|
c. List other wrongdoers, other than the named defendants, and describe the alleged misconduct of each wrongdoer.
Due to the nature of the fraud, Plaintiff cannot list all persons involved in the alleged misconduct, absent discovery. The below lists the main other wrongdoers of whom Plaintiff is currently aware grouped according to their main affiliation.
ACCESS/RENOVA
2. John and Jane Roes 1-100
There are persons whose identities are currently unknown to Plaintiff who worked for Access and Renova in the United States in further of the Illegal Scheme.
ALFA GROUP
3. Alfa Capital Markets (USA), Inc. (“Alfa Capital Markets”)
Alfa Capital Markets is a corporation organized under the laws of the United States, maintains an office in New York City, and is a member of the Alfa Group. Upon information and belief, Alfa Capital Markets is used to structure the laundering of the proceeds of the Slush Fund for investment in the United States, such as the recent acquisition of Golden Telecom, Inc., a publicly held American company, by the Alfa Group. Alfa Bank and Alfa Capital Markets are owned and controlled, directly or indirectly, by Alfa Finance.
4. Crown Commodities Ltd. (“Crown Commodities”)
Crown Commodities is a company organized under the laws of England and Wales and a member of the Crown Group. Crown Commodities provide trading services by which oil taken from Russia is sold on the world market from which the proceeds are then laundered through the Slush Fund companies.
5. Crown Trade and Finance Limited (“CTF Ltd”)
CTF-Ltd. is a company organized under the laws of Gibraltar and a member of the Crown Group and provides trading services by which oil taken from Russia is sold on the world market from which the proceeds are then laundered through the Slush Fund companies.
6. Crown Resources A.G. (“Crown AG”)
Crown AG is a company organized under the laws of Switzerland and a member of the Crown Group and provides trading services by which oil taken from Russia is sold on the world market from which the proceeds are then laundered through the Slush Fund companies.
7. Crown Resources (USA) Inc. (“Crown Resources”)
Crown Resources is a corporation organized under the laws of the United States and maintains a place of business in New York City is a member of the Crown Group and, upon information and belief, provides trading services by which oil taken from Russia is sold on the world market from which the proceeds are then laundered through the Slush Fund companies.
8. OOO Alfa-Eco (“Alfa-Eco”)
Alfa-Eco is a company organized under the laws of the Russian Federation which was used by the Alfa Group for trading purposes and is a member of the Alfa Group and provides trading services by which oil taken from Russia is sold on the world market from which the proceeds are then laundered through the Slush Fund companies.
9. John Irving (“Irving”)
Irving is a resident of England. He was the head of crude oil trading for CCL in London and directly involved in the scheme by which monies were diverted from TNK through Crown and then laundered through the Slush Fund Companies.
10. Alexey Kuzmichev (“Kuzmichev”)
Kuzmichev is a resident of England. He served as a director of various Crown Companies as well as numerous Slush Fund Companies and was directly involved in the scheme by which monies were diverted from TNK through Crown and then laundered through the Slush Fund Companies.
11. Dimitry Plouznhikov (“D. Plouznikov”)
D. Plouznikov is a resident of England. He served as a director of various Crown Companies as well as numerous Slush Fund Companies and was directly involved in the scheme by which monies were diverted from TNK through Crown and then laundered through the Slush Fund Companies.
12. Vladimir Plouznikov (“V. Plouznikov”)
V. Plouznikov is a resident of England. He served as a director of various Crown Companies as well as numerous Slush Fund Companies and was directly involved in the scheme by which monies were diverted from TNK through Crown and then laundered through the Slush Fund Companies.
13. Dr. Norbert Seeger (“Seeger”)
Seeger is a resident of Lichtenstein. He is a director of the Crown Finance Foundation and is believed to have organized the overall corporate structure for the money laundering scheme.
TNK
14. Novey Petroleum Finance Ltd. (“Novey Petroleum”)
Novey Petroleum is organized under the laws of Cyprus and was involved in the Corrupt 1997 and 1999 Privatization of TNK as the vehicle which acquired the controlling interest in TNK.
15. OAO TNK-Nyagan (“TNK-NG”)
TNK-NG is a company organized under the laws of the Russian Federation which is wholly owned by TNK and was used as TNK’s vehicle in the corrupt bankruptcy of Kondpetroleum.
16. OAO TNK-Nizhnevartovsk (“TNK-NV”)
TNK-NV is a company organized under the laws of the Russian Federation which is managed and controlled by TNK and was used as TNK’s vehicle to strip assets from Chernogorneft in the corrupt bankruptcy of Chernogorneft.
17. Alan Bigman (“Bigman”)
Bigman is a United States citizen. Bigman was an officer of TNK, who, open information and belief, was responsible for structuring the laundering of funds from TNK though Crown to the Slush Fund companies.
