Karen Hudes Tue, Feb 5, 2013 at 7:10 AM To: iansolomon

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Karen Hudes Tue, Feb 5, 2013 at 7:10 AM

To: iansolomon@worldbank.org [Executive Director for the United States on the World Bank Board]

Bcc: Government in the Middle East

Dear Mr. Solomon,

The stakeholder analysis referred to in the attached article has been guiding my efforts since 2004 in forming a coalition for the rule of law. During these years, I have been in contact with the

Committees in the US Congress responsible for oversight of the World Bank, as well as other legislatures, oversight agencies and regulators.

The United States' resistance to the Board of Governors' decision to bring the World Bank into compliance is futile at this point. Further brinksmanship only increases the risks of a further reduction in the US' credit rating and a currency war.

Sincerely,

Karen Hudes

Law Offices of Karen Hudes

202 316 0684

---------- Forwarded message ----------

From: Karen Hudes

Date: Tue, Feb 5, 2013 at 5:05 AM

Subject: Rule of Law in Bretton Woods

To: jpia.club@nyu.edu, onlineforum@nyujilp.org

Cc: Jacek Kugler, University of Amsterdam Game Theory Modeler

Dear JILP,

I have not heard back whether you have accepted the article on Rule of Law in Bretton Woods which

I submitted to you on October 31, 2012 for publication in NYU's Journal of International Law and

Politics https://s3.amazonaws.com/khudes/Article2.2.doc

My litigation in the DC Circuit Court of Appeals is now before the Judicial Conference and the

Conference of Chief Justices. The stakeholder analysis' prediction that countervailing coalitions in favor of the rule of law will develop (page 4, footnote 11) has been borne out by events:

Since my submission, the UK Parliament has published a second statement: http://www.publications.parliament.uk/pa/cm201213/cmselect/cmpubadm/writev/publicpolicy/m03.htm

[and now a third statement (see pages 178; 186-7): http://www.parliament.uk/documents/commons-committees/publicadministration/Complaints%20Consolidated%2024%20July.pdf

On January 14, 2013 Germany announced that it will repatriate 674 tons of gold valued at $17.9 billion. This sends a strong signal to the Judicial Conference of the United States that decisions of the Board of Governors of the World Bank are to be respected and implemented.

https://docs.google.com/file/d/0Bzss7Q0pShvzS2Npbk9lV0xkWkk/edit

Please let me know whether I should update the article to include the developments since submission of the first draft or whether I am free to submit the article for publication elsewhere.

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Sincerely,

Karen Hudes

Law Offices of Karen Hudes www.kahudes.net

-----Original Message-----

From: kahudes

To: richard.fleck <richard.fleck@hsf.com>

Sent: Mon, Feb 4, 2013 2:48 pm

Subject: Financial Reporting Council

Dear Mr. Fleck,

I regret the formatting difficulties. I am currently in contact with 600,000+ members of the

National Taxpayers Union, which published a blog on my report of internal control lapses at the World Bank: http://www.ntu.org/governmentbytes/governmentreform/whistleblower-protections-a1220.html

The World Bank Board of Governors settled my litigation in the US Court of Appeals. I have requested the US Judicial Conference to correct court records:

http://kahudes.net/wp-content/uploads/2013/01/ljudicialconference1.pdf and informed the Chief

Justices of State Supreme Courts: https://docs.google.com/file/d/0Bzss7Q0pShvzS2Npbk9lV0xkWkk/edit

On January 22, 2013 Deanna Spingola interviewed me on her radio program: http://kahudes.net/wp-content/uploads/2013/01/Spingola_1_012213_110000.mp3 http://kahudes.net/wp-content/uploads/2013/01/Spingola_2_012213_120000.mp3

Sincerely,

Karen Hudes

Law Offices of Karen Hudes www.kahudes.net

From: "Fleck, Richard" <Richard.Fleck@hsf.com>

Date: 1 October 2012 12:56:50 BDT

To: Elaine Colville

Subject: Request for FRC Investigation of Deloitte and KPMG for deficient audits of World Bank Group.

Dear Ms Colville,

I am writing to confirm that your emails dated 29 august, 9 September and 1 October have been passed to me and that the matters that you have raised are being looked into to determine the appropriate approach to be taken by the Financial Reporting Council.

I will be in touch as soon as we have completed our review of the information you have provided.

Regards

Richard Fleck

Chairman, FRC Conduct Committee.

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-----Original Message-----

From: kahudes

To: raymondgreenburgh Cc: dhkeare56 <dhkeare56@earthlink.net>; brian_appel

<brian_appel@bennet.senate.gov>; Angie.Williams <Angie.Williams@icaew.com>; fcc

<fcc@fsa.gov.uk>; consumer.queries <consumer.queries@fsa.gov.uk>; ianball <ianball@ifac.org>; patrick_miller <patrick_miller@jec.senate.gov>; thomas_caballero

<thomas_caballero@legal.senate.gov>; bill_dauster <bill_dauster@reid.senate.gov>; keith_luse

<keith_luse@foreign.senate.gov>; doug.centilli <doug.centilli@mail.house.gov>; james_brown

<james_brown@casey.senate.gov>; conor_carroll <conor_carroll@jec.senate.gov>; aurie_rubiner

<aurie_rubiner@blumenthal.senate.gov>; jmcpherson <jmcpherson@naag.org>; enquiries

<enquiries@frc.org.uk>; fergusonl <fergusonl@pcaobus.org>; djz-ir <djz-ir@minbuza.nl>;

Jonathan_Davidson <Jonathan_Davidson@Bennet.senate.gov>

Sent: Mon, Feb 4, 2013 12:30 pm

Subject: Re:

Raymond,

Dr. Kim does not need to stand down. He simply needs to play by the rules. A mutual acquaintance, Douglas Keare, whom I worked with at the World Bank 15 years ago, contacted me six months ago, asking me to help "this good man to succeed for every possible reason."

I and IBRD's other $135 billion worth of bondholders are entitled to accurate financial statements.

I am bringing the accounting profession back into the hopefully prompt resolution of this matter.

Best,

Karen

Law Offices of Karen Hudes www.kahudes.net

-----Original Message-----

From: raymondgreenburgh

To: Karen Hudes

Sent: Mon, Feb 4, 2013 10:18 am

Subject: Re: Your news

Dear Karen

Your latest e-mail puts your case most succinctly.

If Kim stands down matters will probably resolve positively. Unhappily few people holding high and lucrative office resign out of any sense of duty or obligation. They have to be forced to leave office and rely on inertia to retain position. In the case of multinational organizations, the incumbent of a leading Office believes that resignation is a betrayal of his country who first proposed him for the post. Rationality takes a back seat.

Your best bet is to motivate the Board of Governors to maintain pressure on Kim bur that is a hard row to hoe.

Fond wishes

Raymond

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From: Karen Hudes

Date: Mon, 4 Feb 2013 09:10:15 -0500 (EST)

To: Raymond Greenburgh

Subject: Re: Your news

Dear Raymond,

It is not up to me to propose any compromise. I am simply the canary in the coal mine. My case is a proxy for rule of law.

The US public does not know of a secret US hegemony at the World Bank and would not approve of it. The US Congress has spoken decisively on this point. We are dealing with a cover up of corruption: nothing more and nothing less. The 50 states are together with the US Congress and the rest of the world in fighting this corruption.

Do the corrupt persons want to relinquish their plunder? The German Government has now given them a clear ultimatum which they are powerless to counter. Their only hope is to continue to misinform the American public. But I have a clear line of communication now through the taxpayers associations. The writing was on the wall when the US lost the Gentlemen's Agreement to name the

President of the World Bank. What follows is simply implementation.

Either there is rule of law or there is a currency war. After the UK Parliament published my statement, it simply is a matter of sequencing. Yesterday I faxed the Chief Justices of the State

Supreme Court to bring them up to date.

As to whether I continue in office after my reinstatement: as I told Eugene Miagkov when he reinstated me as the Acting General Counsel of the International Bank for Reconstruction and

Development in 2009--I would serve at the pleasure of the Board of Executive Directors and Board of Governors.

The agreement that the Board of Executive Directors simply votes up or down what the President proposes actually ended along with the Gentlemen's Agreement--the US would not live with this arrangement if it did not hold the Presidency of the World Bank.

