Quelques lumières sur le Carlyle Group, — ou l’accomplissement du système militaro-politico-industriel

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Quelques lumières sur le Carlyle Group, — ou l’accomplissement du système militaro-politico-industriel

Le Carlyle Group est aujourd’hui connu. C’est bien le moins qu'on puisse attendre d’un conglomérat américain d’industries d’armement principalement qui avait réussi à mettre côte-à-côte, comme actionnaires, conseillers et amis, Bush-le-père et la famille Ben Laden. On trouve d’autres surprises de ce genre avec Carlyle. Mais ce n’est pas ce qui nous intéresse vraiment ici.

L’aspect fascinant et novateur du Carlyle Group est qu’il n’y a aucun lien originel de tradition avec l’industrie d’armement (il n’y a pas à l’origine un Alan Lockheed et un Glenn Martin, qui donnent à Lockheed Martin, malgré tout, un reste de tradition). Formé en 1987 par deux hardis investisseurs qui adoptèrent le nom de l’hôtel (Carlyle) où ils se réunissaient parce qu’il donnait une impression de confort rassurante pour les nouveaux investisseurs à intégrer, c’est une entreprise qui entend réussir des opérations de captation d’entreprises à bon prix pour les faire fructifier à leur avantage. C’est la nomination de Frank Carlucci comme CEO qui donna son orientation à Carlyle et le conduisit vers le succès. Carlucci, homme de la CIA, sortait d’une année passée à la tête du Pentagone, comme dernier secrétaire à la défense (1988-89) de Reagan. Naturellement, Carlucci orienta Carlyle vers les entreprises de défense.

D’autre part, une pratique essentielle de Carlyle fut développée par Carlucci : s’adjoindre à prix luxueux comme il se doit des “rabatteurs” préparant le travail de rachat. Il s’agit en général d’hommes politiques disposant d’une grande audience et d’un carnet d’adresses très fourni. Cela va de George Bush (le père) et Howard Baker (ancien secrétaire d’État de George Bush le père) à John Major ou à un ancien président sud-coréen. On trouve ici l’accomplissement du système militaro-industriel, qu’on pourrait agrandir par exemple, dans ce cas, en une sorte de complexe militaro-politico-industriel (avec un zeste de CIA en plus, par Carlucci interposé). La dimension politique est totalement intégrée, avec les politiciens soutenus financièrement durant toute leur carrière par l’industrie, suscitant alors qu’ils sont au gouvernement des affaires publiques les systèmes et les marchés pour le compte de ce gouvernement et de la soi-disant sécurité nationale, qu’ils iront plus tard, grâce aux relations établies durant leur temps de soi-disant service public, faire attribuer à des sociétés Carlyle, avant de rabattre les nouvelles sociétés pouvant être absorbées par Carlyle.

Ci-après, nous reproduisons une interview donnée par l’auteur d’un livre sur Carlyle qui fait autorité (Dan Briody, auteur de The Iron Triangle: Inside the Secret World of the Carlyle Group), interview donnée au site Buzzflah.com. Nous laissons le commentaire d’introduction de Buzzflash.com ainsi que l’extrait du livre de Briody choisi pour avoir une appréciation de Carlyle. Enfin, nous terminons par une très récente appréciation de ce livre (que nous n’avons pas lu nous-mêmes), que donne un article très élogieux, de The Economist. Cet hebdomadaire qui est le chantre du capitalisme et du libre-échange acceptant avec une très grande approbation une appréciation si critique de Carlyle, voilà qui est significatif. Phrase de conclusion de l’article : «  Shrouded in secrecy, Carlyle calls capitalism into question. » Cela suscite la question de savoir si, avec Carlyle, nous n’arrivons pas au terme de la perversion du système, — et, si oui, nous y arrivons avec une connexion absolument intime avec l’actuelle administration comme l’explique Briody, dans un arrangement proche de la perversion (« We have seen an absolute affinity for mixing business and politics, and throw in a war and you’ve got the Bush administration. And that scene of him giving that speech at United Defense’s plant in Santa Clara summed up perfectly what this administration is all about. »)


