Last set of documents converted.
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Oct. 1. 2004 1:36PM EA GROUP INC No.8143 P. 1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
)
LAW GROUP, INC.,
)
Plaintiff, )
) Civil Action No,
v. ) 1:02CV02425 (UK)
)
THE REPUBLIC OF THE GAMBIA, )
)
Defendant. )
PT AIMTIFF’S FIRST SET OF REOIJESTS FOR ADMISSION
Pursuant to Fed. R. Civ, P. 36, Plaintiff RAW Group, Inc. hereby requests
that Defendant The Republic of The Gambia respond to these Requests for
Admission within 30 days from service, and admit or deny the truth of the
facts as set forth below.
I, INSTRUCTIONS AND DEFINITIONS
1, Each matter for which an admission is requested will be deemed admitted
unless responses to each request are served within 30 days of the date of
service of this request. Any matter admitted is conclusively established.
Pursuant to Fed. R. Civ. P. 37, Defendant may be required to pay Plaintiff
the reasonable expenses, including attorneys fees, incurred in proving the
truth of any matter set forth below that Defendant fails to admit.
2, Responses shall be provided in writing. The answer shall specifically
admit or deny the matter or set forth in detail reasons why you cannot
truthfully admit or deny the matter. When good faith requires that you
qualify your answer or deny only a part of the matter of which an admission
is requested, you shall specify so much of it as true and qualify or deny
the remainder. You may not state lack of information or knowledge as a
reason for failure to admit or deny unless you state that you have made
reasonable inquiry and that the
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information known or readily obtainable by you is insufficient to enable
you to admit or deny.
3. You shall include in your answers any information that is in the
possession, custody, or control of you, your employees or agents, or any
other person acting on your behalf, including but not limited to your
attorneys.
4. In the event that any request is not answered on the basis of any claim
of privilege or work product, then each request shall be answered to the
extent consistent with the privilege asserted, and infoj.’uation sufficient
to permit the Court to make a determination whether a proper basis exists
for withholding a further response shall be provided.
5. These requests are continuing in nature. If additional information comes
into your possession or is brought to your attention after the date of
Defendant’s response to these requests, supplementation of Defendant’s
responses to these requests is required.
6. As used herein, “you,” “your,” “Defendant,” or “The Gambia” shall mean
The Republic of The Gambia, named in this action, and any current or former
representatives or persons who are acting or authorized to act on behalf of
The Republic of The Gambia, including but not limited to, President Yahya
A.J.J. Jammeh and all current and fojuier members of his administration.
7. As used herein, “EAW” or “Plaintiff’ shall mean the Plaintiff LAW Group,
Inc. named in this action, and any of its current or former employees,
agents, or representatives, including but not limited to John B. Aycoth.
8. As used herein, “First Agreement” shall mean tile contract, dated May15,
2000, between LAW and The Republic of The Gambia, referenced in ParagraphS
of The Gambia’s Answer.
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9. As used herein, “Second Agreement” shall mean the contract, dated
September 1, 2001, between BAW and The Republic of The Gambia, referenced
in Paragraph S of The Gambia’s Answer.
10. As used herein, “September 23 Letter” shall mean the letter, dated
September 23, 2002, signed by Julia 0. Joiner as Secretary General of The
Republic of The Gambia, referenced in Paragraph 12 of The Gambia’s Answer,
1 1, As used herein, “Services,” unless otherwise specified, shall refer to
the “public relations, govermnent affairs and trade and economic
development services” referenced in the First Agreement and the Second
Agreement.
12. As used herein, “Amerada Hess” shall mean Amerada Hess Corporation, and
any of its current or former employees, agents, subsidiaries, affiliates,
or representatives, including but not limited to, Grant Gilchrist,
13. As used herein, “Bombardier” shall mean Bombardier Inc., and any of its
current or fonner employees, agents, subsidiaries, affiliates, or
representatives, including but not limited to, Piers Cumberlage and
Emmanuel Paillier.
14. As used herein, “KG” shall mean American International Group, Inc., and
any of its current or foiiuer employees, agents, subsidiaries, affiliates,
investment funds, or representatives, including but not limited to, AIG
Emerging Market Partnerships and Tom Gibian.
15 As used herein, “Seaboard” shall mean Seaboard Coiporation, and any of
its current or former employees, agents, subsidiaries, affiliates, or
representatives, including but not limited to, Ralph Moss.
