft falsely :bore a Zaire
registry number., (Turkish authorities had been notified in ~0/79
.
by Zaire that certain .aircraft had falsely used Zaire reqist.ration~G/pr.JG
numbers. -Z aire authorities asked that all such airC:~i:t;j:hat"=1m_Bmt
--- :
land at Turkish airports be grounded.)
~[:\.,,L ,t_o:::-c;:;,.L,iO ...,
4 - Bureau
G[)-
Miami l96A-1056
l - Rome
LJP:mcm
(5)
JUlt t1 1981
ROM
196A-40
. - .rurkish _o fficials found llO trip or maintenance <logs

on -the aircraft and .proper - egistration and airworthiness
certificates were .not on board. Maintenance -and operating manuals
were located as were c e r s that showed the aircraft used
'
rom 5/17/78 .to 8/15/7.9. MeteoJ:Ological
.registration markings
reports show a possib e g t from .Bombay to Sharjah to' Luxenlbourg.
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A further details search ~of the aircraft by 'rurkish

Customs oficials was conducted on 4/24/81. ~his search disclosed
no evidence of contraband, contraban4 containers such as gun cases,
or scratches on aluminum surfaces. Three oxygen tubes were missing.
~he interior passenger compartment was stripped of seats except four
.The space was divided by .wooden partitions 90 centimeters liJh. Small
doors allowed ~ccess through each~artition._ Dry animal excrement
.was found on the floor along with animal. hair belonging to sma11
headed animals such as goats and sheep. A "locked compa~tment contained '
five pairs of trousers, , three shirts, six cans of .beer, .one Honda
generator, sugar, coffeeJ one .small table, one chair, one oxygen
tank and two inflatable ~afts.
The aircraft was found tQ :be in good condition except
for enginasnumber .fluee .and four and bore no signs of sabotage.
Enough fuel was on bqard to complete a light to Luxembourg.
,
The aircraft -i~ parked at Bsenboga Airport and i s under
t.he jurisaict:ion of the .Ministry of Justice.
:,
MFA files contained a .c~py of an article appearing ~n

International, a 1 2/27/80, written ~by,l>avid :.Lermount-, which
supposedly is a history of the aircraft.
,
~Flight
Inquiries continue.
- 2-
. r
TO: SAC:
(Copies to OHI~ .. s Checked)
Routing' Slip
0.7 <Rev. 5-28-80)
---
_'1~
~
,....,.\
TO: L_EGAT:
c=JB~rn
CJ
Bogota
BOt'ln
Bu~nos Aires
Hong Kong
London
Manila
Mexico City
Ottawa
Panama
P$tis
Ro~
8 Tokyo
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Remorks: ~('['\'.:)
C.O?t~
<:::>~ C).
~ 0.\\\B\ .
SU.~CHf.O _ _ _..,INOE.X.0------t
SEf\IAlll0
flL0-------1
Ene.
JUL 1 0 1981
Bufil_e
U:rCile
F&l/00.1
Memorandume
S.\C, !L~IAIU ( 199-293) ( P)
To
J
Fr~
:
!
I I
Su~jt :
AIDlENIAN TERRORISM MATTERS

FCI-TERRORISH
JS LOS ANGSL~S AIRT.EL 10 DIRECTOR .DATED 5/21/81., CAPTIONED

AS ;\I30VE.
.
II
For the information of the X.UAl.U files, on 7/7-8/81 attempts

to loc te and intervie\nT either
ArnaG :30GHANALIAN at
l'l'let "ttith neg:)ti ve
resu ts. W3S ur 1er ascer a1ne , rom a gardner who was
working at the SOGHANALIAN residence, that the "owners were
vacationing out of the country .and have been for some time."
:s t;
On 7/8/81, a telephone call

made
sajHANALIAl!'s
residence
t:e pumberl_
_in an effort to
contact either
~ARK IS' \"'lth negat ve results. The fen::tle
who did answer t e p one advised that both of the brothers were
currently unavailable,as they were vacationing out of the country.
~fuen she was advised that this caller was furnished this number
through a mutual friend, and instructed to speak only with one of
the brothers, she stated that they \"'ere currently in Svtitzerland
and that she could contact them should the need arose. She further
advised that she is unaware of any date that they rn.ay plan on
returning to their residence, or even how long they plan on staying
in .Switzei?land.
utilfzi:g
This information is bein furnished as a matter of record, and

for whatever action is deerned appropriate.
G~C/gec
2-71IAHI
.1-( 199-293)
<1!7(196-/0,S"p)
JUL 8 1981
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J:?uring the. course of,:investigation conducted at

'Pabr.ica Mil~tar de Braco de Prata, Lisbon, :Portugal;
I photlgraphs were taken by ~pecial Agent (SA)I
_
of certain machine guns which W'ere .iden~t~J.:~f~J.-=-e~d"""T:"y::-:-r-'____,
employees of .Fabr.:ica Mi1itar de Bracode Prata as the
300 _:AM.MJ 50 caliber machine ~uns p}..aced ~ndex;- constructive
seizure by the Judiciary Police in Lisbon, :Portugal, du~
ing 1978. A log of
made ~y A~sistant
u.s. -Attorney (AUSA)_
_ __ ~ ~
~hese photoraphs
an~ th~photograph ~og are e ng-ma1nta1ned as evidence
h~ the .Miami Office of the ~eaeral 'Bureau.of investigation
rhese .p:o;oqraphs waj

T-
(FBI).
..
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lt'l~ti91tiOI'I on _ _ _...6/.._1_5.;../_8_l_ _ _ ,t _ _-L_i_s_b_o_n___;_P_o_r_t_u....g::..a_l......,___ f'ile. Miami '19 6A-'l05 6 ....

AA,
bY.;._ _ _ _ _ _
s_A.._I_ _ _ _ _ _ _ _ _
_..b.... ~----....cn~e ol(t~.te<l _ _ _6_1_1_9_1_8_1_ _ _ __
This.Qoeument c:o.,tlns neither re<:ol'l'lrt'let'l<lltiOns 'rlof c:on<:lusio~s of the f'BI. lt is the

,it 1n<1 itt contents ~re not to t>e distribute<! outsi(le YOUI' oei'I<:Y
Prot~ert)l of the f'BI 1n<1ls lot'le<l to younagei'I<:Y:
I;-
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AIRTEL
7/9/81
TO:
SAC, ALBANY (l96A-2~)
FROM:
SAC, MIAMI (l96A-l056) (P) ,
SUBJECT~ARKIS
.
'I
UNITED
a.
SOGHA}tALIAN, .DBA
TRAllE
INTmNATIONAL;
_VICTIM
FBW; MF; ITSP
b3
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(00: MIAMI)
'
' Re Albany airtel to Miami, '10/17/80.
Enclosed for Albany are the arhrinal and one

a Federal
Grrd
Jury
aubp~~ena .fo~.....----:-,- - - - - - - - - - - - 1
LEAD
ALBANY
AT WOODSTOCK. NEW YORK
I.
cony of
...
'Oat of
tt~nSriPtl~n_...;7...;/...;~;.;'()....:../_8..;.1_ __
!secretary, Gonzalez Brothers

M~ri~e _cons~ructl.on, :Incolporated. ] 77:3 -~ .w_. 20th S_tree~.'
Ml.arnl.J F1orl.da, telephone.
.Frov1.ded the .follOWl.ng
'information:
-A .review of her company's -records aisclosed a
deposit sl-ip .for the -company account at .Republic National
Bank of Miami refl!'ctinl a :s;so~ deposit on :February 3,
1-978, for "Mr. Sarkis". _
_advised there was no
contract folder .for the wor
one in .return :for .the $5,500
deposit, indicat)ng t:e jib was completed prior to
Januar:Y '1, -197.8.

expla:ined that .her company 1 s
:cont-ract ;records are . estroyed after three years .
.------l...l...LL.L:.X;.at;;:.L.....Q,U.l..1.~U,_~t:., .had consul tea with

the company
in reference to
the above deposit..
a vised her he :recal~ed that
the work per_forroed cons1..ste of the construction of a, boat
dock at the ;residence of Sarkis So hanal:ian. l'he work
was performed in l977 ana
had considerable
diffrcn] tv in obtairring payment.
furthe.r .advised
th~t _
speaks .no. English.
,I
At 'the conclusion' of the ..interview

urnished a xerox copy .of the February
,. 3 depo~s-1.~t-s~I~-p--.~
be
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I'
lnelti9U~n
1))'
7/l0/81
Qn
Miami, F;lorida
"Fir..
Miami 196A--l056 ..-/yi.
fy,f)('\-/
sAl
l:!lb
Oate <lkhte<l
7/10/81
'This <IO(I.II'r>ent ~Qt'lttlns neith., tQmmen<l,tlon$ f\Ot' o~l<,~siQns o f the f"SI, It is the Pt'QPty oft,. f'BI -.n<IIS loned t,Q youf ~~tn<:Y:
i'
tl'ld Its ~tel'lts
~re
nQt
t.~ ~
<listrjl)l,lted
outs~
yout tgen<:y,
Memorandum
TO
=-
FROM

FEDERAL BUREAU OF. INVESTIGATION
5/r(, ~ { ,Cf~A-\ ~~x, J
~1
''\
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f7(,A,fd!~ -/n;
SEARCll.e'~'\'DE.t;,o.
""'"'D
-
SEJU~U7"'1'
~-
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I
~~
.- (
'~'""1(>)'-e
11, '--
~\_../
.rm lS l~ijl
Buy U.S. Savings Bonds Regularly on the Payr911 Savings Plan
AIRTEL
7/15/81
-1
DIREC'lOR, FBI (A'l'TN t WHITE COLLAR CRIME SECTIOr
swmn&ml~--------~-
FROMs
s.Ac,
SUBJECTs
SARKIS GARABET SOGHANALIAN DBA
MIAMI (l96A-1056)(P)
J ~~ATIONALI'
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(OOs MIAMI)'
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!I
Re Bureau teletype to..Miami, 5/8/81
During the period June 7-24, 1'381, ~rJ

(Miami Case Agent in instant matter) and AUSt.i
southern District of Florida, travelled to th 1iU8Jilc RePUDiic o
Mauritania, Lisbon, Portugal and London,_ ~and to conduct"
interviews and. gather documentary evidence tn this investigation.
All ot the investigative objectives ot this. travel were achieved
and essential evidence was gathered which could not have been
collected in any othen.anarmer.. Based on the auccesatul_
accomplishment ot the objectives o! travel to the above countries,
it ia anticipated an indictment will be returned on 7/22/81.
It. is noted that a number otu.sasta

-Departmtt
personnel were J.na.trumental in aas1st1ng S
d AUSA
in arranging travel to Mauritania and in con uc
inves gation
both Mauritania and Portugal. In each case, these individuals
~Bureau
(Yo Miami
HAL~
~-
,......
,'
'
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~ . ~to.~.""~~
, . . ..,!,' ..
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f .. ..,.., .... ~1""f:;
,.:....
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J .
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"" displayed a high degree o~ p*ess1onl1SIIl and vill1ngfteas

,to. assist in every wayposaible. Without the :tu11 cooperation.-
j.ot these personnel; the !ull investisativ-objectives ot
-the travel could not, have been achievfd. Accordingly, it is
requested. that approp.riate letters ot appreciation bear.lng
the Director .signature be prepared and forvarcled through
ot.ticial channels to ;th u.s. Department ot State. 'l'hese
State. Departaent personnel are listed below along .with a
brie.t narrative describing_ tb~ assiatancthey rendertdl
to
lcountry Officer
Countries, u.s.
: DePartment ot State, Vasbirlgton, D.C. .
Coordinated travel.
Mauritania. Assisted in
eatabllahing contacts vith '
Mauritanian Government
o.t.ticials who are witnesses
1n the inveatigation
L........:::t:-o-r"""~~W'=""e-s"T"t-ern--:S~abr-e,i
,,'
.I
leountry
. officer tor Westem Siliel" Countries,
U.S. 'Dept. ot State, Waah!ngton, J).C .
t
'
r----------'------,
,.
L.. -""""O"""X.. . . ,.W,_W,_st_.. . .AX,....r,...,lcati,.._.-Affairs,

_
U.S . Dept.
o.t State,
' s
u.s.
I Charge
Performed a variety of
"leg work*' tunctions, such as
obtaining a
Yaahington, D.C .
' .
.saae .tunction.&' as
!secretary Office
,,
P.rfnrmad
Embassy. Nouakchott, M'auritania
'
Mauritani~,visa
tor case agent..
d 1 Aftaires,
b6
Used his official. and

personal 'c,optacta to gain .
cooperation of Mauritan! en
Government officials. Handled
lodlinc: and trinaportation
_an-aq8Jie4ta.
bue.t, u.s.A.I.D.,
L...-.....
u. . .s. . .-Wi=a=.s=ay=,-N'"""o\iik,.,..,....,!chott, Mauritania
.
~
Served' aa interpreter tor

case agent. Alao providedvaluable baelqround on
polltical situation 1n
Mauritania aiJ\;well as
ita customs. ap..d
,rorea~
~ .' J ~
j_
'l
'
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---
...
.,
1-
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MM 196A-1056
served u
. . I Officer. u.s.IErlbaisy
Regional Security
,_ Lisbon,
. Portugal'
cooperation ot- Pol#lgeae
'
. u.s . Bibiisy,
b6
b7:::
ldlitary. Also arranged: .

lodli!ll- and transportation;
,
IInvestigator,
Fore.tp.. national employett .

.-{)t u.s. stat Dept. who .
. served "as translator and
Llabon, PortUgal .
ua!~tLto
..
liaison with
Judiciary Police, Lisbon,.

and certain Po~ae

GoVernment agencies.
. . Instrumental 1n achieving
caa agent.
if.
...~-_
. It .ts requested that the -Bureau furnish Miaal- with

copies ot the above letters ~or information purposes.. . , "
,
,,
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A - /O
sEARCBED
a-- /~-..3--'
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SE1\1AL17.'!:'~f" " 0
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JUL ?. /i. \~tSl

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'
~anslation
of article
~E
~ ..
~~ '
I
SOIR dated 5th May I98I

I
A BOEING 707 SINCE 16 MONTHS AT ANKARA AIRPORT !
------An old Boeing
.,
~(
707 abandoned at Ankara Airport were it have

sudenly be found although he was not moved for I6 months l
T6is is the only "proof" left over by the person who left
, the Boeing there and made a profit of I,I55.000 us DOLLARS
,"$'
!I
I,
!
L
The affair of the Boeing is very complex and this is why the
Turkish authorities refuse to made any ~omments.
It all start in the evening of .the 23rd January I980 when the
control tower of Ankar'a Airport had to give permission for a
landing emergency to the pilot of a plane who left from Larnaca
for the Luxemburg by the say1ng of the pi_l ot - who also says
that two of the engines of his plane has suddenly topped '
when he penetrate into turkish air.
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The pilot who , got off the boeing after having been the same day at
International Airport' of
nrod"""' ro the authorities
a passport in the name of _
_
.
,
rsenboao
He assured the authorities that he will be back very quickly

and disapeared!
a'.representative of
'I
It is only on the arrival a few weeks ago, of

the
FBI having a search warrant of the court of Florida, that the
Turkish authorities recognize the unusual long stay .of the Bo'e ing. .
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A WELL ORGANISED FRAUD

The affair.of the Boeing if we are lead to believe the American
comments in the Turkish c~pital, can only be considered today,
as a well organised fra ud with multiple changes in many different
countries.
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The story--started' in I977 when the Government of the Isla mic Republic
of Mauritania - as per their saying - wanted to acquire from a
British specialised company named. BOCCA INVESTMENTS, in Jersey,
200 .SO machine guns available from the USA.
From the same sourc~ of .information, :it seems thatlL-.....-----=-----~
president of BOCCA INV~STMENTS, has requested an american C ompany,
\
th~ "UNI'I'~D TRADE INTE~ATIONAL' in Fl::;~
the material
Th~s amer~can company 1s owes byl
___ _ _
_ _
The husband of Mrs Adams (since ~b~x~v~u~r~c~n-,~~nr;\1r~mrue~n~a~n pilot
named. Sarkis Soghanalt:n ha"a
)larged to acquire .and c~rry
the guns on beh,a lf of__
_
~
The transport has to ~~a--o~n~e~v~l'-a~L~ir.s~bon to Nouakshott on board of a
707 BOEING of -the UNITED TRADE INTERNATIONAL company - The plane,
P"
for unknown reasons, was carrying a Zaire immatriculation.
!
.The safle was co n cludedf between bu yedrs, sellers and transporter for the
sum -o USD I, I 5 5 000 reight inc 1 u ed.
,
.
It is pre~~- ~ure. ,however, that sarkis Soghanal _ian ,had been to Lisbon -an ,
-ad presented the documents certifying that the guns are on board, and
that 'he has been paid for the cargo- Condition of the delivery in
Nouakshott, without any control of the materin1 nn~ ~v~nnr th~
f)'I"'P~f"nr~ nf 'f'l,,... ' "
---"- -- - ---
da: t: S'm:l r
:a=
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The'armenian.pilot,'whowas as well director of two

commercial companies called UNITED INDUSTRIESin BEYROUTH and
AIR TRADE LIMITED .in NICOSIA disapear on this stage.~
After investigations, the FBI recognize that the plane has
never landed in Lisbon, but at that time he was doing some
occasional journeys betweenFlorida and San Juan (Porto Rico)There is no trace about any purchase of arms in the States always in agreement with the American informations.
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All the problem was at that stage, one plane to discover and
one check to reimburse the Mauritanian Government.
The Government .of NOUA~SHOTT insist of course upon~~--~~--~
to ohtaiq the reimbursement of the non delivered mater~~a~l~-------------~~
I
Jcalled upon the ~erican Justice and assigned
pr:sid:nt of UNITED TRADE INTERNATIONAL company.
L-------------~~
lstate that the .plane that she use to owe, was not anymore
un er er controle or under her responsibility and that the fact
that the,plane has to land in Ankarawas only due to a sabotage
operated against the plane.
accept to sign a document. authorising the

However, I
representatives of the FBI to go into the plane to get the log book.
Therefore Turkish ~uthorities were officia_lly informed.
In the old rusted body of the plane, the FBI do not find any .log
book, .no maintenance books, no guns and even no seats
For the FBI, the mysterious pilote' who . .,l,. ,ar-::n:-::d,-,e=-d__o_:_ __,;::u:::Y'::ma 'can
1980 on Ankara Airport and introduce hirm~s~e~l~f~a~s~l~:~-~-~-w-~-~-~-~-~~~
can only be the armenian ex-husband ofl
be.foolis~ enough to pilot such an old plane.
In this aventure,l
lhave lost a husband, and.~lso a plane,
that she has never declared as disapeared, until .the time that
The Court of Florida ask her some more informations.
~~he
unfortunate english businessman has lost alot
L-o,...f-c.,.....r~e""'~'d"'Tirb"Ti"'C'l"Ti-:"t--:ly which is so important in the 'defence business, and

he should now reimburse the price of 200 machine guns.
Ankara is. now. l'eft With a very cumbrous wreck.
And a man has really disapear with I,SSI,OOO USDOLLARS.
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My introduction to SGS arose out of a prevjous .transaction

which I hadengineered for the Government of Mauritania through
.a contact of mine .in
Par~s, G~oup Captain~~----------------~
'
and arose out of my knowledge through this previous transaction
.Lf
that SGS had . freight jaci1ities for merchandise of this parti.:.

cular nature.
'
I or.iglnally
spoke by telephone to SGS in Miami, .in the first
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instance speaki.ng with
Fho explained to me tha.t
L . . I_ _ _ _ _ _ _ _ _ _. . . . .
he worked for SGS.
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I advised SGS that I would have a freight requirement and he

specifically asked me at that time for the details of the
freight and suggested that I purchase the merchandise from
him as he had an established and ,ready availabi.lity.
confirme.d to. him that I had no objection to purchasing from

him provided inspections were made. and that such merchandise
conformed to specification required.
J
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I advised him that I would give him speci_fic details on telex

and provisional quantities setting out condition of goods that
we required (new manufacture).
Reference ~o. ~59-654 refers.
My telex dated 6th May, 1977,

His telex reply is dated
27th May, 1977 in confirmation of avai_lability of onsight

inspection. , It is quite clear as to the reasons inspection
'
was made in the U.S.A. for at all timeswe were advised by

SGS that merchandise emanated from the U.S.A.
Further,
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SGS was
. a.wa~e
requ~red
at all times th_a t
merchandise was
of .new specification.
nurin~ . ;inspection:
~~ris,
Ithe .inter-preter from
and the }:Uii_tary -Attache_ for the p\irchasing 'Government,
by whom the inspection was to
be
(..
I.
veri_f ied . and the merchandise:
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sanctioned as to specs, were i _n . dialogue with mtself and SGS.

I
on these matters and 9an confirm that SGS was aware. of_ our
:fu}l requirem~nts and'that he clearly .indicated the source
,.
of. the merC.nandise_ to' be. ex_ 'U.S.A.
bt
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Half wa:y through :i _nspection, -SGS informed u.s that the

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National Guard in Washington would_ not
relea~e
.30 equipme'nt
for sale_. and that they .had advised_ SGS that. thi_s e_q uipment
'
could be inspected .in Sa~ta. Domingo j _n_ their stocks at this

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_location.
'
At .that time we confirmed to SGS that we wou_ld
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only be interested if_ mate:t"ial was_ to specification requi_red
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He repl_ied
and t .h.a t we did not want secondhand materia.i.
at that time that . materiai would 'be new and_ unused.

'
to
~:t"ip,
'
,......---------,
in Miami he introduced!
las . one of
President Carter's advisors on.. the matter of American affai_rs

who ~ was arra:nging
the .t-rip to SD.
~----~~returned t~
Pari_s .f_rom Miami' at th_is point.
.on
~rrival
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in SD, SGS advised me that _it would; not be possible
for .me person,ally 'to see t _his . ~quipment because of t _he difficulties inmaximum numbers ,permitted for .'this inspectio~.
.....
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I advised him that I was fully aware of what the equipment

looked -like and that the Military Attache would be authorizing
the purchase;
he was imperative that he be present to v:erify
condition.
The Mi_litary Attache ,subsequently advised me that the equipment
1,
was not as SGS described and in his view the journey to SD .

'
was a waste of time but that in view
of SGS comments now with
regard to
manufa~ture
of this equipment, he WQuld submit a
recommendation that new assemblies be mounted within slightly
[
'
Subsequently this 'possibility was turned down by the purchasing

Government which then proceeded on.ly to' move on the . 50 materials
(new from Numrich).
~GS
was advised of this in telephone
conversations and agreed eventual acceptance of L/Cs.
''
Page 60, Line 16-19

At no time prior to the, inspection 'that.! arranged with
Ion instructions fr.om SGS.
Captai,,
(Numrich Arms Corporation) was I informed that,SGS had

met with Capt.l
~to
I In
L.
effect my introduction of Capt.
SGS in the Washington Marriott Hotel was the first
time that he had met with him.
~....-_ ____,~lean testify 'to this:

Page 60, Line 20-22
We discussedonly .30 Calibre Browning 1919 A4 machine
guns - n,ot a quantity of 30.
Page 61, Line 5-6.

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SGS refers here to inspection in February 1978 in Lisbon.
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(Refer my affadav_it re inspection).

here andl
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lean evidence
L...----....1
Page 63, Line -13
Accommodations arranged by QRC .in the name of United

Trade International
(evidencedL~-------~~) .
,....
.Page 65, Line 3

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The. purpose of the visit was specifical_ly t_o inspect and

SGS was totally aware of this.
(E~idencedl
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Page 68, Line 12-25

Purpose of
~nspection
Numrick was to see part of completed
order that SGS was supposed to have already put in hand ..

The equipment shown to us was held out to be by SGS.
Equipment for' our order.
(Evidenced!
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Page 70, Line 22-24

SGS not only
ins~sted
he could supply from USA' but ,
had also previously held himself out to be part shareholaer of Numrich Arms Corporation.
l
...
He had explained
that the on1y possible source of this equipment was -in

fact from USA and that in addition'to the end user
certi_ficate issued by the Paris Embassy for the' Mauri-
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tanian Government, a Form DSP 83 would also.have to be

cqmpleted.
(This is the U.S. MunitiomControl statutory
form-required for export of

USA).
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~ecurity
trade material from
(Evidenc~d~
1.
Further to these explanations, I then negotiated with
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lfor freight costs from USA t.o Lisbon to

Mauritania (evidence4
I> ..
Page 71, Line 14-'16

'
(Evidenced Munitions Control Export, U.S. State Department,

Washington) .
This weapon stil_l in use with U.S. Army and
widely used throughout the world.
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Page 71, Line 17-20
!t..
SGS in fact explained the vast quantity of spares held
:...
....
by Numrich from which these units could be assembled

as new.,
He further confirmed that the receivers.of
these weapons were manufactured in another part of the

(Evidenced by Capt.L~----------------~ All
this confirmed in te.lephone conversations between SGS
u.s.
Capt.L~------------------------~---~~~from
Paris on our return

from inspections, approximate date 20th July.
I
.....
Page 72, Line 17

We
~.
s~e<?ifically
did not travel to Santa Domingo to
inspect . 50 because following inspection Capt. L.~---------~
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had agreed to purchase the equipment shown to us at

Numrich Arms Corporation and after discussions between
s~s, I
L
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I Capt Dand myself .in which we made
it quite clearto SGS that the specifications as shown

'to us at Numrich were acceptable and that the new con. dition as shown to us at Numrich was acceptable.
He.,
~hat .is Capt.Owould telephone Washington Embassy of
Mauritania and advise his recommendation to accept the
purchase from,Numrich and he also then telexed his
Gove-rnment in Mauritania to that effect.
t
.....
.The purpose of travelling to Santo Domingo was because

SGS had informed us that the .30 purchase could not be
taken from National Guard supplies and that they had
advised him, SGS, to take them from U.S. Army stocks in
Santo Domingo.

Page 74, Line 15-21'
SGS advised o( inspectiO:n arrangement.s .and. t concurred

that.. it was not necessary fo~ me: to. see. the. materi~l as
the Capta_in. had to make the decisiort :regarding .the ptrrchase ..
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CJ~-(v-c..t ~~ yq~ ~UL,s;,
l.;....
~.:t-sS. ~ +~~j,: ~~w..L-.tfL-rJ., ~, frJIN/ re?lf'.i.- o~

.
Cc. . . . .R..J. ~,. . ,...tf.tV".-1'~?.~ rN. . ~,l"...(re.dt~-" uc..~k! ~. t'A-w.t-"'
'
) ~~ c
pz~lt'
..
.lrf~ ~t~- v""'r~._t-~ l1p,~~

~
.. ~OJ
-~JiYtJ. t'/Of t~
lk&:-ph~,PQ .
QftV't{
.f;wf tv_ . ~~
Lt~~.
.
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.'-1/_
bG ..;_,
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1~-.J.f-6'J. t-t\)~
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BOCA lNVEST~NTS LIMITED

Registered Ofl"1ee:
1. E. Ralph, .Esq.
Consultant,
Boca Investments Limited,
c/o Keepers's Cottage'
flimwell,'
East Su'ssex.
England.
~----
~- ~-
II
Osprey Uouse,
$,Old Street,
PLEASE REPL\' TO THE ATl ACIIfH> ADDRESS

USING Tttn AI>DI~ESSED LABEL FOR YOUR
CONVENIENCE:
\.
St.Helier,
Directors:
Jersey, C'Mnl'l1 Jsbnd$.

P.E.Ratph (Austr~lia)
Executive Directors:
Administration:
M. RAlph (Australi3)
J. Sousa e Mello (Portugal)
J. E.Ra.lph (U.K. CoMultant)
Telephone:
TEL. No.: 05805 20n

ANSWER SERVICE
TEL. No.: OZ27 61218
tElEX: 96118 ANZEEC G
1981
21st May
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Dear
..
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Soghanalian Affair
I enclose a. copy of a translation of the newspap!?r article which

you have doubtless alreadyreceived.
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This translation was sent to London by ar

.
l(the
ver,y person who is.managing Director of !ne company against which
I obtained a u ent in Brussels in October of last year) to a
a Solicitor who does a certain amount of work -for
L.....,m~e-an~~w:~o""'':':a~s:""T.:~ownl
Ifor about twenty years. With
the article a letter Implied that I had obtained %1,500,009 from the
matter.
I telephoned 1 Le 'soir 1 , the Belgian Nel:spaper and told them I had
been advised of the article and that I would be in Belgium within ,
the next week or two and I would contact them again.
I plan to
say only the following statement of fact:- In April 1978 I re_fered the matter to my Lawyers in the trSA and that im.ediately a civil
action against SGS et Al was comenced for 'breach of -contract, and
that at the same time a formal criminal complaint-was made to the
U.S.Attor.ney 1 s office in Miami. i t would therefore be imprud~nt for
me to comment any.furth~r on the facts of the matter or to attempt
to prejudge the issues now before the courts.
The address of 'Le Soir 1 is as follows:1000 Bruxelles, Belgium.
Place de Louvain 21,
I must advise you of the above information because of the implications

conce:rning libel and defamation of character that emarge when these
articles are exposed.
In Belgium any person named in an article
has the ~ight of reply equal to the amount of copy published.
I
do not think that at. this stage there is any more to say than I
suggest above - unles of course you think otherwise.
n:t ::c:
Banque 'Bruxelles Lambert are most anxious that their name -is in no
way exposed, and of couQsa.id that I woul~
make
exposure.
I spoke .wit
this,morning a n d L I J . s
having a meeting with the oa
o get their agreemen to rem
ees
to you.
I have arranged to go to Brussels next week to have a
meeting with them and I expect to be there on Tuesday or Wedne~day.
----= =----- -
----~-=
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I:Esq.
L...-Ari..,.,....,d"""re_w_s__an__,d...,fu,....b bers
21st May, -1981
b6
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lgo
It occurs to me that wh.en

to Mauritania and
.Portugal they may wish to make a note of som~ comrn;jts I made on
paper shortly after I got SGS 1 s deposition. l a s k e d me to
highlight some points at that time which I d d.
have no ..rish
,to lead them but for the sake of example, where SGS.claims he had
no intention of supplying. the machine guns from the USA and he
infor-med me of this whilst on the inspectibnJ
need only
refer to conversations SGS had directly with Cap a1n
I
Ito get at the truth because SGS contin':-::u-:-:a:"'ll""'ll'.-:-:-a:-s--:s-:-:u~red
us all that Numi'ich were to supply and that all the equipment wou~d
come .t:rom this source.
Nonetheless I don t want to p:ut forwardsuggestions which they are already covering.
I am s:ure by now
they will have a true picture of Soghanalaian 1 s alienation from fact
of any matterwith which he gets-involved.
I have got the copy of the press article from. 'Flight' and it is
of some interest it dovetails in with the article from Le Soir'
and it appears that there was a change of passport in flight. Well!
Well!
The date of the flight seems to be shortly after the date
of our request for production of the log book, etc.
I hope the
F.B.I. interview the Flight Engineer when they are in London and
bring a picture of SGS with them.
It might be interesting.
It seems that more newspaper articles will come to light shortly
if the matter is;pursued by the press agencies.
If I see any I
will let you. know right away.
rL
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BOCA lNVESn.mNTS LIMITED
Andrews and Lubbers,

2601, East Oakland Park l3oulevard,
Fort Lauderdale
.Florida 3;310
L...
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ANDREWS: &_ LUBBERS
"'Ii
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r>. Q. a:ox s:s:zs:

:z"e:o:l
otAN ANO.REW$.
AOStRT G. wa:a:EAs, JR:
.J. t)AVfD_ LYNCH
OONA(O .J;. 0000'(
:EAS_T OAI<r.ANO_ 9ARI< SOu_~[VARC)
----
l"OR~- t..AUDEBI>.AL:r:, l"U>RXI>.A 3:3316
June_ 4, 1981
FBI
3801_ Biscayne_- B1vd._

Miami, Florida
'Re::
Boca_ tn:vestments vs._ sarlds G._ -Soghanalian:,- et_ al .
.'DearIL...--------'
have recei~ed today a 1ette_r froml

dated May 21,
wi_th_ certain_ enclosures.. I_ am _forwarding to you a copy. of .
._such letter. and_ enclosures for: review and consideration.: 1 think.
the_ notes which_ he_ made immediately -after .the" taking of. Soghanalian' s
deposition: are_ of_ some_ particular interest. In_ all probability you
already have a trans_lation_ .of_ the. newspaper article,- but: l nonetheless:
have .furnished. the_ :same.
-
. r
~1981,.
Sincerely: yours
,-.
DA:. -dt_
Enclosures-
~~
bG
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FD-35() (Rev. '12578)
<Indicate page,~ of
news~ap. city and $tate.)
rtwu~ .fh AMtl/1viE

~~~---~-~(=~=un~tC~I~~~~~~~-~~~~hl
~
. e:,
'Edition:
,Character:
f1) tJ
Ot
Cla-ssitication:
Subl:c.itting Office:
q(p
\'\""""
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bar attended by William Weisenburger,

then on ae:tive d\:tY with the CIA, and an
other agent working undercover at Amer
ican 'Electronic. Libya eventually placed
Former CIA agents and U.S. suppliers reap profits
an order for 300,000 timers-far more
than needed to blow up any Possible num
he world's most notorious supporter Teehriology, Inc., were two former ClA un ber of imagined braeli mine$.
American Electronic balked at the
of international terrorism is Libya's dercover agents: Edwin P. Wil$00, 52.
mercurial strongman, Colonel Muammar who had helped to organize the disastrous size of this order. Wil$00 then recruited
Gaddafi. The Reagan Administz:ation is Bay of Pigs inva$ion of Cuba, and Frank anOther CIA supplier, Scientific Commu
so convinced of the Gaddafi connection E. Terpil, 41, who had worked ovet$eas nications, Inc., of Dallas, to provide a sec
with terrorism that laS:t month it ordered for the agency as a communications tech ond batch of prototype$. &hey were de
Libya's diplomatic mission in Washing nician. Wilson. known as ''the ice-man" livered to Wil$00 and Mulcahy at a niotel
ton to clqse up shop and leave the U.S. attheagency,wasacoldyetcharmingop. near CIA headquarter$ in Langley, Va ..
But who is helping to train and arm Gad erative who kept in gregarious touch with by Joe Halpain, the Dallas firm's PJ'C$
dafi's terrorists? The astonishing and em his CIA buddies. He often took Mulcahy ident, The final Gaddafi order was for
barrassing answer: former agents of the along to $Uburban Washington bars, like 500,000 of the timet$, for which he prom
Central Intelligence Agency and private the Rough Rider Lounge at the Ramada ised to pay $35 million. They c:Ost only
U.S. companies that have long supplied Inn in T)'S(m Comet$, Va., where agents $2.5 million to produce. ExplosiVe$ to go
the CIA with SI.ICh tricks of the trade as gathered. Mulcahy was convinced that with the timers were illegally supplied by
gun silencers. concealable explosives, de his partner was still working
J .S. Brower & Associa tC$ of Polayed.triggering timers and electronic "'under deep cover" {or the CIA. Edwin
mona, Calif. another CIA con
snooping deviCe$.
Thus Mulcahy was not
tractor, Some 40.000 lbs. of
So claims a two-part story in The New alarmed when his two partner$
the high explosive RDX-the
largest nonmilitary shipment
York Times Magazine by Seymour Hersh, told him that they planned to
a former Times reporter and current free visit Gaddafi in Tripoli. One ;
on recOrd-were flown to Lib
ya in ~5-gal. drums marked
lance joux:nali$t. ~is a~nt of Ameri reasOl\: Wilson, in Mulcahy's >;~
"ind1JStrial solvent."' This was
cans puttmg theU' purswt of pet$onal presence, had told Theodore 1-:..
a risky enterprise since the
wealth above the national interest has G. Shackley, then an assistant f ;;;
drums c0\1ld have exploded jn
been confumed in its essential deta~ by to the CIA's highest clandestine ~:'~\
flight in turbulent weather.
TIME correspondents. Hersh's tale of in operations official, about the ':/W:.
Mulcahy finally decided
trigue also raised questions about the Gov trip. Gaddafi wanted to buy ~
,:.:, "
his partners were acting on
emment's attitude toward the export of thousands of timet$ that could
their own, not for the agency,
expertise in terrorism. The Justice De- set off explosives at a specified
when they directed him to arpartment and the FBI investigated the case hour, ostensibly to clear Isz:aeli K vtn Muk
range lor purchase of a Redeye
seemingly with ICM than full enthusiasm. nUnC$ left from the October r~
ally
ground-to-air missile lor Gad
The State Department and the CIA ap- War of 197~ven though
dafi. Mulcahy feared Gaddafi
pear unable to stop this peculiar kind of there is no evidence that any
might be planning to arm a
profiteering.
SI.ICh nUnC$ were in Libyan wa
Redeye with a nuclear war.
The main source for Hersh's story is tef$orterritory.
head. Alarmed, he searched

Kevin Mulcahy, 38, a former: computer
A firm called American
through his company's files.
_and communications expert for the CIA. Electronic Laboratories, Inc.,
found documents he had nev
He leftthe agency in 1968, worked in elec- of Falls Church, Va., which
er seen-and reported his
tronics and computer$, overcame a strug had long .furnished the CIA
findings to both the CIA and
gle with alcoholism, and in 1976 was with classified equipment, ~
coaxed into the business of exporting agreed to build prototype$ {or .
therBt
The documents, according
high-speed communications and com put- Gaddafi's order. The deal was " I
to Het$h, disclose that Wilson
er gear. His scheming partner$ in Inter set at a meeting in a Virginia
and Terpil had set up a tz:ain
ing program in Libya in ..espi
onage, sabotage and general
psychological warfare." It in
eluded a laboratory near Trip.
oli lor making assassination
bombs disguised as ashtrays.
lamps or teakettles. An active
CIA agent, Pat Loomis. alleged
Jy helped induce SOme Green
Berets training at Fort Bragg.
N.C . to leave the Special Forces and join the Libyan opera
tion as instructOr$.
Mulcahy also discovered that Terpil
had provided arms. explosiVe$ and tor
ture devices under a S3.2 million on tract
with ldi Amin Dada's brutal government
in Uganda. Terpil had once bragged about
tC$ting a new poison on mmeone in
Uganda whom he had no rea$00 to kill.
He also told two New York City under .
cover police posing as arms buyers. )f
you're knocking off Americans, it will cfcst
you 40% more."
Trafficking:in Terror for Libya
,,
~
i.,
TIME.HJNE
I ........, ,.., ,
_1 _, _
,,
' ---
19$1
'
'
FEDERAL' BUREAU OF INVESTIGATION
O.!t of
tro~nstrfP!Io
7/17/Bl
. __ _ _ _ _ __
I
'
'
I Senior Cor.tmercial Assistant, .Foreign Commercial

On1ted States .Department of Commerce, United States
Embassy, London, -England; was interviewed at the Uni-ted .S tates
Embassy, London, 'England_, .and furnished the followin_g information:
Serv~ce,
I
}advised that he w~s intrr~d~u~e~d~t~--~~--~former bus1ness associate of his.,
-took plac~ in la'te 1977 ~ or early~l:-;9=-:7:-:s=-,--a-n-d:-r--......,;::..:.;essent-ially was
makin_g a comp1:aint concer.n ing the nondelivery o -machine 'guns
.from the .United States t .o a client of . .his in 'the Islamic Republic
of Hauritania.- I
!stated that his duties included ass isting
citizens of the Un1ted Kingdom who -were engage~ in commercial
contracts with the United States., and ~here.fore ,1
~~om_plaint
or information came Wi-th!n his ~u~view. _ Consequently!
1
recall~d 4~aftin~ or _pr?viding 'imput to :sev~ral. cables tat were
trar1sm1tted from the Un1ted State s .Ernb;.,ssy 1n .Lpndon to the State
Department .-i n ~-lashillgton_, D.C. and the .U nited States tmbassy in
Lisbon, Portugal.
llwJls .ques~ioned specifically concerning a cable dated
!ebr~ _, ~l!)Ji, 1r.om the American , Embassy in London, to the
State Department~ in' Washington, .D.'C., and the American :Embassies .

.in Lisbcm, and Nouakc.ho'tt, Mauritp.nia. I
!advised that he reca'lled
the -cable . and that he in fact had drafted i t s ,c ontents. The cable
"as precipi~Te;
bl a visit "fror.~l
jrepresenting Boca
.Investments.
had :come into the Embassy and contacted~
having know
from a ~revious business relationship.
related to h1m , or the first time, t he details of a _problem .J.nvo v.ing
the shipment of machine guns ~hich were sup osed ~o cone from the
United States and ~e shipped - to Mauritania.
was told that
the cable' :referenced -:the supplying of
7
c l..ne guns, 'a s' opposed
to the 197 called ;for in the contract.
stated that this
was proba~ly a typographica1 ~rror ..or .s~mp y an .e rror in 'his
.
.recol~ect1.on o.f the conver~at.1.on w1t)ll
lw~s also
quest1.one~ to a .reference .J.n the cable that the -mach~ne gurs were
to be fully reconditioned and of the water-cooled variety. t
I
stated -that it was possible that 'he had interjected his own assum:tions
and l<nqwledge of weaponry into t.he information provided by I
J ..
_____ ,.~ndon, England

1 nvnti9~uon <Xl_6--./._l_8_1_8l
F'tle
'
MM 'l96A-l056- /n
'
., " I ,t=>/
b~_gjL______________. . .I-----~---_m.:;.j_s
.
__o.te dicttt<~_s_l_l_a_l_a_l_ _ _ _ __
r~mmendtlons
<on1~si01'1i of tt.. f'8l: 1~ is tt.. property of the FSI ""<< i$ .1on~d tQ your gen(~;
Ttl iS Clo(utnef'lt <ont,lns f'leitl'ler

nor
it nd its contents e not ten distrit>ute<l ,outside ye>ur gel'l(y.
b6
b7c
MM :196A-l056
-2
lstated that 'in his experience wi~h ~eapons, M-2 machine guns
He stated that he was unaware that HBM2 machine
guns were air cooled rather than water cooled. In refe~o the
machine guns being -fully reconditioned rather than new,~
stated that it ,is possible that he interjected this J.nformat1on
on his own~l
]explained that he was aware at the time -that
no _50 ca-liber HBM2 machine guns were 'being manufactur.ed anywhere
:in the world, therefore it was _probably an assumption on -his part
~he machine guns were recondi~ioned ~ather tha~ ~ew.
Ho~ever,
L______j stated .he c~uld not be certa1n as -to the spec1f1cs of h1.s
conversati-on with[
!further stated that this conversation
~ithl
!ranged over .numerous topics and the question of the
de~ivery of ~he machine guns was only one of the subjecUwhich
they discussed.
~w-e_r_e~water cooled.
!.further stated that subsequent cables dn this Datter may

'have been prepared byl
Ia Customs official who subsequently
became -involved in the .matter.
b6
b7
\.
(REV, 3-f-77)
''
FEOERA"BUREAU OF INVESTIGATION
d 1.n
was 1.nterv1.ewe
USA)
He is c.ur.rentl y employed as a senior contrac.t negot:iator with

t;. M. I: Electronics , L i e , London, Englod te lephorie number.
0'1-573-3888, extension
Previously',
served 1-7 years with
the Royal. Air. Force an
ed in the gra e of- Flight Lieutenant.
While in the Air. Force.,
served as a navigator.
!acquired
in the Royal Air Force
, a. wo~nowledge o mac!hne guns
and other weapons and armaments. L_____Jror.mal. education ended after
one year of university studies.
llwas. hired in November of 1977., byl
lof Boca
.1
Inve~s, Limitetd position 'was that o~ an associate or
tant.. One of.

first duties during his employment with
involved. a tr.1.p o ntwerp~
'um, in Novembtr gf l9Zr with
to meet Reynolds Williams.
recalled that
_was
assoc1.ated. with r.R.C. in Arlington, .l.rg_i nia.lalso recalled
that' a man named_
lwa~ somehow as.soci.a ted with Q.R.C.
!stated that t~e. purpose _of this first trip to. Antwerp wa~
b6
presen~at1.on of certain doc.uments to the Banque Bruxelles L7c
Lambert in. orde~ to obtain payment for th~ delivery
197 m:Jhine
g~ns to the country of Mauritania .!
I stated that:_
__had
:
broug~t certain documentation to Antwer~ which included an a1.rway bill,
a certificate of origin, a certif1_,.ate of inspection, anrJ possibly other.
lundel"st-anding
documents had been
documents.. It was I
furnis~ed by Sarkis So~hanalian and t h a t w a s So&hanalian's
author1.zed representat1.ve. These docume
w
resented to the
bank and subsequently, payment f.or the. weapons was transferred to
Soghanalian in the U~ited States.
to handle the
lf-
t::t :::"J-
::: r:
'
During the process of presenting these documents to the. Banque

Bruxeiles Lambert, thf ba;:
cjrtain
changes. In o~er. to
effect th~se changes,
had to call Soghanal1.an 1.n
the United States.
a e
e as present during the evening at
.,London, England
,, MM 196A-lOS6 - /
DY~L.._ _ _ _ _ _ __l"-------...;;;-.:.:.m:...~j~s:....._cute c:fteuted _ _;6::::.1~2.::.2:_1..::::8.::l...______

.,
'
'Tnts c:focurnent <:ontalns neltnet rec:ommendatloM not eon<:lusions of tne FSI, It ts the l>t'OPerty, of the F91 at~c:f IS Jo.ned to you'r ageney;it anc:f 1ts contents are not to De <1 istriQ~o~ted
o~o~tsi<le y~t
agenc:y,
s-7
I
I
MM l96A-l056
a hotel in: Antwerp, Belgium, whenr

Itelephonically contac.ted
Soghanalian, who was then ei~:~r in :iamL Beach, Florida, or Arlington,
Virg~na.l
!recalled that!_
_I related to SoghanaliaQ the
changes which the bank desire Sog analian authorized the changes
and subseq~ently, documents reflecting these changes were submitted
to the B~ Bruxelles Lambert. After. the bank accepted these
changes,L____Jreturned to the United Kingdom.
Subsequent to his return to London,~was adviseq by~r-----,1
that another change_ had to be made in th~mentation
Irecalled
that the Credit Commercial de. Franca in Paris, which was ano her bank
involved. in theitranjactions, had requested. certain. changes. I
I
dispatched
to the United States to accomplish these changes.
subsequent y~ on or about December 3, 1977, traveled to Arlington,
1rg nia, and went to the offices of Q.R.C. The amendments which
had been ra uested by Credit Commercial de Fr.ance ~ade at that
While in the offices of Q.R.C.,L____Jrequested that

con ac oghanal.ian in. Miami by telephone.., 1n orderm1g t inquire. as to the nondelivery of the machine guns.
~e~x-p~ained that by this. time, Soghanalian had. received payment or t e bs

machine guns and all o:. the docum:;ts lubmitted by Soghanalian or
b7C
his representative.,! _
__
_indicated that the weapons
had. been onboard a cer al.n a1r.cra . an were. ready for immediate
delivery in Mauritania. I
I placed
call to $oghanalian
in Miami and then handed the telephone. to
jasked Soghanalian
why the ma~hine guns had not been. de~ivered.. Soghanalian replied
tha~ there. had been certain technical problems with the aircraft in
question bu~ that these problems were. now resolved. Soghanalian
further stated that delivery of tha machine guns would definately
place during the. first part of the week of December 5, 19.77.
then further pressed Soghanalian to. name a specific and de.finate
very date. Soghanalian then said the weapons would be delivered
on December 6, 1977.r----lthen requested that Soghanalian authorize
I
Ito furnish. a--Ie:tter confirmi~g that delivery would be. dur.ing
the. week: be:innin: Dece.nber 5, 1977. However, Soghanalian wov1 d
not. allow r
Ito. <t-:ri:te. such a l~tter and would authorize.!
I
to ont: sta ~ ver-ally that the delivery would be during that particular
week.
ubsequently. traveled with the amended docum.ents back
to Lon on and then took the req~ir.ed documents to the bank in Antwerp.
fhe
.
Irecalled subsequently being advised b'y I
I that the,
weapons, which were to have been_ del.ivered from. the United States,
had been rel..c:cated in Lis.bon, Pc:rtugal. I
lalso advised hi.r.n that
he had been l.nfor.med that the al.rcraft bear1ng: the wea-pons had left.
Lisbon and that the weapons had been. placed in. a warehouse there.

MH 196A-l056'
:~
he f~l
urt~eca~led that in early 1978, possibly Januarv, 1978,
instance to
and conversed with. 1
]
un erstood that
was Soghanalian's representative
In L sbon.recalled thatdvised him that the l-97
machine guns were in a military ware ouse controlled by th~ Portuguese
~~Y I
'requested to see the weapons but this request was refused
llstated. he took a_ number of' trips to_ Lisbon subsequent- to
se_ t i she met Captain!
I
of the Mauritanian Army.
and Soghanalian were
all staying at the Sheraton o. e 1n 1s on.
did not pe~sonally
see Soghanalian during this particular trip u conversed with him
f~equently on the telephone inside the hotel.
He recalled that
Soghanalian told_ him that the weapon~ could not be shipped from
Lisbon. because Soghanalian was unable to, get an export license.
L..-....,....-----llasked Soghanalian why he needed an export: license. since.
the weapons were only there in transit,. they should be under bond.
Soghanalian r.;plied only that thi<: "as ~ot the ca~e. jeca~~ "things
do not. wc:rk: like that llere. " ~ur11}g t_hl.s same tr1.p,
1.nforme.d
Soghanall.'an thatl
Jwas c.om1.ng 1.n fr.om London the nex day.
Soghanalian then proceeded to leave. Libson that afternoon.
Dece~l977, and that on one oft
I Irecalled that
numerous attempts byl
~uring jhe early. months. of ;978, he. wi~nessed
_
_to contact. Soghanal1an to obta1.n
delivery on the weapons.
ecalled that all or most. of these
attempts to contact ~oghanalian were unsuccessful.
lwas ques~
ed as to his understanding of- what an airway
bill represent_ed.
stated that his understanding was. that: an
airway bill_ indicate t at certain goods were on bwcertain
aircraft at the t.ime. the airway bill was prepared.
stated that
he was perplexed at how the 197 machine guns-could eon the. ground
in a warehous~ in. Lisbon, when an airway bill had been prepared
indicating that they,were on a certain aircraft, ready for shipment.
I
lwas questioned as to his recollection of the condifion t~at
the machine guns were to be in upon delivery. Specifically,
j
was asked- if he recalled whether ~ the machine guns were to be
new or refurbished machine guns. L_____,..J stated that he re.called
~fically that duri~g his_ conversatl.on w~th Captainl
l~n Lisbon,
L____Jwas most adament 1n reference to the fact that the mach1ne gun~
were to be ne~machine guns and no~ refurbished machine. g~s. [
I
further stated tha~ he became aware, at some point in. his employment
fori
~uring this period of tima~ that the machine guns to be
b6
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MM 196A-1056
deliver.ed were.~ refurbished machine guns ins~ead of new machine

guns; however,L___j stated that he simply could. not remember at what
point he became aware that this was the case.
I
lwas questioned as to his knowledge of the. ultimate source
of the weapons to be delivered to Mauritania,!
~stated that the
sout:tr. he weapons was never revealed t9
raithough he recalled
tha
had stated that he had viewed some weapons at N\.unmrich Arms ,
in t e n1ted S~ates.
~--~--~~f~t~r~t~hjr added that it was he who had introduced!
I a commercial re::jsentative of the United. states

in London, England.
stated that he had previously known
L_____JWhen they had w~rked oge er on a certain commercial project.
~y
At. the conclussion of the interview , . I I furnished a Xeroxed

copy Qf a draft statement which he had pr~ covering his activities
of november 16, 1977, until December 5, 1977.
lstated that he was fully willing to travel to the United

States to testify in this matter.
b6
b7C

1-
~te of tran~ll>t~n 7 /1 EY f 81.
'
ne;
num er
vo untar1 y appeare a
e; n1 e S~ates Embassy,
London, England, and. was. interviewed in the :!'esence of Assistant
United States At-torney CAUSA) I
_
land Constable I
t----~I....:..M:..::ewt..:t;~opolitan Police (New. Scotland X'ar >, ondon, Englandrr-.---~
lfu!'nished the_ following: information:
.
L...-----;;:::::==:::::::!....----.
L..l_""T"""_ ____,,...I
is re.~i!'ed. fror.\ the B!'it:i:sh A!'my afte!' a pe!'iod of:

15 year's service. He is currently un~mployed.
first became associated with~------~~

No ~==-.........--"'PP""'''~. I
I accep.ted a posl. t1on
1n . for.J
in
ompany, Boca Investments, Limited.
wa~-nonn--~
a C
-basis d u r i o enployment for
U!'l.ng .the.
time that he: worked for
he. occupied o 1ce space at 10 Cheyne
Place, London, Southwest !'ee, and 15 Cheyne Place, London.
!recalled that shortly after he became employed by
~ated to him the general circumstances concerning
ha:T>1.
~a~c~o~n~t.,.,.r.,..a.,..c""'t-t""'h,..at
he had calling for delivery of 197. heavy

fifty calibe~ machine. guns to the country of Maur.itania.J~~~~------~
recalled that the supplie~ for these machine guns was a Sar,l.s
Soghanalian, of Miami;. Flo~ ida. .4s time progressed, towa!'ds the
~ end of' 1977. and early 1978,1
]beg~n to have increasing difficutties
in. obtaining delivery of th . wea o s fron Soghanalian. At some
poin~ in late 1977 or. 1978,
recalled that the weapons
were suppos~dly in Portugal,
were originally to have
' come. from the United Stat.es.
stated that he recalled
that originally new machi'ne guns were o have been delivered from
the Unite'd States. but at some. point in time,, it had bec:m; cleaJ
that re.furbished machine gun.s were to be delivered.! .......
c.ould not remember exactly when he learned of the possl. l. l. ty o
delivery o~ refurbished machine guns irt li:~:~ of new machine guns.
b6
blc
~tated that during the period November, 1977, through

February, 1978, he called on numerous occasions, the telephone
number in: Miami, Florida, which was listed on several documents or
..
Investigation on_....;6;..:./...;;1;;.;9;..;./_8;.,;;1;;..'_ _ _ _ .at
sAl
London, England
MM__..1.96A-1056
_,__.-!'
_____
...;,..J iT'
Ft1e _
6/19/81-
1-mJs
by_.;;;.::;,a,..---------.J.--~---.;;;.;.:::~-~~te<lictateel-_.;,.
_ _ _ _ _ _ _ __,
Thi$ CI<Xument contains neither rtcommen<Utions no.r Wndvsions oft~ F'SI; I( i$ the j;,roperty of the f'Sln<S is loane4 to YOIH ,Jgen~y;.
it anel its contents are. not to 1>4 Clistributeel O\ltsiele y'our agency,.
'
, I

MM l96A-1056
certifications furnished by Soghanalian. His purpose for calling

was to follow up on the delivery of the machine. guns. _
recalled asking for Soghanalian numerous times but: was never
successful in talking to him. He. would normally be. told by a
~oman ~nswe~ing the telepqone th:: So~anali~n ~as out of to~n o~
otherw1se out. of contact. !
__ _also w1tnessed numerous
attempts byl
Ito contac Sog analian, all of which. wera
unsuccessful. j
!recalled. asking: the woman who anwered
the telephone 1.n ~ham1 on one occasion, "who is Manoug?" The
woman answering tha telephone replied that she did. not know who
Monoug was.
I
I stated that among his duties were included the posting
of ma1l and occasionally the sendin& of telegrams to Soghanaliari.
I
!stated that during the period November, 1977 through
February, 9.78, he did nor recall having used any sort of special
delivery service or any other type of mail service other than the
regula!" British. mail.. I
Irecalled that I I sent or
caused to ba sent numerous telexes and telegram~ghanalian
during the tima period in question in an attempt to obtain delivery
o. the weapons.
I
!further added. that. typing for Boca Invest~during
the above pTriod of tim~ was done by a secretary hired byL____Jby
the name of _
bE
b7C
Memorandum
-TO
:- S""rl-t-
FROM
'
SUBJECT:
ff\
----
---~
--
...........
- ---

FEDERAL BUREAU OF INVESTIG~TI()N
~ {I tj &A-I tfl7o.JtjD~TE:
)/<-'>-/h
(" ~
J} 1- t/ tl 1 --------~~ro~
b/<e.v-hf:J) ~ ~ ~
Ph-
1
L...-
eft-.
Buy U.S. Savings Bonds Regularly. on the Payr~ll Savings .Plan

- - - - - -
b6
b7C
b7D

(
I
f"()-3()2 (R\/,'3-$77)
''
7_/_J._?_f_S_l_ __
o.te of trnWIPUon _ _
IParf s Fra:ce)'
bus in!:-e=-s=-s=--t=e"'~'l"=e-=p"Ch~o~n~e~n~um"!":.~b~e"""r~l----,L......,h,..,o"""m,..,e,......,t""'e,..I""'e"""p"""n...o,..,n"""e..,.....n
.......u..!.~ber ;
I
was telephonically contacted and furnished -the ollowing :1n orma 10n.:
.stated that he and

had
_L...,-....,...,....-,.--=e...,..r.Jmediaries between the Gov.ernment .of Maur.1 tan1a and
~~=-...----L.L.I,.;I.I.!...~e purpose of acquiring weapons .for Hauri tania during
stated that .his role was limited strictly to that
~~e~w~e~e=n~or intermediary.
lstated that he .recalled~olo..L.IIIr.t..t.Q-....-.~~~~~~-....,

United States on a ~icket purchased by
request-, sometime during the _summer .ofl.r'I'I"'T..,.....-r-------,f-===Te~_.J
-to the Washington, D. c.; area: -and subsequently o .a p an called
Nummrich Arms in another part of the Unitad States where certain
arms wer~ b~ing manufactur.ed.
!state~ that _he did not
recall v1ew1ng completed ~chlneuns at Nummr.1ch Arms but sunposedly
.50 caliber machine guns re:e ~:-the. process of 'being manufactured
there. During this t~ip,L __ __
!server as an interpreter or
a Mauritanian Army Captain . y
e name ofL
r ;
furthe;: stated that dlfr.ing thi~ tr:iP to .Jhpn.mrich

Arms, Sark-l.s Soghanal1an conversed dl.rectly W.l. th Captal.n L
he~
lnid not recal~ any of the conversation.
b6
b7c
. I
I advised that he did not d~sire ~o :travel to the
Un1tea States to testify, but would .consl.der $l.V.lng a -statement .or
de_posi tion to United 'States officia.ls in ,Paris.
lnVC$U9tlon on _ _...6~/:o.2.~"-/.8,.1
bY . '
MM 196A-10S6-/~~
___ .. c Lonc;!Ql), nQ;land
S~L...---------...i--------.;;;m;:..~j..;;;S--.o.,te
Gl(tatea _
__::6:.,:f..,:2~3:.,:f:_:8::,:1=.------
=This ao<:urneftt contlns neotl'ler recornrneft<l~tloM nor conct.usk>ns of lhe f.'S I. It .Is the property .of tl'le F'SI
It n<Jits contents ~r no\tC:. be Clistril>ute<l outsl(le your 9ency,
~nc:ns
loned to your A9ency:
l. --~~----~------------------~~--------~--------------------~
..
.1
~nd p~ov~
_ __
.business telephone numoer

home
France, was telephonically
e t e ollowing information:
telepbo=n-=e-_=n...,u=m.~=r-__._=..;.;.;;..;.~Paris,
contacted
Olte of tta11Kr~Uo..__._1_/_J._7_/_8_l
He served as ~n ~~terme~ary betwee~l

Jand~he .
Government of MaurJ. tan1.a :.durol.ng .negotiatJ.ons "'to f'urnJ.sh 50 _c all.ber
machine .guns to Maur.itania.1
lst.a t.ed 'that his -role was
strictly, that of an Ointermedia~y and that he 'had very little .
_persona), knowledge _of -~he transac!ions or events 'that transpire~
betweell!
}.nd Sarkl.s Soghanalian.
-
~urther stated that he was disinclined to trav.e~

to -t~~nu""'e,......onxr&xrcne~urr-':o;:s+~ates -to tes tify.
'
b6
b7C
lil'tflt~\IOtl Oft _ _ _
s_/_2;;.2;;...;./o;,S..;;l;..-___ .t
.,n.
London' 'England
'MH .l96A-1056 ... /~/
by_:sA~~-------.....Jo------------=m;;;;.J..~,.;'~~. <li<:Ute<1--~s I.-2-2...J.s..;;l;...__,_.;.__

...
oument.~ntlnt
neitllet retommen<ltions 1\or col'l<:luslons ?'the FBI. It is the i>foperty of .the F'SInd -is &o.ne<l to your 9ency;
t>e distributed ovtside vou oenev.
n nd Ju contenu not
to
- -

MM l9GA.-1056
t
-2
of Soghanalian' s: a sum of' money. r - l recalled that t .h i.s. associate

was namedl
land that he. was~South Ar.te.rica.
advised that she would be will-ing to come to the United

States to testify.
b6
b7C
-l
(REV. 3-a-77)
..
of
HE~al th
Iadvised that she is currently employed at the Department

and . Social Security' London, Eng_land, as a. secret'ary
lof Boca Investments, Limited,_ as a secretary and chauffeur.

.
~
established by
in London.
n a:~ro~imately July or August-, 19.7 7, she was employed by
~s-h_e__s~.-a~t-~~thaf she ~aintained regula~ office hours at an office
' I
,.
duties. includedQin, and normal office functions,
such as the posting of ~ail.

~ecalled typing some mail. which
was sybsequently mailed to Sar 1s oghanalian at Miami Beach, Flo~ida
Jalsq rec~led p:rting ~il herself. which was sent to Soghanalian
at M1ami Beach.
further stated almos.t. all items, o: mail
were aent out dur1ng
e period of time she worked ffrl _
__ J
were sent via. the normal British mail system.lco~u~a~r~e~cAa~~~
only one. instance when she sent somovia. a spec1al courier
system at Hethro. Airport. However,
could not remember whether
this itern was' sent to Soghanalian or ano er business associate of
I
!advised that she did recall thatl
I
dispatched numerous telexes to Soghanalian. Hqwever tbis tilex
machine, located in a9other office ad.jacent to l
_office.,
was never operated byL
::ictl
:06
b7C
~ecalls 'making numerous telephoneo for I

Ito
Miam1. Beach, asking for Sarkis Soghanalian.
stated that she.
was neve~ successful in. talking to Soghanalian ut normally spoke
w!th a. ffmale who had a non-Briti~h acce_nt:. I
Jalso re~aUed
the name_
~
las an assoc1ate ~~ Soghanalian s or Un1ted
Trade Internat1onal. Vowever. she. could not recall any other
information concerningL
]
I .
lsnoke :ith Soghanalian on orly oni occasion when Soghanalian
cal.leC!1._________,j at' his office. to askto lend an associate
.1
,."'
6/23/8
_ lnvesti~Uon onr::===~=------~t'!'
.~'On
, . .,
Qn r
.,.,.,
.1
' 'En~[l~
bY~.__ _ _ _ _ _ _____.I---------.:;..Im;:;.:..~.i..:;:;s_,o.te dlcta:ed

This ClotuMellt tolltalns neitl"l
reC'oMf"l'le"'d~tlons
File
J:!M l96A-1056
6/2 3/8-l
not conclusions or the FSI, 11 Is tile property of the f'SI and is
it an <I' Its tontenU are. not to t>e <l'istribute<l outside. your agel'!()',.
to~ned
to you atency;
;.,/t,~

. FEDERAL BUREAU OF INVESTIGATION
L......,......,........,.....,.....,,.......,,.......... concern1.ng
aravet So&hanalian. -~----------------------------------~
!informed he was. unacquainted with soghanalian and

knew:nothing concerning him. However, he informed he had,metL..I______
I
lin. London. England on or about Max, 9 ~981. .In. a conversation' withl
~etermined. that l
lis associated with_
a company named 1 Nasco Arabia, Ltd . NassatJ, Ba ama Islands. 'The same
conversation also determined thatl
jWas associated with Langris
Trust, Ltd._ Bank, Londo_n, England.
.
.
____J
~--------------------------------~
b
b c
b [
these principals .
n;e::n~ ~~:;:::; P:~tion
lwa;
of the d
ab~2 c o n v e r s a t i o n
. b e t w e e n l s h e "nform
r::OlL--~~====~~----~~-------0---0---e-------~----n---~e--U_~_:i_t_e_d_-_s_~_a_t_e_s~~
I
7/16/81_
I had no first-hand knowledge. of any.:'iliegal activitv

I However
he informed that I
Honolulu, Hawaii
lrt /?- /;; ~"'Z- ,~ '

HN 196A""219
Investigation on_.;...._____________ a t - - - - - - - - - - - - - f ' l l e - - - - - - - -
~.
SAl
B_/ctm)
7/17/81
bY---L-----------...J~f-,.-....;;,
_ _ _ _o.tedieUted _ _ _ _ _,_ _ _ _ __
Tl'lls doeumel'lt eolltalns neltMr reeol'l'lmendatlons nor eonduslons of tl'le f'BI. It Is tl'le property of tl'le f'BI and I$ ~aned to your agei'ICYI
It andiU eontei'IU are not to be c:llstrlt>uttd ouWde your ageney.
F!II/OOJ
-~
TRANSMIT VIA:
CJ Teletype
0 Facsimile
Eb
Airtel
'
.'J"
FBI
PRECEDENCE:
CLAS SIF ICATI ON:

0 TOP SECRET
0 SECRET
0 CONFIDENTIAL
0 UNCLAS E F T 0
0 UNCtAS
0 Immediate
0 Priority
Rolltine
Date.
7/20/81
~------------------------~-----------------------------
TO:-
SAC, ALEXANDIRA
FROM:
SAC, HONOLULU (196A-219) (RUC)
S ARKIS GARAVET SOGHANALIAN,

dba United Trade International;
ET AL;
I
IVICTIM
FBW; MF; !,TSP
(00: Miami)
I
Re Miami airtel to Honolulu dated 7/6/81.

Enclosed for Alexandria is one copy of Honolulu letter
to Miami dated 5/22/81 and an FD-302. Enclosed for Miami is one
original FD-302 and one page of interview notes.
For the info~ation of Ai;xandria, on 7/16/81,

I (orotect) in~
d hP h::~s h!:!-rl nn qnhqt>nnPnt- l'nnt"!ll'fo
.... fo'h
lis .not in a position to enter Libya and do any

active inves~l.P"R""""Einn rPP"RrdinPI
lnther than remaining alert
~f~
2 -Alexandria (Enc. 2)
{p- Miami (196A-1056) (~c.
2 - Honolulu (1 - 196A-219)
(1 - 163-307)
RBB/ctm
(6)
ORIGINAL DOCUMENT (S) ENCLOSED

DO NOT BLOCK S1.AMP
Approved:--------
Transmitted--------CNumber)
JUL 2 4 19R1
Per _ _ _ __
(Time)
'V U.S. GOVERNMENT PRINTING off let_: 19$030$7$0/$402
b
b
b D

HN 196A-219
In view there is no further investigation remaining
within the Division, this matter is considered RUC at Honolulu.
2*
~-
--l
\-.
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA
SBG:mlw
NO.
18 u.s .c. l341

M/S 5 years - $1,000
18 u.s.c. 1343
M/S 5 years - $1,000
18 u.s.c. 2314
M/S 10 years - $10,000
UNITED STATES OF AMERil

INDIC' 1ENT
v.
SARKIS G. SOGHANALIAN
The Grand Jury charges that:
INTRODUCTION
1.
United Trade International, Inc.
(hereinafter
referred to as "UTI") is a United States corporation, incorporated in the State of Delaware in 1975.
During all
times pertinent to this indictment, UTI maintained offices at

305 North Hibiscus Drive, Hibiscus Island, in Miami Beach,
Florida, which is the residence address of the defendant,
SARKIS G. SOGHANALIAN, as well as in Arlington, Virginia.
The defendant, SARKIS G. SOGHANALIAN, was the overseas agent,
however he at all times also exercised ownership, dominion
and control over UTI and all its assets.
2.
During all times pertinent to this indictment, UTI
also transacted business and was known under the name of

United Trade International Air Cargo Limited (hereinafter
referred to as "Air Cargo").
Air Cargo, while having no
legal existence apart from UTI, maintained a mailing address

at 276 s.
w.
33rd Court, Ft. Lauderdale, Florida.
The de-
fendant, SARKIS G. SOGHANALIAN, while not the named owner of

Air Cargo, exercised full ownership, dominion and control
over its activities and assets.
.
3.
Dur~ng
was the
all
to
pert~nent
owner of a
reg~stered
United States
t~mes
reg~stration
Boe~ng
N711UT,
th~s
707 jet aircraft
hav~ng
UTI
~nd~ctment,
w~th
acquired said
aircraft on June 26, 1975.

4.
"QRC")
QRC International, Ltd.

a
~s
State of Delaware
of
States
Un~ted
Virg~n~a.
corporat~on,
in the
~ncorporated
1974, doing business in the commonwealth
~n
all
Dur~ng
referred to as
(here~nafter
t~mes
pert~nent
to this indictment,
QRC was employed under contract to perform, and did perform,

services for UTI and the defendant, SARKIS G. SOGHANALIAN.
5.
Air Trade Limited, which is also known as Air Trade
(UTI) Ltd.
(hereinafter referred to as "Air Trade"),
company formed
pertinent to
Nicosia, Cyprus
~n
th~s
~nd~ctment,
SOGHANALIAN, was the chief
~n
At all times
the defendant, SARKIS G.
execut~ve
Air Trade, and controlled its
1976.
~sa
off~cer
act~v~t~es.
and director of
The defendant,
SARKIS G. SOGHANALIAN, authorized Air Trade to be represented

as being a
subs~d~ary
of UTI and Air Trade was, in fact, so
represented.
6.
Brown~ng
referred to as
~ncorporated
Dur~ng
all
Prec~s~onTool
"Brown~ng")
is a
Un~ted
(hereinafter
States company,
f~rst
on April 24, 1978 in the State of Delaware.
t~mes
pertinent to this
SARKIS G. SOGHANALIAN, was a

holder of
company, Inc.
d~rector
and controlled
Brown~ng,
~nd~ctment,
~ts
the defendant,
and majority stockact~vities.
Browning
was represented by the defendant, SARKIS G. SOGHANALIAN, as

hav~ng
bus~ness
Lauderdale,
7.
address at 276 s. W. 33rd Court, Ft.
Flor~da.
United Industries, Inc.
(hereinafter referred to as
"United Industries") is a company established in 1969 in

Beirut, Lebanon.
During all times pertinent to this indict-
ment, the defendant, SARKIS G. SOGHANALIAN, was an owner of

United
Industr~es,
and controlled its activities.
During all
times pertinent to this indictment; the defendant, SARKIS G.

SOGHANALIAN, maintained a bank account at the Irving Trust
Company in New York City, which was in his personal name and
in care of United Industries.
-2-
BOCA
8.
I~estments,
Limited (hereinJiter referred to
as "BOCA") is a company established under the laws of the

Jersey States in the Channel Islands, which are islands located
of the coast of Great Britain, in 1974.
9.
"Defense materials" is a term that refers to various
items which, among other things, have their export from the
united States to any other country regulated by the United
States Department of State.
A .50 caliber HBM2 machine gun
and any attending accessories are "defense materials".

10.
In order to lawfully export defense materials from
the United States to any other country, the exporter must

first apply for, and receive, an export license from the
Office of Munitions Control at the United States State DepartSaid application must be accompanied by a certificate
ment.
from the Government of the country where the weapons are

ultimately to be delivered that the defense materials are
to be used solely by that country.
Said certificate is
referred to as an "End-User certificate".

11.
This introduction is incorporated and realleged as
if fully set forth in each count of this indictment.

COUNT l-18
1.
From a date uncertain, but being prior to July 5,
1977, and continuing up to and including the date of this
indictment at Miami Beach, Dade County, in the Southern

District of Florida, and elsewhere, the defendant,
SARKIS G. SOGHANALIAN,
did unlawfully and knowingly devise and intend to devise a
scheme and artifice to defraud and obtain money and property
by means of false and fraudulent pretenses, representation
and promises from BOCA Investments, Limited and the Government of the Islamic Republic of Mauritania, well knowing at
the time that the pretenses, representations and promises
would be and were false and fraudulent when made.
-3-
THE SCHEME AND ARTXFXCE TO DEFRAUD

2.
Xn or about May,
Maur~tan~a
cornp~eted
negot~at~ons
ment whereby BOCA agreed to

defense weapons
descr~bed
spec~f~c
HBM2.
of
mode~
3.
States.
~nto
an agree-
Maur~tan~a
w~th
certa~n
wh~ch
entered
for
supp~y
~nto
~ts
defense
sa~d
mater~a~s
agreement
w~th
BOCA that he
of the defense
cou~d
mater~a~s
requ~red
new~y
be~ng
~ts
and
wou~d
requ~rements
wou~d
thereafter
or a
a~~
port~on
requ~red.
~nformed
on-s~te
conduct, such an
6.
by BOCA that
Mauritan~a
States weaponry, and
Un~ted
~nspect~on
of the product that
wou~d
arrange to, and
~nspect~on.
Xt was further part of the scheme and
art~f~ce
defraud that the defendant, SARKXS G. SOGHANALXAN,

representatives of BOCA and the
trave~
to the
States, in
Un~ted
commerce, to confer
~n
prop~sed
Maur~tan~an
and
~nterstate
to
wou~d
Government
fore~gn
washington, D.C. with the defendant,
and to thereafter make an
7.
to
to defraud
art~f~ce
supp~y
the defendant, SARKIS G. SOGHANALXAN,
to
~nformed
Maur~tan~a.
manufactured
further required an
inv~te
Un~ted
It was further part of the scheme and artifice to
defraud that upon
wou~d
the
~n
BOCA contacted and
~977,
It was part of the scheme and
5.
ca~~ber
agreement, BOCA sought a
th~s
that the defendant, SARKXS G. SOGHANALXAN,

~nform
~terns,
the weapons to be new and
the defendant, SARKIS G. SOGHANALXAN, of
4.
.so
as a
des~gnated
requ~red
On or about May 6,
fu~f~~~
among other
~nc~uded,
States manufacture.
Hav~ng
source of
and entered
supp~y
gun
mach~ne
The agreement
Un~ted
BOCA and the Government of
~977,
on-s~te
~nspect~on
of the armaments
to be furni9hed by the defendant to BOCA.

Xt was further part of the scheme and
defraud that on or about

G. SOGHANALXAN,
wou~d
~ocated
~n
7,
~977,
to
the defendant, SARKIS
and did take and accompany the rep-
resentatives of BOCA and

Corporat~on
Ju~y
artif~ce
Maur~tania
to the Numrich Arms
Albany, New York.
-4-
a.
Xt was further part of the scheme and artifice to
defraud that the defendant, SARKXS G .SOGHANALXAN, would and

did represent to the representatives of BOCA and the Mauritanian
government that
h~
was an owner of the NUmr!ch Arms Corporation,
and .that the .ctrmaments inspected at Numrich were, in fact,

the armaments that he would sell to BOCA for delivery to
Mauritan!a.
9.
Xt was fu;other part of the scheme and artifice to
defraud that the defendant, S'ARKXS G. SOGHANALXAN, would

and did represent to the representatives of BOCA and Mauritania
inspect~d,
that the weapon
which was a
.so
caliber HBM2 macb!ne
gun, was newly manufactured in the United States, as would be

any other .SO caliber machine guns sold to BOCA.
10.
defraud that the

and did
~nvite
defe~dant,
S'ARKXS G. SOGHANALXAN, would
the representatives of BOCA and Mauritania to,
and would, in fact,. travel to the defendants' residence, 30S

North Hibiscus Drive, Miami Beach, Florida to conduct final
contract negotiations for the sale of the Numrich Arms
.so
caliber machine guns.

11.
defraud that on or about July 9,, 197'7, the defendant, SARKXS

G. SOGHANALXAN, in Miami Beach, Flor!da, would and did OJ:ally
agree to sell 200 .SO caliber HBM2 machine guns, together
with specified accessories to BOCA.
This contract was later
amended to call for the sale of 197 machine guns.

12.
defraud that the defendant, s'ARKXS G. SOGHANALXAN,
woul~
and did utilize the business name and entity of United Trade
Xn~ernationa1
Air Cargo Limited to thereafter enter into the
written contract with BOCA to supply BOCA with armaments.

Said contract was executed by the defendant, SARKXS G. SOGHANALXAN,
as the representative of Air Cargo in July 13, 1977 in Santo
Domingo.
-s-
13.
i t was further a part of the scheme and artifice to
defraud that the defendant, SARKIS G. SOGHANALXAN, wou1d, and

did in or about August, 197'7, request from BOCA an End-User certificate from the Government of Mauritania for the 197 .50
ca1iber machine guns and accessories, and a verification by
the Mauritanian Ambassador to the United States in Washington,
D.
c.
of the signatures thereon exp1aining to BOCA that these
documents were required to obtain a 1icense to export the

machine guns from the United States.
14.
defraud that the defendant, SARKIS G. SOGHANALXAN, wou1d and

did require BOCA to de1iver said End-User certificate to
QRC, his representative in Washington, D.
15.
c.
defraud that the defendant, SARKIS G. SOGHANALXAN, did not

fi1e an app1ication with, nor receive an export 1icense from,
the United States State Department, but that he wou1d inform
BOCA that a 1icense to export the machine guns had been
obtained.
16.
defraud that the defendant, SARKIS G. SOGHANALXAN, wou1d and

did require BOCA to obtain an irrevocab1e 1etter of credit as the
means of payment by BOCA for 197 HBM2 .50 ca1iber machine
guns and de'signated accessories.
To accomp1ish this, BOCA
obtained an irrevocab1e 1etter of credit at the Banque

Bruxe11es Lambert, S.A. in Antwerp, Be1gium in the amount of
$1,153,590.00.
17.
defraud that since the funds avai1ab1e under the Be1gium

1etter of credit wou1d
h~
and were payab1e
~o
the defendant,
SARKIS G. SOGHANALXAN, on1y upon presentation to the bank

by the defendant or his representative of certain specified
documents which inc1uded (a) a certificate of United States
origin and the year of manufacture for the machine gun;
certificate of inspection for the machine guns;
(n)
(c) an airway
bi11 certifying that the armaments were in custody and ready
-6-
..
for immediate shipment;

(e)
commercia~
(d) a certificate of insurance;
invoices stating the armaments were of curren.t
United States manufacture, and (f) a copy of the e:xport
~icense
for the machine guns, that the defendant, SARKIS G. SOGHANALIAN,

would and did present and cause to be presented to the Belgian
bank false and fraudulent documents as
comp~iance
with the con-
di tions set forth above.

18.
It was further a part of the scheme and artifice to
defraud that in or about November,
~977,
the defendant,
SARKIS G. SOGHANALIAN, would and did cause an employee of QRC

to obtain
~etterhead
stationery and a corporate seal for a
company, Browning Precision

19.
Too~
Co.
defraud that in or about November,
~977,
the defendant,
SARKIS G. SOGHANALIAN, caused to be prepared, among others,

the
fol~owing
documents, knowing that the representations
contained therein were

~ist"
or
"~iste
fa~se
and fraudulent:
(a) a "packing
de colisage" representing that
crates were in e:xistence, containing the

guns and accegsories;
~97
~97
packing
HBM2 machine
(b) a certification that the weapons
were inspected and found to be newly manufactured in
~977;
(c) a certification that the weapons were of United States

origin and again that they were
(d) an airway
bi~l
new~y
manufactured in
certifying that the
~97
~977;
HBM2 machine guns
were in the custody of the shipper, Air Trade (UTI) Ltd. and
ready for immediate shipment to Mauritania.
20.
defraud that the defendant, SARKIS G. soGHANALIAN, appointed

an
emp~oyee
of QRC as his agent and provided that
emp~oyee
with his power of attorney to represent the defendant in the

transaction
re~ating
to the
~etter
of credit.
-7-
21.
defraud that on or about November 18, 197.7, the defendant,

SARKIS G. SOGHANALIAN, through his agent under power of
attorney would and did present the false and fraudulent documentation in safisfaction of the conditions set forth in the
letter of credit, the certification documents being written
on the Browning Precision Tool Company letterhead.
22.
defraud that the defendant, SARKIS G. SOGHANALIAN, would and

did authorize certain amendments to be made to the documents
as required by the bank.
23.
defraud that following presentation of the required documents,

the defendant, SARKIS G. SOGHANALIAN, would and did cause the
Banque Bruxelles Lambert, S.A. to release the $1,153,590 under
the letter of credit, and make payment to the defendant by wire
transfer to the defendant's bank, account number 19-126826,
at the Irving Trust Company, in New York, New York.
24.
defraud that following the receipt of full payment the

defendant, SARKIS G. SOGHANALIAN, would and did
no~
deliver
any of the weapons called for in the contract with BOCA but
would instead utilize deceit and deception to "lull" BOCA into
believing delivery would be made.
The tactics utilized by
the defendant included, but were not limited to, the following:
(a) in or about December, 1977, the defendant, SARKIS G.
SOGHANALIAN, caused BOCA to be informed that delivery of the
weapons was delayed due to mechanical difficulties with the
aircraft, knowing that said representation was, and would be,
false and fraudulent when made;
-8-
(b) on or about December 1.8, 1.97'7, the defendant, SARKIS

G. SOGHANALIAN, caused BOCA to be informed that whil.e the HBM
machine guns were in a warehouse in Lisbon, Portugal., del.ivery
woul.d be delayed pending receipt of an export l.icense from
Portugal., knowing that said representation was, and woul.d be,
false and fraudulent when made;
(c) on or about January 25, 1978, the defendant, SARKIS G.
SOGHANALIAN, caused the Banque Bruxel.les Lambert,
s. A. and
boca to be informed that the del.ay in shipment of the weapons

to Mauritania was due to the movement of the weapons, knowing
that said representation was, and would be, false and fraudulent
when made;
(d)
in or about February, 1978, the defendant, SARKIS G.
SOGHANALIAN, caused BOCA to be informed that further del.ays

were due to the Portugese national. hol.idays, knowing that
said representation was, and would be, fal.se and fraudulent
when made.
25.
defraud that the defendant, SARKIS G. SOGHANALIAN, woul.d and

did convert to his own use the monies paid by BOCA.
26.
defraud that wire and radio communications and the United

States mails woul.d be and were used in interstate and foreign
commerce
27.
~n
furtherance of the scheme.
On or about each of the dates designated by each
count enumerated bel.ow, in the Southern District of Fl.orida,

the defendant,
did knowingl.y and wilfully, for the purpose of executing the
aforesaid scheme and artifice to defraud and to obtain
money and property by means of false and fraudulent pretenses,
representations and promises and attempting to do so, wil.full.y and knowingly transmitted and caused to be transmitted
by means of wire and radio communication in interstate and
-9-
foreign commerce, writings, signs, signa1s and sounds

as set forth in each enumerated count be1ow:
APPROXIMATE DATE
COMMUNICATION
May 6, 1977
An internationa1 te1ephone
ca11 from John Ra1ph in
London, Eng1and to SARKIS
G. SOGHANALIAN in Miami
Beach, F1orida.
May 16, 1977
ca11 from SARKIS G. SOGHANALIAN
in Miami Beach, F1orida
to John Ra1ph in London,
Eng1and.
June 2, 197'7
Eng1and.
Ju1y 29, 197'7
Eng1and.
August 22, 197'7
Eng1and.
September 1, 197'7
Eng1and.
September 22, 1977
Eng1and.
November 15, 197'7
Eng1and.
December 3, 1977
An interstate te1ephone ca11

from Robert Burr in the Metropo1itan Washington, D.C. area
to SARKIS SOGHANALIAN in
Miami Beach, F1orida.
COUNT
1
-10-
~~
January
~2,
1978
An international telephone
ca~~ from John Ralph in
London, England to SARKIS G.
SOGHANALIAN in Miami Beach,
F~orida.
~2
January
~3,
~97.8
ca~l from John Ralph in
London, Eng~and to SARKIS G.
F~orida.
~3
February 5,
~4
February 6, 1978
An internationa~ te~egram
from Ra~ph to SOGHANALIAN
in Miami Beach, F~orida.
~5
February 7, 1978
An internationa~ mailgram
from United Trade International
in Miami Beach, F~orida to
John Ra~ph in London, England.
~6
February 8, 1978
An international te~egram
from John Ralph in London,
Eng~and to SARKIS G.
An internationa~ telegram
from John Ra~ph in London,
Eng~and to SARKIS G. SOGHANALIAN
in Miami Beach, Florida
~978
F~orida.
February 9,
~7
~ 9 7.8
An
internationa~ te~ephone
ca~~ from Captain Ahmadou
Anne Baba~y in Paris, France
to SARKIS G. SOGHANALIAN in
Miami Beach, F~orida.
March 9,
~8
Al~
in
~97.8
An internationa~ te~egram
from John Ralph in LOndon,
Eng~and to SARKIS G. SOGHANALIAN
in Miami Beach, Florida.
of Title 18, United States Code, Section
vio~ation
~343.
COUNTS
~-
The Grand Jury repeats and reallege paragraphs
through 26 of Counts
2.
~9-20
through 18 as if fully set forth herein.
count enumerated below, in the Southern District of
F~orida,
the defendant,
did
knowing~y
and wilfully, for the purpose of executing the
aforesaid scheme and artifice to defraud and to obtain money

and property by means of false and fraudulent pretenses,
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representations and promises, and attempting to do so, knowing1y

and wi1fu11y did p1ace and cause to be p1aced in an authorized
depository for mai1 matter, and did cause to be de1ivered
by the United States Posta1 Service according to the direction
thereon, certain mai1 matter as set forth in each enumerated
count be1ow:
APPROXIMATE
DATE
COUNT
ADDRESSEE
MAIL MATTER
19
Ju1y 11, 1977
305 N. Hibiscus Drive
Miami Beach, F1orida
A 1etter from John

Ra1ph containing the
contract between
BOCA and UTI for the
machine guns.
20
Sept. 11, 197'7
A 1etter from John

invoice for the 197
.so ca1iber HBM2
machine guns.
A11 in vio1ation of Tit1e 18, United States Code, Section

1341..
COUNT 21-29
1.
The Grand Jury repeats and rea11eges paragraphs 1
through 26 of counts 1 through 20 as if fu11y set forth herein.

2.
count enumerated be1ow, in the Southern District of F1orida,

the defendant,
did knowing1y and wi1fu11y, for the purpose of executing the

and property by means of fa1se and fraudu1ent pretenses,
representations, and promises , and attempting to do so, wi1fu11y
and knowing1y negotiated and caused to be negotiated the checks
drawn on account number 19-126826 at the Irving Trust Company
in New York, New York as
se~
forth more fu11y in each enumerated
count be1ow, thereby caus ing the funds represented by eacn

said check and the check itse1f to be transported in interstate commerce between New York City, New York and Miami, F1orida,
knowing that said funds had been taken and obtained by fraud:
-12-
APPROXIMATE
DATE
COUNT
,,
~
CHECK
NUMBER
PAYEE
AMOUNT
PAYOR
21
Dec. 16,1977
353
SARKIS G.
SOGHANAL:IAN
SARKIS G.
SOGHANAL:IAN
22
Jan. 12,1978
364
Fred Jenner
SARKIS G.
SOGHANAL:IAN
$5,000
23
Jan. 17,1978
370
CASH
SARKIS G.
SOGHANALIAN
$5,000
24
Jan. 24,1978
369
:res,
SARKIS G.
SOGHANAL:IAN
$65,000
25
Feb. 3,1978
375
Southeast
First Nat'l
Bank
SARKIS G.
SOGHANAL:IAN
$10,000
26
Feb. 3,1978
379
Gonzalez Bros.
Construction
SARKIS G.
SOGHANAL:IAN
$5,500
<
27
Feb. 9,1978
380
:res,
Inc.
SARKIS G.
SOGHANAL:IAN
$25,000
28
Feb. 10,1978
381
:res,
Inc.
SARKIS G.
SOGHANAL:IAN
$20,000
29
F~b.
382
United Trade,
Inc.
SARKIS G.
SOGHANAL:IAN
$'8, 000
10,1978
Inc.
$150,000
All in violation o Title 1.8, United States Code, Section

2314.
COUNT 30
l..
The Grand Jury repeats and real.l.eges paragraphs l.
through 26 o Counts 1 through 1.8 as i ull.y set orth herein.

2.
on or about the irst two weeks o July 1.977 in the
Southern District o Florida, the defendant,

did knowingly and wilfully, or the purpose o executing the
and property by means o alse and raudul.ent pretenses,
representations and promises, and attempting to do so,
transport, cause to be transported and induce to travel.
in and to be transported
~n
interstate commerce two persons,
to-wit: John Ral.ph and Captain Ahmadou Anne Babal.y, travel.ing

rom New York to Miami, Florida;
-1.3-
-- --- ---- -------
All
~n v~olat~qn o~ ~~tle la~
Un~ted
states Code,
Sect~on
A TRUE BILL
FOREPERSON
AT E _
UNIT D STATES ATTORNEY
M&~
PENBe GJ:LLMAN
ASSISTANT
UNIT~D
.
STATES ATTORNEY
-:-14-
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_:-::=~'Cc'---=:--=--=--:::_"-...:--:::--c=-=-=---=-=-~=-~~~~~-=-~~:'::--=---,..::::-=--=-=-=-=--=-=--=---:.:::.::_
_ __;_:_:;_;______:;____;;;_:.__::___:___,1
SBG~m~w
uNITED STATES' DISTRICT' COURT

CASE NO.
UNITED STATES. OF AMERIC~
v.
ESTIMATED TRIAL TIME
~--~~----------~----~---)
CERTIFICATE' OF' TRIAL ATTORNEY
I do hereby
1.
~ertify
have carefully cons'idered the a~~egations .of the
indictment, the number .o.f defendants, the number of
prob~ble
witnesses ~nd' the legal comple~iti~s of the indictment/

attache~
2'.
hereto.
I
am aware ~hat the i:nformation supplied on; tl:lis
stateme-nt will be relied upon by the Judges of thi'S Cour~

in setting their calendar.s and scheduling criminal trials
under the mandate of the sp~edy Trial Act, Title 18, u.s.c.
'3161.
3.
This case ~i~l. take 2-3 weeks for the parties to
4.
'(check the
try.
I
II
~II
IV
~pprop.riate
9ategory)
to less than 3 days
3' to less .than 7' days
7 days to less than 3' weeks

3' weeks
(l.S days)
(15 days) to less than 6 weeks

(30 days)
~eeks
to
~ess
than 3 months
-VI
3 months .to less-than -6-moin:'hs~
VII
6 months or more
B.
GILLMAN.
THE UNITED STATES
~-
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~o-302 (REV, 3-..77)
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Jnv~ti9Uon oo--7:..t-/.:2.::2:,.t;/..;8;:;,;l::;...____ ,t _.;.M,;;1::;a:::m:;:;:i::.:,z-:::.F;:::l;,::O:;.:I'::.:i:.;:;::d::;:a:::,______ FI~
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July 31,. 1981
PERSONAL
''
b6
BY LIAISON
'
Investigator
The American Embassy
Lisbon, Portugal
Dear.._l_ _ _ ___.l
Speclal. Agent oh~s ~d~lsed. me that you assisted
.
him and Assis~ant United States Attorney.....

l _ ____.l while they
were in your country investigating: a. case and that you: served
most capably as their translator.
;
'
We certainly appreciateyour
.professional help in_ this mat:ter and' want

sincere gratitude.
'
you. to
know of our
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.sincerely yours,
~#M/2:;;WilliamH. Webster.
Director.
lY - Miami
I,
(l96A-l056).
Reurairte~
L - Paris.
7/15/81.
(._1:._~.-i--
_/~~-z;.: ..-/6#
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\July 3l, 1981
,,
.PERSONAL
BY LIAISON
,.
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I.Reglonal Sec!lrUy otlicer
The'American Embassy
Iiisbon, Portugal
b6
b7C
De a~~--------~
we :ln the FBI are most appreciative of the assistance :you gave Special Agent DandAssistant United States
At~orney I
' lin a recent case which required their travel
to Portugal.
was
a great
Your 'liaison with the Judiciary Police at Lisbon '

help, as ;as':Your ability t~ oo.taln the cooperation.
'o~ the Por,tugese Military.
I understand -that you also handled.
/rrangements for their lodging ~nd transportation . I again

thank you for your hospitality .and assistance .
Sincerely _yours,
i~H-~--.c_
,William H .Webster
Director
- Miami
(196A~l056)
Reurairtel 7/15/81
.1 - paris
..
-~Enclosure
/!, !r.
6 198.1
FSI-MJAMJ
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. FEDERAL BUREAU OF INVESTIGATION

:!
~t of trnserlptlon._ _S_/_5...;/_8_1__.....,_
., .
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Special Agentl
lanpeared before Federal Grand
.1.
b3
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3.
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rnv~no.ation on _ _....7._./,_..,2..~,2~/t...81..1...1l_......_
_.._ .. t_......Mu...r.i.s;aum.~.~.~.i,...,~f~l~o~..~r..:.l.~o~du:;a;~._~----
.,
bv~~----------------~~----------~---~'~m~j~s~~~t
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~uly
31, 1981
'PERSONAL
BY 'LIAISON
Chief
u.S.A. I .D.
'I'he American 'Embassy

Nouakchott, Mauritania
b6
b7C
Dear~~----------~
~
am deeply appreciative
of the assistance you
.
'
.Provided Special Agentr-~-----.pur.ing his v.isit to Mauritania

'in June, and he joins me in extending warmest thanks .for
your help.
Your service as an interpreter and .your
b~iefing
on the political situation and customs in Mauritania were

essential to the .achievement of our investigative .90U and
we are most grateful for your cooperation.
Sincerely yours,
ILAit~ fj-.~
William H. Webster
Director
~ Miami (196A-1056)
Reurairtel 7/15/81.
/Wf: 6 1901
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July :Jl, l981
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.PERSONAL
BY .LIAISON
I
~c-b~a~r~g~e~d~.~A~t~ta~i~r~e~s~----~
The American ~bassy

Nouakchott, Mauritania
b6
b/C
Dear~~-------------4
'.,
,.
Special Agentl--ljoins me' in extending ~armest
thanks for your assistance--auring .h'ls recent visit to your
country. We certainly appreciate your arranging :lodging and
transportation and coordinating liaison with officials of the
Mauritanian Government. Without your help, our full investigative objectives could .not .have been accomplished, and
we are deeply grateftil.for your cooperation. Please do .not
hesitate to contact us t:henever we can be .of assistance to
_you.
Sincerely yours,
~~#~
William H . webster
I
Director
'
(!}-
l1iarn1 (196A-1056)
Reurairtel 7/15/81
..
AUG 6 198.1
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3uly -31, 1981
PERSONAL
BY LIAISON
Secretary
Office of West.African /Affairs
'
united States Department of State

Washington, o. c.
,.
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b6
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b7C
Dear I~----------~
I deeply appreciate the .assistance you .provided
the PBI in obtalning -~visa_ for Special Agent D i n order
that be could travel'to Mauritania toconduct interviews and

gather documentary evidence for one of our investigations.
~--------~lvisit proved
'investigative
very
benefi~lal to ou~
objecti~escould
case and our
not have been achieved with-
out your help. He joins me 'in extending. warmest 'thanks .for

.
your cooperation.
'
Sincerely yours,
I
/.~/~
.L~t~.#~~
WilliamH. ~webster
Director
'(y- 'Miami
(l96A-.l056)
Reurairtel. 7/15/81.
, l~v /1-:rd./Z"' l7I

'~?~.~~{ftl
SERW.IZEO
mcutn'Y----t
X:: BI..ED----1
1\t.}r, 6 1981
FBI-MIAMI
l I
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July '31, 1981

PERSONAL
BY LIAISON
Country ottlcer for western

Sahel Countr-ies
u. s. Department of State
washington, D. c.
Dear .____I_
b6
b7C
_____.I
I
want to take this opportunity to express my per-
sona! appreciation for your invaluable assistance to Spec ial

AgenO and Assistant United States 'Attorney
lin
connection with their travel to Mauritania to interview witnesses in one of our investigations.
We are truly grateful
.,
for _your help which enabled them to more effec'tively carry

~hanks
out their responsibilities in this case.
again for
your fine cooperation in this .matter.

Sincerely yours,
(uJ~
N-tvdf!;;-William H. Webster
Director
(Y-
Miami U96A-l056)
Reurairtel 7/15/81.
17~/1-- /cJ~-6 -17~

'su;-:cHFD.
li\CWD---1
l~1\!.>.LIZto__t:::mw._"- - " ' i
P,UG 6 1981
FBl-MlAMl
--~------------------~----~----~--------~------------~----~--~----------.~.
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July 31, 1981

PERSONAL
BY LIAISON
Country Officer for Western

Sabel Countries
u. s. Department of State
Washington, D. c.
b6
b'7C
Dearl
, lease add my personal- thanks to those of Special

Agcn~and Assistant United States Attorney!
lfor
your ~o=ut~s~t~anding cooperation in coordinating their travel
to Mauritania., i'la are most. grateful for your assistance in
establishing contacts with officials of the Mauritanian Government who were. witnesses in one of our investigations.
Your efforts on their behalf greatly aided them in accomplishing their objectives, and we are indeed appreciative
of your help.
Sincerely yours,
(~N-~
William H. Webster
Director
(!)- Miami
(196A-1056) - Enclosu~es (6)

7/15/81.
Reurairte~
Stt.:":tHt[):
lNDEXE~D---t
S$1AU2ED---lL.fJLED-'_ ___.
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/WG 6'1981
FBl-MIAMl
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te GA
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AUG 1 0 1981
'~t~OO .s OQHA NAl..IAI,SARliS GARAB~.Il.ll~l~~-20629. 508.230.

- --~
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R0.3LK.4 DA-A11652240 260~.C50J81.196A-1055.

l,OOC,OOO, C
? SURETY OFF/2608
& 28
>!NU/INS #
FLFEI :t:;o
NCIC
ENTER
SUPR. QVH. AGENT
WI
./ ~
MOOIFYO
CLEAR 0
CANCEL 0
....--....L..--_AU_G~ 7 1981
LOCATED
D.-\1~/);j
NCIC #t
cj~\o Q } ~ &0( ()
_L-
8/7/81
l>2c~te: ,
.INSTRUCTIONS Rever$e side
NOTE: Priorit}' A ant;! a Fugitive,s- With initial_151,l.brni:y;sion,
MIAMI (196A-1056)(P)
:sAc.
AIRTEL
"Set forth $ytl(W$is of :ctum .on revers~ .sia.
6
b7c ;
SARKIS GARABgf SOGHANALIANTFDG~TIVE,
DBA UNITED TRADE INTERNATIONAL,
.I
~;..
ll"
:;MF, nJcriM
,
b
.t::J~itl~ 'Submission
c:l 'Suppl~o,ts :Ft>Q5 d a t e d - - - - - -
(00: MIAMI)
..
ln,dicate Fugitive Priority
.~
CJB
r:JC
NAM Sex 5E.XRace RAC
.MKE Name
Caution
POB
Eye Colot
SARKIS GARABET SOGHANALIAN
EYE
H~r
:BROliN
Birth ~t,
008 Height 1_G_T Wei~hin WGT

5 1 8"
G.;~V
2/b/29
SKH
HAl FBI No.
Colot
BLACK
SMT
Scars, Marks, Tatto<, .etc,

FPC Oth~rJ~nHfying Numb\':t
....
MNU 'Soeial Secl.llio/ #
SOC
INS #All 652 240
OLH
'Qper~or'_s
OLS Ye.tr( ExPire
License State
OL Y
.Hail;. Fraud, Wire Fraud, Interstate Trans. ot Stolen Propert~

u. :s. Code.l'itle ~ Sectioo 18, USC, Sections 1341, 1343, 2314
DOW F. Q. File IIOCA
Warrant tss~d By.
USDCJ J~e Eaton J .. ~ac.
00
_$/7 /81
196A-1056
t>ate PBV Q~ Bond Deflt Case Referred to Omco
Offen.u Cha.rgt~ OFF,
Mi.i5-eUEineou~ Inchxding Bond ~ecom.;rte'ndf<:!
MIS Fingerprint Classlficatioo <Henry
Sy~em)
s1 ;qo6 tboo -corporate

LICENSE PLATE AND VEHICLE INFORMATION
Lic~.n$(l
Pll!lte .Numlm
Vehicle ldentific$.tion #
LIC State
YIN Yeax
VYR.Make
LIS Yeflt EJq>ires
LIY LteMe P.late
VMA Model
VMO
Styl~
/
Aliases
NlC
,
Ty~
VST Color
LIT
v~o
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Subject indicted by raJ. SDF, on -8/S/Blt and charged
wi'th wir,e/mail .b-aud and ITSP J.n, COMt'ction-wl-th
a fraudulent I ' . "
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weapons transaction. SUbject rec;t1vec1, in -excess ot .tl_,ooo,ooo ,, '

in payment -blr.so caliber aachine ~ to, the ;lal..Uc . . , . ,... ,.
Republic ot Mauritania, but 1'ail~ ;tb c1,1verI any:ot the '1 ,, ~o~~""'
Weapona.
ti
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'FD-515 (R.e~6.78)
STATISTICS LETTER
TO: DIRECTOR, FBI
Date: __a I
..!/- I -Bl.
Bureau File Number

FROM: SAC,MIAMI
(P)
F.O. File Number
SUBJECT:- SARKIS GARAB~ .SOGHANALIAN-FUGITIVE,

AmA tmiTED mADE INTmNATIONAL, ETC.
P"'l
A.
lviC1'IM
PRELIMINARY JUDICIAL PROCESS
1. _
2. _
3. ,..1_
4. _
D.
Complaint
Information
True Bill
No Bill
-==
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FINAL JUDICIAL PROCESS
~ ill=-o
1. ~
2. _
3. _
4. _
ARRESTS I LOCATES I SUMMONS
_Q_
2._
1._
3._
5._ 6._
4._
7. _
Criminal Summons
E.
Pretrial Diversion
Dismissal
Acquittal
Conviction-Misdemeanor
_
No. of Counts
5.
6 . _ Conviction-Felony
_
No. of Counts
7.
SENTENCES
1. _
2. _
3. _
4._
RECOVERY AND LOSS PREVENTED

1. Recovery
2. Potential Economic
Loss Prevented
F.
5.
(No. of Subjects)
Confinement
Probation
Suspended
Fine
$
FBI Arrests
FBI Locates
(No. of Subjects)
$
$
CIVIL MATTERS
~
Government Defendant
c.
(No. of Subjects)
FUGITIVE PRIORITY
'
B.
"'-F...Blf; MFJ ITSP
(No. ot Subjects)
..
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1. Amount of Suit
2. Settlement or Award
$
$
Government Plaintiff
3. Amount of Suit
4. Settlement or Award
Amount of Fine
$
$.
REMARKS:
~ra[ >
t)THALI~JI~ (3)
418
* Include subc~ter if applicable.

L-=:.::.-..;..::_:c:--c.;_:-::.:_-=-'-'-'-:c.__.=~::_:--_:__--=-..=_c--:._:_-.=_--'-'----'-----'-----
~-~
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t, /1- /d~?, ... 11J
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- - - --
--~-~-~~~--
INSTRUCTIONS
,.-...,
I
I
Sub=it an original only of the FD-515 within 30 days of a re<:orda'ble aceo~plisb,:o.ent. Sub=ission of
each statistic should not be delayed awaiting th~ ace;u.to.\l.lation of several statistics.
'1
(1)
(2) Tbe date the Fl>--515 is subzitted must be shown.

(3) Tbe field office file ll.Ul)).ber and appropriate subclassification. if awlicable. =nst be set forth. '
<4> Category A - .. PRELIMINARY JUDICIAL PROCESS" This indice.tes the nu:mber: of subje:ets again$t
whom judicial action has taken place. The n\lllO.ber of subjects must be indicated with a nu.merical entry and not
with the letter .. X" or a check mark.
FOR EXAMPLE: If 4 subjects have 10 Bills of Indictment returned against them. enter 4 OQ line 3.
<5> Category B ... FINAL JUDICIAL PROCESS"- This. again. fndicates the nu:ml;Jer of subjects and.
the number of counts or violations for which the subject is convicted. Tbe n='bet of counts $hown on lines 5 and
7 rAUst equal or exceed the number of subjects indicated on lines 4 and 6. never be leu. Category 4 and 5 or 6 and
7 cannot be <:!aimed prior to sel).tencing.
FOR EXAMPLE: IC a subject is convicted for multipl~ counts in a single indictmel).t or is convicted on
a llUl)).'ber of individual indictments, the entry in either case will be one subject convict~.
(6) Category C- .. SENTENCES" ~Indicate only the n\lllO.ber ofsubjec_ts and where a eo~bination of
aentences are l.m~d. enter only the most severe sentence. The ll.Ul)).ber of subjects cannot exceed the nu:mber ot .
sub;ects indicated in Category a, lines 4 and 6. The amount of the fine (line 5 ), if any. is always claimed in
conjunctiOn with either lines 1. 2. 3, or 4.
priorities.
<7> Category D ... ARRESTS/LOCA YES/SUMMONS" -Indicate the number of subjects \lnder designated'
-...;.:;..
-----.
<8> Category E..-"RECOVERY-AND LOSS PREVENTED"- Recoveries. When $tolen or illegally

Posses$ed items with int~insic value are reovered as a part of an FBI investigation, the, value of the ite= should
be recorded. Restitutions will be recorded in this category when ordered as part of a sentene.
Potentiol Economic Loss Prevented w Record items such as counterfeit securities, ;!.Olley orders, Cashie:r
Checks, Travelers Checks, and pirated copy-light 'and patented material.
.
'
A iustifi~tion airt1l nl.Us,t ~--'Ub=~tted with the FP-515 as an encl0$ure when the. recovery or pote.ntial
econOl:llic loss prevented ex~ds'U,OOO,QOO,.
11
(9) Category F- CIVIL MATTERS'" To record an entry in this category. it is necessary to con.duct
actual investigation ill. the matter. l3oth the original Sl)).ount so~ght and the damages awarded by the court are to
be recorded under amount of suit and $ettlement or award< Therefore. if numbers 1. or 3 are completed, it is
necessary that number 2 and 4 als0, b.. completed even if by zero. The only ex<:eption would be when monies are
in Ascertaining'
Financial
Ability Matters wherein it is Mt necessary to record an entry F3.
paid by the sul?ject
\~
~~1~
$~1'>..<,1!.'4-!
!tf
( 10> "REMARKS" -ldentify the nal)).e ot the subiect<s> and when reportiri.g a convi<:tion ~deXltify the,
Title, Section, and Code. applicable to each count convicted~
<11> Errors .I( a previously submitted Fl>--515 is determined to conta,in an error after verifying the
statistic on the Monthly; Statistical Renlts RepOrt, submit an orig'inal only or" the FD~515" clearly marki.Jlg the top of
the form Sn red in% with Ute.word "AMENDED)" Otb.er than th~ title. FJ3IHQ rne ~her (if known>J field office file
nu:mber, and date, only complete the category being ~rected by a nwne.rica,l entry representb:ig the appropriate
decrease or increase. lf"tbis e.ntry represents,~ decrease~ in$ert-a ~inus ~ -" si~ and jt an inc~ase. insert a
plu$ +'' si~ directly to the'left Q( the nu:metical eiltries whiCh 'will signify the type_ of correction.,
,
,.
~ ':l'~~ for Arrest of Defend=t ( 7-52).
---------
llluitr~ ~tntr.a
Cr. Form No. 12
1lli.atrfrt <!tnurt
FOR THE

UNITED STATES OF AMERICA
v.
SARKIS G. SOGHANALJ:AN
81-34o-CR':"'.JE , _
C::-
No.
--
o:;
.-
.~;=::=~-~:.-:::.--:~
ANY U.S. MARSHAL OR ANY OTHER AUTHORIZED
To1
'
You are hereby commanded to arrest
SARKIS G. SOGHANALJ:AN
forthwith before the United States District Court for the SOUTHERN
in the city of
to answer to an
.:
.:..
;!;;_;;::::=:.-
..
c::;:::.:~
- I
and>bring-~:1m
District of~FLORIDA
charging him
INDICTMENT
"i.W"ii."":Y.."'ii:
t?~it!t~
:.:::::...-::: :
with
Dev:ising a scheme to defraud & obtain money & property from BOCA Investments, L~ited
& the Govt of the Islamic Republ:ic of Maur:itania. Cts. 1 to 18.
Placed :in an authorized pedos:itory for mail matter certain mail matter for the purpose
of executing a scheme to defraud. Cts. 19-to 20.
Negotiated checks drawn at the Irving Trust Co. :in New York knowing sa:id funds had been
obta:ined by fraud &~transported_:in :interstate commerce. Cts. 21 to 29.
Caused to be transported :in :interstate commerce two persons for the purpose of execut:ing
a scheme to defraud. Ct. 30
in violation of
18:1343
18:1341
18:2314
18:2314
.-.o.v.-....-:.
-:..-.-:::::.~
.:::...-!.:.-
M'IAMI, FLORIDA
Dated at ---------------------------------AUGUST 10,
81
on ---------------- --------------- 19 ---NO BOND SET.
Bail fixed at$------------------
JOSEPH I. BOGART
------------------------------------------
~
Clerk.
By
-./&~-~--~---------
tf7 Deputy Clerk.
ss
day of
Received-the within warrant the
and executed same.
------------------------------------------
------------------------------------~--
- Insert designation c4 offieer to whom the warrant is issued, e. g., "an7 United States Marshal or any other
authorized officer"; or United States Marshal !or---------- District of----------"; or "any United States Marshal";
or "an7 Special Agent of the Federal Bureau of Investigation"; or "an7 United States !Jarshal or an7 Special Agent of
the Federal Bureau of Investigation"; or "any agent of the Alcohol Tax Unit."
Certified to be a true and

correct copy of the orig1nal
.Joseph I. Bc.gart, Clerk

U S. Dletrict Court
8~mD~~~
7
Cl~rk
Deputy
Date
--
//..~ /9"Q
-
,. =
.....
'
' '
- ! ..
~~:
(:;.;.;.;.;.;..:;::.:::
;::::=~:~~:;:~-=~
19
By
-----------.-;..
~~~ti\
RETURN
District of
;::~-:.-:-~-:.z
~~~:=~~~~~
~~~~~r[~~~~
~~:=~~:::~~~=~
/
.
_,-
SBG:m1w
UNITED STATES DXSTRXCT COURT

SOUTHERN DXSTRXCT OF__ FLORIDA
lmS
la
-;,.?.cfls/lrer:Jf
M/S 5 years - $1,000 18 u.s.c. 51343
.
M/S syears- $1,000
18 u.s.c. 2314 -M/S 10 yea;-s
P"JfEtf>8v___
UN:ITED-STATES OF AMERICA
INDICTMENT
v.
SARKIS G. SOGHANAL:IAN
The Grand Jury charges that:
:INTRODUCTION
1.
Un~ted
Trade :Internationa1, Inc.
referred to as "UTI") i.s a

corporated i.n the
~~es pert~nent
305
~orth
F1ori.da,
s~ate
to this
Un~ted
(hereinafter
States corporation, in-
of De1aware i.n 1975.

i.ndi.~tment,
During a11
UT:I maintained offices at
Hibiscus Drive, Hibiscus :Is1and, in Miami. Beach,
whi.~~
i.s the resi.dence address of the defendant,
SARKIS G. SOGHANAL:IAN, as we1! as in Ar1i.ngton, Virginia.

The defendant, SARKIS G.'SOGHANAL:IAN,
however he at a11
t~es
a1so
wa~
exerc~sed
t~e
overseas agent,
ownership, domi.ni.on
and contro1 over UTI and a!1 its assets.

2.
Dur~ng
a11
t~mes
pertinent to this
~ndi.ctment,
UT:I
a1so .transacted business and was known under the name of

United Trade :Internati.ona1 Ai.r cargo
referred to as "Air cargo")_.
w.
(hereinafter
Air car-go, whi1e having no
1ega! existence apart from UT:I,

at 276 s.
L~i.ted
mainta~ned
a mai.1ing address
33rd court, Ft. Lauderda1e, F1ori.da.
The de-
fendant, SARKIS G. SOGHANAL:IAN, whi.1e not the named owner of

Air cargo, exercised fu11
ownersh~p,
over its activities and assets.

... -
---
....
----
-- -
dom~nion
and contro1
Dl
..
.-
3.
During a11 times pertinent to
th~s
indictment, UTI
was the registered owner of a Boeing 707 jet aircraft with

united St<ltes registration N711UT, having acqu:ired said
aircraft on June 26, 1975.
4.
(herein~fter
QRC :International.; Ltd.
referred to as
"QRC")._is a_United States corporation, incorporated in the

State of Del.aware in 1974, doing business in the commonweal.th
of Virginia. During al.l. times pertinent to this
QRC was empl.oyed unde_r
services for UT:I
5.
a~d
contra~t
the
~ndictment,
to perform, and did perform,
de~end.ant,
SARKIS G. SOGHANALIAN.
Air Trade Limited, which is also known as Air Trade
(UT:I) ~td.
(hereinafter referred to as "Air Trade"), is a
company formed in Nicosia, Cyprus in 1.976.

pertinent to this indictment, the
At al.l. times
defenda~t,
SARKIS G.
SOGHANALIAN, was the chief executive officer and director.of

Air Trade, and control.led its activities.
SARK:IS
as
SOGHANALIAN, authorized Air Trade to be represented
G~
-~eir.>.g
The defendant,
~ubsidiary
of UT:I and Air Trade was, in fact, so
represented.
6.
Browning Precision
Too~
Company, Inc.
(hereinafter
re:ferred to as "Browning") is a United States company, first

- incorporated on April. 24, 1.978 in the
~tate
of_ Dela_ware.
During al~ times pertinent to this indictment, the defendant,

SARKIS G. SOGHANALIAN, was a director and majority stockholder of Browning, and c_ontrol.l.ed i.ts activities.
Browning
was represented by tlie defendant, SARKIS G. SOGHANALIAN, as

having a busi.ness address .at 2'76
Lauderdal.e,
7.
s. W. 33rd Court, Ft.
Fl.orida~
United :Industries, Inc.
,united In_dustries")
Beirut, Lebanon.
(hereinafter- referred to as
i_s Cl. company establ.ished in 1969 in
During al.l. times pertinent to this indict-
ment, the defendant, SARKIS G. SOGHANALIAN, was an owner of

United :Industries, and control.l.ed its activities.
During al.l.
times pertinent to this indictment, the defenciant, SARKIS G.

SOGHANALIAN, maintained a bank account at the Irving Trust
Company in
N~w
York City, which was in his personal name and
in care of United Industries.

-2-
.. .
BOCA InJittments, Limited
8.
(hereina~r
referred to
as "BOCA") is a company establ.ished under the l.aws of the

Jersey States in the Channel.- :Isl.ands, which are isl.ands l.ocated
offthe coast of Great Britain, in 1.974.
9.
"Defense material.s" is a term that refers to various
items which, among other things, have their export from the
United States to any other country regulated by the United
States Department of State.
A .50 cal.iber HBM2 machine
~un
and any attending accessories are "defense material.s".

l.O.
:In order to l.awful.l.y export defense material.s from
the United States to any other country, the exporter must

first appl.y for, and receive, an export l.icense from the
Office of Munitions Control. at the United States State Department.
Said appl.ication must be
accomp~nied
by a certificate
from the Government of the country where the weapons are

ul.timatel.y to be del.ivered that the
d~fense
materials are
to be used sol.el.y by that country.
Said certificate is
referred to as an "End-User certificate".

l.l..
if
~ul.l.y
This introduction is incorporated and real.l.eged as

set forth in each count of this indictment.
COUNT l.-1.8
l..
From a date uncertain, but being prior to Jul.y 5,
1.97'7, and continuing up to and incl.uding the date of this

indictment at Miami Beach, Dade County, in the southern
District of Fl.orida, and el.sewhere, the defendant,
SARKIS G. SOGHANAL:IAN,
did unl.awful.l.y and knowingl.y devise and intend to devise a
scheme and artifice to defraud and obtain money and property
by means of fal.se and fraudul.ent pretenses, representation
and promises from BOCA Investments, Limited apd the Government of the :Isl.amic Republ.ic
of Mauritania, wel.l. knowing at
,
the time that the pretenses, representations and promises
woul.d be and were fal.se and fraudul.ent when made.
-3-
THE SCH!s AND ARTI:FI:CE TO DEFRAUD.

2.
In or about May, 1977, BOCA and the Government of
Mauritania comp1eted negotiations and entered into an agreement whereby BOCA agreed to supp1y Mauritania with certain
I
described defense weapons which inc1uded, among other items,

a specific mode1 machine gun designated as a
HBM2.
.so
ca1iber
The agreement required the weapons to be new and
of United States manufacture.

3.
Having entered into this agreement, B9CA s_ought a
source of supp1y for said defense materia1s in the United

States.
On or about May 6, 1977, BOCA contacted and informed
the defendant, SARKIS G. SOGHANALIAN, of its requirements to

u1fi11 "its agreement with Mauritania.
4.
It was part of the scheme and artifice to defraud
that the defendant, SARKIS G. SOGHANALIAN, wou1d thereafter

inform BOCA that he cou1d and would supp1y a11 or a portion
of the defense materia1s required.
5.
defraud that upon being informed by BOCA that Mauritania

required new1y manufactured United States weaponry,
~nd
further required an on-si.te inspection of the product that

the defendant, SARKIS G. SOGHANALIAN, wou1d arrange to, and
wou1d conduct, such an inspection.
6.
~t
was further part of the scheme and artifice to
defraud that the defendant, SARKIS G. SOGHANALIAN, would

invite representatives of BOCA and the Mauritanian Government
to trave1 to the United States, in interstate and foreign
commerce, to confer in washington, D.C. with the defendant,
and to thereafter make
anon-~ite
inspection of the armaments
proposed to be furnished by the defendant to BOCA.

-7.
defraud that on or about Ju1y 7, 1977, the defendant, SARKIS

G. SOGHANALIAN, wou1d and did take and accompany the representatives of BOCA and Mauritania to the Numrich Arms
Corporation 1ocated in A1bany, New York.
-4-
. / 8 :rt was furthefltpart of the scheme and a~ice to

defraud that the defendant, SARKIS G. S'OGHANALJ:AN, would and
did represent to the representatives of BOCA and the Mauritanian
government that he was an owner of the Numrich Arms Corporation,
and that the armaments inspected at Numrich were, in fact,
the armaments that he would sell to BOCA for delivery to
Mauritania:.
9.

and did represent to the representatives of BOCA and Mauri.tania
that the weapon inspected,
~hich
was a
.50 caliber HBM2 machine
gun, was newly manufactured in the United States, as would be

any other .50 caliber machine guns sold to BOCA.
10.

and did invite the representatives of BOCA and Mauritania to,
and would, in fact, travel to the defendants' residence, 305
North Hibiscus Drive, Miami Beach, Florida to conduct final
contract negotiations for the sale of the Numrich Arms
.so
caliber machine guns.

11.
defraud that on or about July 9, 1977, the defendant, SARKIS

G. SOGHANALIAN, in Miami. Beach, Florida, would and did orally
agree to sell 200
.so
caliber HBM2 machine guns, together
with specified accessories to BOCA.
This contract was later
amended to call for the sale of 197 machine guns.

12.

and did utilize the
busin~ss
name and entity of United Trade
International Air Cargo Limited to thereafter-enter into the

written contract with BOCA to supply BOCA with armaments.
Said contract was executed by the defendant,.SARKIS G. SOGHANALIAN,
as the representative of Air Cargo in July 13, 1977 in Santo
Domingo.
-5-
..' . ..13.
xt was further a part of the scheme and artifice to
defraud that the defendant, SARKXS G. SOGHANALIAN, wou1d, and

did in or about August, 1977, request from BOCA an End-User certificate from the Government of Mauritania for the 197 .SO
ca1iber machine guns and accessories, and a verification by
the Mauritanian Ambassador to the United States in Washington,
D. C. of the signatures thereon exp1aining to BOCA that these
documents were required to obtain a 1icense to export the
machine guns from the United States.
14.
Xt was further a part of the scheme and artifice to
defraud that the defendant, sARKIS G. SOGHANALIAN, wou1d and

did require BOCA to de1iver said End-User certificate to
QRC, his representative in washington, D.
1S.
c.
Xt was further a part of the scheme and artifice to
defraud that the defendant, SARKIS G. SOGHANALIAN, did not

fi1e an app1ication with, nor receive an export 1icense from,
the United States State Department, but that he wou1d inform
BOCA that a 1icense to export the machine guns had been
obtained.
16.
It was further a part of the scheme and _artifice to
defraud that the defendant, SARKIS G. SOGHANALIAN, wou1d and

did require BOCA to obtain an irrevocab1e 1etter of credit as the
means of payment by BOCA for 197 HBM2 .SO ca1iber machine
guns and designated accessories.
To accomp1ish this, BOCA
obtained an irrevocab1e 1etter of credit at the Banque

Bruxe11es Lamber.t, S.A. in Antwerp, Be1giwn in the amount of
$1,1S3,S90.00.
17.
defraud that since the funds avai1ab1e under the Be1gium

1etter of credit wou1d be and were payab1e to the defendant,
SARKIS G. SOGHANALIAN, on1y upon presentation to the bank
by the defendant or his representative of certain specified
documents which inc1uded (a) a certificate of United States
_,
origin and the year of manufacture for the machine gun;

certificate of inspection for the machine guns;
(o)
(c) an airway
bi11 certifying that the armaments were in cus tody and ready
-6-
--ediate
shipm~. . .;
(d) a certificate of ir.41Fance;
.l..-
commercial invoices stating the armaments were of current
cc )
ted states manufacture, and (f) a copy of the export license
t,ltU.
~or
the machine guns, that the defendant, SARKIS G. SOGHANALIAN,
would and did present and cause to be presented to the Belgian

bank false and fraudulent documents as comp1iance with the con-
ditions set forth above.
18.
I t was further a part of the scheme and artifice to
defraud that in or about November, 197.7, the defendant,

SARKIS G. SOGHANALIAN, would and did cause an emp1oyee of QRC
to obtain 1etterhead
statio~ery
and a corporate sea1 for a
company, Browning Precision Too1 Co.

