Ivanka Money Laundering Subpoena
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Case 1:18-Cv-09936-LGS Document 97 Filed 07/24/19 Page 1 of 26
Case 1:18-cv-09936-LGS Document 97 Filed 07/24/19 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------------------X : 7/24/2019 JANE DOE, et al., : Plaintiffs, : : 18 Civ. 9936 (LGS) -against- : : ORDER THE TRUMP CORPORATION, et al., : Defendants. : ------------------------------------------------------------- X LORNA G. SCHOFIELD, District Judge: This case concerns an alleged fraudulent scheme to promote certain third-party companies offering multi-level marketing and training programs. The Amended Complaint (the “Complaint”) asserts racketeering and conspiracy claims under the Racketeer Influenced and Corrupt Organizations Act, 18 U.S.C. § 1961 et seq. (“RICO”). The Complaint also asserts various state law claims. Defendants Donald J. Trump (“Trump”), The Trump Corporation, Donald Trump, Jr., Eric Trump and Ivanka Trump move to dismiss the Complaint for failure to state a claim and lack of subject matter jurisdiction under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). As discussed below, Defendants’ motion to dismiss is granted in part. The RICO claims are dismissed because the Complaint does not sufficiently plead that Defendants’ conduct was the proximate cause of Plaintiffs’ losses. Defendants’ motion to dismiss the state law claims is denied because the Court has subject matter jurisdiction under the Class Action Fairness Act, 28 U.S.C. § 1332(d) (“CAFA”). BACKGROUND The following facts are taken from the Complaint and are accepted as true only for purposes of this motion. See Doe v. Columbia Univ., 831 F.3d 46, 48 (2d Cir. 2016). Case 1:18-cv-09936-LGS Document 97 Filed 07/24/19 Page 2 of 26 A. -
1 of 93 1 2 3 4 5 6 7 8 a B C D E F G First Name Last Name City State Zip Country Willie Gobabis Omahe Ke 9000 NAMIBIA Z
A B C D E F G 1 First Name Last Name City State Zip Country Petition Comment Willie Gobabis Omahe 9000 NAMIBIA 2 ke zohaib jhelum 49600 PAKISTAN truth of mlm companies 3 4 Armando AZ 85257 USA 5 Yesenia CA 90063 USA Jayasankar Chennai Tamil 600034 INDIA Dear President, I am from India. Kindly ban the MLM companies nadu like AMWAY which is making false claim and cheating people of India.We people of India see you as a Different from other President's who ruled US> we see you next to Abraham Linkcon,JFK. we all hope that you will bring a Amendentment in the Senete to BAN MLM COMPANY AMWAY. 6 LONNIE & LACOMBE ALBER T4L 2N5 CANADA MERLO TA 7 SULZLE Londell & Jodie LACOMBE ALBER T4L 1P4 CANADA Sulzle TA 8 Petitions for Regulation of Multi-Level Marketing – PUBLIC 1 of 93 Gathered on http://www.pyramidschemealert.org A B C D E F G Dahya Des Plaines IL 60018 USA Government must take strong actions against all the pyramid and so called MLM schemes.common people fall for ir as they are pitched well and are very deceptive.For people awareness past records and investigations should be made to run again on TV and other medias. have been financially hurt by Amway/Quixtar,and finally left it.FTc especially should investigate the support systems so called motivational organisations associated with the Amway like BWW,LTD,WWDB,network21 and so on..who litterly sucks money out of the members by selling cds,videos,meetings,books and whatever they can.I humbly asks a Congressional Investigation of the FTC and SEC regarding enforcement of laws against Pyramid Selling Schemes, Multi-level Marketing Scams, Ponzi Investment Frauds, Bogus "Motivational organisations" and "Work from Home" Schemes. -
Page 02 April 04.Indd
ISO 9001:2008 CERTIFIED NEWSPAPER Thursday 4 April 2013 23 Jumada I 1434 - Volume 18 Number 5659 Price: QR2 Hassad buys Ruthless Real Indian basmati ease to rice firm 3-0 win Business | 21 Sport | 32 www.thepeninsulaqatar.com [email protected] | [email protected] Editorial: 4455 7741 | Advertising: 4455 7837 / 4455 7780 Emir meets Canadian minister OPINION Cabinet okays Influence of Iran, Brotherhood draft health on GCC states here is confu- Tsion insurance law among Gulf citizens about the role of Iran Govt to pay premiums of Qataris and its inter- Khalid Al Sayed vention in EDITOR-IN-CHIEF DOHA: The State Cabinet membership of a representative their domes- yesterday ratified the draft of Qatar 2022 supreme commit- tic