COUNT ONE

The SPECIAL FEBRUARY 2016 GRAND JURY charges:

1. At times material to this indictment:

a. Defendant SAEED VALADBAIGI, also known as “Saeed Valad” and “Saeed Baigi,” was a resident of Iran and held an Iranian passport.

b. Super Alloys LLC was a company located in Dubai, United Arab Emirates.

c. Emirates Alloys LLC was a company located in Dubai, United Arab Emirates.

d. NBH Industries SDN BHD was a company located in Kuala Lumpur, Malaysia.

e. Georgia Petrochemical and Aviatech was a company located in Tblisi, Georgia.

f. Defendant VALADBAIGI was affiliated with and controlled the operations of Super Alloys, Emirates Alloys, NBH Industries, and Georgia Petrochemical and Aviatech.

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