19.
defraud that in or about November, 1977, the defendant,

SARKIS G. SOGHANALIAN, caused to be prepared, among others,
the following documents, knowing that the representations
contained therein were false and fraudulent:
list" or "liste de
co1isage'~
(a) a "packing
representing that 197 packing
crates were in existence, containing the 197 HBM2 machine

guns and accessories;
(b) a certification that the weapons
were inspected and found to be newly manufactured in 1977;

(c) a
certific~tion
that the weapons were of United States
origin and again that they were newly manufactured in 1977;

(d) an airway bil1 certifying that the 197 HBM2 machine guns
were in -the custody of the shipper, Air Trade (UTI) Ltd. and
ready for immediate shipment to Mauritania.
20.
defraud that the defendant, SARKIS G. SOGHANALIAN, appointed

an emp1oyee of QRC as his
~ith
~gent
and provided that emp1oyee
his power of attorney to represent the defendant in the
transaction relating to the letter of credit.
-7-
_.,.,....,_..,__"'. ..,._..,,..,a...,..,..,..,,..,w..,.....,.__.,._,.,..t".,.,.
. _....
.
..
...
. ?f,...,,__....,,"!
q....,. ...- ......,.,..., ...., .....,......,-._-- -
""""""
~_:-.,.
_'!'l!:''t"""""
?"'~
. _!"-"
'"!'
'~!'?'""-:'l'"'lrif'l'~,::'l'?~t~~-"!'"
,
.._.--
21..
It was further a part of the scheme
and~tifice
to
defraud that on or about November 1.8, 1.977, the defendant,

SARKIS G. SOGHANALIAN, through his agent under power of
attorney woul.d and did present the fal.se and fraudul.ent documentation in safisfaction of the conditions set forth in the
l.etter of
~redit,
the certification documents being written
on the Browning Precision Tool. Company-l.etterhead.

22.
defraud that the defendant, SARKIS G. SOGHANALIAN, woul.d and
did authorize certain amendments to be made to the documents

as required by the bank.
23.
defraud that fol.l.owing presentation of the required documents,

the defendant, SARKIS G. SOGHANALIAN, woul.d and did cause the
Banque Bruxel.l.es Lambert, s.A. to rel.ease the $1.,1.53,590 under
the l.etter of credit, and make payment to the defendant by wire
transfer to the defendant's bank, account number 1.9-1.26826,
at the Irving Trust Company, in New York, New York.
24.
defraud that fol.l.owing the receipt of ful.l. payment the

defendant, SARKIS G. SOGHANALIAN, woul.d and did not del.iver
any of the weapons cal.l.ed for in the contract with BOCA but
woul.d instead util.ize deceit and deception to "l.ul.l." BOCA into
bel.ieving del.ivery woul.d be made.
The tactics util.ized by
the defendant incl.uded, but were not l.irnited to, the fol.l.owing:
{a) in or about December, 1.977, the defendant, SARKIS G.

SOGHANALIAN, caused BOCA to be informed that delivery of the
weapons was delayed due to mechanical. difficulties with the
'I
aircraft, knowing that said representation was, and woul.d be,

false and fraudulent when rnade7
-8----~-------
----.,---
~-
- --
--
~.
--
/.
.
o-:~
;
(b) on or about ~ember 1.8, 1.977, the d e f e . - t , SARKIS
./G. soGHANAL:IAN, caused BOCA to be informed that whil.e the HBM

machine guns were in a warehouse in Lisbon, Portugal., del.ivery
woul.d be del.ayed pending receipt of an export l.icense from
Portugal., knowing that said representation was, and woul.d be,
fal.se and fraudul.ent when made; "
(c) on or about January 25, 1.978, -the defendant, SARKIS G.
SOGHANAL:IAN, caused the Banque Bruxel.l.es Lambert, S.A. and
~ to
be informed
t~at
the del.ay in shipment of the weapons
to Mauritania was due to the movement of the weapons, knowing

that said representation was, and woul.d be, fal.se and fraudulent
when made;
(d)- in or about February, 1.97'8, the defendant, SARKIS G.
SOGHANAL:IAN, caused BOCA to be informed that further delays
were due to the Portugese national. hol.idays, knowing that
said representation was, and woul.d be, fal.se and fraudul.ent
when made.
25.
:It was further a part of the scheme and artifice to
defraud that the defendant, SARKIS G. SOGHANAL:IAN, woul.dand

did convert to his own use the monies paid by BOCA.
26.
:It was further a part of the scheme and artifice to
defrau~-that
wire and radio communications and the United
States mail.s would be and were used in interstate and foreign

commerce in furtherance of the scheme.
27.
on or about each of the dates designated by each
count enumerated-bel.ow, in the Southern District of Fl.orida,

the defendant,
did knowingl.y and wil.ful.l.y~ for the purpose of executing the
aforesaid scheme"and artifice to defraud and to obtain
money and property by means of fal.se and fraudul.ent pretenses,
representations and
pr:~.mises
and attempting to do so, wil.-
fully and knowingl.y transmitted and caused to be transmitted

by means of wire and radio communication in interstate and
-9-
l ________ _
..
foreign commerce, writings, signs, signals and
soun~
as set forth in each enumerated count below: APPROXIMATE DATE
COMMUNICATION
May 6, 1977
call from John Ralph in
London, England to SARKIS
G. SOGHANALIAN in Miami
Beach, Florida.
May 16, 1977
An
June 2, 1977
call from SARKIS G. SOGHANALIAN
to John Ralph in London,
England.
July 29, 1977
international telephone
England.
August 22, 1977
England.
September 1, 1977
An
September 22, 1977
call from SARKIS G. SOGHANAL
England.
November 15, 1977
call from SARKIS G. SOGHAN
England.
December 3, 1977
An interstate telephone ca
from Robert Burr in the Me
po1itan Washington, D.C. a
to SARKIS SOGHANALIAN in
Miami Beach, Florida.
England.
An
-10-
call from SARKIS G. SOGHANALI
in MiamiBeach, Florida
England.
13
January 12, 1978
An international. te1ephone
London, Eng1and to SARKXS G.
SOGHANALXAN in Miami Beach,
F1orida.
January 13, 1978
London, Eng1and to SARKXS G.
- F1orida.
February 5, 1978
An international. te1egram
from John Ra1ph in London,
Eng1and to SARKIS G. SOGHANAL
14
February 6, 1978
An international. tel.egram
from Ralph to SOGHANALXAN
in Miami Beach, F1orida.
15
February 7, 1978
An international mai1gram
from United Trade Xnternatio~
in Miami Beach, F1orida to
John Ralph in London, Eng1and
16
February 8, 1978
An international. tel.egram
from John Ralph in London,
Engl.and to SARKXS G.
F1orida.
17
February 9, 1978
ca11 from Captain Ahmadou
Anne Baba1y in Paris, France
to SARKXS G. SOGHANALXAN in
Miami Be~ch, F1orida.
18
March 9, 1978
An international. te1egra.m
from John Ra1ph in London,
Eng1and to SARKIS G. SOGHAN
in Miami Beach, Fl.orida.

1343.
COUNTS 19-20
1.
The Grand Jury repeats and rea11ege paragraphs 1
through 26 . of Counts 1 through 18 as if fu11y set_ forth herein.

2.
count enumerated be1ow, in the Southern District of F1orida,

the de.fendant,
SARKXS G. SOGHANALXAN
did knowing1y and wi1fu11y, for the purpose of executing the
-11-
...
and promises, and attempting to do so, knowing1y
and wi1fu11y did p1ace and cause to be p1aced in an authorized
depository for mai1 matter, and did cause to be de1ivered
by the United States Posta1 Service according to the direction
thereon, certain mai1 matter as set forth in each enumerated
count be1ow:
APPROX:IMATE
DATE
COUNT
ADDRESSEE
MA:IL MATTER
19
Ju1y-11, 1977
SARK:IS G. SOGHANAL:IAN
A 1etter from John

contract between
BOCA and UT:I for the
machine guns.
20
Sept. 11, 1977
A 1etter from John

invoice for the 197
.so ca1i.ber HBM2
machine guns.

1341.
COUNT 21-29
1.
The Grand Jury repeats and rea11eges paragraphs 1

I Y
tr?--?"1
t;- J- -f-,through 26 of Counts 1 through -2'6- as if fu11y set forth herein.
2.
count enumerated be1ow, in the Southern District pf F1orida,

the defendant,
did knowing1y and wi.1fu11y, for the purpose of executing the
representations, and promises, and attempting to do so, wi.1fu11y
and knowing1y negotiated and caused to be negotiated the checks
drawn on account number 19-126826 at the Irving Trust Company
in New York, New York as set forth more fu11y in each enumerated
count be1ow, thereby causing the funds represented by each
said check and the check itse1f to be transported in interstate commerce between New York City, New York and Miami., F1orida,
knowing that said funds had been taken and obtained by fraud:
-12-
. -.
_:I
..
APPROXIMATE
DATE
COUNT
~
CHECK
NUMBER
PAYEE
PAYOR
AMOUNT
21.
Dec. 1.6,1.977
353
SARKIS G.
SOGHANALIAN
SARKIS G.
SOGHANAL:IAN
22
Jan. 1.2,1.978
364
Fred Jenner
SARKIS G.
SOGHANAL:IAN
$5,000
23
~an.
l. 7, 1.97'8
370
CASH
SARKIS G.
SOGHANAL:IAN
$5,000
24
Jan. 24,1.978
369
:res, :Inc.
SARKIS G.
SOGHANALIAN
$65,000
25
Feb. 3,1.978
375
Southeast
Fi.rst Nat'l.
Bank
SARKIS G.
SOGHANALIAN
$1.0,000
26
Feb. 3,1.978
379
Gonzalez Bros.
Constructi.on
SARKIS G.
SOGHANAL:IAN
$5,500
27
Feb. 9,1.978
380
:res, Inc.
SARKIS G.
SOGHANALIAN
$25,000
28
Feb. 1.0,1.978
381.
:ICS, :Inc.
SARK:IS G.
SOGHANALIAN
$20,000
29-
Feb. 1.0,1.978
382
Uni.ted Trade,
Inc.
SARKIS G.
SOGHANALIAN
$8,000
$1.50,000
All. in viol.ation of Title 1.8, United States Code, Section

231.4.
COUNT 30
l..
The Grand Jury repeats and realleges paragraphs l.
.through 26 of counts l
2-.
through 18 as if fully set forth herei.n.
on or about the first two weeks of Jul.y 1.977 in the
Southern District of Flori.da, the defendant,

did knowingl.y and wil.ful.l.y, for the purpose of executing the
aforesai.d scheme and arti.fice to defraud and to obtai.n money
and property by means of false and fraudulent pretenses,
representati.ons and promises, and attempting to do so,
transport, cause to be transported and induce to travel
i.n and to be transported in i.nterstate commerce two persons,
to-wit: John Ral.ph and Captai.n Ahmadou Anne Babaly, travel.ing
from New York to Miami, Fl.orida:
-1.3-
---........
~-:-:---
---- ----
..
-.-_......,.
-
/2314.
I
~~,:RUE
BI:LL
~: _ ~--c;.._X_.~
FOREPERS
W.
AMPLER, I:
UNIT D STATES ATTORNEY
M&~
SPENB: GILLMAN
ASSISTANT UNITED STATES ATTORNEY
Certified to be a true a~
correct copy of the original.
Joseph I. Bogart, Clerk

U. S. Olatrict C<XI:'t
Southern D~rtct of Florida
-14-
~---------------------------------------
,,
:-~
..
..
... J
,.
'
I! f
.. ' I
't
Arms Dealer Sarkis Soghanalian

:'
' I
denie ~ale
lo
Nicaraguan regime:
SEARCJIEO_I~Ot:>;. \0~
SEIUAII''
'I'
.-1cn
AUG t . '1981
-~
MM0214 22223402
I
P? HI WF
DE Mi!l .
.P 102340Z AUG 81
.R1 tUAMl C1~6A- 105S> P
TO DIRECTOR PRlORlTY
AT.IENT:ION:
..----------.1 '
~JHx.TF.
COLLAR CRlf1E
SECTJO~J S.UPZRV~SORD
b
b7C
'
\JASHHOTO'N FIELD PRIORITY

Br
mJCI... A S
'
~RKIS GARABtT SOGHA:-IALIAN.;;.
FUGlTJV!'::; DBA UNITED TRAD.E
.INTER NA!IOIJAL, Etc. ;L..I_ _ _ _.....JI vrCT,Ii"l; FB.w';

PO:
-~MF;
-l!SP;
MIATU.
REFERENCE MIAMI AIRlEL TO BUREAU, JULY 15, 1981.

F'OR I NF'ORMA'TlON OF'
a UREA U,
t~A-SHI N'GTON FIELD, A NO LEGA !S,
St!BJECT tJAS lNDI-CT0 AUGUST ?, 1$81, 8Y FEDERAL GRAN-D JURY,
SOUIHF.RN ozsTRICT OF' FLORIDA, At\D '.~AS 'CHARGED \HTH EIGH!EEN

'
COUNTS Of ',J!fn: FRAUD <TITLE
'l8, UNITED STAlES CODE, SECI:ION
1343), Tl.vO :COUMTS OF
~1AIL fRAUD
CT ITLE 18,.
unn:o
STATES CODE,
Sf:'CTION 1541)_, A~m .:HNE COUNTS .OF' ITSP <TITLE 18, UNITED SlATES
.e
.PAGE. TlvO f1?1 19GA-'Hl.56 UNCLAS

,WOE, S::C110 N 2'314)..
WARRAtiT :ISSUED
ON
AUGUST 1., -1981, BY
UNITED STATES DISTRICT COURT JUDGE JOE EATON, SOUTHERN DISTRICT

OF fLORIDA, \UTH BOr..'D
SURETY.
RECOM:'lE~'DEO
b'/D
lNDICTMENT SEALED
U:i!IL AUGUST 1,9, 1981, TO AFFORD OPPORTUNITY .TO EFFECT

EXTRAD IT ION OF SUBJECT.
b7C .
AT ,$1 MILLION COMMERCIAL
NCIC ENTRY AND UlS STOP EFFECTED.
SUBJECT lS 'FURTHER DESCRIBED AS tJHITE 'MALE, DATE OF S.lRTH

'FEBRUARY 6, 1929, PLACE OF BIRTH ALEXMH>RETTE,
<ARMENIA>, fiF1Y-EIGHT, TWO HUNDRED THIRTY
BRO\fN EYES,
TUR~EY
POU~lDS,.
UNITED STATES -I ~S NUMBER A 11 652
24~.
BLACK HAIR,
SUBJECT
BSLIEVED TO P,OSSESS UNITED STATES AND LEBAN'ESE .PASSP.ORTS.

ADDRESS
rs
.3.05/307 NORTH HIBISCUS DRIVE, MIAMI BEACH, FLORIDA
. SUBJECT Ol:INS A NORTH AMERICAN ROCK\,JELL SABERLINER, t10DEL
SABER 4'0, maTED STAT~ REGz'STRA1.ION NUriO.ER 40GP, ~JHICH rs

RE PORlEDl. Y t; OCAT ED IN tlE NEVA.
t~ASHI
matED
NGTON FIELD Is REQUESTED TO
STATE~
IM~1EDIA1El. Y
CONTACT
DEPARTMENT OF ,STATE, PASSPORT DIVISION., AND
bE
"'
.. ,..
PAG THREE _MM .1S6A-.Hf56 UNCLAS

DETERMINE SUBJECT'S UNI1ED S!ATES PASS PORI NUMBER..
SUTEL
.BUREAU AND MIAMI l.rJITH RESULTS OF' PASSPORT APP.LICATIOr~ REVI.\1
AID PLACE APPROPR IA1E 'STATE DEPARTMENT STOP..

:BUREAU IS REQUESTED TO IM~1ED IATEL Y CO IJT ACT DEPART ME ~n AL
]:;6
):'?
AlT01rNEYI
IINTERNAT.IONAL AfFAIRS SECTtiON,
DEPARli1E NT OF' JUST'ICE,. TELEPHONE Nm1BER 724-7600, TO FURNISH

I
DESCRJPT1VE DATA AND COORDINATE EXTRADITION.

OlORDl NAT IO.N
~HT HI
I HANDLED
SOtrrHERN D.ISTR"ICT OF fLORIDA,
By AJJSA
lNITIAL
1EL~:HONE NUMBERI
I
I
BUREAU .IS ALSO REQUESTED TO RETRANSMIT ABOVE I NF'ORMATION

TO LEGAlS, LONDON,, <ATTEirfiON ASSISTANT LEGA.T PAT DENTE>-, ROME,
~friS,
BI
ANO BERN.
I '
I
FBI,
TRANSMIT VIA:Qg Teletype
0 Facsimile
PRECEDENCE:CJ Immediate
EJ Pdority
0------
I
I
I
I
I
I
I
I
I
I
I
I
I
I
CLASSIFICATION:
CJ .TOP.SECRET
OSECRET
CONFIDENTIAL
CJ UNCLAS E F- T 0
' -o
o Routine
~UNCLAS
Date AUGUST 10, 198f
----------------------------------------------------J
F,t-1 MIA,t-1! (196A-1056 )_ P
PlRECTOR PRI<lRI'.l'Y
AT'I'ENTION:
7Y.fff
WHITE COLLAR CR!.t-iE SECtiON
S-UPERVISO~
orJ
WASH:tNm'<>N l'IELD PRIORITY
cf.P,
L------....1
BT
UNCLAS
SA~I~S GARABET SOGHANALtAN -
INTERNAT~IONAL,
00:
FUGt_TtVE: DB_A UN-ITED TR2\DE
ETC. ;L..I_ _ _ _ _
...~IviCTI.t-1;
1-'BW; ;F; I:TsP;
,t.iiAMI.
RE-FERENCE MI2\1{I AlRTEL TO -BUREAU, JULY 15, 19 81.
jFoR INFOR.MA'I'ION OF BUREAU, WASH-!NGTON flEt,;D, AND LEGA'I'S,
jsuBJECT WAS INDICTED AUGUSTS, 1981, BY 1-'EDERAL GRAND JURY,

SOUr:t:HE-RN DtS'I'RICT OF FLORIDA, l;I.ND WAS CH~RGE-D WITH EIGH'I'EEN
COUNTS OF WIRE F-RAUD (TITLE 18, UNITED STATES CODE, S-EC'I'ION
1343), TWO COUNT-S OF ,t.iA!L F-RAUD (TI:'I'LE 18, UNITE-D
s-EcTION 1_341)
ST~TES
CODE,
AND NINE couNTs, oF x:TsP ('I'ITLE 1s I UNITED sTA'I'E
(,)- ,t.ii ami
'ifAL:c;Jr
(1)
01{
lNumber>
-CTime)
b6
b7C
,. ._._,..... __ "r.:e-t.;:
.;-:t:l''*'<
\ f'.M
.=r.~
' - '" ,.,.
'
::. ... ,,. f....
,......,: ..._.'"'-"'"",..,."h'l-;,
.~
..~<.~t-=...~~~,..r .
oe
~~
~ <'{tev. 5-22-78)
-~
;;.-.~~A'""'t-
~ -~
')
FBI
TRANSMIT VIA:
PRECEDENCE:
D Teletype
D Facsimile
Olmmediate
0------
. CLASSIFICATION:
0
0
0
0
0
D Priority
0 Routine
TOP SECRET
SECRET
CONFIDENTIAL
UNCLAS E F T 0
UNCLAS
Date-------;
------------------------------------------------------PAGE TWO MM l96A-1056 UNCLAS
CODE, SECTION 2314).
WARRANT ISSUED ON AUGUST 7, -1981, BY
UNITED STATES DISTRICT COURT JUDGE JOE EATON, SOUTHERN DISTRIC'

OF FLORIDA, WITH BOND RECOMMENDED AT $1 MILLION COMMERClAL
SURETYj ~~.....~..~..,
.r.N'.L'.KX .A.Nu
J..L~"
v~: .,;:;ji:..,. Ee'I'ED.
INDICTMENT SEALED
UNTIL AUGUST 19, 1981, TO AFFORD OPPORTUNITY TO EFFECT

EXTRADITION OF SUBJECT. I
SUBJECT IS FURTHER DESCRIBED AS WHITE MALE, DATE OF B!RTH
1
....__________.1 PLACE OF BIRTH ALEXANDRE'I'TE, TURKEY
(ARMENIA), FIFTY-EIGHT, TWO HUNDRED THIRTY POUNDS, BLACK HAIR,
BROWN EYES, UNITED STATES INS NUMBERI
I SUBJECT
BELIEVED TO POSSESS UNITED STATES AND LEBANESE PASSPORTS.

ADDREss Is I
IMIAMI BEACH, FLORIDA.
SUBJECT OWNS A NORTH AMERICAN ROCKWELL SABERLINER, MODEL

SABER 40, UNITED STATES REGISTRATION NUMBER 40GP, WHICH
~S
REPORTEDLY LOCATED IN GENEVA

WASHINGTON FIELD IS REQUESTED TO IMMEDIATELY CONTACT
UNITED STATES DEPARTMENT OF STATE, PASSPORT DIVISION, AND
Approved: - - - - - - - -
Transmitted~~--:---~~-tNumber>
CTime)
Per _ _ _ __
b6
b7C
b7D
" ... ". "..-.:.-, .. - "'""-\

.~
'
.(~
,'
FD-36/Rev. 6-2~18)
'--'
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~ ..-.-----,J<..,..._,_-~~ -~...._ <~~V>'U....~.,_., .,_J'..-=;(t-~-!t.. _ .. _ ~-"'". -tit-
,, .,.
FBI
TRANSMIT VIA:-
PRECEDENCE:-
CLASSIFICATION:-
0 Teletype
0 Facsimile
Olmmediate
0 TOP SECRET
0 Priority
0 Routine
OSECRET
0 ----:------
0 CONFIDENTIAL
0 UNCLAS E F T 0
0 UNCLAS
Date-------;'
----------------------------------------------------PAGE THREE MM l96A-1056 UNCLAS

DETERMINE SUBJECT'S UNX:TED STl\,TES PASSPORT NUMBER.
SU'I'EL
BUREAU AND MIAMI WITH RESULTS OF PASSPORT .2\,PPLICATION REVIEW

AND PLACE APPROPRIATE STA'I'E
BUREAU
~S
DEPAR'I'~NT
STOP.
REQUESTED
. TO IMMEDIATELY CONTACT DEPARTMENTAL
ATTORNE:YI
IINTERNATIONAL AFFAIRS SECtiON I
bG
b7C
DEPARTMENT OF JUSTICE, TELEPHONE NUMBER 724-7600, TO FURNISH

DESCRIP-T-IVE DATA AND COORDINATE EXTRADITION.
~ANDLED
COORDINATION WITH I
BY AUSA
lNITIAL
SOUTHERN DISTRICT OF FLORIDA, TELEPHONE NUl-1BL...-E-R1 1_ _ _ _ _........._,

BUREAU IS ALSO REQUESTED TO RETRANSMIT ABOVE
INFOR~TION
TO LEGATS, LONDON, (ATTENT-ION ASSISTANT LEGAT PAT DENTE) , :ROME,

PARIS, AND BERN.
BT
ofh~
.P
;rl'lr. 1/rJ?n 1?:5
1'0 Oi l'f(J
~=n~ttJl'- ,, "" $1't,
AmJ:
om
Approved: - - - - - - I
L:__
Transmitted ~:-":"--:----::=:---:--<Number)
(Time)
Per _ _ _ __
~(
-- ,.,
NOTE: Suhmlt ORIGINAL aftd ONE COPY
Add1eS5
305/307 North Hibiscus Drive
ta
.Hiartl 'Beach
JidY JIJr ttJac ~Ab as: ltatWII Jllaso tJsia 8'1: clts:uw t 1 1\e:J,..eallF:' :bl
'
(Numbet and Stree.t)
Date of Birth (t1tclude

rdonth, day, ~tar)
2/26/29
Florida
:: eql'it:lpas ad'll:l:al~ s'
'(Ci
Nationality
Turkish
\a:ue ou:;C
(Sta
td\ntifying Num~r
0 Passport
Lebanese
,,.u, ,r * w, . u_.,,
Req~~s.ting Office
FBI,
I
:~uani
Date of ft~est
(ind ,m(JY!th1 day, JeQr)
wrt fur2
Fs
ca~ctlU.t(oo ~te
(incl. mont~, '}ear)
. S/10/81
IJ Oth~r
'II:M lh s llPt:
loU ddl l ' l , .. ct I
J:liilllsl I
lo_,
.,
Mistellaneous:
Bench warrant ;issued ,8/7/81 by u.s. District Court
Judge .Joe Eaton, SouthernDistriet of Florida, charging

violation of Title 18, United States Code, Sections 1341, 1;43,
ll!ld 2314. ~ond recormendation: :)1,000,000 corporate sur~~
~L96
~1056(l)
~ 1
,1tfV
1.1, ~
..
F:D-315 (Rev.J23-76)
rtDEML BURtAO OF INVESntAliON

INS Lookout Notice
Moii,To.-1 "Records Adn\inlstrotion and lnforn\otlon Bran cit,
stiwr&~~O,
',' ~~'::
,,
!.!.!
,,i,
,r.Uiet
.,
lmmi~r~tlon ond Notu~ollzotlo~ ~rvl~~~

f\t~O,
4~~ 'Eye Str~et, N,W,, WosMngt.o~, 0. C. 2~~36
,
. l9/l' I
R11110/e
,,,
~ras~ r~v~~~~h!!3:ti!\~~ J>:;.

aV.msH deal1~with_:;f:ran:;4;:'~~ -=-r..a;
_'fJM
'
'
..
.. "
= .
..
..
0.
TilE MYSTERIOUS ~rash of au

-turn the plane! made shortly beArgendnian cargo plane in Rus--
~ ~ r~
fore disar>peari_ng, from:rlJ'Urklsh ~~~---:-:':~~~:.--~-:=::"":
sia last Saturday has revealed " "!:":'" - ~ ~ '"':'~ --:.-7". ~ - r c _z:_adar scrceJ?S'
:.
, '. :,
;;~~!~~~~fi.7..r.l
a big arms deal between Is.-ael . Th 1
)"f.
;
h
The contra~t to move -the 360 ~\:'~ll"-.~
-:-t:~.;.~~~1
and Iran-....:.... in. ~Jirect def1an~e of
e srae .1 or~!g~ mms~ry , as-: .tons of supplies to Teheran was '!/..~
..-.!:.~: . _ ?'~''! :,
-the US embargo on arms sup. .. demed any deal "!11 h then:: ~ck"f' hawked 'around gun-runners in
p1ies to .the regime 'of ~.f,.yatollah ... n_owle,dged. encm.y, Iran. B_~t; ,1':"-' :Europe via ;a ' variety .of :brokers
Khomeinl.:.''fhc "deal, negotiatedl :slght . h~s.' estabh~hed that.' l ~ : :this spring; Most"''of,t:th.oset'ap.
i~ London, \'(asj to supply Iran '~'t
"the~ deal ~-.in!olved .;fercyl~g P.i-oahed shie~ aw~li'~'"T~~~!-. ~.,
._wnh 369 ;to,r)s' of tll;t;_Jk sP.ares :a_nd ..~.~ 11;1llita_b'j;.su'ppl~:,es ,..~C?rt,h '15 \,ltui~~The d~at;"'c?a'rtied 1J.witht h ~ SJ>C
->ammun~llo_~i.whl~h ~~ dl'sperately. "f\hol_l~n ,~~fpl~~!ld,s ~ lrP.II) .,.~el~'cial risks:""thC!Israe1is 'were .in~
needed to. pursue Us ~0-month Av1v to Teheran v1a ~~rna~a I~ sistent that the spares and
old war wath Iraq.
Cyprus.
ammunition should leave Tel
The man hir.ed to deliver: ti!e 0 The contra~t ~was' signed by Aviv properly documented, with
US-made supphes f.-om :Tel Avv British. middlemenin London re details of the-cargo entered on
to Teheran was a 38-year-old Scot, presen~ing . both'.:'a Tel '. Aviv ~waybills' and manifests but
.. Stuah. Allan M~Ca1le.rty. He is "cover firmcand the Ayatollah. -with tile -~ ultimate destination
. disguised. My. 'pripcipals ,. in

!Presum_cd to have per1shed when
-.-'
the cargo plane, a CL "44 turbo-; . Three ,loads, ope~ 1Y docu~"London im;isted that- the "Whole
~prop, was interceped_f?y; Russ~an,: n;tented as ~ank -~parc:s.~erc ;.de: .-. thing, should -.be clean~~ said
fighters !"on the SoyJet-'I)~Z:~lsh:::.~ hve~ed on July 12, 1.4 and'~?,. Jenni, who :eventually ac~epted
-border and crashed.
!
1< The l>lan~ was inte~cepted as lt! the contract: ,! .It - seemed!!c:ra~y
. y ste.rd y .,.M. ~Ca" f{ert''s sw.ss-wasretyrnlng fl'om. usthird run. -to me .. . ... --:: f:;: .
_ " ..
. e
a ,
~
J
- - - t .t t , tr.--

'
t-'""
.
~anner, Andreas Jennik told us _;~ 0 The. pi~ne ma-r .have been\._. .. At,the.sa!De-time;;,the,Jr!lni.a~s
r~he d~ta1is of the. secret de~l- And < lured Into Russian 3!1' space by ...;,were ins1stmg that Lar~aca m
.hesaidhewassulldetermm~d.to a series.of spoof nav1gauonbea-Cyprus was to be_ used .- aS;" t h e f - i o - - - - - - - - - i gee the spares and !lmmumtiOil' cons wh~~h the ~ussian~ have in staging-post because : that : route
~,...,~~-.
through to .Teheran. "We were _stalled JUSt ins1de cthe1r bordE;r-- had .proved -l'eliable m ;:. the- past.,
fully aware of the. ri~k 'we were 'with Turkey __and,.,.,. Iran. 'fhls .-
.
r"
running: he said.
.. would e~p~~~n,!fa--t.s~d~.en ~nght
, ~ .COflt&nued :on page
,~
."
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L
' "';~:_..,! .. , .. ,
. ~--, . . -~. ':'~"';.:>~ :--, ,. " '~~~-~ ....,
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. __--_:~~-~, -~-- -::....::1 -~
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,
l
.
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-
1:-
2..
,
;; ~"r!' . -':., r~~;~ ? . ~ . ~
arm:~suppJy ~
for~A~~h~n~J;i,
:~::. ~-';
...
- ~ ~.....
..
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..... - ........ -t -.. - ~ -
.....
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' '):By' RICHARD l!.EES"I'(?N.~-}
Jn Washington
"
THE Central' Intelligence~
Agenc~ is;l'et>Otted _to '
. be c:o-ord1natmg a.~maJor In
clandestine. arms :- supply ,
programme for .A;fghan~ IJ
resistance fighter s mvolv- t"-.
jng .China, Paki5;tan, -Egypt
. and Saudi Ara-bla.. .
A report.in the NEW l\EPU8uc by <;atl Bernstein, '. the

Water"ate journalist; said tha~
~-!-
~
\
..' I
...
the United
..' tbc
States.and'
Saud ~~==============:=o:ll!!~~~
Arabia
mam.
paymS
ci
strrs forare
thearms
programme.
China b _ per~itting ov;r
' !~ flights of her terr1tory; for atr. , craU ferrying arm~ fo~ Af~;th~n
'
1 lstam Pakistan . Is pernnttml(
'regular car~vans - of ~~!OS., to
cross the jomt bo~der. _
.
Egypt is providing tra1ning
- - - - - - - - - - : - - - - - for. Afghan ~errillas, and
_ ..
_ . . .
.
'.
l
supplying. Russtan weapons ,__ :::..,.;:.._..;.~,- -_-.....;_ _
. .
.
.
.--
-,~
1~~~~!!:!!!!!:!:!:!:~~~~~!:!:~~~=====~~
i'
..
-------,._.,..,_ .-...
"'
~-- :-~~~ ..
.. _ ...
j.
... .
-~~-~
"~
'Ill:"
_r.~ .. , .;,.~ :~:'Jl::: ~~~- work~d
.
It.
1
l '
..
'i
out under the Cartel" Administtation *nd President_-Reagan,

assessh;g the suocesses of ~ !be
operation. has . ordered an_
expansion of the current programme .already es!tmate~ atover $100 million (53 mllhon).
China had agreed _to help
supply the Afgaans wtth _sa_m7 anti-aircraft . .and antt-tank
missiles and _ to . ..tr~nship
weapons across tb~ - ~fficult
Chinese-Afghan frontier.
President Zia 'of pak1stan
stipulated that the suppoly . o1f.
arms should not . be pub1c Y
acknowledged; the arms w?uld
be moved directlY 'ct~ss the
border and that sh1pments
.should'bf!: limited>tO;tWOPI4':1~,
'
..
.
':
?~
~'~
;1T-
't
.l..
obtained tcoro'"thesovtet
4':~ -/!: .. ~~ ....-,.-;,.4..."h~-._,...,.
durinJ tbe: yea~ _o~"'~5 ~"!!' ..
-~-.!;.-.; . - . -:- --~ _<- ~
Egy~llan I< frendshP . ,., ~ - .
--' - - ' -
J! ,. ..
_1
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~
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un:or
~~--..... -:_,!.,.;.,.'!_,->..~~--~" -.,-:,;;~-':'.-:~":. -~-~:.s
~--~~ ~A ::; ~ -~-: ~"Z ;;10~4.:-~-~ ~~~~-: -_.~ --
'
-,if~lo~a~d~s~&;;.w;;~;e;k;~~,~~-~~==:::':::~J:-.:. .~;;
~........,..(.
~~"'. ~.!-:::-,_ ~c
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---
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Tel
He claimed
be' i'l phumaeeut
-S.eals."
.,
ButJlo US airline would touch
' Jt. So. in late June, McCafferty
t~,trned up in Buenos Air";
' Argentina, ~t the officn of
_, Tu.nsportc Aerco Rioplatense, a
I .,. :i snull air charter firm with a
' I reputation for not asking too ~
"-"'.many gue$tions. It agreed to rent ,,
. : , , " McCaffertY it$ CL44 (call-sign .
, ' , Tango Nove;mb~r). He paid cash.
Early' this month McCafferty
went with Tango November' to,
Miami where 011e of the plane's
en::tines wu refitted.
.1
On July,7, the plane set oft for,
Tel--Aviv. Besides McCafferty, L:.....:..~-=L:~~:i:==:=:~-.!:=:::==:.__J .1
1
f'n Mud w~r~ ~,' Ar~entinian
' i.
. "rl,f'rf' fh" ""'"'" "'"Hh,.rt .,,,.,.,. fh,. ' ...-.lll~fon:
"'
,.
'
~.
' i
--2-
August 10, 1_981
it would please .me greatly t~ see o_ne pax-ticular fraud artist- sitting -in .a
cox-rect_ional inst_itut_ion long enough t-o ponder "whe:re h_e went wrong."
bG
Since:rely yours,
ANDREWS &LOBBERS
B y l . . , _ _ _ _ l_ _ _ _ _ _ _ J
DA/jp
Enc_ls.
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SZARCfltO_I~DSW(_
SEft.IALIZF.D_FII.ED:--
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AUB 141981
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pp
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.22-7023 8Z
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F.~1
1'1lA:vli (-19GA-1056> P
TO DIRECTOR PRIORITY
ATT
:~:
.\,'HITE COLLAR
OR IME S!CT ION, SUPeRVISOR
L . . l_
__ _ ,
A~:n OFf<TCE OF PlJBl-I C A~m CO ~XlRESS IO ~.~AL AF'FA IR-S
BT
UNCLA S
I
SARKIS GARBE:! SOOHANALIA~~-: FUGlTIVE_; DBA UNITED. TRADE -HlTERNAT.IO~JAL,
ETc. j
IVI CT l\'1;
F'o'rJ; '1 F; IT SP;
.z~: ~HA ~1I.
RE MIAMI lELETYPE TO 13:UREA.U, DATED AUGUST ]3, l~Sl.
FOR
-INF'OR~1AT10N
oF su:qEAU
A~\u
I sor-,
LEGATs, AUSAI
b6
ADVISES HE llAS HH'"ORMED BY I~'TER~JA1IO~IAL AFFAIRS SECTIO:J, DOJ,
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THAT ~S.UBJECT '.~'AS ARRESTED'BY S~JlSS ALJ!HORiliES AT GENEVA, S':!ITZER-
LA!;D, O'J AUGUST 13,' 1981, BASED Q\J WARRANT .ISSUED 1~1 IlrSTANT i'lATTER.
'SUBJECT' 's AlTOR NEY ADVlS0 .S'.J ISS AUT EOR:I1'lES 0 ~J ;1pR ~a ~JG :OF
.AlJG US! 14, 193.1 , 1' HAT SUBJECT: I:JOLtD tJAl VE EXTRAD.!T-!0 :-J.
1.
,,
AUSA
~...I
_ __ _ _ _ .
STATED DOJ IS 'COORDINATI:!G SUBJ~CT' S RETURtl EITHER BY D. s. iM'RSHALS

01 St-JISS "POL_ICS !O U.S. _DURING 'i/E~ K ,0 F Al.!G.USI 17-23, lS 81
l1~1r71 ~-":lor'
1~
--~~~-=
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- ~------------~
PAGE 'H.r 0 i.'~ ;:,1 C19 6 A- 10 5 6)
'
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U:~ SL A S
INDICFIJE\JT AND \!!ARRANT REMAINS SE.P.LED UNTIL SUBJECt'S

APPE AR.6. 1J CE: AT
1_1
S.
P0RT 0 !<' E NT R Y
BUREAU IS REQUESTED TO RETRANSMIT ABOVE TO LEGATS

BER NE , PAR I S , A NO P OM E.
Bf
Date AUGUST 14, 1~1

~-----------------------------------------------------
FM MIAMI (196A-1056) P
~ TO DIRECTOR PRIORITY
ATTN:
WHITE
~
COLLAR C~SECT~ON, SUPERVISO~....._______
__,
AND OFFICE OF PUBLIC AND CONGRESSIONAL AFFAIRS

BT
b6
b7C
UNCLAS
SARKIS GARBET
SOGHANA~IAN
ETC.;~~-----~~
RE MIAMI
- FUGITIVE; DBA UNITED TRADE JNTERNATIONAL,
VICTIM; FBW; MF; ITSP; OO:MIAMI.
~ELETYPE
TO BUREAU, DATED AUGUST -13, -1981.
FOR :INFORMATION OF BUREAU AND LEGATS' AUSAI
I SDF,
ADVISES HE WAS INFORMED BY INTERNATIONAL AFFAIRS SECTION, DOJ,

THAT SUBJECT WAS ARRESTED BY SWISS AUTHORITIES AT GENEVA, SWITZERLAND, ON AUGUST 13, 1981, BASED ON WARRANT ISSUED IN INSTANT
~~TTER.
SUBJECT'S ATTORNEY ADVISED SWISS-AUTHORITIES ON MORNING OF

AUGUST 14' 1981, THAT SUBJECT WOULD WAIVE EXTRADITION.
:AUSAI
STATED DOJ IS COORDINATING SUBJECT'S RETURN EITHER BY U.S. NARSHALS

OR SWISS POLICE TO U.S. DURING WEEK OF AUGUST
17~23,
1981.
'..
();)- Miami HAL:mia

(1)
lft~JI "/difo-'lf'J
Approved:
Cfu/e___
-1-!3~--:::;;:--~V~'f~-\-p
-g-' r W~ransmitted ~{)_~
<Nutt!{;r)
CTi:r\
Per-~~~--
'
- .,
F~-~ev. 5-22--78)
TRANSMIT VIA:
'.ClTeletype
0 Facsimile
Cl
ee
....
,J~.
FBI
PRECEDENCE:
"Cl Immediate
t:J Priority
Cl Routine
CLASSIFICATION:
Cl TOP SECRET
0 SECRET
0 CONFIDENTIAL
0 UNCLAS E F T 0
0 UNCLAS
Date
PAGE
~WO
I
I
I
.I
I
I
I
I
I
I
I
I
I
I
,I
'I
I
I
MM (196A-l056) UNCLAS
INDICTMENT AND WARRANT REMAINS
'SEALED~UNTIL
SUBJECT'S INITIAL
APPEARANCE AT U.S. PORT OF ENTRY.

BUREAU IS REQUESTED TO RETRANSMIT ABOVE TO.LEGATS.LONDON,
BERNE, PARIS, AND ROME.
BT
Approved: _ _ _ _ _.....__ _
.........
Transmitted~~~----=--,-.-(NuiDber>
(Time)
Per-----
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I
-.
:Memorandum
'fo
$ f1c.
,.,.
'~ I
Subjt:
ff1lt~[J
~ ,.,. ~
(I t:f c.,A-- ( 0 )l, )(f')
.Date
t /t 1 /(/1
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fflt.J
t'f):~
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SEARCIJED_I~DEXED_
SERIAUZEO-FIU:D _ _
AU6191981
M:10216 2242205Z
RR HI '
DE
MM
.R .122205Z AlJG 81
<196A- 1056)
fM MIAMI
.P
TO DIREC! OR ROUT.! tJE

ATTN:
OFFICE OF COOORESSIONAL AND PUBL-IC AF'FAIRS; AND
SECT IO !J, SUPERVISOR
~ICC
I~....-_______.
BT
U~Cl.AS
T SOG HANAL Itdl - FUG IT lVE; DBA UNITED TRADE HJTERI
~....-_ _ _ ___.1
'
.,
VI CT r1;, FEVJ.; ,"JF; ITS?; 00: i'1IAMI.
b7C ;
RE i1IMU TELETYPE 10 BUREAU-, AUGUST 10, 1981

rNFOR'~1ATION I~l BACKGROUND CO~lCER~ING INSTA~lT T1ATlER lS BEING
FUR ~!SHED TO !HE BUREAU IN VIEvJ OF M:!'lCIPATED \HDESPREAD

.I
r-1'1ED!ATE
I~ITEREST
J:J THE
~JEAR
'
FUTURE.
./'!
... ~
SEARC~EO
. 0 '
.. w: ...
i',I
~ iJ... ....-('0) ~ . . '/ .
ltlOEXE. .... "v .... 1W

~tPl~t\ZEO :,

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fill
~)
r-=--...;......_....L..Z.t....-....;;......., a.J F-~ ) '
b6
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'
BA.CKGROU ND ON SUBJECT IS AS i'OLL.O'.'.IS:

SUBJECT IS A 52 YZAR OLD ::~A!:IVE OF !URK!i:Y ~vHO ~AS L"IVED
'
I=~ 1 HE U. ,s. PERIOD I CALL. Y S INCE 1958.
SUBJECT .lS AN ,H~TER :-JAT IO NALLY
J<~>iO'.-UJ ARi1S DEAL.ER, 'JHO HAS SEtl THE: fOCUS OF 'CO~SIDERABL.E :I1r-
riDIATZ ATTENTION BOTH l~l SOUT.H Fl..ORIDA AND :lAlfONALLY BECAUSE
.OF' HIS AR!'1S TRAFF"ICKH!G 'I~ 1 HE PAS!.

l:XGATED BY A
NU~ER
OF' U.S.
A~m
~BJECT HAS BEEN I NVES-
FOREIGN POL.ICF.
AGENCI~S
FOR
~UGGLI~G .OF' AR~1S, STDLEtl AUTo's, AND NARCOTICS, 'BUT UP 10 THIS

l'INE, HAS SUCCESSFULLY EL.UDED PROSECUTION.
CL'RRENTLY
U~JDER
.INVESr-IGAliON.BY U.S.
YORK, FOR AL.L.EGEDLY
IN 1979.
SUBJECT
L...-_ _ _ _
HAVI~J~
C0:'1~1RCE DEPAR!~1E:n,
NEH
S.CLD A Cl30 TY-PE AIRCRAfT TO tIBYA '
lSI
___.I.CURRE ~ITL Y A BUREAU rUGlllVZ, :0 N !ERROR IST CHARGES.
SUBJECT ':JAS TARGETED BY
t~IM1I
F:IGURE 'Ifl SEP.TEt1BER, 190,
SUBJECT .IS Al.SO
A'~m
orviSION A'S.A t'1AJOR CRlMINAL

HAS
8EE~11.HE
SUBJECT Or A YEAR
..
PAGE THREE :1i1 (
196A-1~56)
LONG :INTENSIVE
I~VESTIGATION
IN NI t\E FORE IG
:~
COU
UNCLAS
COtiDUCTED THROUGHOUT THE U.S. AND
~rr RIE S.
THE FOLLO'.HNG IS A SYNOPSIS Or "THE FACTS OF THE :INVESTIGA-
ouRI~G
1977 SUBJECT, .OPf.:RATI:~ FROM ~1IAMI BEACH, F.LORlDA,
Art) THE vJASHI:.xJTON, D.C. AREA, .CONTRACTED tilTH AN E~XlL!SH
susr NESSMA
tJ,I
Ira suPPLY
197 NEWLY MANUFACTURED
lr.N
EROIHJIKG .50 CALISER ~ACHIN~--GUNS OF U.S. OR.IGIN.I
.TURN .HAD CONTRACT.ED TO SELL THE \v.EAPO"lS 10 T.HE ISLA~1!C REPt.taLIC

OF ~1A~'RITANlA, A FORMER FRE:NCH COLONY ON THE ~\ORTI-NEST COAST
OF' AFRICA.
~1AURITA~HA I.JAS A11HA11I~1E E~tJAGED :IN A BORDER
WAR AGAINST COMMUNIST :GUERRILLAS SUPPORTED BY .LlSYA AND ALGERIA

. I.N JUl. Y, 1977,
SUBJ~C.T
!Ool<DA ND A REPRESE NTA1 IVE OF
.THE ~lAUR IT ANIA N GOVERNMENT TO VIli

AT AN ARMS PLANT .IN :JEjl YORK.
~1ANUFACTURING
.sa
CALIBER :MCHI NE-G UNS
SUBJECT .ctAIMED JHE PLAtH ~~AS
NElt,' SRmJ.NI~JG ~1ACHINE-GU~;s A! !HE RA!E OF' 30 :tO 4.0
.A MO!'ITH, r,JHICH HE
~JOULD
SUPPLY TO ntL THE
COI~TRACT.
INVEs-
TIGATION OlSCLOSED THAT I~~ FACT, !HE PLANT l:JAS MANUFACTURirv'G

0:\J.. Y SPARE PARTS ~OR MA.CiH :~E-GUNS M:D 1:/AS ~JOT ASSEi1BL!NG
b6
b7C
:e
"
PAGE fOUR ~1~1 (196A- .12.5.6) UNCLA S

MACHI ~E-GUNS A! THAT .T H1E/
1HE G0 V~R ~11E NT 0 F' MAURITANIA SUS-
$ QUE NIL Y RA !SED A LETTER OF CRED.IT v!.IT H A UROPEMJ BANK FOR
1.6 MILLION .DOLLARS TO fU~'D lH PURCHASE OF' THe MACHI~JE-GUNS.
l N N~VEMBER, 1977, SUBJECT DI SPAT Cf.ED HIS REPR'ESE NTAT.lVE

TO EUROPE, 'd.HO PRESE~JTED TO A BANK FALSE DoCm1ZNTS, 'INDICATI~G
THAT '197 NE\J BROlJNI NG .30 CAL.!BER MACHI NE-GU~JS tvERE ON 'BOARD
A BOEING 707., '.~HIGH HAD T.RANSITED TO L'ISBON, 'PORTUGAL, READY
TO MAKE DELIVERY TO
~1AURITANIA.
UPON PRESEtnATIO~J OF THE'
rRAUD.ULE NT DOCUMENTS, 1. r1ILL.IO N DOLLARS ivAS 'TRA NSF.ERRED TO
L----....J~BANX
IN
B-E~GlUM,
OF' WHICH l. 153
~ULLION
DOLLARS .tJAS
THEN 1.HRE IRArlSFERRED TO SUSJE.CT''S BANK ACCOU:VT HJ ~E\-1 YORK .CITY.
AS TIME PASSED AND NO vJEAPO~S ,\1ERE DEL-IVERED, SUBJECT OFFERED

'
VARIOUS EXCUSES FOR Nor~DELIV,RY; .I.E.,

. . D.IFF!CUL!IES ~H1H THE
AIRCRAFT .A ~'D EXPORT LICESSE, LACX OF TRIPODS FOR T.HE HEAPONS,
b6
b7C
.ETC.
:IN FEBRUARY, 1S78, S.UBJECT DISPLAYE.D .CERTA'lN .50 CALIBER
MACHlNE-GUN'S lN P.ORTUGAL
101
f~D A REPRESEN!AliVE OF' THE
MAURITArliAN GOVERtt11ENT, .HHICH HE CtAH~ED '.vEREtHE ~JEAPONS IN

OOESLION.
SUBSEQUENT INVESTIGATION !~ PORTUGAL DISCLOSED THESE
l~------~~~~----~~~~~--~----~
- - - - - - - - - - - - -......111!111
. .. -~. . . . .--..-~~--~~~--::--::.-. ---
(..-
....
PAGE rxvE M~1 t 196A-1056) UNCLAS
.\~ERE SUR'Pl.US 1:1EAPONS BtLONGIOO
NOT TO SUBJECT BUT TO THE PORTUGUESE
GOVERmiE'NT, A:.'D HAD BEE~J ., MADE AVAILABLE T.O SUBJECT FOR VIE\JI~G
IN HIS CA PA C.Il Y AS A PROSPECT IV~ .BUYER ONl. Y.
FURTHER HJVEST !GA-
T ION IN PORTUGAL ES!A"BL.ISHED THAT SUBJECT DID PURCHASE 300

~LVAGED .50 CALIBER A"IR,CRAFT MACHI.NE-OUNS FOR ABOUT $11'0,000.
HO~.>JEVER, THESE MACHINE-GUNS COULD
~OT BE USED SY GROUND FORCES,
A:~n ~10D1F'ICATION OF THE .NACHHJE-GUNS TO GROUND STANDARDS \lAS
~~! COt1:1ERCIALLY FEASIBLE.
THESE 300 SALVAGED MACHINE-GU~JS \JERE
S::IZED DURH~G 1978 BY !HE POR'l:UGUESE POLICE BASED ON A COMPLA!:-lT
. FR0~11
~1\'0
!VIDENCE THAT SUBJECT HAD PRESENTED FALSE
DOCUMENTS TO JHE "PORTUGUESE GOVERN:1EN! TO OBTAIN AN .EXPORT

LICENSE.
SUBJEC!':S -INT.ENliONS lHTH rHE 300 SALVAGED MACHI~E-
GUNS REMAINS UNCLEAR.

\vER 1 NG 1 NQUIRIES
EVEl'Jl'UALLY, SUBJECT SlMPl.Y STOPPED ANs-
FR0~11
KEPT THE 1. 153
At-D rv'EVER DEL-IVERED ANY \JEAPONS TP
MIL~ IoN
~AURITAIHA.
DOLLARS,
IT -zs. NOTED
!HAT THE TOTAL LOSS TO ~1AURITAN_IA ~~AS 1.6 MILLION DOLLARS.

DURIOO THE COURSE OF THIS INVEST IGAT.ION, lHE ABILITY
THE FBI 10 CO ~'DUCT INTER NAT-IONAL FORE IG ~~

,IN THE \vORLD .HAS M1PL Y DE~10 NSTRATED.
..
r NVEST'!GAT IONS
9F
M~YvJHERE
!RAVEL BY THE -~1lAt1I CASE
b6
b7C
PAGE S I X t~ ~1 <19 6 A- 10 56) UN CL AS

~.GENT TO MAURITANIA, PORTUGAL, AW Ei'nLAKD vJAS ABSOLUTELY :I~-
THE ASSISTANCE OF' THE U.S. DEPARTME~T OF STATE
o-ISPENSAB.LE.
!;JAS OF PARAMOUNT IMPORTA1JCE ,IN tHVING ACCE-SS !0 wiTr:ESSES WHO

.~HE' Mn1BERS OF THE GOVZRri:1ENTS AND MILITARY ESTABLISHMENTS OF
~1AURITANIA
?HID PORTUGAL.
'LEGAT, ROi"1E, '~.'AS ABLE "T.O EFFECT THE
~ARCH BY TURKISH AUTHOR'!! IES OF A BOE I~G 7~7 GROU'NDED IN ANKARA,
TtJR KEY.
"
LEGAT, R 0~1E, 1,/AS ALSO I ~STRUMENTAL I tJ OBTA'INI~'G CEfn.I-
FIED "INCORPORAT_I.ON DOCUtr1r:NTS CO~ICER-NING 'cORPORATIONS CONTROLLED

BY SUBJECT IN THE MIDDLE EAST.
THE ASSISTANCE OF .LEGAl, tONDON,
\M S ALSO INVALUABLE IN COORD'! NAT] 00 ] 'WESTJGA! ION IN r\GLAND

AND OBTAI~Ut-G THE FULL .SUPPORT OF TfiE ~1ETROPOLl1A~~ POLICE <NEl,~
SCOTLAt\'D YARD)_, LONDON.
..
THIS CASE IS EXPECTED 10 HAVE A MAJOR IMPACT UPON T.HE COI-JMAN

OJ:1i1UNI!Y IN SOUTH F'LOR_IDA A.ND UPON 'THE
A~MS
I~ER.NA!'IONAL
TRADE At..'D 'ITS ASSOCIATED TERROfUST 'IMPllCATlONS.
MIA;.JI t!ILL ADVISE THE BUREAU \JHEN THE INDICn1ENT IS

ArD OF FURTHER DEVEL0Pl'1ENTS AS A.PPROPR !ATE.
EI'
ILLICI!
ACCORDINGLY,
UNSEALED~
.. -
JI'D.3e <an. &-1.3-'18> . '-
FBI
TRANSMIT VIA;
OFacaimile
PRECEDENCE:
CJ Immediate
CJ Priodty
o-----
tD Routine
fO Teletype
CLASSIFICATION:
CJ TOP SECRET
OSECRET
0 CONFIDENTIAL
0 UNCLAS E F T 0
E9 UNCLAS
AUGUST 12,
Date
t
l9til
-------1'
------------------------------------------------------FM MIAMI
(196A-l056) .p
~TO DIRECTOR ROU'I'INE

A'I'TN:
OFFICE OF CONGRESSIONAIJ AND PUBLIC AFFAIRS; AND WCC
SECTION, SUPERVISOR!
BT
UNCLAS
tJ
SARKIS GARABET SOGHANALIAN - FUGITIVE; DBA UNITRD TRADE 'INTERNATIONAL, ETC.
;I
b6
b7C
VICTIM; FBW; MF; ITSP; .00 :MIAMI
.RE MIAMI TELETYPE TO BUREAU, AUGUST 10, 1981.

-INFORMATION -IN BACKGROUND CONCERNING INSTANT l1AT'l'ER IS BEING
FURNI9~ED
TO THE BUREAU IN VIEW OF ANTICIPATED W'IDESPREAD
t*o\ e.d-a ~L
IMMBDIA'fE INTEREST IN THE NEAR FUTURE.
..
\
(!}-
Miami
~r=mia ~
/~
Approved:
Transmitted
_O:::.=:ifb:--:--:--.;;;((l~'J2.~-CNumber>
C'l'i~)
":~'~.:.==:w..::~:;:;,;: ,:;::,.~.:~:_ -.::.:--7:~ __!_;,~-. ::~.;~~~~.;:===-~~=~~'";~,!:~~~~'-"

tt"
ro-as (Rey. ~~78)
..
'~
FBl
TRANSMIT VIA:
D Teletype
D
D
CLASSIFICATION:
. 0 TOP SECRET
OSECRET
'0 CONFIDENTIAL
0 UNCLAS E F T 0
OUNCLAS
PRECEDENCE:
:D Immediate
D Priority
Facsimile
ORoutiDe
I .
I
I
I
1
I
I
I
I
Date--------1
----------------------------------------------------PAGE TWO MM (196A-l056) UNCLAS
bE
b7C
BACKGROUND ON SUBJECT :IS AS FOLLOWS:

SUBJECT IS A 52 YEAR OLD NATIVE OF TURKEY WHO HAS LIVED
IN THE U.S. PERIODICALLY SINCE 1958.
SUBJECT IS AN .INTERNATIONALL
KNOWN ARMS DEALER, WHO HAS BEEN THE FOCUS OF CONSIDERABLE U1MEDIATE ATTENTION BOTH IN SOUTH .FLORIDA 'AND NATIONALLY BECAUSE
OF HIS ARMS TRAFFICKING IN 'l'HE -PAST.
SUBJECT HAS .BEEN' INVES-
TIGATED BY A NUMBER OF U.S. AND FOREIGN POLICE AGENCIES FOR

SMUGGLING OF ARMS, STOLEN AUTOS, AND NARCOTICS, BUT UP TO THIS
TIME, HAS SUCCESSFULLY ELUDED PROSECUT-ION.
.,.
SUBJECT IS ALSO
CURRENTLY, UNDER INVESTIGATION 'BY U.S. C011MERCE DEPARTMENT, NEW

YORK, FOR ALLEGEDLY -HAVING SOLD A Cl30 TYPE AIRCRAFT .TO L'IBYA
.IN -1979.
SUBJECT IS ~LSO A -~NOWN
L...-_ _ _ _ _
___.fURRENTLY A. BURBAU FUGITIVE, ON TERRORIST CHARGES.
SUBJECT WAS TARGETED BY MIA.MIDIVISION AS A HAJOR CRIMINAL

.FIGURE lN SEPTEHBER, 1980, .AND . HAS BEEN THE SUBJF.CT OF A YEAR
Approved:-------
Per _ _ _ __
'':, :.:p~,-.;::;:::::::,,. ~;.,-:..__: : ~~-r
" .
::..::.:::;:.;:~~~-~:~:~'.?'.:~~"';~:,!.~~!~ ..
....
FBI
TRANSMIT VIA:
Cl Teletype
Cl Facsimile
0------
CLASSIFICATION:
OTOPSECRET
PRECEDENCE:
C) Immediate
D Prior.ity
OSECRET
CONFIDENTIAL
-ORoatine
UNCLAS E F T 0
OUNCLAS
I
Date - - - - - - - i
----------------------------------------------------'
PAGE THREE MM (l96A-1056) UNCLAS

.LONG INTENSIVE INVEST~GATION CONDUCTED THROUGHOUT THE U.S. AND
IN NINE FORE-IGN COUNTRIES.
THE FOLLOWING Is A SYNOPSIS OF THE FACTS OF THE INVESTIGA'!'ION:
DURING 1977 SUBJECT, OPERAT'ING FROU MIAMI BEACH, FLORIDA,
AND THE WASHINGTON, D.C. AREA, CONTRACTED WITH AN ENGLISH
BUSINESSMAN,!
ITo suPPLY 197 NEWLY MANUFA~TURED
BROWNING 50 CAL_IBER MACHINE-GUNS OF u.s. ORIGIN. I
I.IN
'TURN HAD CONTRACTED TO SELL THE WEAPONS TO 'I'HE lSLAMIC -REPUBLIC

OF MAURI'I'AN.!A, A .FORMER FRENCH COLONY ON THE NORTHWEST COAST
OF AFRICA.
MAURITANIA.WAS AT THAT TIME ENGAGED IN A BORDER
WAR AGAINST COMMUNIST GUERRILLAS SUPPORTED BY LIBYA AND ALGERIA .

...
IN JULY, 1977, SUBJECT TOOK RALPH AND A -REPRESENTATIVE OF
THE MAUR:t;TANIAN GOVERNMENT 'I'O. VIEW 50 CALIBER MACHINE-GUNS
AT AN ARMS -PLANT :IN NEW YORK.
SUBJECT CLA!MED THE PLANT WAS
MANUFACTURING NEW BROWNING MACHINE-GUNS AT THE RATE OF 30 TO 40

A MONTH, WHICH HE WOULD SUPPLY .'I'O .F-ILL THE CONTRACT.
TIGATION DISCLOSED THAT rN'FACT, THE PLANT WAS
INVES-
J~ANUFACTURING
ONLY SPARE .PARTS FOR MACHINE-GUNS AND WAS NOT ASSE.HBLING
Approved:-------
Transmitted -~":""""::---~-=---
,,
<Number)
CTU.)
Per _ _ _ __
b6
b7C
.-::..;:::-:;.~'"-.:~:. -:; .::.::~;.':"-;.: :-~..;::....- ~- :o..::-:.:=:.:-.:;;-~~:ti~:.:E:t~~~7~~~-~~----.
!,
. . . -
FD-a& (Bey. 1-p-78)
FBI
TRANSMIT VIA:
Cl Teletype
QFaceimile
0 Immediate
D Priority
0------
ORoutiDe
PRECEDENCE:
CLASSIFICATION:
.CJ TOP SECRET
OSECRET
0 CONFIDENTIAL
Cl UNCLAS EFT 0
OUNCLAS
Date-------;
----------------------------------------------------PAGE FOUR MM (196A--1056) UNCLAS

MACHINE-GUNS AT
~HAT T~ME.
~HE
GOVERNMENT OF MAURITANIA SUB-
SEQUENTLY .RAISED A LETTER OF CREDIT WITH A EUROPEAN BANK FOR

1.6 MILLION DOLLARS TO FUND THE PURCHJ\.SE OF THE MACHINE-GUNS.
IN NOVEMBER, -_1977, SUBJECT DISPATCHED HIS .REPRESENTATIVE
TO EUROPE, WHO PRESENTED TO A BANK FALSE DOCUMENTS, INDICATING
THAT 197 NEW BROWNING .SO CALtBER MACHINE-GUNS WERE ON .BOARD
A BOEING 707, WHICH HAD TRANSITED TO LISBON, .PORTUGA,L, READY
TO MAKE DELIVERY
~0
MAURITAN-IA.
UPON PRESENTATION OF THE
FRAUDULENT DOCUMENTS, 1.6 MI.LLION DOLLARS WAS TRANSFERRED TO

L---------~~BANK 'IN BELGIUM, OF l'VHICH -1.153 MILLION DOLLARS WAS
THEN WIRE
~RANSFERRED
TO SUBJECT'S BANK ACCOUNT IN NEW YORK CITY.
AS TIME PASSED 'AND NO WEAPONS WERE DELIVERED, SUBJECT OFFERED

VARIOUS EXCUSES FOR NON-DELIVERY; ~.E., DIFFICULTIES WITH THE
AI_RCRAFT f\ND EXPORT -LICENSE 1 .LACK OF TRIPODS FOR THE WEAPONS,
ETC.
IN FEBRUARY, 1978, SUBJECT DISPLAYED CERTAIN .SO CALIBER
MACHINE-GUNS ~N PORTUGAL Tol
~D A.REPRESENTATIVE OF THE
MAURITANIAN GOVERNMENT, WHICH .HE CLAIMED WERE THE WEAPONS IN

QUESTION.
SUBSEQUENT INVESTIGATION :.IN PORTUGAL DISCLOSED THESE
Approved:-------
Transmitted -":;:;-"-.--:--":'!"--:--CNwaberl
CTimel
Per _ _ _ __
b7C
-e
~
I .
I
FBI
TRANSMIT VIA:
0 Teletype
OFacsualle
PRECEDENCE:
CJ Immediate
0 Prior.ity
0------
.CJRouUne
I
I
I
I
I
I
CLASSIFICATION:
Cl TOP SECRET
QSECRET
0 CONFIDENTIAL
o UNCLAS E F T 0
OUNCLAS
I
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I
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I
I
I
I
Date
----------------------------------------------------PAGE -FIVE MM (l96A-1056) UNCLAS

WERE SURPLUS WEAPONS BELONG_ING NOT TO SUBJECT BUT TO THE PORTUGUES
GOVERNMENT, AND HAD BEEN MADE AVAtLABLE TO SUBJECT FOR VIEWING
IN HIS CAPACITY AS A PROSPECTIVE BUYER ONLY.
TION IN PORTUGAL ES-TABLISHED
~HAT
FURTHER INVESTIGA-
SUBJECT DID PURCHASE .300
SALVAGED .50 CALIBER AIRCRAFT MACHINE-GUNS FOR ABOUT $110,000.

HOWEVER, THESE MACHINE-GUNS COULD NOT BE USED BY GROUND FORCES,
A~D
MODIFICATION OF THE MACHINE-GUNS TO GROUND STAND.ARDS WAS
NOT COMMERCIALL'.{ FEASIBLE.

SEIZED DURING
~978
THESE 300 SALVAGED l1ACHINE-GUNS WERE
BY THE 'PORTUGUESE POLICE BASED ON A COMPLAINT
FRO~D 'EVIDENCE THAT SUBJECT HAD PRESEN~ED FALSE

DOCU~ENTS
TO
LICENSE.
SUBJECT'S INTENTIONS WITH THE 300 SALVAGED MACHINE-
~HE
PORTUGUESE GOVERNMENT TO OBTAIN AN EXPORT
GUNS 'RE,MAl_NS UNCLEAR.

WERING
l~QUIRIES
EVENTUALLY, SUBJECT SIMPLY STOPPED ANS-
FROM :RALPH, .KEPT THE
1.~53
MILLION DOLLARS,
AND NEVER DEL:IVERED ANY WEAPONS -TO MAURITANIA.

THAT
~HE
IT IS NOTED
TOTAL LOSS TO MAURITANIA WAS 1.6 MILLION DOLLARS .
.DURING THE COURSE OF. THIS. :INVESTIGATION, .THE ABILIT.Y OF

THE FBI TO CONDUCT
:INTERNATIONAL -FORE~GN
J:N THE WORLD WAS AMPLY DEMONSTRATED.
Approved:------'
INVESTIGATIONS ANYWHERE
TRAVEL BY THE M!.AHI CASE
Transmitted --=::--:--:----:::::--o:--CNumberJ
CTi l
"
Per _ _ _ __
b6
b7C
;.,...__-::......'~~-~
.,; .........
-~'
'rtl1f
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~~
.. ,... . . ,
.1011
'
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.
TRANSMIT VIA:
.,
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biiT
....
111~......,.,-
1*-";illoU'tl'
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......--~-_,--.........,....,._~,.__._.......w
,.
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t.'ff- ~,........ ........................ ~. . . . "-~
It
---
FBI
0 Teletype
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trl*
..._..........,....,.."" .......... ~ .......-.~
.,.....~_
.,.,
PRECEDENCE:
~ Cl hlmediate
D Priority
-ORoatiDe
CLASSIFICATION:
0 TOP SECRET
C) SECRET
0 CONFIDENTIAL
0 UNCLAS E F T 0
OUNCLAS
Date-------;
----------------------------------------------------'
PAGE SIX MM (196A--1056) UNCLAS

AGENT TO MAURITANIA, PORTUGAL; AND ENGLAND WAS ABSOLUTELY INDISPENSABLE.
THE ASSISTANCE OF THE U.S. DEPARTMENT OF STATE
WAS OF PARAMOUNT IMPORTANCE :IN GIVING ACCESS TO WITNESSES WHO

ARE 'MEMBERS OF THE GOVEBNMENTS AND MILITARY :ESTABLISHMENTS OF
MAURITANIA AND PORTUGAL.
LEGAT, ROME, WAS ABLE TO EFFECT THE
SEARCH BY TURKISH AUTHORITIES OF A BOEING 707 GROUNDED lN ANKARA,

TURKEY.
LEGAT, ROHE, WAS ALSO INSTRUMENTAL IN
OBTA~NING
CERT_I-
FIED INCORPORATION DOCUMENTS CONCERNING CORPORATIONS CONTROLLED

BY SUBJECT IN THE MIDDLE EAST.
THE ASSISTANCE OF LEGAT, LONDON,
WAS ALSO INVALUABLE IN COORDINATING INVESTIGATION IN ENGLAND

AND OBTAINING THE FULL SUPPORT OF THE METROPOLI-TAN
POLICE~
(NEW
SCOTLAND YARD), LONDON.
THIS CASE IS EXPECTED TO HAVE A MAJOR IMPACT

UPON THE CON}mN
COMMUNITX ~N SOUTH FLORIDA AND UPON THE INTERNATIONAL ILLICIT
'
ARMS TRADE AND .ITS ASSOCIATED TERRORIST IMPLICATIONS.
ACCORDINGLY
MIAMI WILL.ADVISE THE, BUREAU WHEN THE .INDICTMENT IS UNSEALED

AND OF:FURTHER DEVELOPMENTS AS.APPROPRIATE.
B';t'
#
Approved:-------
Transmitted ~::"""":"~---::=:---:--<Number)
CTi)
Per _ _ _ __
.W. CZ
CH~O ~ 64
DE HQ
0364 2262234
z:'JR uuuuu
R 141S52Z AUG 81
~
l
F,\1 DIR~ C!OR F"l3 I
T.O FBI ~HA ~I ROUT I ~lZ
,,
fBI 1JASHHJGTON
,_
BT
U:IO.. AS
SAR J(!S GAR ABET
TC.;L..I_ _ _
____,~~ V~CTlt1; ffi'.~;
:.lF; ITSP (00:

I
'BY !ELETY?S DATED AUG.UST 14,. 1981, BE:R~J ADV.ISED:
'
SET OUT BELO':J F'OR THZ I:JFQR:~MTIO':J tJF .FS.IHQ AMD ~l!Ai'1! IS t:V.:
TEXf OF' U. S. E"BASSY, BERN, cABLE TO U. S. orrPARt:Jr::n Of STATE
NOTIF'YgG OF !HE ARREST O.F SU3JECT 1\J s::JITZERLA~:D:
:c-6
b7C
"SARKIS SQGHA}JALIAN \JAS PLACED u:.:DER PROVISIOtJAL ARREST BY

S:JISS.AUTHORITlES AUGUST 13 ON THE BASIS OF' THE Er-1r3ASSY'$ REQUEST.
! .IS 8FU~:G DETAINED IN JAIL AT ~E~JEVA.
THE Tl.oJO MONTH PER.IOO OF

I
?0 OVlSIONAL
DElE !l!.IO N ?R OVID ED r'OFl IN AR! IU. E Vl OF THE EXTRADlT 1 OtJ
(
I,
-PAGE
1 1.~0
DE HQ
;:,~64
UNCLAS
TREATY BEG HJS ! ODAY, AUG US! .13.
I-Ol:JE VER, 'THE S'.JISS DEP.AFrTr1E~T Of
JUSTICE AND POLICE ASKS THA! !HE F'OFH1Al. 'REQUEST FOR EXTRADIT!ON
TH~
10GET HER \vl!H
HARRANT
A~.'D
OTHER REQUIRED
-DOCU~1ENTS BE
'
"FOR\JARDED
AS SOON AS POSSISLS.. , OUR co:nACT SAYS .XHAJ i11.ISONERS HELD FOR EXlN~E
r~
?.::RlOOS AT THE -JAIL
1:~ !3E~JEVA
ARE OFTEN
ADV~f1SELY I~JFtUE~CED
BY JHE
OT.HER 1 ~H1ATES.
"OUR CONTACT ULSO URGE~JTLY REQUESTS DETtfiLS OF A! LEAST ONE
OF J HE OrFE NS~S 1:/ lTH \!HI CH SOG HA NAL lA 'I
rs
CHARGED.
UtiDER SvHSS
l.A',J, A PERSO'J UtmtR :PRovxsrotJAL URREST :1AY APPEAL OIRI':CTL'(..TO THE '
SUFRE~1Z
GOURT .FOR RELEASS F'Rm1 DETENTION.
SKOULD SOGHANALlMJ
~11\K?:
'SUCH AN _APPEAL, TH Sl-J~SS AUTHORITIES ::JOULD ~EED -SPECIFIC .INFOFP1AT10N

0~
A! LEAST O~JE CHA'RGT-: TO US I~J ARGU~lENT BEFORE TK~ SUPRE~1E COURT.

''T~LEGRM1 TO THE E,\13ASSY \HLL SUFF'IC?:, .f0Ri'1AL it.EADINGS F'R0:-1
1 HE US ARE
~WI
~SEEDED
FOR THIS PUR POSE.
''T.HE DEP~.RH1ENt OF JUSliC~ A'\D POLICE REMUIDS US THATU~WER

Tt TREATY, THE US lS RESPONSIBLE .FOR ALL COSTS CON~JECTED lll!-H THE
'
EXTRADITION, MlD 'THAT PAR XING FEES -FOR AlRCRA F'T AT GENE VA ARE QUITE
HIGH.
"vJHStJ SOGHANAL.IAN HAS ARREstED, 1HE StHSS PoLICE FOUSD !_HAT
THE ADJO.INING nooM
.
,I
'
__
'
~JAS
_occuPIED BY
IBoiHJ IL--______.
tG
t7c
'
I'
\
I
PAGE
rt-~EE
DE HQ
0~64
..:,.:.. ,.,, .
U:JCLAS
At BTAT,ER (SIC).
HZ
CLA"l~.ED
'
T.O BE .SOGI!A
~~l. IAN's SCRE:TAR y.
O'JR ?BLlCE cotnACT RECALLS THAT THERE \JAS .A REQUEST FOR ASSISTANCE
fROM T HZ FBI IN (!lARCH 1979 1.JHI CH
.z'~JVOL VED
AN H\O .lVlDUAL NM1EO
r-~------.
J;JHILE THE FIRST ,'MtiE MtJ 009 I:J THAT CASE WERE .D:IFFERENT, lHE: SHISS
1 HOUGH! I! ~~~ORTH'.vHILE
TO CALL lHIS TO
.,
.. OUR ATTENT.!ON :sINCE DISCrl:EPA~CIES
.so
OFTEN OCCUR l ~~ .ARABIC ~JA-:1ES A:JD BIRTH DATES~
b6
b 7C '
A> DETAILS OF AT LEAST
"AC!lON REQUESTED:
n:LEGRAPHED
OF THE
"PRO~PTL Y
~iJARRMlT
BERN
M:O OTHZR
INO ~ICES
F'E IHQ A~:0
TO 1 HE EMBASSY.
'00G4
'
NNNN
TO ifZ
8) XPED IT IOUS FOFWARD.IriG
.RE.QUIRtD FOR ZXTRAD!T.ION."
NEGAli IfF. RE .HA1E"1
~HA MI
REQUESTED TO Plro VIDE .13ER N WIl H A~JY I NfOR:1AT:ION
AVAILABLE IN BUriU:S RE
DOCU~1E "NTS
O~JE OF.F.~'~SS
L - 1_ _ _ _ _ _ _ _ .
-
.....
-TO: L_EGAT:
Bern
Bogota
Bonn
Hong Kong
London
Manila .
Mexico City
Ottawa
P.enaeoa City
Paris
Ro=e
B Tokyo
-Remarks:
SEE ATTACHED
Ene.
Bufile
Urfile
Memorandum
.
~,, ~(tttt~A~tlli'0LfJ
.,.,. 's4-l
S.bj<
-r/1r/1r1
I~(I!. sD~! oi\1V - ~
b6
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'
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23 21321
.,
} '.
, ,
AUG 81
f~
iiA3HINGTCN FIELD
. 1 0 . Hid CT OR fBI IMME;DlAT E
' ,)
.,
' ' ,
GA1rABET. SO(j HA NAL lA N- P'i!'Gii !VE; 'DBA

cp ' ''1.''" T(" I A!
t.,; i'lr\ L ~
R-E
. AUGUS!
.;
rJ I A.rH
.., ._ L.;-----.-:"""'r"-..,.J
T!.i:L 1' n~~sto ATF;,O AQ&US~ . 10, .
' PcLIGUST 14,
~4
. ! lN .AUGUST
..
.I
1
"T .-,
t '. i:_
t3, 1:181; A~~D : BUP?EAU t~hE'fYPES DA!EO
AND
19_(q,
' h~..
' '
'
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._.
:19ai~
.~ f
'
l9 B 1' ' THE>' FlLE~
' . >:.
IG2~H63f.;, CN 1}EC>1B!t}1
,.
'2'
,.
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14, 19}'9t'":AMD tHE
A UtfUf,D SlATES-
CIT~ZEN; .
... : - '
..-:- '
HQ MM
Z IJR UUL!UU
0 18.1300Z /tUG Bl
R'1 lvASHI NGTO~ FIELD Cl9~-406) CRUC):
T 0 D IR E CTO R FBI !;'11:"1ED I ATE

c
FBI M!A'H Cl96A-1 056)
I MMEDIATE
3T
INTER NAT IO NP,L' ETC.

C00 :
;L..I_ _ _ ____.
~1IAM!)
RE MIAMI TELETYPES DATED AUGUST . 10,
A~D ~ UREAU TELETYPES
14, l9 8 L
O N t~UGUST
14, 1981, THE .FILES OF
UNITED STATE:S D E PARTi~E .NT
SON, GAFiABET SP.RKIS SOGHANALIAN, i;JA S ISSUED

K3208636,
ON DE CEr1BE R 14, 1979i AND THE SON
FAT HER \"JAS 'JOT A UNITED STATES CITIZE tl;

FAT HER ;
:.~,r Ho
IS rH; '
rnu: or< GAPrro NED
A U~IT ED STATES PASSPORT~

'.-._-
CASE,
TWO DE tJF' 0003

DUE TO .THE ABOVE~
NO FURTHER
THE BUREAU IS REQUESTED
T 0 . LEG AT,
000 3
ro DISSEMHJATE
f'()-302 (REV, 3-8771
"
.......
''
FEDERAL BUREAU.OF INVESTIGATION
~te ottr,nscrlpttQI'I
8/7 L81
:
.I
Ivice :President Nummrick. Arms Cor_porat:ion
Wood_stock, New York, recel.ved service of
to
in
Miami. 'F16fida, on August 5, 1981, .from Special 'Agent_
I
.
.
. . . _________.
1
proce~s
af~ear
,,
'
"<!
,.
'
'
b6
'
'
-~
,.
This <loc.....,ent contilns neithet recon'""''"<l~tfol'l$ nor conclust<>ns of .the1'8.1, I~ Js tl'l. propertyof thef'SIn<l is ~"" to yo11t ~ency;
Wn(litS 'eontel'lt$ are t'IOt ~0 l;>e (llstrtl)ute(l OYtsi(l'e YOII'1 .~et'l(y,
,
'
--- - - - - - - - ' ' - - - - - - - - - - - - - - - - - - = - - - - - -
_. .
c '"-
AIR'l'EL
8/14/81
~0:
SAC, MIAH.I (l96A-1056)
FRO!-!:
SAC, ALBANY (196A-296) (RUC)
SUBJECT:
::: :te:
l:J3
SARUIS G. SOGH.l\UALIAN
(00:
r~~i~ternatiOnal J
't. p
MIAMI)
Re Miami airtel to Albany dated 7/9/81.
_,, l~,Miami (Encs. 3)

l.~Albany
LDS:njd
(3)
b6
b7C
FD-36 (Rev. 5-2~78)
FBI'
TRANSMIT VIA:
PRECEDENCE:
0 Teletype
t:l Facsimile
t::J Immediate
0--------
Priotity
0 Routine
AIRTEL
CLASSIFICATION:
0 TOP SECRET
0 SECRET
0 CONFIDENTIAL
0 UNCLAS E F T 0
0 UNCLAS
Date
TO:
FROM:
SAC, ALBANY (196A-296) (RUC)
SUBJECT:
.I
I
I
I
8/14/81
SARHIS G. SOGHANALIAN
dba United Trade International;
I FBW; ME'; ITJPVICTIM
(00: MIAMI)
b
b
I:J
Re Miami airtel to Albany dated 7/9/81.
,.
1
~Miami
(Encs. 3)
~-Albany
LDS:njd
(3)
11 - /1)-.r.z..- /?~
~EARCHED----JXOEXED
' !tRIAUZED-FlU:D
AU!) 1 9l9tU
FBMIIOIJ
t
!
\
Transmitted
-:-::--:--:---=--=----(Nu=ber l
(Tixne)
Per,_ _ _ __
AUG 2:11981 .
'
,f
, A
..
..
I'
.
~.-'
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'
'
'7/7.7/81
AIRTEL
-'l'O
Director, FBI
FROM
Legat, London '(196-200) (P)
,i
b6
b7C
'
'
00- Miami
_
1
Enclosed .for the Miami Office is a copy of a

-report dated 7/10/81 1 prepared by DetectiveConstablel
New Scotland Yard, London, tc)qether with .Airway Bill N~o-.----:~O:-:~l~0~9:-:0.,.4-r8
.
3621 and Statement of witness form. No copies of the enclosures
are furilished FBIHQ nor being -retained ln London Office.
-~?A-(;j a- . ~ ..,_'
- ' . :
4-wu
~~h-{:a_
- Miami) ( 3 enels) <.:.:A:.=.tt.;;:n;;.;:;....;;.S;;.;.At..l_ _ _ __j

1don
RAK:rn
(5)
AUG.2 l 1981
,.
...
~
7/27/81
AIRTEL
~0
Director, FBI
FROM
Legat, -London (196-200) (P)
SARKIS GARI\BET SOGHJ\NALIAN,

dba Qnited T+ade International,
FBW, MF I
'
-Etc;
_!VICTIM
I'l'SP
00- Miami
Enclosed for the Miami Office is a -ctoy of .a

report dated 7/10/81, prepared -by Detective Constable
l
New Scotland .Y ard, lOndon, t()(Jether with Airway Billo. oio 9o48
3621 and Statement of witness form. No copies of the enclosures
are furnished FBIHO nor being retained in ~ndon Office.
4 - Bureau
Miami) :(3 encls) c....
At....,t.-n....: .....s....d~--------J
l -LOndon
0-
RAK:rn
:(5)
b6
bic
CW. F'LF'''3 I N\~00. NMl/S 0 GJL~ NALI AN, S AR~ IS
FLF8H1l100
M/S03HANALIAN,SARKIS
AUG 2 4 1981
~~
f'- -- -
2_362235Z
AUG 8 1
P J: UH I TF. COLl.AR OR Ir:1E

. GONGRESS I OM t\L AND
GARABrT SOGHA NALIAN,DBA

~.L...J.----.........,
I CT HI! ~ F'3 W; ~1 F ; l T SP ; '0 0 :
UNITED TRADE
M1 Al"l I
-.~...,....,.----
.MI AN I .
SlHT?:ERLA rJD
IN
TH~
CUSTODY' 0 F THJ::
IN Sv!ITZERLAND.
I-NITIAL
\ .
1
,. '-,
_?00' PF:RSONA~.
.A ; r> $500,
.
"/"
0 ,~:~H\0 BY Stt8Jr'CT AT MIMli BEACH, fLORID.~.
AT INITIAL APPEARANCE.
ON.

..,- T'' r
.-
-,~,
"~IC
(1f'l~~~-1"'5l")
rv;-Ar~"n.
fJ"CL/IP,
,_.
'
'
~-
......
,ol""'
.PRECEDENCE:
"'PANS MIT .VL\:
,E Teletype
., .
I
.FBI
-CLASSIFICATION:
CJ .TOP SECRET
Cl SECRET
CJ.Facsimile
0 _....;...______
0 CONFIDENTL\L
CJ. UNCLAS.E F !f. 0
~NCLAS
.
Date
I
I
I
T
I'
I
I
~
August 24t, '1981

I
~------------------------------------------------------FM:MIAMI (l96A--1056) P
.ro
BUREAU {
PliioiZircj)
. AT'I'N: WHITE COLLAR CRIME SECTION,. SUP.ERVISORI.__ _ _ _____.lAND OFFICE
. OF CONGRESSIONAL 'AND ,PUBLIC :AFFAIRS.

.
. sT
b6
b7C
, UNCLAS
, SARKIS 'GARABET' SOGHANALIAN, DBA UNITED 'l'RADE INTERNATIONAL;c=J
K'ICTIH; Fm'l; MF; :iTSP; 00:
MIAMI,.
:RE MI~I TEL TO ;BUREAU 1 AUGUST 14, ~1981.

ON AUGUST .22,. 1981, SUBJECT WAS .RETURNED TO MIAMI FROM
GENEVA, .SWITZERLAND, IN THE CUSTODY OF 'l'HE us MARSHAL SERVICE,
, HAVING f7AIVEb EXTRADITION .IN 'SWITZERLAND.
ON AUGUST -24, 1981,
SUBJECT UNDERWENT INITIAL :APPEARANCE FOR US MAGISTRATE HERBE~T S .

SHAPIRO,. SDF;. AND WAS 'RELEAS~Do:N:$SO#OOO COMMERCIAL SURETY BOND
'AND $500',000 -PERSONAL SURETY 'BOND coLLATERALIZED BY 'l'WO RESIDENCES
I
OWNED BY SUBJECT AT MIAMI BEACH, FLORI'DA.

UNSEALED AT INITIAL APPEARANCE.
(l\_ .Miami
'ffflL/cir
(1) CAfi,..
0
i,
I'NDICTMENT AND WARRA..~T

/'
'

TRANSMIT VIA:
CJ Teletype
0 Facsimile
0-----
FBI
PRECEDENCE:
.CJ Immediate
0 Priotity
O Routine
,,
~,.....)
_.-
CLASSIFICATION:
0 TOP SECRET
CJ SECRET
0 CONFIDENTIAL
0 UNCLAS'E F T 0
0 UNCLAS
Date - - - - - - - - - - ;
----------------------------------------------------.PAGE TWO (l96A-1056) UNCLAS
NCIC CLEARED.
BT
Ap}>l'oved: - - - - - - - -
Transmitted"-:':':-":'--:""--=:-~--
<Number>
(Time)
Per-----
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UNITEOSTATESOFAMER:cA - --- --
WMMNT OF lR~~SPORTATION- f0EAA~ AVIAliO~ AOMINI$lRA!IO~

CERTIFICAtE OF AIRCRAfT REGISTRATION
mFT
S(I~A~NO.
eth11t~enopo:a~.
..,.,..
US. MAlL
.........
17601
\..
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707~321
bOEING
mvslb4ht.ee~
'~
lhi$terii~Ca\el$
INI'i EC 1RAC~ Ufl L INC

' PO aox 1448
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25 .November 197.5'
('
Federal Avi_a tion Administration

Aircraft Registration Branch
P.O.Box 25504
Ok_l_a homa City
Oklahoma ?.3125
Gentlemen:
I am acting as the Resident Agent :for United Tra_d e Inter-national, Inc., a 'Delaware corporation, wbo are the ovmers o:f
a .Boeing ?07~.321 aircraft, S/N 16701, p\trchased l _a st surn.nler :from
Concare Aircraft Leasing Corporation of Tulsa, Oklahoma. It is
being operate d by the owner u:n_d er F-AR, Pfrt 91 ~(ovi_ sions, and
bears the original ai_r cra:ft registration_
__ ,ref'l.'ecting its
_prior ovmersh_ip by _Pan American ~'lorld Airways, w o sold it 'to
ConGare.
t
turns out after several months of experience, that the
~...-____.I designator is causing a certai_n am_o unt of con:fusio_n in A_TC.:

circ:cs
oversea:;. si:1ce tne cont_rol_l_~rs . a~tomatically .identif"y it
as a :PANAM ai-rcraft, and. -ground contro~lers f'requently attempt to
direct the xnacbi:ne 'to the -PANAM of'floading a:reas on a:r;ri val. I<'or
this reason, vre would like to cbange tbe Certif'icate of Aircraft
Reg~stration to a deS:ignator tbat more ,accurately represe_
nts :its
ovme_rship.
'
~s
far as des~red numbers are concerned, here

any one of: wh_ich woul_d be satisfactory:
"l
a:re~
few samples,
-
us of the a:vailab.ili ty of a number, at the sarae time sending us
the required .form to be completed 'to ef'f'ect the change; w,i. tO. t~1e "
unqerstanding that this :form must be signed by ~he registered owner
of the aircraft and 'returned to you with a paym~nt of $10 fo_r th~
.service. 'We assume that a temporary CofAR would t hen be i _s sued, and
the old c...erti-:ficate would tl)erea:fter be surrendered.
\'le understand that you wi_
l l research t _b ese numbers ~nd .advi_s e
I should note -that the corporatio_n address of record on the

cu:i"rent certificate is the corporation administ_rator in Wiltningto:n.
I at all possible, I would :I_ike to ask that the new certificate
,_
ei thcr be sent direct to me, s_i _n cc I \'rill be preparing the .form and
f'orwardin~"
it to t _h e aircrcw ,overseas, or, al-ternatively to th~ _
0
owner who would send i t to me. We wi_ll be trying to meet a deadline __
o 7th December, at which tim_e the aircraft is sch~d~led into . Atla:nt~cAviation in Wilmington .for a paint job, Which hopefully woul9. _i_n c-J.ud_e
.,__ .
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the new side number. I:f' it were possible, perhaps I could be

advised by phofle i~ the new number is granted, so that it could
be incorporated in the planned painting.
Thank you -for your attention to this request.
~ r-------------------------------------~
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BOCA INVESTM-TSLIMITED
Res;is.tetro Office:
PLEASE_ REPLY TO THE AITACHED ADDRESS

USlNG THE ADDRESSED LABEL FOR YOUR
CONVENIENCE:
t---.~
-------~----
.I
--------
~sq.
COnsultant,
Directors:
Executive: Directors:.
,Adtnini$trttion:
Telep-hone:
Boca Investments Limited,
P. E. Ralph(Australia}
M. Ralph (Australia)
I Sensa e ~ello (Portugal)
Consultant)
JU.K.
TEl. No:: 05805 2aT7
c/o 'Keepers's Cottage'

Flimwell,
East Sussex.
,England.
17th August 1981
ANSWER SERVICE
TEL. No.: 022761218'
TELEX: 96118 ANZEEC G
'lhe_ Fed.era.l Bureau of Investigation,

;801, Biscayne. Boulevard,
Miami,
Florida 331:?7,
u.s.A.
For the attention of
. _ I_ _ _ _ _ _ .
Dea~L----....J
Sarkis G. Soghanalain
I. would_ like to bring to your attention the. fac~ that the

Civi~ Aviation AuthoritY - head office - in London has an
extensive file onl
~d.. its operation under the
registrationjL..._ _ _...J
l understand that maintenance records and other records o!
the aircra~, together with affidavits of evidence are
with the file.
the. investigating of.fice~ for the CAA

.__c_an~be~-c-o-n~ta-c-t~e~d~on the London telephone number:-
...
- his
work number'.
I have had two meetings with hi~ to date and i have also
advised the Foreign and.Co~onwealth Offic~ (Nort~America
Department) of the CAA interest.
.
1
,-
r---
OTEt Submit ORIGINAL ond ONE COPY.:
r - - - - l_,;......__ _,
Name
'
'
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SOGHANALIAN 1
I lIJ I
4 I I I I II
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305 ~ .~IBISCUS DRIVE

.
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(Numb~r (Wl $tr~~t)
D~te ~f Birth
Nation~lity
(inClde ,
rtvmth, da~, ,ear)
SARKIS ,
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Identifying Nijtnbtr
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[ype of reque$.!
FBI,
-Miami, ~Fla.
, :Lebanese ,
2/26/29
(State)
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_(City)
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~AMI ~BEACH,
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GARABET
CJtl l]r~ LJF3 :
D~te. of request
C)Othex
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Cancell~tion d~te
?incl, month, ~ear)
: (in,l.mrmth, da~,.year)
tt a aut r 'kl 1/r uou i
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'ftDERAL 8URE~U or INVE.SUCAno~-~PC~. ,,r.'t'l'l~-'41

INS Lookout
Notice
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Plo(e nt\'nWReMove
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I~Migrotion Of!d Hoturoltzotion Servite, , : '. . , ~ .. ~(2-.. ,

425 eye. Street,' N.W,, Woshington1 0, C. 20536
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FD-350 (Rev. 12-578)
oj
<Indicate page, nar:oe of

newspaper, city $lid state.)
Page z B
Miami Herald, Miami,
r-----~-----=~:.:...;:.:.:~~~:...:.:.:::.::.!..-----1 Date:
8/25/81
b'
1.
.Edition:
Final
Title~:
SARKIS SOGHANALlAN
Character:
or
Clauif!catiori:
SubMitting Office:
'
196
MM
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tJ.uG k 'i 1931
re1Jooo~
FD-35_0 (Rev. 12578)
<Indicate page, name ot

newspaper, city e.nd state.)
Page 2 A .
Miami News, MJ.amJ., Fl.
_ _ _....;......;.._ _ _ _ _ _ _ _j;(M~o~u~n!_tC~1~~r!nlS~po~c!.!B:!!!Io:!w'.!.)_..;.'";,..;;.......;....;.._ _"1-:i:~on:g /25 /81'
_ _
Metropolitan
_Title: SARKIS
SOGHANALIAN
Character:
or
Clas-sification:
Submitting Office:
196
Annenian.iat.rh$deale.r ih~iCtedil~
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~mary factor fn ~re~~l_l8 Lebane~ hO~_tagel held 'br;the ..
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,1A tlamboyant Armenf4n ttml. dea1et-.k!lown tor -Palestl!lian U~r~~1on OrganlzatlonJn 1~7S.
Y. ,
ptd<illng artillery to Thltd World rounttftf, }lU !>Jt_n, r . .Soghanaliari had beezi'Jnvestlgated: by~ ted era! oftf.,,
fndkted by, a Mlamt federal grand Jury. on Cu&rgg of.,, cl~.Js $.!nee 1978 when teports suttaUd, that :he- ht<11
detrauc1fng a small Af~ean natf_on ~nd a priv~t.e ~tP<>-, .fru$trated a.U.S..-.weapons embargo on the late Nleata
,
-. . ,
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,-
ratlori of moie thin $2 million 111 All arms-du~ scam. . .,'..guan president Anast~sio ~om~ .
..
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Sarkfn Soghanalfan. a Lebtne$e natlona~ who ~wns.

In .Sept. 1978. John RaJph1 owner and duet operat
} a plush Hibiscus Island home fn MJtmJ Btach;,was frj.. lng' oltfeer 6f.BOU'Iiiv~tments;!ilid a $1mi1Iion Sui*
dieted yesterday.
agafrist: Soaharii.Ut~ Jn'I>ade, ctrcwt: Court. ehargfng
, , The Indictment said. thtl (he lsiamfc. Republic of that he tafltd to 'supplY, the'plane!Oad of machine guns
(_' Ma\trltanft; and ~ lnv~stments L~~l a prlv:ate rot to Matirlttnft:.
,
. ,
i
.
poratlon; had ci>ntracted wltb Soghinalfan In .1977 to , :R~nting of!lce~ lri Cocoritlt. 'Grove and. Fort Lauder:-,
1 deliver more than $2 mlJ_llon fn . .50-caHber.mae~tne 'dale SoghanaUarf~amtd:'a *orldwlde repntaUon'by
l. guns. The grand fury charged Sogbanalfan. kept the ......rJiing
machine guns and tanks _
'mtllltyandneverdellve(edtbeatmsJ
. .
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t th
'J. r t . fri tw .1:>-&J .. gt.7
,' , .-S~hant.Jlan Wt$dr~.-tfter;pc)s~fng.a.$559,000-SpotS 0. tee._co;,tnens, ..~. 8, _ ~~~ .. :_.
,
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mortars~
tra~ ~e pros!ciJtod.~
~M~~<?:;h;';ul},!t~~e~po~S:,
Mldd~
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~eported1y
~1d
fa~k$
to J~rdan. AmeneJr;:,dl6
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$nf~r.
scope~ to Eeua<iof tn4 m~rtars
..
. bon
was allowedtorretalzi:h!$!pAssport
.
anywhere exeept fn the
Ea$t, atrordlng .
ito te4eral
.
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:,ifles to A.ngots.
~ ' Jn argufng to retain hls passport;SogbanaHan told to Mantftltlfa.l..
rl,~
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AIR'l'EL
8/27/81
DIRECTOR, FBI (196-1066)
.TO:
ATTN:
EXECU'l'IVE .AGENCIES UNIT, ROOM 5218
FROM:
SAC, MIAMI (196A-l056)(P)
SUBJEc;f
SARKIS SOGHANALIAN
t/
DEFENSE INTELLIGENCE AGENCY (DIA)
NAME CHECK REQUEST
"BUDED:
Re
9/30/81
Bulet to Miami, 8/19/81.
Enclosed for .the~ureau are .five copies of a letterhead

dissemination to DIA.
~randumor
Jl,_Ij 8/24/81, AUSA~

ISouthern .District
of Florida,~ppriaed of fh~~CheCk request~ DIA re
captioned subject. AUSA
sed no objection to re"lease
to DIA of the information
enclosed LHM.
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3-Bureau (Encs. S)
(2-Executive Unit, Room 5218)(Bncs. S)
~(1-Whita Collar Crime Section)
<!.:Y'Miam.i
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196A-1056
Miami, Florida
. August 27, 1.981
1m~
. '
SARXIS SOGHANALIAN
~ha 1 Miami Office of the Federal Bureau ' of

Investigation has -conducted an extenaive investigation
into allegations that .sarkis Garabet Soghanalian defrauded
the Islamic Rapublic-of .Mauritania of well over $1,000,000
in a fraudulent weapons transactiont Investigation disclosed
that soghanalian contracted to sell 197 :new .so caliber
,
HBM1 machine gUnS of United Statea .origin to Mauritania
through Boca Investments, a trading company formed in
the Jersey Channel Islands, Unitecl :ltingdom. SOghanalian,
operating principally in the Miami, Florida and Waehlngton,
D.c. areaa, allegedly created false docUJDenta vhich .he
subsequently .caused to be preaented -to a 'Belgian bank
.Aa a result, Soghanalian received $1,153 1 000 1n payment
for the :machine 9\Ul&, but failed to make 'any deliveries.
'
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'
on AUguat 5, 1981, a Federal. Grand -Jury sitting

at Miami returned a-true bill of indictment based on
the above inveatigation, charging Soghanalian .w ith Fraud
by Wire, -.Mail Fraud, and Interstate Transportation of
Stolen Property. Soghan.alian 1 who was residing in - ~eva,
SWitzerland a t the .time, was arrested on August 1 3, 1981,
by SWiss Police on a provisional -warrant based on the
above i ndictment. So9hanalian waived extradition
proceeding an4 waa returned to Miami on Auguat 22,
1981. Soghana1ian 'un4erwent an initial appaarance
before the .United .States Magiatrate, Southern Diatrict,
of Florida, on August 24, 1981, and waa released on
$550,000 bond aecure4 by hia two reaidences on Miami
Beach, .Florida. No trial date has been set at this -time.
Soghanalian ia further described as a white
ale, date of .birth February 6, 1929 1 place of birth ,
Alexandrette, TUrkey, reaiding -at 305/307 Bibiacus Drive,
This .document contains neither recommendations
_nor -conclusions of the FBI. It. is the propex:ty of the

FBI and ia lqaned t~ yow: ~gency; ,it and its contents
are not to be distributed outside your agency.
ureau
iami
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L~--------------~-=--~--~~~------~--~~~~~----~---------------- '
.Memorandum
- e
SAC,
To
~
s~t>Jt:
~iami
{i_96A-tOS6)~
Directol:, FBI_
Date
8/19/81.
(~96-1066)
S~RKIS SOGHANALIAN
J>_EFENSE. I.N'I'ELLIG.ENCE AGENCY.. (DIA)

NAME_ CHECK REQUE-ST
,
BUDED:. SEPTEMBE~ 30, 1981_
'
'
The :Bureau .is in receipt_ of: a. name check request:

troni th~~ DIA. concern_ing the. captioned. individual, a cop~
of: which _is attached._
,
l-iiami is directed,tQ its case captioned "Sarkis Garabet
Soghana1.ian:, doi~g business as,. unit.ed Trade International;"
I
!Victim; Fraud by Wire; Mail Fraud; Interstate
'l'ransportaJ..o.n of. Stolen- Pro:?erty ."
For your information, the: FBI is. authorized tQ
conduct: p,ame. checks for Federal Executive Branch. agencies.
in.. accordance. with. established procedures. (see. l-1AOP, .Part: 2,
Section 9, -~-2 .. 4).: where. these:n.ame checks relate. to pend~ng
investigative m~tte~s,. as in_ instant case, it is. out' policy'
tQ contact: the appropriate_ Office of the United. States.
Attorp.ey for di_ssemiriation, guidance. from a :?rosecutive
standpoint.
.,
Promptly submit: the. resultS: of thi_s. contact, and

b:t ncl.osed .letterhead memorandum suitable. for- dissemination,
the. information authorized, .mar~ed tQ t~.e attention. of
the_ .Ex:ecuti:ve. -?\genci_es Un_it, Room 5218, .FBIHQ.
bo
I:J7C
Enclosure.
flf/J-;0 ~
AUG
,.111/00_J'
,SAC, Miami
8/19/81
(l'96A-1056)
Director, FBI
(196-1066)
SARKIS SOGHANALIAN
DEFENSE IN'l'ELLIGEUCE ,AGENCY (DIA)
NAME CHECK REQUES'l'
/OODEDa
SEPTEHBER, 30, 1981

b6
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The~ureau 'is in receipt of a ,name check request

from the .DIA qoncernlng the captioned individual, a copy
of which
is attached.
,
.
Miami is directed to ~ts case captioned "Sarkis'Garabet

doing
United Trade,International;
__
__ __ Victim7
Fraud by Wire1 Mail Fraudr Interstate
anspor
on of Stolen Property" n
' ' I :;ahanal:::l
business as,
For your infor.mation, the,FBX is authori~ed to

conduct name checks for Federal .Executive Branch agencies
in accordance with established procedures (see MAOP, Rart 2,
Section 9 1 9-2.4). Where -these name checks ,relate to ,pending
investigativ~c.atters, as in instant case, it.is our policy
to contact theappropriate Office of th~ United States
.Attorney for dissemination guidance from a prosecutive
standpoint.
Promptly submit the results of this contact, and
by enclosed letterhead memorandum suitable or dissemination,
the infor.mation .authorized, marked to the attention of

, the 'Executive Agencies Unit, Room 5218, FBiliQ.
Enclosure
AUG 2 ~l
~Y~1
FBIMIAY.I
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.... ----
--
FBI
TRANSMIT VIA:
PRECEDENCE:
~Teletype
0 Immediate
CJ Priority
CJ Facsimile
0------
CLASSIFICATION:
0 TOP SECRET
0 SECRET
0 CONFIDENTIAL
Cl UNCLAS E F T 0
~ UNCLAS
'\
~Routine
/76G,o
8/28/81
Date--------;
----------------------------------------------------FM MIAMI (196A-1056) P

TO DIRECTOR (INFO) ROUTINE
ATTN:
I~~
WCC SECTION.
M.
i (__.
ALBANY (196A-296) (INFO) ROUT1.NE/-$
~ALEXANDRIA
(l96A-283) ROUTINE
BALTIMORE (196A-439) ROUTINE

I
'f
BT
UNCLAS
SARKIS GARABET
OGHANALIAN, DBA UNITED
L...-------------~~VICTIM;
~RADE
INTERNATlONAL;
FBW; MAIL "FRAUD; ITSP; 00:
MIAMI.
b6
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FoR INFORMATION OF -ALEXANDRIA AND OTHER OFFICES, SUBJECT

INDICTED BY FGJ, SDF, ON AUGUST 5, 1_981, AND CHARGED WI'I'H WIRE
AND MAIL FRAUD AND ITSP.
SUBJECT WAS ARRESTED ON AUGUST 13, -1981
BY SWISS AUTHORITIES.AT GENEVA, SWITZERLAND, WAS RETURNED IN

CUSTODY TO MIAMI AND UNDERWENT -INITIAL APPEARANCE ON AUGUST 24,
1981.
SUBJECT WAS RELEASED ON BOND AND ALLOWED TO RETAIN HIS
LEBANESE PASSPORT.
G).
DURING ARGUMENTS BEFORE THE MAGISTRATE TO
Miami
HAL:klj
(l)~.
~-----------------==-----------------~~--------------~-~--~--~-~-----~~~ ~-~
-~
:J
..
FBI
TRANSMIT VIA:
0 Teletype
0 Facsimile
0 =- - - - - -
CLASSIFICATION:
Cl TOP SECRET
PRECEDENCE:
Immediate
CJ 'Priotity
.'0 Routine
0 SECRET
0 CONFIDENTIAL
UNCLAS E F T 0
b7 C
0 UNCLAS
Date .- - - - - - - ;
----------------------------------~--------------~---PAGE TWO MM (196A-1056) UNCLAS
RETAIN HIS PASSPORT, SUBJECT'S ATTORNEY, L..l_ _ _ _ _ ___.l STATED

SUBJECT -HAD BEEN -INSTRUMENTAL IN FREE"I_NG U.S. HOSTAGES HELD BY
THE PLO IN :BERUIT .I N 1975.
IcLAIMED
HE HAD BEEN IN coN-
TACT WITH A U.S. ARMY COLONEL, (FNU) HUNT, WHO WAS ASSIGNED
~0
THE U.S. EMBASSY., -BERUIT, IN 1975, AND THAT COLONEL HUNT HAD
VERIFIED SUBJECT'S ASSISTANCE.~
~MENTIONED THAT COLONEL
HUNT WAS CURRENTLY :ASSIGNED TO ANOTHER U.S. EMBASSY IN THE M(DDLE

EAST.
BASED ON THE POSSIBILITY
THA~.__ _ __.~Y
DUCE COLONEL HUNT AS -A CHARACTER WITNESS AT
ATTEMPT 'l'O 'PRO-
~RIAL,
THE USA'S
OFFICE, MIAMI, BELIEVES FBI INTERVIEW OF 'HUNT PRIOR TO

WOULD BE HIGHLY DESIRABLE, IF FEASlBLE.
~RIAL
-ACCORDINGLY, ALEXANDRIA
IS REQUESTED .TO CONTACT DIA HEADQUARTERS AND 'ATTEMPT TO FULLY

IDENTIFY HUNT AND H-IS CURRENT ASSIGNMENT.
BALT-IMORE IS REQUESTED TO OBTAIN CERTtF.IED COPIES OF RECORDS
OF
.INCORPORA~ION
.FOR -QRC
lNTERNA~IONAL~
'INCORPORATED, 1411 JEF-
JERSON DAVI_S HIGHWAY, ARLINGTON, VIRIG_IN!A, BELIEVED
TO
HAVE BEEN
INCORPORATED IN DELAWARE 'IN 1974.

BT
Approved: - - - - - - - -
Transmitted ,_,.,..._,.~---:::=:--:--<N"IImber)
(Ti fl)
Per-----
f..~.
MM0004 24 01722Z
RR HQ AL AX BT
D'E MM
R 281722Z AUG 81
FM MIAMI 096A-1056>' P
70 DIRECTOR <INFO> ROUTINE
ATTN:
WCC SECTION.
ALBANY <196A-296) '(INFO> ROUT! NE

ALEXANDRIA (196A-283> ROUTINE
BALTIMPRE Cl96A-439) ROUTINE
SARKIS GARABET SOGHANALIAN, DBA UNITED TRADE

~.....-
INTERNATIONA~;
~ VICTIM; FBW; ~1AIL FRAUD; .ITSP; 00:
_ _ _____J
b6
b7C
.,
MIAMI.
FOR .INFORMATION OF ALEXANDRIA AND OTHER OFFICES,
SUBJEC~
INDICTED BY F.GJ, SDF, ON AUGUST'5, 1981, AND CHARGED WITH WIRE

'AND MAIL FRAUD AND ITSP.
SUBJECT WAS ARRESTED ON AUGUST .13, 1981,
BY SWISS AUTHORITIES, AT GENEVA, SWITZERLAND, WAS RETURNED. IN

CUSTODY TO MIAMI AND UNDERWENT 'I NITIA~ APPEARANCE ON
-1981.
'
'
AUGU~T
24,
SUBJECT WAS RELEASED ON BOND AND ALLOWED TO RETAIN HIS
LEBANESE PASSPORT.
DURING ARGUMENTS BEFORE THE MAGISTRATE 10
~0)
.r.!).RCHED
mnEr.to. ---e..~~
r.
~rolAUZEO. ... ",._._..._
viOoO'
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PAGE TWO MM C19GA-1056) UNCLAS
RETAIN HIS PASSPORT, SUBJECT'S ATTORNEY,!

