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Baker & Hostetler LLP 45 Rockefeller Plaza New York, NY 10111 Telephone: 212.589.4200 Facsimile: 212.589.4201 David J. Sheehan Timothy S. Pfeifer Keith R. Murphy Denise D. Vasel Marco Molina A. Mackenna Mosier Brian F. Allen

Attorneys for Irving H. Picard, Trustee for the Substantively Consolidated SIPA Liquidation of Bernard L. Madoff Investment Securities LLC and Bernard L. Madoff

UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF NEW YORK

SECURITIES INVESTOR PROTECTION CORPORATION, SIPA LIQUIDATION

Plaintiff-Applicant, v. No. 08-01789 (BRL)

BERNARD L. MADOFF INVESTMENT (Substantively Consolidated) SECURITIES LLC,

Defendant. In re:

BERNARD L. MADOFF,

Debtor, IRVING H. PICARD, Trustee for the Liquidation of Bernard L. Madoff Investment Securities LLC, Adv. Pro. No. 10-05411 (BRL)

Plaintiff,

v.

SONJA KOHN, ERWIN KOHN, NETTY BLAU, AMENDED RICO CASE ROBERT ALAIN KOHN a/k/a AVRAHAM ZE’EV STATEMENT KAHAN, RACHEL KOHN, RINA HARTSTEIN

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(NÉE KOHN), MOISHE HARTSTEIN, MORDECHAI LANDAU, YVONNE LANDAU (NÉE KOHN), MICHAEL KOHN, NICOLE HERZOG (NÉE KOHN), ERKO, INC., WINDSOR

IBC, INC., EUROVALEUR, INC., INFOVALEUR, INC., YAKOV LANTZITSKY, TECNO DEVELOPMENT & RESEARCH S.R.L., I- TECHNOLOGY SOLUTIONS, INC., RENATO FLORIO, MARIADELMAR RAULE, TECNO DEVELOPMENT & RESEARCH LTD., SHLOMO (MOMY) AMSELEM, HERALD ASSET MANAGEMENT LTD., FRANCO MUGNAI, PAUL DE SURY, DANIELE COSULICH, 20:20 MEDICI AG f/k/a BANK MEDICI AG, ABSOLUTE PORTFOLIO MANAGEMENT LTD., MEDICIFINANZ CONSULTING GMBH, MEDICI S.R.L., MEDICI CAYMAN ISLAND LTD., BANK MEDICI AG (GIBRALTAR), PETER SCHEITHAUER, ROBERT REUSS, HELMUTH FREY, MANFRED KASTNER, JOSEF DUREGGER, ANDREAS PIRKNER, WERNER TRIPOLT, ANDREAS SCHINDLER, SUSANNE GIEFING, UNICREDIT BANK AUSTRIA AG, GERHARD RANDA, STEFAN ZAPOTOCKY, FRIEDRICH KADRNOSKA, URSULA RADEL- LESZCZYNSKI, WERNER KRETSCHMER, WILHELM HEMETSBERGER, PETER FISCHER, HARALD NOGRASEK, BANK AUSTRIA WORLDWIDE FUND MANAGEMENT LTD., BANK AUSTRIA CAYMAN ISLANDS LTD., UNICREDIT S.P.A., ALESSANDRO PROFUMO, GIANFRANCO GUTTY, PIONEER GLOBAL ASSET MANAGEMENT, S.P.A., SOFIPO AUSTRIA GMBH, M-TECH SERVICES GMBH, MARKETINC STRATEGIES LTD., EASTVIEW SERVICES LTD., SYSTOR S.A., IT RESOURCES, BRIGHTLIGHT TRADING LTD., FINTECHNOLOGY LTD., TONGA INTERNATIONAL S.A., LIFETRUST AG, PRIVATLIFE AG, STARVEST ANSTALT, NEW ECONOMY.TECH S.A., RTH AG, ECOINFO GMBH, REDCREST INVESTMENTS, INC., LINE GROUP LTD., LINE MANAGEMENT SERVICES LTD., LINE HOLDINGS LTD., HERALD CONSULT LTD., SHAREI HALACHA JERUSALEM, INC., JOHN AND JANE DOE

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DEFENDANTS 1-100.

Defendants.

PLAINTIFF’S AMENDED RICO CASE STATEMENT

Plaintiff Irving H. Picard (the “Trustee”), as Trustee for the liquidation of the business of Bernard L. Madoff Investment Securities (“BLMIS”) and the substantively consolidated estate of Bernard L. Madoff (“Madoff”) under the Securities Investor Protection Act, 15 U.S.C. §§ 78aaa et seq. (“SIPA”), by his undersigned counsel, submits this Amended RICO Case Statement and accompanying Second Amended Complaint (which this Amended RICO Case Statement incorporates by reference) based on the information currently available to the Trustee. Given the scope of Madoff’s Ponzi scheme (the “Ponzi scheme”), the deceptive nature of Defendants,1 and the deliberately Byzantine structure of the Medici Enterprise, certain information about the Illegal Scheme has been purposefully concealed from the Trustee (and the United States and certain U.S. and foreign law enforcement and regulatory agencies) and will only become available through discovery. The Trustee reserves his right to amend this Amended RICO Case Statement and accompanying Second Amended Complaint as information is learned and discovery is obtained. The information contained in the Amended RICO Case Statement tracks the information contained in the Second Amended Complaint.

1 The Trustee asserts against Sharei only U.S. and New York State bankruptcy claims and has voluntarily dismissed Palladium Capital Advisors LLC, Gianfranco Gutty, and Friedrich Kadrnoska from the action.

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a. State whether the alleged unlawful conduct is in violation of 18 U.S.C. §§ 1962 (a), (b), (c) and/or (d):

Defendants’ unlawful conduct in furtherance of the Illegal Scheme is in violation of 18 U.S.C. §§ 1962(c) and (d). As set forth fully herein, and as alleged in the accompanying Second Amended Complaint, Defendants conducted and/or participated, both directly and indirectly, in the conduct of an enterprise through a pattern of racketeering activity, and they further willfully combined, conspired, and agreed to violate 18 U.S.C. §§ 1962(c); that is, to participate directly or indirectly in the conduct of the affairs of the enterprise through a pattern of racketeering activity in violation of 18 U.S.C. § 1962(d).

Defendants’ racketeering activity consisted of repeated and related acts of: (i) money laundering in violation of 18 U.S.C. § 1956; (ii) engaging in monetary transactions in property derived from specific unlawful activity in violation of 18 U.S.C. § 1957; (iii) wire fraud in violation of 18 U.S.C. § 1343; (iv) financial institution fraud in violation of 18 U.S.C. § 1344; (v) mail fraud in violation of 18 U.S.C. § 1341; (vi) transporting funds taken by fraud in violation of 18 U.S.C. § 2314; (vii) transportation of persons to defraud in violation of 18 U.S.C. § 2314; (viii) receiving funds taken by fraud in violation of 18 U.S.C. § 2315; and (ix) interstate and international travel in violation of the Travel Act, 18 U.S.C. § 1952.

b. List each Defendant and describe the alleged misconduct and basis of liability of each Defendant:

The members of the Medici Enterprise are grouped according to their main affiliation:

A. KOHN FAMILY DEFENDANTS

1. Sonja Kohn (“Kohn”) 2. Erwin Kohn (“E. Kohn”) 3. Netty Blau (“Blau”) 4. Moishe Hartstein (“M. Hartstein”) 5. Rina Hartstein (“R. Hartstein”) 6. Mordechai Landau (“Landau”) 7. Yvonne Landau (“Y. Landau”) 8. Robert Alain Kohn (“R. Kohn”) 9. Rachel Kohn (“Ra. Kohn”) 10. Michael Kohn (“M. Kohn”) 11. Nicole Herzog (“Herzog”)

B. KOHN SHAM ENTITY DEFENDANTS

1. Kohn’s New York Sham Entity Defendants

a. Erko, Inc. (“Erko”) b. Eurovaleur, Inc. (“Eurovaleur”) c. Infovaleur, Inc. (“Infovaleur”) d. Robert Reuss (“Reuss”)

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e. Yakov Lantzitsky (“Lantzitsky”) f. Windsor IBC, Inc. (“Windsor”)

2. Kohn’s Canadian Sham Entity Defendant

a. I-Technology Solutions, Inc. (“I-Tech”)

3. Kohn’s Caribbean Sham Entity Defendants

a. Herald Asset Management Ltd. (“HAM”) b. Franco Mugnai (“Mugnai”) c. Paul de Sury (“de Sury”) d. Daniele Cosulich (“Cosulich”) e. Marketinc Strategies Ltd. (“Marketinc”) f. Eastview Services Ltd. (“Eastview”) g. Systor S.A. (“Systor”) h. IT Resources (“ITR”) i. Brightlight Trading Ltd. (“Brightlight”) j. Fintechnology Ltd. (“Fintechnology”) k. Tonga International S.A. (“Tonga”)

4. Kohn’s Italian Sham Entity Defendants

a. Tecno Development & Research S.r.l. (“Tecno Italy”) b. Renato Florio (“Florio”) c. Mariadelmar Raule (“Raule”)

5. Kohn’s Gibraltar Sham Entity Defendants

a. Tecno Development & Research Ltd. (“Tecno Gibraltar”) b. Shlomo (Momy) Amselem (“Amselem”)

6. Kohn’s Liechtenstein Sham Entity Defendants

a. Lifetrust AG (“Lifetrust”) b. PrivatLife AG (“PrivatLife”) c. Starvest Anstalt (“Starvest”)

7. Kohn’s Swiss Sham Entity Defendants

a. New Economy.Tech S.A. (“New Economy”) b. RTH AG (“RTH”) c. EcoInfo GmbH (“EcoInfo”)

8. Kohn’s Austrian Sham Entity Defendants

a. Sofipo Austria GmbH (“Sofipo”)

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b. M-Tech Services GmbH (“M-Tech”)

C. BANK MEDICI DEFENDANTS

1. Bank Medici Corporate Defendants

a. Bank Medici AG (“Bank Medici”) b. Absolute Portfolio Management Ltd. (“APM Cayman”) c. MediciFinanz Consulting GmbH (“MediciFinanz”) d. Medici S.r.l. (“Medici S.r.l.”) e. Medici Cayman Islands Ltd. (“Medici Cayman”) f. Bank Medici AG (Gibraltar) (“Bank Medici Gibraltar”)

2. Bank Medici Individual Defendants

a. Peter Scheithauer (“Scheithauer”) b. Helmuth Frey (“Frey”) c. Manfred Kastner (“Kastner”) d. Andreas Pirkner (“Pirkner”) e. Werner Tripolt (“Tripolt”) f. Andreas Schindler (“Schindler”) g. Susanne Giefing (“Giefing”)

D. FINANCIAL INSTITUTION DEFENDANTS

1. Bank Austria Corporate Defendants

a. UniCredit Bank Austria AG (“Bank Austria”) b. Bank Austria Worldwide Fund Management Ltd. (“BA Worldwide”) c. Bank Austria Cayman Islands Ltd. (“Bank Austria Cayman”)

2. Bank Austria Individual Defendants

a. Gerhard Randa (“Randa”) b. Friedrich Kadrnoska (“Kadrnoska”) c. Stefan Zapotocky (“Zapotocky”) d. Ursula Radel-Leszczynski (“Radel-Leszczynski”) e. Josef Duregger (“Duregger”) f. Peter Fischer (“Fischer”) g. Werner Kretschmer (“Kretschmer”) h. Wilhelm Hemetsberger (“Hemetsberger”) i. Harald Nograsek (“Nograsek”)

3. UniCredit Corporate Defendants

a. UniCredit S.p.A. (“UniCredit”) b. Pioneer Global Asset Management S.p.A. (“Pioneer”)

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4. UniCredit Individual Defendants

a. Alessandro Profumo (“Profumo”) b. Gianfranco Gutty (“Gutty”)

E. KOHN’S HOLDING COMPANY DEFENDANTS

1. Redcrest Investments, Inc. (“Redcrest”) 2. Line Group Ltd. (“Line Group”) 3. Line Management Services Ltd. (“Line Management”) 4. Line Holdings Ltd. (“Line Holdings”) 5. Herald Consult Ltd. (“Herald Consult”)

F. SUBSEQUENT TRANSFEREE DEFENDANT

1. Sharei Halacha Jersusalem, Inc. (“Sharei”)

G. JOHN AND JANE DOE DEFENDANTS 1-100

The relevant Non-Defendant Bad Actors are grouped according to their main affiliation:

H. BERNARD L. MADOFF INVESTMENT SECURITIES LLC

1. Bernard L. Madoff Investment Securities LLC (“BLMIS”)

a. Bernard L. Madoff (“Madoff”) b. Frank DiPascali (“DiPascali”)

2. Cohmad Securities Corporation (“Cohmad”)

a. Cohmad Securities Corporation b. Maurice (Sonny) Cohn (“Cohn”)

3. Madoff Securities International Ltd. (“MSIL”)

a. Leon Flax (“Flax”) b. Steven Raven (“Raven”)

I. MEDICI ENTERPRISE FEEDER FUNDS

1. Primeo Fund (“Primeo Fund”) 2. Thema International Fund plc (“Thema International”) 3. Alpha Prime Fund Ltd. (“Alpha Prime Fund”) 4. Herald Fund SPC (“Herald Fund”) 5. Senator Fund SPC (“Senator Fund”) 6. Herald (Lux) SICAV (“Herald (Lux)”)

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J. ITALIAN INSTITUTIONS AND AGENTS

1. Intesa Sanpaolo S.p.A. (“Banca Intesa”) 2. FundsWorld Financial Services Ltd. (“FundsWorld”) 3. Brera Servizi Aziendiale S.r.l. (“Brera”) 4. Dario Frigerio (“Frigerio”) 5. Alberto La Rocca (“La Rocca”) 6. Paul Tiranno (“Tiranno”)

K. KOHN’S SLUSH FUND RECIPIENTS

1. Gerila Beteiligungsverwaltungs GmbH (“Gerila”) 2. Infotech Applications (“Infotech”) 3. Austrasia 4. Enchanted Rock Ltd. (“Enchanted Rock”) 5. A.L.A. 6. Hungarian Foreign Trade Bank (“MKB”) 7. Aurelia Worldwide S.A. (“Aurelia Worldwide”) 8. Tamiza Investments Ltd. (“Tamiza”) 9. Marina Ventures LLC (“Marina Ventures”)

L. BANK AGENTS

1. Hassans International Law Firm (“Hassans”) 2. Thema Asset Management Ltd. (“TAM”) 3. ReviTrust Services Est. (“Revi”) 4. HypoVereinsbank (“HVB”) 5. Wiener Stadtische Versicherung AG (“WSV”) 6. Friedrich Pfeffer (“Pfeffer”) 7. Helmut Horvath (“Horvath”) 8. Alexandra Lavi (“Lavi”) 9. Medici Realty Ltd. (“Medici Realty”)

M. SHAM ENTITY AGENTS

1. Alon Technology Ventures Ltd. (“Alon Technology”) 2. Anne Kritzer (“Kritzer”) 3. Susan Alexander (“Alexander”) 4. Aleksander Kampa (“Kampa”) 5. Thomas Grasso (“Grasso”)

N. KOHN’S OTHER NEW YORK AGENTS

1. Medici Fund Management Company, Inc. (“Medici Fund Management”) 2. Medici Finance Services, Inc. (“Medici Finance Services”)

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A. KOHN FAMILY DEFENDANTS

1. Sonja Kohn (“Kohn”). Kohn is the Mastermind of the Illegal Scheme and the Medici Enterprise. She is a citizen of Austria and resided in New York from 1983 to 1994. On information and belief, Kohn traveled to New York in relation to the Illegal Scheme as recently as late 2008. Although Kohn’s daughter and grandchildren live near New York City, Kohn has stayed outside the United States since Madoff confessed.

Kohn established and controls companies in New York that are her alter egos and are critical members of the Medici Enterprise. These include Eurovaleur, Infovaleur, Erko, and Windsor. Kohn and certain of her co-conspirators employed these members of the Medici Enterprise to further the Illegal Scheme. She also owns and controls certain Non-Defendant Bad Actors involved in the Illegal Scheme such as Medici Fund Management and Medici Finance Services in New York.

In the mid 1980s, while Kohn was living in New York and working at Merrill Lynch & Co., Cohn of Cohmad introduced Kohn to Madoff. Madoff paid Cohmad at least $526,000 for this introduction. Kohn and Madoff agreed that he would secretly pay Kohn for soliciting investors for BLMIS. Kohn immediately began soliciting investors for Madoff’s Ponzi scheme in New York, initiating the Illegal Scheme and laying the foundation for the Medici Enterprise.

Through Bank Medici, Kohn and others conspired to solicit investors in Madoff’s Ponzi scheme through Primeo Fund, Herald Fund, Thema International, Alpha Prime Fund, Senator Fund, and Herald (Lux) (collectively “the Medici Enterprise Feeder Funds”). With the assistance of Bank Austria, Bank Medici acquired an Austrian banking license in December 2003. Kohn, Bank Medici, HAM, Bank Austria (and later UniCredit), and others conspired to solicit investors for Madoff’s Ponzi scheme in the United States, Europe, the former Soviet Union, and elsewhere.

Kohn paid herself at least $800,000 in Customer Property from Infovaleur and at least $47,444 in Customer Property from Erko.

Kohn (herself and acting through HAM, Eurovaleur, Infovaleur, Erko, Tecno Italy, Tecno Gibraltar, and Windsor) committed acts of mail fraud, wire fraud, financial institution fraud, interstate and foreign travel in violation of the Travel Act, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, transporting funds taken by fraud, transporting of persons to defraud, receiving stolen funds, and conspiracy in furtherance of the Illegal Scheme.

2. Erwin Kohn (“E. Kohn”). Kohn’s husband, E. Kohn, is a resident of Switzerland and resided in New York from 1983 to 1994. E. Kohn is a member

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of the Medici Enterprise. E. Kohn furthered the Illegal Scheme by, among other things, traveling to London on behalf of Kohn’s New York Sham Entity Erko to collect illegal payments of stolen Customer Property2 from MSIL. E. Kohn is a director of Medici Realty in Gibraltar. Bank Medici Gibraltar and Hassans International Law Firm (“Hassans”) own Medici Realty. E. Kohn is the president and founder of Sharei, a New York company that received stolen Customer Property from Infovaleur. E. Kohn also served as a director of FundsWorld.

E. Kohn received slush fund payments of stolen Customer Property from Infovaleur totaling at least $115,146. On February 2, 2009, E. Kohn received $299,995 from Tecno Italy through his company Tamiza.

E. Kohn (himself and through Erko) committed acts of interstate and foreign travel in violation of the Travel Act, money laundering, wire fraud, engaging in monetary transactions in property derived from specific unlawful activity, transporting funds taken by fraud, transporting of persons to defraud, receiving stolen funds, and conspiracy in furtherance of the Illegal Scheme.

3. Netty Blau (“Blau”). Blau is Kohn’s mother. She is a citizen of Austria. Blau is a member of the Medici Enterprise. Blau owned and managed Kohn’s Italian Sham Entity, Tecno Italy. Blau conspired with Kohn, Raule, and Tecno Italy to receive at least $14,601,000 of stolen Customer Property in kickbacks from Madoff.

Blau received payments of stolen Customer Property from Erko totaling at least $3,146,223. Blau also received illicit payments from Eurovaleur totaling at least $57,360.

Blau (herself and through Tecno Italy) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, transporting funds taken by fraud, receiving stolen funds, and conspiracy in furtherance of the Illegal Scheme.

4. Moishe Hartstein (“M. Hartstein”). M. Hartstein is one of Kohn’s sons-in-law. M. Hartstein is a U.S. citizen and resident of New York. M. Hartstein is a member of the Medici Enterprise. M. Hartstein and Kohn’s daughter R. Hartstein live in a house sold to them by Kohn and E. Kohn on December 26, 2006. This residence also served as the mailing address for New York Sham Entity Infovaleur and R. Kohn. M. Hartstein and R. Hartstein are recipients of proceeds of the Illegal Scheme.

M. Hartstein conspired with Kohn to operate at least one of Kohn’s New York Sham Entities by acting as a broker for Eurovaleur. M. Hartstein was registered

2 SIPA § 78lll(4) defines “Customer Property” “as cash and securities . . . at any time received, acquired, or held by or for the account of a debtor from or for the securities accounts of a customer, and the proceeds of any such property transferred by the debtor, including property of unlawfully converted.”

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as a broker for Eurovaleur as of July 1998 in New York. As of December 10, 2009, M. Hartstein was registered as a broker with Eurovaleur. M. Hartstein, himself and through Marina Ventures received payments via check from Kohn’s Sham Entity Infovaleur. These payments began on February 19, 2003 and continued until at least March 5, 2009. In total M. Hartstein received at least $380,158 from Infovaleur.

M. Hartstein (himself and through Eurovaleur) committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

5. Rina Hartstein (“R. Hartstein”). R. Hartstein is Kohn’s and E. Kohn’s daughter. Upon information and belief, R. Hartstein is a U.S. citizen and resident of Monsey, New York. R. Hartstein is a member of the Medici Enterprise. R. Hartstein received payments via check from Kohn’s New York Sham Entity Infovaleur. In total, R. Hartstein received at least $28,272 from Infovaleur.

R. Hartstein committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

6. Mordechai Landau (“Landau”). Landau is another of Kohn’s sons-in-law. He is a resident of Israel. Landau is a member of the Medici Enterprise. Landau and Kohn jointly owned Austrian Sham Entity M-Tech. On December 29, 2006, Kohn sold her interest in M-Tech to Landau. On June 30, 2008 and July 18, 2008, M-Tech received payments of stolen Customer Property from Kohn’s New York Sham Entity Infovaleur. Landau personally received payments from Infovaleur totaling at least $15,000.

Landau (himself and through M-Tech) committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

7. Yvonne Landau (“Y. Landau”). Y. Landau is Kohn’s and E. Kohn’s daughter. Y. Landau is a member of the Medici Enterprise. Y. Landau and her husband, Landau, received payments of stolen Customer Property from Infovaleur. On January 6, 2009, Y. Landau received $16,659.

Y. Landau committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

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8. Robert Alain Kohn (“R. Kohn”). R. Kohn is Kohn’s and E. Kohn’s son. R. Kohn is a member of the Medici Enterprise. R. Kohn conspired with his mother and her New York Sham Entity Eurovaleur to further the Illegal Scheme. R. Kohn, like other Kohn Family Defendants, acted on behalf of Eurovaleur in furtherance of the Illegal Scheme. For example, between September 11, 2002 and January 6, 2009, R. Kohn received stolen Customer Property from Infovaleur totaling at least $60,038 and from Erko totaling at least $30,081. R. Kohn directs Sharei’s Israeli branch.

R. Kohn committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

9. Rachel Kohn (“Ra. Kohn”). Ra. Kohn is married to R. Kohn. Ra. Kohn is a member of the Medici Enterprise. On May 19, 2004, Ra. Kohn received $551,382 of Customer Property from Erko. Ra. Kohn is affiliated with Sharei.

Ra. Kohn committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

10. Michael Kohn (“M. Kohn”). M. Kohn is Kohn’s and E. Kohn’s son. M. Kohn is a member of the Medici Enterprise. M. Kohn received payments of Customer Property from Infovaleur totaling at least $462,491. M. Kohn has been affiliated with addresses in Monsey, New York as recently as January 2011.

M. Kohn committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

11. Nicole Herzog (“Herzog”). Herzog is Kohn’s and E. Kohn’s daughter. Herzog is a member of the Medici Enterprise. On June 24, 2002, Herzog received $90,000 of Customer Property from Infovaleur through her company Austrasia. On June 24, 2009, Herzog received $224,646 of Customer Property from Erko. Herzog is affiliated with Sharei.

Herzog committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

B. KOHN SHAM ENTITY DEFENDANTS

1. Kohn’s New York Sham Entity Defendants

a. Erko, Inc. (“Erko”). On April 15, 1987, Kohn incorporated Erko in New York. At all relevant times, she was the 100% owner and manager of Erko. Erko is a member of the Medici Enterprise. Erko is the general

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partner of the holding company that wholly owns another Kohn-owned New York Sham Entity, Windsor. At all relevant times Erko had no legitimate business purpose and existed only to receive stolen Customer Property from BLMIS and further the Illegal Scheme.

Erko employed certain individuals who worked for Kohn at Windsor. Madoff did not distinguish among Kohn’s Sham Entities and considered them all alter egos of Kohn. In furtherance of the Illegal Scheme, Kohn did not distinguish between her Sham Entities and treated them interchangeably.

As early as 1987, on information and belief, Erko, a New York entity, began receiving illegal kickbacks from Madoff. Even after Erko’s dissolution on June 24, 1998, Kohn continued receiving payments from Madoff at her childhood address in Vienna, Austria on behalf of Erko. In total, Erko received at least $11,058,054 from Madoff, all of which is stolen Customer Property.

Erko subsequently laundered Customer Property to Blau, Kohn, R. Kohn, E. Kohn, Ra. Kohn, Herzog, and Brightlight.

Erko committed acts of wire fraud, interstate and foreign travel in violation of the Travel Act, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, transportation of funds taken by fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

b. Eurovaleur, Inc. (“Eurovaleur”). Kohn incorporated Eurovaleur in New York on March 26, 1990 and she is its sole shareholder. Eurovaleur is a member of the Medici Enterprise. The company remains active in New York and Kohn is listed as its president and CEO. Eurovaleur functioned as an alter ego of Kohn and certain of the Kohn Family Defendants. Eurovaleur shared the same address as Kohn’s New York Sham Entity Infovaleur. Eurovaleur held itself out under various guises, including a fund of hedge funds, a New York registered brokerage, a provider of research services, and “a European boutique investment bank.”

At all relevant times, Eurovaleur had no legitimate business purpose and existed only to further the Illegal Scheme. As set forth fully below, Eurovaleur received illicit payments from BA Worldwide through 2007 and solicited investors for Madoff’s Ponzi scheme as early as 1991. Eurovaleur has a central role in the Medici Enterprise and the Illegal Scheme:

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 Kohn, through Eurovaleur, registered the “Primeo” trademark in New York in 1993 and transferred it to Bank Austria in December 2001.

 From 1994 until 2007, Eurovaleur served as the sub-adviser to BA Worldwide, the investment adviser to Primeo Fund.

 From 1994 until 2007, Eurovaleur received 20% of all fees paid to BA Worldwide by Primeo Fund.

 In addition to certain Kohn Family Defendants including M. Hartstein, Eurovaleur employed Reuss, Grasso, and Kritzer.

Eurovaleur received illicit payments from FundsWorld totaling at least €2,649,552. Eurovaleur also received $893,157 from Bank Austria’s Financial Services department, Finanzservice Gesmbh, from November 2006 through July 2007.

Eurovaleur transferred illicit payments in furtherance of the Illegal Scheme through its accounts at Bank Gutmann. Eurovaleur transferred $57,360 to Blau, $879,943 to Tonga, and $801,661 to Hassans.

Eurovaleur committed acts of wire fraud, financial institution fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, mail fraud, transportation of funds taken by fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

c. Infovaleur, Inc. (“Infovaleur”). On February 22, 1996, Kohn incorporated Infovaleur in New York. At all relevant times, she was the 100% owner and manager of Infovaleur. Infovaleur is a member of the Medici Enterprise. Throughout its existence, it has used the same New York mailing address as Kohn’s Eurovaleur and employed certain of the same individuals. Infovaleur also used the Hartsteins’ residence as a mailing address.

At all relevant times, Infovaleur had no legitimate business purpose and existed only to receive stolen Customer Property from BLMIS and further the Illegal Scheme. Since 1998, Infovaleur received at the very least $34,659,360 in illegal kickbacks from Madoff, all of which is stolen Customer Property. From 2000-2008 it was BLMIS’s third-highest paid “vendor.” As early as 2002, and as recently as 2009, after Madoff confessed to running a Ponzi scheme, Infovaleur transferred approximately $13,004,845.31 to Kohn, members of her family, close business associates, and other co-conspirators.

In furtherance of the Illegal Scheme, Kohn, through Infovaleur, transferred

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stolen Customer Property to herself, E. Kohn, Herzog, M. Hartstein, R. Hartstein, M. Kohn, R. Kohn, Landau, Y. Landau, Bank Austria, Duregger, Tecno Italy, Pirkner, Tripolt, Frey, Scheithauer, Giefing, Reuss, de Sury, Cosulich, APM Cayman, Marketinc, Eastview, Sharei, New Economy, Infotech, RTH, ITR, Fintechnology, EcoInfo, Systor, M-Tech, and Lantzitksy.

Infovaleur committed acts of mail fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, transportation of funds taken by fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

d. Robert Reuss (“Reuss”). Reuss is a citizen of Austria. He maintains a residence in New York. He is a former Vice-President of Eurovaleur and a former employee of Infovaleur. In his capacities as an employee of Eurovaleur and Infovaleur, Reuss resided in New York State. Reuss currently maintains a residence in New York, New York. Reuss presently acts as in-house counsel for Bank Medici. On information and belief, Reuss is not a lawyer. Reuss is a member of the Medici Enterprise.

Reuss received at least $1,500 of stolen Customer Property from Infovaleur.

Reuss (acting through himself, Infovaleur, and Eurovaleur) committed acts of wire fraud, mail fraud, financial institution fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

e. Yakov Lantzitsky (“Lantzitsky”). Lantzitsky is a New Jersey resident and former employee of Infovaleur. Lantzitsky was Kohn’s next-door neighbor in Monsey, New York and, on information and belief, her gardener. Kohn gave Lantzitsky signing authority over Infovaleur.

Lantzitsky received at least $14,353 of stolen Customer Property from Infovaleur.

Lantzitsky committed acts of mail fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

f. Windsor IBC, Inc. (“Windsor”). On July 15, 1987, Kohn incorporated Windsor in New York, New York. At all relevant times, Kohn was the owner and manager of Windsor. Erko was also a general partner of the holding company that owned Windsor. Windsor is a member of the

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Medici Enterprise. Windsor employed certain individuals who worked for Kohn at Eurovaleur. Through Windsor, Kohn solicited investors for Madoff’s Ponzi scheme. As to at least one of these investors who had a direct account with BLMIS, Kohn arranged for duplicates of his BLMIS account statements to be sent to her at the offices of Windsor.

Windsor committed acts of wire fraud and conspiracy in furtherance of the Illegal Scheme.

2. Kohn’s Canadian Sham Entity Defendant

a. I-Technology Solutions, Inc. (“I-Tech”). I-Tech was incorporated on August 11, 2000 in Montreal, Canada. I-Tech owned 95% of Tecno Italy. These shares were held for I-Tech by Brera. Line Holdings owns 100% of I-Tech. On information and belief, Line Holdings holds these shares in I- Tech for RTH. Also on information and belief, Kohn ultimately owns and controls I-Tech. I-Tech is a member of the Medici Enterprise.

At all relevant times, I-Tech had no actual business purpose and existed only to conceal and obfuscate the illicit moneys that MSIL paid to Tecno Italy. On information and belief, I-Tech received Customer Property from Tecno Italy.

