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$OUTHEW DIfSTNCT REPORTERS P.C.

ID # 13-2775946 500 Pearl St Room 330 New York, N.Y. 10007 U.S.A. (2 12) 805-0300

INVOICE

INVOTCE NO. INVOICE DATE

025 1796-IN 06/06/20 12

CUSTOMER NO. Bleaklev.Platt & Schmidt One North Lexington Ave. White Plains, NY 10601 Attention: William H Mulligan WORKORDERNO. SALESPERSON

1000217 121487 Siwik, Christine

Job Date

=ENAN V BOSCO CASE NO. 1lCV08500 Original 28 PGES At 3.120

5/30/20 12

PAYMENT IS DUE UPON RECEIPT OF THIS INVOICE

Net Invoice: Less Discount: Freight: Sales Tax:

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK NEIL F. KEENAN, Individually and as Agent for THE DWGON FAMILY, citizens of foreign states, Plaintiff, 11 CV 8500 (JMF) DANIELE DAL BOSCO, et al., Defendants.
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New York, N.Y. May 30, 2012 3:30 p.m. Before : HON. JESSE M. FURMAN, ~istrictJudge

BLEAKLEY, PLATT & SCHMIDT Attorneys for Plaintiff BY: WILLIAM MULLIGAN, JR. CHRISTOPHER EARL STRUNK, Pro Se Proposed Intervenor

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

(In open court) DEPUTY CLERK: Civ. 8500. Counsel, please state your name for the record. MR. MULLIGAN: Good afternoon, William Mulligan, Jr.,
&

Matter of Keenan versus Dal Bosco, 11

member of the firm of Bleakley, Platt

Schmidt in White

Plains, New York, attorneys for the plaintiff. THE COURT: Good afternoon, Mr. Mulligan. MR. STRUNK: My name is Christopher Earl Strunk, I'm pro se self-represented without being an attorney. I'm a

proposed intervenor and I'm responding to the order of the Court. THE COURT: Good afternoon, Mr. Strunk. Before I get to the motion to intervene, Mr. Mulligan, I read your letter. unusual one. I have reviewed the complaint. It's an

Give me a little bit of a better sense of what

exactly is going on here and what the status is of your efforts, if any, to serve the defendants. MR. MULLIGAN: Yes, your Honor. Did you say you perused the complaint? THE COURT: I can't claim to have read in deep care

every single word, but I certainly read through the complaint and have I sense of what is going on. MR. MULLIGAN: Thank you, Judge. I did the best I

could to satisfy the judge's request for a status report and SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

condensed that on 111 pages and being as straightforward as I could be. Nothing has changed since, your Honor, in that I have not served any of the defendants yet for a variety of reasons. I'm getting reports as recently as 12:48 a.m. this morning. still cannot locate Mr. Dal Bosco or Mr. Sale. We believe Mr. Sale is in Thailand with Defendant Dam, who was the head of the OITC. It's funny now being able to talk about this case after 15 months. And as one of the attorneys said to me, it I

reads more like a screenplay than a complaint, and I said I would take that as a compliment. But we haven't served, Judge. could the reasons why. I set forth as best I

The primary reason is that I can't find

three of these guys. We wouldn't be here if Mr. Dal Bosco hadn't stolen the bonds from my client, Mr. Keenan. And he is on the run, so to speak. I'm still gathering information, Judge. straightforward as I can. I'm being as

Some of it has to do with

jurisdictional issues. And as the months were going by, I

1 said - - I don't want to, for instance, serve the U.N., get a
timetable going there. To be frank, some defendants are going to have defenses which might be more difficult to overcome than others.
I had my eye on the 120 days.

I had my on eye on the

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

last sentence in Rule 4(m) about not applying to foreign defendants, although I realize I may be in the wrong circuit for that. But essentially I have come to the conclusion that the defendants will be served to the extent that I can find them. I believe it is likely that I will have to amend the I

complaint. And I have never been in a situation like this.

never had a case like this, obviously, that I was just waiting for things to happen. My client has been in Indonesia for three months. We

communicate by Skype sometimes, otherwise by e-mail, and I am doing the best I can to try to get this thing off the ground. My concern as the plaintiff, and in light of Rule 4(m), I would rather not have the case discontinued, albeit without prejudice. That's just an inherent defensive tactic, I don't want to have the case discontinued. On other hand, 1'11 be honest, I may well have to amend the complaint, which will start the ball rolling again. I don't think I will have a

statute of limitations problem, because the essential tort here is conversion. until 2013. I think it's three years, and I think I have

I'm being totally frank with you, Judge, what is

going on through my mind. So as I put forth in my letter, my main concern at this point was to appeal to the Court, even though it's not formally presented by motion or anything, by the Court or anyone else, that - - I'm hedging, I am hedging, I admit it, but SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

my primary concern would be maybe to get the Court's permission to have that 120 days extended. I realize it's been extended

by 60 days by fate with the replacement, I understand that. THE COURT: Can I stop you for a second, and I will

get back to the service issues in a few minutes, but before I address those, I had one threshold question which is, as you know, the Court is required to raise sua sponte the question of subject matter jurisdiction where there's any question about it. I have read that portion of your complaint with some care, and I understand that you're claiming subject matter jurisdiction on two grounds, and I wanted you to discuss that in a little bit more detail because it's not clear to me that there is subject matter jurisdiction here. The provision of

the Foreign Sovereign Immunities Act that you cite has a definitional provision defining what a foreign state is for the purposes of the act. You invoke federal common law, but certainly don't cite any authority in support of the proposition that would give rise to subject matter jurisdiction. MR. MULLIGAN: Well, maybe not in the complaint, your Honor, but in our research I do believe that what we have here is the expropriation of United States Federal Reserve notes. If you go on the Federal Reserve - - and I do believe it's uniquely federal interest in that they are notes issued by the SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

federal government - - withdrawn, not the federal government, the Federal Reserve, which is not part of the government. And I think that given that there are perhaps $134.5 billion worth of Federal Reserve notes floating around that have been stolen, that would be subject to the auspices of the Federal Reserve Bank in New York, that this Court, because there are uniquely federal interests involved in the possible black marketing, if you will, of United States Federal Reserve notes, that a federal court, and certainly in New York where the Federal Reserve Bank of New York is located, would have jurisdiction. one of the things I'm going after, Judge, goes to that point. And I can't say I have the affidavit, but I have a draft, which I received as recently as yesterday, and in essence, Judge, what I would be arguing, if that issue were specifically here - - I know you raised it sua sponte, which you're entitled to do, but the argument would be that the Dragon family is the largest single depositor holding assets and counter assets managed by the Federal Reserve Bank of New York. Therefore, illegal use the Dragon family assets such as gold, for which we in turn
--

the I1we1' there, this would be

authored directly from a member of the Dragon family. This is one of the first direct contacts I had from this family. It's

not to me but through my client. He cites to and we would cite SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

C5UTKEEC to the responsibility of the New York Fed, which is to serve as the fiscal agent of the United States for foreign central banks and official international financial organizations. It acts as the primary contact with other foreign central banks. off their web site. THE COURT: This is off the Fed's web site? That part, not the proposed affidavit This is

MR. MULLIGAN:

that I was reading from. And I said proposed, it's not signed, I don't have it, but I'm being as straight as I can with you, Judge. I think that when pressed, if I have to brief it, that I could do a better job than I'm doing right now about explaining the federal common law jurisdiction. THE COURT: I think you'll have to brief that. If you

would prefer to wait for that, I'm happy to let you.

I will

tell you I'm not - - sitting here and without doing any research, I can't tell you I'm inclined to think that the fact that these are Federal Reserve notes alone suffices. Cash, I have a $20 bill here, it says at the top "Federal Reserve note." It would be hard to imagine that a federal court would have subject matter jurisdiction in a case involving the theft of a large amount of cash, or cash regardless of how much of it was involved. So you can address it.
I

MR. MULLIGAN:

I hear you, and it's not totally

unexpected. And I would also like to address the Foreign SOUTHERN DISTRICT REPORTERS, P.C.
(212) 8 0 5 - 0 3 0 0

MR. MULLIGAN:

I realize I may have a few more upon

1

information and belief allegations in my complaint than I started out, but with respect to the role of the Italians - and I would be happy to further that, your Honor, if you're suggesting that you're putting it to me to explain or brief the

I

I
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subject matter jurisdiction, I would like the time to do so and I would be happy to do so. THE COURT: I think there's a serious question going

to the Courtls jurisdiction, so I am going to ask you to brief that. Obviously you proffered two bases for it, you can brief both of those.
I think assuming that the foreign Sovereign

I

I I I II

Immunities Act gives rise to jurisdiction over Italy and Italian officials that you named, I would say you should also address whether that is sufficient - - whether that gives rise to jurisdiction over the whole matter or just with respect to those parties. MR. MULLIGAN: THE COURT:
i

Certainly not all the defendants.

So we'll talk about a timeline for that,

but I think you have to address that.

I I

Now a related matter also going to the Courtls jurisdiction is the fact that the United Nations and Ban Ki-moon are named as defendants here.
I think you probably

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know this, but under the Convention on the Privileges and Immunities of the United Nations, the United Nations itself is immune from ''every form of legal process except insofar as any particular case it has expressly waived its imrn~nity.~~ take I it there has been no waiver here, certainly. MR. MULLIGAN: Certainly not, your Honor. It's an

uphill battle, but I don't think that you can claim sovereign immunity and offer $100 million bribes, whether the U.N. or Ban Ki-moon or anyone else. THE-COURT: My understanding of the convention is pretty basic, that the United Nations itself and Ban Ki-moon may be in different positions in the sense that the United Nations, I understand, is absolutely immune absent a waiver, and the secretary general is immune with respect to acts performed in his function as secretary general. So there may

be room with respect to the secretary general that there isn't with respect to the United Nations. MR. MULLIGAN: Certainly, Judge, it certainly comes as

no surprise that that would be the primary issue on your mind and certainly on the U.N.'s mind if they were served, and that will be an expected argument. THE COURT: So we will get to the schedule on that as

well, but I think I will have you brief the question of whether there is jurisdiction with respect to those defendants and/or give you a date by which you can obtain a waiv@r of their SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

immunity. I find it hard to believe that would be forthcoming. MR. MULLIGAN: THE COURT: I don't think that will happen.

So we'll get back to that.

Again, before we run to the issue of service, I want to address Mr. Strunklsmotion to intervene.
1 understand from

your letter that you oppose the motion and wanted - - well, let me hear from Mr. Strunk first what his interest is in the matter that gives rise to his motion. MR. STRUNK: Thank you, your Honor.
I have been researching the post World War I1

arrangements of the U.S. government and its relationship to the Society of Jesus in particular and the role of de Chardin starting back - - Father de Chardin - - starting back in 2005 for someone who hired me to do a zoning study in Dutchess County which ended up in the River's Keeper program. De Chardin is

buried up there. And his involvement inside China was, other than finding Peking Man and writing The Phenomenology of Man, he dug up graves, and he was involved with the Office of Naval Intelligence in transferring large amounts of gold outside of China through our submarines in 1935 in exchange for Federal Reserve gold bonds, and the monies were transfer to the Federal Reserve Bank on the West Coast. So my own interest in history

and my ability to make money doing zoning research led me into starting to research the history of the Japanese gold settlements after World War I1 and the involvement of OSS. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300
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C5UTKEEC was a Vietnam veteran. And I knew Stephen Solarz, who was involved in removing Ferdinand Marcos from government. with him before his death. I had conversations

He was my Congressman. So that I

was aware of many of the gold transfer problems and the fight over where the buried gold was, and the Imelda Marcos case where I saw the research, the testimony on the part of various OSS officers as to the whereabouts of gold and how Imelda Marcos ended up with the gold from concentration camp victims in Citibank, and there was testimony on that in the late '90s. So I have looked at a lot of this research, looked at court testimony. I looked at Judge Holwellfs decisions on the

matter of which I'm a - - I own two historic gold bonds, one from 1913, 20 pounds, and one from 1942, a gold-based backed bond also. And I read the complaint, I felt there were weaknesses in it, and that since the Federal Reserve was an essential player, its role is to oversee all of the operations in the region that the theft occurred, and that I looked at the agreements between the Securities and Exchange Commission and the Swiss government on what I believe is an ongoing two-sided platform in collateralizing the bonds by the Chinese government, who are the only ones able to use the historic bonds for the purposes of commercial transactions, and that I believe is being done in Switzerland. That was not in the report, but certainly Occam's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

razor, the only logical use of these historical bonds, which they're considerable, is by the red Chinese government inside Switzerland, and that for that interest - - I am interested in the merging of the Taiwan government and the red Chinese government under fair principles in that it appears to me it's not going to happen in that the Chinese are getting both sides of the coin. But I intervene specifically, and I believe that my - if you want to put it criticisms, bringing in the foreign bond holders protection counsel is essential for any bond held by an American or having to do with an American bond holder. They

were set out by Congress in 1933. They're an extension of the United States corporation, which is a corporation in Maryland, not properly up to date, and essentially they are the foreign bond holders corporation of counsel is the front end opera.tion operating as if it were the United States corporation, which is a very unusual when I start doing the research with the Secretary of State in Maryland. But that I feel that there are essential parties here, the foreign bond holders protective counsel who have a duty under treaty arrangements to essentially do an accounting for the use these historical bonds and related bonds which are part of the sinking fund which would guarantee payment in the event that red China should come together with Taiwan I can get paid. And I'm not here to get paid, I'm just here to make sure SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

there's a level playing field and there's a proper accounting of the proceeds which should be protected both by the federal reserve as a party to this transaction going back to 1913 through 1942, and that - THE COURT: Let me stop you for a moment. And I

appreciate all of this, and I appreciate your interest in this matter, as your deep interest in this matter is quite evident. As you may know under the law, in order to intervene in the lawsuit, as opposed to just following it, you have to have some kind of stake in the matter. So to sort of simplify

it, what I'm not entirely understanding from your papers or from your comments now is what you have riding on this other than your interest in it, which I understand to be a deep one. If you can briefly explain that. MR. STRUNK: To the extent that I believe that there's certain mention of the protections necessary to protect the sinking fund which would repay me through a two-sided platform, and that they're using the bonds in order to collateralize, and they don't ever - - they're there, the shadow of money, and to the extent that collateralizing what would be my sinking fund, I have an interest that that the portion of the Dragon family's financial instruments be accounted for by the Federal Reserve, and course the foreign bond holders counsel, which it's their duty under U.S. law to do such. And I'm here just looking out after my interests. And SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

I did serve who I thought were parties to this case with the summons and complaint, the World Economic Forum, Dan Carlo here in New York, he was duly served, the Swiss ambassador was served who had to be given notice in any case that this was going on in his system, and the Italian ambassador was served as well as Mr. Petty and the foreign bond holders counsel and the New York City - - the Federal Reserve Bank of New York along with Bollinger. And I have just - - I'm just interested in all these - if you're going to get involved in something as complicated as this, then because the Chinese have just been given a position with the Federal Reserve, now not only are they using the sinking fund in Switzerland, they're now coming in and using it here in New York by becoming, as the Hong Kong Shanghai Bank was brought in, the red Chinese bank is coming in to run our banking system, and I think these matters should be put before the Court. THE COURT: Thank you, Mr. Strunk. Now back to you, Mr. Mulligan, I'm not going to ask you to address the particular merits at the moment, but I understand you oppose the motion to intervene? MR. MULLIGAN:
'

Yes, your Honor.

I reread your order.

My intent, responding to your request for the information, was that since there had been no return dates set, obviously since I haven't served anybody yet, that I would certainly expect SOUTHERN DISTRICT REPORTERS, P.C.
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that I would oppose it. And I think your Honor hit the main point on the head, and I would anticipate that my argument will be there's just no connection between my case and that case. With all due respect to Mr. Strunk, if he wants to bring a lawsuit, go ahead, but there's no connection. I can't imagine that Rule 24 would be properly invoked here. THE COURT: OK, well, I think - MR. MULLIGAN: THE COURT: But I really haven't briefed it all.

I understand, and I'm going to be giving

you a few assignments today, one of which is to address that. I think it makes sense. You're correct, there was no return date, but it makes sense today to set a briefing schedule and take a brief from you and then allow Mr. Strunk an opportunity to respond if he would like it. That brings us to the issue of service which you started to address before, and I wanted to just return to, number one, can you just help me - - you have referenced the 120 day rule and Rule 4 (m). MR. MULLIGAN: THE COURT: Yes, your Honor.

I want to sort of make sure we're on the

same page as to who is and who isn't subject to that rule. MR. MULLIGAN: Yes, your Honor. By my account, your

Honor - - and I read rule 4(m), the last sentence says what it says, that the 120 day rule does not apply to essentially and 4 (j) service of process overseas, at least under 4 (i') SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

.

It's in my letter. And I read yesterday in this circuit there are plenty of cases, there was an '87 Second Circuit case, but that was under the predecessor to Rule 4(m) which said that you at least have to show that you tried to serve somebody. And that does seem to be the law in this circuit, and it's been cited by many district courts, as opposed to law in some other circuits. And so I recognize that. THE COURT: That's good. Yes.

MR. MULLIGAN: THE COURT:

Let's start by figuring out who is and who

is not subject to 4 (m). MR. MULLIGAN: Eleven of the 14 that I have that I

would argue - - when and if I have to, and if I have to do it now I will do the best I can - - who would not be subject to the 120 day rule automatically would be Dal Bosco. THE COURT: Since the other group seems to be smaller,

why don't you identify for me who you think is subject to - MR. MULLIGAN: I would say World Economic Forum

U.S.A., the U.N., Ban Ki-moon. I'm having trouble reading my own writing here. THE COURT: Why not Cesare Maria Ragaglini? MR. MULLIGAN: Ragaglini I have a question mark.
I

think she has a residence here. THE COURT: What about Giancarlo Bruno?
MR. MULLIGAN:

Well, Bruno I allege, and I think he

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

does have a residence here, so that's a possible.

I consider

him to be a resident of Italy, but that's an arguable point. THE COURT: OK. MR. MULLIGAN: So my eleven might be - - I have three, If I said eleven, I probably

U.N., Ban Ki-moon, Ragaglini. should have ten, your Honor.

THE COURT: And talk to me about the OITC, what exactly that is. MR. MULLIGAN: Well, that's a great question as to what they are. The addresses that they claim are in Kumphawapi

City in Udon Thani , Thailand, and Kampong Karmon (ph), Phnom Penh, Cambodia. There is a web sit which lists an address at 1133 Connecticut Avenue Northwest in Washington DC, also. THE COURT: Do you have reason to doubt that? MR. MULLIGAN: I'm just not sure, Judge, to be honest.

I'm not sure if that's real or not. THE COURT: OK. Is the organization real?

MR. MULLIGAN:

Oh, it's real. They have a web site.

I think that they're a highly questionable organization, but they have certainly been around, and I stand by all the allegations in my complaint concerning them. Ray Dam, who was their leader, has been in and out of jail. He's either in Cambodia or Thailand right now, to the best of my knowledge. Dal Bosco, present whereabouts unknown. Dam, not certain. David Sale, unknown, but possibly in Thailand with Dal Bosco. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

C5UTKEEC OITC we talked about. Giancarlo Bruno. I do have a West End Avenue address for

I will speak with Mr. Strunk, I think he just World Economic Forum U.S.A.,

mentioned that he served him. Inc. at 3 East 54th Street. Sorry, Judge, run through for you what - -

not sure where

going. Should

THE COURT: By my count there are, at least according to your complaint, probably five defendants who have presence in the United States, if not New York: The United Nations, Ban

Ki-moon, Ambassador Ragaglini, World Economic Forum and Giancarlo Bruno. I don't see how any of those five would not

be subject to the 120 day rule. Do you have a different position? MR. MULLIGAN: No, your Honor, I don't. THE COURT: OK. MR. MULLIGAN: I think that would be - - certainly as

to three of them, but looking at my notes here and my own question marks, you're certainly not wrong. THE COURT: OK. And are there others aside from those

five who you would conceive or acknowledge are subject to the 120 day rule? MR. MULLIGAN: THE COURT: No, I don't think so, Judge.

Focusing on those five for the present,

talk about why you have not served them as of now. And by your acknowledgment, I think it is closer to 180 days at this point. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

than 120. MR. MULLIGAN: The reasons I stated in the letter,

Judge, I really didn't want to initiate a piecemeal litigation and have different timetables for all types of different people. We were determined to find Mr. Dal Bosco first. We haven't been able to. I have also felt I probably will have to

amend the complaint, so I took the approach of let's wait, let's see what happens. And if the case is going to be discontinued, I would have rather discontinued it on my own, albeit that the rule also states clearly it's without prejudice, and I would refile. And frankly, I looked forward to coming here today, as

I did two months ago with Judge Holwell, so I could just get to
the bottom of this and see which way - - I admit, it's sort of a hedge. I would like the Court's permission to extend the time

so if's not discontinued, but if it's discontinued, I will regroup and I will refile. And the complaint might be amended or not. It might not be as long, a couple of defendants might

not be included, but this is the first opportunity I have had to sort of bring it to a head, so I appreciate where you're headed. THE COURT: And what steps, if any, have you taken with respect to the foreign defendants to serve them? MR. MULLIGAN:
1 can't find three, as I said, and I

have not physically attempted to serve them. Again, I have SOUTHERN DISTRICT REPORTERS, P.C.
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been taking a wait and see attitude to see when everything was going to come together, waiting for my people to get me more information on whereabouts of Dal Bosco, and when the complaint is served, that everyone is served in reasonably the same period of time so we don't have twelve different schedules going forward. THE COURT: And what about the defendants, other than those three, that is the foreign defendants that you do know where they are? MR. MULLIGAN: Judge, straight out. THE COURT:
OK.

I have not attempted to serve them,

I have to say I appreciate your

concern about not proceeding in a piecemeal fashion. The flip side is I'm not interested in this case remaining on the Court's docket for years and years and years because you're not able to locate a particular defendant and we're waiting for that defendant. MR. MULLIGAN: THE COURT: I understand.
.

I would actually rather hold you to the

rules and hold you to a relatively strict timetable. And to extent that you can comply with that, I will allow it to proceed, and to the extent you can't, you will have to suffer the consequences. But to that end, I mean I guess I haven't previously given you notice that I might dismiss as to the domestic defendants pursuant to Rule 4(m) and giving you an SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

C5UTKEEC opportunity show good cause for failure to serve them. I am

happy to do that now, although in some respects I think you already made your proffer. MR. MULLIGAN: in the letter. I think I have. I attempted to do that

I'm like you, I'm not into playing games with

this, and I'm being as straightforward I can. THE COURT: I will be straight with you, which is I

don't think you have showed me good cause for failure to serve those defendants. I'm happy to give you an opportunity to brief that as well if you want an opportunity to show good cause or persuade me that what you have said - - cite cases showing me that qualifies for a good cause, but you can tell me that you don't want to proceed in that fashion or you can try and persuade me, but at the moment I'm not persuaded. MR. MULLIGAN: I understand that, Judge, and I don't

think - - I could ask for two weeks to try to persuade you, and I don't think it would work because I have nothing more to tell you, straight out, than what I have said either in my letter or here. So to the extent,that I would ask for 60 more days, I take it that would be denied. THE COURT: Correct.

Now let's talk about schedule with respect to the foreign defendants, who I take to be there are 14 defendants total, correct? MR. MULLIGAN: I think so, Judge.

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THE COURT:

So talking about nine. Yes.

MR. MULLIGAN:

THE COURT: Let's talk about how much time you need to locate and serve these defendants. MR. MULLIGAN: THE COURT: I would ask for 60 days, Judge. In your letter you talk about the

OK.

need to go through the Hague Conventions and have things translated and so forth. I would rather give you more time if

you feel that more time is necessary and require you to update me periodically. MR. MULLIGAN: THE COURT: I got a little shy.

Hang on. You tell me how much time you

need, I will give you that time, and in the interim I will ask you to update me on the steps you are taking to locate and serve. I will hold you to that, and if you demonstrate diligence in doing so, so be it, I will give you the time that you ask for now. If you don't, then I will end up dismissing So

for failure to prosecute and failure to serve in the time. I want you to - MR. MULLIGAN: THE COURT: Under Rule 4, without prejudice.

Correct.

I want you to be realistic. You know about more these defendants than I do. Needless to say, I don't think Italy is hard to locate. I don't think Silvio Berlosconi is hard to locate. I don't think the Italian Financial Police are hard to SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

C5UTKEEC locate. There may be practical considerations with serving those entities, but you tell me. MR. MULLIGAN: I will stick with the 90 days I asked

for in my letter rather than the 60. THE COURT: Meaning that you're OK if I set a deadline

of 90 days from today to serve those defendant? MR. MULLIGAN: To serve those defendants. And so I understand, as to the domestic defendants, the case is discontinued? THE COURT: I am going to dismiss as to the five

defendants who I believe, based on your complaint, have a presence. I'm not going to dismiss as to the United Nations

because I think the United Nations is in a different position, and I strongly suspect that I will dismiss to them as to different grounds. But I will dismiss as to the other four defendants who are subject to the 120 day rule by your concession, that is Giancarlo Bruno, World Economic Forum U.S.A., Cesare Maria Ragaglini and Ban Ki-moon, for failure to serve within 120 days and failure to show good cause for that failure. That is pursuant to Rule 4(m), and pursuant to that rule is obviously without prejudice. MR. MULLIGAN: Then the 90 days or the same thing

would occur with respect to the foreign defendants? THE COURT: 90 days or the same thing will occur with

respect to the remaining defendants. Obviously you're entitled SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

to make a case that you have good cause td the additional time. I'm going to ask you in 45 days to submit a letter to the Court apprising me of what steps you have taken to locate and serve the defendants to demonstrate that you are exercising due diligence throughout the period, and I will expect in that letter that you will have exercised due diligence in that regard. MR. MULLIGAN: Yes, your Honor. THE COURT: I think that takes care of the service

issues. Let's set a briefing schedule first on the motion to intervene. Mr. Mulligan, how much time do you need to file a memorandum of law opposing the motion to intervene? MR. MULLIGAN: THE COURT: Friday, June 29 . MR. MULLIGAN: OK. Could I ask for 30 days, Judge?

30 days from - - I will give you until

THE COURT: And then Mr. Strunk, I will give you an memorandum. By opportunity to respond to Mr. Mu1ligan.l~ June 29 he will file memorandum with the Court and serve a copy on you. You can discuss with him how best to do that, and then I will give you four weeks after that to file something in response, so by July 27. MR. STRUNK: That's generous, thank you. THE COURT: So that will deal with that issue. And

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

then Mr. Mulligan, the last remaining issue is the question of subject matter jurisdiction. How about I give you the same period of time until June 29 to file memorandum on that. MR. MULLIGAN: That's fine.

THE COURT: And just so we're clear on what to address in that, I would like you to address the question of whether the Court has subject matter jurisdiction in general, over the entire case that is, and specifically as well whether there is subject matter jurisdiction with respect to the United Nations in the absence of a waiver of immunity. And if by that time you are able to obtain a waiver of immunity, obviously that would be one way to address that issue, but in the absence of a waiver, your memorandum of law should address what the subject matter jurisdiction is with respect to the United Nations. Are we clear on that?
I

MR. MULLIGAN:

Yes.

THE COURT: Anything else that we need to deal with? MR. MULLIGAN: On the Foreign sovereign Immunities

Act, do you also want me to - THE COURT: As I understand, you are premising subject matter jurisdiction for the Court on the Foreign Sovereign Immunities Act and federal common law. MR. MULLIGAN: THE COURT: Correct.

Your memorandum of law should address both

of those issues and also address specifically the question of SOUTHERN DISTRICT REPORTERS, P.C. (212) 8 0 5 - 0 3 0 0

whether there is jurisdiction over the United Nations either by obtaining a waiver, or in the absence of a waiver, why the absolute immunity of the United Nations doesn't deprive the Court of jurisdiction. MR. MULLIGAN: THE COURT: things. OK.

Let me give you some page limits and

On the subject matter jurisdiction memorandum I will On the motion to intervene,

give you up to 25 pages.

Mr. Mulligan, I will give you 20 pages. And Mr. Strunk I will give you the same 20 pages to respond, and I think that's all I need to do on that front. MR. MULLIGAN: OK.

MR. STRUNK: Your Honor, is that single or double? THE COURT: Double spaced. MR. STRUNK: All right. Judge Rakoff normally discussed single. THE COURT: No, I prefer double spaced, sir. Then I am going schedule another conference for - Mr. Strunk, you don't need to show up unless the motion to intervene has been granted, but to discuss the issues of service. 90 days from today would be - - why don't we set it for right after Labor Day. That gives you a few days beyond the 90 days. That is not to say that that deadline is changed,

but just our next appearance will be right after Labor Day. September 4th at 3:00 p.m. And again, Mr. Strunk, no need for SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

you to appear unless your motion has been granted, but you're obviously welcome, the Court is open to the public. Anything further for today? MR. MULLIGAN: It occurs to me, Judge, thinking out

loud, in light of the dismissal as to the domestic defendants, that may cause me to more seriously consider more quickly filing an amended complaint, which might moot - - I will advise your Honor. Does is that sound right to you, if I amend the complaint, the 120 days would start all over again, as I understand? THE COURT: Well, let's take it a step at a time. You

can look into that. You're welcome to amend the complaint if you like, and if, based on your research, that triggers another 120 days, so be it. I don't think it moots the question of

subject matter jurisdiction, so that brief should be filed - MR. MULLIGAN: Understood. THE COURT:
- - by the deadline that we set.

MR. MULLIGAN: Understood. THE COURT: It doesn't moot the issue of intervention,

so that should also be filed. MR. MULLIGAN: Understood, Judge. THE COURT: It may obviously bring the defendants - -

the five defendants who are present in this country back into the matter, in which case we'll address those as we do, but I think I have made it clear that I'm not interested in letting SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

this thing linger on the Court's docket, and I expect you to proceed diligently with respect to all defendants, those who are subject to the 120 days and those who are not. In that

regard, if you determine that filing an amended complaint brings them back in it, don't assume you can wait to serve those defendants simply because there are other defendants you haven't located. OK? MR. MULLIGAN: Yes, sir. THE COURT: Anything further for today? MR. MULLIGAN: I don't think so.

THE COURT: Mr. Strunk, anything further? MR. STRUNK: Thank you for hearing us. THE COURT: Thank you. We are adjourned. 000

SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300

Case 1:'1 4-cv-08508-JMF Document 6

Filed 051

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

......................................................................

X

NEIL F. KEENAN, individzially and as agent for the Dragon family, citizens of foreign states, Plaintiff,

1 1 Civ. 8500 (JMF)
NOTICE OF INITIAL PRETRIAL CONFERENCE

-vDANIELE DAL BOSCO, et al., Defendants.

JESSE M. FUIPMAN, District Judge: Plaintiff Neil F. Keenan brings this action seeking monetary and equitable relief against Defendants. Plaintiff filed his Complaint on November 23, 201 1. Service of process has not been effectuated upon any of the Defendants, On January 25,2012, Christopher Earl Strunk filed a motion to intervene as a plaintiff in this matter. By letter dated May 11,2012, Plaintiff Keenan indicated to the Court that he intends to oppose this motion. It is hereby ORDERED that counsel for all parties and proposed intervenor Strunk appear for an initial pretrial conference with the Court on May 30,2012 at 3:30 p.m. in Courtroom 26A of the United States District Court for the Southern District of New York, 500 Pearl Street, New York, New York. A11 counsel are required to register promptly as filing users on ECF. All pretrial conferences must be attended by the attorney who will serve as principal trial counsel. SO ORDERED.

Dated: May 15,2012 New York, New York ~nked States District Judge

Notice Maiied To: Christopher Earl Strunk 593 Vanderbilt Avenue #281 Brooklyn, NY 11238

BLEAKLEY PLATT SCHMIDT, & LLP
9 1 4.287.61 3 1 WMULLIGAN@BPSLAW.COM
WHITE P L A I N S , N E W YORK

10601

91 4 . 9 4 9 . 2 7 0 0 FAX: 9 1 4 . 6 8 3 . 6 9 5 6
BPSLAW.COM

May 11,2012
Via E-mail

Hon. Jesse M. Furman United States District Judge Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 1000'7-13 12

Re:
Dear Judge Furman:

Keenan v. Dal Bosco, et al. 11 Civ 8500

We represent the plaintiff, Neil F. Keenan in this matter. This letter is submitted in accord with Your Honor's Order of April 26,2012. This will confirm that there are no currently scheduled conferences or oral arguments with the Court. As the Court is aware, after the filing of this action by the undersigned on November 23,20 11, the Initial Scheduling Conference was scheduled on January 13,2012 to be held on March 9,2012. Further, on account of the resignation of the Assigned Judge, Richard J. Holwell, that conference was adjourned sine die by Order dated March 2,2012. 1. I am counsel of record for plaintiff and there has been no change from the information contained in the Docket. As service of process has not been effectuated upon any of the defendants, no record appearances have been filed by any other counsel, except that a motion to Intervene was filed in early January 20 12 (see fiuther discussion under subparagraph 5). The complaint is comprised of 111 pages and the following is a good faith effort to condense that volume into a "brief statement of the nature of the case" in accordance with the Court's most appropriate directive. This case asserts 12 causes of action seeking monetary and equitable relief against a variety of international persons andlor entities, including a foreign government (Italy) and agencies, as well as the United Nations ("UN"), the Office of International Treasury Control ("OITC"), and the World Economic Forum ("WEF"). The action arises initially from the expropriation and conversion of certain negotiable financial instruments

2.

Hon. Jesse M. Furman May 11,2012 Page 2 lawfully owned by the Dragon Family, a highly secretive and informal organization that operates between old families within China and Taiwan. These instruments, the majority of which are comprised of 249 1934 Series Federal Reserve Notes, with a total face value of $124.5 Billion, are referenced in the complaint as the "DFFI," short for Dragon Family Financial Instruments. Plaintiff Keenan, a U. S. Citizen who resides in Bulgaria, had been entrusted with the DFFI between January and May 2009 by virtue of written Special Powers of Attorney, by which he was authorized to coordinate the investment of the DFFI for appropriate humanitarian investment programs. Subsequently, Keenan was introduced to defendant Daniele Dal Bosco, who, at the time, resided in Italy, and who, after months of intermittent companionship and travel with Keenan in furtherance of Keenan's legally authorized objectives, gained his trust to such a degree that Keenan granted custodianship of the DFFI to Dal Bosco in Switzerland in September 2009. Dal Bosco acknowledged his custodianship in writing. Regrettably, over the ensuing months, Dal Bosco conspired in various ways with other defendants, notably David Sale, OITC and the UN, by which he abused his role as custodian and exerted domination and control over the DFFI to the exclusion of Keenan, including his participation in bribe offers to Keenan to relinquish control over the DFFI. As set forth in great detail in the Complaint, the defendants variously participated as conspirators, andlor aiders and abettors of the fraud and conversion and expropriation of the DFFI. Mr Dal Bosco has refused to return the DFFI, despite due demand therefore, and the whereabouts of the DFFI, at the time of filing the lawsuit, and continuing to the present, remains unknown 3. There are no existing deadlines or cut-off dates. However, as the Court is aware, under Federal Rule 4 (m), if a defendant is not served within 120 days after the complaint is filed, "the court - on motion or on its own after notice to the plaintiff - must dismiss the action without prejudice against that defendant or order that service be made within a specified time, subject to the provision that if the plaintiff shows good cause for the failure, the Court must extend the time for an appropriate period." Notably, however, as the Rule pertains to the facts and defendants in this case, the 120 day rule in subdivision (m) does not apply to service in a foreign country under Rule 4(f) (Serving an individual in a foreign country) or 4 (j)(l) (a foreign state or its political subdivision, agency or instrumentality). (See further discussion under subdivision 10). By our calculation, no less than eleven (1 1) of the fourteen (14) named defendants in this case are located in a foreign country and subject to such service

Hon. Jesse M. Furman May 11,2012 Page 3 abroad. 4. See discussion above - original conference set for March 9,2012 adjourned. I submit that any matters that might have been discussed at that time are presently set forth in this letter. As reflected on the Docket Sheet (ECF Document #3), on or about January 5,20 12, Christopher Earl Strunk filed a motion to Intervene as a plaintiff as of right under Fed R. Civ. P. 24(a) as "an American Chinese historic Bond holder on the day and month in 2012, at a time and courtroom designated by the court." In his supporting affidavit, Mr. Strunk also seeks alternative relief under Fed. R. 24 (b) for permissive intervention and attaches a proposed supplemental complaint naming the Federal Reserve Bank of New York and others as required supplemental defendants. Given that issue has not been joined as to any defendant, no action has been taken with respect to this motion. If and when such motion is officially scheduled by the Court, it would be plaintiffs intent to oppose the motion as we see no claimed interest by the proposed Intervenor which in any way relates to the property or transaction which is the subject of plaintiff Keenan's complaint, or in any way implicates the provisions of Rule 24. The foregoing is stated with all due respect to the merits of such independent claims propounded by Mr. Strunk. There are no pending appeals. There has been no discovery undertaken to date. There have been no settlement discussions between or amongst any of the parties. It would be very difficult at this juncture to estimate the length of any trial. We believe this case presents novel factual issues and has potentially enormous national and international economic repercussions. We also represent that the decision to date not to have formally served the complaint has been conscious and deliberate and do not assert that any meaningful effort has been undertaken to effectuate service. We submit, however, that such decision has been made entirely in good faith for various reasons, including without limitation, the following: (a) it became apparent within a short time after filing this lawsuit that additional, largely historical information, which would bolster plaintiffs claims and repudiate certain anticipated defenses, would be forthcoming. We remain

5.

6.

7.
8.

9. 10.

Hon. Jesse M. Furman May 11,2012 Page 4 positive in that regard although much of that information, emanating from sources outside the United States, remains outside the possession of counsel; (b) the whereabouts of the person who might be deemed the primary defendant in this action, certainly the original tortfeasor, whose theft triggered the lawsuit, the aforesaid Daniele Dal Bosco, remains unknown, as confirmed by a report received earlier this week; (c) the whereabouts of defendant David Sale has apparently been in an active state of flux, and again, as reported earlier this week, have obtained what might be a good address; (d) the location of defendant Ray C. Dam has also been problematical and although he appears to be resident in Cambodia, Cambodia and Thailand, the two alleged locations of defendant OITC, do not appear to be signatories to the Hague Convention, thus further complicating what federal and New York state cases have traditionally found to be the cumbersome duties normally associated with service under the Hague convention'; (e) service upon the World Economic Forum, based in Switzerland, does not allow service by mail and process would necessarily implicate the Central Authority with requisite Hague Forms and the Complaint possibly subject to translation into French and served through Swiss authorities; (f) service upon the Italian defendants, including former President Silvio Berlusconi, may require translation of the complaint into Italian although Italy does allow service by mail. In short, in light of the fact that the majority of the defendants named in this lawsuit are foreign entities not subject to the 120 day rule, and further in light of the fact that for the sake of judicial convenience and with a desire to avoid piecemeal litigation with widely disparate times to answer, move or otherwise engage in discovery, we respectfully suggest that the Court, in the exercise of its discretion, allow an additional 90 days to effectuate service upon the defendants within the parameters of Rule 4 (m). We respectfully offer this suggestion as it would avoid any possible discontinuance, albeit without prejudice, as against the United Nations, Ban Ki-moon and WEF USA defendants (those three (3) of the defendants who are located in New York City), and I submit, would be without prejudice to any of the parties. Further, in light of the possibility, indeed likelihood, of the need to amend the complaint, it would be our goal to
1 Recently the 3rd Department ruled that article 10 (a) of the Hague Convention permits service of process by mail, allowing the plaintiff in that case to serve Canadian defendantspursuant to the applicable Vehicle and Traffic Law. By its Decision, the 3rdDept. shifted course and joined with precedent established in the Second and Fourth Departments. The decision noted a similar division among federal circuit courts of appeal, and adopted the reasoning of the Second Circuit. NYS Thruway Authority v. Fenech, 938 N.Y.S. 2d 654,656 (3rdDept., 2012).

Hon. Jesse M. Furman May 11,2012 Page 5 attempt to effectuate service upon all parties with the same pleading (amended or not) and within the same relative time frame. We do not believe any prejudice would be suffered by any defendants as, if the case is in fact discontinued without prejudice by the Court, or voluntarily by plaintiff, an amended complaint will subsequently be filed.

I am available at any time at the convenience of the Court to answer any questions the Court may have about any of the foregoing.
Respectfully,

William Hughes Mulligan, Jr.

COMMITTEEON THE BUDGET

March 13,2012 The Honorable Gene L. Dodaro Comptroller General of the United States U.S. Government Accountability Office 441 G Street, NW Washington, D.C. 20548 Dear Mr. Dodaro: We write to request that the Government Accountability Office (GAO) conduct a complete and accurate inventory of all U.S. government holdings of all Republic of China (ROC) sovereign bonds issued between January 1,1900 and December 31,1949, whether considered to be in default or not. We expect this accounting to include but not be limited to the Departments of State, Justice and Treasury. In an era when sovereign debt obligations are critical, the U.S. government should recognize all of its creditor relationships. From 1900 to 1949 the Chinese government issued hundreds of millions of dollars in sovereign debt-most notably, a large tranche of £25,000,000 issued at 5 percent in 1913. Backed by the full faith and credit of the Chinese government, these bonds were sold to investors in the United States, Japan and Europe by international banks, primarily HSBC and Deutsche Bank, and were widely acquired by both banks and governments. The most prevalent Americanheld bond is the aforementioned 1913 Chinese Government Five Percent Reorganization Gold Loan Bearer Bond, which matured in 1960. Printed on these bonds is the following statement: "[Tlhese obligations are intended to be biding upon the Government of China and any successor government." Despite this pledge, in 1938 the government selectively defaulted on these bonds, leaving millions of global creditors unpaid. Following the announcement by the ROC that it could no longer service its national debts in the beginning of 1938 due to the Japanese invasion, the government began issuing new bonds denominated in U.S. currency in April of 1938 and continuing through 1940. Some of these bonds carried a 27-year maturity date. The Republic of China pledged its intentions to resume payment, but when the Communist Party overthrew the government in 1949, the new People's Republic of China (PRC) selectively refused to recognize or honor the bond obligations of the governments it succeeded. In the case of the debt owed to the United Kingdom, however, the PRC settled its obligations in 1987.

PRIMEDON RECYCLED PAPER

We are concerned that the U.S. government may hold a substantial portion of these bonds and, like more than 20,000 private U.S. investors, is entitled to remuneration. With this in mind, we ask the GAO to determine: 1. The overall number of Chinese sovereign bonds held, or previously held, by the U.S. government or any of its authorized associates or affiliates; 2. The various types of Chinese sovereign bonds held, or previously held, by the U.S. government or any of its authorized associates or affiliates; 3. The cumulative value (in 2012 USD figures) of these bonds. Thank you for your assistance in this matter. If you have any questions, please do not hesitate to contact us. Sincerely,

Zkf47~
ARD . R CE Member of Congress Member of Conmess
I

Member of Congress

FRANK R. WOLF

*-R.O~

STEVE PEARCE Member of Congress

Member of Congress

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NEIL F KEENAN*I . ~ and ahl Agtnt for ~ u THE DRAGON FAMILY, dtizcns o foreign states, f By BLEAKLEY PLATT & SCHMDT*LLP W d b m H. MuUigm, Jr. (WM2945) Jus.tin M. Gardner (JMG 6 169) One North kcington Avenue - . White Plains, New Ymk 10601
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FEDERAL RESERVE BANK OF NEW YORK, by LEE C. BOLLINGER, Chairman 33 Liberty St. New York, NY 10045 FOREIGN BONDHOLDERS PROTECTIVE COUNCIL INC, by JOHN R . PETTY principal; 90 Broad Street New York, NY 10004-2205 GIANCARLO BRUNO. individuallv. and a s Head of the

DANIELE DAL BOSCO, a citizen of a foreign state, THE OFFICE OF INTERNATIONAL TREASURY CONTROL, a foreign corporation ("OITC"), A C. RY DAM ("DAM"), individually, and a s President of OITC, DAVID A. SALE ("SALE"), individually, and a s Deputy Chief of the Council for the Cabinet of OITC H.E. Ambassador Marcello Spatafora Del Consolato Generale d'Italia a New York 690, Park Avenue New York, NY 10065 Attention: H.E. Ambassador CESARE MARIA RAGAGLINI, Individually, and a s Permanent Representative of the Italian Mission to the UN in New York, H.E. Ambassador LAURA MIRACHIAN, Individually, and a s Permanent Representative of the Italian Mission to the UN in Geneva, the ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE, Former Prime Minister of Italy, SILVIO BERLUSCONI, BAN KI-moon, individually, and a s Secretary General of the UNITED NATIONS United Nations Headquarters Room GA- 1B-57 New York - NY 10017 Consulate General-Switzerland 633 3rd Ave # 30, New York. NY 10017

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .X .................................

NEIL F. KEENAN, Individually and as Agent for THE DRAGON FAMILY, citizens of foreign states, Plaintiff,

11-CV-8500 (RJH)

-againstDANIELE DAL BOSCO, a citizen of a foreign state, THE OFFICE OF INTERNATIONAL TREASURY CONTROL, a foreign corporation ("OITC"),RAY C. DAM ("DAM"),individually, and as President of OITC, DAVID A. SALE ("SALE"),individually, and as Deputy Chief of the Council for the Cabinet of OITC, the UNITED NATIONS, BAN KI-moon, individually, and as Secretary General of the UN, H.E. Ambassador CESARE MARIA RAGAGLINI, Individually, and as Permanent Representative of the Italian Mission to the UN in New York, H.E. Ambassador LAURA MIRACHIAN, Individually, and as Permanent Representative of the Italian Mission to the UN in Geneva, the ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE, Former Prime Minister of Italy, SILVIO BERLUSCONI, THE WORLD ECONOMIC FORUM ("WEF")a foreign corporation, WORLD ECONOMIC FORUM U.S.A., INC., GIANCARLO BRUNO, individually, and as Head of the Banking Industry of WEF, and various unknown individual co-conspirators, JOHN DOES A-2, Defendants.
.................................. ................................. X

Christopher-Earl Strunk in esse Affidavit in Support of the Notice of Motion to Intervene as of right

STATE OF NEW YORK
COUNTY OF KINGS

)

1

1 -.

Accordingly, I, Christopher Earl Sbunk, being duly sworn, depose and say under penalty of perjury:
1) Petitioner, Christopher-Earl: Sbunk, in esse (hereinafter, "Strunk" "Petitioner"),

a m self represented without an attorney, and make this affidavit in support of

Strunk's Supplement to the Complaint Page 1 of 15

intervention as of right with Federal Rules of Civil Procedure (FRCvP) Rule 24(a) as an American Chinese historic Bond holder Intervener-Plaint@ and or 2) That as an alternative this affidavit in support of intervention with permission with FRCvP Rule 24 (b) (l)(B)(2) (A) (B), in that FEDERAL RESERVE BANK OF NEW YORK (FRBNY) by LEE C. BOLLINGER, its Chairman and President as well as the FOREIGN BONDHOLDERS PROTECTIVE COUNCIL INC (FBPC) by its principal JOHN R. PETTY are required supplemental Defendants, as shown and explained in the Proposed Supplement with three (3) supplemental causes of action added to the Complaint fded 11123111 annexed herewith, are necessary parties to clar* the

transactions and injuries alleged by Plaintiffs that without same would infringe upon Petitioner's rights and property. 3) That Strunk is the bearer of unredeemed "Historic" Chinese Bond property effected by the failure of the Mainland Peoples Republic of China (PRC ) to re-unite with the Republic of China (ROC) also known as Taiwan; and that Strunk owns ONE
(1)S20 CHINESE GOVERNMENT FlVE PER CENT REORGANIZATION GOLD LOAN OF 1913 FOR S25,000,000 STERLING with serial number 41 1339 (see Exhibit A) (herein

after known as "S20 Bond), and ONE (1)$20 NATIONAL GOVERNMENT OF THE REPUBLIC OF CHINA ALLIED VICIDRY U S DOLLAR LOAN of 1942 with serial number 0064833 payable in accordance with the regulation of October 31, 1953 with semiannual interest at 4% per annum (see Exhibit B) (herein after known as "$20 Bond); and that as a point of valuation reference the combined accrued current $932,848.36 value of the obligations is estimated to be for:
a) the $20 Bond equal to 4.705882 troy ounces o gold or $97.27 in 19 13 Bond f

now valued at say 561.2966 boy ounces of gold or based upon the

1110112

London PM Gold Price Fixing of $1637 per ounce say $918,842.46; and then

Strunk's Supplement to the Complaint Page 2 of 15

b) the $20 Bond equal to 0.5714 troy ounces of gold or $20.00 in 1942 Bond now valued at say 8.5558 boy ounces of gold or based upon the PM Gold Price Fixing of $1637 per ounce say $14,005.90. 4) That Strunk's historical bonds involve lawful money previously recorded and presently discoverable as part of a sinking fund under a double-bookkeeping regimen used by the Defendant FRBNY and auditable by the FBPC with fiduciary duties. 5) That although Plaintiffs' DFFI property does not coincide with any S20 Bond or $20 Bond similar to Strunk's property, based upon information and belief the DFFI is nevertheless part of the sinking fund or reserve created to re-pay the S20 Bond or $20 Bond denomination similar to Sbunk's property when the PRC and ROC re-unite; and therefore, the disposition of the DFFI is germane and a direct interest to Sbunk. 6) That Petitioner, with the intent not to duplicate matters already settled, searched for cases with details coinciding with the basis for intervention herein including those cases disposed in this District by the Honorable Richard J. Holwell; and that Petitioner found three cases: BALANOS u ROC SDNY 06-CW- 1322 1 (RJH), MORRIS V R O C SDNY 05 Civ. 4470 (RJH), and a more current case fded in the Northern District of California, TAIWAN C M L RIGHTS LlTIGATION ORGANIZATION u. KUOMINZANG BUSINESS MANAGEMENT COMM17TEE et a1 NDCA 10-cv-00362- VRW. 7) As to the three cases searched as germane other than important material facts and fmdings that would apply herein supporting intervention do not preclude Petitioner intervention as a matter of first impression before this Court.
8)

1110112 London

That in the case TAIWAN C M L RIGHTS LlTIGATION ORGANIZATION u.