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16. As used herein, “Quilford Mills” shall mean Guilford Mills, Inc and any
of its current or former employees, agents, subsidiaries, affiliates, or
representatives, including but not limited to, Walter Martindale
17. As used herein, “Tntercei” shall mean Jntercel Holdings, Ltd., and any
of its current or former employees, agents, subsidiaries, affiliates, or
representatives, including but not limited to, Joseph Gatt,
iS, As used herein, “QlaxoStnithKline” shall mean GlaxoSmithKline PLC, and
any of its current or former employees, agents, subsidiaries, affiliates,
or representatives, including but not limited to, William Schuyler,
19. As used herein, “Gampuels” shall mean the GamFuels Project, as
designated by The Republic of The Gambia, and any and all efforts to
develop a fuel depot in The Gambia, from January 1999 to present, and any
current or former employees, agents, subsidiaries, affiliates, or
representatives of any entities involved with the GamFuels Project,
including but not limited to, the Republic of South Afiica, Aveng, Grinaker-
LTA Limited, Engen Petroleum Limited, SRK Consulting, Standard Chartered
Bank, CSII(, HSBC Equator Bank and Bruce Jewels,
20. As used herein, “Human Rights Watch” shall mean Human Rights Watch non-
governmental organization, and any of its current or foiu’er employees,
agents, subsidiaries, affiliates, or representatives, including but not
limited to, Peter Takirambudde,
21. As used herein, “Complaint” shall mean the Complaint filed in this
action on February 27,
2003.
22. As used herein, “Answer” shall mean the Answer filed in this action on
July 17, 2003.
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23. As used herein, “Counterclaim” shall mean the Counterclaim filed in
this action on July 17
2003.
II REQUESTS FOR ADMISSIONS
REQUEST FOR ADMISSION NO, 1 Admit that from May 15, 2000, through September
23, 2002, The Gambia did not express to EAW any dissatisfaction with LAW’s
perfoimance under the First Agreement.
RESPONSE:
REQUEST FOR ADMISSION NO. 2 Admit that from May 15 2000 through September
23, 2002, The Gambia did not express to LAW any dissatisfaction with LAW’s
performance under the Second Agreement.
RESPONSE:
RE FOR ADMISSION NO, 3 Admit that from May 15, 2000, through September 23,
2002, The Gambia did not express to EAW any dissatisfaction with RAW’s
provision of the
Services.
RESPONSE:
REQUEST FOR ADMISSION NO, 4 Admit that on December 13, 2001, The Gambia
invited
John E. Aycoth to attend President Yahya A.J.J. Jammeh’s Inauguration
ceremony to be held on
December 21, 2001.
RESPONSE
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REQUEST FOR ADMISSION NO 5 Admit that The Gambia’s invitation to John E.
Aycoth to attend President Yahya A.J.J. Jammeh’s Inauguration ceremony on
December 21, 2001 was in recognition for LAW’s perfoiiiiancc of the
Services and EAW’s assistance in the election.
RESPONSE:
REOUEST FOR ADMISSTON NO. 6 Admit that on September 5, 2000, The Gambia,
including but not limited to President Yahya A,J,J. Jammeh, met with RAW
and Intercel.
RESPONSE:
REQUEST FOR ADMJSSIQN NO, 7 Admit that LAW arranged the meeting described
in the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO. 8 Admit that on September 5, 2000, The Gambia,
including but not limited to President Yahya A,J,J, Jammeh, met with EAW
and U.S. Congresswoman Cynthia A. McKiriney, RESPONSE;
REQUEST FOR ADMISSION NO. 9 Admit that EAW aitanged the meeting described
in the preceding request.
RESPONSE
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REOUEST FOR ADMISSION NO. 10
Admit that
on September 5, 2000, The Gambia,
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including but not limited to President Yahya A.J.J. Jammeh, met with PAW
and Human Rights Watch.
RESPONSE
REOUEST FOR ADMISSTON NO.
11:
preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO,
12:
Admit that LAW arranged the meeting described in the
Admit that on September 5, 2000, representatives of
The Gambia including but not limited to President Yahya A Janimeh, had
dinner with
EAW.
RESPONSE
REQTJE SJ FOR ADMISSIflN
NO. 13: Admit
that
on September
6 2000. The Gambia,
including but not limited to President Yahya A.J.J. Jammeh, met with LAW
and representatives of the Boston Globe, including but not limited to John
Donnelly.
RESPONSE
RE FOR ADMISSION NO. 14
Admit that LAW arranged the meeting described in the
preceding request.
RESPONSE
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RE FOR ADMISSION NO, 15 Admit that on September 6 2000, The Gambia,
including but not limited to President Yahya A,J,J, Jammeh, met with EAW
and Seaboard.
RESPONSE:
REOUBST FOR ADMISSION NO. 16 Adm that LAW arranged the meeting described in
the preceding request.
RESPONSE:
REOUEST FOR ADMISSION NO. 17 Admit that on September 6, 2000,
representatives of The Gambia, including but not limited to President Yahya
A.J.J. Jammeh, had dinner with
LAW,
RESPONSE:
REOUEST FOR ADMISSION NO. 18 Admit that on or about September 8, 20OO The
Gambia, including but not limited to President Yahya A,J,J, Jammeh, met
with EAW and Dr.
Hem Kissinger.
RESPONSE:
REQUEST FOR ADMISSION NO. 19 Admit that EAW arranged the meeting described
in the preceding request.
RESPONSE
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REOTJI.dST FOR AflMISSIQN Nfl 20 Admit that on or about September 8, 2000,
The Gambia, including but not limited to President Yahya A.J.J. Jammeh, met
with EAW and AdO, including but not limited to, Ado/Emerging Market
Partnerships.
