The Clearing House Payments Company

Petronas Azerbaijan (Shah Deniz) Sàrl et al v. Bank of America et al: Discovery Application (Luxembourg & Spain)

November 22, 2024

Application by Petronas Azerbaijan (Shah Deniz) Sàrl and Petronas South Caucasus Sàrl, both of Luxembourg, to take discovery from Bank of America Corporation, Wells Fargo & Company, BankUnited, Inc., TD Group US Holdings LLC, The Clearing House Payments Company, L.L.C., CF Taurus (US) LLC, and Pacific Strategies & Assessments Americas LLC "in aid of certain foreign civil and private criminal proceedings that Petitioners intend to file in Luxembourg and Spain relating to a rogue arbitration proceeding commenced in Spain against the Malaysian government" in which an award for $14.9 billion was entered, filed at the U.S. District Court for the District of Delaware.

Metropolitan Municipality of Lima v. Brookfield Infrastructure Partners L.P. et al: Discovery Application (Peru)

November 18, 2024

Application by the Metropolitan Municipality of Lima from Brookfield Infrastructure Partners L.P., Brookfield Asset Management Ltd., Brookfield Corporation, Cahill Gordon & Reindel LLP, KPMG LLP, The Bank of Nova Scotia, Scotia Capital (USA) Inc., Scotia Holdings (USA) LLC, Arup Latin America S.A., Arup Americas, Inc., Citibank, N.A., Wells Fargo, N.A., JPMorgan Chase & Co., The Clearing House Payments Company L.L.C., and The Federal Reserve Bank of New York for use in legal proceedings in Peru "concerning a corrupt toll road project in Lima, Peru" involving Brazilian firm Odebrecht S.A., filed at the U.S. District Court for the Southern District of New York.

Evangelos Marinakis v. Citibank N.A. et al: Discovery Application (England)

October 21, 2024

Application by Evangelos Marinakis, a citizen of Greece described as "a successful businessman who is particularly well-known since 2017 for his involvement in and ownership of Nottingham Forest Football Club", to take discovery from Citibank, N.A., The Bank of New York Mellon, Bank of America, N.A., Barclays Bank PLC, BNP Paribas USA, Commerzbank AG, New York Branch, Deutsche Bank Trust Co. Americas, HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., Société Générale, New York Branch, Standard Chartered Bank USA, UBS AG, Wells Fargo Bank, N.A., and The Clearing House Payments Company L.L.C. for use in legal proceedings in England against Irini Karipidis, of Greece; Amani Swiss (Cyprus) Limited, of Cyprus; Ari Harow, of Israel, and Sheyaan Consulting Limited, of Israel, alleging a "smear campaign", filed at the U.S. District Court for the Southern District of New York.

Resource International Holdings CV et al v. Citibank NA et al: Discovery Application (Brazil)

September 16, 2024

Application by Gilmar Benedito Batistela, described as "a Brazilian businessman who built a long career in the IT sector", and Resource International Holdings CV, described as "a company managed and owned by Gilmar Batistela", to take discovery from Citibank, N.A., Banco Itaú S.A. New York Branch; BNP Paribas USA, Inc., Deutsche Bank Trust Company America, Itaú CorpBanca, Safra National Bank of New York, Itaú Securities, JPMorgan Chase Bank, N.A., The Bank of New York Mellon, The Clearing House Payments Company LLC, The Federal Reserve Bank of New York, TRG Management LP, Knox Lawrence International, Inc., and Midas Medici Group Holdings, Inc. for use in legal proceedings in Brazil "concerning the investigation of misappropriation of funds by Nana Baffour-Gyewu and Frank Assante-Kissi related to the sale of Resource Holding de Participações Ltda., Resource IT Chile SPA, and Resource IT Colombia S.A.S. to Getronics Ltda. and Samba Holdings S.A.R.L.", filed at the U.S. District Court for the Southern District of New York

Maria Beldi et al v. Federal Reserve Bank of New York et al: Discovery Application (Brazil)

September 10, 2024

Application by Maria Claudia Beldi, Maria Inês Beldi, and Antonio Fábio Beldi to take discovery from the Federal Reserve Bank of New York, The Clearing House Payments Company LLC, Citibank N.A., Deutsche Bank AG, HSBC Bank (USA) NA, JPMorgan Chase Bank N.A., Standard Chartered Bank, and The Bank of New York Mellon "for use in a disputed probate proceeding currently pending in São Paulo, Brazil, for the estate of Alexandre Beldi Netto", which was "collectively worth more than USD $50,000,000", filed at the U.S. District Court for the Southern District of New York.

Commercial Bank of Dubai PSC v. Bank of America NA et al: Discovery Application (England)

September 9, 2024

Application by Commercial Bank of Dubai PSC, of Dubai, United Arab Emirates, to take discovery from Bank of America, N.A., Bank of Communications, Barclays Bank PLC, BNP Paribas New York, Citibank, N.A., Deutsche Bank AG, Deutsche Bank Trust Company Americas, HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., Mashreqbank pcs, Mizuho Bank, Ltd. – NY, Société Générale, Standard Chartered Bank, Sumitomo Mitsui Banking Corporation, The Bank of New York Mellon, The Northern Trust Company, UBS AG, Wells Fargo Bank, N.A., and The Clearing House Payments Company L.L.C. for use in legal proceedings in England alleging fraud against Abdalla Al Sari, Majid Al Sari, Mohamed Al Sari, described as "Emirati nationals and members of the wealthy Al Sari family"; FAL Oil Co LLC, Investment Group Private Limited, IGPL General Trading LLC, Hamad Almheiri, Globe Investment Holdings Limited, MAS Capital Holdings Limited, all of the UAE, and MENA Investment Holdings Limited, of the British Virgin Islands, filed at the U.S. District Court for the Southern District of New York.

