110 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHILDUTA that occurred? A. The first time personally I give something to him was after he hire me. I give $1,000. Q. Why did you give him $1,000? A. Because that was the deal I make with him before I get hired. Q. Who is Nikolai? A. Nikola! is a friend of mine. Q. What's his full name? A. Majescu Nikolai. Q. Is Nikolai the person that 112 1 2 3 4 5 6 7 8 9 about the thousand dollars or did Mr. Gjieli approach you about the thousand dollars? A. Mr. Gjieli approached me about the amount because he told me to don't go to the other guy, to my friend, so if we talk something, we do something, we have to go straight to him. Q. Who was your friend he was what to expect, right? A. Right. Q. Were you hired after you gave 11 Mr. Gjieli the thousand dollars? A. Yes, sir. Q. Mr. Gjie1i hired you? A. No, first I give him the gift, 12 then after he hire me, I give him the 13 thousand dollars. 10 recommended or referred this job to you? A. Correct, sir. Q. Did you approach Mr. Gjieli GHILDUTA A. Because that was the deal before I get hired. Q. Because Nikolai told you that's 14 15 16 17 18 19 20 21 22 23 24 25 Q. A. Q. A. Q. A. Q. What was the gift you gave him? I give him a crucifix. A crucifix? Yes, about $490, about $500. And then he hired you? Yes. Do you have the receipt from where you bought that crucifix? A. I don't have a receipt, but I have a witness. Q. Who is the witness? A. Nikolai's wife. 111 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHILDUTA referring to? A. Majescu, the guy that recommend me for porter. Q. So where were you when Mr. Gjieli told you this? A. 29th floor. Q. 29th floor? A. His Office. Q. And that's the manager's office? A. Correct. Q. Were you expecting him to ask you for a gift? Let me withdraw that. Did Nikolai tell you that you should expect that Mr. Gjieli would be asking you for a gift? A. He make a deal before. Q. Again, the question is just yes or no, did Nikolai indicate to you to expect Mr. Gjieli to ask for a gift? A. I cannot recall that. Q. Were you surprised when Mr. Gjieli asked you for a gift? A. No. Q. Why not? 113 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GH!LDUTA Q. Nikolai's wife? A. Yes. Q. Where did you purchase this? A. Right here on canal Street. Q. What's the name of the store? A. I don't remember. I don't remember. Q. Is there anything that would help you remember what the name of the store is? A. I know exactly where the store is. Q. I'm sorry? A. I know where the store is, but I cannot tell you right now. Q. Okay, we will leave a space in the transcript and you can tell me where the store is and what the name is? A. Okay (Insert:) Q. And is it still there now? A. I think so. Q. What is Nikolai's wife's name, the one that was with you? VERITEXT/NEW YORK REPORTING COMPANY, LLC 212-267-6868 516-608-2400 29 (Pages 110 to 113) . .. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 ll6 114 GHJLDLITA Joany, 1-o-a-n-y, Majescu. A. were you friends with Nikolai Q. and Ioany? A. Yes, I used to be. At the time in 1994, you were friends with them? A. Yes. Q. What were you doing work-wise at the time that you went to -- for employment at Trump? Q. 1 2 3 4 5 6 7 8 9 10 A. Your income taxes? Yes, sure. Q. After you gave Mr. Gjieli the crucifix, you were hired, is that correct? A. Correct, sir. Q. Did Mr. Gjieli also ask you to fill out any employment applications? A. And you did that? A. Yes, sir. Was I working -- Q. Yes, were you working before 13 14 Yes, I did work, yes. At that time were you employed, at the time that you went to seek work 15 16 17 with Trump? A. Yes, I work. Q. Where were you working at that time? A. MT Pretzel. It's a company right here. Q. What's the name of it? A. MT Pretzel. 19 20 21 22 23 24 25 Q. Q. Q. A. A. something. 11 12 then? GHILDLITA going to find a way, income tax or 18 Yes, sir. Q. (Defendants' Exhibit B marked for identification.) Q. Mr. Ghilduta, I just marked a document for identification Defendants' B. It's a two-page document. The second page there's a signature next to a signature line. Is that your signature? A. Yes. Q. Is this your writing on the first page? A. Yes, sir. 117 ll5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHJLDLITA Q. MT Pretzel? A. Yes. It's am food company. Q. What were you doing with them? A. I was a salesperson. Q. A salesperson? A. Yes. Q. What was your income in 1993 with MT Pretzel? A. I cannot recall that. Q. What was your income when you first started with Trump? What was your salary? A. Around $30,000, $33,000. Q. Was that more or less than YoU were making at MT Pretzel? A. It was more. Q. Is there anything that would help you remember what your salary was at MT Pretzel? A. No right now, but I can provide you that information. Q. Where would you get that information from? A. I talk with the company. I am 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHILDLITA Q. And that is YoUr application for employment. MR. BARROWS: Is that correct, a copy of your application for employment? A. Yes, sir. Q. I notice that the section next to college or education, that is blank. Did you go to college in Rumania? A. Sure, sir. Q. Why is it blank in the application? A. Because manager told me don't write more than 1 did because you are over qualified for the job. So when you get a job, you have to put up enough how much education, sir. Q. And what was the name of the college you attended in Rumania? A. Cluj Polytechnic Institute of Construction. Q. Where was that located? A. Cluj. Q. Cluj, Rumania? A. Yes. VERITEXT/NEW YORK REPORTING COMPANY, LLC 516-608-2400 212-267-6868 30 (Pages 114 to 117) 120 118 1 2 3 4 5 6 7 8 9 10 11 GHJLDUTA Q. Is that still there? A. Yes, it's still there. Q. Polytechnic Institute of 1 2 3 4 5 6 7 8 9 10 Construction? A. Yes. Q. And that was the only college you attended? A. Yes, sir. Q. What degree did you obtain from 11 there? 12 13 A. Bachelor degree. Q. And you see there's a column 12 14 there or row there for trade school as 15 16 17 18 19 20 21 22 23 24 25 well in the application, is that correct? A. Yes. 14 15 16 17 18 19 20 21 22 23 24 25 13 Q. And why is that blank? Well, let me back up. Did you attend the trade school in Rumania? A. No. Q. Did you attend a trade school anywhere? A. No. Q. So the only school you attended was Polytechnic Institute of Construction GHJLDUTA A. No, sir. Q. He had left for another company? A. Yes, he left. Q. Did you have any discussions with any other of your coworkers about Mr. Gjieli's hiring practices? A. Yes, I did, sir. Q. With whom did you have such discussions? A. Cornell Nedelcu, Petre Anghel. A few others I don't remember right now. Q. When did you have a conversation with Cornell Nedelcu With regard to Mr. Gjieli's hiring practices? A. When I met him. Q. When you first met him? A. Yes. Q. And when was that? A. I cannot recall right now. I don't remember exactly when it was the time. Q. More than five years ago? A. Yes, more than five years. Q. Was it more than two or three 119 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHILDUTA and that's where you referred to earlier you obtained a degree in civil engineering, is that correct? A. Yes, that's correct. Q. And you knew Nikolai in Rumania, is that correct? A. Correct, sir. Q. Was he employed with Trump? A. Yes, sir. Q. Was he still employed with Trump on December 20, 2002? A. No, sir. Q. Are you currently in contact with him? A. No, he is dead, sir. Q. When did he die? A. I don't remember exactly. He died in car accident in -Q. Approximately five years or more? A. More. Q. And at the time that he was in in the car accident, was he employed with Trump? 