Case 2:20-cv-05911 Document 1 Filed 07/01/20 Page 1 of 280 Page ID #:1 1 DEBORAH CONNOR, Chief Money Laundering and Asset Forfeiture Section (MLARS) 2 MARY BUTLER, Chief, International Unit WOO S. LEE, Deputy Chief, International Unit 3 BARBARA Y. LEVY, Trial Attorney JOSHUA L. SOHN, Trial Attorney 4 JONATHAN BAUM, Trial Attorney Criminal Division 5 United States Department of Justice 1400 New York Avenue, N.W., 10th Floor 6 Washington, D.C. 20530 Telephone: (202) 514-1263 7 Email: [email protected] 8 Attorneys for Plaintiff 9 UNITED STATES OF AMERICA 10 UNITED STATES DISTRICT COURT 11 FOR THE CENTRAL DISTRICT OF CALIFORNIA 12 13 UNITED STATES OF AMERICA, No. CV 20-5911 14 Plaintiff, VERIFIED COMPLAINT FOR 15 v. FORFEITURE IN REM 16 REAL PROPERTY LOCATED IN [18 U.S.C. § 981(a)(1)(A) and (C)] 17 PARIS, FRANCE TITLED IN THE 18 NAME OF AVE RAPHAEL (PARIS) [F.B.I.] SCI, 19 20 Defendant. 21 The United States of America (the “government”) brings this complaint against 22 the above-captioned asset and alleges as follows: 23 PERSONS AND ENTITIES 24 1. The plaintiff is the United States of America. 25 2. The defendant in this action is real property located in Paris, France1 titled 26 in the name of Ave Raphael (Paris) SCI, including all appurtenances, improvements, and 27 28 1 Pursuant to L.R. 5.2-1, residential addresses are listed by the city and state only. Case 2:20-cv-05911 Document 1 Filed 07/01/20 Page 2 of 280 Page ID #:2 1 attachments thereon, as well as all leases, rents, and profits derived therefrom, as more 2 particularly described in Attachment A (“DEFENDANT ASSET”). 3 3. The persons and entities whose interests may be affected by this action are 4 Low Taek Jho, Low Hock Peng, Goh Galk Ewe, Low Taek Szen, Low May Lin, Ave 5 Raphael (Paris) SCI, Ave Raphael (Paris) Ltd, Ave Raphael (Paris) Partner Ltd, and Ave 6 Raphael (Paris) Trust. 7 4. Contemporaneously with the filing of this complaint, plaintiff is filing 8 related actions seeking the civil forfeiture of the following assets (collectively, the 9 “NEW SUBJECT ASSETS”). 10 a. BASQUIAT DRAWING: One colored crayon, black felt tip pen, 11 and acrylic drawing on Arches wove paper with “JMB” initialed on the reverse side, 12 entitled “Self-Portrait” by Jean-Michel Basquiat. 13 b. WARHOL PORTRAIT: One gold paint and silkscreen ink portrait 14 on canvas, entitled “Round Jackie” by Andy Warhol. 15 c. CAMPBELL’S SOUP CAN AND VÉTHEUIL AU SOLEIL 16 PAINTINGS: One acrylic, spray paint, and silkscreen ink on linen painting entitled 17 “Colored Campbell’s Soup Can (Emerald Green), 1965” by Andy Warhol and one oil 18 on canvas painting entitled “Vétheuil au Soleil” by Claude Monet. 19 d. VASCO AND EAGLE STRATEGIC FUNDS: All funds on 20 deposit in account number ‘0610 held by Vasco Investments Services SA at Bank 21 Privée Edmond de Rothschild (“Bank Rothschild”) in Luxembourg, and all funds on 22 deposit in account number ‘1751 held by Eagle Strategic Investment Fund (B) at Bank 23 Rothschild in Luxembourg. 24 e. RIVER DEE FUNDS: All funds and assets, including securities and 25 investments, on deposit in account numbers ‘6001 and ‘6001.1001 held by River Dee 26 International SA at Falcon Private Bank Limited ("Falcon Bank") in Switzerland. 27 28 2 Case 2:20-cv-05911 Document 1 Filed 07/01/20 Page 3 of 280 Page ID #:3 1 5. Plaintiff has previously filed the following complaints, seeking civil 2 forfeiture of the following assets (referred collectively, together with the NEW 3 SUBJECT ASSETS, as the “SUBJECT ASSETS”): 4 a. Case number CV 16-5362 DSF (PLAx), United States v. The Wolf of 5 Wall Street Motion Picture, Including any Rights to Profits, Royalties and Distribution 6 Proceeds owed to Red Granite Pictures, Inc. or its Affiliates and/or Assigns (“THE 7 WOLF OF WALL STREET”). 8 b. Case number CV 16-5368 DSF (PLAx), United States v. The Real 9 Property Known as The Viceroy L’Ermitage Beverly Hills (“the L’ERMITAGE 10 PROPERTY”). 11 c. Case number CV 16-5369 DSF (PLAx) United States v. All Business 12 Assets of The Viceroy L’Ermitage Beverly Hills, Including All Chattels and Intangible 13 Assets, Inventory, Equipment, and All Leases, Rents and Profits Derived Therefrom 14 (“THE L’ERMITAGE BUSINESS ASSETS”). 15 d. Case number CV 16-5377 DSF (PLAx) United States v. Real 16 Property located in Beverly Hills, California (“HILLCREST PROPERTY 1”). 