KUOMINZANG BUSINESS MANAGEMENT COMM17TEE et a1 NDCA 10-cv-00362- VRW I

Strunk's Supplement to the Complaint Page 3 of 15

found an affidavit of the Chinese

- US

Historical Bond Expert CHENG CHUNG-MO(11,

(see Exhibit C) that applies in support of Petitioner motion to intervene. 9) That according to Chinese - US Historical Bond Expert CHENG CHUNG-MO, in the affidavit shown as Exhibit C, Article 63 of the Act Governing Relations Between

Peoples Of The Taiwan Area And The Mainland Area states:
"To the extent not contrary to the public order or good morals of the Taiwan Area, it shall be upheld the legal effects of any civil matter together with any right or obligation thereof created in the Mainland Area, prior to the coming into force of this Act, between any people of the Taiwan Area and Mainland Area, or between any two or more of the people of the Mainland Area, or between any of the people of the Mainland Area and any foreign national. The provisions of the preceding paragraph shall not apply provided that there had been laws or regulations in effect, prior to the coming into force of this Act, restricting the exercise or transfer of the rights referred to therein. The following debts shall not be repaid prior to national unification: Outstanding foreign currency bonds issued in the mainland prior to 1949 and the short-term Gold Bonds of 1949. Various debts owed by any government bank as well as any other fmancial institution accepting deposits before their retreat ti-om the Mainland." 10) That according to the Chinese
- US

Historical Bond Expert CHENG CHUNG-MO

regarding to Article 63 of the Act Governing Relations Between Peoples Of The Taiwan

Area And The Mainland Area shown a s Exhibit C:
"This act was promulgated and amended as stated above by Presidential Order on October 29, 2003 and implemented from March 1,2004 by the Order of the Executive Yuan during my term of office as Vice President of the Republic of China Judicial Yuan. "The intent of this Act in regards to pre 1950 Chinese bonds was to reaffirm their Existence as defaulted foreign debt obligations of the Republic of China owed in the United States and elsewhere and to defer their resolution until

Grand Justice and Vice President of the Republic of China Judicial Yuan 1999-2006, Minister of Justice of the Republic of China 1998-1999, and as a law professor in Taiwan and as a visiting professor at the University of Vienna and Wisconsin. Judicial Yuan is the Republic of China's highest judicial organ tasked with interpreting the Constitution of the Republic of China. Holds LL.D. from the University of Vienna and worked many years as a Law Professor including the position of Chairman of the Law Department of National Chung-Hsing University.
Strunk's Supplement to the Complaint Page 4 of 15

national unification, "These bonds referred to in Article 6 3 were all issued by the former Kuomintang Government of the Republic of China or were ratified by the Kuomintang government. "Kuomintang business holdings are worth billions of US dollars as part of the "black gold system of Kuomintang nepotism corruption and cronyism. "The issue of defaulted pre 1950 bonds is inexorably tied to the Kuomintang and its Assets in that the Kuomintang has been the main beneficiary of that default. "Until approximately I991 , the Kuomintang and the Government of the Republic of China were one and the same entity. With the election o f Chen Shuibian as President of the republic of China in 2000, for the first time the Republic of China was governed by a party other than the Kuomintang and the Kuomintang entirely ceased to be an organ or agent of the state. However, the Kuomintang apparatus typified by the Kuomintang Business Management Committee retained billions of dollars of assets accumulated while the Kuomintang was an organ of the Republic of China ti-om 1926 to 1991. It is entirely plausible that the proceeds, sinking funds, and other benefits of the pre 1950 defaulted bonds referenced in Article 63 have been retained by the Kuomintang Business Management Committee to this day. 'While Article 6 3 defers overall settlement of the bonds until the issue of Mainland China is dealt with, it does not preclude legal actions for unjust enrichment against the Kuomintang which is now a non sovereign juridical entity."
11) That Strunk contends that in light of the facts in the Complaint associated

with the DFFI and FRN, FRBNY policy and procedure as well as the Foreign Securities Act of 1933 under which FBPC has fiduciary duties and Article 63 of the Act Governing

Relations Between Peoples Of The Taiwan Area And The Mainland Area, the S20 Bond
or $20 Bond denomination similarly include Strunk's property and are part of the assets secured by Plaintiffs' claim against Defendants that involve money of exchange also involve "theproceeds, sinking funds, and other benefits of the pre 1950 defaulted

bonds referenced in Article 63 have been retained by the Kuomintang Business Management Committee to this d a g that reasonably would include Plaintiffs as well in
such private bansaction(s) with subject securities to form a two-sided market platform

Strunk's Supplement to the Complaint Page 5 of 15

to monetize debt in Switzerland as a transaction defmed under what would be a pendant action with New York State's "Blue Sky L a f l in New York as well as effecting eventual repayment and or the guarantee here in New York. 12) That according to the Complaint during the course of its existence over the last century, the Dragon Family has accumulated great wealth by having provided the Federal Reserve Bank and the United States Government with asset assignments of gold and silver via certain accounts held in Switzerland, for which it has received consideration in the form of a variety of Notes, Bonds and Ceficates such as those

described in Complaint paragraph 2 that are an Obligation of Defendant FRBNY and Federal Reserve System. 13) That according to the Complaint upon information and belief, these Bonds have values ranging in the many Thousands of Trillions of United States Dollars, a relatively small portion of which is involved in the claims giving rise to this action. Each of these currencies, such as the DFFI

/ FRN involved in this action, was and remains duly

registered within the Federal Reserve System and are directly verifiable by the Federal Reserve through its efficient verification system and screening process 14) That Petitioner contends that Plaintiff Keenan as Disclosed Principal of the Dragon Family admit that their relationship is identical with the Kuomintang Business Management Committee as "the Kuomintang appointed guardians of this Gold and the securities issued by the United States who came to be known euphemistically as the Dragon Family. The Dragon Family is, in fact, a highly secretive and informal organization that operates between old families within China and Taiwan, above the political divide of the two independent Chinese Governments." 15) Petitioner contends that based upon information and belief, The Dragon Family and Defendants seek a Two-side Market Platform in Switzerland to monetize debt obligations in association with interests of SMOM, CFR and Vatican that effects

Strunk's Supplement to the Complaint Page 6 of 15

Strunk's historic bond assets. 16) That Petitioner contends that Defendants are attempting to comingle DFFI and FRN in a Two-side market platform in Switzerland to monetize EU ECB obligations with Strunk's asset. 17) That Petitioner contends that based upon information and belief there is a

M e m o r a n d u m of Understanding of August 3 1, 1982 (see Exhibit D) between the
Securities Exchange Commission of the United States and the Swiss Government regarding non-public securities trading that would investigate a Two-side market platform in Switzerland to monetize EU ECB debt obligations and or transact risk based investments effecting Strunk's assets.
18) Petitioner contends based upon the Complaint that named Defendants have

proffered an effort to utilize Plaintiffs' DFFI

/ FRN asset by such action involve

supplement defendants thereby effecting Strunk's assets. 19) That Petitioner contend based upon the Complaint that in light of the facts associated with the DFFI and FRN as well as FRBNY policy and procedures, Plaintiffs' claim against Defendants involve money of exchange not credit involving money of account means that lawful money was and is or probably would be disbursed by either side in a covered transaction even using a platform of a two-side market transactions to monetize the DFFI

/ FRN would be a covered transaction to be accounted for to

preserve Strunk's historic Bond sinking fund as the reserve for re-payment. 20) That Petitioner contends based upon the Complaint that the FRBNY and Lee C. Bollinger by mis-administration and neglect have placed Strunk's repayment at risk. 2 1) That Petitioner contends he has a direct interest in the DFFI, FRN and related funds. 22) That Petitioner contends that the International Operations of the FRBNY

Strunk's Supplement to the Complaint Page 7 of 15

represents the Federal Reserve System and the U.S. Treasury, also is responsible for intervening in foreign exchange markets to achieve dollar exchange rate policy objectives and to counter disorderly conditions in foreign exchange markets. Such transactions are made in close coordination with the U.S. Treasury and Board of Governors, and most often are coordinated with the foreign exchange operations of other central banks. Dollars are sold in exchange for foreign currency if the goal is to counter upward pressure on the dollar. If the objective is to counter downward pressure, dollars are purchased through the sale of foreign currency. 23) Petitioner contends based upon the public record that the responsibility of the FRBNY, as a private entity, is to serve as fiscal agent in the United States for foreign central banks and official international fmancial organizations. It acts as the primary contact with other foreign central banks. The services provided for these institutions include the receipt and payment of funds in U.S. dollars; purchase and sale of foreign exchange and Treasury securities; and the storage of monetary gold. 24) That Petitioner contends based upon the Complaint that the FRBNY and Lee C. Bollinger, FBPC and J o h n R. Petty by nonfeasance are parties to fraud, breach of contract and replevin action in that the Expropriation and Conversion under Federal Common Law and international law are under there auspice. 25) That Petitioner contends based upon the Complain that failure of FRBNY and Lee C. Bollinger, FBPC and J o h n R. Petty to perform duties and obligations would take Strunk's property. 26) That Petitioner contends based upon the Complaint that FBPC is an essential party herein because the FBPC was formed under the Foreign Bondholders Act of 1933 (15 USC 577bb through 577hh with law) at the request of the United States Secretary of State, the Secretary of the Treasury and the Chairman of the Federal

Strunk's Supplement to the Complaint Page 8 of 15

Trade Commission under President Franklin Roosevelt as a private, non-profit corporation to protect the rights and interests of American holders of foreign defaulted bonds. The FBPC has been involved in over 40 settlements between American bondholders and defaulted foreign governments, the most recent being Poland (1975), Hungary (1975), Bulgaria (1978), and Czechoslovakia (1984).The FBPC records are maintained in the Library Archives of Stanford University. 27) That Petitioner contends based upon the Complaint that FRBNY and Bollinger duties and responsibilities are in part to safeguard the use of the Federal Reserve Notes (FRNs) issued as a result of the transfer of the Gold ti-om the ROC; and 28) That Petitioner contends based upon the Complaint and public record that the FRBNY and its agents are active interveners into the fmancial matters of the European Union (EU) and the European Central Bank (ECB) in that Defendants have expropriated and attempt to convert the DFFI and FRNs thereby effecting both the degree of fmancial intervention by Defendant FRBNY and the safety of Strunk's direct interest in the disposition of the sinking fund and or reserve ti-om which to re-pay the historical bonds 29) That Petitioner contends that the historical bonds involve lawful money previously recorded and presently discoverable as part of a sinking fund under a double-bookkeeping regimen used by the Defendant FRBNY and auditable by the FBPC with fiduciary duties. 30) Furthermore, that according to a mutually acceptable Federal Reserve Bank expert on double bookkeeping standards and procedures of the Defendant FRBNY. 3 1) That Petitioner contends based upon the history and ongoing facts detailed in the Complaint that Defendants activities are associated and coordinated with the Aragon Templars, Society of Jesus, Jesuit General Nicholas control over transactions

Strunk's Supplement to the Complaint Page 9 of 15

and directed outcomes of members of the SMOM, CFR, and FRBNY pose a threat to the repayment of Strunk's assets; and in that regard 32) Petitioner provides herein the supporting Aftidavit of Eric J o n Phelps who as an expert on the Society of J e s u s before and after the 1540 Council of Trent in their activities globally (see Exhibit E) that presents allegation to warrant that members of the SMOM and CFR involved in the matter herein be restrained ti-om a direct involvement in the relief fashioned herein. 33) That in support of restraint of members of the SMOM and CFR under the Aragon Templars having shaped events and transactions complained of herein effecting China and Asia with and that now effect the events and outcome of this

instant action were an accounting not conducted of the sinking fund and reserves, Mr.
Phelps a f f i s an abbreviated history of the Jesuit Company involvement in Asia since no later than the bull Dominus ac Redemptor Noster, was to forever suppress and extinguish the Society of Jesus starting at paragraph 22 of the Supporting Affidavit for Intervention shown as Exhibit E quote:
22..In 1773 Pope Clement XIV issued his infamous bull Dominus ac Redemptor Noster, forever suppressing and extinguishing the Society of Jesus. As did Pope Clement V with the crusading Order of the Knights Templars, so did Pope Clement XIV with the crusading Order of the Society of Jesus---the New Knights Templars. At about this time, the Manchu dynasty (1644-1912) expelled the Company from China. In the future, the Manchus would pay dearly for this, Jesuit vengeance to result in the termination of the dynasty a n d the destruction of patriotic Chinese nationalism. 23. The Order fled for protection to non-Catholic nations. Embraced by Catherine I1 "the Great" of "heretic" Orthodox Russia, by Frederick I1 "the Great" of "heretic" Lutheran Prussia and by George I11 of "heretic" Anglican England, the sons of Loyola launched their war on the Vatican. Founding the Illuminati in 1776, they ignited the French Revolution leading to the Napoleonic Wars and the secret killing of Pope Pius VI while punishing the papacy a n d the Roman Catholic monarchs of Europe for suppressing the Society of Jesus. Roman Catholic Freemason Napoleon Bonaparte I was the Company's "Great Avenger." 24. In 1798 Napoleon invaded Malta. Advised by Jesuit Abby Sieyes, he confiscated all the weapons and treasures of the Knights of Malta to be used for his invasion of Egypt in the punishment of the Mamluks for driving the Knights Templars from Acre in 1291. Napoleon then drove the Knights of Malta to Russia, there to submit to terms of the

Strunk's Supplement to the Complaint Page 10 of 15

acting Jesuit General. From then on, the Knights of Malta would never again resist the Society of J e s u s . Today, the Knights of Malta control the central banks of the world along with the cartel-capitalist private banks, such a s Bank of America, JPMorganJChase a n d Citibank. 26..Upon the Order's international restoration in 1814 by Pope Pius VII, the Company began to regain its lost power. Directing the British Crown a n d influencing the American presidency, the Jesuits sought to create a united Anglo-American alliance to be used to conquer first J a p a n and then China. At this time both J a p a n and China had expelled the Company a n d vowed never to readmit their traitorous oppressors. 27. In 1841, via British influence of the First Opium War (1839-1842),the Chinese Manchus were forced to readmit the Jesuits into the Empire. In 1854 the Jesuits used the American Navy with Commodore Perry finally to open u p J a p a n to the White Protestant nations of the West---especially Jesuit-ruled Great Britain. The Jesuit General's old plan was still inexistence: Conquer China through J a p a n using her Emperor and military power now to be backed by the British Crown under Jesuit rule. 28..The Jesuits were legally readmitted into J a p a n in 1865. Emperor Komei stoutly resisted lifting "the Christian Ban" for which he was poisoned in 1867 a t the young age of thirty-six. That same year Tokugawa Shogon Yoshinobu resigned giving his office to the new Emperor Meiji then only fourteen years of age. Meiji "the Great" would serve his Jesuit masters for over forty-five years, centralizing all power in Tokyo and creating the Japanese Imperial Empire---for the use of the Jesuit Order. Japanese nationalists opposing the Meiji regime would be finally defeated in battle, massacred with American gatling guns in 1877. 30..The Society of J e s u s began to use its "Japanese Sword of the Church" against the QingJManchu dynasty of China also ruling Korea. In 1894 J a p a n launched and, in 1895, won the first Sino-Japanese War taking Korea a n d Taiwan away from China while forcing the QingJManchu government to pay 13,600 tons of silver to J a p a n for war reparations. That same year Japanese agents of Jesuit-ruled Emperor Meiji brutally assassinated anti-Japanese, pro-Chinese Korean Empress Myeongseong. The surviving crown prince sought and received protection from the Russian legation in Soul, a n act for which Russia would pay dearly. 31..As a result of these loses of the QingJManchu Empress Dowager Cixi along with the continued invasion of foreigners, desperate Chinese nationalists began to resist. Therefore, the Jesuits incited and led the Boxer Rebellion in 1901 (during which many Protestant missionaries were murdered in according with the Jesuit Oath of the Fourth Vow). But the nationalists were betrayed, meeting the armies of eight nations under Jesuit rule or influence in battle. Five of those nations were Japan, America, Germany, Russia and Great Britain. With the foremost Chinese nationalists exterminated and the population weakened with opium addiction, the end of the hated , anti-Jesuit QingJManchu dynasty was approaching. 32..In 1904 J a p a n attacked Orthodox Russia ultimately destroying two of its three fleets. Termed "the first great war of the 20" century," J a p a n was victorious, furthering the Order's building of its Japanese Imperial Empire. Conversely, the loss of Russia fueled unrest in Russia leading to the Order's first Russian Revolution against the Romanov dynasty in 1905. For the Jesuits had been formally expelled from Russia by Czar Alexander I in 1820, only to legally re-enter in 1922 with their successful

Strunk's Supplement to the Complaint Page 11 of 15

Bolshevik Revolution financed and promoted by Rome's Anglo-American, Apostate Protestant, International White Power Structure centered in Washington, D.C., and London. 33..In 1912 the QingJManchu dynasty was finally overthrown. China would undergo a series of socialist upheavals and would yet suffer a Second Sino-Japanese War beginning in 1937 to end in 1945. During this time Freemason Emperor Hirohito would do the bidding of his masters residing a t Jesuit Sophia University in Tokyo, the Japanese invading twelve Asian countries for three reasons: to kill the nationalists, to kill all Protestant missionaries and to plunder the gold of the region much of it then buried in 175 "imperial" treasure vaults in the Philippines. After World War I1 (the second act of the Black Pope's Second Thirty Years' War, 1914-1945), much of that gold would find its way to American banks in New York, one of them being Citibank ruled by the Knights of Malta. Other knights facilitating the movement of the gold were OSS chief William Donovan and CIA chief Allen Dulles, a co-conspirator in the Kennedy Assassination. 34..China, now divided into pro-communist and anti-communist camps, would finally be conquered by the Jesuit Order. Suffering the loss of its gold to the Japanese and the loss of its honor via the Japanese Rape of Nanking, the Chinese people, driven to desperation, were ready for the "solution" to their "chaos." In 1949 the Order, using its Council on Foreign Relations (CFR) member Secretary of State Dean Acheson, facilitated the successful subjugation of China to socialist-communism perfected by the Order on its socialist-communist "reductions" in Paraguay a s per above. All the nationalist, anticommunists fled to Taiwan under the leadership of Freemason Chang Kai-shek loyal to Francis Cardinal Spellman, the mastermind behind the Kennedy assassination. Meanwhile, Communist China was under the dictatorship of Freemason Mao Zedong. Rome controlled both factions via Freemasonry, her open-but-false policy being to support the Nationalist Chinese having fled to Taiwan. But her secret-but-true policy was to back the Communist Chinese on the mainland. It is for this reason the US Seventh Fleet blocked Taiwan's planned invasion of Communist China in 1950 with the excuse that the Fleet was to keep China from invading Taiwan. This blockade enabled Communist China to send one million troops into North Korea to kill American servicemen. 35..Hence, the Jesuit Order via its high-level Freemasons within its International AngloAmerican White Power Structure, controls the governments of both Taiwan and China. The peace-meal policy of betrayal towards Taiwan by Jesuit-directed, CFR-ruled American government is intended to end with the martial unity of Taiwan with China. This secret policy of unification, including the re-uniting of Korea and the uniting of J a p a n with China is to create a Far Eastern coalition of Asian nations for the future invasion of North America. J a p a n has been used to conquer China, J a p a n now to be used both commercially and militarily with its Red Chinese ally in the future subjugation of the entire Far East (including Australia and New Zealand) to culminate in a massive Oriental Asian invasion of North America having been invaded with millions of "fifth column" of Red Chinese loyalists including the spy, nuclear scientist and CIA operative Wen Ho Lee. 36..The Knights of Malta rule the pope's Federal Reserve Bank through such men a s Peter G. Peterson, former president of the Federal Reserve Bank of New York City, the bank holding both title a n d possession of America's gold in the form of 660,000 gold bars. The Jesuits employ the Knights of Malta in various academic positions, CFR-

Strunk's Supplement to the Complaint Page 12 of 15

member a n d Knight of Malta J o h n J . DeGoia serving a s president of Jesuit Georgetown University, it overseeing the policies of the White House through the Vatican's Vaginal Oval Office of the Virgin Mary 37..The Jesuit Order, in complete control of London, Moscow, Washington, D.C., Beijing, Baghdad, Cairo, Istanbul, Paris, Rome, Berlin, Brussels, Tehran, etc., is therefore in total control of the pope's International Intelligence Community, including all sixteen American intelligence agencies, Britain's MI5JMI6, Germany's BND, Israel's Mossad, China's CSIS, Russia's FSBJSVR, a n d all other lesser intelligence services. These intelligence services control the government of their host nations and thus the military complexes of those nations for the benefit of the Jesuit Papacy intending to make the pope of Rome the universal monarch of the world. 38..The Jesuit Order, in complete control of all central banks, including the Federal Reserve Bank and Bank of England, rules all stock exchanges and dictates the value of all paper currencies for the benefit of the Jesuit Papacy, the pope presently calling for the establishment of a World Bank---under his secret rule via his Knights of Malta subject to the Jesuit Superior General. 39..Thus, the Jesuit Order, in seeking to destroy the last bastion of the Protestant Reformation here in the United States of America, is now pulling out its manufacturing base relocating it into Red China, Mexico and Europe. This is in preparation for the Sino-Soviet-Muslim-Hispanic invasion of the American Empire after US forces are betrayed by the Joint Chiefs of Staff a n d defeated on a t least two war fronts. And the secret Japanese imperial gold horde has contributed to the financing of our plotted demise. 41.. To facilitate this "Final solution to the Protestant Question," the Order, via its Knights of Malta controlling international banking and commerce, has used its Japanese a n d Nazi secret gold horde to conduct the pope's Cold War in covertly building Far Eastern communist nations while weakening the Western free enterprise nations of America a n d Canada in preparation for the Sino-Soviet-Muslim-Hispanic invasion of North America. 42.. This design of using massive amounts of gold is in accordance with the Black Pope's statement a t the secret meeting in Chieri, Italy, in 1825:

"For thesepurposes, it is not enough to haue at our disposal men of talent and men of action---we must haue gold to keep them fast to their work. Aye, giue me gold---plenty of gold; and then, with such able heads and such resources as the church commands, I will undertake not only to master the whole world, but to reconstruct it entirely. " Abbate Leone, The Jesuit Conspiracu. The Secret Plan o f the Order, (London: Chapman and Hall, 1848), p. 134.
34) That were this Court not to take the precaution to protect Plaintiffs' assets from

further degradation with admission of supplemental parties with authority to do the necessary accounting without the appearance of impropriety Strunk's asset would be in jeopardy along with that of the Plaintiffs' considerable interest involved herein

Strunk's Supplement to the Complaint Page 13 of 15

35) That Petitioner summary in support of intervention contends the supplemental parties and Sbunk's intervention as of right with FRCP Rule 24 (a)is done on timely motion in, in which the court must permit anyone to intervene who claims an interest relating to the property or bansaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede Strunk's ability to protect its interest, unless existing parties adequately represent

that interest.; and
36) Further, even were FRCP Rule 24 (b) for
PERMISSIVE INTERVENTION

to apply

instead then also Strunk is here by a timely motion, that the court may permit anyone to intervene who: (B) has a claim or defense that shares with the main action a common question of law or fact; and as with the legal duty of the Defendant FBPC and

it agents under the Foreign Bondholders Act of 1933 requires it as a quasi

governmental Agency to act on such timely motion, as the court may permit a federal or
state governmental officer or agency to intervene if a party's claim or defense is based on: (A) a statute or executive order administered by the officer or agency; or (B) any regulation, order, requirement, or agreement issued or made under the statute or executive order; and furthermore, were Delay or Prejudice. In exercising its discretion, the court must consider whether the S b u n k intervention will unduly delay or prejudice the adjudication of the original parties' rights or in fact assist the court in the litigation. 37) Furthermore, that Strunk has received a copy of the Initial Scheduling Conference Notice and Order so ordered on January 10, 20 12 by the Honorable Richard J. Holwell USDJ assigned to hear this case entered January 13, 2012 into the PACER electronic system along with the Judge's Chamber rules (see Exhibit F). 38) Petitioner intervention requirements satisij the issue of supplement summons.

Strunk's Supplement to the Complaint Page 14 of 15

WHEREFORE, Petitioner Skunk wishes a decision of the Court to grant Intemenermaintiff status herein for the purpose of expediting a settlement by an order i n assistance to F'laintifls' demand for relief to include:
'r

A. Assign a mutually acceptable special master for a n accouhting of the DFFI-FF?N;

B. ~ssign'the special master the task of an accounting of the sinking fund;
C. Assign the special master the task ta scrutinize any or all Two-sided Market

Platfbrm(s).

D. Re$&&
1

any member of the SMOM and or CFR from interfering with the accounting including Lee C. B o b g e s , John R. Petty and or their agents;

E. Such other and different relief the Court deems necessary herein.
I have read the foregoing, and in which Petitioner as Intervener-P a n i f litf

requests a preliminary Injunction with r e s e t o Defendants and its agents as to the f

accounting of t.he sinking fund to safeguard the guaranteed reserve to repay Strunk's
American Chinese historical Bonds; and h o w the contents thereof apply to me by

misapplication and administration of laws as a continuing injury caused by the scheme to defiaud wt unjust enrichment that sects HaintXfs' and Intervenerih

Plaint. along with those similarly situated; the same i true to m y own knowledge, s
except as to the matt& therein stated to be alleged on information and belief, and as

to those matters I believe it to be true. The grounds o my beliefs as to all matters not f stated upon inforrnatiun and belief
personal knowledge.

Strunk's Supplement to the Complaint Page 15 of 15

NEIL F. KEENAN et al. v. DANIELE DAL BOSCO et al. 11-cv-8500 (RJH) Strunk Affidavit i n support o f Motion to Intervene

Exhibit A

NEIL F. KEENAN et al. v. DANIELE DAL BOSCO et al. 11-cv-8500 (RJH) Strunk Affidavit i n support o f Motion to Intervene

Exhibit B

NEIL F. KEENAN et al. v. DANIELE DAL BOSCO et al. 11-cv-8500 (RJH) Strunk Affidavit i n support o f Motion to Intervene

Exhibit C

Case3:10-cv-00362-JW Document46-1

Filed07/29/11 Page1 of 3

THOMAS EASTON CSB#109218 EAsroN LAw OFFICE THoMAS oF Dr 2 967Sunset 97477 Springfield, Oregon 746-1335 3 Tel/Fax:541 easton3535@gmail.com

I

4

H, JONATIIAN LEVY CSB#158032 29926 South Carolina HiltonHead, Fax:202-318'2406

Pointe Dr 5 37Royale

6 Telr 843-837-8413 7 jonlevy@hargray.com 8 9 10 I1
and for Attorneys Plaintiffs theClass

DISTRICTCOURT UNITEDSTATES DISTRICTOF CALIFORNIA NORTHERN TAIWAN CIVIL RIGHTS

-t2 LITIGATION ORGANIZATION
13 14

NO.CV r0-0362-VRW

;aat,

DEcLARATIoNqE!B-oI'qsIQRcHENG
OF CHUNG.MOIN SUPPORT PLAINTIFFS' MOTION FOR DEFAULTJUDGEMENT

Plaintiffs,

1 5 KUOMINTANGBUSINESS MANAGEMENTCOMMITTEEet 1 6 al, 1'.7 18 l9 20 21 22 23 25 26 2'7 28 Defendants,
I. CHENG CHUNG-Mo. declarei

L I am not a partyto this law suit andif calledto testifyin this matterwill do so as followsbelow. whileGrand Justice acquired knowledge frommy ownpersonal this 2. I make declaration ofthe MinisterofJustice Yuan1999-2006, Judicial of of andVicePresident theRepublic China at in and Republic China 1998-1999, asa law prof'essor Taiwanandasa visitingprofessor of of tireUniversities Vienla andWisconsrn. 3. The JudicialYuan is the Republicof China's highestjudicial organtaskedwith of ofthe Republic China. the interpreting Constitution 4. I hold a LL.D. from the Universityof Vielna and workedmanyyearsas a Law

Paee1 of 3

Case3:10-cv-00362-JW Document46-1

Filed07/29/11 Page2 of 3

I

ofNationalChung-Hsing ofthe Law Department including positiorofChairman the Professor

2 Univelsity.. 3 4 of for 5. I wasalsotheMinisterof Justice theRepublic Chinafrom 1998to 1999. Peoples The Of Between Reldtions 6. I amfamiliarwith Article63 of theAct Gol)eming

Area And TheMainland Area whi,chstates: 5 Tctiwan 6 To the extentnot coltrarv to the publicorderor goodmoralsof the TaiwanArea,it shallbe created lhereof wiLh riSht obligation or any logelhei of ellects anycrril maner '7 uphiiaihelegat of any itii-tr. urintu?a 4i"", prior t6 thecominginio forceof rhisAit. between of thepeople ol Area.or bet\ eenan) two or moreol the People me theTrir{cn Areaandihe Matnland natlonal AreaandanylorerBn o[ anv 8 MainlaldArea.or betneen of thepeople theMainland provrded therehadbeenIaqs or thal provi.ionsof the precedin!paragrhph shallnotaPPly The or the inLo in 9 ieei,hrion.a iffeci. piior LothEiomi"ne forceof thisAtt. restricting exercise lransfer ofthe rishtsrefefied'totherein. l0 The folliwing debtsshallnot be repaidprior to nationalunification: l1

t 2 h"j$f#lt?,r"r?;gn t4 15 t6 t'7 18 19 20 2l 22 23
)4

prior and in bonds issued theMainland to 1949 theshort-term cuffency

bank as well as any other financirl institution 1 3 2. Variousdebts owed bv rnv government Mainland. from Lhe deposits beforeiheiire'ireat rccepting Orderon as and 7. This act was promulgated amended statedaboveby Presidential Yuan from March 1,2004 by the Orderof theExecutive 29, October 2003andimplemented of of duringmy tennof office asVice President the Republic ChinaJudicialYuan bondswas to reaffirmtheir to 8. The intent of this Act in regards pre 1950Chinese of foreigndebtobligations the Republicof Chinaowedin the United existence defaulted as unification, until national and States elsewhere to delertheirresolution and 9. Thesebondsreferredto in A icle 63 were all issuedby the former Kuomi[tang govemment government theRepublic Chinaor wereratifiedby the Kuomintang oi of as are billionsof US dollars partofthe "black business holdings wofl:h 10. Kuomintang gold" system Kuomintang nepotism, coruption,andcronyism of and pre is tied 1l The issueof defaulted 1950bonds inexorably to theKuomintanS its of has assets thatthe Kuomintang beenthemainbeneficiary thatdefault. in 12. Until approximatelyI 99I , the Kuomintangand the Govemmert of the Republicof of as entity. With the electionof ChenShui-bian President the Chinawereoneandthe same

25 26 27 28

Page2 of 3

Case3:10-cv-00362-JW Document46-1

Filed07/29/11 Page3 of 3

I

by of Chinain 2000,1brthe first time theRepublic Chinawasgovemed a partyotherthanthe

of to ceased be anorganor agent thestateHowever entirely and 2 Kuomintang theKuomintang Committee Management typified by the KuomintangBusiness 3 the Kuomintangapparatus wasan organof the while the Kuomintang accumulated billionsof dollarsof assets 4 retained sinkingfunds'and plausible theproceeds, that It Chinafrom 1926to 1991. is entirely 5 Republic retained the by been in referenced Article63 have bonds of 6 otherbenefits thepre 1950rlefaulted '7 Kuomintang to Committee this day. Management Business

8

of of overallsettlemert thebondsuntil the issue Mainland 13.While Article 63 defers

precludelegal actionsfor unjust en chmentagainstthe 9 China is dealt with, it does not which is now a non sovereignju dic entity. l 0 Kuomintang

ll 12
that underpenalty perjuryunderthelawsof theUnitedStates theforegoing of I declare DC at l 3 is trueandcofiectandexecuted Washington, on

l4 l5 t6 l7 I8 t9 20 2l 22 23 24 25 26 2'/ 28
Page3 of 3

,2010.

NEIL F. KEENAN et al. v. DANIELE DAL BOSCO et al. 11-cv-8500 (RJH) Strunk Affidavit i n support o f Motion to Intervene

Exhibit D

MEMORANDUM OF UNDERSTANDING

The United States Securities and Exchange Commission

The Governmentof Switzerland

Washington, D.C. August 31, 1982

II

I

THE GOVERNMENT OF THE UNITED STATES OF AMERICA

THE GOVERNMENT OF THE SWITZERLAND

MEMORANDUMOF UNDERSTANDING I. 1. Introduction f o r t h the under-

This HOg i s a s t a t e m e n t o f i n t e n t s e t t i n g

s t a n d i n g s r e a c h e d by t h e d e l e g a t i o ~

o f S w i t z e r l a n d and t h e

United S t a t e s a c t i n g on b e h a l f o f t h e i r r e s p e c t i v e governments ( e t h e p a r t i e s ~) t o e s t a b l i s h improving i n t e r n a t i o n a l field m u t u a l l y a c c e p t a b l e mean8 f o r

law e n f o r c e m e n t c o o p e r a t i o n i n t h e These u n d e r s t a n d i n g s c o n t i n u e a long

of i n s i d e r t r a d i n g .

tradition

o f law e n f o r c e m e n t c o o p e r a t i o n between S w i t z e r l a n d

and t h e United S t a t e s ar~ were reached i n t h e c o u r s e o f consultations between r e p r e s e n t a t i v e s
o f S w i t z e r l a n d and

t h e United S t a t e s i n .Bern on March • and 2w 1982e and £n Washington, D.C. on August 30 and 31, 1982: The Swiss d e l e g a -

t i o n was headed by M i n i s t e r ~ean Zwahlenw head o f t h e Economic and F i n a n c i a l S e c t i o n o f t h e F e d e r a l Departme'nt o f F o r e i g n Affairs, and i n c l u d e d o t h e r r e p r e s e n t a t i v e s of the 8aid

d e p a r t n e n t w Lutz Krauskopfw Deputy C h i e f o f D l v i s i o n r and L i o n e l F r e i , C h i e f o f . S e c t i o n , I n t h e F e d e r a l Department

o f ~ u s t l c e and P o l l c e 0 a ~ l ~ e p r e s e n t a t l v e s o f t h e F e d e r a l •Denking Commission and t h e Swiss N a t i o n a l Bank. 0£ the Unite~ S t a t e s i n c l u d e d ~ h n t h e D i v i s i o n o f Enforcement o~ The d e l e g a t i o n

H. F e d d e r s , D i r e c t o r o f

.h3 S e c u r i t i e s and Exchange

Commission (gSECe)w Edward Fo Greenew General Counsel o f t h e
-.

.

.

.

.

°

. . . .

. o

Q.

"3"

whose b e h a l f t h e t : a n s a c t i o n was a f f e c t e d and o t h e r r e l e v a n t information. However, Swiss law p r o h i b i t s banks in p r i n c i p l e

from d i s c l o s i n g
Its services.

information with r e s p e c t to a customer u t i l i z i n g

4.

The p a r t l @ s concluded t h a t t h e c o n d u c t o f p e r s o n s who Swiss banks t o e f f e c t s e c u r i t i e s transactions In the

utilize

United S t a t e s ,

I n o r d e r t o t a k e advantage o f m a t e r i a l nonis d e t r i m e n t a l to the i n t e r e s t s o f both

public infor=ation, nations. 5.

On the b a s i s o f t h e f o r e g o i n g c o n s u l t a t i o n s , interest

the p a r t i e s

r e a f f i r m e d t h e two c o u n t r i e s '

in mutual a s s i s t a n c e

In law e n f o r c e m e n t m a t t e r s In accordance w i t h m u t u a l l y a c c e p t a b l e p r o c e d u r e s and In c o n f o r m i t y w i t h i n t e r n a t i o n a l and n a t i o n a l lawr In p a r t i c u l a r transactions a s s i s t a n c e :with r e s p e c t t o

e f f e c t e d by p e r s o n s In p o s s e s s i o n o f m a t e r i a l

non-public information. 6,
During t h e c o n s u l t a t i o n s the p a r t i e s engaged I n an

exchange o f o p i n i o n s p u r s u a n t t o A r t i c l e 39, p a r a g r a p h 1 o f t h e T r e a t y Between t h e United S t a t e s and t h e ~ i s s C o n f e d e r a t i o n on Mutual & s s i s t a n c e I n C r i m i n a l Kattersw
which became e f f e c t i v e on January 23w 1977 ( t h e 'J1,977 T r e a t y J ) .

S e c t i o n I I o f t h i s Memorandum o f Understanding m e m o r i a l i z e s t h e exchange o f o p i n i o n s and r e l a t e d u n d e r s t a n d i n g s t h a t t h e parties have r e a c h e d .

-5-

a.

Article provides

1, p a r a g r a p h 1 og t h e 1977 T r e a t y that the Contracting Parties'under-

t a k e t o a f f o r d e a c h o t h e r w £n a c c o r d a n c e w i t h provisions
o f the T r e a t y w - m u t u a l a s s i s t a n c e

In "Lnvestlgatlons respect falls of offenses

or court proceedings

In

t h e p u n i s h m e n t o f which within the Jurisdiction of the requesting

o r would f a l l

of the Judicial State or a state

authorities

o r c a n t o n t h e r e o g , m T h i s meansw by t h e SZC £ o : which

f o r e x a m p l e , t h a t an i n v e s t i g a t i o n

s h o u l d be c o n s i d e r e d an i n v e s t i g a t i o n assistance c o u l d be f u r n i s h e d

(1£ t h e o t h e r

requirements

o£ t h e T r e a t y a r e m e t ) a s l o n g a s t o c o n d u c t which m i g h t courtSo a particular •

the lnvestigatl0n'relates be d e a l t b°

with by the crlninal that

The 1977 T r e a t y r e q u i r e s

o f £ e n s e be a c r i m e u n d e r t h e l a w s o f e a c h nation in order £or compulsory assistance under the Treaty. transactions
%

to

be r e q u i r e 4

The p a r t i e s affected

understand that

by

persons In possession

of material

non-public under Articles

i n f o r m a t i o n c o u l d be an o f f e n s e 148 ( f r a u d ) # 159 ( u n ~ a i t h f u l

management) o r 162

-7undertake to consider whether comparable diplomatic to other offenses notes relating

s h o u l d be e x c h a n g e d w i t h r e s p e c t to securities XII. 1o transactions

covered by the Treaty.

The P r i v a t e & g r e e m e n t ~ n g Memberm of the Swiss Bankers ~ &ssociation reco~nize that t h e r e may be s e c u r i t i e s by Swiss banks non-public_

The p a r t i e s

transactions acting

effected

in the United States

on b e h a l f o f p e r s o n s who p o s s e s s m a t e r i a l

information, available

f o r w h i c h c o m p u l s o r y m e a s u r e s would n o t be Such a s s i s t a n c e could not the As t h e

u n d e r t h e 1977 T r e a t y .

be o r d e r e d I f a v a i l a b l e existence o f an o f f e n s e

information

did not indicate

u n d e r t h e S w i s s P e n a l Code.

Swiss Federal Council will submit to the Parliament a bill

on t h e m i s u s e o f i n s i d e filled.

information,

this

l a c u n a c o u l d be or

For oases i n which t h e T r e a t y i s n o t a p p l i c a b l e , is not possibl• to ~lather evidence.by

in vhich it

employing

compulsory process, the parties aegis

p e n d i n g t h e e n a c t m e n t o f Such l e g i s l a t i o n , • proposed private Agreement under the

discussed

o f t h e S w i s s B a n k e r s e A s s o c i a t i o n w w h i c h would p e r m i t banks to disclcse the identity of • customer specified

participating .and certain

other 1relevant lnformationr

under certain

circumstances, of

i n r e s p o n s e t o • r e q u e s t made b y t h e D e p a r t m e n t

O u s t i c e on b e h a l f o f t h e SEC and. p r o c e s s e d t h r o u g h t h e

-9-

d e f i n e t h e c i r c u m s t a n c e s u n d e r which t h e Commission o f E n q u i r y " s h a l l s be s a t i s f i e d g r o u n d s t o make t h e r e q u e s t . the criteria that t h e SEC h a s - r e a s o n a b l e o t h e r c a s e s i n which understand that to review the Is

In all

a r e n o t mete t h e p a r t i e s

t h e Commission o f E n q u i r y w i l l

be r e q u i r e d

i n f o r m a t i o n s u b m i t t e d b y t h e 8EC t o d e c i d e w h e t h e r i t reasonably 8atisfie~ t o make a r e q u e s t . that a failure specified that

t h e SEC h a s r e a s o n a b l e g r o u n d s understand*

Accordingly, the parties

by t h e 8EC t o meet t h e t h r e s h o l d c r i t e r i a Agreement s h a l l not result i n any

in the private

presumption that

t h e SEC d o e s n o t have r e a s o n a b l e g r o u n d s for assistance under t h e terms of the

to sake the request private

Agreement an~ t h i s

Memorandum o f U n d e r s t a n d i n g . the failure o f a bank c u s -

- The p a r t i e s

understand that

t o m e r t o provAde i n f o r m a t i o n which may d e m o n s t r a t e t h a t the transaction i n q u e s t i o n was n o t made i n v i o l a t i o n of

the United States securities private guilt, . The p a r t i e s understand that Agreement, s h a l l

lawsw a s p r o v i d e d f o r b y t h e i n any p r e s u m p t i o n o f

not result

£nfo~ation

obtained through

the ~echanism e s t a b l i s h e d &gre~ent
o

b y t h i s memorandum and t h e p r i v a t e
~ • bq

w i l l be used o r i n t r o d u c e d a s e v i d e n c e o n l y i n

-11that a report the private vithout s u b m i t t e d by a bank p u r s u a n t t o t h e t e r m s o f t h e SEC Interests

Agreement may n o t be t r a n s m i t t e d . t o hat-neither to the essential

considerable

of Svitzerland relationship

or to thirdpersons

who a p p e a r t o have no to the request the

t o t h e o f f e n s e w h i c h gave r i s e In such c a s e s t It

for assistance.

is understood that use i t s

Federal Office for Police Matters viii to adapt the report so t h a t useful

beat efforts
o

I n f o r m a t i o n may be

p r o v i d e d t o t h e SEC w i t h o u t c a u s i n g such harm t o t h e i n t e r e s t s of thirdperaona or to Switzerland. t h e S~C v i i i I n t h e same s p l r i t t It

Is understood that ma~e £n good f a i t h alternative •IV. 1.

~udge t h i s o p i n i o n as one

an~ u s e m o d e r a t i o n vhen c o n s i d e r I ~

measures.

F u r t h e r . C .o n s u l t. a t.i o.n s . . law

I n o r d e r t o c o n t i n u e and improve i n t e r n a t i o n a l

e n f o r c e m e n t c o o p e r a t i o n i n a manner c o n s i s t e n t interests of both nationsw the parties

with the the

understand that

SEC and t h e F e d e r a l O f f i c e f o r P o l i c e M a t t e r s w i l l u n d e r take further contacts or consultations i n t h e f u t u r e when

t h e need t o do so i s r e c o g n i z e d m u t u a l l y .

2~

T h e r e w i l l be c o n t ~ . ~

or consultations

between t h e

Parties

concerning the fo~xoving matterss

-13-. unaer the private Agreement and t h e 1977 T r e a t y o f such t e r m i n a t i o n on

as w e l l a s t h e e f f e c t this
C.

memorandum. agree that any q u e s t i o n s or dis-

The P a r t i e s

p u t e s between t h e n~w i t h r e s p e c t pretation or application

to the inter-

o f t h i s Memorandum o f

Un4erstandlngw the exchange of o p i n i o n s Included herein pursuant to Article 39w p a r a g r a p h 1. o f

t h e 1977 T r e a t y o r t h e o p e r a t i o n o f t h e p r i v a t e Agreement s h a l l , be s e t t l e d sultations. • V. O t h e r . I. parties N o t w i t h s t a n d i n g any o t h e r p r o v i s i o n agree that hereinw t h e by means o f c o n -

t h i s Memorandum does n o t m o d i f y o r s u p e r s e d e in f o r c e in the United S t a t e s or

any laws or r e g u l a t i o n s Switzerland. 2. any r i g h t The p a r t i e s

agree that

t h e y do n o t i n t e n d t o c o n f e r

on any c u s t o m e r o f a bank which i s a s i g n a t o r y o f Agreement t o J u d i c i a l review in the courts of the to disclose

the private

the United States with respect information the private to United States' Agreement.

t o any d e c i s i o n authorities

under the terms of

14th July, 1982

AGREEMEHT

XVZ

o f t h e Swiss Bar~ers ~ A s s o c i a t i o n v l t h regard to the handling of requests for £ n f o r ~ a t l o n from t h e $ e c u r £ t l e s a n d Exchange C o n n l s s £ o n o f t h e Un£ted S t a t e s on t h e sub:Sect o f m i s u s e o f :Lns£de lnfornat£on

"In consideration

Of t h e I n ~ u l r ~ e s (hereafter

from t h e 5 e c ~ r l t ~ e s

~I

Exchange C o m £ s s l o n

8 SEC) o f t h e Un£ted S t a t e s £nformation to the appropr£ate ass£st• % e~

on t h e n £ s u s e o f £ns£de £ n f o r n a t ~ o n and so f a r a s t h e b a n k s c a n n o t be o b l i g e d t o f u r n i s h ante procedure, (hereafter stlpulat£ons 8 Sw£ss a u t h o r £ t £ e 8 f o r submiss£.on, t o "the $EC i n a l e g a l t h e me~ber b a n k s o f t h e " p r e s e n t • 8 the banks) undertake to respect

Agreement

the following

kr~icle

2

1 . The B o a r d o f D i r e c t o r s &ssocLation shall three deputies.

of the Swiss Bankers e me mbe r s a n d •

a p p o L n t a CommissLon o f £ n q u L r y t h e memberw o f t h e n a y exercLse an subject

( t h e mCommiss£onU) c o m p o s e d o f t h r e e Neither Commission n o r t h e i r executive function to the Federal 2. ~s s e l e c t e d Federal deputies

£n a company v h l c h i s

Law on Ba nks a n d S a v i n g s B a n k s , - . of the banks 47, p a r a g r a p h 1, o f t h e deputies and s t a f f are the

representatives

in accordance wlthArticle Of t h e Commlssionw t h e i r bound b y t h e r u l e facts the procedure

Law on B a n k s a nd S a v i n g s Banksw t h e m e m b e r s o f b a n k i n g s e c r e c y fo~ a l l

o f w h i c h the m a r e a p p r i s e d

In the course of Kgreement.

set out by the present
°.

3. The Commission s h a l l be d o m i c i l e d a t t h e o f f i c e s o f t h e Swlss B a n k e r s ' & s s o c l a t l o n . 4. The Commission s h a l l o r g a n i z e i t s own s e c r e t a r i a t .

(ll)

£ t has o t h e r m a t e r i a l referred o f U.S. i n s i d e r

indications trading £n a l l

that

t,he

transactions £n v i o l a t i o n

t o i n B o above w e r e made l a w s . The c a s e s £n

Commission s h a l l which the dally increased ,25 trading rities

be s a t i s f i e d trading

volume o~ s u c h s e c u r i t i e s

50 I o r more a t a n y t i m e d u r i n g t h e days prior t o s u c h announcement a b o v e volume o f s u c h s e c u to such trading

the average daily

d u r i n g t h e p e r i o d from t h e gOth t r a d i n g day prior o f such s e c u r i t i e s In all other cases,

d a y t o t h e BOth t r a d i n g varied at least

announcement o r t h e p r i c e days prior

50 ~ o r more d u r i n g t h e 25 t r a d i n g review the information sub-

to such announcement.

t h e Commission s h a l l satisfied that

m i t r e d by t h e SEC t o d e c i d e w h e t h e r i t t o make t h e Znqu£ry~

is reasonably

t h e SEC h a s r e a s o n a b l e g r o u n d s

5 . t h e I n q u i r y i s a c c o m p a n i e d b y an" u n d e r t a k i n g b y t h e SEC n o t t o d i s c l o s e t h e i n f o r m a t i o n t o be 4.3. to any per~n or . by t h e SL~ of the provided pursuant to Article a law e n f o r c e m e n t a c t i o n against
e

e x c e p t i n c o n n e c t i o n w i t h an SEC i n v e s t i g a t i o n initiated alleged purchaserp or sellers o~©all
Fe~°r

~:omp~y s securities

options the reforQ for laws i n c o n n e c t i o n

violations-of

U.S. £nsidez trading

with the Acquisition

or Business Combination.

4. Together with the report, t h e Commission a l l
customer.

t h e bank s h a l l received

flle

with

materials

from the

5. If

t h e Commission n e e d s f u r t h e r £t will

lnformat£on

for

the sake of the Inquiry,

a p p r o a c h t h e SEC

through the Federal Off£ce for Pol£ee Matters.

~rticle
ii i

$

The c u s t o m e r p . w i t h i n t h e n e a n i n g o f ~ r t i e l e s hereo£e ~ncludes the beneficial o~er £dentlf£ed in accordance with the ~rticles

2 to S $ to $ of of

of the assets

t h e A g r e e m e n t d a t e d O u l ¥ lw 1982 on t h e o b s e r v a n c e o f c a r e i n a c c e p t £ n g funds and on t h e p r a c t i c i n g bank£ng secrecy.

