usa vs james davis - stanford swiss secret account

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When Stanford needed cash to make these bribe payments, he generallywould instruct DAVIS to debit funds from a secret numbered Swiss bank account atSociety General Bank (SocGen account# 108731) and to wire those funds to an SFGaccount at Bank of Antigua, from which the cash in United States dollars would bewithdrawn. This secret SocGen account # 108731 was funded by CD investor fundsand was also used to make regular bribe payments, via wire transfer, to SIBL's outsideauditor in Antigua, C.A.S. Hewlett & Co. Ltd.

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EXHIBIT 2

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IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

SECURITIES AND EXCHANGE COMMISSION,

Plaintiff,

v.

STANFORD INTERNATIONAL BANK, LTD.,STANFORD GROUP COMPANY,STANFORD CAPITAL MANAGEMENT, LLC,R. ALLEN STANFORD, JAMES M. DAVIS, andLAURA PENDERGEST-HOLT,

Defendants.

§§§§§§§§§§§§§

Case No.: 3-09-CV-0298-N

APPENDIX TO NOTICE OF FILING

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Dated: September 28, 2009 Respectfully submitted,

BAKER BOTTS L.L.P.

By: /s/ Kevin M. SadlerKevin M. Sadler, Lead AttorneyTexas Bar No. [email protected] I. HowellTexas Bar No. [email protected] T. ArlingtonTexas Bar No. [email protected] San Jacinto Center98 San Jacinto Blvd.Austin, Texas 78701-4078Tel: 512.322.2500Fax: 512.322.2501

Timothy S. DurstTexas Bar No. [email protected] Ross AvenueSuite 600Dallas, Texas 75201-2980Tel: 214.953.6500Fax: 214.953.6503

ATTORNEYS FOR RECEIVERRALPH S. JANVEY

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CERTIFICATE OF SERVICE

On September 28, 2009 I electronically submitted the foregoing document with

the clerk of the court of the U.S. District Court, Northern District of Texas, using the electronic

case filing system of the court. I hereby certify that I have served the Court-appointed Examiner,

all counsel and/or pro se parties of record electronically or by another manner authorized by

Federal Rule of Civil Procedure 5(b)(2).

/s/ Kevin M. SadlerKevin M. Sadler

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1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS

2 HOUSTON DIVISION

3 UNITED STATES OF AMERICA . 4:09-CR-00335-1

4 . HOUSTON, TEXAS VERSUS . AUGUST 27, 2009

5 . 9:00 A.M. JAMES M. DAVIS .

6 . . . . . . . . . . . . . . .

7 TRANSCRIPT OF REARRAIGNMENT BEFORE THE HONORABLE DAVID HITTNER

8 UNITED STATES DISTRICT JUDGE

9

10 APPEARANCES:

11 FOR THE GOVERNMENT:

12 Gregg Jeffrey Costa Assistant United States Attorney

13 Post Office Box 61129 Houston, Texas 77208-1129

14

15 ALSO FOR THE GOVERNMENT:

16 Paul E. Pelletier Jack B. Patrick

17 Matthew A. Klecka DEPARTMENT OF JUSTICE

18 1400 New York Avenue NW Washington, DC 20530

19

20 FOR THE DEFENDANT:

21 David Michael Finn MILNER & FINN

22 International Center - IV 2828 North Harwood Street

23 Suite 1950, Lock Box Nine Dallas, Texas 75201

24

25

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 APPEARANCES - CONTINUED

2

3 OFFICIAL COURT REPORTER:

4 Mayra Malone, CSR, RMR, CRR U.S. Courthouse

5 515 Rusk, Room 8016 Houston, Texas 77002

6 713-250-5787

7 Proceedings recorded by mechanical stenography. Transcript produced by computer-aided transcription.

8 - - - - -

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Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 P R O C E E D I N G S 0 9 : 0 1

2 THE COURT: Court calls the case, Criminal Matter

3 09-335-01, United States versus James M. Davis.

4 Who represents the government?

5 MR. COSTA: Gregg Costa for the United States, and I'm0 9 : 0 5

6 joined by Paul Pelletier, Jack Patrick and Matthew Klecka from

7 the Department of Justice.

8 THE COURT: Who represents the defense?

9 MR. FINN: I do, Your Honor. David Finn, F-I-N-N.

10 THE COURT: Do you want to bring your client up,0 9 : 0 6

11 please?

12 MR. FINN: Yes, sir.

13 (Compliance)

14 THE COURT: I understand you want to enter a plea of

15 guilty in this matter; is that correct, sir?0 9 : 0 6

16 THE DEFENDANT: Yes, Your Honor.

17 THE COURT: Raise your right hand and take the oath.

18 (Defendant sworn)

19 THE COURT: All right. Do you understand you are now

20 under oath and if you answer any of my questions falsely, those0 9 : 0 6

21 answers may later be used against you in another prosecution

22 for perjury, that is for making a false statement?

23 THE DEFENDANT: Yes, sir, Your Honor.

24 THE COURT: You can step back. Why don't you step a

25 little bit to the side. It should pick up. Okay? 0 9 : 0 6

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 THE DEFENDANT: Yes, sir.0 9 : 0 6

2 THE COURT: Please state your full name.

3 THE DEFENDANT: James Milton Davis.

4 THE COURT: Your age?

5 THE DEFENDANT: Sixty.0 9 : 0 6

6 THE COURT: And your education?

7 THE DEFENDANT: Through college. Sixteen years.

8 THE COURT: Okay. Where did you go and what degrees?

9 THE DEFENDANT: Baylor University, and I received a

10 BBA degree.0 9 : 0 7

11 THE COURT: Okay. Have you ever been treated for any

12 mental illness or addiction to narcotic drugs?

13 THE DEFENDANT: No, sir, Your Honor.

14 THE COURT: Are you presently under the influence of

15 any drug, medication or alcoholic beverage of any kind?0 9 : 0 7

16 THE DEFENDANT: No, sir.

17 THE COURT: Have you had sufficient time to consult

18 with your attorney?

19 THE DEFENDANT: Yes, sir.

20 THE COURT: Are you satisfied with your attorney?0 9 : 0 7

21 THE DEFENDANT: Yes, sir.

22 THE COURT: Counsel, have you had sufficient time to

23 investigate the law and the facts of your client's case now

24 before the Court?

25 MR. FINN: Yes, Your Honor.0 9 : 0 7

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 THE COURT: Does he understand the nature of the0 9 : 0 7

2 charges pending against him?

3 MR. FINN: He does.

4 THE COURT: Has he been able to cooperate with you in

5 every respect?0 9 : 0 7

6 MR. FINN: Yes, sir.

7 THE COURT: In your opinion, is he now mentally

8 competent?

9 MR. FINN: He is, Your Honor.

10 THE COURT: Have you and your attorney received a copy0 9 : 0 7

11 of the information pending against you, that is the written

12 charges in this case?

13 THE DEFENDANT: Yes, sir, Your Honor.

14 THE COURT: All right. Has any waiver been done yet

15 of indictment in this case?0 9 : 0 7

16 MR. COSTA: Yes. It was done in front of Judge

17 Botley, Your Honor, at the initial --

18 THE COURT: Do we have a copy of that here? If not,

19 it was done and it was signed by Judge Botley?

20 MR. COSTA: Yes, Your Honor.0 9 : 0 8

21 THE COURT: Let me briefly mention to you: You know

22 you have an absolute right to be indicted by a grand jury for

23 any of the charges filed against you? Do you understand that?

24 THE DEFENDANT: Yes, sir, Your Honor.

25 THE COURT: All right. And by waiving the right to0 9 : 0 8

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 indictment, in effect, you are pleading to charges drawn up by0 9 : 0 8

2 the government, known as an information. It is not an

3 indictment, and you are hereby waiving your right to be

4 indicted by a grand jury and, in effect, proceed to trial

5 and/or this plea based upon the charges filed by the government0 9 : 0 8

6 that have not been, in effect, screened by a grand jury?

7 Do you understand that?

8 THE DEFENDANT: Yes, sir, Your Honor.

9 THE COURT: All right. Have you discussed this with

10 your counsel?0 9 : 0 8

11 THE DEFENDANT: Yes, sir, Your Honor.

12 THE COURT: All right. And I understand that you have

13 waived and already signed a waiver of your right to proceed to

14 a grand jury? Is that correct?

15 THE DEFENDANT: Yes, sir, Your Honor.0 9 : 0 8

16 THE COURT: Mr. Finn, let me just ask you, you are

17 counsel on this. I gather it is your understanding that he has

18 full knowledge of his waiver. Is that correct?

19 MR. FINN: Absolutely, Your Honor.

20 THE COURT: Okay. You are pleading today to Counts0 9 : 0 9

21 One, Two and Three of the information. Count One is a

22 violation of 18 United States Code, Section 371, conspiracy to

23 commit mail, wire and securities fraud. The basic elements are

24 the defendant and at least one other person made an agreement

25 to engage in mail, wire and securities fraud.0 9 : 0 9

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 The defendant knew the unlawful purpose of the0 9 : 0 9

2 agreement and joined in it willfully, that is, with the intent

3 to further the unlawful purpose and that one of the

4 conspirators during the existence of the conspiracy knowingly

5 committed at least one of the overt acts described in the0 9 : 0 9

6 indictment in order to accomplish some object or purpose of the

7 conspiracy.

8 Penalty is, for this statute, imprisonment for a

9 term not to exceed five years, a fine of up to $250,000 and

10 restitution of up to $7 billion.0 9 : 1 0

11 Count Two, a violation of 18 United States Code,

12 Section 1341, mail fraud. The basic elements are the defendant

13 knowingly engaged in a scheme to defraud investors who

14 purchased CDs from Stanford International Bank Limited. That

15 the defendant acted with a specific intent to defraud; that the0 9 : 1 0

16 defendant caused something to be mailed through the postal

17 service or a private interstate carrier for the purpose of

18 carrying out the scheme, and that the scheme to defraud

19 employed false, material representations.

20 Penalty for violation of this statute includes0 9 : 1 0

21 imprisonment for a term not to exceed 20 years, a fine of up

22 $250,000 and restitution again of up to $7 billion.

23 Count Three is a violation of 18 United States

24 Code, Section 371, conspiracy to obstruct an SEC proceeding.

25 SEC, of course, Securities and Exchange Commission.0 9 : 1 1

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 The basic elements are that the defendant and at0 9 : 1 1

2 least one other person made an agreement to obstruct a pending

3 SEC proceeding; that the defendant knew the unlawful purpose of

4 the agreement and joined in it willfully, that is, with intent

5 to further the unlawful purpose. And that one of the0 9 : 1 1

6 conspirators during the existence of the conspiracy knowingly

7 committed at least one of the overt acts described in the

8 indictment in order to accomplish some object or purpose of the

9 conspiracy.

10 Penalty on this count is imprisonment for a term0 9 : 1 1

11 not to exceed five years and a fine of up to $250,000.

12 You are also advised that upon any finding of

13 guilty, there will also be supervised release of up to a

14 maximum of three years, and you are further informed -- that

15 means after any imprisonment. And if the defendant violates0 9 : 1 2

16 the conditions of any period of supervised release, then you

17 are subject to an additional two years incarceration without

18 any time or credit being given for any successful time served

19 on supervised release prior to any violation.

20 There is also a special statutory assessment of0 9 : 1 2

21 $100 per count of conviction.

22 MR. COSTA: Your Honor, I just wanted to add one thing

23 to the penalties. On the fine, the alternative fine provision

24 may also apply, in which case the defendant would face a fine

25 of twice the amount of gain or loss arising from the offense.0 9 : 1 2

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1 THE COURT: Is that on each count?0 9 : 1 2

2 MR. COSTA: Certainly on Counts One and Two.

3 THE COURT: All right. With that addition, do you

4 understand this to be the nature of the charges and the

5 possible penalties pending against you?0 9 : 1 3

6 THE DEFENDANT: I do, Your Honor.

7 THE COURT: Do you understand you have a right to

8 continue to plead not guilty if you want to to any offense

9 charged against you and to persist in that plea?

10 THE DEFENDANT: I understand, Your Honor.0 9 : 1 3

11 THE COURT: If you had continued to plead not guilty,

12 you would have had the right to a trial by jury or before the

13 Court during which you would also have the right to the

14 assistance of counsel for your defense, the right to see and

15 hear all the witnesses and have them cross-examined in your0 9 : 1 3

16 defense, the right on your own part to decline to testify,

17 unless you voluntarily elected to do so in your own defense,

18 the right to the issuance of subpoenas or compulsory process to

19 compel the attendance of witnesses to testify in your defense.

20 At trial, the government would have to prove each0 9 : 1 3

21 element of the offense of which you were charged beyond a

22 reasonable doubt.

23 Do you further understand that by entering a plea

24 of guilty, if that plea is accepted by the Court, there will be

25 no trial and you will have waived or given up your right to a0 9 : 1 3

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 trial as well as those other rights associated with the trial0 9 : 1 4

2 as I just described them?

3 And do you also understand if I accept your plea

4 of guilty, you will be waiving any non-jurisdictional defects,

5 if any, in this prosecution, such as, for example, any illegal0 9 : 1 4

6 search and seizure, a violation of your right to a speedy trial

7 and an inadmissible statement, if you have made one? In other

8 words, if I accept your plea of guilty, you will not be able to

9 raise these defenses at a later time?

10 Do you understand by pleading guilty, you have0 9 : 1 4

11 waived all the rights I just described?

12 THE DEFENDANT: Yes, Your Honor.

13 THE COURT: Just for the record, I need to ask, are

14 you a citizen of the United States?

15 THE DEFENDANT: Yes, Your Honor.0 9 : 1 4

16 THE COURT: As such, do you understand that the

17 offenses to which you are pleading guilty are felony offenses,

18 and if your plea is accepted, you will be adjudged guilty of

19 that offense? And that such adjudication may deprive you of

20 such rights as the right to vote, the right to hold public0 9 : 1 4

21 office, the right to serve on a jury and the right to possess

22 any kind of a firearm? Do you understand these possible

23 consequences of your plea?

24 THE DEFENDANT: Yes, sir, Your Honor.

25 THE COURT: Has any plea agreement been entered into0 9 : 1 5

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 between the parties?0 9 : 1 5

2 MR. COSTA: Yes, Your Honor.

3 THE COURT: Initially, what does it state relative to

4 rights of appeal?

5 MR. COSTA: That the defendant waives his right to0 9 : 1 5

6 appeal the sentence, except for a sentence above the statutory

7 maximum, and the defendant waives his right to file any motion

8 for post conviction relief.

9 The government reserves its right to appeal the

10 sentence. And in the event the government appeals the0 9 : 1 5

11 sentence, then the defendant is no longer bound by his waiver.

12 THE COURT: All right. Under what section are we

13 proceeding? What rule of Federal Rules of Criminal Procedure?

14 11(c)(1) what?

15 MR. COSTA: B, Your Honor.0 9 : 1 5

16 THE COURT: B. Okay. Guidelines have been set for

17 judges to consider in determining the sentence in a criminal

18 case.

19 Have you and your attorney talked about how these

20 guidelines might apply to your case?0 9 : 1 5

21 THE DEFENDANT: Yes, sir, Your Honor.

22 THE COURT: Do you understand I will not be able to

23 determine the guideline sentence for your case until after a

24 presentence report has been completed and you and the

25 government have had an opportunity to challenge the facts0 9 : 1 6

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 reported by the probation officer?0 9 : 1 6

2 THE DEFENDANT: I understand, Your Honor.

3 THE COURT: Do you also understand after it has been

4 determined what guideline applies to a case, the judge has the

5 authority due to a recent -- well, relatively recent Supreme0 9 : 1 6

6 Court opinion to impose a sentence that is more severe or less

7 severe than the sentence called for by the guidelines?