Extrait du livre The Iron Triangle: « Today, the Carlyle Group is a story of dealings inside the ‘Iron Triangle,’ the place where the world's mightiest military intersects with high-powered politics and big business. It is a company whose history includes ties to CIA cover-ups and secret arms deals, and an astounding trail of corporate cronysim. By making defense buyouts the cornerstone of its business strategy, Carlyle now finds itself the beneficiary of the largest increase in defense spending in history. Indeed the stars seem to have aligned perfectly for Carlyle, in just 15 short years. With the ascension of George W. Bush to the presidency, the White House is now full of ex-Carlyle employees, friends, and business partners. And with the newly fattened defense budget, Carlyle has been able to extract massive profits from its defense holdings, like United Defense, in the wake of the terrorist attacks on September 11, 2001. It may be tough times for Americans, but as Bette Midler might say, everything’s coming up Carlyle. »


Interview de Dan Briody, auteur de “The Iron Triangle”

What Did Eisenhower Mean When He Warned of a Military Industrial Complex? Take a Look at the Carlyle Group.


A Buzzflash Interview Dan Briody, author of “The Iron Triangle: Inside the Secret World of the Carlyle Group”, 23 juin 2003

They are at the epicenter of the military-industrial-complex-Bush-Cheney-crony-capitalism administration. The Carlyle Group is the model example of the nearly seamless connection between the Bush administration, self-enrichment and companies who receive big government defense contracts.

The roster of Carlyle “consultants” reads like a who’s who guide to government officials of the 1980s, starting with former president George Bush, former secretary of state James Baker, and former defense secretary Frank Carlucci.

The most chilling aspect of Briody’s book is that the political connections and lobbying activities he unmasks are not illegal.

It is a testament to the brain dead mainstream media that the relationship between the Carlyle group and the Bush-Cheney cartel is not a national scandal.

Brady is an award winning journalist who has written for Forbes, Wired, Red Herring and the Industry Standard.

You can purchase his book as a BUZZFLASH premium at: ''The Iron Triangle:Inside the Secret World of the Carlyle Group.''

* * *


BUZZFLASH: If we were looking at the Carlyle Group — aside from its controversial nature and the political world of who runs it and the consultants affiliated with it — what business model does it represent?

BRIODY: It’s what’s known as a private equity firm. And that’s a very vague term to describe a whole umbrella of different types of companies. What Carlyle specializes in is buyouts, which means that they operate very similar to a mutual fund. Only instead of buying and selling stock, they buy and sell private companies. And they also do venture capital and real estate. So they’re in a variety of different kind of financial transactions-based businesses. But their bread and butter is buyouts. And within that area, they focus heavily on government-regulated industries – anything that depends very heavily on policymaking and legislation coming out of Washington, D.C. As such, they hire a number of ex-politicians to help them in that regard.

BUZZFLASH: In terms of companies that they buy out, most notably in terms of their political-business crossover, they’re probably most known for their relationship to the defense industry, even though that’s not by any means exclusively what they do.

BRIODY: They got their start in the defense buyout business. They struggled for the first couple of years before they hired Frank Carlucci, who was the outgoing Secretary of Defense from the Reagan administration. And Carlucci brought them in the direction of defense buyouts in the late ‘80s, early ‘90s, in between the Cold War and the Gulf War, when defense properties were undervalued. And the company struck gold a couple times in that business and was able to build a very healthy buyout practice on the back of these defense LBOs, or leveraged buyouts.

From there, they have diversified over the ensuing 10-12 years, into everything from healthcare to telecommunications, to aerospace and others. But defense is still the cornerstone of their practice. And when people think of the Carlyle Group, the first thing they think of is defense.

BUZZFLASH: On the cover jacket of your book, it says that the book will provide witness to how the Carlyle Group profited from the Sept. 11 terrorist attacks and continues to profit from the ongoing war on terrorism. What evidence do you provide for that?

BRIODY: There are a number of transactions that the company profited from directly following the Sept. 11 attacks. The most important one was the fact that they were able to take United Defense, their crown jewel of defense holdings public shortly after the attacks. In fact, in the prospectus that they circulated, before that IPO, they cited the Sept. 11 attacks as one of the reasons why they were able to sell public stock in this company at this time. So that was all on the back of the defense build-up following Sept. 11.

There are also a number of other holdings of theirs — like at that time, they owned a company called the IT Group, which is a company that cleans up hazardous materials and won a very lucrative contract to clean up the Hart Senate Building in Washington, D.C., which had been tainted by anthrax.