Article

8

In the case o f any d o u b t a r i s i n g accuracy of the report Comission priate by i t s e l f channels, furnished

as to the material by t h e b a n k , t h e

o r t h e SEC, t h r o u g h t h e a p p r o the report given conforms •

may r e q u e = t t h e F e d e r a l B a n k i n g COm-

mission to examinewhether tO t h e f a c t s shall report
Q

and tO t h e p r e s e n t J~greement. The b a n k information needed f o r e x a m i n a t i o n . an amendedbe measures inaccuracy ls discoverede

provide all

If any material

showing t h e c o r r e c t

information shall

forwarded to the Federal Office for Police Matters. tO be f o r w a r d e d t o t h e SEC. Any o t h e r a p p r o p r i a t e " the provisions o f t h e F e d e r a l B a n k i n g Commission Ln a c c o r d a n c e wit.h o f t h e F e d e r a l Law on Banks a n d S a v i n g s Banks a r e r e s e r v e d .

--

6ml,

--

t o t h e SEC t h e C o n n n i s s i o n ' s r e p o r t to Article

pursuant

?, o r
for review pursuant to Article on.the sixtieth 8

(ii)

a request

hereof is received, the date of receipt amended r e p o r t has been i s s u e d ,

day after 8 hereof after ?

o f s u c h i n q u i r y w h e r e no

pursuant to Article o r on t h e t e n t h d a y

t h e d a t e a n y amended r e p o r t whichever is earlier# oE

under Article

w h i c h h a s b e e n i s s u e d i s f o r w a r d e d t o t h e $EC,

b)

the proceedings in a final

i n a U . $ . c o u r t have t e r m i n a t e d not

Judgement, by c o n s e n t or o t h e r w i s e ,

adverse to the customer, or
B Q

C)

the SEC'consents in writing.

4 . The e v l d e n t i a r y under 2 a),

proof concerning the conditions c) h e r e o f

listed shall

b) and c) and 3 a ) , b ) ' a n d

b e communicated t h r o u g h t h e F e d e r a l O f f i c e f o r P o l i c e

Katterm.

!

Article
• m

11

The A g r e e m e n t i s years of Its

£n f o r c e

for a fixed period of three ° Zt s h a l l if be thereafter by one of at least to _ not terminated

as from .o.o°...°...°.

r e n e w e d on a y e a r t o y e a r b a s i s

members b y g i v i n g a d v a n c e n o t i c e being termlnated, within all

six months addressed to the Swiss Bankers e Association. Zn t h e c a s e o f I t s parties t h e A g r e e m e n t u u s t be i n f o r m e d t h e r e o f they then have the right, t o become a p a r t y no l o n g e r termination . effect to such termination shall w£thout delays even vhenthere £s

a month from t h a t , d a t e , of the It.

s i x m o n t h s t o r u n up t o t h e e x p i r a t i o n t e r m . The A g r e ~ e n t

r e m a i n £n f o r c e a n d

f o r t h o s e members v l ~ h a v e n o t t e r m i n a t e d be a b r o g a t e d legislation

The A g r e e m e n t w i l l legislature £nformat£on.

In the case of the Swiss on t h e m i s u s e o f i n s i d e

enacting

°:

Znthe

case of the Agreement already Inst£tuted rill

being abrogated, with the Federal

pro-

ceedings

Office

for Police Hatters

be c a r r i e d

through to settlement.

M E M O R A N D U M OF U N D E R S T A N D I N G B E T W E E N THE G O V E R N M E N T OF THE U N I T E D S T A T E S OF A M E R I C A AND THE G O V E R N M E N T OF S W I T Z E R L A N D ON M U T U A L A S S I S T A N C E IN C R I M I N A L M A T T E R S AND ANCILLARY ADMINISTRATIVE PROCEEDINGS

I.

Introduction
• ° _ _

i.

This Memorandum setting

of Understanding

(MOU)

is a statement by the

of intent

forth the understandings States

reached

delegations behalf

of the United respective

and Switzerland authorities

acting on (the Parties) law of

of their

executive

to improve

their cooperation

in the field of international continue

enforcement.

These understandings cooperation reached between

a long tradition

law enforcement States and were

Switzerland

and the United between

in the course of consultations and the United States.

representatives

of Switzerland

On the basis of the foregoing reaffirmed the two countries' and ancillary between

consultations, in mutual

the Parties assistance in

interest

criminal matters Article States

administrative the Government

proceedings

under

1 of the Treaty of America

of the United on Mutual

and the Government

of Switzerland

or tax fraud as defined under Swiss law. include assistance and authenticating

Such cooperation may producing

in locating and hearing witnesses,

judicial or business records and serving

judicial or administrative documents. 2. The Treaty, in particular, has been used on numerous

occasions by the law enforcement authorities of both countries. The Parties understand that the procedures provided by the instruments should be used as a first resort whenever available and to the extent applicable. The Parties will use their best

efforts to interpret and apply the instruments to provide assistance when requested by the Central Authority of the other Party and to streamline the implementation process of the instruments in order to improve their practical availability

and effectiveness.

III.

Early Warning/Consultations

1.

In o r d e r

to continue a n d improve international

law

enforcement cooperation in a manner consistent with the interests of both countries, the Parties understand that the

appropriate authorities will undertake contacts or consultations in the future when the need to do so is

recognized mutually.

may prejudice or proceeding;

the successful and

completion

of

an

investigation

(c) the Central mutually an effort

Authorities

have had 30 days, within which

or other in

agreed perio~ of time, to resolve the matter

to consult

to their mutual

satisfaction. Even where the above conditions continue enforce objects 4. to exercise moderation unilateral compulsory have been met, and restraint the Parties will in undertaking to

measures

to which the other

or to block enforcement The Parties understand

Df such measures. further that they will use their obtained in such it

best efforts

to insure

that the information

communications

is handled with appropriate

care to prevent

from becoming public and,

in particular, will not be disclosed dealing with the case concerned parties of the

to any person except officials and, once an official

request has been presented, in connection

having

a right of appeal

with the handling

request.

IV.

Moderation

and Restraint

Where obtain

the above-mentioned

mechanisms

are not available

to

evidence

in areas covered by this MOU the Central with a view to avoiding or minimizing

Authorities

will,

counterfeiting,

extortion,

robbery or terrorism (which may also can be circumstantial evidence of the

involve money laundering)

existence of organized crime. In view of these considerations, the Parties understand

that the Central Authorities will continue their practice of using their best efforts to interpret and apply the instruments, in particular, such provisions that deal with in such a way as t o

organized crime and drug trafficking,

provide assistance to the widest extent possible.

VI.

Legal Status

This MOU is not intended to create legal obligations. embodies statements of intent of the two Parties.

It

The Parties

further understand that this MOU does not modify or supersede any laws or regulations United States. in force in Switzerland or in the

This MOU is not intended to create any rights

enforceable by private parties and does not impose any obligations on the legislative and judicial branches of the Parties.

DEPARTHENT OF STAT~ WASHINGTON
l|ove~ber

10, 1987

Excellency, " X have t h e honor t o r e f e ~ t o the Tceaty betveen t h e United States o f - A m e r i c a a n d t h e Swiss C o n f e d e r a t i o n on i n C c l B l n a l K a t t e r s , . v h i c h v a s s i g n e d on on J a n u a r y 23, 1977

Nutual Assistance

Kay 25e 1973e a n d became e f f e c t i v e ('Tceaty'}, Article 1. and in particula~ That provision

to Paragzaph.3 of "the competent

provides that

authorities assistance in certain

of the Contracting Parties

may a g r e e t h a t begranted ~n r e s p e c t ! o£

asprovided by t h i s T r e a t y w i l l a l s o a n c i l l a r y administrative p r o c e e d i n g s
falling vithin

Of m e a s u r e s w h i c h may be t a k e n a g a i n s t t h e p e r p e t r a t o r an o f f e n s e
o o

the purviev of this Treaty. a of securities by p e r s o n s £n

In cases involving, trading possession offenders " criminal sanctions -repaired of material

non-public informationr the
4

n a y n o t o n l y be . f o u n d / g u i l t y and s e n t e n c e d i n a p r o c e e d i n g b u t a l s o may be s u b j e c t t o o t h e r in order that or thai'the . t h e . h a m c a u s e d by t h e o f f e n s e i s from s£m£1ar-. undecstanding under

.offenders are deterred It is therefore-the

-conduct i n t h e

futuce.

of the United States

Govermnent t h a t r

if assistance

His ExcellencY~., Klaus Jacobi,

.--~:

.-

:..

J~nbassador o f S w i t z e r ~ a n d .

provisions

of the United S t a t e s

securities

laws or t h e

r u l e s and r e g u l a t i o n s p r o m u l g a t e d t h e r e u n d e r ~ and (5) E n f o r c e m e n t p r o c e e d i n g s c o n d u c t e d b e f o r e t h e SEC or law Judge i n which t h e r e v o c a t i o n o~ of a regulated entitye or a

an a d m i n i s t r a t i v e

s u s p e n s i o n o f the. r e g i s t r a t i o n suspension

Or b a r o f a p e r s o n from b e i n g a s s o c i a t e d w i t h as a r e s u l t of violative conduct is sought.

s u c h an e n t i t y , It

i S a g r e e d t h a t t h e T r e a t y p r o v i d e s an i m p o r t a n t

means o f o b t a i n i n g i n f o r m a t i o n n e e d e d t o e n f o r c e t h e C r i m i n a l o r p e n a l laws o f t h e U n i t e d S t a t e s T r e a t y s h o u l d be used t o t h e e x t e n t f e a s i b l e . further u n d e r s t o o d t h a t an i n v e s t i g a t i o n and t h a t t h e It is

by t h e SEC i s t o can be

be c o n s i d e r e d an i n v e s t f g a t i o n furnished (if

for which assistance

the other requirements of the Treat~ ate relates t o c o n d u c t which

m e t ) . a s l o n g as t h e i n v e s t i g a t i o n

m i g h t be d e a l t w i t h by t h e c r i m i n a l c o u r t s o f t h e U n i t e d States. I have t h e f u r t h e r
• . . .~

honor to state,

on b e h a l f o f t h e under t h e criminal

U n i t e d S t a t e s Goverrmente t h a t : i / f

assistance

T r e a t y c o u l d be g r a n t e d w i t h a v i e w ~ o p o s s i b l e p r o c e e d i n g s ~n S w l t z e r l a n d w a s s i s t a n c e granted in connection with thefollowing and p r o c e e d i n g s , including investigations

w i l l a l s o be investigations t h a t may l e a d t o

s u c h p r o c e e d i n g s e t h a t a c e c o n d u c t e d by c o m p e t e n t Swiss

-5-

..

article into

le Paragraph 3 of the Treatya which 6hall enter o n t h e d a t e o f Your E x c e l l e n c y e s note in reply. o f my

force

&ccepte Excellencyt highest consideration.

the renewed assurances

~or the ~ecretary

of 8tatez

NEIL F. KEENAN et al. v. DANIELE DAL BOSCO et al. 11-cv-8500 (RJH) Strunk Affidavit i n support o f Motion to Intervene

Exhibit E

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT O F NEW YORK
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .X .................................

NEIL F. KEENAN, Individually a n d as Agent for THE DRAGON FAMILY, citizens of foreign states, Plaintiff,

11-CV-8500 (RJH)

-againstDANIELE DAL BOSCO, a citizen of a foreign state, E t al. Defendants.
................................ ................................ X

Affidavit of Eric Jon Phelps in esse a s Expert in support of Christopher-Earl Strunk in esse Motion to Intervene

COMMONWEALTH OF PENNSYLVANIA COUNTY OF BERKS

) ) )

SS

I, Eric-Jon: PhelpsO in esse, Affirmant, being duly sworn, depose and state under
penalty of perjury: 1. Am a natural born citizen of the Republic of California residing in the Commonwealth of Pennsylvania, am over 18 years of age and not a party to this instant action 2. Affirmant's residence for service of process is 203 South Fort Zellers Road, Apt. D, Newmanstown, PA, 17073; Email: eric@vaticanassassins.org;home phone
: 610-589-5300.

3. Affirmant makes this affidavit in support of Christopher-Earl: Strunk in esse

("Petitioner") motion to intervene in the above captioned case in the United States
Eric-Jon: Phelps Affidavit Page 1 of 19

District Court for the Southern District of New York, and with due notice am available to testify accordingly.

4. That Petitioner has requested that Affirmant testify herein and or related
proceedings as an expert witness on the Jesuit Order and related organizations in the following matters: a. The history of the Bible-based, Protestant Reformation as relates to the hstory of the Jesuit Aragon Templars, a.k.a. the Society of Jesus

b. The Aragon Templar history in Asia from 1540 to the present
including the events associated with the Open Door Policy in China leading to the over throw of the Emperor, Versailles treaty after World War I, and the rise of Mao Zedong to power on the Mainland against the Chnese Nationalist movement on Taiwan. c. Jesuit control inter alia over the Sovereign Military Order of Malta, New York Council on Foreign Relations and Federal Reserve Bank of New York. d. The Strategic outlook of the coming events involving the Jesuits.

5. Affirmant, author of Vatican Assassins: "Wounded In The House O f M v

Friends, " Third Edition (2006), solemnly states the following historical
points of interest with regard to topics above a-d: 6. During the Dark Ages, when the pope of Rome was virtual master of Europe

Eric-Jon: Phelps Affidavit Page 2 of 19

and the Far East, the Knights of the Temple of Solomon (Knights Templars hereafter) were created to conduct the pope's Crusades for the purpose of taking Jerusalem from the Islamic Saracens after which the Temple of Solomon was to be rebuilt upon Jerusalem's holy Temple Mount. To effect this design, the Knights Templars would conduct ceaseless warslcrusades financed with an income tax upon European nobles as well as with an international commerce, including shipping and banking, squarely under the direction of the Order's Grand Master.

7. In 1291 the Templars were driven from Acre by the Islamic Egyptian
Mamluks, the pope's Latin Kingdom of Jerusalem (revived today under the name of "Israel") ceasing to exist. Weakened, the Knights vowed to return, re-establish the kingdom (accomplished in 1948) and rebuild the temple.
8. But by the turn of the Fourteenth Century, the Order of the Knights

Templars had become the virtual masters of all European finance and thus the real directors of Europe's divine right monarchs.
9. In putting an end to this magnificent monopoly, King Philip IV "the Fair" of

France and Pope Clement V set out to suppress the Templars. This providential act in restraining Satan's "mystery of iniquity" (I1 Thessalonians 2:7), was Pope Clement V issuing his famous bull, Vox in Excelsis, in 1312, suppressing the Order, confiscating all its wealth to be

Eric-Jon: Phelps Affidavit Page 3 of 19

given over to the Sovereign Military Order of Malta (Knights of Malta, hereinafter). 10.The Knights Templars fled to several countries, primarily Scotland, where they devised their war on the papacy to ensue for over 200 years. Agents of the Order divided the papacy, resulting in the Babylonian Captivity of the Church (1309-1377) and the reign of two simultaneous popes, shattering the Spiritual and Temporal Power of "the Vicar of Christ." Agents of the Order released the bubonic plague across Europe, killing one thrd of the population most of which was loyal to the Roman Catholic papacy and despised the Knights. Agents of the Order incited the Peasants' War in England (1381) due to famine, plague and excessive taxation financing foreign wars, killing the Grand Master of the Knights of Malta thereby beginning the chastisement of the rival crusading Order of Malta, holder of all wealth of the Knights Templars. 11.With the dawn of the printing press (1450) followed by the beginning of Luther's Protestant Reformation (1 517), the power of the papacy was shaken to its very core. Europeans were reading the Bible resulting in the loss of the pope's Spiritual and Temporal powers. People began to understand there is only one mediator between God and men, the man Chnst Jesus (I Timothy 2:4-6). Whole nations broke away from the politicalltemporal power of the

Eric-Jon: Phelps Affidavit Page 4 of 19

"Holy See." The commerce of Rome was suffering tremendous loss, De Medici Pope Leo X leaving a nearly bankrupt papacy at his death in 1521. 12.It was now time for the suppressed Templars to "strike while the iron is hot." Rome was in peril of Sunni Islam at the gates of Vienna, and now the Protestant Reformation further threatened her existence. Ignatius Loyola, an Aragon Knights Templar came to the rescue. A Spanish noble and soldier of dauntless courage coupled with fanatic devotion to the Virgin Mary, Loyola would revive the Knights Templars founding an even more diabolical and dangerous Order of warrior priests. 13.After a 1523 pilgrimage to Jerusalem in the attempt to establish the Jesuit headquarters of his future New World Order, Loyola created the Society of Jesus in Paris, France, in 1534. In 1540 his New Order of the Knights of the Virgin M a r y h i g h t s Templars was brought under the protection of the papacy, Farnese Pope Paul I11 issuing the bull of its establishment. 14.Created to first take Jerusalem from the Islamic Saracens and then to stop Martin Luther and William Tyndale's Protestant Reformation in Germany and England, the Order oversaw its "Counter Reformation" Council of Trent (1 545-1563). Therein contained all the doctrines to champion during the Order's military "Counter Reformation." Ending the council with the unified cry "Accursed be all heretics," Jesuit Wars began in earnest against

Eric-Jon: Phelps Affidavit Page 5 of 19

all Protestants and Bible-believing Christians across Europe. These wars would also be directed against all religions and nationalists refusing to submit to the Spiritual and Temporal Power of the pope. 15.The Company specifically sought to overthrow the Protestant Reformation in England under Queen Elizabeth I and in Great Britain under King James I. Failing, due to rise of the Protectorate of Oliver Cromwell resulting from the Puritan Civil Wars initiated by the Scottish Presbyterian Covenaters, the Order plotted to restore the Roman Catholic Stuart dynasty. Succeeding in 1660, the Company ruled over Great Britain with its anti-Christian tyranny for twenty-eight years, when, in 1688, the bloodless Glorious Revolution drove James I1 from the throne into France. But all was not lost. Upon William I11 of Orange ascending the throne in London, the Order secretly gained control of "King Billy." For William refused to capture James I1 after the Battle of the Boyne (1690), enabling his father-in-law to again escape to France then to plot the overthrow of Protestant Great Britain directed by the Jesuits overseeing the Jacobites. 16.The Order, in seeking to use the developing British Protestant Empire to wage war on its enemies, needed a national bank for financing. In 1694 Scottish Freemason and Jesuit Temporal Coadjutor William Paterson founded the Bank of England. This national bank would be the great lender

Eric-Jon: Phelps Affidavit Page 6 of 19

to the British Crown extending credit and issuing notes of credit to wage British crusades of subjugation for the benefit of the Jesuit General. One of those crusades was its war on the White Protestant and Baptist American colonies having declared their independence in 1776. 17.The Society of Jesus, also called the Military Company of Jesus, plotted to conquer all the nations of the Far East. Francis Xavier set out for India and Japan while Matteo Ricci set out for China. The military design was to first conquer Japan, and then, using the superior military prowess of the Japanese, to conquer China. This design would never change for over four hundred years. 18.The Company of Jesus (after which "the Company" of the CIA is modeled) engaged in massive international commerce. Establishing 57 "reductions" in Paraguay, these were the first socialist-communist experiments of the Order spanning one hundred and fifty years (1609-1759). Over 200,000 native Guarani Indians were enslaved to produce a host of goods then to be placed in commerce and taken to European ports with the Order's massive fleet of "Blackships" overseen by the Jesuit General. The Order became so magnificently wealthy that it established banks throughout the world to facilitate its commerce. These revived Knights Templars were faithfully following in the footsteps of their forebears. War and Commerce conducted

Eric-Jon: Phelps Affidavit Page 7 of 19

by the Ignatians would be the keys to a total restoration of the pope's Spiritual and Temporal Power over every nation on earth---including Japan and China. For as Cicero declared, "Money is the sinew of war." This, the Jesuits have proven and perpetually practice especially now in Red Chna. 19.The Jesuits were in need of supportive warriors in Protestant lands to further the Counter ReformationlWorld government design of the Jesuit Superior General. Hence, Scottish-Rite Freemasonry was created by the Jesuits in their College of Clermont, Paris, in 1754. Therein, the first 25 rites of this new Masonic order were authored by the Jesuits. Its purpose was to be the tool to restore the Roman Catholic Stuart dynasty to the throne of England while making a slain and risen Roman Papal Caesar of Jesuit rule "the universal monarch of the world." After this design, the Masonic rite of the slain and revived Hiram Abif was conceived. 20.By 1750 the Society of Jesus had nearly complete control of the world. Every Roman Catholic European monarch was possessed of a Jesuit confessor. Many Protestant monarchs were secretly "under the influence" of the sons of Loyola. Japan had expelled the Order in 1614, later finalized and termed "the Christian Ban." But the Jesuits were beloved in the court of China's emperor, they being the masters of Peking. Bringing a vast array of European science to the Chinese court, Loyola's Ignatians became the

Eric-Jon: Phelps Affidavit Page 8 of 19

foremost and favorite astronomers of the Ming Emperor. Matteo Ricci and Adam Schall were two of several. 21.But God would set back the power of the Knights Templars (now the Society of Jesus) once again. Portugal expelled the Jesuits in 1759; France in 1764, Spain in 1767 and the Grand Master of the Knights of Malta expelled the Order from Malta in 1768. This led to the Bourbon dynasties of Spain and France demanding the pope's suppression of this most dangerous, murdering and thieving Military Order of the Society of Jesus. 22.h 1773 Pope Clement XIV issued his infamous bull Dominus ac Redemptor

Noster, forever suppressing and extinguishing the Society of Jesus. As did
Pope Clement V with the crusading Order of the Knights Templars, so did Pope Clement XIV with the crusading Order of the Society of Jesus---the New Knights Templars. At about this time, the Manchu dynasty (16441912) expelled the Company from China. In the future, the Manchus would pay dearly for this, Jesuit vengeance to result in the termination of the dynasty and the destruction of patriotic Chinese nationalism. 23.The Order fled for protection to non-Catholic nations. Embraced by Catherine I1 "the Great" of "heretic" Orthodox Russia, by Frederick I1 "the Great" of "heretic" Lutheran Prussia and by George I11 of "heretic" Anglican England, the sons of Loyola launched their war on the Vatican. Founding

Eric-Jon: Phelps Affidavit Page 9 of 19

the Illuminati in 1776, they ignited the French Revolution leading to the Napoleonic Wars and the secret killing of Pope Pius VI while punishing the papacy and the Roman Catholic monarchs of Europe for suppressing the Society of Jesus. Roman Catholic Freemason Napoleon Bonaparte I was the Company's "Great Avenger." 24.h 1798 Napoleon invaded Malta. Advised by Jesuit Abby Sieyes, he confiscated all the weapons and treasures of the Knights of Malta to be used for his invasion of Egypt in the punishment of the Mamluks for driving the Knights Templars from Acre in 1291. Napoleon then drove the Knights of Malta to Russia, there to submit to terms of the acting Jesuit General. From then on, the Knights of Malta would never again resist the Society of Jesus. Today, the Knights of Malta control the central banks of the world along with the cartel-capitalist private banks, such as Bank of America, JPMorganlChase and Citibank. 25.During the Suppression of the Company of Jesus, the Order gained control of Pope Pius VII. In 1801 the Jesuit Order was formally restored in Orthodox Russia and in 1805 the same occurred in Protestant America, President Thomas Jefferson never raising an objection. 26.Upon the Order's international restoration in 1814 by Pope Pius VII, the Company began to regain its lost power. Directing the British Crown and

Eric-Jon: Phelps Affidavit Page 10 of 19

influencing the American presidency, the Jesuits sought to create a united Anglo-American alliance to be used to conquer first Japan and then China. At this time both Japan and Chna had expelled the Company and vowed never to readmit their traitorous oppressors. 27.h 1841, via British influence of the First Opium War (1839-1842), the Chinese Manchus were forced to readmit the Jesuits into the Empire. In 1854 the Jesuits used the American Navy with Commodore Perry to finally open up Japan to the White Protestant nations of the West---especially Jesuit-ruled Great Britain. The Jesuit General's old plan was still inexistence: Conquer China through Japan using her Emperor and military power now to be backed by the British Crown under Jesuit rule. 28.The Jesuits were legally readmitted into Japan in 1865. Emperor Komei stoutly resisted lifting "the Christian Ban" for which he was poisoned in 1867 at the young age of thirty-six. That same year Tokugawa Shogon Yoshinobu resigned, giving his office to the new Emperor Meiji then only fourteen years of age. Meiji "the Great" would serve his Jesuit masters for over forty-five years, centralizing all power in Tokyo and creating the Japanese Imperial Empire---for the use of the Jesuit Order. Japanese samurai nationalists opposing the Meiji regime would be finally defeated in battle, massacred with American gatling guns in 1877.

Eric-Jon: Phelps Affidavit Page 11 of 19

29.After fomenting the American Civil War, rightly termed by Southerners the War of Northern Aggression (1 861-1 865), the Order would establish an American Empire through the declared ratification of the Fourteenth Amendment. All power would be centralized in Washington, D.C., the Order's Radical Red Republicans having created the Jesuit American Empire on the ruins of the Calvinist Federal Republic of these United Sovereign States of America. By 1888 the Jesuit Superior General ("the Black Pope") now had five empires under his control: the Protestant British Empire (under Queen Victoria), the Japanese Imperial Empire (under Emperor Meiji), the Orthodox Russian Empire (under Czar Alexander 111), the Protestant American Empire (under President Grover Cleveland) and the Protestant Second German Reich (under Kaiser Wilhelm 11). These powers would be used in tandem against China during her "century of humiliation" leading to the overthrow of the Manchu dynasty. 30.The Society of Jesus began to use its "Japanese Sword of the Church against the QingManchu dynasty of China also ruling Korea. In 1894 Japan launched and, in 1895, won the first Sino-Japanese War taking Korea and Taiwan away from China while forcing the QingManchu government to pay 13,600 tons of silver to Japan for war reparations. That same year Japanese agents of Jesuit-ruled Emperor Meiji brutally assassinated anti-

Eric-Jon: Phelps Affidavit Page 12 of 19

Japanese, pro-Chinese Korean Empress Myeongseong. The surviving crown prince sought and received protection from the Russian legation in Soul, an act for which Russia would pay dearly. 31.As a result of these loses of the QingManchu Empress Dowager Cixi along with the continued invasion of foreigners, desperate Chinese nationalists began to resist. Therefore, the Jesuits incited and led the Boxer Rebellion in 1901 (during which many Protestant missionaries were murdered in according with the Jesuit Oath of the Fourth Vow). But the nationalists were betrayed, meeting the armies of eight nations, under Jesuit rule or influence, in battle. Five of those nations were Japan, America, Germany, Russia and Great Britain. With the foremost Chinese nationalists exterminated and the population weakened with opium addiction, the end of the hated , anti-Jesuit QingManchu dynasty was approaching. 32.In 1904 Japan attacked Orthodox Russia ultimately destroying two of its three fleets. Termed "the first great war of the 2othcentury," Japan was victorious, furthering the Order's building of its Japanese Imperial Empire. Conversely, the loss of Russia fueled unrest in Russia leading to the Order's first Russian Revolution against the Romanov dynasty in 1905. For the Jesuits had been formally expelled from Russia by Czar Alexander I in 1820, only to legally re-enter in 1922 after their successful Bolshevik Revolution

Eric-Jon: Phelps Affidavit Page 13 of 19

financed and promoted by Rome's Anglo-American, Apostate Protestant, International White Power Structure centered in Washington, D.C., and London. 33.h 1912 the QingManchu dynasty was finally overthrown. China would undergo a series of socialist upheavals and would yet suffer a Second SinoJapanese War beginning in 1937 to end in 1945. During this time Freemason Emperor Hirohito would do the bidding of his masters residing at Jesuit Sophia University in Tokyo, the Japanese invading twelve Asian countries for three reasons: to kill the nationalists, to kill all Protestant missionaries and to plunder the gold of the region much of it then buried in 175 "imperial" treasure vaults in the Philippines. After World War I1 (the second act of the Black Pope's Second Thirty Years' War, 1914-1 945), much of that gold would find its way to American banks in New York, one of them being Citibank ruled by the Knights of Malta. Other knights facilitating the movement of the gold were OSS chief William Donovan and CIA chief Allen Dulles, a co-conspirator in the Kennedy Assassination. 34.China, now divided into pro-communist and anti-communist camps, would finally be conquered by the Jesuit Order. Suffering the loss of its gold to the Japanese and the loss of its honor via the Japanese Rape of Nanking, the Chinese people, driven to desperation, were ready for the "solution" to their

Eric-Jon: Phelps Affidavit Page 14 of 19

"chaos." In 1949 the Order, using its Council on Foreign Relations (CFR) member Secretary of State Dean Acheson, facilitated the successful subjugation of China to socialist-communism perfected by the Order on its socialist-communist "reductions" in Paraguay as per above. All the nationalist, anti-communists fled to Taiwan under the leadership of Freemason Chang kai-shek loyal to Francis Cardinal Spellman, the mastermind behind the Kennedy assassination. Meanwhile, Communist China was under the dictatorshp of Freemason Mao Zedong. Rome controlled both factions via Freemasonry, her open-but-false policy being to support the Nationalist Chinese having fled to Taiwan. But her secret-buttrue policy was to back the Communist Chinese on the mainland. It is for this reason the US Seventh Fleet blocked Taiwan's planned invasion of Communist Chna in 1950 with the excuse that the Fleet was to keep China from invading Taiwan. This blockade enabled Communist China to send one million troops into North Korea to kill American servicemen. 35.Hence, the Jesuit Order via its high-level Freemasons within its International Anglo-American White Power Structure, controls the governments of both Taiwan and Chna. The peace-meal policy of betrayal towards Taiwan by the Jesuit-directed, CFR-ruled American government is intended to end with the martial unity of Taiwan with China. This secret policy of unification,

Eric-Jon: Phelps Affidavit Page 15 of 19

including the re-uniting of Korea and the uniting of Japan with China, is to create a Far Eastern coalition of Asian nations for the future invasion of North America. Japan has been used to conquer Chna, Japan now to be used both commercially and militarily with its Red Chnese ally in the future subjugation of the entire Far East (including Australia and New Zealand) to culminate in a massive Oriental Asian invasion of North America having been occupied with millions of "fifth column," Red Chinese loyalists including the spy, nuclear scientist, CIA operative Wen Ho Lee. 36.The Knights of Malta rule the pope's Federal Reserve Bank through such men as Peter G. Peterson, former president of the Federal Reserve Bank of New York City, the bank holding both title and possession of America's gold in the form of 660,000 gold bars. The Jesuits employ the Knights of Malta in various academic positions, CFR-member and Knight of Malta John J. DeGoia serving as president of Jesuit Georgetown University, it overseeing the policies of the White House through the Vatican's Vaginal Oval Office of the Virgin Mary. 37.The Jesuit Order, in complete control of London, Moscow, Washngton, D.C., Bejing, Baghdad, Cairo, Istanbul, Paris, Rome, Berlin, Brussels, Tehran, etc., is therefore in total control of the pope's International Intelligence Community, including all sixteen American intelligence

Eric-Jon: Phelps Affidavit Page 16 of 19

agencies, Britain's M I 5 M 6 , Germany's BND, Israel's Mossad, China's CSIS, Russia's FSBISVR, and all other lesser intelligence services. These intelligence services control the governments of their host nations and thus the military complexes of those nations for the benefit of the Jesuit Papacy waging war to make the pope of Rome the universal monarch of the world. 38.The Jesuit Order, in complete control of all central banks, including the Federal Reserve Bank and Bank of England, rules all stock exchanges and dictates the value of all paper currencies for the benefit of the Jesuit Papacy, the pope presently calling for the establishment of a World Bank---under h s secret rule via his Knights of Malta subject to the Jesuit Superior General. 39.Thus, the Jesuit Order, in seeking to destroy the last bastion of the Protestant Reformation here in the United States of America, is now pulling out its manufacturing base relocating it into Red China, Mexico and Europe. This is in preparation for the Sino-Soviet-Muslim-Hispanic invasion of the American Empire after US forces are betrayed by the Joint Chefs of Staff and defeated on at least two war fronts. Further, the secret Japanese imperial gold horde has contributed to the financing of America's plotted demise. 40.Thus, the Jesuit Order has used its unified American military intelligence community to cause the 91 1 Crisis and subsequent invasion of Afghanistan, Iraq, Pakistan, and soon-to-be Shia Iran. This is a papal crusade against the

Eric-Jon: Phelps Affidavit Page 17 of 19

Shia Muslims, the enemies of Sunni Islam originally created by the Vatican having authored the Koran inciting Arab Muslims to kill true Chnstians and Jews. Upon the destruction of the Shia Muslims, the Sunni World can then be united against America for our coming invasion, the Muslims to be transported from West African ports in Senegal and Mauritania to Cuba to North America by the Chinese Overseas Shipping Company (COSCO). 41.To facilitate this "Final solution to the Protestant Question," the Order, via its Knights of Malta controlling international banking and commerce, has used its Japanese and Nazi secret gold horde to conduct the pope's Cold War in covertly building Far Eastern communist nations while weakening the Western free enterprise nations of America and Canada in preparation for the Sino-Soviet-Muslim-Hispanic invasion of North America. 42.This design of using massive amounts of gold is in accordance with the Black Pope's statement at the secret meeting in Chieri, Italy, in 1825:

"For these purposes, it is not enough to have at our disposal men of talent and men of action---we must have gold to keep them fast to their work. Aye, give me gold---plenty of gold; and then, with such able heads and such resources as the church commands, I will undertake not only to master the whole world, but to reconstruct it entirely."*
*Abbate Leone, The Jesuit Cons~iracv.The Secret Plan ofthe Order, (London: Chapman and Hall, 1848), p. 134. Eric-Jon: Phelps Affidavit Page 18 of 19

NEIL F. KEENAN et al. v. DANIELE DAL BOSCO et al. 11-cv-8500 (RJH) Strunk Affidavit i n support o f Motion to Intervene

Exhibit F

i

Case 1:lI-cv-08500-RJH Document 2

Filed Oll13/12 Page Iof 9

UNITED STATES DISTRICT COURT SOUTMERN DISTRICT OF NEW YORK
- - - - - - - C - - - - r - - - - - - - - - - - - - - - - . " - - - - - - - - -

--X

\

Neil F Keenan .

Individually artd as Agent for The Dragon Family, citizens o foreign states f
5

Daniele Dal Bosco, et d, a citizen o aforeign stare f

Initial Scheduling Conference Notice md Order This action has been assigned to Judge Richard J. Holwell for d purposes. l It is hereby ORDERED as follows:
1.

2.

3,

Counsel receiving this Order shall promptly mail or fax copies hereof 20 aU other counsel of m r d or, in the case of parties for which no appearance has been made, to such parties. Counsel for all parties should note their appearance as counsel in this matter by lettet immediately. Counsel for a11 parties are directed to confer regarding an agreed scheduling order pursuant to Fed. R Civ. P.2661). If counsel are able to agree on a schedule and the ag*reed schedule calls far Plling.of the pretrial order not more than nine (9) months from the date of this order, counsel shall sign and email a PDF of the proposed schedule to the Orders m Judgment Clerk w i h fourteen (1 4 d ) days h r n the date hereof, following the scheduling order requirements attached hereto. Counsd should note, in submitting their consent scheduling order, that the otherwise scheduled conference should be adjourned. If such a consent order is not filed within the time provided, an initial scheduling conference will be held in this matter on March 9,201 2 at 1 : 0 a.m. in 03 Courtroom 17B at the U.S.Courthouse, 500 Pear1 Street, New York, New Yark 10007. A proposed scheduling order, following the scheduling order requirements attached hereto, should be submifled to Chambers three days before the initial scheduling conference. '

Case 1: I 1-cv-08500-RJH Document 2 Filed 0111311 2 Page 2 o 9 f

4.

5.

Amy requests for adjournments must be made in writing and must be received in Chambers not later than 43 hours before the scheduled time. Alternative dates that are mutually agreeable to all parties must be suggested when requrhng to reschedule the initial scheduling conference. Parties should consult the Individual Practices of Judge Holwell with respect to communications with Chambers and r e l M matters. This case has been designated an electronic case. The parties are advised that all orders will be Issued via the Electronfc Case 1;Tling PECF') system and parties wilI not be sent copies by mail or facsimile. It is the responsibililyof counsel to become familiar with and fallow ECF procedures. Judge HoIwell's individual practices may be found at http:Jfwww.nysd.usc0~1rts.g0vflndiVidnaI~Practi~es/H01~eLpdf~ Parties ~hould direct questions regarding ECF to the ECF N d p Desk at 212-805-0800.

SO ORDERED.

Dated: New Yo&, New York January @ ,2012,

Richard J. Holwell United States District Judge

Case 1:IA-a-08500-RJH

Document 2

Filed 01113112 Page 3 of 9

.

Scheduling Order Reqairements
1.

D d p t i o l r of the Case a. Identify the attorneys of record for each party, including ltad trial attorney; b State the basis for federaljurisdiction; . c. Briefly describe the claim asserted in the complaint and any counterclaims; d. S tafe the majo~legal factual issues in the case; and and e. Describe the relief sought.
'

2.

Proposed Case Management Pian a Identify all pending motions; b. Psopose a cutoff date forjoinder of additional parties; c. Propose a cutoff date for amendments to pleadings; d. Propose a schedule for completion of di&vay, including: i. A date for Rule 26(a){l) disclosures, if not previously completed; ii. A fact discovery completion date; iii. A date for Rule 26(a)(2) disclosures; and iv. An expert discovery completion date, including dates for delivery of expert reports;
e. Propose a date for filing dispositive motions; . f. Propose a date for filing a ha1 pretrial order; and g. Propose a trial schedule, indicating;

i. ii. iii.
3.

Whetherajurybidisrequd, The probable length oftrial; and When the case wif 1 be ready for trial.

Consent to Pmceed Before a Magispie Judge: Indicak whether the parties consent umnimously to proceed before a Magistrate Judge.
Status af Settlement Discussions a. Indicate whether any settlement discussions have occurred, b. Describe the status of any settlement discussions; and c. Whether parties regucst a settlement conference.

4.

Case 1111-cv-08500-RJH Document 2

Filed 01113112 Page 5 of 9

2 Schedulmg Order Requirements .
A. Description of the Case i. Identify the attorneys ofrecord far each party, including lead trial attorney; ii. State the basis for federal jurisdiction; iii. Briefly describe the c f i m asserted in the complaint and any counterclaims; iv. State the major legal and factual issues in the case; and v. Describe the relief sought.

B Proposed Case Management Plan . i. Identify all pending motions;
,

ii. Propose a cutoff date for joinder of additional parties; iii. Propose a cutoff date for amendments to p l d i g s ; iv. Propose a schedule for compbion of discovery, including: a A date for Rule 26(a)(1) disclosures, if not previously completed; b. A fact discovery completion date; c. A date for Rule 26fa)Q) disclosures;and d. An expert dt scovery completion date, including dates for delivery of expert reports; v. Propose a date for fiIing dispositive motions; vim Propose a date for filing a final pretrial order; and vii. Propose a trial schedule, indicating: a Whether a jury trial is requested; b. Theprobable length oftrial; and c. When the m e will be ready for trial.

C. Consent to P m w d Before a Magistmte Judge. Indicate whetha the pasties consent unanimously to proceed before a Magistrate Judge.

D .
.

Status of Settlement Diseumions

i. Indicate whether any settlement discussions have occurred; ii. Describe the status of any settlement discussions;and iii. Whether parties request a settlement conference.

3. Motions

A R~Mntian . Conferences in Civil Cases. For discovery motions, follow h

l Civil Rule 37.2. A pre-motion conference with the Court is required before making a motion for summv judgment or dismissal, including motions to dismiss filed in lieu of answer. To arrange a pre-motion conference, the moving party shall submit a letter not to exceed three pages in length setting forth the basis for the msicipated motion. Pre-motion conferences are not requid for other motions. Service of a pre-motion conference letter within the time provided by Federal Rule of Civil Procedure 12(a) constitutes timely service of a motion made pursuant to F e d 4 Rule of Civil Procedure 12(b).

Page 2 of 6

t

Case 1:11-cv-08500-RJH Document 2

Filed 01I1 311 2 Page 6 of 9

B. Courtesy Copies. Two courtesy cupits of all motion papers, marked as such, shali be submitted to Charnbers at the time the papers are served. For motions for admission pro
hac vice, only one &esy copy shall be suhitted, together with a proposed order form and the necessary supporting documents.
C. Memoranda of Law. Unless prior permission has been granted, memoranda of law in support of and in opposition to motions are limited to 25 pages, and reply rnemomda are limited to I0 pages. Memoranda of 10 pages or more shall contain a table of contents. The .memoranda shall be double-spaced and use 1Zpoint font for text and footnotes. Citations to authority not available in Westlaw or LexisNexis ahauld be accompanied by copies of the cited miterials.

D Exhibits. If deposition testimony is submind, four pages of testimony should, if .
possible, appear on a single page.

E Rling of Motion Papers, Motion papeft shall be filed promptly after service. For ECF . filings, the Court prefers, but does not require, that parties upload text-searchable PDF
documents.

F Oral Arguments en Motions. Parties may request oral Wgument by letter at the time .
their moving or opposing or reply papers are filed. The Court will determine whether argument will be heard and, if so, w i H advise counsel of the argument date,
G. Effect of a Motion on Notice of Appeal. Paragraph A above does not app'lyto any of the motions described in Fed. R.App. P. 4(a)(4)(A). A pre-motion conference is not

required before making such motions, which should be filed when served.
4. Pretrial frocedures

A. Final Pretrial Orders i Civil Casea Unless otherwise ordered by the Court, within 30 n days from the date of the completion of discovery in a civil case, the. parties shall submit to the Court for its approval a joint final pretrial order that includes the information required by Fed. R Civ. P.26(a)(3), and the following:
i. The names, addresses (including firm names), and teIephone and fax numbers of trial counsel. 5. A brief statement by plaintiff as to the basis of subject m t e jurisdiction, and a brief atr statement by each other party as to the presence or absence of subject matter jurisdiction. Such statements shall include citations to all statutes relied on and relevant facts as to citizenship and juridctiod amount. iii. A brief summary by each party of the claims and defenses that party has asserted which remain to he tied, without recital of evidentiary matter but including citations to dl statutes relied on. Such summaries shall identify all claims and defenses previously asserted which are not to be tried,

Page 3 of 6

Case 1:l t-w-Q86~-WH Document2 Filed Q 1E13112 Page 7 of 9

iv. A statement by each plaintiff setting fbtth and calculating with specificity each . element of damages sought with respect to each claim that fermfermns fried, to be
v. A statement by each party i to whether the case is to be tried with or without a jury, u

and the number of trial days needsd.

vi. A statement as t whether or not all parties have consented to trial of the case by a o magistratejudge (without identifying which parties have or have not so.consented). vii. Any stipulations or agreed statements of fact or law, which have been agreed to by all parties.

-

viii. A list ofall w i t n e s , with a brief summary of the substance of each witness's testimony and an indication whether such witnesses will testify in person or by deposition. No witness not identified herein shall be permitted to testify in either party's case in chief absent good cause shown.

ix. A designation by each party of deposition testimony ts be offered in its case in chief, with any crossdesignations by any other party. Each party shall set forth any
objections it bas to deposition testimony designated by the other and the basis therefore. If deposition testimony is submitted, four pages of testimony should, if possible appear on a single page.
x. A list by each party of exhibits to be offered in its case in chief, with one star indicating exhibits to which no party objects on grounds of authenticity, and two stars indicating exhibits to whichno party objects on any ground. The list shall include a description of each exhibit. The grounds for the objection to the admissibility of any exhibit shalt be-stated in summary form. Any objections not sel forth in lhe iinal pretrial order shall be considered waived absent good cause shown.

B Faings Prior to Trial i CiwP Cases. Unless otherwise ordered by the Court, each party . n
shall file the following at the time of the filing of the final pretrial order:.
i. Injury cases, requests to charge and proposed voir dire questions. Joint proposed jury charges should also be submitted on a CD-ROM i Micmsofi Word f m t , with n a table of contents;

ii. E all c s , n a x motions addressing any evidentiary or other issues which should be resolved in limine;
iii. In any case where such party believes it would be useful, a pretrial memorandum; and iv. In non-jury cases, Proposed Findings of Fact and Con~lusions Law. The Proposed of ' Findings of Fact should be derailed; there may be no opportunity for post-trial

Page 4 of 6

Case 1:11-cv48500-RJH Document 2

Filed 0111311 2 Page 8 of 9

submissions. The Proposed Findings shall address with specificity each element of damages claimed.
C. Filings in Opposition. Any party may file the following documents within one w e of ek the filing of the final pretrial order, but in no went less than three days before the scheduled trial date: ,

i. Objections to another party's requests to charge or proposed voir dire questions; ii. Opposition to any motion in limine;

iii. Opposition to any legal argument in a pretrial memorandum.
*

D Courtesy Copiea Two courtesy copies of the final pretrial order and all documents filed .
or served with the final pretrial order should be submitted to Chambers on the date of filing or service.
5. Conferences A. Plincipal Trial Counsel. The attorney who will serve a principal trial counseI must appear at 9111: conferences with the Colrrt.

B Initial Scheduling Conference. The Initial Scheduling Conference Notice and Order .
will be mailed to plaintiffs counsel, who will be responsible for distributing copies to all parties. If all counsel are able to agree on a schedule and the agreed schedule calk for filing of the final pretrial order not more than six (6)months from the date of the Initial Scheduling Conference Notice and Order;& such consent scheduling order is filed with the Orders and Judgment Clerk within fourteen (14) days from the date of the Initial Scheduling Conference Notice and Order, no initial scheduling conference shall be necessary. The scheduling order should conform to the requirements set forth in paragraph 2 above. Otherwise, the pmies"report pursuant to Fed. R. Civ. P 26(0 and . two courtesy covies of the pleadings shodd be delivered by plaintiffs counsel to Chambers three days prior to the conference date.

Page 5 ,of 6

Case 1:l la-08500-RJH Document 2 Filed 01/13/12 Page 9 of 9

Attachment 1
DEFAULT JUDGMENT PROCEDURE
Applications. Applications for defdt judgments must comply with Local Civil Rule 55.1 and 55.2 and must ~rovide reasonable notice to the party against whom default shall be entered by: First-class mail or courier, if the party is domestic; i. Courier, if the party is international; or ii. Any method authorized by Rule 4 of the Federal Rules of Civil Procedure. iii.
Applications will not be accepted absent the folloMhg: An affidavit setting fortk i a, A description of the nature ofthe claim; b. The basis for subject matter jurisdiction over the action; c. The basis for personal jurisdiction over the defendant; d. A representation that defendant is not an infant or an incompetent; and e. A representation that notice has been provided i accordance with the n requirements set forth ahove; A certificate of defadt stating that the defendant was properly sewed with ii the complaint and faiied to answerlappear, signed and stamped by the Clerk of the Court. (If the defendant did appear in the action, xhe plaintiff must submit an affidavit representing that the defendant has notice of the application for default); An afidavit setting forth reasonable attorneyssfees and showing that iii. attorneys' fees are recoverible; A copy of the complaint; and iv. A proposed form of default judgment. Y.

.

.

Damages. V the plaintiff seeks an award ofdamages in the motion for default judgment, the plaintiff must also include: A requed for an mount equal to or l a s than the principal amount i. demanded in the Complaint; . Definitive information and documentation such that the mount provided ii. for in the proposed judgment can k calculated. (If Chis requirement cannot be satisfied, a default judgment may be granted as to liability, and damages wil I be determined by an inquest); An affidavit representing h a t no pact of the judgment sought has been iii. paid, other than as indicated in the motion; A q u e s t for interest on the principal amount not to exceed 9 hif interest ?, iv. is sought; and v. The calculations made in h v i n g at the proposedjudgment amount,

UNITED STATES DIWRICT COURT SOUTHERN DTSTl?IC=T OF NEW YOFX
NEIL F. KEENAN,~d~

m DRAGON F ~ Y citizeh~ foreign states, , of
-

and as Agent for

f I-cv-S~MT (RIM)

.

PlainW,

~ ~ t DAMELE DAL BOSCO, a citizen of a foreign slate, Et a . l
Defendants.
-------h---------h--h----dh-------------=--------------------

-

X

Christopher-Earl Strlznk i esse Memorandum of Law in support of the n
t

Motion t o Intervene

1) ~&titioner, Christopher Strunk,i self-representedwithout being & attorney, s

has a supporting &davit with exhibits and a proposed supplement annexed; and as a
non-parQ seeks to i n m e as a Intervener-PlaintHherein with both Federal Rules of
Civil M u r e (FRCvP) RuIe 24(4 as an Americafl Chinese hisboric Bond holder, and

or as an alternative with permission with FRCvP Rule 24 0) (B] (2)(A) (B], in that (1)
FEDERAL RESERVE BAM< NEW YORK p m ~ r uby LEE C . OF )
C v

BOLLWGER,

its

.

and President as well as the FOREIGN BONDHOLDERS PROTECTIVE

COUNCIL INC (FBPC)by its principal JOHN R. PElTY are required supplemen-tal

Defendants that have been.leR out from the Complaint
BACKGROUIID

1 PROCEDURAL BACKGROUND .

d

That Fhhtiffs' complaint fled November 23, 2011 has multiple allegations of
wrongdoing i a conspiracy by f n o &
defendants including Italy its governmental

Petitioner's Memorandum of Law Page 1 of 6

agencies, the United Nations General Secretary, quasi public entities and persons some of whom are transacting business here in SDNY. That Plaintiffs seek as a replevin stolen property as well as damages and other relief, in which Petitioners supports as a matter of protecting his personal property rights along with those of a class similarly situated however insufficiently represented by Plaintiffs. The PACER Electronic docketing system reports that the proof of service of the summons and complaint has not been fded yet, and no Defendants have made an appearance yet. Further, the Court has set a preliminary conference date of March 15, 20 12 as shown by Petitioner in his affidavit exhibit F.

