For those who cannot read the attached court documents. I've converted it
into word and reproduced it. Some of the characters did not convert well.
But you can get most of what is written in these court documents:
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Oct. 4. 2004 5:51PM EA GROUP INC No.8103 P. 1
David A. Super (D.C. Bar No. 429359)
E, Barrett Atwood (D.C. Bar NQ. 478539)
BAKER BOTTS LL
1299 Petmsylvania Avenue, N.W. C
Washington, D.C. 20004 __
Telephone: (202) 639-7700 __
C ‘
•) H tM
r N.)
Attorneys for Plaintiff
_ C : ;;;
c i
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA C
CASE NUMBER U02CV02425
JUDGE Gladys Kessler
EAWGROUP, I S DECK DIPEt Contract
2555 Pennsylvania Avenue, N,W,, Suite 806 )
Washirigton,D,C, 20037, ) DATE STAMP’ 12/tO/200
)
)
Plaintiff, ) COMPLAINT
)
V. )
)
THE REPUBLIC OF THE GAMBIA, )
State House, )
Banjul )
Republic of The Gambia, )
)
)
Defendant )
Plpintiff EAW Group, Inc. (“EAW”) tiles this Compisint against The Republic
of The Gambia (“The Gamb nd allegel as follows:
PARIIhS
1. Plaintiff MW is a corporation providing public relations, government
affairs and nud, development services. EAW is incorporated in the Ditct of
Columbia and has its principal place of business
 at 2555 Pennsylsranss
Avenue, N.W., Suite 806, Washingt D.C. John Edward Aycoth is the Ps of B
OCQI 34423tI
Oct. 4. 2004 5:58PM EA GROUP INC No.8103 P. 2
2 Defendant The Gambia is a foreign sovereign state.
JURISDICTION
3. This Court has subject marter jurisdiction over this action pursuant to
28 U.S.C. § l330(a) and 1605(a)(2), because The Gambia is a forei state
under 28 U.S.C. § 1603(a), and this action is based upon commercial
activity ca on in the United States by The Gambia, and upon acts outside
the tetsitory of the United States in connection with commercial activity
of The Gambia that has caused a direct effect in the United States.
4. This Court has personal jurisdiction over The Gambia pursuant to 28 U §
1330(b) because this action involves a claim for relief over which the
Court has jurisdiction under 23 U.S.C. § 1330(a) and service is being
effected under 28 U.S
.C. § 160.8.
GENERAL Al I POATIONS
5. On May 15, 2000, The Gambia giid EAW executed a contract (“First
Agreement”) under which EAW agreed to provide public relations, government
affairs and trade and economic development services (“Services”) for The
Gambia over a one tenis. In return for such Service, The Gambia agreed to
EAW $500,000 as compensation - $250,000 due upon execution of the contact
and $250,000 due within 90 days. EAW fiulfilled its obligations tinder the
Fint A •t arid The Gambia paid EAW in fb
6. In July 2001, Mr. Yahya AJ.J. Jaznmeh, President of The Gambia,
discussed with M AyCoth by telephone a new apeement by which EAW would
provide Services to The Gambia fbr addidonal two-year period. and, in
retuin fbr EAW’s Services, The Gambia would pay EAW $1,000,000 as
compensation — $500,000 due upon execution of the contract ‘ $500,000 due
on Dec C 15, 2001.
DCOL:344236, 1 2
Oct. 4. 2004 5:58PM EA GROUP INC No.8103 P. 3
7. President Jammeh expressly requested the two-year te of the new
agreement, as well as the two specific payment dates By letter dated August
8, 200!, Mrs. Julia D. Joiner, Secretary General of The Gambia as directed
by President Jammeh, conititited that The Gambia had “decided to renew Ithe
contract] with the EAW Group Inc. for a further two-year period effective
1st September 2001.” Secretary General Joiner ftirther requested that EAW
submit ‘a draft a for consideration” EAW submitted a draft agreement as
requested.
