Jerry Lee Harvey - Page 12




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               The Government did eventually obtain petitioner's Cayman                
          Islands records, but not through grand jury subpoenas.  The                  
          records were obtained from the Cayman Islands Government pursuant            
          to the Agreement Concerning Obtaining Evidence From Cayman                   
          Islands With Regard to Narcotics Activities, Aug. 29, 1984, U.S.-            
          U.K., 24 I.L.M. 1110 (as extended).  The records were received by            
          Stephen Snyder (Snyder), an attorney in the Tax Division of the              
          Department of Justice.  Snyder's office was located in                       
          Washington, D.C.; however, some of the responsibilities of his               
          position entailed investigations in the Southern District of                 
          Florida.                                                                     
               Immediately after Snyder received the records, he called                
          Young and had him fly to Washington, D.C., to pick them up.                  
          Young, as agent of the grand jury, accepted the records on behalf            
          of the grand jury in the Southern District of Florida.  Young                
          brought the records back to Florida with him and kept them in a              
          locked security cabinet in his office in Fort Lauderdale.                    
          Thereafter, Young physically presented the records to the grand              
          jury with a discussion and analysis.                                         
               Using in part the Cayman Islands records, the grand jury in             
          the Southern District of Florida indicted petitioner in 1985 for             
          criminal tax violations for the years 1978 through 1982.                     
          Petitioner filed a motion to dismiss the indictment as a                     







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