Dragon Family $1 Trillion lawsuit

I know this is a lot of text but sections 5-10 give you a good idea of things. Sounds like the U.N. and others were trying to screw these guys out of 145 billion dollars worth of U.S. Treasury Bonds that were issued before the gold standard was abolished in 1934.Pretty wild story I have to read more about it.
1.
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. ) Civil Action No.
See Attached Schedule A )
Defendant
)
) JUDGE HOlWEll
SUMMONS IN A CIVIL ACTIONTo: (Defendants 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 youare 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
ofthe Federal Rules of Civil Procedure. The answer or motion must be
served on the plaintiff or plaintiffs attorney,whose name and address
are: William H. Mulligan, Jr. Bleakley
Platt & Schmidt, LLP One North
Lexington Avenue White Plains, NY 10601
(914) 949-2700You als~~~~ ~~!
~O~:S::;~~:~g:~~~~~~::~~~ :i~~~e entered aga~~:;::~~9:;e complaint.
~ ,~ODate: 1 f/22/2011
------------------- 2. AO 440 (Rev. 12/09) Summons in a Civil
Action (Page 2) 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 I personally served the
summons on the individual at (place)
on (date)
;or -------------------------------------------------
o I left the summons at the individuals residence or usual
place of abode with (name)
, a person of suitable age and discretion who res ides
there, ---------------------------------- on (date)
, and mailed a copy to the individuals last
known address; or ---------------- o
I served the summons on (name of individual)
,who is designated
by law to accept service of process on behalf of (name of organization)

on (date) ; or
------------------------------------------------- o I
returned the summons unexecuted because
; or 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:
Servers signature
Printed name and
title
Servers address Additional information regarding
attempted service, etc: 3. SCHEDULE A - DEFENDANTS1. DANIELE
DAL BOSCO2. THE OFFICE OF INTERNATIONAL TREASURY CONTROL3. RAY C.
DAM, individually, and as President ofOITC4. DAVID A. SALE,
individually, and as Deputy Chief of the Council for the Cabinet of
OITC6. THE UNITED NATIONS7. BAN KI-moon, individually, and as
Secretary General of the UN8. H.E. Ambassador CESARE MARIA RAGAGLINI,
Individually, and as Permanent Representative of the Italian
Mission to the UN in New York9. H.E. Ambassador LAURA MlRACHIAN,
Individually, and as Permanent Representative of the Italian
Mission to the UN in Geneva11. ITALIAN REPUBLIC12. ITALIAN FINANCIAL
POLICE13. SILVIO BERLUSCONI, Former Prime Minister of Italy14. THE
WORLD ECONOMIC FORUM15. WORLD ECONOMIC FORUM U.S.A., INC.16.
GIANCARLO BRUNO, individually, and as Head of the Banking Industry of
WEF 4. William H. Mulligan, Jr. (WM 2945)Justin M. Gardner (1M
6169)BLEAKLEY PLATT & SCHMIDT LLPOne North Lexington AvenueWhite
Plains, New York 10601(914) 949-2700 Tel.(914) 683-5956
Faxwmulligan@bpslaw.comAttorneys for PlaintiffUNITED STATES DISTRICT
COURTSOUTHERN DISTRICT OF NEW YORK
JUDGE HOLWELLNEIL F. KEENAN, Individually and as Agent forTHE DRAGON
FAMILY, citizens of foreign states, Index No. 11 Civ. _
( ) Plaintiff,
COMPLAINT -against-
Plaintiff Demands Trial By Jury
for All Applicable ClaimsDANIELE DAL BOSCO, a
citizen of a foreign state,THE OFFICE OF INTERNATIONAL TREASURYCONTROL, a
foreign corporation ("OITC"), RAY C.DAM ("DAM"), individually, and as
President of OITC,DAVID A. SALE ("SALE"), individually, and as
DeputyChief of the Council for the Cabinet of OITC, the UNITEDNATIONS,
BAN KI-moon, individually, and as SecretaryGeneral of the UN, H.E.
Ambassador CESARE MARIARAGAGLINI, Individually, and as
PermanentRepresentative of the Italian Mission to the UN in NewYork,
H.E. Ambassador LAURA MIRACHIAN,Individually, and as Permanent
Representative of the ItalianMission to the UN in Geneva, the ITALIAN
REPUBLIC,the ITALIAN FINANCIAL POLICE, Former PrimeMinister of Italy,
SILVIO BERLUSCONI, THE WORLDECONOMIC FORUM ("WEF") a foreign
corporation,WORLD ECONOMIC FORUM U.S.A., INC.,GIANCARLO BRUNO,
individually, and as Head of theBanking Industry of WEF, and various
unknown individualco-conspirators, JOHN DOES A-Z,
Defendants. 5. Plaintiff, NEIL F. KEENAN
(hereinafter, "KEENAN"), individually, and as agent andassignee of THE
DRAGON F AMILY, citizens of various foreign states, by and through
hisattorneys, 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 andinternational conspiracy
engaged in by the Defendants for the designed purpose of
defraudingplaintiff KEENAN, the designated Agent of his Principal, the
"Dragon Family," for the expresspurpose of expropriating, stealing and
converting certain negotiable financial instrumentslawfully 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 beenintended for participation in
select, registered and authorized Private Placement InvestmentPrograms
(or "PPPs") for the benefit of a wide range of global humanitarian
purposes. At thetime of the criminal and deceitful acts of the
Defendants, the approximate face value of thestolen DFFI was One Hundred
Forty-Five and One Half Billion ($145,500,000,000.00) UnitedStates
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
theDragon 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 6. each with a face value of $500 Million
($500,000,000.00) United StatesDollars in the total amount of One
Hundred Twenty-Four Billion Five-Hundred 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 Familys 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 7. (d) Upon
information and belief, following the promulgation in1934 of the Gold
Reserve Act, the law required all bullion goldand gold coin to be
surrendered to the Federal Reserve, a privatecorporation that is
chartered to operate as the Central Bank of theUnited States and the
issuer of the United States Dollar.(e) Upon information and belief,
domestically owned gold waspurchased. Foreign Gold held by the Treasury
was alsosurrendered to and thus leased to the Federal Reserve,
whichresulted in the issuance of the series of 1934 Notes by the
FederalReserve. These Dragon Family FRNs have never been redeemedand,
upon information and belief, the accrued interest was met bythe
subsequent issue of certain 1968 series of Kennedy Bonds (see~ 2
(iii), infra) and later further issues of the 1934 series FRNswhich,
upon information and belief, were issued through the periodof the
Chinese civil war to assist Kuomintang operations in Chinaand later in
Burma. These 1934 FRNs guarantee the leasepayments and helped to allow
the Chinese Government to continuefinancially. KEENAN has no personal
knowledge as to whetherthe FRN s with which he was entrusted were
original orsubsequently issued Notes.(f) Upon information and
belief, this gold was documentedinto accounts through the Union Bank of
Switzerland, placed underprotection of the Swiss Attorney General,
registered through the 4 8. Swiss
National Bank:into the Bank for International Settlements("BIS")
International Collateral Combined accounts and then fromwithin the BIS,
blocked to form the Institutional ParentRegistration Accounts of the
Federal Reserve System.(g) Upon information and belief, and in
accordance withprocedures that would be expected to occur in the event
the NoteHolder of record wished to redeem it, the Holder would do so
byfirst remitting the number of the Note to the Federal Reserve with
amajor project or a list of projects for approval. Once the projectshave
been approved, the Note would be recognized and theF edsystem would
then make arrangements for the Note to bedeposited into a bank which
would provide a specific credit line,perhaps of30% up to 80% of the face
value. The Fedsystemwould then provide immunity to the Holder to
present the Note at aspecific Bank where a Credit Line has been
pre-arranged.Attempting to present these Notes outside this system will
see thenote arbitrarily denied and the illegal presenter
incarcerated.(h) Upon information and belief, in order to effectuate
thisprocess, the Notes were printed to appear as if they were
notproduced from official origin and bear obvious
imperfections,therefore easily deniable. However, when proper procedures
arefollowed, the number of the Note and other linking identic
dataallows ultimate authentication and verification through the Federal
5 9. 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. A1306
(construction bond) and A 1310 (the "Japanese Bonds"), which wereissued
on April 30, 1983 by the Ministry of Finance, Government ofJapan, 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, theseJapanese Bonds
are but two (2) of Five Hundred (500) such Bonds ownedby the Dragon
Family, each having the same face value, according to astatement of
Yamaguchi dated April 20, 2009 concerning the BondHistory 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 10.
communications witIi Yamaguchi including the representationsmade by
Yamaguchi in various documents he has executed overthe years in
connection with his attempts on behalf of the DragonFamily to place
various Kennedy Bonds into legitimate PPPs infurtherance of their
objective to provide humanitarian globalassistance when and where
needed.(b) In a sworn statement by Yamaguchi, dated August
4,2010,entitled "Kennedy Bond History," and which relates to the
detailsof ten (l0) other Kennedy Bonds, virtually identical to
thatentrusted to KEENAN in May 2009 except for the registrationnumbers,
Yamaguchi stated that the "US government borrowedhuge amount funds from
the Dragon Family many years ago. Thebase of the lent funds from the
Dragon Family to the USGovernment were the Gold and Silver. Therefore
the USgovernment was able to issue huge USD as currencies via FRBthen."
Yamaguchi proceeded to state: "We, the Dragon Family,requested some
interest to the US Government on 1998 by use ofsome
securities/certificates got expired as same as the 57th SeriesJapanese
Government Bonds. And, we have received the KennedyBonds, issued in
1998, as one of the interest payments from the USGovernment. I recognize
as my position that the Kennedy Bondswere issued by the US Government
as the interest only for theDragon Family." 7 11.
(c) Upon information and belief, the Kennedy Bonds representa series
of notes printed for the purpose of creating a settlementfund for the
gold and other precious metals transferred to theUnited States under the
terms of the Green Hilton MemorialAgreement (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 entrustedwith the care of the gold. Upon information and belief,
theseBonds were originally issued in 1968 by way of speciallydenominated
1968 Kennedy Bonds, "Z" series. These bonds werenot commercially
negotiable, or cashable, but were redeemablethrough the Federal Reserve
System in what was intended to be aneffective, beneficial, and
well-aimed program that was intended forbetter global development.
President Soekarno was deposed in1967 by General Suharto, thus
disrupting the entire programcausing a failure to institute the planned
development programintended for Indonesia and the Asian region.(d)
Upon information and belief, few, if any, of the 1968Kennedy Bonds had
been used within the original 30 year period, afact to which Yamaguchi
may have been referring in his abovestatement. Thus, theoretically, the
gold that had been lent by theDragon Family had not been paid for and
therefore had not fullytransferred to the Federal System. Upon
information and belief, 8 12. 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 beenentrusted to KEENAN in early 2009 by the
Dragon Family. Months thereafter, in September2009, KEENAN was
fraudulently induced through the conspiratorial actions and schemes of
theDefendants to transfer and entrust the DFFI for temporary safekeeping
and custodianship todefendant Daniele DAL BOSCO (hereinafter, "DAL
BOSCO"). 4. Thereafter, unbeknownst to KEENAN, DAL BOSCO, in a
malevolent, consciousand concerted scheme and enterprise of staggering
proportions, plotted and conspired with theother Defendants in a variety
of ways to defraud KEENAN and to convert the DFFI for theirown personal
financial gain and to the complete financial detriment of KEENAN and
the DragonFamily, as described in more detail throughout the Complaint
below. 5. In summary, this conspiracy included: (a) the
expropriation, stealth andconversion by DAL BOSCO of the very same DFFI
with which he had been temporarilyentrusted; (b) the repeated and
unsuccessful attempts to bribe KEENAN in the total amount ofOne Hundred
Million ($100,000,000.00) Dollars (half of which was to be kept by
DALBOSCO), in an effort to obtain KEENANs consent to release the DFFI to
others withoutdisclosing such theft to the rightful owners of the DFFI,
the Dragon Family; (c) a plan wherebythe DFFI would be converted and
placed into a so-called "UN Sovereign Program" wholly under
9 13. the auspices, protection
and umbrella of the: "sovereign immunity" allegedly accorded to
thedefendants by the actions of certain of the defendants, including the
UNITED NATIONS and theITALIAN REPUBLIC; (d) the execution of a written
agreement between DAL BOSCO anddefendants OITC and SALE, with the full
knowledge and authority of DAM, whereby DALBOSCO openly repudiated his
duties as custodian of the DFFI; (e) the issuance of an illegal
andutterly baseless Cease and Desist Order under which OITC asserted the
thoroughly andknowingly false proposition that the DFFI was, in fact,
in the lawful possession of OITC, whichhas acted for decades with
impunity and under the asserted umbrella of protection allegedlyaccorded
by the UNITED NATIONS; (f) the longstanding and unlawful complicity of
theUNITED NATIONS in allowing the blatantly false, but to date,
unremedied representation to theworld at large by OITC that it was
organized under a non-confirmable and apparently non-existent UN Charter
Code provision; (g) the unlawful, concerted and malicious attempt,
throughthe actions of various of the defendants to utilize not only the
stolen DFFI, which are the focalpoint of this matter, but also numerous
various other financial instruments either stolen or seizedunder color
of police authority of the ITALIAN FINANCIAL. POLICE or obtained by
others, topurchase Banca Commerciale di Lugano, Lugano CH (Switzerland),
or some other Swissregistered bank into which they could deposit stolen
assets, and to capitalize the banks assetswith profits obtained from
such actions. Upon information and belief, such bank capitalizationwas
to include yet another approximately One-Hundred Thirty-Four Billion,
Five-HundredMillion Dollars ($134,500,000,000.00) Dollars of financial
instruments also owned by theDragon Family, including FRNs and Kennedy
Bonds virtually identical to the DFFI, which wereseized on the
Italian/Swiss border in June 2009. (See ~~ 63-69 supra, "The Chiasso
Incident"). 10 14.
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
ImmunitiesAct (hereinafter "FSIA"), 28 U.S.C. § 1603(a), namely
defendants the ITALIAN REPUBLICand the ITALIAN FINANCIAL POLICE, which
defendants are not entitled to immunity eitherunder 28 U.S.C. §§
1605-1607 or under any applicable international agreement.
Specifically,defendants the ITALIAN REPUBLIC and the ITALIAN FINANCIAL
POLICE and their agentsacting on their behalf with actual authority,
while actively participating in the conspiracy todefraud KEENAN and
convert the DFFI, engaged in inherently commercial activities when
saiddefendants and their agents attempted to bribe KEENAN in the total
amount of One HundredMillion ($100,000,000.00) Dollars for the purpose
of obtaining the DFFI, from KEENAN, fortheir own personal profit by and
through the investment of the DFFI in a United NationsSovereign Program
largely through actions taken in New York, New York. Said
commercialactivity 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 obligati~n of the U.S. Federal ReserveSystem, and
in order to negotiate said financial instruments, the holder of these
instruments mustwork directly with the U.S. Federal Reserve System to
have the instruments verified beforeanticipated placement into an
approved PPP. Additionally, and upon information and belief, theactions
of the said defendants and their agents, as described in more detail
below, constitute anexpropriation of the DFFI in clear violation of
international law, and said DFFI are currently heldby 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 15. uniquely federal interests. Specifically, this action
involves an international conspiracy todefraud KEENAN and convert (i)
Two-Hundred Forty-nine (249) United States 1934 SeriesFederal Reserve
Notes each with a face value of $500 Million ($500,000,000.00) United
StatesDollars in the total amount of One Hundred Twenty-Four Billion
Five-Hundred Million UnitedStates Dollars and (ii) One (1) United States
Kennedy Bond with a face value of One (1) BillionUnited States Dollars,
bearing registration number APII 024068 A issued by the U.S.
FederalReserve and/or the U.S. Treasury Department to the Dragon Family
in exchange for the DragonFamilys 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 internationalcriminal conspiracy involving a sovereign
nation and international organizations as co-conspirators, including the
ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE,BERLUSCONI, BRUNO, the
UNITED NATIONS and the WORLD ECONOMIC FORUM,implicates the Dragon
Familys right to be compensated for the gold and precious metal
depositsit made into the Federal Reserve System pursuant to the original
agreements between the UnitedStates and the Dragon Family, as well as
KEENANs rights as Agent of the Dragon Family toplace the DFFI into the
PPPS intended and to be compensated in accordance with his own rightsas
such Agent. Alternatively, the conspiracy implicates the Dragon Family
and its AgentKEENANs right to the return of the gold and precious metal
deposits with interest-a rightwhich clearly implicates the uniquely
federal interest of the United States in the U.S. FederalReserve System,
the federally chartered central banking system of the United States.
Becausethis action involves issues that are of such a peculiarly federal
concern, namely the obligations ofthe federally chartered central
banking system of the United States, the underwriting support of
12 16. the U.S. Dollar
and its continued viability as the global reserve currency, this action
is governedby federal common law. 8. The Court also has
jurisdiction over any remaining claims under principles ofsupplemental
jurisdiction as such claims "are so related to claims in the action
within suchoriginal 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 partof the events or
omissions giving rise to the claims occurred, or, upon information and
belief, asubstantial part of the property that is the subject of the
action is situated in this district, andunder 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 theWORLD
ECONOMIC FORUM USA, INC. (hereinafter "WEF USA") are in the district.
Venueis 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 TREASURYCONTROL (hereinafter, "OITC"), RAY C.
DAM (hereinafter "DAM"), DAVID A. SALE(hereinafter "SALE"), the WORLD
ECONOMIC FORUM (hereinafter "WEF") and SILVIOBERLUSCONI (hereinafter
"BERLUSCONI"), the former Prime Minister of Italy, and as suchmay 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, namGlydefendants the ITALIAN
REPUBLIC (hereinafter "ITALY") and the ITALIAN FINANCIALPOLICE, and a
substantial part of the events or omissions giving rise to the claims
occurred, or, 13 17.
upon infonnation and belief, a substantial p~ of property that is the
subj ect of the action issituated in this district.
PARTIESThe Plaintiff Neil Francis Keenan
10. At all relevant times, plaintiff KEENAN was an individual
citizen of the UnitedStates, who currently is a resident of Bulgaria.
KEENAN was introduced to Yamaguchi and theDragon Family in or about
August 2008 in connection with their efforts to place certain
JapaneseBonds and Kennedy Bonds into a PPP after proper Bank
verification. KEENAN acted as anintennediary in introducing the Dragon
Family to th~ Alpha Bank, located in Cyprus, for whichYamaguchi
expressed great appreciation. On account of the assistance and political
connectionsKEENAN provided at that time, Yamaguchi persistently sought
out KEENAN to provide directservices on his behalf related to
international banking and trading transactions in furtherance ofDragon
Family humanitarian programs. KEENAN eventually agreed to accept
theresponsibilities attendant to representing the Dragon Family in
numerous transactions in theworld 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,
Yamaguchiexecuted 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 DragonFamily, for the
private placement of or legal return of the DFFI "which were stolen by
DanieleDal Bosco (and others) from you," effectively assigning any cause
of action which the DragonFamily might possess as the legal holder of
the DFFI. Any such causes of action would be inaddition to KEENANs
personal and representative claims as the Dragon Familys designated
14 18. Agent
under his Special Powers of Attorney, as the victim of the theft and
conversion of theDFFI by DAL BOSCO and the various and sundry other
conspiratorial and illegal actions of theother defendants. 12.
