Dated 16 September 1987



            A Petition to the United States District Court

                 Salt Lake City in the state of Utah



                                By



                         Mr Bernard Braham



                                of

              2226 Harrison Glenview, Illinois 60025



                                For



The return of property taken from him 6th November 1986 by agents of

the Bureau of Alcohol, Firearms and Tobacco, a federal agency, for use

by them as evidence in the case of.



United Staes versus

Charles William Goff senior and

Charles Goff Junior and

American Research and Development Corporation, and all of

Salt lake City Utah.  Case # CR 861/168/S now pending before

The Honorable Judge David Sam, United States district court, Salt Lake

City, Utah



I, Bernard Braham respectfully petition this court to order the return

of my property without delay and regardless as to the outcome of the

above mentioned case. My property is being held in the custody of the

Bureau of Alcohol firearms and Tobacco in Salt Lake City Utah. Agent in

charge to date is Mr T Whitman.



My property is described as follows.

One American Model A180 .22 caliber machine gun serial # ARB 0161

One 16 inch barrel Serial# A00856

One wood shoulder stock and one Gun Gaurd carrying case

The property described was purchased by me from American Research and

Development Co in April of 86. It was purchased legally and in good

faith and was registerd to me by the National Firearms Act branch of

the Department of the Treasury on ATF form #3 a copy of which is attached.



I see no reason why this property should not be returned to me without

delay or what in fact reason exists for it's legal retention, possible

confiscation or destruction since it became my property in a legal and

proper manner regardless to the circumstances of theabove quoted

case. I had no choice but to surrender this property voluntarily as

an order for it to be seized would have been sought.

My property has been held for almost one year and I am sufferring a

considerable financial loss due to it's retention.



        I thank the court for it's consideration of this humber

petition.



        Respectfully,



        Bernard Braham