121 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHILDUTA years after you first started working for Trump? A. I think after three years. I cannot recall right now. Q. What were the circumstances that this conversation about Mr. Gjieli's hiring practices came about that you had with Cornell Nedelcu? A. Mr. Gjieli asked me to find the guys which went in wanted to work to pay for the job. Q. When did Mr. Gjieli ask you this? A. I cannot recall right now, but it was like two months before he get hired. Q. Did Mr. Gjieli ask you to do this on more than one occasion? A. Yes, sir. Q. When was the first time he asked you to do this? A. This was the first time, sir. Q. Can you tell me the other times that he did this? VERITEXT/NEW YORK REPORTING COMPANY, LLC 212-267-6868 516-608-2400 31 (Pages 118 to 121) ,, ?o " o, 13' 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 2 3 4 5 6 7 GHILDUTA between Mr. Nedelcu and Mr. Gjieli with respect to the money that had to be paid to Mr. Gjieli? A. Can you rephrase it, like a little shorter, please. Q. All right, let me go back. 8 Did Mr. Gjieli ever communicate 9 to Mr. Nedelcu about the money that Mr. Nedelcu was going to have to pay Mr. Gjieli? A. No, sir. Q. 136 10 11 So Mr. Gjieli communicated with you about that money? A. Yes, sir. Q. And you communicated with Mr. Nedelcu, is that correct? A. Correct, sir. Q. Do you know anybody else who acted as a go-between for Mr. Gjieli and a potential employee, besides yourself? MR. BARROWS: Object to the term go-between. A. There were a few other people. Q. You understand what I mean by 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHILDUTA That was the practice or whatever. Q. Other than yourself and Mr. Petre, do you know if this was being done by anybody else? A. Sure, all the guys pay the money. Q. I'm sorry? A. All the guys which pay for the job, somebody else took the money. Also I don't know the situation when the person gives money to him, it was one person who take it to the job and took the money and give the money to the manager. Q. So you did this on two occasions, is that correct? A. No, I did that one occasion, but in another guy was the guy which I tell him -Q. Okay, I understand. In other words, you testified already that the second person -- you didn't handle the money, you just referred him to Mr. Gjieli, is that correct? A. Yes, correct. 135 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHILDUTA go-between? A. Yes, yes. If I understand well, you talk about somebody else took the money from another one and they give money to Mr. Gjieli. That is your question? Q. Yes. A. Yes, sir. Q. And who were those people? A. You see, when Petre Anghel took the money, he bring one guy, he give the money to Gjieli, sir. Q. So Petre Anghel did similar thing that you did, correct? A. Yes, yes, yes. Q. Anybody else? A. I cannot recall right now. Q, And why do you think that Mr. Gjieli asked you to act as this go-between? A. I don't have any explanation right now, sir. Q. Did you have any explanation at the time that this occurred? A. I don't have an explanation. 137 1 2 3 4 5 6 7 a 9 10 II 12 13 14 15 16 17 18 19 20 21 22 23 24 25 GHILDUTA Q. Was there any other occasion when you referred somebody to Mr. Gjieli? A. It was like four times. Q. Four times? A. Yes. Q. And on each of these occasions did you tell the person that you referred that you were sure he was going to have to pay Mr. Gjieli? A. Yes. Q. And on each of those occasions did that person directly, or through somebody else, pay Mr. Gjieli? A. I assume so, sir. Q. Do you know how much the second person paid Mr. Gjieli? A. I don't know. Q. Other than that first occasion, did you ever personally handle the money that was being exchanged? A. No, sir. Q. So on those other occasions, you served merely as the person who referred the potential employee to Mr. Gjieli, is VERITEXT/NEW YORK REPORTING COMPANY, LLC 516-608-2400 212-267-6868 35 (Pages 134 to 137) Case Document 77 Filed 03/03/08. Page 1 of,5 .. UNITED STATES DISTRICT COURT i. . .. i SOUTHERN DISTRICT OF NEW YORK I i? "j IOAN GHILDUTA [$11 0 5. .. Plaintiff, ?against? 04 CV 7494 (BSJ) (GWG) ECF Case THE TRUMP CORPORATION and MICHAEL P. ISHMAN, as President of LOCAL 32B-32J, . -. SERVICE EMPLOYEES INTERNATIONAL UNION, AFL-CIO Defendants. SETTLEMENT AGREEMENT AND GENERAL RELEFWE This Settlement Agreement and General Release (the ?Agreement?) is made by and between The Trump Corporation, The Board of Managers (Residential and Commercial) of the Trump Tower Condominium, and Trump Tower Commercial LLC (collectively ?Trump?); Michael P. Fishman, as President of Local 328-32], Service Employees International Union, AF L-CIO (?Local (collectiver ?Defendants?); and loan Ghilduta, an individual residing in the State of New York (?Plaintiff?), (collectively ?the Parties?). WHEREAS, Plaintiffs filed a Complaint in United States District Court for the Southern District of New York entitled ?loan Ghilduta v. The Trump Corporation and Michael P. Fishman, as President of Local 328-32], Service Employees International Union, Index Number 04/7494 (United States District Court, Southern District of New York) (?Action?); WHEREAS, Defendants deny all claims in the Action; and WHEREAS, the Parties have determined it to be in their mutual interests to settle the Action. NOW, THEREFORE, for good and valuable consideration, the sufficiency of which is acknowledged hereby, and in consideration of the mutual covenants and undertakings set forth herein, the Parties agree as follows: 1. Compensation. Trump and Local 328] each agrees to issue a check to Plaintiff in the amount of seven thousand ?ve hundred dollars ($7500.00) within seven days after the Agreement, and the stipulation referenced in paragraph 8, have been signed by Plaintiff and returned to Katchen Locke, SEIU Local 328], 101 Avenue of the Americas, New York, NY 10013, and so long as Plaintiff has not revoked the Agreement as set forth in paragraph 13 below. Case Document 77 Filed 03/03/08 Page 2 of 5 2. Denial of Wrongdoing. It is agreed and understood between the Parties that nothing contained in this Agreement, nor the fact that Plaintiff has been paid any consideration under it, shall be construed to be an admission of liability or any wrongdoing by Defendants. 