llntteb ~tates i!ltstrtctmxm_< 1620.00 1298.00 1.20 36.16 633.92 93.00 165.00 828.00 453.08 75.00 66.80 262.08 339.00 36.72 239.52 2655.80 43.80 . 5352.00 121.52 23258.00 556.78 514.00 145.52 Shipped 70pcs 38.08 Shipped 140pcs 103.36 Shipped 140pcs 180.88 Shipped 70pcs 68.32 Shipped 245pcs 35.20 Shipped 82pcs 134.00 24.00 84.46 30.24 340.00 5070.00 35.20 33.60 31.20 24.00 284.08 50.00 34.00 0.00 475.20 1437.45 8.56 23.94 459.00 1135.80 294.00 20332.00 Shipped 22150 2728.50 Shipped 5370pcs 14421.00 1162.50 5462.50 1162.50 11116.80 21172.80 225.60 112.80 176.80 11596.50 26230.00 261.60 75.68 0.00 7635.00 1175.58 25.50 1435.50 1227.15 644.08 644.08 618.00 363.35 185.50 0.00 30.44 1883.76 3.60 2060.00 719.60 963.22 14929.91 3247.60 88.35 33.12 15.00 Shipped 3pcs 349.20 Shipped 7pcs 5412.60 6984.00 1222.20 349.20 34105.60 2984.24 852.64 415.14 415.14 125.80 1482.24 40.30 0.00 3680.00 107.60 1040.00 41.50 117.00 22.40 94.40 23.55 41.70 66.60 23.55 22.35 21.45 354.60 42.00 8.58 8.60 4.65 92.70 10.35 14.85 3324.75 2105.60 2953.60 262.08 Shipped 25 2674.56 567.60 1574.10 1648.36 25.28 13.80 460.16 76.88 124.50 39.00 112.80 112.80 918.72 32.30 39.60 79.20 1041.60 33.20 37.52 4.50 1 8.96 413.40 11.84 25.80 3.76 4.40 0.00 29.34 1495.00 20.65 19.60 13.75 492.00 12.88 cmaA Trident Ha Moxoso? 4380.00 Trident Ha Moxoao? 185.50 shipped in 8 552.50 1747.20 291651.21 i 1 MELINDA HAAG (CABN 132612) United States Attorney 2 DAVID R. CALLAWAY (CABN 121782) 3 Chief, Criminal Division 4 PHILIP J. KEARNEY (CABN 114978) Assistant United States Attorney 5 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 6 Telephone: (414) 436-7023 FAX: (415) 436-7234 7 Philip.kearney@usdoj.gov 8 Attorneys for the United States of America 9 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 14 UNITED STATES OF AMERICA, Plaintiff, 15 16 v. 17 18 19 20 21 PAVEL SEMENOVICH FLIDER and TRIDENT INTERNATIONAL CORPORATION, LLC, Defendants. 22 23 24 25 26 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. CR 15-0154 VC DECLARATION OF RICHARD J. FITZPATRICK IN SUPPORT OF GOVERNMENT’S MOTION TO DENY BAIL SAN FRANCISCO VENUE I, Richard J. Fitzpatrick III, hereby declare: 1. I am employed as a Special Agent (“SA”) with the United States Department of Commerce (“DOC”), Bureau of Industry and Security, Office of Export Enforcement, and have been 27 since September 2012. I am currently assigned to the field office in San Jose, California. I am a law 28 enforcement officer of the United States within the meaning of 18 U.S.C. § 2510(7) and am authorized 1 1 by law to conduct investigations and make arrests for felony offenses. Prior to my current assignment, I 2 was employed as a SA with the U.S. Department of Homeland Security Investigations and the Naval 3 4 Criminal Investigative Service, where I investigated numerous violations relating to counterintelligence, counterterrorism, and U.S. export violations. I am the lead DOC SA involved in the investigation of 5 6 7 defendants Trident International Corporation, LLC (“TRIDENT”), and Pavel Semenovich Flider (“FLIDER”). 2. 8 This affidavit is made in support of the government’s motion to deny bail to the 9 defendant as a flight risk, under 18 U.S.C. § 3142(f)(2). 3. 10 On March 18, 2015, federal search warrants were served at the San Francisco, 11 California, office of TRIDENT and the San Rafael, California, home of FLIDER. The TRIDENT 12 Search Warrant is attached hereto as Exhibit A and incorporated as if fully set forth herein. I am 13 informed that approximately ten terabytes of data and thousands of documents were retrieved 14 collectively pursuant to those searches. The preliminary review of this material has provided new 15 evidence of foreign assets, companies, and real estate apparently held by FLIDER and described in 16 further detail below. Based on my presence at the initial proceedings conducted in open court in which 17 18 19 20 FLIDER’s assets were discussed and based on my discussions with government counsel, I believe that FLIDER did not disclose the existence of these foreign assets to the Pre-Trial Services Agency during his initial interview. I believe that the existence of these foreign assets, as well as their apparent willful 21 concealment from the Court, disclose a significant risk of flight by the defendant. I further believe that a 22 substantial portion of the approximately $69,653,430.67 of proceeds from the illegal export scheme 23 detailed in Exhibit A remain unaccounted for, and further contribute to FLIDER’s ability to flee if 24 released from custody. See Exh. A ¶¶ 88-90. 