This Special Power of Attorney explicitly superseded and extended prior
Powersof Attorney granted to KEENAN by which KEENAN was authorized to
coordinate with theappropriate programs in the United States, Asia and
Europe for investment purposes utilizing theDFFI as collateral. In
addition to the wide range of responsibilities granted to
KEENANregarding the negotiation of the DFFI and their investment in
proper PPPs in a fully securedinvestment facility, KEENAN, "and only"
KEENAN, was specifically authorized to determinewhat 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 ofthe litigation and determine "what to do with
any proceeds from any outcome" as "the bondswere stolen from you and you
are financing their retrieval and you are taking all the risks."
Ineffect, Yamaguchi assigned to KEENAN any and all causes of action he
or the Dragon Familymay have in seeking the recovery of the DFFI or
damages arising from their theft "as the legalholder" of the DFFI.
KEENAN was placed "solely in control over the legal recovery of
saidbonds and all aspects of it."Keenans Disclosed Principal- the Dragon
Family 13. Upon information and belief, the 1934 FRNs
described, supra, at ~ 2 (i), cameunder the control of the Kuomintang
from whom the gold was received in return for the leasepayments, 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 19. moved much of the FRNs (but
not all) to Taiwan, which allowed for the development of andserved as
the basis for the underlying wealth of Taiwan. The FRNs were good for
value as theywere backed by the gold and other precious metals purchased
and leased by the United Statesgovernment. 14. Upon
information and belief, the Kuomintang appointed guardians of this
Goldand the securities issued by the United States who came to be known
euphemistically as theDragon Family. The Dragon Family is, in fact, a
highly secretive and informal organization thatoperates between old
families within China and Taiwan, above the political divide of the
twoindependent Chinese Governments. The Dragon Family abstains from
public view andknowledge, but, upon information and belief, acts for the
good and better benefit of the World inconstant coordination with
higher levels of Global Financial Organizations, in particular,
theFederal Reserve System. During the course of its existence over the
last century, the DragonFamily has accumulated great wealth by having
provided the Federal Reserve Bank and theUnited States Government with
asset assignments of gold and silver via certain accounts held
inSwitzerland, for which it has received consideration in the form of a
variety of Notes, Bonds andCertificates 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
ofTrillions of United States Dollars, a relatively small portion of
which is involved in the claimsgiving rise to this action. Each of these
currencies, such as the DFFI involved in this action, wasand remains
duly registered within the Federal Reserve System and are directly
verifiable by theFederal Reserve through its efficient verification
system and screening process.
16 [*]20. THE DEFENDANTSDaniele Dal Bosco 15.
Defendant DAL BOSCO is an individual who, upon information and belief,
hasmultiple 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 telephonecommunication 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, hasacted in concert and conspired with
Defendant THE OFFICE OF INTERNATIONALTREASURY CONTROL (hereinafter
"OITC"). Upon information and belief, OITC has itsprincipal offices in
Singapore and Cambodia, although according to a document OITC producedin
March 2006, it has offices in Malaysia, the Netherlands, the United
States, Australia andEcuador. According to its own website,
[www.unoitc.orgJ, OITC has a "Due Diligence DivisionOnly" office located
in Washington D.C., and claims to be "an International Financial
InstitutionChartered under the United Nations Charter Control No:
10-60847." 17. Further, OITC identifies itself as a "Sovereign
Entity in its own right, as institutedby the Nations of the World and
as provided for under The Treaty of Paris 1886." It claims tohave
"substantial assets in its control." OITC spokesmen have claimed that
the organization hasbeen chartered by the United Nations under a secret
protocol and that it was established as the
17 [/*]21. Office of His Excellency Dr. Ray C.
Dam, changing its name to the Office of InternationalTreasury Control in
2003. 18. In the "General Overview" of its History, provided
on the website, OITC tracesits roots to The Trilateral Trillenium
Tripartite Gold Commission ("TTTGC") purportedlyorganized in 1944/5 for a
term of fifty (50) years. OITC represents that during this term,
theTTTGC held the "Mandate, Rights and Authorities over the Combined
International CollateralAccounts 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
CollateralAccounts had been utilized within the 50 Years, agreed not to
extend the term of the TTTGC, butinstead appointed a single independent
person to the position of International Treasury Controllerwith full
rights, authority, and legal ownership of the Combined International
CollateralAccounts. 19. Further, according to the OITC
website, on January 20, 1995, defendant Dr. RayC. Dam (hereinafter,
"DAM") was "appointed International Treasury Controller, and Legal
Heirand Owner of the Combined International Collateral Accounts of the
Global Debt Facility, withfull authority and dispositional control of
same, under Legal Decadency RCD 1088, executed bythe Nations of the
World." Also purportedly established on January 20, 1995, was "The
Officeof International Treasury Control, as the management,
administrative and operationsorganization for His Excellency, Dr. Ray C.
Dam," who claimed to be the authorizedInternational Treasury
Controller. 20. Defendant DAM is an individual and, upon
information and belief, is generallybelieved to be a native of Cambodia,
although he is also a United States citizen bearing UnitedStates
passport number 467832299. Upon information and belief, DAMs real name
is Amijan 18 22.
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 indemnifiedInternational Central Banking financial
institution operating as The Office of InternationalTreasury Control."
Further, as reported on the website, following the confirmation of his
Powersand 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
wasgranted "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 informationand belief, the University
has no record of conferring a degree upon DAM. 21. Defendant
David A. Sale (hereinafter, "SALE") is an individual citizen of
theUnited Kingdom who holds himself out as "Deputy Chief of the Council
of the Cabinet" ofOITC 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, TheOffice of
International Treasury Control, UN Charter Contro1.No: 10-60847." Upon
informationand belief, SALE lived and worked from a small apartment in a
low cost community inKumpawapi, Udon Thani Province in Thailand and is
not known to have ever met with DAMpersonally, in their entire eight
years of association. 22. According to its website, OITC
"though not generally or publicly known ... isthe largest International
Institution of its kind" and "the largest single owner of gold
andplatinum 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 ofthe Combined
International Collateral Accounts of the Global Debt Facility, whose
accounts are 19 23.
held within the Federal Reserve, The Bank for International
Settlements, The US Treasury,Swiss National Bank, Swiss Federal Finance
Administration." Further, as represented on itswebsite, since being
established, the OITC has become the largest single owner of
HomeMortgage Securities in the World today, and "Original assets in the
form of gold have beenwisely and well utilized to create wealth that
creates future wealth." 23. Upon information and belief,
contrary to the representations of OITC, the UnitedStates Government has
stated that "within the Federal Reserve, there exists no organization
ordepartment with the initials OITC, nor anything similar to this."
Additionally, the aforesaidBank for International Settlements ("BIS") -
an international organization representing centralbanks - has also
denied any knowledge of the OITC. The BIS was established in 1930, and
hasits principal office located in Basel, Switzerland with two
representative offices in the HongKong Special Administrative Region of
the Peoples Republic of China and in Mexico City. TheBIS is reportedly
tl1e worlds oldest international financial organization whose customers
arecentral banks and international organizations. BIS does not accept
deposits from, nor providefinancial services to, private individuals or
corporate entities .. According to its website, BISexists to "foster
international monetary and financial cooperation and serves as a bank
for centralbanks." Further, according to OITCs website, OITC claims
sovereignty over the InstitutionalParent Registration Accounts 984
52700845-34-18 within the Federal Reserve System. 24. Upon
information and belief, the OITC has declined to publish any
independentverification of its status, claiming that only individuals
with a "level 3" to "level 5" securityclassification can see "its
protocol for verification," which in tum, "can only be undertaken by
asenior member of the Government or the Reserve Bank." Further, the UN
is allegedly "legallybound to respond to a verification request on the
condition that the requisite controls and
20 24. procedures are followed or no response
will be received from the United Nations." Further, theonly way a
verification request can be made is "through the UN headquarters in New
York orGeneva, not via, or by, any sub-office of the UN." 25.
Upon information and belief, the UN has been complicit in the
nefarious activitiesof OITC in that it has never formally denounced or
disassociated itself from OITC, and hasallowed OITC to hold itself out
to the world community as protected by its umbrella oflegitimacy and
chartered by the UN itself. It was reported as recently as August 10,
2010 on theinternet 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 Magazinefrom 1998 until
2005, that "The UN never, until the current investigation! began, denied
itsaffiliation 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
aseries of bizarre scandals in multiple countries, holding the men on
suspicion of large-scale fraudand forgery." Included in the group was
"Ray C. Dam, the chairman of ARP-OITC Group CoLtd." This followed an
October report in the same newspaper that examined the "Office
ofInternational Treasury Control," of which ARP-OITC is a subsidiary,
and questioned the groupsalleged 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 roughly1 See
discussion of "The Chiasso Incident", infra, at ~~ 63-69.
21 25. $500
million." Subsequent news reports confirmed the charges by the Phnom
Penh MunicipalCourt on December 20, 2010 and noted the prior Post
reports that OITC officials had "previouslybeen 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 aimsare facilitating cooperation
in international law, international security, economic
development,social progress, human rights, and achievement of world
peace. It was founded in 1945 afterWorld War II to replace the League of
Nations, and its main headquarters are located oninternational
territory in New York, New York. Upon information and belief, at all
relevanttimes referenced in this complaint, defendant UN and others,
including any officials acting on itsbehalf, were acting outside the
scope of their official capacities and are accorded no immunityfor such
actions. 28. Defendant BAN KI-moon is a native of South Korea,
was the Foreign Minister ofthe Republic of Korea from January 2004 to
November 2006 and was elected in October 2006 tobe, and currently is the
eighth Secretary-General of the United Nations. 29. Defendant
H.E. Ambassador Cesare Maria RAGAGLINI is the PermanentRepresentative
of the Italian Mission to the UN in New York, New York, and maintains
aresidence in New York, New York. 30. Defendant H.E.
Ambassador Laura MIRACHIAN is the PermanentRepresentative 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 foundingmember of what is now
known as the European Union. It is a member of NATO and is a
22 26. member state of defendant
UNITED NATIONS. Defendant SILVIO BERLUSCONI hasrecently resigned as the
Prime Minister of the ITALIAN REPUBLIC. Upon information andbelief,
BERLUSCONI has been a central figure in the plot and scheme to utilize
seized or stolenfinancial instruments belonging to the Dragon Family for
his own personal financial gain andprofit 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 Ministerof Economy and Finance of the ITALIAN
REPUBLIC and ultimately, at all relevant timesherein, acted under the
authority of defendant BERLUSCONI. It is a part of the Italian
ArmedForces and is essentially responsible for dealing with financial
crime and smuggling. Itsactivities are financial, economic, judiciary
and public safety and, among other things under itsjurisdiction are
smuggling, money laundering, customs and border checks, and political
andmilitary 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, selectedintellectuals and journalists
to discuss the most pressing issues facing the world, including
healthand the environment. The WEF was founded in 1971 by Klaus Martin
Schwab, a German-bornbusiness professor at the University of Geneva. It
was originally named the EuropeanManagement Forum, but changed to its
present name in 1987 and sought to broaden its visionfurther to include
providing a platform for resolving international conflicts.
23 27. 34. The WEF is
headquartered it Cologny, Switzerland, near Geneva. In 2006 itopened
affiliate offices in Beijing, China and New York, New York. The WEF
purports to striveto be impartial, and is not tied to any political,
partisan or national interests. In 2009, it openedan office in Tokyo,
Japan. It is committed to improving the State of the World and has
observerstatus with the United Nations Economic and Social Council, and
is under the supervision of theSwiss 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 andItaly and at all pertinent times has served as
Director responsible for the Financial ServicesIndustry Group of the WEF
in its New York City offices at the WORLD ECONOMIC FORUMUSA, Inc.
(hereinafter "WEF USA"), which is the WEF affiliate incorporated in
Delaware, aforeign not for profit corporation authorized to do business
in the State of New York overseeingthe development and content and the
relationships with the WEFs partner companies in theBanking, Insurance
and Asset Management sectors. Prior to joining the WEF, BRUNO
hadextensive experience in banking and corporate finance. He also had
working experience withdefendant UN, at the United Nations Industrial
Development Organization ("UNIDO"), wherehe carried out research
responsibilities in the field of comparative development with
theGovernments Funds Unit of the Mobilization and Management of
Financial Resources Division.BRUNO is also a member of the Democratic
Party Constituent Assembly, Italy. BRUNO hasacted as a central figure in
concert with other defendants, including principally DAL BOSCO,the
UNITED NATIONS, the ITALIAN REPUBLIC, the ITALIAN FINANCIAL POLICE
andBERLUSCONI in seeking to bribe KEENAN to release the DFFI with which
DAL BOSCO hadbeen entrusted, in order that defendants, including BRUNO,
could profit illegally from both the
24 28. possession and illegal marketing of the
DFFI. Upon information and belief, BRUNOs actionstook place principally
in New York, New York, and involved the use of international
telephonecommunications. 36. Defendants JOHN DOES are
individuals or organizations who may have acted inconcert with any or
all of the named defendants herein and may be liable to plaintiff for
thedamages suffered by him. PERTINENT FACTUAL BACKGROUND
INFORMATION COMMON TO ALL CAUSES OF ACTIONA.
Keenan and the Dragon Family 37. The aforesaid Akihiko
Yamaguchi is a Japanese citizen who was born inDecember 1954 and who, in
approximately 1986, at the age of thirty-two (32), through
hisinternational trade business in Taiwan, was introduced to Mr. Sei
Sasaki, who had devotedalmost forty (40) years of his life and enjoyed a
brotherly relationship with a person at thehighest levels of the Dragon
Family. Yamaguchi was considered a "son" by Mr. Sasaki, and hewas
ultimately introduced to the Head of the Dragon Family, General Haan,
who, together withother high level members of the Dragon Family,
educated him over the years about theaccumulation and ownership of the
assets held and controlled by the Dragon Family. Upon theirmeeting,
Yamaguchi was appointed a formal member of the Dragon Family by the top
person inthe Organization, and thereafter began to devote his entire
professional career to the DragonFamily from the time he was 35 years
old until the present. Mr. Sasaki died when Yamaguchiwas 40 years old.
38. Eventually, Yamaguchi became a legal signatory and
Controller of the DragonFamily Organization, with full signing authority
to enter into all transactions relating to Dragon
25 29. Family Assets and Financial
Instruments, irlcluding cash, Private TradinglInvestment Programswith
the leading financial institutions throughout the world such as UBS,
Bank of Japan and theFederal 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 theseveral
factions or sects of the Dragon Family, in the last decade the
Organization hasundertaken to attempt to contribute significant Billions
of United States Dollars for the purposeof aiding numerous global
humanitarian purposes, such as relief aid during natural disasters
tocountries throughout the world, including Hurricane Katrina in the
United States, earthquakes inHaiti, China and Indonesia, the Grenoble
nuclear disaster, rebuilding the Republic of Georgiasinfrastructure,
water and energy supply for the Cayman Islands, Bangladesh and more.B.
The Grant and Execution of Plaintiff Keenans Special Powers of
Attorney Relating to the DFFI 40. Ultimately, KEENAN was
authorized to negotiate the final details and executeand enter into a
cash enhancement andlor project funding transaction relating to the
PrivatePlacement of the DFFI. This was to be accomplished, in the case
of the Federal Reserve Notesand Kennedy Bond, after verification by the
United States Federal Reserve Bank or TreasuryDepartment, 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 Familyto utilize the assets
placed in the various Programs for global humanitarian purposes.
1. The 1934 United States Federal Reserve Notes 41. Among
the assets accumulated by the Dragon Family are the
above-describedFederal Reserve Notes ("the Federal Reserve Notes" or
"FRNs") which were collected by
26 30. Yamaguchi from Mr. Sasaki and the Dragort Family
for use for any world economic aid andhumanitarian projects. On October
5, 2008, Yamaguchi declared in writing that he desired to usethe Notes
for any appropriate humanitarian investment program immediately by use
of hiswritten authority and power as signatory of the Dragon Family.
42. KEENAN was authorized by Yamaguchi to coordinate the
investment of249 ofthese 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 MillionUnited
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 FederalReserve Notes, KEENAN was to
receive at least 30 % of any profit sharing from the particularPPP,
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
onFebruary 20, 2009, which had a six month term, KEENAN was granted a
Special Power ofAttorney in a writing executed by Yamaguchi to act on
Yamaguchis behalf for the coordinationof investing certain assets of the
Dragon Family, to wit, the above-referenced two (2) 57 SeriesJapanese
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 theirJapanese Trustee Five-Hundred (500) 5ih
Series Japanese Government Bonds which had beenissued largely based upon
Dragon Family Funds for future use in world economic aid
andhumanitarian projects. After the deaths of Messrs Mitsuzaka and
Obuchi, the Trustee delivered
27 31. many of these Japanese Bonds, including thb aforesaid
two (2) Japanese Bonds, to one ofYamaguchis foundation associates, who
was well aware of their history. Thereafter, many ofthese Japanese Bonds
were returned to Yamaguchi to be utilized for any
appropriatehumanitarian investment program under his authority and power
as authorized signatory of theDragon 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 toobtain
validation of the bonds from the Bank of Japan or Mizuho Bank, as
attested to byYamaguchi on or about February 20,2009. 46. By
the explicit terms of the Power of Attorney, Yamaguchi appointed
KEENANto act on his behalf for the coordination of the Japanese Bonds
for investment with theappropriate parties in the United States, Asia
and Europe in legally registered and charteredtrading 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 andterms he deemed proper and was further
authorized to utilize Yamaguchis bank account in hisown designating
banks and to sign any Private Program contract as Yamaguchis
agent.KEENAN was authorized as attorney-in-fact for authentication and
due-diligence of theJapanese Bonds through KEENANs bank to the Bank of
Japan by using the two certified copyJapanese Bonds including any and
all of the documents showing Yamaguchis endorsements onthe reverse side
of those Bonds. 47. F or the services he was to provide in
connection with the placement of theJapanese Bonds, KEENAN was to
receive 30% of any net profit from the particular PPP.
