For the first (April 29, 1996) filing in this case see http://www.utwatch.org/corporations/freeportfiles/filing.html. See also the dismissal of that filing, April 9, 1997, at http://www.utwatch.org/corporations/freeportfiles/duval-970409.html.

This filing was dismissed by Judge Duval on August 8, 1997.

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT FOR LOUISIANA

CIVIL ACTION

CASE NO: 96-1474, SECTION K

TOM BEANAL, ON BEHALF OF HIMSELF AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFF

VERSUS

FREEPORT-McMoRan, INC. AND FREEPORT-McMoRan COPPER AND GOLD, INC., DEFENDANTS

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SECOND AMENDED COMPLAINT - CLASS ACTION

1.

The plaintiff, TOM BEANAL, a resident of Timika, Irian Jaya (West Papua) within the Republic of Indonesia and a leader of the Amungme Tribal Council, Lembaga Musyawarah Adat Suku Amungme (LEMASA) represents that this second complaint is brought individually and on behalf of all other similarly situated class members (indigenous people of Irian Jaya (West Papua) adversely impacted by the defendants, FREEPORT-McMoRan, INC. and FREEPORT-McMoRan COPPER AND GOLD, INC.'s, crimes against humanity.)

2.

Also made plaintiff herein is Lembaga Musyawarah Adat Suku Amungme (LEMASA), a duly incorporated foundation with its stated constitutional (Akte Notaris) goals to assist the Amungme community and Irian Jaya (West Papua) generally in the fields of education, health and welfare and to further act in the best interest of the Amungme. (See Exhibit A, attached hereto, the LEMASA Resolution dated April 18, 1997, wherein LEMASA, on behalf of the Amungme people voted to join the instant litigation.) Also made plaintiffs herein are BARTHOLOMEUS MAGAL, VICTOR BEANAL, LUKAS AMISIM and MATHIAS KELANANGAME, all of whom are residents of Timika, Irian Jaya (West Papua), within the Republic of Indonesia and directors of LEMASA.

3.

Also made plaintiffs herein are John Does and Jane Does, who are all Amungme tribes people residing in Irian Jaya (West Papua), Republic of Indonesia and have suffered the death of family members, rapes, assaults, torture, false imprisonment, surveillance, extreme mental harm and loss of traditional land rights. Plaintiffs seek compensatory and punitive damages for the harm they have suffered.

4.

Made defendant herein is FREEPORT-McMoRan, INC., a domestic corporation incorporated in the State of Delaware having as its primary corporate domicile located at 1615 Poydras Street, New Orleans, Louisiana 70112. Also made defendant herein is FREEPORT-McMoRan COPPER AND GOLD, INC., a domestic corporation incorporated in the State of Delaware and also having its primary corporate domicile at 1615 Poydras Street, New Orleans, Louisiana 70112. Hereinafter defendants are referred to collectively as FREEPORT.

5.

The proper Agent for service of process for both FREEPORT-McMoRan, Inc. and FREEPORT-McMoRan COPPER AND GOLD, INC. is C.T. Corporation Systems located at 8550 United Plaza, Baton Rouge, Louisiana 70809.

6.

Plaintiffs are informed and believe that at all times herein material each of the defendants was working in concert with its Indonesian subsidiary, PT-FI, and the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel to the extent that said conduct was perpetrated by PT-FI or the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel, FREEPORT confirmed and ratified the same.

7.

Plaintiffs are informed and believe that at all times herein material, FREEPORT, conspired with PT-FI and the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel by entering into an agreement to commit wrongful and tortious acts contained herein and FREEPORT participated in or committed wrongful acts in furtherance of said conspiracy which resulted in injury to the plaintiffs.

8.

Whenever and wherever reference is made to individuals who are not named or defendants in this complaint but were employees/agents of FREEPORT, such individual at all relevant times acted on behalf of FREEPORT.

9.

Jurisdiction is proper in the Eastern District of Louisiana, United States District Court, based upon 28 U.S.C. 1332 in that the amount of controversy asserted herein is in excess of $50,000 and that the controversy is between corporate citizens of a state and/or subjects of a foreign state. Additionally, jurisdiction is proper herein pursuant to the Alien Tort Claim Act, 28 U.S.C. 1350 and 28 U.S.C. 1367 (supplemental jurisdiction).

10.

Venue is proper under 28 U.S.C. 1391 in that both corporate defendants have their primary corporate headquarters located at 1615 Poydras Street, New Orleans, Louisiana 70112 and a substantial part of the events giving rise to the claims were initiated at the corporate headquarter of FREEPORT-McMoRan, INC. and FREEPORT-McMoRan COPPER AND GOLD, INC. located at 1615 Poydras Street, New Orleans, Louisiana, including but not limited to all corporate decisions, management directives, Board of Directors resolutions and the implementations thereof including matters involving hiring, training and supervision of FREEPORT's security personnel in Irian Jaya (West Papua), Indonesia; matters involving the method(s) of conducting its mining operations in Irian Jaya, Indonesia which have inflicted the conditions of life upon the plaintiffs alleged herein; and matters involving compensation to the plaintiffs for their traditional land rights.

11.

The plaintiffs bring this claim as a class action on behalf of themselves and all others similarly situated pursuant to Rules 23(a), 23(b)(1)(A) and 23(b)(3) of the Federal Rules of Civil Procedures.

12.

The class consists of all indigenous tribes people of Irian Jaya (West Papua), Indonesia who have been, are, or will be subject to the death of family members, assault, rape torture, false imprisonment, surveillance, extreme mental harm and/or loss of traditional land rights in furtherance of FREEPORT's mining activities in said district.

13.

The exact number of class members is not known but it is estimated that the class includes ten thousand (10,000) indigenous tribes people who have been subject to death of a family member, assault, rape, torture, false imprisonment, surveillance, extreme mental harm and loss of traditional land rights by FREEPORT or its agents. The class is so numerous that joinder of individual members is impracticable.

14.

The plaintiffs' injuries arise from a set of facts and circumstances common to that of the class they seek to represent and raise common questions of law.

15.

These common questions of law and fact include but are not limited to:

• a) Whether the plaintiffs and the plaintiff class experienced the harms alleged herein as the result of the actions of FREEPORT and whether the Indonesia military, intelligence and/or FREEPORT security personnel were acting at all times relevant to this complaint as an agent of FREEPORT;
• b) Whether or not FREEPORT knew or should have known and/or ratified the actions of PT-FI and/or Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel against the class; and
• c) Whether the actions of FREEPORT inflicted a condition of life upon the class which was deliberately calculated to destroy the class or a part thereof.

16.

The plaintiffs' claims are typical of the claims of the class.

17.

Plaintiffs are able to and will fairly and adequately protect the interests of the class.

18.

The attorneys for the plaintiffs are experienced in human rights litigation and in class action litigation and will fairly and adequately represent the interests of the class.

19.

This action is property maintained as a class action because the prosecution of separate actions by individual members of the class would create a risk of adjudication which would as a practical matter be dispositive of the interests of the other members or would substantially impair or impede their ability to protect their interest and/or the questions of law and fact common to the class predominate over questions affecting only members of the class and a class action is a superior method of adjudication rather than the filing of thousand of lawsuits against FREEPORT.

20.

The area of FREEPORT operations can be divided into five geographical regions: mountains and mountain valleys, high plateaus and river valleys, flat rain forest areas, tidal mangrove swamps and the coastal region. The Amungme have traditionally inhabited the highland areas living by farming and hunting.

21.

In 1967, defendant, FREEPORT-McMoRan, INC., by and through its predecessor corporation(s), initiated development of the Ertsberg Mine within the region commonly known as Irian Jaya (West Papua), a Province of the Republic of Indonesia.

22.

In 1988, defendant, FREEPORT-McMoRan, INC., by and through its subsidiaries and/or affiliates discovered within the Jayawijaya Mountain an enormous deposit of ore containing copper, gold and silver. Thereafter, the defendants began operating an open pit mine referred to as the Grasberg Mine. Included in the Grasberg open pit mining facility of the defendants is a mill, tunnels, slurry pipe lines and a corporate port located at Amamapare. The aforesaid Grasberg open pit mining operation encompasses an approximately 2,890 square kilometer area.

23.

FREEPORT, in connection with its Grasberg operations, deposits approximately 160,000 tons of tailings per day into the Aghawagon, Otomona and Ajkwa Rivers. Said tailing have diverted the natural flow of the rivers and have rendered the natural waterways of the plaintiffs unusable for traditional uses including bathing and drinking. Furthermore, upon information and belief, the heavy metal content of the tailings have and/or will affect the body tissue of the aquatic life in said rivers. Additionally, tailings have blocked the main flow of the Ajkwa River causing an overflow of the tailings into lowland rain forest vegetation destroying the same.

24.

FREEPORT, in connection with its Grasberg operations has diverted the aforesaid rivers greatly increasing the likelihood of future flooding in Timika, the home of the plaintiff, TOM BEANAL.

25.

FREEPORT, in connection with its Grasberg mining operation has caused or will cause through the course of its operations 3 billion tons of "overburden" to be dumped into the upper Wanagon and Carstensz Valleys creating the likely risk of massive landslides directly injurious to the plaintiffs. Furthermore, said "overburden" creates acid rock drainage which has created acid streams and rendering Lake Wanagon an "acid lake" extremely high in copper concentrations.

26.

The plaintiffs, as Amungme, possess a cognitive system wherein the earth is perceived as "mother" and the mountains are considered the head of the body, in symbolic terms. Disturbance to or loss of the earth symbolizes the loss of their body, their root, their identity and/or their life. Furthermore, the Amungme believe that the mountains are the home of their ancestors' spirits.

27.

The FREEPORT concession has drastically limited the use and ownership of land by the Amungme in the upper Waa Valley even though the Amungme were the original habitants of the land.

28.

FREEPORT, pursuant to its contract of work with the Republic of Indonesia has agreed to compensate the Amungme for resettlement due to its mining operations in connection with customary land rights. (Adat).

29.

The resettlement of the Amungme to the lowlands by FREEPORT was accomplished without adequate compensation and resulted in devastating outbreaks of malaria within the Amungme population.

TRIBAL GENOCIDE

30.

The plaintiffs here reiterate each and every foregoing paragraph of this complaint.

31.

FREEPORT operates within its mining concession a security force which had a budget of well over 2.5 million dollars in 1995.

32.

Upon information and belief, FREEPORT security personnel are trained and supervised by "security consultants" who have trained the security personnel in methods of controlling the indigenous tribes people, which include, but are not limited to, the use of firearms, batons, surveillance techniques, imprisonment and restrain.

33.

FREEPORT security personnel have engaged in a pattern and practice of recklessly discharging their firearms at indigenous tribes people, including certain John Doe and Jane Doe plaintiffs merely because they were within the FREEPORT concession. Said actions have resulted in innumerable deaths and disappearances including members of the plaintiffs' families. Said practices are an ongoing practice of the FREEPORT security personnel and is so pervasive that FREEPORT knew of said practice, should have known of said practice and/or ratified said practice.

34.

FREEPORT security personnel have engaged in an ongoing practice of rape of the indigenous tribes people in the remote Amungme village of Hoya and Agandi within the concession of FREEPORT including certain Jane Doe plaintiffs and family members of Jane Doe plaintiffs. Said practice is so pervasive that FREEPORT knew of said practice, should have known of said practice and/or ratified said practice.

35.

FREEPORT security personnel have engaged in a pervasive practice of assaults, imprisonments without lawful cause at FREEPORT security stations and surveillance of the plaintiffs including TOM BEANAL, members of LEMASA's Board of Directors and certain John Doe and Jane Doe plaintiffs, calculated to result in serious bodily and mental harm to the Amungme tribe. Said practices are so pervasive that FREEPORT knew of said practices, should have known of said practices and/or ratified said practices.

36.

FREEPORT has deliberately inflicted upon the plaintiffs' tribal group, the Amungme, conditions of life including colossal environmental damage to the mountains, waterways and rain forests in which they reside, planned political disruptions and division of their tribal organizations, a pervasive paramilitary presence within the FREEPORT concession and dispossession of the Amungmes' traditional land rights which has been calculated by FREEPORT to result in the physical destruction of the Amungme.

37.

The plaintiffs allege that the aforestated acts of FREEPORT, extrajudicial killings, rape, assault, false imprisonment and surveillance, by and through its security personnel at the FREEPORT concession, were committed with intent to destroy the Amungme tribe or a part thereof, for the direct and sole purpose of benefitting FREEPORT's mining operations.

38.

The aforesaid acts of FREEPORT violate international law, federal common law, and all applicable United Nations Conventions including Article II of the Convention on the Prevention of Punishment of the Crime of Genocide, 78 U.N.T.S. 277.

39.

The plaintiffs and the class they represent have been damaged by the genocidal corporate conduct of FREEPORT and seek compensatory and punitive damages.

HUMAN RIGHTS

40.

The plaintiffs specifically allege each and every paragraph of the foregoing complaint as if repeated herein.

41.

FREEPORT, in 1995, budgeted close to One Million Dollars (1,000,000.00) for support of the Indonesian military within the FREEPORT mining concession.

42.

FREEPORT has constructed security posts and barracks for the Indonesian military within the FREEPORT mining concession.

43.

FREEPORT feeds, clothes and provides equipment, including helicopters, buses, jeeps and containers used to imprison the indigenous tribes people, to the Indonesian military within the FREEPORT mining concession.

44.

FREEPORT security personnel and the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel and intelligence operatives have engaged in concerted actions against the plaintiffs and the class of plaintiffs including extrajudicial killing, rape, torture, surveillance and threats of death.

45.

The plaintiffs individually and on behalf of those similarly situated, complain that the defendants' security guards, in concert with Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel, acting by and through the corporate policy of the defendants and under color of Indonesian law, have engaged in summary executions, arbitrary arrest and detention, torture, disappearances, surveillance and the destruction of property. Said violations have occurred on FREEPORT buses, within FREEPORT workshops, at FREEPORT security command centers, FREEPORT security stations, FREEPORT private roadways and containers owned by said corporate defendants.

46.

On April 6, 1996, Bagus Kogoya was severely beaten by four FREEPORT security guards which resulted in Mr. Kogoya being permanently brain damaged.

47.

On December 25, 1994, on FREEPORT bus #44, while being operated on the road from Timika to Tembagapura, Wendy Tambuni was stabbed and shot to death while being transported on said bus.

48.

Also, on December 25, 1994, at the FREEPORT workshop located at Koperapoka, three civilians were killed after being tortured.

49.

On December 26, 1994, four civilians, arbitrarily and without lawful cause, were arrested at the FREEPORT security station and imprisoned in FREEPORT containers in Banti.

50.

Repeated acts of torture have been conducted at FREEPORT security stations and FREEPORT containers throughout the FREEPORT concession in Irian Jaya (West Papua), Indonesia. Said torture included kicking about the stomach, chest and head regions while FREEPORT security personnel were wearing military boots, beatings engaged in with fists, sticks, rifle butts, stones, starvation, kneeling on iron bars, standing with heavy weights on the subject's heads, shackling of thumbs, wrists and legs, stabbing, taping eyes closed and forced labor.

51.

Throughout the operation of the FREEPORT concession in Irian Jaya (West Papua), the defendant corporation in concert with Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel have engaged in security surveillance of the indigenous people, including the plaintiffs, throughout the region and said surveillance has resulted in fear, tension and severe mental distress resulting from the conduct of FREEPORT security personnel.

52.

Torture victims, including John Doe and Jane Doe plaintiffs, have been kept in FREEPORT containers by the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel, where they are required to stand for periods of up to and including seven days in water which was calf-high and reeked of human feces.

53.

Indigenous people, including John Doe and Jane Doe plaintiffs, have also been detained at FREEPORT workshops and security stations throughout the region where their eyes were taped shut, thumbs tied and were subject to repeated beatings and torture by FREEPORT security personnel and Indonesian military acting in concert with said personnel and under color of Indonesian law.

54.

FREEPORT security personnel, acting in concert with Indonesian military, intelligence and/or police forces, and under color of Indonesian law have committed ongoing crimes against women including rape, forced captivity and sexual slavery in the villages of Agimuga, Jila and Tsigna.

