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Janvey Pol Suit

Janvey Pol Suit

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Published by: editorial.online on Feb 22, 2010
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02/13/2014

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ECEIVER 
S
O
RIGINAL
C
OMPLAINTAGAINST
P
OLITICAL
C
OMMITTEES
1
IN THE UNITED STATES DISTRICT COURTFOR THE NORTHERN DISTRICT OF TEXASDALLAS DIVISION
RALPH S. JANVEY, IN HIS CAPACITY ASCOURT-APPOINTED RECEIVER FOR THESTANFORD INTERNATIONAL BANK, LTD.,ET AL.,Plaintiff,v.DEMOCRATIC SENATORIAL CAMPAIGNCOMMITTEE, INC.; NATIONAL REPUBLICANCONGRESSIONAL COMMITTEE; DEMOCRATICCONGRESSIONAL CAMPAIGN COMMITTEE,INC.; REPUBLICAN NATIONAL COMMITTEE;and NATIONAL REPUBLICAN SENATORIALCOMMITTEE,Defendants.§§§§§§§§§§§§§§§§§§Case No. _____________  ________________________________________________________________________ 
RECEIVER’S ORIGINAL COMPLAINT AGAINST POLITICAL COMMITTEES
 ________________________________________________________________________ 
SUMMARY
1.The Court has ordered Receiver Ralph S. Janvey (“Receiver”) to take control of all assets of the Receivership Estate in order to make an equitable distribution to claimantsinjured by a massive fraud orchestrated by Allen Stanford, James Davis, and others.2.The Receiver’s investigation to date reveals that revenue from the sale of fraudulent certificates of deposit generated substantially all of the income for the StanfordDefendants, including Allen Stanford (“Stanford”) and James Davis (“Davis”), the StanfordFinancial Group, and the many related Stanford entities.3.Allen Stanford, James Davis, and the Stanford Financial Group contributed morethan $1.8 million of their ill-gotten gains to a variety of political organizations and candidates.
Case 3:10-cv-00346-F Document 1 Filed 02/19/2010 Page 1 of 14
 
3:10-cv-346
 
ECEIVER 
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OMPLAINTAGAINST
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OLITICAL
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OMMITTEES
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The defendants in this case, the Democratic Senatorial Campaign Committee, Inc.; the NationalRepublican Congressional Committee; the Democratic Congressional Campaign Committee,Inc.; the Republican National Committee; and the National Republican Senatorial Committee(collectively, the “Committee Defendants”), received more than $1.6 million in funds ultimatelytraceable to money investors paid to the Stanford Defendants for the purchase of fraudulentCDs.4.The Committee Defendants did not furnish any consideration whatsoever for thefunds they received from Stanford, Davis, and the Stanford Financial Group. Consequently, theyhave no legitimate right to retain the funds, and the Receiver is entitled to the return of all suchfunds.5.The Receiver has made written requests to the Committee Defendants for returnof these funds, first in February 2009, and again in February 2010. The Committee Defendants,however, have ignored these requests, and, as a result, the Receiver has been forced to file thislawsuit seeking the return of the funds to the Receivership Estate for the benefit of claimants.6.The Receiver seeks an order that: (a) the payments from Stanford, Davis, and theStanford Financial Group to the Committee Defendants constitute fraudulent transfers under applicable law; (b) the payments from Stanford, Davis, and the Stanford Financial Group to theCommittee Defendants are property of the Receivership Estate held pursuant to a constructivetrust for the benefit of the Receivership Estate; (c) the Committee Defendants are liable to theReceivership Estate for an amount equaling the payments they received from Stanford, Davis,and the Stanford Financial Group; and (d) the Receiver is entitled to an award of reasonableattorneys’ fees, costs, and interest.
Case 3:10-cv-00346-F Document 1 Filed 02/19/2010 Page 2 of 14
 
ECEIVER 
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RIGINAL
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OMPLAINTAGAINST
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OMMITTEES
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JURISDICTION & VENUE
7.This Court has jurisdiction over this action, and venue is proper, under Section22(a) of the Securities Act (15 U.S.C. § 77v(a)), Section 27 of the Exchange Act (15 U.S.C.§78aa), and under Chapter 49 of Title 28, Judiciary and Judicial Procedure (28 U.S.C. § 754).8.Further, as the Court that appointed the Receiver, this Court has jurisdiction oveany claim brought by the Receiver to execute his Receivership duties.9.Further, within 10 days of his appointment, the Receiver filed the originalComplaint and Order Appointing the Receiver in 26 United States district courts pursuant to 28U.S.C. § 754, giving this Court
in rem
and
in personam
jurisdiction in each district where theComplaint and Order have been filed, including the District for the District of Columbia.10.This Court has personal jurisdiction over the Committee Defendants pursuant toF.R.C.P. 4(k)(1)(C) and 15 U.S.C. §§ 754 and 1692.
THE PARTIES
11.Plaintiff Ralph S. Janvey, acting in his capacity as Court-appointed Receiver, has been appointed by this Court as the Receiver for the assets, monies, securities, properties, realand personal, tangible and intangible, of whatever kind and description, wherever located, andthe legally recognized privileges (with regard to the entities) of Stanford International Bank,Ltd., Stanford Group Company, Stanford Capital Management, LLC, Robert Allen Stanford,James M. Davis, Laura Pendergest-Hold, Stanford Financial Group, the Stanford FinancialGroup Bldg., Inc., and all entities the foregoing persons and entities own or control (the“Receivership Assets”).12.Defendant Democratic Senatorial Campaign Committee, Inc. is a District of Columbia corporation with its principal office in Washington, D.C.
Case 3:10-cv-00346-F Document 1 Filed 02/19/2010 Page 3 of 14

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