23. Between March 1992 and January 1996, in the Isle of Man, a self- governing British crown dependency located between Scotland and Northern Ireland in the Irish Sea, Sam Wyly established ten (I0) trusts and Charles Wyly established seven (7) trusts (collectively the "Offshore Trusts"), naming many ofthem for places or events ofpersonal significance. Among the Offshore Trusts' names, for example, were• Louisiana towns and schools associated with -the Wylys' youth, including Lake Providence, where the Wylys were born, Delhi, where the Wylys attended high school, 9 The Wylys Appointed Trusted Loyalists to Serve as "Protectors"29. Although the language ofthe trust agreements governing the Wylys' Offshore Trusts purported to confer upon the Offshore Trustees broad and exclusive authority to manage the trust assets, this authority was illusory. Under the trust agreements, trust Protectors were granted the right "to remove, appoint or replace any Trustee with or withput cause at any time," as well as the right to add or remove trust beneficiaries. Inpractice,theOffshoreTrustswerecontrolledbytheseProtectors,who .were Wyly-appointed loyalists whose livelihoods were dependent on the Wylys and whose function was to ensure that the Wylys' instructions for the Offshore Trusts were executed. 31. The Wylys employed a protocol for effecting transactions in their Offshore System. One or both ofthe Wylys conveyed instructions to the Protectors for transactions to be executed in their Offshore System. The Protectors, in tum, conveyed the instructions to the appropriate Offshore Trustee, who then implemented them by signing the necessary documentation, or, in the caseofissuer Securities transactions, by faxing the necessary trading instructions to Schaufele or his assistants; or, in the case of structured Issuer Securities transactions, by executing and returning the relevant portion .oftransaction documents that the Wylys had first negotiated through Sch