January 27, 2000
Brendan V. Sullivan, Jr.
Howard W. Gutman
Williams & Connolly
725 12th St., N.W. Washington D.C. 20005-5901
Re: Arthur A. Coia
Criminal No- 00
Dear Mssrs. Sullivan and Gutman:
This letter sets forth the Agreement between
the United States Attorney for the District of Massachusetts ("the
U.S. Attorney") and your client, Arthur A. Coia ("Defendant"),
in the above captioned case. The Agreement is as follows:
1. Entry of Plea
Defendant shall today plead guilty to the
annexed Information. (In the event the Court's schedule does not
permit the entry of Defendant's plea today, the plea shall be
entered at the earliest practicable date). Defendant expressly
and unequivocally admits that he in fact knowingly and intentionally
committed the crime charged in the Information, and is in fact
guilty of that offense. The U.S. Attorney and Defendant agree
to the accuracy of the attached Agreed Factual Basis, which represents
the factual basis for the Information.
2. Penalties
Defendant faces the following maximum penalties:
Five years' imprisonment; $250,000 fine; three years' supervised
release; $100 special assessment.
3. Sentencing Guidelines
The parties agree to jointly take the following
positions at sentencing with regard to offense conduct, adjustments
and criminal history under the United States Sentencing guidelines:
a) The applicable guideline to Count one
is U. S. S. G. §2F1.1, with a base offense level of 6.
b) The loss resulting from the defendant's
conduct is $99,646.79, and therefore a six-level enhancement is
warranted pursuant to U.S.S.G. §2F1.1(b)(1)(G).
c) The offense involved more than minimal
planning and involved a scheme to defraud more than one victim,
and therefore a two-level enhancement is warranted pursuant to
U.S.S.G. §2FI.I(b)(2).
d) The defendant is entitled to a two-level
reduction for acceptance of responsibility pursuant to U.S.S.G.
§3EI.1(a).
e) The defendant is entitled to a four-level
downward departure pursuant to U.S.S.G. §5K2.0 for his cooperation
in the reform process of the Laborers' International Union of
North America.
f) According to the information presently
available to the U.S. Attorney, the Defendant is in criminal history
category 1. The guideline range for level 8, criminal history
category I is 0-6 months.
The U.S. Attorney's agreement that the disposition
set forth in Paragraph 4 below is appropriate in this case is
based, in part, on Defendant's prompt acceptance of personal responsibility
for the offense of conviction in this case, as reflected by his
agreement to the attached Agreed Factual Basis.
The U.S. Attorney specifically may, at his
sole option, be released from his commitments under this Agreement,
including, but not -limited to, his agreement that paragraph 4
constitutes the appropriate disposition of this case, if at any
time between his execution of this Agreement and sentencing, Defendant:
a) Fails to admit a complete factual basis
for the plea;
b) Fails to truthfully admit his conduct
in the
Offenses of conviction;
c ) Falsely denies, or frivolously contests,
relevant conduct for which Defendant is accountable under U.S.S.G.
§1B1.3;
d) Fails to provide truthful information
to the United States Probation Office about his financial status,
unless relieved of that obligation by the Court;
e) Gives false or misleading testimony in
any proceeding relating to the criminal conduct charged -in this
case and any relevant conduct for which Defendant is accountable
under U.S.S.G. § 1B1.3. U.S. Attorney will not seek testimony
from the Defendant between his execution of this Agreement and
sentencing;
f) Engages in acts which form a basis for
finding that Defendant has obstructed or impeded the administration
of justice under U.S.S.G. § 3C1.1;
g) Intentionally fails to appear in Court
or violates any condition of release; and/or
h) Commits a crime
The U.S. Attorney hereby agrees that Defendant's
agreement to the attached Agreed Factual Basis satisfies provisions
(a)-(c) above and that testimony adopting the Agreed Factual Basis
would satisfy (e) in the event Defendant were called to give testimony.
Defendant expressly understands that he may not withdraw his plea
of guilty, unless the Court rejects or modifies this Agreement
under Fed. R. Crim. P. 11(e)(4).
