This criminal complaint alleges that Hassan Saied Keshari and Traian Bujduveanu conspired to export defense articles and U.S. goods to Iran without obtaining required licenses, in violation of federal export laws. Specifically, it alleges that from 2006 to present in Florida and elsewhere, the defendants agreed to (1) export defense articles without State Department licenses, and (2) export U.S. goods to Iran without Treasury Department authorization, violating federal statutes on arms exports and trade embargoes. An affidavit from an ICE agent provides further details in support of these allegations.
U. s. bureau of industry and security doj press release - april 9, 2009muculetz
Jeff Bush, Department of Justice, ICE Agent Sammy Cruzcoriano, Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, David Kris, Assistant Attorney General for National Security, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Government Conspiracy,Defense Criminal Investigative Service, R. Alexander Acosta, United States Attorney for the Southern District of Florida, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Christopher Amato, Special Agent in Charge of the Pentagon's Defense Criminal Investigative Service, Southeast Field Office, Revolution in Romania,R. Alexander Acosta, U.S. Attorney for the Southern District of Florida; David Kris, Assistant Attorney General for National Security; Michael Johnson, Special Agentin Charge, U.S. Department of Commerce, Office of Export Enforcement; Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations; and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Defense Criminal Investigative Service, Judge Patrick A. White, Judge Patricia A. Seitz, Judge John M. O’Sullivan, Attorney Mark Eiglarsh, Attorney Michael Cohen,C.I.A.,Defende Intelligence Agency,National Intelligence Agency,Department of State,Department of Navy,Interpol,F.B.I., National Security Agency, FBI Special Agent in Charge, Michael Johnson,Traian Bujduveanu,Revolution in Iran,Attorney Robert G. Amsel
United states’ motion in limine concerning united states munitions list deter...Cocoselul Inaripat
This document is a motion filed by the United States in a criminal case requesting that the court preclude the defendant from challenging the US State Department's determination that certain exported items were properly classified as "defense articles" on the United States Munitions List. The motion argues that (1) the Arms Export Control Act expressly prohibits judicial review of State Department determinations about items on the munitions list, (2) past precedent establishes that such determinations involve political questions reserved for the executive branch, and (3) allowing challenges would undermine the executive's authority over national security and foreign policy matters.
FindLaw | Holocaust Museum Shooting Suspect's Murder ChargesLegalDocs
This criminal complaint charges James Wenneker Von Brunn with two counts related to a shooting at the United States Holocaust Memorial Museum on June 10, 2009. According to the affidavit, Von Brunn drove to the museum armed with a rifle and shot and killed a security guard when he entered. He was then shot by other security guards and taken into custody. The complaint charges Von Brunn with first degree murder and killing in the course of possessing a firearm in a federal facility based on evidence that he planned and carried out the shooting.
This document summarizes a court case regarding a same-sex couple challenging California's Proposition 8, which banned same-sex marriage. The court granted California's motion to dismiss, finding that the plaintiffs lacked standing to challenge Proposition 8. Specifically, the court found that the plaintiffs did not demonstrate a concrete and particularized injury, or that their injury could be redressed by a favorable court decision, which are both requirements for standing. This was the second time the plaintiffs had brought similar challenges to the court regarding same-sex marriage bans.
This document provides discovery materials to the defendants in a criminal case involving charges related to exporting aircraft parts to Iran. It includes:
1) CDs and images of computer data seized from the defendants containing emails and files.
2) Reports of post-arrest interviews of the two defendants.
3) Notification that physical documents and items seized can be inspected by the defendants, and copies of documents ordered.
4) A request for reciprocal discovery from the defendants and commitment to provide ongoing discovery required by law, including Brady and Giglio materials.
This is the final judgment of Oriel Jean Oriel Jean — the former security chief of ex-President Jean-Bertrand Aristide and whose testimony in U.S. courts a decade ago helped take down key figures in Haiti’s drug trafficking underworld
In 2005, Jean was sentenced to three years in prison in a money-laundering plea deal after helping the U.S. Attorney’s Office convict several Haitians and Colombians of moving tons of Colombian cocaine through Haiti to the United States.
At Jean’s November 2005 sentencing, U.S. District Judge Jose Martinez complimented him for his “good work.” In his court testimony, Jean indirectly implicated former Haitian President Jean Bertrand Aristide and also testified against him before the grand jury.
Doj press release: defendant pleads guilty to conspiring to export military a...Cocoselul Inaripat
An Iranian national and his company pled guilty to conspiring to illegally export military aircraft parts to Iran. They purchased parts from a supplier in Florida and shipped them to Iran through Dubai, using false shipping documents. The parts were for aircraft in the Iranian military, including F-14 fighter jets. The defendant faces up to 5 years in prison and fines. The case is part of a larger initiative to crack down on illegal weapons exports.
Handgun fundamentals and safety training iirandystensaas
This document provides information about concealed carry handgun fundamentals and safety from a training course. It discusses:
- The qualifications, application process, costs, and validity period for obtaining a concealed carry permit in Wyoming.
- Where concealed firearms are not valid, including schools, government buildings, and places serving alcohol.
- Safety procedures for handling firearms, including always treating them as if loaded, keeping fingers off the trigger, and pointing the firearm in a safe direction.
- Types of revolvers and how to operate them safely, as well as potential malfunctions and their causes.
U. s. bureau of industry and security doj press release - april 9, 2009muculetz
Jeff Bush, Department of Justice, ICE Agent Sammy Cruzcoriano, Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, David Kris, Assistant Attorney General for National Security, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Government Conspiracy,Defense Criminal Investigative Service, R. Alexander Acosta, United States Attorney for the Southern District of Florida, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Christopher Amato, Special Agent in Charge of the Pentagon's Defense Criminal Investigative Service, Southeast Field Office, Revolution in Romania,R. Alexander Acosta, U.S. Attorney for the Southern District of Florida; David Kris, Assistant Attorney General for National Security; Michael Johnson, Special Agentin Charge, U.S. Department of Commerce, Office of Export Enforcement; Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations; and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Defense Criminal Investigative Service, Judge Patrick A. White, Judge Patricia A. Seitz, Judge John M. O’Sullivan, Attorney Mark Eiglarsh, Attorney Michael Cohen,C.I.A.,Defende Intelligence Agency,National Intelligence Agency,Department of State,Department of Navy,Interpol,F.B.I., National Security Agency, FBI Special Agent in Charge, Michael Johnson,Traian Bujduveanu,Revolution in Iran,Attorney Robert G. Amsel
United states’ motion in limine concerning united states munitions list deter...Cocoselul Inaripat
This document is a motion filed by the United States in a criminal case requesting that the court preclude the defendant from challenging the US State Department's determination that certain exported items were properly classified as "defense articles" on the United States Munitions List. The motion argues that (1) the Arms Export Control Act expressly prohibits judicial review of State Department determinations about items on the munitions list, (2) past precedent establishes that such determinations involve political questions reserved for the executive branch, and (3) allowing challenges would undermine the executive's authority over national security and foreign policy matters.
FindLaw | Holocaust Museum Shooting Suspect's Murder ChargesLegalDocs
This criminal complaint charges James Wenneker Von Brunn with two counts related to a shooting at the United States Holocaust Memorial Museum on June 10, 2009. According to the affidavit, Von Brunn drove to the museum armed with a rifle and shot and killed a security guard when he entered. He was then shot by other security guards and taken into custody. The complaint charges Von Brunn with first degree murder and killing in the course of possessing a firearm in a federal facility based on evidence that he planned and carried out the shooting.
This document summarizes a court case regarding a same-sex couple challenging California's Proposition 8, which banned same-sex marriage. The court granted California's motion to dismiss, finding that the plaintiffs lacked standing to challenge Proposition 8. Specifically, the court found that the plaintiffs did not demonstrate a concrete and particularized injury, or that their injury could be redressed by a favorable court decision, which are both requirements for standing. This was the second time the plaintiffs had brought similar challenges to the court regarding same-sex marriage bans.
This document provides discovery materials to the defendants in a criminal case involving charges related to exporting aircraft parts to Iran. It includes:
1) CDs and images of computer data seized from the defendants containing emails and files.
2) Reports of post-arrest interviews of the two defendants.
3) Notification that physical documents and items seized can be inspected by the defendants, and copies of documents ordered.
4) A request for reciprocal discovery from the defendants and commitment to provide ongoing discovery required by law, including Brady and Giglio materials.
This is the final judgment of Oriel Jean Oriel Jean — the former security chief of ex-President Jean-Bertrand Aristide and whose testimony in U.S. courts a decade ago helped take down key figures in Haiti’s drug trafficking underworld
In 2005, Jean was sentenced to three years in prison in a money-laundering plea deal after helping the U.S. Attorney’s Office convict several Haitians and Colombians of moving tons of Colombian cocaine through Haiti to the United States.
At Jean’s November 2005 sentencing, U.S. District Judge Jose Martinez complimented him for his “good work.” In his court testimony, Jean indirectly implicated former Haitian President Jean Bertrand Aristide and also testified against him before the grand jury.
Doj press release: defendant pleads guilty to conspiring to export military a...Cocoselul Inaripat
An Iranian national and his company pled guilty to conspiring to illegally export military aircraft parts to Iran. They purchased parts from a supplier in Florida and shipped them to Iran through Dubai, using false shipping documents. The parts were for aircraft in the Iranian military, including F-14 fighter jets. The defendant faces up to 5 years in prison and fines. The case is part of a larger initiative to crack down on illegal weapons exports.
