UNITED STATES OF AMERICA V. ARIF DURRANI MOVANT'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS

• Document Type: FOIA
• Keywords: IRAN CONTRA
• Keywords: SCANDAL
• Collection: FOIA Collection
• Document Number (FOIA) /ESDN (CREST): 0001474393
• Release Decision: RIFPUB
• Original Classification: U
• Document Page Count: 9
• Document Creation Date: June 22, 2015
• Document Release Date: January 10, 2008
• Case Number: F-2000-02383
• Publication Date: June 12, 1991

JUN 25 91 15:02 FROM US ATTORNEYS OFF BFT
IA
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA
VS.
CIVIL B-90-090
CRIM.' B-86-59
(TFGD)
(TFGD)
ARIF DURRANI
JUNE 12 , 19 91
NOVANT'S FIRST RtQUEST
Fop. PRODUCTION OF DOCUMENTS
Pursuant to Rule 6(a), Rules Governing ? 2255 Proceedings in
the United States District Courts, and Fed. R. Civ. P. 26 et
seq., movant Arif Durrani hereby requests that the United States
produce the following documents within no more than thirty days
from the date leave is granted to serve these requests.
INSTRUC_TION AND DEFINI ION.:
i. These interrogatories shall be. deemed continuing, so as to
require supplemental answers if further information is obtained
between the time the answers are served and the time'of trial.
2. If no one employee or agent is competent to answer all
the interrogatories, the responses should be separately answered
under oath by as many agents of the plaintiff as are necessary.
3. As used herein, the term "document" means the original as
well as any copy regardless of origin or location. of any
typewritten, handwritten, printed or recorded material including,
APPROVED FOR RELEASE
DATE: NOV 2007
 FROM US ATTORNE''(S OFF EPT
iU~d' c?5 ' S 1 15: `3--z
but not limited, to any book, pamphlet, periodical, letter,
memorandum, telegram, report, record, study, handwritten note,
working paper, chart, paper, graph, index, tape, disc, data
sheet, data processing card, diary, calendar, business records,
address and telephone records, or any other written, recorded,
transcribed, punched, taped, filmed or graphic matter however
produced or,reproduced to which you have or have had access or
control.
4. As used herein, the term "identify" or "identification" with
reference to a document means to state the date, author (and if
different the signer or signers), the addressee, document (e.g.,
letter, memorandum, etc.) and its present or last known location and
the name and address of the person having custody or control of such
document. If any such document was, but is no longer in your
possession or subject to your control, state the disposition made of
it, the reason for such disposition and the date thereof, its present
location and the name and address of the person having custody or
control of such document, with sufficient particularity to request its
production.
5. As used herein, the term "you" means you, yourself, the
,our
person to whom these interrogatories are addressed or any of Y
agents, deputies, assignees, partner associates or any employees,
 JUN 25 'S1 15:03 FROM US ATTORNEYS OFF EFT
employers or organizations of which you are a member or an employee,
or any person acting on your behalf.
6. Without limitation, a document is deemed to be in your
"control" if you have the right to secure the document or a copy
thereof from another person or public or private entity having actual
possession thereof.
7. "Communicate" or "communication" means every manner or means
of disclosure, transfer, or exchange, and every disclosure, transfer
or exchange of information whether orally or by document or whether
face-to-face, by telephone, mail, personal delivery, or otherwise.
8. Use of the term "identify" with reference town individual
person, means to state his full name, present home address, present
position and business affiliation or employment. "Identify" as to a
communication means to state the date of the communication, the type
of communication, the place where such communication was made, the
identities of the maker(s) and the receiver(s) of the communication
and of each person present when it was made, and the subject matter
discussed.
9. The masculine shall include the neuter or feminine gender,
unless the context expressly indicates otherwise; the singular
includes the plural and vice versa; the present tense includes the
past tense and vice versa; and "or" shall be construed either
 conjunctively or disjunctively to bring within the scope of these
interrogatories any information which might otherwise be construed to
be outside their scope.
