Case 1:18-cv-09011 Document 1 Filed 10/02/18 Page 1 of 24

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
ACCENT DELIGHT INTERNATIONAL LTD.
and XITRANS FINANCE LTD.,
Plaintiffs,

COMPLAINT

-againstSOTHEBY’S and SOTHEBY’S, INC.,
Defendants.

Plaintiffs, for their Complaint, allege, with knowledge as to their own acts and
otherwise on information and belief, that:
NATURE OF THE ACTION
1.

Sotheby’s—one of the world’s largest and most famous art brokers and auction

houses—materially assisted the largest art fraud in history. Plaintiffs, two companies based in the
British Virgin Islands, were the victims. Yves Bouvier, their art advisor, masterminded the fraud.
Sotheby’s was the willing auction house that knowingly and intentionally made the fraud
possible. Sotheby’s actions instilled Plaintiffs’ trust and confidence in Bouvier and rendered the
whole edifice of fraud plausible and credible.
2.

For more than ten years, Bouvier served as Plaintiffs’ agent, counselor, and

representative as Plaintiffs acquired 38 art masterworks for more than $2 billion. Plaintiffs
believed that Bouvier was negotiating with sellers on their behalf and paid Bouvier a commission
for his services. In fact, Bouvier’s detailed accounts of hard-fought negotiations with sellers were
pure fiction. Instead, Bouvier was negotiating for steep discounts and pocketing the difference
for himself. He repeatedly and blatantly misrepresented the acquisition prices for the paintings.

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Indeed, the price Bouvier actually paid for Plaintiffs’ collection was approximately half the total
price at which Bouvier falsely claimed the works had been acquired and Bouvier charged
Plaintiffs. Through this scheme, Bouvier defrauded Plaintiffs of over $1 billion.
3.

To perpetrate this fraud, Bouvier needed Sotheby’s: as a broker for the

transactions, and as a respected authority in the art world to help him justify the fraudulent prices
he charged to Plaintiffs. Sotheby’s was uniquely positioned to understand—and to facilitate—
Bouvier’s breathtaking fraud. It knew the actual prices Bouvier paid to the sellers and the
fraudulently inflated prices Bouvier induced Plaintiffs to pay to him.
4.

Sotheby’s aided and abetted Bouvier’s fraud. Before transactions, Sotheby’s gave

Bouvier written materials designed to induce Plaintiffs to pay inflated, fraudulent prices. After
transactions, Sotheby’s lent a veneer of legitimacy and expertise to those fraudulent prices by
providing Bouvier with inflated appraisals on demand. Sotheby’s intentionally omitted the sales
to Bouvier from the transaction histories listed in these appraisals. In short, Sotheby’s assisted
Bouvier in acquiring artworks at prices the sellers were willing to accept while helping him
charge Plaintiffs fraudulently inflated prices (and concealing the actual acquisition prices from
Plaintiffs).
PARTIES
5.

Plaintiff Accent Delight International Ltd. is an entity incorporated in the British

Virgin Islands. It is owned by a trust settled by and for the benefit of members of the Rybolovlev
family.
6.

Plaintiff Xitrans Finance Ltd. is an entity incorporated in the British Virgin

Islands. It is owned by a trust settled by and for the benefit of members of the Rybolovlev
family.

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7.

Defendant Sotheby’s, doing business in New York under the name Sotheby’s

Holdings, is a publicly traded corporation incorporated under the laws of Delaware with its
principal place of business at 1334 York Avenue, New York, New York. Founded in 1744,
Sotheby’s is in the business of selling art at auction and brokering private sales. It also provides
professional appraisals of artworks by experts. Sotheby’s is one of the world’s oldest and most
prestigious art companies. According to its website, Sotheby’s “has been entrusted with the sale
of many of the world’s treasures” and has built a “reputation for excellence based on the expert
knowledge and scholarship of [its] specialists.”
8.

Defendant Sotheby’s, Inc. is the wholly owned U.S. subsidiary of Sotheby’s.
JURISDICTION AND VENUE

9.

Subject-matter jurisdiction exists under 28 U.S.C. § 1332(a)(2) because Plaintiffs

are citizens of a foreign state, Defendants are citizens of New York, and the amount in
controversy exceeds $75,000.
10.

Venue is proper under 28 U.S.C. § 1391(b)(1) because Defendants reside in this

judicial district.
FACTS
11.

Sotheby’s aided and abetted the fraud designed by Yves Bouvier. (For purposes

of this Complaint, the term “Bouvier” refers to Yves Bouvier and persons and entities acting on
his behalf and under his control.)
Bouvier’s Fraudulent Scheme
12.

Bouvier’s fraud depended on the creation and violation of trust. Bouvier was first

introduced to Plaintiffs’ representative, Dmitry Rybolovlev, in 2003 through a mutual

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connection, Tania Rappo. Rappo was the godmother of one of Rybolovlev’s daughters, and he
considered her like a family member. Rappo fostered Rybolovlev’s trust in Bouvier.
13.

From 2003 through 2015, Bouvier, along with Rappo, worked to acquire art

masterworks on Plaintiffs’ behalf. Plaintiffs and Bouvier agreed that he would act as their agent.
Bouvier held himself out to Plaintiffs as an intermediary acting on their behalf, not as a seller in
the marketplace. Plaintiffs trusted him.
14.

