ansbacher cayman report appendix volume 14

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    ISBN 0-7557-1355-9

    Govern ment of I reland 2002

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    Appendix XV (153) Mr Harold F Murray1. Evidence relied upon by the Inspectors in arriving at the conclusion relating to MrHarold F M urray.

    a) Transcript of evidence of Mr Harold T Murray dated 1 February 2001.b) Guinness and Mahon statement of 31 March 1980 re Guinness MahonGuernsey Limited.c) Internal Guinness and Mahon memo of 30 September 1987 reGMCT/College.d) Guinness and Mahon statement of 20 January 1986 re GM CT/College.e) Letter of 4 January 1994 - IIB to Kredietbank NV .f) Internal IIB memo re Murray Group Holdings credit application of 3

    February 1989.g) Internal Guinness and Mahon credit committee memo of 29 April 1977.h) Letter of 25 April 1989 - IIB to Murrays Europcar Limited.i) Letter of 23 July 1993 - Murrays Europcar to IIB.j) Letter of authority - M urrays Europcar to IIB in respect of accounts of thecompany up to 31 December 1992.

    2. Correspondence received from or on behalf of Mr Harold F Murray.a) Letter of 3 December 2001 - O'Do nnell Sw eeney Solicitors to Inspectors.

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    Appendix XV (153) (1) (a)

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    PRIVATE EXAMINATION OF MR. HAROLD T. MURRAY

    UNDER OATH

    ON THURSDAY, 1ST FEBRUARY 2001

    I hereby certify thefollowing to be a true andaccurate transcript of myshorthand notes in theabove named interview.

    Stenographer

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    PRESENT

    The Inspectors:

    Solicitor to the Inspectors

    Interviewee:

    Represented by:

    HIS HONOUR JUDGE 0'LEARYMS. MACKEY BL

    MS. M. CUMMINS

    MR. HAROLD T. MURRAY

    MR. NORMAN FITZGERALD0'DONNELL SWEENEYSOLICITORS

    15 - 16 FITZWILLIAM PLACEDUBLIN 2

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    WITNESS

    I N D E X

    EXAMINATION

    MR. H. MURRAY JUDGE O'LEARY

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    1 THE EXAMINATION COMMENCED, AS FOLLOWS, ON TUESDAY,2 23RD JANUARY 2 001:34 JUDGE 0'LEARY: Mr. Murray, as you are5 aware, we are appointed to6 investigate the affairs of a limited liability7 company. We are not appointed to investigate your8 affairs. We are appointed to investigate the9 affairs of a limited liability company.

    1011 Unfortunately, there are many people whose paths may12 have crossed the limited liability company we are13 investigating and we have to ask them a certain14 number of questions relating to their knowledge of15 or business with the company.1617 Now, it is a reasonably informal procedure except in18 one regard and that is the evidence is taken on19 oath. So I would ask the solicit or to the inquiry,

    20 Ms. Cummins, to administer the oath.2122 MR. HAROLD MURRAY, HAVING BEEN SWORN, WAS EXAMINED2 3 AS FOLLOWS:2425 1 Q. JUDGE 0'LEARY: First of all could26 I introduce both of us.27 This is Miss Noreen Mackey. She is one of the28 inspectors and my name is Sean O'Leary, I am a Judge29 of the Circuit Court and I am another one of the

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    1 inspectors. There are four inspectors but for2 simplicity sake, and to avoid the appearance of a3 large number of people, we have, with regard to most4 of the individuals, allocated one or possibly two5 inspectors to deal, if you like, with any matters6 arising in that case.78 So Miss Mackey and I will deal with anything which9 arises in your case which may be nothing at all but

    10 anything that arises we will deal with it. Do you11 understand?12 A. Yes.13 2 Q. Could I first of all say thank you very much for14 coming this morning and you are welcome.1516 The position is we are investigating a company which17 apparently, that is all I can say at the moment,18 operated in Ireland even though, if you like, based19 in the Cayman Islands, operated in Ireland and

    20 provided a banking facility to certain individuals21 within Ireland and it is our job to enquire into22 these activities, did they take place, and23 ultimately to report to the High Court.2425 If you like, we are creatures of the High Court. We26 have if you like, no statutory basis other than27 appointment by the High Court under the appropriate28 legislation. It is not because I am a Circuit Court29 Judge or Miss Mackey is a Barrister, that does not

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    1 give us any rights. It is because we are appointed2 by the High Court so, if you like, it is the High3A

    Court that is doing the inquiry.

    5 First of all, we know quite a bit about your company6 and there is no point in me going through it in too7 much detail with you, but I think the Murray Group8 of Companies was established, I think, by your9 father; is that correct?

    10 A. Yes it was built up by my father.11 3 Q. Is your father dead, is he?12 A. My father and mother died in 1994, December 1995 my13 father.14 4 Q. He was a good age when he died, was he, Mr. Murray?15 A. He was 82.16 5 Q. And he established what was originally a car hire17 company; is that right?18 A. No, he started off in the funeral business.19 6 Q. Did he, in fact, yes?

    20 A. And he moved from the funeral business and I suppose21 in the 40's into renting a small number of cars and22 gradually the car rental business became, more or23 less, the main business and then we moved into the24 car sales business. He bought a garage in25 Serpentine Avenue which was owned by a friend of his26 who got into health difficulties and he bought the27 garage off him to help his family out.28 7 Q. So he followed the pattern of a fairly successful29 entrepreneur during the course of his life?

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    1 A. He was, yes.2 8 Q. How many children did he have, do you mind me3 asking?4 A. He had nine children, one died at birth and the5 other, my brother, died I think about 7 years ago,6 my younger brother, Paul.7 9 Q. But, if you like, there were?8 A. Five girls and three boys.9 10 Q. I think in common with a lot of people in the

    10 1970's, and I want to emphasise we are not11 investigating this, but in common with a lot of12 people in the 1970's, your father took certain steps13 in the early 1970's with the coming of capital taxes14 and that sort of thing, he made certain arrangements15 with regard to the establishment of a Trust and all16 that sort of thing?17 A. Well, are you referring to anything in particular18 now?19 11 Q. Well, did he establish a Trust?

    20 A. What happened was we sold some properties,21 I understand, and he established a Trust at that22 time.23 12 Q. So that was not unusual at the time?24 A. No.25 13 Q. Do you know what the name of that Trust was or is?26 A. The Trust was the Woodward Trust, as far as I27 understand it, and that was on the sale of28 properties in '73.29 14 Q. We are not investigating that. That is not a matter

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    1 really of any consequence. We are accepting that as2 fact. Do you understand?3 A. Yes .4 15 Q. So you need not worry, so far as we are concerned,5 about that at all. So he established a Trust, he6 got his money, whatever way he got the money, it7 makes no difference to us, and he established a8 trust called the Woodward Trust; is that right?9 A. That's correct.

    10 16 Q. And that was established where, do you know?11 A. In Jersey. I think at that time there was some12 worry, I believe, of devaluation of the Irish Pound13 I think.14 17 Q. He deemed it prudent to do it anyway?15 A. Yes .16 18 Q. That was fair enough. So he established the trust17 and we have in fact the documentation and I do not181 Q

    intend to go through that documentation with you.-L J

    20 I think that trusts, they operate through companies.21 Do you know the name of the company that this Trust22 operated through?23 A. I am not sure I understand what you mean by that.24 19 Q. When a Trust is established, you see, the Trust is25 established and it has to operate. In other words,26 it has to function and one of the ways it functions27 is that there is a company attached or owned by the28 Trust. Were you familiar with the name of the29 company which was attached to the Woodward Trust?

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    1 A. No I don't think I know that. As I understand from2 that particular point about that, we transferred3 those funds from the sale to Jersey and they set up4 the Woodward Trust there?5 20 Q. Yes .6 A. And that was my father's kind of whatever.7 21 Q. I understand that?8 A. He dealt with that entirely. It was not part of our9 company, if you understand what I am saying.

    10 22 Q. It was not part of the company?11 A. It was not part of the company and it was set up12 off-shore.13 23 Q. But, of course, the funds had originally come from14 the company; isn't that right?15 A. They did, yes.16 24 Q. So, to that extent, it had a connection with the17 company?18 A. It did. I understand the way it was set up that it19 did originally have, yes but the funds weren't

    20 needed as I understood.21 25 Q. Does the name Sumac Limited mean anything to you,22 Sumac Limited?23 A. Sumac, no I heard it, I heard it somewhere but it24 does not mean anything to me.25 26 Q. You did not know about it, did you?26 A. No, I should really point out that I was working at27 the time in Esmonde Motors where I had moved from28 Murrays at that time and I wasn't really, I didn't29 even know the Trust was set up until recent times

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    1 when this has all come to light. I am talking about2 at that time now.3 27 Q. Yes I understand that but you knew about the company4 Sumac many years later, didn't you, you did business5 with it?6 A. I heard about that later, yes, but I am not sure7 what the actual involvement of that was.8 28 Q. What did you understand it to be? Don't mind what9 I understood it to be. You tell me what you thought

    10 it was?11 A. I don't know how I was involved. I know that we set12 up the Woodward Trust and, as far as I was13 concerned, the actual money that my father put out14 into Jersey was used sometimes for the guarantee of15 loans. I do not really know.16 29 Q. We will come to that later.?17 A. When it comes to Sumac, I don't really know the18 connection.19 30 Q. You do not know anything about Sumac?