10. if any of the information requested in answer to the
interrogatories propounded herein is available in machine-readable
form (such as punch cards, paper or magnetic tapes, drums, discs, or
care storage) state the form in which it is available and describe the
type of computer or other machine required to read the records. If
the information requested is stored in a computer, indicate whether
there is an existing program which will print the records in the form
desired, or if no program exists, whether one could be written.
11. If you do not answer any interrogatory because of a claim of
privilege, set forth the privilege claimed, the facts upon which you
rely to support the claim of privilege, and identify all documents for
which such privilege is claimed.
1. Records of an entity called "Forways,'t including bank
statements and/or cancelled checks, marked as exhibit number
EN 0199-358 at Congressional hearings investigating the
involvement of officials of the United States Government with
selling KAWK.missile parts to Iran at any time prior to July 1,
1987.
 1UN 25 '91.15:74 FROM US ATTORNEYS OFF EPT
Records, including those in possession of or prepared by
the Federal Bureau of Investigation ("FBI") concerning visits or
meetings between citizens or representatives of the Islamic
Republic of Iran and United States citizens Lt. Col. Oliver
North, Richard Secord, Albert Hakim and/or George Cave, in
Washington, D.C., on or about July 9, 10 and ii, 1986, and/or
September 19, 20 and 21, 1986.
Records, including those in possession of the Central
intelligence Agency ("CIA") concerning meetings or discussions
between citizens or representatives of Iran and Albert Hakim
and/or George Cave in Frankfurt, West Germany on July 25, 1986;
in London on August 7, 1986; and in Madrid on August 10, 1986.
4. Records, including those in possession of t :e Deparr.:.a_nt
of Transportation, related in any. way to the entry of aircraft
into Dulles International Airport directly or indirectly. from
Istanbul, Turkey, on September 19, 1996.
5
 JUN,25 '51 15:05 FROM US ATTORNEYS OFF SPT PAGE.OOS
05- All documents in the possession of or available to the
United States Government, including the CIA, FBI and Customs
Service, concerning Manuel Pires, a resident of Lisbon, Portugal.
06-- Records relating to the entry of Manuel Pires into the
United States during June and/or July 1987, including records of
the Immigration and Naturalization Service ("INS") and/or the
Customs Service.
^^1 AT 1 records of a meetin
between L _ 1'o _ Al iver North
g
and an Iranian exile in the office of United. States Senator Jesse
Helms on June 27, 1986.
All-,records, including cargo manifests, of a shipment
from employees or agents of the United States government to Iran
through Madrid, on a carrier known as Race Aviation.
 FAGc . 1 C
JU.N:'E5 ' ? 1 15: 05 FROM IJ5 ATTORNEYS OFF BP T
All documents relating to or identifying the so-called
"Second Channel", including records of a briefing given by
Admiral Poindexter of the National Security Council ("NSC") to
Avram Nir on September 10, 1986.
10. All records of the sale of HAWK missile system parts
from Varian Associates to an entity called Merex, regardless of
its address.
11. All records, including court stipulations, concerning
the location or whereabouts of Lt. Col. Oliver North from
September 1, 1986 to October 15, 1986.
12. ALL reports of the office of the Inspector General or
other offices within the Department of the Army, from January 1,
1985 to December 31, 1987, concerning the sales of or the
termination of sales of HAWK missile system parts to the CIA.
 JUN 25 '91 15:06 FROM US P.kTORNEYS OFF BPT PRGE.011
THE MOVANT,
ARIF A. DURR34NI
By
350
Orange St.
P.
0. Box 606
New
Haven, CT
06503
W Liam M. Bloss
'TACOBS, GRUDBERG, BELT & DOW,
(203) 772-3100
His Attorney
8
 JUhd. c^. .5 ' S 1 15:06 FROM US ATTORNEYS OFF BPT P 'ac . W I
CERTIFTCATTON
I hereby certify that a copy of the Movant's First Request
for Production of Documents was mailed first class,' postage
prepaid to:
Holly Fitzsimmons
Assistant United States Attorney
915 Lafayette Blvd.
Bridgeport, CT 06604
eo
day of June, 1991.