8. During Mr. Aycoth’s subsequent visit to The Gambia in September 200!,
The Gambia and EAW executed a second contact, effective September 1,2001
(“Second Agreement”). The Second Agreement contains the terms as agreed
upon by President Jarnrneh and Mr. Aycoth in their July 2001 discussion C
including a two-year tenit and two payments of $500,000, the first due upon
execution and the second due on December 15, 2001. At that time Mr. Famara
Jatta, Secretary of State for Financial and Economic Affairs of The Gambia,
requested that the second payment date of December 15, 2001 be changed to
February 15, 2002. Based on that request, and with Pcsident Jammeh’s
express approval, the second payment date was changed to February 15, 2002,
and the parties initialed that changi in the Second Agreement to make it
official.
9. The Second Agreern-...t provides that it is “governed by the laws of the
Disthct of Columbia, United States of America, both as to interpretation
and performance.”
10. As required by the Second Agreement, The Gambia paid EAW S50O upon
execution of the contact Consistent with its oblijations, EAW set about
performing the Services called fbr by the S ..ond Agreement.
At the direct
request of President Jammeh duxing a telephone discussion with Mr. Aycoth
on Febuary 11, 2002, Mr. Aycoth Scat a letter to Seernry Jatta on February
12, 2001. indicating that the second payment of $500,000 under the
DcOI:34423&t 3
Second Agreement was due on Febr 15, 2001, and providing Secretary Jatta
with a copy of
- Oct. 4. 2004 5:58PM EA GROUP INC No.8103 P. 4
the Second Ageement and an invoice.
I The Gambia breached its contractual obligations under the Second
Agreement by failing to pay LAW $500,000 on February 15, 2002. Nonetheless,
over the next eight months. EAW continued to perfo and The Gambia continued
to accept. LAW valuable professional Services under the Second Agreement.
Throughout that period. Mr. Aycoth inquired about the overdue payment, and
representatives of The Gambia, including President Jammeh and Secretary
Jatta personally, assured Mr. Aycoth that E
AW would be paid as required
under the Second Agreement. However, The Gambia continued to breach the
contract by failing to make the required payment.
12. By letter dated September 23, 2002, Secretary General Joiner, on behalf
of The Gambia. purported to te the Second Agreement as of September 30,
2002. This purported action was a breach of the contact, which does not
provide a right of teiii’ination by either party. In her Septeinb’n 23
letter, Secretary General Joiner confirmed the quality of EAWs past
Services by “express sincere appreciation for the invaluable services
rendered” to The Gambia by EAW.
13. The day after receiving the invalid “termination Letter,” Mr. Aycoth
sent an e-mail to Secretary Ja explainIng that The Gambia’s purported
termination was improper and requesting that The Gambia make the required
payment, which w then eight months overdue.
14. By letter dated November 11,
2002, EAW, through counsel, again
requested that The Gambia make the required paym. due EAW. The Gambia has
not made the payment and has not responded to the November 11
DCOI:344236.l
4
Oct. 4. 2004 5:59PM EA GROUP INC No.8103 P. 5
COUNT FOR BREACH OF CON I RACT
15. EAW refers to and incorporates herein the allegations of Paragraphs I
through 14 above.
16. The Second Agreement is a binding and enforceable contract,
17, EAW has perfo properly its obligations under the Second Agreement.
18, The Gambia breached the Second Agreement by failing to pay EAW $500,000
On February 15, 2002, and has compounded that breach by failing to tender
payment since then.
19, The Gambia breached the Second Agreemcut by purporting to te the
contract on September 23, 2002, despite the fact that the Second Agreement
does not petitt early cc 1 by The Gambia.
20. As a result of The Gambia breaches of the
Second Agreement, EAW has
been damaged in the amount of $500,000, plus reasonable interest accruing
since February 15, 2002, the date the payment was due under the contact.
DCOI 5
Oct. 4. 2004 5:59PM EA GROUP INC No.8103 P. 6
PRAYER FOR RELIEF
WHEREFORE, EAW prays that the Court enter judgment against The Gambia
awarding:
(i) $500,000 in damages;
(ii) pre- and post-judgment interest as pe by law; and
(iii) such other and further relief as the Court deems just and
appropriate.