Vantage Mezzanine Fund II Partnership v. The Clearing House Payments Company LLC et al: Discovery Application (Bermuda, England, Ghana, Italy, Malta & Switzerland)

July 18, 2024

Application by Vantage Mezzanine Fund II Partnership, acting through Vantage Mezzanine Fund II (Pty) Ltd. to take discovery from The Clearing House Payments Company LLC, Barclays Bank PLC, Citibank N.A., Deutsche Bank Trust Company Americas, HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., The Bank of New York Mellon, The Northern Trust Company/The Northern Trust International Banking Corporation, UBS AG, Wells Fargo Bank N.A., Bank of America N.A., and Standard Chartered Bank for use in legal proceedings in Bermuda, England, Ghana, Italy, Malta and Switzerland regarding an attempt to enforce a $59 million arbitration award against Ghana businessman John Eric Kowdo Taylor, filed at the U.S. District Court for the Southern District of New York.

Carlos Lazo Reyes v. The Clearing House Payments Company LLC et al: Amended Discovery Application (Mexico)

May 30, 2024

Application by Carlos Lazo Reyes, described as a citizen of Venezuela and "a successful international entrepreneur, owning numerous successful companies in Mexico, the United States, and Europe, including sports betting companies, sports teams and tequila companies", to take discovery from The Clearing House Payments Company LLC and the Federal Reserve Bank of New York, specifically "records of transactions relating to YOX Holding S.A. de C.V., a sports betting company based in Guadalajara, its parent company XOY Asesores en Inversiones Independientes S.A.P.I. de C.V., and individuals employed by these entities, namely Mr. Lazo, Mr. Lazo's wife Helena Lazo, Mr. Lazo's daughter Nicole Lazo, Karina Mendoza Antuna, Sara Cristina Ejea Mejia, Ivan Israel Guerrero Lara, Cecilia Paulina Flores Salinas and Estefania Nares Rivas", for use in "ongoing and prospective proceedings in Mexico" in which he is defending himself against "baseless allegations of fraud", filed at the U.S. District Court for the Southern District of New York.

Dussan Kipperband et al v. Citibank et al: Discovery Application (Argentina)

May 24, 2024

Application by Dussan David Kipperband, Ivan Kipperband, and Mara Kipperband to take discovery from Citibank, N.A., The Bank of New York Mellon, Société Générale, New York Branch; HSBC Bank USA, N.A., BNP Paribas USA, JPMorgan Chase Bank, N.A., Wells Fargo Bank, N.A., Deutsche Bank Trust Co. Americas, UBS AG, Bank of America, N.A., Bank of China, New York Branch; Standard Chartered Bank US, Commerzbank AG, New York Branch; and The Clearing House Payments Company L.L.C. for use in legal proceedings in Argentina, filed at the U.S. District Court for the Southern District of New York.

Carlos Lazo Reyes v. The Clearing House Payments Company LLC et al: Report & Recommendation Denying Discovery Application

May 16, 2024

Report & Recommendation recommending the denial of a discovery application in Carlos Lazo Reyes, described as "the founder and former president of YOX Holding S.A. de C.V., a sports betting company based in Guadalajara, Mexico" v. The Clearing House Payments Company LLC and The Federal Reserve Bank of New York at the U.S. District Court for the Southern District of New York.

Carlos Lazo Reyes v. The Clearing House Payments Company LLC et al: Discovery Application (Mexico)

April 16, 2024

Application by Carlos Lazo Reyes, described as a citizen of Venezuela and "a successful international entrepreneur, owning numerous successful companies in Mexico, the United States, and Europe, including sports betting companies, sports teams and tequila companies", to take discovery from The Clearing House Payments Company LLC and the Federal Reserve Bank of New York, specifically "records of transactions relating to YOX Holding S.A. de C.V., a sports betting company based in Guadalajara, its parent company XOY Asesores en Inversiones Independientes S.A.P.I. de C.V., and individuals employed by these entities, namely Mr. Lazo, Mr. Lazo's wife Helena Lazo, Mr. Lazo's daughter Nicole Lazo, Karina Mendoza Antuna, Sara Cristina Ejea Mejia, Ivan Israel Guerrero Lara, Cecilia Paulina Flores Salinas and Estefania Nares Rivas", for use in "ongoing proceedings in Mexico and in ongoing proceedings in the International Criminal Police Organization ("INTERPOL")" in which he is defending himself against "baseless allegations of fraud", filed at the U.S. District Court for the Southern District of New York.

Vinmar Overseas Ltd. v. The Clearing House Payments Company LLC: Discovery Application (Indonesia)

April 3, 2024

Application by Vinmar Overseas Ltd., a Bahamas company based in Texas, USA, to take discovery from The Clearing House Payments Company LLC for use in legal proceedings in Indonesia "against certain individual shareholders and directors of PT Sumi Asih, Mr. Alexius Darmardi Karjantoputro, Mr. Markus Susanto, and Mr. Muljadi Budiman, as well as its corporate shareholders PT Mulia Darma Sarana and Stargate Trading Limited", filed at the U.S. District Court for the Southern District of New York.

