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Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 1 of 19

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

)
WYE OAK TECHNOLOGY, INC. )
)
Plaintiff )
)
v. ) Civil No. 1:10-cv-1182 (RCL)
)
REPUBLIC OF IRAQ, et al., )
)
Defendants. )
)

DEFENDANTS’ S SECOND NOTICE OF SUPPLEMENTAL FILING


(RE: ECF ## 408 AND 430)

On June 12, 2019, Defendants, Republic of Iraq (“Iraq”) and the Ministry of Defense of

the Republic of Iraq (“MoD”) (collectively “Defendants”) gave notice of Defendants’ filing of

documents pertinent to Defendants’ [Corrected] Opposition to Plaintiff’s Motion for Sanctions

and For Adverse Inferences (ECF #408). See ECF # 430.

In ECF #430, Defendants advised the Court inter alia that: (1) as of June 12, 2019,

counsel for Defendants had received translations of the Iraq Integrity Commission Extradition

Office transmittal letter and the summaries of cases ## 20, 23-35 (English-language translations

bearing Bates ## IC17 and IC19-IC23); and (2) Defendants’ counsel will provide the Court with

translations of the remaining case summaries upon receipt of those translations.

Defendants counsel have received such translations and provided the translations to

Plaintiff’s counsel. By this Second Notice of Supplemental Filing, Defendants are providing to

the Court these translations. See Attachment 1 hereto (completed English-language translations

of all Iraqi Integrity Commission case summaries).


Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 2 of 19

By this Second Notice, Defendants’ counsel also advise the Court that counsel for the

parties are conferring with the object of arriving at an agreed arrangement for providing the

Court with a true and correct copy the Iraqi criminal statute (and English-language translation)

referenced in Case No. 20 as having been violated by former MoD officials Ziad Cattan, Bruska

Shaways and Dr. Sawsan Jassim. See ECF #430 at 21.

July 2, 2019 Respectfully submitted,

MILLS LAW GROUP LLP


By: /s/ Timothy B. Mills
Timothy B. Mills
D.C. Bar No. 425209
910 17th Street, N.W.
Washington, DC 20006
Telephone: (202) 457-8090
Fax: (202) 478-5081
TimothyBMills@aol.com
Lead Counsel for Defendant
Ministry of Defense of the Republic of Iraq

By: /s/ Jonathan R. Mook


Bernard J. DiMuro (D.C. Bar No. 393020)
Stacey Rose Harris (D.C. Bar No. 486358)
Jonathan R. Mook (D.C. Bar No. 929406)
DiMuroGinsberg, P.C.
1101 King Street, Suite 610
Alexandria, VA 22314
703-684-4333
703-548-3181 (Fax)
bdimuro@dimuro.com
sharris@dimuro.com
jmook@dimuro.com
Co-Lead Counsel for Defendants Republic
of Iraq and Ministry of Defense

2
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 3 of 19

CERTIFICATE OF SERVICE

I certify that on this, the 2nd day of July, 2019, I electronically filed the foregoing
pleading with the Clerk of Court using the ECF filing system, which will transmit a Notice of
Filing to the following ECF registrant counsel for the parties.

John H. Quinn Jr. Robert J. Pavich, Pro Hac Vice


Patrick M. Klemz John J. Pavich, Pro Hac Vice
Quinn, Racusin & Gazzola Chartered PAVICH LAW GROUP, P.C.
888 17th Street N.W., Suite 640 20 S. Clark Street
P.O. Box 65778 Suite 700
Washington , D.C. 20006-3325 Chicago, IL 6063
Telephone: (202) 842-9300 Telephone: (312) 782-8500
Facsimile: (202) 682-0148 Facsimile: (312) 853-2187
Email: jhq@qrglawfirm.com rpavich@pavichlawgroup.com
Email: pmk@qrglawfirm.com jpavich@pavichlawgroup.com
Counsel for Plaintiff Co-Counsel for Plaintiff
Charles Allen Foster Eric C. Rowe
Eric Bolog Whiteford Taylor & Preston LLP
Adrian Snead 1800 M Street, N.W.
Whiteford Taylor & Preston LLP Suite 450N
1800 M Street, N.W. Washington, D.C. 20036
Suite 450N (202) 659-6787
Washington, D.C. 20036 Fax: (202) 689-3164
Telephone: (202) 689-3153 Email: erowe@wtplaw.com
Facsimile: (202) 331-0573 Counsel for Plaintiff
Email: cafoster@wtplaw.com
Email: ebolog@wtplaw.com
Email: asnead@wtplaw.com
Counsel for Plaintiff

/s/ Timothy B. Mills

3
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 4 of 19

ATTACHMENT 1

English-Language English-Language Translations of Iraqi Integrity Commission

Summaries of Cases Involving former MoD Official Ziad Al-Cattan et al. (#1-80)

and former MoD Defense Minister Hazim Al-Shalan (#1-5)