28 32. 3. The Kennedy Bond
48. KEENAN was also authorized by Mr. Yamaguchi to coordinate
the investment ofthe one (l) Kennedy Bond entrusted to him with a face
value of One (l) Billion United StatesDollars. As attested to by
Yamaguchi in his statement of the Kennedy Bond History datedSeptember
6,2008, the Kennedy Bond is good, clean, clear and free from any liens
andencumbrances. 49. For the services he was to provide in
connection with the placement of theKennedy Bond, KEENAN was to receive
at least 30% of any profit sharing from the placementof the bond in a
part~cular PPP for investment into infrastructural and economic
developmentprojects. 50. KEENAN personally accepted the
custodianship and income rights therefromaccorded to him in accepting
responsibility for investment of the Federal Reserve Notes onJanuary 22,
2009 in Zurich, Switzerland. He took possession of the Japanese Bonds
andKennedy Bond on May 5, 2009, at which time he acknowledged in writing
the receipt of all ofthese instruments which comprise the DFFI. KEENAN
remains the only legal custodian of theDFFI 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 KEENANs connections inEurope,
and with additional Dragon Family financial instruments, began to
approach variousinternational Governments, which were either in need of
humanitarian aid or had provided theDragon Family with assistance in the
past. In tum, KEENAN proceeded to select individualswhom he knew and
trusted to assist him in either finding or establishing a suitable PPP,
or towork with the principals who would be involved in obtaining proper
verification of the DFFI, 29
33. 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 anoutright loan transaction
would be sought. During the spring of 2009, KEENAN was very activeon
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 Familythrough the Turkish
Groups supposed traders in Zurich. During the course of the
ensuingmeetings and negotiations, Yamaguchi was present at various times
when KEENAN woulddisplay, upon request, certain Dragon Family financial
instruments, which notably included thevery same 2 Japanese Bonds, Nos.
A 1306 and A1310, and the same Kennedy Bond, whichcomprise a portion of
the DFFI that are the focus of this lawsuit. 53. During this
period of time, KEENAN and Yamaguchi were welcomed andentertained in
Zurich not only by several legitimate traders, lawyers and Bank
representatives,eager to do business with the Dragon Family and
Yamaguchi as the FamilyS authorizedsignatory. At one meeting with Bank
Julius Baer & Co. Ltd. ("Julius Baer"), attended byKEENAN, Mr. Benny
Guttman, Executive Director, went immediately to Yamaguchi and toldhim
that he had been waiting a long time to meet him. Guttman hosted an
elaborate buffetluncheon in honor of Yamaguchi. After discussions among
the group, Guttman asked to reviewthe DFFI which Yamaguchi had with him.
After looking at the instruments, Guttman asked if hecould 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 wasaware that security was present and that in the
event of any determination that the DFFI were not
30 34. genuine, he and Yamaguchi were
subject to:immediate incarceration. This was consistent withthe
expectation that The Bank selected by Yamaguchi was expected to act
accordingly so thatproper verification of the DFFI would be achieved.
Only licensed financial traders would beconsidered to act with respect
to the DFFI. However, KEENAN and Yamaguchi were alsointroduced to many
individuals who were mere "brokers" who, as it happened, sought to
takeadvantage of their exposure to the opportunities presented by the
introduction to the DragonFamily and its significant assets. 54.
In connection with these various meetings and myriad other meetings
with severalpeople holding themselves out as traders and Banking
representatives, particularly individualsconnected with the Turkish
Group, KEENAN and Yamaguchi were led to believe that allnecessary
arrangements and Bank verifications had been made in order to establish a
PPPthrough a Credit Suisse branch in Alstatten, Switzerland. On or
about May 18,2009, Yamaguchiaccurately confirmed to Credit Suisse
through Assistant Vice President Andre Weishaupt that the2 Japanese
Bonds were cash backed instruments of the Dragon Family under his name.
Herepresented that the bonds had a total value of $19 billion U.S.
dollars, free of liens andencumbrances. He also requested a Safekeeping
Receipt of the bonds that had been deposited onor about May 15,2009,
pending verification from The Bank of Japan and the U. S.
TreasuryDepartment 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 tobecome available upon the
establishment of the PPP and resultant trading profits were opened atDZ
Privatabank in Zurich, as well as Coutts & Co., a private bank
whose principal place of doingbusiness is in London, United Kingdom.
Arrangements were also made to set up an account atthe Central Bank of
Switzerland, the Swiss National Bank (aka Schweizerische Nationalbank),
31 35. which
subsequently assisted in the verification process regarding the Dragon
Family Bonds inMay and early June 2009. 56. During this period
of time, which involved several waiting periods while variousrelated
contracts and trading programs were being approved, it was the practice
of Yamaguchiand Watanabe to travel from Switzerland to Carimate, Italy,
where they would visit and stay atthe home of their longtime friend,
Alessandro Santi ("Santi"). On such trips, the pair wouldoften travel
through the Chiasso railway station, in the canton of Ticino,
Switzerland, which isowned by the Swiss Federal Railways, and serves as a
border station between Switzerland andItaly. 57. On
approximately May 24, 2009, after one such trip, the pair had returned
fromCarimate, and was staying at the Hilton Hotel Airport in Zurich.
While there, they learned thatthere had been a maj or change in the
personnel involved in completing the transaction with theTurkish Group
that had approached KEENAN several weeks earlier. That Group appeared
tohave been replaced as serious questions had arisen about the
legitimacy of certain of itsmembers. However, a new group under the
leadership of a Baron von Gise, appeared to beready, 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 ofpreparations by Baron von Gise. 58. On May 31,
2009, KEENAN and Yamaguchi received news of yet anothersetback in their
plans and were awaiting confirmation that the details had been worked
out in asatisfactory manner. They were advised that everything would be
in place and a TradingAgreement ready to be executed by Yamaguchi
between June 3-5. 32 36.
59. On June 3, 2009, KEENAN was advised by Swiss lawyer Tobias
Braegger, whohad acted as the attorney for the Turkish Group, that all
necessary preparations would becompleted by the next day and the
transaction would be completed within the next week. On thesame day,
Yamaguchi advised KEENAN that he would be leaving Italy for a meeting in
Madridon other business matters. 60. Although KEENAN had been
advised during this time period that the SwissCentral Bank had verified
the Kennedy Bond, he was ultimately informed (following the
ChiassoIncident described infra) that both Banca Intesa and the Swiss
Reinsurance Company declined toengage in further transactions regarding
it "for political reasons." 61. Despite the failed
negotiations with the Turkish Group, and which might havecaused
Yamaguchi to exercise more care, Yamaguchi, after receiving a telephone
call whilehaving lunch with Santi and Watanabe in Carimate, suddenly
left for the train station and headedfor Spain. 62. On June 4,
2009 Yamaguchi sent an email to KEENAN from Barcelona advisingthat he
was well, but was otherwise silent as to the events that had transpired
upon his departurefrom Carimate.D. The Chiasso Incident 63.
In fact, unbeknownst to KEENAN until days later, upon their arrival at
Chiassoon this particular trip, both Yamaguchi and Watanabe were
approached directly by the ITALIANFINANCIAL POLICE and their bags were
searched. The pair was found to be carrying DragonFamily Instruments
(hereinafter, the "DF Chiasso Instruments") virtually identical in
content to aportion of the DFFI, which are the focus of this
litigation-in an amount approximating $134.5Billion U. S. Dollars.
Ironically, this was the exact amount that the United States Treasury
33 37. Department
had announced on or about March 30,2009 remained in its Troubled Asset
ReliefProgram ("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 boreserial 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
(ascompared to the 1 Kennedy Bond entrusted to KEENAN). 64. As
reported by the Japanese and Italian press at the time, upon arriving
atChiasso, Yamaguchi and Watanabe were detained by the ITALIAN FINANCIAL
POLICE afterattempting to enter Switzerland with "undeclared United
States Treasury Bonds concealed in asuitcase with a false bottom." The
Japanese Consulate General in Milan confirmed that the"detention" had
taken place while trying to confirm the mens identities. Eventually,
neitherYamaguchi nor Watanabe were arrested, although their computer and
eight telephones were alsoconfiscated. Reportedly, Yamaguchi advised
the authorities that the pair was in possession ofvalid 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 theprotocol required by the
Federal Reserve system, and no negotiation with the Federal
Reserveconcerning the actual value of the financial instruments he was
carrying, no laws had beenbroken. Charges against the two were expected
to be heard before the Procura Della Republicain Como, Italy in May
2011. According to at least one Italian newspaper, "La Provincia," on
orabout June 30, 2011, Yamaguchi and Watanabe were sentenced to three
and a half years inprison for trying to "smuggle" debt securities deemed
to be false. The story also reported thatMr. Santi had bargained in a
preliminary hearing for a year and four-month probation on related
34 38. 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 theiroffers to help went unheeded. Upon
information and belief, Campisani withdrew from the casewithout ever
responding to Keenan or his· attorney. 65. Upon information
and belief, approximately three years prior to this incident,
theinvestment banking firm of Goldman Sachs in the United States had
formally authenticated theFRNs entrusted to KEENAN and owned by the
Dragon Family, virtually identical to and sharingthe identical history
of the FRNs seized at Chiasso. KEENAN believes that all of the 1934FRNs,
including those seized by the Italian authorities at Chiasso, as well
as the DFFI entrustedto KEENAN, were fully backed by United States gold
bullion, authentic, and subject toverification by the Federal Reserve
when properly presented by the legitimate holder or theirrepresentative,
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
genuinelooking, "meticulous" work, and "indistinguishable" from
authentic instruments and werewaiting to be confirmed. Yet,
approximately two days after the seizure, the United StatesTreasury
claimed that the Federal Reserve Notes, which had been seized at
Chiasso, werecounterfeit 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 NewYork
Times reported on the story and included the statements of a United
States Secret Servicespokesman to the effect that the Secret Service had
performed an inspection, as required by theItalian Judiciary, and found
that the Instruments were fictitious and had never been issued by
theFederal Reserve or the United States Treasury. Upon information and
belief, the assertions that
35 39. the FRN s seized at Chiasso are not genuine are
inaccurate as will be determined through theverification process through
the Federal Reserve Systems black screen process. 67. It had
been reported that it remains unclear to the Italian authorities how any
suchinspections had been carried out and even whether the commission of
American experts whowere expected to travel to Italy to perform the
inspection, had ever arrived. Further confusingthe facts from reported
allegations, it was also reported that the DF Chiasso Instruments
wereaccompanied 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 ChineseGovernment regarding the
possibility of paying the "penalty" (40 % of the value of the
seizedInstruments) for the alleged failure to declare the Instruments in
crossing the SwisslItalian borderat Chiasso. Further, upon information
and belief, the negotiations were halted when it wassuggested that the
40% penalty would be paid, but in return for such payment, the
ITALIANREPUBLIC would reimburse its debt to China, which debt greatly
exceeded the amount of thepenalty Italy demanded for the return of the
Chiasso Instruments. Upon information and belief,The ITALIAN REPUBLIC
and the ITALIAN FINANCIAL POLICE have steadfastly declinedto return the
DF Chiasso instruments, but have actively and illegally sought to
convert suchInstruments for their own benefit, as more fully described
herein. 69. Despite the La Provincia newspaper article, an
extensive search for the file relatedto the seizure at Chiasso by Keenan
and his representatives, no such file has been located.
Suchrepresentatives were told in August 2011 that the file in Como could
not be found because of theholiday season. In September, although they
were told that the file had been transferred to thecentralized system in
Rome, they were ultimately advised that "there is no such file." In
early 36 40.
October, a telephone call was made to the Justice Department in Rome and
direct contact madewith 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 thecomplete
database on Alessandro Santi, Akihiko Yamaguchi and Mitsu Watanabee, all
three mencharged at Chiasso. He confirmed that it would have been
normal procedure for the Como file tohave been transferred to Rome
because two of the defendants were foreigners and translationswould be
required. Yet, he reported that nothing could be found on the matter. He
furtherresponded, when asked if there could be any hidden or highly
classified files, that he had fullauthorization and, as his
responsibilities required him to have full and complete access becauseof
his rank as Chief Inspector, he was also the Interpol liaison officer.
He made it eminentlyclear that there was no file to be found. Further,
there has been no known report or record of thedestruction of the
instruments seized at Chiasso which, upon information and belief, would
havebeen 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 ofemails between the two, Mr. Leo Zagami, a self-described
33 rd degree Free Mason, who, as ofApri12008, had reportedly claimed to
be the leader of a breakaway faction of the KnightsTemplar and
high-level Freemasons centered around the elite of the Masonic P2
(PropagandaDue) 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 sectsocieties and had been
looking to make contact with certain Asian Secret Societies. After
theJuly 2009 meeting, Zagami informed Fulford that he had information
that Yamaguchi andWatanabe had been "set up" at Chiasso and further that
he had "inside information" concerning
37 41. the seizure of the DF Chiasso Instruments.
Zagami immediately put Fulford in touch with theItalian Financial Police
who confirmed the authenticity of the seized Instruments. 71.
Upon his return to Italy, Zagami contacted Fulford to arrange for a
meeting inRome where, among other things, they again discussed the
Chiasso Incident. At that time,Zagami introduced Fulford through SKYPE
conversations to DAL BOSCO whom Zagamirepresented 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
theItalian Treasury Police." 72. Upon information and belief,
Fulford passed this information along to a memberof the British Royal
Family who then passed it on to a "group of Asians of royal blood known
asthe Dragon Family." On or about February 9, 2010, Zagami sent Fulford
another email, onbehalf of an acquaintance, inviting him to Italy and
Switzerland to discuss the transfer incustodianship of the DFFI from
KEENAN to DAL BOSCO and other issues. 73. As a result of the
FulfordiZagami discussions in or about July 2009, KEENANreceived a
request for a meeting from DAL BOSCO, who used Zagamis name as a
reference.KEENAN and DAL BOSCO spoke via Skype conversations on an
almost daily basis forapproximately six weeks thereafter until they
arranged to meet in Italy in September. During thecourse of those
discussions, DAL BOSCO represented to KEENAN not only that he was
thefinancial advisor to Zagami, but also to the Vatican, Vatican City,
Rome as well as the Treasurerof 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
travelsthroughout Europe and crossing of international borders, it had
been KEENANs practice tomaintain personal possession of all DFFI in
order to avoid possible confiscation or other loss. In
38 42. the normal course, KEENAN
would place the DFFI with hotel security before traveling, forinstance,
throughout Italy, Switzerland and Austria, while on his various business
ventures.Over time, and throughout his discussions with DAL BOSCO,
KEENAN became convinced thatit was in his best interests and safety, and
that of his principal, the Dragon Family, to entrustDAL BOSCO with
custodianship of the DFFI for safekeeping, most especially in light of
therepresentations 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 toKEENAN 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 43. 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 veryclose friend,
Alessandro Santi, with whom Yamaguchi had met prior to the seizure at
Chiasso inJune. It was arranged that DAL BOSCO would meet KEENAN and
Santi in Milan, as DALBOSCO 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 KEENANand Santi picked him up
at the train station. This was the first time KEENAN had met DALBOSCO
personally. At this time, the Milan Fashion Show was taking place which
was beingattended by DAL BOSCOs girlfriend, Alessia. After the Fashion
Show ended, the grouptraveled to Rome where DAL BOSCO offered to
intercede on behalf of Santi with people heclaimed to know were
associated with the ITALIAN FINANCIAL POLICE and the ItalianGovernment,
including former Italian Prime Minister, Silvio BERLUSCONI. 78.
Upon information and belief, thereafter, according to DAL BOSCO, he
visitedwith the ITALIAN FINANCIAL POLICE who advised him that the
financial instruments thathad been confiscated at Chiasso were
authentic, but that Santi had been charged with illegalpossession of
certain bonds. DAL BOSCO further reported that the Italian Government,
-throughBERLUSCONI, was demanding 400/0 of the instruments face value
for their return. KEENANwas already aware of that information.
40 44. 79. Throughout
this period of time, KEENAN was working on coordinating efforts tocarry
out his instructions regarding the intended proper placement of the DFFI
with which he hadbeen entrusted for the benefit of certain European
countries and business entities for investmentin 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
dayswith 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 justifyKEENANs decision to entrust the DFFI to DAL BOSCO
and corroborated his representationsthat he was associated with the
Monte Carlo P2 Masonic Lodge and a financial advisor to theVatican. DAL
BOSCO spoke freely to Somberg and KEENAN about his connections with
theVatican and the Italian Government. However, it was also during that
trip that DAL BOSCOtold KEENAN that he had "good news" for him. Upon
inquiry, DAL BOSCO explained that hehad received a call from a friend
inside The ITALIAN POLICE (GdF) who had informed DALBOSCO that the GdF
was willing to sell back the DF Chiasso.lnstruments for 10% of their
facevalue. KEENAN responded that he doubted that the Dragon Family would
be interested inbuying back its own Bonds and reminded DAL BOSCO that
he had no power of attorney to acton behalf of the Dragon Family with
regard to those Instruments and that his designated missionand authority
was to place only the DFFI with which he had been entrusted into a
legallyrecognized PPP. 81. Upon their return to Switzerland,
on or about September 18,2009, prior toKEENANs departure for the Zurich
airport and return home to Bulgaria, KEENAN physicallyentrusted the DFFI
to DAL BOSCO, as had been planned and acknowledged by DAL BOSCO.
41 45. 82. On
subsequent and frequent trips to Zurich, DAL BOSCO would meet KEENANat
the Hilton Hotel Airport and place the DFFI in KEENANs possession until
KEENANsdeparture at which time KEENAN would again entrust the DFFI to
DAL BOSCO.F. Negotiation for Placement of the DFFI into a Private
Program 1. The Introduction to H. Edward Wales 83.
KEENAN subsequently traveled to Zurich on or about January 16,2010
formeetings with people whom he believed could help in the placement of
the Federal ReserveNotes or the Kennedy Bond, which comprised part of
the DFFI, into a qualified PPP. KEENANremained in Zurich until February
13,2010. On or about January 29,2010, KEENAN took DALBOSCO 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
emailcommunication 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)
JapaneseBonds 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 forKEENAN, to show the
portfolio, including the Federal Reserve Notes and the Kennedy Bond,
toWales. KEENAN inquired of Wales whether he could also arrange for a
trading program whichwould include these instruments as well. This was
the first time Wales had seen an originalKennedy Bond, and he informed
KEENAN that he would like to concentrate on the JapaneseBonds, but would
be interested in further examination of the FRNs and Kennedy Bond
forpotential use in a PPP. Wales gave the portfolio back to KEENAN, who
then gave them to DAL 42 46.
BOSCO, and instructed DAL BOSCO to sehd copies via email to Wales for
his further reviewand recommendations. DAL BOSCO was in possession of
the instruments when everyone leftthe hotel. 85. In accordance
with KEENANs instruction, on or about February 3, 2010, DALBOSCO
forwarded copies of the documents of the DFFI via e-mail to Wales. On at
least twoother 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 KEENANs plan ofplacing the DFFI into a PPP.G.
