Martin De Luca

Application by Ecoprivate Business Ltd., of the British Virgin Islands, and Jean Sebastian Ferrer Funke, a citizen and resident of Switzerland, to take discovery from The Clearing House Payments Company LLC, The Federal Reserve Bank of New York, Barclays Bank PLC, and HSBC Bank USA N.A. "a criminal proceeding in Switzerland, which Applicants contemplate bringing against Mr. Sonashah Shivdasani; as well as in recognition and enforcement proceedings that the Applicants contemplate bringing in the UK" regarding "a real estate investment scheme that cost the Applicants well over US $6,175,000.00 in losses plus penalties and interest", filed at the U.S. District Court for the Southern District of New York.

Application by Zhongshan Quimica do Brasil Ltda, described as "the Brazilian subsidiary of Zhongshan Chemical, a global leading agrochemical manufacturer", to take discovery from Citibank N.A., The Clearing House Payments Company LLC, and The Federal Reserve Bank of New York "for use in contemplated civil and criminal proceedings in Brazil", filed at the U.S. District Court for the Southern District of New York.

Application by Ecoprivate Business Ltd., of the British Virgin Islands, and Jean Sebastian Ferrer Funke, a citizen and resident of Switzerland, to take discovery from KSL Capital Partners for use in "(1) a contemplated criminal proceeding in Switzerland, which Applicants anticipate will be brought against Mr. Sonashah Shivdasani; and (2) an arbitration proceeding commenced by Ecoprivate against Bluebay Resorts (BVI) Limited" alleging fraud and "criminal mismanagement" involving "a complex web of associated individuals and corporate entities in offshore jurisdictions such as Thailand and the British Virgin Islands", filed at the U. S. District Court for the District of Colorado.