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My suggestion to Gilbert was to go ahead with you and
draft the Affidavits, at least yours and mine and we
(you, Gilbert and me) would review the Affidavits
before sitting down with McWade and Myron Chang. The
conversation with McWade ended with him saying he would
get back to Gilbert after another meeting with Chang,
however, we should go ahead with drafting the
Affidavits.
Chuck, as Gilbert may have told you, this means blowing
the whistle on 1400 of you know who's [sic] clients, 10
or 12 of which are Gilbert's clients. As you and I
discussed, when the Nazi knows that 1400 of his
client's [sic] are going to be clobbered and that he
will have the Criminal Investigation Division of the
IRS coming down on him I think he will be inclined to
pay me my money.
In the weeks that followed, Messrs. Alexander and Kozak prepared
draft affidavits for submission to Mr. McWade.
On August 12, 1986, Mr. Alexander sent copies of his draft
affidavit to Messrs. Matsumoto and Kozak by overnight mail. On
August 15, 1986, Messrs. Alexander, Matsumoto, and Kozak held a
conference call regarding the affidavits. In a letter to Messrs.
Kozak and Matsumoto dated August 16, 1986, Mr. Alexander stated
as follows:
Dear Chuck & Gilbert:
Following our conference call of yesterday, August
15th, I am submitting the following for both of your
considerations:
1. I suggest that we submit to the IRS AFFIDAVITS in
DRAFT FORM ONLY.
2. It is against my better judgment to submit executed
and notarized affidavits without having some idea what
the IRS will do and what they will pay.
3. They can make their determination (s) and eat up 30
days based on drafts or I should say final drafts. We
can agree verbally to execute the final drafts when
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