3. Con?dentiality. It is agreed and understood between the Parties that the terms and conditions of this Agreement shall be kept con?dential. Plaintiff agrees that he will not disclose any information concerning the terms and conditions of this Agreement, including the amount paid to him, except to his immediate family members and to his legal, tax and/or ?nancial advisor(s), and to the extent necessary to enforce the terms of this Agreement. Any damages resulting from a breach of this con?dentiality provision will be dif?cult to determine, and Plaintiff agrees that Trump and Local 32BJ shall each be entitled to recover the amount of $7,500.00 from the Plaintiff as liquidated damages in the event of each such distinct and separate breach by Plaintiff, in addition to attorney?s fees and costs and any equitable relief available to Trump and Local 32BJ. This provision shall be reciprocal in nature in all respects. 4. No Future Employment. Plaintiff agrees that he will not seek any future employment with Trump. 5. General Release. Plaintiff, in consideration of the sum of seven thousand ?ve hundred Dollars and other good and valuable consideration received from and/or on behalf of Local 3ZBJ and Trump, receipt of which is hereby acknowledged, releases and discharges: 1(a) Trump, Trump?s parents, subsidiaries, af?liates, present and former of?cers, directors, attorneys, employees, shareholders, members, agents and representatives, The Trump Organization, Inc, Donald J. Trump individually, and any and all other corporations, partnerships, limited liability companies, designees, and other entities owned, Operated, controlled and/or managed by Donald J. Trump, and each and every entity and/or business or company with which Donald J. Trump is af?liated in any manner, and each of the aforementioned releasees? respective of?cers, agents, directors, employees, attorneys servants, partners, members, subsidiaries, and shareholders, collectively, the ?Trump Releasees?); and 2(a) Local 3ZBJ, and Local 3ZBJ ?5 parents, subsidiaries, af?liates, present and former of?cers, directors, attorneys, agents, employees, servants, and members collectively ?Local 32BJ Releasees?), from all actions, causes of action, suits, debts, dues, sums of money, accounts, reckonings, bonds, bills, Specialties, covenants, controversies, agreements, promises, variances, trespasses, damages, judgments, extents, executions, claims and demands whatsoever, in law, admiralty or equity, which against the Trump Releasees, and/or Local 32BJ Releasees, which Plaintiff ever had, now has, or hereafter can, shall, or may have, for, upon, or by reason of any matter, cause or thing whatsoever from the beginning of the world to the day of the date of this Agreement. This release is general in nature as and between Plaintiff and the Trump Releasees and Local 3ZBJ Releasees, but Case Document 77 Filed 03/03/08 Page 3 of 5 10. ll. 12. also speci?cally relates to all claims or causes of action asserted or which could have been asserted in the Action. on-Disparagement. Plaintiff agrees not to criticize or denigrate Trump Releasees; or (ii) make any remarks or comments about Trump Releasees, orally or in writing, to any third party, which remarks or comments reasonably could be construed to be derogatory or disparaging in nature, or which reasonably could be anticipated to be damaging or injurious to Trump Releasees? reputation or good will. Any damages resulting from a breach of this non-disparagement provision will be difficult to determine, and Plaintiff agrees that Trump shall be entitled to recover the amount of $7,500.00 from the Plaintiff as liquidated damages in the event of each such distinct and separate breach by Plaintiff, in addition to attorney?s fees and costs and any equitable relief available to Trump. This provision shall be reciprocal in nature in all respects Duty of Fair Representation. Without any admission of wrongdoing, Local agrees to comply with its duty of fair representation with respect to its representation of Plaintiff. Dismissal of Claims. Plaintiff agrees to dismiss with prejudice any and all claims against Defendants, including any and all claims asserted, or which could have been asserted, in the Action. Plaintiffs shall execute the Stipulation of Dismissal, attached here as Exhibit A, and any and all other documents necessary to effect the dismissal of the Action with prejudice, and to waive, release and discharge with prejudice any and all rights, claims or causes of action Plaintiff may have in the Action. Covenant Not to Sue. Plaintiff agrees that he will not, jointly or individually, ?le any charge, claim, grievance, suit, complaint or action with any government agency, union body or in any court or other jurisdiction against Defendants relating to any claims that are released in Paragraph 5. General. The invalidity of any provision of this Agreement shall not affect the validity of any other provision hereof. This Agreement may be executed in counterparts. Entire Agreement. This Agreement constitutes the entire agreement between the Parties with respect to the matters set forth herein and supersedes and terminates any and all previous agreements and negotiations between the parties with respect to the matters set forth herein. Plaintiff acknowledges that Defendants have made no promises to him other than those contained in this Agreement. This Agreement may not be changed unless the change is in writing and signed by all of the Parties. Review Period. Plaintiff acknowledges that he has been afforded a reasonable and sufficient period of twenty-one (21) days to review and consider this Case Document 77 Filed 03/03/08 Page 4 of 5 13. 14. LOCAL 32 By; Name: Title: Date: Agreement before signing it. Plaintiff understands that he may use as much of this twenty-one?day period as he wishes prior to signing. Plaintiff acknowledges that, to the extent that he decides to sign this Agreement prior to the expiration of the above period, such decision was knowing and voluntary on his part. The Parties agree that any changes to this Agreement, whether material or immaterial, do not restart the running of the twenty-one day period. Revocation Period. Plaintiff acknowledges and understands that he may revoke this Agreement within seven (7) days of the date on which he signs it (?the Revocation Period?) by delivering a written notice of revocation to Katchen Locke, SEIU Local 3281, 101 Avenue ofthe Americas, NY, NY 10013, no later than the close of business on the seventh day after he signs this Agreement. If Plaintiff revokes this Agreement during the Revocation Period, the entire Agreement shall be null and void and the Parties shall have no obligations under the Agreement to one another. This Agreement shall not be effective or enforceable and no payment will be made hereunder until after this Agreement is fully-executed by the Parties. Choice of Forum and Law. This Agreement shall in all respects be interpreted, enforced and governed in accordance with and pursuant to federal law. The Honorable Barbara S. Jones of the United States District Court for the Southern District of New York shall retain jurisdiction to resolve any dispute arising out of, or related to, this Agreement. Name: Cece Zoo/it; Title: R?vvome% Ere-i ?from? fl Z*Eit% aware?? Date: ScalkxA is: IOAN Pro Se Plaintiff Date: 62 as Sworn to before me this 200'- day of ,2008 Notary ic LYLE D. ROWEN Notary Public State of New York No. 02H0611B333 Quali?ed In New York County Commission Expires November 8, 20 i? 4 Case Document 77 Filed 03/03/08 Page 5 of 5 SO ORDERED: x' Honorable Barbara S. {63 708/ Three indicted in bribery case By BILLY BOWLES Free Press Staff Writer Three Albanian men. one of them already serving four life terms for murder and assault. have been indicted by a federal grand jury on charges of offering a $100,000 bribe to a US. Treasury Department agent for help in a prison escape. The indictment against convicted murderer Zeff Lulgjurai. his 20-year-old son Nickola. and a family friend. Gjergj GJlell. 