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I, Ala Fadili Al Tamimi, declare under the penalty of

perjury and under the law of the United States of America

and under the laws of the states of Massachussetts, New

York, California, Florida, Oregon and Nevada that the

foregoing is true and correct.

          Sometime in March/Apri1,1982, I went to see my lawyer,

Mr. Gary Pappas, at his office on Union Wharf in Boston,

Massachussets. I was welcomed by a woman receptionist on

the first floor. She told me that Mr. Pappas was not in

his office and that Mr. Pappas' secretary was out of the

office having lunch.

          The receptionist picked up the phone and told someone

that I, Mr. Tamimi, was there. Mr. Wayne Hollingsworth

came out into the reception area from his office and said,

"Hello Ala". He shook my hand and invited me into his

office. Mr. Hollingsworth and I went into his office.

The secretary then brought us two cups of coffee. Mr.

Hollingsworth introduced the receptionist as his wife,

Mrs. Hollingsworth. I thanked her for the coffee.

          Mr. Hollingsworth is a lawyer. His partner was Mr.

Pappas. Mr. Hollingsworth's office is on the ground floor

and his wife is his secretary. Mr. Pappas' and another

lawyer, Danny Lenzo, and their secretary are on the

second floor. [Signature] Ala Fadili Tamimi


Page 2

          This was not the first time I met Mr. Hollingsworth.

The first time we met was about three or four months

before at the Liberty Bank and Trust Company. This bank

is located on School Street in Boston, Massachussetts.

Mr. Hollingsworth and Mr. Pappas were at the bank doing

business. I also banked there. Mr. Pappas introduced Mr.

Hollingsworth to me. After that first meeting, we had

said hello to each other when I visited Mr. Pappas and

Mr. Lenzo at the Union Wharf offices. Up to that time

I had never been involved in any type of business with

Mr. Hollingsworth.

          Going back to the March/April, 1982, visit in Mr.

Hollingsworth's office, Mr. Hollingsworth started asking

me all kinds of questions about my business and the things

that I had been doing, however, he never gave me a

chance to speak. Mr. Hollingsworth then started telling

me about himself. He said that he use to work for the

FBI and the Federal Courts. He also said that he has

many friends in the Federal Government. Mr. Hollingsworth

then started speaking about the possibility of someday

doing business with me. It looked like he was waiting

for me to say something.

          Mr. Hollingsworth knew a lot about me. He told me

about the problem I was having with my partner, Mr.

[Signature] Ala Fadili Tamimi


Page 3

Nick Abraham. He also knew about my dealings with Mr.

Jurgens of West Germany. This shook me up because I

didn't know if he still had an association with the FBI.

          Mr. Hollingsworth's phone rang. He answered it and

told me that Danny Lenzo just returned to his office.

As I began to leave and was shaking hands with Mr.

Hollingsworth, he looked right into my eyes, with a

small smile on his face, and asked, "How is your brother

Amer?" I told him he was fine and asked him why he had

asked and how he knew Amer. Mr. Hollingsworth told me

that he didn't know Amer, however his friends knew

Amer and that he and I should discuss Amer. I asked

what was going on with Amer. Mr. Hollingsworth then

told me to promise to never tell anyone, including

Mr. Pappas, Mr. Lenzo, Amer and everyone else, what he

was about to tell me. I promised this to him.

           Mr. Hollingsworth then told me that my brother, Amer,

had been sports gambling, with big boys in town. Amer

had won about $80,000. But Amer lost about $40,000

four weeks ago and has not yet paid the gambling debt.

Thus, the boys in town are very mad and they can break

his legs. Mr. Hollingsworth asked me if I understood him.

Mr. Hollingsworth told me that maybe he could help and

asked me to call him. We said goodbye and I left his office.

[Signature] Ala Fadili Tamimi


Page 4

           I then spent about ten minutes with Mr. Lenzo. I

then used Mr. Lenzo's phone and called Amer. I told him

I would pick him up.

           Amer's full name is Amer Fadili Al Tamimi. At this

time (1982) , he was a student at Northeastern University

in Boston, Massachussetts. He was living in the Fellsview

Terrace Apartments, Apartment Number 113, in Stoneham,

Massachussetts. This building was owned by my older

brother Adel Fadili Al Tamimi. Amer is presently (1984)

living with my parents in Sharjah, United Arab Emirates.