Last week-end I met some national security whistleblowers. The battle against corruption and state capture in the US is what is holding up the settlement of my case. Dr. Kim is loathe to move until that battle is clearly decided. At this rate, Dr. Kim may not be able to hang on long enough to maintain his presidency.

Best,

Karen

-----Original Message-----

From: raymondgreenburgh

To: Karen Hudes

Sent: Mon, Feb 4, 2013 5:30 am

Subject: Your news

Dear Karen

Thank you for your update. Why is Kim resisting the Board of Governors decision? Does he think that the Board will not make his refusal to

4

reinstate a resigning matter?

Cannot this matter be resolved in such a way that no one loses?

Fond wishes

Raymond

---------- Forwarded message ----------

From: Karen Hudes

Date: Fri, Feb 1, 2013 at 8:10 AM

Subject: update

To: senseoncents@aol.com

Dear Larry,

A UK lawyer advised me to involve the credit rating agencies a year ago. Here is recent correspondence with the American Bar Association and US Congress. There is now a 95% chance that there will be an end to the corruption that has been plaguing the US and the rest of the world.

Best,

Karen cell 202 316 0684

---------- Forwarded message ----------

From: Karen Hudes <h.k3511@gmail.com>

Date: Fri, Feb 1, 2013 at 8:01 AM

Subject: American Bar Association and the National Dialogue

To: abapresident@americanbar.org

Cc: Aaron Schildhaus <schildhaus@earthlink.net>, Carol Mates

<cmmates@gmail.com>, christian.ahlund@ilac.se, mparish@gmail.com, janet.jackson@americanbar

.org, bill.pritchard@americanbar.org

Dear Ms. Bellows,

Your President's message at the beginning of 2013 is very apropos:

" The American Bar Association has always been at the forefront in discussing issues that affect the legal profession. For this reason, our association has assembled the Cybersecurity Legal Task Force and charged it with examining ways to help lawyers protec t their practices and their clients’ confidential information and intellectual property. The task force will also position the ABA to contribute to the national dialogue about cyberissues."

The American Bar Association has been at the center of these issues for many years.

Sincerely,

Karen Hudes

Law Offices of Karen Hudes www.kahudes.net

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---------- Forwarded message ----------

From: Karen Hudes

Date: Fri, Feb 1, 2013 at 7:43 AM

Subject: Oversight

To: David_Young@grassley.senate.gov, Leah_Shimp@grassley.senate.gov, Kolan_Davis@grassley.

senate.gov, Jill_Kozeny@grassley.senate.gov, Julia_Frifield@mikulski.senate.gov, Shannon_Kula@ mikulski.senate.gov, Catie_Finley@mikulski.senate.gov, Jean_Doyle@mikulski.senate.gov, Rachel_

MacKnight@mikulski.senate.gov

Cc: sharon.raj@fitchratings.com, "rebecca.mirza" <rebecca.mirza@fitchratings.com>,

"elizabeth.mccarroll" <elizabeth.mccarroll@moodys.com>, "jamie.kogan"

<jamie.kogan@moodys.com>, rosaleen_manzi <rosaleen_manzi@sandp.com>, "trevor.pijper"

<Trevor.Pijper@moodys.com>, Paul_Coughlin@standardandpoors.com

Dear Messrs. Young, Davis, and Mesdames Shimp, Kozeny, Frifeld, Kula, Finley, Doyle, and

MacKnight,

Senators Grassley and Mikulski have been helping ever since I first contacted Congress on these rule of law issues.

http://www.ntu.org/governmentbytes/government-reform/whistleblower-protections-a1220.html

Sincerely,

Karen Hudes

From: kahudes@aol.com

To: geraldine.dufort@ec.europa.eu

Sent: Fri, 7 Mar 2008 3:47 pm

Subject: Re: World Bank Governance

Geraldine,

I am a US lawyer who studied development economics at the University of Amsterdam and worked in the legal department of the World Bank for many years. I was fired for insisting that the US leadership at the Bank respect the rules. In December 2006 I informed Mr. Wijffels, the Dutch

Executive Director, that I would alert the US government about a crisis in governance at the World

Bank. In September 2007 Ms. Riny Bus of the Dutch Ministry of Foreign Affairs suggested that I involve the Washington office of the EU, and I have been informing Mr. Nagarajan about my progress.

I believe that I have succeeded in impressing upon the US Congress about the severity of the crisis, and next week I am meeting with representatives on the House of Representatives appropriations committee in advance of their meeting with the US Treasury Department. I am also scheduled to meet with a representative on the Senate Finance Committee. This Committee oversees the Treasury Department.

At these meetings, I would like to speak authoritatively about the European Union's position on the need to restore rule of law at the World Bank and the concrete steps to be taken.

Sincerely,

Karen Hudes

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---------- Forwarded message ----------

From: Karen Hudes

Date: Fri, Feb 1, 2013 at 7:08 AM

Subject: Oversight of the Broadcasting Board of Governors

To: Kate.Barlow@mail.house.gov, Michael.Ahern@mail.house.gov, Audra.McGeorge@mail.house.go

v

Dear Ms. Barlow, Mr. Ahern, and Ms. McGeorge,

I also forwarded this to other members of the House Committee on Foreign Affairs.

An email to the Broadcasting Board of Governors is at the foot of this string of emails; I will be happy to provide additional correspondence with the Broadcasting Board of Governors.

Sincerely,

Karen Hudes

Law Office of Karen Hudes

202 316 0684

---------- Forwarded message ----------

From: Karen Hudes

Date: Wed, Jan 30, 2013 at 3:28 AM

Subject: Oversight of the Broadcasting Board of Governors

To: "Fridman, Ari" <ari.fridman@mail.house.gov>, amy.porter@royce.house.gov

---------- Forwarded message ----------

From: Karen Hudes <h.k3511@gmail.com>

Date: Tue, Jan 29, 2013 at 6:22 AM

Subject: Fwd: Keeping you posted

To: ombudsman <ombudsman@npr.org>

WAMU suggested that I contact NPR on this.

---------- Forwarded message ----------

From: Karen Hudes <h.k3511@gmail.com>

Date: Tue, Jan 29, 2013 at 6:09 AM

Subject: Keeping you posted

To: rblatt@wamu.org, insight@wamu.org

Dear Rebecca,

Since you requested an update, I will also forward you today separately my email to the SEC. How the press informed the American public as this story developed over the past ten years is perhaps the biggest part of the story, and one which WAMU can certainly participate in if you look back through your correspondence files.

Sincerely,

Karen Hudes

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From: insight@wamu.org

To: karenhudes

Subject: WAMU General Query

Date: Mon, 28 Jan 2013 12:52:13 -0500

Dear Karen,

Thanks so much for sharing all of this information. As the local station here, we generally let NPR cover World Bank issues, but please keep us posted as this moves along.

Best,

Rebecca--

Rebecca Blatt

Senior News Editor - Special Projects

WAMU 88.5 News

(202) 885-1233 (Newsroom)

(202) 494-8755 (Cell) rblatt@wamu.org

---------- Forwarded message ----------

From: Karen Hudes

Date: Mon, Jan 28, 2013 at 4:12 AM

Subject: Rule of Law

To: mike.heavican@nebraska.gov

Cc: andrew.lippstone@state.de.us, dquam@nga.org, geoffrey.harris@ep.europa.eu, CAB-ASHTON-

ARES@ec.europa.eu, sintonb@parliament.uk

Dear Justice Heavican,

I am contacting you as President-Elect of the Conference of Chief Justices to inform you about a governance crisis. I faxed background information on December 14, 2012, to the 51 Chief Justices comprising the CCJ.

Please contact Governor Markell, President of the National Governors Association. The 188 member countries of the World Bank are aware of this matter; I am copying the European Union and the Parliament of the United Kingdom, which are assisting.