I-Tech committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

3. Kohn’s Caribbean Sham Entity Defendants

a. Herald Asset Management Ltd. (“HAM”). Kohn created HAM in the Cayman Islands on March 12, 2004. Its ownership structure is obscured by a complex web of interrelated companies engineered by Kohn using the services of Hassans. The ultimate beneficial owners of HAM, however, are Kohn and her husband, E. Kohn. HAM is a central member of the Medici Enterprise. HAM operated from, among other places, the offices of Medici S.r.l. and Tecno Italy in Milan. Bank Austria Cayman leased HAM its office space in the Cayman Islands.

Herald Fund was the largest of the Medici Enterprise Feeder Funds and it fed over $1.5 billion dollars into BLMIS. This generated hundreds of millions of dollars in management, distribution, and other fees for HAM, Bank Medici, Bank Austria, and UniCredit. This structure of feeding money into BLMIS in return for fees for the Medici Enterprise is the crux of the “Money-In” aspect of the Illegal Scheme.

Kohn directs the activities of Bank Medici. Kohn directs the activities of

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HAM. Kohn, Bank Medici, and HAM are symbiotic and inextricably linked.

HAM purported to be, among other things, the investment manager for Herald Fund. HAM received a management fee equal to 2% of the net asset value of Herald Fund, calculated on a monthly basis, as well as a performance fee equal to 10% of any increase in the net asset value of Herald Fund, also calculated on a monthly basis. HAM received at least $99,500,000 in management fees from Herald Fund. Although BLMIS was in fact the investment manager, HAM held itself (and Bank Medici) out as performing Madoff’s so-called Split Strike Conversion (“SSC”) strategy. HAM and Bank Medici claimed that BLMIS was merely an executing broker that took orders from HAM as to which equities to buy and sell.

HAM committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, transportation of funds taken by fraud, and conspiracy in furtherance of the Illegal Scheme.

b. Franco Mugnai (“Mugnai”). Mugnai is a citizen of Italy. He is a director of HAM and Herald Fund and an employee of Medici S.r.l. Mugnai is a member of the Medici Enterprise. Mugnai and Kohn shared a personal secretary, Raule.

Mugnai personally received payments from HAM via wire transfer in foreign commerce. On information and belief, Mugnai received these transfers for marketing and distributing Herald Fund.

Mugnai (himself and through HAM) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

c. Paul de Sury (“de Sury”). De Sury is a resident of Italy. He is a former employee of Bank Medici S.r.l. and a former director of Herald Fund and HAM. De Sury is a member of the Medici Enterprise.

De Sury personally received payments from HAM via wire transfer in foreign commerce. On information and belief, de Sury received these transfers for marketing and distributing Herald Fund.

De Sury also received at least $69,500 of stolen Customer Property from Infovaleur.

De Sury (himself and through HAM) committed acts of wire fraud, money

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laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

d. Daniele Cosulich (“Cosulich”). Cosulich is a resident of the United Kingdom. Cosulich was instrumental in running the day-to-day activities of HAM and was employed by Medici S.r.l. Cosulich is a member of the Medici Enterprise. He also served as the Managing Director of Sofipo.

On April 2, 2007, Cosulich sent DiPascali of BLMIS a facsimile on behalf of HAM (but sent from Sofipo’s facsimile machine) informing BLMIS that Herald Fund would wire $35 million to BLMIS through HSBC Securities Services (Luxembourg) (“HSBC SSL”). Moreover, Cosulich purported to speak on behalf of Primeo Fund in the same facsimile.

Cosulich personally received payments from HAM via wire transfer in foreign commerce. On information and belief, Cosulich received these payments for marketing and distributing Herald Fund through HAM, Bank Medici, and Sofipo.

Cosulich also received at least $367,000 of stolen Customer Property from Infovaleur.

Cosulich (himself and through HAM) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

e. Marketinc Strategies Ltd. (“Marketinc”). Marketinc was incorporated in 1999 in the BVI. Marketinc dissolved on May 1, 2005, the same date as co-Defendants Eastview and Fintechnology. Marketinc is a member of the Medici Enterprise.

From May 2002 to September 2004, Marketinc received at least $1,848,000 of stolen Customer Property from Infovaleur. On information and belief, Kohn controls Marketinc.

Marketinc committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

f. Eastview Services Ltd. (“Eastview”). Eastview was incorporated in the BVI on October 1, 1997. Eastview dissolved on May 1, 2005, the same date as co-Defendants Marketinc and Fintechnology. Eastview is a member of the Medici Enterprise.

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From May 2002 through September 2004, Eastview received at least $997,990 of stolen Customer Property from Infovaleur. On information and belief, Kohn controls Eastview.

Eastview committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

g. Systor S.A. (“Systor”). Systor was incorporated in the BVI on or about March 2000. Systor dissolved on November 1, 2005, the same date as co- Defendants ITR and Brightlight. Systor is a member of the Medici Enterprise.

From August 2004 through September 2006, Systor received at least $1,610,320 of stolen Customer Property from Infovaleur. On information and belief, Kohn controls Systor.

Systor committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

h. IT Resources (“ITR”). ITR was incorporated in the BVI on or about May 2001. ITR dissolved on November 1, 2005, the same date as co- Defendants Systor and Brightlight. ITR is a member of the Medici Enterprise.

From October 2002 through November 2003, ITR received at least $771,000 of stolen Customer Property from Infovaleur. On information and belief, Kohn controls ITR.

ITR committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

i. Brightlight Trading Ltd. (“Brightlight”). Brightlight was incorporated on May 1, 2002 in the BVI. Brightlight dissolved on November 1, 2005, the same date as co-Defendants Systor and ITR. Brightlight is a member of the Medici Enterprise.

On May 8, 2003 Brightlight received €4,453,365 of stolen Customer Property from Erko. Brightlight transferred €181,462 to Erko on June 15, 2004. On information and belief, Kohn controls Brightlight.

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Brightlight committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

j. Fintechnology Ltd. (“Fintechnology”). Fintechnology was incorporated on October 1, 1997, the same formation date as co-Defendant Eastview. Fintechnology dissolved on May 1, 2005, the same date as Eastview and Marketinc. Fintechnology is a member of the Medici Enterprise.

Fintechnology received one payment of $90,000 on April 4, 2003 from Infovaleur.

Fintechnology committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

k. Tonga International S.A. (“Tonga”). Tonga was incorporated on July 17, 1998 in the BVI. Tonga is a member of the Medici Enterprise.

Tonga received at least $879,943 from Eurovaleur in 2001. On information and belief, Kohn controls Tonga.

Tonga committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

4. Kohn’s Italian Sham Entity Defendants

a. Tecno Development & Research S.r.l. (“Tecno Italy”). Tecno Italy is a Milan-based company incorporated on February 21, 2002. Tecno Italy is a member of the Medici Enterprise. Tecno Italy was 95% owned by Brera. On information and belief, Brera holds its 95% interest in Tecno Italy in trust for I-Tech. On information and belief, Line Holdings holds 100% of I-Tech for RTH AG, which is controlled by Kohn. The remaining 5% of Tecno Italy was directly owned by Kohn’s mother, Blau. Florio served as Managing Director, President, and later the liquidator of Tecno Italy. Kohn, via Eurovaleur, registered the internet domain name of Tecno Italy in New York on January 30, 2004.

At all relevant times, Tecno Italy had no legitimate business purpose and existed only to receive stolen Customer Property from Madoff and further the Illegal Scheme. From May 21, 2002 through January 2, 2007, Tecno Italy received kickbacks of stolen Customer Property from Madoff totaling at least $14,601,000. Tecno Italy laundered some of this money

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to E. Kohn months after the Filing Date.

As with many of the Sham Entities owned and controlled by Kohn, Tecno Italy had strong connections to Bank Medici. Tecno Italy was located in the same offices as Medici S.r.l. (Via Andegari 18, 20121 Milan, Italy) and shared employees. Tecno Italy liquidated its assets on December 5, 2008, one week before Madoff confessed.

Tecno Italy also received stolen Customer Property from Infovaleur.

On February 2, 2009, Tecno Italy paid E. Kohn (through Non-Defendant Bad Actor Tamiza) $299,995. This payment occurred three months after Tecno Italy’s dissolution and resulted in a criminal money laundering investigation by the Swiss authorities.

Tecno Italy committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, transportation of funds taken by fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

b. Renato Florio (“Florio”). Florio is a citizen of Italy. Florio held a 5% interest in Tecno Italy which he later sold to Blau. Florio also served as President, Managing Director, and Liquidator of Tecno Italy. Florio is a member of the Medici Enterprise. Florio produced falsified liquidation reports for Tecno Italy.

Florio committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, transportation of funds taken by fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

c. Mariadelmar Raule (“Raule”). Raule is a citizen of Italy and personal assistant to Kohn and Mugnai. Raule is a member of the Medici Enterprise. She was an employee of both Medici S.r.l. and Tecno Italy, both of which operated from the same offices in Milan. She worked for Medici S.r.l. from 2006 to 2008.

Raule (herself and through Tecno Italy and Medici S.r.l.) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

5. Kohn’s Gibraltar Sham Entity Defendants

a. Tecno Development & Research Ltd. (“Tecno Gibraltar”). Tecno Gibraltar was incorporated on January 3, 2007, in Gibraltar. Tecno Gibraltar is a member of the Medici Enterprise. Tecno Gibraltar is located

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in the offices of Line Management, which is associated with Hassans. On information and belief, Kohn owns and controls Tecno Gibraltar. Its ownership structure is obscured by a complex web of interrelated companies orchestrated by Kohn and including Hassans. Tecno Gibraltar’s sole director is Amselem, an Israeli national residing in Gibraltar. Amselem is also an employee of Line Management.

At all relevant times, Tecno Gibraltar had no legitimate business purpose and existed only to receive stolen Customer Property from BLMIS and further the Illegal Scheme. On May 2007, Tecno Gibraltar replaced Tecno Italy as a vehicle for Kohn to receive kickbacks of stolen Customer Property from Madoff. In 2007, Tecno Gibraltar received approximately $1,400,000 from Madoff. Additionally, in 2008, Tecno Gibraltar received at least $3,750,000 directly from BLMIS in New York.

Tecno Gibraltar committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

b. Shlomo (Momy) Amselem (“Amselem”). Amselem is an Israeli national and resident of Gibraltar. He is the lone director of Tecno Gibraltar. Amselem is also employed by Line Management, which is associated with Hassans. Amselem is a member of the Medici Enterprise.

Amselem corresponded with Leon Flax (“Flax”) via e-mail to confirm Madoff’s payments of stolen Customer Property via wire transfer to Tecno Gibraltar.

Amselem (himself and through Tecno Gibraltar) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, and conspiracy in furtherance of the Illegal Scheme.

6. Kohn’s Liechtenstein Sham Entity Defendants

a. Lifetrust AG (“Lifetrust”). Lifetrust is a Liechtenstein company created on January 8, 2008. Kohn and UniCredit used ReviTrust Services Est. (“Revi”) to create Lifetrust, along with co-Defendants PrivatLife and Starvest. Revi capitalized these entities using stolen Customer Property from HAM. On information and belief, UniCredit helped Kohn and Bank Medici create Lifetrust. Also on information and belief, Lifetrust provided no real services. Lifetrust owns 50% of PrivatLife. Lifetrust’s two equal shareholders are Rainer Marxer and Revi. Lifetrust is a member of the Medici Enterprise.

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On January 24, 2008, Lifetrust received payments of $428,571 and €293,460 from PrivatLife. On January 25, 2008, Lifetrust sent $428,571 and €293,460 to PrivatLife.

Lifetrust committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

b. PrivatLife AG (“PrivatLife”). PrivatLife is a Liechtenstein company created on October 24, 2007. Kohn and UniCredit used Revi to create PrivatLife, along with co-Defendants Lifetrust and Starvest. Revi capitalized these entities using stolen Customer Property from HAM. On information and belief, UniCredit helped Kohn and Bank Medici create PrivatLife. Also on information and belief, PrivatLife provided no real services. Lifetrust owns 50% of PrivatLife and Starvest owns 15%. PrivatLife is a member of the Medici Enterprise.

On January 24, 2008, Lifetrust received payments of $428,571 and €293,460 from PrivatLife. That same day, PrivatLife sent $1,571,429 and €1,076,020 to Starvest. On January 25, 2008, Lifetrust sent $428,571 and €293,460 to PrivatLife. That same day, Starvest sent $1,571,429 and €1,076,020 to PrivatLife. PrivatLife also received at least one payment from Bank Medici

PrivatLife committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

c. Starvest Anstalt (“Starvest”). Starvest is a Liechtenstein company created on January 9, 2008. Kohn and UniCredit used Revi to create Starvest, along with co-Defendants Lifetrust and PrivatLife. Revi capitalized these entities using stolen Customer Property from HAM. On information and belief, UniCredit helped Kohn and Bank Medici create Starvest. Also on information and belief, Starvest provided no real services. Starvest owns 15% of PrivatLife. Starvest is a member of the Medici Enterprise.

On January 24, 2008, PrivatLife sent $1,571,429 and €1,076,020 to Starvest. On January 25, 2008, Starvest sent $1,571,429 and €1,076,020 to PrivatLife.

Starvest committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity,

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receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

7. Kohn’s Swiss Sham Entity Defendants

a. New Economy.Tech S.A. (“New Economy”). New Economy was incorporated in Switzerland on April 20, 2000. New Economy utilized Kohn’s residence at Katharinenweg 4, CH-8002 Zurich, Switzerland, as one of its affiliated addresses. Massiah, long-time personal friend to Kohn, oversaw New Economy’s business operations. On information and belief, Kohn controlled New Economy. New Economy is a member of the Medici Enterprise.

From June 2002 through May 2006, New Economy received at least $998,600 of stolen Customer Property from Infovaleur. All these payments were via check, and all were signed and endorsed by Kohn.

New Economy committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

b. RTH AG (“RTH”). RTH is a Swiss company incorporated on May 8, 2001. On information and belief, RTH holds I-Tech, Tonga, and Herald Consult in trust for various co-Defendants, including Kohn and E. Kohn. On information and belief, Kohn controls RTH. RTH is a member of the Medici Enterprise.

From September 2002 through May 2005, RTH received at least $76,250 of stolen Customer Property from Infovaleur.

RTH committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

c. EcoInfo GmbH (“EcoInfo”). EcoInfo was incorporated in Switzerland on June 18, 2003. EcoInfo dissolved on April 26, 2007. On information and belief, Kohn controls EcoInfo. EcoInfo is a member of the Medici Enterprise.

From December 29, 2003 through January 6, 2004, EcoInfo received at least $240,000 of stolen Customer Property from Infovaleur.

EcoInfo committed acts of money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial

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institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

8. Kohn’s Austrian Sham Entity Defendants

a. Sofipo Austria GmbH (“Sofipo”). Sofipo is an Austrian company owned by Bank Medici. Sofipo is a member of the Medici Enterprise. Until April 21, 2009, Sofipo was registered at the same address as Bank Medici. Kohn served as an Assistant Chairwoman and Managing Director of Sofipo. Cosulich replaced Kohn as the Managing Director of Sofipo.

Sofipo received transfers designated as “retrocession fees” via wire from HAM for marketing and distributing Herald Fund.

Sofipo committed acts of wire fraud, money laundering, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

b. M-Tech Service GmbH (“M-Tech”). M-Tech is an Austrian company founded on November 30, 2000. M-Tech is a member of the Medici Enterprise. From January 4, 2002 until January 4, 2007, Kohn owned 50% of M-Tech. She eventually sold her interest in M-Tech to her son-in- law Landau. Kohn served as M-Tech’s Managing Director from January 4, 2002 until November 29, 2003. M-Tech also employed Bank Medici director Pirkner and Landau as managing directors. M-Tech went into liquidation in 2007.

On June 30, 2008 and July 18, 2008, Infovaleur made payments totaling $97,000 of stolen Customer Property to the already liquidated M-Tech.

M-Tech committed acts of engaging in monetary transactions in property derived from specific unlawful activity, money laundering, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

C. BANK MEDICI DEFENDANTS

1. Bank Medici Corporate Defendants

a. Bank Medici AG now d/b/a 20:20 Medici AG (“Bank Medici”). Bank Medici is located at Hegelgasse 17/17 1010 Vienna, Austria. Bank Medici is a member of the Medici Enterprise. Bank Medici began as a company named Anton-Schwarz GmbH, which was wholly owned by Bank Austria. In 1994, Bank Austria sold Kohn 90% of Anton-Schwarz GmbH and kept 10% ownership. Kohn named her company using various iterations of the “Medici” name, eventually settling on “Bank Medici.” Upon its inception, Bank Medici immediately began distributing Primeo Fund, picking up where Eurovaleur started in New York.

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With the assistance of Bank Austria and Randa, the Austrian government granted Kohn and Bank Medici an Austrian banking license in 2003. At all relevant times, Kohn was the controlling shareholder of Bank Medici and Bank Austria owned the remaining shares. At all relevant times Bank Austria operated Bank Medici as a de facto “branch.” Bank Austria’s internal records recorded Bank Medici as “Branch 1199.” This ownership and operating structure remains to this day.

Bank Medici, HAM, Bank Austria, and UniCredit, together, make up the operating nucleus of the “Money-In” aspect of the Illegal Scheme. Bank Medici and Bank Austria had a revolving door of officers and directors, many of which had no relevant experience selling financial products such as Primeo Fund, Herald Fund, and other Medici Enterprise Feeder Funds.

The vast majority of Bank Medici’s total income came only from peddling the Medici Enterprise Feeder Funds. On information and belief, the vast majority of these fees were paid to Bank Medici by HAM. The Trustee has limited visibility to the full range of fees and/or commissions paid to Bank Medici for its participation in the Illegal Scheme. At the very least, Bank Medici received $30 million for its various roles in the Medici Enterprise. On information and belief, the actual total received by Bank Medici over the course of the Illegal Scheme is many times this amount.

Bank Medici also served as the primary marketer, distributor, and investment manager of 100% BLMIS-invested Herald (Lux), and received a monthly management fee equal to 2% of the net asset value of Herald (Lux) and a monthly performance fee equal to 10% of any increase in the net asset value of Herald (Lux), also calculated on a monthly basis. Bank Medici also marketed, distributed, and managed Thema International for which it received approximately $13 million.

In 2007, Bank Medici received $1,200,000 from Pioneer, the investment manager to Primeo Fund and wholly owned investment arm of UniCredit.

On October 29, 2008, Bank Medici sent CHF 1,125,000 to PrivatLife. On information and belief, Bank Medici caused Wiener Stadstiche Versicherung (“WSV”) to send CHF 1,125,000 to PrivatLife on March 17, 2008.

Bank Medici has many branded and de facto “branches,” each of which is a member of the Medici Enterprise: APM Cayman, MediciFinanz Consulting GmbH (“MediciFinanz”), Medici S.r.l., Medici Cayman, and Bank Medici Gibraltar, a “joint venture” with Hassans. On information and belief, Medici Finance Services and Medici Fund Management are financial institutions created by Kohn in New York to solicit investors into

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BLMIS. Bank Medici and Hassans also jointly own Medici Realty in Gibraltar. Bank Medici Gibraltar and Medici Realty are located in the offices of Hassans. Bank Medici and Kohn own and control Sofipo.

Months after Madoff’s confession, several key members of Bank Medici’s management, including Scheithauer and Tripolt, resigned from their positions at Bank Medici. Around the same time, the Austrian Government seized control of Bank Medici and its assets. Sometime later, the Austrian government stripped Bank Medici of its banking license.

Bank Medici and its subsidiaries (all controlled by Kohn) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, interstate and foreign travel in violation of the Travel Act, transportation of people to defraud, transportation of funds taken by fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

b. Absolute Portfolio Management Ltd. (“APM Cayman”). Kastner incorporated APM Cayman in the Cayman Islands on April 19, 1999. APM Cayman is a member of the Medici Enterprise. Bank Medici owned 50% of APM Cayman.

Kastner owns and controls APM Cayman. Kastner also owns and controls APM Cayman’s sister company MediciFinanz. HAM paid APM Cayman for MediciFinanz’s distribution and marketing of Herald Fund and Primeo Fund. APM Cayman received over $12,940,394 in payments from HAM, via wire transfer. APM Cayman was the second-largest recipient of transfers from HAM after Bank Medici itself.

Kastner, through APM Cayman, received $780,047 in payments from Kohn’s New York Sham Entity Infovaleur in 2007 and 2008.

APM Cayman committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

c. MediciFinanz Consulting GmbH (“MediciFinanz”). Kastner incorporated MediciFinanz, a foreign corporation, in Germany on October 10, 1996. Kastner owns and controls this company. MediciFinanz is a member of the Medici Enterprise. Bank Medici owned 50% of MediciFinanz from its inception until some time in or about 2002. Bank Medici was an indirect owner of MediciFinanz. MediciFinanz operated as a de facto “branch” of Bank Medici. MediciFinanz is the sister company to APM Cayman.

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MediciFinanz was the primary distributor and marketer of Herald Fund, Primeo Fund, Thema International, and Alpha Prime Fund in Germany.

Kastner, through MediciFinanz, owns and controls APM Cayman. HAM paid APM Cayman for MediciFinanz’s distribution and marketing of Herald Fund.

Kastner and MediciFinanz were involved in the creation of Bank Medici’s Herald (Lux).

MediciFinanz committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

d. Medici S.r.l. Medici S.r.l. is a branch of Bank Medici opened on October 24, 1997. Medici S.r.l. is a member of the Medici Enterprise. Bank Medici held a 51% shareholding of Medici S.r.l. Bank Medici held this majority shareholding until 2004, after which it appears to have held a 100% shareholding. Medici S.r.l. shared an address and personnel with Tecno Italy.

On information and belief, Kohn and other members of the Medici Enterprise solicited investors for the Medici Enterprise Feeder Funds in Medici S.r.l.’s offices.

Medici S.r.l. committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

e. Medici Cayman Islands Ltd. (“Medici Cayman”). Medici Cayman is a wholly owned branch of Bank Medici incorporated on April 20, 2007. Medici Cayman is a member of the Medici Enterprise.

On information and belief, Kohn and other members of the Medici Enterprise solicited investors for the Medici Enterprise Feeder Funds in Medici Cayman’s offices. Moreover, beginning on September 26, 2007, Medici Cayman received at least $182,729 from HAM.

Medici Cayman committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

f. Bank Medici AG (Gibraltar) (“Bank Medici Gibraltar”). In November 2004, Bank Medici and Hassans announced the opening of

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Bank Medici’s Gibraltar branch. Bank Medici Gibraltar eventually opened in January 2005. Bank Medici Gibraltar is a member of the Medici Enterprise. Bank Medici Gibraltar and Tecno Gibraltar are located in Hassans’s offices. On information and belief, Bank Medici and Hassans jointly own Bank Medici Gibraltar.

On information and belief, Kohn and other members of the Medici Enterprise solicited investors for the Medici Enterprise Feeder Funds in Bank Medici Gibraltar’s offices.

Bank Medici Gibraltar committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

2. Bank Medici Individual Defendants

a. Peter Scheithauer (“Scheithauer”). Scheithauer is a citizen of Austria. Scheithauer is a member of the Medici Enterprise. Scheithauer worked for Bank Austria and its predecessors as far back as 1989. Scheithauer was an executive at Bank Austria until 1999 and was one of the co-creators of Primeo Fund, along with Kohn.

During his tenure with Bank Austria, Scheithauer was involved in the European launch of Primeo Fund (which Kohn and Eurovaleur registered and initially distributed in New York).

On September 1, 2008, Kohn hired him as Bank Medici’s CEO. Scheithauer served as a director of Herald (Lux).

Scheithauer conspired with Kohn, Bank Medici, Bank Austria, UniCredit, and others to conceal BLMIS’s role in Primeo Fund and other Medici Enterprise Feeder Funds. On December 23, 2008 (after Madoff confessed to running a Ponzi scheme), Scheithauer met with Lavi and Herald (Lux) investor Elena Shpe (“Shpe”) in Vienna at the offices of Bank Medici. At that meeting Scheithauer denied that he knew that Herald (Lux) was 100% invested in BLMIS.

Scheithauer (himself and through Bank Austria and Bank Medici) received a $15,000 check on August 25, 2008 from Kohn, via Infovaleur, approximately two weeks before beginning his employment with Bank Medici.

Scheithauer committed acts of wire fraud, financial institution fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

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b. Helmuth Frey (“Frey”). Frey is a citizen of Austria. Frey is a member of the Medici Enterprise. In 2006, he joined Bank Medici’s advisory board and was its CEO from 2006-2008. He met Kohn while working as a director of Bank of America in New York from 1973 to 1984. He oversaw the creation of Herald (Lux). Frey served as a director of Herald Fund.

From November 2006 to June 2008, Frey received five payments totaling $29,500 of stolen Customer Property from Infovaleur.

Frey (himself and through Bank Medici) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

c. Manfred Kastner (“Kastner”). Kastner is a citizen of Austria. Kastner owns and controls APM Cayman. He also owns and controls Bank Medici’s branch in Germany, MediciFinanz. Kastner is a member of the Medici Enterprise. Kastner worked in the offices of Medici Cayman (which received transfers from HAM) in 2000 and 2001.

Kastner marketed and distributed Herald Fund, Thema International, Primeo Fund, and Alpha Prime Fund. Kastner and MediciFinanz were also involved in the creation of Herald (Lux). Bank Medici (through HAM) and Bank Austria paid Kastner for these services. Kohn, Bank Medici, and Bank Austria provided him with all of the marketing materials for Herald Fund, Thema International, and Primeo Fund (and, for at least Primeo Fund, complete with stamps from Bank Austria).

In the course of this distribution, Kastner and Kohn visited Madoff at the New York headquarters of BLMIS on at least two occasions.

Kastner also owns Gerila, through which Kastner received €600,000 from Kohn. On information and belief, this payment was a personal loan to help pay for expenses associated with Kastner’s divorce. Kohn paid Kastner using HAM’s accounts, which she used as a personal slush fund.

Kastner (himself and through APM Cayman and MediciFinanz) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, interstate and foreign travel in violation of the Travel Act, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

d. Andreas Pirkner (“Pirkner”). Pirkner is a citizen of Austria. Pirkner is a member of the Medici Enterprise. He was an employee of Bank Medici

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from 2003 to May 2008. In 2005, Pirkner became the Head of institutional sales at Bank Medici. In 2007, Pirkner became a director of asset management at Bank Medici. Pirkner was involved in the creation, management, and distribution of Herald (Lux), was a Managing Director of Herald (Lux), and a director of HAM. Pirkner also served as director of M-Tech. Pirkner was in regular contact with Nograsek, the Head of Investment at Bank Austria. Pirkner was also the Bank Medici contact for due diligence questions regarding the Medici Enterprise Feeder Funds.

From August 2006 to July 2007, Pirkner received five payments totaling at least $30,000 of stolen Customer Property from Infovaleur.

Pirkner (himself and through Bank Medici) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

e. Werner Tripolt (“Tripolt”). Tripolt is a citizen of Austria. He joined Bank Medici in 2007 as an assistant to the managing board of directors and officially became a member of the board on January 2008. Tripolt is a member of the Medici Enterprise. Tripolt was responsible for the entire financial policy of Bank Medici, including credit and debit management, regulatory reporting, the bank’s company shareholdings, fund operations, and its infrastructure.

On October 1, 2008, Tripolt received a one-time payment of $10,000 of stolen Customer Property from Infovaleur.

Tripolt (himself and through Bank Medici) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

f. Andreas Schindler (“Schindler”). Schindler is a citizen of Austria. He was the Head of asset management at Bank Medici. Schindler is a co- creator of Herald (Lux) and served as one of its directors. Schindler is a member of the Medici Enterprise. Schindler conspired with Kohn, Bank Austria, Bank Medici, and others to create misleading Bank Medici marketing presentations for at least Primeo Fund and Herald Fund.

Schindler (himself and through Bank Medici) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

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g. Susanne Giefing (“Giefing”). Giefing is an Austrian citizen. Giefing had signatory authority for Bank Medici. At Kohn’s direction, Giefing authorized scores of payments of Customer Property from HAM to co- conspirators in furtherance of the Illegal Scheme. Giefing is a member of the Medici Enterprise.

From January 2007 to November 2008, Giefing received six payments totaling at least $34,000 of stolen Customer Property from Infovaleur.

Giefing (herself and through Bank Medici) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

D. FINANCIAL INSTITUTION DEFENDANTS

1. Bank Austria Corporate Defendants

a. UniCredit Bank Austria AG (“Bank Austria”). Bank Austria is an Austrian bank headquartered in Vienna. Bank Austria is a member of the Medici Enterprise. In 2005, UniCredit acquired Bank Austria. At all relevant times, Bank Austria maintained a New York branch located at 150 E. 42nd Street, New York, New York. Historical records of the New York Department of State, Corporations Division, list a number of Bank Austria entities in New York including Bank Austria America, Inc., Bank Austria Creditanstalt American Corporation, Bank Austria Finance, Inc., Bank Austria Securities, Inc., and others.

Bank Austria, its parent and co-conspirators, UniCredit, Bank Medici, and HAM, are the operating nucleus of the “Money-In” aspect of the Illegal Scheme. Bank Medici and Bank Austria had a revolving door of officers and directors, many of whom had no relevant experience selling financial products such as Primeo Fund, Herald Fund, and other Medici Enterprise Feeder Funds. This structure enriched Bank Austria officers and directors personally, as well as furthered the Illegal Scheme.

Shortly after Kohn’s arrival in Vienna, Bank Austria opened a direct account with BLMIS (account number 1FN082) in 1995. The Account Maintenance File (“AMF”) recovered from BLMIS contains Zapotocky’s business card. This card has a handwritten notation containing Kohn’s phone number. The AMF also listed Kretschmer as Bank Austria’s primary contact for the account. Bank Austria’s direct account is a “net winner” and received approximately $250,000 in fictitious profits. Despite Kohn knowing that Madoff was a fraud, Bank Austria lent its name and credibility to, and hence validated and bolstered, the Medici Enterprise Feeder Funds, including at least Primeo Fund, Herald Fund,

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and Herald (Lux).

Through Bank Medici, Kohn, Bank Austria, and other members of the Medici Enterprise furthered the Illegal Scheme by conspiring to solicit investors for Madoff’s Ponzi scheme initially through Primeo Fund.

Bank Austria owned 10% of Bank Medici from 1994 to 2003. Bank Austria was instrumental in securing a banking license for Bank Medici in 2003. Immediately thereafter, Bank Austria became the owner of 25% of Bank Medici. At all relevant times, Bank Austria operated Bank Medici as its de facto “branch” despite its minority share. Bank Austria referred to Bank Medici as “Branch 1199” in internal records.

Bank Austria also entered into a Contract of Agency with Bank Medici under which all transactions of customers acquired and advised by Bank Medici were to take place via Bank Austria. All of Bank Medici’s accounts and portfolios were maintained by Bank Austria. In addition, Bank Austria agreed to assist Bank Medici in undertaking its due diligence obligations. For its services under the contract, Bank Austria received compensation from Bank Medici. Bank Austria not only tolerated the activity of its rogue branch, it encouraged, facilitated, and profited from it.

Bank Austria owns 95% of BA Worldwide. The Trustee has limited visibility to the full range of fees and/or commissions paid to Bank Austria for its participation in the Illegal Scheme. At the very least, Bank Austria received at least $31,729,922.09 for its various roles in the Medici Enterprise. Bank Austria received $2,000 of stolen Customer Property from Infovaleur on October 10, 2002. On information and belief, the actual total received by Bank Austria over the course of the Illegal Scheme is a multiple of this amount.

