9 1 THU
9:25
MIKE
JUL 04 '91 08:32 07. 03. 91
BORSE & COHEN 852-5295035
12:47
PM
P
KINGSTON
169 P06
P06
し
In late June of 1989, Osman's legal advisers in Hong
!
Kong, inspected the Hong Kong court files relating to the Letters
of Request and were allowed to make
of the relevant allowed to make copies of documents filed in support of the application. Hong Kong counsel then requested of the Hong Kong Attorney Goneral that Osman be given notice of any discovery scheduled to be taken pursuant to the
Letters of Request.
i
In November 1989, Assistant United States Attorney Mark J. Stein ("Stein") of the Southern District of New York received copies of the Letters of Request issued by the Hong Kong court. On March 19, 1990, stein presented the Letters before the Honorable Vincent L. Broderick, who signed an order pursuant to 28 U.S.c. a "Commissioner to take steps as are I 1782 appointing Stein as necessary, including issuance of subpoenas to appear and to produce documents and physical avidance pursuant to Rule 17(0), Fad. R. Crim. P., and to obtain testimony and other evidence in conformity with the captioned Letter of Request; to submit all evidence
obtained in accordance herewith
Government of Hong Kong
to representatives of the
" In re Letter of Request from the
Government of Hong Kong, No. M19-117 (S.D.N.Y. Mar. 19, 1990) ("th
Maroh Order").
The order was filed under seal, but has bee
unsealed in the course of the instant motion.
In April 1990 Stein served Notices of Deposition upc
Ther
each of the banks designated in the Letters of Request. Notices stated that they were served "pursuant to Rule 30 (D) (6) (
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