Tr. 1087 · ECF 204-1 at 7

Proximity

The Government told the jury the closest Saint Clair got to the United Nations was an apartment office across the street. Here is that sentence set against the record: the witnesses, the photographs, the UN’s own documents, and the official who was there in 2006 and again in 2019.

Tr. 1087 · ECF 204-1 at 7

“During 2017 to 2019 … the closest he got to the UN was having an apartment office across the street”

The prosecutor’s words to the jury in rebuttal summation, the last argument the jury heard before deliberating. Exactly as the transcript records them: “Ladies and gentlemen, at bottom, during 2017 to 2019 when Asa Saint Clair was at the WSA, the closest he got to the UN was having an apartment office across the street.” (Tr. 1087) Exhibit C, filed with the motion, plots the record against it, with Saint Clair at the center and each ring a step farther from the United Nations.

Asa Saint Clair, in a white WSA shirt, photographed between the framed official portraits of UN Secretaries-General Kofi Annan and Ban Ki-moon.Saint Clair in the lobby of UN headquarters in New York, inside security, between the official portraits of Secretaries-General Kofi Annan and Ban Ki-moon
The UN Mine Action Service certificate recognizing Asa Saint Clair as a Champion of the Safe Ground campaign.Saint Clair’s award from the UN Mine Action Service, Safe Ground campaign · PX 33 · ECF 136 at 6
A working meeting around a conference table inside UN headquarters, a UN video screen at left; Asa Saint Clair sits at right in a gray jacket.The UNMAS Safe Ground working meeting inside UN headquarters, April 4, 2019, taken by an official UN photographer. Saint Clair is at the right end of the table, in a gray jacket; Amir Dossal is present · PX 878 · ECF 204-2 at 24

Across the street, or inside?

Tr. 1087 · Tr. 511–12, 574–75 · ECF 135 at 33, 52, 80
The prosecutor, in rebuttal summation
“Ladies and gentlemen, at bottom, during 2017 to 2019 when Asa Saint Clair was at the WSA, the closest he got to the UN was having an apartment office across the street.” (Tr. 1087)
The record
  • Inside UN headquartersA Government witness went with him into UN headquarters in 2018 (Tr. 574–75). The Government’s cooperating insider attended a UN conference there with him, where he spoke (Tr. 511–12). A defense witness met him inside the UN in August 2017 (ECF 135 at 80).
  • With senior UN officialsHe met Director-General Møller in August 2017 (ECF 135 at 33, 52) and again at Davos in 2018 and 2019 (DX 22; Tr. 855–60).
  • UN instrumentsThe UNGSII joint venture (July 2017), the UNMAS “Champion” designation, his personal UNMAS award, and the UN’s own “Collaborative Partner” signage (ECF 150-1 at 21–24; PX 32–34).
On the chart, every one of those points sits inside the Government’s ring. The Government’s sentence is the only thing in the outer orbit.
Exhibit C, page 2: a radial chart with Asa Saint Clair, WSAIGO 2016 to 2019, at the center. Rings are labeled inside or at UN headquarters, with senior UN officials, UN-linked instruments and designations, and the outer dashed ring, the Government’s version, holding only the summation quote. Each node is dated and cited.Exhibit C, page 2 · Petitioner’s documented UN proximity, 2017–2019 · ECF 204-1 at 7
Demonstrative chart filed with the motion. It organizes record evidence; it is not itself evidence. Tap to enlarge.

Amir Dossal, 2006 and 2019

The same UN official appears at both ends of the arc. In 2006, as Executive Director of the UN Fund for International Partnerships, he took part in the ECOSOC meeting that launched WSA (DX 11 at 214). He wrote that he looked forward “to the continued practical outputs of the ‘World Sports Alliance’ to propel the development goals of United Nations even further!” (PX 888) In April 2019 he stood with Saint Clair outside UN headquarters (PX 879). Schatz has sworn he introduced the two that year. (ECF 135 at 50 ¶ 14)

Asa Saint Clair and Amir Dossal standing together outside UN headquarters in New York, flags of member states and the banner for the International Day of Sport for Development and Peace behind them.Saint Clair (right) with Amir Dossal outside UN headquarters, before the UN banner for the International Day of Sport for Development and Peace, early April 2019. PX 879 · ECF 204-2 at 26
Amir Dossal’s 2006 congratulatory message in the ECOSOC High Level Segment report, highlighted: We, at UNFIP are very appreciative of the NGO Section, DESA and this initiative supported by ECOSOC; applaud the various partnerships launched under the UN-NGO-IRENE umbrella; I look forward to the continued practical outputs of the World Sports Alliance to propel the development goals of United Nations even further.2006 · Dossal’s congratulatory message on the meeting that launched WSA: “I look forward to the continued practical outputs of the ‘World Sports Alliance’” · PX 888 · highlighting added
Page 214 of the 2006 UN ECOSOC book, DX 11, listing notable participants at the WSA launch; Mr. Amir Dossal, Executive Director, UNFIP, is highlighted and boxed.2006 · the UN’s own record lists “Mr. Amir Dossal, Executive Director, UNFIP” among the participants · DX 11 at 214 · orange highlight and box added
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