Case 2:19-cv-01327 Document 3 Filed 02/22/19 Page 1 of 261 Page ID #:5 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 JOSHUA L. SOHN, Trial Attorney BARBARA LEVY, Trial Attorney 4 Criminal Division United States Department of Justice 5 1400 New York Avenue, N.W., 10th Floor Washington, D.C. 20530 6 Telephone: (202) 514-1263 Email: [email protected] 7 NICOLA T. HANNA 8 United States Attorney LAWRENCE S. MIDDLETON 9 Assistant United States Attorney Chief, Criminal Division 10 STEVEN R. WELK Assistant United States Attorney 11 Chief, Asset Forfeiture Section JOHN J. KUCERA (CBN: 274184) 12 MICHAEL R. SEW HOY (CBN: 243391) Assistant United States Attorneys 13 Asset Forfeiture Section 312 North Spring Street, 14th Floor 14 Los Angeles, California 90012 Telephone: (213) 894-3391/(213) 894-3314 15 Facsimile: (213) 894-0142 Email: [email protected] 16 [email protected] 17 18 Attorneys for Plaintiff UNITED STATES OF AMERICA 19 20 UNITED STATES DISTRICT COURT 21 FOR THE CENTRAL DISTRICT OF CALIFORNIA 22 WESTERN DIVISION 23 UNITED STATES OF AMERICA, No. CV 19-1327 24 Plaintiff, 25 VERIFIED COMPLAINT FOR v. FORFEITURE IN REM 26 27 Up To $28,174,145.52 In Huntington [18 U.S.C. § 981(a)(1)(A) and (C)] National Bank Escrow Account Number 28 ’7196; Up To $1,148,739.35 In Barclays [I.R.S.] Case 2:19-cv-01327 Document 3 Filed 02/22/19 Page 2 of 261 Page ID #:6 1 Bank Of Delaware Account Number 2 ’6111; And Up To $162,486.88 In Fidelity Investments, Inc. Account 3 Number ’9340 4 Defendants. 5 6 7 The United States of America brings this complaint against the above-captioned 8 assets and alleges as follows: 9 PERSONS AND ENTITIES 10 1. The plaintiff is the United States of America. 11 2. The defendants in this action are: (1) up to $28,174,145.52 in escrow 12 account number ‘7176 held by escrow agent Squire Patton Boggs (US) LLP at 13 Huntington National Bank; (2) up to $1,148,739.35 in account number ‘6111 held in the 14 name of Christopher Joey McFarland at Barclays Bank of Delaware; and (3) up to 15 $162,486.88 in account number ‘9340 held in the name of Christopher Joey McFarland 16 at Fidelity Investments, Inc., all of which being traceable to equity in COMPANY 1, a 17 facilities management company headquartered in Newport, Kentucky (“DEFENDANT 18 ASSETS”). 19 3. The persons and entities whose interests may be affected by this action are 20 Riza Shariz Bin Abdul Aziz, Christopher Joey McFarland, Nina Partners, LLC, Red 21 Granite Investment Holdings, LLC, and Red Granite Pictures, LLC. 22 4. Contemporaneously with the filing of this complaint, plaintiff is filing 23 related action seeking the civil forfeiture of the following assets (collectively, the “NEW 24 SUBJECT ASSETS”). 25 a. RED MOUNTAIN PROPERTY: Real property located in London, 26 United Kingdom1 titled in the name of Red Mountain Global Ltd., including all 27 28 1 Pursuant to L.R. 5.2-1, residential addresses are listed by the city and state only. 2 Case 2:19-cv-01327 Document 3 Filed 02/22/19 Page 3 of 261 Page ID #:7 1 appurtenances, improvements, and attachments thereon, as well as all leases, rents, and 2 profits derived therefrom. 3 b. OCEANA 57 FUNDS: $5,407,252.87 in funds constituting the net 4 proceeds from the sale of real property in New York, New York that was titled in the 5 name of Oceana 57 LLC until it was sold on or about August 9, 2018. 6 5. Plaintiff has previously filed the following complaints, seeking civil 7 forfeiture of the following assets (referred collectively, together with the NEW 8 SUBJECT ASSETS, as the “SUBJECT ASSETS”): 9 a. Case number CV 16-5362 DSF (PLAx), United States v. The Wolf of 10 Wall Street Motion Picture, Including any Rights to Profits, Royalties and Distribution 11 Proceeds owed to Red Granite Pictures, Inc. or its Affiliates and/or Assigns (“THE 12 WOLF OF WALL STREET”). 13 b. Case number CV 16-5368 DSF (PLAx), United States v. The Real 14 Property Known as The Viceroy L’Ermitage Beverly Hills (“the L’ERMITAGE 15 PROPERTY”). 16 c. Case number CV 16-5369 DSF (PLAx) United States v. All Business 17 Assets of The Viceroy L’Ermitage Beverly Hills, Including All Chattels and Intangible 18 Assets, Inventory, Equipment, and All Leases, Rents and Profits Derived Therefrom 19 (“THE L’ERMITAGE BUSINESS ASSETS”). 20 d. Case number CV 16-5377 DSF (PLAx) United States v. Real 21 Property located in Beverly Hills, California (“HILLCREST PROPERTY 1”). 