Ativos Especiais II et al v. The Clearing House Payments Company LLC et al: Discovery Application (Brazil)

March 13, 2024

Application by Ativos Especiais II - Fundo de Investimento em Direitos Creditórios - NP and Ativos Especiais III - Fundo de Investimento em Direitos Creditórios - NP, described as "two investment funds organized under Brazilian law", to take discovery from The Clearing House Payments Company LLC and Morgan Stanley & Co. LLC for use in legal proceedings in Brazil "against Silvana Malandrini Mazza", who was described as "a Brazilian businesswoman" who "may be concealing certain funds and assets abroad", filed at the U.S. District Court for the Southern District of New York.

OIH Renewables Sàrl v. Citibank, N.A. et al: Discovery Application (Brazil)

February 29, 2024

Application by OIH Renewables Sàrl, of Luxembourg, to take discovery from Citibank, N.A., The Bank of New York Mellon, Société Générale, New York Branch; HSBC Bank USA, N.A., BNP Paribas USA, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Deutsche Bank Trust Co. Americas, UBS AG, Bank of America, N.A., Standard Chartered Bank US, Commerzbank AG, New York Branch; Bank of China, New York Branch; Wells Fargo Bank, N.A., Safra National Bank of New York, Banco do Brasil S.A., and The Clearing House Payments Company L.L.C. for use in legal proceedings in Brazil "against Marco Aurélio Luz Goncalves" regarding allegations that he "might be concealing his assets by using offshore corporate structures and making fraudulent transfers of his assets to his family members, since he is seemingly able to comply with the alimony costs without showing any real source of funds", filed at the U.S. District Court for the Southern District of New York.

Loudmila Bourlakova et al v. The Clearing House Payments Company LLC: Discovery Application (England)

February 20, 2024

Application by Loudmila Bourlakova, described as "a resident of Monaco who was born in Ukraine", and Veronica Bourlakova, who "lives in the United Kingdom, and was born in Ukraine", described as the widow and daughter, respectively, of Oleg Bourlakov, described as "a Ukrainian, Russian and Canadian national" who "developed and set into motion a plan to hide Bourlakov Family Assets from his wife and adult daughters", to take discovery from The Clearing House Payments Company L.L.C. for use in legal proceedings in England, filed at the U.S. District Court for the Southern District of New York.

Golden Meditech Holdings Ltd. v. Citibank, NA et al: Discovery Application (Hong Kong)

January 16, 2024

Application by Golden Meditech Holdings Limited, of the Cayman Islands, to take discovery from Citibank, N.A., The Bank of New York Mellon, Société Générale, New York Branch, HSBC Bank USA, N.A., BNP Paribas USA, JPMorgan Chase Bank, N.A., Wells Fargo Bank, N.A., Deutsche Bank Trust Co. Americas, UBS AG, Bank of America, N.A., Bank of China, New York Branch, Standard Chartered Bank US, Commerzbank AG, New York Branch, and The Clearing House Payments Company L.L.C. for use in legal proceedings "brought in Hong Kong against eight foreign defendants, namely: (i) Mr. Yuan Ya Fei (also known as Li Zhen Yuan Adams), (ii) Ms. Yang Huai Zhen, (iii) Mr. Xu Ping, (iv) Mr. Chen Xiao Yang, (v) Nanjing Ying Peng Huikang Medical Industry Investment Partnership, (vi) Nanjing Li Xin Trading Industrial Co Ltd, (vii) Blue Ocean Creation Investment Hong Kong Limited, and (viii) Blue Ocean Structure Investment Company Limited", filed at the U.S. District Court for the Southern District of New York.

Ibiuna Crédito Gestão de Recursos Ltda. et al v. Goldman Sachs Group Inc. et al: Discovery Application (Brazil)

January 9, 2024

Application by Ibiuna Crédito Gestão de Recursos Ltda., Travessia Securitizadora de Créditos Financeiros S.A., and Travessia Securitizadora de Créditos Financeiros XXXII S.A. to take discovery from Goldman Sachs Group Inc., Goldman Sachs & Co. LLC, Santander Bank, N.A., The Clearing House Payments Company LLC, and the Federal Reserve Bank of New York for use in "foreign civil and criminal proceedings pending in Brazil concerning the business operations of Starbucks and Subway in that country, held through the SouthRock Group, a group of U.S. and Brazilian companies controlled and owned by Kenneth Steven Pope", filed at the U.S. District Court for the Southern District of New York.

Ernesto Andrade Group v. Citibank NA et al: Discovery Application (Brazil)

November 7, 2023

Application by Ernesto Andrade Group to take discovery from Citibank, N.A., The Bank of New York Mellon, Société Générale, New York Branch; HSBC Bank USA, N.A., BNP Paribas USA, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Bank of America, N.A., Wells Fargo Bank, N.A., and The Clearing House Payments Company, LLC for use in legal proceedings in Brazil to recover $7,680,184 from Nelson Nogueira Pinheiro that he allegedly "embezzled ... in his role as the former manager of FPB Bank", which is based in Panama, filed at the U.S. District Court for the Southern District of New York.

