JO:ab 89-802c UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 89 -8 Q2-"-:Cr-":'KE~(c)-

18 U.S.C. S371

-----

UNITED STATES OF AMERICA, Plaintiff, vs. ROBERT GURIN, Defendant. INFORMATION

--------------------------_1
The United States Attorney Charges That:
1.

At all

times material

herein, AEA Aircraft

Recovery

(hereinafter "AEA") was engaged in the business of the recovery of seized aircraft. in
the Foreign

AEA is a "domestic concern" as tha.t term is used
Corrupt

Practices

Act

of

1977,

as

amended

(hereinafter "FCPAtI),
2. At all

15 U.S.C.

7Bdd-2(h)(1)(B). ROBERT GURIN,

times material herein defendant

(hereinafter "GURIN"), a United States citizen, was the sole owner
of AEA Aircraft Recovery

and engaged

in the business

of

the

recovery of seized aircraft.
concern
2(h)(1}A).
fI

Defendant GURIN was a "domestic
in the

as

that

term

is used

FCPA,

15 U.S .C. 78dd-

3.

At all times material herein Joaquin Pou, a Dominican

Republic citizen, was an agent of domestic concerns, to wit, AEA,
and

defendant GURIN.

4.

At all time material herein Alfredo G. Duran, a United

States citizen, was an agent of domestic concerns, to wit, AEA, and defendant--G{fRl}L~----------------~ _ ~
5.
At

all times material herein Jose Guasch, a Un!ted States of domestic concerns
I

citizen, was an agent defendant GURIN.
6.

to wit,

ABA

and

From on or about April
5,

12,

1989,

through on or about District of

November

1989,

in Dade

County

in the Southern

Florida, and elsewhere, the defendant,
ROBERT GORIN

willfully and knowingly

did combine,

conspire,

confederate

and

agree with other persons to commit an offense against the United States of America, to wit, to use the means and instrumentalities of interstate commerce in furtherance of an offer, payment, promise to pay and authorization of the payment of money and anything of value to officials of the Dominican Republic for the purpose of influencing the acts and decisions of said foreign officials in

their official capacities - - and inducing said officials to do or omit to do an act in violation of their lawful duty -- and for the purpose of indUCing such foreign officials to use their influence with the government thereof, of the Dominican Republic or any

lnstrwnentality

to affect

and influence

the acts and

decisions of that government, and to induce said foreign officials to use their influence with the government of the Dominican

Republic or any instrumentality thereof, to affect and influence the acts and decisions of that goverrunent
2
I

to assist AEA

and

defendant ROBERT GURIN in obtaining and retaining business for or
with, and directing

business to any person, to wit, the recovery

of aircraft-seTz9<f"by -ttre-gove-E'nment--O.L-the __ ~mtl!:i.~_~!l_Republic, in violation of Title 15, United States Code, Sections 78dd-2(a)(1) and (3). PURPOSE OF THE CONSPIRACY 7. It was a purpose and object of the conspiracy to offer,

pay, promise to pay and authorize the payment of money and anything of value, directly and indirectly, to officials of the government of the Dominican Republic in order to obtain the release of a Piper Navajo FAA registration number N6846L.

OVERT ACTS
In furtherance of this conspiracy and to effect the object thereof, the following overt acts, among others, were committed within the Southern District of Florida and elsewhere: 1. On or about May 30, 1989, defendant GURIN and another

person had a telephone conversation

and discussed the preparation

of fictitious paperwork in order to obtain the release of aircraft N6846L. 2. On or about June in Miami, 12, 1989, defendant and received GURIN met with $482.00 for his

another person

Florida

services in obtaining the release of aircraft from the Dominican Republic. 3. On or about June 27, 1989, documents relative to aircraft

N6846L were faxed from Miami, Florida to the Dominican Republic.

3

4.