8 THE DEFENDANT: Yes, sir, I understand.

9 THE COURT: Do you also understand that under some

10 circumstances you or the government may have the right to0 9 : 1 6

11 appeal any sentence that a court imposes except to the extent

12 that you have waived that right in your plea agreement? And my

13 understanding is you have waived all of those rights retaining

14 just those few, those one or two items that were just

15 mentioned. Do you understand that?0 9 : 1 6

16 THE DEFENDANT: Yes, sir, Your Honor.

17 THE COURT: Do you also understand here in the federal

18 system, as compared to the state system, here in the federal

19 system, parole has been abolished, and if you are sentenced to

20 the penitentiary, you would not be released on parole?0 9 : 1 7

21 THE DEFENDANT: Yes, sir, Your Honor.

22 THE COURT: All right. If you would, please state for

23 the record any additional terms of the plea agreement.

24 MR. COSTA: Your Honor, the defendant agrees to plead

25 guilty to Counts One, Two and Three. He agrees to cooperate0 9 : 1 7

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 with the government. The defendant agrees that the total0 9 : 1 7

2 adjusted --

3 THE COURT: When you say "agreement," does that

4 include testifying at any trials?

5 MR. COSTA: Yes, Your Honor.0 9 : 1 7

6 THE COURT: All right. Go on.

7 MR. COSTA: The defendant agrees that the total

8 adjusted offense level under the guidelines is 46.

9 THE COURT: Now, does he understand that that's

10 subject to the probation officer totaling it up? And then I0 9 : 1 7

11 mentioned the judge's discretion.

12 MR. COSTA: Yes. And the agreement says that that's

13 the party's recommendation, but that it is up to the Court, and

14 the probation office may make different recommendations.

15 He also agrees to the waivers of appeal we have0 9 : 1 7

16 already discussed. He agrees to enter into an agreed

17 forfeiture judgment in the amount of $1 billion.

18 Those are the general terms. There are others

19 detailed in the agreement.

20 In exchange, the United States agrees that he0 9 : 1 8

21 should get three points off for acceptance of responsibility,

22 if he persists in his plea agreement and in his cooperation

23 through the time of sentencing. And the government agrees that

24 the guideline level would result in an offense level of 46, and

25 the government reserves the option, at its sole discretion, to0 9 : 1 8

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 file a downward departure motion, if the defendant's0 9 : 1 8

2 cooperation rises to the level of substantial assistance.

3 THE COURT: Mr. Davis, are those the terms of the plea

4 agreement with the government, as you understand them?

5 THE DEFENDANT: I do, Your Honor.0 9 : 1 8

6 THE COURT: Has anyone made any other different

7 promise to you of any kind, such as possible leniency or an

8 offer of probation in order to induce you or to get you to

9 enter a plea of guilty in this case?

10 THE DEFENDANT: No, sir.0 9 : 1 8

11 THE COURT: Has anyone attempted in any way to

12 threaten, force or coerce you into pleading guilty?

13 THE DEFENDANT: No, sir.

14 THE COURT: The Court has considered your plea of

15 guilty under Federal Rule of Criminal Procedure 11(c)(1)(B).0 9 : 1 9

16 Do you understand I may accept or reject the plea

17 agreement as proposed to the Court?

18 THE DEFENDANT: Yes, sir, Your Honor.

19 THE COURT: Do you also understand if I accept your

20 plea of guilty today but reject the plea agreement that the0 9 : 1 9

21 parties have brought before the Court, you will nonetheless not

22 be permitted to withdraw your plea of guilty at a later date?

23 Also, do you understand that the government's

24 recommendation or your request for a particular sentence is not

25 binding on me and I'm free to assess any punishment within the0 9 : 1 9

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 limits prescribed by law as I described earlier?0 9 : 1 9

2 THE DEFENDANT: I do, Your Honor.

3 THE COURT: Are you now ready to enter a plea to the

4 three counts pending against you?

5 THE DEFENDANT: Yes, sir.0 9 : 1 9

6 THE COURT: Counsel, do you know of any reason why

7 your client should not plead guilty?

8 MR. FINN: No, sir.

9 THE COURT: Do you know of any meritorious defenses

10 that he would have to the three counts to which he intends to0 9 : 1 9

11 plead?

12 MR. FINN: No, Your Honor.

13 THE COURT: Before I can accept your plea of guilty, I

14 need to make a determination there's a factual basis for your

15 plea, that you are, in effect, guilty as charged. If you would0 9 : 2 0

16 listen to the Assistant U.S. Attorney now as he gives me a

17 brief summary of what his file shows, in effect the facts that

18 would be shown if this case had gone to trial.

19 MR. PELLETIER: Yes, Your Honor. Your Honor, as the

20 Court will soon be aware, in the plea agreement, there is a0 9 : 2 0

21 more exhaustive factual statement, but I will give the Court a

22 brief summary of the facts that we would show if this case had

23 gone to trial.

24 Essentially, Your Honor, the government would be

25 able to prove at trial that from at least 1999 through February0 9 : 2 0

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 of 2009, this defendant, along with several other named0 9 : 2 0

2 defendants --

3 THE COURT: That is 10 years, a 10-year span?

4 MR. PELLETIER: That is correct, Your Honor.

5 For 10 years, this defendant, along with0 9 : 2 0

6 Mr. Robert Allen Stanford, Ms. Laura Pendergest-Holt, LeRoy

7 King, Mark Kuhrt, Gilberto Lopez and other individuals who are

8 identified but not named in the information and in the factual

9 statement, which is attached to the plea, and others,

10 orchestrated a scheme whereby essentially investors were duped0 9 : 2 1

11 into investing more than $5 billion into their CD program at a

12 bank called Stanford International Bank, which was located in

13 Antigua, and these CD investments were advertised, Your Honor,

14 as safe and secure investments. In actuality, the evidence

15 will show that rather than being safe and secure, these0 9 : 2 1

16 investors were encouraged to invest in what was really a

17 massive Ponzi scheme ab initio.

18 As early as 1990, Mr. Davis, first as controller

19 and then ultimately as CFO of Stanford International Bank, at

20 the request of Allen Stanford, began entering false -- making0 9 : 2 1

21 false entries into the books and records of SIBL -- SIBL I will

22 refer to as Stanford International Bank -- reflecting false

23 revenues. These false revenues would then be booked in the

24 books of SIBL, and they would show false earnings and assets,

25 which would then be disclosed both on SIBL's annual reports and0 9 : 2 2

Mayra Malone, CSR, RMR, CRR 713.250.5787

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1 in filings with the bank regulator in Antigua.0 9 : 2 2

2 SIBL's base of operations, Your Honor, in the

3 United States was, in effect, in Houston, and it was a company

4 that was called -- it was sort of the parent company. It was

5 called Stanford Financial Group with offices here in Houston.0 9 : 2 2

6 And it is from that office that these disclosures would be --

7 these false disclosures would be manufactured, mailed to

8 investors. And sometimes investors would, in fact, mail

9 information, money and documents, either through mail or wire,

10 back to Stanford Financial Group or banks in and around0 9 : 2 2

11 Houston.

12 In addition to these false disclosures to

13 investors, Your Honor, what also the investors were never told

14 was that there was billions of dollars, more than $2 billion in

15 loans actually made to Robert Allen Stanford that were not0 9 : 2 3

16 disclosed to these investors.

17 They were also not disclosed that in the assets

18 of SIBL, there were a billion dollars -- allegedly billions of

19 dollars in real estate, which were actually billions of dollars

20 of just artificially inflated value to real estate which was0 9 : 2 3

21 worth less than $100 million.

22 What the investors also weren't told, Your Honor,

23 is that Robert Allen Stanford was directly paying the Antiguan

24 regulators, specifically LeRoy King, hundreds of thousands of

25 dollars in bribes so that they would not examine the books and0 9 : 2 3

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1 records of SIBL in Antigua.0 9 : 2 3

2 What the investors were also not told and what

3 Mr. Davis directly participated in was --

4 THE COURT: Slow down a little bit. The court

5 reporter needs to take it down. We have got plenty of time.0 9 : 2 4

6 Go on.

7 MR. PELLETIER: Thank you, Your Honor. Was that

8 rather than having an independent outside auditor actually

9 audit the books and records, as they told the investors they

10 would, what they did was they had a captive auditing company in0 9 : 2 4

11 Antigua, which was not independent at all. As a matter of

12 fact, they too were being paid hundreds of thousands of dollars

13 in bribes from a secret Swiss bank account, the number being

14 108731 at SocGen, in Switzerland, in which Mr. Davis had

15 personal signatory authority over and directed some of these0 9 : 2 4

16 bribe payments both to LeRoy King, the regulator, and to the

17 auditors, who were allegedly doing an independent audit of the

18 bank.

19 Your Honor, these CDs were, in fact, securities

20 as defined by the Securities and Exchange Commission and the0 9 : 2 4

21 Securities Exchange Act of 1934.

22 So in addition to this massive scheme whereby

23 investors were duped into investing with false disclosures,

24 over $5 billion which resulted in $7.2 billion in liabilities

25 at the end of the scheme of SIBL to investors, Mr. Davis, along0 9 : 2 5

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19

1 with his co-conspirators, embarked upon a scheme beginning in0 9 : 2 5

2 at least 2005 to obstruct an SEC proceeding and investigation

3 of SIBL and the CD program. And they did that in a number of

4 ways. One way they did it, Your Honor, is that when the SEC

5 would send confidential investigatory letters to the bank0 9 : 2 5

6 regulator in Antigua, that bank regulator specifically being

7 LeRoy King, he would share these confidential letters with

8 Mr. Stanford, with other co-conspirators at SIBL, including

9 Mr. Davis. And they would all get together. Sometimes

10 Mr. Davis would be a part of this group; sometimes he wouldn't.0 9 : 2 6

11 But they would all get together and create fabricated or false

12 letters attesting to the bona fides and the financial

13 bona fides of SIBL. And, in fact, those statements were false

14 to the FSRC -- excuse me -- to the SEC. The FSRC being the

15 bank regulator in Antigua that would eventually send these0 9 : 2 6

16 letters that were fabricated with the assistance of Mr. Davis

17 and Mr. Stanford and the rest of the co-conspirators. They

18 would send them back to the SEC in Dallas. Sometimes Mr. King

19 would fax these letters to Houston, and they would be discussed

20 there. And the fabricated or misleading or false responses0 9 : 2 6

21 would be put together, both in Houston and Antigua.

22 Ultimately, Your Honor, after a series of these

23 fabricated responses were sent to the SEC from Antigua and

24 Houston in 2005 and 2006 --

25 THE COURT: Slow down a little bit. You are speeding0 9 : 2 6

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20

1 up a little bit.0 9 : 2 7

2 MR. PELLETIER: I'm sorry. In 2005 and 2006, what

3 eventually happened was that in 2009, the SEC actually began

4 taking the testimony of several of the individuals at Stanford

5 International Bank and at Stanford Financial Group.0 9 : 2 7

6 Originally they subpoenaed Mr. Stanford and

7 Mr. Davis to be testifying, along with Laura Pendergest-Holt,

8 before the SEC proceeding in Dallas and Fort Worth. But what

9 Mr. Davis and what Mr. Stanford and Ms. Pendergest-Holt and

10 other people identified in the factual statement, what they did0 9 : 2 7

11 is they falsely convinced the SEC that Mr. Davis and

12 Mr. Stanford didn't know about the entire asset portfolio of

13 SIBL and that Ms. Laura Pendergest-Holt and the SIBL present

14 were the people who were in the best position to inform the SEC

15 as to the breadth and scope and details of the entire asset0 9 : 2 8

16 picture of SIBL.

17 Mr. Davis knew that wasn't true. Mr. Stanford

18 knew that wasn't true. The people who organized this for SIBL

19 all knew it wasn't true. And so what they did was they put up

20 Ms. Pendergest-Holt to testify before the SEC on February 10th.0 9 : 2 8

21 And at that proceeding on February 10th in Fort

22 Worth, Ms. Pendergest-Holt falsely informed the SEC that she

23 didn't know about the asset allocations in Tier III, which was

24 essentially the bulk of the assets in SIBL. And the reason why

25 she said that is because she didn't want to reveal the truth,0 9 : 2 8

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21

1 which was that the portfolio in Tier III was essentially a0 9 : 2 8

2 house of cards. And that there was essentially nothing behind

3 the purported $8.5 billion in assets that the SIBL was telling

4 people in 2009 that it had as assets.

5 So the be all, end all of that, Your Honor, is0 9 : 2 9

6 that in February of 2009, the whole Ponzi scheme collapsed, and

7 the investors learned at that point in time that their

8 investment had been essentially in a house of cards. And at

9 that point in time, Your Honor, the SEC brought a civil action.

10 And then I would suggest, Your Honor, the rest is history. The0 9 : 2 9

11 conspiracy essentially ended at that point in time.

12 That is a broadbrush of what the government would

13 prove, Your Honor, if it went to trial in this matter.

14 THE COURT: Thank you.

15 Mr. Davis, are these facts as recited by the0 9 : 2 9

16 Assistant U.S. Attorney true?

17 THE DEFENDANT: Yes, Your Honor.

18 THE COURT: Did you intend to commit the acts as he

19 just described?

20 THE DEFENDANT: Yes, Your Honor.0 9 : 2 9

21 THE COURT: Did you know what you were doing at the

22 time?

23 THE DEFENDANT: Yes, Your Honor.

24 THE COURT: All right. You may now arraign the

25 defendant as to the counts involved in the plea agreement,0 9 : 3 0

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22

1 unless you want to voluntarily waive reading of the indictment.0 9 : 3 0

2 MR. FINN: Your Honor, we will waive the reading of

3 the information.

4 THE COURT: Very well, sir. As to the three counts to

5 which you are pleading today, how do you plead? Guilty or not0 9 : 3 0

6 guilty?

7 THE DEFENDANT: Guilty, Your Honor.

8 THE COURT: Have you read and do you understand the

9 plea of guilty agreement?

10 THE DEFENDANT: Yes, Your Honor.0 9 : 3 0

11 THE COURT: Then you may go ahead and sign it at this

12 time.

13 (Compliance)

14 THE COURT: Let me ask the defendant as to the form --

15 very often locally we have a couple more sheets attached to it.0 9 : 3 1

16 Is that sufficient as far as you are concerned?

17 MR. COSTA: You mean the data sheet, Your Honor?

18 THE COURT: No. I'm talking about the signature

19 sheet.

20 MR. COSTA: Oh, yes. Because that has been0 9 : 3 1

21 incorporated.

22 THE COURT: It's been incorporated.

23 MR. COSTA: And there is also -- we would also submit

24 with that -- and it is incorporated in the plea agreement

25 filing -- there is a letter plea agreement, dated April 21st,0 9 : 3 1

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23

1 2009. And the plea agreement we just signed incorporates most0 9 : 3 1

2 of that, but we just also want to file this as an attachment.

3 THE COURT: You want it attached to the plea

4 agreement?

5 MR. COSTA: Yes, Your Honor. The plea agreement0 9 : 3 1

6 references that letter agreement.

7 THE COURT: All right then. I am talking to my staff.

8 It is now one document.

9 These are the Court's findings: I find the

10 defendant mentally competent at the present time. I find there0 9 : 3 2

11 is a factual basis for the plea of guilty and that the

12 defendant intended to do the acts he committed. I find the

13 defendant's plea of guilty is voluntarily and knowingly made

14 and that the defendant understands the nature of these

15 proceedings and understands the consequences of his plea of0 9 : 3 2

16 guilty.