25 26 27 28 // // // 2 1 Evidence of Foreign Bank Accounts 2 Promsvyazbank, Russia 3 4 4. Documents recovered from FLIDER’s residence show that on July 31, 2014, FLIDER transferred 500,000 rubles from his account at the OJSC Promsvyazbank in Moscow, Russia, to the 5 6 7 corporate account of a Russian limited liability company named Fabrika Sveta held at the Sberbank Rossii OJSC (“Sberbank”). (Document and translation of this transaction attached as Exhibit B). I am 8 informed by Russian-speaking federal law enforcement officers that “Fabrika Sveta” means ‘factory of 9 light’ and that Sberbank refers to the Savings Bank of Russia, one of Russia’s largest banking 10 institutions and currently the subject of sanctions imposed by the U.S. Department of Treasury. I 11 12 13 14 15 believe based on this transaction that FLIDER has an active bank account with Promsvyazbank in Russia. MKB Bank, Hungary 5. A “Financial Services Agreement” seized from FLIDER’s residence revealed the existence 16 of another account linked to FLIDER with the MKB Bank ZRT (“MKB”) in Budapest, Hungry. This 17 agreement is attached as Exhibit C. This document demonstrates that in 2008 FLIDER opened an MKB 18 account in the name of “Santora International Ltd” (“Santora”), a company apparently formed by 19 FLIDER in the Republic of Seychelles as discussed further below. MKB account documents appear to 20 21 22 23 be signed by FLIDER in 2011 and list both his correct date of birth and a Russian passport number. See Exh. C at 8. In an account “Declaration” signed by FLIDER on April 26, 2011, FLIDER lists his address as “g. Pushkin ul. Shkolnaya, d. 39/33, kv. 177.” I am informed by Russian-speaking federal 24 law enforcement officers that this address refers to a residence on Shkolnaya Street in the City of 25 Pushkin, which is a suburb of St. Petersburg Russia, and is discussed further below. 26 SBERBANK, Russia 27 6. 28 Pages from a spiral bound note pad recovered from FLIDER’s home office during the service of a search warrant by your affiant on March 18, 2015, contained hand written notes in Russian 3 1 and English. They are attached as Exhibit D. One page of the note pad contained the name “Saving 2 Bank of Russian Federation, Moscow Bank Corr (correspondent) Account 890-0053-982 Bank of New 3 4 York USA.” Exh D at 1. This Sberbank account number is different than the recipient account of the ruble transfer from FLIDER’s Promsvyazbank account discussed above. As such, I believe this account 5 6 7 number appears to be evidence of yet another foreign bank account FLIDER either owns or actively does business with in Russia. 8 Evidence of Foreign Corporations 9 10 Santora International 7. As noted above, FLIDER apparently created a company in the Republic of Seychelles 11 named “Santora International Ltd” (“Santora”). Two official registration certificates dated December 2, 12 2008, with identical incorporation numbers were recovered from FLIDER’s home office pursuant to the 13 14 15 16 search warrant service noted above. These are attached collectively as Exhibit E. The documents reveal Santora’s corporate office to be located at Suite 9, Ansuya Estate, Revolution Avenue, Victoria, Mahe, Seychelles. The documents state the authorized share capital of the company to be $100,000 USD; each 17 bears a Republic of the Seychelles seal (dated August 11, 2014 and September 4, 2014 respectively). 18 Also seized from FLIDER’s home during the search were communications from the Hungarian 19 company “Laveco Ltd” (“Laveco”), an offshore company formation agency which bills itself as “The 20 offshore company maker since 1991.” A one-page letter on Laveco stationary addressed to FLIDER 21 22 23 24 with what appears to be a 2014 date states in relevant part: “I am glad to send you Certificate of Official Company Search of the company Santora International Ltd.” Based on these seized documents I believe that FLIDER has set up and funded an offshore company in the Republic of the Seychelles. 25 Fabrika Sveta, LLC 26 8. As noted above, documents recovered from FLIDER’s residence written in Russian and 27 translated by Russian-speaking U.S. law enforcement personnel appear to show that FLIDER obtained a 28 loan from a company named “OOO Fabrika Sveta” in 2013. These documents are attached as Exhibit F, 4 1 with English translations. I am aware that “OOO” is the Russian equivalent of a U.S. Limited Liability 2 Company. Open source research conducted by your affiant appears to confirm that OOO Fabrika Sveta 3 4 is a manufacturing company reported as located variously in Abakan and Stavropol, Russia. Documents contained in Exhibit F appear to show a “second stage” payment to a “no-interest-loan investment 5 6 7 contract” made by FLIDER to OOO Fabrika Sveta in the amount of 500,000 rubles on June 17, 2014. Exh F at 6. Based on my training and experience, I believe the existence of this no-interest loan to be 8 potential evidence that FLIDER either owns an equity stake in OOO Fabrika Sveta or that the company 9 is conducting work at FLIDER’s request. 