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Case 2:17-cv-04438 Document 1 Filed 06/15/17 Page 1 of 251 Page ID #:1 1 DEBORAH CONNOR, Acting Chief Money Laundering and Asset Recovery Section (MLARS) 2 MARY BUTLER Chief, International Unit 3 WOO S. LEE Deputy Chief, International Unit 4 KYLE R. FREENY, Trial Attorney JONATHAN BAUM, Trial Attorney 5 Criminal Division United States Department of Justice 6 1400 New York Avenue, N.W., 10th Floor Washington, D.C. 20530 Telephone: (202) 514-1263 7 Email: [email protected] 8 SANDRA R. BROWN Acting United States Attorney 9 LAWRENCE S. MIDDLETON Assistant United States Attorney 10 Chief, Criminal Division STEVEN R. WELK 11 Assistant United States Attorney Chief, Asset Forfeiture Section 12 JOHN J. KUCERA (CBN: 274184) CHRISTEN A. SPROULE (CBN: 310120) 13 Assistant United States Attorneys Asset Forfeiture Section 14 312 North Spring Street, 14th Floor Los Angeles, California 90012 15 Telephone: (213) 894-3391/(213) 894-4493 Facsimile: (213) 894-7177 16 Email: [email protected] [email protected] 17 Attorneys for Plaintiff 18 UNITED STATES OF AMERICA 19 UNITED STATES DISTRICT COURT 20 FOR THE CENTRAL DISTRICT OF CALIFORNIA 21 22 UNITED STATES OF AMERICA, No. CV 17-4438 23 Plaintiff, VERIFIED COMPLAINT FOR 24 v. FORFEITURE IN REM 25 CERTAIN RIGHTS TO AND [18 U.S.C. § 981(a)(1)(A) and (C)] 26 INTERESTS IN THE VICEROY HOTEL GROUP, [F.B.I.] 27 28 Defendant. Case 2:17-cv-04438 Document 1 Filed 06/15/17 Page 2 of 251 Page ID #:2 1 The United States of America brings this complaint against the above-captioned 2 asset and alleges as follows: 3 PERSONS AND ENTITIES 4 1. The plaintiff is the United States of America. 5 2. The defendant in this action is Certain Rights to and Interests in the Viceroy 6 Hotel Group, (hereinafter, the “DEFENDANT ASSET”), more particularly described in 7 Attachment A. 8 3. The persons and entities whose interests may be affected by this action are 9 Low Taek Jho; Low Taek Szen; JW Hospitality (VHG Intl) Ltd.; FFP (Cayman) Ltd.; 10 Mubadala Development Company PJSC; Viceroy Hotel Group; and Jynwel Capital Ltd. 11 4. Contemporaneously with the filing of this complaint, plaintiff is filing 12 related actions seeking the civil forfeiture of the following assets (collectively, the 13 “NEW SUBJECT ASSETS”): 14 a. THE EQUANIMITY: All right and title to the yacht M/Y 15 Equanimity, including all appurtenances, improvements, and attachments thereon, and 16 all leases, rents, and profits derived therefrom. 17 b. PALANTIR STOCK: All right and interest in 2,500,000 shares of 18 Series D Preferred Stock in Palantir Technologies held by Tarek OBAID (“PALANTIR 19 STOCK”). 20 c. ELECTRUM ASSETS: All right and interest in the Electrum 21 Group, including (i) Global Holdings, L.P. (“Electrum Global”); (ii) TEG Global GP 22 Ltd.; and (iii) TEG Services Holding Inc. (“Electrum Services”) (collectively 23 “Electrum”), owned, held or acquired, directly or indirectly, by JW Aurum (Cayman) 24 Gp Ltd. (“JW Aurum”), including any right to collect and receive any profits and 25 proceeds therefrom, and any interest derived from the proceeds invested in the Electrum 26 Group by JW Aurum (hereinafter, “ELECTRUM ASSETS”). 27 d. “DUMB AND DUMBER TO” RIGHTS: All rights to and 28 interests in the motion picture “Dumb and Dumber To” belonging to Red Granite 2 Case 2:17-cv-04438 Document 1 Filed 06/15/17 Page 3 of 251 Page ID #:3 1 Pictures, a film production company located in Los Angeles, California 90069, 2 including copyright and intellectual property rights, as well as the right to collect and 3 receive any profits, royalties, and proceeds of distribution owned by or owed to Red 4 Granite Pictures or its affiliates and/or assigns in connection with its role in producing 5 “Dumb and Dumber To” (hereinafter, the “DUMB AND DUMBER TO RIGHTS”); 6 e. “DADDY’S HOME” RIGHTS: All rights to and interests in the 7 motion picture “Daddy’s Home” belonging to Red Granite Pictures, a film production 8 company located in Los Angeles, California 90069, including copyright and intellectual 9 property rights, as well as the right to collect and receive any profits, royalties, and 10 proceeds of distribution owned by or owed to Red Granite Pictures or its affiliates 11 and/or assigns in connection with its role in producing “Daddy’s Home” (hereinafter, 12 the “DADDY’S HOME RIGHTS”); 13 f. METROPOLIS POSTER: One framed, 3-sheet color lithograph 14 poster created by the German artist Heinz Schulz-Neudamm for the 1927 silent film 15 “Metropolis.” 16 g. ONE MADISON PARK CONDOMINIUM: All right and title to 17 the real property located in New York, New York1 owned by Cricklewood One 18 Madison LLC (“ONE MADISON PARK CONDOMINIUM”), including all 19 appurtenances, improvements, and attachments thereon, as well as all leases, rents, and 20 profits derived therefrom. 