SUBJECTHAD BEEN INSTRUMENTAL .IN FREEING
THE PLO IN 'BERUIT IN 1975.
.
U.S.
lsTA!ED
HOSTAGES HELD BY"
ICLAIMED HE HAD BEEN
IN CON-
TACT WITH A U.S. ARMY COLONEL, CFNU) HUNT, WHO WAS ASSIGNED TO
):;6
):;7
THE U.S. EMBASSY, BERUIT, IN 1975, AND THAT COLONEL HUNT HAD
VERIFIED SUBJECT'S ASSISTANCE.
!MENTIONED THAT COLONEL
HUNT WAS CURRENTLY ASSIGNED TO ANOTHER U.S. EMBASSY 'IN THE MIDDLE
EAST. B~SED ON THE POSSIBILITY THATL-1_ _____.IMAY ATTEMPT TO PRODUCE .COLONEL HUNT AS A CHARAqtER WITNESS AT TRIAL, THE USA'S
OFFICE, MIAMI, BELIEVES FBI INTERVIEW OF HUNT PRIOR TO TRIAL
WOULD 'BE HIGHLY DESIRABLE, -IF FEASIBLE. ACCORDINGLY, ALEXANDRIA
IS REQUESTED TO CONTACT DIA HEADQUARTERS AND ATTEMPT TO 'FULLY

IDENTIFY HUNT .AND HIS CURRENT ASSIGNMENT.
BALTIMORE IS REQUESTED TO OBTAIN CERTIFIED COPIES OF RECORDS
OF .INCORPORATION FOR QRC INTERNATIONAL, INCORPORATED, 1411 JEFJERSON DAVIS HIGHWAY, ARLINGTON, VIRIGINIA, BELIEVED TO HAVE BEEN
lNCORPORAiED I~ DELAWARE IN 1974.
BT
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~te
11/17/80
of trati$CI'iPtlon,_ _ _ _ _ _ __
!voluntarily appeared at the Miami

office of the Federaf Bureau of Investigation for the
purpose ~f rev.iewing the deposition he furnished on
September 11-, ..1979, ,in connection with case number 78.l4372CA08, Circuit Court of the :Eleventh Judicial court,
Dade :ounty, Florida. .At the conclusion of the review,
L......:---~Jfurnished copies of a calend~r and .itinerary which
he compiled concerning his activities dur..ins 1977. The
~tinerary and calendar are being 'retained as eviden~e
.by the Miami op-f.ice of the Feder.al .Bureau of .Investigation.
Miami,
:ll/5/80
;r~or.ida
bo
b7C
Miami ..l96A-1056-~~
lnwstl9atlonon _ _ _ _ _ _ _ _ _ ., _ _ _ _ _ _ _ _ _ _ _ _ _ _ Fi .. - - - - - - - - -
SAl '
Llb
ll/ll/80
bY-----JL.--------1-~----------0ate4i<:tate4----------Tillis 4o<:uMent eontaiiiS neitheoo reco~tl.c:latlons I'IOf conclusions of tl'le FBI. If Is the J)foperty ot tl'le F81 at~.c:l is loaned to your aget~cY:
It and l.ts contents are not to be distrit>ute.c:l outside yow aoeney,
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(RE;V, 3-$-71)
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_. ,,. Miami "Int'ellnatl.onal A.lrport, Miami, F-lorida, ..furnished
xerox copies of 'landing tickets at Miami ;Internationa1
Ai"rport :for a .Boeing '707 I :N711U'I' I during November ana
December,,l9i?. ~hese documents are being .retain~d as
'
evidence by the Mi-ami Office .of the Feder.al Bureau of
:Invest-igation.
.I
'Miami 1 Florida
10/24/80
ll'lvesug~uol'lon-;:::========~t---------------"n
llb
Miami l96A-,l056-7o<.---------10/30/80
s_.-.....,....,,.,................................Lt----------O.te cnett<t------------
by _ _ _ _
This <l.Oeurnen't eontln$ neltl'let neoMMel'ldftiOns f'IOr eonelvslons of tl'le 1'a1. It Is tl'le propertY of tl'le FSI-~nel 1$ oneell<;> yovr ~eny 1
I~ n<l Its contents are r><>t to .De Clistril;>uted outside Yol.lr gency,
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Memorandum
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To
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slit.,~ (116J/t,/dJ&:,)!I!) D~to
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081549Z SEPT 81
FM ALEXANDRIA Cl96A-283) CRUC)

TO MIAMI (19A-1056) ROUTINE
BT
SOGHANALIAN, DBA UNITEb TRADE INTERNATIONAL;
....._______.I
VICTIM; F'B\4; r1AIL FRAUD; ITSP;
<00:~1IAt1Il
RE MIAMI T~LETYPE TO DIRECTOR~ AUGUST 28, 1981; ALEXANDRlA
TEL~PHf"~lF
lro
CALLI
M.IMH
sEPTEMBER 1 ,. 1981.
ALFXANDRIA LIAISON WITH DEFENSE INTELLIGENCE AGENCY <DIA>

REVEALS THAT
"COLON~L
HUNT" IS PROBABLY RETIRED UNITED STATES
MARINE CORPS COLONEL F.ORREST J. HU'NT.
HE \!AS ASSIGNED TO UNITED
,<)TATE'S ~MBAS.SY, BE-IRUT, FROM 1973 - 1976, AND .PARTICIPA.TED IN

PL'O
~n=:GOTIATI0~1.S
PILOT.
FOR 'RELEASE OF A
DO~INED
UNITED STATES AIR FORCE
J,1Hl1 RETIRED OCTOBER, 1.976, AND DIA L.ISTS HIS _LAST KNOtvN
'
ADDRESS AS USA-RFP JECOR, APO NY 09038.

l S Hl RIYADH, SAUDI ARABIA.
DIA ADVISES THAT THIS
DIA HAS HIGHEST REGARDS FOR HUNT.
111
\
SEP 81981
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The' following FBI record, NUMBER
, is furnished FOR OFFICIAL USE ONLY.
Information shown on this Identification Record represents data furnished FBI b.Y fingerprint contributors.
WHERE DISPOSITION IS NOT SHOWN OR FURTHER EXPLANATION OF CHARGE OR DISPOSITION IS
DESIRED, COMMUNICATE WITH AGENCY CON)'RIBUTING THOSE FINGERPRINTS.
'NAME AND NUMIEl
CONTitltUT04t 0#
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CH.UGI
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Sarkis G.
Soghanal_ian
#19?2194
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20, 1966
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Sarkis G.
Sogh_a nclian
#163
,Sheriff's
Office
Los Angeles
California
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OF.',USTICE
23 drc 9/15/81
FEDERAL BUREAU OF INVESTIGAT
IDEHTIFICATIOH DIVIS ION

WASHINGTON, D. C. 20S37
l BU
..
The following FBI record, NUMBER

95.1.. 603 J3
, is furnished FOR OFFICIAl USE ONLY.
Information shown on this Identification Record represents data furnished fBI by fingerprint contributors. WHERE
DISPOSITION IS NOT SHOWN OR FURTHER EXPLANATION OF CHARGE OR DISPOSITION IS DESIRED,
COMMUNICATE WITH AGENCY CONTRIBUTING THOSE FINGERPRINTS.
'
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Information shown on this Identification Record represents data furnished FBI by fingerprint contributors.
DESIRED, COMMUNICATE WITH AGENCY CONTRIBUTING THOSE FINGERPRINTS.
' '
CONTitJtVTOt Of
fiNGU,RINT$
'
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DI$'<)SITIOH
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December Fugitive from

\. 20, 1966 Justice
Police
Department
Vestal
New York . .
Sarkis G.
Soghano1ian
#163
Sherirrs
Office
Los Angeles
California
Sarkis G.
Soghanalian
#1972194
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Federal warrant
United States
Marshal
May
7, 1972
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WASHIHGTOH, D. C. 20537
23 drc 9/15/81
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Information shown on this Identification Record represents data furnished FBI by fingerprint contributors. WHERE
DISPOSITION IS NOi SHOWN OR FURTHER EXPLANATION OF CHARGE OR DISPOSITION IS DESIRED,
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Copies to Offices Checked
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JO: SAC:
D AlbanY ,
0 All:uquerque
0 Alexandria
~8-
Anchorage
Atlanta
Baltimore
Bimingh=
BostOI.'l
Buffalo
0 Butte_
Charlotte
Chicago
8-. Cincinnati
C)
H~_ston
Indim.8p01is
Jadc$00
Jaksonville
Kansas City
Knoxville
Las Vegas
Little Rock
Los Angeles
0 Louisville
[J Meml)bis
~ Mia=i
Milwaukee
MiM.et()olis
~8
~Newark
Cle~land
RE:
Coluro.bia
Dallas
M~ile
tJ Oklah>m$ City
Philadelphia
BO!Uha
Phoenix
Bufile
Portland
Ricbmond
'Urfile
~B.
Pittsbugh
Sacnwento
St. Louis
..0 Salt Lake City
San Antonio
San Diego
San Frmcisro
SanJuan
Savannsh
Seattle
Springfield
Tnpa
_ Washington Field
196-1056
8-
Denver
NewHa~
Detroit
New OrlWls
El Paso
New York City
Honolulu
Norfolk
C) SAC, New Rochelle <MRA)
C) ASAC, Rapid City ('Mmi)
SEP 1G1981
Dote-------
SARKIS GARABET SOGHAUALIAN, FUGITIVE

FBH ;MF ;- ITSP
Validate NCIC Record
Modi~ to Include FPC
Enclosed is subject's identiticati<>D record. FBI#

~Enclosed is identificatioo record ot an individual who mJl or.~ not bJ identiealJ!b subject. Endeav to determine and
advise whether these individuals are identical. FBI # f~<; _ ~ &
II identical to fugitive, submit supplemental FD-65.
0 Asearch of the lWle files of the Identiticatioo Divisi<>D did not dis'close a finge11rint reeord for the above-camed fugitive.
Endeavor to develop any roditional data that will identity this individua-l with a fingerprint record.
0 Identiticatioo reeetd con$ists only of xo.ilit8l)' fing~ints. Fugitive notke being maintaiued 0 identical or 0 may be
identical with FBI #
0 Enclosed is in(ormaticc extracted fro=. i_dentitication record FBI # - - - - - - a s reqliested in u.rlet - - - - 0 Photographs aDd negatives trans=itted herewith. EJ No photograph avallable.
CJ Photograph may be obtained f r o m - - - - - - - - - - - - - - - - - - - 0 Original photograph from _ _ _ _ _ _ _ _ _ _ _ on microtib and will be fll'nished upon request
3 . . ::S"
FBI number
pertains to one
fJ()
Modify NCIO record.
,l{r /).]: fJ& (O jJI ,/)~ ~A.--~-7(.~1

3~
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FINGERPRINT CLASSIFICATION: 0
~o.:z;
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HCICCLASSIFICATION:
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FEDERAL BUREAU OF INVESTIGATIO'N
lcl~rk, Deiaw~re
I
Division of
.,
Department of state,
corporate kecords, ma,de available one certffied
copy of Delaware .corporate file for QRC International, Led.
Webb ~advise~! ;t~e corpore1tion became void on 'March 1, :1980 for
not filing annual . f.r~n9hise t~X", r~port.
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lnvestl9,tlon .c>n-....o.,__ _ ___._ _ _ _ at _ _ _ _
_ _ _ _Delaware
_ _ _ _ _ _..;__f"IM ._.-..;_ _ _ _ _ _ __
9/10/81
Date cHeute<l-------..:..--..-..--
'
Yl'lls <locvment ~ont,lns fleitl'ler reeornmendatiQns t'lor eonerusrons;of tM

aCid Jts ~olltents are flot ~o ~> <Hstril>vttd 'ouUidt yovr agency,
'I~
~81.
It Is t,.,. Property of tM f'81 and iS o,M<I ~o your:agency;

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FBI
TRANSMIT VIA:
PRECEDENCE:
0 Immediate
'Cl Priority
CJ Teletype
CJ Facsimile
C) Ro,lltine
tXJ--.AIR'l'EI, .
CUS SIFICATION:
0 TOP SECRET
0
CJ
0
0
SECRET
CONFIDENTIAL
UNCLAS E F T 0
UNCLAS
Date
9/22/83
-~---------------------------------------------------
SAC, MIAMI (196A-l056)
TO:
FROM:
BALTIMORE (196A-439) (SQ 7) (RUC)

IS GARABE'l' SOGHANALIAN
International;
L.....::=---=~--===' VICTIM;
FBW; MF; ITSP
00: Miami
~~~~~~~ade
Re Miami tel to Bureau, 8/28/81.
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Enclosed for Miami is one certified copy of Delaware

corporate file for QRC International, Ltd., an~.-302 .re
.receipt of same.
;:(5 .
ORIGINAl DOCUh
.
' 00 #.\.A . MtNT(S) ENCLOSED
n\lf BlOCX STAMP
Miami (Enc.
1 - Baltimore
JPB:bjd
(3)
SEARCUED.----l'~EXED_____
5ElUALIZED_FU.:>O--
SEP 2 51981
Approved:--------
Transmitted -<Number)
- - - - - - - (Tirr.e)
-----~u.S.
Per-----
GOVERNMENT PRINTING OFFICE1 198030$7$0/$402
'
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AIRTEL
9/22/81
'1'0:
SAC, MIAMI (l96A-.l056)
FROl-h
SAC, BALTIMORE (196A-439) (SO 7) (RUC)
SUBJECT:
SARKIS GARABE'l' SOGHANALIAN

Jrade International;
_ VICTIM;
DBA United
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Miami
00:
~iami
Re
tel to Bureau, 8/28/81.
'Enclosed for Miami .is one certified copy of Delaware

corporate file for ORC International, Ltd., and FD-302 re
recei_pt of same.
ORIGINAL DOCU
.
;.
MENT(S) ENCLOSED
0 NOT BLOCf\ SiAMP
~ Miami (Enc. 2) (RGIS .MAIL)
---i - Baltimore
JPB:bjd
(3)
SEP 25\981
fBI
F't3T: ;>itA\1r Cl .~!S-10~6) ROUTINE
cUP nE ~rr
vHtl ER PR I Nt.s RE cE: I vE:o . ,F<R otr.t tl.tti:tEv
H. OR !D A, FOH SAR 10:~ GARABtf
TA
~;;oe.:HM~AL I A~1, THEIJJ~. ."..........
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-RE S,l.B r~CE L JSIED AS:

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60.! ,13, \vHO MAY BE !DENT to -SliB.:JECI
. lif.:GAt I VF: a BUREAU U~;A~L S '10
lOCAtE N\ltll'l CA'f...10 10'. OF' ' PR tOR

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Vl CZ CHQO 2!75
HQ
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TO FBI HMH ( 1961056) ROUTINE
BT
UNCLA S
SAHJUS GARABET SOGHA:MLIAN,
FUGITIVE,
FB\IJ; i"'F';
ITS .~"
'.
CSOGHANAL 1.1\'\l ~lAY BE IDEt,!T \viTH FBI NUilBER 954 603 J3f
CURREf\l"f F'INGERPR IiHS RECEIVED
FR0:'1 UN1TED STATES: '
mP,i1I, FLORID A, F'OR SARKIS GAR ABET

~%988-004,
ARRESTED 823-81,
RESIDENCE LISTED AS: 307
1iJAIL FRAUD.
00 DISPOSil'JON 111
NORTH HIBISCUS DRIVE,
MIAMI BEACH, FLORIDA. THIS PERSON IDE~H WITH FBI

954 6,13 J3, I:JHO MAY BE IDErtl
10 SU8.JE CT
ilf:GATIVE. BUREAU UNABLE TO LOCATE NOTIF'ICATION.OF PRIOR
AP ffi 2: HE fJS ION.

LOCATED.
HA ''JDLF M!D SUTEL IF' Stf8J E CT IDENTICAL
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U.S. Departme.f Justice
United States Attorney

Southern District ofFlorida
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/$J South Miami Artnut, Suitt 700
Miami. Fk>rlda '3_3130
October 6-, _1_981
L...-..,.--=...-----=-____JI.E_squ ire
One .Bi_scayne T_owe_r
2_5th :t1_oox::
Mi_a mi, Flo~i_d_a
RE:
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ttn_ited States v. Saz::~is G. Soghana_1 ian

Case No. 81-340-Cr-JE
Dea~~...-_ _ _ ___.1'
Pur:suant to th_e Standing bi_scovery Order ente_red in the
case of United. States v. SarkisS!. Soghana1ian, th.e. fol_1owing
adClit_iQn.al mate:z::i_a _l s are f_orwarded to you' as an en~l_osure to
thi_s Jett_e :r.
~he_se docwn~_nts
consists of:
_1 .
FBI _iP,~_ntif_icati_on .record regarding de_fe_ndant

Soghana_1_i_an.
2.
T_he _resu_l t_s of a Uni~e_d States Departme_nt

State _records search.
~3.
-United st_a tes nepartment of State certi_f_icat_i_on

i~o. 81/16946.
ot
l t _i _s ant_icipated t _h_a t additiqn_a 1 mater_ia1s wi_1_1 _b e

in th_e _f uture. ,t\.s t.bey become availa~1.e we wi1_1
fqrward th~m to you.
forth~e>ming
Ve_r y truly youx:s,

ATLEE W. WA!-iPLER, ii_I
UNI~ED ST_AT_ES ~T_TORNEX
~--
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Memorandum
:ro
)~ 1 ~ (i1(of\-IO){cj(IJ
"""'.>A
o~te lo/o/n
~.A~EO
ER!AlllE~
~~
l96A-1056
post Office Box 592418 AMF

Miami 'International Airport
Miami, Florida 33159
'October 9, .1981
Bureau of .Alcono:, ToJacco, & Firearms

Post Office ~ox 784
Washington, .D.c. 20044
De a~~------------~
.
Referenj: is ::de ~o a conversation between you
and .S.Pecial Agent _ o f the Miami Office of the
:Federal Bureau of nves gat on .on. October 9, -19Sl.
We reque$t that a certification of records review
be furnished for trial _purposes .reflecting ~eview of xecords
:for the .following 197 Browning I model HBM2 .50 caliber
machine guns, which were allegedly manufactured in the United
States during calendar year 1977; the serial numbers of
which are as foll.ows-:
' . L . . . - - - - 1_
______.
For your assistance, it is noted that Alcohol,

Tobacco and Firearms bas verbally aavised that a search of
these .serial numbers was negative for ca1endar year 1977,
and, in fact, for .-any year prior to 1.977.
An .additional certi-fication is also requested
reflecting review of records for Browning model ANM3 . 50
caliber machine guns bearing the following serial numbers:
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The above ANM3 ~-so caliber machine gun:s 'are

currently located .in a military warehouse in .Lisbon,
Portugal., ang are -'in salvagea -eondi t.ions. These
weapons bear an .identification.plate with the 'notation
. -"Springfield Armory -52":.
, '.
.,.
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The defendant in this matter is 'identified -as

Garabet Soghanalian, a white .male, born on.February 26,
1.929 or Februaey 26; 1928. Soghanal'ian used the following
business titles in connection with this matter:
~arkis
Brown~ng -Precision ~ool . Co.

United Trade lnternational, ~nc.
Air Trade (U'l'I) Ltd.
Air Trade ~imited
United Trade lnternational Air Cargo~imited
United Industries, Inc.
Should any questions arise concerning the above

.certlfi;::~:::. rlease contact Speci:~ Agenij
at .FTS ,
nnmberC==== ~.Please direc~ your .reply to Special
Agent
on at the fol~ow1~9 address:.
Federal Bureau of Xnvestigation

3801 Biscayne Boulevard
_,
Thank you for-your assistance.
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very truly yours,
O'OSEPUv. CORLESS
Special Agent in Charge
BY:
I_Supervisory Special Agent

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Memorandum
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DATE: October 7, 1981
DOCKh1' ROOM
FROll: AUSA_I_ _....__

SUilJEcr: REASSIGl~IENT OF CRUIINAL/ CIVIL.t!A'ITERS/CASES
The following
USA FILE Nlli'ffiEl
1)
cr1m~nal/c1vil
matters/cases are reassigned as follows:
81-0637
---
lm1LY ASSICllSD AUSA
CASE AGENT
NAME OF CASE/tlli'ITER
USA v. Arnold A. OPER, et al.cc: HHS
cc:
USA v. Sarkis Soghanalian
cc: Dept. of Coinmerce cc:
USA v~ Miguel Musibay
c~:
FBII
4) 7'7-1794
USA v. Kenneth Townsend
cc:
cc:
80-101-cr-SMA
S) 80-0346
81-367-cr-EPS
AT~
USA v. Leslie Zacharias
cc: FBII
cc:
6) 81-0SS'O
USA v. Bruce E. Griffin
cc: . IRSJ
cc:
7) 81-0236 .
USA v. Sarkis G.
Soghanalia~ o/~
cc:
2) 81-0726
81-2 /3-Cr-CA
3) 78-1245
.
77-So2-cr=mnr
81-34o-crJE
Lee;
cc:
8) .
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cc:
ATLEE W. WAMPLER, III
APPROVEt
.FRAUD &PUBLIC
CORROPTIO~
SECTIOK
OCT 101981
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ONffEDSTATES DEPARTMENT-OTIU5TiCE
FEDERAL BUREAU Of INVESTIOAnON
WASHINGTON, D.C. 20537
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951+ 60 3 J3
, is furnished FOR OFFICIAL USE ONLY. .
Information shown on this ldentiflcation Record represents data wrnished FBiliy Rngerprint contributo~>
WHERE DISPOSITJON IS NOT SHOWN OR FURTHER EXPLANATION OF CHARGE OR DISPOSITION IS
DESIRED, COMMUNICATE WITH AGENCY CONTRIBUTING THOSE FINGERPRINTS.
COHTJ:WTOI 01
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Police
Department
Vestal
New York
Sarkis G.
Soghanolian
#163
Sheriff ' s
Of fie~
Los Angeles
California
Sarkis G.
Soghanalian
USH W.aci FL
cember
o, 1966
Fugitive from
Justice
Federal warrant
United States
Marshal
111972194
Sarkis , Garabet
8-23-81
Soghanalian
cail fraud
06988 004 .
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10-6-81 82 JEM

FEDERAL !UREAU Of INVESTIGATION
IDENTIFICATION DIVIS ION
l BU
WASHINGTON, D. C. 20537
.,..

954 603 J3
.. _, i~ lumishecliOR OffiCIAl USE.oNl~~
Information shoW11 on this Identification Record represents dota furnished FBI by fingerprint contributors. WH~'
DISPOSITION IS NOT SHOWN OR FURTHER EXPLANATION 0 F CHARGE OR DISPOSITION IS ,DESIRED,
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CONTtliUTot 01
ftNOUitiHTS
u.o
AUUTtO Ot
NUMalt
CHAlet,
lKfMD
CCSI'OSITlOH
UAliTED DY BUREAU
Sari~ is barabet Soghanali
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(NAYBE IDEltr) F! W; I-1F; I'l SP ; Fug Index 1)9 $434
o.o. Hiami inf ec 8-18-~ ~
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10-6-81 82 JEM
-.;c~..~
FEOEIAL auaEAu of INVUTIGAnON

IOEHTIFICATIOH DIVIS ION
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BU
WASHIHGTOH, D. C. 20537
The foUowin" f84 record, NUM!fR

954 603 J3
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lnfotmotion shown on this ldntiflcotion Rt:eord rprs.nts data hlrnish.d FBI by fingerprint contributors. WHERE
DISPOSITION IS NOT. SHOWN OR FURTHER EXPLANATION OF CHARGE OR DISPOSITION IS DESIRED,
COMMUNICATE WITH AGENCY CONTRIBUTING THOSE FIHGERPRINTS.
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10-6-81 82 JEM
UNITED STATES DEPARTMENT OF
Jusna
PIDII.Al. IUitEAU Of INVESTIGATION

WASHINGTON. D.C. "20537
""""-----:---
95'4 603 J3 ~
, is fumishe~FOR QFFICIAL U.SE_ONLY. .
Information shown on this Identification Record represenh data fvrnished FBiliy flngrprint contribu~--..
DESIRED, COMMUNICATE WITH .AGENCY CONTRIBUTING THOSE FINGERPRINTS.
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Police .
Department
Vestal
New York
Sarkis o.
Soghanolian
#163
Sheriff's
Office
Los Angeles
California
Sarkis G.
Soghanalian
#1972194
cember FUgitive from

1966 Justice
o,
Federal warrant
United States
Marshal
USK Kiami FL
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IDENTIFICATION DIVISION
10-6-8182 JEM
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STATES DEPARTMENT
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FIDUAL tUREAU OF INVESTIGATION
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9 54 60 3 "j3 -. . ..: _~ Ia hamlsh-4:10R OffICtAl us,;0Nl~ ~
Information ahown on this ldentiAcotion Record repreMnts dota furnished FBI by fingerprint contributors. WH~
DISPOSITION IS NOT SHOWN OR FURTHER EXPLANATION OF CHARGE OR DISPOSITION IS .DESIRED,

COMMUNICATE WITH AGENCY CONTRIBUTINCl THOSE FINGERPRINTS. .
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UAUTED BY BUREAU
(HAYBE IpElri')
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arabet Soghana1
P;
Fug Index 19
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10-6-81 82 JEM
J:::;a CHCY.
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UNITED STATES DEPARTMENT OF JUmCE

PIDIIAL IUUAU OF INVESTIGAnON
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The following
record, NUMIER
954 G03 J3 .. ---"",Is fu,.;l;h'iaToRC)fi:.IOOUSEoN~
Information shown on this lct.ntiflcotlon Record represents data furnished fll by flngrprint contributors. WHERE
DISPDSITIDJIIS IIDT SH.DWJI DR FU~!~J.rEXPLAJIATIDII DF CHARGE DR DISPDSITIDII IS DESIRED,
ODMMUIIICATE WITH AGENCY CDIIT,....UTIJIG THDS! FIIIGERP RIJITS.
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Southern District ofFlorida
1$$ South Mi.qm/ Avmut, Suitt 700

Mi.qmJ, Florid JJJJO
October 28, 1981
~:-----=--=-------=,...--___j Esq.
One Biscayne Tower

25th Floor
Miami, Florida
j l'l(o-lO~* q\3"6
~
G.
So_ghanalian
RE: United States v~ Sarkis
Dear
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Enclosed pursuant to the Standing Discovery Order entered

in the above matter is a copy of a certi_fication dated October
16-, 1_981, obtained from the Headquarters of the Bureau of
Alcohol, Tobacco and Firearms, Washington, D.C.
very truly Y.
.A.'I'LEE W.
UNITED S
KWL:jml
Enclosure
cc:
""'
x AIRTEL
10/19/81
TO:
DIRECTOR, FBI
F.ROM:
LEGAT, ROME (196A-40) (RUC)
~ARKIS GARBET SOGHANALIAN - FUGITIVE

VrDBA UNXTED TRADE INTERNATIONAL, ETC
I VIC'l'IM
FBW; MF; ITSP

(00: MIAMI)
Re Bureau teletype dated 8/15/81.

view of subject's arrest in Switzerland and
that all logical investigation is completed at Legat :Rome
this matter .is being RUC by Lega~ Attache Rome.
~n
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4 - Bureau
~ Miami) (19GA-1056)
l - nome
LJF:bad
(5)
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10/19/81
TO:
DIRECTOR, FBI
-FROM:
'LEGA'l' I :ROME (196A-40)
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(RUC)
V SARKIS
GARBET SOGHANALIAN - FUGI'!IVE

IN'l'ERNATIONAL, ETC
VICTIM
FBW; loG'; J:TSP
( 00: 1-l.IAMI)
D}fA UNITED ~RADE
Re Bureau teletype dated 8/15/81.

In view of subject's arrest in switzerland and
that all logical investigation is completed at Legat Rome
this matter is being ~uc ~Y ~egal Attache Rome.
4 - Bureau
~- Miami) (196A-1056)
-1- Rome
LJF:bad
(5)
- '
------------------
TO: LEGAT:
Bea-n
Bogota
Bonn
Buenos Aires
Hong Kong
London
Manila
Mexieo City
Ottawa
PanaJ.a
Paris
Rome
B Tokyo
Retention
c:J For int'orm.ation CJ optiOl\3.1

Cl The enclosed is tor
Fer appropr:iate
CJ action
CJ Surep.
by------0 c~al all
you: information. U used in a future repoct.

sowces.
paraphrase contents.
Cl Enclosed ar_e corrected ~ges trom report ot SA - - - - - - - - - - - - - -
dated
Remorks:
-------------------
~dosed ~)!:.;
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1:?oM.~
10-/l(-P',.
SEARC'.R
S.ERIALJ7
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.10/21/81
LEGA'l' I 'BERN (196A-121) (P)
SARKIS GABABE'r SOGUANALXAN -
PUGI'l'IVB, dba
I ~~~~tiona1,
e.tc.,
;itl
(00:
TO:
Miami)
DIRECTOR, FBI
ReBERcab, 8/14/81.
'FBIHQ and Miami are .asked to respond to request
.contained in reBBRcab, so that this inatter can be brought to
a logical conclusion at Bern.
4- Bureau
{(2)7- Miami)
:1 - Be-rn
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(5)
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10/21/81
LEGAT, BERN (l96A-121)
(P)
. .~ARKIS GARABE'r SOGHANALIAN - '
mr.c1, Internationa1..'
~UGI'l'IVB,
n,.c+:all
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EBW; ltF; ITSP
( 00:
'!'0:
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etc. 1
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DIRECTOR, FBI
.ReBERcab,
8/14/81.
m .
FBIBQ and Miami are asked to respond to request

contained .in reBERcab, so .that this matter can be .brought to
a logical conclusion at Bern.
.,
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'11/16/81
TOt
DIRECTOR, FBI (A'l"l'N: WHI'l'E COLLAR. CRIME SECTIOU)
PROM:
SAC, MIAMI .(l96A-10S6) (P)
SUBJECTs
AARKIS GARABET SOGHANALIAN, DBA
v'::x~:;TRADE ~~RNATIONAL,
BWr
'
X~CTIM
E'l'C7
(00: MIAMI)
cable
to
Re Legat, Bern airte1

Bureau, 8/14/81.
to
Bureau, 10/21/81, and Bern
Flr .information of .Leqat, Bern, Miami

indices are
Iat Btater (SIC).
negative .re _
The Bureau is .requested to forward this airtel to
Legat, Bern along with the results of Bureau indices check

.rej
I.Per previous request of .Legat in re Bern cable
.Bern)
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yo: LEGAT.:
Bern
Bogota
'
Bonn
Hong Kong
LondOll
Manila
Mexico City
Ottawa
Pana=.a City
Paris
r=:JRome
CJTokyo
11/17/81
(Date)
_
_Retention
_ F 8.PP1'9PI'iate _
C) For in(ormation 0 optional
C)&:Jioo .
c:J Surep. by __~-----The enclo-sed is tor -your information.: U us~ i.n a future repoz:t.
c~_al all
sources. C) paraphra-se contents.
-C l Enclose3
ere CTe-cted pages from re:Pol":t of SA - - - - - : ; . . . _ - - - - - - - - - :
dated -
_ -
Re-morlcs:
t:J
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Call.:
NOV 1 9 i981
E-nc.
Butile
,Urtile_
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UNCLASSIFIED
LIMITED OFFICIAL USE

PAGE 01
ACT-ION .AF-10
NOUAKC
05404
OCT-f31
~DS-00
L-03
INFO
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.JUS129
101014Z
~U~E-00
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--------~-----~--001517
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Fl'f7ANEMBASSY NOUAKCHOTT
TO SECSTATE WASHDC 0578
LIM-ITED OFFICIAL USE NOUAKCHOT,T 05404

FROM- THE CHARGE
E.O.-:- 12065: N/A

CFEDt OTRAr PGOV, NRr US
. SUBdECT: -FBI ,.INVESTIGATION
~AGS:
REF:~
P~EASE
STATE 259566
r:~ ~:~c~:~
INFORM
1 I WOUL.:D BE
lAND
DEPARTMENT
O~USTICE
REP _ I T H::rT
AT
HAPp.Y
TO
TEST.IFY AS PER' F T CONVERSATIONS .IN:CASE
AGAINST SOGHANALIAN FOR ARMS'FRAUD. REFTELSAIDTRIAL
WOU~D .BE IN DECEMBER OR ~ANUARY. ;PLEASE NOTE THAT E:CON/
COMMERCIAL. OFFICER WILL BE ON LEAVE EARLY DECEMBER

.
THROUGH EARLY JANUARY 'AND SINCE .WE ARE STILL WITHOUT AN
AMBASSADOR, IT WOULD BE EXTREMELY .DIFFICUlT FOR-ME TO
TRAVEL DURING 'THAT TIME PERIOD. JANUARY WOULD BE
PREFERABLE, -IF IT COULD BE SO ARRANGED.
SCHRAGER
.
.LIMIT~D OFFICIAL USE

P,
o. sox ze.i&
~601 (A$Y OAIIlANO l"AFII( $0U~(VAf!lO
FORT LAUJ?l!:RD.ALI!!, l"LORIX>A 30010
u;U:PHONt (JOSl 563-,fS-&1
'December 1, "1981
-T.he Honorable Charles H. 'snowden
2000 s._ Dixie_ Highway, Suite 212
Miami, .Florida_
zm:
Boca xnvestaients, L_imited v. Sarkis G.

Soghanalian,. et_ al, Case No. 7$-14372 (CA:-08)
Dear -SI>ecia1 Master L-~---....1
l: wr_ite to you informally conce_rning continued pro-secution of the_ abovereferenced matt_e_r, wherein. you were_ appointed Special 'aster by the
Hon_orable Franc'is X. Knuck, by Order e:ntered May 4, 1981~ 7 copy of which is:
attached for ready reference. 'I believe it_ ..rould be productive for both
the Court_ and the litigant_s t:o meet_ in for_mal Pre-Trial Conference during
the earliest part: of January, at which time all procedural matters can be
iaentified and accomplish~(! through appro-pt:_iate order of Court.
'
If you w~ll_ be kind en_ough to tele-phone me <;ol_lect at t_he below reflected

number, advising on ea-rliest convenient calendar date in January, I will_
'then_ prepare and submit_ an Order setting date_ (or same.
By copy of .this letter, I am advising op-posing counseL
.'Iharik you for your c:onsideration_ in this matter.
Since_rely your's,
ANDREWS & LUBBERS, P.A.

Attorneys for Boca Investments, .Ltd.
2601 E . Oakland Park_ Blvd.
Fort Lauderdale, FL
33306
(305) 563_-2541
111
cc:
I;
Esq.
(Cer_tlf_led Mail -- Return Receipt)
One Biscayne Tower, 25th Floor
Miami;_.FL 33'13_1
b6
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i!)
..;:...
Memorandum .
b3
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te~e~.t.lJ ~~
~~
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l'fG> A r(O~ -(9.3/

'J.::?-:tO-I~xtD,---+
tRIAUZE,~UI)~~
DEC 2 !3 1981
AIRT&r. (t11'1) LlMifBD
PAU1fi!D~s. 1
XICOSIA, CYPRUS (L!RIIC.&. ..&.mPOR!)
,.
AIR WAYBILL NUM&ER
B~ Pof- .. 2 6 9 6
li.711 U.!.
-AIR WAYBILL -
Gou WEIGICT
, IIIAUSAIIO
UECIPr
IIUIIIEIS
Caiasea
boia,cha
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-Poicla leta14kc
" Bruta24kc
-Dimens 458x25
5.000 emus .lJx HOR'l'Im 4e

hauteaent exploaiw
c/ESPL PERC
DS'f .lZDM
111 .&2 (D)
MOft 8laa
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s sa r ...................... l
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us.
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al-
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... lmlt ~otala o.oo~
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~
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OOTHIII
SKIH'llt'S OICUitEO VALUE

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fOil
($po<ifJ
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$445.000.00
~i.?o71s:7ilfl b:i:
~ o~~LISBOlifPORTUQJ.L
1. TO
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otopplAC p i - are
placet
places of deportvre an4

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SHIPPERS C. 0. D. IN WORDS
"Fret~
TOTALS~
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ON THl itf:Yllt$l HlMOf, ,
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INVESTMENtS L"rD
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NAME Of SHiffllt:BOCA
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".Fr.pt. r~ye"
ea,.er certfte~ aboYo-descriMd

wore receied for cemace sutJtCT TO THl
CONOITION$ ON THl ltf:V1t$l Hl Of, lilt 100<11 tile.- ...,, it1 opparent COO<! orGer
H tOftdtbOA eatt' pt al AOtef reoa.
~
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ao4 ACreHit tht CONOIT
ty IROII11/ AGtNT
-R.BJ
s. . . W\ ;.I
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ITEM NUMIIII
CMAACUkl TO $0.F
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) . TO
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NO.4- DELIVERY RECEIPT
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'
'Memorandum ..

FOIPA
Total
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Deleted Page(s)- 53
6 - Duplicate
1 6 - Duplicate
17 - Duplicate
2 5 - Referral/Consult
27 - Duplicate
2 8 ~ Duplicate
34 ~ Duplicate
3 6 ~ Duplicate
52 ~ Duplicate
57~ Referral/Consult
116 ~Duplicate
117 ~Duplicate
159- Duplicate
160- Duplicate
210 ~ b5
211 ~ b5
2 2 3 - Referral/Consult
224- Duplicate
2 2 5 ~ Referral/Consult
2 56 - Referral/Direct
2 57 - Referral/Direct
2 58 ~ Referral/Direct
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331 -Duplicate
332- Duplicate
333- Duplicate
3 34 - Duplicate
34 7 - Duplicate
l..AW OFFICES
NoRMAN MALINSKI
SUIT~ 900 CITV NATIONAL SANK SUILOING
Z5 W&:ST H.AGI._t~ STRt-CT-
MIAMI, Fl..ORIDA 33130
January 5, 1982
Federal Bureau of Investigation

Attention:
~Re:
Special
Agent~~--------~
J._F.c. Enterprises Inc. et al . , v. Pan Aviation .Inc.
Case No. 81-19000 .(30)
b6
b7C
Dear Mr.~l_ __.

Thank you for discussing the matter of Sarkis Soghanalian
.with me the other day.
At your request I am enclosing. a copy of the Complaint which
I have f i 1e d on be ha 1 f o f my c 1 i en t s a ga i ns t Mr . So ghana 1 i an ,
his associate and his aviation company.
I Mould appreciate your advising me of.anymatters that come
to your attention which may be of assistance in my, representa:t ion of J . F.. C. Corpora t i on .
,1hank you.
Norman Malinski
NM:ss
enclosure
JAN .6 iM2
IN THE CIRCOIT COORT OF THE

11TH JODICIAL CIRCUIT IN AND
FOR DADE COONTY, FLORIDA
GENERAL J.O.RISDICTION DIVISION
CASE NO.:
J. F. C. ENTERPRISES, INC.,
a Florida corporation, d/b/a
CONCORD INTERNATIONAL
:
AIRLINES, JOSEPH F. CI AVARDON'E,
WILLIAM R. WEBSTER, DOROTHY
_WEBSTER, ERICH H. ADAMS,
PATRICIA B. ADAMS, ANTHONY
CISERANO, DONALD W. GROSS,
ROBERT A. DYKE, WALTER E.
SHINN, CHARLES ARRINGTON,
HELEN ARRINGTON, and ANTHON'Y
TORO,
.
81-190QO
COMPLAINT
Plaintiffs,
vs.
PAN AVIATION, INC., a Delaware
corporation, SARKIS
SOGHANALIAN, and RAYMdNO
GARAVITO,
Defendants.
The Plaintiffs, J.F.C. ENTERPRISES, INC., a Florida

corporation, d/b/a CONCORD INTERNATIONAL -A.IRLINES {hereinafter,
"J.F.C."), and, JOSEPH F. CIAVARDOKE, WILLIAM R. WEBSTER,
DOROTH'Y W'EBST-ER, ERICH H.. ADAMS, PATRICIA ~- ADAMS, ANTI-ION.Y
CISERANO, DONALD
.w.
GROSS,
ROB~RLA.
DYKE, WALTER E. SI-IINN-,
CI-IARLES ARRINGTON, l-IE LEN ARRINGTON, and ANTI-ION'Y TORO (he rei na fter,
"STOCKHOLDERS"), sue the Defendants, PAN AVIATION, INC. (hereinafter "PAN"), a
(hereinafter~
"GARAVITO"),
Delaw~re
corporation, SARKIS SOGHANALIAN
"SOGI-IANALIAN"), and RAYMOND GARAVITO {hereinafter,

a~d
allege the foll6wing:

JO'RI SDI CT ION
..
1.
This is an actiori for damages in excess of Five
Thousand ($5,000.00)
~ollars,
for an accoanting and for
equitable relief.
I.AW OFFICES OF' NORMAN MALINSKI. 900 CITY NATIONAL BANK BUit.DING, MIAMI, FLORIDA 33130
C301n 3~8l~IIJ

2.
At- all times mater_ial hereto, Plaintiff J._F.C. was
and is a Florida corporation, having its principal place of

b~siness
3.
in
Dadi_Cou~ty,
Fl4rida!
STOCKHOLDERS were and are at all times material
hereto shareholders of Plaintiff J.F.C., having an identifiable

share in the aisets of
4.
J.F.C~
Defendant PAN was and is at all times material
hereto a Delaware corporation authorized to do and _doing

business iri
5.
p~de
County, Florida.
Def~~da~t SOG~ANA~IAN is a resident of Da~e Co~nty,
Florida.
6.
At
al~
times
m~terial
hereto, Defendants
SOG~ANALIAN
and GARAVITO were and are doing business in Dade County,

Florida.
7.
All of the
Dade County,
event~
occ~rred
in
-Florida~
._
8.
described herein
FACTS
JF.C. is an international certified air carrier
operating pursuant to the Federal Avi ati on Act. under authority

of a Certificate of Convenience and Necessity issued by the
Ci~il
Aeronauiics Board.
9.
Plaintiff J.F.C. was in the business of aircraft
leasing and. of .providing both passenger and cargo air serviceson a charter basis to various points nationally and internationally.
10.
J.F.C.'s substantial assets at the time of the
events described below comprised of its aircraft fleet,

consisting of three (3) DC-8 all-cargo aircraft and one (1)
DC-8 passenger confi g~red aircraft. gro~nd s~pport equipment.
its cargo shipping contracts and aircraft leasing agreements.
..
11.
During-1980, J.F.C.'s Jncome was substantially
derived from an aircraft 1 eas-e ag-reement (hereinafter. "the

Ongoing Lease") between Plaintiff J.F.C. and Compagnie
Nationale Air France (hereinafter, "Air France"), and a
-2LAW O,;PICES 01" NORMAN MALINSKI, 900 CITY NATIONAL BANK BUILDING, MIAMI, FLORIDA 33130
C30!$) 3!!J8-IISIIS
.Do~glass
DC-8-33 ill-cargo aircraft FAA Reg. No. N-82430
(her,inafter,
~the
Airplane~)
which Plaintiff J.F.C. made
available for lea_~e_ for .freight shi.pment.
12.
The Airplane was being acquired under a conditional
sales agreement pursuant to which Plaintiff J.F.C. had sub-sta-ntially perform.~d its payment obligations.
13.
Plaintiff CIAVARDONE was president of J.F.C. and,
during mid-1980,csought .to locate additional capitalization

for it.
14.
In June, 1980, Pl a_i nti ff CIAVARDONE met Defendant
GARAVITO who
rep~esented
to him
tha~
he was in contact with
a prospective purchaser of the outstanding stock of J.F.C.,

_thereby introducing Pl a i nti'ff CIAVARDONE to Defenda.nt SOGfiANAL IAN
.who held.himself out to Plaintiff CIAVAROONE as the owner,
agent, and chief operating officer of Defendant PAN, a
prospective purchaser of the outstanding stock of J.F.C.
15.
met with
occasions
During June and

Defend~nts
~980,
Pl~intiff
SOGfiANALIAN and GARAVITO on
concernin~
stock o.f J.F.c.
J~ly,
CIAVARDONE
sev~ral
PAN's acquisition of the outstanding
During said meetings,
D~fe.ndant
GARAVITO
acted in conce~t with and assisted D~fendant SOGAANA~IAN in

obtaining relevant financial and other information concerning
J.F.C.
16.
In July, 1980, Plaintiff CIAVARDON.E and Defendants
SOGAANALIAN and PAN entered into an agreement (hereinafter

"the Agreement") for, among other things, the parchase and
sale of all outstanding stock-of Plaintiff
Agreement is evidenced
i~
par~
J.F~C.
The
by that certain Parchase
Agreement dated July 18, 1980, and attached hereto as Exhibit

"A", and by that certai.n Ag-reement to Sell Stock and Appoi ntme.nt
of Escrowee to Transfer Stock dated July 21, 1980, and
attjched hereto as Exhibit "B".
-3-
LAW OP'F'ICI!:S OF' NORMAN MAI.INSKI, 900 CITY NATIONAl. BANK BUII.OING. MIAMI. F'LORIOA 33130
t30!U 3!1811515
...
Ond~r );he abovedescribed Ag'reements, the recovery.
17.
rei~statem~rit and .r.efu'rbtshment of the .A1 rpla11e was an
afffr.mati ve cgv~r,aa_nt .and duty of __ Defendant PAN.

In ~~1~, 19~0. and following the formation of the
18.
aboved~scrib~d-~greement,
~
..... -
'
D.f.ndant~
.... ..
SOG~ANALIAK
~
ahd GARAVIT9,
'
i ndi vi dually ~n~_ as ag~nts or employees of Defendant PAN and
on ttiei.r own fe~-pecti ve beha l fs, represented to .Plaintiff

C!AVA~DON'E that;
in vi ~w of the forthco mi ng closing upon ~he
_outsta.n ding s.tock of J.F.C!-- ~t would be in the best interests

of the Pl ai nti ff,s for Defendants SOGHANALIAN and GARAVITO to
ass~me f~li control and direction of t~e o~eration and
nia~agement of Plainti.ff J.F. C.
and that the a'ffairs of
J-. F. c. would-.~~- conducted with. :full and due care for the
'interes~s ~(ilJ
19~
of the Plaintiffs~
I~ J41y~
198Q, and in reliance ~~ori the representations
referred to in -pa ra_graph 13 hereinabove, Pl ai nti ff c IAVAROON'E

'
c~ased
acting as
J.F.C.,
Pr:-_esiden~
~~ased ac~e~ting
t~rn~d ove~ con~rol
of
~nd
any
~he
Chief Operating Officer of
f~rther com~ensation,
and
mariagement and Qperation of
J.F.C . to Defen_dants SOGHANALIAN and GAR~yiTO, acting for

themsei.ves and" on beha 1 f of Defendant
.
.. PAN.
'
20.
De.f~_nd~nts
S_OG~ANAL
IAN and GARAV ITO assumed. control
of 'Plaintiff J.F.C. and exercised ~nrestricted a~thori.ty and

discretion in
~onnection.with
its operations.
21. In Oc~ober, 19~0~ the term of the Ongoing Leas~

above-descri~ed w~s
nearing expiration and was up for ann~al
renewal~
Th~
age~t
repreie~ted
and
clos_e upon
Deferi~ant SOG~ANALI~N ~et
..
and acq~~re
~o
him that Defendant fAN
~as
aboUt to
the . outstar_ldiog stock of J.'F.C., that
J.F.c. would not be able to

'
with the Lessees
contin~e
Air France, and that Air France
to provide
~hould
se~Vices
renew the Ongoing
Lease with Defendant PAN and not with J.F.C.

22.
~~bseijuent
to the
~oregoing
~epresentatio~s
of
Defendant SOGHANALIAK, a lease agreement was entered into
-4-
to
~-.,
'
..
-.
betweeri
Ai~
France and
Defenda~t
.PAN, effective
1980 ~(liereil)aft_er,; "the Rene-wed L~ase").
Novemb~r 1~
Plaintiffs were
not advised
that
the Renewed
Lease
had been drawn in the'
..
7
~~d
name of Defendant 'AN
Defendants led. Plainti.ffs
~o
believe t.hat said lease ha<J been renewed with Plaintif-f

J.F.C.
On or- ab_out october-~ -1980, subsequent to the
23.
execution of the Renewed Lease, Defendants SOGtiANAL_IAN. and

t~e
GARAVITO leafned that
Airplane bad become inoperible by_
reason of damage to it;s fariding gear and relat_ed apparatus.

De!e~dants
24.
knew or
~pon
the:exerci1se of-reasonable
care W<?uld have I(J)Own that J.F.C. had expended approximately

.
~~ven tiundred SeventY-N.i ne Thousand ($779 ,ooo. o_o) Do~ 1 ars
pursuant to the conditional sales contract under wh.ich the

Airplane was J:>:eing purchased ,a,nd' tha~ the additional sum
approxi~at~ly
<?f
Three Hundred Tbouiand
($300,000~00)
~ollars
was
due United- Air Leasing before
title to t_he Airplane
.
,.
('
would vest in Plaintiff J.F.C.

25.- Defendants SOGHANALI~N and'-~ARA9IJ0 ~ep~esented to
repairin~
the Plaintiff that the cos;of
~he
a~rpl~ne's
damages
as a foredescri
bed would 'be appro
-- '
.xi rna tely Two Hundred
~
Fifty Thousand. ( $250,000.00) Dollars when Defendants knew.

or should have --known and, upon the ex_erci se of due care,
would .have
to the a i
k~own
rp~ a_~i
that the actual
repai~
cost~
was in fact not greater_ t~an
for the damages

S~venty
Thousand
($7o,ooo.oo)
Dollars-.
'
.
~-
Defendant~
26.
repair the
A1r~1ane
failed to take steps ~o cause JLF~c. to

and, further,.failed to cause J.F.C. to
!'lla!<~ payme~t~ due United .Air Leasing -.for the Airplane, and
fail~re
..
of which resulted in repossession of the
27.
in such a
Airplane~
Defendants further- conducted the bus i ness of' J. F: c._

man~er
as to dissipate its
~ssets
an~
incur substantial
further liabilftie_s~ thereby totally destro.>'ing_the value of J.F.c.
":"5-
~W OF'~ICES
OF NORMAN M_A LI.NSKio
9~
CITY,NATIONA': BAN.<
BUII.OINO~ MIAMI~
FLORIOA 33130
<30~) 3:5SI:5t!J
...
...
.
28.
d~vesting
After
J_.F.C. of :Its equJty and assets,
the Oefend.nt:~~N rep~diat~d its obligat~on~ to p~rcha~e t~e

Plaintiff J.F . C.'s . stock,_and refused to compensate the.
Plaj~tiffs
fo~_the
looting 6f J.F.C.
29. Oefe_ndant .PAN was so organized~- opera ted, owned

and controll~d 'by Defend~nt SOGH!\NALIAN as to be the .mere
agency~
alt~r
adjunct:,
ego and _instrumentalitY
~f
Defendant
SOGHANALIAN, who ~~ploy~d ~efend~nf PAN as a veil and e~ploited

the corporate identity of Defendant PA_N for the purpose of
defrauding Plaintiffs herein. and
forth~
u_njus~
purposes of'
1 o <;> t i ng and wa s t i n g. of the as s e t s a n'd good w i 11 of J F C

he~ein.
and .Plainti.ffs.
30 ~
De fe11,dan t GAR_AV I TO C()nsp ired and acted in concert
with Defe.ndant SOGHANALIAN in fu-rtherance o:f the acts

complained of herein and, iD
additi~n.
Defendant GARAVITO
was th_e agent, instrumenta-lity and/or employee of 'DefEmd_ants

SOG~ANALIAN
and
~AN.
31.. . Defendants SOGHANALIAN and GARAVITO ~ere employees

and agents of Defendant .~AN ~nd, at all times material hereto.
~
were. acting w_i t!ii n .the course , __ scope and purpose of .their
e~ployment
and agency.
COO'N'T I
BREAC.H OF CONTRACT.
32.
The Pla,intiffs reallege and reaver:- each and
~very
allegation set forth above as though :fully set forth herein.

33.
Plaintiffs and Defendant PAN AVIATION INC. entered
'irito the Agreenierit pursuant to which Pla:intiffs agre_ed to

sell' and Oefenda!lts
agree~
to purchase the stock of J.F.C.
The !\greel)lent is ev'idenced in part by
~he
writings attactled
her:-eto as Exhi b~ t ~A." and- "B'~ .respectively.

34.
. The p~rchase price for the stock was agr-~edupon
as iwo .Hundr-ed Fifty Th!lusand ($250,0QO~OO) Dollars as

described 1 n
~aragraph
3 of Exhi ~it ''A" hereto. wh.i ch sum. was
-6LAW Of'FICES OF
NO~MAN MAI.INSKI. 900 CITY NATIONAl.
BANK BU}&.DING; MIAMI. F&.O_RIDA 33130
(30ll') 311815l5
di v1 d~d among the sharehol'ders

riumbef of
35.
cl~~~ "A~
Und~r
sha~e~
n direct proport1 on
owned bY
e~ch
6f
~o .
the
theM~
the terms of the .Ag'reeinent~- Defend~nts PAN
and SOGHANAI. ~A_N agree~ to pay, 1 n addition to-,. the purchase

price for the s _tock, suffi
c~ent
.monies to ena.bl e the reco-very
arid reins~at~m~n~ of the Air~tane and, i~ addition, to

disch~~ge
or cause the discharge of the ongofng
obligations
36.
du~
United Air
Leas~ng
payme~t
for the Airplane.
All condq:1ons precedent to . ~efendants' duty of
performance under the Agreerri~!'lt- .w ere performed, sat1 sf1 ed ~

or were excused.
3}.
of
Pl a 1nt1 ffs tendered stock ~o Defendants and demanded
Defendant~
perf~~~'~
that they
accordance with- the terms
A~~eemint.
of the
3B.
Def~ndants . breac~ed
refusing to
p~r~hjse
the
~tock
the A~reement by failing and

in the
~~nner
as aforedeseribed
..a~d, fur.ther, b~ failing and refu_sing to -discharge the

payme~t ob11~at1ons of J.F.C. - ~o united Air Leasin~!
39.
~o ~arket for
t~~ stock of J.F.C.
existed aftef
the breach compl a 1 ned of herein and, further, no market for

said stock .has arisen f.rorri the date of breach to t _he present.
40.
a :direct
As
and proxim!lte result of Defendants'
breaches as aforedeseribed, Plaintiffs have
sa~fered
the
loss of the consideration due for tt)e purchase of the s tock,

arid as a further consequence, the 1 oss of Pl ai nti ff s
~n and the value of the Air~lane,
~qu i
ty
and other pfeyfously
described assets of J.F.C. which have been: dissipated or

destroyed by the Defendants.
WHEREFORE, the Pl ai_nt1 ffs .herei ~ pray the Court grant
the
followin~
A.
relief:
Award to Plainti_.f f J.F.C. damages against Defendants,
jointly and
B.
sev~rally;
a!'ld ..
'
_Award to Pl a i nti .ff STOCKtiOLDE.RS damages against
Defendants,- jointly and severally, 1 n the amount of Two
-t
LAW
OFf'~C$
OP' NORMAN MAL.IN$KI, 900 CITY ,NATIONAl. BANK
~U~LD_ING, , MIAMI~
FLORIDA 33130
..
(~250,000.00)
HJI'ndred Fifty Thousand
Dollars, said amount to
.be apportioned . arriong the i ndi.vi dual Plai ~ti fts/Stockhol ders
nL!mb~r
in direct _proportion to the

the~;
by each of
C.
and
aga~nst
Awrd_to Plaintiffs
in~~rest,
prejudgmel'}t
D.
Def~ndants
and attorneys' fees
with the prosecution of
of Class "A" shares owned
th~s
action;
costs~
e~pended
in
connec~ion
~nd
Grant -such ottaer :and further relief as this Court
may deem jt(st and proper.
CQU'N'T II
FRAUD
P1aintiffs reallege and reaver each~and every
41.
allegation set for~h _in paragraphs l.. tllrough 40 as though

he~ei~~
fully st forth
Defendants SOGHANA.LIAN and GARAV.I"TO participated
42.
in, aided, -abetted, conspired, approved, and eit~er knew or

had reasonable
,..
' .
~
g~ounds
.
to know
of
the facts as
...
.
, ,
~ereinabove
and hereinbelow mentione4.

Defenda~ts kno~ingly and wi~lfully empJoyed devices,
43.
s~hemes
and artifices to defraud; ma_de untr:ue, decepti ~e and
misleading-statements of .material facts, and engage~ in

- ~~ts,
pract~ces
and ~oafses of busines~ which operaied as a
; .
fraud ar}d .dece1t upon Plaintiffs, said- acts being done with
a reckless disregard for the property rights of
.44.
The devices,
s~hemes
flaintiffs~
al'ld artifices to defraud, the
deceptive and .miS 1 eadi n~ sta tements of .materia 1 facts, and

the acts,
l?~~c1;ices
and courses of busi{l_ess whjch
oper~ted
--
as a fraud and deceit upo. n Plaintiff

included,
inte~ alia:
.,
..
~..
A.
.
The inducing of Plaintiffs to
ente~
in~o
the
Agreement aforedescribed. as .evidenced in part by Exhibits
"A" arid "B";
B:
~nd
_-The .. mak i n_g and repeating of the rep~e_senta ti on
that Defendant
PAN,.
and Defendant SOGHANALIAN, by vir-tue of
.
,..
.-
-8-:
LAW'OFf"ICES OJ'_.,NORMAN MALINSKI, QOO CITY NAYIONAl. BANK BUil.DING. 'MIAMI. FLORIDA 33130
(30ll'J 3!J8IIII!J
J'!is
owner~hip,
control and capitalization of Defendant PAN
and personal worth and
resotJ'rc~s,
were ready, wi )1 i
~g
and
able to P.Utchase the outstanding s.:t:ock of Plaint~ ff STOCK'JJOLDERS

herein;
C.
Th~
.making_ and
repea~ing
of the representation
that Defen~ant PAN and Defendant SOG~AN~l~A~. by Virtue of

his ownership, control and capi tali zatfon of Defendant .PAN
a_nd
per~ona~
worth. and resotJ'rces, were ready, willing 'and
able fo discharge ~he outstanding and CQntinuing payments

.due Onited Air Leasjng for the Atrpla~e;
~;
The
ther~fore,
and
SOG.~ANAli.AN
that Defendants
~a~a~eri~l,
~aking
~i~ectoral
rep~ating
of the
represe~tation
and GARA.YITO possessed
su'per~or
and operational sk11ls and should,
prior to closing u'pon t'he purchase of the
ou'tst~nding
stock, assume management, operation and control- of Plaintiff

j~F.c . ;
and the-~reation .of a reta~ionsh1p of ~~ust and
conf{dence wJth Pla1n,tiffs by reason of such represen~ations;

The_~aking
E.
and repeating of the
re~res~~tation
that .~efend_ant~ SOGHANAL IAN and GARAY I TO would, upon the

assumption of management, operation nd control of J.F.C.,
. protect
.
and enhance its assets, goodwjll and business opportu'nities,

-
discharge
~he
1nd~btedness
ind close
~pon.
the purchase of the outstanding
f.
The
on the .Air:plane as aforedescribed,

stock-o~
J F. C. ;.
ma~irig
that the landing gear and

~as
and repeating of
re1at~d
th~ ~epresentation
apparatus of the Airplane
damaged so extensively as to r~~u1re repairs in the
a!l'lount of TWC? Hundred Fifty Thousand ($250, 000.00) Doll_ars

_wh~!l.
Q~f~~dan~~, -~_!ld
of reasonable
~a~e
~~~J~
of them k'n,ew, or t!l the ex_erci s~
should have
kn~wn~
that the damage could
.~be repaired for- the sum not great_er than. SeventY T'housand
Dollars;
G.
The wasting and diverting of J .F.c.:os corporate
assets by. inter
~.
permitting the repossession of the
'Airplane; and
-9-
,I
..
-~
The 1 ooti ng and (.rst:r'rpi ng by Defendants of
H.
Plaintiff J.F.C.'s assets and business opportanities by,

representing to it;;s L,essee Air France, that
inter~.
Defendants were acquiring the outstanding stock of J.F.C.,

that it was in all parties' best interests for Air France to
renew said lease with Defendant PAN and not With Plaintiff
J.F.C., and,
f~rther.
the actual inducing of Air
Fran~e
to
renew its leasewith Defendant PAN.

45.
The devices, schemes. acts, practices and statements
of material facts as aforedescribed were deceptive, and

misleading
a~d
part of a deliberate scheme and
between Defendants to loot J.F.C. and

and business
opport~:~nities
opportuni ty to benef1 t
46.
t~
con~piracy
usurp its assets
and, in particular. to usurp its
under the Renewed Lease.
Plaintiffs are ancertain of the benefits under the
.Renewed Lease .which benefits. have been obtai ned a.nd diverted
b~
Defendants and believe and therefor allege that Defendants

seq~ester
have and will continue to transfer and

47.
such proceeds.
Plaintiffs relied upon and were deceived by the
aforesaid representations. devices, schemes and artifices to

defraud,
r~linquished
management and control of J.F.C. to
the Defendants, and did not
~iscover,
and could not have
discovered by. the exercise of. reasonable di 1 i gence, t,e, true

facts which were wrongfully misrepresented, concealed and
omitted
the
a~til
Renewed
48.
long after
th~
Airplane was repossessed and
Lease was executed.
As a direct and proximate result of the
Plaintiffs suffered
~he
foregoi~g.
loss of the Airplane, the loss of
t-he benefits of the Renewed Lease, and the destruction of

Plaintiff J.F.C. as an ongoing
'
""'
busines~
operation, all of
wh 1-ch. as a further di rec.t consequence. re.ndered a.nd continues

to render Plaintiff's stock
unm~~ketable
and without value.
WHEREFORE, the Plaint-iffs herein pray the Court grant

the following relief:
-10-
LAW OFFICES OF NORMAN MALINSKI. 900 CITY NATIONAL BANI( BUILDING. MIAMI. FLORIDA 33130
(30!:1) 3!:18.1518

A.
Award_ to Plaintiffs compensatory damages against
Defendants, joiritly and severalty.

Awar~
B.
to
Pla~ntiffs-ag~i.nst
.and severa Jly,- suppJ ementary damages

~otal
damages
v.a 1 ent to triple the
1n-th1s action; and
~rid seve~ilty,
Aw~rd
D.
and
e~ui
Award to the Plaintiffs against the Detendants~
C.
jointly
fec~verable
Defendants, jointly
sever~lly!
reasona_bl e
to
Plaintiff~
pr~j~dgment
at~orneys'
_;-
p~~itive dama~es~
against Djfendants, jointlY
fnterest, Plaintiffs' costs and
fees; and
Ordii an Accounting to determin~ the amoant and
E.
1 oca ti on of the b~nefi ts which ~ nn~red to Defend.ants to the

det'riment of the .Plaintiffs under the Renewed Lease; and
F.
tr~st
Impose a constructive
and upon the
.pr~ceeds
~pon
Re~ewed
the
Lease
received :by and due Defendants- thereu'nder
and declar.ing Defendants trustees thereof for the benefit of
'
Plaintiffs .herein; and

G.
. .Grant such other and
.j~st
deems
f~'rther
relief as this Court
and p"roper.
COO'N'T I I I
INTERFE'RENCE W'ITH CONTRAC-T AND BOSIN'ESS OPPORTONITY

~9.
Plaintiffs rea 11 ege and reaver each a_nd every
a.llegation set forth in paragraphs 1
thro~gh
48 as though .
fully
se~
50.
forth-herein.
Plain~iff J~F.C.
and the STOCKHOLDERS, by Virtue
of' their equitY haterest,s -in J.F._C., maintained a valuable;

.advantageo~s
and 1 ucrati.ve
b~s i
ness .rel ati onshi p and
contract~a 1
relatio~s with Air Fr~nce including, inter alia, the -Ongoing
Lease_
..
~nd
with Air
51.
the
ci~going
Fran~e
good~ill
and business relationship
Deferida~ts
intentio~~lly
and ~nj~Stiiably interfered
with, destroyed .and_~s~rped Plai-ntiffs' contract~al relati~ns

and advantage'ous business re.l a tionshi p with Air
reason of acts. concealment of facts,
co~rses
of
Franc~
by
conduct~
-11~W
OI'I'ICES OF' NORMAN' MAC:-INSKI.
~00
CITv ,NATIONAL BANK BUILIOINO.
MIAMI~ ~LORI lOA
33130
(30:1')' 31181111:1'
..
representat~o"'~~;
and schemes including, inter alia, the
followif1g:
Defendant
~OG~ANAL1A~.
on his own behalf and
.
.
,
A.
for the benefit ~f and wit~ the a~sistance, acq~iescence and

- encouragemen~ of the ot_her Defendants . contacted Air Fral'lce.
~egotiations
and c.ommenced
_with-Air France for the renewal
of lease.
B.
rep~esent~d
SOG~ANALIAN
Dur-ing said negotiation,_Defendant
to Ai~ Frarice that he w~s the chief pri'1cipal of
and d_1recting
-~he- m~n~geme~t~
operation. and control of
J.F.C. and, i~ addition, t~e agent, ~mployee ~nd owner of

Defendant
PAN~
C;-
Quring said negotiations. Defendant
SO&~ANALIAN
- represented to ~Air France that ~efendant .PAN was unconditionally

~obligated
to acquire and certai.n to <;:lose upon the purchase
of all of theoutstanding stock of_J.F.C. and that, byreason of the foregoing .and otherwise, J.
--unable to
~e~f~r~
iti obligations to Air
France shoul!1 not renew its. lease

that Air -F.rance
sho~ld
wi~h
F. C.
wo~l d be
F~ance,
that Air
Plaintiff J.F.C and
renew the lease with Defendant PAN.
Air France_, in reliance .upori the foregoing,
D.
in fact .renewe.~- the lease w_ith Defendant PAN and not w.ith J.F.C
.52..
Defendants- undertook the aforedescri bed acts,
concealments, CO~rses Of .CC?riduct representations, fraud .and'

decei.t and schemes with :fufl -knowledge that the Ongoing
Lease was
J.F.C.,
su_bstantial income producing asset of Plaintiff
hav~ng
generated over One Million

~hat
Dollars -per an_rium in gross._revenues,
($1,000,000~00)
J.F.C. was certain
or.. subs tantia:J:'i:Y -ce~ta-i n -to .enjoy th~ re~ew:a l
by Air France
of t~~ 1 ease;, .an~ t~a t . t~e 1 oss of. the .Renewed Lease was
..
certain or sul:)stantially certain to destroy the ability of

'
&
-.
Plai!'ltiff ~-ff,~--~ to op~rate as an ongoing business coticer~

-
and, further.~ ~o substantiaJly. reduce 0~ d.estroy the .Value
-12~W
OFFICES 0,.
N~fU~~~-~ALINSKI~ SOO
CITY
,N;;,:TI~NAL.
-:'ANK BUILDING . M!AMI.- FLORIDA 33130
<'305)' 358115115

of Plaintiffs stock interests therein, thereby acting with
a gross
a~d
reckless disregard for the prospective rights of
J.F.C.
53.
Plaintiffs are uncertain of the benefits under the
Renewed Air France Lease-which benefiti have been obtained and

div~rted
~~
Defendants and believe and therefor allege that
Defendants-have and will continue to transfer and
~equester
such proceeds.
WHEREFORE, the Plaintiffs herein.pray the Court grant the
following relief:
A.
Award to-Plaintiffs compensatory damages against
Defendants, jointly and severally.

B.
Award to Plaintiffs against Defendants, jointly
and severally, supplementary damages equivalent to triple the

~otal
damages recoverable in this action; and

C.
Award to the Plaintiffs against the Defendants,
jointly and severally, pUnitive damages.

D.
- ~w~r_d-
to Plaintiffs against Defendants, jointly
and severally, prejudgment interest, Plaintiffs' costs and

reasonable attorney fees; and
E.
Order an accounting to determine the amount and
location ~f the benefits w~ich innur~d to Defendants to the

detriment of the Plaintiffs under the Renewed lease; and
F.
Impo~e
a cons tructi ve
~rust
upon the .Renewed Lease
and upon the proceeds received by and due Defendants
thereund~r
and declaring Defendants trostees thereof for the benefit of

Plaintiffs
G.
herei~;
and
Grant such other and further relief as this Court
deems Jut-and proper.

COO'NT IV
..
BREACH OF FIDOCIARY DUTIES

54.
allegation
Plaintiffs reallege and reaver each and every

~et
forth in paragraphs 1 through 53 above as
though fully set forth herein.

J
-13LAW OFFICES OP' NORMAN MALINSKI. 900 CITY NATIONAL BANK BUILDING. MIAMI. FLORIDA 33130
(30lU 3158.11:111:1
r.
ss
Defendants SOG'lfANALIAN and GAHAVITO assuined direction
and control of the operation ~nd~a~agement of J.F.C. a~d

exercised t_t.ae ~powers of di rect~r~s- and offi cers tinder <;1 aim
and ,color of an elect.ion or appointment for such
56.
Defendants
~OG~ANALIAN
and GARAVIJO
po~itions.
cloth~d
th~~sel~es
with the authoritY o:f d.i re<;tors and officers and assumed a
quasi-fiduciar~
Defendants ~OG~ANALlAt{ and GARAVIT9 owed J.F.C.
57.
~nd
-.re"lationship with J.f.C. and STOCK-~OLDERS.
stockholders
duti~s
of good
f~ith,
care and fair dealing
and a duty to exerc-is'e their powers ira the interest'S 'of the
corpo ration.
Defendants SOGH-ANALIAN a.nd GARAVITO w'il.lfully.
58.
~eckle~sJy
or negligently
~reached
thei~
duties a& .aforedescribed
b,Y' courses of .-conC:fuct. i ncl udi ng but .not. 1 imited to. the
:fo 11 owing:
A.
F_ailing to maintain the payments dueUnited
.A.ir .Leasing -:for t~e Airplane, failing .to raise, borrow or

expend the sums necessary to .mai.ntain payments :for the
and permitting the
~irplahe,
~epossession
of the Airplane by
United Air Leasing;

B.
~enew
the Air
Fainng to t_ake. steps to enable J . F.C. to

Fra~ce
lease and the taking
~f
affirmative
s ~eps to cause Defendant PAN -;o .renew the A.ir F.rance 1 ease:;
and
C.
failing to .take steps to protect and
preserv_~
the assets o,f J.F.C. alld. to preserve or assist in preserVing

J.F.c.~s
abilitY to continue to operate as an ongoing business
operation.
breach o:f their duties an.d conduct: as aforedescribed. Plaintiffs
suffered the loss of the Airplane- and their equitY interest

therein, the loss of benefits
and the
:financi~l
~ue
under the
Rene~ed
Lease;.
collapse of J.F.C. which, as a fUrther
-14-
LAw of'PICE:s Of' .NORMAN ,MAI.INSKI. soo CITY .NATIONAl. sANK ouii.DING. MIAMI. FI.ORIOA 33130
--
(30:J) 3:JSI"I"
..
direct and foreseeable -consequence, m~ teri ally redu_ced or

d~stroy~d
the value of stockholders stock fnterests fn J.F.C.
WHEREFOii'E~ tl_le Plaintiffs .h~ere:in pray the Court grant
the followir:-g relief:

A.
An Order c_ompelling an acco .u nting - to determine - the

an~ , l~~ation
amount
,
Defend~nts
~rider
B.
An
of the benefits which have innured to
Renewe~
the
9.rd_~r
Lease; and.
impos .i ng a
c~nstructive
trus .t
upon the
Renewed Lease, ~nd upo!' the proceeds received by ~nd due

Defendants the~eunder an~de~).r1ng Deferidants tru~tees
thereof. .f or the ~enefi-t of Plaintiffs herein; and
c.
Award to
Deferidants,
D.
flain~iffs
~ointly
compen~atorY
damages against
and :severa ll'y; and
Aw_ard_ _to Plaintiffs
pun~ti_ve
damages
ag~ir:-st
D,efendants , . j 'c iintl y and se~era lly.

A~~u"~ to Plaintiffs agai~st Defendant~ _prejud~_ment.
E.
costs and reasonable attorneys -; fees~
- i _nterest, Pl a iAti ffs.'

and
F.
deems
~rarit
jus~
arid
su~h
other
~nd
further rel'ief as this Court
prope~.
LAW OFFICES OF .NORMAN..MALINSKI, .P .A.

900 . Cit:,Y National Bank Buil -d ing
25 West Flagle~ Street
Miarrii; Florida
33130
Tel~~hone:
(305) 358-1515
By,~~LiiS~-:
LAW OF'F ICE OF BRUCE M. LE'V I NE.
2050 Coral Way
s uite 4oz-M1am1,Florida
Te fephc;me:
( 305
..
-15LAW OFFICES
~,.. ,NORoMAN
M..;L.INSKf, 900 CITY NATIONAL. 'BANK BUI_L.DING,
MIAMI~. FL.ORIDA
3313?.
<'305) 35811515
PURC.HASE AG.REEMENT
.
THIS AGREEMENT made this

between J.F.C.
:'1"
-;;f.
Is day
of July, l980. by and
INC., a Flor_~da_ corporation . doing
ENTERPRISES,
~-bus i n_es_~ as ~_ONC0'}9~-JlT.E RN~T I ONAL AI RLJ NES,
hereinafter re fer.red
to as "JFC":
and'.'AVIATION,
corporation~ herein...-. INC;, a Delaware
.
'
'
after.refe~red
t~ as
"PO~~HASER"; and
the.stockholde~s o~ JFC,
- h_ere1 na fter r.ef~rred to as ... STOCK"fiOLDERS", . an~ somet ~m.es i ndi v :idually
~efer~ed -~~-: ~s a ~s~ot~HOLDER".
-- :.
.
_..
"'\
~.
-w~E~EAS,
"
~FC ~,
an International certificated.~lr ca~rier,:
OP.erating_ pursuanJ to sect.ion 401 of the .Federal Avfation Act-of,

~~-1-95~8. as amen~ec,J . That said JFC .holds a ~ertU1cdte o.f convenience
~.and
necessity
Aeronautics
Uoard and is in t.he
-.. iss~ed
- . .... - . by the C1~11
.
.
-~
: ~~us~n~ss_~of prov.icfing_ both passe!'lger and cargo air services on a

-. cha-rt_er. basis.
--
-_JFC's op_ef.ations are

'
Fe~e~al
'
~w ~<'
--
.1n
full
compliance wit~ ___ all applicable
Aviatio~-Ad~inistrat~~n Regulatio~s.
Th~ ~ss~t~_of JFC a~d.pr6perty,- ~ncl~de the said certific~~~
~ ~:-~~~f',co!"v~~1enc~ :an;:ne~e-~s1t~~~-_f'lig~t eq~ip~e-~t.
~nd
ground equipment,
othoer prope"rti~~~--~-nd faci-11t.ies, used or." held for use. in connec"tion-.
....&
:;.
operat~O.P: ~f
:wit_h _tt\e
-
bus_~~ess._ 1_~. contr:ac~ts ~or,
its
- of .-a i rcr~ ft, acco.u(nts rece_1.va bfe, cash. good -wi

-
-~:_
...
-~
;_:~<;'~',: :.,..
. . .,
~ ":--
'~
11
t"he
..,
purchas~ ..
and other .mi see 1 i a-
neous property/~tangible -and .1ntangi.ble; an_d.

?-'.... ':'
...
: -WHEREA_S!f'~~~r.hase~ is:: a Delaware"' corporatJon, 100% of t.he

.. ~. .
r~-~-
."_".
. .- -~1;ock of wh i c.h_ 1:~:--~~ned by

-7"
-;
Ga r:.bet Soghana l_i ail; and
.WHEREAs.f:~~jf~chaser
-..
-. "'-
:~::.--1'~~
'_
des'ires to acquire the stock of JFC _and
. -..,- ... - .
- .JFC des.ires to se.}l' .the stock. at the price and upon the -terms and _
.-_ . -::-:'" -
~:
~ ~ ~-.~?"./~. ~
~n
condit1.ons here.inafter.. set for.th.

-:..
- ~--~
-,~; -~-
-- . -
.:.,.....
,~
::-., .. ,. ....
_ WHEREAS<i.t:he class -"A"~-and class-"B'' st.oc.k of JFC cons~itut_es
ar'!d~ ..Cl ass
... __.. 1'
~~>.;'I_.., .,
'
-_
"B ,; stock;~_col.lectively her.einafter will

_.-
'!.ST_OCK';.
:;-
'1.~ ~
"~.-::...
... ::
..
._,
'
be
referred to as
,.>.-.
-,
-
..
l; Tha~-~~~c~aser agrees tQ pay sufficient monies,for the

-
'1>-.~
'
-~
oi
recovery and rei'nstatement
possession of a certain 'aircraft,
1J;~t1_~:1eCI ~a~ a.-~~~-~~

as-- DC-8- 3'j.;. fre f ghte~ :~- i rc ~aft.
..
FAA regis t ra-
":
tion number_-N-8243_u:;~ Serial
tf'!~- -~ubject- ~a~t~/~~f

Cor~orat ion,
No.-,:4S258.
Said aircraft having been
-certa~n- ~l.awsuit,- wh~re-in Unite~ Air Leasi~g

O~tahoma cor:porat f C?n :is -PJ a 1 nt i H: and JFC- Enterpri.ses,
ari
In~--~ Flo;f_da c~_!'"-P2r.atfon. fs ~efe~dant._~ame being case-~Q 80-9.949.-
been- -_ .
Said case
having
.
~
filed
'
f~ t-he Circuft. Court of 'the 11th Judic:ia-1

:-.-.
C:frcuit .in and fo~~ f?ade County, Florida, -and _th-at_ said amouilt of
monies
in.the
app;c,_ximate
si:.m-_of
$75,ooo.oo,_~IHl1-1
be pafd dfrectJy for
.
- . --:"':'
.
the pu'rpose of ~is.mi~-sf~ safd Jawsu1t and .-rscover.ing possession of .said
air:~~a-ft
sa1d.f!).~-ie?./s a._~~nder
and
th~ consummat.io~-_f-~ ~his.
upoy
agre;'"'e~~yu~~ ~g ~~~ (t;;~~~

---
2. The
sto~ol~s
.
.
-.
'
-~ f_-fttt;. --
(J)-_l-4-e..,
here.by
agree to - sell and the purchaser
. "''
.
hereby .agre~s to buy__ ~:the s.tock of JFC, on the terms and conditions
:........"..,:_ ....herei.n set forth. -~i ;:\-
I:
--
'
'
Th~ .to~;i\>urchas~
- 3.
price for the stock sha J be the s(tm of
.-
-~-~2.5Q.QOO.oo. -.which-$~-~ shall
be divided among the. stockholders ~n ai---
rect: _'p'roportion to ~he_ number of class "A" s~ares owned by each of them
.- --- 4.--This
~
'<
agr.e~;;,ent 1s su'bJect ~o approval if

'"..
-~~
~
>
:_
)_
>
0<
Civil"A~ronauti~~-Board
the
'i,
"
...
'
of the Onited States of

~
5. ~hat i~e ... ~~~~kholderi

have executed a
". - "'
~
req~irea
by law~~
..
~~
Ameri~a.
cer~afn
to
ag~eement
sell- stock and-_have.:J>lac;ed said sf)ares o'f sto.ck in escrow wit_h attorney.
Sanford
-
F~-eed. 4:4,,Bfs-c6'yne B~t_lding. 19 .West Flagler Street. Miami,

.: .
-- .....:'" ~. - .
.
Florida,- 33130, and
~~-~_v~
appointed said San'ford_Freed, as t.heir agent,
-fo~ t~ep~rpo_se of tr.ansferdng _said shares .of _stock upon payment to
said_Sa~ford Fre~d-~ri:b~half of't~~-~stockholder-s

~
'.-
.....
;:
"
as set forth in said
,-
..
1lf
ag'reeinent to _seU .. s. tock- and~.that sa.id stock, -upon receipt ~f'-consf'dera-=-- -------~~~-
~io~--;~-~~t~--~-e~--~~e~-~--~~-~
JFC c~~r:por..~t1on..
~-.-That
Grass- Co~p~ny,
~us def.t\llte~.is
r~~cinded
. ,._.
Jf::C 'ha:~ heretofore entered :into an agre<'mn-nt with SNI!Je
lf.lc,. ;-_,;_ry~ JFC repre-sents t.hat the Sedge t>~ass Company

in
said-:-:-;~reement,.
bu't' jn any event.
th~~~fhe_._shar~s~:o_f'-stock
-
and
~~ :~
~;~ ~:;"
AND
SCH~FFE~.
ATTORN.IEVS AT I.A_W. 200
thdt
s_aid agreement
owned byJoseph Ciavardone,
~---
:: .k-.
fl'II.AFIA~
~,
shall= be trans.ferred .by Sanford Freed tq the
s.
;.;2-
w:
2rid AVENUE. MIAMI. FLORIDA 33130. TEl..: 3712773
-..
:~:
..
have been pledged or is held by security for a $20,000.00 loan and
that said stock is held ~Y attorney, Howa~d Cerney,of.New York City,

a~d
t~at
authority is being received, that upon receipt of the sum of
$~0,000.00,
that -said Howard Cerney 1s to convey said stock to the law-
firm of Pilafian and Schaffer, as attorneys for Purchaser, and_the said

Joseph C1av.ardone, does hereby appoint -James P1laf1an, as its agent _.
for the purpose of

/""'-....:
-~-
" -
transfer~ing
said stock to the
~urchaser.
7, Thi!itransaction shall be closed on or before thirt_y_ (30)
days from this date, unless said closing be postponed by mutual agre_e-
'(
... ment of JFC and Purchaser.
'
~.....
~~- .
(a)
8. ~ach.~tockholder,
indiv1dual"lj', represents and warrants
that he own~ t~e shares of Stock as shown on the stocks transfer

"'
books and ledg-ers of JFC;
(b_) that he either has duly and val idly- exe-
cuted and delivered this Ag~eement on his behalf. and it constitutes

his valid and legally
bin~ing agreement; and (c) that his shares of
"'
-~
;"
Stock are free and clear OT all
liens, claims and encumbrances and
that he wil ~ deliver his Stock certificate .pursuant to paragraph 4

-hereof duly endorse~ for transfer and appropriate d~cumentary- stamps,
if any are
requir~d,
attached, or accompanied by stock powers.duly
executed and ~tamps.
9.
JFcrepresen~s
and warrants as
follows~-
JFC is a corporation duly organized, validly existing,
9. 01
.and in good standing under the laws of the State of Florida.

autho~ized
JFC has
capital stock consisting of Class "B" voting common stock
and of Class "A" non-voting common stock.

of all of. the
St~ckholders.of
The names and shareholders
JFC on the date of this Agreement shall
be furnished to Pufchaser in writing and such Stockholders ar!
tore_s- t_o th-is. Ag_;:ee'!le'!_t_.
signa~
JFC does n.ot have issued, outstanding -or
authorized any other shares of Stock or any options, warrants. con- "vertib_le
secur1~ies
or other rights to purchdse or
g a t i on s i n to Stock -or sec u r i t 1 e s of ,J F C
issue a~y Stock

iight to
acquir~
or
co~avert
any oh11-
J 1- C i s no t o b 1 i 9 a ted
t. o
any opti~n. warrant. convertiblisecuiity or other
Sto~k
and prior to the C1osinq will
Stock or any such--right to acquire Stock.
not
iss~e
any
All voting rights of JFC
are vested exclusively in the Stock described in this section.
True
and correct cooies of JFC Ar~icles of Incorporatjon and Bylaws are

PILAFIAN AND SCHAFFER, ATTORNEYS AT LAW. 200 S. W. 2nd AVENUE. MIAMI. FLORIDA 33130. TEL.: 371-2773
-3-
..
..
available upon request.
JFC has all
req~1s1te
corporate_power and
authority to own . operate, and lease its properties, and to carry on

1~s
bus1ness_as now being conducted.

9.02
JFC has one
su~idiary.
namely Air Cargo
Equipm~nt
And Support, which is wholly owned by JFC and which is duly incorporated, validly existing and in good standing under the laws of Florida
. For purposes of the transactions contemplated hereby, JFC and said
s~all
subsidiary
9.03
be treated as one entity.
This Agreement does
no~
or violate any terms of any contractual
and will
o~
nul conflict wfth
other obligations,
res~rfc~-
ions or commi.tments of any kind to which J-FC is a party. or by which

it is bound.
9.04
cial
(a) JFC has delivered to Purchaser unaudited finan-
statements dated December 31, 1979.
All
such financial
state-
ments were_prepared from the books and records of JFC, are true and
complete. fairly present the financial condition of JFC at the date

of such financial
the~periods
statements and the results of its operations for
then ended.
9.05
JFC neither has nor will
11~bilities,
including
guaran~ies,
liabilities,
whic~
rep~rtable
cordance with
are
have any obligations or
contingent liabilities, or tax

on its financial
statements in ac-
accepted accounting principles, exceeding
genera~ly
$500,000.00 in the aggregate existing as of July 29, 1980, exclusive

.of matters
i~
li~igation
or pending litiQation or judgments obtained
against JFC.
9.05
E~cept
w~iting
as disclosed in
since December 31, 1979 there has not
by JFC to
Purch~ser,
been~
(af Any change-~n the assets, liabilities, agriements,

obligations, propspects, or con_d1tion (financial _or otherwise), of
JFC,_ including any change any-.change in the.ordinary course of business.
whic.h in
th~
a."ggregate ha_ve been materially ad.vers.e;

(b)
Any damage. destruction. or loss (whether covered
by insurance or not) materially ad \ersely affecting the business or

properties of JfC;
-4-
...
..
, /.I'--
any divi.de-nd or d-1~tribut1on 1n. -respect- of any of the Stock of JFC

or any purchase or.redemptidn by JFC of any Stock or
sec~rities;
(d) Any 1 ssuance by JFC of any stock. b~nds-, or

oth-et- securities or righ_ts to acquire any of the foregoing;
(e) Any.wage of salary increase for ~ny officer or
emp}"oyee of JFC (other than normal
-
authorizatio~
practices)_ or apy
increases consistent with the past
or payment tQ any employee,
offi~e~~
or other.person of any extraordinary compensation or bonus.

(f) 1\n.Y CQmm1tme_nt made or-liability ir!curred, or.,ny
purchase, sa 1 es .
o-r
1 ea~ of equ 1 pment.
property. or other capita 1
assets by JFC,_exc~pt commitments made or liabilities incurred in t~e

ordinary course of business and consistent wi~h past p~actices;
-
(g) Any sale of any of the assets, tangible or intan-
gible, of JFC,
ex~~pt
in the normal course of business, 6r any
m~rt
gage, _pledge. 1 i en or other charge or encumbrance placed upon any o_f

the
~ssets
of JFC;
(h) Any default. on. or mat~r_1al
contract,
pur~hase
or any actual or
change to, any m~terial
order, or other obligation to which JFC is a
th~eatened
cancellatio6 thereof or of material
pa~ty,
dis~
putes thereunder;(1) Any waiveror release,of any rights of any material
value. whether or.not in the ordinary course of business;

(j) Any labor .~trike, dispute,
labor-
slowdown,_stoppage. or
difficulty;'~-
- (ki Any material change in the manner in which JFC

conducts its
bu~in~s~;
(1) A~y materia)
,-
transaction ente~ed into by JFC"other
than 1n the ordinary course of business and consi.stent wj_th
.p~st
..
practises
.
10.
d~ys
Jt:C has -delivered or wtll deliver within fifteen {15)
after the
sig~Jng
~f
this Agreement the following information .to
Suyer in "ritin9:
(a) Real
property. A legal
descrip~ion
of each parcel or
-5PILAFIAN AND SCHAFFER. A!TORNEYS AT
LAW.~ S. W. :Znd AVE:NUE. MIAMI, Ft.ORIDA 33130, TEL.: 3712713
-._:. ,{J'
... -.
~_,,
. real-property-own-ed 9r contr.ol:led_by,-or leased to, JFC and,eopies
%~.a~~.:
- ~ '
of'
e~ch
par~el
f'
.Such lease, togeth-er with evidence of marketable title to each

of real
property owned by JFC.
(b) Personal
~1.1
A descr-iption 9f_
ules of deprecJable
propert~,
of ttae
buildings, equipment, etc.
bu11~ings,
person~l
and other struct_ures, and sched-
property a~d equipment of' material
value
of fFC together wi~h depreciation schedules applicable thereto, such

Purchaser:
descriptions bei_ng sufficient to enable 1 _ ~o 'identify and, as contemplated by the parties, fully and completely to inspect the property
described.
..:-
(c) Leases covering personal pfopert~~ A copy of each

lease by which JFC is a lessee or-lessor of personal
property of a
value of at least $25,00~.

(d) ~Jl2"_~s,
permit~~.s-~
Copies of all material
ap-
provals, permits, ~uthorizations~ consents, licenses, orders and re~

~overnmental
strictions of any
agency, Federal, state or local, held
by JFC.
A list of all off'i-
(e) Of'f'icers, directors, employees.
cers and directori~of' JFC, a list of' employees whose rate of renumerat1on is more than $25,000.
pe~
year, and a list of all
persons witti
whom'JFC ha~-w~itten--employme~~ agreements, as well as copies of any

such employment ad~eemenfs.
(f) Employee benefit plans.
Copies of all
pension, bonus,
deferred compensation, health and welfare, group insurance, and any

-
and all .. other employee benefit plans,

-
(g) Onion contracts.
if -any, of JFC.
A copy of each
or labor agreement and of' each agreement

e~ployment ,no~ ~in
~ ce;t~;_i~ation
..
of any kind to
a9r~~r.e~ts
P_'l'~escribing
ef'fect f'or _()perat;j_o,ns of JFC or..
sat_isf'actory
(h)
collec~ive
tlu~ch'tt~rt_
~.!.~~r-ia 1_~-l!.~.r~.~~-~
whi~h
for the
JFC is a party,
p~rchase
of
ra~
bargaining
conditions of __
i.n ~l!e ~lt~rn<l.th'~ . _
no such. agreements exist:
Copies of a 1.1
fiiJ
te r 1" 1 ag reemcn t s
including but not limited to
~e~e~~als,or
tne
~~l~
of proauc:s
and/or services b~:~fC.
-6-
PCLAPIAN AN~ SCHAFFER. ATTORNEYS AT LAW, 200 S. W. 2nd AVENUE, MIAMI. FLORIOA 33130 1 TE\..> 37\-2773
Jf. -:"'--- --
!-.
..,_~-<i:~-~ ~:{~~~:.-.'" -,~: -~'i;. ':J

-- .
~
(t) Policies o-f
insurance.~
Copies of all insurance
policies of' JFC._
(j} Debt instruments and
guarantie~.
Copies of each
instrument, agreement, or other docume.nt evidencing a_ny-material

obligation, .indebted.ness or a guaranty of JFC, and a description of
any property securing.such obligation,
(k) Litigation.
indebtedness or guaranty.
A description of' all
pending or threat-
ended suits, actions, arbitrations, claims, administr.a.tive proceedIngs or governmental
1~~est1gations
to which JFC is or is threatened
to be made a party, or to which any of th-e asset.s of ,JFC is ot is

th.reatened to be made subject:.
by an
1nsu~ance
incl~ding
lawsuits.
if any, defended
company.
(1) Bank accounts.
A ltst of the naes and addresses of
each bank, brokerage firm, or other depository in w.hich JfC maintatns

an account or safe deposit box or
vault and the name of each per.son
-authorized to act on behalf of JFC in connection
wi~h
such account,
safe deposit box, or vault.

11.
JFC has good marketable tit1e to all of its owned assets,
.including those_ reflected on its balance s.heet as of December 31, 1979,

wherever located and whether real, perscinal, mixed, tangible_or intangible, free and clear of
~r
assig_nment
a~d
r~strictions
on or conditions to
tra~sfer
free and c'ear of mortgages, deeds of trust, 1 iens,
pledges,_ charges-, encumbrances, equities, claims, easements, rightsof-way, covenants, .conditions,
~r
restrictions, except as disclosed
by JFC to Purchaser or as to such obligations or liabilities as are
.
dis.closed
set fo.rth in the financial

Except as
such_obligation$
..
~r
s:tatements described in Sections 9.04 .
by JFC tcfur]hasat;rl tangible asset~, real . personal

li!~ili~ies
as are set forth in the financial
statements descr.i bed. herein, and excep~ such easements, rights-of-way

covenants, conditions, restrictions or encumbrances as do not materiall_:
int.erfere- w,oith the- usc thereof ain the normdl c-onchu;t of th" opcratior,.-.
All
tangible assets. real. personal and mixed in each of
categories will
th~
follo-wing
have on the Closing Date, a fair market or realizable
value in the aggregate.at lease
eq~al
to the
val~e
of each
s~ch
-7PILAFIAN AND SCHAFFER. ATTORNEYS AT LAW. 200 S. W. 2~ AVENUE. MIAMI. FLORIDA 33130. TEL.: 31\2773
.. _.
: ,-,:~,-~
-; ~~~i~-
..
. '
"\
L:.,-,Ai::';:(;~;
<-<~
', - '11$;_~- - -- -.;- -'', - - ._,_ -~-s-::)t~.:C:~tig~ry~ ..-;esl~'citfvely. ~ es~- .-acc;u"m'ui
.
a_te<t depr~c1 at 1 on ~~~ -- re.flect~~~~l~-;~a~-6i.nel~mb~r-.-31. 1979: fnvent~~ies. lan-d.)~::<<
_"-:;<~.t::::-ct~n ~;f"c:!-;--bal-~~itJ:sheet=
~
..-_.~;
..
~uHdt~gs
. '.
-~~-
:_
~'
and~.bU1lding
-,"'~ ~
,.,;=..__*-:.;.'_-~. "
< '\
4+;
improvements. equipment, vehicles and rental
'
-:;~.'1-:.
II
.-
property. : JF:~ .J~_oHis ~11 easements. rights-of-way or auth'Ority ,~eces..:

..
- - ~ .-~~~- ~~-~~~...,
sary
fc>r
access.,to
and
oper~tion of.all. its assets.
Such
assets of
- .... - -
"
:-~
~-.olFC
(together
assets. acquired
since
.December
31, 1979 and .leased
.
. .
::.w'i.th
/:.,
-~
. .
,- ~;.:-~ss-ets)-~ons~-~-'E~~e-all of the assets (other than cast!) used or re.ason..:
8:bly required,_.ior use_ by JFC 1n .its busi_ness as presently conduet;ed~ _
<~:~ept as di;cf~sed to .Purchaser by JFC~ all of t.he

-m'ateri~l note-~i:.;:.~cintr~ctsi agreements, 'leases~ and ~ther documents
12;
Oo :
. .: :
..
~ ~
...
to
which JFC is if-part.)'W'-are

valid
and fully enforceable
in accordan-ce w)t.h
-.
..
.-~
'
t_heir t~rms._ if~cept as disclosed to .Purchaser by JFC, t.here does .not

n_ow exist a~y-~efaul~ whi.ch,.has r.aot t>~en wa,ived-, or any c~n-dit.i.on or
.
...
event that. ~i.~J:l'"riotice_o_r .lapse of t~me. or bot.h. would consti~ute a

d.ef.aul.t.
und~t;)!l:Y ~<?f -s~-c~ -documents. or ~greemcnts.

T~~_.operat~_o~ and mainten~nce by J!='C of its assets,
13.
_wh~ther leas~drowried,
...
-:" .....:.. ,
a~d
.
other faciliti~s do not in any ~aterial way
', -violat-any:~rC:I,iriance,_ ?r' F~,dera~. sta~e. or -local law or regulation~

restr1-cti ye
"<;~-~Ein.ant. 0;.- r1Jhts

':' -
14_.
__-
}--~ ':" -;.
Jf~.
'
of any other person.
...
has filed with the ap,propriate governmental agency
_at the appr~pr.Ja.te time or" ..t1mes an tax returns and reports required
to be f.iled. :- .~ll taxes. assessments. fe~s. and other gove"r nmental
charges
due.
'
i.r.om
""C~
,. -
JFC .have
been
paid. Cop.ies of .Federal and State in-.
come tax re~~r'ris .for JFC for the four- yea rs e.nded .December 31, 197 9
available~ti~on
are
"'
request.
-
1s: ~~~e_pt as dis<?_losed to Purct-aser by JFC, there is no sl.lit.

ac~ion, arbitr_A~ion. c_laim-,. admin.istrative proceeding, governmental
investigatio~.,-~or ot~er proceeding of any k~nd pending- or th-reatened
..
-~g~inst JFC or~ towh:ich-any--of- 1-ts ... asse.ts ..t.s _s~u!!J~~!--~ .. i's ~~t __ i_~
default with.~~s~ect to anY order, w~it,
inj~nction, or decree of any
.Court. or ar\y __-.d~partm':n.t,~agency, or instrumentality.

-
_.
'"
..
- 'lc-__~:
-8~
. ..~l::.
PIL~FIAN
AND
SC~~~Fi~.
ATTORNEYS AT LAW, 200 S.. W.
:zncs A~ENUE. MIAMI~
FLORIOA 33130. TEL.: 3112773
fif..
'
_______ -- :'. _ __ f&_... ~ ~ 1::4se CJ~ JFc"!' kn.-:w~c:<.l~e, ~FC J.s no~ .&.n ~t.c,;. ~al.
--:-:}~'~;~4~~~.t:~~
. ~;~~,
.
~~-~~i-~~PP.~i~~~~:~-:~~at~~t;~~
'J._a~s,
-regul,at4o~i~.o~- i:Lcen~~t=~~ -- . ,.
~-;./" .: - -~ -.. . - ':'...:~~:-;~- - .~
:~ - :..
":~f"'~- !'. . : . -.
. . - .... "--~"'~- -_:--:-~-- -- -: ,,.-_':" ~ . .--.:..,.- - -=-~'"t-...~1!:.~~- >'':.!
..
.. -
or . ';- --:.
-, ___ .J
"'-~_ ; --~~~e..ct:_~-r~:~.~~.s- pr~~~f;.Y - ~r ..~l:l~:J.n~~-~~~ _ipc~.uding",. w!thou~:-~.J~"itati.on,'~r;;~!.~i~: ~
r;g:u~a~~~ns-_dea_~__in~. ,with- _eqdai_, employmez:1t

-_ (?pportuni. ty; 'o1~upa tion~i : -> :~
- :.
. - .
.
.
.;
saf_~ty ang -heai~th; ~-~nviro~mE:mt~i matters ,. and zoning.= ._ :-
---
- -
l.-~ <
- 'l
~ -:'"
of
To -the knowl.e_dge
JI!C,
..
. permit'~
;.
all gov_ernmental agencies, wheth~r Federal I

o
"
:.
.. -
JFC has a1l. approval.s,
au t:h.orJ. za t:i OnS ' c "o i:Jsent:S 1 J.j_cen_SeS, OrderS 1 and other
O
-:;
of
state or l _oc,a l, required
t~ _permit the oper~t-ion of its business as present~y conducted.

.
'
l a
_
E.xcep~
. , . d to
Purc;has.er
: 1
as d"l._sc.ose
1 _ ~:>y JFC, a 11 -t h e mater.1.a
opo_r_.:i~.i.~q f.::tcili.ti.e~,
prope-=:ti.e_s.1 _
~nd
. cquipmont
CQndi t:!on clnd

Stat'e
~ Of
1
are suitabl.a
.
.. . ~.:lir
" /"
~or
of
~Fe ~re
.in good
the purposes for
which they "are normaiiy used.

-
f -_
.#
~ --
The
.. 19
acco~nts
receivable of JFC as of -the
dat~
of
t~~s
. Agreement arose, _ ~nd_ ~-s of_ the. .ciosing Date will :.ave. ar~s~n, from
-
bona fide transactio#~ in the ordinary course-of business, and
"ax~~P~ ~:to_ ._-tJle ~xten~. . ~'# - the_ r~-s~~"e for ba~ debts shown on t_;he books -
o.f -J~-C- ~s ~f ~h~t : d~~~ , . -are-; ~~

coli~ctible withi-n
a reasonabl.e p~ri.od
~ndu-~t~; s~andards; <:..};;_ -_- :

- -
- .
. - -
: . --'1';..-:..
o~
JFC
s know1~dge,
fu11y
of time consistent with
. .
......._, ~;, .
. 20_;:~ The e,x~_~U~ion -Or deiivery of this Agrecmen~ and the
.--
':
..- .
the - b~st
consu.mati.on of thE/ t;;~ri-~-ac~ions cohternplated by this Agreeme~t, or

- .
~ _-
'
::-:_'"*
~ -~
- ... .. '"'
:'
-any olie of such events', . \olill.. not ~onst! tute:
':.'" _>: . -=-~-:~- (~) -._ }\~~~:fault; o;;.. a"ri - ~vent

- l~~s~ - ~~ ti~e-, ~~i both, constitute a
that would w.ith notice or
default, under a violation

-~~
: -~- - .' : .~ . ;~~~f~ .: - - ..~ -: .:
-. or . breac~ of, th~: !i:U:'ticl~_s of - ~ncorporation or Bylaws .of_ JFC,
-
--
":
.. .: ~~ ~ .. '"
or any indenture~ :;: l'icense, l_ease or t"ranchise b~ which JFC or .
..,
...
th~- ;ropci~-ties. ~- ~-~~JFC- ~a~
--.~- ~:-
, _ -!
.bound, - or
be-
_(b).:.~~-: ~~~~""zrt-"th;.t w6~id. per-;i~;n;p;~ty to a-~-;-~------.---
---
.. .-.
agreeine~t
or l~strulrient
to - terminate
i t o~-to ncccl~rat-t.th~
.
- ...
... .:
.-- .. . . . . : .
niatt!l:j_ty of' any._i;;d-ebtedness cor-- any obligation of Jl'C1 : o-r
_
- - ! - - - .
'
'-
(c)
~ ~
An ~ ~v~t
t~a~ wo~id
res~:t i~ ~he crcatio~ ~r
.
.
~-
i.rnp()sitlon of l:lnyyal_id li.en!' - ~barge, or eric~rance on any
asset of JFC.
ftlt.M'!~~
AND
---:- :
. :~: 2: ~~~:_..:-,.,
SCHAF~ER. AT!'O~~EY~ AT
'
.
""'.
(-: .
"""'-~
.ho
-~
-9-
LAW. ZoO- S.
-_ .
>I;
.. -
..........
~-"'2M-AVENUE. MIAMI.
~
FLORIDA 33r30 TEl..: 371:.2173

-
. - ....... :.
'I
- -.--~
-
- _.. :. -
"":.'
~-
~.
~ritruestatement
. any
~r
ofa material fact
~-- -- :~-tate a, mate~i-~ 1 . fact ~~~-es~ar~

-~
:-:
,. . . .-. . .
.:
in -
or~e-~: to
omit or will omit
o~mis
make the sta te~ents
...
co.t:at. a1ned her~ .1n or the~e1n : riot -misleading. Except as disclosed to
-_ Purchaser . JFC knows of no.- facts which have resulted, :nor in the
~- --
~ -
....
. -
'
t".-
-r..easona_ble.judgmeot
of
JFC: are imminen-t .. which will
-
:-
resu~t
~-
in a
m_a terta 1 -_change :f~ the bus 1ne's s, opera t i_ons. a ffa 1 rs:, properties/ .
-.
..
~~_-...a~sets~
or
condition
of- JFC w~1ch has
-.
-- .....
.. .
.
.~~Agreement
-.
_.,., -or t pe : 1nformat_1on,
~.
rot been set forth

.;
-.
1~
this
f1napcl.sL statements, cert1fl~

Pur.c haser
:~ _cates or wr1tten ~1sclosures of any kind .,delfvered to 1 1n writing
:.- ..
-- .
.
...
pri~r to. the execution- .of "this Agreement.-.- . .. ~ .. ...
- - -. - 22. ' Purchaser represents and warrants.as follows:
Purchaser : (a)' :./
1s _a corporation dti.l~- organized a~d existing ..in
.i
.
.
li~ts.
--~
'
--::
.. -
=-
good standing
under- the.. lawsorthe State of Delaware.
Ptirchaser
.... -- <~-~~-=:-~~~_s f. a _lJ~~~~-q~.1 -s~:~~'>c~~P~-rae~: p~-wer and a~thcirity to enter. into' this .
.~ : -
..
--
.-.!.
- :', .
. _. . A9r.eeinent and
. . _> -,
. : a~d
.-
~1ll
:..,.
1ts ~ o' bl1gations here_under.
de11v.ery, and
- .:-
_. .
performan~e
-
of this
h~-v~ ;be'e~ .d-uly author1~ed by all ~ecessary cor~orat~ act~on
not
/ioi-~i'"e
.
... - Purcha-~er_
. ~ Arti~les
.
~ -. .
'
or the terms of ..arii

--
....
; (b')
~ ~~h~-e
xec u. ~ io_~,
.
..
-
. .
Agreeme~t
~-;;..
perform
-=- ... -
.: ..,.~--~-~
o{ Incorporation
or-Bylaws
.
- .
-'
. contractual '- -or other obl-1 gat ion. restr"i ct ion. or
~
. commitment of any kind . or nature to which-Purchaser 1s a party or by

. . ::. - - :~ -~- :
. ~ .~ ..;j.:";.l -.
which- 1t _-1s - bound~ ~ .
-~,
.~t~~~ Ag-reem_en~ - has -- been dul'y ~.nd val tdly executed
..--- :-
_ -.- (c;
a~d - del1v_~red by ,;_u.r~chaser and ~onstitutes _ a valid and legally binding
~9reement
-;
...
.. ' > -...:
'
. ,.
of
:~
p~rcf:la'ser.
... (d)' P.urchaser.- has not employed any

..
-- - ---~---
. - .: ..;,~..-......
--
-.
- -- ---
-.
~r~~~r ~!' f.:!Rder: __i,.n,
-con'nectfo7w1th . t~.e ~ transaction contemplated by this Agreement that
..
~~--.:i.: ~--~~;'f;;~~':f/i_(-:"f="#;:i.-..:. ~-~,: ',~:~~;-Li:.-.~:~~~::_..:_.. __;~~::-i..:-i-~:;~.-- ..,~.-=: .. !- .-. : ~- --.,.-~: . --- - ,_ .. ~F<~~-::- :- - - .c.:;;::.>:-.,::.
"#J~~~~~i~lt~~~~~)~~w!~~~~t~~~~~~~1~?i{~fffb$~1~r;i!;J.~~i#;;{;:~-i~Z-.!~"'"')~\~1i~});-~~~};#s:~f_~::~]~:
.~ti:~~
-..
.;l.l
..
.: ..
~J-;=. -~-.._,.~."':~J..'-.!~-:.r~-1~"_i,~;"'"f.{'~~_;.>-n_;. .4~ >::enra 1 ;, 'i:OridUC$~iof~ bu$1 rleSs -. ::-,c:on~UC~ ::;:._~2(.,4!\_U$.1 ne~~':"'.).';f;f:~
1
~*-~~~~~::.~:.~~\?~-i:f"~~~~-f~~~--=!.s.~:::-.~~~22~~:~~=- -~-.:;:,.~~ :~::~~-;-:~.~: ; :"~:~?;.::_::~~: ::.~ --~-.:."' _!,~.;- ~~ _'.~ . . ~ (':;;"";,~-~- ~;r;.~.~::~_~'!-;~~-{_ :-. ~~r::~{js~.,~--~~~
v.~:; \! ~ ~ J:'t..~ ~ ..~ :\aif~.-.rti' ~....-.,:~~-( ...
"'"~ -~---..-
-...c.~'--::~~~.. ~~-.!,:.c . .,.,. _." .. - ...- :c.f... : ,.../-_:}
- --
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........ _ ,.~: ...~~--t,;'::.~
:..Z{; ~~--;~(~ !J.i.b.:'.'!:~Ji.Jt9'Jl.~!:JJ..e!i';~ ~.d,F~I_I r.u.~~,n~.\~~an ~~r::.fp _';#~ ~C_9 r;~ a nCQ W1 t h. p~-~-1;-; J? ra Ct f~-~{\~S. "'.J~ !~~
="<~-~~tsh~:i~::~~~I-~~!1 ~_:~~~_i_t~{~:~:~f:~-~-!~~~: :~:ui> ~:t .~ ~:1(.ord f n~ ry. c-~-"~~i)~f'-bus 1~\'e,~~~~:\~ ;;~

. ,'
.--.~,~'
). : <:,/::;_:: (b) Compliance wf th laws.
': ~.11- ~ n~~e~--:~~f ~h ~:~ 1"1-...~-j:)p l . f~~ bl:e :~ t a tu t ~ s.
(.
' ~ --~ f~:~~ ~ 1:~~-- - it$ :-_;~o-~e-rt 1es-
. _ :.
~~~~;- ~
-~~ -~1: ~~:~~!"~~~~~~:~_:--
-: ,-_: ._:. -.~ .; - _ ?-:'}\_::>-

.
- ..._
. :__~. -
-J . .: ~.. : .; :
\~- _(c) ._.<

.
or.
::: _-.~_- -..... ._- <~
Cot:~duct
~--
1 aw_s .
-.-~u s.1-ne ss .
~_=:~~- -~
-!
its
.. . -
:.. -
. -
in com-
regu 1a t f on s . and 11 ce nse s
. . .
w-
No col:'P'Ol:lfte change s. -_. M~k_e no
.; - .
tusfn~s.s
. .
- .
chang~
-.
... .
:f.n its
-
..; - ~-<!. ~-.:. :~- ,-~:Articiles-. of ~~ncorporat:ion . or Bylaws and take such action
~~~-~)~~? ~:~::~;-~-~~~;--.~e-~~o~::~~~- ~~Y

. <
_- o
~~-
.1~.:..o_
maintain,
pre~erve,
and
. . .:
..
--_
. - :
.- ~-; rights and . franchises,; ~- .-. -
- :- ~-~:-~~~::_:=. -R-~:~-.;~-~-:~~;~r
-'-
-~~7~ss~r~ ~o
-:keep in full force and efect its corporate existence and
_w_~.~:: - ~ -: ~~:- -- -
be
.,"-
. :--: -.-
:_ -
-___. - .
- ..
(d) . 'Capi ~-li-:.:ati-on.
Make no, cha~&go in its authori.zed
. _.:~~.is.au"e..d .. c~pi.tai
stook
'.
. :
-. .
. .
--.-or issue or ~grca to issue a_ny
Aec1_.1rities c;:onvertibl:~ .1-rit:o, or any rights to PIJ.rc~ase,
~
ahy--sha-res
i'
?.:
- ..-- . ...
_-
- --
- -
- <-_....
c;~- ~tock of any class 'or-:any securities; or

~
~.
"
-'
.. -
.oblig~tion~ 9ther tha~ short-term obligations issued
- .
in
the
~I
!i:~~1;~~5~~~-A ~.0~~~~~-,
"~' ~'\~.-
-~ ~
--~.
'1
'?<",)<
,~"'$':'"ij:\
)''!.,.};..~:.).~;~.~~~
>;i<-~~~~~lr~':,'..tj~~~~~
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eP.['..;;.;;
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~ "'t~:~.~...
"...,.;' lf~tf.:~YV~....--(..-V.~ ~_..,..... -,~!~{- ~~
..... r~ ~
- ~
;.~'<~~-f~..~1'<t~-Kc k.:" ~\l.;f~'>J.{',;\!f~~~~:}1:-1ft?;'!I[~~~d.;~'ti-:.;.. ,~.~h:f.'t :/:.:_~~ f"..:--.;,.::~~:.-._ c-.:: : : ~;c,~r-~~{~t-;:-i;~~-:>':!.;~: ~i-~~"'ii~;..-~.
>
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...-_
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;~ -,-~~:~e-~~ "';S,.r,~ ~ :f~~~r~ i " ~~~J":I ~-'-~-~,.~~~~ -~~-'!.'l~l:":--; ~ .:: n9'F~~~~-~-~$'S", r~:~:a~''f0Jl$.'~>J ~>~'T;'~l-<\~~~' ''i
: ' ~~?~~~:r~~~j;t~~:~~~~~~:~~,~~s~~~ir;.;;1.r1-~:=~:.}1: ~ :~~
_ ;=~
:_
~--' :~s:-" /5~f~-~-~~~-~:~ ~;:;: _ ~--~. -t~:~f.;.:-1~~::~x:_~
protect1on of Assets.
.- --:_ _,..
protec.t . _.i t:s asset~ ._
-'.~-~~.:;:J: " ~"-:-<'?~=--- _! (: 1}
_-
. :- :~~: ~ ..:-... ... - . \

p~eserve::.uad :::
-~
-~:0.:.~-:;~~
. /:- -.- . -~ - _ ~-_:--_:_
-. :..:__ .- -_'
_.
...
-~:
~~r-' -.
,. _.,.
- - --
..
,.._
-~:
. ".--c ~
-~
agreements.
. Modify
..
. - . .- .
- - ...
(j)
N9t make any changes or_ mod.i-
>.: fici~tions
-:i.~ -any ~gree~ent to which
. "
_- - .:J
_ ,. - : -:_ .:- -
.
:
--- . ~ ~J=r
.- _ -:-: _~:sr
Ose .1ts . best efforts ~o
; - _- - ::--
.. ...
...
ffft?l&:?
~;: "'~
- -is. a
JFC
" .~.;. ~
party ~xcept
_:y. e.itller in - the Ordinary course of business or as may . be
---': J~- ~.--- -::.:~;~~:
-~--
. :,~ ---
...__ ._. :_--_..
. . _
-. _
-_
_ .
:"
; -:' _-.-.::~ required by _the terms of _such agreement, or as lawfully

_. -..."'l:::i:~-~!.\~~~--":i~:ht-:':- -.~ ... : -~ ----- :"- . _;: . ,.,. ... "' . ~- . -. -_.
- ~-~- --::-:; : ,-l-~': inay_~ be required by the third party to such- agreement, or
_-; _. ~/~~\;- .--~-- -:. _: - ~- - . - - --- ; -:_ . - -. - . :~ '
~
- _. ..
-' -_.:X<~ , :r a~ ~ay ~~ requir_ed by- A government~]. bureau, agency, or
.... -. -
_..:.::
. ~
_...
.- -
1: J
~~-- ~~:-_ :.
::
~f~iil~, s~l.arieo;j,
_ .:; ,_ (k_) _
. . ___ ___
' - ~~
,. ..._.-;:_.:! ... .. - .~.. . ::.-
- ~:-
..
- ~ !t
: .::
no
.incr~~se "in
the
com~_erisation
kay_ empio~ee:
or pay or - pi:-(:)v.ide
.. .
:::. - ._ . _. - --
: _.:
paymenti. except normal. . increases and . bonuses consistent
:~
.. ,.-~ ~<~ ~--~-:
~- -. -
~- ";;}:~~!;~;:~.;~ -: &..-_:."r-~:-
and bonuses. Without the priot:
.,
paid_ ox: Pa.Y~~~~ tc;> any di;l:'ector, o~fi.per, or execut.i ve or
_ _, _ .
_
-- .. -
~i~- ~pa~t:-~~j:~~tice~, - m~~e-
--
..-
_ -f: .-5="
., -
- -
written consent of the _ :', m_a ke or grant no general wage

. ~ --- . -::~ ;i~-.;.-~
. - :. -_._-
.
- _. __
- - .
or salary increase other ' than normal increases consi.stent
.. ' '. .
. . ._, . department .hav.:i.ngjurisdiction.
"":"
-~
wi~b-
=- -~} ~ ~ ~-
- _
-.
~=.;
_;_'._~-- }_~; --:".
--:
-_
_ .
'~f~c~i~~s-,- ~~~- -~nte~ in~o ~~
past
.-~ ~.. : . , . ~-.:/
acjr~ement,
aul.ting
for - no bonus or simil.ar
.::;
s;=ll~s-/agency,
:-~: ~,: ,_~=~- - ~~~~~-~~me~i~--J~f:~ ~~~pee~:_- ~o

--,. . -_: ' - - .-_ -: .. . . . _ . _ : :. .. - . . :.;
employment or con-
~~-
..
...
or other contract or
the performance of personal
. :- . :..-.:~- -:.- services which .is not te~minable w.i thout . liabil.i ty of
-~ ... : -
-.
-- ~~~
-f'"
_
-:
.,.
_ -
=
:c.::.--_ - :-JFC
on
.- - :('~ . -~ -..
- -.. -
_:
.: -
...
~aix -months
-
..
~_,. -
:- -
'
"
...
notice -o:a:- less.

.
,.
'-.--- - - .- 24.-- JFC shalT.

ow Purchaser
and
1 ts authorized agents and
:::__
-_ ; all
.
.
~-
re~~es~ntat.1ves-, toJ~'~ve full.ac~~ss to the assets, including equip:..
---:
~----
..
-:
_ ..
. ..
... _
j.
- 'Iii
-- m~ri~ ~.nd :_o,!:_flen. t~-~g ~~1
e.-- per~O&:l_~ i,-- . property books, f 11 e_s . and records

t:. . :
o~ . JF.C at any . r:-easoria-ble time- and Jn any reasonable manner and wi.ll
-~- t.-~~u_c-_h_ .t ime ~~-. .~fl such fi nanc 1 a.l and operating data
-__;u.~-~- 1 ~h
- Po~~-ha. se~
- ..
. '.
_,.
~--
..
- ... -
- nn-cl ud 1 n9:_,such m~tti;rs .

.
:.
as . pro~essi ng
ma ter.i ~ :ls . ma tcria 1 balances;
pr-o_~_es:s1~~ ---~~nd1..1;_1--~-n~ ~a.:n_d.' s-im1~~~-- matters)

.
=>"' -.
:- . ..
~ ~---
:-
and
-~ -.
oth~~-- -tnfor~a~i~n
with
-
-respec~ 'to :tts b_ustne.~s -or asse.ts a.s Purchaser shall rcas~nabl_.,v rcqucs~.
~- -~ -_2-;. -~f-~ .sh~l~~~ ~~e t.h~1r_--~-est.

i1ci~s \~~te~p1a~ed)~~-z. fh1 -~ Agr-~e~ent
_ .. .
efforts to
~fhct.uate
t.he transac
a_nd to fulfill all of the condi
t~~~s ; o~ Jfcs ob11d~~lons under: th~~ Agreement nd shall do all such

acts a~d -. thing. s as .may be _requ1_red to carry but JFC's obl _igations
~--L:~~;;~:-,~~::..
"ILA;IAN
.... -;..-
,~:::~~,_:_-
-_.
, -; _< - -
~~0- ~HAFFER, ~ATTORNEYS
AT
.-12.;.
uw: 200 s. ~.2nd AVENUE, MIAMI,
FLORIDA 33130, TEL.: 371-2773
-_ _-:.
'
o1t!P.,t~J~1";~ .~-.~ ~~ ~.~~~t~F~

-:.Jhe-~,~-?C~cu:t~ton of: thi$ ~greement: '?Y o"fffcers and/or d1rec:'torl> <>.f JFc~-_-j.:~~-'~
-_
as --StockJlolders- of
--~,~~~.~i, ~~h~J~--\~p~~-1;1;:;
-~., .::.~.
- -
'
'
.::,.
_1~
JFC shall be and
'
:.:;~'::;
here.by
_ ",-~--e~_!ll_li~d __t_Q-be- e~.~~~~t-fon of tt).f~ A-greement by each of themfn th~ir

. ,- ~~,~~-~~pe-~tJv~.-
,_,.
off. 1~er~ a.nd/or_ ,$!1_r.e~tors of JfC as we11 ~~-~.s-~~cf<h~lders-_of~~~'l:F.~~-:-- ~-- _ ;

. - --.: -. >
- _.,
.
:<-~' ..
.o
1,...,_~_.:..
-:. '_. ''
< ,.:.'
~.
''
~:~~~~f.:!-fes ~s
,;
_,,
.-.--,~~:-:-,.t~:-:~-~--9~ .. In c,opsiderat1on--.of the sale of.al'l of the...:s_tock

-- _ ):-i:~~~..:.~:-~-~J.!~~-~~=- . -~._
~ ~ .. _.._ .
..
' .
<.!.~~~~c;l t>y~ eac~ of -.~he StQclo;,holders of JFC. this Agreem.ent~ sha~
of- Jt:C --- :
___ ..----.
-<~iJ~'~at.ft :ps ~~.mutt,tal general .r~H~~se of. all clail\ls by and -.among Jt:C~
~-~:1....
,.."'{':
. ....
-~~ ..~"'
:~ Pt,t'_r_c.hAs.er~
-.
. :"
,,_.
7-:--.
-.--"
_.
~-
~- -~
'
'
t..- Ciavardone.
~~oseph
Garbet
a_n and
- Soghana11
."
... - 1:
,"'.
'
.of:
'JFC against
-
.:_~~:~C?t~d.,l!~c~~~-w~tt_J:l :th~-.-~aws.:c:of~,t-~e- State of FJorida.