They also own a company called U.S. Investigative Services, USIS, which is a company that does background checks and provides varying levels of security clearance for different government employees, airline employees – things like that. Obviously their contracts went through the roof after Sept. 11.

In addition to that, they own companies that do all kinds of security, different aerospace companies. So whenever there’s a big defense buildup, those companies profit. So there are a number of ways that they’ve profited very handsomely from Sept. 11.

* * *


BUZZFLASH: I recall that reading in the British papers that Tony Blair was considering privatizing a portion of the intelligence apparatus in Britain, and that the Carlyle Group was going to be subcontracted to do some of that.

BRIODY: He did, in fact. The new company is called Qinetiq. It’s spelled Q-I-N-E-T-I-Q. It’s the research arm of the ministry of defense in the U.K., which is essentially equivalent to DARPA [the Defense Advanced Research Projects Agency] here in the U.S. And the Carlyle Group was part of that transaction, so they own part of Qinetiq. It was a very controversial transaction in the U.K., obviously. I mean, if you could try to imagine a foreign company coming in and buying DARPA from the United States. It’s unimaginable. And particularly a company that’s so stockpiled with very powerful former politicians.

BUZZFLASH: So Tony Blair essentially condoned the privatization of a large section of the British defense intelligence apparatus to the Carlyle Group. It would be comparable for us to subcontract that to a foreign company.

BRIODY: Yes, which I don’t think would ever happen.

BUZZFLASH: You mentioned in another interview that we heard – I believe it was on NPR, Terry Gross – that your book doesn’t detail illegal activity of the Carlyle Group. And whether that exists or not, you don’t know. But it details the legal activity, which is, to you, probably the more worrisome issue – that all of this is legal. By that, do you mean the seamless relationship between the private military sector and the governmental military sector?

BRIODY: That’s exactly what I mean. The book opens up with a mention of Dwight Eisenhower’s farewell speech, in which he warned the country against the formation of this military-industrial complex. And I think that that is exactly what we’re seeing today. We’re seeing a very tight-knit group of companies and private military contractors that are virtually indistinguishable from various administrations and the political infrastructure of Washington, D.C. – so much so that it’s not clear whose interests we’re acting on when we go to war.

BUZZFLASH: And now we see the extension in the case of Britain, to the British defense intelligence industry.

BRIODY: Right. And we’re also seeing Carlyle expand into Italy. They just bought part of Fiat’s aerospace division, which was a state-controlled Italian military agency. And they are also in the running to buy out DaimlerChrysler’s aerospace division in Germany. So we’re seeing a real broadening of the military activity around the Carlyle Group, so much so that’s becoming more than just a domestic concern here – it’s becoming an international concern.

BUZZFLASH: Now Carlyle is – correct me if I’m wrong – a holding company. Is it publicly traded?

BRIODY: It is not publicly traded.

BUZZFLASH: So it’s a limited partnership?

BRIODY: Yes. It’s a limited partnership. And as such, it’s under no obligation to release any of its financial data. So it’s very difficult for the average citizen to find out what the holdings of this company are and where the conflicts of interest might be. You may have noticed that they ''opened up'' their website recently because they were receiving a lot of criticism for being secretive and closed up. But they’re still controlling what information they’re putting on that website, so it’s not like we’re getting a look under the hood, so to speak, of this company. And they’ll never go public. They would never do that.

BUZZFLASH: Now probably the most controversial relationship is the relationship of former President Bush to the company. As you point out, so many of the members of the cast of characters in the Carlyle Group have been associated with past administrations, particularly Reagan and Bush’s. Former President Bush has probably the highest profile relationship. What is his relationship to the Carlyle Group, and what has he been used for?

BRIODY: George Bush Sr. is a senior advisor to the company -- again, an ambiguous term -- but essentially his role is to travel abroad and meet with foreign business leaders and foreign heads of state, give speeches on behalf of the Carlyle Group, and pack the house full of wealthy investors who will contribute to Carlyle’s buyout fund. And also he has had his hand in a number of deals for Carlyle. He has worked closely with business leaders in South Korea and in Saudi Arabia. He’s very close with the bin Laden family. He’s close with the royal family in Saudi Arabia. So he’s been very, very involved and a very effective business partner for the Carlyle Group for a number of years now.