           I then drove in my Cadillac Seville and picked up

Amer. We went to the Hilltop Restaurant in Saugus,

Massachussetts. I questioned Amer about owing anyone

$40,000. Amer told me that he must pay xxxxxxxxxxxx

$40,000. Amer said that xxxxxxxxx and his people have

been after him for three weeks. Amer explained everything

to me. Amer wanted to know how I knew about the gambling

debt. I merely told him that I had found out. I didn't

mentioned that Mr. Hollingsworth had told me.

           I then used a pay phone at the restaurant and

phoned Mr. Hollingsworth. I asked him if it was possible

to meet that night over drinks. Mr. Hollingsworth said yes.

           Later that day, at about 7:00 PM, I met Mr. Hollings-

worth at a restaurant close to Union Wharf. I believe

[Signature] Ala Fadili Tamimi


Page 5

it's called "Josephes" or something similar. I walked

in and he was standing at the bar. We shook hands.

Mr. Hollingsworth bought me a drink and started telling

me more about Amer and the $40,000 gambling debt. I

told Mr. Hollingsworth that I had spoken with Amer about

the gambling debt. I told Mr. Hollingsworth that I never

mentioned any names to Amer, and that Amer was very

worried and that there were people bothering him about

the debt. I told Mr. Hollingsworth that Amer had no

money to pay the gambling debt. I also told Mr. Hollings-

worth that I wasn't going to pay the debt because it

was a gambling debt, rather than a debt for

something Amer had purchased.

           Mr. Hollingsworth then told me to listen to him

carefully. He said that he only had a few minutes

because he had to return to his office and meet his

wife. Mr. Hollingsworth told me that it was possible

that Amer wouldn't have to pay any money, to xxxxxxxxxx

not even one dollar, if I did some business with those

boys in town. Mr. Hollingsworth told me that those boys

knew me well and liked me, believe it or not.

Mr. Hollingsworth stated that the "business" meant

working with lawyers and classy people. He said I could

make myself big money. Mr. Hollingsworth then told me,

[Signature] Ala Fadili Tamimi


Page 6

"As I told you before in my office, I know everything

about you. You like to play and I have a nice game for


           Mr. Hollingsworth said that he and his friends knew

they could trust me. He asked if I was willing to do

some business. He then said that he could arrange a

meeting soon because the "game" must be done. Mr. Hollings-

worth said that this was big money, more than the German

deal. He asked if I knew what he meant. I told him to

continue. I then asked him how much money he was speaking

about and how much money would I receive. Mr. Hollings-

worth told me the deal was for two or three million

dollars and maybe even more. He said I would get 20%

in my pocket. I asked Mr. Hollingsworth when the deal

would happen and who was involved. Mr. Hollingsworth

said the deal would take place in the USA and I would

make good friends with the people I met. These peole

would also help me with my German problem with Mr. Jurgens.

Mr. Hollingsworth also added that he could help me with

my German problem because he knew all the FBI agents

in Boston and most of the United States Attorneys. He said

that I would be doing business with smart people and that

I would see that what he was telling me was true.

           I told Mr. Hollingsworth okay. I told him that I

[Signature] Ala Fadili Tamimi


Page 7

like to make money and I would be happy to meet good,

new friends. I then asked about Amer's situation.

Mr. Hollingsworth told me not to worry about it for

the time being and to just leave it all up to him.

Mr. Hollingsworth told me to trust him. He also told me

to please tell Amer to stay away from gambling. I told

Mr. Hollingsworth okay and thanks. I then asked what

was to happen next. He told me to phone him at about

11:00 AM the next day. He said that he must first clear

Amer's problem, and then he would tell me where to go

to meet a friend. He said he would take it from there.

           Mr. Hollingsworth told me that he had to leave.

We both left the restaurant. I asked him if he needed

a ride to his office and he said no thank you and I

told him I would call him the next day.

           The next morning, I called Mr. Hollingsworth at

his office. He told me to go to Kenmore Square in Boston

and meet xxxxxxxx. xxxxxxxxxx would be sitting in a black

Mercedes Benz sports car, parked in front of the Greek

Restaurant. Mr. Hollingsworth told me that he would be

at his office until 6:00 PM and told me to phone him

later. He wished me luck and said goodbye.