10 Evidence of Foreign Real Estate Holdings 11 9. 12 13 14 15 In addition to his personal residence in the St. Petersburg suburb of Pushkin noted above, two documents recovered from FLIDER’s residence and written completely in Russian appear to be certificates showing FLIDER owns one lot of undeveloped land in Ryazan, Russia, which is approximately 170 kilometers from Moscow. These documents are attached as Exhibit G. The 16 documents are dated 2007 and appear to have official stamps from the local municipal government. 17 They correctly list FLIDER’s date of birth. Your affiant is aware that Ryazan is known to be a high-tech 18 manufacturing center in Russia and is home to many military-industrial companies. Ryazan is also 19 home to several Russian Air Force bases. 20 21 22 23 Foreign Travel 10. I am aware from my investigation in this matter that FLIDER regularly travels abroad, often to the Russian Federation. I am also aware from my review of Automated Targeting Systems data 24 maintained by U.S. Customs and Border Protection, that FLIDER, along with his wife and daughter, are 25 currently booked on Lufthansa flight 455 leaving San Francisco International Airport on June 16, 2015 26 bound for Frankfurt, Germany, with a follow-on flight (LH 1320), booked to Pulkovo, Russia. 27 28 CONCLUSION Based on the above, your affiant believes there is evidence that FLIDER has substantial assets 5 1 2 outside of the United States, including liquid assets, corporate holdings, and real estate. I believe he has affirmatively concealed these assets from Pre-Trial Services and by extension, the Court. Your affiant 3 4 further believes that these holdings-and the potential lifestyle they would afford--disclose a substantial 5 increase in the risk ofFLIDER's 6 to disclose these assets also reveals a lack of honesty with the Court and a resulting further risk of flight. 7 8 flight from the United States ifhe is released from custody. His failure I declare under the penalty of perjury that the foregoing is true and correct to the best of my Knowledge. 9 10 Executed on this 17th day of April, 2015, in San Francisco, California. :VJ!l/~j~J7L 11 12 Special AgeiIt Richard 1. Fitzpatrick III Department of Commerce 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 6 EXHIBIT A 1 MELINDA HAAG (CABN 132612) United States Attorney 2 DAVID R. CALLAWAY (CABN 121782) 3 Chief, Criminal Division 4 PHILIP J. KEARNEY (CABN 114978) Assistant United States Attorney 5 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 6 Telephone: (414) 436-7023 FAX: (415) 436-7234 7 Philip.kearney@usdoj.gov 8 Attorneys for the United States of America 9 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 14 UNITED STATES OF AMERICA, Plaintiff, 15 16 v. 17 18 19 20 21 PAVEL SEMENOVICH FLIDER and TRIDENT INTERNATIONAL CORPORATION, LLC, Defendants. 22 23 24 25 26 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. CR 15-0154 VC SUPPLEMENTAL DECLARATION OF RICHARD J. FITZPATRICK IN SUPPORT OF GOVERNMENT’S MOTION TO DENY BAIL SAN FRANCISCO VENUE I, Richard J. Fitzpatrick III, hereby declare: 1. I am employed as a Special Agent (“SA”) with the United States Department of Commerce (“DOC”), Bureau of Industry and Security, Office of Export Enforcement, and have been 27 since September 2012. I am currently assigned to the field office in San Jose, California. I am a law 28 enforcement officer of the United States within the meaning of 18 U.S.C. § 2510(7) and am authorized 1 1 by law to conduct investigations and make arrests for felony offenses. Prior to my current assignment, I 2 was employed as a SA with the U.S. Department of Homeland Security Investigations and the Naval 3 4 Criminal Investigative Service, where I investigated numerous violations relating to counterintelligence, counterterrorism, and U.S. export violations. I am the lead DOC SA involved in the investigation of 5 6 7 8 defendants Trident International Corporation, LLC (“TRIDENT”), and Pavel Semenovich Flider (“FLIDER”). 2. This affidavit is made in support of the government’s motion to deny bail to the 9 defendant as a flight risk, under 18 U.S.C. § 3142(f)(2). 