2. FACTUAL BACKGROUND
Petitioner personal property rights along with those of a class similarly situated however insufficiently represented by Plaintiffs in that the property held by Defendants comprises all or part of a sinking fund set in reserve to repay Petitioner when the Historic bonds are presented for redemption upon a reunited Mainland and Taiwan, and that Petitioner contends that the theft and conversion of the securities undermines and or wastes the reserves necessary for repayment. To the extend that Plaintiffs have claim on property that was issued as a contractual agreement with the Government of Taiwan and Mainland China and the Federal Reserve Bank of New York and it was not named as an interested party, Petitioners does so along with the quasi government entity formed under the Foreign Bondholders Act of 1933 (15 USC 577bb through 577hh with law) at the request of the United States Secretary of State, the Secretary of the Treasury and the Chairman of the Federal Trade Commission under President Franklin Roosevelt as a private, nonprofit corporation to protect the rights and interests of American holders of foreign defaulted bonds applies herein to determine the status of the sinking fund. In addition

Petitioner's Memorandum of Law Page 2 of 6

as a more convoluted wrinkle on whatever accounting is done requires any member of

the Sovereign Military Order of Malta (SMOM),of which several of the Defendants are members, and or it associated organization including the New York Council on Foreign Relations are to be restrained from performing the accounting with appointment of a mutually acceptable special master by the Court paid by the funds associated with the responsibility and duty of the Federal Reserve Bank of New York and Foreign Bondholder Protective Council.
ARGUMENT I. STANDARD FOR INTERVENTION

Under Fed. R. Civ. P. 24, a non-party may be allowed to intervene as a party in an existing lawsuit, either as of right or by permission. Intervention as of right is governed by Rule 24(a), which provides that, unless a right to intervene is unconditionally granted by federal statute, a non-party has no right to intervene in a case as a plaintiff or defendant unless it shows that (1)its motion to intervene was timely fded, which this motion is; (2) it has an interest relating to the property or transaction that is the subject of the action, which is satisfied; (3) it is so situated that without intervention the disposition of the action may as a practical matter impair or impede its ability to protect its interest, which is satisfactorily explained by Petitioner ; and (4) its interest is not adequately represented by existing parties, in that necessary parties have not been joined and in the case of the alleged two-side market platform to be established in Switzerland would fall subject to the joint agreement between the US and Switzerland as shown by Petitioner in the affidavit Exhibit C. See Fed. R. Civ. P. 24(a); Butler, Fitzgerald & Potter u. Sequa C o p , 250 F.3d 171, 176 (2d Cir. 2001). "All four parts of the test must be satisfied to quahfy for intervention as of right."
Washington Elec. Coop., Inc. u. Massachusetts Municipal Wholesale Elec. Co., 922 F.2d

Petitioner's Memorandum of Law Page 3 of 6

92, 96 (2d Cir. 1990); accord D'Amato u. Deutsche Bank, 236 F.3d 78, 8 4 (2d Cir. 200 1) ("Denial of the motion to intervene is proper if any of these requirements is not met"); United States u. New York, 820 F.2d 554, 556 (2d Cir. 1987)."The moving party
has the burden of demonstrating its entitlement to intervene." Seils u. Rochester City Sch. Dist., 199 F.R.D. 506, 509 (W.D.N.Y.2001).

As for Permissive intervention is governed by Rule 24(b), which provides that, unless a right to intervene is conditionally granted by federal statute, a court may not exercise its discretion to permit a non-party to intervene in an action unless the nonparty shows that its "claim or defense

. . . shares with the main action a common

"The district court has broad question of law or fact." Fed. R. Civ. P. 24(b)(l)(B). discretion to deny an applicant's motion for intervention under Rule 24(b)." Seils, 199 F.R.D. at 5 12 (citation omitted). In exercising this discretion, "the court shall consider whether the intervention will unduly delay or prejudice the adjudication of the rights of the original parties." Fed. R. Civ. P. 24(b)(3)- all of which Petitioner has done. The Court also may consider "the nature and extent of the intervener's interests, whether the intervener's participation will contribute to a just and equitable adjudication of the issues, and whether the intervener's [interests] are adequately represented by the parties of record." S h a r i u . Nau York State Educ. Dep't, 709 F. Supp. 365, 369 (S.D.N.Y. 1989) (citation omitted); Seils, 199 F.R.D. at 5 13. The Supreme Court has not resolved the question 31 whether a party seeking to intervene under Rule 24(a) must satistj the requirements of Article I11 of the Constitution. See Diamond u. Charles, 476 U.S. 54, 68-69 (1986) (citing cases from Courts of Appeals for the Seventh, Eighth, Ninth, and District of Columbia Circuits). And the Second Circuit has held that a prospective intervener need not
satisij Article I11 standing requirements merely to participate in district court

Petitioner's Memorandum of Law Page 4 of 6

proceedings. United States Postal Sew. u. Brennan, 579 F.2d 188, 190 (2d Cir. 1978). Nevertheless, a n intervener's interest must "be direct, substantial, and legally protectable." New York News, Inc. u. Kheel, 972 F.2d 482, 486 (2d Cir. 1992) (citation and quotation omitted). Petitioner has satisfied this requirement because he has more than a generalized interest in this matter that could be shared by any citizen. Cf:
Schlesinger u. Reservists Comm. to Stop the War, 418 U.S. 208, 220-21 (1974).
11. STRUNK MAY INTERVENE AS OF RIGHT.

Petitioner has satisfied the f ~ s tsecond, third, or fourth requirements of Rule , 24(a) for of right intervention. Because he must satistj all four requirements to prevail, his motion must not be so denied. See D'Amato, 236 F.3d a t 84; United States u. New
York, 820 F.2d a t 556.
111. STRUNK PERMISSIVE INTERVENTION SHOULD NOT BE DENIED.

A court may not exercise its discretion to permit a non-party to intervene in a n

action unless the non-party shows that its "claim or defense

. . . shares with the main

A action a common question of law or fact." Fed. R. Civ. P. 24(b)(l)(B). s elaborated in

Part I1 and that Petitioner has articulated a legitimate, individualized claim of Defendants, and shares a common question of law or fact with this case. On this ground alone, his claim for permissive intervention must be granted Moreover, in exercising its broad discretion under Rule 24(b), a court considers "the nature and extent of the intervener's interests,

. . . and whether the intervener's

[interests] are adequately represented by the parties of record." Shariiu. New York
State Educ. Dep't, 709 F. Supp. 365, 369 (S.D.N.Y.1989) (citation omitted); Seils, 199

F.R.D. a t 513. The arguments set forth in Part I1 with respect to why intervention as of right should be granted apply with equal force to permissive intervention: Petitioner's

Petitioner's Memorandum of Law Page 5 of 6

interests, are neither vague nor generalized, and collateral, and he has a specijic .

basis t argue that those interests are not adequately represented by record parties. o

P d s s i v e intervention also implicates uwhetherthe intentention will unduly delay or prejudice the adjudication of the rights o the original parties,"Fed. R. Civ. P. f

24(b) or,put otherwise, %het.her the intewener's participation will contribute t a (3), o
just and equitable adjudication ~f the issues.*Shan'f; 709 F. Supp. at 369.Setting

aside t e arguments already made see, Petitioner3 submission demonstrates why h
perrPissiGe intervention is conducive to a j s and equitable adjudication of the ut
important issues in this case. Petitioner's &davit contains a good deal-ofmaterial,
pertinent matter that under the usual circumstances of the facts associated with this

complaint i not scandalous or even out o the mainstream of current understanding s f

of the record parties herein that under any other circumstance rnny be stricken under
Fed. R. Civ. P. 12(f), as many of the factual allegations in the complaint taken as true
support the Petitioner's affidavit, and in addition render inclusion wholly relevant and necessary issues before the Court, As for the role of the Sovereign Military Order o f

M l a and the Aragon Templam Petilioner possesses factuat evidence and expert at
testimony that would aid the Court i its disposition of the legal issues before it. n
4

COHCLu8fOa
For the foregoh~g reasons, Petitioner's motion to intervene as a PlaintBin the case,

whether a~ of right or by permission, should be granted along with other relief.

23,012 Dated: January-, Brooklyn New York
Christopher-Earl:,Strunk i esse n self-represented without an attorney 593 Vanderbilt Avenue - 28 1 Brooklyn, New York 11238 . Phone - 845-90 1-6767 Email: chris@;strwrk.ws Petitioner's Memorandum of Law Page 6 of6

SOUTHERN DISTRICT OF NEW YORK
NEIL F KEENAN, Individually and as Agent for . THE DRAGON FAMILY, citizens of foreign staks,

Christopher-Ehrk Shmk, i esse as a bondholder n 593 Vaaderbilt Avenue-281 Brooklyn New York 1.1238 Phone: 845-90 1-6767 and Email: chris@stmnk.ws

VERIFIED SWPPLEMEIVT

TO THE COMPLAlIQT

'

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D ~ L DAL BOSCO, a citizen of a foreign state, E THE OFFICE OF INTERNATIONAL TREASURY CONTROL, a foreign corporation ("OTTC'?, RAY C. DAM ('DAM'),individually, and as President of OPC, DAVID A. SALE ("SALE'?, indMdualEy, and as Depuly Chief of the Council for the Cabinet of O r C , the UNITED ' NATIONS, BAN KI-moon, individually, and as Secretary General of the UN, H.E. Ambassador CESARE MARLA RAGAGLINI, Individually, and as Permanent Representative of the Italian Mission t the UN ixl New o York, H.E.Ambassador LAURA MIRACHIAN, Individually, and as Permanent Representathe o the -1 f Mission to the UN i Geneva, the ITALIAN REPUBLIC, n the ITALMN FINANCIAL POUCE, Former Prime Minister of I, * S E W 0 BERLUSCOM, THE W 3 L 02D ECONOMIC FORUM CWEF") a foreign corporation, WORLD ECONOMIC FORUM U .S.A,, INC., GIANCAFUI BRUNO, individually, and as H a d of the Banking Industry ofWEF, and various unknown individual co-conspirabrs, JOHN DOES A-2,
Defendants.
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RESERVE B m OF HEW YORK,33 Liberiy S t New York, NY 10045 by LEE C. EOLLEHGER, Chairman; 3REIGIV BONDHOLDERS PROTECTIVE COUNCIL S C N, P Broad Street New York, W 10004-2205 by 3R PETTY principal; JOHN and JANE DOES and <Z ENTTTIES. Supplement Defendants -----------------------X
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I

.kmener-Plaintiff,Christopher-Earl: Strut&, i esse ~ n ~'5-7, r divid-, and as an American Chinese Bond holder, selfsepresexlkd without a n terney for his Supplement t the Complaint fled 1 1/23/1 1 here& alleges of o rpplement defendants and defendants as follows:
Strunk's Supplement t the Cornplaint Page 1 o 24 o f

,

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I

JURISDICTION AND VENUE
1) Jurisdiction exists for Intervention as of right pursuant to Federal Rules of Civil

Procedure (FRCvP) Rule 24(a) (2) and or FRCvP Rule 24 (b) (l)(B)(2) (A) (B), 28 U.S.C. §1605(a)(2)(3)and (3) 22 USC 51643 (1). The matter of the Supplement in controversy concerns the commercial activity of the Defendant in the United States, and the amount in controversy, exclusive of interest and costs, exceeds $75,000.00. 2) Venue is proper in this District because Defendants are doing business in this District and are subject to the jurisdiction of this District; and Assignment of this action to the White Plains Division is appropriate because Defendants are doing business in Westchester County and PlainWs attorneys are located in Westchester County; and that Supplemental Defendants to respond are located for service and do business in Southern District of New York. SUPPLEMENTAL PARTIES 3) Intervener-Plaintiff Christopher-Earl: Strunk, in esse, (herein after known as "Strunk", "Intervener-PlainW) is self-represented without being an attorney, and is an American bondholder of "Historic" Chinese Bonds; with place for service located at 593 Vanderbilt Avenue-281 Brooklyn New York 11238 Phone: 845-901-6767 and

22 USC 51643 - It is the purpose of this subchapter to provide for the determination of the amount and validity of claims against ... the Chinese Communist regime, which have arisen since January 1, 1959, ... since October 1, 1949, in the case of claims against the Chinese Communist regime, out of nationalization, expropriation, intervention, or other takings of, or special measures directed against, property of nationals of the United States, and claims for disability or death of nationals of the United States arising out of violations of international law by ... the Chinese Communist regime, in order to obtain information concerning the total amount of s u c h claims against ... the Chinese Communist regime, on behalf of nationals of the United States. This subchapter shall not be construed a s authorizing a n appropriation or a s any intention to authorize a n appropriation for the purpose of paying s u c h claims.

Strunk's Supplement to the Complaint Page 2 of 24

4) That Strunk is the bearer of unredeemed "Historic" Chinese Bond property effected by the failure of the Mainland Peoples Republic of China (PRC ) to re-unite with the Republic of China (ROC) also known as Taiwan; and that Strunk owns ONE
(1)S20 CHINESE GOVERNMENT FlVE PER CENT REORGANIZATION GOLD LOAN OF
1913 FOR S25,000,000 STERLING with serial number 41 1339 (see Exhibit 1)(herein

after known as "S20 Bond), and ONE (1)$20 NATIONAL GOVERNMENT OF THE REPUBLIC OF CHINA ALLIED VICIDRY U S DOLLAR LOAN of 1942 with serial number 0064833 payable in accordance with the regulation of October 31, 1953 with semiannual interest at 4% per annum (see Exhibit 2) (herein after known as "$20 Bond); and that as a point of valuation reference the combined accrued current $932,848.36 value of the obligations is estimated to be for:
a) the $20 Bond equal to 4.705882 troy ounces o gold or $97.27 in 19 13 Bond f

now valued at say 561.2966 boy ounces of gold or based upon the

1110112

London PM Gold Price Fixing of $1637 per ounce say $918,842.46; and then f b) the $20 Bond equal to 0.5714 troy ounces o gold or$20.00 in 1942 Bond now valued at say 8.5558 boy ounces of gold or based upon the PM Gold Price Fixing of $1637 per ounce say $14,005.90. 5) Supplemental Defendant Federal Reserve Bank of New York (FRBNY) (herein after known a "Defendant FRBNY") is a private entity located at 33 Liberty Street New York, N 10045 Phone Tel: (212) 720-5000. Y 6) Defendant FRBNY is one of 12 Federal Reserve Banks (the Fed), and that each Reserve Bank is headed by a president appointed by the Bank's nine-member board of directors. Three of the directors are elected by the commercial banks in the Bank's region that are members of the Federal Reserve System. The other directors are selected to represent the public with due consideration to the interests of agriculture,

1110112 London

Strunk's Supplement to the Complaint Page 3 of 24

commerce, industry, services, labor and consumers. Three of these six directors are elected by member banks and the other three are chosen by the Board of Governors.
7 ) The 12 Federal Reserve Banks are the operating arms of the Federal Reserve

System. They supervise and regulate bank holding companies, as well as state chartered banks in their district that are members of the Federal Reserve System. Each Reserve Bank provides services to depository institutions in its respective district and functions as a fiscal agent of the U.S. government. 8) The Defendant FRBNY conducts on-site and off-site examinations of member depository institutions, and branches and agencies of foreign banks in the Second District. The Fed's responsibilities extend to all state-chartered banks that are members of the Federal Reserve System, all U.S. bank holding companies and many of the U.S. operations of foreign banking organizations. In addition, the Fed stands ready to provide temporary or long-term liquidity to any depository institution that meets its criteria for discount window borrowing.
9) International Operations of the Defendant FRBNY represents the Federal

Reserve System and the U.S. Treasury, also is responsible for intervening in foreign exchange markets to achieve dollar exchange rate policy objectives and to counter disorderly conditions in foreign exchange markets. Such transactions are made in close coordination with the U.S. Treasury and Board of Governors, and most often are coordinated with the foreign exchange operations of other central banks. Dollars are sold in exchange for foreign currency if the goal is to counter upward pressure on the dollar. If the objective is to counter downward pressure, dollars are purchased through the sale of foreign currency. 10) Another responsibility of the Defendant FRBNY is to serve as fiscal agent in the United States for foreign central banks and official international fmancial

Strunk's Supplement to the Complaint Page 4 of 24

organizations. It acts as the primary contact with other foreign central banks. The services provided for these institutions include the receipt and payment of funds in U.S. dollars; purchase and sale of foreign exchange and Treasury securities; and the storage of monetary gold.
11) Supplemental Defendant Lee C. Bollinger (herein after known "President.

Bollinger" "Defendant Bollinger") is a natural person appointed Chairman and President of the Board of the FRBNY through 20 12 with place of business located at Federal Reserve Bank of New York 33 Liberty Street New York, N 10045. Y 12) Defendant Bollinger is president of Columbia University in New York City and a member of the faculty of the Law School. He became the 19th president of Columbia University in 2002. He is a graduate of the University of Oregon and Columbia Law School, where he was an articles editor of the Law Review. 13) Defendant Bollinger is a Knight of the Sovereign Military Order of Malta (SMOM)(2) and a member of the New York based Council on Foreign Relations (CFR).

SMOM "Sovereign Military Order of Malta'- a s a member of the Knights of Malta, and by virtue of a blood oath of obedience to the Pope, you are required to support to the death the desires of the head of the Order of the Knights of Malta-in this case, Pope Benedict XVI -over and above any other allegiance you may feel or pretend to feel toward any other loyalty such a s a loyalty to the Constitution for the united States of America. Those who are presently members of the Knights of Malta must on penalty of death support those policies advocated by the Vatican. It is not hard for them to do this. They BELIEVE in these policies and principles. The polices which are espoused and proclaimed by the office of the Pope and Jesuit General a t the Church of GESU are a s follows: 1. End of sovereignty for the United States and other countries. 2. End of absolute property rights. 3 . End of all gun rights. 4 . The new international economic Order (world government) 5. The redistribution of wealth and jobs. 6. Calls for nations to trust the United Nations. 7. Total disarmament. 8. Promote the United Nations a s the hope for peace. 9 . Promote UNESCO, the deadly educational and cultural arm of the United Nations. 10. Promote interdependence. 11. Support sanctions honoring Father Pierre Teilhard de Chardin-the New Age Humanist Priest. 12. Support the belief that the economic principle of traditional Christian or Catholic social doctrine is the economic principle of communism. 13. Promote the Pope a s the acting go-between for the United States and the Soviet Union.

Strunk's Supplement to the Complaint Page 5 of 24

14) Both the SMOM and CFR are under the Aragon Templar General Nicholas 15) Defendant Bollinger, as with Michael I. Sovern past president of the university (1980-1993), is currently the university's Chancellor Kent Professor of Law and are CFR members. Mr. Sovern is most recently the subject of an important investigation of Columbia University student records under seal, as he was president of the institution during the years of Barack Hussein Obama 11, a.k.a. Barry Soetoro, a.k.a. Soebarkah was in attendance (1981-1983) at the School of Foreign Affairs under Professor Zbigniew K. Brzezinski, also a Knight of the SMOM and inter alia National Security Advisor to the Carter Administration among others including that of Mr. Obama. 16) Supplemental Defendant FOREIGN BONDHOLDERS PROTECTIVE COUNCIL, INC. (herein after known as "FBPC" "Defendant FBPC") with New York Secretary of State f h g number 32709 is an active Foreign Business Corporation originally formed in the State of Maryland with Dept ID#: DO0103044 and incorporated in New York on February 19, 1934 with place for New York service at 90 Broad Street New York, NY 10004-2205 with the principal J o h n R. Petty. 17) Defendant FBPC is without stock operating as a not for profit that is the surviving trade name of the forfeited (4 parent domestic corporation UNITED STATES CORPORATION not in good standing (4 of 1123 North Eutaw Street Baltimore, MD 2 120 1 formed on 1211811933 with the Maryland Secretary of State.

Forfeited means for a Maryland entity, its existence h a s been ended by the State for some delinquency. For a non-Maryland entity it means its authority to do business and legal presence here h a s been terminated. For a trade name it means the filing h a s lapsed after 5 years and not been renewed.
4 Good Standing means a n entity is deemed to be in good standing if all reports, filings and penalties due THIS DEPARTMENT of the Maryland Secretary of State are u p to date and paid and the entity h a s a valid, active resident agent. An entity may be bankrupt, under indictment, and owe taxes to state, local and federal government and yet be in good standing with this Department.

Strunk's Supplement to the Complaint Page 6 of 24

18) Further, the Defendant FBPC uses Federal I.D, Number 13-5080630 with the

contact person listed as J o h n R. Petty that also has an office located at 1402 Langley Place Mc Lean, V 22101-3010 and 1953 Gallows Rd Ste 220 Vienna, V 22182-3934 A A with telephone number 703-744-8400; and in addition has a PO BOX 2283 SEATTLE, W 98 111-2283 located in King County Washington State. A 19) Furthermore, Defendant FBPC was formed under the Foreign Bondholders Act of 1933 (15 USC 77bb through 77hh with related law) (5) at the request of the United States Secretary of State, the Secretary of the Treasury and the Chairman of the Federal Trade Commission under President Franklin Roosevelt as a private, non-profit corporation to protect the rights and interests of American holders of foreign defaulted bonds. The FBPC has been involved in over 40 settlements between American bondholders and defaulted foreign governments, the most recent being Poland (1975),

5

Source: Encyclopedia of Banking & Finance (9h Edition) by Charles J Woelfel:

Under Title Ii of the Securities Act of 1933, provision was made for the creation of a Corporation of Foreign Security Holders, to be effective when the President of the United States "finds that its taking effect is in the public interest, and by proclamation so declares." It was contemplated that the activities of the new corporation would be similar to those of the British Corporation of Foreign Bondholders, which has a n official status in negotiating with foreign issuers. The act states that the corporation shall be created "for the purpose of protecting, conserving and advancing the interests of the holders of foreign securities in default." The secretary of State, however, advised the President that some of the foreign nations whose bonds were in default would regard the creation of such a n official corporation a s a n unfriendly act. In fact, Title I1 was not contained in the original administration draft of the Securities Act and was added on the floor of the Senate a t the insistence of the late Senator Hiram Johnson of California, who had been responsible for the Senate Finance Committee's investigation of sale of foreign bonds in the United States. Instead of the official corporation provided by the act, the unofficial FOREIGN BONDHOLDERS' PROTECTIVE COUNCIL, INC. was organized in 1933.

Strunk's Supplement to the Complaint Page 7 of 24

Hungary (1975), Bulgaria (1978), and Czechoslovakia (1984).The FBPC records are maintained in the Library Archives of Stanford University. 20) Supplemental Defendant John R. Petty (herein after known as "Principal of FBPC" "Mr. Petty" "FBPC Respondents" "Defendant Petty") is a natural person with place for New York service at 90 Broad Street New York, NY 10004-2205. 2 1) Defendant Petty serves as Chairman and Chief Executive Officer of TECSEC, Incorporated, a data security company. Mr. Petty served as the Chairman of Marine Midland Bank, a Partner of Lehman Brothers, and as Assistant Secretary of the U.S. Treasury. Mr. Petty is a Founder at Federal National Payables, Inc. Mr. Petty has been the Chairman of the Board of Federal National Payables, Inc., Federal National Commercial, Inc., and Federal National Services, Inc., a factoring company, since 1992. Mr. Petty has been a Director of Arris Group Inc. since 1993 and serves as its Lead Independent Director. He served as a Director of Anixter International Inc. since 1988. He served as a Member of Board of Trustees at American University of Sharjah until J u n e 2009. 22) Defendant Petty according to http:/ /www.namebase.or~/main2/John-RPettv.htm1 served with the U.S. Department of State in Chile ti-om 1970-1973 during and after the over throw of the Allende Government and in Czechoslovakia from 199 11995 as an employee in consultation with the U.S. Treasury Department having served as an undersecretary for foreign affairs along with Peter G. Peterson starting with the Johnson Administration onward in other Administrations. Mr. Petty as with Mr. Peterson are current members of the Council on Foreign Relations (CFR), Knights of the Sovereign Military Order of Malta (SMOM), and are associated with the Bretton Woods Committee among other organizations with undue influence on U.S. Finance, foreign and monetary policy including the International Bilderberg Group members.

Strunk's Supplement to the Complaint Page 8 of 24

23) As relevant background as to Defendant Petty, on January 1, 1976, all previously independent Marine Banks were merged into a single Marine Midland Bank with headquarters in Buffalo. The new bank was divided into regions, with Marine Midland Bank-Western Region based in Buffalo. Marine Midland Bank became a national-chartered bank in early 1980. As it entered the 1980s, assets were close to $20 billion. In 1980 The Hong Kong and Shanghai Banking Corporation acquired a 5 1% shareholding in Marine Midland Bank, which it extended to full ownership in 1987. In 1994, Marine Midland acquired Spectrum Home Mortgage, which operated in eight states. Then in 1995, Marine acquired United Northern Federal Savings Bank, with branches in Watertown and Lowville, New York. Marine Midland also acquired The Hong Kong and Shanghai Banking Corporation's six New York City retail branches, and the next year Hang Seng Bank's two branches in New York City. That same year, Marine Midland acquired 11 branches ti-om the East River Savings Bank in the New York Metropolitan area. Marine also acquired the US dollar clearing business of J P Morgan. At the same time, HSBC transferred two branches in the northwestern United States to HSBC Bank Canada. The next year, Marine completed its acquisition of First Federal Savings and Loan from Toronto-based CT Financial Services, for $620 million. First Federal Savings, headquartered in Rochester, had $7.2 billion in assets, 1,600 employees, 79 retail branches in New York State and 15 mortgage origination offices in nine states. 24) For those with the stomach to know history and what is playing out in light of the January 14, 20 12 elections in Taiwan now resolved, the Jesuit General of the Aragon Templars (Society of Jesus) at his website http: / /www. siweb.in€o/news/index.cfm?Tab=2&publan~= stated the importance of 1 this Chinese New Year as the 'Year of the Dragon" :

Strunk's Supplement to the Complaint Page 9 of 24

"Father General will visit Sydney, Australia, for a week, beginning 17 January, the week of Chinese "New Year of the Dragon," to attend the Assembly of Major Superiors for the Asia Pacific Jesuit Conference (JCAP). He will be accompanied by the Assistant for Asia Pacific, Fr Danny Huang, and Fr Francisco Javier ~ l v a r e zthe Secretary for Social Justice and Ecology. The Provincials will , consider the recent document on the "Renewal of Province Structures" and its application to Asia Pacific. "Our Provincials have already commented that this document is relevant and useful for us. They are eager to begin using the criteria it proposes in order to explore new governance arrangements in Asia Pacific," said JCAP President, Fr Mark Raper. An important question for JCAP is how to give appropriate governance support to the missions and regions. JCAP has seven Provinces and 6 Regions and its territory includes some 16 countries, and more than that number of main languages, although the normal language for Conference communications is English. Several of the Provinces are newly created in the last few years and several Regions, notably Myanmar and Timor Leste, have a growing number of young Jesuit members and are now engaged in important institution building. Yet the overall number of Jesuits in the Conference has remained the same for about 25 years. Jesuit formation is high on the agenda for the assembly, as also are the two Conference priority engagements of Migration and the Environment. In Sydney, Fr General will spend a day with members of the Australian Province, first with the Jesuits, and later will be joined by several hundred close collaborators in mission." Commemoration of 7 August 1814. Father General's letter to all the Jesuit Superiors on January 1, requests that the whole Society recall the document of Pope Pius VII, Sollicitudo omnium ecclesiarum, of August 7, 1814, by which the Society of J e s u s was restored all over the world. " I am bringing this event to your attention now because I am convinced that commemorating it can help u s enter more deeply into the continuing renewal of the Society that takes place in each generation." After speaking about the committee created for this purpose and its tasks, Father General continues, "...during meetings with the Presidents of the Conferences and the Major Superiors in all the Assistancies I have asked that new studies be undertaken, especially in the regions where the Society was active at the time of the Suppression. We all need to know more about the main apostolates of the Society in the last half of the 18th century; the impact of the Suppression on Jesuits and their contemporaries as they experienced the event; what happened in the late 18th and early 19th century to the institutions and ministries that Jesuits had to leave; when and how Jesuits returned to places where the Society had previously served; and what new initiatives the Restored Society undertook, especially in the many places where it began to serve for the first time." The letter then explains the purpose of all this: "Prayerful reflection based on the historical knowledge that is or will become available can enable u s to learn from the lights and shadows of our past so that we might see more clearly and embrace more generously what the Lord calls u s to do in our own times." 25) Members of the SMOM and CFR are guided daily by the Aragon Templar General Nicholas

Strunk's Supplement to the Complaint Page 10 of 24

BACKGROUND FOR THE SUPPLEMENT TO THE COMPLAINT

26) Intervener

-

Plaintiffrepeats and re-alleges each and every allegation contained

in paragraphs 1 through 25 above as though set forth fully and at length herein and contends the supplemental parties and Strunk's intervention as of right with FRCvP Rule 24 (a)is done on timely motion in, in which the court must permit anyone to intervene who claims an interest relating to the property or transaction that is the subject of the action, and is so situated that disposing of the action may as a practical matter impair or impede Strunk's ability to protect its interest, unless existing parties adequately represent that interest.; and furthermore, even were FRCvP Rule 24 (b) for
INTERVENTION to apply instead then also Strunk is here by a timely motion, PERMISSIVE

that the court may permit anyone to intervene who: (B) has a claim or defense that
shares with the main action a common question of law or fact; and as with the legal duty of the Defendant FBPC and it agents under the Foreign Bondholders Act of 1933 requires it as a quasi governmental Agency to act on such timely motion, as the court may permit a federal or state governmental officer or agency to intervene if a party's claim or defense is based on: (A) a statute or executive order administered by the officer or agency; or (B) any regulation, order, requirement, or agreement issued or made under the statute or executive order; and furthermore, were Delay or Prejudice. In exercising its discretion, the court must consider whether the Strunk intervention will unduly delay or prejudice the adjudication of the original parties' rights or in fact assist the court in the litigation. 27) That Plaintiffs Complaint of 111 pages fded November 23, 201 1 on its face is taken as true by Intervener Plaintiff and the transactions and disposition of Plaintiffs' subject property "Dragon Family Financial Instruments" or the "DFFI" as described at "The Nature of the Action and Jurisdiction" starting at page 2 with paragraph 1

Strunk's Supplement to the Complaint Page 11 of 24

through the description in paragraph 2 ending at page 9, is then discussed in detail as further effects Strunk's property as related to the named parties ti-om page 9 paragraph 3 through paragraph 36 on page 25. 28) The stolen DFFI asset entrusted to Plaintiff Keenan in early 2009 by the Dragon Family, are comprised of the following quote:
"(i)Two-Hundred ForQ-Nine (249) United States 1934 Series Federal Reserve

(b) Upon information and belief, between 1927 and 1938, as a result of arrangements made between China and the United States, the United States purchased some 50 million ounces of silver and leased vast amounts of gold ti-om the Nationalist Chinese Government, known as Kuomintang. During this period, China was partly occupied by Japanese troops and there was a fear of China being overrun by the Japanese. (c) Upon information and belief, in return for the precious metals delivered by the Chinese, ceficates were given pursuant. to private agreement made between China and the United States. These certificates became the underlying funds of the Kuomintang. (d) Upon information and belief, following the promulgation in 1934 of the Gold Reserve Act, the law required all bullion gold and gold coin to be surrendered to the Federal Reserve, a private corporation that is chartered to operate as the Central Bank of the United States and the issuer of the United States Dollar. (e) Upon information and belief, domestically owned gold was purchased. Foreign Gold held by the Treasury was also surrendered to and thus leased to the Federal Reserve, which resulted in the issuance of the series of 1934 Notes by the Federal Reserve. These Dragon Family FRNs have never been redeemed and, upon information and belief, the accrued interest was met by the subsequent issue of certain 1968 series of Kennedy Bonds (see Paragraph 2 (iii),infra) and later further issues of the 1934 series FRNs which, upon information and belief, were issued through the period of the Chinese civil war to assist Kuomintang operations in China and later in Burma. These 1934 FRNs guarantee the lease payments and helped to allow the Chinese Government to continue fmancially. KEENAN has no personal knowledge as to whether the FRN s with which he was entrusted were original or subsequently issued Notes.
(f) Upon information and belief, this gold was documented into accounts through the Union Bank of Switzerland, placed under protection of the Swiss Attorney General, registered through the

Strunk's Supplement to the Complaint Page 12 of 24

Swiss National Bank: into the Bank for International Settlements ("BIS")International Collateral Combined accounts and then ti-om within the BIS, blocked to form the Institutional Parent Registration Accounts of the Federal Reserve System. (g) Upon information and belief, and in accordance with procedures that would be expected to occur in the event the Note Holder of record wished to redeem it, the Holder would do so by f ~ sremitting the number of the Note to the Federal Reserve with a t major project or a list of projects for approval. Once the projects have been approved, the Note would be recognized and the Fed system would then make arrangements for the Note to be deposited into a bank which would provide a specific credit line, perhaps o f 3 m u p to 800/0 of the face value. The Fed system would then provide immunity to the Holder to present the Note at a specific Bank where a Credit Line has been pre-arranged. Attempting to present these Notes outside this system will see the note arbitrarily denied and the illegal presenter incarcerated.
(h)Upon information and belief, in order to effectuate this process, the Notes were printed to appear as ifthey were not produced from official origin and bear obvious imperfections, therefore easily deniable. However, when proper procedures are followed, the number of the Note and other linking identic data allows ultimate authentication and verification through the Federal Reserve System screening process and the presenting of the Note under the immunity shield allows effective use. (i)As of April 20, 2009, the Dragon Family had calculated the total value of these FRNs alone, with interest accrued since 1934, as approximately Nine-Hundred Sixty-Eight Billion United States Dollars ($968,000,000,000.00). (ii)Two (2) 57th Series Japanese Government Bearer Bonds, Nos. A 1306 (construction bond) and A 1310 (the "Japanese Bonds"), which were issued on April 30, 1983 by the Ministry of Finance, Government of Japan, each having a face value of Japanese Yen Five Hundred (500) Billion, which is equivalent to an amount in excess of Nine and One-Half (9.5) Billion United States Dollars. Upon information and belief, these Japanese Bonds are but two (2) of Five Hundred (500) such Bonds owned by the Dragon Family, each having the same face value, according to a statement of Yamaguchi dated April 20, 2009 concerning the Bond History relating to these specific Japanese Bonds. (iii)One (1)United States Kennedy Bond with a face value of One (1) Billion United States Dollars, bearing registration number APII 024068 A. (a)As with the FRNs, KEENAN has no personal knowledge of the circumstances which gave rise to the issuance of the 'Kennedy Bond bearing registration number APII 024068 A, issued in 1998

Strunk's Supplement to the Complaint Page 13 of 24

and which had been entrusted to him by Yamaguchi on May 5, 2009. The knowledge he has obtained is based largely upon his communications with Yamaguchi including the representations made by Yamaguchi in various documents he has executed over the years in connection with his attempts on behalf of the Dragon Family to place various Kennedy Bonds into legitimate PPPs in furtherance of their objective to provide humanitarian global assistance when and where needed. (b) In a sworn statement by Yamaguchi, dated August 4,2010, entitled "Kennedy Bond History," and which relates to the details of ten (10) other Kennedy Bonds, virtually identical to that entrusted to KEENAN in May 2009 except for the registration numbers, Yamaguchi stated that the "US government borrowed huge amount funds from the Dragon Family many years ago. The base of the lent funds ti-om the Dragon Family to the US Government were the Gold and Silver. Therefore the US government was able to issue huge USD as currencies via FRB then." Yamaguchi proceeded to state: 'We, the Dragon Family, requested some interest to the US Government on 1998 by use of some securities/certificates got expired as same as the 57th Series Japanese Government Bonds. And, we have received the Kennedy Bonds, issued in 1998, as one of the interest payments ti-om the US Government. I recognize as my position that the Kennedy Bonds were issued by the US Government as the interest only for the Dragon Family."
( c) Upon information and belief, the Kennedy Bonds represent a series of notes printed for the purpose of creating a settlement fund for the gold and other precious metals transferred to the United States under the terms of the Green Hilton Memorial Agreement (GHMA), November 11, 1963 which was executed by, among others, President J o h n F. Kennedy and President Soekarno, t the f ~ sPresident of Indonesia, who had previously been entrusted with the care of the gold. Upon information and belief, these Bonds were originally issued in 1968 by way of specially denominated 1968 Kennedy Bonds, " 2 series. These bonds were not commercially negotiable, or cashable, but were redeemable through the Federal Reserve System in what was intended to be an effective, beneficial, and well-aimed program that was intended for better global development. President Soekarno was deposed in 1967 by General Suharto, thus disrupting the entire program causing a failure to institute the planned development program intended for Indonesia and the Asian region.

(d) Upon information and belief, few, ifany, of the 1968 Kennedy Bonds had been used within the original 30 year period, a fact to which Yamaguchi may have been referring in his above statement. Thus, theoretically, the gold that had been lent by the Dragon Family had not been paid for and therefore had not fully transferred to the Federal

Strunk's Supplement to the Complaint Page 14 of 24

System. Upon information and belief, this resulted in a situation where the gold was no longer being purchased at the gold price of 1963 but at the increased 1998 price. Thus, a new "A" series of bonds, which Yamaguchi may also have been describing in his statement above, were issued in 1998 reflecting that price and the old " 2 series became defunct and worthless." 29) That Strunk notes based upon review by an expert in reference to methods used above as materially germane herein that this same principle is clearly demonstrated concerning Japan's secret, post-WWII "M-Fund". The fund was a Japanese political slush fund for the benefit right-wing, "anti-communist" Japanese politicians. It was derived from the "Black Eagle Trust," backed by looted Nazi gold and established by Skull and Bonesman Secretary of War Henry Stimson and his assistant, Knight of Malta J o h n J. McCloy, for use during the pope's Cold War Hoax We read in Gold Warriors:America's Secret Recovery of Yamachita's Gold by Sterling and Peggy Seagrave (New York: VERSO, 2003), p. 9: "A related legal battle was that of former U.S. Deputy Attorney General Norbert Schlei, who had to fight for his survival after being stung by the U.S. Treasury Department for asking too many questions about Japan's secret M-Fund. While Schlei was indicted, prosecuted, bankrupted, and professionally ruined for trying to negotiate a fmancial certificate based on the M-Fund, former Secretary of State Alexander Haig - according to eyewitnesses -went to J a p a n and negotiated a similar certificate successfully, with the help of a personal letter from President George H. W. Bush. Why one man succeeded while the other was destroyed is a chilling story of fmancial collusion between Washington and Tokyo." As a fact to support restraint of any SMOM member ti-om shaping relief, the reason is clear: Alexander Haig was a Knight of Malta and his brother Francis, a powerful Jesuit priest; and that Haig's superior was another Knight of Malta, George H. W. Bush 30) That according to Plaintiff Keenan as the Disclosed Principal of the Dragon Family at Complaint paragraph 13, he states quote: "Upon information and belief, the 1934 FRNs described, supra, at paragraph 2 (i), came under the control of the Kuomintang from whom the gold was received in return for the lease payments, and allowed the Chinese Nationalist Government in Taiwan to continue fmancially. Many of the FRNs were left in

Strunk's Supplement to the Complaint Page 15 of 24

Communist China when the Kuomintang had to flee to Taiwan. Further, upon information and belief, the Gold had been nationalized by the Kuomintang who moved much of the FRNs (but not all) to Taiwan, which allowed for the development of and served as the basis for the underlying wealth of Taiwan. The FRNs were good for value as they were backed by the gold and other precious metals purchased and leased by the United States government." 3 1) That according to Plaintiff Keenan as the Disclosed Principal of the Dragon Family at Complaint paragraph 14, he states quote: "Upon information and belief, the Kuomintang appointed guardians of this Gold and the securities issued by the United States who came to be known euphemistically as the Dragon Family. The Dragon Family is, in fact, a highly secretive and informal organization that operates between old families within China and Taiwan, above the political divide of the two independent Chinese Governments. The Dragon Family abstains ti-om public view and knowledge, but, upon information and belief, acts for the good and better benefit of the World in constant coordination with higher levels of Global Financial Organizations, in particular, the Federal Reserve System. During the course of its existence over the last century, the Dragon Family has accumulated great wealth by having provided the Federal Reserve Bank and the United States Government with asset assignments of gold and silver via certain accounts held in Switzerland, for which it has received consideration in the form of a variety of Notes, Bonds and Ceficates such as those described in - 2 that are an Obligation of the Federal Reserve System .Upon information and belief, these Bonds have values ranging in the many Thousands of Trillions of United States Dollars, a relatively small portion of which is involved in the claims giving rise to this action. Each of these currencies, such as the DFFI involved in this action, was and remains duly registered within the Federal Reserve System and are directly verifiable by the Federal Reserve through its efficient verification system and screening process." 32) That although Plaintiffs' DFFI property does not coincide with any S20 Bond or $20 Bond similar to Strunk's property, based upon information and belief the DFFI is nevertheless part of the sinking fund or reserve created to re-pay the S20 Bond or $20 Bond denomination similar to Sbunk's property when the PRC and ROC re-unite; and therefore, the disposition of the DFFI is germane and of a direct interest to Sbunk. AS AND FOR A FIRST SUPPLEMENTAL CAUSE OF ACTION (Defendants FRBNY and Lee C. Bollinger are parties to the Expropriation and Conversion under Federal Common Law and International Law)

Strunk's Supplement to the Complaint Page 16 of 24

33) Intervener-plaintiff repeats and realleges each and every allegation contained in Paragraphs 1 through 32 and the Compliant fded November 23, 20 11 and paragraphs
1 through 174 as if set forth herein at length omits same for brevity, in that Defendant

FRBNY and Defendant Lee C. Bollinger with named Defendants are parties to the Expropriation and Conversion under Federal Common Law and international law. 34) That Defendants FRBNY and Defendant Bollinger duties and responsibilities are in part to safeguard the use of the Federal Reserve Notes (FRNs) issued as a result of the transfer of the Gold ti-om the ROC; and 35) That the Defendant FRBNY and its agents are active interveners into the fmancial matters of the European Union (EU) and the European Central Bank (ECB) in that Defendants have expropriated and attempt to convert the DFFI and FRNs thereby effecting both the degree of fmancial intervention by Defendant FRBNY and the safety of Strunk's direct interest in the disposition of the sinking fund and or reserve ti-om which to re-pay the historical bonds. 36) That Strunk's historical bonds involve lawful money previously recorded and presently discoverable as part of a sinking fund under a double-bookkeeping regimen used by the Defendant FRBNY and auditable by the FBPC with fiduciary duties. 37) That according to a mutually acceptable Federal Reserve Bank expert on double bookkeeping standards and procedures of the Defendant FRBNY quote:
a) "Banks are required to adhere to Generally Accepted Accounting Principles (GAAP),GAAP follows an accounting convention that lies at the heart of the double-entry bookkeeping system called Matching Principle. This principle works as follows: When a bank accepts bullion, coin, currency, checks, drafts, promissory notes, or any other similar instruments (hereinafter "instruments") from customers and deposits or records the instrument as assets, it must record offsetting liabilities that match the assets that it accepted ti-om customers. The liabilities represent the amounts that the bank owes the customers, funds accepted from customers. In a ti-actional reserve banking system like the United States banking system, most of the funds advanced to borrowers (assets of the banks) are created by the banks themselves and are not merely transferred ti-om one set of depositors to another set of borrowers."

Strunk's Supplement to the Complaint Page 17 of 24

b) "In classical economic theory, once economic exchange has moved beyond the barter stage, there are two types of money: money of exchange and money of account... With exception of customary stores of value like gold and silver, the monetary base of the economy largely consists of credit instruments.. Against this background, I conclude that the Note, despite some language about "lawful money" explained below, clearly contemplates both disbursement of funds and eventual repayment or settlement in money or account (that is, money of exchange would be welcome but is not required to repay or settle the Note)." c) "Lawful money was the form of money of exchange that the federal government (or any state) could be required by statute to received in payment of taxes or other debts. Traditionally, as defmed by Congress, lawful money only included gold, silver, and currency notes redeemable for gold or silver on demand. In a banking law context, lawful money was only those forms of money or exchange that constituted the reserves of a national bank prior to 1913." d) "According to the Federal Reserve Bank of New York, money is anythmg that has value that banks and people accept as money.. . money does not have to be issued by the government or in any special form. .". e) "The bookkeeping entries tend to prove that banks accept cash, checks, drafts, and promissory notelcredit agreements (assets) as money deposited to create credit or checkbook money that are bank liabilities, which shows that, absent any right of setoff, banks owe money to persons who deposit money. Cash (money of exchange) is money, and credit or promissory notes (money on account) become money when banks deposit promissory notes with intent of treating them like deposits of cash. See 12 U.S.C. Section 1813 (1)(1)(defmition of "deposit" under Federal Deposit Insurance Act).. . the newly issued credit or money is similar or equivalent to a promissory note, which may be treated as a deposit of money.. .that explains that when banks grant loans, they create new money. The new money is created because a new "loan becomes a deposit, just like a paycheck does...What banks do when they make loans is to accept promissory notes in exchange for credits to the borrowers' transaction accounts... . Explains that the banks' assets and liabilities increase by the amount of the loans." 38) That Strunk contends that in light of the facts associated with the DFFI and

FRN as well as FRBNY policy and procedures, Plaintiffs' claim against Defendants involve money of exchange not credit involving money of account means that lawful money was and is or probably would be disbursed by either side in a covered transaction even using a platform of a two-side market transactions to monetize the DFFI

/ FRN would be a covered transaction to be accounted for to preserve Strunk's

historic Bond sinking fund as the reserve for re-payment.

Strunk's Supplement to the Complaint Page 18 of 24

39) That during the course of its existence over the last century, the Dragon Family
has accumulated great wealth by having provided the Federal Reserve Bank and the

United States Government with asset assignments of gold and silver via certain accounts held in Switzerland, for which it has received consideration in the form of a variety of Notes, Bonds and Certificates such as those described in Complaint paragraph 2 that are an Obligation of Defendant FRBNY and Federal Reserve System. 40) Upon information and belief, these Bonds have values ranging in the many Thousands of Trillions of United States Dollars, a relatively small portion of which is involved in the claims giving rise to this action. Each of these currencies, such as the DFFI

/ FRN involved in this action, was and remains duly registered within the

Federal Reserve System and are directly verifiable by the Federal Reserve through its efficient verification system and screening process. 41) That Defendant FRBNY and Defendant Lee C. Bollinger by mis-administration and neglect have placed Sbunk's repayment at risk. 42) That Strunk has a direct interest in the DFFI, FRN and related funds. AS AND FOR A SECOND SUPPLEMENTAL CAUSE OF ACTION (Defendants FRBNY,Lee C. Bollinger, FBPC and John R. Petty with fiduciary duties are in breach of the quasi contract with Strunk a s a n American Historical Bondholder with Plaintiffs interest to maintain the sinking fund for re-payment) 43) Intervener-plaintiff repeats and realleges each and every allegation contained in Paragraphs 1 through 42 and the Compliant fded November 23, 20 11 and paragraphs
1 through 249 as to conspiracy, fraud, breach of contract and replevin action as if set

forth herein at length omits same for brevity, in that Defendants FRBNY, Lee C. Bollinger, FBPC and J o h n R. Petty with fiduciary duties are in breach of the quasi contract with Strunk as an American Historical Bondholder with Plaintiffs interest to maintain the sinking fund for re-payment

Strunk's Supplement to the Complaint Page 19 of 24

44) That according to the Chinese - US Historical Bond Expert CHENG CHUNG MO(61, as would apply to the fiduciary duties of the Defendant FBPC and Defendant FRBNY, being familiar with Article 63 of the Act Governing Relations Between Peoples

Of The Taiwan Area And The Mainland Area which states quote:
"To the extent not contrary to the public order or good morals of the Taiwan Area, it shall be upheld the legal effects of any civil matter together with any right or obligation thereof created in the Mainland Area, prior to the coming into force of this Act, between any people of the Taiwan Area and Mainland Area, or between any two or more of the people of the Mainland Area, or between any of the people of the Mainland Area and any foreign national. The provisions of the preceding paragraph shall not apply provided that there had been laws or regulations in effect, prior to the coming into force of this Act, restricting the exercise or transfer of the rights referred to therein. The following debts shall not be repaid prior to national unification:
i) Outstanding foreign currency bonds issued in the mainland prior to 1949 and the short-term Gold Bonds of 1949. ii) Various debts owed by any government bank as well as any other fmancial institution accepting deposits before their retreat ti-om the Mainland."