17 e. Case number CV 16-5371 DSF (PLAx) United States v. Real 18 Property Located in New York, New York (“PARK LAUREL CONDOMINIUM”). 19 f. Case number CV 16-5367 DSF (PLAx) United States v. One 20 Bombardier Global 5000 Jet Aircraft, Bearing Manufacturer’s Serial Number 9265 and 21 Registration Number N689WM, its Tools and Appurtenances, and Aircraft Logbooks 22 (“BOMBARDIER JET”). 23 g. Case number CV 16-5374 DSF (PLAx) United States v. Real 24 Property Located in New York, New York (“TIME WARNER PENTHOUSE”). 25 h. Case number CV 16-5378 DSF (PLAx) United States v. Real 26 Property located in Los Angeles, California (“ORIOLE MANSION”). 27 i. Case number CV 16-5375 DSF (PLAx) United States v. Real 28 Property Located in New York, New York (“GREENE CONDOMINIUM”). 3 Case 2:20-cv-05911 Document 1 Filed 07/01/20 Page 4 of 280 Page ID #:4 1 j. Case number CV 16-5364 DSF (PLAx) United States v. Any Rights 2 to Profits, Royalties and Distribution Proceeds Owned by or Owed to JW Nile (BVI) 3 Ltd., JCL Media (EMI Publishing Ltd), and/or Jynwel Capital Ltd, Relating to EMI 4 Music Publishing Group North America Holdings, Inc., and D.H. Publishing L.P., Inc. 5 and D.H. Publishing L.P. (“EMI ASSETS”). 6 k. Case number CV 16-5370 DSF (PLAx) United States v. All Right to 7 and Interest in Symphony CP (Park Lane) LLC, Held or Acquired, Directly or 8 Indirectly, by Symphony CP Investments LLC and/or Symphony CP Investments 9 Holdings LLC, Including Any Interest Held or Secured by the Real Property and 10 Appurtenances Located at 36 Central Park South, New York, New York, Known as The 11 Park Lane Hotel, Any Right to Collect and Receive Any Profits and Proceeds 12 Therefrom, and Any Interest Derived From the Proceeds Invested in The Symphony CP 13 (Park Lane) LLC by Symphony CP Investments LLC and Symphony CP (Park Lane) 14 LLC (“SYMPHONY CP (PARK LANE) LLC ASSETS”). 15 l. Case number CV 16-5376 DSF (PLAx) United States v. United States 16 v. Real Property Located in New York, New York (“WALKER TOWER 17 PENTHOUSE”). 18 m. Case number CV 16-5379 DSF (PLAx) United States v. Real 19 Property located in Beverly Hills, California (“LAUREL BEVERLY HILLS 20 MANSION”). 21 n. Case number CV 16-5366 DSF (PLAx) United States v. one pen and 22 ink drawing by Vincent Van Gogh titled “La maison de Vincent a Arles” (“VAN 23 GOGH ARTWORK”). 24 o. Case number CV 16-5366 DSF (PLAx) United States v. One painting 25 by Claude Monet titled “Saint-Georges Majeur” (“SAINT GEORGES PAINTING”). 26 p. Case number CV 16-5366 DSF (PLAx) United States v. 27 €25,227,025.83 Euros held in an escrow account at UBS, S.A. in Switzerland 28 4 Case 2:20-cv-05911 Document 1 Filed 07/01/20 Page 5 of 280 Page ID #:5 1 constituting the proceeds of the sale of a painting by Claude Monet titled “Nympheas” 2 (“PETITE NYPMHEAS PROCEEDS”). 3 q. Case number CV 16-5380 DSF (PLAx) United States v Real 4 Property in London, United Kingdom, owned by Qentas Holdings (“THE QENTAS 5 TOWNHOUSE”). 6 r. Case number CV 17-4240 DSF (PLAx) United States v. Real 7 Property in London, United Kingdom owned by Stratton Street (London) Ltd. (“THE 8 STRATTON PENTHOUSE”). 9 s. Case number CV 17-4242 DSF (PLAx) United States v. Real 10 Property in London, United Kingdom owned by Seven Stratton Street (London) Ltd. 11 (“STRATTON FLAT”). 12 t. Case number CV 17-4244 DSF (PLAx) United States v. Real 13 Property in London, United Kingdom owned by Eight Nine Stratton Street (London) 14 Ltd. (“STRATTON OFFICE BUILDING”). 15 u. Case number CV 17-4438 DSF (PLAx) United States v. Certain 16 rights To and Interests In The Viceroy Hotel Group. (“THE VICEROY HOTEL 17 GROUP ASSETS”). 18 v. Case number CV 17-4439 DSF (PLAx) United States v. All rights To 19 and Interests In The Motion Pictures “Daddy’s Home” and “Dumb and Dumber To,” 20 Belonging to red Granite Pictures. (“DUMB AND DUMBER TO RIGHTS” and 21 “DADDY’S HOME RIGHTS”). 22 w. Case number CV 17-4441 DSF (PLAx) United States v. All Right and 23 title to the Yacht M/Y Equanimity. (“THE EQUANIMITY”). 24 x. Case number CV 17-4446 DSF (PLAx) United States v. Certain 25 Rights to and Interests in Shares of Series D Preferred Stock in Palantir Technologies 26 (“PALANTIR STOCK”). 27 y. Case number CV 17-4440 DSF (PLAx) United States v. One 28 Metropolis Poster (“METROPOLIS POSTER”). 5 Case 2:20-cv-05911 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.