-
,'_--32.- _Integrated {\greement.
< -~efe~.-ed_ .to -~e.-_e t_n

..~
',
'
This .1\.gree\"ent and the
con-st 1-tu~ethe' e~ti re

;:_ ' 7
~greemen t
'
.--
~ocu.ments
between th; partje.s--

',
,. -
---: h_e-ra1!q__;~ and th"ere a.re -~O -_covenants. agreements, warran"'t;_i~s. rept-esenta-'-
>;
".,--
'1:
~~'
'
o+
...
:t_1oQs:.or -unde.rst;,a..nd1nc;Js,.w_r-:itte.n or oral ,_-be-tween t~e P.a_rt,es other
~--~~ba~
-"t~ose
_e~p~_~s.s.ly_
s~t
.
-;;
'.
'
.fo-rth
herein.
- -
'
-~ lJ
~.
prior agreeme-nts- between
..
..: -
--
-.-">>.:-
---~nd_
""'"
1'
.:,._IH WITN-ESS WHEREOF, the parties hereto have set their hands
seals
th~
year-~;trst
day and
Flp_ri4a -
above wr,tten at Dade
county~
By__.;...,.._------.
-
--14- ,
.- PI~A"IAH ANO SCHAFFER, ATTORNEYS AT LAW, 200 S. W. 2nd AVENUE, MIAMI. Ft.OfUOA 33130. TEl-' 371-2773
:o--
"'
~~~-:_~~~-~~-~~~,:~c>;_;;;~_iiifh~Ji::;~~i~~rr,c
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-~ -::~- --~ --~::. _. ;: .-.- . . .. .

":<:
. _-.- .
. .-~~J~~ :' ~"'--:>,~\i:~~ y..:'., . - ... -::_:,:.f'L _ :';;.~~~~~:_.;:r.~ ~)_o,_"f.~ f1_9 ,-s~ockhol ~ers o ~~~~llliJ~}:;t~-:e- this ~~!--~~~~~~- ~,.~:.. :~f:-::~ :.-_:.,.' Stockholders-. as well as.-ot"fice rs, directors and
employ--~-~-s-of~~~Fc<; ~'\*~!.~-
. -.~
as the case may be:

-
JOSEPH F. CIAVARDONE
ROBERT A. DYKE
wI l q AM R wE 85 TER
WALTER
E. SHINN
DOROTHY WEBSTER
PATRICIA B. ADAMs
ANTHONY TOR
ANTHONY CISERANO
DONALD
w.
GROSS
APPRO VEO AND ACC.EPTED:
..
-15-
-.
-~..
-.. ----
.-.
AND APPO': X~: H'~JT OP ESCRONI'm

TO TRANS.l'h:~ ~TQCK -
Th~c tlfadcrs.i~ncd
doing b\lsinc!;s _as

corpo1ation
~t'ocl~hold~ls
Coo~or<.!
<" f J.P.
Tr~t- crnat.
c.
Enterprises~
ion a 1 Ai rlines, a
Inc.,
Florida
herc in r .e fcJred .t o as .Jt-C, hereby agree to sell all
of theil s-cocl-:: i~ jFt >;;o sah~ corp(-. -;atjor.,

h<'l~cin
and COndit.ionS
~et
fort..~l.
(ic. JFC), on the terms
'i"!liS .l\l~l"eement S'\tper~cdOS all
prior A!;rccmcnts t o sell said stock, which prior Agrcemen!-s arc

hereby revoked and rcci ndcd.
'
The stock of JFC t.o whjch thfs Acreement
per.t ains is both
Cl~s~. "A''. antl Cl :1:$S t~ st.o~t; of 5<.t5~~ corporation.
The fu11 con~hier:ati<~n to eac-h st ockhorcter shall .be t.he

amount set. forti~ ~.n Schc<htle "A'" lwJ c .ill.after set forth in this>
Agreement.
Each of the unders:i.gned stocl=holdcrs has hcreto;(orc: placed
his stock in ' e~cro'.~
'"i th
Sanford frc~d_ , F.sq\lire, _,0-1 Biscayne
Building, 19 West Flagler Street,

tO
~grcein~
:>~11
to
Agr9emc~t
of this
tran sf.,:,~-
agent to
~~aid
StOCJ~,
Niami~
C:l'Ch
Florida.
Stockholder, by hiS execution
COl,Stit'i :ltcs attJ ;<ppoints said

on .t he ,books nnd_of
shares of sa icl corpora tiO!l
0\vlH~d
for said stock !,>eing paid to
~aid
b)' him,
sui~
In acldi ti on
' B~crO\..-ee
~s
his
corpor'a t:ion all of the
upon the COnS idera t ion
.nscro~,cc
in full.
holder, tciscthcr \iith all of :he Other stockholders
Uach stockCXCCU~ing
this At:lcemcnt, ai!rues . that S 1.!, ::;oo .110 shal.l .be paid _.t o Sanford
Prcccl,
~-C}Hlr<ft:c
entit~ed~
a nd :t'I'f art frotu th() )'l.'Occcds to which tt&ey
'
as s et forth on Scie'<lulc
~/\'',.
as
ar~
full pa'ymcnt for his
s._crviccs to JFC tip to th.c. time of Un:. cxc.cution of this Ag!"_cemcnt,

for his h.:-.ying -prepare4 th::i s Ar.\ec'tliCl~t, and for his s~rv.ing as
their Pscrowec, qnd that saio tmyml~lt. t:o. San.ford Freed is one of
Htc
condi .t ions fen :!'aiu. ::-tocl.l()lulr~ h::wi~g execut~d thi~ Agreement.
--~ --- - ---~--
---. ----- ...
... ...........
C)':'
cashiers c11oci: t') ,. d.J
s:-:s~;<H.(
The Escrowee agrees tc pay each

.!>al~
p.roc{~cds
us _S{Jon us t:hc
purciws<.~
l'lw
o.f
stockhol<;er;' make nn
s~id
,~ockholder
hav~
::c~ro.sent;t t.)
vqid all
his pioceeds from this
cleared his trust 3ccount.
stock S!t.:ci(jcally
~cknowledgcs
that the
o,,s \vim tsocver relative to .J1C
A<!-c]'l~cnt
an,l its a-f.fair:; an<!- th:lt this

~nvalidate.and
_- o behalf of said sto.ckh.oldcrs.
rr~rcseJ\t~tions
is
intcnd~d
to supercede,
relative to JFC that night
have bePll madt.

Exc.ept for the clalr. s of. Ro!,;:a
t.
A.
llyke and William R.
for 1:1onies lo..lncd tu .=Fe and for t.:i)<" .:laim of Anthony

th~ ~rjo~
snlc of the stock o

fo~
consideration
herein
a~recd,
from any
cons,~Pt.:ct
to t
h~
3lld
~ir
the purchase of
<:ach of th<: ttndcr,... i
all claims
what~ocv<r
Curco Support,
i scro,>~ec
Iric. to
Jf~.
for
in
stock being consumated as
~~uc:tl
st:ockhol <lers release JPC
from the
~cginning
s~d
of time:- to
<.! pt'trchasc price
herci n namcc;.
In C<Jn~'ider<ltiot, of tb; sale

ti1..i ~ Aerc<-m<:nt:
Ciser~:mo
~~id
said r-urchase hy the p.1ymcnt of
i.on o (
\\'~bstc:-r
shall o:;)Qr<lte as a
o.r
;;aid stock~ as-herein ~greed,
n~l
case of al 1 claims of .JFC
a_P,alnst: each of the mHJcrsien.ed stodd1olders effective simultaneous

purcha~~
t-:iti1 t.hc consumation of the

which
r~'lc.<l!>C
shall be a11
soever from the
b~ginning
inclu~:i.vc
of
tip(~
of said stock as herein provided,

from any and all c1aims what.-
to the consumation of said purchase.
Ti\iS Agrcel!lcllt: mny be s.igncd in
counterparts~
all of which. shall
b'c take'l t.Of:!Cther as a- siuglc inst.rument.

Each
stockho~
dcr hereby rertcscnts and ,.,.arrants that he is the

O\vncr of the ~tocJ. bc~in: :-:old and that ho.! m"ns !;ajd stock free and
clear of all
liens, claims and
-2-
<"ncum~rances.
fjl:t~~~-
SCJ .. __
--------
\: J'
-- , .....,("''P(")- I) ~"
:.s..::!~:--=~-~..:!- ~-:-'-'~E::_:_
R.
~illinm
~Jtll'"Ot!~y
=~
nric!,
~cbster
~;i..'"!Jtst.ca-
..\dn-m~
- Pat:ricia .--.
..,,, "
,,.~~,~
---~-
PROC'J.~(;;JS
NF.T
---
and
a~hi
Ad:.-l,~;
1 5 .) !/8 . t> 1
2.0. 99.i. 66
Gl"O$S '
29. 3~~(.. ;;
Robert.
36,393.$.:"
Chail.c:; !.rringt-<'n ~u-:l.
'~cJ
- 13 , 9'!> 7 (<~
<.'!'1 i\.r,-1: n,!;t'o;J
- Antno.-:y Toro
ll,19~.f0
172.174.47
J 2 :. 0 0 1).0
$184,671- ..: ~
In
l~i
1.:nc"s:;
~th<."rco
f,
t.hc un<h: t .- .: ~!ncd s toe';-: ho lde>rs h'nvc set
thch- h:nnds :1nd soaJs th.is~lst <lay of .h'tly, 1930 nt ll~H!l'! c:ount.y
florida.
3-
Memorandum
To
From:
.ff
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AIR'lEL
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2/5/82
',,
'l'Oi' .
'DIREC'roR, FBI <ATTN: WCC SECTION. SUPERVISOR
FRO!<i:
SAC~
!I
I
I
MIAMI (l96A-:l056).(P)
~~IS
SUBJECT:
..
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GARABET SOGWwALIAN,
DBA .UNI'l'ED 'l'PADE IN'l'ERNATIONAL I
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~ICTIM
' 'FBW; MF1 X'l'SP

(00; MIAMI)
'
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Re telc'al'l between Bureau supervi~o~L..-------~1

.and s111
12/4/82.
I
L...----....1
Encl~sed for the' bureau' are tho original and fi~e
, copies of an
'LHM
which is furnished per re telcall .
Isouthern
D~strict of 'Florida~
was contacted on 2/4/82and~oncurred~n the release of-the '
information set forth in .the enclosed LUM.
. .."' .
' AusA!
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Bureau (Encs. 6)
U.ami
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. 196A-1056
Miami, Florida .
,,
Februar,y .S, l982
m::
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SARKIS GARABE'I' SOGHANALIAN, . _
DOING BUSINESS AS UNI'l'BD
~RADE
INDR.NATIONAL,
ETC. J
'l'RANSPO~M'ION
OF STOLEN POOPERTY1
~VICTIM -.
~.F=RA=w~=B=Y"'"""W..,...IREl INTERSTA'l'E 1
.UAIL l'MUD
The Miami Office of tha Federal Bureau o~ .

Investigation conducted an extensive investigation into '
alle9ations that Sa~kls Soqhanalian defrauded the Islamic
Republic of -Mauritania of ovur $l,Oqo,ooo in a fraudulent
weapons transaction. Baaed on thia investigation, a Federal
Grand Jury sitting in Miami returned a true bill of
indictment on AUg'Ust. S, 1981, charging Soghanallan with
.
'Fraud .by Wire, Mail Fraud and Interstate Transportation of
Stolen Property ..,, Soghanalian is currently free on , bond. ,
. Trial baa been s~t for May 10, 1 981. .
.
.,:: v;==
::::r
1,:
';
.!
During the 'course of this -inveatic;ation, it

that a Lebanese citizen by the nama of .. .
I has worked for Soghanalian as .aecretary.
~_
,
ioyee both in Miami -~nd in Beirut, Lebanon. _
asCertained .that'Gosilanian is llla:&:ried to
1 1 w h o is Chief of the Miami seou'rlty o'ffice of
8 !118""7 es Depr~( Stato, 11o evidence was '
'
lin the transactions
developed .implieating__ ____

for which Soghazut~ian was n ctea.
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It ia fu:r:ther noted that during this investigation,

n'o evidence,
~lQCJA~ons were developed which
Jhad engag-ed i n unlawful
would .indicate_ _ _
or unauthorizo con uc
.
.
I
~t;reau
~1aroi
.HAL:nlb
(8)-~
.
:,
Thia ' document. contains noither :recocmendations

nor conclusions o( the .FBX. :It is tho property of t:he
FBX and is loanod to your ag-ency, it and its contents
are not to be distributed outside your agency.
'
.,
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4 .,
'''
I.
-.
AIR'l'EL
' '
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'
-'
2/5/82
l
:DI~'XO~,
TO:
''
.. ,
.:FBI
I:D.TTN
wee
SFCTxou
I SUPERVISOR
SAC, -MIAMI (196A-1056)-(P)
FROM:
"
su~c..r.UARKIS
b7C
GARABE1' soomwALIAN,
-DBA UNI'.rED 'l'RADE INTERNATIONAL,
I:
lf'i:CTIK
F-; Mt1 :t-sp

.(00: MIAMI)
<\I
''
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-,
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:Re t!;l c. a]] betwe,n .Bure-au Supervisor

land SP.j ,. . . .
_ 2/4/82. .
_ .......___ _____.
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,L-1..........---:......,.........
~Enclosed'for tha'Bureau are'the oriqinal and -five

, copies of an LUM which is furnished .per re telcall.
.
'
AUSAb
'
''
I Southern .District of F1orida,
was contactedn Z/4/BZ -ana eoncu~red .in the release of the .

information 'set forth in t~e enclosed LliM. '
'~
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Post Office Box 592418 AMF

Miami International Airport
196A-1056
February a_, 19 82
~~----~~Esq .
.Andrews and Lubbers
Post Office Box 5828
Ft. Lauderdaie, Florida '33310
Dear .Mr-.
L - 1_ _ _ _ _ _.......
Reference is made to a 'telephone conversation on

4, 1982, between yourself .arid Sp~cial AgentL..I_ _____,
L__Jof our Miami Office.
~ary
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P~ease be advised that trial in the-matter of

versus Sarkis Soganalian has been set for May 10,
1982, before United'States District ~udge Joe Eaton in
Miami. -Your _clien~
will be called as
.
witness in this mat
nte~~~-~
call two ,associates of
and
L
I Your 'jssistance -~n .a er
and!
_to the above trial
u.s.
be
The above persons should

advised that their
presence -in Miami will be desired on or about May 6,
1982, -to allow .for pre.!trial preparation.
I
'
, Witnes~es $hould, also'_be notified not to commence

actual travel until .notification 'is glven by the United .
States .Attorney's Office, Mi-ami. This notification can be.
expected approxi~te~y forty-eight hours in advance of the
requested trave1.'
'
The trial date of May lO ~s considered a date
certain unless othermatters before the court are
Addressee
196A-l056
IA.M ~
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ICJR"(2)~
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.unexpectedly prolonged.
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Thank .you foryoUF assistance.

...
-very truly yours,
...
''
JOSEPH V. CORLESS
~Special . Agent ln Charge
I.
BY:-
'
I Agent
.
........s~urorp~e:'l'r""v.,..x~si"J'o""'r"'y,......,s::1pl"n"''e:l"'c""l""fial
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ANDREWS & LUBBE"RS
P.o. aox
otAN AN PFitws
~OBtRT
G, \.\IBB_t_l'l$,
$~ie
;(601 J:AST OAII\.ANO-PARI( SOUl-t\/AR-0
.JR.
FOBT XAVDEBDAX:l':, I'X.OlUDA 33010
J, OA\110 \.YNCH
OONAlp .;, ooooy
\'t_ltPHONC f305) 5632541
February 1_1, 1982

Mr. I
u.~
~-.~n-e~p~a~r~tm--e~n~t--o~f--J~u~stice
Federal Bureau of Jnve_stJgation

P. 0. Box 592418 AMF
Miami, Fl<>rida ~3159
Re:-
Dear
\'16-\~ct{}
U. S. vs. Sai_kis G. SoghanaJian

.Your .File No. 196A-10S6
L . I_ _ _ _ _ _ _ _ _ _
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'I'his will acknowledge -your letter

Fehr-,,a:v 8, _1982. bfter
prior con:vet"sation with Spec_ial Agent_ _
_ llast week, _I
did speak withl
jby t-elephone last Mon ay and a_lerted
him to the -matters now set forth in your instance 1etter. Mr.
linfor~ed that he would b9ld himself .ready _for .appearance
at tr,ia_l on May 10,-1982
would be .ple9sed to caordjna;e and
e_ffect the appearances_ of_
1and
I
am, however,_ forwarding toim ~opy ot your le:tter. I in orm you
also t_hat civi_l .t-rial of our action against Sark.is G. Soghanali_an
has now been ordere(;l by the court to commence on Monday, Apr_i_l _19,
1982 at 9:-30 a. m. with one .week reserved therefor. I fully expect
maximum e_f_fort .of the defendant:s to attempt delay of this tria_l
date, howe:ver, t_h~ Circuit Court seems firm in its resolve t_hat
,it wiJl not tolerate furth~r delay tact_ics by the defendants,
this act_ion having 9e~n pending since Septembe_r 1978.
rn:
! I
lf 1 .mayj be of. an:y cont_in:uing assi_stanc~ to

action, please immed.iately advi_se.
you _in- !the cr_imina_l
:Sb ~\'Sirice];.'ely yours,

.:._5....;E;_AR-CR-E~~~~~-~~~'-I
ANDREWS &. LUBBERS
.-
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. Sfi;RM:O.!'-; ,-..,- ''""-"' .u.,~~
Byl....___- - -~
DA/jp
....-----..=:::::;-----'
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FI>-350 (Rev. 12578)
...
. .,ndiCliiC 1)1110:0, l'llli'DC'
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~w ..papcr, city And 11tntc,) ~g. A-1

Anchorage Daily.News
Anchorage,. Alaska
'
Uotc: 1/2 9/82
..
Ed ilion:
(Mo11nt Clipping In Spoco Solow)
"Bergt 1 s Firm Linked

to Illegal Plane Sale"
Title:
Chnruc:lcr:
or
CIM11iric:ntion: 196A-86
.Suhroiuing Orrit"C: Anchorage
..
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:r~rgt's firm Iinke~ :.
to illegal
. plane 'sale.:.
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By ANN CONY
Daily News reporter
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Just one day after Alaska 'International Air

(AlA) sold a Hercules cargo plane to a Florida'
.finn in late 1979, the aircraft was resold illegally .
to Libya, ABC's "20-20" newsmagazine reported
Thursday. , .
' . '
The .sale to Libya violated a U.S. ban on sales
of the. versatile aircraft to the country ruled by :
notorious Col. Moamrnar Khadafy. The ban was :
~po~d in 1972 and remainS In effect today.
:
The AlA Hercules 0.130 was sold to a Miami,
Fla. finn Nov. 30, 1979, "20-20" reported in a :
broadcast Thursday night In the Lower 48. The :
report .said Federal Aviation Administration :
records show the plane was sold again the :
following day to the Libya government's airline. .:
The TV program, scheduled to be shown in
Alaska next Thursday night, traced the sale to
Libya of AlA's Hercules and two other C.130s, :
which were owned by Canadia!'l. and Philippine :
fmpanies. The report indicated the sales were :
ngineered by a Libyan intelligence agent.
ABC .corresPOndent Pierre Salinger Inter- :

'
See Back Page, BERGT'S :
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SEARCHEu.;>..~,._,
SERIAL17.
.FJ=~ 26 1982
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Continued from PageAl
-- _ . . . . : . _
-\
.vlbwed AlA president Gary White, as well as ;)

o\fner of the Mial'l)i company, who gave confii ~ll8 versions of how the AlA sale occurred.
. The Daily News attempted Thursday to contact White in AlA's Anchorage oice, but
reportedly he was in Calgary and could not be
reachedforconurienl
: ABC described the Lockheed Hercules ~130s

~s highly versatile military craft. The planes -also built in commercial versions- can take off
and land on aircraft carriers ana on short .
~anding strips in deserts or frozen tundra.
:
The AlA plane and the two 'oiher ~130s sold
to Libya were used in Khadafy's invasion of
Chad, in the hauling of long-range missiles for '
tests in the Libyan deserts and in shipping '
uraniwn from the African country of Niger to '
Libya, according to Salinger.
'
AlA put one of its Heres up for sale in 1979,
Salinger said. He then quoted White as saying:~our sales department was contacted by 8 Mr.
~rkis Soghanalian, W a fellow who owns a
company in Miami f.i1Jed United Trade International - indicating they were interested in the
urchase of our aircraft..,
White, according to Salinger, said Soghana] ..

1 n wanted to inspect the plane in Malta an
'harteredtheC.130forthatpurpose.. Salinger said White gave the loUowing
, countofwhatfollowed:1 Crewed by AlA personnel, the plane flew from
_.A..I~~k~ to Miami, where it was loaded with
Jeeps. But instead of flying to Malta, the plane
was diverted to Libya at Soghanalian's request.
In Libya, the plane was impounded and the crew
was expelled. Then Soghanalian paid AlA $8.1
million for the airplane.
Neil Bergt - owner of AlA and new chief
executiv~ officer of Western Airlines - ~ave
eSSentially the same account in an interview
with The Daily News in Anchorage Tuesday.
Without naming Soghanalian, Bergt said Unit
ed Trade International of Miami was interested
.in buying the plane but first wanted the craft
flown to Malta so it could be demonstrated to a
client. After the plane left Alaska on a charter
basis, Bergt said, United Trade asked that the
.plane be diverted to Tripoli because the finn's
client was stranded there as the result of a
Moslem holiday.
~ Bergt said after confinnin~ that it was indeed
a: Moslem holiday, AlA agreed to fly the Here t~
Ubya. When the plane landed in Tripoli, It WI)S
s!ized by government_troops who put the AM
. crew on a plane to London, Bergt said.
f;
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With his plane lmpou~ded and Its crew

..1 called everybody In sight," he sai~.
e episode ended, as far as AIA was concerne ,
. few days later when it received a check for U e
ane from United Trade International, Ber
said.
.
.
But a ditcerent account of events leading to
the sale was given by Soghanalian, who was
<tesc.ribed as an international anns dealer under
federal indictment in Miami. In somewhat bro-,
ken English, Soghanalian contradicted Bergt and 1
White, claiming he was not responsible for 1
:diverting the AlA He~ules to Libya.
,
,
"I was in Geneva and my office called saying
certain people at Alaska International Air liked
to see me because they had some difficulties or
the seizure of their airplane," he told Salinger.
Asked where the plane was when AIA first
_contacted him, Soghanalian said, "They told me
the aircraft (was) in Libya In Bengasi."
(Bengasi is on the Medit~rranean about 400

air miles east of Tripoli.)
"'They knew they new there . voluntary,"
Soghanalian said of AlA's flight to Libya.
He also said that when he talked to AlA
officials from Geneva, ..I didn't promise I could
make miracles, but I talked to people In
'
ported,
-Ge~va."
linger said Soghanalian sold the Hercules -'t.
thE day after he bOught it from AlA - to Unite*

Af ican Airways, which Is run by the Ubya
go ernment. Soghanalian claimed to have e
ranged the sale through Ali Hajazi, a friend of
t Khadafy and alleged Libyan intelligence agent.
The two other Herc_ules _ABC traced to Ubya
fonncrly were 0\\11ed by PacUic Western airlines of Canada and Philippine Aerotransport.
Salinger linked the sale of the AlA Hercules to
the sale o! the Pacific Western Hercules, indicat
in~ both were engineer'ed by Hijazi. Hijati
acknowledged a long-standing friendship with
Khadafy, and Salinger said U.S. sources- who
were not identified - consider Hijazl 8 Libyan
intelligence agent.
Although Hijazi denied having any involve:mcnt In the sale of the AlA Hercules, Soghanali
an insisted that he arranged the plane's sale to
_l.ibya through HiJazi. And Salinger produced.
FAA docwncnts ot the AlA sale that contained
the signature of Hijazl's o!!ice manager
Hijazl, according to Salinger, admitted creating a front company called Greenline Aviation,
which bought the Paci!ic Western Hercules after
the craft was sold by Pacific Western to a major
E~ropcan freight carrier.
r
The plane Is now operating on a 1.ong-telfm
If sc to United Africa International, accordJ.fB
, t Hijazi.
.
.
.
~ - ~-~~~--------------------------------------------------------------------------------------~
..,
Federal Bureau oflnvestigation
ANCHORAGE, ALASKA
MARCH 3, 1981
In Reply, Pleu Refer

FU. N
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~~ INTERNATIONAL AIR ~A)
On Febr,larv 13 l~Pll
1 Fai_r banks,
Alaska, T~leph~ne ,_
_____.....JI furnished the following inforrnat_ion:
He was born on September 29, 1938, at Kansas City, Missouri,
and is an unemployed Teamster. He is also an Airlines Pilot, formerly
employed with Northwest Airlines and Alaska International Air. He.
was hired by Alaska International Air as an Engineer and later
p~ornoted to Co-Pilot for the Hercules-type planes operated by
Alaska Internal Air. He was hired~y.AIA in 1968, and ~as fired from
that position in June, 1976. He was allegedly fired for being late
for a (light; however, he believes t_hat the real reason he was !ired
was because of his efforts to Unionize tbe employees ~f AlA. During
his employment with AlA and subsequent to that employment, he has
become increasingly concerned about activit_ics of AIA, which he
bel_ieves border on t :re_ason. He has kept cur1.ent with activities
of A_lA since 1976 through contact wit_h fo1.mer co-workers. His
speci_fic- concerns involve tbe pract_ice .of AJA to purchase Herculestype planes and to resell these to nations not friendly to the
United St_a tes. He stated that the Hercules .T ransport Planes -are
made by Lockheed Corporation at Har-ietta, Gc>:ol.gia. The vast
majority of these planes are produced \mder t _h e N_odel No. C-130,. and
are produced for only the United States Military under that designation. A nearly identical 'model, .-wh'ich has a slight alteration of a
rear window, is manufactured for l _imited civilian use under the
Model Designation L-382.
Spec_ifically, he is :l\-1are of an incident which occ\nred

i _n 1975 in which .a Hercules L-382 (Production No. 108) was manufactured
at .the Marietta, Georgia, plant for --AlA .. ~-This-..4ln_.it:._(No~_l_Q_8)_\ia.s,__.........__
t _h ereafter sold by AlA to Idi Amin, the Dictator of Ug.mda. AlA
reportedly paid approximately $2.5 rnillio~ for the plane and sold it
to Amin for $8 Million. This plane \-1as rcpoltedly later .dest1oyed
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. - - ....... - ... ------- .. .
- -- ~ .~
.. , .. -... !"'lo _,,....r-o- .... , .,. .....
..
ALASKA INTERNATIONAL AtR (AIA)
b6
when forces .overthrew ~in.

He is also aware of a subsequent incident in which AIA
pur~hased two L-382 Hercules Aircraft from-the Government of South

Af~ica (the Production Nos. of these were 106 and 107).
South
Africa had apparently _purchased t _h ese .aircra_f t _from the -Marietta

Plant and \tere subsequently prevented from taking d e l i v Q a n
embargo or by- adverse public reaction- to the purchase.
el_ieves
that_ AIA thereafter obtained the planes through th-e ir i_n erna ional.
political_ connections.
'
:He also has been told that AIA sold two used L-382
Hercules.Aircraft to Angola during 1976. Production Nos~ .of these
aircraft were 103 and 105 . As part of - this transaction, AIA sent
crews to Angola during 1976, where they remained for three to -six
month_s, t :rain_ing "Port-uguese" crews to fly the_ plane. There .is
.reason to believe t_hat these "Portuguese" crews were actually Cuban
Soldiers.
Additionally, dur_ing November, 1979, he is aw~re of an

incident in_which.an L-382 was transferred from AIA to the . Libya
Government. Specif_ical_ly, .this aircraft, Product_ion No. 501,
was purc_hased du-ring the Spr_ing of 1979, and brought to .Fairbanks,
Alaska. '!'he .He_r cules was not painted when it arrived, and_ there
after under'Wene a series of test flights to iron out bugs. This
airc_ra_ft had also all_e gedly come into possession of AIA, when the .
original purc_h aser had been prevcnted from , buying t~e plane through
.an embargo or ot_he~ action. Wl)en -the_ "bugs" were all ironed out
of this airplane 1 it was flow-n_to Flo~ida, o
. t took on a
cargo of one Jeep veh_icle 1 bound for -Malta.
emp~asized that_ it
was highly improbable that anybody would char er a Hercules-type
aircraft to fly one Jeep from Florida_ to Malta.. Thi.s fl_ight o~d
g November . 1979 I and, was n'i 1 oted by Ch_i ef__Pilot t Capt~inL___J
and was co-piloted byj
..
En_ r o ute to Malta, the
ane' wa_s given radio _ins truct1.ons ~to land in Li.by~ (believed to
be ~ripoli). .I_mmediately afte~ the plane landed, troops from the
Libyan Army .boarded the plane and_ took the pilot and co--pilot
directly to Colonel 'Kadaffi (phonetic). Colonel_ Kada_fi thereafter
'hosted the two men for_ approx_imately: two or 'three days 1 at .which
time he gave_the men approximately $1 1 000.00 t9 $2 1 000.80, and they
tak_e n, again_ at gunpoint, to the -Commercial Airport where_ they flew
home. -Both men thought .that_ the plane had been stolen by the. Lil>yan
upon their return to Fairbanks 1 they were told
Government; howeu
to "cool
as to~a t he was no longer the_ Chief .Pilot
'with .AIA.
a d thatL_Jdoes. -continue to be .a pilot .for AI_A
in a .less
_ . tion.
.
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--- tf
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ALASKA INTERNATIONAL AIR (AlA)

~------_.____, !further explained that the original owner of AIA was
~ho got into financial trouble because of unexpected
....d"e-1..-a_y_s__l.r.n--t--=hr-e--' construction of the Trans-Alaska Pipeline. .Based on

these'troubles, he filed for bankruptcy in 1969. While u n d Q
es of the Bankruptcy Court, the Chief Pilot for AIA,
purchased a l a r g e o of shares of AIA, at least one m
on
, at $1.00 ~ach.
was Srn:~ or Pil:t a~d in t~at capacity,
was also the Pres1.dent
under__
~_and pr1.or to tbat
was a Bush Pilot in Alaska. It is un nown w ere e obtained the
capital to purchase the shares of AIA stock; however, rumors
indicate that he obtained the money from Chicago .. With the help of
the Bankruptcy Court, a group of executives from the Flying .Tiger
Airlines were brought lnto the case in order to salvage AIA.. These
officials, along with some .financial breaks, were successful in
saving AlA, wo.h
was released from the bankruptcy action in 1973.
At that time,
owned the majority stock in the Company and
became the Op
He immediately shifted the banking business
for AIA to various Chicago Banks. He"also hiredl
Ia
~ful A l a s o r a t , 'C!-S Vice President of Poll.tl.cal Relations.
L____Jbelieved
s responsible for .many ~ int~rnational
transactions curr n
being handled by AIA.
emphasized that
these transactions reportedly involve numerous nc1.dents where AlA
aircraft are used to transport munit.ions to various countries around
the world. He explained that he personally made a flight in 1975
from England to a hidden air force base in Saudi Arabia. This
flight was in an AIA Hercules-type airplane and. carried a shipment
of missile warheads. These munitions were.manufactured in a
Connecticut plant.
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r----lexplained that after he attempted to Unionize the
employees~A, the Company agreed to negotiate with a Union: however,
never signed a contract. Before a contract could be signed, all of

Union sympathizers were systemati~ally removed from the Company and
the remaining employees (whoni
described as "Yes Men") formed a
b~
Company Guild which was not assoc1.ated with any National Union. This b'
Guild continues to function at 'AIA and insures that all the ef!lployees
there are blindly loyal to AIA. I
]further claimed that he does not
believe that any of the employees of AIA would ever cooperate with
investigators looking into AIA's international transgressions, since
the current job market for pilots and related occupations is extremely
tight. Anyof the e~ployees at AlA would fear dismissal if they said
anything which might cause problems to the Company.
:I
!suggested that one source of information might be

previously ran the South African Operat~on for AlA
~--------~~0
- 3 -
. ..
. ..
'.
'
'
ALASKA INTERNATIONAL AIR (AIA)

d u x : i w and 1973.1
lza~~ri_moved from his job with the Company .
assu.med control ..
when
was further injured by th~ Company
when
unexpectedly sold a uge volume of his stock in the
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Comp
,
using the v~_lue of the stock to c~m approximately
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$25.00 per share down to about $8.00. Since
.holdings were- _
heavily based on these_ stocks, including t~e act
at his stocks .in
AlA had been pledged as Collateral _in quarter of .a million dollar
residence. near Fairbanks, the sudden crash of these_ stocks caused him_
to lQse everything. SpeciJically, his hou~e_ was repossessed by the
Alaska Nationa_l Bank of the North. and he also lost_ a Montgomery Ward
St-or~perated in Fairbanks. I
I e_x plained that he last_ heard
thatL__Jw~s operat_
ing a t :rapline somewhere in the ' bush of Alaska.
'L
l
lr:g:ested that another employee of the A.frican Operatiot:l. of AlA_ was_
I who was last known to be operating a
Sears and ~oebuctore somewhere north of_ Wenatchee, Washington, -in
Nort_h_ Cent_ral Washington. 'This indiv~dual might have additional
._information concerning the intern.a tional operations of AIA.
H_a ys .also suggested tllat former AIA Pilotlr---------.
might b~ lon:i:~ed to assist _in any investigation ol A!!. He
descriped
j.as being very loyal to AIA, even though he was
released __ro
e Company 'duri_n g 1975 or 1976, and is now an
_independent pi_lot in the_ Fai_rbimks area, possibly:.associat_e d with
Aurora Flight Sex:vice.
He explained thad
lwa_s arrest-e d in .,l975- or _1 976,
somewhere i~ Louisiana, in . connection with a counterfeiting charge,
and he believes that this fs :h~:I Was released from AlA. He
believes that in the event
is still on Federal Parole -in
connection with t~at matter 1 e
ht fe-e l inclined_ to -cooperate
to insure in his mi~d that hi_s Parole_is -not in jeopardy.
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I I further advised that during 1976 I he is aware that

AIA arrangea--iiltmy of its internat_ional t -ransactions - -through two
London,Engl_and, Brokers. He does not recall the ioentity .of these
Brokers; however,
believes they may-= be
able_. to provide additional_
_infox:mat_ion,
if identif_ied.
_,
__ _ _ _ _ _;,.__ _ _ _ _...........____,_ _ _ _ __
lrepeatedly emphasiz~d that he is coming :forth :at this
t_ime _in1eW ol the increasing reputation of AIA among Al_aska Pilots
to .be_ profiting from the international transportation of mun_itions
to the h_ighest bidding count-ry, despite the political leanings of
that country.
-
-.k'-
. {p
TRANSMIT VIA:
CLASSIFICATION:
jHRTEI.
---"uLl.liN......
Ciwl\~s~.--_ _ _ __
DATE:
--~2~/~'~3+/48'--~~
~ROM: DIRECTOR, FBI

TO:
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SARKIS GARABET SOGHANALIAN,

UNITED TRADE -INTERNATIONAL,
ETC.;
~DBA
~VICTIM
FBW; MF; ITSP

00: MIAMI
Enclosed for information of Miami are 2 copies

each of a 1/29/82 memorandum from Anchorage to 'the Bureau
and its enclosed LnM and news article, all of which pertain
to captioned matter.
Enclosures
-(2)
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.,
.l
""'ICOJ
\ ij
i. '
L-----~--~----~----------~------------------------------------------~~--r.
;.
:Memorandum ,,)
To
From
'~#- I ~
:I
'
l '{ & pt, lo .(to) (t')'
Dat~ J) ~ l~
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So~j(t: )~,C c-.S
506 ~lt"Lcrn-J
f)J<J
(A;) '.
lt\A. ~
MAR 1 '0 1982
~ -"
IN THE CIRCUIT COURT OF THE E'L EVENTH

JUDICIAL CIRCUIT OF FLORIDA IN AND :FOR
DApE COYNTY
CASE NO.
78-l.4372
(08)
GENERAL JURISDI~TIO~ DIVISION
BOCA INVESTMENTS:, L~D.,

Plainti'rf(s), :
:
SUBPOENA . JaM~KK~
FOR
DEPOSITION
vs.
SARKIS SOGHANALXAN,
et- al.,
Defendant(s).
THE STATE OF FLORIDA:

Al Lane, Special. Agent
TO:
Federal. Bureau of Inyestigation
3'801 Biscayne Boul.evard
Miami, Fl.orida 33137
YOU ARE HEREBY COMMANDED to appear .before a person authorized by law to take
'depositions,at the l.aw 'offices of Fl.oyd, Pearso~ , Stewart, Richman, Greer
& Weil., P. A . , One B.iscayne Tower, 25th Floor
in
Miami
- ,Fiorida, .on Tuesday, March 23
-,J9_Jl2,at J..~OOPM.,
for t_he taking of you_r depos!tion in .the above styled cause:lf:IMd::lD:kwx~~~xHc:U:imexxmt::p:klxCK:

xtobx:fcdkJw(~
If you fa~l .to appear, you may be in contempt .of Court.

You are siJbpoen~ed to appear by the foll9wing attorneys and unless c_x'cused froJn. this subpoena by these attorneys or the Court, you shall' respond to this subcoe2l\~~irccted.
c:> l~ot.-
- .
DATED ON
MAR
.
.1?..;___ __
Richard P. Brinker,
as Clerk of said Court
R. FRANKLIN WILLiAMS
By': __ _ _ _ _ _ _ _...;__ _:__ _:__ _
_
Gerald
At~orney for
Address
F. _ R~chm~n,
Esquire
.A. ~
De.::mty ("lerk
Defendants
One Biscayne Tower

25th Fl.oor
-
Hi~i.
Florida 33131-1868
- ----~----~--~--~~--------~
r.?- --
- -
'Memorandum
,-l
--To
-sAt-,~ {cqlOA-(Oj~J
-- f,41
Subject,)~ :~L . .
rrJu
J,_
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Co.~
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US. Departm.r
Justi~

--------------------------------------------------------------------~ .
United Stat~s Cowt House Buildint. Rd!Jm 2_80"0
Jrd and Constitution Avrnue.N.'W.
'Washlntton, _D.C. 2~001
~arc_h
24, 1982
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1-E_s quire_
States Att9rney
c/o_ United_ St_a tes Attorney's Office
155 south Miami Avenue
~iami, Florida
-
~s~p~e~c~1~a~l~A~s~s~i~s~t~an~e-U~nited
Dea~L-----'
A~ you know 1 on a few occasions over the 'past: months,
you and ._I have spo~en a bout sa:x::~is Soghanali_a ril a . de_fendant~
_in a_ pending cz:-iminal_ case in the south~rn District of_
Flor_i_d a. r have a_lso h.a d occasion to speak brie(ly with
Atlee Wampler, the former united States Attorney for the
southern oistr_ict of Florida, regardi_ng ~r. Soghan.alian.
t : fall, one_ o_f l-tr. Soghanalians a ttor_neysJ

approached me_ on a n unsolicited basis with an offer.
_
. tance from his client. I
!indicated th_a t:
his client had s-ubstantial contacts 1n the Middle East and
'might be of assistance t9 this office in a very' se:nsitive_
case under investig-a tion -- the Wilson/Te_rpil case. As I
have expl_a i_n ed to you, the Wi_lson/Terpil ca se involves our
.inve_s t_igation of two (2) former employee_s of the Centr-a l
_I ntelligence Agency who a re under .indictment: for supplying
~ibya wit~ huge quantities of munition~ and explosives over.
the past: five. (5) or six (6) years. While the_ investiga ti_o n
actively continues _into related areas, both Wil_s on a nd
Terpil have been .fu-g it_ives for nearly two years . Wi_l_s on
has been _living in. ~r.ipoli, Libya, and Ter.pil was l _a st seen_
in Beiruit, Lebano_n. Mr. Soghan_a lian offered to be of what..ever assistance he could in our efforts to recover Messr s.
Wilson an-d 'rerpif. In that regard, he ~raveled to - washington, n.c. and met pers qnally with me to provide
certa_in background information about the dealings that
Mr. Wilson_ and Mr. Terpil had in the Mid~le East. During
that lengthy meeting with me 1 ~r. soghanalian provided
substanti_a l bac~ground inf'ormation that h~ was aware of.
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I Esquire
~e~a~g~e~tww~o~--------~
Mr. Soghanalian also provided certain sensitive documents to us which appear to be of significant value on
their face and will hopefully prove more valuable to us
in the future.
Obviously, any disposition reached -in Mr. Soghanalian's
case is purely between you and he. In determining what
disposition and/or sentence may be appropriate, however,
I felt it necessary to bring to your attention the nature
and extent of Mr. Soghanalians cooperation thus far with
~his office. Because our efforts to recover these fugitives
are ongoing, I would appreciate your handling the information in this ~etter on an extremely sensitive basis. If
you find it necessary to provide the Court with this
information, I would appreciate your attempting to do so
in camera. If you need any further information about my
contacts with Mr. Soghanalian or his attorney, please do
not hesitate to contact me at (202) 633-1708.
Sincerely yours,
STANLEY S. HARRIS
By:
I
LA~s~s~1~s~t~a~n~t~u9-n~i"t~e~d~S~t~a~t=e=s~A~ttorney
Deputy Chief, Maior Crjmej Div.
Telephone:
cc:
IEsquire
~s~t~e~ir-n~,-.M~1rl~l~e~r~and Brodsky
1801 K Street, N.W.

Washington, D.c.
L~--------------~-
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..... ....,..... _, ------April 12, 1982

State of Del ware
Office of Se retary of State
Dover, Delaw re
United States v. SARKIS SOGHANALXAN

Case No. 81-340-cr-JE
You a e a witness on behalf of the United States Government in
the case cap ioned above and below. This letter is.sent to you in lieu
of service o~ a subpoena.
Please acknowledge service of this letter by
signing the uplicate and return i t to our office in the enclo.sed
envelope. ~lso please insert o~ the - duplicate your horne and office
phone numbers in the spaces provided in case i t becomes necessary to
contact you on this cas.e.
Area Code 305
Please contact our office at 350- 5441
after 3:00 p.m. on
Friday
1982 .......................................................................
..........May 14,
..... .....
to verify ttat the trial and/or pretrial conference will begin as
scheduled.
If the trial doesnot begin on the scheduled date, we will
keep you in ormed by telephone of the new trial date.
:It is imperative
that you notify this office in advance if you have any intention of
leaving towr after the s .cheduled trial date.
~~
~~
If ycu are the case agent with primary responsibility for the
conduct of he investigation of this case, you are to contact the AUSA
assigned to this case or the AUSA's secretary immediately upon receipt
of this let er.
If y u are to appear for trial in Miami, please report to the
Witness Roon, Room 346, at the United States Courthouse, 300 N.E. First
Avenue, Mia~i, Florida, (phone: 350-4136) in order that your attendance
may be cert fied.
SPEC AL INSTRUCTIONS: Reference: certification concerning
BROWNING PrEcision Tool Company, Inc., United Trade :International
Inc.
and QRC IntErnational, Ltd.

Thark you for your cooperation .
Sincerely,
STANLEY MARCUS
UNITED STATES ATTORNEY
B~L...---....,-~
Assistant United- States Attorney

350- 5441
or 350-5442 -
81-34o.:..cr-JE
SARKIS SOGHANALXAN
I a:cept service of this notice in lieu of subpoena and will

be present at the time and place designated above.
HOME NUMBER - - - - - - - - S:IGNATURE
-~-~~~~-------- -- ---
Apr.il 12, 1982

Department of the Treas.u ry
_
Bureau of ~lcohol., Tobacco and Firearms
washingtonl''o~.c~._ _____,f~
~)
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ll--------
United States v.SARKIS SOGHANALIAN

case No. 81-340-Cr-JE
You ~re a witness on behalf of the United States Government in

the case captioned above and below. This letter is sent to you in lieu
of service pf a subpoena.
Please acknowledge service of this letter by
signing th~ duplicate and return i t to our office in the enclosed
envelope. [Also please insert on the duplicate your home an.d office
phone numb~~s in the spaces provided in case i t becomes necessary to
contact yo~ on this case.
Area Code 305Please contact our office at 350~ 5441
after 3:00 p.m. on
..
Friday
, ---.!:M!!a~vL-.:.1:.:4w...,___.,1....9~8~2"'-------------to verify 1hat the trial andior pretrial. conference wil.l. begin as
scheduled.
Xf the trial doesnot begin on the schedul.ed da~e, we will
keep you iJformed by telephone of the new trial. date.
It is imperative
that you nctify this office in advance if you have any intention of
l.eaving tm n after the scheduled tr.ial. date.
if ou are the case agent with primary responsibil.ity for the

conduct - of the investigation of this case, you are to contact the AUSA
assigned t> this case or the AUSA's ' secretary immediatel.y upon receipt
of this l.e ter.
If ou are to appear for trial. in Miami, please report to the Witnes.s Ropm, Room 346, at the United States Courthouse, 300 N.E. First
Avenue, Mi~mi, Florid.a , {phone: 350-..41.36) in order that your attendance
may be cer~ified.
SPEt:IAL INSTRUCTIONS:
October 1.6
Refe~enc~
certification datGd
1.981. concerning SARKIS GARJ\.BET ~n~l-fl\NALIA~- ..dLhLA.
B_R_O_WN
___I_N_G__P-+rn
__
cc_I_S_I_O_N__T
__
o_o_L~C~O~M~P~A~N~Y~,~e~t~c~------------------------- ----------
Th~nk you for your cooperation.
Sincerel.y,
STANLEY MARCUS
UN:ITED STA'.L'ES ATTORNEY
Byl
Assistant United States

350- 5441 -_or 350-5.442
Pl.ease return
CASE NO.
81-340--cr-Je
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Attor~~Y
SARKIS SOGHANALIAN
I
:1ccept service of .t his n6'tice in lieu of s .u bpoena and w'ill
be presenF at the time and place d 'esignated above.--
HOME NUMB~R
...............
-~~--
.....,... , "'"'
SIGNATURE
- -- .
-- .- ~

April. 1.2, 1.982
United States Department of State
Support Servi. es Division
Office of Mun
ions Control.
Washington, D c.
20520
United States v. SARKIS SOGHANALIAN

Case No. 81.-340-Cr-JE
You
a witness on beh~l.f of the United States Government in
the case capt~~u~u above and be1ow.
This 1etter is sent to you in 1ieu
of service of
subpoena.
P1ease acknow1edge service of this 1etter by
signing the
1icate and return i t to our office in the encl.osed
enve1ope.
p1ease insert on the dup1icate your home and office
phone number
in the spaces provided in case i t becomes necessary to
contact you
this case.
Area Code 305office at 350- 5441.
after 3:00p.m. on
FridAy
May 1.4, 1982

to verify
the trial. and/or pretrial. conference wi11 begin as
schedu1ed.
the trial. doesnot begin on the schedul.ed date, we wil.1
keep you inf~m~n by te1ephone of the new trial. date.
I t is imperative
that you not
this office in advance if you have any intention of
1eaving town
ter the schedu1ed trial. date.
----------------~------------------'
:If
are the case agent with primary responsibi1ity for the

investigation of this case, you are to contact the AUSA
is case or the AUSA's secretary immediate1y upon receipt
are to appear for trial. in Miami., p1ease report to the

Room 346, at the United States Courthouse, 300 N.E. First
M~-~~~~~, Fl.ori.da,
(phone: 350-4136) in order that your attendance
ed.
:If
Witness
INS TRUCT:I ONS :

and
r;;.ce=f-=e:.:r=-e=n:.:c=-e=-=-:--'c=e:..:X",_;t,.,...i...,f,..i....c.....,a._,t_1..._o,.....nL.....:N:..:..:O;..::...;S=-=1~/_,1""'6~9_,4:....:6=<----
ed September 24, 1.981.
Thank you for your cooperation.

Sincere1y,
STANLEY MARCUS
UNXTED STAT?S ATTORNEY
By
I.______
b 6
b7 C
Assistant United States Attorney

350- 5441
or 350-5442
1ease-r;t~;;;-t~
CASE NO.
1-340-cr-JE
--------------------------------------------------------US Attorney, 155 s. Miami Ave., Miami, F1orida 33130

TITLE OF CASE
ACTION
SARKIS SOGHANALIAN
:I ace pt service of this notice in 1ieu of subpoena and wi11

be present
the time and p1ace designated above.
ourHOME NUMBER
ourWORK NUMBER
SIGNATURE
- - - - - - - - -
---
- - -- - - - - - - -
'-------- ---~
-----~..--;;c----.----------
- ---- -------------------
April 12, 1982
Federal Aviati
Administration
Will Rogers
ld Airport
Oklahoma City, Oklahoma
United States v. SARKIS SOGHANALIAN

You are a witness on behalf of the United States Government in
the case capt
ed above and below. This letter is sent to you in lieu
of service of
subpoena.. Please acknowledge service of this letter by
signing the d
icate and return i t to our office in the enclosed
envelope.
Al
please insert on the duplicate your home and office
phone numbers
the spaces provided in case i t becomes necessary to
contact you on this case.
Area Code 305office at 350- 5441
after 3:00 p.m. on
May 14, 1982
Fr
to verify that
and/or pretrial conference will begin as
scheduled.
If the trial doesnot begin on the scheduled date, we will
keep you in
by telephone of the new trial date.
It is imperative
that you noti
this office in advance if you have any intention of
leaving town a ter the scheduled trial date.
------~----------+-----------------'
If you
e the case agent with primary responsibility for the
conduct of the investigation of this case, you are to contact the AUSA
assigned to th s case or the AUSA's secretary immediately upon receipt
of this letter
If you
Witness Room,
Avenue, Miami,
may be certifi
to appear for trial in Miami, please report to the

346, at the United States Courthouse, 300 N.E. First
rida, (phone: 350-4136) in order that your attendance
reference: certifications provided
concerni
and
Thank
for your cooperation.

Sincerely,
~TANLEY MARCUS
=I.___-----------'
By
Assistant United States
350-5441
or 350-5442
Please return
CASE NO.
US Attorney, 155
TITLE OF CASE
81-340-cr-JE
SARKIS SOGHANALIAN
be
HOME NUMBER
WORK NUMBER
s.
Miami
~ve.,
Attorne~
Miami, Florida
A~TION
33130
service of this notice in lieu of subpoena and will

e time and place design~~ed above.
/
-~~~----~-----~~----~-------
-- _.,.._,
---, ----:..
Apri1 12, 1982

r.ommonwea1th o Virginia
>tate Corporat on Commission
~ichrnond, Virg nia
United States v.SARKIS SOGHANALIAN

You are a witness on beha1f of the United States Government in
the cas~ capticned above and below. T~is letter i~ sent to_you in lieu
pf serv~ce of
subpoena.
Please acknowledge serv~ce of th~s letter by
signing the d.u licate and return i t to ,our office in the enclosed
envelope.
A1s) please insert on the duplicate your horne and office
phone numbers n the spaces provide"d iri case i t becomes necessary to
contact you on this case.
Area code 305" Pl.ease ~ontact our office at 350- 5441.
after 3:00 p.m. on
Friday
May 14, 1982
to verify that the tria1 and/or pretrial conference will begin as
scheduled.
If the trial doesnot begin'on the scheduled date, we will
keep you inforned by telephone of the riew trial date.
It is imperative
that you notif~ this office in advance if you have any intention of
leaving town aFter the s.cheduled trial. date.
If you ~re the case agent with primary responsibil;ty for the
conduct of the investigation of this case, you are to contact the AUSA
assigned to th s case or the AUSA's secretary immediately upon receipt
of this letter.
If you ~re to appear for trial iri Miami, please report to the
Witness Room, ~oom 346, at the United States Courthouse, 300 N.E. First
Avenue, Miami, Florida, (phone: 350-4136) i.n order that your attendance
may be certlfi~dSPECIAL INSTRUCTIONS :
concernin~
R:..:=e:.=f:.;:e::.:r::..e=n:.;:C:..:e::...:...:_...:C::..:e:::.r:::...:::t::.:i:..:f::..i=c:.:::a::...:t::.:i::.o=n:.....:f:..u=rc:.n:..:i::..s=hc:::e:.::d=--~--
Q.R c. International, Ltd.
Thank you for your cooperation.

Sincerely,
STANLE"i Y.&ARCUS
Assistant United-States Attorney

350- 5441 or 350- 5442
---------------------------------------------------~-~---------------~ase
return to:
Attorney, 155
Miami Ave., Miami, Florida 33130
u.s.
CASE NO.
-
31.-34 o-cr-JE
s.
TITLE OF CASE
A':::TION
SARKIS SOGHANALIAN
I acce1= t service of this notice in lieu of s.ubpoena and wil.l

be present at the t~me and place designated above.
HOME NUMBER
b6
b7C:
....
------- --
.ANDREWS & LUBBE-R S
P. O . BOX 5Si&
.2_e01 ~AST OAII~NO PARK BOUI..CVARO
OEAN ANDREWS
ROa.tRT G. ~vaatRS,
,J , OAVIO ~YNCH
OONA~O ,J, cCOOOY
.JR.
J"OBT LA'UX>l!:BX>AL:Il:, l":LORIX>A 333iO
April 19, 1982
b6
b7C
PERSOOAL & COOFIDENI'IAL
~kral
Bureau o1 Investigation
3801 Biscayne Blvd.
Miami, Flox:ida
RE: .Boca .Investments Ltd., v. Sarkis Soghanalian
I enclose copy of Order dated April 13, 1982, which new sets trial of our
civil action for June 7, 1987. Content of such other matters feu1d and
ordered by the Court Will be self-explanatory.
Also'~ ~ed by teleplxxle this date, my recent pex:sooal cmferenc:e

WitH_ _ _ _ lin Washington uncovered further the .fact that she thought
she
. r ox:1.ginal diary of events back in Novanber, 1977. I requested
that she ,look back and if in fact she feu1d such diary to than furnish to
~ copies of the dates in which the false certifications were manufactured by SGS. -I enclose copy of her letter with enclosuresc
I particularly find the margin entry concemillg
t
going to the printer of significance. Further, I was s
til!:
acmpanying
be portrayei). as
I '"" !'elieved thatr :
of his laS na.re COlilCl.des Wl.th the notation 0
narre J~i.on
diary. I
that he in fact SCM this man on
contment
With SGS 'WhO was en acting as his ''body guard'~.
r.vidual
L .
::t
Jconfinns
SGS =ultimately
m- --
M>st irrportant, I want you to knoW that!

!resolve -in this
matter remains absolutely unsbakab1e. He will present himself for
testiloony in both the civil and criminal proceedings no matter When
scheduled.
- -
--- -
~- -
b6
b 7c
.t'
...
Page 'lWo
I Will cont:i.rrue to keep you advised of any significant developrents as

they occur in our civil proceedings.
With .best regards, I am
Sincerely .yours,
.ANDREWS & WBBERS
b6
BY
DA/mfa
b7C
c8PR~
cG.
IITH~
IN THE CIRCUIT
OF THE
JUDICIAL CIRCUIT IN AND FOR DADE
COUNTY, FLORIDA
GENE'RAL JURISDICTION DIVISION
CASE NO.
78-14372
(08)
BOCA INVESTMENTS, LIMITED,

_etc.,
P1aintif,
-vsSARKIS G. SOGHANALIAN,
et a1,
Defendants.
ORDER CONTINUING AND RESETTING TRIAL
THIS CAUSE came on before the Court upon the Motion of
the Defendants for Pretria1 Conference, Determination of
Jurisdictiona1 Issues, and to continue the cause to permit
such hearing as we11 as to comp1ete discovery on the merits.
The Court having considered said Motions, having heard arguments
of counse1 and i t having been specifica11y represented to the
Court that Defendant Sarkis G. Soghana1ian wi11 not assert any
rights under the Fifth Amendment to the United States constitution if . such proceeding is he1d subsequent to the crimina1
proceeding in the United States District court now specia11y
set for the 24th day of May, 1982, regard1ess of whether such
case is in fact tried at that time, i t is,
ORDERED AND ADJ.UDGED, that the Motion for Continuance be
and the same is hereby granted and this cause is hereby removed
from the tria1 ca1endar of Apri1 19, 1982, and is specia11y
reset as the No. 1 case to be tried non-jury on J .une 7, 19'82.
No further continuances, under any circumstances, wi11 be
granted.
It is further,
ORDERED AND ADJUDGED, that the Motion for a Request for

Hearing on Jurisdiction be and the same is hereby denied.
The
Court sha11 try both the merits and the jurisdictiona1 issues
--
(
._
at the tria1 on the 8th day of June, 1982.
It is further,
ORDERED AND ADJUDGED, that there being an agreement by

counsel that this cause shou1d be pre-tried, this Court sha11
set a pretria1 conference by further order upon request by

either party.
DONE AND ORDERED in Chambers at Miami, Dade County,
Florida, this
/....J
day of Apri1, 1982.
. EDWAiCD
tl.
SWAUKO
Circuit court Judge

Copies furnished to:
Gera1d F. Richman, Esq.
Dean Andrews, _ Esq.
..
-2-
- '
....
.
b6
b7C
Cabin John, Haryland

20818_.
LEsqujre
Il'ort _Lauderdale, -Florida
33310
b6
'
Here are the_ pages from the calendar.

hope 'you can read them .
They a:re_ rather messy.
b 'iC
on the flfteenth,- scribbled on tl}e side is "RW to printer."
On tbe sixteenth SGS an[

2:00. :PM.- 1
h_aps the
;:re :t ORC from 8:45
lsa:y th1.s 1.sj

__
_
Leucn cau.e. f_rom him--perna
no
I the
AM~
boxer.
until
Per--
Under the_ -To Be_ Done Today: you will find the_ airline a:JJ.d ,hotel
_rese-rvations for various people.
r -found
the cbeck for America:n .Airlines.
The date is 18 November.
t aiso show a: deposit _in my .c_heckbook from UTI, one of t_he many
SoghanaliaJ). co~panies. But Z: believe he has all the checks so- it
would' be impossible to prove anything. 'I am cert-ai_n. that t .sent:
stationery to him in WiscoJ).sin, he_ signed blanl(s and returned them

so the new lette:rs could be typed. Yo~ might_ quiz Reynol_ds on it
if you think _it could help.
Hopefully, this will all be over by- next- week.
hard.
-
I am !>raying very
,ISincere!>
P. s.
P.P.S.
- - - - - - - -
'
Sor:ry,. but the address you have for me is wrong.
one_ above.
b6
b7C
Correct_
Am also enclosing copy otcaffi4avit we using in prying

from SGS some of the money, he owed QRC at- the time_ of
M'r. n Is death.
15
NOVEM. '1977
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TUESDAY .
NOVEMBER~ - 1977
OESC~IPTION OF' S(RVtCtS
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WEDNESDAY
327th,Oay NOVEMBER; 1977
(.
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VIRGINJ:A:
:IN THE CJ:RCUXT COURT FOR ARLXNGTON COUNTY
ORC XNTERNATXONAL-, LTD.,
)
)
P~ai.nti.ff,
v.
SARKXS G. SOGHANALXAN,
SHXRLEY A. SOGHANALXAN,
and
UNXTED TRADE XNTERNATXONAL~ :INC.,
At Law
No. 20653
)
)
)
)
)
Defendant's .
UN XTED TRADE XNTERNATXONAL, :INC., )

)
P~ai.nti.ff,
)
)
)
v.
J:n Chancery
No. 29477
ORC :INTERNAT:IONAL, LTD.,
)
)
Defend~nt.
AFFXDAV:IT OF PATRJ:CJ:A
~.
Mary1and.
Hy
name i.s Patr.ici.a Kaenel..
From approxi.mate1y the
1.978, when the

empl.oyed by
Ar~ington
Q~C
office manager.
22~01.,
X reside i.n Bethesda,

of 1974, unti.l.
J:nte~nationa~.
Ltd.
(ORC) as secretary and
J: continued to work as secretary for ORC at

Westgat~
Dri.ve~
McLean, Vir-
until. August, 1.978, when J: was el.ected Secretary-
Treasurer of the-Corporation, which position X

2.
Apri.~,
offices of ORC were c1osed, J: was
i.ts new address, Sui.te 600, 8400

ginia
fa1~
KAE~mL
sti.1~
ho1d.
This Affidavi.t i.s based upon my personal. know1edge
and i3 made i.n support o the i.1ings in Law No. 20653 by P1ainti QRC and in Chan~ery No. 29477 by Defendant QRC.
3.
The President of ORC un.t i.l. February, 1978, ...,as
John Wi.l:l.iam Ho1comb.

on that date.
Mr.
Mr.
Mr. Ho1comb di.ed i.n an airp1ane crash
Reyno1ds H.
Wi.1~i.ams,
Jr., was Mr. Ho1corr.b's
As'sistant.
-1-
-to ' "
-AFF'I.DAV:IT 2---- ... --, .
"'
_:_ ..... 1

Soghana~.ian
Mr. Sarkis G
4.
in the spring of
for him.
~975,
ac~.ient
became
of QRC
when he asked QRC to procure an airplane
J:n August, 1975, Mr. SoghanaJ.ian .. and his wi.fe came
to Washington, in connection ~ith the purcha~e of thea.irpl.ane

<lnd other matters being
hand~ed
soghana~ian
A corporation organized by Mr.

Trade
J:nternationa~,
J:nc.
.for Ml:'. Soghanal.ian by QRC.

in
De~aware,
United
(UTJ:), was to be used to oWn and
operate the airplane, wi.th Mrs. Soghanal.ian J.isted as UTI's

oficer.and:di.rector.
cer, director, or
A~though
stockho~der
Soghanal.ian was not an offi.ofMr.UTI:,.

he managed the corporation
and used i t for his personal. affairs and those of

naJ.ian.
ary,
During the
~978,
from the
fal.~
Sogha-
of J.975, .through Janu-
MJ;; Soghanal.ian acted as the principal. agent/officer
himseJ.f and Ml:'s. SoghanaJ.ian in the

business affairs.
conduc~
J:nternational., Inc., Airtrade
(UTI:) Ltd., and UTJ:/Air Cargo, Ltd.

control.~ed
by Mr.
Al.l. of these corporations
Soghana~ian.
During the entire period of Mr.
5.
of their personal.
Mr. Soghanal.i.an aJ.so required QRC to perform
services for United Industries
were
Mr~.
UTI: was aJ.so used by Mr. Soghana1ian as the agent for
of .UTI:.
."'
p~riod
so~e
Soghanal.ian~s
dea~
ings with QRC, J: was th.e onJ.y secretary in QRC's offices, and J:
prepared
a~~
~etters
and papers
inc1uded a11
~etters
and. documen.ts which invoJ.ved UTI:.
~hich
were produced by QRC. This
UTI: documents were prepared at the direction of
Mr~
Such
Soghanal.ian
or,. occasiona~J.y, one of ~is employees !n F~orida, by teJ.ephone,

.,,..1;el.e,type~
.. ~~
Ho~comb
c!C)~U.":\ents
nalian.
by
~J.
or personal. visit to QRC's offic.es.

.or Mr. Wil.J.iams
a~thor!zed
At no time were
to prepare any corporate
for UT:r, except with the prior approval. of

A11 correspondence
i~v6J.ving_Mr.
Soghana~ian
me.- (For exampJ.e, Exhibits 5-6, 7-1, 7-9,
7-~~(5),
correspondence i.nvoJ.ving Mr. Soghanal.ian's
a~ fairs was type'd on UTJ: letterhead-
-2-
M!:'.
Sogha-
was typed
9-13,9-28)
per~ona1
business
(For exampl.e, E:<hibi ts
:-.
"'~
.. _,
..
_..,_
as the p rincipal. offi:ce
of
UT.I:.
Exhibits 9-36 to 9-4~ are cop-.
ies of .documents prepared by me at the direction of Mr. Sogha~

nal.ian d~i:ing his visit to ORS's ~ffices on November 1.6, 19"17.
Mr.. Soghana.l.ian al.so suppl.ied the portions of the docuri!e~~~ . :Ln
the French .l~_ngua~e.
" ...
'"
6.
As QRC's secretary, .I: al.so tyPed, at the direction-
of Mr. Hol.com.b or Mr. Wiil.i~ms, financial. repo~ts a-~d summaries

of in:form~t;ion ;-e~ating to the business of UTI and of Mr. Soghanal.ian.
repor~s
These
or sent to him~
7.
Mr
..
were
giy~n
to Mr. Soghanal.i.,:an in P.erson
(For ~xampl.~, Exhibit;s 7~10 ~nd a-i).

Soghana.lian: often visited the
-area during 1.976 and 1977.
.'f{ashingto~,
As QRC's secretary, :t r:nade hotel.
and airl.ine reservations for Mr. Soghanal.ian ~nd for any other
p~sons
This incl.u~ed overseas trave~,
who travel.ed wi:th him.
-as wel.l. as travel. in the United States.
Visits to the QRC
offices varied in l.ength, from one to three or, pe_rhaps, foUr

day~.
Mr.
Soghanal.ian woul.d spend time in the office arid al.so
hol.d meeti_ngs at h.is hotel..
. From
~hacking
endars for the years l:976-. and 1.977, I

visit~d
the QRC office cal.-
find that Mr. Soghanal.ian
or had meetings in the QRC offices approximatel.y twenty
times in each o those years.

8.
At the direction of Mr. Soghanal.ian ,. Mr. Hol.coinb
~nd Mr. Wiiii~ms prepared ceFtain corporate docW!le_nts for UTI:~

:t typed these documents.
Then, i f Mr . Soghanal.ian was in the
QRC' offices at .the time, he woul.d take the d,ocuments to be

given to. Mr-s.
Soghanal.ia~
for
executio~,
or, at other times,.
.,
the documents were ma.il.ed to Mrs. Soghana.lian at her address

in Wisconsin.
was
riever
.
To the best of
my-know~edg~,
!'
'
~s~~Sog~:nnal.i.an
t
;.
;.
consuited' when corporate decisions al..legedl.y were

'
'
'made, al.though her signature was required on all. such documents.
'
:
i
-3-
:
:
~:
---:J-.. . . ...-.... an
andria Nationa1 Bank of
nad
a UTI: bank accoun.t in the Al.ex-
v~rginia,
No. o-sS-92-411, into which
he transferred money and from which he directed that expenses

be paid.
These
e~penses
inc1uded such
insurance for the airp1ane.
item~
as gaso1ine and
This.account was a1so used to pay
such persona1 expenses as the American Express Company_charges

on cards in the names of Mr. and Mrs. Soghana1ian and their
two chi1dren.
Deposits into the bank account were irregu1ar.
Often the ba1ance was be1ow $100.
Except for one charter of
the airp1ane during 1977, J: know of no income received by UT:t.

J:n fact, on severa1 occasions QRC 1ent money to Mr. Soghana1ian
to be p1aced inithis UT:t. bank account.
I: remember-frequent
te1ephone ca11s from the American Express office in Phoenix

requesting payment, and ORC's efforts,to prevent the credit
cards from being cance11ed.
J:t was often necessary to
~epre-
sent to American Express and other creditors that Mr. Soghana1ian was out of the country and temporari1y "out of reach." ..
10.
Between 1.975 and ear1y 1.9'78, UT:t was used by
Soghanal.ian to hol.d titl.e to and
~o
Mr.
operate the aircraft used
by Mr. Soghana1ian and al.so as an instrument to conduct his

persona1 affairs.
These principa11y re1ated to the procurement
of arms in the United States and abroad, and the sal.e of these
arms abroad.
The principal. means
~f
communication between
Mr.
Soghana1ian and his actual. or prospective customers was the
Mr. Soghana1ian carried on his
tel.eprinter in the QRC offices.
personal. business by signing messages sent by UTI: and receiving

messages sent to UTI:.
(Exhibits 9-1 to 9-1.2).
he signed on beha1f of UTI:.
(Exhibi~s
J:n some cases,
9-1.3 to 9-28).
He r.epre-
sented himse1f to be "President" or.the principa1 oficer of

UTI:.
~11
11.
such communications were charged to UTI:.

Mr. Soghanal.ian used QRC's offices to communicate
with Mrs .. Soghana1ian on business and personal. matters
I: made
business cal.1s to Mrs. Soghana1ian, particc.1arl.y in connection
.,
.;.
:\
with the execution of UTI: corporate documents, which she was

required to do, and the power of attorney.
Mrs.
Soghana~.ian
used QRC's offices to .communicate with her husband.

~
~2
. on,Novemher
~6,
~977,
Mr.
Soghana~ian
visited
QRC's offices in Ar1ington, Virginia, in connection with UT:X:'s

of arms to Mauritania, through BOCA :Investments, Ltd.
sa~e
Mr.
Soghana~ian's dire~tion~
I: typed up a
number of documents
to be used in connection with that
sa~e.
~~
Exhibits 9-36 to
a1so, Paragraph 5,
13.
duced for
The
fi~es
c~.ients
supra, ' an~
(Exhibits 9-28 to 9-30;

9-4~).
of QRC and any documents . that were pro-
were kept .in locked
fi~es
in the QRC offices.
The keysto "these file cabinets were kept .in a safe with a
nation lock.
At
combi~
This combination was known only to Mr. Holcomb,
Mr. Wi11iams, and myse1f.
When Mr. Holcomb was
ki~1ed,
and
the decision was made to move the QRC offices from Arlington to
McLean, Virginia, these files and the safe were moved .intact
to the present address of the corporation, as stated in Paragraph
so~e
~.
supra.
person with
Mr.
Wi~~iams
know~edge . of
has 1eft QRC, and I: am now the

the combination.
A1l documents
have been .inventoried and kept secure.
Vi.rgini.a! County of ~-?~~-
'
.;.-
~~
Sworn to and subscribed before me this
Patricia Raenel
/: ~~
J.
1979.
Notary Public
My Commission Expires:
. -. :- -~- ....
- - ,
___
_..,----~ ~-
,~
.'/
'
;;-
day of April,
---
i .
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<Rev. 5-22-78)
...
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'
FBI
TRANSMIT VIA:
PRECEDENCE:
0 Teletype
0 Facsimile
O
AIRTEL
0 Immediate
0 Priority
CLASSIFICATION:0 TOP SECRET

0 SECRET
0 CONFIDENTIAL
0 UNCLAS E F.T 0
0 UNCLAS
Routine
4/23/82
Date
-------i
----------------------------------------------------TO:
SAC, ALBANY (196A-296)
I
SAC, UIAMI (1_96A-1056) (P)
FROM:
Enclosed for receivinq offices are trial subpoenas

as set forth below:
Albany: I
Alexandr1a
Baltirnorer=~----------------1-------------------~
Newark: J
1
New York~~--~----------~~-----------.
Salt Lake C1ty: IL.,_______________JI
LEAD
Receiving offices will serve enclosed trial subpoenas

as set forth below:
2-Albany (196A-296) (Enc. 1)

2-Alexandria (196A-283) (Encs. 4)
2-Baltirnore (196A-439) (Encs. 2)
2-Newark (196A-75l) (Enc. 1)
2-New York (196A-1385) (Enc. 1)
~Salt Lake City (196A-322) (Enc.
(b'Miarni
HAL~ n;J,>n
b6
b7C
(14~
. -
Approved:
. .
(/r-~
jl
.
Transmitted -<Number)
- - - - - -<TilDe)
-----
FILED.
'- .....J-
.,rnrer;;;:e:J
I~ ~A- /OS~
-:trO
Per - - - - -
'
l_96A-l056
ALBANY
AT l;yOODSTOCK, NEW YORK.
----""1-________.l ~ice
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------------------------------ --------- ---- ------------- --F!H MIAMI (62...;5710 SUB-A)
---~--
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(1961).-1056), P
TO D!'RECTOR ROUT:XN&
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, . RKIS G~RABET SOGHAN~LJ.;N.
ELSUR;
REFERENCE .BURE~U TELET~PE TO M-t~i!, APRI'L _2_3, 1982.

FOLLOWING ADDIT;IONAL INFORM:z\'tiON IS FURNIS-HED il'ER RE !l'EL:SAR~IS GARABE'l' SOGHANALI'AN WAS '!'HE SUBJECT OF T_HREE sEP.;RATE
CONSENSUAL HON!:TORINGS UNDER MI'A11'I -F-tLE NUMBE:R 1._96A-1056, c.;P'I'IONED

'"SARKIS Gl).RABET SOG_HANAL:XAN, DBA 'UNtii'ED TMDE INTERNfTIONAL;
vrc'tll1; FBW; MF; r:Ts-P; oo:
TO ALL THRE-E MONI'TORIN~S:
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TELEPHONE:
MIAMI."
THE
-FOL~WING
'APPLIES
1) NAME OF :tNDIVIDU~L G)~AN'I'I_NG coNSENT -
) NATURE OF 'I'ECHN.IQUE
.;No
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--
INEW JE-RSEY
CALL. FROMi
lr""'"-----------,1 TELE_P-HONE NUMBE-R I
&
TO ;RES:I_DENCE
OF SOGHANAI;IAN, 305 NOR'r_H Ht:Brscus DRIVE, lUAMI BE.;CH, FLORI'DA,

TELEPHONE NU:MBER _305-672-1263, ON OCTOBER 31, 1_980.
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BODY
RECO~DER AND T~SMt'M'tNG DEVICE (WORN BY._I_ _ __.I ,- A'I' MlN-1!,

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DAY PERIOD.
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NOVEMBER . 4 I 1_9 8 0 I ONE, NON'I'ELEPHON.I C
OBJECT OF l10NtTORI_NG WAS TO -DOCU;MENT 'POSS-!BLE QB_S:'I'RUC'I'ION

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:tiON UNDER <Mt-:1 .196.-b -1056.
EVtDENCE OBTAlNED THROUG-H ABOVE MON'I'I'ORINGS WAS -DEEMED
..
INS-UFF.ICI'ENT T o ES.TABL-tSH OBS-'I'RUC'I'-IQN lNVES-'I'IGA'I'ION, AND DI:o N-OT .ADD

sUFF-ICJENTLY TO ~HE FRAUD' ziNVES'I'IGAToiON TO WbRRAN'I' COMPRO.MtS-E OF
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<196A-1056>
FM niAMl (62-5710 SUB-A>
T 0 DIRE cr OR ROUTINE
m
UNCLA S
asuR; SARKIS GARABET SOGHANALIAN.
REFERENCE BUREAU TELETYPE TO MIAMI., APRIL 23, 1982.
FOLLOWING ADD.IT 10 NAL I NFORMAT'IO N IS FUR Nl SHED PER R.E TEL:
SARKIS GARABET
SOGHA~ALIA"N ~vAS
THE SUBJECT OF THREE SEPARATE
CONSENSUAL MONITORIOOS UNDER MIAMI FILE NUMBER 196A-1056, CAPTIONED

"SARKIS GARABET SOGHANALIAN, 'DBA UNITED TRADE .INTERNATIONAL;IL..,___
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TO ALL THREE
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TELEPHONE NUMBER 305-672-1263, ON OCTOBER 31, .1980.
B. TELEPHONE:
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CALL FROM
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~----------------------~~
NE\~
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A...ailDA,TELEPHONE NUMBER 305-.672-1262, .r\OVEMBER 3, 1980.

RECORDER AID TRANSMIT.T:ING DEVICE <lvORN BYI
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OCTOSER 31, 1980, 0 NE, TELEPHONIC, NOVEMBER 3 ,. 1980., 0 NE, TELEPHON.IC,
OOVE~lBER
4., 19.80, ONE,. NONTELEPHONIC.
OBJECT OF MONITORING WAS TO DOCUMENT POSSIBLE OBSTRUCTION

'ATTEMPT BY SOGHANAL.IA.N .IN CON~'ECT.ION 1.HTH WIRE/MA'Il. FRAUD .HWESTIGAT ION UIDER MM 196A-1056.
EVIDENCE OBTAINED THROUGH ABOVE MOUITORIOOS
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FM MIAMI (62-5710 SUB A> C1.96A-1056) ?

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SUPERVISOR.-~------.
ATTEl\1! ION:
rEWARK (196A-7_5!) ROUT.INE
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TELETYPE:
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TELEPHONIC CONSE.NSUAL r10NITORINGS ON OCTOS.ER 31, 1982
AID. NOVEMBER 3, 1981 WERE CONDUCTED BY NE\VARK DIVISION.

TELCALL 10
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Memorandum
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5/6/82_.
/sARKIS' SOGH.ANALIAN
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The originai Subpoema,, wi~h the return ,portion .completed,
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f:i.~Y 13 1982
UNITED STATES DISTRICT COURT

UNtTED STATES OF AMERICA
v.
SARI(I S G. SOGHANALIAN
PRE-PLEA AGREEMENT
COMES NOW the United States of America, through the
undersigned Assistant United States Attorney, the defendant,
sar~is
G. Soghanalian, and his attorneys, Gerald F. Richman, Esq.
and Warren L. Mi_ller, Esq., and do hereby enter into and f_ile the
following pre-plea agreement:
1.
The defendant, Sarkis G. Soghanalian, agrees that
he will enter a plea of guilty, pursuant to United States v.

Alford, 400
u.s.
25(1970), to one count in the indictment fiJed
in the above-styled case charging a violation of Title 18, United

States Code, 134\--the specific
coun~te
determined and
agreed to prior to the entry of said plea of guilty.

2.
The United States of America agrees that it will
dismiss with prejudice the remaining counts of the indictment

fi_led in the above-styled cause at the time of the sentencing.
3.
The United States of America agrees that it will
inform the Court at the time of the plea and at sentencing and
will infox:m the Court's probation of_f_ice that it affirmatively
recommends that the defendant receive a sentence of probation
with no incarceration.
The United States of America further
agrees that at the time of sentencing it will specifically waive

'
its right of allocution except to refute or correct any incorrect
(~
or misle.ading statements subi:ti tted by, or on_ the be_h alf of the
Defendant..
Ame~ica SJ'eci_ficall~ .reserVe~
Tl)e united St_ates of
the right, however, to inform the Court's probation off_ice of the

f _a cts o_f the
offe~se
set- forth. it:t the. above-styled indictment and
tl_le defendant s I'art_icipation the_rei_n.

4'.
'I'h~
the _parties. a s a n
a nd is
expressl~
~cceptin~
the
plea is being entered

~erican
. ~nto
.a nd con.s idered by
Bax: Associ_a tion type_ !'lea
a~reement
.co nditioned upon the court approving a n_d
~<?.l.lowin~
.conditions , of the .plea:
t}le Court. wili. not impose any term. of
' (1)
i _ncarcera tion_ uI'on the defendant and will

'_impose a sentence of' probat_ion:
t _h e Court- wi-ll
( 2}
ente~
as pa.rt of .its fi_mil_
judgment in this ca se a finding . that. the Court:

_recommends a51a.i _n st deportation of the
-defendant.
' In the _e vent: tl_le Court refuses. to a pprove a nd acce!'t the_ a bove.
conditi9ns of the
_!'l~a,
the
defendan~
shall be entitled to
withdraw his !'lea without prejud_ice a nd this a~ree~ent shall be

considered null. and. void and
th~
_plea .vacated.
~e
Court Is
determin_a tion of whether or not- to a pprove. a nd a cce!'t: the

conditi9ns of tbi.s !'lea shall. be made after the Court has
. x:eviewed
the - Presentenc~ Investigat~on
5.
District of
The United. St.ates

F}o~ida
Report .
~t.tox::neys
Of_;ice for the Southern
agrees that -tl_le United States of Ar.lerica
shall respqnd t9 any inqu_i_ries by tbe -Court, the probatiqn ..of.fice

.
or any appropriate governmental entity on_.tbe issue of the
'
Defendant's immigration. status that it affirmatively recommends

that the defendant not be deported from the United States as a
result of the plea of guilty entered in accordance with paragraph
one (1) above.
[6.
The defendant,
sa~kis
G. Soghananlian, agrees to
make rest_itution in the amount of $l,l53 1 590.within nine (9) months

from the date of his plea.
Senten~in
shall
~ ~~ jA
~- The Un1ted States Attorney dr the Sout~rn D1str1ct
tution is made by
th~ defendantj
occur after resti-
to
.k
of Florida- agrees to advise the United States Department of st-a te

or any other governmental entity or any foreign governmenta_l
entity or any persons that it has no interest in the weapons owned
by Avitexti_l Company, the defendant, or any agent of the defendant,
that are in Portugal and are the subject of a judicial lien by
~ MJ :/&t4M rJ. ~ ~tt~:-\ ~

agreem~o~~s~e~terla
the Portugese Government]

8.
No other
into except as expressly set forth in writing in this pre-plea

agreement.
Respectful_ly submitted,
S-TANLEY MARCUS
uNI~ED S'l'ATES
~#{:_
GERALD F. RICHMAN, ESQ. ~
WA~
ATTORNEY
..
O.t of trnserlptlon
k1ay 5 1 19 8 2
~
~llumrich Arms Corporation,
West Hurle , New torR, was appr1sed o the identity of the
interviewing Agent and thereafter served with a subpoena :from the
Southern District of Flori~- 81-340-CR-JE, such subpoena
conunanding the presence of
n May 17, 1982,, at 9:30AM, at
the u. s. District Court .for t e southern District of Florida,
Miami, Florida, to testify in t~ of the United States vs.
SOGHANALIAN, further commandingl_____jto bring with him all
original documents, correspondence, etc., with SARKIS SOGl~NALIAN

and United !I'rade .International-.
b6
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1
pccepted ~ervice of the subpoena, stating that
he had several days previous been teleplhonical:ly .contacted by
an .Agent of the Federal Bureau of -Investigation, .Miami, Florida,
Office who advised that trial'in the above matter had been
delfve~ unt'l May 24, 19~2, thus necessitating ~ppropriate change
for_ _
_appearance in District Court in Miami, Florida,
effect1ve that later date. I
btated that he fully intends to
comply with the demands of the subpoena which he received a copy
of, signaturing the original appropriately.
c:
The interviewing Agent ~dvised

lthat should he'
have any questions ~oncerning compliance withtbe subpoena: he
should conta~t Assistant United States AttorneyL
~
_
Southern District of Florida, 155 South Miami A~v~e~n~u~e~,-.M~1~a~m~1',----~
.Florida, I
I
'
:,$.-
(Ulster County)
MI 196A-1056
-Ot60
~_'_n_~....,s::::::, N~~:::: ,_F'_.._. .:.l.t.:. J.~J-:sz. : "-A- -2_9_6- -
_4_L_J_O-LQ_2_ _ _
'fl'lls c:~oc,,;,...n,~ontlns Mltl'let rtcoi'I'H'I'Iet'l4tl01'1s 1\or ..co~rvsi,o.. s of tM

It n<l Its COI'IttnU re ~t to 1>e c:hstril>lltt<l ~lltsi<lt )'OVf gt1'1Y,
b6
b7C
1'~1. It is tt>e orot>rty ~f tt>e I'Brn<l ~ ol'lt<l to yovr ~gel'lcY:
. I
TRANSMIT
FBI
PRECEDENCE:
VIA~
0 Immediate
Teletype
0 Facsimile
0------
Q.Pdority
0 Routine
CLASSIFICATION:
Cl TOP SECRET
Cl SECRET
0 CONFIDENTIAL
C1 UNCLAS .EFT 0
0 UNCLAS
Date
AIRTEL
May 6,
1982
----------------------------------------------------TO:
~AC, MIAMI (196A-1056)
I . ..
'FROM:
~Vt~~C,
SUBJECT:
ALBANY (196A-296) (RUC)
SARKIS GARABET SOGHANALIAN,.
~:::,~:~J;:~~~T~~ternational;
(00: ALBANY)
b7
Re Miami airtel to Albany, 4/23/82.
ex;cut:d I
Enclosed for Miami is the original, returr

subpoena provided in referenced airtel to Albany for
Numrich Arms Corporation, West Hurley, New York; oriTl.na
_copy of FD-302 regarding service of that subpoena on_
an one
14/30/82.
With the enclosed, Albany considers this matter RUC'd

to Miami.
~iami
~-Albany
(Encs 3 ~
~)
(\ -~U! ;l~\
TAD:jvd
(f)
MAY 14 1982
6
Approved: -~------
Transmitted~:--:--:---~-:--<Number)
(Ti~X~e)
~-
'lf<CV. 3-$771
flOE:nAL BUR(I\U OF INVCSTIGI\TION
5/3/82
Olt of trnsc:rlptlon _ _ _ _ _ _ __
r-------~~~--~-~~----~---------~-~~~~----_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-_-~~~telephone
b6
b7C
IL._ _ _ _ _.Jiadviscd as follows:-
lie was furnished a copy of <1 subpocnn cornmandinq him

to appear in u.s. District Court for the southern District of
rlorida, U.S. Post Office and Courthouse Building, Room 346,
300 N.E. 1st Avenue, Miami, F.lori<la, on the 17th day of. ~1ay, 1982,
,, t 9 :- 3 0 a . m
b
I
1'1 ll'H' .,,., .. , ''"''"1\ nt-1th#t ft'\.,~lhUt.tti~S~luua\ nu1 \.Uf\\h.I\OH\
1 .. rtIU t.onttl($1
re
fW\ tow
d\tllo\.~tc(J u"~~Ml-f
L,f
U~
b7C
1 151
y(J.\It vfrt<,.y.
...
'.,
..
. I
i
FEDERAl BUREAU OF INVESTIGATION
'5/11/82, .
Oate of l'-ilserlptlo~..;.;--.;..---~---;;....._.;....
~~~~--r-------~----~~--~Cabin John,
Maryland, telephone
was 'contacted at her:place
of employment, Deci~s~1o~n--a-n~~Design, Suite 600, 8400 Westpark
Drive, telephone 821-2828, and:advisedl,as .follows:
b7C
.
She was fw;'~ished a. copy, C)f -a subpoena commanding
:her to appear in the u.s. DistrictCourt for the Southern
.District of Florida located at u.s. Post Offi'ce and Courthouse
Building, Room 346, 300 N.E. lst Avenue, .Miami, 'Florida .c;m
May 17, 1982 at 9:30a.m
.She
this subpoena
directed, and
United States
and telephone
given.
'
stated that she had some questions regarding

and whether or notshe was able to appear as
stated that shewould be ,in contactwith the
Attorney, Miami, Fiorida, whose name,. address
number appearedon 'the subpoena whichshe:was
5/11/82
1nvestl91t1on on
>t; t
~--------~~~~s_
S.~?-1
'
McLean, virginia
.BA 196A-439
_,__/'P'I'J""G.,...,.rJ,...,....,.,..Or.;S,.6..;..~~(,3
~------------------File .;..-
______,
b6
..Jr:j_m
_ _.___._____eat <1''''<~--
, b)'_;.;_,......;;.L.___,,.,.....________________
5/11/82
.....----------.;..._--..-.....
<1,
'TI'Iis Cle>~utnent C9f'ltilns neltl\et' ~e~o..,.,.,en<litlons not cof'lcluslons of the FSI,It Is the .Pt'OI)ett)' of the FSI n<l fs 101ne<1 to Y04Jr 19encv:
.It n<l Its contents''' not to t>e disttlbute<l outside your IQen,y.
b7c
Memorandum
To
SAC 1 MIAMI
.e
(196A-1056)
JJ,~' ACTING SAC, BALTIMORE
(196A-439)
Da.te
(SQ. 7)
5/11/82
-:RUC-
$u.bjectJSARKIS GARABE'l' SOGHANALIAN

dba U:~ ted 'l'rade International;
~.........---.-.-......---==!~- VIC'l'IM
'
FBW;
; .I'l'SP
b6
b7C
(00: MM)
Re.Miami airtel to Albany, 4/22/82.

Enclosed for the.Miarni Division is the original
of two subpoenas furnished to the Baltimore Division in
referenc~d communication, the original and one copy of
two {2) FD-302s regarding service of these subpoenas, .and
agent s rough draft notes.
....
Since no additional investigation appears to remain
in this matter, case is considered RUC.
CD- Miami
(Enc. 7
1 - Baltimore
WLK:mjm
fJU/
(3)
b6
b'/C
~A-36
<Rev. 5-2Zf.78)
FBI
CLASSIFICATION:
0 TOP SECRET
0 SECRET
0 CONFIDENT lA L
0 UNCLAS E F T 0
0 UNCLAS
Date __s_/_1_1_/_82_ _-;
PRECEDENCE:
O Immediate
D Priority
0 Routine
',TRANSMIT VIA:
0 Teletype
0 Facsimile
t:5 AIRTEL
----------------------------------------------------SAC, HIAMI (l96A-1056)

TO:
FROM:
SAC, NEWARK -{l96A-751)
(RUC)
(C-5}
GARABET SOGHANALIAN,
International;
r-L>"~.......,..~~~o.......otrade
VICTIM
FBW;
MAIL FRAUD;
ITSP
00: MIAUI.
, bo
b7C
F.Fclosed fo~ M~ami ~s original sub:oena,
directed to
Plainfield, New Jersey,or
Florida, Hiami, Florida.
e Southern Dis ric of
on 5/10/82. copy of enclosed subpoena was
served onl
As there are no leads remaining, this case

will be RUC'd.
(i)- Miami (Enc. 1)

1 - Newark
EHM/cwrn
MAY 15 1982
(3)
b6
b7C
Transmitted
-----=---<Number)
<Time)
Per------

-X
AIRTEL
5/ll/82
'l'O~
.SAC, .MIAMI (196A-l056)
FROM:
.SAC, NEWARK .(l9eiA-751')
(RUC)
(C-5)
J~RKIS
GARABE'l' SOGHANALJ:AN,
dba united Tfade International#
I
VICTIM
FBW1
MAIL FM.UD7
.I'l'SP ~
00: MTAMI .-
b6
Enclosed
tq
~or
Miami is ori:inal
Plainfield, New Jersey, ~or

Florida, Miami, ~~orida.
dir~cted
the sou nern .ots rlct
On '5/10/82. copy of
b7C
sub~ena,
dt
was
~closed .su~poena
served onL..I____________Jj
As there are no leads remaining, this case

will be .RUC'.d
. I1~JJ.,.) o,:;G - _s, ~~~

ED-
Miami (Enc:. 1)
1 -Newark
"EHM/cwm
(3)
'.1'
,>
-~
'~o-'
t,
r~. ~
----
~---*"~
~~~ ~I
,.
,[~
Memorandum
To
Fro=
~I(Z,t'~ (cJtliA-lo~~JCfj
rA
Date
1(/to[n__
b6
b7C
I
I
Subject:
)~ ~f;.c.~,
fD& lh1i:JJ}t.:cRPJ
-Fn-J
1,
~- .,
..
_J~~a....:..;:;.~--.-.l.G~ '
o4'{'q''~!F.n_l\'DEXED
~l!:aal.'"" ~.r~.n~
tAAY 1Y '!~d~
~-~'6;.;.,1.-.-I-.~
,.
,,
,:~
....
'
'
'
Assistant,Attorney General .
crtminal Division
(Attn~
Mr-. Pav.id M. SimQnson)
'
.May 71 1982
Assistant Director
Records Management Division
'!
'
SARKIS -GARABET SOGHANALIAN

:ELECTRONIC SURVEILLANCE
Reference is made to your ~~orandum dated

March 2 1 :198 2, .requesting electron'ic surveil:lance information
.pertaining to Sarkis Garabet . Soghanalian ;or the period
of January '1, 19771 to 'February 251 1982.
On the basis of the attached ~dentif~ing data
provided by the Department concerning this ~ndividual; records
pertaining to F.BI elect.ronic :surveil l.anee .have been searched
. to the extent that such records have been indexed.
~xcept as set :forth .herein, no lndek referenq~s were

.
located indicating Sarkis Garabet.soghanalian was the target of
electronic ~urveillance1 was monitored by an electronic ~evice
of the F.BI; or was known to 'have owned, -leased-, or licensed
premises on which the FBI maintained an e~ectronic . survell'lance.
!l'he .Miami Field Of.fice of the F.BI has advised that
the fol'lowing information is 'the su~ject. of -a .Protective order
.i ssued on January 28, 1.:982, by United States Di~tr-ict Judge
Joe Eaton, southern District of Flo.rida. 'l'he :intent o.f
..
this order is to preclude disclosure of electronic :surve.illance
material not being introduced or used as .evidence :in the
prosecution of sar'kis Garabet Soghanalian .in the Southern
oistric't of F,lorida_.
I'
I
'
'
'
1 - SAC~ Miami .
(At-t n:
'
ELSUR
coordinator_) (Detached)
'i
...
' .-
,... .
''
..
'
.Assistant Attornoy General
Crimina:l -D-ivision
.,
.
'
. ,- Sarkis Oarabet .soghana-lian was consensually ~nitored

by tbe Newark Field Office on October 31, 1980, and nov~r 3,
l9SO, by -I~cms of a tol~pbcnc recordin9 device. Apr;>roval for
ti:tese.~nitorin$f:a l-IAS 91:anted on oa.tober..31,, 1980, by t.he
'special .Agent in Charge of -thG ltewark -Field office. soghann.lian
was also conson$Ual1y
''
~onito~edby
the Miami Field Offiee on

Noile!nhe.i' 4, l.9St), by 1neans .:of .a body recorder. ~ergency app-roval
for tho use of a body recorder was granted on November 3, ~980,
'
1'
by an appropriate F.Bl.UQ .official. J.rhis- appX"Oval was reaffitmed

on 1ioverlber lOt 19801 ;for a perioa of thfrty days by Philip l'lilens.,
'
Director~
Office of
~nforcement
Operations, United States
. l)epart:l:tient of Justioe4
t~ppropriate ~terial regarding the above., o:.-onitorings

-has been previously .furnished the _requesting .attorney by
the ~lia..."''i Office of the Fax~
.'
''
..,
.I
I~
'
'
, 'I
.,
'
-2-
: -,
.F0-302 (REV, 3877) '
'
-.1
1
On Ma_y :7, .:1982, Mr

INorthern
Virginia :Printers, "Incorporated, 820 .North Pollard Street,
.Arlington; 'VirgiJ_~ia, waS servr a ::ral ~:d ~:v
subpoena by Spec1al Agent (SAt
____
__
__
which had been issued on Apri ,8,
, at
e On1 ed
Stat.es District Court for the Southern District of F1or-ida
at Miami, Florida_, requiring his appearance ,in that court
...on May _lq, -1982, -at 9:'30 .a.m.
b6
b7C
.;
rnYe$t~tiOn
on_S...;/;..7...;/;..8_.2_____
ArL-ington,. vir9inia
s~r-------___..-1e~~kar
. 'Miami '196A-1056-.~"a
Fr.. 1 Alexa~dria 196A-283
' '
b6
b7C
5/ll/82
by---!::o==========='--~~----.Da~ ditaftd--~------'
'
, I
'Thl$ doeu~t e~il'l$ ncithtt feeQt'l'lmenc:lationt .no( ~1u$ions t>f the 'F8!- Is lhe ~rty Of the FBI nd
1
I ~ .a'n4 'iU C?I'Ittnts ~ none> be dl~trlJ:,~ outs~ you,r ~y,
'
. .
..
Is
~t'leQ to your ~:
"
L
Fo.302 (1\EV. 3-8-:77)
FEDERAl BUREAU OF INVESTIGATION
'1
_,
1;
''
Date of
' '
tr~tipt!Qn
5 I 12 I 8 2
lo
on May
1982,
Northern Virginia .Printers, _820 North Pollard Street,
Arlington, Virginia, was s:r,:d a :d;~ ra'l Grfnd Jury subpoena
by Special Agent lSA)I
~ ~
.,..__ _
_which had been
issued o~ Apri~,8, 1982, a t e Un1te States District Court .
.for :the southern District of Florida at .Miami, F-lorida,
requiring his appearance in that court on May 17, .1982,
at 9: 30 a.m.
'
b
b
b
'
' ,
Miami '196A-:1056 ~ ~fo1
lt1Ve$ti9a~i0n
on
_s...J_7...J_8_2_____ '" _Ar...;__-1_1_.n...;s;;;,.t_o_n_,_v....i_r..;;;g_i_n_i_a_ _ _ ~~,,,.......,. Alexandr ia l96A-2 83
r'4ir
py,.!'_...;-...!:=::::;:======::::::===-------sAl
. '
.!
b6
b7C
5/.~l/82
Date -dt~taW<:I-----------
"''hi$ ~utnent.eontans ~ithet :r~enc:Jatlons nQr wnelvsio!'l$ of the FSI. ft is the J)roptrty .of .the ~81 and is ~ JO ~r ncy;
~and iU ~ttnts .,.. not to 'be di$~ribvted ;ou~ yQVI' gency.
' .
<
-1
'
On May 7,, 1982 "----____,,....-......,.,.,,.......,.-"""'="'"~--=-~---=----...,.1

1
Armand. a~e Virginia, ~as :::ye:~ a ::d:ra~ :rtnd. Jury subpoena
~y Spec1al Agent (SA)_
--~ _
__ ~ _ ~--wh1ch had
:been .issued on April 1 .I
,
t t
n1 e
tates District
Court for the Southern District of Florida at Miami, Florida,
requiring his appearance in that court on May 17, 1982 1
at 9:30 a.m.
b6
b7C
b3
,,
. ,
Virsinia
5/7/82
lnvesti.Qation on- - - - - - - - - - : - - - - - , ,;rl~------------F.II~
kar
Miami :196A-.l056-~70
A1.exandr-ia l..96A-283
I---------5/ll/82
~---~--------------=--===-==L-----------Da~d~a~---------~----~-.
~L
'
l1
Jh$ .dw'nen.t ~onlbins neithenecommenclatioO$ nor lie~on$ <>I the fBI. 1\ i'$ the property Qf the F81 nd i'$ lo~~ -~~ YQvt ~;.
it anct i~ eootenu _.are not to be~ ~tr~ outs1<fe yout ~ncy,
'
,.
'
.
;!!'
.,'''
'
' ~~
'
b6
b7C
FEDERAl. BUREAU OF INVESTIGATION
oate ot
,l
~ra~rir>tiOn - 5
.-.-l___l_2_1_S_2_ __
. On .May 71 .1982
.R and D Rubber stamp Comp uy, Incorpoxatea, IW'' coxumbia
Pike, Annandale, Virginia, was
Fede:al
IJ'ury
subpoena 'by Special Agent (SA)I
~
I
which had been issued on April 1 ~ 2_1 at t e Unl.te States
District Court for the Southern District .of Florida at
-Miami., .Florida, 'requi-ring his appearance in that court on
May "17, 1982, at 9:30 a.m.
:er;: a
Miami l96A-l056 -~1/

Alexandr-ia 196A-283 .
~ ~t .~nnand~le,
5/7/82
.
.I1We$t~atoon
OI'l _ _ _ _ _ _ _<r_/~=-
SAI
Gran:
b6
b7C
b3
ft.e II
~-ar
5/11/.82
bY-----------------~-------0~ dle~Wd-~---------
..
Thi$ du~n'C C.Qntains ~ilher l~~ion$ not ~lu$ion$ Of~- FBI. 1t 1$ t~ prQperty <>f t~ FBI ,anc;l i$ loaned to
no:t to be 41$ttiQu\ed .QUtslc:fe yot.11 ~Y
. 'i:i .and \'t$ .eont'"'t$ art

,
,t
lei
...
'(OlJt ~;
,,
'
'~
b6
b7C
Air.tel
5/12/82
Director, F.BI
SAC , lUar.~i
(Attn: :CLSUR
Coordin~to.r)
}!LSUR;
vSARKIS "GARABET SOGllANALIAN
ReDuatrtel to HH dated '3/18/.82 and f.!H airtel to

BU .dated 4/6/82; :su teletypes to l1l-'1 dated 4/23/82 and 5/3/82;
HH
teletypes to
11u
dated -4/26/82 and 5/.6/82 ..
.Enclosed .for MH is one copy of a ntenorandun)"'

prepared at FBIHO for the De1>arti:1.ent of Justice ,in responsc
to the captioned inguiry.
-ln reHHairtel of 4/6/8.2 r.t.'i advised :that
copies of .all pertinent docur.,ents relating to captioned
search had been .furnished to the reguestlng attorney.
!i.'he enclosed ar:e furnished to HH for inforr.:tatio.n
purposes only.
Enclosure (l)
'~D-36
(Rev. 5-22-78)
TRANSMIT VIA:
'PRECEDENCE:
0 Teletype
0 r<'acsimile
X) . Airtel
cj Immediate
0 PJior:ity
0 Routine
. -- -.:::.::~
~;
~,'~SAC,
FBI
CLASSIFICATION:
.CJ TOP SECRET
0 SECRET
0 CONFIDENTIAL
0 .UNCLAS E'F T 0
0 UNCLAS
Date _ _s_/_1_4...;./_8_2_--i
:~~~ ~ ;1:::-~:::)------------------ ~
-----;- --1
i\LEXANDRIA (l96A-283) .(RiiC)
SARKIS GARABET SOGHANALIAN,
dha UNITED TRADE INTERNATIONAL;

1- VICTIM
IL...:F::-:B::::W-=-;~M':':F::-;---:I:-::::!TSP
(00: MIAMI)
J:.:6
Re Miami airtei' to Albany, 4/23/82.

sybpoenas
I:
]:;7
]:;3
Enclosed fof ~iami are ;~; ;amnl;ted ar;'ain:J

ser~edupon_
___ _
_
_
_
pnd~~~~~~----~~~o~n--s~~g--.--A~.~s~o~e~n~c~o~s~e~~f~o~r~~
M1ami are the original and one copy of the FD-302's re(lecting
service of ~hose subpoenas.
Inasmuch as no further investigation remains
outstanding, Alexandria considers the matter RUC.
'(VMiami (Enc 12) {;rf

2-Alexandria
(l-l96A-283)
(1-66-384 Sub C)
FCK:kar
(4)
Approved:---------
b6
b7C
...
X Airtel
5/:14/82
SAC, MIAMI (l96A--l056)
TO:
fRO'l-1: ,
SAC, ALEXANDRIA (196A-283)
(ROC)
V ~ARKIS TRADE
I:::
___ ---- _1~:
(00: MIAMI)
;
GARABET SOGHANALIAN 1
TE:
INTERNATIONAL;
VICTIM
;
'l'SP
be
b "!C
b3
co ' leted or i inal
Inasmuch as no :further investigation remains

outstanding, Alexandria considers the matter RUC
...
r@Miaml (Enc 12)

~Alexandria
(l:.l96A-283)
(1-66-384 Sub C)
FCK:kar
(4)
q ~A ~
EIJ\CI-"ED .
)OS6 .... ;l?3

i\rEXEO .
:..c~:wzc~r:lr~ -~-~
c
-~
MAY 1.9 1982
- --- - - - - - - - - - - - - - - - - - - ' - - - - - - - - - - - - - - - : . 1
'I
..
f"0:30:l (REVo~$77)
. .
,.
Oat of tflnS(;rfl>tlon, _;5/13/82

_ _ _ _ _....__ _
bE
I
IAssoc!ate Counsel, irving
Trust 9o~~p~a~n~y~,--i~~w~a~~~i~s~t~r~e~e~t~, New:ork. New vork accepted
service of a subpoena on behalf ofL
h 7C
'I
.rnvesu9~uo"' on _ _
S;,.,/_l_0.../_8_2_____.,1 _ __;N::.:..;:;e.;.:.w-=Y:.::o~r:.:k;.J,r-:'N:.:..e::.w~.::.Y.;::o:.::r~k~_.,,,, .riX
12 6A-13 8 5
I CJ~IJ- lbS,& --Gt7l(
'1J_jc
..
SCI
5/J.l/82 '
b6
bY---L.------------~.....J -':'~oe..;;---------Oate <llctated--=::.c._..=,:::::.c,_~:::----.----- b 7 C
y,,sesocur'Mtlt col'ltaltls neotller ecol'l'lf'ne,d~tlon~ :nor to,trus>o,s of the Far.i It Is th' t>roJ)erty of tl'\e f'~lan<SIS IQal'ld lo your t"cY:
ot and Its conte,ts are I'IOt to t>e <listrit>~.>te<l outsl(le you~ ~ncy.
....'
F[)-36 (Rev. 5-22-78)
FB1
TRANSMIT VIA:
PRECEDENCE:
0 Teletype
0 Facsimile
(XJ AIRTEL
0 I!Xlmediate
0 Priority
0 Routine
CLASSIFICATION:
0 TOP SECRET
0 SECRET
Cl CONFIDENTIAL
0 UNCLAS E F T 0
0 UNCLAS
Date
5/13/82
----------------------------------------------------TO
FROM
~~
SUBJECT:

AC, SALT -LAKE CITX (196A-322) (RUC)
SARKIS GARABET SOGHANA!;IAN, dba
UNITED TRADE INTERNATIONAL;
- VICTIM;
~T!"''':'r':""""'':n'.O"':;:---"''""'s P
00:
MIAMI

tel call to Miami I 5/.10/82.
San Antonio
Enclosed
for the Miami Division is the
original c.F'-'--........-~=~==-=::.......:l.~s~s~u~e~d~b!.L..-~t~h~e~s~o~u~t:!!h~e~r::n~D~i~st~r~l.~c::.,:t~o~f::..,
-Florida t
For the information of the Miami Division] the
enclosed subpo~na was served on_
_on May 10,
1982. In compl:iance with instructions from case agent in the
Miami Division, the datel
lis to report to
testify in Miami, Florida was changed .from May 17 to May 241
1982.
b6
b7c
Ladvisea that she .has been unava_ilable

.for the servl.ce of tn1.s su poena in view of the fact that she
~een :in Miami 1 -Florida and returned to her home in I
I
L_____J>n
(Y-
5 /.9 I 8 2
Miami (Enc. 1)
-1 - Salt Lake City
c;{..
RKG:gf
(3)
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Approved: - - - - - - - -
.,
..
FD-36 <Rev. 5-22-78)

.,.
TRANSMIT VIA:
FBI
PRECEDENCE:
Cl Teletype
0 Facsimile
I,
,.
I'
I
CLASSIFICATION:
Cl TOP SECRET
CJ Immediate
CJ Priority
0 Routine
'AIRi'BL
~
0
SECRET
CONFIDENTIAL
Cl UNCLAS E F T 0
C) UNCLAS
Date
MAY 1 8 1982
-~---------------------------------------------------
'lO:
FROM:
~'fh.z/J:Rc,
SUBJECT:
(P)
NEW YORK (196A-1385) .(ROC) '(M-3)
ARKIS
GARABE~OGHANALIAN
b6
INTERNATIONAL
VICTIM
~RADE
b7C ,
.,;.
MF;
ITSP
,(OO:MM)
ReMMairtel to'NY, 4/23/82.

Enclosed for MM is one original executed
supboena, one original and three copies of .an 'FD-302
reflecting service of that subpoena.
Miami (Encls.
1-New 'York
5)0~
'J'. .
GMH:jjc
'(4)
..
_______________.____________________
-p~========~~~~~~
b6
b7C
Approved: - - - - - - - - - -
Transmitted._,..,._~--~-'!"""~-
<Number>
<Time)
Per _ _..,_ __
1\1emorandum :~
'
.,
To
From
"
-Dat~
5/6/8_2
sAl!--_ _ _ ___.
SARKIS'GARABETSOGHANALiAN:
FBW.
i:l6 .
(00:. MIAMI)
Request .paymenb
:07C
.from
FSA
of .$255-. 00. tol
LMi_ai:ni, F~ot xaa,

L......:::f:-o-r--=-t-r.:-"a_n_s_'=""l-a-:-t...-in-g-.s""""'e_r_v_i.-c..,. ._e,. . _-:p-e-r""""f=-o_r_i:n_e....,d,.........
_~,....r.,....,~om 5 I 3-6 I 82 .
Service_ consisted!of translation from Greek to'Engl~sh
of a 17.. page if?.c;orpor-ation doc_::~ent to 'be useq ~t trial
in -instant- matter,. 5/24/8~. FBIHO (see serial 124). :~nd
Miami in-house .t~anslatorL
Fere unable to
accomplish. t;-ansl~tiori..
~ate was computed at .17 ~pages transl~te<;li
-tr-anscribed and typed at $1$-.00 pei: page=$255 .00.
Jm_i96A-1056
'IA..At9AL: nlb
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SERJAU"
JUL
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frR ~M
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JUN 82
Y:"1 DI q~CTOR .F'B I
TO F8 I
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P.OUT.I NE
nr
.PinR,1ATI0~1AL, ~lC; ~. .1_ _ _____.1..
VI CTI '1_; FB ~J; :Mr;
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00: MIA''1l
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ROM~ AIRT~L
L~G
AT
DATSD OCTOBSR
1~,
19E2.
Ro~n: P.~PORTt:O:
I
l~FORMATIO~ R~C~IV~D
E~BAS~Y
SOURCrs
I~
JUNE 3, 1992, FROM AMERICAN

I
REV~AL
A"KARA, TURKEY,
' ~OLLO'~.I~'G T~XT OF' A NEl~S I1EM APPEARED

"~ILLI
Yt>T" oal
TH~
~10~1DAY, ~AY
!HAT THE
N~'vSPAP~R
HI 1HE
3J, JS32:
Bnt:'PJG 707 .WHICH LANor.o AT i!:SE\iBOGA
Al~PO~!
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TP~ -PLil.~l:-
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TO UNIT;:D TRADS INTt:RNATIO"J, A
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PAGr." T',!O _Dt" HQ 11.37
u.s
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WILL
U~lCLAS
O~Jr.: CLAI~1S
,IF' "0
B~ COqSID~R~D
IT
rs
POSSIBL~
TH~ D~~
OF
l~T~Rgsr I~
A~lY
ACTHW
AS
PL~-~~
THS
ABA~DO~ED
AT
UliTIL JU!'F.
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1$82,
CUSTO~S.
THAT THi ABOVE AlRCRAFT IS lDSNTICAL TO, ,

THIS
~ATTSR A~D
15
BEING PPOVlDE FOR
nr.;r.:r1!DAPPROPRIATf: BY 00.
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0037
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fLOYD PEARSON STEWART RICHMAN GREER & WElL
fOROP'$$10NAI. AS_S_OCIATION
c:.,~tiOIN
II!Oet~T ~novo
ULI:N
"AV><. .. tAII!SON
"'OS"1
LA,.._Y $, $TtWAIIt'l'
Gli'IALO ' ~~'"''"'"'"

ALAN G.Gtt
KENNETH J.WtiL
e~T"'A CLAHtt Ut
,JOHN M.e.UMSAUG'"'
, STI:.... tN N. ZA11
ANOtw J, M I "'AIJITO
.JAMt$ e.TI\.GioiMAN,.J~.
$. OANit~ l"ON1:
8~Ut A.CAAISTtNStN
GA"Y O.P'OX
e.
GALT, XIX
OAVtO W. 81ANCHI ,
CHAIOILlS C.IJUK(~,XI:r
Htlit~N ,J,ftV$$0MANN0
"'OSC,..TO MA~TONCZ
WILLIAM C:. KI:A,..ON
.JAM tS lit. GAILCY
ROS"''1' C:. eltGtN
H0WA"0 ... G"''$$
.fHOMA$ MttKS CloiA~LtS H.JOHN$0"
USLI( .J.l..OTf
I'ATiitiCII J.. NtWTO"
ONt 81$C:AYNt TOWtl't

TWC:NTYFirTH
".OOR
MIAMI, FLORIDA 3313118G8_

ARC:A COOt 30S
U:LtPttONC: -3710_241
SROWARO .S2342_97
.... 1\.l..UOI:,WALKl"'
Septeriber '23,. 1982
s_eon o. s'"' tfTALL

F~ori& 33137
l-1iami,
-~L.------1
bC
.After our_ recent_ conversation nceming the .release of o:Jtoin docunents :'
custody of .the.FBI, ,I have _forwarded the enclosed letter UJ
1of
the u.s. At~mey's Office for his attention.
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ca
_
.
_I have: also enclosed a.copy of a letter fran Peat, Mal:wick, Mitchell & Co.
outli.n.ylg the docuren~: which I have :reqUested
. As I rrentianed in Icy' letter
+-~J ~da:wreciate i~
if
:YQU'and
he_'W:)uld get- together and ca:oo~tion. as to the procedure for

obtaining ~ outlined rraterial.
My .thanks.for _:YOur-attention to this.rratter.
b6
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'VOI/tay
_rnclos\lre
~SW:
~ .''1 ll(t/J
LAW OFFICC.S
FLOYD PEARSON STEWART RICHMAN GREER E. WElL

,.~O'CSSIONA'- A$$0(;1ATION
otO ..(In
~. flOTO
AY H. lt'CARSON
'-AitltY $.$TitWAJtT
G~lltAlD ~.-6(: NAN
...
AI.AN O.Gitttlt
"tNNETH .,I,W[I~
OtltTHA (;~Aiott \.[.It
.JOHN M.eltUI<8AUGN
ST(JOH[N N, ZAC:K
ANOottW .,I, MlltA81TO
JAM[$ 8.fi\.GHMAN,.Jit,
$, 0ANI(\. JOON(:It
81tU(: A.(: .. lti$T[N$-[N
GAAY o.~ox
H\.1:01
C , ~lt(IOIN
otltt e,GA\.T,m
OAV.O W. al..t.NCMI
<:HAotu:s c.evottot,m
H[ltMAN .,1, ltU$$0MANN0
ltOetltTO MAIOITINU
WIU,IAM (:,HtAitON
.,lAMES lt,GAJU;I'
ltOOtiiT (;,81[GtN
"OWAitO I',GitOSS
THOMA$ MElt"$
CHAitUS H,,JOHN$ON
US\.1[ ..1. \.OTr
I'ATitiCK .,1. NEWTON
JOHIUII' [ , WAU<[It
sc:on
ONC 81SCAVNC TOWC:R

TWC:NTYf',TH
MIAMI,
"'-O~IOA
n.OO~
331311888
ARC:A c ooc 305

ttU:-PHONC: 3770.Z41
8-ROWAR.O s z:34t_97
Sept:.areer 231 1982
o.s"'""~"
U.S. Attomey 1s Office

R:x:rn 202B
299 East Broward Boulevard

Fort Iatrlerdale, Florida 33301
b6
b7C
Reference is rrade to our conversaticn of this past week concerning docurents

belonging to U:>.ited T:t:ade International, Inc. and~o
ustx:ies International, Inc.

our conlex:saticn, I contac
t tre FBI pursuant
to yoor suggestion. _
_infonred me that while
_ nay have the
docurents in question, that the auth:>rity fur the release of those docurents
has to care fran you or your office.
'Af:f
Pather than continuing to call back and forth between your office and the
office of the FBI, I ~d appreciate it if you \rould reach sare conclusion
as to the availability of tlx)se docunents.
I have enclosed a letter .f~ Peat, Ma.n.>ick, Mitchell & Co. outlining the
docune.nts being reg:Uested. It is also possible that sareone fran the aceotmtant's
office could go to the FBI's office to review those docurents .if that becares
necessaxy.
I w:>ul.d appreGiate it if yoo w:>uld contact ne at your eax::liest convenience regarding
'V.""e rrust follcw in order to obtain tre requested docuncnts.
the procedur:e which
I look forward to your reply.
b6
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'
L-
,.
;'
.. - . .
'
I~t,Lrwick,MitclJell
i
i
I
Certified Public Acrountants

800 BrickeUAvenue.
&Co
MiAm~ Florida 33131
'$r.; 8 .. 23-170
Floyd, Pearson, Stewart,

Ric_h.man, creer & weu,- P.A.
1. Biscayne .Tower
25th Floor.
Mia~i, FL 33131
b6
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Re :- 'Sarkis Soghanalian
Dea:~L---------'
We. need to have. access to the financiai records o{ United_ rndu.stries.

:International, Inc:.' and trnited .Trade Internadqnai,- rnc. ,: .in order e-o:
l'repare. tax: returns:.:
Si>ecif_ically, as to United :xnd.ustries :xnter_nadona1,_ :Xnc., we: need::
Bank. stateme~tfi, _including the cancell~d checks and deposit
slips,: for account_ 1!678-t;..saoo a~ .1st AmerJc.an Bank. of_ Virginia,:
in the na~e. of "S.ark!s: G.: Soghanalian,- T/A Unit~d rndustr}es-"
f9r. month ending i/30/81, and for 9/30/81 through the: most
recent: lliQnth. availal;>l.: .
.
Check stubs from september i,: J98Q to the. most.. recent. avai.iabie .
Ari.y other financ_ia! record-s pertaining, to the: period from septeX!iber
.1,: _1980 to date.
As t'Q United_ Trade :Xnter_nat!onal,
Inc~::
Bank st-atements_, Jnc1_uding the-c_ancel!ed'.checks: and: deposit. slips,_

{or account_ /Jl07-5.23.;.2 .at: .tiags~il? Bank in_ the: name_ of. United
Trade_ tnt.er_national, Inc., for _the month. ending _1/31/8.1,_ and for
months:- ending 8/31/81_ _through the most. recent a:vailabl.e._
Check stubs f_rom 12/31/80 through the most. recent available.
::rbere 'fJi.ay' also have been. an account_ at_ the_ Southeast: Bank during_,the:
period_ June_ 1980 -: February-l98l.: :n that !s correct, we_ would :need1
all_ bank_ Statements,: cancelled-checks d-eposit_ Sli!>S and.checl( stubs
.on_ that account._
Any- othe~- financial records pertaining to .the l>e.:r:iod_ June_ i. l980 to

date._
We. would-; ap{ireciate_- your -help

to us .
Jn arranging tO:. have these records rJi.ade_ available~
1'hank you._
Very truty_:y_ours.
.
LEB:mi_
Dr
SEARCRED~'~E~~
8ERIALI~~FILED.5-
OCT 2B196?.
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.
;
'
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'
.e
ANDREWS & LUBBERS
LAWYERS
MICHA_1. f', KATZIN 1
t>. o.
C-OUNS__1.
aox 5S:za
2_1501 CAST OAK~NO PARK BOU_LCVAFiO
OCAN ANORWS
RO_BtRT G. ~UBB_tRS, .JR.
.J. OAVIO ~YNCH
CARl. R,
or
PORT .LA'U_DERDAX.E, }Pl.ORIDA 33310
MU_I.~ER
TC_L.PH0N C-3_05) 158_32-541
October 25, _1982
~
Federal Bureau o~ lnvesti.gation '3801 Biscayne BoUlevard
Miami, nor:ida
b6
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which
~etci~l~.~:-~~1;
._ ~l!~~~~:s,:ter s.zas :inned~ : t~~f~~~ies
an
.comtry
se~ civil ~1aa ~
that has oc~ed.
lso had a pr1or connn,_ t. ~e court will I'IIJ"W r:e.:.:

_liest pos_si'Qle dite .an9 I will advise you when
As I pt:eViously advised you by telep~ne, Sogharuilian offered up

$2;000,000 as and for settlem:mt~ at ca:rm;mc_emant of tl::'ial on Jme 21 and_
thereafter has coopletely
defaul~ed
on pa)"trent Q; 1 any mmie_s whatsoever.
tinues to bleat with .the -Probation Oa):,..~:

..JX!tt:t:m!::::n:~.rn._e nt as sorre _innoCent- vi~tim: ,I .~t .wi_
:J
effort tO
~~ong With
r----___...~tFriday afte~1and it _is:xey intentio ~ c'u2 keeping

fully-advise_dix)each .andtevexy aspect Qf this matter.. - . .
L...--------1
We are hopeful that sentencing will noo occur~ very n~ futur:e

.and, .of coux:se, I ~J~<::i ..,.::~ :~uch sentencing. L___Pa.s suggested that
it migh~ be we,ll fo~
also make . appear~ce. at sentencing and
I certa1nly concur. _ _l____ the m:m:m~_ - sentencmg 1s scheduled, it will
be rcy intentiprt to . con~c
d urge tha~ he do make appear_ance be_fore
Judge Eaton.
b6
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At this point .we have but one singular goal and that is to .achieve eaCh
and every sanction of _law against Soghanalian.
;
....!": t
With best regards, I am
'
Sincer:ely yo'Urs,
ANDREWS & llJBBERS 1.
ByiL..__________
n\/jp
____J
'
;Memorandum
-
io
Fr~
...
SAC, MIAMI (196A-iOS6 )' (P)'
6/17/,82
s~.__________,
b6
b7
SARKIS G. joGHANALIAN, d/b/a

-United Trade International;
Sub;t:
::;A~~
(00:
MM
.Date
f .VICTIM
MIAMI)'
Re ;SAC, Miami memoranda dated 2/3/82 and

'"ELSUR MATTERS".
62-5710.c~ptioned
'3/29/8~,
under
Pursuant to.above SAC memoranda, an.ELSUR review. of instant

file was conducted by writer.
A review of the 1-B section. of Instant file- indicated .-one
ELSUR overhear as follows:
'
'
'Bulky Sheet: 1B~6

:corresponding Serial(s) : 116, 52
-bate or overnear: 1174~~~-------------------------~
:Indl.viduals Monitored: I
I
1Sark1.s G. Soghanalian'
.Summary. 'of Serial Cont-,.,.L~...........----------~
on, 11/4/80, .a body recorder was used:'.to record conversations

with all of a~ove individuals.
' 'Re's'ul t's of :In'iti'al ELSUR Check:
Initial' ELSUR cards reflecting above overhear on -11/l(/So
'for .all of .above individuals furnished FBIHQ .via 'Miami air.tel dated
cll/111/80.
b6
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Sub's'egue'rit 'Administrative Action:

Corresponding serials noted:on ~ile bulky-sheet; names of
.above individuals (subjectsofoverhear) noted"on .file'bu~k~ sheet.
~f])-
":!'-
196A-1056:
62-57~o:_"~.
~LLR:mrz
'(2)~ .
JLiL 1 f) 1osz
~
iJ
' ..,
FD-~'~
(R.v. 121~-8-0)
ACCOMPLISHMENT REPORT
($\A)m~ wltlltt> )Q <1aya
TO:
from <!ate or IQCOfTIPf1SI\Inen!)
DIRECTOR. FBI
FROM:
SUBJECT:
'l96A-l056 ]
t:ilAMI
AC,
SARKIS GARABET
SOGHANAL.IAN I
dba United Tr-ade
Internationa_l;
FBW; MF; ITSP
WCC-2
14 Polyg<tiPI\
Aasisliii\Ca
9 lnlomlanl
ln!on'natlon
1 ~- lAO tllv
,...,.
~,.llmlflary
A.
JWJctal , _..
lnfomlaaona
tn<f~lm_.,~
(NUI'IOIIet Of ~tal
t. Atnoto, Loceleo 6
19. Ur\detWoler
Operation
16 .. Show Money
Vsage
1ZO-
V....-1 Invest
MaiYM (V1A)
~. ~0-0. flaotMIOfll, COUI1 o~:ed FO!iell"''' '011111 f - I e Lo11 Praveotef (ffi'l

~01
...u> Type
$vllllllofiMI
Code
CN""''*' of avb~cto)
_1
,,, An-eats
FBI Locates
01monal Summons _ _ __
s
s
s
s
Number Ql $\(lJOCII Of f$1 Alfesll WhO Physocatly Reaatef _

Number Of Slbiacla c1 F81 Alfesta WhO w.,. -"""ed
C. fie lease Of Hooto~o: (NIIIIII>er of Hootageo fleleUeCI)
"~ nnn ihn
s
s
s
s
Clvl Mottara
Nnart Of S..ll
Settlement 01 Aw~
$
tnter J$ A Paymel'lt Here
Svbjeclt Name
0
0
D
l)lamssaJ
AcQUitlal
*"b~ct
(J
0
0
SARKIs
f're~
l)tvors<Ofl
sD
~"" ~~
' flllol Mlclel hoeeu:
Coovlctlofto
ntarconllletioft anf
sentence <!all In epeca at
riQill r - tlatllour
oec;110111 .,.. lnVOivl4. lmlt 10
.,.lour nos! relevant.
FLA.
(VM two letter ..... lbbreVlll~~. 0"1<: Guide. For bample. Tile NOI1hetll0<at~<:t of Texaa .. N~ f)(;
Felon(
~=
Maona as MUI ,,.....ta 11&!0 Qnly )
.....,,.r_
CooviCIIOa
Tille
18
Section
1343
Yra
Col>"
Moe
SIOb,lecfl
*'oopeftded
Yra
Moa
PIObiVOft
Yra
Moa
.5
,.,.
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$
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r~~el
o..~ Cofa 3A
Tnol
2 Name
Suopeftded
Pr.NI
l)verooon
l)am<aa
Acqulttol
COIIviCGOfll.
Enter QOIWICtlon lll4

1entence <Jollln opeca at
nghl. r more lllan lour
aecuona.,. InVOlved, Rml to>

,..
.J
G~RABfPfild so<ffl~ ALtm'
lour .~~
,.Ieven!
0 felony
M..O.
0 ..,_
Yra
Ttaa
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Mo.
, 'robatiolt
Mo.
$
$
0
0
Plea
0
0
felOny
Trial
Sut>)ect J NI!IYle
.,."""
Ooveraoon
Ooamoaaal
AcQU<ttol
CooviCGOfla
Enllteonvict101111l4
eantence Clall In epeca at
right.
r tnO<e """ fQur
MC!Ionl .,. lnVOivef, limR 10

hlour 1n011 relevant.
0
0
Title
CoMicSeeton
Counta
MadlMMI'IOI'
Plea
Tnal
Attacll leldltiOflal IOtMI I riPOI'tlfiO filial Ju<llclal ,oee11 011 lllOia "u """ lubjacta.
entered plea of guilty on 5/13/82 to one count of w~re fraud

(l8USC1343) before USDCJ_ Joe Eat?n ~n 12/3/82, Subject was ~ent~nce~
by Judge Eaton to 5 years probat~on, and ordered to pay restatutl.on l._n the
amount of $1,153,000.00 within one year, mon~es to be re~~ed and
distribu~ by the u.s. Probation 'Office.
b6
~011"Miami (!)- l96A-1056) H~ (4) ~f7tA-/b..Sk-rZ) b7c
~subject
_ coJIJ,~.}.tioft' .,, raquii'I<J ~ wllen fii)OI'!JnQ a~IC1011.

I ~ COde Ofl reverse lode. sJ.~t Gocrt~
L
"
\~
Jr-=r:5
______
CYS: Credit 1 felony conlr;ct;on ana

$1,153,000.00 ~o SA.__
? .OIIOOJ
r:st1tu~~on
__.J
of
Property
Ty~
Potentlel
Cod
Code
No Description
No
Cash (U.S. and foreign currency)

StOck. BondS 0t Negotiable n~ (cheek$, travelers Cl'lecks; .
money OtdefS; eert!icates of ~t ~) .
General Retal Merchandise (clottllng. food. liQUOr, ~ettes, TVs. etc:}
2
3
__,.~!!"14~~v;::eh::lc::;le$~!au.m to rcks, ~tots, 11 aile s. c:art'il)el'$. motorcycles, etc)

-- 5 ' Heavy MaCt!iilerY & Equipment (heavy equlprn$nt. ~ws. etc)
e. Bulk Material$ (gr~n. !'u$1, raw tMterlal$, metal$. wire. etc) .
.lc
Loss Prevented (PELP) Type Codes
Description
2 I BlaAA NeQOtlable Ntrumen!$ Of _Tickets

22 ; COI.rltetfeC S!OCks; BondS, C11rency 0t Negotable ln~umen!$
. 23 Counterfeit Ot Pirated Sound RecOtcfngut Mo!jQA~~------1
.~ &;.11$/fiij
AbOi'ted
, 25 ~; ExtortiOn 0t Bribe OemNid Aborted

1 26
Theft From, Ot Fraud Agein$t. GOvernment ScherM Abotte<l
27; Cotrvnercial Ot tldu$trial Theft ScherM ~d
(ineWng Ul'l$$t preclou$ and semipreelou$ sloneS)

PreC!ou$ Metal$ (gold, wer, saverw.re, pJatinum. etc)
Art. Antlqv$$ Of Rare ColeetionS
~etry
7
.8
9
10
11
12
OanQerOY$ DnJg$ .
W~Ot~
30 AJ Otl Potential EconomiC l.o$$ Prevented (nOt faling n My

ealeOOtY above) .
Bv$in-e"s$e$ Ot Assets Forfeited
20
f..J ~Recoveries (not falling n My cateooi'Y abOve)
*"
~ case file n'IU$t contain

explanation ot the computatiOn ot the recovery ~k.le Of 10$$ prevented. An expranatlon aii'WI tnl.i$t accompany this
report if the recovery is $1 ITiiltion Ot more, Ot if the PElP ~ $5 ITIIDion 0t II'IOre:
S11bject Deicrlptlon Codes
Ente( Description Code Only When Reporting a Conviction
' Union Mem~rt:
SA ntemational 0t National Ofr~-er
Orgenlzed Crime S11blecta;
: 1A .Bo$s, Underbo$$ Of Con$lglere

1 e ~;;,a 01 Soldier
1C Possible LCN Member cit AsSoclale
ss t..oear Officer.
_6C . Union Employee
10 0C SubJect Oti'IEir Than LCN

GOvernment Official Or EmployMs:
Known Criminels (Other .Then OC Membera):
6A . Fedefel _Elected Otf~ial
. 2A TOP Ten or LO. Fi,o~ve
66 'Fe<*el NOM~ Executive level
2B TOP Th~f
Fedetal A.l Other
.
2C TOP Con MM
60 Stale E!e'1ed Official
Foreign Natlonels:
6E _State Nonelected Ex~ve level
3A Legal Alen
6F' Stale AI Oltl
3B llegal AEen
6G . local- Elected Ot!iciaf
~C FOteign Official Without _Oiploma!ie k'nrnunity
6H local NOI'I$IeCted Execufive level
30 U .N. 'emp~oyee Wltl'lout Oiploma!ie tTimunity
6J local AI Other .
S.nk Officers Or Empfoyees:
_3E Foreign S~ts
3F .AJ Others ,
,-7A Bank OffiCer
.
-76 _Bank Ernplo~
-Terrorists: .,.
4A Known Member of a TerrOtist OrganizatiOn
All Others:
4B PO$$ijle TerrOtist Member 0t ~izet
SA AJ Oltl Si.t>je"ct$ (not fitting al),()ve categorie$)
-If a svbiet eM be cla$$lfltd n rriore than one ot the categories, se14ct 1M triost appropriate n the cir0Jm$tanc$,-
ec
lftstr11ctlona.
SubJect Priorities for FBI Arrest or Locetes:
A Subject wanted for etin'ie$ ot violence (i.e: murder, J'!~Mstavghter. forcible r~; robbery Nld aggravate~ a$Sault) 0t c:Onvicted of SUCh er~ i'l
the past five years:
B Subjects wMted for crimeS i'lvoMng ttle loss 0t deS~tion ot prot*ty vak.led in ex~ ot $25.060 0t _
cOnviCted ot such ~s n the Past
five year$.
C AI Otler$
Claiming Convictions Other Than Federet
It ;s -perm.$$lble to claim a local ($tate. eounty Ot Jocal) convietiOI'I if the fBr~ i'lve'stigaton $ign&f~ay cOntributed to the succes$fui!Ocal
pr~. A $UCCirict nair~ve se~no ~ ttl$ ba$i$ tor claimng a locill coiwlc~ tmi$1 acC:omp'at 1y t!'liS report; When c:latning a c:Onvict10n
other than Federal. enw the word "LOCAL" n the "ConvietJon-Setiort~ b10k. disreoatd the~ ot cOnvictiOI'I eo~.nts. bvt enter the ~terle$
n tte awt'OPriale b~k$- ' Enlet *lF h tt1e .''h-Jait': block fOr aft ite senleftC:$$ and ~cp~ tor al <:aPtal puni$M'Ient $entences.,
Reporting Con~lctlons:
1
Convlcllons should not be repOrted untlf the $entenCe his been iSSued. There are two excepton$ to thiS rule. The c:onvietiOn il'lfon:nation CM be
$Ubmitle0 by ase11 11:
. 1 The svbiect ~ a fugitive ~ conviction 1M priOr to sentencng.

2. The $Vbject die$ after c:Onvletion. but priOr to $enterlcing.
An explariatior\ IS reQUired in the RemarkS s:ec:ton tot ecner ot the above exeepton$.
R11le 20 Slt11atlona:
The .field offiCe that obtail'led the J)roeess (nonnally the off~ ot Otigil'l) ;s the off~<:e that shOufd clam tie c:Onvietion, not the otf~<:e where lhe
svbjec:t enters the plea in ca$es nvotvinO rue 20 of the F~al Rule$ of ermnar Procedures.
Investigative Asalstence or Tectlnlq11e1 (IA/Ta) UMct:

;Since more ttlan cine tAfT COIJd have cOntributed to tt1e acCompfistvnent. eacn WT n'IU$t be rated.
Ttie IA/T used rTIU$t be rated eech time arl ac:compl~t 1$ Claimed . (For e~le if il'\tormant irlfoi'ITialion was the bast$ for a cOmplant. an
arr~t. a reWiery and a convietiOI'I and if ~a~ FD515s are SUbr'rtlt1ed for each of the aforementioned ac:Compfl~ts. the "n!ormant
t'ltormation~ block rTIU$t be rated on each FD-515 even it was~ ~ il'lformation ~hat c:OntribW,. to all the acCOml)i~.)
'
X.Airtel
12/13/82
DIRECTOR FBI
b6
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FROM:
.,,_
SAC, MIAMI (l96A-1056) (P)
::
'SUBJE~:
SARKIS GARABE!!' SOGHANALIAN I
'<J
' I
' .
.":~ed Tr~~~i:i~ernatio~al;
'
:ITSP;
'
. (00: ,MIAMI) . .
Re Bureau teletype to.Miami, June 4,' 1982.

.
For ~nfo~4tion of the Bureau,. ~aptioned subject entered
plea of guilty on May 13, 1982, to one <;eun~ of Wire Fraud, before
,, united States 'Distrlct \Judge Eaton, Southern Distrlct of Florida, "
on .December 3, 1982. Judge Eaton sentenced subject to 5 years probation and ordered .subject to:make restitution in the amci t of
1
This. 'lna. tter. w,as indicted by ,former AUSA
.
. who resiqned from the Miami United Sta~s....JMJ~::m~:-s-utfice
I
_ L..":'"'n:-""'l:,. . e:::-:_p="'t"""er.lb:d.- er, 1981, to enter private practice.
.remained'
primary c~unsel on .this case as a Special Assis an
n e
tates
A~~orney, devoting~umerous hours .of his own time to the ~atter
withndnimal compensation. Miami .requests that the Bureau prepare
a letter of commendation bearing the Director's signature for. 'his '
fine work on, this case and overall performance as a ~raud Prosecutor.
~he .fo~lowin<J in~ormation 'is provJ.ded:
;
.. .,
:53 r0 ,
lserved as an A~sistant United Stat~s .

Attorney In the united States Attorney's Office, Southern Distr1ct
of Florida, from March 15, 1979 until September 15, .1981. , He ~lso
served as Chief of the United States Attorney's Fraud unit, from
_
January l, 1981, uritil his resignation to enter p~ivate practicf in
the Ci~i~.Law field. ,ouring.his tenure as a AUSA~
.
I
2 - Bureau
~~
, ..
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bE
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'
.
. I
i'
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;
.
..
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'
. .
.,
'
displayed the ~:t::: ::;:Jsonal devotion to duty and pro-_

.,
fessionalism.J _____ ------~orked tire~essly in 'the face of
an overwhelmin
e
a~ :a:e load :n support pf FBI
, fraud investigations. AmOng(
many achievements
..
was the maktef of the United S a es vs.arkis Garabet Soghanalian.
I
_ceaseless efforts, ~ncluding countless' hours o~ h~s
own time as a special AUSA, after leaving the United States Attorney'.s
' Office, resulted. in .':the felony convict'ion of the
and
a restitution order of $1,.153,000. only througnl_ _ _ _
.
persi'stence and .dedication was the defendant conv!-=-r-c~e,..,.........,...,n,.......,o=n-=e____.
of the I:l.ost significa;t f:a:d 4tters investigated by the Miami .
Office of the FBI. [__
___ _ ex~plified the .highest standard
of performance and su por
or . BI investigations throughout
his . asso'ciatlonwith: the Miami United States Attorney's Office .
:e:e:d;nt
re
letter for _
aurean i
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r_torequested
to forward the commendation
Uiami for personal presentation
. '
'
.'
.
'4
I
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2*
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..
u.s. Departm,eor Justice

Southern ,District of .Florida
299 E. BroWflfd bkPfDd

.Fort ltJudtrdak, F7orlda 33J01
February
8, 1983
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Special Agentl
.
Federal Bureau of lnvestl.gatl.on
3801 Biscayne-Boulevard
Miami, tFlorida 33133
Dear'Mr.~l------~
This .is to.confirm that all property and evidence acqu~red
by your Agency in ~Qnnection with the matter of the United States
of Am~rica vs. Sat'kis Garabet Soghanalian should at this time be
returned to the contributo;-s or otherwise properly disposed of.
Very truly yours,
STANLEY Zv'.LARCUS
BY=I~~~
ASSISTANT UNI'I'ED
STAT~S
ATTORNEY
MHdm
cc l. . _______,
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IEARCHED~''))EX~
IERIALlZEy~Frtt:D
FEB 111983
?ebruary 16, 1983
Mr.l
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Mia~&Tx~,~&~1"o~x~x~anar-------~
De a~~----------~
x am pleased to have this opportunl ty to express

sincere appreciation for your outstanding performance while
serving -as Assistant Unit~d States Attorney .for the southern
District of Florida .and or your support of our fraud investigations. We are truly grateful for _your assistance in
the mat-ter involving Sarkis Garabet Soghanalian. I understand that even .after .leaving office you still .devoted many
hours to ensure the felony conviction of Soghanalian. .Your
professional .skills and untlring efforts greatly contributed
to the success achieved in that significant case and you
have our heartfelt than'ks. My colleagues join me in extending
best wishes for continued success.
Sincerely yours,
William H. Webster
Director
Ci\- :Miami (196A-l0.56)
"'V Reurairtel 12-1.3-82.
---
,- Memorandum ..
To
SAC, Miami (196A-1056)
-/JAJW I}lt.U.J
From
Z:'
S.t;t:
Da.te
2-16-83
Director, FBI
~ARKIS
JJ:~
!:TED ~RADE
I --- -- -
GARABET SOGHANALIAN
1:ti7.'ERNA7.'IONAL;
B ; .
VICTIM;
b 0r
b'/C
ITSP;
(00:
MIAMI)
Reurte1 12-13-83.
~~ yoat
:c
letter of appreciation to be presen~ed

together with a copy for the completion
Enclosures (2)
!9i?_f!:-/O~ - tzf6
~~rii~to l;J>
FEB
18 1S83
--
_';{
'".
-~
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...
SAC, .Miami
2-16-.83
(196A~l056)
'
Director,
,FBI
SARKIS GARABET SOGHANALIAN

dba UNITED TRADE INTBRNATIONALJ
VICTIMJ
J
I'l'SP;
(00: MIAMI) ,
Reurtel 12-13-83.
I
.Of
to
JUU ..
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b7
'.
to be presented
::.:~ann" Jletter ofwithappreciation
a copy for tbe
fa
X:Z
'tog~ther
completl~n
Enclosures (2)
.,
'I
l9k.l+-'l0Sb -~"'
.
'.o)~
~-
~'lf;'(~_-l ..
,
FEB 1. : U!3
..
-'
'
-,'
..
, 196A-1056
'
,-
'
Post Office Box 59241.8 AMF

Miami international.Airport
Miami, Florida - 33i59 -
'
.,
I . . .. J .
I'_
'f.l
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Northern vlrg nia Printers, Inc.

820 N. Pollard- .
Arlington, Virginia 22203
'
pear Mr~
b' / C
I'
~
. :; I
.Enclosed pleas'e find certain original aoeumen.ts you

previously 'furnished to ou'r Arlington_, -virginia '.Office. "Your
'cooperation in this matter is ~ppreclated..
Verytruly
~ours~
: JOSEPH V. CORLESS ,
Special Agent 1~ Charge,
'
I'
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'
'Supervisory Special Agent-
'.SEARCHED
_ . .INDEXED . .. ....-.- .
SERIAUZEil'" .;n-:,: ...... ~.
FIL-ED
1
'
J. - Addressee -
.Enclosure 1
l - Miami (1.96A-l056)
.HAL:mca
,' {2)
' .'
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~~
....... !< ....... '
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/ G1. (;.,4; /D~b ~ f-11
'.
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196A-.lo.S6
..
'Post. Office Box .59241S -AMF

Miami ;international ~lrport
:}t!anii', .Florida '3315'9
''
,I
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March 4, 1983'
II
.,
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ort .Lauderdale 1 :Florida ,33934

f
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Dearl
I
I
Enc~osed please find certain original .docUmepts you
previously furnished to this .office., Your cooperation in this

matter 'is ap_preciatea.
.
'
, Very ~tr~ly yours,
JOSEPH V. 'CORLESS
Special: Agent in charge
.BY:'
.,
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'.
I Supervisory Special
I .Agent
., '
'
~~
,.
''.
SEAitCHED
INDEXED ., . u-
..
.
SE~IAI.lZED . ''M,~ .......
'
F1L"!D
1 - 'Addressee
'Enclosure :l
l. - Miami (l:96A-l'OS6)
' ..
. , . :}~ ' ...
''~
~
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..
HAL:mca
'(2)
.
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Post Office Box 592418 AMF

Miami International .Airport
.196A-1056
<
March 4, '1983
<
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P!ainfie!d, New Jersey 07062

Dear.
Mr-~...1_ _ _ ___.
.
. Enclosed please find certain documents you :furnished
.. this office in connection with the matter styled United States
versus Sarkis Soghanalian. As you may be aware, Soghanalian
plead,guilty to one lelony count of wire fraud 'and was .sentenced
. in December, 1982, to .five yea~s probation and ordered to'make
, :resti't:ution of $1,156,000.00

.'
.
I
'
.Your ~ooperation i~ this matter

l
is
app~ec~ated.,
, Very truly yours;
' '
JOSEP~ v. , COR~SS
Special Agent .in Charge

~Y:
'
J' .
!:::
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''
SEARCHED ................
, .l ,_ Addressee
Enclosure .l
, l - 'Miami (l96A-l056
. '
l.
Hl\.L:roca
(2)
-~
uNtTED STATES DISTRICT COURT
SOU'i'HE$ DIS'TRIC'I' OF" "FLoRID.;_,
o '~
UNI'I'ED STATES or AMERICA:_
v .
sARKis: G._ SOGHANALIAif
'1
'
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. :_
I
'0 'R -DE R
. THIS. CAUS-E_. comin.~. on .before .. the Court,- and_.being ,f:ully;

advised :in_ the premises,:
:I'l' lS HEREBY ORDE-~D and ADJUDGED that. the_ government's

Motion_ For Enlargement_ Of: Time -To rile: Eespqnse is_. hereby
I,
GRANTEI>.Th, soverrunE>nt "has" until .the" '"
'J.-'J.--.:! day ot
'1983, to file_ its Response.

ooNE.. and_ ORDEREP this."
';--i-'. dal'
I
of_-~
, 1983.:
5b~
t
~~~l-
aOE EATON
u. S . DI-STEIC'I' JUDGE
HON~:
cc:_
u.s.- Attorney '<Hurs_~y)

FBI (Lane)
Dean_ Andrews, Esq :
.
,_/o)~
'
---a9o
SEAJtCHED~EXED.
, SE.ftlALIZ~lt3.~
,1
JUN 23 J9f3 .
.,
. fiJ,MIA.1'
I .
"
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.:.
:Memorandum.
To
From :
S~
Subject
-,
(C)
June 19, 1984
Date
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:)SA'-R-KI_S_S..,...OG_H_AN_AL_IAN____.
FBW
(00: MM)
1984, the -writer was contacted by
~: : !t ~~~~renco -tbyc~~~!~~ed::s;,.,..,hw..iu;e;.....
~,
AUS~JSDF, who requested that the writer meet
:
~~~~e~~~n;itl<iuir;
t...._.------.
disclosed tho: the m;::~; ~ was to be wit~

_
I
.counsel, an~Jdeputy counsel,
ce o
Professionalespons
ty {OPR), Departme~stice,
W a s c D. C., . FTS 633-3365. Superviso
advised
AUS
that concurrenoeof FBIHQ would have o e obtained
prior o nterview by DOJ OPR of an FBI employee. Sq~c~h~--~
concurrence was suhse;,;ently obtain;;d
nd, per ASACT
I
the writer met wif~ __
land
_
n the afternoon of
May 23, 1984. SA__
Wa$ present throughout
the course of the mee ng.
I
ladvited :ha: :;~ office was investigating
an allegation made by
jthat someone in the Miami
USA'sOffice or Depar men oustice had been paid a bribe
in connection .with the plea agreemec.red into by the
Government with captioned subject.
stated that the
allegation reflected in no way upon t e . , and that witnesses
interviewed by OPR to date had . nothin~but :faise for the
FBI's handling of captioned matter.
further advised
'that although there was no .evidence t t a ribe or -other
impropriety had occurred, some questions had arisen concerning
the administrative handling of the plea and subsequent pleadings
before the courtb:J matter. The writer proceeded to discuss
witN
land
the facts of the substantive case, and
the writer's reco ec on of .events surrounding the plea agreement.
-196A-l~
C
HAI:/ne
y#V
JUN 2 0 i984
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'
Memoranaum

FEDERAL BUREAU OF I,NVESTIGATION
To
:-
s-fk:.., ~ ( \ q "A-loSlP
FROM
:-
54
suBJECT:-
SAR(.. \ ~
-S ot:s HA-NI\'L I P.PJ' .dc4
kF1' P'DW
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DD: .VV\VV\. ,.
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~ ~ ~ cW?i- ~
~~tS
Sf>b~t{f1\}
L . . . _ __ _ _
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~
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Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan
~~----~-------------
APPEARANCES:
2
3
4
ANDREWS & LUBBERS,

By s DEAN A'UDREtiS 1 ESQ. 1
P. o. l.lo:>: 11570,
Fort Lauderdale, Florida 33339 1
and
5
6
7
9
10
11
12
BARANDES, RABBINO & ARNOLD,

By: GERALD BARANDES, ESQ.,
and
MITCHELL w. RABBINO, ESQ.,
18 Bast 48th Street,
New York, New York 10017,
Co-Counsel for Plaintiff.
FRATES, FLOYD, PEARSON, STEWART, RICHMAN & GRBER 1
By: GERALD F. RICHMAN, ESQ.,
One Biscayne Tower, 25th Floor,
Miami, Florida 3313~,
Attorneys for Defendants.
13
I N D E 'X
--------
14
15
16
WITNESS
17
18
19
20
21
22
23
24
25
CROSS
DIRECT
EXHIBITS
FOR IDEUT.
PLAINTIFF'S
58
59
77
80
86
110
110
110
2
3
4
5
6, 7, 8
9
10
CERTIFIED QUESTIONS
Page 15, Lines 3, 14, 19
3
16
:.-v,.
.,_
Castillo & Castillo

- Reytsured l'r;oft-ssional Rt-portus :219 N.W. 12TH AVENUE MIAMI, fi..A. 33128 '
TEL. 324-6311
.,
~~~------tt----------~----~--~--~~~3~
.Thereupon:
2
SARRIS G. SOGHANALIAN 1
...
3
a defendant herein, was -called as a witness by the plaintiff
and, having been first
d~ly
sworn, was examined!and testffied
as follows:
DI REC'l' EXAMIUATIOt~
-7
:BY MR .
~NDREWS:
Will
Sarkis Garbet soghanalian.
10
.Q
11
,No, I '.m not.
Of what country .are you a citizen?
A.
Lebanon.
.{l
liere _you born in Lebanon?
A.
No 1 I .ve. been. ~born in I skenderun 1 Turkey 1 previously
12
13
14
16
16
18
19
20
21
'22_'
24
25
:Please state your full naDe.
Arc you a citizen of the United States?
part of syria.
17
:i3
yo~
And thereafter you became a c;tizen of Lebanon?
A.
.Correct.
Do you
present~y-hold
A.
Yes, ,I
d~.
0.
By what authority have you presently been allowed' 'to .
a:
pas$po~t
issued by Lebanon?
enter the United States?