Doubts Con~erning DAL BOSCO 86. Upon information and
belief, unbeknownstto KEENAN, after considerablepUblicity throughout
Europe and Asia following the Chiasso Incident, DAL BOSCO becameintent
not only on learning more about the Dragon Family and, in particular,
the nature and valueof the various Financial Instruments owned by the
Dragon Family, but diligently began toresearch how such Instruments were
utilized in the international global finance system. DALBOSCOs interest
intensified when he learned through his contacts in the
ITALIANGOVERNMENT and THE ITALIAN FINANCIAL POLICE that the Federal
Reserve Notes andKennedy 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 lawfultransaction
regarding the DFFI entrusted to him by KEENAN, without the authority
ofKEENAN andlor Yamaguchi on behalf of the Dragon Family, DAL BOSCO
sought assistancefrom various other sources and contacts, in order to
act upon and perpetrate a fraud in connectionwith the sale or placement
of the DFFI in the global marketplace through stealth, conversion
andbribery. 43 47.
87. DAL·BOSCOs research and connections ultimately led to his
introduction todefendants SALE and OITC. As revealed by an OITC
spokesman and published to the world atlarge on or about January 3,
2011, on Fulfords Internet website, the assertion that, followinginitial
communications from DAL BOSCO on February 2,2010, defendant DAM
executed awritten agreement with DAL BOSCO on March 16, 2010. This
agreement acknowledged thatOITC was fully aware ofDAL BOSCOs intentions
to steal the DFFI from KEENAN and placethem in the possession of OITC
which would claim ownership pursuant to its alleged authorityunder the
provisions of its claimed U.N. Charter and the D.N.s "sovereign
immunity"protections. 88. Upon information and belief, DAL
BOSCOs connections in Europe includeddefendant BRUNO and the WEF who, in
turn, had direct contacts with defendant the UNITEDNATIONS. Thereafter,
as set forth in more detail below, the various defendants entered
intovarious criminal schemes and enterprises whereby DAL BOSCO would
knowingly betray,violate and breach all of his previously acknowledged
fiduciary duties to KEENAN and therebythe Dragon Family, by stealing the
DFFI and converting possession of the DFFI for their ownselfish,
criminal and personal financial gain. 89. During KEENANs stay
in Zurich in the January-February 2010 time period,DAL BOSCO suddenly
and surprisingly advised KEENAN that he had made contact with highlevel
UNITED NATIONS officials, through the assistance of BRUNO and the WEF,
wherebyDAL 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
44 48. not include the Japanese Bonds or the
Kennedy Bond which, as described, form a portion of theDFFI. 90.
DAL BOSCO asked KEENAN if he wanted to pursue this offer but stated
that, asa condition, neither Yamaguchi nor the Dragon Family could be
involved and that the UN didnot want Yamaguchi involved. KEENAN
emphatically rejected any interest, noting further thatthe Federal
Reserve Notes were not his to sell. 91. DAL BOSCO told KEENAN
that "I assure you this is our best deal and my friendGiancarlo from the
Economic Forum stands behind it. He went to see our friends in
theUNITED NATIONS and this is very delicate but can be done but nothing
for Yamaguchi or theDragon Family." DAL BOSCO further stated that
Yamaguchi would not only never know theDFFI had been stolen but that the
rightful owners, the Dragon Family, would "never be able toreceive ONE
CENT" from the transaction. Further, upon information and belief, the
DFFIwould 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 greatreluctance to discuss the UN or
BRUNOs involvement and stated that no one would ever get tospeak to
BRUNO or his ITALIAN FINANCIAL POLICE or Vatican connections.H. The
Speaker Telephone Conference Call between DAL BOSCO and BRUNO
92. Following Dal Boscos report to KEENAN of the offer from the UN
andBRUNO, and while still in Zurich in early February 2010, KEENAN had
gathered several closebusiness associates and friends for a routine
meeting/luncheon in the VIP Room on the 5th floorat 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 aforesaidpotential transaction involving the Japanese Bonds with
Wales. Other guests of KEENAN
45 49. included Nikolai Raykov, a Canadian citizen
(hereinafter, "Raykov"), Vasil Ganov, a Bulgariancitizen (hereinafter,
"Ganov"), Ognyan Marinov, (hereinafter, "Marinov"), also a
Bulgariancitizen and retired Intelligence officer, as well as Walter
Berens (hereinafter, "Berens"), a citizenof Germany. At one point, DAL
BOSCO arranged to place a telephone call via speaker phone toa man whom
he identified as Giancarlo BRUNO. DAL BOSCO indicated to those present
thatthe call was intended for KEENANs ears only but that they could
listen to the call. During thecourse of the call, the man who was
identified as BRUNO stated that he could arrange to "put$100 Million USD
into KEENANs hands if KEENAN agreed to it." KEENAN, who hasalways been
told that any involvement participation by BRUNO must be kept a secret,
was thuscaught off guard when a call of this nature was to take place,
was disgusted with the call andwalked away from the table while DAL
BOSCO continued the call with the man he identified asBRUNO. 1.
Recollections of Mr. Raykov 93. 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
phonewas actually BRUNO. DAL BOSCO asked Raykov if he had any idea who
BRUNO was andRaykov 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 DALBOSCO ifhe could speak with BRUNO and
was told that he could, but only from a pay phoneand not a cell phone.
Raykov proceeded to drive with DAL BOSCO to the airport in a taxi andDAL
BOSCO then placed a call to BRUNO who spoke directly with Raykov. BRUNO
told 46 50.
Raykov that if he could convince KEENAN to take the money, he would make
sure thatRaykovs family would be set for life. 95. During
this telephone conversation, BRUNO said that the DFFI would "be
placedinto 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 wouldbe no problems and that this was
being blessed by the UNITED NATIONS" which "wouldprotect 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 wasactually BRUNO, Raykov told DAL BOSCO that he did not believe
him. DAL BOSCOthereupon called the number again and told Raykov to
listen. The person speaking identifiedhimself as Giancarlo BRUNO. DAL
BOSCO also gave Raykov a telephone number in NewYork to call when Raykov
was in the United States. Raykov, in fact, called the telephonenumber
he was given while in New York in July and the call was answered by
BRUNO. Raykovtold 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 entrustedto him by KEENAN and "now more
than ever" Raykov was needed to speak with KEENAN totry to convince him
to cooperate with DAL BOSCO and BRUNO. 97. Raykov subsequently
told KEENAN to be careful and that "the wolves aresurrounding him."
KEENAN told Raykov not to get involved. Raykov spoke again with DALBOSCO
and told him "to forget" about persuading KEENAN to cooperate with him.
DALBOSCO responded that KEENAN would regret that as he "was no longer
in possession" of theDFFI.
47 51. 2. Recollections of Mr. Gano-.v 98. Ganov
recalls that following the telephone call, he inquired ofDAL BOSCO
whathe would receive from this "transaction" and DAL BOSCO responded
that he would receive50% of KEENANs $100 Million USD, the total amount
of which would be placed into aSovereign Program by the UN and that they
would each receive 2000/0 monthly returns minimumfrom the total
"investment" of$100 Million USD. DAL BOSCO was then asked how much
theUN, WEF, BRUNO and OITC would receive, and he responded that this was
not KEENANsbusiness and not to ask because "it can only cause trouble."
DAL BOSCO stated that the Noteswould 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
Ganovto help him convince KEENAN to participate in his scheme. 99.
DAL BOSCO informed Ganov that "everyone was also protected by the
ItalianFinancial Police and the Italian Government itself." DAL BOSCO
boasted about his position asFinancial Advisor to the Vatican and
Treasurer of the Masons and that "nothing could gowrong." 100.
Ganov and Berens also told KEENAN that they thought DAL BOSCOsplacement
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 BOSCOwas playing the role of a salesman trying
to sell something to all present. Raykov told Ganovthat he thought DAL
BOSCO was a thief and that he thought DAL BOSCO was hiding the truthfrom
KEENAN and was using BRUNO and the UN to assist him in his scheme.
Ganov toldKEENAN that he did not trust DAL BOSCO and was assured by
KEENAN that he had no 48 52.
interest in DAL BOSCOs "offer" and that his goal was not only to
protect the DFFI but also toget them placed into a proper PPP.
101. During KEENANs trip to Zurich, Ganov asked if he could view the
DFFI andDAL BOSCO retrieved them for viewing. Ganov inquired as to their
authenticity and DALBOSCO responded that the UN had verified their
authenticity. Ganov also inquired aboutYamaguchi, and DAL BOSCO stated
that he was a powerful, but unpopular man and that the UNwould not do
business with him. 102. In discussions with DAL BOSCO, Ganov
was informed that BRUNO wasprepared to pay KE~NAN "100 Million Dollars
by Friday if things worked right" and shouldKEENAN consent to the
transaction. When Ganov commented that he thought KEENAN wouldbe
jeopardized by any involvement in such a transaction, DAL BOSCO
responded that "no onecan get in trouble ... it is perfect ... the UN
protects everyone under their shield." Ganov wasalso told by DAL BOSCO
that most of the plans and communications were made between him,BRUNO
and the UN, either through BRUNOs private New York cell phone or his New
Yorkoffice. DAL BOSCO also stated, in response to Ganovs questions
about KEENANs security,were the Dragon Family to learn of any possible
involvement by KEENAN, that "they will notreceive one cent so they will
never know" and further that the DFFI "do not belong to theDragon Family
but to OITC." 103. During this trip, Ganov had also asked
KEENAN if he thought DAL BOSCOcould assist him and his business
associates, who were present with him, on another proj ect onwhich they
were working in Italy. KEENAN responded that he thought DAL BOSCO
mighthave the ability to help and arrangements and introductions were
made. 49 53.
104. Ultimately, not only did Ganbv become aware that DAL BOSCO had
stolen theDFFI, but he also learned that DAL BOSCO had tried to swindle
Ganov on his other businessdeal on which DAL BOSCO purported to assist
his group. KEENAN departed for Bulgaria onFebruary 13,2010. 3.
Recollections of Mr. Ognyan Marinov 105. 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 2010meeting with DAL BOSCO at the Hilton Airport Hotel in
Zurich. DAL BOSCO had apparentlybeen made aware of Marinov s
Intelligence background and approached him for a privateconversation.
Believing KEENAN and DAL BOSCO were close friends, Marinov acceded tothe
request. Marinov has stated that he shortly came to believe DAL BOSCO
was engaged in aplot to steal the DFFI with which he had been entrusted.
4. Raykov Meeting with BRUNO and DAL BOSCO in Geneva in May
2010 106. Months later, while in Geneva on business with some
of his associates, Raykovcalled DAL BOSCO for a social visit. DAL BOSCO,
upon answering the call, asked Raykov tomeet him at the Balexert Mall
in Switzerland and indicated that "he had to speak" with Raykov.Upon DAL
BOSCOs arrival with his girlfriend, Alessia, Raykov asked DAL BOSCO
what hewanted 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 theothers 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 notnecessary." BRUNO asked DAL BOSCO if Raykov "was
assisting them yet." DAL BOSCOreplied that he had asked Raykov to meet
with BRUNO because he wanted BRUNO to speak
50 54. directly to Raykov. BRUNO, speaking
freeiy, told Raykov that KEENAN "was stupid for nottaking the 100
MILLION US DOLLARS" and that "things had been in the planning stages
forawhile and were about to be completed with or without KEENAN." BRUNO
again askedRaykov if he would help convince KEENAN to take the money
that was offered and Raykovresponded 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 BRUNOs description
of the details of how theDFFI were received and were planned to be
placed into a financial program and that "no onewould know anything."
BRUNO said that "it would be silent" and after the completion of
theprogram, 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 themwith immunity as well did OITC."
109. BRUNO then told Raykov that he would only speak with him,
if Raykov "calledhis 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 hasnot spoken with BRUNO
since this conversation. 5. Marinov Meeting with BRUNO and DAL
BOSCO in Geneva in May 2010 110. In late May 2010, Marinov met
DAL BOSCO at the Intercontinental Hotel inGeneva, who introduced him to a
gentleman he identified as Giancarlo BRUNO from the WorldEconomic
Forum. Although Marinov extended his business card to BRUNO, DAL
BOSCOdiscouraged such an exchange. It was the impression of Marinov that
DAL BOSCO wasdeferential to BRUNO, whom Marinov considered being
"highly intelligent" and who wasclearly "running the show." BRUNO
proceeded to explain how the Davos Program had
51 55. achieved such success and seemed to
imply~that Marinov would be welcome at future meetingsat Davos. BRUNO
proceeded to boast about various dignitaries with whom he had
donebusiness, 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 orNotes Mr. KEENAN was holding for the
Dragon Family and who was involved." BRUNOspecifically named RAGAGLINI,
MlRACHIAN and BERLUSCONI, and the ITALIANFINANCIAL POLICE and commented:
"so you see there is no possible way we can have aproblem. We can cloak
ourselves with the immunity shield and everyone will go away.
Justanother day in the UN!" 112. Marinov asked BRUNO to explain
what he was talking about and BRUNOresponded: "we want you to get
KEENAN to give the bonds to us for 100 Million USD. Wehave better uses
for the notes than KEENAN would ever dream of nor would he release them
tous so readily. So we need your help." 113. DAL BOSCO then
explained that he had approached others for help but thatKEENAN would
not relinquish the bonds, although a "Sovereign Program" was all set up.
Itwas evident to Marinov that his status as a Bulgarian Intelligence
Officer might influenceKEENANs decision to cooperate in the scheme DAL
BOSCO and BRUNO were openlydiscussing. 114. As Marinov grew
increasingly uncomfortable with the volume of telephone callsbeing made
and received by BRUNO, after approximately 45 minutes, he was introduced
byboth BRUNO and DAL BOSCO to defendant MlRACHIAN, whom he found to be
pleasant andintelligent. In response to questions posed to her by BRUNO,
MlRACHIAN stated that: (i). "from the very top we were
protected"; 52 56.
(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 largeundertaking
... in accordance to UN standards" and he then stated that the UN was
"in theprocess of confiscating Trillions and Trillions of Dollars in
assets within the next couple ofmonths and no one could do anything
about it." When Marinov inquired as to whether themoney 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 topersuade KEENAN to cooperate with DAL BOSCO to accomplish what
DAL BOSCO andBRUNO were proposing, especially in light of KEENANs
transfer of the DFFI to DAL BOSCOthe previous September. DAL BOSCO
indicated that he was considering taking the Bonds andusing them for
undisclosed purposes without KEENANs permission but that he was
reluctant todo so as KEENAN might ask for them to be produced and DAL
BOSCO might "find himself ina bad spot." DAL BOSCO, however, went on to
volunteer that there were "future plans" for theBonds. This necessitated
that KEENAN turn them over "so that no one could cause a ruckusclaiming
they were stolen from them." According to BRUNO, "not anyone could
withstand suchscrutiny" thus "they were trying to buy The Bank of Lugano
in Switzerland to hide such thingsas stolen instruments." When Marinov
asked who was buying the Bank, he was told "the
53 57. ITALIAN FINANCIAL POLICE, BERLUSCONI
and others" which would allow them to "tradethe many instruments stolen
over the years by the Italian Financial Police and trade them fromthe
Swiss Bank and no one would be the wiser." It was apparent to Marinov
that DAL BOSCOand BRUNO saw it most advantageous to their conspiracy to
gain KEENANs cooperation andparticipation "with the entire scheme
already in motion," which KEENAN has steadfastlyrefused to do.
117. In conclusion, Marinov witnessed the dialing of aNew York City
telephoneexchange and placement of a telephone call by DAL BOSCO and
BRUNO to RAGAGLINI inNew York. Marinov heard them ask "if everyone was
ready to do the Bond deal" and heconfirms that RAGAGLINI stated that
"the Powers that be in New York had no problems withthe actions about to
be taken so long as some candy was tossed to them." Further,
RAGAGLINIacknowledged that BAN KI-moon "was on board and approved the
plan so everything was inplace but KEENAN." RAGAGLINI concluded by
asking Marinov "to rope KEENAN inbecause it was necessary for success."
Although compensation for Marinovs services wasdiscussed, no exact
amount was ever mentioned. Marinov took no actions attempting topersuade
KEENAN to cooperate with the aforesaid scheme, and KEENAN has
continuouslyrefused all overtures from the Defendants to participate in
their illegal actions. 6. Berens Telephone Call from DAL
BOSCO in August 2010 118. KEENAN has known and conducted
business with Berens for several years. Heis known to KEENAN to be
highly respected and trustworthy. Berens was also present inFebruary
2010 at the Hilton Zurich Airport Hotel for the business luncheon
arranged byKEENAN. He was present when DAL BOSCO, whom he had met with
KEENAN in the recentmonths prior thereto, placed a telephone call via
speaker phone to BRUNO in New York. He
54 58. heard DAL BOSCO asking KEENAN ifhe:wanted
to do a "deal with the UN" which "involvedMR. BRUNO, very high ranking
friends of Mr. BRUNOs and DAL BOSCO in the UN."Berens heard DAL BOSCO
tell KEENAN that they "could take the 100 Million Dollars as earlyas
Friday that week." KEENAN rejected the offer. 119.
Subsequently, in August 2010, Berens received a telephone call from
DALBOSCO who asked him if he would make contact with KEENAN to "once
again" offer the 100Million USD that had been previously offered in
February in Zurich. Berens responded that itwas his understanding that
KEENAN no longer held the Bonds and that DAL BOSCO "had runwith them."
