AS DISCOVERY LIKELY MOVES FORWARD IN THE MULTI-BILLION DOLLAR CBI FRAUD SCANDAL, WILL B OF A TAKE ACTION TO CLOSE THOSE HIGH-RISK CORRESPONDENT ACCOUNTS?

In the §782 Discovery proceeding, pending in the Southern District of Florida, the Applicants have filed their RESPONSE IN OPPOSITION TO APPLICANTS' RENEWED APPLICATION AND, ALTERNATIVELY, MOTION FOR PROTECTIVE ORDER, which seeks to obtain records from Bank of America, N.A., to be used to defend against a Defamation proceedings abroad. Truth is an absolute truth to defamation, and the Applicants have asserted that bank records will prove that they have made truthful statements about fraud, which by definition, are not defamatory.

Here is a summary of their Response:

(1) The statutory requirements of §782 have been met.

(2) The discretionary factors all weigh in favor of granting the Application.

(3) There were no abuses arranting denial of the Application.

(4) the Motions for a Protective Order should be denied.

A fair reading of the Response indicates that the Application has merit, and is therefore likely to be granted, and a subpoena to Bank of America for records of CARIBBEAN GALAXY REAL ESTATE CORPORATION and TIMOTHY HARRIS is expected to issue. The potential regulatory and legal consequences for B of A, should the allegations of the MSR plaintiffs in the RICO case, cannot be minimized. The bank's correspondent accounts for Caribbean financial institutions in the EC states that have Citizenship by Investment passports, exposed as the result of the §782 proceeding,are alleged to contain evidence of massive and rampant CBI fraud.

Additionally, we note that RICO defendant LESLIE KAHN a/k/a LES KHAN, the longtime head of St. Kitts' Citizenship by Investment program, and subsequently the CEO of CARIBBEAN GALAXY, and who was originally a Vice President at Bank of America, has disappeared, and cannot be found for the purpose of serving him with the Complaint. His relationship with B of A's correspondent banking unit, in light of his prior employment there, deserves an independent investigation to rule out whether any possible criminal conduct occurred.

Finally, one has to wonder what former Prime Minister Timothy Harris and Caribbean Galaxy are so afraid of that MSR can find out in the Bank of America accounts.

When risk levels reach the point where continuing with a correspondent banking relationship, already assessed as high-risk, constitutes an unacceptable level of risk, with potential exposure to additional unknown clear and present dangers, prudent managers take action. We are waiting to see someone exercise some leadership in this situation.