The Grand Jury charges that:

Count One:

(Conspiracy)

At all times material to this indictment:

A. Introduction

The Defendants

1. Defendant MAHAN AIR was a private Iranian passenger airline located in Tehran, Iran, and organized under the laws of Iran.
2. Defendant KRAL HAVACILIK IC VE DIS TICARET SIRKETI, doing business as KRAL AVIATION, was a company which brokered aircraft parts and related goods on behalf of foreign customers. Defendant KRAL AVIATION was registered in the Republic of Turkey with a mailing address of Florya Senlikkoy Mh. Gumus Sk. Slrln Vlia No: 3/1, 1 Bakukoy-Istanbul, Turkey, and a physical address at EGS Business Park, Ataturk CAD, Blok ln. 12 B2 Blok K6 D234, Bakirkoy, Istanbul, Turkey.

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