CT Group Holdings Ltd. v. The Clearing House Payments Company LLC et al: Discovery Application (England)

October 27, 2023

Application by CT Group Holdings Limited, described as "a private investigative and consulting firm that provided its clients, Alon and Anna Laniado, a report concerning the financial resources of their stepmother, Linda May Laniado", to take discovery from The Clearing House Payments Company LLC and The Federal Reserve Bank of New York for use in legal proceedings in England "concerning the administration of their father and Linda’s late husband’s estate before the Royal Court of Jersey and the Royal Court of Guernsey", filed at the U.S. District Court for the Southern District of New York.

Banco Votorantim SA v. The Clearing House Payments Company LLC et al: Discovery Application (Brazil)

October 24, 2023

Application by Banco Votorantim S.A. to take discovery from The Clearing House Payments Company L.L.C., Bank of America, N.A., The Bank of New York Mellon, BNP Paribas USA, Citibank, N.A., Commerzbank AG, Deutsche Bank Trust Company Americas, HSBC Bank USA, N.A., Bank of Nova Scotia, Barclays Bank PLC, JPMorgan Chase Bank, N.A., Société Générale, Standard Chartered Bank, UBS AG, and Wells Fargo Bank, N.A. "for use in an ongoing civil proceeding that Applicant filed against the judgment debtors Credz S.A. Instituição de Pagamento, JJLF Empreendimentos Imobiliarios e Participacoes Ltda., JJLF Participações Financeiras Ltda., Elenir Elias Zogbi, Fabio Joao Zogbi, Lais Helena Zogbi Porto, Joao Antonio Zogbi Filho in Brazil to enforce the BRL 81 million (approximately USD 16 million) money judgment that Applicant owns against the Foreign Judgment Debtors", filed at the U.S. District Court for the Southern District of New York.

LITASCO SA v. The Clearing House Payments Company LLC et al: Discovery Application (England)

September 25, 2023

Application by LITASCO S.A. to take discovery from The Clearing House Payments Company LLC, Citibank N.A.; Deutsche Bank Trust Company Americas; Standard Chartered Bank; HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., The Bank of New York Mellon, Wells Fargo Bank N.A., Barclays Bank PLC, United Bank for Africa, America, Société Générale North America, SG Americas Securities Holdings, LLC, and BNP Paribas USA, Inc. for legal proceedings in England "against Der Mond Oil and Gas Africa SA and Locafrique Holding SA", filed at the U.S. District Court for the Southern District of New York.

Lukoil Benelux BV v. Bank of America et al: Discovery Application (England)

August 7, 2023

Application by Lukoil Benelux B.V., of Luxembourg, to take discovery from The Clearing House Payments Company L.L.C., Bank of America N.A., Citibank N.A., Deutsche Bank Trust Company Americas, Standard Chartered Bank, HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., The Bank of New York Mellon, Wells Fargo Bank N.A., Santander Bank, N.A., and Credit Agricole CIB for use in legal proceedings in England "against Oil Distribution Terminals S.L., Biomar Oil S.L., Buran Energy S.A., Corporacion Financiera Kleber Iberica S.L., Mr Tirso-Jose-Maria Tomas Herrero and Mr Juan Antonio Molina Garcia", filed at the U.S. District Court for the Southern District of New York.

Ecoprivate Business Ltd. et al v. The Clearing House Payments Company LLC et al: Discovery Application (Switzerland & United Kingdom)

July 14, 2023

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.

N.P.S.SF. Debt Co. Sàrl v. Standard Chartered Bank et al: Discovery Application (Germany, India, Marshall Islands, Pakistan, St. Kitts & Nevis & United Arab Emirates)

June 30, 2023

Application by N.P.S.SF. Debt Co., S.à.r.l., of Luxembourg, to take discovery from Standard Chartered Bank, Citigroup, d.b.a. Citibank; The Bank of New York Mellon Corporation, Bank of America, N.A., JPMorgan Chase Bank, N.A., Deutsche Bank AG, Deutsche Bank Trust Company Americas, HSBC Bank, Société Générale, UniCredit Bank AG, Credit Suisse Bank N.A., UBS Group AG, Wells Fargo Bank, N.A., The Clearing House Payments Company L.L.C., Bank of China, BNP Paribas USA, Commerzbank AG, Mashreq Bank PSC, and Habib American Bank for use in legal proceedings in Germany, India, Marshall Islands, Pakistan, St. Kitts & Nevis, and United Arab Emirates regarding an alleged $36.6 million fraud by Muhammad Tahir Lakhani and Muhammad Ali Lakhani, both described as residents of Dubai, UAE, and Pakistan, and their Astir Group, filed at the U.S. District Court for the Southern District of New York.

Saul Klein v. Citibank et al: Discovery Application (Brazil)

June 28, 2023

Application by Saul Klein to take discovery from Citibank, N.A., Banco Santander S.A. New York, Santander Investment Securities Inc. of New York, JPMorgan Chase Bank, N.A., J.P. Morgan Securities LLC, Credit Suisse (USA), Inc., Safra National Bank of New York, Banco Itaú S.A. New York Branch, Itau CorpBanca, Itaú Securities, The Clearing House Payments Company LLC, and The Federal Reserve Bank of New York for use in "foreign civil and criminal proceedings in Brazil concerning the assets of the late Samuel Klein, a prominent Brazilian businessman and founder of the Casas Bahia retail chain" in which the Estate's Executor, Michael Klein, is suspected of fraud and embezzlement, filed at the U.S. District Court for the Southern District of New York.

