1.-

Robert S. MINTON, an American national, resides at 137 Fremont Road, Sandown, New Hampshire 03873, USA. Holds an American passport as well as an Irish passport, and frequently travels to Switzerland, England and Turkey.

His wife is Therese S. MINTON, residing at 39 West Cedar St., Boston, Massachusetts 02114, USA.

2.-

In the mid 1980s the INTERNATIONAL MONETARY FUND and the WORLD BANK required that the continuation of their assistance to NIGERIA (restructuring of credits, new loans, etc.) depended on a reduction of the external debts of that country.

At that time the contracts between Nigeria and international creditors and debt holders had strict guidelines and clauses regarding the purchasing of NIGERIAN debt without respecting the equality of the creditors of the same rank.

3.-

In this frame, Robert MINTON conceived and executed a secret fraudulent plan from 1987 to 1993 of buying debts by diverting considerable funds coming from the CENTRAL BANK OF NIGERIA and the NIGERIAN NATIONAL PETROLEUM CORPORATION (NNPC).

4.-

According to this plan, Robert MINTON and his accomplices established and used several special purpose corporations for the purchasing of debts of NIGERIA (Bank debt, Government debt, promissory notes).

5.-

Having at their his disposal a confidential list identifying the principal owners of the debts, Robert MINTON and his corporations then contacted them directly with the purpose of convincing them that the NIGERIAN government would never refund them and obtained from the majority of them the transfer of the debt at a low price.

6.-

These acquisitions were financed with funds directly from the CBN and NNPC.

The corporations of Robert MINTON then increased these debts to higher prices to the CENTRAL BANK OF NIGERIA and resulted in several millions of dollars more in commissions and fees.

The CENTRAL BANK OF NIGERIA bought the debts for several million of dollars more, being defrauded by not being provided with the actual costs to the corporations of Mr. MINTON.

7.-

In this context, GML INTERNATIONAL Ltd (previously GROWTH MANAGEMENT Ltd) established in London by Robert MINTON (Att. 1-2), played a central role as financial advisors.

MINTON has been separated from that corporation since 1991.

Other corporations were established and utilized by MINTON, specifically:

 

A. GREENLAND HOLDINGS Inc., Panama. B. SHAMROCK FINANCIAL CORPORATION, established in Sandown / Salem, New Hampshire, USA, January 30, 1991 (Att. 3) C. GREENCLAD Ltd established in London June 30, 1986 (Att. 4) of which the corporate name was changed on June 30, 1986 to GROMAN FORFAITING Ltd. The corporation was dissolved in December 1989 (Att. 5). D. TRIOLET INTERNATIONAL Inc, established in Boston, Massachusetts, September 13, 1988 and which merged on December 31, 1990 with TRIOLET INTERNATIONAL Ltd (Att. 6-7). E. TRIOLET INTERNATIONAL Ltd. established in Manchester, New Hampshire on December 21, 1980 and dissolved in May 1998 (Att. 8). F. ARGYLE KENT Ltd London.

8.-

The two corporations TRIOLET INTERNATIONAL and SHAMROCK FINANCIAL acquired debts owed by NIGERIA for a total of $5 billion in nominal value between 1988 and 1993. Debts of nominal value of several hundreds of millions of dollars were specifically acquired from BCCI.

9.-

Very likely the intermediary transfer of debts between firms permitted the raise of costs of acquisition fictionally.

10.-

With letter of January 15, 1992 signed by Robert MINTON, SHAMROCK FINANCIAL CORPORATION confirmed to the CENTRAL BANK OF NIGERIA the acquisition of bank debt for an amount of $1,200,000,000 (and that for the benefit of the Central Bank of Nigeria). (Att. 9)

11.-

The detailed accounting of the operations for GREENLAND HOLDING INC. also indicates the purchase of debts from March 1988 to December 1991 for more than one billion dollars.

This accounting shows a list of owners of the debt from whom they were bought, the nominal value as well as the Cost to GREENLAND which represents in each case between 25% and 45% of their nominal value. (Att. 10)

We know however that most of the debts had been obtained at a very low price and the alleged Cost to GREENLAND provided by MINTON to the CENTRAL BANK OF NIGERIA was false. The records of intermediary bankers or Debt Traders permit to establish the insider trading which escalated the price, And increased undisclosed fees and commissions.

12.-

In Geneva, Robert MINTON deposited the diverted funds in different bank accounts which were opened for corporations as well as his personal accounts operated with codes.

13.-

ROBERT MINTON and his wife opened several accounts specifically for GREENLAND HOLDINGS, at the DISCOUNT BANK AND TRUST COMPANY, 1-3 quai de l'Ile, 1204 Geneva.

MINTON was introduced to this bank by M. Jozef BICACO, a Turkish national, residing at rue Louis-Curval 10, 1206, Geneva.

M. Albert CEZANA, sub-director, residing at 10 chemin Rieu, Geneva and M Nessim HABIB, associate director, residing at 96, chemin du Levant in Lausanne were in charge of managing the accounts.

