Lab theory, 15–16 June, press · p.82
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C+9:Y*3
b6
~6/16/82
b7c
Approved:
Assistant United Statcs Attorney
Before:
Honorable Harold Raby
82.903.
United States Magistrate
Southcrn District of New York
X
UNITED STATES OF AMERICA
：
：
COMPLAINT
：
Violation of
b6
18 u.S.C. s371
b7c
a/k/a
bcing the
NEw Yock Courty
person depicted in the photograph:
annexed to this complaint as
Exhibit l, and
：
a/k/a
being the
person depicited in the
：
photographannexcdtothis
complaint as Exhibit 2,
Defendants.
X
SOUTHERN DISTRICT OF NEW YORK,SS.:
being duly sworn, deposcs and
b6
says that he is a Spccial Agent of the Federal Bureau of Investi-
b7c
gation and chargcs as.follows:
From on or about January l, 1982 up to and including the
date of filing.of this complaint.in the Southern Districr of New
York,and elsewhere,
b6
a/k/a
beingthepersondepictedinthephotograph.
b7c
annexed to this complaint as Exhibit l, and
a/k/a
being the person dcpicitcd in the photograph annexed to
thxs complaint as Exhibit 2,the dcfendants, and others to the
undersigned known and unknown,unlawfully,wilfuliy and knowingly
did combine, conspire,confederate and agree together and with
each other to commit offenses against the United States, to wit,
to violate the provisions of thc federal explosive materials,
firearms and arms export control laws, as set forth in Title'18,
United States Code, Sections 842, 844 and 922; Title 18, United
States Code Appendix, Section 1202; Title 22, united States Code,
Section 2778 and the regulations promulgated'thereunder, 22 CFR
ss 121.0l et se9; and Title 26, United States Code, Section 5861.
OBJECT OF THIS CONSPIRACY
It was the principle object of this conspiracy that the
defendants and thcir co-conspirators, being_members and persons
associated with the Provisional Irish Republican Army (PiRA) --
the military wing of thc Irish Republican Army.-- would and did
negotiate for, and attempt to secure, the purchase of military
weapons and equipment in the United States, in particular, five
Redeye type surface to air missles, for export by them and persons
associated with them to PiRA forces located in Northern Ireland,
b6
~6/16/82
b7c
Approved:
Assistant United Statcs Attorney
Before:
Honorable Harold Raby
82.903.
United States Magistrate
Southcrn District of New York
X
UNITED STATES OF AMERICA
：
：
COMPLAINT
：
Violation of
b6
18 u.S.C. s371
b7c
a/k/a
bcing the
NEw Yock Courty
person depicted in the photograph:
annexed to this complaint as
Exhibit l, and
：
a/k/a
being the
person depicited in the
：
photographannexcdtothis
complaint as Exhibit 2,
Defendants.
X
SOUTHERN DISTRICT OF NEW YORK,SS.:
being duly sworn, deposcs and
b6
says that he is a Spccial Agent of the Federal Bureau of Investi-
b7c
gation and chargcs as.follows:
From on or about January l, 1982 up to and including the
date of filing.of this complaint.in the Southern Districr of New
York,and elsewhere,
b6
a/k/a
beingthepersondepictedinthephotograph.
b7c
annexed to this complaint as Exhibit l, and
a/k/a
being the person dcpicitcd in the photograph annexed to
thxs complaint as Exhibit 2,the dcfendants, and others to the
undersigned known and unknown,unlawfully,wilfuliy and knowingly
did combine, conspire,confederate and agree together and with
each other to commit offenses against the United States, to wit,
to violate the provisions of thc federal explosive materials,
firearms and arms export control laws, as set forth in Title'18,
United States Code, Sections 842, 844 and 922; Title 18, United
States Code Appendix, Section 1202; Title 22, united States Code,
Section 2778 and the regulations promulgated'thereunder, 22 CFR
ss 121.0l et se9; and Title 26, United States Code, Section 5861.
OBJECT OF THIS CONSPIRACY
It was the principle object of this conspiracy that the
defendants and thcir co-conspirators, being_members and persons
associated with the Provisional Irish Republican Army (PiRA) --
the military wing of thc Irish Republican Army.-- would and did
negotiate for, and attempt to secure, the purchase of military
weapons and equipment in the United States, in particular, five
Redeye type surface to air missles, for export by them and persons
associated with them to PiRA forces located in Northern Ireland,