4
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 5 of 19
Name Case number Summary of case
1 Ziyad Tariq 1566/CR3/2011 The fugitive Ziyad Tariq Al Qattan in his capacity as the Deputy Secretary-General at the Ministry of Defense and the General Director of Arming and
Abdallah Salih Equipment in 2005, in conjunction with the convict (Adil Abdallah Mohamed). He entered into the contract number (T64/2005) with the Lam’a Horizon
Company to equip the ministry with spare parts for planes at a total cost of one million six hundred and thirty-five thousand American Dollars contrary
Al Qattan to the controls and special instructions for contracting. An extra disbursement for the contract and for the benefit of the company with a total of
(243,482,886) two hundred and forty-three million and four hundred and eighty-two thousand and eight hundred and eighty-six Dinar caused deliberate
damage to the entity for which he was working. The evidence collected against him is: the statement of the legal representative for the Ministry of Defense,
the administrative investigation, and the criminal record of the defendants. He was convicted by the Al Rasafa Criminal Court, and he was sentenced in
absentia to six years in prison in case number (1566/CR3/2011 on 11/8/2011).
2 Ziyad Tariq 973/CR1/2007 The fugitive, in his capacity as Deputy Secretary-General at the Ministry of Defense and as a representative [of the government], entered into contract
Abdallah Salih number (T/42/2004 on 23/12/2004) with the Al Ain Commercial Trade and Contracting Company for equipping the Ministry of Defense with 200 tank
trucks, among which were 100 for fuel transportation and 100 for water transportation. 85 tank trucks for water and 98 tank trunks for fuel were received
Al Qattan contrary to the terms of the contract. Additionally, he entered into the contract contrary to the operational contexts for contract and bidding and outside
the scope of the authority granted to him to contract. The collected evidence is: the witness statement, the statement of the legal representative for the
Ministry of Defense, the administrative investigation, and the statement of the defendant. He was convicted by the Central Criminal Court / Karkh, and
he was sentenced in absentia to seven years in prison in case number 973/CR1/2007 on 5/9/2007.
3 Ziyad Tariq 974/CR2/2007 The fugitive (Ziyad Tariq Al Qattan) signed the contract between the Ministry of Defense and the Al Milad General Trade and Contracting Company for
Abdallah Salih the rehabilitation of the respective buildings at the base of the presidential regiment and equipping them with hardware, equipment, and machinery without
following the legal procedures and without presenting it to any authority from the Ministry of Defense. The collected evidence in the case are: the statement
Al Qattan of the legal representative for the Ministry of Defense and the administrative investigation. He was convicted by the Central Criminal Court / Karkh, and
was sentenced in absentia in case number (974/CR2/2007 on 12/8/2007).
4 Ziyad Tariq 977/CR2/2007 The fugitive Ziyad Tariq Abdallah was working as the Deputy Secretary-General at the Ministry of Defense when he signed the contract number (T25/205)
Abdallah Salih with the Zuhour Nourouz Company regarding providing services to Camp Tariq east of Fallujah without the approval of the Minister by referring,
advertising, presenting, or bidding. It came outside the financial power that the defendant was legally authorized and without informing the service of the
Al Qattan general legal advisor. His endorsement of the contract legally cited above is a given that the evidence is sufficient for the conviction of the defendant
under article 340. The court decided his conviction thereunder and identified a punishment according to it. The decision rendered an agreement in absentia
and can be appealed based on the provisions of article 182/1Procedures and was announced publicly on 12/1/2007. The collected evidence: the progress
of the investigation, the statements of the legal representative, and the administrative investigation. He was convicted by the Central Criminal Court /
Karkh [sic], and he was sentenced in absentia to seven years in prison in accordance with the provisions of article (340) PL in case number (977/CR2/2007)
on (12/8/2007).
5 Ziyad Tariq 978/CR3/2007 The fugitive (Ziyad Tariq Abdallah) signed a contract to equip ninety (90) armored personnel carriers in the amount of (38,281,500) with the Sifeen
Abdallah Salih General Trading Company under contract number (26/T/2004 on 24/11/2004) without following the correct legal procedures.
Al Qattan
6 Ziyad Tariq 1101/CR1/2007 The fugitive (Ziyad Tariq Abdallah) entered into contract number (T/9/2005), concluded with the Ministry of Defense and Al Ain Commercial [sic]
Abdallah Salih Company, to equip the Ministry with thirty (30) mobile ice- and water-making plants contrary to instructions and outside of the financial authority
entrusted to him. The collected evidence was: the statement of the confidential informant and the statement of the legal representative for the Ministry of
Al Qattan Defense. He was convicted by the Central Criminal Court / Karkh, and he was sentenced in absentia, pursuant to article (340) PL in case number
(1101/CR1/2007 on 25/7/2007).
7 Ziyad Tariq 1102/CR17/2007 Concerning the irregularities of the contract (17/2004), the contract between the Ministry of Defense and Yanboa Al Khalij Trading and Contracting
Abdallah Salih Company consists of the amount provided without ensuring a guarantor contrary to the stipulations of the contract. Payment must be financially guaranteed
in the amount of (9) million Dollars in addition to not deducting the amount of taxes. Further, the contract was entered into contrary to the general
Al Qattan conditions for contracting. The collected evidence is: relevant statements and the administrative investigation. He was convicted by the Central Criminal
Court / Karkh, and he was sentenced in absentia in case number (1102/CR17/2007 on 13/8/2007).
8 Ziyad Tariq 2229/CR1/2007 The convict (Ziyad Tariq Abdallah Al Qattan) entered into a contract to specially equip military uniforms, shirts, and boots, among other items, with a
Abdallah Salih value of (113752) Dollars, contrary to the law and the official legal and financial circumstances contexts for contracting. The collected evidence is: the
statements of the legal representative for the Ministry of Defense, the administrative investigation, and the report of the Office of Financial Supervision.
Al Qattan He was convicted by the Central Criminal Court/Karkh, and he was sentenced in absentia to seven years in prison in case number (2229/CR1/2007) in
accordance with the provisions of article (340 PL).
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 6 of 19
Name Case number Summary of case
9 Ziyad Tariq 77/CR3/2011 In 2004, he entered into a contract with Al Ain Commercial [sic] Company to equip the Ministry of Defense with (3000) automatic rifles
Abdallah Salih (treacherous[weapons]) contrary to the general procedures for contracting, outside of the financial authority entrusted to him by law, thus causing financial
damage to the entity for which he was working. The gathered evidence is: the statement of the legal representative, the administrative investigation, and
Al Qattan the report by the Financial Oversight Board. He was convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison
in case number (77/CR3/2011 on 7/4/2010).
10 Ziyad Tariq 398/CR3/2012 The defendant Ziyad Tariq Abdallah Al Qattan, who was working as the Deputy Secretary-General at the Ministry of Defense and was the General
Abdallah Salih Director of Arming and Equipment in 2005, entered into contract number (T/37/2005) with the Zuhour Nourouz Company to equip the Second Brigade,
the regiment protecting oil installations, with rations for the members of the regiment. Whereas the contract included financial and administrative
Al Qattan violations, and whereas the defendant entered into the contract outside of his financial authority, in addition to not following the financial and accounting
controls when paying the financial receivables to the company. The lack of legal bids caused financial damage to the entity for which he was working.
The collected evidence is: the statement of the legal representative, the administrative investigation, and the report by the Financial Oversight Board. He
was convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison in case number (298/CR3/2012 on 10/4/2012).
11 Ziyad Tariq 1145/CR2/2010 He entered into a contract with the Oriental Commercial and Shipping Company for the purpose of transporting reserve materials for generators for the
Abdallah Salih Ministry contrary to the law and for excessive prices for moving reserve materials for generators from storage at the Ministry of Agriculture in the al-
Fudhailiya area to storage at the Ministry of Defense, in addition to the existence of deficiencies in the materials that were stored in the Ministry’s storage
Al Qattan valued at (112,315) thousand American dollars. The collected evidence is: the statements of the legal representative and the administrative investigation.
He was convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison in case number (1145/CR2/2010) on
(20/7/2014).
12 Ziyad Tariq 1493/CR2/2010 The convict Ziyad Tariq Abdallah Al Qattan, by exploiting his position as the previous Deputy Secretary-General at the Ministry of Defense and in
Abdallah Salih conjunction with the other fugitives Dalia Sabah Tawbia and Waleed Khalid Ismail in 2005, appropriated advances amounting to (165,000,000) one
hundred and sixty-five million Iraqi dinars without returning it to the Ministry despite the demand for it. The collected evidence is: the statement of the
Al Qattan legal representative and the Board of Inquiry. He was convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to ten years in prison
in case number (1493/CR2/2010 on 29/8/2010).
13 Ziyad Tariq 1522/CR1/2010 He exploited his position as the Deputy Secretary-General at the Ministry of Defense and the General Director of Arming and Equipment and wrongly
Abdallah Salih appropriated four residential homes in the Green Zone belonging to the Ministry of Finance. The houses are numbered (house 32 alley 2 neighborhood
226), (house 35 alley 3 neighborhood 226), and (house 36 alley 3 neighborhood 226). The collected evidence is: the statement of the legal representative
Al Qattan and the criminal record of the defendant. He was convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison,
pursuant to article (335), in case number (1522/CR1/2010 on 16/8/2010).
14 Ziyad Tariq (2089/CR3/2010) In 2005, the convict Ziyad Tariq Abdallah entered into contract number (T/6/2005) between the Ministry and Danya General Trade Company, for the
Abdallah Salih purpose of equipping the Ministry with light weapons and gear, outside of his financial authority and contrary to the general controls and procedures,
thus causing financial damage to the entity for which he was working. The collective evidence is: the administrative investigation and the criminal record
Al Qattan of the defendant. He was convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison, pursuant to article (340)
of the Criminal Penalties Code, in case number (2089/CR3/2010 on 3/11/2010).
15 Ziyad Tariq (2298/CR3/2011) The defendant Ziyad Tariq Abdallah Al Qattan, who was working as the Deputy Secretary-General at the Ministry of Defense and the General Director
Abdallah Salih of Arming and Equipment in 2005, entered into contract number (T55/2005) with Samyoum Trading Company to equip the Ministry with blankets ([for]
each individual), a total of thirty thousand blankets, contrary to the general procedures for contracting and without forming the appropriate committee for
Al Qattan receipt of the materials, thus causing financial damage to the entity for which he was working. He was convicted by the Al Rasafa Criminal Court, and
he was sentenced in absentia to six years in prison, pursuant to article (340) of the Criminal Penalties Code, on (20/11/2011) in case number
(2298/CR3/2011).
16 Ziyad Tariq 2777/CR4/2010 The defendant Ziyad Tariq Abdallah Al Qattan, previously the Deputy Secretary-General at the Ministry of Defense and the General Director of Arming
Abdallah Salih and Equipment in 2005, entered into contract number (T8/2005) with Al Ain Commercial [sic] Company on (23/1/2005) to equip the ministry with
automatic guns (AK-47) in a total amount of (9,962,000) million American dollars contrary to the specifications, controls, and instructions for contracting
Al Qattan and an extra disbursement of three hundred and ten hundred thousand American dollars (310,000) American dollars benefitting the company and causing
financial damage to the entity for which he was working. The collected evidence: the administrative investigation and the contract. He was convicted by
