Jack J. Kramer - Page 6

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            released from prison in 1981.  After this initial episode,                                    
            petitioner maintained a social and business relationship with Sam                             
            Gilbert.                                                                                      
                  By November 1983, petitioner had become deeply involved in                              
            laundering Ben's marijuana smuggling profits.  He met with Sam                                
            Gilbert in a Beverly Hills hotel to discuss a plan to launder $12                             
            million in drug smuggling profits5 through a British Virgin                                   
            Islands (BVI) entity, to a bank in Liechtenstein.  This bank                                  
            turned the funds into a seemingly legitimate "construction loan"                              
            so that Ben, through various entities, was able to invest the                                 
            proceeds in the Bell Gardens Bicycle Club, Inc. (the card club),                              
            a legal, State regulated gambling enterprise, without revealing                               
            his participation.  Another BVI entity, Troon Mortgage                                        
            Investments, N.V. (Troon Mortgage), run by Shaun (or Shawn)                                   
            Murphy (Murphy), subsequently held the note as a vehicle through                              
            which Ben could recover the $12 million principal, 15 percent                                 
            interest on the loan, and an additional 15-percent "kicker".                                  
                  Ben and Sam Gilbert, along with M. Dale Lyon (Lyon) and                                 
            Michael Gilbert, the "front men" used to obtain the gambling                                  
            license for the card club, later formed the entities used to                                  
            conceal Ben's supposed ownership role in the card club.  Sam                                  

            5Ben's share of these funds was $4 million.  The other $8                                     
            million came from his partners in the drug smuggling enterprise,                              
            Randy Lanier and "Tommy", also known as George Brock.  By his own                             
            testimony, petitioner was to control the laundering of these                                  
            funds.  Petitioner and Ben met Tommy in New York in Sept. 1983 to                             
            convince Tommy to invest in the Bell Gardens Bicycle Club, Inc.,                              
            discussed infra.                                                                              



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