Bouvier acquired 38 masterworks for Plaintiffs—including paintings by Picasso,

da Vinci, Rothko, and Modigliani—in 37 transactions. (Two works by Picasso were acquired
together in one transaction.)
15.

Plaintiffs paid more than $2 billion for the collection. They generally paid

Bouvier a two-percent commission on the purchase price of each work.
16.

Consistent with usual practice in the market for fine art, Plaintiffs were generally

unaware of the sellers’ identities. The transactions were confidential, and Bouvier insisted on
serving as Plaintiffs’ exclusive representative.
17.

Bouvier repeatedly lied to Plaintiffs and withheld material information from them.

He told Plaintiffs he was negotiating with sellers on their behalf, when in fact he had generally
already agreed to acquire the paintings at lower prices. The negotiations over the higher prices
were fabricated.
18.

By acquiring the paintings at lower prices than he represented, rather than

fulfilling his fiduciary duties as Plaintiffs’ agent, Bouvier pocketed hundreds of millions of
dollars in fraudulent gains. He also paid Rappo about $100 million in kickbacks for her role in
the scheme.

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Bouvier Serially Defrauds Plaintiffs With a Pattern of Deception
19.

Bouvier’s method of operation was consistent: Having already agreed, in most

cases, to buy a work at one price, he lied to Plaintiffs by pretending he was still negotiating with
the seller on their behalf, inducing Plaintiffs to pay an inflated price.
20.

Three transactions illustrate Bouvier’s pattern of deception.
The Modigliani Painting

21.

In December 2011, Bouvier worked to acquire Amedeo Modigliani’s Nu Couché

au Coussin Bleu on Plaintiffs’ behalf.
22.

Bouvier agreed with the painting’s owner to purchase it for approximately $95

million.
23.

Unbeknownst to Plaintiffs, the transaction was already agreed upon and had been

set into motion on December 17, 2011.
24.

Six days later, however, Bouvier emailed Plaintiffs’ representative: “I do not

know the price. . . . If [Rybolovlev] likes this painting, I will look into it.”
25.

The next day, Bouvier told Plaintiffs’ representative: “[T]he owner is . . . very

rich and certainly has other solutions. He is not obligated to sell this painting and not solely to us.
For now, we must firstly maintain a trust relationship with him and secondly make him waste
time in order to negotiate better.”
26.

In January 2012, Bouvier sent Plaintiffs an invoice for $118 million. Relying on

Bouvier’s false representation that this was the true purchase price, Plaintiffs paid Bouvier this
amount, plus $2.36 million in commission.
27.

Bouvier paid Rappo, Rybolovlev’s close family confidant, a $5 million kickback

on this transaction. This payment was kept secret from Plaintiffs.

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The Klimt
28.

In September 2012, Bouvier worked to acquire Gustav Klimt’s Wasserschlangen

II on Plaintiffs’ behalf.
29.

Bouvier’s friend and associate Jean-Marc Peretti represented Bouvier at a meeting

with the seller in Paris on September 11, 2012. There, Peretti agreed on Bouvier’s behalf to
purchase the painting for a net amount of $112 million. (Peretti has been the subject of criminal
investigations in France, including a 2009 investigation for running an illegal gambling ring,
according to the New Yorker.)
30.

The same day, however, Bouvier sent Plaintiffs’ representative an email

describing high-stakes negotiations with the seller: “They’re holding back for 180 [million
dollars] and are at the breaking point; I think they are ready at 190. But I should be able to twist
them to reach 185 with the payment of a deposit and the balance in 30 days. What should we
do???”
31.

Plaintiffs’ representative authorized Bouvier to pay up to $185 million for the

painting. Bouvier claimed to have reached a deal to buy Wasserschlangen II for $183.8 million.
32.

The negotiations that Bouvier described to Plaintiffs were fabricated. $183.3

million was not the true purchase price. In fact, Bouvier agreed through Peretti at the September
11 meeting to buy Wasserschlangen II for $112 million.
33.

On September 13, 2012, Bouvier sent Plaintiffs an invoice for $183.8 million for

Wasserschlangen II. Relying on Bouvier’s representation that this was the true purchase price,
Plaintiffs paid Bouvier this amount. Plaintiffs also paid Bouvier $3,676,050 in commission.
34.

Bouvier secretly paid Rappo a $4.78 million kickback on this transaction. This

payment was kept secret from Plaintiffs.

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The da Vinci
35.

Christ as Salvator Mundi is one of approximately 15 authenticated paintings by

Leonardo da Vinci that exist today.
36.

Bouvier arranged for the painting to be shown to Rybolovlev in person on March

22, 2013.
37.

At some point in March 2013, Bouvier reached agreement with the owners of the

da Vinci—Warren Adelson, Alexander Parish, and Robert Simon—to purchase the painting for
$83 million.
38.

On April 10 and 11, 2013, however, Bouvier had an email exchange with

Plaintiffs’ representative, in which he described hard-nosed negotiations to purchase Salvator
Mundi on Plaintiffs’ behalf. Bouvier claimed that Plaintiffs’ $100 million offer was “rejected
without a moment’s hesitation,” and that the seller was “[o]ne tough nut, but I’ll fight and take as
long as necessary.” Bouvier later said that a deal was “clinched” at $127.5 million—“[t]erribly
difficult, but it’s a very good deal with regard to this unique masterpiece by Leonardo.”
39.