Denise Derani et al v. Citibank NA et al: Discovery Application (Brazil)

May 10, 2023

Application by Denise Derani and Gisele Derani, both of São Paulo, Brazil, to take discovery from Citibank N.A., Banco Santander S.A., Santander Investment Securities Inc., JPMorgan Chase & Co., Credit Suisse (USA) Inc., Safra National Bank of New York, Banco do Brasil Securities LLC, The Clearing House Payments Company LLC, and The New York Federal Bank of New York for use in legal proceedings in Brazil "concerning the assets of late Wadya Derani, Michel Derani, Alexandre Derani, and Amira Derani, a prominent Brazilian family", filed at the U.S. District Court for the Southern District of New York.

African lender seeks to collect on $59M award against Ghana’s John Taylor in Bermuda, Italy & Malta

May 7, 2023

South Africa's Vantage Mezzanine Fund has applied to collect evidence from banks in the United States for use in legal proceedings in Bermuda, Italy and Malta to collect on a $59 million arbitration award against Ghanaian businessman John E. Taylor, who is Executive Chairman of Internet service provider Surfline Communications.

Vantage Mezzanine Fund II Partnership v. The Clearing House Payments Company LLC et al: Discovery Application (Bermuda, Italy & Malta)

May 5, 2023

Application by Vantage Mezzanine Fund II Partnership, described as a South African "investment fund that provides finance to high-risk businesses across Africa and in other developing jurisdictions", to take discovery from The Clearing House Payments Company LLC, Barclays Bank PLC, Citibank N.A., Deutsche Bank Trust Company Americas, HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., The Bank of New York Mellon, The Northern Trust Company, f.k.a. The Northern Trust International Banking Corporation; UBS AG, and Wells Fargo Bank N.A. for use in legal proceedings in Bermuda, Italy, and Malta to enforce an arbitration award of US$59.4 million "against Mr. John Eric Kodwo Taylor", who was described as a citizen of Ghana and Malta and "executive chairperson of Surfline Communications Ltd., a Ghanaian company engaged in developing high-speed internet networks in Ghana", at the U.S. District Court for the Southern District of New York.

Zhongshan Quimica do Brasil Ltda v. Citibank NA et al: Discovery Application (Brazil)

April 29, 2023

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.

ABRAAJ Investment Management Ltd. v. Bank of America et al: Amended Discovery Memorandum of Law (Cayman Islands)

March 17, 2023

Amended Memorandum of Law in support of Amended Application by the Joint Official Liquidators of ABRAAJ Investment Management Limited, of the Cayman Islands, to take discovery from Bank of America, N.A., The Bank of New York Mellon, Citibank, N.A., Deutsche Bank AG, New York Branch; Deutsche Bank Trust Company Americas, Goldman Sachs and Co., HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., Mashreqbank PSC, New York Branch; Standard Chartered Bank US, a.k.a. Standard Chartered Bank, New York Branch; Wells Fargo Bank N.A., Barclays Bank PLC, New York Branch; Société Generale North America; BNP Paribas USA Inc.; Bank of Nova Scotia, UBS AG, New York Branch, Commerzbank AG, New York Branch; and The Clearing House Payments Company LLC for use in legal proceedings in the Cayman Islands regarding an alleged $385 million fraud by Pakistan citizen Asif Masood Naqvi, filed at the U. S. District Court for the Southern District of New York.

Damien Byrne v. Citibank et al: Discovery Application (United Arab Emirates)

February 23, 2023

Application by Damien James Byrne, a citizen of Ireland residing in the United Arab Emirates, to take discovery from Citibank, N.A., The Bank of New York Mellon, Société Générale, New York Branch; HSBC Bank, N.A., BNP Paribas USA, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Deutsche Bank Trust Co. Americas, The Bank of Nova Scotia, New York Agency; UBS AG, Bank of America, N.A., Standard Chartered Bank US, Commerzbank AG, New York Branch; and The Clearing House Payment Company LLC for use in legal proceedings in the United Arab Emirates alleging fraud "against Mustansir Hamza Khetty Dawoodbhoy, Omar Hassan Ali Alattar and Mehboob Hamza Khetty Dawoodbhoy" at the U.S. District Court for the Southern District of New York.

China Construction Bank (Asia) Corporation Ltd. v. Goldman Sachs et al: Discovery Application (Hong Kong & Italy, ‘$300M Debt of Inter Milan FC President Steven Zhang’)

January 19, 2023

Application by China Construction Bank (Asia) Corporation Limited to take discovery from The Goldman Sachs Group, Inc., The Raine Group LLC, Oaktree Capital Management, L.P., Bain Capital, L.P., Lazard Frères & Co. LLC, Citibank, N.A., BNY Mellon, N.A., Wells Fargo Bank, N.A., Bank of America, N.A., Deutsche Bank AG, and The Clearing House Payments Company LLC regarding, inter alia, "the corporate financing and executive compensation structures of F.C. Internazionale Milano S.p.A", a.k.a. Inter Milan FC, an Italian soccer club, for use in legal proceedings in Hong Kong and Italy involving an allegation that Inter Milan's president, Zhang Kangyang, a.k.a. Steven Zhang, owes "more than US $300 million to China Construction Bank (Asia) Corporation Limited", filed at the U.S. District Court for the Southern District of New York.