    20 A. I don't know the connection and I don't understand21 the connection.22 31 Q. I see. Now, when did you say you acquired a23 position of significance within the Murray24 organisation?25 A. Well a position of significance, I was asked to move26 to Esmonde Motors in 1968 and I was there for many27 years. That was a company that was involved with28 selling and buying and also selling new cars that2 9 was cars for our hire drive company and I got in

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    1 involved in that part of the business for many years2 and we sold the property there in Serpentine Avenue3 to the bank, that was the early 70's and it must4 have been five years later we moved eventually. We5 moved to a small garage next. We rented one which6 was Kinsellas on the Blackrock Road which was too78

    small for what we required and we eventually boughtthe OK Garage in Stillorgan and I have been there

    9 for -- in fact, my head office is still there but10 I became involved in the car rental business more11 and more through buying the cars for that car rental12 company, and I got more involved.1314 We had a lot of people working for us. We were kind15 of with the car rental company for many years, 4016 years wouldn't be unusual but I got involved as a17 main Board Director I think it was 1978.18 32 Q. I see. When did you become Managing Director?19 A. Managing Director I think was around 91.

    20 33 Q. Yes and before that who was the Managing Director?21 A. Before that, Ray Carroll was the Managing Director22 before that.23 34 Q. At the time that you became Managing Director, let24 us take that picture in the early 1990's, just at25 that time, who were the owners of the Murray Group?26 A. The owners of the Murray Group, the shareholding27 was, my father, of course, was the main shareholder.28 35 Q. Yes .29 A. And the other Directors are...(INTERJECTION).

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    1 36 Q. We will put it like this: How much did you own?2 Forget the others for the moment. What percentage3 did you own?4 A. Nine per cent.5 37 Q. You owned nine per cent?6 A. Yes .7 38 Q. And when did that change?8 A. The nine per cent changed on my father's death.9 39 Q. Which was in 19?

    10 A. 94, 95 I should say.11 40 Q. And after that? What percentage did you own after12 that?13 A. What happened was after that, my brother, Paul, had14 died and the way the actual, my father's wishes were15 that the girls were to get 40 per cent of the16 company and the boys would get 60 per cent of the17 company but that was not established. I was trying18 to get him to actually lock-in on that at a much19 earlier date because I was building up the company

    20 and the cake was getting bigger and I was trying to21 get him to fix the amounts and so on but eventually22 that was done, and when my brother, Paul, died, the23 girls were dealt with with preference shares and he24 left his house and contents to the girls.2526 My father gave me 60 per cent of the company and27 that was including the nine, now, and my other28 brother, Noel, forty per cent.29 41 Q. So that was the way it divided?

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    1 A. That was the way it divided and then after his2 death, the girls disputed the Will and my father had3 held ten per cent for my mother and ten per cent4 for himself. Don't ask me why he held on to it and5 when he died, of course, that was in the estate and6 there was a dispute over that and the girls were,78

    two of the girls, the other girls were advised,three other girls to get involved because it was in

    9 their interest. One decided not to and it10 eventually ended up that the four girls got five per11 cent each. Since then, we have bought out the five12 per cent of each of the girls.13 42 Q. So the position nowadays is that you own sixty per14 cent, is it, approximately?15 A. As I speak, we are just about to sign a deal where I16 am buying out by brother, Noel, so there is nobody17 left other than myself then.18 43 Q. I see. Did Mr. Carroll own a percentage of the19 company at any stage?

    20 A. Ray Carroll?21 44 Q. Yes?22 A. Yes he had five per cent. As I understand, my23 father passed over at some stage the five per cent24 to him because he was with the company for a long25 time.26 45 Q. Are you sure it was not nine per cent because I have27 some documents which would seem to suggest it is28 nine per cent. I could be wrong now?29 A. I am sorry...(INTERJECTION).

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    1 46 Q. Would you check that for me?2 A. I could check that out.3 47 Q. That would be very helpful?4 A. I know that my Uncle Anthony, who was involved in5 the funeral business at the time, was given a6 percentage and Ray Carroll was given a percentage at7 some time.8 48 Q. Mr. Carroll's involvement, the dates of it where he9 owned X per cent and X per cent?

    10 A. Yes .11 49 Q. If that was laid out to us, it would be of12 considerable assistance if you would do that?13 A. Yes okay.14 50 Q. I know these things can become very complicated down15 through the years and you don't necessarily carry16 them around in your head, but if we were making a17 report, we may not mention it in the report at all18 but if we do have to mention it, we would prefer to19 be accurate, as you will appreciate. We don't want

    20 to say Mr. Carroll had five per cent when he had21 nine and we certainly don't want to say he had nine22 per cent if he had five. Do you understand what I23 mean?24 A. Yes .25 51 Q. Was Mr. Carroll a family member?26 A. No he wasn't a member of the family, no.27 52 Q. He was a trusted employee?28 A. He was an accountant.29 53 Q. He did move into more general management at one

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    1 stage as well, did he?2 A. He was Managing Director.3 54 Q. And when would he have ceased to be that then, Mr.4 Murray?5 A. He retired, I think, in 1991.6 55 Q. In the normal course of events?7 A. Yes .8 56 Q. And your arrival on the scene as Managing Director9 was, if you like, following on from that retirement?

    10 A. That's correct, yes.11 57 Q. I am only just trying to get the picture. The12 company which we are investigating is, as you know,13 it is a company which was a subsidiary of Guinness &14 Mahon here in Ireland and which ultimately had a15 number of different names but if we call it16 Ansbacher for the moment but it did not always have17 that name. You will have seen the other names that18 it had?19 A. Yes .

    20 58 Q. And you are probably saying to yourself, "What is my21 connection with that company?" and I will go through22 that with you. But before we go through that, and23 that is where we are heading, if you like, I am not24 taking you by surprise, I would like to just canvass25 your company's involvement with Guinness & Mahon.26 How long was your company doing business with27 Guinness & Mahon?28 A. I don't really know but I do know that we did29 business with them for a certain number of years but

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    1 I wasn't really involved in the financial2 arrangements or loans.34 I was involved more in the operational side of it,5 totally in fact, but I do know that we dealt with6 Guinness & Mahon and obviously I knew that because7 they used to have an annual golf outing in the8 Castle, I used to play in it and I knew they were9 involved in it.

    10 59 Q. Did you negotiate anything with them?11 A. I never negotiated.12 60 Q. Never negotiated?13 A. No I was never involved in any of it.14 61 Q. Did you know any of the people involved in Guinness15 & Mahon?16 A. Yes I knew Maurice O'Kelly.17 62 Q. Did you know Mr. Traynor?18 A. No.19 63 Q. Or Mr. Collery?

    20 A. No.21 64 Q. You did not know them?22 A. No.23 65 Q. I see. Now, from about 1989 onwards, that banking,24 right?25 A. Yes.26 66 Q. About 1989 onwards, that arm of the banking seems to27 have been changed to IIB; is that correct?28 A. Irish Intercontinental Bank?29 67 Q. Yes?

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    1 A. Yes, that's right because I remember meeting them2 and seeing them in Merrion Square.3 68 Q. I take it that from 1991 onwards, you would have4 dealt with IIB directly or indirectly?5 A. I did not deal with them directly, no.6 69 Q. But would you have been aware of the money you were7 borrowing from them?8 A. No the borrowings changed, you see. The money we9 borrowed for cars, during the early 1980's, we took

    10 over a Ford dealership in 1980 and the new car11 market at that stage was about 106,000 registrations12 per annum and in 1981/82, the market collapsed so it13 was not necessary to have collateral for borrowing14 for cars because cars were not acceptable to banks15 as an asset because the banks felt they could not16 repossess them clearly enough, and as we moved into17 the 1990's, the economic situation changed and we18 were borrowing money through Ford, Ford Motor Credit19 Bank, in which we could reverse the situation and we

    20 could borrow money versus cars, if you like, so we21 weren't really involved in that.2223 I have to say I would not be aware of what financial24 arrangements were made with IIB.25 70 Q. But after 1991 you would, surely? You were the26 Managing Director after 1991?27 A. I was, yes but we had a new accountant who dealt28 with loans.2 9 71 Q. And what was his name?

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    1 A. His name was Dan Kenny.2 72 Q. And is he still with you?3 A. He is, yes. He is our accountant and our financial4 guru or whatever. I think he joined the company5 around that time.67 Sorry, I think I am wrong in that. I do not think8 he joined the company in 1991, I think he joined the9 company around 1995. Ray Carroll would have been

    10 still involved with the company even though he moved11 from MD, he moved to advisor, company consultant.12 73 Q. What I am going to show now, Mr. Murray is this. I13 am going to show you a Guinness & Mahon statement,14 page 206 Exhibit I.1516 Now, I am going to show it to you because of certain17 information which is contained in it. Even though,18 if you like, it does not show any connection with19 the company which we are investigating but I will

    20 explain that to you later?21 A. (Handed) Okay.22 74 Q. It is helpful for me in understanding the full23 picture?24 A. This is a Guinness & Mahon Sterling Account. This25 is 1980?26 75 Q. 1980, all right?27 A. Yes.28 76 Q. Now, you will see that it is an account which29 Guinness & Mahon in Dublin had for Guinness Mahon

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    1 (Guernsey) and it was for a particular customer?2 A. Sorry?3 77 Q. It was for a particular customer, if you like. The4 customer was not Guinness Mahon (Jersey). I think5 the customer was the Murray Group in one guise or6 other?7 A. Yes .8 78 Q. There is nothing wrong with that, I am not making9 any suggestion there is. But you will see a number

    10 of things arise with regard to that. You will see11 in March 1980 to "H.T. Murray College Trustees12 Jessica Trust, 91,100."1314 Now, can I take it that the "H.T.15 Murray"...(INTERJECTION)?16 A. Sorry, "Transfer into H.F. Murray".17 79 Q. "H.F. Murray" is first, yes?18 A. "28th March 1980 transfer to H.T. Murray College19 Trustees".