Handgun fundamentals and safety training iirandystensaas
This document provides information about concealed carry handgun fundamentals and safety from a training course. It discusses:
- The qualifications, application process, costs, and validity period for obtaining a concealed carry permit in Wyoming.
- Where concealed firearms are not valid, including schools, government buildings, and places serving alcohol.
- Safety procedures for handling firearms, including always treating them as if loaded, keeping fingers off the trigger, and pointing the firearm in a safe direction.
- Types of revolvers and how to operate them safely, as well as potential malfunctions and their causes.
FindLaw | Court of Appeals Reverses Entry Bar to Islamic ScholarLegalDocs
This document summarizes a United States Court of Appeals case regarding the denial of a visa for Tariq Ramadan, an Islamic scholar. The three organizational plaintiffs claimed the denial violated their First Amendment right to have Ramadan share his views in the US. The government denied the visa because Ramadan had contributed funds to a charity that supported Hamas, which the government deemed material support to a terrorist organization. The Court of Appeals concluded that the consular officer who denied the visa did not properly confront Ramadan with the allegations, which prevented Ramadan from demonstrating that he did not know the charity supported terrorism. The Court vacated the decision and remanded the case for further proceedings.
This document is a court opinion from the United States Court of Appeals for the Ninth Circuit regarding an executive order issued by President Trump imposing restrictions on entry into the US from several majority-Muslim countries. The court found that while the President has broad authority to control immigration, his actions in issuing the executive order exceeded the scope of authority delegated by Congress. Specifically, the President did not make a sufficient finding that entry of these classes of people would harm national interests, as required by law. The court also found the order violated other provisions of immigration law prohibiting nationality-based discrimination and requiring certain processes for refugee caps. The court affirmed the lower court's preliminary injunction of sections of the executive order on these statutory grounds.
This document summarizes a 1996 appellate court case regarding the removal of a wrongful death lawsuit to federal court. The lawsuit was filed in Alabama state court against an airplane engine manufacturer and inspector over a plane crash in France. The defendants removed the case to federal court under the Federal Officer Removal Statute. The appellate court upheld the removal, finding the inspector was acting as a federal officer in certifying the plane's engine as airworthy. It also found the district court did not abuse its discretion in dismissing the case based on forum non conveniens, as most witnesses and evidence were located in France.
49 u.s.c. § 46504 – interference with flight crewMichael Pariente
49 u.s.c. § 46504 – interference with flight crew is a federal crime and this is some information about how the law originated in different bits of case law involving diminished capacity and crimes of intent.
Bankruptcy Attorney Houston | 09/09/2005 Special Session ActHelixSEO
Plaintiff Chapter 7 debtor filed a motion for summary judgment on his claim that defendant creditor should be judicially estopped from asserting charges that could have been, but were not, included in its proof of claim filed in debtor’s previous bankruptcy case.
Ex-CIA John Kiriakou Complaint-Affidavit-Releaseglobalnewsuk
Ex-CIA agent John Kiriakou charged over leaks : An ex-CIA agent leaked the names of other covert operatives to the media, the US justice department said.
John Kiriakou is accused of disclosing the names of agents who interrogated a suspected al-Qaeda financier, who was allegedly waterboarded 83 times.
Prosecutors say the probe started after lawyers for suspected terrorists filed a legal brief including details not provided by the government.
Mr Kiriakou, 47, will appear in court in Alexandria, Virginia, on Monday.
He is suspected of leaking classified information to reporters, who in turn provided information to the defence teams of the suspected terrorists.
During a recent interview with the FBI, Mr Kiriakou denied releasing the identity of classified agents, according to a sworn affidavit.
In particular, Mr Kiriakou was asked whether he released to the New York Times in 2008 the name of an officer who helped interrogation of the suspected al-Qaeda financier, Abu Zubaydah.
Mr Kiriakou responded: "Heavens no," according to the affidavit.
Waterboarding revelation
Information about the interrogation, which took place in 2002, was classified at the time.
Mr Zubaydah was detained in Pakistan in 2002 and his case has been used as an example by critics of waterboarding as an interrogation technique.
The affidavit also alleges that photographs of the CIA agent who was involved in the interrogations were found in possession of Guantanamo Bay detainees.
In 2007, Mr Kiriakou said in an interview with ABC News that waterboarding had been used to break down Mr Zubaydah. He later worked as a consultant for the US news network.
He is also charged with lying to the CIA in order to publish a book, entitled The Reluctant Spy: My Secret Life in the CIA's War on Terror.
Mr Kiriakou was an agent with the CIA between 1990 and 2004.
"Safeguarding classified information, including the identities of CIA officers involved in sensitive operations, is critical to keeping our intelligence officers safe and protecting our national security,'' US Attorney General Eric Holder said, calling it a "solemn duty" not to reveal classified information.
COUNT 4 - CONSPIRACY TO MURDER (For UIE...Criminal Complaint)VogelDenise
17 USC § 107 Limitations on Exclusive Rights – FAIR USE
CONFEDERATE STATES OF AMERICA’S A/K/A UNITED STATES OF AMERICA’S CONFEDERATES, KU KLUX KLAN, WHITE SUPREMACISTS/ZIONISTS CONSPIRE TO HAVE THE UTICA INTERNATIONAL EMBASSY’S INTERIM PRIME MINISTER VOGEL DENISE NEWSOME ASSASSINATED AND/OR MURDERED
MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "At...Louis Charles Hamilton II
This document is a motion filed by Louis Charles Hamilton II (the plaintiff) requesting a temporary restraining order and order to freeze the documents, records, and assets of defendant Antoine L. Freeman (an attorney) and co-defendants Joyce Guy and Edward McCray. The motion alleges that the defendants committed fraud, obstruction of justice, and violated RICO statutes in relation to civil suit number A-180805. It requests that the court issue orders prohibiting the destruction of records and freezing the defendants' assets until the case is resolved.
This document lists acceptable forms of primary identification that can be used in conjunction with a secondary ID to gain access to certain military installations, in accordance with Installation Access Control Policy JBM-HH 190-16. It provides over 20 options for primary IDs, including passports, military IDs, government employee IDs, driver's licenses, immigration documents, tribal IDs, and original birth certificates. The listed IDs must contain a photo and personal details to be used for NCIC-III/VCIN vetting at entry points to Fort Myer and Henderson Hall in Virginia or Fort McNair in Washington, D.C.
TNT Dinar - TNT Tony Court Sentencing Documents Tony Renfrow 14 Daily PlusIraqi Dinar News
Here are the TNT Tony court documents following his sentencing on 11/30/2015 for the 14dailyplus.com ponzi scheme. Tony's brother Raymond Renfrow (RayRen98 / RayRay) has been conducting the TNT Dinar calls in Tony's absense. Tony is not permitted to make any calls or to even use social media. Court transcripts will be release soon. Court case 2:12-cr-20041.
Follow this Slideshare channel for updates. Please share this presentation. Thanks to Sherif for showing up at the courthouse to confront Tony before his sentencing.
BIA Remands of Immigration Judge William Cassidy 01/01/2014-05/26/2016Bryan Johnson
EOIR FOIA ID # 2016-23184. Also, see acknowledgment letter at following link: http://www.slideshare.net/abogadobryan/eoir-acknowledgment-letter-for-201623284
U.S. Supreme Court Order On The Travel Ban Appeals, June 26, 2017Honolulu Civil Beat
The Supreme Court granted certiorari and partially stayed injunctions blocking enforcement of Executive Order 13780, which suspended entry of nationals from six Muslim-majority countries. Lower courts had issued nationwide preliminary injunctions, finding the order likely violated the Establishment Clause. The Supreme Court's partial stay allows the 90-day travel ban to take effect but exempts foreigners with bona fide relationships with U.S. entities or individuals. Oral arguments will be heard in the fall on the constitutionality of the executive order.
Le FBI autorisé par la Cour Suprême à pirater n'importe quel PCMarket iT
The document is a letter from Chief Justice John Roberts to Speaker of the House Paul Ryan and President of the Senate Joseph Biden transmitting proposed amendments to the Federal Rules of Criminal Procedure that were adopted by the Supreme Court. The letter provides the text of the amendments to Rules 4, 41, and 45. The amendments relate to arrest warrants and summonses, search warrants for remote access to electronic storage media, and computing time after certain kinds of service. Accompanying materials submitted to the Court for its consideration are also listed.
1. Plaintiff was sentenced to 35 months for conspiracy related to emergency economic programs. He was assigned to a halfway house operated by Defendant Dimas Charities.
2. Dimas Charities was aware of Plaintiff's medical conditions but did not properly accommodate him. They placed strict restrictions on his phone use against the conditions of his home confinement.
3. Plaintiff requests the Court issue an order clarifying the conditions of his home confinement regarding phone use to comply with BOP policy. He argues Dimas Charities exceeded their authority over a federal prisoner.
Motion for extension of time to file expert witness disclosuresCocoselul Inaripat
The defendant filed a motion for an extension of time to file expert witness disclosures. The defendant is charged with multiple counts related to violating the Iran embargo and arms export control acts, which require expert testimony. The government disclosed some expert witnesses on December 17th but the disclosure was incomplete. The defense needs additional time to hire experts and file disclosures once the government provides a full disclosure. The motion requests extending the deadline to disclose experts by 30 days after the government's full disclosure, as well as extending the deadline to file motions to dismiss until after reviewing the expert disclosures.
