from: http://cryptome.org/fayed-v-usa.htm Click Here: <A HREF="http://cryptome.org/fayed-v-usa.htm">Al Fayed, Punch v. USA</A> ----- [Exhibit 1] 26 July 2000 REQUESTS SUBMITTED PURSUANT TO THE FREEDOM OF INFORMATION ACT BY MOHAMED AL FAYED AND PUNCH MAGAZINE Request No. 1 All records relating to Diana Frances Spencer, Princess of Wales (DOB: July 1, 1961; British citizen), Emad "Dodi" Fayed (aka Imad Mohamed Fayed)(DOB: 1955; Egyptian citizen) and/or Henri Paul (DOB: July 3, 1956; French citizen) all of whom were killed in Paris, France on August 31, 1997. The deaths of these three individuals cannot be in dispute. Request No. 2: All records relating to the August 31, 1997, deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed), Henri Paul and/or Diana Frances Spencer, Princess of Wales, that occurred in Paris, France. Request No. 3: All records relating to the inquiry conducted by investigating French Judge (P remier Juge d'instruction) Hervé Stéphan regarding the August 31, 1997, deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed), Henri Paul and/or Diana Frances Spencer, Princess of Wales, that occurred in Paris, France. Request No. 4: All records relating to surveillance and/or intelligence gathering activities directed at or originating from Emad "Dodi" Fayed (aka Imad Mohamed Fayed), Diana Frances Spencer, Princess of Wales and/or Henri Paul. Request No. 5: All records relating to Mohamed Al Fayed, a resident of London, England and the father of Emad "Dodi" Fayed (aka Imad Mohamed Fayed). An Authorization and Privacy Waiver is enclosed as Exhibit "1A". The original is maintained in my possession. Request No. 6: All records relating to Trevor Rees-Jones (DOB: 1968; British citized including, but not limited to, his book "The Bodyguard's Story", and the book's ghost writer Moira Johnston. Request No. 7: All records relating to an effort in 1997-98 to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. Request No. 8: All records relating to Keith Fleer, an entertainment lawyer in Los Angeles, California, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. Request No. 9: All records relating to Karl F. Koecher, a former Czech spy who was arrested, charged, and subsequently exchanged in 1985, by the United States for Soviet dissident Anatoly Shcharansky, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. Request No. 10: All records relating to Oswald LeWinter (aka George Mearah) (DOB: approximately 1930; United States citizen) including, but not limited to, his effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. For your information, Mr. LeWinter has been tied to events involving the October Surprise and Iran-Contra scandals and the bombing of Pan Am Flight 103. Request No. 11: All records relating to Ricardo Shapp, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. Request No. 12: All records relating to George Williamson, a U.S. reporter, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. Request No. 13: All records relating to Pat McMillan (aka MacMillan), allegedly a former CIA agent, and the effort to sell classified or unclassified records, allegedly created by or from the possession of the CIA, pertaining to the deaths of Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. Request No. 14: All records relating to Jacques Pettier, an individual believed to reside at 8 Rue du Congres, Asniere-Paris, France. Request No. 15: All records relating to Richard John Charles Tomlinson, who was employed by the British intelligence agency MI6 between September 1991 and April 1995. An Authorization and Privacy Waiver is enclosed as Exhibit "1B". The original is maintained in my possession. Request No. 16: All records relating to the detention by U.S. govemment officials of Richard John Charles Tomlinson, who