BUZZFLASH: Is there cause to be concerned? Some people who cover Carlyle also mention that one shouldn’t solely focus on him, because he sort of jumps in and out. It’s more the day-to-day people who cross back and forth between their relationships with government officials and the private industry – the military-industrial complex, if you will, as Eisenhower called it. But former President Bush is the most visible symbol. Do you have any speculation on how that might impact foreign policy, since he’s the father of the current president?

BRIODY: There have been numerous reports that have been widely circulated, and not disputed, by the New York Times, Wall Street Journal, of how the father of the president is advising his son on foreign policy. Certainly in the first year, he was very active in advising his son on policy toward Korea and toward Saudi Arabia. And in both cases, he stepped in and placed phone calls himself to the leaders of those nations to try to smooth things over for his son, who was struggling a little bit in the early going, in dealing with some of those more sensitive areas. So I think that the impact of the father on the son in foreign policy has been very significant and very inappropriate, given the investments of George Bush Sr.’s company in both regions – in both the Korean peninsula and in Saudi Arabia.

BUZZFLASH: On pages 144 to 146, you discuss a little bit of the relationship between Carlyle and the bin Laden family. Can you just mention that in passing, and what that relationship was and perhaps is now?

BRIODY: The Carlyle Group started working in Saudi Arabia in the early ‘90s through a Saudi prince, who is one of the biggest foreign investors here in the United States. And through that relationship, they started expanding their business in Saudi Arabia very significantly. One of the most important investors that they found in the kingdom was the bin Laden family, which, of course, owns the Saudi Binladin Group. It's about a $5 billion construction company -- extremely wealthy family, extremely successful company, and who officially disavowed Osama bin Laden back in the early ‘90s.

So they had been doing business with the bin Laden family for, give or take, five or six years, when Sept. 11 happened. And suddenly, Osama bin Laden became public enemy number one. He was on the cover of all the newspapers. And it came to light that this company that was employing George Bush Sr. counted the bin Laden family among their investors. And they had to divest themselves from that relationship because of the criticism.

BUZZFLASH: And although you don’t mention it, there are those, including author Greg Palast, who have claimed that the Bush administration ferreted out members of the bin Laden family on special planes after Sept. 11. But again, that’s not a part of what’s in your book, but we’re just pointing that out.

Let’s look at United Defense as one example of the relationship between the private industry, the defense industry, and, in this case, it’s a publicly held company owned by the privately held Carlyle Group. Is that correct?

BRIODY: That’s right. And they own 50% of it.

BUZZFLASH: And what is United Defense? Maybe you can give us as a case study of the interrelationship between a company that has an umbilical cord to the U.S. government, about how a company like that is never a loser.

BRIODY: United Defense is a classic military contractor. They make guns and gun systems, large Howitzer-type, mobile Howitzers. They make the Bradley fighting vehicles and the Paladin gun systems that we’ve seen a lot of on TV, especially during the Iraqi war. They are one of the largest defense contractors to the Army in the nation. And the Carlyle Group has owned this company since 1997.

When they bought the company, there was a gun program that was the future of United Defense. It was a gun called the Crusader. It was essentially a next-generation Paladin gun system – a very large, mobile Howitzer. It looks like tank, but it’s essentially an enormous gun. And the Crusader was heavily criticized by a national defense panel that was put together to assess the military requirements going forward. It was called too heavy, too slow – a Cold War relic. And it was on the chopping block for years after that. But the Carlyle Group was able to mount a very successful campaign by using strategically placed lobbyists, by extending their personal relationships with folks in the Pentagon and in Washington, and by waging essentially a public relations campaign for the gun, and they kept it alive through successive rounds of defense budget cuts – miraculously.

No one could believe that this gun had survived as long as it did. And then finally after Sept. 11, when all ships were sort of, you know, rising on the tide of defense spending, they were able to take United Defense public, make hundreds of millions of dollars off of that IPO, only to then finally have the Crusader program cancelled in a very public fashion by Donald Rumsfeld in an announcement. But of course, behind the scenes, what the public didn’t see was that United Defense was awarded a brand-new contract for a brand-new gun that very same day that the Crusader program was cancelled. In fact, the press release that United Defense put out about it had the announcement of the new contract in it as well.

BUZZFLASH: So they were essentially held harmless.

BRIODY: Yes, exactly.