This document is a court docket listing events in the civil case "Bujduveanu v. Ginspert et al" from its filing in January 2011 through May 2011. It notes that the plaintiff filed an initial motion for return of property and later an amended complaint against multiple defendants. It also records the assignment of magistrate judges and orders requiring the joint scheduling report and payment of filing fees. The docket reflects motions filed by the pro se plaintiff regarding appointment of counsel and extensions of time.
Defendants dismas charties, inc., ana gispert, derek thomas and lashanda adam...Cocoselul Inaripat
This document contains the statement of undisputed facts submitted by the defendants in support of their motion for summary judgment in the case of Traian Bujduveanu v. Dismas Charities, Inc. et al. It outlines 33 facts regarding the plaintiff's criminal conviction and transfer to a halfway house operated by Dismas Charities, the rules and policies he acknowledged, and his violations of possessing an unauthorized cell phone and driving without permission which led to his transfer back to prison.
The document is a brief filed by defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas, and Adams Leshota (incorrectly identified) in response to the plaintiff's motion to compel discovery responses. The defendants argue that they have properly responded to the plaintiff's requests for production and interrogatories. They provided the requested documents for inspection at their counsel's office and responded to all interrogatories. The defendants assert that the plaintiff's discovery requests seek irrelevant personal information and appear aimed at harassment rather than the case issues. They request that the plaintiff's motion to compel be denied.
This document is a report and recommendation from a Magistrate Judge regarding a motion to dismiss filed by the defendants in a civil case. The plaintiff, Traian Bujduveanu, filed suit against Dismas Charities and several employees alleging violations of his constitutional rights and various torts related to his confinement at a halfway house run by Dismas Charities. The report provides background on the plaintiff's claims and requested relief. It is recommended that the defendants' motion to dismiss be granted.
This document is a response brief filed by defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas, and Adams Leshota in response to the plaintiff's motion to strike the defendants' response brief to the plaintiff's motion to compel discovery responses. The defendants argue that the plaintiff has provided no valid legal basis to strike their response brief. They assert they properly responded to all discovery requests and the plaintiff is merely trying to force them to change their answers to be more favorable to the plaintiff's case. The defendants request that the plaintiff's motion be denied and sanctions be granted against the plaintiff.
This document provides an undisputed statement of facts in support of a motion for summary judgment. It states that the plaintiff pled guilty to conspiring to illegally export military parts and was sentenced to 35 months, which he served partly at Dismas Charities halfway house. It details the rules plaintiff agreed to, including no unauthorized driving or cell phones. It states that on October 13, 2010 plaintiff drove himself to Dismas and a cell phone was found, violating the rules, so he was returned to prison to complete his sentence.
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
FindLaw | Court of Appeals Reverses Entry Bar to Islamic ScholarLegalDocs
This document summarizes a United States Court of Appeals case regarding the denial of a visa for Tariq Ramadan, an Islamic scholar. The three organizational plaintiffs claimed the denial violated their First Amendment right to have Ramadan share his views in the US. The government denied the visa because Ramadan had contributed funds to a charity that supported Hamas, which the government deemed material support to a terrorist organization. The Court of Appeals concluded that the consular officer who denied the visa did not properly confront Ramadan with the allegations, which prevented Ramadan from demonstrating that he did not know the charity supported terrorism. The Court vacated the decision and remanded the case for further proceedings.
This document is a court opinion from the United States Court of Appeals for the Ninth Circuit regarding an executive order issued by President Trump imposing restrictions on entry into the US from several majority-Muslim countries. The court found that while the President has broad authority to control immigration, his actions in issuing the executive order exceeded the scope of authority delegated by Congress. Specifically, the President did not make a sufficient finding that entry of these classes of people would harm national interests, as required by law. The court also found the order violated other provisions of immigration law prohibiting nationality-based discrimination and requiring certain processes for refugee caps. The court affirmed the lower court's preliminary injunction of sections of the executive order on these statutory grounds.
This document summarizes a 1996 appellate court case regarding the removal of a wrongful death lawsuit to federal court. The lawsuit was filed in Alabama state court against an airplane engine manufacturer and inspector over a plane crash in France. The defendants removed the case to federal court under the Federal Officer Removal Statute. The appellate court upheld the removal, finding the inspector was acting as a federal officer in certifying the plane's engine as airworthy. It also found the district court did not abuse its discretion in dismissing the case based on forum non conveniens, as most witnesses and evidence were located in France.
49 u.s.c. § 46504 – interference with flight crewMichael Pariente
49 u.s.c. § 46504 – interference with flight crew is a federal crime and this is some information about how the law originated in different bits of case law involving diminished capacity and crimes of intent.
Bankruptcy Attorney Houston | 09/09/2005 Special Session ActHelixSEO
Plaintiff Chapter 7 debtor filed a motion for summary judgment on his claim that defendant creditor should be judicially estopped from asserting charges that could have been, but were not, included in its proof of claim filed in debtor’s previous bankruptcy case.
Ex-CIA John Kiriakou Complaint-Affidavit-Releaseglobalnewsuk
Ex-CIA agent John Kiriakou charged over leaks : An ex-CIA agent leaked the names of other covert operatives to the media, the US justice department said.
John Kiriakou is accused of disclosing the names of agents who interrogated a suspected al-Qaeda financier, who was allegedly waterboarded 83 times.
Prosecutors say the probe started after lawyers for suspected terrorists filed a legal brief including details not provided by the government.
Mr Kiriakou, 47, will appear in court in Alexandria, Virginia, on Monday.
He is suspected of leaking classified information to reporters, who in turn provided information to the defence teams of the suspected terrorists.
During a recent interview with the FBI, Mr Kiriakou denied releasing the identity of classified agents, according to a sworn affidavit.
In particular, Mr Kiriakou was asked whether he released to the New York Times in 2008 the name of an officer who helped interrogation of the suspected al-Qaeda financier, Abu Zubaydah.
Mr Kiriakou responded: "Heavens no," according to the affidavit.
Waterboarding revelation
Information about the interrogation, which took place in 2002, was classified at the time.
Mr Zubaydah was detained in Pakistan in 2002 and his case has been used as an example by critics of waterboarding as an interrogation technique.
The affidavit also alleges that photographs of the CIA agent who was involved in the interrogations were found in possession of Guantanamo Bay detainees.
In 2007, Mr Kiriakou said in an interview with ABC News that waterboarding had been used to break down Mr Zubaydah. He later worked as a consultant for the US news network.
He is also charged with lying to the CIA in order to publish a book, entitled The Reluctant Spy: My Secret Life in the CIA's War on Terror.
Mr Kiriakou was an agent with the CIA between 1990 and 2004.
"Safeguarding classified information, including the identities of CIA officers involved in sensitive operations, is critical to keeping our intelligence officers safe and protecting our national security,'' US Attorney General Eric Holder said, calling it a "solemn duty" not to reveal classified information.
COUNT 4 - CONSPIRACY TO MURDER (For UIE...Criminal Complaint)VogelDenise
17 USC § 107 Limitations on Exclusive Rights – FAIR USE
CONFEDERATE STATES OF AMERICA’S A/K/A UNITED STATES OF AMERICA’S CONFEDERATES, KU KLUX KLAN, WHITE SUPREMACISTS/ZIONISTS CONSPIRE TO HAVE THE UTICA INTERNATIONAL EMBASSY’S INTERIM PRIME MINISTER VOGEL DENISE NEWSOME ASSASSINATED AND/OR MURDERED
MOTION TO FREEZE DOCUMENTS, ASSETS, OF DEFENDANT ANTOINE L. FREEMAN J.D., "At...Louis Charles Hamilton II
This document is a motion filed by Louis Charles Hamilton II (the plaintiff) requesting a temporary restraining order and order to freeze the documents, records, and assets of defendant Antoine L. Freeman (an attorney) and co-defendants Joyce Guy and Edward McCray. The motion alleges that the defendants committed fraud, obstruction of justice, and violated RICO statutes in relation to civil suit number A-180805. It requests that the court issue orders prohibiting the destruction of records and freezing the defendants' assets until the case is resolved.
This document lists acceptable forms of primary identification that can be used in conjunction with a secondary ID to gain access to certain military installations, in accordance with Installation Access Control Policy JBM-HH 190-16. It provides over 20 options for primary IDs, including passports, military IDs, government employee IDs, driver's licenses, immigration documents, tribal IDs, and original birth certificates. The listed IDs must contain a photo and personal details to be used for NCIC-III/VCIN vetting at entry points to Fort Myer and Henderson Hall in Virginia or Fort McNair in Washington, D.C.
TNT Dinar - TNT Tony Court Sentencing Documents Tony Renfrow 14 Daily PlusIraqi Dinar News
Here are the TNT Tony court documents following his sentencing on 11/30/2015 for the 14dailyplus.com ponzi scheme. Tony's brother Raymond Renfrow (RayRen98 / RayRay) has been conducting the TNT Dinar calls in Tony's absense. Tony is not permitted to make any calls or to even use social media. Court transcripts will be release soon. Court case 2:12-cr-20041.
Follow this Slideshare channel for updates. Please share this presentation. Thanks to Sherif for showing up at the courthouse to confront Tony before his sentencing.