4. Agreed Disposition
The U.S. Attorney and Defendant agree pursuant
to Fed. R. Crim . P . 11 (e) (1) (C) that the following is the
appropriate disposition of this case:
a) A two year term of probation. The conditions
of pro ation shall be: the conditions and agreements set forth
in paragraph 5 below, which shall be imposed as special conditions
of probation subject to the provisions of paragraphs 5 and 11(C),
below; the mandatory conditions set forth in 18 U.S.C. §
3563 (a) (1) and (3); and the conditions of
probation set forth in 18 U.S.C. 9 3563 (b)
(8) , (b) (15) , (b) (17) , and (b) (18) The United States Attorney
and Defendant agree that the conditions set forth in 18 U.S.C.
§ 3563(b)(2) will be satisfied on the date of the guilty
plea and that therefore 18 U.S.C. § 3563(a) (2) is satisfied.
The U.S. Attorney and Defendant agree that the reporting requirements
set forth at 18 U.S.C. § 3563(b)(15) and (b) (1-7) should
reflect that Defendant does not reside in this judicial district
and may choose, inter alia, to retire or become self-employed.
b) A fine of $10,000.
c) Restitution of the tax loss of $99,646.79
to the State of Rhode Island and the Town of Barrington, Rhode
Island.
d) $100 special assessment.
The appropriate disposition of this case
includes no home confinement, intermittent confinement, or incarceration,
and no restitution, forfeitures, fines or other sentence or conditions
of probation except as expressly set forth in this Agreement.
The U.S- Attorney and Defendant agree that there is no basis for
departure from the sentencing range established by the United
States Sentencing Guidelines, except as explicitly described in
paragraph 3, above. The U.S. Attorney and the Defendant further
agree that the Defendant shall pay the fine, restitution, and
special assessment set forth in this paragraph on the day of pleading
guilty. in the event the Court rejects this agreement pursuant
to Fed. R. Crim. P. 11(e)(4) and the Defendant withdraws his plea
of guilty, these funds shall be returned to the Defendant.
5. Agreement Concerning Future Union
Activities
a) on January 1, 2000, the Defendant retired
as General President from the Laborer's International Union of
North America ("LIUNA") and became the General President
Emeritus, an honorary position that involves no service as a consultant
or adviser (as those terms are used and defined for purposes of
29 U.S.C. § 504) to LIUNA or any of its affiliated or subordinate
entities, and which involves no decisionmaking authority concerning
or over, or control over LIUNA or any of its affiliated or subordinate
entities. For purposes
of this Agreement, the term " affiliated
or subordinate entities" includes any labor organization,
employee benefit plan, labormanagement cooperation committee,
or trust established or maintained by LIUNA or any of its subordinate
labor organizations.
b) The U.S. Attorney and the Defendant hereby
agree that, as a result of his guilty plea, and as a condition
of his probation (in accord with paragraph 11(C), below), the
Defendant will remain retired from LIUNA as General President
Emeritus pursuant to the terms of compensation on the date of
his retirement and will be barred, whether within or outside LIUNA,
from any service as a consultant or adviser (as those terms are
used and defined for purposes of 29 U.S.C. § 504) to LIUNA
or any of its affiliated or subordinate entities, or in any capacity
from any decisionmaking authority concerning or over, or control
over LIUNA or any of its affiliated or subordinate entities. In
addition, the U.S. Attorney and the Defendant hereby agree that,
as a result of his guilty plea and as a condition of his probation
(in accord with paragraph 11(C), below), the Defendant will not
accept any compensation increases from LIUNA above the level of
the current constitutionally-mandated salary of the General President.
c) The U.S. Attorney and the Defendant hereby
agree that the Defendant, as a result of his guilty plea and as
a condition of his probation (in accord with paragraph 11(C),
below) shall be disqualified by operation of law from serving
in any of the capacities described in 29 U.S.C. § 1111 for
the period specified in that statute, unless the sentencing court
sets a lesser period pursuant to U.S.C. § 1111 (a) . The
U.S. Attorney and the Defendant agree that pursuant to the definition
of " consultant" set forth in 29 U.S.C. § 1111(c)
(2), the Defendant is not precluded from working for an entity
that provides goods or services (including, but not limited to,
consultation, advice, or other assistance) to an employee benefit
plan so long as he is not personally involved in the provision
of such consultation, advice, or other assistanceThe U.S. Attorney
and the Defendant further agree that to the extent it is necessary,
the U.S.