From November 2006 to July 2007, Bank Austria sent Eurovaleur several illicit payments totaling $893,157 through its Financial Services department, Finanzservice Gesmbh.

Bank Austria committed acts of wire fraud, interstate and foreign travel in violation of the Travel Act, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, mail fraud, transportation of people to defraud, transportation of funds taken by fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

b. Bank Austria Worldwide Fund Management Limited (“BA Worldwide”). BA Worldwide was a subsidiary of Bank Austria incorporated in the British Virgin Islands on September 29, 1993. BA Worldwide is a member of the Medici Enterprise. BA Worldwide was the

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investment adviser to Primeo Fund from December 15, 1993 until April 25, 2007.

BA Worldwide received fees based on the net asset value of each of Primeo Fund’s two sub-funds, calculated on a monthly basis. Kohn’s Eurovaleur in New York received 20% of these fees for serving as a sub- adviser to BA Worldwide. BA Worldwide also served as the investment adviser to Alpha Prime Fund and received advisory fees equal to a percentage of the net asset value of the fund, calculated on a monthly basis. It also served as the investment adviser to Thema International. Over the course of the Illegal Scheme, BA Worldwide received at least $68,472,933.69 in purported management and advisory fees.

In 1996 BA Worldwide and Bank Austria employed Radel-Leszczynski. Bank Austria and BA Worldwide promoted her to president of BA Worldwide in 2000. She was responsible for BA Worldwide’s management and operation. Beginning in the mid-1990s, Radel- Leszczynski, along with Zapotocky, Kretschmer, and Hemetsberger traveled to New York and met with Madoff at BLMIS headquarters approximately two to three times a year.

On, or about, April 25, 2007 UniCredit and Pioneer hired Radel- Leszczynski for the purpose of maintaining UniCredit’s connection to Madoff.

BA Worldwide committed acts of wire fraud, interstate and foreign travel in violation of the Travel Act, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, transportation of funds taken by fraud, and conspiracy in furtherance of the Illegal Scheme.

c. Bank Austria Cayman Islands Ltd. (“Bank Austria Cayman”). Bank Austria Cayman is a branch of Bank Austria incorporated on October 12, 2000 in the Cayman Islands. Bank Austria Cayman is a member of the Medici Enterprise. Its principal place of business is located at Whitehall House, 238 North Church Street, P.O. Box 31362, Seven Mile Beach, George Town, Grand Cayman, Cayman Islands, which is the same address as HAM.

Bank Austria Cayman received at least $59,305.55 from HAM.

Bank Austria Cayman committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

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2. Bank Austria Individual Defendants

a. Gerhard Randa (“Randa”). Randa is a citizen of Austria. From 1995 to 2003, he was the Chairman of Bank Austria. Randa is a member of the Medici Enterprise. Randa was a director for HypoVereinsbank (“HVB”). Randa was instrumental to the creation of Primeo Fund, and on information and belief, introduced Kohn to Bank Austria in the early 1990s. As Chairman of Bank Austria, Randa was instrumental in the opening of Bank Austria’s BLMIS Account. Randa, through Bank Austria, on information and belief, played a crucial role in securing Bank Medici a banking license in 2003.

Randa was the Chief of Operations for Bank Austria’s parent company during UniCredit’s takeover of Bank Austria in 2005.

Randa (himself and through Bank Austria) committed acts of engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, wire fraud, mail fraud, and conspiracy in furtherance of the Illegal Scheme.

b. Friedrich Kadrnoska (“Kadrnoska”). Kadrnoska is a citizen of Austria. Kadrnoska is a member of the Medici Enterprise. From 1995 to 2003, he was a director and member of the management board of Bank Austria. From 2003 to 2004, Kadrnoska served as Deputy Chairman of Bank Austria’s Management Board. Kadrnoska is currently a director of UniCredit. On information and belief, Kadrnoska purported to be Kohn’s liaison between Bank Austria and Bank Medici.

Kadrnoska (himself and through Bank Austria) committed acts of engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, wire fraud, and conspiracy in furtherance of the Illegal Scheme.

c. Stefan Zapotocky (“Zapotocky”). Zapotocky is a citizen of Austria. Zapotocky was employed by Bank Austria beginning in 1991. Zapotocky was also the Director of Equities and from 1997-2000 he was the Head of Asset Management for Bank Austria. He also oversaw investments and the creation of Primeo Fund. Zapotocky was directly responsible for Bank Austria’s direct account with BLMIS. Zapotocky is a member of the Medici Enterprise. His responsibilities at Bank Austria included oversight of investments. He was instrumental in the creation of Primeo Fund and served on its board. Zapotocky was responsible for overseeing BA Worldwide during his tenure at Bank Austria.

After leaving Bank Austria, Zapotocky conspired with Kohn and Radel- Leszczynski to launch Alpha Prime Fund. Zapotocky also served as a

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director of Alpha Prime Fund with Kohn. Zapotocky was also associated with Senator Fund

On information and belief, Zapotocky earned at least $8 million for his various roles in the Medici Enterprise in furtherance of the Illegal Scheme.

Zapotocky, on behalf of both Bank Austria and BA Worldwide, traveled to New York to meet with Madoff two to three times a year at BLMIS headquarters. The purpose of these meetings was to discuss Bank Austria, BA Worldwide, and Bank Medici regarding their involvement with the Medici Enterprise Feeder Funds.

Zapotocky (himself and through Bank Austria) committed acts of interstate and foreign travel in violation of the Travel Act, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, wire fraud, and conspiracy in furtherance of the Illegal Scheme.

d. Ursula Radel-Leszczynski (“Radel-Leszczynski”). Radel-Leszczynski is a citizen of Austria. She was hired by Bank Austria and BA Worldwide in 1996. She became the President of BA Worldwide in 2000. Radel- Leszczynski is a member of the Medici Enterprise.

Radel-Leszczynski was instrumental to the creation of Alpha Prime Fund and Senator Fund. Certain other members of the Medici Enterprise referred to Radel-Leszczynski as the “figurehead of Primeo.” She was Madoff’s personal contact for any questions concerning Primeo Fund, Alpha Prime Fund, and Senator Fund. Radel-Leszczynski had a close personal working relationship with Madoff, and corresponded with him regularly.

On information and belief, Radel-Leszczynski is the ultimate beneficiary of the service providers to Senator Fund and earned millions of dollars for her roles in the Medici Enterprise in furtherance of the Illegal Scheme.

Radel-Leszczynski, on behalf of both Bank Austria and BA Worldwide, traveled to New York two to three times a year to meet with Madoff at BLMIS headquarters.

Radel-Leszczynski (herself and through BA Worldwide) committed acts of money laundering, wire fraud, interstate and foreign travel in violation of the Travel Act, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

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e. Josef Duregger (“Duregger”). Duregger is a citizen of Austria. Duregger is a member of the Medici Enterprise. On information and belief, Bank Austria placed Duregger on Bank Medici’s board of directors to oversee Kohn. He was the Head of the Participations department at Bank Medici beginning in 2006. Duregger is currently a director of UniCredit CA-IB Securities UK Ltd. (“UniCredit UK”), a wholly owned UniCredit subsidiary. Duregger served as a director of BA Worldwide from 1993 until 2003. Duregger is a member of Bank Austria Cayman’s Supervisory Board. He was a member of Bank Austria’s Commercial Representation Board from 1991-1993 and from 1999 to the present. Duregger served as a director of Primeo Fund. Despite the implosion of Bank Medici in the wake of Madoff’s confession, Duregger continues to serve as a member of 20:20 Medici’s Advisory Board alongside Kohn.

Duregger helped create Primeo Fund with Kohn in 1993.

From January 2003 to July 2008, Duregger received ten payments totaling at least $30,900 of stolen Customer Property from Infovaleur.

Duregger (himself and through Bank Medici, BA Worldwide, and Bank Austria Cayman Islands) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, mail fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

f. Peter Fischer (“Fischer”). Fischer is a citizen of Austria. Fischer served as Treasurer of Bank Austria from 1991 through 1998. Fischer also served as a high-ranking executive at Bank Austria’s predecessor, Landerbänk. Fischer is a director of Alpha Prime. He is also a long-time friend and business associate of Kohn. Fischer is a member of the Medici Enterprise.

Fischer (himself and through Bank Austria) committed acts of engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, wire fraud, and conspiracy in furtherance of the Illegal Scheme.

g. Werner Kretschmer (“Kretschmer”). Kretschmer is a citizen of Austria. He was a director of Bank Austria from May 2006 until May 2008 and a director of Bank Medici from 2004 to 2006. Kretschmer is a member of the Medici Enterprise. In 2008, Kretschmer was named CEO of Pioneer Investments Austria for Central and Eastern Europe. Kretschmer also served as a director of BA Worldwide. Kretschmer, on behalf of both Bank Austria and BA Worldwide, traveled to New York to meet with Madoff two to three times a year at BLMIS headquarters. The purpose of these meetings was to discuss Bank Austria, BA Worldwide,

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and Bank Medici regarding their involvement with the Medici Enterprise Feeder Funds. Bank Austria’s account maintenance file (“AMF”) recovered from BLMIS names Kretschmer as the primary Bank Austria contact for the account.

Kretschmer committed acts of interstate and foreign travel in violation of the Travel Act, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, wire fraud, and conspiracy in furtherance of the Illegal Scheme.

h. Wilhelm Hemetsberger (“Hemetsberger”). Hemetsberger is an Austrian citizen. He was a director of Bank Austria from February 2001 to May 2008. Hemetsberger is a member of the Medici Enterprise. He was also a director of BA Worldwide from 1993-2003. Beginning in 1998, Hemetsberger became the Head of Bank Austria’s CA-IB investment bank. In 2005, Hemetsberger was named as UniCredit’s Head of Global Markets and served on UniCredit’s Executive Management Committee. Hemetsberger, on behalf of Bank Austria and BA Worldwide, traveled to New York to meet with Madoff two to three times a year at BLMIS headquarters. The purpose of these meetings was to discuss Bank Austria, BA Worldwide, and Bank Medici regarding their involvement with the Medici Enterprise Feeder Funds

Hemetsberger (himself and through Bank Austria and BA Worldwide) committed acts of interstate and foreign travel in violation of the Travel Act, wire fraud, and conspiracy in furtherance of the Illegal Scheme.

i. Harald Nograsek (“Nograsek”). Nograsek is an Austrian citizen. He was the Bank Austria employee from 1991 to 2004. In 1991, Nograsek served as the Head of the Financial Investment Division at Bank Austria. In 1997, he became the Bank Austria employee responsible for all investments. Nograsek served as a director of BA Worldwide. Nograsek is a member of the Medici Enterprise. At Bank Austria, Nograsek “supervised” Bank Medici. Nograsek was director of Alpha Prime Fund and Primeo Fund. On information and belief, he was primarily responsible for managing the investments of Primeo Fund, which invested only in BLMIS.

Nograsek (himself and through Bank Austria) committed acts of wire fraud, mail fraud, and conspiracy in furtherance of the Illegal Scheme.

3. UniCredit Corporate Defendants

a. UniCredit S.p.A. (“UniCredit”). UniCredit is an Italian banking consortium that acquired Bank Austria in 2005 through the purchase of HVB (the 100% owner of Bank Austria). UniCredit is a member of the Medici Enterprise and maintains a branch at 150 E. 42nd Street, New

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York, New York.

UniCredit has been involved with Madoff and BLMIS since at least 2000, through its wholly owned investment arm Pioneer. Pioneer was involved with BLMIS feeder funds Fairfield Sentry Ltd. and Kingate Global Fund Ltd. In 2007, after UniCredit acquired Bank Austria and Bank Medici, Pioneer took over from BA Worldwide as Primeo Fund’s investment manager. Kohn’s relationship with UniCredit predates its acquisition of Bank Austria.

Profumo, former CEO of UniCredit from 1997 until 2010, enjoyed a close working relationship with Kohn prior to his bank’s acquisition of Bank Austria in 2005. Gutty, former Vice Chairman of UniCredit, also enjoyed a close working relationship with Kohn from his days with Banca Intesa, and subsequently served on the boards of Bank Medici and PrivatLife with Kohn.

Upon its acquisition of Bank Austria, UniCredit, through Pioneer, directed Primeo Fund to close its direct account with BLMIS in 2007 and invest with BLMIS indirectly through Herald Fund, Alpha Prime Fund, and Thema International. UniCredit memorialized its participation in the Illegal Scheme and entry into the Medici Enterprise by directing Pioneer to produce false prospectuses that concealed Primeo Fund’s investment in BLMIS.

UniCredit partnered with Kohn, Bank Medici, and Revi to create the Liechtenstein Sham Entities.

UniCredit committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, transportation of funds taken by fraud, and conspiracy in furtherance of the Illegal Scheme.

b. Pioneer Global Asset Management S.p.A. (“Pioneer”). Pioneer was incorporated on October 19, 2000 under the laws of Italy. UniCredit created and wholly owns Pioneer. Pioneer is a member of the Medici Enterprise. One of Pioneer’s wholly owned subsidiaries replaced BA Worldwide as the investment adviser to Primeo Fund starting on April 25, 2007. Pioneer has a wholly owned subsidiary in New York, created in 2002, and located at 330 Madison Avenue, New York, New York 10017.

Pioneer paid Bank Medici approximately $1,200,000 in retrocession fees sometime in 2007.

After the integration of UniCredit, Pioneer, Bank Austria, Bank Medici, and Primeo Fund, UniCredit and Pioneer began to be paid in the pattern

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and practice of the Medici Enterprise. From July 2008 until November 2008, HAM paid Pioneer at least $9,439,787.95.

Pioneer committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, transportation of funds taken by fraud, receipt of stolen funds, and conspiracy in furtherance of the Illegal Scheme.

4. UniCredit Individual Defendants

a. Alessandro Profumo (“Profumo”). Profumo is an Italian citizen. He served as CEO of UniCredit from 1997 until September 21, 2010. Beginning in 2005, Profumo served as the Chairman of the Supervisory Board of HVB. Profumo is a member of the Medici Enterprise.

Profumo oversaw UniCredit’s acquisition of Bank Austria and Bank Medici and, on information and belief, directed the replacement of BA Worldwide by Pioneer as investment manager of Primeo Fund. All the while, Kohn maintained close relationships with Profumo and other UniCredit executives.

Profumo (through UniCredit and Pioneer) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

b. Gianfranco Gutty (“Gutty”). Gutty is an Italian citizen. Gutty is a member of the Medici Enterprise. He served as Deputy Chairman of UniCredit from 2006-2008. Prior to this appointment, Gutty served on the board of UniCredit from 2005-2008. Gutty also served as a director for Bank Medici and PrivatLife AG (“PrivatLife”), a Liechtenstein based insurance company of which Kohn serves on the supervisory board and is the majority shareholder. Gutty remained on the Bank Medici board alongside Kohn until 2009.

Gutty (through Bank Medici, Pioneer, and UniCredit) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

E. HOLDING COMPANY DEFENDANTS

1. Redcrest Investments, Inc. (“Redcrest”). Redcrest is a company located in the British Virgin Islands and incorporated on January 20, 2003. It is the corporate parent of Line Holdings, Line Management, Line Group, and Tecno Gibraltar. On information and belief, Redcrest holds its interests in Tecno Gibraltar in trust for Kohn. Redcrest is a member of the Medici Enterprise.

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Redcrest (through Tecno Gibraltar) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, and conspiracy in furtherance of the Illegal Scheme.

2. Line Group Ltd. (“Line Group”). Line Group is a company incorporated in Gibraltar on January 14, 2008 and wholly owned by Redcrest. Line Group owns 100% of Line Management. A number of the directors of Line Group are partners or associates of Hassans. Line Group is a member of the Medici Enterprise.

Line Group (through Tecno Gibraltar) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, and conspiracy in furtherance of the Illegal Scheme.

3. Line Management Services Ltd. (“Line Management”). Line Management is a company incorporated in Gibraltar on March 22, 1995 and wholly owned by Line Group. Line Management owns 100% of Line Holdings. A number of the directors of this company are partners or associates of Hassans. Tecno Gibraltar’s sole director is also employed by Line Management. Line Management is a member of the Medici Enterprise.

Line Management (through Tecno Gibraltar) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, financial institution fraud, and conspiracy in furtherance of the Illegal Scheme.

4. Line Holdings Ltd. (“Line Holdings”). Line Holdings is a company incorporated in Gibraltar on July 15, 1988 and wholly owned by Line Management. A number of the directors of this company are partners or associates of Hassans. Line Holdings holds 100% of Herald Consult Limited in trust for Kohn and E. Kohn and is a corporate parent of HAM. On information and belief, Line Holdings holds I-Tech’s shares for RTH. Line Holdings is a member of the Medici Enterprise.

Line Holdings (through Tecno Gibraltar and HAM) committed acts of wire fraud, financial institution fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

5. Herald Consult Ltd. (“Herald Consult”). Herald Consult is a company incorporated in Gibraltar on March 12, 2004 and wholly owned by Line Holdings. Herald Consult owns 100% of HAM. Herald Consult’s parent, Line Holdings, holds its interest in HAM in trust for Kohn and E. Kohn. Herald Consult is a member of the Medici Enterprise.

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Herald Consult (through HAM) committed acts of wire fraud, money laundering, engaging in monetary transactions in property derived from specific unlawful activity, and conspiracy in furtherance of the Illegal Scheme.

F. SUBSEQUENT TRANSFEREE DEFENDANT

1. Sharei Halacha Jerusalem, Inc. (“Sharei”). Sharei is a company incorporated in New York on or about November 1999. On information and belief, E. Kohn is the President and founder of Sharei’s Israeli branch. R. Kohn directs Sharei’s Israeli branch. Also on information and belief, Herzog, Landau, Y. Landau, and Ra. Kohn are affiliated with Sharei.

From May 2002 through July 2008, Sharei received eight payments totaling at least $180,000 of stolen Customer Property from Infovaleur.

G. JOHN AND JANE DOES 1-100

The Trustee asserts claims against those whose true identities, roles, and responsibilities in relation to the Medici Enterprise and Illegal Scheme have yet to be ascertained. They may include additional Kohn family members and others who participated in the Illegal Scheme. Given the deliberately complex and obfuscatory structure of the Medici Enterprise, the Trustee anticipates amending this Amended RICO Case Statement and accompanying Second Amended Complaint after discovery.

c. List other Non-Defendant Bad Actors, other than the named Defendants, and describe the alleged misconduct of each wrongdoer.

The primary other wrongdoers of whom the Trustee is currently aware are listed below and grouped according to their main affiliation.

H. BLMIS

1. Bernard L. Madoff Investment Securities LLC (“BLMIS”). BLMIS was founded in 1959 by Madoff and, for most of its existence, operated from its principal place of business at 885 Third Avenue, New York, New York. Madoff, as founder, chairman, CEO, and sole owner, operated BLMIS together with several of his friends and family members. BLMIS was registered with the SEC as a securities broker-dealer under Section 15(b) of the Securities Exchange Act of 1934 (the “1934 Act”), SIPA § 78o(b). By virtue of that registration, BLMIS is a member of SIPC. BLMIS had three business units: the investment advisory business (“IA Business”), market-making, and proprietary trading. The Illegal Scheme perpetuated and fed off Madoff’s IA Business. Since at least the inception of the Illegal Scheme, Madoff ran his IA Business as a Ponzi scheme. Nonetheless, Kohn directed over $9 billion to Madoff. In return, Kohn and the Medici Enterprise reaped a windfall in unearned fees and other proceeds of the Illegal Scheme.

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The money sent to BLMIS for investment was simply used to keep the scheme going until such time as the requests for redemptions in December 2008 overwhelmed the flow of new investments and caused the inevitable collapse of the Ponzi scheme.

a. Bernard L. Madoff (“Madoff”). Madoff is a citizen of the United States and at all relevant times was a close friend and associate of Kohn. Kohn communicated with Madoff regularly, and traveled to and from New York and elsewhere to visit him, his family, and BLMIS. On March 12, 2009, Madoff pled guilty to, among other things, securities fraud, investment adviser fraud, mail fraud, wire fraud, three counts of money laundering, false statements, and false filings with the SEC for orchestrating the Ponzi scheme that the Illegal Scheme furthered and from which the Medici Enterprise siphoned stolen Customer Property and other proceeds of the Illegal Scheme.

b. Frank DiPascali (“DiPascali”). DiPascali is a citizen of the United States. DiPascali was Madoff’s right hand man and BLMIS’s CFO. He communicated directly with Bank Austria in relation to Bank Austria’s direct account with BLMIS. On August 11, 2009, DiPascali pled guilty to conspiracy, securities fraud, investment adviser fraud, falsifying books and records of a broker-dealer, falsifying books and records of an investment adviser, mail fraud, wire fraud, and international money laundering to promote specified unlawful activity.

2. Cohmad Securities Corporation

a. Cohmad Securities Corporation (“Cohmad”). Cohmad is a corporation organized and existing under the laws of the State of New York. Its principal place of business is 885 Third Avenue, New York, New York 10022. Cohmad was registered with the SEC and was a member of the Financial Industry Regulatory Authority (“FINRA”), formerly the National Association of Securities Dealers (“NASD”).

b. Maurice (Sonny) Cohn (“Cohn”). Cohn is the owner of Cohmad and serves as its Chairman and President. Cohn is registered as an agent of Cohmad with CRD Number 1313085. He is a citizen and a resident of the State of New York. Cohn is responsible for introducing Kohn to Madoff in or about 1985. Madoff paid Cohmad at least $526,000 for this introduction.

3. Madoff Securities International Ltd.

a. Madoff Securities International Ltd. (“MSIL”).3 Madoff created MSIL in 1983 and controls it as BLMIS’s London affiliate. Certain of Madoff’s

3 MSIL brought an action in England against, among others, its former officers and directors for breaching their

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kickbacks of stolen Customer Property to Kohn and her Sham Entities were paid from Madoff’s London accounts. All of Kohn’s kickbacks were directed by Madoff from New York.

b. Leon Flax (“Flax”). Flax is a citizen of South Africa and a resident of London, England. He was a director of MSIL from 1986 until May 23, 2009 when the company was placed in liquidation. Originally, he was responsible for MSIL’s office management, accounting, and payroll, though later he became the managing director. Flax had numerous direct accounts with BLMIS. Flax authorized and executed scores of Madoff’s payments to Kohn via check and wire transfer as directed by Madoff from New York.

c. Steven Raven (“Raven”). Raven is a British subject and resident of London, England. He was a director of MSIL in 1983 and, thereafter, a non-executive director from 1992-1994, executive director from 1994- 2004, and CEO from 2004 until the company was placed in liquidation after Madoff’s confession. At various times, he also acted as a compliance officer for MSIL. Raven authorized and executed scores of Madoff’s payments to Kohn via check and wire transfer as directed by Madoff from New York.

I. MEDICI ENTERPRISE FEEDER FUNDS

The Medici Enterprise profited on the backs of those who invested with BLMIS through the Medici Enterprise Feeder Funds. For over fifteen years, the Medici Enterprise Feeder Funds fed almost $4 billion into the Ponzi scheme and generated hundreds of millions of dollars of management, distribution, and other fees and other illicit proceeds of the Illegal Scheme for Kohn, Bank Medici, Bank Austria, UniCredit, HAM, and other members of the Medici Enterprise. On information and belief, certain of these proceeds of the Illegal Scheme that relate to the Medici Enterprise Feeder Funds are stolen Customer Property. This structure of feeding money into BLMIS in return for illegal proceeds for the Medici Enterprise is the crux of the “Money-In” aspect of the Illegal Scheme.

Kohn routinely disregarded the directions of Bank Medici and Bank Austria clients to place their money with particular Medici Enterprise Feeder Funds. Kohn treated the Medici Enterprise Feeder Funds, like her Sham Entities, as interchangeable. For example, in 2008 Kohn told Bank Medici client, Shpe, that her money would be invested in Herald Fund when it was in fact invested in Herald (Lux). Kohn, Bank Medici, Bank Austria, and other members of the Medici Enterprise represented that Herald Fund and Herald (Lux) were different investments. In fact, they were both 100% invested in BLMIS (as were all the Medici Enterprise Feeder Funds). Kohn and other members of the Medici Enterprise conspired to disguise this fact. UniCredit similarly exploited the purported formal differences between and among the Medici Enterprise Feeder Funds to disguise its investment with BLMIS.

fiduciary duty to MSIL by following Madoff’s directions to pay, among others, Kohn. Kohn, Tecno Gibraltar, and Erko are defendants in this action.

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1. Primeo Fund Ltd. (“Primeo Fund”). Primeo Fund is an open-ended investment fund incorporated in the Cayman Islands on November 18, 1993 and created by Kohn, Eurovaleur, Bank Austria, Randa, Scheithauer, Zapotocky, Kretschmer, Kadrnoska, and Hemetsberger. Throughout its entire existence, Primeo Fund was 100% invested with BLMIS, holding account numbers 1FN060 and 1FN092. Primeo Fund fed at least $371,690,000 into BLMIS. To disguise its involvement with BLMIS, UniCredit directed that Primeo Fund invest in other Medici Enterprise Feeder Funds, including Herald Fund, Alpha Prime Fund, and Thema International. All of the Medici Enterprise Feeder Funds were 100% invested in BLMIS.

Kohn, Eurovaleur, Bank Austria, Bank Medici and its branches (including MediciFinanz), HAM, and other members of the Medici Enterprise marketed, distributed, and sold Primeo Fund. BA Worldwide served as Primeo Fund’s investment adviser from 1993 until April 25, 2007. At UniCredit’s direction, Pioneer replaced BA Worldwide as Primeo Fund’s investment manager in 2007 and hired Radel-Leszczynski to ensure continuity with Madoff.

2. Thema International Fund plc (“Thema International”). Thema International is a hedge fund incorporated in Ireland on May 9, 1996. Thema International is owned and controlled by the Benbassat family of Genevalor, Benbassat, & Cie. At all relevant times, Thema International was 100% invested with BLMIS, holding account number 1FN095. Thema International fed over a billion dollars into BLMIS over its twelve-year existence.

Kohn, Eurovaleur, Bank Austria, Bank Medici and its branches, HAM, and other members of the Medici Enterprise marketed, distributed, and sold Thema International. In 1996, Kohn, through Eurovaleur, received a 10% ownership interest in Thema International’s investment manager as a “thank you” from its principals in return for Kohn introducing them to Madoff. Also beginning in 1996, Kohn’s relationship with Thema International’s principals led to Bank Medici receiving fees for distributing and marketing Thema International. This arrangement furthered the Medici Enterprise and lasted until Madoff confessed to running a Ponzi scheme. In 2006, Bank Medici became the investment manager to Thema International and received fees for this purported service in furtherance of the Illegal Scheme.

From 2006 to 2008, Bank Medici served as Thema International’s investment manager. Additionally, BA Worldwide served as Thema International’s investment adviser.

Kohn, Eurovaleur, Bank Austria, Bank Medici and its branches (including MediciFinanz), HAM, and other members of the Medici Enterprise marketed, distributed, and sold Thema International Fund.

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3. Alpha Prime Fund Ltd. (“Alpha Prime Fund”). Alpha Prime Fund is a Bermuda-based investment fund incorporated on March 12, 2003. At all relevant times, Alpha Prime Fund was 100% invested with BLMIS, holding account number 1FR097. Alpha Prime Fund fed at least $399.9 million into BLMIS over its five-year existence.

Alpha Prime Fund was created by Kohn, Zapotocky, and Radel-Leszczynski and was a structural “clone” of Primeo Fund. Zapotocky created this additional investment vehicle into BLMIS to further the Illegal Scheme and further enrich himself and Kohn. Kohn served as a director to Alpha Prime Fund.

Kohn, Eurovaleur, Bank Austria, Bank Medici and its branches (including MediciFinanz), HAM, and other members of the Medici Enterprise marketed, distributed, and sold Alpha Prime Fund. BA Worldwide was Alpha Prime Fund’s investment adviser beginning in 2003.

4. Herald Fund SPC (“Herald Fund”). Herald Fund is an investment fund incorporated in the Cayman Islands on March 24, 2004 and created by Kohn, Eurovaleur, Bank Austria, and Bank Medici. At all relevant times, Herald Fund was 100% invested with BLMIS, holding account number 1FR109. Herald Fund fed at least $1.5 billion into BLMIS over its five-year existence. Herald Fund issued withdrawals of more than $536 million in the three months leading up to Madoff’s confession.

Kohn, Eurovaleur, Bank Austria, Bank Medici and its branches (including MediciFinanz), HAM, and other members of the Medici Enterprise marketed, distributed, and sold Herald Fund. Herald Fund’s purported investment manager was HAM, although Bank Medici contributed to overseeing its day-to-day operations. HAM and Bank Medici pretended to select the stocks that Madoff in turn purported to select.

5. Senator Fund Ltd. (“Senator Fund”). Senator Fund is a Bermuda-based fund that was incorporated on March 12, 2006. At all relevant times, Senator Fund was 100% invested with BLMIS, holding account number 1FR128. Senator Fund fed at least $247 million into BLMIS over its two-year existence.

Senator Fund was created by Radel-Leszczynski and was a structural “clone” of Alpha Prime, which is in turn a structural “clone” of Primeo Fund. Radel- Leszczynski masterminded this additional investment vehicle into BLMIS to further the Illegal Scheme and further enrich herself and Kohn.

Kohn, Eurovaleur, Bank Austria, Bank Medici and its branches, HAM, and other members of the Medici Enterprise marketed, distributed, and sold Senator Fund.

6. Herald (Lux) SICAV (“Herald (Lux)”). Herald (Lux) is an investment fund incorporated in Luxembourg on February 18, 2008 and created by Kohn,

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Eurovaleur, Bank Austria, Bank Medici, and Frey. At all relevant times, Herald (Lux) was 100% invested with BLMIS, holding account number 1FR135. Herald (Lux) fed at least $255.6 million into BLMIS over its existence.

Kohn, Eurovaleur, Bank Austria, Bank Medici and its branches (including MediciFinanz), HAM, and other members of the Medici Enterprise marketed, distributed, and sold Herald (Lux). Bank Medici served as the investment manager for Herald (Lux). Scheithauer served as a director to Herald (Lux).

Herald (Lux) was one of the Medici Enterprise’s last efforts to feed money into BLMIS before Madoff confessed to running a Ponzi scheme.

J. ITALIAN INSTITUTIONS AND AGENTS

1. Intesa Sanpaolo S.p.A. (“Banca Intesa”). Banca Intesa is an Italian bank based in Milan. Banca Intesa partnered with Kohn to create Non-Defendant Bad Actor FundsWorld. Banca Intesa and its predecessors were partly owned by Bank Austria. Gutty served as a director at Banca Intesa prior to his employment with UniCredit. It was during his employment with Banca Intesa that he and Kohn became acquainted.

2. FundsWorld Financial Services Ltd. (“FundsWorld”). Kohn founded FundsWorld in Ireland in December 1998 as Nole Brook Ltd. Kohn changed its name to FundsWorld in December 1999 and registered it in Italy under the name FundsWorld Financial Services Ltd. on May 20, 2002. At all relevant times, Kohn operated FundsWorld from Milan, Italy. Kohn, through FundsWorld, made payments to her New York Sham Entity Eurovaleur of €750,000 in 2000 and over €1.1 million in 2002. On information and belief, Kohn established FundsWorld to sell access to the Medici Enterprise Feeder Funds. Kohn, through Eurovaleur, informed Mark Madoff at BLMIS of FundsWorld’s offerings.