BIA Remands of Immigration Judge William Cassidy 01/01/2014-05/26/2016Bryan Johnson
EOIR FOIA ID # 2016-23184. Also, see acknowledgment letter at following link: http://www.slideshare.net/abogadobryan/eoir-acknowledgment-letter-for-201623284
U.S. Supreme Court Order On The Travel Ban Appeals, June 26, 2017Honolulu Civil Beat
The Supreme Court granted certiorari and partially stayed injunctions blocking enforcement of Executive Order 13780, which suspended entry of nationals from six Muslim-majority countries. Lower courts had issued nationwide preliminary injunctions, finding the order likely violated the Establishment Clause. The Supreme Court's partial stay allows the 90-day travel ban to take effect but exempts foreigners with bona fide relationships with U.S. entities or individuals. Oral arguments will be heard in the fall on the constitutionality of the executive order.
Le FBI autorisé par la Cour Suprême à pirater n'importe quel PCMarket iT
The document is a letter from Chief Justice John Roberts to Speaker of the House Paul Ryan and President of the Senate Joseph Biden transmitting proposed amendments to the Federal Rules of Criminal Procedure that were adopted by the Supreme Court. The letter provides the text of the amendments to Rules 4, 41, and 45. The amendments relate to arrest warrants and summonses, search warrants for remote access to electronic storage media, and computing time after certain kinds of service. Accompanying materials submitted to the Court for its consideration are also listed.
1. Plaintiff was sentenced to 35 months for conspiracy related to emergency economic programs. He was assigned to a halfway house operated by Defendant Dimas Charities.
2. Dimas Charities was aware of Plaintiff's medical conditions but did not properly accommodate him. They placed strict restrictions on his phone use against the conditions of his home confinement.
3. Plaintiff requests the Court issue an order clarifying the conditions of his home confinement regarding phone use to comply with BOP policy. He argues Dimas Charities exceeded their authority over a federal prisoner.
Motion for extension of time to file expert witness disclosuresCocoselul Inaripat
The defendant filed a motion for an extension of time to file expert witness disclosures. The defendant is charged with multiple counts related to violating the Iran embargo and arms export control acts, which require expert testimony. The government disclosed some expert witnesses on December 17th but the disclosure was incomplete. The defense needs additional time to hire experts and file disclosures once the government provides a full disclosure. The motion requests extending the deadline to disclose experts by 30 days after the government's full disclosure, as well as extending the deadline to file motions to dismiss until after reviewing the expert disclosures.
This document is a court docket listing events in the civil case "Bujduveanu v. Ginspert et al" from its filing in January 2011 through May 2011. It notes that the plaintiff filed an initial motion for return of property and later an amended complaint against multiple defendants. It also records the assignment of magistrate judges and orders requiring the joint scheduling report and payment of filing fees. The docket reflects motions filed by the pro se plaintiff regarding appointment of counsel and extensions of time.
Defendants dismas charties, inc., ana gispert, derek thomas and lashanda adam...Cocoselul Inaripat
This document contains the statement of undisputed facts submitted by the defendants in support of their motion for summary judgment in the case of Traian Bujduveanu v. Dismas Charities, Inc. et al. It outlines 33 facts regarding the plaintiff's criminal conviction and transfer to a halfway house operated by Dismas Charities, the rules and policies he acknowledged, and his violations of possessing an unauthorized cell phone and driving without permission which led to his transfer back to prison.
The document is a brief filed by defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas, and Adams Leshota (incorrectly identified) in response to the plaintiff's motion to compel discovery responses. The defendants argue that they have properly responded to the plaintiff's requests for production and interrogatories. They provided the requested documents for inspection at their counsel's office and responded to all interrogatories. The defendants assert that the plaintiff's discovery requests seek irrelevant personal information and appear aimed at harassment rather than the case issues. They request that the plaintiff's motion to compel be denied.
This document is a report and recommendation from a Magistrate Judge regarding a motion to dismiss filed by the defendants in a civil case. The plaintiff, Traian Bujduveanu, filed suit against Dismas Charities and several employees alleging violations of his constitutional rights and various torts related to his confinement at a halfway house run by Dismas Charities. The report provides background on the plaintiff's claims and requested relief. It is recommended that the defendants' motion to dismiss be granted.
This document is a response brief filed by defendants Dismas Charities, Inc., Ana Gispert, Derek Thomas, and Adams Leshota in response to the plaintiff's motion to strike the defendants' response brief to the plaintiff's motion to compel discovery responses. The defendants argue that the plaintiff has provided no valid legal basis to strike their response brief. They assert they properly responded to all discovery requests and the plaintiff is merely trying to force them to change their answers to be more favorable to the plaintiff's case. The defendants request that the plaintiff's motion be denied and sanctions be granted against the plaintiff.
This document provides an undisputed statement of facts in support of a motion for summary judgment. It states that the plaintiff pled guilty to conspiring to illegally export military parts and was sentenced to 35 months, which he served partly at Dismas Charities halfway house. It details the rules plaintiff agreed to, including no unauthorized driving or cell phones. It states that on October 13, 2010 plaintiff drove himself to Dismas and a cell phone was found, violating the rules, so he was returned to prison to complete his sentence.
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Two munitions dealers arrested and charged in conspiracy to export military a...muculetz
Jeff Bush, Department of Justice, ICE Agent Sammy Cruzcoriano, Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, David Kris, Assistant Attorney General for National Security, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Government Conspiracy,Defense Criminal Investigative Service, R. Alexander Acosta, United States Attorney for the Southern District of Florida, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Christopher Amato, Special Agent in Charge of the Pentagon's Defense Criminal Investigative Service, Southeast Field Office, Revolution in Romania,R. Alexander Acosta, U.S. Attorney for the Southern District of Florida; David Kris, Assistant Attorney General for National Security; Michael Johnson, Special Agentin Charge, U.S. Department of Commerce, Office of Export Enforcement; Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations; and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Defense Criminal Investigative Service, Judge Patrick A. White, Judge Patricia A. Seitz, Judge John M. O’Sullivan, Attorney Mark Eiglarsh, Attorney Michael Cohen,C.I.A.,Defende Intelligence Agency,National Intelligence Agency,Department of State,Department of Navy,Interpol,F.B.I., National Security Agency, FBI Special Agent in Charge, Michael Johnson,Traian Bujduveanu,Revolution in Iran,Attorney Robert G. Amsel
Two munitions dealers arrested and charged in conspiracy to export military a...Cocoselul Inaripat
Two munitions dealers, Hassan Saied Keshari and Traian Bujduveanu, were arrested and charged with conspiring to export military aircraft parts from the United States to Iran in violation of export laws. The parts were obtained in the U.S. and shipped through Dubai to buyers in Iran and included components for helicopters and fighter jets. Both men made initial court appearances and face statutory maximum sentences of up to 20 years in prison and fines of up to $1 million if convicted.
Doj press release: defendant pleads guilty to conspiring to export military a...Cocoselul Inaripat
Hassan Saied Keshari and his corporation Kesh Air International pled guilty to conspiring to illegally export military aircraft parts from the US to Iran. As part of the conspiracy, Keshari purchased parts designed for military aircraft like F-14 fighter jets and Cobra helicopters from a supplier in Florida and shipped them to Iran through the UAE, violating US export laws and sanctions against Iran. Keshari faces up to 5 years in prison and a $250,000 fine.
The document is a detention order for Traian Bujduveanu, who is charged with conspiracy to export military parts to Iran without proper licensing. At a hearing, the court determined no bail conditions would reasonably assure his appearance at trial given: 1) the substantial evidence against him, 2) his extensive international business and travel ties, and 3) his ties to Romania, making him a flight risk. As a result, the court ordered him detained pending trial.
The document is a detention order for Traian Bujduveanu, who is charged with conspiracy to export military parts to Iran without proper licensing. At a hearing, the court determined no bail conditions would reasonably assure his appearance at trial given: 1) Substantial evidence against him including shipments of helicopter and fighter jet parts to Iran; 2) His ties to Romania as a naturalized citizen whose girlfriend is Romanian; and 3) Risk he could flee to Romania or continue his international aviation business abroad. The court ordered him detained pending trial.
§ 2339C PROHIBITIONS AGAINST THE FINANCING OF TERRORISMVogelDenise
17 USC § 107 Limitations on Exclusive Rights – FAIR USE
§ 2339C PROHIBITIONS AGAINST THE FINANCING OF TERRORISM
The title speaks for itself. Nevertheless, we are posting this information as EVIDENCE of one of the Statutes/Laws under which we will be moving forward and seeking INTERNATIONAL Intervention as a result of the United States DESPOTISM Government Regime’s/Organization’s UNLAWFUL and ILLEGAL SEIZURE of the United States of America’s Government!
We look forward to Legally and Lawfully obtaining INTERNATIONAL Assistance as we move forward to BUILDING a NEW GOVERNMENT that will PROTECT the Natives and Blacks/Negroes/African-Americans/People-Of-Color residing within the Lands/Territories NOW known as the United States of America FROM the NAZI and/or WHITE Jews/Zionists/Supremacists that have INFILTRATED and/or HIJACKED the United States of America’s Government and are PRESENTLY holding this PROTECTED Group of People HOSTAGE and subjecting them to GENOCIDAL practices for purposes of ADVANCING the WHITE Man’s Agenda to MAKE the WHITE Race Supreme OVER “ALL” other Races, etc.
