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premises to be searched (the premises). Attachment B to the
application states Mr. Goolkasian’s belief that, on the premises,
there are concealed various business records of AMCOR, “for the
years 1982 through 1988, inclusive, and relating to the following
partnerships and corporations: [a list of 192 entities, not
including the partnership]”. The application states that the
items to be seized are “the fruits, instrumentalities, and
evidence of conspiracy to commit tax evasion, in violation of
18 U.S.C. � 371 and 26 U.S.C. � 7201, and aiding or assisting in
the preparation of false or fraudulent tax returns, in violation
of 26 U.S.C. � 7206(2).” Mr. Goolkasian’s affidavit is attached
to, and made part of, the application. Attached to it are lists
of entities that had farming agreements with AMCOR. The
partnership’s name appears on one of those lists. Items were
seized pursuant to the warrant, and an employee of respondent’s
prepared a detailed inventory of those items.
On March 27, 1989, Mr. Davies recorded a telephone call
among himself, Mr. Frame, and Bruce Hochman, a criminal defense
attorney retained by Mr. Frame. He did so without authorization
or permission from Mr. Goolkasian. Mr. Goolkasian reviewed the
record of that conversation. On March 28, 1989, Mr. Davies was
instructed not to record any more conversations with Mr. Hochman.
Mr. Goolkasian informed Mr. Hochman that the conversation of
March 27, 1989, had been recorded.
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