3. Brera Servizi Aziendiale S.r.l. (“Brera”). Brera is located in Milan, Italy, and was incorporated on November 7, 1981. Brera holds 95% of Tecno Italy in trust for an unknown beneficiary. On information and belief, this beneficiary is Kohn.

4. Dario Frigerio (“Frigerio”). Frigerio is a citizen of Italy. Frigerio was a high- ranking executive at Pioneer during the Illegal Scheme. Kohn’s partnership with Bank Austria and Banca Intesa in the early 2000s allowed her to meet Frigerio and other members in the inner circle of the Milanese banking community.

5. Alberto La Rocca (“La Rocca”). La Rocca is a citizen of Italy. La Rocca is the CEO of UniCredit’s Pioneer and a citizen of Italy. La Rocca was critical to executing UniCredit’s scheme to invest Primeo Fund’s assets indirectly into BLMIS through Herald Fund, Alpha Prime Fund, and Thema International. La Rocca corresponded with Radel-Leszczynski, BA Worldwide, Bank Medici, Kohn, and BLMIS in 2007 regarding this secret transfer of Primeo Fund shares.

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6. Paul Tiranno (“Tiranno”). Tiranno is a citizen of New York. Tiranno is an employee of UniCredit’s Pioneer. Shortly after UniCredit’s acquisition of Bank Austria, UniCredit directed Tiranno to travel to New York to meet with Madoff, Kohn, and Reuss. Tiranno’s meetings with BLMIS and Eurovaleur were to discuss UniCredit’s efforts to disguise the extent and nature of its involvement with BLMIS through Pioneer and Primeo Fund. After this meeting, Reuss sent Tiranno an e-mail providing him with the necessary details for Primeo Fund to invest in Herald Fund.

K. KOHN’S SLUSH FUND RECIPIENTS

1. Gerila Beteiligungsverwaltungs GmbH (“Gerila”). Kastner is the creator and owner of Gerila, which received a €600,000 transfer from Kohn via HAM. On information and belief, this transfer was a personal loan from Kohn to Kastner to cover expenses related to his divorce.

2. Infotech Applications (“Infotech”). From August 2002 through October 2006, Infotech received at least $2,670,120 of stolen Customer Property from Infovaleur. These payments were made via check. The signed endorsements on these checks were identical to those Infovaleur sent to Eastview, Tonga, Systor, and Non-Defendant Bad Actor Enchanted Rock.

3. Austrasia. Austrasia received a check from Infovaleur totaling $90,000 on June 24, 2002. On information and belief, this payment was for the benefit of Herzog. Kohn signed and endorsed this check.

4. Enchanted Rock Ltd. (“Enchanted Rock”). From May 2006 to September 2006, Enchanted Rock received $621,000 of stolen Customer Property from Infovaleur. These payments were made via check. The signed endorsements on these checks were identical to the checks Infovaleur sent to Eastview, Systor, Tonga, and Non-Defendant Bad Actor Infotech.

5. A.L.A. From March 2007 to June 2008, A.L.A. received $415,000 of stolen Customer Property from Infovaleur.

6. Hungarian Foreign Trade Bank (“MKB”). On March 2002, MKB received two checks from Infovaleur totaling $85,000 of stolen Customer Property.

7. Aurelia Worldwide S.A. (“Aurelia Worldwide”). Aurelia Worldwide was formed in the BVI on May 18, 2001. Aurelia Worldwide dissolved in November 2010. On October 25, 2006, Aurelia received one payment totaling $120,000 of stolen Customer Property from Infovaleur.

8. Tamiza Investments Ltd. (“Tamiza”). Tamiza was formed in the BVI on January 2, 2007. Tamiza dissolved on June 1, 2011. On February 2, 2009, Tamiza received a one-time payment of $299,995 from Tecno Italy for the benefit

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of E. Kohn. Tecno Italy was dissolved at the time of the payment. This payment resulted in a criminal money laundering investigation by the Swiss authorities.

9. Marina Ventures LLC (“Marina Ventures”). From March 2003 to August 2003, Marina Ventures received at least $60,500 of stolen Customer Property from Infovaleur. On information and belief, these payments were made for the benefit of M. Hartstein.

L. BANK AGENTS

1. Hassans International Law Firm (“Hassans”). Hassans is Gibraltar’s premier law firm. Hassans is counsel to key members of the Medici Enterprise, including Kohn, Herald Fund, and on information and belief, HAM. Kohn has a longstanding relationship with Hassans. Bank Medici Gibraltar and Medici Realty are located in Hassans’s offices. Certain partners and associates at Hassans also hold non-lawyer corporate positions at certain Holding Company Defendants controlled by Hassans, Kohn, or other members of the Medici Enterprise. These entities purport to offer private company management and private banking services and appear to be part of a deliberately complex structure orchestrated by Kohn and engineered Hassans that includes, for example, HAM, Cosulich, de Sury, Mugnai, Tecno Gibraltar, Bank Medici Gibraltar, and Medici Realty.

Days, if not hours, before Madoff confessed, HAM unsuccessfully attempted to transfer $6.5 million and €6.5 million to accounts in Gibraltar held by Hassans. On February 3, 2009 Hassans received payments of €295,587 and $428,316 from Eurovaleur.

2. Thema Asset Management, Ltd. (“TAM”). TAM is a company organized under the laws of the British Virgin Islands with a registered address c/o Codan Trust Company (B.V.I.) Ltd., Romasco Place, P.O. Box 3140, Road Town, Tortola, British Virgin Islands. TAM served as the investment manager and global distributor for Thema International. Eurovaleur owned 10% of TAM.

3. ReviTrust Services Est. (“Revi”). Revi is a Liechtenstein company that operates as a corporate registry and trust formation agent in Liechtenstein and Switzerland. Revi is a member of the Medici Enterprise.

At Kohn’s direction, Revi received three payments from HAM in 2008 totaling approximately $5.33 million. At Kohn and UniCredit’s direction, Revi used large portions of this sum to capitalize the Liechtenstein Sham Entities.

4. HypoVereinsbank (“HVB”). HVB is a German bank and the corporate parent of Bank Austria. HVB is wholly owned by UniCredit.

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5. Friedrich Pfeffer (“Pfeffer”). Pfeffer is an Austrian citizen. On February 3, 2003, Pfeffer received a one-time payment of $800 of stolen Customer Property from Infovaleur.

6. Helmut Horvath (“Horvath”). Horvath is an Austrian citizen. Horvath is a former Bank Medici employee. From July 2006 to September 2006, Horvath received at least $4,000 of stolen Customer Property from Infovaleur.

7. Alexandra Lavi (“Lavi”). Lavi is an Israeli citizen. She was a financial adviser at Bank Medici. She was responsible for advising Bank Medici client Shpe when Shpe invested in Herald (Lux). When questioned by Shpe after Madoff confessed to running a Ponzi scheme, Lavi admitted that she carried out Kohn’s instructions to fraudulently conceal from investors the fact that their money was ultimately invested with BLMIS.

8. Medici Realty Ltd. (“Medici Realty”). Medici Realty is a Gibraltarian company. Kohn and Hassans created Medici Realty on March 17, 2006. E. Kohn serves as its director. Line Holdings owns 75% of Medici Realty and Bank Medici Gibraltar owns the balance. Hassans employees also serve on Medici Realty’s board.

M. SHAM ENTITY AGENTS

1. Alon Technology Ventures Ltd. (“Alon Technology”). Kohn and Bank Austria created this company in the BVI in 2000.

2. Anne Kritzer (“Kritzer”). Kritzer is an Austrian citizen. She is a former employee of Eurovaleur. Kritzer corresponded with BLMIS on behalf of Kohn and Eurovaleur.

3. Susan Alexander (“Alexander”). On information and belief, Alexander is an American citizen. Alexander was a former shareholder, director, vice-president, and secretary of Infovaleur.

4. Aleksander Kampa (“Kampa”). On information and belief, Kampa is an American citizen. Kampa served as director and president of Infovaleur. Kampa received a one-time $2,000 payment from Infovaleur through his company GAX.

5. Thomas Grasso (“Grasso”). Grasso is a Swiss citizen. He is a former employee of Eurovaleur. Grasso corresponded with BLMIS on behalf of Kohn and Eurovaleur.

N. KOHN’S OTHER NEW YORK AGENTS

1. Medici Fund Management Company, Inc. (“Medici Fund Management”). Medici Fund Management was a Delaware company registered to do business in New York. Medici Fund Management had no known business purpose and, on

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information and belief, was used by Kohn to further the Illegal Scheme. It was dissolved in 1999.

2. Medici Finance Services, Inc. (“Medici Finance Services”). Medici Finance Services was a New York corporation dissolved on July 29, 2009. Medici Finance Services had no known business purpose and, on information and belief, was used by Kohn to further the Illegal Scheme. E. Kohn, at Eurovaleur’s 767 Fifth Avenue address, was Medici Finance Service’s registered agent.

d. List the victims and state how each victim was injured:

The Trustee represents the BLMIS estate and is empowered to recover all Customer Property and damages to the business and property of the BLMIS estate resulting from the deepened insolvency directly caused by the racketeering activity of the Defendants in furtherance of the Illegal Scheme.

The Trustee seeks the return of all Customer Property for BLMIS customers, in the form of secret corrupt kickbacks from Madoff, unearned fees, compensation, bonuses, and otherwise, as well as all damages, compensatory, punitive, or otherwise (all damages trebled under RICO), caused by the Defendants’ racketeering activity in furtherance of the Illegal Scheme, and the disgorgement of all proceeds of the Illegal Scheme by which the Defendants and the Medici Enterprise were unjustly enriched at the expense of the BLMIS estate.

Plaintiff is the Trustee appointed by order dated December 15, 2008 for the liquidation of the business of BLMIS under SIPA § 78eee(b)(3). Under SIPA § 78fff-1(a), the Trustee has the general powers of a bankruptcy trustee in a case under the Bankruptcy Code. Chapters 1, 3, 5, and subchapters I and II of chapter 7 of the Bankruptcy Code are applicable to this case to the extent consistent with SIPA § 8fff(b). In addition to the powers of a bankruptcy trustee, the Trustee has broader powers granted by SIPA. The Trustee is a real party in interest and has standing to bring these claims under SIPA § 78fff-1 and the Bankruptcy Code, including sections 323(b) and 704(a)(1) of Title 11. The RICO claims asserted herein are assertable only by the Trustee.

e. Describe the alleged injury to business or property:

Each Defendant member of the Medici Enterprise conspired to participate in, and committed acts in furtherance of, the Illegal Scheme to: (i) feed investors’ money into the Ponzi scheme; and (ii) enrich themselves and the Medici Enterprise in the process via kickbacks from Madoff, unearned fees, compensation, bonuses, and other proceeds of the Illegal Scheme. All of Kohn’s kickbacks and certain of these proceeds of the Illegal Scheme are stolen Customer Property. As a proximate result of the Illegal Scheme, the estate and customers of BLMIS have suffered an injury in fact to their business and property for which the Trustee is entitled to reimbursement in the form of, among other things, monetary damages trebled under RICO. The total amount lost in the Ponzi scheme is approximately $19.6 billion. By this action, the Trustee seeks damages in at least that amount, trebled under RICO.

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f. Describe in detail the pattern of racketeering activity or collection of unlawful debts for each RICO claim:

Defendants’ racketeering activity in furtherance of the Illegal Scheme forms a “pattern” in that more than two predicate acts were committed within ten years of each other as per 18 U.S.C. § 1961(5), as alleged below. Each of the Defendants’ actions were undertaken to further the Illegal Scheme and enrich each Defendant and the Medici Enterprise, expand the scope of the Medici Enterprise, and perpetuate the Medici Enterprise and the Illegal Scheme. Defendants’ acts in furtherance of the Illegal Scheme are related; have similar purposes, results, participants, victims, or methods of commission; are systematic in nature; and are not isolated events. Defendants’ acts in furtherance of the Illegal Scheme are part of the Medici Enterprise’s regular way of doing business.

The description of the pattern of racketeering shall:

(1) List the predicate acts and specific statutes which were violated:

Defendants, in carrying out the goals and objectives of the Medici Enterprise, committed repeated and related acts of: (i) engaging in monetary transactions in property derived from specific unlawful activity in violation of 18 U.S.C. § 1957; (ii) wire fraud in violation of 18 U.S.C. § 1343; (iii) mail fraud in violation of 18 U.S.C. § 1341; (iv) money laundering in violation of 18 U.S.C. § 1956; (v) financial institution fraud in violation of 18 U.S.C. § 1344; (vi) transportation of people to defraud in violation of 18 U.S.C. § 2314; (vii) transportation of funds taken by fraud in violation of 18 U.S.C. § 2314; (viii) receipt of stolen funds in violation of 18 U.S.C. § 2315; and (ix) interstate and international travel in violation of the Travel Act, 18 U.S.C. § 1952.

These violations constitute predicate acts that constitute a coordinated and intricate pattern of racketeering activity, as defined in 18 U.S.C. § 1961(1) and as described fully as a “pattern” in response to f(6) below. This pattern of racketeering activity is the direct and proximate cause of the injury to the business and property of the BLMIS estate.

Money Laundering in violation of 18 U.S.C. § 1956:

1. Transfers from BLMIS to Infovaleur: Predicate Acts 1-184

a. Illegal Scheme

b. Kohn, Infovaleur, Eurovaleur, and Reuss

c. One hundred eighty four (184) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Infovaleur from July 15, 1998 to October 2, 2008

2. Transfers from Infovaleur to Kohn Family Defendants: Predicate Acts 185-464

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a. Illegal Scheme

b. Kohn, E. Kohn, Herzog, Infovaleur, Eurovaleur, Reuss, M. Hartstein, R. Hartstein, M. Kohn, Landau, Y. Landau, R. Kohn

c. Two hundred eighty (280) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Kohn Family Defendants from March 27, 2002 to March 5, 2009

3. Transfers from Infovaleur to other Medici Enterprise Defendants: Predicate Acts 465-1410

a. Illegal Scheme

b. Kohn, Reuss, Infovaleur, Eurovaleur, Marketinc, Eastview, De Sury, New Economy, Infotech, RTH, Bank Austria, ITR, Duregger, Lantzitsky, Systor, Cosulich, Pirkner, Frey, Giefing, APM Cayman, MediciFinanz, Kastner, Tecno Italy, Blau, Raule, Florio, I-Tech, E. Kohn, RTH, Medici S.r.l., Bank Medici, Gutty, M-Tech, Landau, Scheithauer, and Tripolt

c. Nine hundred forty-six (946) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Medici Enterprise Defendants from May 7, 2002 to January 13, 2009

4. Transfers from Erko to Kohn Family Defendants: Predicate Acts 1411- 1490

a. Illegal Scheme

b. Kohn, E. Kohn, Erko, Blau, R. Kohn, Ra. Kohn, and Herzog

c. Eighty (80) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from Erko to Kohn Family Defendants from February 14, 2002 to June 24, 2009

5. Transfer from Tecno Italy to E. Kohn: Predicate Acts 1491-1500

a. Illegal Scheme

b. Kohn, E. Kohn, Blau, Tecno Italy, Bank Medici, Raule, Florio, I- Tech, RTH, and Medici S.r.l.

c. Ten (10) Money Laundering violations between and among the above-mentioned Defendants, in relation to a payment from Tecno Italy to E. Kohn, through Tamiza, on February 2, 2009

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6. Transfers from MSIL to Erko: Predicate Acts 1501-1620

a. Illegal Scheme

b. Kohn, E. Kohn, and Erko

c. One hundred twenty (120) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from MSIL to Erko from December 31, 1992 to December 18, 2001

7. Transfers from MSIL to Tecno Italy: Predicate Acts 1621-1800

a. Illegal Scheme

b. Kohn, Tecno Italy, Medici S.r.l., Bank Medici, Blau, Florio, I- Tech, RTH, and Raule

c. One hundred eighty (180) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from MSIL to Tecno Italy from May 21, 2002 to January 2, 2007

8. Transfers from MSIL to Tecno Gibraltar: Predicate Acts 1801-1816

a. Illegal Scheme

b. Kohn, Tecno Gibraltar, Bank Medici Gibraltar, Amselem, Redcrest, Line Group, Line Management, and Line Holdings

c. Sixteen (16) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from MSIL to Tecno Gibraltar from April 24, 2007 to July 5, 2007

9. Transfers from BLMIS to Tecno Gibraltar: Predicate Acts 1817-1848

a. Illegal Scheme

b. Kohn, Tecno Gibraltar, Bank Medici Gibraltar, Amselem, Redcrest, Line Group, Line Management, and Line Holdings

c. Thirty two (32) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Tecno Gibraltar from January 10, 2008 to August 8, 2008

10. Transfers from BA Worldwide to Eurovaleur: Predicate Acts 1849-3208

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a. Illegal Scheme

b. Kohn, Reuss, Bank Austria, BA Worldwide, Eurovaleur, Randa, Kadrnoska, Zapotocky, Hemetsberger, Nograsek, Fischer, Kretschmer, Duregger, and Radel-Leszczynski

c. One thousand three hundred sixty (1360) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from BA Worldwide to Eurovaleur from January 1, 1996 to April 1, 2007

11. Transfer from Erko to Brightlight: Predicate Acts 3209-3213

a. Illegal Scheme

b. Kohn, E. Kohn, Erko, and Brightlight

c. Five (5) Money Laundering violations between and among the above-mentioned Defendants, in relation to a payment from Erko to Brightlight on May 8, 2003

12. Transfers from FundsWorld to Eurovaleur: Predicate Acts 3214-3219

a. Illegal Scheme

b. Kohn, Reuss, and Eurovaleur

c. Six (6) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from FundsWorld to Eurovaleur from December 31, 2000 to December 31, 2002

13. Transfers from Bank Austria to Eurovaleur: Predicate Acts 3220-3443

a. Illegal Scheme

b. Kohn, Reuss, Eurovaleur, Bank Austria, Randa, Kadrnoska, Zapotocky, Radel-Leszczynski, Kretschmer, Fischer, Hemetsberger, Nograsek, and Duregger

c. Two hundred twenty four (224) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from Bank Austria to Eurovaleur from November 8, 2006 to July 23, 2007

14. Transfers from Eurovaleur to Kohn and her co-Defendants: Predicate Acts 3444-3618

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a. Illegal Scheme

b. Kohn, Eurovaleur, Reuss, Infovaleur, Blau, E. Kohn, Tecno Gibraltar, Tonga, Amselem, Line Group, Line Holdings, Line Management, Redcrest, and Bank Medici Gibraltar

c. One hundred seventy five (175) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from Bank Austria to Eurovaleur from July 24, 2001 to March 3, 2009

15. Transfers from HAM to Bank Medici and Medici Cayman: Predicate Acts 3619-5118

a. Illegal Scheme

b. Kohn, HAM, Bank Austria, Bank Medici, Medici S.r.l., Bank Medici Gibraltar, Medici Cayman, Herald Consult, Line Holdings, Gutty, Kastner, E. Kohn, RTH, Raule, Scheithauer, Frey, Tripolt, Schindler, Duregger, Pirkner, Mugnai, de Sury, and Cosulich

c. One thousand five hundred (1500) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from HAM to Bank Medici and Medici Cayman from February 6, 2006 to November 20, 2008

16. Transfers from HAM to APM Cayman: Predicate Acts 5119-5766

a. Illegal Scheme

b. Kohn, HAM, Bank Medici, APM Cayman, MediciFinanz, Herald Consult, Line Holdings, Kastner, Mugnai, de Sury, RTH, Raule, Medici S.r.l., and Cosulich

c. Six hundred forty eight (648) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from HAM to APM Cayman from February 10, 2006 to October 22, 2008

17. Transfers from HAM to Bank Austria Cayman: Predicate Acts 5767-5856

a. Illegal Scheme

b. Kohn, HAM, Bank Austria, Bank Austria Cayman, Medici S.r.l., Raule, E. Kohn, Herald Consult, Line Holdings, Line Management, Line Group, Redcrest, Mugnai, de Sury, Cosulich, and Duregger

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c. Ninety (90) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from HAM to Bank Austria Cayman from November 22, 2006 to January 23, 2008

18. Transfer from Pioneer to Bank Medici: Predicate Acts 5857-5869

a. Illegal Scheme

b. Kohn, Bank Austria, Scheithauer, Frey, Tripolt, Schindler, Pirkner, Duregger, Radel-Leszczynski, Bank Medici, Pioneer, UniCredit, Profumo, and Gutty

c. Thirteen (13) Monetary Laundering violations between and among the above-mentioned Defendants, in relation to the transfer from Pioneer to Bank Medici in 2007

19. Transfers from HAM to Pioneer: Predicate Acts 5870-5964

a. Illegal Scheme

b. Kohn, HAM, Pioneer, Bank Medici, RTH, Raule, E. Kohn, Medici S.r.l., UniCredit, Herald Consult, Line Holdings, Line Management, Line Group, Redcrest, Profumo, Gutty, Mugnai, de Sury, and Cosulich

c. Ninety five (95) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from HAM to Pioneer from July 21, 2008 to November 12, 2008

20. Transfers from HAM to Sofipo: Predicate Acts: 5965-6072

a. Illegal Scheme

b. Kohn, HAM, Sofipo, E. Kohn, RTH, Raule, Herald Consult, Line Holdings, Line Management, Line Group, Redcrest, Mugnai, de Sury, and Cosulich

c. One hundred eight (108) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from HAM to Sofipo from November 16, 2007 to October 22, 2008

21. Transfers from HAM to Kastner, Mugnai, de Sury, and Cosulich: Predicate Acts 6073-6408

a. Illegal Scheme

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b. Kohn, HAM, Herald Consult, Line Group, Line Management, Line Holdings, Redcrest, E. Kohn, Bank Medici, Medici S.r.l., RTH, Raule, Mugnai, de Sury, and Cosulich

c. Three hundred thirty six (336) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from HAM to Mugnai, de Sury, and Cosulich from June 1, 2006 to December 17, 2008

22. Transfers from HAM to Revi: Predicate Acts 6409-6453

a. Illegal Scheme

b. Kohn, HAM, Bank Medici, Medici S.r.l., Herald Consult, Redcrest, Line Group, Line Management, Line Holdings, E. Kohn, RTH, Raule, Mugnai, de Sury, and Cosulich

c. Forty five (45) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments from HAM to Revi from January 9, 2008 to March 27, 2008

23. Transfers Between and Among the Liechtenstein Sham Entities: Predicate Acts 6454-6556

a. Illegal Scheme

b. Kohn, Gutty, PrivatLife, Starvest, and LifeTrust

c. One hundred three (103) Money Laundering violations between and among the above-mentioned Defendants, in relation to payments between and among the Liechtenstein Sham Entities from January 24, 2008 to January 25, 2008

Monetary Transactions in Property Derived from Specified Unlawful Activity in violation of 18 U.S.C. § 1957:

1. Transfers from BLMIS to Infovaleur: Predicate Acts 6557-6740

a. Illegal Scheme

b. Kohn, Infovaleur, Eurovaleur, and Reuss

c. One hundred eighty four (184) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Infovaleur from July 15, 1998 to October 2, 2008

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2. Transfers from Infovaleur to Kohn Family Defendants: Predicate Acts 6741-6805

a. Illegal Scheme

b. Kohn, E. Kohn, Herzog, Infovaleur, Eurovaleur, Reuss, M. Hartstein, R. Hartstein, M. Kohn, Y. Landau, and R. Kohn

c. Sixty five (65) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Kohn Family Defendants from June 24, 2002 to January 6, 2009

3. Transfers from Infovaleur to other Medici Enterprise Defendants: Predicate Acts 6806-7516

a. Illegal Scheme

b. Kohn, Reuss, Infovaleur, Eurovaleur, Marketinc, Eastview, de Sury, New Economy, Infotech, RTH, ITR, Systor, Cosulich, APM Cayman, MediciFinanz, Kastner, Tecno Italy, Blau, Raule, Florio, I-Tech, E. Kohn, RTH, Medici S.r.l., Bank Medici, Gutty, M-Tech, Landau, and Scheithauer

c. Seven hundred eleven (711) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Medici Enterprise Defendants from May 7, 2002 to August 25, 2008

4. Transfers from Erko to Kohn Family Defendants: Predicate Acts 7517- 7580

a. Illegal Scheme

b. Kohn, E. Kohn, Erko, Blau, R. Kohn, Ra. Kohn, and Herzog

c. Sixty four (64) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from Erko to Kohn Family Defendants from February 14, 2002 to June 24, 2009

5. Transfer from Tecno Italy to E. Kohn: Predicate Acts 7581-7590

a. Illegal Scheme

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b. Kohn, E. Kohn, Blau, Tecno Italy, Bank Medici, Raule, Florio, I- Tech, RTH, and Medici S.r.l.

c. Ten (10) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to a payment from Tecno Italy to E. Kohn, through Tamiza, on February 2, 2009

6. Transfers from MSIL to Erko: Predicate Acts 7591-7710

a. Illegal Scheme

b. Kohn, E. Kohn, and Erko

c. One hundred twenty (120) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from MSIL to Erko from December 31, 1992 to December 18, 2001

7. Transfers from MSIL to Tecno Italy: Predicate Acts 7710-7890

a. Illegal Scheme

b. Kohn, Tecno Italy, Medici S.r.l., Bank Medici, Blau, Florio, I- Tech, RTH, and Raule

c. One hundred eighty (180) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from MSIL to Tecno Italy from May 21, 2002 to January 2, 2007

8. Transfers from MSIL to Tecno Gibraltar: Predicate Acts 7891-7906

a. Illegal Scheme

b. Kohn, Tecno Gibraltar, Bank Medici Gibraltar, Amselem, Redcrest, Line Group, Line Management, and Line Holdings

c. Sixteen (16) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from MSIL to Tecno Gibraltar from April 24, 2007 to July 5, 2007

9. Transfers from BLMIS to Tecno Gibraltar: Predicate Acts 7907-7938

a. Illegal Scheme

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b. Kohn, Tecno Gibraltar, Bank Medici Gibraltar, Amselem, Redcrest, Line Group, Line Management, and Line Holdings

c. Thirty two (32) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Tecno Gibraltar from January 10, 2008 to August 8, 2008

10. Transfers from BA Worldwide to Eurovaleur: Predicate Acts 7939-9058

a. Illegal Scheme

b. Kohn, Reuss, Bank Austria, BA Worldwide, Eurovaleur, Randa, Kadrnoska, Zapotocky, Hemetsberger, Nograsek, Fischer, Kretschmer, Duregger, and Radel-Leszczynski

c. One thousand one hundred twenty (1120) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from BA Worldwide to Eurovaleur from January 1, 1998 to April 1, 2007

11. Transfers from Eurovaleur to Kohn and certain co-Defendants: Predicate Acts 9059-9131

a. Illegal Scheme

b. Kohn, Eurovaleur, Reuss, Infovaleur, E. Kohn, Blau, and Tonga

c. Seventy three (73) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from BA Worldwide to Eurovaleur from July 24, 2001 to November 24, 2008

12. Transfer from Erko to Brightlight: Predicate Acts 9132-9136

a. Illegal Scheme

b. Kohn, E. Kohn, Erko, and Brightlight

c. Five (5) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to a payment from Erko to Brightlight on May 8, 2003

13. Transfers from FundsWorld to Eurovaleur: Predicate Acts 9137-9142

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a. Illegal Scheme

b. Kohn, Reuss, and Eurovaleur

c. Six (6) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above- mentioned Defendants, in relation to payments from FundsWorld to Eurovaleur from December 31, 2000 to December 31, 2002

14. Transfers from Bank Austria to Eurovaleur: Predicate Acts 9143-9366

a. Illegal Scheme

b. Kohn, Reuss, Eurovaleur, Bank Austria, Randa, Kadrnoska, Zapotocky, Radel-Leszczynski, Kretschmer, Fischer, Hemetsberger, Nograsek, and Duregger

c. Two hundred twenty four (224) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from Bank Austria to Eurovaleur from November 8, 2006 to July 23, 2007

15. Transfers from HAM to Bank Medici and Medici Cayman: Predicate Acts 9367-10700

a. Illegal Scheme

b. Kohn, HAM, Bank Austria, Bank Medici, Medici S.r.l., Bank Medici Gibraltar, Medici Cayman, Herald Consult, Line Holdings, Gutty, Kastner, E. Kohn, RTH, Raule, Scheithauer, Frey, Tripolt, Schindler, Duregger, Pirkner, Mugnai, de Sury, and Cosulich

c. One thousand three hundred thirty four (1334) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from HAM to Bank Medici and Medici Cayman from February 6, 2006 to November 20, 2008

16. Transfers from HAM to APM Cayman: Predicate Acts 10701-11312

a. Illegal Scheme

b. Kohn, HAM, Bank Medici, APM Cayman, MediciFinanz, Herald Consult, Line Holdings, Kastner, Mugnai, de Sury, RTH, Raule, Medici S.r.l., and Cosulich

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c. Six hundred twelve (612) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from HAM to APM Cayman from February 10, 2006 to October 22, 2008

17. Transfer from HAM to Bank Austria Cayman: Predicate Acts 11313- 11330

a. Illegal Scheme

b. Kohn, HAM, Bank Austria, Bank Austria Cayman, Medici S.r.l., Raule, E. Kohn, Herald Consult, Line Holdings, Line Management, Line Group, Redcrest, Mugnai, de Sury, Cosulich, and Duregger

c. Eighteen (18) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to a payment from HAM to Bank Austria Cayman from November 22, 2006

18. Transfer from Pioneer to Bank Medici: Predicate Acts 11331-11343

a. Illegal Scheme

b. Kohn, Bank Austria, Scheithauer, Frey, Tripolt, Schindler, Pirkner, Duregger, Radel-Leszczynski, Bank Medici, Pioneer, UniCredit, Profumo, and Gutty

c. Thirteen (13) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to the transfer from Pioneer to Bank Medici in 2007

19. Transfers from HAM to Pioneer: Predicate Acts 11344-11438

a. Illegal Scheme

b. Kohn, HAM, Pioneer, Bank Medici, RTH, Raule, E. Kohn, Medici S.r.l., UniCredit, Herald Consult, Line Holdings, Line Management, Line Group, Redcrest, Profumo, Gutty, Mugnai, de Sury, and Cosulich

c. Ninety five (95) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from HAM to Pioneer from July 21, 2008 to November 12, 2008

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20. Transfers from HAM to Kastner, Mugnai, de Sury, and Cosulich: Predicate Acts 11439-11710

a. Illegal Scheme

b. Kohn, HAM, Herald Consult, Line Group, Line Management, Line Holdings, Redcrest, E. Kohn, Bank Medici, Medici S.r.l., RTH, Raule, Mugnai, de Sury, and Cosulich

c. Two hundred seventy two (272) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from HAM to Mugnai, de Sury, and Cosulich from August 1, 2006 to December 17, 2008

21. Transfers from HAM to Revi: Predicate Acts 11711-11755

a. Illegal Scheme

b. Kohn, HAM, Bank Medici, Medici S.r.l., Herald Consult, Redcrest, Line Group, Line Management, Line Holdings, E. Kohn, RTH, Raule, Mugnai, de Sury, and Cosulich

c. Forty five (45) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from HAM to Revi from January 9, 2008 to March 27, 2008