the Al Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison in case number (2777/CR4/2010 on 16/1/2011).
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 7 of 19
Name Case number Summary of case
17 Ziyad Tariq 3000/CR/2010 The defendant Ziyad Tariq Abdallah Al Qattan, in conjunction with the defendants Faris Ghanim and Sawsan Jasim Mohamed, entered into contract
Abdallah Salih number (T/19/2004) to equip the Ministry of Defense with encrypted mobile phones amounting to (2,212,500) two million two hundred twelve thousand
Al Qattan and five hundred American dollars contrary to the general procedures for contracting and outside of the legal and financial authority of the defendants. He
disbursed the entire value of the contract without the existence of a financial guarantee. The collective evidence: the statements of the legal representative
and the administrative investigation. He was convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison in case
number (3000/CR/2010 on 24/2/2011).
18 Ziyad Tariq 3006/CR/2010 The defendant Ziyad Tariq Abdallah Al Qattan entered into a contract with the Arab Construction and Contracting Company to develop buildings for the
Abdallah Salih Department of Veterans Affairs contrary to the general procedures for contracting and outside of the financial authority granted to him. In bad faith, he
Al Qattan caused financial damage to the entity for which he was working in order to obtain benefits for himself. The collected evidence: the statement of the legal
representative for the Ministry of Defense, the administrative investigation, and the consent of the defendant’s reference. He was convicted by the Al
Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison, pursuant to article (318), in case number (3006/CR/2010 on 24/2/2011).
19 Ziyad Tariq 3012/CR/2010 In 2004, the defendant Ziyad Tariq Abdallah Al Qattan set up a Dohuk warehouse with a civilian cadre that did not have the knowledge to receive or
Abdallah Salih deliver military material. The approval to disburse [money] for military material and machinery of various types and sizes to entities outside of the Ministry
Al Qattan of Defense is contrary to instructions and accounting protocol. Disbursing orders which caused, in bad faith, damage to the nation’s money for his personal
benefit in the amount of (sixteen billion six hundred sixty-three million nine hundred four thousand and eight hundred dinars. He harmed the interest of
the entity for which he was working. The collected evidence: the administrative investigation, and the consent of the defendant’s reference. He was
convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to seven years in prison, pursuant to article (318) of the Criminal Penalties
Code, on (24/2/2011) in case number 2012/CR/2010.
20 Ziyad Tariq (34/CR3/2011) In 2004, convicted fugitive Ziyad Tariq Abdallah Al Qattan, when he was working as the Deputy Secretary-General at the Ministry of Defense, in
Abdallah Salih conjunction with the defendants Bruska Nouri Sadeeq and Sawsan Jasim Mohamed when they were working at the Ministry of Defense, concluded a
Al Qattan financial agreement with the General Investment Group (GIG) Company to finance a Ukrainian company tasked with the rehabilitation of tanks for the
Ministry. Failure to follow the legal procedures for contracting caused intentional harm to the state assets and to the interest of the entity for which he was
working. An amount of four million dollars was paid for the maintenance of tanks type (T72). There was a second payment valued at (twenty-four
million and seven hundred fourteen thousand and six hundred ninety-seven dollars and fifteen cents) for the maintenance of tanks type (T55). The evidence
collected against him is: the statement of the legal representative, the report by the Financial Oversight Board, the administrative investigation, transcripts,
and case documents. He was convicted by the Al Rasafa Criminal Court, the specialist in integrity cases, and he was sentenced in absentia to seven years
in prison, pursuant to article (340) of the Criminal Penalties Code, on 24/3/2011 in case number (34/CR3/2011).
21 Ziyad Tariq (89/CR2/2010) In 2004, the fugitive (Ziyad Tariq Abdallah Al Qattan), when he was working as the Deputy Secretary-General at the Ministry of Defense, wrongly
Abdallah Salih appropriated funds from the money of the Ministry of Defense and transferred them abroad by writing a letter to Warka’ Bank for the purpose of opening
Al Qattan a line of credit in foreign currency, outside of the country in the amount of six hundred million American dollars. The aforementioned bank opened the
line of credit at The Housing Bank. Jordanian financing and a transfer in the amount of one hundred and sixty million dollars for him under this illicit line
of credit without the approval of the Ministry or the Central Bank of Iraq and without the existence of valid documentation for the banking transactions
and the valid documentation for it. The evidence against him is: the statement of the legal representative for the Ministry of Defense, the statement of the
legal representative for the Central Bank, the statement of the witness and detective, the report by the Financial Oversight Board, and the facts and
documentation of the case. He was convicted by the Al Rasafa Criminal Court, the specialist in integrity cases, and he was sentenced in absentia to ten
years in prison, pursuant to article (316) of the Criminal Penalties Code, on 2/3/2010 in case number (89/CR2/2010).
22 Ziyad Tariq (116/CR/2015) In 2005, the fugitive (Ziyad Tariq Abdallah Al Qattan), when he was working as the Deputy Secretary-General at the Ministry of Defense, deliberately
Abdallah Salih and in violation of his job’s duties damaged the interests to the entity for which he was working through entering into contract number (T46/2005) between
Al Qattan the Ministry of Defense and Zuhour Nourouz Company to equip the Ministry with rations contrary to [his] authority and the general conditions for
contracting. The evidence against him is: the statement of the legal representative, the report by the Financial Oversight Board, the administrative
investigation, and the minutes and documentation of the case. He was convicted by the Al Rasafa Misdemeanor Court, specialist in integrity cases, and
was sentenced in absentia to two years in solitary confinement, pursuant to article (331) of the Criminal Penalties Code, on (16/4/2015) in case number
(116/CR/2015).
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 8 of 19
Name Case number Summary of case
23 Ziyad Tariq 326/CR3/2013 The fugitive (Ziyad Tariq Abdallah Salih Al Qattan) together with (Dhur Mohamed Tawfeeq, Adil Abdallah Mohamed, Sawsan Jasim Mohamed),
Abdallah Salih intentionally caused financial damage to the public and committed legal, financial, and administrative violations in 2004 while employed as Deputy Secretary
Al Qattan General of the Ministry of Defense, by concluding contract number (T28/2004), concluded between the Ministry of Defense and the Iraq Technology
Company, regarding providing the Ministry with an electronic survey system about the cellular phone network and radio transmissions for (thirty million,
one hundred sixty-two thousand, eight hundred dollars). The evidence gathered against him is: minutes, case documents, a report by the Financial Oversight
Board, and an administrative investigation. He was convicted by the Al Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was
sentenced in absentia to seven years in prison, pursuant to article (340) of the Criminal Penalties Code on 31/3/2013, in case number 326/CR3/2013.
24 Ziyad Tariq (602/CR1/2010) The fugitive (Ziyad Tariq Abdallah Salih Al Qattan), in 2005 while employed as Deputy Secretary General of the Ministry of Defense, together with (Dhur
Abdallah Salih Mohamed Tawfeeq), concluded contract (T52/2005) between the Ministry and the Meer Company, regarding providing the Ministry with food, without
Al Qattan obtaining the prior consent of the Minister, thus demonstrating bad intentions toward the entity with which he was employed. The evidence gathered against
him is: an administrative investigation, a report by the Financial Oversight Board, and a statement by the legal representative. He was convicted by the Al
Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to ten years in prison, pursuant to article (318) of the
Criminal Penalties Code, dated 26/5/2010, in case number (602/CR1/2010).
25 Ziyad Tariq 617/CR2/2006 In 2004, the fugitive (Ziyad Tariq Abdallah Salih Al Qattan), in his capacity as Deputy Secretary General of the Ministry of Defense, signed a contract with
Abdallah Salih (Taybek Management System Offshore) to provide cars for the Ministry of Defense, namely five (BMW) armored cars and fifteen (Land Rover) armored
Al Qattan cars, without following the correct procedures indicated by Iraqi law, valued at (five million, fifty-three) thousand US dollars. The evidence gathered against
him is: a witness statement, a statement by the legal representative of the Ministry of Defense, an administrative investigation, and a statement by the
Defendant. He was convicted by the Central Criminal Court/ Karkh and sentenced in absentia to fifteen years pursuant to article (318) in case number
(617/CR2/2006 on 24/7/2006).
26 Ziyad Tariq (666/CR3/2011) The fugitive (Ziyad Tariq Abdallah Salih Al Qattan), in 2004 while employed as Deputy Secretary General of the Ministry of Defense, together with (Sawsan
Abdallah Salih Jasim Mohamed), concluded contract (T16/2004) between the Ministry of Defense and the Iraq Technology Company with a navigation and control system
Al Qattan for (one million, nine hundred sixty thousand, five hundred dollars), thus violating the rules and regulations regarding government contracting procedures,
thus causing intentional financial damage to the public. He signed the contract outside of the financial authority entrusted to him and cashed the amount of
the contract, but there are no documents showing that the materials were received or that they entered the Ministry’s warehouses. The evidence gathered
against him is: the remarks of the legal representative, a report by the Financial Oversight Board, and an administrative investigation. He was convicted by
the Al Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant to article
(340) of the Criminal Penalties Code on (28/7/2011) in case number (666/CR3/2011).
27 Ziyad Tariq 836/CR3/2009 The fugitive (Ziyad Tariq Abdallah Salih Al Qattan) committed violations stemming from contract number (46/2005), concluded between the Ministry of
Abdallah Salih Defense and the International Companies Group to build a prison at Al Muthana Airport, which would hold (150) persons, for use by the Ministry of
Al Qattan Defense. In his capacity as Deputy Secretary General of the Ministry, he concluded the contract in violation of contracting procedures, without obtaining
the consent of the Minister of Defense, and without providing the necessary guarantees, and furthermore, the contract fell outside of his financial authority.
The evidence gathered against him is: a letter from the investigative committee, a report by the Financial Oversight Board, and the remarks of the legal
representative. He was convicted by the Central Criminal Court/ Karkh and sentenced in absentia to six years pursuant to article (340) PL of the Criminal
Penalties Code on 6/9/2009 in case number 836/CR3/2009.
28 Ziyad Tariq 975/CR3/2007 In 2005, he concluded contract number (T/20/2004) between the Ministry and the (Yanboa Al Khalij) Company, regarding providing the Ministry with
Abdallah Salih munition, outside his financial authority, without following the legal guidelines for contracting procedures, and without obtaining prior consent, thus causing
Al Qattan financial damage to the entity for which he was working. The evidence gathered against him is: a witness statement, a statement by the legal representative
of the Ministry of Defense, and an administrative investigation. He was convicted by the Central Criminal Court/ Karkh and sentenced in absentia to fifteen
years pursuant to article (318) Pl in case number (975/CR3/2007 on 12/9/2006).
29 Ziyad Tariq 1075/CR1/2010 A contract was concluded between the Ministry of Defense and the Al Aneeq Laboratory for Signs and Camps, to provide the Ministry with (720) tents, for
Abdallah Salih a total cost of two hundred eighty-eight million dinars. Whereas the contract was concluded in violation of general contracting procedures, outside of the
Al Qattan financial authority entrusted to [the fugitive], and without confirmation that the materials subject of the contract were received, thus causing financial damage
to the Ministry. He was convicted by the Al Rasafa Criminal Court and sentenced in absentia to six years, pursuant to article (340) in case number
1075/CR1/2010, on 26/7/2010.