45)That according to the Chinese

- US

Historical Bond Expert CHENG CHUNG-MO

regarding to Article 63 of the Act Governing Relations Between Peoples Of The Taiwan

Area And The Mainland Area:
"This act was promulgated and amended as stated above by Presidential Order on October 29, 2003 and implemented from March 1, 2004 by the Order of the Executive Yuan during my term of office as Vice President of the Republic of China Judicial Yuan." "The intent of this Act in regards to pre- 1950 Chinese bonds was to reaffirm their Existence as defaulted foreign debt obligations of the Republic of China owed in the United States and elsewhere and to defer their resolution until national unification, "

Grand Justice and Vice President of the Republic of China Judicial Yuan 1999-2006, Minister of Justice of the Republic of China 1998-1999, and as a law professor in Taiwan and as a visiting professor at the University of Vienna and Wisconsin. Judicial Yuan is the Republic of China's highest judicial organ tasked with interpreting the Constitution of the Republic of China. Holds LL.D. from the University of Vienna and worked many years as a Law Professor including the position of Chairman of the Law Department of National Chung-Hsing University.
Strunk's Supplement to the Complaint Page 20 of 24

"These bonds referred to in Article 6 3 were all issued by the former Kuomintang Government of the Republic of China or were ratified by the Kuomintang government." "Kuomintang business holdings are worth billions of US dollars as part of the "black gold system of Kuomintang nepotism corruption and cronyism. "The issue of defaulted pre 1950 bonds is inexorably tied to the Kuomintang and its Assets in that the Kuomintang has been the main beneficiary of that default." "Until approximately I99 1, the Kuomintang and the Government of the Republic of China were one and the same entity. With the election o f Chen Shui-bian as President of the republic of China in 2000, for the first time the Republic of China was governed by a party other than the Kuomintang and the Kuomintang entirely ceased to be an organ or agent of the state. However, the Kuomintang apparatus typified by the Kuomintang Business Management Committee retained billions of dollars of assets accumulated while the Kuomintang was an organ of the Republic of China from 1926 to 1991. It is entirely plausible that the proceeds, sinking funds, and other benefits of the pre- 1950 defaulted bonds referenced in Article 6 3 have been retained by the Kuomintang Business Management Committee to this day. " 'While Article 6 3 defers overall settlement of the bonds until the issue of Mainland China is dealt with, it does not preclude legal actions for unjust enrichment against the Kuomintang which is now a non sovereign juridical entity." 46) That Strunk contends that in light of the facts associated with the DFFI and FRN, FRBNY policy and procedure as well as the Foreign Securities Act of 1933 and

Article 63 of the Act Governing Relations Between Peoples Of The Taiwan Area And The Mainland Area, the S20 Bond or $20 Bond denomination similarly include Strunk's
property and are part of the assets secured by Plaintiffs' claim against Defendants that involve money of exchange also involve "theproceeds, sinking funds, and other benefits

of thepre 1950 defaulted bonds referenced in Article 63 have been retained by the Kuomintang Business Management Committee to this d a g that reasonably would
include Plaintiffs as well in such private transaction(s) with subject securities to form
a two-sided market platform to monetize debt in Switzerland as a transaction defmed

Strunk's Supplement to the Complaint Page 2 1 of 24

under what would be a pendant action with New York State's "Blue Sky L a f l in New York as well as effecting eventual repayment and or the guarantee here in New York. 47) Defendants FRBNY and Defendant Lee C. Bollinger, FBPC and J o h n R. Petty by nonfeasance are parties to fraud, breach of contract and replevin action in that the Expropriation and Conversion under Federal Common Law and international law are under there auspice. 48)That failure of Defendants FRBNY and Defendant Lee C. Bollinger, FBPC and J o h n R. Petty to perform duties and obligations would take Strunk's property. AS AND FOR A THIRD SUPPLEMENTAL CAUSE OF ACTION (Defendants FRBNY,Lee C. Bollinger, FBPC and John R. Petty with fiduciary duties to Strunk a s a n American Historical Bondholder with Plaintiffs interest to maintain the sinking fund for re-payment are wasting Plaintiffs assets) 49) Intervener-plaintiff repeats and realleges each and every allegation contained in Paragraphs 1 through 48 and the Compliant fded November 23, 20 11 and paragraphs
1 through 249 as to fraud, breach of contract and replevin action as if set forth herein

at length omitting same for brevity, in that Defendants FRBNY, Lee C. Bollinger, FBPC
and J o h n R. Petty and or their agents with fiduciary duties to Strunk as an American Historical Bondholder with Plaintiffs interest to maintain the sinking fund for repayment are wasting Plaintiffs assets. 50) Plaintiff Keenan as Disclosed Principal of the Dragon Family admit that their relationship is identical with the Kuomintang Business Management Committee as "the Kuomintang appointed guardians of this Gold and the securities issued by the United States who came to be known euphemistically as the Dragon Family. The Dragon Family is, in fact, a highly secretive and informal organization that operates between old families within China and Taiwan, above the political divide of the two independent Chinese Governments."

Strunk's Supplement to the Complaint Page 22 of 24

51) Based upon information and belief, 'She Dragon Family and Defendants seek a
Two-side Market Platform i Switzrland t monetize debt obligations i association n o n
with interests of SMOM, CFF? and Vatimm that effects Strunk's historic bond assets.
52) That Defendants are atkplmg t c o m e DFFI and FRN in a Two-side m

market platform i Switzerland t monetize EU ECB obligations with Strunk's assets. n o
53) B a d upon information and belief the= i a M e m m m h m qf Undetstanding of s
August 31, 1982 between the Securities Exchange IOommksion of the United Stat&

and the Swiss Government regarding non-public securities trading that would
investigate a Two-side market platform i EMzerland to monetize EU ECB debt n
I

obligations and or transact risk based invesbnents eff-

S

W

s assets.

54) T b t m e d Defendants have proffered ap effort to ut&x Plaintiffs' D m / FRN
asset by such action involve supplement Defendants thereby ef%cling StmnPs assets.

s

-

Inkmmer-Plaintiff Strunk wishes a decision of the Court t : o
A. Assign a m u m acceptable special masbr for an acoounting of the DFFI-FRN;

B. Assign the special master the task of an accounting of the sinlung fund;
C. Assign the special master the task to scrutjnize arry or all Two-sided Market Platformts) that would effect the smking fund;
D. Restrain any member of the SMOM and or CFR h m inkrfkhg with the accounting including Lee 6. BoUinger, John R. Petty and or their agents;

E. Such other and different relief the Court deems necessary h &
Date& January /4,2012 B m k l p New York
Christopher-Earl: Slrunk in esse Self-represented without an attorney 593 Vanderbdt Avenue - 28 1 Brooklyn, New York 11238 Phone - 845-90 1-6767 Em& c ~ s . t r u n k . w s

Strunk's Supplement to the Complaint Page 23 o 24 f

STATE OF'-

YORK

)

C O m OF lams

3

1 ss.

Accordingly, T, Chistopher Earl Strunk, being duly sworn, depose and say under
penalw of perjury:

I have read the foregoing Supplement to the Complaint fled November 23,
20 11, and as applies to the Supplemental Parties and Three Supplement Causes of

-

action as against Defendants i their official capacity and or individually, and In which n Intemner- Plaintiff requests a preliminary Injunction with restraint of Defendants and
I

its agents as to the accounting of the sinking fund to safeguard the guaranteed reserve'

to repay Stmnk's American Chinese historical Bends; and know the contents thereof
apply to me by misapplication and administration of laws as a continuing injury

caused by the scheme to defraud with unjust enrichment that affects Plaintiffs' and
Intervener-Plaintiff along with those M a r 1 p situated; the same is m e to m y own

knowledge, except as to the matters therein stated to be alleged on information and

belief, and as to those matters I believe it to be true. The grounds of my beliefs as to all
matters not stated upon information and belief are as follows: 3d parties, books and
L

records, and personal knowledge.

A

This

Sworn to before me day ofJanuary 2012

Commissioner of Deeds City of New Yo& bI0.5-883 Cgrtificate Filed in Richmond C o ~ n \ y - Commission Expies June 30,20

-

+If

S W s Supplement to the Complaint Page 24 o 24 f

NEIL F. KEENAN et al. v. DANIELE DAL BOSCO et al. 11-cv-8500 (RJH) SUPPLEMENT TO THE COMPLAINT

Exhibit 1

NEIL F. KEENAN et al. v. DANIELE DAL BOSCO et al. 11-cv-8500 (RJH) SUPPLEMENT TO THE COMPLAINT

Exhibit 2

Case 1:11-cv-08500-JFK Document 1

Filed 11/23/11 Page 1 of 114

AO 440 (Rev. 12/09) Summons in a Civil Action

UNITED STATES DISTRICT COURT
for the Southern District of New York Neil F. Keenan, Individually and as Agent for The Dragon Family, citizens of foreign states,
Plaintiff

v.
See Attached Schedule A
Defendant

) ) ) ) ) ) )

Civil Action No.

JUDGE HOlWEll

SUMMONS IN A CIVIL ACTION
To: (Defendant's name and address) SEE ATTACHED SCHEDULE A

A lawsuit has been filed against you. Within 21 days after service of this summons on you (not counting the day you received it) - or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) - you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney, whose name and address are: William H. Mulligan, Jr. Bleakley Platt & Schmidt, LLP One North Lexington Avenue White Plains, NY 10601 (914) 949-2700

You
Date:

entered
------------------1 f/22/2011

complaint.

Case 1:11-cv-08500-JFK Document 1
AO 440 (Rev. 12/09) Summons in a Civil Action (Page 2)

Filed 11/23/11 Page 2 of 114

Civil Action No.

PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (l))
This summons for (name of individual and title, if any) was received by me on (date)

o
o

I personally served the summons on the individual at (place) on (date) ;or

-------------------------------------------------

I left the summons at the individual's residence or usual place of abode with (name)

---------------------------------on (date)

, a person of suitable age and discretion who res ides there,

----------------

, and mailed a copy to the individual's last known address; or ,who is

o

I served the summons on (name of individual)

designated by law to accept service of process on behalf of (name of organization)

-------------------------------------------------

on (date)

; or ; or

o

I returned the summons unexecuted because

o

Other (specify):

My fees are $

for travel and $

for services, for a total of $

0.00

I declare under penalty of perjury that this information is true.

Date:
Server's signature

Printed name and title

Server's address

Additional information regarding attempted service, etc:

Case 1:11-cv-08500-JFK Document 1

Filed 11/23/11 Page 3 of 114

SCHEDULE A - DEFENDANTS 1. 2. 3. 4. 6. 7. 8. 9. 11. 12. 13. 14. 15. 16. DANIELE DAL BOSCO THE OFFICE OF INTERNATIONAL TREASURY CONTROL RAY C. DAM, individually, and as President ofOITC DAVID A. SALE, individually, and as Deputy Chief of the Council for the Cabinet of OITC THE UNITED NATIONS BAN KI-moon, individually, and as Secretary General of the UN H.E. Ambassador CESARE MARIA RAGAGLINI, Individually, and as Permanent Representative of the Italian Mission to the UN in New York H.E. Ambassador LAURA MlRACHIAN, Individually, and as Permanent Representative of the Italian Mission to the UN in Geneva ITALIAN REPUBLIC ITALIAN FINANCIAL POLICE SILVIO BERLUSCONI, Former Prime Minister of Italy THE WORLD ECONOMIC FORUM WORLD ECONOMIC FORUM U.S.A., INC. GIANCARLO BRUNO, individually, and as Head of the Banking Industry of WEF

Case 1:11-cv-08500-JFK Document 1

Filed 11/23/11 Page 4 of 114

William H. Mulligan, Jr. (WM 2945) Justin M. Gardner (1M 6169) BLEAKLEY PLATT & SCHMIDT LLP One North Lexington Avenue White Plains, New York 10601 (914) 949-2700 Tel. (914) 683-5956 Fax wmulligan@bpslaw.com Attorneys for Plaintiff

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

JUDGE HOLWELL
Index No. 11 Civ. _ COMPLAINT
Plaintiff Demands Trial By Jury for All Applicable Claims

NEIL F. KEENAN, Individually and as Agent for THE DRAGON FAMILY, citizens of foreign states, Plaintiff, -againstDANIELE DAL BOSCO, a citizen of a foreign state, THE OFFICE OF INTERNATIONAL TREASURY CONTROL, a foreign corporation ("OITC"), RAY C. DAM ("DAM"), individually, and as President of OITC, DAVID A. SALE ("SALE"), individually, and as Deputy Chief of the Council for the Cabinet of OITC, the UNITED NATIONS, BAN KI-moon, individually, and as Secretary General of the UN, H.E. Ambassador CESARE MARIA RAGAGLINI, Individually, and as Permanent Representative of the Italian Mission to the UN in New York, H.E. Ambassador LAURA MIRACHIAN, Individually, and as Permanent Representative of the Italian Mission to the UN in Geneva, the ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE, Former Prime Minister of Italy, SILVIO BERLUSCONI, THE WORLD ECONOMIC FORUM ("WEF") a foreign corporation, WORLD ECONOMIC FORUM U.S.A., INC., GIANCARLO BRUNO, individually, and as Head of the Banking Industry of WEF, and various unknown individual co-conspirators, JOHN DOES A-Z, Defendants.

( )

Case 1:11-cv-08500-JFK Document 1

Filed 11/23/11 Page 5 of 114

Plaintiff, NEIL F. KEENAN (hereinafter, "KEENAN"), individually, and as agent and assignee of THE DRAGON F AMILY, citizens of various foreign states, by and through his attorneys, Bleakley Platt & Schmidt, LLP, as and for his complaint herein, alleges as follows: NATURE OF THE ACTION AND JURISDICTION 1. This is a civil claim arising out of the concerted, knowing, malicious scheme and

international conspiracy engaged in by the Defendants for the designed purpose of defrauding plaintiff KEENAN, the designated Agent of his Principal, the "Dragon Family," for the express purpose of expropriating, stealing and converting certain negotiable financial instruments lawfully owned by the Dragon Family and entrusted to KEENAN in early 2009. These assets (hereinafter referred to as the "Dragon Family Financial Instruments" or the "DFFI") had been intended for participation in select, registered and authorized Private Placement Investment Programs (or "PPPs") for the benefit of a wide range of global humanitarian purposes. At the time of the criminal and deceitful acts of the Defendants, the approximate face value of the stolen DFFI was One Hundred Forty-Five and One Half Billion ($145,500,000,000.00) United States Dollars with an approximate accrued interest value of One Trillion ($1,000,000,000,000.00) United States Dollars. 2. The stolen DFFI, which had been entrusted to KEENAN in early 2009 by the

Dragon Family, are comprised of the following: (i) Two-Hundred Forty-Nine (249) United States 1934 Series Federal

Reserve Notes (or "FRNs") which, according to a Federal Reserve System Inventory List (SC1226-71-DOO4-D45184101 A) prepared at the time of issuance, were contained in "Box No. D 45184101 A" bearing Bond Nos. "D 45184101 A- D 45184350 A" (one sheet No. D 45184349 A missing) 2

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each with a face value of $500 Million ($500,000,000.00) United States Dollars in the total amount of One Hundred Twenty-Four Billion FiveHundred Million United States Dollars ($124,500,000,000.00). (a) KEENAN does not have personal knowledge of the

circumstances which gave rise to the original issuance of any of the DFFI. The knowledge he has obtained is based largely upon the representations made by Mr. Akihiko Yamaguchi (hereinafter, "Yamaguchi"), Signatory of the Dragon Family, in various documents Yamaguchi has executed over the years in connection with his attempts to place the DFFI into legitimate PPPs in furtherance of the Dragon Family's objectives to provide humanitarian global assistance when and where needed. (b) Upon information and belief, between 1927 and 1938, as a

result of arrangements made between China and the United States, the United States purchased some 50 million ounces of silver and leased vast amounts of gold from the Nationalist Chinese Government, known as Kuomintang. During this period, China was partly occupied by Japanese troops and there was a fear of China being overrun by the Japanese. (c) Upon information and belief, in return for the precious

metals delivered by the Chinese, certificates were given pursuant . to private agreement made between China and the United States. These certificates became the underlying funds of the Kuomintang. 3

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(d)

Upon information and belief, following the promulgation in

1934 of the Gold Reserve Act, the law required all bullion gold and gold coin to be surrendered to the Federal Reserve, a private corporation that is chartered to operate as the Central Bank of the United States and the issuer of the United States Dollar. (e) Upon information and belief, domestically owned gold was

purchased. Foreign Gold held by the Treasury was also surrendered to and thus leased to the Federal Reserve, which resulted in the issuance of the series of 1934 Notes by the Federal Reserve. These Dragon Family FRNs have never been redeemed and, upon information and belief, the accrued interest was met by the subsequent issue of certain 1968 series of Kennedy Bonds (see 2 (iii), infra) and later further issues of the 1934 series FRNs which, upon information and belief, were issued through the period of the Chinese civil war to assist Kuomintang operations in China and later in Burma. These 1934 FRNs guarantee the lease payments and helped to allow the Chinese Government to continue financially. KEENAN has no personal knowledge as to whether the FRN s with which he was entrusted were original or subsequently issued Notes.

(f)

Upon information and belief, this gold was documented

into accounts through the Union Bank of Switzerland, placed under protection of the Swiss Attorney General, registered through the 4

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Swiss National Bank:into the Bank for International Settlements ("BIS") International Collateral Combined accounts and then from within the BIS, blocked to form the Institutional Parent Registration Accounts of the Federal Reserve System. (g) Upon information and belief, and in accordance with

procedures that would be expected to occur in the event the Note Holder of record wished to redeem it, the Holder would do so by first remitting the number of the Note to the Federal Reserve with a major project or a list of projects for approval. Once the projects have been approved, the Note would be recognized and the F edsystem would then make arrangements for the Note to be deposited into a bank which would provide a specific credit line, perhaps of30% up to 80% of the face value. The Fedsystem would then provide immunity to the Holder to present the Note at a specific Bank where a Credit Line has been pre-arranged. Attempting to present these Notes outside this system will see the note arbitrarily denied and the illegal presenter incarcerated. (h) Upon information and belief, in order to effectuate this

process, the Notes were printed to appear as if they were not produced from official origin and bear obvious imperfections, therefore easily deniable. However, when proper procedures are followed, the number of the Note and other linking identic data allows ultimate authentication and verification through the Federal 5

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Reserve System screening process and the presenting of the Note under the immunity shield allows effective use. (i) As of April 20, 2009, the Dragon Family had calculated the

total value of these FRNs alone, with interest accrued since 1934, as approximately Nine-Hundred Sixty-Eight Billion United States Dollars ($968,000,000,000.00). (ii) Two (2) 57th Series Japanese Government Bearer Bonds, Nos. A

1306 (construction bond) and A 1310 (the "Japanese Bonds"), which were issued on April 30, 1983 by the Ministry of Finance, Government of Japan, each having a face value of Japanese Yen Five Hundred (500) Billion, which is equivalent to an amount in excess of Nine and One-Half (9.5) Billion United States Dollars. Upon information and belief, these Japanese Bonds are but two (2) of Five Hundred (500) such Bonds owned by the Dragon Family, each having the same face value, according to a statement of Yamaguchi dated April 20, 2009 concerning the Bond History relating to these specific Japanese Bonds. (iii) One (1) United States Kennedy Bond with a face value of One (1)

Billion United States Dollars, bearing registration number APII 024068 A. (a) As with the FRNs, KEENAN has no personal knowledge of

the circumstances which gave rise to the issuance of the 'Kennedy Bond bearing registration number APII 024068 A, issued in 1998 and which had been entrusted to him by Yamaguchi on May 5, 2009. The knowledge he has obtained is based largely upon his 6

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communications witIi Yamaguchi including the representations made by Yamaguchi in various documents he has executed over the years in connection with his attempts on behalf of the Dragon Family to place various Kennedy Bonds into legitimate PPPs in furtherance of their objective to provide humanitarian global assistance when and where needed. (b) In a sworn statement by Yamaguchi, dated August 4,2010,

entitled "Kennedy Bond History," and which relates to the details of ten (l0) other Kennedy Bonds, virtually identical to that entrusted to KEENAN in May 2009 except for the registration numbers, Yamaguchi stated that the "US government borrowed huge amount funds from the Dragon Family many years ago. The base of the lent funds from the Dragon Family to the US Government were the Gold and Silver. Therefore the US government was able to issue huge USD as currencies via FRB then." Yamaguchi proceeded to state: "We, the Dragon Family, requested some interest to the US Government on 1998 by use of some securities/certificates got expired as same as the 57th Series Japanese Government Bonds. And, we have received the Kennedy Bonds, issued in 1998, as one of the interest payments from the US Government. I recognize as my position that the Kennedy Bonds were issued by the US Government as the interest only for the Dragon Family." 7

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(c)

Upon information and belief, the Kennedy Bonds represent

a series of notes printed for the purpose of creating a settlement fund for the gold and other precious metals transferred to the United States under the terms of the Green Hilton Memorial Agreement (GHMA), November 11, 1963 which was executed by, among others, President John F. Kennedy and President Soekarno, the first President of Indonesia, who had previously been entrusted with the care of the gold. Upon information and belief, these Bonds were originally issued in 1968 by way of specially denominated 1968 Kennedy Bonds, "Z" series. These bonds were not commercially negotiable, or cashable, but were redeemable through the Federal Reserve System in what was intended to be an effective, beneficial, and well-aimed program that was intended for better global development. President Soekarno was deposed in 1967 by General Suharto, thus disrupting the entire program causing a failure to institute the planned development program intended for Indonesia and the Asian region. (d) Upon information and belief, few, if any, of the 1968

Kennedy Bonds had been used within the original 30 year period, a fact to which Yamaguchi may have been referring in his above statement. Thus, theoretically, the gold that had been lent by the Dragon Family had not been paid for and therefore had not fully transferred to the Federal System. Upon information and belief, 8

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this resulted in a situation where the gold was no longer being purchased at the gold price of 1963 but at the increased 1998 price. Thus, a new "A" series of bonds, which Yamaguchi may also have been describing in his statement above, were issued in 1998 reflecting that price and the old "Z" series became defunct and worthless. 3. As referenced above, and discussed in more detail below, the DFFI had been

entrusted to KEENAN in early 2009 by the Dragon Family. Months thereafter, in September 2009, KEENAN was fraudulently induced through the conspiratorial actions and schemes of the Defendants to transfer and entrust the DFFI for temporary safekeeping and custodianship to defendant Daniele DAL BOSCO (hereinafter, "DAL BOSCO"). 4. Thereafter, unbeknownst to KEENAN, DAL BOSCO, in a malevolent, conscious

and concerted scheme and enterprise of staggering proportions, plotted and conspired with the other Defendants in a variety of ways to defraud KEENAN and to convert the DFFI for their own personal financial gain and to the complete financial detriment of KEENAN and the Dragon Family, as described in more detail throughout the Complaint below. 5. In summary, this conspiracy included: (a) the expropriation, stealth and

conversion by DAL BOSCO of the very same DFFI with which he had been temporarily entrusted; (b) the repeated and unsuccessful attempts to bribe KEENAN in the total amount of One Hundred Million ($100,000,000.00) Dollars (half of which was to be kept by DAL BOSCO), in an effort to obtain KEENAN's consent to release the DFFI to others without disclosing such theft to the rightful owners of the DFFI, the Dragon Family; (c) a plan whereby the DFFI would be converted and placed into a so-called "UN Sovereign Program" wholly under 9

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the auspices, protection and umbrella of the: "sovereign immunity" allegedly accorded to the defendants by the actions of certain of the defendants, including the UNITED NATIONS and the ITALIAN REPUBLIC; (d) the execution of a written agreement between DAL BOSCO and defendants OITC and SALE, with the full knowledge and authority of DAM, whereby DAL BOSCO openly repudiated his duties as custodian of the DFFI; (e) the issuance of an illegal and utterly baseless Cease and Desist Order under which OITC asserted the thoroughly and knowingly false proposition that the DFFI was, in fact, in the lawful possession of OITC, which has acted for decades with impunity and under the asserted umbrella of protection allegedly accorded by the UNITED NATIONS; (f) the longstanding and unlawful complicity of the UNITED NATIONS in allowing the blatantly false, but to date, unremedied representation to the world at large by OITC that it was organized under a non-confirmable and apparently nonexistent UN Charter Code provision; (g) the unlawful, concerted and malicious attempt, through the actions of various of the defendants to utilize not only the stolen DFFI, which are the focal point of this matter, but also numerous various other financial instruments either stolen or seized under color of police authority of the ITALIAN FINANCIAL. POLICE or obtained by others, to purchase Banca Commerciale di Lugano, Lugano CH (Switzerland), or some other Swiss registered bank into which they could deposit stolen assets, and to capitalize the bank's assets with profits obtained from such actions. Upon information and belief, such bank capitalization was to include yet another approximately One-Hundred Thirty-Four Billion, Five-Hundred Million Dollars ($134,500,000,000.00) Dollars of financial instruments also owned by the Dragon Family, including FRNs and Kennedy Bonds virtually identical to the DFFI, which were seized on the Italian/Swiss border in June 2009. (See 63-69 supra, "The Chiasso Incident").

10

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Subject Matter Jurisdiction:
6. This Court has "original jurisdiction without regard to amount in controversy"

over this action brought against a foreign state as defined in the Foreign Sovereign Immunities Act (hereinafter "FSIA"), 28 U.S.C. § 1603(a), namely defendants the ITALIAN REPUBLIC and the ITALIAN FINANCIAL POLICE, which defendants are not entitled to immunity either under 28 U.S.C. §§ 1605-1607 or under any applicable international agreement. Specifically, defendants the ITALIAN REPUBLIC and the ITALIAN FINANCIAL POLICE and their agents acting on their behalf with actual authority, while actively participating in the conspiracy to defraud KEENAN and convert the DFFI, engaged in inherently commercial activities when said defendants and their agents attempted to bribe KEENAN in the total amount of One Hundred Million ($100,000,000.00) Dollars for the purpose of obtaining the DFFI, from KEENAN, for their own personal profit by and through the investment of the DFFI in a United Nations Sovereign Program largely through actions taken in New York, New York. Said commercial activity further has a direct effect in the United States in that a significant portion of the DFFI, namely the 249 FRNs and the Kennedy Bond, are an of the U.S. Federal Reserve

System, and in order to negotiate said financial instruments, the holder of these instruments must work directly with the U.S. Federal Reserve System to have the instruments verified before anticipated placement into an approved PPP. Additionally, and upon information and belief, the actions of the said defendants and their agents, as described in more detail below, constitute an expropriation of the DFFI in clear violation of international law, and said DFFI are currently held by said defendants in New York for investment in a UN Sovereign Program. 7. This Court also has original jurisdiction over this matter pursuant to 28 U.S.C. §

1331 as federal common law is applicable to the claims asserted herein, which claims involve 11

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uniquely federal interests. Specifically, this action involves an international conspiracy to defraud KEENAN and convert (i) Two-Hundred Forty-nine (249) United States 1934 Series Federal Reserve Notes each with a face value of $500 Million ($500,000,000.00) United States Dollars in the total amount of One Hundred Twenty-Four Billion Five-Hundred Million United States Dollars and (ii) One (1) United States Kennedy Bond with a face value of One (1) Billion United States Dollars, bearing registration number APII 024068 A issued by the U.S. Federal Reserve and/or the U.S. Treasury Department to the Dragon Family in exchange for the Dragon Family's extensive gold and other precious metal deposits, which were then placed in the U.S. Federal Reserve System for the benefit and underwriting support of the United States Dollar, which was to become and currently remains the global reserve currency. This international criminal conspiracy involving a sovereign nation and international organizations as coconspirators, including the ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE, BERLUSCONI, BRUNO, the UNITED NATIONS and the WORLD ECONOMIC FORUM, implicates the Dragon Family's right to be compensated for the gold and precious metal deposits it made into the Federal Reserve System pursuant to the original agreements between the United States and the Dragon Family, as well as KEENAN's rights as Agent of the Dragon Family to place the DFFI into the PPPS intended and to be compensated in accordance with his own rights as such Agent. Alternatively, the conspiracy implicates the Dragon Family and its Agent KEENAN's right to the return of the gold and precious metal deposits with interest-a right which clearly implicates the uniquely federal interest of the United States in the U.S. Federal Reserve System, the federally chartered central banking system of the United States. Because this action involves issues that are of such a peculiarly federal concern, namely the obligations of the federally chartered central banking system of the United States, the underwriting support of 12

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the U.S. Dollar and its continued viability as the global reserve currency, this action is governed by federal common law. 8. The Court also has jurisdiction over any remaining claims under principles of

supplemental jurisdiction as such claims "are so related to claims in the action within such original jurisdiction that they form part of the same case or controversy" pursuant to 28 U.S.C. § 1367. VENUE 9. Venue is proper in this district under 28 U.S.C. § 1391 (b) (2) as a substantial part

of the events or omissions giving rise to the claims occurred, or, upon information and belief, a substantial part of the property that is the subject of the action is situated in this district, and under 28 U.S.C. § 1391 (b) (3) as certain defendants, namely the UNITED NATIONS (hereinafter, the "UN"), BAN KI-moon, H.E. Ambassador CESARE MARIA RAGAGLINI (hereinafter, "RAGAGLINI"), GIANCARLO BRUNO, (hereinafter, "BRUNO"), and the WORLD ECONOMIC FORUM USA, INC. (hereinafter "WEF USA") are in the district. Venue is also proper in this district under 28 U.S.C. § 1391 (d) as certain defendants are foreign aliens, namely DANIELE DAL BOSCO, THE OFFICE OF INTERNATIONAL TREASURY CONTROL (hereinafter, "OITC"), RAY C. DAM (hereinafter "DAM"), DAVID A. SALE (hereinafter "SALE"), the WORLD ECONOMIC FORUM (hereinafter "WEF") and SILVIO BERLUSCONI (hereinafter "BERLUSCONI"), the former Prime Minister of Italy, and as such may be sued in any district. Lastly, venue is proper in this district under 28 U.S.C. § 1391 (f) (1) as this action is against a foreign state and a political subdivision or agency thereof, namGly defendants the ITALIAN REPUBLIC (hereinafter "ITALY") and the ITALIAN FINANCIAL POLICE, and a substantial part of the events or omissions giving rise to the claims occurred, or, 13

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upon infonnation and belief, a substantial situated in this district.

of property that is the subj ect of the action is

PARTIES The Plaintiff Neil Francis Keenan

10.

At all relevant times, plaintiff KEENAN was an individual citizen of the United

States, who currently is a resident of Bulgaria. KEENAN was introduced to Yamaguchi and the Dragon Family in or about August 2008 in connection with their efforts to place certain Japanese Bonds and Kennedy Bonds into a PPP after proper Bank verification. KEENAN acted as an intennediary in introducing the Dragon Family to Alpha Bank, located in Cyprus, for which

Yamaguchi expressed great appreciation. On account of the assistance and political connections KEENAN provided at that time, Yamaguchi persistently sought out KEENAN to provide direct services on his behalf related to international banking and trading transactions in furtherance of Dragon Family humanitarian programs. KEENAN eventually agreed to accept the responsibilities attendant to representing the Dragon Family in numerous transactions in the world of private financing, international banking, and governmental trading. 11. As a result of the actions of the defendants which gave rise to this action,

described in greater detail in the succeeding paragraphs, on October 28,2010, Yamaguchi executed a certain Special Power of Attorney by which he, with the approval of General Haan, the Head of the Dragon Family, authorized KEENAN to act on his behalf and that of the Dragon Family, for the private placement of or legal return of the DFFI "which were stolen by Daniele Dal Bosco (and others) from you," effectively assigning any cause of action which the Dragon Family might possess as the legal holder of the DFFI. Any such causes of action would be in addition to KEENAN's personal and representative claims as the Dragon Family's designated

14

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Agent under his Special Powers of Attorney, as the victim of the theft and conversion of the DFFI by DAL BOSCO and the various and sundry other conspiratorial and illegal actions of the other defendants. 12. This Special Power of Attorney explicitly superseded and extended prior Powers

of Attorney granted to KEENAN by which KEENAN was authorized to coordinate with the appropriate programs in the United States, Asia and Europe for investment purposes utilizing the DFFI as collateral. In addition to the wide range of responsibilities granted to KEENAN regarding the negotiation of the DFFI and their investment in proper PPPs in a fully secured investment facility, KEENAN, "and only" KEENAN, was specifically authorized to determine what legal proceedings should be initiated in order to recover the stolen DFFI, how to finance it, and seek all damages arising therefrom. KEENAN was authorized to coordinate all aspects of the litigation and determine "what to do with any proceeds from any outcome" as "the bonds were stolen from you and you are financing their retrieval and you are taking all the risks." In effect, Yamaguchi assigned to KEENAN any and all causes of action he or the Dragon Family may have in seeking the recovery of the DFFI or damages arising from their theft "as the legal holder" of the DFFI. KEENAN was placed "solely in control over the legal recovery of said bonds and all aspects of it."

Keenan's Disclosed Principal- the Dragon Family
13. Upon information and belief, the 1934 FRNs described, supra, at 2 (i), came

under the control of the Kuomintang from whom the gold was received in return for the lease payments, and allowed the Chinese Nationalist Government in Taiwan to continue financially. Many of the FRNs were left in Communist China when the Kuomintang had to flee to Taiwan. Further, upon information and belief, the Gold had been nationalized by the Kuomintang who 15

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moved much of the FRNs (but not all) to Taiwan, which allowed for the development of and served as the basis for the underlying wealth of Taiwan. The FRNs were good for value as they were backed by the gold and other precious metals purchased and leased by the United States government. 14. Upon information and belief, the Kuomintang appointed guardians of this Gold

and the securities issued by the United States who came to be known euphemistically as the Dragon Family. The Dragon Family is, in fact, a highly secretive and informal organization that operates between old families within China and Taiwan, above the political divide of the two independent Chinese Governments. The Dragon Family abstains from public view and knowledge, but, upon information and belief, acts for the good and better benefit of the World in constant coordination with higher levels of Global Financial Organizations, in particular, the Federal Reserve System. During the course of its existence over the last century, the Dragon Family has accumulated great wealth by having provided the Federal Reserve Bank and the United States Government with asset assignments of gold and silver via certain accounts held in Switzerland, for which it has received consideration in the form of a variety of Notes, Bonds and Certificates such as those described in 2 that are an Obligation of the Federal Reserve System. Upon information and belief, these Bonds have values ranging in the many Thousands of Trillions of United States Dollars, a relatively small portion of which is involved in the claims giving rise to this action. Each of these currencies, such as the DFFI involved in this action, was and remains duly registered within the Federal Reserve System and are directly verifiable by the Federal Reserve through its efficient verification system and screening process.

16

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THE DEFENDANTS

Daniele Dal Bosco
15. Defendant DAL BOSCO is an individual who, upon information and belief, has

multiple residences in Divonne-Ies-Bain, France, London, United Kingdom and Rome, Italy, although he at all relevant times represented to KEENAN that he resided in Geneva, Switzerland. His actions, which give rise to this action, were acted upon in various locations in Europe, including Switzerland and Italy, and involved the direct use of international telephone communication between Europe and N ew York City.

The Office of International Treasury Control ("OITC") and Individual OITC Defendants
16. Defendant DAL BOSCO, at the relevant times described more fully below, has

acted in concert and conspired with Defendant THE OFFICE OF INTERNATIONAL TREASURY CONTROL (hereinafter "OITC"). Upon information and belief, OITC has its principal offices in Singapore and Cambodia, although according to a document OITC produced in March 2006, it has offices in Malaysia, the Netherlands, the United States, Australia and Ecuador. According to its own website, [www.unoitc.orgJ, OITC has a "Due Diligence Division Only" office located in Washington D.C., and claims to be "an International Financial Institution Chartered under the United Nations Charter Control No: 10-60847." 17. Further, OITC identifies itself as a "Sovereign Entity in its own right, as instituted

by the Nations of the World and as provided for under The Treaty of Paris 1886." It claims to have "substantial assets in its control." OITC spokesmen have claimed that the organization has been chartered by the United Nations under a secret protocol and that it was established as the

17

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Office of His Excellency Dr. Ray C. Dam, changing its name to the Office of International Treasury Control in 2003. 18. In the "General Overview" of its History, provided on the website, OITC traces

its roots to The Trilateral Trillenium Tripartite Gold Commission ("TTTGC") purportedly organized in 1944/5 for a term of fifty (50) years. OITC represents that during this term, the TTTGC held the "Mandate, Rights and Authorities over the Combined International Collateral Accounts of the Global Debt Facility." At the expiration of the term of 50 years, the so-called "Nations of the World," disappointed with the biased way The Combined International Collateral Accounts had been utilized within the 50 Years, agreed not to extend the term of the TTTGC, but instead appointed a single independent person to the position of International Treasury Controller with full rights, authority, and legal ownership of the Combined International Collateral Accounts. 19. Further, according to the OITC website, on January 20, 1995, defendant Dr. Ray

C. Dam (hereinafter, "DAM") was "appointed International Treasury Controller, and Legal Heir and Owner of the Combined International Collateral Accounts of the Global Debt Facility, with full authority and dispositional control of same, under Legal Decadency RCD 1088, executed by the Nations of the World." Also purportedly established on January 20, 1995, was "The Office of International Treasury Control, as the management, administrative and operations organization for His Excellency, Dr. Ray C. Dam," who claimed to be the authorized International Treasury Controller. 20. Defendant DAM is an individual and, upon information and belief, is generally

believed to be a native of Cambodia, although he is also a United States citizen bearing United States passport number 467832299. Upon information and belief, DAM's real name is Amijan 18

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Khali Abdeb and was born in Kyrgyzstan of a mother who was a Cambodian princess. According to the OITC website, His Excellency Ray C. Dam is a "certified and indemnified International Central Banking financial institution operating as The Office of International Treasury Control." Further, as reported on the website, following the confirmation of his Powers and Authorities by the so-called "Washington Panel" in 1998, the establishment of the Institution - The Office of International Treasury Control- was completed on January 20, 2003, whereby "based upon the content and requirements of numerous International Treaties," the OITC was granted "Sovereign Entity Status under the United Nations Charter Control No: 10-160847." DAM reportedly also claims to have earned a degree from UC Berkeley but, upon information and belief, the University has no record of conferring a degree upon DAM. 21. Defendant David A. Sale (hereinafter, "SALE") is an individual citizen of the

United Kingdom who holds himself out as "Deputy Chief of the Council of the Cabinet" of OITC and signs pertinent correspondence (more fully discussed below) as "D.A. Sale, F. LLA, Special Global Envoy, Senior Commercial Advisor to His Excellency, The Chairman, The Office of International Treasury Control, UN Charter Contro1.No: 10-60847." Upon information and belief, SALE lived and worked from a small apartment in a low cost community in Kumpawapi, Udon Thani Province in Thailand and is not known to have ever met with DAM personally, in their entire eight years of association. 22. According to its website, OITC "though not generally or publicly known ... is

the largest International Institution of its kind" and "the largest single owner of gold and platinum bullion in the World, in addition to being a major owner of Bank Debenture Securities, International Treasuries, cash and other forms of securities, all of which are recorded as assets of the Combined International Collateral Accounts of the Global Debt Facility, whose accounts are 19

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held within the Federal Reserve, The Bank for International Settlements, The US Treasury, Swiss National Bank, Swiss Federal Finance Administration." Further, as represented on its website, since being established, the OITC has become the largest single owner of Home Mortgage Securities in the World today, and "Original assets in the form of gold have been wisely and well utilized to create wealth that creates future wealth." 23. Upon information and belief, contrary to the representations of OITC, the United

States Government has stated that "within the Federal Reserve, there exists no organization or department with the initials OITC, nor anything similar to this." Additionally, the aforesaid Bank for International Settlements ("BIS") - an international organization representing central banks - has also denied any knowledge of the OITC. The BIS was established in 1930, and has its principal office located in Basel, Switzerland with two representative offices in the Hong Kong Special Administrative Region of the People's Republic of China and in Mexico City. The BIS is reportedly tl1e world's oldest international financial organization whose customers are central banks and international organizations. BIS does not accept deposits from, nor provide financial services to, private individuals or corporate entities .. According to its website, BIS exists to "foster international monetary and financial cooperation and serves as a bank for central banks." Further, according to OITC's website, OITC claims sovereignty over the Institutional Parent Registration Accounts 984 52700845-34-18 within the Federal Reserve System. 24. Upon information and belief, the OITC has declined to publish any independent

verification of its status, claiming that only individuals with a "level 3" to "level 5" security classification can see "its protocol for verification," which in tum, "can only be undertaken by a senior member of the Government or the Reserve Bank." Further, the UN is allegedly "legally bound to respond to a verification request on the condition that the requisite controls and 20

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procedures are followed or no response will be received from the United Nations." Further, the only way a verification request can be made is "through the UN headquarters in New York or Geneva, not via, or by, any sub-office of the UN." 25. Upon information and belief, the UN has been complicit in the nefarious activities

of OITC in that it has never formally denounced or disassociated itself from OITC, and has allowed OITC to hold itself out to the world community as protected by its umbrella of legitimacy and chartered by the UN itself. It was reported as recently as August 10, 2010 on the internet site of Benj amin Fulford ("Fulford"), a journalist of Canadian descent and citizenship, who currently resides in Japan, and who served as the Asian Bureau Chief for Forbes Magazine from 1998 until 2005, that "The UN never, until the current investigation! began, denied its affiliation with the OITC." 26. On or about December 18, 2010, the Cambodian Phnom Penh Post (the "Post")

reported the arrest of "four employees of a shadowy organisation that has been implicated in a series of bizarre scandals in multiple countries, holding the men on suspicion of large-scale fraud and forgery." Included in the group was "Ray C. Dam, the chairman of ARP-OITC Group Co Ltd." This followed an October report in the same newspaper that examined the "Office of International Treasury Control," of which ARP-OITC is a subsidiary, and questioned the group's alleged associations with the United States government, the United Nations and HSBC Bank. DAM was accused of "forging documents and using forged documents to claim he has roughly

1

See discussion of "The Chiasso Incident", infra, at

63-69.

21

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$500 million." Subsequent news reports confirmed the charges by the Phnom Penh Municipal Court on December 20, 2010 and noted the prior Post reports that OITC officials had "previously been implicated in financial scandals in Ecuador, Fiji and the United Kingdom."
The United Nations and Individual Defendants

27.

Defendant UNITED NATIONS is an international organization whose stated aims

are facilitating cooperation in international law, international security, economic development, social progress, human rights, and achievement of world peace. It was founded in 1945 after World War II to replace the League of Nations, and its main headquarters are located on international territory in New York, New York. Upon information and belief, at all relevant times referenced in this complaint, defendant UN and others, including any officials acting on its behalf, were acting outside the scope of their official capacities and are accorded no immunity for such actions. 28. Defendant BAN KI-moon is a native of South Korea, was the Foreign Minister of

the Republic of Korea from January 2004 to November 2006 and was elected in October 2006 to be, and currently is the eighth Secretary-General of the United Nations. 29. Defendant H.E. Ambassador Cesare Maria RAGAGLINI is the Permanent

Representative of the Italian Mission to the UN in New York, New York, and maintains a residence in New York, New York. 30. Defendant H.E. Ambassador Laura MIRACHIAN is the Permanent

Representative of the Italian Mission to the UN in Geneva, Switzerland.
The Italian Republic, Prime Minister and Related Defendants

31.

Defendant the ITALIAN REPUBLIC is a democratic nation and is a founding

member of what is now known as the European Union. It is a member of NATO and is a 22

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member state of defendant UNITED NATIONS. Defendant SILVIO BERLUSCONI has recently resigned as the Prime Minister of the ITALIAN REPUBLIC. Upon information and belief, BERLUSCONI has been a central figure in the plot and scheme to utilize seized or stolen financial instruments belonging to the Dragon Family for his own personal financial gain and profit in collusion with various other defendants, as more fully described herein. 32. Defendant, the ITALIAN FINANCIAL POLICE, or Guardia di Finanza, meaning

"Financial Guard" ("GdF") is a militarized Italian police force under the authority of the Minister of Economy and Finance of the ITALIAN REPUBLIC and ultimately, at all relevant times herein, acted under the authority of defendant BERLUSCONI. It is a part of the Italian Armed Forces and is essentially responsible for dealing with financial crime and smuggling. Its activities are financial, economic, judiciary and public safety and, among other things under its jurisdiction are smuggling, money laundering, customs and border checks, and political and military defense of the Italian borders.
Giancarlo Bruno and the World Economic Forum Defendants

33.

Upon information and belief, defendant the World Economic Forum (hereinafter,

"WEF") is a Swiss registered non-profit foundation best known for its annual meeting in Davos, Switzerland, which brings together top business leaders, international political leaders, selected intellectuals and journalists to discuss the most pressing issues facing the world, including health and the environment. The WEF was founded in 1971 by Klaus Martin Schwab, a German-born business professor at the University of Geneva. It was originally named the European Management Forum, but changed to its present name in 1987 and sought to broaden its vision further to include providing a platform for resolving international conflicts.

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34.

The WEF is headquartered it Cologny, Switzerland, near Geneva. In 2006 it

opened affiliate offices in Beijing, China and New York, New York. The WEF purports to strive to be impartial, and is not tied to any political, partisan or national interests. In 2009, it opened an office in Tokyo, Japan. It is committed to improving the State of the World and has observer status with the United Nations Economic and Social Council, and is under the supervision of the Swiss Federal Government. 35. Upon information and belief, defendant Giancarlo Bruno (hereinafter, "BRUNO")

is an individual who maintains residences in New York, New York, Geneva, Switzerland and Italy and at all pertinent times has served as Director responsible for the Financial Services Industry Group of the WEF in its New York City offices at the WORLD ECONOMIC FORUM USA, Inc. (hereinafter "WEF USA"), which is the WEF affiliate incorporated in Delaware, a foreign not for profit corporation authorized to do business in the State of New York overseeing the development and content and the relationships with the WEF's partner companies in the Banking, Insurance and Asset Management sectors. Prior to joining the WEF, BRUNO had extensive experience in banking and corporate finance. He also had working experience with defendant UN, at the United Nations Industrial Development Organization ("UNIDO"), where he carried out research responsibilities in the field of comparative development with the Governments Funds Unit of the Mobilization and Management of Financial Resources Division. BRUNO is also a member of the Democratic Party Constituent Assembly, Italy. BRUNO has acted as a central figure in concert with other defendants, including principally DAL BOSCO, the UNITED NATIONS, the ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE and BERLUSCONI in seeking to bribe KEENAN to release the DFFI with which DAL BOSCO had been entrusted, in order that defendants, including BRUNO, could profit illegally from both the 24

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possession and illegal marketing of the DFFI. Upon information and belief, BRUNO's actions took place principally in New York, New York, and involved the use of international telephone communications. 36. Defendants JOHN DOES are individuals or organizations who may have acted in

concert with any or all of the named defendants herein and may be liable to plaintiff for the damages suffered by him. PERTINENT FACTUAL BACKGROUND INFORMATION COMMON TO ALL CAUSES OF ACTION

A.

Keenan and the Dragon Family
37. The aforesaid Akihiko Yamaguchi is a Japanese citizen who was born in

December 1954 and who, in approximately 1986, at the age of thirty-two (32), through his international trade business in Taiwan, was introduced to Mr. Sei Sasaki, who had devoted almost forty (40) years of his life and enjoyed a brotherly relationship with a person at the highest levels of the Dragon Family. Yamaguchi was considered a "son" by Mr. Sasaki, and he was ultimately introduced to the Head of the Dragon Family, General Haan, who, together with other high level members of the Dragon Family, educated him over the years about the accumulation and ownership of the assets held and controlled by the Dragon Family. Upon their meeting, Yamaguchi was appointed a formal member of the Dragon Family by the top person in the Organization, and thereafter began to devote his entire professional career to the Dragon Family from the time he was 35 years old until the present. Mr. Sasaki died when Yamaguchi was 40 years old. 38. Eventually, Yamaguchi became a legal signatory and Controller of the Dragon

Family Organization, with full signing authority to enter into all transactions relating to Dragon 25

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Family Assets and Financial Instruments, irlcluding cash, Private TradinglInvestment Programs with the leading financial institutions throughout the world such as UBS, Bank of Japan and the Federal Reserve Bank. As stated, he was introduced to KEENAN in or about August 2008. 39. Upon information and belief, after decades of inactivity by agreement among the

several factions or sects of the Dragon Family, in the last decade the Organization has undertaken to attempt to contribute significant Billions of United States Dollars for the purpose of aiding numerous global humanitarian purposes, such as relief aid during natural disasters to countries throughout the world, including Hurricane Katrina in the United States, earthquakes in Haiti, China and Indonesia, the Grenoble nuclear disaster, rebuilding the Republic of Georgia's infrastructure, water and energy supply for the Cayman Islands, Bangladesh and more. B. The Grant and Execution of Plaintiff Keenan's Special Powers of Attorney Relating to the DFFI 40. Ultimately, KEENAN was authorized to negotiate the final details and execute

and enter into a cash enhancement andlor project funding transaction relating to the Private Placement of the DFFI. This was to be accomplished, in the case of the Federal Reserve Notes and Kennedy Bond, after verification by the United States Federal Reserve Bank or Treasury Department, or in the case of the Japanese Bonds, after verification by the Bank of Japan. KEENAN was authorized to invest the DFFI into a fully secured Investment Facility and, in fact, was "empowered with all of my powers" by Yamaguchi. It was the intent of the Dragon Family to utilize the assets placed in the various Programs for global humanitarian purposes.

1.
41.

The 1934 United States Federal Reserve Notes Among the assets accumulated by the Dragon Family are the above-described

Federal Reserve Notes ("the Federal Reserve Notes" or "FRNs") which were collected by

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Yamaguchi from Mr. Sasaki and the Dragort Family for use for any world economic aid and humanitarian projects. On October 5, 2008, Yamaguchi declared in writing that he desired to use the Notes for any appropriate humanitarian investment program immediately by use of his written authority and power as signatory of the Dragon Family. 42. KEENAN was authorized by Yamaguchi to coordinate the investment of249 of

these United States 1934 Federal Reserve Notes, each with a face value of Five Hundred (500) Million Dollars, with a total face value of One-Hundred Twenty-Four (124) Billion 500 Million United States Dollars, and each bearing an interest coupon of 4% per annum since 1934. 43. For the services he was to provide in connection with the placement of the Federal

Reserve Notes, KEENAN was to receive at least 30 % of any profit sharing from the particular PPP, such profits to be invested into infrastructural and economic development projects.