    20 80 Q. Who is H.F. Murray?21 A. That is my father.22 81 Q. All right. Do you know anything about that?23 A. No.24 82 Q. Do you know anything about Jessica Trust?25 A. No.26 83 Q. Did you ever hear of Jessica Trust?27 A. Never heard of it.28 84 Q. Look at the next entry?29 A. "A.P. Murray"?

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    1 85 Q. "H.T. Murray"?2 A. "A.P.", that is Ann Patricia, that was my mum.3 8 6 Q. MS. MACKEY: "H.T. is the next one?4 87 Q. JUDGE 0'LEARY: "Transfer to H.T. Murray"?5 A. Sorry, I thought you said that?6 88 Q. No I didn't, I said "H.F. Murray"?7 A. "H.F. Murray", that is my father.8 89 Q. The next is "Transfer to H.T. Murray"?9 A. Yes, 81,990.

    10 90 Q. Yes?11 A. Yes.12 91 Q. And something to do with a Delisle Trust?13 A. Delisle Trust.14 92 Q. Yes. Is that you?15 A. Never heard of it.16 93 Q. Is that you?17 A. I have no knowledge of that at all.18 94 Q. Is that you?19 A. H.T. Murray is me, yes.

    20 95 Q. Did you get 81,990 directly or indirectly in 1980?21 A. I would say I could have but I don't recall. I know22 that year I bought a house. I sold my house in23 1979/80, the very end of 1979 in Kill Lane, which is24 where I lived, for 100,000 and I bought another25 house in Carrickmines for 164,000 and I borrowed26 100,000 from the bank.27 96 Q. Which bank?28 A. I don't know why or I will have to check what that29 was because any money that I got...(INTERJECTION).

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    1 97 Q. I know you strike me, Mr. Murray, with respect, as2 a very modest man. You are not a flashy life-style3 man or anything like that?4 A. Some people may have a different opinion you know.5 98 Q. But if you got in 1980 81,000, almost 82,000, you6 would not forget it. That is the point I am making78 A.

    to you?That is not necessarily so because when I -- the way

    9 I ever got money was from the company. It might10 have been a loan from the company or a bonus or11 something at the end of the year.12 99 Q. I understand that of course.13 A. And even when I got married, I mean my father gave14 me in 1963, 6,000 and he never handed it to me15 himself. I got it from the accountant in the16 company. We did not have that kind of relationship.17 So the money that would be there, obviously it went18 through the books of some kind or was transferred19 into...(INTERJECTION).

    20 100 Q. I might help your memory because I will now go on21 the next one?22 A. Yes .23 101 Q. The next one is "A.P. Murray"; is it?24 A. Yes .25 102 Q. Who is "A.P. Murray"?26 A. My mum, Ann Patricia, yes.27 103 Q. And "Bianca Trust", do you see that, "for Trustees28 as Trustees for the Bianca Trust"?29 A. "Bianca Trust", yes.

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    1 104 Q. Do you know anything about that?2 A. No I never heard of that.3 105 Q. And do you see the next one now, "Pay to Ray4 Carroll"?5 A. Yes.6 106 Q. Ray Carroll, we know, was an important person within7 your organisation at that time and he got 50,000?8 A. Yes.9 107 Q. Would that not in its entirety seem to suggest that

    10 some kind of a divi up at that time: Your father11 got so much, you got so much, your mother got so12 much and Mr. Carroll got so much?13 A. Yes. When you say "a divi up".14 108 Q. Where did the money come from is what I am asking15 you?16 A. Guinness & Mahon (Jersey).17 109 Q. I know that is where it came from, but I am talking18 about did it come from the Woodward Trust?19 A. I do not know.

    20 110 Q. I will tell you why that becomes very relevant when21 I show you the next two or three documents. I need22 to know where that money came from. I really don't23 care why you got it. I don't care whether tax was24 paid on it or not, it is nothing to do with me, but25 I am interested in where it came from because that26 is necessary for the investigation of the company in27 circumstances which I will explain to you later. So28 I need to know where that money came from and could29 you enquire about that?

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    1 A. Okay. Can I take a copy of that?2 111 Q. Absolutely we will give you a copy of that.3 A. Okay.4 112 Q. We will get another copy for you?5 A. Thank you.6 113 Q. I want to make it clear that right up to this point,78

    there is no connection with what I would call theCayman Islands, Ansbacher (Cayman Islands) even

    9 though the money in question ultimately, I think, I10 would be able to show to your satisfaction in the11 Woodward Trust ended up in the Cayman Islands?12 A. About 2 years ago when the Ansbacher thing came into13 the papers, 2 years ago when that was announced, I14 have to say, I can quite honestly say that that was15 a bombshell and my father's name was printed in the16 paper with that because I had never heard of17 Ansbacher before and neither had he or anybody else.18 114 Q. I think Miss Mackey will confirm that quite a number19 of people who have been genuinely trying to help us

    20 find themselves in the same position. That is fair21 enough. But the reality is that what happened was22 that the person in question, it may be your father,23 I am not saying it was your father, but whoever was24 involved in the setting up of the Trust?25 A. Yes .26 115 Q. If you like, entrusted certain individuals with27 regard to their money and there was nothing28 improper, there wasn't money being taken or anything29 like that, but that person was given wide authority

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    1 to move the money around and ultimately it ended up2 in the Cayman Islands?3 A. Okay.4 116 Q. That is the problem and that is why a lot of people5 are coming into us, do you understand?6 A. Yes .78

    117 Q. Not because they know it themselves but because thefact of life is that Guinness & Mahon, through Mr.

    9 Traynor or otherwise, ended up in a situation where10 the money ended up in the Cayman Islands and it11 ended up in the company we are investigating,12 unfortunately for you. Do you understand the point13 I am making?14 A. Yes .15 118 Q. What I would like to show you then about that is I16 would like to show you number 282. Exhibit 2.17 A. (Handed).18 119 Q. Again we will give you a copy of this if you want it19 in due course. There is no problem or difficulty

    20 with that?21 A. The College Trust.22 120 Q. Does the name College Trustees mean anything to you?23 A. I have to say I heard of College Trustees all right.24 121 Q. I think what College Trustees did is, I think they25 managed the money out in the Channel Islands?26 A. Yes .27 122 Q. Would you think that is a fair summary of the28 position?29 A. Yes .

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    1 123 Q. They were the managers, if you like?2 A. Yes .3 124 Q. But what happened, right, is that College Trustees4 in managing the money had wide powers, College5 Trustees now was a creature of Guinness & Mahon as6 well, they had wide powers where to put the money.78

    Sometimes they put it one place and sometimes theyput it another. But if you look at 282, Exhibit 2,

    9 you will see, do you see "GMCT", do you see that up10 on top?11 A. "GMCT" Guinness Mahon.12 125 Q. Cayman Trust. That is one of the names of the13 company we are investigating. Ansbacher came in14 afterwards, but that is one of its names.1516 This is a Guinness & Mahon document and I am sure17 Guinness & Mahon will confirm it to you if you wish18 but College Trustees opened an account in Guinness19 Mahon (Cayman Trust) and in September 1987 Sumac, do

    20 you see Sumac there, S-U-M-A-C, Exhibit 2?21 A. Yes .22 126 Q. Sumac had Deutsch Marks at that time?23 A. Deutsch Marks, yes.24 127 Q. Did you know that at the time?25 A. No.26 128 Q. It is a fact. You can take it that it is a fact27 that it was there. Do you understand?28 A. Yes .29 129 Q. So that is the first thing. The second thing I want

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    1 to show you is one of a number of sheets of paper2 which I have which even make the thing more clear,3 number 283, Exhibit 3.4 A. (Handed).5 130 Q. Do you see it is a Guinness & Mahon statement like6 the first statement I showed you, Exhibit I?7 A. Yes .8 131 Q. Except this time the money has gone through Cayman9 because the customer of Guinness & Mahon in Dublin

    10 is Guinness Mahon Cayman Trust/College. You can11 take that means College Trustees Re Sumac?12 A. Yes .13 132 Q. And that means in 198 6, Sumac, which was the company14 which was the operating company of Woodward Trust,15 had 1.421 million Sterling. I think there was a16 Sterling account in the Cayman Islands.17 133 Q. MS MACKEY: Deutsch Marks?18 A. Deutsch Marks, is it?19 134 Q. JUDGE 0'LEARY: I do not see where that is

    20 written actually.21 MS. MACKEY: It is written on the top.22 JUDGE 0'LEARY: It is indeed, Deutsch23 Marks. Do you see that?24 A. Yes .25 135 Q. Now, did you know anything about that?26 A. No.27 136 Q. And where did you think the money was, because28 I know the money came back in 1994 and we will go29 into all that later, but where did you think it was?

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    1 A. As far as I knew, Jersey was the only word that we2 used, the money was in Jersey.3 137 Q. It was being controlled in Jersey. Do you4 understand?5 A. Whether it was or not, as far as I knew, the money6 was Jersey money or whatever.7 138 Q. I understand. So you see there where there was this8 money and it is clearly money that Sumac had an9 interest in. Forget who owed Sumac that. It is not

    10 terribly important just for the moment.1112 You can take it, Mr. Murray, that I have many other13 similar examples but they all come down to precisely14 the same?15 A. Yes.16 139 Q. So I think unless you can come up with an17 alternative explanation for it, I think you can take18 it that you are going to have to come to terms with19 the fact that the money was in the company we are

    20 investigating. Do you understand?21 A. Well, I 22 140 Q. There is nothing wrong with that, I can say to you,23 but the reality is one of the jobs the High Court24 has asked us to do is to find out who the customers25 of the company were. Now, we certainly will have to26 report, unless we get another explanation, that27 Sumac was one of the customers of Ansbacher. Do you28 understand?29 A. Yes.