'
By the immigration law .
do~t.know-which
article.
.But I've been married to an American citizen.

'By
.virtue of .being married to an American citizen,

Casti!lo & Castillo
-Registered 'E'rofessional Reponets2t9N.W, 12TH AVENUE MIAMI, f\,A,
TU 324-631\
33t:iS
4
:1.
did you . then make
~pplication
:to livo. in this country?
Yes.
Hhat is your status?
How are _you described, :being
a citizen . of Lebanon and allowed ' to 'live hereJ are - you termed .
a resident?
A.
According to the
im~igrat;on . and naturalizatiori
it you _get married .to an ADerican citizen

8
the~
'law,
allow you to
live in the- United States..

.
Didyo~
rnake
~pplication
married?
11
Well~
when_'I
as~ed
-for r:ty visa it:l
12
1958, then I made the application
13
States.
14
fs
to ~ come
N~ples, .
tp the - United
here issued by the immigration authorities?

A.
l7
Yes,_ I do.
And what is it;, what type of docurnentation, .i -f you
know?
19
Well, it' ca1led "green card.
20
That green card : status, does it require
21
22
Italy, in
t)o you hold any documentation allowing you to live - '
16
18 ' .
to live hete after 'becoming
y6u - to . ~ake
reapplication in your ,resident status from .time to time?

No, once you have it it's permanent, until
.YOU
become citizen.
24
2_5
You are not required .to make any -annual, as an

example, reapplication lor the
issu~nce
of that green card?
Castillo, & Castillo

-
Reglstutd "froftssioizal Rtpomrs -
219 N.W, 12TH AVENUE MIAMI, f~A , ~3128

TEL, 324-6_311
5
~
No.
I guess all you do, you report once a year that
you are residing at such-and-such address.
Q.
Do you own a residence home in Dade county, Florida?
A.
Yes, I do.
\ihat is the address of that home?
It's 305 North Hibiscus Drive, Hibiscus Island.

Is that in the City of
A.
9
10
Mia~i?

Do you own this horne in. your individual name?
A.
11
Yes, I do.
When did you acquire that home, if you recall?
12
A.
About three yeara ago.
13
Q.
Do you own a residence home in your own name in any
14
other part of the United States?
15
MR. RICHMAN:
Excuse me.
Hight I inquire l-the.t this
16
has to do with the issues in this case?
17
thing that might be of interest in a garnishment proceedin9 o
18
something like that, but to go and inquire into all of the
19
assets and things that he owns I don't think will lead to the
20
discovery of anything that is relevant to these proceedings.
21
22
MR. AHDREHS:
That would be some-
Well, I will advise you, as to the
point of the inquiry, you will recall in our Complaint we ha

sought, among other things injunctive relief, which we have
24
not called up.
25
person-might allow him to leave this country on short notice
We have pointed out that the status of this
Castillo & Castillo

- Reglsrmd Professional Reportus219 N.W. 12TH AVENUE MIAMI, H.A. 3.3128
TU.. 324~311
and that we, therefore, arc concerned about what assets he

2
does have, and I will be
this corning.
inquiry about those assets
Well, if it gets beyon~ the question of
MR. RICHMAN:
where he lives and what he's got and goes into details of all
his assets, we will let the
per inquiry.
Co~rt
decide whether that is pro-
It gets into questions of garnishment.
I don't think the relief being sought is appropriate 1
He is a resident and owns a home.
10
and so on.
11
BY MR.
12
That's a substantial asset,
ANDRE\'lS:
Well, my last question was:
Do you own a residence
13
horne in your individual name in any other part of the United
14
States other 'than here?
'15
No, I don't.
16
Now, what ij your present--
17
A.
Excuse me, I don't want to mislead or nisinterpret
18
anyof my answers.
19
Hisconsin on a farm.
20
21
23
24
25
I do have a land contract, lease, in
In your name?
A.
22
I.
~aking
Yes.
Now, will you tell me what your present occupation
is, if any.
A.
Right now I'm not employed or doing nothing.

When you made application back in 1958 for your
Castillo.& Castillo
-
Registered l'roftssional Rtporttrs -
219 N,W, 12TH AVENUE MIAMI, J'~A. 331i8

Ttl.. 324-G311
7
residency status, were you required then to list an occupation~
2
No, you are entitled to describe your profession.
And did you at that time describe ~your profession?
Yes, I did.
And what profession did you set forth?
A.
I do not recall.
In the renewals or reporting annually that you have
7
8
described, do you list your occupation, are you required to
list your profession1
10
11
To your knowledge, you have never listed an occupa-
12
13
don't think it's required.
Nobody asked
~me
that.
tion in any-A.
No.
--in any .formal documentation attending your resi-
15
dency as a citizen of Lebanon?

.Do you want to .repeat that one more time, please.
16
17
0.
18
I'll try and state it even more simply.

Do you have any recollection of stating your occupa
19
tion in any application made to this country allowing you
20
residency here, your green card?
21
A.
22
23
No.
As of May 1977, did you 'then have any occupation?
A.
I was--officially I was in my--visiting hotels and
24
asking.questions on hotels, something like that1 occupation,
25
commerce.
Castillo & Castillo
- Rtgisrtred Professional Reporrtrs ......
21~ N.W. 12TH AVENUE MIAMI, H.A, 3312.8
T(~. 324-6311
----~--~-~------------~-~--------~8~
~
General.
2
3
Q.
Well, what type of commerce?
Generally what?
MR. RICHMANa
What did you deal in, in commerce?
Answer the question, sirJ basically,
whether you .were - ernployed oi not.

Do you understand the question?
What was the nature
of your businessr what were you doing--buyinq and selling,
whatever.
Buying nd selling military surplus
THE WITNESSa
10
or be coordinator of defensive equipment between countries and
11
manufacturers in this country.
12
BY HR. ANDREWS a
13
14
Do you have -any other'business activities other than

what you just described?
15
16
A.
What do you mean now?
Q.
18
broker or--
19
23
Yes.
~or
20
22
answered that question.
said, "General comt,nerce."
17
21
That's my profession now.
And then, as I take it, you buy, sell or
consult.
--or consult on the sale of military surplus, is tha

it?
A.
Military equipment.
could be surplus, could be new,
depending on case by case.
24
What type of equipment?
25
Military equipment.
Castillo & Castillo
-
l?~lsrered
Pro,(essional Reporrers -
219 N.W. t2TH AVENUE MIAMI, FLA. 331:i8
""TEL. 324-6311
-9
~
2
Well, that covers a rather broad spectrum.
Do you
deal in all military equipment?
A.
Hell, nourishment.
What do you mean by thatJ food?
A.
Food.
Military food?
A.
Well, military..o-for IUilitary pack, for military use,
...
because they come in the special packinqs.
0.
Yes.
10
A.
And
11
Food, clothing?
12
A.
Weapons.
13
0.
Weapons.
14
A.
Communications equipment.
15
0.
What type of weapons?
16
A.
Assault rifles or machine guns, those are the
17
weapons.
clothe~,
weapons.
Depending on the requirement of the customer.
18
0.
Now--
19
Now, to correct you on one thinq, that as I men-
tioned before, and I want to state one thing, I do not Sell
21
this type of equipment in this country.
22
my profession, overseas.
That is my business,
23
Do you buy this type of equipment in this country?
24
No, I consult certain companies that they do manu-
25
facture this type of equipment.

Castillo & Castillo
- Registued l>rofesslonal Reportrrs 219 N,W, 12TH AVENUE MIAMI, FLA. 3312S
TE_L, 3-24-6-311
10
~
country for export to another country?

A.
Would they then buy direct?

A.
you were not--
A.
Some of them entered the scene.

But your answer is you have never bought military
10
equipment in this country for export to another country?
12
A.
Not personally to my name, no.

Have you ever done so through any 'business entity
13
14
They buy direct, yes.

And .you would merely arrange for them to buy direct,
11
No, but I have coordinated overseas customers to
I local manufacturers.
Have you ever bought any military equipment in this
that you either owned orcontrolled or had an interest in?

In this country?
15
16
,Q.
Yes.
17
A.
Yes.
18
have formed a company but never dono busi-
ness.
19
Now, these business activities that you have just
20
described, were you engaged in those same 'business activities
21
in 1977?
22
A.
Yes.
23
Are you presently married?
24
no.
25
Have you ever'been married?

Castillo & Castillo
-
R~lst(red
Prq/esslonal Reporters-
219 N,W, 12TH AVENUE MIAMI, fLA, 33128
T(l., 324..e311
-~-------1_1_,
.,
A.
Yes.
I
And to whom were you married?
A.
To a Shirley Adams Soghanalian.

And when were you married to Shirley Adams?
In 1958, June 4th.
Where were you rnarried?

A.
8
9
In Beirut, Lebanon.
Has that marriage been terminated?
A.
Yes.
10
How was it terminated?
11
Well, on friendly terms.
12
I mean, have you been divorced?
13
A.
Yes.
14
Q.
When were you divorced, sir?
15
A.
About almost two years.
16
17
And where did that divorce take place?

A.
In lUsconsin.
18
MR. RICHMAN:
19
I'm not sure that you understand the question that
I don't want to mislead you.
20
he's asking, when the divorce took place.
21
interpreting it as when it was filed as opposed to when it
22
becarr.e final.
23
I think you are
I have not seen the papers and I have just been
24
informed of this, so--
25
THE WITNESS:
I don.t have the exact dates, but I

Castillo & Castillo
- Rtglstnt>d P1o[t>ssional Rt>pOTit'rS219 N,W, 12l'H AVENUE MIAMI, fLA.3312.8
TEL, 324-6.311
12
.,can ,get .it for you.,
MR-. RICHMAN: Do you kno\i whether it became -final
ago~
recently or whether it :became final some time
And if you
don't know, -don't answer the question.
'4
THE WITN-ESS a Some time ago, 'but I do not know the

date.
.6
BY MR. ANDRE\'1S :.
.\'loll, some .time ago, i'n .. approximate terms, .a few
months, a, few weeks?
10
No, more. than that.
11
''lell, how much more than that?
12
(No 'response.)
13
Did yoti appear at
14
Uo, I haven't.
16
.Q.
tion
18_
.A.
you~iven
iny notification when final disposi- ,
of this marriage?
Yes, it was mailed to me, but I wasn't here

And approximately how
20
'A.
21
23
Were
was.~ade
19
22
final disposition of this
matter in a court of .law?
15
17
a~y
lo~g
ago was it mailed to youi
I would say ,between six to eight months.

And this divorce,- ,I believe you said, to9k place .in
:wisconsin?
' ''
'
A.
Uh-huh.
24
{\
Where in Wisconsin?
25'
A.
Prairie du .Chien,- P-r-a-i-r-i-e d-u

Castillo & Castillo
- 'Rtglsttred Prqf<>ssionaf Rt>porrus 219 N.W. 12TH AVENUE .MIAM,I, H.A, 331iS
TEl.., 324-.e3_11,
C-h-i-e-n~
13
Wisconsin.
Now, I believe you teotified earlier that your
w~fe
was a citizen of the United States, is that correct?
Yes.
And you also testified that your marriage to a citi-
zen then enabled you to make application for the type of resi-
dency that you now enjoy here, is that correct?
A.
Does the divorce in any way affect your present
9
10
Yes.
status of living in the United States, if you know?

MR. RICHMAN:
11
12
sion on his part.
13
certainly don't.
THE WITNESS:
BY MR.
yo~
do,
No.
mean, nobody--
AUDRE~'lS:
~o
18
19
If
answer it, but--
16
17
I don't know if he knows the answer.
Do you know the answer to the question?
14
15
I'd say it calls for a legal conclu-
what?
No, you don't know, or no, ithas no
effect?
I
Nobody told ce anything that I should change my
20
21
status or not in my residency here in this country.
22
Did you ever employ a man named Felix Rodriguez?
23
no.
24
25
0.
Do you know a man by the name of Felix Rodriguez?

Yes, I do.
Castillo & Castillo
- Reylsurtd Professional
R~porrns
.219 N.W, 12TH AVENUE MIAMI, FI,.A, 33f2S
TEl.., 324-6-311
....
14
-~
Sometime in 1976.
2
3
4
5
6
Q.
And what
Rodriquez?.
A
~ere
the
c~rcumstances ot rnee~ing
Mr.
How did _you .P corne to .know him?
He was presented 'to roe .as in . electronic mantifac-
turer s representative.-
.A
.Q
10
t1
When did you become .acquainted' with him?
o.
12
'Who presented him to . yo:U,?

A
mutual friend.
- ~hose
name was?
'Hilson~
Hhat Wilson?
I
don't .remember his .first name ri'ght
' 13
}:dward Wils()n?
14
Yes, Ed.
. no\~.
Edward.
don~ know~
where does.Mr. Wilson live?
c.
16
He used to .live in Washington, D.
1)
.Q.'
After such introduction, did yoti thereafter ever do
18
19
any .business with Mr. Rodriguez?

.No._
Concerning your business .activities,. do you have an

21
interest in . a ,shipping company known as Ga:z::mel?

Shipping company Garmel?
23 . '
Yes.
24
I had a boat 'by the name cif
GARMEL~~
A .boat?
:C:~stillo & Castillo
_...,;, Rrgtsrued Profrssiona/ Rrporurs' 21~N.W.
12TH AVENUE MIAMI, F\.A. 33128
15
~
2
Yes, but I do .not remember having a shipping company
Garmcl.
Now, do you file federal income tax returns in this
3
4
country?
MR. RICHMAN:
question.
proceedings.
I will instruct him not to answer the
can't see that that
~s
relevant to any of these
Object to that.
MR. ANDREWSs
Are you instructing him not to answer?
MR. RICHMANs
Yes, instruct him not to answer.
10
think we are qoing well ..beyond the--
l1
MR. ANDREWSs
Show that the witness refused to
12
answer and certify the question.
13
BY MR. ANDREWS s
14
Did you file a federal income tax return in 1977?
15
MR. RICHMAN&
Sa~e
16
MR . Al~DREWS a
Same reflection and certification to
17
that question.
18
BY HR. ANDREWS 1
o.
'19
20
instruction.
Prior to your divorce,, did your wife ever join with
you in the filing of your tax returns?
21
MR. RICHMAN:
Same instruction.
22
MR. ANDREt'lS s
Again 1 the same reflection that the
23
witness is not answering the question and certify .the questior.
24
BY
25
~SR.
ANDREWS:
Do you presently maintain any bank account
Castillo & Castillo
-
Reglsrered hofessional Rtporrers -
2,9 N,W, 12TH AVENUE MIAMI, fLA. 33128

TEL. 324-63;1
16
relationships in Dade County, Florida?
2
A.
Yes.
Would you please identify those accounts for me.
4
5
MR. RICHHANa
It doesn't relate to the issues in this case.
6
1.
Instruct the witness not to answer.
.MR. ANDREWS:
Well', for ease of helping the Court,
I think there are a number of named defendants in this matter,
which the banking relationships and the intertwining may very
well have meaning, and we therefore '"ant to make inquiry, not
10
only as to Mr. Soghanalian's banking interests, but his
11
knowledge, if any, concerning banking interests of some other
12
entities that I will later identify.
13
MR. RICHMANa
If you ask him about other entities,
14
but I'm not going to have him identify his own personal bank
15
accounts, if he has any.
16
garnishment proceeding if and .when you get a judgment, and,
17
historically, it's not a proper area of inquiry .
18
MR. :ANDREWS a
That is something that we go to a
It :rnay.
19
you.
20
want the question certified.
21
Not to be argumentative with
You have instructed him not to answer the question and I
MR. RICHMANz
To make it clear, I don't have any
22
objection to him testifying about the bank account in New York
23
or matters of that nature which you asserted as part of the
24
pleadings in this matter, but his own personal bank accounts
25
inMiami, I don't think are in any way relevant to the

Castillo & Castillo
- Rrglstu~d Pro/rssiontJI R~porttrs .219 N,W, 12TH AVENUE MIAMI,1'1.A, 33128
nt.. 324..t31t
17
proceedings.
2
BY !SR.
ANDRE\~S:
Well, let's go to outside Dade.county, Florida, the ,
for the moment, and I ask you if you have presently any bank
account relationships in the United States but outside Dade
County, Florida?
RICHMAN 1
You are talking about him, _personally
.HR.
Go ahead and answer the question.
THE 9ITNESS~
10
BY
HR.
ANDREWS:
Will you please identify what accounts you maintain
11
12
Yes, I do.
outside Dade County, Florida
HR. RICHMAl~ z
13
Again, I ,wi 11 allow him to answer the
14
question concerning that Irving" Trust Company, or whatever it
15
is that you .have asserted, but as far as his other bank
16
accounts, if they be in Wisconsin or California or wherever
17
they are, I don't think that's a proper prejudgment inquiry.

I will instruct him not to answer.
18
19
questiotis
20
relatin~
HR.
fie d.
22
BY MR. ANDREWS I'
23
24
25
All right.
I want the question certi-
Do you .maintain a bank account relationship in New

York City.?
No.
Castillo & Castillo
- Rtgistered Professional Reporters 219 N.W, 12TH AVENUE MIAMI, FLA, 33128
TE_L, 324-$311
to the .New York bank account.
ANDREWS:
21
He can answer
18
0
2
In 1977 did you maintain a bank account relation*hip
in New York City?
Yes, I did.
Will you please identify the account.
Irving Trust
Q.
What type of an account was it?
The account was opened sometime in 1971 or '72.
Was this in your individual name?
.9
It was opened to transfer and .make transfers from
10
overseas to that bank whenever I used to come to the United
11
States, because I was not residing that period of time in
12
the United States; I was residing in Beirut, Lebanon.
13
Q.
This was whenJ 1971?
From ''69 up.
15
Q.
Through what period of time?
16
'76, '77J part of '77.
17
Q.
Now, again, uas this account in your individual namcl?
18
Was to my name and United Industries, joint.
19
Q.
United--
20
To my rec6llection, yes, United Industries of
21
22
23
Lebanon.
o.
That was a foreign account.

\'laa
that a separate account or did United Industries
and yourself, individually, maintain this account?
24
Soghanalian for United Industries.
25
That is the way the account was set

Castillo& Castillo
- Regi'smed Professional Reporms 219 N.W. 12TH AVENUE MIAMI, FLA. 3312.8
Tu.. 324-6.311
up~
19
A.
At all times?
2
3
4
Was the account set up that way
A.
That was only one account.

And tell me again who was United Industries.
A.
Was a company in Beirut, Lebanon.
Was it a company owned by you?
Was established by
~e
but interest was owned by sev-
eral other people.

Did you own an interest--
10
11
~n
1977?
5
6
Right.
A.
Yes.
12
-~in
13
Yes.
14
Did you own a controlling interest in this company?
1S
A.
16
Q.
17
18
had the management power.
well, you say you caused it to be formed.
Did you
own part of United Industries?

A.
19
20
this company?
Yes.
All right.
Now, dJd you own a majority part of
United Industries?
A.
No.
You owned something less than a .majority part?
A.
.Right.
Who were the other owners in United Industries?
A.
Lebanese citizens.
Castillo & Castillo
-
Regisrned /'rofesslonal Rt>poners -
219 N.W. 12lH AVENUe! MIAMI, Fl.A. 331:28
TE I., 324-63f1
20
1
Their narnes?
The interest was soid, to start with, to certain
people like 'l'ehini, Antoine :Khater.
But then those people, I
heard they have sold their, you know, shares to others, but I
don't know whorn they sold it.
In 1977 do you know who owned United Industries?
No, because I didn't--you know, I wasn't back in
Beirut then
and~
didn't know who bought and who sold to whom.
But you owned an interest in it?
10
A.
'1 1
Yes1 I owned interest in it, yes.

But you don't know the names of any other people in
(I
1977 who owned an interest?
12
13
A.
14
don't.
15
No, I don't.
In order to be correct in rny answer, I
Now, did you indicate to rne that the account is no
16
longer in existence?
17
A.
18
And when was the account closed?
19
A.
1978, but I do not have the
ri~ht
date because when
20
21
the bank had sent a letter and a balance to my address here in

'
Miarn i , I wasn t here.

Why was that account closed?
23
Again, they have sent a letter which I saw at a
24
later date.
25
thi~ account,~nd
~hey
said, "Who opened that account and who owned

all that.
At ny absence it was not answered'.
Castillo & Castillo

-
R~lstmd
Profrsslona/ Rrport(f$ -
219 N,W, 12TH AVENUE MIAMI, H.A, 3312S

TEL. 324-6311
21
in time, apparently, and they went ahead and they closed the
2
.account.
MR. RICHMANa
Excuse me.
So the record won't be
confu~ing,
called for a "yes.
that he had closed out the account and he said, "No."
think he.meant no" in the sense--
I think he gave a no answer when your question

You asked hirn whether or not he .had said
'l'HE HITUESSz
I didn't close the account.
MR. :RICHMAN a
I think he meant "no in the sense
10
that the account was, in fact, closed out.
11
clarify that for the record.

MR. ANDREHSa
12
13
15
16
Why don't we
Let's ask him.
BY !1R. ANDRE\'lS 1
Did you cause tho account to be closed or did the
14
bank cause the account to be closed?

A.
The bank caused.
17
The bank caused the account to be closed?
18
Yes.
19
~
21
22
23
~
2S
And, again, do _you know why tho bank caused that
account to be closed?
No, I don't, but I assuoe because .that first letter
was not answered, that was the reason why it was closed.
And you say it was closed sometime, to your recollection, in
I
~958?
78
Castillo & Castillo
- Rtglsttred Profes$ional Reporters 219 N:w. 12TH AVENUf' MIAMI, H.A. 3_3 1iS
T(~.
324-6.311
22
~
Excuse me, 19787 right.
2
3
4
5
6
7
8
9
10
11
12
Mr. Soghanalian, are you familiar with a corporatior

known as United Trade International, :Incorporated?
A.
Yes, I am.
Q.
In .1977 was your former wife, Shirley, the president
of this company?
A.
Yes.
Q.
Was she also the secretary of that company?
A.
By title and name, yes.
Q.
Did you cause the formation of this company?
A.
No--what do you mean when you say, "Did you cause"?
Q.
Well, just as you told me you had caused United
13
Industries to come into existence, did you cause United Trade
14
International, Inc., to come into existence?
15
A.
No,
16
Q.
Did you instruct
17
18
'19
QRC
International did.
QRC
International to forQ this
corporation?
l~o, QRC
A.
International suqgested that they should havtl
a company.
20
Q.
Sugqested to you?
21
A.
Yes.
22
Q.
Why?
23
A.
Because we were in need of aircraft.
Q.
Yes.
.A.
And therefore the aircraft needs a home and needs a
24
,4c
' '
25
Castillo & Castillo

-Reglsttrtd Proftssional Rtporters21~ N.W, 12TH AVENUE MIAMI, H.A. 3312S
TEL, 324-6311
company to be registered and therefore they .have formed this

2
corporation.
Now, when you . say, "We had need for an aircraft;"
do you mean yourself and Shirley?
4
5
A.
No, the company, United Industries.

The company that you described--
A.
In Lebanon.
--.in Lebanon--
9
10
Yes.
Q.
--was inneed of--
,1
An airplane.
12
--an airplane, and QRC then suggested to you that
13
United Trade International, Inc., be formed so that the air-
14
plane, as you put it, could .have a homer is that correct?
15
Uh-huh.
16
Now, when, if you know, did that occurr when did
17
that .company come into existence?
18
To the best of my recollection was in 1975 or '76.
19
And after making this suggestion to you, QRC, that
20
,you have just described and' we will get into a little later,
21
'that
company was formod for the purpose of acquiring an air,
22
craft?
23
To register tho aircraft.
24
Pardon me?
25
A.
To register.
Castillo & Castillo
-
R~ist(rfd "Pro/fssional Rfport(rs -
21Q N,W, 12TH AVENUE MIAMI, FLA. 33128
T(t.. 324-6311
24
To register.
A.
Yes.
,l
Thereafter, do you know what business activities, if
3
~
any, United Trade International became engaged in?

A.
for United. Trade.
engaged
~hemselves
I mean QRC did,
And they have purchased parts7 they have

to maintain the aircraft and its activities.
Have you ever been an authorized signatory to any
bank accounts in the na'r.te of this company?
10
No.
11
Did either you or your.wife, Shirl~y, contribute any
12
capital to this company when it was formed?

A.
13
No, I did not contribute fron myself and my account,
14
but I have guaranteed the loans that was loaned to this com-
15
pany from overseas.

Q.
And who made loans to this company that you guaran-
18
A.
Certain Lebanese people.
19
{\
what are their names?
20
A.
.Nane is Tanios Saba.
21
0.
Tanios Saba?
22
A.
T-a-n-ios Saba.
23
0.
Is that an individual and, if so, where does he
24
A.
He lives in Beirut, Lebanon.
25
All right.
16
17
They purchased' another aircraft.
teed?
live~
And how much did he loan United that you

Castillo & Castillo
-
Rfgisrered
Professional &porters -
219 N.W. 12TH AVENUE MIAMI, H.A,~12S
Ttl.324-6311
guaranteed?
2
3
.seven hundred fifty thousand dollars.

~
When did that occur?
I have to look to the dates in order to answer your
7
8
question more properly.

~
Wall, approximately when did that occurJ at tho tirn
that the company was formed?
At the time that the company was being formed.
10
And how did that loan take place? Did this gentle-
11
12
man write a check to United?

A.
no,, the gentleman wrote the check to rne.
When I
13
say give it to me, to the narne of United Industries, and we
14
put that check into the bank.
15
Q..
What bank?
16
I think was Litex Bank.
17
I beg your pardon?
18
Litex Bank.
19
Where is Litox Bank located?
20
In Beirut, Lebanon.
-21
Okay.
22
23
1.
About seven hundred something thousand dollars,
.
'
24
25
He gave you the money and you put it in Lite
and then you gave the money to United?

A.
No, I send the money to QRC, where they made the
payment for the aircraft

(.\
Okay.
You gave QRC the approximate sum of $750,000

Castillo & Castillo
-- Rrglstrred Professional Reporters 219 N,W. 12TH AVENUE MIAMI, H.A. 3312_8
T-U.. 324-6-311
26
'2
A.
Uh-huh.
And QRC then acted for you in buying an aircraft; is
"'1!,
that correct?
A.
Uh-huh.
And title was then taken, registration--title was
Yes.
then taken in United to the aircraft; is that the sequence?
A.
Right.
.8
Did anyone else make .a loan such as the gentleman
10
t1
12
13
14
Right
that _you just described, to you, and then the sequence?

said several people, didyou not, made loans?
A.
friends.
0.
think he got part of the money from
don't know whom.
of his
dealt withr is that correct?

A.
.He is the only one I dealt with.
16
Q.
Has that loan been satisfied?
17
A.
Not yet.
18
Q.
How much is owed, the full $750,000?
19
A.
.Plus the interest.
20
Q.
Plun the interest.
21
And that is reflected how; is the loan made to you?
22
A.
I have guaranteed 'the loan.
23
Q.
Right.
25
so~e
But you don't know, .he is the only one that you
15
24
~ou
--
Has United in any way obligated itself to
either you or this gentleman concerning that loan?

A.
No, I did, obligated myself.

Castillo & Castillo
- Reyistered Professional Reporters 219 N.W. 12TH AVtNUE MIAMI, F~A. 33128
T(\..~-24~311
27
Q.
~:
'
Okay.
Now, we have been talking about acquisition
of an aircraft.
Are you familiar with a Boeing 707 aircraft,
registration No. N711UT?
A.
Yes, I am.
Q.
Is that the aircraft that you have been describing
purchased by United?
A.
By
Q.
iiell, let me ask you this:
QRC.
ORC
acted as a broker
for the purchase -of this aircraft?
10
Uh-huh.
11
Q.
Were they pjid a
12
A.
Yes, they got paid a
13
Q.
And you furnished the noney, you obtained the noney
Yes.
co~rnission?
co~nission
at that timo.
14
as you have described,. furnished it then to
15
QRC
16
in United Trade International, Inc.?
QRC
and instructed
to make payment for the aircraft and title was then taken
17
A.
Yes.
18
0.
No\ot 1 uere you ever acquainted with a man named John
19
Holcor.lb?
20
A.
John William Holcomb, yes.
21
Q.
All right.
22
and how did you become acquainted?
Z:3
24
2-5
Tell nc tho circumstances. Where, when
We can take those in different segments if you want,

Where did you first meet John Holcomb?
~
In Arlington, Virginia, at
QRC's
Castillo & Castillo

- Rtgisttrtd Professional Reporters 219 N.W. 12TH AVENUE "MIAMI, FLA.
TEl, 324--6311
33128
office.
.J
28
~
About (ive months after they bought the aircraft.
About five months after QRC acted as .a broker for
::
acquisition of N711UT?
A.
Yes.
How did this come about?
Was it as a result of
QRC's brokerage activities that you then went to Virginia to
the offices of QRC?
A.
Yes.
10
But you
11
A.
I had not .met Mr. Holcomb befor,.
12
I was there be fore.

h~d
not met Mr . Holcomb before?

I was dealing
with a gentleman by the name of Jim cunningham.
13
Who worked for QRC?
14
A.
I thought he was one .of the partners.
15
16
17
18
19
20
21
I never quea-
tioned what his title was at that time.

~
Now, were you ever acquainted with a man named
.Reynolds Williams or R. M. Williams, Jr.?
A.
I got acquainted with him almost after one year of

I
my dealing with QRC.

~
And that would have been
approxirnat~ly
when that you
met Mr. Williams?
22
A.
I'd say by the end of '76, the first part of
23
And how did you become acquainted with him?
24
A.
As an employee of the company.
25
Of what company?
Castillo & ,Castillo
- Rrglsttrtd Proft_sslonal Reporters 219 N,W, 12TH AVENUE MIAMI, F.LA. 33128
TE\.. 324~311
77.
29
A.
Were _you ever acquainted with a woman named Aceta.
2
3
ORC.
Goustanian?
Who is Aceta Goustanian?
Aceta Goustanian was part time eroployed by United
7
8
Industries in Beirut, Lebanon.

.Q.
From time to time.
What were these' in the nature of secretarial ser-
10
11
Did she work and perform services for you?
vices?
12
Correct.
13
Were those services ever performed here in the
14
United States?
Yes.
15
1\.
16
17
Industries?
Is she still associated with either you or United
18
Yes, she is.
19
And does she reside here locally?

Yes.
21
Hhere?
22
In Miami--
23
Do you'know her--
24
--Florida.
25
Do you kno,., her address?

C::tstillo & Castillo
-
R~ism<>d.Professional
Reporters--
219 N,W, 12TH AVENUE MIAMI, H.A, 33128
n1.. 324--6~11
30
I don't,
-~
no~
Now, Mr. soghanalian, at any time did you ever, you,
-2
~ndividually,
eve~:personally
contract and a power of attorney -signed by
deliver to the :offices -of .QRC a
:Shirley, 'dealing with -services : .that QRC would; _perform for

United Tiade Inteinational?
A.
0.
yciui~ormer wife,
Do you .recall when,
~pproxi_rnately,
~ou
r.tade such
delivery?
10
A.
Yes, \-tas ; in '76 sometimes.
\1
.Q.
Did you at any time thereafter instruct any person
~-
t'3
-at QRC to
ope~
up
bank
accoun~
for
U~itcd
Trade
International, 'Inc., at a bank in Alexandria, Virginia?

did instruct?
14
'A.
If
,15
0.
.Yes.
16
A.
No.
17
0.
You . did not.
Were :y_ou at any time ever aware of the existence of .
18
19'
such.an account 'in the
20
at the
21
Virginia?-
Al~xandria
of ;united Trade International, Inc
narn~
.,
National Bank located ' in Alexandria,
22 . .
In brief discussion I was told.
23
\lith whom did you have such a brief 'discussion?
24
Hr. Holcomb.
25
'But .your testimony is you did. not instruct him or

Castillo & Castillo
--
R~lstered
Profrssional Rrporters -
. 219 N,W,'12TH AVENUE MIAMI, H.A. 33128

TE_t., 324-6311
--- - ----~~~--~---------- ~--~
31
authorize
hi~
to- open up such an account for United?
Didn't have no authority with United.
But you were aware that such an account did exist
because of the -brief conversation with Hr. Holcomb?
A.
Mr. Holcornb--I don't remember the date--asked me fo:r:
some money--
MR. RICHMAN:
Would you read back tho question to him.
Because you have gone off into some kind of an
10
Mr. Soqhanalian, answer the question.
explanation, or whatever, but the question juat calla for a
1t
12
BY HR.
13
14
16
17
18
21
"r
f}
2-5
A.
Previous :from his telling me, you mean?
Well, tell rne about what he told you.
Well, he told me that the cornpany has some expenses
should make some loans.
20
24
Were you aware of the exis-
and 'they are not able to meet their payments, therefore I
19
23
And my question was:
tence of such an account?
15
22
ANDRm'lS:
'
Didyou do so?
A.
Yes, I did.
Did you cause a deposit of
~onies
to the account of
United Trade International, Inc.?

A
No.
Did you ever deposit any monies to an account of

Castillo & Castillo
- Reyisrued Professional Reporters 219 N.W, 12lH AVENUE MIAMI, H.A, 33128
T~l.. 324.-6-311
32
United International, Inc., located at the Alexandria Bank?

2
A.
no.
No?
A.
No, notme.
Q.
l1hat do you r.tcan, "not me?
7
8
9
10
knowledge that someone else did and-A.
deposited it.
~
For the purpose of depositing it to the United
account?
A.
Yes.
12
So Mr. Holcomb was merely--
13
A.
-In charge of whatever he was .doing.
14
But you gave him money and then that money he put in
the United account?
16
A.
Yes.
17
In Alexandria.
Did you-ever instruct that any of your own personal
18
19
expenses be paid from .that account, such as your American
20
Express card or your Master Charge?
21
A.
I did not advise him to pay any American Express,
.22
United--I mean expense card, but he was doing that1 that wao
23
his .management duty .
24
I give the money to l1r. Holcomb and he went and he
11
15
't
I taJ:e it you have
25
Well, do you have any knowledge that your American
Express account may at any tine have been paid through the
Castillo & Castillo
-
Reglstued l'rofrssional &pollers -
219 N,W, 12TH AVENUE MIAMI, FlA, 33128

Tt ~. 324-c>31 1
-,7
33
United Trade International bank account?

If I would do any.work for them, yes, travel for
2
3
them.
Did that occur frequently?
Yes.
And did you then instruct or request that these
expense~
be paid fror.l that United bank account?
A.
No, I didn't instruct.
0.
Well, hou did it happen?
10
A.
Well, he was sort of paying the money back to me,
11
the money -that I was loaning him to the company.
12
13
14
I see.
The monies that you gave him to deposit to
United to meet expenses-A.
When he had the money and I had any obligations he
15
wouldpay that money for, if I had to pay anybody, and deduct
16
it from whatever the money they owe me.
17
Did you ever instruct that other.bank accounts be
18
opened here .in Dade County, Florida, in the name of United
19
Trade International, Inc.?
20
A.
21
22
.23
24
25
No, I did not instruct.

Were you ever aware of the existence of any bank
accounts under the na~e of United ' Trade?

A.
Yes.
Where were they located?
What banks were they
established in?
Castillo & Castillo
- R<>gisttred Proftssional Rtporters219 N.W. 12TH AVENUE MIAMI, H.A. 3312$
TEl 324-{;311
34
MR. RICli!-iAN:
I instruct the witness not to answer.
It's the same question again about garnishment, as to what

3
bank accounts there were of these companies in Dade County,
Florida.
MR. ANDREWS:
No, I think we are clearly establish-
ing some link between this defendant and these accounts and
that is exactly the direction that I want to go, as I origi-
nally announced to you.
BY MR. ANDREWS:
10
Now, I ask you again:
You statcdyou were aware of
11
United Trade International, Inc., bank accounts in Dade
12
County, Florida.
13
A.
Yes.
14
Did you ever deposit monies to these accounts?
15
MR. RICHMAN:
You can answer that.
THE WITNESS:
No.
17
18
19
BY MR. ANDREWS:
Q.
bills be paid from these accounts?
20
21
22
Did you ever instruct that any of _your personal'
I did not instruct anybody at the United Trade to do

anything for me.
Q.
\'1ell, .do you have any knowledge that your personal
23
accounts may have been paid through the United Trade
24
International?
25
Yes.
Castillo & Castillo
~ R~lstutd hof<>ssiona/ R<>porurs 2t~ N.W. 12TH AVENUE MIAMI, H.A, 33128
Tt\., 324-6'31 I
35
You do.
2
Was Aceta Goustanian an authorized signatory, if yo
know, to the United Trade International bank accounts in Dade
County?
5
6
Yes.
' Q.
Do you know how that happened to occurr did you
instruct that that be accomplished?
I did not instruct.
Do you know how she could .have come, your secretary
10
to be a signatory to these accounts?
11
Yes.
12
now?
13
Mr. Holcomb carne down to Miani with his employee,
14
Mr. Reynolds Williams, and he opened an account in the name
15
of United Trade International to
16
~aintain
part of the aircraf
maintenance and stuff like that here, to be deposited money.

I
17
And they have leased the aircraft to certain coMpany here7
18
whenever there was revenue that money should go to the accoun
19
and they will withdraw the rnonoy from that account to
20
Washington, where they had all main assets and main bookkeep-
21
22
23
, ing and. everything.
And they opened petty cash account for
minor expenses.
And they .had to have somebody to sign for that
24
account and they find out Hiss Aceta Goustanian trustworthy
25
and they give her the signature.

Castillo &. Castillo
- Reyisreud Pro/tmional Reporters 219 N,W, 12TH AVENUE MIAMI, H.A, 3312S
T1. 324-63\1
36
-:r
Was that at your suggestion?
A.
No.
Mr. Soqhanalian, are -you in any way associated with
a company known as Airtrade (UTI) Ltd.?
A.
Where?
Q;
Anywhere.
A.
Yes.
Oid you cause the formation of this company?
A.
Yes.
10
Are you the principal owner of that company?
11
I am, you know, owner, part owner of the company.
12
How rnuch do you own of tho company?
13
A.
90 percent.
14
Who owns the other ten percent?
15
A.
Oivided by Cypriots and my son.
16
~fuat
17
A.
To transact and do business in Cyprus.
18
What type of business?
19
A.
.20
21
22
2.3
24
25
was the purpose of forming this company?
Any kind of business, import-export, transit, leas-
ing, chartering.
~
What is the significance, if any, of the UTI indica-
tion in the name of that company?
Does it have anything to de
with United Trade International?

A.
No.
Nothing~
What does it mean?
What was the
Castillo & Castillo

-
R~l$ftrtd
Professional Repo!ltr$ -
219N.W, 12TH AVENUE MIAMI, H.A, 3312.8

.,.~ '
. ~-... .,..,.
.,_,
37
.,
significance of putting UTI in the .name of that conpany?
1>.
It' s not UTI J it's Uti.
Q.
A.
Uti, yes.
Q.
What language is that a word of?
A.
It's a name that I like.
Q.
It's a name you made up, Uti?
A.
Yes.
Q.
u-t-i?
10
11
BY MR.
MR. RICHMAUa
I'r:'l sorry, now you said U'l'I.
THE WITNESS&
Uti.
ANDREWS 1
letters are u-t-i 1 correct?
16
Yes, correct.
17
That's a word that you liked and you
18
19
Is it
However, whether you pronounce it as a word, the
14
15
It's a word?
UT or UTI?
12
13
see.
~ade
it up,
Uti?
A.
Yes.
20
And it has no significance other than that?
21
No.
22
t<Jhen was this company formed?
23
MR. RICHHANt
24
(Discussion off the record.)
Off the record.
25
Castillo & Castillo
- Regi'stu(d hof(ssional R(por/(f$ 219 N.W. 12TH AVEN:JE MIAMI, FlA. 3312-8
TEl. "3246311
38
-,
2
3
BY MR. ANDREWS z.
Q.
My question was, Mr. Soghanalian, when was Airtrade
(UTI) Ltd. formed?
I think it was .1976.
Has this company ever engaged anyone in the United
6
7
States to perform services for it?

A.
Yes .
Who?
Reynolds Williams.
10
11
12
Q.
When?
A.
1977.
Q.
\ihat did it engage Mr. "'lilliams to do for it?
13
14
To transact on its behalf.

0.
Transact what?
15
On one occasion to issue or sign papers.
16
All right.
17
ba~k
to that a little
Has this company ever maintained any offices in the

United States?
20
no.
21
To your knowledge, has this company ever been
22
23
....
later.
18
19
We will come
registered anywhere in the United States to conduct business?

A.
No.
24
Where is this company registered to conduct business?
2.5
In Cyprus7 Nicosia.
Castillo & Castillo
--
R<>gist~r~d.Prof~ssional
Rtporms-
21$ N,W, 12TH AVENUE MrAMI, Ft.A, 3.3128
TEL, 324..6311
As far as I know.
'
And what was the name of the city or
place in which
.it-A.
Nicosia.
In the formation.of this company was it your inten-
tion to
you have described that you are otherwise engaged in earlier
11
12
13
14
utili~e
this company in the business activities that
in this deposition?
A.
Well, that was the purpose of doing business in
Cyprus.
~
But you have testified also that this
co~pany
employed Mr. Williams to perform certain services for it.
15
A.
Not employed, nor authorized.
16
Authorized Mr. Williams to perform certain services?
17
A.
not services.
18
Tell
A.
Authorized Mr. Williams to sign.
To sign for it?
A.
Yes.
Does this company maintain any banking relationships
19
20
21
22
23
24
...
. .,
10
ized to conduct business .under Cypriot laws?
--------~-------3~9
Is the company presently in goodstanding and author
25
~e
what--
in this country?
A.
No
Now, ue have been discussing United Trade

Castillo & Castillo
R~isru~d Prof~ssional R~port~rs 219 N.W. 12TH AVENUE MIAMI, FlA, 33128
-T(J... ~l24-6-3H
40
International, Incorporated.
2
Is this company, Airtrade, a
subsidiary of United Trade International?
No.
Do you have any knowledge .of Airtrade ever having
been characterized as .a subsidiary of United Trade
International?
Not to my knowledge.
Q.
with a
Now .. let's turn to another company.

cornpa~y
Where?
11
Anywhere.
12
Yes.
13
All right.
When and in what circumstances did you
become familiar with this company?
15
Tomake some inspections on certain aquiprnent.
16
17
\'las in '7 77 and also 'they "had done other inspcctione
18
19
20
before that, '75, '76.

0.
Well, if you know, who were the principals in this
company?
21
I know an employee in the company.
22
Who is that?
23
Mr. Kamil Harmouch,
24
Hhere does he live?
25
In Beirut.
K-a-m-i~l
H-a-r-m-o-u-c-h.
Castillo & Castillo

R~i$ttrc>d Profc>sslonal Rtporters 21$ N.W. 12TH AVENUE MIAMI, H.A, 33128
Are you familial
known as Browning Precision Tool Company?
10
'14
I do not recall.
Ttl.. o3"24-6.311
2
3
His address is in Fourn-el, F-o-u-r-n dash e-1,

c-h-e-b-a-k.
Do you know his address?
Is he the only person you know connected with

Browning Precision Tool Company?
Yes .
lihen did you become acquainted with him?
I know him a .long time ago, many years ago.
Is
10
he the only person you have ever dealt with in
_this company?
11
As a principal, yes.
12
Anyone else come to ,your mind?
13
~hey
14
Do you recall the names of any of them?
15
There was one by the name--there was one by the
had.employees.
16
name of Manoug, M-a-n-og or n-o-u-g.
17
Ghassan, G-h-a-s-s-a-n, Bassil, B-a-s-s-i-1
18
19
Anyone else?
A.
20
21
24
2_5
Those are the two that I know.

Arc they
A.
22
23
There was another one,
~ll
located in Beirut?
Yes .
Are you familiar .with the premises located at 276
Southwest 33rd Court in Fort Lauderdale, Florida?

A.
Yes.
Did you ever lease those premises?
Castillo & Castillo
Rrgist~r~d Pro/~ssional R~porms 2l9 N.W. ,2TH AVENUE MIAMI, H.A. 33,28
Ttl.. 324-6311
42
No, I did not lease the premises.
2
3
4
5
6
8
9
10
11
12
13
14
15
16
17
18
19
20
Did you ever pay any leasehold-or rental ,payments

for those premises?
A
around here, in Miami.
At whose instruction or request was this done?
ur. Holcomb.
.Q.
Who told Mr. Holcomb to do this?
Who told Mr. Holcomb?
Q.
Yes.
To do that?
Q.
Yes.
.,.,
i
25
'To do what?
You mean--
0.
To r:take payments for the prcnises.
The company .needed a warehouse,
guess, at that
time when they purchased the aircraft, to put the seats that
they took out of the airplane, to put them somewhere, because
they were--they told us, or they asked us if we want--we wore
using the aircraft1 if we want to use it with the seats in it
or without the seats.
We said, No, without the seats."
22
24
This was years ago.
{\
21
23
It was paid by QRC, and several times when I was
So then they went--they leased this warehouse to

put the seats in it.
Q.
Who didl QRC?
Was done by--either by Jim Cunningham coordinating

Castillo & Castillo
R~lsttrtd f>roftsslonal Rtporrtrs 219 N,W, 12TH AVENUE MIAMI, H.A, 331:iS
.-
TEl.. 324..6311
43
with the captain of the aircraft or what.

2
3
4
Did you ever arrange for Drowning Precision Tool
Company to lease or rent these premises?

You .mean to.QRC or me?
DrowningJ did you ever arrange for Drowning to--
I didn't instruct anything to QRC to lease it or--
lease it or not lease it.

~
Do you have any knowledge whatsoever of Browning
10
Precision Tool Company ever 'leasing, renting, occupying, hol
11
ing themselves out to occupy those preciscs?
12
In one occasion when Drowning Precision of Lebanon
13
needed an address here. in United States to certify certain
14
equiprnent,with Mr. Holcomb's suggestion they use the address
15
of that address you.re talking about.
16
17
18
19
20
Did you arrange this?
I have introduced the company to Mr. Holcomb.
Who did you introduce to Mr. Holcomb?
Browning Company, the name.
Well, whoJ anyone in particular?
21
tain names in connection with Browning.
22
to any particular person?
23
24'
f
~
I just don't know how it happened, but it was handled by QRC.
['
I just--you know,
25
No, just the company.
How did you do that?
You have named
Did you introduce h
What do you mean, how did' I do that?

Castillo & Castillo
-
R~lsmt>d
ho/t>sst'onal Rt>portt'rs -
219 N.W. 12TH AVENUE MIAMI, H.A, 33128
Tu. ~24~3n
44
~
-How did you -effect this introduction?
A.
By telephone.
0.
What did you say, do. you recall?
A.
What did I say?
0.
Yes.
4
5
Did you say, "Hello, John, and then what did
you say concerning Browning Precision Tool Company?
they needed an address in the United States.
Mr. Holcomb?
A.
lihat did you telll
I talked to Browning people on the phone.
tO
Who?
11
The Browning people.
12
What people?
13
In Beirut.
14
What people?
15
Mr. Harmouch, through my employee in Beirut.
16
What was the nature of that conversation?
17
A.
18
Who did you talk to on the phone at Browning?
To go and, inspect certain equipment in Portugal.

Were you requesting Browning to do this?
19
Yes.
20
Okay.
Now, you had made this request of them and
21
we are trying to get back to your introduction of people in
22
Browning to Mr. Holcomb concerning--
23
A.
NoJ I talked, to a person to get in touch with Mr.

I'
24
Harmouch, and Mr. Harmouch carne to the phone two days later
25
and he called me.
And he said they are not registered in

Castillo & Castillo
- Regisrutd ho/tsslonal Rtpontrs 219 N.W, t2TH AV(NU( MIAMI, f'l..A.33t2S
Tt:l... 324,63\1
You said
45
United States, they do.not have addresses.
2
3
And .I said, "Services is not going to be dona in

United St~tes, this is for overseas."
5
6
So he said, we do not
hav~
any address right now,
'because it was a war and he could not go and get any of his
paperwork from the office.
And I passed--then I passed a message to Mr. Uolco
"The people don't have an address here.
their paperwork."
10
They do not have
And Mr. Holcomb suggeeted that they could
use the address of the warehouse.
'11
And we went back again in two
d~ys
got--I nean I ~ot verbal approval of Mr. Harrnouoh to authori
13
Mr. Holcomb to use that address that you have, that you are
speaking about.
15
.Yes 1 Southwest 33rd Court.
16
Yes.
:And they have used it with the permission of
17
Mr.
18
Mr. Holcomb did print letterheads for this company.
19
he has instructed Mr. Reynolds Williams, which he went and
20
he print the papers.
21
Portugal.
Uolco~b.
And as far as the paperwork was concerned,

I
think
And they have sent an inspector to
22
Uow, were any--
23
And they signed the papers, an4 then they send
24
25
additional signed papers with the trust of Mr. Holcomb and

and then they filled it up.
Castillo & Castillo
-
time and we
12
14
R~lstfrfd Pro/fssional Rtporrus .-
2t9 N.W. 12TH AVENUE MIAMI, FI..A, 3312$
Tto\.. 324-~>'311
~--------~------------------~-~------~-4-6~
Now, in connection with their usage of these premis~l
Q.
2
in Fort Lauderdale, were
your knowledge, between Browning and yourself or QRC concern-
ing their usage of that address?
~ny
written instruments executed, to
Excuse me, yes.
And what were those instruments?
8
9
A.
They were certifying certain machine guns and-MR. RICHMAN:
I'~
sorry, I don't think .he under-
stood your question.
10
MR. ANDREWSs
Right.
11
HR. RICHMAN s
liould you rephrase it for him.
12
BY MR. AUDREHS a
13
Even though you have been telling us certain inci-
14
dents or about certain incidents, I want to go back again to
15
the occupancy and/or usage of the Fort Lauderdale address.
16
You have told me that you introduced Browning to Mr. Holcomb.
17
18
19
Yes.
And that thereafternrowning utilized these premises
at least for address purposes.
20
Uh-huh.
21
And my question iss
concerning their utilization of
22
those premises, their occupancy or nonoccupancy or
23
using it as an address, were there any formal documents signee
24
attending their usage, like a lease?
25
No, not to ny knowledge.

Castillo & Castillo
-
R~lsrered
"frofrssional Rrporrers -
219 N.W. 12TH AVENUE MIAMI, Ft..A, 33t2S

TEL..
324~31
~ercly
47
Okay.
Now, you have mentioned earlier that--or did
you?
Was this company in any way registered to conduct busi-
ness in the United States, to your knowledge?

No, the Beirut company was not, but since I was
getting ready to qive up the hope in Lebanon for the politica
settlement, I liked the name and I registered--I give instru
tions to the attorney here, Mr. Schneider, to .form a corpora-
tion and give me the major shares.
Of Browning Precision Tool Company?
10
Yes, sir.
11
Did he do that?
12
Yes.
13
And when did that occur?
14
A.
15
16
78.
And was that

A.
Florida corporation?
Either Florida or Delaware.
I do not remember.
17
You don't recall?
18
No.
19
Are you the only shareholder?
?0
No, I'm partial holder, and my son is, also.
21
22
23
What part do you own?

I don't knowr either 75 or
.0
so,
because--
lihcn was 'this company formed, do you recallJ in 197 ?
24
Yes.
25
Now I
w~nt
to talk for a moment about the Browning

Castillo & Castillo
- Rtgi'srmd l'ro/fsslonal Rfportus -
2\9 N.W. 1.2TH AVt:NUE o MIAMI, $t,.A, 33128
TEL. 324-.63\1
48
people that you described in Lebanon in 1977, and I want to
.2
know, so far as you know, exactly -what business did Browning
Precision Tool Company engage in in 1977.
MR. RICHMAN&
What did it do?
When you hit a good break point, when'
you go into another area, why don't we take a break?
been goinc; .for an hour and a half.
MR. AUDREWSs
He will do it right now and we
will come back to that question.
9
10
Fine.
.we have
(Thereupon a short rocess was taken.)

BY HR.
ANDRE~1S:
11
We left off with the question of what precisely
wa~
12
the business of 'Browning Precision Tool company as you knew i
13
-in 1977.
14
Again, this is about--
15
The fellows that you described in Lebanon.

Oh.
''they are adjuster for accidents and they are
17
also, especially Mr. Gbassan, that I -know, he's expert on
18
weapons.
19
The same with Mr. Harmouch.

Well, -what business activities does the company--
20
you told me now that two people arc experts- on weapons and th
21
they adjust accidents, .they are accident adjusters.
22
They are accident,adjusters, and if someplace, you
23
know, takes fire and all that, they go there and inspect and
24
tell to close.
25
They are experts in evaluating material.
Incidentally, did you have an interest in the Holi

Castillo & Castillo
~ Rrgisrerrd hofrsslonal Rrporurs 219 N.W. 12TH AVENUE MIAMI, H.A, 33128
Tft... 324-6311
49
Inn- in Beirut .that was bombed out?
2
A.
3
4
No.
No.
It just occurred to me they
m~ght
have done
some adjustment for you there.
-5,
Back again, Mr. Soghanalian, to the business of
Browning Precision
accident adjusters and that two named principals of the com-
pany
beyond accident adjustment services?
10
11
~re
A.
15
16
Company.
weapons experts.
You had said that they arc
Now, what does the company do
I told you, they are experts in machinery
ev~luatingr,
condition of engines, wear and tearJ mechanical engineers.
12
13
~ool
Why did you bring up the weapons?
Are they experts
at evaluating weapons?
A.
Yes.
Q.
Was that the reason for your acquaintanceship and
association with this company, their expertise in that regard?
17
Uh-huh.
18
And how long has that relationship existed?
19
Yes.
When
did it first begin?
20
I knew Ghassan in 1954 and I knew Harmouch in 1956.
21
In association with this company, Browning Precision
22
Tool Company?
23
No.
-24
You know them individually?
25
A.
I knew them individually.
~hen
Castillo & Castillo

-
Rtglstu~d
'E'rof<>ssional R<>porters-
219 N,W, 12TH AVENUE MIAMI, FLA. 3312S
'TtL. 324-6311
when I went back to
so
Beirut .I met them aqain and they told me where they.re workinq
,
1
what they're _doing.
When was that?
When I first went back, in '64.
Uhen did they first perforr:l any services for .you as

weapons experts?
A.
'1971.
0.
Do you have current business relationships with this
10
company?
11
A.
No.
12
0.
When is the last tirne that thoy performed any ser-
13
vices for _you?
14
Tho year was
15
0.
Wasthat in connectionwith matters attending this
16
77.
lawauit?
17
A.
Yes.
18
0.
That's the last time they performed any services
19
for you?
20
A.
Yes.
21
0.
Are you familiar with a company known as United
2-2
23
24
.-
And then I saw
them again in 1971.
What year was that?
25
Trade International Air Cargo.Limited?

A.
I would say two things.
This needs explanation if
I may have your permission

MR. RICHMAN&
Go ahead and explain to them what it

Castillo & Castillo
-- R~lsrmd ho[t'ssional Rt'porrus -21~
N,W, 12TH AVENUE MIAMI, FLA. :3312S

-TEL. 324-63,
51
is.
2
MR. ANDREWSs
You have mine.
THE WITNESS:
Yes, undoubtedly.
In 19--first part of
,4
77 or last part.of '76, when
UTI, so-called United Trade International with abbreviation
of UTI, ceased flying because of the conditions, war condi-
tions of Lebanon, and the crews that are sitting there con-
tacted Mr. Cunningha~, who was working for QRC International,
Mr. Cunningham suggested that if they would get any charter
10
business over in Europe, "Go ahead and negotiate and consult
11
me back"--I mean Mr. Cunningham--"but don't sign anything.

Captain Kamm, in order to have--no, no, the captain
12
13
w&s Krumm (phonetic) at that time, yes--went and printed
14
papers saying United Trade International and he did put "Air
15
Cargo" in order to advertise himself as they do cargo busi-
16
ness.
17
When they didn't qencrate any business, they cane back to
18
Miami, and those letterhead papers came with them.
19
also printed cards for each crew member under that name.
20
indicated himself "General Managcr"J another one indicated
.21
himself as captain."
22
And then that name stayed on until they
~ame
over.
And they
One
And, you know, as f~r as the company is concerned
23
under that name, it is not registere~ as company such as Air
24
Cargo but just as an identification for the address there was
25
such a name and was being used for identification, not to

Castillo & Castillo
- Rfglstutd Proftssiona/ Rtporurs :219 N.W, 12TH AVENUE MIAML, H.A, 3312.8
TE_I.. 324-6311
52
conduct business under that name but was going under, you
2
know, Air Cargo just to say this is that department.
3
4
This is my knowledge about Air cargo.

BY MR. ANDREWS:
5
6
Well,. you have described now a crew.
You have nat.'led
a Captain Krumm.
A.
Yes.
Q.
And you have told me how the name evolved.
A.
Uh-huh.
10
Q.
Did you have any relationship yourself with this
12
A.
I was overseas agent.
13
Q.
Who made you overseas agent?
14
A.
Mr. Holcomb.
15
Q.
Mr. Holcomb.
11
name?
16
17
And when did that happen?

A.
18
19
20
23
24
25
76 or early part of '77.
What were your duties as you knew them to be as

agent for this company?
A.
21
22
I guess late part of
To do anything I could for their interest.

Well, did you ever do anything for their interest?
A.
I tried.
'Q.
Tell me about your efforts.

I do not recall any efforts, but if you.have any
specific transaction-Castillo & 'Castillo

- Rtgi'sttred Professlonal Reporrtrs -.
219 N.W, 12TH AVENUE MIAMI, fl.A. 33128
TEt.., 324-6311
53
Q.
.,. ;:,,.
'Well',. 'te'll' me, did .you .ever arrange -any transaccompany~
tions for this
A.
1 made a lot 6f negotiations.
0.
Well, give me--statt at the beginning.
one do
A.
.I went to Ecuador.
0.
When?
8.
A.
0.
~'lhy?
10
A.
'l'o see if I could. sell them
11
.Q.
Okay.
12
,thing?
13
r..
.Uh-huh.
14
0.
And you did thiG .individually or on behalf of the
15
fter ybu
A.
of7
0.
No,
received~his
tha~
first
appointment?
any~hinq,
.to the Army.
To see ifyou could sell Ecuador'n
company or the name
16,
18.
yo~ ~ecall
Wh~t
Ar~y any~
we are talking.about?
did it individuall
Uell,
want 'to go back to your services to this
company, United Trade International Air cargo
~i~itod~
Of
which you have 'told us this . !'lorning that you were .the overseas
agent.
21
Uh-huh.
What didyou do for them?
'23
24
25
,90
back
t~
the
.be~innin~
and. toll me
And I .have asked you .to

whe~
you first did some-
thing for .them.

I -went--I didn't go for Air .cargo
Castillo & Castillo
"'!"'
/?.t"glsr~ud Prof~ssional R~portus-
21~ N,W,-12TH AVENUE ":HAM!, H.A.3312-8
TEL. 324-6-311
Limited~
C:A
Where' to Ecuador?
A.
YeG, I went ns Sarkis Soghanalian.
l,,
Let's stop there for a moment and get on to any
other effort that you made in behalf of this company, if you
did.
your words.
You have said that you tried.
I believe those were
uow, what .did you try to do for ther.1?
Buy gasoline for their aircrafts.
All right.
9
10
Where did you buy gasoline for their
aircraft?
A.
11
In Madrid, in Portugal, in
What aircraft was this?
12
A.
Yes.
13
Q.
What else did you do
Leb~non.
Was this N711UT?
forthe~?
14
I don't remember.
15
Did you at any time arrange for this company to
16
utilize the premises at 276 Southwest 33rd court in Fort
17
Lauderdale?
18
A.
19
If I did use the premises, you say?

Yes.
'You recall you. told us quite a bit about the
20
warehouse in Fort Lauderdale.
21
recall.
That!s the same address you
Did you ever arrange--
22
A.
I went there several times.
23
Q.
Now, you have told us how you arranged for Browning
24
to use those premises.
25
International Air Cargo Limited to similarly utilize those
Did you ever arrange for United Trade
Castillo & Castillo

- Rrglsttrtd Professional Reportu$ 219 N.W. 12TH AVEI\jUE MIAMI, H.A. 33128
TEL. 324--6-3t1
55
premises?
2
3
The premises was already there before I came over

1;0 Miami.
8
9
10
11
12
13
14
Q.
I know that, Mr. Soghanalian.
A.
Q.
Oh, it did?
A.
Yes.
0.
United Trade International Air Cargo Limited?
A.
Not Air Cargo, you know.
0.
I'm talking about Air Cargo Limited.
A.
That Air Cargo name was allowed or not allowed by,UTI,
mean, the company already had the warehouse.
Mr. Holcomb, or not, I do not know, but itwas just named that
by the captain of the aircraft1 I mean, telling me to use it.
I used that for--as an address but not for the purpose of
running a business under that name.
16
17
But you arranged for Air cargo Limited to usc that

address?
18
19
I did not--I didn't have any authority to allow or

not to allow.
20
Well, that is my question.
21
22
A.
I used that as an address with the permission of
one.
23
Wh~le
24
25
Did you ever arrange--
representing Air Cargo Limited?
While representing United Trade International overseas.

Castillo & Castillo
- Rt>gisttred Professional Reporters 219 N.W, 12TH AVENUE MIAMI, 1'L.A. ~3128
TEL., 324,e~311
56
~
Overseas.
Now, we are talking about, again, United

\
Trade International Air cargo Limited.

3
4
You utilized that
address at 276 Southwest 33rd Court-A.
Just as a mailing address, yes.
Mailing address.
And Mr. Holcomb afforded you your authority as an
agentJ is that correct?
9
10
Yes, as United Trade International, Inc., overseas.

Q.
But you state that you never owned any interest in
this entity, whatever it was?
11
Which?
12
United Trade International Air Cargo Limited.
13
There was nothing to own.
14
But you had no connection other than you have just
15
It was just an address.
indicated?
16
Just as an identification.
If I go to a .hotel I
17
put, you know, Hilton 'Plaza or Rockefeller Plaza becauce I
18
stay thcrOJ I use that address.
19
20
21
22
23
24
25
see.
Now, other than buying .gasoline for the N711UT, did

you do anything else for this company?
A.
Spend the money on the maintenance overseas,
accommodations, rooms in hotels overseas.
In more than one
occasion, two, three or four times, getting them charter

flights to various parts of Europe or Africa.
Castillo & Castillo
-
R~lstert-d
fro[t'ssional Rt'porrt-r$ -
219 N,W, 12TH AVENUE MIAMI, f't.A. 33128

Tt:\.;324~311
Those arc the
57
services that I did.
2
3
Now, Mr. Soqhanalian, are you acquainted with Mr.

John Ralph, a principal in this existing controversy?
A.
~e,
if I know him?
Yes, do you know him?
A.
If I know--excuse
Yes, I kno\\ him.

All right.
Now, if I may, I would like to show to
you--
First I will show it to you, Jerry.
10
This is a copy of a telex directed to your atten-
11
tion dated May of 1977 !rom Mr. Ralph, the same being Exhibit
12
1 to plaintiff's Complaint, .Jerry.
14
15
You have seen that before.
MR.
RICHl1.~N:
Is' this about the clearest copy you
MR.
ANDREWS&
That is the clearest that I have, and,
have?
'16
certainly, let it be reflected that it's not clear, perhaps,
17
in some measure.
18
BY HR. ANDRBHS&
19
20
21
22
I ask if you can identify that copy of the telex

which you have before you.
MR.
RIClU-iAN:
This is the same one as Exhibit 1 to
the Complaint, right?
23
MR. ANDREWS:
Yes, it is.
24
MR. RICHMAth
The question is 1 have you ever seen
25
this before, this telex.
Take your time and look at it.

Castillo & Castillo
-- Regisrtred /'rof(ssionol Reporttrs 219 N.W. 12TH AVENUE MIAMI, FlA, 33128
rer.. 324-~f311
58
THE lUTNESS:
2
BY UR.
.Q.
Did you, .in fact, receive that telex?
No, it was read to me by Mr. Holcomb.
But you recall that the contents of that telex were
6
7
A't:ORE\-lS:
communicated to you?
Yes.
8
9
MR. AUDREWSa
10
(The copy of telex referred to was marked by the
11
reporter as Plaintiff's Exhibit No. l for Identification.)
12
BY !.SR.
13
ANDREl~S
Now, I next show to your couhsel and to you a copy
14
of a telex--the copies are getting worse--dated May 7, 1977,
15
directed to Mr. John Ralph and purporting to be with your
'16
regards,
17
copy of the telex?
19
s.
Soghanalian, and I ask if you can identify that, a
Incidentally, that is Exhibit 2 to plaintiff's

Complaint in this matter.
20
Yes, I recall this one.
21
Q.
Did you, in fact, send that telex to Mr. Ralph?
22
l1R.
23
(indi'catinq).
24
'
Will you mark that for identification,
please.
18
'
I remember this telex, yes.
25
RICHMAN a
MR. ANDRBWSa
This says "Boca Investments" here
To the attention of Mr. Ralph.
does it say at the topJ J. E. Ralph, Boca Investments?

Castillo & Castillo
- Rtglstmd "frof~sslontJI
R~port~rs ,_
:2t9 N.W. 12TH AVENUE MIAMI, I'J,..A, 33128

TEJ,...324-6311
What
59
MR. RICHMAN:
The question is did you send that to Ralph on or
2
3
about that date.

THE WITNESS&
RightJ 7 May 1977.
I talked by the phone and I did tell
Mr. Holcomb to send this telex.
MR. AUOREtiS 1
Will you mark that for identificatiol), .Please.

(The copy of telex referred to \fas thereupon marked
by the reporter as Plaintiff's Exhibit No. 2 for Identifica
10
tion.)
11
BY 'MR. A!H>REtiS 1
was the May 7th telex in response to the previous
12
13
telex that you have identified?
14
15
All right.
Uh-huh.
Q.
Now, both-of those telexes at one point mention--
16
the initial one to you, or to your attention, rather, speaks
17
of making an inspection of the merchandise, the armaments
18
specified in it, and
19
the need, inspection will be madeJ and the second telex that
20
you have identified here speaks also of arranging an inspcc-
21
tion in JuneJ is that correct?
22
23
24
2-?
Mi~
MR. RICHt.SAN:
documents speak for
Ralph specifies if you can satisfy
I m sorry J \fhat is the question?
"the~selves,
MR. ANDREWSc
The
whatever they say.
I understand that, but what I want to
do--my ns>:t question, I think, will clez:.r the air.

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60
BY MR. ANDREWS&
2
3
Both of those telexes, do they not speak of an

in~pection
of certain armaments?
Is that correct?
This one speaks for an inspection here (indicating).
MR. RICHHANs
MR. ANDREWSa
MR. RICHHAHa
13
'16
Okay.
Now, my .question iss
Did such an inspection there-
after occur or any such inspection?

A.
14
15
"our client government is
BY MR. ANDREWS 1
11
12
Let's see.
waiting to inspect."
9
10
.don't know if Exhibit 1 mentions anything about inspection.
The second one does, Exhibit 2.
Yes.
Will you detail for me the circumstances, as best
you can recall, of such incpection.

A.
After this telex, I went to Lisbon and I met
17
Captain Anne, A-n-n-e, from Mauritania Army, to come and
18
inspect the 30 machine guns that is identified here (indi-
19
ca tin_g) and--
20
21
HR. RICHUANs
machine guns.
Do you
To clear the record, you said 30

m~an
.30 caliber or what?
22
THE WITNESS&
It was a quantity of 30 machine quns.
23
HR. RICIUU\N s
Okay.
'THEWITNESSs
And Hr. Ralph was supposed to come and
24
25
I want to make sure we are
clear.
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61
.Y-~---------,
work with the export license.
BY MR. ANDREWS:
3
4
No, I'm talking about the inspection now.

tion was:
5
6
A.
Did such an inspection occur?

Yes, I
took the captain to the naval base and he
inspected the machine guns.
7
8
9
10
My ques-
0.
Where did this occur?
A.
In Lisbon.
0.
Who arranged for you to meet the captain?
Did you
'know the captain?
11
A.
The captain was waiting at the hotel.
12
0.
Who arranged that?
A.
Yes.
0.
And this occurred in Lisbon, and it occurred at what
13
14
15
16
point in time after that responsive telex of yours?

that is dated what, May 7 or 27?
17
18
MR. RICUMAH:
copy.
19
20
Did Mr. Ralph arrange that?
I don't see a
Now,
It's a little unclear.
It appears to be dated Hay 1 on this
2.~
MR. ANDREHS:
In any event, let's categorize it as-
THE WITNESS:
I don't remember the right date, but I
May.
21
22
23
24
25
remember going there and taking the captain to the base and
inspecting the weapons.
When you said--excuse me--how it was arranged to.
meet the captain, I had a phone call from a guy in Paris who
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was interuser" .of Ralph in -Mauritania.

..,
BY 'MR . ANDREWS:
.What was his- name?
A.
'I wouldn't remember his name.
5
6
Anyway,. he said' the .captain was
and inspected .the weapons.

Well, let's .qet that to more--
Q.
You speak in -that
.9
telex of atranqinq. an inspection in-June.
10
refresh yourmemory if it.needs to.be refreshed.
.say
14
15
16
That is
~ound
to
Or docs it
J~ly?
12
13
fo~
the weai>ons, and .I took the captain to, 'the base the next day
11
there
wa~tinq
MR. RICHMANa
say June.
.It's 'hard to read, but it'.appears to
.Actual'ly, what it.says is--to be clear, it says
:after aornethinq or other, June--looks like there's .a day

there but it doesn't appear to,be leqible.
.BY MR.
ANDREWS:
17
Now, let .me ask -you specifically,. after that telex ;
18
was sent did you arra.n9e for a personal meeting between your--.
19
self, Sr. :Ralph and =a representative of tho Mauritanian

Government _in washing"ton, o. c.?.
21
A.
22
Mr . Ralph and who?

And a representative. of the
23
Captain Ahmadeu Anne.
.24
July?
.25
Mauritania~
Do .you recall meeting them in early
.Yes, I do.
Castillo-& Castillo
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.63
.i
In Washington?
A.
Yes
What was the purpose of that
-~
.d
s:
0.
Governmen~.
Were those the same items detailed in Mr . Ralph's
telex to yoti that youpreviously identified?
,g
I see.
10
And the reason they came toWashington--
11
Tho purpose of that meeting was- theyhad a list of
.several items to purcihase for Mauritanian
6
7
meotin~~
'More.
This is only one 'item.
Anyway,
yes, I met them there.
12:
Q.
Okay.
13
~.
No, QRC did.
-~
Did you fly from.Miami to Washington for that meet-
.14
15
16
;, 7
18
i'ng?
i\.
.Now, 'after
Q.
yo~r
arrival .in Wash.ingt<?n, did you then
go :to. the offices of QRC?
19
20
Q.
21
Did you arrange for accommodations?
Then. I went to the hotel.

te~~
"You were,
:M~.
identify who was
Ral~h
-pre~ent i~;Washington
was,. an4'Captain.Anne?
22
A.
23
pick~d
24
Mr . Ralph and Captain 'Anne I and also this French: .guy.
25
Q:
now.
When I arrived to the airport,. Mr. Holcomb .came and

rne up and .took me to the hotel and:introduced.m to
Whose name you-:c:.ant remember at the moment?

-~-
Castillo &_ Castillo

- Rrglsrued Professional Reportus :a~ N.W."12TH AVENUE MIAMI, FLA, 33128
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L~--~~--------------------------------------------------------~
'64
A.
2
i~enti:fy
names~
If you give me more than two or three
.I can
-two out of threo .,

Did Mrs. Soqhanalian accompany you to"this meeting?
Mrs.?
W~re
-'
No.
you accornpanied'by -anyone at this
~ee~inq?
.no,. x was .by, rnyse lf.

Do you.:recall where you stayedlthat niqht?
8
At the Marriott Hcitel.
Do you 'i:ecall who paid for ,your .accommodations?.
10
A.
11
.could it have been.United
12
13
A.
could. be.
16
Doyou know ifUnited thereafter paid that American
Express bill?
18
x think so.
19_
0.
ltow, is that. the first time ,you met Captain. :Ahmadeu
Anne, the representative of

"21
Haurit~nia?
.Yes.
22
24
I paid with--could be by
It could:or could not be?
15
.23
International?
American .Express.,
14
17
I remember I paid.
~rade
Did-you know. at that time that
he~~as
..
:tive of the Hauritani'an Government?
'
a representa-
'
He identifiedhimself'with his IDcarde

Now, was "the
,purpo~e
of Mr. Ralph and' Captain
Castillo &. Castillo

-- Reyistfrtd Proftssional Reporters-219 N,W,'12TH AVENUE ,MIAMI,ft,A.~12S
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Ari~e
6S
journeying to Washington to, in fact, inspect the armaments

2
which you proposed to furnish under those two telexes?
No, the purpose of their visit was to rneetme.
Yes.
A.
And to talk in genera1 about
arrna~ent
business.
Of course, you knew--or did you know at that time
that Mr. Ralph had
armaments described in that telex (indicating)?
a~contract
with Mauritania to furnish the ,
No.
10
You did not know that?
'11
No.
12
You have said that this telex saying I can furnish
13
was in response to this telex (indicating), and now you have
14
stated that you knew Captain Ahmadeu Anne to be there as a
15
representative of Mauritania.
16
just to meet you?
Why did you think he was thereJ
17
I don't know what Mr. Ralph told Captain Ahmadeu.
18
Well, I'm sure you don't, but what I want to know i5
19
20
A.
All I knew, that he wants to show some samples--
21
Good.
22
--of certain military
23
Was it this military .equipment (indicating)?
24
MR. RICHMAN1
25
equip~ent.
Whon you say "this, you are refer-
ring to Exhibit 1?
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MR. 'ANDREWS 1
\,
Yes
BY MR. ANDREWS:
Excuse me, the military equipment of Exhibit 1
which you have previously identified.
of -making an inspection attendant to that equipment?
A.
Yes.
Okay.
MR. AtfDREi'lSs
Was it for the purpose
Jerry, it's a little after 12.,
not get breakfast.
10
MR. RICHMAN:
11
MR.
AtlDREWSs
Whatever your pleasure is.

If we can break for lunch and come
12
back at a time convenient, I would like to do that at this
f3
point in time.
14
MR.
15
16
RICHHANs
Okay.
(Thereupon, at 12z05 p.o., a luncheon recess was

taken.)
17
18
19
20
21
22
23
24
25
Castillo & Castillo

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did
67
AF'L'ER RECESS
(The deposition reconvened at 1:30 p.m., after the

3
luncheon recess.)
4
DIRECT BXAHINZI.TION (CONTINUED)

5
BY HR. 'ANDREWS t
6
I think we left off, Mr. Soghanalian, with people
gathered in Washington for the inspection referred to in the

8
telexes.
Now--
MR. RICHMAN:
Excuse me, if we can go off the recor
10
for a second.
11
(Discussion off the record.)

12
BY MR. 'ANDREWS:
13
Now, let me ask you, did you then journey from
14
Washington to Albany, New York, with Mr. Ralph and Captain

15
Anne?
16
A.
And Anne.
And the man whose name you can't remember?
17
18
Have you remembered what 'his name is yet?

19
A.
Not yet.
Okay.
20
But, in any event, Mr. Ralph and
Captai~
21
Anne andyourself, did you then journey from Washington to

22
Albany?
23
A.
Yes.
Did you all go together?
24
25
Castillo & Castillo
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Q.
Did you arrange that transportation?
Uh-huh.
MR. RICHMAUs
Answer "yes" or "no," sir.
get the "uh-huh."

THE WITNESS:
6
7
Yes.
BY MR. ANDRB\'lS s
Q.
Now, was the purpose of this journey for making the
on-site inspection referred to in your telex of May 7th that
you have identified?
10
A.
No .
11
Q.
What was the purpose?
12
The purpose was to see a sample.
13
A sample?
14
Yes.
15
Of the merchandise described in the original telex
16
to which you responded?
17
Yes.
18
Look at those.
'19
20
'2 1
A.
I mean, if you need to.
Yes, one of the items.

All right.
Now, what was the narne of the
Numrich Arms.
23
Had you previously nade
25
co~pany
that you visited in Albany, if you recall?
22
24
arrange~ents
this inspection to take place?

Yes.
Castillo & Castillo
- Rtgisrmd ProfeHional Reporurs-:
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L
He can't
with Numrich fo
6
~
,,
...
And with whom at Numrich had you made those arrange
ments?
Mr. Ira Trust, I-r-a T-r-u-s-t.
Had you previously done business with Numrich?
A.
No.
This was the first occasion?
Yes.
And did, in fact, an inspection of any arms occur a
Numrich?
10
Yes, one sample.
11
Uow, at that inspection who was present other than
12
yourself, Mr. Ralph, Captain Anne and Mr. Ira Trust?
13
the name?
Is that
14
Yes.
15
Was he present when the inspection occurred?
16
A.
Yes.
17
Was anyone else present?
18
A.
There was one of his shop managers.
19
Q.
Do you happen to recall his nane or do you know his
21
A.
No, I don't.
22
0.
Now, what precisely was shown to Mr. Ralph' and the
20
23
24
25
name?
'Mauritanian representative, Captain Anne?

A.
One machine gun,
.so
caliber, with a tripodJ and'
also spare parts, and a tour of his shop.

Castillo & Castillo
...;. Rt>glsttred Professlonal
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219 N.W. 12TH AVENUE MIAMI, FLA. 33128
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Now, after the
.... '
what next occurred?
3
4
beca~se
Did you leave Albany? '

the~want
.to see this
machine gun here (indicating).

~ou
are referring :to Mr. Ralph's telex to you,
'being the first exhibit?
Yes, .30 .caliber.
8
9
as you have .described it,
What did. you do?
Yes, we left Albany
6 .
in~pecti~n
'Thetwanted~to
see
that~
all right.
Did you take
them somewhere to .see a _.30 caliber?

Yes, we went from: Albany, .. frorr. Numrich Arms, and we
11
came to .Miami.
'
12.
13
A.
Yj~,
14
Q.
Was this via commerci'al airline?
'15
A.
Yes.
Q.
Andwere
A.
Yes.
18
Q.
Except .Mr. Trust?
19
A.
Yes.
Q.
All right.
16
17
20
How did you come1 did you fly to Miami?

we flew to Miami.
you.stil~
all together, the
Now you .are :in Miami.
sa~e
group?
.Oi'd you conduct
:any.meetings at your residence home?'

22.
A.
Ralph
.24
Yes,. we went to my .house, and .as I explained.. to Mr.

pre~iouslyi
I told him that I cannot negotiate any ar*
deal in .United States.

When did you tell him that?
Castillo& Castillo
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I told him that in Washington previous to going to-
-Albany?
--Albany and Numrich.
.Why?
Because I'm not licensed and I was not doing any
7
8
What was behind that advice.
business in United States.

Q.
So you told'him in Washington, D. c.--tell me again
what you told him more explicitly.

A.
I toid him, I said, "I cannot sell you any weapons
10
in this country.
11
factories manufacturing those weapons here," .as he 'knew
12
before, before he came over here.
13
14
15
16
17
Q.
I was very clear to him.
"And there is no
How do you know he knew that before?

Because the Mauritanian ambassador already told
him that the production of those weapons are not valid any
more because the
u. s. Arcy dropped that class of weapons.
And I told him, "I will show you a sample here and
18
take you to a factory where they are overhauling and they are
19
assembling the weapons 'from surplus material," which was avail-
:to
able from various sources.
21
Is that what you were doing at'Nurnrich?
22
Yes.
23
He said, "Okay, let's take the captain and show him
24
something."
They were only.manufacturing the barrels.
.And I called Ira and he qot one of his rebuilt,
remanufactured machine guns and we took the captain there and

Castillo & Castillo
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72
showed him the sample.

2
Was that just the barrel or--
Machine gun,
Complete?
Complete, mounted on. tripod.
Q.
All right.
And then we flew down to Miami.
prepared to sign in
Mia~i.
10
in United States.
11
the United States in weapons.-
do not deal in
.30 machine gun?"
14
15
I'M not authorized and
He said, "Where can we show the captain the other
12
13
lie had a contract
I said, "I told you I cannot sign .any contract here
I told him, "In Santo Domingo, and also the surplus

weapons were in Santo Domingo.
16
Also what surplus weapons?
17
There arc surplus
18
0.
'19
And the French guy called his wife and his wife told
20
.so
machine guns in Santo Domingo.
see.
him that he was busy, he should go back to Paris.
21
'
ev~rything.
He went back to Paris, and there were no flights
22
going to Santo Domingo and I was supposed to go to Guatemala
23
on another matter..
24
went to Santo Domingo.
25
we
I chartered a plane.
Wo all got onboard,
a11 .being yourself, John Ralph and Captain Anne?

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,._
Anne and others7 company people, you know.
Tell me who they are, who.was present on that flight.
A.
My brother.
Yes.
A.
Sohrab,, s-o-hr-a-b, G. Soghanalian.
Where does he live?
He lives in Binghamton, New York.
0.
Okay.
A.
B Grand Avenue.
And there was Felix Rodriquez.
10
11
0.
Yes.
12
A.
And a gentlenuu1 by the name Dr. Conte, and a couple
13
other people that they were friends of Felix.
14
to Guatemala, so--
15
What is his name?
0.
They wore going
Did the accompaniment of your brother and Felix
16
Rodriguez and the doctor and the others, whoever they may be,
17
that you have named have anything to do with your relation-
18
ship up to that point with Mr. Ralph-
19
A.
No.
20
0.
--and Captain Anne?
21
A.
no.
22
They were merely going along as passengers on their
23
24
25
way to Guatemala?
A
Except Felix Rodriguez, who used to act as a trans-
lator for me.

Castillo & Castillo
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Q.
Yes.
And Dr. Conte.
What was Dr. Conte's role?
He speaks Spanish and English.
You mean the same thing, or. Conte and Felix were
gQing along as translators for you at your request?

Yes.
For the purpose of viewing the .30 caliber cachine
8
9
10
guns and also-A.
13
accurate?
A.
Yes.
All right.
14
15
.so.
--and also the .50 caliber machine guns1 is that
11
12
And
A.
And we went to Santo Domingo.
called the head-
16
quarters.
17
the surplus naterial in Santo Domingo.
18
for the captain, myself, Rodriguez, my brother.
19
We met a colonel who was in charge of the sales of

They took clearance
-And -Mr. Ralph didn't come to check the material.
20
said, "Whatever the captain sees, it's all right with me.
21
He's the one who has -to, you know, like them or take them."
22
Yes.
23
Then we--you know, we made two days' tour with- the
24
captain and he saw the weapons everywhere, where they were,
25
what the conditions were.
lte
'!'hey were in-not in good condi tior; s,

Castillo & Castillo
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but he did agree to buy the weapons and .to overhaul them.
2
{).
He approved of what--
A.
He approved.
0.
--of what was shown to him in Santo Domingo?
A.
Correct.
0.
Okay, sir.
A.
When we came back to the hotel, he oaid, ftRow did it
0.
Who said that?
10
A.
Mr. Ralph, at the hotel.
11
0.
In Santo Domingo?
A.
Yes.
12
go?"
13
And I said, "Why don't you ask the captain?"
14
They went together with the captain to talk togethe%
15
in their own room.
16
"They being John Ralph and Captain--
17
And Captain Anne.
18
And he came back and he said that the captain was
19
satisfied with what he had seen.
20
I said, "John, we can, you know, rebuild those
21.
but, I said, "I don't think the captain knows what he's
22
getting into.
23
will not serve his purpose.
24
so it's his business."
25
Those .30's are no good.
They're too bad and
But I said, "If he wants it,
He said, "What do you care?
That's what the man.
Castillo & Castillo

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76
-wants."
2
3
Q.
This is what John Ralph said- to you?
A.
Yes.
I said, "Okay."
He asked .me where the weapons--the captain asked me
where the weapons were going to be overhauled.
best place is Portugal because they have good, you know,
When did he ask you thisr in santo Doningo?
Domingo
I s&.id, "If you want to do the overhauling, it's
12
13
better to do it in Portugal."
Then he agreed.
14
15
'18
19
Then I have committed myself to the Santo Domingos,

saying that it's approved, "I will, you know, purchase what
we have inspected and get together with your people there.
We got the contract.
Now, are you speaking--let me shol'l you . at this ,point,._
20
21
I think it might be appropriate to do so--
22
23
24
25
lie said, '"As long as they corne out ,
good and we test the weapons, then, you know, we don't .care."
16
17
Yes, thenJ the whole discussion was done in Santo
A.
10
,,
said, "'Ihe
rebuilding facilities there.H
BY
l~R.
MR. AUDREHS:
Jerry, this is--
MR. RICHMAU:
Exhibit 3.
AUDREHS:
This is Exhibit 3 to the Complaint, being a one, two
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three, four page agreement.
2
I show this to you and to your
counsel and ask if that is your signature appearing thereon?
Yes, this is my signature on this.
Okay.
MR. ANDREWS:
as t:xhibit 3.
(The docutcent referred to was thereupon marked by
thu reporter as Plaintiff's Exhibit 3 for Identification.)

MR. RICHHANz
9
10
Hill you.mark that four-page agreement
Check it out.
Is that your signature
and your initials over here?
11
THE WITNESS:
This is my signature (indicating).
12
MR. RICHMAN:
Okay.
THE WITNSS:
This doesn't have my signature (indi-
15
MR. AHDREWSs
Hell, that's the first pg.gc.
16
MR. RICHMAN:
You are identifying--
17
MR. ANDREWSs
I am identifying a four-page document
14
18
'19
20
eating).
styled
"Agreement~
by its terms.
HR. RICHMAUa
He's identified hi~ cignature as appe
ing on the fourth page.
21
Mn. MiDREHS:
And it's dated July 11th, 1977.
22
MR . RICHMAN:
Yes
.2_3
HR. ANDREWS:
Okay.
24
HR. RICHI~IAN:
Counsel, you said it's dated July l'lt
25
1-lould you hand that to him.
I would note that, of course, the docurncnt speaks for itself.

Castillo & Castillo
-- Rt-gistert'd J>roftssional Reporttrs -
219 N.W. 12TH AVENUE MIAMI, fLA. 33128

T(L, 324-.6311
78
~he
It does bear two dates.
first page bears the date of
July 11th, but the fourth page that bears his signature bears
the date of July 13th.
MR. ANDREWS:
All right.
Pine.
for the purpose so we can identify it.
that the docunent speaks for itself.
THE WITNESS:
date I
Well, again, only
And I
agree with you
could possibly bo that this was the
refused when he filled this up (indicating).
MR . ANDREWS:
Well, let's not get into the data--
10
MR. RICHMAN:
Let him ask you questions.
11
-HR. ANDREWS:
--for the moment, but let me ask _you--
12
BY MR. ANDREWS:
13
14
Was your signature affixed to that document as a

result of the telexes and the inspections that you have
described to us thus far?
16
You want to repeat one more time, please?
17
Yes.
18
The description--
19
Was the executionof this document, whatever date it
20
may -have been signed--
21
And wherever.
22
Pardon me?
23
And wherever it might have been signed.
24
Okay, wherever it night have been signed.
25
A.
Okay.
Castillo & Castillo
-
R(glsm~d Prof~sslonal R~port~rs
TEL. '324-6311
79
Q.
Nas that as a. result of this (indicating)?
Of this (indicating)?
Of the telexes and the inspections.
Yes.
Q.
All right, sir.
Now, Mr. Soghanalian, the telex, the original telex
from Mr. Ralph directed to you, this one (indicating), speaks
of raising a letter of credit, and part of the provisions of
this agreement which you just identified speaks of raising a
10
letter of credit in order to effect payment
11
action.
~or
the trans-
12
Uh-huh.
13
now I want to show you a copy of a two-page document
14
which is, incidentally, Exhibit 4 to plaintiff's Complaint
15
and appears to be a commercial letter of credit, and ask you
16
if you can identify that document?
' 17
A document was presented to me--
18
Yes, sir.
19
--a copy with cut big holes without the prices.
20
I'm talking .about this now, this document.
21
identify that?
Can you
Was that ever presented to you by Mr. Ralph?
22
MR. RICHMAN:
In exactly the form it appears?
23
MR. AUDREWSt
Yes.
24
THE WITNESS:
Yes, similar to it.
25
Castillo & Castillo

- Rtgistert-d l'rofess"ional R<>portns 21~ N,W, 12TH AVENUE MIAMI, FI.A. 331:iS
TE\.,
~24-$~U
BY MR.
Q.
Was that one, in fact, presented to you by Mr. Ralph
A.
Would you mark -that for identi-
(The document referred to was thereupon

reporter as
Pl~intiff
th~
Exhibit No. 4 for Identification.)
Now, was that the letter of credit contcnplatcd by
the provisions of this agreement speaking of a letter of credi ?

A.
No.
14
! t was not a result of this agreement?
15
A.
It was--
17
Q.
Ye3.
18
A.
But this letter of credit did not--
19
Q.
Hy question, and again I'm not trying to confuse you
Thato the agreement
th~t
20
by the question, was:
21
sentcd to you by Mr. Ralph--
Thia ultir3ate letter of credit .pre-
22
A.
Has partial.
23
.0
Yes.
--did it arise out of the original provisions of thi~
,;
25
we have agreed
upon.
,24:
'
by
13
16
~arkcd
BY MR. AHDREHS:
11
12
Okay.
fication, please, Mr. Reporter.
:10
in a moment about any intervening
Yes.
MR. A!~DREWS:
~e
circumstances.
You can tell
3
4
ANDREl~S
80
agreement?
Castillo & Castillo
..... Regi'sttrtd Profrssi'onal Rrporrrrs 21$ N,W, 12TH AVENUE MIAMI, H.A,'33J2$
TEl... 324-6311
'Sl
Yes, I assume so.
Yes.
And did you approve that letter of credit?
No.
I mean, were the terms acceptable _;to you in that
letter of credit?
No.
What did you disapprove?
First of all, he says that the goodG should be
ported from United States.
'10
I said repentedly, "I'm not working in United States
11
and goods are not in the United States.
12
your letter of credit."
13
You have to change
Again, there was a lot of time between this contract
14
(indicating) and by the tizne he car:te out with a letter of
15
credit.
16
17
This is dated in July and this is dated 13 September

(indicating).
18
A.
19
days' time.
Yes.
20
It was supposed to come back in, you know, 60
Therefore, was the result.
And second area was he want a manufacturer's
certifi~
21
cate from USAi which there was no manufacturers any rnore1 tho
22
line stopped in 1954.
Each one had different nanufacturer'~ address on it.
24
Dade ,by Mirrnont (phonetic), some was made
25
by many different countries--I mean manufacturers.
And he saw the weapons in the
Castillo & Castillo

- R~i'srued Professional Reporters 219 N,W, 12TH AVENUE MIAMI, FLA.3312S
TU., 324-6311
trans~
I,. '
~I
>
';.~
by
~arehouse~
Some was
Colt, some were
82
Then he said, "How are we going to do it?"

2
3
'I said, "I cannot comply with this letter of credit,"

and I
refused it.
5
6
Well, again, I merely want to call to _your attention this agreement that you signed, which provides-, as to the
merchandise described therein:
and "Origin:
.A.
All new manufacture~
United States of America."
Origin, yes
9
10
"Quality:
Now, docs this letter of credit differ from those

statements in the agreement?
11
Yes.
12
I see what you .mean.
It says here, "From USA airport"
(indicating).
But other than that, does the
13
letter of credit differ from the roquireuents set forth in thi
14
agreerllent?
15
~e3.
16
lvhcre?
17
Where?
18
1cs.
I mean, you have already said that you dis-
19
agreed now with the requirements set forth in-the letter of
20
credit that-A.
It sayG, "marque Browning."
22
Yes.
23
They were not mark Browning; they were type
24
Okay.
:25
A.
Browning~.
'And the third, as I said, I donot work in United

Castillo & Castillo
- Rrgistered Pro.fesslonal R<'pOrtt'rs 219 N.W. 12TH AVENUE MIAMI, FLA. 33128
T!l.., 3246-311
-e
!:3
States in armament7 otherwise-.2
So you objected at the
to you to the reference that it would emanate from an .airport
in the
12
these be mark Browning.

A.
Mark Browning.
I
A.
see.
And then ther6 was discrepancy of M3, M2.
Yes.
A.
And, you know, there were not--it was not acceptable
15
And this letter of credit went to Lisbon to be negotiated at
16
the bank there.
17
Well, I'm trying to take this in sequence.
18
Another thing that occurs to rne is the-agreement
.so
tha~
19
you have identified specified delivery of 200
20
machine guns and 200 .30 caliber machine guns and the letter of
21
credit now ultimately being presented to you under date of 13
22
September speaks of 197
23
_Now, I take it there was a nodification somewhere along the
24
. line as to the number of arros to be furnished .
25
.so
caliber
caliber Browning machine guns.
Nunber and the rnodel.

Castillo & Castillo
~
Rtglstrrtd Profrssiona! Rrportrrs-
219 N,W, 12TH AVENUE MIAMI, FLA. 33\28
He has
here will be M2 (indicating).
13
14
Yes1 excuse rne.
And you objected, further, to the requirement that
10
11
States of America with the destination in
Uh-huh..
7
8
Unit~d
.Mauritania?
6.
(''
that this was presented
~ime
TEl,., 324~311
84
I see.
All right.
Was it agreeable to you to furnish 197 machine
It was agreeable with rne, yes.
Now, that letter of credit that you have identified
guns?
'
speaks
also of certain documents against which payment would
be made.
'7
A.
8
9
Look at it, if you \-till, or perhaps you remember it.

Yes.
Yes.
Ar.tong them, an air waybill.

A.
Yes.
10
A certificate of current manufacture.
11
Yes.
12
Look at it.
13
Is that correct?
told you that that was the reason why I have
14
refused this letter of credit, that the certificate of origin
15
from the factory.
16
by .any third party.
17
It does not say here certificate of origin

We agreed to involve third party to
inspect the goods so will be acceptable by Hr. Ralph.
18
Who agreed?
19
Mr. Ralph and myself, when I have refused this.

All right.
21
Now, he's presented this to you and you have looked
22
down through it and you .have said, "Mr. Ralph, I find certain
23
objections to this letter of credit.
24
25
A.
Yes.
I find it
objection~ble
for you to specify Browning
Castillo & Castillo

- R(glsrutd f>ro/rssional Rrponrrs2t9 N,W, ,2TH AVENUE MIAMI, FLA. 33t2S
TEL. 324-6311
35
as the make"' is that accurate?

2
A.
0.
the arms shall be flowing from the United States to Mauritania."
A.
Yes.
0.
And what else, if anything?
A.
Hanufacturer,, the model, and mark nrowning.
We
didn't have all mark Browning because when we inspect the
machine guns they were type Browning but they were not oanufactured by Browning.
11
0.
Well, in a moment I think maybe this will come a
12
little clearer, because i t seems that the exact specifications
13
set forth in that were thereafter--
14
They were not correct.
15
0.
We will come to that in a moment.
16
I'~
nu=o we are
going to come back to that in a moment.
17
;'
I find it obj actionable because 'it specifies that
10
."
Yes.
MR. ANDREWS s
18
that is attached.
'19
here.
I wonder
~f
Jerry, I want to show bin a document
I don't seem to have an.extra copy of it

ue might--
to
MR. RICIU-!AU:
Something attached to the Complc::.int?
21
MR. ANDREWSs
No, just--it's in the file and it's
22
an affidavit attached to the--or, rather, it'.s an exhibit
23
attached to the affidavit of R . ~!. Williams and it's a pur-
24
ported power of attorney.
25
Let me find it.
Can you find it, Mi~ch?
It's Exhibit l to the
Castillo & Castillo

- Rrgistered 'Professlonal Rfportus 219 N,W, 12TH AVENUE MIAMI, F~A, 3-3t2$
Tf~. 324-0311
86
affidavit .of Williams.

2
Okay, I found it.
No~,
since I don't have a sepa-
rate copy, itprobably would be easier if we could make one so
.we can keep all of these exhibits attached to the deposition.
MR. RICHMAN:
Sure, we can do that.
now and we can rnark it and then make copies.
BY MR. ANDREWS:
8
9
Will you look at this 1 please..

Exhibit
Show it to him
This is attached as
in the court 'file to the affidavit of Mr.
R. M.
10
Williams, and it purports to be a power of attorney dated
11
16 November 1977, running from Airtrade (UTI) Ltd. to
12
M. Williams, Jr., and executed by yourself.
13
that copy?
14
A.
sure..
R~ynolds
Can you identify
Yes.
Okay.
16
MR. ANDREWSs
Now, Mr. Reporter, when we do get a
17
copy of that, that will be--you have it down as what it is
18
identified as.
19
(Copy of said power of attorney dated 11-16-77 to
20
be later marked as Plaintiff's Exhibit No. 5 for
21
BY MR. ANDREWSz
Q.
Now, did you personally deliver that power of attor-
23
ney to Hr. Hilliams in Washington,
24
15th, 1977?
25
~dentification.:
n. c., on or nbout NovembeJ:
Yes.
Castillo & Castillo
-
Rrglsrered Professional Reporters-
21Q N,W, 12TH AVENUt MIAMI, 1'LA,~t2S
Ttl... 3:24-63f1
R7
~
2
and identifies the letter of credit that you have identified
here.
credit of 13 Septenber.
-5
6
7
8
9
10
,,
12
13
14
15
'16
17
18
19
20
21
22
23
24
:f
{.
Now, the power of attorney specifically refers to
25
'
The number corresponds to the number of this letter of
The reason--yes, but the reason they put that number
there, it's to identify the transaction.

~
Yes, but it gives him authority to act under that
specific letter of credit, doesn't it?

A.
-~
A.
Yes.
All right.
Now--
Excuse me, one more point.
On this letter of credit,
also it was rejected because of the insurance policy.

~
What was objectionable
A.
told him that I
abou~
that?
could not get any insurance for
the goods.
~
That you could not get insurance?
A.
Yes.
Q.
You told who that?
A.
Mr. Ralph.
Q.
When did you tell him that?
When--you know, when I
read the letter of credit and
I .refused it
~
You say you refused it .and--
A.
Excuse mer and then--
Q.
By all means.
Castillo & Castillo
-
R~glsurt>d
hofrsslonal Rrporrrrs -
219 N,W, 12TH AVNUE MIAMI, H.A, 3_312S
-ru.. 324-6311
88
~
-~he
items~-
{l
Yes, sir .
-~in
-5
'6
'7
this letter o(
That would have
~redit
.require~
and-~eparateor
.no, he said he could. go and talk to 'his banker and
.take all those things out from the letter of credit and modify
it theway 'that we want it.
"Then after he went and.he negotiate with his
11
~hoever
12
refused to. make tiy .~odi~ication at all.
13
their orders.
14
with it.
15
16
-17
additional
or supplemental letter of credit, would it not?
10
{l
rte said, "Those are
That s the only way,, you 'know, they ci:m deal
When did he tell you that, do you recall,. in
sequence of time?
"This is dated 13 September.
When after
that did.y6u have this -conversation?

L
After he went to his. bank.
19
o:
.When would that "have. been in point of t'ime?
21'
bank~
did open the- letter of credit, this. other French barik,
18
to-
promised' that hewas. going to change all those
wou~(
say this
lette~
of-credit was telexed to the
bank in .Portugal--
22
To what bank in .Portugal?
23
The Danque Commcrciale,. something like that, o~
24
Agriculture.
25
you -the name of the bank.
You have the telex, maybe, the copy.
Castillo & Castillo

......._ Rrglstered "Professlonal Reporters .-.
2_19
N.V>f. 12TH ,AVENUE
MIAMI, H.A.
TEL, 3-24-63\1
331:is
I'll get
89
And then he said that--the first excuse he gave, he

2
could not change anything until the bank returned tho telex,
the letter of credit.
said, "I refuse this letter of credit which--"
And I gave a letter to the bank.
When did you do that?
Four days after the notification, because when the
telex came to Portugal he carried this, handcarriod it, Mr.
Ralph, and I told him on the phone that we would not accept
it.
He carried this, handcarried, and those are the points
10
that he had to make a change (indicating).
11
and his bank told him that, you know, they have to return the
12
telex first.
I give a letter to this bank.
13
ne advised the bank
in Brussels and then nrussels--this is what I heard from him-
15
talked to this French bank and the French bank refuse to nake
16
any modification.
17
oodify it, and those are .the instructions that they have.
And he came back and he said he could .not
18
What did you say?
19
And I said, There is only one way we can do it.

I said, "You pay cash for it.
21
And he said, "Can you supply the documents?"
22
I said, "I will not supply any document to your
23
bank, but whatever you need you tell me and I will cooperate
24
with ,you."
.25
Well, fine,
b~cause
that leads me into some other
Castillo & Castillo

-
R~lsuud hof~sslonal R~porr~rs
219 N,W, 12TH AVENUE MIAMI,H.A, 33128
:TEt., 324~311
-
He went to his b
14
20
90
documents now and I want to show you-2
And this is when Mr. Williams came to take this
'-'\,1
thing over because--
The power of attorney is signed by you as the presi-
dent of Airtrade (UTI) Ltd. and you said you personally
delivered this to Mr. Williams in Washington, D. C.J is that
correct?
'
Uh-huh.
Q.
And that directs Hr. Williams to act as attorney-in-
Yes.
10
fact to represent Airtrade in a transaction inv6lving this
11
letter of credit, and it identifies it, and that is Gigned by
12
you--
13
A.
Yes.
14
Q.
--on behalf of Airtrade.
15
Then I want to show you three--
16
Excuse me.
17
Go ahead1 what is it you want to say?
18
A.
Fro~
19
0.
Yes, September 13.
20
A.
September 13.
21
Q.
Through
22
Yes.
this date (indicating), from this date.
t;over~tber
16.
Mr. Ralph went back and forth maybe fifteen
23
times.
24
Back and forth where?
25
A.
I mean by phone, you know.,

Castillo & Castillo
- Rtgisrered J>rofessiontJI Reporters.219 N,W, 12TH AVENUE MIAMI, FLA. ~128
TEL, 324-6311
_,,
91
~----------~------------------~~----~------~
0.
To you?
Yes, to me.
I got frustrated.
~hen
This is why
from 16 on I told Reynolds 'Williams to deal himself because I
was on trips.
MR. RICHMhN:
5
'6
hnd ho uaed to call QRC-I'm lost here because you are going
off without a question pending at all.
don't know what
areas you are going into or what you are doing.
you to--
would ask
he's a3king me, you know--
TJIE
l'liTltESS:
t~o,
10
nn.
RIC!UiA~: 1
Just
11
'l'HE
WITNESSz
All right.
12
:.m.
RICHHANs
But don't go off in a narrativcr okay?
13
'l'IIE WITNESS:
14
Yes,
whatever:question he asks.
Okay.
did sign that power of attorney to Mr.
15
Reynolds tiilliar.ls.
16
BY MR 1\ttDREUS s
And you delivered it to hir.\ in Washington yourself?
17
18
ans~1er
A.
Yes.
.19
All right, sir
20
Now, I next show you three items, being Exhibits 8,
21
9 and 10 .to plaintiff's Complaint, and these are items
22
attending certain certifications which would seem to track
.23
the requircr.\enta of that lettex- of credit, and I ask you if
you can identify these?
25
MR. ANDREWS:
Jerry, I'll pass them to you so you

Castillo & Castillo
- Reylsurtd ho/tsslonal
Rtpon~rs .-
219 N,W, 12TH AVENUE MIAMI, FLA, 33128
TEL, 324-6311
..
92
can look them over.

2
MR. RICHMAN:
Can you read back the pending questior.
(The pending question was read -back by the reporter

as above recorded.)
MR. RICHMAN:
Let me just object to the form of the
question insofar as it assumes certain conclusions about
tracking the letter of credit.
7
'
BY MR. ANDREWSs
Well, sir, have you ever seen those before?
9
10
A.
These papers?
Yes.
12
A.
Yes.
The originals.
13
Did you, in fact, deliver the origi-
14
nals of those to .Mr. Williams at the same time that you
15
delivered this power of attorney?
16
A.
17
18
I was in the office, but deliver it to them?

Have you had occasion to read .the affidavit of Mr.
Williams in t;he court file?
19
No.
20
I'll synopsize it, I hope accurately, to your satis-
21
faction.
He says in his affidavit that you delivered those
22
papers to him in Washington.
24
25
I knew that they were there, but I did not deliver

it.
Castillo & Castillo
-
R~lsttrtd
Pro/tsstonal Rtporttrs -
219 N,W, 12TH AVENUE MIAMI, FI..A, 33128

TE~. 324..6311
93
"1
You did not deliver it?
No.
Let me ask you, when did you first see those certifil-
cates, if you did?
The ones that I have seen, they were not acceptable.
You say you did.
by
the bank.
I'm talking
a~out
these (indicating).
You said you
did not recall or you specifically did not deliver the origi-
nals of these to Mr. Williams.
10
Those, no, I did not deliver.
11
You did not deliver these to Mr. Williams?
12
No.
13
Didyou ever see these (indicating)?
14
This?
15
These (indicating).
16
No.
17
Never saw thern?
18
Not this.
19
Let me ask you this--
Please note the telephone
20
number at the top. of each of those.
21
telephone number in Z..Siani?
22
.Yes, it is.
23
On each of them?
24
25
A.
Is that your residence
Yes, it is.
I want to get very clear that _you sayyou never saw
Castillo & Castillo
- Regisrtrtd l'roftsiional Rtporrtrs 219 N,W, 12TH AVENUE MIAMI, FL.A, ~3128
Y(L.. 324~311
94
those certifications before.

2
I was aware of the certifications.
How?
A.
Because they have sent the contents of this on
other--
Who is "they"?
This Browning people.
That you previously described?
Yes, after they went to Portugal.
10
11
After who went to Portugal?

A.
12
13
gu~,
After this
Okay.
this, you know, Manoug, the inspcc
Now, did Manoug go to Portugal to rnake an
inspection of merchandise that you were going to furnish under

.....
14
this agreer.tent and the ultimate revision being 197 50 caliber
15
machine guns.
16
17
A.
Yes.
.HR. RICHMAlh
'
l'lait.
Let me just object to the form
18
of the question insofar as it presupposes that the later agree
19
ment was necessarily a revision of the earlier one.
20
think that's been clearly established.
21
MR. ANDRE,'lS:
I don't
I would agree it has not been.
22
think as far as
23
agreed to revise the number of ~achine guns from 200 and 200
24
fifty and thirties to 197 fifties.
25
\ve
have gone is that -he has said that he had
MR. RICHMAN:
As I
underst~nd
it--we may be
Castillo & Castillo

-- Reglsrtrtd Proftsslonal Rtporrns :21Q N,W, 12TH AVENUE MIAMI, H.A, 33128
Tf:L. 3.24--6311
95
misinterpreting the same thing--I understand he said he

2
clearly agreed to supply 197 but he hasn't said that 197 was
out of that same original agreement.
.supply it.
s
6
ue said he agreed to
You may want to ask him that, but I don't believe

that was established in the record.
I
I'll ask 'hir:l that.
MR. ANDREHSa
8
9
BY MR. ANDREWS:
Q.
10
may have been to you, was prcaented, the one that you have
11
identified, I asked you previously if the merchandise describe~
12
was anoutgrowth of the merchandise originally described in
13
thi8 agreement, to which.you answered, "Yes.
14
to change that?
No. I want to clarify that.
15
16
18
19
Do you want
I don't want to change
anything.
17
'.
When the letter of credit, as unsatisfactory as it
All right.
That is exactly what we allwant to
achieve.
A.
When that agreement was signed, it was signed, as I
20
said before, in Santo Domingo for the material that the cap-
21
tain had inspected in Santo Domingo.
22
Go on.
23
This is when we signed that contract.
24
When he came back with a refused letter of credit,
25
he said he will buy them cash,. and he bought then cash.

Castillo & Castillo
--
R~lstn~d 'frof~ssionatR~porrtrs-
219 N,W, 12TH AVENUE MIAMI, H.A, 331:iS

T(I..~24-63U
e
I
96
0.
We will: come to that--
A.
All right.
Q.
--a little later on, Mr. Soghanalian, but the thing
-j
:.
that I'm trying to clarify here is that, thus far, it appears
that a letter of credit was presented and thereafter you
delivered a power of attorney toMr. Ailliams to identify
that letter of credit or his activities, and .now we have a
conflict at hand between his sworn affidavit and your sworn
testimony here today.
10
I don't know what he--
11
0.
And the first one we are developing is as it
12
attends the copies of these certifications by Browning, and
13
he has Said you delivered these to him in Washington and told
14
him to present them to the Banque Bruxelles Lambert, and you
'15
have testified here a moment ago that you never saw these.
16
17
18
.Because you said I delivered to them.
I did not
deliver it to them.
Q.
Okay.
oo you have any knowledge, any knowledge at
19
all, of how those certifications carne into existence, those
20
right there (indicating)?
21
Came by plane, carne by mail.
22
0.
Okay.
23
Now, who caused those certifications to be
made, if you know?
24
You mean who give instructions to be inspected?
25
Yes, who said, "Browning, please provide these

Castillo & Castillo
-
R~lstered ltofesslonal
Reporters -
219 N.W. 12TH AVENUE MIAMI, Ft..A. '33128

TEt... 324--6311
97
A.
We contacted the Beirut
experts.
3
4
Right.
And they send one of their men, whose signature is
..
there (indicating), and inspected.

Okay.
7
8
place?
A.
Now, when and where did the inspections take
In Lisbon.
10
~'lhen?
11
MR. RICHMAN:
Are you asking him of his own persona
knowledge now?
12
Myself and Mr. Holcomb.
13
MR. ANDREWS:
If he has one.
14
MR. RICHHAN:
If he was actually physically there,
can answer it.
15
If not, it would be hearsay, if he wasn't the
16
MR. ANDREWS:
You put an answer to him.
17
MR. RICHMAN 1
I don t know if he-. was p~ysically
there or not.
18
MR. ANDREWS:
19
don't, either .
BY MR. ANDREHS 1
20
Were you present when any inspections were made of
21
any firearms in Lisbon?
22
23
A.
No, I wasn't.
24
Do you have any knowledge of who was present?
25
I assume that-- 'No, I don't.
'
..
Castillo & Castillo

- R~isttred hoftssional Rtpcrltrs-
219 N,W, 12TH AVENUE' MIAMI. F~A. 33128
TE~. 3:24-6311
'
., ',
It
..
'
;f;
C
2
Okay.
You made the request to Browning, "Please
make inspections of certain arrnc"?
Yes.
.so
98
...
~-
caliber machine guns?
Yes.
197 of them?
A.
Or whatever was available.
.Q.
Well, they say 1977 they describe thern
Look at it.
10
A.
197 of them were included in the material.
11
Q.
Yes.
12
They have inspected other materials, too, which is
13
not part of--
14
I'~
15
not concerned about other materials.
I'm really
concerned about those three documents.
16
Yes.
'17
Those three certifications, -and those certifications,
18
19
I take it, were rnade by Browning .at your request.

A.
20
Yes.
All right.
Now, rnt question is:
21
inspections take place?
22
Go to such-and-such an address"?
23
A.
Hhcrc did those
Oid you arrange, did you te'll them,
Yes.
24
All right.
25
In Lisbon.
What address did you tell them to go to?
Castillo & Castillo

-
Regismed hofessiontJI Rt'{Jorrers -
219 N.W. 12TH AVENUE MIAMI, H.A. 33128

'TU., 324-6311
99
-~
In Lisbon where?
To Avitextil.
3
4
Where is Avitextil located?

A.
In Lisbon.
Do you know the street address?
tio 1 I don' t know the street address.
tiell, who is Avitextil?
Avitextil is a company, firm, that deals with
general merchandise, includinq weapons.
10
11
Okay.
Did you tell them to go to Avitextil and see
any particular person in order to make these certifications?
12
13
Hhat is Avitextil?
I give the telephone number of Avitextil and talk

to Mr. Martins.
14
Mr. Hartins at 1witextil?
15
A.
Yes.
16
And who did you talk to at Browning at this point
17
18
in time?
rnoan what peraon.
A.
To Hr. Kamil llarmouch.
0.
What did you say to Karnil?
"Karnil, I need certain
20
certifications..
21
Avitextil and make an inspection and thereafter certifications .?
22 '
23
24
2_5
A.
-Please 90 over and call Mr. Martins at
Yes.
Okay.
Now, at the time yougave those instructions
was the merchandise being held in your name at Avitextil?

No.
Castillo & Castillo
-- Rtglstt>rt>d Proft>ssional Rtportus 21~ N.W;12TH AVENUE MIAMI, H.A. 331:i8
TEL. 324~311.
- .
e.
2
It was in a government warehouse.
0.
'i'~as
't,
5
6
- 100
this something different than Avitextil, the
government warehouse?
-~
Yes.
Well, to the best of my knowledge, the weapons
were always with the government warehouse.

~
Excuse me, I nay have misunderstood you.
I thought
you said to the man you identified at Browning, "Please go
call Mr. Martins at Avitextil and go over and make certain
10
inspections and certifications.
11
At the location of the weapons.
12
0.
All right.
13
To my knowledge, at the government warehouse, mili-
14
Where were the weapons located?
tary warehouse.
15
0.
Is that different
16
ll
Yes.
17
0.
Why did you tell him to go to 'Avitextil?
18
Avitextil is the coordinator, the licensed weapons
19
20
fro~
Avitextil?
dealer in Portugal.
~
Okay.
So if I get this straight--I don't mean to
21
interrupt you1 I'm merely trying to follow your sequence of
22
advices here--you said, "Browning, call Martins at Avitextil"
23
and then did you say "Avitextil will act as the coordinator
24
for your inspection at the government warehouse"?
2-5
No, Avitextil was supplier to me.

Castillo & Castillo
-
R~lstn(d
"frof(ss"ional R(pOf/(f$ -
219 N.W, 12TH AVENUE MIAMI, H.A, 33128
TE t.. 324-6311
101
0.
Okay.
And Avitextil is .buying fron 'the local government
in Portugal.
3
4
0.
The Portuguese Government?
The Portuguese military people.
I see.
So hvitextil was acting as your agent to buy
those guns described from the Portuguese Government1 is that
accurate?
1>.
"los
10
.~
At that specific time, and I'm speaking of your
11
instructions to Drowning, who held title to the 197 machine
12
guns .described in those certifications?
'13
&
?~rtuguese
14
The Portuguese Government?
15
Yes.
16
No~,
'
Government.
take .it, then, that the guns which you
17
requested be inspected and certified were not guns from
18
Nu:nrich
Ar~s.
19
11.
~~0.
20
0.
In any way, shape or
21
A.
No.
22
0.
And were not guns frorn Santo Domingo in any way,
23
for~.
shape or form.
24
i
...
25
0.
These were guns owned by the portuguese Government?

Castillo & Castillo
-
Rtglsrrrrd h<?frssional Rrporms -
2t9 N.W. 12TH AVENUE MIAMI, H.A,

rEl.. 324-$311
~3128
"102
A.
Yes.
All .right.
Now, then,
~m
a little mixed up between what--the
certifications were obviously .made at your request by Browning,
as evidenced by these documents, were they not?
Pardon me?
MR. RICHMAN:
either.
BY MR. ANDREWS:
10
11
A.
Yes.
--that you requested?
A.
14
15
Could you rephrase that.
Did, in .fact, Browning make the inspections--
12
13
I don't understand the question,
Yes.
And did, in fact, they mako the written ccrtifica-
tions which you
requ~sted?
16
Yes, they did.
17
All right.
18
Did they then furnish to you those
written certifications?
19
A.
20
'0.
To?
You.
You are the requesting party.
You arc the one
21
who is required to make the cGrtifications, if we go back to
22
the disputed letter of credit.
23
A.
24
25
It was mailed to QRC.