17 Upon your plea of guilty, I find you guilty as

18 charged in Counts One, Two and Three, and I will consider the

19 party's plea agreement before the imposition of sentence.

20 A written presentence report will be prepared by0 9 : 3 2

21 the probation office to assist me in sentencing and a written

22 -- you will be required to give information for the report and

23 your attorney may be present if you wish.

24 The Court will permit you and your attorney to

25 read the presentence report before the sentencing hearing, and0 9 : 3 2

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24

1 at the sentencing hearing, you and your counsel will be given0 9 : 3 2

2 the opportunity to speak on your behalf at that time.

3 The sentencing date, the defendant is ordered to

4 be back before this Court for sentencing on November 20, 2009,

5 at 10:00 a.m.0 9 : 3 3

6 I imagine this date is subject to being set off.

7 It depends upon how this case proceeds. Is that correct?

8 MR. COSTA: Yes, Your Honor, and the plea agreement

9 says the defendant agrees to continue sentencing as long as his

10 cooperation is on-going.0 9 : 3 3

11 THE COURT: All right. What is the bond status on

12 Mr. Davis?

13 MR. PELLETIER: The current bond status is that

14 Mr. Davis is presently on bond.

15 THE COURT: How much is the bond, please?0 9 : 3 3

16 MR. PELLETIER: Half a million. And I think there are

17 co-signers, as well.

18 MR. FINN: Yes, Your Honor. And I believe we also put

19 up, was it, 10,000, 5,000 cash? 5,000 cash and half a million

20 in sureties.0 9 : 3 3

21 THE COURT: All right. What is the government's

22 position on him remaining free on bond pending sentencing in

23 this case?

24 MR. PELLETIER: Your Honor, the defendant at this

25 point in time has met all the conditions of bond. He has0 9 : 3 3

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25

1 traveled to this district to assist in the securing and0 9 : 3 3

2 location of assets.

3 THE COURT: Where is he residing at the present time?

4 MR. PELLETIER: He is presently residing in Michigan.

5 And whenever we have called him to either participate in a0 9 : 3 4

6 debriefing or to help us find and secure assets, he has

7 attended. I believe, Your Honor, that the current bond status

8 is sufficient for the United States, and we would be happy to

9 agree to continue the current bond status at this time.

10 THE COURT: Mr. Finn, your position?0 9 : 3 4

11 MR. FINN: I will join Mr. Pelletier, Your Honor. He

12 will show up. He has shown up for everything. He has been

13 extremely accessible to the government, and I might add, I

14 think they also have his passport.

15 MR. PELLETIER: We do, Your Honor. Pretrial Services0 9 : 3 4

16 does.

17 THE COURT: Very well then. I will continue him on

18 the same elements of pretrial release. Then, Counsel, you need

19 to stop past the probation department on the way out to start

20 some processing, and you will get part of the paperwork today.0 9 : 3 4

21 MR. FINN: Thank you, Your Honor.

22 THE COURT: Is there anything further from the

23 government?

24 MR. COSTA: Two issues, Your Honor. One, we would

25 like to submit an agreed preliminary order of forfeiture for a0 9 : 3 5

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26

1 money judgment of a billion dollars that Mr. Davis has agreed0 9 : 3 5

2 to in the plea agreement.

3 THE COURT: Any objection, Counsel?

4 MR. FINN: No, Your Honor. No objection.

5 THE COURT: Very well.0 9 : 3 5

6 MR. COSTA: And the second issue --

7 THE COURT: Hang on. Let me just sign it and get it

8 off my desk.

9 Yes, sir?

10 MR. COSTA: The second issue is just for the record.0 9 : 3 5

11 I wanted to point out that the government submitted a number of

12 letters from victims who wanted to comment on Mr. Davis's case.

13 Those are submitted to the Court, and I assume the Court has

14 seen those. And it's my understanding that the Court has

15 decided that it will consider at sentencing the procedures for0 9 : 3 5

16 some victims to speak in court but that that is not necessary

17 here.

18 THE COURT: Thank you for reminding me. I have -- you

19 know, I have read the statements that were sent in. Some were

20 sent, in fact, directly to my chambers, and I elect not to have0 9 : 3 5

21 a hearing at this time but certainly at the time of sentencing,

22 there will be some provisions for folks that have a desire to

23 speak, at least for some of them to speak at that time. Thank

24 you for reminding me on that.

25 Anything further from the government in this0 9 : 3 6

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27

1 matter?0 9 : 3 6

2 MR. COSTA: No, Your Honor.

3 THE COURT: Anything further from the defense in this

4 matter?

5 MR. FINN: No, sir.0 9 : 3 6

6 THE COURT: I have got a couple things I need to read

7 before you leave, so if you want to just have a seat and

8 Mr. Davis can be seated where he was. This shouldn't take too

9 much time.

10 I have a couple other matters that were set0 9 : 3 6

11 today. I'm going to get to one matter that has not -- that is

12 not set today that at least I want to mention.

13 I will consider the matter of the nonpayment of

14 attorneys' fees by insurance carriers once all briefing by

15 counsel for all interested parties is submitted. There has0 9 : 3 6

16 been a request for other parties to submit some writings on

17 that, and I want to consider that before I decide what, if

18 anything, to do.

19 Additionally, at 5:30 a.m. this morning,

20 Mr. Stanford was found to have an irregular electrocardiogram0 9 : 3 6

21 and extremely high pulse readings. He was taken by ambulance

22 to the Conroe Regional Medical Facility. So, therefore, the

23 hearing regarding his attorney representation will have to be

24 reset, and I will reset that as soon as possible, and that's

25 all I have to visit with you today, and we stand adjourned.0 9 : 3 7

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28

1 MR. COSTA: Thank you, Your Honor.0 9 : 3 7

2 (Proceedings concluded at 9:37 a.m.)

3 * * * *

4 I certify that the foregoing is a correct transcript from the record of proceedings in the above-entitled cause.

5 Date: August 31, 2009

6

7 /s/ Mayra Malone, CSR, RMR, CRR

8 Official Court Reporter

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

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EXHIBIT 3

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LIA refutes Stanford claims By Stacey-Marie Ishmael and Brooke Masters Published: July 15 2009 03:00 | Last updated: July 15 2009 03:00 The Libyan Investment Authority has disputed claims made by Sir Allen Stanford's defence team that it invested at least $500m with the Texas billionaire accused by US prosecutors of running a $7bn Ponzi scheme. Sir Allen's girlfriend Andrea Stoelker described the purported investment in a sworn statement filed in the criminal case last week. But the LIA wrote in a letter to the Financial Times yesterday, that while top Libyan officials met with Sir Allen, his investment "proposals failed to meet the LIA's investment criteria and they were rejected". Sir Allen's attorney did not respond to a request for comment. Brooke Masters in London and Stacy-Marie Ishmael in New York Copyright The Financial Times Limited 2011.

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EXHIBIT 6

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10TRIPOLI79: TECHNOLOGY TO

TOURISM: HEAD OF INVESTMENT

AUTHORITY DISCUSSES

OPPORTUNITIES FOR U.S. BUSINESS IN LIBYA

This is not the original Wikileaks document! It's a cache, made on 2011-02-01 02:14:11. For the original

document check the original source: http://213.251.145.96/cable/2010/01/10TRIPOLI79.html

0

< Search index

ID 10TRIPOLI79

SUBJECT TECHNOLOGY TO TOURISM: HEAD OF INVESTMENT AUTHORITY DISCUSSES OPPORTUNITIES FOR U.S. BUSINESS IN LIBYA

DATE 2010-01-28 15:03:00

CLASSIFICATION CONFIDENTIAL

ORIGIN Embassy Tripoli

TEXT C O N F I D E N T I A L SECTION 01 OF 02 TRIPOLI 0000 79 SIPDIS STATE FOR NEA/MAG, COMMERCE FOR NATE MASON E.O. 12958: DECL: 1/26/2020 TAGS: CVIS PREL ECON EFIN ECIN EINV EIND ETRD ETTC LY SUBJECT: TECHNOLOGY TO TOURISM: HEAD OF INVESTMENT AUTHORITY DISCUSSES OPPORTUNITIES FOR U.S. BUSINESS IN LIBYA CLASSIFIED BY: Gene A. Cretz, Ambassador, U.S. Embassy Tripoli, Department of State. REASON: 1.4 (b), (d) 1.(C) Summary. During a January 20 meeting with the Ambassador, Mohamed Layas, the Head of the Libyan Investment Authority (LIA, Libya's sovereign wealth fund), welcomed the February 20-23 Department of Commerce-led Trade Mission and highlighted ways that U.S. businesses could thrive in Libya, particularly in the tourism and health services sectors. The Ambassador underlined the need for the Libyan government to eliminate the "visa freeze" for official Americans and to improve the visa process for other Americans, including allowing American tourists to enter Libya. Layas asserted that the LIA has USD 32 billion in liquidity, and noted that several American banks are each managing USD 300-500 million of the LIA's funds. End Summary. HOW U.S. BUSINESS CAN THRIVE IN LIBYA: TECHNOLOGY TO TOURISM 2.(C) During a January 20 meeting in his prime office-space overlooking the Mediterranean Sea, Layas discussed with the Ambassador (accompanied by the FCS officer and P/E chief) the

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many ways in which U.S. businesses could thrive in Libya, through investment, trade, and joint ventures. He welcomed the February 20- 23 Department of Commerce Trade Mission and offered his thoughts on how to make the program a success -- "The best thing to do is to meet the right people here. You should have 2-3 ministers address the whole group." He explained that the LIA was very interested in attracting more U.S. business to Libya and believed the U.S. could play a "major role" in Libya's development. During a recent visit to Washington, Layas met with a number of American company representatives, as well as the Export-Import Bank (EXIM), to educate them on opportunities to invest in the "unique [Libyan] market," which according to him, unfortunately includes bureaucratic "red tape and corruption." Some of the advantages that Layas saw the U.S. having over European competitors for contracts in Libya are the weakness of the dollar compared to the Euro, as well as U.S. access to more advanced technology. Layas believes U.S. companies can expand on their success in Libya's hydrocarbon market by competing for contracts in the electricity market, health services, and tourism. 3.(C) Layas was particularly interested in importation of advanced U.S. medical technology, outlining plans to create a large medical center in Tripoli. He sees opportunities for U.S. firms to enter into joint ventures with Libyan companies to develop such plans. Additionally, he noted that the LIA plans to manage a large tourism development plan, which will involve USD 1 billion projects in Western Libya, Eastern Libya, the Green Mountains, and potentially another city (most likely Tripoli). Layas believes more than half of Libya's projected USD 136 billion development plan budget has been committed in contracts, but implied that some companies may back out of those contracts, as they were "reconsidering the conditions." Layas asked the Ambassador to pass on the message that Libya was still open to development by U.S. companies and that Libya wants to establish "lasting relationships" with major U.S. firms. IMPROVING BILATERAL RELATIONS THROUGH VISAS 4.(C) The Ambassador attested to the interest of Americans -- businesspeople, government officials, and tourists -- in coming to Libya, but underlined the obstacles that Americans face when trying to obtain visas. The current "visa freeze" for official Americans was only the latest in a number of difficulties that Americans faced. The Ambassador highlighted the imbalance in our governments' approaches to the relationship -- whereas the Embassy provided full consular services and had issued over 3,000 visas to Libyans since opening in April 2009, U.S. tourists still could not visit Libya. The situation is affecting Embassy operations, including planning for the Trade Mission, and needs to be addressed. Layas sympathetically commented that he had also faced problems recently in trying to obtain visa approvals for a number of American businessmen that had been invited to visit Libya for business discussions.

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LIA'S INVESTMENTS: WEATHERING THE STORM 5.(C) The Ambassador stressed the U.S. commitment to the bilateral relationship, including in trade and investment. He inquired about the state of the Libyan economy and the LIA's wealth in particular, given fallen oil prices and the recent world economic crisis. Layas informed the Ambassador that Libya had "weathered the storm" of the economic crisis. He noted that the LIA operated with "high liquidity," and therefore was not concerned about the volatility of the oil market. "We have USD TRIPOLI 00000079 002 OF 002 32 billion in liquidity," he stated, "mostly in bank deposits that will give us good long-term returns." He explained that several American banks are each managing USD 300-500 million of LIA's funds, and opined that the LIA was entangled in a legal disagreement with Lehman Brother's due to a major investment that was "mismanaged." He said that the LIA has an office in London and preferred doing business there rather than in the United States, due to the "ease of doing business" in the UK and relatively "uncomplicated tax system." He noted that the LIA's primary investments are in London, in banking and residential and commercial real estate. 6.(C) Layas denied press reports that the LIA had invested USD 100 million with the infamous Allen Stanford. He said that he had personally written a letter to the "Financial Times" disputing the information, explaining that Stanford had approached the LIA in the middle of his crisis, offering a 7- 8% share in his investment scheme, but Layas had refused. Layas also mentioned having been previously approached by Bernard Madoff about an investment opportunity, "but we did not accept." On the contrary, LIA's recent purchase of the Canadian Verenex oil company -- after much controversy over the manner in which it was purchased and share price -- was considered by Layas a "good deal." LIA plans to operate Verenex jointly with the Libyan Investment and Development Corporation (LIDCO). 7.(C) Comment: The LIA controls at least seven subsidiary organizations, and a fund that holds USD 32 billion in liquid assets. The fact that Layas weathered his own storm -- LIA's controversial, reported entanglement with Allen Stanford -- in a regime that has proven to be unforgiving in the face of embarrassment, is surprising, and indicative of his strong ties to powerful protectors within the Libyan regime. End comment. CRETZ 0 01/28/2010 6969 CVIS,PREL,ECON,EFIN,ECIN,EINV,EIND,ETRD,ETTC,LY TECHNOLOGY TO TOURISM: HEAD OF INVESTMENT AUTHORITY DISCUSSES OPPORTUNITIES FOR U.S. BUSINESS IN LIBYA During a January 20 meeting with the Ambassador, Mohamed Layas, the Head of the Libyan Investment Authority (LIA, Libya's sovereign wealth fund), welcomed the February 20-23 Department of Commerce-led Trade Mission and highlighted ways that U.S. businesses could thrive in Libya, particularly in the tourism and health services sectors. The Ambassador underlined the need for the Libyan government to eliminate the "visa freeze" for official Americans and to

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improve the visa process for other Americans, including allowing American tourists to enter Libya. Layas asserted that the LIA has USD 32 billion in liquidity, and noted that several American banks are each managing USD 300-500 million of the LIA's funds. End Summary.

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EXHIBIT 7

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New fund deployed by Libya

Financial Times 18-Oct-2007 By Roula Khalaf in Tripoli Middle East Editor

A new Libyan sovereign wealth fund is starting to deploy its $40bn (£19bn, €28bn) capital on international markets as the oil-rich state showcases its rehabilitation in the global community.

Following in the footsteps of the Gulf countries, the regime of Colonel Muammer Gadaffi earlier this year allocated tens of billions of dollars that had been managed by the central bank to a new entity, the Libyan Investment Authority, which will now also receive a portion of the surplus oil revenues each year.

Although the ramshackle Libyan economy is in need of huge investment after decades of isolation, the government's strategy is to reduce the country's oil dependence and diversify sources of income.

"Because of sanctions our policy used to be to protect our assets and keep our funds in short-term deposits," said Mohamed Layas, the LIA's executive director, in an interview with the Financial Times. "After the embargo was lifted, it was a new era, a new opening, and we had a tremendous increase in oil revenues over the last five years."

