Sam F. and Ingrid D. Ford - Page 3

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               In conjunction with his guilty plea, petitioner entered into           
          a cooperation agreement concerning other prosecutions.                      
          Thereafter, during March and April of 1992, the District Court              
          conducted a 9-day "Fatico" hearing in petitioner's criminal case.           
          A Fatico hearing is a proceeding held before the sentencing of a            
          convicted criminal at which the prosecution and the defense may             
          introduce evidence relating to the appropriate sentence.1  The              
          principal issues addressed during petitioner's Fatico hearing               
          were whether petitioner had breached his cooperation agreement              
          and whether petitioner was truthful about his interest in or                
          control over certain foreign corporations and bank accounts.                
               Assistant U.S. Attorney Andrew E. Tomback (AUSA Tomback)               
          represented the United States at the Fatico hearing.  His first             
          witness was Corporal Gregory James Pattison (Corporal Pattison)             
          of the Royal Canadian Mounted Police.  Corporal Pattison's duties           
          included his being assigned, during September of 1986, to an                
          investigation into the trading of shares in a company called                
          International Tillex.  His conduct of that investigation led to             
          an examination of trading in shares of a company known as Beverly           
          Development.  Corporal Pattison testified that petitioner, using            
          his own name or that of family members, had traded shares in both           
          International Tillex and Beverly Development through seven                  

               1See United States v. Lohan, 945 F.2d 1214, 1216 (2d Cir.              
          1991) (citing United States v. Fatico, 603 F.2d 1053 (2d Cir.               

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