36, was announced Monday in Detroit by US. Attorney James K. Robinson. According to a press release from Robinson?s office. family friend Gjleii approached Treasury agent Robert Van Hengei on June ll asking his help in a plan to help Lulgjura] escape from Jackson Prison, where he was sent after his June 1977 conviction for gunning down four men in his restaurant. Zorba?s Coney island at 9100 Woodward. on Oct. 28, 1976. - The indictment says Gjieil met again with Van Hengei five days later and reiterated the offer and on July 22 Van Hengei went to Jackson and met with left who told Van Hengei that $50,000 to $60,000 was already raised to pay the bribe. According to the indictment, Gjieli and Nickola Luigjura] met with Van Hengei July 24 and gave him 310.000, and on Aug. 5. Nickola met again with the agent and showed him $90,000 more. but did not give it to him. Nickels Luigjura] declined to comment on the charges. His lawyer. Evan Callahan of Westland, said the charges "are far-fetched. I think you've got a government agent taking advantage of some very naive people . . . an overzealous government agent taking advantage of a naive foreigner." Callahan said the government has tape recordings that it claims support its case, but Callahan said he has not yet listened to them. Nickola Lulgjuraj was charged along with his father in the shootings. in which Leroy Turner. 29. Morgan Marshall Jr.. 44. and Robert Duson, 44. all of Detroit, were killed and William Anderson, 20. was wounded and left paralyzed. Nickola was 16 at the time and was committed to the Michigan Department of Social Services for detention in the state?s Boys Vocational School. Lawyer Callanan said Nickels now is a student at Wayne County Commu- nity College. ) UNITED STATES OF AMERICA, ' p I CRIMINAL NO.80-80529 Plaintiff, Q ' VS_ ~ HON. HORACE GILMORE ' ,"1 : .' ' L. A- GJERGJ GJIELI, ET AL., ' ' a Def end ant s. . ,_ ,' f x ' , t.. >> >> w / a! 6 32 SENTENCING MEMORANDUM "fir FOR THE UNIT ED STAT ES --------------------- 5.9 c" #1 . ?' Amy" ()2 13" 0 (j .0315?" fifi gfi '" AA?" /9 .fig INTRODUCTION 1 22%; 93, The purpose of this memorandum is to provide to the court the views of the United States as they relate to what type of sentence that should be imposed. Initially, it should be noted that since this was a jury trial, this court has seen and heard all of the evidence; therefore, this memorandum will not dis- cuss the facts in any great detail. For reasons which will be explained in the following discussion, it is the position of the United States that all of these defendants should be imprisoned for a substantial period of time. SENTENCING CONSIDERATIONS GJERGJ GJIELI As this court has seen from the evidence, defendant ;he Gjieli was the person who first approached Special Agent Van Hengel with the bribe offer. It is the contention of the United States that this defendant was acting pursuant to the instructions of defendant Zef Lulgjuraj, him out anyway.) (who told him to find somebody to get Lfi --cuitaule evidence established beyond any doubt that defendant Gjieli's actions were knowingly done. He acted in a calculated manner to find a method to help a convicted murderer break out of prison. This utter disdain for the laws of our country cannot be tolerated. His actions are even more re-- prehensible when one considers that he is a citizen of this country by choice. According to his testimony, this defendant came to the United States to enjoy the abundant freedoms that are non--existent in Albania or Yugoslavia. This defendant should learn that freedom carries a price: obedience to the law. The United States believes that because of defendant Gjieli's central role in these offenses and the contempt he has shown and, laws, in fact, continues to Show for our system of a substantial period of incarceration and a committed fine should be imposed. As an indicator of the seriousness of this offense, the United States made a plea offer of a maximum of ten imprisonment to this defendant. ZEF LULGJURAJ Paradoxically speaking, making a sentencing recommendation with respect to this defendant is both the easiest and the most difficult task. This is due to the fact that this defendant is already incarcerated; the temptation exists to simply say that whatever is done by this court would have little or no However, to take such a position would be a derelection ' of the duties of this office. it is the position of the United States that a O n Briefly, the d at H 7* geffect. signigicant period of incarceration--consecutive to his pre- The '1"3'a sent sentence----should be imposed upon this defendant. v _United States urges a consecutive sentence because of the>> seriousness of the offenses for which this defendant attempted to avoid incarceration. ' . V" Furthermore, .A ,1' it should be noted that ' ,',1>!_'_,,.'A ( under the laws of this state, a sentence of imprisonment for > escape is consecutive; M.C.L.A. 750.193. Such a law reflects ' -_uuALD wno try to avoid couliuement for their crimes. The United States believes that this court should recognize and give effect to that policy hererecognizing in the process that the defendant tried to use the Federal Government to avoid his confinement.v NICKOLA LULGJURAJ As indicated during the trial of this case, the evidence clearly established that this defendant knew what he was doing and was fully aware of the illegal nature of his activities. While it is possible that he acted out of love for his father and perhaps even followed his father's orders, that does not excuse his actions. In fact, it should be noted that when this defendant followed his father's orders just over four years ago, he killed three people. The importance ofifibt fact can not and should not be lost on this court. This defendant, Nickola Lulgjuraj, is not the innocent, well intentioned young man that he and his sweet, family/friends would have this court believe. This court observed the defendant on the witness stand as he twisted and contorted facts in a futile attempt to avoid a conviction for his actions. Now, we are subjected to the same display in an attempt to avoid a well deserved substantial period of imprisonment. Counsel for defendant has requested sentencing under the Youth Correction Act. The United States of America strenuously objects to any such sentence. To allow a person who, along with his father, has killed three people and then tried to help his father escape from confinement for those offenses to receive the :1 a! oke ij e fact of the matter is that this defendant needs to be punished; there is no hope of rehabilitation because if ": mes cri se the of one any mit com ld wou he ty, uni ort opp given the again. t an nd fe de is th ce en nt se to ed ir qu re t no is t ur co 'This under the Act. The only legal requirement is that the court 7:; the benefits of the Act would be a travesty of justice. - need not even be stated. 