(A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) Closed 07/17/2012 Financial Account - Account $768,370.54 Treasury Suspense Account 31 USC 5317 (c) (2) Administrative Administrative 11/27/2012 12/05/2012 - Deposited into Fund $461,022.32, 09/26/2012 - Partial Return to Owner $307,348.22 (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) Closed 07/26/2012 Financial Account - Account $306,725.85 Treasury Suspense Account 31 USC 5317 (c) (2) Administrative Civil Judicial 04/19/2013 06/03/2013 - Deposited into Fund $306,725.85 (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) Closed 12/05/2012 Currency - U.S. Currency $83,010.00 Treasury Suspense Account 18 USC 981 Administrative Civil Judicial 09/05/2013 09/17/2013 - Partial Return to Owner $73,010.00, 09/12/2013 - Deposited into Fund $10,000.00 Closed 12/05/2012 Currency - U.S. Currency $300.00 Treasury Suspense Account 18 USC 981 Administrative Civil Judicial 09/17/2013 - Returned to Owner $300.00 (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) (b) (3) (A) Closed 01/25/2013 Financial Account - Account $89,416.42 Treasury Suspense Account 31 USC 5317 (c) (2) Administrative Civil Judicial 12/16/2013 12/24/2013 - Deposited into Fund $89,416.42 (b) (3) (A) (b) (3) (A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (7)(A) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C) (b) (6), (b) (7)(C)

Case 1:12-cv-01905-RWR Document 93 Filed 07/02/14 Page 10 of 12 11 In fact, Congress passed 18 U.S.C. § 981(k) specifically to ensure that foreign financial institutions such as AIB could not challenge the forfeiture of a depositor’s funds held in their interbank accounts. The statutory language of 18 U.S.C. § 981(k) was “designed to make a depositor’s funds in a foreign bank’s U.S. correspondent account subject to the same civil forfeiture rules that apply to a depositor’s funds in other U.S. bank accounts.” 147 Cong. Rec. S8944 (Daily ed., Aug. 3, 2001).

CONCLUSION For the foregoing reasons, the United States respectfully requests that this Court enter the attached order staying this civil forfeiture action pursuant to 18 U.S.C. § 981(g). If this Court finds that the current record is insufficient to establish that civil discovery will adversely affect the ability of the Government to conduct the related criminal investigation, the United States respectfully seeks leave to submit evidence ex parte as authorized by 18 U.S.C. § 981(g)(5). Case 1:12-cv-01905-RWR Document 56 Filed 11/08/13 Page 8 of 9 9 Respectfully submitted, JAIKUMAR RAMASWAMY, CHIEF ASSET FORFEITURE AND MONEY LAUNDERING SECTION /s/ Elizabeth A. Aloi____________________ DANIEL H. CLAMAN Assistant Deputy Chief ELIZABETH A. ALOI Trial Attorney Asset Forfeiture and Money Laundering Section Criminal Division United States Department of Justice 1400 New York Avenue, N.W., Suite 10100 Washington, D.C. 20530 Telephone: (202) 514-1263 Attorneys for Plaintiff UNITED STATES OF AMERICA Case 1:12-cv-01905-RWR Document 56 Filed 11/08/13 Page 9 of 9

CONCLUSION For the foregoing reasons and those set forth in the United States’ Motion for a Stay (ECF No. 56), the United States respectfully requests that this Court enter the proposed order staying this civil forfeiture action pursuant to 18 U.S.C. § 981(g) for 180 days. If this Court finds that the current record is insufficient to establish that civil discovery will adversely affect the ability of the Government to conduct the related criminal investigation, the United States respectfully seeks leave to submit evidence ex parte as authorized by 18 U.S.C. § 981(g)(5). Case 1:12-cv-01905-RWR Document 62 Filed 11/29/13 Page 11 of 12 12 Respectfully submitted, JAIKUMAR RAMASWAMY, CHIEF ASSET FORFEITURE AND MONEY LAUNDERING SECTION /s/ Elizabeth Aloi_____________________ DANIEL H. CLAMAN Assistant Deputy Chief ELIZABETH A. ALOI Trial Attorney Asset Forfeiture and Money Laundering Section Criminal Division United States Department of Justice 1400 New York Avenue, N.W., Suite 10100 Washington, D.C. 20530 Telephone: (202) 514-1263 Attorneys for Plaintiff UNITED STATES OF AMERICA Case 1:12-cv-01905-RWR Document 62 Filed 11/29/13 Page 12 of 12

For purposes of Section 981(a)(1)(A), the U.S. need only show a “substantial connection” between Defendant Assets and Nguema’s criminal activity. 18 U.S.C. § 981(c)(3). “Several courts have held that real property is ‘involved in’ a money laundering offense if laundered funds are used to make payments toward purchase of the property and to pay for improvements.”

Intelsat Global Sales and Marketing Ltd, 534 F. Supp. 2d at 34 (D.D.C. 2008). As alleged in the Complaint, this Court has subject matter jurisdiction pursuant to 28 U.S.C. §§ 1345 and 1355(a), and 18 U.S.C. §§ 981(a)(1)(C) and 984 (ECF No. 15, ¶ 7). In addition, as also alleged in the Complaint, the wire transfers necessary to establish this Court’s jurisdiction over the alleged wire fraud conspiracy occurred each time the United States Defense Finance and Account Services, located in Rome, New York, through the North Atlantic Treaty Organization’s Maintenance and Supply Agency, processed and disbursed payments to TOIFOR Global Life Support Services (now known as “Xeless”), which in-turn made payments totaling $77 million to Hikmat Shadman Logistics Services Company (ECF No. 15, ¶¶ 31-33, 46, 47).

Haleamau, supra 887 F.Supp. 2d at 1056. The defendant properties are therefore subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C) and 31 U.S.C. § 5317(c). 10.

Haleamau, supra 887 F. Supp. 2d at 1056. The defendant properties are therefore subject to forfeiture pursuant to 18 U.S.C. § 981(a)(1)(C) and 31 U.S.C. § 5317(c). 10.

Wherefore, the United States requests that this Court strike the claims of Unsworth and Pillsbury, or in the alternative, deny the motion to stay pursuant to 18 U.S.C. § 981(g)(2) and require responses to the special interrogatories. Respectfully submitted, PATRICK J. FITZGERALD United States Attorney By: s/Daniel E. May DANIEL E. MAY

25 If necessary, the proposed intervenors can always enforce their contractual rights through a breach of contract action against the Vigilant Companies. Case: 1:11-cv-04175 Document #: 52 Filed: 12/23/11 Page 23 of 24 PageID #:285 24   Victim creditors like the proposed intervenors have another potential avenue for prospective relief; namely, the restoration provisions of 18 U.S.C. § 981(e)(6). Accordingly, even if the Court could allow the proposed intervenors’ intervention pursuant to Rule 24(b), which it statutorily cannot, it should exercise its discretion and deny the requested intervention.