Hong Kong, in a case involving a co-defendant, to be 14 years, although

in that case, it was discounted to 10 years because it was an Attorney

General's reference. A copy of the judgment in Attorney General -V-

Mohamed Hashim Shamsuddin is appended hereto as Appendix E.

16.

In these circumstances, we submit that it is not possible for the

Specialty Assurance to be honoured if Mr. Osman is extradited to Hong

Kong. Since such an assurance is fundamental to the law of extradition,

it is a most material consideration.

17.

Further, we would draw attention to the fact that the Specialty

Assurance does not now comply with section 6(4) of the EA because it

does not contain the exclusion provided for in section 6(5) of the EA.

This is apparent from an examination of these provisions and is a most

material consideration in the circumstances.

PREJUDICE AND UNFAIRNESS OF EVENTUAL TRIAL

18.

During the course of the 4th Application for Habeas Corpus, Mr. Osman's

solicitors, in preparation for his eventual trial in Hong Kong, sought

and obtained inspection of the documents

the documents which had previously been

produced to the Hong Kong Government on the basis

basis that they were

relevant to the committal proceedings against Mr. Osman in the Bow

Street Magistrates Court. As a result of the inspection, it was

discovered that some 65% of the 5,439 documents and/or files previously

produced to the Hong Kong Government were missing. This has never been

in dispute.

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