Dated: December 10, 2002 Respectfully submitted,
David A. Super (D.C. 8 o. 429359)
E. Barren Atwood (D.C. Bar No. 478539)
BAKER BOTrS L.L.P.
1299 Pennsylvania Avenue, N.W.
Washington D.C., 20004-2400
(202) 639-7700
Attorneys for Plaintiff EAW
DcOI;344236.I 6
Oct. 4. 2004 5:59PM EA GROUP INC No.8103 P. 1
IN THE UNITED STATES DtSTR COURT
FOR
 THE DISTRICT OF COLUMBIA
LAW GROUP, [
CASE NUMBER 1:02CV02425
Plaintiff
JUbGE, Gladys Kessler
V. ) DECK TYPE’ Contract
THERE?UBLICOFTHEQAMBLk, ) DATE STAHP 12/10/2002
)
Defendant. )
RULE 26 1 DISCLOSURE OF CORPORA l AFFILIATIONS AN FNANCIAL N OF EAW
ORQIJVIJNC..
I the undersigned, counsel of record for Plaintiff EAW Group, Inc. (“EAW”)
certify that EAW has no parent companies, subsidiaries or affiliates having
outstanding securities in the hands of the public.
These represcutations are made in order that judges of this court may
deteiti&ine the need for recusal.
Dated: December 10, 2002 Respectfully submitted,
X
David A. Super (D.C. Bar 0.429359)
E. Barrett Atwood (D.C. Bar No. 478539)
BAKER BGTIS L.L.P.
1299 Pennsytvania Avcpue, N.W.
Washington D.C., 20004-2400
(202) 639-7100
- Attósaey for Plaintiff
EAW
DCO
S AO 440 (Ray. 8/0 I S h) Ci’ Action
Oct. 4. 2004 5:59PM EA GROUP INC No.8103 P. 8
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
EAW Group, Inc.
2555 Pennsylvania Avenue, N.W., SuIte 506 Washington D.C, 20037
V
The Republic of The Gambia
State House, Banjul, Republic of The Gambia
r i (Nr
H.E. Baboucarr-Blalse Jagne-Dept. of State
4, Muan El-Ohadaffic Avenue
Banjul, The Gambia
SUMMONS IN A CIVIL ACTION
CASE NL :02CV02425 __ _
YOU ARE HEREBY SUMMONED and required to serve on PLAINTIFF’ S ATTORNEY (n d
&d&e
David A. Super (D.C. Bar No, 429359)
E. Barrett Atwood (D.C. Bar No. 478539)
Baker Botts L.L.P., 1299 Penn Ave., NW Ste 1300
Washington DC 20004
an answer to the complaint which is sewed on you with this summons, within
S ( days after service of this surnnlons on you, exclusive of the day o
f
service. If you fail to do so, judgment by default will be taken against
you for the relief demanded in the complaint. Any answer that you serve on
the parties to this action must be filed with the Clerk of this Court
within a reasonable period of time after service.
NANCY M. MAYEA
MAR 4 2003
DAT
Det - Rule 55A (CO 40 Revised-DC 02100)
Oct. 4. 2004 5:59PM EA GROUP INC No.8103 P. 9
UNITED STATES DISTRICT COURT
FOR TH DISTRICT OP COLUMBIA
EAWOROUP IN
Plaintiff(s)
V.
THE REPUBLIC OP THE GAMBIA
Defendant(s)
RE: THE REPUBLIC OF THE GAMBIA
Civil Action No. 02.2425(GK)
DEFAULT
It appearing that, the above-named defendant has failed to plead or
otherwise defend this action though duly served with summons aM copy of the
complaint on March 4, 2003 affidavit on behalf of the plaintiff having been
filed, it is this 16th day of Jinie 2003 declared
tha
t: defendant is in defEIt.