10 3. The U.S. Department of Commerce (“DOC”), Bureau of Industry and Security (BIS), 11 Office of Export Enforcement (“OEE”) has investigated the illegal export activities of FLIDER and his 12 corporation TRIDENT since 2004. During this investigation SA’s with OEE have interviewed FLIDER 13 14 15 16 on three separate occasions regarding his export business. In all three of these interviews detailed below, FLIDER provided false statements to investigators about his company’s exports. Evidence of False Statements 17 2004 Interview 18 4. I am aware that on January 23, 2004 OEE SA’s contacted FLIDER at his residence and 19 the corporate location for TRIDENT, located at 4773 Surrey Lane, Richmond, California. During this 20 interview FLIDER claimed that the end-user of the commodities he exported was a company called 21 22 23 24 “Sparta” located in St. Petersburg, Russia. FLIDER said he was aware of the DOC Export Administration Regulations (“EAR”) and that all the commodities he exported were classified by the manufacturers as “EAR99,” meaning no U.S. government license was required for their shipment to 25 Russia. According to FLIDER, he chose not to purchase commodities requiring an export license to 26 avoid the “headache.” As your affiant I have reviewed evidence recovered from the March 18, 2015 27 search of FLIDER’s residence and the TRIDENT office space that directly contradicts FLIDER’s 28 statement to OEE agents in 2004. Among the evidence recovered are TRIDENT invoices going back as 2 1 far as 1999 and showing multiple shipments to Russian end-user “VO Mashpriborintorg.” According to 2 open source reports from the FBI VO Mashpriborintorg is a procurement front company for the Russian 3 4 Intelligence and Security Service. Nowhere have I found evidence of TRIDENT exports directly to “Sparta” as alleged by FLIDER. As your affiant I believe FLIDER fabricated “Sparta” as cover for the 5 6 7 true end-users of the electronic components he exported. I have also found extensive evidence that FLIDER exported controlled (non-EAR99) electronic components to Russia. 8 2013 Interview 9 5. On August 5, 2013 your affiant along with another OEE SA interviewed FLIDER at what 10 was at that time his residence located at his residence in Richmond, California. During this interview 11 12 13 14 FLIDER told your affiant he has had one and only one customer, Estonia based Adimir, for the past 18 years. FLIDER was adamant that he did not export to any end-users inside the Russian Federation. When asked about his previous statements regarding Sparta as his customer, he said Adimir used 15 “Sparta” only as a consultant for various projects. I have reviewed, sometimes with the help of 16 Russian- speaking federal law enforcement officers, results of search warrants executed on FLIDER’s 17 email account which directly contradict FLIDER’s statements in 2013. In addition, a Mutual Legal 18 Assistance Treaty (MLAT) request to the Estonian Customs Service returned thousands of documents, 19 20 21 22 23 including interviews with Adimir corporate officers, which directly refute FLIDER’s statements to your affiant that Adimir was the end-user for TRIDENT exports. 2015 Interview 6. On March 18, 2015, federal search warrants were executed at the TRIDENT office space 24 and FLIDER’s residence. Subsequent to the execution of these search warrants your affiant interviewed 25 FLIDER at his residence after reading FLIDER his Miranda Rights from the BIS FORM 7008TF 26 “Office of Export Enforcement Warning and Waiver of Rights” form. FLIDER read his rights and 27 28 waived them both verbally and in writing at approximately 11:03 AM (PST). During this interview FLIDER told your affiant that from 2000 to 2013 he only exported electrical components to Adimir and 3 1 denied exporting to Russia during that time period. FLIDER was shown copies of TRIDENT invoices 2 discovered during the execution of the MLAT dated during the 2000 to 2013 time frame which showed 3 4 Russian end-users for his exports. In spite of this evidence FLIDER denied to your affiant that he had exported the items to Russia. I am aware of the information contained in Exhibit B, the affidavit of FBI 5 6 7 SA David C. Koblitz which provides the details of a small sampling of the hundreds if not thousands of suspected exports of electronic equipment to Russian end-users made during the exact time frame that 8 FLIDER claimed not to have done so. As such and based on my broader investigation, I believe that 9 FLIDER’s statements to me were untrue. FLIDER did admit during this interview that he undervalued 10 TRIDENT exports and falsified the end-user information provided to his freight forwarders which were 11 input into the shippers export declaration (SED) and/or the Electronic Export Information (EEI). 12 False Statements on SEDs 13 7. 14 During the course of this investigation I have personally reviewed 156 Shippers Export 15 Declarations (SEDs) filed by FLIDER for TRIDENT exports between January 2009 and April 2014. All 16 of these SEDs untruthfully listed freight forwarders in Finland and/or Estonia as the ultimate consignee 17 for the corresponding TRIDENT shipments. When SAs and local law enforcement visited these sites 18 they found no electronic or industrial manufacturing facilities. Your affiant believes these falsified 19 SEDs constitute further evidence that FLIDER is dishonest with U.S. government personnel. 