Steven K. Han - Page 40





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          the Kodak stock, from petitioner’s personal P-B No. 1 account               
          into ANB No. 1.                                                             
               Notwithstanding the granting of the TRO, Northwest remained            
          frustrated in its efforts to obtain information from petitioner             
          regarding bank and brokerage accounts into which ticket sales               
          proceeds had been transferred.  On July 1, 1988, Hasman wrote               
          Belofsky advising him of petitioner’s refusal to provide                    
          financial documents and Hasman’s opinion that such conduct                  
          violated the TRO, and urging Belofsky to counsel petitioner on              
          the need to comply with the TRO so as to “resolve the growing               
          need for court supervision of your client’s conduct”.  More                 
          specifically, Hasman wrote:                                                 
                    I was advised yesterday that our [Northwest’s]                    
               auditors’ review of the sparse documents which Mr. Han                 
               and Mr. Chung have made available disclosed six                        
               brokerage accounts, about which Northwest had no prior                 
               knowledge because of Mr. Han’s prior refusal to                        
               disclose those accounts, or documentation which would                  
               lead to disclosure of those accounts.  This appears to                 
               be a pattern that your client has been following,                      
               namely, withholding information and documentation which                
               would lead to the disclosure of relevant financial and                 
               other information necessary to conduct the ongoing                     
               audit.  We believe that the withholding of                             
               documentation which would lead to disclosure of                        
               accounts in which Mr. Han and his companies have                       
               transferred funds has been and continues to be                         
               intentional and in violation of the requirement * * *                  
               of the TRO, which requires the defendants to allow my                  
               client “immediate access” to books, records and                        
               documents.                                                             








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