Name Case number Summary of case


Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 9 of 19
30 Ziyad Tariq (1231/CR/2014) The fugitive (Ziyad Tariq Abdallah Salih Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, signed contract number
Abdallah Salih (T19/2005) on 29/3/2005, concluded between the Ministry of Defense and the Nowruz Company, to provide a site in east Fallujah (Camp Tariq) with food
for (4,325) four thousand three hundred twenty-five soldiers per day, with eight dollars [per person per day] providing three meals to each person for sixty
Al Qattan days. The contract was signed without following the correct legal guidelines for contracts, such as the approval of the purchase by Minister or his
representative, by accepting bids or sending a direct invitation to several companies to provide food, and furthermore, there were no competing offers to
ensure competitive pricing, and there was no detailed description of the foods being requested. Additionally, the contract was signed outside the convicted
Defendant’s financial authority, and he did not follow the financial and accounting procedures in paying back what was due. He was convicted by Al
Rasafa Misdemeanor Court and sentenced in absentia to two years, without the possibility of reducing the sentence, pursuant to article (341) of the
Criminal Procedure Code on 9/2/2010, in case number (1231/CR/2014).
31 Ziyad Tariq 1254/CR3/2007 The fugitive (Ziyad Tariq Abdallah Salih Al Qattan), in his capacity as Deputy Secretary General of the Ministry of Defense, signed contract number
Abdallah Salih (T24/2004 on 24/11/2004), with the MBA Company (UAE), to buy (230) cars, valued at (26,053,250) US dollars, without following the correct legal
guidelines for contracts. The evidence gathered against him is: a witness statement, a statement by the legal representative of the Ministry of Defense, an
Al Qattan administrative investigation, and a report by the Financial Oversight Board. He was convicted by the Central Criminal Court/ Karkh and sentenced in
absentia to fifteen years pursuant to article (318) PL in case number (1254/C3/2007 on 10/7/2006). He was also required to pay (18,002,250) US dollars,
to compensate the Ministry for the value of the cars subject of the contract with the MBA Company (UAE).
32 Ziyad Tariq (1526/CR2/2009) The fugitive (Ziyad Tariq Abdallah Salih Al Qattan), in 2004 while employed as Deputy Secretary General of the Ministry, concluded contract number
Abdallah Salih (T31/2004), concluded between the Ministry of Defense and Amjad Anbar Al Rafidain Company, to provide the Ministry with (5000) pieces of bullet-
proof gear, for a total value of (two million, one hundred seventy-five thousand dollars). The contract was done in a way that violates the rules and
Al Qattan regulations, and with no bidding process or offers, without a detailed description of the specifications of the materials, and without providing guarantees
or centralized records proving that the Ministry received the materials. The amount of the contract was paid, [however], causing intentional financial
damage to the country and to the entity with which [the fugitive] was employed. The evidence gathered against him is: a statement by the legal
representative of the Ministry, statements by other Defendants, and an administrative investigation. He was convicted by the Al Rasafa Criminal Court,
which has jurisdiction to try integrity cases, and he was sentenced in absentia to six years, pursuant to article (340) of the Criminal Penalties Code, on
24/12/2009, in case number (1526/CR2/2009).
33 Ziyad Tariq 1570/CR3/2010 The fugitive (Ziyad Tariq Abdallah Salih Al Qattan), who was employed (2005)as Deputy Secretary General of the Ministry of Defense and General
Abdallah Salih Manager of Weapons and Munitions, exploited his position and misappropriated materials belonging to the Ministry of Defense by raiding the Dohuk
warehouse and sending a representative of Zuhour Nourouz Company to take seven (7) portable kitchens in order to transport them to Baghdad without
Al Qattan an official contract. They were not sent to the warehouse of the Ministry of Defense in Baghdad, to which they still belong; he misappropriated them.
The evidence gathered against him is: a statement by the legal representative of the Ministry of Defense, statements by previous Defendants, and an
administrative investigation. He was convicted by the Al Rasafa Criminal Court and sentenced in absentia to fifteen years pursuant to article (316 PL) in
case number 1570/CR3/2010, on 22/8/2010.
34 Ziyad Tariq (1682/CR3/2010) The fugitive (Ziyad Tariq Abdallah Al Qattan) together with (Hazim Katram Al Shaalan, Sawsan Jasim Mohamed), intentionally caused financial damage
Abdallah Salih to the public in 2004, while employed as Deputy Secretary General of the Ministry of Defense, by cashing (four million three hundred thirty-two thousand
five hundred dollars) from contract number (USMI-5CCONTIGFOB.2), concluded between the Ministry and the Iraqi-American Group, in violation of
Al Qattan financial, accounting, and legal regulations. The exchange took place between (26/12/2004) and (26/2/2005). The evidence gathered against him is:
minutes, case documents, a report by the Financial Oversight Board, and an administrative investigation. He was convicted by the Al Rasafa Criminal
Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Criminal
Penalties Code on 2/9/2010, in case number (1682/CR3/2010).
35 Ziyad Tariq (1934/CR3/2012) In 2005, fugitive (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, together with (Adil Abdallah
Abdallah Salih Mohamed, Sawsan Jasim Mohamed, Dhur Mohamed Tawfeeq), who were employed with the Ministry of Defense, concluded contract number (T29/2005)
between the Ministry and Ain Al Saqr Security and Protection Services Company to transport three hundred drums of gasoline from Majmaa Saad in Abu
Al Qattan Ghraib to the Ministry’s headquarters, intentionally causing financial damage to the public and to the entity with which they were employed, by concluding
the contract in violation of the rules and regulations for contracting, exchanging money in the absence of original documents [attesting to] the exchange,
violating financial and accounting regulations, failing to following transportation procedures, and failure to document [the transportation of materials].
The evidence gathered against him is: an administrative investigation, minutes, case documents, and statements by the other Defendants. He was convicted
by the Al Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven
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years in prison, pursuant to article (340) of the Criminal Penalties Code on 26/8/2012 in case number (1934/CR3/2012).
36 Ziyad Tariq 2121/CR/2010 The fugitive (Ziyad Tariq Abdallah Salih Al Qattan), in 2004 together with (Sawsan Jasim Mohamed), concluded contract (T5/2004) between the Ministry
Abdallah Salih of Defense and Aroud Trading Company, to provide the Ministry with (3,000) 9mm caliber pistols, (3,000) automatic pocket pistols, and (500,000) rounds
Al Qattan of ammunition. The amount of the contract was cashed before [the materials] were provided, namely (5,222,500) five million, two hundred twenty-two
thousand, five hundred dollars. They violated the general contracting procedures, as there was no call for bids or direct invitation [of competitors] and no
indication that the Minister approved the purchase or the contract. The contract was concluded outside the financial authority of the Defendants, and
there is no indication, that the materials were received or placed in the Ministry’s warehouses. There is no certified guarantee of collateral presented by
the company; the entire amount was paid upfront, in violation of accounting regulations, causing financial damage to the public. The evidence gathered
against him is: an administrative investigation, complaints stating crimes committed previously by the defendants, and witnesses’ statement. He was
convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to six (6) years, in case number (2121/CR/2010 on 27/10/2010).
37 Ziyad Tariq (2285/CR3/2012) In 2004, fugitive (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, together with (Sawsan
Abdallah Salih Jasim Mohamed, Dhur Mohamed Tawfeeq. Adil Abdallah Mohamed) concluded contract number (T16/2004) with Sifeen General Trading Company to
Al Qattan provide eight hundred electric arc test kits to be used by pedestrians, equipped with a weapon-detecting device, metal armor, and (c5500) metal materials,
at a cost of (forty-four thousand eight hundred US dollars), at (five thousand six hundred US dollars) per unit, but the materials were not received by the
General Office of Weapons and Munitions, and the amount of the contract was cashed in advance, with no letter of guarantee, in violation of accounting
and financial procedures, thus intentionally causing financial damage to the public. The evidence gathered against him is: remarks by the legal
representative of the Ministry of Defense, an administrative investigation and a report by the Financial Oversight Board. He was convicted by the Al
Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340)
of the Criminal Penalties Code on 20/9/2012 in case number (2285/CR3/2012).
38 Ziyad Tariq (2442/CR2/2015) The fugitive (Ziyad Tariq Abdallah Salih Al Qattan), who was employed as Deputy Secretary General of the Ministry of Defense, intentionally caused
Abdallah Salih financial damage to the public by concluding contract number (T23/2004) between the Ministry of Defense and the (Yanboa Al Khalij) Company, to
Al Qattan purchase non-weapon materials for the Iraqi army, intentionally causing financial damage to the public and to the entity with which he was employed, in
the amount of (6,972,000) six million, nine hundred seventy-two thousand US dollars. The evidence gathered against him is: a witness statement, an
administrative investigation, minutes, and case documents. He was convicted by the Al Rasafa Criminal Court, and he was sentenced in absentia to seven
years in prison, pursuant to article (340 PL) of the Criminal Penalties Code on 2/11/2010 in case number (2442/CR2/2015).
39 Ziyad Tariq (2538/CR2/2014) The fugitive (Ziyad Tariq Al Qattan) committed violations through contract (T8/2004 on 27/10/2004), concluded between the Ministry as represented by
Abdallah Salih the convicted Defendant and Sifeen General Trading Company, to provide the Ministry with light weaponry for a total value of thirty-one million four
Al Qattan hundred fifty thousand dollars. Whereas the Ministry did not confirm that it received the materials subject of the contract; meanwhile, the total amount
was paid, causing intentional damage to the public, in the amount of the total value of the contract. He was convicted by the Al Rasafa Criminal Court
and sentenced in absentia to fifteen years pursuant to article (318) PL in case number (2538/CR2/2014) on 24/12/2014.
40 Ziyad Tariq 2799/CR1/2010 The Defendant concluded contracts number 23/A, 5/2005, and 36/2005, regarding food [service] contracts with Al Nourain Company, World Kitchens,
Abdallah Salih and the Arab Group, to provide food, in violation of the accounting and financial rules and regulations, thus causing financial damage to the country
Al Qattan through Defendant Tariq’s gross negligence in his capacity as former Deputy Secretary. He overstepped his financial authority and did not call for bids
or offer to guarantee bids, together with the Defendant Dhur Mohamed Tawfeeq Al Badri, Contracts Manager at the Office of Weapons and Munitions.
41 Ziyad Tariq (2824/CR/2010) In 2005, fugitive (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, together with (Omar Abd
Abdallah Salih Al Rahman Mahmoud, Sawsan Jasim Mohamed), who were employed with the Ministry of Defense, concluded contract number (T2/2005), between the
Al Qattan Ministry and Sifeen General Trading Company, to provide the Ministry with six Toyota armored cars, for a total price of one million, one hundred fifty-
eight thousand dollars, thus causing intentional financial damage to the public and to the entity with which they were employed, by concluding the contract
in violation of the rules and regulations for contracting. The evidence gathered against him is: a witness statement, a statement by the legal representative,
an administrative investigation, minutes, and case documents. He was convicted by the Al Rasafa Criminal Court, which has jurisdiction to try integrity
cases.
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and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Criminal Penalties Code on 24/2/2011 in case number
(2824/CR/2010).
42 Ziyad Tariq (2969/CR3/2012) In 2004, the convicted fugitive (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, together with
Abdallah Salih (Sawsan Jasim Mohamed) and other Defendants facing various charges in this case, exchanged (one hundred thousand US dollars) in excess of the amount
of contract number (T46/2004), which was concluded between Al Ain Commercial Company, to provide the Ministry with a tanker truck. They violated
Al Qattan the conditions and rules for contracting, thus causing intentional financial damage to the public and to the entity with which they were employed, by
exchanging an amount in excess of the amount of the contract. The evidence gathered against him is: an administrative investigation, minutes, case
documents, and a statement by the legal representative. He was convicted by the Al Rasafa Criminal Court, which has jurisdiction to try integrity cases,
and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Criminal Penalties Code on 27/11/2012 in case number
(2969/CR3/2012).
43 Ziyad Tariq (2974/CR3/2012) In 2004, the convicted fugitive (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, together with
Abdallah Salih (Dhur Mohamed Tawfeeq. Adil Abdallah Mohamed, Sawsan Jasim Mohamed), caused intentional financial damage to the public by transferring two
deeds, numbers (696642, 696643), in violation of the rules and regulations, to a representative of Al Ain Commercial Company, [pursuant] to contracts
Al Qattan concluded with the Ministry of Defense in violation of contracting procedures and outside of the authority entrusted to it. They did not confirm receipt
of the materials subject of the contract. The first deed was valued at (one hundred forty-nine million, one hundred twelve thousand, nine hundred fifty)
US dollars, and the second deed was valued at (three hundred forty-eight million, eight hundred twenty-eight thousand, two hundred eighty) US dollars.
The deeds were exchanged in advance, and there is no amount equivalent to the deeds subject of the contract in the exchange records; rather, the money
was smuggled out of Iraq. The evidence gathered against him is: a statement by the legal representative, case documents, papers, an administrative
investigation, and a report by the Financial Oversight Board. He was convicted by the Al Rasafa Criminal Court, which has jurisdiction to try integrity
cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Criminal Penalties Code on 26/11/2012 in case number
(2974/CR3/2012).
44 Ziyad Tariq (3076/CR4/2010) In 2004, the convicted fugitive (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, together with
Abdallah Salih the Defendant (Sawsan Jasim Mohamed), concluded contract number (T7/2004) with Sifeen Trading Company, to provide the Ministry with 662 mm
caliber light ammunition, as well as 12.7 mm ammunition, anti-personnel grenades, and armor, valued at (twenty-four million, five hundred thousand
Al Qattan dollars) in violation of financial and accounting guidelines. He overstepped his financial authority and did not show the contract to the Ministry to obtain
legal approval, thus causing intentional financial damage to the public. The evidence gathered against him is: a statement by the legal representative, a