By:
NANCY MAYER-WFITTTTNGTON, Clerk
and an
Clerk
Oct. 4. 2004 5:59PM EA GROUP INC No.8103 P. 10
• 2U U: E GRO I No P
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
SUPPLEMENTAL PRABCIPE OF EAW
By Order of the Court. th p filed a Joint ?ra4cipo on April 29, 2OO4
updating the Court on the thtu of this case. In a separate portion of the
Praccipe, EAW painted out that It b it should be allowed to take the
deposition of ?residcnt Yabyt A,J,J, JAztmeh in pCt
• rather than by video co beo i is the key witness I this case, EAW a
nìoted that it served an ii,terrog on Th Gambi last January requestIng that
it provide the dates on
• which Mr. jammeli (end any other witne will be in the United Ststes. The
Ganibi gerved its respon on M 3, zcpresentlng under oath that, “st this
time, t Defendant doa not know if and when il
 of the person! identified W
be present, in the United States.” Se Interrogatory Response No. 25
(relevant portions attached as Ex A). On May 6, SAW d15;overed that The G
re is false. President Ysmtteh Will be m commencement poakcr for St. Mary’s
College in St. Mary’a City, Maryland on May 15, 2004. Zs Portion of St.
Mcy’s College Website (attaebed as Thc, B There c b; little doubt that The
O has khown of this planned trip to * United States thy months, and obvigu
kaew About ‘It befgr it served its
1
.
‘SAW GROUP, INC,
• )
)
.
)
Plainlift
.
)
)
V. ‘
‘ )
‘ )
THE IkEPUEt,IC OF ThE GA
‘
‘
)
Defendant.
‘
)
)
CivilAction No. flO2CV (c
Pre-trial Conference:
August 2, 2004
Oct. 4. 2004 6:00PM EA GROUP INC - No.8103 P. 11
h 2304 10 9
EAV GROUP WO No P 2
• intørroptory responses under oath. By letter of May ‘7, SAW has demanded
that Th Gambia make President Jamineh available for deposition during next
week’s tip to Mary1 au Letter dated May 6 2004 (attached so Er. C) The
Gambia has not responded to EAW’s letter,
Dated: May 11,2004 Re submitted, .
David A. Super (DC B& Nc, 429
E. Barrett Atwood (D.C. Bar No. 47B BAKER BOTTS L,L$,
1299 Pennsylvania Avenuø, N.W,
Washington D.C., 20004-2400
(202) 6397700
Attoth for ?la(ntiff
Defendant EAW 9rou Inc.
DCO
Oct. 4. 2004 6:00PM - EA GROUP INC - - No.8103 P. 12 - -
SEF 17 1 BAKER a EDITS LJASH :!C 202 639 ?9 P.02
UNITED STATES DISTRICT COURT FOR
THE DISTRICT OF COLUMBIA
EAWGROUP.INC )
)
plaintiff, )
) Civ Action No, 1:02CV02425(GK)
) DiscOvery clQ$ 10/15/2004
)
REPUBLIC
OF THE GAMBIA, )
)
Defendant. )
DEFENDANT S MOTION TO q NOTICE OF DEPOSITION.OP HIS
EXCELLENCY PflSIDENT VAUVA JAMMEIf
COMES NOW the defendant, the Republic of The Gambia, and pursuant to Rule
26 ofthe Federal Rules of Civil Procedure, moves to quash plaintiff, LAW
Group In s nøtice of deposition of His ExceIkncy President Yahya Jammeh,The
Gambia r requests that this Court grant its motion because His Excellency
is the head of state of The Republic of The Gambia and is thus entitled to
head of state immunity In the alterna a deposition would place an uudu
burden on His Excellency and plaintiff has not used 1e intrusive discovery
methods, The Republic of The Gambia relies on the attached Memorandum of
Law in support of its notion.
WHEREFO RE, The Gambia respectfully requc that this Court quash plaintiffs
notice of dcposition of ills Excellency President Yahya Jammeh
Oct. 4. 2004 6:00PM EA G
ROUP INC No.8103 P 13
SEFiG—2004 17: BAKER a EDITS LJPSH X 2 639 7990 P.
Dated: Sept 16,2004 RespectfuLly submitted
/ thomas H. Queen
Thomas H. Queen, Esq.