20 Foreign Travel 21 8. 22 FLIDER is a Russian émigré and naturalized U.S. citizen who has lived in the U.S. since 23 1992. FLIDER has maintained he was born in the country of Belarus, formerly of the Union of Soviet 24 Socialist Republics (USSR); however FLIDER maintains passports only from the U.S. and Russia. 25 Over the past few years FLIDER has consistently traveled to Russia for extended periods of time. 26 27 During these trips FLIDER utilizes both his Russian and U.S. passport interchangeably. // 28 4 CONCLUSION 1 2 3 4 9. Based on the above, your affiant believes there is evidence that FLIDER has continually provided false statements to your affiant and other federal law enforcement officers during this investigation. I believe the fact that FLIDER has continued to provide these false statements, even when 5 6 confronted with contradictory evidence, reveals a lack of honesty which your affiant believes can and 7 will translate in to an increased risk of flight ifFLIDER is released from custody. The growing body of 8 evidence collected during this investigation, including as characterized by SA Koblitz as referenced 9 above, also reveals a nexus between FLIDER and end-users in the Russian military- industrial complex. 10 11 It is your affiant's belief that with the support of the Government of Russia FLIDER could flee this country if released and find safe harbor inside the Russian Federation. 12 13 14 15 16 I declare under the penalty of perjury that the foregoing is true and correct to the best of my Knowledge. Executed on this 18th day of May, 2015, in San Francisco, California. ;Uil& 17 18 Special Agent Richard J. Fitzpatrick III Department of Commerce 19 20 21 22 23 24 25 26 27 28 5 BRIAN J. STRETCH (CABN 163973) United States Attorney BARBARA J. VALLIERE (DCBN 439353) Chief, Criminal Division PHILIP .I. KEARNEY (CABN 114978) Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 Telephone: (415) 436?7023 FAX: (415) 436?7234 .srev Attorneys for United States of America UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION UNITED STATES OF AMERICA, NO. 15?0154 VC JOINT SUBMISSION REGARDING RUSSIAN TRANSLATION OF PLEA AGREEMENT Plaintiff, V. TRIDENT INTERNATIONAL CORPORATION, LLC, I i Defendant. At the Court?s request, the undersigned parties jointly submit the attached declaration of Russian interpreter Yuri Galashoy (?Declaration?). The Declaration describes corrections made by Mr. Jalasnov to his His JOINT SUBMISSION RE TRANSLATION OF PLEA AGREEMENT CR 15-0154 VC corrected Russian translation of the Agreement has previously been submitted to the Court. Dated: August 22, 2016 MARCUS DANIEL MERCHASIN Attorney for Pavel Semonvich Flider BRIAN J. STRETCH United States Attorney Dated: August 22, 2016 PHILIP J. KEARNEY Assistant United States Attorney 23 24 25 26 27 28 PLEA AGREEMENT CR 15-0154 VC 2 MARCUS DANIEL MERCHASIN Attorney Counselor at Law 2 Post Of?ce Box 10369 Lahaina, HI 96761 3 (415) 269?0481 Fax: (415) 520-0426 4 Email: marcus@merchasin.com Attorney for Defendant, 6 Trident International Corporation, LLC 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 1 1 12 UNITED STATES OF AMERICA, No. CR 15?0154 VC Plaintiff, 13 DECLARATION OF YURI GALASHOV v. REGARDING RUSSIAN TRANSLATIONS OF 14 PLEA AGREEMENTS TRIDENT INTERNATIONAL 15 CORPORATION, LLC, 16 3 DefendantYuri Galashov, hereby declare: 21 1. I am a court-certi?ed Russian interpreter who has been retained by the defense in the above?named matter. Included in my duties was the preparat1on or Rusman translations of both the 23 corporate and individual plea agreements to assist defendant Pavel Flider in his understanding of both 24 25 documents; based on my extensive interaction with him however, I believe Pavel Flider to be ?uent in 26 both the Russian and English languages. I initially prepared Russian translations of each plea agreement 27 in preparation for the entry of pleas on August 16, 2016. As noted in my previously?filed interpreter 28 certifications, I went through the Russian translation of each plea with Mr. Flider Who expressed an 1 understanding of the terms and provisions of each document. I believe this understanding was based also on Mr. Flider?s reading of the English versions of each agreement. After being noti?ed on August 16, 2016, of a potential translation error in one of the documents, I undertook a complete, line-by?line review of my Russian translations of each plea agreement as compared to the ?led English versions. 