report by the Financial Oversight Board, and an administrative investigation. He was convicted by the Al Rasafa Criminal Court, which has jurisdiction
to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Criminal Penalties Code on 3/3/201 in
case number (3076/CR4/2010).
45 Ziyad Tariq 659CR2/2006 In 2005, the convicted fugitive (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, signed a
Abdallah Salih contract outside his authority with Hussein Al Wakeel Company to provide the Ministry with bullroarers, thus maliciously causing damage to the entity
for which he worked. This is clear from the remarks of the legal representative of the Ministry of Justice, who requested a complaint against the Defendant,
Al Qattan and the Court was further persuaded by an administrative investigation and a report by the Financial Oversight Board. Despite that an arrest warrant was
issued and that the Defendant’s assets were placed under hold, he did not appear for the investigation. The authorities were unable to arrest him, despite
taking all measures to compel him to appear and publishing notices in two local newspapers, namely Al Manar in issue (695) on 20/4/2006 and Al Dustour
in issue (792) on 21/4/2006. He did not pay attention to what would happen to him as a result of the case, and he did not heed the verdict that would be
issued against him because of sufficient evidence. He was convicted pursuant to the provisions of article 318 of the Iraqi Criminal Penalties Code and
sentenced in absentia to (fifteen years) on 24/7/2009, in case number 659CR2/2006.
46 Ziyad Tariq 2016CR2/2006 In 2005, the convicted fugitive (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, issued an
Abdallah Salih order to exchange ninety-six thousand US dollars to purchase a crane and a car. This order was a violation of the authority entrusted to him; rather, that
authority belongs exclusively to the Minister of Defense, as stated in Declaration number (2243) dated 7/9/2005), which proves that exchanging the
Al Qattan money subject of this case was outside his authority. The fugitive Defendant did this in his personal capacity without following the legal methods and
indicated procedures. This is proven by witness testimony, whereas the witness (Haydar Mazhar), who was Internal Oversight Manager at the time, stated
that he went to sales exhibitions, pursuant to an assignment from his direct supervisor, and found that the average price of one bus was eighteen thousand
dollars; meanwhile, one had been sparks [sic: should say “bought”] for twenty-three thousand dollars. As for the fork crane, he went to the Hyundai
Company, the main exhibitor in Masbah, he found that its price was twenty-one thousand, five hundred dollars, but it had been bought by the Defendant
for twenty-five thousand dollars. Thus, the difference in the prices was seventeen thousand dollars, and the manager refused to settle up. This manager
was the Internal Oversight Manager, (Omar Abdulrahman), and the rest of the witness testimony is along the same line, because of sufficient evidence
against him in
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namely a statement by the legal representative, witness testimony, the factual evidence of the Defendant’s failure to appear, and his flight to an unknown
location, despite that all measures were taken to compel him to appear. He was convicted pursuant to the provisions of article 318 of the Iraqi Criminal
Penalties Code on 7/1/2007 in case number 2016CR2/2006.
47 Ziyad Tariq 2083CR4/2009 On 12/4/2005, fugitive Defendant (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, concluded a
Abdallah Salih contract with Samyoum Company to provide the Ministry with (2,500) bulletproof curtains at a price of (435) per unit, for a total of one million eighty-
seven thousand five hundred dollars. [Illegible] he committed this action outside his financial authority and without following the legal procedures for
Al Qattan contracting, such as correspondence, collateral, and offers, and the contract was not certified by the Office of the General Legal Consultant. The witness
Raheem Abdulhussein confirmed this, and the Court reviewed the administrative investigation related to the case and a copy of the contract concluded with
the aforementioned company, exchange records, and a report by the Financial Oversight Board. The Court reviewed the reference [illegible] for referral
number (28/4036) on 6/8/2006 issued by the Ministry of Defense. Because sufficient evidence has been gathered against him, namely the remarks of the
legal representative, which are corroborated by the remarks of the witness, and the Financial Oversight report, and because the Defendant’s flight is
considered factual evidence that he committed the crime, he was convicted pursuant to the Iraqi Criminal Penalties Code and sentenced in absentia to
(fifteen years) in prison on 26/10/2009 in case number 2083CR4/2009.
48 Ziyad Tariq 429CR2/2008 Fugitive Defendant (Ziyad Tariq Abdallah Al Qattan): On 11/4/2005, a contract was made with ADKOL Company (UAE) by the Defendant Ziyad Tariq
Abdallah Salih Al Qattan in his capacity as Deputy Secretary General of the Ministry of Defense and Manager of Weapons and Munitions to provide the Ministry of
Defense with pilot and aviation technician uniforms for the Air Force, for 87250 dollars. The materials subject of the contract were supplied and received,
Al Qattan but the contract lacked the conditions and documents [indicated] in the guidelines for executing contracts, thus causing financial damage to the country.
Those documents are supported by the remarks of the legal representative for the Ministry of Defense, a copy of contract number T27/2005, which is
attached to the documents, and a letter from the investigative committee, which was formed to investigate the matter of the contract. Based on the
committee’s minutes dated 15/1/2008 and the Financial Oversight Board’s letter number 478 dated 22/1/2008, and because sufficient evidence has been
gathered against him, he was convicted pursuant to the provisions of article 340 PL and sentenced in absentia to (seven years) in prison on 11/8/2009 in
case number 429CR2/2008.
49 Ziyad Tariq 359CR2/2009 In 2005, the fugitive Defendant (Ziyad Tariq Abdallah Al Qattan), in his capacity as Deputy Secretary General of the Ministry of Defense, concluded
Abdallah Salih contracts with Zuhour Nourouz Company to provide the Ministry with foodstuffs, including contract number 28. The act of concluding the contract was
outside the authority of the aforementioned Defendant. In concluding it, he did not follow the procedures required by law, namely governmental bidding,
Al Qattan as he did not announce a bid to provide foodstuffs. These facts are supported by remarks of the legal representative for the Ministry of Defense, the
recommendations of the investigative committee, and Financial Oversight Board report number 9320 on 22/10/2006. Because there is sufficient evidence
against him, he was convicted pursuant to article 326/1 of the Iraqi Criminal Penalties Code and sentenced in absentia to (five years) in prison, without the
possibility of reducing his sentence, on 27/7/2009 in case number 359CR2/2009.
50 Ziyad Tariq 548CR2/2006 In 2005, the fugitive Defendant (Ziyad Tariq Abdallah Al Qattan) signed a contract with Al Ain Commercial Company to provide the Ministry with 30 Ford
Abdallah Salih fire trucks, when the appropriate authorities did not request them, thus causing severe financial damage to the Ministry. The legal representative for the
Ministry requested a complaint against the Defendant. This is supported by the statement of witness Sawsan Jasim and the contents of the administrative
Al Qattan investigation relating to the cases. Despite that an arrest warrant was issued and that the Defendant’s assets were placed under hold, he did not appear for
the investigation. The authorities were unable to arrest him, despite taking all measures to compel him to appear and publishing notices in two local
newspapers, namely Al Manar in issue (705) on 7/5/2006 and Al Dustour in issue (806) on 7/5/2006. Because the Defendant did not appear, despite being
notified, not paying attention to what would happen to him as a result of the case, and not heeding the ruling that would be issued against him and because
of the statements by the legal representative for the Ministry of Defense and the witness Sawsan Jasim and the administrative investigation, which proves
that he maliciously caused damages to the entity for which he was working and to the country’s finances, and because sufficient evidence has been gathered
against him, he was convicted pursuant to article 318 of the Iraqi Criminal Penalties Code and sentenced in absentia to (fifteen years) in prison, on 24/7/2006
in case number 548CR2/2006.
51 Ziyad Tariq 614CR2/2006 In 2004, fugitive Defendant (Ziyad Tariq Abdallah Al Qattan), while employed as Deputy Secretary General of the Ministry of Defense, and acting on
Abdallah Salih behalf of the Ministry of Defense, signed a contract with Al Ain Company, to provide the ministry with hand grenades, for nine million, two hundred forty-
nine US dollars. He maliciously caused damage to the entity with which he was employed, by signing the contract outside the contract-making authority
Al Qattan entrusted to him. This is demonstrated by the statements by the legal representative for the Ministry of Defense, who requested a complaint against the
Defendant, and corroborated by the administrative investigation and Financial Oversight Board report related to the case. Despite that an arrest warrant
was issued and that the Defendant’s assets were placed under hold, he did not appear for the investigation. The authorities were unable to arrest him, despite
taking all measures to compel him to appear and publishing notices in two local newspapers, namely Al Manar in issue (695) on 20/4/2006 and Al Dustour
in issue (792) on 21/4/2006, and because sufficient evidence has been gathered against him, he was convicted pursuant to article 318 of the Iraqi Criminal
Penalties Code and sentenced in absentia to (five
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years) in prison, on 24/7/2006, in case number 614/CR2/2006.
52 Ziyad Tariq 2015CR1/2006 The fugitive Ziyad Tariq Abdallah Al Qattan, in 2004, while employed as Deputy Secretary General of the Ministry of Defense, concluded with Sifeen
Abdallah Salih General Trading Company contract number T2/204 to purchase 2000 helmets at the rate of one hundred ten dollars per helmet. It was confirmed that there
were no bids and the general contracting procedures were not followed. [The contract] was outside of the authorities of the aforementioned defendant who
Al Qattan is not in charge of contracting. After signing [the contract] the defendant handed the amount of the written check to the other fugitive Faris Ghanim Abd Al
Majeed and there are no documents of bank guarantee in that [amount]. Furthermore, there are no records of receiving the items agreed upon and that the
defendant Faris Ghanim has no relation to the contracting. It was confirmed later through the response of the Directorate of Budget and Program in the
Ministry of Defense in its letter number 289 on 27/10/2005 that defendant Ziyad Tariq authorized the defendant Faris Ghanim to receive the contract, the
documents and the checks and [the directorate] initiated a complaint against them. Furthermore, the statements of the legal representative in front of this
court and the court read the statement of witness Sawsan Jasim Mohamed who was employed at the Directorate of Budget and Programs at the time in the
Ministry of Defense, confirmed what was stated by the legal representative of the Ministry of Defense. The court also examined the copy of contract number
02/6 on 24/11/2004 which include the first party the Deputy Secretary General Ziyad Tariq and the second party Sifeen General Trading Company, the
period of the contract [which is] two weeks for providing the Ministry of Defense with 2000 steel helmets at the rate of 110 dollars per helmet for a total
cost of 220,000 two hundred twenty thousand dollars to be paid in cash at the signing of the contact and has the signature of fugitive Ziyad Tariq Al Qattan
and a request on the same date 24/11/2004 to pay the aforementioned amount. It is noted that there is no bank guarantee [for this contract]. The evidence
gathered against him in this case is: statement by the legal representative during the different stages of investigation and trial and the concluded contract
connected to the complaint which showed that he violated the general procedures for contracting namely not demanding a bank guarantee. Furthermore,
the declaration of the [female] witness and the escape of the defendants and not attending [the trial] to defend themselves in all stages of the investigation
and the trial. They were convicted pursuant to article 316 of the Penalties Code and they were sentenced in absentia to fifteen years in prison, on 4/2/2009,
in case number (2015CR1/2006).
53 Ziyad Tariq 2705CR/2007 The fugitive (Ziyad Tariq Abdallah on 26/12/2004 in Baghdad, in his capacity as Deputy Secretary General of the Ministry of Defense, concluded equipment
Abdallah Salih supply contract number T/53 between the Ministry of Defense and Al Ghadeer Bank to provide the Ministry of Defense (700) steel closets with one door
at the rate of 45 dollars per closet and 350 steel bunkbeds at the rate of 65 dollars per bed o contrary to the legal, financial and administrative sound
Al Qattan procedures for contracting, outside of the financial authority entrusted to him, thus causing intentional financial damage and waste to the public. The court
confirmed that through a statement by the legal representative [sic] of the Ministry of Defense and the documents of the case including the equipment supply
contract, the documents of the administrative investigation of the case and the report and recommendation of the investigative committee. Given all the
evidence gathered against him, the court convicted him pursuant to article 340 of the Penalties Code, on 3/2/2008, in case number (2705/CR/2007.
54 Ziyad Tariq 2469CR3/2007 The fugitive (Ziyad Tariq Abdallah Al Qattan), on 23/1/2005 while employed as Deputy Secretary General of the Ministry of Defense, concluded a contract,
Abdallah Salih on behalf of the Ministry of Defense, number (10/2005) with (Al Ain Commercial Company) to provide the ministry with 5,25 mm caliber light
ammunition, valued at (260 dollars) for every 1000 rounds and the amount of (480 thousand dollars) was added for the cost of air shipment and the addition
Al Qattan o (40 thousand dollars) for transportation expenses. The provider did not submit a bank guarantee [letter]; moreover, the contract was sent to Al Ain
Commercial company without following the legal procedures namely announcing for tenders or bids to choose the most appropriate bids. The contract was
concluded without asking any entity that deals with the aforementioned ammunition and the price was not determined by the appropriate committee.
Furthermore, the contract did not specify the required specifications for the ammunition, the origin and serviceability of the ammunition and gave long time
period of four months to provide the ammunition and that the sum of money was paid in advance in violation of accounting procedure in executing contract.
Defendant Ziyad Tariq Abdallah is responsible for all these violations given that he is the person who concluded this contract. This is evident from the
statement by the legal representative of the Ministry of Defense who filed the case against [Ziyad Tariq Abdallah] for causing intentional financial damage
to the state. There is sufficient evidence gathered against him and therefore, [the court] convicted him pursuant to article (340) of the Iraqi Penalties Code