All of these representations were false. The negotiations were fabricated.

Unbeknownst to Plaintiffs, Bouvier had already agreed to buy Salvator Mundi from Adelson,
Parish, and Simon for $83 million.
40.

On May 3, 2013, Bouvier sent Plaintiffs an invoice for $127.5 million. Relying on

Bouvier’s representation that this was the true purchase price, Plaintiffs paid Bouvier this
amount. Plaintiffs also paid Bouvier $1.275 million in commission.
41.

Bouvier secretly paid Rappo a $4.92 million kickback on this transaction. This

payment was kept secret from Plaintiffs.

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Sotheby’s Aids and Abets Bouvier’s Fraud
42.

Sotheby’s has admitted its involvement in Bouvier’s scheme. According to

Sotheby’s, “Sotheby’s facilitated the sale of 12 of the 37 works to Bouvier, consigned for auction
2 of the [w]orks on Bouvier’s behalf (1 of which it previously sold him), and conducted
valuations for 4 of the [w]orks (2 of which it previously sold him).” Sotheby’s made this
admission in a brief filed on June 29, 2018 in the U.S. Court of Appeals for the Second Circuit.
See Memorandum of Law in Support of Motion for Stay Pending Appeal (ECF No. 16-2) at 5
n.4, No. 18-1755 (2d Cir. June 29, 2018). “‘Sotheby’s’ refers to Sotheby’s, Inc., a U.S.
corporation with its principal place of business in New York.” Id. at 1 n.1.
43.

Sotheby’s was uniquely positioned to understand both sides of Bouvier’s

fraudulent scheme: the prices that sellers were willing to accept and that he paid, and the
fraudulently inflated prices he charged to Plaintiffs. Rather than alert Plaintiffs or the authorities,
Sotheby’s continued its lucrative business with Bouvier.
44.

Demonstrating its close involvement with Bouvier’s scheme, and their common

interests, in November 2017 Sotheby’s allied itself with Bouvier as a co-plaintiff in a civil
proceeding against Plaintiffs in Geneva, Switzerland.
Sotheby’s Maintains a Close Relationship with Bouvier
45.

Samuel Valette, Sotheby’s Vice Chairman for Private Sales Worldwide,

maintained a close relationship with Bouvier, for many years. They communicated regularly.
Valette, a specialist in impressionist and modern art, frequently contacted Bouvier to suggest
works that Plaintiffs might want to acquire.
46.

Valette, on behalf of Sotheby’s, would “source” works of art for Bouvier to sell to

Plaintiffs, comment on their quality and importance within the artist’s body of work, and

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sometimes issue appraisals. Valette did so in emails to Bouvier and Peretti, which Valette knew
would be forwarded to Plaintiffs’ representative.
47.

To Plaintiffs, whatever Valette said or did, because of his position, was on behalf

of Sotheby’s and carried the imprimatur of Sotheby’s. Bouvier would refer Plaintiffs to Valette
and to Sotheby’s to confirm what he was saying to Plaintiffs.
48.

Alexander Bell, Sotheby’s Co-Chairman of Old Master Paintings, also dealt with

Bouvier.
49.

At all relevant times, Valette and Bell were employees, agents, and servants of

Sotheby’s, acting within the scope of their duties.
50.

Sotheby’s valued its relationship with Bouvier. Bouvier is a major player in the

art world. He is associated with global “freeport” businesses where fine art is stored tax-free. In
the 14 transactions involving Bouvier and Plaintiffs that it brokered, Sotheby’s earned tens of
millions, or perhaps even hundreds of millions, of dollars in commissions. Bouvier was also
valuable to Sotheby’s because he did other business with Sotheby’s, unrelated to Plaintiffs.
51.

Bouvier was—and remains—one of Sotheby’s most important business contacts.

52.

Citing its confidentiality obligations to Bouvier, Sotheby’s refused to voluntarily

provide Plaintiffs with documents that would show the extent of Bouvier’s fraud, including
correspondence between Bouvier and Valette. Plaintiffs obtained some of those documents by
court order under 28 U.S.C. § 1782.
53.

For the time being, Plaintiffs are not allowed to use those documents to support

the allegations of this Complaint. Concurrently with the filing of this Complaint, Plaintiffs will
seek leave to use those documents to supplement their allegations here.

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Sotheby’s Pitches Deals to Plaintiffs Through Bouvier
54.

Sotheby’s knew that Bouvier was not acting for himself, but rather for Plaintiffs.

55.

On April 9, 2011, in an email to Valette concerning the purchase of Auguste

Rodin’s Le Baiser, Bouvier referred to Plaintiffs’ representative as “my friend.”
56.

Similarly, in an April 14, 2011 email to Bouvier relating to the purchase of

Aristide Malliol’s La Mediterranée, Valette referred to Plaintiffs’ representative as “the client.”
57.

Knowing that Bouvier was Plaintiffs’ agent, Sotheby’s repeatedly contacted

Bouvier to suggest works that Plaintiffs might want to buy.
58.