Mr Layas said the fund, which will have offices in London and Tripoli, would concentrate at first on portfolio investments managed through western banks and institutions. But it also intends to buy real estate worldwide and, when it is more established, look at private equity transactions.

"If we buy shares in a construction company abroad, for example, the other benefit is that we will generate business for them in Libya, where we have a huge development plan," he said.

Although not its primary target, the LIA is considering investing in hydrocarbon development projects. It was a small partner in the $900m exploration contract BP signed with Tripoli in May. Still largely under-explored, Libya is hoping to increase its oil production from 1.7m to 3m barrels per day by 2015. Its oil revenues are expected to reach $15bn this year.

The LIA has set up a $2bn investment fund with its counterpart in Qatar to invest in Libya, Qatar and western markets. It has taken on three existing entities: the $5bn Libyan African investment portfolio; Lafico, a $3bn assets investment company mainly involved in real estate; and an $8bn existing portfolio of other international investments, largely in capital markets.

The creation of the LIA highlights the transformation of Tripoli from pariah state to international partner since its decision in 1999 to hand over suspects in the 1988 Lockerbie bombing in Scotland, and later to renounce its weapons of mass destruction.

On Tuesday, Tripoli secured a non-permanent seat on the United Nations Security Council - the body that lifted sanctions against it in 2003.

"If you wanted to invest in the past, no one would take your calls. Now bankers fly on their private jets to see us," said Mr Layas.

Industries: Monetary Authorities - Central Bank; Finance & Insurance; Countries: Libya; FT.com Copyright The Financial Times Ltd. All rights reserved.

Page 1 of 1InfoViewer: New fund deployed by Libya

6/9/2011http://us.ft.com/ftgateway/superpage.ft?news_id=fto101820070919549088

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Enter keywords... Tag Archives: Mohamed Layas

Libya Wealth Fund To Disclose Details On Invest – Fund Head

11. Jan, 2009

The State-run Libyan Investment Authority will disclose details about its investment strategy in coming months to allay concerns in the U.S. and

Page 1 of 4Mohamed Layas | Sovereign Wealth Fund Institute

6/9/2011http://www.swfinstitute.org/tag/mohamed-layas/

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European about its intentions, the fund’s Executive Director Mohamed Layas said Sunday. The Libyan state investment vehicle, or sovereign wealth fund, will also open a London office this year after months of consideration and is eyeing investments in some distressed banking and real estate assets in the U.S. and Europe, Layas said, declining to provide specifics.

“We will soon publish a report soon about our investments and intentions. We will show our purpose to be transparent and that we are a long-term investor,” Layas told Dow Jones Newswires in an interview by telephone from the Libyan capital, Tripoli. He declined to provide any details about what type of investment principles the LIA will commit to and said the report could be disclosed before spring. By laying out its investment philosophy in some form, the LIA wants to assure lawmakers in foreign countries its intentions are purely commercial and not for political advantage, said Layas, a former chairman of the Libyan Arab Foreign Bank.

“Any deals we pursue will be about commerce only,” he said. The LIA currently has about $70 billion on hand to deploy, Layas said, up from around $40 billion when the fund was launched in late 2007 with the aim of investing big chunks of the North African oil-rich nation’s growing cash pile from record crude prices into overseas assets. Government-controlled investment funds have snapped up foreign companies in recent years, sparking calls in the U.S. and Europe for more transparency about the funds’ purposes.

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Page 2 of 4Mohamed Layas | Sovereign Wealth Fund Institute

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Libya eyes more property in westBy Heba Saleh in TripoliPublished: March 18 2009 02:00 | Last updated: March 18 2009 02:00

Libya's $70bn sovereign wealth fund is on the lookout for investments in western real estate markets, as Muammer Gaddafi's regime flexes its financial muscle after emerging from its international isolation.

Unlike many Middle Eastern funds, which are sitting on substantial losses, the Libya Investment Authority was set up only in 2007 and is scouring the globe for opportunities in the downturn.

In an interview with the Financial Times in Tripoli, Mohamed Layas, the LIA's chief executive officer, said that after buying, through an affiliate, an office block in London, the fund was looking for more investments in property.

"The strategy is that we have to increase our investment in real estate, mainly in commercial buildings, and to invest in portfolios where they concentrate mainly on real estate in different parts of the world, in Europe and the US," he said.

"We received many offers that are under consideration."

Mr Layas said most of the fund's capital was still in cash and that it was set to receive a fresh allocation this year from the government, despite the sharp drop in oil prices, the country's main source of revenue.

"Almost 75 per cent of our assets are still liquid, which is a unique position compared to similar institutions," he said.

"We want to benefit from the situation of the market today. It is a very good opportunity for us to look for good investments which we can buy in Europe, in the United States and in other markets."

The LIA is steering clear of investments in the financial sector and seeking instead safer opportunities in real estate, services and utilities.

Private equity firms and other western investors have taken notice and have been knocking on the LIA's door.

While he would not talk specifically about foreign partners, Mr Layas said the LIA was mandating banks in Europe and the US to run its portfolio investments until it builds up the expertise to do so on its own. "We are not ready here to run the show locally," he said. "We are building the institution. We are sending people for training. We hire experts from abroad and we seek advice from consultants."

He said the LIA and the Qatar Investment Authority had already set up a joint $2bn (€1.5bn, £1.4bn) fund that was about to start investing both internationally and within the two countries.

According to Mr Layas, the LIA also has a $5bn Africa portfolio which has been investing in real estate, hotels, agriculture, mining and communications in different countries around the continent. Another $8bn of the fund's assets is specifically earmarked for long-term investments.

Beyond portfolio investment, the fund, according to Mr Layas, will consider direct investment in companies, including entering into joint ventures in Libya with foreign partners. The LIA is already developing oilfields with BP and National Oil Corporation, the national oil company. It has also worked in partnership with Norway's Yara in a fertilizer plant venture.

Copyright The Financial Times Limited 2011. Print a single copy of this article for personal use. Contact us if you wish to print more to distribute to others.

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F MIDDLE EAST & NORTH AFRICA

Page 1 of 1FT.com print article

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Bloomberg

Libyan Investment Authority Is Said to Boost UniCredit StakeSeptember 17, 2010, 10:33 AM EDT

By Sonia Sirletti

Sept. 17 (Bloomberg) --UniCredit SpA investor Libyan Investment Authority boosted its stake in Italy’s biggest bank since July and told the country’s stock

market regulator that it’s a separate entity from the Central Bank of Libya, according to two people with knowledge of the matter.

The Libyan sovereign wealth fund informed Italy’s Consob in a letter that it purchased an additional 0.5 percent stake in the Milan-based lender, raising its

holding to 2.6 percent, said the people, who asked not to be identified because the letter is confidential.

The Libyan Investment Authority, responding to requests from Italian regulators to clarify its position, also said it’s acting independently from the Central Bank

of Libya, the people said. The central bank owns almost 5 percent of UniCredit, making it one of the top three investors in the bank.

The recent Libyan investments in UniCredit have triggered opposition from some members of Prime Minister Silvio Berlusconi’s government, and raised legal

questions about whether the investors acted independently. UniCredit’s bylaws restrict investor voting rights to 5 percent.

Libyan investors chose “autonomously” to buy the stakes in UniCredit, Chief Executive Officer Alessandro Profumo told reporters in Milan Sept. 6. The bank is

strengthening its ties to Libya as Berlusconi fosters trade relations with the country, led by Muammar Qaddafi. The Central Bank of Libya last month assigned

a banking license to UniCredit, which became the first foreign bank allowed to operate in the country.

Independent Investors

A UniCredit official declined to comment, while a spokesman for the Libyan Investment Authority in Tripoli wasn’t immediately available for a comment. The 0.5

percent purchase by the Libyan Investment Authority was reported earlier today by financial daily Il Sole 24 Ore.

Consob and the Bank of Italy asked the two Libyan investors to prove that they are independent entities after the Libyan sovereign wealth fund bought a 2.1

percent stake in UniCredit in July.

A Consob official confirmed today that it received a letter from the Libyan Investment Authority fund concerning its stake in UniCredit, though he declined to

disclose the contents.

UniCredit’s board meets Sept. 30 to discuss the matter and send a response to the Italian regulators.

--With assistance from Alaa Shahine in Cairo, Alessandra Migliaccio in Rome. Editors: Dan Liefgreen, Frank Connelly

To contact the reporters on this story: Sonia Sirletti in Milan at [email protected] To contact the reporters on this story:

To contact the editor responsible for this story: Frank Connelly at [email protected]

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©2011 BLOOMBERG L.P. ALL RIGHTS RESERVED.

Wednesday March 9, 2011

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NewsBritain freezes colonel's millionsJon Ungoed-Thomas.408 words27 February 2011The Sunday TimesST13English© 2011 Times Newspapers Ltd. All rights reserved

Colonel Muammar Gadaffi has channelled hundreds of millions of pounds into London that are now set to be frozen as his regime totters, writes Jon Ungoed-Thomas.

Investments include a flagship hotel set to open later this year, a hedge fund in Knightsbridge and prime commercial properties.

America and Switzerland have already issued orders freezing Gadaffi's assets. An asset freezing unit at the Treasury is identifying investments in London.

The main investment vehicle for Gadaffi's state funds is the Libyan Investment Authority (LIA), which has offices in Mayfair. It has been reported to have more than £50 billion in assets around theworld.

Mohamed Layas, head of the LIA, was revealed in a cable released by WikiLeaks to have told American diplomats last year that it favoured London because of the "ease of doing business" and relatively"uncomplicated tax system".

In 2009, the LIA invested hundreds of millions of pounds in a hedge fund, FM Capital, staffed by former bankers from Goldman Sachs, Morgan Stanley and JP Morgan. The fund has also been trainingLibyans in dealing with investments.

One of Libya's highest profile investments is the former Metropole hotel, near Trafalgar Square. The Libyan Foreign Investment Company, a subsidiary of the LIA, is part of a consortium that paid £130mfor the building in February 2008.

The hotel, which has been renamed the Corinthia, will include 47 luxurious suites, including the capital's largest royal suite. It is due to open in April.

Other properties owned by the LIA include Portman House, a retail complex in Oxford Street. It was sold by Land Securities in 2009 for £155m. The authority also owns an office block opposite the Bank ofEngland.

The LIA has a wide range of investments. Its portfolio includes a stake in Pearson, owner of the Financial Times.

President Barack Obama announced on Friday that America was freezing the assets of the Gadaffi regime, including those of the Central Bank of Libya. Switzerland has blocked the sale or transfer of anyassets linked to the Gadaffi family.

The British government has not yet announced any action against Libyan assets, but is likely to move once it has established that all Britons in the country have been safely evacuated.

The biggest tranche of Gadaffi's assets may be in Italy because of the close relationship he has with Silvio Berlusconi, the Italian prime minister.

Document ST00000020110227e72r000rb

Factiva http://global.factiva.com/aa/default.aspx?pp=Print&hc=Publication

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EXHIBIT 8

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SEC Investigating Stanford Group Offshore-Bank CDs (Update1) By Alison Fitzgerald - July 3, 2008 16:49 EDT

July 3 (Bloomberg) -- The U.S. Securities and Exchange Commission is investigating sales of certificates of deposit by Stanford Group Company at its offshore bank, which has $6 billion in assets in Antigua.

The SEC issued subpoenas yesterday to two former Stanford Group employees asking for information about the CD sales by its offshore bank, Stanford International Bank Ltd. The subpoenas also demanded sales-training materials for the CDs and so-called mutual fund wrap programs, which are portfolios of diversified mutual funds. Houston-based Stanford Group is owned by billionaire R. Allen Stanford. Its companies have more than $43 billion under management or advisement, according to its Web site.

The subpoenas were provided to Bloomberg News by Mike O'Brien, the Houston-based attorney for two former employees, Charles Rawl and Mark Tidwell. They are both suing Stanford Group, accusing the company of forcing them to resign because they did not want to participate in illegal activities that they say Stanford Group was requiring them to carry out.

Stanford Group spokeswoman Lula Rodriguez said the company is ``not aware of any formal actions by the SEC related to either Mr. Tidwell or Mr. Rawl or connected to any of our clients.''

Rodriguez said the allegations ``have been made by disgruntled employees and are totally without merit.''

SEC spokesman John Nester said the agency does not confirm or deny the existence of an investigation. Rawl and Tidwell were both investment advisers for Stanford Group in Houston.

`Leave That Place'

``All we wanted to do was leave that place, get out of there and get our clients out safe and sound,'' Rawl said in an interview.

In the lawsuit, Rawl and Tidwell claim that the company failed to file forms to the U.S. Treasury Department disclosing its clients' offshore holdings and did not advise its clients to file those forms.

The lawsuit also alleges that Stanford Group purged files and destroyed documents as early as last year related to what Tidwell and Rawl claim is an ongoing SEC investigation regarding the CD sales practices. The lawsuit alleges that the company gave clients false historical performance data for its securities.

In court papers, Stanford Group said it had fired Tidwell and Rawl and that the two owe the company repayment of loans made to them.

Rawl said he owes Stanford Group $579,441. He said the company paid him a bonus upon his hiring in 2005 that would vest over time and that he was required to pay back when he left the company early. Tidwell owes the company $155,598, according to court papers filed by Stanford Group.

R. Allen Stanford was ranked the 605th-richest person in the world by Forbes Magazine this year, with an estimated net worth of $2.0 billion. The Texas native holds dual citizenship after becoming a citizen of Antigua in 1999. Stanford International Bank had $6 billion in assets as of July, 2007, according to its Web site.

To contact the reporter on this story: Alison Fitzgerald in Washington at [email protected]

To contact the editor responsible for this story: Michael [email protected]

Page 3 of 6SEC Investigating Stanford Group Offshore-Bank CDs (Update1) - Bloomberg##

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EXHIBIT 9

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1

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF TEXAS

DALLAS DIVISION

RALPH S. JANVEY, IN HIS CAPACITY AS

COURT-APPOINTED RECEIVER FOR THE

STANFORD INTERNATIONAL BANK, LTD.,

ET AL.,

Plaintiff,

v.

LIBYAN INVESTMENT AUTHORITY and

LIBYAN FOREIGN INVESTMENT COMPANY,

Defendants.

§

§

§

§

§

§

§

§

§

§

§

§

§

Case No. 3:11-CV-1177-N

________________________________________________________________________

DECLARATION OF

KARYL VAN TASSEL

________________________________________________________________________

I, Karyl Van Tassel of 31 Old Windsor Way, Sugar Land, Texas, 77479 state

under penalty of perjury as follows:

1. Effective September 30, 2011, I have accepted a new job position at

PricewaterhouseCoopers LLP.

2. Prior to this date, I was employed by FTI Consulting, Inc. The statements made

in this declaration are true and correct based on the knowledge I have gained from the work my

team and I have performed in the course of FTI’s investigation on behalf of the Receiver.

3. The documents attached to this declaration are true and correct copies of

documents that FTI collected from Stanford’s e-mail systems or computer hard drives in the

course of its investigation on behalf of the Receiver.

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2

Executed this 14th day of October 2011.

Karyl Van Tassel

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Exhibit KVT-1 to Declaration of Karyl Van Tassel

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From:                                         Ventrice, Ed [[email protected]]

Sent:                                           Monday, July 14, 2008 5:30 PM

To:                                               Chaisson, Scott S.

Cc:                                               Green, Jason

Subject:                                     Fw: Wall st journal in beginning of july

Scott what's the deal with this, is this place a ticking time bomb?