Sincerely,

Karen Hudes

202 316 0684

---------- Forwarded message ----------

From: Karen Hudes

Date: Fri, Jan 25, 2013 at 9:02 AM

Subject: Compliance of the World Bank

To: National Taxpayers Union

Cc: Sattler Robert

<sattler@rechnungshof.gv.at>, intosai@rechnungshof.gv.at, intosai.donor.secretariat@idi.no, kimberl y.gardner@alliedbarton.com, Peter.Ammon@diplo.de, ihoven

<ihoven@worldbank.org>, iansolomon@worldbank.org

Bcc: Elaine Colville,

8

Keith_Luse@foreign.senate.gov,chris_lucas@judiciary-rep.senate.gov, president@press.org, delegation-usa-info@eeas.europa.eu, CAB-ASHTONbcc:

ARES@ec.europa.eu,peteris.ustubs@ec.europa.eu,christopher.jones@ec.europa.eu, antti.karhunen@ec.europa.eu,media@patch.com,partnerships@patch.com, pmeyer@email.unc.edu,jeff.jarvis@journalism.cuny.edu,sbeej68@gmail.com, brian.farnham@patch.com,kelly@patch.com,

Dear National Taxpayers Union,

I am requesting the National Center for State Courts as secretariat of the Conference of Chief

Justices to inform the Chief Justices of the 50 States. Holders of World Bank bonds in the 50 states can have no confidence in the accuracy of the World Bank's financial statements. The World Bank continues to refuse a Government Accountability Office inquiry requested by Senators Lugar, Leahy and Bayh, and to qualify for the US contribution to International Bank for Reconstruction and

Development capital increase under the Consolidated Appropriations Act of 2012. Ian Solomon, US

Executive Director, did not return my call on Friday. Allied Barton's employees, under contract with the World Bank to provide security services, persist in contacting the Human Resources Department whenever I request a security badge. Allied Barton's employees refuse to accept direction from Dr.

Merza Hasan, Dean of the World Bank's Board of Executive Directors, on the decision of the World

Bank's Board of Governors. Article V, Section 2 of the World Bank's Articles of Agreement provides:

"[a]ll the powers of the Bank shall be vested in the Board of Governors".

Best,

Karen

Law Offices of Karen Hudes

202 316 0684 www.kahudes.net

---------- Forwarded message ----------

From: Karen Hudes

Date: Fri, Jan 25, 2013 at 8:37 AM

Subject: Constitutional Crisis

To: ccj@ncsc.dni.us

Cc: andrew.lippstone@state.de.us, dquam@nga.org, geoffrey.harris@ep.europa.eu, robert_kelly@m enendez.senate.gov, daniel_o'brien@menendez.senate.gov, priscilla_ross@cardin.senate.gov

I would appreciate for the Conference of Chief Justices to inform the Chief Justices about the crisis in the translatlantic alliance caused by corruption and improper accounting at the World Bank.

I have requested the Judicial Conference to supervise the Director of the Administrative Office of the

U.S. Courts in the performance of his duties as the administrative officer of the courts of the United

States under 28 U.S.C. § 604.

I am forwarding background documentation for your information. The Eckhard Deutcher referred to in the following correspondence with the Senate Committee on Foreign Relations https://docs.google.com/file/d/0Bzss7Q0pShvzbVpwZ2FpRHJUcTQ/edit represented the Government of Germany on the Board of Executive Directors of the International

Bank for Reconstruction and Development. The co-author in this article http://www.kahudes.net/wp-content/uploads/2012/05/ilsaJournal1.pdf is on a first-name basis with

Angela Merckel.

Germany is simply signaling to the US that we are at a fork in the road: we can either choose rule of law and the transatlantic alliance, or we will have a currency war and China will come up very fast.

9

This is based on a 2004 stakeholder analysis using game theory modeling which predicted that the

US would lose the right to name the President of the World Bank if we did not observe financial rules.

(that happened in 2010 http://www.imf.org/external/np/cm/2010/042510.htm) This game theory modeling tool has a 90-95% accuracy rate based on years of experience.

See http://kahudes.net/wp-content/uploads/2012/05/board-of-governors.pdf , starting page 16. https://docs.google.com/file/d/0Bzss7Q0pShvzLWlzMFo3bXkzY2c/edit

Respectfully,

Karen Hudes

Law Offices of Karen Hudes

202 316 0684

Here is my recent post in Business Insider: http://www.businessinsider.com/german-gold-claw-back-causes-concern-2013-

1?pundits_only=0&comments_page=1#comment-5101029269bedd056a000002

Karen Hudes (URL) on Jan 24, 4:44 AM said:

Germany's announcement that it will repatriate 674 tons of gold valued at $17.9 billion sends a strong signal to the Judicial Conference of the United States that decisions of the Board of Governors of the

World Bank are to be respected and implemented. The Board of Governors settled bondholder litigation in the District of Columbia Circuit Court of Appeals against the International Bank for

Reconstruction and Development and its auditor, KPMG, in order to bring the IBRD into compliance.http://kahudes.net/case-in-court-of-appeals/ An April 8, 2005 letter to the World Bank stated, "The Joint Economic Committee of the US Congress has received credible evidence indicating that the World Bank has experienced accounting problems involving its borrowing, investment, and lending activities over a number of years." Senators Lugar, Leahy and Bayh requested a GAO inquiry in 2008, which the World Bank simply stonewalled. "In March 2009, GAO staff stated that 'we cannot begin this work because of challenges we recently faced in gaining access to World Bank officials to discuss these types of questions. We are continuing to negotiate access with World Bank officials but this process is likely to take at least several months.’ Senator

Lugar’s staff continues to press the World Bank and GAO to begin this report during the first half of

2010." See page 18 http://www.foreignpolicy.com/files/fp_uploaded_images/int_fin_inst2.pdf

US taxpayers are calling for an end to corruption at the World

Bank. http://www.ntu.org/governmentbytes/government-reform/whistleblower-protectionsa1220.html Congress sanctioned the Treasury Department for its inaccurate report to the

Appropriations Committees dated November 21, 2012 on World Bank Reform pursuant to Section

7082 of the Consolidated Appropriations Act, 2012 (Pub. L. 112-

74). https://docs.google.com/file/d/0Bzss7Q0pShvzWmE5Rlp1NVdMQlk/edit

The World Bank intimidated any accountant or lawyer, including the International Finance

Corporation's General Counsel, who tried to correct inaccurate financial information: http://www.commondreams.org/newswire/2010/04/06-3

The Court of Appeals' clerk ignored the Board of Governors' decision to settle the litigation and bring the IBRD into compliance. Instead of entering the settlement into the docket, the Clerk entered an unpublished opinion issued by a panel consisting of Judges Garland, Williams and Randolph one day after this statement in Foreign Policy:

10

http://thecable.foreignpolicy.com/posts/2012/11/07/the_romney_national_security_transition_team_th at_might_have_been?wp_login_redirect=0

"I have requested the Board of the World Bank to remove this litigation from the DC Circuit Court of

Appeals. The World Bank's General Counsel, who is supervising the litigation, is part of the internal control lapses.I have testified before the European Parliament and the UK Parliament posted my evidence on its website twice. The latest testimony was published on November 2, 2012 and is at: http://www.publications.parliament.uk/pa/cm201213/cmselect/cmpubadm/writev/publicpolicy/m03.

htm"

The 50 Governors and Attorneys General are also trying to bring the World Bank into compliance under blue sky laws.

Read more:

http://feedproxy.google.com/~r/JohnBrownesMarketCommentary/~3/hQje8c7L7gw/german_gold_cla w_back_causes_concern#ixzz2IswfWbZG

On January 22, 2013, I was on Spingola Speaks; the two podcasts dated 1/22/2013 are listed on the following website: http://www.republicbroadcasting.org/podcasts.active.php?programID=81

I am also on a blog by the National Taxpayers'

Union: http://www.ntu.org/governmentbytes/after-over-a-decade-stronger1115.html

---------- Forwarded message ----------

From: Karen Hudes

Date: Thu, Jan 24, 2013 at 6:47 AM

Subject: Please ask Senator Kerry/Secretary Clinton what he/she intends to do about the crisis in the translatlantic alliance caused by corruption and improper accounting at the World Bank

To: robert_kelly@menendez.senate.gov, daniel_o'brien@menendez.senate.gov, priscilla_ross@cardi n.senate.gov

I would appreciate if the above question could be entered into the record.

This unresolved matter, with Senators Mendez and Cardin for many years, is also causing a constitutional crisis. See attached

---------- Forwarded message ----------

From: Karen Hudes <h.k3511@gmail.com>

Date: Thu, Jan 10, 2013 at 9:52 AM

Subject: Handshake

To: geoffrey.harris@ep.europa.eu

Cc: dquam@nga.org, andrew.lippstone@state.de.us

Dear Mr. Harris,

Yesterday I spoke with Mr. David Quam, Director of the National Governors

Association's Office of Federal Relations, and with Governor Jack Markell, Chair of the National Governors Association, about bringing the International Bank for

Reconstruction and Development into compliance with states' blue sky securities laws.