424,441 (1973). -cusuus Dorzynski v. for such a finding United States, 418 U.S. The United States urges this court to make a finding of'"no benefit"'and impose a Substantial period of incarceration as an adult upon this defendant. CONCLUSION In conclusion, it should be noted that the offenses of which these defendants have been convicted are very serious. Bribery is an offense which goes to the integrity of a free governmental system such as ours. It is an offense which attempts to substitute the will of the individual for that of the orderly processes of government. Jacobs, 431 F.2d.754,759 (2nd Cir. 1970). See United States v. Accordingly, these defendants should be sternly dealt with. Respectfully submitted, RICHARD A. ROSSMAN United States Attorney OHN N. THOMPSON, . P-- ) Assistant United States Attorney Attorneys for Plaintiff 817 Federal Building Detroit, Michigan 48226 313/ 226--4460 Dated: January 6, 1981 CERTIFICATE OF SERVICE th< Robert G. Anderson; 1766 City National Bank B1dg., Detroit, 48226, by depositing same in a U.S. Postal Service mail receptacle located in the Federal BUilding in Detroit, Michigan MI on January 6, 1981. Miran a MM i__i___qfl. " arris, ecretary okt I 7" ll This is to certify that copies of the foregoing Memorandum Evan Callanan and John was served upon the following counsels: Poman; 33300 W. Warren, Suite 107, Westland, MI 48185, and TRUE NAME: Gjergj Gjieli "-- ._ DOCKET NO J [_ | 80 - 80529 iUflEXefiUifllfiiIQRUZ)EXEGQEMBfiifiUEMQQCXMTMIHHVNEfiUfi Gbifibefii mourn In the presence of the attorney for the government 198 1 I 8 y ar nu Ja -- > -- -- -- -- -- -- -- -- e dat this on son per in ed ear app the defendant l red desi t ndan defe her whet d aske and sel coun to t righ of t ndan defe sed advi t However the cour L_l WITHOUT COUNSEL COUNSEL have counsel appointed by the court and the defendant thereupon waived assistance of counsel. . a YLAM DAY lX_.I WITH COUNSEL LBPEeE'ifin'leisin _ _ _ _ _ _ of_cou_nse_l) _ _ _ _ _ _ _ _ _ _. _ (Name PLEA 1 NOT GUILTY | |NOLO CONTENDERE, l L__.l GUILTY, and the court being satisfied that there is a factual basis for the plea, L__l NOT GUILTY. Defendant is discharged flaming/verdict of There being [EJ GUILTY. k Defendant has been convicted as charged of the offense(s) of FINDING & "mGMENr Count One: Conspiracy to Bribe a Public Official; l8:USC:37l. Count Two: Birbery of a Public Official; 18:USC201(b)(3). r' tra con the to se cau t ien fic suf no e aus Bec d. nce nou pro be not uld sho nt gme The court asked whether defendant had anything to say why jud i ant end def The t: tha d ere ord and ted vic con and d rge cha as lty gui ant end def the ed udg adj rt cou the rt, cou the to ed ear app or wn, sho was of iod per a for ent onm ris imp for ve ati ent res rep d ize hor aut his hereby committed to the custody of the Attorney General or- years (5) Count One: Five SENS?" Count Two: Fifteen (15) years "3:33?" These sentences to run concurrently . BOND IN THIS MATTER WAS CANCELLED ON 11/2 1/80 Defendant remanded at that time. SPECIAL CONDITIONS OF PROBATION ADDHTONAL CONDITIONS 0F PROBATION -' r~ ._ '7 r _ __ the on t ou set n io at ob pr of ns io it nd co l era gen the t tha d re orde by re he IS It e, ov ab d se po im n io at ob pr of ns io it nd co l cia spe In addition to the . n, io at ob pr of ns io it nd co the ge an ch y ma t ur Co reverse side of this judgment be imposed. The w, la by d te it rm pe s ar ye ve fi of od ri pe n io at ob pr m mu xi any time during the probation period or within a ma . iod per n io at ob pr the ng ri du g in rr cu oc ion lat vio a for n io at prob ,-- ds en mm co re d an l ra ne Ge ey rn to At e th of y The court orders commitment . to the cu. stod . the, .1. u "is okdmd that the Clerk dcrm I a certified copy of this judgment Mllen' Federal and commitment to the U.S. Marshal or other qualified officer. . - j \x\ a i DATION \ \'\i\'\?\ ( s \ V SIGNED BY '-- \ \kx'" I fl ' } M \ \ r ~ LKKJ U.S. District Judge Horace W . Gil m "ms. it..- *e' ,_-_.,-.r_. Ni . s N Us" V- - on." r. .; -va.._, i --- --- .LUTll-Tne'al'l'eg ati'oh 5 0 f Paragraph fourteen are ne' h /;139 6/ "Md __ n ' "'ZE//Jy// i , _,Y.d9 not heceSSarily have to become'citizens. They can be jlssued what we {call ~a green card, which allows them to be-a resident alien; '* I 'A As far as I know, Marash I know is a resident alien. Gjergh we believe has a green card, and Zeff and Nick both have green cards. Whether or not they have subsequently become citizens, we're not really sure of that. ' A JUROR: Okay. That 18-- MR. THOMPSON: " (interposing) for reasons unknown to me, the immigration records are not very well kept and we asked them to check it out, and we still haven't been able to get a clear answer on it. Page 22 -- COVERT: " . Gjergj, who is an Albanian, engaged him in the conversation about getting a short--wave radio so that he could listen to broadcasts from his native Albania. Page 23 - COVERT: " . . . Zeff was convicted of shooting four people here in Detroit on Woodward and Clairmount back in--l975, I believe, or '76 is when his occurred. Three of the people were, they were all shot, and when they were down he and his son went around and shot them again to make sure, and one guy played like he was dead but he lived. He's paralyzed for life, but he did live. And subsequently, Zeff was convicted of these murders and they wanted to break him out of jail and secrete him out of the country. 