Amicus Curiae Brief — Jaffe v. Snow

No. 93-241

»*

A a

IN THE

SUPREME COURT OF THE UNITED STATES

October Term, 1993

Ruth Jaffe,

Petitioner,

v.

Hardy M. Snow, Jr. and Accredited Surety

& Casualty Company, Inc.,

Respondents.

On Petition for a Writ of Certiorari to the District

Court of Appeal of the State of Florida, Fifth District

MOTION FOR LEAVE TO FILE BRIEF AMICUS

CURIAE AND BRIEF OF THE GOVERNMENT OF

CANADA AS AMICUS CURIAE

IN SUPPORT OF PETITIONER

Of Counsel: DOUGLAS E. ROSENTHAI

WILLIAM H. CORBETT, ESQ. Counsel of Record

Senior General Counsel KAY C. GEORGI

Department of Justice COUDERT BROTHERS

Justice Building, Room 459 1627 I Street, N.W.

- 239 Wellington Street Suite 1200

Ottawa, K1A OHS Washington, D.C. 2000

Canada 202) 775-5100

Counsel for the Government

cf Canada Amicus Curiae

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I

TABLE OF CONTENTS

cel Nan tice esas Ca rete Peden eet ees ]

INTERES! OF THe AMICUS CURIAE - oo. .isuc les 2

SRSUR RE TAME SU Bae se Socks cel wane acco ween 3

SA FEMEPADE 0 ADE PUMP EIEN oko oh eens dane deh es 3

PRP E eC eres nu sna ee tee Loe 4

I. THE TRANSBORDER KIDNAPPING CON-

STITUTED AN INFRINGEMENT OF CANA-

DIAN TERRITORIAL SOVEREIGNTY AND

WAS CONTRARY TO THE CANADA-

UNITED STATES EXTRADITION TREATY,

THE SUBSEQUENT CANADA-UNITED

STATES LETTER OF UNDERSTANDING ON

TRANSBORDER KIDNAPPING, AND INTER-

PU Ps BE Cae ee eek cee eee ee ecleas +

Il. THE FLORIDA COURT’S DECISION FAILED

TO ACCORD PROPER WEIGHT TO THE KID-

NAPPING’S VIOLATION OF _ INTERNA-

TIONAL AGREEMENTS AND INTERNA-

STAs PEE Oo ag Sas ea bes Ca eae eet 7

CASTS UIETS 9.0 sin C04 che Ke-aih a oy baa brea Se ee 8

TABLE OF AUTHORITIES

Cases: Page

Jaffe v. Snow, 610 So. 2d 482 (Fla. Dist. Ct. App.

NGL) :s 05 cso ow ald oe ae eee ee ee ee eon 3

Johnson v. Kear, (Ont. H.C. June 9, 1986), aff'd, 5

CCC. (36) 574 COR. fA ee ee reese 5

Kear v. Hilton, 699 F.2d 181, 185 (4th Cir. 1983)....... 5

Rules:

otin. (1. Rs Bad vena vs cena sc rasaver eben ee eee ]

Treaties:

Extradition Treaty Between the United States of Amer-

ica and Canada, 27 U.S.T. 983 (1976) ............. 4

January 11, 1988 Exchange of Letters Constituting an

Understanding Between the Government of Canada

and the Government of the United States of America

Concerning the Protocol Amending the Treaty on

Extradition, 27 L.1.Mi 422 (2980) <a oo eevee eeeees 3,4,6

Protocol Amending the Treaty Between Canada and the

United States of America, 27 I.L.M. 422 (1988).... 4

Other Authority:

Diplomatic Circular from the U.S. Department of State

to the U.S. Chiefs of Mission, (Aug. 17, 1978),

peprindid in, 73 Aan: 3: WO 1 Ta Wee: cae nae aea ence 2

Statement of George P. Shultz, Secretary of State, before

the State of Florida Probation and Parole Commis-

sion In re: Sidney Leonard Jaffe (June 22, 1983)... 5

No. 93-241

IN THE

SUPREME COURT OF THE UNITED STATES

October Term, 1993

Ruth Jaffe,

Petitioner,

Vv.

Hardy M. Snow, Jr. and Accredited Surety

& Casualty Company, Inc.,

Respondents.