Ed Ventrice CPA, CFP, CIMA, PFS

Managing Director

Stanford Group Company

561-350-4602 Mobile

----- Original Message -----

From: Bohs, Brenda

To: Bober, Michael

Cc: MacDonald, Michael; Ventrice, Ed

Sent: Mon Jul 14 11:00:51 2008

Subject: RE: Wall st journal in beginning of july

Hi:

I had Derik check Bloomberg and this is all he found:

By Alison Fitzgerald

July 3 (Bloomberg) -- The U.S. Securities and Exchange Commission is investigating sales of

certificates of deposit by Stanford Group Company in its affiliated Antigua-based offshore bank.

The SEC issued subpoenas yesterday to two former Stanford Group employees asking for

information about the CD sales by its offshore bank, Stanford International Bank Ltd. The subpoenas

also demanded sales-training materials for the CDs and so-called mutual fund wrap programs, which

are portfolios of diversified mutual funds. The companies are owned by billionaire R. Allen

Stanford.

The subpoenas were provided to Bloomberg News by Mike O'Brien, the Houston-based attorney for

two former employees, Charles Rawl and Mark Tidwell. They are both suing Houston-based Stanford

Group, accusing the company of forcing them to resign because they did not want to participate in

illegal activities that they say Stanford Group was requiring them to carry out.

Stanford Group spokeswoman Lula Rodriguez said the company is ``not aware of any formal actions

by the SEC related to either Mr. Tidwell or Mr. Rawl or connected to any of our clients.''

Rodriguez said the allegations ``have been made by disgruntled employees and are totally

without merit.''

SEC spokesman John Nester said the agency does not confirm or deny the existence of an

investigation. Rawl and Tidwell were both investment advisers for Stanford Group in Houston.

`Leave That Place'

``All we wanted to do was leave that place, get out of there and get our clients out safe and

sound,'' Rawl said in an interview.

In the lawsuit, Rawl and Tidwell claim that the company failed to file forms to the U.S.

Treasury Department disclosing its clients' offshore holdings and did not advise its clients to

file those forms.

The lawsuit also alleges that Stanford Group purged files and destroyed documents as early as

last year related to what Tidwell and Rawl claim is an ongoing SEC investigation regarding the CD

sales practices. The lawsuit alleges that the company gave clients false historical performance

data for its securities.

In court papers, Stanford Group said it had fired Tidwell and Rawl and that the two owe the

company repayment of loans made to them.

Rawl said he owes Stanford Group $579,441. He said the company paid him a bonus upon his hiring

in 2005 that would vest over time and that he was required to pay back when he left the company

early. Tidwell owes the company $155,598, according to court papers filed by Stanford Group.

R. Allen Stanford was ranked the 605th-richest person in the world by Forbes Magazine this

Page 1 of 3

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year, with an estimated net worth of $2.0 billion. Stanford International Bank had $6 billion in

assets as of July, 2007, the company said on its Web site.

--Editors: Michael Forsythe, Otis Bilodeau

To contact the reporter on this story:

Alison Fitzgerald in Washington at +1-202-624-1846 or [email protected]

To contact the editor responsible for this story:

Michael Forsythe +1-202-624-1840 or [email protected]

Brenda L Bohs

561-544-8266 (P)

561-544-8265 (F)

-----Original Message-----

From: Bober, Michael

Sent: Monday, July 14, 2008 10:19 AM

To: Bohs, Brenda

Cc: MacDonald, Michael

Subject: Re: Wall st journal in beginning of july

Alex from miami. I think it was july 2nd date. Alex said go to www.bloomberg and put stanford in

search engine. Thanks

Sent from my Blackberry Wireless Device

Michael Bober CPA, CFP, CIMA, PFS

Managing Director

Stanford Group Company

561-350-4634 mobile

----- Original Message -----

From: Bohs, Brenda

To: Bober, Michael

Cc: MacDonald, Michael

Sent: Mon Jul 14 09:10:42 2008

Subject: RE: Wall st journal in beginning of july

Hi:

I search online on WSJ and didn't see anything. I am not sure if you have more access with a login.

Google had nothing

Yahoo had nothing

Derik has some old journals in the office so he will bring them home and I will look

I looked on the portal and the same employees are still listed as when we got here.

Where did you hear this?

Brenda L Bohs

561-544-8266 (P)

561-544-8265 (F)

-----Original Message-----

From: Bober, Michael

Sent: Monday, July 14, 2008 9:31 AM

To: Bohs, Brenda

Cc: MacDonald, Michael

Subject: Wall st journal in beginning of july

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Bb

Good morning. There was an article in wsj about some brokers in denver leaving stanford and their

comments about the firm. Can u google or see if u can find and please send to me.

Raining up here but all good. Meeting with alvarez young prospect in an hour and with alex and

arturo.

Thanks

Sent from my Blackberry Wireless Device

Michael Bober CPA, CFP, CIMA, PFS

Managing Director

Stanford Group Company

561-350-4634 mobile

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Exhibit KVT-2 to Declaration of Karyl Van Tassel

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From: MacDonald, Michael Sent: Monday, July 14, 2008 5:37 PM To: Bohs, Brenda; Bober, Michael Cc: Ventrice, Ed Subject: Re: Wall st journal in beginning of july   "Oh the web we weave" Let's hope they are lying And sgc is not doing something underhanded ------------------------ This message has been sent by my blackberry wireless device Michael S MacDonald VP Investments Stanford Group Company 561-544-8263   ----- Original Message ----- From: Bohs, Brenda To: Bober, Michael Cc: MacDonald, Michael; Ventrice, Ed Sent: Mon Jul 14 11:00:51 2008 Subject: RE: Wall st journal in beginning of july   Hi: I had Derik check Bloomberg and this is all he found:       By Alison Fitzgerald     July 3 (Bloomberg) -- The U.S. Securities and Exchange Commission is investigating sales of certificates of deposit by Stanford Group Company in its affiliated Antigua-based offshore bank.     The SEC issued subpoenas yesterday to two former Stanford Group employees asking for information about the CD sales by its offshore bank, Stanford International Bank Ltd. The subpoenas also demanded sales-training materials for the CDs and so-called mutual fund wrap programs, which are portfolios of diversified mutual funds. The companies are owned by billionaire R. Allen Stanford.     The subpoenas were provided to Bloomberg News by Mike O'Brien, the Houston-based attorney for two former employees, Charles Rawl and Mark Tidwell. They are both suing Houston-based Stanford Group, accusing the company of forcing them to resign because they did not want to participate in illegal activities that they say Stanford Group was requiring them to carry out.     Stanford Group spokeswoman Lula Rodriguez said the company is ``not aware of any formal actions by the SEC related to either Mr. Tidwell or Mr. Rawl or connected to any of our clients.''     Rodriguez said the allegations ``have been made by disgruntled employees and are totally without merit.''     SEC spokesman John Nester said the agency does not confirm or deny the existence of an investigation. Rawl and Tidwell were both investment advisers for Stanford Group in Houston.                          `Leave That Place'       ``All we wanted to do was leave that place, get out of there and get our clients out safe and sound,'' Rawl said in an interview.     In the lawsuit, Rawl and Tidwell claim that the company failed to file forms to the U.S. Treasury Department disclosing its clients' offshore holdings and did not advise its clients to file those forms.     The lawsuit also alleges that Stanford Group purged files and destroyed documents as early as last year related to what Tidwell and Rawl claim is an ongoing SEC investigation regarding the CD sales practices. The lawsuit alleges that the company gave clients false historical performance data for its securities.     In court papers, Stanford Group said it had fired Tidwell and Rawl and that the two owe the company repayment of loans made to them.     Rawl said he owes Stanford Group $579,441. He said the company paid him a bonus upon his hiring in 2005 that would vest over time and that he was required to pay back when he left the company early. Tidwell owes the company $155,598, according to court papers filed by Stanford Group.     R. Allen Stanford was ranked the 605th-richest person in the world by Forbes Magazine this year, with an estimated net worth of $2.0 billion. Stanford International Bank had $6 billion in assets as of July, 2007, the company said on its Web site.   --Editors: Michael Forsythe, Otis Bilodeau

Page 1 of 3From: MacDonald, Michael

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  To contact the reporter on this story: Alison Fitzgerald in Washington at +1-202-624-1846 or [email protected]   To contact the editor responsible for this story: Michael Forsythe +1-202-624-1840 or [email protected]     Brenda L Bohs 561-544-8266 (P) 561-544-8265 (F)   -----Original Message----- From: Bober, Michael Sent: Monday, July 14, 2008 10:19 AM To: Bohs, Brenda Cc: MacDonald, Michael Subject: Re: Wall st journal in beginning of july   Alex from miami. I think it was july 2nd date. Alex said go to www.bloomberg and put stanford in search engine.  Thanks   Sent from my Blackberry Wireless Device   Michael Bober CPA, CFP, CIMA, PFS Managing Director Stanford Group Company 561-350-4634 mobile   ----- Original Message ----- From: Bohs, Brenda To: Bober, Michael Cc: MacDonald, Michael Sent: Mon Jul 14 09:10:42 2008 Subject: RE: Wall st journal in beginning of july   Hi: I search online on WSJ and didn't see anything. I am not sure if you have more access with a login. Google had nothing Yahoo had nothing Derik has some old journals in the office so he will bring them home and I will look   I looked on the portal and the same employees are still listed as when we got here.   Where did you hear this?   Brenda L Bohs 561-544-8266 (P) 561-544-8265 (F) -----Original Message----- From: Bober, Michael Sent: Monday, July 14, 2008 9:31 AM To: Bohs, Brenda Cc: MacDonald, Michael Subject: Wall st journal in beginning of july     Bb   Good morning. There was an article in wsj about some brokers in denver leaving stanford and their comments about the firm. Can u google or see if u can find and please send to me.  

Page 2 of 3From: MacDonald, Michael

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Raining up here but all good. Meeting with alvarez young prospect in an hour and with alex and arturo.   Thanks   Sent from my Blackberry Wireless Device   Michael Bober CPA, CFP, CIMA, PFS Managing Director Stanford Group Company 561-350-4634 mobile

Page 3 of 3From: MacDonald, Michael

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Exhibit KVT-3 to Declaration of Karyl Van Tassel

97

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98

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Exhibit KVT-4 to Declaration of Karyl Van Tassel

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Exhibit KVT-5 to Declaration of Karyl Van Tassel

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From: Staley, Jack Sent: Wednesday, December 24, 2008 11:41 AM To: Stanford, Allen Subject: Re: AW: Libya! Sorry, yes we are ! ----- Original Message ----- From: Stanford, Allen To: Staley, Jack Sent: Wed Dec 24 05:32:49 2008 Subject: Re: AW: Libya! ???yes/no ----- Original Message ----- From: Staley, Jack To: Stanford, Allen Sent: Wed Dec 24 05:29:28 2008 Subject: Re: AW: Libya! Good. Thanks ----- Original Message ----- From: Stanford, Allen To: Staley, Jack Sent: Wed Dec 24 05:22:54 2008 Subject: Fw: AW: Libya! Jack are we sending to all clients the SIB monthly report and the WF magazine (with page tags as most people will miss page 50) RAS ----- Original Message ----- From: Stanford, Allen To: Siragna, Peter Sent: Wed Dec 24 05:17:03 2008 Subject: Re: AW: Libya! Good will put this on the calendar. Peter are you going to send the World Finance magazine and the just released SIB monthly report to this client? If so be sure to tag the pages in the mag where the story is page 32 and page 50. RAS ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Wed Dec 24 02:07:40 2008 Subject: AW: Libya! Allen, the proposed dates (25th - 27th) have been confirmed! Rgds. p. ________________________________ Von: Stanford, Allen Gesendet: Di 23.12.2008 12:34 An: Siragna, Peter Betreff: Re: Libya!

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Peter did you also receive the SIB monthly report today? RAS ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Tue Dec 23 07:09:05 2008 Subject: RE: Libya! We got the magazine! ________________________________ From: Stanford, Allen Sent: Tue 12/23/2008 6:02 AM To: Siragna, Peter Subject: Re: Libya! Call you in 15 minutes RAS ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Tue Dec 23 05:59:19 2008 Subject: RE: Libya! +4179216 0811! ________________________________ From: Stanford, Allen Sent: Tue 12/23/2008 5:54 AM To: Siragna, Peter Subject: Re: Libya! Peter what number can I reach you on? RAS ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Tue Dec 23 05:52:20 2008 Subject: Libya! Allen, in reference to our proposed dates (25, 26 and 27th Jan.) re our visit, after talking to AbduIfatah Sharif again today, I hopefully receive a confirmation by tomorrow! Whilst, they are obviously concerned about the "Madoff case", the "communication-climate" between us is however, very professional and also friendly! Wishing you and your family Happy Holidays! Kind regards. Peter.

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Exhibit KVT-6 to Declaration of Karyl Van Tassel

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From: Siragna, Peter Sent: Monday, February 09, 2009 2:30 PM To: Stanford, Allen Subject: RE: Libya Importance: High No Sir, thats money from LAFICO and they lost huge and need to have the cash back! However, I spoke to the newly appointed Treasurer of theirs recently and he spoke already of new investments with SIBL in the near future! So, I am not concerned at all about this! ________________________________________ From: Stanford, Allen Sent: Monday, February 09, 2009 3:24 PM To: Siragna, Peter Subject: Re: Libya Peter they are not closing out their position at SIB I trust...I learned that another 7M Euros was withdrawn last week. What is going on here. RAS ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Mon Feb 09 07:39:36 2009 Subject: Libya Allen, spoke to Abdulfatah Sharif this morning after his return from Dubai and their position is, that they awaiting our next step of actions in respect to the propositions we made at our visit/letters! It was also mentioned, that they would prefer to deal with one issue after the other, rather than us to "flock in" with everybody at the same time, i.e. maybe first with Capital Markets (distressed assets); followed by clean technology; the Green Mountains project (real estate development)! What do you think/suggest? As here-to-fore, I continue to pursue/push all "avenues" in respect to SIBL! Dr. Zlitni and Sharif will be in Rome later this week for 2 days, other than that, no fix travel agenda was mentioned! p. ________________________________________ From: Stanford, Allen Sent: Wednesday, February 04, 2009 9:24 AM To: Siragna, Peter Subject: Peter what is the status of our Libya friends and their doing more business with Stanford. RAS

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Exhibit KVT-7 to Declaration of Karyl Van Tassel

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From: Siragna, Peter Sent: Tuesday, February 10, 2009 6:02 PM To: Stanford, Allen Subject: RE: I understand your point, however the various companies organised under the Libyan Investment Authority have appointed budgets and P/L, but large freedom of how to invest and therefore also do not recveive "support" when things go sauer from LIA! ________________________________________ From: Stanford, Allen Sent: Tuesday, February 10, 2009 6:57 PM To: Siragna, Peter Subject: Re: Doesn't make sense Peter when they have the big general fund with so much cash. Are you certain we are on solid ground with them and they are interested in increasing their relationship with us? RAS ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Tue Feb 10 11:53:43 2009 Subject: RE: Well, as I mentioned yesterday, I am not concerned, as we know LAFICO lost huge amounts of money in 2008 and presently is in urgent need of cash! p. ________________________________________ From: Stanford, Allen Sent: Tuesday, February 10, 2009 6:06 PM To: Siragna, Peter Subject: What's going on with our Libya friends. I was advised that another 7M is leaving. RAS

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Exhibit KVT-8 to Declaration of Karyl Van Tassel