'They wanted to get him back into Albania, which is one of the'" Communist bloc countries at this time. Page 24 - COVERT: " . . .7 These people are particularly violent people.' They don't need muCh of an excuse to kill anybody. They have no respect for law, law enforcement. The fact that they offered a'Specialv >>>> Agent a bribe let's you know what they think of law enforcement.' They juSt figure they can buy anybody. Page 25 -'COVERT!j "I. :1.'Most of-the; all of the defen ants ,in"this Case are aliens. EAlbanians talk very,.Very; fast and maybe that"S'why they chose ATF, becauSe we're used to working with machine guns, you know, becauSe'he'juSt, you know, talks very, very fast. So you have to---they are hard to understand. it's there. But TRANSCRIPT On June 16, .of Alcohol, 1980, Special Agent ROBERT VAN HENGEL, Bureau Tobacco and Firearms, Criminal Enforcement, Detroit, Michigan, made an undercover contact with GJERGJ GJIELI at DeLuca's Lounge, 1008 N. Woodward, Oak, Michigan. " Royal At approximately 6:02 p.m., Special Agent VAN HENGEL entered the lounge. The conversations were recorded. GJIELI was not immediately present, but arrived later. General conversations with other persons, not associated with this investigation are omitted. GJIELI is a bartender and since he was working the conversations are interrupted. One June 26, 1980 and June 27, 1980, Special Agent Van Hengel transcribed the conversations. The following is a transcript of the conversations between Special Agent VAN HENGEL and GJERGJ GJIELI: V. GEORGL just walked in, ... Routine bar talk . G. How you young man? V. Pretty good GEORGE, G. Oh, 'V. I'm crazy, in a red shirt . . . . how are you? crazy. You're late. G. (Unintelligible) V. I know tnat. G. I didn't call you so then . V. What? G. you know don't have no You probably busy in office time to call (unintelligible) and ah, his father was last night in my house . . . Sunday night V. Who's father? G. ZBF's V. Yeah. father . . TOBY knows that . . . . (unintelligible) . . .--2... And you say for what, you told me, you know, you got talk to somebody, I don't know you know have been left him last night . . . . . sort of . I just . . they stayed for awhile you know . this guys off work, (unintelligible) his son, his daughter and his wife and ah, what he alls going to do, he's going back to Yugoslavia . . . (Pause here while GEORGE is taking care of a customer) And ah then, I was justa nothing resting, I really wanted to go (unintelligible) had a good time, great time. For instance . . . and for the ah . . . what the hell was I saying . . . yeah, I stopped today for the ah, for the, where the hell I stop in there . . . Clawson Lounge, Clawson RCA . . . RCA? Ha huh All kinds of short waves or whatever you know? Yeah. Was it I found, that is I use a straight wire. Uh huh Or use ah, That's what I told you. Or put it, Yeah, put it on a pole if you can . .'. I talked to our old friend the other day. Oh who is? KIRK G. -3-- Yeah. He says you're, you're going back to ah the old country . . . course KIRK talking in his cups again. He . . . he's a funny guy. Apologie in there to (unintelligible) . . . operation o o 70 years old . . . he tell me ever time it changed the world . . . (unintelligible) V. Arthritis? (Pause while GEORGE takes care of customer) G. I'm going to tell you situations . . . or whatever . . how much you want me for, forrthe longest time I keep your radio I will give you whatGVer, you know, your money you wants me give you, you know, because my -relatives are going go in Europe, and really, by this present time I'll give you some money, you know, OK, Even when? tomorrow, even tomorrow, radio and I give you . . I going to give your the . No you can hold onto the radio, hell, what the hell. No really. I think three hundred is a fair price. Pardon me. Three hundred's fair That's sounds good, it's good_price. But if you don't want it, you know, say so, you won't That's up to you to decide. embarrass me. That's right, I was opening the shell and I never saw nothing like that . . . The Army has them Hell of a piece of equipment, yeah. What the hell . made to specs that are unbelieveable. the other night you're were kinda late, you know, it was kinda late when I was talking to you . . . a hundred thousand . . . cash . . . Cash on line, and if you don't believe, I get it my house, any kinda way to want it. I don't care what way you want it, he'll do it cause if (unintelligible) What's he in for? Huh? What's he in for? What's he in for? G. He's a . V. What's ZEF? . . What's he in for He killed three niggers . . . (unintelligible) . . . they robbed his place and they came about two - three o'clock . restaurant Is that . downtown? . . . . . that's not that one dOWn on Woodward (unintelligible) That's the one. Oh really? to (unintelligible) An shit . . . I never did hear what happened that Because a . There was a big thing on it when it happened . . ah that. o They were changing the things one day said this, one day said this and it was all badly abused, you know . . . that day it was my house, and I said, he told me it's somebody he knows and he, told, and he, you know, that guy, that guy, he picked him up in house, he didn't tie him up, they know each other for many years, you know he didn't tie him up and he was out of jail . . . something like this he I always said they told him, you know, eh he told me. don't going to be in jail for shooting . . . you (unintelligible) they said they found him dead, there's no fucking dope, cause I been there you know he never sold dope, never in his He had lot of pushers there, all time, (unintelligible) life. -5- Where was that place?' ' It was on Woodward somewhere. Yeah, near Clairmont. Clairmont? G. Clairmont. (Interruption ~ Routine bar talk) G. So . . . (unintelligible) . . . says to him, you know, he says ah, we think you found some guns, and he said no, he says ah, (unintelligible) he says stupid, you know, (unintelligible) . . . cause my mother's cousin, my mother's, my mother had ah, had a brother, you know, so her father and that guy's All father they are brothers. Albanian? Albanian. I got to thinking bout that, you know, after . . . it was late at night and I'm thinking Shit goddamn, you setting me up, or what, you know. No way, no way man. Us Albanians, we dcn't, (unintelligible) there's no way man. I am nothing like this, you know, the guy, he is . . he's there. You know, after I mentioned to you, that guy, his daughter (unintelligible) used to own Airport Limousine. Who . . oh Airport Limousine . . . yeah. . . he had a There is the one . . . (unintelligible) talk with him and he told me, says, promised him he would be . . . six months . . . that son of a bitch it was not even four weeks after that he was dead in his house. Dead from what? with Albanians, I don't know if I want to screw around you guys are crazy. No . . . no . . . no . . . this guy did die . . . you know, he used to work for Jimmy Hoffa, he used to be his secretary, he used to own the Airport Limousine Service Yeah, I know the AirpOrt Limousine Service Well that . . . That was a Hoffa connected thing Yeah well he, he got shot in his bed. After he left (unintelligible) his wife told me that (unintelligible) You mean Hoffa got shot in his bed? No . . . his secretary. His secretary. His secretary His secretary's a guy though. That's right And he He, Oh . he, .'. . he, . it's a guy, oh yeah whatid he do with Airport Limousine. used to own Airport Limousine. and he got shot after that Oh yeah. We don't work that see, let alone . . . I work drugs and that stuff, Yeah he did. Keep track of . . He shoot . . . 