11

I am copying Mr. Andrew Lippstone, Governor Markell's Chief Legal Counsel.

Sincerely,

Karen Hudes

Law Offices of Karen Hudes

202 316 0684 www.kahudes.net https://docs.google.com/open?id=0Bzss7Q0pShvzejNWLWR3Yjljdmc

--------- Forwarded message ----------

From: Karen Hudes

Date: Tue, Jan 15, 2013 at 8:31 AM

Subject: Congress and States are Bringing the World Bank into Compliance

To: alan_hanson@shelby.senate.gov, david_young@grassley.senate.gov, rick_dear born@sessions.senate.gov, Karen_Billups@murkowski.senate.gov, David_Ramseur

@begich.senate.gov, paul_cancienne@mccain.senate.gov, Steve_Voller@flake.sen

ate.gov, Andy_York@pryor.senate.gov,matt_sagely@boozman.senate.gov, Chris_T hompson@feinstein.senate.gov, Chad_wallace@boxer.senate.gov, sarah_moffat@f einstein.senate.gov, Laura_Schiller@boxer.senate.gov, Michael_Sozan@udall.senat

e.gov, Jonathan_Davidson@bennet.senate.gov, laurie_rubiner@blumenthal.senate.

gov,Francis_Creighton@murphy.senate.gov, Jim_Reilly@carper.senate.gov, Todd_

Webster@coons.senate.gov, Pete_Mitchell@nelson.senate.gov, cesar_conda@rubi o.senate.gov, Charlie_Harman@chambliss.senate.gov, Teresa_Ervin@chambliss.se

nate.gov, chris_carr@isakson.senate.gov, andy_winer@schatz.senate.gov,Betsy_Li n@hirono.senate.gov, Susan_Wheeler@crapo.senate.gov, John_Sandy@risch.sen

ate.gov, patrick_souders@durbin.senate.gov, Kate_Dickens@kirk.senate.gov, Dean

_Hingson@coats.senate.gov, Joel_Elliott@donnelly.senate.gov, Brian_Ahlberg@har kin.senate.gov, Jackie_Cottrell@roberts.senate.gov,Todd_Novascone@moran.sena

te.gov, Josh_Holmes@mcconnell.senate.gov, Doug_Stafford@paul.senate.gov, Jan e_Campbell@landrieu.senate.gov, Kyle_Ruckert@vitter.senate.gov, steve_abbott@ collins.senate.gov, kay_rand@king.senate.gov, Rachel_MacKnight@mikulski.senate

.gov, Marianne_Kreitner@mikulski.senate.gov, Chris_Lynch@cardin.senate.gov, Mi ndy_Myers@warren.senate.gov, David_lyles@levin.senate.gov, Amanda_Renteria

@stabenow.senate.gov, Jonathan_Becker@klobuchar.senate.gov, Casey_Aden-

Wansbury@franken.senate.gov, Steven_Wall@cochran.senate.gov, michelle_barlo w@wicker.senate.gov,julie_dwyer@mccaskill.senate.gov, Glen_Chambers@blunt.s

enate.gov, Paul_Wilkins@bauchus.senate.gov, mollie_binotto@tester.senate.gov, to m_lopach@tester.senate.gov, kathline_amacio@johanns.senate.gov, tim_becker@j ohanns.senate.gov, Mike_Hybl@fischer.senate.gov, david_krone@reid.senate.gov,b ill_dauster@reid.senate.gov, josh_finestone@heller.senate.gov, leonardo_benavide s@heller.senate.gov, mac_abrams@heller.senate.gov, erica_anhalt@shaheen.sena

te.gov, Maura_Keefe@shaheen.senate.gov, John_Easton@ayotte.senate.gov, judy

_rainey@lautenberg.senate.gov, dan_katz@lautenberg.senate.gov,daniel_o'brien@ menendez.senate.gov, Michael_Collins@udall.senate.gov, Steve_Haro@heinrich.se

nate.gov, mike_lynch@schumer.senate.gov, jess_fassler@gillibrand.senate.gov, chr

12

is_joyner@burr.senate.gov, crystal_king@hagan.senate.gov, sara_garland@conrad

.senate.gov, elizabeth_gore@dorgan.senate.gov,mark_powden@brown.senate.gov,

Ryan_Jackson@inhofe.senate.gov, Brian_Treat@coburn.senate.gov, Joshua_Shei nkman@wyden.senate.gov, Michael_Zamore@merkley.senate.gov, james_brown@ casey.senate.gov, Christopher_Gahan@toomey.senate.gov, Neil_Campbell@reed.s

enate.gov,Sam_Goodstein@whitehouse.senate.gov, Richard_Perry@graham.senat

e.gov, Kimberly_Wallner@scott.senate.gov, Drey_Samuelson@johnson.senate.gov,

Ryan_Nelson@thune.senate.gov, Ryan_Loskarn@alexander.senate.gov, Todd_Wo mack@corker.senate.gov, Beth_Jafari@cornyn.senate.gov,Chip_Roy@cruz.senate.

gov, Michael_Kennedy@hatch.senate.gov, Spencer_Stokes@lee.senate.gov, John_

Dowd@leahy.senate.gov, Michaele_Crowell@sanders.senate.gov, Jacob_Lew@sa nders.senate.gov, Luke_Albee@warner.senate.gov, Mike_Henry@kaine.senate.gov,

Mike_Spahn@washington.senate.gov,Jennifer_Griffith@cantwell.senate.gov

On December 20, 2012 I informed the Senate and House Appropriations Committees:

"The Treasury Department should be sanctioned for its report to the Appropriations

Committees dated November 21, 2012 on World Bank Reform pursuant to Section 7082 of the Consolidated Appropriations Act, 2012 (Pub. L. 112-74). The uncertified report is inaccurate in all material respects."

See https://docs.google.com/file/d/0Bzss7Q0pShvzWmE5Rlp1NVdMQlk/edit

I testified on the corruption at the World Bank to the European Parliament: http://www.europarl.europa.eu/document/activities/cont/201105/20110518ATT19540/20110

518ATT19540EN.pdf

And the UK Parliament:

http://www.publications.parliament.uk/pa/cm201213/cmselect/cmintdev/writev/402/contents

.htm

http://www.publications.parliament.uk/pa/cm201213/cmselect/cmpubadm/writev/publicpoli cy/m03.htm

The rest of the world settled my appeal in the DC Circuit Court of Appeals, but court records do not yet reflect this fact. US taxpayers associations in the National Taxpayers Union are fully briefed http://www.ntu.org/governmentbytes/government-reform/whistleblower-protectionsa1220.html

So is Justice Stephen Breyer, the Chief Justices of the State Supreme Courts, and the

National Center for State Courts.

See: https://docs.google.com/file/d/0Bzss7Q0pShvzaTJMQWFfcWNFS28/edit

Sincerely,

Karen Hudes

Law Offices of Karen Hudes www.kahudes.net

301 229-0058

13

From: Karen Hudes

To: customerservice.oag@dc.gov; oag@oag.state.md.us; philipz@oag.state.md.us; rob.mckenna@at g.wa.gov; iansolomon@worldbank.org; melitot@gao.gov; kohhh@state.gov; jwaskey@gmail.com; ch usa@covad.net;thomas_caballero@legal.senate.gov; mantoncic@worldbank.org; hgruss@worldbank.

org; lking@bbg.gov; alan_frumin@sec.senate.gov; alan.beattie@ft.com; rdizard@loc.gov; keith_luse

@foreign.senate.gov

CC: Elaine Colville, Yonas Biru;

christopher_lynch@cardin.senate.gov; marianne_kreitner@mikulski.senate.gov; pat.zindulka@aspeni nstitute.org

Subject: Re: Announcement of UK Parliamentary Inquiry

Date: Mon, 19 Sep 2011 10:45:03 -0400

The UK leads the world in grant funding for the World Bank. The UK Parliament International

Development Select Committee recently announced this inquiry into the Department for International

Development Annual Review and Multilateral Aid Review: http://www.parliament.uk/business/committees/committees-a-z/commons-select/internationaldevelopment-committee/inquiries/dar/

The Committee invited submissions from individuals. Elaine Colville, Yonus Biru and I are preparing a joint submission on systemic problems in the World Bank's governance.