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From: Siragna, Peter Sent: Wednesday, February 04, 2009 8:38 AM To: Stanford, Allen Subject: Re: Good morning - well, our friend Sharif is still in Dubai until sunday with his family and therefore infos are difficult to optain! All letters have been delivered! The only indirect feedback i got so far from a lower level employe was, that our visit left a strong mark with everybody! As soon as our investment bankers are ready to deliver/visit re the distressed fund we need to go back!! Clean-tech people still need to optain visa's, but should send their passports asap to me! Rgds p. ----- Original Message ----- From: Stanford, Allen To: Siragna, Peter Sent: Wed Feb 04 02:24:33 2009 Subject: Peter what is the status of our Libya friends and their doing more business with Stanford. RAS

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Exhibit KVT-9 to Declaration of Karyl Van Tassel

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From: Siragna, Peter Sent: Wednesday, October 15, 2008 2:51 PM To: Stanford, Allen Subject: Urgent!! Is my attendence required tonight? Rgds p. ----- Original Message ----- From: Stanford, Allen To: Staley, Jack Cc: Siragna, Peter Sent: Tue Oct 14 06:50:15 2008 Subject: Re: Details/IMF Called yesterday no answer at the 2 #s given will try again today RAS ----- Original Message ----- From: Staley, Jack To: Stanford, Allen Sent: Tue Oct 14 05:14:48 2008 Subject: FW: Details/IMF Allen, Have you been able to make contact? Jack L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Tel. Nr.: +41.44.205.53 53 (direct) Fax Nr.: +41.44.205.53.06 ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Sun Oct 12 13:33:38 2008 Subject: FW: Details/IMF Dear Allen Please find hereunder the respective information and contact details! In talking to Abdulfatah Sharif after receiving this mail, he confirmed, that it would be appropriate for me to attend the meeting too, especially for further fallow up when next in Libya! You can reach me at the fallowing # +4179-2160811! I just arrived in NYC and I am staying at the InterContinental Hotel on 48th Street! Regards. Peter. ________________________________ From: Abdulfatah Sharif [mailto:[email protected]] Sent: Sun 10/12/2008 9:04 AM To: Siragna, Peter Cc: [email protected]; [email protected]

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Subject: Re: Details/IMF Dear Peter, Kindly note that Dr.Abdulhafez Zletni the Minister for Planning and Chairman of LIA (Libyan Investment Authority) is currently in Washington DC, attending the IMF meetings. Dr.Zletni is expecting Sir Allen`s office to contact the Libyan Mission in Washington by contacting our Charge d`affaires, Mr.Alaoujli at the following numbers: 1) 202 9449605 2) 202 9449601 . Dr.Zletni is eager to meet with Sir Allen any time of up to next Friday as he has to return back to Tripoli. As explained before Dr.Zletni is an ex University Professor, University President, Minister for Education, Minster of Econmy and Trade;.Ex Governor of Central Bank of Libya. This meeting will help consolidating relations between LIA and SG. Kind regards, Abdulfatah.

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Exhibit KVT-10 to Declaration of Karyl Van Tassel

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From: Barlow, Laura Sent: Wednesday, October 15, 2008 6:48 PM To: Stanford, Allen Subject: RE: Tonight is now a dinner meeting I spoke to Chene again and she said you could address Dr. Zlitni as Secretary or Secretary Zlitni. As for the assistant she said you could address him as Mr. El Meddehem. The emphases is on the d. She also said they do not get upset if their names are mispronounced they understand it is sometimes difficult for Americans to say their names as they do. -----Original Message----- From: Stanford, Allen Sent: Wednesday, October 15, 2008 12:32 PM To: Barlow, Laura Subject: Re: Tonight is now a dinner meeting Get the correct phonetic pronunciation and correct way to address his assistant ----- Original Message ----- From: Barlow, Laura To: Stanford, Allen Sent: Wed Oct 15 12:23:24 2008 Subject: RE: Tonight is now a dinner meeting Chene Fick said the only ones there should be Dr. Zlentni and his assistant Abubaker El Meddehem -----Original Message----- From: Stanford, Allen Sent: Wednesday, October 15, 2008 12:18 PM To: Barlow, Laura Subject: Re: Tonight is now a dinner meeting Who is going to be at the dinner? Names ----- Original Message ----- From: Barlow, Laura To: Stanford, Allen Sent: Wed Oct 15 12:08:50 2008 Subject: Tonight is now a dinner meeting Sir, Chene Fick called and confirmed the meeting tonight will now include dinner. Thank you, Laura

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Exhibit KVT-11 to Declaration of Karyl Van Tassel

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From: Staley, Jack Sent: Thursday, October 16, 2008 2:45 PM To: Siragna, Peter Cc: Stanford, Allen Subject: Re: Details/IMF Excellent news Peter! ----- Original Message ----- From: Siragna, Peter To: Staley, Jack Sent: Thu Oct 16 08:19:07 2008 Subject: Re: Details/IMF Back in NYC after a very good dinner meeting last nite! The two hitted off very well, it could not have gone any better! Dr. Zletni is a very smart operater, politician and financial expert at the same time! Certainly one of the top key individuals in the country! Sir Allen got officially invited by him and promissed to come within the next three months! P. ----- Original Message ----- From: Staley, Jack To: Siragna, Peter Sent: Wed Oct 15 05:15:19 2008 Subject: RE: Details/IMF Have you heard anything? L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Tel. Nr.: +41.44.205.53 53 (direct) Fax Nr.: +41.44.205.53.06 Email: [email protected] Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG. -----Original Message----- From: Siragna, Peter Sent: Monday, October 13, 2008 2:16 PM To: Staley, Jack Subject: Fw: Details/IMF Importance: High Here it is again! At this moment we have not fixed yet anything! I assume Allen will call this morning!

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----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Sun Oct 12 13:33:38 2008 Subject: FW: Details/IMF Dear Allen Please find hereunder the respective information and contact details! In talking to Abdulfatah Sharif after receiving this mail, he confirmed, that it would be appropriate for me to attend the meeting too, especially for further fallow up when next in Libya! You can reach me at the fallowing # +4179-2160811! I just arrived in NYC and I am staying at the InterContinental Hotel on 48th Street! Regards. Peter. ________________________________ From: Abdulfatah Sharif [mailto:[email protected]] Sent: Sun 10/12/2008 9:04 AM To: Siragna, Peter Cc: [email protected]; [email protected] Subject: Re: Details/IMF Dear Peter, Kindly note that Dr.Abdulhafez Zletni the Minister for Planning and Chairman of LIA (Libyan Investment Authority) is currently in Washington DC, attending the IMF meetings. Dr.Zletni is expecting Sir Allen`s office to contact the Libyan Mission in Washington by contacting our Charge d`affaires, Mr.Alaoujli at the following numbers: 1) 202 9449605 2) 202 9449601 . Dr.Zletni is eager to meet with Sir Allen any time of up to next Friday as he has to return back to Tripoli. As explained before Dr.Zletni is an ex University Professor, University President, Minister for Education, Minster of Econmy and Trade;.Ex Governor of Central Bank of Libya. This meeting will help consolidating relations between LIA and SG. Kind regards, Abdulfatah.

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Exhibit KVT-12 to Declaration of Karyl Van Tassel

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From: Siragna, Peter Sent: Thursday, October 23, 2008 11:09 AM To: Stanford, Allen Cc: Staley, Jack Subject: Meeting-Feedback ... Importance: High Spoke briefly to Sharif re a feedback from Dr. Zletni, however the two gentlemen have not had an opportunity yet to meet! Sharif expects to meet with him over the coming weekend! I shall keep you updated! Rgds p.

From: Stanford, Allen

Sent: Fri 10/17/2008 11:56 AM To: Siragna, Peter

Cc: Staley, Jack

Subject: Fw:

Blackberry was not functioning properly for 2 days so I am not certain that the below message was received RAS ----- Original Message ----- From: Stanford, Allen Cc: Staley, Jack Sent: Thu Oct 16 11:39:24 2008 Peter I had delivered to Dr Zlitini the Forbes magazine...World Finance article....bios of our international advisory board...a one page overview of Stanford and a short personal note from me. All in the nice leather pouch with the Eagle on it. He told Jim Conzleman who personally delivered it that he thoroughly enjoyed the dinner last night. RAS

Page 1 of 1Fw:

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Exhibit KVT-13 to Declaration of Karyl Van Tassel

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From: Conzelman, James Sent: Thursday, October 16, 2008 5:23 PM To: Stanford, Allen Subject: MISSION ACCOMPLISHED He sends his regards as well and wanted me to let you know how much he enjoyed dinner last evening.

Page 1 of 1From: Conzelman, James

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Exhibit KVT-14 to Declaration of Karyl Van Tassel

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From: Siragna, Peter Sent: Thursday, November 13, 2008 9:05 AM To: Stanford, Allen Cc: Staley, Jack Subject: Feedback! Importance: High Good Morning Sir I finally received a feedback from Abdulfatah Sharif re our meeting with Dr. Zlitni in DC, I quote: "He very much enjoyed the meeting; he was fascinated about you; he is impressed about our Group, in particular re our market approach & performance and above all, he would much welcome your visit to Libya"! It was proposed, that ideally you should make available for your visit 24 hours (1 overnight) and offer them 2 to 3 possible dates before the end of the year! Regards. Peter.

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Exhibit KVT-15 to Declaration of Karyl Van Tassel

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From: Conzelman, James Sent: Thursday, October 16, 2008 4:52 PM To: Stanford, Allen Subject: I have made telephone contact with Dr Zlitni. He will meet me in 10 minutes. I will be back in touch with you asap. Jim

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Exhibit KVT-16 to Declaration of Karyl Van Tassel

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From: Alvarado, Mauricio Sent: Sunday, July 15, 2007 10:55 AM To: Staley, Jack Subject: Re: Libya Jack, I thougth that the TPC meetings went very well. It was great. You did a super job!!! Congratulatons! Mauricio ----- Original Message ----- From: Alvarado, Mauricio To: Staley, Jack Sent: Sat Jul 14 00:37:51 2007 Subject: Re: Libya Thanks ----- Original Message ----- From: Staley, Jack To: Alvarado, Mauricio Sent: Sat Jul 14 00:37:03 2007 Subject: Re: Libya 9 am ----- Original Message ----- From: Alvarado, Mauricio To: Staley, Jack Sent: Sat Jul 14 00:35:42 2007 Subject: Re: Libya Jack, Good morning! At what time are we starting this morning? Mauricio ----- Original Message ----- From: Staley, Jack To: Alvarado, Mauricio Sent: Mon Jul 09 11:27:10 2007 Subject: RE: Libya Great!! L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Fax Nr.: +41.44.205.53.06 Email: [email protected]

Page 1 of 3From: Alvarado, Mauricio

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Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG. -----Original Message----- From: Alvarado, Mauricio Sent: Monday, July 09, 2007 6:19 PM To: Staley, Jack Subject: Re: Libya No problem. I will be available at any time. I should be arriving in Zurich by noon on Friday. I will see you then. Thanks. Mauricio ----- Original Message ----- From: Staley, Jack To: Davis, James; Alvarado, Mauricio Cc: Siragna, Peter; Stanford, Allen Sent: Mon Jul 09 09:10:32 2007 Subject: Libya Good morning Jim and Mauricio You may remember in our discussions in Zurich that we wanted to get Allen with the people in Libya. The schedules will not allow us to this (them not us) and instead our main contact, Mr. Sharif, will be coming to Zurich on this Friday the 13th, TPC day. Allen has agreed to meet him after the close of the Friday session and I am alerting you in case Allen wants you to join him in the session. All the best and I look forward to seeing you this week!! Jack L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12

Page 2 of 3From: Alvarado, Mauricio

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CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Fax Nr.: +41.44.205.53.06 Email: [email protected] <mailto:[email protected]> Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG.

Page 3 of 3From: Alvarado, Mauricio

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Exhibit KVT-17 to Declaration of Karyl Van Tassel

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From: Staley, Jack Sent: Monday, August 27, 2007 5:07 PM To: Pendergest, Laura Subject: Good News-Libya Laura, Thanks to the hospitality of you and your team in handling our Libyan guests last month, you will be pleased to know that on Friday of last week we received $150 million. Of this amount, $50 million will go initially to SIB (for a period of 6 months as part of the allocation process) and $100million will stay at Coutts. Please let everyone know who had a hand in this that they were instrumental in helping us achieve this.!! Thanks Jack L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Tel. Nr.: +41.44.205.53 53 (direct) Fax Nr.: +41.44.205.53.06 Email: [email protected] Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG.

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Exhibit KVT-18 to Declaration of Karyl Van Tassel

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From: Stanford, Allen Sent: Monday, October 01, 2007 4:13 PM To: Siragna, Peter; Staley, Jack Subject: Re: Libya - trip to NYC We can help on the political front. Let them know that. Also are they aware of the Forbes 400.? Good PR. RAS ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen; Staley, Jack Sent: Mon Oct 01 10:00:10 2007 Subject: Libya - trip to NYC Still awaiting final news (dates) on above subject, however the original meant delegation has been broken- up into two, one more focused on the political front with D.C. and one covering "everything else", i.e. business-focused! I shall keep you informed! Thanks, p. ________________________________ From: Stanford, Allen Sent: Thu 9/6/2007 2:44 PM To: Staley, Jack Cc: Siragna, Peter Subject: RE: Libya Just landed Miami call 3059608531 in 30 min to talk RAS ________________________________ From: Staley, Jack Sent: Wednesday, September 05, 2007 9:48 AM To: Stanford, Allen Cc: Siragna, Peter Subject: Libya Allen, This is just a heads-up The delegation of our Libyan friends that you were to meet in Libya are now coming to NYC at the end of Sept/first part of October and will be with Gaddafi’ s son. They would like to meet with you and talk about real estate investment opportunities. This certainly might be more agreeable for you than having to meet them in Libya and it moves the discussion along the lines of what you talked about with Mr. Sharif. Please let me know how you would like us to handle this Thanks Jack

Page 1 of 2From: Stanford, Allen

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L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Tel. Nr.: +41.44.205.53 53 (direct) Fax Nr.: +41.44.205.53.06 Email: [email protected] <mailto:[email protected]> Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG.

Page 2 of 2From: Stanford, Allen

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Exhibit KVT-19 to Declaration of Karyl Van Tassel

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From: Staley, Jack Sent: Wednesday, November 28, 2007 10:47 AM To: Stanford, Allen Cc: Walker, Kye; Hodge, Julie Subject: Your Zurich visit Allen, Good morning! Hope you are well. I am checking to see if the Zurich visit is still on track for your arrival on Sunday (this week) with Monday in the office in Zurich and Tuesday going to Geneva. I have the investment group we are seeking to buy on standby for 2:30 pm in Geneva and also our friends from the desert (Mr. Sharif) wanting to see you in Geneva also, late in the day. Please let me know as soon as you can. Thanks Jack L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Tel. Nr.: +41.44.205.53 53 (direct) Fax Nr.: +41.44.205.53.06 Email: [email protected] Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG.

Page 1 of 1

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Exhibit KVT-20 to Declaration of Karyl Van Tassel

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From: Siragna, Peter Sent: Thursday, November 29, 2007 12:56 PM To: Stanford, Allen Subject: RE: Our "North African Friends" ..... Okay thanks, will do!

From: Stanford, Allen Sent: Thu 11/29/2007 6:16 AM To: Siragna, Peter Cc: Staley, Jack; Hill, Karen; Walker, Kye Subject: Re: Our "North African Friends" .....