           At noon I drove to Kenmore Square, saw the black

Mercedes Benz and pulled up behind it. xxxxxxxx driving

[Signature] Ala Fadili Tamimi


Page 8

the Mercedes Benz waved his hand, indicating I should

follow him. I followed him. About five minutes later,

he pulled into a small parking lot of a motel on Boylston

Street. I parked my car next to his. We shook hands and

he said hello Ala. He introduced himself as xxxxxx

           xxxx and I walked into the small restaurant at the

motel. We walked over to a gentleman dressed in a dark

suit, having a cup of coffee. The man stood up and said,

"So you are Ala". He said his name was xxxxxxxxxx.

xxxxxx said he knew my brother Amer. xxxxxx

invited xxxx and I to sit with him at his table. We

all drank coffee. xxxxxxxx told me that Amer was a

nice boy and he liked him. xxxxxxxx told me to not

worry about Amer and the $40,000 gambling debt. xxxxxxxxx

said that I was his friend now and that Mr. Hollingsworth

was a good friend of his who had spoken good things about

me. xxxxxxxx continued talking and told me that he

wanted to meet me and tell me personally that no one

would bother Amer anymore. xxxxxxxx also said that

Mr. Hollingsworth told him that I was going to join

them for some business dealings. I told xxxxxxxx

that was correct and that I was very happy to do business

with him.

           xxxxxxxx then asked me if I liked to make big money.

[Signature] Ala Fadili Tamimi


Page 9

I answered I sure did. I asked him the same question.

xxxxxxxx told me that he wasn't joking. He said that

there are big, nice and important people involved in

what we were going to do. He said that if I work with

them and do good, the deal was a real big one, coming

very soon, that was in the millions of dollars. He asked

if I knew what he meant. I told xxxxxxxx that he had

lost me and that I didn't know what he was talking about.

I asked him what it was that we were doing and what it

was that I could do for him. xxxxxxxx said that it

wasn't "We" it was "Me" that was doing it and he knew

that I would do the best.

          I asked xxxxxxxx to tell me about the deal.

xxxxxxxx said that the deal was between two and three

million dollars in counterfeit checks. He told me that

he would introduce me to another friend of his. This

friend was a very good friend of his and Mr. Hollingsworth.

The friend was also a lawyer with offices on Union Wharf,

he told me. I asked xxxxxxxx for the friend's name.

xxxxxxxx told me that I would meet him soon. I told

him okay.

xxxxxx then told me that xxxx was his personal

friend. xxxxxx told me that xxxx would be the one

who would be in touch with me about the deal. xxxxxxxx

[Signature] Ala Fadili Tamimi


Page 10

warned me to be careful to never tell anyone about meeting

him, not even Amer. He also told me to tell Amer that I

had taken care of the $40,000 gambling debt for him.

           xxxxxx told me that xxxx would phone me the next day

at 10:00 AM. He said that we would have another meeting.

He stood up and we shook hands. I told him that it was

nice meeting him and I left.

           xxxx phoned me at about 10:00 AM the next day.

xxxx asked if I could meet him sometime that afternoon.

We agreed to meet at 2:00 PM in the parking lot of

the Palace Disco Night-club in Saugus, Massachussetts.

We met at 2:00PM and xxxx was driving the same Mercedes

Benz. xxxx asked if I was free the next day so I could

meet xxxxxxxxx for breakfast at the Collonaide Hotel

in Boston, Massachussetts, at 10:00 AM. I told xxxx that

was fine. xxxxxx then said that xxxx had also

instructed that I park my car somewhere in Boston and

take a taxi to the hotel. xxxx and I were together

about five minutes then we each left.

           The following day at about 9:30 AM, I parked my

car in Quincy Market in Boston. I then went by taxi

to the Collonaide Hotel. I arrived at the hotel a few

minutes before 10:00 AM. xxxx was in the lobby and said

good morning to me. I said hello and we both walked into

the restaurant. I saw Mr. Hollingsworth, xxxxxxx and

[Signature] Ala Fadili Tamimi


Page 11

another man sitting at a table in the restaurant. I

said good morning to everyone and shook hands with

Mr. Hollingsworth and xxxxxxxx Mr. Hollingsworth

told me to say hello to Michael Flynn. I said hello

to Mr. Flynn. Mr. Flynn said "Hi Ala, nice to meet you".

We all had breakfast and the others were talking

about sports. Then Mr. Hollingsworth asked me how

Amer was. I told him Amer was fine. xxxxxxxx said

that he liked Amer and that Amer was a nice boy.

