 Second, he allegedly told the staff of Daniel Sudnick, a senior U.S. adviser to the Iraqi Ministry of Communications, that there would be "hell to pay" if the contract for a first responder communication system did not include a provision holding out the possibility of later expansion to a nationwide commercial CDMA network, instead of ruling out CDMA.Third, Shaw sought to have the Iraqi communications minister replaced with Sami al-Majoun, his deputy minister, who was in the Liberty Mobile consortium.Sudnick requested an investigation of Shaw's conduct.