ILANA DIAMOND ROVNER, Circuit Judge.
In the late 1980s, Fred Whitson helped the American Comtel Corporation ("Comtel") obtain a contract to install pay telephones in Veteran's Administration ("VA") Hospitals by bribing a friend at the VA. Comtel paid Whitson more than half a million dollars during 1988, 1989 and 1990 in exchange for that assistance, and the money has been sequestered in several numbered bank accounts in the Cayman Islands ever since. In 1994, Whitson...
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