Case 2:16-cv-05362 Document 1 Filed 07/20/16 Page 1 of 136 Page ID #:1 M. KENDALL DAY, Chief Asset Forfeiture and Money Laundering Section (AFMLS) MARY BUTLER Chief, International Unit WOO S. LEE Deputy Chief, International Unit KYLE R. FREENY Trial Attorney Criminal Division United States Department of Justice 1400 New York Avenue, N.W., 10th Floor Washington, D.C. 20530 Telephone: (202) 514-1263 Email: EILEEN M.

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DECKER United States Attorney LAWRENCE S. MIDDLETON Assistant United States Attorney Chief, Criminal Division STEVEN R. WELK Assistant United States Attorney Chief, Asset Forfeiture Section JOHN J. KUCERA (CBN: 274184) CHRISTEN A. SPROULE (CBN: 310120) Assistant United States Attorneys Asset Forfeiture Section 312 North Spring Street, 14th Floor Los Angeles, California 90012 Telephone: (213) 894-3391/(213) 894-4493 Facsimile: (213) 894-7177 Email: Attorneys for Plaintiff UNITED STATES OF AMERICA UNITED STATES DISTRICT COURT FOR THE CENTRAL DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. “THE WOLF OF WALL STREET” MOTION PICTURE, INCLUDING ANY RIGHTS TO PROFITS, ROYALTIES AND DISTRIBUTION PROCEEDS No.

CV VERIFIED COMPLAINT FOR FORFEITURE IN REM 18 U.S.C. §§ 981(a)(1)(A) & (C) [F.B.I.] 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 28 Case 2:16-cv-05362 Document 1 Filed 07/20/16 Page 2 of 136 Page ID #:2 OWED TO RED GRANITE PICTURES, INC.

OR ITS AFFILIATES AND/OR ASSIGNS, Defendant. The United States of America brings this complaint against the above-captioned asset and alleges as follows: PERSONS AND ENTITIES 1. The plaintiff is the United States of America. The defendant in this action is “The Wolf of Wall Street” Motion Picture, Including any Rights to Profits, Royalties and Distribution Proceeds owed to Red Granite Pictures, Inc.

Or its Affiliates and/or Assigns, (hereinafter, the “Defendant Asset”), more particularly described in Attachment A. Bebe Stores. The Defendant Asset is held by Red Granite Pictures, Inc.

The persons and 4. Entities whose interests may be affected by this action are listed in Attachment A. Contemporaneously with the filing of this complaint, plaintiff is filing related actions seeking the civil forfeiture of the following assets (collectively, the “SUBJECT ASSETS”): a. THE L’ERMITAGE PROPERTY: All right and title to the real property commonly known as 9291 Burton Way, Beverly Hills, California 90210, including the L’Ermitage Hotel (“L’ERMITAGE PROPERTY”), including all appurtenances, improvements, and attachments thereon. THE L’ERMITAGE BUSINESS ASSETS: All assets related to the L’ERMITAGE PROPERTY, including but not limited to all chattels and intangible assets, inventory, and equipment (“L’ERMITAGE BUSINESS ASSETS”), including any and all funds in accounts owned, held or maintained at financial institutions by LBH Real Estate, or for the benefit of LBH Real Estate or the L’ERMITAGE 2 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 28 Case 2:16-cv-05362 Document 1 Filed 07/20/16 Page 3 of 136 Page ID #:3 PROPERTY, and all leases, rents, and profits derived from said business.

Collectively herein, the L’ERMITAGE PROPERTY and the L’ERMITAGE BUSINESS ASSETS are referred to as, “L’ERMITAGE.” c. HILLCREST PROPERTY 1: All right and title to the real property located in Beverly Hills, California1 owned by 912 North Hillcrest Road (BH), LLC (“HILLCREST PROPERTY 1”), including all appurtenances, improvements, and attachments thereon, as well as all leases, rents, and profits derived therefrom. PARK LAUREL CONDOMINIUM: All right and title to the real property located in New York, New York owned by Park Laurel Acquisition LLC (“PARK LAUREL CONDOMINIUM”), including all appurtenances, improvements, and attachments thereon, as well as all leases, rents, and profits derived therefrom. BOMBARDIER JET: All right and title to Bombardier Global 5000 aircraft bearing manufacturer serial number 9265 and registration number N689WM, with two Rolls Royce engines bearing manufacturer’s serial numbers 12487 and 12488 (“BOMBADIER JET”), including all appurtenances, improvements, and attachments thereon, all aircraft logbooks, and all leases, rents, and profits derived therefrom.