and he was sentenced in absentia to seven years in prison, on 14/2/2008, in case number 2469CR3/2007.
55 Ziyad Tariq 476CR2/2009 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2005 while employed as Deputy Secretary General of the Ministry of Defense, concluded a contract with
Abdallah Salih Samyou Company to provide the Ministry of Defense military equipment contrary to the general regulations for contracting and outside his authorities;
whereas the contracting was done without a bid or announcing it. These facts were confirmed by the statements of the legal representative which were
Al Qattan supported by the documents of the contract subject to case number 33 on 12/4/2005, the letter of the Financial Oversight Board number f1853/15/1/1 on
5/3/2008 and the results of the administrative investigation attached to the documents. The evidence gathered against him is sufficient to convict him
pursuant to article 336/1 of the Iraqi Penalties Code and he was sentenced in absentia to (five years) in solitary confinement, on 26/7/2009, in case number
476CR2/2009.
56 Ziyad Tariq The fugitive Ziyad Tariq Abdallah Al Qattan, in 2005 while employed as Deputy Secretary General of the Ministry of Defense, entered into an agreement
Abdallah Salih with Lam’a Horizon Company owned by Mr. Pierre Boutros Yousef to provide the base of the First Mechanical Brigade in Al Taji or any place they occupy
dry and fresh food as well as all kinds of meat sufficient to feed (1800) one thousand eight hundred soldiers daily in addition to mineral water in the
Al Qattan agreement attached to the papers in violation to the contracts and agreements law and without announcing the contract and accepting the lowest bid.
Furthermore, the contract was written exceeding the value of the contracts by an increase of
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 14 of 19
Name Case number Summary of case
708CR2/2009 Nine dollars per person per day causing damage to the entity for which he was working and given that the evidence gathered against him is sufficient and
was convicted pursuant to article 318 of the Iraqi Penalties Code and he was sentenced in absentia to (ten years) in prison, on 24/5/2009, in case number
(708CR2/2009).
57 Ziyad Tariq 707CR3/2009 On 1/4/2005, The fugitive Ziyad Tariq Abdallah Al Qattan, while employed as Deputy Secretary General of the Ministry of Defense, concluded contract
Abdallah Salih number T25 for the year 2005 with Zuhour Nourouz Company to provide first brigade of Al Rafidain Brigade in Al Ramadi Camp with dried and fresh
food to feed (600) soldiers at the cost of eight [sic] dollars per soldier and for a period of sixty days. Whereas the contract was not approved by the senior
Al Qattan inspector in the ministry and there was violation of the instructions for the execution of contracts and bids by not attaching the supporting documents and
proof to the contract and the clearance statement also was not attached. They relied on the projection statement when the contract was concluded causing
intentional financial damages to the state and to the entity for which he was working. Given that the evidence gathered against him is sufficient, he was
convicted pursuant to article 340 of the Penalties Code and he was sentenced in absentia to (three years) in solitary confinement, on 19/8/2009, in case
number (707CR3/2009).
58 Ziyad Tariq 235CR1/2008 The fugitive Ziyad Tariq Abdallah Al Qattan, in 2004 concluded contract number T49/2004 to provide the ministry with 600 Land Rover vehicles while
Abdallah Salih employed as Deputy Secretary General of the Ministry of Defense with [sic] Al Ain Commercial [sic] Company and its representative Aziz Marzouk [sic]
who signed the contract outside of the financial authority entrusted to him by law whereas, it became evident to the court after it reviewed [incomplete
Al Qattan sentence] and given that the evidence against him that became apparent upon the court review of the copy of the aforementioned contract signed on
23/12/2004 and copy of the administrative investigation included in the recommendations confirms the responsibility for negligence of the aforementioned
defendant and the report by the Financial Oversight Board number 8957 on 30/10/2007 that includes seventeen paragraphs stating the violations in the
contract subject of this case and statements by the legal representative of the Ministry of Defense. The court decided to convict him pursuant to article 340
of the Penalties Code and he was sentenced in absentia to seven years, on 9/5/2010, in case number (235CR1/2008).
59 Ziyad Tariq 953CR3/2009 The fugitive Ziyad Tariq Abdallah Al Qattan, in 2006 while employed as Deputy Secretary General of the Ministry of Defense, concluded contract number
Abdallah Salih 2005/47 with Nourouz Company to provide rescue equipment to the seven division of the first brigade in violation of laws, regulations and codes causing
intentional damages for the entity for which he was working for. The evidence was supported with statements by the legal representative and the testimony
Al Qattan of witnesses. Given the evidence gathered against him is sufficient, he was convicted pursuant to article 340 of the Penalties Code and he was sentenced in
absentia to six years in prison, on 6/9/2009, in case number (953CR3/2009).
60 Ziyad Tariq 1632CR1/2007 The fugitive Ziyad Tariq Abdallah Al Qattan, in 2006 while employed as Deputy Secretary General of the Ministry of Defense, caused financial damages
Abdallah Salih to the Ministry of Defense through his position by contracting with Yanboa Al Khalij to provide the ministry with (R_B_K_C) weapons whereas the
contracts were given without bids to a company that is not registered at the company register. Furthermore, the prices were inflated and the source of the
Al Qattan agreed upon weapons was not identified specifically and there was no condition for an appropriate penalty despite the lateness of the company by one full
year without paying penalties for being late. There was no follow-up of the contract and making sure that the merchandise arrived. Moreover, the received
merchandise is Chinese made despite that, in the contract, the aforementioned merchandise is Russian made or from Eastern European countries. After
review, deliberation and examining the gathered evidence from the defendant and among which: a statement by the representative of the Ministry of Defense,
testimony of witnesses and the two reports the administrative in minutes number 11 on 10/2/2007 and [the report] of the Financial Oversight Board number
9/3/4/7 on 2/9/10/2006 and the other minutes attached to the papers. The court confirmed that fugitive Ziyad Tariq Al Qattan caused intentional financial
damage to the department for which he works at the Ministry of Defense for overstepping the authorities given to him in contracting with other and by
violating the legal and financial procedures in executing the contract and acting individually in ordering the items and the specifications of the merchandise
agreed upon with Yanboa Al Khalij Company without involving the rest of the specialists in that process and paying the value of the merchandise without
complying with the financial procedures which requires subtracting specific percentages from the contracts and calculating the late penalties. Given the
sufficient evidence gathered against him [the court] convicted him pursuant to article 340 of the Penalties Code and he was sentenced in absentia to seven
years in prison, on 27/8/2007, in case number (1632CR1/2007).
61 Ziyad Tariq 357CR2/2009 The fugitive Ziyad Tariq Abdallah Al Qattan, in 2005 while employed as Deputy Secretary General of the Ministry of Defense, concluded a contract to
Abdallah Salih prepare food for members of the second Brigade/Division in charge of oil protection with Zuhour Nourouz Company. The concluded contract was outside
the authorities of the defendant above and he did not follow the proper and legal procedures in advertising of government tenders. These facts were supported
Al Qattan by the statements of confidential informant, the [statements] of the legal representative of the Ministry of Defense, the recommendations of the investigation
committee established to investigate the administrative issue of the case and the report of the Financial Oversight Board attached to the documents. The
evidence gathered against him is sufficient and he was convicted pursuant to article 336/1 of the Iraqi Penalties Code and he was sentenced in absentia to
(five years) in severe prison, on 28/7/2009, in case number (357CR2/2009).
62 Ziyad Tariq The fugitive (Ziyad Tariq Abdallah Al Qattan), on 12/11/2005 concluded a contract with the Arab Port Company to build building for the department of
Abdallah Salih veterans in the Ministry of Defense. Reviewing these contracts, it was noted those contracts were concluded outside of the authorities of the defendant.
Also, they did not adhere to the proper contracting procedures in terms of government tenders; wherein they were not advertised. These facts were supported
Al Qattan by the statements of the legal representative
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 15 of 19
Name Case number Summary of case
440CR2/2009 Of the Ministry of Defense and the recommendations of the administrative investigation committee established in this regard. The evidence gathered against
him is sufficient and he was convicted pursuant to article 336/1 of the Iraqi Penalties Code and he was sentenced in absentia to (five years) in solitary
confinement, on 28/7/2009, in case number (440CR2/2009).
63 Ziyad Tariq 31CR3/2011 The fugitive (Ziyad Tariq Abdallah Al Qattan), together with defendants (Bruska Nouri Sadiq and Sawsan Jasim Mohamed), on 27/12/2004 concluded an
Abdallah Salih invalid contract violating the laws and regulations, between the Ministry of Defense and Lloyd’s Corporation (USA) to build bases for the Rapid
Al Qattan Deployement Forces in Fallujah intentionally causing financial damage to the public and the interests of the entity they were working for. Whereas the
company did not implement any articles of the contract. The above fugitive had approved the payment in the amount of (eight million three thousand three
hundred and forty-six dollar) to the aforementioned company even though there was no valid contract or any documentation that the company had fulfilled
the contract or any contractual commitments even though the abovementioned amount was paid out. This was proven to the court through the administrative
inquiry, the report of the Financial Oversight Board, the statement of the legal representative of the Ministry of Defense, witnesses’ statements, the statements
of the other defendants, the criminal record of the defendant. The evidence gathered against him were sufficient and he was convicted by the Al Rasafa
Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to (seven years) in prison, pursuant to article 318 of the Iraqi
Penalties Code on 24/3/2011, in case number (31CR3/2011).
64 Ziyad Tariq 1638CR/2015 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2004 while employed as Deputy Secretary General of the Ministry of Defense, together with defendants
Abdallah Salih Adil Abdallah Al Shaikhly, Sawsan Jasim Mohamed, Hassan Fadl Nasser, Dhur Mohamed Tawfeeq Abdallah while they were working at the Ministry of
Al Qattan Defense, concluded contract number (T/4/2004] with Aroud Trading Company to provide the Ministry of Defense with light weapons and ammunition,
which resulted in willful violations in the contract and intentional damage to government finances valued at (16,749,590) sixteen million, seven hundred
and forty-nine thousand, five hundred and ninety Dinar. With all of the evidence against him, which includes the statement of the legal representative,
witness statements, the report of the Financial Oversight Board, the administrative inquiry, and the evidence that he fled. Thus, he was convicted by the Al
Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340) of
the Penalties Code and in accordance with articles (47, 48, 49) on 16/9/2015, in case number (1638CR/2015).
65 Ziyad Tariq 577CR3/2011 The fugitive (Ziyad Tariq Abdallah Al Qattan), on (15/1/2005) while employed as Deputy Secretary General of the Ministry of Defense, concluded a contract
Abdallah Salih with International Supplier Company to provide the Ministry with (100) land cruiser vehicles at a cost of (35,000) thirty-five thousand US dollars per each
Al Qattan vehicle, for a total of (3,500,000) three million, five hundred thousand US dollars without following the proper legal procedures for contracting and without
the approval of the Ministry of Defense. The gathered evidence for the case was sufficient to be convicted by the Al Rasafa Criminal Court, which has
jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Penalties Code, on 2/6/2011, in
case number (577CR3/2011).
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 16 of 19
Name Case number Summary of case
66 Ziyad Tariq 219/CR1/2016 On 16/1/2005 and under number T/6 an agreement was concluded with Al Furatain Company and its representative ( Azad Mustafa Rasheed) and the
Abdallah Salih buyer the Ministry of Defense and its representative the Deputy Secretary General, the fugitive (Ziyad Tariq Abdallah Al Qattan), to provide the Ministry
Al Qattan with six Emirati made bulletproof [illegible], (2500) units valued at 530 dollars per unit. The total value of the contract was one million three hundred
twenty-five thousand dollars and was paid in two payments after the material subject of the contract was received. The legal representative of a ministry
[sic] of the Ministry of Defense said in a documented statement that the contract was in violation of the legal procedures for contracting, namely
announcement, offers and biddings to choose the best and lower cost bids. The contract did not include the specifications of the material, the place of
delivery and the late penalty indicated [in the contract] is less than the percentage specified by the law. The court reviewed the aforementioned contract
and the copy of the administrative investigation, minutes number 78/ dated 21/7/2008, which was included in the recommendations. The negligence of
defendant Ziyad Tariq Abdallah Al Qattan was affirmed, and he was referred to the appropriate court. Furthermore, [the court] reviewed the Financial
Oversight Board report number 2798 dated 25/4/2007, which includes the addition of the aforementioned paragraphs including paragraph 7 of the contract.
The defendant does not have the financial authority to conclude the agreement or make financial commitments in this amount. [Upon] reviewing the minutes
of inspecting and evaluating the contract number T/6 on 16/1/2005, it was determined that the contract is missing details and specifications found in the
report and that the price for the bullet proof vest is very much exaggerated. Therefore, the evidence gathered in this case is: statements by the legal
representative of the Ministry of Defense, attached documents and minutes which corroborate the evidence as well as the Defendant’s failure to appear in
all stages of the investigation and during the trial. All of these are sufficient evidence to convict the fugitive Defendant Ziyad Tariq Abdallah Al Qattan
according to article 318 of [Criminal] Penalties [Code] for causing damage to the Ministry of Defense for his own benefit [or] for the [benefit of] the seller
company Al Furatain Company. The evidence against him is sufficient. The court decided to convict him on and to determine the penalty according to it.
He was sentenced in absentia with the understanding [that the judgment] can be subject to objection and appeal pursuant to the provisions of original article
182/A and 243 and was publicly announced on 15/4/2010.

