JUL 2 2 2008

the defendants,MAC AVIATION,TOM McGUINN,SEAN BYRNE,andSEAN McGUINN,did knowingly and willfully combine, conspire, confederate, and agree with each other, and withothers known and unknown to the Grand Jury, to commit offenses against the United States, that is,to export and cause the exportation of aircraft engines and parts, and to attempt to export and causethe exportation of aircraft engines and parts, from the United States to Iran in violation of theembargo imposed upon that country by the United States, without having first obtained the requiredlicenses or authorizations from the Office of Foreign Assets Control, United States Department ofthe Treasury, located in the District of Columbia, in violation of Title 50, United States Code,Sections 1702 and 1705, and Title 3 1, Code of Federal Regulations, Parts 560.203 and 560.204.COUNTS THREE THROUGH NINETEEN(Exports to Embargoed Country)22. The allegations in Paragraphs 1 through 14 are incorporated and re-alleged byreference in this Count.23. On or about the dates listed as to each count below, in the District of Columbia, andelsewhere, the defendants,MAC AVIATION,TOM McGUINN,SEAN BYRNEandSEAN McGUINN,did' knowingly and willfully violate the embargo against Iran by exporting and causing to export