Republic of Kazakhstan v. The Clearing House Payments Company LLC: Discovery Application (Belgium, Luxembourg & Netherlands)

December 23, 2022

Application by the Republic of Kazakhstan to take discovery from The Clearing House Payments Company LLC regarding "(1) ongoing criminal proceedings against Moldovan oligarch Anatolie Stati, his son Gabriel Stati, and their companies Ascom Group S.A. and Terra Raf Trans Traiding Ltd. in Luxembourg; (2) ongoing civil proceedings in the Netherlands between the Statis and Petitioner; and (3) ongoing and anticipated proceedings against the Statis in the courts of Belgium and other jurisdictions" regarding "a series of complex, multi-faceted fraud schemes, including money laundering schemes, engineered by the Statis", filed at the U.S. District Court for the Southern District of New York.

Anatolie Stati v. The Clearing House Payments Company LLC: Supplemental Discovery Application (Moldova)

November 22, 2022

Application by Anatolie Stati, described as "a Moldovan businessman, who, along with his son, Gabriel Stati, and two companies owned by them, had been developing substantial oil fields and energy assets in the Republic of Kazakhstan", to take discovery from The Clearing House Payments Company LLC for use in legal proceedings in Moldova "for damages caused by the criminal actions of, inter alia, Marat Beketayev [former Minister of Justice of Kazakhstan], Kairat Boranbayev [former head of Kazakhstan’s security services] and Karim Massimov [former Prime Minister of Kazakhstan]" and alleging "abuse of official authority, blackmail, and attempted blackmail", filed at the U.S. District Court for the Southern District of New York.

Banco BNP Paribas Brasil SA v. Citibank NA et al: Discovery Application (Brazil)

September 6, 2022

Application by Banco BNP Paribas Brasil NA to take discovery from Citibank, N.A., The Bank of New York Mellon, Société Générale, New York Branch, HSBC Bank USA, N.A., BNP Paribas USA, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Deutsche Bank Trust Co. Americas, The Bank of Nova Scotia, New York Agency, UBS AG, Bank of America, N.A., Standard Chartered Bank US, Commerzbank AG, New York Branch, and The Clearing House Payments Company, LLC for use in legal proceedings in Alagoas, Brazil involving Empresa Alagoana de Terminais Ltda. and Copertrading Comércio Exportação e Importação S.A., filed at the U.S. District Court for the Southern District of New York.

N.P.S.SF. Debt Co. Sàrl v. Standard Chartered Bank et al: Discovery Application (Germany, India, Marshall Islands, Pakistan, St. Kitts & Nevis & United Arab Emirates)

August 9, 2022

Application by N.P.S.SF. Debt Co. Sàrl, of Luxembourg, to take discovery from Standard Chartered Bank, Citigroup, d.b.a. Citibank; The Bank of New York Mellon Corporation, Bank of America N.A., JPMorgan Chase Bank N.A., Deutsche Bank AG, Deutsche Bank Trust Company Americas, HSBC Bank, Société Générale, UniCredit Bank AG, Credit Suisse Bank N.A., UBS Group AG, Wells Fargo Bank N.A., The Clearing House Payments Company L.L.C., Bank of China, BNP Paribas USA, Commerzbank AG, Mashreq Bank PSC, and Habib American Bank for use in legal proceedings in Germany, India, Marshall Islands, Pakistan, Saints Kitts and Nevis, and United Arab Emirates, filed at the U.S. District Court for the Southern District of New York.

Anatolie Stati v. The Clearing House Payments Company LLC: Discovery Application (Moldova)

July 28, 2022

Application by Anatolie Stati, described as "a Moldovan businessman who held interests in substantial oil fields in the Republic of Kazakhstan, which were wrongly expropriated by Kazakhstan resulting in the state’s obligation to pay a nearly $500 million international arbitral award issued by the Stockholm Chamber of Commerce", to take discovery from The Clearing House Payments Company LLC for use in legal proceedings in Moldova alleging "abuse of official authority, blackmail and attempted blackmail" against Vladimir Voronin, Oleg Reidman, Emmanuel Grinshpun, Nursultan Nazarbayev, Karim Massimov, Timur Kulibayev, Kairat Boranbayev, Arvind Tiku, Alexander Mashkevich, Kanatbek Safinov, Arman Rakhimov, Serik Rakhimov, Grigory Andreev, Andrey Kiselyov, Marat Beketayev, Ruslan Ashenov, Orynbasar Kubygul, Almat Madaliyev, and others, filed at the U.S. District Court for the Southern District of New York.

Kian Sadaat Yazdi v. The Clearing House Payments Company LLC et al: Discovery Application (United Arab Emirates)

June 17, 2022

Application by Kian Sadaat Yazdi, a citizen of the United Kingdom residing in Dubai, described as "a shareholder and the Chief Executive Officer of Hassan’s Optician Co., one of the largest optical chains in Kuwait", to take discovery from The Clearing House Payments Company L.L.C., Bank of America, N.A., Barclays Bank PLC, Bank of Baroda, BNP Paribas, Citibank, N.A., Deutsche Bank AG, Deutsche Bank Trust Company Americas, Habib American Bank, HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., Mashreqbank PSC, Standard Chartered Bank, The Bank of New York Mellon, and Wells Fargo Bank, N.A. for legal proceedings in the United Arab Emirates involving suspected fraud and forgery, filed at the U.S. District Court for the Southern District of New York.