2. The "Japanese Bonds"
44. On or about February 25,2010, replacing a similar instrument executed on

February 20, 2009, which had a six month term, KEENAN was granted a Special Power of Attorney in a writing executed by Yamaguchi to act on Yamaguchi's behalf for the coordination of investing certain assets of the Dragon Family, to wit, the above-referenced two (2) 57 Series Japanese Government Bonds Nos. A 1306 and A 1310 (the above-described "Japanese Bonds") The Special Power of Attorney was unlimited as to time. 45. Upon information and belief, in or about 1997, Ex-Japanese Finance Minister,

Mr. Hiroshi Mitsuzaka, and Ex-Japanese Prime Minister Keizo Obuchi, had delivered to their
Japanese Trustee Five-Hundred (500) 5ih Series Japanese Government Bonds which had been issued largely based upon Dragon Family Funds for future use in world economic aid and humanitarian projects. After the deaths of Messrs Mitsuzaka and Obuchi, the Trustee delivered 27

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many of these Japanese Bonds, including thb aforesaid two (2) Japanese Bonds, to one of Yamaguchi's foundation associates, who was well aware of their history. Thereafter, many of these Japanese Bonds were returned to Yamaguchi to be utilized for any appropriate humanitarian investment program under his authority and power as authorized signatory of the Dragon Family. Yamaguchi had been in possession of these Bonds since at least October 18, 2006. The person who was designated to handle the bonds by Yamaguchi was instructed to obtain validation of the bonds from the Bank of Japan or Mizuho Bank, as attested to by Yamaguchi on or about February 20,2009. 46. By the explicit terms of the Power of Attorney, Yamaguchi appointed KEENAN

to act on his behalf for the coordination of the Japanese Bonds for investment with the appropriate parties in the United States, Asia and Europe in legally registered and chartered trading Programs, known as PPPs or for other funding purposes by use of the Bonds as collateral. KEENAN was further empowered to coordinate and proceed on any material conditions and terms he deemed proper and was further authorized to utilize Yamaguchi's bank account in his own designating banks and to sign any Private Program contract as Yamaguchi's agent. KEENAN was authorized as attorney-in-fact for authentication and due-diligence of the Japanese Bonds through KEENAN's bank to the Bank of Japan by using the two certified copy Japanese Bonds including any and all of the documents showing Yamaguchi's endorsements on the reverse side of those Bonds. 47. F or the services he was to provide in connection with the placement of the

Japanese Bonds, KEENAN was to receive 30% of any net profit from the particular PPP.

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3.
48.

The Kennedy Bond
KEENAN was also authorized by Mr. Yamaguchi to coordinate the investment of

the one (l) Kennedy Bond entrusted to him with a face value of One (l) Billion United States Dollars. As attested to by Yamaguchi in his statement of the Kennedy Bond History dated September 6,2008, the Kennedy Bond is good, clean, clear and free from any liens and encumbrances. 49. For the services he was to provide in connection with the placement of the

Kennedy Bond, KEENAN was to receive at least 30% of any profit sharing from the placement of the bond in a projects. 50. KEENAN personally accepted the custodianship and income rights therefrom PPP for investment into infrastructural and economic development

accorded to him in accepting responsibility for investment of the Federal Reserve Notes on January 22, 2009 in Zurich, Switzerland. He took possession of the Japanese Bonds and Kennedy Bond on May 5, 2009, at which time he acknowledged in writing the receipt of all of these instruments which comprise the DFFI. KEENAN remains the only legal custodian of the DFFI by virtue of the written authority granted by the Dragon Family through Yamaguchi.

C.

Events in April-May 2009, Preceding the "Chiasso Incident"
51. After receiving the DFFI, Yamaguchi, aided by KEENAN's connections in

Europe, and with additional Dragon Family financial instruments, began to approach various international Governments, which were either in need of humanitarian aid or had provided the Dragon Family with assistance in the past. In tum, KEENAN proceeded to select individuals whom he knew and trusted to assist him in either finding or establishing a suitable PPP, or to work with the principals who would be involved in obtaining proper verification of the DFFI, 29

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which would be used as collateral in furthernnce of global humanitarian programs. Alternatively, if the DFFI were not placed in a PPP, a suitable arrangement for concluding an outright loan transaction would be sought. During the spring of 2009, KEENAN was very active on behalf of Yamaguchi and the Dragon Family meeting with traders and Bank representatives, particularly in Zurich, Switzerland, in furtherance of these goals. 52. In April 2009, KEENAN was approached by a group of Turkish investors (the

"Turkish Group") who were interested in establishing a relationship with the Dragon Family through the Turkish Group's supposed traders in Zurich. During the course of the ensuing meetings and negotiations, Yamaguchi was present at various times when KEENAN would display, upon request, certain Dragon Family financial instruments, which notably included the very same 2 Japanese Bonds, Nos. A 1306 and A1310, and the same Kennedy Bond, which comprise a portion of the DFFI that are the focus of this lawsuit. 53. During this period of time, KEENAN and Yamaguchi were welcomed and

entertained in Zurich not only by several legitimate traders, lawyers and Bank representatives, eager to do business with the Dragon Family and Yamaguchi as the Family'S authorized signatory. At one meeting with Bank Julius Baer & Co. Ltd. ("Julius Baer"), attended by KEENAN, Mr. Benny Guttman, Executive Director, went immediately to Yamaguchi and told him that he had been waiting a long time to meet him. Guttman hosted an elaborate buffet luncheon in honor of Yamaguchi. After discussions among the group, Guttman asked to review the DFFI which Yamaguchi had with him. After looking at the instruments, Guttman asked if he could take them to another room and have copies made. After approximately forty (40) minutes, Guttman offered Yamaguchi the opportunity to deposit them in Julius Baer. KEENAN was aware that security was present and that in the event of any determination that the DFFI were not 30

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genuine, he and Yamaguchi were subject to':immediate incarceration. This was consistent with the expectation that The Bank selected by Yamaguchi was expected to act accordingly so that proper verification of the DFFI would be achieved. Only licensed financial traders would be considered to act with respect to the DFFI. However, KEENAN and Yamaguchi were also introduced to many individuals who were mere "brokers" who, as it happened, sought to take advantage of their exposure to the opportunities presented by the introduction to the Dragon Family and its significant assets. 54. In connection with these various meetings and myriad other meetings with several

people holding themselves out as traders and Banking representatives, particularly individuals connected with the Turkish Group, KEENAN and Yamaguchi were led to believe that all necessary arrangements and Bank verifications had been made in order to establish a PPP through a Credit Suisse branch in Alstatten, Switzerland. On or about May 18,2009, Yamaguchi accurately confirmed to Credit Suisse through Assistant Vice President Andre Weishaupt that the 2 Japanese Bonds were cash backed instruments of the Dragon Family under his name. He represented that the bonds had a total value of $19 billion U.S. dollars, free of liens and encumbrances. He also requested a Safekeeping Receipt of the bonds that had been deposited on or about May 15,2009, pending verification from The Bank of Japan and the U. S. Treasury Department which issued the Kennedy Bond and a joint account was opened for Yamaguchi. 55. Additionally, accounts for the investment of the funds, which were expected to

become available upon the establishment of the PPP and resultant trading profits were opened at DZ Privatabank in Zurich, as well as Coutts & Co., a private bank whose principal place of doing business is in London, United Kingdom. Arrangements were also made to set up an account at the Central Bank of Switzerland, the Swiss National Bank (aka Schweizerische Nationalbank), 31

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which subsequently assisted in the verification process regarding the Dragon Family Bonds in May and early June 2009. 56. During this period of time, which involved several waiting periods while various

related contracts and trading programs were being approved, it was the practice of Yamaguchi and Watanabe to travel from Switzerland to Carimate, Italy, where they would visit and stay at the home of their longtime friend, Alessandro Santi ("Santi"). On such trips, the pair would often travel through the Chiasso railway station, in the canton of Ticino, Switzerland, which is owned by the Swiss Federal Railways, and serves as a border station between Switzerland and Italy. 57. On approximately May 24, 2009, after one such trip, the pair had returned from

Carimate, and was staying at the Hilton Hotel Airport in Zurich. While there, they learned that there had been a maj or change in the personnel involved in completing the transaction with the Turkish Group that had approached KEENAN several weeks earlier. That Group appeared to have been replaced as serious questions had arisen about the legitimacy of certain of its members. However, a new group under the leadership of a Baron von Gise, appeared to be ready, willing and able to establish a legitimate PPP, or so-called "Sovereign Program." Yamaguchi and Watanabe thus decided to return to Italy on May 27 to await the completion of preparations by Baron von Gise. 58. On May 31, 2009, KEENAN and Yamaguchi received news of yet another

setback in their plans and were awaiting confirmation that the details had been worked out in a satisfactory manner. They were advised that everything would be in place and a Trading Agreement ready to be executed by Yamaguchi between June 3-5.

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59.

On June 3, 2009, KEENAN was advised by Swiss lawyer Tobias Braegger, who

had acted as the attorney for the Turkish Group, that all necessary preparations would be completed by the next day and the transaction would be completed within the next week. On the same day, Yamaguchi advised KEENAN that he would be leaving Italy for a meeting in Madrid on other business matters. 60. Although KEENAN had been advised during this time period that the Swiss

Central Bank had verified the Kennedy Bond, he was ultimately informed (following the Chiasso Incident described infra) that both Banca Intesa and the Swiss Reinsurance Company declined to engage in further transactions regarding it "for political reasons." 61. Despite the failed negotiations with the Turkish Group, and which might have

caused Yamaguchi to exercise more care, Yamaguchi, after receiving a telephone call while having lunch with Santi and Watanabe in Carimate, suddenly left for the train station and headed for Spain. 62. On June 4, 2009 Yamaguchi sent an email to KEENAN from Barcelona advising

that he was well, but was otherwise silent as to the events that had transpired upon his departure from Carimate.

D.

The Chiasso Incident
63. In fact, unbeknownst to KEENAN until days later, upon their arrival at Chiasso

on this particular trip, both Yamaguchi and Watanabe were approached directly by the ITALIAN FINANCIAL POLICE and their bags were searched. The pair was found to be carrying Dragon Family Instruments (hereinafter, the "DF Chiasso Instruments") virtually identical in content to a portion of the DFFI, which are the focus of this litigation-in an amount approximating $134.5 Billion U. S. Dollars. Ironically, this was the exact amount that the United States Treasury 33

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Department had announced on or about March 30,2009 remained in its Troubled Asset Relief Program ("TARP"). These instruments included 249 1934 Series Federal Reserve Notes. (similar to the 249 FRNs entrusted to KEENAN by the Dragon Family, except that they bore serial nos. D 45183602A to D 45183850A), and 10 Kennedy Bonds issued in 1998 (Nos. API! 025691 A to No. APll 025700 A), each with a face value of One Billion U.S Dollars (as compared to the 1 Kennedy Bond entrusted to KEENAN). 64. As reported by the Japanese and Italian press at the time, upon arriving at

Chiasso, Yamaguchi and Watanabe were detained by the ITALIAN FINANCIAL POLICE after attempting to enter Switzerland with "undeclared United States Treasury Bonds concealed in a suitcase with a false bottom." The Japanese Consulate General in Milan confirmed that the "detention" had taken place while trying to confirm the men's identities. Eventually, neither Yamaguchi nor Watanabe were arrested, although their computer and eight telephones were also confiscated. Reportedly, Yamaguchi advised the authorities that the pair was in possession of valid historic bonds and that a mistake was being made. According to Japanese press reports, Yamaguchi and Watanabe were released as they "broke no laws." Upon information and belief, it was Yamaguchi' s position that since there had been no verification in accordance with the protocol required by the Federal Reserve system, and no negotiation with the Federal Reserve concerning the actual value of the financial instruments he was carrying, no laws had been broken. Charges against the two were expected to be heard before the Procura Della Republica in Como, Italy in May 2011. According to at least one Italian newspaper, "La Provincia," on or about June 30, 2011, Yamaguchi and Watanabe were sentenced to three and a half years in prison for trying to "smuggle" debt securities deemed to be false. The story also reported that

Mr. Santi had bargained in a preliminary hearing for a year and four-month probation on related 34

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charges. The Japanese were reportedly provided with an attorney named Campisani in Como. In March 2010, both Keenan and his attorney offered to assist Attorney Campisani but their offers to help went unheeded. Upon information and belief, Campisani withdrew from the case without ever responding to Keenan or his· attorney. 65. Upon information and belief, approximately three years prior to this incident, the

investment banking firm of Goldman Sachs in the United States had formally authenticated the FRNs entrusted to KEENAN and owned by the Dragon Family, virtually identical to and sharing the identical history of the FRNs seized at Chiasso. KEENAN believes that all of the 1934 FRNs, including those seized by the Italian authorities at Chiasso, as well as the DFFI entrusted to KEENAN, were fully backed by United States gold bullion, authentic, and subject to verification by the Federal Reserve when properly presented by the legitimate holder or their representative, i.e., plaintiff herein, KEENAN. 66. At the time of the seizure, Colonel Rodolfo Mecarelli, GdF Commander in Como,

Italy, was reported to have stated that the seized DF Chiasso Instruments were very genuine looking, "meticulous" work, and "indistinguishable" from authentic instruments and were waiting to be confirmed. Yet, approximately two days after the seizure, the United States Treasury claimed that the Federal Reserve Notes, which had been seized at Chiasso, were counterfeit based solely upon its viewing of pictures of the Notes over the Internet. Further, while confirmation of the DF Chiasso Instruments was still pending, on June 25, 2009, the New York Times reported on the story and included the statements of a United States Secret Service spokesman to the effect that the Secret Service had performed an inspection, as required by the Italian Judiciary, and found that the Instruments were fictitious and had never been issued by the Federal Reserve or the United States Treasury. Upon information and belief, the assertions that 35

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the FRN s seized at Chiasso are not genuine are inaccurate as will be determined through the verification process through the Federal Reserve System's black screen process. 67. It had been reported that it remains unclear to the Italian authorities how any such

inspections had been carried out and even whether the commission of American experts who were expected to travel to Italy to perform the inspection, had ever arrived. Further confusing the facts from reported allegations, it was also reported that the DF Chiasso Instruments were accompanied by a recent and original bank record from Credit Suisse in Switzerland. 68. Further upon information and belief, soon after the seizure at Chiasso,

representatives of the ITALIAN REPUBLIC approached representatives of the Chinese Government regarding the possibility of paying the "penalty" (40 % of the value of the seized Instruments) for the alleged failure to declare the Instruments in crossing the SwisslItalian border at Chiasso. Further, upon information and belief, the negotiations were halted when it was suggested that the 40% penalty would be paid, but in return for such payment, the ITALIAN REPUBLIC would reimburse its debt to China, which debt greatly exceeded the amount of the penalty Italy demanded for the return of the Chiasso Instruments. Upon information and belief, The ITALIAN REPUBLIC and the ITALIAN FINANCIAL POLICE have steadfastly declined to return the DF Chiasso instruments, but have actively and illegally sought to convert such Instruments for their own benefit, as more fully described herein. 69. Despite the La Provincia newspaper article, an extensive search for the file related

to the seizure at Chiasso by Keenan and his representatives, no such file has been located. Such representatives were told in August 2011 that the file in Como could not be found because of the holiday season. In September, although they were told that the file had been transferred to the centralized system in Rome, they were ultimately advised that "there is no such file." In early 36

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October, a telephone call was made to the Justice Department in Rome and direct contact made with a gentleman who identified himself as Giorgio Divincenzo, Chief Inspector from the GdF.

Mr. Divincenzo was described to appear to be very helpful and reported that he would run the
complete database on Alessandro Santi, Akihiko Yamaguchi and Mitsu Watanabee, all three men charged at Chiasso. He confirmed that it would have been normal procedure for the Como file to have been transferred to Rome because two of the defendants were foreigners and translations would be required. Yet, he reported that nothing could be found on the matter. He further responded, when asked if there could be any hidden or highly classified files, that he had full authorization and, as his responsibilities required him to have full and complete access because of his rank as Chief Inspector, he was also the Interpol liaison officer. He made it eminently clear that there was no file to be found. Further, there has been no known report or record of the destruction of the instruments seized at Chiasso which, upon information and belief, would have been expected given the reported decision of the Court.

E.

The Events of July 2009 and the Introduction of DAL BOSCO to KEENAN
70. Upon information and belief, on or about July 9,2009, following a long period of

emails between the two, Mr. Leo Zagami, a self-described 33 rd degree Free Mason, who, as of Apri12008, had reportedly claimed to be the leader of a breakaway faction of the Knights Templar and high-level Freemasons centered around the elite of the Masonic P2 (Propaganda Due) Lodge in Monte Carlo, arrived in Japan to speak with Fulford. According to Fulford, Zagami had claimed to be a representative of the Vatican Illuminati and other European sect societies and had been looking to make contact with certain Asian Secret Societies. After the July 2009 meeting, Zagami informed Fulford that he had information that Yamaguchi and Watanabe had been "set up" at Chiasso and further that he had "inside information" concerning 37

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the seizure of the DF Chiasso Instruments. Zagami immediately put Fulford in touch with the Italian Financial Police who confirmed the authenticity of the seized Instruments. 71. Upon his return to Italy, Zagami contacted Fulford to arrange for a meeting in

Rome where, among other things, they again discussed the Chiasso Incident. At that time, Zagami introduced Fulford through SKYPE conversations to DAL BOSCO whom Zagami represented was a trustworthy Vatican Banker and also associated with the P2 Masonic Lodge. Zagami told Fulford that DAL BOSCO would be able to help "cash the bonds seized by the Italian Treasury Police." 72. Upon information and belief, Fulford passed this information along to a member

of the British Royal Family who then passed it on to a "group of Asians of royal blood known as the Dragon Family." On or about February 9, 2010, Zagami sent Fulford another email, on behalf of an acquaintance, inviting him to Italy and Switzerland to discuss the transfer in custodianship of the DFFI from KEENAN to DAL BOSCO and other issues. 73. As a result of the FulfordiZagami discussions in or about July 2009, KEENAN

received a request for a meeting from DAL BOSCO, who used Zagami's name as a reference. KEENAN and DAL BOSCO spoke via Skype conversations on an almost daily basis for approximately six weeks thereafter until they arranged to meet in Italy in September. During the course of those discussions, DAL BOSCO represented to KEENAN not only that he was the financial advisor to Zagami, but also to the Vatican, Vatican City, Rome as well as the Treasurer of the P2 Masonic P2 Lodge in Rome and Monte Carlo working directly with Zagami. 74. Since the time he took possession of the DFFI, and during the course of his travels

throughout Europe and crossing of international borders, it had been KEENAN's practice to maintain personal possession of all DFFI in order to avoid possible confiscation or other loss. In 38

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the normal course, KEENAN would place the DFFI with hotel security before traveling, for instance, throughout Italy, Switzerland and Austria, while on his various business ventures. Over time, and throughout his discussions with DAL BOSCO, KEENAN became convinced that

it was in his best interests and safety, and that of his principal, the Dragon Family, to entrust
DAL BOSCO with custodianship of the DFFI for safekeeping, most especially in light of the representations DAL BOSCO had made about his own credentials. 75. In early September 2009, KEENAN offered such custodianship to DAL BOSCO,

and by electronic transmission dated September 2, 2009, DAL BOSCO acknowledged to KEENAN his "ACCEPTANCE" as "Custodian of the Dragon Family Financial Instruments" and noted, among other things: (a) I can assure you that you will never regret making this decision. You are aware of the fact I am well trusted and a financial advisor within the Vatican and Mason circles and would never jeopardize my position with them for anything. (b) My word is my bond and my word is Gold.

(c) I will be waiting for your Zurich arrival so that we can do great things for the world. I understand clearly that I am not to discuss these bonds with anyone outside the immediate circle and my privacy is integral to the success of many nations. (d) I further understand you are the authorized representative and Power of Attorney for said bonds and I will entrust them believe me as though it was my life depending on it. Therefore I humbly accept the custodianship of said Bonds in which I am only"to return them to either you or Mr. Yamaguchi. Not any other! (e) Although electronic this email is to be considered my legal binding acceptance of the following bonds: 1. 250 Federal Reserve Notes, Series 1934, Numbers D 45184101 A to 45184350 A, with each having a face value of 500 Million USD each totaling 125 Billion USD. 39

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2. Japanese Bonas 57 Series numbers 1306 and 1310 with a value of 19 Billion USD including the interest. 3. 1 Kennedy Bond with a value of $1 Billion USD.

(f) Will be ready when called upon to deliver said notes to you. Thank you once again for your kindness. Yours truly, Daniele Dal Bosco Italian Passport C 165124 76. On or about September 8, 2009, KEENAN flew to Italy to meet with his very

close friend, Alessandro Santi, with whom Yamaguchi had met prior to the seizure at Chiasso in June. It was arranged that DAL BOSCO would meet KEENAN and Santi in Milan, as DAL BOSCO wanted to speak with Santi about his knowledge of the Chiasso Incident. 77. On September 9, 2009 DAL BOSCO took a train into Carimate and KEENAN

and Santi picked him up at the train station. This was the first time KEENAN had met DAL BOSCO personally. At this time, the Milan Fashion Show was taking place which was being attended by DAL BOSCO's girlfriend, Alessia. After the Fashion Show ended, the group traveled to Rome where DAL BOSCO offered to intercede on behalf of Santi with people he claimed to know were associated with the ITALIAN FINANCIAL POLICE and the Italian Government, including former Italian Prime Minister, Silvio BERLUSCONI. 78. Upon information and belief, thereafter, according to DAL BOSCO, he visited

with the ITALIAN FINANCIAL POLICE who advised him that the financial instruments that had been confiscated at Chiasso were authentic, but that Santi had been charged with illegal possession of certain bonds. DAL BOSCO further reported that the Italian Government, -through BERLUSCONI, was demanding 400/0 of the instruments' face value for their return. KEENAN was already aware of that information. 40

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79.

Throughout this period of time, KEENAN was working on coordinating efforts to

carry out his instructions regarding the intended proper placement of the DFFI with which he had been entrusted for the benefit of certain European countries and business entities for investment in recognized PPPs. For instance, on or about September 13,2009, Mr. Stanley Somberg (hereinafter "Somberg"), a personal friend of KEENAN, flew into Rome to spend a few days with KEENAN and for a planned trip with KEENAN to Vienna, Austria. 80. DAL BOSCO joined KEENAN and Samberg on the trip to Austria. On that trip,

KEENAN closely observed DAL BOSCO, whose words and actions appeared to justify KEENAN's decision to entrust the DFFI to DAL BOSCO and corroborated his representations that he was associated with the Monte Carlo P2 Masonic Lodge and a financial advisor to the Vatican. DAL BOSCO spoke freely to Somberg and KEENAN about his connections with the Vatican and the Italian Government. However, it was also during that trip that DAL BOSCO told KEENAN that he had "good news" for him. Upon inquiry, DAL BOSCO explained that he had received a call from a friend inside The ITALIAN POLICE (GdF) who had informed DAL BOSCO that the GdF was willing to sell back the DF Chiasso.lnstruments for 10% of their face value. KEENAN responded that he doubted that the Dragon Family would be interested in buying back its own Bonds and reminded DAL BOSCO that he had no power of attorney to act on behalf of the Dragon Family with regard to those Instruments and that his designated mission and authority was to place only the DFFI with which he had been entrusted into a legally recognized PPP. 81. Upon their return to Switzerland, on or about September 18,2009, prior to

KEENAN's departure for the Zurich airport and return home to Bulgaria, KEENAN physically entrusted the DFFI to DAL BOSCO, as had been planned and acknowledged by DAL BOSCO. 41

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82.

On subsequent and frequent trips to Zurich, DAL BOSCO would meet KEENAN

at the Hilton Hotel Airport and place the DFFI in KEENAN's possession until KEENAN's departure at which time KEENAN would again entrust the DFFI to DAL BOSCO.

F.

Negotiation for Placement of the DFFI into a Private Program 1.
83.

The Introduction to H. Edward Wales
KEENAN subsequently traveled to Zurich on or about January 16,2010 for

meetings with people whom he believed could help in the placement of the Federal Reserve Notes or the Kennedy Bond, which comprised part of the DFFI, into a qualified PPP. KEENAN remained in Zurich until February 13,2010. On or about January 29,2010, KEENAN took DAL BOSCO with him to meet with financial trade arranger H. Edward Wales (hereinafter "Wales") in Geneva, Switzerland at the Intercontinental Hotel. 84. The meeting with Wales was arranged through a telephone call and email

communication to Wales from Sonya Nikolova Alexieva, a citizen and resident of Bulgaria. Also attending the meeting was Javad Moharr, an Iranian citizen, and a resident of Switzerland. The purpose of the meeting originally was to discuss the placement of the two (2) Japanese Bonds into international trade through a qualified and legal PPP. However, at the meeting, KEENAN requested DAL BOSCO, who was physically holding the entire DFFI portfolio for KEENAN, to show the portfolio, including the Federal Reserve Notes and the Kennedy Bond, to Wales. KEENAN inquired of Wales whether he could also arrange for a trading program which would include these instruments as well. This was the first time Wales had seen an original Kennedy Bond, and he informed KEENAN that he would like to concentrate on the Japanese Bonds, but would be interested in further examination of the FRNs and Kennedy Bond for potential use in a PPP. Wales gave the portfolio back to KEENAN, who then gave them to DAL 42

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BOSCO, and instructed DAL BOSCO to sehd copies via email to Wales for his further review and recommendations. DAL BOSCO was in possession of the instruments when everyone left the hotel. 85. In accordance with KEENAN's instruction, on or about February 3, 2010, DAL

BOSCO forwarded copies of the documents of the DFFI via e-mail to Wales. On at least two other occasions, DAL BOSCO also brought the DFFI to additional meetings in Zurich, Switzerland in line with his role as Custodian, and in order to facilitate KEENAN's plan of placing the DFFI into a PPP.

G.

Doubts
86.

DAL BOSCO

Upon information and belief, unbeknownst'to KEENAN, after considerable

pUblicity throughout Europe and Asia following the Chiasso Incident, DAL BOSCO became intent not only on learning more about the Dragon Family and, in particular, the nature and value of the various Financial Instruments owned by the Dragon Family, but diligently began to research how such Instruments were utilized in the international global finance system. DAL BOSCO's interest intensified when he learned through his contacts in the ITALIAN GOVERNMENT and THE ITALIAN FINANCIAL POLICE that the Federal Reserve Notes and Kennedy Bonds owned by the Dragon Family and seized at Chiasso were genuine. Further, cognizant of the fact that he was legally unauthorized and thus unable to negotiate in any lawful transaction regarding the DFFI entrusted to him by KEENAN, without the authority of KEENAN andlor Yamaguchi on behalf of the Dragon Family, DAL BOSCO sought assistance from various other sources and contacts, in order to act upon and perpetrate a fraud in connection with the sale or placement of the DFFI in the global marketplace through stealth, conversion and bribery. 43

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87.

DAL·BOSCO's research and connections ultimately led to his introduction to

defendants SALE and OITC. As revealed by an OITC spokesman and published to the world at large on or about January 3, 2011, on Fulford's Internet website, the assertion that, following initial communications from DAL BOSCO on February 2,2010, defendant DAM executed a written agreement with DAL BOSCO on March 16, 2010. This agreement acknowledged that OITC was fully aware ofDAL BOSCO's intentions to steal the DFFI from KEENAN and place them in the possession of OITC which would claim ownership pursuant to its alleged authority under the provisions of its claimed U.N. Charter and the D.N.'s "sovereign immunity" protections. 88. Upon information and belief, DAL BOSCO's connections in Europe included

defendant BRUNO and the WEF who, in turn, had direct contacts with defendant the UNITED NATIONS. Thereafter, as set forth in more detail below, the various defendants entered into various criminal schemes and enterprises whereby DAL BOSCO would knowingly betray, violate and breach all of his previously acknowledged fiduciary duties to KEENAN and thereby the Dragon Family, by stealing the DFFI and converting possession of the DFFI for their own selfish, criminal and personal financial gain. 89. During KEENAN's stay in Zurich in the January-February 2010 time period,

DAL BOSCO suddenly and surprisingly advised KEENAN that he had made contact with high level UNITED NATIONS officials, through the assistance of BRUNO and the WEF, whereby DAL BOSCO and KEENAN could receive One-Hundred ($100,000,000.00) Million D. S. Dollars for all of the United States Federal Reserve Notes contained in the DFFI. The offer did

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not include the Japanese Bonds or the Kennedy Bond which, as described, form a portion of the DFFI. 90. DAL BOSCO asked KEENAN if he wanted to pursue this offer but stated that, as

a condition, neither Yamaguchi nor the Dragon Family could be involved and that the UN did not want Yamaguchi involved. KEENAN emphatically rejected any interest, noting further that the Federal Reserve Notes were not his to sell. 91. DAL BOSCO told KEENAN that "I assure you this is our best deal and my friend

Giancarlo from the Economic Forum stands behind it. He went to see our friends in the UNITED NATIONS and this is very delicate but can be done but nothing for Yamaguchi or the Dragon Family." DAL BOSCO further stated that Yamaguchi would not only never know the DFFI had been stolen but that the rightful owners, the Dragon Family, would "never be able to receive ONE CENT" from the transaction. Further, upon information and belief, the DFFI would be invested directly through the UN and its Sovereign Program and that the transaction "was all set up" and "no questions would be asked." DAL BOSCO also expressed a great reluctance to discuss the UN or BRUNO's involvement and stated that no one would ever get to speak to BRUNO or his ITALIAN FINANCIAL POLICE or Vatican connections.

H.

The Speaker Telephone Conference Call between DAL BOSCO and BRUNO
92. Following Dal Bosco's report to KEENAN of the offer from the UN and

BRUNO, and while still in Zurich in early February 2010, KEENAN had gathered several close business associates and friends for a routine meeting/luncheon in the VIP Room on the 5th floor at the Hilton Zurich Airport Hotel in which he stayed regularly while on business in Zurich. KEENAN was accompanied by DAL BOSCO, with whom he was working on the aforesaid potential transaction involving the Japanese Bonds with Wales. Other guests of KEENAN 45

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included Nikolai Raykov, a Canadian citizen (hereinafter, "Raykov"), Vasil Ganov, a Bulgarian citizen (hereinafter, "Ganov"), Ognyan Marinov, (hereinafter, "Marinov"), also a Bulgarian citizen and retired Intelligence officer, as well as Walter Berens (hereinafter, "Berens"), a citizen of Germany. At one point, DAL BOSCO arranged to place a telephone call via speaker phone to a man whom he identified as Giancarlo BRUNO. DAL BOSCO indicated to those present that the call was intended for KEENAN's ears only but that they could listen to the call. During the course of the call, the man who was identified as BRUNO stated that he could arrange to "put $100 Million USD into KEENAN's hands if KEENAN agreed to it." KEENAN, who has always been told that any involvement participation by BRUNO must be kept a secret, was thus caught off guard when a call of this nature was to take place, was disgusted with the call and walked away from the table while DAL BOSCO continued the call with the man he identified as BRUNO.

1. 93.

Recollections of Mr. Raykov
In a private discussion with DAL BOSCO in a hallway outside the meeting room,

Raykov expressed concern and doubt that the man whose voice was heard on the speaker phone was actually BRUNO. DAL BOSCO asked Raykov if he had any idea who BRUNO was and Raykov responded in the negative. DAL BOSCO then repeated that BRUNO could arrange for a $100 Million USD payment to KEENAN, if KEENAN agreed to it. 94. Further, after the advice he received from DAL BOSCO, Raykov asked DAL

BOSCO ifhe could speak with BRUNO and was told that he could, but only from a pay phone and not a cell phone. Raykov proceeded to drive with DAL BOSCO to the airport in a taxi and DAL BOSCO then placed a call to BRUNO who spoke directly with Raykov. BRUNO told

46

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Raykov that if he could convince KEENAN to take the money, he would make sure that Raykov's family would be set for life. 95. During this telephone conversation, BRUNO said that the DFFI would "be placed

into a federal program using the UN as protection" along with "his company" which would "generate unlimited capital for everyone involved." BRUNO assured Raykov that "there would be no problems and that this was being blessed by the UNITED NATIONS" which "would protect everyone" as the DFFI would be "placed into a Sovereign Program" after which the DFFI "would disappear" and "there would be no questions asked." 96. Remaining somewhat skeptical that the person he had just spoken with was

actually BRUNO, Raykov told DAL BOSCO that he did not believe him. DAL BOSCO thereupon called the number again and told Raykov to listen. The person speaking identified himself as Giancarlo BRUNO. DAL BOSCO also gave Raykov a telephone number in New York to call when Raykov was in the United States. Raykov, in fact, called the telephone number he was given while in New York in July and the call was answered by BRUNO. Raykov told BRUNO he was just checking the telephone number he had been provided by DAL BOSCO. BRUNO then advised Raykov that DAL BOSCO had taken the DFFI which had been entrusted to him by KEENAN and "now more than ever" Raykov was needed to speak with KEENAN to try to convince him to cooperate with DAL BOSCO and BRUNO. 97. Raykov subsequently told KEENAN to be careful and that "the wolves are

surrounding him." KEENAN told Raykov not to get involved. Raykov spoke again with DAL BOSCO and told him "to forget" about persuading KEENAN to cooperate with him. DAL BOSCO responded that KEENAN would regret that as he "was no longer in possession" of the DFFI.

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2.
98.

Recollections of Mr. Gano-.v
Ganov recalls that following the telephone call, he inquired ofDAL BOSCO what

he would receive from this "transaction" and DAL BOSCO responded that he would receive 50% of KEENAN's $100 Million USD, the total amount of which would be placed into a Sovereign Program by the UN and that they would each receive 2000/0 monthly returns minimum from the total "investment" of$100 Million USD. DAL BOSCO was then asked how much the UN, WEF, BRUNO and OITC would receive, and he responded that this was not KEENAN's business and not to ask because "it can only cause trouble." DAL BOSCO stated that the Notes would be placed into. the "Sovereign Program by the UN" and then, after a completed program, that the Notes would be returned to their "owners," the OITC. DAL BOSCO also urged Ganov to help him convince KEENAN to participate in his scheme. 99. DAL BOSCO informed Ganov that "everyone was also protected by the Italian

Financial Police and the Italian Government itself." DAL BOSCO boasted about his position as Financial Advisor to the Vatican and Treasurer of the Masons and that "nothing could go wrong." 100. Ganov and Berens also told KEENAN that they thought DAL BOSCO's

placement of the call in a public, rather than a private setting was ill-advised and put BRUNO, whom they considered to be an important man, in a very bad light. Ganov thought DAL BOSCO was playing the role of a salesman trying to sell something to all present. Raykov told Ganov that he thought DAL BOSCO was a thief and that he thought DAL BOSCO was hiding the truth from KEENAN and was using BRUNO and the UN to assist him in his scheme. Ganov told KEENAN that he did not trust DAL BOSCO and was assured by KEENAN that he had no

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interest in DAL BOSCO's "offer" and that his goal was not only to protect the DFFI but also to get them placed into a proper PPP. 101. During KEENAN's trip to Zurich, Ganov asked if he could view the DFFI and

DAL BOSCO retrieved them for viewing. Ganov inquired as to their authenticity and DAL BOSCO responded that the UN had verified their authenticity. Ganov also inquired about Yamaguchi, and DAL BOSCO stated that he was a powerful, but unpopular man and that the UN would not do business with him. 102. In discussions with DAL BOSCO, Ganov was informed that BRUNO was "100 Million Dollars by Friday if things worked right" and should

prepared to pay

KEENAN consent to the transaction. When Ganov commented that he thought KEENAN would be jeopardized by any involvement in such a transaction, DAL BOSCO responded that "no one can get in trouble ... it is perfect ... the UN protects everyone under their shield." Ganov was also told by DAL BOSCO that most of the plans and communications were made between him, BRUNO and the UN, either through BRUNO's private New York cell phone or his New York office. DAL BOSCO also stated, in response to Ganov's questions about KEENAN's security, were the Dragon Family to learn of any possible involvement by KEENAN, that "they will not receive one cent so they will never know" and further that the DFFI "do not belong to the Dragon Family but to OITC." 103. During this trip, Ganov had also asked KEENAN if he thought DAL BOSCO

could assist him and his business associates, who were present with him, on another proj ect on which they were working in Italy. KEENAN responded that he thought DAL BOSCO might have the ability to help and arrangements and introductions were made.

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104.

Ultimately, not only did Ganbv become aware that DAL BOSCO had stolen the

DFFI, but he also learned that DAL BOSCO had tried to swindle Ganov on his other business deal on which DAL BOSCO purported to assist his group. KEENAN departed for Bulgaria on February 13,2010.

3.
105.

Recollections of Mr. Ognyan Marinov
A highly respected retired Intelligence officer from the Country of Bulgaria,

Marinov, corroborates much of the foregoing, as he was also in attendance at the February 2010 meeting with DAL BOSCO at the Hilton Airport Hotel in Zurich. DAL BOSCO had apparently been made aware of Marinov' s Intelligence background and approached him for a private conversation. Believing KEENAN and DAL BOSCO were close friends, Marinov acceded to the request. Marinov has stated that he shortly came to believe DAL BOSCO was engaged in a plot to steal the DFFI with which he had been entrusted.

4.
106.

Raykov Meeting with BRUNO and DAL BOSCO in Geneva in May 2010
Months later, while in Geneva on business with some of his associates, Raykov

called DAL BOSCO for a social visit. DAL BOSCO, upon answering the call, asked Raykov to meet him at the Balexert Mall in Switzerland and indicated that "he had to speak" with Raykov. Upon DAL BOSCO's arrival with his girlfriend, Alessia, Raykov asked DAL BOSCO what he wanted to speak about, and DAL BOSCO advised him to wait and he would see for himself. 107. Approximately 15 minutes later, a man came to the table at which Raykov and the

others were sitting, presented his business card, and introduced himself as Giancarlo BRUNO. DAL BOSCO asked Raykov for the card saying an exchange of business cards "was not necessary." BRUNO asked DAL BOSCO if Raykov "was assisting them yet." DAL BOSCO replied that he had asked Raykov to meet with BRUNO because he wanted BRUNO to speak 50

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directly to Raykov. BRUNO, speaking free'iy, told Raykov that KEENAN "was stupid for not taking the 100 MILLION US DOLLARS" and that "things had been in the planning stages for awhile and were about to be completed with or without KEENAN." BRUNO again asked Raykov if he would help convince KEENAN to take the money that was offered and Raykov responded that he could not and that KEENAN would not listen to him. BRUNO responded: "Not even for 500 Million US Dollars?" 108. Raykov continued to listen to BRUNO's description of the details of how the

DFFI were received and were planned to be placed into a financial program and that "no one would know anything." BRUNO said that "it would be silent" and after the completion of the program, the DFFI would be given back to the owners, who DAL BOSCO identified as OITC. BRUNO told Raykov "there would be no chance of trouble" and that the UN "provided them with immunity as well did OITC." 109. BRUNO then told Raykov that he would only speak with him, if Raykov "called

his New York office" as New York was "protected" from eavesdropping, unlike Geneva. BRUNO asked if Raykov "was in or out" and Raykov responded that "I would see." Raykov has not spoken with BRUNO since this conversation.

5.
110.

Marinov Meeting with BRUNO and DAL BOSCO in Geneva in May 2010
In late May 2010, Marinov met DAL BOSCO at the Intercontinental Hotel in

Geneva, who introduced him to a gentleman he identified as Giancarlo BRUNO from the World Economic Forum. Although Marinov extended his business card to BRUNO, DAL BOSCO discouraged such an exchange. It was the impression of Marinov that DAL BOSCO was deferential to BRUNO, whom Marinov considered being "highly intelligent" and who was clearly "running the show." BRUNO proceeded to explain how the Davos Program had 51

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achieved such success and seemed to

Marinov would be welcome at future meetings

at Davos. BRUNO proceeded to boast about various dignitaries with whom he had done business, such as former President Bill Clinton, Henry Kissinger and Alan Greenspan. 111. BRUNO then began to speak about "what they wanted to do with the Bonds or

Notes Mr. KEENAN was holding for the Dragon Family and who was involved." BRUNO specifically named RAGAGLINI, MlRACHIAN and BERLUSCONI, and the ITALIAN FINANCIAL POLICE and commented: "so you see there is no possible way we can have a problem. We can cloak ourselves with the immunity shield and everyone will go away. Just another day in the UN!" 112. Marinov asked BRUNO to explain what he was talking about and BRUNO

responded: "we want you to get KEENAN to give the bonds to us for 100 Million USD. We have better uses for the notes than KEENAN would ever dream of nor would he release them to us so readily. So we need your help." 113. DAL BOSCO then explained that he had approached others for help but that

KEENAN would not relinquish the bonds, although a "Sovereign Program" was all set up. It was evident to Marinov that his status as a Bulgarian Intelligence Officer might influence KEENAN's decision to cooperate in the scheme DAL BOSCO and BRUNO were openly discussing. 114. As Marinov grew increasingly uncomfortable with the volume of telephone calls

being made and received by BRUNO, after approximately 45 minutes, he was introduced by both BRUNO and DAL BOSCO to defendant MlRACHIAN, whom he found to be pleasant and intelligent. In response to questions posed to her by BRUNO, MlRACHIAN stated that: (i). "from the very top we were protected";

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(ii).

"there was no reason lor anyone, including KEENAN, to worry about any sort of repercussions";

(iii).

"the Italian cohorts in New York had even approved the matter with Secretary General BAN KI-moon 'but of course he will deny any such matter if questioned!'"

115.

Marinov had the clear understanding that what was being discussed was an

"Italian conspiracy to steal the Bonds with approval being granted by the Secretary General, BAN KI-moon himself." BRUNO proceeded to take the position that "this is not a very large undertaking ... in accordance to UN standards" and he then stated that the UN was "in the process of confiscating Trillions and Trillions of Dollars in assets within the next couple of months and no one could do anything about it." When Marinov inquired as to whether the money being confiscated belonged to the UN, BRUNO responded "of course not!" 116. Marinov was convinced that DAL BOSCO and BRUNO needed his help to try to

persuade KEENAN to cooperate with DAL BOSCO to accomplish what DAL BOSCO and BRUNO were proposing, especially in light of KEENAN's transfer of the DFFI to DAL BOSCO the previous September. DAL BOSCO indicated that he was considering taking the Bonds and using them for undisclosed purposes without KEENAN's permission but that he was reluctant to do so as KEENAN might ask for them to be produced and DAL BOSCO might "find himself in a bad spot." DAL BOSCO, however, went on to volunteer that there were "future plans" for the Bonds. This necessitated that KEENAN turn them over "so that no one could cause a ruckus claiming they were stolen from them." According to BRUNO, "not anyone could withstand such scrutiny" thus "they were trying to buy The Bank of Lugano in Switzerland to hide such things as stolen instruments." When Marinov asked who was buying the Bank, he was told "the 53

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ITALIAN FINANCIAL POLICE, BERLUSCONI and others" which would allow them to "trade the many instruments stolen over the years by the Italian Financial Police and trade them from the Swiss Bank and no one would be the wiser." It was apparent to Marinov that DAL BOSCO and BRUNO saw it most advantageous to their conspiracy to gain KEENAN's cooperation and participation "with the entire scheme already in motion," which KEENAN has steadfastly refused to do. 117. In conclusion, Marinov witnessed the dialing of aNew York City telephone

exchange and placement of a telephone call by DAL BOSCO and BRUNO to RAGAGLINI in New York. Marinov heard them ask "if everyone was ready to do the Bond deal" and he confirms that RAGAGLINI stated that "the Powers that be in New York had no problems with the actions about to be taken so long as some candy was tossed to them." Further, RAGAGLINI acknowledged that BAN KI-moon "was on board and approved the plan so everything was in place but KEENAN." RAGAGLINI concluded by asking Marinov "to rope KEENAN in because it was necessary for success." Although compensation for Marinov's services was discussed, no exact amount was ever mentioned. Marinov took no actions attempting to persuade KEENAN to cooperate with the aforesaid scheme, and KEENAN has continuously refused all overtures from the Defendants to participate in their illegal actions.

6.
118.

Berens' Telephone Call from DAL BOSCO in August 2010
KEENAN has known and conducted business with Berens for several years. He

is known to KEENAN to be highly respected and trustworthy. Berens was also present in February 2010 at the Hilton Zurich Airport Hotel for the business luncheon arranged by KEENAN. He was present when DAL BOSCO, whom he had met with KEENAN in the recent months prior thereto, placed a telephone call via speaker phone to BRUNO in New York. He 54

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heard DAL BOSCO asking KEENAN ifhe:wanted to do a "deal with the UN" which "involved MR. BRUNO, very high ranking friends of Mr. BRUNO's and DAL BOSCO in the UN." Berens heard DAL BOSCO tell KEENAN that they "could take the 100 Million Dollars as early as Friday that week." KEENAN rejected the offer. 119. Subsequently, in August 2010, Berens received a telephone call from DAL

BOSCO who asked him if he would make contact with KEENAN to "once again" offer the 100 Million USD that had been previously offered in February in Zurich. Berens responded that it was his understanding that KEENAN no longer held the Bonds and that DAL BOSCO "had run with them." DAL BOSCO replied that he did possess the Bonds and "would not give control of them until he knew he was safe." DAL BOSCO added that "if KEENAN took the money everything would be better" and stated that "he is a good Christian who might have made some very bad mistakes that could hurt a lot of people." DAL BOSCO mentioned he was even having trouble with his girlfriend because of the situation, including Internet reports of what he had done. He again stated that "if KEENAN would take the money it makes everything go away and everyone can go back to things the way they were." 120. Berens inquired as to the authenticity of the Bonds and DAL BOSCO stated:

"Believe me, the UN has checked them out and they are very real. I gave them one bond to check." Berens suggested to DAL BOSCO that he call KEENAN directly, to which he responded that KEENAN would prefer to "hang him not speak with him." DAL BOSCO again acknowledged his mistakes but that it was "impossible to take it all back seeing it had been done." Berens ultimately asked DAL BOSCO precisely what he wanted him to inquire of KEENAN so that he did not make any mistakes. DAL BOSCO responded that "100 Million USD would be given to KEENAN immediately upon giving the Bonds to Mr. Giancarlo 55

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BRUNO from the World Economic Forum who would then "take the Bonds and give them to BRUNO and DAL BOSCO's friends in the UNITED NATIONS to take into the Federal Sovereign Program for Trade," after which the bonds would be "given back to their rightful owners the Organization (sic) of International Treasury Control so everyone ended up happy." DAL BOSCO added that "taking part in this was Leo Zagami and the P2 Lodge in Rome." 121. Berens contacted KEENAN in September 2010 to inquire about the status of the

DAL BOSCO situation and asked about the bribe offer. KEENAN responded that "this was an attempt at theft and nothing more." KEENAN also confirmed what DAL BOSCO had previously told Berens, namely that the 100 Million USD would be split between KEENAN and DAL BOSCO which DAL BOSCO wanted to place in another trading program to generate capital and then enter into various programs and projects. KEENAN said that the Bonds were "not his to give or sell" and that the UN had acknowledged their authenticity and that Yamaguchi was well known as the comptroller/signature of the Dragon Family. KEENAN stated that the transaction he was working on was "to help countries not the UN, OITC, the WORLD ECONOMIC FORUM or BRUNO" and that "the returns would be greater for everyone involved and the Dragon Family would receive a great return for their humanitarian projects."

I.

The Continuing Duplicity and Ultimate Betrayal by DAL BOSCO March-June 2010
122. In or about March 2010, DAL BOSCO, in conversations with KEENAN, began to

intimate and suggest that he was continuing discussions within the UN about the negotiation of the Federal Reserve Notes, but erroneously noted that the Japanese Bonds and the Kennedy Bond were "government bonds" which could only be traded or negotiated between governments and that it was illegal for any individual to possess them or to attempt to trade them. KEENAN

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immediately rebuffed any suggestions that the Federal Reserve Notes be dealt with in any unlawful manner. 123. KEENAN subsequently learned that Zag ami had informed Fulford on or about

June 19,2010 that DAL BOSCO had gone into the Swiss mountains in the vicinity of Stein, Switzerland, with "some key members of the Swiss Illuminati" a year earlier to discuss, among other things, the destruction of the Papacy. Thereafter, KEENAN was concerned that DAL BOSCO might disappear on a whim. 124. In various conversations throughout April and May 2010, KEENAN reiterated to

DAL BOSCO that he was currently working on placing the Japanese Bonds only in a legally recognized PPP through Mr. Wales in Geneva, Switzerland, and had no active plans for the investment or placement of the Federal Reserve Notes or the Kennedy Bond. KEENAN kept DAL BOSCO abreast of his efforts regarding his working with his connections in China and Japan whereby the Bank of China would place 9.5 Billion Dollars as cash backing for the two (2) Japanese Bonds upon verification by the Bank of Japan. KEENAN considered DAL BOSCO to be more than a mere custodian of the DFFI, but a confidante and friend. However, KEENAN had also been sensing a change in DAL BOSCO's attitude and demeanor, such as increasingly frequent comments such as he "had to tell me something" but could never articulate what it was. KEENAN slowly sensed the DFFI were in jeopardy under DAL BOSCO's control. 125. At the same time KEENAN was working to achieve the placement of the

Japanese Bonds into a trading program, he was also attempting to place the Federal Reserve Notes into another program which would assist the United States and certain European countries. In connection therewith, on or about May 19,2010, KEENAN reminded DAL BOSCO that he

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would soon need the Japanese Bonds and that he might also have a deal for the Federal Reserve Notes. 126. While DAL BOSCO continued to mention the "offer" from the UN, KEENAN

reiterated that the purported proposal by the UN was not acceptable legally or ethically. He told DAL BOSCO to "forget it" and that he was only going to transact business lawfully through Mr. Wales. It was made clear that KEENAN and the Dragon Family had arranged for the DFFI to be used as collateral with the Bank of China, and that Wales had been requested to seek to invest the DFFI in a recognized PPP. 127. At all relevant times leading up to the month of June 2010, KEENAN would

advise DAL BOSCO whenever he needed the DFFI for presentation at a business meeting and at all times DAL BOSCO complied. However, beginning in or about May 2010, KEENAN observed that DAL BOSCO had consciously decided to change apartments in Rome as if to confuse KEENAN as to his whereabouts and, as it transpired, in order to avoid contact and ultimately to disappear. 128. In conversations in early June 2010, indicated clearly to DAL BOSCO

his hopes of coordinating a transaction involving three European countries and expressed his desire that DAL BOSCO participate in the venture. DAL BOSCO again reiterated the aforesaid offer from the UN to buy the FRNs for $100 Million USD, but KEENAN again rejected the notion and warned that the UN was acting unlawfully with respect to its planned disposition of the DFFI.

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129.

On or about June 8,2010, KEENAN advised DAL BOSCO directly that his

associate, Mr. Joseph Bendana (hereinafter "Bendana"), an American citizen, would be traveling to Geneva, Switzerland to retrieve the entire DFFI in order that they would be available for their intended purposes.

J.

The OITC Cease and Desist Order of June 8, 2010 (the "OITC Order")
130. Oddly, at or about the time that DAL BOSCO was advised by KEENAN that

Bendana would be flying to Geneva to retrieve the DFFI, or on or about June 8, 2010, the OITC "served electronically" a "Cease And Desist" Order (hereinafter, the "OITC Order") purportedly issued by "His Excellency, Dr. Ray C. Dam, International Treasury Controller 10-60847," representing, among other things, that DAM was appointed to that position under United Nations Charter Control No: 10-60847 and UN International Clearing Code: UNRCD-ID006197. The OITC order, among other things, stated that KEENAN, Yamaguchi and Watanabe "together with all associates, colleagues" were to "Cease and Desist" from "attempting to handle various Master Accounts and Assets of the Combined International Collateral Accounts of the Global Debt Facility, which incorporates the Dragon Funds, without any Official Authority or Approval whatsoever; which are legally owned under full Legal International Laws/International Treaty/ Convention Laws, as herein referred, by the aforementioned and referenced International Treasury Controller." (Emphasis added) 131. Further, the OITC Order, among other things, directed the individuals to

"Immediately Surrender All" certificates, assets, or otherwise held in their possession on or before July 7,2010. 132. On the day after the OITC Order was published, DAL BOSCO, feigning fear,

contacted KEENAN to advise that he had received a copy of the OITC Order by email and asked 59

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KEENAN how OITC had obtained his email address. In fact, DAL BOSCO had aided in the orchestration of the OITC Order and was neither in fear nor surprised by its issuance. He had inquired about OITC from KEENAN as early as January 2010 and was told OITC was a fraudulent organization. Further, DAL BOSCO had referred to OITC as the "owners" of the FRNs in his discussions with Vasil Ganov in February 2010 in Zurich (see with Nikolai Raykov in Geneva in May 2010 (see 102, supra) and

108, supra). KEENAN responded that he

had no idea and questioned how OITC even had his own email address. 133. At various other times DAL BOSCO advised KEENAN and others that he was

not returning the DFFI, but rather had placed the DFFI in the possession of his attorney (unidentified) until the situation had been clarified in order to take the time necessary to "decide what to do with them." Further, on June 22,2010, in a conversation with Fulford, DAL BOSCO affirmatively stated that he was alternatively "working with the Police and the UN" as well as "with Interpol." Fulford asked for the name ofDAL BOSCO's attorney or the names of the Interpol person with whom he was in contact so that Fulford could "get the Japanese security police to contact them on behalf of the Japanese government." DAL BOSCO responded that he . . should "contact OITC @ intl.finance@unoitc.org and explain what they want to do." 134. DAL BOSCO also advised KEENAN that he was communicating with

representatives from Interpol, but again refused to provide details of names or contact numbers. Ultimately, he told KEENAN: "Buddy, the Bonds do not belong to the Dragon Family. They belong to OITC." 135. On June 9, 2010, KEENAN notified the OITC bye-mail that he was in receipt of

the OITC Order and asked three questions, as follows:

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1.

What is your role or responsibility, or involvement in the bonds? Please be more descriptive. Who is the party or persons that have provided you with our names? What gives you the authority to issue such a Cease and Desist" document (PDF files?).

2.

3.

136.

KEENAN further demanded detailed responses within 24 hours together with a

reservation of rights regarding future civil or criminal actions. 137. On or about June 9, 2010, DAL BOSCO contacted KEENAN and expressed his

own personal fear and his inability to make a decision regarding the DFFI. KEENAN assured DAL BOSCO that he had done nothing wrong, that the OITC was a fraudulent entity and that, despite its outward representations, enjoyed no protection, sanction, affiliation or approval from either the UN, the Federal Reserve Board, or the BIS, and that any licensing it might once have enjoyed had been nullified several years prior. 138. KEENAN told DAL BOSCO to ignore the OITC Order pointing out that DAL

BOSCO was not even named in the document. KEENAN did inquire of DAL BOSCO how the OITC obtained his email address and DAL BOSCO denied my knowledge, although KEENAN was aware that DAL BOSCO had prior communications with OITC. 139. On June 10, 2010, OITC sent a letter via email toKEENANwherein.interalia.it

"strongly advised" KEENAN not to ignore the OITC Order and to review "our Website (www.unoitc.org) and in particular the Video Presentation ... " and further "adhere to the content ofC&D Notice IOrder ... and comprehend what you are actually involved in." Additionally, purporting to answer the questions put forth by KEENAN in his letter, OITC stated, in part, that "The Bonds are issued against the Dragon Funds, whereby the Bonds are collateralized by the 61

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Dragon Funds. The Dragon Funds are part of the Combined International Collateral Accounts of the Global Debt Facility of which H.E. Dr. R. C. Dam (of Royal family origin) is the Legal Heir, Owner, Sole Arbiter as appointed by the Nations of the World (January 20, 1995) to replace the Trilateral Trillenium Tripartite Gold Commission established January 1945 with a Fifty (50) year term, expiring in 1995." 140. The OITC also responded to KEENAN's letter by stating, in response to the

question as to who had provided OITC with the names in the OITC Order, that "This is privileged information and cannot be disclosed." As to the third question posed by KEENAN as to what gave the OITC the authority to issue its Order, OITC responded: Our ownership of the Dragon Funds, being part of the Combined International Collateral Accounts of the Global Debt Facility, and our international status combined with our International Authority as granted, attested to, and formally issued by the Nations of the World. The OITC letter concluded with a warning that the "impertinent mannerisms" in which KEENAN had allegedly "approached this matter" would not be tolerated as it shows "an
insulting and arrogant attitude towards a Sovereign Entity which is legally chartered under the United Nations and recognized by all Nations . . :" (Emphasis added) and was

signed: Yours faithfully, D.A. Sale, F. LLA. Special Global Envoy, Senior Commercial Advisor to H.E. The Chairman The Office of International Treasury Control, UN Charter Control No: 10-60847 141. On June 14,2010, KEENAN responded with a letter addressed to Mr. Dam, sent

via email in which he disputed that the BIS, UN or Federal Reserve recognized OITC, but urged

Mr. Dam "to request Mr. Yamaguchi to work directly with you," noting that "if you can possibly 62

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assist him with his bonds then I can provide "the TRADER for you. Then there will be money for humanitarian causes in our hands." 142. SALE responded the same day opening with the greeting that "Again your

arrogance and total lack of knowledge shows within the content of your communication." After disputing that either Yamaguchi, as Controller, or the Dragon Family itself are the "Legal Owners" of the missing DFFI, SALE advised that the OITC Order "stands and is enforceable in full" and that "appropriate action" would be undertaken in due course for failure to comply. SALE also NOTED that "H.E. Dr. Dam does not respond to communications directly from people, as he is far to [sic] busy on more important issues attending to Royal Families. Neither does H.E. Dam attend meetings with, nor have appointments with anyone other than Royal Family members." 143. On June 17,2010, OITC sent KEENAN an email advising that, inter alia, (1)

since Monday, June 14, 2010, it had received several communications from a Swiss Law Finn (unidentified) "relative to one of their clients"; (2) that Swiss Law Firm was "now in possession of various Bonds and Certificates passed to their client by you"; (3) it had advised said Law Finn "to ensure" that such instruments "are held totally secure at all times until they are able to verify our status"; (4) it had "dispatched" to said Firm "details regarding the protocols that they must apply, together with the relevant information reference to where and to whom they should apply for verification of the OITC/H.E. Dr. Dam"; (5) it had made arrangements for the Swiss Intelligence Services to visit the Law Firm "to ensure that the Law Firm is fully aware of what they are handling and the seriousness of same"; (6) it had received from the Law Finn that morning copies of threatening letters from "a Japanese person" and KEENAN and which it would report to the Intelligence Services and Police; (7) that, as of that morning, H.E. Dr. R.C.
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Dam had "agreed to cover the Law Firm., its '.Partners and employees, and the specific client under International Security Clearance Level 3-5 and the Vienna Convention, whereby any untoward act or actions ... will now be handled accordingly ... " and otherwise threatened to issue a Warrant of Arrest which would be "enforceable internationally." The letter ended: It is therefore in your own interest, and that of your colleagues, associates or otherwise, not to under-estimate the Status and Power ofR.E. Dr. Dam or the OITC. Faithfully, D .A. Sale, F. LLA. Deputy Chief of the Council for the Cabinet, Special Global Envoy, Senior Commercial Advisor to R.E. The Chairman The Office of International Treasury Control, UN Charter Control No: 10-60847 144. KEENAN responded immediately, advising OITC, inter alia, that it was an

"ongoing publicity seeker and not much more" with "no standing in any court or organization and not a protected entity." 145. On June 20, 2010, KEENAN sent another email to DAL BOSCO advising that

"Apparently your attorney has made contact with OITC but still to this date your lawyer has not made contact with our attorneys. Seeing it is the Dragon Family bonds that you have absconded with, you have not given me to give to my attorneys any contact numbers for your attorney to date which in itself is illegal. I see OITC has it and as previously mentioned you and your attorneys are responsible for anything happening to those bonds outside a court of law. Your attorney is speaking with OITC but not the owners of the bonds. This is very interesting and illegal. Please forward attorney contact numbers immediately." 146. Within hours, KEENAN received a response from OITC, through DAL BOSCO,

by which OITC advised DAL BOSCO: 64

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Dear Daniele, Take no notice and do not reply, because that will only provoke him. Kindest regards, D.A. Sale, F. LLA. Special Global Envoy, Senior Commercial Advisor to H.E. The Chairman The Office of International Treasury Control, UN Charter Control No: 10-60847 No response has ever been received by KEENAN from any person purporting to act as an attorney for DAL BOSCO.

K.

Attempted Retrieval of the DFFI by Joseph Bendana
147. Bendana had previously worked with KEENAN on PPPs initiated by the Dragon

Family. For instance, on or about September 23,2008 Yamaguchi, "as the legal holder of the 10 Kennedy Bonds and the 415 metric Tons of AU (gold)" had executed an Authorization Letter in favor of Bendana whereby Bendana was authorized "to oversee all'operations involved with the Private Placement Program for both the bonds and the AU and you are to insulate at all times the members of the Dragon Family by handling all issues that arise with Mr. Neil Keenan, project coordinator ... to make sure that the programs are ready for us to enter upon authentication of the bonds or AU certificates ... " 148. On or about June 14,2010, Bendana received a telephone call from DAL BOSCO

and after discussing with him his authorizations, made specific arrangements to meet with DAL BOSCO in Geneva to retrieve the DFFI. 149. On or about June 15,2010, Bendana flew to Geneva for the sole purpose of

retrieving the DFFI, including the Federal Reserve Notes and the Kennedy Bond, so that he could arrange their return to KEENAN. On or about June 17,2010, Yamaguchi executed a 65

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Power of Attorney in favor of Bendana "to

the bonds/notes from the hands of Mr.

Daniele Dal Bosco or from the legal safekeeping vault where Mr. Daniele Dal Bosco deposited them," such written instrument also expressing the hope that Mr. DAL BOSCO would place them in Mr. Bendana's hands "as he received them from Mr. Keenan." The instrument also directed Mr. Bendana to make preparations to move the DFFI in accordance with KEENAN's instructions after KEENAN has confirmed that the DFFI retrieved by Bendana are the same as those turned over to DAL BOSCO. 150. Ultimately, DAL BOSCO neither contacted nor met with Bendana at the

appointed time and location. Bendana did meet with Wales briefly at the Intercontinental Hotel, and Wales also attempted to contact DAL BOSCO. Upon information and belief, Wales did have conversations with DAL BOSCO in which he suggested that DAL BOSCO return the DFFI to KEENAN and even provided a draft format of a safekeeping receipt for use by DAL BOSCO's attorney to send to KEENAN. Wales' attempts to assist KEENAN were rebuffed causing him to inform Bendana that DAL BOSCO would not be returning the Federal Reserve Notes and Kennedy Bond, which comprised part of the DFFI,.to him. After spending three days in Geneva, Bendana left empty handed for Bulgaria where he saw KEENAN while harboring hopes that DAL BOSCO would change his mind and Bendana could fulfill his assignment. This did not occur and Bendana ultimately returned to the United States on July 4, 2010. It was not until a few days after Bendana home that DAL BOSCO called him to state that he might

reconsider returning the DFFI and to "wait a little longer." 151. During his trip, Bendana had dinner with KEENAN at Ganov's house in Bulgaria.

Bendana expressed his regret that he had divulged his itinerary to DAL BOSCO and that he was sure DAL BOSCO was planning to steal the DFFI. Bendana also said that by revealing his 66

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itinerary, DAL BOSCO might have been pressured to take action with the DFFI more quickly than he might originally have planned. 152. Eventually, DAL BOSCO himself told KEENAN that he would never return the

DFFI and that he "should get on with his life." DAL BOSCO's actions caused substantial economic harm to KEENAN as the European group KEENAN had been dealing with had made all the necessary financial arrangements in order to invest Fourteen Billion Dollars ($14,000,000,000.00) in the form of a cashier's check in return for the use of the FRNs which, as described, comprised a portion of the DFFI as well as a 50% participation in a PPP. 153. At various and continuing times from June 2010 through the present, DAL

BOSCO and OITC have threatened, harassed and attempted to intimidate KEENAN by stating, among other things, that the DFFI should be placed with the OITC andlor the Italian Government and has at all times refused to relinquish control of or return the DFFI to KEENAN, Yamaguchi or the Dragon Family.

L.

Affirmative Actions Taken by KEENAN and/or his Principal to Retrieve the DFFI
154. Since the time it became clear that DAL BOSCO had utterly breached any and all

fiduciary and legal obligations he owed to KEENAN under his agreement to act as temporary safe keeper and custodian of the DFFI, KEENAN has spared no effort to try to either reason with or persuade DAL BOSCO, and those with whom he has elected to conspire to steal and convert the DFFI for their own selfish and illegal purposes, to return the DFFI. These efforts have been entirely futile and DAL BOSCO, and those with whom he has conspired, has at all times refused to relinquish control of or return the DFFI to KEENAN, Yamaguchi or the Dragon Family.
I

155.

Among the actions taken or participated in by KEENAN to enforce his rights and

to repudiate DAL BOSCO's actions, have been the following:

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i. The service of his own Cease and Desist Order upon DAL BOSCO on or about June 20, 2010, demanding the return of the DFFI, citing DAL BOSCO's broken trust and attempts to sell the DFFI to the UNITED NATIONS and the ITALIAN REPUBLIC or agencies thereof; his failure to turn the DFFI over to Bendana as had been arranged; DAL BOSCO's collaboration with OITC and participation in attempting to bribe KEENAN with the assistance of the UNITED NATIONS and its high ranking representatives, BRUNO, the WEF and/or WEF USA and others; DAL BOSCO's failure to advise of the identity of the "attorney" with whom he had allegedly deposited the DFFI, or the identity of the "police" with whom he had allegedly conferred about the DFFI ii. The issuance of another Cease and Desist Order upon DAL BOSCO by Yamaguchi on or about June 22, 1010, as well as his filing of a Criminal Complaint on or about June 24, 2010 with the Governments of France and Switzerland in their respective Ambassadors' offices in Tokyo. The Complaint noted DAL BOSCO's illegal possession of the DFFI, with an estimated value of 989 Billion USD for the past 3 weeks, as well as DAL BOSCO's expressed threats to transfer their possession to OITC. The filing of another Criminal Complaint on or about July 2,2010, by Yamaguchi against DAL BOSCO with the Italian Embassy in Tokyo c/o Ambassador Vincenzo Petrone, charging DAL BOSCO with, inter alia, "grand theft, fraud, conspiracy, grand larceny, and conspiring acts of bodily harm against the papacy, [and] violence directed toward the Vatican ... "; the Complaint charged that DAL BOSCO had been colluding with some members of the Italian Government in attempting to "extort extreme amounts of money from the Dragon Family." Yamaguchi urged that the DFFI be returned from DAL BOSCO and his lawyer through Mr. Keenan as soon as possible. He further requested the Italian Authorities to detain DAL BOSCO if he entered their jurisdiction and to launch a full investigation of said charges.
111.

iv. The filing of yet another Criminal Complaint by Yamaguchi with the Metropolitan Police Department in Tokyo on or about July 8, 2010 , alleging "the robbery damage" ofDAL BOSCO by virtue of his stealing the DFFI in Geneva from KEENAN, to whom Yamaguchi had entrusted the DFFI in January and May 2009. v. The submission on or about July 21,2010 ofa sworn statement by Bendana to Interpol advising of his written authorization in June 2010 "to retrieve over a trillion dollars worth of bonds" from DAL BOSCO in Geneva, Switzerland and which were then in the possession of DAL BOSCO for safe keeping only. Bendana also referenced his 68

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exchange of contact information with DAL BOSCO prior to his trip to Geneva. vi. The issuance by Wales on or about July 26, 2010, of his own "Cease and Desist Order Effective Immediately" against DAL BOSCO, based upon DAL BOSCO's misappropriation of the DFFI, which he knew were under the legal control of KEENAN, and DAL BOSCO's subsequent "slanderous and malicious attack" upon Wales' person or character. vii. On or about July 27, 2010, KEENAN submitted a package of information to Interpol Headquarters in Lyon, France "revealing the theft of approximately 1 Trillion USD in Financial Instruments by Italian Daniele Dal Bosco ... " Among other things, KEENAN advised Interpol that his enclosed package contained documentary evidence to support his claims against the actions taken by DAL BOSCO relating to the theft and (a) DAL BOSCO's refusal to return the Instruments "back to their rightful owners/custodians," (b) DAL BOSCO's attempted sale of the DFFI to the UNITED NATIONS "which offered him 100 Million USD for them" (c); DAL BOSCO's steadfast refusal to provide contact information for the individuals, including his lawyer, or law enforcement agencies, including Interpol itself, with whom he had allegedly conferred about depositing the DFFI; and (d) the closing by DAL BOSCO of his London office, his change of email address, and moving from his apartment. Included in the package was (e) an affidavit from Mr. Somberg in which Somberg described his understanding of the relationship between KEENAN and DAL BOSCO based upon the several conversations he had with DAL BOSCO while travelling with him in Switzerland, Germany and Austria during the September 2009 time period (see supra). Somberg related his own observation that DAL BOSCO; during this period, "was very close by Mr. Keenan and was clearly the caretaker of the financial instruments that Mr. Keenan was authorized to use by the Dragon Family and their comptroller/signatore Mr. Yamaguchi." Somberg understood that KEENAN "was attempting to work an international transaction involving various governments to help them in their time of crisis." Somberg also quoted the response ofDAL BOSCO, whom he had deemed at that point to be "a very sound and practical person" when queried by him as to why he was then custodian of the D FFI: Neil has to travel across borders and it is illegal to carry the bonds across said borders and if he gets stopped he will have an international scandal and this is what we are trying to avoid. I am a trusted financier not only in Switzerland but in France and Italy as well. I am the custodian of many 69

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bonds and instruments so Neil's instruments that he represents are in good hands. Nothing will happen to them. v1n. On or about July 29,2010, KEENAN sent a letter to His Eminence Vatican Secretary of State Cardinal Bertone, whom he had met previously at a Celebration for the Dominican Republic and President Belaguer in October 1992. He noted his regret to have to advise the Cardinal that Italian Citizen DAL BOSCO, who had represented that he was a resident of Vatican City, as well as Divonne-Ies-Bain, France, and was the Financial Advisor to the Vatican and Treasurer of the Masons, had "absconded with approximately 1 Trillion USD and Japanese Bonds in June 2010 that were entrusted to me." KEENAN noted that DAL BOSCO "was a very nice young man who presented himself properly at all times and of course I believed him." KEENAN also advised Cardinal Bertone that DAL BOSCO had told him he had been working with the Vatican through its financial programs, or Platforms, and had been hopeful of placing the DFFI into such a program. Despite DAL BOSCO's stated intentions of working with the Vatican, KEENAN also felt obliged to report to Cardinal Bertone that he had received information (while expressing reservations about its accuracy) to the effect that DAL BOSCO had been involved with others in discussions concerning a plot to destroy the Papacy ix. In a letter dated July 31, 2010, which enclosed a package of pertinent information, sent via certified mail return receipt requested by Mr. Bendana from his residence in New Jersey, KEENAN advised BAN KI-moon that DAL BOSCO, "an Italian citizen, passport number C165124 absconded with 1 Trillion Dollars in BondslNotes which had been entrusted to me yet belonged to the Dragon Family." He further stated that the "sole reason" he was writing was that "it is the UNITED NATIONS itself that set DAL BOSCO off on his quest to either Sell the Bonds or place them in a Private Program." KEENAN further advised that "You have individuals inside the UN in Geneva who know Mr. Dal Bosco and who offered him One Hundred Million USD for them." Further, DAL BOSCO's "UN friends advised him that Mr. Yamaguchi was a very powerful member of the Dragon Family whose titles are indeed Signature (sic)/Comptroller but that they at no cost wanted Mr. Yamaguchi involved in this transaction. He was not even to receive one cent for the Dragon Family." KEENAN also referenced DAL BOSCO's illicit connections with OITC and SALE and the use of the UN "as a cover for their illegal dealings" as well as the danger posed to the United States by the UN's condoning such activities through the promises of "security and secrecy" and called for a serious reprimand of any people within the UN for their participation in the plot to steal the DFFI. While KEENAN never received a direct response to his letter to BAN KI-Moon, upon 70

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information and belief, Mr. Bendana spoke on at least two occasions with him during the course of which BAN KI - moon stated, among other things, that "this goes much higher than me." Mr. Bendana relayed this information to KEENAN and added: "I cannot wait to see you buddy; wait until you hear the information I have." He also repeated this to his brother-in-law who was present during the conversation. Mr. Bendana, who received the return receipt requested from the UN on September 2, 2010, was found dead in his apartment in New Jersey on the morning of September 4, 2010, two days before he was to depart to visit with KEENAN and provide him with all the information he had received from his conversations with BAN KI-moon and days after he had received a telephone call from DAL BOSCO threatening his physical safety if he continued pursuing legal claims on behalf of KEENAN. x. On August 30, 2010, KEENAN sent a personal letter to BRUNO, certified mail, addressed to WEF headquarters in Switzerland, by which he reminded BRUNO that he, KEENAN, was the person who had entrusted the DFFI to DAL BOSCO, who had informed him, inter alia, that (a) BRUNO had offered 100 Million USD as a cash payment with no questions asked; (b) a Stipulation of such payment was that Mr. Yamaguchi was never to receive anything for the bonds and that all or a portion of the bonds would have been placed into a FED investment program handled by you and your organization (World Economic Forum); (c) five (5) International Complaints were currently filed against DAL BOSCO and one with Interpol; (d) he was filing a civil complaint in the federal district court in Manhattan in which BRUNO and WEF would be named; (e) DAL BOSCO was reportedly claiming that the DFFI were in a Federal Trading program and in safe hands in the UN, which was what DAL BOSCO had claimed BRUNO had proposed more than two months prior thereto. To date, KEENAN has not received a response to his August 30, 2010 letter from either BRUNO or WEF.

M.

Recent Revelations Concerning the DAL BOSCO! OITC Enterprise
156. On or about November 9, 2010, KEENAN received a written communication

from Keith F. Scott, formerly associated with the OITC as Chief of Cabinet of OITC, Special Envoy and Executor for His Excellency Dr. Ray C. Dam and later, Chief of Council of the Cabinet. Scott directly contradicted the June 2010 communications from SALE, and stated

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clearly that the DFFI are the rightful propertY of the Dragon Family who are legally entitled to same. 157. Scott also informed KEENAN that in late September or early October 2010, he

had become aware of one of Fulford's internet blogs regarding "the theft of a series of Historical Bonds that with their accrued value with interest coupons was worth approximately One Trillion United States Dollars" and that such bonds "had been stolen from one Neil Keenan." 158. According to Scott, he informed DAM about two weeks later and witnessed

DAM's reaction in anger as DAM explained to Scott that he had been aware that SALE had access to the Bonds and had sent him scanned copies which DAM proceeded to showed to Scott. DAM advised Scott that he had determined that the Bonds were authentic based upon his experience and review of records which he had historically kept in his what he referred to as a "Book of Codes," which, upon information and belief, purports to be a detailed listing of all records and true owners of the International Combined Accounts, further blocked to the "IPRA" or International Parent Registration Accounts. 159. According to Scott, the Dragon Family, through various secret arrangements, hold

vast assets which he has substantiated to KEENAN by presenting "copies of official top secret bank documents that confirm the amount of gold delivered by the Dragon Family." Scott is clear and emphatic in stating that any alienation of the Bonds from the Dragon Family or their appointed Agents is illegal. Scott maintains that the Dragon Family are the known Depositors of gold as well as other bullions and other assets in private bank accounts held in Swiss Banks, and that the DFFI were in fact obligations of the Federal Reserve System against the assets blocked to the Federal Reserve System Accounts. Scott explained that these assets deposited in the Dragon Family owned accounts were part of the aforementioned "IPRA." 72

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160.

In recent postings available to the world at large via the Internet, SALE has

admitted that it is "verifiable" through OITC's own records that the "first ever written communication from Mr. Dal Bosco was within the first week of February 2010, in fact 2nd February 2010." Further SALE has published "a few relevant sections of the Agreement dated March 2010" between DAL BOSCO and OITC "duly executed by DAM." It has thus been admitted to a global audience by SALE, confirming KEENAN's worst suspicions, that DAL BOSCO had contacted OITC no later than February 2010, and entered into a written contract with OITC no later than March 2010, regarding the disposition of the DFFI with which he had been entrusted by KEENAN in September 2009. This further corroborates the conversations that DAL BOSCO had with Vasil Ganov in February 2010 in Zurich when trying to persuade Ganov to influence KEENAN to accept the $100 Million USD bribe and when DAL BOSCO alluded to OITC as the "owners" of the Notes which would be returned to OITC after having been placed in a UN "Sovereign Program." It also corroborates DAL BOSCO's discussions with Nikolai Raykov in May 2010 in Geneva (See 161. 98-104; 106-117, supra).

Further, it has become evident that during the period in the very months after

KEENAN had entrusted DAL BOSCO with the DFFI, namely early 2010, DAL BOSCO, in total dereliction of his fiduciary duties, was, in fact, embarking simultaneously upon staggering schemes to steal and convert the DFFI through his illiCit actions, including bribery, not only with BRUNO, THE WORLD ECONOMIC FORUM, the UNITED NATIONS, BAN KI-moon, RAGAGLINI, MIRACHIAN, BERLUSCONI, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and others but also with OITC, SALE and DAM. These schemes were plotted_solely for the purpose of aggrandizing the various Defendants' personal wealth at the expense of the rightful Legal Holders of the DFFI and their designated agent KEENAN. 73

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N.

Recent Revelations Concerning DAL BOSCO, BRUNO, ITALIAN REPUBLIC, ITALIAN FINANCIAL POLICE, BERLUSCONI Enterprise
162. In or about mid-December 2010, it was learned by KEENAN that, beginning in or

about September 2008, Brazilian financier, Carlo Alfredo Nascimento da Silva, with the assistance of his attorney, Rubens Mariani, was planning to purchase Banca Commerciale Lugano, Lugano CH (Switzerland) ("Banca Cornmerciale"). Upon information and belief, this plan came to be aided and abetted by DAL BOSCO, BERLUSCONI and BRUNO, as well as retired Colonel of the ITALIAN FINANCIAL POLICE, Mauricio Fanelli, Italian attorney, Pierre Luigi Manzione, and others. Further, upon information and belief, the plan included the deposit of stolen bonds and notes into Banca Commerciale or any other Swiss bank to establish credit lines and to enter into trading programs. The stolen assets which were to be deposited included not only all the DF Chiasso Instruments seized in June 2009, and still held by THE ITALIAN FINANCIAL POLICE, but also the DFFI stolen by DAL BOSCO in June 2010, and continuously held under his custody or control. This information further confirms the recollection of Ognyan Marinov's discussion with DAL BOSCO and BRUNO in Geneva in May 2010 (See Paragraph, supra).

o.

Deed of Authorization and Agreement from Dr. Edy Soekanto
163. In November 2011, KEENAN was issued a deed of Authorization and Agreement

(the "Agreement") from Dr. Seno Edy Soekanto, who has sworn to be the "legal heir of record as stated in the last will and testament of the late President Soekamo of Indonesia and heir son of the late Kiyai Hadji Djawahir, as well as the legal holder of the Family Heritance Guarantee, as attached to all the gold deposits as ordered by President Soekamo between 1948 and 1968 when

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he was granted such Heritance Guarantee as C'payment for his services to the World." See 2(iii)(c). 164. Dr. Soekanto swears that President Soekarno had designated to him the

responsibility to collect all those funds known as the Family Heritance Guarantee and the accumulated interest thereon and that he has "been acknowledged by depository bank, as evidenced by the bank instruments, books, record and ledgers and codes in his possession, as the sole recognized heir to" the aforesaid fortune. Further, under such Agreement, on account of his "severe and long term chronic illness," he granted to KEENAN the authority to act as one of his Attorneys in Fact "to act jointly and/or severably and to undertake all means and methods to recover the funds owing to me and the People of Indonesia." 165. Dr. Soekanto has further agreed and has confirmed that he holds the "full secret

Book of Codes (Maklumat Book) and Ledgers and all Records of the Accounts as delivered" to him and that, upon their request, he will "deliver or cause delivery of the originals of such books for presentment to any court determined to have such jurisdiction" and "for any other purpose" KEENAN may require or need the Books. KEENAN and others under his direction are presently in custody of certified copies of said Book of Codes (Maklumat Book) and Ledgers with the authorizations to use them when needed. 166. These Books and Ledgers define the information that is held in the Federal

Reserve screen system. They contain the secret code cyphers and data on legal decisions, treaties and other arrangements. Upon information and belief, they provide information pertaining to all the accounts and sub-accounts that contain the gold and other assets, as well as information pertaining to the financial instruments issued against the gold. Further, they specify and provide the factual information as to what is in the Global Accounts, such as who owns the 75

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gold and the source of its ownership. The protection and security of these Books is, therefore, of the utmost importance and central to the authentication and verification process.

AS AND FOR A FIRST CAUSE OF ACTION AGAINST DEFENDANT DAL BOSCO [Expropriation and under Federal Common Law and International Law]
167. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 166 of the Complaint with the same force and effect as though fully set forth herein. 168. Pursuant to a certain Special Power of Attorney executed by Yamaguchi on behalf

of the Dragon Family, and with the approval of General Haan, the Head of the Dragon Family, which authorized Plaintiff KEENAN to act on behalf of Yamaguchi and the Dragon Family for the private placement of or legal return of the DFFI, KEENAN lawfully possessed the DFFI. 169. KEENAN released custodianship of the DFFI to defendant DAL BOSCO

pursuant to his written ACCEPTANCE of September 9, 2009, whereby DAL BOSCO would retain custody of the DFFI for safekeeping while KEENAN travelled throughout Europe in his effort to invest the DFFI in recognized PPPs. DAL BOSCO agreed to only return custody of the DFFI over to KEENAN or Yamaguchi and "Not any other!" 170. DAL BOSCO proceeded to engage in a course of conduct totally contrary to his

oral and written agreement. Such actions were taken intentionally and without authority by DAL BOSCO, who at all relevant times engaged in the unauthorized assumption and exercise of right of ownership of the DFFI, thus interfering with KEENAN's right of possession. Such unauthorized assumption of control is evidenced, in part, by DAL BOSCO's following and unauthorized activities, alone and in conspiracy with others:

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(1) Exercised dominion cind control over the DFFI totally outside of and beyond the scope of his acknowledged duties, and remains in custody and control of the DFFI, despite repeated demands for their return; (2) Further exercised his dominion and control over the DFFI by entering into a written agreement with defendant OITC for the purpose of proclaiming the DFFI as the lawful property ofOITC, rather than KEENAN, and subsequently conspiring with OITC to issue a fraudulent Cease & Desist Order proclaiming such ownership; (3) Entered into an agreement with defendants BRUNO, the WEF and/or WEF USA, UNITED NATIONS, BAN KI-moon, the ITALIAN REPUBLIC, RAGAGLINI and MlRACHIAN whereby a bribe of $100 million USD would be offered to KEENAN for the release of the DFFI to BRUNO for the ultimate investment of the DFFI in a "Sovereign Program" under the control of defendant the UNITED NATIONS, at all times under the claimed umbrella of protection afforded by the "sovereign immunity" accorded the UN; (4) Entered into an illicit agreement with defendants the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BERLUSCONI, WEF, WEF USA, BRUNO and others whereby said defendants plotted to utilize the stolen the DFFI, which in combination with other various stolen or seized assets, would be placed into international commerce through the purchase of a Swiss Bank, Banco Commerciale di Lugano, or another Swiss bank for future credit and trading purposes. 171. After rejecting numerous improper offers and bribes made by DAL BOSCO, as

detailed supra, KEENAN demanded orally and in writing on multiple occasions that DAL BOSCO return the DFFI to KEENAN's possession. 172. Despite these demands, DAL BOSCO unlawfully withheld possession of the

DFFI from KEENAN and the Dragon Family in violation of their legal rights to the same. 173. KEENAN has suffered serious financial detriment·on account of the conversion

of the DFFI by DAL BOSCO and, at a minimum, DAL BOSCO is required to pay the full value of the DFFI and all of its accumulated interest, with interest. DAL BOSCO is also required to

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pay KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 174. Consequently, KEENAN has been damaged by the conversion of the DFFI by

defendant DAL BOSCO and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars. AS AND FOR A SECOND CAUSE OF ACTION AGAINST DEFENDANTS DAL BOSCO, BERLUSCONI, RAGAGLINI, MIRACHIAN, ITALIAN FINANCIAL POLICE, ITALIAN REPUBLIC, BAN KI-moon, UNITED NATIONS, BRUNO, WEF and WEF USA, [Civil Conspiracy to Expropriate and Convert the DFFI under Federal Common Law and International Law] 175. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 174 of the Complaint with the same force and effect as though fully set forth herein. 176. Upon information and belief, defendants DAL BOSCO, BERLUSCONI, the

ITALIAN FINANCIAL POLICE, and the ITALIAN REPUBLIC entered into an agreement whereby each party knowingly and voluntarily agreed to participate in a scheme to steal and convert certain financial instruments for the purpose of profiting from this theft of financial instruments, including the DFFI. Among the prospective unlawful uses planned for the DFFI by said defendants was the purchase of a Swiss Bank, such as Banco Commerciale di Lugano, or any other Swiss Bank into which they could immediately move all stolen assets, including the DFFI. 177. Upon information and belief, defendants BRUNO and the WORLD ECONOMIC

FORUM and/or the WORLD ECONOMIC FORUM USA, INC. knowingly and voluntarily agreed to participate in this scheme to convert various financial instruments, including the DFFI. 78

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Defendants BRUNO and the WEF and/or WEF USA further knowingly and voluntarily agreed to utilize their connections within the defendant UNITED NATIONS to set up Sovereign Programs for the investment of the unlawfully obtained financial instruments that they knew to be either stolen or seized under color of police authority of the ITALIAN FINANCIAL POLICE or unlawfully obtained by others, and which included the DFFI, to the profit of all the coconspirators. 178. Upon information and belief, BRUNO, acting within his authority as the Director

responsible for the Financial Services Industry Group of the defendant WEF and/or WEF USA in its New York City offices, and defendants BERLUSCONI, H.E. Ambassador CESARE MARIA RAGAGLINI, Permanent Representative of the Italian Mission to the UN in New York, H.E. Ambassador LAURA MlRACHIAN, Permanent Representative of the Italian Mission to the UN in Geneva, defendant BAN KI-moon, Secretary-General of the United Nations, and other unknown representatives of defendants the ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE and the UNITED NATIONS procured an agreement entered into knowingly and voluntarily by the foregoing defendants whereby the unlawfully obtained financial instruments that said defendants knew to be either stolen or seized under color of police authority of the ITALIAN FINANCIAL POLICE or unlawfully obtained by others, and which included the DFFI, would be invested in a " Sovereign Program" wholly under the auspices, protection and umbrella of the "sovereign immunity" allegedly accorded to the UNITED NATIONS and the ITALIAN REPUBLIC. 179. Upon information and belief, in furtherance of the aforesaid civil conspiracy,

defendants the ITALIAN FINANCIAL POLICE and the ITALIAN REPUBLIC intentionally participated in the furtherance of the plan by seizing the DF Chiasso Instruments in an amount 79

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approximating $134.5 Billion U.S. Dollars from Dragon Family representatives Yamaguchi and Watanabe. This seizure of the DF Chiasso Instruments, which incident was described in detail

supra, was then utilized by the defendant co-conspirators as a pretext for introducing DAL
BOSCO to KEENAN for the purpose of convincing KEENAN that it would be wise to entrust custody of the DFFI to DAL BOSCO in order to avoid a similar incident from occurring with respect to the D FFI. 180. Further upon information and belief, in furtherance of the aforesaid civil

conspiracy, defendant DAL BOSCO intentionally participated in the furtherance of the plan by making knowingly false material representations to KEENAN for the purposes of inducing KEENAN to relinquish custody of the DFFI into DAL BOSCO's possession, orchestrating and participating in the numerous attempts to bribe KEENAN in an effort to induce KEENAN to participate in the theft of the DFFI from the Dragon Family as detailed supra, and ultimately absconding with the DFFI when the attempts to bribe KEENAN were unsuccessful. 181. In furtherance of the aforesaid civil conspiracy, defendant BRUNO, acting within Services Industry Group

his capacity and authority as the Director responsible for the

of the defendant WEF andlor WEF USA in its New York City offices, intentionally participated in the furtherance of the plan by offering KEENAN a $100 Million USD bribe to be split with DAL BOSCO in an effort to obtain his participation and cooperation in the theft of the DFFI from the Dragon Family and by speaking to and meeting with acquaintances of KEENAN, including Raykov and Marinov in an effort to obtain their assistance in convincing KEENAN to participate in the scheme to convert the DFFI. 182. Upon information and belief, in furtherance of the aforesaid civil conspiracy,

defendants BRUNO, acting within his capacity and authority as the Director responsible for the 80

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Financial Services Industry Group of the defendant WEF and! or WEF USA in its New York City offices, defendants RAGAGLINI, MARACHIAN, BERLUSCONI, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS and other unknown individual co-conspirators acting on behalf of defendants the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS intentionally participated in the furtherance of the conspiracy by planning, negotiating, developing and facilitating the creation of a UN Sovereign Program for the investment of the stolen DFFI. Said defendants' actions in this regard also furthered the conspiracy in that said defendants, in an effort to obtain KEENAN's cooperation in the conspiracy to convert the DFFI, repeatedly misrepresented to KEENAN and his acquaintances as detailed supra, that by acting in conjunction with the WEF andlor WEF USA, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS, all of the individual co-conspirators' illegal actions would be protected under the umbrella of sovereign immunity. 183. KEENAN has suffered serious financial detriment on account of and as a direct

proximate result of the civil conspiracy to expropriate and convert the DFFI and, at a minimum, defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEF USA are jointly and severally liable for the full value of the DFFI and all of its accumulated interest, with interest. Said defendants are also jointly and severally liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program.

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184.

Consequently, KEENAN has been damaged by the civil conspiracy to expropriate

and convert the DFFI by defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACIDAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KImoon, the UNITED NATIONS, BRUNO, WEF andlor WEF USA and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars.

AS AND FOR A THIRD CAUSE OF ACTION AGAINST DEFENDANTS DAL BOSCO, SALE, DAM AND OITC, [Civil Conspiracy to Expropriate and Convert the DFFI under Federal Common Law and International Law]
185. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 184 of the Complaint with the same force and effect as though fully set forth herein. 186. Upon information and belief, DAL BOSCO, as early as January 2009, had

discussions with defendant OITC and its President, defendant SALE, who was acting with the knowledge of and under the authority of defendant DAM, to discuss various fraudulent schemes, options andlor alternative actions DAL BOSCO and the other defendants, including OITC, SALE and DAM, would take with respect to bribing KEENAN or otherwise defrauding KEENAN into relinquishing control of and ultimate defalcation of the DFFI, which were then to be traded under DAM's Federal Reserve Master Commitment Holder Trading License. As a result of these discussions, defendants OITC, SALE and DAM knowingly and voluntarily agreed to participate in this scheme to unlawfully steal and convert the DFFI from KEENAN. According to recently published admissions by defendant SALE, DAL BOSCO admittedly contacted OITC no later than February 2010, and entered into a written contract with OITC no later than March 2010, whereby said parties agreed to steal and convert the DFFI, which had 82

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been temporarily entrusted to DAL BOSCO, in complete contravention ofDAL BOSCO's oral and written representations, as well as all fiduciary duties concomitant with such representations. 187. In furtherance of the aforesaid civil conspiracy defendants SALE and DAM,

acting on behalf of defendant OITC, intentionally participated in the furtherance of the plan by taking the position that the DFFI stolen and converted by DAL BOSCO were, in fact, the "property" of OITC rather than the Dragon Family, thereby enabling DAL BOSCO to perpetuate his fraud and convert the DFFI. Said acts in furtherance of the civil conspiracy include the following statements and/or actions of OITC, through SALE and DAM: (1) Issuing the OITC Order of June 8,2010, on behalf of DAM stating: (a) DAM was appointed as international Treasury Controller under United Nations Charter Control No: 10-60847; (b) that the DFFI were, in fact, the property of the International Collateral Accounts of the Global Debt Facility which are legally owned by His Excellency, Ray C. DAM, International Treasury Controller"; (c) directing KEENAN and Yamaguchi to surrender the DFFI on or before July 7, 2010; (2) Sending the June 10, 2010 letter via email to KEENAN "strongly advising" him not to ignore the OITC Order and to "adhere" to its content; and (3) Misrepresenting in writing to KEENAN that "Our ownership of the Dragon Funds being part of the Combined Internationl;ll Collateral Accounts of the Global Debt Facility, and our international status combined with our International Authority as granted, attested to, and formally issued by the Nations of the World" and warning that that the "impertinent mannerisms" in which KEENAN had allegedly "approached this matter" would not be tolerated as it shows "an insulting and arrogant attitude towards a Sovereign Entity which is legally chartered under the United Nations and recognized by all Nations ... "; and (4) Advising DAL BASCO that all conspirators could rely upon the "immunity" enjoyed by OITC for many years in reliance upon the umbrella of protection afforded by its relationship with the UN. 188. KEENAN has suffered serious financial detriment on account of and as a.direct

proximate result of the civil conspiracy to expropriate and convert the D FFI and, at a minimum, defendants DAL BOSCO, SALE, DAM and OITC are jointly and severally liable for the full 83

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value of the DFFI and all of its accumulated interest, with interest. Defendants DAL BOSCO, SALE, DAM and OITC are also jointly and severally liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 189. Consequently, KEENAN has been damaged by the civil conspiracy to expropriate

and convert the DFFI by defendants DAL BOSCO, SALE, DAM and OITC and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars.

AS AND FOR A FOURTH CAUSE OF ACTION AGAINST DEFENDANTS DAL' BOSCO, BERLUSCONI, RAGAGLINI, MIRACHIAN, ITALIAN FINANCIAL POLICE, ITALIAN REPUBLIC, BAN KI-moon, UNITED NATIONS, BRUNO, WEF and WEF USA, [Aiding and Abetting the Expropriation and Conversion of the DFFI under Federal Common Law and International Law1
190. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 189 of the Complaint with the same force and effect as though fully set forth herein. 191. The actions of defendants DAL BOSCO, BERLUSCONI, RAGAGLINI,

MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KJmoon, the UNITED NATIONS, BRUNO, WEF and/or WEF USA violate any and all notions of

jus cogens, a body of peremptory principles of customary and universal intemationallaw
recognized by civilized nations. At a minimum, the actions of said defendants constitute a knowing and willful participation to aid and abet the theft and conversion of the DFFI, valued at approximately ONE TRlLLION UNITED STATES DOLLARS, which theft and conversion was carried out by defendant DAL BOSCO, who personally absconded with the DFFI.

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192.

Upon information and beliet defendant BRUNO, acting within his capacity and

authority as the Director responsible for the Financial Services Industry Group of the defendant WEF and/or WEF USA in its New York City offices, defendants RAGAGLINI, MARACHIAN, and BERLUSCONI, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KImoon, the UNITED NATIONS and other unknown individual co-conspirators acting on behalf of and with the approval of defendants the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS, with knowledge of the planned theft and conversion of the DFFI from its true and rightful owners, and for the express purpose of facilitating the conversion of the DFFI from its true and rightful owners, provided substantial assistance in the expropriation and conversion of the DFFI from KEENAN by planning, negotiating, developing and facilitating the creation of a UN Sovereign Program for the investment of the DFFI purportedly under the umbrella of the ITALIAN REPUBLIC's and the UNITED NATION's sovereign immunity. In doing so, these defendants provided practical assistance, encouragement and moral support to the expropriation and conversion of the DFFI from KEENAN. 193. The substantial assistance and complicity of defendants BRUNO, WEF and/or

WEF USA, RAGAGLINI, MARACHIAN, BERLUSCONI, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS and other unknown individual co-conspirators acting on behalf of and with the approval of defendants the WEF and/or WEF USA, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS in the theft and conversion of the DFFlis further illustrated by the following acts performed with knowledge of the planned theft and conversion of the DFFI from its true and rightful owners, and for the express purpose of providing substantial assistance in the conversion of the DFFI from its true and rightful owners: 85

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(1) . Defendant UNITED NATIONS knowingly and actively participated in the conversion of the DFFI stolen by DAL BOSCO when it agreed to offer a bribe to KEENAN in the amount of $100 Million USD in an effort to obtain KEENAN's cooperation in the conversion of the DFFI, for its own benefit, those of its representatives, including defendants BAN KI -moon, for the benefit of defendants the ITALIAN REPUBLIC and its representatives, including defendants BERLUSCONI, RAGAGLINI, MlRACHIAN and the ITALIAN FINANCIAL POLICE, and for the benefit of the WEF andlor WEF USA, and its representative, defendants BRUNO, and for the benefit of others presently unknown, who participated in and aided and abetted the criminal enterprise. As part of the criminal enterprise and scheme, defendant DAL (2) BOSCO made contact with high level UN officials through the assistance of defendants BRUNO and the WEF andlor WEF USA, and as a result defendants the UNITED NATIONS and BAN KI-moon knowingly and actively approved the purchase of the DFFI, which it knew had been stolen by DAL BOSCO, not only for the purpose of aiding and abetting the conspiracy, but entered into the scheme with the avowed purpose of further concealing the theft and actively engaging in the conversion of the DFFI by: (1) purchasing the DFFI then in the possession of DAL BOSCO who had breached his fiduciary duties to KEENAN as temporary custodian of the DFFI by converting the DFFI; (2) offering to pay the sum of $100 Million USD for the release of the DFFI; (3) placing the stolen DFFI into a Sovereign Program for its own financial benefit; (4) all of the above to be accomplished without the knowledge of the Legal Holders of the DFFI, the Dragon Family. (3) The complicity of defendants the WEF andlor WEF USA, the UNITED NATIONS, the ITALIAN FINANCIAL POLICE and the ITALIAN REPUBLIC is apparent from the telephone conference call placed to BRUNO by DAL BOSCO on a speaker phone in the VIP Room of the Hotel Zurich in Switzerland in early February 2010. Such call was made via international telephone communication between DAL BOSCO and defendant BRUNO, of the WEF and/or WEF USA, who, upon information and belief, participated from New York, New York wherein the participation and approval' of the UNITED NATIONS was described in detail by BRUNO, who represented that he could "put 100 Million Dollars into KEENAN's hands if KEENAN agreed [to release the DFFI in contravention of the Dragon Family's rights in the same]." After this call, Vasil Ganov, who had been present for the call inquired of what DAL BOSCO would receive from the "transaction." DAL BOSCO stated that he would receive half of the $100 Million USD offered to KEENAN for his assistance, which he indicated would be placed into a Sovereign Program by the UN and that they would receive 200% monthly returns minimum from the total "investment." DAL BOSCO refused to comment on how much defendants the UN, WEF andlor WEF USA, BRUNO and OITC would receive from the transaction, indicating that such an inquiry "can only cause trouble." DAL 86

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BOSCO did, however, indicate that the stolen Notes would be placed into a "Sovereign Program by the UN," and upon completion would be returned to their rightful "owners," which he indicated was the OITC. DAL BOSCO further informed Ganov that "everyone was protected by the ITALIAN FINANCIAL POLICE and the Italian Government itself." (4) This complicity is also corroborated by the international telephone communication between DAL BOSCO and BRUNO, as overheard and described by Nikolay Raykov during his trip to the Zurich airport with DAL BOSCO following the telephone conference speaker call described above, and by Raykov's other interactions with DAL BOSCO and BRUNO. In the telephone conversation, BRUNO represented to Raykov that the DFFI would "be placed into a federal program using the UN as protection" along with "his company" referring to the WEF and/or WEF USA, which would "generate unlimited capital for everyone involved." According to BRUNO, "there would be no problems and that this was being blessed by the UNITED NATIONS" which "would protect everyone" as the DFFI would be "placed into a Sovereign Program" after which the DFFI "would disappear" and "there would be no questions asked." In a subsequent telephone call between Raykov and BRUNO, which took place while both parties were in New York, BRUNO advised Raykov that DAL BOSCO had absconded with the DFFI and that "now more than ever" Raykov was needed to convince KEENAN to cooperate in the conspiracy to deprive the Dragon Family of its interest in the DFFI. At a subsequent meeting between Raykov, BRUNO and DAL BOSCO at the Balexert Mall in Switzerland in May 2010, BRUNO commented that KEENAN "was stupid for not taking the 100 Million U.S. Dollars" and that "things had been in the planning stages for a while and were about to be completed with or without KEENAN." BRUNO again requested Raykov's assistance in convincing KEENAN to participate in the scheme. When Raykov indicated that KEENAN would not listen to him, BRUNO exclaimed, "Not even for 500 Million U.S. Dollars?" BRUNO then encouraged Raykov to call him at his New York office of the WEF USA to speak about the matter further. (5) Defendants' complicity was further corroborated during the course of the meeting between DAL BOSCO, BRUNO and Miranov at the Balexert mall in Switzerland in May 2010. At this meeting, defendant BRUNO explained who was involved in the conspiracy to convert the DFFI, specifically naming defendants RAGAGLINI, MlRAClllAN, BERLUSCONI, and the ITALIAN FINANCIAL POLICE, stating: "so you see there is no possible way we can have a problem. We can cloak ourselves with the immunity shield and everyone will go away. Just another day in the UN!" During this meeting held for the purpose of convincing Miranov to assist the defendants in their theft, a telephone call was received from defendant H.E. Ambassador MlRACHIAN, Permanent Representative of the Italian Mission to the UN in Geneva, who confirmed the direct knowledge and approval of the UNITED NATIONS Secretary General, 87

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BAN KI-moon stating: (i) "from the very top we were protected"; (ii) "there is no reason for anyone, including KEENAN, to worry about any sort of repercussions"; (iii) "the Italian cohorts in New York had even approved the matter with Secretary General BANK KI-moon" whom she expressly acknowledged "would deny he knew anything about it." 194. KEENAN has suffered serious financial detriment on account of and as a direct

and proximate result of defendants' acts aiding and abetting the expropriation and conversion of the DFFI and, at a minimum, defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KImoon, the UNITED NATIONS, BRUNO, WEF andlor WEF USA are jointly and severally liable for the full value of the DFFI and all of its accumulated interest, with interest. Defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF andlor WEF USA are also jointly and severally liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 195. Consequently, KEENAN has been damaged by the actions of defendants DAL

BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF andlor WEF USA aiding and abetting the expropriation and conversion of the DFFI and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars.

