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  1. On November 23, 2011, NEIL F. KEENAN (hereinafter, "KEENAN"), as agent and assignee of THE DRAGON FAMILY, through his attorneys, Bleakley Platt & Schmidt, LLP, filed civil suit against a number of high profile individuals for theft of assets (hereinafter referred to as the "Dragon Family Financial Instruments" or the "DFFI") that 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. Background Between 1927 and 1938, under arrangements made between T.V.Soong (Finance Minister of China) and Henry Morgethau, Secretary of the Treasury, The United States Government 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 the fear of China being overrun by the Japanese. The Kuomintang's gold and other precious metal deposits, which were 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. 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 that are an Obligation of the Federal Reserve System. 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 verification system and screening process. The 1934 Federal Reserve Notes 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 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. Recent History 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 th~ 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. July 9,2009, following a long period of emails between the two, Mr. Leo Zagami, a self-described 33rd degree Free Mason, who, as of April 2008, 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. 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. This was the exact amount that the United States Treasury 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 (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 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. 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. 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. 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. In July 2009, 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 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. 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." 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. 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. 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. 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. 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." 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. 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. 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. 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, 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. During the Vienna trip 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. 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. 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. 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. 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 FRN s and Kennedy Bond for potential use in a PPP. Wales gave the portfolio back to KEENAN, who then gave them to DAL 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.
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