affairs, law on mandatory health tee to the National Committee for and the role of Muslim insurance and referred it to Occupational Safety and Health Brotherhood, or what is called the Advisory Council for its established by cabinet Decree No. political Islam, which is domi- recommendations. (16) of the year 2011. nating the Arab Spring states. The law will facilitate imple- With the uprising in Syria mentation of the proposed Other cabinet decisions in its third year, it is clear for national health insurance scheme Other decisions of the meet- any observer that Iran has that will cover all citizens and ing include: Approving the draft spread its security and intel- expatriates, including visitors to bids regulation for Public Works ligence influence in the Gulf. the country. Authority. Recently, the Saudi Ministry The first phase of the manda- Approving the draft of Interior disclosed that it tory health insurance scheme is Memorandum of Understanding has busted an Iranian spy net- expected to be implemented by (MoU) in the field of urban plan- work comprising of 16 Saudis the end of this year. -
Roman Zastserinski: Hingega Asja Kallal
LHV ajakiri Nr 10 | Suvi 2010 INTERVJUU: Olli Rehn: Euroopa vajab reforme AJALUGU: Eesti majanduse tõusuaastad NÕUANNE: kuidas saab pangast laenu? BÖRSIETTEVÕTE: Premia sirutab tiibu GURU: Donald Trumpi trumbid Roman Zastserinski: hingega asja kallal PENSIONIFONDID: KLIENTE TULEB JÄRJEST JUURDE 2 RUBRIIK INVESTEERI! / KEVAD 2010 Koht, kus raha kasvab. JUHTKIRI 3 Sisukord Analüüs 4 Euroopa majanduskriis tähendab heaoluühiskonna lõppu. Intervjuu 9 Olli Rehni sõnul vajab Euroopa reforme. Investori ABC 12 Aktsiate noteerimine börsil aitab investeerimiseks raha leida. Börsiettevõte 14 Premia Foods täitis eesmärgid. Nõuanne 18 Mida pidada silmas pangast laenu küsimisel? Uudis 20 Investeeritav väärpaberitulu muutub eraisikutele maksuvabaks. Persoon 22 Kokk roman Zaštšerinski paneb oma ärisse kogu hinge. Ülevaade 26 Keeruline majandusolukord seab portfellihaldusele väljakutseid. Ajalugu Investeerimine ei ole loterii 28 Iseseisva Eesti majanduse esimesed head aastad olid 1924–1929. uvalisel hetkel suvaliste aktsiate ostmine ei ole investeeri- Guru mine – see on loterii. Mõnusat närvikõdi võib see küll 32 Donald Trumpi elu trumpide keskel. pakkuda, loteriid mängides aga raha ei teeni. Selleks, et Pensionifondid investeerimise abil oma kapitalile korralik tootlus tagada, 39 Kliente tuleb hoogsalt juurde. Stuleb tunda ettevõtteid, millesse raha paigutatakse, ning riike ja turge, kus need ettevõtted tegutsevad. Tuleb tunda ettevõtete Uudised 41 Euro ja krooni intressimäärad ühtsed. juhtkondi ja konkurente. Tuleb mõista äri ja investeerimisega Käivitasime videouudised. seotud riske ning globaalseid majandusprotsesse. Tuleb teada tohutult palju ja arvestada lõputu hulga teguritega. Pikaajaliselt LHV toetab edukas investeerimine on täiskohaga töö. 44 Viljandi pärimusmuusika festival kutsub. Enamikul meist paraku nii palju vaba aega ei ole ning seega Raamatud jääbki edukaks investeerimiseks järele põhimõtteliselt kolm 49 LHV raamatukogus leidub ka eestikeelset võimalust: investeerida aktiivselt juhitud fondidesse, järgida fi nantskirjandust. -
American Interest Policy, Politics & Culture Vol
THE RUSSIAN CONNECTION • PUTIN’S MODERATE FASCIST STATE American Interest Policy, Politics & Culture Vol. XII, No. 4 | March/April 2017 STRATEGIC CHOICES IN THE AGE OF TRUMP THE ART OF THE DEAL: FIVE EASY PIECES Philip Zelikow TRUMP’S NEW WORLD ORDER Niall Ferguson SAME WORLD, LONELY WORLD, COLD WORLD Adam Garfinkle A LETTER FROM THE EDITOR A Case of Schizophrenic Fear s Inauguration Day approaches on Friday as I write, I sense that most Ameri- cans (and probably others) are resigned to the fact that Donald Trump is A about to become President of the United States, and, cognitive dissonance being what it is, many have figured out ways to discount the potential downside of that onrushing reality. Fine; people do what they need to do. Some take comfort in the fact that several of Trump’s cabinet choices are not as scary as he is, but what is anyone to make of the fact that the better choices flat out disagree with the Presi- dent’s own high-profile policy pronouncements? Some take comfort in assuming the strength of American’s institutions, legal and otherwise, in preventing an unfit man from running the ship of state aground. Others just pray in very general terms. But here’s the problem for at least a few of us: If you know how cognitive disso- nance works, then you become self-conscious of the much-historically-rehearsed pro- cess of delusional fear abatement—and then it no longer works. That’s my problem: too much post-grad psych and history reading. -
