DHL Corporation and Subsidiaries - Page 54

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          Robinson, 9.27 percent.  The remaining 22.39 percent of DHL’s               
          outstanding stock was owned by others--one of them owning 9.27              
          percent, and the remainder each owning less than 5 percent.                 
          Cheiro was a Hong Kong corporation, the stock of which was held             
          50 percent by Allen and 50 percent by Po Chung, from 1977 through           
          September 1981.  After that time, Cheiro stock was held by Allen            
          or for his benefit through various entities.                                
               As of the time of the transactions in question, DHLI’s stock           
          was held through Mattawan Ltd. (Mattawan), a Hong Kong                      
          corporation, which served as an intermediate entity.  It was                
          owned 49 percent each by Po Chung and Hillblom, and the remaining           
          2 percent was held by the Mattawan Employees Trust.  MNV’s stock            
          was held 49 percent by Robinson and 51 percent by Allen through             
          several intermediate entities.  From the relatively early                   
          foundations of DHL, DHLI, and MNV, through the time when the                
          foreign investors became involved in the DHL network, Hillblom,             
          Po Chung, Allen, and Robinson, collectively and functionally,               
          were the controlling shareholders of the DHL network entities and           
          the DHL network.  Amongst the four controlling shareholders,                
          Hillblom was the most influential.                                          
               In the mid-1970’s Donnici introduced Allen to Stephen J.               
          Schwartz (Schwartz), a tax attorney, who began representing some            
          of the DHL shareholders and their related entities.  Schwartz’              
          focus was on the minimization of tax, which, among other methods,           

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