Last set of documents converted. ============================================================================ 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 DCO1 Oct. 1. 2004 1:36PM EA GROUP INC No.8143 P. 2 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. DCO 1: 378057 .2 Oct. 1. 2004 1:31PM EA GROUP INC No.8143 P. 3 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. DC01 :378057.2 Oct. 1. 2004 1:31PM EA GROUP INC No.8143 P. 4 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. DC0U378057.2 Oct. 1. 2004 1:31PM EA GROUP INC No.8143 P. 5 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 DCO1 Oct. 1. 2004 1:31PM EA GROUP INC No.8143 P. 6 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 DCO :378057.2 REOUEST FOR ADMISSION NO. 10 Admit that on September 5, 2000, The Gambia, Oct. 1. 2004 1:38PM EA GROUP INC No.8143 P. 1 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 DC 1: 378057 .2 Oct. 1. 2004 1:38PM EA GROUP INC No.8143 P. 8 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 DCO 378057.2 Oct. 1. 2004 1:38PM EA GROUP INC No.8143 P. 9 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 DCO1 3780572 Admit that EAW arranged the meeting described in the Oct. 1. 2004 1:38PM EA GROUP INC No.8143 P. 10 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 DCO :378057.2 Oct. 1. 2004 1:38PM EA GROUP INC No.8143 P. 11 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 $3,866.00, the items of furniture referenced in the preceding request. RESPONSE: REOT J HST FOR ADMISSION NO 1S Admit that RAW paid for the goods referenced in Request for Admission No. 33. DCC 1: 378057.2 Oct. 1. 2004 1:38PM EA GROUP INC No.8143 P. 12 RESPONSE: RE FOR ADMISSION NO 36 Admit that The Gambia reimbursed EAW for the purchase of the goods referenced in Request for Admission No, 33, RESPONSE: R.EOLEST FOR ADMTSSION NO 17 Admit that in or before to May 2002, President Yahya A.J.J. Jammeh requested LAW to procure one 2001 BMW 75011LP automobile, RESPONSE REQUEST FOR ADMISSION NO. 3$; 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 DCO Oct. 1. 2004 1:39PM EA GROUP INC No.8143 P. 13 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. DCC 1: 378057 .2 Oct. 1. 2004 1:39PM EA GROUP INC No.8143 P. 14 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 DCO 378057.2 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 Oct. 1. 2004 1:39PM EA GROUP INC No.8143 P. 15 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 DCO 78057.2 Oct. 1. 2004 1:39PM EA GROUP INC - No.8143 P. 16 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 DC0U378057.2 Oct. 1. 2004 1:40PM EA GROUP INC No.8143 P. 11 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 DCO :378057.2 Oct. 1. 2004 1:40PM EA GROUP INC No.8143 P. 18 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 DC0I 378057.2 Oct. 1. 2004 1:40PM EA GROUP INC No.8143 P. 19 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 DC0U378057.2 Oct. 1. 2004 1:40PM EA GROUP INC No.8143 P. 20 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 DCCI :378057 Oct. 1. 2004 1:40PM EA GROUP INC No.8143 P. 21 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. DCOI 378057.2 Oct. 1. 2004 1:41PM EA GROUP INC No.8143 P. 22 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 OCO 378057.2 Oct. 1. 2004 1:41PM EA GROUP INC No.8143 P. 23 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 DCO 1: 378057 .2 Oct. 1. 2004 1:41PM EA GROUP INC No.8143 P. 24 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 DCO1 378057.2 Oct. 1. 2004 1:41PM EA GROUP INC No.8143 P. 25 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 ¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤ To unsubscribe/subscribe or view archives of postings, go to the Gambia-L Web interface at: http://maelstrom.stjohns.edu/archives/gambia-l.html To Search in the Gambia-L archives, go to: http://maelstrom.stjohns.edu/CGI/wa.exe?S1=gambia-l To contact the List Management, please send an e-mail to: [log in to unmask] ¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤¤