[Strömberg]: Message to Nationales Konsortium Fur Marineexport

[Connor]

Security Classification: SECURE
Document Classification and Security Act 1995
Encrypted by the Strömberg International Legal Consultants​

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LETTER TO CEASE AND DESIST​

To whom it may concern within Nationales Konsortium Fur Marineexport,

Our law firm, Strömberg International Legal Consultants, represents our clients the Swedish Department of Defence in the interest of points of law. If you are represented by legal counsel, please direct this letter to your respective lawyers immediately and have them notify us of such representation. It should be noted that all correspondence is to go via our firm and you should not contact our client in reference to this letter.

It has been brought to our attention that Nationales Konsortium Fur Marineexport, currently publicly advertise the sale of a number of military-grade products in the form of online advertisement by means of website - specifically the Sachsen-class Frigate. An agreement between the Swedish Department of Defence and the German Ministry of Defence namely a 'Domestic Production Rights Agreement' ratified in 1997 prevents this activity explicitly. The agreement prohibits the advertisement or even acknowledgement of this product, clearly outlined in a risk assessment contained within. I am duty-bound to inform you that Strömberg International Legal Consultants has collated a significant amount of evidence (including financial data and physical advertisement) that we intend to take to civil court should this cease and desist not be actioned immediately.

In addition, we will be seeking appropriate compensation for the substantial risk our client have now unduly been laden with. We seek that you inform of us all sales of the aforementioned product, the recipients and the total value of these sales. Between us, we will find an appropriate out-of-court disposal to suit both of us.

We demand that you provide us with written assurance within three days of receiving this letter. If you fail to comply with the demand, the Swedish Department of Defence are entitled to use your failure to comply as evidence of wilful infringement and seek monetary damages and equitable relief for your actions via the judicial system. If in the event that you fail to communicate with us, please be advised that our clients have asked us to make it clear to you that they will be looking to pursue all available legal remedies and should we be forced to go via the judicial system they will be requesting court costs, counsel fees and other appropriate expenses. Your liability and exposure under such legal action could be considerable and will likely result in a monetary loss which we will pursue. We will be acting on behalf of our client and any further correspondence will be official, on behalf of our client and the judicial system of our choosing.

Before taking legal action, however, my client wishes to give you one opportunity to discontinue your illegal conduct by following the instruction given within this letter.

I look forward to hearing from you.

Regards,
William Helrig
Strömberg International Legal Consultants

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Strömberg International Legal Consultants and Strömberg Debt Collection Solutions are trading names of Strömberg
All promotions, goods and services are subject to bespoke negotiation
95487526-8728 | Swedish Company Registration Office
72092582 | Dutch Business Registry of the Chamber of Commerce​

Danny​

 

[Connor]

Security Classification: SECURE
Document Classification and Security Act 1995
Encrypted by the Strömberg International Legal Consultants​

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URGENT ACTION REQUIRED​

To whom it may concern within Nationales Konsortium Fur Marineexport,

Our law firm, Strömberg International Legal Consultants, represents our clients the Swedish Department of Defence in the interest of points of law. If you are represented by legal counsel, please direct this letter to your respective lawyers immediately and have them notify us of such representation. It should be noted that all correspondence is to go via our firm and you should not contact our client in reference to this letter.

We have recently undertaken an investigation into this matter that is in reference to the supply of prohibited goods in accordance with bilateral agreements in place. Our investigation leads us to believe that you had connection to this breach and therefore you are responsible for part or all of the associated implications to our client, the Swedish Department of Defence.

We have contacted you in relation to this matter and you have chosen not to respond to our demands. I warn you that failure to comply with our correspondence will result in this matter before forwarded to the courts for judgement and as stated in our previous letter hould we be forced to go via the judicial system they will be requesting court costs, counsel fees and other appropriate expenses. Your liability and exposure under such legal action could be considerable and will likely result in a monetary loss which we will pursue. We will be acting on behalf of our client and any further correspondence will be official, on behalf of our client and the judicial system of our choosing.

This matter can be resolved amicably - please make contact with our office urgently to discuss. No further correspondence will be sent and your failure to respond will serve as additional evidence of your involvement in the breach.

I look forward to hearing from you.

Regards,
William Helrig
Strömberg International Legal Consultants

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Strömberg International Legal Consultants and Strömberg Debt Collection Solutions are trading names of Strömberg
All promotions, goods and services are subject to bespoke negotiation
95487526-8728 | Swedish Company Registration Office
72092582 | Dutch Business Registry of the Chamber of Commerce​

Danny​

 

[Connor]

Danny

 

[Connor]

Kingdom of Sweden Reinfeldt Administration

August 2006​

PRE-TRIAL DISCLOSURE​

To whom it may concern within Nationales Konsortium Fur Marineexport,

I write to you on behalf of the Department of Defence, Kingdom of Sweden, my client. This matter has been referred from a third party solicitor firm Strömberg International Legal Consultants who had attempted to make contact with you, or your legal representation, on numerous occasions to solve the matter of breach of contract. This correspondence went unheard thus the matter has since been referred to the International Court of Justice by means of an Article 40 application, which has since been approved by the Commercial Chamber. Please accept this correspondence as your pre-trial disclosure.

This pre-trial disclosure is an extract from our original Article 40 application. I can confirm that no content has been redacted however it may have been edited to remain compliant by domestic and international law.

The plaintiff in this matter is the Department for Defence, Kingdom of Sweden (in part represented by third party Strömberg International Legal Consultants of Strömberg Group). The defendant in this matter is Nationales Consortium Fur Marineexport - it is anticipated that their plea will be not guilty. Our case surrounds the breach of contract between the Kingdom of Sweden and the incumbent government in Germany, for whom it is presumed the defendant acts on behalf of, and the subsequent risks to national security and substantial financial loss attributed.

In August 1997 the plaintiff and the then Minister of Defence, Federal Republic of Germany entered into a Domestic Production Rights Agreement which took effect on the date of ratification within the same month and year for and behalf of their respective governments. The agreement was for a naval frigate namely the Sachsen-class Frigate (hereon-in 'the frigate'). This agreement fundamentally focussed on, as the name suggests, the domestic production of seven iterations of the frigate for use within the Swedish Royal Navy - however, within the content of the agreement a risk assessment was established (Chapter II - Terms of Sale, Article 2). The risk assessment established a substantial risk posed to the national security of the plaintiff owing to the highly capable nature of the frigate - it also established that at the time of the report there was no existing sales of the frigate within the international market. As such the terms the agreement established that the frigate be removed from the then German Defence Export's catalogue, specifications should be accredited the security classification 'TOP SECRET' (SDCSA 1995) or equivalent and not to refer to or publicly acknowledge the agreement.

It is the view of the plaintiff that this contract has been breached.

Our investigation has established that in February 2004 the Nationales Consortium Fur Marineexport, the defendant, published their catalogue within which a number of advanced naval equipment was advertised for sale. The catalogue included prices and a purchase form - leading us to the conclusion that this was a marketplace catalogue for international sale. The aforementioned frigate is listed as the first available product which is at the time of writing named as 'F124 Sachsen-class Frigate' valued at $1,072,603,350.00. Purchase forms within the catalogue are encrypted and the prosecution have been unable to access this documentation. However, responses by the defendant show that on two separate occasions, in Feburary 2005 and April 2005, the frigate is invoiced with a total value of $2,145,206,700 and $6,435,620,100 respectively. This is a total of $8,580,826,800 and the view of the prosecution that this equates to the sale of eight iterations of the frigate.

Broader scope shows ten of the frigate in active service in the Portuguese Navy by official government publication - this is undocumented and the origin of this sale is unknown.

Since discovery a Cease and Desist been sent by Strömberg International Legal Consultants, representing the plaintiff, outlining the breach of contract - this was followed by a letter informing urgent action required, which again went unanswered. Both of these documents were addressed to the defendant and presumed as received. This leads us to believe this is now a wilful breach of contract as no action has been taken and no contact made with the plaintiff or their associates.

In light of the above, it is our firm position that the defendant has not only violated the express terms of the agreement, but has done so wilfully, repeatedly, and with disregard for both contractual obligations and international security implications.​

In the interest of a fair trial, my office will not be available for any further correspondence pending legal trial in the International Court of Justice. I must stress that any communication with my office should be via the courts. All and any unsolicited correspondence may be tendered in evidence to the courts for this case.

The Commercial Chamber has received a carbon copy of this correspondence in the interest of serving as evidence of our deliverance.

Regards,
Mari Heidenborg
Chancellor of Justice
Department for Justice

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CONFIDENTIAL
Crown Copyright © Kingdom of Sweden
All information is encrypted and subject to the Swedish Document Classification and Security Act 1995​

Global Assembly Danny