JSC Ingtorgstroy v. Citibank NA et al: Discovery Application (Russia)

April 5, 2022

Application by JSC Ingtorgstroy, of Russia, to take discovery from Citibank NA, The Bank of New York Mellon, Société Générale, New York Branch; HSBC Bank USA NA, BNP Paribas USA, JPMorgan Chase Bank NA, Barclays Bank PLC, Deutsche Bank Trust Co. Americas, The Bank of Nova Scotia, New York Agency; UBS AG, Bank of America NA, Standard Chartered Bank US, Commerzbank AG, New York Branch, and The Clearing House Payments Company LLC for use in legal proceedings "against former CEOs and beneficial owners of OJSC "GK Amazarkan", including Pavel Entin and Bogdan Solodukha before the commercial court of Moscow city and the commercial court of Kaluga Region, Russia", filed at the U. S. District Court for the Southern District of New York.

Banco Santander (Brasil) SA v. Citibank NA et al: Discovery Application (Brazil)

January 24, 2022

Application by Banco Santander (Brasil) SA to take discovery from Citibank NA, The Bank of New York Mellon, Société Générale, New York Branch; HSBC Bank USA NA, BNP Paribas USA, JPMorgan Chase Bank NA, Barclays Bank Plc, Bank of America NA, Wells Fargo Bank NA, and The Clearing House Payments Company LLC for use in legal proceedings in São Paulo, Brazil alleging fraud "against Ducoco Produtos Alimenticios S/A, Ducoco Alimentos S/A, Malibu Holding S/A, and Nelson Nogueira Pinheiro", filed at the U. S. District Court for the Southern District of New York.

BASF T.O.V. v. Citibank NA et al: Discovery Application

January 11, 2022

Application by BASF T.O.V., of Ukraine, to take discovery from Citibank, N.A., The Bank of New York Mellon, Société Générale, New York Branch; HSBC Bank USA, N.A., BNP Paribas USA, JPMorgan Chase Bank, N.A., Barclays Bank PLC, Deutsche Bank Trust Co. Americas, The Bank of Nova Scotia, New York Agency; UBS AG, Bank of America, N.A., Standard Chartered Bank US, Commerzbank AG, New York Branch; and The Clearing House Payments Company, LLC for use in legal proceedings in Ukraine alleging fraud "against PE Cherkes Trading House (f/k/a PE “Firma Bershad Agroplius”) (and its affiliates and officers, including Mr. Zulynskyi Stepan Olegovych), Agrarian Alliance LLC, STOV Dibrova I K, and Motoviltex LLC" at the U. S. District Court for the Southern District of New York.

BTA Bank v. Bank of America et al: Discovery Application (‘$7.5B Fraud’)

November 16, 2021

Application by JSC BTA Bank, of Kazakhstan, to take discovery from The Clearing House Payments Company LLC and "thirteen intermediary banks", namely Bank of America NA, Bank of China, The Bank of New York, BNP Paribas USA, Citibank NA, Commerzbank AG, Deutsche Bank Trust Company, HSBC Bank USA NA, JPMorgan Chase Bank NA, Société Générale AG, Standard Chartered Bank, UBS AG, and Wells Fargo Bank NA regarding Saint Vincent and the Grenadines-domiciled Panolos Limited for use in legal proceedings in England "against BTA Bank's former chairman, and primary shareholder, Mukhtar Ablyazov, upon BTA Bank's discovery that Ablyazov had illegally misappropriated as much as $7.5 Billion of BTA Bank’s assets and subsequently laundered the proceeds through multiple financial institutions all over the world", filed at the U. S. District Court for the Southern District of New York.

ABRAAJ Investment Management Ltd. v. Bank of America et al: Amended Discovery Application (Cayman Islands)

September 16, 2021

Amended Application by the Joint Official Liquidators of ABRAAJ Investment Management Limited, of the Cayman Islands, to take discovery from Bank of America, N.A., The Bank of New York Mellon, Citibank, N.A., Deutsche Bank AG, New York Branch; Deutsche Bank Trust Company Americas, Goldman Sachs and Co., HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., Mashreqbank PSC, New York Branch; Standard Chartered Bank US, a.k.a. Standard Chartered Bank, New York Branch; Wells Fargo Bank N.A., Barclays Bank PLC, New York Branch; Société Generale North America; BNP Paribas USA Inc.; Bank of Nova Scotia, UBS AG, New York Branch, Commerzbank AG, New York Branch; and The Clearing House Payments Company LLC for use in legal proceedings in the Cayman Islands regarding an alleged $385 million fraud by Pakistan citizen Asif Masood Naqvi, filed at the U. S. District Court for the Southern District of New York.