5 This review was conducted with the assistance of a Russian?speaking FBI Special Agent. In each 6 document, several differences between the English ?nal version and my initial translations were found; 2 these differences were corrected as described below. Our handwritten corrections regarding the Trident 9 International Corporation, LLC (?Trident?), plea agreement are noted in Exhibit A attached. My 10 corrected ?nal Russian translation of the Trident plea agreement has previously been provided to the 1 1 Court. 12 After making the corrections, I called Mr. Flider on August 17, 2016, and explained the changes 13 made to the Russian translations. Mr. lider stated that he understood the changes and approved of their 14 use. Mr. Flider expressed to me that the changes did not affect his understanding of either document or 1: the desire to maintain his guilty pleas for Trident. Mr. Flider is the President and CEO of Trident as 17 well as the sole shareholder of Trident. 13 Explanations of Corrections Made to the Russian Translation of the Trident Plea Agreement 19 1. In the ?rst line of the introductory paragraph on page one, an end quotation mark was 20 placed in the parenthetical after the word ?Trident.? 21 2. In Paragraph 1, in the ?rst and second sentences, the words ?money laundering? were inserted and the words ?smuggling of goods? were deleted. In the second sentence of the 24 same paragraph, the word ?and? was deleted to correct the sentence?s grammar. 25 3. In Paragraph 2, in the ?rst sentence, the tense of the word ?pleaded? was changed to ?is 26 pleading.? Later in that paragraph, the words ?in the export documents? were inserted. 27 28 1 4. In Paragraph 3, the word ?Trident? was inserted at the end of the paragraph and the word 2 ?employer? was deleted. 3 5. In Paragraph 4, in the second sentence, the word ?conviction? was inserted and the words 4 ?guilty verdict? were deleted. 5 6. In Paragraph the word ?until? was inserted to connect the parts of the sentence. In 6 Paragraph the words ?compel? and ?subpoena? were inserted to clarify the meaning 2 of ?to summon.? 9 7. In Paragraph 9, the ?nal two words, ?sentencing decision,? were deleted and replaced 10 with the word ?sentence.? 11 8. In Paragraph 10, the third sentence in the third paragraph was not changed. The word 12 ?possible? was deleted in error and no words were inserted. In the ?nal sentence of that 13 paragraph, the word ??nancial? was replaced with the word ??nancial litigation? to 14 clarify the nature of the department. :2 9. In Paragraph 12, in the ?rst sentence of the second paragraph the words ?money 17 laundering? were inserted. In the third sentence of this Paragraph the words ?that,? and 18 ?any,? were inserted to correct the grammar; the words ?related to state jurisdiction? were 19 inserted to improve the grammar structure of the sentence after the words ?and will not 20 assist anyone to contest? and the word ?state? was deleted. 21 10. In Paragraph 14, the ?nal clause of the ?rst sentence was changed from ?Trident will not claim otherwise in the future? to ?supersedes any other agreements, written or oral.? 24 11. In Paragraph 16, the words ?to dismiss? were replaced by the words ?to move to 25 dismiss.? 26 12. In Paragraph 17, the word ?pledges? was deleted and the word ?agrees? was inserted. 27 28 Paragraph 19, the words ?right of? were inserted to clarify the meaning of ?ownership.? 14. In Paragraph 20, in the ?rst sentence the words ?existing? and ?deprived of the right to enter new contracts? were added to clarify the meaning of ?debarment? due to the lack of an analogous Russian verb. In the third sentence the words ?such debarment? were added to make the meaning of the sentence clearer. 15. In Paragraph 21 the words ?carried out? were deleted and the words ?observed? were inserted. I declare under the penalty of perjury that the foregoing is true and correct to the best of my Knowledge. Executed on this 22nd day of August, 2016, in San Francisco, California. Yuri? Galashov Certi?ed Russian Interpreter 23 24 25 26 27 28 Government?s Exhibit BRIAN J. STRETCH (CABN 163973) United States Attorney DAVID R. CALLAWAY (CABN 121782) Chief, Criminal Division PHILIP I. KEARNEY (CABN 114978) Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102?3 495 Telephone: (415) 436?7023 FAX: (415) 43 6-7234 Philip.kearney@usdoi.gov Attorneys for United States of America CYTT HITATOB CEBEPHLIIZ OKPYF @325 15-0154 VC npomg CTTEJTKA MERRY TRIDENT INTERNATIONAL CORPORATION, LLC O6BHHaeMbii?1, Trident International Corporation, LLC, (??Ttideni) HpORypaTypa no OprT?y KanntbopHnH (nanee ?HpORypaTypa 3T0 cOTJTanieHHe BHHBI ("Cornamenne") 11 (1) (A) 11 (B) Hpaenn