Case 2:20-cv-05916 Document 1 Filed 07/01/20 Page 1 of 280 Page ID #:1 1 DEBORAH CONNOR, Chief Money Laundering and Asset Forfeiture Section (MLARS) 2 MARY BUTLER, Chief, International Unit WOO S. LEE, Deputy Chief, International Unit 3 BARBARA Y. LEVY, Trial Attorney JOSHUA L. SOHN, Trial Attorney 4 JONATHAN BAUM, Trial Attorney Criminal Division 5 United States Department of Justice 1400 New York Avenue, N.W., 10th Floor 6 Washington, D.C. 20530 Telephone: (202) 514-1263 7 Email:
[email protected] 8 Attorneys for Plaintiff 9 UNITED STATES OF AMERICA 10 UNITED STATES DISTRICT COURT 11 FOR THE CENTRAL DISTRICT OF CALIFORNIA 12 13 UNITED STATES OF AMERICA, No. CV 20-5916 14 Plaintiff, VERIFIED COMPLAINT FOR 15 v. FORFEITURE IN REM 16 ONE PAINTING ENTITLED [18 U.S.C. § 981(a)(1)(A) and (C)] 17 “COLORED CAMPBELL’S SOUP CAN 18 (EMERALD GREEN), 1965” BY ANDY [F.B.I.] WARHOL AND ONE PAINTING 19 ENTITLED “VÉTHEUIL AU SOLEIL” 20 BY CLAUDE MONET, 21 Defendants. 22 23 The United States of America (the “government”) brings this complaint against 24 the above-captioned assets and alleges as follows: 25 PERSONS AND ENTITIES 26 1. The plaintiff is the United States of America. 27 2. The defendants in this action are one acrylic, spray paint, and silkscreen ink 28 on linen painting entitled “Colored Campbell’s Soup Can (Emerald Green), 1965” by Case 2:20-cv-05916 Document 1 Filed 07/01/20 Page 2 of 280 Page ID #:2 1 Andy Warhol, and one oil on canvas painting entitled “Vétheuil au Soleil” by Claude 2 Monet, as more particularly described in Attachment A (“DEFENDANT ASSETS”).