105 W. Madison Street

Suite 1702

Chicago, Illinois 60602



312.630.0098 fx



April 18, 2006


Alexander Seger 

Department of Crime Problems

Directorate General of Legal Affairs

Council of Europe

Strasbourg, France


Subject:   Complaint regarding the false disclosure of share capital by a foreign  corporation, “ALLIANZ” A.G., Munich, Germany to the NYSE, based on the violation of stock ownership rights of Mr. Pašk Kačinari,    Zagreb, Croatia, shareholder of "Zagrebacka banka" d.d., Zagreb, Croatia, acquired  by a Consortium consisting of ‘ALLIANZ” A.G. and “UNICREDITO   ITALIANO” S.p.A. Milan, Italy.




Dear Sir/Madam,


            I am writing to you as the United States legal representative of, Mr. Pašk Kačinari of Frankopanska 9, Zagreb, Croatia, wholesaler in gold and diamonds, who has alleged that "ALLIANZ" A.G., Munich, Germany and  "UNICREDITO ITALIANO" S.p.A., Milan, Italy, hereinafter the 'Consortium', has inflicted damages to him in an amount in excess of $60 million. We bring this to the attention of the Securities and Exchange Commission due to the enormity of the scandal and its direct effect on shareholder confidence in major financial insitutions, as well as the financial impact on US investors and institutions that have direct financial interests in these above mentioned organizations. One of these organizations, “ALLIANZ” A.G., Munich, Germany, is listed on the New York Stock Exchange, which makes this case directly relevant to U.S. financial markets, especially more so as there is strong material evidence that the said Consortium, of which ‘ALLIANZ” A.G. is a member, is misreporting its stock holdings, based on a falsified share register of a bank it recently acquired.


            My client claims that the said damages came about in such a way that the said Consortium, on February 15, 2002, performed a stock swap with a group of shareholders of "Zagrebacka banka" d.d., Zagreb, Croatia (hereafter referred to as ZABA), in such a way that 20% of the share capital of ZABA was paid for in cash, while 80% was acquired by way of a stock swap.  Upon this stock swap, the previous ZABA shareholders were now recorded as holders of "New Unicredito shares", while the "ALLIANZ" - "UNICREDITO ITALIANO" Consortium was now registered as shareholders of ZABA, so that "ALLIANZ" A.G. was registered as holder of 13.67% ZABA shares, and "UNICREDITO ITALIANO" as holder of 81.91% of shares, meaning that the Consortium at that time was registered as owner of 95.58% ZABA shares.


            At that time, the Consortium did not swap shares with lawful shareholders, as it can be established that no lawful share register existed at the time of the said stock swap. Thus, the Consortium took the place of unlawful owners, and the share register in which the Consortium is listed as owning 95.58% of shares represents a forgery.


            It is also important to note that, although ZABA is a formerly state-owned bank, the largest in the Republic of Croatia, there is no record of ZABA ever having been privatized, as has recently been admitted by Croatia’s former Privatization Minister. Thus, there is no legal trail by which a formerly state-owned entity has passed into the hands of private owners, i.e. the current majority owners, members of the said Consortium.


            A short history of the transaction is important.  On November 13, 1990, my client, in the capacity of a private investor, signed a contract with ZABA, on the basis of which ZABA was required to acquire in my client's name a number of shares directly from its own issuance of stock and register my client as the shareholder in the shareholder register. The number of ZABA shares to which my client is entitled totals 164,421.



            ZABA did not fulfill this obligation, instead using the money from the deposit to acquire shares for another party, or parties.  This other party or parties, which became registered as a shareholder(s) on the basis of my client's funds, after a period of more than ten years, swapped shares with the "ALLIANZ"-"UNICREDITO ITALIANO" Consortium, resulting in the present situation where the Consortium, in place of my client, is registered as shareholder.


            My client claims that this amounts to a confiscation of his property, underlining that this took place during the time of a fierce inter-ethnic war in the Balkans, when confiscations were an everyday occurrence.  My client further claims a contributing factor to this confiscation could be found in his status of an ethnic Albanian and member of an ethnic minority in wartime Croatia.  Recently other ethnic minorities have also made similar claims in Croatian courts, including the Austrian Honorary Counsel in Croatia, a Mr. Georg Gavrilovic, who claims an illegal conversion of 14,357 original shares of ZABA which would now total more than 46 million Euros.



During the early 1990s, in the period immediately preceeding and including the civil war in the former Yugoslavia, ZABA issued an additional 1.010.288 Series I shares without reporting a capital increase or an issuance of a new series of shares to Croatia’s regulatory bodies. It is clear that this was a case of a subsequent covert issuance of shares, partly financed by my client's funds.  In other words, over 5% of the shares of this mysterious, covert issuance of shares should have been registered to the name of my client, Mr. Pašk Kačinari, of the total 2,884,928 shares that ZABA has issued.


            In addition, Mr. Kačinari presented his case in great detail and has, in the legal proceedings he has initiated against ZABA in Croatian Courts, provided a total of 58 documents supporting his case and his rights. A website has also been established to detail this illegal transaction.  It provides interested parties with documentation supporting my client’s claim.  The website is located at  This website also features other cases proving that the ZABA share register is a forgery, including scanned copies of ZABA shares currently in my client’s possession (, which have been “erased” from the current ZABA share register (, thus defrauding possibly thousands of legal ZABA shareholders.



            To date, neither ZABA nor it’s formally recorded owners from the "ALLIANZ"-"UNICREDITOITALIANO" Consortium have ever addressed my client, nor have in any way responded to these accusations, even at ZABA Annual Shareholder Assemblies, at which my client’s claims have been presented – and never denied.  The consortium has completey ignored my client's willingness to settle this matter amicably.


            We urge your office to conduct a complete and thorough investigation of my client’s claim, not on behalf of our client, but on behalf of shareholders of other institutions who were directly involved in this scandal, including  KPMG, Price Waterhouse Coopers, and how they helped make it happen, and how reputable investment banks, Credit Suisse - First Boston and  Dresdner Kleinwort Wasserstein (DKW), failed to perform due diligence for their shareholders prior to aquiring an interest in such shares.


We also urge your office to investigate this case for the purposes of protecting the integrity of U.S. and other financial markets, as the falsified ZABA share register compromises the integrity, lawfulness and validity of the shares and capital of “ALLIANZ” A.G., Munich, Germany, whose shares are traded on the NYSE, and "UNICREDITO ITALIANO" S.p.A. Milan, Italy, one of Europe’s largest banking groups, part of whose shares may be currently or in the future be held by U.S. corporations or citizens. According to ZABA’s Annual Report for the year 2004, as of December 31, 2004, ZABA’s total capital equals $11,421,205,655.68, which means that ZABA participates in the total capital of the “ALLIANZ/UNICREDITO Consortium in the amount of $10,916,388,365.70. This capital has no legal shareholders, and, thus, compromises the share registers of the said Consortium’s members.  Finally, as recent media reports have indicated, during the early 1990s, ZABA served as a conduit for the laundering of at least $800-900 million of funds that may be tied to al-Qaeda, some of which may have been used to covertly and illegally capitalize the bank.


            Should your office require additional information, copies of documentation or wish to interview my client directly as to these allegations, please contact me immediately.  Thank you in advance for your immediate attention to this urgent matter.



                                                                      Very truly yours,


                                                                            Paul Djurisic