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I, AKIL ABDUL AMIR AL FADILI AL TAMIMI, declare under the penalty
of perjury and under the laws of the United States of America and
the United Arab Emirates and under the laws of the States of
Massachusetts, New York, California, Florida, Oregon and Nevada
that the foregoing is true and correct.

I am twenty-three years of age. I was born on 7 July 1962. I
presently live in the same State that I was born, Sharjah, in the
United Arab Emirates.

I was the person who took two counterfeit checks in the amounts of
Two Million Dollars and One-Half Million Dollars to the Middle East
Bank in New York City on, or about, 7 June 1982. I attempted to
open an account with these two checks. I told the man who worked
in the bank that my name was Aquil Abdulamiar. I endorsed both
checks with the name of Aquil Abdulamiar. The following is a
chronological explanation of the circumstances surrounding this
incident. It is to the best of my knowledge and recollection.

I travelled to the United States from the United Arab Emirates
about one month before I took the checks into the Middle East
Bank. I flew from Dubai to Boston. I had to change planes in
Paris. I flew on Air France and British Airways. I had purchased
roundtrip airline tickets in the United Arab Emirates. My return
ticket was for an open return, up to one year later.
[signed A. Tamimi]

Page Two

My brother's name is Ala. Ala was living in Saugus, Massachusetts
during this time. Ala's Boston Attorney, Danny Lenzo, picked me
up from the Boston Airpoet. Danny Lenzo said that Ala had been arrested.
We drove to the jail and bailed out Ala. After this, Danny Lenzo, Ala
and I went to the Colonial Hotel in either Lynn or Saugus, Massachusetts,
and ate dinner. The hotel is located on Route One.

I stayed with Ala in his home. About ten days before I took the
checks to the Middle East Bank, Ala began telling me what he wanted
me to do. Ala told me that a Boston Attorney named Michael Flynn
had gotten hold of two legitimate checks from the Bank of New
England in Boston. Michael Flynn gave the checks to Ala. Ala
had counterfeit copies of the checks made. Ala told me that all I
had to do was open the account and deposit the checks. I did not
have to cash the checks and receive money. Ala said that he and
Michael Flynn were going to make the arrangements to get the money
after the checks were cleared in the Bank of New England.

Ala told me that he had decided to use the name "Aquil Abdulamiar"
on both counterfeit checks. Ala chose this name because it's very
similar to some of the words in my real name. Ala changed the spelling
of my real name "Akil" to "Aquil" and changed the spelling and format
of my names "Abdul Amir" to "Abdulamir". Ala said that this would
make it easy for me to use my real passport as I.D. to open the
[signed A. Tamimi]

Page Three

account. All I would have to say was that my name had been
misspelled on the checks.

I practiced writing the signature "Aquil Abdulamiar" over and over.
I did this in Ala's home, under his supervision. He also told things
to do and things to say when I was in the Middle East Bank. We
rehearsed these things over and over.

Ala possessed the business card of a person connected to the Middle
East Bank. I cannot remember his name at this time. Ala told me
that he had spoke to a person on the phone at the Middle East Bank
by the name of Agha Raoof. Ala said that he told this person that
he was a big businessman in Beverly Hills, California. Ala did not
give Agha Raoof his correct name. Ala told Agha Raoof that he
wanted to open an account at the Middle East Bank and dropped
the name of some important person who worked at the Middle East Bank.
Ala told me that he told Agha Raoof that he was too busy to come
to the bank himself and asked Agha Raoof if it would be allright
if his nephew, Aquil Abdulamiar, brought two large checks to the
bank and opened the account. Ala told Raoof that Aquil Abdulamiar
was a student in Washington.

                                                                       [signed A. Tamimi]
I drove with xxxxxxxxxx and met someone/ sitting in a parked
car at a prearranged location. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx gave me an envelope and
said that only I was to ever touch the envelope and its contents.
xxxxxxxxx had a cast on his hand. I noticed it when he handed me
[signed A. Tamimi]

Page Four

the envelope. I took the envelope and took it home. It contained
the two counterfeit checks which I later took to the Middle
East Bank.

I received a phone call from Ala. Ala told me that he was at
the Marriott Hotel in Fort Lauderdale, Florida. Ala told me to
take the counterfeit checks to the Middle East Bank the following
day or the day after. Ala gave me final instructions, including
the flying time to New York from Washington and the weather conditions
for the last few days in Washington. Ala told me that someone might
ask me these questions in the bank. Ala also told me that another
person was going to accompany me to New York, but this person
was not to be seen by anyone at the bank. Ala said that I was supposed
to phone him as soon as I opened the account and just before I was
to catch a plane to Fort Lauderdale.

A day or two later, the other person and I flew from Boston to
New York. I believe that we purchased the tickets when we were
flying on the plane to New York. I think that we flew on Eastern
Airlines. xxxxxxxxxxxxxx waited for me at La Guardia Airport. We
decided on a location to later meet at the airport. Ala had given
me the address of the Middle East Bank. I caught a cab at the
airport and went directly to the location of the Middle East Bank.
I was wearing a grey suit, a white shirt and black shoes. I also
had on a tie.