Sotheby’s also estimated the value of those works, with Valette explaining in

emails how important the works were in the artist’s overall production. Sotheby’s estimates
supported the fraudulently inflated prices Bouvier later charged to Plaintiffs.
59.

Sotheby’s knew when it pitched these deals that Bouvier intended to charge

Plaintiffs an undisclosed markup in excess of the true acquisition price.
60.

Plaintiffs relied on Valette’s comments on the value of the works because of

Valette’s authority as an expert on behalf of Sotheby’s, one of the two preeminent art auction
houses in the world. Valette’s emails, on behalf of Sotheby’s, to Bouvier were important in
engendering Plaintiffs’ trust and confidence in Bouvier.
61.

For instance, on November 14, 2011, Valette sent Bouvier an email discussing the

market for works by surrealist painter René Magritte. Valette knew that Bouvier was going to
forward this email to Plaintiffs to encourage them to buy a Magritte. He wrote the email for that
purpose.
62.

In the email, Valette said that a major Magritte work, such as The Empire of

Light, would sell for around €40 million in a private sale.

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63.

Bouvier forwarded the email to Plaintiffs the next day, as Valette intended.

Bouvier told Plaintiffs that a different Magritte painting, The Domain of Arnheim, was “more
beautiful” and “more important” than The Empire of Light, and that their market value would be
comparable.
64.

At some point in the next three weeks, Bouvier agreed to purchase the painting.

On December 5, 2011, he sent Plaintiffs an invoice for $43.5 million, plus $870,000 in
commission, for The Domain of Arnheim. This price was inflated; the price Bouvier paid was far
lower.
65.

Similarly, in July 2012, Valette emailed Bouvier with information about

Modigliani’s sculpture Tête. Valette knew that Bouvier was going to forward this email to
Plaintiffs to encourage them to buy the sculpture. He wrote the email for that purpose. The email
suggested that the market value of the sculpture was between €80 to €100 million.
66.

In December 2012, Bouvier exchanged emails with Plaintiffs’ representative

describing negotiations with the owner of Tête. At that point, however, Bouvier had already
acquired Tête. The negotiations he described to Plaintiffs were fabricated.
67.

On January 7, 2013, Bouvier sent Plaintiffs an invoice for €62.5 million for Tête.

Relying on Bouvier’s representations that this was the true purchase price, Plaintiffs paid
Bouvier €62.5 million. The price which the seller was willing to accept and at which Bouvier
acquired the work was much lower.
68.

In the summer of 2014, when Plaintiffs agreed to part with Tête as partial

consideration for the purchase of Mark Rothko’s No. 6, Sotheby’s again played a critical role.
69.

Bouvier had agreed to purchase No. 6 from its owners for $80 million, but he

claimed in emails to Plaintiffs’ representative that the fictitious “seller” demanded €140 million.

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Plaintiffs agreed to this fraudulently inflated price. Plaintiffs and Bouvier agreed that he would
transfer Tête to the “seller” in satisfaction of €60 million of the total €140 million purchase price.
70.

Instead, Sotheby’s sold Tête at a public auction in New York in November 2014.

Sotheby’s did so despite knowing that the work was part of Plaintiffs’ collection, and despite
knowing that Bouvier lacked the authority to sell it—or at least never verifying whether he did.
Indeed, Bouvier himself testified to the Monaco authorities regarding another artwork consigned
to Sotheby’s: “Sotheby’s did not verify the [work]’s ownership. Mr. Valette and his team
accepted to do the transaction based on my good reputation. Mr. Valette did not know that the
paintings belonged to one of Mr. Rybolovlev’s companies. No certificate of authority was
required.”
71.

Bouvier kept the auction proceeds for himself and has never accounted to

Plaintiffs for them. The real sellers of No. 6, the Moueix family, never had any interest in Tête at
all.
Sotheby’s Arranges and Brokers the Klimt and da Vinci Transactions
72.

Despite its knowledge that Bouvier was charging Plaintiffs secret markups,

Sotheby’s promoted and brokered the Klimt and da Vinci transactions through Bouvier.
73.

Sotheby’s arranged a viewing of Wasserschlangen II for Plaintiffs on September

3, 2012. Sotheby’s also arranged the September 11 meeting in Paris at which Peretti agreed on
Bouvier’s behalf to buy the painting for $112 million.
74.

Sotheby’s brokered the $112 million sale of Wasserschlangen II to Bouvier.

75.

Over the next several months, Sotheby’s worked to obtain approval of the $112

million sale from the heirs of the painting’s original owners in Austria. This approval was

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necessary because the Nazis had stolen the painting from the original owner during the
Holocaust. The seller and the heirs split the proceeds of the $112 million sale in half.
76.

Similarly, Sotheby’s arranged Rybolovlev’s March 2013 viewing of Christ as

Salvator Mundi. Sotheby’s also showed the painting to Peretti the preceding day.
77.

A Sotheby’s representative participated in a meeting in early April 2013 at which

the sellers and Peretti negotiated the terms of the sale.
78.

Sotheby’s brokered the sale of Christ as Salvator Mundi from Adelson, Parish,

and Simon to Bouvier for $83 million.
79.