was employed by the British intelligence agency MI6 between September 1991 and April 1995, at John F. Kennedy International Airport after arriving on a Swiss Air flight on or about August 30, 1998. An Authorization and Privacy Waiver is enclosed. The original is maintained in my possession. Request No. 17: All records relating to David Shayler, but only to the extent the records pertain to Diana Frances Spencer, Princess of Wales, Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and/or Henri Paul, all of whom were killed in Paris, France on August 31, 1997. Request No. 18: All records pertaining to requests received by intermediaries acting on behalf of Mohamed al-Fayed including, but not limited to, former Senator George Mitchell. This request pertains, but is not limited to, Senator Mitchell's letters to the CIA dated September 2 and 15, 1999, and DCI George Tenet's response dated September 30, 1999; Senator Mitchell's letter to Robert S. Tyrer, Chief of Staff, Office of the Secretary of Defense, dated September 17, 1999, and Mr. Tyrer's response dated October 4, 1999; and Secretary of Defense William Cohen's letter to Senator Mitchell dated April 28, 1999. Request No. 19: All records pertaining to Mohamed al-Fayed's efforts to obtain records or information relating to the death of his son Emad "Dodi" Fayed (aka Imad Mohamed Fayed) and Diana Frances Spencer, Princess of Wales. In responding to this request, you may exclude those records that were publicly filed as part of the legal proceedings in In re Application of Mohamed Al Fayed, Misc. No. 99-43 (D.D.C.); In re Application of Mohamed Al Fayed, Misc. No. 99-35 (D.Md.); In re Application of Mohamed Al Fayed, Appeal No. 99-1268 (4th Cir.); Mohamed Al Fayed v. Keith Fleer et al., Case No. BC 213751 (Sup. Ct. Los Angeles, Calif); Mohamed Al Fayed v. Keith Fleer et al., Case No. B137378 (Ct. App. 2nd Div. Calif ), except to the extent internal notations or comments have been added. Request No. 20: All records pertaining to the review of information provided by the Defense Intelligence Agency and the National Security Agency, pertaining to Emad "Dodi" Fayed (aka Imad Mohamed Fayed), Henri Paul and/or Diana Frances Spencer, Princess of Wales, including that which was deemed responsive to Mohamed Al-Fayed's FOIA requests, by any government officials including, but not limited to, Robert S. Tyrer, Chief of Staff, Office of the Secretary of Defense. ------------------------------------------------------------------------ [Exhibit 2] KEITH G. FLEER Loeb & Loeb LLP Suite 1800, 1000 Wilshlre Boulevard Los Angeles, Califorriia. 90017-2475 (Los Angeles County) Telephone: 213-688-3400 Facsimile: 213-688-3460 Email: [EMAIL PROTECTED] Web-Site: http://www.loeb.com Firm Listing POSITION: Member ADMITTED: 1967, District of Columbia; 1968, New York, 1976, California LAW-SCHOOL: Washington College of Law of American University (J.D., 1967) COLLEGE: American University (B.A., 1964) TEXT: Omicron Delta Kappa (President) Business Editor, American University Law Review. Member, National Moot Court Team. Recipient, Bruce Hughes Award and Alumni Award, Outstanding Leadership and Scholarship. Co-Chair, 1991-1992 and Member, 1983- , UCLA Entertainment Symposium Advisory Committee. Adjunct Professor, University of Southern California Law Center, 1996. (Century City Office) MEMBER: American Bar Association; Los Angeles Copyright Society (President, 1989); American Film Marketing Association (Member, Seminar Planning Committee). BORN: February 28, 1943, New York, N.Y. ______________________________________ OSWALD LE WINTER Known aliases: George Mearah Abrahim Razin John Fishmah Oscar Winter Razin Le Winter I. Semit Thought to have born George Mearah Date of Birih: 4 February 1931 Place of Birth: La