At your inntructions?
A.
Yes.
Castillo & Castillo
R~ist~r~d Prof~ssional R~porr~r$ 219 N.W, 12TH AVENUE MIAMI, H.A, 3312$
TE\.. 324--6311
103
0.
..
All rlght.
Now, then, when you got up around
November 15 and delivered that- power of attorney to Reynolds
Williams, did you see the certifications that had been mailed
at your instructions?
,;
MR. RICHMAN:
Excuse me.
of the question.
15 when November 16 is the date.
f-IR. AlmREWS:
think you have inadvertently said
l~ovember
asked him on or about November lS.
Yes, the power is dated the 16th, and'we will say at or
10
around Novenber 16th.
11
BY
12
Let me object to the form
MR. ANDREl1S:
Q.
At the ti'mc that you delivered this, whatever pre-
13
cise date it may have been, did you then have occasion to see
14
those certifications?
15
16
The ones that I have seen which was similar to this
one were not accepted, acceptable for some reason.
17
0.
By whom?
18
I did not
19
a~k
by whon.
This is what Mr. Reynolds
Williams told me.
20
0.
ne
21
Excuse me--
22
Q.
Yes.
23
Not until I give him the .power of attorney.
was acting for you, wasn't he?
But we
24
have request to modify whatever Mr. Williams'desire was, the
25
exact wordinq. And those were mailed.

Castillo & Castillo
- Rrglstered "Professlonal ReporUr$ 219 N.W. 12TH AVENUE MIAMI, I'LA.3312S
TE\.. 324-6311
104
~
Did you ever see those--
When I left--
.~
--in Washington?
--washington,! went to Wisconsin.
His question was did you ever see these particular ones (indi-
eating).
THE WITNESSr
No,
did not see those particular
ones.
10
BY MR.
11
{l.
You have never seen them?
12
1i.
no.
"13
Q.
You saw something else?
14
A.
Yes.
15
Q.
But it wasn't this?
16
No.
17
Q.
And you are certain you didn't deliver thone to
18
.<
Please answer the question.
'
Excuse me.
MR. RICHMAN:
MlDREllS:
Mr. Williams personally?
19
A.
No.
20
Q.
It is your recollection that you told Browning to
21
mail them--
22
A.
Yes.
23
Q.
--to QRC?
24
Yeo
25
Q.
Now, I next want to show you a copy of an air waybil

C3stillo & Castillo
-
Reglstered l'rofesslonal Reporur$-
219 N.W. 12TH AVENUE MIAMI, FLA. 3312:8
TU., 324-6311
lOS
which is dated november 15, 1977,

2
Exhibit 5 to the
oidyou personally cause that 'to :be prepared with-
out signature?.
Pardon me?
.bid you;cause that -air waybill to'be prepared? .Did
:you prepare itJ was itprepared -at _your direction?
10
tf I .told them to
A.
11
~ashington
16
at the same time that you delivered the power of
attorney to him \'iith instructions to ;him to. take that to

'
Banque Bruxelies Latlbert and,.oxecutc. it at 'the bank under the

:power of attorney that you had afforded to
A.
20
hi~?
Thio?
'l'hat.
A.
22
25
anyone to
Di'd you. deliver .that document to Ur. tiilliams 'in
15
24
tel~
Not this document,, no.
'14
23
Did you
-prepare that?
13
'21
pre~are it~
Told anyone to prepare it.
12
.t9
Complaint, and ask if you can
I have received in' the flail a copy of this.
A.
18
which is attached as
identify that document?
17
pl~intiff's
and~
No, no,
no~
no.
Have _you ever seen that before?

m~iled
'A.
You.sa1d you were
a copy of it.
.He mailed a copy to me, yes.
l~hen
did that .happeni'

-
When did you firs-t see. that? ,
Castillo & Castillo

-- Reglsrered l'rofesslonal Reporters .219N.W. 12TH AVENU( MIAMI, Ft..A,3312.S
n:f..-.324-6311
6
~
After he came back from Brussels.
Was that after you got paid?
When he came back it was not paid yet.
Okay.
At one point in time you saw what you now
say is a copy of what Hr. Williams mailed to you, a copy of
this?
-~
Yes.
0.
Where did he mail it tOJ here in Miami?
A.
He mailed it down to Miami.
10
0.
Did you approve of it?
A.
Yes,
Q.
All right.
12
approved of it.
And was that air waybiLl intended to
13
fulfill the r~quirements of the letter of credit and effect
14
payment to you of certain monies for the machine guns?
15
A.
16
17
18
Now, the air waybill describes the air carrier as

N711U'l'.
A.
.19
~
21
Yes.
Yes.
That is the same aircraft that was owned by United
Trade International that we talked about earlier?

A.
22
Yes.
Now, the air waybill certifies--
.23
with air waybills?
usage of air waybills?
25
A.
Are you familiar
Have you done business before involving
I have an opinion.
Castillo & Castillo
-
Regi'sttrtd l'roftssiona! Repontrs .-
219 N,W, t2l'H AVENUE MIAMI, H.A, 33128

"TEL. 324-6311
107
~
You are not unfamiliar
with~
air waybills?
uo.
3
Now, that air waybill signed by Williams under powe

'
of attorney by you, issued ,as president of Airtrade, states
that the goods described 'therein, naoely 197 machine guns,
are in custody and onboard the aircraft.

MR.
RICHMAn:
Don't answer the question _yet.
want to note an objection .for the record.
MR. ANDREWS:
10
MR. RICHMAN:
There is an improper predicate in wha
MR. ANDREWS:
-~with
11
haven't asked the question yet":"-
you said.
12
13
MR.
RICHl4AN:
the monologue here.
The problem is I object to the 'form of
14
the question in that you have made a certain assumption 'in
15
there that this air waybill is dated coincidentally with the
16
power of attorney.
17
November and the air waybill
18
15 November, which is prior to the date of the power of ,attor-
19
ney.
to
21
~he
MR. ANDREWS:
power of attorney is dated the lGth o

appe~rs
to have been executed on
I agree, and again we are in conflict
about the presentation of that document.,
Mr. Soghanalian has
denied that he prepared it and presented it with that date

23
with instructions--
24
MR. RICHHAN&
25
form ofyour question.
Hy objection, though, was just the

Your question said "under the power of
Castillo & Castillo
R~lsr~r~d 'Pro/~ssional R~porurs
:21~ N.W, 12TH AVENUE MIAMI,1'LA, 331:28
"T!L, 324-6311
108
attorney" and it presupposes that the dates are consistent

2
when they are in conflict.
BY MR .ANDRBWSa
~
familiarity
with air waybills and this being signed by Airtrade under
whateverauthority, hnd perhaps no authority, is that a certi-
fication that the machine guns have been received and are in
custody and are ready to fly off to Mauritania?

MR. RICHMAN:
Object to the form of the question
10
insofar as it calls for this witness to express a legal con
1f
elusion.
12
it.
13
Bi' MR. ANDREHS1
14
15
He can testify factually as to what he knows about
What do you know about it?
Do you know anything at
all about those goods being in custody?
16
In custody of whom?
17
In custody of Airtrade, the shipper.
18
It says--
Look, if you will read down there--
19
This air way--
20
I will ask you if you have any knowledge of this
21
yo~r
:I'"
Totally aside from the date and
Okay, excuse me.
after I read it.
22
"Carrier .certifies above-described goods were
23
received for carriage , the goods then being in
24
apparent good order and condition
25
hereon.
Castillo &Castillo
- Rt'glstered Pro/t'SSional Reponer$ 219 N.W. 12TH AVENUE MIAMI, Fl..A. 33128
TU 324-6311
ex~ept
as noted
'109
Signed Airtrade (UTI) Ltd., by R. M. Williams, or
L
appears to be.
t~
Do you have any knowledge of that?
Of this air 'bill, I don't have the knowledge, no, a
that date.
~
Do you know if that purported to deal with the same
machine guns that you just described a moment ago as being
Portuguese Government machine guns?
guns
10
fro~
the Portuguese Government at any time on or before
the date of that air waybill,which is November 15th?
11
A.
1~0.
12
W~ll,
13
Had you bought the machi
do you know if, in fact, Airtrade had posses-
sion of the nerchandise described in that air waybill?
14
A.
no.
15
Do you know
16
No.
17
Q.
r~o"1,
anyon~
who would have known?
I show you a copy of an invoice dated November
18
16, 1977, directed to the plaintiff, in the sum of $1,153,590,
19
describing 197 machine guns, and apparently signed by you, and
20
I ask if you can identify it and if that is your signature?
21
22
23
MR. ANDREWSr
Incidentally, it's Exhibit 7 to
plaintiff's Complaint, Jerry.

MR. RICHMAN:
I just want to make sure that we are
not going to get confused here, recordwise.
25
8 1 9 and 10 have yet to be marked and given exhibit numbers

Castillo & Castillo
-
Regist~r(>d hof~ssional R~port~rs
TEL,
324~311
These
exhibit~
24
110
for this deposition by the reporter.
MR. ANDREWS:
I.
You may want to do that.
Let s. r1ark those.
Those are the
three documents bear;ng Browning Precision Tool's certifica-
tions.
(The three certifications referred to were marked
by the reporter as Plaintiff's Exhibits non . 6, 7 and 8 for
Identification.)
HR. AUDREHS:
(The air waybill referred to was Darked by the
'10
Mark this as 9.
reporter as Plaintiff's Exhibit No.

MR. RICHMAN:
11
And mark this
for Identification.)
&S
lO.
(The invoice referred to was marked by the reporter
12
13
as Plaintiff's Exhibit No. 10 for Identification.)
14
BY MR. ANDREWS:
15
('~
Uou, did you deliver that invoice to R. u. \iilliams
c.,
16
in Washington, D.
17
time you.delivered to him this powar of attorney?

MR. RICHHAN:
18
19
on or about november 15th, at the same
Same
obje~tion
to tha date, usinq
November 15th instead of the 16th.

HR. AU DREWS:
20
t-le 11,
I don't know why you are object
21
ing to it because he can say, "Not on the lSth7
22
was on or about November 15th or November 16th."

TilE WITNESS1
23
24
25
think it
To which one?
BY MR. AltUREWS:
-~
You tell me.
I'm askinq you tho question.
Do you
Castillo & Castillo

-
Regisrtrtd Projtssional Rtpontrs -
2t9 N.W. 12TH AVENUE! MIAMI, H.A. 33128
TU. 324.6-311
I
l---------------------------------------------------------------------------~
111
have .any recollection of journeying up to Washington to take

any
docuc~nts
to Mr. Williams?
You
~lready
said yes, you did
as to this power of attorney, and my question iss
At the
same time did you also deliver to hirn that invoice?

A.
.Yes.
Q.
All right, sir.
A.
On the 16th.
Q.
On the 16th?
A.
Yes.
{.\
And was this for the purpose of gaining paynent to
you of tho
SUr.1
Again-
reflected therein?
A.
'res.
What instructions did yourgive Mr. Williams, if any,
after delivering to him the documents you have admittedly

delivered to him?
A.
To carry those docunents to Mr. Ralph.
To Hr. Ralph where?
A.
I think he was in Paris.
Q.
Well, _do you have any recollection what your inst
tions were?
A.
'I'o deliver those documents to 1-tr. Ralph.
And, again, do you or do you not recall where he was
to effect this delivery?

L
I think was Paris.
Q.
Did you tell him to deliver any documents to Banque

Castillo & Castillo
-
Rtgisrue_d Profrssional Rrportrrs -
219 N,W, 12TH AVENUE MIAMI, FLA. 3312S

TEL. 324-6311
112
Bruxelles Lambert, -the issuer of that letter of credit of
2
which these documents seem to track ,the requirements?
No.
You did not?
I did not tell him to give any document to the
Banque Lambert.
7
8
At that same time did you also deliver to him a
personal power of attorney to act in your behalf?
.,._
At the November time that you journeyed up there,
10
11
12
whether .it was the 15th -or the lGth or the 17th.
A.
15
A.
And was this for the purpose of gaining payment to

you, arising out of that letter of credit?
No, for the sale of 197 machine guns.
19
It had nothing to do with the letter of credit?
21
22
\,
Yes.
18
20
Did you deliver to him a personal
power of attorney to act in your behalf?
16
17
16th.
Okay, the 16th.
13
14
What tine?
A.
uo.
Now, did you, 'in fact, receive payment of
$1,153,590?
23
Fror:t. whom?
24
I don't know, I'm asking you.
25
>Did you receive P':'Y-
ment of that invoice?

Castillo & Castillo
-
R~lsrered
hofessional Reporters -
219 N,W, 12TH AVENUE, MIAMI, H.A, 331:28

TE 1.., 3.24-6-311
113
~
Okay.
2
3
4
Yes, I received the payment of that invoice.
1..
teen days
When?
I was notified approximately, about fourteen,_sixfro~
my 'bank.
Okay.
Was that sum of money remi'tted. to you by
Banque Bruxelles Lambert?
Yes.
And- was it in payment for 197 machine guns?
-9
It was for this invoice here (indicating).
10
Was it in payment of that invoice?
11
A hundred ninety-seven dollars.
12
No, machine guns.
13
Machine guns, on behalf of Mr. Ralph.
14
The remitter was Banque Bruxelles- Lambert?
15
That was his bank.
16
Yes, and the issuer of this letter of credit was
17
'Banque Bruxelles Lambert?
18
No, I .guess it's a French bank.
19
But the paying bank was Banque Bruxelles Lambert.
.~
Wasn't it to be paid through at the counter of Banque
21
Bruxelles Lambert?
22
(Indicating).
23
What are you pointing to there that's si~nificantJ
24
25
anything?
Yes, that speaks for itself.
It was obviously
, Castillo & Castillo

,_
Reylsr~r~d
Proft>sslonal Rt>portt>rs ._
21~ N,W, 12TH AVENUt MIAMI, H.A, 33128
'Ttl... 324-$-311
L~----------------------------------------------------------------------~
114
issued
2
by
CCF Bank in Paris through Banque Bruxelles Lambert.
Banque Bruxelles Lambert is the payee1 right?

HR. RICHHAN:
itself.
I guess the document has to speak for
You're asking the witness to draw a
~egal
conclusion.
MR. ANDREWS:
Lambert" (incUcating).
MR. RICHMAN:
My French is not part_icularly good.
MR. AUDREHS:
Hine isn't, but as I look at it closer
"At the counter of Banque Bruxelles
it's French and at the bottom in English throughout.
TP.E WITNESS:
10
On behalf of this French bankJ okny?
11
The same thing like Bruxolles Lambert paid me on behalf of
12
Mr. Ralph.
13
BY
~R.
ANORE~'lS:
14
Well, I auspect we will hsvc to--I've got
Dorc testimony other than your own to clear that up, but your
16
recollection is that Banque Bruxelles Lambert, in fact,
17
rernitted $1,153,590 to you, to your account, in payment of .the
18
invoice for 197 H2HB 50 caliber machine guns, which are also
19
described in the letter of credit?
to
21
0..
little
(Shakes head) '.

''lhy are you shaking your head?
i\.
Q.
24
25
A.
Banque Bruxelles Lambert did not pay me or purchase
from me.
~------------------------------------------------------------------~~
Castillo &- Castillo
- Registtrtd hoftssi'onal Rtporrers-2t9 N.W. ,2TH AVENUE MIAMI, H.A, 33t2-S
'T E L, ~-2 4--63 U
- ~----------------------~------------~
Tl5
,,
2
\"j
3
0.
'rn
No, no, I
hot saying that -they .did.
you that impression, I'n sorry.
If, I gave
I'm saying. did .they .remit to
1ou that money.?
4'
-k
They have-
0.
.Yes.
--that
remitted~-
~nemilli6n
and whatever
~t
is on that invoi
'7
on behalf of.Mr. Ralph

.8
How do you know that?
Because--
Q.
Really on behalf of Boca Investments, wasn't .it 1 .the ,
10
l1
party with whom-you had
12'
13
14
15
Boca Invistrncnt
0.
Yes, right.
18
i~
"
this :natter?
Mr. Ralph.
So itwas
i~
payment of
~atters
which
you have now all day testified.ahout leading tip to the sale of
themachine guns?
f6.
17
negotiat~d
Z..1R. RICHMAN&
tion.
BY
Let me
o~ject
to. the form of .the ques- .
That presupposes an awful lot of things.
:.m.
AUDREHS t
19
Q.
Let me ask you this, in one final sweeping question
20
'COncerninq the payment:
You did receive the $1', 15 3, 590 ,. io
21
that correct?
22
A.
Yes, yes.
And it. was.
23
i~
payment of this invoice (indicating)
24
directed to Boca Investments, Ltd.?

25
A.
co
t.
Castillo. & Castillo
- Regisrmd f>roftssional Rtpontrs 2t~N.W.12THAVENUE MIA~11 1 ft.A,33t28
TEI..,-324-63i1
116.
All right, sir.
Now, were the machine guns ever
delivered to Boca Investments, Ltd.?
The machine guns were put into the disposition of
Mr.--Boca Investments.
4
5
Mr. Boca Investments1 all right.
Now, the machine guns were destined for Mauritania,

were they not?
1
8
A.
Yes.
All right.
10
Mauritania?
11
A.
Do you know if they ever got to
No.
12
You don't kno,.,?
13
They did not get there.
14
Hhy not?
15
A.
Because Mr. Boca Investments, Mr. John Ralph, did
16
not ship the remaining of the parts to complete the machine
17
guns.
18
I don't believe I understand that.
Were these
t9
incomplete machine guns that you were paid for?
~o
something lacking there (indicating invoice)?
21
22
23
24
25
MR. RICHMANa
He's asking for something lacking on
the face of the invoice, so answer that question.

THE WITNBSSa
Is there
No.
.BY HR. ANDREWS 1

They were not incomplete machine guns?
Castillo & Castillo
-- R~istnc>d Pro[fsslonal R~po1t~TS 219 N.W. 1-2TH AVENUE MIAMI, fLA. 33128
''fU., 324-6311
117
'1
They were complete machine guns.

Q.
All right.
Now, there is a slip betwixt the cup anc
the lip here.
you say they never got to Mauritania because Mr. Ralph didn't
complete the machine guns.
You got paid for completed machine guns but
MR. RICHMAN&
~ending
than a question.
BY MR. ANDREWS:
at the moment.
I'm not clear.
There is no question
That's more of a statement, counset,
10
Well, explain it a little further because--
11
You asked me the question.
12
I asked you did the machine guns get to Mauritania.
13
I said, "No."
14'
Q.
15
16
And you said, "No," and I said, "Why not?"

Because Mr. Ralph, John Ralph, Doca Investment,
didn't have the license 1 number one.
17
18
I answer you.
I see7 it's the license now.

A.
What license?
Export license.
'19
Running from where to where?
20
From Portugal to Mauritania.
21
t1R. AUDREWS t
I think, Jerry, this is the time that
22
I would like to stop and call my office because if I have to
23
go .back I'm going to hav~ to go back now.
24
MR. RICHMAN&
Let's take a ten-minute break.
25
MR. ANDREliS t
And if I do have to go back I hope we

Castillo & Castillo
R~lsrned l'rofessional Reporttrs 219 N,W, 12TH AVENUE MIAMI, H.A, 33t:iS
"TEl., 324-63tt
.--'-
--'----------------------------------------------------------------------~--------------------------~
118
can -recommence-,
MR. RICHMAN a
He can reconvene in the morning.
I've
"'
told you I've got the day set aside so we can conclude it.
Okay,
5
6
let~s
take ten
~inutcs.
(Thereupon a .recess was taken, after which the

depo~ition
was adjourned until the following norning, March
22, 1979, at 9:30 a.m.)
--
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Castillo & Castillo

-
R~isttrt'd
ho/t'ssional Rt'porrus -
219 N,W. 12TH AVENUE MIAMI, FLA, _3 3128

TEL. 324-6311
119
1
IN THE CIRCUIT COURT OF THE

ELEVENTH JUDICIAL CIRCUIT IN
AND FOR DADE COUNTY, FLORIDA
2
~.'
GENERAL JURISDICTION DIVISION

4
No. 78-14372
(08)
5
6
BOCA INVESTMENTS, .LIMITED,

a trading company formed under
the laws of the Jersey States,
Channel Islands,
a
a
Plaintiff,
9
a
:
vs.
:
:
10
11
:
1
SARKIS G. SOGHANALIAN, indivi dually 1 et al. ,.
a
a
a
12
13
Defendants.
-----------------------------------
14
25th .Floor
One Biscayne Tower
Miar.ti, Florida
Thuroday, March 22 1 1979
9t55 a.m. - ll1SS a.m.
15
16
17
18
CONTINUED DEPOSITION OF
19
20
21
22
Taken before Richard A. Castillo, RPR, Notary Publi
23
for the State of Florida at Large, pursuant to Re-Notice of
24
~aking
Deposition filed in the above cause.
25
Castillo & Castillo
-. Reylsrtrtd l'roftssi'onal Rtporttrs219 N,W, 12TH AVENUE MIAMI, FLA. 33128
TEL, 324--63U
l20
.,
APPEARANCES&
2
{.
AUDREiiS & LUBBERS,

By& DEAU ANDREWS, ESQ.,
P. o. Box 11570,
Fort Lauderdale, Florida 33339 1
and
5
.6
8
9
10
11
12
' 13
BARAUDES, RABBIUO & ARNOLD,

Bys GERALD BARANDES, ESQ.,
and
MITCHELL W. RABBINO, ESQ.,
18 East 49th Street,
New York, New York 10017 1
Co-Counsel for Plaintiff.
FRATES, FLOYD, PEARSOU, STEWART, RICHMAN & GREER,
By: GERALD F. RICHMAN, ESQ.,
and
ROt~ALD BRE~lNER, ESQ. 1
25th Floor, One Biscayne Tower,
Miami, Florida 33131,
14
15
I N D E X
16
17
18
\1ITUESS
CONT. DIRECT
CROSS
121
19
EXHIBITS
20
21
22
23
24
'
PLAINTIFF'S
FOR IDENT.
ll
139
12
143
13, 14
15
152
153
25
Castillo & Castillo
..-. Rrgz'stered l'rofessz'ona/ Reporters 219 N.W, 12TH AVENUE MIAMI, J't..A,
'"1'1., 324-6311
33ti8
121
Thereupont
2
SARKIS G. SOGHAUALIAN
.resumed as a witness called by the plaintiff, and, ha\ing been
previously 4uly sworn, was examined and testified .further as
follows:
6
7
DIRECT EXAMINATION (CONTINUED)

BY MR. AHDREWSI
Mr. Soghanalian, let's pick it up at this point

from yesterday.
Your invoice was paid that you previously identifiec
10
'11
and you
h~d
X'eceived $1,153,590.
12
A.
Yes.
13
0.
Now, at that time did you then own the machine guns
14
which you had sold?
15
A.
No.
16
0.
You did not.
17
18
19
20
At that tirnc or at any time after the payment of

your invoice had you or did you pay anyone for those machine
guns?
A.
21
22
Will you ..tell me to whom you made payment

A.
23
24
Yes, I did.
To Avitextil.
Approximately when, if you know, did that occur?
A.
I don't remember the exact date.
records, though.
Castillo & Castillo
-
R~lstered
ho.fessiona/ Rt'porurs-
219 N.W. 12TH AVENUE MIAMI, H.A. 3312S

T~l
24-6 11
I~'s
in the
..
122
~
2
November, is that correct?
Yes.
All right.
.guns?
A.
As I said, I don't recall.
Q.
can you give me an approximate time?
A.
11
A.
13
don't exactly recall.
don't exactly recall.
have to check my books.
You have no recollection at all of how--
14
A.
15
not at this moment.

--how soon after?
Would it have been a matter of
days?
17
MR. RICHMAN:
Dy that, do you mean just a couple of
MR. ANDREWS:
liell 1 a few days.
MR. RICHMAN:
Everything is a matter of days.
days?
19
20
21
Would it have
Would it have been in December?
12
18
I will check my records.
been within days or weeks?
10
16
Using that as a point of reference,
when then did you make payment to Avitextil for these machine
You received your invoice payment the latter part oj
BY MR. ANDREWS:
Hould i t have been within a week after you received
23
24
25
payment?
I cannot, you know, tell you exactly one week or
two weeks_, but it was after 'I got paid.
Castillo & Castillo
-
21~
Rtgistt'rt'd "i'roft'ssional Rt'portus ~

N,W, 12TK AVENUE MIAMI, F\.A, 33128
n\.. 324-6311
123
0
2
paid, to the best of yo~r recollection?
3
4
To be honest with you, I can't say that, but was

after the getting paid.
5
6
Would it have been.within two weeks after you got
All right.
A.
I give a check.
Your check?
Yes.
Fro~
10
A.
11
'12
13
this from the Irving Trust account that you dis-
cussed?
A.
Yes.
And that check was nade payable to whom?
A.
16
17
your account?
Yes.
~-las
14
15
How did you make payment?
Avitextil.
Avitextil?
A.
18
Uh-huh.
Yes.
All right.
Now, you have made payment within a
19
short tirncJ is that accurate?
20
characterization?
21
22
A.
Would that be an accurate
I don't know what you call short.

MR. RICHHANs
I mean--
I've got to instruct the witness that,
23
you know, he can't guess.
24
sometime thereafter, he'll have to check his records on that.
25
And to expedite things, I'll be happy to supply you with that
He says he doesn't know but it was
Castillo & Castillo

- Reyisttrtd "Proftssional Rtponers 219 N.W, 12TH AVENUE MIAMI, FLA. ~128
tEL, 324-&311
124
information after the deposition is over.

MR. ANDREWS:
2
3
THE
,5
WITNESS:
Sure.
.MR. ANDREWS:
All right.
BY f.1R. ANDREWS:
The exact time that pay-
ment was made and the exact person . to whom it was made
.4
All right.
Now, having made payment to
Avitext~l,
I take it
you then owned the guns.
A.
At that time, yes.
10
Q.
Yes, sir1 and at that time where then were those
11
machine guns located,physically located?
12
At the military warehouse.
13
Can you tell me where the military warehouse is
14
located?
15
In Portugal.
16
Where in Portugal?
17
18
19
.A.
one' of their warehouses.

Q.
20
21
24
25
But you don't know where?

I said in the warehouse, but, you know, the exact
quarters of the warehouse I don't remember
. 22
23
I don't know the name of the location but it was in
Okay.
It's a warehouse .in the Country of Poxtugal,
you said.
A.
Yes.
All right.
In a particular city in Portugal?

Castillo & Castillo
.- Reyistrnd hof~sslonal
21~
N.W.
I~TH
R~porrers
AVENUE MIAMI,
'TEL. 324-6311
F~A , 331~8
~-
".
--- -- -
'125
1
It was outside,ot the City of Lisbon.
In a rnilitary-warohouoe?
Yes.
Now, by military you mean whose military?
What
do you moan, just a characterization that they stored mili-
tary equipment?
Portuguese military.
It was in a Portuguese military warehouse?
A.
10
Outside. of Lisbon?
11
Yes.
12
But you are not.certain of tho precise warehouse .or
13
14
precise location?
15
16
No.
A.
Wore you at any time advised by any person as to tho

precise location of whore your machine guns wore then located?
A.
Q.
A;
(.l
21
they were.
A.
23
Q.
You vioited there?
24
A.
Yes.
25
0.
All right.
went and saw the machine guns myself.
oo._you recall where you went to look at

C3stillo & C3slillo
- Rrgistrrt'd l'rofrssional Rrpurtus 21~ N,W, t2TH AVENU[ MIAMI, FLA, 33J;tS
TEL."324~3tt
L ~~~--~----~~------~
126
them?
We drove by car and then it was outside of the City
2
3
of Lisbon.
All right.
s.
When did this occur, before or after
you made payment to Avitextil?
Once before and once after.
Tell me about the before time.
Who took you to see
those machine qunst who drove the car?
Martins, John Martins.
10
Did anyone else go with you?
11
Mauritanian representative of the Ambassador,
12
13
14
Ahmadeu.
~
And this was an inspection that you made prior to
making payment for the quns, before making payment?
15
Prior and after.
16
All right.
A.
Yes.
Was a Mauritanian representative with you also
17
18
19
2_0
21.
Well, tm talking about the before time
Yes.
before?
A.
Yes, and also this Frenchnan.
The Frenchman?
A.
Yes.
And yourself and Mr. J. Martins?
A.
Yes.
An~
-,
--
'
22
-, '
23
24
( ,,
25
you drove to the military .warehouse?

Castillo & Castillo
.,.. Reylsttrtd l'rofmlona/ Rtporrtrs .219 N.W. UTH AVENUt MIAMI, H.A, 33128
TE_l.. 324-63'11
'I
2
4
'
A.
Yes.
Who had
--
~rranged
for you to _get in :to inspect these
machlne guns?
3.
4'
A.
The officers of the base.
s,
But who had contacted the officers of the base?
A.
:John, Martins.
Mas he a~ting i~ your behalf in doing so?
A.
.Ho, 'I was roy{ng fror.1 hit.n
He was acting in your behalf in arranging this
inspection for you?
,1()
11
A.
'As far as I was concerned, :he .was selling it to
12
Now, where precisely are those machine guns located
13
. toda_y?
14
A.
15
I. was told that they
~oved
~e.
'them to anotherwarehouse
which belongs to als6 . military.
t6
.o
who toldyou that?
A.
John.Martins.
Js
-~n4
19
A.
Which.was
20
Have you had any further information .as to the loca-
22
23
24.
25
when did .he tell you that?

~l~ost
a year ago.
ti6n
in the .Past year.of these machine guns?
'.
21
'
A.
I assume they, are still there.

Have you talked. to .anyone to ascertain if -they are
still there?
Yes,
the~ ar~ stil~
there, I think
.Castillo &;Castillo
._ Rtgisurtd Professional Reponer$ ,219 N.W. 12TH AVENUe MIAMI1 FLA; 331iS
127
rE_t.. 324-6311
128
~
Do you consider that you still own them?

concerne~,
As far as I'm
If you wanted to get them, take possession of 1thern,
where would you go to do so, how would you accomplish that?

A.
6
7
11
arrangements?
A.
For part of it, yes.

Well, part of what, part of the arrangements?
A.
Well, 197 of those guns 'belong to--if we are talk-
ing of the total quantity, belongs to Hr. Boca Iuvcstrnen't.
12
13
I should contact Martins.

And he would then arrange it, make the necessary
9
10
I should be owning them.
Well, you're saying that he has the right to those

guns because he paid your invoice?
14
Yes.
15
Now, if Hr. Boca Investments, and by that you mean
16
17
John Ralph-A.
18
19
20
21
John Ralph, yes.

--as the principal of that company--
A.
Yes.
--if he were to call .you--assuming now, just for a
moment, your assumption that 197 of those guns, he has a

right to them--
23
Yes .
24
;..-and.he called you .and he said, "I uant them, what
25
would be the steps necessary to accomplish that?

Castillo & Castillo
-
R~glstered l'rof~ssional
Reporters -
2t9 N,W, 12TH AVtNUE MIAMI, H.A, 33128
TU.. 324-63,
A.
2
lie '11 take them.
129
It's his.
I ncan how would you arrange for that to happen?

Would you then call J. Martins?
Yes.
And say, "Mr. Ralph is coming to pick up his gunsw?
A.
Mr. Martins already has the instructions to deliver
them to Mr. John Ralph.
Well, when was he given any such instructions?
Over a year ago.
10
Hhen you paid him?
11
Yes.
12
How were those instructions given by you?
13
A.
By me.
14
Q.
In writing or otherwise?
15
A.
Was verbal.
16
Verbal instructions?
17
Yes.
18
Now, was it your responsibility to deliver those
19
20
guns to Mauritania?
A.
no.
21
It was not.
22
The invoice that you have identified, you were paid
23
seventy-something thousand dollars for delivery, were you not,
24
included in the $1;153,590, for delivery of the machine guns
25
to the country of Mauritania1 is that accurate?

Castillo & Castillo
-. Rt>gismt>d Pro[t>sslonal Rt>portt>rs219 N.W. 12TH AVENUE MIAMI, FLA. 33128
Tt:_L, 324-6311
130
That's for transportation.
Yes.
Well, let's take it this way, and, .of course,
the invoice speaks for itself, you admit having been paid this
sum of money for that service.
i
!
5
6
you not deliver the guns to Mauritania?

MR. RICHMAN:
Go ahead and explain.
THE WITNESS:
Because Mr. John Ralph has engaged
10
himself to supply the tripods, and since the receipt was give
11
to him, including
12
return the money until I have seen tho t~ipods because he did
13
not have the tripods.
15
~he
tripods, we--I roean I didn't want to
BY MR. AUDREWSa
~
Now, just so I can understand this rnatter, back
16
again to your invoice, which
17
guns--
18
'A.
Yes.
19
--and with tripods, for which you were paid--
20
.A.
Yes.
21
Q.
--you sold' him the tripods, did you not, .in
22
23
,,
Now, after payment to you of the $1,153,590, why di
14
,.,.
ref~ected
both the 197 machine
accordance with that invoice?

I asked you yesterday, and not to interrupt you but
24
perhaps help my understanding, I asked you yesterday if the
25
machine guns were complete, if what was represented in the

Castillo & Casti!Jo
-
Registered Professional Reporters-
219 N,W, 12TH AVENUE MIAMI, 1=\.A, :33128
TE\.. 324-6311
131
invoice was in fact complete, and
I understand that.
believe,
Let's look for a moment, if we
may, at that invoice and that might give us some--
All .right, now, correct me if I am incorrect1 does
tt not say, your invoice, 197
197 tripods?
10
A.
.so
caliber machine guns and
Yes.
Okay.
11
ttow, explain to me further what you are say-
ing about you were paid for those.
12
13
A.
When you say complete machine gun, that means it 1 e
a complete 'machine gun
14
15
I'm talking about the tripods
Q.
.I understand that.
A.
The tripod is different unit.
now.
16
17
18
understand that.
And.you billed Boca Investnents
for the tripods and you were paid- for the tripods?
19
20
Yes.
21
Q.
All right, sir.
uow, you are trying to tell me
something about Mr. Ralph being responsible for furnishing
22
25
unit and a tripod is another unit.
24
answer was,
Just to clarify on one point, a machine gun is one
23
yo~r
'
the tripods..
A.
I don t quite understand that.
Mr. Ralph made .agreement with me that he would
supply the tripods, that we would refund this money to him.

Castillo & Castillo
- Reyismtd Professional Reporters 219 N.W, 12TH AVENUE MIAMI, fL.A. 33128
TEL.. 324-&31t
132
~
I see.
When did that agreement occur?
This agreement occurred before we made the invoice.
Where?
A.
In Lisbon.
And when, approximately, did that occur?
A.
This was after he decided that he did not want the
machine guns of Santo Domingor he wants to get t~e machine
guns of 'Portugal.
Well, now--
10
A.
Because--
11
You said--
12
MR. RICHMANz
Let the witness finish his answer.
13
UR. ANDREWS&
14
certainly agree I shouldn't inter-
rupt him and I'm apologetic, Mr. Richman, for having done so.
'
15
THE
WITNESS:
I told him that we
could~-you
know,
16
Portugal does not have the tripods but Santo Domingos do
17
manufacture the tripods, and he said, "You don't have to
18
worry about that.
19
BY MR. ANDREWSs
can get it frorn England."
20
Now, this was after
.21
This was during the agreement.
~he
agreement was executed?
All right, during the agreement.

23
Yes.
24
And I take it you told him, "I can furnish 197
25
.so
caliber machine guna"r is that accurate to what you are

Castillo & Castillo
- R~isttrtd. l'roft$$1'onal Rtporttrs 2t~N.W. 12TH AVfNUE MIAMI, fLA.331i8
TEL. 324-6311
-J
133
saying to me?
2
A.
Yes.
Q.
"But I cannot furnish the tripods"?
A.
I said, "I can supply you part of the tripods. "
And he said, "I can qat the tripods from England."
I Said, suppose you cannot get the tripods from
England?"
9
10
All right.
A.
He said, "What do we do is we pay you1 if you 'get

it, you're paid.
But if you dori't get it, I supply them;"
Okay.
13
14
A.
Under that agreement we got paid. Then we went--
15
Oh, before we give him this invoice we search in the States.
16
we could not get the tripods, there was a delay on it.

When did this occur, approximately, :th'is search in
17
18
the United States?
19
A.
20
thing.
21
22
23
This occurred before giving him any invoice or any-
Okay.
Did the two of you undertake.this search
together?
A.
He searched his part and I searched my .part.
24
But not in joint company?
25
No, we didn't go togetherJ no.

Castillo & Castillo
-
Regz'st~r~d hof~ssional R~porttrs
TU., 324-63it
Where
does that leave us?"
11
12
"Then where does--you know, where do we stay?
He was in London at
134
'that time.
2
3
4
And his suggestion was that he'll pay for the

and when he gets
After we got paid he called-.
He said he has located
tripods and he will supply them.
still search for it but when
he gets them we .refund the money to him.
5
6
thern-~ should
I said, Fine.
When they are ready, you let us
know and we pny you.
When he did find out--when he found the tripods, he
10
told us he was going to charge us $750 for each tripod.
11
said,
we
12
A.
t4
This one here (indicating).

Yes, $770.
15
A.
16
Yes.
He said, "Who is going to pay the transportation
from England?"
18
19
only pay you what we got paid.

Which was $770?
13
17
I said, "You pay .because everything starts from

Lisbon.-
20
He send me a telex once saying that tripods arc
21
and he has obtained the license from English Government to
22
ship the tripodo out and all he needs is an end.. user from
-23
Portugal.
24
25
road~
I said, wPortuguese Government won't give you an,end

user
because they are not users of these tripods, they are

Castillo & Castillo
-
R~lstued
'Professional Reporters -
219 N,W, t2TH AVENUE MIAMI, f'LA, 33128
TEL. 324-&311
13
going in transit."
2
And then he insisted that he got the license some-
how.
I don't know how.
Through different channels we checke
that there was no such license issued for the tripods.
the person who manufactures the tripod was contacted through
friends.
ready for shipment.
They said they don't have that quantity of tripods
And we told him that.
Let rne go back for a moment.
12
15
told him that.
gain payment of the $1,153,590, such as the air waybill-A.
13
14
All of the various paperwork which was required to
10
11
And
Yes.
--and the certifications of packing of equipment,
are you telling me that all those were fraudulent documents?

A.
16
No, I'm not saying that.

Well, you told .me yesterday about Browning making an
inspection in Lisbon at your request and your testimony was
18
that they then sent certifications directly to Washington, and
19
in those certifications it was required that, not only the
machine guns .be identified 1 'but the tripods be identified.

Now, I ask you, were those documents accurate or we
21'
22
they inaccurate?
23
would appear that the tripods never existed.
24
25
A.
From what you are telling me this morning i
There were tripods in the warehouse when the inspec
tion was done.

Castillo & Castillo
- Rrgi'stertd />rofessional Reporters 219 N.W. 12TH AVENUE MIAMI, Ft.A._33128
T-E_l.,
324~311
136
1'
When what 'inspection was done?
To inspect the weapons.
Browning?
Yes.
On the Browning Precision Tool inspection you say
there were tripods available?
I think so.
a pile of tripods.
9
10
'11
Because when I was in Portugal they had
Well, my point is-A.
We could buy that time of the inspection the tripods
when they were available.
12
But I say again, when the required certffications
13
were presented to Banque Bruxelles Lambert, which certifi'ed,
14
among other things, in the air waybill that all of the mer-
15
chandise
16
Airtrade and ready for shipment to Mauritania and here are
17
_packing certifications and serial numbers and what-have-you,
18
were those documents fraudulent or not?
19
described~
including the tripods, are in custody of
MR. RICHMANs
Object to that because the witness has
20'
no direct knowledge as to what was presented to the bank.
21
wasn't physically there.
He
I don't want him to speculate as to
what may have been done.

23
24
MR . ANDREWS:
I don't want him to speculate and I'm
not attempting to lead him into speculation.
25
Castillo & Castillo
- Rtgz'st(r(d l'rofrsslonal Rrport(rs 219 N.W. 12TH AV[NUE MIAMI, H.A, ~128
TEl. 324-6_3 t1
137
BY MR. ANDRBWSs
2
What I know to know precisely isa.
received the payment' of $1, 153 1 '590 was all of the equipment
at hand and ready for shipment to Mauritania?

A.
It was not?
A.
No.
0.
And you have no knowledge, or do you have any
knowledge, did you ever receive copies of any documents pre-
10
sented to Banque Bruxelles Lambert iri order to gain that pay-
11
ment?
'12
13
0.
No one ever furnished you anything?

A.
17
18
19
22
23
24
25
No, sir, no complete document or-Did you ever receive a copy of the air waybill that
was ultimately presented to the bank and accepted'by the bank?

A.
20
21
You did not?

No.
15
16
No.
14
No.
'
y~u
I~
At the time
Copy of--I don't know if it was accepted or not.

I understand you weren't there.
You previously
testified Mr. Williams went over for the purpose of presenting

'documents.
I repeat again, to the best of my knowledge Mr.
Williams was going to meet 'Mr. Ralph in Paris.
Okay.
And after the time you had received the

Castillo & Castillo
- Registered Professlonal Reportus 219 N,W, 12TH AVENUE MIAMI, FA33128
TE\.,~24~311
138
payment of the conies, did Mr. Williams or any other person
2
ever furnish you with copies of documents which were p-resented
to Banque Bruxelles Lambert?
A.
uo.
I take it you knew at the time you were paid that
you did not have the tripods described in your invoice.
A.
Excuse me, you want to repeat one More time?
At the time you 'received the payment did you know
9
10
that you did not in fact have the tripods for which you had
received payment?
11
A.
Yes.
12
~ou
13 '
A.
Yes.
14
And now you have described to us this morning
knew that?
certai~
15
conversations that were held between you and Hr. Ralph con-
16
cerning his furnishing the tripods.
17
back, Mr. Soghanalian, and rny question was, "Why did you not
18
furnish the machine guns to Mauritania,"and your answer was,
19
"Because we did not have the
20
A.
21
We will go all the way
tripods~"
Is that--
Correct.
Is that fairly accurate?
22
A.
Yes.
23
Q.
Now, I want to show you some additional documents,
24
the first being a letter dated november 15, 1977, the same
being Exhibit 11 to plaintiff's Complaint, directed to Boca
Castillo & Castillo
- Registered Professional R<'porters 219 N.W, ,2TH AVENUE MIAMI, fLA, 331i8
'TtL. 324-63n
1'39'
Investments and written in your name by R. M. Williams, and

2
ask if you can identify that for me?
3
4
11 '
12
BY
lm.
Q.
'
Okay.
Explain when you first saw it
ANDREWS z
Let me ask you this--
Go ahead.
This letter (indicating)?

Yes, sir.
I did not instruct him.
19
Okay.
20
25
Yes.
WI'l'NESSs
execute that letter?
18
24
T~E
Did you authorize and instruct Mr. Williams to
17
23
You have seen it before sitting here
llo, go ahead.
16
22
MR. RICHMANa
and how you saw it, to identify it.
14
21
No.
MR. RICHMAlh
13
15
'l'HE WITNESSa
today?
10
The question is have you seen it
before.
HR . RICHMAth
MR. ANDREWS:
Will you mark that for identification,
please.
('l'he letter referred towas thereupon marked by the
reporter as Plaintiff's Exhibit No. 11 for Identification.)
BY MR. ANDRE\'lS:
Did ,you ever have any knowledge of that letter in a
Castillo & Castillo
-
R~glstert>d
Professlonal Rrporters -
219 N.W. 12TH AV.ENUE MIAMI, I'LA. 3lt2S
TU. 324~311
140
way, shape or form?
.,
'
Not before that was written.
Not before it was written.
5
6
written?
k
12
13
What documents were mailed?

MR. RICHMAN:
For clarification, he's talking about
after the lawsuit was filed, when the Complaint was filed.
10
'11
When the documents and other papers were mailed,
this was among photocopies with Mr. Brenner.
8
9
Well, after it was
MR. ANDREWS:
I see.
BY MR. 'ANDREWS:
Your first recollection of ever seeing that letter
was after this instant action had been commenced?
14
'Yes.
15
You had never seen it before?
16
1>.
No.
17
Never had any knowledge of it?
18
A.
no.
19
All right, sir.
20
show you next a copy of a letter directed to Boca
21
Investments, Ltd., executed by 'Airtrade under the signature of
22
Williams.
23
MR. RICHMAN:
Excuse me, I don't fuean to interrupt
24
you, but so it will be clear, I think the witness is inter-
25
pretinq this action as also including the federal action, if

Castillo & Castillo
- Rtglsttrtd 1'rojtssional Rtporttrs 21~ N.W, 12TH AVENUE MIAMI, F\.A. 33128
TEl., 324-6311
141
you foll0\'1 me.
'
In other words, that was part of the Corr.plaint
in the federal action.
So I just want to make sure that we
are not inferring--we are just talking about the state action.
BY MR. ANDREWS:
'
Let's get it clear that the first -time you became
acquainted with the letter that is now Plaintiff's Exhibit 11
for Identification was upon the initial filing of litigation
by the plaintiff, Boca Investments, is that correct?
A.
Yes.
10
That is, you had never seen it before?
11
A.
t:o.
12
You knew nothing about it and never authorized its
execution?
13
14
A.
Not this letter.
15
Not this letter.
16
Now, I believe I was trying to describe for you
17
another letter written by Airtrade, being Exhibit 12 to
18
Plaintiff's Complaint, written to Boca and indicating therein
19
that the shipment to Mauritania was being delayed due to
20
mechanical difficulties with the aircraft.
21
Will you take a look at that and tell me if you can

identify that copy.
22
I
23
HR. RICHMAN:
Look at it.
24
THE WITNESSz
I don't see any letter like this
25
There's no date on it.
before.
Castillo & Castillo
hofr_sslonal Rrport~rs -
~ Rt>gisru~d
219N.W.12THAVENUE MIAMI,H.A.~128
TU.. 324-6311
142
BY MR. ANDREWS:
2
3
4
5
7
8
9
0.
to send that letter?

k
To whom?
0.
Yes, sir.
A.
Did you ever see that letter o~ become aware of that'
18
19
20
21
22
23
24
.(
~
~
25
This letter (indicating).

~
This letter, no.

MR. ANDREWS1
cation.
15
17
I don't think.so.
No, I did not see any letter.
13
16
don't recall.
matter?
11
14
To Boca?
letter prior to the institution of any litigation in this
10
12
'Did you ever instruct or authorize R. M. Williams
Incidentally, mark that for idcntifi-
That willbe 12.

(The letter referred to was thereupon .marked by the
reporter as Plaintiff's Exhibit No. 12 for Identification.)
BY MR. ANDREHSz
0.
Now, according to your testimony this morning, after
you had gained the payment the delay in furnishing the weapons
to Mauritania was only because of the matter of tripods.
Was
any delay, to your - kno~ledqe, caused by mechanical difficultie

with the aircraft described in the air waybill?
Do you have
any knowledge of any mechanical difficulties attending

N711UT immediately after you received payment?
A.
No.
Castillo & Castillo
- Regl'smed Professional Reporters219 N.W:t2TH AVENUE MIAMI, H.A, 33128
TU., 324-631!
143
~
oo you have any knowledge that such mechanical
difficulties would have made delivery delayed to Mauritania?

'
MR. RICHMAN:
I'm not sure that I--
said he .has no knowledge of
think that that has to answer your question.
difficulties, so .I
'BY MR. ANDREWS:
7
8
m~chanical
He's already
And you have no knowledge at all of this letter

(indicating)?
'l'his letter, no.
10
All right, sir.
And it was never brought to your
11
attention, I take it, at any time subsequent to--we don't
12
know the date.
13
Of the letter or the mechanical problem?
14
No, the letter.
15
16
17
18
A.
I'rn speaking of the letter .now.
No.
You already said you had no .knowledge of mechanical
difficulties.
All right.
I next show you a letter dated 18 December 1977
19
directed to United 'l'rade International,, Inc., in Arlington,
20
Virginia, from Avitextll, signed by J. Martins, which here
21
asserts that delivery will be made upon renewal of an expired
22
export license.
23
In any event, I ask if you .can identify that letter.,
24
Yes, I remember this letter.
25
Did you authorize or instruct that that letter be

Castillo & Castillo
~
Rrgi.sttred 'Professional Reporters -
219 N.W. 12TH AVENUE MIAMI, FLA. :33128
n'-. :324-6311
144
wri'tten?
2
A.
I did not instruct but I
0.
That it be written?
A.
To have an explanation.
Q.
Who did you ask?
A.
Mr. Martins.
0.
And this was the explanation that Mr. Martins--
A.
This was the explanation I got.
Q.
Did you have any .reason to question that explana-
10
asked.
tion?
A.
12
Q.
Had you then resolved all
matter~
of the tripods?
1..
14
15
16
0.
Well, then, there is a conflict in his explanation
then and the knowledge that you hadJ is that correct?

A.
No.
You had asked him for an explanation why shipment
17
18
was delayed?
19
A.
Yes.
20
And in response to that he wrote this letter of
21
18 .December saying. that an export license had expired, or at
22
least that is the import of it.
23
Would you say that was the
, import?
24
Yes
25
.nut you say that, in fact, he couldn't have shipped

Castillo & Castillo
R~ist(r(d hof($Sional R(poners 219 N.W, 12TH AVENUE MIAMI, H.A, 33128
TEL.. 324-6311
the merchandise in any evont .because the tripods were not

2
available?
He's talking about the machine guns.
Only machine guns?
Yes.
And those are the same machine guns that you have
described that you made payment to him for themJ is that cor-
rect?
Yes.
10
11
12
Do you know anything about his reference to the

expired export license?
A.
13
14
Who told you that?

A.
15
16
17
I was 'told that the l _icense was expired.
Mr. Martins.
In whose name had that export license been issued?
A.
All
{l
Yes, but in whose name was the export license, the
recall was for the subject
o~
the machine guns.
18
one that is referred to as having expired, in whose name would
19
that have been issued?
to
For?
21
Yes.
A.
_I think -Mauritania.
2_3
Well, clearly the license would have allowed export
24
of the weapons to Mauritania, but who would have been author-
25
ized under the export license to
~ake
the export?
Castillo & Castillo

- Reylstertd Professional RepoTttr$ 219 N.W. 12TH AVENUE MIAMI, I' LA. 33128
Tf:L , 324-63t1
-
--
- - - - - - -------
~ ---=-=--~---=-.:.::._::_...:.___
_ _~
146
A.
'Avitextil.
Q.
And who would have issued such a license1 Portugal?
Portuguese Government.
In these particular circumstances was the export
5
6
license your responsibility?

A.
No.
And going back to tho letter
you would assume all
that letter written by Williams.
10
J\.
11
responsibili~y,
where it purports that
you have no knowledge of
no.
Do you know, Mr. Soghanalian, if an export license
12
was, in fact, re-issued or ever issued or re-issued concerning
13
these machine guns?
14
15
No.
Q.
I want to show you next a letter writteri by United
16
Trade International under the signature of Harold Richmond to
17
~Banque Brussel Lambert" dated 25 January 1978, being. Exhibit F
18
to John Ralph's affidavit, and ask if you can in any way iden-
19
20
"
tify that copy?

A.
21
22
23
.what do you want me to identify?

Have you ever seen it before?
Do you have knowledge
of it?
A.
I seen this letter with the file that was mailed.
24
was that the first time you ever saw it?
25
Yes.
Castillo & Castillo
-
R~istfrfd ho/fsslonal Rfportfrs -
219N.W. 12TH AVENUE MIAMI 1 H.A.3312S

"T1... 324-63t1
147
That letter reflects, incidentally, a branch of!ice
'1
at your residence address.
branch office there?
Did, in fact, United maintain a
MR. RICUMAN:
He's referring to that (indicating)-.
THE WITNESS:
For mailing purposes, yes.
MR. ANDREWS:
Okay.
BY MR. ANDREWS:
Was that letter mailed from that address, or you
9
10
said,you don't know, you.had never seen that letter before,

is that correct, until this litigation?
11
Yes, I have not seen it before.
12
Okay.
13
subs~diary
14
subsidiary?
15
A.
16
That letter also.characterizes Airtrade as a
of United Trade International.
Was it, in fact, a
No.
Now, the letter also says--which you have not seen
now until the litigation--that the machine guns are in posses-
t8
sion of Airtradc.
19
January?
20
21
22
A.
Was that, in fact, accurate as of 25th
No, it's not accurate.

And, further, the letter indicates that as of that
date the .export license had been reissued.
If you will look
23
here, "The delay following the issue of the export license has
24
arisen out of the movement from the military warehouse to
the factory, et cetera.

Castillo & Castillo
- Rrgistered hofessionol Reporters 219 N.W. 12TH AVENUE MIAMI, FLA. 33128
TU.. 324-6311
148
~---------~--~------------------~~
Do - you know .if 1 in fact, the export license men2
tioned in previous communications directed to you .had, in
fact, been renewed as of January 25, 1978?
No,
You don't know?
No.
Were you in communication with Mr. Martins during
12
,A.
Once in a while.
What do you mean by once in a while"?
It~was
pretty hot item of controversy, wasn't it?

A.
No,
used to. call him.
Would he have kept you advised if the license had
13
14
don't know.
this period of time?
10
tt
been renewed to
A.
16
Avi tcxtil?
He \.zould immediately advise me.

Did you ever gain -such advice? '
No.
18
Never?
19
A.
No.
20
Q.'
Now, I have shown you several documents which you
21
.had not seen, first talking about mechanical difficulties and
22
the next one talking about an expired license, and now another
-23
letter which you haven't seen, stating that the delay now is
24
because of movement fro,/the military warehouse to the factory.
25
Do you .have any knowledge of any delays because of

Castillo & Castillo
- Rt-gisured Professional Rtporttrs 219 N.W. 12TH AVENUE MIAMI, FLA.~12_8
TEL. 324-0311
e.
149
movement of these weapons from the military warehouse to the

2
factory?
If there was any delay-- ,can you ask me again that
3
4
question, please.
Do you have any knowledge of any delays experienced
in getting these weapons to Mauritania caused by difficulties
in movement of the weapons from the military warehouse to the
factory?
MR. RICHHAN s
9
10
knowledge
You are asking for his personal
or what he may have heard?

What does he know about it.
Le~
11
MR. ANDREWS:
him
12
tell me what he knows.
13
THE WITNESS:
Oh, well--
14
MR. RICHMAlh
Tell what you personally know, or if
15
it's just something you heard, qualify it, but just say what-
16
ever you know about it.
17
THE WITNESS:
I heard that they were having some
18
difficulties to move them from military warehouse to another
19
military warehouse because one warehouse didn't have enough
20
space or--
21
BY MR. ANDREWS:
22
:Q.
23
A.
24
25
I see.
This was the explanation I got.
Who gave you that explanation?
A.
Mr. Martins.
Castillo & Castillo
-
R~isrrrrd
hofrsskma/ Rrporurs -
219 N.W. 12TH AVENUE MIAMI, Ft..A. 331:28
TEt.., ~24-6-31 t
150
2 '
0.
l'lheh di'd
A.
D~ring
h~
In January?
'4
Sort of.
Sort of.
Do
7'
Facto;-y?
as Avitextil?
I know they have an
o~fice
import-export.
That letter refers to "factory;"
'Q.
12.
meaning to you?
13
the factory . You
14
Does that have
It talks about moving from .the warehouse to

know what that wotild mean?
d~nt
(Shakes head).
No.
Now, are you acquainted with Mr. Richmond?
Q.
.16
Yes.
17
Who is he?
Q.
18
19
fa~to;y
Not .to my knowledge.
11
15
equate the
Yes.
Q.
10
.explanati~n?
the transaction period.
'3
you~
give. you that
MR. RICHMAn 1
.H . J.
Richmond~
M~.
.For tho record, you re talking about ,
~rwhatever--
ANDREWS:
This l~tte~ that 'he hasn't seen that
21
purportedly. \-Jritten-,on behalf of United Trade International
22_
n4 signed, "Yours faithfully, Harold J. Richmond, Regionil

Director."
24 BY MR. AltDREl'lS
25
Was Mr. Richmond ever regional director for United

Castillo & Castillo
-
f?eglsttr<d /'roftsslonal Rtporttrs-
219 N.W. 12TH AVENUE. MIAMI, FLA,3_3_12S
TH. 324-6311
151
Trade .International, Inc.?
2,
";.,
Q.
Tell me what you know about hiro.,. if you know any-
I know 'him, yes.
Q.
Did you ever employ him?
Q.
12
13
16
21
Did any company with which you were associated in
No.
can explain.
MR. RICHMAN:
Just explain.
THE WITNESS:
Mr. Richmond is an . expert in weapons.
MR. ANDREWS:
We have qot a lot of exporta here in
\le , .
if nothing else.
THE
WITNESS:
Just like we have too many lawyers.
MR.
A~DREWS:
All .right.
B'l HR. AU DREWS:
18
20
..
weapons 1 haven t
15
'19
",,.... -
this transaction ever employ him?
11
f7
No.
A.
10
14
Do you know him?
.....--
8
9
thing about .him.
Back to Mr. Richmond, he's a weapons expert, you
Yes, and I hired his services, his expertise, for
say?
several things, other transactions.
_2-2
Other than, this transaction?
23
A.
Yes.
When did you first hire him as an expert?
A.
I did not hire him as employee.
24
25
Castillo & Castillo

-
Rrglsrered Professlonal Reporters.-
219 N.W. 12TH AVENUE - MIAMI, Ft,.A, "331-28
-T.1.. 324-631\
--
- ~ --
----
- ----
- - -
-- -- ----"-==----- -=-_;_:;__-'----
152
1
As a consultant, whatever.he ,was.
Consultant.
until--I don't remember exact date until when he return from
Europe.
Mid part of November when?

MR. RICHMAN:
What year
MR. ANDREWS:
Yes.
THE WITNESS:
1977.
10
11
12
13
14
15
16
17
18
with the United Trade International, Inc.?

A.
No, he was doing business, you know' for me.

MR. ANDREWS:
Excuse me, we did not mark that.
MR. RICHMAN:
Let me suggest you have the December
18th letter that has not been marked.

MR. 'ANDREWS:
18th letter of Martins.
MR~
ANDREWS:
That is the one I have here, .Dececber

That is the next one.
That should be 13.
And the next one will be the letter o
,January 25 directed to "Banque Brussel Lambert" on the letterhead of United International and signed by Harold
Richmond~
(The two letters .referred to were marked by the
24
reporter as Plaintiff's Exhibits Nos. 13 and 14 for Identifi-
25
cation, respectively.)
Castillo & Castillo
- Rtgi$ttrtd Pro/tssional Rtporrtrs219 N,W, 12TH AVENUE MIAMI, H.A, 33128
'TEL. 324-6311
Ma
that January 25th letter as Plaintiff's Exhibit 13.
2-0
23
think you are asking.
Was he, to your knowledge, in .any way associated
MR. RICHMAN:
22
BY MR. ANDREWS:
19
21
...
And .it was mid part of November, up
153
BY l'iR.
ANDRE~"lS 1
Next, Mr. Soghanalian, I showyou a copy of a tele-
-gram directed to John Ralph, Boca Investments 1 and signed
sarkis G. Soghanalian, the same being Exhibit 14 to
plaintiff's. Complaint, and I ask if you can identify that c
A.
Yes.
Did you send that telegram?
A.
Yes.
MR. ANDREWS:
9
10
Reporter.
(The copy of telegrac referred to was thereupon
11
12
marked by the reporter as Plaintiff's Exhibit No. 15 for
13
Identifica:tion.)
14
MR. RICHMANa
Where is the date on that?
15
MR. ANDREWS:
It has to be in February.
16
MR. RICHMAN:
The 1st of February?
17
MR. ANDREWS:
The date is up here somewhere.
18
MR. BRENNER:
In the right-hand corner.
19
It says
something like February 7th or something.
20
...
Will you mark that, please, Mr.
MR. RICHMAN:
Okay, February 7th.
Looks like an
21
office stamp.
22
BY MR.
23
You sent that telegram?
24
A.
Yes.
25
Q.
Now, you state in there the reason for the delay as
ANDRE~i'S:
Castillo & Castillo

-
R~lst~r~d Pro/~ssiorial
Rtporttrs -
219 N.W. 12TH AVENUE MIAMI,'I'LA. 33t28

TEL, 324-6311
154
of February 7th, if that is the date, is because of the

2
Portuguese national holidays.

A.
For the delay?

Yes.
4
5
Was that, in fact, the reason?
A.
No.
I did send this telegram to tell them that
I'm not up to date aware-MR .RICHMAN:
Let
m~
note an objection, Counsel, to
the form of the question.
I think counsel's characterization
of the telegram as saying that it's due to the holioays, the
10
delay, is not really what the telegram says.
11
BY MR. ANDREHS:
Did you in any way intend to assert that the delay
12
13
in shipment was occasioned by the Portuguese national holi-
14
days?
15
A.
16
17
holidays?
18
19
20
21
22
25
Why did _you make reference to the Portuguese n&tion

What was the purpose, just to say "Happy Holidays
No, not to have a happy holiday.
Because I could
not get hold of Mr. Martins.

I see.
I assume those holidays ended and -did you
thereafter contact your agent, as you say in that telegram?

A.
23
24
'No.
Yes.
Okay.
A.
What happened when you contacted him?.
He told me that the goods are at the .factory.

We are trying to get-Castillo & Castillo
- Rfgistered Professional Reporters 219 N,W, 12TH AVENUE MIAMI, n.A,-33128
TEL, 324-6-311
.e
~
.t;
155
Or at the warehouse.
We are trying to get the goods to Mauritania, aren't
we, and we have had some difficulty with a license and--
Get explanation from Mr. Martins.
Did you get any explanation?
Yes,
10
got--
and after the date.
You are .bringing papers before the dat
I don't know which one is--
Let's zero right in on the Portu9uese national holi-'
days are over which had occasioned difficulty for you contacting J. Martins.
11
Yes.
12
And you indicate even :in the telegram you are going
13
to contact him.
I assume it's to rustle up the .bushes and'
14
qet the quns to Mauritania.
15
Correct.
16
Did you contact him then?
17
A.
Yes, I did.
18
What didhe tell you?
19
He told me that he was waiting for the license and
w
21
~
23
24
25
also for the tripods.

He told you again that he did not have a license as
of February?
I think so.
I don't remember what he said, but his
explanation was passed to Hr. John Ralph. Whatever it was &t

that time, I don't remember.
Castillo & Castillo
~
Rrgisttred Professional Reporters-
.219 N.W,12TH AVENUE MIAMI, f'lA. 33128
. Ttl-. 324-e3tt
156
~
Now let me ask you this.
I want to turn back for a
moment in the pages of tiDe.
We are back to September of 1977.
Did John Ralph, in September of 1977, deliv~r ~o you an end
user certificate issued by the country of Mauritania for pur-
5 '
poses of you gaining a United States export license for the
machine guns?
'
He brought me a document, yes.
Do you have that document in your possession?
9
10
11
12
No.
The document must be with.QRC, to the best of
my knowledge.
0.
And was that for the purpose of obtaining an export
license?
13
HR. RICHHANt
From the United States?
14
~HE
From United States?
15
MR. ANDREWSt
Yes.
16
THE WITNESS:
Yes.
17
MR. ANDREWS:
Okay.
18
19
WI~NESSt
BY MR. AUDREWS:
~
Now, you may need to refer back, but your invoice
20
reflects a freight charge--we had discussed that earlier--of
21
$76,000, an air freight charge.
22
A.
Yes.
23
0.
That invoice (indicating).
24
A.
Yes.
25
0.
Now, let me ask you:
Was, in fact, that a freight
Castillo & Castillo

- Registered Professional Rtporttrs219 N.W. 12TH AVENUE MIAMI, f\.A, 33128'
TEL. 324-6311
------=-'-==--"---------'---'--------"'=----=--
157
charge calculated back at the time that you executed tho

2
3
4
agreement, the July 11th agreement or July 13th, the two dates
appearing on it?
Was that a freight charge calculated from
the United States to Lisbon .to Mauritania?
No, from Lisbon to Mauritania.

Only?
A.
9
10
Are there usual and,custornary freight chatges, Mr.

Soghanalian, or are those a matter of negotiation between
parties?
11
12
Yes.
It's negotiation between partiea.

Q.
And this sum did not represent anything, you say,
13
except a charge for freight from Lisbon to Mauritania, as
14
opposed from the United States via Lisbon to Mauritania?
15
A.
No, was from 'Lisbon to Mauritania.
16
now, in January of 1978--
17
Yes.
18
--did John Ralph deliver to you yet another end
19
user certificate, not the end user certificate that we have
20
just discussed in September but yet another end user certifi,

cate issued by the country of Mauritania which would allow
21
22
renewal of the required export license to Avitextil?
23
not to me.
24
Do you have any knowledge of his delivery of any
sue~
end user certificate to anyone involved in this transaction?

Castillo & Castillo
- 'Reyisttrtd Professional Reponers 219 N,W, 12TH AVENUE MIAMI, FLA. 3312S
TEL. 324-6311
_________________~tt-_____________1~58
~---------tt
1
I don't remember.
11.
You have no knowledqe of a subsequent end user
2
3
'certificate?
6
7
10
Q.
Well, all right.
now do you know that he gave an
MR. RICHMANa
I just want to make sure we are not
confusing the question.
We're talking about December alone
or in January?
MR. ANDREKSa
Talking about .a subsequent one, and
let it .be Nixonian clear, January -1978.

THE WITNESS:
To be clear, I don't remember.
14
MR. ANDREWS:
All right.
16
BY HR. ANDREHS 1
Q.
Now I want to show you yet another letter.
This is
17
dated December 9, 1977.
18
Defense of Mauritania.
19
purports to have been written, although unsigned, by United
It's directed to the Minister of

It's French in its content, but it
20
Trade International, Inc., -through QRC International, and let
-21
me ask if you can identify that copy?
22
11.
I mean, what is the question?
23
Q.
can you identify that letter?
24
~(
was in it.
13
15
wh~t
end user certificate and to whom did he give it?
11
12
I 'know he has given
an end user certificate, but I don't know
I'm not aware of the contents.
z:s
Have you ever seen
it before?
11.
Not the letter, but I .m aware of Mr. Holcomb asked

Castillo & Castillo
-
R~lsrued
hof(ssional Reporters -
219 N,W, 12TH AVENUE MIAMI, I'LA, 3312$
Tft.. 324-6-311
'
me--he was asked by, Hauritanian. Ambassador in Washington .to
give him a list
if I would back him in case he
v~..::t'ae
could supply, and. Mr. Holcomb asked r.:tc

~ake
such proposal.
Did you instruct and authorize Mr. Williams to
said, "Yes."
deliver the original of that letter to the Mauritanian
Ambassador?
Mr. Williams was not work-ing for
Well, that may be the case.
r.~e.
My question is:
Did
10
,you ever instruct Mr. Williams to deliver, and by hand, the
11
original of that letter to the Mauritanian Ambassador in
12
Wash;ngton, D. C.?
13
14
15
You don't know?

k
16
17
No.
said, "No."
Your answer is "No"?

k
18
No.
nve you, subsequent to the date of that letter,
19
December 9th,-either individually or through any company that
20
you are associated with, furnished any military equipment to
21
the country of Mauritania?
22
23
24
.25
Excuse me, you want to ask me one more time, please.

sure.
A.
At any time subsequent to 9 December 1977--
Yes.
--have you, either individually or through any
Castillo & Castillo
-R~isurtd
Proftsslorial Rtporttrs-
219 N,W, 12TH AVENUE MIAMI, FLA. 33128

TEL. 324-6311
160
company with.which you were associated, furnished military
2
3
equipment to the country of Mauritania?

A.
'4
5
6
Yes.
Okay.
A.
When and what?
There were some mortar rounds that I had sold to
.Mr. Ralph, Boca Investment.

I'm saying subsequent to December 1977, excluding--
A.
10
11
12
Excluding the 81 millimeter mortar rounds, have you

furnished.any military equipment and/or armaments to the
.country of Mauritania?
A.
13
14
You mean after '77?
.No.
Individually or through any company with which you
were associated.
15
No comment.
16
What do you mean, .no comment?
17
I can't expose military operations of other coun-
18
tries.
19
2.0
Why can't you?

'A.
21
It's not my obligation.

Well, it's your obligation here.
We have a count
22
in this
23
.fere with contractual relationships with the country of
24
Mauritania, and it's to that end that I am inquiring.
25
A.
Compl~int
that you interfered' and set about to intcr-
You're inquiring if I have supplied Mauritania?

Castillo & Castillo
- Registtrt'd Professional
Reporters~
219 N.W. 12TH AVENUE MIAMI, FLA, 33128

TEL. 324-6311
lEa
1'
Yes, sir.
After signing a contract with Mr. Boca or--
Mr. Ralph.
A.
No.
You have not?
5
6
--or Ralph?
A.
No.
Either individually or through any company?
No.
Your answer is no?

No.
10
Now, from the $1 1 153 1 000 that you received, paid to
'11
12
you for the machine guns, didyou use any of those proceeds
13
to purchase yet another Boeing 707 aircraft?
~
.,
14
15
A.
paid from my account for Boeing 707, and alao for
other stuff.
Well, I'm talking particularly about a Boeing 707.
16
Did you, in fact, buy, purchase, yet another additional air-
1a
plane frorn the account to which the $1,153,000 was deposited?
19
A.
21
tared?
22
A.
23
24
25
I did purchase a Boeing 707, yes.

Okay.
20
~nd
in what company was that aircraft regis-
United Trade International.

And does that company yet own this aircraft?
A.
No.
What disposition was made of it?
\.
Castillo & Castillo
- Rrgi'stered Professional Reporters219 N,W, 12TH AVENUE MIAMI, f:t.A, 33128
nt..324~3a
162
A
What do you mean?
Q.
What happened to it?
,A
It's sold.
Q.
When?
November .
Q.
This past November?
Yes.
Q.
To whom?
A.
To a company called Aero Support.
10
Q.
Where is that company located?
11
In Miar.\i here.
12
Q.
Who did you deal with at Aero Support?
13
A.
Two persons.
14
15
16
17
and the second person was Abbott,Abbott Hardy.

Q.
Incidentally, does United Trade Internatiunal yet
own the N711UT?

A
18
19
One name was Robert DiSanto or DiSanta,
Yes.
Does that aircraft continue to be based and main-
tained here in Miami?
20
Most of the time.
21
Back in about the latter part of November, when, in
22
fact, you received the
23
that aircraft?
24
25
$1 1 153,000~
who was then the pilot of
To the best of my knowledge, didn't have any fixed

.pilot.
Castillo &Castillo
- Rtglsrered Professional Reporlers 219 N,W, 12TH AVENUE MIAMI, H.A, 33128
TU.. 324~311
163
~
Nobody was on the payroll?
k.
No.
-~
Is anybody on the payroll now as a pilot?
A.
No.
How would you have obtained--assuming that all of
the sold merchandise or purportedly sold merchandise was in
hand ready to fly off to Mauritania at or about the latter
part of November, who would have piloted the aircraft N711UT?
10
'
the pilot listing company.

~
Is that how you obtain your pilots?
12
A.
Yes.
13
So when you have nead of a pilot you gain one thro
a pilot listing company?
15
k.
Uh-huh.
16
Where is the pilot listing company located, locally
18
A.
In Miami.
19
17
It would be any captain that would be assigned by
11
14
:~
~-
A.
Yes.
here?
.Now, from the monies paid toyou for your invoice,
20
did you ever thereafter use any of those proceeds to pay a s
21
of money to Mr. H. J. Richmond, the author of the letter that
22
you have never seen, the January 25th letter to Banque
23
Bruxelles Lambert?
24
A.
25
.~
No
From those same proceeds did you use
~ny
of those
Castillo & Castillo

.-... Reylsttrtd Professlonal Reporters-219 N.W. 12TH AVENUE MIAMI, FLA. 331:iS
"'rEt., 324-63,
..
----------------------~--==~~~~~~~~~~~~~--~---
sums to .pay any sum of money to J . Martins?

2
Partly, yes.
Whatdid you make payment to him for?
At what date?
Well, any payments that you may have made to him
subsequent to the receipt of the $1,153,590.
"7
Yes, we did.
Q.
For what?
For machine guns.
10
Connected with this matter or unconnected with this
did.
matter?
12
Connected with this matter.
13
Q.
Okay.
14
15
A.
No.
16
Q.
Okay.
18
.22' '
23
I would like to take a short break, if
MR. RICHMAN&
Sure.
(Thereupon a short recess was taken.)
20
MR. ANDREWS:
I may.
"19
21
Did you pay him any other sums of money for
any other purpose?
17
BY HR. ANDREWSt
Q.
Mr. Soghana1ian, who today presently owns United
Trade International, Incorporated?
24
You mean the.shares?
25
Q.
Yes.
I
I
Castillo& Castillo
- Reylsrtred Proftssional Reporters 2t9 N.W. t2TH AVENUE MIAMI, f'I.A. 33t:iS
'T E 1.. 324-631t
.e
A.
.My ex-wife.
Your ex-wife owns all of the shares1
'A.
See, she owned 'the shares but the certificates are
in
col~ateral
THE
BY
MR.
WITNESS:
Yes.
ANDREWS:
She owns all of the shares .in United Trade?
10
A.
.Yes.
11
Has she always owned .all .of the shares from the
12
inception of that.company?
13
I assume whoever's name is on it that's the owner.
A.
mean, I have to explain.
14
15
shares, this and
16
her name.
mean,
don't know too much about
legal part, but it's her--you know, on
~hat
17
And always have been so far as you know?
18
A.
Yes.
19
You don't know of any transfers that have occurred
20
since
th~t
corporation was formed?
21
A.
Transfer?
22
Yes,. of stock to her.
"'
23
24
~.
The question is who owns the shares.
Is she the owner of the shares?
against the loan that UTI--
MR. RICHMAlh
165
25
HR. RICIIMAN :. .Do you understand the question?
When
the company was formed was she the owner of all the shares1
THE WITNESS&
Yes.
Castillo & Castillo
- Rtgistued Professional Reporters 219 N,W, 12TH AVENUE MIAMI, fLA, 3312S
TEL. 324~3 t1
1:66
'1
MR. RICHMAN:
Has she consistently been the owner
all the way through?

3
4
TlU: WITNESS:
-BY MR. ANDREl'lS:
5
6
7
You mentioned also you have some knowledge of a

loan to UTI for which those shares are pledged as collateral.
A.
8
9
10
'
A.
Now, who
A.
A.
23
24
25
And also my uncle.

Did you identify him yesterday as
MR. RICHMAN:
Give him the name.
THE WITNESS:
Ohannes Kupelian.
BY MR. ANDREWS:
20
'22
You know, I borrowed it from Mr.--
being the man who provided--
18
21
No, not me.
the loanJ you?
And your uncle.
17
19
~ade
I recall you identified the man yesterday.
15
16
The nature of that loan was to purchase the air-
craft.
13
14
Yes.
And what is the nature of that loan?
11
12
She was
Where does he live?

A.
Beirut, Lebanon.
How much did he loan you?
I have to check.
It was in Lebanese pounds and we
bought dollars.
Approximately how much?
Castillo & Castillo
--
R~lsured
Professional Rt'porurs -
TU., 324-6311
A.
About six'hundred thirty thousand.
0.
Okay.
A.
About seven hundred
0.
Did you.give to them your personal note for those
loans?
A.
Yes, I gave them notes and I gave them a letter.
0.
Was this the guarantee .you were speaking of yester-
2
3
9
10
And the other gentleman, how much did he
loan?
thous~nd.
day when you said, I personally guaranteed this loan?

A.
Yes.
11
Did your wife give them any evidence of this loan?
12
She didn't give any letter or anything, no.
13
She didn't sign anything?
14
A.
15
16
17
A.
22
25
She signed back of the, you know,
She did sign over the certificates?

A.
Yes.
And then what.became of the certificates?
they now?
A.
23
24
No, she did not.
back of .the certificates.
20
21
wife~
Did she sign anything?
18
19
At that time shewasn't my
They're with my uncle.

You gave them to your uncle?
A.
Yes.
Did you give us his address?
Castillo & Castillo
- Regz'sttrtd Profrssional Rtporters 219 N,W, ,2TH AVENUE MIAMI, FL.A, 331:i8
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Where are
168
In Beirut?
'A.
2
Yes.
No, I didn't.
What is his address, if you know?
Louis Pasteur, Beirut, .Lebanon.
And Shirley signed those certificates and you
delivered them to your uncle and they were for the
collateral security for the loan that you have described?

Yes.
If you like, you know, I can explain.
10
Would you explain it.
11
MR. RICHMAN:
Is what he said correct?
If
i~'s
12
correct and you .need to explain it orqualify it, go ahead
13
and do so.
THE WITNESS:
14
15
MR. ANDREWSc
17
time.
18
BY
20
not
Well, .would you 'like to ask me one
more time, then.
16
19
of
~urpose
MR.
Yes, I would like to ask you one more
AtlDREWS:
When Shirley signed the certificates did you then
present .them to your uncle?
21
No.
22
No?
23
The certificates were sealed and nailed to my ex-
wife aud then she kept it for ' period of six
then when the paymentY were due and was delayed and we had a
Castillo & Castillo
-- Registtre_d hof(ssional R(port(rS -
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And.
,,
..
219 N.W. 12TH AVENUe MIAMI, FI,.A, 3312_8
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169
little bit of argument, in order .to give them confidence I

2
gave
the~
Shirley gave them back to you and then you gave them
3
4
the shares, the papers.
to your uncle?
A.
Yes, I gave them.
When did that happen?
About maybe ten, eleven months.
And your uncle yet holds those certificates?
Yes.
10
11
12
So far as you know?

A.
Yes.
And then my uncle give other engagement 'to the
other loaner.
13
What do you mean by that?
14
Because they are two loaners, Mr. Saba and my
15
uncle, because they were 'both complaining.
16
17
Has either one of those loans that you have

described ever bean repaid?
18
As of today, nothing is
19
Is there any due date for payment?
20
A.
~aid
yet.
There was a date about a year ago, fourteen months
21
ago, and then that wasn't done because of the war and all the
22
troubles, and ten months ago I renewed the debts for December,
23
this December, and that was overdue also, and I was asked to
24
bring it up to date about a month ago.
I haven't done any-
thing about lt yet.

Castillo & Castillo
- Registered Professional Reporters 219 N,W. 12TH AVENUE MIAMI, F\.A; 33128
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-- - - - - - - - - - - -------==----=---=='--------'--=---'---'------'---=-~-;;;:_---::;_~------=~c.:..---='---'----=-=---'-'-----=-c-'--=---'
.,_.
0.
Are you going to?
A.
I'm intending.
0.
When?
A.
As soon as I can.
MR. ANDREWSa
5
6
MR. RICHMAth
MR. ANDREWSs
And I do want you to expedite getting
it typed up for us and into Mr. Richman's hands for editing.

(Thereupon, at llsSS a.m., the deposition was
11
12
The witness will not waive reading ana
signing, and we would like a copy.
10
I have nothing further, Mr.
Soghanalian.
concluded.)
13
14
15
Sworn to and subscribed before me this _____day of

16
___________________1979.
17
18
Notary Public, State of Florida

at Large.
19
20
My commission expiresa
21
22
23
24
170
25
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Castillo & Castillo

-~ P;rgistqed 1'rofesslonai.'Reportm -
219 N.W. 12TH AVENUf; 0 MIAMI, FI..A, 33128
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TEL. ~24~3,.
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-= . . . ,
171
CERTIFICATE
STATE OF PLORIDAt
COUNTY
.?. '_,
---..,.
OF
DADE:
~~
ss.
RICHARD A. CASTILLO, Registered Professional
Reporter and Notary Public in and for the State of Florida at

7
Larqe, hereby certify that pursuant to Notice heretofore

8
filed in the above-styled cause there appeared before roe on

9
the 21st and 22nd days of March, 1979, at the time and place
10
aforesaid, SARKIS G. SOGHANALIAN, who was by me first duly

11
sworn to testify to the whole truth, and who thereupon testi12
fied as is hereinabove shown, that the above and foreqoinq

13
pages, numbered 1 to and including 170, were reduced to ~rit-
14
inq under my personal supervision.

15
I further certify that I am neither of counsel nor

16
related to nor employed by any of the parties to the action

17
for which this deposition is taken, nor financially inter18
ested in said cause.

19
IN WITNESS WHEREOF, I have hereunto affixed my hand

20
and official seal this 25th d~ay March, 1979.
/. .
21
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22
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23
24
Hy commisaion expires:
November 28, 1981.

25
Castillo & Castillo
-
R~istered
Professional Rtporters-
219 N.W. 12TH AVENUE MIAMI, FLA. 331:i8
TEL, 324-6311
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U~ITED ST~TES {!OVERNMENr
UNITED STATES DEPARTMENT OF JUSTICE.
Memorandum
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FEDERAL BUREAU OF lNVE~TIGAJ'ION.
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recording device on a telephone located
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IN TUECIRCUIT COURT OF THE

ELEVENTH JUDICIAL CIRCUI'I' IN
AND FOR DADE COUNTY,, FLORI~A
GENERAL JU-RISDICTION DIVISION
BOCA INVESTl1ENTS, _LTD.
etcetera.,
:
:
Plaintiff,
vs.
SARKIS. G. SOGUA_NALI~N,
etc , e t al ,
De_fendants.
- -----
'Case ~o. 78-14372 CA 08
.:
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- - - _, - - -x
One Bisca~ne Tower,

ktiami, Florida,
Tuesday, 10:30 a.m.,
September 11, 1979.
D E P 0 S I T
r o
of
JOHU 'E. RALPH
taken
OJ)
be})a1_f of the defendants
purs~ant to a Notice of Ta_king DE}positio.n

'
I
SUITt !!ZI, BISCAYNE BUILDING
BERT
FRIEDMAN
TOM
'LOMBARDI
DAlE GENDRON
;
--
~-
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It WEST I"I.AGL.lR, $TI'llT

MIAMI, I"I.ORIOA 3)130
Ttl..tPHON:
37t.et'78
OA\.C GtHORON
APPEARANCE;
ANDREWS & LUBBERS, by
DEAN ANDREWS, ESQ., of counsel,
and
BARANDES, RABBINO & ARNOLD, by
GERALD BARANDES, ESQ., of counsel,
Co-counsel for Plaintiff
.4
..
FRATES, FLOYD, PEARSON, STEWART,

RICHHAN & GREER, by
GERALD F. RICHMAN,. ESQ. 1 of counsel,
..
-.~-and
, PETER SCHLESINGER, ESQ.,

.,
9
10
Thereupon:
JOHN EDWARD RALPH
11
was called as a witness and, having been duly sworn, was

12
exa~ined
-.::::
and testified as follows:
13
DIRECT EXAMINATION
.14
BY
~1R.
RICHMAN:
15
Please state your full name, sir.
.!'-
John Edwar9, Ralph.
What is your present residence ad4ress?
25 Cheyne Place, London, SW34.
That is in the City of London?
It.is in the main
16
17
18
19
20
re~
of London, but it is not the
'21
City of London.
What is your business-address?
My business address is in Jersey, which is 54 Bath
What is Jersey?
..
OAU: G:NOIIION
r
(
'
---
'.
Jersey is a group of--one of the Channel Islands.
For the record and for those who may not be
familiar with that particular part of the world, ~hat are
.4
the Channel Islands?
Where are they located?
Ten miles off the coast of France, Northwest France.
Would you tell us your educational
Yes.
bac~ground.
I was educated in England--grammar school,
public schoo.l--then I served si_x years in the Royal Navy.

Q
Have you had any ormal college education or any
10
technical education, other than what you received in the
11
service?
12
13
Yes~-not
other than I received in the service.
The technical education I received was in the service.
14
What did you receive in the service?
15:
Marine engineering.
Of what does that
All engineering matters pertaining to marine units.
Specifically, does it have anything to do with
16
17
18
19
'
..
:
20
21
consi~t?
guns, with armaments or anything of that ~ind, or is it

primarily related to'ships and boats?
A
It is primarily related to engineering; r.~arine
engineering, pertaining to ships and boats, but during the
22
23
24
--
course of ones training there is periphery training which

covers all those r:'latters.
Q
What years were you in the Royal Navy?
25
..
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D-"U; GlNORON
For six years, Ul)til 6 2---19 6 2
Hh_a t !>osition did you hold or wbat rank?
-A
Sub-lieutenal')t
.,4
Did you go in wit})._tbat
'
ran~
as an officer or did
5 ' you acbieve tbat whi_le you 'wet"e in the_.Royal Navy?

6
I acbieved tbat wblle I was in tbe Royal Na~y.
'j
Mbat position did
An,Upper
Q
"
l~ h_a t
10
Tbat is a positiOJ') w}lich is desigl')ated for cor:ir:d_"s sio
11
':;.H
Yardmal')~
is th_a t -?
ran_king.
Q
Did you go _i_I)to the Navy rigbt out- of high school_?
13
Yes, t did.
.14
You were appro~_im-ately 18 _yea:::s old at t _he t _i _me?
15
Yes.
16
t do not wal')t to g o i _nto any ~ind_ of great detai_l
18
19
20
"21
~2-
2_
3
.. _
go in as?
12_
17
yo~
24
25
...
at a ll, but just genera 1_ly where you served \'1}).i_le .i_n the iJa~y
and wbat txpe of work you wer doing.
~efus stai't witb whet'
you ser-ved._
A
America,
"~st
tndies, Rome, Greece, Medittral')ean,
!:1 i d d 1 e -East ~
Q
Could you tell us what- type of. work_ you did whi_l _e
you were _in t _b e Navy?

A
Yes, the assur:iption_ of t"esponsibi_lity fo'r au~iliary
engineering units and maln - engineering ui)its
D"C..C: GCNDRON
'
5
1
--::::::.
3
4
mea~?
Well, one has to assume the responsibility for
those units during one's period of watchkeeping.

tihat type of work, physically,
there?
you actually do?
'~ere
you doing in
When you say you were in marine engineering, what did
. Assumed the responsibility for the auxiliary and
main engineering units from time to time, as my watchkeeping
'requi~ements were dictated to me.
10
In essence, you were working on engines?'
11
That's right.
12
I asked you specifically about guns and armaments
13
and matters of that nature.
,14
would you have had occasion to wo:k on any

, type of armaments,
15
as opposed to working on engines?
16
When and under what circumstances
During one's initial training.
I received instructi
17
in small arr::s, rna in armaments, as a matter o;, course', and
'
18
subsequently during Royal Harine Commando --training, 1 had more
19
active requirements to be familiarized with small arms.
2.0
21
22
23
. 24
......
25
'.
'
......
What does that
How were you involved in ,Royal Marine Commando
training?
A
I. didn't say Royal Harine Commando training--Royal
Naval Commando training.

Q
How were you involved in that? Did you go through
that course?
OAI.I: GtNDRON
6
1
3
4
5
Yes.
How'long does that take?
Approximately six months.
Other than what you have already told us, does that
fairly well sum up the type of things you did whlle in the
Navy for those six yea_rs?
A
9
10
. Yes.
You did not take any course or anything in design
of arm~rnents or purchase of armaments or anything of that type,

did you?
11
No.
12
~hat
13
.14
did you do after you got out of the Navy?
First of all, I prsurne you got an honorable dis-
charge or \<lhatever the British eauivalent

..
, is?
15
Yes.
16
Why did you leave the Navy?
17
By choice.
18
Had you gone in with the Lntentio~ of making it a
19
career and then changed your mind?
20
no.
21
When you left the Navy, what did you do?
22
Commercial banking.
23
How did you get into that?
24
By application.
25
What I mean is did you take any kind of course or
OAt.( CC:NORON
-=-="-'-'-=-'""----"---=-"-'---''-'----'=-
anything like this or go up and
work for a bank?
appl~
to a bank and go to
Yes.
Hhat bank?
United Dominion Trust.
What year was that?
1963.
would
you chronologically tell us what you did for
.,
that bank and any other banks for wbom you worked.
g~tting
10
interested in is
11
leading up to the events involved in this case.
What I am
your basic business background and
I completed the management training courses of
12
13
United Dominion Trust and actively worked for them in
14
regional anG branch offices in England.
15
16
17
18
19
20
21
22
23
24
..
.......
...,....
25
''
Up unti_l what period of time?
1966.
v~rious
t\fhat was the highest position you achieved with the
bank before leaving the bank?

A
Regional manager.
For what region?
oxfordshi_re.
ts that a township or how would you describe it?
It is a county.
Then what did you do?
Management consultancy.
O"U: G(NOI'ION
'
1
.:~.
4
5
7
8
9
t;;as that privately or with a company?
't~ith
lV'hat was the company?
Montague, Kent
What kind of company is that?
Management
consUltancy company
..
could you ex-plain or clarify _a little bit
a company.
&
Co., Limited.
r.~ore
of
what a management consultancy company is?
10
Could you
11'
Yes.
e~plain
that, please?
.The services of a manage_ment: col)sultancy
are used in companies wbich are having problems.

Q
So a company would get- i_nto trouble aod you come_
.14
in tbere and try to give advice as to hor to get out of
15
trouble, essentially?
16
Yes.
17
-How long did you stay wit.h tbat cor:tpany?'
18
Tbree years.
19
20
:I
21
Nhat was the name of that?
22
Nenbam,
23
Nhere was that located?
24
In Nestminter, London.
.2.5
Hm.,. large a company ,.1as that in .te.rms of number of
~~
-.;:
--- ........
Company doctors;
13
....
'12
..
for_med my mtn company.
~alph
& Partnes,
OA~[.
~imited.
G(NOAON
employees?
We employed approximately 35 consultants.
What year was that?
1969, '70,
Those were the four years the company existed?
Yes.
v7hat happened to the company i _n 1972?
shareholders.
10
Q
sold it?
'71,
'72.
disposed of the sha_res to another group of
11
In fact, I sold the company.
What was the status of the company at the time you

Was it an ongoing, successful company?
12
Ye_s.
13
Hhat did you do after selling out t _here?
.14
Nothing.
15
What was tbe nature of the company's business before
16
17
18
19
2_0
21
22
23
you sold out?

A
Ha_rket consul tancy.
The same ty-pe of work you had been doing previously?
Yes.
After you ~old out, you say you did nothing.
~ere
you living sort of in retirement on the income you had made

or \1hat?
A
Yes.
When did you go back into business again or get
24
25
~ -- -
involved in any other kind of business or investment after thalt
OAI,.C C[NOAON
10
1
sellout?
2
3
started to look at various opportunities in
197,3-'74.
Q
You were appr~ximately how old in 1974?
[No response.)
Five years younger than you are today, whatever that
So from the period of
10
"~
is.
~as
born in
1936~
~972
get involved in a business venture?

A
1974.
12
What company was that?
13
Boca Investments, Limited.
Who was involved in that business with
The directors of the company.
i~he_re
15
16
'
18
19
20
23
24
...rere you living at that tir.'le, say 1974?
9as there any reason you formed
'
compan~
outside
Yes.
It was an off-shore company.
What is the purpose or advantage or dis~dvantage of
having an off-shore
co~pany,
as opposed to having it incorpora
in London?
A
Taxation.
Before we get into questions relating specifically
25
~his
of London?
21
22
yo~?
London.
17
'
on, when did you next
11
,14
.~------'-0'---A-~C: G(NOROH
11_
1
:: {
to Boca_ Investments, Limited, are you involved 'i%) any ot_her
'
'
Investm~nts?
MR. ANDREWS:
Hben, as of today?
~fR.
Say from 1974 on.
RICHHAN:
Did you become_ involved in_ any other companies
'Q
besides Boca Investments, Limited, ai)_y other business_ ventures
or anything like that, other than :Boca Investments, Li_mited?
~o.
"e have been supplied witb regard to
'
~oca
lnvestment
10
Limited, pursuant- to our Request- for Production, t_hi_s document
11
~hich
12
deposition.
I would 11ke to have marked as
13
' ~~-
~oca
companies besides
'.
.14
D~fendants'
No. 1 to th1s
(Thereupon, the document referred to was MarY..sd

:as DeJel')dants' Exhibit- No. 1 for identi_fication.]
'
,.
15
~et m~
show you
b~fendal')ts'
E~hibit ~o.
and :ask
16
you i_f that- is a true and cor_rect copy of the egu:..vale%').t of
17
our Certificate of
Incorporation~
'.
18
]...
Yes.
19
Is Boca Investments, Li_mi ted, a corporat_ion,
in a sense, a vehicle th_at _is set out for the purposes of21
i'
}}!
...
..
establishing li_mited liability?
22
Yes._
23
Is this the entire docurnent of incorporation?
24
Yes.
25
Are there equivalent records, such as corporate
OALC GtNDAON
12
::~
minutes, that are kept in the normal course of business, arid
annual meetings and anything of that nature?
Due to the shortness of time, you were unable to get it or no
such records exist?
MR. ANDREWS:
11
HR. RICHMAN:
He requested
Let me just .inquire.
l'f'e did request those items.
either in your possession or
13
on behalf of the company?
~n
Do you have such items,
the possession of someone else
.14
I have them in my possession
15
Are thate then corporate mlnutes that are tept of
.,
annual meetings of the company?
17
I presune so, yes.
-;s
\\'here would those records be at this time?
19
Either with the directors or the accountant, pre-
20
21
23
24
25
...
sumably.
Q
Let us go through, then, step by step.

You incorporated the company.
22
..
We have no such records.
12
16
.:~:
.._::;:;
We have not been supplied with tha
he bring everything in his possession.'
10
... u
I believe we .had requested copies of the minutes
of the Board of Directors.
I presume so, yes.
How many directors
..
did you have when you incorporated what is designed as being

a limited liability company?
A
Well, I didn't incorporate the company.
The
13
--
...
accountant incorporated it, so I don't know what the director
status was.
......
you had of the company?
There were two directors.
Who were they?
Sir Claude and
Whq were
Residents in Jersey.
10
Does the law there require, to your knowledge, that
~ady
du eros.
the~?
11
a company incorporated there have to have some residents of
12
the particular area as di_rectors?
13
No.
.14
Hew did you ha.ppen to choose them, then, as director
15
16
17
'18
19
20
21
22
23
.f.,
Subsequent to that, do you know how many directors
24
...:;~1:
25
of the company?
A
They were chosen by the accountant.
Who were the accountants that set it up?.

Co. _. ~
Turquands, Barton, !:1ayhe\-l
Can we have for the reco=d their address, please.
54 Bath Street, st. Helier, Jersey.
That is the name that appears down here in the
&
lower left-hand corner?

A
That's right.
I take it that there the accountant can handle
an incorporation, as opposed to it having to be done by a
14
1
lawyer.
~--
3
4
5
6
....
.;
Do not presume.
[Continuing)
Answer what you know.
know that normally the incorporation
'
Do you happen to know who the lawyers wre in this
No,
10
Besides the two directors you mentioned, were there
case?
I
don't.
11
any other persons, besides yourself, involved in any kind of
12
an ownership position or an officer or managerial position
13
with the company when it was first incorporated?
.14
will get, into what happened afterwards: ,

A
18
~hen,
we
The O\-lnersbip of the shares was not held by the
directors of the company, as far as 1 am aware.
17
Q
as
So the two directors then bad no ownershi~ interest,
far as you know?
19
As far as l
20
Were there officers of the company: president,.
21
:.~.
MR. ANDREWS:
16
....
I presume tbeywork in conjunction with the lawyer.
lawyers.
15
'\
As far as you know, there is no requirement?
of a company is set up by the accountant, in conjunction with
am aware.
vice president or anything like that?
22
.A
23
You were not a director?
24
No
25
Was there any requirement of which you were
l~o,
just the di_rectors.
.::::.
'-;:;;.;'
..
OA\.C: (;tNORON
a~are
15
1
in 'the Jersey Islands that the directors be residents, so

that would have precluded you from becoming a di_rector?
4
5
No.
Do you have shares of stock
type that are issued?
ln
othe~
fo~
cornpan~
wordst bow is the
of this
own~rship
held in the company?

A
Tbrough sbares.
~ho o~ned
I_ don ' t
10
Could you clarify fo~ me what your inter~st ~as,
11
A
fo~
-I was the consultant- al')d cbief operat-ing officer
tbe company .
.14
Did you -have a written contract?

I
rs-
Yes.
16
~etween
17
The
l8
Who e8ecuted the contract
19
The directors.
20
Both directors?
21
Yes.
22
You actually have no knowledge, sitting here today,
23
25
wbom was tbat contract egecuted?
compan~ ~nd
myself.
as to who the shareholders of
24
..
kno~.
tben, in the company?
12
13
the shares of stock?
~he
Ol'l
company were
No.
~hey
are nominees.
~hat
do you mean by l')omil')ees?
011\.C: GtNORON
'
bebalf of the compa:rly?
o~
are?
16
~
.-;,:.:
are certain .things I am not- privy to in the company operation.
~m.not
a director.
.
'
Were you one of
t_]Je ones or were_ you the person
responsible for forming the company and starting the company
in 1974?
'"j
I advised on it.
Hh_om did you advise?
Sir Claude and Lady du eros.
10
Could you tell us just briefly how you happened to
11
get involved with these people in creating that company in
12
197 4?.
13
"I
There
'.
Well, the shares ar held by nominees.
Yes.
They asked rne wbetber tbey
15
Jersey company inter_natiol)alJy and I
16
advised t_]Jem so.
18
19
'
...
20
21
thought--~1hether
tbought there ,.,.ere_ various possibi_lities in trading the_
.14
17
thoug]Jt there_ \otere and
Can you tel_l us what- t_heir address' i_s?
]':.
No, I can t at the moment.
l don't Xno'.; t_beir
address.
Q
Do
yo~
hav~
any records back borne from which wa
could .establish that as to ,..-hat their address i_s?
22
23
24
--
'
25
If we wanted to reach tbem and
'tal~
to tbem, ho.,.,
would we be able to do so1

A
Well, I have no idea.
Presumably--- I don't kow.
'
..
'
OA~( COtNOAON
.17
1
I_ ,don_ t know.
2_
If~ ~ou
wanted to -t~l_k to them, how would you talk
'3
A_
5
requirer.~ent:
well, _I_ have_ no further
to talk .to them,
so I_ don't: have_ an~{ requirement~ to speak with~ ther.\.
l1!_len_ was the_ last ..t!rne. you had_ an)!' contact_ with
A_
i978._
~~
Q_
X:s the corn!'any- stiil_ in_ existence?
1Q
A_
Yes.
11
Do tou
them?
a
.,
kno~
who
i~
'
running the company
a~the
12_' ' P.res ent: time?

.....
13:
.14
Nho
15:
N_y br~tl)er: and hi_s_ (.,.if e.
16
m1at_ are their' names(
17
A_
:Peter Ralph and_ Uargaret_ RaJ?h .-
i~
that?
''
18
t~hen_ did they- beco:,e_ invoived i_n_ 'the comt'~ny?.
19
A.
!n_ 197 8 .
'20
.Hhat is Peter ,Raiph.- s background(
21 '
22_
~in.d of_ business was he: in before_ he b~ca_me involved i_n this
corni?any?
-li'e is an accountant.-
23
Q_
...
..
Basicaliy, what_
L--- ~-- --~- -- - - ------- .. - -
In_ .Austraiia.
18
Q
:::;
So they are running this Jersey Islands company .
from Australia?
3'
A.
They are directors of the company.
Did they replace the other two persons as directors?
Yes.
Do you know the circumstances of the other two
giving up their directorships and Peter Ralph and his wife
coming in to take it over?
No, not strictly speaking, no.
10
Do you know whether the other two directors
11
12
voluntarily resigned or gave up whatever interest they had

in the cornpan_y?
13
.14
15'
16
17
18
Yes.
Do you
No.
I am lost on one point.
shares.
They sold the shares.

k~ow
to whom they sold the shares?
I have no idea.
You said they sold the
I thought you indicated you did not know who owned
the shares.
19
They held the sha_res in noninees names.
Heaning they held then for the benefit of somebody
That's right.
You have no idea who those other persons
No, I don't.
And in no way did you have any interest in.those
20
21
else?
22
~ere?
23
....
24
~
...._~-;:.:;"j
25
'
OAl.[ G(NOAON
--
19
shares?
No.
Is the company itself present_ly an operating company
Yes.
Do you have any connection with the company at the
6
7
10
11
~:;:~.
present- time?
Yes.
I am the chif operating officer.

..
. Go~ng back to the contract you entered into in
1974 1 what was the basis of your
co~pensationunder
that
contract?
A
Each project t _h at I worked on on behalf of .the
12
company was taken on its metits and a commission or fee was
13
paid to me on the conclusion of each contract.
14
15"
'16
17
18
19
20
21
22
23
24
1<! . . . .
25
How was it
decide~
withregard to each matter as
to how you would be compensated?
There was a mutual agreement between the directors
and nyself.
0
agre~ment
Befora or after?
In other wordsr was the mutual
at the time the project was
underta~en
or was the
compensation determined once the project was concluded?
The fee was after it was completed and then it
was decided at that ti_m e.

Q
How were the di_rectors compensa:ted with regard to
what it was that you were doing?
I have no idea.
OA\.C: GtNOFION
1
,,._...
.........
in negotiating for each one of the projects these two
individuals?
Yes.
Were there any other employees of the company?
7'
directors left-_;'what other kinds of employees did the cornpa:r1y

ever have?
A
Consultant.
12
Let us see i_f we ca:r1 ta}::e it- step by step.
13
Did the cor:ipany maintain a formal office ,mea_t)i_:rlg
14
did it have a pa_rticular place out of which it operated at
15
all ti_rnes?
19
20
21
22
23
..
24
::::.
2_5
,.
It had its registered offices in Jersey.

~ias
'Q
that registe_r_ed office li_~e .a lettex;- box, a
mai_l-drop kind of thing?

tbere
~nd
Was it actually~ an office that was
kept staffed?
I~
Was it the same accountant that did the
was an
~ccountant's
-'l
office.
it)corporation?
A
Yes.
l-Jas there a separate area set aside in that: of"fice
for your company, a desk and chair and places like that or :rlOli
OA~t:
__,,
say, 1978, when tbose two
11
18
Other than the two directors aX1d yoursel_f and
~erbaps ~ se9retary--up until,
17
'
think from ti_me to time, yes.
16
"ere ~he only persons with whom yo~ were dealing .
10
::.,~.
20
GtNOAOH
21
1
::S:"?::.
3
4
In other words, from time to ti_rne they would make
a desk\or an office within thelr offices available to you and

at other times there was no office thare?
5
6
"7
8
9
~s
Yes.
when you had
ernploy~es
of the
to the best of, your recollection--!
could you tel
co~pany,
u~derstand
you do not
have any records here in front of you--who the employees we_re,

oth~r
than somebody who did nothjng other than perhaps
10
secretarial work?
11
self and t _h e two di_rectors, did that company have from the
12
time it was lncorporated, say, through and
13
present t _i _m e?
~hat other actual ern~loyees,
be~ides your-
i~cluding
14
To my knoh'ledge, it hact a Hr. IRobert .Burr.
15'
Anyone else?
16
Mr. Michael Ballantyne.
17
hnyone else?
18
Not t~ my knowledge.
19
Tell me about Mr. Robert Burr.
20
Occasionally, as the requirement was.
~~
.....
~here
tbe
can Mr. Burr
be located at the present time?
21
In High Nyconbe.
22
Do you have an address for him?
23
I can't recall that address, but I do have an
24
:;;:;;;,;
25
address.
Q
You can obtain it for us, but you do not recall it
OA~C
CtNOAON
22
1
right now?
If you requlre it,
3
4
5
6
7
8
9
10
11
12
13
14
15
16
.,
..:::
--
~es.
ls his background or profession?
~hat
He has a service background, Royal Air Force.
What rank?
I~don't
Do you know whether he was an officer or en_l isted man?
Hewas an officer.
How old a man is he, approxlmately?
Thirty- four, approx i _ma tely.
~hat
He went to Antwerp.
know.
type of work did he do for the company and
when?
He went to Wash1I).gton, on my
instruct_ions.
Q
Could you tel_l us approxiMately \.,hen he was
e_~ploy~d
by the company?
17
November, 1977.
18
Prior to the time he was employed tn Nov~mber of
19
1977 ai).d prior to the time he had been i _n the .Royal Ai.r Force,
20
do you know what kind of work he had done?
21
Yes.
22
Doing . what, sir?
23
International trading.
24
could you be
25
No.
He had worked for a trading company in London,
an~r-lnore
specific: than. .th~it?t .-
I can give the name of the company.
OALt GI:HCRON
The name .i
23
----
~.
Rally Trading and it is a subsidiary of the Bowater Group in
London.
3
4
How did you have occasion to retain his services
10
11
12
13
~iscussed
the possibility of work with the company
and he agreed to accept the temporary consultancy position.

Q
When you say he was a temporary consultant, what
~pecifically
was he hired to do for your company?
To come to Antwerp and advise on matters relating
to documentary credits.
l~hen
15
1.97 6.
16
~hen
Rally Trading in London.
~Zhen
19
20
21
22
23
_..
18
for your company in November of 1977?
14
17
......
company and the Air Force, to your knowledge?
Had he worked for anybody else other than that
'~
. . Q
24
25
did you first meet hin?
and where?
you say he was hired to a dvise regarding
docunel)tary matters, was that specifically with .regard to

the transaction involved in this case or ,.,ere there other
matters involved?
A
In this instant matter.
How long did he remain with your company?
He again went to Washington for me in December,
1977, on this instant matter
OAI.C Cli:NORON
-~~
~~hat
.A
~~ell,
his
4
5
-7
he did his job and, we .had. no further use for

.
at- that ti_me.
After be completed the trip to Washington.

Do you
knm~
when that trip was completed,
approxi_ma tely?
A
I think it was completed in December, on or about
the 4th of December.
11
12
13
that_ trip to i.Yashington?
December?
A
10
aJte~
l.Yhen did that 'conclude, approximately by the end of
Q_
..
'
se~vices
-~
.happened
24
So you paid birn and that w-as basically the_.end?.
Yes.
matte~
14
And then be worked again on this instant
jn Portugal.
wor~
Wben did he
on th_is matter agai_n?
]).
ije ca_me to Portugal wit_b ne on two occasions.
Can you tell .us when t_hat was?
A_
bpproximatel_y February, January, Februa_x:y,
Were .both occasions in January or Februa;ry, 1_978,
15
16
17
18
19
or was i t anotber one at another time?

~
2Q
21
'78.
.There were two sep.at:ate occasions in wbicro be
came to Portugal and they w~re both on or about January,
22
Q
AJter those two trips to Portugal, were there
23
an~
I
...
.,..;z.:
24
25
roore trips?
A
No.
25
1
..
2
3
...
Were both of those trips wit~ 900 or were they on
b.is own?
A
-I a_rn not quite sore, _but- I recall tbat- we
i~ ~ortug~l together.
might })aVe been_ separ-ately.
we~e_
both
ih~ actual traVel to and from Portugal
Hith regard to ~r. Burr, was that the ei)d of his.
-7
servic e_s_ per.maneiJ,tly for the CO!l'pany, after tba t - secoi)d tr it>
to Portugal
with tl)e cornpan_y ?
~ith_
you, or did l)e_ have a _n yt_hing fur.ther t .o do
10
We ha~ on~ o~ two meeting i~tondo%1.~
11'
't~hen
12_
-In 1978 and -I cannot _t:ecal_l t _be dates.
13
l=:as anyone p:z:oesent at t _h ose rneetiiJ,gs, _b esides . tbe
14
t ....:o of you?
15
No.
16
\~})at_
17
Discussion~
Did l:1r ._ Burr h_a ve an_y kind of
wer.e t _h ose meetings?
was the pu_i:'pose of the meetings?

about otber p:z:oojec~s not ~e~ated ~o
18
19
20
21
22
23
.. .
I
24
\, .:....":;.:
25
, expe~i_ence
at all
in the s ervice relatfng to weapoi)s or a _rms of wbich you J<"now?

~
To my knowledge, yes.
~xperience?
Hhat t _ype of_
I caiJ,_' t be precise aboUt that
Can you be general about it?
Well, ] understand tb~t he had a knowledge o(
OAI._t GtNORON
J ~ .J
.....;.
...
- - .
1 '
"
-~
= -- '
'
-1
....
~ question,
_I'm a fraid.
26
...
weaponry.
Q
to,airplanes or what?
A
Weaponry in general, I think.
s-
How about
When did he become
The beginning of 1978, the end of 1977--December,
Tell us briefly his background prior to becoming
1977.
associated with your company.

A
11
12
Ballantyne?
10
~r.
associated with your company?
-7
Weaponry in general or weaponry related specifically
He worked for the--- He was with the Army and also
with the .Royal Ai_r Force.
13
He was with both tbe Army and t _be Air Force?
14
Yes.
15
In ,,ha t capacity?
;..
He ,.;ras with the intelligence services.
During ,..lbat period of
-I
Do you know whether he was an officer or enlisted
16
17
18
19
20
ti_~e?
can't tell you.
r.~an?
'21
22
23
~!.
.....":...
24
25
He Has an officer.
Do you know what rank?
No.
Do you know anything else about hi_s background,
other than that?
OAI.C: GCNORON
27
He subsequently worked with the foreign office.
I~
During
wbat cat>acity?
know.
do~'t
'~hat
' '
period of_ ti_rne did he work for the
foreign of_fice?
~
) don't know.
Ho~
four
H~.
did
~ou
used to
'happen to meet Mr.

~ork.
Bl~antyne?
with me before.
When and where?
,._
Ill 1971.
Q_
How did you happen to work wi t .b h_i _m i _n 1971?
He made appl_ica t _iol)_ to the co::tipany.
Tbat company would have been__your prior company?
Yes.
What did he do for your prior company?
~d_min_i_stt"a tion.
~hi_s
Yes.
Let .me go back again to
~eat'S
is \1hen you had '30 or 35 e_rnployees'?
th~
prior
co~pany,
tbe
Ot" so you had t _bat prior cor:ip,a ny .

Did anything that that cornpa:1.y did in its rnanage_men
consul ti_ng set"v ices h_a ve a_nything .. a t al_l to do. with weapons
L' . , .~_: '_
~-~~' ' '
-'
;..
No.
Had Mr. Balla_nt_yne_ had a lot of adrnin'istrative
.n ,~,.~ - "";'''""..;:. .. "' '' 1 ~' - n;
- "~!.,.. ' '
t~-- :' _
O"I.C GC:NORON
:
.,-1
28_
1
..
ex:>erience so that you woul'd_ hire hira i _J). t _bat capacity?
Yes._
Was anythiJ).g your company did involved in any wa_y
in intelligence or intell_igence .services .or a nythi%19 l _i _k e tbat.
No.
l~as the management ser~vices of_ you%' company simi_lai'
'7
to the
10
at tbe ti_me
11
12
13
14
. of_ company
~i_nd
wit_b which you had worked before?
'Yes.
Was 1:1:-. Ballantyne_ stil_l wit_b_ your prior comi>a_J).y
~you
hired .h_i _m in_ 1_977?
;..
No.
_Do you know
appro~imately
"'be J).
16
b~
h_a d le_ft t _he
prior company?
;..
Appro~i_ma tely
Do you :know "'bat_ he ~id iJ). t _be i _nte:t:im, between
1_97 2.
I
15
tl1,el) a::1d 1977?