On November 21, 2016, Sotheby’s filed an action seeking a declaratory judgment

that it did not breach its obligations to the sellers of Salvator Mundi. Sotheby’s, Inc. v. R.W.
Chandler, LLC et al., No. 16-CV-9043 (S.D.N.Y.). (The case was quickly resolved by a
confidential settlement unavailable to Plaintiffs or to the public.) In that action, Sotheby’s
claimed it was unaware of Bouvier’s relationship with Rybolovlev when it arranged for
Rybolovlev to view Salvator Mundi. Sotheby’s has also claimed in correspondence that
Rybolovlev was “completely unknown” to them.
80.

Sotheby’s claim to have no knowledge of Rybolovlev is not credible.

81.

The viewing took place in a New York apartment at 15 Central Park West. When

the apartment was purchased for $88 million in 2011, it was the most expensive individual
purchase of an apartment ever in New York City. A connection between the apartment and the
Rybolovlev family was widely reported in the press and is common knowledge.
82.

Rybolovlev, Bouvier, and Valette were all among the small group of people

present at the viewing. According to Sotheby’s, Bouvier and Rybolovlev went into a separate
room of the apartment to view the painting together.

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83.

Sotheby’s claims that Valette did not know who Rybolovlev was at the time.

84.

It is inconceivable that Sotheby’s would arrange a viewing of one of the world’s

most valuable masterworks in one of the world’s most expensive apartments, in the presence of
the person widely reported by the press to be the apartment’s owner and entirely for his benefit,
without knowing who he was. Sotheby’s was trying to arrange a private sale of Salvator Mundi.
In that capacity, according to its website, its job was to “discreetly offer [Salvator Mundi] to
individual potential purchasers.” It would have been professional malpractice for Sotheby’s not
to know who Rybolovlev was.
85.

Valette and Sotheby’s knew exactly who Rybolovlev was, and they knew Bouvier

was purporting to act on Plaintiffs’ behalf.
Sotheby’s Issues Inflated Appraisals that Conceal Bouvier’s Fraud
86.

In late 2014, Sotheby’s helped Bouvier cover his tracks with a series of fraudulent

appraisals issued in rapid succession. If it had not previously known of Bouvier’s fraud, it surely
knew by the time it issued the appraisals.
87.

Bouvier requested that Sotheby’s appraise Wasserschlangen II in October 2014.

On October 24, 2014, Sotheby’s appraised the value of the painting at $180 million. The
appraisal is signed by Valette.
88.

The transaction history listed in the appraisal omits the 2012 sale to Bouvier at the

price of $112 million. Sotheby’s brokered that sale. That material omission must have been
intentional.
89.

The appraisal values Wasserschlangen II at roughly the inflated price Bouvier

confidentially invoiced to Plaintiffs, not the price Bouvier paid in the Sotheby’s sale. But it does

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not explain why. Sotheby’s knew Bouvier was trying to justify the inflated price he charged
Plaintiffs, and it chose to help him do so.
90.

Sotheby’s also provided Bouvier with several other appraisals on October 24,

2014. Each time, Sotheby’s valued the work at the confidential, inflated price Bouvier charged
Plaintiffs, without explaining why. Each time, Sotheby’s responded to Bouvier’s input in setting
the value of the work. Sotheby’s was collaborating with Bouvier to conceal his wrongdoing on a
wide scale.
91.

On October 24, 2014, Sotheby’s appraised Modigliani’s Nu Couché au Coussin

Bleu at $110 million at Bouvier’s request. The appraisal approximates the $118 million Bouvier
charged to Plaintiffs for this painting, rather than the $93.5 million he paid for it. The transaction
history listed in the appraisal omits the 2011 sale to Bouvier at the price the seller was willing to
accept.
92.

On October 24, 2014, Sotheby’s appraised Henri Matisse’s Nu au Chale Vert at

$85 million at Bouvier’s request. The appraisal is signed by Valette. Bouvier had charged
Plaintiffs $85 million, plus approximately $2.2 million in commission, for this painting in 2011.
The transaction history listed in the appraisal omits the 2011 sale to Bouvier at the price Bouvier
paid.
93.

On October 24, 2014, Sotheby’s appraised Paul Gauguin’s Otahi (Alone) at $120

million at Bouvier’s request. The appraisal is signed by Valette. Bouvier had charged Plaintiffs
€120 million, plus approximately €2.4 million in commission, for Otahi in 2013. Plaintiffs do not
know the price Bouvier paid for this painting. The transaction history listed in the appraisal omits
the 2013 sale to Bouvier.

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Plaintiffs Discover the Fraud As Sotheby’s Continues to Help Bouvier Conceal It
94.

Sotheby’s failure to disclose Bouvier’s fraud to Plaintiffs allowed Bouvier to

continue to perpetuate his scheme. But for Sotheby’s omissions, Plaintiffs would have
discovered Bouvier’s fraud much earlier and substantially mitigated their losses. But Sotheby’s
remained silent. Inasmuch as Bouvier’s wrongful conduct would not have been possible without
Sotheby’s substantial assistance, Sotheby’s is liable for Plaintiffs’ damages after Sotheby’s first
involvement in the scheme.
95.

Even as Bouvier’s fraud began to come to light, Sotheby’s continued to provide

him with inflated appraisals on demand to justify the fraudulent prices he charged Plaintiffs.
96.

In November 2014, Plaintiffs and Rybolovlev became aware of an article in The

New York Times reporting that the purchase price of Christ as Salvator Mundi in the 2013
Sotheby’s sale was $75 to $80 million. The article had been published several months earlier.
97.