D Bar No 146340
THOMAS H. QUEEN AND ASSOCIATES
530 Eighth Street, S.E.
W&shin9ton, D.C. 20003.
(202) 544-4200
Attorney f Defendant, The Republic of The 0 ainbia
Oct. 4. 2004 6:00PM EA GROUP INC No.8103 P. 14
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
).
LAW GROUP, INC., )
)
Plaintiff, )
) Civil Action No.
) .1:02CV02425 (OK)
)
THE REPUBLIC OF THE GAMBIA, )
)
Defendant. )
DECLA OF JOHN F. AYCOTH
1. My name is John B. Aycoth. I am the President of RAW Group, Inc.
(“EAW”), a business incorporated under the laws of the District of Columbia
on May 19, 1993.
2, In the Spring of 2000, 1 was contacted
 by Mr. Yabya Jammeh, President of
The Republic of The Gambia (“The Gambia”), about entering into an agreement
to provide public relations, government affairs, and trade and economic
development services to The Gambia for a one year term (“First Agreement”).
President Jammeb personally negotiated all the terms of the First
Agreement, which was signed on May 15, 2000,
3, In July, 2001, President Jammeh called me to discuss renewing the First
Agreement.
President Jammeh specifically requested that the new agreement be for a two
year term. On
September 1, 2001, I signed, on behalf of EAW, a new consulting contract
(“Second
Agreement”) with The Gambia for a two year term. President Jammeh was The
Gambia’s sole
negotiator for the Second Agreement.
DCO
Oct. 4. 2004 6:01PM EA GROUP INC No.8103 P. 15
4. No other official from the Gambia was present during the ne
gotiations
for either the First or Second Agreement. President Jammeh is the only
person, besides myself, with direct personal knowledge of what was
discussed and agreed to during the negotiations.
5. The only other official from The Gambia who had any role in the
formulation of the
Second Agreement was Famara Jatta, the former Secretary of State for
Finance and Economic
Affairs. Secretary Jatta requested that we change the proposed date of the
second payment from
December 2001 to February 2002. However, this change was not made until
President Jammeh
and I agreed to modify the date.
6. I have spoken with David Stewart, head counsel for Diplomatic Law and
Litigation at the United States Department of State. He has stated that I
will be notified if The Gambia makes a request for a Suggestion of
Immunity. To date, The Gambia has not made such a request.
7. President Jammeh would have ample time to b
e deposed during one of his
visits to the United States. I accompanied President Jammeb on two of his
trips to the United Nations, in September 2000 and May 2002. President
Jarnmeh canceled approximately half of the meetings which were on his
official schedule and often sent other officials in his place to United
Nations meetings and receptions. President Jammeh spent the majority of his
time on these trips either in his hotel room or shopping.
I declare under penalty of perjury that the foregoing is true and correct,
Dated: September 27, 2004 _____________
John E. Aycoth
DC0U398972.1 — 2 —
Oct. 4. 2004 6:01PM EA GROUP INC No.8103 P. 16
N THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
)
EAW GROUP, INC., )
)
Plaintiff, )
) Civil Action No.
v. ) 1 :02CV02425 (GK)
)
THE REPUBLIC OF THE GAMBIA, ) Pre-trial Conference:
) A
ugust 2, 2004
Defendant, )
PLAINTJ.EF’S RRSPONSFS TO OFFENDAN i’S Th,J IERROGATOR!bS
Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure
Plaintiff EAW Group, Inc. (“BAW”) responds to D efendant The Republic of
The Gambia’s (“The Gambia”) Interrogatories.
GENFRAT OBJECTIONS
1. EAW objects to the Jnterrogatories to the extent that they purport to
impose a greater obligation on BAW than that imposed by the Federal Rules
of Civil Procedure or the Local Rules of this Court,
2, EAW objects to the Interrogatories to the extent that they seek
infoijuation that is not relevant to this action and not reasonably
calculated to lead to the discovery of admissible evidence
3. EAW objects to the Interrogatories to the extent that they purport to
require the disclosure of any information protected by the attorney-client
privilege, the work product doctrine or any other evidentiary
immunity or
privilege.