DAL BOSCO replied that he did possess the Bonds and "would not give
control ofthem until he knew he was safe." DAL BOSCO added that "if
KEENAN took the moneyeverything would be better" and stated that "he is a
good Christian who might have made somevery bad mistakes that could
hurt a lot of people." DAL BOSCO mentioned he was even havingtrouble
with his girlfriend because of the situation, including Internet reports
of what he haddone. He again stated that "if KEENAN would take the
money it makes everything go away andeveryone 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 tocheck." Berens suggested
to DAL BOSCO that he call KEENAN directly, to which heresponded that
KEENAN would prefer to "hang him not speak with him." DAL BOSCO
againacknowledged his mistakes but that it was "impossible to take it
all back seeing it had beendone." Berens ultimately asked DAL BOSCO
precisely what he wanted him to inquire ofKEENAN so that he did not make
any mistakes. DAL BOSCO responded that "100 MillionUSD would be given
to KEENAN immediately upon giving the Bonds to Mr. Giancarlo
55 59. BRUNO from the World
Economic Forum who would then "take the Bonds and give them toBRUNO and
DAL BOSCOs friends in the UNITED NATIONS to take into the
FederalSovereign Program for Trade," after which the bonds would be
"given back to their rightfulowners 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 theDAL BOSCO situation and asked about the bribe
offer. KEENAN responded that "this was anattempt at theft and nothing
more." KEENAN also confirmed what DAL BOSCO hadpreviously told Berens,
namely that the 100 Million USD would be split between KEENAN andDAL
BOSCO which DAL BOSCO wanted to place in another trading program to
generatecapital 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 Yamaguchiwas well known as
the comptroller/signature of the Dragon Family. KEENAN stated that
thetransaction he was working on was "to help countries not the UN,
OITC, the WORLDECONOMIC FORUM or BRUNO" and that "the returns would be
greater for everyone involvedand 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
tointimate and suggest that he was continuing discussions within the UN
about the negotiation ofthe Federal Reserve Notes, but erroneously noted
that the Japanese Bonds and the KennedyBond were "government bonds"
which could only be traded or negotiated between governmentsand that it
was illegal for any individual to possess them or to attempt to trade
them. KEENAN 56 60.
immediately rebuffed any suggestions that the Federal Reserve Notes be
dealt with in anyunlawful manner. 123. KEENAN subsequently
learned that Zag ami had informed Fulford on or aboutJune 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, amongother things, the destruction of the
Papacy. Thereafter, KEENAN was concerned that DALBOSCO might disappear
on a whim. 124. In various conversations throughout April and
May 2010, KEENAN reiterated toDAL BOSCO that he was currently working on
placing the Japanese Bonds only in a legallyrecognized PPP through Mr.
Wales in Geneva, Switzerland, and had no active plans for theinvestment
or placement of the Federal Reserve Notes or the Kennedy Bond. KEENAN
keptDAL BOSCO abreast of his efforts regarding his working with his
connections in China andJapan 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 tobe more
than a mere custodian of the DFFI, but a confidante and friend.
However, KEENANhad also been sensing a change in DAL BOSCOs attitude and
demeanor, such as increasinglyfrequent 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 BOSCOs control. 125.
At the same time KEENAN was working to achieve the placement of
theJapanese Bonds into a trading program, he was also attempting to
place the Federal ReserveNotes 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
57 61. would soon
need the Japanese Bonds and that he might also have a deal for the
Federal ReserveNotes. 126. While DAL BOSCO continued to
mention the "offer" from the UN, KEENANreiterated that the purported
proposal by the UN was not acceptable legally or ethically. He toldDAL
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 beused as collateral with the Bank
of China, and that Wales had been requested to seek to investthe DFFI in
a recognized PPP. 127. At all relevant times leading up to
the month of June 2010, KEENAN wouldadvise DAL BOSCO whenever he needed
the DFFI for presentation at a business meeting and atall times DAL
BOSCO complied. However, beginning in or about May 2010, KEENANobserved
that DAL BOSCO had consciously decided to change apartments in Rome as
if toconfuse KEENAN as to his whereabouts and, as it transpired, in
order to avoid contact andultimately to disappear. 128. In
conversations in early June 2010, KEENAN~ indicated clearly to DAL
BOSCOhis hopes of coordinating a transaction involving three European
countries and expressed hisdesire that DAL BOSCO participate in the
venture. DAL BOSCO again reiterated the aforesaidoffer from the UN to
buy the FRNs for $100 Million USD, but KEENAN again rejected thenotion
and warned that the UN was acting unlawfully with respect to its planned
disposition ofthe DFFI.
58 62. 129. On or about June 8,2010, KEENAN advised DAL
BOSCO directly that hisassociate, Mr. Joseph Bendana (hereinafter
"Bendana"), an American citizen, would be travelingto Geneva,
Switzerland to retrieve the entire DFFI in order that they would be
available for theirintended 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 thatBendana 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") purportedlyissued 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
NationsCharter Control No: 10-60847 and UN International Clearing Code:
UNRCD-ID006197. TheOITC order, among other things, stated that KEENAN,
Yamaguchi and Watanabe "together withall associates, colleagues" were to
"Cease and Desist" from "attempting to handle various MasterAccounts
and Assets of the Combined International Collateral Accounts of the
Global DebtFacility, which incorporates the Dragon Funds, without any
Official Authority or Approvalwhatsoever; which are legally owned under
full Legal International Laws/International Treaty/Convention Laws, as
herein referred, by the aforementioned and referenced
InternationalTreasury 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 orbefore 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 63.
KEENAN how OITC had obtained his email address. In fact, DAL BOSCO had
aided in theorchestration of the OITC Order and was neither in fear nor
surprised by its issuance. He hadinquired about OITC from KEENAN as
early as January 2010 and was told OITC was afraudulent organization.
Further, DAL BOSCO had referred to OITC as the "owners" of theFRNs in
his discussions with Vasil Ganov in February 2010 in Zurich (see ~ 102,
supra) andwith Nikolai Raykov in Geneva in May 2010 (see ~ 108, supra).
KEENAN responded that hehad 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 wasnot 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 "decidewhat to do with them." Further, on June 22,2010, in a
conversation with Fulford, DAL BOSCOaffirmatively stated that he was
alternatively "working with the Police and the UN" as well as"with
Interpol." Fulford asked for the name ofDAL BOSCOs attorney or the names
of theInterpol person with whom he was in contact so that Fulford could
"get the Japanese securitypolice 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
withrepresentatives 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. Theybelong to OITC."
135. On June 9, 2010, KEENAN notified the OITC bye-mail that he was in
receipt ofthe OITC Order and asked three questions, as follows:
60 64. 1. What is
your role or responsibility, or involvement in the bonds?
Please be more descriptive. 2. Who is the
party or persons that have provided you with our
names? 3. What gives you the authority to issue such
a Cease and Desist" document (PDF files?).
136. KEENAN further demanded detailed responses within 24 hours
together with areservation of rights regarding future civil or criminal
actions. 137. On or about June 9, 2010, DAL BOSCO contacted
KEENAN and expressed hisown personal fear and his inability to make a
decision regarding the DFFI. KEENAN assuredDAL 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 fromeither the UN, the Federal Reserve Board, or
the BIS, and that any licensing it might once haveenjoyed had been
nullified several years prior. 138. KEENAN told DAL BOSCO to
ignore the OITC Order pointing out that DALBOSCO was not even named in
the document. KEENAN did inquire of DAL BOSCO how theOITC obtained his
email address and DAL BOSCO denied my knowledge, although KEENANwas
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 contentofC&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 65. Dragon Funds. The
Dragon Funds are part of the Combined International Collateral Accounts
ofthe 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 theTrilateral
Trillenium Tripartite Gold Commission established January 1945 with a
Fifty (50) yearterm, expiring in 1995." 140. The OITC also
responded to KEENANs letter by stating, in response to thequestion as to
who had provided OITC with the names in the OITC Order, that "This
isprivileged information and cannot be disclosed." As to the third
question posed by KEENAN asto 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 whichKEENAN had allegedly "approached
this matter" would not be tolerated as it shows "aninsulting and
arrogant attitude towards a Sovereign Entity which is legally
charteredunder the United Nations and recognized by all Nations . . :"
(Emphasis added) and wassigned: 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, sentvia email in which he disputed
that the BIS, UN or Federal Reserve recognized OITC, but urgedMr. Dam
"to request Mr. Yamaguchi to work directly with you," noting that "if
you can possibly 62 [*]66.
assist him with his bonds then I can provide "the TRADER for you. Then
there will be money forhumanitarian causes in our hands." 142.
SALE responded the same day opening with the greeting that "Again
yourarrogance and total lack of knowledge shows within the content of
your communication." Afterdisputing that either Yamaguchi, as
Controller, or the Dragon Family itself are the "LegalOwners" of the
missing DFFI, SALE advised that the OITC Order "stands and is
enforceable infull" 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 frompeople, as he is far to
[sic] busy on more important issues attending to Royal Families.
Neitherdoes H.E. Dam attend meetings with, nor have appointments with
anyone other than RoyalFamily 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 possessionof 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 verifyour status"; (4) it had "dispatched" to said Firm
"details regarding the protocols that they mustapply, together with the
relevant information reference to where and to whom they should applyfor
verification of the OITC/H.E. Dr. Dam"; (5) it had made arrangements
for the SwissIntelligence Services to visit the Law Firm "to ensure that
the Law Firm is fully aware of whatthey are handling and the
seriousness of same"; (6) it had received from the Law Finn thatmorning
copies of threatening letters from "a Japanese person" and KEENAN and
which itwould report to the Intelligence Services and Police; (7) that,
as of that morning, H.E. Dr. R.C.
63 [/*]67. Dam had "agreed to cover the Law Firm., its
.Partners and employees, and the specific clientunder International
Security Clearance Level 3-5 and the Vienna Convention, whereby
anyuntoward act or actions ... will now be handled accordingly ... " and
otherwise threatened toissue 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 organizationand 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 notmade contact with our attorneys. Seeing it
is the Dragon Family bonds that you have abscondedwith, you have not
given me to give to my attorneys any contact numbers for your attorney
todate which in itself is illegal. I see OITC has it and as previously
mentioned you and yourattorneys are responsible for anything happening
to those bonds outside a court of law. Yourattorney is speaking with
OITC but not the owners of the bonds. This is very interesting
andillegal. 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 68. 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 anattorney for DAL
BOSCO.K. Attempted Retrieval of the DFFI by Joseph Bendana
147. Bendana had previously worked with KEENAN on PPPs initiated by
the DragonFamily. For instance, on or about September 23,2008 Yamaguchi,
"as the legal holder of the 10Kennedy Bonds and the 415 metric Tons of
AU (gold)" had executed an Authorization Letter infavor of Bendana
whereby Bendana was authorized "to oversee alloperations involved with
thePrivate Placement Program for both the bonds and the AU and you are
to insulate at all times themembers of the Dragon Family by handling all
issues that arise with Mr. Neil Keenan, projectcoordinator ... to make
sure that the programs are ready for us to enter upon authentication
ofthe bonds or AU certificates ... " 148. On or about June
14,2010, Bendana received a telephone call from DAL BOSCOand after
discussing with him his authorizations, made specific arrangements to
meet with DALBOSCO in Geneva to retrieve the DFFI. 149. On or
about June 15,2010, Bendana flew to Geneva for the sole purpose
ofretrieving the DFFI, including the Federal Reserve Notes and the
Kennedy Bond, so that hecould arrange their return to KEENAN. On or
about June 17,2010, Yamaguchi executed a
65 69. Power of Attorney in favor of Bendana "to
r~trieve the bonds/notes from the hands of Mr.Daniele Dal Bosco or from
the legal safekeeping vault where Mr. Daniele Dal Bosco depositedthem,"
such written instrument also expressing the hope that Mr. DAL BOSCO
would placethem in Mr. Bendanas hands "as he received them from Mr.
Keenan." The instrument alsodirected Mr. Bendana to make preparations to
move the DFFI in accordance with KEENANsinstructions after KEENAN has
confirmed that the DFFI retrieved by Bendana are the same asthose turned
over to DAL BOSCO. 150. Ultimately, DAL BOSCO neither
contacted nor met with Bendana at theappointed 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 didhave conversations with DAL BOSCO in which he suggested that
DAL BOSCO return the DFFIto KEENAN and even provided a draft format of a
safekeeping receipt for use by DALBOSCOs attorney to send to KEENAN.
Wales attempts to assist KEENAN were rebuffedcausing him to inform
Bendana that DAL BOSCO would not be returning the Federal ReserveNotes
and Kennedy Bond, which comprised part of the DFFI,.to him. After
spending three daysin Geneva, Bendana left empty handed for Bulgaria
where he saw KEENAN while harboringhopes that DAL BOSCO would change his
mind and Bendana could fulfill his assignment. Thisdid not occur and
Bendana ultimately returned to the United States on July 4, 2010. It was
notuntil a few days after Bendana retu~ed home that DAL BOSCO called
him to state that he mightreconsider returning the DFFI and to "wait a
little longer." 151. During his trip, Bendana had dinner with
KEENAN at Ganovs house in Bulgaria.Bendana expressed his regret that he
had divulged his itinerary to DAL BOSCO and that he wassure DAL BOSCO
was planning to steal the DFFI. Bendana also said that by revealing his
66 70. itinerary, DAL
BOSCO might have been pressured to take action with the DFFI more
quicklythan he might originally have planned. 152. Eventually,
DAL BOSCO himself told KEENAN that he would never return theDFFI and
that he "should get on with his life." DAL BOSCOs actions caused
substantialeconomic harm to KEENAN as the European group KEENAN had been
dealing with had madeall the necessary financial arrangements in order
to invest Fourteen Billion Dollars($14,000,000,000.00) in the form of a
cashiers check in return for the use of the FRNs which, asdescribed,
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, DALBOSCO 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 Governmentand has at all
times refused to relinquish control of or return the DFFI to KEENAN,
Yamaguchior 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 allfiduciary
and legal obligations he owed to KEENAN under his agreement to act as
temporarysafe keeper and custodian of the DFFI, KEENAN has spared no
effort to try to either reason withor persuade DAL BOSCO, and those with
whom he has elected to conspire to steal and convertthe DFFI for their
own selfish and illegal purposes, to return the DFFI. These efforts have
beenentirely futile and DAL BOSCO, and those with whom he has
conspired, has at all times refusedto 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
andto repudiate DAL BOSCOs actions, have been the following:
67 [*]71. i. The
service of his own Cease and Desist Order upon DALBOSCO on or about June
20, 2010, demanding the return of the DFFI,citing DAL BOSCOs broken
trust and attempts to sell the DFFI to theUNITED NATIONS and the ITALIAN
REPUBLIC or agencies thereof;his failure to turn the DFFI over to
Bendana as had been arranged; DALBOSCOs collaboration with OITC and
participation in attempting tobribe KEENAN with the assistance of the
UNITED NATIONS and itshigh ranking representatives, BRUNO, the WEF
and/or WEF USA andothers; DAL BOSCOs 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
DALBOSCO by Yamaguchi on or about June 22, 1010, as well as his filing
ofa Criminal Complaint on or about June 24, 2010 with the Governments
ofFrance and Switzerland in their respective Ambassadors offices in
Tokyo.The Complaint noted DAL BOSCOs illegal possession of the DFFI,
withan estimated value of 989 Billion USD for the past 3 weeks, as well
asDAL BOSCOs expressed threats to transfer their possession to OITC.
111. The filing of another Criminal Complaint on or about
July2,2010, by Yamaguchi against DAL BOSCO with the Italian Embassy
inTokyo c/o Ambassador Vincenzo Petrone, charging DAL BOSCO with,inter
alia, "grand theft, fraud, conspiracy, grand larceny, and conspiringacts
of bodily harm against the papacy, [and] violence directed toward
theVatican ... "; the Complaint charged that DAL BOSCO had beencolluding
with some members of the Italian Government in attempting to"extort
extreme amounts of money from the Dragon Family." Yamaguchiurged that
the DFFI be returned from DAL BOSCO and his lawyerthrough Mr. Keenan as
soon as possible. He further requested the ItalianAuthorities to detain
DAL BOSCO if he entered their jurisdiction and tolaunch a full
investigation of said charges. iv. The filing of yet another
Criminal Complaint byYamaguchi with the Metropolitan Police Department
in Tokyo on or aboutJuly 8, 2010 , alleging "the robbery damage" ofDAL
BOSCO by virtue ofhis stealing the DFFI in Geneva from KEENAN, to whom
Yamaguchi hadentrusted the DFFI in January and May 2009. v.
The submission on or about July 21,2010 ofa swornstatement by Bendana to
Interpol advising of his written authorization inJune 2010 "to retrieve
over a trillion dollars worth of bonds" from DALBOSCO in Geneva,
Switzerland and which were then in the possession ofDAL BOSCO for safe
keeping only. Bendana also referenced his
68 [/*]72. exchange of contact information with DAL BOSCO prior to
his trip toGeneva. vi. The issuance by Wales on or about July
26, 2010, of hisown "Cease and Desist Order Effective Immediately"
against DALBOSCO, based upon DAL BOSCOs misappropriation of the DFFI,
whichhe knew were under the legal control of KEENAN, and DAL
BOSCOssubsequent "slanderous and malicious attack" upon Wales person
orcharacter. vii. On or about July 27, 2010, KEENAN submitted
a packageof information to Interpol Headquarters in Lyon, France
"revealing thetheft of approximately 1 Trillion USD in Financial
Instruments by ItalianDaniele Dal Bosco ... " Among other things, KEENAN
advised Interpolthat his enclosed package contained documentary
evidence to support hisclaims against the actions taken by DAL BOSCO
relating to the theft and(a) DAL BOSCOs refusal to return the
Instruments "back to their rightfulowners/custodians," (b) DAL BOSCOs
attempted sale of the DFFI to theUNITED NATIONS "which offered him 100
Million USD for them" (c);DAL BOSCOs steadfast refusal to provide
contact information for theindividuals, including his lawyer, or law
enforcement agencies, includingInterpol itself, with whom he had
allegedly conferred about depositing theDFFI; and (d) the closing by DAL
BOSCO of his London office, hischange of email address, and moving from
his apartment. Included in thepackage was (e) an affidavit from Mr.
Somberg in which Sombergdescribed his understanding of the relationship
between KEENAN andDAL BOSCO based upon the several conversations he had
with DALBOSCO while travelling with him in Switzerland, Germany and
Austriaduring the September 2009 time period (see ~~77-82, supra).
Sombergrelated his own observation that DAL BOSCO; during this period,
"wasvery close by Mr. Keenan and was clearly the caretaker of the
financialinstruments that Mr. Keenan was authorized to use by the Dragon
Familyand their comptroller/signatore Mr. Yamaguchi." Somberg
understoodthat KEENAN "was attempting to work an international
transactioninvolving various governments to help them in their time of
crisis."Somberg also quoted the response ofDAL BOSCO, whom he had
deemedat that point to be "a very sound and practical person" when
queried byhim 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 73. bonds and instruments so Neils 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 HisEminence
Vatican Secretary of State Cardinal Bertone, whom he had metpreviously
at a Celebration for the Dominican Republic and PresidentBelaguer in
October 1992. He noted his regret to have to advise theCardinal that
Italian Citizen DAL BOSCO, who had represented that hewas a resident of
Vatican City, as well as Divonne-Ies-Bain, France, andwas the Financial
Advisor to the Vatican and Treasurer of the Masons, had"absconded with
approximately 1 Trillion USD and Japanese Bonds inJune 2010 that were
entrusted to me." KEENAN noted that DAL BOSCO"was a very nice young man
who presented himself properly at all timesand of course I believed
him." KEENAN also advised Cardinal Bertonethat DAL BOSCO had told him he
had been working with the Vaticanthrough its financial programs, or
Platforms, and had been hopeful ofplacing the DFFI into such a program.