Plaintiffs began to suspect Bouvier had defrauded them. Plaintiffs’ representative

confronted Bouvier. Bouvier said the media underreported the price because the total price
included various fees and commissions of which the media was not aware.
98.

In December 2014, Plaintiffs discovered the true purchase price of Nu Couché au

Coussin Bleu. At that point, Plaintiffs became certain Bouvier had defrauded them.
99.

In January 2015, after Plaintiffs’ representative confronted him, Bouvier

contacted Valette to request that Sotheby’s appraise Salvator Mundi. Sotheby’s agreed.
100.

Sotheby’s issued an appraisal on January 28, 2015. At Bouvier’s request,

Sotheby’s valued Salvator Mundi at €100 million.
101.

Sotheby’s appraisal includes a transaction history, but it omits the 2013 sale to

Bouvier. Sotheby’s brokered that sale. The omission must have been intentional.

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102.

The appraisal values Salvator Mundi at the inflated price Bouvier confidentially

invoiced to Plaintiffs, not the price Bouvier negotiated in the Sotheby’s sale that the seller was
willing to accept. But it does not explain why. Sotheby’s knew Bouvier was trying to justify the
fraudulent price he charged Plaintiffs, and it chose to help him do so.
Plaintiffs Attempt to Bring Bouvier to Justice
103.

In European civil law countries, crime victims can start criminal proceedings. As

Bouvier’s lies, misrepresentations, and deliberate omissions came to light, Plaintiffs started
criminal proceedings against him and Rappo in Monaco. Plaintiff Accent Delight International
Ltd. also joined criminal proceedings started by a third party against Bouvier in Paris.
104.

Bouvier has been charged with fraud and complicity in money laundering in

Monaco and has been charged with repeated handling of stolen goods in France. Magistrates in
both countries are continuing to investigate Bouvier’s crimes.
105.

Plaintiffs sued Bouvier for civil damages in Singapore, the site of his art

warehousing business. Bouvier has taken measures to liquidate his assets and place them beyond
the reach of the Singapore courts.
106.

Plaintiffs also brought criminal charges against Bouvier in Switzerland.

107.

Bouvier was taken in for questioning in Monaco in 2015. Police recovered from

him a USB flash drive containing several scanned Sotheby’s logos, Valette’s electronic
signature, and the electronic signature of another Sotheby’s official, Dr. Franka Haiderer, Senior
Director and Chairman for Valuations in Europe.
108.

To date, Sotheby’s has not terminated Valette’s employment or, to Plaintiffs’

knowledge, disciplined him in any way.

17

 Case 1:18-cv-09011 Document 1 Filed 10/02/18 Page 18 of 24

Sotheby’s Functions as One Single Entity
109.

Sotheby’s dominates and controls its wholly owned foreign subsidiaries and

functions as a single integrated global business, supervised from New York. Sotheby’s used such
domination to commit the wrongful acts that injured Plaintiffs. The wholly owned foreign
subsidiaries are mere instrumentalities of Sotheby’s wrongdoing.
110.

Sotheby’s describes its wholly owned foreign subsidiaries as “offices” or

“locations,” not as independent entities.
111.

Sotheby’s has one chief executive officer, one worldwide general counsel, one

global head of compliance, one director of communications—all based in its New York
headquarters. Its website, branding, marketing materials, and letterhead are the same around the
world.
112.

Sotheby’s maintains consolidated financial statements. Its wholly owned foreign

subsidiaries are not treated as independent profit and loss centers, and do not deal at arms length
with each other. On information and belief, Sotheby’s transfers assets between its wholly owned
foreign subsidiaries. The subsidiaries do not have their own executives and do not appoint their
own leadership. Rather, Sotheby’s is centrally managed from New York.
113.

In some of the transactions that Sotheby’s arranged for Bouvier, including the

Salvator Mundi sale, the contracts were signed by Sotheby’s, Inc. In others, the contracts were
signed by one of Sotheby’s wholly owned foreign subsidiaries, which Sotheby’s dominates and
controls.
114.

Irrespective of which subsidiaries technically employ Valette and Bell, Valette

and Bell were acting on behalf of Sotheby’s, Inc. during their dealings with Bouvier. As

18

 Case 1:18-cv-09011 Document 1 Filed 10/02/18 Page 19 of 24

Valette’s title reflects—Vice Chairman of Private Sales Worldwide—he is empowered to act and
does act on behalf of Sotheby’s and all of its subsidiaries.
115.

Sotheby’s, Inc. has repeatedly acknowledged as much. For example, as it

explained in its declaratory judgment complaint filed in this Court, Valette and Bell negotiated
the Salvator Mundi deal on behalf of Sotheby’s, Inc. with Bouvier and the sellers of that
painting.
116.

In the declaratory judgment complaint described in paragraph 79 above,

Sotheby’s, Inc. described Valette as its employee.
117.

In an affidavit filed in other proceedings in this Court, a Sotheby’s executive has

testified that Valette “managed” the relationship between Sotheby’s, Inc. and Bouvier.
Declaration of Aimee Scillieri (ECF No. 153), In re Application of Accent Delight Int’l, No. 16MC-125 (S.D.N.Y. Mar. 13, 2018).
118.