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    1 141 Q. Now, what I am saying to you is, if you have any2 other information which would contradicts that, by3 all means tell us. Do you understand?4 A. I wouldn't have any information.5 142 Q. I am just going to leave it like that for the moment6 on that part of it?7 A. Yes.8 143 Q. Now, one of the things which we are going to have to9 do then is we are going to have to find out who

    10 Sumac were, all right?11 A. Yes.12 144 Q. We know that Sumac were a company which was the13 operating arm of the Woodward Trust. We have to14 find out then who the Woodward Trust was and prior15 to the money coming back in 1994, and I will deal16 with that separately later, prior to that now, if I17 was to ask you in 1991 who owned the money which you18 thought was in Jersey, what would you have said?19 A. My father. My father dealt with it whenever he had

    20 to, I suppose.21 145 Q. So you would have thought your father could have22 done what he wanted with it?23 A. Yes, absolutely. It was not something that was24 discussed ever because I can say if he brought money25 back or gave it to anyone, I was not privy to that2 6 knowledge.27 146 Q. As far as you were concerned, he was the man who had28 control of that money?29 A. Yes.

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    1 147 Q. And when did he die?2 A. January 1995.3 148 Q. Between 1991 when you took over as Managing4 Director, and I know it is a gradual thing, I know5 you don't just go in one morning and say "I am the6 Managing Director", that's not the way it is done.78

    I have been around business long enough to know theway that family business is operated, it is a

    9 gradual transfer?10 A. Yes .11 149 Q. So you would have naturally thought that your father12 had the power and control over that but at some13 stage that changed?14 A. Yes. No, it did not change until I think he decided15 to bring it back when the Amnesty was announced and16 that was, as I understood, what had changed.17 150 Q. But when the Amnesty was announced, percentage18 meaning nothing at the moment now?19 A. Yes .

    20 151 Q. We will go into those later, but you got a big21 percentage of it?22 A. Yes .23 152 Q. So at some stage it did change. At some stage24 somebody said, "Well if it was your father's money25 and it became your money, you got a very substantial26 gift from your father"?27 A. Well, when he set up the Trust, whatever way he set28 up that Trust, I don't know.29 153 Q. You can take it that there is nothing in the Trust

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    1 that would have said you would get forty per cent of2 the money or fifty per cent of the money?3 A. I have no idea whether there was or not. Whether he4 set this Trust up and he decided...(INTERJECTION).5 154 Q. Do you have the Trust document?6 A. No.7 155 Q. Have you ever seen the Trust document?8 A. No.9 156 Q. You can take it from me I have seen the Trust

    10 document.1112 Miss Cummins indicates to me that in fact as part of13 your affidavit to the authorised officer who was an14 official investigating the company, you exhibited15 the Trust document as part of your affidavit.16 I know you might have forgotten it, I am not making17 a big issue of it, but you can take it that in the18 Trust document which you have had access to, you19 were not named as a fifty per cent beneficiary. Do

    20 you understand?21 A. Okay.22 157 Q. It is all the children and variable. You know the23 usual kind of nonsense that people go into in these24 documents, you understand that?25 A. Yes .26 158 Q. But somebody decided that this very deserving young27 man at the time, Mr. H.T. Murray, was not entitled28 to the same as all the rest of his siblings but he29 was entitled to forty or fifty per cent. All I am

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    1 asking you to find out is when that decision was2 made?3 A. How can I answer that?4 159 Q. I don't know because I don't know what went on.5 When the money came for the Amnesty, your father was6 an elderly man at this stage?7 A. He was still involved in business in so far as he8 was in every day, I should say, but when that9 decision was made, I don't know.

    10 160 Q. Would you show Mr. Murray a letter dated 4th January11 1994 from Irish Intercontinental Bank to Kredietbank12 in London, Exhibit 4?13 MS MACKEY: Page 193.14 A. (Handed).15 161 Q. JUDGE 0'LEARY: You can see down there it16 talks about your account17 in general and the second last paragraph:18 "On receipt of the above funds, theamounts will be transferred into four19 individual deposit accounts with IIB inthe following proportions: Harold T.20 Murray, 50%; Noel G. Murray" -- (who isyour brother) -- "31%; Harold F.21 Murray" -- (who, I think, was yoursurviving father at that stage)?22 A. Yes .23 162 Q. "And Ray Carroll 9%"?24 A. Yes .25 163 Q. Did that reflect at that time your interest in the26 company approximately or how was that percentage27 arrived at?28 A. I don't know.29 164 Q. I see?

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    1 A. Unless it was in proportion to the way the2 shareholdings were held but the shareholdings3 changed. I never saw that before.4 165 Q. I am not saying you saw it but you know you got5 fifty per cent of the money?6 A. I did not know what percentage of the money.7 166 Q. I see. Did you know that you got more than Noel?8 A. I expected I would get more than Noel.9 167 Q. Because you owned more of the company?

    10 A. Yes, well I was not sure what way he would have11 broken it up.12 168 Q. Does that not lead to the inference that the money13 was really the company's because it was being14 divided in accordance with your interest in the15 company?16 A. Yes, I suppose, but my interest in the company, my17 mother was there with a ten per cent shareholding of18 the company and she is not featured there at all. I19 don't understand those percentages.

    20 169 Q. MS MACKEY: Did your mother not die in21 1994 you told us, I think?22 A. My mother died at the end of 1994. This is 93, is23 it not?24 170 Q. JUDGE O'LEARY: Yes, this is 4th January25 1994. But am I not right26 in saying that, for instance, your sisters aren't27 mentioned at all in that?28 A. No they had been dealt with at that stage.29 171 Q. Yes but they had been dealt with in so far as their

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    1 ownership of the company was concerned?2 A. Yes.3 172 Q. But they had not been dealt with unless some money4 which was out in Jersey or Cayman or whatever it5 was, unless that was owned by the company as well.6 Can you see the problem?7 A. I have to say that my father really dealt with this8 account most of the time.9 173 Q. And he decided?

    10 A. But my sisters now, this was before my father died.11 My mother died at the end of 94 and my father died12 in 95.13 174 Q. But, you see, your sisters are not mentioned in that14 at all?15 A. No because they were not part of the company then.16 175 Q. It was reflecting your interest in the company17 approximately without being precise for the moment?18 A. It was but I was not aware of that.19 176 Q. I understand that. Could I ask you this: Did you

    20 declare, I am not really interested in your tax21 affairs, it is nothing to do with me. I am only22 interested in it in so far as it might give the23 information with regard to the ownership of money,24 that is the only thing that we are interested in. I25 don't care whether you have over paid your tax or26 under paid your tax, it is nothing to do with me?27 A. Yes.28 177 Q. But I am interested about the fact that you did29 actually avail of the Amnesty?

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    1 A. Our company?2 184 Q. Yes?3 A. Yes .4 185 Q. It had been doing that with Guinness & Mahon?5 A. Well I was not aware that Guinness & Mahon were6 involved, although I am sure that they were, but I78

    was aware of Irish Intercontinental Bank because, asI said, the motor industry at that time in the mid

    9 80's was difficult.10 186 Q. What I would like to show you is a memo which is11 dated and it is page 227 to 231, Exhibit 5.12 A. (Handed).13 187 Q. This is an IIB memo and this is a credit14 application. It is only typical of many such15 documents that we have. If you look at page 228,16 which is the second page of that, IIB make the17 following statement, "Proposed Security". Do you18 see that there down at the bottom of the page?19 A. "IIB facilities secured"?

    20 188 Q. No, the term "Proposed Securities". Have you page21 228?22 A. Yes .23 189 Q. Look at the bottom of that page, "Proposed24 Security"?25 A. Yes .26272829

    190 Q. "The term loan will be secured forprincipal only by a bank guaranteeaccepted by IIB. This will be providedon behalf of a Trust controlled by theshareholders of the company, who have adeposit of a similar amount."

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    12 Is that a fair reflection of what the position was3 at that time? That is what the Bank is saying and4 that is all it, is what the Bank says?5 A. That's correct. I mean, it was controlled by the6 shareholders of the company, the company being7 Murray's you are talking about.8 191 Q. Yes .9 A. That is what we used to guarantee the loans at that

    10 time for money we borrowed for.11 192 Q. The only other matter that I want to talk to you12 about before moving on probably less contentious13 matters is of all the discussions we have had so14 far, only one really has led to a disagreement and15 it is this, that we have information, and you have16 seen one document which is the bank statement,17 Exhibit I?18 A. Yes .19 193 Q. Which refers to other Trusts, being the Jessica, the

    20 Delisle Trust, the Bianca Trust and finally a Trust21 called Kodier, C-O-U-D-I-E-R,I do not know how you22 pronounce it, which I think was connected with Mr.23 Carroll. Do you know anything about those?24 A. No.25 194 Q. Nothing at all?26 A. No.27 195 Q. Absolutely nothing?28 A. Absolutely nothing.29 196 Q. And specifically about your own one and I am using

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    1 that in inverted commas now for the moment the2 Delisle, D-E-L-I-S-L-E?3 A. No, I know nothing about that.4 197 Q. Fair enough. I am going to give you an example of5 the Guinness & Mahon borrowings, do you understand?6 I know you do not know much about them but as, if78

    you like, the main man in the company it would beunfair if I did not give you the opportunity of

    9 commenting on it.1011 So I wonder if you would go to page 296 and would12 you bend down the top because it has nothing to do13 with this matter. We can give you a copy of this14 but I want to take the top off it because it is15 nothing to do with you, it is different. These are16 minutes of a credit minute in Guinness & Mahon and17 you can see that at that time "Murray's Europcar",18 Exhibit 6.19 A. (Handed).