To support the work of Community Activist Vogel Denise Newsome DONATIONS may be made at:
www.Cash.me/$VogelDeniseNewsome or
CONFIDENTIAL/ANONYMOUS DONATIONS AT:
https://donorbox.org/community-activist-vogel-denise-newsome
With PEACE & LOVE,
Community Activist Vogel Denise Newsome
Post Office Box 31265
Jackson, Mississippi
(513) 680-2922
Doj press release: defendant pleads guilty to conspiring to export military a...Cocoselul Inaripat
Hassan Saied Keshari and his corporation Kesh Air International pled guilty to conspiring to illegally export military aircraft parts from the United States to Iran. Keshari purchased parts for aircraft in the Iranian military, including the F-14 fighter jet, and exported them to Iran through freight forwarders in Dubai in violation of U.S. embargoes and arms export regulations. The parts included items exclusively for military use that required State Department licenses. Keshari faces up to 5 years in prison and a $250,000 fine, while his corporation faces a maximum $500,000 fine.
USA vs. Joe Rickey Hundley, by US District Court for N. GeorgiaUmesh Heendeniya
Joe Ricky Hundlely is accused of assaulting a 2-year old child on a Delta Airlines flight from Minneapolis to Atlanta. According to witness statements, Hundlely told the child's mother to shut her "N word" baby up, then turned and slapped the crying child in the face, leaving a scratch below his eye. This occurred while the plane was in the special aircraft jurisdiction of the United States, violating federal assault statutes.
This document outlines an agreement for protecting classified information. It states that the agreement is consistent with and does not alter existing executive orders and laws regarding employee obligations and rights to disclose information. It also incorporates the definitions, requirements, and liabilities from those executive orders and statutes. The individual signing acknowledges reading the agreement and having executive orders and statutes referenced in the agreement made available to them.
Cia director grandiosity v. abilt justicePublicLeaks
This document is a declaration by John Brennan, Director of the Central Intelligence Agency, asserting the state secrets privilege and CIA statutory privileges to prevent disclosure of classified information in a lawsuit brought by a former CIA employee. Brennan asserts these privileges to protect information about specific CIA intelligence operations, the identities and roles of covert employees, and sources and methods. He argues that disclosure of such information could reasonably be expected to cause serious or grave damage to national security.
This document provides discovery materials to the defendants in a criminal case involving charges related to exporting aircraft parts to Iran. It includes:
1) CDs and images of computer data seized from the defendants containing emails and files.
2) Reports of post-arrest interviews of the two defendants.
3) Notification that physical documents and items seized can be inspected by the defendants, and copies of documents ordered.
4) A request for reciprocal discovery from the defendants and commitment to provide ongoing discovery required by law.
Hassan saied keshari, traian bujduveanu charged in conspiracy to export milit...Cocoselul Inaripat
Two men, Hassan Saied Keshari and Traian Bujduveanu, were charged with conspiring to export US military aircraft parts to Iran in violation of export laws. They obtained parts for helicopters and fighter jets from US suppliers and shipped them to Iran through Dubai to conceal the illegal exports. The parts included items for the CH-53, F-14, and AH-1 military aircraft. Both defendants were arrested and charged with illegally exporting defense articles and violating sanctions against Iran.
Hassan saied keshari, traian bujduveanu charged in conspiracy to export milit...Cocoselul Inaripat
Two men, Hassan Saied Keshari and Traian Bujduveanu, were charged with conspiring to export US military aircraft parts to Iran in violation of export laws. They obtained parts for helicopters and fighter jets from US suppliers and shipped them to Iran through Dubai to conceal the illegal exports. The parts included items for the CH-53, F-14, and AH-1 military aircraft. Both defendants were arrested and charged with illegally exporting defense articles and violating sanctions against Iran.
Hassan saied keshari, traian bujduveanu charged in conspiracy to export milit...muculetz
Jeff Bush, Department of Justice, ICE Agent Sammy Cruzcoriano, Jeffrey H. Sloman, Acting United States Attorney for the Southern District of Florida, David Kris, Assistant Attorney General for National Security, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Government Conspiracy,Defense Criminal Investigative Service, R. Alexander Acosta, United States Attorney for the Southern District of Florida, Michael Johnson, Special Agent in Charge, U.S. Department of Commerce, Office of Export Enforcement, Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations, and Christopher Amato, Special Agent in Charge of the Pentagon's Defense Criminal Investigative Service, Southeast Field Office, Revolution in Romania,R. Alexander Acosta, U.S. Attorney for the Southern District of Florida; David Kris, Assistant Attorney General for National Security; Michael Johnson, Special Agentin Charge, U.S. Department of Commerce, Office of Export Enforcement; Anthony V. Mangione, Special Agent in Charge, U.S. Immigration and Customs Enforcement, Office of Investigations; and Amie R. Tanchak, Resident Agent in Charge, U.S. Department of Defense, Defense Criminal Investigative Service, Judge Patrick A. White, Judge Patricia A. Seitz, Judge John M. O’Sullivan, Attorney Mark Eiglarsh, Attorney Michael Cohen,C.I.A.,Defende Intelligence Agency,National Intelligence Agency,Department of State,Department of Navy,Interpol,F.B.I., National Security Agency, FBI Special Agent in Charge, Michael Johnson,Traian Bujduveanu,Revolution in Iran,Attorney Robert G. Amsel
BIA Remands of Immigration Judge Michael Baird from 01/01/2014 to 05/26/2016Bryan Johnson
- The respondent, a native and citizen of Zimbabwe, appealed the denial of her applications for withholding of removal and cancellation of removal by the Immigration Judge.
- The Board upheld the finding that she did not show the government of Zimbabwe was unable or unwilling to protect her from persecution. However, the case was remanded for further consideration of her application for cancellation of removal based on the passage of time.
- On remand, the parties were instructed to further address issues such as good moral character, hardship if relocated to Zimbabwe, and whether relief should be granted as a matter of discretion based on an updated record.
The defendants filed a motion to dismiss the indictment charging them with violating export control laws. They argue that the language of the US Munitions List regulating the export of military equipment is unconstitutionally vague and does not provide fair notice of what requires an export license. Specifically, the list does not enumerate the exact parts the defendants were charged with exporting. This violates the due process requirement that criminal statutes define the prohibited conduct clearly. The defendants therefore could not have known their actions were illegal.
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
The document discusses the results of a study on the effects of exercise on memory and thinking abilities in older adults. The study found that regular exercise can help reduce the decline in thinking abilities that often occurs with age. Older adults who exercised regularly performed better on cognitive tests and brain scans showed they had greater activity in important areas for memory and learning compared to less active peers.
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Just...Cocoselul Inaripat
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Criminals into the US Federal Government Offices,The Most Corrupted Country In the World,Democracy Propaganda
Traian Bujduveani 1,Corruption inside US Government,Corruption of the US Justice System,Election of Crominals into the US Federal Government Offices,The Most Corrupted Country In the World
The United States government conducted a large raid involving over 30 agents from numerous agencies on Traian Bujduveanu's residence to seize assets. The lead prosecutors claimed in court that the assets were worth over $100,000, but they ended up being less than $10,000 in value, consisting of antique aircraft parts. The massive raid was unnecessary and terrorized Bujduveanu's 84-year-old blind mother, who was sent to the hospital. Witnesses state that Bujduveanu had been under surveillance for over a year before the raid. The government's actions seem aimed at justifying the expenses of the investigation rather than appropriately addressing the matter.
This document lists the names of various government agencies and individuals, including Jeb Bush, the Department of Justice, ICE agents, US Attorneys, Assistant Attorney Generals, FBI agents, and others. It also references concepts like government conspiracies, revolutions in Romania and Iran, corruption in government, and crimes against humanity.
1. ' A 91 (Rev. 5/85) Criminal Complaint (AUSA Damian)
United States District Court
SOUTHERN DISTRICT OF FLORIDA
UNITED STATES OF AMERICA
v.
CRIMINAL COMPLAINT
HASSAN SAIED KESHARI
and
TRAIAN BUJDUVEANU,
Defendants
I, the undersigned complainant, being duly sworn, state the following is true and correct to the best of
my knowledge and belief. From In or about August 2006 and continuing to the present, In Miami-Dade
County and Broward County, in the Southern District of Florida, and elsewhere, the defendants,
HASSAN SAIED KESHARI and TRAIAN BUJDUVEANU, did knowingly and willfully combine, conspire,
confederate, and agree with each other and with others to commit offenses aga~nst United States,
the
that is, (1) to export from the United States defense articles for which a license IS required without first
obtaining the required license or written approval from the Department of State, in v~olation Title 22,
of
United States Code, Section 2778, and Title 22, Code of Federal Regulations, Sections 121. I , 123.1,
and 127.1, and (2) to export and cause to be exported U.S. made goods from the United States to the
Islamic Republic of Iran without having first obtained the required authorizations from the Office of
Foreign Assets Control, in violation of Title 50, United States Code, Sections 1702 and 1705(b), and
Title 31, Code of Federal Regulations, Section 560;
all in violation of Title 18, United States Code, Section 371.