Sotheby’s subsidiaries, Valette, and Bell were instrumentalities of Sotheby’s

wrongful conduct.
FIRST CLAIM
Aiding and Abetting Fraud
119.

Plaintiffs repeat and reallege the allegations in the preceding Paragraphs.

120.

Sotheby’s had actual knowledge that Bouvier was defrauding Plaintiffs. Sotheby’s

and Bouvier had an intimate business relationship for years. Sotheby’s knew Bouvier was
Plaintiffs’ agent. Sotheby’s knew the price that Bouvier obtained in transactions it brokered. Yet,
Sotheby’s sent Bouvier emails designed to get Plaintiffs to pay inflated prices for other works.
And Sotheby’s gave Bouvier materially misleading appraisals on demand. These appraisals
deliberately omitted Bouvier’s acquisitions of the works to create the false impression that
Plaintiffs paid fair prices.
19

 Case 1:18-cv-09011 Document 1 Filed 10/02/18 Page 20 of 24

121.

Sotheby’s provided substantial assistance to Bouvier, causing injury to Plaintiffs.

Sotheby’s affirmatively assisted Bouvier by arranging for him to acquire artworks at certain
prices that the sellers were willing to accept, and by sending him emails intended to help him
convince Plaintiffs to pay Bouvier fraudulently inflated prices. Sotheby’s helped Bouvier conceal
his fraud by providing materially misleading appraisals that falsely suggested the artworks were
worth what Plaintiffs paid for them.
122.

As a result of Sotheby’s aiding and abetting Bouvier’s fraud, Plaintiffs have

sustained damages in an amount to be determined at trial but not less than $380,000,000 plus
interest.
123.

Sotheby’s conduct was willful, wanton, reckless, and intentional.
SECOND CLAIM
Aiding and Abetting Breach of Fiduciary Duty

124.

Plaintiffs repeat and reallege the allegations in the preceding Paragraphs.

125.

Sotheby’s knowingly participated in Bouvier’s breach of his fiduciary obligations

by providing him with substantial assistance. Bouvier was Plaintiffs’ fiduciary. Bouvier held
himself out as a skilled expert in the art market. Plaintiffs relied on Bouvier to provide them with
strategic advice about the art market and to negotiate high-stakes transactions on their behalf.
Plaintiffs had confidence in Bouvier because of their years of business dealings and because of
Rappo’s personal connection to Rybolovlev.
126.

Bouvier breached his fiduciary duties to Plaintiffs by acting disloyally and

contrary to Plaintiffs’ interests. Rather than act on Plaintiffs’ behalf to acquire artworks at fair,
negotiated prices that sellers were willing to accept, Bouvier seized those opportunities for his
own benefit. He then harmed Plaintiffs’ interests by charging them inflated prices on the basis of
false representations.
20

 Case 1:18-cv-09011 Document 1 Filed 10/02/18 Page 21 of 24

127.

Sotheby’s knew that Bouvier was Plaintiffs’ agent and that Plaintiffs relied on his

counsel. It strategized to sell Plaintiffs art through Bouvier and approached Bouvier about new
opportunities for Plaintiffs. By brokering sales to Bouvier at certain prices, sending Bouvier
emails designed to encourage Plaintiffs to pay inflated prices, and misleadingly appraising works
at inflated prices, Sotheby’s participated in Bouvier’s breach of his fiduciary duties to Plaintiffs.
128.

As a result of Sotheby’s aiding and abetting Bouvier’s breach of fiduciary duty,

Plaintiffs have sustained damages in an amount to be determined at trial but not less than
$380,000,000 plus interest.
129.

Sotheby’s conduct was willful, wanton, reckless, and intentional.
THIRD CLAIM
Breach of Contract – Declaratory Judgment

130.

Plaintiffs repeat and reallege the allegations in the preceding Paragraphs.

131.

In December 2016, Plaintiffs and Sotheby’s (including its New York, English,

Swiss and Austrian subsidiaries) entered into a one-year written Tolling Agreement.
132.

The Tolling Agreement contains a New York choice of law clause and an

exclusive New York forum selection clause.
133.

Among other things, the Tolling Agreement required each party to the agreement

to “provide 14 days written notice (“Notice of Suit”), as provided in paragraph 8 [of the Tolling
Agreement,] prior to filing or commencing any litigation or other legal proceeding against any
other party” based on claims or defenses “arising out of the direct or indirect involvement of
Sotheby’s with Yves Bouvier.” Tolling Agreement ¶¶ 3, 1.
134.

Paragraph 8 of the Tolling Agreement, referred to above, states: “All notices

required hereunder shall be in writing and shall be deemed duly given on (1) business day after
being sent at the address given below by reputable overnight courier service (charges prepaid), as
21

 Case 1:18-cv-09011 Document 1 Filed 10/02/18 Page 22 of 24

follows: If to the Collectors [Plaintiffs]: c/o Daniel J. Kornstein, Esq., Emery Celli Brinckerhoff
& Abady LLP, 600 Fifth Avenue, 10th Floor, New York, NY 10020.”
135.