BUZZFLASH: Perhaps this is more of a comment, but we found it not-so-curious that after the controversial visit of Bush to the U.S.S. Abraham Lincoln in the flight suit, that he returned to California from 30 miles offshore and gave a speech at, of all places, the United Defense plant. Do you have any thoughts there about the fact the President of the United States is speaking at a plant that is 50% owned by a company that his father is a consultant with?

BRIODY: I think it’s brazen, and I think it’s shameless. And I think that that will go down as a hallmark of this administration. We have seen an absolute affinity for mixing business and politics, and throw in a war and you’ve got the Bush administration. And that scene of him giving that speech at United Defense’s plant in Santa Clara summed up perfectly what this administration is all about.

BUZZFLASH: So all the interconnections were right there — he was boosting the war effort, talking about keeping the country secure, which meant, in this case, he was praising the employees of United Defense, who, in essence, are employees, in part, of the Carlyle Group, with which his father is affiliated.

BRIODY: He was doing it all. He was pitching a tax cut for the very wealthy while doing an advertisement for his father’s company, and professing the war to be over, and kicking off his reelection campaign, all in one fell swoop. It was an amazing achievement.

BUZZFLASH: And yet for all these connections, I did not see any of them in the press. I only made them because of your book, and knowing about the Carlyle Group, and just going back and confirming that United Defense was, in essence, a company that the Carlyle Group had ownership of.

BRIODY: It was missed by most of the mainstream media, and that was very disappointing. But The Nation picked up on it, thank God.

BUZZFLASH: Going in another direction, you detail how the firm, when it was opened in 1987, picked the name, “the Carlyle Group.”

BRIODY: Well, the co-founders, David Rubenstein and Stephen Norris, were, at the time, meeting frequently at this hotel on the Upper East Side of New York called the Carlyle Hotel. And the Carlyle was very, very, very opulent and it’s a very swanky establishment. It’s a beautiful hotel. And these guys were looking for a name that gave them a sense of legitimacy and credibility in the industry. They wanted something that was a little blue-blood, or, as Steve Norris put it, gave them a silk-stocking air. And so they thought that the Carlyle Group was the right way to go. And certainly it does have that blue-blood, old money kind of feel to it, even though it’s only 15 years old.

BUZZFLASH: Your book about the Carlyle Group, subtitled Inside the Secret World of Carlyle Group, is called The Iron Triangle. Why did you choose that title?

BRIODY: Well, “the iron triangle” is the euphemism that is employed in a number of different areas. But among the areas that it’s employed is this confluence of business and politics that Eisenhower was talking about when he referred to the military-industrial complex. This is a combination of power and influence that is very dangerous and can result in foreign policy decisions that are based solely on monetary concerns of very few people. And that’s what I think we’ve found here today.

BUZZFLASH: Recently we’ve read that the Carlyle Group is starting to dabble into media acquisition. Is that right? And if so, should we be worried about that?

BRIODY: Yes, they have picked up a couple media companies. They, for a while now, have owned a very popular publication called Le Figaro in France, and they have been expanding their media acquisitions. And I definitely think this is something that we should be concerned about. I mean, anytime you see a company that has this much political clout — and obviously has a political agenda — picking up media properties, you’ve got to be concerned, especially with the action that the FCC has taken so far this year. We’re looking at the potential for having a real controlling influence in the media. And I personally would not like to see Carlyle Group controlling the information that I receive on a daily basis.


[Notre recommandation est que ce texte doit être lu avec la mention classique à l'esprit, — “Disclaimer: In accordance with 17 U.S.C. 107, this material is distributed without profit or payment to those who have expressed a prior interest in receiving this information for non-profit research and educational purposes only.”.]


C for capitalism

The secretive Carlyle Group gives capitalism a bad name. But dismantling the whole system may be slightly over the top — The Iron Triangle: Inside the Secret World of the Carlyle Group, By Dan Briody

Jun 26th 2003, The Economist

ON the day Osama bin Laden's men attacked America, Shafiq bin Laden, described as an estranged brother of the terrorist, was at an investment conference in Washington, DC, along with two people who are close to President George Bush: his father, the first President Bush, and James Baker, the former secretary of state who masterminded the legal campaign that secured Dubya's move to the White House. The conference was hosted by the Carlyle Group, a private equity firm that manages billions of dollars, including, at the time, some bin Laden family wealth. It also employs Messrs Bush and Baker.