22. Transfers Between and Among the Liechtenstein Sham Entities: Predicate Acts 11756-11858

a. Illegal Scheme

b. Kohn, Gutty, PrivatLife, Starvest, and LifeTrust

c. One hundred three (103) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments between and among the Liechtenstein Sham Entities from January 24, 2008 to January 25, 2008

23. Transfers from BLMIS to Bank Austria: Predicate Acts 11859-11865

a. Illegal Scheme

b. Kohn, Bank Austria, Randa, Zapotocky, Kretschmer, Kadrnoska, and Eurovaleur

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c. Seven (7) Monetary Transactions of Property Derived from Specified Unlawful Activity violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Bank Austria on July 10, 1996

Financial Institution Fraud in violation of 18 U.S.C. § 1344:

1. Transfers from BLMIS to Bank Austria: Predicate Acts 11866-11886

a. Illegal Scheme

b. Kohn, Bank Austria, Randa, Zapotocky, Kretschmer, Kadrnoska, and Eurovaleur

c. Twenty One (21) Financial Institution Fraud violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Bank Austria on August 8, 1996 and September 20, 1996

2. Transfers from BLMIS to Infovaleur: Predicate Acts 11997-12070

a. Illegal Scheme

b. Kohn, Infovaleur, Eurovaleur, and Reuss

c. One hundred eighty four (184) Financial Institution Fraud violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Infovaleur from July 15, 1998 to October 2, 2008

3. Transfers from Infovaleur to Kohn Family Defendants: Predicate Acts 12071-12156

a. Illegal Scheme

b. Kohn, E. Kohn, Herzog, M. Hartstein, R. Hartstein, R. Kohn, Landau, Y. Landau, and M. Kohn

c. Fifty six (56) Financial Institution Fraud violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Kohn Family Defendants from March 27, 2002 to March 5, 2009

4. Transfers from Infovaleur to other Medici Enterprise Defendants: Predicate Acts 12157-12416

a. Illegal Scheme

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b. Kohn, Reuss, Marketinc, Eastview, de Sury, New Economy, Infotech, RTH, Bank Austria, ITR, Duregger, Lantzitsky, Systor, Cosulich, Pirkner, Frey, Giefing, APM Cayman, MediciFinanz, Kastner, Tecno Italy, Blau, Raule, Florio, I-Tech, E. Kohn, RTH, Medici S.r.l., Bank Medici, Gutty, M-Tech, Landau, Scheithauer, and Tripolt

c. Two hundred ninety (290) Financial Institution Fraud violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Medici Enterprise Defendants from May 7, 2002 to January 13, 2009

5. Transfers from BLMIS to Tecno Gibraltar: Predicate Acts 12417-12448

a. Illegal Scheme

b. Kohn, Tecno Gibraltar, Redcrest, Line Group, Line Management, and Line Holdings, and Amselem

c. Thirty two (32) Financial Institution Fraud violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Tecno Gibraltar from January 10, 2008 to August 8, 2008

Wire Fraud in violation of 18 U.S.C. § 1343:

1. November 14, 1989 Facsimile from Gottlieb to BLMIS: Predicate Acts 12449-12450

a. Illegal Scheme

b. Kohn and Windsor

c. Two (2) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Gottlieb and BLMIS on November 14, 1989

2. April 23, 1992 Facsimile from Kohn to Mario Benbassat: Predicate Acts 12450-12454

a. Illegal Scheme

b. Kohn, Eurovaleur, Reuss, and Windsor

c. Four (4) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Kohn and Mario Benbassat on April 23, 1992

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3. August 29, 1995 Facsimile from Kritzer to BLMIS: Predicate Acts 12455-12467

a. Illegal Scheme

b. Kohn, Reuss, Bank Austria, Randa, Zapotocky, Kretschmer, Kadrnoska, Hemetsberger, Nograsek, Fischer, Scheithauer, Duregger, and Eurovaleur

c. Thirteen (13) Wire Fraud violations between and among the above-mentioned Defendants, in relation to correspondence between Kritzer and BLMIS on August 29, 1995

4. December 21, 1995 Facsimile from Kohn to BLMIS: Predicate Acts 12468-12480

a. Illegal Scheme

b. Kohn, Eurovaleur, Reuss, Randa, Zapotocky, Kretschmer, Kadrnoska, Hemetsberger, Nograsek, Fischer, Scheithauer, Duregger, and Bank Austria

c. Thirteen (13) Wire Fraud violations between and among the above-mentioned Defendants, in relation to correspondence between Kohn and BLMIS on December 21, 1995

5. Transfer from BLMIS to Bank Austria: Predicate Acts 12481-12487

a. Illegal Scheme

b. Kohn, Bank Austria, Randa, Zapotocky, Kretschmer, Kadrnoska, and Eurovaleur

c. Seven (7) Wire Fraud violations between and among the above- mentioned Defendants, in relation to payments from BLMIS to Bank Austria beginning in July 10, 1996

6. December 12, 1997 Facsimile from Flax to BLMIS: Predicate Acts 12488-12490

a. Illegal Scheme

b. Kohn, E. Kohn, and Erko

c. Three (3) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Flax and BLMIS on December 12, 1997

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7. January 12, 1998 Facsimile from Flax to BLMIS: Predicate Acts 12491- 12493

a. Illegal Scheme

b. Kohn, E. Kohn, and Erko

c. Three (3) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Flax and BLMIS on January 12, 1998

8. January 6, 2000 Facsimile from Grasso to BLMIS: Predicate Acts 12494- 12496

a. Illegal Scheme

b. Kohn, Reuss, and Eurovaleur

c. Three (3) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Grasso and BLMIS on January 6, 2000

9. February 20, 2002 Facsimile from Radel-Leszczynski to DiPascali: Predicate Acts 12497-12505

a. Illegal Scheme

b. Kohn, Radel-Leszczynski, BA Worldwide, Bank Austria, Duregger, Nograsek, Kretschmer, Hemetsberger, and Bank Medici

c. Nine (9) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Radel-Leszczynski and DiPascali on February 20, 2002

10. Transfers from MSIL to Tecno Italy: Predicate Acts 12506-12685

a. Illegal Scheme

b. Kohn, Tecno Italy, Medici S.r.l., Blau, Florio, I-Tech, RTH, Bank Medici, and Raule

c. One hundred eighty (180) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments from MSIL to Tecno Italy from May 21, 2002 to January 2, 2007

11. September 10, 2004 E-mail from Reuss to BLMIS: Predicate Acts 12686- 12692

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a. Illegal Scheme

b. Kohn, Reuss, Bank Austria, Radel-Leszczynski, Hemetsberger, BA Worldwide, and Eurovaleur

c. Seven (7) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Reuss and BLMIS on September 10, 2004

12. December 16, 2005 E-mail from Reuss to Tiranno: Predicate Acts 12693- 12700

a. Illegal Scheme

b. Kohn, Bank Medici, Reuss, UniCredit, Pioneer, Profumo, Gutty, and Eurovaleur

c. Eight (8) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Reuss and Tiranno on December 16, 2005

13. July 10, 2006 Facsimile from Radel-Leszczynski to BLMIS: Predicate Acts 12701-12704

a. Illegal Scheme

b. Radel-Leszczynski, Zapotocky, Fischer, and BA Worldwide

c. Four (4) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Radel-Leszczynski and BLMIS on July 10, 2006

14. September 25, 2006 Facsimile from Radel-Leszczynski to BLMIS: Predicate Acts 12705-12708

a. Illegal Scheme

b. Radel-Leszczynski, Zapotocky, Fischer, and BA Worldwide

c. Four (4) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Radel-Leszczynski and BLMIS on September 25, 2006

15. March 16, 2007 Facsimile from La Rocca to Radel-Leszczynski: Predicate Acts 12709-12717

a. Illegal Scheme

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b. Pioneer, UniCredit, Profumo, Gutty, Radel-Leszczynski, Bank Austria, BA Worldwide, Bank Medici, and Kohn

c. Nine (9) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Radel-Leszczynski, Bank Medici, BA Worldwide, Kohn, La Rocca, and Pioneer on March 16, 2007

16. April 2, 2007 Facsimile from Cosulich to BLMIS: Predicate Acts 12718- 12728

a. Illegal Scheme

b. Kohn, Cosulich, HAM, de Sury, Mugnai, Bank Medici, Medici S.r.l., UniCredit, Profumo, Gutty, and Sofipo

c. Eleven (11) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Cosulich, and BLMIS on April 2, 2007

17. April 30, 2007 Facsimile from Pirkner to BLMIS: Predicate Acts 12729- 12736

a. Illegal Scheme

b. Pirkner, Bank Medici, de Sury, Mugnai, Cosulich, Medici S.r.l., Frey, and Kohn

c. Eight (8) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Pirkner, Bank Medici, Kohn, and BLMIS on April 30, 2007

18. June 4, 2007 E-mail from Amselem to Flax: Predicate Acts 12737-12740

a. Illegal Scheme

b. Kohn, Amselem, Bank Medici Gibraltar, and Tecno Gibraltar

c. Four (4) Wire Fraud violations between and among the above- mentioned Defendants, in relation to correspondence between Amselem and Flax on June 4, 2007

19. Transfers from MSIL to Tecno Gibraltar: Predicate Acts 12741-12756

a. Illegal Scheme

b. Kohn, Tecno Gibraltar, Bank Medici Gibraltar, Redcrest, Line Group, Line Management, Line Holdings, and Amselem

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c. Sixteen (16) Wire Fraud violations between and among the above- mentioned Defendants, in relation to payments from MSIL to Tecno Gibraltar from April 24, 2007 to July 5, 2007

20. Transfers from BLMIS to Tecno Gibraltar: Predicate Acts 12757-12788

a. Illegal Scheme

b. Kohn, Tecno Gibraltar, Bank Medici Gibraltar, Redcrest, Line Group, Line Management, Line Holdings, and Amselem

c. Thirty two (32) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Tecno Gibraltar from January 10, 2008 to August 8, 2008

21. Transfer from Tecno Italy to E. Kohn: Predicate Acts 12789-12798

a. Illegal Scheme

b. Kohn, Blau, Raule, Florio, I-Tech, RTH, Tecno Italy, Medici S.r.l., Bank Medici, and E. Kohn

c. Ten (10) Wire Fraud violations between and among the above- mentioned Defendants, in relation to the transfer from Tecno Gibraltar to E. Kohn on February 2, 2009

22. Transfers from HAM to Bank Medici and Medici Cayman: Predicate Acts 12799-14298

a. Illegal Scheme

b. Kohn, HAM, Bank Austria, Bank Medici, Medici S.r.l., Bank Medici Gibraltar, Medici Cayman, Herald Consult, Line Holdings, Gutty, Kastner, E. Kohn, RTH, Raule, Scheithauer, Frey, Tripolt, Schindler, Duregger, Pirkner, Mugnai, de Sury, and Cosulich

c. One thousand five hundred (1500) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments from HAM to Bank Medici and Medici Cayman from February 6, 2006 to November 20, 2008

23. Transfers from HAM to APM Cayman: Predicate Acts 14299-14946

a. Illegal Scheme

b. Kohn, HAM, Bank Medici, APM Cayman, MediciFinanz, Herald Consult, Line Holdings, Kastner, Mugnai, de Sury, RTH, Raule, Medici S.r.l., and Cosulich

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c. Six hundred and forty eight (648) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments from HAM to APM Cayman from February 10, 2006 to October 22, 2008

24. Transfers from HAM to Bank Austria Cayman: Predicate Acts 14947- 15036

a. Illegal Scheme

b. Kohn, HAM, Bank Austria, Bank Austria Cayman, Medici S.r.l., Raule, E. Kohn, Herald Consult, Line Holdings, Line Management, Line Group, Redcrest, Mugnai, de Sury, Cosulich, and Duregger

c. Ninety (90) Wire Fraud violations between and among the above- mentioned Defendants, in relation to payments from HAM to Bank Austria Cayman from November 22, 2006 to January 23, 2008

25. Transfer from Pioneer to Bank Medici: Predicate Acts 15037-15049

a. Illegal Scheme

b. Kohn, Bank Austria, Scheithauer, Frey, Tripolt, Schindler, Pirkner, Duregger, Radel-Leszczynski, Bank Medici, Pioneer, UniCredit, Profumo, and Gutty

c. Thirteen (13) Wire Fraud violations between and among the above-mentioned Defendants, in relation to the transfer from Pioneer to Bank Medici in 2007

26. Transfers from HAM to Pioneer: Predicate Acts 15050-15144

a. Illegal Scheme

b. Kohn, HAM, Pioneer, Bank Medici, RTH, Raule, E. Kohn, Medici S.r.l., UniCredit, Herald Consult, Line Holdings, Line Management, Line Group, Redcrest, Profumo, Gutty, Mugnai, de Sury, and Cosulich

c. Ninety five (95) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments from HAM to Pioneer from July 21, 2008 to November 12, 2008

27. Transfers from HAM to Sofipo: Predicate Acts: 15145-15252

a. Illegal Scheme

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b. Kohn, HAM, Sofipo, E. Kohn, RTH, Raule, Herald Consult, Line Holdings, Line Management, Line Group, Redcrest, Mugnai, de Sury, and Cosulich

c. One hundred eight (108) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments from HAM to Sofipo from November 16, 2007 to October 22, 2008

28. Transfers from HAM to Kastner, Mugnai, de Sury, and Cosulich: Predicate Acts 15253-15588

a. Illegal Scheme

b. Kohn, HAM, Herald Consult, Line Group, Line Management, Line Holdings, Redcrest, E. Kohn, Bank Medici, Medici S.r.l., RTH, Raule, Mugnai, de Sury, and Cosulich

c. Three hundred thirty six (336) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments from HAM to Mugnai, de Sury, and Cosulich from June 1, 2006 to December 17, 2008

29. Transfers from HAM to Revi: Predicate Acts 15589-15633

a. Illegal Scheme

b. Kohn, HAM, Bank Medici, Medici S.r.l., Herald Consult, Redcrest, Line Group, Line Management, Line Holdings, E. Kohn, RTH, Raule, Mugnai, de Sury, and Cosulich

c. Forty five (45) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments from HAM to Revi from January 9, 2008 to March 27, 2008

30. Transfers from HAM to Hassans: Predicate Acts 15634-15663

a. Illegal Scheme

b. Kohn, HAM, Bank Medici, Medici S.r.l., Herald Consult, Redcrest, Line Group, Line Management, Line Holdings, E. Kohn, RTH, Raule, Mugnai, de Sury, and Cosulich

c. Thirty (30) Wire Fraud violations between and among the above- mentioned Defendants, in relation to payments from HAM to Hassans on December 15, 2008

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31. Transfers Between and Among the Liechtenstein Sham Entities: Predicate Acts 15664-15766

a. Illegal Scheme

b. Kohn, Gutty, PrivatLife, Starvest, and LifeTrust

c. One hundred three (103) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments between and among the Liechtenstein Sham Entities from January 24, 2008 to January 25, 2008

32. Transfers from Eurovaleur to Kohn and her co-Defendants: Predicate Acts 15767-15941

a. Illegal Scheme

b. Kohn, Eurovaleur, Reuss, Infovaleur, Blau, E. Kohn, Tecno Gibraltar, Tonga, Amselem, Line Group, Line Holdings, Line Management, Redcrest, and Bank Medici Gibraltar

c. One hundred seventy five (175) Wire Fraud violations between and among the above-mentioned Defendants, in relation to payments between and among the Liechtenstein Sham Entities from July 24, 2001 to March 3, 2009

33. Phone call from Kohn to Shpe: Predicate Acts 15942-15944

a. Illegal Scheme

b. Kohn, Scheithauer, and Bank Medici

c. Three (3) Wire fraud violations between and among the above- named Defendants in relation to the telephone call made on December 23, 2008 from Kohn to a Herald (Lux) investor wherein Kohn falsely denies knowledge that Herald Fund and Herald (Lux) are invested in BLMIS

Mail Fraud in violation of 18 U.S.C. § 1341:

1. Registration of “Primeo” trademark in New York by Eurovaleur: Predicate Acts 15945-15948

a. Illegal Scheme

b. Kohn, Eurovaleur, Reuss, Bank Austria, and Randa

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c. Four (4) Mail Fraud violations by the above-named Defendants caused by Eurovaleur using the U.S. Mail to send the “Primeo” trademark application to the United States Patent and Trademark Office (“USPTO”) on August 12, 1993

2. Assignment of the “Primeo” trademark in New York from Eurovaleur to Bank Austria: Predicate Acts 15949-15955

a. Illegal Scheme

b. Kohn, Eurovaleur, Reuss, Bank Austria, Nograsek, Duregger, and Randa

c. Seven (7) Mail Fraud violation by the above-named Defendants caused by Duregger and Nograsek sending a letter using the U.S. Mail to the USPTO on December 17, 2001 regarding the assignment of the “Primeo” trademark from Eurovaleur to Bank Austria

3. Invoices mailed from Infovaleur to BLMIS: Predicate Acts 15956-16084

a. Illegal Scheme

b. Kohn, Infovaleur, and Reuss

c. One hundred twenty nine (129) Mail Fraud violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Infovaleur from July 15, 1998 to August 4, 2008

Interstate and Foreign Travel in violation of 18 U.S.C. § 1952:

1. Travels by Kohn and E. Kohn from New York to MSIL’s offices in London, England: Predicate Acts 16085-16168

a. Illegal Scheme

b. Kohn, E. Kohn, and Erko

c. Eighty four (84) violations of the Travel Act. Kohn and E. Kohn traveled from New York to London, England to collect illegal kickbacks of stolen Customer Property from Madoff approximately four times a year from 1987 until 1993

2. Travels by Kohn, Zapotocky, Radel-Leszczynski, Hemetsberger, and Kretschmer from Vienna, Austria to BLMIS headquarters in New York: Predicate Acts 16169-16522

a. Illegal Scheme

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b. Kohn, Bank Medici, Bank Austria, BA Worldwide, Zapotocky, Radel-Leszczynski, Hemetsberger, and Kretschmer

c. Three hundred fifty four (354) violations of the Travel Act. Kohn, Zapotocky, Radel-Leszczynski, Hemetsberger, and Kretschmer traveled to New York to visit Madoff at BLMIS. Each of these Defendants visited Madoff in New York approximately 2-3 times a year, starting in 1994 and lasting until Madoff confessed in 2008

3. Travels by Kohn and Kastner from Europe to BLMIS headquarters in New York: Predicate Acts 16523-16528

a. Illegal Scheme

b. Kohn, Bank Medici, and Kastner

c. Six (6) travels by Kohn and Kastner to visit Madoff at BLMIS in New York

Transporting Funds Taken by Fraud in violation of 18 U.S.C. § 2314:

1. Transfers from Infovaleur to Kohn Family Defendants: Predicate Acts 16529-16544

a. Illegal Scheme

b. Infovaleur, Kohn, Reuss, and Eurovaleur

c. Sixteen (16) Transporting Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Kohn Family Defendants from June 24, 2002 to January 6, 2009

2. Transfers from Infovaleur to other Medici Enterprise Defendants: Predicate Acts 16545-17080

a. Illegal Scheme

b. Infovaleur, Kohn, Reuss, and Eurovaleur

c. Four hundred thirty six (536) Transporting Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Medici Enterprise Defendants from May 7, 2002 to November 10, 2008

3. Transfers from BA Worldwide to Eurovaleur: Predicate Acts 17081- 17948

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a. Illegal Scheme

b. Bank Austria, BA Worldwide, Hemetsberger, Nograsek, Kretschmer, Duregger, and Radel-Leszczynski

c. Eight hundred sixty eight (868) Transporting Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from BA Worldwide to Eurovaleur from January 1, 1997 to April 1, 2007

4. Transfers from Eurovaleur to Kohn and certain co-Defendants: Predicate Acts 17949-18036

a. Illegal Scheme

b. Kohn, Eurovaleur, Infovaleur, Reuss, Blau, E. Kohn, and Tonga

c. Eight eight (88) Transporting Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from BA Worldwide to Eurovaleur from July 24, 2001 to March 3, 2009

Transportation of Persons to Defraud in violation of 18 U.S.C. § 2314:

1. Travels by Zapotocky, Radel-Leszczynski, Hemetsberger, and Kretschmer from Vienna, Austria to BLMIS headquarters in New York: Predicate Acts 18037-18471

a. Illegal Scheme

b. Kohn, Bank Medici, Bank Austria, Randa, and Eurovaleur

c. Four hundred thirty five (435) violations of the Transportation of Persons to Defraud statute. Zapotocky, Radel-Leszczynski, Hemetsberger, and Kretschmer traveled to New York to visit Madoff at BLMIS. Each of these Defendants visited Madoff in New York approximately 2-3 times a year, starting in 1994 and lasting until Madoff confessed in 2008. Kohn, Bank Medici, Bank Austria, Randa, and Eurovaleur caused or induced each of these travels

2. Travel by Kastner from Europe to BLMIS headquarters in New York: Predicate Acts 18472-18474

a. Illegal Scheme

b. Kohn, Bank Medici, and Eurovaleur

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c. Three (3) violations of the Transportation of Persons to Defraud statute. Kastner visited Madoff at BLMIS in New York. Kohn, Bank Medici, and Eurovaleur caused or induced Kastner’s visit

Receiving Funds Taken by Fraud in violation of 18 U.S.C. § 2315:

1. Transfers from Infovaleur to Kohn Family Defendants: Predicate Acts 18475-18479

a. Illegal Scheme

b. Herzog, R. Kohn, Landau, and Y. Landau

c. Five (5) Receiving Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Kohn Family Defendants from June 24, 2002 to January 6, 2009

2. Transfers from Infovaleur to other Medici Enterprise Defendants: Predicate Acts 18480-18748

a. Illegal Scheme

b. Kohn, Marketinc, Eastview, New Economy, E. Kohn, Infotech, RTH, de Sury, ITR, Fintechnology, EcoInfo, Systor, Cosulich, Pirkner, Frey, Giefing, Tecno Italy, Blau, Raule, Florio, I-Tech, Medici S.r.l., Bank Medici, M-Tech, Landau, Pirkner, APM Cayman, Kastner, MediciFinanz, Scheithauer, and Tripolt

c. Two hundred sixty nine (269) Receiving Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from Infovaleur to Medici Enterprise Defendants from May 7, 2002 to March 9, 2009

3. Transfers from MSIL to Erko: Predicate Acts 18749-18868

a. Illegal Scheme

b. Kohn, E. Kohn, and Erko

c. One hundred twenty (120) Receiving Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from MSIL to Erko from December 31, 1992 to December 18, 2001

4. Transfers from BLMIS to Tecno Gibraltar: Predicate Acts 18869-18900

a. Illegal Scheme

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b. Kohn, Tecno Gibraltar, Bank Medici Gibraltar, Amselem, Redcrest, Line Group, Line Management, and Line Holdings

c. Thirty two (32) Receiving Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Tecno Gibraltar from January 10, 2008 to August 8, 2008

5. Transfers from BA Worldwide to Eurovaleur: Predicate Acts 18901- 19272

a. Illegal Scheme

b. Kohn, Reuss, and Eurovaleur

c. Three hundred seventy two (372) Receiving Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from BA Worldwide to Eurovaleur from January 1, 1997 to April 1, 2007

6. Transfers from Eurovaleur to Kohn and certain co-Defendants: Predicate Acts 19273-19303

a. Illegal Scheme

b. Kohn, Eurovaleur, Infovaleur, Reuss, Blau, E. Kohn, and Tonga

c. Thirty-one (31) Receiving Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from BA Worldwide to Eurovaleur from July 24, 2001 to March 3, 2009

7. Transfers from FundsWorld to Eurovaleur: Predicate Acts 19304-19309

a. Illegal Scheme

b. Kohn, Reuss, and Eurovaleur

c. Six (6) Receiving Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from FundsWorld to Eurovaleur from December 31, 2000 to December 31, 2002

8. Transfers from BLMIS to Bank Austria: Predicate Acts 19310-19316

a. Illegal Scheme

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b. Kohn, Bank Austria, Randa, Zapotocky, Kretschmer, Kadrnoska, and Eurovaleur

c. Seven (7) Receiving Funds Taken by Fraud violations between and among the above-mentioned Defendants, in relation to payments from BLMIS to Bank Austria on July 10, 1996

(2) State the dates of the participants’ involvement in the predicate acts and the facts surrounding the predicate acts

Kohn’s New York Activity in Furtherance of the Illegal Scheme

Kohn and Madoff in New York:

Kohn began the Medici Enterprise in New York as early as 1985. After being introduced to Madoff in New York by Cohn, Kohn immediately began to build the architecture of the Medici Enterprise.

Kohn Solicits U.S. Investors in New York:

1. Chicago-based investor Howard Gottlieb (“Gottlieb”) is a former business partner of Kohn. Through Kohn and Windsor, Gottlieb opened BLMIS account 1G0067 with Kohn and Windsor’s assistance. On November 14, 1989, Gottlieb, on behalf of Kohn, directed BLMIS via facsimile to send duplicate copies of his account statements to Kohn, in care of Windsor. This correspondence ensured that Kohn and Windsor had visibility with respect to Gottlieb’s account, which allowed her to monitor his purported investment. Gottlieb quickly identified that BLMIS’s stated returns were impossible and closed his direct account on June 24, 1993 after taking $1.4 million in fictitious profits from BLMIS. Gottlieb severed all business relations with Kohn.

The correspondence between Kohn and Gottlieb was transmitted via wire in interstate commerce and in violation of 18 U.S.C. § 1343. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

Kohn Solicits Foreign Investors in New York:

2. Kohn continued to use Windsor and Eurovaleur to solicit investors for the Ponzi scheme, for which Kohn received fees and furthered the Illegal Scheme. In 1992, Kohn, through Windsor, induced wealthy Swiss investor Mario Benbassat to open BLMIS account 1FN021 in the name of Lagoon Investments Ltd. On April 23, 1992, Kohn sent a facsimile, on Windsor letterhead, to Mario Benbassat confirming the opening of his BLMIS account. This solicitation of the Benbassat family was Kohn’s

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first of many successful efforts to persuade large investors to invest in BLMIS. Kohn’s relationship with the Benbassat family continued for the duration of the Illegal Scheme.

In 1996, Eurovaleur received a 10% ownership interest in TAM as a “thank you” from the Benbassats for introducing them to Madoff. Also beginning in 1996, her relationship with the Benbassats led to Bank Medici receiving fees for distributing and marketing Thema International. This arrangement furthered the Medici Enterprise and lasted until Madoff confessed to running a Ponzi scheme. In 2006, Bank Medici became the investment manager for Thema International and received fees for this purported service in furtherance of the Illegal Scheme.

The April 23, 1992 correspondence was transmitted via wire in foreign commerce and in violation of 18 U.S.C. § 1343. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

Kohn Registers the “Primeo” Trademark in New York:

3. Primeo Fund was the Medici Enterprise’s first large investment vehicle into BLMIS. Its creation and distribution was instrumental in furthering the Illegal Scheme and enriching the Medici Enterprise. Kohn, through Eurovaleur, conspired with Bank Austria, Randa, Zapotocky, Scheithauer, Nograsek, and Duregger to create Primeo Fund.

On August 12, 1993, Kohn, through Eurovaleur, sent, via the U.S. Mail, a trademark application to the USPTO to register the “Primeo” trademark. On November 1, 1994, the USPTO granted Eurovaleur’s trademark application. The trademark remained registered to Eurovaleur until 2001, when Eurovaleur assigned the “Primeo” trademark to Bank Austria. On December 17, 2001, Nograsek and Duregger, on behalf of Bank Austria sent, via the U.S. Mail, a letter to the USPTO appointing Bank Austria’s New York attorney as its domestic representative as part of the assignment process of the “Primeo” trademark. Bank Austria still owns the “Primeo” trademark. These mails were necessary to ensure the continuity of Primeo Fund to further the Illegal Scheme.

The November 1, 1994 and December 17, 2001 correspondences constitute violations of the Mail Fraud statute under 18 U.S.C. § 1341. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

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Kohn Facilitates Bank Austria’s Direct BLMIS Account:

4. On August 29, 1995, Kritzer, on behalf of Kohn, sent a facsimile from New York to BLMIS naming Bank Austria executive Kretschmer as the contact regarding Bank Austria’s direct BLMIS account number 1FN082. This facsimile was sent on Eurovaleur letterhead. On information and belief, Kohn and Eurovaleur received fees for introducing Bank Austria to Madoff and BLMIS. Bank Austria’s AMF, recovered from BLMIS, contains Bank Austria’s Senior General Manager Zapotocky’s business card. This card has a handwritten notation containing Kohn’s name and phone number.

Bank Austria closed its direct account with BLMIS in 1996 as it began to distribute Primeo Fund on a large scale. Bank Austria, through its membership in the Medici Enterprise and participation in the Illegal Scheme, continued to profit from the Ponzi scheme without the exposure of a direct account with BLMIS. Randa, Kadrnoska, Zapotocky, Kretschmer, Fischer, and Nograsek directed and oversaw the creation, and later the closing, of Bank Austria’s direct BLMIS account.

The August 29, 1995 correspondence was transmitted via wire in interstate commerce and in violation of 18 U.S.C. § 1343. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

Bank Austria’s Direct BLMIS Account Received Fictitious Profits:

5. Bank Austria’s account received fictitious profits from BLMIS in the amount of $249,627.82. Bank Austria received three transfers of stolen Customer Property from BLMIS over the life of its direct account. On July 10, 1996, BLMIS transmitted via wire in foreign commerce $1,743,641 to Bank Austria. On August 8, 1996, BLMIS sent a check via the U.S. Mail in the amount of $1,351 to Bank Austria. Finally, on September 20, 1996, BLMIS sent a check via the U.S. Mail in the amount of $826 to Bank Austria. These checks were processed and received by Bank Austria. This stolen Customer Property was under the custody and control of J.P. Morgan Chase, an FDIC-insured, New York-based financial institution.

These transactions constitute financial institution fraud under 18 U.S.C. § 1344. The August 8, 1996, and September 20, 1996, transactions also constitute mail fraud under 18 U.S.C. § 1341. The July 10, 1996 wire constitutes a violation of 18 U.S.C. § 1343. This transmission also constitutes a monetary transactions in criminally derived property under 18 U.S.C. § 1957. Under § 1957, this transaction exceeds $10,000. To the extent any of these transfers were less than $5,000, they do not

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constitute a receipt of money, across state or international lines, which is known to have been stolen, unlawfully converted, or taken in violation of 18 U.S.C. § 2315. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

Kohn Announces the Expansion of Primeo Fund:

6. On December 21, 1995, Kohn sent a facsimile, on Eurovaleur letterhead, to BLMIS wherein she announces that Primeo Fund would begin issuing Class B shares and would open a new account with BLMIS. This correspondence resulted in Primeo Fund opening direct account 1FN092 with BLMIS. Kohn, Randa, Zapotocky, Kretschmer, Kadrnoska, Fischer, Reuss, and Bank Austria were instrumental to the creation of Primeo Fund and introduced Bank Austria officials to Madoff and other representatives of BLMIS in New York.

On February 20, 2002, Radel-Leszczynski sent a facsimile to DiPascali requesting approval of language describing the investment strategy used to market Primeo Fund to investors. The facsimile was sent from a Bank Medici facsimile machine on BA Worldwide letterhead.