RESPONSE
REOIJFST FOR ADMISSIONNO,
21
preceding request.
RESPONSE:
REOLEST FOR ADMtSSION NO
22:
Admit that RAW arranged the meeting described in the
Admit that on or about
September 8, 2000, The
Gambia, including but not limited to President Yahya A.J.J. Jammeh, met
with U.S. National
Security Advisor Condoleezza Rice via telephone.
RESPONSE:
REOUFST FOR A NO 2
preceding request.
RESPONSE:
REOTJ ADIvHSSIQNNO 24 Admit that on September 8, 2000, representatives of
The Gambia, including but not limited to President Yahya A.J.J. Jarnmeh,
had dinner with
LAW.
RESPONSE
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Admit that EAW arranged the meeting described in the
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REOLhST FOR ADMISSION NO, 25 Admit that on or about August 23, 2000,
President
Yahya A.J.J. Januneh endorsed Governor George W. Bush for President of the
United States of
A
RESPONSE:
REQUEST FOR ADMISSTON NO. 26 Admit that on January 25, 2001, LAW contacted
U.S.
National Security Advisor Condoleezza Rice on behalf of The Gambia.
RESPONSE:
REQUEST FOR ADMISSION NO. 27 Admit that on April 2, 2002, U.S. Congressmen
Edward R, Royce and Donald M. Payne wrote U.S. President George W. Bush
urging the President to meet with President Yahya A.J.J. Jammeh,
RESPONSE:
REQUEST FOR ADMISSION NO. 28 Admit that U.S. Congressmen Edward R. Royce and
Donald M. Payne wrote the letter described in the preceding request due to
the efforts of EAW.
RESPONSE:
REQUEST FOR ADMISSION NO. 29 Admit that EAW assisted drafting the letter
described in
Request for Admission No. 27.
RESPONSE
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REOIJItST FOR ADMII$SIONNO, 3O Admit that on May 13, 2002, The Gambia
requested
RAW to arrange for a Medical/Hospital Engineer to travel to Banjul, The
Gambia to install
hospital equipment.
RESPONSE:
REOIJ NST FOR ADMISSION NO. 31 Admit that EAW made the alTangements
requested by
The Gambia in the preceding request.
RESPONSE:
REOT J FOR ADMISSION NO 2 Admit that RAW secured the donation, to The
Gambia, of the hospital equipment referenced in Request for Admission No.
30.
RESPONSE:
R.EOUPST FOR ADMISSION NO 33 Admit that during or prior to October 2001, The
Gambia requested EAW to procure specific items of furniture.
RESPONSE:
REOTJpST FOR ADMISSION NO 34 Admit that on October 11, 2001, EAW procured,
at a cost of approximately $3,866.00, the items of furniture referenced in
the preceding request.
RESPONSE:
REOT J HST FOR ADMISSION NO 1S Admit that RAW paid for the goods referenced
in Request for Admission No. 33.
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RESPONSE:
RE FOR ADMISSION NO 36 Admit that The Gambia reimbursed EAW for the
purchase of the goods referenced in Request for Admission No, 33,
RESPONSE:
R.EOLEST FOR ADMTSSION NO 17 Admit that in or before to May 2002, President
Yahya A.J.J. Jammeh requested LAW to procure one 2001 BMW 75011LP
automobile,
RESPONSE
REQUEST FOR ADMISSION NO. 3$; Admit that RAW paid a $3,000.00 deposit on
the BMW automobile referenced in the preceding request.
RESPONSE:
REQ FOR ADMISSION NO. 39 Admit that LAW assisted in the preparation of the
October 2002 edition of the Gambia Newsletter, a publication of the Embassy
of The Gambia,
Washington, D.C.
RESPONSE:
REQueST FOR ADMISSION NO 4ft Admit that on March 11, 2002, LAW and The
Gambia, including but not limited to Ambassador Bojang attended the 2002
Salute to Senator Jesse Helms.
RESPONSE
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REOLtST FOR ADMISSION NO.41 Admit that LAW arranged The Gambia’s attendance
at the event described in the preceding request.
RESPONSE:
REqUEST FOR ADMISSION NO. 42 Admit that on August 30, 2000, LAW advanced The
Gambia $5,000.00 for use during President Yahya A.J,J, Jammeh’s visit to
the United States.
RESPONSE:
REOUEST FOR ADMISSION NO. 43 Admit that from October 2001 to February 2002,
EAW assisted The Gambia in obtaining the resignation of Ambassador-At-Large
Clark Enslin.
RESPONSE:
REOUEST FOR ADMISSION NO. 44 Admit that on or about November 15, 2001, The
Gambia requested EAW to obtain tickets from Ghana Airways.
RESPONSE:
REOUEST FOR ADMISSION NO. 45 Admit that LAW paid for the tickets referenced
in the preceding request.
RESPONSE:
RRO FOR ADMISSION NO. 46 Admit that The Gambia reimbursed RAW for the
purchase of the tickets referenced in Request for Admission No, 44.
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RESPONSE
REOI i FOR ADMISSION NO
47
machine to The Gambia.