67 Ziyad Tariq 1391/CR2/2010 The Defendant (Ziyad Tariq Abdallah Al Qattan), concluded agreement number (T48/2004) between the Ministry of Defense and Al Ain Commercial
Abdallah Salih [sic] Company to provide the ministry with (100) ambulances valued at eight million three hundred and fourteen thousand and five hundred US dollars.
Al Qattan Whereas he concluded a contract in his capacity as Deputy Secretary General of the Ministry of Defense in violation for legal procedure. The evidence
gathered against him is: the statement by the legal representative of the Ministry of Defense. He was convicted by the Al Rasafa Criminal Court, which has
jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Penalties Code and in accordance
with articles (47, 48, 49) on 18/8/2010, in case number (1391/CR2/2010).
68 Ziyad Tariq 482/CR2/2009 The fugitive Ziyad Tariq Abdallah, while employed as Deputy Secretary General of the Ministry of Defense, concluded contract number 45 with Yas Jasim
Abdallah Salih Company to provide the Ministry of Defense bulletproof vests. The contract was concluded outside the authorities of the aforementioned defendant and
Al Qattan did not announce the bid of this contract according to the procedures applied in governmental bidding. These facts were confirmed by the statements of the
legal representative of the Ministry of Defense and the decision of the investigation committee formed administratively to investigate in the subject of the
aforementioned contract and the report by the Financial Oversight Board number 5630 on 29/7/2007. Given all the evidence gathered against him he was
convicted pursuant to article 336/1 of the Iraqi Penalties Code and he was sentenced in absentia to (five years) in solitary confinement, on 28/7/2009, in
case number (482/CR2/2009).
69 Ziyad Tariq 2390/CR2/2010 The fugitive (Ziyad Tariq Abdallah Al Qattan), together with another defendant concluded contract number (T54/2004) between the Ministry of Defense
Abdallah Salih and Adnan Abd Al Aal Office to provide the ministry with different dorms in their capacity as representative of the ministry. Upon the review of the
Al Qattan documents, it was noted that the contract was concluded in violation of general conditions of contracting and outside the authority of the defendants.
Furthermore, there is no proof that the mentioned items in the contract were delivered and the contracts were not submitted to bids inspection committees
and the committees that receive the bids. The evidence gathered against him is: administrative investigation and statements by the legal representative. He
was convicted by the Al Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to six years in prison,
pursuant to article (340) of the Penalties Code and in accordance with articles (47, 48, 49) on 7/12/2010, in case number (2390/CR2/2010).
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 17 of 19
Name Case number Summary of case
70 Ziyad Tariq 1402/CR2/2010 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2005 while employed as Deputy Secretary General of the Ministry of Defense together with defendant
Abdallah Salih (Fares Ghanem, Sawsan Jasim Mohamed) while working at the Ministry of Defense concluded a contract between the Ministry of Defense and Al Ain
Al Qattan Commercial Trade [sic] Company for equipping the Ministry with (60 mobile hospitals and the contract was done in violation of the legal and procedural
conditions. The evidence gathered against him was sufficient to be convicted by Al Rasafa Criminal Court, which has jurisdiction to try integrity cases, and
he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Penalties Code on 17/8/2010, in case number (1402/CR2/2010).
71 Ziyad Tariq 13/CR N/2017 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2005 while employed as Deputy Secretary General of the Ministry of Defense intentionally causing
Abdallah Salih financial damage to the public and to the entity with which he was employed, by committing violations through contract number (T11/2005) dated 5/1/2005
Al Qattan between the Ministry of Defense and International Supplier Company to provide the ministry with (100) metal detector sticks for a total value of (13000)
thirteen thousand dollars. All the amount of the contract was paid without providing the equipment stated in the contract and [this] according to check
number (971302 on 2/3/2005). The evidence gathered against him is: a statement by the legal representative, an administrative investigation and his escape
is sufficient evidence to convict him by the Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in
prison, pursuant to article (315/ part two) of the Penalties Code in case number (13/CR N/2017) on 3/10/2017.
72 Ziyad Tariq 872/CR3/2010 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2004 while employed as Deputy Secretary General of the Ministry of Defense together with (Sawsan
Abdallah Salih Jasim Mohamed) concluded contract number (T/7/2004) with Al Ain Commercial [sic] Company to provide the Ministry with weapons and ammunition.
Al Qattan The contract was done in a way that violates the rules and regulations, causing financial damage to the public. The evidence gathered against him from the
administrative investigation, the report by the Financial Oversight Board and the testimony of the witness (Tariq Abd Zayir Salman) is sufficient to be
convicted by the Al Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant
to article (340) of the Iraqi Penalties Code on 15/6/2010, in case number (872/RC3/2010).
73 Ziyad Tariq 862/CR N/2017 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2005 while employed as Deputy Secretary General of the Ministry of Defense caused intentional financial
Abdallah Salih damage to the public and to the interests of the entity with which he was employed by committing violations through contract number (T39/2005) concluded
Al Qattan between the Ministry and Abdallah Kabab Restaurant. The damage valued at (two hundred fourteen million and four hundred fifty thousand dinars). The
evidence gathered against him from the administrative investigation, the report by the Financial Oversight Board and the statement by the legal
representative. The Criminal Court which has jurisdiction to try integrity cases [decided] that the evidence is sufficient to convict him. He was sentenced in
absentia to seven years in prison, pursuant to article (340) of the Iraqi Penalties Code in case number (862/CR N/2017) on 23/7/2017.
74 Ziyad Tariq 2241/CR[sic]2 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2005 while employed as Deputy Secretary General of the Ministry of Defense together with defendant
Abdallah Salih / 2011 (Sawsan Jasim Mohamed) while they were working at the Ministry of Defense concluded a contract with (The International Equipment Company) without
Al Qattan receiving the approval of the Minister or his representative to make a purchase or issue a direct invitation and the bid was not announced to guarantee the
competition between the companies. Additionally, the contract was signed outside his financial authority, and the contract did not include an article related
to the stamp fees and the calculated taxes which is part considered part of public regulations. A proposal was submitted by (Serdar Hussein Car Trading
Company) at the rate of (35,000) thirty-five thousand dollars per one car and it include the specifications of the contracted cars; however, the contracting
was done with (The International Equipment Company) at the rate of (36,400) thirty-six thousand and four hundred dollars per car including the
transportation, insurance, fees and taxes. The evidence collected against his is: a statement by the legal representative, administrative investigation by the
Ministry of Defense, minutes and case documents. He was convicted by the Al Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he
was sentenced in absentia to six years in prison, pursuant to article (340) of the Penalties Code on 27/10/2011, in case number (2241/CR2/2011).
75 Ziyad Tariq 1006/CR1/200 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2004 while employed as Deputy Secretary General of the Ministry of Defense committed violations
Abdallah Salih 7 through contracts number (51/4004) and (39/2004) and (41/2004) and their annexes with Al Ain Commercial [sic] Trade and Contracting Company to
Al Qattan provide the Ministry of Defense a number of planes [paying to the company] large sums of money without the following the correct legal and financial in
contracting and reimbursement procedures which involves a criminal agreement with the company that is ready to conclude these agreement and which
objective was to commit fraud or deceit to cause damages to the operations of the armed forces. Whereas the evidence gathered against him is: a statement
by the legal representative of the Ministry of Defense, testimony of witnesses, administrative investigation and a report by the Financial Oversight Board.
The evidence is sufficient for him to be convicted by the Central Criminal Court/ Karkh and was sentenced in absentia to a life sentence pursuant to article
(175/1) of the Penalties Code in case number (1006/CR1/2007) on 25/9/2007.
76 Ziyad Tariq 3043/CR/2010 The fugitive (Ziyad Tariq Abdallah Al Qattan), in (2004) while employed as Deputy Secretary General of the Ministry of Defense, together with (Sawsan
Abdallah Jasim), concluded contract number (T/17/2004) between the Ministry of Defense and (BRS) General Trading LLC to provide the ministry with anti-bullet
vests valued at (1087500) one million eighty-seven thousand and five hundred in violation
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 18 of 19
Name Case number Summary of case
Salih Al of general procedures for contracting and outside the financial authorities. The payment was made in violation of the procedures and was based on irregular
Qattan documents. The evidence gathered against him is: a statement by the legal representative and minutes of the administrative investigation of the Ministry of
Defense. He was convicted by the Al Rasafa Criminal Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven years
in prison, pursuant to article (318) of the Penalties Code in case number (3043/CR/2010) on 24/2/2011.
77 Ziyad Tariq 1895/CR3/2011 The fugitive (Ziyad Tariq Abdallah Al Qattan), in 2004 while employed as Deputy Secretary General of the Ministry of Defense, together with defendant
Abdallah Salih Sawsan Jasim Mohamed concluded contract number (T/50/2004) with Al Ain Company (UAE) to provide fire engines and contract (T/3/2004) with the
Al Qattan Lebanese company (SAL) without complying with the legal conditions for the two contracts with companies, thus causing intentionally financial damage
to public and to the interests of the entity with which they were employed. The evidence gathered is: an administrative investigation, report by the Financial
Oversight Board and a statement by the legal representative. The evidence is sufficient, [gathered] by Al Rasafa Criminal Court, which has jurisdiction
to try integrity cases. He was convicted, and he was sentenced in absentia to six years in prison, pursuant to article (340) of the Iraqi Penalties Code on
15/9/2011 in case number (1895/CR3/2011).
78 Ziyad Tariq 889/CR1/2010 The fugitive (Ziyad Tariq Abdallah Al Qattan), together with other defendants concluded contract number (16/2005) between the Ministry of Defense and
Abdallah Salih TTG Company to provide meals to the units of the Iraqi army whereas the contracts has many violation among which not receiving the approval of the
Al Qattan minister to conclude [the agreement], there was no direct bidding, announcement for a proposal, no competing offer and the absence of committee to receive
and evaluate the offers and proposals. The contract was signed outside [the defendant] financial authority and the contract was not confirmed by the
department of legal counsel at the Ministry of Defense, no certificate of good standing was presented, and the contract was extended twice without the
approval of the Minister of Defense. The evidence gathered against him are: a statement by the legal representative, an administrative investigation by the
Ministry of Defense and a report by the Financial Oversight Board. He was convicted by the Rasafa Criminal Court, which has jurisdiction to try integrity
cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Penalties Code and in accordance with articles (47, 48, 49)
on 21/7/2010, in case number (889/CR1/2010).
79 Ziyad Tariq 1858/CR3/2010 The fugitive (Ziyad Tariq Al Qattan), in 2004 violated the financial authority entrusted to him when he signed agreement number (T/14 on 11/11/2004)
Abdallah Salih concluded between the Ministry of Defense and Amjad & Sons of Al Rafidain Company to provide the Ministry with Turkish made blankets in the number
Al Qattan of 75,000 blankets at the rate of (22,000) per blanket and a total amount of (one billion and six hundred and fifty thousand dinars). The period for equipping
was 54 days in addition to administrative violations related to the approval, taxes and the stamp fees. The receipts were copies and there is no decision on
how to inspect the material of the contract after its receipt and which is (50,000) pieces and the remaining (25,000) pieces remain unaccounted for. The
evidence gathered are: a statement of the legal representative of the Ministry of Defense, an administrative investigation, a report by the report of the
Financial Oversight Board and the escape of the defendant is sufficient evidence to convict hm by Al Rasafa Criminal Court, which has jurisdiction to try
integrity cases, He was convicted and he was sentenced in absentia to fifteen years in prison, pursuant to article (318) of the Iraqi Penalties Code in case
number (1858/CR3/2010) on 29/9/2010.
80 Ziyad Tariq 635/CR/2017 The Convict (Ziyad Tariq Al Qattan), in 2004 while employed as Deputy Secretary General of the Ministry of Defense committed violations in concluding
Abdallah Salih contracts for the Ministry of Defense. These violations were in the way the contracts were concluded and the way payment were made to contracting
Al Qattan companies despite the fact that the contracts were prepared completely. The evidence gathered against him are: a statement of the legal representative, an
administrative investigation and the report of the Financial Oversight Board and the escape of the defendant is sufficient evidence to convict him. He was
convicted by Al Rasafa Criminal Court, which has jurisdiction to try integrity cases and money laundering and he was sentenced in absentia to three years
in solitary confinement, pursuant to article (331) of the Penalties Code in case number (635/CR/2017) on 29/11/2017.
Case 1:10-cv-01182-RCL Document 436 Filed 07/02/19 Page 19 of 19