One of the important accounts that Minton was the economic beneficiary of was opened in the name of the KAROSA Foundation. This foundation is being administered by M Nessim HABIB.

At this Geneva bank, MINTON used to identify himself under the name of Mr. B. Katy. It is by the way noted that this organization issued credit cards under the (false) name Katy used by Mr. Minton.

Several hundreds of millions of dollars were diverted to the detriment of Nigeria between 1987 and 1993 and went through the accounts at DISCOUNT BANK ANDTRUST COMPANY in Geneva.

We know that on 19 November 1998, a transaction in the amount of $4 million was conducted at this bank by MINTON and the KAROSA Foundation; account number: 108:10179140900.

MINTON and his wife are actually in contact with DISCOUNT BANK AND TRUST COMPANY Geneva where they own important funds.

14.-

Connected with the Geneva bank, Robert MINTON and his wife are also the holders and economic beneficiaries of accounts with the DISCOUNT BANK AND TRUST COMPANY in London. Those accounts are being managed by M Patricia COUSINS (Account Manager).

15.-

With letter of March 29, 2000, Prince Bola AJIBOLA, High Commissioner of NIGERIA in London informed DISCOUNT BANK AND TRUST COMPANY Geneva that a judicial investigation had been opened against MINTON and demanded that the bank block his funds internally. (Att. 11).

On April 3, 2000 our counsel in Geneva confirmed to the bank that they had to proceed and had the obligation to state the facts to the Bureau of Communication concerning money laundering in accordance with the law relating to the fight against money laundering n the financial sector. (Att. 12).

The bank confirmed receipt of the letter on April 4, 2000 without however stating the measures they wanted to take. (Att. 13)

16.-

In this context, Robert MINTON traveled to Europe to meet the directors of the DISCOUNT BANK AND TRUST COMPANY.

MINTON was accompanied in his travels by Stacy BROOKS, an American national, born April 8, 1952 and residing at 107 17th St. Belleair Beach, Florida 33786.

17.-

In London, MINTON had a meeting on May 25, 2000 at the offices of DISCOUNT BANK AND TRUST COMPANY, Grosvenor Square 34 with Patricia COUSINS and M Nessim HABIB who is managing the accounts for the Geneva bank.

18.-

On 30 May 2000, ROBERT MINTON went to the offices of DISCOUNT BANK AND TRUST in Geneva where he had a meeting with the directors.

According to our information, Robert MINTON demanded at that meeting the immediate transfer of his funds specifically to Germany and Great Britain as well as the destruction of documents.

Following that meeting, our law firm addressed a new circumstantial correspondence by Fax and hand couriered mentioning the presence of Robert MINTON in their house and reminding them of their vigilant obligation. (Att. 14)

19.-

MINTON and his escort departed Geneva on May 31, 2000 for Frankfurt, Hamburg and Leipzig for meetings with German banks.

MINTON and Stacy BROOKS reserved places to return to Boston, United States for June 5, 2000.

20.-

Other accounts were opened by MINTON in Switzerland, specifically in the name of PREDILECT, GROWTH MANAGEMENT Ltd / GML INTERNATIONAL Ltd and GREENLAND HOLDINGS, at CENTRAPRIV ZURICH AG, Stauffacherstrasse 44, 8039 Zurich and BANK CANTRADE Zurich.

Mr Kurt BYLANG of CENTRAPRIV ZURICH AG was in charge of administering the accounts at CANTRADE BANK.

Very likely in connection with CENTRAPRIV ZURICH AG, GREENLAND HOLDINGS has an address at Stauffacherstrasse 5, 8089 Zurich.

After having suspected that the funds received from NIGERIA constituted an activity of money laundering, BANK CANTRADE closed its accounts for GROWTH MANAGEMENT Ltd / GML INTERNATIONAL LTD and GREENLAND HOLDINGS.

The main conduit and flow of funds into DISCOUNT BANK AND TRUST came from OSTERREICHISCHE LANDERBANK now known as BANK AUSTRIA which is also suspected of harboring assets for Mr. MINTON accumulated through his criminal enterprise.

21.-

Robert MINTON, GML INTERNATIONAL Ltd, GREENLAND and SHAMROCK FINANCIAL CORPORATION, have also been in contact with the following banks and financial institutions:

BANQUE DE DEPOTS, 94 rue du Rhone, Geneva (GORDON-AHMED Sabiha, sub director),

HERITAGE FINANCE & TRUST SA, 12 cours des Bastions, 1205 Geneva (M. Christian M WAGNER).

SIFIDA Societe Internationale Financiere pour les Investissements et le Developpement en Afrique, Luxembourg, Affiliate of Chene-Bourg, rue Francois- Perreard 22 (M. Philippe SECHAUD, Administrative delegate).

SWISS BANK CORP, especially for operations with the agency in New York 10008, 222 Broadway (M. Anton SPICIJARIC).

PARVENTA FINANZ AG, Bale Zug