22 e. Case number CV 16-5371 DSF (PLAx) United States v. Real 23 Property Located in New York, New York (“PARK LAUREL CONDOMINIUM”). 24 f. Case number CV 16-5367 DSF (PLAx) United States v. One 25 Bombardier Global 5000 Jet Aircraft, Bearing Manufacturer’s Serial Number 9265 and 26 Registration Number N689WM, its Tools and Appurtenances, and Aircraft Logbooks 27 (“BOMBARDIER JET”). 28 3 Case 2:19-cv-01327 Document 3 Filed 02/22/19 Page 4 of 261 Page ID #:8 1 g. Case number CV 16-5374 DSF (PLAx) United States v. Real 2 Property Located in New York, New York (“TIME WARNER PENTHOUSE”). 3 h. Case number CV 16-5378 DSF (PLAx) United States v. Real 4 Property located in Los Angeles, California (“ORIOLE MANSION”). 5 i. Case number CV 16-5375 DSF (PLAx) United States v. Real 6 Property Located in New York, New York (“GREENE CONDOMINIUM”). 7 j. Case number CV 16-5364 DSF (PLAx) United States v. Any Rights 8 to Profits, Royalties and Distribution Proceeds Owned by or Owed to JW Nile (BVI) 9 Ltd., JCL Media (EMI Publishing Ltd), and/or Jynwel Capital Ltd, Relating to EMI 10 Music Publishing Group North America Holdings, Inc., and D.H. Publishing L.P., Inc. 11 and D.H. Publishing L.P. (“EMI ASSETS”). 12 k. Case number CV 16-5370 DSF (PLAx) United States v. All Right to 13 and Interest in Symphony CP (Park Lane) LLC, Held or Acquired, Directly or 14 Indirectly, by Symphony CP Investments LLC and/or Symphony CP Investments 15 Holdings LLC, Including Any Interest Held or Secured by the Real Property and 16 Appurtenances Located at 36 Central Park South, New York, New York, Known as The 17 Park Lane Hotel, Any Right to Collect and Receive Any Profits and Proceeds 18 Therefrom, and Any Interest Derived From the Proceeds Invested in The Symphony CP 19 (Park Lane) LLC by Symphony CP Investments LLC and Symphony CP (Park Lane) 20 LLC (“SYMPHONY CP (PARK LANE) LLC ASSETS”). 21 l. Case number CV 16-5376 DSF (PLAx) United States v. United States 22 v. Real Property Located in New York, New York (“WALKER TOWER 23 PENTHOUSE”). 24 m. Case number CV 16-5379 DSF (PLAx) United States v. Real 25 Property located in Beverly Hills, California (“LAUREL BEVERLY HILLS 26 MANSION”). 27 28 4 Case 2:19-cv-01327 Document 3 Filed 02/22/19 Page 5 of 261 Page ID #:9 1 n. Case number CV 16-5366 DSF (PLAx) United States v. one pen and 2 ink drawing by Vincent Van Gogh titled “La maison de Vincent a Arles” (“VAN 3 GOGH ARTWORK”). 4 o. Case number CV 16-5366 DSF (PLAx) United States v. One painting 5 by Claude Monet titled “Saint-Georges Majeur” (“SAINT GEORGES PAINTING”). 6 p. Case number CV 16-5366 DSF (PLAx) United States v. 7 €25,227,025.83 Euros held in an escrow account at UBS, S.A. in Switzerland 8 constituting the proceeds of the sale of a painting by Claude Monet titled “Nympheas” 9 (“PETITE NYPMHEAS PROCEEDS”). 10 q. Case number CV 16-5380 DSF (PLAx) United States v Real 11 Property in London, United Kingdom, owned by Qentas Holdings (“THE QENTAS 12 TOWNHOUSE”). 13 r. Case number CV 17-4240 DSF (PLAx) United States v. Real 14 Property in London, United Kingdom owned by Stratton Street (London) Ltd. (“THE 15 STRATTON PENTHOUSE”). 16 s. Case number CV 17-4242 DSF (PLAx) United States v. Real 17 Property in London, United Kingdom owned by Seven Stratton Street (London) Ltd. 18 (“STRATTON FLAT”). 19 t. Case number CV 17-4244 DSF (PLAx) United States v. Real 20 Property in London, United Kingdom owned by Eight Nine Stratton Street (London) 21 Ltd. (“STRATTON OFFICE BUILDING”). 22 u. Case number CV 17-4438 DSF (PLAx) United States v. Certain 23 rights To and Interests In The Viceroy Hotel Group. (“THE VICEROY HOTEL 24 GROUP ASSETS”). 25 v. Case number CV 17-4439 DSF (PLAx) United States v. All rights To 26 and Interests In The Motion Pictures “Daddy’s Home” and “Dumb and Dumber To,” 27 Belonging to red Granite Pictures. (“DUMB AND DUMBER TO RIGHTS” and 28 “DADDY’S HOME RIGHTS”). 5 Case 2:19-cv-01327 Document 3 Filed 02/22/19 Page 6 of 261 Page ID #:10 1 w. Case number CV 17-4441 DSF (PLAx) United States v. All Right and 2 title to the Yacht M/Y Equanimity. (“THE EQUANIMITY”). 3 x. Case number CV 17-4446 DSF (PLAx) United States v. Certain 4 Rights to and Interests in Shares of Series D Preferred Stock in Palantir Technologies 5 (“PALANTIR STOCK”). 6 y. Case number CV 17-4440 DSF (PLAx) United States v.