;;..
~~Y understa%"1aing i _s it_ \.,.as :Eurtber admin_i_strat_ion_
Eor go~e~nme%"1tS or for private companies?
For
Leadi_ng up to _1 977, t _hen, '1.-:by did you hire him
f7
18
'
19
pri~ate
cor:\paJ).ies.
2_
Q
21
at that
t_ ir:~e?
22_
;..
Because "I had_ t _b e. requirement for _a n adrnini_st_r:ator.
'To do
;..
General administ_ration
23
--
~bat,
speciJically?
24
II-
\-lOr~.
25:
..
__ OA\.C: GC,..DROH
r~
- ------------------------------------------~
29
.......
Can iou be ~ore specific?
Khy was it that yofir
co:::\pany, Boca -Investments, at that tine

needed
an administrato 7
'
-
instant rnatter.
Do you mean matters other than the instant matter?
No, the instant
It was taking up a lot of your time?
Yes.
~nd you needed help and assistance on it?
10
I needed to delegate certain work that- I normally
12
m~tter.
woulc have done myself.
Let me go back for a moment.
men~ioned the napes
13
of er:'.?loyees and people, other than secretaries.
14
a~y full-time secretaries for the conpany or did you use
1S
--the secreta_rial services of t _he acco~:nti_ng firm?
Did you hav
16
I had a fu11-time secr~tary.
17
Dul."ing Nhat period of time?
18
l 9 7 5 ; 1 9 7 6 , . 19 7 7 , 1 9 7 8 and 1_9 7 9.
19
~~as that the same person or a va_riety of persons?
20
A va_r iety of persons.
21
was there one person who was there particularly,
22
say, in mi'd-1976 until the end of 1977 or pri_r narily du_ring
23
that time?
24
I happened to be rather busy ' on other matters, the
11
...
No.
No, I don't t _hink so, no pri_rnary person.
How about 1978?
1 U.oe ,
25
Was it a variety of - people, as
. 30
1
~~~
A_
Variety of p_eople .
"o~ld
4'
people were?
5"
A_
No.
Yo~
your c~rnpany ~ecords indicate who those
do not have paj'roll records. or anything l'iJce
that that' wo~la show that?.
8'
10
Th~re ~s.n6 .payroll~
were:~~ople
'How
paid who worked al
On .a. fee .basis.
12
In cash, in other \lords?
..,;,. "13
Yes._
14
Ther~
'16
17
18
'19
20
21
22
23i
~:;::
24
>.;::::i:;
'25
~ull-time
secretaries?
11
15
\,
opposed to one. __person?
i_s nothing 'like social security or income. tax.
witbboldlng or anyth,ing like t_bat?

A
f~o.
So you; simply paid the. enplo_yees who
secretarie~
as.
dash?
~
On
-All the records .of: the
in. tbe
fee basis,
~e.
are. -kept-
'\-:or)~ed
acco~nting
cornp~ny
offfce.
that are 1n e>:i.stence
Is that correct?
A.
'.{es
.Hfth. regard to Mr. Ballantyne, 'could you tell us
specificall~
how long he stayed with your comp_any?
Approximately two years.
31
......
Is he still with the company at the present
He is available to do work for the company if l
need him, yes.
On what basis does he work for the company?
On the same basis.
Cash fee basis?
On a fee basis, on a free-lance basis.
Is he work_ing for other companies at the present tim ;
I have no idea.
10
Do you
11
12
...
time~
13
14
15
16
17
18
19
20
~now
his address or where he can
~e
reached?
think we can get that for you, if necessary, yes.
But I con' t have a record of it at t _he r.:oment.

Q
Is he just generally i _n London or living in
th~
Jersey Islands?
Well, I think he is living in the United Kingdom,
yes, not in London, not in the Jersey

Q
ls~ands.
Do those two individual_s, Robert Burr an;d Hicha2l
Ballantyne, pre.tty well cover it, the%), for: employees of the

company, other than secreta_ries?
Yes.
What did Mr. Ball~ntyne do with respect to the
21
instant transaction, the one that is the subject of this case?
22
.23
I
.::~
Maintain records
Did he do anything else, other than maintaining
24
'!;::;;;;
25
records?
OAI.C: (;C:NOAON
32
....-
--
Monitored telephone calls.
What do you mean by monitored"?
Well, listened to the telephone calls.
Do you mean he handled the telephone calls or when
the calls came in he would listen on another line?
He would listen on another extension.
Has that with the knowledge of the party he was
calling?
on the line, also, listening?
Nas the party calling told that Mr. Ballantyne was
10
I don't know.
11
Did he make notes of the telephone convers~tions?
12
If they were inportant, I t_hink be did, yes.
13
Do you know where those notes of the telephone..
14
16
conversations are kept?

A
No. Ne didn't retain the_n.
Do you know when the notes were destroyed?

t-:~11,
17
18
just the end of every day after discussions
it would be--- .
Q
So to the best of your knowledge, none of the notes
19
20
21
22
23
24
;:;;;::
25
of any telephone conversations were ever typed up and retaine ?

A
No.
You did not have any kind of me_rno::andurn to the file
or anything relating to a transaction?

A
No.
Other than monitoring telephone conversations and
DAI.t GtNDRON
33
1
......_..
~
2_
Mr. Ballantyne do for the_ company?
Well, whatever I w-as able to delegate to him .
Can xou. give us some_ e)(arnples of the. types of thing
he did?
He would go to
Anything else?
H-e. would have discussio%1S wit_h various people in_
my absence.
10
11
::;~:.
rnaki_ng notes of some teleJ>hone conversations, what else did
me~tings
What kind of people?
with_ the various embassies.
Hould it have been
an~body
with "-'hom the company \'las dealing?-
12
Yes.
13
-Did he deai. with anyone relati%1g to tbe trai)saction
14
'15-
that _is the subject of this ca_se?

A
lf
\las absent, he "-'Ould take -I"le_ssages and
~ake
16
a l)Ote Of the_rn al)d paSS. t_hem tO :r:'\e 1 bUt nO 1 he didn It- })aVe
17
a:n.y dealings.
.....
18
19
dealin9s with anyone involved in th_is transaction?
22
23
(
..
......._..
-
24
25
No.
20
21
So as far as you know, he had ooface-to-face
~;lith
regard to l-lr. Ballantyne, you said be "tas
involved 1n administrative matters relat1ng to this case.

a_n trying .tO pin
,dOW!)
a litt_le more,. if We_ can.
Other than him taking messages and dealing \'lith_

some J>eople at embassies that you nentJoned, can you think of
OA\.C: GC:NORON
r-
34
'1
..;-;;~
al)ytbing. else at all th_a t he did?
~ell,
The company bad no employees?
No.
What
He would read_ f.iles up and. bring hi_mself up-to-date
~ind
genera~
administration
wor~.
of admi_n_i _stration 'w ork wa s he_ doing?
on varioUs matters whicb were being handled by
at the time.-
10
.Mhat otber
~1-~.
i:rnrrfa t _er_ial._
13
15
16
office
tbe offica bandling, besides
A_N DREl;fs: Objection.
12
14
matte~s ~as
tb~
tbe instant case?
11
...
just
tt ._i s i _rrel_evant and
Besides tbe :rnatte_rs involved in_ t _hi_s case, wbat
othe~ ~inds
of
bUsin~ss
was
th~ co~pany do~og?

.,_
!).
oefe_nse rn_a teri_a l_ supply.
-In
A.
Yes. .
-Bes_ides t _b e tra_nsaction i _nvolved in t _his case,
ot~er:
<lords, t _h at ,.:as tb.e
~.,a in
nature of the
17
18:
19
20
21
.had you_r cor.1pany been' involved in the supply of a ny kind of

defen_s e rnate_rials, as you ca_l l tbern?
-I am i _ncluding in that offensive or de_fensive
22_
23
.-..-,;:::-~
24
25:
weapons, encompassing anything relating to
a~ms
and weaponry
to any countries, otber tha_n Hauri'tania

A
Yes.
~ ~--~~~~~--~~
~-~--~~-~-~
--~
- ~
--~~~~----------~--0-AL_[_G_t_ND_R_O_N------------~------------------~
35
1
~--
Had it supplied on any previous occasion any
defensematerials to the Country of Mauritania?~
Yes~
In what year did it first start supplying defense
materials?
1975.
Besides the supply of defense materials to whatever
countries or entities to which it supplied such materials,
did the company have any other business?
10
Yes.
11
In what other kind of business did the company
12
.....
engage?
13
Connodity supplies.
14
What types of commodities?
15
Fertilizers.
Anything else?
1;.
Cer.'Lent.
Can you give us an example of wh~re it obtained it
16
17
18
19
and where it sold it?

HR. ANDREt1S:
20
21
22
23
think he said it was _prinarily engaged in the sale of
defense materials, but'also engaged in the sale of other

commodities.
MR. RICHMAN:
....
I am going to object to that, too.
Are you instructing him not to answer
24
:;f/iE.
I am trying to get a background to determine whetber
25
l'
OAl.[ GtNOIIION
-----'-----
36
....:.::.
this is essentially, frankly, a shell corporation or .
involved' in substantial other business.
any other way to do it.
~now
MR. ANDREWS: Ask him if he is involved in
4
5
I do not
substantial other business.

~HE
WITNESS:
It is involved in substantial other
business.
What types of substantial other business?
Commodity supplies.
10
Of the overall nature of the pusiness of the
11
company in the year 1975, what percentage of the company's
12
business \\as related to defense materials and \-!bat percentage

'
...
13
14
15
16
17
18
19
20
21
\:as related to fertil_izers and cement?

A
Eighty percent to ,defense: materials' and twenty:.percent
to cor.imodities.
Q
Were these commodity kind of sales primarily
between nations, international .kind of transactiol)S, or were

they local
A
tra~sactions?
could you be more precise about the terminology
"local transactions"?
Q
Nithin the United' Kingdom.
~~o.
They were sales of matters outside the United
22
23
:Kingdom?
.....
J'~=f~t~:
24
25
Yes.
OAI.C: CC:NDRON
37'
'
tet us go backto defense
'
materiats~
Prior: to the_ time you got involved in_ this. cor.tpan:t,

'3
.'
' had you evex:: been_ involved in anything 'relat!n9. to
bu-~ing.
selling o( what ~ou ref~x::~td. as de!~rtsa matetial~ pri6r to
1Q74?
1>.,_
0.
t6
or
No, no._
.How did_ you have occasion through this
ge~ invol~ed i~
compan~r
that kind o( business?'
9
10
Q_
How did_ the_ chance_ .come u:I>?
lt
1>..
Somebody -asked_ pe_. i_f: I ca_n. su_pply it.
12
Q_
.t)nd_. 'you,- in.. effect,_ became a: broker? wouid. that-
1~
14
b~
a :fair
1>..
stat~ment
or
~hat
would you
c~i1
it?
Yes . . .t thi_nk that: iS:-a_ !'ai::::: statenent.:

I
l;;ras 'this: eighty percent tigux::e. you gave. us_
15"
16
.i975 tr:ue in ~1_976, 197-7 and
1:978?
-.
17
18
.19
20
2_1
Were .the I>ax::ties
'\
\:.~~
'25'
Qer~ dealin~ i~
the
were~
they
primarily- ge>vernnents?
A~
Both.
~his
Areasonable
0.
ijo\;;- long
involved
doe~
a_ great deaf_ of t_ravei. on_ your part?amoun~
of
travel~d
it: take to get: from London. to the_
24
you
tex::tilizer and -cement: business private companies or
22.
23
wit~ who~
J~rsey
islandS: wbere your office.
wa~?
~-
~ - -
Do ox:: to door?
);' es ._
'I'hree, foux:: bours.
Did
.YOU
38
spe11d 'most of youx:: time rel_a t'ing to the
company opera~ing a~ ~ondon or operating out of th~ ~ersey
Islands?
l operated out of London.

~at-_b
regard to the de_fense materia_ls, that aspect
of the business of the company whicb .You - say comprised ei~ht9
10
percent of the company s business, is tJ~e compan_y ,still_
11
'i _nvolved in_ tbat business/ at t _be presei)t time?
12
Defense
13
Yes.
14
." fes.
Qere Jou involved i%1 both buy~ng and selling?
mat~rials?
15
16
17
18
19
20
2_1
~ben
l say you, l
~-
Yes.
Did _you
.........
24
'1;:;:::-
2_5
wor~
.the company.
direct_ly wit_b y ou_r'gove_rnment ox:: were
you just si_mpl_y operati_ng as a

~
~et
nev~x::
_bro~er-?
have worJ.>ed witb tbe :Briti_sb G-o vernmei)t.
us go back to Mauritania,
specific~lly.
'l::hen was tbe f i _x::st ti_rne ,_you had any deal_il19S with
22
23
~eai)
tbe Gove_r'nmei)t of z.sauritania?

raferring to you or your
A
Again, wben I -say you, I am
compa%1Y~
1976, early 1976.
DAI.C GtNOAON
39
1
. <l n
I t 'I
Let us talk specifically now about Mauritania.

How did you become involved in doing anything with
to that country?
re~ard
I was introduced to them.
By wham?
Is Captain Stevens with the British Government?
Yes.
What government?
10
No government.
11
You called him a Group
12
I presume he w9rked for some
13
C~ptain.
govern~ent.
retired, but he reserves his title, as he is entitled to do.
14
From what service is he retired?
15
Royal Air Force.
Khat were the
16
17
18
19
20
21
22
He is
c~rcumstances
of
yo~r
neeting or
knowing Mr. Stevens?

A
I \-las . introduced to Hr. Stevens . . by a company in
London.
Q
iihat was
ur.
Stevens, in his reti_rernent, or captain
Stevens doing at that ti_me?

A
I think he was representing Rolls Royce in Paris.
How did he have occasion to introduce yo~ to anyone
23
.~:;!
.......
24
from the l1auritanian Government?

A
25
He knew officials in the nauritanian Enbassy in
40
1
-.........
2
3
4
5
6
1'
8
'10'
11
12
"'
13
14
15
Paris.
Q
Whom did you meet from tbe
With Mr. Stevens.
With anyone else?
B.A. Ahmed
To the extent
O~ld
Ma~ritanian
Goqernment?
Ghanahalla.
th~t JO~
can,
pl~ase
~pell
that for
the court r"eporter.

A
G-a-n-a-1-l-a-h, o-u-1-d'
a-1-1-a-h.
A-l-1-a--I 1 m sorry--
That is the best of my recollection,
b~t
it can
be conf irrne.d in tbe .diploma tic 1 ist.

Q
DO you know wbere ..PaPE.:-rn~.[ny is today?
k1auritania, I understand,
Do
yo~
know '\lhat position he holds \V'_i t}) the
,government?
No.
~1hen "t>~'as
t_he last ti.rne you eve.:: had any contact
16
with him?
17
m:t~.ai;;~;r;~:J
18
Let us go back and stay in 1976 .for the r..onent.
19
.I ,.,ould
li~e. yo~
20
involved in any
21
22
23
24
...~,;;;::
25
to Just tell us step by step how you. got

~ind
of a contract relationship to supply ai:ms
to Nauritania in tbe year 1.97 6.

A
'-~'aS
~1ichaeJ.
asked by llr.
Stevens to obtain certai:r:
eq~ipment.
What specific
From the poi_nt of
eq~ipment?
~w
r_
BUtT
of the government,
TON
f'.Rit~H'IAN ~ ~()loCBAROI
01<\.t GtNORON
41
-~
confidentiality of Mauritania, I don't think I would like
to answer that without their permission.
confidential point of view.
important that
had.
...
on the other hand, I think it is
establish what kind of dealings, if any, you
I need to know whether this transaction was
~arge
in comparison to what you were doing before with Mauritania,
10
whether .it was small compared to what you "''ere doing, because
11
we have a major claim in here that this has adversely affectee
12
your business dealings with the Government of Mauritania.
13
14
15
16
Would _you like to know the monetary side of 1that,
particularly?
Q
The rnoneta_ry sice, the geno_ral nature of what it
"''as and when.
17
Approximately one and a half million dollars.
18
v;hat type of things were they, if you can just tel_l
19
..
practical problem.
I understand it may be awkward for you from a
~ecord ~
Let me state on the
us generally.
20
I am not trying to be--- Could I speak to my lawyer?
21
Would it be fair to characterize these as defense
22
materials?-
23
24
-..;;;;:~
25
These were defense materials.

MR. ANDREWS:
He all respect the confidentiality,
just as I did in examining your client, but I think you
r__.ll--f
B[I'~T
J'RI(OI>IAN
u
~
TOM
1.01>48AROI
OAI.C: GtNDROH
42
............ff
~
are entitled in general terms to follow the business
relationship as it developed here.
accurate in saying it is a major part of the claim
asserted.
...
Without getting into specifics of what precisely
is being furnished to the country, I think you can inqui e
within those parameters.
HR. RICHMAN:
MR.
~NDREHS:
Let us go backwards.
Other than the instant matter of what
'
10
we have identijied here as to what was to have been
11
furnished to them.
13
Let us see whether we can go on.

Q
Going backwards, in point of time, your company
14
began in 1974.
15
the selling of defense matetials to any country?
\'hen was the first ti_me it got involvee in
16
In 1976.
17
What did it do, generally, in 1975?
Negotiations.
Relating to defense
Yes.
or
Yes, relating to defense materials.
So the whole year of 197 5 was b'asically spent
18
'
19
20
21
22
23
24
. ;.;::;;
You are quite
12
-
25
mate~ials?
..
other matters?
negotiating, as opposed to actually consummating any sales?
Yes.
OA~C_
GtNOAON
43
1
~-~
:~
Di4
~6U &av~
othe~
-an2
busines~ o~ ~hi~~
kind o(
2_;
you ~ere working~ besides tb~ negotiations in .1~75, relatin~
to. defense_. materials?
occupation~
5--
-~ecause I
negotiations on the otnex::s

-o~
~as
too' busy negotiating
the defense mate:r;ials matters

Q_
.Ho.w in_ 197 s did you 9et- 'lnvoived in_ the. negotiating
at: all,- relating to
10
11
There we:r;' othet' negotiatio~s, ~ut 1 didn't begin
a
9
was this_ I>r.irnaril;t 2ou:r; rnajox::
def"ense-materi_als~
if
Orotip Cai>tain:Stevens asked me
hirn on the suppl!ing of
t could
assis~
defensa.materials~
12
....:.
13
he_ invoi_ved
14
15-
2A
t> ......
~ ~-
de_f ense_. rna ter i~is~
X u~derstand -he was representin9 noil~ ~o~c~ i~
_{s
- -
1Q
17
commiss_ion_ tor his frivoi_vernents :in these
18'
the. gove_rnments_ involved?
i9
t &av no idea(
20
You do
,21
A_
No iaea at: ali.
22
Q_
Hhe~e.. is
.-::!!f
~.-
24
'
no~'have
ho~
any idea
.Q
tou would
'
hav~_no
transac~ions
---
--
to~ay? ~
jdea how to get in touch with
25:
frez:."'ti
wa~ comi>ensated~-
he
GroUp Captain_ Stevens
l don't 'know
23
\
j~n_
.him i( you wanted_ to _get in_ touch
~ith_ him~
OA\.C CCNDRON
u:~
44
If I wanted to get in touch with bim,
I_
would
tel epho1'le the last numbet: I had .for him in Pari's.
You have a number someplace in :yout: records?
thin~
I have retai1'led. it in some way, a 1'lOte of
it, yes, but---
When was the last- time you bad_ any contact with him.
-~
I~
Can you tell us the circumstances of tbat contact?
~ust
11
Telephone conversation.
'12
\vas be di_rectly involved in any of the tral)sactions
the middle of 1977.
genet:al diseussions on defense materials.
10
...
13
14
15.
16
17
18
19
relati::lg to the liauritanian Government?
i"es.
ln what
He "fas a negotiator.
0~
Tbat is a
behalf of wbom?
don't k~ow who he was negotiating on b~balf of.
~ittl~ perple~il)g
to me.
Did be appear to 'be representing the Nauritanian
20
21
c~pacity?
Go~~rl)ment~
Uauritanian officials or what?
i\lel_l, in hi_s l)egotiations
~~ith
tl)e Mauritan_ian
22
B_rnbassy, })is position, I_ understand, was
~one
of sole interest.
23
_I don t- think he was _retai'ned by the Uaur i tanians to l)egotiat
24
Q
0.:::;:
25
And you have no idea how or by whom he was being
45
1
compensated?
No.
t'las he putting in a substantial amount- of time on
...
..
these transactions?
He appeared to be, yes.
Was he attempting .to obtain a better price for
the Mauritanian Government or a better price for you or what?
10
don'f ~now.
What role did he play in the negotiations?
What ,.,as it, specifically, that he was doing?

A
11
He was talking to rne .fron time to tir:\e about various
12
defense naterial requirements, not only for Mauritania, but fo
13
other countries.
Can you tell us any of
14
~he
other countries that
were involved?
15'
HR. ANDREt;1S:
16
I object to that.
I think that is
i_r.u:1aterial so .far as he was negotiating .or 'bad
17
~no,.,.ledge
18
'
19
of other
22
23
....
24
-.;;:~:ft
25
needs and having talked to llr.
~alph
about it, but confine it to Mauritania.

HR. RICHHAN':
20
21
countrie~'
here.
.I am walking on a delicate tightrope
I think understandably.
I am trying not to be
too broad on this thing, yet at the same tim~ I have to
protect my client's interests i_n terms of a clair.'l that

there was a business relationship that was hurt.
l
I think
have to establish that this was a viable, on-going
OAI.C GCNOAON
j '"'
t' ~~
. .......
e
--;~_:
I..~
company t _hat had
to go i _nto this matter.
i~
why I am tr-ying
confidentiality, but I tbink certain things I do have to
get out.
1\
12
_D id you deal witl\ otber cou:nt_rfes and consummate
transaction~
11
1976?
with otber
co.ul')trie~
Wb_a t size contr<:lcts, besides

You said you had none in
;...
;..
Yes, I think we did.
15
~;~e_re
1Q
govern:r.'lent?
17
1:.
18
23
24
25
------ ---
i~o
ma~e
a profit on ali tbe t _r a_nsac tiol)s?
14
22
say in_.
How about in 1976?
to ol)e and a _ bal_f, t\10 mi_ll iol) dol_lars ._

Did you
21
r975~
~1au_ritania,
Hell, they varied in s_i _ze 'f rom a half r:dllion dolla_r
_20
relating to m-aterials?
Yes.
13
19
That
_I_ a_m not- trying to I>ut you i _n a _n_ aw~ward spot on
10
/j?
clients.
. ...
othe~
46
al:l the tral)sactions fron gov e r_n_:::\ent to
Did _you })ave any _e':C-pertise -a t :a_1l: with reg-ard to
the types of ueapons you
w~re
selling?
;...
~I was farnir'iar 'Hith ther:l, yes.
Nbel) you use the term "defense materiais," you are
not- sayi_ng b_y that t _bat: tbe r.~aterials were necessarily

materials that- could on_ly be used for C.e_f_ense pur-poses?
'!'hey cou_ld be used for any purposes?
A
Of course, yes.
47
1
.=
.
-'
were: you dealing with any Iron Curtain countries?

;...
I was only dealing witb_
~esides Mauri~ania, were you dealing with other
countries.
African countries?
Yes.
-.
Was there_ anyone besides -Mr. Stevei)S o~ Captain
Stevens who \tas negotiating or bringing people to _you for this
purpose?
10
11
13
Yes.
What other persons?
lfR. AN-DREt;1S:
12
.....
wes~ern
-1-~
Here you dealinc; only with western countries or
Objection.
Do not answer the
question.
HR. RICHMAi::
14
Fo~ the purposes o! a discovery

I
15:
16
17
18
depositi_on--- I do not even object, if X)._ecessary _for

th.e deposition, to Ultimately i)aving it be Unde= C~_a_l,
i_f
\-le
are going through matters that are confidential.
But it is ,very di_fficult for rne to de~ineate the line

as fa_r as we can_ go.
I tbi_nk it is something that the
19
court ma_y ultimately have to delineate.

20
l:fR. ANDRE-'t1S:
Perhaps so.
'!'he business here is
21
a business inter_ruption with !-1au~ita%).ia and dealings
22
with kiauritai).ia, Hhich allegedly were- interrupted; nOt -ot:he
23
African': countries or other western countries or Iron
l
:.;:~
~r~=
24
'
Curt~i countries or other countries.
25
DAt-I: GI:NORON
48
-=
I understand that.
The problem is.
if you are in the middle of a discovery deposition--and
I will lay this point out--if the
was adversely affected by other business reversals with
other countries, that could bear on whether or not
Hauritania would deal with them.
_factor~ that could be involved and when we narrow it
down to just talking about Mauritania, it puts me in
a .straitjacke. : .
10
MR. ANDREWS:
11
12
...
HR. RICHMAN:
13
14
cornpany~s
business
There are many other
He never made claim for
int~rruption
beyond that of Hauritania.

!ffi. RICHMAN:
I understand.
I have no idea, but
there may be other problems that this company encountere

with other countries that would adversely affect his
I
15
16
17
18
19
20
21
relationship with Mauritania, besides what happened !n

this transaction.
.MR. ANDREWS:
But no .such claim has
MR. RICHMAN:
You
rnisunderstand'~Y
bee~
made.
question.
I am
not saying there is a claim that \.,e adversel_y interfered

with the business of this company with other countries.
I am saying that there' may be other factors relating
to the business of this country that bore upon the
22
adverse effects with Nauritania and I do not tbin_k, in
23
defending my client on this claim, I can just strictly
24
narrow myself to what specifically happened with
25
49
1
Mauritania, per se.
NR. ANDREWS:
You go ahead and ask your continued
"
specific questions and, if I feel it is an area of
confidentiality, I am going to instruct him not to answer
If you feel constrained, we will take it up with the
Judge and let him decide.

MR. RICHMAN:
have it.at least laid out on the record.
what your position is, basically, and l
10
12
know
think I have
With respect to the other countries, l
ask you tbe
13
names of the other countries that you were dea.ling with i _n
14
197 G- and 1.977.
16
HR. R!CP.HA~l:
18
21
22
I \-lOU_l d.
l~R. RIC1U1AN:
Certif~' that quest_ion.
presume it \10U_l d be the sane if I as~ed hi_r.a the
size and nature'of any contract~, any specif~c contracts
as to the types of weapons being supplied to other

countries, other t _h an ~1auri tania.
MR. ~NDREWS:
23
24
H_R . ANDRE~:;s:
19
20
Nould that be a question you would
object to and inst_ruct hi_m not to ansv7er?
'17
.::,
think I
Certify that last question.
15'
...........
.._
will
stated mine at thi_s poi_n t.
11
....
Let me go into the question so l
Yes, as to spec~fic accounts.
He bas
already answered yo~r question.

Q
Has your company been involved in any litigation,
25
8tfiT
TOM
'll!ltOioCAI'/ ~ LOioCBAROI
50
1
~
'1"'-
2
3
4
5
6
1
8
:~~-
any lawsuits other than this lawsuit?

A
No.
Have there been any other contracts in which the
company has been involved that resulted in claims or disputes

that were resolved without the filing of a lawsuit?
No.
Did you at- any time demand or request arbitration
of any of the matters involved in this lawsuit?
No~
10
Besides Banque Bruxelles Lambert that is involved--
11
pardon me if I
12
in this case, did your company use any other banks for its
13
normal banking transactions?
am not pronouncing it right--that is
MR. ANDREWS:
14
~nvolved
In this case? In this instant matter?

"
15
16
this case.
17
18
..
l'
HR. RICHHAN:
[Continuing]
relationships
~ith
Yes, the bank that is involved in
Did your
cornpa~y hav~
anybanking
other banks?
l9
MR. ANDRE~iS:
20
MR. RICHMAN: I am going to ask it both ways.
In'volving this matter?
21
involving this matter.
22
No.
23
Other than this matter, did your company have
24
banking relationships with banks other than that bank?
::::.
~.
25
Yes.
First,
51
1
2
3
.4
5
Was that bank used. in any other transact_ions,
besides this one, the Banque Bruxelles Lambert?

A
Yes.
Did those other transactions involve defense
materi'als?
Yes.
Going back to 1976, relating to the Government of
Mauritani~,
for the record again, I want to discuss specifical l
:what r:.1aterials were supplied.
10
11
MR. RICHMAN:
HR. l.,.NDREHS:
13
.....
, -~
Correct.
The same question I would ask for 1977, other than
this transaction.
HR. RICUHAN:
I presurne you \oTould a.ga in instruct
him not to answer?

ANDREWS:
19
H~.
20
MR. RICHMAN:
21
object again
well.
17
18
wo~ld
We will certify that question, as
16
I presume you
to other than this transaction?
12
.14
Yes.
Certify it.
'
Subsequent to this contract or the contract
22
which is alleged in this case, dated July of 1977, were there
23
any other transactions relating to the .Hauritanian Government
24
in which your company was involved?
~~~:=
25
Yes.
OA\.C: GtNDRON
52
1
There is one transaction relating to 5, 000 round.s
of mortars, I believe, mortar rounds.
Prior to this contract.
It was consummated after
~uly
of 1977, though, was
it not?
Yes.
Other than the rounds of mortars and so on, what
,.
other transactions did your company have with the Government
of Mauritania subsequent to this alleged contract in this cas ?

'
10
Two contracts.
11
For what kind of
12
5,,000 pieces, 105 millJr.~eter ammunition.
9hat was tbe other one?
5,000 pieces of 106 millimeter recoilless rifle
13
.14
15
16
17
18
19
rnateria~s?
ammunition.
Q
. A
What happened to those contracts?

They were canceled by the Mauritanian
Do you have copies of those
.Yes.
HR. AUDRENS:
_!
Go~ernrnent
cont~acts?
might tell you they a,re in the file
20
They are attached to john Ralph's af.fidavit filed in

21
this action as Exhibits B and E.
22
HR. RICHMAN:
Both contracts?
23
24
Q
25
,,
When were they cancelled?
53
1
'
,f
--
#~
;;._
The beginning of 1978.-
Do you have any cor-respondence
to that
cancellation?
An advice from a bank.
What- bank?
6'
.Banque of Br-uxelle.s Lambert.
!~as
~elating
that ban_k
als~
involved_ in these two other
t_ransactions?
A'
10
Yes.
Did they also involve letters of
c~ed1t?'
'11
12
t;lere any of tbe ,items, those two na:ned items, ite_ms
13
tbat were being
.14
case?
pu~chased
from any of the defendants in this
15
Can you tel_l us, sil').ce
16
17
in frol').t of us, \\'h_a t t_he_
18
_1978?
HR. A_NDREi'lS:
19
saie to you at . .that tihs il'l.
I_ wal').t to clear
'~hat
u_p because your
20
21
from
22
the advice occurred because the answer implied i t 'Was
2_3
correspondence.
.\
~~~-
do l').Ot bave t_he docunel').t
question was cox-respondence_ and his answer was advic.e

th~
~m.
24
. ..........
b~nk
~v-e
25
banks.
RICHHAt::
~et
us really clear that up as to bow
Let .us see i_f it was.

It did imply it- to me.
-I assumed.
..
OA\.C GCNOAON
J..,<'
1f
>~
'' ,, ... ,
.I
i1
That is what
54
1
2'
3
Was there any writing received_ from the
A copy of a Telex.
Is that something with.whichwe have been supplied?
4
'
ban~k?
MR. ANDREWS:
believe so.
~.
5
6
andtakealook-for-that~and-see
--I
-'
if-wecan-locat~
any
such Telex.
8
9
10
an~y
in
writing to relate -to that from the b,an_k or
other source?
11
No.
12
Did you receive
13
....
an,ything else
~ela~ing
No.
15'
t;Jhen you said
t_!)e
17
acguire t!iat
2Q
fro~
any
source
earl~i_er
k~new
that you
something about
':1eapons that you we:r.-e .involyed i~n selling, .,.,here did you
16
19
verbal advice
to tbat?
.14
.18
~nY
'infor~mation
or backgrotlnd?
,.
f~avy.
small arms trading il). tbe Royal
l;1ould that be it, e:<clusively, the
training
i~n-
tbc
~oyal
s~a_ll
ar::'ls
Navy?
21
2~2
ijad you had any
e~perience
'
23
24
\,
-";::~-::
25
'
in matters
..
s~uch
_as
Certificates of Origin of weapons and tbings like that?

A
Yes.
When and where?
'55
But_ all since 1974 or issued, sa_y, si_nce early
.':~~
to the instant matter.
197 6? Would t _bat be correct?
~rior
previous transaction
Concerning weapons, yes.
-Prior to January 1, 1976, then, had you ever been
involved
i~
a _n y kind of certi_f:ication of we apons as to origin,
manujacturer or matters of that nature?
In terns of documents?
~hen
11
How did you get involved in
12
~ust
13
Could you be
and
Yes.
wbere~
10
....
,14
15
be~n
in the
~oyal
Navy?
as a matter of stores tra_i _n_ing.

~ore
pecific?
How would
yo~ hav~
_inv.ol ved i _n anytbi_ng _r elating to d<?c'l1neJJ.tin.g the origin
or place of rJanufactu-re o _f wear>ons?
16
17-
tb~t
Hben_ a ship of_ He_r
~::aj
esty' s
!~~a vy,
s~ip-:..-
stores:
'
'
Among otber t _hings, they store anmun_itio:'l and witb t!le
is
arrlm~nition
19
~hips,
20
date o: manu_facture, etcetera, of arnrnul}._ition a_nd .weapon_::-y
21
and that is bal}.dled by the Roya_l

Q
22
.23
1~78
bi.l.ls of_ lading from .tbe -Roya_l -Fleet: Auxil_iary
which
~upply
~:Yith
rel~ting
tbern,
co~e
documents certifying
~;avy
~rigin,
stor:es.
regard to the ~ancellation that occurred i _n

to the Government of 'Mauritania, did you have .
24
any discussions with any uauritanian Embassy or other
25
o.fficials subsequent to the ti_me you received that notice?
.:..~':!.
>.;~:.::~
..
OA'-C GCNO-RON
~ _
_ ,.
h '"- . .. ~ ~_l~
i . <Mtr . l... -....:"" "' - .._ ,_,
- -
,I
.'
56
1
( ~:.~~
3
4
No.
Did
10
....
Govern~ent
regard to the instant transaction?

HR. ANDREWS:
Objection. I
instruct hi.m not to
Certify that
questi~n.
answer.
7
8
ever have any dealings with the
of . Portugal relating to arms or weapons, other than with
5
6
yo~
MR. RICHMAN:
Q
Did you have any kind of a relationship or dealings
' with the government or government officials of Portugal on

any other arms matters?
11
MR. ANDREWS:
12
MR.
13
RICHHAJ~:
Objection.
Certify that question.
assume you are i _nstructi_ng
hir:~
not to answer?
.14
15
16
have any dealings \-titb the Portuguese Government officials?

Yes.
18
When and where?
19
On or about January, 1973.
20
Pr.ior to January, 19 7 8, did you have any
conta~t
21
with any Portuguese Government officials relating to the
22
subject transaction?
23
No.
24
With whom did you have contact in January of 1978?
25
The Minister for Commerce and Foreign Trade,
.... ....
'
With regard to the instant transaction, die yoU
17
-~...;:.'
OAI.l GCNOR()N _ _ _ _ _ _ .
57
e
1
...
~- -
ll~~:~~~~~-~-~~~7
Does he still hold that position?
Was anyone present with you at the ti_me?
Yes.
17ho?
~'lhat
He spoke English and Portuguese.
10
He was primarily a t _ranslator?
11
Yes.
12
llas
don't know.
..
..',
13
...
officia_l title?
No.
15
Anyone else?
16
No.
17
Before we get into what took place at that rnaeting
19
20
21
22
23
24
--..;.--;
he a la\vyer or did he have any ot_her k_ind of
.'
was his position?
.14
18
Portuguese man called ~eJpJts.~~~ '~M.ul.~'.J
25
..
and the background, did you have any othermeetings with any
?or tug uese Government officials relati_ng to the instant
transaction at any ti'me?
A
No.
Can you be more specific as to the date of that
meating.
A
No.
How was the r:teeting set up?
OALC: GCNORON
58
At my request.
What took place at the meeting?
We discussed the formalities required for the
4
5
6
7
issue of export licenses.

Q
10
"...
Nas there an export license in existence at the tirne
relating to the instant transaction?

A
I have no idea.
MR. RICHMAN:
8
9
Let me just note for the record one
of the things we requested are copies of all export

licenses.
We have not been supplied with that.
11
I take it you have not been able .to locate any?
12
MR. ANDREWS:
Cortect.
13
HR. RICHHAN:
I assume, for purposes of the
.14
15
16
17
18
19
22
cor.\?any itself that we have requested and that have not

been supplied, that you have 'been unable to locate and
do not have in your possession or available any of the
other
~atters
set forth in our Request for Production,
othe_r than what has been supplied to us?

MR . ANDREWSi
Q
That is correct.
Have you ever seen an e~port license reiating to the
subject transaction at any time?

A
No,
What did Mr. Schlect tell you?
Well, not really very much.
23
24
t;-::;;;~~
25
'
record~
other than the corporate minutes or documents of the
20
21
59
1
As best you can recall,_ would_ you relate tQ us the
...
4
5
'
k~h_at
did you. ask h.irn, what- .did_ he tell_ you a nd so
on?
A
My l _i_l).e_ of inquiry was as to why .tl_lere should be
any delays in the issue of
~~por~ licen~es.
-;
You were aski_I).g him w}ly there. should be_ a ny delays?
(No
Q
..
you
10
]:.
Yes.
11
Qhat did "he tell
12
-Tbe_re .,.,.as no reason for deJays.
13
~heiJ.
.14
1:.
'I
15
Did you indicate to b.:.rr: thll.t thare had been a_ problirn
16
~esponse.)
ha~e
to al).swer audibly
you~
what happened?
"Than_~-
said,
you very_ much.
...
is
You
tbe~
contacted .no other
gov~rnment
official or
l)ever _folloHed .it up - an_y further witb_ the governrnent.-
20
correct?
22
23
24
~=
25
...
19
21
:.~.
Goodbye."
or a delay at t}le ti_me?
17
~1::~.
~hat's
RI.C~1AN:
ts tha
correct.
'i'le w_i il
b_rea~
at about five mi_l)utes to twelve,
make some pbone calls and recol),vene shortl? after .1:00.

Q
t1ith regard to the Governt:\ent of !:1aur itan_ia, ""ere
there a_ny otl_ler persons
.i_nvol~ed
OA\.C
in_ t _be oegotiations besides
~(NOAO,_.
.60
~~
Group Captain Stevens in your dealings with the .l-1aUritanian
,2
Government?
Relating to any matters or this instant' matter?
this matter
......
get to other
~ight
~~tters
later.
Let Us stay wit
now.
In regard to the instant matter, were there any
6
7
~ill
other
'in~ividuals
involved, bes_ides Stevel')s?

'
Gr.oup Captail') Stevens was never 'involved in the
negotiations
10
Nho was?
11
;..
I1r.
12
Anyone else?
13
!!r. Soghanai ian.
I{r. Pol_lard, David Pol_lardr
~elating
~arl
to this instant
Bigaignon and
~1r.
.~atter.
Guy ::eigaignon.
.14
15
16
Reynold 't;:!.l_liams, l!r. Ira Trast.
17
any other people involved.
!~r.
Holco~b,
Hr.
don't tbi_nk there were
18
'19
20
21
.Mon_s ieur B.i\.
ls that thi fellow ~ou named eai1ier?
Yes.
Captain ,i\nne, Hr. H_arti_ns--Hartins .is not \\ith tbe
22
23
J
24
..... '
........
-~~--
'";;;;;;;
25
..
Governrnen~
ot
MaUritania.
That is Portugal?
Yes.
~rn
sorry.
61
'1
Anyone eise from :-tauritania that you can thin_k of?
'Q
~~~
.r
!Iave I got
You have .Karl and Guy.
Yes, tbat's right.
Q_
Tell_ me again BA'
I think he. signed that certificate tbere, BA
10
Mr. Trast
w~s
the president or
~ice
president of
pronunciation--Bigaigl"lon?
Hr. Bigaignon \ias
t~rns
to
!~auritania
l;1ho was be?

~
re~ident
of Paris ,.;ho supplied
otber t.ban de_fense -naterial_s.
d_o you nean by that?
16
i'lha~
'17
t;iel_l, he told me. that he never supr>lied defen~e
18
..
Mr. Trast?
t'lho was Hr.--you have to help me w_it_b the
.14
;~:t:
How do you pronounce that?
the. i1umricb Arns Corpo'ration in Albany, Ne,., ;?ork Sta~e.
12
('
ii
Hbo
15
name.
B~.
1-iohamed .. Abdallabi":'- capi t_al

Q
13
11
..
Bigaignon?
~h::.
~ateria~~
a~
a personal entity.
19
You are talking about Karl Bigaignon now.
20
rigbt?
21
Yes.
22
Nhat about Guy :sigaignon?
23.
He was his brother al)d t_hey together had .an i_mport-
24
export
25
.b~siness
based in Paris.
Related to countries other than Mauritania1
Is tbat
'ies.
Do you happen to know the address of that company
Champs :Elysees.
Do you know the
To the bestof my recollection it is G.S.G., and
name of the company?
then the second word in small capitals is s.a.r.l., and I
thin)< the
Q
12
13
ad~ress
is 78 Champs Elysees
.Do _you speak any languages other than English
fluently?
No.
11
Q
Do you have
a working transl_ation knowledge o:f other
such as French, for example?
.14
Yes.
15
How about Spanish?
16
No.
17
So
18
19
.20
21
22
23
24
25
'
~pecific
-7
10
in Paris?
62
~f
you had a
~ocument give~
to 1ou in
Span~sh,
you would need help translating it?

A
.Yes.
If you bad -a document given to yoU in French,
~ou
could get t_ha gi_st of it, :but not necessarily all .. t_he specific
Would that;be a fair statement?
A
"tes.
Ho"ir did Hr. Bigaignon 'have anything to do "'ith the
transaction?
In other words, what o;.ra_s his _invoi vernent?
63
M-R
HR. RIC-HMAN:
A
Wbich one?
Let- us take ~j_~1Er7:]
He telephoned me in
~ondo~
ana said
tha~
he was
4.
negotiatir)g the suppl_y of _ certa_ir) ite_ms of defense material--
sorry, correction--certain items apart from defense material
to Hauritania, but tbat th_e_y al_so .had a_ req-u irement for
'-j
defense ?aterial~ and ~ woUld l
could I supply such items of defense rn_a~erial as they fin.al_ly
decided to purchase.
11
12
15'
16
17
1a
19
20
l:{ow did the_y happen to cal_l you?
-I' dol') t k_nO'\o-T.
I have r)ever spoken to Hr. -Bigaignon
prior to that .ti_rne.

.Q
13
.14
be interested in supplying an~

'
10
...
.i;\_N'ORE\~5:
~our
oid he _ind_i cate to _you _il'l any
:"la_me or hov: he had gotten in touch
v:a~
\-:it~
ho""' be }'.ad gotten

you?
~o,
~hat
'!'_hat \vas t _b e cor.lmence_m ent of a very lol)g,, .dra \.,.n-out
he
did~'t.
h~ppened ne~t?
and prot1::acted negotia t _io.l') with_ the l1a uri taniaJ') Goverm:\ent.
Q
Prior to that contact from hi~, had you supplied
a.l')y rr.aterials to tbe l1_a uritan_ian Go'\.rer:1ment?
21
Q
Approxi_m ately }:\ow
~an_y
othe_;.- tral)sact_ions bad you
22
had ~:itb tbe !-:1auritanian Government- p:t"ior to th_i_s phone cal:l?
23
(
;...
Two.
lnvolving how mucb mon.ey each?
24
25
. '
..
..
_ ____ ____
OA\.C: CCNORON
--~~==~~=----=--~~~~~--~~--~~ --- - --
''
,,
If" ,<t
64
1:\ total of one and a half million dollars.
2,
,Q
Both through Captain Stevens?
Yes.
2B
Other than those two
'.
Captain Stevens and the transaction that is the subject of
the instant case and the two you have_ testified were _negotiat
7.
but_ cancelled, ,.,.ere there al)y otber .transactions that )'OU wer
involved in: with the 1-tauritanian Government?
9
10
Let me also
include in tbat the cohtract related to the mortar

A
~ounds.
Well, as you know, we did negoti_ate and .enter into
11
that before the cancellation of tbose two ot.ber contracts,
12
but apart from those, no, we have not.- ..
13
"'
'
earlier through
transaction~
.14
~o
othe~
con~racts1
"!;.
~o
other contracts
t~ere
U~der
Besides the blo that were cancelled?
Yes.
For what kind .of
Various 4afense materials.
Can you, be at al_l rnore speci_fic i_o ter~s of t_he
15
16
17
18
19
20
there otber cont_rncts under
x;egotiatio~?
negotiation, yes.
mate~ials?
21
22_
aize of whatever it was that was being negotiated?

A
~he tota~ v~lurne
was approxinately ten m!ll_ioo
23
dol_la~s
over the following t\-lelve rnol)tbs, about.
24
.;:gg;;
~
Q
2_5
..
~bat
kind of items?
'
65
l.
..-
~ainly
Did the Mauritanian Government subsequently change?
There have been changes in the Mauritanian Governmen .
Was there in fact a coup in the government at some
snall arms and mortar
am~unition.
point in 1978?
A
Subsequent to the cancellation, yes
Appro~imately
-I can't put a date on it.
Did the coup involve a change i _n t _he major
10
.....
when did that coup take place?
government officials in Mauritania?
11
I don't know.
12
Did t _h e coup bave any effect on, _fo= exarr:ple,
13
Captain Anne's position or
.14
Uonsie~BA?
I don't know
It wa s, though, some ti_rne in 1978.
15
MR.
16
17
18
A
19
.'I'he coup, as opposed to 1979.
U_R . ANDREt;:S:
If
you know.
a luncheon recess vas taken at l_l: 58
a.rn.j
24
..
25
..
..
That would be a good breaking point.
23
_.
'
I think it was, yes.
[)~hereupon,
21
What was?
HR. R!CHHAN:
MR. RICHMAN:
20
22
bNDREWS:
I_s that correct?
OAI.C: C(NOAON
66
1
AFTERNOON SESSION
[The afternoon session commenced at 1:30 p.m.}
MR. ANDREWS:
Let the record reflect that Mr.
Richman is 16 minutes late from his pre-announced arriva
........ 1.ce.
HR. R_ICHHAN:
The record may so reflect that I had
an emergency to handle and have just come out of that,
after
~aving
had a sandwich at my desk.
[By Mr. Richman)
With respect to the prior two
10
Hauritanian t _ransactions before anything relating to the
11
instant case, we_re there any individuals involved in those
12
transactions, other than the people that you have named that
13
were involved in this transaction or Hr. Stevens?
;14
Yes.
There was a company in Brussels.
15
What was that company in
17
What was its involvement?
18
They acted as suppliers.
Is there a man named Cradock involved in that
B~ussels?
16
19
20
21
22
23
24
........
25
company?
A
cradock.
What was his position with that company?
Well, there were
and one son.

quite sure
tw~ ~en
called Cradock, one father
They both held different positions. I am not
'~hat
position--- I think it was vice president or
D.t.I.C CCHDROH
-
- - - ---
67
1
2
)"'===\.
>
.3
4
'.
5
6
7
8
a si_rnilar position.
Q
Do you recall thei_r full_ names?
Fran~ Cradoc~
Where
ln Brussels.
Are they Belgian citizens?
So, not as far a$ I know.
Do you know the citize11ship of either of tl)em?
Did you ever meet face to face with ther:\?
'Yes.
Do
Yes.
ar~
and Paul Cradock.
tbey located?
10
11
12
13
.~~~:.
they speak -English?
.14
15
~ou11d?
16
or do they appear to be Anerica11s or could you tell?
f7
'
....._..
..
o~her
words, do tbey appear to be British citizens
. he~d,
t;lell, I dont. know what citizenship they
18
but they did
19
were originally from the U11ited Kingdom.
20
.\
ln
spea~
Did you
ver_y good -E11glish.
d~il
So _I would say t}J.ey
witb_th~t co~pany
or aither of those
21
two individuals on any otber tra11sactions, .besides the t':o
22
relating to Mauritania?
23
]j.
Yes.
24
Matters relating to other cou11tries?
25
Yes.
OAI.C: CCNOAON
-e
r::.-
Wbat was your rela_tionship -with them?
~hey
.Q
Did you have a contract with .t _he_rn?
.14
l~hen
17
'18
19
: .
20
21
22
. 23
24
2_5
..
I
you say they
ac~ed
as :suppliers, did tbe_y

ln
Came f_rom otber counti'i_es.
Did t _hey then make tbe. arranganents to bave_ t _bose
goods shipped -f_rom anothe_r country dir _e ct_ly to Hauri t :a nia?

;..
Yes
t~bat_
ki_nd
ot
ca_r rier did you use?
._Did I use?
16
''{
to those two tral')sactions, specifi-
a _nother countr-y?
15
bac~
other words, was i t located in Belgium .or di~ it come from
13
. ;;;
Let us go
12.
\,
' res.
supply what~ver items they were supplying (n Belgium?
11
..
acted as suppliers.
lQ
cal_ly relating to l{auritania .
-;-
.';
68
~ind
of carr-iei' was used?
l\'bat
An aircraft.
i:1as_ it a_ privately-owned a _i _rc_raft_Or government
aircraft?
l;.
Hr. Soghana l _ian.
For that tral')saction, as well?
For the t\lO t _ransactions,
What ai_rcraft, specif_ically, was us ad?
~es
'
whet_be.r _i t was a . N7ll-OT, or another one?
..
OA~l
I
. ,
GtNOI'ION
Do you know
e
(
Yes, it was N7ll-UT.
Wbo was the_ shipper in tbose transactions?
]>,.
Do you .know whether or not
Mauritania?
.7
A.
No.
You_ do not kx)ow ei tl).er way?
No.
MR. A~tD:REHS:
'13
Prior or at_ t _h at
.Other tban the transactions involved i _n thi.s_
case a nd the fact that !-Ir. Soghanalian 's ai_rcra ft--in_ your
.14
words-:- tr.'anspo:::::te_d tbe r:taterial_s and the tv;o othe_r Haur i tanian
15
transact_iol)s, do you kno\-: _i f Nr. Soghanalian or .any cor.'\pa.ni es
'16
\-lith Mbicb. he was associated .. had any t _ransact_ions \: it.h the
17
1-:auri_tan_ian Government at
,-a
A_
i~o.
19
~itb ~es~ec~
~n~
t'ime?
to tbese two transactions tbat
~ere
20
prior to t _he one i _n t _he _i nst:af\t case, ho,1 did 1-lr. Soghan<:-lian
21
or any of his
22
.invol.ved?
2$
..
Hhat- do y,ou mean?
ti_r:te?
Q
1,
Hr. Soghanalian or any
of_ his companies had ever had any dealings di_rect_ly with
11
-"
don't know.
'5.
10
--
69
'24
25
conpanies~itb.
Could you
HR.
~epeat
R_ICH~1,t!.N:
which
h~
was associated
bec~me
tbat question, please?
~lould
_you read _i t back,
pl~ase.
[tO:here_upon, the_ pendi_ng quest_ion was read by t _be
OAL[ CC:NOIIION
70
1
I., ~1~
reporte~,
A.
He _freighted the defe_l)se material._
3'
0ho contacted
~r.
Did Mr. Cradock_ deal direct_ly with bim, as _f ar as
.,
.8
Yes.
l~ho was the_ shipi'er of t _h _

e goods?
MR.
~N-DRE,1S:
He has al_ready said he did not Know.
I don't know.
11
~:;r})o handled tbe documentation for .tbe transactions?
12
Hr. cradock, Hr. Ste_vens and. myself-.
13
can you give us t _he a ppro:-ci_r.'iate dates of t _be
.14
~_ra:).saction?
15
Hiddle 76.
\~it_h_ _respect to tbe transa_

c tions,
17
18
19
2_0
21
22
23
Cradock.
16
~~.
to do tbat?
10
.....
...
........
bi~
_you know?
as above recorded.]
24
2'5 .
..
..
:r know j!OU told us tbe_y ~!e_re i.n_.1_976
do you }:::no\.: "'nat_
typ~ of agree_ment .,... as _i _nvo.l ve_d as to payment of sl~ippi~g
cha_rg es, wbether it wa_s a C. I. F. t_ra~saction, f. o. b ., or

,.,hat it was?
A
i~o.
Do yo~ know whether or not the overall price
_included shipment or wl)ether tbat \>las paid .for separata_ly?

~
By Cradock or by, the Government of Uaur i tania?
By anyone .
Well, there are two different positions in the
71
~-:
, transaction.
'2
4
'
Yes.
H0\-1
Was that Mr. Stevens?
did Cradock become involved in the transaction?
contacted him or: his company?
l contacted him.
Q_
You .had already" had prior dealing-s with hi_rn Ol'l other
transactions or not?
11
Yes.
12
You had at- that tirne, 1976?
13
;...
Yes.
'14
Had you dealt with b.i.m il'l 1975?
15
-A
18
19
20
21
22
23
... ....
contacted
17
I negotiated '1-:oitb hi_m, but- l')Ott dealt "litb biro in
'7 5.
Q
Had any
tra~sactiol')s
beel')
col')sum~a ted
monies bad gone .through. and bee,n paid prior

~
~o
":i tb l)._irn ..:h ere
this , transact5.oh
' .
or these tral')sactions 'i.n 197 6, relati_ng to ~lauri tania?

A
.Yes--no.
so this tral')saction ,.,.ith Hauritania .,.1as the first
one that was consumMated with Cradock?
A.
Yes.
Rhat kind of a fee arrangement did
yo~
have in
24
l~ho
tha~
16
....,..
you to get' involved in it?
10
~~~~1~
tbose two transactions, who was. it
'
Let us take the transactio:) through step by step.

~n
25
that kind of transaction?
How were Jou compensated for
OA.I.( GtNORON
JOUr
72
1
2
(
5
6
On a percentage basis.
What kind of a percentage?
Ten percent.
Did title to any of the goods pass to Boca
Investments the way the transaction was set up?
No.
So what actually did you do, then, act strictly as
a broker in the t_ransaction?
10
Yes.
11
Let me see if I can take it step by step.
12
~~
----~
You were contacted by Stevens.

Cradock?
Yes.
16
You then contacted the Hauritanian Governr..ent,

e~ecuted
bet\-:_~en
17
assisted in the co::tract being
is
the Hauritanian Govern~ent and you received a ten percent
19
commission.
20
That's right.
21
Are there any steps I have left out or is that
essentially it?
...
Ctct!ock e.nd
basically.
23
I think essentially that is
24
Cradock contacted Mr. Soghanalian to arrange
25
.'
You then contacted
15
22
..
Tell Me
if th_is is essentially correct.
13
,14
'
I
efforts or those of your company?
OA\.C GCNORON
l.
~I
fo~
73
'
..
Yes.
That was
P~ior
to that time, had you ever 'heard of Mr.
Soghanalian?
I didn't hear of Mr. Soghanalian actually at that
time while the transaction ' was going through.
When did you first hear of him?
Mr. Stevens.
Approximately when?
The beginning of 1977.
10
How did he happen to mention that to you?
11
He confirmed that Mr. Soghanalian had actually
freighted the material.
13
How did he happen to Pention it, what conta8t?
.14
He had a discussion a_bout. the transaction
15'
What else did he
16
17
'18
19
20
21
22
23
total responsibility.
12
...
hi~
24
.... .;;.:::
25'
...
te~l
you about Ur. Soghanalian
or his business?
A
1\othing.
In 197 6, i _n this t _ransaction in' ~...hich you incica ted
you were strict_ly a broker,
~... ere
there other transactions
or w~re the other tra~sactions in which you were involved

in 197 6 also
strictl~'
brokerage transactions, as opposed to
taking title and then reselling the goods?
Some of then were.
l'lere there transactions, then, i _n .,.,.hich you actuallyr
by you I mean Boca
In~estments--took
0"'-C GltNORON
title to the goods?
74.
I,
=
;.;t
Yes.
But none with the Mauritanian Government?
No.
Was the first transaction with the Mauritanian
I~.
ri
i;
I
I~
"~=
f:
..:.~
,.
E
..
~
Government wherein you took titJe to the goods the one involved
in this case?
Yes.
Did you have any other dealings with Mr. Soghanalian
. or any .companies with which he was involved, to your }:nowledge 1
"
i..
10
l.'
,.
"
"
...
prior to
Jan~ary,
1977, other than the two
shiprne~ts
to
11
Hauritania?
12
No.
13
"as there any particular carrier you used for
14
15
16
17
18
19
20
shipping goods where you had
t~ken
title to the goods?
No.
Did you have any other dealings with Ctadock or his
co:npany, ot.ber than the t\':o !ia uri tanian t_ransactions?

.'
Yes.
Subsequent to the Mauritanian transaction?
He.
Was there some kihd of dispute or problem that
21
22
23
(
..
24
25
developed between you and his company?

A
Yes.
What was the nature of that dispute?

HR. ANDREHS:
...
I object to that.
I thin}: that is
75_
1
....
--
irrelevant an4
immate~ial.
2
~~DRE~S:
MR.
~o.
~ dis~fission
Ho~
7_
Through lawyers.
Has
~ould
you tell us, please, sir.

centered mainlY
~rofind
fees,
was that discussion resolved?
the~e
a laws-uit involved or was it settled out
. of court?
9
10
!e~.
'11
Who wa s t _be lawsuit between?
;:._
Cotir:'lerce 'Interna tionai I
12
.There ~as a lawsuit invplv~d.
Incor'pora ted, rnyse_l 'f a nd
Group Captain ' Stevens.
13
.14
Hhere vas tbat
la-..~suit
f_ile_d ?
I
15
-I am go_i_ng to object because tbi_s is
A_NDRE-~~s:
H_R.
sonething tbat occurr_ed i _IJdividual_ly, 'bet\'leen bir.\sel ,f ,
16
and sonetbing tot-a lly out_side t _he ! >ale and_ i~ is
17
_i_r -relevant and I ar.\ going to ihst:-uct-.. -h_i _m not to ans"'er_ t
18
HR. R_ICHfiAN:
19
J;?roffer a few
20
Let rne certify the quest_ion and
r:~o re
questions into the r_ecord as to the
areas of inquir_y.
21
Q
~.-:ere_
you
nar:~ed
individually or Has Boca Invest_m ent_s
22
n_a mad?
23
24
..,.,..
--"
Na_med?
,Q
bs
'
~t p~rt~in~
to tb lawsuit
25
..
'
_ OAIL( GC:NORON
- - - - - --
.e
76
1
2
t...
I was named individually.
~ere
A_
Plaintiff.
Q_
l"hen you wex::e dealing as a
you a defendant or the
plaintiff~
3
4
' .
bro~er
with. t _h ese othex::
two t _ra_n sactions wit}). H_a uritania, with Cradoc~, were you deali
personallt or were Jou d~alin9 in tbe n~m~ of Boc~ ln~est~ents
-7
8
9
10
11
12
.....
13
.14
15'
16
17
'
I was deal_ing personal_ly.
So _Boca Investments was l)Ot a_ I>arty, t _hen , , t _o ei the_r
of the other two :transa.c tions with tbe GovernmeJJ,t of.
~
my na_
r ne,
Q
Through me, yes~
l1auri_tani~..
l was on behalt of ~oda, but ln
perso1:1ally.
Did Boca rn~e -stmen~s get any money out of tbe
t _ransaction?
~
~o,
ls
A.
Yes ..
PI'ior to tbe transaction in ~he i:nstant'case,
JJ,ot yet.
tbe lawsuit still pending?
"'
18
there are no tra nsact_ions i _n w}).icb the pl .a int.i _f_f: {n t _bis
19
case, Boca _I n.vestments, \-las i _nvolved with tbe Go~er:nment. of
20
Hauritania.
ls that- correct?
21
Tha~s
correct.
2.2
Is Captain Stevens a plaintiff OI' a defenC.a_nt _i_n
24
Plaintiff.
2.5
Ca_n you_ tel_l us in_ what jur_i'sdiction t _ha lawsu_it is
23
( -~
. ;;;:"'
~
77
1
I'
filed, in what country?
.Brussels.
'3
Can you tel_l us the court in wbich .it- i 's filed?
.A
So, I can't tell
Can _you tell us the names of the la_w yers inv-o lved?
..
~m. ' RICP.H~N:
of the part_ies that are 'involved.
12
HR.
13
bimself.
AN-DRE1;7~ ::
~ver
21
2_2
23 '
other
infort;"~a~ion
' I want to e:{amine

-I .can _i_n_ case
J understand tbat.
You are not
' .
pe~mitt~ng
us to go
~ntQ
that?
AUD~EI~S:_
HR.
the
'la\'~~'ers
are."
t3o.
Asl~
You said, "Can. you tell us wbo

hi_m i-f he can id enti_fy _i_t ._
If it i _s
~-1:\ Br~ssels,
it see_ms to r.\e you would' be able
to track
~t.down
tbere.
M_R . R.!CHHA_n :
c~n
as t
fro~
_I Hould like to get as rnucb i _nfot:mati
to . make it .easie_r to
.t
Brusse~s~
I would_ l_ i~:e to be able to get_ "-'bat-
.<
'
Cradoc~:,
tbe court- fi_ie _i_%) :Brussels.
24
25
He h_a s .told_ _you Stevens,
He has told you i t .is (iled in
!JR. ;RICHHA:::
20
.i~g
it may lead to tbe -discovery of_
11
19
totally outside the
.t hings that could be relevant to th_is matter. because
18
Jo~
10
17
'
B~t
it
i~
_pale no.w of the matters _in_ this i _nstant m atter.
16
s~it an~
15
..
Objection. I think, once again,
})ave identified a
.14
yo~ that~
, "
A~DREWS:
HR.
'
OAU: GtNORON
Q
- -- - -
'
,..,
trac~
down..
I_f I have tbe
.. '
-.;.;~~=
~":;.-:'
names of the lawyers on either side, that makes it
easier.
3
4
5
6
7
you recall.
Q
Help him
find this case.
.
-
Can you tell us the name of your lawyer and the
name of the opposing

A
Give the name of your lawyer, if
lawyer~,
if you recall?
Well, I can get it for you and you can have it on
the record, but
advocate who is handling the matter.
10
11
..........
MR. ANDREWS:
can't recall the name of the individual
You do not recall the opposing advocate's name,
do you?
12
No, I don't.
13
Can you tell us hoov1 much is involved in the dispute,
14
15
16
what the lawsuit is for?

A
In
~y
particular instance, a hundred and sor:-.ething
thousand dollars.
17
18
How about
t;:ell,
_I
Captai~
Stevens?
don't }:now \o.Jhat the .fact 'figure is.
19
!1R. ANDRENS:
If you
.20
THE WITNESS:
I don 1 t kno\-lo
21
But as of this time, it is still at. the trial level,
as opposed to having been resolved and being on appeal.
23
that correct?
:'.0
25
..
~n0\-1.
22
24
"
..
Yes.
Do you know in what year it was filed?
!s
e
-.
1977.
Cradock s company subsequent to that di_spute.
Is that correctl
That's correct.
Prior to that dispute, other t _han the two transactio s
6
'
with Hauritania, approximat~ly how many other transactions

have you had with Mr. Cradock's company?
trans~ctions.
Two other
Can you tell us with what countries those are?
10
MR. ANDREWS:
Object.
11
MR. RICHMAN:
Do you instruct him not to answer?
12
HR. ,t\!mREN'S:
Yes.
13
Can you tell us if you personally have -been i _nvolved
14
in any other lawsuits or litigation, other than the instant
15
case and that case relating to 11r. Cradock?

HP..
16
17
H_R. -RlClU!AU:
you talki_ng about hroad,
l~~igation?
Yes, sir, if he personally has been
20
these two matters.
23.
I think I have the right to determine if he i&

a litigious person, if he is involved in other litigation,
has had ot_h er depositions taken.
MR. ANDREWS:
24
25
..
l~ re
involved in any other kind of lit.igation, ot_her th_a n
22
...::.::;:
Object.
19
21
( ...
A~fDRENS:
'sweeping matters of
18
take it you have had no other dealings with Mr
Go ahend and answer the question.
Yes, on occasions.
so
e ..
1
.-
I am not interested in goi_ng bac).c into things
terribly
~emote
say,
Yes.
What
11.
Somebody drove into
ll.nything else?
th_in).c I was exceeding the speed limit in Englal).d.
am talking about otber that). minor traffic offel).ses ..
........
~m
of la\o:sui ts?'
m~ moto~
car.
sued them.
referring to--::R. 'BARli.NDES:
13
HR.
R_ICHt:fAH:
,14
'like_ that.
15
Cornmercia_l dealings on_ly?

Xes, comnercial l_itigatio%1., al)ything
I had a ?air of 12-gauge shotguns stole%). f_ron ny
solicitor's office; sued tbe insurance company for navment.

.
17
18
11.
19
Anything else?
no.
I take it you have never been convicted of al)y
kind of crirn.lnal offense or anything like that?
21
No.
22
l,!oving to .the instant case and the background, i_f

firs~
2_3
we can take that .step by step, when did you
24
i_n any negotiations leading up to the transaction in the
25:
instant case or the_ transaction relating to the 10,000 mortar
-~
..
~h~t
~i%1.d
12
20
1970~
11.
16
'
time~
11
'
in
P.ave you been involved in any other lawsuits since,
10
...
.. .
~
u
8t-AT
TOM
f'-f'Ut_OMAN ~ \.,OMBAI'IOI
OA\.1: ClCNORON
get involved
81
1
...
' -
rounds?
1976.
When in 1976, ,specifically?
In the spring.
Who brought it .to you_r attention?
Well, the negotiations on various requirements
for the.Mauritanian Government started in the spring of 1976
with }ir. Big,a ignon and 'extended themselves throughout that
9
10
year, continued'into 1977, and everitually hardened into a

firm order for the mortars and -the HB!-12 machine guns.
11
12
1 ist
.14
Yes.
~e
discussed many requirements that they had
fron time to ti_me

Q
1516
the Haur i tan ian Government \7as interested in in 197 6?

A
13
Did Hr. Bigaignon bring you kind of 1 i _k e a shopping
Do you still have any copies of any such written
lists that he gave to you?

!~o
17
' !).
18
No?
19
No.
20
I take it i _n your business you generally do
no~
21
keep a lot in the way of records o= t _h ese transactions.
22
that correct?
A
23
24
~-.;:f.~7
25
..
Is
One keeps records, records of ~ransactions, but
don't think one keeps records so much of negotiations.

Q
You do not have any kind of a file anywhere that
O,_LC: G(NORON
82_
detail item by item the ~egotiations ~elating to the

Go~~rnrnent
3
4
8o,
Was Captai_~ Stevens involved in any of thi.s?
w~
dont.
l-1R .A.NDR!n~s:
of Mauritania? In other words---
\ ...
In any of what?
MR. ~IC_HHAN: You. ~re right.
I wi_ll. be more speci.fic .
to the
No.
10
Tell_ us, i .f you would, ever_ytbi.ng you can recal_l
Was he in~olved in any of tbe negotiations ~el~ting
.so
calibre
mac~ine
guns?
11
as to \-l})at happened i _n any way x:~_lating to Hauritan_ia in
12
197~-
13
easiest
.14
ch_ronolo.gica_lly, to tbe best of our recollecti~n, please
that you bave not a _! ready told us in_ \'1~ateve:t:' i _s t_he

~ay
for you.
If you want to take it step .by
~tep,
15
I
I'
i:
!.
!JR. ANDRE.t: s:
16
f7
1:
I object to that.
\~ant
you. to
ask birn specif.i~ que_stions, sta_rt.i_ng at~ a speci_f'ie time ,

,
18
and
think t_bat- \.:il_l be he_lpf_ul to the \ritness in
19
,.
l.
MB. BICHt~8:
20
~11.1 be happy to do so.
just trying to get the cbronology out b~fore we get
}2
to the specifics of this
23
tra~saction.
Nhen was the ~irst time you heard of any kind of
24
request or interest for tbe 50 cal_i _bre or 30 cal_i _bre rnachin
25
guns for the Mauritanian Government?
~ -
-~
~ am
21
illl-
..
OA\.t G(_NOitOH
.
A
tiations. from ti_me to time between Bigaignon and the
Ma~ritanian
mysel_f and Big:aignon, eitber in Paris_ or London, took place.

Q
Embassy in
invol~ed
Did. you get

rnate~ial
Pa_r~s too~
place, and meetings between
an~
in
pe~sonal
a~ms
defense
than the
as we re_ferred to it, pertai_ni_ng to Hr. CradocJ:.;.
10
11
'
.
one
negotiations 'in a
kind of
"'
nell, generally, during the course of 197-6, nego.-
with_ Mauritania?
or
othe~
capacity,
should say it with, Nauritanil
.
Q
So all tbe others tbat you haye 'been involved 1n
as a broker or other\1'i_se were in t_be name of Boca_ Investments.
12
!)._
t es.
13
~a~~ a~ain
to l976.
Had you been involved at_ any t_i_ne i_n supplying any
.14
15'
16
country with 30' or .50 calibre machine guns prior to tl)ese

discussions in 1976, relating to !{a'urita_nia?
HR. l)._NDRE~~S:
17
'
18
: '
..
'I
instr~ct
him
:not to
'.'
a_nswer tbat question.

MR. RICHMAN:
19
Obj ect_ion.
Certify the qu.stion.
I '\1'ill ask some more guestip11s because I
2Q
thin~
it
'
21
\1'ill be clear as to wby I an as};ing tbe question.

Q
Had you had any
e~perience
with .30 or
22
.so
calibre
r.1achine guns prior to tbe transaction in tbis case?
23
Na~~,
In the Royal
yes.
Did xou ever purchase .30 or .50
24
\. ..
25
.,
..
~alibre ~achine
84
1
2
3
4
'.
guns ii1 the_ Royal Navy?

A
No.
I never made any purchases of .30 or .50
-calibre machine guns in the Royal Navy.

Q
ta~e
it, then, your ex-perience _in the .Roya_l Navy
s.
was li_rnited to knowledge of the use of the weapons, as opposed
to anytbing relati_ng to purcbase of the weapons?
'!'hat is wbat I-~Q
9
10
11
12
13
:14
f5
16
17
certain_ly recognize the_m.
Prior to the transaction relating to this case,
,.were _you ever _i_nvol ved in obtaining Certificates of Origin or

certificates of
Nanu~acture
No.
Did you
~ver
relatin~
to
.so
calibr~
investigate the background to find out
,'t>;b,ere t_hey are manufactured or who is making
._so
ca._1_ibre
guns, say, in 1976?

A.
At what time?
me whether I
Are you
_investigated tbat in 1976 or 1975 or 1_974 or now?

,Q
Did you
1976.
investig~te
~t
in
~976
invastigated tbe supplier of machine
or any
~uns--
19
-50 machine guns,
'
not the manufacturer.
20
Q
Sitti:l).g he_re today', do _you know anybody who is
21
:r.~anufactur i~g
50 ca_libre machi_ne guns?
_22
Yes.
Prom
Yes
23
(
sc~atcb?
24
.:~
~=:::
25
..
OA~C:
GC:NORON
rnacbine guns
prior to l97G?
18
85
1
tin
~
'.
How about the ones of the type that are the subject
of the alleged contract in this case?
think it is the
Do you know anybody who is manufacturing them?
HBM2.
Yes.
Hho?
~~gp.~~~
What is NAPCO?
An ~~?~~;-:~<?_?_r;p~r~~~~n !j
Any other company?
11
Any others?
12
There are various companies which are subcontracted
6
7
8
10
13
.14
to
~ake
parts for them

Are any of these two
co~panies
-
you named or any
15
companies, to your knowledge:, nanufacturing them as opposed
16
to reconditioning and rebui_lding thc:r.'l?

'
17
;,.
Hanuf actur i _ng them.
18
From scratch?
19
Yes.
20
~horn
21
Anybody you know up there.
. :::.::.:
could we contact at NAPCO to confirm that?
HR. ANDREv:s:
22
II
othe~::
Objection.
I instruct hi_rn not to
23
answer.
24
Managing director.
25
Can you give us any names o: anybody?
OAl.C:
GU-'-'
cO
:_
~:..::_
O_:_c_N_
_ _ __
86
M_R. ANDREWS:
.. ..."=
. ...
A
the man.
lf you know.
remembe~ .bu~
Maybe
If you do not ].c_now---:
I _am trying to remember the name of
\.,i_ll .recall it later.
How about- at ~o-n-tj
What is his position with the company?
He was vice president or---
Were you advised by any source that that particular
9
10
..
.model machine gun while in service was no longer being manufactured, as opposed to being
11
.;..
No.
12
Let us go back to,
.14
15
16
17
18
reco~ditioned
sa~,
or rebuilt?
1976 or 1977.
Did _you ever discuss wH:_h anyone during that
13
...
of time the new

A
'x'es.
,.i i th
.A
Q
manufacture ~
pa~iod
of such weapons?
~1hom?
Mr. Soghanalian.
What did be tell you and when? -.
19
20
~~ -~~~~a~~~~ ~-c-~;:~.:!,~ :,:~r; -~AF-\e 7.1:;a7

Q
Hho was present \-:hen t _hat state_m ent Has made?
21
22
~ieen.:..~-.s~'
Subsequently, tbere were verba_l discussions -
23
from the time of the visit to NUmrich factory, where Mr.

\
24
' ~I
Bigaignon was present and Captain Anne was present.
~:::-
25
..
....
--
2
3
4
5
6
7
8
9
On the telephone conversations, was this one of
the ones where Mr. Burr was listening?

A
No.
I don't think that there was any second party
listening to that
Q
teleph~ne
conversation.
Did you have any discussions with Mr. Soghanalian
as to whether they were being actually manufactured, as oppose

.
to being reconditioned and sold as though they were new?
A
No.
.~h-ey w~_;--~__.bei)1_g
~e- :f~i"ct- ,.that Mr. Soghanal'ian told

-- -~--
---- --- - -------- -- ---
----
manufactured -i n .America -and
-~ --- - --- - -
- --
---.......
-- ~- --
me was
that
- - ------ ----------------i~
Ju~
coul'd obta'i:n a
.....
10
11
12
13
16
17
18
19
20
21
22
consider to be particularly
very carefully,
i~portant.
Are you certain that nothing, no representation
or no information was given to you indicating that that rnachin

gun was no longer--the
~so
cal~bre
machine gun--being currentl
r:~anufactured?
Absolutely, without a shado...,. of
And the information about which I am talking would
~a.
doubt.
be verbal or written? You were never given any verbal or

written information?
Is that correct?
That is correct.
Let us now go to the end of 1976 and concentrate
23
our questions relating to the
..
~emory
because all the questions are important, but this one I
14
15
I want you to search your
.so
calibre machine guns.
24
~~!iii
You had, I take it, no contact at all with Mr.
25
'.
OAI.C GCNOAON
........
........
Soghanalian or any of his companies, to your knowledge, in
1976, other than the use of the aircraft for shipping?
Other than through Mr. Cradock.
You had no face-to-face discussion with Hr.
Soghanalian or any of his agents or employees or anything,
any of his companies, to the best of your knowledge.
correct?
9
10
11
12
-
88
13
.14
15
16
17
Is that
'That's correct.
How did you actually get in ~ouch with him?
I spoke to Mr. Stevens and said that I wanted to
discuss -freight rates for defense material shipments. e r . -

tbc--..._
~;;~-~;-~;-ug9~~~~?-~-~h~~--! contact
ur:- sognana:r~~n,-~ ii!io--.ha~
sl}.ippe_d_ :t:he. aef.e.n.s_~___m.a.:f.erlal.f.-~r. Cradock had supplied.

\i
Do you know what company it was that shipped the
defense material?
A
~-:ell, Hr. Soghanalian had confirmed in \,r i ting :to--l
I am sorry.
l1r. David Pollard had confirrn~d~in writing, had
18
a paper of United Trade International Air Cargo, Limited.
19
The freight rates would have been applicable to shipments of
20
21
Hr. Cradock.
Q
Did you ever investigate where that conpany was
22
incorporated or anything else about its background?
23
24
~-
No.
What happened after that conversation you had
25
OAI.C: GtNDFION
89
with Mr. Stevens?

.:&.......
I rang Mr. Soghanalian.
Where did you call him?
America, a teiephone number in Miami.
Tell us approximately when it was that you called hi
6![:~~-:x~~ihink. i t _w.a.s__ a:x;:2_~~d --~l?.o_u_!:_ A~r;~l--t~ .1271-;7
Prior to the time you made that phone call, had you
,;"
had any disc~ssions with anyone re~ating to Hr. Soghanalian
or his business or reputation or anything, other than the
discussion with Mr. Stevens that you have already ~elated?
10
1l
12
...
No.
Was your sole purpose in calling him, then, to
arrange for freight?
13
14
- - ..
.
~
15
II P~.fl...;::.lajl
16
17
I
I
18
19
20
21
ii---~-
Tell us what was said in that conversation.

Well, it was a very brief conversation ~n which I
explained to Hr. Soghanalian that I rnight~have a requirement

later in the year for freight shipment of defense material
and would he be inteiested in handling that.
What did he say?
He said yes, he would, and he asked me what the
22
defens~ material would be and where it was going to.
23
'
.....
What did you tell him?
At that time, I declined to discuss that infornatio
24
....... .,..,
.'.
25
0"''-C GC..,ORON
--
~--::;
with him.
2_
Rhat happened
Well, other negotiations with the Mauritanian
'.
90
afte~
that
con~ersation?
Governrnent took place at some time subsequent to that first
And: I 'rn not quite sut'e when I
convet"sation.
was able to
say to Hr. Soghanalian more definitely that I had the
requirement for the freight.
..
9
..
1'1hen you say _you had the requi_renent- for t_he
freight, do you 'mean a require.ment just si.ni>lY to sbip?
10
Yes.
11
Q_
At
"'-
~bi_s
po i_I)t- ii:l tir.1e, were you yet in you_r
12
13
.-:.
.14
15
16
17
18
19
20
21
22
23
25
..
tbat would have -been the .first step that
had been taJ.;en to rnal::e formal eemancls

Q
So at t_his point, you already haC. a rift \o:ith
xour ~upplier, Cradock,
ls tbat right?
't~;ith
t::ith a supplier, a_nd you ~:e.re see}~ing another
a supplier,_ yes.
supplier or interested in find1ng another ~up~lier?

A
again, so
Q
1;lell, 'I didn't i_ntend to use !~r. C~adock to supply

;:ij'
s~pply
":oule obviously be ron anothe.I' sou=c e.
Had you li.ned up another sou_rce yet at_ tb_at
point?
I
24
'4'!!!.!.
thin}~
Q'
had discussions with
~at'ious
people,
y~s.
t::hen did you tben tall< to Hr. Soghanal_ia%1
~bout
thi_ ,
1
91
1
.....
_.,
-~
or anybody associated with him?
Later in the year.
We started with April, so if you can chronologically
'
4
take us through, when would it have been, assuming the trip
to Hiami and all and the contract would have been in July,
1977?
Hhen was it you again had a conversation with him?

;,
9
10
11
12
...
13
Well, in one of the conversations subsequent to
the initial conversation, Mr. Soghanalian offered not only

. the freight services, but said that--::. "When: x:told
~h'im
what we
probably \o/anted;, .-e~~:SaTd 3h'a~- 'h-e -coii~.le\ ~~P.P.i'.lY. - ~ha-~- .rnaur1:a1~

You then told him what it was that you wanted?
e~~.l ~~
A
I then ,.,.as very speci~ic and sent a Telex to Ur.
_______ __._ .
_ . _ __ __ ____ _
_ . e lilt. 4 _f-lt-"'"l
Sogh ana 1 ian, ~ _<L~T_el:ex_ ..Mr.~.-S_oghan.aJ..i.an_g.a,v_a ~ mc:Ls ~ t
Q
14
I
15
16
17
18
19
20
that Telex, in addition to the specifications, the conditfcrn

of the guns we wished to purchase.
Q
Stevens was no longer involved in it at this point?
No.
At this point in tirnG, had you been dealing or
He was never involved in that.
had you dealt directly with any Mauritanian Enbassy officials,

government officials?
21
I dealt with them through Mr. Bigaignon.
He translated for you, essentially?
Yes.
22
23
And then, subsequently to the negotiations,
24
the Anbassador for Mauritania came to London and we had a
~;;;';;\
25
e
.meeting il't. Loi)don.
(---:;.
Mauritania?
\1ith the Ambassador f_rorn
11.
Yes, sir.
i-~bei)
92
-.~
was that?
carne to represent his country

essentia_
l
_
ly
he
We,l,l,
A
Quee~ Eli~abetb~ I _I I and it
at the Jubilee Celebrations fo~
'7
was in that t _i _me span.
,.
roore with wher)

Can you help :r:le a 'little
was?
1 do hot bappen .to recall that.

I_ suppose_- --: t ca_n t be---- Obyiously, t ,can loo~
11.
\0
it
bac~ a nd see \-.'hen t _h e Ju_b i_lee Celebrat_ions we_re held.
He v:'as
11
'12
i%'4 London at tbat ti_me.

At this point, \-lhenever that wa_s, did _y ou have a
13
u:..
r---.
.14
iS
t~o.
t~h.en wa _s it_ that you. !}_a d your first signed cont_!;act
I can't recall the time.
16
I.
17
They w~re dated,. but
18
19
20
it's---H_:R. ANDRE~:1s:
He produced t _h at contract for you.
!:l:R. RlCi{HM~:
I will see if we can_ ju_s t_ pul_l t_bat
21
out a_n d have it ident_i :f ied.

22
It ,.,.as August, 1_977, wben it ulti_n ately \~as
23
executed.
(
.., 24
~..._--;:~:;;;:
Th_is would be an appropriate tine to go anead and
25
-- - a
c ccuOP,....N
-e
..
get that marked for the
~d,
please, as Defendants'
Z.1R. ~ND~Et;lS:
attached to that is a
preceded this
identifi~d
E~hibit
hve this mark
No. 2
~eferred
to
~as
marked
want to call to your attention tbat

lette~
cont~act,
HR . RIC1tM~N:
10
~otild ~ou
of
~ntent
of
~une,
which
which is another separate docurnen
Leave it togetber and
we
will .have it
as such in the record.
sould you look at that, sir, and tell us if that
11
ciocume%1t is the contract_ to whicb_ you referred, which was the
12
first signed contract_ relating to tbis transactio:).
-.13
It is tbe contract between rtyself and tbe Mauritania
:14
Governnent, bet\oleen Boca Irwestments and the Nauritaniali
'15
Government.
'16
17
as Defenda_nts' Exhibit No. 2 for identi_fication . )_
~ecord.
[Whereupon, tbe document
'3
..
93-
-Is tbat the_ first- signed contrac:c
rela~i_ng
to this
t_r_ a X).S_a c tio n?
...
18
19
20
21
0as thar~ another signed contract ~elhing to
this transaction?
A
Yes, ~1r. Soghai').alian.
I meant witb tbe Mauritanian Government.
22
This is the
23
though?
.24
-...--
--
.25
..
Yes.
onl~
one \-lith t})e
Z~auritanian
Govern_rnent,
....--~ ~
sir, the last page_ of the composite document, which_ . . is dated
in June of 1977, t_he 30th of June.

-
Government.
8'
9
10
11
12
13
.14
Hhat is that, si_r?
.7
-;:;.
2\,ttached to that, could you identify for us,
Q_
94
That is a lettel:' of intent- to the J1auritanian
Did you .receive it at or about- the ti_me. of the
date that appears there?

]).
Yes.
0as this other contract, wbich is dated August
29tb, in fact
e~ecuted
on that date?
]).
Yes.
Let us continue.
He went from Apl:'il to sone time
subsequel)t to that, wbere_ you' bad
a conversat_ion .,.,.it_h
Nr.
Soghanalian relating to actually sUt>plying l'l'\aterials .

I
i::hat bappened after t_hat convei:"sation-?
15'
Incidenta_lly, before
16
:1
ask you that quest_io:), "as
.a_nyo:1,e
.
.
tl1a'C
. conversa t.l.On
r.tonl.. t o::l.n<J
~
"' ':-na.u.an.
~ ..
?
1r.
_s og ..
Wl.. th
17
18
No.
Continue, if you would, si_r.
Te_ll u_s what- happened
19
after that conversation.

20
b
1-lr. Sogha:nalian made the of.fer that he coUld supply
21
.,
'tbe naterial and I

22
said tbat I would put a Tele~ on to him.
Nbat material was i t he was offering .to su~~ly at
23
tbat time?
-~ :..
\ -.....::::;:.
.24
~l:.~
.sO
and .30 Browning
~achi:ne
25
0"\.C CCNORON
guns.
95
....
How many?
The initial negotiations that I had with the
Mauritanian Government was 200 and I advised him that it would
be in that area.
200 of each?
200 of each, but provided that: t _he transactions
were satisfactory, because there is a possibility of dupli-
cation of the order.
What happened after that?
10
~?--~~_g_!l_a_~a~-i_?:!l __g~v_e - ~ :r'~---~~~--?~~l~~~~-x;.~E.?_30n- ~ca
11
where I could put a : . Telex on to him and I did so.

!-1R. ANDREHS:
12
13
conpl~int
14
Prior to
th~t ~onversation
and beo:e wa gat to
that specific exhibit, had you received or did you ever
16
supply to or discuss with Mr. Soghanalian any other types of
17
wea~ons or supplying of any other types of weapons, besides
18
the nachine guns?

A
There were others.
There were others.
There
20
were other matters that I mentioned \<1hich had been discussed
21
with me and I think there is a letter that I wrote to Mr.
22
23
24
25
'.
I~:.ixbTh1t:iJ to the plaintiff s
15
19
-~~~;1:
Soghanalian, sort of setting out various requirements that

I had been asked to establish, ~here he ~as also in a
position to supply those.
Q
Do you happen to recall what those other itens werer
OAI.C:: GCNDRON
96
Not offhand, no.
I do not have a copy of the document.
'"
Maybe I do.
For the record, so we will be clear on that:
4
5
aated in May of 1977, Exhibit 1 to the complaint?
the one you are referring to, where you corresponded with
Mr. Soghanalian for the first time?

A
Yes.
Subsequent to the time
11
That
~s
10
The Telex to which you have referred, wbich is
the Telex I sent Mr.

~ou
Is that
Sogh~nalian.
sent that Telex, what
transpired relating to this transaction?

A
My conversations with Mr. Soghanalian dealt mainly
12
on the fact that the client government ,.,ould reguir_e to in-
13
spect the HBU2 machine guns and .30 calibre 1919A4 machine
.14
guns and satisfy the_nselves that they \'<'ere as required, to
15
16
17
18
19
20
21
22
23
the definitive specifications and in new' condition.
You just used the words "new condition."
~hat
you mean by that?

A
Ne,, ,. unused.
When you say "unused," do you nean necessaiily
recently manufactured or just not previously used?

A
Not previously used.
So if they had been manufactured ten years or
fifteen years before, but had never
been~used,
that would
constitute new manufacture, as far as you understood the
24
.t;~~fi
25
..
do
term or not?
OAL GCNOIIION
'
~iso
Well, they
~ssu_min<J
~nd
\~hat b_appe~ed
.Mr. Soghanalian
6_
had to be
operatio~al.
they were operational.
in new condition.
'after that?
~epiied
to tbe effect that we can
inspect the_rn on site
~ou
Did
Mr. $oghanalian was ~ little bit ~eticent-~bout
9
tO
13
:14
at that pel"iod of t _h e negotiations.

I will bave copies
9ou received.
17
-~ubstituted
on this;,but let
That is dated May 27, 1977.
I can only ~ecog~1=e the Tele~ tbat l -sent.
) don't reco~nize, for ~nstance--- ~h~t could be
15:
16
discuss the site?
re~iewing the site and that is a~ u~derst~nd~ble ~eticence
11
.,::.,
9T
a faded cop~' of a Telex w!J,_ich h::l.dn' t been t _ra:)s-:::d tted. tou

can t di_sti_nguisb between t _b e red and the b-lac].:.
is:_ _Do
-~ou _.recal_l
18
19
'f:
_).'
read tbe contents o! this?

-I _f -I can see ti~ own 'I'elex, l can compare _i t.
A
2_0
~_fR.
21
RIC_H!f.l\}1:
A_NDRE'NS:
to tbe complaint which ~ou have .there before you.

tb_inY. you_ might- find 'E_x hibit_ 2---
2_5
..
' "
I,
, ..
~ I:,
> '
He were
_I t_hi~_k be is speaki_ng of ex_h.ibi t.s
24
---
_i t }J.e_re.
supposed to be supplied ali documents r~latin9 to it.

HR.
.\
. ha~e
2_2
23
.Fi_n'e, if you
.... ,.s . .:
I ~
'
DALC GIENOROH
I
'
.. ..
to
~.'t
~hat
that item.
that- .item.
~eqUest tha~
Do you have any idea, then,
~by
to
bas been made tor
that was mentioned
in there?
A
Well, 'Mr.
~oghanalian
mentioned
befor~
that
h~
was
an agent for Colt or a representative of Colt to
11
t_he ~160-Al and we didn't'require it:"for't_n.Ei_client coU:ritry'anp
12
we made no request for it for that client country.

Q
of Colt
You_
~(ne""
Man~facturing
Company?
'~h_t.t
h.
Fron "''hat h_e said, fror.'l
16
Did you con! i_t:m t_hat f_rorn
17
is
20
21
22
23
24
25
manufactu~e
Nr. soghanalian to be_ a representat_ive
15
19
'
There 1s no
~s
10
,14
'!'hat is the Telex we received from
Mr. Soghanalian, but no requirement is on there
13
~-.jfj)
we haqe sbown .you.
THE t~tTltESS:
.....
Exhibit 2 appears to be identical
-~
.HR. RICH}1Af~:
.~-::".:-
98
a~y
!1r. Sogbanalian told r:te.

otber source?
No.
Subsequent to that communication~dated the 27th of
''
.z.:ay,
1977, did you contact or did you have_ any further contact
with
~~r.
'!.
]).
Soghana_lian relat_ing .to the speci_f_ic _items?

-In telephone conversat_ioi).s, I di_scussed who would
be coming on the inspection and tbe date .Has set for the
i_nspection.
Q
X am going now through the documents
poodence that have been supplied to us.
"0.\\.( C(NDAON
~rid corr~s-
99
The next thing that is attached to the complaint

p~
is a contract which is dated the 11th of June, 1977.
I am looking through what Mr. Andrews has supplied
to us.
in writing between those two dates.
MR. RICHHAN:
Do you, Mr. Andrews?
MR. ANDREWS:
No.
MR. RICHHAN:
Can you recall any?
HR. ANDREl'lS:
Not in writing.
Are you talking about submission of theTelex,
10
...
Let me doublecheck, but I do not recall anything else
11
speaking of inspection, the responsive Telex, Exhibit
12
2, and then the next
13
.14
HR.
RICH%1AN:
ite~
being the contract?
Correct
Betwee:). 'the 27th of Uay

until the 11th of June,
.,
15
to the best of your knowledge, was there anything in writing
16
by ...VOU or Boca
17
companies or companies with which he was associated relating
18
to this transaction?
~nvestrnents
or Mr.' Soghanalian or any of his
19
No.
20
Hith respect to the discussions you had subsequent- -
21
Can I make a correction?

I recall that I did send--,l~Aid::!~J~o -ffr~--,
22
[9_l1_a.~a-li'an onthe t-el~.Phc:>_n~~-that~ould stmd li."iaadra-f.Q,..,-'

1
23
':,
...;~:~~::
24
25
Proposed contract?
OA\.C (;(NDRON
100
.Proposed contract.
Did you do so?
And I did so.
Were the contracts involved in this case contracts
that you prepared, as opposed to something Mr. Soghanalian
prepared?
Contracts that we preparea.
Normally, you prepared contracts?
Yes.
10
Did you have advice of counsel or a lawyer assisting
11
12
....
13
you in doing it or did you just draft th~rn yourself?

A
had advice fro:-n la\'Tyers all along the
Lav7yers 1:1 the Jersey Islancls- or in London?
15
.!n London.
16
t:ith respect to \:he items _you \tanted on your
17
'1' elex here,
21
22
23
\'Je
contracts
24
25
I note that on' tt.e 'l'el ex there is a reference to-J
let neuse the complaint copy since it is'easier to reac-a n~rnber of items that are on here.
HR. ANDREHS:
20
Ho.
19
.14
18
(
~-:~~~~;
Let us take a look.
You are reading from Exhi_bit 1 to the
complaint?
Q
There is a reference to .-50 calibre machine gun
and there is a reference to spare barrel--
Yes.
--field maintenance spares, cleaning kit---
101
1
(
Yes.
Did he indicate he could supply those?
Yes.
Then there i$ an indication here of a tripod,
H3 tripod.
Ye.s.
Did you have any discussion with him as to whether
10
~u
as to whether or not that could be supplied?
..
Did you have any discussion with Mr. Soghanalian'
or not he could supply those?
11
Yes.
12
Did he indicate to you be could supply the necessar_
13
quantity of those?
14
Yes.
15
Of'any of the others that c:.re involved in here--and
16
take your tine and just e>:<amine it carefully--did he indicate
17
to you as to any of those
18
supply them at that tir.le or that he did not' have
ite~s
that he
woul~
be
un~ble
to
__.
19
20
21
22
23
...
24
25
th~n
on hand?
No.
Did he indicate to you ~hether or not he had all
the items contained in there on .,hand, available immediately

to supply?
A
He didn 1 t say that he had them in stock.
He did
on a--on one telephone conversation, he claimed that he had

stocks of defense material dotted around the wo~ld, but these
O ... U: GI:NOFION
102
......
particular items were being manufactured in the States and.
we were going to inspect them in the States and he would
supply them from that source as to the specifications.
4
5
6
7
8
9
10
11
12
..
13
14
15
16
17
Did you have any kind of an agreement relating
to price at that point?

A
No, because there was an indication that I had
originally put in for suggestion of price, but that was a

suggestiqn which Mr. Soghanalian couldn t meet and t_herefore
we had to discuss, in t_he due course of time, the price of
the items.
Q
Did you have any discussions at that time,.about
the same time as this Tilex took place, about any other
items, the supplying of other items besides what is in there?
A
Not
How about mortar rounds?
~-lith
reference to the !-:auritanian Government.

I
Were you discussing
that at this same ti.me or at a later time or what?

A
I said there was a possibility that
the~e.would
be
a further requirement for mortars, but that had not been

18
directly communicated to me by the 11auritanian Governnent;

19
therefore, it was only a suggestion at that time that I had

20
made and I didn't include it in this Telex because it -..:asn' t

21
a definite--22
Q
'
When did you get back into discussions rilating
23
to the mortars'?
24
:!.:::
Nell, subsequent to the Telex and towards the end
25
OA\.C: GC:NORON
103
~-
~-
,,
'1
of June.
Government would want to purchase in total ten thousand
.:mortars.
I was told by Mr. BigaigI)on that- the Hauritanian
That was i_n t_he begini)ing of June?
1>.
l~ell,
it was during the June period.
put- a definite finger on the date._
I can't
That was later confirmed
7
, [l~.hereupon,
8
9
a four-page document was marked as
Defei)dai)ts' E~_hibi_t: ilo. 3_ for ide%1ti_ficati_on.

Would you look .at Defendants'
10
E~bibit
3; please,
11
...
sir, and tel_l us iJ you can ideotJ_fy that.
12
'b
Yes.
13
What is that, sir?
14
That is a draft copy of a proposed agreement.
15
Ist_}).at t_he 0%1e you sent_ i_n. tbe mail?
16
I tbink.
17
18
~he
HR.
21
25
R'ICHUA.fi:
'I'he_ record w_ill reflect that i t :i_s
Following along chronologically
~ow,
ajter tbat
draft was sent i_:n the rnaJl, what bappened next relating to
~rans_action?
this
24
~--~
r~f~~red?
a four-page cor.lposite ex_hi_bi:t.
20
23
one to which. you just
Y' es.
19
22
Yes, I believe i t \fas.
I tbink further telephone conversations, which \-lere
real_ly designed to gear up t_he inspection ai)d make sure everyol '
O"~C GCNDRON
1
.,.
104
...---...
~--
3B
..
knew that we were going for the inspection and who wou_ld be
going. And there were further discussions on price which again
were still indeterminate, and then I received a letter of inte i
from the Hauritanian Government, which specified three items:
200 HBM2, plus
.rounds of 81 mm mortar.
.so
Browning machine guns, 1919A4, and 18,000
MR. RICHMAN:
[Discussion off the record]
9
10
till
Off the record.
!s what you have reference to now the June 29th lette
of intent?
11
Yes.
12
June 30th, rather?
Yes.
13
14
15
16
18
That is the name of the r.~an I was trying t.o
recall earlier.
Ahned Ould Ghanahalla?
Yes.
Here you negotiating .directly with this !':'leu~, '"hos~
17
nar.~e appears at the end of the June 30th l~tter?

A
Partly directly and partly indirectly.
Ho\1 indirectly or ho,.,. di_rectly?
Through Mr. Bigai~non.
,I notice there is a mention in here to a figure of
19
20
21
22
10,000.
It, of course, is all in F:=ench-.
23
Can you tell us whether t:_hat is the 10,.000 mortar
24
,.
~
. -.::::
~:::""'
rounds, as well?
25
OAI.It GCNORO ..
e.
I
~~
105_
Yes.
2_
Did you convey this to Hr. Sogha:oalian?
'A
That is 10,000, 81
r.'lr.'l
...
mortar.
~er
quantities
-5
said I .received a letter of intent- a:od that the

s tollows.
l~tter
This
.of intent is dated June lOth.
Did you have any face-to-face meetings with Ur.

.
...
Soghanalian. or aJ)y of his representatives .in the
period of_ tiF&e?
interv~ning
9'
In the interveJJ.ing period of ti_me between when?
1Q
Between the Ma_y 26th Telex and the June 30tb -letter.
11
Duri:og that tJme, had you had any face-to-f,ace deal_i:\gS 'Hith
12
!{::-.
SoghaJJ.alian or any of his representatives?
13
l.
No.
14
On the
15
te~aphone
Yes.
17
--,las there
..
19
20
21
22_
23
24
........
25
~onversaticns
tbat took place that
nont~--
16
'18
...
anyb~dy
nonitoring tbo;>e telephone
caLls, to your knowledge?

A
~o
.,
After receiving this
~u~e
30, 1977, letter, wbat
did you do?

A
I telepl:lo:oed Hr. Soghanalian and confirmed tbe
ar:1oui1ts, the qua:otities, and said that it' looked as t~ough

these were the
Q
quantiti~s
that would be involved.
Then what happened?
OA\.(. GCNORON
106
1
--~;:~
'
2
3
Where was it to take place?
Inspection for the machine guns would have taken
place at the site of manufacture in America, and for the
mortars, in Portugal.
manufacture?.
th~
site of the
Well, Mr. Soghanalian was still reticent about that.
10
He said it was in America, but he said he was a bit
11
reticent about actually specifying.

Eventually, he told me it 'h'as Albany.
12
.,
What were you told was to be
Nu~rich
13
Is that the
14
Subsequently,
15
16
Arms 1actory?
jes, I
found that to be the Numrich
Arms actory in Albany.
Again taking this step by step and before you get

approxi~ately
te~ephone
17
to that point,
when was the
conver-
18
sation with Hr. Soghanalian subsequent to the ,iune 30th
19
letter?
---
20
21
22
23
24
"'::i{ff:
25
-~-
Yes.
.Between the June 30th letter and the .St.h'-_ __
of July, the Embassy had wanted to know where in America

they would be traveling to because they have to make
arrangements diplomati~ally for the mi1~tary attache to be
seconded to the Mauritanian Embassy in Washington and it ~as
obvious they had to }~noH where he \\'as going to go and !tr.
107
1
.......
(
_S oghanalian then_ told me it was going to be in (il_bany.
Cbronologicall~,
wb~t
happened after tbt
con~er-
Incidental_ly, let. me stop for one second.
I keep
sation?
4
5
-asking you whet_her various telephone .conversations \'>'e_r e_
monitored.
start until- some .place _l ater, so I wi'll save t _irne ill. asking
that_ q_uestion.
_I. gather _from this tbat the rnonitori_ng did not

-
can yoo tell me wben it was it be9an?
10
11
12
Yes.
If
an~
con~ersations we_~e
wil_l tell you a t_ t _he t _irne.

conv e_rsation
13
14
tb~t
wa_s
If we are tal)<ing about 9- te_lepho e
r-~oni to red,-
16
f7
18
19
20
tell _you.
~~i_ ll
fto\'1 tell us about t _he ne~t conversat_i _on.
_I had many conversations wi _tb !:ir. Big a igno::1 in

-
15
mon_itored, I_
that b_r_ief per_iod of t _i _n e al'ld Hr. Bigaignon was very _a n_xious,

obvi~usly,
\l~s
he
that t _be diploma tic- con:)ect_ions he bad established
.not going to be e_::-:posed to tbe wrong sort- of ;>eopl e a _nd

as~ed
my opinion of !1r. Sogbal)alian._ And
t said l
))_a d
no r<::ason to doubt a nythi_ng t _hat Ur. Soghana_l iall. had said

to rne on the telephone and I accepted h_i_m at ~ace ~a_lue !na
that we would soon di~co~er' wb~ther, in f~ct, Mr. Sogbanalian
21
\'laS
able to per_fot'n., as he had _indicated he would
perforr:~;
22_
that _is, .in terms of t:he inspection, a_n d w~ could make ou_r
23
deci_sion after \Te had _inspected t _be r:'\aterial.
24
~
- ~;;~ 7
25
l felt it was right that we should proceed to
108
or-'~'-:-~
inspection, as we had the assurance of l-it:. So9hana.iian that
he could s}low us what was required.
Wbat happened next?
Hr. :sigaignon_ 'then was concerned t_hat there rnight
]:)e a possibility that
api'roaches
-i
intt:oductions and "Vlha t could we do to overcome that problem,
and I said it- w-as a commercial problem one had to face in any
transaction.
10
11'
'12
,.10
~r.
13
14
~o
So ghana lian_ would make di_rect
the l-1auritanian Government -subsequent to our
...
But agai%), -I felt that .Hr. Soghana:lian--- l1e
could judge the i_ssues at a later date.

Q
II) oth'et: w-ords, you \i'Oul:d bav.e no assurance. in
dealing \':i_th anybody that they rnight I)Qt dea_l di_rect_ly wit_b
the t'art_icula_r goverl')rnent or try to unee.rcut you on price?
-Is that- t:ig1;t? That w-as OI)e of tbe risks involved?
I
1516
17
18
19
20
21'
It i_s a t:ist--col':'lt.":ercial
ris~--but
ii:t coMM~rcial
transactions of this type, t}lere are certain codes o.f boner

that- one observes and -I have never atter:1pted to circumvent
'
peopl_e I
have
d~alt
with and I always ende-a.vor .to give people
the benefit of tbe doubt in a

Q
situati~n~
)."ou do understand, though, -that t_hat i_s one of
the risks if yo~ are dealinri witb tbe governMent? ~here
is
notb_ing to _prevent someone el_se from dealing tdth the
22
government?
23
I didn't have a written contract, which is an
24
--~:::.
exclusive agreement to deal
25
~'lith
any govern_ment in tbe world.
.
;r~
u
8ti'IT
TOio4
,-RI[OMAN ~ '-OMSAR-01
' OAI.C: GtNORON
109
1
in an_y way any kind
else?
: ..9.
4
5
the Hauritanian Government.

A
That is correct.
~ny
prior dealings with
Is that- correct?
But Mr.
Soghana~i~n
never indicate
10
that .he had ever had -prior dealings with tbe !1auri'tanian
11
Government, either.
13
Q
wit~
oid be tell you ''hat- other govern_nents he "fas dealin
on other arms
~atters?
Good heavens, no.
15
'l'hat is the kind of thing that in this busi:)ess -?cu
.;
as~~
do not normally di_scuss.
did~
14
17
hi.m.
I_s tl).at correct?
I t_hin_k one disc',lsses it, but
pro~?.-hly
18
'
particularly when one is getti_ng
19
sta:)tial i_nvol vement in terms of contract vol une.

Q
20
21
invol.v~d
i:n a fai_rly
,to.
whe~e
\ole made the ar:-ange_rnent .

to meet
~nd.wh~re
Nr. Sogbanalaian told
23
24
for us to stay in a botel in t1ashingto:'l. and I
25
sub~
~~hat- happened next prior to your trave.ling to
me
.......,
r.ot d_irectly,
Mial"li or to the United States?
22
~-
You h_ave al_ready told us that you })ave no knowledge
16
But- in_ my discussions 'tdth Hr. Soghanalian,
either way as to whethet be had bad
12
:~:7
a ::11on-cor:lpetin.g agreement or anything
,.
No.
o~
be went to extreme 1 e:r1gtbs to prove his commercial abil i_ti'es.
,,,..,h
'"
Ana: you never obtai_ned from Hr. So<;bahal_ian
to go and he had made arrangeMents

spoY.e to !1r.
Bigaig!'lon ancl_ passed that informnt_ion on, .and we all duly
OALC GEI<CRON
~~~
110
assembled in l~ashington, I think, just after American
Indepe~dence
Day.
Whp was it that \l'as there in
wasbJ~gton,
\-:hen you
say "We all duly assembled"?
~1r.._
With whom did 9ou meet in
'!'he of_ficers of
Qho was that?
Mr. ~ill Holcomb and Mr. Beynold 8illiams.
\~as
Did he
Yes.
Hbere did tbe meeting tate place?
10
Bigaignon and myself and Captain 1\,nne.
Q~C,
~ashingto~?
I~ter~ational.
Hr. Soghanal_ian present the_re?
11
12
.......
"
13
14
17
subsequently?
lt:l tbe ?Jarriott aot_e_l
15'
16
~ppear
Soghanalian
~ace
be_
=i r s t
I
t_i_rn e :r rn e t Hr
to face.
'Yihat \'las discussed at tb_at ti_r.le?
Hel_l, l)Othing at that i_nstat).t t-ir;"~e.
'~e
later had
18
19
20
discussions
i~
the
eveni~g.
t~hat
.A
The inspection sc.bedule.
Q_
~iho
~::ell,
was discussed that- evenil)g?
21
22
said wl)at?
Hr. Bigaigt).on and Captain Anne and mysel_f
23
we~t to l:1r.
::.
l;:;:
~- ;;-.:;;
Soghanalian 1 s room and Mr. Soghanalian explained
24
we ,.;ould be. leaving the next--I think i t was the next rnorning
25.
OA\.C: CtNOAO"'
--
111
"1
2.
..~
3
.4
That \-las_ on. the 6th of July . And then Mr.

Soghanalian explained we would be leaving on tbe. 7th. of July, .
early in the morning 1 from the Hashington National Ai_rport
to go to Nurnrich Corporation jn Albany.
price?
bid you
'1'.
' Well I
..
ag~ee
any discussion tben
on
p~ice
r~lating
to
at that point?
I
'
the figure mainly that ~was-: conce"rned.-,~s;:.what.we
had originally based o~r p~ice discussion on, $4,700 apiece,

and ii;. was my .im'pressio'n-:at":::tl)at. tiroe;.tha't~ tbat_,~cov.e:red... ,..,.,..,, ~.,
the complete weapon 1 tripod an'd spa~es. 'I'ha t- \-las 'for the
11
.so
12
Bro'tV"ning.
.14
15
Bro,ming HBH2, and the figure of $1,800 for the .30
You say i t
irnpr~ssion up
\-ias
your impression.
It was your
unti.l \ol})at point i_n_ time?
Unt.il Hr. So_gha.nal ian to'ld r.\e that- $4, 7 0 0 Has
16
only for tbe r.lacbine gun and that the tripod "-'Ould be an
17
additional cost.
~ell ~ou
18
Rhen did he
19
In .Hiami.
20
Did you go from the r-:arriott right down. to
that?
No.
'
'
21
22
hav~
10
13
'
Did you
':::
~ie
went from rt_he l-1arriott- to Albany, and
f~orn
23
,i\lbany to Portland, and from Portland to Connecticut, from
24
Connecticut to New York to Miami, arriving in Miami on Saturda.
' --
~"
mo~ning
,.
..
at about 3:00.
112
Did you say Portland?
Portla~d,
Maine. Yes, that's right.
MR. RICHMAN:
,4
[Discussion off the record]
HR. RICHZ:1AN:
Off the record.
Let me run through this and we will
take a break for about five or ten .minutes.
you want, we will take a break, if you are tired or
whatev~r;
Any tine
otherwise, we will go until I get tLred.

i
10
11
Tell us
~d:t.at
took place in Albany.

A
He were met by a car from Numrich Corporation.

were tat-en to Numrich
t~e
12
.# .......
Sequentially, you went up to Albany.
\o7here \-."e
Corpora~ion,
13
r.1et Hr. Ira Trast, the president of the cor.\pany or vice
'14
~resident,and
we were shown the HBM2, .50 Browning machine
15
gun on its tripod, brand new, and ue \:ere also shO'v.'n t.he
16
\-:orkshop where they
17
sho\-m the tripods, a very ,considerable quant.ity of tripods--
,s
all folded down
20
21
22
23
. . 24
;
sho~.,.n
the assembly of the

tJe
th~
flat--,t.l3.~tripods.:7,i
We Here
19
manu~actured
\~ere
barrels, and
\-:e
were
all the spares that they had for
:..so or the manufacture of the .so. ('
sho,.,.n a vast quantity of the
sp~res
..__,
for
the .30, but we were not sho'v:n t.he . ~ 0 complete

Q
Hhy not?
Did they indicate to you that they did not have it
don't know.
.h~
..-
25
..
0"\.C: GC:NORON
..
or did not manu_fact\lre .it- or what?
_2
:, I
'.
.No.
didn't
s~
questions
was talking only
to .Hr. Soghanal'ian. and zfr. SoghanaliaJJ,--- He wa s dealing 'd th
,4
Hr. Trast a_nd I didJJ.'t want to insi_n\late r.iyself in any
.s
conver s_a tioJJ,_s di_rectly wi tb M:r:. 'I'.rast, because I didn t waJJ,t
to offend Mr. Soghanalian
~nd
his position as
~upplier
from
tbe Numrich C~rporation~

8
an ag.reenent on pr:ice with t _be nauritan_ian Governr.-:ent on
10
an_y of- tbese _items?

~es.
11
12
......
At_ t _bis poi_n t ,in time, had you reached or negot_i _a te
Ye_s, we })_a d been given a -figure original__ly,
and then wh:en the
r_:aur:i~anial'lS
discuss .ed i _t t}:ley t})ought i _t _
13
'"as too r.lilch, so we lowe_:- ed _it aod ev entu_a _l_ly ended up "-_i th a
,14
figu_r:e_ of $3,600 for tbe co:r.pl_ete uoit, plus the

Q
15
.16
~~ben_
<lid you reach -that
ag::-ee;-,;:~ft
frei~bt-
cost
of approxi_:-:'.atelS
$810.00 a Uz:'l,i_t, plus fr eigl:lt:?

i _n Ju_ly.
17
Later
is
SQ a _s of tl:le Ju_ly 1_1 th document, as of t _b_a t point
OJ}
.,
19
"20
-21
22
23
r
!.
tir.~.e,
you actually did not have a .firm price \lith the
Hauritan~an
*::!.:
2_
5
You were stil_l negot.iating wi_tb th _e
l-:auritanian' Govern_m ent on price?

~
~e w~re .negotia~ing
:aut you had nothing firm i _n wrl ting?

No.
24
r~
Gover:nr:tent?
a round f_igure of $9,000.
That was---
Do you have ant evid~nce of ~n~ of t~ose
'.
-'----'-----'=- -- -
- --
-----
114
1
~~
with them?
written back and forth, or was it all done verbally?
3
4
privy to all those discussions.

Q
What else happened in the Nunrich Arms visit?
We had lunch.
Other than your seeing these things, was anything
else done
No, because that was not
10
You simply looked?
prerogative.
your visit and left?

A
He
13
What did he tell you?
14
He thought that it
17
~y
You saw these things, completed
12
16
asked llr. Soghanalian the delivery rate.
wou~d
be around--I think--he
I
S<lid--- eHe:::~_.f?E?C!uc~~io-n --:ate -~:as. so~:~~~inl _a-=_~~~d-~~
f :no.nf11~- ...an<i-~i'-t.hink
........ -
~:e said thnt that_'<-muld obviously tak~
........!
~r.o. x_~oa~el'y :foux:-r..-o~~~~~--~d
we did not Hant to wait fou!"
18
months, probably, and when would thay starf the assembly of
19
the order.
Ne could take some from stock and Ur. Soghanalian
20
..
discussed about prices or anything else?
15-
....
o~
11
All done verbally, but Mr. Bigaignon certainly was
. ,.....
Do you have any correspondence or anything
21
indicated that it \.;ould be no prohlen to fulfill the
22
date.
23
is what we wanted to
deliv~ry
So over a period of a couple of months, because that

finaliz~---
24
How about tripods?
25
That was all part and parcel of the order.
OALC: GtNORON
That was
-----------~---
115
1
..
...
all inclusive.
Did they have tripods in stock?
Oh, yes.
Do you know at what price or ....-ere you not involved
in tbat?
'
didn't discuss the price with Mr. Trast because
that, again,, was not my prerogative.
prerogative.
10
Did you know if they had as
That was Mr. Soghanalian'
~any
as two
~r
three
hundred tripods in stock?
11
j\','/~o
They had a considerable number of tripods
in stock.
12-
-.~
No.
ex~ct quanti~y
I didn't know the
they had in
13
stock and the questions that
.14
ask9d and Karl Bigaignon asked of Mr. Soghanalian were around
15
the de_live_ry proble_m a_nd \'f'e ~ere given to understand that
16
the delivery would be within the r~quira~ent of the Mauritania.
17
Governnent.
asked and that Captain Anne

.
_...
18
19
..:
20
........
25'
..
reached later in
including the tripod?

A
That was inclusive of the
t~ipod,
between Boca Investments and the Mauritanian

Q
23
24
agre~nen~
late J'uly for 8,000, ....as that including the tripod or not
21
22
When you said you had an
~ee
.. l.ng.?
~.
$8,600.
That was
Govern~ent.
"hat else, if anything, ha~pened in Numrich at your

Here there any other discussions of any significance
about any of the items?
OAI.C C:tNORON
1)6
1
.":'!."::;.
~-~......
~o.
Qe had seen wbat we
earn~
to
1n~pect ~pd
2_'
Captain Anne said that he
seen, and t _hat- he was sati's_fied that: Numricb could produce
them wi_tb a _n obvious tremendous stock of :part_s, et cetera, a n
wa~
satisfied with it,
wh~t
be bad
5
6
-,
.., ........::.
flo
~he_ re
10
moment.
11
the
12
lil')e
~1e
ba~r~ls
you actual_ly see tbese guns bei%}.g manufactured(

'was no production l _i _ne i _l') ,process at- the
didn't- .see a production l i_ne of tbem. !ie sa\<l

being produced, but we didn't lee
production
up.
13
Hhat_ day of the week \-las it: do you recall?
.14
Yt is not--if I can just relate the
condi~ions--
15
J thil'.\k, gel)era_l_ly perta_il')i_ng to nanu:acture of t _l).is type of
16
esuipn.el)t, t _hat_ they don't. produce_ unti_l
17
order, because it is not thought advisa_b le
18
rnents for any government factory o~ cornrnefcial factory tb bav~
19
t _re_nel)dous stoc};s of weapons in_ case of any burg laries.
7.3
24
25'
'
with it.
Di~
22
that part: of the inspect_ion . wa s com_pl -e t.e and he "'as s atisfied
21
be. would si<]'nify to tbe -Ambassador in t:Vashington tbat
20
( ,,
.that
th~_y
b;r
h_a ve a fi.rr.'l
tnri.ous go\.ern-
A coup?
That is r.'l;y u_nder_stal)ding frol':'\ dis:cuss_ions "'ith
various tJal')ufacturing cor:1panies 1 so that was%)' t an unusua_l

situation.
Q
Is there (lnyt_hi_ng else that you can thi_n_k of t:::_a t -
happened in Albany1
OA~t
GtNORON
--------
117
A
No.
l;tas there any discussion as to del_ive_ry rate
relating to tripods?
A
No.
-tt ,;;ras clear_ly understood that the tripod, the
gun, the spare barrel, thespares, were supplied as one group.

Q
Let me digress for just one moment- with respect to
tbe formal contract that you supplied, \"lh_ich has been rnar_ked
as Def endant,s Exhibit
'I'ba t
l~o.
3.
for_nal contract re_f ers to, under "Del_i very,
C.l.F. Mauritania."
What do you understand that term 'to mean?
A
~1auritania?
In
n.
Yes.
i1hat about "Hithin si_xty days of receipt of a:)
acceptabla letter of ctadit and
e~port
license
bei~g
granted"?
0itb reg~~d to tbe use of the language ~~a sep~tate

I
letter of credit, ,.,.as that .your_ norna_l procedure in t_ransactions of this type, to use a letter
~ho
.
...
o~
credit?
Yes._
As opposed to cash?
Yes.
OoH about '-:it_h respect to the e~port license_?
normally obtained
~
~he
e~port
license?
l\.l\lays tbe supplier
OALI: GC:NDRO"'
118
1
---
-~-
3
4
'.
..
..
Ih this type of transaction, when you proposed what
is in Defendants' 3.
Who was the shipper?
He was to be the shipper?
Yes.
He was responsible 1or it, at any rate, to
Hauritania .
As opposed to Boca Investnents being responsible?
10
Yes.
11
Have you ever been involved in obtaining an export
license?
13
In relation to this instance?
14
In relation to any transaction.
15
Yes.
16
What is the procedure in obtaining an export
lie e'ns~, nornally, if there is a standard p:-pcedure?

.....
;a
'Ne
19
Along with an End-User certificate?
20
Yes, always.
21
Have you ever been involved in obtaining an export
submit it to the government authorities.
22
license with respect to any of your dealings with regard
23
to Hauritania?
25
In what transaction?
24
.....
........
MR. ANDREWS:
Mr. Soghanalian.
17
Who was the shipper in the transaction?
12
"'::::
No.
Have you ever been the shipper of any arns ~aterial
CALC GCNORON
119
!1'
-
1
shipments?
,.
--
:
:; i
.. '
I~ .. ,
3
4
No.
Q
Ha~e
you ever been the supplier of
~rms
material
shipments?
:.
..
Yes
Approximately how.. many times have you been the
,.
!~
supplier, :as opposed to being a broker or rn.idd1eman?
I~
0~ thre~
'
On
10
13
Yes.
Q
you obtained
On t.be. th:t"ee occasions i_n '-:hich you ,.;ere t_be
16
supplier, were you al_so the sbippe_r, O:t" did you b.ave another
17
shipper?
19
..
No.
is
Q
In the situations in whicb you were to be the
20
supplier, did you consider that ~f you were unable to obtain
21
an export .lic_ense as the supplier t_hat tbe. transaction
22
23
24
25
..
~1}:\icb
No.
Q
..i
Here there any other t_i_mes in
tl), e ex"t)ort license?
,14
:I
three of those occasions, did ?ou obtain
the e_xport .lice11se?
11
12
~ll
occasions.
b~ consider~d
to be vitiated?
"~-.ould
In other words, was tbat tbe
position you took with reg~rd to tbose t~ansactions?

I
am
not as};ing for a 1 egal opinion.
asking for your state of mi11d.
___
1:)~).[ ~t_NJ)RQN
am just
120
~
1
2
o~t
' .
of the
co~ntr~
Let.
Yo~ ca~'t
~s
get an
e~port
license .
~o~
can't
mo~e .
of origin.
move, tben, from ihimrich in
~l_bany
to tbe.
next Plac~ you wen~ ~ft~r leaqing there.
Marernont
Qbere was . that
I think it
Rb9rn did yo~ v~sit there?
.9
~-
Tbomasian
Hdll, Ur. Soghana_l.ian had a m_e et_i _ng with
Corpor~tion.
located~
wa~ ~o~tland,
Majne.
'
10
11
12
13
~. ~
'14
15
they sudde:1_ly appeared ..... it_b an !160
it and .
Q
16
17
18
19
20
p~t
sa,.;
. th~r:1
gun and st _ri!>ped

'
I
it togethei.' again and then 'tt'e al_l .had lunc:h.
2-160 or
~achi.ne
~l16?
Ill.
!-!60.
Tb~n
A.
':i:hey showed us a_r.ound t _he. factory \.,.here we a_ll
ther.~
21
what happened?
al_so nanu_factu_r.ing 50 ba_rrel_s,
H:B!~12
Bro,mings.
'i'o~ say you sa\,. tbe.m rnanufactur ing 50 barrels.

D-' d _you. se_e tbe_l':\
22
a nd
r.~anufact~ring
a ny other portions
of the machine gun?

.23
No.
..
...
2.4
.,
....
;:~~
'Tben what nappened?
25
..
-------
---- - -
-- - - - --
OM._C: GC:NORON
-------=----==---=-=----"---==..:...--'------=--=--::.._c-'-''-'--~
- --..:..:....-..:=-:.......1
.e.. .
1
--
hotel_ i%)., . I th.ink i t \-tas, :Boston.
ar~ange4 fo~ ~s
to go there.
~l)~t
Stayed
Wh_a t kind of aircraft \~ere _you fl _ying, cornrner ical_
or _private?
~-
12
did you do there?

overnight~
We.f-1, on or).e leg .it_ was a private aircraft.
cha~te~ed
It- wa s
airdraft.
Ne were al_l very i _m pressed .

Q
11
....
Hr. Sogh._a~J.alian })ad
10
-.
~ell, the meeting finished nd we w~nt on i~to a
te t lt -1
121_
The%). what
happe~ed?
you stayed tbere overtlight.

~lent-
You say you went to Boston . and
'
Tb.'!n ,.,.hat?
13
I>.
'l'!)en_ "'e
.14
~:ie_re thet:e a_n_Y discussions relatii)g to tbis matte_~
15
of any
16
17
'
18
19
20
sig~i!icance
to Connecticut--Hart_ford -.
in Boston?
'l"he_y \'lere just_ gen.er'a l eiscussions ongoing I C.e_l _ivery
and' H~. Soghanal_ian said he. would le_t_ us -}:nO'tl

,.:hat deliverv
.
~
we
~ould e~pect
of tbe BBM2, .50.
~here wa~
a little hit
~f
un_rest .a bout havJng to go _ins:>ect it.

'I_ 1 r.i just reca_l _l _i _ng t _he instant mo~e clearly.
-I
2_1
22
23
...
.: . ::.
~=:-
24
25
Numrich Arrns in th.e a _f ternoon_ to the. Boston botel.

~nd
to :-!a remont.
then the ne_xt day, i _n tbe next- morning, ,.,.e went
.
.It is just a recollection o .(:.. rnl.ne,
of the tir:te
frar.'le t})a t - .-I art tryi_ng to work out in my mi_nd.
OALI: CtNORON
122
.e.
1
-'
..
Anyway, I 'rn .s-aying, discuss_ions_ centered around
delivery and trying to establish what tbe total t>rice_ "-'as
goi:ng to be.
Hr. Soghana1i'an said be wasn't quite sure \.,.hat it
would be
Marernont and see the !-160, and

we didn't really want to go and
.-
se~
a~
,.
...
tb~n
the H60 because it: wasn't
that time and
he said we would .be going to
a requirement we had.
He said, "Whi_l e _you are a captive over here, I

.' might as \'1ell show i t to you."
!-1r. Soghanalian was cal_l il')g
10
the tune because -he was organizi_ng the t_rip in America, ax,d
11
we \... ent to
12
brief luncb, al')d t_ben
1-~arernont
Cor-poration and we had lunch there, a

He
\;l~_e:1.
uent on to--- I think that's
13
1:1e
,14
fle.w to Connecticut a_l')d Hei)t to see the Colt
15
-factor~',
.16
!:!ons-ie-Jr Bi<taigno:l and Captai!) l.nne were .a l_itt_le bit
17
18
.30.
'l..,.~ich
i_s -again not: sonet_hing- \;e '1.-:ant_ed
. _ thougbt_
f-~~
~o
s~-e
and
d_ise:;.c~an.t
-,
\le
'"era: go).ng to see_ the ;30, hi)d it didn't
19
20
Mi. Soghanalian
_21
22
24
_j,?
25
'
"It is being org&l')ized.
It
is being organized."
And so
23
':.';.
~aid,
the
~rip
\ote
had to go along witb the next- leg of
and, after we bad been to the Colt factory, Monsieur
Bigaignon got very irate in the off ice of the Colt factory
. OM.C GI:NOAON
123
'
'.
because we really didn't want to see -the Colt r-160-A_l, and
so then we were driven bacK from the Colt factory to the
ai~field
Gew
Khat did you see at the Colt factory?
A.
Coit -~evolvei'S and ~60-Al.
'
.I.:r.
....
.~;:here
Hr. Soghal)alian bad
Ramada
~nn
'
did you stay i_n Uiami?

arr~nged
t_bat He stay at tbe
in Miami.
11
What tben happened in Uiarni?
12 '
On SaturC.ay aft.ernoo11, Hr. Bigaigl)on t_ben
v~nt
'back
13
to Pa_r is e>.nd Captai_n An_ne and rn_ysel f and Hr. -Bigaignon "':ent
.14
to
15
attached to his hor:-.e in l!ibi_scus
16
!lr .
17
Santo Dor.1ingo to see tbe .,30.
~r.
Soghanali~n's of~jce
Sogh~nal
in tbe
~ate
Isl~nc.
norning.
It is
And I discussed '7ith
,. ar
.... ~n;:>,
ian, Who
_. \,as -a
.. .r.l._n';::l
_ ,..an-..,.,...,~
... _-.: __.........
.~-he-n
..__ -
When we inquired why we had to ""go to
18
~o
... _
,.,_ o
-,
San~
19
Domingo, Hr. Soghana1ian said originally be was getting t_hem
20
from
21
Guard decided tber \:eren't going to relcass the .-30.
22
Therefore, he \-las going to ta:J<e us to Santo
23'
the_ 30.
25
th~
National Guard in Washington and tben the
Do~ingo
Hatio~al
t_o see
l said, "Are they in tbe sa_me condition as the
24
-:~
8B~Z
we have seen?"
~
u
8EI'IT
--..
'_It was really a waste
of time.
8 '
10
..
to Miami.
'""
~ork
and caUgbt an airplane in tbe early evening froM
F'FII(_OMAN
TON
~ ~OMBAFIOI
DAL( CltNDRON
'1_24
~-
..::::
l, ~~
condition sou bave seen tbere."

l
said, "Welli l will
ha~e
to go to talk to
CaptaiiJ. Anne," and I
-5
.rang the Embassy fror.\ 1:1r. Sogbanalian _s office .-and told t _})e_m
9
10
11.
Then, during ~he course of tbe afternoon, l

endeavored to establis}:l. a price with l-:1r:._ Sogha_nalian, but aga_l r
he was--tbere was a lot of commotion and goings on 1n the
office a_nd it was -a bit di"f_f_icult.
t~
discussing
,14
15
th~
E~entua_l_ly,
we got aroui)d
price and the COIJ,tract.
We '\:ent over: t _he contract.
12
13
and he
what he was doing.
-;
8
explained it to Captain
t:~.nne
-.::.'~
1hey will be jri tbe sarne sort o!
He said, " _
Y es-.
ar. Pol_la-rd guot_ed
freight r:ates_ for the Mortars

fror:'l nauritania,
said it .....__,.
\-.'ould
.
.
.be $2,000 and _i t ,.,.ould c<;>st $53,000,
__l.S
dl. -s cusse'd -c'h'
\o:l.""-h.,
..._.
~: .r.
an~
t.bi_n~t..i._at he-----
d a t ~h
So<J.h ana_1';l.at). b. . e_f'ore .h e arrl.ve
... a ~..
dec i _s ion. . 1-~d t _b _e n !~r. ?ol_la_r d quoted ~-be fr eigbt ra t _e for

16
the .r.-:achine guns fror.t
Ai':"' :~r ica
to naur i tania.
17
18
'
~ot to e~ceed sj6,000 .
How about the basic price?
l~r.
19
'
'.
20
Sognanal_-ian .sa id he still h_adlJ' t det_er:mil)ed
21
the price for the
t~ipods.
2_2_
Q
Who detert.ined t _he pr:ice for the basic -weapon?
$4,700
Did he tell you why he had not determined tbe pr:ice
2_3
.:.,,
,-_;:.:e
-;;-
24
25
"
..
.. . .
..
125
for the tripods1
No.
Did he indicate to you that he had the tripods in
,l;;~
4
' .
We had seen them in the Numrich Arms Corporation.
He did not own those tripods, though, did he?
~hat
He told you he owned them?
He told us that he owned a share of Nurnrich.
10
Did he say how big a share?
11
No.
Do you know \.,.hen this r:~eeti:ng in Hiat.'l.i too}: place?
12
13
his possession?
S<l turday,
Q
~hat
the 11 t_b.
happened then?
\\ell, the details
16
17
is what Mr. Soghanatian told us.
Do you know tbe date of the meeting?
14
15
\'1
ere fill ~d in on the co::-.;:.::-ac\:.s, . sucl
as \.,.a ,.,.ere able to fill in, the quantities and the price of
the mortars, \-l'hich was finalized, and t_hernrice of the HE}t2.
18
!"lr. Soghanalian said be would advise us of the ?ric

19
20
21
for the tripods.

Q
Then what happene~?
4!r. Soghana_lian carried on, organizing a trip to
22
23
Santo Dor.tingo.
Q
..
24
~.
''~:-
25
in time?
Was anything signed in the contract at that point
126
. . :~=~:
'
..
No.
What happened next?
~ell,
Mr. Soghanalian---
We went back to the Ramada Inn hotel and we all assembled
'gain on sunday in Mr. Soghanalian's office.
So you assembled again on Sunday, the 12th?
Yes.
And did what?
We really sat about and waited for somebody to say,
10
"All right.
11
12
...
we had some dinner.
13
Ne're off.
We're ready to go."
Did you ~hen leave for Santo Domingo?
On a Monday afternoon, we suddenly left for Santo
Domingo.
,14
By what rnaans of transportation?
!1:t.
Was tb2 sole purpose of going to Santo Domingo to
15'
16
17
Soghanalian chartered an aircraft, I bel_ieve.
inspect the .30 calibre machine gun?
18
19
As far as I was aware, yes.
Hhat
We arrivedat Santo Domingo.
Tell us, if you wbuld, what took place in santo
bappen~d
then?
20
21
Domingo?
22
;.,.
tle were met by some arr.Jy people on the air strip
23
and
.,
ta}~en
to the VI_P lounge.
24
..........
...
---
25
.'
Do you remember the names of any of the army peoplel
127
,.
k=~
....
No.
~b~n
i~e
' .
us detai_l _s of the ins-pection.
l~hat-
Hr. Soghanal_ian_ sa_id, "No.
tomorro~,
"l;;e_l __l," I
14
'!'he
18
19
2_3
"
'
24
..-::;~
"'-"'.;:.7..::
25'
t .,
what happened?
ne~:t
day,
!~_r.
Sogbanalian \.;ent .,.,.it_b Captain
:1 thinl::
:r el iz
their in_s pec\:ion.
I 'n not sure whether tbe.re i _s a day _i:o \:bi h
Rodr_igue_z.
t _bey went on
soneth_il')g d_ien t h_ap:>en because the i_nspect_ion, -I think---- I

a_m not g:ui_te_ sure if. tbe inspection o;.tas Tuesday or ,;;ednesd_a _y,
but one ot the two days.
nut .on t1edne_sday, t _he
20
22
said, "as long as Captai_l') Anne se e_s t _h e
!>.nne and, :r tb_i_n_k,
'
21
1n tbe numbers of
weapon_ry and can assess t _bern, t _hat i _s quite i _n_ order."

~ben
17
'
.
Q
16
are going to .i!)spect
and there is ~ bit of dif~iculty
13
15
't~e
COI':\e?"
10
12
occurred tben-?
peo_pl e pe:t'r.~i'tted to inspect, a nd would you mi_nd if you didn't
I
I
t _ben_ \'<'ent to t _be hotel, \'<'here we were put: _i nto
various rooms, and I th-en waited for _t.1r. Sogbanalian to give
..
wbat happened?
11
_i_:os~ect_ion
had been
r;.~de.
On ftednesday, I was inforned tbat Mr. ~ogh~natiari was going

on .in tbe a_i _rc_:x::af-G to Q\ratema_la.
At this .point, bad Captain Aone finished 'his
inspection?
A
Xes, he bad.
O.o\1.1: GtNOROH
--
--
- - - - - - - ------
r=~==~-:
128
Did he report back to you as to "'hat he had
I had a conversation
'\-1.i th
seen~
Captain Anne and he said,
"Well, he had been shown---
"A
What had he
s~en?
He said he had been shown various things, but as
far as the .30 was concerned, he didn't know what to say.
He had to make a .report to his government, but they didn't
'
look in the sort of condition that would be suitable for their

.requirements.
So I
10
"No.
11
12
13
14
l5
16
said, "What do you mean?

They are secondhand.
Are they not new?"
They have been used."
Did he see any .SO's?
He didn't tell ne he had seen any .SO's.
Then what ~appened?
Did he say he saw anything
bes!.des .30's?
He said h~ had seen .SO aMnunition.
were all aged and not suitable.
He said they
He hadn't gotten .approval
17
fron his government to inspect a~ything e}~e;

18
He felt everything else he had seen ~:as quite
19
pointl~ss because he just had approval to inspect the .50's
20
and .30 Btownings and 81 mm'mortars.

21
Then what happened?
22
1\ell, that presented -sonething of a probler:l, becaus
23
we wanted to 9 et back to Europe to inspect the 81 rnn mortar i l
24
~ H
'".:~.~~-
Portugal that Mr. Soghanalian was arranging and we had a big
25
..
OA\.C: GC:NORON
~- 29
.....
problem of getting off in Santo Domingo and getting back to

Miami and I did make inquiries.
Our inquiries were on a Wednesday morni~g about a
flight out and all tbe flights were booked because it just
happened to be the time of the Miss World contest and we
couldn't get a flight out.
are refueling at Cayman Islands."
We will get off at Cayman Islands and connect a flight ' back.
Can I ask you to ask your secretary to arrange a booking or
So Mr. Soghanalian said, "Me

And I said, "All right.
10
arrange a reservation of a Cayman Islands' flight to Miami
11
for Captain An_ne and myself?"
12
ae said, "Yes."
13
So I rang from the ai_rport in Santo Domingo.
s ~cr et _
a.ry
.14
rang !-!r. Soghanalian s home i _n Hi ami, spoke to his
15
and explained to her t _h e position, a:1d she then said ''~s,
16
zbe would
~ake
tbat arrangement.
She rang
17
hac~
and said she rr.ade a ):)coking from
18
t _he cayr.1an Islands, so that rather resolved the proble!:'. tb,_;.t
'19
\ l e
had been faced \dth a_nd t1e got off at the Cayme.n Islanqs
'
20
and took a flight to Miami and the connection from, Miami to
21
~ondon,
22
.23
1.
.,
24
';;~{!;7
25
; _rom London to Portugal.
~ad you agreed on the price of tbe tripods at this
!1r, Soghanalian still \1as not able to give a price
tir.:e?
of the tripods.
130
And l said, "all, in that event, we bad better

. ........
!,
' .
sign the contract on the understanding that it is subject
to. an agreed price on the tripods and t _h e confi_rmation by
raising the letters of credit for the quantities, and we
can execute the contracts here with t!'lose conditions in
mind.
7
8
9
10
..
A
bedroom.
It was in Mr. Soghanalians hotel bedroom suite.