On Petition for a Writ of Certiorari to the District

Court of Appeal of the State of Florida, Fifth District

MOTION FOR LEAVE TO FILE BRIEF AMICUS

CURIAE AND BRIEF OF THE GOVERNMENT OF

CANADA AS AMICUS CURIAE

IN SUPPORT OF PETITIONER

MOTION FOR LEAVE TO FILE

BRIEF AMICUS CURIAE

The Government of Canada hereby moves for leave to file

a brief as amicus curiae in support of Petitioner Ruth Jaffe

pursuant to Sup. Ct. R. 37.2. The consent of Petitioner Ruth

Jaffe has been filed with this Court. Remarkably, Respon-

dents, Hardy M. Snow, Jr. and Accredited Surety & Casualty

Company, Inc., have refused their consent to the filing of this

amicus curtae brief. Attached as Exhibit A is the Government

of Canada’s letter to Respondents and Respondents’ response

“vehemently object[ing]’’ to the filing of this brief.

]

5

As this Court is aware, it was the Clerk of this Court who

first requested the U.S. Department of State to inform foreign

governments that they should make their views known to the

Court by filing amicus briefs. In a diplomatic circular to the

U.S. Chiefs of Mission, dated August 17, 1978, the U.S.

Department of State specifically stated:

The United States will consent to such a[n amicus]

filing in any case in which it is a party. Jn the unlikely

event that anv other party should decline to consent,

the Supreme Court will almost certainly grant the

motion of a foreign government for leave to file a

brief. '

Respondents’ refusal to consent to permit the Government of

Canada’s views lacks any justification. The Government of

Canada respectfully requests permission to file this brief so

that the Court can have the benefit of Canada’s views on

important international issues as to which Canada is in a

strong position to comment.

INTEREST OF THE AMICUS CURIAE

The Government of Canada is filing this brief in support

of the Petition for Writ of Certiorari because important

policies of Canada and the United States in deterring trans-

border kidnapping are implicated. Although the judgment

below was purportedly based on the public policy of Florida,

the transborder kidnapping in Canada at issue in this case

constituted both a breach of Canada’s criminal law and a

breach of international law. The Government of Canada

submits that the court below failed to consider the public

policy of the United States as evidenced in the January 11,

1988 Exchange of Letters Constituting an Understanding

Between the Government of Canada and the Government of

the United States of America Concerning the Protocol

Amending the Treaty on Extradition, as well as the principles

of international comity.

1. Reprinted in, 73 Am. J. Int'l. L. 124 (emphasis supplied).

heeiereeeeeseememuneen neces : —

3

STATEMENT OF FACTS

Ruth Jaffe sued the Respondents in the Supreme Court of

Ontario, seeking damages in connection with expenses in-

curred following the wrongful abduction of Sidney Jaffe from

Canada to the United States by United States bounty hunters

hired by the Respondents. On November 22, 1990, the Su-

preme Court of Ontario found in favor of Mrs. Jaffe and

awarded her money judgment.

Mrs. Jaffe then brought an action in the Ninth Judicial

Circuit in and for Orange County, Florida, seeking recognition

and enforcement of the judgment rendered by the Supreme

Court of Ontario. The court entered summary judgment in

favor of the Respondents.

Mrs. Jaffe appealed that ruling to the District Court of

Appeal of the State of Florida, Fifth District, which affirmed

the Circuit Court’s judgment on November 13, 1992.2 A

rehearing was denied on January 12, 1993. A motion to invoke

the jurisdiction of the Supreme Court of Florida was denied on

May 10, 1993.

Mrs. Jaffe petitioned this Court for a writ of certiorari to

the District Court of Appeal of the State of Florida, Fifth

District on August 9, 1993.

SUMMARY OF ARGUMENT

The Government of Canada submits that in determining

public policy, for the purposes of recognizing and enforcing

foreign judgments, United States courts should have regard to

international agreements and principles of international co-

mity, which constitute the public policy of the United States.

The United States Government has undertaken in an Ex-

change of Letters with the Canadian Government to co-

operate to deter transborder kidnapping.* The District Court

. Jaffe v. Snow, 610 So. 2d 482 (Fla. Dist. Ct. App. 1992).

. The January 11, 1988 Exchange of Letters Constituting an Under-

standing Between the Government of Canada and the Government of the

United States of America Concerning the Protocol Amending the Treaty on

Extradition states: ‘*. . . Canada and the United States agree to cooperate

‘a2 tl

4

of Appeal of the State of Florida, Fifth District erred in failing

to take this into account.