55.

Indonesian military personnel in connection with their surveillance tactics wear FREEPORT subsidiary clothing.

56.

The acts described herein were inflicted under color of Indonesian law and under color of official authority and/or in conspiracy or on behalf of those acting under color of official authority, and were inflicted deliberately and intentionally.

The acts and injuries to plaintiffs and their next-of-kin described herein were part of a pattern and practice of systematic human rights violations designed, ordered, implemented and directed by FREEPORT and its agents.

57.

As a direct and proximate result of FREEPORT's violations of international law, plaintiffs have suffered and will continue to suffer physical injuries, pain and suffering, and extreme and severe mental anguish and emotional distress; plaintiffs have incurred and will continue to incur medical expenses; and plaintiffs have suffered and will continue to suffer a loss of their means of economic support and the loss of their personal and real property. Plaintiffs are thereby entitled to general compensatory damages and punitive damages in amounts to be proven at trial.

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

58.

The plaintiffs herein reiterate each and every forgoing paragraph of this complaint.

59.

The acts described herein constitute outrageous conduct against plaintiffs and all other similarly situated and were without privilege.

60.

FREEPORT intended to cause plaintiffs to suffer emotional distress, or, in the alternative, (a.) FREEPORT engaged in conduct with reckless disregard of the probability of causing plaintiffs to suffer emotional distress, (b.) the plaintiffs were present at the time the outrageous conduct occurred and (c.) FREEPORT knew that the plaintiffs were present.

61.

Plaintiffs suffered severe emotional distress and the outrageous conduct of FREEPORT was a cause of the emotional distress suffered by plaintiffs.

62.

FREEPORT's outrageous conduct constitutes the intentional infliction of emotional distress and is actionable under the laws of Louisiana and the United States of America.

CONVERSION

63.

The plaintiffs herein reiterate each and every foregoing paragraph of this complaint.

64.

FREEPORT deprived the plaintiffs and all others similarly situated of their traditional rights by wrongful acts and disposition of inadequate recognition. At the time of conversion, plaintiffs were in possession of said property.

65.

As a result of FREEPORT's conversion of the plaintiffs' traditional land rights and/or property, the plaintiffs were damaged by the loss and/or loss of use of their property.

NEGLIGENT SUPERVISION

66.

The plaintiffs herein reiterate each and every forgoing paragraph of this complaint.

67.

On information and belief, when engaging in the wrongful conduct alleged herein, Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel were acting as the agents of FREEPORT. On information and belief, FREEPORT exercised control over the operative details of the conduct of the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel.

68.

FREEPORT knew or reasonably should have known that Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel would violate plaintiffs' rights and the rights of all others similarly situated, and that, as a direct and proximate result of these violations, the plaintiffs and class members would suffer injuries as alleged herein.

FREEPORT had the authority to supervise, prohibit, control and/or regulate the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel so as to prevent these acts and omissions from occurring.

69.

FREEPORT knew or reasonably should have known unless they intervened to protect plaintiffs and properly to supervise, prohibit, control and/or regulate the conduct described herein, Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel would perceive their acts and omissions as being ratified and condoned.

70.

FREEPORT failed to exercise due care by failing to supervise, prohibit, control or regulate the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel. As a direct and proximate result of FREEPORT's negligent selection, hiring, retention and contracting with the Indonesian military, intelligence and/or police forces and/or FREEPORT security personnel, plaintiffs have suffered and continue to suffer injuries entitling them to damages to be proven at trial.

DAMAGES

71.

Plaintiffs and other similarly situated incurred damages proximately and directly caused by the acts and/or omissions of defendant corporations set out heretofore said damages which include but are not necessarily limited to:

• a. bodily injury;
• b. physical injury in the past;
• c. bodily injury and physical impairment in the future;
• d. physical pain, suffering and mental anguish in the past;
• e. physical pain, suffering and mental anguish in the future;
• f. emotional distress in the past;
• g. emotional distress in the future;
• h. increased risks of disease or other ailments;
• i. costs of medical monitoring with regards to toxic exposure;
• j. medical expenses and services in the past;
• k. medical expenses and services in the future;
• l. disfigurement;
• m. loss of earning capacity;
• n. devaluation and/or loss in use and enjoyment of personal property;
• o. devaluation and loss of vegetation;
• p. loss of consortium;
• q. loss of services; and
• r. loss of traditional land rights.