Visa Account Updater Merchant List
Visa Account Updater Merchant List The Visa Account Updater (VAU) Merchant List includes all merchants enrolled as of May 1, 2016. It is consolidated in an attempt to relay the most relevant and meaningful merchant name as merchants enroll at differing levels: by subsidiary, franchise, or parent organization. Visa recommends that issuers and merchants do not actively market the service to cardholders because: 1. We do not have 100% penetration on all sides. 2. We cannot guarantee that the information exchange between the financial institution and merchant will occur in time for the cardholder's next billing. 3. Some merchants on this list may have only certain divisions or geographic regions participating. Therefore, we do not want to create an expectation that the service will address all account update issues for all merchants listed. Visa Confidential: This document contains Visa's proprietary information for use by Visa issuers, acquirers, merchants and their processors solely in support of Visa card programs. Disclosure to third parties or any other use is prohibited without prior written permission of Visa Inc. Merchant Name Web Site 1 Bloc LLC www.justmeans.com 100K Portfolio www.100kportfolio.com 100TB 121 Limited www.121Limited.com 125-Bonner & Partners www.agora-inc.com 1760335 ontario inc. www.cottagecountry.com 1800 Flowers 1-800-Flowers.com, Inc 190-Sovereign Society www.agora-inc.com 193-World Currency Watch www.agora-inc.com 195-Boom & Bust www.agora-inc.com 2 Checkout.Com. www.2co.com 2 Min Miracle 2-10 Holdco, Inc. www.2-10.com 2-10 Home Buyers Warranty www.2-10.com 21st Century Insurance and Financial Services www.21st.com 2251723 Ontario Inc. -
SKOLKOVO RESEARCH Emerging Russian Multinationals: Achievements and Challenges
SKOLKOVO RESEARCH EmERging RuSSiAn muLtinAtiOnALS: achiEVEmEntS And CHALLEngES nOVEmbER 2008 REpORt © mOSCOw SCHOOL Of mAnAgEmEnt SKOLKOVO RAnKing mEtHOdOLOgy © VALE COLumbiA CEntER fOR SuStAinAbLE intERnAtiOnAL inVEStmEnt, mOSCOw SCHOOL Of mAnAgEmEnt SKOLKOVO And EmERging mARKEt gLObAL pLAyERS pROjECt pARtnERS ExEcutivE summary the second annual survey of Russian multinational enterprises by the moscow School of management SKOLKOVO reveals a continuing global expansion of Russian firms. this study provides a starting point to evaluate future change to that trend from the current economic downturn. Russia’s top 25 multinationals – ranked by foreign assets – had, at the end of 2007, uS$90bn assets abroad and about uS$220bn in foreign sales (including exports), and employed nearly 140,000 persons in other countries. foreign assets have increased four times since 2004, and employment abroad has tripled. Russian multinationals are comparable to their counterparts in other bRiC countries by their foreign assets and growth rates. they lag way behind the world’s biggest multinationals – those from developed countries – but they grow much faster. while the foreign assets of Russia’s global players are still concentrated in Europe ( 52%), the move toward north America, Africa and Australasia is becoming more significant. Reflecting the country’s resource endowments, the biggest Russian multinationals are in extractive industries. three oil/gas firms – Lukoil, gazprom, tnK-bp, – and nine metals and mining firms, led by norilsk nickel, together account for 80% of the total foreign assets of the top 25. However, the dominance of oil/gas conglomerates in the transnationalization process is clearly decreasing: in 2004, they accounted for as much as 63% of aggregate foreign assets, compared to 44% in 2007. -
The Curious World of Donald Trump's Private Russian Connections