ARGUMENT

I. THE TRANSBORDER KIDNAPPING CONSTITUTED

AN INFRINGEMENT OF CANADIAN TERRITORIAL

SOVEREIGNTY AND WAS CONTRARY TO THE

CANADA-UNITED STATES EXTRADITION TREATY,

THE SUBSEQUENT CANADA-UNITED STATES LET-

TER OF UNDERSTANDING ON TRANSBORDER KID-

NAPPING, AND INTERNATIONAL LAW

The Government of Canada’s participation is based in

part on the United States’ position on the issue of transborder

bounty hunting and the reliance Canada may place on the

undertakings of the United States Government to deter such

activities and to exert its best efforts to inform those engaged

in transborder bounty hunting that such activities are illegal

and that offenders will be subject to extradition. It is also

grounded in concerns ahout the effective implementation of

the Canada-United States Extradition Treaty.

The abduction of Sidney Jaffe from his home in Toronto,

Canada to Florida by U.S. bounty hunters hired by the

Respondents was a blatant infringemen: of Canadian territo-

rial sovereignty and was contrary to the Canada-United States

Extradition Treaty and international law.

Transborder bounty hunting has been condemned by the

international community. It is the criminal offence of kidnap-

ping in Canada, the United States and Florida; kidnapping is

an extraditable offence in both countries.4 The Canadian

Government filed formal protests with the United States

Government objecting to the abduction and demanding Mr.

NOTES (Continued)

to deter such transbordcr abductions. . .””. (27 I.L.M. 422 (1988), Appen-

dix B.)

4. See Extradition Treaty Between the United States of America and

Canada, 27 U.S.T. 983 (1976), Appendix A-40, Petitioner’s Brief and

Protocol Amending the Treaty Between Canada and the United States of

America, 27 1.L.M. 422 (1988), Appendix A-42, Petitioncr’s Brief.

5

Jaffe’s release. The United States Department of Justice and

the United States State Department condemned the abduction

of Mr. Jaffe from Canada as a violation of United States public

policy.

The gravity of the incident was recognized by United

States Secretary of State George Shultz in the following

words:

. it 18 perfectly understandable that the Govern-

ment of Canada is outraged by his alleged kidnapping,

which Canada considers a violation of the treaty and of

international law, as well as an affront to its

sovereignty.*

Secretary of State Shultz recognized the serious effect of the

kidnapping on Canada-United States relations. He said:

... the Jaffe case threatens to have a generally

deleterious effect on our relations with Canada.°®

And he stated the public policy of the United States in this

matter as follows:

It is simply in the national interest that this case no

longer be permitted to intrude upon our relations with

one of our most important and highly valued

neighbors... .’

Canada sought extradition of the bounty hunters. The

United States Government refused to excuse or exonerate the

bounty hunters and extradited them to Canada where they

were tried and convicted.® Extradition to Canada from Florida

was not dvenied by the United States Government or the

Florida Courts because of any activities that may have been

undertaken by Mr. Jaffe in Florida. The bounty hunters hired

5. Statement of George P. Shultz, Secretary of State, before the State

of Florida Probation and Parole Commission In re: Sidney Leonard Jaffe,

2-3 (June 22, 1983) (attached as Appendix C).

6. ld.

7. Id.

8. Kearv. Hilton, 699 F.2d 181, 185 (4th Cir. 1983); Johnson v. Kear,

(Ont. H.C. June 9, 1986), aff'd, § C.C.C. (3d) 574 (Ont. C.A. 1989).

6

by the Respondents were convicted; no justification for their

actions could be found by the court in any activities carried

out by Mr. Jaffe in Florida.

The policy of the United States Government concerning

transborder bounty hunting is demonstrated in the January 11,

1988 Exchange of Letters Constituting an Understanding

Between the Government of Canada and the Government of

the United States of America Concerning the Protocol

Amending the Treaty on Extradition (the ‘‘Canada-United

States Letter of Understanding’’).* The Canada-United States

Letter of Understanding, signed by the United States Secre-

tary of State and the Canadian Secretary of State for External

Affairs, reads in part as follows:

The United States and Canada recognize that the

transborder abduction of persons found in Canada to

the United States of America by civilian agents of

bail-bonding companies . . . is an extraditable offense

under the United States-Canada Extradition Treaty.