Attorney will join in a motion pursuant to
29 U.S.C. 9 1111(a)(B) to give effect to this understanding.
d) The United States Attorney and the Defendant
hereby agree that, consistent with subparagraphs 5(a) and 5(b),
above, the Defendant, as a result of his guilty plea and as a
condition of his probation (in accord with paragraph ll (C), below),
shall be disqualified from serving: (a) as a consultant or adviser,
as those terms are used in 29 U.S.C. § 504 (a) (1) , to LIUNA
or any of its af f iliated or subordinate entities; (b) as an
officer, director, trustee, member of any executive board or similar
governing body, business agent, manager, organizer, employee,
or representative, as those terms are used in 29 U.S.C. §
504 (a) (2), of LIUNA or any of its affiliated or subordinate
entities; and (c) in any capacity that involves decisionmaking
authority concerning, or decisioranaking authority over, or custody
of, or control of the moneys, funds, assets, or property of LIUNA
or any of its affiliate or subordinate entities, as those terms
are used in 29 U.S.C. § 504(a)(5)
e) The United States Attorney and the Defendant
hereby agree that, consistent with subparagraphs 5(a) and 5(b),
above, the Defendant will also be barred personally from serving
for a period of five years as an employee of any other labor organization,
including as an officer, director, trustee, member of any executive
board or similar governing body, business agent, manager, or organizer,
as those terms are used in 29 U.S.C. § 504(a)(2).
f) Nothing in this agreement shall be construed
to preclude the Defendant from serving: (a) as a consultant or
adviser, as those terms are used in 29 U.S.C. § 504 (a) (1)
, to labor organizations other than LIUNA or any of LIUNA's affiliated
or subordinate entities; (b) as a labor relations consultant or
adviser to a person engaged in industry or activity affecting
commerce, or as an officer, director, agent, or employee of any
group or association of employers dealing with any labor organization,
or in a position having specific collective bargaining authority
or direct responsibility in the areas of labor-management
relations in any corporation or association
engaged in an industry or activity affecting commerce, as those
terms are used in 29 U.S.C. § 504 (a) (3), except that in
such capacities, the Defendant shall not personally serve as a
consultant, adviser, or labor relations consultant (as those terms
are used and defined for purposes of 29 U.S.C. § 504) to
LIUNA or any of its affiliated or subordinate entities. Further,
in any of the capacities listed in this paragraph, the Defendant
may not receive any compensation that is calculated based, on
proceeds or profits from any dealings with LIUNA or any of its
affiliated or subordinate entities.
g) The provisions of subparagraphs 5(a),
(b), (d), (e) and (f) above shall be imposed consistent with paragraph
11(c), below, and in lieu of any other bar under 29 U.S.C. §
504, if any.
6. Waiver of Rights to Appeal and
to Bring Collateral Challenge
Defendant is aware that he has the right
to challenge his sentence and guilty plea on direct appeal. Defendant
is also aware that he may, in some circumstances, be able to argue
that his plea should be set aside, or his sentence set aside or
reduced, in a collateral challenge such as pursuant to a motion
under 28 U.S.C. § 2255.
In consideration of the concessions made
by the U.S. Attorney in this Agreement, Defendant knowingly and
voluntarily waives his right to appeal or collaterally challenge:
(1) Defendant's guilty plea and any other
aspect of Defendant's conviction, including, but not limited to,
any ruling on pretrial suppression motions or any other pretrial
dispositions of motions and issues; and
(2) The imposition by the District Court
of the sentence agreed to by the parties, as set out in paragraph
4, even if the Court rejects one or more positions advocated by
the parties with regard to the application of the U.S. Sentencing
Guidelines
Plea-Tendered Pursuant to Fed. R. Crim
P. 11 (e) (1) (C) and 11 (e) (4)
The sentencing disposition agreed upon by
the parties and
their respective calculations under the Sentencing
Guidelines are not binding upon the United States Probation Office.
Defendant's plea will be tendered pursuant to Fed. R. Crim. P.
11 (e) (1) (C) and 11 (e) (4). Defendant cannot withdraw his plea
of guilty unless the sentencing judge rejects or modifies this
Agreement. I f the sentencing judge rejects or modifies this Agreement,
or in the event the U.S. Attorney withdraws from this Agreement
pursuant to paragraph 3 of this Agreement, this Agreement shall
become null and void and none of its terms and conditions will
be binding on either party. The U.S. Attorney agrees that in the
event the Court rejects this Agreement and the Defendant withdraws
his plea of guilty, or in the event the U.S. Attorney withdraws
from this Agreement pursuant to paragraph 3 of this Agreement,
no writings, agreements, Agreed Factual Basis, admissions, or
other statements made by either party or their counsel during
or following these plea negotiations shall be admissible for any
pu . rpose at any proceeding.
