Case 2:20-cv-08466 Document 1 Filed 09/16/20 Page 1 of 300 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 2:20-cv-8466 14 Plaintiff, VERIFIED COMPLAINT FOR 15 v. FORFEITURE IN REM 16 ALL FUNDS HELD IN ESCROW BY [18 U.S.C. § 981(a)(1)(A) and (C)] 17 CLYDE & CO. IN THE UNITED 18 KINGDOM AS DAMAGES OR [F.B.I.] RESTITUTION IN PETROSAUDI V. 19 PDVSA UNCITRAL ARBITRATION, 20 Defendant. 21 22 The United States of America (the “government”) brings this complaint against 23 the above-captioned asset and alleges as follows: 24 PERSONS AND ENTITIES 25 1. The plaintiff is the United States of America. 26 2. The defendants in this action are all funds held in escrow by Clyde & Co. in 27 the United Kingdom as damages or restitution in the 2017 UNCITRAL arbitration 28 Case 2:20-cv-08466 Document 1 Filed 09/16/20 Page 2 of 300 Page ID #:2 1 between PetroSaudi Oil Services (Venezuela) Ltd.