    20 198 Q. Do you see that there?21 A. Yes .22 199 Q. They had these Credit Committee meetings and23 everybody was discussed at it and you were one of24 the people discussed at it under the heading of25 Murray's Europcar:2627

    "Murray's Europcar are borrowing170,000 for working capital, rate15%"?28 A. 1977 .29 200 Q. 1977. You see there the words "suitably secured",

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    1 do you see that?2 A. "Suitably secured", yes.3 201 Q. You can take it that we have evidence from Guinness4 & Mahon that that word was a code they used5 themselves which meant that they were backing6 deposits. Do you understand?7 A. Yes.8 202 Q. Where they wanted to avoid saying, "This person had9 backing deposits", they used "adequately secured" or

    10 "suitably secured" as a code word. So they are11 saying in 1977 this loan was backed by money and you12 have no reason to doubt that?13 A. No, any money that we would have borrowed, maybe not14 all of it, but we secured it against our -- my15 father actually guaranteed the loan through the16 money he had obviously in Jersey. That happened all17 the time right up to...(INTERJECTION).18 203 Q. Can you see the problem that arises? You can take19 it I have a dozen other examples, all right, which I

    20 won't put to you because they are all the same and21 you have been very fair with you us and we22 appreciate that.2324 Now, the problem, as far as we are concerned, with25 that is that nowhere in your accounts that we have26 seen is there any record that the loans you have27 taken out are secured by back-to-back deposits.28 Certainly there is no reference to that until well29 into the 90's. Do you understand and we would like

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    1 your comment on that?2 A. I am not an accountant but should there be?3 204 Q. Oh, yes, you can take it that there should?4 A. There are guarantees you have to put in.5 205 Q. You are supposed to give a full record, do you6 understand, so that everybody who looks at them78

    knows what the position is. Now, what I would likeyou to do is, if you would not mind, I would like

    9 you to consider that and you may wish to take legal10 advice on it. If you do by all means of course,11 there is no difficulty with regard to that, and I am12 not asking that you should answer the question now,13 if you like, but if there is anything you wish to14 say to me about it, feel perfectly free to write15 into me about it?16 A. Well, all I can say really is it would be reflected17 in our accounts that the money was transferred out18 when they did it in the 73 period, but as regards19 the loans --

    20 206 Q. If it was company money, it should be on the balance21 sheet. Can you see the problem?22 A. I can't say why they were not. I can't answer that23 question.24 207 Q. You see, Mr. Murray, when it was moved out, if it25 was genuinely moved out of the company, it was no26 longer company money?27 A. No longer company money, that is correct.28 208 Q. Now, if it came in, if you like, through a back door29 by you using back-to-back facilities, that should

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    1 have been made clear in the company records and one2 of the things that we are required to do is if3 during the course of investigation of the company,4 which is the banking company, we come across exact5 accounts of where the company, which is the banking6 company, gave information or other companies acted7 in a way which was potentially illegal, that we may8 have to report on it. Do you understand?9 A. Yes.

    10 209 Q. We will be writing to you formally about this but11 I think it is only fair that I should say to you it12 is a concern to us at the moment, not specifically13 only with regard to your company but that the whole14 question of the back-to-back facilities were hidden15 from view for over 20 years as far as anybody16 looking at your accounts is concerned, and of course17 we will, in due course, be asking you, have you any18 comment to make on that? So I am giving you fair19 warning in advance that you might go away and think

    20 about that and I am glad you have your solicitor21 here who can take a note of it and he can advise you22 accordingly and make any representations you want to23 us about it or make no representations. It is a24 matter entirely for yourself.2526 You see, I am going to give you as an example of27 that, it might be good if you took this away with28 you, a page 178 and this is only one example of a29 number, and this is in 1989 before you became

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    1 Managing Director but it is related to your company2 and I have to put it to somebody, Exhibit 7?3 A. (Handed).4 210 Q. That is an offer from the Irish Intercontinental5 Bank to your company for a loan of Stg 700,000.6 Now, you can take it that that was cash-back loans.7 As you said yourself, they were all a cash-back8 loan. The offer letter to you makes no reference to9 the back-to-back facilities?

    10 A. It does say the security there, "security.... in a11 manner acceptable to IIB".12 211 Q. Well I think we all the know the difference between13 a truth and a whole truth. Will we put it like14 this, it is at least economical with the truth, if15 you understand?16 A. I don't think we were deliberately trying to hide17 anything.18 212 Q. It is not your document, Exhibit I, but I am saying19 to you, that is typical of the way the business was

    20 done?21 A. Yes I see.22 213 Q. Do you accept that, that that was typical of the23 kind of short-hand that was used to hide the fact24 that there was a specific back-to-back facility?25 A. Well, is there something incorrect about a26 back-to-back facility, because obviously the bank27 have to have some kind of security and, as far as I28 was aware, the money that was in Jersey was legally29 over there and the bank, well you have to give them

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    1 some security other than motor vehicles or whatever,2 so that is why we used that. I was not aware that3 that was illegal.4 214 Q. I am not saying it is illegal, that is a different5 matter altogether. You see, one of the problems,6 Mr. Murray, and you had better take legal advice on7 this because you may wish to make representations,8 one of the problems we have on this is that, on the9 one hand, you send money out to a Trust, whether it

    10 was you or your father, it does not matter at the11 moment, it is somebody within the company, sends12 money out to a Trust. They no longer have control13 of that money because it has now gone into the Trust14 but in reality they have control?15 A. I would have thought my father would have had16 control of the Trust.17 215 Q. At all relevant times?18 A. I would have understood that he decided to do19 whatever he wanted to do so he wasn't giving the

    20 money out to Joe Bloggs who wouldn't go through21 everything, you know?22 216 Q. I understand. I am not going to go back even though23 I have a note here with regard to what appears to be24 withdrawals for yourself, your father, your mother25 and Ray Carroll of 91, 81, 91 and 50,000 but I26 think you are going to come back to me on that. You27 have that copy there, have you, Exhibit 4?28 A. Yes I have a copy of it.29 217 Q. We normally take a break but we are almost finished

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    1 so I don't think really it's necessary.2 A. I am fine, yes.3 218 Q. And there is a cup of coffee or tea there?4 A. Thank you.5 219 Q. Could I show you at page 217, I am going to give you6 a copy and to a certain extent now I am asking you78

    to account for the potential sins of others but aspart of your company, if you like. I know it is

    9 signed by Mr. Carroll but it is your company's name.10 You can see the problem there, Exhibit 8.1112 This is a letter sent by one of your company's13 signed by Mr. Carroll which says:141516

    "I wonder would it be possible to omititem 3 in the letter to Stokes KennedyCrowley confirming the amount of theloans at the end of the year."

    17 You can take it that item number 3 is dealing with181 Q

    security.

    20 If you give, Mr. Murray the following document as21 well because that is necessary for a fuller22 understanding as to what was asked. That is pages23 218 and 219, Exhibit 9?24 A. (Handed) 92 and this is 93?25 220 Q. Yes at the time when you were the Managing Director26 of course. Mr. Carroll must have been still a27 Director of the company?28 A. He was involved. I must check those dates.29 221 Q. Would you do that?

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    1 A. Yes .2 222 Q. It did strike me as a little odd. I do not think he3 went out quite immediately?4 A. No he didn't, no.5 223 Q. I am going to assume for the moment, unless I know6 to the contrary, that he was still involved on that78

    date and he was writing on behalf of your companyand was effectively saying "hide the security"?

    9 A. Okay.10 224 Q. Have you any comment to make on that?11 A. No.12 225 Q. Would it be fair, Mr. Murray, or unfair, finally as13 far as I am concerned, Ms. Mackey may have other14 questions, but would it be fair to say, I know we15 have already gone into the question of who16 controlled the money when it went out to the Trust17 and you said it was your father, I understand all18 that, but would it be fair to say that at some time19 immediately prior to the money being repatriated for

    20 the Amnesty, that discussions were held between21 yourselves and the accountant with regard to the22 matter?23 A. Yes .24 226 Q. That would be quite normal?25 A. Yes .26 227 Q. Do you remember who was involved in those27 discussions ?28 A. No because I wasn't involved directly. I was not29 involved in the discussions of that but when I was

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    1 advised I was a beneficiary, I was told that I would2 be advised on the Amnesty and to do something but I3 was not involved in the discussions as to how or4 what at that time.5 228 Q. Who would have advised that you had better do6 something because you were going to get money out of78 A.

    it?My father would have said, "We feel that we should

    9 avail of the Amnesty" and he would have said or10 advised that we are going to avail of it in order to11 bring it back and put it into the company.12 229 Q. Yes .13 A. I have to say I was not aware of the percentages at14 the time.15 230 Q. Would Mr. Carroll have been involved in those16 discussions ?17 A. Yes .18 231 Q. So you would think from a practical viewpoint it19 would be Mr. Carroll and your father and Stokes

    20 Kennedy?21 A. Correct.22 232 Q. Would Noel have been involved in it?23 A. No, he would not have been involved in it actually24 because he was not -- I think he was a main Board25 Director at that point.26 233 Q. Would your mother have been involved in it?27 A. No.28 234 Q. Did your mother have any say?29 A. No she was not involved in the company.

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    1 235 Q. Would it be fair for us to assume that in so far as2 that generation is concerned, that the control of3 anything of that nature rested with your father4 rather than your mother?5 A. My father really, everything yes.6 236 Q. Rather than your mother?7 A. Yes.8 237 Q. She would have taken a back seat in those sort of9 things?

