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Table Of Contents

CRIMINAL PROCEEDING
Entities Affiliated with Beracha
THE FRAUDULENT SCHEME
I. ILLARRAMENDI’S NETWORK OF ENTITIES AND FUNDS
II. THE GENESIS OF THE FRAUD
III. “OFF-THE-BOOKS” BANK ACCOUNTS
IV. THE “PERMUTA” MARKET
THE TRANSACTIONS CONCERNING BERACHA AND HIS AFFILIATED ENTITIES
I. Beracha and his Entities Benefit Twice from Sale of EDC Notes
II. Beracha and Northwestern Benefit from Money Advanced by Fractal
III. Beracha, BM Financial and the 2007 PDVSA Trade, Part I
IV. Beracha, BM Financial and the 2007 PDVSA Trade, Part II
V. PDVSA Subscription in SOF
VI. SOF Payments to Beracha Entities
VII. Netvalue Strategy’s Consulting Fee
VIII. Fractal’s $10,000,000 Investment in the Master Fund
IX. Beracha Entities Invest $26,000,000 in the Master Fund
X. $30,000,000 in Promissory Notes Through Rowberrow
XI. SOF/Fractal Loan and Investment Transactions
XII. 4% Kickback for a $40,000,000 Investment
XIII. Investments in the Master Fund
XIV. Beracha Bond Transaction with the Master Fund and Related Fees
XV. Subscriptions in MKV
XVI. $20,000,000 Promissory Note
XVII. $25,000,000 Promissory Note and Redemption
XVIII. Rowberrow’s Receipt of $25,000,000 Promissory Note at 12%
XIX. $15,000,000 Credit Linked Note
XX. Rowberrow Receives $6,669,049
The 2011 Collapse
THE TRANSFERS
CLAIMS BY CERTAIN DEFENDANTS
THE ONGOING INVESTIGATION
FIRST CAUSE OF ACTION CUFTA SECTION 52-552E(A)(1) (ACTUAL FRAUD)
SECOND CAUSE OF ACTION CUFTA SECTION 52-522E(A)(2) (CONSTRUCTIVE FRAUD)
THIRD CAUSE OF ACTION CUFTA SECTION 52-522F(A) (CONSTRUCTIVE FRAUD)
FOURTH CAUSE OF ACTION COMMON LAW FRAUDULENT TRANSFER
FIFTH CAUSE OF ACTION UNJUST ENRICHMENT
SIXTH CAUSE OF ACTION CONVERSION
SEVENTH CAUSE OF ACTION CONSTRUCTIVE TRUST
EIGHTH CAUSE OF ACTION ACCOUNTING
NINTH CAUSE OF ACTION AIDING AND ABETTING BREACH OF FIDUCIARY DUTY
BAKER & HOSTETLER LLP
P. 1
PDVSA Ponzi Receiver vs Beracha w Exhibit

PDVSA Ponzi Receiver vs Beracha w Exhibit

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Published by: Latin American Herald Tribune on Feb 09, 2012
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