RESPONSE:
REOIJEST FOR ADMISSION NO
4R
Admit that during August 2000, EAW donated
a fax
Admit that on February 19, 2002 The Gambia held a
reception to commemorate The Gambia’s 37th Independence Anniversary at the
Willard Hotel in Washington D.C.
RESPONSE:
REOT J } ST FOR ADM NO 49 Admit that EAW arranged the event referenced in
the preceding request,
RESPONSE:
REOTJt FORADM1SSIONNO 0
for consumption at the event referenced
RESPONSE:
REOIJI FOR ADMISSION NO. 51
reception to commemorate The Gambia’s 36th Independence Anniversary at the
Willard Hotel in Washington D.C.
RESPONSE
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Admit that EAW purchased $1046.40 worth of alcohol
in Request for Admission No. 48.
Admit that on February 20, 2001 The Gambia held a
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REOUEST FOR ADMISSION NO. 52 Admit that RAW arranged the event referenced
in the preceding request.
RESPONSE
REQUEST FOR ADMISSION NO. 53 Admit that Seaboard attended the event
referenced in
Request for Admission No. 51.
RRSPONSF
REQUEST FOR ADMISSIONNO. 54 Admit that RAW arranged for Seaboard to attend
the event referenced in Request for Admission No. 51.
R
RPOUEST FOR ADMISSION NO. 55 Admit that U.S. Congresswoman Eva Clayton
attended the event referenced in Request for Admission No, 51, RESPONSE
REQUEST FOR ADMISSION NO 56 Admit that EAW arranged for U.S. Congresswoman
Eva Clayton to attend the event referenced in Request for Admission No. 51.
RESPONSE’
REQUEST FOR ADMISSION NO. 57 Admit that the GlaxoSmithKline attended the
event referenced in Request for Admission No. 5
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RESPONSE:
R.EOLhST FOR ADMISSION NO 58 Admit that LAW alTanged for GlaxoSmithKline to
attend the event referenced in Request for Admission No. 51.
RESPONSE:
REOTJhST FOR ADMISSION NO 59 Admit that Malik Cbaka, aide for U.S.
Congressman
Edward Royce, attended the event referenced in Request for Admission No. 51.
RESPONSE:
REQ FOR ADMISSION NO 60 Adniit that RAW arranged for Malik Chaka, aide for
U.S. Congressman Edward Royce, to attend the event referenced in Request
for Admission No.
51.
RESPONSE:
REOUEST FOR ADMISSION NO 61 Admit that on August 9, 2000, The Gambia invited
Bruce A. Jewels to visit The Gambia to discuss a proposed new oil storage
facility in The
Gambia.
RESPONSE:
REOT FOR ADMISSION NO 62 Admit that EAW arranged the invitation described
in the preceding request.
RESPONSE
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RE FOR ADMISSION NO 63 Admit that on August 9, 2000, The Gambia invited
Johan Oe of NEDBANK to visit The Gambia to discuss a proposed new oil
storage facility
in The Gambia.
RESPONSE:
REOUEST FOR ADMISSION NO. 64 Admit that RAW arranged the meeting described
in the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO. 65 Admit that on August 9, 2000, The Gambia
invited Bob
Lampman of LTA to visit The Gambia to discuss a proposed new oil storage
facility in The
Gambia.
RESPONSE:
REQUEST FOR ADMISSION NO. 66 Admit that EAW arranged the meeting described
in the preceding request.
RESPONSE:
REOUEST FOR ADMISSION NO. 67 Admit that on April 1, 2002, The Gambia
confirmed with EAW the payment of$190,000,00 for the completion of the
GamFuels feasibility study.
RESPONSE
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REOTJhST FOR ADMISSION NO 6R Admit that on April 1, 2002, The Gambia
requested
EAW to complete the GamFuels feasibility study.
RESPONSE:
REOTJaST FOR ADMISSTON NO 69 Admit that BAW arranged for the completion of
the feasibility study referenced in the preceding request.
RESPONSE:
REOIJhST FOR ADMISSION NO 70 Admit that on or about June 23, 2002, The
Gambia met with GamFuels, including Bruce Jewels.
RESPONSE:
REOIJhST FOR AflMISSION NO 7P Admit that EAW arranged the meeting described
in the preceding request.
RESPONSE:
REOTJaST FOR ADMISSION NO. 72 Admit that on May 14 2002, The Gambia paid
Grinaker-LTA for the GamFuels feasibility study.
RESPONSE:
REOUEST FOR AnMTSSTON N 7 Admit that LAW arranged for the payment of the
feasibility study referenced in the preceding request.
RESPONSE
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REQUEST FOR ADMISSION NQ. 74; Admit that on July 11, 2002, GamFuels
provided evaluation materials regarding a fuel depot to The Gambia.
RESPONSE:
REOT ) b ST FOR AnMISSION NO 7 Admit that RAW arranged for the development
of the evaluation materials referenced in the preceding request.