    10 A. Totally.1112 MR. MURRAY WAS EXAMINED, AS FOLLOWS, BY MS MACKEY:1314 238 Q. MS. MACKEY: I have just one question,15 Mr. Murray.1617 Judge O'Leary asked you about the four other Trusts18 whose names were mentioned and they were all19 unfamiliar to you. But can I ask you this, did you

    20 have a Trust yourself in either Jersey or Cayman?21 A. Did I have a Trust?22 239 Q. Yes?23 A. No.24 240 Q. Or your brother or any other member of your family25 that you know of?26 A. Not that I am aware of.27 241 Q. Thank you.2 8 JUDGE O'LEARY: Would you do us a favour29 in that regard? I am not

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    1 247 Q. Yes but he is moving out of the business?2 A. He is, yes.3 248 Q. But he is not deceased but your other brother is4 deceased?5 A. My other brother is dead.6 249 Q. And your father. I am not asking you to account for7 them. Obviously I have to ask with regard to their8 involvement in the company. But with regard to9 their own personal business, that is their own

    10 personal business and it is nothing to do with you.1112 So, I wonder, would you do that for us?13 A. Okay.14 250 Q. It would be considerably helpful. Is there anything15 else?16 MS. MACKEY: No.17 JUDGE 0'LEARY: Thank you very much. What18 happens now is actually19 very simple. This lady over here in the corner has

    20 been taking a careful note of everything we said.21 That will be reduced into a transcript form and you22 will be asked to sign the transcript just to say23 "yes that is what happened".24 A. I am sorry if you think I was in any way unhelpful25 but, as I said, in running the company and kind of2 6 moving up through the ranks I was not that involved27 with the financial end, whatever, in detail.28 251 Q. Mr. Murray, I did not form the view that you were29 unhelpful at all.

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    1 252 Q. MS MACKEY: Finally, Mr. Murray, would2 it be true to say that3 Mr. Carroll was the person most involved in the4 financial end of the company?5 A. With the company, yes. There was arrangements of6 loans and cash loans.7 253 Q. And he would have had a good knowledge of the8 company's finances and how it conducted its9 business; isn't that so?

    10 A. So.11 254 Q. JUDGE 0'LEARY: And would have been your12 father's financial13 advisor?14 A. My father was there every day up to some months15 before he did. He used to go in and he was a very16 dominant personality.17 255 Q. And you know the way these dominant personalities18 gather around them people who carry out their19 wishes, if you like?

    20 A. People who advise them, yes but he did not.21 256 Q. Would Mr. Carroll fall into that category or was22 there a friendly relationship or was it purely a23 business relationship?24 A. I would say there was a friendly relationship there.25 They worked together for years.26 257 Q. What age is Mr. Carroll now?27 A. Ray is now, say, 75.28 258 Q. MS MACKEY: Just one other question,2 9 Mr. Murray. Do you have a

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    1 brother Austin?2 A. Austin, no. No, Paul was my brother and Noel is my3 other brother.4 259 Q. JUDGE 0'LEARY: Thank you very much5 indeed.6789 THE EXAMINATION WAS THEN CONCLUDED

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    272829

    50

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    i

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    w i i m i i i mm tmniti u .IN CB. --.-_iTkVLINSIW H I < m C . LEDGER

    G i n N N E ^ + J ^ O N U T ). . '" >.'". "iMMU*r'MMbl uti/U/tf

    n m n r M i JlH*Ha

    IS ,f 7I .OF,KI S4HMI0

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    Appendix XV (153) (1) (c)

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    w a r , / m m

    flftft HWffHf W -

    p . an

    CTP40004 r06040018

    0604019ft09040317

    Mimufti0604081900040840

    a m

    Sumao

    fiyszastt J a b o tItObDJM.a t iu SD.M.VanIRCIRftUS* .DM.ItsAStfrlO.FII.U8t

    MOMMM 1,111,317.00**9BMT1M tr*110M.TB * < / *781,17.7

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    Appendix XV (153) (1) (d)

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    !l G + Ma*maaMtMIMCGU1NNE SS+MAH0N LTD

    17 CataftOma Ovate 1 P 0.1 g* TmihwhjHHMCIIIHM SS NAHM CAIMAN THUJT / C3LLKCM SUMACaiUtCHNAMSa r t M A k c a u. a /A LEDGER i e*o*oil*m iM M M 20JAN94

    STAriKt.-cr NO.(AOS MO.

    'BAH

    .'V 7m -

    i>imin

    m m nrt|3ALAMCC MOUCMr M*HA>CfU (HTUtST MTB CHAMGtO . 1 3 9IXCH CUXNNISS .1 C T /SOU.

    -..V.y r-^SiV-

    ITxio;- .

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    WMi.aoo.oo! i > * j i c s c . o oo.ooO.ao

    V"

    I J /* ?tf i

    r

    CUINN6SS KAHON CATNAN TRUST / CCU.CSS

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    Appendix XV (153) (1) (e)

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    IRISH IHTtHCONTimHTAL SANK

    FOD/AOC January 4, 1994Kredietfaank NV London B ranch,Exchange House - 7th Floor, .Primrose Street,London EV2A2HQ .

    Sumac Investments Lfmited/Murravs Eu ropcar Limited/Esmonde Motors Limited.\

    : . . . Sirs,We refer oour letter to you of 28 May 1993 in connect ion with Sumac InvestmentsLhnited/Murrays Europcar Limited. We hereby confirm that it is in order to transfer the fullbalance on deposit account number 40349002 to our account in Royal Bank of Scotland -.. account Irish Intercontinental Bank Limited. We understand that the balance on this account iscircaGBP922,6o6. ' *W e also refer to our letter to you of 28 M ay 1993 in connection with Sumac InvestmentsLimited/Esmonde Motors Limited. We confirm that it is in order for you to transfer the fullbala nce on deposit account number 40349001 to our account at Kredietbank Bankverein Bremen- account number 5000971910 - account Irish Intercontinental Bank Limited. We understandthat the balance on this account is circa DM1,142,000.

    v.:mts. With HB iai the folfr^proportioiis, Haiold $ Munay - 31%,'liaorold P.'Wbnii^ f ^ K ind ib^S^nd'CacroKl if J."- :."# * ,:'..

    W e hereby confirm that you will be released from your guarantees to us of 28 May 1993 subjectto receipt of the abovefilnds. W e understand that the transfer of funds is to take place on 7Janu ary 1994. The instruction of Sumac Investments Limited in relation to the amount andallocation of the transfer to the individual deposit accounts m ust be in accordance with die aboveproportions.Yours faithfully,

    yj/j dl j*' * m Donlon, Finola O'Donoghue.cutive Director. Manager.HUSHINflKCONtlNtNfAL BANK LIMITtD l MLRWON M)UAU. OUSLIN I (UtCHClNC. 01 OOI")?J*' rACSIMHt. 01 >H0>4 tltX JJ11A hUMhtUIAHV Of KHlDttTBANN N V

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    HURRAY GROUP HOLDINGS LIMITED AND SUBSIDIARIES

    CREDIT APPLICATION

    Background:The Murray Group ("Murrays") was started in the 1930's by H.F. Murray, nowretired. The principle business was initially the hire car business (withsome chauffeur driven cars), although they subsequently expanded into car

    -'isales","- The current group structure is;outlined in ApfMndix. 1;(including ... .trading) although there are only' two principal trading companies/, ->. viziJ . t * *

    - Murrays Europcar Limited - Car hire- Esmonds Motors Limited - Car salesMurrays held the Hertz franchise in Ireland for approximately 20 'years until1972- when Hertz decided to set up their own organisation in Ireland. At^ ^ s g r t a s r a j ^ continue in business at that time. In 1973 Murrays entered e licensingagreement with Europcar/Godfrey Davis which is still in effect. They currentlyhave a five year agreement with Europcar until 1st Janaury 1994.The referral of business by Europcar is extremely important for Murrays

    accounting for approximately AOS of total business. In addition, Murrayshave three year contractwith Aer Lirtgus to suppfly/drive programme. This also leads to substantial volumes particularly

    ^ -" " Jti ^ l ^ SM ^ IiiMSiiiici Vacant' s e a t s W

    Fleet Movements:Murrays traditionally start the year with 300/350 cars all less than a yearold. Beginning in February/March this is built up to 800/850 cars bythe end of June. Approximately 300 new cars are purchased while the balanceare leased. Sales of the older cars commence in August/September and aredisposed of by November/December. The year then commences again with astock of cars of approximately 300/350 all-of which would be less than ayear old.

    tftt

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    )

    PrbpoaaliMurrays have a core borrowing requirement of approximately IR1.2m whichthey have traditionally borrowed in currency. It i9 proposed to transferthis fron Guinness-& Mahon who currently provide it.

    It is also proposed to provide a short term revolving credit of up to IR3mto be drawndown as indicated in Appendix 2. This will be used for new

    fleet, purchases and would be repaid in accordance with the schedule. As.Indicated above this is a short it (irm>elfTUqM4.dtln9^'It has - traditionally been provided by Bank of .Ireland Finance.Existing Banking Facilities*The following facilities are .available to Hurrays

    t1. Bank of Ireland - Overdraft Facility - IR250k

    Credit - IR400k2. Industrial Credit Company - Tourism Loan IR3Q0k3. Bank of Ireland Finance - Car Loans - Up to IR2.5n.The Bank of Ireland facilities are secured by an equiteble deposit of thetitle deeds to Haddington Road (value IEP 400k) premises and the guaranteeof various group companies.The Bank of Ireland Finance facilities are secured by a chattel mortgage

    .. ~oves..tl.jHW1 financed together with a. holding coapeny guarantee^a*w. I ^ v j O U U * ^ : ^ ; ^ ^ , ^ ^ .The ICC facilities are secured by a floating charge oVer horndene InvestmentsLimited, a chattel mortgage over the cars financed and a guarantee of MurrayGroup Holdings. The cars financed are owned by Thorndene investments.It is with a view to simplifying the above structure that IIB has an opportunityto provide the revolving credit facility.Proposed Security t.The term loan would be secured for principal only by a bank guarantee acceptableto 118. This will be provided on behalf of a trust controlled by the shareholdersof the company, who have a deposit of a similar amount.