-----Original Message-----

From: Karen Hudes

To: erin_vaughn@schumer.senate.gov

Sent: Fri, 7 Mar 2008 7:12 am

Subject: World Bank in Governance Crisis

The Joint Economic Committee should tackle an ongoing governance crisis at the World Bank by requesting the Government Accountability Office to investigate internal control lapses. The World

Bank has continued to violate 2006 appropriations legislation requiring whistleblower protections at the multilateral development banks -- its proposed whistleblower policy would eliminate any due process protection available to the World Bank's whistleblowers. The proposed whistleblower policy also prevents staff from reporting misconduct to the Board--they are directed to report only to their manager or to the Bank's Institutional Integrity Department ("INT").

I worked for 20 years in the World Bank's legal department, and was fired after reporting a cover-up to the Board and the Senate Committee on Foreign Relations. The World Bank rated its supervision performance as satisfactory although the banking sector project in the Philippines ended in failure and corruption. Last September, Estrada, the former president of the Philippines, was ordered to repay the commissions he received for the sale of stock in Philippines National Bank held by government employee pension funds. I was reassigned from the project after requesting the Country

Director to warn the Government that the conditionality in the project was not met, and the country's banking laws were being violated. PNB failed and had to be bailed out for $500 million; $200 million was canceled from the project, together with $200 million in matching loans from the Japanese.

The Dutch Government asked the Audit Committee to look into my case, and the Chair of the Audit

Committee referred the matter to INT. INT ignored the governance questions I flagged, but spent $1

14

million in a vicious personal attack. The Volcker Panel told me that it was not an ombudsman, and did not address the internal control lapses involved in INT's "goon squad" malfunctioning or the continuing cover-up. The Board is troubled that Mr. Zoellick circumvented the necessary Board approval for the proposal to appoint an independent panel to supervise INT.

The Staff Association has stated that other staff are intimidated from reporting misconduct after I was fired. But the Administrative Tribunal refused to consider the Staff Association's statement of support. Another whistleblower at the Bank (who was fired for trying to prevent corruption in an education project in Kenya and then reinstated) has been raising questions about INT's independence.

Sincerely, Karen Hudes

-----Original Message-----

From: kahudes@aol.com

To: Senator@schumer.senate.gov

Cc: chris_frenze@jec.senate.gov; Chris_Armstrong@finance-rep.senate.gov

Sent: Tue, 4 Mar 2008 2:31 am

Subject: Fwd: World Bank: INT as a tool of managerial harassment

The reputation of the United States for probity in the governance of the World Bank is very much at stake. I am forwarding a letter to this effect from the President of the World Bank's Staff Association, and an open letter sent by another whistleblower at the World Bank, concerning the World Bank's

General Counsel and Mrs. Laufer, the head of the Mediation Office. Mrs. Laufer had tried to assist me in resolving my case through mediation. It does not do to fire persons who defend rule of law at the World Bank.

----- Forwarded by World Bank Whistleblower on 02/29/2008 12:30 AM -----

02/29/2008 12:28

AM To

37520 WBIHD EDS EDS and

ALTERNATES

cc

EXC Correspondence Unit, MDW

Roster,

MDD Roster, MDO Roster, CRR ALL,

SA

Office, WBI Staff, AFR Staff,

ECA

Staff All, LCR Roster, EAP

Roster, SAR

Roster, MNA Roster, LEG Roster,

IEG

Roster, OPC Roster, SFR Anchor

Team,

SDN Roster, FSE Staff, MIG

Roster, PRM

Roster, CFP Roster, FPD All,

15

DEC

Roster, HDN Roster, EXC Staff,

HRS

Roster, EXT Roster, EDS ALL

STAFF, FPD

Network Members, FSE Sector

Members,

PREM Network All, SDN Network

Members,

HD Sector Members, HD HQ

Network

Members, HD CO Network

Members

Subject

INT as a tool of managerial

harassment: the example of Ms.

Ana Palacio

Dear Mr. Kvasov,

Dear members of the Board:

The contract of Ms. Deborah Laufer as Manager of Mediation Services

(MEF)expired on Wednesday, February 27, 2008. As I described in some detail in my last (February 24, 2008) email to Mr. Zoellick, in view of

Ms. Laufer?s high professional standards and very successful tenure, her forced departure represents a great loss to the Bank. Since the Mediation

Services have been the only functional part of the entire Conflict

Resolution System (CRS) in recent years, and since no credible business explanation of her departure has been given, this seems to be the final proof of the Bank?s complete lack of sincerity in its pursuit of the socalled "CRS reform" (if such proof is needed).

Today, I want to draw your attention to a different, in many respects even more disturbing aspect of this case, namely what seems by all appearances an improperly motivated and highly unethical manner in which Ms. Laufer was forced to leave, and in particular to the use of the

Department of Institutional Integrity (INT) as a tool of harassment by the

Bank?s General Counsel, Ms. Ana Palacio. The Board is in the unique position to take on this case, since the Bank's internal mechanisms (in particular: the INT and the Ethics Office) are evidently unable to do so.

The credibility of INT reform is at stake

The present case has wide ramifications for the credibility and prospects of the Bank's governance and anti-corruption (GAC) efforts, especially for the ongoing reform of INT. In particular, the Laufer case exposes a grave deficiency of the Volcker Report on which the current reform plans are based, namely the failure to recognize the INT's use as a managerial weapon against selected staff, an issue that previously was widely acknowledged as crucial for the credibility of any INT reform worth its name. Indeed, in the February 22, 2007 Townhall meeting, then

President Wolfowitz had explicitly promised to include this issue in the

16

TOR of the Volcker Panel; see my attached October 15, 2007 email to Mr.

Zoellick. The Volcker Panel?s disregard appears to have been quite deliberate; for example, it appears that the Panel was briefed in some detail about key aspects of the present case by both members of the CRS and a member of the board, but nonetheless completely excluded this important issue from its purview.

(See attached file: World Bank Whistleblower to Mr Zoellick-

101507 .doc)

Notwithstanding outward appearances (cf. e.g. SA Chair's February

25, 2008 Note attached below), Ms. Laufer's fixed-term contract did not expire simply as the result of ordinary managerial discretion. To the contrary, Ms. Laufer's forced departure had been prepared systematically by Ms. Ana Palacio, the General Counsel of the Bank. The present summary of Ms. Palacio's dealings with Ms. Laufer substantially expands on the earlier account in my February 24, 2008 email; it also repeats and slightly corrects some parts of this earlier message.

(See attached file: Note from the SA Chair-February 25,

2008.doc)

Shortly after the Mediation Office was formally placed under the auspices of the General Counsel in clear violation of the letter and spirit of Staff Rule 9.1, thereby contradicting earlier verbal commitments by both then Managing Director Shengman-Zhang and subsequently then chief of staff, Letitia Obeng, Ms. Ana Palacio told Ms. Laufer in November 2006 that she could not be confirmed without additional OPEs.

Using the INT as tool of psychological blackmail

An interim OPE meeting was therefore held in January 2007. During that meeting, Ms. Palacio agreed that while the performance of the

Mediation Office had improved, not everyone was impressed by Ms. Laufer.

In particular, for the first time, Ms. Palacio revealed the existence of an ongoing INT investigation against Ms. Laufer and alleged that its findings cast serious doubt on her professionalism; as a result, she would need to put Ms. Laufer on a 3-month PIP (Performance Improvement Plan).

While Ms. Laufer insisted on knowing details of the charges and findings of the investigation, Ms. Palacio was unwilling to reveal them, citing

"confidentiality?". To this very day, in flagrant violation of the most basic notions of due process and common fairness, Ms. Laufer has never been allowed to know the allegations against her, let alone the findings of the investigation. Not having been charged with misconduct, she was never able to clear her name. To the contrary, the Bank has been adamant in keeping its file open, as if to keep the threat of tarnishing her reputation alive even after she left the Bank.

Perhaps to add some spice, during the January 2007 meeting, Ms.

