Case 2:20-cv-05911 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 20-5911 14 Plaintiff, VERIFIED COMPLAINT FOR 15 v. FORFEITURE IN REM 16 REAL PROPERTY LOCATED IN [18 U.S.C. § 981(a)(1)(A) and (C)] 17 PARIS, FRANCE TITLED IN THE 18 NAME OF AVE RAPHAEL (PARIS) [F.B.I.] SCI, 19 20 Defendant. 21 The United States of America (the “government”) brings this complaint against 22 the above-captioned asset and alleges as follows: 23 PERSONS AND ENTITIES 24 1. The plaintiff is the United States of America. 25 2. The defendant in this action is real property located in Paris, France1 titled 26 in the name of Ave Raphael (Paris) SCI, including all appurtenances, improvements, and 27 28 1 Pursuant to L.R. 5.2-1, residential addresses are listed by the city and state only. Case 2:20-cv-05911 Document 1 Filed 07/01/20 Page 2 of 280 Page ID #:2 1 attachments thereon, as well as all leases, rents, and profits derived therefrom, as more 2 particularly described in Attachment A (“DEFENDANT ASSET”).