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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Case 2:20-cv-05914 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 20-5914 14 Plaintiff, VERIFIED COMPLAINT FOR 15 v. FORFEITURE IN REM 16 ALL FUNDS AND ASSETS, [18 U.S.C. § 981(a)(1)(A) and (C)] 17 INCLUDING SECURITIES AND 18 INVESTMENTS, ON DEPOSIT IN [F.B.I.] FALCON PRIVATE BANK LIMITED 19 ACCOUNT NUMBERS ‘6001 AND 20 ‘6001.1001, 21 Defendants. 22 23 The United States of America (the “government”) brings this complaint against 24 the above-captioned assets and alleges as follows: 25 PERSONS AND ENTITIES 26 1. The plaintiff is the United States of America. 27 2. The defendants in this action are all funds and assets, including securities 28 and investments, on deposit in account numbers ‘6001 and ‘6001.1001 held by River Case 2:20-cv-05914 Document 1 Filed 07/01/20 Page 2 of 280 Page ID #:2 1 Dee International SA at Falcon Private Bank Limited (“Falcon Bank”) in Switzerland 2 more particularly described in Attachment A (“DEFENDANT ASSETS”). 3 3. The persons and entities whose interests may be affected by this action are 4 “Jasmine” Loo Ai Swan and River Dee International SA. 5 4. Contemporaneously with the filing of this complaint, plaintiff is filing 6 related actions seeking the civil forfeiture of the following assets (collectively, the 7 “NEW SUBJECT ASSETS”). 8 a. BASQUIAT DRAWING: One colored crayon, black felt tip pen, 9 and acrylic drawing on Arches wove paper with “JMB” initialed on the reverse side, 10 entitled “Self-Portrait” by Jean-Michel Basquiat. 11 b. WARHOL PORTRAIT: One gold paint and silkscreen ink portrait 12 on canvas, entitled “Round Jackie” by Andy Warhol. 13 c. AVE RAPHAEL APARTMENT: Real property located in Paris, 14 France titled in the name of Ave Raphael (Paris) SCI, including all appurtenances, 15 improvements, and attachments thereon, as well as all leases, rents, and profits derived 16 therefrom. 17 d. CAMPBELL’S SOUP CAN AND VÉTHEUIL AU SOLEIL 18 PAINTINGS: One acrylic, spray paint, and silkscreen ink on linen painting entitled 19 “Colored Campbell’s Soup Can (Emerald Green), 1965” by Andy Warhol and one oil 20 on canvas painting entitled “Vétheuil au Soleil” by Claude Monet. 21 e. VASCO AND EAGLE STRATEGIC FUNDS: All funds on 22 deposit in account number ‘0610 held by Vasco Investments Services SA at Bank 23 Privée Edmond de Rothschild (“Bank Rothschild”) in Luxembourg, and all funds on 24 deposit in account number ‘1751 held by Eagle Strategic Investment Fund (B) at Bank 25 Rothschild in Luxembourg. 26 5. Plaintiff has previously filed the following complaints, seeking civil 27 forfeiture of the following assets (referred collectively, together with the NEW 28 SUBJECT ASSETS, as the “SUBJECT ASSETS”): 2 Case 2:20-cv-05914 Document 1 Filed 07/01/20 Page 3 of 280 Page ID #:3 1 a. Case number CV 16-5362 DSF (PLAx), United States v. The Wolf of 2 Wall Street Motion Picture, Including any Rights to Profits, Royalties and Distribution 3 Proceeds owed to Red Granite Pictures, Inc. or its Affiliates and/or Assigns (“THE 4 WOLF OF WALL STREET”). 5 b. Case number CV 16-5368 DSF (PLAx), United States v. The Real 6 Property Known as The Viceroy L’Ermitage Beverly Hills (“the L’ERMITAGE 7 PROPERTY”). 8 c. Case number CV 16-5369 DSF (PLAx) United States v. All Business 9 Assets of The Viceroy L’Ermitage Beverly Hills, Including All Chattels and Intangible 10 Assets, Inventory, Equipment, and All Leases, Rents and Profits Derived Therefrom 11 (“THE L’ERMITAGE BUSINESS ASSETS”). 12 d. Case number CV 16-5377 DSF (PLAx) United States v. Real 13 Property located in Beverly Hills, California (“HILLCREST PROPERTY 1”). 14 e. Case number CV 16-5371 DSF (PLAx) United States v. Real 15 Property Located in New York, New York (“PARK LAUREL CONDOMINIUM”). 16 f. Case number CV 16-5367 DSF (PLAx) United States v. One 17 Bombardier Global 5000 Jet Aircraft, Bearing Manufacturer’s Serial Number 9265 and 18 Registration Number N689WM, its Tools and Appurtenances, and Aircraft Logbooks 19 (“BOMBARDIER JET”). 20 g. Case number CV 16-5374 DSF (PLAx) United States v. Real 21 Property Located in New York, New York (“TIME WARNER PENTHOUSE”). 