21 h. FLYWHEEL SHARES: All right and interest in the shares of 22 Flywheel common stock held or acquired by FW Sports Investments LLC. 23 i. 11.72-CARAT HEART-SHAPED DIAMOND: One 11.72-carat 24 heart-shaped diamond with GIA number 2155273833. 25 j. 8.88-CARAT DIAMOND PENDANT: One 8.88-carat fancy 26 intense pink diamond pendant surrounded by 11-carat fancy intense pink diamonds. 27 28 1 Pursuant to L.R. 5.2-1, residential addresses are listed by the city and state only. 3 Case 2:17-cv-04438 Document 1 Filed 06/15/17 Page 4 of 251 Page ID #:4 1 k. MATCHING DIAMOND JEWELRY SET: One 18-carat white 2 gold diamond jewelry set, including diamond necklace, diamond earring, diamond 3 bracelet, and diamond ring. 4 l. 11-CARAT DIAMOND EARRINGS: One pair of 18K white gold 5 diamond earrings consisting a 5.55-carat diamond with GIA number 2165455706 and a 6 5.49-carat diamond with GIA number 2165635932 7 m. MATCHING DIAMOND RING AND EARRINGS: One pair of 8 diamond earrings and matching diamond ring, consisting a 7.53-carat flawless type 2A 9 diamond with GIA number 2145864026, a 3.05-carat flawless type 2A diamond with 10 GIA number 2136117071, and a 3.08-carat flawless type 2A diamond with GIA number 11 2145977021. 12 n. PICASSO PAINTING: One painting entitled “Nature Morte au 13 Crane de Taureau” by Pablo Picasso. 14 o. BASQUIAT COLLAGE: One collage entitled “Redman One” by 15 Jean-Michel Basquiat. 16 p. ARBUS PHOTOGRAPH: One photograph entitled “Boy with the 17 Toy Hand Grenade” by Diane Arbus. 18 5. Plaintiff has previously filed the following complaints, seeking civil 19 forfeiture of the following assets (referred collectively, together with the NEW 20 SUBJECT ASSETS, as the “SUBJECT ASSETS”): 21 a. Case number CV 16-5362 DSF (PLAx), United States v. The Wolf of 22 Wall Street Motion Picture, Including any Rights to Profits, Royalties and Distribution 23 Proceeds owed to Red Granite Pictures, Inc. or its Affiliates and/or Assigns (“THE 24 WOLF OF WALL STREET”). 25 b. Case number CV 16-5368 DSF (PLAx), United States v. The Real 26 Property Known as The Viceroy L’Ermitage Beverly Hills (“the L’ERMITAGE 27 PROPERTY”). 28 4 Case 2:17-cv-04438 Document 1 Filed 06/15/17 Page 5 of 251 Page ID #:5 1 c. Case number CV 16-5369 DSF (PLAx) United States v. All Business 2 Assets of The Viceroy L’Ermitage Beverly Hills, Including All Chattels and Intangible 3 Assets, Inventory, Equipment, and All Leases, Rents and Profits Derived Therefrom 4 (“THE L’ERMITAGE BUSINESS ASSETS”). 5 d. Case number CV 16-5377 DSF (PLAx) United States v. Real 6 Property located in Beverly Hills, California (“HILLCREST PROPERTY 1”). 7 e. Case number CV 16-5371 DSF (PLAx) United States v. Real 8 Property Located in New York, New York (“PARK LAUREL CONDOMINIUM”). 9 f. Case number CV 16-5367 DSF (PLAx) United States v. One 10 Bombardier Global 5000 Jet Aircraft, Bearing Manufacturer’s Serial Number 9265 and 11 Registration Number N689WM, its Tools and Appurtenances, and Aircraft Logbooks 12 (“BOMBARDIER JET”). 13 g. Case number CV 16-5374 DSF (PLAx) United States v. Real 14 Property Located in New York, New York (“TIME WARNER PENTHOUSE”). 15 h. Case number CV 16-5378 DSF (PLAx) United States v. Real 16 Property located in Los Angeles, California (“ORIOLE MANSION”). 17 i. Case number CV 16-5375 DSF (PLAx) United States v. Real 18 Property Located in New York, New York (“GREENE CONDOMINIUM”). 19 j. Case number CV 16-5364 DSF (PLAx) United States v. Any Rights 20 to Profits, Royalties and Distribution Proceeds Owned by or Owed to JW Nile (BVI) 21 Ltd., JCL Media (EMI Publishing Ltd), and/or Jynwel Capital Ltd, Relating to EMI 22 Music Publishing Group North America Holdings, Inc., and D.H. Publishing L.P., Inc. 23 and D.H. Publishing L.P. (“EMI ASSETS”). 24 k. Case number CV 16-5370 DSF (PLAx) United States v. All Right to 25 and Interest in Symphony CP (Park Lane) LLC, Held or Acquired, Directly or 26 Indirectly, by Symphony CP Investments LLC and/or Symphony CP Investments 27 Holdings LLC, Including Any Interest Held or Secured by the Real Property and 28 Appurtenances Located at 36 Central Park South, New York, New York, Known as The 5 Case 2:17-cv-04438 Document 1 Filed 06/15/17 Page 6 of 251 Page ID #:6 1 Park Lane Hotel, Any Right to Collect and Receive Any Profits and Proceeds 2 Therefrom, and Any Interest Derived From the Proceeds Invested in The Symphony CP 3 (Park Lane) LLC by Symphony CP Investments LLC and Symphony CP (Park Lane) 4 LLC (“SYMPHONY CP (PARK LANE) LLC ASSETS”).
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