J.J. Zand - Page 228

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               With regard to Interrep and its relation to petitioner, an             
          Ashland report to the Board of Directors dated June 26, 1975, in            
          connection with an investigation of Ashland's political                     
          contributions, describes certain interactions between Ashland and           
          Interrep but contains no reference to petitioner personally.                
          There are only two documents in evidence that draw any link                 
          between petitioner and Interrep.  The first document states that            
          the $100,000 paid by Ashland to Interrep constituted "Prepayment            
          of part of anticipated fees payable in respect to New York                  
          Venture".  This document further states that there were four                
          additional payments, as follows:                                            
               Payee          Date           Amount         Purpose                   
               J. J. Zand     6-6-73         $12,500        Fees related to           
                                                            Iranian                   
                                                            participation             
                                                            project                   
               J. J. Zand     7-9-73         3,000          O. E. Atkins              
                                                            check for                 
                                                            riyals Zand               
                                                            advanced to               
                                                            Atkins in                 
                                                            Teheran                   
               J. J. Zand     7-11-73        400            Gifts for                 
                                                            NIOC                      
               J. J. Zand     11-29-73       5,000          Reimburse for             
                                                            Teheran hotel             
                                                            bills, dinner             
                                                            party and                 
                                                            entertainment             
                                                            of Ambd. & Dr.            
                                                            Fallah                    






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