Despite DAL BOSCOs statedintentions of working with the Vatican, KEENAN
also felt obliged toreport to Cardinal Bertone that he had received
information (whileexpressing reservations about its accuracy) to the
effect that DAL BOSCOhad been involved with others in discussions
concerning a plot to destroythe Papacy ix. In a letter dated
July 31, 2010, which enclosed a package ofpertinent information, sent
via certified mail return receipt requested byMr. Bendana from his
residence in New Jersey, KEENAN advised BANKI-moon that DAL BOSCO, "an
Italian citizen, passport number C165124absconded with 1 Trillion
Dollars in BondslNotes which had beenentrusted to me yet belonged to the
Dragon Family." He further statedthat the "sole reason" he was writing
was that "it is the UNITEDNATIONS itself that set DAL BOSCO off on his
quest to either Sell theBonds or place them in a Private Program."
KEENAN further advisedthat "You have individuals inside the UN in Geneva
who know Mr. DalBosco and who offered him One Hundred Million USD for
them."Further, DAL BOSCOs "UN friends advised him that Mr. Yamaguchiwas a
very powerful member of the Dragon Family whose titles are
indeedSignature (sic)/Comptroller but that they at no cost wanted
Mr.Yamaguchi involved in this transaction. He was not even to receive
onecent for the Dragon Family." KEENAN also referenced DAL BOSCOsillicit
connections with OITC and SALE and the use of the UN "as a coverfor
their illegal dealings" as well as the danger posed to the United
Statesby the UNs condoning such activities through the promises of
"securityand secrecy" and called for a serious reprimand of any people
within theUN for their participation in the plot to steal the DFFI.
While KEENANnever received a direct response to his letter to BAN
KI-Moon, upon 70 74.
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 communicationfrom Keith F. Scott, formerly
associated with the OITC as Chief of Cabinet of OITC, SpecialEnvoy and
Executor for His Excellency Dr. Ray C. Dam and later, Chief of Council
of theCabinet. Scott directly contradicted the June 2010 communications
from SALE, and stated 71 75.
clearly that the DFFI are the rightful propertY of the Dragon Family
who are legally entitled tosame. 157. Scott also informed
KEENAN that in late September or early October 2010, hehad become aware
of one of Fulfords internet blogs regarding "the theft of a series of
HistoricalBonds that with their accrued value with interest coupons was
worth approximately One TrillionUnited 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 witnessedDAMs reaction
in anger as DAM explained to Scott that he had been aware that SALE
hadaccess 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 hisexperience 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 allrecords 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, holdvast assets which he
has substantiated to KEENAN by presenting "copies of official top
secretbank documents that confirm the amount of gold delivered by the
Dragon Family." Scott is clearand emphatic in stating that any
alienation of the Bonds from the Dragon Family or theirappointed Agents
is illegal. Scott maintains that the Dragon Family are the known
Depositors ofgold as well as other bullions and other assets in private
bank accounts held in Swiss Banks, andthat the DFFI were in fact
obligations of the Federal Reserve System against the assets blockedto
the Federal Reserve System Accounts. Scott explained that these assets
deposited in theDragon Family owned accounts were part of the
aforementioned "IPRA." 72 76.
160. In recent postings available to the world at large via the
Internet, SALE hasadmitted that it is "verifiable" through OITCs own
records that the "first ever writtencommunication from Mr. Dal Bosco was
within the first week of February 2010, in fact 2ndFebruary 2010."
Further SALE has published "a few relevant sections of the Agreement
datedMarch 2010" between DAL BOSCO and OITC "duly executed by DAM." It
has thus beenadmitted to a global audience by SALE, confirming KEENANs
worst suspicions, that DALBOSCO had contacted OITC no later than
February 2010, and entered into a written contractwith OITC no later
than March 2010, regarding the disposition of the DFFI with which he
hadbeen entrusted by KEENAN in September 2009. This further corroborates
the conversations thatDAL BOSCO had with Vasil Ganov in February 2010
in Zurich when trying to persuade Ganovto influence KEENAN to accept the
$100 Million USD bribe and when DAL BOSCO alluded toOITC as the
"owners" of the Notes which would be returned to OITC after having been
placed ina UN "Sovereign Program." It also corroborates DAL BOSCOs
discussions with NikolaiRaykov in May 2010 in Geneva (See ~~ 98-104; ~~
106-117, supra). 161. Further, it has become evident that
during the period in the very months afterKEENAN had entrusted DAL BOSCO
with the DFFI, namely early 2010, DAL BOSCO, in totaldereliction of his
fiduciary duties, was, in fact, embarking simultaneously upon
staggeringschemes to steal and convert the DFFI through his illiCit
actions, including bribery, not only withBRUNO, THE WORLD ECONOMIC
FORUM, the UNITED NATIONS, BAN KI-moon,RAGAGLINI, MIRACHIAN, BERLUSCONI,
the ITALIAN FINANCIAL POLICE, theITALIAN REPUBLIC and others but also
with OITC, SALE and DAM. These schemes wereplotted_solely for the
purpose of aggrandizing the various Defendants personal wealth at
theexpense of the rightful Legal Holders of the DFFI and their
designated agent KEENAN.
73 77. N. Recent Revelations Concerning th~ 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 orabout September 2008,
Brazilian financier, Carlo Alfredo Nascimento da Silva, with
theassistance of his attorney, Rubens Mariani, was planning to purchase
Banca CommercialeLugano, Lugano CH (Switzerland) ("Banca Cornmerciale").
Upon information and belief, thisplan came to be aided and abetted by
DAL BOSCO, BERLUSCONI and BRUNO, as well asretired Colonel of the
ITALIAN FINANCIAL POLICE, Mauricio Fanelli, Italian attorney,
PierreLuigi Manzione, and others. Further, upon information and belief,
the plan included the depositof stolen bonds and notes into Banca
Commerciale or any other Swiss bank to establish creditlines and to
enter into trading programs. The stolen assets which were to be
deposited includednot only all the DF Chiasso Instruments seized in June
2009, and still held by THE ITALIANFINANCIAL POLICE, but also the DFFI
stolen by DAL BOSCO in June 2010, andcontinuously held under his custody
or control. This information further confirms therecollection of Ognyan
Marinovs discussion with DAL BOSCO and BRUNO in Geneva in May2010 (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 asstated in the
last will and testament of the late President Soekamo of Indonesia and
heir son ofthe late Kiyai Hadji Djawahir, as well as the legal holder of
the Family Heritance Guarantee, asattached to all the gold deposits as
ordered by President Soekamo between 1948 and 1968 when
74 78. he was granted such
Heritance Guarantee as Cpayment for his services to the World." See
~2(iii)(c). 164. Dr. Soekanto swears that President Soekarno
had designated to him theresponsibility to collect all those funds known
as the Family Heritance Guarantee and theaccumulated interest thereon
and that he has "been acknowledged by depository bank, asevidenced by
the bank instruments, books, record and ledgers and codes in his
possession, as thesole 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
hisAttorneys in Fact "to act jointly and/or severably and to undertake
all means and methods torecover the funds owing to me and the People of
Indonesia." 165. Dr. Soekanto has further agreed and has
confirmed that he holds the "full secretBook of Codes (Maklumat Book)
and Ledgers and all Records of the Accounts as delivered" tohim and
that, upon their request, he will "deliver or cause delivery of the
originals of such booksfor 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 arepresently in
custody of certified copies of said Book of Codes (Maklumat Book) and
Ledgerswith the authorizations to use them when needed. 166.
These Books and Ledgers define the information that is held in the
FederalReserve screen system. They contain the secret code cyphers and
data on legal decisions,treaties and other arrangements. Upon
information and belief, they provide informationpertaining to all the
accounts and sub-accounts that contain the gold and other assets, as
well asinformation pertaining to the financial instruments issued
against the gold. Further, they specifyand provide the factual
information as to what is in the Global Accounts, such as who owns the
75 [*]79. gold and
the source of its ownership. The protection and security of these Books
is, therefore, ofthe utmost importance and central to the authentication
and verification process. AS AND FOR A FIRST CAUSE OF ACTION AGAINST
DEFENDANT DAL BOSCO [Expropriation and Conversio~ under Federal Common
Law and International Law] 167. Plaintiff repeats and
realleges each of the allegations contained in paragraphs 1through 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 behalfof 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 forthe private placement of or legal return of the DFFI, KEENAN
lawfully possessed the DFFI. 169. KEENAN released custodianship
of the DFFI to defendant DAL BOSCOpursuant to his written ACCEPTANCE of
September 9, 2009, whereby DAL BOSCO wouldretain custody of the DFFI
for safekeeping while KEENAN travelled throughout Europe in hiseffort to
invest the DFFI in recognized PPPs. DAL BOSCO agreed to only return
custody of theDFFI over to KEENAN or Yamaguchi and "Not any other!"
170. DAL BOSCO proceeded to engage in a course of conduct totally
contrary to hisoral and written agreement. Such actions were taken
intentionally and without authority by DALBOSCO, who at all relevant
times engaged in the unauthorized assumption and exercise of rightof
ownership of the DFFI, thus interfering with KEENANs right of
possession. Suchunauthorized assumption of control is evidenced, in
part, by DAL BOSCOs following andunauthorized activities, alone and in
conspiracy with others:
76 [/*]80. (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, asdetailed supra,
KEENAN demanded orally and in writing on multiple occasions that
DALBOSCO return the DFFI to KEENANs possession. 172. Despite
these demands, DAL BOSCO unlawfully withheld possession of theDFFI 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 conversionof the DFFI by DAL BOSCO and, at a minimum, DAL
BOSCO is required to pay the full valueof the DFFI and all of its
accumulated interest, with interest. DAL BOSCO is also required to
77 [*]81. pay KEENANs
lost profits from the fees to which he was entitled for performing his
servicesfor the Dragon Family with respect to coordinating the placement
of the DFFI into an approvedtrading program. 174.
Consequently, KEENAN has been damaged by the conversion of the DFFI
bydefendant DAL BOSCO and has sustained damage in a sum to be determined
at trial, butbelieved 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 1through 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, theITALIAN FINANCIAL POLICE,
and the ITALIAN REPUBLIC entered into an agreementwhereby each party
knowingly and voluntarily agreed to participate in a scheme to steal
andconvert certain financial instruments for the purpose of profiting
from this theft of financialinstruments, including the DFFI. Among the
prospective unlawful uses planned for the DFFI bysaid defendants was the
purchase of a Swiss Bank, such as Banco Commerciale di Lugano, orany
other Swiss Bank into which they could immediately move all stolen
assets, including theDFFI. 177. Upon information and belief,
defendants BRUNO and the WORLD ECONOMICFORUM and/or the WORLD ECONOMIC
FORUM USA, INC. knowingly and voluntarilyagreed to participate in this
scheme to convert various financial instruments, including the DFFI.
78 [/*]82. Defendants
BRUNO and the WEF and/or WEF USA further knowingly and voluntarily
agreedto utilize their connections within the defendant UNITED NATIONS
to set up SovereignPrograms for the investment of the unlawfully
obtained financial instruments that they knew tobe either stolen or
seized under color of police authority of the ITALIAN FINANCIAL POLICEor
unlawfully obtained by others, and which included the DFFI, to the
profit of all the co-conspirators. 178. Upon information and
belief, BRUNO, acting within his authority as the Directorresponsible
for the Financial Services Industry Group of the defendant WEF and/or
WEF USA inits New York City offices, and defendants BERLUSCONI, H.E.
Ambassador CESARE MARIARAGAGLINI, 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 UNin Geneva,
defendant BAN KI-moon, Secretary-General of the United Nations, and
otherunknown representatives of defendants the ITALIAN REPUBLIC, the
ITALIAN FINANCIALPOLICE and the UNITED NATIONS procured an agreement
entered into knowingly andvoluntarily by the foregoing defendants
whereby the unlawfully obtained financial instrumentsthat said
defendants knew to be either stolen or seized under color of police
authority of theITALIAN FINANCIAL POLICE or unlawfully obtained by
others, and which included theDFFI, would be invested in a " Sovereign
Program" wholly under the auspices, protection andumbrella of the
"sovereign immunity" allegedly accorded to the UNITED NATIONS and
theITALIAN REPUBLIC. 179. Upon information and belief, in
furtherance of the aforesaid civil conspiracy,defendants the ITALIAN
FINANCIAL POLICE and the ITALIAN REPUBLIC intentionallyparticipated in
the furtherance of the plan by seizing the DF Chiasso Instruments in an
amount 79 83.
approximating $134.5 Billion U.S. Dollars from Dragon Family
representatives Yamaguchi andWatanabe. This seizure of the DF Chiasso
Instruments, which incident was described in detailsupra, was then
utilized by the defendant co-conspirators as a pretext for introducing
DALBOSCO to KEENAN for the purpose of convincing KEENAN that it would be
wise to entrustcustody of the DFFI to DAL BOSCO in order to avoid a
similar incident from occurring withrespect to the D FFI. 180.
Further upon information and belief, in furtherance of the aforesaid
civilconspiracy, defendant DAL BOSCO intentionally participated in the
furtherance of the plan bymaking knowingly false material
representations to KEENAN for the purposes of inducingKEENAN to
relinquish custody of the DFFI into DAL BOSCOs possession, orchestrating
andparticipating in the numerous attempts to bribe KEENAN in an effort
to induce KEENAN toparticipate in the theft of the DFFI from the Dragon
Family as detailed supra, and ultimatelyabsconding with the DFFI when
the attempts to bribe KEENAN were unsuccessful. 181. In
furtherance of the aforesaid civil conspiracy, defendant BRUNO, acting
withinhis capacity and authority as the Director responsible for the
~inancial Services Industry Groupof the defendant WEF andlor WEF USA in
its New York City offices, intentionally participatedin the furtherance
of the plan by offering KEENAN a $100 Million USD bribe to be split
withDAL BOSCO in an effort to obtain his participation and cooperation
in the theft of the DFFIfrom 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 toparticipate 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 84.
Financial Services Industry Group of the defendant WEF and! or WEF USA
in its New York Cityoffices, defendants RAGAGLINI, MARACHIAN,
BERLUSCONI, the ITALIAN FINANCIALPOLICE, the ITALIAN REPUBLIC, BAN
KI-moon, the UNITED NATIONS and otherunknown individual co-conspirators
acting on behalf of defendants the ITALIAN FINANCIALPOLICE, the ITALIAN
REPUBLIC and the UNITED NATIONS intentionally participated inthe
furtherance of the conspiracy by planning, negotiating, developing and
facilitating thecreation of a UN Sovereign Program for the investment of
the stolen DFFI. Said defendantsactions in this regard also furthered
the conspiracy in that said defendants, in an effort to obtainKEENANs
cooperation in the conspiracy to convert the DFFI, repeatedly
misrepresented toKEENAN and his acquaintances as detailed supra, that by
acting in conjunction with the WEFandlor WEF USA, the ITALIAN FINANCIAL
POLICE, the ITALIAN REPUBLIC and theUNITED NATIONS, all of the
individual co-conspirators illegal actions would be protectedunder the
umbrella of sovereign immunity. 183. KEENAN has suffered
serious financial detriment on account of and as a directproximate
result of the civil conspiracy to expropriate and convert the DFFI and,
at a minimum,defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the
ITALIANFINANCIAL 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 DFFIand all of its accumulated interest, with
interest. Said defendants are also jointly and severallyliable for
KEENANs lost profits from the fees to which he was entitled for
performing hisservices for the Dragon Family with respect to
coordinating the placement of the DFFI into anapproved trading program.
81 [*]85. 184.
Consequently, KEENAN has been damaged by the civil conspiracy to
expropriateand convert the DFFI by defendants DAL BOSCO, BERLUSCONI,
RAGAGLINI,MlRACIDAN, the ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC,
BAN KI-moon, the UNITED NATIONS, BRUNO, WEF andlor WEF USA and has
sustained damage in asum 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 1through 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, haddiscussions with defendant OITC and its President,
defendant SALE, who was acting with theknowledge 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 defraudingKEENAN into relinquishing control
of and ultimate defalcation of the DFFI, which were then tobe traded
under DAMs Federal Reserve Master Commitment Holder Trading License. As
aresult of these discussions, defendants OITC, SALE and DAM knowingly
and voluntarily agreedto participate in this scheme to unlawfully steal
and convert the DFFI from KEENAN.According to recently published
admissions by defendant SALE, DAL BOSCO admittedlycontacted OITC no
later than February 2010, and entered into a written contract with OITC
nolater than March 2010, whereby said parties agreed to steal and
convert the DFFI, which had
82 [/*]86. been temporarily entrusted to DAL BOSCO, in complete
contravention ofDAL BOSCOs oraland 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 bytaking 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 perpetuatehis
fraud and convert the DFFI. Said acts in furtherance of the civil
conspiracy include thefollowing 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.directproximate 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 [*]87. 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 KEENANs lost profits from
thefees to which he was entitled for performing his services for the
Dragon Family with respect tocoordinating the placement of the DFFI into
an approved trading program. 189. Consequently, KEENAN has
been damaged by the civil conspiracy to expropriateand convert the DFFI
by defendants DAL BOSCO, SALE, DAM and OITC and has sustaineddamage 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 1through 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 KJ-moon, the UNITED
NATIONS, BRUNO, WEF and/or WEF USA violate any and all notions ofjus
cogens, a body of peremptory principles of customary and universal
intemationallawrecognized by civilized nations. At a minimum, the
actions of said defendants constitute aknowing and willful participation
to aid and abet the theft and conversion of the DFFI, valued
atapproximately ONE TRlLLION UNITED STATES DOLLARS, which theft and
conversion wascarried out by defendant DAL BOSCO, who personally
absconded with the DFFI.
84 [/*]88. 192. Upon information and beliet defendant BRUNO,
acting within his capacity andauthority as the Director responsible for
the Financial Services Industry Group of the defendantWEF 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 behalfof and with the approval of defendants the ITALIAN
FINANCIAL POLICE, the ITALIANREPUBLIC and the UNITED NATIONS, with
knowledge of the planned theft and conversion ofthe DFFI from its true
and rightful owners, and for the express purpose of facilitating
theconversion of the DFFI from its true and rightful owners, provided
substantial assistance in theexpropriation and conversion of the DFFI
from KEENAN by planning, negotiating, developingand facilitating the
creation of a UN Sovereign Program for the investment of the
DFFIpurportedly under the umbrella of the ITALIAN REPUBLICs and the
UNITED NATIONssovereign immunity. In doing so, these defendants provided
practical assistance, encouragementand moral support to the
expropriation and conversion of the DFFI from KEENAN. 193. The
substantial assistance and complicity of defendants BRUNO, WEF and/orWEF
USA, RAGAGLINI, MARACHIAN, BERLUSCONI, the ITALIAN FINANCIALPOLICE, the
ITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS and otherunknown
individual co-conspirators acting on behalf of and with the approval of
defendants theWEF and/or WEF USA, the ITALIAN FINANCIAL POLICE, the
ITALIAN REPUBLIC andthe UNITED NATIONS in the theft and conversion of
the DFFlis further illustrated by thefollowing acts performed with
knowledge of the planned theft and conversion of the DFFI fromits true
and rightful owners, and for the express purpose of providing
substantial assistance in theconversion of the DFFI from its true and
rightful owners: 85 [*]89.