AS AND FOR A FIFTH CAUSE OF ACTION AGAINST DEFENDANTS DAL BOSCO, SALE, DAM, OITC, and UNITED NATIONS, [Aiding and Abetting the Expropriation and Conversion of the DFFI under Federal Common Law and International Law]
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196.

Plaintiff repeats and

each of the allegations contained in paragraphs 1

through 195 of the Complaint with the same force and effect as though fully set forth herein. 197. The actions of defendants DAL BOSCO, SALE, DAM, OITC and the UNITED

NATIONS violate any and all notions ofjus cogens, a body of peremptory principles of customary and universal international law recognized by civilized nations. At a minimum, the actions of said defendants constitute a knowing and willful participation to aid and abet the theft and conversion of the DFFI, valued at approximately ONE TRILLION UNITED STATES DOLLARS, which theft and conversion was carried out by defendant DAL BOSCO, who personally absconded with the DFFI. 198. Defendants SALE and DAM acting on behalf of defendant OITC, with

knowledge of the planned theft and conversion of the DFFI from its true and rightful owners, and for the express purpose of facilitating the conversion of the DFFI from its true and rightful owners, provided substantial assistance in the expropriation and conversion of the DFFI from KEENAN by taking the position that the DFFI stolen and converted by DAL BOSCO were in fact the "property" ofOITC rather than the Dragon Family, thereby enabling DAL BOSCO to perpetuate his fraud and convert the DFFI. In doing so, these defendants provided practical assistance, encouragement and moral support to the expropriation and conversion of the DFFI from KEENAN. Said acts in substantial assistance to the conversion of the DFFI from KEENAN, which were made with knowledge of and for the purpose of facilitating the conversion of the DFFI, include the following statements and/or actions of OITC, through SALE and DAM: (1) issuing the OITC Order of June 8,2010, on behalf of DAM stating: (a) DAM was appointed as international Treasury Controller under United Nations Charter Control No: 10-60847; (b) that the DFFI were, in fact, the 89

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property of the International Collateral Accounts of the Global Debt Facility which are legally owned by His Excellency, Ray C. DAM, International Treasury Controller; (c) directing KEENAN and Yamaguchi to surrender the DFFI on or before July 7, 2010. (2 Sending the June 10,2010 letter via email to KEENAN "strongly advising" him not to ignore the OITC Order and to "adhere" to its content; and (3) Misrepresenting in writing to KEENAN that "Our ownership of the Dragon Funds being part of the Combined International Collateral Accounts of the Global Debt Facility, and our international status combined with our International Authority as granted, attested to, and formally issued by the Nations of the World" and warning that that the "impertinent mannerisms" in which KEENAN had allegedly "approached this matter" would not be tolerated as it shows "an insulting and arrogant attitude towards a Sovereign Entity which is legally chartered under the United Nations and recognized by all Nations ... "; and (4) Advising DAL BASCO that all conspirators could rely upon the "immunity" enjoyed by OITC for many years in reliance upon the umbrella of protection afforded by its relationship with the UN. 199. The UNITED NATIONS has been complicit in the nefarious and fraudulent

activities of OITC in that it has never formally denounced or disassociated itself from OITC, and has allowed OITC to hold itself out to the world community as protected by its umbrella of legitimacy and chartered by the UNITED NATIONS itself. Upon information and belief, defendant the UNITED NATIONS, with knowledge of the planned theft and conversion of the DFFI from its true and rightful owners, and for the express purpose of facilitating the conversion of the DFFI from its true and rightful owners, provided substantial assistance in the expropriation and conversion of the DFFI from KEENAN by allowing and actively encouraging the OITC to represent itself as affiliated with and charted by the UNITED NATIONS in OITC's efforts to convince KEENAN to release the DFFI to defendants on the purported basis that the DFFI belonged to 0 ITC rather than the Dragon Family.

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200.

KEENAN has suffered seriofts financial detriment on account of and as a direct

and proximate result of the action of defendants DAL BOSCO, SALE, DAM, OITC and the UNITED NATIONS aiding and abetting the expropriation and conversion of the DFFI and, at a minimum, said defendants are jointly and severally liable for the full value of the DFFI and all of its accumulated interest, with interest. Defendants DAL BOSCO, SALE, DAM, OITC and the UNITED NATIONS are also jointly and severally liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 201. Consequently, KEENAN has been damaged by the actions of defendants DAL

BOSCO, SALE, DAM, OITC and the UNITED NATIONS aiding and abetting the expropriation and conversion of the DFFI and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars. AS AND FOR A SIXTH CAUSE OF ACTION AGAINST DEFENDANT DAL BOSCO [Fraud under Federal Common Law and International Law] 202. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 201 of the Complaint with the same force and effect as though fully set forth herein. 203. As described in more detail supra, DAL BOSCO arranged to meet with

KEENAN in July 2009 for the conscious purpose of gaining his trust and confidence with the intention of fraudulently inducing KEENAN to transfer custodianship and control of the DFFI in order that DAL BOSCO and his co-conspirators could unjustly enrich themselves for their own personal benefit and utterly to the detriment of KEENAN and the Dragon Family. 204. At all relevant times, DAL BOSCO's intention was to knowingly assume control

and exercise ownership over the DFFI in contravention of the rights of KEENAN and the 91

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Dragon Family and to utilize the DFFI in various selfish and unlawful ways, including the pronouncement by OITC through its unlawful Cease and Desist Order of its alleged legal ownership of the D FFI and further criminal actions as described herein 205. Despite DAL BOSCO's knowledge and intent to abscond with the DFFI for his

own personal benefit and the benefit of his co-conspirators, he falsely misrepresented to KEENAN, as set forth both orally and in his written ACCEPTANCE of September 9, 2009, made for the express purpose of inducing KEENAN to rely upon them, as follows: (1) "I can assure you that you will never regret making this decision"; (2) "You are aware of the fact I am well trusted and a financial advisor within the Vatican and Mason circles and would never jeopardize my position with them for anything"; (3) "My word is my bond and my word is Gold"; (4) "I will be waiting for your Zurich arrival so that we can do great things for the world"; (5) "I understand clearly that I am not to discuss these bonds with anyone outside the immediate circle and my privacy is integral to the success of many nations"; (6) "I further understand you are the authorized representative and Power of Attorney for said bonds and I will entrust them believe me as though it was my life depending on it. Therefore I humbly accept the custodianship of said Bonds in which I am only to return them to either you or Mr. Yamaguchi. Not any other !"; (7) "although electronic this email is to be considered my legal binding acceptance of the following bonds (bonds listed)"; (8) "Will be ready when called upon to deliver said notes to you." 206. KEENAN reasonably and justifiably relied, to his severe personal detriment, on

the knowingly false material misrepresentations ofDAL BOSCO set forth above, as well as the numerous material oral misrepresentations of a similar or identical nature made by DAL BOSCO between July and September 2009 set forth in detail in the Complaint at paragraphs 70 through 92

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82, and KEENAN transferred custody of the DFFI to DAL BOSCO on or about September 18, 2009 on the basis of said misrepresentations. 207. Defendant DAL BOSCO deliberately made such misrepresentations in order to

induce plaintiff KEENAN to rely on said misrepresentations and convince KEENAN to transfer custody of the DFFI to him. KEENAN has suffered serious financial detriment on account of and as a direct and proximate result of defendant DAL BOSCO's fraud and, at a minimum, DAL BOSCO is liable for the full value of the DFFI and all of its accumulated interest, with interest. DAL BOSCO is also liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 208. Consequently, DAL BOSCO's intentional failure to return the DFFI, which were

entrusted to him by KEENAN on the basis of his numerous misrepresentations, has caused severe financial detriment to KEENAN. Consequently, KEENAN has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars. AS AND FOR A SEVENTH CAUSE OF ACTION AGAINST DEFENDANTS DAL BOSCO, BERLUSCONI, RAGAGLINI, MIRACHIAN, ITALIAN FINANCIAL POLICE, ITALIAN REPUBLIC, BAN KI-moon, UNITED NATIONS, BRUNO, WEF and WEF USA, [Civil Conspiracy to Commit Fraud under Federal Common Law and International Law] 209. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 208 of the Complaint with the same force and effect as though fully set forth herein. 210. Upon information and belief, defendants DAL BOSCO, BERLUSCONI, the

ITALlAN FINANCIAL POLICE, and the ITALIAN REPUBLIC entered into an agreement whereby each party knowingly and voluntarily agreed to participate in a scheme to steal certain
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financial instruments for the purpose of profiting from this theft of financial instruments. As part of this scheme, defendants DAL BOSCO, BERLUSCONI, the ITALIAN FINANCIAL POLICE, and the ITALIAN REPUBLIC knowingly and voluntarily agreed to defraud KEENAN of the DFFI. Among the prospective unlawful uses planned for the DFFI by said defendants was the purchase of a Swiss Bank, such as Banco Commerciale di Lugano, or any other Swiss Bank into which they could immediately move all stolen assets, including the DFFI. 211. Upon information and belief, sometime thereafter, defendants BRUNO and the

WORLD ECONOMIC FORUM and/or the WORLD ECONOMIC FORUM USA, INC. knowingly and voluntarily agreed to participate in this scheme to assist DAL BOSCO in his effort to obtain the DFFI from KEENAN through various acts of fraud. Defendants BRUNO and the WEF and!or WEF USA further knowingly and voluntarily agreed to utilize their connections within the defendant UNITED NATIONS to set up Sovereign Programs for the investment of the unlawfully obtained financial instruments that they knew to be either stolen or seized under color of police authority of the ITALIAN FINANCIAL POLICE or unlawfully obtained by others, and which included the DFFI, to the profit of all the co-conspirators. Among the prospective unlawful uses planned for the DFFI by said defendants was the purchase of a Swiss Bank, such as Banco Commerciale di Lugano, into which the DFFI, in combination with other stolen or seized assets, could be deposited and traded for the profit of said co-conspirators. 212. Upon information and belief, thereafter BRUNO, acting within his authority as

the Director responsible for the Financial Services Industry Group of the defendant WEF and/or WEF USA in its New York City offices, and defendants BERLUSCONI, H.E. Ambassador CESARE MARIA RAGAGLINI, Permanent Representative of the Italian Mission to the UN in New York, H.E. Ambassador LAURA MlRACHIAN, Permanent Representative of the Italian 94

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Mission to the UN in Geneva, defendant BAN Kl-moon, Secretary-General of the United Nations, and other unknown representatives of defendants the ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE and the UNITED NATIONS procured an agreement entered into knowingly and voluntarily by the foregoing defendants whereby the unlawfully obtained financial instruments that said defendants knew to be either stolen or seized under color of police authority of the ITALIAN FINANCIAL POLICE or unlawfully obtained by others, and which included the DFFI to be obtained by DAL BOSCO's fraud, would be invested in a "Sovereign Program" wholly under the auspices, protection and umbrella of the "sovereign immunity" allegedly accorded to the UNITED NATIONS and the ITALIAN REPUBLIC. 213. Upon information and belief, and in furtherance of the aforesaid civil conspiracy

to defraud, defendants the ITALIAN FINANCIAL POLICE and the ITALIAN REPUBLIC intentionally participated in the furtherance of the plan by seizing the DF Chiasso Instruments in an amount approximating $134.5 Billion U.S. Dollars from Dragon Family representatives Yamaguchi and Watanabe. This seizure of the DF Chiasso Instruments, which incident was described in detail supra, was then utilized by the defendant co-conspirators as a pretext for introducing DAL BOSCO to KEENAN for the purpose of convincing KEENAN, through numerous misrepresentations detailed supra that it would be wise to entrust custody of the DFFI to DAL BOSCO in order to avoid a similar incident from occurring with respect to the DFFI. 214. Upon information and belief, and in furtherance of the aforesaid civil conspiracy

to defraud KEENAN, defendant DAL BOSCO intentionally participated in the furtherance of the plan by making knowingly false material representations to KEENAN for the purposes of inducing KEENAN to relinquish custody of the DFFI into DAL BOSCO's possession, orchestrating and participating in the numerous attempts to bribe KEENAN in an effort to induce 95

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KEENAN to participate in the fraudulent scheme as detailed supra, and ultimately by absconding with the DFFI when the attempts to bribe KEENAN were unsuccessful. 215. In furtherance of the aforesaid civil conspiracy to defraud KEENAN, defendant

BRUNO, acting within his capacity and authority as the Director responsible for the Financial Services Industry Group of the defendant WEF and/or WEF USA in its New York City offices, intentionally participated in the furtherance of the plan by offering KEENAN a $100 Million USD bribe to be split with DAL BOSCO in an effort to obtain his participation and cooperation in the fraudulent scheme and by speaking to and meeting with acquaintances of KEENAN, including Raykov and Marinov in an effort to obtain their assistance in convincing KEENAN to participate in their fraudulent scheme. 216. Upon information and belief, in furtherance of the aforesaid civil conspiracy to

defraud KEENAN, defendants BRUNO, acting within his capacity and authority as the Director responsible for the Financial Services Industry Group of the defendant WEF and/or WEF USA in its New York City offices, defendants RAGAGLINI, MARACHIAN, and BERLUSCONI, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC,_ BAN KI-moon, the UNITED NATIONS and other unknown individual co-conspirators acting on behalf of defendants the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS intentionally participated in the furtherance of the conspiracy by planning, negotiating, developing and facilitating the creation of a UN Sovereign Program for the investment of the DFFI to be fraudulently obtained from KEENAN. Said defendants actions in this regard also furthered the conspiracy to defraud KEENAN in that said defendants, in an effort to obtain KEENAN's cooperation in the fraudulent scheme, repeatedly misrepresented to KEENAN and his acquaintances as detailed supra, that by acting in conjunction with the WEF, WEF USA, the

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ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS, all of the individual co-conspirators' illegal actions would be protected under the umbrella of sovereign immunity. 217. KEENAN has suffered serious financial detriment on account of and as a direct

proximate result of the civil conspiracy to defraud KEENAN of the DFFI and, at a minimum, defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEF USA are jointly and severally liable for the full value of the DFFI and all of its accumulated interest, with interest. Defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEF USA are also jointly and severally liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 218. Consequently, KEENAN has been damaged by the civil conspiracy to defraud

him of the DFFI by defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEF USA and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars.

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AS AND FOR A EIGHTH CAUSE OF ACTION AGAINST DEFENDANTS DAL BOSCO, SALE, DAM AND OITC, [Civil Conspiracy to Commit Fraud under Federal Common Law and International Law] 219. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 218 of the Complaint with the same force and effect as though fully set forth herein. 220. Upon information and belief, DAL BOSCO, possibly as early as January 2009,

had discussions with defendant OITC and its President, defendant SALE, who was acting with the knowledge of and under the authority of defendant DAM, to discuss various fraudulent schemes, options andlor alternative actions DAL BOSCO and the other defendants, including OITC, SALE and DAM, would take with respect to bribing KEENAN or otherwise defrauding KEENAN into relinquishing control of and ultimate defalcation of the DFFI, which were then to be traded under DAM's Federal Reserve Master Commitment Holder Trading License. As a result of these defendants OITC, SALE and DAM knowingly and voluntarily agreed

to participate in this scheme to participate in this scheme to obtain the DFFI from KEENAN by fraud. According to recently published admissions by defendant SALE, DAL BOSCO admittedly contacted OITC no later than February 2010, and entered into a written contract with OITC no later than March 2010, whereby said parties agreed to assist DAL BOSCO in the fraudulent scheme to abscond with the DFFI for the enrichment of all co-conspirators. 221. In furtherance of the aforesaid civil conspiracy to defraud KEENAN, defendants

SALE and DAM, acting on behalf of defendant OITC, intentionally participated in the furtherance of the plan by taking the position that the DFFI stolen and converted by DAL BOSCO were, in fact, the "property" of OITC rather than the Dragon Family, thereby enabling DAL BOSCO to perpetuate his fraud and convert the DFFI. Said acts in furtherance of the civil conspiracy include the following statements andlor actions of OITC, through SALE and DAM: 98

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(1) Issuing the OITC Order of June 8, 2010, on behalf of DAM stating: (a) DAM was appointed as International Treasury Controller under United Nations Charter Control No: 10-60847; (b) that the DFFI were, in fact, the property of the International Collateral Accounts of the Global Debt Facility which are legally owned by His Excellency, Ray C. DAM, International Treasury Controller"; (c) directing KEENAN and Yamaguchi to surrender the DFFI on or before July 7,2010; (2) Sending the June 10,2010 letter via email to KEENAN "strongly advising" him not to ignore the OITC Order and to "adhere" to its content; (3) Misrepresenting in writing to KEENAN that "Our ownership of the Dragon Funds being part of the Combined International Collateral Accounts of the Global Debt Facility, and our international status combined with our International Authority as granted, attested to, and formally issued by the Nations of the World" and warning that that the "impertinent mannerisms" in which KEENAN had allegedly "approached this matter" would not be tolerated as it shows "an insulting and arrogant attitude towards a Sovereign Entity which is legally chartered under the United Nations and recognized by all Nations ... "; and (4) Advising DAL BASCO that all conspirators could rely upon the "immunity" enjoyed by OITC for many years in reliance upon the umbrella of protection afforded by its relationship with the UN. 222. KEENAN has suffered serious financial detriment on account of and as a direct

proximate result of the civil conspiracy to defraud KEENAN of the DFFI and, at a minimum, defendants DAL BOSCO, SALE, DAM and OITC are jointly and severally liable for the full value of the DFFI and all of its accumulated interest, with interest. Defendants DAL BOSCO, SALE, DAM and OITC are also jointly and severally liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 223. Consequently, KEENAN has been damaged by the civil conspiracy to defraud

him of the DFFI by defendants DAL BOSCO, SALE, DAM and OITC and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars.
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AS AND FOR A NINTH CAUSE OF ACTION AGAINST DEFENDANTS DAL BOSCO, BERLUSCONI, RAGAGLINI, MIRACHIAN, ITALIAN FINANCIAL POLICE, ITALIAN REPUBLIC, BAN KI-moon, UNITED NATIONS, BRUNO, WEF and WEF USA, [Aiding and Abetting Dal Bosco's Fraud under Federal Common Law and International Law]
224. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 223 of the Complaint with the same force and effect as though fully set forth herein. 225. The actions of Defendants DAL BOSCO, BERLUSCONI, RAGAGLINI,

MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KJmoon, the UNITED NATIONS, BRUNO, WEF and WEF USA violate any and all notions ofjus

cogens, a body of peremptory principles of customary and universal international law recognized
by civilized nations. At a minimum, the actions of said defendants constitute a knowing and willful participation to aid and abet the defrauding of KEENAN of the DFFI, valued at approximately ONE TRILLION UNITED STATES DOLLARS, which fraud was completed by defendant DAL BOSCO, who personally obtained the DFFI from KEENAN through fraudulent misrepresentations. 226. Upon information and belief, defendant BRUNO, acting within his capacity and

authority as the Director responsible for the Financial Services Industry Group of the defendant WEF andlor WEF USA in its New York City offices, defendants RAGAGLINI, MARACHIAN, and BERLUSCONI, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KImoon, the UNITED NATIONS and other unknown individual co-conspirators acting on behalf of and with the approval of defendants the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS, with knowledge of the plan to fraudulently obtain the DFFI, and for the express purpose of facilitating said fraud, provided substantial assistance to the
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fraudulent scheme by planning, negotiating; developing and facilitating the creation of a UN Sovereign Program for the investment of the DFFI to be fraudulently obtained from Keenan. In further substantial assistance of the fraudulent scheme, said defendants, in an effort to obtain KEENAN's cooperation, repeatedly misrepresented to KEENAN and his acquaintances as detailed supra, that by acting in conjunction with the WEF andlor WEF USA, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS, all of the individual co-conspirators' illegal actions would be protected under the umbrella of sovereign immunity. In doing so, these defendants provided practical assistance, encouragement and moral support to the fraudulent deprivation of the DFFI from KEENAN and the Dragon Family. 227. The substantial assistance and complicity of defendants BRUNO, WEF, WEF

USA, RAGAGLINI, MARACHIAN, BERLUSCONI, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS and other unknown individual co-conspirators acting on behalf of and with the approval of defendants the WEF andlor WEF USA, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS in the fraudulent scheme to deprive KEENAN and the Dragon Family of the DFFI is further illustrated by the following acts performed with knowledge of the fraudulent and unlawful nature of the scheme, and for the express purpose of providing substantial assistance therein: (1) Defendant UNITED NATIONS knowingly and actively participated in the fraud when it agreed to offer a bribe to KEENAN in the amount of$100 Million USD in an effort to obtain KEENAN's cooperation in the fraudulent scheme, for its own benefit, those of its representatives, including defendants BAN KI-moon, for the benefit of defendants, the ITALIAN REPUBLIC, and its representatives, including defendants BERLUSCONI, RAGAGLINI, MIRACHIAN and the ITALIAN FINANCIAL POLICE, and for the benefit of the WEF andlor WEF USA, and its representative, defendants
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BRUNO, and for the benefit of othets presently unknown, who participated in and aided and abetted the criminal enterprise. (2) As part of the criminal enterprise and scheme, defendant DAL BOSCO made contact with high level UN officials through the assistance of defendants BRUNO and the WEF and/or WEF USA, and as a result defendants the UNITED NATIONS and BAN KI -moon knowingly and actively approved the purchase of the DFFI, which it knew had been on the basis of fraudulent misrepresentations by DAL BOSCO, not only for the purpose of aiding and abetting the conspiracy, but entered into the scheme with the avowed purpose of further concealing the fraud and actively engaging in the conversion of the DFFI by: (1) purchasing the DFFI then in the possession of DAL BOSCO who had breached his fiduciary duties to KEENAN as temporary custodian of the DFFI by fraudulently obtaining and converting the DFFI; (2) offering to pay the sum of $100 Million USD for the release of the DFFI; (3) placing the stolen DFFI into a Sovereign Program for its own financial benefit; (4) all of the above to be accomplished without the knowledge of the Legal Holders of the DFFI, the Dragon Family. (3) The complicity of defendants the WEF, the WEF USA, the UNITED NATIONS, the ITALIAN FINANCIAL POLICE and the ITALIAN REPUBLIC is apparent from the telephone conference call placed to BRUNO by DAL BOSCO on a speaker phone in the VIP Room of the Hotel Zurich in Switzerland on or about February 2010. Such call was made via international telephone communication between DAL BOSCO and defendant BRUNO, of the WEF and/or WEF USA, who participated from New York, New York wherein the participation and approval of the UNITED NATIONS was described in detail by BRUNO, who represented that he could "put 100 Million Dollars into KEENAN's hands if KEENAN agreed [to release the DFFI in contravention of the Dragon Family's rights in the same]." After this call, Vasil Ganov, who had been present for the call inquired of what DAL BOSCO would receive from the "transaction." DAL BOSCO stated that he would receive half of the $100 Million USD offered to KEENAN for his assistance, which he indicated would be placed into a Sovereign Program by the UN and that they would receive 2000/0 monthly returns minimum from the total "investment." DAL BOSCO refused to comment on how much defendants the UN, WEF and/or WEF USA, BRUNO and OITC would receive from the transaction, indicating that such an inquiry "can only cause trouble." DAL BOSCO did, however, indicate that the stolen Notes would be placed into a "Sovereign Program by the UN," and upon completion would be returned to their rightful "owners," which he misrepresented was the OITC. DAL BOSCO further informed Ganov that "everyone was protected by the ITALIAN FINANCIAL POLICE and the Italian Government itself."

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(4) This complicity is also corroborated by the international telephone communication between DAL BOSCO and BRUNO, as overheard and described by Nikolay Raykov during his trip to the Zurich airport with DAL BOSCO following the telephone conference speaker call described above, and by Raykov's other interactions with DAL BOSCO and BRUNO. In the telephone conversation, BRUNO represented to Raykov that the DFFI would "be placed into a federal program using the UN as protection" along with "his company" referring to the WEF andlor WEF USA, which would "generate unlimited capital for everyone involved." According to BRUNO, "there would be no problems and that this was being blessed by the UNITED NATIONS" which "would protect everyone" as the DFFI would be "placed into a Sovereign Program" after which the DFFI "would disappear" and "there would be no questions asked." In a subsequent telephone call between Raykov and BRUNO, which took place while both parties were in New York, BRUNO advised Raykov that DAL BOSCO had absconded with the DFFI and that "now more than ever" Raykov was needed to convince KEENAN to cooperate in the conspiracy to deprive the Dragon Family of its interest in the DFFI. At a subsequent meeting between Raykov, BRUNO and DAL BOSCO at the Balexert Mall in Switzerland in May 2010, BRUNO commented that KEENAN "was stupid for not taking the 100 Million U.S. Dollars" and that "things had been in the planning stages for a while and were about to be completed with or without KEENAN." BRUNO again requested Raykov's assistance in convincing KEENAN to participate in the fraudulent scheme. When Raykov indicated that KEENAN would not listen to him, BRUNO exclaimed, "Not even for 500 Million U.S. Dollars?" BRUNO then encouraged Raykov to call him at his New York office of the WEF USA to speak about the matter further. (5) Defendants' complicity was further corroborated during the course of the meeting between DAL BOSCO, BRUNO and Miranov at the Balexert mall in Switzerland in May 2010. At this meeting, defendant BRUNO explained who was involved in the fraudulent scheme to steal the DFFI, specifically naming defendants RAGAGLINI, MlRACIDAN, BERLUSCONI, and the ITALIAN FINANCIAL POLICE, stating: "so you see there is no possible way we can have a problem. We can cloak ourselves with the immunity shield and everyone will go away. Just another day in the UN!" During this meeting held for the purpose of convincing Miranov to assist the defendants in their fraud, a telephone call was received from defendant H.E. Ambassador MlRACHIAN, Permanent Representative of the Italian Mission to the UN in Geneva, who confirmed the direct knowledge and approval of the United Nations Secretary General, BAN KImoon stating: (i) "from the very top we were protected"; (ii) "there is no reason for anyone, including KEENAN, to worry about any sort of repercussions"; (iii) "the Italian cohorts in New York had even approved the matter with Secretary General BANK KI-moon" whom she expressly acknowledged "would deny he knew anything about it." 103

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228.

KEENAN has suffered seriotls financial detriment on account of and as a direct

and proximate result of defendants' acts aiding and abetting the fraudulent scheme and, at a minimum, defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEF USA are jointly and severally liable for the full value of the DFFI and all of its accumulated interest, with interest. Defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEF USA are also jointly and severally liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 229. Consequently, KEENAN has been damaged by the actions of defendants DAL

BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF andlor WEF USA aiding and abetting the effort to defraud KEENAN of the DFFI and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars.

AS AND FOR A TENTH CAUSE OF ACTION AGAINST DEFENDANTS DAL BOSCO, SALE, DAM, OITC, and UNITED NATIONS, [Aiding and Abetting Dal Bosco's Fraud under Federal Common Law and International Law]
230. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 229 of the Complaint with the same force and effect as though fully set forth herein.

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231.

The actions of defendants DAL BOSCO, SALE, DAM, OITC and the UNITED

NATIONS violate any and all notions ofjus cogens, a body of peremptory principles of customary and universal international law recognized by civilized nations. At a minimum, the actions of said defendants constitute a knowing and willful participation to aid and abet the defrauding of KEENAN of the DFFI, valued at approximately ONE TRILLION UNITED STATES DOLLARS, which fraud was completed by defendant DAL BOSCO, who personally obtained the DFFI from KEENAN through fraudulent misrepresentations and absconded with the DFFI. 232. SALE and DAM acting on behalf of defendant OITC, with

knowledge of the planned fraudulent scheme to obtain the DFFI in contravention of the rights of its true and rightful owners, and for the express purpose of facilitating the said fraud, provided substantial assistance·in the fraud by taking the position that the DFFI stolen and converted by DAL BOSCO were in fact the "property" ofOITC rather than the Dragon Family, thereby enabling DAL BOSCO to perpetuate his fraud and convert the DFFI. In doing so, these defendants provided practical assistance, encouragement and moral support to the fraud. Said acts in substantial assistance to the scheme to defraud KEENAN, which were made with knowledge of and for the purpose of facilitating the fraud, include the following statements andlor actions of OITC, through SALE and DAM: (1) Issuing the OITC Order of June 8,2010, on behalf of DAM stating: (a) DAM was appointed as international Treasury Controller under United Nations Charter Control No: 10-60847; (b) that the DFFI were, in fact, the property of the International Collateral Accounts of the Global Debt Facility which are legally owned by His Excellency, Ray C. DAM, International Treasury Controller"; (c) directing KEENAN and Yamaguchi to surrender the DFFI on or before July 7,2010.

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(2) Sending the June 10,2010 letter via email to KEENAN "strongly advising" him not to ignore the OITC Order and to "adhere" to its content; (3) Misrepresenting in writing to KEENAN that "Our ownership of the Dragon Funds being part of the Combined International Collateral Accounts of the Global Debt Facility, and our international status combined with our International Authority as granted, attested to, and formally issued by the Nations of the World" and warning that that the "impertinent mannerisms" in which KEENAN had allegedly "approached this matter" would not be tolerated as it shows "an insulting and arrogant attitude towards a Sovereign Entity which is legally chartered under the United Nations and recognized by all Nations ... "; and (4) Advising DAL BASCO that all conspirators could rely upon the "immunity" enjoyed by OITC for many years in reliance upon the umbrella of protection afforded by its relationship with the UN. 233. The UNITED NATIONS has been complicit in the nefarious and fraudulent

activities of OITC in that it has never formally denounced or disassociated itself from OITC, and has allowed OITC to hold itself out to the world community as protected by its umbrella of legitimacy and chartered by the UNITED NATIONS itself. Upon information and belief, defendant the UNITED NATIONS, with knowledge of the planned fraudulent scheme, and for the express purpose of facilitating the defrauding of KEENAN and the Dragon Family, provided substantial assistance to said fraud by allowing and actively encouraging the OITC to represent itself as affiliated with and charted by the UNITED NATIONS in OITC's efforts to convince KEENAN to release the DFFI to defendants on the purported basis that the DFFI belonged to OITC rather than the Dragon Family. 234. KEENAN has suffered serious financial detriment on account of and as a direct

and proximate result of the action of defendants DAL BOSCO, SALE, DAM, OITC and the UNITED NATIONS aiding and abetting the fraudulent scheme and, at a minimum, said defendants are jointly and severally liable for the full value of the DFFI and all of its accumulated interest, with interest. Defendants DAL BOSCO, SALE, DAM, OITC and the 106

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UNITED NATIONS are also jointly and severally liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program. 235. Consequently, KEENAN has been damaged by the actions of defendants DAL

BOSCO, SALE, DAM, OITC and the UNITED NATIONS aiding and abetting the effort to defraud KEENAN of the DFFI and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars.
AS AND FOR A ELEVENTH CAUSE OF ACTION AGAINST DEFENDANT DAL BOSCO [Breach of:'Contract under Federal Common Law and International Law]

236.

Plaintiff repeats and realleges each of the allegations contained in Paragraphs 1

through 235 with the same force and effect as though fully set forth herein. 237. After months of meetings and discussions with KEENAN, DAL BOSCO, for

valuable consideration, entered into a written contract with plaintiff, KEENAN. 238. The contract provided: (1) "I can assure you that you will never regret making

this decision"; (2) "You are aware of the fact I am well trusted and a financial advisor within the Vatican and Mason circles and would never jeopardize my position with them for anything"; (3) "My word is my bond and my word is Gold"; (4) "I will be waiting for your Zurich arrival so that we can do great things for the world"; (5) "I understand clearly that I am not to discuss these bonds with anyone outside the immediate circle and my privacy is integral to the success of many nations"; (6) "I further understand you are the authorized representative and Power of Attorney for said bonds and I will entrust them believe me as though it was my life depending on it. Therefore I humbly accept the custodianship of said Bonds in which I am only to return them 107

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to either you or Mr. Yamaguchi. Not any other!"; (7) "although electronic this email is to be considered my legal binding acceptance of the following bonds" (bonds listed); (8) "Will be ready when called upon to deliver said notes to you." 239. DAL BOSCO has failed to perform his obligations under the contract and thereby

breached the contact by failing to return and/or deliver the DFFI entrusted to him upon notwithstanding KEENAN's repeated requests made in accordance with the terms of the contract. 240. KEENAN has suffered serious financial detriment on account of and as a direct

and proximate result ofDAL BOSCO's breach of contract and DAL BOSCO is consequently liable for the full value of the DFFI and all of its accumulated interest, with interest. DAL BOSCO is also liable for KEENAN's lost profits from the fees to which he was entitled for performing his services for the Dragon Family with respect to coordinating the placement of the DFFI into an approved trading program, which loss was a foreseeable result ofDAL BOSCO's breach of contract. 241. Consequently, KEENAN has been damaged by DAL BOSCO's breach of

contract and has sustained damage in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars. AS AND FOR A TWELFTH CAUSE OF ACTION AGAINST ALL DEFENDANTS [Replevin under Federal Common Law and International Law] 242. Plaintiff repeats and realleges each of the allegations contained in paragraphs 1

through 241 of the Complaint with the same force and effect as though fully set forth herein. 243. Pursuant to a certain Special Power of Attorney executed by Yamaguchi on behalf

of the Dragon Family, and with the approval of General Haan, the Head of the Dragon Family, 108

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which authorized KEENAN to act on behalf of Yamaguchi and the Dragon Family for the private placement of or legal return of the DFFI, KEENAN lawfully possessed the DFFI. 244. Family. 245. All Defendants engaged in a civil conspiracy to convert the DFFI from KEENAN Defendant DAL BOSCO converted the DFFI from KEENAN and the Dragon

and the Dragon Family. 246. All Defendants aided and abetted the conversion of the DFFI from KEENAN and

the Dragon Family. 247. Despite repeated demands by KEENAN to return the DFFI, the Defendants have

continued in their refusal to return the DFFI to KEENAN or the Dragon Family. 248. Upon information and belief, defendant DAL BOSCO andlor alternatively all of

some of the Defendants currently possess all or a portion of the DFFI. 249. Plaintiff KEENAN therefore seeks a permanent Injunction ordering DAL BOSCO

or any other Defendant or related entity to return the DFFI to plaintiff KEENAN.
WHEREFORE, Plaintiff NEIL F. KEENAN, Individllally and as Agent for THE

DRAGON FAMILY, requests judgment in his favor against Defendants as follows: 1. As to Counts One and Six against defendant DANIELE DAL BOSCO, awarding

KEENAN compensatory and consequential damages in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars; 2. As to Counts Two, Four, Seven and Nine against defendants DAL BOSCO,

BERLUSCONI, RAGAGLINI, MlRACHIAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEF USA, jointly and severally, awarding KEENAN compensatory and consequential damages in a 109

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sum to be determined at trial, but believed t6 be in excess of One Trillion ($1,000,000,000,000.00) US dollars; 3. As to Counts Three, Five, Eight and Ten against defendants DAL BOSCO,

SALE, DAM, OITC and the UNITED NATIONS, jointly and severally, awarding KEENAN compensatory and consequential damages in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars; 4. As to Count Eleven, against defendant DANIELE DAL BOSCO, awarding

KEENAN contractual and liquidated damages, and for compensatory, consequential and reasonably foreseeable damages in a sum to be determined at trial, but believed to be in excess of One Trillion ($1,000,000,000,000.00) US dollars; 5. As to Count Twelve, against all Defendants, the entry of a permanent injunction

directing each Defendant found to be in possession of the DFFI or any portion thereof, to return the said DFFI or portion thereof to plaintiff KEENAN, which DFFI consists of: (i) Two-Hundred Forty-nine (249) United States 1934 Series Federal Reserve Notes which, according to a Federal Reserve System Inventory List (SC1226-71-DOO4-D45184101 A) prepared at the time of issuance, were contained in "Box No. D 45184101 A" bearing Bond Nos. "D 45184101 A- D 45184350 A" (one sheet No. D 45184349 A missing) each with a face value of $500 Million ($500,000,000.00) United States Dollars in the total amount of One Hundred Twenty-Four Billion Five-Hundred Million United States Dollars ($124,500,000,000.00); (ii) Two (2) 57th Series Japanese Government Bearer Bonds, Nos. A 1306 and A 1310, which were issued on April 30, 1983 by the Ministry of Finance, Government of Japan, each having a face value of Japanese Yen Five Hundred (500) Billion, which is equivalent to an amount in excess of Nine and One-Half (9.5) Billion United States Dollars; and (iii) One (1) United States Kennedy Bond with a face value of One (1) Billion United States Dollars, bearing registration number APII 024068 A.

110

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6.

Awarding plaintiff KEENAN punitive damages and the costs of this action,

including reasonable attorneys' fees, assessed against all Defendants, jointly and severally; 7. F or such other and further relief as this Court may deem just and proper.

Dated: White Plains, New York November 23,2011 BLEAKLEY PLATT & SCHMIDT, LLP

By:

William H. Mulligan, Jr. ( 2945) Justin M. Gardner (JMG 6169) Attorneys for Plaintiff One North Lexington Avenue White Plains, New York 10601 (914) 949-2700

111

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
**__l"__r_____L-_r**~**-------------h*-+**-*----------------***-**

. . _ . ...
X

NEIL F.KEENAN, Individually and as Agent for THE DRAGON FAMILY, citizens of foreign states,

11I

.Plaintiff, AFFIDAVIT OF SERVICE
-againstDANIELE DAL BOSCO, a citizen of a foreign state, Et a . l

Defendants.
" I _

X

I, Edward M.Person, Jr., declare and state under penalty of pej
a.

Am over 18 years of age and not a party to this action.
On January 24,20 12, C h s b p h c r Strunk gave me instmct~ons personally serve a true conformed copy to

b. My place of business is located at 5342 C a k Road #I75 Sarasota Florida 34233. lr
c.

of the Sin&% Notice of Motion to Intervene with Supporting f i d a v i t Exhibits and Memorandum of
Caw with the Verified Supplement to the Complaint for the case Keenan et a1, v Bosco Er 01.. D M S
Case No.: 1-8500, for personal service upon Gancarlo Bruno and the World Economic Forum USA 201

Inc.

d. I placed one copy each in a brom envelope with the name and address of the Party with the notice
"Urgent Legal Sentice" printed in the lower left corner of the envelope and seating same.
e. OnJanuary24,2012,at 1:56PM-Ip~dlywenttoserveuponGian~loBrunoandtheWorld

Economic Forum USA Inc. at the 17th Floor of 3 East 54th Street New York New York where Rafaela
Caucasian 25 years old Brownish hair there for Recepti~n received service for Giancarlo Bruno and the

World Economic Forum USA Inc.

Dated: New York New York

January 24,2012

-

Edward M. erson, Jr. f

&71 :L

2

UNITED STATES DISTRIm COURT SOUTHERN DISTRICT OF NEW YORK
*-*---d-*--*------*-----------------------------------------------X

NEIL F. KEENAN, individually and as Agent for THE DRAGON FAMILY, citizens of foreign states,

I
-

Plaintiff,
'7

1 .

against-

DANIELE DAL BOSCO, a citizen of a foreip state, E d. t
Defendants.
---------d--p-----------*-------*-----------

-.

X

I, Edward M. Person, Jr., declare and state under penalty of perjury with 28 USC
I

a. A over 18 years of age and not a party to this action. m

b. M place of business is located at 5342 Clark Road #I75 Sarasota Florida 34233. y c. On January 24,2012, Chnstophcr Stmnk gavc me instructions to personally scrvc a true conformed copy
of the Sbmk's Notice of Motion to Intervene with Supporting Mdavit Exhibits and Memorandum of

I

Law dthe Verified Supplement to the Complaint for the case Keenan et al. v Bosco Ef at..,TDNY
Case No.:201 1-8500, for petsonal service upon H.E. Ambassador Marcello Spatafora Del Consoklato

G e n d e d'ltafia a New York for the Italian Government defendants..

d. T placed one copy each in a brmn envelope with the name and address ofthe Party with the notice
"Urgent Legal Set-vice" printed in the lower left corner of the envelope and sealing same.
e.

I

On January 24,2012,

at 1:40 PM - I personally went to serve upon HE. Ambassador Marcello

Spatafora Del Consolato Gende d'Italia a New York for the Italian Government defendarrts at the 690
Park Avenue New YorkNew York where xhe 55 year old heavyset man bald there fbr

WeptionlSecurity received service for the H E ,Ambassador Marcello Spatafora h Consolato 1
Generale d'ltdia a New York.

Dated: New Yo& New York January 24,20 12

b
I

-

--

UNITED STATES DISTRlCT COURT SOUTHERN DISTRICT OF NEW YORK
______L_r_____rr___------~------*----------------------m----------

X

I

NEIL F. KEENAN,Individually and as Agent for THE DRAGON FAMILY, citizens of foreign states,

11-CV-8500 W H ) [

AFFIDAVIT OF SERVICE
DANIELE DAL BOSCO, a citizen of a foreign state, Et al.

Defendants.
I -

- _ _ _ Y I I_ _ _ _ _ _ _ I _ C I _ _ I _ _ _ _ _

X

-

.--.

-

I, Edward M. Person, Jr., declare and state under penalty of perjury with 28 USC

'

a. Am over 18 years of age and not a party to this action.

b. My place of business is located at 5342 Clark Road #I75 Sarasota ~lorida 34233.
c.

On laouary 24,20 12, Christopher Strunk gave me imtmctions to personally serve a true conformed copy

ofthe Sfrunk's Notice of Motion to Intervene with Supporting *davit

Exhibits and Memorandum of Law wah the Verified Supplementto the Complaia for the case Keenan e a1 u Bosco Et nl.. t SDNY
Case No.: 1 1-8500, for persod service upon Consulate General of Switzerland. 20

d. I placed one copy each in a brown envelope with the name and address of the Party with the notice
"Urgent Legal Senice" printed in the lower leR comer of the envelope and sealing same.
e. On January 24,20 12. at 2:31 PM - I personally went to the Consulate General of Switzerland at the 3 0'

Flmr of 633 Third Avenue New York New York where Rafaela received service for the Consulate

General of Switzerland.
C

Dated: New York New Yerk January 24,2012

-

Edward M. Person, Jr.

:&*Lgg?g

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
1----*--*-"--__----------*--*-*-----------h+--+--*--*--"----------

X

PRO SE OFFICE
11-CV-8500 ] 3 H [R1)

NEIL F. KEENAN, Individually and as Agent for THE DRAGON FAMILY, citizens of foreign states,
Plaintiff,
-

AFFIDAVIT OF SERVICE - -

DANIELE DAL BOSCO, a citizen of a foreign state, E al. t
-a,-

Defendants.
- . . Y C I I - - - l l t t . I - I - - - l l l - . r " - I - - - - - - - - - 1 ~ . 1 - - . - - 1 1 -

...
X

- -

-

-r-

I, Edward M. Person, Jr., declare and state under penalty of perjury
d

17Y&

a.

Am over 18 years of age and not a party to this action.

b. My place of business is located at 5342 Clark Road #I75 S a r e t a Florida 34233.
c.

On Jamaary 24,2012, Christopher Stmnk gave me instructions to personally serve a true confumed copy
of the Summons and Complaint filed 11/23/20 11 for the case Keenan et al. v Basco Et a/..S D M Case

No.:2011-8500, for persod service by USPS certified return receipt upon Tbe Foreign Bondholders
Protective Council by John R..Petty the PtificipaI, Ban Ki-Moon Individually and as the Secretaq

General of the United Nations.

d. 1 placed one copy each in a brown envelope with ml y the name and address of the defendant with the
notice "Urgent Legal Service" printed in the lower left comer of the envelope and sealing same w t a ih
certified return receipt with return address of Christopher Stmnk and the USPS placed proper postage.
e.

On January 24,2012, at 5 : 00 PM - I personally went t the Church Street Station Post Office where o
each envelope was deposited with the USPS for senjce upon Partics nad or their counsel:

Bendholdefk Pidtkctive C o u d Inc, By J o h R. Petty Principal

Fo

1402 LAMGLEY PL MC LEAN, VA 22101-3010 Cert RR # 70111570000107000671

Ban Ki-moon individually and as Secretary General of the United nations United Nat~ons Head'quarters Room GA-1857 New York, New York 10017 Cert RR # 70111570000107000688

Dated: New York New York January 24,20 12

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
----------=*-------------*-m*-------------------------------------

NEIL F. KEENAN, Individually and as Agent for THE DRAGON FAMILY, citizens o foreign states, f

1f -CV-8500 1 -(

.Plainm,
AFFrnA

-againstDANIELE DAL BOSCO, a citizen of a foreign state, E d. t

Defendants.

...

-

.

.

I, Edward M. Person, Jr., declare and state under penalty of perjury with 28 USC WW r '7 5f.k
a. Am over 18 years a€age and not a party to this action.

+

w

b. M place of business is located at 5342 Clark Road #I75 Sarasotn Florida 34233. y
c.

On January 24,2012, Christopher Stnmk gave me instructions to personally serve a true conformed copy
of the Strunk's Notice of Motion to Intervene with Supporting Affjdavit Exhibits and Memorandum of Law with the Verified Supplement to the Complaint forthe case Keenan et al. v Bosco Et al..SDM Case No.:201 1-8500, for personal service by USPS cedfied r a m receipt upon The Foreign Bondholders Protective Council by John R.,Pettythe'hncipd. Ban Ki-Moon Individually and as the Secretary General of the United Nations and Neil F. Keenan by counsel William H. Mulligan of Bleakley
Platt & Schmidt LLP

d. 1placed one copy each in a brown envelope with only the name and address of the defendant with the
notice "Urgent Legal Service" printed in the lower lefi corner of the envelope and sealing same with a
certified return rcccipt &th rcturn addrcss of Christopher Stnrnk and the USPS placcd propcr postage .
e. On January 24,2012, at 5 : 00 PM - I p e r s d I y went to the Church Stred Station Post Wee where

m b envelope was deposited with the USPS for service upon Parties and or their counsel:
Foreign Bondholders Protective Council I c n,

By John R. Petty Principal
1402 LANGLEY PL MC LEAN, VA 221013010 Cert RR #7011157000010?000671

Ban Ki-moon idividuallya and as Secretary Generl
of the United nauons United Nations Headquarters . Room GA- 15 5 7 New York, New York 10017 Cert RR # 70t 1157000010700~88

William H, Mulligan Jr. fsq. Bleakley Matt &Schmidt LLP One North Lexington Avenue White Plalns NY 10601 Cert RR # 70111570000107000895

Dated: New York New York Jammy 24,2012

'

UNITED STATES DISTWCT COURT SOUTHERN DISTRICT OF NEW YORK
NEIL F. KEENAN,Individually and as Agent for
. .

THE DRAGON FAMILY, citizens of foreign states,
Plaintiff,
. r

AFFIDAVIT OF SERVICE
:F

.

I 8

I
DANlELE DAL BOSCO, a citizen of a foreign state, Et al.

Defendants.

- -

I I I

----

----

------ -----*

X

-

I, Edward M. Person, Jr., declare and state under penalty of perjury with 28 USC 1
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a. Am over 18 years of age and not a party to this action.

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b. My place of business is Iocated at 5342 CIark Road #I75 Sarasota Florida 34
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On January 24,2012, Chstophcr Strunk gave me instructions to penonally scrvc a true conformed copy
afthe Strunk's Notice of Motion to Intervene with Supporting Affidavit Exhibits and Memorandum of Law with the Verified Supplement to the Complaint for the case Keenan et a1. v Bosco Et a?. .SDM
Case No.: 1-8500, for personal service upon The Federal Reserve Bank of New York by Chairman / 201

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President Lee C.Bollinger.

d. T placed one copy each in a b
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m envelope with the name and address of the Party with the notice

"Urgent Legal Service" printed in the lower left corner of the envelope and sealing same.

O January 24,2012, at 4: I0 PM - I personally went to the Mailroom of Federal Resene Bank of New n York at 75 Libaty Street New York New York where M . r Press received service of Federal Reserve
Bank ofNew York by Chainnan I President Lee C. Bollinger.

Dated: New York New York Janua1y24.2012

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Edward M. Person, Jr..