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    Security for the short term revolving credit would be the guarantee of allgroup companies supported by fixed and floating charges on all assets ofthe group. While^he past the company has provided chattel mortgages onthe.oars financed,"given the short term requirements, the size of the fleetand the frequent sales and purchases this has proved administratively cumbersomeand very expensive. Murrays, therefore, are currently seeking a bankwho will provide the facility without the chattel mortgage requirement..Trading: ..... ...' Appendix 3 contains the consolidated profit and loss account for the groupfor the last two years. Pre-tax profit in the year to December 1987 amountedto IR414k (1986: IR172k) more than double that of the previous year.1986 returns were depressed by the small number of Americans in Europe dueto the Libyan crisis and the fact that Murrays did not have the contractwith Aer Lingus that year. Interest cover in 1987 wes 2.4 (1986: 1.66)a satisfactory level for what is essentially a short term leasing company.Management accounts for the year to 30th November 1988 indicate , a pre-taxprofit of IR408k (Budget: IR320k) and the projected out-turn for the yearis similar to 1987. 1988 has seen margins eroded but the Aer Lingus contracthas increased volumes significantly. An improved car market has seen EsmondsMotors performing well for the first time in many years.Financial Postitlon:Thir financial position-at-31st Paceabernet worth of IR2.1m (19B6: - IR1.7n) representing -39* of total assets.The long term liabilities represent 7158 of net worth but when deferred taxationis excluded long term debt amounts to only 50* of shareholders' funds.Overall, the level, of gearing is very .low at year end in this company -reflecting the cyclical nature of its fleet.At mid-year, both the inventory of cars and short term debt can be expectedto increase by up to IR3m. Nevertheless, this represents stock coverof 2 times. The stock would be readily saleable over a number of monthsand would be more than capable of repaying short term debt. Other currentassets (IEPBOOk) and fixed assets of IEP 1.2m provide significant additionalsecurity cover.

    T

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    Assessment:This is a company with a long tradition in the motor industry in Irelandwhich has weathere'd the recession of the 80's very well. It has been wellintroduced to the bank via Stokes Kennedy Crowley, who are their auditors.Alex Spain has recently joined the Board of Murray Holdings, having beenassociated with the company for many, years.

    ">. The pro osail ;for; facility .represe^. return of 3/4% on whaV is very' limited fisRT1 The risk onlnterestislimited'."-lilv:'", ^ "as the structure can be collapsed at any time (KB London will earn Vflgon the guarantee which- is cash collateralised).

    !The proposal to finance short term car asset's is well secured by stocksand'fixed assets and is inherently of a self-liquidating nature. IIB willhave the right to inspect the very comprehensive fleet summaries which Murraysproduce on a monthly basis. It will be possible to verify the location

    ~ f l e e t " and-to'lnspect-lte * tax >*i6k.aSrtaMcentrally in head office.The principal risks associated with the short term funding proposal arechanges in excise duties and frauds Given the likelihood that any exciseduty changes will be signalled in the Budget, (in January - when stocks ereat a minimum) and the short term nature of the funding it is likely that

    ^ the company will be. able to take steps to ameliorate the fffc s. of thechanges. In addition, the i^rtance.of the car hire industry to tourism

    4 ^ liey conceivably lead 'to- special treatment -as ,thaIpmb*.-^ makes the possibility of large scdle fraud unlikely. Any disposal of the fleet

    in excess of plenned level would have the effect of reducing prices significantlyin the market place.Overall, Murrays appears to be a tight well managed operation. They produceexcellent fleet and financial management in a timely fashion within twoweeks of month end. Having weathered the recession of the early 80's theyare well poised to take advantage of the present, upturn in the economy andthe increased emphasis being put on tourism.The strong asset cover and the readily realisable nature of stock providea strong basis for providing the facilities outlined. j m

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    ' la

    I

    B o r r K e r i Hurrays Europcar H2jJ*S' 2803 Pate: 3.2.

    C26) Purpose and JustificationPurposet 1. .To approve a new IRi.2m equiv. term loan facility;

    2. To approve a new IR3.0m equiv. revolving credit facility.Justification: 1. The term facility represents a good return on a bank guaranteed

    fecilityi.2, The revolving credit isjustified.by: ,

    I '.':'. (a) thestrong asset cover (2.5j.) --W(b) the annually self liquidating.nature of the transaction.(

    (27) Guarantees and Collaterala). Existing

    A 'b) In processe) Proposed (New or additional) vi B a n k Guarantee acceptable to IIB

    (probably KB London)i

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    Appendix XV (153) (1) (g)

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    i^hln428:

    I . I

    429sRacommandad.Murrays European

    Amount:ftirpote:Rata:Drawdown:Scurl_ty:Ravlcw:Recommended.

    170,000Working capital15%

    * 4/5/77"Suitably leemed".4/11/77

    430:

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    V * 'I 1

    IRISH INTERCONTINENTAL BANKLIMITED25 April 1989

    Our Ref: GQ/VH/2803Murrays Europcar LimitedBaggot.Street BridgeDublin 4

    Dear 8IraWe are pleased to confirm the wllUngneaa of JrlahIntercontinental Bank Limited ("IIB") to make the.following facility available to Murraya Europcar Limited("the Borrower") on the following terms:and condltlons:-1 TYPE OF AND AMOUNT OF FACILITY;

    A term loan of up to STG700.000 (aeven hundredthousand Sterling pounds) to be used by the Borrowerfor general working capital purpoaea.2. QVRflgNpY QF FA Cy UT Y?

    Thefacnity.maybe drawn own inanyfreely.. available currency other than Xrleh pounds eubjaptto the agreement of ITB and the Central Bank ofIreland.3. LA TE ST DflAWPQWN PATit

    The facility la to be drawn down 1n full not laterthan May 318t, 1989. Mot leaa that two bualneaadays notice of the Intention to make the drawingwill be provided by the Borrower to IIB.

    i

    Iiszkcfbttred Number *W37 Republic of IrcUnd

    . y c

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    /2.

    INTEREST;The Interest rate or rates on amounts outstandingunder the facility.will b aet on the data of firstdrawdown and for subsequent rollovers on the firstday of each Intereat period. In each case theInterest rate will be 3/4X above the rate at whichIIB shall be offered funds of like amount on theLondon Interbank Market for the remainder of therelevtmt Interest period. iThe Borrower may, by notice 1n writing to IIB, notlater that three business days before the date offirst drawdown, or as the case may be before theexpiry of an intereet period, elect whether the nextfollowing Interest period will be of one or threemonths duration, or such other duration as may beagreed from time to time by IIB and falling suchelection by the Borrower, the next following IInterest period will be of three months duration.Interest will be calculated on the dally balanceoutstanding and will be due and payable on the lastday of each Interest period with the final Interestpayment on the date of final repayment of the loan.

    5. PERIOD OF FACILITY:Without perjudlce to ZIB's right to requirerepayment of the loan on demand at any time, 1t Isagreed that, unless and until IIB shall exercise isuch right, the loan will be repaid not later thanJanuary 31st, 1990. I" ' i ' ' ; . . //; ;'.." I

    6' SECURITY s ' ' *Any and all indebtedness or liability of theBorrower to IIB is to be secured in a manneracceptable to IIB.

    i % e e

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    /3,7- CONDITIONS PRECEDENT;

    In addition to the Conditions Precedent set out inclauae 1 of iib's Standard Terms and Conditions,drawings under this facility are subject to:-(a) Completion by the Borrower of warranties In aform acceptable to IIB. The warranties relateto 8uch matters as the accuracy of Informationfurnished In the course of negotiations for thefacility and the absencerof any pending or

    . threatened litigation;(b) Receipt by IIB of appropriate Instructions asl. to the management of the account;(c) ixb being satisfied that adequate overdraftfacilities will continue to be available fromthe Borrowerother bankera;

    a* STANDARn TERMS AND CONDITIONS:The facl 11 ty is subject to IIB's Standard TermsandConditions which are attached hereto and which formpart of this facility letter.

    8 * ac ce pt an ce Q P QPFER.This offer will lapse on 1st May 1989.

    f^ T o accept this offer on the above terms andconditions, the enclosed duplicate of this letter8nouldbe signed and returned toue, together With ,the aittached form for the opening of. an accountYours faithfully,

    for and on behalf ofIRISH INTERCONTINENTAL BANK LIMITED

    E A MARAH Deputy Chief Executive ^*Associ oicawcorAccepted on the above Terms and ConditionsFor . and on Behalf o f MURRAYS EUROPCAB LIMITED.and on Behalf o f MURRAYS EUROPCAB L.

    loriseo signatory Authdrhu t h o r i s e d S i g n a t o r y Authorised Signato

    T

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    Append ix XV (153) ( l ) ( i )

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    EuropcarMurray* Europ car Limitedfaggot 8trat Bridge,Dubfln 4, Imtand.Tale phone 668 1777Telex 83784Fax 660 2956

    ~ li/K ^ VJ/O u r ret: llC/VfCJ v b y p t t , 1 9 9 3 .

    / M r . H u d o D o h e r t y* H a n a o e r - B a n k i n o r ,I r i s i i I n t e r c o n t i n e n t a l B a n k ,9 1 / C a r r i o n S q u a r e ," v D u b l i n = 2 .

    at M

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    Appendix XV (153) (1) (j)

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    ^ ^ . this torm nas oeen approveu uy.uie nuuiutc u i u w i w i s uIrish Banks' Standing mm ittee and the Northern Ireland Bankers' ' tociatio n.The Manager, Our ref: AJ OC [C M

    fe& tefc (Bank)JfaMCiStiA. (Branch)

    Dear Sir,r - (Name of cuitomer)

    I/We have read this document and l/we authorise you to provide the information requestedherein in respect of the accounts of the above-named cuitomer and also to disclose thenumber of Joint accounts, if any, to which the above-named customer Is party.Please sendtots ntimatiori to ^a ud fof oK yfrI Sfekgg fktQ. , St. St&iju+A Kr^LM . ZYours faithfu lly.

    mhmmmnmmmin seeMeAuthorised Signature(s)Dear Sir, i iWe report that at the close of business on* the records of thisbranch showed:

    o

    ''*-'''"*>-1'-.--Description of a/ra(Including deposit a/cs) S/SXNote A

    Dm of In tinter outliningterms/conditions ofborrowingBalance DrJCr. postetfat above date (Note B t'

    ''*-'''"*>-1'-.--Description of a/ra(Including deposit a/cs) S/SXNote A

    Dm of In tinter outliningterms/conditions ofborrowingBalance DrJCr.

