*After high-level Xe - Blackwater executives Gary Jackson and Dave Jackson met with company personnel to discuss ongoing U.S. Department of Justice investigations, company employees began to destroy documents and other evidence relating to the Moonen shooting and other legal proceedings.

*Illegal Xe - Blackwater conduct is captured on videotape and audiotape, but rarely reported or punished. Records of illegal conduct are routinely destroyed by the defendants.

*Company mercenaries who murdered innocent Iraqis ("bad shoots") were not disciplined or fired or placed on a "do not use" list. Instead, Xe - Blackwater continued to rehire and deploy mercenaries known to have killed innocents.

*Heavily armed "shooters" were routinely sent by Xe - Blackwater into the streets of Baghdad under the influence of steroids and other judgment-altering substances.

*Xe - Blackwater - which suggests that it primarily uses retired American military personnel - has hired former military personnel from at least a dozen nations. Some recruits and hires are known to have been involved in human rights abuses in Latin America and elsewhere. The defendants also hire and deploy to Iraq foreign nationals even though they were forbidden by the laws of their country from serving as mercenaries.

*The widow of Mr. Sa'adoon was promised a series of payments to compensate for the death of her husband. Xe - Blackwater paid a small sum initially, but then made no further payments.