Both countries agreed to take action against transborder

bounty hunting:

. .. Canada and the United States agree to cooperate

to deter such transborder abductions. .

Of particular relevance in the petition is the undertaking made

in the letter by the United States to Canada, which reads as

follows:

[T]he United States will continue to exert its best

efforts to inform those engaged in business as bail-

bondsmen or bounty hunters . . . of the positions set

forth in this exchange of letters.

This policy applies to persons found in Canada irrespec-

tive of citizenship.

Il. THE FLORIDA COURT’S BECISION FAILED TO AC-

CORD PROPER WEIGHT TO THE KIDNAPPING’S

VIOLATION OF INTERNATIONAL AGREEMENTS

AND INTERNATIONAL COMITY.

Florida did not petition the United States government to

request Mr. Jaffe’s extradition, and Canada did not refuse a

request for Mr. Jaffe’s extradition. This is not a case where

the extradition process was tried and failed. There was no

justification for extraordinary measures to be taken; Florida

has used the Treaty successfully before and since the Jaffe

instance to obtain the return of fugitives. The Court of Appeal

failed to give effect to the Letter of Understanding and the

Extradition Treaty.

Canada has a right to rely on the undertaking set out in

the Canada-United States Letter of Understanding. The

judgement of the Florida Court of Appeals failed to take into

account the undertakings of the United States Government.

The Canada-United States Letter of Understanding should be

respected and given consideration by United States courts in

the determination of public policy as it relates to the question

of recognizing and enforcing the judgment of the Supreme

Court of Ontario.

8

CONCLUSION

In reaching its decision, the Florida Court of Appeal

failed to consider the public policy of the United States

concerning transborder kidnapping. This is an important issue

of national and international public policy which should be

considered. Accordingly, the petition for a writ of certiorari

should be granted.

Respectfully submitted,

Of Counsel: DOUGLAS E. ROSENTHAL

WILLIAM H. CORBETT, ESO. Counsel of Record

Senior General Counsel! KAY C. GEORGI

Department of Justice COUDERT BROTHERS

Justice Building, Room 459 1627 I Street, N.W.

239 Wellington Street Suite 1200

Ottawa, K1A OH8 Washington, D.C. 20006

Canada (202) 775-5100

Counsel for the Government

of Canada Amicus Curiae

September 8, 1993

PS

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APPENDIX A

COUDERT BROTHLRS

Attorneys and Counselors At Law

1627 I STREET, N.W.

WASHINGTON, D.C. 20006

TEL: (202) 775-5100

TLX: 248594 CLAW UR

FAX: (202) 775-1168

September 1, 1993

BY FACSIMILE AND MAIL

Sharon Lee Stedman, Esq.

1516 E. Hillcrest Street

Suite 200

Orlando, FL 32803

Re: Ruth Jaffe v. Hardy M. Snow, Jr. & Accredited

Surety & Casualty Company, Inc., No. 93-24]

Dear Ms. Stedman:

We are writing you on behalf of the Government of

Canada to request the consent of Respondents, Hardy M.

Snow, Jr. and Accredited Surety & Casualty Company, Inc.,

to the filing by the Government of Canada of an amicus curiae

brief in support of the petition for writ of certiorari in the

above referenced case. In view of the very tight filing deadline

we would appreciate your sending us the consent in writing by

facsimile and courier within the next 48 hours.

We have been advised that your clients may not consent

to the Government of Canada’s amicus brief. If your clients

do not wish to consent, would you please advise us of their

reasons for not consenting.

Thank you for your cooperation.

Sincerely,

s/ Douglas E. Rosenthal

Kay C. Georgi

Douglas E. Rosenthal

Kay C. Georgi

APPENDIX A (Cont’d)

LAW OFFICES

SHARON LEE STEDMAN, P.A.

Sharon Lee Stedman 1516 E. Hillcrest

Attorney at Law Suite 200

Orlando, Florida 32803

(407) 894-7844

FAX (407) 894-3142

September 2, 1993

Via Fax No. 202-775-1168

Mr. Douglas E. Rosenthal

Ms. Kay C. Georgi

Coudert Brothers

1627 I Street, N.W.

Washington, D.C. 20006

Re: Ruth Jaffe v. Hardy M. Snow, Jr. and Accredited

Surety & Casualty Company, Inc. No. 93-241

Dear Mr. Rosenthal and Ms. Georgi:

This is to acknowledge your facsimile to me of September

1, 1993, requesting the respondents’ consent to the filing of an

amicus curiae brief in support of the petition for writ of

certiorari by the Government of Canada in _ the

above-referenced case. Please be advised that the respon-

dents vehemently object to this filing. In addition, I believe

that the time has expired for any such filing.