I further state that I am a Special Agent with the Bureau of Immigration and Customs Enforcement and that this
complaint is based on the following facts:
SEE ATTACHED AFFIDAVIT OF SPECIAL AGENT SAMMY CRUZCORIANO.
fl
Continued on the attached and made a part hereof:
Sworn to before me, and subscribed in my presence,
&-('i- d d 5
2
Date
PATRICK A. WHITE
United States Maqistrate Judqe [-
Name and Title of Judicial Officer Signature of ~=ial Officer
2. AFFIDAVIT
I, Special Agent Sammy Cruzcoriano, being first duly sworn, state as follows:
I. PERSONAL BACKGROUND
I. I am a Special Agent with the United States Department of Homeland
Security, Immigration and Customs Enforcement ("ICE"), Counter Proliferation
Investigations Unit (CPI) and have been so employed since December 2002. 1 am a
graduate of the Immigration Officer Basic Training Course and the Criminal Investigator
Training Program at the Federal Law Enforcement Training Center. I am responsible for
conducting investigations for alleged violations of the Immigration and Customs laws of
the United States.
2. As a Special Agent with ICE, I am familiar with and have received training
regarding federal laws specifically related, but not limited to, the unlawful export of
goods and technology from the United States, as specified in the Arms Export Control
Act, 22 U.S.C. $3 2751, er seq.; the Export Administration Act, 50 U.S.C. $9 2401, e f
seq.; and the International Emergency Economic Powers Act, 50 U.S.C. §$ 170 1, el seq.
3. I am also familiar with related federal laws 'and the interpretation and
application of federal laws and federal court procedures, and I have previously conducted
and assisted in the execution of numerous federal arrest and search warrants. I have
conducted and participated in investigations of violations of United States laws relating to - .
-- . -
the unlawful export from the United States of goods and technology restricted for export
for reasons of national security, foreign policy, anti-terrorism, and embargoed
- destinations, and I am empowered to make arrests in connection with such violations.
3. 4. I make this affidavit based upon my (a) personal observations and knowledge;
(b) conversations with other law enforcement agents who have participated in this
investigation; and (c) review of documents connected with the investigation. Because
this affidavit is being submitted for the limited purpose of establishing probable cause to
arrest HASSAN SAIED KESHARI (herein referred to as "KESHARI") and TRAIAN
BUJDUVEANU (herein referred to as "BUJDUVEANU"), 1 have not included details of
every aspect of this investigation of which I am aware. As set forth below, there is
probable cause to believe KESHARl and BUJDUVEANU did knowingly and willfully
combine, conspire, confederate, and agree with each other and with others to commit
offenses against the United States, that is (1) to export from the United States defense
articles for which a license is required without first obtaining the required licenses or
written approval from the Department of State, in violation of the Arms Export Control
Act ("AECA"), Title 22, United States Code, Sections 2778(b)(2) and (c), and Title 22,
Code of Federal Regulations, Sections 121.1, 123.1, and 127.1, and (2) to export and
cause the exportation of goods from the United States to the Islamic Republic of Iran in
violation of the embargo imposed upon that country by the Uriited States, without having
first obtained the required licenses or authorizations from the Office of Foreign Assets
Control ("OFAC"), in violation of the International Emergency Economic Powers Act
("IEEPA"), Title 50, United States Code, Sections 1702 and 1705(a), and the United -- _
States Treasury Department's Office of Foreign Assets Control ("OFAC")
comprehensive trade and investment embargo against Iran under the authority, inter alia,
of IEEPA, as amended, Section 505 of the International Security and Development
Cooperation Act of 1885, Executive Order 13059 of August 19, 1 997, which consolidates
4. the provisions of Executive Orders 12613, 12957, and 12959, and the Iranian
Transactions Regulations ("ITR") promulgated thereunder, principally, Title 3 1, Code of
Federal Regulations, Parts 560.203 and 560.204; all in violation of Title 18, United States
Code, Section 371
11. THE APPLICABLE LAW AND REGULATIONS
A. ARMS EXPORT CONTROL ACT
5. The AECA authorizes the President of the United States to, among other
things, control the export of "defense articles." 22 U.S.C. 5 2778(a)(l). AECA also gives
the President the authority to designate items as "defense articles." As a practical matter,
that task is performed by the U.S. Department of State ("DOS"), with concurrence of the
U.S. Department of Defense ("DOD"), in accordance with regulations promulgated by
DOS, Directorate of Defense Trade Controls ("DDTC"), (formerly known as the Office
of Defense Trade Controls). 22 U.S.C. 5 2778(a)(2); 22 C.F.R $5 120.l(a), 120.2. All
items designated as "defense articles" are identified by category on the United States
Munitions List ("USML"), a document prepared by DDTC. 22 U.S.C. 5 2778(a)(l); 22
C.F.R. 120.02.
6. Anyone who is a manufacturer, exporter, importer, or broker of any "defense
article" (collectively, "defense article exporter") is required to register with DDTC. 22
U.S.C. 2778(b)(l)(A); 22 C.F.R. $120.l(a). It is a crime for any defense article exporter
--
to willfully fail to register with DDTC. 22 U.S.C. 5 2778(c); 22 C.F.R. 5127.3. Moreover,
all defense article exporters are required to obtain a valid export license from DDTC for
any "defense article", regardless of its value, before the article is exported to another
country. 22U.S.C. $ 2778(b)(2); 22 C.F.R. 5 123(a). It is a crime for any defense article
5. exporter to wilIfulIy fail to obtain an export license before exporting a "defense article" to
another country. 22 U.S.C. 5 2778(c); 22 C.F.R. 5 127.I(a)(l).
B. THE UNITED STATES IRANIAN TRADE EMBARGO
7. The President of the United States, by virtue of the IEEPA, is granted
authority to deal with unusual and extraordinary threats to the national security and
foreign policy of the United States. On March 15, 1995, the President of the United
States, following previously issued Executive Orders, continued to declare a national
emergency with respect to the Islamic Republic of Iran ("Iran"), finding the policies and
actionseof Iran constitute a threat to the national security of the United States due to Iran's
support of international terrorism and its attempts to acquire weapons of mass
destruction.
8. On May 6, 1995, the President declared a trade embargo against Iran and
prohibited the exportation from the United States to lran of any goods, technology, or
services, with limited exceptions for publications, other informational material, and
donated articles, such as medical supplies intended to relieve human suffering. On
August 17, 1997, the President reiterated and renewed 'the Iran Embargo, which
continued throughout the time of the events of this affidavit.
9. To implement the U.S. Iran Embargo, the United States Department of
Treasury ("Department of Treasury"), through the Office of Foreign Assets Control
("OFAC"), issued the Iranian Transactions Regulations (3 1 C.F.R. $$ 560.203-560.205)
("ITR") in September 1995. These regulations prohibit the export of goods from the
United States to Iran unless authorized by the Department of Treasury. The regulations
further prohibit any transactions evading or avoiding the U.S. lran Embargo, including
6. the exportation of goods from the United States to a third country if the goods are
intended or destined for Iran. Violation of the U.S. Iran Embargo is a federal felony
offense punishable by up to twenty years' imprisonment. See 50 U.S.C. 5 1705(b) and 3 1
C.F.R. § 560.204.
Ill. PROBABLE CAUSE
A. BACKGROUND
10. The individuals who are the subject of this affidavit are known to
investigators as "HASSAN SAIED KESHARI" and "TRAIAN BUJDUVEANUv. As set
forth below, KESHARI and BUJDUVEANU have conspired to export U.S. commodities
to individuals and entities who provide these same U.S. manufactured goods to
individuals and entities in Iran, in violation of the AECA, IEEPA, and the U.S. Iran Trade
Embargo.
11. The team of investigators from ICE, OEE, and DCIS, including your affiant,
are conducting ongoing investigations which have identified numerous networks of
individuals and entities in Iran which are engaged in the business of illegally procuring
U.S. manufactured commodities for customers and end-users in Iran. These
investigations have revealed that these Iranian procurement networks use suppliers
located throughout the world, including suppliers in the United States, to obtain the U.S.
commodities. The investigations have also revealed that the networks of individuals and
- --
entities engaged in the illegal procurement of goods often use email accounts hosted by
U.S. based ISPs and IHPs in furtherance of their illegal procurement activities. Thus, a
large part of the ongoing investigation of illegal Iranian procurement networks has
focused on email communications regarding the illegal exports and shipments of U.S.
commodities to Iran.
7. B. THE KESh%IR@CMAIL.COM EMAIL ACCOUNT
12. In the course of analyzing evidence obtained during the course of this
investigation, investigators learned of KESHARI and his U.S. based business, KESH
AIR INTERNATIONAL, located in Novato, California, and identified KESHARI as a
U.S. based supplier for ultimate buyers and recipients in Iran. The majority of the
evidence upon which investigators learned about KESHARI was found in emails seized
during the execution of federally authorized search warrants. This evidence reveals that
KESHARI has been using the KESHAIRBGMAIL. COM and
S.KESHARI@WORLDNET.ATT.NET email accounts in furtherance of his work of
brokering and supplying U.S. commodities for Iranian customers. Investigators found
that these two email accounts used by KESHARI were the recipient or sender for
thousands of emails related to discussions concerning the procurement of U.S.
commodities, including commercial and military aircraft parts for Iranian customers. The
KESHAIR@GMAIL.COM email account, in particular, is hosted by the California based
internet hosting provider ("IHP") Google, Inc. and is registered to SAIED KESHARI.
13. During the review of evidence found 'during searches of the
KESHAIRBGMAIL account, investigators found evidence of many purchases, sales,
and shipments of U.S. made commodities from aircraft parts suppliers located in Miami
Dade and Broward Counties.
