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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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