Monica Niedbalski v. HSBC Bank USA NA et al: Discovery Application (Canada)

September 10, 2021

Application by Monica Niedbalski, a citizen of Canada, to take discovery from HSBC Bank USA, N.A., JPMorgan Chase Bank, N.A., Bank of America, N.A., City National Bank, Barclays Bank PLC, Deutsche Bank Trust Co. Americas, Wells Fargo Bank, N.A., UBS AG, Standard Chartered Bank, Commerzbank AG, New York Branch, and The Clearing House Payments Company LLC for use in legal proceedings in Canada alleging fraud "against Walton International Group Inc. et al", filed at the U.S. District Court for the Southern District of New York.

Monika Niedbalski v. HSBC et al: Discovery Application (Canada)

September 10, 2021

Application by Monika Niedbalski, described as "a Canadian citizen who, between 2006 and 2010, along with other victim plaintiffs, invested approximately $13,500,000.00 into syndicated "land based" investment companies and limited partnerships founded and controlled by the "WIGI" and its principal officer and guiding mind William "Bill" K. Doherty", to take discovery from HSBC Bank USA N.A., JPMorgan Chase Bank N.A., Bank of America N.A., City National Bank, Barclays Bank Plc, Deutsche Bank Trust Co. Americas, Wells Fargo Bank N.A., UBS AG, Standard Chartered Bank, Commerzbank AG, New York Branch, and The Clearing House Payments Company LLC for use in "a filed Canadian Civil Proceeding against Walton International Group Inc. et al" that alleges fraud, filed at the U. S. District Court for the Southern District of New York.

Frederico da Costa Pinto v. Loeb Block & Partners: Discovery Application

August 10, 2021

Application by Frederico da Costa Pinto, of Rio de Janeiro, Brazil to take discovery from Loeb Block & Partners law firm, its attorneys Yuisa Montañez and Steven Rasch; The Clearing House Payments Company L.L.C., Wells Fargo Bank, N.A., JPMorgan Chase Bank, N.A., Citibank, N.A. and Bank of America N.A. for use in a pending "probate proceeding" and "a reasonably contemplated civil action for fraud-related claims" in Brazil "concerning the estate of Applicant's deceased father, Humberto Da Costa Pinto", filed at the U. S. District Court for the Southern District of New York.

Uralsib Bank v. Citibank et al: Discovery Application (Russia)

July 16, 2021

Application by Uralsib Bank PJSC, of Russia, to take discovery from Citibank, N.A., The Bank of New York Mellon, Société Générale, New York Branch; HSBC Bank USA, N.A., BNP Paribas USA, JPMorgan Chase Bank, N.A., Barclays Bank Plc, Deutsche Bank Trust Co. Americas, The Bank of Nova Scotia, New York Agency; UBS AG, Bank of America, N.A., Standard Chartered Bank US, Commerzbank AG, New York Branch, The Clearing House Payments Company, LLC, Paypal, Inc., and MoneyGram Payment Systems, Inc. for use in legal proceedings in Russia "to recover a debt" of $4.3 million allegedly owed by Denis Smyslov, filed at the U. S. District Court for the Southern District of New York.

USA v. Federal Express et al: Order

July 15, 2021

Order granting a petition for Leave to Serve 'John Doe' Summonses as part of an IRS investigation into U.S. taxpayers who are suspected of tax evasion using the services of Panama Offshore Legal Services in USA v. Federal Express Corporation, a.k.a. FedEx Express; Fed Ex Ground Package System, Inc., a.k.a. FedEx Ground; DHL Express (USA), Inc., United Parcel Service, Inc., the Federal Reserve Bank of New York, The Clearing House Payments Company LLC, HSBC Bank USA, N.A., Citibank, N.A., Wells Fargo Bank, N.A., and Bank of America, N.A. at the U. S. District Court for the Southern District of New York.

USA v. Federal Express et al: ‘John Doe’ Summonses Supplemental Information

June 25, 2021

Supplemental Memorandum of Law and Declaration in support of a petition for Leave to Serve 'John Doe' Summonses as part of an IRS investigation into U.S. taxpayers who are suspected of tax evasion using the services of Panama Offshore Legal Services in USA v. Federal Express Corporation, a.k.a. FedEx Express; Fed Ex Ground Package System, Inc., a.k.a. FedEx Ground; DHL Express (USA), Inc., United Parcel Service, Inc., the Federal Reserve Bank of New York, The Clearing House Payments Company LLC, HSBC Bank USA, N.A., Citibank, N.A., Wells Fargo Bank, N.A., and Bank of America, N.A. at the U. S. District Court for the Southern District of New York.

USA v. Federal Express et al: ‘John Doe’ Summonses Petition

May 4, 2021

Ex Parte Petition for Leave to Serve 'John Doe' Summonses as part of an IRS investigation into U.S. taxpayers who are suspected of tax evasion using the services of Panama Offshore Legal Services, described as "a Panamanian law firm that has been providing offshore services since 2000", allegedly offering legal structures formed in several jurisdictions, including Belize, the British Virgin Islands, Delaware, Nevis, Nevada, Panama, Saint Vincent and the Grenadines, and Switzerland, in USA v. Federal Express Corporation, a.k.a. FedEx Express; Fed Ex Ground Package System, Inc., a.k.a. FedEx Ground; DHL Express (USA), Inc., United Parcel Service, Inc., the Federal Reserve Bank of New York, The Clearing House Payments Company LLC, HSBC Bank USA, N.A., Citibank, N.A., Wells Fargo Bank, N.A., and Bank of America, N.A. at the U. S. District Court for the Southern District of New York.