Quenta, California Last known US. address: 31900 Manherim Lane, La Quinto, California 92253 Additional information that may help facilitate searches: * In November 1997, he represented himself as a former CIA employee describing himself to the CIA as a Counter-Intelligence Director; * In 1995, he allegedly stood trial in Germany on weapons transfer changes anid was found guilty; * In 1991, he allegedly passed information to the BBC of CIA involvement in the death of the late Prime Minister Aldo Moro of Italy; * In 1990, he allegedly attended the World Jewish Conference in East Berlin, East Germany, and produced a card describing himself as a former CIA agent; * In 1989, he was allegedly convicted in Frankfurt, Germany of impersonation of a former CIA officer; * In 1984, he was allegedly arrested by the German police for drug trafficking. * In 1983, he allegedly represented himself as a Professor of Psychology at the University of Maryland; * In 1971, he allegredly obtained false credit by producing a forged New York Police Department badge; * He had himself listed in Who's Who in East Germany as a CIA agent. ------------------------------------------------------------------------ Transcription and HTML by Cryptome. ------------------------------------------------------------------------ [This is the court docket for an earlier proceeding.] --------------------------------------------------------------------------- PACER Service Center Transaction Receipt 09/01/2000 12:33:23 --------------------------------------------------------------------------- Docket as of April 19, 2000 8:25 pm Page 1 Proceedings include all events. 1:99ms43 In re: AL FAYED APPEAL APPEAL U.S. District Court USDC District of Columbia (Washington) CIVIL DOCKET FOR CASE #: 99-MS-43 In re: AL FAYED Filed: 01/29/99 Assigned to: Judge Henry H. Kennedy Demand: $0,000 Nature of Suit: 0 Lead Docket: None Jurisdiction: unknown Dkt# in other court: None Cause: Motion for Production of Documents & Continued Deposition Case type: 1. miscellaneous MOHAMED AL FAYED In re: ------------------------- CENTRAL INTELLIGENCE AGENCY Andrea M. Sharrin Non Party FTS 616-8268 Room 943 [COR LD NTC gvt] U.S. DEPARTMENT OF JUSTICE Civil Division 901 E Street, NW P.O. Box 883 Washington, DC 20530 AREA CODE (202) DEPARTMENT OF INTELLIGENCE Andrea M. Sharrin AGENCY (See above) Non Party [COR LD NTC gvt] ------------------------- MOHAMED AL FAYED Terrence O'Donnell movant FTS 434-5000 202-434-5029 FAX [COR LD NTC ret] WILLIAMS & CONNOLLY Edward Bennett Williams Building 725 12th Street, NW Washington, DC 20005 AREA CODE (202) Docket as of April 19, 2000 8:25 pm Page 2 Proceedings include all events. 1:99ms43 In re: AL FAYED APPEAL Docket as of April 19, 2000 8:25 pm Page 3 Proceedings include all events. 1:99ms43 In re: AL FAYED APPEAL 1/29/99 1 APPLICATION (EXPARTE) by movant MOHAMED AL FAYED for order directing issuance of subpoenas pursuant to 28 USC 1782; exhibits (3) (bcs) [Entry date 02/02/99] 2/5/99 2 ORDER by Judge Henry H. Kennedy : granting motion for order directing issuance of subpoenas pursuant to 28 USC 1782 [1-1] by MOHAMED AL FAYED (N) (dcn) 3/31/99 3 MOTION filed by movant MOHAMED AL FAYED to compel agencies to comply with subpoenas issued to DOD and CIA ; exhibits (4) (tb) [Entry date 04/01/99] 4/19/99 4 MOTION filed by Non Party CIA, Non Party DEPT/INTELLIGENCE to extend time to 4/29/99 to respond to plaintiff's motion to compel and order (adc) [Entry date 04/20/99] 5/13/99 5 MOTION filed by Non Party CIA to quash the subpoena; exhibits (16) (tb) [Entry date 05/14/99] 5/26/99 6 REPLY by movant MOHAMED AL FAYED in support of motion to compel agencies to comply with subpoenas issued to DOD and CIA [3-1] by MOHAMED AL FAYED; exhibits (2) (tb) [Entry date 05/27/99] 5/26/99 7 RESPONSE by