RESPONSE:
REOI J KST FOR ADMTSSION NO 76 Admit that on July 11, 2002, GamFuels
requested from
The Gambia information regarding the proposed ftel depot.
RESPONSE:
REOL HST FOR i&DWSSTON NO 77 Admit that LAW arranged for the information
referenced in the preceding request to be gathered.
RESPONSE:
REOLhST FOR ADMISSION Nfl 7 Admit that on or about F 14, 2001, Seaboard met
with The Gambia, including but not limited to President Yahya A.J.J. Jammeh
and Secretary General Julia Joiner, in The Gambia, RESPONSE
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REOUEST FOR ADMISSION NO. 79 Admit that EAW arranged the meeting described
in the preceding request.
RESPONSE:
REQUEST FOR A.DMISSION NO. 80 Admit that on or about November 11, 2000, The
Gambia, including but not limited to, Ambassador Johnson, met with Seaboard.
RESPONSE:
REQUEST FOR ADMISSION NO, 81 Admit that LAW arranged the meeting described
in the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO. 82 Admit that in 2000 through 2001, The Gambia
was negotiating with Seaboard for the construction of a flour mill.
RESPONSE
REOUEST FOR ADMISSION NO,
83;
the preceding request.
BA$
REQUEST FOR ADMISSION NO
84:
Admit that EAW arranged the negotiations described in
Admit that in 2001 The Gambia was negotiating with
Guilford Mills for the development of The Gambia’s textile industry.
RPSPONSE
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REOI FOR ADMISSIONNO
R5
the preceding request.
RESPONSE:
REOTTPST FOR ADMISSION NO
86:
Admit that LAW arranged the negotiations described in
Admit that on March 2, 2001, Guilford Mills wrote The
Admit that E AW arranged for Guilford Mills to write
on or about November 1, 2000, The
Gambia regarding development of The Gambia’s textile industry.
RESPONSE:
REOTJhST FOR ADMISSION NO 87
The Gambia as described in the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO RX Admit that
Gambia, including but not limited to President Yahya A.J.J. Jammeh, met
with Intercel
RESPONSE:
REOIJ l FOR ADMISSION NO. 89 Admit that LAW arranged the meeting described
in the preceding request.
RESPONSE:
REOI.LEST FOR ADMISSION NO. 90 Admit that on or about November 8, 2000, The
Gambia met with Intercel.
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RESPONSE
RE FOR ADMISSION NO.
91:
Admit
that BAW arranged the meeting described in the
preceding request.
RESPONSE:
REOUEST FOR ADMJSSION NO,
92:
Admit
that dur
ing March 2001 The Gambia, including
but not limited to President Yahya A.J.J. Jammeh and Secretary General
Julia Joiner, met with Intercel.
RESPONSE:
REODEST FOR ADMISSION NO. 93 Admit that EAW arranged the meeting described
in the preceding request.
RESPONSE:
REOUEST FOR ADMISSION NO. 94 Admit that in 2000 and 2001, The Gambia was
negotiating with Tntercel for the issuance of a OSM License.
RESPONSE:
REOUEST FOR ADMISSION NO, 95 Admit that EAW arranged the negotiations
described in the preceding request.
RESPONSE
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REOT J fr ST FOR ADMTSSTON NO 96 Admit that in or before April 2001, The
Gambia, including but not limited to, Ambassador Bojang and Minister of
Finance Jatta, met with GlaxoSmithK
RESPONSE:
REOT J b ST FOR ADMISSION NO 97 Admit that EAW atTanged the meeting
described in the preceding request.
RESPONSE:
REOTJpST FOR AnMISSION NO 95 Admit that on May 8-10, 2002, The Gambia
including
President Yahya A.J.J, Jammeh, attended the United N ations Special S
ession on Children in
New York City, New York.
RESPONSE:
REOUEST FOR ADMISSION NO 99 Admit that EAW assisted The Gambia in making
arrangements to attend the event referenced in the preceding request.
RESPONSE:
REOUEST FOR ADMISSION NO lOOAdmit that John E, Aycoth was a member o The
Gambia’s delegation to the event referenced in Request for Admission No. 98.
RESPONSE
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REQUEST FOR ADMISSION NO. 101 : that on May 7, 2002, officials of The
Gambia, including President Yahya A.JJ. Jammeh, visited the foIIIAer site
of the World Trade Center in New York City, New York.
RESPONSE:
REOUEST FOR ADMISSION NO. 102:Admit that LAW arranged the visit described
in the preceding request.
RESPONSE:
REOUEST FOR ADMISSION NO, 103:Admit that on May 8, 2002, President Yaiiya
A,J,J.
Jammeli had a dental appointment with Dr. Marc Behuri in New York City, New
York.
RESPONSE:
R.EOTJEST FOR ADMISSION NO. 104:Admit that LAW arranged the appointment
described in the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO. 1O5:Admit that President Yaiiya A.J.J. Jammeh
paid $6,000 cash, plus a $20,000 tip, for the dental services described in
Request for Admission No. 103, and requested that John Aycoth hand the
money over to the dentist,
RESPONSE
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REQUEST FOR ADMISSION NO, 106:Admit that on May 10. 2002, The Gambia,
including but not limited to President Yahya A.J.J. Jammeh, met with
Bombardier.
