· MAY 14 '92 19:47 CLIFFORD CHANCE HK 852 8184708

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extradition proceedings against Saniman between April and November 1987. Monnet stated that M. Chauvy had reviewed the witness statements we furnished to him and that he was the more appropriate person for us to deal with. Monnet told us that we should feel free to discuss the matter with M. Chauvy. He suggested we discuss the matter and the documentation with M. Chauvy because he would ultimately handle the case and was already somewhat familiar with it.

M. Chauvy asked me what the position was in relation to the other co- conspirators in Hong Kong and England. I explained that George Tan was on bail in Hong Kong and Shamsudin was presently serving a period of ten years imprisonment as a consequence of his pleading guilty to offences arising out of the transactions related to the Saniman case. I told him that Mr. Osman had appealed against the Magistrate's decision ordering his return to Hong Kong and that we had only just concluded the hearing of that appeal in the Divisional Court and were awaiting the judgment.

M. Chauvy thanked me for the witness statements and documentation and said he had read them carefully. It was apparent to me that indeed he had because of the number of flags and the amount of underlining that appeared on his copies. M. Chauvy explained that there was an important difference between the requirements of Article 6 and 7 of the Extradition Treaty of 1878. He said that Article 7 provided that the French authorities, when seeking extradition from the UK, were required to produce sufficient evidence and documents. He said Article 6 was the exact opposite and provided that a request made by UK for extradition from France by the UK Government did not have to include documents or statements of witnesses. All that was required was a clear and detailed summary of the evidence annexed to a diplomatic request. M. Chauvy explained that in relation to a request from France the question of evidence of a prima facie case does not arise. He said that the French Courts does not examine the foreign charges. M. Chauvy

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