On or about June 28, 1989, defendant GURIN, a Dominican

official and another person had a telephone conversation in which the Dominican off leT aT ConI:tnned--reee4:9t--O£__doCJJrn.~p._~~ __!=,elative to aircraft N6846L. 5. On or about July 6, 1989, defendant GURIN and another

person had a telephone conversation and discussed travelling to the Dominican Republic. 6. On or about July 17, 1989, defendant GURIN had a

telephone conversation with Pou and discussed meeting Pou in the Dominican Republic N6846L. 7. On or about July 19, 1989, defendant GURIN and another airlines from Miami, Florida to in order to obtain the release
of

aircraft

person travelled via commercial

Santo Domingo, Dominican Republic. 8. On or about July 20, 1989, defendant GURIN, another

person and Pou met in Santo Domingo, Dominican Republic. 9. On or about July 23, 1989, defendant GURIN and another and discussed the payment of

person had a telephone conversation
$5,000

to General Pou to distribute to Dominican officials. On or about July 25, 1989, Pou travelled from the

10.

Dominican Republic to Miami, Florida via commercial airline.
11. On

or about July 26,

1989, Pou defendant Club in Miami
$5,000

GURIN

and

another
Airport.

person met at

the Clipper
POll

International
in cash to pay

During the meeting,

received

officials to effect the release of aircraft N6846L.

4

12. On or about August 1, 1989, defendant GURIN and another person met with Alfredo G. Duran in Miami, Florida.
meeting, During the

Duran agreed---£ooe--Ehe----esc-raw--agent

-fQ£ __ t_l'!_~_

release of

additional monies to Pou in order to obtain the release of aircraft N6846L. 13. On or about September 12, 1989, Jose Guasch met with

defendant GURIN and another person in Miami, Florida and received $990 in cash to pay officials in the Dominican Republic. All in violation of Title IS, United States Code, Section 371.

dEXTER W. LEHTINEN UNITED STATES ATTORNEY

]2;;>~UQ

Jah~

Ql

5

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

--------------un

tte-d--5t-a-t-e-s--a.LA.IIJ_e_t:j..

ca

Plaintiff
vs. Robert Gurin

---

._--,------)
)

CASE NO:

89-802-Cr-KEHOE(S)
----- --~ ~----

)
)

ESTIMATED TRIAL TIME

--------------------------) OF CD1'IFICATE
I do hereby certify:

Defendant

)

)

TRIAL ATTORNEY

1. I have carefully oonaidered the allegations of the indictment, the number of defendant., the number of probable witneases and the legal complexities of the indictMent/information.
2. I am aware that the information INPPliecl on this statement will be relied upon by the Judge. of thi. Court in setting their calendars and scheduling criminal trials under the mandate of the ipeecSy Trial Act, Titl. 28, U.S.C., Section 3161

-try.

3. 4.

Thi. cause

will take

0

days for

the

parties

to

(Check the appropriate cat.gory)
X

I II III IV
V

o to 5 day. 6 to 10 daya 11 to 20 4aya

21 to 60 daya
61 daytI and over
in this Court? _

If

Hu ttd.. Y8aio Judg., N\IIber:

5.

cue beeR previously f1l.,

Cue

A copy of the cUapoa1t1ve order rauat be attached hereto.
Attornay for thi8 Di.-trict?

state. Attorney at tt. t1me Judge

6.

Wa. thi. matter pend1ng

Marc:u8

in the

wa.

Office

the

Un! ted

of the United

Statea

Ye.

BOND RECOMMENDATION "DEFeNDANT
ROBERT GURIN

_ Cash) (Marshal's

l-O,OOO P.S.B.
$ ----------------~
,

Custody)

(Surety, Recognizance, Corp. Surety, (Jail) (On Bond) (Warrant) (Summons)

UNITED Last Known Address:

STATES ATTORNEY

What Facility:
Agent:

Frank

Customs (FBI) (SECRET SERVICE) (DEA) (IRS) (CUSTOMS)
Rifenberg, U.S.

(OTHER)

BOND

RECOMME~DATION

DEfE~1JANT
(Surety, Recognizance, Corp. Surety, Cash) (Jail) (On Bond) (Warrant) (Summons) (Marshal's Custody)

ASSISTANT Last Known Address:

UNITED

~

STATES ATTORNEY

.

\"hat Agent:

Facility:
(FEn) (SECRE'l'

SERVICE)

(DEM

(IRS)

(CUSTOMS)

(OTHER)

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