Summary of Hazim Al Shaalan Cases

Name Case number Summary of case


1 Hazim Katran 998/CR3/2011 In 2004, while employed as Minister of Defense, and with the participation of other Defendants, the convicted Defendant Hazim Katran Al Shaalan
Al Shaalan distributed residential lands in Baghdad, unlawfully and without legal documentation, to personnel of the Ministry. A verdict was issued sentencing him
in absentia to six years in prison, pursuant to the provisions of article (340) of the Criminal Penalties Code. It was issued by the head of the Criminal Court
in the Federal Courthouse in Rasafa/the Third Committee in case number 998/CR3/2011 on 11/8/2012.
2 Hazim Katran 603/CR3/2010 In 2004[sic], while employed as Minister of Defense, the convicted Defendant Hazim Katran Al Shaalan approved an advance payment to persons affiliated
Al Shaalan with the Ministry of Defense for equipment for demolition and clearing space in the Green Zone for security purposes, because many persons affiliated
with the Ministry had received threats. [The approval was given] in violation of the rules and authorities granted to [the Defendant] and without legal
documentation. Whereas it is clear from the investigation and the trial in absentia that the real estate properties for which the demolition or restoration was
paid in advance did not belong to the Ministry of Defense. Furthermore, there was no legal instrument to govern the clearing of the lots, and the amounts
requested for demolition and restoration were not specified. Likewise, there were discrepancies in the amounts disbursed to each person, thus causing
damage to the Ministry and the waste of public funds, and the person responsible for this is the aforementioned former Minister of Defense. A verdict was
issued sentencing him in absentia to seven years in prison, pursuant to the provisions of article (340) of the Criminal Penalties Code. It was issued by the
head of the Criminal Court in the Federal Courthouse in Rasafa/the Third Committee in case number 603/CR3/2010 on 2/5/2010.
3 Hazim Katran 862/CR3/2010 In the year [sic: no year specified], while employed as Minister of Defense, the convicted Defendant Hazim Katran Al Shaalan approved contracts, numbers
Al Shaalan (39,51,41/2004), concluded between the Ministry of Defense and Al Ain Commercial Company, in violation of the rules. Whereas the amount of the
contract was paid in full to the beneficiary company upon the signing of the contract, but the materials were not received, thus causing damage to the
Ministry’s finances. A verdict was issued sentencing him in absentia to seven years in prison, pursuant to the provisions of article (340) of the Criminal
Penalties Code. It was issued by the head of the Criminal Court in the Federal Courthouse in Rasafa/the Third Committee in case number 862/CR3/2010
on 12/6/2013.
4 Hazim Katran 1682/CR3/2010 The fugitive (Ziyad Tariq Abdallah Al Qattan) together with (Hazim Katram Al Shaalan, Sawsan Jasim Mohamed), intentionally caused financial damage
Al Shaalan to the public in 2004, while employed as Deputy Secretary General of the Ministry of Defense, by cashing (four million three hundred thirty-two thousand
five hundred dollars) from contract number (USMI-5CCONTIGFOB.2), concluded between the Ministry and the Iraqi-American Group, in violation of
financial, accounting, and legal regulations. The exchange took place between (26/12/2004) and (26/2/2005). The evidence gathered against him is:
minutes, case documents, a report by the Financial Oversight Board, and an administrative investigation. He was convicted by the Al Rasafa Criminal
Court, which has jurisdiction to try integrity cases, and he was sentenced in absentia to seven years in prison, pursuant to article (340) of the Criminal
Penalties Code on 2/9/2010, in case number (1682/CR3/2010).
5 Hazim Katran 2804/CR3/2010 In the year [sic: no year specified], while employed as Minister of Defense, the convicted Defendant Hazim Katran Al Shaalan, together with the fugitive
Al Shaalan Defendant Bruska Nouri Shawis, who was employed as former General Secretary of the Ministry, approved the concluding of an unwritten contract with
Hussein Al Wakeel Company to provide the Ministry of Defense with communication devices, in violation of the legal procedures for contracting. They
paid (83595) eighty-three thousand five hundred ninety-five dollars to the aforementioned company, without following financial and accounting regulations
and despite that there were no original documents [acknowledging] receipt of the materials provided and no inspection committee to investigate whether
[the materials] met specifications. Al Rasafa Criminal Court/the Third Committee sentenced the aforementioned Defendant in absentia to seven years in
prison pursuant to the provisions of article (340) of the Criminal Penalties Code on 26/5/2011, in case number 2804/CR3/2010.

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