This correspondence was transmitted via wire in interstate commerce and in violation of 18 U.S.C. § 1343. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

Kohn Seeks Additional Mechanisms to Further the Illegal Scheme:

7. On January 6, 2000, Grasso, on behalf of Kohn and Eurovaleur, sent a facsimile on Eurovaleur letterhead to Mark Madoff at BLMIS enclosing Italian articles regarding Kohn’s involvement with Milan-based online sales platform FundsWorld. FundsWorld offered mutual and hedge funds to institutional and wealthy investors. Kohn created and owned FundsWorld. FundsWorld appears to have been created to sell access to the Medici Enterprise Feeder Funds. Kohn, through FundsWorld, paid Eurovaleur €750,000 in December 2000, and €1,149,552 on December 31, 2002.

This correspondence was transmitted via wire in interstate commerce and in violation of 18 U.S.C. § 1343. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

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Members of the Medici Enterprise Travel to New York:

8. At all relevant times, Kohn, Zapotocky, Kretschmer, Hemetsberger, and Radel-Leszczynski traveled regularly to New York to meet with Madoff at BLMIS headquarters in furtherance of the Illegal Scheme. On information and belief, during these visits, Kohn, Zapotocky, Kretschmer, Hemetsberger, and Radel-Leszczynski also traveled to Bank Austria’s New York branch located at 150 E. 42nd Street, New York, New York. Kohn facilitated these travels through Eurovaleur in New York. At all relevant times, Reuss oversaw the day-to-day activities of Eurovaleur. On September 10, 2004, Reuss sent an e-mail, with a Eurovaleur signature, confirming a meeting between Madoff, one of his employees, and Bank Austria representatives Radel-Leszczynski and Hemetsberger. These travels were crucial to the expansion of the Illegal Scheme by facilitating the opening of new BLMIS direct accounts for the Medici Enterprise Feeder Funds.

Each of these travels constitutes a violation of the Travel Act under 18 U.S.C. § 1952. Because Kohn, Bank Medici, Bank Austria, Randa, and Eurovaleur caused or induced each of these travels in interstate or foreign commerce in the execution or concealment of the scheme to defraud, for purposes of obtaining money by means of false pretenses, representations, or promises, they also constitute violations of 18 U.S.C. § 2314.

On July 10, 2006, Radel-Leszczynski sent a facsimile to Madoff regarding a recent meeting they had in New York at BLMIS headquarters. In the correspondence, Radel-Leszczynski profusely and obsequiously thanked Madoff for “granting” her a new BLMIS direct account. The purpose of the facsimile was to confirm that the accountholder would be Senator Fund and to arrange for the opening documents be sent to the account’s custodian. On September 25, 2006, Radel-Leszczynski sent another facsimile to Madoff to notify him that she would serve as his primary contact for Primeo Fund, Alpha Prime Fund, and Senator Fund. Radel- Leszczynski also proposed a future meeting with Madoff on October 23, 2006 purportedly to discuss her role as to these Medici Enterprise Feeder Funds.

These correspondences were transmitted via wire in interstate commerce and in violation of 18 U.S.C. § 1343. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

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UniCredit Formalizes Its Previous Participation in the Illegal Scheme and Role in the Medici Enterprise:

9. In 2005, UniCredit acquired Bank Austria. UniCredit has been involved with Madoff and BLMIS since at least 1999. After UniCredit’s acquisition of Bank Austria, Pioneer replaced BA Worldwide as the investment manager to Primeo Fund. UniCredit sought to obfuscate Primeo Fund’s investment structure by electing to invest in BLMIS indirectly through Herald Fund, Alpha Prime Fund, and Thema International. UniCredit conspired with Kohn, Eurovaleur in New York, and Bank Medici to effect this deception.

On December 16, 2005, Reuss, on Kohn’s behalf, sent an e-mail, with a Eurovaleur signature, to Tiranno, a Pioneer employee. Reuss references an earlier meeting in New York regarding Pioneer’s interest in investing Primeo Fund’s shares in BLMIS indirectly through Herald Fund. As a follow-up to that New York meeting, Reuss provided Tiranno with information regarding the Herald Fund.

By April 2007, UniCredit, through Pioneer, executed its plan to invest Primeo Fund’s shares indirectly with BLMIS through Herald Fund, Alpha Prime Fund, and Thema International. On March 16, 2007, Pioneer CEO La Rocca sent a facsimile to Radel-Leszczynski at BA Worldwide, copying Kohn and Bank Medici, confirming that it was UniCredit’s and Pioneer’s understanding that Madoff consented to the transfer of Primeo Fund’s shares into Herald Fund. Later, on April 30, 2007, Pirkner sent a facsimile to BLMIS, on behalf of Kohn and Bank Medici, attaching Herald Fund’s board of directors’ resolution accepting Primeo Fund’s shares and agreeing to invest these shares into BLMIS. The Herald Fund board of directors’ resolution contains Mugnai’s signature as director of Herald Fund.

These correspondences furthered the Illegal Scheme by facilitating the conspiracy among UniCredit, Bank Austria, Kohn, and Bank Medici to disguise UniCredit and Pioneer’s continued 100% investment in BLMIS.

These correspondences constitute wire fraud under 18 U.S.C. § 1343. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

Payments from BLMIS to Infovaleur:

10. Starting in at least 1998, Kohn, through Kohn’s New York Sham Entity, Infovaleur, received transfers of stolen Customer Property from Madoff and BLMIS in furtherance of the Illegal Scheme. On the dates and

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amounts set forth below, Infovaleur effected these corrupt kickbacks from Madoff to Kohn and Infovaleur.

These transfers were authorized and executed by Madoff. Kohn and Infovaleur invoiced BLMIS via the U.S. Mail and the funds were transmitted via check. Reuss, on behalf of Kohn and Infovaleur, mailed the invoices to BLMIS. On information and belief, Reuss sent these invoices through the U.S. Mail in furtherance of the Illegal Scheme and in violation of 18 U.S.C. § 1341. The funds transmitted to Kohn and Infovaleur are stolen Customer Property.

These transactions constitute the laundering of monetary instruments, monetary transactions in criminally derived property, mail fraud, and Financial Institution Fraud in violation of 18 U.S.C. §§ 1956, 1957, 1341, and 1344. These checks were processed and received by Kohn and Infovaleur, and this stolen Customer Property was under the custody and control of J.P. Morgan Chase, an FDIC-insured, New York-based financial institution.

The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. Under 18 U.S.C. § 1957, all transactions exceed $10,000. The transfers set forth below reflect the dates and amounts of the invoices that Infovaleur sent to BLMIS in New York. This list contains the invoices in the Trustee’s possession and, on information and belief, is not exhaustive.

Date Amount From To July 15, 1998 $221,000.00 BLMIS Infovaleur November 11, 1998 $398,000.00 BLMIS Infovaleur February 2, 1999 $492,500.00 BLMIS Infovaleur April 20, 1999 $548,500.00 BLMIS Infovaleur August 10, 1999 $401,700.00 BLMIS Infovaleur October 13, 1999 $470,830.00 BLMIS Infovaleur January 6, 2000 $470,830.00 BLMIS Infovaleur April 10, 2000 $450,000.00 BLMIS Infovaleur May 12, 2000 $425,000.00 BLMIS Infovaleur May 22, 2000 $300,000.00 BLMIS Infovaleur July 12, 2000 $750,000.00 BLMIS Infovaleur October 16, 2000 $750,000.00 BLMIS Infovaleur January 16, 2001 $750,000.00 BLMIS Infovaleur May 1, 2001 $750,000.00 BLMIS Infovaleur July 13, 2001 $750,000.00 BLMIS Infovaleur

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October 2, 2001 $481,000.00 BLMIS Infovaleur November 15, 2001 $875,000.00 BLMIS Infovaleur February 14, 2002 $875,000.00 BLMIS Infovaleur April 10, 2002 $875,000.00 BLMIS Infovaleur July 3, 2002 $875,000.00 BLMIS Infovaleur October 9, 2002 $875,000.00 BLMIS Infovaleur January 17, 2003 $875,000.00 BLMIS Infovaleur April 22, 2003 $875,000.00 BLMIS Infovaleur July 15, 2003 $875,000.00 BLMIS Infovaleur October 20, 2003 $875,000.00 BLMIS Infovaleur February 10, 2004 $875,000.00 BLMIS Infovaleur May 4, 2004 $875,000.00 BLMIS Infovaleur July 26, 2004 $875,000.00 BLMIS Infovaleur November 3, 2004 $875,000.00 BLMIS Infovaleur February 2, 2005 $875,000.00 BLMIS Infovaleur April 5, 2005 $875,000.00 BLMIS Infovaleur July 14, 2005 $875,000.00 BLMIS Infovaleur November 28, 2005 $875,000.00 BLMIS Infovaleur January 3, 2006 $875,000.00 BLMIS Infovaleur April 5, 2006 $875,000.00 BLMIS Infovaleur May 4, 2006 $875,000.00 BLMIS Infovaleur July 25, 2006 $875,000.00 BLMIS Infovaleur November 27, 2006 $875,000.00 BLMIS Infovaleur February 2, 2007 $875,000.00 BLMIS Infovaleur April 24, 2007 $875,000.00 BLMIS Infovaleur September 5, 2007 $875,000.00 BLMIS Infovaleur October 16, 2007 $875,000.00 BLMIS Infovaleur May 6, 2008 $875,000.00 BLMIS Infovaleur May 19, 2008 $875,000.00 BLMIS Infovaleur August 4, 2008 $875,000.00 BLMIS Infovaleur October 2, 2008 $875,000.00 BLMIS Infovaleur TOTAL $34,659,360.00 MADOFF INFOVALEUR

Payments from Sham Entity Defendants to Kohn Family Defendants:

11. Starting in 2002, Kohn, through her New York Sham Entity and alter ego Infovaleur transferred stolen Customer Property to herself, E. Kohn, M. Hartstein, R. Hartstein, Landau, Y. Landau, M. Kohn, Herzog, and R. Kohn. On the dates set forth below in the amounts set forth below, Infovaleur effected these illegal payments to the above-named Defendants.

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Each of these payments was transmitted to Kohn, E. Kohn, M. Hartstein, R. Hartstein, Landau, Y. Landau, M. Kohn, Herzog, and R. Kohn via check.

On information and belief, Kohn used funds from Infovaleur to finance the sale of Kohn’s New York residence to M. Hartstein and R. Hartstein.

This dissipation of stolen Customer Property continued even after Madoff’s confession. On January 6, 2009, Kohn, through her New York Sham Entity and alter ego Infovaleur, transferred a total of $231,313 to: M. Hartstein, M. Kohn, R. Kohn, R. Hartstein, and Y. Landau via five separate checks in foreign commerce. Additionally, on March 5, 2009, Kohn, through Infovaleur, transferred $4,000 via wire in foreign commerce to M. Hartstein.

The Infovaleur transfers constitute laundering of monetary instruments, monetary transactions in criminally derived property, transporting funds taken by fraud, receiving funds taken by fraud, financial institution fraud, transportation of stolen funds, and receipt of stolen funds in violation of 18 U.S.C. §§ 1956, 1957, 1344, 2314, and 2315, respectively, in furtherance of the Illegal Scheme. These checks were processed and received by the above-named Defendants, and this stolen Customer Property was under the custody and control of J.P. Morgan Chase, an FDIC-insured, New York-based financial institution and banker to Infovaleur and BLMIS.

The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. To the extent any of these payments are less than $10,000, they are not monetary transactions in criminally derived property under 18 U.S.C. § 1957, but still constitute the other predicate acts alleged herein. The transfers that follow constitute the transfer of money in interstate or foreign commerce, known to have been stolen, converted, or taken by fraud, in violation of 18 U.S.C. § 2314. All transfers have a value of $5000 or more. The transfers that follow constitute the receipt of money, across state or international lines, which is known to have been stolen, unlawfully converted, or taken in violation of 18 U.S.C. § 2315. All transfers have a value of $5000 or more. This list reflects records of checks drawn on Infovaleur’s New York bank account at J.P. Morgan Chase and, on information and belief, is not exhaustive.

Date Amount From To March 27, 2002 $3,026.20 Infovaleur E. Kohn March 27, 2002 $3,026.20 Infovaleur E. Kohn

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March 27, 2002 $3,026.20 Infovaleur E. Kohn April 17, 2002 $3,026.20 Infovaleur E. Kohn April 17, 2002 $3,026.20 Infovaleur E. Kohn April 25, 2002 $3,026.20 Infovaleur E. Kohn June 7, 2002 $3,026.20 Infovaleur E. Kohn June 7, 2002 $3,026.20 Infovaleur E. Kohn June 17, 2002 $3,026.20 Infovaleur E. Kohn June 24, 2002 $90,000.00 Infovaleur Herzog (through Austrasia) June 25, 2002 $3,026.20 Infovaleur E. Kohn July 30, 2002 $3,026.20 Infovaleur E. Kohn July 30, 2002 $3,026.20 Infovaleur E. Kohn September 12, 2002 $3,032.40 Infovaleur E. Kohn September 12, 2002 $3,026.20 Infovaleur E. Kohn September 12, 2002 $3,026.20 Infovaleur E. Kohn September 12, 2002 $3,026.20 Infovaleur E. Kohn October 30, 2002 $3,336.20 Infovaleur E. Kohn October 30, 2002 $3,336.20 Infovaleur E. Kohn October 30, 2002 $3,336.20 Infovaleur E. Kohn December 9, 2002 $3,336.20 Infovaleur E. Kohn December 30, 2002 $3,336.20 Infovaleur E. Kohn January 6, 2003 $43,367.50 Infovaleur E. Kohn January 15, 2003 $3,336.20 Infovaleur E. Kohn February 19, 2003 $102,500.00 Infovaleur M. Hartstein March 11, 2003 $3,336.20 Infovaleur E. Kohn M. Hartstein (through Marina March 24, 2003 $50,000.00 Infovaleur Ventures) M. Hartstein (through Marina August 29, 2003 $10,500.00 Infovaleur Ventures) September 11, 2003 $2,500.00 Infovaleur M. Hartstein January 20, 2004 $916.98 Infovaleur R. Hartstein February 17, 2004 $400,000.00 Infovaleur M. Kohn March 18, 2004 $2,197.03 Infovaleur M. Kohn June 30, 2004 $916.99 Infovaleur R. Hartstein August 26, 2004 $2,703.93 Infovaleur R. Kohn August 26, 2004 $1,947.87 Infovaleur M. Hartstein October 13, 2004 $425.00 Infovaleur M. Hartstein November 10, 2004 $1,519.00 Infovaleur M. Hartstein December 21, 2004 $4,000.00 Infovaleur M. Hartstein March 8, 2005 $3,985.00 Infovaleur M. Hartstein

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March 21, 2005 $9,000.00 Infovaleur M. Hartstein July 21, 2005 $4,000.00 Infovaleur Landau September 30, 2005 $2,925.00 Infovaleur M. Hartstein November 16, 2005 $1,000.00 Infovaleur Landau January 10, 2006 $4,269.00 Infovaleur M. Hartstein November 6, 2006 $5,000.00 Infovaleur Landau December 20, 2006 $400,000.00 Infovaleur Kohn December 25, 2006 $400,000.00 Infovaleur Kohn March 28, 2007 $7,000.00 Infovaleur M. Hartstein October 23, 2007 $5,000.00 Infovaleur Landau October 31, 2008 $105,000.00 Infovaleur M. Hartstein January 6, 2009 $70,587.18 Infovaleur M. Hartstein January 6, 2009 $60,294.35 Infovaleur M. Kohn January 6, 2009 $57,334.03 Infovaleur R. Kohn January 6, 2009 $26,438.33 Infovaleur R. Hartstein January 6, 2009 $16,659.16 Infovaleur Y. Landau March 5, 2009 $4,000.00 Infovaleur M. Hartstein TOTAL $1,967,765.15 INFOVALEUR KOHN FAMILY

In addition, Kohn, through Infovaleur, transferred stolen Customer Property to APM Cayman, Bank Austria, Cosulich, de Sury, Duregger, Eastview, EcoInfo, Fintechnology, Frey, Giefing, Infotech, ITR, Lantzitsky, Marketinc, M-Tech, New Economy, Pirkner, Reuss, RTH, Sharei, Systor, Scheithauer, Tecno Italy, and Tripolt. On the dates and in the amounts set forth below, Infovaleur effected these illegal payments to the above-named Defendants.

On information and belief, these payments were made at the direction of Kohn to benefit Kohn, M. Hartstein, Landau, Kastner, APM Cayman, Bank Austria, Cosulich, de Sury, Duregger, Eastview, EcoInfo, Fintechnology, Frey, Giefing, Infotech, ITR, Lantzitsky, Marketinc, M- Tech, New Economy, Pirkner, Reuss, RTH, Sharei, Systor, and Tripolt. Each of these payments where transmitted via check. At all relevant times, Landau was a principal of M-Tech, and Kastner was a principal of APM Cayman.

These payments of stolen Customer Property constitute laundering of monetary instruments, monetary transactions in criminally derived property, financial institution fraud, transportation of stolen funds, and receipt of stolen funds in violation of 18 U.S.C. §§ 1956, 1957, 1344, 2314, and 2315. These checks were processed and received by the above- named Defendants, and this stolen Customer Property was under the custody and control of J.P. Morgan Chase, an FDIC-insured, New York-

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based financial institution. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. To the extent any of these payments are less than $10,000, they are not monetary transactions in criminally derived property under 18 U.S.C. § 1957, but still constitute the other predicate acts alleged herein. To the extent any of these transfers are less than $5,000, they do not constitute the transfer of money in interstate or foreign commerce, known to have been stolen, converted, or taken by fraud, in violation of 18 U.S.C. § 2314. To the extent these transfers are less than $5,000, they do not constitute the receipt of money, across state or international lines, which is known to have been stolen, unlawfully converted, or taken in violation of 18 U.S.C. § 2315. This list reflects records of checks drawn on Infovaleur’s New York bank account at J.P. Morgan Chase and, on information and belief, is not exhaustive.

Date Amount From To May 7, 2002 $180,000.00 Infovaleur Marketinc May 10, 2002 $46,500.00 Infovaleur Eastview May 14, 2002 $58,700.00 Infovaleur Eastview May 17, 2002 $42,000.00 Infovaleur Eastview May 28, 2002 $20,000.00 Infovaleur Sharei June 11, 2002 $47,500.00 Infovaleur Eastview June 17, 2002 $39,800.00 Infovaleur Eastview June 17, 2002 $38,600.00 Infovaleur Eastview June 19, 2002 $2,500.00 Infovaleur de Sury June 24, 2002 $125,000.00 Infovaleur New Economy July 3, 2002 $118,000.00 Infovaleur Marketinc July 3, 2002 $90,000.00 Infovaleur Marketinc July 8, 2002 $32,460.00 Infovaleur Eastview July 9, 2002 $75,000.00 Infovaleur New Economy July 10, 2002 $38,450.00 Infovaleur Eastview July 11, 2002 $28,980.00 Infovaleur Eastview July 30, 2002 $135,000.00 Infovaleur Marketinc August 22, 2002 $150,000.00 Infovaleur Infotech September 17, 2002 $20,000.00 Infovaleur RTH October 1, 2002 $1,500.00 Infovaleur Reuss October 3, 2002 $180,000.00 Infovaleur Marketinc October 3, 2002 $90,000.00 Infovaleur Marketinc October 10, 2002 $2,000.00 Infovaleur Bank Austria October 21, 2002 $95,000.00 Infovaleur ITR October 21, 2002 $78,000.00 Infovaleur Infotech

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October 28, 2002 $120,000.00 Infovaleur ITR October 28, 2002 $90,000.00 Infovaleur Infotech November 12, 2002 $97,000.00 Infovaleur Marketinc December 9, 2002 $126,000.00 Infovaleur ITR December 9, 2002 $90,000.00 Infovaleur ITR December 9, 2002 $72,000.00 Infovaleur Infotech December 31, 2002 $40,000.00 Infovaleur de Sury January 27, 2003 $2,800.00 Infovaleur Duregger February 24, 2003 $15,000.00 Infovaleur Sharei March 14, 2003 $3,000.00 Infovaleur RTH March 31, 2003 $76,900.00 Infovaleur Eastview April 4, 2003 $90,000.00 Infovaleur Fintechnology April 7, 2003 $57,400.00 Infovaleur Eastview April 18, 2003 $180,000.00 Infovaleur Marketinc May 22, 2003 $25,000.00 Infovaleur RTH June 27, 2003 $120,000.00 Infovaleur Marketinc July 14, 2003 $86,000.00 Infovaleur Eastview July 18, 2003 $64,700.00 Infovaleur Eastview August 1, 2003 $95,000.00 Infovaleur New Economy August 12, 2003 $90,000.00 Infovaleur New Economy August 18, 2003 $85,000.00 Infovaleur ITR August 20, 2003 $105,000.00 Infovaleur ITR August 22, 2003 $110,000.00 Infovaleur Infotech August 22, 2003 $80,000.00 Infovaleur Infotech September 12, 2003 $11,000.00 Infovaleur RTH September 22, 2003 $90,000.00 Infovaleur Marketinc November 4, 2003 $150,000.00 Infovaleur ITR November 12, 2003 $150,000.00 Infovaleur Infotech December 1, 2003 $100,000.00 Infovaleur Marketinc December 29, 2003 $90,000.00 Infovaleur EcoInfo January 6, 2004 $150,000.00 Infovaleur EcoInfo June 25, 2004 $5,000.00 Infovaleur de Sury August 2, 2004 $750.00 Infovaleur Lantzitsky August 20, 2004 $270,000.00 Infovaleur Marketinc August 24, 2004 $30,000.00 Infovaleur Sharei August 26, 2004 $180,000.00 Infovaleur Systor August 26, 2004 $160,000.00 Infovaleur Eastview August 30, 2004 $185,000.00 Infovaleur Infotech August 31, 2004 $150,000.00 Infovaleur Systor

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September 2, 2004 $180,000.00 Infovaleur Eastview September 7, 2004 $162,000.00 Infovaleur Infotech September 14, 2004 $198,000.00 Infovaleur Marketinc October 12, 2004 $270,000.00 Infovaleur New Economy October 15, 2004 $750.00 Infovaleur Lantzitsky November 2, 2004 $15,000.00 Infovaleur Cosulich November 18, 2004 $750.00 Infovaleur Lantzitsky November 18, 2004 $750.00 Infovaleur Lantzitsky November 18, 2004 $750.00 Infovaleur Lantzitsky November 26, 2004 $83,460.00 Infovaleur Systor December 15, 2004 $87,600.00 Infovaleur Systor December 17, 2004 $86,650.00 Infovaleur Infotech December 30, 2004 $17,000.00 Infovaleur Cosulich February 25, 2005 $15,500.00 Infovaleur Cosulich April 7, 2005 $14,500.00 Infovaleur Cosulich April 11, 2005 $2,700.00 Infovaleur Duregger April 12, 2005 $3,750.00 Infovaleur Lantzitsky May 13, 2005 $17,250.00 Infovaleur RTH June 14, 2005 $163,600.00 Infovaleur New Economy June 17, 2005 $2,250.00 Infovaleur Lantzitsky June 20, 2005 $86,480.00 Infovaleur Systor June 21, 2005 $76,700.00 Infovaleur Infotech June 21, 2005 $67,780.00 Infovaleur Systor June 21, 2005 $2,700.00 Infovaleur Duregger June 23, 2005 $68,770.00 Infovaleur Infotech July 5, 2005 $2,400.00 Infovaleur Duregger July 26, 2005 $15,000.00 Infovaleur Cosulich August 5, 2005 $92,000.00 Infovaleur Systor August 10, 2005 $125,000.00 Infovaleur Infotech September 19, 2005 $1,000.00 Infovaleur Duregger September 26, 2005 $15,000.00 Infovaleur Cosulich October 17, 2005 $5,000.00 Infovaleur de Sury November 15, 2005 $15,000.00 Infovaleur Cosulich December 23, 2005 $5,000.00 Infovaleur Sharei December 28, 2005 $16,000.00 Infovaleur Cosulich January 3, 2006 $180,000.00 Infovaleur Systor January 3, 2006 $125,000.00 Infovaleur Systor January 5, 2006 $135,000.00 Infovaleur Infotech January 10, 2006 $150,000.00 Infovaleur Infotech

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January 17, 2006 $3,000.00 Infovaleur Lantzitsky April 17, 2006 $10,000.00 Infovaleur Cosulich April 25, 2006 $178,000.00 Infovaleur Systor May 2, 2006 $178,000.00 Infovaleur Infotech May 3, 2006 $150,000.00 Infovaleur Infotech May 31, 2006 $180,000.00 Infovaleur New Economy June 7, 2006 $120,000.00 Infovaleur Infotech June 12, 2006 $90,000.00 Infovaleur Systor June 13, 2006 $35,000.00 Infovaleur Infotech June 29, 2006 $20,000.00 Infovaleur Sharei July 10, 2006 $3,500.00 Infovaleur Duregger July 24, 2006 $10,000.00 Infovaleur Cosulich August 15, 2006 $5,000.00 Infovaleur Pirkner August 30, 2006 $30,000.00 Infovaleur Sharei September 14, 2006 $110,000.00 Infovaleur Systor September 15, 2006 $150,000.00 Infovaleur Infotech September 18, 2006 $180,000.00 Infovaleur Systor September 27, 2006 $198,000.00 Infovaleur Infotech October 11, 2006 $11,000.00 Infovaleur Cosulich October 11, 2006 $2,000.00 Infovaleur Duregger October 18, 2006 $120,000.00 Infovaleur Infotech November 6, 2006 $5,000.00 Infovaleur Frey November 14, 2006 $20,000.00 Infovaleur Sharei November 21, 2006 $22,000.00 Infovaleur Cosulich December 4, 2006 $10,000.00 Infovaleur de Sury January 8, 2007 $2,500.00 Infovaleur Giefing January 16, 2007 $1,800.00 Infovaleur Duregger January 25, 2007 $13,500.00 Infovaleur Cosulich February 14, 2007 $5,000.00 Infovaleur Pirkner February 16, 2007 $5,000.00 Infovaleur Giefing February 23, 2007 $14,500.00 Infovaleur Cosulich March 21, 2007 $300,000.00 Infovaleur APM Cayman March 21, 2007 $105,047.15 Infovaleur APM Cayman May 14, 2007 $5,000.00 Infovaleur Giefing May 16, 2007 $11,000.00 Infovaleur Cosulich May 22, 2007 $5,000.00 Infovaleur Pirkner May 23, 2007 $5,000.00 Infovaleur Frey May 25, 2007 $5,000.00 Infovaleur Duregger June 13, 2007 $10,000.00 Infovaleur Pirkner

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June 28, 2007 $7,000.00 Infovaleur de Sury July 19, 2007 $35,000.00 Infovaleur Cosulich July 25, 2007 $5,000.00 Infovaleur Pirkner September 18, 2007 $6,500.00 Infovaleur Giefing September 25, 2007 $5,000.00 Infovaleur Frey November 21, 2007 $48,000.00 Infovaleur Tecno Italy November 23, 2007 $50,000.00 Infovaleur Cosulich January 22, 2008 $7,000.00 Infovaleur Frey January 23, 2008 $26,000.00 Infovaleur Tecno Italy March 11, 2008 $21,000.00 Infovaleur Cosulich June 24, 2008 $7,500.00 Infovaleur Frey June 30, 2008 $72,000.00 Infovaleur M-Tech July 1, 2008 $40,000.00 Infovaleur Sharei July 8, 2008 $7,000.00 Infovaleur Duregger July 18, 2008 $25,000.00 Infovaleur M-Tech August 6, 2008 $375,000.00 Infovaleur APM Cayman August 8, 2008 $46,000.00 Infovaleur Cosulich August 25, 2008 $15,000.00 Infovaleur Scheithauer August 25, 2008 $10,000.00 Infovaleur Giefing October 1, 2008 $10,000.00 Infovaleur Tripolt November 10, 2008 $5,000.00 Infovaleur Giefing January 13, 2009 $1,603.16 Infovaleur Lantzitsky TOTAL $11,037,080.31 INFOVALEUR KOHN CO-CONSPIRATORS

Payments from Erko to Kohn and Kohn Family

In addition, Kohn, through her New York Sham Entity and alter ego Erko transferred stolen Customer Property to herself and Blau, R. Kohn, E. Kohn, Ra. Kohn, and Herzog. On the dates and in the amounts set forth below, Eurovaleur effected these illegal payments to the above-named Defendants.

On information and belief, these payments were made at the direction of Kohn and transmitted to Kohn, Blau, R. Kohn, E. Kohn, Ra. Kohn, and Herzog via check.

These payments of stolen Customer Property constitute laundering of monetary instruments and monetary transactions in criminally derived property in violation of 18 U.S.C. §§ 1956 and 1957. To the extent any of these payments are less than $10,000, they are not monetary transactions in criminally derived property under 18 U.S.C. § 1957, but still constitute the other predicate acts alleged herein.

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Date Amount From To February 14, 2002 € 12,000.00 Erko Blau February 14, 2002 € 12,000.00 Erko Blau April 2, 2002 € 10,000.00 Erko Kohn April 2, 2002 € 4,200.00 Erko Kohn June 28, 2002 € 5,000.00 Erko Kohn September 11, 2002 $30,080.66 Erko R. Kohn November 6, 2002 € 30,000.00 Erko Kohn March 3, 2003 € 30,000.00 Erko Blau March 26, 2003 € 10,000.00 Erko E. Kohn January 27, 2004 £20,896.07 Erko Blau May 19, 2004 $551,381.98 Erko Ra. Kohn September 27, 2004 £20,550.05 Erko Blau September 21, 2005 £20,417.67 Erko Blau November 15, 2006 € 30,000.00 Erko Blau March 27, 2008 £39,393.52 Erko Blau December 30, 2008 € 1,980,000.00 Erko Blau February 23, 2009 £29,936.87 Erko Blau February 23, 2009 € 469.48 Erko Blau March 3, 2009 £7,895.60 Erko Blau June 24, 2009 £137,538.49 Erko Herzog TOTAL $4,010,428.41 ERKO KOHN FAMILY

Payments from Tecno Italy to E. Kohn

In addition on February 2, 2009, Kohn, through her then-dissolved Italian Sham Entity and alter ego Tecno Italy, transferred $299,994.97 in stolen Customer Property to her husband E. Kohn. This payment was transmitted via wire.

These payments of stolen Customer Property constitute laundering of monetary instruments, monetary transactions in criminally derived property, and financial institution fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. To the extent any of these payments are less than $10,000, they are not monetary transactions in criminally derived property under 18 U.S.C. § 1957, but still constitute the other predicate acts alleged herein.

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Date Amount From To February 2, 2009 $299,994.97 Tecno Italy E. Kohn (Through Tamiza) TECNO TOTAL $299,994.97 KOHN FAMILY ITALY

Payments from Madoff to Erko, Kohn, and E. Kohn:

12. On December 12, 1997 and January 12, 1998, Flax sent a facsimile on MSIL letterhead to BLMIS wherein Flax requested that BLMIS transfer $200,000 and $323,500, respectively, to MSIL to fulfill Madoff’s request to pay Kohn’s New York Sham Entity and alter ego Erko. Kohn and Erko caused this transmission by invoicing Madoff at MSIL. This correspondence resulted in Erko receiving stolen Customer Property in furtherance of the Illegal Scheme. On information and belief, these secret kickbacks began as early as 1987. The transfers set forth below reflect the dates and amounts of the invoices that Erko sent to Madoff at MSIL from New York and elsewhere. The transfers appear to have been transmitted via check and picked up in person at MSIL by either Kohn or E. Kohn.