8. Civil Liability
By entering into this Agreement, the U.S.
Attorney does not compromise any civil, maritime, or administrative
liability, if any, which Defendant may have incurred or may incur
as a result of his conduct and his plea of guilty to the charge
specified in paragraph I of this Agreement.
9. Withdrawal of Plea By Defendant
Other than as provided in paragraph 7 above,
should Defendant move to withdraw his guilty plea at any time,
this Agreement shall be null and void at the option of the U.S.
Attorney.
10. Expedited Sentencing Date
The U.S. Attorney and the Defendant agree
to seek sentencing today, if the %Court is available and willing,
and it not, to seek an expedited sentencing date from the Court.
11. Breach of Agreement
(A) If the U.S. Attorney determines that
Defendant has failed to comply with any provision of this Agreement,
has violated any condition of his pretrial release, or has committed
any crime following his execution of this Agreement through the
termination of his period-of probation, the U.S. Attorney may,
at his sole option, be released from his commitments under this
Agreement in their entirety by notifying Defendant, through counsel
or otherwise, in writing. The U.S. Attorney and the Department
of
Justice may also pursue all remedies available
to them under the law, irrespective of whether the U.S. Attorney
elects to be released from his commitments under this Agreement.
Further, the U.S. Attorney and the Department of Justice may pursue
any and all charges which have been, or are to be, dismissed or
not initiated pursuant to this Agreement. Defendant recognizes
that no such breach by him of an obligation under this Agreement
shall give rise to grounds for withdrawal of his guilty plea-
Defendant understands that, should he breach any provision of
this Agreement through the termination of his period of probation,
the U.S. Attorney will have the right to use against Defendant
before any grand jury, at any trial or hearing, or for sentencing
purposes, any statements which may be made by him subsequent to
this agreement, and any information, materials, documents or objects
which may be provided by him to the government subsequent to this
Agreement, without any limitation. In this regard, Defendant hereby
waives any defense to any charges which he might otherwise have
under any statute of limitations or the Speedy Trial Act, not
to include any such defenses that he had at the time of the signing
of this Agreement.
(B) For purposes of paragraph 11 (A) above,
other than with respect to a violation of paragraph 5 of this
Agreement (which is covered in paragraph 11 (C) , below) , the
U. S . Attorney and Def endant agree that, following sentencing,
unless Defendant commits a crime following his execution of this
agreement through the term of his probation, Defendant has complied
with all provisions and conditions referred to in paragraph 11(A).
(C) The U.S. Attorney and Defendant agree
that if, at any time following sentencing and prior to the end
of his term of probation, the Court determines that Defendant
has committed a material breach of paragraph 5 of this Agreement,
the Court may find a violation of probation and shall have the
authority to enter an appropriate order, including, but not limited
to, the payment by the Defendant to the United States of any proceeds
or profits derived from this breach, and in addition, any other
appropriate f ine. If, following the term of probation, the Court
determines that Defendant has committed a material breach of paragraph
5 of this Agreement, the Court may find the Defendant in contempt
of an order of the Court and shall have the authority to enter
an appropriate order, including, but not limited to, the payment
by the Defendant to the United States of any proceeds or profits
derived from this breach, and in addition, any other appropriate
fine. Nothing in this paragraph is intended to limit the statutory
authority of the Court set forth in 18 U.S.C. § 3565 or any
other applicable statute to punish material breaches of paragraph
5.
12. Who is Bound By Agreement
In the event the Court accepts this Agreement
and the Defendant is sentenced pursuant to this Agreement, the
U.S. Attorney agrees that he will not prosecute the Defendant
for any act, conduct, transaction, or offense, if any, that is
known by the Organized Crime and Racketeering Section of the Department
of Justice or the U.S. Attorney on the date of the signing of
this Agreement. The U.S. Attorney also will not prosecute any
member of Defendant's immediate family for any act, conduct, transaction,
or offense, if any, related to the conduct alleged in the attached
Information, or related to any conduct involving personal vehicles
that occurred prior to the date of the signing of this Agreement.