Peter set the meeting for 430pm Tues at the Kempinski (former Noga Hilton). Tell Mr Sharif I look forward to seeing him again. RAS ----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Thu Nov 29 04:39:11 2007 Subject: RE: Our "North African Friends" ..... Good morning Sir I understand from Jack, that you have a meeting arranged in Geneva at 2.30pm close to the Airport. Mr. Sharif would be available for meeting with you, any time between 4.00pm and 7.00pm in Geneva, as he has commitments before and after those times. Thank you for your attention. Regards. Peter. ________________________________ From: Stanford, Allen Sent: Thu 11/15/2007 7:23 AM To: Siragna, Peter Cc: Staley, Jack Subject: Re: Our "North African Friends" ..... Peter..... I will be in Zurich/Geneva Dec 3rd and 4th If Mr Sharif is available to meet on those dates I would welcome the opportunity to visit with him. RAS ------Original Message------ From: Siragna, Peter To: Allen Stanford Sent: Nov 15, 2007 6:10 AM Subject: Our "North African Friends" ..... Apologies for not being able to communicate to you further information in regard to a possible trip of a above mentioned delegation to NYC! Whilst there are at present some ministers attending the yearly IMF Meetings, I've been today briefed, that the people we should meet will only travel to the US in the early part of next year! I have also learned yesterday from the Zurich Management, that you might be in Zurich and Geneva in the early part of December and should you wish in the meanwhile, I would be happy in trying to arrange a further meeting with Mr. Abdulfatah A. Sharif (Chairman of Libyan African Investment Company) for you during those dates. Thank you for your attention. Kind regards. Peter.

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Exhibit KVT-21 to Declaration of Karyl Van Tassel

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From: Staley, Jack Sent: Friday, January 04, 2008 12:50 PM To: Stanford, Allen Subject: RE: Libya heads U.N. Security Council - CNN.com Allen, We are waiting for the 150mio as we speak. They indicated they would get it to us by end of year. It is coming, but their timing is always a bit loose. Hope you are well. Jack L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Tel. Nr.: +41.44.205.53 53 (direct) Fax Nr.: +41.44.205.53.06 Email: [email protected] Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG. -----Original Message----- From: Stanford, Allen Sent: Friday, January 04, 2008 1:47 PM To: Staley, Jack Subject: Re: Libya heads U.N. Security Council - CNN.com Where are we on the additional business discussed in Geneva? RAS ----- Original Message ----- From: [email protected] <[email protected]> To: Stanford, Allen Sent: Fri Jan 04 01:58:11 2008 Subject: Libya heads U.N. Security Council - CNN.com <http://s.clickability.com/s?19=40004&7=212106&38=2060630040> <http://images.clickability.com/eti/spacer.gif> <http://images.clickability.com/eti/spacer.gif> CNN.com <http://edition.cnn.com> <http://images.clickability.com/logos/cc0000/emailthis-logo.gif> Powered by <javascript: window.open('http://www.clickability.com/landing/imware','','toolbar=no, width=800, height=800, resizable=1, scrollbars=1'); void('');> * Please note, the sender's email address has not been verified. <http://images.clickability.com/eti/spacer.gif>

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Allen, This is really significanct!! Jack <http://images.clickability.com/eti/spacer.gif> Click the following to access the sent link: <http://images.clickability.com/partners/205021/etIcon.gif> Libya heads U.N. Security Council - CNN.com <http://www.emailthis.clickability.com/et/emailThis?clickMap=viewThis&etMailToID=2060630040> * SAVE THIS link <http://www.savethis.clickability.com/st/saveThisPopupApp?clickMap=saveFromET&partnerID=212106&etMailToID=2060630040> FORWARD THIS link <http://www.emailthis.clickability.com/et/emailThis?clickMap=forward&etMailToID=2060630040&partnerID=212106> Get your EMAIL THIS Browser Button and use it to email information from any Web site. <http://www.emailthis.clickability.com/et/emailThis?clickMap=browserButtons> <http://images.clickability.com/eti/spacer.gif> *This article can also be accessed if you copy and paste the entire address below into your web browser. http://edition.cnn.com/2008/WORLD/africa/01/03/libya.un/index.html

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Exhibit KVT-22 to Declaration of Karyl Van Tassel

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From: Davis, James Sent: Thursday, January 15, 2009 7:39 PM To: Stanford, Allen Subject: Re: Libya! God bless us one and all Sent from my iPhone On Jan 15, 2009, at 10:50 AM, "Stanford, Allen" <[email protected]> wrote:

FYI

----- Original Message ----- From: Siragna, Peter To: Stanford, Allen Sent: Thu Jan 15 09:43:35 2009 Subject: RE: Libya!

Allen, in respect to the proposed agenda, at this moment I only got a verbal overview of the people we should meet:

Libyan Investment Authority - Dr. Zlitni (Chairman) & Mr. M. Layas (CEO) Libyan African Portfolio - Mr. Bashir Salah (Chairman) & Mr. A. Sharif (CEO) Libyan Foreign Investment Co. - Mr. I. Zletni (Chairman) Libyan Foreign Bank (Central Bank) - Mr. Jousef Abdelmaula (Chairman) & CEO Libyan Financial Investment Co. - Dr. Khaled F. Zentuti (CEO)

In respect to the Visa process, you should receive your invitation numbers latest on Monday. You should also urgently organise an arabic translation of your passport. You might want to contact the Libyan Embassy in advance to see, if they could provide you with such a translation too.

p.

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Exhibit KVT-23 to Declaration of Karyl Van Tassel

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From: Davis, James Sent: Tuesday, January 27, 2009 12:41 PM To: Stanford, Allen Subject: Re: Results Still, time is fleeting. I know all will work, but have to sit down on strategic issues. Thx....praying foe u Sent from my iPhone On Jan 27, 2009, at 6:29 PM, "Stanford, Allen" <[email protected]> wrote:

All positive.. incredible opportunities..met with all and I mean all of the top decision makers .. working on follow up plan on the am... I'm Zurich now going to dinner and follow up on actions to be taken..meeting tomorrow am with Solidinvest owner 450M deal discretionary management. My blackb wouldn't work in Libya and is now hit and miss anyway fill you in over weekend. All is good and will work out.

----- Original Message ----- From: Davis, James To: Stanford, Allen Sent: Tue Jan 27 05:59:57 2009 Subject: Results

Any word from travel?

Sent from my iPhone

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Exhibit KVT-24 to Declaration of Karyl Van Tassel

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From: Lopez, Gil Sent: Friday, March 02, 2007 2:57 PM To: Kuhrt, Mark Subject: Fw: Libyan Joint Venture Attachments: Memo Libyan Joint Venture.pdf; Libyan Joint Venture Scenarios.pdf Sent from my GoodLink synchronized handheld (www.good.com) -----Original Message----- From: Davis, James Sent: Friday, March 02, 2007 06:00 AM Central Standard Time To: '[email protected].' Cc: Pendergest, Laura; Lopez, Gil; Lopez, Gil Subject: Fw: Libyan Joint Venture ----- Original Message ----- From: Staley, Jack To: Davis, James Sent: Fri Mar 02 03:38:20 2007 Subject: FW: Libyan Joint Venture Jim, I thought I would forward to you the outlines we are working on for Libya. This is our first draft. We obviously will require input from compliance, legal, accounting etc but we thought it made sense to get this going. Peter Siranga will be meeting them again in a week and we will get their input at that time. Best regards Jack L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Fax Nr.: +41.44.205.53.06

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Email: [email protected] <mailto:[email protected]> Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG. _____ From: Heiniger, Silvia Sent: Friday, March 02, 2007 8:47 AM To: Staley, Jack Subject: Libyan Joint Venture Here you go. As you know, I am not an expert in the English language. In case you would find odd words/phrases within presentations which I have prepared, you can always tell me and I will adjust them. I always try to do tasks according to my best knowledge. Thanks. Silvia Heiniger Financial Accountant Stanford Group (Suisse) AG Dreikönigstrasse 12 CH-8002 Zurich - Switzerland Phone: +41 44 / 205 5300 Fax: +41 44 / 205 5305 e-mail: [email protected] <mailto:[email protected]>

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Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG.

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Exhibit KVT-25 to Declaration of Karyl Van Tassel

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M E M O

From: SH

To: LJS/MR/PS

cc: HK

Date: 28-Feb-2007

Re: New Joint Venture Company and/or Holding Structure between SG Suisse & Libyan Client

Structure:

o Legal entity of new JV company (e.g. AG, etc.) or Off-shore Holding structure (e.g. in Malta, Morocco, Singapore, Liechtenstein, Dubai, EU: Luxembourg or Netherlands)

o Investment share by each party (e.g. 50/50, 40/60, 30/70)

o Domicile (e.g. Zurich, Zug)

o Shareholder’s, BoD, etc.

o Staffing, minimum requirements

o Resource planning (provided from SGS to JV): IT, Manpower, Processes

o Objectives of JV (e.g. discretionary asset management for unit funds, annual assumed revenue & AUM)

o Product types

o Assessment for growth options

Legal Aspects:

o Obtain legal advice and in depth evaluation

o Company foundation

o JV agreement

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Regulatory Framework:

o Regulated by Polyreg? (if JV in Switzerland)

o Independence

Taxation:

o Subject to international tax planning (Domicile, Holding, etc.)

o Within Switzerland: Zug or Zurich, applicable tax rate (11-23%)

Financial Accounting:

o Same financial accounting set up for new JV company as for SGS, but kept completely separate and independent

o Financial accounting could be fully maintained/administered by SGS

o Same reporting to Houston as SGS by indicating SGS’ investment share into this new JV company

o Consider additional reporting requirements from the Libyan party (according to Libyan Gaap or other Gaap depending on e.g. Holding domicile)

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Exhibit KVT-26 to Declaration of Karyl Van Tassel

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Scenario 1:

SGS' investment in JV to be discussed

= Investment tax credit (Beteiligungsabzug)

SGS Libyan

Zurich Client

Dividend0% WHT 100% investment

° Manpower Royalties

° Know How Check DTT

° IT & Processes Taxation?

Off-shore Staff, several Investments (Hospitality)

Holding ° Own Libyan Assets

Malta to be managed

° Asset MngmtFees (or Dubai, Morocco etc.) ° External Client Referrals

° SLA for provid. Resources Discretionary Mngmt?

Revenue Volume? Unit Funds?

Management Fees %? 50% investment share each

taxable (or 30-40% / 60-70%)Dividend35% WHT possible

(If Holding in EU: 0% possible due to DTT)

(Luxembourg, Netherlands)

New

Joint Venture

(AG)

Zug Zug: Should have local Senior Staff or BoD

(or Zurich)

Products (Discretionary Mngmt, Unit Funds, etc.)?

Assumed annual Revenue Volume?

AUM Annual new AUM Volume?

Outsourcing of Resources (Manpower, IT, Processes) to SGS

Marketing?

Taxation?

Legal & Regulatory?

Taxation Switzerland:

Zug: approx. 11% Income&Capital Tax

Zurich: approx. 23% Income&Capital Tax

DBSt: 8,5% Income Tax

DTT = Double Tax Treaty

WHT = Withholding Tax

Off-shore Holding Structure Malta - Joint Venture Zug

Custodian

Banks

eg. UBS, BKB?,

Coutts

VFeb2007

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Scenario 2:

SGS' investment in JV to be discussed

= Investment tax credit (Beteiligungsabzug)

SGS Libyan

Zurich Client

50% investment share each

(or 30-40% / 60-70%) Taxation?

° Manpower

° Know How

° IT & Processes

° Own Libyan Assets

to be managed

° External Client Referrals

° Asset MngmtFees Discretionary Mngmt?

° SLA for provid. Resources Unit Funds?

Revenue Volume?

Management Fees %?

taxable Dividend Dividend0% WHT 35% WHT

(no DTT)

New

Joint Venture

(AG)

Zug Zug: Should have local Senior Staff or BoD

(or Zurich)

Products (Discretionary Mngmt, Unit Funds, etc.)?

Assumed annual Revenue Volume?

AUM Annual new AUM Volume?

Outsourcing of Resources (Manpower, IT, Processes) to SGS

Marketing?

Taxation?

Legal & Regulatory?

Taxation Switzerland:

Zug: approx. 11% Income&Capital Tax

Zurich: approx. 23% Income&Capital Tax

DBSt: 8,5% Income Tax

DTT = Double Tax Treaty

WHT = Withholding Tax

On-shore Joint Venture Zug

Custodian

Banks

e.g. UBS, BKB?,

Coutts

VFeb2007

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Scenario 3:

SGS Libyan

Zurich Client

Taxation?

° Manpower

° Know How

° IT & Processes

° Own Libyan Assets

100% investment to be managed

° External Client Referrals

° Asset MngmtFees Discretionary Mngmt?

° SLA for provid. Resources Unit Funds?

Revenue Volume?

Management Fees %?

taxable Dividend35% WHT

(no DTT)

New

Company

(AG)

Zug

(or Liechtenstein)

Products (Discretionary Mngmt, Unit Funds, etc.)?

Assumed annual Revenue Volume?

AUM Annual new AUM Volume?

Outsourcing of Resources (Manpower, IT, Processes) to SGS

Marketing?

Taxation?

Legal & Regulatory?

Taxation Switzerland:

Zug: approx. 11% Income&Capital Tax

Zurich: approx. 23% Income&Capital Tax

DBSt: 8,5% Income Tax

Taxation Liechtenstein:

DTT = Double Tax Treaty approx. 7,5-15% (AG)

WHT = Withholding Tax

SGS provides Asset Management & Resources for Libyan owned Company

SGS stays independent and does not hold any investment in this new company.

Custodian

Banks

e.g. UBS, BKB?,

Coutts

VFeb2007

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Exhibit KVT-27 to Declaration of Karyl Van Tassel

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From: Davis, James Sent: Thursday, March 15, 2007 12:04 PM To: Pendergest, Laura Subject: Fw: Libya Be ready to be my eyes and ears on this one ----- Original Message ----- From: Staley, Jack To: Alvarado, Mauricio; Lopez, Gil; Stinson, Lena Cc: Rathgeb, Martin; Heiniger, Silvia; Krieger, Hansjorg; Davis, James; Siragna, Peter Sent: Thu Mar 15 04:05:15 2007 Subject: Libya We have been working with our client in Libya about establishing a JV with them to manage money which they will be able to bring from many other clients throughout North Africa. We have been talking with them for a while and they have now given the green light to begin to put something together in order to be in business by early summer. I believe this will entail establishing a new company here in Switzerland initially to handle the business. I am alerting you all now as we will want to move ahead soon and I need your help in thinking this through. Do we have a prototype JV document we can review? What are our finance issues, including capital considerations (minimal), but which company would make the investment, and what issues do we need to be wary of regarding compliance etc, etc, etc. Please put some though into this and let me know what other areas we need to be working on. We will try to set up a conference call in the next few days to outline our course of action. Thanks Jack L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Fax Nr.: +41.44.205.53.06 Email: [email protected] <mailto:[email protected]> Please note: This e-mail message transmission and any attachment herein may contain

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confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG.