Please let me know if I can be of any further assistance.

Sincerely yours,

/s/ Sharon Lee Stedman

SLS/msw

——————————

APPENDIX A (Cont’d)

LAW OFFICES

SHARON LEE STEDMAN, P.A.

Sharon Lee Stedman 1516 E. Hillcrest

Attorney at Law Suite 200

Orlando, Florida 32803

(407) 894-7844

FAX (407) 894-3142

September 3, 1993

Via Fax No. 202-775-1168

Mr. Douglas E. Rosenthal

Ms. Kay C. Georg!

Coudert Brothers

1627 I Street, N.W.

Washington, D.C. 20006

Re: Ruth Jaffe v. Hardy M. Snow, Jr. and Accredited

Surety & Casualty Company, Inc. No. 93-241

Dear Mr. Rosenthal and Ms. Georgi:

Subsequent to my letter and facsimile to you of Septem-

ber 2, 1993, I have learned that the filing of an amicus curiae

brief can be filed with the response in opposition to the

petition for writ of certiorari, contrary to my understanding

that it had to be filed at the time that the petition for writ of

certiorari was filed. Nevertheless, the respondents still vehe-

mently object to any such filing.

Sincerely yours,

/s/ Sharon Lee Stedman

SLS/msw

APPENDIX B

Letter of Secretary Shultz, ’anuary 11, 1988

THE SECRETARY OF STATE

WASHINGTON

January 11, 1988

Dear Mr. Minister:

I refer to the Protocol Amending the Treaty on Extradi-

tion between the United States and Canada we signed today

and have the honor to address to you the following.

The United States and Canada recognize that the trans-

border abduction of persons found in Canada to the United

States of America by civilian agents of bail bonding compa-

nies, so-called ‘‘bounty hunters’’, is an extraditable offense

under the United States — Canada Extradition Treaty.

Where a person has been charged with or convicted of

such an offense in Canada and is found within the jurisdiction

of the United States, the United States agrees, upon request,

to commence extradition proceedings against such a person

pursuant to the Treaty in order that the person may be

returned to Canada.

The United States will use its best efforts to honor

Canadian requests for testimony, information, or other assis-

tance pertaining to such abductions.

Canada and the United States agree to cooperate to deter

such transborder abductions. To assist in achieving that

purpose, the United States will continue to exert its best

efforts to inform those engaged in business as bail bondsmen

or bounty hunters and other interested parties of the positions

set forth in this exchange of letters.

Canada and the United States agree to consult promptly

concerning any case of transborder abduction involving

bounty hunters which might arise in the future. The purpose

of such consultation shall be to address matters relating to any

such case, including any request by the Government of

Canada for the return of the person so abducted. In the event

of return, the Governments agree to co-operate to have the

abducted person escorted to Canada and taken into custody at

the border, pursuant to a request for provisional arrest,

pending the outcome of extradition proceedings. For the

purpose of these consultations, the principal law enforcement

contact for the United States will be the Director of the Office

of International Affairs of the Criminal Division of the De-

partment of Justice.

The Right Honorable

Joe Clark, P.C., M.P.,

Secretary of State

For External Affairs of Canada,

Ottawa.

I have the honor to propose that this letter and your reply

constitute an understanding between our two Governments

which is not intended to create or otherwise alter legal

obligations for either Government nor to create or otherwise

alter any rights or privileges for private parties.

Sincerely yours,

/s/_ George P. Shultz

George P. Shultz

APPENDIX B (Cont’d)

Letter of Secretary Clark, January 11, 1988

THE RT. HON. JOE CLARK, P.C., M.P.

SECRETARY OF STATE FOR EXTERNAL AFFAIRS

CANADA

Ottawa, January 11, 1988

JLA-0026

Dear Mr. Secretary:

I have the honour to acknowledge receipt of your letter of

today’s date concerning transborder abduction of persons

found in Canada to the United States of America by civilian

agents of bail bonding companies, so-called ‘“‘bounty hunt-

ers’’. I accept your proposal that your letter and this reply

constitute an Understanding between our two Governments

which is not intended to create or otherwise alter legal

obligations for either Government nor to create or otherwise

alter any rights or privileges for private parties.