14. A typical example of the transactions between KESHARI and his suppliers is
reflected in an April 2008 shipment from a Miami based supplier in response to a
purchase order from KESHARI on behalf of KESH AIR. The series of emails discovered
in KESHARIysKESHAIR@GMAIL.COM account reveals an April 18, 2008, email to the
8. Miami based supplier with an attachment that contains a purchase order for 3 "vertical
gyros" (an aircraft part). The purchase order reflects the sale by the Miami based
supplier with a "ship to" address of KESH AIR, 35 Pamaron Way, Ste A, Novato, CA
94949 via UPS. A subsequent email, on May 19, 2008, was sent from KESHARI's
KESHAIK@GMAIL.COM to a company located in Iran using an email address
registered to the Iranian company. The May 19, 2008, email contains an attachment with
an invoice for the sale of the 3 vertical gyros from KESH AIR to a company in Dubai,
United Arab Emirates.
15. As noted above, investigators have found hundreds of communications
between KESHARI and Miami Dade and Broward based suppliers of aircraft parts
regarding purchases, sales, and shipments of U.S. made goods from these Miami Dade
and Broward suppliers to KESH AIR and its representatives.
C. THE ORIONAV@MSN.COM EMAlL ACCOUNT
16. In the course of analyzing the evidence obtained during searches of the
KESHAIR@GMAIL.COM email account, investigators noted approximately 857 emails
were sent between KESHAIR@GMAIL.COM and ORIONAV@MSN.COM during the
period of January 8,2007, through May 2 1,2008.
17. The ORIONAV@MSN.COM email account is hosted by the California based
internet service provider ("ISP") Microsoft Networks and registered to a business - --
identified as ORION AVIATION CO. and the individual named TRAIAN
BUJDUVEANU, with a listed address of 5601 W. Broward Blvd, Plantation, Florida.
Records checks reveal ORION AVIATION CORPORATION was a registered
corporation in the state of Florida, with a listed AgentfOfficer as BUJDUVEANU, but
7
9. that the corporation is currently inactive. Internet research reveals that ORION has been
active in the business of brokering aircraft parts for many years. All of the
approximately 857 emails between KESHARI and BUJDUVEANU discuss the purchase
and/or delivery of various U.S. manufactured commodities, including commercial and
military aviation parts. Additionally, the majority of these emails involve requests for
quotes ("RFQ7's) which originate from Iranian individuals or entities.
18. For example, investigators recovered a series of emails among
KEkS'HAIK@GIZ.D1IL.
COM, ORIONA V@MW.COM, and two Yahoo! email addresses.
Investigative research of the two Yahoo! email addresses, which will be referred to
throughout this affidavit as Yahoo! address 1 and Yahoo! address 2, reveals that they are
both registered to separate individuals located in Iran. Both of these Yahoo! accounts
have been identified during this investigation as being used for the purpose of acquiring
U.S. commodities on behalf of entities in Iran. Both of these Yahoo email accounts use
internet protocol ("IP") addresses which are registered to an ISP in 'Tehran, Iran.
19. This particular email series began on May 17, 2007, with the first email sent
from Yahoo! address 1 to KESHAZR@GMIL.COM with a. listed subject of "perches
order". This email is written in Farsi and has three Word document attachments: "Perches
order 7008.doc", "Perches order 7035.doc", and "Perches order 7040.doc." The
attachment pertinent to this particular email chain is number 7008. This document reads: - --
"Perches order ...RFQ: 7008 ...Top urgent". The document then lists seven items by
name, P/N [part number], S/N [serial number], quantity, condition and price. Of the seven
listed items, the following three items are relevant to this discussion: P/N 65103-1 1003-
102, P/N 2433, and P/N 65 103-1 1004-082. Investigators researched these specific listed
10. part numbers and found that P/N 65 103-11003-102 is an aircraft diaphragm seal used on
the CH-53E military helicopter and is only manufactured by two companies: Sikorsky
Aircraft Corporation, headquartered in Strafford, Connecticut, and SKF USA Inc.,
located in Eglin, Illinois. The CH-53E military helicopter is known to be part of the
Iranian military fleet. P/N 2433 is an internal wrenching bolt manufactured by Eaton
Aerospace LLC, located in Jackson, MS. And, P/N 65103-1 1004-082 is listed as a
discontinued part number (cancelled by the U.S. Navy).
20. On May 22, 2007, KESHAIR@GMAIL.COM sent an email to
ORIONA V@MSN. COM and Iisted all seven part numbers from the May 17, 2007, email
sent to KESHARI from Yahoo! address 1, discussed above. On May 22, 2007,
BUJDUVEANU, using ORIONAV@MSN.COM, responded to KESHARl at
KESHAIR@GMAIL.COMand quoted six of the seven listed part numbers, including P/N
65103-1 1003-102 (the diaphragm seal) at $458.00 each, P/N 2433 (the wrenching bolt) at
$ 87.00 each, and P/N 65 103-1 1004-082 (the discontinued item) at $462.00 each.
21. On May 22, 2007, a follow up email was sent from KESHAIR@GMAIL.COM
to ORIONAV@MSN.COM in which KESHARI advises BUJDUVEANU: "I will be
sending you a p.0. [purchase order] for the following parts.. ." KESHARI then lists three
of the seven parts for which he had received a quote from BUJDUVEANU: 65103-
11003-102; 2433 bolt; and 65103-1 1004-082 seal (the three discussed in the preceding
paragraph).
22. In a June 8, 2007, email from KESHAIR@GMAIL.COM to
ORIONAV@MSN.COM, KESHARI advises, "I am going to the bank to send you some
money for the order on rfq 7008 around $14k." Then, on June 19, 2007, three emails
11. were exchanged between KESHAIR@GMAIL. COM and ORIONA V@MSN COM in
which BUJDVEANU provides two Federal Express tracking numbers and advises he
shipped "ALL PARTS IN 7008." Investigators believe the "7008" BUJDVEANU is
referencing is the "Perches order 7008.doc" discussed above. Subsequently, on that same
date, June 19, 2007, an email was sent from KESHAIR@GMAIL.COM to Yahoo! address
1 and Yahoo! address 2. This email is in Farsi and provides the two Federal Express
tracking numbers previously given by BUJDVEANU to KESHARI.
23. Federal Express shipping documents obtained pursuant to subpoenas served
on Federal Express reveal that the first shipment was sent on June 16, 2007, from ORION
AVIATION CO, at 5601 N. Broward Blvd, Plantation FL 33317, to Planet Commercial
Brokerage, in Dubai, United Arab Emirates ("UAE"), and arrived on June 24, 2007. The
second shipment was sent on June 18, 2007, from ORION AVIATION CO to Planet
Commercial Brokerage in Dubai and arrived on June 24, 2007.
24. Investigators know that at least one of these particular shipments from
ORION subsequently reached KESHARI's Iranian client and their customer in Iran
because of an email sent on August 15, 2007, from Yahoo! address 1 to
KESHAIR@GMAIL.COM with a subject of "rfq;7008..seal". This email is written in
Farsi and has one portable document format ("pdf') attachment. The pdf document
reads: ". ..REFERING TO YOUR INVOICE NO:7017/008 DATED 19/JUNE/07, ---
- --
PLEASEBE INFORMED THAT L/1 (SEAL-65 103-1 1004-082)IS REJECTED
BECAUSE OF THE ISSED ITEMS ARE USED AND REWORKED, PLEASE CHECK
THE MATTERAND ADVISE BY RETURN FAX URGENTLY. SINCERELY YOURS
D.M.D FOR COMM AFFAIRS FOR A-MIGHANI".
12. 25. Subsequently, on August 16, 2007, KESHARI, using
KESHAIR@GMAIL.COM, sent an email to ORIONAV@MSN.COM to advise that he
(KESHARI) had received an email "from our customer stating that the IOea P/N 65103-
11004-082 which you provided were reworked and worked on? Could you please look
into this and give me some explanation so I can get back to them."
26. Thus, it is apparent that these items requested by KESHARI on behalf of his
Iranian clients and supplied and exported by ORION were procured for and sent to Iran.
As explained above, the sale and export of these items to individuals andlor entities in
Iran without a license from OFAC constitutes a violation of the IEEPA and the U.S. Iran
Trade Embargo.
27. Moreover, DOS records inquiries have determined that P/N 65 103-1 1003-102
(the aircraft diaphragm seal used by the CH-53E military helicopter) is designated on the
U.S. Munitions List as a "defense article" (Category VIII(h)). Therefore. any export of
this item requires a license from the DOS. Further records checks reveal that neither
ORION AVIATION CORPORATION, BUJDUVEANU, KESH AIR
WTERNATIONAL, nor KESHARI are or were registered with the DDTC nor have any
been issued a license to export U.S. Munitions List Articles from the United States.
28. Another example of BUJDUVEANU7s work with KESHARI to procure
U.S. commodities for individuals and entities in Iran is seen in a series of emails among
KESHAIR@GMIL. COM, S.KESHARI@ WORLDNET.ATT~NE?, Yahoo! address 1.
Yahoo! address 2, ORlONAV@MSN.COM, and a Google Gmail address registered to an
individual located in Iran. The first email in this series was sent on April 23, 2008, from
The s.keshari@wor/dnet.att.net email account is a secondary account used by KESHARI to conduct
business. This email account appears to be an older account.
13. KESHAIR@GMIL.COM to ORIONAV@MSN.COM with the subject listed as "any
news." In this email KESHARl writes to BUJDUVEANU: "1 have not heard back from
you in regards to the parts you supplied and the information I provided you. Please let me
know where we stand on that. Should I ask them to send them back."