(1) . Defendant UNITED NATIONS knowingly and activelyparticipated in
the conversion of the DFFI stolen by DAL BOSCO when it agreedto offer a
bribe to KEENAN in the amount of $100 Million USD in an effort toobtain
KEENANs cooperation in the conversion of the DFFI, for its own
benefit,those of its representatives, including defendants BAN KI -moon,
for the benefitof defendants the ITALIAN REPUBLIC and its
representatives, includingdefendants BERLUSCONI, RAGAGLINI, MlRACHIAN
and the ITALIANFINANCIAL POLICE, and for the benefit of the WEF andlor
WEF USA, and itsrepresentative, defendants BRUNO, and for the benefit of
others presentlyunknown, who participated in and aided and abetted the
criminal enterprise. (2) As part of the criminal enterprise
and scheme, defendant DALBOSCO made contact with high level UN officials
through the assistance ofdefendants BRUNO and the WEF andlor WEF USA,
and as a result defendantsthe UNITED NATIONS and BAN KI-moon knowingly
and actively approved thepurchase of the DFFI, which it knew had been
stolen by DAL BOSCO, not onlyfor the purpose of aiding and abetting the
conspiracy, but entered into the schemewith the avowed purpose of
further concealing the theft and actively engaging inthe conversion of
the DFFI by: (1) purchasing the DFFI then in the possession ofDAL BOSCO
who had breached his fiduciary duties to KEENAN as temporarycustodian 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 aSovereign Program for its own financial benefit; (4) all of the
above to beaccomplished without the knowledge of the Legal Holders of
the DFFI, theDragon Family. (3) The complicity of defendants
the WEF andlor WEF USA, theUNITED NATIONS, the ITALIAN FINANCIAL POLICE
and the ITALIANREPUBLIC is apparent from the telephone conference call
placed to BRUNO byDAL BOSCO on a speaker phone in the VIP Room of the
Hotel Zurich inSwitzerland in early February 2010. Such call was made
via internationaltelephone communication between DAL BOSCO and defendant
BRUNO, of theWEF and/or WEF USA, who, upon information and belief,
participated from NewYork, New York wherein the participation and
approval of the UNITEDNATIONS was described in detail by BRUNO, who
represented that he could"put 100 Million Dollars into KEENANs hands if
KEENAN agreed [to releasethe DFFI in contravention of the Dragon Familys
rights in the same]." After thiscall, Vasil Ganov, who had been present
for the call inquired of what DALBOSCO would receive from the
"transaction." DAL BOSCO stated that hewould receive half of the $100
Million USD offered to KEENAN for hisassistance, which he indicated
would be placed into a Sovereign Program by theUN and that they would
receive 200% monthly returns minimum from the total"investment." DAL
BOSCO refused to comment on how much defendants theUN, WEF andlor WEF
USA, BRUNO and OITC would receive from thetransaction, indicating that
such an inquiry "can only cause trouble." DAL
86 [/*]90. 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 theirrightful "owners," which he
indicated was the OITC. DAL BOSCO furtherinformed Ganov that "everyone
was protected by the ITALIAN FINANCIALPOLICE and the Italian Government
itself." (4) This complicity is also corroborated by the
international telephonecommunication between DAL BOSCO and BRUNO, as
overheard and describedby Nikolay Raykov during his trip to the Zurich
airport with DAL BOSCOfollowing the telephone conference speaker call
described above, and byRaykovs other interactions with DAL BOSCO and
BRUNO. In the telephoneconversation, BRUNO represented to Raykov that
the DFFI would "be placedinto a federal program using the UN as
protection" along with "his company"referring to the WEF and/or WEF USA,
which would "generate unlimited capitalfor everyone involved."
According to BRUNO, "there would be no problems andthat this was being
blessed by the UNITED NATIONS" which "would protecteveryone" as the DFFI
would be "placed into a Sovereign Program" after whichthe DFFI "would
disappear" and "there would be no questions asked." In asubsequent
telephone call between Raykov and BRUNO, which took place whileboth
parties were in New York, BRUNO advised Raykov that DAL BOSCO
hadabsconded with the DFFI and that "now more than ever" Raykov was
needed toconvince KEENAN to cooperate in the conspiracy to deprive the
Dragon Familyof its interest in the DFFI. At a subsequent meeting
between Raykov, BRUNOand DAL BOSCO at the Balexert Mall in Switzerland
in May 2010, BRUNOcommented 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 wereabout to be completed with or without
KEENAN." BRUNO again requestedRaykovs assistance in convincing KEENAN to
participate in the scheme. WhenRaykov indicated that KEENAN would not
listen to him, BRUNO exclaimed,"Not even for 500 Million U.S. Dollars?"
BRUNO then encouraged Raykov tocall him at his New York office of the
WEF USA to speak about the matterfurther. (5) Defendants
complicity was further corroborated during the courseof the meeting
between DAL BOSCO, BRUNO and Miranov at the Balexert mallin Switzerland
in May 2010. At this meeting, defendant BRUNO explained whowas involved
in the conspiracy to convert the DFFI, specifically namingdefendants
RAGAGLINI, MlRAClllAN, BERLUSCONI, and the ITALIANFINANCIAL POLICE,
stating: "so you see there is no possible way we can havea problem. We
can cloak ourselves with the immunity shield and everyone willgo away.
Just another day in the UN!" During this meeting held for the purposeof
convincing Miranov to assist the defendants in their theft, a telephone
call wasreceived from defendant H.E. Ambassador MlRACHIAN,
PermanentRepresentative of the Italian Mission to the UN in Geneva, who
confirmed thedirect knowledge and approval of the UNITED NATIONS
Secretary General, 87 [*]91.
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 directand proximate result of defendants acts
aiding and abetting the expropriation and conversion ofthe 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 andlor WEF USA are jointly and severallyliable for
the full value of the DFFI and all of its accumulated interest, with
interest. DefendantsDAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the
ITALIAN FINANCIALPOLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITED
NATIONS, BRUNO, WEFandlor WEF USA are also jointly and severally liable
for KEENANs lost profits from the feesto which he was entitled for
performing his services for the Dragon Family with respect
tocoordinating the placement of the DFFI into an approved trading
program. 195. Consequently, KEENAN has been damaged by the
actions of defendants DALBOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN, the
ITALIAN FINANCIAL POLICE,the ITALIAN REPUBLIC, BAN KI-moon, the UNITED
NATIONS, BRUNO, WEF andlorWEF USA aiding and abetting the expropriation
and conversion of the DFFI and has sustaineddamage 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]
88 [/*]92. 196. Plaintiff repeats and reallege~ each of the
allegations contained in paragraphs 1through 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
UNITEDNATIONS violate any and all notions ofjus cogens, a body of
peremptory principles ofcustomary and universal international law
recognized by civilized nations. At a minimum, theactions of said
defendants constitute a knowing and willful participation to aid and
abet the theftand conversion of the DFFI, valued at approximately ONE
TRILLION UNITED STATESDOLLARS, which theft and conversion was carried
out by defendant DAL BOSCO, whopersonally absconded with the DFFI.
198. Defendants SALE and DAM acting on behalf of defendant OITC,
withknowledge of the planned theft and conversion of the DFFI from its
true and rightful owners, andfor the express purpose of facilitating the
conversion of the DFFI from its true and rightfulowners, provided
substantial assistance in the expropriation and conversion of the DFFI
fromKEENAN by taking the position that the DFFI stolen and converted by
DAL BOSCO were infact the "property" ofOITC rather than the Dragon
Family, thereby enabling DAL BOSCO toperpetuate his fraud and convert
the DFFI. In doing so, these defendants provided practicalassistance,
encouragement and moral support to the expropriation and conversion of
the DFFIfrom KEENAN. Said acts in substantial assistance to the
conversion of the DFFI fromKEENAN, which were made with knowledge of and
for the purpose of facilitating theconversion of the DFFI, include the
following statements and/or actions of OITC, through SALEand 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 93. 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 fraudulentactivities of
OITC in that it has never formally denounced or disassociated itself
from OITC, andhas allowed OITC to hold itself out to the world community
as protected by its umbrella oflegitimacy and chartered by the UNITED
NATIONS itself. Upon information and belief,defendant the UNITED
NATIONS, with knowledge of the planned theft and conversion of theDFFI
from its true and rightful owners, and for the express purpose of
facilitating the conversionof the DFFI from its true and rightful
owners, provided substantial assistance in the expropriationand
conversion of the DFFI from KEENAN by allowing and actively encouraging
the OITC torepresent itself as affiliated with and charted by the UNITED
NATIONS in OITCs efforts toconvince KEENAN to release the DFFI to
defendants on the purported basis that the DFFIbelonged to 0 ITC rather
than the Dragon Family.
90 [*]94. 200. KEENAN has suffered seriofts financial detriment
on account of and as a directand proximate result of the action of
defendants DAL BOSCO, SALE, DAM, OITC and theUNITED NATIONS aiding and
abetting the expropriation and conversion of the DFFI and, at aminimum,
said defendants are jointly and severally liable for the full value of
the DFFI and allof its accumulated interest, with interest. Defendants
DAL BOSCO, SALE, DAM, OITC andthe UNITED NATIONS are also jointly and
severally liable for KEENANs lost profits fromthe fees to which he was
entitled for performing his services for the Dragon Family with
respectto coordinating the placement of the DFFI into an approved
trading program. 201. Consequently, KEENAN has been damaged by
the actions of defendants DALBOSCO, SALE, DAM, OITC and the UNITED
NATIONS aiding and abetting the expropriationand conversion of the DFFI
and has sustained damage in a sum to be determined at trial, butbelieved
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 1through 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 withKEENAN in July 2009 for the
conscious purpose of gaining his trust and confidence with theintention
of fraudulently inducing KEENAN to transfer custodianship and control
of the DFFI inorder that DAL BOSCO and his co-conspirators could
unjustly enrich themselves for their ownpersonal benefit and utterly to
the detriment of KEENAN and the Dragon Family. 204. At all
relevant times, DAL BOSCOs intention was to knowingly assume controland
exercise ownership over the DFFI in contravention of the rights of
KEENAN and the 91 [/*]95.
Dragon Family and to utilize the DFFI in various selfish and unlawful
ways, including thepronouncement by OITC through its unlawful Cease and
Desist Order of its alleged legalownership of the D FFI and further
criminal actions as described herein 205. Despite DAL BOSCOs
knowledge and intent to abscond with the DFFI for hisown personal
benefit and the benefit of his co-conspirators, he falsely
misrepresented toKEENAN, 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 canassure you that you
will never regret making this decision"; (2) "You are aware of the fact I
amwell trusted and a financial advisor within the Vatican and Mason
circles and would neverjeopardize my position with them for anything";
(3) "My word is my bond and my word isGold"; (4) "I will be waiting for
your Zurich arrival so that we can do great things for theworld"; (5) "I
understand clearly that I am not to discuss these bonds with anyone
outside theimmediate circle and my privacy is integral to the success of
many nations"; (6) "I furtherunderstand you are the authorized
representative and Power of Attorney for said bonds and I willentrust
them believe me as though it was my life depending on it. Therefore I
humbly accept thecustodianship 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
bindingacceptance of the following bonds (bonds listed)"; (8) "Will be
ready when called upon todeliver said notes to you." 206.
KEENAN reasonably and justifiably relied, to his severe personal
detriment, onthe knowingly false material misrepresentations ofDAL BOSCO
set forth above, as well as thenumerous material oral
misrepresentations of a similar or identical nature made by DAL
BOSCObetween July and September 2009 set forth in detail in the
Complaint at paragraphs 70 through
92 [*]96. 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 toinduce plaintiff KEENAN to rely on
said misrepresentations and convince KEENAN to transfercustody of the
DFFI to him. KEENAN has suffered serious financial detriment on account
of andas a direct and proximate result of defendant DAL BOSCOs fraud
and, at a minimum, DALBOSCO is liable for the full value of the DFFI and
all of its accumulated interest, with interest.DAL BOSCO is also liable
for KEENANs lost profits from the fees to which he was entitled
forperforming his services for the Dragon Family with respect to
coordinating the placement of theDFFI into an approved trading program.
208. Consequently, DAL BOSCOs intentional failure to return the
DFFI, which wereentrusted to him by KEENAN on the basis of his numerous
misrepresentations, has causedsevere financial detriment to KEENAN.
Consequently, KEENAN has sustained damage in asum 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 1through 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,
theITALlAN FINANCIAL POLICE, and the ITALIAN REPUBLIC entered into an
agreementwhereby each party knowingly and voluntarily agreed to
participate in a scheme to steal certain
93 [/*]97. financial instruments for the purpose
of profiting from this theft of financial instruments. As partof this
scheme, defendants DAL BOSCO, BERLUSCONI, the ITALIAN FINANCIAL
POLICE,and the ITALIAN REPUBLIC knowingly and voluntarily agreed to
defraud KEENAN of theDFFI. Among the prospective unlawful uses planned
for the DFFI by said defendants was thepurchase of a Swiss Bank, such as
Banco Commerciale di Lugano, or any other Swiss Bank intowhich they
could immediately move all stolen assets, including the DFFI. 211.
Upon information and belief, sometime thereafter, defendants BRUNO
and theWORLD ECONOMIC FORUM and/or the WORLD ECONOMIC FORUM USA,
INC.knowingly and voluntarily agreed to participate in this scheme to
assist DAL BOSCO in hiseffort to obtain the DFFI from KEENAN through
various acts of fraud. Defendants BRUNO andthe WEF and!or WEF USA
further knowingly and voluntarily agreed to utilize their
connectionswithin the defendant UNITED NATIONS to set up Sovereign
Programs for the investment of theunlawfully obtained financial
instruments that they knew to be either stolen or seized under colorof
police authority of the ITALIAN FINANCIAL POLICE or unlawfully obtained
by others, andwhich included the DFFI, to the profit of all the
co-conspirators. Among the prospectiveunlawful uses planned for the DFFI
by said defendants was the purchase of a Swiss Bank, suchas Banco
Commerciale di Lugano, into which the DFFI, in combination with other
stolen orseized assets, could be deposited and traded for the profit of
said co-conspirators. 212. Upon information and belief,
thereafter BRUNO, acting within his authority asthe Director responsible
for the Financial Services Industry Group of the defendant WEF
and/orWEF USA in its New York City offices, and defendants BERLUSCONI,
H.E. AmbassadorCESARE MARIA RAGAGLINI, Permanent Representative of the
Italian Mission to the UN inNew York, H.E. Ambassador LAURA MlRACHIAN,
Permanent Representative of the Italian
94 98. Mission to the UN in Geneva, defendant BAN Kl-moon,
Secretary-General of the UnitedNations, and other unknown
representatives of defendants the ITALIAN REPUBLIC, theITALIAN FINANCIAL
POLICE and the UNITED NATIONS procured an agreement enteredinto
knowingly and voluntarily by the foregoing defendants whereby the
unlawfully obtainedfinancial instruments that said defendants knew to be
either stolen or seized under color of policeauthority of the ITALIAN
FINANCIAL POLICE or unlawfully obtained by others, and whichincluded the
DFFI to be obtained by DAL BOSCOs fraud, would be invested in a
"SovereignProgram" 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 conspiracyto defraud, defendants the
ITALIAN FINANCIAL POLICE and the ITALIAN REPUBLICintentionally
participated in the furtherance of the plan by seizing the DF Chiasso
Instruments inan amount approximating $134.5 Billion U.S. Dollars from
Dragon Family representativesYamaguchi and Watanabe. This seizure of the
DF Chiasso Instruments, which incident wasdescribed in detail supra,
was then utilized by the defendant co-conspirators as a pretext
forintroducing DAL BOSCO to KEENAN for the purpose of convincing KEENAN,
throughnumerous misrepresentations detailed supra that it would be wise
to entrust custody of the DFFIto 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
conspiracyto defraud KEENAN, defendant DAL BOSCO intentionally
participated in the furtherance of theplan by making knowingly false
material representations to KEENAN for the purposes ofinducing KEENAN to
relinquish custody of the DFFI into DAL BOSCOs possession,orchestrating
and participating in the numerous attempts to bribe KEENAN in an effort
to induce 95 99.
KEENAN to participate in the fraudulent scheme as detailed supra, and
ultimately byabsconding with the DFFI when the attempts to bribe KEENAN
were unsuccessful. 215. In furtherance of the aforesaid civil
conspiracy to defraud KEENAN, defendantBRUNO, acting within his capacity
and authority as the Director responsible for the FinancialServices
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 MillionUSD bribe to be split with DAL BOSCO in an
effort to obtain his participation and cooperationin 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 toparticipate in their fraudulent
scheme. 216. Upon information and belief, in furtherance of the
aforesaid civil conspiracy todefraud KEENAN, defendants BRUNO, acting
within his capacity and authority as the Directorresponsible for the
Financial Services Industry Group of the defendant WEF and/or WEF USA
inits New York City offices, defendants RAGAGLINI, MARACHIAN, and
BERLUSCONI, theITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC,_ BAN
KI-moon, the UNITEDNATIONS and other unknown individual co-conspirators
acting on behalf of defendants theITALIAN FINANCIAL POLICE, the ITALIAN
REPUBLIC and the UNITED NATIONSintentionally participated in the
furtherance of the conspiracy by planning, negotiating,developing and
facilitating the creation of a UN Sovereign Program for the investment
of theDFFI to be fraudulently obtained from KEENAN. Said defendants
actions in this regard alsofurthered the conspiracy to defraud KEENAN in
that said defendants, in an effort to obtainKEENANs cooperation in the
fraudulent scheme, repeatedly misrepresented to KEENAN andhis
acquaintances as detailed supra, that by acting in conjunction with the
WEF, WEF USA, the 96 100.
ITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS,
allof the individual co-conspirators illegal actions would be protected
under the umbrella ofsovereign immunity. 217. KEENAN has
suffered serious financial detriment on account of and as a
directproximate result of the civil conspiracy to defraud KEENAN of the
DFFI and, at a minimum,defendants DAL BOSCO, BERLUSCONI, RAGAGLINI,
MlRACHIAN, the ITALIANFINANCIAL 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 DFFIand 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 andseverally liable for KEENANs lost profits from
the fees to which he was entitled for performinghis services for the
Dragon Family with respect to coordinating the placement of the DFFI
intoan approved trading program. 218. Consequently, KEENAN
has been damaged by the civil conspiracy to defraudhim of the DFFI by
defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN,the ITALIAN
FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the UNITEDNATIONS,
BRUNO, WEF and/or WEF USA and has sustained damage in a sum to
bedetermined at trial, but believed to be in excess of One Trillion
($1,000,000,000,000.00) USdollars.