64 (unintelligible) (unintelligible) this son of a bitch You mean he got shot? Shot him dead, four times. Who? 1 they say, he got shot and nobody know, they never Nobody Said anymore after mentioned him anymore, never. the (unintelligible). She work, she make it from M-Ss by cemetary there, you know _7.. I don't know that area that well. That's Pontiac. Yeah, I know Pontiac. M-59 goes through Pontiac 'Cemetary there, you know, on top of the Oh, it's right down, oh, as you come in from a, OK, I know where the Airport Limousine Service is, yeah, they used to have a garage there. Add they change it now, Orion now. she she bought a place Lake (Pause while GEORGE take care of Customer) G. Anything . V. No I just . . . . if I, if I go . . . eh . . . . If I know something . KIRK said This month KIRK said possible you're going, a shit . I don't really give No, my mother and my dad are going, for good. V. my dad are going Yeah. For good. If by any chance if I'm do have to go them in July, and if I have to go in July, then I'll know if they want to come back and I will do one thing . . I'll bring even here the radio, cause (unintelligible), I bring here the radio, I give it with DENNIS, I give it to JOHN,.(unintelligible) before it comes to this you nothing is going to happen to it and I'll call you in a (unintelligible) something happens (unintelligible) Well, you‘re going back, aren't you? Oh yeah. What a . Oh yeah. Oh yeah. . . can you go back and forth over there? Oh yeah. I thought there was some shit over there that you can't go . . . ' ' ‘Ah, no, ah my dad, my dad (unintelligible) No with you, but I understand alot of people can‘t go back into there That's right . . well, my brother finished military and my sister_husband, he is the, for 25 years working fOr Government, for Communist Government, and he he has a job, he is over telephone and telegraph. The post . office, the telephone, the telegraph, thats all the one. Yeah. It's not like here, you know. Here‘s it's a private industry it's there it's all Government One And job me, thing (unintelligible) and ah, he's he's over that. ah, heLs over that, one (unintelligible) he had a with the Communist, but anyway, they don't bother I just shut up. I don't say another godamn word. Yeah You don't say another word, and if we have a house there and stuff like that, you know, what you going to do, you One thing was great there . . . most .have no choice. people (unintelligible) like-a dollar was 2000 (unintelligible regarding value of the dollar against Yugoslavian currency You cannot find a kilo coffee today and Government). 100 bucks, buy kilo coffee. ‘7 You can't.find it? ._9... You cannot find ah white flour, American flour to make a food for.a hundred bucks a pound, you cannot find it. The Russian pumpernickel, some (unintelligible) they changed it. You die, that's why JIMMY CARTER is going next week there. ' ” JIMMY CARTER's going there? Yugoslavia or to (unintelligible) Lotsa money. That's it, that's what happened. So, so in the case of something, or you know, if you wanna be Well, I'm thinking, thinking about this other thing, you're talking what, a hundred thousand One hundred thousand dollars cash and besides that I'll guarantee you you'll get a biggest present of any, you ever had in your life. I don't give a shit what you got there, because I know the people. We are people that live like in native country, know what I mean, who are no no no shit, you know, really each but six hundred (unintelligible) . . hundred and some thousand dollars . . . man says whoever do the job, get the money (sent (unintelligible) . . . either he going to die there, do the job and get the money What about the a, courts? Appeals, what about going at it through the you know, and that Judge ROBERSON, assholes, assholes (unintelligible) . . you know what they want, just to get him out of there, cause, you know, just to get him out of there cause they have ways (unintelligible) just to get him out of there. OK, assume we . . . (Unintelligible) a person has somebody (unintelligible) he wants to get out of jail or something OK, soon as they transport someplace . . . setting us up, you know what I mean, some shit, you know. You mean transport him from the prison to ah, Something Yeah like this, but mental, mental, something —10_ You know, but when you go, so some guy I slipped, you know, fall asleep or Yeah but this is a . . (unintelligible) . three murders, they're going to watch him like a godamn hawk. That's the only problem. Yeah, but he has the best record. One of the best records out at Jackson four years. You know they allowed him? Talk out to his parents two - three times a week. I'm talking about two — three times on telephone. Where are his parents? Jackson Where are his parents though? In Detroit. Oh, they're they're \ Also, he had a TV, he has all kind things, kinds . . . (unintelligible) he gets all You can get anything if you have money. Yeah. What's . . don't know, . you know I could come down there, this things getting kinda deep. and, I You know something Hundred thousand is good. That's no bullshit I know, no bullshit, but what do I use for a front? Huh? Are they Vhat do I use for a front to talk to people. going to drop some money out in front? G. I don't understand. V. Put some front money up. G. It doesn't work that way. Five, ten thousand out in front. -ll- ' V. You got to talk to people though. G. (Unintelligible) I know, I know, I know, I didn't realize that, the guy says he does, you know, people that promised him, you know, he going through the court, nothing like that. Eh, shit, nothing happened . . nothing happened. So he said then just, I have to find somebody, give him money and get the job (unintelligible) hundred thousand, whatever he want, he wants, here . . . V. Yeah, but the problem is getting it after it's done. Say the act's done, son of a bitch is out of the country, you know I'm a Federal agent, I've about twenty years, you know that. I've got twenty years on this job. G. Twenty years, yes. (Interruption — Routine_b§r talk) G. So that's how it is, V. Yeah, it is crazy, guarantee, you know but I got to have some godamn number one, I got a partner a partner I work with, I make G. Huh. V. A partner. know . (Unintelligible . V. Hang up there . . . . I have he knows every godamed move He's an ex-Chicago policeman, G. weekends . . . uh, you they don't know if . .