18. Alexander Berman (“Berman”)
Berman was an officer of an affiliate of TNK who was illegally instated as the General Director of Yugraneft as part of the seizure of Yugraneft and participated in the armed invasion and takeover of Yugraneft’s offices in Nizhnevartosk.
19. German Khan (“Khan”)
Khan is the First Vice President and Executive Director of TNK. Khan was instrumental in the takeover of Yugraneft and threatened and offered bribes to Rotzang and Kondrashina.
20. Igor Nam (“Nam”)
Nam is an officer of TNK. Nam was instrumental in the takeover of Yugraneft and threatened and offered bribes to Kondrashina.
SLUSH FUND COMPANIES
21. Aletar Co. Inc. (“Aletar”)
Aletar is organized under the laws of the British Virgin Islands and is believed to be a vehicle by which monies are laundered to pay bribes to Russian government officials.
22. Arufa Invest & Trade, SA (“Arufa”)
Arufa is organized under the laws of the British Virgin Islands and is believed to be a vehicle by which monies are laundered to pay bribes to Russian government officials.
23. AS Naftaco Industrial Partners Limited (“AS Naftaco”)
AS Naftaco is organized under the laws of Cyprus and is believed to be a vehicle by which laundered monies are paid to Blavatnick and Vekselberg.
24. Banstead Enterprises Limited (“Banstead”)
Banstead is organized under the laws of the Isle of Man and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
25. Beechville Trading Limited (“Beechville”)
Beechville is organized under the laws of the Isle of Man and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
26. Fairfax Investment Limited (Cyprus) (“Fairfax”)
Fairfax is organized under the laws of Cyprus and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
27. Freebow Investments (“Freebow”)
Freebow is a company organized under the laws of Cypress and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
28. Fullbrook Trading Limited (“Fulbrook”)
Fullbrook is organized under the laws of the Isle of Man and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
29. Futura Associates Limited or Futura SA (“Futura”)
Futura is a company organized under the laws either the United Kingdom or Panama. Futura is owned and controlled, directly or indirectly, by Spitz. Spitz, through Futura, was the recipient of millions of dollars of salary and bonus payments diverted through Eastmount, which were hidden from American tax authorities. Spitz and Kuzmichev arranged for millions of dollars of salary and bonus payments to other Crown employees to be paid through the Slush Fund Companies, which were hidden from American, English, and Russian tax authorities.
30. Iverforth Properties Limited (“Iverforth”)
Iverforth is organized under the laws of the Isle of Man and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
31. Lamport, Ltd. (“Lamport”)
Lamport is a company organized under the laws of Cypress and was the recipient of funds from CTF which are believed to be used to pay bribes to Russian government officials and make secret salary and bonus payments to Defendants and their agents.
32. Ozerla Business Corporation (“Ozerla”)
Ozera is a company organized under the laws of an unknown country and is believed to be the means by which monies are laundered to pay bribes to Russian government officials.
33. Redhill Properties Limited (“Redhill”)
Redhill is organized under the laws of the Isle of Man and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
34. Riverside Cay Limited (“Riverside”)
Riverside is a company organized under the laws of the British Virgin Islands and was the recipient of funds from CTF which were laundered through Sandwell and which are believed to be used to pay bribes to Russian government officials and make secret salary and bonus payments to Defendants and their agents.
35. Scorpio Res (“Scorpio”)
Scorpio is a company organized under the laws of Panama and was the recipient of funds from CTF which were laundered through Sandwell and which are believed to be used to pay bribes to Russian government officials and make secret salary and bonus payments to Defendants and their agents.
36. Wasdale Limited (“Wasdale”)
Wasdale is organized under the laws of the Isle of Man and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
37. Watford Limited (“Watford”)
Watford is organized under the laws of the Isle of Man and is believed to be a vehicle by which monies are laundered to pay secret salary and bonus payments to Defendants and their agents.
ASTON’S
38. Gillian Norah Caine (“Caine”)
Caine is a resident of the Isle of Man and, upon information and belief, is an officer or director of Astons. She is the director of numerous Slush Fund companies. She is directly involved in the laundering of funds through the various “Slush Fund Companies” in order to pay bribes to Russian government officials and to make secret salary and bonus payment to Defendants and their agents.
39. Susan Christine Cubbon (“Cubbon”)
Cubbon is a resident of the Isle of Man and, upon information and belief, is an officer or director of Astons. She is the director of numerous Slush Fund companies. She is directly involved in the laundering of funds through the various “Slush Fund Companies” in order to pay bribes to Russian government officials and to make secret salary and bonus payment to Defendants and their agents.
|