On information and belief, beginning in 1987, Kohn and E. Kohn traveled to London from New York and elsewhere to pick up these checks in violation of the Travel Act under 18 U.S.C. § 1952 and in furtherance of the Illegal Scheme.

The transfers from Madoff constitute the laundering of monetary instruments and monetary transactions in criminally derived property in violation of 18 U.S.C. §§ 1956 and 1957, respectively, in furtherance of the Illegal Scheme. Under 18 U.S.C. § 1957, all transactions exceed $10,000. The transfers that follow constitute the receipt of money, across state or international lines, which is known to have been stolen, unlawfully converted, or taken in violation of 18 U.S.C. § 2315. All transfers have a value of $5,000 or more.

This list contains the invoices in the Trustee’s possession and, on information and belief, is not exhaustive, as transfers of stolen Customer Property from Madoff to Erko began as early as 1987, five years before the Trustee currently has records in relation to these illegal transfers.

Date Amount From To December 31, 1992 $33,079.17 MSIL Erko January 27, 1993 $28,500.00 MSIL Erko May 21, 1993 $32,500.00 MSIL Erko July 1, 1993 $35,150.00 MSIL Erko November 10, 1993 $46,600.00 MSIL Erko January 31, 1994 $51,650.00 MSIL Erko

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April 28, 1994 $59,700.00 MSIL Erko July 8, 1994 $70,300.00 MSIL Erko October 3, 1994 $71,100.00 MSIL Erko February 27, 1995 $67,775.00 MSIL Erko April 18, 1995 $60,000.00 MSIL Erko July 20, 1995 $63,500.00 MSIL Erko October 24, 1995 $68,700.00 MSIL Erko January 17, 1996 $85,000.00 MSIL Erko April 17, 1996 $106,000.00 MSIL Erko July 11, 1996 $138,700.00 MSIL Erko October 16, 1996 $175,000.00 MSIL Erko January 26, 1997 $232,000.00 MSIL Erko April 11, 1997 $341,900.00 MSIL Erko July 9, 1997 $329,900.00 MSIL Erko October 7, 1997 $430,000.00 MSIL Erko December 29, 1997 $523,500.00 MSIL Erko March 19, 1998 $511,500.00 MSIL Erko June 29, 1998 $375,000.00 MSIL Erko September 28, 1998 $375,000.00 MSIL Erko December 30, 1998 $375,000.00 MSIL Erko March 30, 1999 $375,000.00 MSIL Erko June 30, 1999 $375,000.00 MSIL Erko September 27, 1999 $375,000.00 MSIL Erko December 27, 1999 $375,000.00 MSIL Erko March 24, 2000 $375,000.00 MSIL Erko May 16, 2000 $125,000.00 MSIL Erko June 29, 2000 $500,000.00 MSIL Erko September 26, 2000 $500,000.00 MSIL Erko December 28, 2000 $500,000.00 MSIL Erko March 26, 2001 $500,000.00 MSIL Erko June 26, 2001 $500,000.00 MSIL Erko August 24, 2001 $321,000.00 MSIL Erko September 28, 2001 $775,000.00 MSIL Erko December 18, 2001 $775,000.00 MSIL Erko TOTAL $11,058,054.17 MADOFF ERKO

Payments from Madoff to Tecno Italy and Kohn:

13. Starting in 2002, Kohn’s Italian Sham Entity Tecno Italy received transfers of stolen Customer Property from Madoff in furtherance of the Illegal Scheme. These transfers were authorized and executed by Flax and Raven. Kohn and Tecno Italy invoiced Madoff at MSIL. The transfers were transmitted via wire in foreign commerce.

At all relevant times, Medici S.r.l. and Tecno Italy were located at the

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same address and employed certain of the same individuals. Kohn also received correspondence for HAM and Bank Medici and/or Medici S.r.l. at the same address. Kohn treated Medici S.r.l. and Tecno Italy as indistinguishable entities. Blau was responsible for overseeing the day-to- day activities of Tecno Italy and owned 5% of its shares. In addition to being a key employee of Tecno Italy, Raule was its contact with respect to the transfers from Madoff at MSIL (as executed by Flax and Raven). Raule was also an employee of Medici S.r.l. Raule served as the secretary to Kohn and Mugnai. The funds transmitted to Tecno Italy and Kohn were provided by Madoff, and each payment is stolen Customer Property.

The May 22, 2002 invoice from Tecno Italy to Madoff at MSIL contains handwritten notes regarding Madoff’s payment approval. The June 28, 2002 invoice from Tecno Italy also notes Madoff’s approval and contains the handwritten notation “Erwin Kohn” and his Austrian phone number 0043xxxxxxxxxx. The September 26, 2002 invoice contains the handwritten notation “3rd October 2002. Discussed with Bernie who approved payment today.”

The invoices were sent by wire in foreign commerce and in violation of 18 U.S.C. § 1343. These payments constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively, in furtherance of the Illegal Scheme.

Under 18 U.S.C. § 1957, all transactions exceed $10,000. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. The transfers set forth below reflect the dates and amounts of the invoices that Tecno Italy sent to MSIL. This list contains the invoices in the Trustee’s possession and, on information and belief, is not exhaustive.

Date Amount From To May 21, 2002 $775,000.00 MSIL Tecno Italy June 28, 2002 $775,000.00 MSIL Tecno Italy September 26, 2002 $775,000.00 MSIL Tecno Italy January 10, 2003 $775,000.00 MSIL Tecno Italy April 2, 2003 $775,000.00 MSIL Tecno Italy July 1, 2003 $775,000.00 MSIL Tecno Italy October 1, 2003 $775,000.00 MSIL Tecno Italy February 3, 2004 $775,000.00 MSIL Tecno Italy June 10, 2004 $701,000.00 MSIL Tecno Italy July 8, 2004 $700,000.00 MSIL Tecno Italy October 4, 2004 $700,000.00 MSIL Tecno Italy January 11, 2005 $700,000.00 MSIL Tecno Italy

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April 7, 2005 $700,000.00 MSIL Tecno Italy July 1, 2005 $700,000.00 MSIL Tecno Italy October 3, 2005 $700,000.00 MSIL Tecno Italy January 9, 2006 $700,000.00 MSIL Tecno Italy March 27, 2006 $700,000.00 MSIL Tecno Italy July 3, 2006 $700,000.00 MSIL Tecno Italy October 4, 2006 $700,000.00 MSIL Tecno Italy January 2, 2007 $700,000.00 MSIL Tecno Italy TOTAL $14,601,000.00 MADOFF TECNO ITALY

Payments from Madoff to Kohn and Tecno Gibraltar:

14. Starting in 2007, Kohn’s Gibraltarian Sham Entity, Tecno Gibraltar, received transfers of stolen Customer Property from Madoff in furtherance of the Illegal Scheme. These transfers were authorized by Madoff and executed by Flax and Raven. Kohn and Tecno Gibraltar invoiced Madoff at MSIL. The funds were transmitted via wire in foreign commerce.

At all relevant times, Amselem was responsible for overseeing the day-to- day operations of Tecno Gibraltar. On at least June 4, 2007, Amselem corresponded with Flax at MSIL via e-mail, in relation to confirming the transfers below. The funds transmitted to Kohn and Tecno Gibraltar were provided by Madoff, and each payment is stolen Customer Property.

The April 24, 2007, May 31, 2007, and June 1, 2007, Tecno Gibraltar invoices to Madoff at MSIL were payable to Wachovia Bank NA in New York. On information and belief, Tecno Gibraltar sent each invoice to Madoff at MSIL via facsimile.

The transfers that follow constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively, in furtherance of the Illegal Scheme.

Under 18 U.S.C. § 1957, all transactions exceed $10,000. The transfers set forth below reflect the dates and amounts of the invoices that Tecno Italy sent to Madoff at MSIL. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list contains the invoices in the Trustee’s possession and, on information and belief, is not exhaustive.

Date Amount From To April 24, 2007 $700,000.00 MSIL Tecno Gibraltar July 5, 2007 $700,000.00 MSIL Tecno Gibraltar TOTAL $1,400,000.00 MADOFF KOHN

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Payments from BLMIS to Kohn and Tecno Gibraltar:

15. Starting in 2008, Kohn’s Gibraltarian Sham Entity Tecno Gibraltar received transfers of stolen Customer Property directly from BLMIS in furtherance of the Illegal Scheme. These transfers were authorized and executed by Madoff and BLMIS. On the dates set forth below in the amounts set forth below, Kohn, Amselem, and Tecno Gibraltar caused payments of stolen Customer Property to be made by BLMIS to Kohn and Tecno Gibraltar by invoicing BLMIS. The funds were transmitted via wire in foreign commerce.

Each of Tecno Gibraltar’s invoices to Madoff at BLMIS was payable to account number xxxx xxx xxx xxx (CHIPS xxxxxx) at NatWest Offshore Limited Gibraltar for ultimate credit to Tecno Gibraltar account number xxxx-xxxxxxxx. On information and belief, Tecno Gibraltar sent each invoice to BLMIS in New York via mail or facsimile. Each invoice is marked by hand “TECNOKOHN.” The January 14, 2008 invoice is also marked “BLM Special.”

The invoices were sent either by wire or the U.S. Mail in violation of either 18 U.S.C. §§ 1341 or 1343. The monetary transfers that follow are laundering of monetary instruments, transactions in criminally derived property, wire fraud, financial institution fraud, and receipt of stolen goods in violation of 18 U.S.C. §§ 1956, 1957, 1343, 1344, and 2315 respectively. Under 18 U.S.C. § 1957, all transactions exceed $10,000. The transfers that follow constitute the receipt of money, across state or international lines, which is known to have been stolen, unlawfully converted, or taken in violation of 18 U.S.C. § 2315. All transfers have a value of $5000 or more. These wires were processed and received by Tecno Gibraltar, and this stolen Customer Property was under the custody and control of J.P. Morgan Chase, an FDIC-insured, New York-based financial institution. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. The transfers set forth below reflect the dates and amounts of the invoices that Tecno Italy sent to BLMIS in New York. This list contains the invoices in the Trustee’s possession and, on information and belief, is not exhaustive.

Date Amount From To January 10, 2008 $750,000.00 BLMIS Tecno Gibraltar February 6, 2008 $750,000.00 BLMIS Tecno Gibraltar June 2, 2008 $750,000.00 BLMIS Tecno Gibraltar August 8, 2008 $750,000.00 BLMIS Tecno Gibraltar TOTAL $3,000,000.00 MADOFF KOHN

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Payments from BA Worldwide to Eurovaleur:

16. Since 1996, Radel-Leszczynski was employed by BA Worldwide and was responsible for its day-to-day activities, including the illegal transactions with Kohn’s New York Sham Entity Eurovaleur alleged below. Duregger served as a director for BA Worldwide.

As part of the Medici Enterprise, BA Worldwide was a wholly owned subsidiary of Bank Austria. Bank Austria was responsible for overseeing the purported investment management activities of BA Worldwide. Bank Austria’s director Kretschmer directly supervised Radel-Leszczynski. Kretschmer was also an employee of BA Worldwide. At all relevant times, Eurovaleur had no legitimate business purpose and existed only to further the Illegal Scheme. Starting in at least 1993, and lasting until at least 2005, Eurovaleur received payments from BA Worldwide. These payments were made at the direction of BA Worldwide, Bank Austria, and Radel-Leszczynski and resulted from BA Worldwide’s agreement to pay Eurovaleur 20% of the income received from its various roles as investment manager and investment adviser to Primeo Fund, Alpha Prime Fund, and Thema International Fund. These payments to Eurovaleur were purportedly for sub-advisory services. On information and belief, Eurovaleur received these payments in exchange for Kohn’s introduction of fellow Medici Enterprise members to Madoff and BLMIS.

These payments constitute the laundering of monetary instruments and monetary transactions in criminally derived property, transportation of stolen funds, and receipt of stolen funds in violation of 18 U.S.C. §§ 1956, 1957, 2314, and 2315, respectively, in furtherance of the Illegal Scheme.

The following chart sets forth the dates and dollar amounts for these transactions. To the extent any of these payments are less than $10,000, they are not Monetary Transactions in Criminally Derived Property under 18 U.S.C. § 1957, but still constitute the Laundering of Monetary Instruments. To the extent any of these transfers are less than $5,000, they do not constitute the transfer of money in interstate or foreign commerce, known to have been stolen, converted, or taken by fraud, in violation of 18 U.S.C. § 2314. To the extent these transfers are less than $5,000, they do not constitute the receipt of money, across state or international lines, which is known to have been stolen, unlawfully converted, or taken in violation of 18 U.S.C. § 2315. This list reflects records of the wires drawn on BA Worldwide’s bank account and, on information and belief, is not exhaustive.

Date Amount From To January 1, 1996 $1,796.68 BA Worldwide Eurovaleur February 1, 1996 $1,796.68 BA Worldwide Eurovaleur

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March 1, 1996 $1,796.68 BA Worldwide Eurovaleur April 1, 1996 $1,796.68 BA Worldwide Eurovaleur May 1, 1996 $1,796.68 BA Worldwide Eurovaleur June 1, 1996 $1,796.68 BA Worldwide Eurovaleur July 1, 1996 $1,796.68 BA Worldwide Eurovaleur August 1, 1996 $1,796.68 BA Worldwide Eurovaleur September 1, 1996 $1,796.68 BA Worldwide Eurovaleur October 1, 1996 $1,796.68 BA Worldwide Eurovaleur November 1, 1996 $1,796.68 BA Worldwide Eurovaleur December 1, 1996 $1,796.68 BA Worldwide Eurovaleur January 1, 1997 $9,022.20 BA Worldwide Eurovaleur February 1, 1997 $9,022.20 BA Worldwide Eurovaleur March 1, 1997 $9,022.20 BA Worldwide Eurovaleur April 1, 1997 $9,022.20 BA Worldwide Eurovaleur May 1, 1997 $9,022.20 BA Worldwide Eurovaleur June 1, 1997 $9,022.20 BA Worldwide Eurovaleur July 1, 1997 $9,022.20 BA Worldwide Eurovaleur August 1, 1997 $9,022.20 BA Worldwide Eurovaleur September 1, 1997 $9,022.20 BA Worldwide Eurovaleur October 1, 1997 $9,022.20 BA Worldwide Eurovaleur November 1, 1997 $9,022.20 BA Worldwide Eurovaleur December 1, 1997 $9,022.20 BA Worldwide Eurovaleur January 1, 1998 $26,285.30 BA Worldwide Eurovaleur February 1, 1998 $26,285.30 BA Worldwide Eurovaleur March 1, 1998 $26,285.30 BA Worldwide Eurovaleur April 1, 1998 $26,285.30 BA Worldwide Eurovaleur May 1, 1998 $26,285.30 BA Worldwide Eurovaleur June 1, 1998 $26,285.30 BA Worldwide Eurovaleur July 1, 1998 $26,285.30 BA Worldwide Eurovaleur August 1, 1998 $26,285.30 BA Worldwide Eurovaleur September 1, 1998 $26,285.30 BA Worldwide Eurovaleur October 1, 1998 $26,285.30 BA Worldwide Eurovaleur November 1, 1998 $26,285.30 BA Worldwide Eurovaleur December 1, 1998 $26,285.30 BA Worldwide Eurovaleur January 1, 1999 $45,454.60 BA Worldwide Eurovaleur February 1, 1999 $45,454.60 BA Worldwide Eurovaleur March 1, 1999 $45,454.60 BA Worldwide Eurovaleur April 1, 1999 $45,454.60 BA Worldwide Eurovaleur May 1, 1999 $45,454.60 BA Worldwide Eurovaleur June 1, 1999 $45,454.60 BA Worldwide Eurovaleur July 1, 1999 $45,454.60 BA Worldwide Eurovaleur August 1, 1999 $45,454.60 BA Worldwide Eurovaleur September 1, 1999 $45,454.60 BA Worldwide Eurovaleur October 1, 1999 $45,454.60 BA Worldwide Eurovaleur

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November 1, 1999 $45,454.60 BA Worldwide Eurovaleur December 1, 1999 $45,454.60 BA Worldwide Eurovaleur January 1, 2000 $60,196.79 BA Worldwide Eurovaleur February 1, 2000 $60,196.79 BA Worldwide Eurovaleur March 1, 2000 $60,196.79 BA Worldwide Eurovaleur April 1, 2000 $60,196.79 BA Worldwide Eurovaleur May 1, 2000 $60,196.79 BA Worldwide Eurovaleur June 1, 2000 $60,196.79 BA Worldwide Eurovaleur July 1, 2000 $60,196.79 BA Worldwide Eurovaleur August 1, 2000 $60,196.79 BA Worldwide Eurovaleur September 1, 2000 $60,196.79 BA Worldwide Eurovaleur October 1, 2000 $60,196.79 BA Worldwide Eurovaleur November 1, 2000 $60,196.79 BA Worldwide Eurovaleur December 1, 2000 $60,196.79 BA Worldwide Eurovaleur January 1, 2001 $93,636.59 BA Worldwide Eurovaleur February 1, 2001 $93,636.59 BA Worldwide Eurovaleur March 1, 2001 $93,636.59 BA Worldwide Eurovaleur April 1, 2001 $93,636.59 BA Worldwide Eurovaleur May 1, 2001 $93,636.59 BA Worldwide Eurovaleur June 1, 2001 $93,636.59 BA Worldwide Eurovaleur July 1, 2001 $93,636.59 BA Worldwide Eurovaleur August 1, 2001 $93,636.59 BA Worldwide Eurovaleur September 1, 2001 $93,636.59 BA Worldwide Eurovaleur October 1, 2001 $93,636.59 BA Worldwide Eurovaleur November 1, 2001 $93,636.59 BA Worldwide Eurovaleur December 1, 2001 $93,636.59 BA Worldwide Eurovaleur January 1, 2002 $96,786.03 BA Worldwide Eurovaleur February 1, 2002 $96,786.03 BA Worldwide Eurovaleur March 1, 2002 $96,786.03 BA Worldwide Eurovaleur April 1, 2002 $96,786.03 BA Worldwide Eurovaleur May 1, 2002 $96,786.03 BA Worldwide Eurovaleur June 1, 2002 $96,786.03 BA Worldwide Eurovaleur July 1, 2002 $96,786.03 BA Worldwide Eurovaleur August 1, 2002 $96,786.03 BA Worldwide Eurovaleur September 1, 2002 $96,786.03 BA Worldwide Eurovaleur October 1, 2002 $96,786.03 BA Worldwide Eurovaleur November 1, 2002 $96,786.03 BA Worldwide Eurovaleur December 1, 2002 $96,786.03 BA Worldwide Eurovaleur January 1, 2003 $118,475.88 BA Worldwide Eurovaleur February 1, 2003 $118,475.88 BA Worldwide Eurovaleur March 1, 2003 $118,475.88 BA Worldwide Eurovaleur April 1, 2003 $118,475.88 BA Worldwide Eurovaleur May 1, 2003 $118,475.88 BA Worldwide Eurovaleur June 1, 2003 $118,475.88 BA Worldwide Eurovaleur

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July 1, 2003 $118,475.88 BA Worldwide Eurovaleur August 1, 2003 $118,475.88 BA Worldwide Eurovaleur September 1, 2003 $118,475.88 BA Worldwide Eurovaleur October 1, 2003 $118,475.88 BA Worldwide Eurovaleur November 1, 2003 $118,475.88 BA Worldwide Eurovaleur December 1, 2003 $118,475.88 BA Worldwide Eurovaleur January 1, 2004 $134,922.65 BA Worldwide Eurovaleur February 1, 2004 $134,922.65 BA Worldwide Eurovaleur March 1, 2004 $134,922.65 BA Worldwide Eurovaleur April 1, 2004 $134,922.65 BA Worldwide Eurovaleur May 1, 2004 $134,922.65 BA Worldwide Eurovaleur June 1, 2004 $134,922.65 BA Worldwide Eurovaleur July 1, 2004 $134,922.65 BA Worldwide Eurovaleur August 1, 2004 $134,922.65 BA Worldwide Eurovaleur September 1, 2004 $134,922.65 BA Worldwide Eurovaleur October 1, 2004 $134,922.65 BA Worldwide Eurovaleur November 1, 2004 $134,922.65 BA Worldwide Eurovaleur December 1, 2004 $134,922.65 BA Worldwide Eurovaleur January 1, 2005 $136,724.00 BA Worldwide Eurovaleur February 1, 2005 $136,724.00 BA Worldwide Eurovaleur March 1, 2005 $136,724.00 BA Worldwide Eurovaleur April 1, 2005 $136,724.00 BA Worldwide Eurovaleur May 1, 2005 $136,724.00 BA Worldwide Eurovaleur June 1, 2005 $136,724.00 BA Worldwide Eurovaleur July 1, 2005 $136,724.00 BA Worldwide Eurovaleur August 1, 2005 $136,724.00 BA Worldwide Eurovaleur September 1, 2005 $136,724.00 BA Worldwide Eurovaleur October 1, 2005 $136,724.00 BA Worldwide Eurovaleur November 1, 2005 $136,724.00 BA Worldwide Eurovaleur December 1, 2005 $136,724.00 BA Worldwide Eurovaleur January 1, 2006 $145,276.98 BA Worldwide Eurovaleur February 1, 2006 $145,276.98 BA Worldwide Eurovaleur March 1, 2006 $145,276.98 BA Worldwide Eurovaleur April 1, 2006 $145,276.98 BA Worldwide Eurovaleur May 1, 2006 $145,276.98 BA Worldwide Eurovaleur June 1, 2006 $145,276.98 BA Worldwide Eurovaleur July 1, 2006 $145,276.98 BA Worldwide Eurovaleur August 1, 2006 $145,276.98 BA Worldwide Eurovaleur September 1, 2006 $145,276.98 BA Worldwide Eurovaleur October 1, 2006 $145,276.98 BA Worldwide Eurovaleur November 1, 2006 $145,276.98 BA Worldwide Eurovaleur December 1, 2006 $145,276.98 BA Worldwide Eurovaleur January 1, 2007 $151,859.14 BA Worldwide Eurovaleur February 1, 2007 $151,859.14 BA Worldwide Eurovaleur

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March 1, 2007 $151,859.14 BA Worldwide Eurovaleur April 1, 2007 $151,859.14 BA Worldwide Eurovaleur TOTAL $11,030,368.87 BA WORLDWIDEKOHN

Transfers from Eurovaleur to Kohn, Kohn Family Defendants, and Related Defendants:

17. Starting in 2001, Kohn, through her New York Sham Entity and alter ego Eurovaleur, transferred stolen Customer Property to herself, E. Kohn, Blau, Tonga, and Tecno Gibraltar. On the dates and in the amounts set forth below, Eurovaleur effected these illegal payments to the above- named Defendants.

On information and belief, these payments were made at the direction of Kohn, to benefit herself, E. Kohn, Blau, Tonga, and Tecno Gibraltar. Each of these payments where transmitted via wire.

This dissipation of stolen Customer Property continued even after Madoff’s Confession. In 2009, Eurovaleur, made four additional transfers in the amounts of €295,587.42, $428,315.96, $817.38, and $5,996.00.

These payments constitute the laundering of monetary instruments and monetary transactions in criminally derived property, wire fraud, transportation of stolen funds, and receipt of stolen funds in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively, in furtherance of the Illegal Scheme.

The following chart sets forth the dates and dollar amounts for these transactions. To the extent any of these payments are less than $10,000, they are not Monetary Transactions in Criminally Derived Property under 18 U.S.C. § 1957, but still constitute the Laundering of Monetary Instruments. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

Date Amount From To July 24, 2001 $89,993.01 Eurovaleur Tonga July 25, 2001 $119,993.06 Eurovaleur Tonga July 26, 2001 $149,993.06 Eurovaleur Tonga August 7, 2001 $119,993.02 Eurovaleur Tonga August 28, 2001 $89,992.69 Eurovaleur Tonga October 22, 2001 $90,000.00 Eurovaleur Tonga October 23, 2001 $84,992.76 Eurovaleur Tonga November 15, 2001 $69,992.84 Eurovaleur Tonga

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November 15, 2001 $64,992.89 Eurovaleur Tonga September 21, 2007 € 5,000.00 Eurovaleur E. Kohn December 3, 2007 $130.68 Eurovaleur Tecno Gibraltar December 17, 2007 $112.95 Eurovaleur Tecno Gibraltar February 6, 2008 € 5,000.00 Eurovaleur Kohn February 22, 2008 € 10,000.00 Eurovaleur Blau February 25, 2008 € 15,000.00 Eurovaleur Kohn March 25, 2008 $5,000.00 Eurovaleur Kohn March 28, 2008 € 3,000.00 Eurovaleur E. Kohn April 7, 2008 $8,000.00 Eurovaleur Kohn April 7, 2008 € 3,000.00 Eurovaleur Kohn April 28, 2008 € 6,000.00 Eurovaleur E. Kohn June 19, 2008 € 15,000.00 Eurovaleur Blau August 20, 2008 $12,000.00 Eurovaleur E. Kohn August 20, 2008 € 2,000.00 Eurovaleur E. Kohn September 29, 2008 € 5,000.00 Eurovaleur E. Kohn October 8, 2008 $32.29 Eurovaleur Tecno Gibraltar November 7, 2008 € 5,000.00 Eurovaleur E. Kohn November 24, 2008 € 10,000.00 Eurovaleur Blau February 23, 2009 $817.38 Eurovaleur Blau March 3, 2009 $5,996.00 Eurovaleur Blau KOHN, KOHN FAMILY TOTAL $1,034,730.37 EUROVALEUR DEFENDANTS AND RELATED DEFENDANTS

Transfers from Erko to Kohn Co-Conspirators:

On May 8, 2003, Kohn, through her New York Sham Entity and alter ego Erko, transferred $5,056,795.56 in stolen Customer Property to her co- conspirator, Brightlight, as set forth below.

On information and belief, this payment was made at the direction of Kohn, to benefit her co-conspirator, Brightlight. The payments were transmitted via wire transfer.

The transfer below constitutes the laundering of monetary instruments and a monetary transaction in criminally derived property in violation of 18 U.S.C. §§ 1956 and 1957, respectively, in furtherance of the Illegal Scheme. Under 18 U.S.C. § 1957, this transaction exceeds $10,000.

Date Amount From To May 8, 2003 € 4,453,364.65 Erko Brightlight

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TOTAL $5,056,795.56 ERKO KOHN CO-CONSPIRATORS

Payments from FundsWorld to Eurovaleur

18. Kohn created FundsWorld to sell access to BLMIS though the Medici Enterprise Feeder Funds. On the dates set forth below in the amounts set forth below, FundsWorld transferred stolen Customer Property to Eurovaleur.

FundsWorld was a complete business failure, having made no money in its brief existence. Still, Banca Intesa paid Kohn, through Eurovaleur, €1,149,552 in December 2000 and €1.5 million on December 31, 2002 on behalf of FundsWorld.

The transfers below constitute the laundering of monetary instruments and monetary transactions in criminally derived property in violation of 18 U.S.C. §§ 1956 and 1957, respectively, in furtherance of the Illegal Scheme. Under 18 U.S.C. § 1957, these transactions exceed $10,000. The transfers that follow constitute the receipt of money, across state or international lines, which is known to have been stolen, unlawfully converted, or taken in violation of 18 U.S.C. § 2315. All transfers have a value of $5000 or more.

Date Amount From To 2000 € 1,149,552.00FundsWorld Eurovaleur 2002 € 1,500,000.00FundsWorld Eurovaleur TOTAL $2,480,895.87 FUNDSWORLDEUROVALEUR

Payments from Bank Austria to Eurovaleur

19 Beginning in 2006, Bank Austria transferred stolen Customer Property to Kohn through her New York Sham Entity Eurovaleur in furtherance of the Illegal Scheme. On the dates and in the amounts set forth below, Bank Austria effected these illegal payments to Eurovaleur.

Each of these payments was transmitted to Eurovaleur via wire in foreign commerce.

The transfers below constitute the laundering of monetary instruments and monetary transactions in criminally derived property in violation of 18 U.S.C. §§ 1956 and 1957, respectively, in furtherance of the Illegal Scheme. Under 18 U.S.C. § 1957, these transactions exceed $10,000.

Date Amount From To November 8, 2006 € 50,000.00 Bank Austria Eurovaleur

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November 8, 2006 € 28,654.26 Bank Austria Eurovaleur November 10, 2006 $114,668.63 Bank Austria Eurovaleur February 7, 2007 € 12,500.00 Bank Austria Eurovaleur February 7, 2007 € 12,500.00 Bank Austria Eurovaleur February 7, 2007 € 12,500.00 Bank Austria Eurovaleur February 7, 2007 € 12,500.00 Bank Austria Eurovaleur February 7, 2007 € 12,500.00 Bank Austria Eurovaleur February 7, 2007 € 12,500.00 Bank Austria Eurovaleur February 7, 2007 € 12,500.00 Bank Austria Eurovaleur February 7, 2007 € 10,166.28 Bank Austria Eurovaleur March 9, 2007 $134,436.85 Bank Austria Eurovaleur May 18, 2007 € 166,887.25 Bank Austria Eurovaleur May 23, 2007 $90,753.76 Bank Austria Eurovaleur July 19, 2007 € 54,091.89 Bank Austria Eurovaleur July 23, 2007 $26,186.84 Bank Austria Eurovaleur BANK TOTAL $892,949.58 EUROVALEUR AUSTRIA

Payments from HAM to Bank Medici and Medici Cayman:

20. Kohn and E. Kohn are the beneficial owners of HAM. On the dates set forth below in the amounts set forth below, HAM effected these transfers to Bank Medici and Medici Cayman.

Starting in 2006, Kohn, through HAM (which is located in the same office as Medici Cayman, Bank Austria Cayman, and APM Cayman), began transmitting money to Bank Medici and Medici Cayman. HAM effected these payments to Bank Medici and Medici Cayman via wire in foreign commerce. Over the course of almost three years (February 2006 through November 2008), HAM knowingly transferred these criminally derived proceeds of the Illegal Scheme to Bank Medici and Medici Cayman, which furthered the Illegal Scheme and unjustly enriched the Medici Enterprise.

These payments constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively.

To the extent any of these payments are less than $10,000, they are not monetary transactions in criminally derived property under 18 U.S.C. § 1957, but still constitute the other predicate acts alleged herein. The table below and the information alleged herein are pled in accordance with the

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particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list reflects records of the wires drawn on HAM’s bank account and, on information and belief, is not exhaustive.