Russia & The West The Curious World of Donald Trump’s Private Russian Connections James S. Henry Did the American people really know they were putting such a “well-connected” guy in the White House? Throughout Donald Trump’s presidential campaign he expressed glowing admiration for Russian leader Vladimir Putin. Many of Trump’s adoring comments were utterly gratuitous. After his Electoral College victory, Trump continued praising the former head of the KGB while dismissing the findings of all 17 American national security agencies that Putin directed Russian government interference to help Trump in the 2016 American presidential election. As veteran investigative economist and journalist Jim Henry shows below, a robust public record helps explain the fealty of Trump and his family to this murderous autocrat and the network of Russian oligarchs. Putin and his billionaire friends have plundered the wealth of their own people. They have also run numerous schemes to defraud governments and investors in the United States and Europe. From public records, using his renowned analytical skills, Henry shows what the mainstream news media in the United States have failed to report in any meaningful way: For three decades Donald Trump has profited from his connections to the Russian oligarchs, whose own fortunes depend on their continued fealty to Putin.We don’t know the full relationship between Donald Trump, the Trump family and their enterprises with the network of world-class criminals known as the Russian oligarchs. Henry acknowledges that his article poses more questions than answers, establishes more connections than full explanations. But what Henry does show should prompt every American to rise up in defense of their country to demand a thorough, out-in-the-open congressional investigation with no holds barred. -
The Great Influence Scam Text: Debika
Hey lovelies! Are you interested in an incredible business opportunit that gives you the abilit to work from home? For decades now, network marketing companies have been dangling the promise of a rocketing income, flexible schedule and THE GREAT aspirational lifestle in front of people desperate for a lucky break. But what happens when the dream of direct sales starts INFLUENCE SCAM to look more like a nightmare? Debika Ray investigates. “I was in a religious cult in my youth—so I school girl, Mean Girls sort of stuff. There’s a ing Association, which represents the indus- quickly recognized the feeling,” says Charlote lot of adulation of the CEO, the woman who try, in 2017 there were 18.6 million direct-sell- over a confidential internet call from Australia. started the MLM, and that is quite typical be- ing representatives in the US—where most of She does not want to divulge her full name be- cause the founder is seen with almost religious these businesses are based—up from 15 million cause, she says, the subjects of this discussion fervor so there was nothing she could say that in 2007. MLMs account for about $34.9 billion are highly litigious. Charlote is part of the An- was wrong.” in sales. Many now operate in other developed ti-MLM Coalition—a group of activists striving The term “pyramid scheme” is ofen used countries, as well as in countries with growing to educate people about multi-level marketing. to describe these kinds of groups, but MLM consumer markets such as India and Mexico. -
A History of the Soviet Diaspora in the Post-Cold War Era (1989
A HISTORY OF THE SOVIET DIASPORA IN THE POST-COLD WAR ERA (1989- 2015): CASE STUDIES OF RUSSIAN-SPEAKERS IN SOUTH KOREA, CAMBODIA, AND THE NETHERLANDS by Dylan J. Harmon-Donovan, B.A. A thesis submitted to the Graduate Council of Texas State University in partial fulfillment of the requirements for the degree of Master of Arts with a Major in International Studies May 2015 Committee Members: Dennis J. Dunn, Chair Sarah Blue Paul Hart COPYRIGHT by Dylan J. Harmon-Donovan 2015 FAIR USE AND AUTHOR’S PERMISSION STATEMENT Fair Use This work is protected by the Copyright Laws of the United States (Public Law 94-553, section 107). Consistent with fair use as defined in the Copyright Laws, brief quotations from this material are allowed with proper acknowledgement. Use of this material for financial gain without the author’s express written permission is not allowed. Duplication Permission As the copyright holder of this work I, Dylan J. Harmon-Donovan, authorize duplication of this work, in whole or in part, for educational or scholarly purposes only. DEDICATION This is dedicated to my mother, Rachel Harmon, for always believing in me and for instilling in me a value in education. ACKNOWLEDGEMENTS Thanks to my committee members, the faculty at Texas State University, and all my fellow student colleagues for assisting me along the way. v TABLE OF CONTENTS Page ACKNOWLEDGEMENTS .................................................................................................v LIST OF ABREVIATIONS ........................................................................................... -