97 [*]101. 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 1through 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 withthe knowledge of and under the
authority of defendant DAM, to discuss various fraudulentschemes,
options andlor alternative actions DAL BOSCO and the other defendants,
includingOITC, SALE and DAM, would take with respect to bribing KEENAN
or otherwise defraudingKEENAN into relinquishing control of and ultimate
defalcation of the DFFI, which were then tobe traded under DAMs Federal
Reserve Master Commitment Holder Trading License. As aresult of these
discuss~ons, defendants OITC, SALE and DAM knowingly and voluntarily
agreedto participate in this scheme to participate in this scheme to
obtain the DFFI from KEENAN byfraud. According to recently published
admissions by defendant SALE, DAL BOSCOadmittedly contacted OITC no
later than February 2010, and entered into a written contract withOITC
no later than March 2010, whereby said parties agreed to assist DAL
BOSCO in thefraudulent scheme to abscond with the DFFI for the
enrichment of all co-conspirators. 221. In furtherance of
the aforesaid civil conspiracy to defraud KEENAN, defendantsSALE and
DAM, acting on behalf of defendant OITC, intentionally participated in
thefurtherance of the plan by taking the position that the DFFI stolen
and converted by DALBOSCO were, in fact, the "property" of OITC rather
than the Dragon Family, thereby enablingDAL BOSCO to perpetuate his
fraud and convert the DFFI. Said acts in furtherance of the
civilconspiracy include the following statements andlor actions of OITC,
through SALE and DAM: 98 [/*]102.
(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
directproximate 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 fullvalue 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 KEENANs lost profits
from thefees to which he was entitled for performing his services for
the Dragon Family with respect tocoordinating the placement of the DFFI
into an approved trading program. 223. Consequently, KEENAN has
been damaged by the civil conspiracy to defraudhim of the DFFI by
defendants DAL BOSCO, SALE, DAM and OITC and has sustained damagein a
sum to be determined at trial, but believed to be in excess of One
Trillion($1,000,000,000,000.00) US dollars.
99 [*]103. 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 Boscos Fraud under Federal Common Law and International
Law] 224. Plaintiff repeats
and realleges each of the allegations contained in paragraphs 1through
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 KJ-moon, the UNITED NATIONS, BRUNO, WEF and WEF
USA violate any and all notions ofjuscogens, a body of peremptory
principles of customary and universal international law recognizedby
civilized nations. At a minimum, the actions of said defendants
constitute a knowing andwillful participation to aid and abet the
defrauding of KEENAN of the DFFI, valued atapproximately ONE TRILLION
UNITED STATES DOLLARS, which fraud was completed bydefendant DAL BOSCO,
who personally obtained the DFFI from KEENAN through
fraudulentmisrepresentations. 226. Upon information and belief,
defendant BRUNO, acting within his capacity andauthority as the
Director responsible for the Financial Services Industry Group of the
defendantWEF andlor 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 behalfof and with the approval of
defendants the ITALIAN FINANCIAL POLICE, the ITALIANREPUBLIC and the
UNITED NATIONS, with knowledge of the plan to fraudulently obtain
theDFFI, and for the express purpose of facilitating said fraud,
provided substantial assistance to the
100 [/*]104. fraudulent scheme by planning,
negotiating; developing and facilitating the creation of a UNSovereign
Program for the investment of the DFFI to be fraudulently obtained from
Keenan. Infurther substantial assistance of the fraudulent scheme, said
defendants, in an effort to obtainKEENANs cooperation, repeatedly
misrepresented to KEENAN and his acquaintances asdetailed supra, that by
acting in conjunction with the WEF andlor WEF USA, the ITALIANFINANCIAL
POLICE, the ITALIAN REPUBLIC and the UNITED NATIONS, all of
theindividual co-conspirators illegal actions would be protected under
the umbrella of sovereignimmunity. In doing so, these defendants
provided practical assistance, encouragement and moralsupport to the
fraudulent deprivation of the DFFI from KEENAN and the Dragon Family.
227. The substantial assistance and complicity of defendants
BRUNO, WEF, WEFUSA, RAGAGLINI, MARACHIAN, BERLUSCONI, the ITALIAN
FINANCIAL POLICE, theITALIAN REPUBLIC, BAN KI-moon, the UNITED NATIONS
and other unknown individualco-conspirators acting on behalf of and with
the approval of defendants the WEF andlor WEFUSA, the ITALIAN FINANCIAL
POLICE, the ITALIAN REPUBLIC and the UNITEDNATIONS in the fraudulent
scheme to deprive KEENAN and the Dragon Family of the DFFI isfurther
illustrated by the following acts performed with knowledge of the
fraudulent andunlawful nature of the scheme, and for the express purpose
of providing substantial assistancetherein: (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 KEENANs 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
101 [*]105. BRUNO, and for
the benefit of othets presently unknown, who participated in andaided
and abetted the criminal enterprise. (2) As part of the
criminal enterprise and scheme, defendant DALBOSCO made contact with
high level UN officials through the assistance ofdefendants BRUNO and
the WEF and/or WEF USA, and as a result defendantsthe UNITED NATIONS and
BAN KI -moon knowingly and actively approved thepurchase of the DFFI,
which it knew had been on the basis of fraudulentmisrepresentations by
DAL BOSCO, not only for the purpose of aiding andabetting the
conspiracy, but entered into the scheme with the avowed purpose
offurther concealing the fraud and actively engaging in the conversion
of the DFFIby: (1) purchasing the DFFI then in the possession of DAL
BOSCO who hadbreached his fiduciary duties to KEENAN as temporary
custodian of the DFFI byfraudulently 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 aSovereign Program for its own
financial benefit; (4) all of the above to beaccomplished without the
knowledge of the Legal Holders of the DFFI, theDragon Family. (3)
The complicity of defendants the WEF, the WEF USA, theUNITED
NATIONS, the ITALIAN FINANCIAL POLICE and the ITALIANREPUBLIC is
apparent from the telephone conference call placed to BRUNO byDAL BOSCO
on a speaker phone in the VIP Room of the Hotel Zurich inSwitzerland on
or about February 2010. Such call was made via internationaltelephone
communication between DAL BOSCO and defendant BRUNO, of theWEF and/or
WEF USA, who participated from New York, New York wherein
theparticipation and approval of the UNITED NATIONS was described in
detail byBRUNO, who represented that he could "put 100 Million Dollars
intoKEENANs hands if KEENAN agreed [to release the DFFI in contravention
ofthe Dragon Familys rights in the same]." After this call, Vasil
Ganov, who hadbeen 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 MillionUSD offered to KEENAN for his assistance, which
he indicated would be placedinto a Sovereign Program by the UN and that
they would receive 2000/0 monthlyreturns minimum from the total
"investment." DAL BOSCO refused to commenton how much defendants the UN,
WEF and/or WEF USA, BRUNO and OITCwould receive from the transaction,
indicating that such an inquiry "can onlycause trouble." DAL BOSCO did,
however, indicate that the stolen Notes wouldbe placed into a "Sovereign
Program by the UN," and upon completion would bereturned to their
rightful "owners," which he misrepresented was the OITC. DALBOSCO
further informed Ganov that "everyone was protected by the
ITALIANFINANCIAL POLICE and the Italian Government itself."
102 [/*]106. (4) This complicity is
also corroborated by the international telephonecommunication between
DAL BOSCO and BRUNO, as overheard and describedby Nikolay Raykov during
his trip to the Zurich airport with DAL BOSCOfollowing the telephone
conference speaker call described above, and byRaykovs other
interactions with DAL BOSCO and BRUNO. In the telephoneconversation,
BRUNO represented to Raykov that the DFFI would "be placedinto a federal
program using the UN as protection" along with "his company"referring
to the WEF andlor WEF USA, which would "generate unlimited capitalfor
everyone involved." According to BRUNO, "there would be no problems
andthat this was being blessed by the UNITED NATIONS" which "would
protecteveryone" as the DFFI would be "placed into a Sovereign Program"
after whichthe DFFI "would disappear" and "there would be no questions
asked." In asubsequent telephone call between Raykov and BRUNO, which
took place whileboth parties were in New York, BRUNO advised Raykov that
DAL BOSCO hadabsconded with the DFFI and that "now more than ever"
Raykov was needed toconvince KEENAN to cooperate in the conspiracy to
deprive the Dragon Familyof its interest in the DFFI. At a subsequent
meeting between Raykov, BRUNOand DAL BOSCO at the Balexert Mall in
Switzerland in May 2010, BRUNOcommented 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 wereabout to be completed with or
without KEENAN." BRUNO again requestedRaykovs assistance in convincing
KEENAN to participate in the fraudulentscheme. When Raykov indicated
that KEENAN would not listen to him,BRUNO exclaimed, "Not even for 500
Million U.S. Dollars?" BRUNO thenencouraged Raykov to call him at his
New York office of the WEF USA to speakabout the matter further.
(5) Defendants complicity was further corroborated during the
courseof the meeting between DAL BOSCO, BRUNO and Miranov at the
Balexert mallin Switzerland in May 2010. At this meeting, defendant
BRUNO explained whowas involved in the fraudulent scheme to steal the
DFFI, specifically namingdefendants RAGAGLINI, MlRACIDAN, BERLUSCONI,
and the ITALIANFINANCIAL POLICE, stating: "so you see there is no
possible way we can havea problem. We can cloak ourselves with the
immunity shield and everyone willgo away. Just another day in the UN!"
During this meeting held for the purposeof convincing Miranov to assist
the defendants in their fraud, a telephone call wasreceived from
defendant H.E. Ambassador MlRACHIAN, PermanentRepresentative of the
Italian Mission to the UN in Geneva, who confirmed thedirect knowledge
and approval of the United Nations Secretary General, BAN KI-moon
stating: (i) "from the very top we were protected"; (ii) "there is no
reasonfor anyone, including KEENAN, to worry about any sort of
repercussions"; (iii)"the Italian cohorts in New York had even approved
the matter with SecretaryGeneral BANK KI-moon" whom she expressly
acknowledged "would deny heknew anything about it."
103 [*]107. 228. KEENAN has suffered
seriotls financial detriment on account of and as a directand proximate
result of defendants acts aiding and abetting the fraudulent scheme and,
at aminimum, defendants DAL BOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN,
theITALIAN FINANCIAL POLICE, the ITALIAN REPUBLIC, BAN KI-moon, the
UNITEDNATIONS, BRUNO, WEF and/or WEF USA are jointly and severally
liable for the full value ofthe DFFI and all of its accumulated
interest, with interest. Defendants DAL BOSCO,BERLUSCONI, RAGAGLINI,
MlRACHIAN, the ITALIAN FINANCIAL POLICE, theITALIAN REPUBLIC, BAN
KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEFUSA are also jointly
and severally liable for KEENANs lost profits from the fees to which
hewas entitled for performing his services for the Dragon Family with
respect to coordinating theplacement of the DFFI into an approved
trading program. 229. Consequently, KEENAN has been damaged by
the actions of defendants DALBOSCO, BERLUSCONI, RAGAGLINI, MlRACHIAN,
the ITALIAN FINANCIAL POLICE,the ITALIAN REPUBLIC, BAN KI-moon, the
UNITED NATIONS, BRUNO, WEF andlorWEF USA aiding and abetting the effort
to defraud KEENAN of the DFFI and has sustaineddamage 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 Boscos Fraud under
Federal Common Law and International
Law] 230. Plaintiff repeats and realleges each of the
allegations contained in paragraphs 1through 229 of the Complaint with
the same force and effect as though fully set forth herein.
104 [/*]108. 231. The actions
of defendants DAL BOSCO, SALE, DAM, OITC and the UNITEDNATIONS violate
any and all notions ofjus cogens, a body of peremptory principles
ofcustomary and universal international law recognized by civilized
nations. At a minimum, theactions of said defendants constitute a
knowing and willful participation to aid and abet thedefrauding of
KEENAN of the DFFI, valued at approximately ONE TRILLION UNITEDSTATES
DOLLARS, which fraud was completed by defendant DAL BOSCO, who
personallyobtained the DFFI from KEENAN through fraudulent
misrepresentations and absconded withthe DFFI. 232. Defe~dants
SALE and DAM acting on behalf of defendant OITC, withknowledge of the
planned fraudulent scheme to obtain the DFFI in contravention of the
rights ofits true and rightful owners, and for the express purpose of
facilitating the said fraud, providedsubstantial assistance·in the fraud
by taking the position that the DFFI stolen and converted byDAL BOSCO
were in fact the "property" ofOITC rather than the Dragon Family,
therebyenabling DAL BOSCO to perpetuate his fraud and convert the DFFI.
In doing so, thesedefendants provided practical assistance,
encouragement and moral support to the fraud. Saidacts in substantial
assistance to the scheme to defraud KEENAN, which were made
withknowledge of and for the purpose of facilitating the fraud, include
the following statementsandlor 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.
105 109. (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 fraudulentactivities of OITC in that it
has never formally denounced or disassociated itself from OITC, andhas
allowed OITC to hold itself out to the world community as protected by
its umbrella oflegitimacy and chartered by the UNITED NATIONS itself.
Upon information and belief,defendant the UNITED NATIONS, with knowledge
of the planned fraudulent scheme, and forthe express purpose of
facilitating the defrauding of KEENAN and the Dragon Family,
providedsubstantial assistance to said fraud by allowing and actively
encouraging the OITC to representitself as affiliated with and charted
by the UNITED NATIONS in OITCs efforts to convinceKEENAN to release the
DFFI to defendants on the purported basis that the DFFI belonged toOITC
rather than the Dragon Family. 234. KEENAN has suffered serious
financial detriment on account of and as a directand proximate result
of the action of defendants DAL BOSCO, SALE, DAM, OITC and theUNITED
NATIONS aiding and abetting the fraudulent scheme and, at a minimum,
saiddefendants are jointly and severally liable for the full value of
the DFFI and all of itsaccumulated interest, with interest. Defendants
DAL BOSCO, SALE, DAM, OITC and the
106 [*]110. UNITED NATIONS are also jointly and severally
liable for KEENANs lost profits from thefees to which he was entitled
for performing his services for the Dragon Family with respect
tocoordinating the placement of the DFFI into an approved trading
program. 235. Consequently, KEENAN has been damaged by the
actions of defendants DALBOSCO, SALE, DAM, OITC and the UNITED NATIONS
aiding and abetting the effort todefraud KEENAN of the DFFI and has
sustained damage in a sum to be determined at trial, butbelieved 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 1through 235
with the same force and effect as though fully set forth herein.
237. After months of meetings and discussions with KEENAN, DAL BOSCO,
forvaluable consideration, entered into a written contract with
plaintiff, KEENAN. 238. The contract provided: (1) "I can
assure you that you will never regret makingthis decision"; (2) "You are
aware of the fact I am well trusted and a financial advisor within
theVatican 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 sothat we can do great things
for the world"; (5) "I understand clearly that I am not to discuss
thesebonds with anyone outside the immediate circle and my privacy is
integral to the success ofmany nations"; (6) "I further understand you
are the authorized representative and Power ofAttorney for said bonds
and I will entrust them believe me as though it was my life depending
onit. Therefore I humbly accept the custodianship of said Bonds in which
I am only to return them
107 [/*][*]111. to either you or Mr. Yamaguchi. Not any other!"; (7)
"although electronic this email is to beconsidered my legal binding
acceptance of the following bonds" (bonds listed); (8) "Will beready
when called upon to deliver said notes to you." 239. DAL BOSCO
has failed to perform his obligations under the contract and
therebybreached the contact by failing to return and/or deliver the DFFI
entrusted to him uponnotwithstanding KEENANs repeated requests made in
accordance with the terms of thecontract. 240. KEENAN has
suffered serious financial detriment on account of and as a directand
proximate result ofDAL BOSCOs breach of contract and DAL BOSCO is
consequentlyliable for the full value of the DFFI and all of its
accumulated interest, with interest. DALBOSCO is also liable for KEENANs
lost profits from the fees to which he was entitled forperforming his
services for the Dragon Family with respect to coordinating the
placement of theDFFI into an approved trading program, which loss was a
foreseeable result ofDAL BOSCOsbreach of contract. 241.
Consequently, KEENAN has been damaged by DAL BOSCOs breach ofcontract
and has sustained damage in a sum to be determined at trial, but
believed to be in excessof 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 1through 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
behalfof the Dragon Family, and with the approval of General Haan, the
Head of the Dragon Family,
108 [/*]112. which authorized KEENAN to act on behalf of
Yamaguchi and the Dragon Family for theprivate placement of or legal
return of the DFFI, KEENAN lawfully possessed the DFFI. 244.
Defendant DAL BOSCO converted the DFFI from KEENAN and the DragonFamily.
245. All Defendants engaged in a civil conspiracy to convert
the DFFI from KEENANand the Dragon Family. 246. All
Defendants aided and abetted the conversion of the DFFI from KEENAN
andthe Dragon Family. 247. Despite repeated demands by KEENAN
to return the DFFI, the Defendants havecontinued in their refusal to
return the DFFI to KEENAN or the Dragon Family. 248. Upon
information and belief, defendant DAL BOSCO andlor alternatively all
ofsome of the Defendants currently possess all or a portion of the DFFI.
249. Plaintiff KEENAN therefore seeks a permanent Injunction
ordering DAL BOSCOor any other Defendant or related entity to return
the DFFI to plaintiff KEENAN. WHEREFORE, Plaintiff NEIL F.
KEENAN, Individllally and as Agent for THEDRAGON FAMILY, requests
judgment in his favor against Defendants as follows: 1. As
to Counts One and Six against defendant DANIELE DAL BOSCO,
awardingKEENAN compensatory and consequential damages in a sum to be
determined at trial, butbelieved 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, theITALIAN REPUBLIC, BAN
KI-moon, the UNITED NATIONS, BRUNO, WEF and/or WEFUSA, jointly and
severally, awarding KEENAN compensatory and consequential damages in a
109 113. 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
KEENANcompensatory and consequential damages in a sum to be determined
at trial, but believed to be inexcess of One Trillion
($1,000,000,000,000.00) US dollars; 4. As to Count Eleven,
against defendant DANIELE DAL BOSCO, awardingKEENAN contractual and
liquidated damages, and for compensatory, consequential andreasonably
foreseeable damages in a sum to be determined at trial, but believed to
be in excess ofOne Trillion ($1,000,000,000,000.00) US dollars;
5. As to Count Twelve, against all Defendants, the entry of a
permanent injunctiondirecting each Defendant found to be in possession
of the DFFI or any portion thereof, to returnthe 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. 110 114.
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: ~~L~~
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 [/list]






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