29. Investigators researched this email and discovered it refers to an RFQ email
originally sent on January 25, 2007, from Yahoo! address 1 to
S. KESHARI@ WORLDNETATT.NET. That emai! has one attachment, titled
" 101032 1 .doc." This attachment lists six items by name, part number, and S/N. The first
part number relevant to this series of emails is a "Harness assy," P/N 080-037-001 and
S/N 15600142643 1. Investigative research reveals that the listed part number is a harness
assembly for the F-14 fighter aircraft and is manufactured by the Parker Hannifin
Corporation, an American company headquartered in Cleveland, Ohio.
30. The next email in this series was sent on January 29, 2007, from
S. KESHARI@ W0RLDNET.A TT.NET to Yahoo! address 1, with a cc: to Yahoo! address
2, and is titled "101 0321". This email is written in a combination of Farsi and English
and appears to be a quote in response to RFQ 1010321. In this email, KESHARI quotes
the prices for the six items listed in the original RFQ. The part number relevant to this
series of emails is listed as "5ea 080-037-001 harness NS $5,500.00". In this email,
KESHARI refers to "Orion", leading investigators to believe that ORION AVIATION -
CORPORATION is the supplier for this particular part. Investigators then reviewed a
subsequent email sent on February 14, 2007, from Yahoo! address 1 to
KESHAIR@GMAIL. COM, titled "Purchase order 1010321". This email has one
attachment, titled "Purchase order 10 10321.docn. This attachment lists six items by
14. name, P/N, quantity, condition, price, and RFQ number. The first listed part number is
relevant to this series of emails and refers to a "Harness assy", P/N 080-037-001, with a
quantity of five ordered in "NS" condition for $5,500.00. Then, on March 5, 2007,
S.KESHARI@WORLDNET.ATTNET sent an email to Yahoo! address 1, with a cc: to
Yahoo! address 2 with a subject: "Fw: FedEx I Track 10321". This email is written in a
combination of Farsi and English, and, in it, KESHARI mentions "ORION" and
"# 1032 1", referring to the same purchase order discussed above (investigators have noted
that the parties intermittently drop the first two numbers - here the initial "10" - when
referencing purchase order and RFQ numbers) and provides a hyperlink to a Federal
Express tracking number. Investigators obtained the Federal Express shipment records
for the given tracking number pursuant to a subpoena to Federal Express. The shipping
documents indicate that on March 3, 2007, a package, with the contents listed as
"Aircraft Parts Cable" and a country of manufacture listed as "U.S.A.", was sent from
ORION AVIATION CO to Behnam Fattahi, Planet Commercial Brokerage, in Dubai,
UAE. The shipment arrived on March 9, 2007, and Fattahi accepted delivery.
3 1. Investigators also found an invoice referencing this particular part (080-037-
001) and referring to it as "HARNESS ASSY." The invoice is one of several attachments
to an April 15, 2007, email from Yahoo! address 1 to KESHAIR@GUAIL.COM with the
subject of "invoice". The emaiI is written in Farsi and has ten pdf attachments.
According to the attached invoice, which is on KESH AIR letterhead, the part was sold
for $5,400.00 each, for a total price of $27,000.00, from KESH AIR INTERNATIONAL
CORP. to Planet Commercial Brokerage LLC in Dubai. The invoice also indicates that
the items were "SHIPPED FROM ORION AVIATION."
15. 32. Investigators located numerous other emails regarding this transaction,
including a March 29, 2008, email from the GmaiI account, referenced above, used by
another individual located in Iran, to KESHAIR@GMAIL.COM with a subject line of
"harness, rfq 1010321 ." This email is written in Farsi and has two picture attachments
titled "harness I.jpeg" and "harness 2.jpeg". The picture attachments show a parts
diagram with two highlighted sections and a parts sheet titled " NAVAIR 01 -F14AAA-4-
7", with one part circled, the "...080-037-00 1 HARNESS ASSEMBLEY /26055/
/GRUMMAN ..." This title refers to the Grumman F-14A jet fighter. Additionally, there
is an F-14 Flight Manual, printed in April of 1984, titled NAVAIR 01 -F14AAA-1, and
investigators believe this attachment may be a page from this F-14 flight manual.
According to the manufacturer of the F-14, Grumman, the listed part, 080-037-001, is
part of the fuel quantity measurement system specific for the F- 14. Further investigative
research shows that Iran is a primary user of the F-14 (also known as the "Tomcat").
33. Investigators also found an email in this chain which was sent on March
3 1, 2008. from KESHAIR@GMAIL. C O M to ORZONA V@MSN. COM with the subject
"harness, rfq 101032 1 ". In this email, KESHARI advises BLT'JDUVEANU, "Attached as
per your request is the information on the Harness which we purchased 5 of them and
there were the wrong parts." To this email, KESHARI attaches the same two picture files
supplied to KESHARI on March 29,2008, by the Iranian client discussed above.
34. Thus, it is again apparent that these items requested by KESHARI on behalf
of his Iranian clients and supplied and exported by ORION were procured for and sent to
Iran. As explained above, the sale and export of these items to individuals andor entities
16. in Iran without a license from OFAC constitutes a violation of the IEEPA and the U.S.
Iran Trade Embargo.
35. Moreover, DOS records inquiries have determined that P/N 080-037-001 (the
harness assembly for the F-14 fighter aircraft) is designated on the U.S. Munitions List as
a "defense article" (Category VIII(h)). Therefore, any export of this item requires a
license from the DOS. As stated above, further records checks reveal that neither
ORION AVIATION CORPORATION, BUJDUVEANU, KESH AIR
INTERNATIONAL, nor KESHARI are or were registered with the DDTC nor have any
been issued a license to export U.S. Munitions List Articles from the United States.
36. Through investigative research, your affiant has determined that each of the
parts at issue in the above-discussed chains of emails is used exclusively for military
aircraft. Moreover these particuIar parts are designed for military aircraft known to those
familiar with the aircraft industry to be used by the Iranian military. BUJDUVEANU
has been in this (the aviation and aircraft) industry for at least twenty years, and your
affiant is confident that BUJDUVEANU knows that these parts are for Iranian military
aircraft.
37. It is also worth noting that investigators have also reviewed emails in which
BUJDUVEANU quotes prices to KESHARI for parts for other military aircraft,
including, specifically, the F-4 (Phantom) aircraft. This aircraft is commonly known in - -
the aviation industry to be used almost exclusively by the Iranian military. And,
investigators have reviewed evidence of negotiations and sales by BUJDUVEANU to
KESHARI for parts for the AH-1 Attack hellicopter, another military aircraft well-known
for its use by the Iranian military.
17. 38. Finally, in a string of emails back and forth between BUJDUVEANU and
KESHARI, the two discuss an RFQ from KESHARI to BUJDUVEANU for other aircraft
parts originally requested by KESHAR17s Iranian customer discussed above. In that
string, in a May 14, 2007, email, BUJDUVEANU responds to an email from KESHARI
in which KESHARI references his clients, and BUJDUVEANU states that, with respect
to KESHARI'S client, "[B)y the way Mr. Keshari, I have meet with these people a while
ago, and they do have the original drawings, and they also paid you in advance ..." Your
affiant believes that, in this email, BUJDUVEANU is telling KESHARI that he
(BUJDUVEANU) has met KESHAR17S Iranian clients. This bolsters investigators7
belief that BUJDUVEANU knows that he is quoting parts that will be exported to Iran.
39. Although investigators are aware of recent emails from KESHARI to
BUJDUVEANU, there appears to have been a breakdown in communication between the
two. However, it does appear that KESHARI and KESHARI's Iranian clients believe
that BUJDUVEANU owes them money for what KESHARI has described as faulty parts
sent by BUJDUVEANU, and, for that reason, KESHARI appears to continue to attempt
to reach BUJDUVEANU by email.
IV. CONCLUSION
40. Based on the forgoing, your affiant submits that there is probable cause to
believe that from in or before August 2006 to the present, KESHARI and
BUJDUVEANU did knowingly and willfully combine, conspire, confederate and agree
with each other and with others to commit offenses against the United States, that is ( I )
to export from the United States defense articles for which a license is required without
first obtaining the required licenses or written approval from the Department of State, in
18. violation of AECA, 22 U.S.C. $9 2778(b)(2) and (c), and 22 C.F.R. $5 121.1, 123.1 and
127.1, and (2) to export and cause the exportation of goods from the United States to Iran
in violation of the U.S. Iran embargo, without having first obtained the required licenses
or authorizations from OFAC, in violation of IEEPA, 50 U.S.C. $5 1702 and 1705(a),
and OFAC7s comprehensive trade and investment embargo against Iran under the
authority, inter alia, of IEEPA, as amended, Section 505 of the International Security and
Development Cooperation Act of 1885, Executive Order 13059 of August 19, 1997,
which consolidates the provisions of Executive Orders 12613, 12957, and 12959, and the
ITR promulgated thereunder, principally, 31 C.F.R. $5 560.203 and 560.204; all in
/-.,
violation of 18 U.S.C. $ 371. /
0AMM CRUZCORIANO
d p ~ ~Agent
~6l
United States Department of Homeland Security
Immigration and Customs Enforcement ("ICE"),
PATRICK A. WHITE
UNITED STATES MAGISTRATE JUDGE
SOUTHERN DISTRICT OF FLORIDA