I had the business card that Ala had given me and the envelope
[signed A. Tamimi]

Page Five

containing the two counterfeit checks. I entered the building and
took the elevator several stories up to the floor where the Middle
                                                                 [initial A.T.]
East Bank was located. There was xxxxxxxxxxx / in the reception
room of the bank. She asked if she could help me. I showed her
the card I had and asked to speak to Agha Raoof. I told her I
was Aquil Abdulamiar. I looked to see if there were any cameras
in the bank, as Ala told me to do, but I didn't see any. She phoned
somebody and told me that Agha Raoof would see me in about five
minutes. She asked if I wanted some coffee.

About five or ten minutes later, Agha Raoof walked into the reception
area from the bank's inner offices located to the right of the
reception room. Agha Raoof greeted me. He appeared to be a Pakastaini
about thirty-five years of age. He was tall and, compared to most
Pakistanis, was light complected.

Agha Raoof asked me to follow him to his office. We walked down
the corridor and turned right. We walked down another corridor, I
                      [initial A.T.]
think to the left, / and went into his room. I don't recall seeing
a window facing outside in his office. I sat down and Agha Raoof
asked me how my uncle was, and when the last time was that I saw
my uncle. I gave him the answers that Ala had rehearsed with me.
About this time, another bank Manager walked into Agha Raoof's
office. I was introduced to this man but I can't remember his
[signed A. Tamimi]

Page Six

Agha Raoof asked me about my flight and how the weather was in
Washington. I told him the things Ala had told me. I was offerred
coffee. I answered all of the questions Agha Raoof and the other
man were asking me, but I never asked them any questions, just
like Ala had told me. During the entire time I was with Agha
Raoof, xxxxxxxxxxxxxxxx would enter the office and then leave. I
cannot recall exactly when he was there and when he wasn't.

Agha Raoof asked me if I had something for him. I handed him the
envelope containing the two counterfeit checks. He removed the
checks and examined them. He made some kind of joke about me
being a rich man. Agha Raoof told me to endorse the checks and
handed me one. I took it between my first and second fingers on
                                                                 [initial A.T.]
my left hand so I wouldn't leave any fingerprint on the check, just
                                                                 [initial A.T.]
like Ala had instructed. I endorsed the check xxx using my
RIGHT  [strike word, overwrite & initial A.T.]
left / hand and pushed the check across the desk to Agha Raoof, using
                                        LEFT  [initial A.T.]
the four fingers on my right / hand. I instantly realized that I
had just put my four fingerprints on the rear of the check. Ala
had told me to never leave any fingerprints on the checks. I was
very nervous the whole time I was in the bank. But when this happened,
I got even more nervous and I became scared. Agha Raoof then handed
me the second check. I took this between my first and second fingers
on my left hand, just like the first check. I turned it over and
signed the check. However, I was now so more nervous after
placing four of my fingerprints on the first check, that I signed
the check wrong. I wrote the name "Aquil" as I was supposed to but
[signed A. Tamimi]

Page Seven

wrote the name "Abdulamiar" not as one word as I should have, but
as two words. I wrote it as "Abdul Amiar". I just left this
check on the desk. I didn't even push it back to Agha Raoof.
Agha Raoof picked up this check and handed me a signature card to
sign. I signed the card. I signed a total of three things in the
bank, the two checks and the signature card.

                                              FOR  [initial A.T.]
Agha Raoof then asked me xx] I.D. I told him that I didn't bring
any because I thought that it wasn't necessary to show I.D. when
all I was doing was opening an account. Agha Raoof told me that
it was necessary and it was really for my protection. I had my
United Arab Emirates passport with me, but I decided not to use
it because I was so nervous. I told Agha Raoof that the embassy,
close to my school, had my passport because they were making some
kind of school recognition papers for me. I told Agha Raoof
that my father always told me to remember my passport number
whenever I travel. I then told him my passport number from memory.
He wrote it down.

Agha Raoof asked me if I could return the next day with I.D. I
told him no because I had tests to take at school the next day and
I had to fly home right after I left the bank. I left the checks
with him. Agha Raoof was very friendly with me. He even gave me
his business card and told me to give his regards to my uncle.

I think I was in the bank for about twenty minutes. I took the
[signed A. Tamimi]

Page Eight

elevator to the street, exited the building and turned left. I walked
two blocks, as Ala had instructed, and took a cab to La Guardia
Airport. I met xxxxxxxxx who flew with me to New York at the
prearranged location. He gave me a phone number to call. I phoned
Florida and spoke with Ala. I told him that I had left the checks
at the bank and the deal was on. I told Ala the flight that xxxxxxx
xxxxxxxxxxx and I were going to take to Fort Lauderdale.

xxxxxxxxxxxxxxxx and I flew from La Guardia Airport to Atlanta,
Georgia. We changed planes and flew to Fort Lauderdale. When we
landed, we were met by Ala's bodyguard, xxxxxxx xxxxxxxxx
told me that he would watch my belongings and directed me to go
outside and talk with Ala. I went outside and saw Ala standing.