movant MOHAMED AL FAYED in opposition to motion to quash the subpoena [5-1] by CIA . (tb) [Entry date 05/27/99] 6/8/99 8 NOTICE OF FILING RE: declaration of Georges Kiejman by movant MOHAMED AL FAYED; attachment (tb) [Entry date 06/09/99] 6/18/99 9 REPLY by Non Party CIA in support of to motion to quash the subpoena [5-1] (jf) [Entry date 06/21/99] 9/2/99 10 SUPPLEMENTAL MEMORANDUM by movant MOHAMED AL FAYED in support of motion to compel agencies to comply with subpoenas issued to DOD and CIA [3-1] by MOHAMED AL FAYED; Exhibit. (lkn) [Entry date 09/08/99] 9/22/99 11 MOTION filed by Non Party CIA to strike supplemental memorandum [10-1], or for leave to file response and notice of recent events (tb) 10/6/99 12 MEMORANDUM by In re: MOHAMED AL FAYED in opposition to motion to strike supplemental memorandum [10-1] [11-1] by CIA; exhibits (2) (tb) [Entry date 10/07/99] 2/24/00 13 MOTION filed by In re: MOHAMED AL FAYED for status conference hearing ; exhibit (1) (bjsp) [Entry date 02/25/00] Docket as of April 19, 2000 8:25 pm Page 4 Proceedings include all events. 1:99ms43 In re: AL FAYED APPEAL 3/29/00 14 ORDER by Judge Henry H. Kennedy : granting motion to quash the subpoena [5-1] by CIA, denying motion to compel agencies to comply with subpoenas issued to DOD and CIA [3-1] by MOHAMED AL FAYED, vacating this Court's 2/5/99 order directing issuance of a subpoena to the CIA [2-1] (N) (adc) [Entry date 03/30/00] 4/10/00 15 MEMORANDUM OF DECISION by Judge Henry H. Kennedy : (N) (N) (dcn) 4/10/00 16 JUDGMENT by Judge Henry H. Kennedy; dismissing 99ms43 (dcn) 4/12/00 17 NOTICE OF APPEAL by movant MOHAMED AL FAYED from order [14-1], entered on: 3/30/00 and judgment order [16-1], entered on: 4/10/00. $5.00 filing fee paid and $100.00 docketing fee paid. Copies mailed to all parties. (tth) [Entry date 04/13/00] 4/13/00 -- TRANSMITTED PRELIMINARY RECORD on appeal [17-1] by MOHAMED AL FAYED to U.S. Court of Appeals (tth) 4/13/00 18 LETTER filed by Appellant Mohamed Al Fayed pursuant to Federal Rule of Appellate Procedure 10(b). (tth) [Entry date 04/18/00] 4/18/00 -- USCA # 00-5150 assigned for appeal [17-1] by MOHAMED AL FAYED (tth) [Entry date 04/19/00] [END OF DOCKET: 1:99ms43] --------------------------------------------------------------------------- ------------------------------------------------------------------------ [Court of Appeals docket.] ______________________________________________________ PACER Service Center Transaction Receipt 09/01/2000 18:21:32 ______________________________________________________ General Docket US Court of Appeals for the DC Circuit D.C. Circuit Court of Appeals Court of Appeals Docket #: 00-5150 Filed: 4/17/00 Nsuit: 2890 Other Statutory Actions In Re: Al Fayed v. Appeal from: U.S. District Court - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Lower court information: District: 0090-1 : 99ms00043 lead: 99ms00043 Trial Judge: Henry H. Kennedy, US District Judge Date Filed: 1/29/99 Date order/judgment: 3/29/00 Date NOA filed: 4/12/00 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Fee status: paid - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Prior cases: None Current cases: None Docket as of August 26, 2000 0:36 am Page 1 00-5150 In Re: Al Fayed v. MOHAMED AL FAYED David E. Kendall Appellant FAX 202-434-5792 202-434-5145 [COR LD NTC ret] Paul C. Rauser [COR ret] Williams & Connolly 725 12th Street, NW Washington, DC 20005 202-434-5000 v. CENTRAL INTELLIGENCE AGENCY Wilma Antoinette Lewis, U.S. Appellee Attorney 202-514-6600 [COR gvt] U.S. Attorney's Office (USA) Civil Appellate 555 4th Street, NW Washington, DC 20001 202-514-7159 David William Ogden, Acting Assistant Attorney General 202-514-3301 Room 9530 [COR gvt] Mark B. Stern, Attorney 202-514-5089 Room 9135 [COR gvt] H. Thomas