RESPONSE:
REQUEST FOR ADMISSION NO. 107:Adnait that LAW arranged the meeting
described in the preceding request.
RESPONSE:
REqUEST FOR ADMISSION NO. 108:Admit that on May 11, 2002, The Gambia,
including but not limited to President Yahya A.J.J. Jammeh, met with U.S.
Congressman Gregory Meek in New York City, New York.
RPSPONSE:
REQUEST FOR ADMISSION NO. 109:Admit that EAW arranged the meeting described
in the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO 1 1O:Admit that on May 11, 2002, The Gambia,
including
but not limited to President Yahya A,J,J, Jammeh, met with U.S. Congressman
Donald Paine in
New York City, New York.
RPSPQNSE
DCO :378057.2
Oct. 1. 2004 1:41PM EA GROUP INC No.8143 P. 26
REQUEST FOR ADMISSION NO, 111 : that EAW arranged the meeting described in
the preceding request.
RPSPONSE:
REqUEST FOR ADMISSION NO. 1 12:Admit that LAW attempted to anange a meeting
between The Gambia and New York City Mayor Michael Bloomberg during May
2002.
RESPONSE:
REqUEST FOR ADMISSION NO. 1 13:Admit that LAW attempted to arrange a
meeting between The Gambia and U.S. President George W. Bush.
RPSPONSE:
REqUEST FOR ADMISSION NO. 1 14:Admit that in October 2002, The Gambia,
including but not limited to President Yahya A,J,J, Jammeh, Director of
Energy Bahsaho and Mr. Njie, met with Amerada Hess.
RESPONSE:
REOUEST FOR ADMISSION NO. 115:Admit that EAW assisted in arranging the
meeting described in the preceding request.
REqUEST FOR ADMISSION NO. 1 16:Admit that in 2002, The Gambia was
negotiating with Amerada Hess for the development of offshore oil drilling.
Dc0L378057.2
Oct. 1. 2004 1:41PM EA GROUP INC No.8143 P. 21
RESPONSE:
RE FOR ADMISSION NO. 1 17:Admit that LAW assisted in the negotiations
described in the preceding request.
RESPONSE:
RE FOR ADMISSION NO. 1 18:Admit that during 2001, LAW assisted in the re
election campaign of President Yahya All. Jammeh.
RESPONSE:
REOUEST FOR ADMISSION NO. 1 19:Admit that on May 29, 2001, RAW received a
proposal from political consulting firm Opinion Media.
RESPONSE:
RE FOR ADMISSION NO, 120:Admit that the proposal referenced in the
preceding request was part of LAW’s efforts in assisting the re-election of
President Yahya ASS, Jammeh.
RESPONSE:
REOLEST FOR ADMISSION NO. 121:Admit that on April 4, 2001, EAW received a
proposal from political consulting f Institute for Democratic Strategies.
RESPONSE
DOOl 378057.2
Oct. 1. 2004 1:42PM EA GROUP INC No.8143 P. 28
REQUEST FOR ADMISSION NO. 122:Admit that the proposal referenced in the
preceding request was part of EAW efforts in assisting the re-election of
President Yahya A.J.J. Jammeh.
RESPONSE:
REQUEST FOR ADMISSION NO. 123:Admit that on May 21, 2002, LAW paid
$10,775.00 for ocean freight charges to The Gambia.
RESPONSE:
REQUEST FOR ADMISSION NO. 124:Admit that on August 30, 2001, LAW paid
$114,984.00 for ocean freight charges to The Gambia.
RESPONSE:
REOUEST FOR ADMISSION NO. 125:Admit that during 2001, The Gambia, including
but not limited to President Yahya ALl. Jammeh, requested that LAW procure
18 Ford F-350 working trucks, spare parts, spare tires and thel tanks,
RESPONSE:
RE FOR ADMISSION NO. 126:Admit that LAW procured the goods referenced in
the preceding request at an approximate cost of $738,656.50, including
shipping.
RESPONSE:
REOUEST FOR ADMISSION NO. 127:Admit that dufing 2001, The Gambia requested
EAW to procure one 2000 BMW 7 automobile.
DCO1 :378057.2
Oct. 1. 2004 1:42PM EA GROUP INC No.8143 P. 29
RESPONSE:
RE FOR ADMISSION NO. 128:Admit that during 2001, EAW procured, at a cost of
approximately $99,400.00, the BMW automobile referenced in the preceding
request.
RESPONSE:
REOUBST FOR ADMISSION NO. 129:Adrnit that EAW paid for the BMW automobile
referenced in Request for Admission No. 127,
RESPONSE:
REOUEST FOR ADMISSION NO. 130:Admit that The Gambia reimbursed EAW for the
purchase of the BMW automobile referenced in Request for Admission No. 127.
RESPONSE:
R.EOUEST FOR ADMISSION NO, 131 Admit that during or prior to February 2002,
The Gambia requested LAW to procure flags of The Gambia and the United
States of America, along with set poles, stands and a flag pole.