Yours sincerely,

/is/ Joe Clark

The Honorable George P. Shultz

Secretary of State of the

United States of America

3

:

APPENDIX C

Statement of Secretary Shultz, June 22, 1983

STATE OF FLORIDA

PROBATION AND PAROLE COMMISSION

IN RE: SIDNEY LEONARD JAFFE

INMATE #082007

STATEMENT OF GEORGE P. SHULTZ,

SECRETARY OF STATE

I urge you to grant parole to Sidney Jaffe on the ground

that his continued incarceration will exacerbate the already

severe Strain placed on the relations of the United States with

Canada arising out of circumstances under which Mr. Jaffe

was returned from Canada to Florida to face the charges

which resulted in his imprisonment.

The circumstances of Mr. Jaffe’s return from Canada to

Florida were examined in the opinions of the United States

Court of Appeals for the Fourth Circuit and the United States

District Court for the Middle District of Florida in the cases of

Daniel Kear and Timm Johnsen, respectively. In brief, the

courts found that Kear and Johnsen were extraditable to

Canada, a showing having been made of probable cause to

believe that the two ‘‘bounty hunters,’’ who were acting as

agents of the company that had posted bond for Mr. Jaffe, had

kidnapped Jaffe in Toronto, Canada and had brought him back

to Florida.

The United States has an extradition treaty with Canada.

That treaty could have been utilized to secure Mr. Jaffe’s

return; no one has suggested the contrary. How, then, did it

happen that Mr. Jaffe was returned by Kear and Johnsen?

Canada, in a petition for writ of habeas corpus filed in the

United States District Court for the Middle District of Florida,

alleges that Kear and Johnsen were “‘acting pursuant to a plan

promoted by officials of th® State of Florida and under the

color of authority of the State of Florida.’’ The officials of the

State of Florida whose conduct has been called into question

by Canada deny the charges, I understand, and I do not now

take any position on the question whether there was state

action or involvement in the alleged kidnapping of Mr. Jaffe.

However, failure to utilize our extradition treaty with

Canada to secure Mr. Jaffe’s return does appear to be

attributable to the Office of State Attorney Stephen L. Boyles,

according to the report to Governor Graham prepared by the

Governor’s General Counsel. On May 18, 1981, when Mr.

Jaffe failed to appear, Judge Perry ordered the State Attorney

to initiate extradition proceedings. Any request for Mr. Jaffe’s

extradition would have been made by the Governor on the

basis of supporting materials prepared by the State Attorney’s

office. Documents submitted by the State Attorney’s office

were found by the Governor’s office to be legally insufficient

to support a request for Mr. Jaffe’s extradition on July 2, and

again on July 23, 1981. Mr. Jaffe was returned from Canada

under the circumstances of which Canada complains on

September 24, 1981. In the intervening two months the State

Attorney’s Office failed to make any further effort to submit

legally sufficient documentation to the Governor’s office in

support of a request for Mr. Jaffe’s extradition.

As no good reason appears why the extradition treaty

was not utilized to secure Mr. Jaffe’s return, it is perfectly

understandable that the Government of Canada is outraged by

his alleged kidnapping, which Canada considers a violation of

the treaty and of international law, as well as an affront to its

sovereignty.

I wish to emphasize that Canada is our most important

extradition treaty partner and that the maintenance of the

excellent extradition relationship we have had with Canada is

greatly in the law enforcement interest of Florida and the

other states, as well as of the federal government. Indeed, in

the last three full calendar years, sixty per cent of the fugitives

surrendered to the United States pursuant to extradition

requests made by states, as opposed to the federal govern-

ment, were surrendered by Canada.

Moreover, quite apart from law enforcement coopera-

tion, the Jaffe case threatens to have a generally deleterious

effect on our relationships with Canada. Canadian authorities

have raised this matter in virtually every recent high level

contact between our two nations. It is simply in the national

interest that this case no longer be permitted to intrude upon

our relations with one of our most important and highly valued

neighbors, allies and trading partners.

For the foregoing reasons, I urge you to grant parole to

Sidney Jaffe.

s/ George P. Shultz

GEORGE P. SHULTZ

Secretary of State

July 22, 1983

Date