Ala and I took a little walk. He asked me what had happened. I
told him everything. He got very mad when he found out that I
was not given an account number and had left the checks at the
bank. Ala told me that after I had phoned him from La Guardia
Airport and told him the deal was on, he phoned his people in
Boston and told them that the account had been opened and the
checks deposited. After a while, Ala calmed down and told me that
I had done my best and to not worry. I had never opened an
account at any bank in my life and really didn't understand the
procedures. I was scared and nervous in the bank.

xxxxxxxxxxx drove all of us to the Marriott Hotel in Fort Lauderdale
[signed A. Tamimi]

Page Nine

The person who flew with me shared a room with me. Ala and Al
Fortucci shared another room. The two rooms had an ajoining door
between them. Ala and the rest of us stayed there another four or
five nights before leaving.

Twice during the stay, Ala told me that Michael Flynn was going to
pick him up in the evening. I asked Ala if I could go with them.
Ala said that Michael Flynn had given instructions that I was
to never meet him or be seen with him. However, the second evening
that Ala and Michael Flynn went out, I xxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx . I decided to walk Ala
to the front door of the hotel, next to the lobby. As we got to
the front door, I saw Michael Flynn in the driver's seat of a large,
dark colored, American car. The car was parked in the driveway,
about 20 meters from the front door. The car xxxxxxxxxxxxxxxx
Michael Flynn was looking in our direction. As soon as we got to
the doorway, he got out of the car, walked behind it and walked
to the passenger door. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx Ala
told me that he was going, indicating xxxxxxxxxxxxxxxxxxxxxxx. I
immediately stopped, about one meter outside the doorway and watched
Ala walk over to Michael Flynn. I had xxxxxxxxxxxxxxx of
Ala and Michael Flynn. They shook hands, then Michael Flynn
opened the front passenger door for Ala and Ala got in the car.
Michael Flynn walked around the front of the car and got in the
driver's seat. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx

I walked thru the lobby and thru the hallway into the nightclub in
[signed A. Tamimi]

Page Ten

the hotel. I sat with xxxxxxxx and xxxxxxxxx. About one
or two hours later, Ala returned to the hotel and met us in the
nightclub. The nightclub has a disco and live entertainment area
plus a restaurant.

After we checked out of the hotel, Ala and I flew together from
Fort Lauderdale to Boston. My brother, Amer, picked us up at
Logan Airport in Boston. He drove us to Ala's home in his 928
black Porsche.

The next day, Ala told me that the checks got caught and that Michael
Flynn wanted me to get away from Boston as soon as possible. xxxxxx
xxxxxxxxxxxxxxxxx picked me up and Ala told me to go
with him xxxxxxxxxxxxxxx He drove me to a ski resort area
close to Portland, Maine. I had a room on the first floor of the
hotel. I think the hotel was two storys high. There were also
small cottages on the property. I stayed there by myself. Because
[initial A.T.]
iT wasn't the ski season, very few people were staying there.
The restaurant wasn't even open.

I stayed there about two weeks. When I was hungry, I had to walk
to a delicatessen store about one mile away. About 300 meters
past the delicatessen was a small pub where I would occassionaly
have a drink.

Ala and xxxxxxxxxxxxxxxxxxx visited me at this hotel a couple
[signed A. Tamimi]

Page Eleven

times. Once, the three of us went for a ride to Vermont. During
this ride, I overheard Ala and xxxxxxxxxxx talking about Michael
Flynn and his involvement in the check forgeries.

About four weeks after this, I flew home to the United Arab Emirates
from Boston.

Additional information: xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx I saw Ala get in
the car with in Fort Lauderdale, as I have previously stated. I
know this man to be Michael Flynn. I have affixed the fingerprint
of my right thumb, using purple ink, to the rear of the photograph.

The signatures directly below which read "Aquil Abdulamiar" were
written by me. This was how I endorsed the first check in the
Middle East Bank in New York City.

[signature Aquil Abdulamiar]

[signature Aquil Abdulamiar]

                                                                                     BLACK [initial A.T.]
In addition, I have affixed all ten fingerprints, in purple / ink,
to the last page of this declaration. This is on Page Twelve. I
                                                                           BLACK [initial A.T.]
have also affixed my right thumbprint, in purple / ink, to the top
[signed A. Tamimi]

Page Twelve

right corner of each page of this declaration.

The previous statements were made freely and voluntarily. They
are true and to the best of my knowledge.

Signed in Dubai, United Arab Emirates, this 10th day of May, 1984.
[signature Akil Abdul Amir Al Fadili Al Tamimi]

[Signature Eugene M. Ingram] 10 MAY 1984
Witnessed by Eugene M. Ingram
Private Investigator
California License Number AA9387
1212 North Vermont Avenue
Los Angeles, California 90029


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