RESPONSE:
REOUEST FOR ADMISSION NO. 132:Admit that on February 16, 2002, LAW
purchased the goods referenced in the preceding request.
RESPONSE
DC :378057.2
Oct. 7. 2004 1:42PM EA GROUP INC No.8143 P. 30
RE FOR ADMISSION NO l that between May 6 and May 11, 2002, during
President Yahya A.J.J. Jammeh’s visit to New York City, President Yahya
A,J,J, Jammeh
and/or The Gambia purchased $9,827.00 worth of toys from FAO Schwarz.
RESPONSE:
RBOIJKST FOR ADMISSION NO 1 14Admit that President YaSya A,J.J. Jammeh gave
EAW cash to purchase the goods described in the preceding request.
RESPONSE:
REOIJFST FOR ADMISSION NO 1 i that EAW purchased, and had delivered to
President Yahya A.J.J. Jammeh’s hotel suite in New York City, the goods
described in Request
for Admission No. 133.
RESPONSE:
REOIJhST FOR ADMISSION NO 136:Admit that between May 6 and May 11, 2002,
during
President Yahya A,J,J, Jammeh’s visit to New York City, President Yahya
A.J.J, Jammeh
and The Gambia purchased $135,488.93 worth of goods from Toumeau NY, Inc.
RESPONSE:
kEp J b ST FOR PT)MISSTON NO 1 l7AdmIt that President Yahya A.J.J. Januneh
gave LAW cash to purchase the goods described in the preceding request.
RESPONSE
DCOI :378057.2
Oct. 1. 2004 1:42PM EA GROUP INC No.8143 P. 31
REQUEST FOR ADMISSION NO. 138:Adrnit that RAW purchased, and had delivered
to President Yahya A.J.J, Jammeh’s hotel suite in New York City, the goods
described in Request for Admission No, 136
RESPONSE:
REOTJEST FOR ADMISSION NO. 139:Admit that the goods referenced in Request
for Admission No. 136 include, but are not limited to:
a. One Cartier “Tortue” (white gold) watch One Cm-tier “Baignoire” (yellow
gold) watch
C. One Rolex YachtMaster 16628
d. One Rolex Oyster Explorer II watch
e. One Rolex Lady Oyster with Diamonds watch
f. One Rolex Mens Master Daydate watch
g. Six Fountain & Roilball Pens
h. Eight Tourneau Watches
RESPONSE:
RBOUEST FOR ADMISSION NO. 140:Admit that between May 6 and May 11, 2002,
during
President Yahya A.J.J. Janimeh’s visit to New York City, President Yahya
A.J.J. Jammeh
and/or The Gambia purchased $2,l 92.50 worth of goods from Mitsosa, located
at 1420 6th Ave.
RESPONSE:
REOIJEST FOR ADMISSION NO. 141 : that President Yahya A.J.J. Jammeh gave
EAW cash to purchase the goods described in the preceding request.
RESPONSE
DCO1 :3780572
Oct. 1. 2004 1:42PM EA GROUP INC No.8143 P. 32
REQUEST FOR ADMISSION NO, 142:Adniit that EAW purchased, and had delivered
to President Yahya A.J.J, Jammeh’s hotel suite in New York City, the goods
described in Request for Admission No. 140,
RESPONSE:
REQUEST FOR ADMISSION NO, 143:Admit that between May 6 and May 11, 2002,
during President Yahya A.J.J. Jammeh’s visit to New York City, President
Yahya A.J.J. Jammeh and/or The Gambia purchased $28,209.21 worth of goods
from The Sharper Image,
RESPONSE:
REQUEST FOR ADMISSION NO. 144:Adnńt that President Yahya A.J.J. Jarnmeh
gave LAW cash to purchase the goods described in the preceding request.
RESPONSE:
REOUEST FOR ADMISSION NO, 145:Admit that EAW purchased, and had delivered to
President Yahya A.J.J. Jamnieh’s hotel suite in New York City, the goods
described in Request
for Admission No, 143.
RESPONSE:
REQUEST FOR ADMISSION NO. 146:Admit that between May 6 and May 11, 2002,
during
President Yahya A,J,J, Jammeh’s visit to New York City, President Yahya
A.J.J. Jammeh
and/or The Gambia purchased $92,110.00 worth of goods from Sunny on Sixth,
Inc.
RESPONSE
DCO :378057.2
Oct. 1. 2004 1:43PM EA GROUP INC No.8143 P. 33
REQUEST FOR ADMISSION NO 1 47Admit that President Yahya A.J.J. Jammeh gave
RAW cash to purchase the goods described in the preceding request.
RESPONSE:
REOT J b ST FOR ADMISSION NO I 4S:Admit that RAW purchased, and had
delivered to
President Yahya A,J.J. Jammeh’s hotel suite in New York City, the goods
described in Request
for Admission No. 146.
RESPONSE:
REQUEST FOR ADMIISSIONNO 149 that between May 6 and May 11, 2002, during
President Yahya A.J.J. Jammeh’s visit to New York City, President Yahya ALL
Jammeh
and/or The Gambia purchased a $270.63 silk scarf from He!__CS.