4. EAW objects to the Interrogatories to the extent that they purport to
require EAW to provide information not within its personal knowledge or
possession as overly broad and unduly
DCOI
Oct. 4. 2004 6:01PM EA GROUP INC No.8103 P. 11
INTERROGATORY NO. 8 Did you ever indicate to the Defendant that you would
accept any offer it may have made conce the contract? If so, state the date
and manner in which the acceptance was communicated, the name and job title
of the person to whom the acceptance was communicated, and what was said or
done by the person to whom the acceptance was directed at the time it was
received.
RESPONSE LAW objects to this Interrogatory because the terms “the contract”
and “any” are vague and ambiguous. Subject to and without waiving the
foregoing objection, EAW did indicate to The Gambia that it would accept
the offer The Gambia made concerning the 2001
 Contract. See Responses to
Interrogatories Nos. 1 and 5.
rNTERROGATORY NO. 9 If the contract was the result of more than one offer
and acceptance, please describe each offer and counteroffer involved by
date and method of communication. Also state the name and address of each
person participating in said arrangement and the name and address of each
person having knowledge of said negotiation.
RESPONSE EAW objects to this Interrogatory because the term “the contract”
is vague and ambiguous. Subject to and without waiving the foregoing
objection, see the Responses to Interrogatories Nos. 1, 4 and 5.
INTERROGATORY NO Did the contract between you and Defendant obligate you to
perform any duties as part of said agreement? If so, state specifically
what duties were to be performed by you, whether you performed all or any
of the duties, and if so, what duties you performed, what duties you partly
performed, a
nd what duties you did not perform.
DCCI :385565.2 9
Oct. 4. 2004 6:01PM EA GROUP INC No.8103 P. 18
R.ESPONSP LAW objects to this Interrogatory because it is overly broad,
vague, calls for opinions and conclusions, and seeks infonnation that is as
easily available to The Gambia as to LAW, RAW further objects because “the
contract” and “said agreement” are vague and ambiguous. Subject to and
without waiving the foregoing objections, RAW agreed to provide public
relations, government affairs and trade and economic development services
for The Gambia. RAW fully performed its duties until on or about The
Gambia’s purported termination on S eptember 3 0, 2 002. A ithough it is
impossible to describe all of the work carried out by RAW in the
performance of the 2001 Contract, the following are some of the examples of
work performed by RAW:
• developing an opportunity for offshore oil drilling, incl
uding meetings
with Amnerada Hess Coiporation;
+ developing an opportunity for the construction of a fuel depot (the Gam
Fuels Project), including meetings with the Republic of South Africa,
Aveng, Grinaker LTA Limited, Engen Petroleum Limited, SRK Consulting,
Standard Chartered Bank, CSU( and HSBC Equator Bank;
+ negotiating for the purchase of airplanes from Bombardier Inc. for The
Gambia’s national airlines and offshore customs projects;
C• developing opportunities for financial investment in The Gambia,
including meetings with KG/Emerging Market Partnership (the largest An-jean
development fund) and Emerging Market Management (All jean investment
fund);
developing an opportunity for the construction of a flour mill, including
meetings with Seaboard Corporation;
DCO1 10
Oct. 4. 2004 6:01PM EA GROUP INC No.8103 P. 19
• developing opportunities for The Gambia
’s textile industry, including
meetings with Guilford Mills, Inc.;
• assisting in selling The Gambia’s mobile phone license, including
meetings with Intercel Holdings, Ltd. and discussions with ORASCOM Telecom;
+ developing an opportunity for the construction of a hotel and golf course
complex. including meetings with Gary Player Design in New York City;
4 expanding The Gambia’s involvement with ongoing health campaigns funded
by the Bill & Melinda Gates Foundation, including meetings with
GlaxoSmithKline PLC;
• expanding The Gambia’s involvement with human lights issues, including
meetings with Human Rights Watch;
4 arranging meetings with US. politicians and government officials,
including but not limited to Congresswoman Cynthia A. McKinney, Congressman
Gregory Meek, Congressman Donald Paine and National Security Advisor
Condoleezza Rice;
• coordinated the issuance o f a
 Apri 2, 2 002 letter from U.S. Congressmen
Edward Royce and Donald Paine urging Presi dent George W. Bush to meet with
President Jammeh;
4 assisting with media opportunities for The Gambia, including arranging an
interview for President Jammeh with the Boston Globe and the Associated
Press;
4• coordinating and planning events on behalf of The Gambia, including The
Gambia’s
36th Independence Anniversary and 37th Independence Anniversary receptions;
4• coordinating and planning The Gambia’s participation in the United
Nations Special Session on Children, including receiving approval from New
York City officials for President Jammeh’s private visit to the Ground Zero
site;
DCO1:385665.2 11
Oct. 4. 2004 6:02PM EA GROUP INC No.8103 P. 20
• assisting the re-election campaign of President Jammeh, including
obtaining
proposals from U.S. campaign consultants to advise President Jarmn
eh’s re-
election
campaign;
• monitoring and reporting all media relating to The Gambia;
+ assisting in the arrangement of wholesale purchases of Gambian fish by
U.S.