I told xxxxxxxx thanks.

           Just after this, Mr. Flynn looked at me and asked

if they were going to make money with me or if I was

going to run away with the money. I answered Mr. Flynn

by asking him which money he was talking about, and

what did he mean. Everyone else at the table was looking

at Mr. Flynn and me as we talked. Mr. Flynn told me

that he knew more about me than I thought. He said I

was a very intelligent and smart man but that I needed

good advise before I did my business. Mr. Flynn told me

that whatever I did he would like to advise me and

make money with me. He said we would have good relations

and make good money. Mr. Flynn said that he and everybody

at the table all liked me, trusted me and we all had

a great chance to make over two million dollars within

[Signature] Ala Fadili Tamimi


Page 12

45 days. Mr. Flynn told me that if I was willing to work

with them and to make money that I would get 20% of the

deal. Mr. Flynn told me that if I was ready I must move

fast starting today. I told Mr. Flynn I was ready.

           Mr. Flynn told me, "Okay, Ala, hear me well. First,

I trust you so do not fuck us because you have a brother

and son in Boston - so let's be friends". Mr. Flynn said,

"Hear me well, this is the baby".

           It was now about 11:00 AM. Everyone of us was looking

at Mr. Flynn and giving him our complete attention.

Mr. Flynn was looking at me and started speaking.

Mr. Flynn said to me that he had a great connection in

the Bank of New England in Boston, and the connection

was a man who could be trusted. The man at the bank

would give us inside bank information like which accounts

were good. Mr. Flynn said that he and his man at the bank

were all ready and they know which accounts were good

and which accounts we were going to get. Mr. Flynn said

that the man at the bank is also going to bring us

legitimate checks to make copies of, but, we could

only keep these checks for four days. The man at the

bank can remove the legitimate checks for us but he

must return them so they can be sent back to where they

belong. Mr. Flynn was still looking at me and asked me

[Signature] Ala Fadili Tamimi


Page 13

if I understood. I told him I did and said to continue.

Mr. Flynn continued telling me that this man at the

bank is going to process the counterfeit checks through

the computer and clear the checks. The checks will then

be held at the bank and no one will find out for about

15 days. Mr. Flynn said that all he cared about is

that the checks cleared. Mr. Flynn was still looking

at me when he spoke.

           Mr. Flynn then said that my part was to find

someone who would make the checks. I would only have

four days from the day I got the legitimate checks to

do the work that had to be done, and the work needed

to be done well. Mr. Flynn said that he knew that I had

the connections and could do it. Mr. Flynn told me that

after I have the checks made he will have to see them

and proof them. Mr. Flynn said that was first. Second,

he said I must deposit the checks in a bank and make

arrangements with that bank to make a telephone transfer

to anywhere I want. He said that to do this I must go

to an international bank, but, he said, that was my part

of the operation.

           Mr. Flynn said that he wanted me to deposit the

checks in a bank, leave $100,000 at that bank and transfer

all the rest of the money out. Mr. Flynn said that he

[Signature] Ala Fadili Tamimi


Page 14

would take care of the rest. He said the money would be

going outside the USA. Mr. Flynn said that my part would

be to make the checks and have them deposited. Mr. Flynn

said that his part will be to clear the checks and send

the money back to the bank account I opened. Mr. Flynn

said that then I would transfer the money from this bank

account and he would make the collection arrangements

for the cash. Mr. Flynn asked me if I understood the deal.

I told him I did.

           Mr. Flynn told me to never phone him, Mr. Hollingsworth,

xxxxxxxx or xxxx In addition, I was to never visit

them at their offices or keep their names or telephone

numbers to make it appear like I never met them or knew

them. Mr. Flynn said that we would meet again and have

drinks outside the USA. Mr. Flynn told me that xxxxxx would

contact me on a daily basis but I was never to speak on

the phone. xxxx would phone me and then we would meet

in person and conduct business. Mr. Flynn said to me

that xxxx would be the man who would speak for all of

them and asked if I understood this. I said I did.

           I asked Mr. Flynn when I would be getting the

legitimate checks and who would be paying my expenses.

Mr. Flynn smiled and told xxxxxxxx that he thought I

was ready to move that day. Everyone started joking and

[Signature] Ala Fadili Tamimi


Page 15

they had big smiles. Mr. Flynn looked at me and told

me that xxxx would be calling me in two days and by that

time I should have my homework done and should know what

I needed. I told Mr. Flynn okay.