RESPONSE:
REOIJEST FOR ADMISSION NO I SftAdmit that President Yahya A.J.J. Jammeh
gave EAW cash to purchase the goods described in the preceding request.
RESPONSE:
kEptj F ST FQR AD?vHS StUN NO 151 Adniit that LAW purchased, and had
delivered to President Yahya A.J.J. Jammeh’s hotel suite in New York City,
the goods described in Request for Admission No. 149.
RESPONSE
DC0 :378057
Oct. 1. 2004 1:43PM EA GROUP INC No.8143 P. 34
R.EOUEST FOR ADMISSION NO I 52:Admit that between May 6 and May 11, 2002,
during
President Yahya A.J.J. Jammeh’s visit to New York City President Yahya
A,J,J, Jammeh
andlor The Gambia purchased $346.11 worth of goods from Friedlander
Hardware Store.
RESPONSE:
REqUEST FOR ADMISSION NO. 153:Admit that President Yahya A,J,J, Jammeh gave
RAW cash to purchase the goods described in the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO. 154:Adnait that LAW purchased, and had delivered
to
President Yahya A.J.J. Jammeh’s hotel suite in New York City, the goods
described in Request
for Admission No. 152.
RESPONSE:
REOUEST FOR ADMISSION NO. 155:Admit that between May 6 and May 11, 2002,
during
President Yahya A.J.J. Jammeh’s visit to New York City, President Yahya
A.J.J. Jammeh
and/or The Gambia purchased $32,490.00 worth of goods from Brookstone.
RESPONSE:
REqUEST FOR ADMISSION NO. 156:Admit that President Yahya A,J,J, Jammeh gave
LAW cash to purchase the goods described in the preceding request.
RESPONSE
DCO 378057.2
Oct. 1. 2004 1:43PM EA GROUP INC No.8143 P. 35
REQUEST FOR ADMISSION NO. 157:Admit that BAW purchased, and had delivered to
President Yahya A.J.J. Jammeh’s hotel suite in New York City, the goods
described in Request
for Admission No. 155.
RESPONSE:
REQUEST FOR ADMISSION NO. 158:Admit that LAW arranged for The First Lady of
The Gambia to receive medical treatment in the United States,
RESPONSE:
REOTJEST FOR ADMISSION NO. 159:Admit that LAW regularly faxed news
articles, relating to The Gambia, to President Yahya A.J.J. Jammeh.
RESPONSE:
R.EOUEST FOR ADMISSION NO. 160:Admit that EAW gathered the news articles
referenced in the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO. 161 : that in September 2002, Ambassador Sey of
The
Gambia requested EAW to purchase an automobile for The Gambia’s U.S.
Embassy.
RESPONSE
DC :378057.2
Oct. 1. 2004 1:43PM EA GROUP INC No.8143 P. 36
REqUEST FOR ADMISSION NO. 162:Admit that on September 13, 2002 in response
to Ambassador Sey’s request referenced in the preceding request, EAW
arranged for the purchase of a Ford Taurus automobile for approximately
$15,875.00.
REqUEST FOR ADMISSION NO, 163:Admit that during RAW’s performance of the
First
Agreement and Second Agreement, President Yahya A.J.J. Jammeh infojuied EAW
that he
refused to conduct telephone interviews.
RESPONSE:
REOUEST FOR ADMISSION NO. 164:Admit that on or about October 23, 2001, The
Gambia, including but not limited to Ambassador Boj ang, met with Kimberly
Ayers, Story Producer for the National Geographic Channel.
RESPONSE:
RE FOR ADMISSION NO. 165:Admit that EAW arranged the meeting described in
the preceding request.
RESPONSE:
REQUEST FOR ADMISSION NO. 166:Admit that during April 2001, Claudia Ochoa
of Gary
Player Design, discussed designing a golf course in The Gambia with EAW.
R P SPONSE
DCO 3750572
Oct. 1. 2004 1:43PM EA GROUP INC No.8143 P. 31
REOT J F’ST FOR AflMISSION N 1 67Admjt that LAW arranged the meeting
described in the preceding request.
RESPONSE
Dated: February 2, 2004 RespectfUlly submitted,
David A, Super (D.C. Bar No. 429359)
E, Barrett Atwood (D.C. Bar No. 478539)
BAKER BOTTS L,L.P.
1299 Pennsylvania Avenue, N.W.
Washington D.C., 20004-2400
(202) 639-7700
Attorneys for Plaintiff-Counterclaim
Defendant EAW Group, Inc
DCO 378057.2
I U (jKOLJP JJNG ? P. 33
cERTIF OF SERVICE
I certify that a true copy ot the foregoing Plaintiffs First Set of
Requests for Admission was served by hand delivery on the 2nd day of
February 2004, upon:
Thomas R. Queen
Thomas H. Queen and Associate
530 Eighth Streets SB
Washington, bC 20003
B Barrett Atwood
1JC01 :378057.2
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