companies, including meetings with (John will give namel;
_ + although it was not required by either the 2000 Contract or 2001
Contract, Mr.
Aycoth advanced money on behalf of The Gambia in order to secure lodging
for The Gambia’s visit to the United Nations in 2000 and for medical
expenses;
C’ although it was not required by either the 2000 Contract or 2001
Contract, at the request of President Jamnieh, EAW met with Libyan
officials in Dusseldorf, Germany to discuss a range of investments to be
funded by the Libyan government, including investments in a tomato paste
factory, a fish processing facility, a fruit juice factory, construction of
a hospital and the donation of a power plant;
although it
was not required by either the 2000 Contract or 2001 Contract,
at the request of President Jammeh, during the state visit of the President
of Taiwan Mr. Aycoth attended and participated in meetings seeking to
increase Taiwan’s
• investment in The Gambia’s private and industrial sectors;
_ • although it was not required by either the 2000 Contract or 2001
Conflct, EAW, at The Gambia’s request, procured goods, such as furniture,
hospital equipment, automobiles, trucks, jewelry and clothing;
DCQ1:385 12
Oct. 4. 2004 6:02PM EA GROUP INC No.8103 P. 21
_ + although it was not required by either the 2000 Contract or 2001
Contract, arranging for medical treatment in the United States for
President Jammeh and the First Lady; and
_ • although it was not required by either the 2000 Contract or 2001
Contract, negotiated a renewal lease for The Gambia’s Embassy to the United
States,
 a subsequent lease for the Embassy at a new location; and a lease
for a new residence for Ambassador Bojang.
Other work perfoi”ed by EAW in perfonnance of the 2001 Contract is
contained in documents to be produced by EAW.
INTERR NO 1 1 Did the contract between you and Defendant require Defendant
to perform any duties? If so, state what were the duties Defendant was to
perform, whether Defendant perfoiiiied all or any of the duties, and if so,
what duties Defendant performed, what duties Defendant partly perfoijijed,
arid what duties you allege Defendant did not perform.
RESPONSE LAW objects to this Interrogatory because it is overly broad,
vague, calls for opinions and conclusions, and seeks information that is as
easily available to The Gambia as to EAW. LAW further objects because the
term “the contract” is vague and ambiguous. Subject to and without waiving
the foregoing objections, the 2001 Contrac
t required The Gambia to pay LAW
$1 million, due in two payments of $500,000, the first upon execution and
the second on December 15, 2001. Mr. Jatta requested that the second
payment date of December 15 2001 be changed to February 15, 2002. Based on
that request, and with President Jamineh’s express approval, the second
payment date was changed to February 15, 2002, and the parties initialed
that change in the 2001 C ontract to make it official. The Gambia made the
first payment of
DCQ 13
_________________
-BambaLaye
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"Our lives begin to end the day we become silent about things that matter."
-Martin Luther King Jr.

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