72.

Additionally, all plaintiffs are entitled to punitive damages or exemplary damages as may be shown by the grossly negligent acts and omissions of defendant corporations as well as human rights violations and tribal genocide amounting to a sum to be determined hereinafter.

73.

The plaintiff, individually and on behalf of those similarly situated, assert that damages against defendant corporations total Six Billion Dollars ($6,000,000,000.00) exclusive of punitive damages.

74.

The plaintiffs request a trial by jury.

WHEREFORE, plaintiffs pray:

• (1) that process in due form of law, according to the course and practice of this Honorable Court, issue against said defendants;
• (2) that after due proceedings be had, judgment be entered in favor of plaintiffs, TOM BEANAL, LEMASA, BARTHOLOMEUS MAGAL, VICTOR BEANAL, LUKAS AMISIM, MATHIAS KELANANGAME, JOHN DOES AND JANE DOES AND OTHERS SIMILARLY SITUATED, against the defendants, jointly, and severally and in solido, for damages and punitive damages in an amount to compensate for the aforedescribed conduct of the defendants in an amount to be determined by this Honorable Court, plus prejudgment interest from the date of filing, costs, punitive damages and that the plaintiff(s) have such other relief as in law and justice they may be entitled to recover.
• (3) For class certification.

Respectfully submitted:

REGAN & BOSHEA, P.L.C.

MARTIN E. REGAN, JR.
(LSBA No. 11153)
Attorney for Plaintiffs
2125 St. Charles Avenue
New Orleans, LA 70130
(504) 522-7260

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PLEASE SERVE:

FREEPORT McMoRan, INC.
C.T. Corporation Systems
8550 United Plaza
Baton Rouge, Louisiana 70809

FREEPORT-McMoRan COPPER AND GOLD, INC.
C.T. Corporation Systems
8550 United Plaza
Baton Rouge, Louisiana 70809

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CERTIFICATE

I hereby certify that a copy of the above and foregoing has been hand delivered to John C. Reynolds of the law firm of Jones, Walker, Waechter, Poitevent, Carrere & Denegre, L.L.P. located at Place St. Charles Avenue, New Orleans, Louisiana 70170-5100.
New Orleans, Louisiana this 23rd day of April, 1997.
(signature)
MARTIN E. REGAN, JR.

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Exhibit A

LEMBAGA MUSYAWARAH ADAT SUKU AMUNGME (LEMASA) 18 April, 1997
Timika, Irian Jaya (West Papua)
Indonesia

RESOLUTION

We, the undersigned duly elected members of the LEMASA Board of Directors with full authority vested in us and acceptance with LEMASA Convention/Charter/Incorporation declare on behalf of LEMASA and the Amungme people that we have voted this 18th day of April, 1997 to join our duly incorporated organization, LEMASA, in the lawsuit entitled Tom Beanal et al. vs. Freeport-McMoRan, Inc. et al., No. 96-1474, Section "K" in the United State District Court, Eastern District of Louisiana as a plaintiff with Tom Beanal.

We further declare that LEMASA does hereby adopt each and every claim made by Tom Beanal against Freeport-McMoRan including tribal genocide, human rights violations and all environmental claims relating to the aforementioned cause of action.

THUS FIRST READ to all present in Bahasa Indonesian, Bahasa Amungme, and Bahasa English and SIGNED this 18th day of April, 1997, in Timika, Irian Jaya, Indonesia.

TOM BEANAL, DIRECTOR, (signature)
LUKAS AMISIM, DIRECTOR, (finger print)
VICTOR BEANAL, DIRECTOR, (signature)
BARTHOLOMEUS MAGAL, DIRECTOR (finger print)
MATHIAS KELANANGAME, DIRECTOR (finger print)

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The preceding text is the amended law suit filed by Tom Beanal against Freeport in New Orleans on April 23, 1997. The text above was typed by Robert S. Boyer from a copy received from the law firm that filed the suit.

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