Case 2:20-cv-05910 Document 1 Filed 07/01/20 Page 1 of 280 Page ID #:1 1 DEBORAH CONNOR, Chief Money Laundering and Asset Forfeiture Section (MLARS) 2 MARY BUTLER, Chief, International Unit WOO S. LEE, Deputy Chief, International Unit 3 BARBARA Y. LEVY, Trial Attorney JOSHUA L. SOHN, Trial Attorney 4 JONATHAN BAUM, Trial Attorney Criminal Division 5 United States Department of Justice 1400 New York Avenue, N.W., 10th Floor 6 Washington, D.C. 20530 Telephone: (202) 514-1263 7 Email:
[email protected] 8 Attorneys for Plaintiff 9 UNITED STATES OF AMERICA 10 UNITED STATES DISTRICT COURT 11 FOR THE CENTRAL DISTRICT OF CALIFORNIA 12 13 UNITED STATES OF AMERICA, No. CV 20-5910 14 Plaintiff, VERIFIED COMPLAINT FOR 15 v. FORFEITURE IN REM 16 ONE DRAWING ENTITLED “SELF- [18 U.S.C. § 981(a)(1)(A) and (C)] 17 PORTRAIT” BY JEAN-MICHEL 18 BASQUIAT, [F.B.I.] 19 Defendant. 20 21 The United States of America (the “government”) brings this complaint against 22 the above-captioned asset and alleges as follows: 23 PERSONS AND ENTITIES 24 1. The plaintiff is the United States of America. 25 2. The defendant in this action is One Drawing entitled “Self-Portrait” by 26 Jean-Michel Basquiat more particularly described in Attachment A (“DEFENDANT 27 ASSET”). 28 Case 2:20-cv-05910 Document 1 Filed 07/01/20 Page 2 of 280 Page ID #:2 1 3. The DEFENDANT ASSET was previously owned by Christopher Joey 2 McFarland (“McFarland”), who agreed, through counsel, to surrender it to the 3 government, and executed a stipulation relinquishing all right, title, and interest in the 4 DEFENDANT ASSET in connection with case number CV 19-1327 DSF (PLAx), 5 United States v.