In the immediate aftermath of the attacks, when no one was being allowed in or out of the United States, many members of the bin Laden family in America were spirited home to Saudi Arabia. The revival of defence spending that followed greatly increased the value of the Carlyle Group's investments in defence companies.

The Carlyle Group is a godsend for conspiracy theorists who are convinced that the world is run by, and on behalf of, a shadowy network of wealthy men. Sure enough, it was not long before Cynthia McKinney, a Democrat member of Congress, pointed a finger at Carlyle, noting in an interview that “persons close to this administration are poised to make huge profits off America's new war” and that, despite “numerous warnings”, they did not alert the “people of New York who were needlessly murdered”. “What”, she asked, “do they have to hide?”

You need not be a conspiracy theorist, though, to be concerned about what lies behind Carlyle's success. Can a firm that is so deeply embedded in the iron triangle where industry, government and the military converge be good for democracy? Carlyle arguably takes to a new level the military-industrial complex that President Eisenhower feared might “endanger our liberties or democratic process”. What red-blooded capitalist can truly admire a firm built, to a significant degree, on cronyism; surely, this sort of access capitalism is for ghastly places like Russia, China or Africa, not the land of the free market?

Named after the luxurious New York hotel favoured by the firm's founders, Carlyle even got started by exploiting a tax loophole, a legitimate capitalistic activity, if not an honourable one. This particular loophole bizarrely allowed profitable American firms to enjoy a large tax break by buying the losses incurred by Eskimo-owned companies in Alaska. In 1987, this opportunity brought together a flamboyant dealmaker, Stephen Norris, who left Carlyle in 1995, with David Rubenstein, a former aide to President Carter and still the brains behind the firm.

After this initial success, though, the going got tougher. Carlyle missed out on several attractive deals while completing some duff ones, including buying a stake in Caterair International, a company that later collapsed under the weight of its junk-bond financing. Still, it did introduce them to a man who became well worth knowing: George W. Bush, a director of Caterair.

Carlyle really only took off after it hired Frank Carlucci, a former secretary of defence and deputy director of the CIA, in 1989. Mr Carlucci was able to open doors in Washington that had hitherto been closed to the firm, allowing it to participate in many lucrative deals.

Although Dan Briody's book is useful reading for anybody interested in American politics today, it tells Carlyle's story in the style of a Tom Clancy or John Grisham novel. This is rather a shame. Instead of expanding in an unrelenting tone of shocked disapproval, the author could have offered a serious view on a number of difficult questions.

For instance, if privatisation can increase the efficiency of the notoriously inefficient defence sector, how should the inherent political and security risks best be managed? Given that the rewards for success in the private sector so far exceed those for public service, how can talented people be persuaded to enter public service without their former private-sector activities becoming a source of suspicion?

While some former presidents are happy to play golf, others may feel they can still earn a decent living. What rules should govern the commercial activities of former President Bush; or, for that matter, former British prime minister, John Major; or former South Korean prime minister, Park Tae-joon—all of whom have taken the Carlyle nickel? Mr Bush senior receives private intelligence briefings that are not available to ordinary investors. Does his inside knowledge of, and possible influence over, the administration's political strategy towards, say, North Korea and Saudi Arabia directly benefit Carlyle? If so, does that constitute an unacceptable conflict of interest?

Perhaps there would be less reason to worry about Carlyle if there were rival clubs of ex-political heavyweights competing within the iron triangle. Alas, this firm seems to be an aspiring monopolist, hoovering up former public officials from across the political divide and, increasingly, from across the world. It is becoming more ambitious in Europe, and keenly eyeing China. Perhaps there would be less reason to worry if Carlyle's activities were more open—but as a private equity firm, it has largely escaped America's recent efforts to improve the governance and transparency of companies, which is unfortunate. At a time when America is aggressively promoting democracy and capitalism abroad, including by military means, it would be helpful if its politicians and businesses were regarded as cleaner than clean. Shrouded in secrecy, Carlyle calls capitalism into question.

The Iron Triangle: Inside the Secret World of the Carlyle Group. By Dan Briody. Wiley; 240 pages; $24.95 and £17.50


[Notre recommandation est que ce texte doit être lu avec la mention classique à l'esprit, — “Disclaimer: In accordance with 17 U.S.C. 107, this material is distributed without profit or payment to those who have expressed a prior interest in receiving this information for non-profit research and educational purposes only.”.]


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