(waitress brings VAN HENGEL coffee) You know we're both . G. crazy . . These people, four negroes, they come in restaurant, baseball bats and knifes (unintelligible) I don't know, I'm sure they looking for something you know, 45 minutes, after 45 minutes he called the cops, the Detroit Police This not . . . show up. V. Vhen'd this happen. G. That night. V. Huh? G. That night. VO G. Oh, that night. That night. Do you believe that stuff. Add this guy, I think it's crazy, he he's going, he said he's going lay off six hundren policemen, or whatever, you know. Who the hell gonna control the god damn city? Something something . . . I'm really glad on Woodward this (unintelligible) people, they are nuts. I'm interested in what you're talking, that's why I wanted to get in here early to talk to you, but . You know something? or I could be setting you Either you're setting me up, up . . . no, No, No, no, no, no, misunderstand. . . no, . nothing like this. know something? Don‘t I‘ve got twanty years. You You know something, I'm not stupid, you know. We all are from families, know what I‘m talking about. nobody says nothing. Yeah, but I'm not part of Albanians, No, no, no, family and you're one of them. don't give a shit, delivery . the . . no and what‘s so we deliver, the, . . . those god damn They kill cops, they the thing of what's and boom. (unintelligible) I'm not about to go down there looking for a hundred thousand. . . Only one man you deal with would be JOE, his father, (unintelligible), me, nobody else involved. Nobody. I know what I'm talking about, and because JOE would talk to him, ZEF, you his dad, gonna give nobody the money anyway. know, give away his money real well, and the only thing we do . . . Or something . ZEF'S the guy that's in? He's 39 years old now . know yourself, if you . . . (unintelligible). raise kids today, . . you 10 years old, a, ic er Am in er th fa no th wi ed is ra be ey th , 15 , 14 16, That's a crazy, I mean, really know that is? you _l3_ V. Albanians don't like blacks, G. No, V. You sure you don't want . G. No, do they? not to well no way . . . . . you know what we, You can never saw it, you how We know. you can go all over United States, never can find a black got a decent place, nice place, where enjoy yourself, I never heard. I never heard. No I never heard. V. How long you been in the United States? G. Ten years. V. 1967 you used to be able to go to the Flame Show Bar downtown, all black run, those bars that ran down there and the best acts would come in there that's before the riots. We're talking about 60, 61 and sure they were catering to the white man, but you used to be able to go in there and if you minded your business, they minded there's and it was good. There was . . . (Interruption - Routine bar talk) G. You hear that? V. Barely read and write, G. Huh? V. Some of them can barely read and write G. They can't read and write, V. What don't you join the army. G. Huh V. Why don't you join the army. G. some of them . . . some of them . . . To late for me. Thirty—seven years old . . . too late. You know something? So many people, for so many men, for some of things Army make people human,.you know and ab. They make a person so live, make person something to .be anyway. Really. You get out of the school, you become 22 years, dumb then, I mean dumb, really, really, really what you gonna do, you know. _l4_ You go to school in Albania? Oh yeah . . . you have to, you have to learn how to read and write and language . . . (unintelligible) You're English is good What? Did you learn English there or here? G. Here. (Interruption — Routine bar talk) V. Before blabber mouth gets back here, ah, gonna need a couple of weeks just to even think on it. You're talking some shit though. G. Listen. First we die and all our life for something like this . . . I'm telling you. V. Yeah, G. Listen no, listen no, don't give me no (unintelligible) I'm not stupid you know, (unintelligible) the family still live in the eighteenth century like, they say they no change, I mean they say and that's all. I want I know, but I'm . . . with you to know something, you plan something, one day (unintelligible) V. I give him a little test run, so, we go just move him around a little bit and show_you what we can do, but I'm gonna need some assurance from you oeople before we do something dumb like that. ' G. No, no doubt about it. V. Do twenty years. G. Oh, V. Probably that on the other side, me and ZEF, I know that. (Interrupti9n_— Routine bar talk) V. GEORGE. I didn't want to talk with her around together. G. No. She can hear too god damn much. G. It is simple if no one knows V. Yeah. Give me a couple weeks, research . . . just for a little 'You know something. You're gonna have I do . . . to meet my partner, cause anything No, no, no listen. I tell you something, OK, on my word, you know, my word that I'm telling you the truth and whatever can meet you want to meet, whatever . . . Well, I'm gonna want some assurance. I know. Anything, anything, any kinda assurance, do you need, any kinda insurance it's possible to give anyone this way, you know,_any way, we give it. (Unintelligible) we want the guy out, is all. Pay the money . . . What you going to do with him when you get him out? We're going to leave him this country. No body gonna, nobody gonna expects he going be in old country. As long as they can do nothing about That's for sure. No it, you know what I mean . . . (unintelligible) way . I bring my partner in here, Don't say No, no, don't tell him any price. a hundred thousand, no, no . . nothing. . You can ta k to him Nothing, nothing He's ex—Chicago policeman, he's ah, I dOn't know about He's him, but when I move, he's with me all the time. I don't want him to know how much. gonna have to know. You know we all got a little game to play. Don't say nothing to. V. OK. guy. Let me, let me take a look at the Couple weeks. I got that piece of paper you wrote the name on. _l6_ G. OK. You know something? And he was not really bad guy, because after he knew he did it because they were niggers (unintelligible). Even, even the, even the judge and jury (unintelligible) Judge ROBERSON‘s brother, I know he he professor, you know, he's a professor in Wayne University. I think, and he told, the other lawyer, this guy told him, he's (unintelligible) the black guy, he's a lawyer now he is, he says (unintelligible). He say it never could happen, he since 1967, say, one black man can shoot three blacks at one time. V. Hmmm G. And the one when he told em, And he was pissed off. they told him, that if went down, they said the (unintelligible) took 45 minutes after when they called . They were police came . . . you can't imagine that. not that far, god damn it they could have come . . . . from Fourty—five minutes, I mean, no Flint to Detroit. Even if there trouble they could go, you know, I mean. was something danger, not from a, not from a, from thir . from eleventh precinct, even from Davison, eleventh Even from second precinct, downtown, on precinct. Beaubian, you know, they could go . . . so many kind police, at least five minutes . . . Detroit police came in, (unintelligible) V. Why he, why'd he shoot them? G. Because they came at him with baseball . . . baseball bats and knifes and they caught him in the office . . what are you going to do. . V. Hm‘am . G. I mean, what are you going What are you going to do. He couldn't go in the basement, he couldn't to do. So he had under the counter, he had a the, the move. the, the a what do you call it, this shit man, the, the, double barreled, you know, shot gun. V. Oh, G. ey th , ys gu r he ot e Th . om Bo . em th of t ou ck fu e Shot th ot sh he a d an , ns gu r ei th ok to d an m, hi s rd wa turned to t ou ab d ha y gu ch ea wn do ll fa ey th s, them two or three time ll ki t, oo sh he If n. ma dy bo g in ck fu r ei th in s ten bullet th ur fo e th d, ze li ra pa or e, iv al s wa k in One of them I th em. I do n ca r ve ne , lk wa n ca r ve ne he , guy . . . all his life shot gun. nothing, but he didn't see ZEF kill him. Do you believe that?