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16.

Without objection, BBMB complied with the Order. BBMB selected from what would have been a universe of hundreds of thousands of documents which, in the exercise of its discretion, it had independently determined to fall within the categories in the 1986 Order. Thereafter, a Mr Clifford Howard

Allison, a Barrister and Crown Counsel from the HK Attorney General's

Chambers, inspected these documents. At the conclusion of his inspection, he

signed a declaration dated 2and December 1986 (pages 41-290, "AK 1").

17.

Mr Allison states at paragraph 2 (page 42, "AK 1") that he was

attaching as exhibit "CHA 1" a schedule of "all the documents I have perused

pursuant to the 4th November 1986 order". It will be noted from "CHA 1" (pages 44-260 "AK 1") that BBMB had selected 5,439 documents and/or files in

compliance with the Order, which Mr Allison carefully itemised. Exhibit "CHA 2" (pages 261-273, "AK 1") was a schedule listing documents then in evidence

before the UK Court. Mr Allison had examined the originals against copies

used in these proceedings and the results of his inspection (1.e. if the found additional pages to a document) were indicated in the 5th and 6th columns of

that schedule. Exhibit "CHA 3" (pages 274-290, "AK 1") contained additional

documents that Mr Allison considered to be material to the case. It should be

mentioned that a substantial portion of those documents produced by Mr.

Allison were heavily censored extracts, including Board minutes as to which I

had previously complained.

MY SUBSEQUENT REQUESTS FOR INSPECTION.

18.

Paragraph 6 of the Krishnan Affidavit refers to the correspondence

between Messrs Boase and Cohen and BBMB since early 1989 in respect of my

request to inspect certain documents. BBMB stated in their letters of 28th

March 1989 and 31st July 1990 (pages 29-30 and 38-39 respectively, "AK 1′′)

that Bank Negara had consented to my request for inspection, on the condition

that it was limited to the documents relating to the extradition which had

earlier been made available to the HK Attorney General's office. I therefore

had every expectation that I could inspect the documents listed in "CHA

1".

19.

On 10th September 1990, the date agreed by the parties for the

inspection, Mr Cohen attended BBMB's office to inspect the "CHA 1"

documents. He was informed by Na'imah bte Khalid, Manager of BBMB legal

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