Palacio alleged that in the course of the investigation at least 50 people had been interviewed. There is no need to explain the threat and potential damage to Ms. Laufer's professional reputation and very ability to function entailed by such a wide-ranging investigation. Of course, it is precisely the likelihood of such(frequently irreversible) damage that mandates restricting INT investigations to situations in which they are absolutely necessary; there is no indication of any such restraint in the

17

present case. As a matter of fact, it is quite unclear whether or not so many people had indeed been interviewed; Ms. Palacio may well have grossly inflated the figure to inflate her psychological leverage over Ms. Laufer.

"Sign" or you are fired!?

The PIP meeting was held on February 6, 2007. While Ms. Palacio still was not willing to divulge what charges or incidents were the basis for the INT investigation, she now alleged that INT had identified a number of "weaknesses" in Ms. Laufer. Ms. Palacio had prepared a long document that was supposed to represent a contract of sorts for the PIP, and asked Ms. Laufer to sign it on the spot. When the latter asked her to read the document overnight before signing it in view of its length and complexity, Ms. Palacio retorted that if Ms. Laufer did not sign the document "here in the room", she would be fired.

Left without alternatives, Ms. Laufer proceeded to sign, adding a written remark that she was forced to sign under duress. Ms. Palacio reacted furiously and predicted that "this act will be held against you".

Ms. Palacio's true understanding of confidentiality

Ms. Palacio's true understanding of confidentiality was revealed in

March of 2007, when she requested in writing all confidential memoranda of the mediation office plus a log of all clients who either met in the mediation suite or spoke with a mediator, again in flagrant violation of

Staff Rule 9, not to mention the universally-accepted international definition of confidentiality in mediation.

Ms. Laufer's 'lack of cooperativeness'

We have only to thank Ms. Laufer's integrity that this massive breach of staff trust did not become reality. But, of course, it did not ingratiate her with Ms. Palacio who, two months later in May 2007, judged the outcome of the PIP to be 'inconclusive' on the grounds that Ms. Laufer was not sufficiently 'cooperative' with her ? I guess, she had a point there! As detailed in my last email, this 'inconclusive' assessment flew in the face of all available objective evidence, in particular of the independent external Mediation Exit Survey. Another OPE was initiated in

June 2007 but never completed. In November 2007, Ms. Laufer was notified by the Acting VP HR, Ms. Aulikki Kuusela, that her fixed-term contract would be allowed to expire on February 27, 2008.

That much dirt to hide

If the Bank's senior management has that much dirt to hide, how can they tolerate propriety in their midst? And how could they ever be expected to allow a CRS to develop that would ensure a minimum of transparency and accountability, unless they are forced to do so?

The corrosive effect on staff morale

The nonchalant mean-spiritedness and the demonstrative expectation of being able to act with complete impunity exhibited by Ms. Palacio?s actions are quite startling, or at least should be, if we were not so much used to such things. Their corrosive cumulative effect on staff morale

18

cannot be underestimated. The following response to my February 25, 2008, emails is unusual only in the choice of words, not in the sentiment that it expresses: I *would* say that it is unbelievable to me how Bank management gets away with such blatant and immoral mismanagement. But after 13 years in the Bank, I have grown jaded and cynical as I learned just how much the Bank is basically just a tool of evil forces, a place where accountability, responsibility and sensibility are unwanted principles? ? what does it take to arrive at the conclusion that one has been and will be devoting a large part of one's life to 'just a tool of evil forces'?

The need for an ethical investigation

As documented above, Ms. Palacio appears to have committed multiple, serious violations of fundamental staff rules. The systematic, manipulative and crassly abusive nature of her ?handling? of Ms. Laufer are strongly indicative of improper motivation. At the same time, Ms.

Laufer's independence and impartiality provided Ms. Palacio with a compelling motive. Taken together, this constitutes strong prima-facie evidence of managerial misconduct emanating from the highest levels of

Bank management. Since this (apparent) misconduct centrally involves the use of INT as a managerial weapon against targeted staff, it threatens to fatally undermine the credibility of the INT in its proper use, namely the fight against corruption.

Two years ago, in the context of Rizagate, the important precedent was established that no staff member of the Bank is exempt from following the Staff rules, not even the Bank's president. In view of the elevated position of the accused, it was left to the Bank's Board to thoroughly investigate the merits of the accusations against then-President

Wolfowitz. In the present case, there again are strong indications of multiple, severe violations of Bank staff rules which in many ways are arguably even more pernicious and ethically questionable than those of Mr.

Wolfowitz.

An ethical investigation of Ms. Palacio's actions is therefore strongly mandated. Since there evidently is no viable internal venue of doing so, this undesirable task falls to the Board. I very much hope that, by taking this task upon itself, the Board confirms that its actions in the context of Rizagate were based on principle rather than political calculation. This would represent a major step forward in re-establishing the credibility of the Bank's governance and anti-corruption (GAC) efforts.

Sincerely,

World Bank Whistleblower

__________________________________

From: Karen Hudes

Sent: Tue 3/25/2008 1:50 PM

19

To: ROBERTS Paul Lachal (OLAF)

Subject: Re: World Bank Governance

Dear Mr. Roberts,

I am writing you because OLAF [Office Lutte Anti Fraude -- the EU's anti-corruption agency] is aware that the Volcker Panel did not adequately address the sinister role of the World Bank's

Institutional Integrity Department in preventing staff from reporting misconduct to the World Bank's

Board of Institutional Directors. As a lawyer familiar with the mandate of the legal department under the Articles of Agreement in maintaining rule of law in the governance structure of the World Bank, I have thoroughly documented these severe control lapses and impressed upon the US Congress the urgent need to restore proper governance.

Since the World Bank's Independent Evaluation Group is implicated in the ongoing cover-up, their integrity to properly evaluate the World Bank's internal controls is impeached. I met with the Senate

Finance Committee March 20, and am under the impression that I have convinced the US Senate to require an independent audit of the World Bank's internal controls by the US Government

Accountability Office.

I have also informed Ms. DuFort about proposals to fully integrate the EC in a proposed global partnership with the World Bank on rule of law and governance. I am forwarding relevant documentation to you with this and one other separate email. I request OLAF to inform member governments about the current crisis in governance at the World Bank.

Sincerely,

Karen Hudes

-----Original Message-----

From: Karen Hudes

To: hcfa@mail.house.gov

Sent: Tue, 23 Sep 2008 9:39 pm

Subject: Re: Cover Up at the World Bank

I am asking the House Committee on Foreign Affairs to meet with Speaker Pelosi's office and the

Committee on Oversight to end a cover-up at the World Bank that alienated our allies and damaged the reputation of the United States. The American people do not agree with hegemony, and yet we have threatened the diplomats appointed by our allies to serve as Executive Directors at the World

Bank and IMF. This abuse of authority needs to be rectified prior to the upcoming annual meetings of the World Bank and IMF in October.

The Europeans have called for an end to the Gentleman's Agreement for appointment by the US of the president of the World Bank. Unfortunately, European allies have been further alienated by the unilateral decision to revise the mandate of the General Counsel and appoint a separate Executive

Secretary of the International Center for the Settlement of Investment Disputes.

Aaron Broches, the longest serving General Counsel of the World Bank, and one of the authors of its

Articles of Agreement, was my mentor. The European Union's anti-fraud unit, Office Lutte Anti

Fraude, advised me that the members of the EU had a discussion about World Bank governance following the Volcker Panel report.

20

Staff members intrepid enough to inform the Board of information necessary for them to carry out their oversight function were being retaliated against by the World Bank’s own Institutional

Integrity Department. I have informed the US Congress of this unfortunate abuse of authority.

Governance reform will feature prominently at these Annual meetings. The integrity of the entire

United States stands indicted before the rest of the world. I would appreciate if the House Committee on Foreign Affairs helps by ending the cover-up on the Philippines Banking Sector Reform Loan and restoring rule of law.

Sincerely,

Karen Hudes cellphone 202 316 0684

-----Original Message-----

From: Paul-Lachal.ROBERTS@ec.europa.eu

To: Karen Hudes

Cc: Franz.Bruener@ec.europa.eu; emilysbolton@gmail.com

Sent: Sat, Mar 29, 2008 2:08 pm

Subject: RE: World Bank Governance

Dear Ms. Hudes,

Thank you for your e mail. I recall your raising some of these issues with me when we met. I regret that you have found the work of the Volcker Panel deficient. As I advised you when we met, the ambit of the Panel's review was prescribed by the terms of reference under which it was established.