Date Amount From To February 6, 2006 $84,159.90 HAM Bank Medici February 7, 2006 € 387,244.58 HAM Bank Medici February 10, 2006 € 6,526.60 HAM Bank Medici February 10, 2006 $2,000.00 HAM Bank Medici April 28, 2006 € 360,354.22 HAM Bank Medici April 28, 2006 $87,064.53 HAM Bank Medici July 20, 2006 € 407,432.71 HAM Bank Medici July 20, 2006 $101,824.00 HAM Bank Medici October 23, 2006 € 405,931.17 HAM Bank Medici October 23, 2006 $109,316.54 HAM Bank Medici January 25, 2007 € 406,388.30 HAM Bank Medici January 25, 2007 $116,406.76 HAM Bank Medici February 20, 2007 € 911.39 HAM Bank Medici March 21, 2007 € 6,911.33 HAM Bank Medici March 21, 2007 $750.00 HAM Bank Medici April 17, 2007 € 122,629.21 HAM Bank Medici April 17, 2007 € 121,819.61 HAM Bank Medici April 17, 2007 $29,385.65 HAM Bank Medici April 17, 2007 $28,991.95 HAM Bank Medici April 25, 2007 € 201,641.29 HAM Bank Medici April 25, 2007 $65,630.31 HAM Bank Medici April 25, 2007 € 1,848.75 HAM Bank Medici May 24, 2007 € 141,443.85 HAM Bank Medici May 24, 2007 $31,042.70 HAM Bank Medici June 19, 2007 € 142,870.21 HAM Bank Medici June 19, 2007 $100,000.00 HAM Bank Medici June 19, 2007 $55,728.67 HAM Bank Medici July 30, 2007 € 219,708.42 HAM Bank Medici July 30, 2007 $128,042.01 HAM Bank Medici August 24, 2007 € 128,113.15 HAM Bank Medici August 24, 2007 $80,591.73 HAM Bank Medici September 18, 2007 € 129,795.39 HAM Bank Medici September 18, 2007 $83,039.38 HAM Bank Medici September 26, 2007 $120,000.00 HAM Medici Cayman

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October 17, 2007 € 187,590.98 HAM Bank Medici October 17, 2007 $135,535.59 HAM Bank Medici October 31, 2007 $22,456.70 HAM Bank Medici October 31, 2007 € 2,307.38 HAM Bank Medici November 16, 2007 $143,052.69 HAM Bank Medici November 16, 2007 € 139,274.86 HAM Bank Medici December 17, 2007 $152,887.48 HAM Bank Medici December 17, 2007 € 134,935.23 HAM Bank Medici January 22, 2008 $449,164.40 HAM Bank Medici February 20, 2008 $322,036.43 HAM Bank Medici February 20, 2008 € 132,184.65 HAM Bank Medici March 18, 2008 $255,458.46 HAM Bank Medici March 18, 2008 € 132,466.37 HAM Bank Medici April 17, 2008 $377,681.59 HAM Bank Medici May 19, 2008 $285,539.98 HAM Bank Medici May 19, 2008 € 146,479.06 HAM Bank Medici June 18, 2008 $290,700.10 HAM Bank Medici June 18, 2008 € 143,589.33 HAM Bank Medici July 23, 2008 $670,822.62 HAM Bank Medici July 23, 2008 € 243,331.82 HAM Bank Medici August 21, 2008 $356,367.89 HAM Bank Medici August 21, 2008 € 145,624.77 HAM Bank Medici September 19, 2008 $363,667.44 HAM Bank Medici September 19, 2008 € 145,943.22 HAM Bank Medici October 22, 2008 $1,019,256.17 HAM Bank Medici October 22, 2008 € 275,071.06 HAM Bank Medici November 20, 2008 $361,434.62 HAM Bank Medici November 20, 2008 € 142,958.32 HAM Bank Medici November 20, 2008 $62,729.22 HAM Medici Cayman TOTAL $13,495,859.37 HAM BANK MEDICI

Payments from HAM to APM Cayman:

21. In the late 1990s, on two separate occasions, Kohn and Kastner traveled to BLMIS’s headquarters in New York. The purpose of these travels was to confer with Madoff in relation to the distribution of the Medici Enterprise Feeder Funds. These travels constitute violations of the Travel Act under 18 U.S.C. § 1952. Because Kohn, Bank Medici, and Eurovaleur caused or induced this travel in interstate or foreign commerce in the execution or concealment of the scheme to defraud, for purposes of obtaining money by means of false pretenses, representations, or promises, it also constitutes a

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violation of 18 U.S.C. § 2314.

Starting in 2006, Kohn, through HAM, began transmitting money to APM Cayman. HAM effected these payments to APM Cayman via wire in foreign commerce. Over the course of almost three years (February 2006 through October 2008), HAM knowingly transferred these criminally derived proceeds of the Illegal Scheme to APM Cayman, which furthered the Illegal Scheme and unjustly enriched the Medici Enterprise. On the dates set forth below in the amounts set forth below, HAM effected these transfers to APM Cayman. On information and belief, these were retrocession fees made in consideration of MediciFinanz’s role as the largest distributor of Herald Fund, Primeo Fund, Herald (Lux), and Thema International in Germany.

The HAM wires constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively, in furtherance of the Illegal Scheme.

To the extent any of these payments are less than $10,000, they are not monetary transactions in criminally derived property under 18 U.S.C. § 1957, but still constitute the other predicate acts alleged herein. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list reflects records of the wires drawn on HAM’s bank account and, on information and belief, is not exhaustive.

Date Amount From To February 10, 2006 € 232,669.64 HAM APM Cayman February 10, 2006 $79,741.05 HAM APM Cayman February 10, 2006 € 23,797.30 HAM APM Cayman February 10, 2006 $10,330.96 HAM APM Cayman April 28, 2006 € 324,286.80 HAM APM Cayman April 28, 2006 $94,031.28 HAM APM Cayman April 28, 2006 € 55,327.46 HAM APM Cayman April 28, 2006 $7,323.48 HAM APM Cayman July 20, 2006 € 489,735.73 HAM APM Cayman July 20, 2006 $102,556.13 HAM APM Cayman July 20, 2006 € 45,861.89 HAM APM Cayman July 20, 2006 € 32,951.00 HAM APM Cayman July 20, 2006 $7,330.23 HAM APM Cayman October 23, 2006 € 665,611.22 HAM APM Cayman

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October 25, 2006 $96,745.34 HAM APM Cayman April 25, 2007 € 616,548.19 HAM APM Cayman April 25, 2007 $99,813.29 HAM APM Cayman July 24, 2007 € 692,227.05 HAM APM Cayman July 24, 2007 $129,845.63 HAM APM Cayman August 14, 2007 $28,009.02 HAM APM Cayman October 17, 2007 € 577,992.83 HAM APM Cayman October 17, 2007 $520,003.55 HAM APM Cayman October 17, 2007 $53,895.12 HAM APM Cayman January 22, 2008 $645,841.71 HAM APM Cayman January 22, 2008 € 621,763.02 HAM APM Cayman January 22, 2008 $81,386.58 HAM APM Cayman March 18, 2008 $28,000.00 HAM APM Cayman April 17, 2008 € 582,515.08 HAM APM Cayman April 17, 2008 $569,887.13 HAM APM Cayman April 17, 2008 $72,117.34 HAM APM Cayman July 23, 2008 € 678,554.98 HAM APM Cayman July 23, 2008 $352,523.21 HAM APM Cayman July 23, 2008 $82,110.19 HAM APM Cayman October 22, 2008 € 767,283.07 HAM APM Cayman October 22, 2008 $731,982.70 HAM APM Cayman October 22, 2008 $88,837.47 HAM APM Cayman TOTAL $12,749,100.95 HAM APM CAYMAN

Payments from HAM to Bank Austria Cayman:

22. Starting in 2006, Kohn, through HAM (which is located in the same office as Bank Austria Cayman, Medici Cayman, and APM Cayman), began transmitting money to Bank Austria Cayman. HAM effected these payments to Bank Austria Cayman via wire in foreign commerce.

In fifteen months (November 2006 through January 2008), HAM knowingly transferred these criminally derived proceeds of the Illegal Scheme to Bank Austria Cayman, which furthered the Illegal Scheme and unjustly enriched the Medici Enterprise. On the dates set forth below in the amounts set forth below, HAM effected these transfers to Bank Austria and Bank Austria Cayman.

These payments constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively.

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The January 12, 2006, August 14, 2007, and January 8, 2008 transfers are less than $10,000. Hence, they are not monetary transactions in criminally derived property under § 1957, but still constitute the other predicate acts alleged herein. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list reflects records of the wires drawn on HAM’s bank account and on information and belief is not exhaustive.

Date Amount From To November 22, 2006 $25,000 HAM Bank Austria Cayman January 12, 2007 $3,293 HAM Bank Austria Cayman August 14, 2007 $3,086.18 HAM Bank Austria Cayman January 8, 2008 $3,926.37 HAM Bank Austria Cayman January 23, 2008 $24,000 HAM Bank Austria Cayman TOTAL $59,305.55 HAM BANK AUSTRIA CAYMAN

Payments between HAM, Bank Medici, and Pioneer:

23. On April 25, 2007, Pioneer replaced BA Worldwide as the investment manager and adviser to Primeo Fund. UniCredit, Profumo, and Gutty, through Pioneer, conspired to mask Primeo Fund’s investment with BLMIS by undertaking to invest the fund indirectly through Herald Fund, Alpha Prime Fund, and Thema International. Kohn, through Bank Medici, conspired to market, distribute, and sell Primeo Fund in furtherance of this misdirection. For agreeing to market and distribute Primeo Fund, Pioneer paid Bank Medici $1,215,546 on or about 2007. This payment constitutes a monetary transaction in criminally derived property under 18 U.S.C. § 1957.

Starting no later than July 2008, Kohn, through HAM, began transmitting retrocession fees to UniCredit’s Pioneer for marketing, distributing, and selling Herald Fund (into which UniCredit conspired with Kohn and Eurovaleur, among others, to disguise Primeo Fund’s investment in BLMIS) in furtherance of the Illegal Scheme and enriching the Medici Enterprise.

These payments constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively. HAM effected these payments to Pioneer via wire in foreign commerce. On the dates set forth below in the amounts set forth below, HAM effected these transfers to Pioneer.

Under 18 U.S.C. § 1957, all payments exceed $10,000. The table below

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and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list reflects records of the wires drawn on HAM’s bank account and, on information and belief, is not exhaustive.

Date Amount From To July 23, 2008 $2,376,839.07 HAM Pioneer August 21, 2008 $1,136,888.72 HAM Pioneer September 19, 2008 $1,228,499.43 HAM Pioneer October 22, 2008 $3,493,016.43 HAM Pioneer November 20, 2008 $1,204,544.30 HAM Pioneer TOTAL $9,439,787.95 HAM PIONEER

Payments from HAM to Sofipo:

24. On April 2, 2007, Cosulich, director of HAM and the Managing Director of Sofipo, sent a facsimile to BLMIS from a Sofipo facsimile machine using HAM letterhead. Cosulich notified BLMIS that: (i) Herald Fund planned to infuse $35 million of Primeo Fund’s money into Herald Fund’s BLMIS account; and (ii) at UniCredit’s direction, Primeo Fund would stop investing directly with BLMIS and begin covertly investing indirectly through Herald Fund.

Starting in 2007, Kohn, through HAM, began transmitting fees to Sofipo in furtherance of the Illegal Scheme. HAM effected these payments to Sofipo via wire in foreign commerce. Between November 2007 and October 2008, HAM knowingly transferred these criminally derived proceeds of the Illegal Scheme to Sofipo, which furthered the Illegal Scheme and unjustly enriched the Medici Enterprise. On the dates set forth below in the amounts set forth below, HAM effected these transfers to Sofipo.

These payments constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956 and 1343, respectively, in furtherance of the Illegal Scheme.

The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list reflects records of the wires drawn on HAM’s bank account and, on information and belief, is not exhaustive.

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Date Amount From To November 16, 2007 €424.01 HAM Sofipo April 17, 2008 €1,025.87 HAM Sofipo July 23, 2008 $690.21 HAM Sofipo July 23, 2008 €409.38 HAM Sofipo October 22, 2008 $703.69 HAM Sofipo October 22, 2008 €352.37 HAM Sofipo TOTAL $4,760.11 HAM SOFIPO

Payments from HAM to Mugnai, de Sury, Kastner and Cosulich:

25. Mugnai, de Sury, and Cosulich oversaw the day-to-day operations of HAM and each distributed Herald Fund. Mugnai, de Sury, Kastner and Cosulich received retrocession fees from HAM for soliciting investors into the Ponzi scheme.

Starting in 2006, Kohn, via HAM, transmitted these fees to Mugnai, de Sury, Kastner and Cosulich in furtherance of the Illegal Scheme. HAM effected these transfers to the above named Defendants via wire in foreign commerce. The following chart sets forth that Mugnai, de Sury, and Cosulich engaged in monetary transactions of criminally derived property with HAM, along with the dates and dollar amounts for these transactions.

Also, Kohn made a large one-time payment to Gerila. On information and belief, this payment was a personal loan from Kohn to her close personal friend, Kastner, a German financial executive who owned and managed APM Cayman and MediciFinanz. On information and belief, the purpose of this loan was to help Kastner pay for expenses associated with his divorce. The following chart sets forth that HAM knowingly engaged in monetary transactions of criminally derived property with Gerila, along with the dates and dollar amounts for these transactions.

These transfers constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively, in furtherance of the Illegal Scheme.

To the extent any of these payments are less than $10,000, they are not Monetary Transactions in Criminally Derived Property under 18 U.S.C. § 1957, but still constitute the other predicate acts alleged herein. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list reflects records of the wires drawn on HAM’s bank account and, on information and belief, is not exhaustive.

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Date Amount From To June 1, 2006 € 2,273.28 HAM Mugnai August 1, 2006 € 10,671.73 HAM Mugnai October 23, 2006 € 35,137.62 HAM Mugnai January 25, 2007 € 33,694.96 HAM Mugnai March 13, 2007 € 10,000.00 HAM de Sury April 25, 2007 € 32,673.25 HAM Mugnai July 24, 2007 € 20,230.27 HAM Mugnai October 17, 2007 € 23,634.79 HAM Mugnai January 22, 2008 € 24,530.66 HAM Mugnai January 23, 2008 $696.20 HAM Mugnai March 18, 2008 € 19,000.00 HAM de Sury March 26, 2008 € 600,000.00 HAM Kastner (through Gerila) April 17, 2008 € 22,463.43 HAM Mugnai April 30, 2008 € 30,000.00 HAM de Sury May 15, 2008 € 30,000.00 HAM Cosulich July 23, 2008 € 17,444.71 HAM Mugnai July 23, 2008 $710.58 HAM Mugnai August 21, 2008 € 20,000.00 HAM de Sury October 22, 2008 € 18,249.59 HAM Mugnai October 22, 2008 $790.96 HAM Mugnai December 17, 2008 € 15,000.00 HAM de Sury TOTAL $1,454,166.47 HAM KOHN CO-CONSPIRATORS

Transfers from HAM to Revi:

26. In 2008, Kohn, through HAM, began transmitting fees to Revi in furtherance of the Illegal Scheme. HAM effected these payments to Revi via wire in foreign commerce.

On information and belief, these payments were used to capitalize Kohn’s latest tranche of Sham Entities, in an effort to create an exit strategy for when BLMIS collapsed.

In 2008, HAM knowingly transferred these criminally derived proceeds of the Illegal Scheme to Revi, which furthered the Illegal Scheme and unjustly enriched the Medici Enterprise. On the dates set forth below in the amounts set forth below, HAM effected these transfers to Revi.

These transfers constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively, in

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furtherance of the Illegal Scheme.

Under § 1957 these payments exceed $10,000. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list reflects records of the wires drawn on HAM’s bank account and on information and belief is not exhaustive.

Date Amount From To January 9, 2008 $2,000,042.00 HAM Revi January 9, 2008 € 2,000,028.51 HAM Revi March 27, 2008 € 250,000.00 HAM Revi TOTAL $5,333,173.92 HAM REVI

Liechtenstein Sham Entity Transfers

27. From January 24, 2008 to January 25, 2008, Kohn and Gutty, through PrivatLife, Starvest, and LifeTrust, engaged in a series of suspicious money transfers. On information and belief, there were no legitimate business purposes for these transactions. These transfers triggered a money laundering investigation in Liechtenstein against Kohn which remains ongoing.

Later, on October 29, 2008, Kohn and Gutty directed Bank Medici to send $970,413 to PrivatLife. On information and belief, Kohn and Gutty also directed WSV to send $970,413 to PrivatLife on the same day. On information and belief, there were no legitimate business purposes for these transactions.

These transfers constitute the laundering of monetary instruments, monetary transactions in criminally derived property, and wire fraud in violation of 18 U.S.C. §§ 1956, 1957, and 1343, respectively, in furtherance of the Illegal Scheme.

Under § 1957 these payments exceed $10,000. The table below and the information alleged herein are pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud. This list reflects records of the wires drawn on HAM’s bank account and, on information and belief, is not exhaustive.

Date Amount From To January 24, 2008 $ 1,571,428.55 PrivatLife Starvest January 24, 2008 € 1,076,019.99 PrivatLife Starvest January 25, 2008 $ 1,571,428.55 Starvest PrivatLife January 25, 2008 € 1,076,019.99 Starvest PrivatLife

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January 24, 2008 $ 428,571.45 PrivatLife Lifetrust January 24, 2008 € 293,460.02 PrivatLife Lifetrust January 25, 2008 $ 428,571.45 Lifetrust PrivatLife January 25, 2008 € 293,460.02 Lifetrust PrivatLife October 29, 2008 $ 970,413 WSV PrivatLife October 29, 2008 $ 970,413 Bank Medici PrivatLife TOTAL $9,947,554.25

Kohn Continued the Illegal Scheme After December 11, 2008:

1. At all relevant times, including after Madoff’s confession, Kohn, UniCredit, Bank Austria, Bank Medici, Zapotocky, Scheithauer, Lavi, and Radel-Leszczynski conspired to conceal the role of BLMIS and Madoff in the Medici Enterprise Feeder Funds.

On December 23, 2008, Shpe met with Scheithauer and Lavi to discuss her investment with Herald (Lux) in light of Bank Medici’s exposure to BLMIS. On information and belief, Scheithauer and Lavi denied having knowledge of Bank Medici’s exposure to BLMIS. Later that day Kohn telephoned Shpe to deny having known that Herald (Lux) invested with BLMIS. At all relevant times, Scheithauer served as a director of Herald (Lux). This correspondence was made with the intention to defraud and furthered the Illegal Scheme.

Soon after this phone call, Lavi called Shpe to confess that Kohn personally instructed her and all Bank Medici employees not to disclose to clients that their assets were invested with BLMIS.

The December 23, 2008 telephone call from Kohn was transmitted via wire in foreign commerce and in violation of 18 U.S.C. § 1343. The information alleged herein is pled in accordance with the particularity requirements of Fed. R. Civ. P. 9(b) with respect to circumstances constituting fraud.

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(3) If the RICO claim is based on the predicate offenses of wire fraud, mail fraud, or fraud in the sale of securities, the “circumstances constituting fraud or mistake shall be stated with particularity.” Fed. R. Civ. P. 9(b). Identify the nature, time, place and contents of misrepresentations, and the identity of persons to whom and by whom the alleged misrepresentations were made; it must be clear why the plaintiff claims the acts to constitute fraud or misrepresentations:

The Trustee’s RICO claims are not based on predicate offenses of fraud in the sale of securities. The Trustee has alleged each predicate act of wire fraud, mail fraud, and financial institution fraud with the particularity required by Fed. R. Civ. P. 9(b).

(4) State whether there has been a criminal conviction for violation of the predicate acts:

The Trustee is not aware whether any Defendants in this action have been criminally convicted in relation to the predicate acts alleged herein. The Trustee understands, however, that Kohn, Bank Medici, Bank Austria, and many other members of the Medici Enterprise are being investigated by law enforcement authorities in the United States, Great Britain, France, Austria, Switzerland, Luxembourg, Liechtenstein, and elsewhere. Madoff and DiPascali have pled guilty to federal crimes, as set forth herein.

(5) State whether civil litigation has resulted in a judgment with regard to predicate acts:

The Trustee is aware of and has brought certain ongoing civil litigations in the United States and elsewhere in relation to the Medici Enterprise Feeder Funds and certain members of the Medici Enterprise that have not yet resulted in a judgment. Kohn, Bank Austria, Bank Medici, and other members of the Medici Enterprise have been named in multiple lawsuits in the United States and elsewhere in relation to the Illegal Scheme and the predicate acts alleged herein and in the accompanying Second Amended Complaint.

(6) Describe how the predicate acts form a “pattern of racketeering activity”:

The predicate acts form a “pattern of racketeering activity” and are all part of a common criminal plan to perpetrate the Illegal Scheme and enrich the Medici Enterprise through the Defendants’ criminal and fraudulent conduct. The Illegal Scheme began in or about 1985 when Kohn met Madoff in New York, continued through Madoff’s confession on December 11, 2008, and may be ongoing. Kohn has dissipated stolen Customer Property and other criminally derived proceeds of the Illegal Scheme since the collapse of the Ponzi scheme. All of the predicate acts relate to one another because they represent a common scheme to further the Illegal Scheme and enrich the Medici Enterprise. The predicate acts progressed in a logical fashion as the Illegal Scheme expanded from its core in New York and as it fed (and fed off of) BLMIS in New York. Kohn received stolen Customer Property directly from BLMIS at least quarterly from at least 1987 until 2008 with few (if any) interruptions to this pattern of transfers. These payments progressed in a pattern from one of Kohn’s Sham Entities to another as she endeavored to conceal her secret corrupt kickbacks from Madoff.

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This twenty year pattern is comprised of repeated and related predicate acts of: (i) money laundering in violation of 18 U.S.C. § 1956; (ii) engaging in monetary transactions in property derived from specific unlawful activity in violation of 18 U.S.C. § 1957; (iii) wire fraud in violation of 18 U.S.C. § 1343; (iv) financial institution fraud in violation of 18 U.S.C. § 1344; (v) mail fraud in violation of 18 U.S.C. § 1341; (vi) transporting funds taken by fraud in violation of 18 U.S.C. § 2314; (vii) transportation of persons to defraud in violation of 18 U.S.C. § 2314; (viii) receiving funds taken by fraud in violation of 18 U.S.C. § 2315; and (ix) interstate and international travel in violation of the Travel Act, 18 U.S.C. § 1952.

(7) State whether the alleged predicate acts relate to each other as part of a common plan. If so, describe in detail:

All of the predicate acts relate to each other as a part of a common plan to effect the Illegal Scheme as alleged in detail herein and in the accompanying Second Amended Complaint.

g. Describe in detail the alleged Enterprise for each RICO claim:

The Medici Enterprise is composed of the seventy-seven known individual and corporate Defendants named in this action. The Medici Enterprise is an association in fact, and not a legal entity. In furtherance of the Illegal Scheme, the Defendants, as members of the Medici Enterprise, committed certain predicate acts alleged herein that constitute violations of RICO § 1962 (c) and (d).

g(1) State the names of the individuals, partnerships, corporations, associations, or other legal entities that constitute the Enterprise:

All Defendants, except for Sharei, are members of the Medici Enterprise.

g(2) Describe the structure, purpose, function and course of conduct of the Enterprise:

Structure:

The Medici Enterprise: (i) is an ongoing association in fact with a decision-making framework or mechanism for controlling the association; (ii) has associated members with a common purpose that functions as a continuing unit; and (iii) is separate and apart from the pattern of racketeering activity. Conduct of the members of the Medici Enterprise as it relates to the Illegal Scheme is for the most part directed by Kohn and her instrumentality Bank Medici, a branch of Bank Austria, which acted through, among others, Randa and Zapotocky. This is the structure of the Medici Enterprise as it relates to the “Money-In” aspect of the Illegal Scheme.

Kohn orchestrated the siphoning of stolen Customer Property directly from the BLMIS estate through her family and her network of Sham Entities in New York and elsewhere. This is the structure of the Medici Enterprise as it relates to the “Money-Out” aspect of the Illegal Scheme.

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Purpose and Function:

All Defendants, as members of the Medici Enterprise, are participants in the Illegal Scheme in different capacities, functions, and roles calculated to enrich and expand the Medici Enterprise so that it could continue to perpetrate the “Money-In” and “Money-Out” aspects of the Illegal Scheme.

Course of Conduct:

Governance of the Medici Enterprise occurred through frequent communications among its members by means of interstate and international wire communication via telephone, facsimile, and e-mail in interstate and international commerce in addition to travel to and from New York and internationally.

g(3) State whether any Defendants are employees, officers or directors of the alleged Enterprise:

The Medici Enterprise is an association in fact that exists apart from its constituent Defendant members. As alleged herein, however, certain individual Defendants are employees, officers, or directors of certain corporate Defendants.

g(4) State whether any Defendants are associated with the Enterprise:

All Defendants, except Sharei, are associated with and members of the Medici Enterprise.

g(5) State whether you claim that the Defendants are individuals or entities separate from the Enterprise, or that the Defendants are the Enterprise itself, or members of the Enterprise:

The Medici Enterprise is an association in fact that exists apart from its constituent Defendant members. As alleged herein and in the accompanying Second Amended Complaint, however, certain individual Defendants are employees, officers, or directors of certain corporate Defendants. All Defendants are associated with or members of the Medici Enterprise.

g(6) If any Defendants are alleged to be the Enterprise itself, or members of the enterprise, explain whether such Defendants are perpetrators or passive instruments:

All Defendants, except Sharei, as members of the Medici Enterprise, are participants in the Illegal Scheme in different capacities, functions, and roles calculated to further its unlawful purposes as alleged herein.

h. State and describe in detail whether you claim that the pattern of racketeering activity and the Enterprise are separate or have merged into one entity:

The pattern of racketeering activity and certain Defendants have merged. For example, Kohn and the Kohn Sham Entity Defendants appear to have no other purpose than to further the Illegal Scheme through siphoning stolen Customer Property directly from the BLMIS estate.

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The predicate acts alleged herein are the sole activity of among others, Kohn and the Kohn Sham Entity Defendants.

Other members of the Medici Enterprise, however, are apparently engaged in other lawful business activity outside of the pattern of racketeering activity alleged herein that furthered the Illegal Scheme. For example, on information and belief, Bank Austria and UniCredit are legitimate financial institutions. Although Bank Austria and UniCredit committed predicate acts in furtherance of the Illegal Scheme and are members of the Medici Enterprise Bank Austria and UniCredit also have an existence separate and distinct from the Medici Enterprise. Bank Austria and UniCredit subverted their legitimate purposes at the direction of Kohn, among others, and committed the predicate acts alleged herein. All Defendants, however, were at all times relevant to this action, employed by or associated with the Medici Enterprise, the activities of which affect foreign and interstate commerce.

i. Describe the relationship between the activities of the Enterprise and the pattern of racketeering activity. Discuss how the pattern of racketeering activity differs from the usual and daily activities of the Enterprise, if at all:

The Medici Enterprise exists only to further the Illegal Scheme. Its pattern of racketeering activity does not differ from the daily activities of the Medici Enterprise. The Illegal Scheme exploited the credibility, wealth, infrastructure, and financial expertise of Bank Austria and UniCredit to solicit investors for the Ponzi scheme. All Defendants knew or had reason to know that the appearance of legitimacy was unwarranted.

j. Describe what benefits, if any, the Enterprise receives from the alleged pattern of racketeering:

Each member the Medici Enterprise received the benefit of stolen Customer Property in the form of, among other things, secret corrupt kickbacks from Madoff, unearned fees, compensation, bonuses, and other proceeds of the Illegal Scheme.

k. Describe the effect of the activities of the Enterprise on interstate or foreign commerce:

The Illegal Scheme fed and perpetuated Madoff’s Ponzi scheme while depleting the BLMIS estate. The Ponzi scheme could not have continued without a constant influx of fresh capital. The effect of the collapse of BLMIS on interstate commerce is a matter of public record and a fact of which this Court can take judicial notice. Kohn and other Defendants used and exploited U.S. financial institutions, the USPTO, lawyers in New York, other states and overseas, as well as interstate and international telephone, facsimile, e-mail, and, wire transfer communications from no later than 1985 to the present. The activities of the Medici Enterprise directly affected U.S. interstate and foreign commerce through the Illegal Scheme.

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l. If the Second Amended Complaint alleges a violation of 18 U.S.C. § 1962(a), describe in detail the acquisition or maintenance of any interest in or control of the alleged Enterprise:

1. State who received the income derived from the pattern of racketeering activity or through the collection of an unlawful debt:

The Trustee does not allege a violation of 18 U.S.C. § 1962(a).

2. Description of the use or investment of such income:

The Trustee does not allege a violation of 18 U.S.C. § 1962(a).

m. If the Second Amended Complaint alleges a violation of 18 U.S.C. § 1962(b), describe in detail the acquisition or maintenance of any interest in or control of the alleged Enterprise:

The Trustee does not allege a violation of 18 U.S.C. § 1962(b) although the fees and commissions received by certain Defendants, such as Bank Austria and UniCredit, enhanced their ability to acquire an interest in, and/or establish the operation of, certain Defendants that also furthered the Illegal Scheme through a continued pattern of racketeering activity.

n. If the Second Amended Complaint alleges a violation of 18 U.S.C. § 1962(c):

(i) State who is employed by or associated with the Enterprise; and

(ii) Describe whether the same entity is both the liable “person” and the “enterprise” under § 1962(c):

The Trustee interprets this question as seeking information only as to parties to this action who are “employed by” or “associated with” corporate Defendants that are members of the Medici Enterprise. These Defendants have numerous employees and associated individuals and entities that are not parties to this action.

Subject to the above interpretation, the Trustee states that the Second Amended Complaint alleges a violation of 18 U.S.C. § 1962(c) and that the specific employees and associates of each Defendant member of the Medici Enterprise are alleged fully herein and in the Second Amended Complaint.

o. If the Second Amended Complaint alleges a violation of 18 U.S.C. § 1962(d), describe in detail the alleged conspiracy:

The Second Amended Complaint alleges a violation of 18 U.S.C. § 1962(d) in that the Defendant members of the Medici Enterprise conspired among themselves to effect the Illegal Scheme as alleged fully herein and in the Second Amended Complaint.

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p. Describe the alleged injury to business or property:

As a direct and proximate result of the Illegal Scheme, the BLMIS estate’s insolvency was deepened, and the Trustee is unable to repay creditors of the BLMIS estate and customers of BLMIS.

q. Describe the causal relationship between the injury and violation of the RICO statute:

In the absence of the Illegal Scheme the Ponzi scheme would have existed and it would have continued. The Illegal Scheme, however, infused the Ponzi scheme with over $9 billion in fresh capital that prolonged it, and is arguably the “sine qua non” of the Ponzi scheme, at least as of the inception of the Illegal Scheme. The role of Kohn, Bank Medici, Bank Austria, and UniCredit lent BLMIS an appearance of legitimacy and credibility that protected it from exposure. Every day that the Ponzi scheme continued, the assets of the BLMIS estate were depleted further.

r. List the damages sustained for which each Defendant is liable:

All Defendants, except Sharei, are jointly and severally liable for all damages to the BLMIS estate.

s. List all other federal causes of action, if any, and provide the relevant statute:

Federal bankruptcy claims: 11 U.S.C. §§ 544, 547, 548, 550, and 551.

t. List all pendent state claims, if any:

New York Debtor and Creditor Law §§ 273-279 and New York Civil Practice Laws and Rules 203(g) and 213(8). New York Unjust Enrichment, Conversion, and Money Had and Received.

u. Provide any additional information potentially helpful to the Court in adjudicating your RICO claim:

N/A

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Dated: New York, New York /s/ Timothy S. Pfeifer April 6, 2012 Baker & Hostetler LLP 45 Rockefeller Plaza New York, New York 10111 Telephone: 212.589.4200 Facsimile: 212.589.4201 David J. Sheehan Timothy S. Pfeifer Keith R. Murphy Denise D. Vasel Marco Molina A. Mackenna Mosier Brian F. Allen

Attorneys for Irving H. Picard, Trustee for the Substantively Consolidated SIPA Liquidation of Bernard L. Madoff Investment Securities LLC and Bernard L. Madoff

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