          I looked at xxxx and told him to call me at about

11:00 AM in two days. xxxx said okay. The breakfast

meeting ended just before 12:00 noon.

           The next day, I met with a friend of mine named

xxxxxxxxxx. xxxxx is in the printing business and

has many friends. I told xxxxx that I had a little

business that I wanted him to do for me but he must get

me the best printer in town.

           xxxxxxxxxx is always hungry for a dollar. He's

always broke. He dresses well but never has any money

in his pocket because he spends it on cocaine. I told

xxxxx that I needed someone to make me some bank checks

within a two day time limit and the job must be the best.

So I told xxxxx to go and find the best man for me and

tell him to get ready to print the checks for me.

          The following day xxxx called me and we met at the

Hilltop Restaurant in Saugus. xxxx told me I should be

getting ready because I would be getting the legitimate

checkes in about a week. xxxx also asked me what I needed.

I told xxxx I needed $25,000 for front expenses. xxxx

[Signature] Ala Fadili Tamimi


Page 16

said it was too much money. I told xxxx to go and ask

Michael Flynn for $25,000 and tell him I need by tomorrow.

I needed the money to prepare many things and pay people

up-front. xxxx said okay, but said he thought it was too

much money. xxxx told me he would call me that night or

the next day.

           xxxx called me the next morning and we later met

at the Hilltop Restaurant in Saugus. xxxx brought me

$10,000 cash and told me he would bring me the other

$15,000 soon. We parted.

           xxxxxxxxxx started calling me two or three

times a day for a week to meet his friend the printer.

xxxxxx wanted to make the fast dollars for finding me the

right printer.

           It had now been about a week since the breakfast

meeting and I was still waiting for xxxx to bring me

the legitimate checks.

          A day or two later, xxxx called me in the early

morning to set up a meeting. I met him at 4:00 PM in

"Dunkin' Donuts" close to Union Wharf. xxxx gave me an

envelope and told me it contained five checks. He said

he had just gotten the envelope and checks from Michael

Flynn. xxxx said I must return the checks back to him

within four days. xxxx said Michael Flynn sent his

[Signature] Ala Fadili Tamimi


Page 17

regards, wished him good luck and said to be careful with

the checks.

          I then met xxxxxxxxxx and xxxxxxxx for

dinner in a restaurant on Newbury Street in Boston.

I had the envelope containing the five checks. One check

was from Florida. I think it was green and had in the top

left corner a picture of fruits, maybe three or four

oranges. This Florida check was a cancelled check which

had been processed through the bank. It had been signed

and had the money numbers on it. The other four checks

were from the Cash Reserve Management of the Bank of

New England in Boston. One of the four checks was cancelled

by the bank. It had been signed, dated and it was in an

amount in excess of a million dollars. The other three

checks where also from the Cash Reserve Management.

These were new checks, but they weren't to be used

except to help the printer.

           During the dinner with xxxxxxxxxx and xxxxxxxx,

I showed the checks to the printer. He started looking

at them . He said it was not going to be an easy job.




how much it was going to cost. I told him that I needed

[Signature] Ala Fadili Tamimi


Page 18

ten checks of each legitimate check, twenty checks total,

and I needed all the checks in two days. xxxx said it

would be impossible to make the checks in two days

because the job required special inks and other materials.

I explained to xxxx that I must return the five checks in

three days. xxxx said that would be no problem because

he could take special photographic pictures by the next

night and finish the job after this. xxxx said he could

returned the five chckes to me in two days.

          I asked xxxx how much money he was going to charge.

He said $5,000 for his labor. In addition, he needed

some materials and didn't know how much they would cost.

He thought it would not be more than $1,000. xxxx promised

me he would do excellent work.

           We made the deal. I gave xxxx $2, 000 in front. I also

gave xxxxxx $1,000 and promised xxxxxxxxxx that I

will give him another $1,000 when the checks were ready.

xxxxxx thanked me and said that he needed the money, xxxx

then took the five checks in the envelope and the $2,000

at the dinner table.