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Exhibit KVT-28 to Declaration of Karyl Van Tassel

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From: Staley, Jack Sent: Monday, March 26, 2007 8:56 PM To: Alvarado, Mauricio Cc: Rathgeb, Martin Subject: JV Libya Mauricio I understand that you have some comments regarding the JV opportunity we are pursuing with Libya. My clear discussion at the table in ST Croix said that we are pursuing this as a possible JV with our swiss company. From a regulatory standpoint there is no issue. Please help me understand how we look at investments as we were also stopped on Blue Oak. Allen was very clear. He told me in front of all of the group that day to get it done. The Libyan connection wants to pursue a JV with us. We need to work through many details before this goes live. If you can provide your thoughts on how we can best do a deal or better way for us to get it done please tell me. Keep in mind the client is looking for a JV structure. Our thought was a 50 50 JV company, Swiss , regulated as SG Swiss is currently, where the JV company hires SG Swiss to manage the money. They want a JV structure and as you know we can't bring them inside of our company we can set up another one to accomplish what they want. Please advise how we may accomplish what they want and what we want if the above doesn't work. Thanks. Jack

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Exhibit KVT-29 to Declaration of Karyl Van Tassel

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From: Alvarado, Mauricio Sent: Thursday, April 05, 2007 7:34 PM To: Staley, Jack Cc: Vingerhoedt, Frans Subject: RE: Libya Jack, Thank you for your note. You have my support conceptually for this venture. I think we should look at every possibility to enhance our relationship with such client in our asset manager capacity, as agreed during our meeting in St.Croix. However, my suggestion would be to consider allowing the Libyan Foreign Investment Company (LFICO) or other Libyan government authorities to create the new marketing company (NEWCO) wholly-owned directly or indirectly (through a holding) by the Libyan government. Thereafter, our existing Swiss company could enter into a referral agreement with NEWCO whereby NEWCO would refer both Libyan and non Libyan institutional investors as clients to our existing Swiss company. The compensation scheme and other financial arrangements to accomplish your objectives could be structured in form and substance similar to the form and substance that you would otherwise structure in a Joint Venture scheme, without incurring the added liability exposure and other risks associated with being a partner of a foreign government entity, such as the Libyan Foreign Investment Company (LFICO) or other Libyan government authorities. It is also very important from our perspective, as a financial institution, to have and retain the absolute right to sever the relationship with any client at any time should circumstances -- political, economic or otherwise -- change, or should any of our regulators so order. Thus, while the Libyan Foreign Investment Company (LFICO) or other Libyan government authorities would continue being our clients in our asset manager capacity, we would retain such right to sever our relationship at any time by simply closing their accounts with any of our financial institutions; whereas, in a joint venture scheme where one of our companies becomes a partner with such client, we would loose such needed flexibility. In regards to the reporting requirements, please be informed that this is not a Swiss law issue; it is a requirement under US law that applies to our Chairman and sole shareholder, who is the ultimate shareholder and a director of a US Broker-Dealer that is a member firm of the NASD. As such, RAS is required to file and maintain a Form U4, Uniform Application for Securities Industry Registration or Transfer. The NASD Registration Requirements specifically state, “Any person associated with a member firm who is engaged in the securities business of the firm, including partners, officers, directors,…must register with the NASD” and “…is under a continuing obligation to amend and update information required by Form U4 as changes occur.” Specific information RAS is required to disclose on the Form U4 includes all companies where he holds positions as sole shareholder, officer, director, chairman, etc., and this includes both investment and non-investment related activities. Thanks. Mauricio

From: Staley, Jack Sent: Thursday, April 05, 2007 4:03 AM

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To: Alvarado, Mauricio

Cc: Vingerhoedt, Frans Subject: Libya Dear Mauricio, I thought that for good order sake and in the spirit of collaboration, I would like to outline for you the proposal we would like to pursue with our Libyan connection. As you and others know, this venture is not a new initiative. In fact, it has been talked about a lot with the senior team since last year when Frans began discussions with them about other possible collaborations. From what I can see, most of the senior team is supportive of this idea, especially Allen and Jim. We have tried to simplify the structure in question to accommodate the client requests, all the while maintaining our sense of purpose which is to act only as the asset manager for their substantial source of funds. What we suggest is the following:

1. Establish a separate Swiss company which will act ONLY as the marketing arm for this venture. The marketing, as we indicated before, will be to both Libyan and non Libyan institutional investors in North Africa. While we will want to own a piece of the company for revenue purposes, the responsibility for client acquisition will rest with this new company. The initial thought by our client is that this newco will be owned by a separate holding company (based in Malta) and will not have a direct link by name. The marketing company essentially refers clients to SG Swiss and in turn we open the accounts on the books of CS, UBS or Coutts. It certainly is the intent to have this new company under the same regulatory supervisor as us, namely Polyreg. Our client wants us a part owner of the marketing company because they want to demonstrate to potential clients that they have a very credible and powerful company which is associated with them. This gives them marketing clout. The fact that they can say they have a business relationship with the asset manager will go a long way toward moving us forward.

2. In response to your comment that “this might require us to make a regulatory notification”, I guess I need some help with this. Please advise which regulatory body has jurisdiction. Certainly not the Swiss. And, if it is not the Swiss, who would it be and why? There is absolutely no requirement for us to disclose this relationship. It is simply an ownership position in a marketing company, nothing more.

3. While we should not be blinded by the money, there are substantial institutional assets which we will generate for our Swiss operation. We are talking about $500 mio to $1 billion or more (their estimates)

4. As you know, the Libyan Foreign Investment Company (LFICO), is already a substantial client of Antigua which, in fact, is a direct link to the government. So, I see no difference.

5. Our external corporate auditor has indicated that there is no issue with this structure, and does not constitute an event which triggers a notification to the Banking authorities..

6. The fact that a number of the senior team seems to be comfortable with this client (Jim, Allen, Juan, Frans, even you), I would like to push this concept forward.

I would like to provide you with a draft of an outline to review and gain your support for this initiative. Please accept my best wishes to you and your family for a wonderful Easter. Jack L. Jack Staley President Stanford Group (Suisse) AG Dreikonigstrasse 12 CH - 8002 Zurich, Switzerland Tel. Nr.: +41.44.205.53.00 Fax Nr.: +41.44.205.53.06

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Email: [email protected] Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG.

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Exhibit KVT-30 to Declaration of Karyl Van Tassel

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V I S I T L Y B I A N D E L E G A T I O N Prepared: June 13, 2007 To: Jack Staley, Martin Rathgeb, Peter Siragna, Stefan Paulus, Hansjörg Krieger, Corinne Schwarzentrub Date Topic Owner Comments Tuesday, 12/6/2007

Arrival Date Pick up at the airport Transportation General information about Zurich Appartment

CS

Wednesday, 13/6/2007

General Information Introduction of mgmt team Information Stanford Financial Group Information Stanford Group (Suisse)

JST/MCR/ PS/HJK

Thursday, 14/6/2007

Morning Session: Legal Issues Compliance Afternoon Session: Investments Introduction in Stanford’s investment philosophy, products & investment units Track record Portfolio construction, Outside manager selection

HJK MG

Friday, 15/6/2007

Morning Session: Investments (cont.) Markets Asset Classes Instruments Products Afternoon Session: Compliance (TvT) Money Laundering

MG HJK

Mr. van Thiel (TvT)

Monday, 18/6/2007

Morning Session: Fund selection/evaluation Money Managers MFP Afternoon Session: Database & Research tools 1515 Lipper (fund evaluation tool) Visit to Lipper’s Zurich office @ Hufgasse 1700 PerTrac Oprimization tool Web-ex presentation

SP SP SP

Martina Richards (Lipper) Laurence Herzberg (PerTrac)

Tuesday, 19/6/2007

Morning Session: Funds 0930 Fund Presentation Schroders Swiss Opportunities Equity Fund

SP/MG

Stefan Frischknecht (Schroders)

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Visit to Schroders office @ Central Afternoon Session: Alternative Investments 1400 Blue Oak Presentation/Work Shop

SP/MG

Simon Bayles (Blue Oak)

Wednesday, 20/6/2007

Morning Session: Third party products Presentation Threadneedle General product overview Afternoon Session: External Money Manager Product, Smart Funds, Mutual Funds

SP/MG

Christian Trixl (Threadneedle) Placido Albanese, Michel Hagens (Finter Bank)

Thursday, 21/6/2007

Morning Session: Structured Products Presentation / Work Shop UBS Afternoon Session: Private Equity 1400 Feri Trust Portfolio construction workshop

MG MG/SP

Claudio Vella (UBS) Antje Biber (Feri Trust)

Friday, 22/6/2007

Morning Session: Information Systems Presentation Bloomberg @ Seidengasse Odyssey Afternoon Session: Wrap-up sessions Summary

SP HJK all

Matt Nurse (Bloomberg)

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Exhibit KVT-31 to Declaration of Karyl Van Tassel

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From: Zora, Mary Sent: Friday, June 15, 2007 4:44 PM To: Schwarzentrub, Corinne; Saldana, Virginia; Herman, Susan; Mercer, Sascha; Rathgeb, Martin; Siragna, Peter; McDougall, Charlene Cc: Gonsalves, Natasha; ERD; Levine, Allan; Davis, James; DAmato, Jason A.; Parker, Rich; Feehan, Hugh; Vingerhoedt, Frans; D'Aniello, Anthony; Rodriguez-Tolentino, Juan; Li, James C; Pi, Osvaldo; Chaisson, Scott S.; Winter, Arlene; Parrish, Zack; Varkey, John; Garlich, Edward; Weeden, Ken; Pendergest, Laura; Finkelstein, Ben; Willard, Neal; Bogar, Danny; Karouni, Sal; Mulett, Sybil; Weiser, Charles; Jackson, Kerry; Young, Bernerd; Fram, Frederick; Rigby, Glen; Lear, Rhonda K.; Comeaux, Jay; Hawkins, Kelley; Garcia, Luis (Houston); Orozco, Dolores (Loly); Security Houston; Receptionist Houston 5050; Barlow, Laura; Stack, Joan Subject: RE: Training for our Libyan guests - URGENT NOTICE Attachments: STANFORD RESOURCES.xls; Training Libya.doc

Corinne,

We do have direct bill for most hotels, as well as ground transportation, so this should not be a problem. Their out-of-pocket expense would be for restaurants, entertainment and any other personal needs they may have. If the FA traveling with them uses his credit card for these items, that would work out well.

We do have a gentlemen here in our Houston office who is from Lebanon. He has offered to be their escort while in Houston. To the point of locating restaurants, site seeing and other events as desired. His name is Sal Karouni. Sal is well connected in his community here in Houston and will do a stellar job in indoctrinating our visitors into the Houston culture.

The attached Resource List is for your review and consideration in contacting the various locations for further assistance. As indicated in the email below, each of the executives in the locations have been given a heads up on the upcoming visits to their respective locations. The list attached is provided for informational purposes only and is to the best of my knowledge, the correct contact person in these locations. However, each department head should confirm and assign the appropriate task within their respective offices, allowing for appropriate training presentations, etc.

We will ensure that our guests are taken care of while in Houston. Each department head in the various locations will be responsible for doing the same, to include hotels, ground transportation, entertainment, etc., while keeping in mind that the visitors do not have credit cards and will rely on our generosity to provide for their needs. All costs for this should be forwarded to the ERD.

To all: If I have left anyone off of this distribution list, please feel free to forward this communication so that we are all on the same page. Note: The Training email attached is provided for information purposes and was forwarded to us by Corinne Schwarzentrub of the Suisse office.

As a heads up to those who have not been copied on prior correspondence, please see the message below from Jack Staley from our Suisse office:

HOUSTON Representatives addressed above: I would like to schedule a meeting on Monday, June 18 at 4:00 pm so that we can coordinate our efforts. Please let Virginia Saldana, re: [email protected], know your availability for this meeting.

From: Staley, Jack Sent: Wednesday, May 30, 2007 8:51 AM To: Garlich, Edward; Pendergest, Laura; Parrish, Zack; Stys, Mark V.; DAmato, Jason A.; Willard, Neal; Frisard, Joe; Bogar, Danny; Rodriguez-Tolentino, Juan; D'Aniello, Anthony; Vingerhoedt, Frans; Spivak, Gary; Stein, Ronald; Tonarelli, Oreste; Siragna, Peter; Rathgeb, Martin; Colavito, Deborah; Zarich, Michael; Zora, Mary; Comeaux, Jay; Stinson, Lena; Reggi, Tom

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Cc: Stanford, Allen; Davis, James; Alvarado, Mauricio; Suarez, Yolanda Subject: TRAINING REQUEST

Over 1 1/2 years ago, Frans Vingerhoedt and Peter Siragna began a lengthy courting process for some business coming out of North Africa which so far has netted a substantial sum for our bank in Antigua. Part of the process for us to obtain even more money from this group will entail us doing some training for 3 of their people. In our discussions with the client, they would be interested to learn more about our investment philosophy, our absolute return theory and practice of investing, geo-political research, company specific research, stock and bond selection techniques as well as the mechanics of investing, and special products ranging from fixed income disciplines to alternatives. As they are comfortable with us as counterparty for their funds, we want to give them a great experience and cement our relationship even more.

They will begin with us in Zurich on June 13. We then propose to send them to the US with stops in NY, Washington, Memphis, Houston, Miami ( Boca as well) and certainly Antigua, and then back to Zurich. We will have one of our Zurich people accompany them in all locations for the duration of the visits.

I am sending this to all of you to ascertain your availability and the availability of your groups/staffs to help us with this project. We think that the time requirements would be for no more than 2 days each in NY and Washington. Memphis would probably be up to 3-4 days as would Houston. Miami/Boca would be 2-3 days and Antigua 3 days. Total time for the project will be close to 6 weeks.

It is our wish that we show them as much of Stanford as possible, keeping the training and briefings informative and highly focused, and as technical as possible. We are of the opinion that if we can pull this off, we stand to receive a fairly substantial sum of money, well in excess of what we already have. But we need your help.

Peter Siragna will be contacting each of you to check your availability and establish some times/dates and an outline of a schedule for each location. Please let me know if you feel we have forgotten anyone

FYI, Allen, Jim, Mauricio and Laura have been pre-advised and are supporting this endeavor wholeheartedly.

Thank you very much for your cooperation.

Jack

L. Jack Staley

President

Stanford Group (Suisse) AG

Dreikonigstrasse 12

CH - 8002 Zurich, Switzerland

Tel. Nr.: +41.44.205.53.00

Fax Nr.: +41.44.205.53.06

Mary Zora

Director Human Resources-North America

Stanford Financial Group

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5051 Westheimer - 12th Floor

Houston, Texas 77056

Tel: 713-964-5276

Fax: 713-964-5284

HYPERLINK "mailto:[email protected]"[email protected]

_____

From: Schwarzentrub, Corinne Sent: Friday, June 15, 2007 8:51 AM To: Zora, Mary; Saldana, Virginia; Herman, Susan; Mercer, Sascha Cc: Gonsalves, Natasha Subject: FW: Training for our libyan guests

Mary, Virginia, Susan, Sascha

Please, since we do not have any corporate credit cards and the limit on the private cc are just to low, could you get organized with the pre billing of the expenses like hotels taxis an so on.

Since we need a final expense report, it would make sense, if Houston could do the whole coordination of the coast for the trip in America and Antigua.

Thank you so much

Corinne

Corinne Schwarzentrub

Teamleader Front Desk & Facility Services

Stanford Group (Suisse) AG

Dreikönigstrasse 12

8002 Zürich, Switzerland

Phone: +41 44 / 205 53 00

e-mail: HYPERLINK "mailto:[email protected]"[email protected]

Please note: This e-mail message transmission and any attachment herein may contain confidential information that may be legally privileged. If you are not the intended recipient, you must not review, retransmit, convert to hard copy, copy, use or disseminate this e-mail, fax or any attachments to it. If you have received this e-mail in error, please immediately notify us by return e-mail or by telephone at +41.44.205.5300 and delete this message. Please note that if this e-mail message contains a forwarded message or is a reply to a prior message, some or all of the contents of this message or any attachments may not have been produced by Stanford Group (Suisse) AG. This notice is automatically appended to each e-mail message leaving Stanford Group (Suisse) AG.

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