In addition, as evidenced by Attachment A hereto, the Deputy Assistant
Attorney General of the Criminal Division of the Department of
Justice agrees that the United States will not prosecute the Defendant
for any act, conduct, transaction, or offense, if any, that is
known by the Organized Crime and Racketeering Section of the Department
of Justice or the U.S. Attorney on the date of the signing of
this Agreement. As is also evidenced by Attachment A hereto, the
Deputy Assistant Attorney General of the Criminal Division of
the Department of Justice agrees that the United States will not
prosecute any member of Defendant's immediate family for any act,
conduct, transaction, or offense, it any, related to the conduct
alleged in the attached Information, or related to any conduct
involving personal vehicles that occurred prior to the date of
the signing of this Agreement. This Agreement is otherwise limited
to the U.S. Attorney for the District of Massachusetts, and cannot
and does not otherwise bind the Attorney General of the United
States or any other federal, state or local prosecutive authorities.
This paragraph shall not preclude prosecution for an act involving
murder or other crime of violence.
13. No Waiver of Attorney-Client
Privilege
The parties agree that neither Defendant's
signing of the Acknowledgment nor any other part of this agreement
shall be construed as a waiver of Defendant's attorney-client
privilege or the work-product doctrine.
14. Complete Agreement
This letter contains the complete and only
agreement between the parties relating to the disposition of this
case. No promises, representations or agreements have been made
other than those set forth in this letter. This Agreement supersedes
prior understandings, if any, of the parties, whether written
or oral.
This Agreement can be modified or supplemented
only in a written memorandum signed by the parties or on the record
in court
If this letter accurately reflects the Agreement
between the U.S. Attorney and Defendant, please have Defendant
sign the Acknowledgment of Agreement below. Please also sign below
as witness. Return the original of this letter to Assistant U.S.
Attorneys Alex Whiting and Ernest S. DiNisco.
Very truly yours,
DONALD K. STERN
United States Attorney
By: s/JAMES B. FARMER
JAMES B. FARMER
Assistant U.S. Attorney
Chief,
Criminal Division
STEPHEN P. HEYMANN
Assistant U.S. Attorney
Deputy Chief,
Criminal Division
ALEX WHITING
ERNEST S. DINISCO
Assistant U. S. Attorneys
I have read this letter in its entirety and
discussed it with my attorney. I hereby acknowledge that it fully
sets forth my agreement with the United States Attorney's office
for the District of Massachusetts. I further state that no additional
promises or representations have been made to me by any official
of the United States in connection with this matter. I understand
the crime to which I have agreed to plead guilty, the maximum
penalties for the offense and Sentencing Guideline penalties potentially
applicable to it. I am satisfied with the legal representation
provided to me by my attorney, We have had suf f icient time to
meet and discuss my case- We have discussed the charge against
me, possible defenses I might have, the terms of this Plea Agreement
and whether I should go to trial. I am entering into this Agreement
freely, voluntarily, and knowingly because I am guilty of the
offense to which I am pleading guilty and I believe this Agreement
is in my best interest.
s/ARTHUR A. COIA
ARTHUR A. COIA
Defendant
Date : 1-27-00
I certify that Arthur A. Coia has read this
Agreement and that we have discussed its meaning. I believe he
understands the Agreement and is entering into the Agreement voluntarily
and knowingly.
Brendan V. Sullivan, Jr
Howard W. Gutman
Attorneys for Defendant
Date: 1-27-00
From in or about June, 1991, through in or
about September, 1997, in the District of Rhode Island, the District
of Massachusetts, and elsewhere, the defendant, ARTHUR A. COIA,
whose permanent abode was in Barrington, Rhode Island, knowingly
defrauded the State of Rhode Island and the Town of Barrington
of certain automobile tax revenues by engaging in the following
course of conduct:
1. On or about July 30, 1991, the defendant,
ARTHUR A. COIA, purchased a 1991 Ferrari F-40 ("the F-40"),
vehicle identification number ZFFMN34A6MOO89653, from Autohaus,
a Ferrari dealership located in Cohasset, Massachusetts, for $450,000
in the name of Viking, (A close personal friend of Coia's for
at least 40 years was the President and owner of a group of automobile
businesses and dealerships that operated under the name Viking,
and had businesses located inter alia, in Middletown and East
Providence, Rhode Island.) In or about March, 1993, the defendant,
ARTHUR A. COIA, purchased the F-40 from Viking for $275, 000,
and obtained financing through Viking from the Chase Manhattan
Bank, Viking collected no use tax on this transaction, and the
defendant, ARTHUR A, COIA, paid no use tax to the State of Rhode
Island in connection with his use and storage of the F-40. The
use tax due and owing to the State of Rhode Island for this transaction
was 7% of $275,000, or $19,250.