    Interest -DrJCr.Est. CurrentAccount Peas& othei lihacoy

    &cjbcI /oo-v.Onfollo/sS

    ..iif -4 j.-

    7ook \ssf*t

    Note A Where a specific letter of set-off for principal exists affecting any of the aboveaccounts, please Indicate this by adding S to the account title. If the set-off refersto accounts other than those being reported on use SX. (Other set-offs may ariseeither at law or on foot of a bank security document).Note B The provision of this information may entail work and oastt. If the information isnot essential this request should be deleted.2. FULL TITLES AND DATES OF CLOSURE OF ALL ACCOUNTS CLOSED DURINGPERIOD:

    >tMMI**l*W*IMfl>l

    N .8 . Date to be inserted befarq form is sent to bank. C.2S (11/82)

    T

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    r V . Nature of tecurit\ ltd direc tly from customer (e.g. Deeds. Stoc Shares etc.).Amount only of any guarantees held for the benefit of the customer.

    M * * t I M M M M M I * < M M M M M M M t M * M * * * H M * n t M * * MMM>IMMMM*HMMt lMMM(MmMM| |(M t, #l

    4. CONTINGENT LIABILITIES:All known contingent liabilities%(a) Total of Bills discounted for your customer, with recourse(b) Amounts and dates of each Guarantee, (axducfinfl Accept-ances) Bond or Indemnity given to you by the customer.

    i - (c) Amounts and date* of each Guarantee, (excluding Acceptancas) Bond or Indemnity given by you on behalf of yourcustomer.(d) Total of Bills drawn on and aceeptad by Bank on behalf ofcustomers (excluding (f) hereunder).(e) Total Forward Foreign Exchange Contracts.(fhTotsI -o f - Outstanding- UabU itie..M nd^D9cun \S^rY,Credits.(g) Others Please give details:

    Oate(i) Amount

    The information available at branch contained herein Vgtoen In confidence for your use*only, in Yourcspsclty as Auditor(s) and without responsibility on the part of the Bank or. any of Its officials* " -Note: No information can or will be given which would disclose confidential Information

    regarding other customers.Signed MMtMli

    IMMtWI *

    ManagerDate

    Branch Brand

    FormSBRI (1982) 528 (11782)

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    Appendix XV (153) (2) (a)

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    Oil M I L S W E E N E Yc i t o r sr k,

    The Earlsfort Centre,

    STRICTLY PRIVATE & CONFIDENTIALADDRESSEE ONLYThe InspectorsThird FloorTrident HouseBlackrockCO DUBLIN

    Earlsfort Terrace,Dublin 2, Ireland.Telephone 01-664 4200.Fax 01-664 4300.Intl. Code + 3 5 3 - 1EMail [email protected] 109 023 Dublin

    Our Ref:December 3, 2001 C/M18/NSPM NF/FFour client: Harold T. Murray, The Leys, Glenamuck Road, Carrickmines,Co. Dublin.re: The late Mr. Harold F. Murray, deceasedDear Sirs and MadamWe refer to your letter of the 25 t h October, addressed to our above named client.Our client has instructed us to write to you in response to the preliminary conclusionthat the late Mr. Murray (our client's father) was a client of Ansbacher.Company loansAs our client has averred to on Affidavit, funds were paid out of the Companies forthe benefit of the Trust and thereafter ceased to be Com pany m onies. TheCompanies had no further beneficial interest, direct or indirect, in the monies exceptin one respect. The principal shareholder of both Com panies at that time wa s ourclient's father, the late H.F. Murray. He was also a beneficiary of the Trust and wasinfluential in getting the Trusiees to see their way to placing certain Trust funds inbank accounts, f irstly, with Guinness & Mahon (Jersey) and later with Kredietbank,as a result of which the C ompanies got slightly more favourable terms o n borrowingsfrom the said banks.Trust fundsYou have already been furnished with a copy of the Trust document entered into bythe late Mr. Murray (" th e W o od ward T ru st']. Under the Trust Deed and at law, theTrustees of the Woodw ard Trust had full control over the funds held by them.The Woodw ard Trust was set up by our client's father. Our client had noinvolvement wha tsoever in the establishment of the Trust. Nor did he have anycomm unication w hatsoever w ith the Trustees at any time.

    I 1 / 1 To i Norman ritegernld Francis Hackett Sean Greene

    mailto:[email protected]:[email protected]
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    Appendix XV (154) Mr Brian Rhatigan1. Evidence relied upon by the Inspectors in arriving at the conclusion relating to MrBrian Rhatigan.

    a) Guinness and Mahon statement of 20 November 1992 - GMCT reCollege.b) Internal Guinness and Mahon memo of 25 May 1977.c) Extract from credit comm ittee minute of 26 October 1977.d) List of companies, furnished by Mr Brian Rhatigan, with which he wasassociated.e) Extract from Guinness and Mahon executive directors meeting of 29 June1977.f) Extract from credit committee minute of 31 May 1977.g) Extract from Guinness and M ahon banking report dated July 1985.h) Extract from Guinness and Mahon banking report dated M ay 1988.i) Extract from Guinness and Mahon credit comm ittee minute of 25 O ctober1978.J) Extract from Central Bank Report on Guinness and Mahon dated 1978.

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    Appendix XV (154) (1) (a)

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    "2+M

    C

    RCT CLUT CALLitmtNkkITI'HAl. CAC1.CPOStl LEDGER

    tlAHMMirf tfiI.>r||ftGUINNESS+MAHON LTIt7Ca*^0"Outilli2P0 Ow56ATirv,. i n * ,

    iONaviZWtMWIUI

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    Ap p e n d i x XV ( 15 4) ( l ) ( b )

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    IS )r|T7.

    Brian RhaHflan, &q uW - EXTENSIONAmounh 15,000Tame Extwialonof 3 months o 0/9/97Ratat 15% fixedDrawdown: By way of iuctuatfns verdraft. (fVawmt i e r f a n c a 12,530.)Security: "Suitably Sacrured".,Rovlaw: 30/9/77RMonimmdad Brian Rhallgait/ Esqulr* - EXTENSIONi

    W)

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    Appendix XV (154) (1) (c)

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    Minutes or the 148 th Meeting of ttwBanking /Credit Committal hetd at 17College Green, Dublin 2, en Wednesday24th October, 1977.J. D. T. - M. E. O'K. - M. J. P. - GMbC - P. O'D. - BMeL. - M. C. K. -I. W. K.MONEY MARKETi

    3

    unit

    Anthony & Brian Rhatfgan:Amount:Purpose:

    5,000Guarantee required by Ulster Bank Ltd.Ranelogh.

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    CcmtnlljiMJtt FM>Saeurily:Reoimwndd

    ImI-nlsai

    50Sultdily Stenrwl.

    A j ^ . t a -'. >

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    Ap p e n d i x XV ( 15 4) ( l ) ( d )

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    r\

    -"Rhatigan Holdings Limited P A R Holdings limitedBro okfidd Securities limitedftledusa Securities limitedpakley Securities LimitedSp acem ate Ireland LimitedArdiff Securities lim ited'^B d-Odi Holdings lim itedTownhold limitedW antu Securities Limited -''Rhatigan Developments lim itedY or k Securities limitedManagem ent Group limitedS tar ling Securities LimitedTarstone Limited"Keansburgh Limited

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    Appendix XV (154) (1) (e)

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    Appendix XV (154) (1) (f)

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    r

    145U Mt d m Saeurttto Ltahocb

    Thli loan'to Hm abovo nmHanad, which b eohtrolUd by f hcstfgan Brat.TrvoIvm a total of 140,000 and will U provided by

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    Ap p e n d i x XV (1 54 ) ( l ) ( g )

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    HAMONO REPORT - JULY 1885

    LOANSI

    VT iMUod a qmrantM for 100,000 la twour f IrtahUfa A m m t i on bthalf of Rhtlgmn Holding! LimitedMid ractttved cih In exchange.

    s

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    Ap p e n d i x XV (1 5 4) ( l ) ( h )

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    ncsrr xARrrr:

    M B B fcovmamrxB:

    " ~ - ' " * b*T lnraad ma gnaraatM fw LSO,000 la tvnae at A.X.X.B.(a ta r l la* Swm rl tlM - Brian f t Tony B b a t l m ) 1to ba JaSSS^JbU lfllk ** Zndcamltjr for &5GOA>

    K U I O O ^nnu iRa i ;

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    Appendix XV (154) (1) (i)

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    Minutes of the 249th Meeting of theBanklrm/tZrsdit Committee held at17 College Green, Dublin 2, onWednesday 25th October, 1978.

    M. E. O'K. - M. J. P. - GMcC. - P. J. F. - P. O'D. - I.W.K. - M. C. K.

    Oakley Securities Ltd:

    Amount:Purpose:

    A

    Term:Rate:Security:Recommended.

    70,000Working capital1 year2% over bateJoint and Several Guarantee A . & B. Rhatigan andhypothecated deposits in name of Par & Brl-odlHoldings to extent of 40K.

    S ig n e d / /* * ^ O ^ * ^Dated -%.-\'m r *>

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