The Panel adhered to those terms of reference. My role as Counsel to the Panel came to an end shortly after the report was presented to the President, in September last year.

OLAF is part of the institutions of the European Union. Its existence, mandate and functionning is established and supervised by the laws of the European Union. These do not, to the best of my knowledge extend to having legal competence to pursue the grievances you raise.

You ask that OLAF inform member governments about what you see as a crisis in governance at the bank. My Director General and I met with a number of European Executive Directors of the World

Bank a few weeks ago to discuss the Volcker Panel report. At the meeting there was also discussion about governance issues. My impression was that the European Executive Directors are well apprised of all relevant issues at the Bank and no further comment by OLAF is warranted even if it was within our legal competence.

Yours sincerely

Paul Lachal Roberts

Adviser to the Director General

European Anti Fraud Office (OLAF)

European Commission

Brussels

21

-----Original Message-----

From: Karen Hudes

To: Sherman_Patrick@foreign.senate.gov

Cc: celes_hughes@mikulski.senate.gov

Sent: Sat, Oct 6 6:30 AM

Subject: Fwd: World Bank Scandal

Sherman,

I hand delivered this letter to Tim Rieser, who said that the Senate Foreign Relations

Committee should take the lead on this. Senator Mikulski's office asked me to follow up with Celes Hughes, whom I am copying on this email.

Senator Patrick Leahy

Senator Barbara Mikulski

Washington, DC 20510

Dear Senators Leahy and Mikulski,

The upcoming Annual Meetings of the World Bank on October 20, 2007 will be troubled by the widespread perception by its members and staff that the US does not respect rule of law in its oversight of the World Bank. The US has failed to address internal control lapses in the cover up of the World Bank's serious supervision mistakes on the Philippines

Banking Sector Reform Loan. As a lawyer in the Bank for 20 years, I reported then

President Estrada's corrupt sale of employee shares in Philippine National Bank resulting in a

$500 million banking failure, cancellation of $200 million from the BSRL and cancellation of $200 million in Japanese cofinancing.

When the Dutch Government requested the Audit Committee to determine whether I was being retaliated against for my whistleblowing, the Audit Committee referred the matter to the Institutional Integrity Department. INT only perpetuated the retaliation and cover-up by attacking me in a report that obfuscated the matter. The Volcker Panel ignored its assignment to evaluate the quality of INT's reports. The Dutch Executive Director, Mr.

Wijffels, has told the Dutch public that members of the Board of Executive Directors are subjected to investigations of their private lives as a form of diplomatic blackmail.

Despite three letters from the Senate requesting an end to the cover-up, I was fired from the Bank on July 31, 2007. In 2003 the Appropriations Committee stated, "The

Committee is particularly concerned with the professionalism of the Bank's legal department, and questions its ability to carry out its responsibilities fairly and effectively. Among other

22

things, the Bank's lawyers have expended resources prolonging cases that should have been resolved quickly, or defended management when it would have been in the interests of the institution to represent the complainants." On September 27, 2007, the World Bank's Legal

Department objected to the jurisdiction of the Bank's conflict resolution system to consider my action for reinstatement.

On Wednesday, at the suggestion of minority staff on the Senate Foreign Relations

Committee, I sent the enclosed email to Kenneth Peel, urging the US to respect rule of law in its oversight of the World Bank. The reputation of the US for probity in its oversight of the

World Bank, high on the agenda at the World Bank's upcoming Annual Meetings, will continue to be tarnished so long as the cover-up is permitted to continue. Bank staff members will be intimidated from reporting wrongdoing to the Board if I am not reinstated.

Sincerely,

Karen Hudes

-----Original Message-----

From: Karen Hudes

To: kenneth.peel@do.treas.gov

Sent: Wed, Oct 3 12:14 PM

Subject: Fwd: World Bank Scandal

Dear Mr. Peel,

Senator Lugar's office suggested that I contact you about an escalating perception that the

US does not respect rule of law in its oversight of the World Bank. Now the members of the

World Bank's Board are subjected to intimidation for trying to restore rule of law at the

Bank.

Mr. Russell Munk is fully aware of the failure by the US to address internal control lapses in the cover up of the Bank's supervision mistakes on the Philippines Banking Sector

Reform Loan, and persecution of the whistleblower who brought this to light. The World

Bank has continued to stonewall and failed to respond to three letters from the US Senate on this scandal, which the Volcker Panel only finessed by removing whistleblower retaliation cases from INT's mandate.

Mr. Lugar's office agreed that the Annual Meetings cannot be expected to conclude successfully when the US shows its disrespect for rule of law at the Bank by permitting the cover-up to continue to fester. In a meeting on September 24, 2007 in the Hague, the

Ministry of Foreign Affairs suggested that I involve the Delegation of the EC to the US in the ongoing scandal.

Sincerely,

Karen Hudes

23

On May 8, 2012, at 5:32 AM, Karen Hudes wrote:

Aaron and Carol,

I hope all is well with you both. Aaron, are you in Argentina, or are you still in the States following the International Law Section's Spring Meetings?

I hope you and my other friends in the American Bar Association can help me to deal with this. Janet is in the office of the President of the ABA.

Did you ever think when this was all developing at the turn of the century that this magnitude of cover up was possible? I for one did not. Here is a rough draft of my webpage, which should be up and running in a couple of days: http://www.apprs.com/kahudes/

Best,

Karen

---------- Forwarded message ----------

From: Karen Hudes <h.k3511@gmail.com>

Date: Mon, May 7, 2012 at 8:21 AM

Subject: World Bank

To: janet.jackson@americanbar.org

I see that the International Law Section and the World Bank are starting the global partnership. Now it would be good if the ABA also continues with my other initiative: rule of law.

Relevant correspondence with the European Union is also attached.

---------- Forwarded message ----------

From: Karen Hudes

Date: Mon, Jun 11, 2012 at 8:25 PM

Subject: Fwd: Rule of Law on the Capital Markets

To: fmulhauser@aol.com

Dear Fritz,

This is the draft letter which was intercepted and replaced with a different version. This morning I requested the UK Parliament to send a similar letter to the World Bank. The

International Development Committee is investigating how the Department for International

Development defends the interests of UK taxpayers.

24

I would appreciate learning when the ACLU is prepared to get involved in these violations of my civil liberties.

Best,

Karen

202 316 0684

---------- Forwarded message ----------

From: Karen Hudes

Date: Mon, Jun 11, 2012 at 8:08 PM

Subject: Re: Rule of Law on the Capital Markets

To: Baltimore <Baltimore@ic.fbi.gov>

Thank you for your email. I am reporting the violation of the Electronic Communications

Privacy Act of 1986, 18 U.S.C.§§2510-20, §§2710-20 (1992), (ECPA). This updated the Federal

Wiretap Act to apply to the illegal interception of electronic (i.e., computer) communications or the intentional, unauthorized access of electronically stored data.

On Mon, Jun 11, 2012 at 6:19 PM, Baltimore <Baltimore@ic.fbi.gov> wrote:

Ms. Hudes,

The Baltimore Division is the office that will try to assist with your complaint. Please explain the federal violation that you are reporting. Thank you.

From: Karen Hudes

Sent: Monday, June 11, 2012 10:59 AM

To: Washington Field; Baltimore

Subject: Re: Rule of Law on the Capital Markets

- Full Details about the crime and a time line of events

This is an update to my previous report to officer Strack concerning destruction of my submission to the US Court of Appeals, DC Circuit at midnight before the filing deadline of

December 1, 2011 . The emails which I sent to Mr. Ries Baeten, staffmember on the

European Parliament Committee on Budgetary Control in Brussels, on May 25, 2012 were interfered with. The attachments to emails which I sent to Mr. Baeten were removed and drafts which I never wrote were attached instead. My website at www.kahudes.net was hacked to remove documents. It is now functioning with delays. The computers of persons who used my website were subjected to malicious virus attacks.

- Any bio-data you have on the subject (address, email address, name, etc…)

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I do not know who is interfering with my emails or hacking my website. Mr. Ries Baeten's email address is attached below.