Xenophobia, Freedom of Conscience and Anti-Extremism in Russia in 2011
SOVA Center fOr InfOrmAtion And AnAlySIS Xenophobia, Freedom of Conscience and Anti-Extremism in Russia in 2011 A collection of annual reports by the SOVA Center for Information and Analysis moscow may 2012 UDC 323.1(470+571)(082.1)”2011” Contents BBC 66.094я43+66.3(2Рос),54я43 X44 Xenophobia, freedom of Conscience and Anti-extremism in russia in 2011: A collection of annual reports by the SOVA Center for Information and Analysis; [Alperovich Vera, Sibireva Olga, Verkhovsky Alexander, Yudina Natalia] – М.: SOVA Center, 2012. – 151 pp.: tables (Academic publication) Vera Alperovich, Alexander Verkhovsky, Natalia Yudina Between Manezhnaya and Bolotnaya: Xenophobia and radical ISBN 978-5-98418-024-5 nationalism in Russia, and efforts to counteract them in 2011 ........................5 This collection of reports summarizes all the major areas of work addressed by the Summary ...............................................................................................5 SOVA Center for Information and Analysis in 2010, in a similar fashion to collections in previous years. Criminal manifestations of racism and xenophobia .................................7 There are three reports on themes which have become traditional for the SOVA Systematic racist and neo-nazi violence ....................................... 7 Center in this collection: The first report addresses radical nationalism and hate crime, and the efforts of government and society to combat these phenomena. The second report Anti-State terrorist activities ...................................................... 10 addresses problems relating to freedom of conscience in contemporary Russia. The third Threats to public officials and civic activists, report addresses the misuse and abuse of ‘anti-extremism’ measures. The reports are updated versions of original texts on the SOVA Center website. punishing “traitors” ................................................................... 11 The appendix provides details about hate crimes and the prosecution of such crimes. -
Pyramid Politics: the FTC’S Long History of Protecting “Multi-Level Marketing” by Robert L
Pyramid Politics: The FTC’s Long History of Protecting “Multi-Level Marketing” by Robert L. FitzPatrick Introduction: An overview and history of the political power of “multi-level marketing” to prevent regulation and law enforcement must begin at the end, with the election of Donald Trump. Yet, the appearance of a dramatic breakthrough is an illusion. MLM has controlled the Federal Trade Commission and prevented criminal fraud prosecutions for at least 30 years and its influence- buying is bi-partisan. The Trump election, however, does signify an extraordinary surge in political influence. Previous administrations have shown disregard for the damage and deception caused by MLMs on Main Street, yet the Trump presidency represents the first time that the president himself is a MLM leader and promoter. And whereas past presidents made appointments or their appointees made appointments that protected pyramids, the Trump presidency has appointed individuals who are themselves involved in MLM as major owners or spouses of owners, spokesmen of MLMs or major shareholders and aggressive defenders of these types of schemes, from which they are directly profiting. • President-elect Donald Trump himself owned an MLM. It was called Trump Network and promoted so-called health products.1 It collapsed and its assets were sold in less than two years. This is in addition to his ownership of the MLM-like “Trump University” (a close cousin to Herbalife's Latino-targeting “Universidad del Exito”, (Success University). For Trump University's deceptions and consumer losses, Donald Trump agreed in a court settlement to pay $25 million in restitution to victims (Herbalife was required to pay $200 million for deceiving its victims).