AMENDED RECEIVER’S COMPLAINT PAGE 3
515420 000002 8381650.1
Appointing Receiver entered on March 12, 2009, and July 19, 2010 (the “Receivership Orders”), which are in the Court’s record and incorporated herein by reference. The Receivership Orders authorize the Receiver to,
: [i]nstitute such actions or proceedings to impose a constructive trust, obtain possession, and/or recover judgment with respect to persons or entities who received assets or records traceable to the Receivership Estate. All such actions shall be filed in this Court. Receivership Orders, ¶ 5(c), p. 5. 4.
The Tiger Woods Foundation, Inc. is a nonprofit corporation with its principal place of business located at 121 Innovation Drive, Suite 150, Irvine, California 92617. It may be served with process through its registered agent for service of process in Texas, KPMG, 717 North Harwood Street, Suite 3100, Dallas, Texas 75201. 5.
The Tiger Woods Charity Event Corporation is a nonprofit corporation with its principal place of business located at 121 Innovation Drive, Suite 150, Irvine, California 92617. It may be served with process through its registered agent for service of process, Gregory T. McLaughlin, at 121 Innovation Drive, Suite 150, Irvine, California 92617.
JURISDICTION AND VENUE
This Court has subject-matter jurisdiction over the matters raised by this lawsuit pursuant to 28 U.S.C. § 1367 because this action is ancillary to
SEC v. International Bank, Ltd., et al
See Haile v. Henderson Nat’l Bank
, 657 F.2d 816, 822 (6
Cir. 1981). Moreover, the money transferred to Defendants as described herein constitutes a Receivership Asset, defined in the Receivership Orders as “assets, monies, securities, properties, real and personal, tangible and intangible, of whatever kind and description, wherever located, and the legally recognized privileges (with regard to the entities), of the Defendants and all entities they own or control.” Receivership Orders, ¶ 1, p. 2. This Court assumed exclusive jurisdiction through the
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