Byron, III, Attorney 202-616-5367 Room 9106 [COR LD NTC gvt] U.S. Department of Justice (DOJ) Civil Division, Appellate Staff 601 D Street, NW Washington, DC 20530-0001 DEPARTMENT OF INTELLIGENCE Wilma Antoinette Lewis, U.S. AGENCY Attorney Appellee (See above) [COR gvt] David William Ogden, Acting Assistant Attorney General (See above) [COR gvt] Mark B. Stern, Attorney (See above) Docket as of August 26, 2000 0:36 am Page 2 00-5150 In Re: Al Fayed v. [COR gvt] H. Thomas Byron, III, Attorney (See above) [COR LD NTC gvt] Docket as of August 26, 2000 0:36 am Page 3 00-5150 In Re: Al Fayed v. Mohamed Al Fayed Appellant v. Central Intelligence Agency; Department of Intelligence Agency Appellees Docket as of August 26, 2000 0:36 am Page 4 00-5150 In Re: Al Fayed v. 4/17/00 CIVIL-US CASE docketed. Notice of Appeal filed by Appellant Mohamed Al Fayed. [515211-1] (sha) 4/18/00 ENTRY OF APPEARANCE filed by Attorneys Paul C. Rauser (application to be submitted), David E. Kendall for Appellant Mohamed Al Fayed (Styled as "Representation Statement" and received by the Court on 4/14/00 before case opening). [511176-1]. (sha) 4/19/00 CLERK'S ORDER filed directing Appellant to file [511418-1]: docketing statement; certificate of counsel; statement of issues; lower court decision; any procedural motions; deferred appendix notice due 5/19/00; any dispositive motions due 6/5/00. Directing Appellee to file [511418-2]: certificate of counsel; any procedural motions; appearance form due 5/19/00; any dispositive motions due 6/5/00. [Entry Date: 4/19/00] (sha) 4/20/00 ENTRY OF APPEARANCE filed by Attorney H. Thomas Byron for Appellees' Dept Intelligence, and CIA [511980-1]. (jth) 4/20/00 ENTRY OF APPEARANCE filed by Attorney Mark B. Stern for Appellees' Dept Intelligence, and CIA [511981-1]. (jth) 5/19/00 INITIAL SUBMISSIONS filed by Appellant Mohamed Al Fayed [518422-1] : docketing statement; certificate of counsel; statement of issues; lower court decision; deferred appendix notice (Deferred Appendix needed = Y). (wmw) 5/19/00 ENTRY OF APPEARANCE filed by Attorney Paul C. Rauser for Appellant Mohamed Al Fayed, David E. Kendall for Appellant Mohamed Al Fayed [518432-1] . (wmw) 5/19/00 STIPULATION filed (5 copies) Regular Stand-By Pool [518437-1], establishing the initial briefing schedule [518437-2] : Appellant's brief due on 6/9/00; Appellant's appendix due on 6/9/00; Appellee's brief due on 6/30/00; Appellant's reply brief due on 7/10/00. (wmw) 5/23/00 ENTRY OF APPEARANCE filed by Attorney David E. Kendall for Appellant Mohamed Al Fayed [518958-1] . (sha) 6/1/00 CLERK'S ORDER filed to schedule oral argument [520609-1] before Judge Initials: SFW DBS JWR on 9/6/00 at 9:30 AM . [Entry Date: 6/1/00] (cwc) 6/9/00 BRIEF filed by Appellant Mohamed Al Fayed [522561-1]. Copies: 15. Certificate of service date 6/9/00. (jth) 6/9/00 APPENDIX filed by Appellant Mohamed Al Fayed [522564-1]. Copies: 10. Certificate of service date 6/9/00. (jth) Docket as of August 26, 2000 0:36 am Page 5 00-5150 In Re: Al Fayed v. 6/30/00 BRIEF filed by Appellee's CIA, Department of Intelligence [527498-1]. Copies: 15. (Certificate of personal service dated 6/30/00). (jth) 7/10/00 REPLY BRIEF filed by Appellant Mohamed Al Fayed [528376-1]. Copies: 15. (Certificate of personal service date 7/10/00). (jth) 8/25/00 PER CURIAM ORDER filed to allocate oral argument times: APET minutes- 10 ERES minutes- 10. [539182-1], One counsel per side to argue. [539182-2] Oral argument scheduled for 9/6/00, Form 72 notice of attorney arguing case - [539182-3] due 9/1/00 for CIA, for Mohamed Al Fayed . . Before Judges Williams, Sentelle, Rogers . [Entry Date: 8/25/00] (lej) Docket as of August 26, 2000 0:36 am Page 6 ----- Aloha, He'Ping, Om, Shalom, Salaam. 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