          We started having dinner and xxxx said he was xxxxxx




[Signature] Ala Fadili Tamimi


Page 19

xxxxxxxxxxxx. The big boss lives in Florida

and xxxxxxxxxxxxxx does his dirty private

work alone at night when all the employees go home. The


xxxxxx. After dinner, xxxxxx left with the checks and the

$2,000. I made arrangements to meet with xxxx and xxxxx

xxxxxxxx two days later in Quincy market in Boston.

           Two days later we all met as planned. xxxx brought me

the checks back along with a list of things he needed.

           I had previously made plans to meet xxxx after the

meeting with xxxx and xxxxxxxxxx We met at the

"Dunkin' Donuts" near Union Wharf about 6:00 AM. I

explained to xxxx that the checks were not going to be

ready in one week but, would be ready in about three weeks

because we could not find the ink. I assured xxxx that

the checks would be done very well when completed. I

told xxxx I was done with the five checks and gave them

back to him. I told him about the list of things my

printer needed. I gave him the list to show it to Michael

Flynn. xxxx asked me to meet him again in one hour at

the same "Dunkin' Donuts".

           xxxx walked to Union Wharf. I bought a newspaper

from the newspaper box machine. I did not leave "Dunkin'

Donuts". About forty minutes later xxxx returned. xxxx

[Signature] Ala Fadili Tamimi


Page 20

told me that he just spoke with Michael Flynn and that

Mr. Flynn is mad. xxxx said Mr. Flynn must speak with

the inside man at the bank and xxxx would meet me again

the next day.

           xxxx called me the next day and told me he would call

me in a few days. He told me that he is going to get

everything on xxxxx list for me. xxxx said everything

was okay and he would be in touch in about a weeks time.

          About ten days later, xxxx called me and asked me

to meet him at the Palace Disco parking lot in Saugus.

I met xxxx and he gave me three boxes. xxxx said that

the boxes contained everything I asked for and added

that everything had to be gotten from outside of Massa-

chussetts. xxxx also told me that Michael Flynn had said

that the checks must be ready before the end May 1982 and

that Mr. Flynn also said that I must be ready to open

the account and deposit the checks at the begining of

June 1982. I asked xxxx to call me in two days.

           That night, after getting the boxes from xxxx I

was driving my black 928 Porsche. I had the boxes in my

car and had been out all night drinking. The following

morning I was driving somewhere in Revere, Massachussetts

or in Everette, Massachussetts. I made a wrong turn and

the M.D.C. Police stopped me. One officer was white and

[Signature] Ala Fadili Tamimi


Page 21

the other was black. They checked me through the computer,

using the radio in the police car. There was a warrant

for my arrest.

           The M.D.C. Police arrested me and checked my car.

The police found the different inks and the scale and

other things. They asked me what the things where for.

I told them the items were samples going to Saudia Arabia.

The police took me to the Revere Police Station. I was

fingerprinted and photographed and then taken to the

Peabody Police Station. I was released the same day.

           Two days later, in the evening I met xxxx , the printer,

in a parking lot of a shopping center in Brockton. I gave

all the things I got from xxxxxxxx. He told me every-

thing he needed was there. I asked how long it was going

to take him to make the checkes. He asked me to call him

at work or at home and gave me his two phone numbers.

I was in touch with xxxx every day and every night. I also

visited him twice at night at work. After about 7 days,

he finished the job and gave me the checks. The checks

were perfect. He did excellent work. I gave him $3,000

and I gave $1,000 to xxxxxxxxxx.

           xxxx had been calling me every day but I never met

with him because the checks were not ready. Finally, I

met xxxx during the afternoon in the same "Dunkin' Donuts".

[Signature] Ala Fadili Tamimi


Page 22

I gave xxxxxx the checks and I asked him to get me $15,000

that night.

           Later, I met with xxxx again. xxxx had a big smile

on his face. xxxx said Michael Flynn loves the checks

and he had asked Mr. Flynn to get the $15,000 that night.

xxxx also added that Michael Flynn said the checks were

perfect, especially the signatures. xxxx said that Mr.

Flynn sent his regards to me. xxxx then said that Mr.

Flynn said he was going to put the numbers, names and

dates on the checks but we must wait for Mr. Flynn's man

at the bank to tell us when. xxxx said that Mr. Flynn

needed to know from me the name that will go on the checks

and reminded me that it has to be the same name opening

the account at the bank. I told xxxx that I would give

him the name within two days. I then asked xxxx where

the money was. xxxx said that he was going to get all

the money right then. He asked where he could meet me

that night. I told him I would be at the Palace Disco

in Saugus. xxxxxx came to the Palace Disco that night

and gave me the $15,000.

