Kenneth A. Weiner - Page 4

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               the financial activities of the investment scheme as                   
               required by law. * * *                                                 
               *    *       *      *         *       *      *                         

                    7.  The unlawful combination, conspiracy,                         
               confederation, and agreement was to be accomplished by                 
               the following means and methods:                                       
                         a.  The petitioner * * * used numerous                       
                    bank accounts, maintained in various names,                       
                    including COMSEC Corporation * * * to conduct                     
                    the financial activities of the investment                        
                    scheme, for the purpose of concealing the                         
                    financial activities of the investment                            
                    scheme.                                                           
                         b.  The petitioner * * * conducted much                      
                    of the business of the investment scheme in                       
                    currency and cashier's check, for the purpose                     
                    of hindering and preventing the tracing of                        
                    the financial activities of the investment                        
                    scheme.                                                           
                         c.  The petitioner * * * failed to                           
                    maintain accurate books and records of the                        
                    financial activities of the investment scheme                     
                    as required by law * * *.                                         
               *    *       *      *         *       *      *                         

                    8.  In furtherance of the conspiracy and to                       
               effect the objects thereof, the following acts were                    
               done and performed by or on behalf of the petitioner                   
               * * *:                                                                 
                         a.  On or about May 17, 1982, the                            
                    petitioner caused the incorporation of COMSEC                     
                    Corporation under Michigan law.                                   
                         b.  On or about April 18, 1993, the                          
                    petitioner * * * opened a savings account                         
                    * * * at the American Federal Savings and Loan,                   
                    Detroit, Michigan.                                                






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