22 h. Case number CV 16-5378 DSF (PLAx) United States v. Real 23 Property located in Los Angeles, California (“ORIOLE MANSION”). 24 i. Case number CV 16-5375 DSF (PLAx) United States v. Real 25 Property Located in New York, New York (“GREENE CONDOMINIUM”). 26 j. Case number CV 16-5364 DSF (PLAx) United States v. Any Rights 27 to Profits, Royalties and Distribution Proceeds Owned by or Owed to JW Nile (BVI) 28 Ltd., JCL Media (EMI Publishing Ltd), and/or Jynwel Capital Ltd, Relating to EMI 3 Case 2:20-cv-05914 Document 1 Filed 07/01/20 Page 4 of 280 Page ID #:4 1 Music Publishing Group North America Holdings, Inc., and D.H. Publishing L.P., Inc. 2 and D.H. Publishing L.P. (“EMI ASSETS”). 3 k. Case number CV 16-5370 DSF (PLAx) United States v. All Right to 4 and Interest in Symphony CP (Park Lane) LLC, Held or Acquired, Directly or 5 Indirectly, by Symphony CP Investments LLC and/or Symphony CP Investments 6 Holdings LLC, Including Any Interest Held or Secured by the Real Property and 7 Appurtenances Located at 36 Central Park South, New York, New York, Known as The 8 Park Lane Hotel, Any Right to Collect and Receive Any Profits and Proceeds 9 Therefrom, and Any Interest Derived From the Proceeds Invested in The Symphony CP 10 (Park Lane) LLC by Symphony CP Investments LLC and Symphony CP (Park Lane) 11 LLC (“SYMPHONY CP (PARK LANE) LLC ASSETS”). 12 l. Case number CV 16-5376 DSF (PLAx) United States v. United States 13 v. Real Property Located in New York, New York (“WALKER TOWER 14 PENTHOUSE”). 15 m. Case number CV 16-5379 DSF (PLAx) United States v. Real 16 Property located in Beverly Hills, California (“LAUREL BEVERLY HILLS 17 MANSION”). 18 n. Case number CV 16-5366 DSF (PLAx) United States v. one pen and 19 ink drawing by Vincent Van Gogh titled “La maison de Vincent a Arles” (“VAN 20 GOGH ARTWORK”). 21 o. Case number CV 16-5366 DSF (PLAx) United States v. One painting 22 by Claude Monet titled “Saint-Georges Majeur” (“SAINT GEORGES PAINTING”). 23 p. Case number CV 16-5366 DSF (PLAx) United States v. 24 €25,227,025.83 Euros held in an escrow account at UBS, S.A. in Switzerland 25 constituting the proceeds of the sale of a painting by Claude Monet titled “Nympheas” 26 (“PETITE NYPMHEAS PROCEEDS”). 27 28 4 Case 2:20-cv-05914 Document 1 Filed 07/01/20 Page 5 of 280 Page ID #:5 1 q. Case number CV 16-5380 DSF (PLAx) United States v Real 2 Property in London, United Kingdom, owned by Qentas Holdings (“THE QENTAS 3 TOWNHOUSE”). 4 r. Case number CV 17-4240 DSF (PLAx) United States v. Real 5 Property in London, United Kingdom owned by Stratton Street (London) Ltd. (“THE 6 STRATTON PENTHOUSE”). 7 s. Case number CV 17-4242 DSF (PLAx) United States v. Real 8 Property in London, United Kingdom owned by Seven Stratton Street (London) Ltd. 9 (“STRATTON FLAT”). 10 t. Case number CV 17-4244 DSF (PLAx) United States v. Real 11 Property in London, United Kingdom owned by Eight Nine Stratton Street (London) 12 Ltd. (“STRATTON OFFICE BUILDING”). 13 u. Case number CV 17-4438 DSF (PLAx) United States v. Certain 14 rights To and Interests In The Viceroy Hotel Group. (“THE VICEROY HOTEL 15 GROUP ASSETS”). 16 v. Case number CV 17-4439 DSF (PLAx) United States v. All rights To 17 and Interests In The Motion Pictures “Daddy’s Home” and “Dumb and Dumber To,” 18 Belonging to red Granite Pictures. (“DUMB AND DUMBER TO RIGHTS” and 19 “DADDY’S HOME RIGHTS”). 20 w. Case number CV 17-4441 DSF (PLAx) United States v. All Right and 21 title to the Yacht M/Y Equanimity. (“THE EQUANIMITY”). 22 x. Case number CV 17-4446 DSF (PLAx) United States v. Certain 23 Rights to and Interests in Shares of Series D Preferred Stock in Palantir Technologies 24 (“PALANTIR STOCK”). 25 y. Case number CV 17-4440 DSF (PLAx) United States v. One 26 Metropolis Poster (“METROPOLIS POSTER”). 27 28 5 Case 2:20-cv-05914 Document 1 Filed 07/01/20 Page 6 of 280 Page ID #:6 1 z. Case number CV 17-4444 DSF (PLAx) United States v. Real 2 Property Located in New York, New York (“ONE MADISON PARK 3 CONDOMINIUM”). 4 aa. Case number CV 17-4448 DSF (PLAx) United States v. All Rights to 5 and Interests in the Shares of Flywheel Common Stock Held or Acquired by FW Sports 6 Investments LLC (“FLYWHEEL SHARES”). 7 bb. Case number CV 17-4445 DSF (PLAx) United States v.
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