Jack J. Kramer - Page 7

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            Gilbert's attorney, Stephen Fainsbert (Fainsbert), performed many                             
            of the legal services necessary to create and operate these                                   
            entities.6                                                                                    
                  During early 1984, petitioner participated in several                                   
            meetings that monitored the card club's financing and                                         
            construction.  He also used Forman's7 services and those of an                                
            attorney, Emerson Allsworth8 (Allsworth), to oversee his and                                  
            Ben's financial interests.  Both Allsworth and Forman, while not                              
            initially involved in the actual money laundering, became                                     
            increasingly aware of the nature of the activities underlying the                             
            card club's financing and Ben's actual ownership role.                                        


            6Petitioner, as discussed infra pp. 13-14, would later                                        
            testify at the criminal trial of Michael Gilbert and Fainsbert as                             
            a Government witness.  Many of the findings for this background                               
            story of petitioner's involvement in Ben's money laundering                                   
            activities are drawn from petitioner's testimony at this trial in                             
            1993 and his similar testimony at the civil forfeiture trial                                  
            adjunct to his own criminal trial in 1991.  Transcripts of                                    
            petitioner's testimony from those trials were made part of the                                
            record in the trial of the cases at hand.                                                     
            7In addition to signing petitioner's 1985 Form 1040 as                                        
            return preparer, Forman performed services for Ben's various                                  
            criminal enterprises, not the least of which was evaluating the                               
            investment decisions concerning the card club, in which Ben and                               
            his associates, with petitioner's assistance, invested $12                                    
            million.                                                                                      
            8Allsworth, petitioner's longtime friend, served as attorney                                  
            to Ben's criminal enterprises, for which he was well paid from                                
            petitioners' Safra Bank account (see infra pp. 16-17), especially                             
            in 1986.  Allsworth was listed as President of Hallandale                                     
            Residential Properties, Inc., the entity created to hold legal                                
            title to the house that served as Ben's personal residence.                                   
            Allsworth also was listed as the registered agent for the various                             
            entities associated with the racing boat enterprise described                                 
            infra.                                                                                        



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