          I had arranged for xxxxxxxxxx from the North

End of Boston, to open the account using the counterfeit

checks. I had false identification for him. However, I

could not locate him. I don't know where he went I had

[Signature] Ala Fadili Tamimi


Page 23

no one to use to go to the bank for me.

           I had already chosen which bank I was going to use,

the Middle East Bank in New York City. This bank is owned

by the Al Fotame family, from the United Arab Emirates.

They are Arabs. The bank is managed by Pakistanies. Most

Pakistanies are stupid and I thought they process the

checks. I have met the manager of this bank in the past

and had his personal card. I chose the name Aquil

Abdulamiar to go on the checks and decided to use my

brother, Akil Fadili Al Tamimi, to present the checks

and open the account at the Middle East Bank. Akil's

long Arabian name is Akil Abdul Amir Fadili Al Tamimi.

I changed the spelling of Akil to Aquil and changed

Abdul Amir to Abdulamiar. This gave the name more of an

Italian spelling, yet would still enable Akil to use

his real name to open the account or transfer money.

           A few days after meeting with xxxx, I told him what

name to tell Michael Flynn to put on the checks and to

also inform Michael Flynn that I was ready to open the


           Sometime in early June 1982, I met with xxxx in

Boston. xxxx gave me an envelope with $5,000 and said

that it was from Michael Flynn to me. xxxx gave me another

envelope from Michael Flynn which had the two counterfeit

[Signature] Ala Fadili Tamimi


Page 24

checks. xxxx also told me that Michael Flynn wanted me

to check into the Marriott Hotel in Fort Lauderdale,

Florida, one day after the account is opened and the

two checks are deposited. Michael Flynn said that he

will also be in Florida at this time. Mr. Flynn will

contact you at the Hotel. xxxx then said xxxxxxxxx sends

his regards and wishes you good luck.

           Two days before the checks were deposited I called

the Middle East Bank in New York City and spoke with the

manager. I told him my name was Hamedi and I was calling

from the Beverly Hills Hotel in Los Angeles California.

I told him that I was from the United Arab Emirates and

good friends of the Al Fotame family and I was doing

some business in the United States. I told him I would

like to open an account with the Middle East Bank but

I cannot find the time and I do not know when I'll be

in New York. The manager was very nice to me. He said

that he wished to see me soon and meet me. I was building

some friendly relationship with him on the phone. Then

I told him I would be in touch and would call him again.

           The next day I called the Bank and spoke with the

manager again. I told him I was not sure when I would

be coming to New York. My bother's son was a student in

the USA and he was going to deposit two checks which

[Signature] Ala Fadili Tamimi


Page 25

I received from people I had sold real estate to. I asked

the manager of the bank to deposit the checks and told

him the boy's name is Aquil. I asked the manager to help

Aquil with what needs to be done to open the account.

He said he would. He was very nice and told me that he

hoped to see me soon.

           Akil went to the bank and met the manager. Akil

gave him the checks and did his best to open the account.

Akil either forgot his real identification or decided

not to use it. Akil later told me that he was real nervous

in the bank. I also had a man go with Akil. This man

waited outside. After Akil left the bank, he flew to

Florida and met me. I was already in Florida with my

bodyguard, xxxxxxxx.

           Two days later, I received a phonecall from Michael

Flynn. I was at the Fort Lauderdale Marriott Hotel.

Mr. Flynn asked to have dinner with me that evening.

At 8:00 PM I was waiting outside the front door of the

Hotel for Mr. Flynn. A long dark American car pulled up.

Mr. Flynn was driving. Mr. Flynn stopped the car, came

out, shaked my hand and opened the door for me. He was

showing respect for me. We left in his car. He drove

over a bridge, next to the hotel, and headed towards the

Atlantic Ocean. We drove for about ten minutes and

[Signature] Ala Fadili Tamimi


Page 26

arrived at a sea food restaurant. Mr. Michael Flynn told

me that the car he was driving was a rented car. The

restaurant was on the coast. It was in the same area as

a real tall building which I think is a hotel. I think

the building has a revolving restaurant.

           At the sea restaurant, Mr. Flynn told me he had

opened an account in the Cayman Islands. Mr. Flynn said

that as soon as the checks clear in Boston, he will know.