2. On or about February 28, 1990, the defendant,
ARTHUR A.
COIA, purchased a 1972 Ferrari Daytona ("'the
Daytona"), vehicle identification number 16549, from Shelton
Sports Cars in Fort Lauderdale, Florida, for $1,050,000. On or
about August 18, 1993, the defendant, ARTHUR A. COIA, caused the
Daytona to be fraudulently registered to Viking's address on East
Main Road in Middletown, in order to evade paying the higher excise
tax rate in Barrington. As COIA continued to reside in Barrington
and the Daytona was not garaged in Middletown, the local excise
tax on the vehicle was due to Barrington. However, the fraudulent
registration of the vehicle in Middletown caused it to be taxed
at the lower rate in Middletown, rather than in Barrington. In
or about February or March, 1994, COIA renewed the registration
on the Daytona, again at Viking's address on East Main Road in
Middletown. Accordingly, the Daytona continued to be taxed by
Middletown, rather than by Barrington, through the 1996 tax year.
In total, the defendant, ARTHUR A. COIA, defrauded the Town of
Barrington of $57,865.01 in taxes in connection with his ownership
of the Daytona.
3. In or about August, 1993, the defendant,
ARTHUR A. COIA, purchased a 1973 Ferrari 365 GTB4 ("the 365
GTB"), vehicle identification number 365GTB416943, from Ferrari
of Los Gatos in Los Gatos, California, for $215,000. On or about
September 10, 1993, the defendant, ARTHUR A. COIA, used a fraudulent
invoice from Viking Pontiac for $2,160 to register the vehicle
without paying
the full use tax of $15,050 due to the state
of Rhode Island. COIA was able to register the vehicle in Rhode
Island while paying a use tax of only seven percent of $2,160,
or $151.20.
4. The defendant, ARTHUR A. COIA, also caused
the 365 GTB to be fraudulently registered to Viking's address
on East Main Road in Middletown, again in order to evade paying
the higher excise tax rate in Barrington- As COIA continued to
reside in Barrington and the 365 GTB was not garaged in Middletown,
the local excise tax on the vehicle was due to Barrington. However,
the fraudulent registration of the vehicle in Middletown caused
it to be taxed at the lower rate in Middletown, rather than in
Barrington. In or about February, 1994, COIA renewed the registration
on the 365 GTB, again at Viking's address on East Main Road in
Middletown. Accordingly, the 365 GTB continued to be taxed by
Middletown, rather than by Barrington, through the 1994 tax year,
after which the vehicle's registration was changed back to the
COIA's Barrington address and taxes were thereafter paid to Barrington.
In total, the defendant, ARTHUR A. COIA, defrauded the Town of
Barrington of $7,632.98 in taxes in connection with his ownership
of the 365 GTB.
5. In or about August, 1995, the defendant,
ARTHUR A. COIA, for the purpose of defrauding the state and local
taxing authorities of tax revenues owed on certain automobiles,
did knowingly and willfully cause a Lax bill from the Town of
Barrington for the tax year 1994 to be sent
to COIA's residence in Barrington by the Postal Service by mail.
DONALD K. STERN
United States Attorney
By:
s/JAMES B. FARMER
JAMES B. FARMER
Assistant U.S. Attorney
Chief,
Criminal Division
STEPHEN P. HEYMANN
Assistant U.S. Attorney
Deputy Chief,
Criminal Division
ALEX WHITING
ERNEST S. DiNISCO
Assistant U. S. Attorneys
s/ARTHUR A. COIA
ARTHUR A. COIA
Defendant
Date: 1-27-00
s/Brendan V. Sullivan Jr.
Brendan V. Sullivan, Jr.
Howard W. Gutman
Attorneys for Defendant
Date: 1-27-00