- Any supporting/collaborating evidence you might have about the crimes committed

Public engagement in policy-making

Written evidence submitted by Karen Hudes (PE 3)

Written evidence submitted by Karen Hudes on Public Engagement in Policy-making

· outsource with great caution, based on lessons learned about undisclosed conflicts

1. I am a lawyer and economist who worked for twenty years in the legal department of the World

Bank. Before the civil service outsources government policy-making functions, lessons must be learned from previous efforts. The Commons Select Committee on International Development published my testimony on the Independent Commission for Aid Impact at: http://www.publications.parliament.uk/pa/cm201213/cmselect/cmintdev/writev/402/contents.htm

2. The UK government's fiduciary responsibility to UK taxpayers cannot be outsourced. Hidden conflicts in the private sector are not readily apparent in many instances. Jimmy Wales, co-founder of Wikipedia, is advising the Government in support of the agenda to open up policy-making. Yet

Wikipedia erroneously reverted my edits to disclose the end of the Gentlemen's Agreement for the

United States to appoint the President of the World Bank.

October 2012

©Parliamentary copyright

Prepared 2nd November 2012

From: kahudes@aol.com [mailto:kahudes@aol.com]

Sent: Wednesday, June 22, 2011 10:19 AM

To: University of Amsterdam

Subject: Re: Avoiding a currency war

Dear Grega,

Thank you for your response. I am asking two things:

1) to validate the accuracy of the 2004 stakeholder analysis which I forwarded you in my previous email. I understand from Prof. Offerman that your group is also conversant with game theory.

2) to serve as the academic contact point for the U v A in a transatlantic dialogue to avoid a currency war through respect for the Articles of Agreement of the Bretton Woods institutions.

Als je verder inlichtingen wil, graag je telefoon nummer sturen.

Best,

Karen

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-----Original Message-----

From: University of Amsterdam

To: Karen Hudes

Sent: Wed, Jun 22, 2011 9:57 am

Subject: RE: Avoiding a currency war

Dear Karen, can you please explain a bit more clearly what you are asking from the IO reserch group.

I don't see the point from the included correspondence....

Best,

Grega

From: kahudes@aol.com [kahudes@aol.com]

Sent: Wednesday, June 22, 2011 3:18 PM

To: University of Amsterdam

Subject: Fwd: Avoiding a currency war

Ik heb net met Prof. _+____ gesproken, en hij heeft mij aangeraden om de Industrial Organization groep bij de U v A bij te betrekken.

From: University of Amsterdam

To: Karen Hudes

Subject: RE: Resolution of the Currency Crisis

Date: Wed, 22 Jun 2011 11:59:32 +0000

Dear Karen,

I am not travelling in the US, and I do not understand why I am involved in this (currency crises are interesting but not my field of expertise).

Best,

From: Karen Hudes

Sent: woensdag 22 juni 2011 13:06

To: University of Amsterdam

Subject: Re: Resolution of the Currency Crisis

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Dear Professor,

I understand that you are now traveling in the United States, and would welcome the opportunity to talk. Could you let me have your telephone number?

Sincerely,

Karen Hudes www.kahudes.net

From: "Fleck, Richard" <Richard.Fleck@hsf.com>

Date: 1 October 2012 12:56:50 BDT

To: Elaine Colville

Subject: Request for FRC Investigation of Deloitte and KPMG for deficient audits of World Bank Group.

Dear Ms Colville,

I am writing to confirm that your emails dated 29 august, 9 September and 1 October have been passed to me and that the matters that you have raised are being looked into to determine the appropriate approach to be taken by the Financial Reporting Council.

I will be in touch as soon as we have completed our review of the information you have provided.

Regards

Richard Fleck

Chairman, FRC Conduct Committee

From: karenhudes

To: Yonas Biru

CC: World Bank Whistleblowers

Bcc:jmcpherson@naag.org; andrew.lippstone@state.de.us; dquam@nga.org; geoffrey.harris@ep.europa.eu; robert_kelly@menendez.senate.gov; priscilla_ross@cardin.senate.gov; sekretariat.gp@nbp.pl; jwaskey@gmail.com; peter.ammon@diplo.de

Subject: RE: Violation of Sarbanes-Oxley 18 USC §1519 - Destruction, alteration, or falsification of records

Date: Sun, 3 Feb 2013 09:49:10 -0500

Yonas,

It is the crime of falsifying evidence. Perjury is lying under oath. Even under the World

Bank's flawed Staff Rule 8.02 PROTECTIONS AND PROCEDURES FOR REPORTING

MISCONDUCT

(WHISTLEBLOWING) http://siteresources.worldbank.org/NEWS/Resources/DraftsStaffRule8_02.pdf, a staffmember can go public with his claims of misconduct under paragraph 6.02bii if "the staff member has grounds to believe that it is not possible to report the suspected misconduct pursuant to any of the established internal mechanisms because all such avenues would create a likelihood that evidence relating to the

28

suspected misconduct will be concealed or destroyed."

Here are the California and Maine laws: http://www.shouselaw.com/offering-preparing-falseevidence. html http://www.mainelegislature.org/legis/statutes/17-a/title17-Asec455.html

The World Bank's falsification of evidence in my case is a violation of Sarbanes -Oxley, 18

§ 1519. See pages 9, 10, and 15 in this brief. http://www.kahudes.net/wpUSC content/uploads/2012/05/appeal74combine1.pdf

The 51 attorneys general and the National Association of Attorneys General are very aware that the

World Bank's lawyers, licensed to practice in the District of Columbia, breached the code of professional responsibility for using tampered evidence in my case in the Administrative Tribunal.

There is a 95% likelihood of rule of law at the World Bank. The US Congress and now the

Conference of Chief Justices are grappling with the fact that Germany is withdrawing its gold from the Fed until the US respects the settlement of my case by the World Bank's Board of Governors.

Here is what I am now faxing to the 50 chief justices of the

States. https://docs.google.com/file/d/0Bzss7Q0pShvzS2Npbk9lV0xkWkk/edit?usp=sharing

I have sent multiple emails informing the 600,000+ members of the associations in the

National Taxpayers Union that the US credit rating is affected by the illegality that we whistleblowers, acting together in coordination, are reporting. The NTU has this blog on their website:

http://www.ntu.org/governmentbytes/government-reform/whistleblower-protections-a1220.html

Other whistleblowers are helping me with press coverage to end this cover-up of illegality and bring the IBRD into compliance.

Best,

Karen

Law Offices of Karen Hudes

301 229-0058 www.kahudes.net

PS Phyllis, let's talk next week

Date: Sun, 3 Feb 2013 00:04:40 -0800

From: Yonas Biru

Subject: Is this perjury, tampering with evidence or hiding evidence

To: Karen Hudes Phyllis Mohammad

Hi Karen and phyllis

This is an important piece that I did not highlight before. But it is the most critical evidence to show the Tribunal's criminal behavior. How would you characterize it?

In Violation of a Cardinal Oath, Strike Three

This is an example showing the Tribunal itself tampering with evidence. As noted above the Bank deleted the aggrieved staff’s management experience from the record and presented him as an excellent technical staff without management experience. The staff presented a copy of his official HR record showing his stellar global management experience. In its judgment the Tribunal surgically removed all references to his management and presented the staff as strong technical staff without management experience. The Tribunal’s judgment read “The Tribunal observes that in the

Applicant’s 2005 OPE [Overall Performance Evaluation], the Director, DECDG, praised the Applicant’s performance in the following manner:”

‘[The Ap plicant] continues to be a very strong performer .... I have no doubt that he will

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continue to be a high performer and use his excellent technical and inter-personal and client skills.’”

Here is the full text:

“[The Applicant] continues to be a very strong performer managing one of the most

critical statistical programs that the Bank has ever managed. I have no doubt he will continue to be a high performer… and use his excellent technical and inter -personal and client skills.”

The Tribunal continued on to write in its judgment:

“In the Applicant’s 2006 OPE, the Director commented that: “[The Applicant] brings much value to our work and I have the highest regards for his expertise and for his dedication and hard work.”

Here is the full text:

“ The Applicant] has multiple roles in terms of the Bank’s global management of this round of ICP and handles critical and important functions dealing with difficult project coordination, management, and technical issues. He is praised for his many

skills in handling difficult regional ICP implementation cases. He brings much value to our work and I have the highest regard for his expertise and for his dedication and hard work.”

It should be noted that the central point of contention that the Tribunal was reviewing was whether the staff member has experience to be global manager or if his experience is limited to technical tasks as the Bank claimed after it denied his managment experience.

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