Then, two days later, the money will be in the New York

account. Mr. Flynn said that I would then make the

arrangements to transfer the money to the Cayman Islands.

           I asked Michael Flynn to give me the details of

the Cayman Islands account, the name of the account and

the name of the bank. Mr. Flynn said as soon as the money

cleared in the Boston bank and his man called him from

the Bank of New England, he would give me all the details.

           Michael Flynn kept talking throughout dinner.

Mr. Flynn told me that I was supposed to meet him and

Wayne Hollingsworth in the Grand Cayman Island, after

I made the money transfer, and Mr. Flynn would give me

half a million dollars in cash. After dinner, Mr. Flynn

drove me back to my hotel and said that he would call me.

           Michael Flynn phoned me three or four days later

at my hotel. He told me he would pick me up at 8:00 PM

[Signature] Ala Fadili Tamimi


Page 27

and we would go for a drink. I was a few minutes late

and Akil walked me to the front door of the hotel. As

we approached the front door, I saw Mr. Flynn standing

outside next to his car waiting for me. Akil went to

the hotel bar and I walked over to Mr. Flynn. We shook

hands. He again opened my door and we drove to the same

area as the sea food restaurant. Mr. Flynn took me to

a nice bar. He was a combination restaurant and bar.

It was on the water and had big windows overlooking the

water. We drank champagne and spent about one hour

together. Mr. Flynn told me that the checks hadn't yet

arrived in Boston and told me that I must call the bank

in New York and see what is going on. Mr. Flynn said

he would call me in two days. I was back in the hotel

by 9:30 PM. I went to the hotel's night club and found

my bodyguard, xxxxxxxx, and Akil having drinks. I told

Akil that I had just had drinks with Mr. Flynn and that

Michael Flynn had told me that the counterfeit checks

Akil had deposited still hadn't arrived in Boston. I had

on previous occasions informed Akil as to the roles

played by Michael Flynn, Wayne Hollingsworth, xxxxxxx

and xxxx.

           The next day, I called the Middle East Bank and

spoke with the same manager. He is from Pakistan. I asked

[Signature] Ala Fadili Tamimi


Page 28

if he deposited my checks. He was too nice to me on the

phone. He said everything was okay and insisted that I

must go to New York and see him. I did not like the way

he was pushing. I felt something was wrong. I told him

that I would be coming soon to New York and said goodbye.

           Two days later, xxxx called me at the Marriott Hotel.

He gave me a number of a pay phone in Boston and told me

to take phone change and call him in one hour from a

pay phone. I did this and called him back. xxxx told me

to forget about the deal because the shit had hit the fan

in the Boston bank. xxxx said that Michael Flynn's man

in the Bank of New England called xxxxxxxx in Boston

the night before and said that everyone in the bank is

talking about the check forgery. xxxx told me to be

careful. xxxx said to forget the whole deal. I said okay.


WAYNE HOLLINGSWORTH Boston lawyer - office at the Union

Wharf Boston, Massachussetts. He is about 47 years old.

He introduced me to xxxxxxxx, xxxx and Michael Flynn.

xxxxxx He is about xx years old, in xxxxxx, Massa-

chussetts. Very big bookmaker in Massachussetts. xxxxxx




[Signature] Ala Fadili Tamimi


Page 29


xxxxxxxxx drives a black Mercedes Benz sports

car. He is about xx years old and works for xxxxxx

and does his dirty work. xxxx was the contact between

myself and xxxxxx and myself and Michael Flynn.

MICHAEL FLYNN Boston lawyer offices at Union Wharf. He

is about 43 years old.

xxxxxx is the printer who made the forged checks. He is

xxxxxxxx of a printing company in xxxxxxxxx

xxxxxx is about xx years old and works in

the printing business. xxxxx is the one who introduced

me to xxxx, the printer. xxxxxx saw the original checks

and he received $2,000 from me for introduce me to xxxx

the printer.


In refering to the Bank of New England I am also refering

to the New England Merchants National Bank, as the bank

was previously known, prior to May 1982.

Executed at Naples, Italy on the 5 day of May 1984.

[signature--Vittorio Girardi? Tamimi's Attorney]
Witnessed by

[signature Ala Fadili Tamimi]
Ala Abdul Amir Fadili Al Tamimi

[signature Ala Fadili Tamimi]
Ala Fadili Al Tamimi (aka)



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