O?emamm Trident: l. Trident OBOTO no ?eBnTHannaTs upenbaeneHHOTO TWOB HapymeHne 18 U.S.C. flew? gmwaa?xmw #14222 Trident 11p113H2101, T1TO aneMeHTaMH 109011013 51131151101011 01101130010110: (1) 01130an11 11011er 0 M00121 321 npe1101121M11 1111211013 1c Meory Ha Teppnropnn 1111211013; (2) 0 HaMepeHHeM 00110110130132111, 11110130110111110 onpeneneHHo? r110511e111311o01121, a 10132111013 113 1111211013. Trident 11p113H210'r, KaqeorBe KopnopaTHBHoro 01130111111121 OH 110001 321 11017101131151 01301111 corpy11H11111110H111>L I110 110p11011 0 17 ne11<11e1111171, 1E110 11 T1a011310 EEI 11 AES, 21 12110110 31101101311111): 6111121 11H1110p1v1a111151 0 11031B30Ba'1?e1111x 111111 1101101111010 1131111121 Hammer-11111 311011013121. Trident 6B1110 113B001H0L113111 011 61131 Ha 11Hd>0pMa111111 11 y6ea1<1101111?3 T110 3110110prepB1, 110110611110 Trident, 111111 npen01aB1/11e1111 CoennHeHHBm 111111 3K0110p10pa Hecyr 321 1101121113! 1101111010 11 npaBHJIBHoro EEI 111111 Bcex 3K0n0p111pyeMB1X 10Bap0B, Roma 010111100115 01111010 10Bapa 0001aB11;1e1 601106 $2,500. Trident 611110 1131300111125110 31a 11006X011111v1as1 HthopManHH 0e61, 1101111110 B0010 1113011010, 11a3Ba1r11e USPPI, 0111102111110 TOBapa, 010 Bee, rpysononyqaremr 111111 11011011110010 11 01011M001B 10Bapa. Trident 6B1110 113B001110, 113111 OH 6B1JI Ha 00110Be 11th 0pMa111111 11 I110, 1E1211111111110 111111 1101111001110, Bce 1pe6yeMBIe EEI 01110011103113110 11111Ha1111a111 113111111131 10Bap0B, BBIITIC 11 35110110110111111 1137111112111 0 nepBoro 110 11511112111113113111, 61311111 30111111311111, 311160 31121321111111 K011011H010 rpysononyqarena, 111160 01111021111111 10BapB1, K010pBre'11epeB03511051, 111160 1111 010111100111. Trident nanee 11p1131-1a01, 111111 0H 6B111 11p011H?0pM11p0Ba11, 11a 00110Be HthopManm/I 11 1110 0111121111 321 BKCHOPTHBIG 011epa111111, Trident 1101131111111 cpegcha 113-321 py6e>1115015, 1110 010 05501101 65111 50311130515505. Trident 003110105550 11 506p0505550 01110351500105 01 05e5y1011111x 5p05 5y10M 30515110111151 0 51311311011151 5111151: (0) 11p050 50 5131131105015 00651 51111051151111; 1111050 50 0110115571 11 53765111155111 0y5 1101305 11p11051>115511111; (0) 1111050 50 31111110111555y10 1101101115 055011010 5 0y50; 1113050 05111015051 5051150555511 50 1011 501%50 50 65150 y01011055050 5 X050 0y5e611010 130361113010550150 550 pasyM55 01111101111171; (0) 5p050 110 01153110 01051137 11 5051100 051150105011 065115051151 5 0y50; pl?d??g?cg??igima? no ggamg??. 0511501050171 3011111151 01 5M0511 Trident 50 0y5e6500 p03611p01e55015?0; 11p050 50505015 1105010110150 06 01505051111 50110301055015 111111 11131160153715 11 301111110 5 00015010151111 0 1101110131011 11511 1151105 1105p05110M11 11 K050151y111111; 513050 505010501505015 0 11p055555051111 50110301055015 0651111051151, 3051555115 11 111011121X, 05p050131010511111 11011 11 51305551555115 50503010550150; 11 (1) 513050 06510505015 11011105110 0 11p1135051111 5111151, 5106510 50010505505551'Cy50, 0 1011510 11011015111160 00110111 Hp111050p0, 5 TOM 511050 0 503M051051111 3765111105. Trident 0011101500105 110 11050101101505015 50pe5 0y50M 06 0135150 010 51111350111111 5111151 110050 1010, 11011 0110 6y501 511000110. Trident 11051111001, T110 301111105051 50010511511171 (0) 05 001110005, 1110 111011151, 5350111055510 5 113151110 2 50010551010 C01505105115 65115 50110553050551 5p01115 5010 5 00015010151111 0 Fed. R. Evid. 801(d)(2)(A) 5 5106011 50050530015011 p03611p010550150, 5 10111 1111050 5 0y5e, 5 05y500 001111 05 5013355111 501150?5560 113 3705051111 1100105115010 C015051051151, 11 011 603y050550 01110351500105 01 51065111 11 50011 111105 5 00015010151111 0 Fed. R. Crim. 11(1) 11 Fed. R. Evid. 410 5 01110510111111 111011105, 11350111055551 5 11y51110 2 50010551010 C01505105115, 5 51060111 1011011 11005053101505 11110110000 Trident 11051111001, t110 5p051110550150 50 6y501 1111051115 11011110 51160 50510015055510 50503010550150, 11011151055510 5 3101/1 05y500. Trident 1101111111001, 510 Cy5 5055105 011111101505 50 Py1105050150 50 5515000111110 11p111050p05 C005550555IX H110105 11 5p11511M015 11X 50 551111011110 51311 55111000111111 npnrosopa, (paKTopaMr/I, 18 U.S.C. 3553 Trident TaKme qro Cyz: He 0135132110 pacquaMH anBeneHHann HmKe M0>Ker BBIBOIE, qro npnmensrercg nnanamH ecnn OH 3T0 czrenaeT, Trident cornatnaercyr, Irro OT Trident He Gyne'r HpaBo, He 6yner npocmra, eBoe BageneHne 0 BHHBI. Trident Terrace cornamaeren reM, I1T0 PYKOBOJICTBO npnroeopa Gyner cnenyroan/IM 06pa30M: a. Ba301313ni?1 U.S.S.G. 8 b. (60.0% $50,000,000) +24 (18 U.S.C. 1956) +2 0. -3 Benn Trident 6y21e'r 'rpeGOBaHHm U.S.S. 3E1.1, Trident MOHCBT Ha Ha 3a 1{To Trident HOHHOCTBIO an3HaeT ceoro Hurry, Gyner CYZIOM Ba up}: HIOSOM Ha nonpnroraopno? cram/m no pacnopnmeHmo eyna, 6yner npononxca'rb npn3HaHne BGCL 13101:qu BpeMx d. npaBOHapyrneHHe 31 e. Ba3HeH5n?fI HrrpaQ: 0 US SG Inrpa? - $13,500,000. f. oneHKa BHHOBHOCTH: 5 g. Pacqer mrpadra: Ha USSG 8C2.7, mrparba paccqn?rHBaeTcn cnenyromHM 0613213001: In'rpad): $13,500,000 K03??Hnnenrz 1 ?nanmon mTpaQa: 8. Trident cornaceH 0 RM, T1T0 coorBeTCTBonmHM paspemeHHeM eroro nena 0 PI 18 U.S.C. 3553(a) m?rpaq) paBMepe $500,000 coorBe're'rBHH 8C3.1 chK, a Tarorce c60p $200. 