Santo Domingo?
~n
12
Santo Domingo, yes.
13
.Both parties signed at that ti_me?
.14
Yes
{Recess taken.)
21
22
2.3
24
25
wi~h
ou~
chronology.
' '
finally in Santo Domingo.

You then went back.
19
20
Let us continue
-You have told us tbat t_be contract. 't:as Si<;ned
17
18
did you execute
l;7e signed the contract in !1r. Soghanalian s hotel
11
16
..,
Wh~re
the contract?
15
--
Where did you do it, then?
You
rnanag~d
to get back to
Miami and then you went from Miami to where, to London?

A
To London, to Portugal.
Bhy to Portugal?
Nr. Soghanalian had arranged for i _nspection of t _he
a1 r.un r:tortar in Portugal, as t _hey were being purchased and
supplied
fro~
Portugal.
OA~[
CC:NORON
131_
:e.
I '-1ou l ed 1 .1.: k.e_ you to te 11

_ us specl._ .J.ca 11
_ y.
You arrived in Portugal.
~:.
By whom were you met? '
We weren't met 'bY anybody.
f-
0e ~ade our
way
to
the_ Estor.i_l Sol Hotel, where l:lr. Sogl)analian had said we_
would _b e contacted by Hr. Harti_ns 1 l)i_s 'a gent, and that- he
had a.rrang ed for Ml:'. Ha_rtins--fol:' us to inspect the mortar
bombs.
'8
-Q
Then wl)at .happened?
't;le_ll 1 I tl)1nk \1e f__i _n al_ly a_r r _ived the_re on :F_r iday
afternoon and_ ~lr. Martins ar:l:'ived at ab~ut ._f ive-thirt_j' Ol:'
10
si.~
11
Q'cloc~
a nd _introduced hi_m , and I
s-aid, "A.re you
. ~1.r
12_
.He -said,
13
...
"Yes."
And :I said, "Are you Ur. Sogh_a nal ian's agent in
.14
tb.i_s business'?"
15
And he
16
said, "Yes," tbat ba was, had
ar~anged
f?r
the inspection a nd th_a t it had been set for !1onda Mor,ning.
17
so we then had to \'ta_i t
18
Saturday~
and Sunday _in
Portugal over t .l )e \:e_e}:end before actually _i_nspecti_:,.g tl)e r.'lort :r
19
bor.&bs on Nonday .rnorni_ng.
20
2.1
22
~lhere did you i _:,.spect tbern?
.A
Mr.
Ma~tins
col_lected us in his motor car, toot us

'
back into Lisbon, wh~re we ~ollected or met Generai Rodriguez,

23
wa~
who
(
witb the hrmy.
24
~:~:
~le
...~-
""'._
then le_ft Li_sbon and
2.5
.'
: '">
U \..-
ol
ol
tt
Vf\ ~ ~-
)'I
,tl
<
_' , . o,< ,,
' -
> I '
< >
:.1 > '
~1ent
over tl)e br:ldge, over
----
132_
the _r iver to .T a<;us, which is about a_ half an hou_t:' s jout:ney.
_2
"e
~ventuall~
arrived at an
~rnmunition
storage
.de:t>ot.
Tl)is i _s a mi_l _itar:y a_mrnun_ition storage_ depot?
Yes.
"hat happened tbere?
:j
We
w~t:e ta~en
th~ stor~g~
to one of
units, wl)ich is
hal_f underground, whet: _e boxes of 81 rnm mortar a mmunition were
stored.
10
~as
11
Captain Anne ...:as, yes, of course, \\itb_ us.
Ca_pta_i _n
Captain
A~ne
with you?
12
...
13
z~nne
said he wo uld -lU:e to })ave a _look
.14
i _n on'e - of the boxes :a nd t _he people \~bo we_::-e worki.ng OI:\ it,
15
in
lG
the 1_id off, and Capta!.n A!:).ne car ~_ful__2.y
17
material, and i _t "t;as cleat: fz:om t._he
.18
th~
And be said, "Yes.
bo~~s and
0e
21
( .:::::
~ban return~a
0here had that
2_5
Tb_is is
_,
>
the mor-tar
on the box t _!lat
e;<act_l_~
'"hat_ ,.,.e \<.a nt.''
to tbe hotel.
con~ract
been signed?
OM.(.<: tN ORON
1
Yes.
24
~n::-k1nqs
.
....
cont.t:act .relating to t _h e nortar _rounds?
2_3
>
i_~ _sp ected
At this point in ti.me 1 did you have any signed
22
Jt.-
O?ened it, took
Q_
20
of the
_i t: \f as 1977 ne..r pl"oduction.
19
=.
un~~aled oc~
depot,
~ >.~
' -
<II
'
"''
t t'
'H~
., .,
t:
I >
'I'
<
'
No.
The negot_iation_s and t _he_ agreement and printi_ng
of the con~rac~ ha~ ta~en p~ace in Miami on a Saturday and,
'1
because we were continually wa _iting for r.~ore deJinite f _ig-ures,
'v-e didn_ t finally execute it- until Santo -Dom_i_ngo.

But- in Miar:\i, as a pract_icai r:fatter, you had not
Q'
10
reached a final agreement
11
on price?
o~
-.or ice?
On the nortat's, we had reacbed a
~inal
.14
tion of the 1{BH_2, \vobicb h _a d l>een :based on $!,,700

:nut as a practical
::~att_c_ r
16
can you say under oath t _hat. _you h:ad
17
on all the i _t _e!':ls _in_ the cor.t.:::act
'
l _ltb?
19
20
'21
22
23
at t _bat po_i nt in ti_ne,

ag=~~d
. h~
.
didn't
to a final
haq~ the
becau~e l~r.
finl price on that.
Back il). Portugal, wbat happer::.ed aft_e_r you in_s-pected
those wea:t?ons?
A
Sell, we droppad Gener~l Rodriguez off in his
24!
Hinister of Defense depot and t"eturned to tbe
25
tbanr.ed Hr. Z..!arti_n_s and nade OUt'
..:.::~~:
-pric~
_l.l)
Not- witb respect to t _be H-BH2,
Soghanalian said
Q
agreement on
.t'._nd in_ Hia_rni, \v-e we_re just wait_i~g for fi_nal con_f.i.rt~a-
price.
~lay
OAL.t- GtNORON
stil'l negotiatin
13
18
:EJ.
lia_d _you had final_ negotiatiol')s for both these_
15
I.
12
.....
as the contt"act for the
items in santo Domingo?
, ,
In tbe sam
ijBH2.
3
4
pl~ce
bacl~
hot. ~l
to -Par is.
and
.e
..
-.:
tbe mortars or the machi_l)e gu_ns?

~~e~l,
'A
I spoke to U.r. Soghanalian. on t_l)e. telephone
and told l)i_rn the Captain bad _b een_ pleased w_i th_ what- he had
seen in Portuga_l alJ,d \ras satisfied \vith the arnmun_ition that
we ins:pected alJ,d b_a d J::"eturned to his count_r y a_nd would, _i n
' .
7
8
9
10
11
12
13
...
Hbat IJ..ext. transpired ' in any wa y _relating to e_ither
'1
134
.14
due course,"' advise me of .t _h ei%' fi_l)a_l J::"ecot:'lnendat_ions ar)d

conclusion, and -I said, " _I don't k_now w}).at that will be, but
. _I
can 1 e t you k_IJ.OW \'1hat the ctuantities, del_ivery time.
require:rnent_ 'is as soon as 'I have_ received

. a conf_irmation by
way of letter of credit."
Q
To w!)om \tas that _letter of credi_t to go?
'A
rt- was from Boca :Inve_st;nents.
~ow
ware the gooas to be paid for to the United
'
15
~tade ;nte~national?
por~ion
Dy a transferable
Il'). ot_her \'70rds, ,.,.e_ra ,t_hey to get a l etter, of
'A
'I'.be_y ';1ere to get a l _etter of credit.
Let me stop you and digress for just
16
of tbat letter of credit.
17
18
19
~
t:'loment to
20
the question of t _hese othe.r'
ar~s
cc::ipa_l').ies.
21
Can Jou tell u~ why ~t is you did- not deal directly

22
witb !-!arer:\ont or th1mrich 1\r)ns o_r any of the otber cor-:panie_s

23
you stated manufacture these rnachiiJ.e guns?

I
...::::...
....
............
24
A
2_5:
..
Hr. sogbana_liaiJ. .held_ bi_n sel.f out to be a
1_35
1
--- ~
shareholder of Nu~rich, which manufactured the weapons.
2
3
4
How about Maremont?
How about them?
Did he hold himself out to be a shareholder of that
cor.ipany?
No.
~hy could you not deal directly with that.cornpany?
Hell, what I had said to Mr. Soghanalian was
'would deal with 'him and he had said yes, he would supply and
10
could supply az:td it \-lasn' t really m_y
11
introduced to various people by Mr. Soghanalian, to try to
12
circunvent him.
13
l~side
::~ocus
operandi , having
from trying to circur.\V.!::lot hi_m, fliY
.14
is:
15
Soghanalian, to begin with, icstead of,
.sor.1eon~
Hould vou
have dealt with
...
.
'
~o
gu~stion
like lr
begin with,
16
17
18
19
20
2_1
22
23
24
..;j1:,:
25
..
w~orn
you cay
A
d~rectly rnanufactu~e
tha product?
Hr. Soghanalian held hi_rnself out to be in a position
of disposing of the product.

Q
I am not sure we are comr.'IUnica ting .at t _he sane .
level.
UR. AJWREi;JS:
tlhy not
asj.~
companies until Mr. Soghanalian

HR.
RICHHA~l:
Let
hi_m if he knew of the

~ade
him acquainted?
me ask it a l.itt_le bit
differently.
OA'-C: CtNOFtON
---o;::.
what conpanies there were in the world that actual_ly mal'lufact~red the prod~cts for wbich yo~ were looking?
4
5
No, not -at that time.
@oUld you not have thought that yo~ coUld get a
better price. by dealing directly with the companies, as, oppose
to someone like .Hr. Soghanalian, '~ho was goi.ng to g~t new
goods trorn those companies?
10
11
!1o, not Hara_rnont.
.to Uarenont
15'
So in sur.lrnary,
I Soghar.~lian
yo~:r
"'a sl.""
basis .e:... or pure..
g -~ro.
\V'as t_hat be represented .hi_mself as bein9 a she.:r~-
17
'holder of ::~ur:~rich Arns, and th~_refore_ you fel-t: that .buying
18
from him ,..fas like buying d~rectly from tl).e !actories?
21
'ies.
He beld himself out .to be the owner of_
t;zas
he i_n fact_ the O\{~er of 10,000 pieces o5 l7'.o:rta_r?
It is
my
opinion, ba:ving now the knooo;...ledge that I

'
wa~nt.
23
do, that he
24
f~ho
'/).
The Portuguese Govern:-:tent, in
........
... -"=
25
10,000 ,pieces of mortar i_n Portugal.
22
..
didnt know we were going
.14
2o
--
G~
to Harer:1ont unt_il \~e ,.,.ere in Arnerica and ,.;e \rent from Boston
19
..
'Including l!a.rernont?
13
16
'!'hat is what Nr. Soghanalian held himself out to
be, in command of those goods, from the 'outset.
12
...
Did you make any investi<;tation to determine
vas?
OAI.._f. GtNORON
rn~
opinion.
137
,,
.... ....
~
'ha~e
been the owner of.
mortar rounds that were .being held in a Portuguese Government
mil'i tary arnmuni tion. depot?
~m~unition,
position, and although yo'l;l may hold title py_,payment or
pax.-t- payn').el).t, it is sti_l_l ,undex.- tbe control of the police or
military.-
,g
, lS
\dth
th~-
Portuguese
Government or could you not have dealt- di_rectly .\dth. the

'
CPortuguese Gover'm.ent to obtai_n -t_he sar:te__iteMs?

I could have done it, but X bad negotiated ~itb
1:3
14
direct~y
Why could you not deal
10
12
that is under totally strict military control,
military and police control, and tben you transit or hold
11
Because wben you purcbase f_rom a government any
'1\
..
Why would Mr. Soghanalian
Hr. Soghanalian and he beld hirnsel,f .out_ to 'be t_he suppliet: of

tbe
it
na~e_rial.
\ZaSn'
16
tiy prer09'at_i Va
?ort~gues~L
and had said he <ttas \:iJli_I).g to supply it, and

1
havi_ng 'been i:l)troduced to tbe
people,. to tben say, "I don't_ want. to deal_ with

I
17
Ur. Sogbal).alian..
"'ant to deal "'ith you..-qirect.
11
18
I
19
right.
dol)'t-
thin~
tbat- would have_ 'be:en c<;>nmercially
20
Q
Tel_l us \lhat happened a_fter you returned .fror.'\
21
your i:l)spection i:t:l .Portugal'.
22
HR. .i\NPRt11S:
t-1bere are
MR . RICl:!HAN:
:I presume back in London.
t:1R. .ANDREHS:
bsk hi_rn tba t question. , I
t-1e
23
:'::::
~ ~::;:
24
no'w?
.,
25
~
etRr
~AI[OMAN
U
Q
TOM
L_()MBAA-01
OALC: Gltl'iORON
'~ould
li)<e
138
<.
--
to pin it down myself.
~bere
'Paris, with Captai_n Anne.
~aris and we had a meeting there with 'Mr. Bigaignon.

Q
t;1hat tool:: place at thi_s meeting?
He
Di.d you inspect any arms or other weapons _in
Portugal, other'than the 81 rnm rounds?

No.
11
Did you have di_scussion witb Ur. Hart_ins of
13
Ho.
14
Did Mr.
17
18_
19
20
21
22_
23
24
~;,.~
25
a~~'tbi_n
of a sUbstantive nature, otber tban what Jou have told us?
M~rtin~ ~ndicate
to you with
wha~
company
he \>Tas associ_ated?
No.
16
::.
the inspections.
A_
15
discu~sed
10
12
~~~.
It was my respon_si_b1l_ity to get hi_m back to
..
did you go after Portugal?
'
4
5
Is he in London?
l~hen
\fas tbe ,irst tiMe you ever beard the nar.\e of
;..vi te~til?
A
When ) went to Portugal to e8ecute the contract for
mortar baterial.
Q
thought
..
~ou
bad
a~rea4y
relati_ng to the morta_r material.
e*ecuted a contract
Are you talking about
another one?
A
I am talking, then, about e*ecuting the actual
mecbanical supply and movement of the mortar material for
139
1
.,_:.;~.
shipment.
Q
abat kind of documents did ~0~ ha~e to get invol~ed
t~hatever doc\.iilents were called for undex- the
2
3
4
5
Was there_ an expor~ license in relation to those?
-7
Wel_l, thel;'e h_a d to be an export 1 icen_s e issu~d b~
the Portuguese Government for mo~tax- material, yes~

~o~
t;;ere
~o~
not a~ all.
11
Did
yo~
12
)"~s.
10
.....
Q.
letter of credit.
13
14
15
16
17
18
19
-20
evet: see an ex-port_ 1 icen_s e?
l saH a document t!)at purported to be an
export _1 icense.
Q
rnac~ine
Relati_ng to the inoi"tar rounC.s or
_rel_a~ing
to tl).e_
g~ns?
~elat1ng
~hen
"In -Portugal, in Septernbet: '77 ._ '
~h~re,
l<.
Hr. Uartins an_d Hr. Sogha1:1al_ian_ produced .it at the
Estox-i~
21
2_2
involved in_ that_ at al_l?
to the mox-tat rounds.
and whex-e did yo~ see tb~t export license?
~peci!icallY,
was it?
.Sol Hotel.
~:las
!)t:esent at t _h e time?
H.r ._ Hartins
'Yes.
~1h_at
tt wa s an ex!'OI't lie ense, about_ so big [indicating]
23
'
:::;.
-..:;:::
did it look ._like?
24
2"5
~~
u
8(AT
TOt.C
~AI(OMA.N-~ ~Oio48AROI
140
Q
...
idea a150\it
Can you give us SQrne
what~.we:are:...t .i111Ung7
They all vary slightly, from government to governmen
and it '"as the first time I had seen one from the Por~uguese
Government authority and it was dated June or Hay, and it was
for 10,000 rounds of 81 mm mortar a~munition, destination of
Hauritania.
It was dated Uay or June?
.A
Yes.
10
Do you have any idea why there would ha~e been an
,.
11
export 1 icense is sued as far bac~; as !:ay a%)d June Hhen you_r
12
contract was not even signed until July?

A
13
14
16
17
20
21
22
23
25
gi~e t~e
certificate to Mr.
Did the export license ~a\e an expi_ration date?
It wasn't indicated on the docu~~nt, as far as I
Q
~as
it
First of all, in what language was it?

~n
Spanish or Portuguese?
w~s
Por~uguese
Hell, it
~re you certain that what you saw was an e~port
document, yes.
license, as opposed to bei%)g an inspection cer~ificate?

A
There was a separate inspection certificate.
So you are absolutely certain you saw a~ export
24
~--
I didn't
recall.
18
19
No.
Sogroanalian until Septe_r:\ber . ..
15
..
I do not mean it facet_iously.
~icense
dated May or June?
141
i .,
-~
(.,
,'.:::
That was what t was told the document was.
Who told you that, specifically?
Mr. Soghanalian and Mr. Martins.
Did you have anybody else with you to translate
...
Mr. Bigaignon was there and Captain ,Anne was there.
Can either of them read Portuguese?
a~11,
Did you retain a copy of that document?
10
It was passed to the bank.
11
'tlhich bank?
12
Banque Bruxelles
13
How was it passed to the hank?
14
That w-as a requirer:-.ent unee:
I can't really say.
La~bert.
So as part of the lett-er
o:
th~
l=tter of cr-clit..
c:-edit, the bank in tha
16
case o;..as asking for a copy of the ex!'o=t certificate, export
17
license?
18
19
20
21
22
23
:'::.
documents?
15
I'
.tbose
24
' ~.::.:;'fZ
25'
Yes .
Did they rnake a similar requiteMent with regard
to the Machine guns, ~to get a copy of the export license?

.:;
Yes.
Did they ever receive an export license relating
to the machine guns?
No.
Was receipt of the export license with regard to th
---------------=-=--=-=--~-------------------~O~A~L~t~GC~N~O~AO~N~-------------------=----
142
1
mortar rounds a condition of payment on the letter of credit?
Yes
Was receipt of an export license on payment of the
..
letter of credit relating to the machine guns a condition of
payment?
Yes.
Do you know why they made payment without receiving
the export
~icense?
Mr. Soghanalian asked that it be amended.
10
To not include it?
11
Did the bank accept-that
amendment?
~overnrnent
They had to refer to the
13
What did the Government of
14
They asked why that request was
15
Then what happened?
16
I asked Mr. Soghanalian whv that
17
And what did he say?
Because the export license issued by the United
18
19
20
21
22
23
24
..
25
of
~auritania.
12
~auritania
say?
~ade.
requ~st
States authorities was a government document.
was made.
It was retaine
by them and, although a copy could be furnished, that even a

copy was not psrmitted to leave America, leave the States,
and therefore the bank couldn't physically have an export
license presented.
Q
So then what happened?

HR. ANDRE\vS:
Excuse me
DALE GENDRON
I do not even understand
1_4 3
1
that question, "So then what h_appened"?
~~
H_R.
He said he' was told thi_s by Hr.
R_ICHHAN:
Soghanalian.
Hhat- happened "after: he was told that?
HR. bNDREtiS:
.HR.
Pertaini_ng t_o
RICHMAi~:
to the letter of
~redit.
'
To which one, mortar rounds or machine

guns?
!lR.
16
17
18
l9
20
21
22
.... ,
now about machine gulJ.S.
15
'
tal~il'lg
11
14
,'
He_ are
The only question was related to nacbine guns.
13
.33
RICH}f~.t::
10
12
.._,;;.
~lhat~
To the export 1 icense, pertaining
1
8
23
24
Z.1acbil'1.e guns.
then coml'iu:,icated to Hr. Soghanal_ia 1
infor-Mation from the Governnent_ of Haurital).ia through Ur.
Bigaigtl.on and they did, .ln

....&. ac .1.... ,
l_ette= of
authoriz~
that
a~end~eXJ.t
to
~r~dit.
Did al).ybody check with tbe Onited States authorities 1
relating to t_hat?
A
I didn't check.
Do you know
No.
Let us go back in poi_nt_, of
if anyone did?
don't knO\o: i_: al).yol).e did.

- t_i_n~
aga_iXJ. to take it
sequential_ly as to what happelJ.ed in 'July of 1977, a_fte.r yo'U

went- to Paris.
You returned.
that- took place in
t~hat
IP.;~:;;:~
You have told us' about t_be discuss"iol).
~aris.~
bappened after that?
25
OA.l_t. GtNORON
-
---------------------------------
144
~
Captain ~n_ne w-as very -concerned about h_i_s _report.
to uauritania on the 30 s he })ad se_en in Santo Dor."lingo and

he said 'that ur. Soghanal~ian had told h_ir.l tbat- the receivel:'
part of the .30 co~ld b~ rnan~factured new and that the .30
spal:'es held by Nur.~rich could be asse_mbled with t})e receiver
in Humrich, and Ca!)tain Anne wa_s not- sure that, in fact, his
government would proceed on that basis.
And so it was decided tbat we .!)lac~ a call.
nl:'.
'Big-aig-non placed a telephone call to Hr. Sogbanal_ian in Hi_a_r.li_

at- that time.
1\l)d Hr. Bigaignon and Ca!_>tain Anne ,spoke t~
Hr. sogba:1alian on this point- and they both \lere px:iyy to the
sa_r:te telephone co;n.versati.on, and :1r. Soghanali_an said tbat_
.he wasn't: sure that, in fact,
he. could secu:re new receivers
for the 3 0 1 but he \1as sur_e that
.~-
~_ne_
.30 ,::ould be a sat is-
factory \-.'eapon.
That . . tas t_be end o tbe conversation a_nd,
'
conversa~10:1
t _el epoone
h d
.a
h ~
~~nls_aa,
&'
\-1l}cn
the
C ap~a1n
~nne.s,op1n1on
,.
I
'
a~out t_hat particula_r part of t.be order and \~hether t_hey 'wul
proceed \dth it, but'he would make recor:ir.lendation_s, as he

saw _fi't\.
..
~hen
I went back to ~ondon and Ca~ta_in Anne went back
\.,.hat- })appened?
to ~1auritania and Hr . Bigaignon sta~'ed in Paris and we_ then

waited for the Nauritanian Governr.lent to decide on what cour_s
of action they were going to

Q
happened next?
k1R. A_NDREWS:
Where?
'4
HR. RIC}fUAN:
A%lytime, a:l)ywhere, related to this
conversation, to this' transaction, chronolog ical_ly .
kH~.
-7
HR. RICHHArh
AN-DRE~~S:
.i\.fte:r: that, what do you want to ki)ow?

It is very hard fo:r: me to ask a
specific questioi).
HR. ANDREt~s:
tnstead of "Then what bappened,"
10
"'l'hen what happened, "--we have a monolog-ue go,i_ng O%l
11
over be:r:e--~:R.
12.
\;;.
1~hat
ta~e.
14.5
l_f you k_nO'\o! a
13
14
R!CH!V.~:
something
certail}l} agre_e
bet~er
d9 not know,
~fay
"~i th
you.
to -ask a question about_
~would
be happy to hear it.

I
15
16
The ea_siest tbi~q for ne to do i's just as~ bin what

trai).spired l'.lext.
I do not know what he did ne8t.
17
18
19
X an here to find
out.
.,
t~ell,
eve:r::.tually t_he Naurita:o.ialJ. (7overlJ,ment- cecided
to pUrchase .197 l{BJi2 s, .plus spare barrel_s, as a unit, a:)d

20
21
S,OOO mortar bombs, 81 bM.

Q
Did
~hey
do t_bat by docun.e:o.t, in '\o:riting, othe::
22
than the cont_ract you have identi_fied, 'dated August of 197 7?

23
"' ".;;:?:~~..
~.
Yes.
They did tbat by the cont:r:act, by tbe
24
sub_r.dssion of tbe End-User s certi_ficates and by the letters

25
OA\.C C:C'<ORON
~y/-
2
3
~oi_nt?
'I' hat- was 'tbe communication _from tl1e governmel')t.
No.
How were those docUments
Ref.ei::ring to the com!'laint, Exhi_bit_ No. 3, col')t_ract
7
8
10
11
12
13
14
1~
i;1as there. ally kind of 'l'elet or communication from
the govern_m ent ,on_ t}1at
of credit.
14 6
transmitt~d
to you?
dated t _h e. lltb of June, this co%ltract i _%l _fact \voas not a ctUally
even signed by t}1e parties on the 11th of June, was it?
No.
What actual day was i t signed; can you ~ec~llj
On the
At tl').e tine at_ w~_ic~ _i t. '-:as actua_l _ly signed a:)d
~3tb.
ini~ialad, ~~ set ~o~th h~re,
as being based on a
tbe pric~s, tbougb set ~orth

-
c~rtajn
amou%lt,
w~re
~~~ld
qualifJ
t~at.
actuallY sti).. ~ open
16
17
Yes.
but I
~o~ ~aid
"Set !orth and signed.~. ~n ~act, they
18
lrera set forth i _n ::ia:ni' on t _h at.
':.'h~y
"t--ere _i_nitialed a _n d
19
signa_d and any
ar.~endrnents
initialed and signad on tbe l _3tb
20
in Santo bomingo.
21
Q
~o
_a l _l the initiali_ng har.e that occurs i_n tbe
22
:::argins occurred at- a _l a ter ti,r.\e i _n Santo :Domi_ngo?
2~
That's rigbt.
Every place a signature appears here,
24
....._~.::::;
25
i~
occurred ln
147
1
ro-.::::;.
(.
;.;:
Santo Domingo?
That's
.i:\.t tbat- point in_ ti_m e, though, as i _l)dicated }).ere,
~igbt.
the price e~en at tbe time it ws sig~ed was s~ill open to
be negotiated?
.i:\.
'I'hat s right .
-7
~ou bave indicated that Captain .Anne wa~ cdncerned
about the arn?unts and you ul ti.rnately got a co~tr_act e~ec-uted
by the vaurit~n~an Go~~r_nment il) -~he ano~nt of the 197 rnachLne
10
11
12
"'
13
14
c;uns.
A
-! 'es.
Prior to that t 'i_:':le, did you e.v~_r get a ::uthorlzation
for the 200 gu_n s fr_orn t _b_e Uauritanian Gove_rn_m ent?
No.
~be only way in which
it had been
l~ft ws
1S
16
17
..
18
19
20
that C_aptail"l. ,,nne sa_id he ":as hope!'ul t _bat the th_i:::.gs "muld_
proceed and t .h.a t. he \.;ould f.'l~}:e hi_s l."ecotir.;e!)f.a_t _io;::.s i:1. lig~t
of t _he. _inspection that ha_d ta}:en plac!:.
Q
f:bat .was _i t, speciJ.ic-a _l ly, t .hat - " bnne. ,.'as -goil"l,g to
recoMnend, as you unde.rstood i't at t _hat ti.me?

;...
~1ell,
:1 u:nder_stood
that he '-:as goii).g to recorn:n_ei).d
'
21
that- the purchase proceeded '"it_h tbe 50 and \lith tbe 91 r:fm
mo:x::ta_::, and also the 30.
22
2.3
!
24
:.":..:
...:............
But ag-a i_n,
be \.;as--- Agai.:J., -r.;~het_be.
he said he was hope_f_ul t _he gover-nne%1,t ~ould accept it, be

knew they requi_red i _t and bad an urgent ~equi_rement for .30,
but he said he would _recornrnel"l,d tbey accept this, Nur.'\~ich' s
2_5
OA\.C: CCNCAON
148
~-
30 as a:) acceptable \-:eapon 1 but. he wasn't sui"e 1 really, t.l'~at
2.
he would do that.
~"-
Were your dealings with Hr. Soghanalian and all the
people wi t.h whom you dea'_l t ~ind of aX). open al).d abo_ve-board,
direct kind of dealing sitnat~on~

I
I'm I).Ot qfiite sfire.
\~ex::e thei"e any J:ickbac).:s involved OI' anytb_ing else
How do yon . me~n?
like that wit-h any of t_he people relat_i_ng to any of these
transactions, with Captai_n An_ne. or anybody else i11volved?
10
Do you mean bribes?
"11
'Bribes?
12
~
13
i:ere there any--let us use tl).e sa_ne \omrds--bri_be_s,
payo:_!:s or anything l_i);e that., to a:)~' officials o1E the
14
=~~uritanian Governroent or anyone who could .influel).ce t_he
15
'
,.. aur .l. ~an_.l

. . an
16
17
~o.
AJ)d that: Hould _include captain Apne anC. anyone else
18
19
1 i k e t h_a i:.?
2Q
21
22
23
. ......
t,
): es, certain.ly.
Up until the pe_r iod of ti::\e t_ha t yon got you:t'
fina.l col).tract signed, do you ~;_no\'. ~ow the figure of 197

wa~ arrived at, as opposed to the 200?
Yes.
~es.
explained that to Hr. Sogbanalia~.
24
'I' be
,.:!::;:.
_. ... u-..
.... ,-
25
uanr itanian Defense Hinist_ry obviously h_ad a bfidg et which
149
1
stic~
. they h_a d .to
to an,d we had .obviously t _x::ied to effect a
price \<.hich would give us as much rnarg in to

3'
fO~slble,
wor~
wit_b as
~nd lnitiall? w~ ha~ $OUgbt to stx::ike a tx::ansaction
:'ith t _bem on t _he_' basis of $9,000 per l.l_n it.

5
He then bad to lowe%: that- price to secure the order I

6
7
8
in ef_f -ect, ,ai)d it carne out_ to $8,600 a :>iece, and_ tbat, tbey
had a_ lump su_m which they could spend ai)d 'the $8, 600 ' into t_ha
lump sum was
10
...
15
16
-~
~hey ~ejected tba~
completelt ~nd l
~nfor~ed
Sogha'nal_i:nn accordingly.
Q
tH t _h x::egard to tbe__l 0, 000 rounds,
'-'i~at
il') t _erms of
\\'aS discussed, \.fas the_ra ever a~y ciscu~sion about H~iti_ng

for ne\.,. 10,000 roui)d_s to be !':'\anu!act_u red, as opposed
~o taJ~in
that _1 0, 000 ::::ounds 't .bat_ 'fas right. thera?
r. -
Nell, :-tr.
Sogbanali_a~'l.
did,
bet~,een
-:._ba".; perl.oc,
..
'
ob~iou$1? havin.~ put all tbat time ~nd affort into i t and
19
( ~~
.~
Did
~li'.
17
18
cali_bra~
'tbey reject tbat compl_etely?
13
14
out at _1_97 unit_s.
Hhat happened finally with the 30
11
12
wo~~ed
2Q
until a certain date fron the !!attritanian Government.
21
Of
2_2
and :r wa s bei_ng :reassu_r ed by the
23
Par i _s througl) Hr. Bigaignon, yes, the na tter \-las bei_ng dealt
24
wit_h by the Uini_stry of Defense in Hauritania and ,they were
25
hopeful that al'l t:he ~'leapons inspected, arnmuni tion inspected,
co~rse,
the_re \'l2_re tel epho::'le conv ersa tJons

!~au.r.itanian
__ OAt.C: GtNORON
bet,~een
us
_E mbassy .in_
150
....
j
''
~~--
would be purchased.
Hr. Soghanalian on those same points in the sar:\e way, and
"
AX)d I had obv_iously sought- to reassure
..
"
eventually we got confirmation tbat they would': proceed
only
on 5,000 and the 197.
~s
tracted witb the Mauritanian qovernnent: and the End-User
.certijicate and
And I relayed that to Mr.
Soghanal~an
soon as l was made aware of it aX)d as soon as I bad con-
.......
th~letter
~ollow
you on
On t_he' l 0,
ooo,
.of credit had coma through.

that~
was it_ the 10, ooo rouX)ds that you
10
and Captain Anne actually inspected?
11
be cal_led an arsenal.?
12
arsenal?
0ere they inwhat would
i:Yould you l"efe::: to tbat as a gover:r:uaent
13
Yes, an a_rsenal, controlled by t_he <jove:rnrnent.
14
1;ias t_here ever a_ny consideration t_hat you can
15
reca1_1 to having :the 10,000 rounds
16
other than the 10,000 being
tal~ en
co::;i!l~
.::rom any ot!)e_r
out o: tb<:tt arsenal?
;..
17
i\'ell, tbe
rnechan~c_s
of t_he s i ~uati~n, as
e)~;>la_in,ed
18
to r.le b.Y .Hr. Soghan.a1ian with respect to tbe
19
.,.:as he h_ac a buyer i:ho
20
wl).en
21
o: tbe z-:aurital').ian Gove_rnment for them .
22
23
I
.'
h:~~
'I==
24
25
\le
~,anted
r~o:rtar
bonbs,
to pure base t_hose lO, ooo and
evel').tual_ly---1 said, "llell, I can't r:~ake up the minds
wait_ for t]:lem tq decide."
t;~-==
'd1_1 just have to
But _if t_hat 10,000 or so---
'!'hat is something I can't do anything about, but I said,
''They
do need thi_s iz:l. a relatively short dal.ivery period, so if i t i,
possible to, i f tl)ey are sold and it is possible for the t.lorta1s,
'
151 ,.
.
"\~
.... .!-- _;;. ..
. to be taken f;-om stock-~ from the government stocks and

by the factory, as long as
~eplenished
..
'
don't exceed a
the~
..
pe~ iod
of two years old,. that would be satisfactory, .J?ecause
.4
that real1yi~ c1ass1fi~d as ~on~aged rnat~~i~l dby NATO."
J ....
'
'.
'The mortar rounds that you inspected, the 10,000

.
...
8
9
10
11
12
o=
13
'
.14
15
16
17
'
in July, which'would have been about the middle part of July?
...
'
Yes.
You'saw. what was represented to youas being-10,000
.rounds .in an arsenal, which was rept"esented to be under the

control or o~nership of Hr. Soghanalian ,or one of his compani~ .
Is
th~t
correct?
'A
Yes._
It was from your own eyes you were able to
obse~ve'
what appeared to be a 1977--'A
1977 production .
So th~y weie of what would be called new manufaqture
.A'
Nind"you, we didn't. count them.
_I
~can't-.
say there
18
19
20
A
Yes.
T.o the best_ of your recollection. of any of the_
'21
22
events here, was tbere any discussion about waiting' for a
23
c4r-:=-
later period of til'le and getting them off an assembly line, .
24
'
'
as opposed 'to
going a}1ead and buying those :right there?
25
..
l~--- ..- - - - ... -----------~~-----.----- ---~
OA\.C GtNOAON
---- -------------------
-----~-
------==---~-~
-- ----.. .-- ----- --
-----~,._- ~
.. .,.__.
152
1
No.
It was a question, really--- It depended on.
whether that 10,000 had been sold by th~ time the Mauritanians
.,
pl,ced the order firm and from their letter of credit.
.4
'that h~p~ened and it, in fact, did happen, Mr. Soghanalian
informed me that the lo, ooo had been sold, then we are still
faced with the responsi_bility
t~
lf
supply the . Uauritanian
.
7
Government with new production of material in a certain time
period.
Now, I did say earlier that
~t
is--it is not the
10
common -procedure of munitions factories.to manufacture unless
11
it is
12
They don't just continually produce ammunition without any
13
outlet for it.
.14
fo~
thei_r own army stock 'o r unless it is for an order.
So if there were no production lines going
at the ti_rne the nau_ritanians placed thei_r orde_r, it a:>!'eared

I
that we may be in difficulties in fulfilling their order in

16
a relatively short period of
'21
22
23
24
the
probabillties that t _h is--difficulties this . . places _u s 'i _n.

"Would you contact the Mauritanian Government,"
19
20
Bigaig~on ~bou~
Now, I had spoken to Mr.
17
18
time~
I said, "and get their confirmation . of the date up to which

~nd
they will acicept stock naterial?"
they said they would
accept it .up to two years old.

Q
'
One other question while I am thinking of it so
I will be sure l have covered all aspects of it.

With regard to the question of bribes or anything
-25
...
...
OA\.C
GC:NORO~
-----
~~~
---
_ _
-=- -=--------'------'-'-"------"
-_ .,_.~ --~-=
-
. e-.. .
similar to .t hat, your statement. .clear1_y under oath is that

you did . not it~l.' any way bri_be anyone or pay anyone off or
_ pu~
1_53
r.\oney .into. t _h e pocke~s_.,~f anyone~ in any ~ay relating to
..4
either ~ t~e Na~~itaniari_ iransa~tion or the machine g~~ tra~s
.s
~ction relating to Ma~ritinia.
Xs t~at dorre~~?
-~
Q .. And yo~ nave~ info~me~ ~nyone that fOU d~d so, did
'I'ha t is , q_~i te correct.
you?
.,
r:o.
..
F.
!..
10
Before we get bogged do\m i _nto
~~
11
moment--we can come back and pick sor.\e of these up, l
12
tomorrow--le~
13
chronology, as you can
():;,
doc~r.\ents
us see if we can finish going

. ~ecall
at- the
thro~gh
tblnk
the
it.
:In the month of July and t _he nonth of .t)ugust,
.14
15
_y ou have alre_a dy told us about the contract you got with the_
16
.government.
18
19
20
21
2_2
-23
c[=-s=
24
_:;;..:
'25-.
..
2
have had that- id_e nt_if_ied.
Hhat else t _ranspi_I"ed during th_a t
17
..
He
of time in, say,
t~e
first- of August?
.bappen that you can reca_11 t!'_l_a t

i_n tl:le rnonth_ of
J~ly
yo~
i_nte_r~v~ning
Did_ ~a_nyt_hing
else
}:lave not told us
,: relating to eit_her
; ~f
pet'iod.
a_bo~t
'
these transactions,
any other conversat_ions yo~ can reca_l _l with_ ~1r, Soghanalian

or anyone eYse relating to it?
A
I ~wrote to MI". Soghanalian and"just confli"med that,
as far as I knew, everything was going ahead and that we woul

have to wait- ~ntil
-\'1e
were advi_sed by the Hauritanians of theiJr
..
1
c~
-
.,r::-
~what' about~the
.4'
5
c-r
"
HR. ANDREWS:
Pertaining to what?
HR. RICHHAN:
Pertaining to any conversations
Officially., prior. to that time, he got that August
30th contract, whatever the date
~as.
Can you.remernber anything other than what you have
testified, anything else you have not already told us?
10
No, I
11
12
What happened then?
"'
8
9
month of August?
with Hr. Soghanalian or any :Hauritanian.
~"ant
ca~t.
think I am going to have to do what I did not
to do.
Let me just show you a document a~d, Ms. Report~r,
13
.14
I will have an extra copy of this made up to insert in the
15
record.
16
Exhibit No. 4.
I will note .for the record
...
J. ...
is Defendants'
Let me show t_hat one docume~t to
17
.OU
and ask you
,..
18
(l..
-
final decision.
..
154
if you can tall us if,you ever saw that before.
19
Yes!
That is a form DSP 83.
20
'Do you know when you fi_rst saw that?
'21
As far as I remember, in October.
22
How did you have occasion 'to se~ l t in October?
23
Hell, that was complete4 in October and taken at
24
Mr. Soghanalian's insistence to the Ambassador in Washington,
25
~ogether with the End-User's certificate issued from the Pari
155
' .'
.1
_' Embassy.
eft-
YoU say the .form was
com~leted
'been executed -by other _parties earlier.
.4
Yes.
JUs~
i~
October.
l t had
.Is .that- .r ight?
looking at the document itsetf, there are

...
'
"
dat-es that appea_r to be on het:e, jj.ugUst 29th.
7:
Q
(;.
11
13
1'7
18
sho~ yo~
a look at that?
what has not been marked, but if
docurne~t
this tbe End-User certificate to 't'lbicb you are
. 29,
20
~hat
Yes , sir
The docunent to wbich
French, bUt it _i s
19
~977,
' s r i gb t
re_f~rred
\>le
have r-ef-erence .is 'in
..
.to and has :a date of August
and a certification by the Ambassador
in
~ashington
on October 19, 1977?
21
22
Yes.
t'lere you i _nvol ved at.' all in_ obt.aini_ng the ,e.ugust
23
2~th
24
cert1fication?
'A
'~
:_ Hay _I _ t ake
:r .eferring?
16
~ --~ - - ---
AHDREi~S
~et~e
~s
15
t _h_i n_~ it i _s dated.
you can, ident_i _fy tl).i_s
.14
25
H~.
12
certificate i _n this case_ was
issUed . on the_ 29th of_ lJ,ugust?
10
i'
End-Use~'s
in 'Paris, so the
cr
That was when tbe End_..;;user certificate was issUed
'
Yes.
T!)at was presented to me_ by tl1.e tmbassr in
.
OALC GCNOI'IOH
156
1
c~
Paris.
How did you happen toobtain that?
t'fell; the End-User--- 'It was a requirement expressed
.:..Ji
in the contract between :myself-:--between Boca .Investments
and---
through the nechanics of getting this ~rom the Govern~ent of
Mauritania on the 29th of August, 1977?
10
11
12
13
.14
Monsieur~,Charge
~c~--
My question is who actually, physically went
~ith
d'Affaires..
He did that simultaneous
obtaining the written contract.
Did you receive a copy of it with.the written
contract?
I received the original.
It was passed to me.
BeJore we get into any documents, let me digress

I
15
16
17
.18
19
20
for just a moment away from our chronology here and ask you
i.f you have or has anyone on your behalf r:'lade any independent
~nvestigation to determine whether or not the
'machi~e
guns are in
Yes.
Who has made such an investigation?
I.'have retained an attorney in Portugal for the
past 18 months.
Q
t1hat is his name?
Dr. Jorge Edwardo de Mello e Abreu.
What 'has he .done on your behalf?
23
24
c~:-:
25
,,
calibre
?ortug~l?
21
22
.so
'
157
1
CF
..
He has established that the machine guns and the
weapons, as'described in it, have never existed in Portugal~
Ha~
he determined that they are not under the care
of Avitextil or not under anyone's control anywhere?
That is what he has determined
How has he determined that, to your knowledge?
By his inquiries over 18 months.
So I can clearly understand what you are saying
.and it -will be clear on the record, you are saying that the
10
machine guns~ as specified in the air \-laybill,

never
.
. existed
11
and the ~50 calibre machine guns never existed in Portugal?
12
13
(f
.14
15
16
17
18
The machine guns, as described in the air waybill,
the End-User's certificate, the letter of credit, the

certificate of origin, certiJicate of i_nspection, packing
lists, have never existed in
Q
Portug~l.
Have you ever made any determination or has he
made any determination, to your knowledge, a~ to ~hether or

not a quantity of 50 calibre nachine guns ,in fact e:-.:ist i_n
Portugal under the control of a company called Avitextil?
19
.A
There are soce weapons which I understand are in
20
Portugal.
I don't know whether they are under the control
21
22
of Avitextil or a factory called Bras Da Prata.

Q
How did those \leapons differ 'from the ones
23
specified in the letter of credit and other documents?
24
J.~i
-'
Quite substantially.
25
DAI.I: GtNDRON
' - -- -- - - - - - --- - - - __ ................. __, _.... , ,_ ____ -=--...
.e
ry-
( ..r
Tell us how.
The weapons in Portugal, I understand, are second-
They are, I understand, 'AN-M3
ha~d,
are ai_rcraft weapons.
They have no relationship t o HB!-12.
Anything else?
Yes. Hy 1awyer has advised rne that an application
Are there any other differences?
~vitextil
for export license was rnade by Mr. Soghanalian and
for six items for export to the Mauritanian Government.
What six items?
10
I can't specify those because I don't have--I'm
11
n~t
12
vestigated.
13
privy to the documentation.
The files are being in-
Do you have ' any knowledge at all, recollection,
.14
as to ,.,.hat the s i_x items ,.,ere or even any of t _hen, if you do
15
not
22
24
25
One of t _he items 315 N3 50 Brownings, total cost of
To be transferred to whom?
The export
~icense
was raised to be delivered
I don't kpow.
I can't remember.
Do you know the date of that export license or
the date of the application for it?_
'
- ---
..
have no idea.
to uauritania.
A
Yes.
0
What other items?
23
=
all six?
$141, 000, 31_5 AN-113, total cost $141, 000.
20
21
~now
19
..
Brownings, whic
l8
.so
17
used.
16
c~~E
158
OAI.t GtNCRON
159
c-.:::::..
No
Do you even
I understand it
~-::
..
(-:f~-
wa~
weapons?
A .
the year?
1978.
No previous 'pplication
'
for export license had been nade prior to that time
'8
~now
Have you found out~ anything else about any other
-I found out something else about the application
or the exp~Ft license,
Idhave been told . that the ve~ificatio
lette~ i _s sued bY, ~mbassador Kochman in Hashington and
10
appended by .a seal to tbe original End-User's certificate,
11
issued by the Mauritanian Embassy and the Form DSP 83,
12
\..-hich you just have shown us, those two documents were verifi d
13
by Ambassador Kochman. on a letter which was sealed to them.
,.
.14
I understand that that letter is on .file and the
15
application .for the export license, but it is not attached
16
to either of those two
17
documents, one of them cov.ering six itens of de_fel;l.Se material,
18
19
20
'21
22
23
24
c-,;;:.= "
..:;:
25
..
docur:~ents
that is
at~ached
to otha.r
signed, and the letters dated the 17th of~ August and signed
by Hr. H. J. Richmond.
The 17th o.August of what year?
1977.
Where -are those
They are with the Portuguese Government~
You do not have possession of those and your
'
docur:~~nts
lawyer does not, either?
OA~C:
C#CNOIIOH
located?
160
1
2_
CF
No.
Let me run th~t ~y'one .more time sot can be
clea~
"i
~ated
That is letter
What does t _h at
1ette~
1~77.
say?
tt- detai_ls si_x ite_ms
How .does this document, which we. have designated
a s Defendants'
UR.
13
to _your lawyer,
of de~ense material.
E~_hibit
4---
A_i~DRE-HS:.
i:o.
'l'hat has not- co_me _i _n.
'
... ...
accordi~g
August 17,
_I cannot--- I don't know.
'12
c-l -"
has ~ document dated Augusf 17, 1977.
10
Th_a t_
bas not been narked or come in yet

~1_R.
.14
RICHUAN:
I know _i t has
r)Ot,
but l a t_r eadi:'
15
_indicated on the record I 't.fou1e have it nar:ked as
16
Dafenda:t)ts' Exhibi_t - 4 as soon as I have a clear copy.
17
18
19
20
21
Q=-
The Portuguese Government,
-6
11
' I
f.
as to wl)at: _it i's . you are saying. '

I
'
f: _
i t.
o ....
''
Q
relate to that. .t)..ugust 17, .1977, l_etter?

A_
23
-to it?
'
of
th~
That_ _is a
matter.
so it i s not a ttached to i t or , in an_y way appe~ded
MR.
'24
25
t\'el.l, _i t doe~n't rel _at~ . to it .at- a_1_1.
plain _f act
22
*'!$
~_NDRE'l-15:
~1ake
will make that
..
that cl'ear.
~lea~
to you.
. OAL G[NORON
- - ----- - - ----- ---
---~ -- ~-
.,..-- -- -=- -- -"'"-
--o:-
~-
--
~-=--~"'=~~ -
--
"="
-~---~--~-
~-~---~--~--
-- ---------
...
__ _____
.
---.(,.--
.........
~----..,.--
....... ___
161
1
licenses were being raised in America, the
Department would not necessarily recognize the signature of
'
Monsieu:r BA, who was
~harge. ~~d :Affai-tes
u.s. State
in:the
Royal~';"'f
::.y.: :.
Embassy in Paris.
certificate issued by the Hauritanian E_mbassy in Pari_s, that
a DSP 83, which is a statutory American Government
End-User's
C......
Nr. Soghanalian insisted that, because the export
.4
-T herefore, in addition to the End-User
..
these two
c~rtificate,
documEfn~s
also be signed by
f~rm,
Monsieur-.~BA~
ana::-then
brought to the Ha uri taniaZ) Ambassador in
10
Washington and verified by him.
And the reason for this
11
would be . that the State Department would rec6gnize Mr. Kocbrnan
12 '
signature immediately and the export license would be raised
13 '
quickly, without any delays of checki_ng Honsie.ur BA 1 s
,14
signature in Paris.
I toorefom arranged th_rough the
15
Paris for an appointment \lit_h Hr.
17
Ambassador in Washington ,for

verification of .uonsie.ur BA' s
' '
18
signature
20
21
-22
23
24
25
...
tan ian r.lha s sy in
16
'l~ochnan,
t _he Uauritanian
OJ)
the DSP 8 3 and t])e End-:Use_r certi,f_icate.
I flew t6 Washington on the 19th of October--I'm
19
c~~
k.~
.;,;:
!~aur i
sorry.
It was the 17~h of October--and

rang to confirm my
'
..
appointment 'with the Mauritanian Ambassador in Washington,

Honsieu:r Kochman, on Wednesday morning, the 19th of October.
, I took that fo;m, the DSP 83, which is a~ American Government
official form and the End-User certificate.
Honsieur Kochman verified i!he signature of each
OAL CtNDRON
..
.1
C~
'
e.
two documents i_n ver]:f_ication
:of verification was,between -that time
and the time 'it appeared in the Portuguese Government,
detached from those two documents that the fetter verified and
-
two othe~ documents
were added to it, which bore no relation
to the verification at all.
What were the two other documents? ...
One was a letter dated the 17th of August, 1977t
10
requesting an application for an e,;:port, license fqr .si,;: items
11
of defense material.
13
'
~etter
The
12
("H'f"
document and sealed the le~ter, .appended the l'etter to tho$e
.SA_
162
.14
15
I can't- remember.
I didn't have privy to it
Tbese are_ the things I was told .by
~y
attorney in Portug-al.
Q
the
"18
19
20
Hhat 'Vias the other docur.'l.ent?
! was just told.
16
17
Q_
Did your attorney i_n ,Portu<j'al tell you tbese -ar.e
offici~~
.Portuguese
That
~ut
.i~
Governmen~
records?
co~rect.
he does not have copies 'of_them
~nd
has
~ot
been able to obtain copies of then? '.

A
They will be rele~sed in due course, I
understand,
21
.. but for the nor.\ent they are privy to the' Portuguese Governrnen'
22
'23
..
,.,.hile the investigation carries on.
.,
l--q~'Of~---
To what investigation are you referring?
-A
Hy la,.;ryer said there '\>las an investigation going on
. __ ,__________
OALC: GCNOIIOI'C
'
163
1
c-=:
...:...
about it
Q.
Are you talking about a government or military
~-
..
Are you talking about a civil lawsuit?
Well, like I say, I retained couns~1 in Portugal
I don't know.
for 18 months t'o make inquiries into this matter.

Q
Has there been any, to your knowledge, affirmative
action taken in:Portugal ~elating to this matter?
10
11
in Portugal.
12
When was that?
13
In October,_ last year.
.14
Do you have any idea of the date? Do you have any
15
~nforcation
16
.No.
Can you tell us even more approximately,when it
17
is
19
20
21
22
23
24
--=
:t.~
25
,,
.. .
,4
(T"
investigation?'
One time Hr. Soghanalian was arrested, I understand,
as to the date?
That can he obtained.
was, other than just last year?

o~
Towards the end
Was that iri the City of Lisbon?
Yes.
Were there any proceedings taken---
I don't know.
last year.
Were there any pro~ee~ings taken with regard to
OAI.C GCNDIION
-.
........ ,
~--
""'"'*~
......
_.t
& '
...
164
attaching any goods or rnerch~ndi~e in'Portugal, to your

.knowledge, relating in
A
.4
'
'
Were you
TliE lV'I..TNESS:
17
l8
was
~ossible.
Here you ever advi_sed?
Listen .to
No.
~riting
.or
~erbally
e~er
that anything in. Portugal had
No.
Q
.Did you
I
necessa~~
,Q
r~quest
that
anythin~
be attached?
inst_ructed my lawyer to take any steps that were
to
~afeguaid
the position of Boca
Has. anything else
come to your
relati~g
In~estme~ts.
to tbis from .any source
att~ntion?
No.
19
20
~hate~er pro~ert~
attached?
been attached?
15
16
~nythihg w~s
I_f you understand the questiox:, did anybpdy
tel_l you in
13
..14
instrUcted
advised that
his question.
12
eve~
HR. At:DREHS:
11
not been attached.

Q
10
way to this transaction?
I don't know what has been attached or what has
a~y
Nhen I refer to that, I ,.,ant to make sure I am
covering. '1-:hat I am talking about,. specifically relating -to an

21
investigation of facts i_n .Portugal.

22
Has an~thing else come to yo~r attention; other
23
thanwbat you have told us?
.24
'No, not,to xny _knowledge.

25
..
165
I think we are going to break shortly so you will
have overnight.
A'
Can I reserve my reply to that because I really---
It's a lot to think about.
We will start with that area tomorrow.
There are
just a couple of other things I would like to ask, at least

start on, and we will continue the rest and get into .the
documents tomorrow.
l;li th
regard to the mortar rounds, were there 5, 000
rounds delivered ultimately?

A
Yes.
Here there any problems regarding the delivery of
those 5 ,.000?
A
It was a pretty hard effort, yes.
t~hen I say problems, ,... as the r:\erchandise delivered,
as represented, in the sense that you. got $5.',000 rounds of

r.tortar?
A
Yes.
But it turned out eve~tu~lly to be 1973
production.
Q
A
.,
When did you find that out?

.,
"hen Mr. Soghanalian at~ived .. in Portugal at the
Esto~il Sol Hotel at the end' of september.
it was 1973 production.
He said that
e
,.
(]
Yes.
Then what happened?
Hell, I had to advise the l-1aur i tan ian authorities.
The way you found out that it was 1973' was through
&im te~1ing you, as opposed to any other source?

A
Yes.
l'lith regard to the remaining 5, 000 rounds or the
'
c~:;:~
166
e.
_..
Yes.
He told me directly .
other 5,000, what happened with those?

A
..
t-1ell, the situation was that when .I eventually got
10
the contracts, letterof credit for 5,000 and advised Mr.
11
Soghanalian that that is all we had to proceed with, he said
12
yes, he ,.;ould nal;e effective delivery.
13
So I did say to him I was told by the Mauritanian
,14
authorities that if a contract-was handled without problens
15
and that they did in fact get what they wanted, then it would
16
be repeated to. make up the
17
18
19
.20
21
22
23
24
,_.
c~:M.
:rt:.=
25
10,000~
but because it did turn
out to be 1973 material, although they did eventually
acc~pt
i t because of the urgency of their requir~ment, I'm o~ the

opinion that=it ~eft~ pasty ta~te in their mouths and they
didn't eventually proceed with the second 5,000 rounds because
of that.
Because of the 1973 date?
Yes.
MR. RICHMAN:
to break.
I think this would be a good point
lot relates to documents, so we will break.
I~
..
:
'"
..
O"U; GtNORO,..
-
-------------------'------'---
1_67
Let rne just button down one other q_u estion, b6cause
(Y:-
I have asked you something about foul:' di_f_ferent ways and- I wa n ...
to ask . you ope last- way.

or :putting
"Putting money into, lining the :pockets of people or putting
into
pockets, would you interpl:'et the words
-money into -the pockets of_ people" as a bribe? . Hould you

interj>ret tl_l_a t in the same vernacular?
t~el_l,
10
z _)ust want to :r.1ake sure tbat. your denia.l_ of
11
bribing
an~one
'
it: could be interpreted as tl_la t. '
or inytbing
-
l~ke
that in any way in relation
to this tra_n saction include_s your statenent under oath t _h at_
12_
c--
~eople
about bribing
~oney
of
you did not put money into t _h e pockets
13
.,....
;
peopl~ 1 s
: ~6u
:.
When I asked
.4
pockets of
.14
peopl~
Ln
rel~tion
to this
people or .l i_ne
tr~nsaction.
Xs that
15
.'l'h:a t is quite correct.
16
'l:1B.
17
:1 h_a ve
-no otbar
ques~_ ions
..
.until
tomorrow
.18
(t:lhereupon, t _b e deposi-tion was ,adjou:r;ned at
19
RICifU~!~:
'
5:10 p.r:l.]
20
' 21
22
23
ch_
'24
1:::.
...~
25
..
--
- - - - --- - - --
04\.t GC:NDAON
- - - - - -- -- -- - - - - - - - - - - - - ' - - - - - ' - - - =-=- -=-=-----.:_---'=

--=-- ---=
--'---"- -:_::_c..:._;::.___:;--'-----=-'
--=- _:_;;
- -'---.1
168
IN THE CIRCUIT COU-R'l' OF THE

ELEVENTH JUDICIAL CIRCUIT tN
AND FOR DADE COUNTY, FLORtDA
--=--
'
GENERAL JURISDICTION D!VISION

BOCA INVESTMENTS I 'LTD.
et cetera,
.
.
:
:
Plaintiff,
..
vs.
S~R~IS
G. SOGHANALIAN,
etc., et a1.,
.
..'...
.
.
.
Case No. 78-14372 CA 0.8
Defendants~
--- ------
- -x
One Biscayne Tower,
Hia-ni, Florida,
Wednesday, 9:30a.m.,
Septenber 12, 197..9 .
-:::.
't:.
./
COllTI~lUED DEPOSI'l'IO~ I
of
JOlm E. RALPH
APPE.T\RANCES:
ASHERETOFORE NOTED
SUITE :!%1. 81$CAYNC BUILDING
BERT
FRIEDMAN
OAlE
..
. 'TOM
LOMBARDI
GEND~ON
.tO WEST
FL.ACLI~ ST~UT
MIAMI, FL.OI'IIDA. 33130

TELE.PHONII 3718878
169
, ~1R. RICHHAN:
ca
}~
,2
Plea'se mark this for identi_fi'cation.
l11hereupon, a two-page document ,.;as marked as
.r,
..
Defendants' Exhibit 4 ~or identifi'cation.)'
Thereupot:l:
JOHN 'EDWA_RD RALPH
havin~ been previ'ously duly sworn, was examined and testi_fled
--;
furtber on his oath as follows:
DIRECT E:X"-RtN"-'l'ION
{Continued]
'9
'10
Q
11
12
(};
.,.
13
will ta~e up where ~e l~ft .of! yesterday.
Mr. Ralph, you talJ:ed a_bout- a machine gun cal_led

~be
'!l._l.~-"_-~.3.
n
. r
-I would 1.,_,
- - ~0
:..~e 11 us,
'f you wou ld I S1r,
.1~e you
~
\:-h_a'i: differences there a_re_ between the IJ.U-113 and tbe l!Bl-12
.,14
15
16
~e
All-H~
lJ.
The
.is a 50 Bro'tming, designed for: an aircra
Are there any similar i ti ~s betwee:o. 'the
t\IO,
so t_ba t
one could be con~erted to the other witbout great di!~iculty?
17
is
.b~ ~ny
more
sp~clfic
as to what the
d~ffererices are, to ~~en~ technical degree,
20
~ust
22
Can you
19
'2l
'
if you -could.
tell us what the difference~ ~nd simila~ities ~re.

A
t\'ell, tbe desi~fnat_ion. of: the
has a heavy barrel.
nBH2
indicate_d it
That ,is~ob~iously.not suitable, for

'
23
mounting in an aircratt, and therefore the barrel is co~plete y
24
different on
25
AU...;l13.
'!'he rate of fire is di_f_ferent.
How different?
Do yo~ know?
e
('i.:
-1
books.
.Q
~-=-
...
uh
I can't be precise without looking in reference
can you even approxi.rnate .it?
the rate of fi_re or is it fairly close or substantia_l_ly
different?
it is su~stantially different; but
to that.
J..
[-
I think it is
substa~tially
different.
couldn't
I understand
make a reference
..
Q'
Anyth;ng else?
The mechanism for fi_ring the weapon is operated
r.
"
10
(!'
-'
11
by a solenoid, electrically, as opposed to the IWM2, which
12
is opeiated
. Danually by a triggar
Anything else?
.14
The manual slide retracting groove i _s different
15
and the sight <]roup i _s different and the buffer group is
16
di_f f erent and the .ba.rrel nounting is different.
17
are di ,f ferences in the feed.
19
,.
20
21
22
23
24
Q~
-
--
25
..
r.~echanism.
13
18
Is .it like double
r.
170'
'::'h~re
. "Anyth_ing else?
There probably are other differences, but l
think
those are the Dain ones
With regard to the information you said that
was conveyed to you about the AN-M3, do you know whether or

not your lawyer personally looked at it o'r anybody .on his
behalf personally looked at it or inspected it to see \-lhat
was there?
OAI.( <OCNDROH
.e.
c'i=
.
...
So you have no idea at- all' as to whether or not,
fo~
whatever to the M3's?
example, there may
changes or convetsions or
'
No
.6
You have no "knowledge either
Yes.
Let us move back to the chronology.

I
thin~
wa~.
Is that
corr~ct?
we had gone into the month of September.
10
Again, before we _get ii_n to 1 'documents, tell us your best.
11
recollec.tion of what occurred relating to th_is transaction,
12
that you have not already tole us, in the
13
Is there anythi.ng else you can
t_hin~
r.~onth
of .September.
of?
.14
Which transaction?
15
The transaction that .is tbe subject of this case:
17
18
19
20
21
22
23
24
25
..
hav~ . been
not the
morta~
you already.
16
Q-~
~old
c ~~
f ..
don't kno\'t any more than I have
.F
'
171
.e
'
but the nachine guns.
I have reference to .
September of 1977.
A
~eceived
I was ,advised by the bank that they had
letters of credit for the nortar transaction and the
rnach~ne
gun transaction.
Q
That is the Brussels bank?
That's right.
Did they advise you in writing or by phone?
They forwarded the letter of credit.
Has that letter of credit---
0.\\.C GCNOROH
- - --------- ---- - -- ---- - - - - - --
- -- - - -
--
~-..,-------- - ---- -
...
--..
---~
-....-- .- ---------- .... --- -172
1
2
12
'--'
Yes.
Nell, there is ~ copy of the letter o~ teco~d.
"
Upon receiving that,
what action did you ta_k e, i _f
any?
11
~a~ tbe letter of credit relat~~g to the machine
10
-.
Both lett~rs .of credit.
-
guns in the a~ount of' $1,524 1 780?'
'A_
, I ~dvised M~. Soghanallan that I had receiqed the

1~7 l{B_H2
letter of_ credit for
.rnach_ine gun_s .
Wha~
He said tbat he wo~ld b~ prepared to handle th~t
did be
te~l
yo~?
supply i .n t _h_a t numerical quanti ty.

.Q
' l~i th respect to tbi s t _ransaction, otber than the
13
contract between Boc~ lnvestm~nts andUnited ~rade
.14
Internation_a l 1l.i_r Ca.rgo, Linited! that we. already had iden-.
\-
"
"
15
tified, ubich ~ou ha~e test~fied was ~igrted b~ ~ou and ~igned
16
by :Jr. Sogbanalian .in santo Dol':'l.i_ngo, \vere there . an~' other.
17
. ' d _ con .._rac-c

. d ocunel)
t s ?..
si-gne
18
r:tatter_s such as ' a Telex .that
19
):now if there was an_y tbi_ng else s _igned of wbicb you a_re
20
aware between the parties.
21
I J,an exc-u
- , d'_l.ng -..
~ rom m~
- ques t"1ons
\-7f.mt
back and' -torth.
I \-tant to
'A .
No.
I -can t;. _recall al)y furtber docur:tentation
'22
between t,l)e parties, apa_~t' f_rorn tbe fol_lowing _instr-uctions
2_3
that lJr. Soghanal_iall gave me_to .tra~s fer t _b e letter of
24
credit .to h~is bal)k in o~der t _} 1at .he .could - proceed \1itb tbe
25
;;upply.
( .}:=.
c --:
..
173
1
Whe~
you say transfer the letter of credit to
hi~
.bank, do you mean to give the bank the letter of credit or

to give tbe bank
.4
5
J
8-
10
C\. .
A.
~unds,
cash that :was involved?
liell, 'letters of .credit and documentary cx::edit
principles are very set i~ternational-ly and it was to transfe
on that part of the letter ?f .credit, which is_ api>licable to

tl)e
SUpi>ly
...
Di.d the%'e come a time when he insisted on, in
Q
eJfec_~~
receivi~g.
cash, as opposed to receiving a letter of
credit1or a portion of tbe letter of credit?
11
Xes.
12
l~l)en
13
.;_,.
was that'?
i\t the t_i_rne o! his delivery of tbe r.'latet"ial or
.14
all:eged delivery of the r:\aterial

I
Do you know the
16
I thint. t_he appro:dt:\ate date 't."as tbe 22nd of
17'
.18
19
'20
~~overnber,
.22
23
24
25
..
date of t_hat?
1977.
,
Prior -to that time, you indi'cated that Hr
Sogbanalianhad requested that the letter of credit be

tra_nsferred to his bank.
t::hel1 did he rna.l:e sucb a request?
21
eft
-:!=
appro~inat2
15
H0\-1
~.'as
_i_t_ :-:1ad e?
]l.s soon as I inforned him that l had received
tbe lette_r of credit.

Q
So t_hat would have been_ sor:te time in september?
:res.
OA\.C GCNCROH
c-
174
Let me hand to yo~ a copy of Exhibit 3 to the
complaint.
r'?
'.
I would like to ask you questions directly with
reference to that, so you will have that in front of you.
'
Let us go down the line.
If you would, sir,
please go to the first page with respect to the contract.
The contract changed, in that everything here relating
to calibre .30, in effect, was taken out?
9
10
Precluded from the transaction, yes.
If' we ,go to the second page--~f you woul~ flip that
11
over, please--the quantity that is referred to with regard
12
to the .50 calibre changed
13
""-
_)"
A,
.14
f~orn
200 to 197.
Is that correct?
That's right.
With regard to the price that is referred to where

I
it says "Price to be negotiated," '.:here it refers to $4,700
15
16
per piece, did that change or didthat remain the same?
is
~
.'
yes.
19
_I
Well, it did eventually change, but at ~he time,
.A
17
20
That did change?
Yes.
With respect to the freight charges, where it
21
says deliv~ry, it says, "But not to exceed 76,000
u.s.
dollars.'
22
Was there ever a figure agreed to or arrived at
23
(?..~
.....
...._.....
subsequently?
24
A
Yes
25
',,
,.. .....,.,,.. .,_... - ...- - -- ..._.,.._.,. ,... . .,_
OALC GCNCRO~
'
""'~~~ - ~- -~*'"".,_,,_....._..,._.,.,._,....
_ _,_,_,.__ ..,.., "
~~
..~. .-.-_....._...,* - a_ .,._ .._. __,-
__
.>It ~......._ '"' ' ~,....._,n _.,._..,,.,~Uit-=~...t-~,....:.;.
- - ~ -"'-""
~,'11.41~-~.,_ c:~.~..n~.-..
,.-..-. -+<.:- -11=
t :
.
..
0=
f::
175
fi~ure,
approxi~ately?
What was that
It is reflected in the invoice.
Showing you Exhibit 7 to the complaint,that refers
.,
4
5
Yes.
So then it did not change.
It remained the same.
Where there is a reference to, under delivery,
c~~~
'
to the same figure, 76,000?
It remained the same?
.within 60 days of receipt of an acceptable letter of credit

~ith
10
and export license being granted, the r?quirement
11
to an ac?eptable letter of credit changed by agreement of the
12
parties to cash, did it not?
13
Yes.
,14
Rith .respect to the reference to an export
15
16
17
is
19
20
21
22
being granted, do you have any
infor~ation
regard
lic~nse
at all to indicate
.when, with regard to'the 197 machine guns, ~fever, any

export license was granted?
..
Yes.
When was that, sir?
On or about the 12th of January, 1978.
.Prior to that?
Export license was raised
What I would
~ike
diplor.~atically.
to know is prior to
th~t
date
23
of January 12th, was there to your knowledge ever an export
24
().=
..;:.;:;:.
-
license granted with respect 'to the 197 machine-guns?

25
..
0.
- d
~~ ~
r.-
.. '
176
Z.1r. Soghanalian informed .us that an export
licen~e
bad been grax:1ted' prior to that date, but following i_nvestiga-
tions in Portugal_ 1 am advised that- no such ~xport 'license
' '
was ever raised prior to' that date for that, fo'r .this
..
Q
7
8
tbe one conducted by your lawyer in Portugal?

A
Is ' all .the information you have relating to that-
10
11
12
c~
i"
13
.14
.Is the investigation:

to which you have reference now
' ..
..
.the information .that was obtained by tb~t. lawyer, ~s opposed

to you oJ:>taining it personalJy from otber sources?
It \.;ras all obtained through r.lY lawyer.
So any .infot"rnat'ion on tbat 'Hould be in hi_s bands,
a:1y \-.'ritten_ docu-mentation or anything .l_ike. that be would have,

I
15
1&
17
as opposed to your having it pet"sonally?

A
.Q
20
don't ku6w.
Let me rephease
tb~
question.
Do you. have anything relat_in<J to J:hat Jnyestigat:ion.
18
.19
yourself?
.l\
No.
Do you have any i~ea 'at all wbat it is that h~
..
21'22
has in '\o:riting to support that?
l:o.
You said that an e)<:port license was raised on_
23
a~.
-::::
'24
about January 12th, diplomatically.
25
~rhat
OX'
do you mean by that?
0;
--
--
177
Well, the Mauritanian Embassy in Paris contacted .
.A
.2
me in December for explanations regarding the delay of the
sh;pment of their material . I told them what hadbeen told
to me ~y.Mr. Soghanalia~ and ~hat Mr. Martins-~~.
;::"
Then what happened?
The Mauritanian Ambassador asked if diplomatic
intervention should raise an export license,would it be helpfu ,
--
Of whom did he ask that question?
He asked that of Mr. Bigaignon and myself in
10
11
12
13
(t
What did they do?
,14
Paris.
Q
On approximately what date?'
The 26th or 27th of December, 1977.
Was anyone else present at this co11versat_ion?
UonsieurBA, Hr. Bigaignon and myself.
Specifically, where did it take place?
;..
'
At the Hauritanian
Embassy in Pa_ris.
What happened next?
I advised Mr. Soghanalian of that offer of assistan ~
What was his respon~e?
Hr. Soghanalian said he ~-1as still l:aiting for the
'
15
16
17.
18
19
20
export l_icense to be raised.
This was non-commital.
21
Q
l!0'\>1
did you contact Mr. So_ghanalian rega_rding
22
23:
that?
Was it by phone or by Telex?

A
By telephone.
24
c-~~:!-fl
25
..
OA'-C: CC:HORON
1-
>:. . . .
--
,_........,....._
,_
.. . ...
-..---~------....--
- ----..
..........
----~-
......-...-~ -
178.
A
..
I communicated again with' l~r. Bigaignon at the
Hauritanian Embassy in Paris.
co~versation
The substance of the telephone
with Mr. Soghanalian---
MR. RICID1AN:
(Discussion off the record)

A
(Continuing)
Off the record.
The Ambassador decided that they would
approach the Portuguese Government and they, I understand, did
that.
From whorn did you next hear relating to that matter?
10
To~ards the end of December,
11
12
13
,14
15
Portugal with Ur. Bigaignon and Monsieur' t;A ,af ~th~~~ request' "O'f . C
the Mauritanian Embassy in Paris at a meeting, having been
arranged
From whom did you next hear?
at that meating, I tal:e it.
rn~eting
Approximately Hhat date \-las that
I think the end ofDecenber or the beginning of
., Q
and r.eported
meeti~g?
Did soRebody report to you a_fter that rneeting?
23
A
Yes, Ur. nigaignon.
What did .he tell you?
24
'
pres~nt
back.
January, 19.78.
You were not
Is that right?
22
L___-_
expor~
Honsieur BA was present at the
21
. -
Gov~rnment.
20
25
Honsieur BA and the
licenses for defense material.
18
19
diplomatical~y het~te!:m
Department in Portugal responsible for issuing
16
17
I again went to
e.
1
'
,:
f:
I
,;
..
5- .,
Go~ernrnent
immediately.
had agreed to jssue the export
What next
Honsieur BA also :reported to Hr. Bigaignon that he
h~ppened?
6 ' was fUrious because tbe name of the Mauritanian people was
being Used in an attempt. to obtain_ an export license for defen
material_ far in excess of that indicated. on the End-User s
certi_ficate originally
supplied to 'Boca Investments for tbe
. .
pUrpose of this transaction.'
11
That is the si_x ite_ms to '\'Tbich you
12
--~-
I. think tbat that proba_bly
Tben what happened?
.15
~he
re_f_erence?
to those six
export license was finally authorized by
tb~
Portuguese Government- on O::' about 'the 12th of January, 1.97.8.
17
l8
19
all.u~ed
ha~e
i t.e_rns.
.14
16
:; _,
13
~-(
..
10
cf.::-
He told me that Mons.ieur BA had the meeting and
that the Portuguese

li~ense
179
...
!ro\~
do you know t:hat?
I was _informed 'by Hr. Bigaignon ,"" \-:ho had been in
tu~n -informed by the Mauritania~ Embassy ~n Par~s.

'
20
'2l
22
23
24
'25

L_ ______
Did anything subsequently happen relating to

'
..
that- license in the sense of do you knoH 't-lhether it still

exists,
A
~hether
it expired, or anything Of the kind?
-I immediately informed Hr. Soghanalian that the
export license had been .raised diplorna tic ally.
MY question ~as:
Do y~u know whether:~r not that
OAC.E Q(~OIItOH
--------~~------~----------------------------------------------------~
...
, ..
'
.. f ~
II' '
'180
.1
:license. ;is still valid, existing, .o.r whether it. has expired
2'
..
or
I
~een
withdrawn or.revo:ked?
'
'A1
It- was subsequently cancel'ed
:s
:A
In AI?ril, i97 8, :at the request of the Hauritaril:an
6'
. Government .
Q_
'
Wh'o{ .in. the 'Hauritanian Government requested the
,,
cancellation?
,,
l do
.Q
Do you :know ~hf they requested the canc~llation?
11
A_
1No.
12
'10
no~
know
.()~
-No reasons were given.
t.;'as any attempt: r.~ade on youX' pa_X't, on your beha:lf,
'13
or .by anyone, to your. knowledge, to 9et that license rein-
,14
stated?
A
.15
16
..
'No._ .
.P~t"sonaliy S?~ a copy of the license?
Did_ you. -ever
Q.
bid anybo~ thatyou kpow ever ~ee ~ popy of th~
17
18
l~icense?
19
"11.'
20
i
. 21.
!
-22
thab'he
'I don't know .

ror e:-caropl e I did your la,'l'ye~ in 'Portugal tell' so~,
pe~sonally
saw
~uch ~
ticense?
.23Q
In the :interveri~ng period between January 12th_ o.f
'24
.E)
..._=-
1978 and' the_ time the lfcense was cancel'ed .iP, "April of ~1978,
-25,
..
are you aware of any discussions by anyone with .the Portug~ese
Government re'lating to _that license up to the ti_me it was

: reque~ted to be canceled by the Mauritanian Government?
A
.,
So as far as you are concerned, sitti_n g here today,
the reasons for cancellation remain a complete mystery, in
the sense you have no information on that _point?
cancellation.
10
13
'
.14
15
16
17
18
19
22
If you would, go back to the exhibit to ,the

the contract, for a moment.
Contin~~ng
with questions that I asked earlier,
where it refers to inspection of materials, under inspection

facilities, i _s the only inspection tha\: took place by you or
Capta_in Anne the visit _in July of .1977, ' -..:ith respect to the
macbine guns?
.A
Subsequent to the presentation of the d~cu~entation
in Brussels, and that is the
on~y
inspectiQn that had taken
place, _yes.
20
21
I have never been told of the reasons for the '
complain~,
12
~--"
No.
'11
(""';
:'.
_,
' '
181
misu~derstood
you.
You are talking about July of
,
That's right.
Re discussed the inspection, 'then, of after July
1977?
23
of 1977.
()::.
--
'"""'-:::
Did you ever or did Captain Anne or any representat v
24
of the Mauritanian Government, to your knowledge, inspect
25
..
..
OALC: GC:NORON - -- - - - - _
----------- --..-....
182
1
( '=-
any other
A.
ma~hine
guns?
In 1978, there was an inspection of machine guns,
/!"::"'
as I'm led to believe.

Q
whom.
MR. ANDREWS:
..
at any _s ubsequent inspection.
tell YO';l about it.

HR. RICHHAN:
I 'dll be happy to phrase it
that way.
11
I was present at one inspection.
Hhen did that inspection take place?
Can I be, f~r the ~o~ent--- ln ~y broad esti~ation
13
l,
.14
of the ti~e, I'd say it was December or January, December
15'
'77 or January '78.
16
17
18
19
20
21
22
23.
-:;;:-
Fine.
If he was, he can then
10
12
c~.: :.
Let us ask him if he was present
...
(Y
Tell me when ~nd where that took place and by
A
Q
~~ here
did t _h e inspection you attended take plac~?
l-!r Soghanalian .arranged it i _n Lisbon, ~ortugal.

Hho was present at the .inspect_ion?
H_r. Hartins.
Anyone else?
Ur. H. J. Richnond, !1r. Sogbanalian.
Anyone else?
A,
Hyself.
Where did you go?
'
~f
you wou14, just tell us to th
24
best of your r~c6llection what took place when you went there
25
OALII: CCNORON
.e
183
for the inspection.

A
Prior to that time, I had insisted by telephone
co~versation to Mr. Soghanalian that we be permitted to inspec
the materials that he sa'id were available in Portugal for

delivery to 'the Uauritanian Government.
So you went- to Lisbon and then whom did you meet
there?
'
Hr. Soghanalian and Hr. Hartins, Hr. Richmond.
Q-
Where did they take you?
'
To,a military warehouse.
You say "military warehouse."
Do you mean one
owned by the Portugues~ Government in Lisbon?
ln Lisbon.
I understand it was a Portuguese Ar~y
dapot in Lisbon.
Were there fairly't1ght security precautions?
Yes.
We a~l had to present our passports at the
gate, so it is a ~atter of publid record.

Was there anyone fromtheMauritanianGovernmen~
Q
I
with you at that time?
No.
What took place when you got to ~he warehouse?
~:e ,.,.ere taken to see the quantity of 50 Browning
..
HBH2, which Hr. Soghanalian claiMed
Q
A
..
'1..1ere
h_i:s.
Do you know approximately how many there were?

No.
I didn't count them
184
a...=
.Q
oid yo~ note th~ c~ndition of ~hem?

From my sighting of them, Z.1r. Soghanalian opened
one of the boxes, raised the lid on one of the bo~es.
appeared t~ be in new c6ndition.

Q.
Then what happened?
Mr. Soghanalian saidi "This is yo~r eqUipment."
Then what happened?
We left the
Were there -any officials of the Portuguese
'
10
11
c....
qM
~bey
9
~ith
youwben
yo~
'.
Gover11men~
rnade tbat inspection?,

Port~guese
There were
~arehouse.
people whom,I think, were
12
conl)ected_ w.i i:h tbe depot, \'lho conducted us to a11d fror.l the.
13
warehouse.
-53.14
They \'lere military personnel?
They \-Tere in civil_ian clothes, to the best of ny
15
16
17
18
19
recollectiOI'\ 1 ~ir.
_or civi_li_an.
yo~
can~ot s~y wbether tbe?w~re rni~ita~y
Did
sea a_ny tripods .tbere? -"'
No.
Did you request to see any tripods there?
ur. Sog})analia1l said there \-laSn It time to go and.
20
'21
22
see any further .equipr:ient.
How r:iuch time. did you spend tbere?
Not all that long.
Were tbere any other inspections that you made'
23
24
c~
::~
':.
.,
25
..
OAU: GtNDRON
185
'1
at any time relating to this transaction?
..
~ou,
I am asking .about
personal1~
'3
A
That was the only one that .I made .personally.
either on be.hal_f of
~ou
or on behalf of tbe llauritanian
7.
8
9.
10
J'l..
Soghal)alian had arra.nged for inspectic;m for,
:I th_i.nk I am co~rect i.n saying Hr . Bigaignon and Honsieur BA,~:.
and then subsequent, a third i.nspection ~for Captain .A.n.ne.

Q
11
...
l-1~.
Let us talk_ about- Hr. Bigaignon and Nonsieur BA.

Did they in fact make an ins?ection?
12
.1'.
t understand so, yes.
13
You were told by them that tbe~ bad made an
Yes.
J'anuar:y of '78.
18
Did tbey see, as far as
19
esse~tially
20
anything else?
I was told by the.~.
.,14
15
16
17
'
'
~:1?
tin~y
'
re~orted
bacl_: to you,
th_e sa_ne thi.ng _you had seen or did they see
21
Yes.
22
'.i:he sa_rne tbing?
23
]).
24
How about CaptaLn Anne?
25
Februa;:-y, 1978.
understaX).d,
~es.
Nhen did be inspect?
186
1
4
5
Did he see the same things?

1 understand that be was -shown the_ H"Im2 machine
guns.
Q
0ere there
~nY
other inspections -that you can
thin_k of, thatyou are a\tare of, other tban \-:hat you told us?
t_~o
...
7
8
9
document in this case, if we turn to tbe paragraph under

. Payment--- Do
i"OU
have tbat- be_fore you?
10
Yes.
11
Did that portion change?

Take your ti_ne, i_: you \.;ould, -and loor. at it
12
""'
Referring to t.be next page of the alleged cont_ract
13
.14
15'
16
17
18
19
2Q
21
22
23-
tel_l us i:f it did and, if so, in "'"hat particula_rs.

;..
The payment terns
~.;oer~
conf i_r_m.;;d by 'the subs equ :;r.t
r.aisi_l')g o: t_he _lett_er o: credit- an_d the

::e~ui_renent
\v'as \-iaiv_ed
.......
~.~
25
licen_se
ban_k of that docu_ment ":-as ...raived.

Q
That 1s the nattet about whicb yau testified
ye_sterday?
Yes, that's correct.
Anything else?
Conmercial invoice
Ho\v a_bout tha
24
+H~~
e~po:::-t
.'Z'h_at is, -t;.e presen-:::ation to tbe
~equirenent
stat_erne~t
re.nain in effect?
with nine copies.
about t_he letter 'of credit
to be transfera_bl_e nox;-e than one tine?
( ...
a~d
Did that chaJ)ge or
''
'187
No.
.-.::::..
I think
tha~
remained.
...
Did the 1ast item on that- page.relating to;disputes
and interpretation of the a_greement ever chan~e by agreement
of the parties or did it remain
-7
8
9
'
.A
th~
same?
There wer-e no further changes
em tbat, .as. far as
I can recall.
You already indicated to us that at no time did
, you or anyone on your behalf re9:uest

with the provisicms of that
:ar~bitration
par~agraph.
~Is
in accordanc
t_hat correct?
Yes.
10
11
Your answer .is yes?
12_
Yes.
13
Q_
i\'e wer_e at th_at poi_nt _in ti::e before_ we we_nt into
14
t_his document.
One other thought occurs to
,vh_en
me~
You rnent_ioned the
-"le t_a lked ye_Sterdtly abOUt yo\lr CQmpal')y
16
director'S
17
Boca Investments,, al)d you gave us ~be name _of a Lady du -Cros.
18
Sir Claudeand Lady du eros, yes:
19
Q_
tiere t:here any other directors before the time
2Q
your brother bec_ame .a director .and t9ok over from the-m?
21
There was a Mr. Parry, but be was a very minor
_,
22
23
24
25
..
addition for a.brief period of time.

Q
Did you have three directors or two, or did he
substitute for one?

I th_in'K he subst_ituted for du eros, but I wasn t
OALt: GC:,.ORON
..
lSS
1
--
quite sut"e of_ the ti_Ming of it.

Q
Do you r.-now whether he had an intet"est in tbe
.4
A_
No
Do you
"2
-~now
,.;hether I under tbe laws of the Jersey

the~-director
s.
arethe":pe'opie! ~' :> l :.
:Islands that govern this,
that- actuall~' run a cor.Lpany, have the managerial s~y O%." not?
'
8
9
10
11
12
A
~how the~
suppose, on wbat they.decide,
decide to conduct ft.

am -not trying
to as].: you for a legal ,conclusion.
I a:m just t_ry ing to get_ t-rh.a tever infor:r:ta tion I can.
Do you know wnather or not tbis ki_nd of legal

~ntity opet"at_es under the -laNs of tbe United Kingdor:1 or
I
15
l a_m not
fami_l_iar 'd t_b that.
13
.14
Well, it depends, l
oper-ates Ul')der a particular la\'r relating to t_he
~_ersey
Islands?
16
17
Do you
~~nol
\:b=ther,. -under Jersey law,
~b~
nanagement
decisiol')s of a ~onpany a:re vested in tbe d~rectors or no~?

18
Do you
.}a-~ow
eith-e%." way?
19
X.fR.
11-NDREt~S:
Do -you or do you not kno,1?
Yes or -no.
20
!-don't r.:1ow
~1hat
.21
does stc11_it.e liners I:'lean \tith respect to
22
rnachi_ne guns?
.23
I th_in}: it is a process by Hhich the life of a
24 .
...
ba%,"%,"el is e8tendad by a line .of stellite composition.
.-:.!:::::
:..-::"1
25
~-
..
~t--4
-u
8(RT'
TOiot
FRitOMAN ~ LOM8AI'I01
"
, . , '"BA
l t js
'_1 89
......
.r.. -...
a sort of sleeve with the morta_r rounds that we have referred

.
-.
to ea_r.l.ier
Mort~r %OUnd~
s.
::.;
I_ u_n de_rstand so 1 yes.
In a ccordance \'litb tbe. United States standa_rds?
:t thi_n k it _is to
tha~ we~e ~anufactured
actUall' in
UR.
RIC!.iH~N:
N-~TO
specif_icat_ions.
I:is. Reporter, please
l':'lar'~
that as
Def_endants . .E~_bibit 5, plea_se.
[1~herefipon,
10
as
'11
D~fendants'
'12
t _he document re_ferl:'ed to was,
E~blbit 8o~ 5
for identification.)
Could _y ou just ieent_i_fy Def e~dants E~_hibit :s ,
sir, and tell us _i:f that is _you:r
13
r.~ar~~ed
si~fnature
appe'".ring
,14
15
16
f7
18
19
,e.
Yes, si_r.
:I_s th_a t a docu_= nent you
I
I
~'
~es ._
D_id you personal_ly verify the
i _n connection ".:_itb-
nortars?
.:.:_r a~~ a o t _ion
in;o:x::~a~ion
tt:.at
".-:'as sat fortb in there?

.A
20
21
reci_v~d
Hr. Polla_rd 1 David Pollard brought those docunents
in .his safeke-~ping frorn Lisbon to bntHe_r p.

Q
Fitb. _respect_ to t_be iterns t _hat are set for'tJJ.
2_2_
there, let
~e
sboY you one other
i~e~.
2~
U.R.
.24
..
- ~
RICS~ll>.N:
substituted.
, Hs. Reportl:!r, t will get_ a copy
tet rne ask you to mar~ that as Defendants'
2_S
_ OAI..I: GC:OCORON . _ _
''
1
{
'
(ftberetipon, the
'i::..
-..
3
4
5
6
'
7
8
9
.10
Exhibit 6.
a s Defendants' No.
Q
doc~ment
_1 90
referred' to
w~s ma~ked
,fot_ idel)ti fica tion. l
Let r.\e hand you Defendants E_xhibit No . 6, si_r, and
as]:: you i_f you can identi_fy tb_a t documeZ).t for us.
-A
Yes.
"'
Ha_
s tb_a t- a certi_ficate re_lati_ng to . the transaction
_involv_i_ng tbe r:torta_rs?

~
Yes._
~~ho o}?tai_ned ~bat,
Do ~ou bave ~~Y reason wbatsoever to do~ht 1~s
si_r, from t _h e Portugu,es e
11
12
13
14
15
. 16
17
have no idea.
au t _b enticity?
'I).
No.
.Q
-I note t _here _i s a -re_ferel).ce be_re to
_io, 000
r.ortar
_rounds.
that
wera
.- .
-
18
deliv~red
- -
ca_r.'le from the _l ot t _hat _is refet.r.ed to ther.e or not? Do you

19
know either way?

20
don't know.
21
Q_
- re_fer~nce
on _De.fel).daZ).ts
22
E8hibit 5 to $310,000 O.s.

23
l _s that tbe a_nount th_a .t ,.:as paid for t _he 5, 000
24
\,
mortar rounds or a n ar\OUI:\t t _hat was to be paid .for a greater
c..:;~~:
"::.om;
25
".
- -~ (! ~- --------=--- - -
,1
1_91
a mount of mor_tar roul')ds'?
-;,::
That related to 5,000.

you ma_rk this
(~bereupon,
5
6
Def_el')da_nts'
-7
E~hibi t
tbe document xeferred to was marked as
~~o.
7 for _i dentification l
Let rne hand you Defendants :Exbibi't 7 and as]:: you
-Y es.
,A
9hat is it, sir?
11
T he 3 0 cal i_br e Browning
12
Do you
~es.
Yes.
t, ben did you_ send :it to hi::'~?
~I
Tb~
13
_De_fendants'
_i J you can identi_fy that: for us.
10
a~
txbibit 7, please.
...
~;iould
Z..fR._ RICHHAH:
~now
19 _1_.92\~.
-from wbere tba document came2
Tbat was sent to
~r.
Soghanal~an.
..14
15:
- 16
17
}th_i _:ok it \..,.e_nt \-:ith the draft cop~' of the
18
19
one that has been
pr~vjously ~arked
as
Def end_a _nts Exh_ibi t -3?

20
2_1
~o
tbat actually accompanied
that~
2_2
A
Yes.
23
Q
Could _you tell us whe_re you .obtained t _bat.
From~
24
( .....
::..."'::~
:..-::.::::c
2-5
..
raference book produced in England, O.K.,
CAlC:- GC:NOROP4
192
..
1
called Jane's.
,.,
Is that Jane's anything like
Jane~
righting 'Ships?
:.;;-:
F.
The same prodtiction company, yes.
What is the name -of the book, specifically?
'
I~
t;
t;
Is it the
sar~~e
company?
Do you recall?
think it is Jane's Infantrv Weapons.
Do you consider that book to be authoritative?
~~
10
'
book of defense materials.

Q
11
12
....
13
It is recognized worldwide as being an authoritative
Do you know if that book was current?
words, was that the latest edition cr a late edition of that

boo~:
at that ti:.1e?
A
.14
Yes.
Defanse's
16
'
D ef endar.ts
20
21
22
Let us
C~hiti~ Co~posite,
.24
.~.';.."':.~
...~~:
25
tb_is r:iad:ed as a
::o. S.
& two-page docu~ent was nar~ed
Exhibit ::o.
ac
.for identi-:: ica tiQn. l
uould you identify Defendants'S for us, please,
Can I?
~o rna~e
sir
it
simpl~r,
is that part of the same
letter tbat was sent and is that also ~ docunent from
23
.'!!.
bav~
19
'
curtent
~as
[ftheteupo~,
17
It
:.m. R!Cm:;~N:
15'
18
ln other
Jane s Infantty
A
.Yes
~:ieapon~?
1_93
1
..,_._
Would your answer be the same i _n terms_ of th_a t
being a current and aut_horitative te;;ct- t _hat you wou_ld a ccept_
an~
'""
;:..
Yes.
t;ias that the i _nform_a tion you "-'ere sending to
~~-r.
Soghanal_ian speci.fical_ly with :regard to this transact_ion, as
to tbe ty-pe of_ m aterials_ for wbich you "1ere looking?
;:..
Yes.
Is t _bat your signature that appears on beth De_f-endaz:-Jc.
10
Defendants' 8?
~nd
11
Yes.
12_
~as th~re
13
"
reiy upon?
a~y
particular
r~ason
why you
sig~~d
both
of t _hose?
.14
/:..
~o,
just as _a confi_rt"'ation t)).at_ it .!)ad er::c.!'}ated
-You
h~Vt!
f5
16
f7
take:::. us th::ough the nont_!) o:_ Septe:;-,ber,
I_ bel_ieve.
18
19
20
21
22
23
24
---
~bn~h
of
Sept~~ber
that you have not already told us, in
1977?
A
:~o,
I can 1 t.
:-1R.
RICiH-1~!1:
please.
~bey ~re
Z1s._ Report_e_r, could you r.1ark t _l;e_se,
two pags.
as Defendants' 9 and 10.
~--
25-
..
OAt.[ CC:NOAON
Pleas~
mark
~hem ~~spective
194
[Whereupon~ the do~Uments'referred to we~e ~arked
( -~;.~
as befendants' ~xhibits Nos. 9 and 10~ respectiqelJ, for
identification.)
Q
Yes.
'7
"hat is it?
8_
1;.
T})atis a commercial .ixrvoice.
10
11
.~~
Let- me fi_rst hand you De.f end ants' 9.

Just identiJy th_at for us, please, .sir.
12
tbat
~elating
to what?
5,000 mortar.
'!'bat i_s _your signature and that of Hr . Soghanalian
ap~ears
1\
13
'14
there1
(-; e 11,
Soghanalian'~.
it i s
r.ly
sign at u r e , but I can t
lS
17
18
~ ~-r
I.
t;:ho a_rri vee at that total l..nvol.c~ value of $4 4 ~, 0 0 O'?
ii!)_o a r r_i v ed at t.ha t

tba~
see
lt is rny signature.
I
16
f igur _:_?
ln oth;;r
~:ords,
from
ftgure come?
A
That carne .fro::"~ th~ cost of_ the losses

a_nd fr~igbt._
-
T_hat is not t_he figure that ~ou paid, i_s it?
.~
19
!f~.
.1\HDRI:f:S:
To '\-:hom?
U_R.,
RICU!~;.:::
~o
20
21
anyone.
~bat was th-e figure t_hat the !laul:".itanian Gover_nn~nt
T.he Haur.i tan ian Government paid $4 4 5, 000 and you
22
23
(
~If~
24
\::fi:~f
essentially paid $310,000, plus the cost of freigbt a:)d
25
OA\.C G(NORON _
195
1
whatever incidental expenses there \-Te_re related to that.
ls that essentially correct?
.-....-
Yes.
How about No. 101
please.
That is an air waybill.
Relating to what?
5,~00
Was that delivered in accordance with that?
10
Yes.
:.m.
11
12
...
AHDRI:~l'S:
t~as
that delivered?
In othar words, were the 5,000 mortar rounds
d&live::ed in accordance Hith ..~~a.t .,.1as set :orth with that
.14
air \{aybil'l?
15
Yes.
16
~as
., 8
19
20
21
22
23
24
'"i:;:::::
25
'.
mortar.
13
17
('
Would you tell us what t _hat is,
t::an~action
.\
e~port
license obtained
~ith regar~
tc that
frow Portugal?
'iell, tha e:(port license !tr. Soghanalian.
was the one

Q
an
~:it_h
What I
pre~ented
the 10,000 quantity, 10,000 on it.

ar.~
t:r_ying to
deterr.~ine
is \-:as there a
sepa_:tate export license covering -this transaction, '"nether

it covered -5 ,000 or 10,000.
covered the export of
A
~ortar
t~as
the_re one license that
rounds, to your knowledge?
Yes, I understand so, yes, but I had no knowledge
of it because
didn't raise it or didn't present it.
1_96
...
'.
You w-.ere not_ involved in
'Hay i11 9etting t})at
export l _ice_nse?
getting _it?
fto, no.
Did you ever see an export license .relating t9
7
8
this
11
12
13
Has a1}ybody on _you:: behal_f _inv-o lved in
We
g~ve ~be ce~tificate
to Mr. Sog})analin.
~ransaction?
--- previously indicated in yesterday's testi_
As
'r.tony ._
I ~ay be confusing that witb ~o~ething -else.
'Q
.do not rnean to be repetitious.

ca~ ~ou
10
..
~ any
~e
just quickly tell
wbat 1t is
~o
whicb
you ~~e referring, to ~efr~b rny recollection.

AI)_ export
a_r:'lr:-.un_it_ion, 81
r.'li::'\,
l_icens .~
{or 10,000 pieces of r:"tortar
for shipr.el)t to ..:-:aur _i tani_a \'fas presented
.14
'
15
'16
17
~une.
dated May or
-,.~..,
"'""-
ref_err_i_ng.
One t _hing ; "Addit_ional R:lceived
A
18
or ~
~ e""'
_,,, s
'V _i_s_ion D evises,, 1 Hight' Binoculars, 5 t~a_l~ie '!'al(.ies,
tSo
19
Colt 3
20
scope~L-~
This.
i~
cornpletaly foreign to rne, l'rn
2_0
afraid.
I con t recogni_"z e_ t:hat at all and tb_a t \1as added
21
aJter.
22
You never received any such {terns?
No.
Can you recognize for us tbe aignature of th~
_23
I
............
--
2_4
2_5
..
0"\.C: G(NORON
197
1
~~~~:
official who appears to have signed and added that?
~~o
tvould it be fair to say that you have absolutely no
knowledge at all as to how that got on there?
Absolutely.
Do you know what that means on here, where it says
"NBT" or anything like that?
like that?
Have you ever seen anything
No.
10
Uhen was the fi_rst time you ever sa,.; this air waybil
11
Five minutes ago--l'rn sorry--in that form, :ive
12
::'linutes ago.
13
.14
Hav~
you seen
o~e
previously that was identical
to this \lithout that additional
inforr~.ation
on there?
15
16
17
in ~he first instance to the bant in Antwerp by Mr. Pollard

0:1
~~hal :f
20
21
22
23
....
24
..
25
of l!r. Soghanal ian.

Do you know who
18
19
That loo}~s si~ilar to the one t_hat \.,as presented
prep~red
this d6curnent, aside fron
the additions that you say you had not seen before?
No.
Did you acJ:no.,.:l ecge and recognize that the s!'.ipper
was Boca Investments Limited with regard to this ~ransaction,

as indicated?
A
Mr. Pollard asked rne to sign as the shipper and I
said, "I am not the shipper, ~r. Pollard.
~
u
8[RT
TOM
f'RI[OMAN ~ I.OMBAROI
'
l'!r
""'D"" '
I arn the consignee "
'.
And !-1r. Pollard said, "That's right.
as
signed
th~t.
You, signed l."igbt there, ~nowing it: says- "shipper"?
]).
Yes.
.Q
Did you do the same thi_ng wit_h rega_rd to the r:'lachine
Yes.
9
10
11
n'
consi~nee,"so I
'!'bat is why you sign,
,,
198
guns?
Cap. you give us any reason as to 'Vlhy you_ ,.,ould sign
as _being the sh~pper, ot:._hsr thal) your stater:~.ent tbat
........
~
t ....
Pollard said you were to sign tbere?

A
i~o.
It w-as a ::-equest_
H_::-. Pol_la_td had .made and be
shi!>mel)~,
said, "You are not 1 i_abl c =or
13
to be indicated .as so::1eol)e ot_he::- than l:~it' :rae~
And I
,14
sa~d,
"
- ~-n.
. . a s h.
' er i_s
_.l.pp
t~~a "C._
12_
('(fT!).
"I can't sign tbn~.~
15
16
17
18
19
20
or go a_haad a;::1d sign?

A
Hr. Pollard said th_at the consignee had to sign

'
21
22
23
,-
24
..
i_n that portion :o; tbe docun-::nt and

~ortars
25
..
t:1e
to A~r Trad~ (U:l) for shipment.

Did you consider the title bad'passe4 to Soca
lnvest:-:\ents?
.~~
.,._~-
He \~ere co:).signi.~g
On the presentation of acceptance of tbe ai_r wa}'biJ,,
OA\.C GCNOIIION
;:;;;:.
(
3
yes.
Q
199
So a _s fal:' as you \o7e_re concerned at t _he_ ti_rne that
this ai_l:' ,.,.aybi_l_l _ wa$ executed, presented, Boca Inve_stment~
.4
5
it .to--as you say "consig-ning"--Air Trade (U'l'l) ,Limited, for
shiprnel)t?
7
8
9
10
Yes, _ir.:irnedia te_ly, and then i _m rnedia tely became
the p:z::operty. of t _he_ Hauri tan ian Govel:'n_m ent, also.

Q
It becar.\e tbe property of th.e Ha\l:t"i tal) ian Governl'!'le%) t
at wba t point .il) ti_me?
11
12
-....
13
-411:~:
14
~~ould
the .sarne presentatiol) told true a s far as
you were concerned witb regard to tbe 197 macbii:le gUns?

/:.
Yes.
15
16
guns, b_ypothetically, axe i::l exi_ st_ ~l)ce a t al_l .i _n accordance
17
\.,.itb any of t _he docun_eJJ,ts in this tra_ns-action, i _f .they exist
'18
i _JJ, Portugal or \The_rever they exist, :ollo~;ing tbat sar.'l.e line
19
of reasoning,
.20
21
22
23
... ~:.
.,...:.;::
24
25
..
--
~our
position woUld be tbat t _b e machine gun_s
are t _he Pt"Operty of' the ~1aUt".itanian Governnel)t?

'A_
I ca_nt--- I t _hi'hk it is a _leg-a l opil)ion a11d 'I
cal)'t really
Q
rna_~e
a legal opi_niol).
CI undet"stal)d.
t am l)ot_ askil)g "you to
rna~ e
a _1 ega_l
opinion. -I am asking you, i_f you cal), to simply state _your

position.
,., -
D41._C CCHDAOH
-200
f
I mean, following iogically
f~om
what you have said,
if you operated under the belif that title passed at that

3
po~nt,
and if they \V'ere there
waybill was executed and presented to the ban].;, then title to
.what
a_rn asking you i_s if tbe machine guns existed
at
that point .in time, once the air
, the machine guris woUld have been considered by you to
ba~e
7 . been passed_
. at that ti_me?
!.
1\
It
passed throUgh Boca
i;1e
have gone throUgh September.
10
"I~et
Can you
t~ll
Us, other than
~atters
12
already covered, anyth_i_ng else t_bat o.appe.ned
13
October of
.14
to !-:auritania.
us move into
October.
11
...
ln~estments
s.
we haVe
in
tbe :1onth of
~977?
Hell, can
Certainly.
\~e
jUst
~e~ert
~o
bacr.
Septembar?
15:
16
f7
18
'19
20
21
22
23
-~
,_:-
ls
ther~ so~Btbing e~se tb~t
happened,
i_n s-eptenber?
A
~mend~ents
~hen.
we
~rrived
totl).ose
at the bant, the bant
;~gfiired
documents~
September?
~n
1\.
Yes .
tlh'en. _you say "'Ne arri ~ed at the ban}".," who
~as
present?
Da~id
1\
Hr.
Pollard and myself.
,Q
With whom did you
~peat
at the bank?
When you
24
say "bank," I. presume. you are referring to the bank in r.russels
25
'-
201
1
t -
Yes.
Wbo was present
-::l_r . Pollard arid rn:ysel_f.
t t'leant
The docurnentary credit section of tbe bank.
'j
-Do you ].:_no.,., a _n_y body in particulat: there_ that you_
wet:e dea_li_ng . with
~-1!).o
-at~
a~
tbe bank?
was present_ on pehal_f of the bank.
t _hat
ti_rne~
l-1t:.- Gt:af.
10
Do _y ou know b_i _s _full na_rne?
11
[l.
~0 -
12
}\n_yone_
13
No.
.14
Te_l_.l
rna '\:hat b_a ppened at tnat - ti_M~
'!'hey
l_ i_sta~
1~
16
18
19
20
21
22
2_3
el_se~
wrote t _}).arn dO\'I:l a:J,d we

. Q
17
that correct?
'2
..-o;:;.;;
~s
'
a nu.m ber of a nend_nents
t.~ad
_-;:.=-
25
1-il')en you say you had .co h_av e
..
Hr . .Pol_l_ard
t_h~n
don_e , t-1l:at C.iC. yo\:
do?
'!>..
Ne_l_l, certain docurn_ental:'y crecli_t procedures ,.,.hich
have to be observed and ol)e or t-..:o spellil).gs a nd things

which bad tri be corrected.
Q
\1a_s th_a t _tak_e n cax::e of?
Yes.
Oas tbis
~elating
to the
to tbe
~acbine
~orta~ ~o~nds,
guns?
r~
-
~nd
to bav e t _}).o s e clone.
24
...
8(1U
u '-9"'BAROI
TON
~"I(_OioiiAN ~
OALt GtHOROH
as opposed
202-
,t ~
Yes.
2_
'
tal~ing
tha~
6
""j
....
so.
-I wanted to make sure
that is what we were talking
)s there
_I
thin_~_
abo~t.
that _i s_ a_ good _idea.
an~tbing ~lse
that
b~ppened ~ben?
0e
no~ mo~e
into October.
Tell_ u_s \1bat: ha_ppened ix:t Octobe_r.
'10
11
ass~me
No .-
8
~
11-_R. ANDREliS:
Q
Septe~ber.
tbat in
~1R. R_Ica~1AN:
4
5
abo~~
Ha~e yo~
_f inished
September?
12
;..
Ix:t con_n ection wit_b \\'hat?
13
Fi_rst,
ha~e
you f_ini_sbed everytb_i _x:tg you ca_n t.h_i _nk of
.14
15
actions?
16
17
posed, I
:II
.20
21'
2_2
2_
3
\ ,__
24
25'
assume?
'l'!{E N!oT~fESS:
18
19
~:ould
Gow
w~ mo~e
Yes.
Octob~r.
on to the month of
Other -than what: we

-to tbe rf:achi_ne g:un
.Y es, I have;.
ba~e alraad~
tt:ans~ct_iol)
or to t _be
covered relating
~ortar
t _ral)saction,
can you tell us anytbing else tbat tt:anspi_red _i _n the mo.nth of

October re_lati_ng to e_ither of t _b ose .
t\lO
transactior:1s, t _h at
you can _recC'.l_l?

HR. AUDREt1S:
Cal:l he _recal_l i _n additiol:l_ to wbat be
203
1
{
--
has previously
~~~
testified?-;~.-,~
MR. RICHMAN:
That is exactly what I have already
said, other than what you already said.
tq be repetitious.
payment.
Q
With rega_rd to which transaction?
The mortar transaction.
H0\-1
10
A.
He told me that they would have to pay additional
~elocation
made?
charges.
On what basis?
13
On the basis t _h at he moved his ai_rcraft from Lisbon
.14
to Athens and, further, t _h at he noved it from Athens to
15
Portland, l1aine, in America.
16
Did he tell you why they had been moved?
17
l\
He said it \o7as because of delnys t _h at ha.d been
caused in this transaction.
19
20
21
.22
23
24
~e_rnands
'
II
were these
12 '
18
..
ur. Soghanalian made additional demands for freight
11
..
I do not mean
25
~er~
caus~d
Deluys
on the part o: whom?
P.e clai_rned
Did you agree?
No
Did he give you a reaaon as to ~hy he said they
th~y
\.;ere caused by Boca Invest::'lents.
caused by Boca Investments?

A
Ho.
2 04
1
'
";.How'did l1l:'.
Sog~analian.
contact you regarding thq.t?
1;;as it- by pho%le?

hotel~
He was in tbe
~he
-A
In Lisbon?
'7
)!'es.
;..pproxi_mately when did that rneeti_ng. take place?
A.
~eginning
~h~t bapp~ned
10
.11
12
13
,14
15
16
17
18
hotel
~h~ie?
Estoril Sol l;otel.
'
of October.
tben
~egal:'di%19
~his
=atter?
How was
it resolved?
;..
I \:ould :ra:ve
t~
assur..e the re.sponsi_biJ_ities for
e;8:-pec1iting the delivery and

Gove~timent
na~dng
su_re .that the !lauritania%l
was not tinduly inconvenienced, and we agreed to
pay t_be. cl)arges.

Q
,A
}!ow nuch \.,.ere they, approxina t-aly?

I think_ t_l)ey
~-:ere
l)Ote.d
0%1
the invoice for tbe
mortar transaction.
AS soon as you fin_ish -thi_s li_ne, coul
19
20
\~e take 'a short five-minute bl:'eak?
21
.~et
me just show you that al)d ask you if t!1at is
22
the figure about wbich
~'OU
23
charge?
24
( .~
A
25
..
$39,200 in total.
a_re t_al}:i_ng.
Is that the relocat_i n
--
Th.at
;.._
Yes.
~tas
lfR. RICHHAN:
[Recess
6A 5
6
:l
..
~1e
ta_ken~
~nd-User
certificate?
1).
Yes.
Where or who got tbAt
.;,.
10
b_y tbe
11
12
15
16
certificate?
:~1aurit_an.i_an
~hei.r e_rnba~sy
'Gove_r nrnent-":"th_rough.
Do you know whetber or not ib
~elated
in ?ari.s.
onlY to tbe
81 r:irn rnortax:s or did :it cove_r any ot_he_r it~~s?

'
:S,ooo
Sole.ly to the 81 r.'in mortar,
13
.14
~nd-Use~s
:.I t ,.;as given to B oca tnvest.rnel').t_s--Boca Inve_stments
~ ~
no,.,.
t;;ith regard to the 81 mrn mortars, was there an
breaJ~
can take a
'i
quantity.
Did you supply tbe ca_x:x:ier wit._h that?
1 gave
0hen did ~6u give it to bim?
~t
to nr.
Sogh~nalian.
17
18
U:R. AHDREt~S:
19
(Discussioz:l
20
21
22
( -
ux:.
24
,.;;,
25
--
~ ...:.._
___
of_~
the _record)
on De.fendal)t_s' Exhi_bit _10 tbat are
are two brothers?
Ol).
nigaigl)on, I assurne
Karl in all of tbese

~
off t .be record .
Let rne as}'; you \-lith regard to t .be va _rious
referr _i.ng to
23
the additional arnount you agreed. to pa_y .'?
..
'205
transac~ions.
t .bere.
~ou are
Is tbat
lz.
... e_
rns
l;hen you .are

referting to
~igbt?
There
206
No.
For clarification, when you have testified
pr~viously
inspected weapons in
things, is it the same Mr. Bigaignon to whom you were
referring or had they interchanged and involved in different
parts of the transaction?
to Mr. Bigaignon being the one who, fot

Po~tugal
..
!n the main, it was Mr. Karl Bigaignon.
Who was it, for
e~arnple,
'b
l:lr. Karl Bi_gaignon.
12
Do you
.14
hav~
any idea how Nr. Karl Bigaignon or
his brother uere conpensated for the things they did in

:::elc:tion to these ar::ts transactions?
15
16
'17
-.
18
19
that made the inspection
in Lisbon?
11
13
exa~ple,
and did a number of different
10
.....,
Mr. Guy Bigaignon, also.
Yes.
Hm1 '"ere
Boca
Did you have any kind of contradt or was.it on a
~_he_y
co;r~pensated?
Investme~ts
paid then.
fee basis or what?

A
There is no contract.
Can you give us any idea at all as to what kind of
20
It was just a fee basis.
21
fee it was, for
e~anple,
on what they did on the 197
22
guns?
23
A
I don't recall.
Can you give us a ballpark figure?
24
,,.:._
\ .._..:;.
25
..
DA~C:
GtNDRON
~achine
'207
'
~~~
~o.
You cannot- even tell us \-.'hether it was more like
5,000 or rnore li~e :SO,OOO?
You do I)Ot have an~ idea at all~
4
;..
6
7
s
9
10
11
12
.14
15:
16
17
-18
don t recall.
~ere
!.think so.
Do you have any record of \V"hat they we_~e paid?
Gob
Do, you know anyone wbo \.fould have such_ r_ecords?
A_
Yes.
Hho iias
~he
;..
:Sa nque.
i1hy i-toule they have t_li,e records?
l1
They just !)_ave it on reco::-~ z:.s a paynent that \:as
they paid
person~lly,
fee, as opposed to a
pe~centage?
no.
~hat?
bank.
--
paid from Banque

Q
Do you
B:::u:~ e ~.1
e s Lambe.rt.
:s~uxel_les
k:)OH
La:-:t;:,ert.
iThether or not H:t.. :si.ga_ignon', eit_her
19
one of tbe t\vO, accot'tpanied tbe -shipment of tbe mortar roui)dS
20
to ;-:auritania?
I think Mr. Ka~l ~igaignon did.
21
Yes.
22
ln that .sense, do you know whetber be, for exa~ple,
23
was tl):ere \lhei) the goods ,.,.ere _received and accepted by t_he
24
Mauritanian officials?
.........
25'
13
......
'
..
;..
I don't know.
I _ wasn't tbere.
.e
Q
Did be. tell you whethet' he wa_s?
X don't recall.
But you do recall h_i _m tell_i_ng you he
208
w~s.
on tbe
a ircraft?
Yes.
~~as anyone e_lse pt"esent besides tbe aircra_f t-
ere~,
to your knowledge?
~
do~t ~no~.
Q '
Re have gone ~hrough bctober.

_Is there anyt_bi_ng el_se _y ou ca~ tbi.n~ -of ,in the. rnontb
of October, 197.7, to which you bave not a _l_ready test_i_f i _ed?
~an
The de_livery of the r:to r t~a_r s \fas made.
That occurre_d _in Octobar?
Yes._
I
t\'i t~ _regard to Octoba_r, is the_re X)Ot})i_:)g ,el s e you
think of?
,A
l .f not, '-:e '~il_ l move to !~ovembe_ r.
I Hent to ~iashington .to bave the End-User's
cartificat~ a~4
bSP 83 ver~fied.
aho was present with y~u when youwent to "asbingtoti?
Are these_ t _he End.:..user' s c-;;_rt_i _ficate_s t _hat you
r~fer_red to as h_
a ving been sta_rriped b~' t _ha ,Haux::_i t_a nian. E_n bassy
and for,varded to Hr._ Soghanaliai)?

~
They were enforced by the Mauritanian Emba~sy in
t~ashingtoi).
209
. It was an
Has there a
Yes.
~;;hat
form or was--;...
~-1aurita])ian
11
8 3.
Q
DSP 83?
13
Yes.
14
fthat did you
inst~uction of !~.
23
(
24
~-:....i
wh~ t
Stat~
go~
once you
safe~~e.eping
Department For_m -DSP
the DSP 83
e~scuted?
of our o:ficer-s or.
s6gha])~lian.
Oas tbera'inytbing to b4 done r~lating ~c the
.Q
_letO::.er of credit Ol:' anv letter of
cJ;:"edi~
.J.
at or abou. t
~_hat
tiJi'l ?
l don't_ reca_ll.
.. fOl:' just a
.
rne])ticned earlier you
Let me
.Q
You
21
22'
~o
Gave it to the
19
20
In_ othe_r words,
Has it O]) an ]>.merican _form, Portuguese
E_mbassy i_n Pari_s and a
12
18
certificate?
It was the :End-Usel:' certi_f icate issued by the
10
17
we speak_ing i])_ the plural?
\'las the certificate?
kind of form was _it on?
16
,,
singl~
15
'
~>.re
End-User~.certificate.
.9
these~
"bat End-User certificates were

.HR. ]>.UDREl1S:
digr~ss
moment
hnd traveled around
to a ])Ur:\ber of different plac~s wh.en you were in tbe United

States
~nd
Santo Domingo in
~uly
of 1g11.:
Did I gathel:' correctly that you ~... ere rathel:'

displ_eased and felt that that ,.,.as very nuch a \:aste of. tine?
25
..
OA\.1: GtNOIIION
210
~~
-1).
Yes.
2_
'Did you ever indicate to the contrary to '1-1r.
Soghanalianl that you were pleased and than~_fu_l for hi_l':l
baving gone to tbe_ e_xpense?
..-
thanked
Sogl).analiaiJ,.
"
Did
_you do so in writing or verbally?
l~ell I
10
11.
12
13
1~e
As a rna'tter of courtesy 1 yes.
.... ,
1).
;14
'15
I thanked h_i_rn ver_bally at the end
of
~1r.
the
inpection aiJ,d tben, probably subsequently, later, in a

_letter.
Q
Did you indicate to hi_rn. tbat- you appr_eciat.ed
t-is courtesies and
~he
great e:{peiJ,se_ he went
~o
to take _you-
arouiJ,d to iiJ.spect a_l_l t_l).e _items?

;.._
Yes.
You said that to bi_rn, but i::n.:ardly you were -rea_l_ly
Let- me get one ot_b er i tern out of. tbe
He
t_hanl:ed him.
I
1~
f7
is
UR. RICH!~.t:.!r:
19
20
'Ha~.
'
us. ~eporter, Hou_ld you ba ve that_
marked as D~fendants' txbibi~ il;

[Where~pon,
a 16-~ag~ document was marked a
21
22
Defendants.' E_xb_ibit Ho. 11

Q
~or
identification.)
-.
Let:. me hand you a composite exhibit, oe:endants
23
Exhibit ~~o. 1_1 1 Hb.ich appears to be a complaint fil'ed in
24
'.-..f!.~
I'
'
t_he Federal Court or a copy of sucb col'lplaint . 1 would just

25
..
~st
211
if you can identify that.
2_
Yes-
Is -tbat- a tr-ue and correct- copy of_ a complaint-
that was ~iled in'Fede~~l Court ~elating to this matter
before the present State Court ~ct_ion was ti_led?
Yes .
:-j
I_s that_ your signature appearing at page 8 and
_.
8
9
10
11
12
,IHO
notarized and S\.Yorn to?
'A
'{es.
Di~ you re~d that complaint,

pleading,
before
it
'
'
was filed and all of the a~l~gations contained therein?
Yes.
13
.14
1S
under oa~h at tbat time t~u~ and correct?

-
..,.
'A
As I recall, _yes, to t_be best of roy bel_ief.
Uas there anytbing else- in tb~ month of October
'16
you can recall?
~J not, we will ho~e to Nov~=ber.
17
'
18
19
;_..
No.
In t_he r.~onth of i~ove_mbet', 1977, telJ us ,.,.bat you

'
ca%'1 -:reca_l~ b_a!>pened at that time relati11g to t_he 197 r.tach._ine
2Q
gun transaction.
21
22
questions, a_s opposed to these broad, overall- questions,

23
\ _;.~
~.
24
"Tell_ us what happened in Nover.~ber."

HR. RICl:mAN:
I do not real_ly }:no'" bO'~--.' e_lse to do
25
OALC GCNOf!ON

Lord of War Part2

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Lord of War Part2

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F0.340 (Rev.

Field File No.

00 and File No.

Receipt Given 0 Yes

FO,S40 (Rev. 4-2SS)

Field File No.

Serial # of Originating Document \ - - - - - - -

00 and File No. -__,...---:,;..:' - - - - - - - - Date Received

(N~im~~pf 'SpeCial' Agent)

.~' N(l Receipt Given 0 Yes )0 No

FD-340 (Rev. 8-7-97)

/)?J'/ t{-t A- -lzfJSGf0

Universal Case File Number

Field Office Acquiring Evidence-------------~

From _ _ _ _ _ _ _ _ _~~~~~~---------(Name of Contributor)

(Name of Special Agent)

To Be Returned 0 Yes El-No

Reference:------=---,.__.,.._,,...,.,.--,--_,..,-.,....,.,...-------(Communication Enclosing Material)

liJ Orjgjoal notes re interview of

FD-340 (Rev. 8-7-97)

Universal Case File Number ...~.OJ.XJ;!:).1.1'--f..!l/r...::-:.c...l..z:.A-~-.....1~9t-t-9-l-2::..:5""1~~,.....

(Address of" Contributor)

(Nime of Special Agent)

Reference: ______-=~-~~~~~~~~--------(Communication Enclosing Material)

Description: ,.Original- notes re interview of

.j. . ''~~. 'y

FD-340 (Rev. 8-7-97)

Universal Case File Number

;}8 I f/- !-# -I 9 9/ .~s-.-1 A-]

Field Office Acquiring Evidence _ _ _ _ _ _ _ _ _ _ _ _---.:._

From __________~~~~~~-------------(Name of Contributor)

Reference: -----...,_-:-=---:-:--;-:----;:=--;--:-----..,-,--.,-.,..--------(Communication Enclosing Material)

Description: esr6riginal notes re interview of

J.__ _ _ ______JI ~4P='?

FD-340 (Rev. &-7-97)

Universal Case File Number d$1 M- hfr , I CJ 1 ?;;-~

To Be Returned 0 Yes ISLNo

FD-340 (Rev. 8-7-97)

Universal Case File Number ()!(;

If- L4 - /7 9 ;..s-s-_, fA-5?

Field Office Acquiring E v i d e n c e - - - - - - - - - - - - - - Serial # of Originating D o c u m e n t - - - - - - - - - - - - - Date Received

(City (\nd State)

KU 5~ 1~r0/Cu k~61/-IN 0(!_

FD-340 (Rev. 8-7-97)

Universal Case File NumberQ?8'/ f/

Field Office Acquiring E v i d e n c e - - - - - - - - - - - - - - Serial # of Originating D o c u m e n t - - - - - - - - - - - - - Date R e c e i v e d - - - - - - - - - - - - - - - - - - - - From---------.,.-;:-:---;-;::-:-:-:-=;-;--;----------(Name of Contributor)

To Be Returned 0 Yes J3"No

S~/11\J j EUI\ /7$ )l9N {)(!_

Reference: -------m===::-:-;==-::-;-;=::-:;;--------(Communication EnClosing Material)

Description: 0 Original notes re interview of

~..__ _ _ __..Jil:n rE]).; 9/J& hrr

FD-340 (Rev. 8-7-97)

Universal Case File Number

,;2?If/- L/1 - /7"9 7 sr - fkl I

Field Office Acquiring E v i d e n c e - - - - - - - - - - - - - Serial# of Originatinp Dpc~ment

pity an:? State)

(Communication Enclosing Material)

Original ndtes re interview of

FD-340 (Rev. 8-7-97)

Universal Case File Number

:Jg11/- Lll - /9 9 zs-s-/ (A I L

(Name of Special Agent)

Kus:-~1/YJ 1{2-t.e/f-s; /rrJ 0 ~

Reference: __________--~~~~~~-------------(Communication Enclosing Material)

From ___; _ _ _ _-::-:---;-::::--:-:;--~---------(Name of Contributor)