9. Trident ,coriraceI-r, qro or Jrro6oro npyroro Hacromnero rM?F/w 5%47? Kev/wage @Mxy?d Pier Hporcypa'rypa MODKCT PI 6yner npenocraanrrB Cyny PI eernc6aM Han30pa 3a BCIO HmbopMauro, nMeromyro 1/1 cyng?rorry . Trident corJIaceH, 6yner npKHaraTB Bee yawn/In, HOHHOCTBIO B06 3111161368., CYHOM. Trident MOMSHT TGM, HID6BIC HO YHIGPGEI IIOIDKHBI 6BITB OHHBI-IGHBI 1131363 cyna HJIH BBHIHCEIHHBIM Ha KnepKa cyna Trident corJIaceH, Irro Jrro60? mrpad), PIJIPI B03MenreHIre ynrep6a, cerOM, nonnexca?r ornIaTe 1/1 Moryr 6BITL Bocrpe60BaHBI nporcyparypoii 18 U.S.C. ?3613. Trident IITO nporcyparypa MOXCBT Beero Hrrpadia, B03MenreHmr ymep6a JIIO6B1X 6e3 yrrera rparana nnarexcefr, CYIIOM PIJIPI HansopHo? cnym?o?, 1/1 qro mrparbbr, nanomeHHBIe cynorvr, 6yner Ha orbeerHBre nporpaMMBI?KaBHaqe?cha, Tarc Trro Jrro6o? {benepanrarrm? Hnarem neperraqa Moryr 6BITB mm KOMneHeaunn (benepanBHBIX Trident PI nporcyparypa cornamarorcg, Irro mrpatbbl, Ha Trident CornameHHeM, yBOBnerBopeHBI TOJIBKO 3a CT-IBT Trident, a nanBre mm Koprropanmr, TOM qncne He Gyny?r rum mrparbOB. Bro corJrameHHe He Hercirroqaer BOWKHBIX no KoropBre 651m nepenaHBI or Trident PIJIPI anaM, Trro?br n36encarb ynara'rBI motioro mrpatba, nanomeHrroro cornarneHHeM. Trident rarerce eornarnaercg YBGIIOMPITL nepen reM, nepenarr) HHrepee Trident BJraneer pero PIJIPI co6cheHH00'rB, K010130171 Trident Bnaneer Hort 1110613114 PIJIPI Kan npyroe 3114110, TOM qncne rpacrrar, TOBapnmecha, . Trident He AU roro, Kan Gyner HanomeHo He HaMepeHHo cyn, IIOCYJICGHBIM anym?aM PIJIPI Hporcyparype; BBEIOJIHHTB JIEO6BIC prrI/Ie Trident eornaceH, Irro BCJIPI OH He Kame?nr/I?o HaeroyrnreM TO HpOKypaTypa (Syner 06130609KneHa OT Bcex CBOPIX 06enraHni?r Cornanrenmr, TOM qncne Hmrce cexunn o?enrarrn? HO Trident He Gyner or Basrmennfi anBHaHnn BHHBI 12. Trident cornacen Ha Kontbnenannro cnenyronrero nMymeeTBa (nanee no TeKcry nMymecho?): a. $226,601.60 17 Mapra 2015 rona, n3 Wells Fargo Bank 00 quTa b. $1,308,736.42 17 Mapra 2015 rona, 113' Wells Fargo Bank 00 were. e. $3,177,651.64 l7 Mapra 2015 rona, H3 Wells Fargo Bank co enera a TaKnce d. $344,070.73 18 Mapra 2015 rona, n3 Avnet, Inc. Trident anBHa?T, neKOBoe mynrecrno npencraBnner 006013 or exeMBI Konrpa6annbri onneannofr BBnne Hapyinenne l3 U.S.C. 305 1 18 U.S.C. 554, o6pa30M nonnemr nonB3y 13 U.S.C. 305 (3), 18 U.S.C. nponenypBI, nsnonceHHBIe npaBnne 32.2 (DenepanBHBIx npaBnJI erJIOBHoro cynonpomBoncha, 21 U.S.C. 853. Trident OTKaBBrBaeren or BceX npaB, npaBa co6cheHnoern, 3110650: KoropBIe Trident Mor nMerB co6cheHHocrn corJIaeeH 1Lrro TaKoe @2130, Moryr 6BITB nonbsy 663 Trident rarone cornacerf?g?ne 6ygre?r ocnapnBa'rBcyne6 ponenyp . (631mg TO rocynapKrB $7 . - em), KoropBre Moryr 6BITB npornB yrcaBaHHon ?41577 Toro, Trident cornaeeH or BceX npaB M2 m/ga? motion (bopMe (B TOM nncne mano6, - . - - Kin/I mo6anr cnoeo60M) acneKTy ocynrechneHI?Io? CornanrenneM, no KaKnM-nn6o TOM qncne TOM, qro npeeMepHHM mrpatborvr HaKa3anneM TOM, npon3BoneTBo no 6131310 Bos6yn>). Trident, 111111 11p213011p00MH111<11 010 001111 310 111101100121B1111, 11p011c21 111111 1101101B1151 He 1131101111101 0651301011101Ba Trident 110 11210105101011}! 00111a1110H1110. Trident He 11011111011 11011013115111, H21 10, 1110611 113601112111 061311011013 20. 11001051111011 0011101110111111. c? Trident 11011111112101, T110 010 00y>1<11011110 M01101 11011B0p111y11. 010 p031111111111M 1101101111111011111131111 11001101101B1111M, 3111110112151, 110 110 orpaH111111Ba5101, 11p1100121110B11011110 1101101an 111111 211111y1111p013011110 111061111 11111101131111 111111 paspemeHHI?iI, KOTO 13111121111 Trident, 11 11p1100121110B11011110 111111 0101p21HeH1151 Trident 01 2,1 C001111H0H11131MI1 111111 0 11106131111 roeynap01B0HHBIM 211011101B0M, 111111 010 01110110111. 0011121111011110111 HpOKypaTypa He 110112101 1111112110111 3051B110H1111 111111 f? 21. 22. 23. 3"a 06emaHHe ornocnrenbno HJIH KaKnX?nn?o 1211114 pa3pe1nenn?. qacrnocrn, anOCTaHOBneHne Hm 1/1 Trident npeneraBneHo Ha yCMorpeHne HOZLPHILHBIX oprann3aur1? nercnroanenbno npenenax nx nonHOMoqnii. Trident HOHnMaer, qro notionnme He 6yner rum BHHBI Trident. Trident TITO OH HMeer npano sarcnroqunH Hae?rosnnero He nosnnee nonaqn Trident nonmeH npenocraBHTL nporcyparype 1/1 cyny Horapnanbno 3aBepeHH0e Hoanepxcnaromee, T-ITO Trident Imeer 3ar