Sotheby’s filed a civil proceeding in Geneva, Switzerland on November 17, 2017

against Plaintiffs (among others) without complying with the notice provision of the Tolling
Agreement quoted above. The purpose of this filing was to invoke the international Lugano
Convention to block a contemplated suit by Plaintiffs in the United Kingdom. Under the Lugano
Convention, if a suit is filed in a signatory country—such as Switzerland—if another suit is filed
in a court in a second country, the second jurisdiction must stay its proceedings until jurisdiction
in the first court has been established. Once the jurisdiction of the first court has been
established, the proceedings in the second court must be dismissed.
136.

As Sotheby’s has stated in its Form 10-Q filed with the Securities and Exchange

Commission, it filed the Swiss conciliation proceeding “in response to the stated intent of
[Plaintiffs] to initiate litigation in the U.K.”
137.

Sotheby’s did not give any advance notice of any kind that it was filing a civil

action in Switzerland, much less 14 days written notice sent by overnight courier service to
Plaintiffs’ counsel.
138.

Plaintiffs have abided by the terms of the Tolling Agreement.

139.

Sotheby’s breached the Tolling Agreement.

140.

Plaintiffs are entitled to a judgment declaring that Sotheby’s breached the Tolling

Agreement.
FOURTH CLAIM
Breach of Contract – Damages
141.

Plaintiffs repeat and reallege the allegations in the preceding Paragraphs.

22

 Case 1:18-cv-09011 Document 1 Filed 10/02/18 Page 23 of 24

142.

As a result of Sotheby’s breach of the Tolling Agreement, Plaintiffs have

sustained damages, in the form of legal fees in the course of responding to the improperly filed
civil proceeding in Switzerland.
FIFTH CLAIM
Breach of Contract – Injunction
143.

Plaintiffs repeat and reallege the allegations in the preceding Paragraphs.

144.

As a result of Sotheby’s breach of the Tolling Agreement, Plaintiffs are entitled to

a mandatory injunction directing Sotheby’s, its agents and employees, and the wholly owned
subsidiaries under its control to withdraw the improperly brought Swiss civil proceeding.
145.

Sotheby’s improperly filed the civil suit in Switzerland in order to use the Lugano

Convention to block Plaintiffs from suing Sotheby’s in the United Kingdom, which is a signatory
to the Lugano Convention, thereby improperly depriving Plaintiffs of their choice of jurisdiction.
146.

As a result, Plaintiffs have suffered irreparable harm for which monetary damages

are an inadequate remedy.
WHEREFORE, Plaintiffs demand judgment as follows:
a.

On the first and second claims, directing Defendants to pay to Plaintiffs

compensatory damages in an amount to be determined at trial, but in any event no less than
$380,000,000 plus interest;
b.

On the first and second claims, directing Defendants to pay to Plaintiffs punitive

damages in an amount to be determined at trial;
c.

On the third claim, declaring that Defendants breached the Tolling Agreement;

d.

On the fourth claim, directing Defendants to pay to Plaintiffs compensatory

damages in an amount to be determined at trial, including the attorney’s fees and related costs
expended by Plaintiffs in responding to the improperly brought Swiss civil proceeding;
23

 Case 1:18-cv-09011 Document 1 Filed 10/02/18 Page 24 of 24

e.

On the fifth claim, preliminarily and permanently enjoining Defendants, their

subsidiaries under their control, and their agents and employees, to withdraw the Swiss civil
proceeding filed on November 17, 2017; and
f.

Awarding Plaintiffs costs, disbursements, and such other and further relief as the

Court may deem just and proper.
Dated: October 2, 2018
New York, New York
~ MERY

CELLI BRINCKERHOFF

&AB DYLLP

Daniel J. Kornstei

0. Andrew F. Wil o
Douglas E. Lieb
600 Fifth Avenue, 10th Floor
New York, New York 10020
(212) 763-5000
Attorneys for Plaintiffs

24

 Case 17-50877

Doc 1

Filed 08/18/17

Page 1 of 29

Fill in this information to identify your case:
United States Bankruptcy Court for the:
MIDDLE DISTRICT OF NORTH CAROLINA
Case number (if known)

Chapter

11

 Check if this an
amended filing

Official Form 201

Voluntary Petition for Non-Individuals Filing for Bankruptcy

4/16

If more space is needed, attach a separate sheet to this form. On the top of any additional pages, write the debtor's name and case number (if known).
For more information, a separate document, Instructions for Bankruptcy Forms for Non-Individuals, is available.
1.

Debtor's name

2.

All other names debtor
used in the last 8 years

ALEVO MANUFACTURING, INC.

Include any assumed
names, trade names and
doing business as names
3.

Debtor's federal
Employer Identification
Number (EIN)

46-2053454

4.

Debtor's address

Principal place of business

Mailing address, if different from principal place of
business

2321 CONCORD PARKWAY S
Concord, NC 28027
Number, Street, City, State & ZIP Code

P.O. Box, Number, Street, City, State & ZIP Code

Cabarrus

Location of principal assets, if different from principal
place of business

County

Number, Street, City, State & ZIP Code
5.

Debtor's website (URL)

ALEVO.COM

6.

Type of debtor



Corporation (including Limited Liability Company (LLC) and Limited Liability Partnership (LLP))

 Partnership (excluding LLP)
 Other. Specify:

Official Form 201

Voluntary Petition for Non-Individuals Filing for Bankruptcy

page 1

 Case 17-50877
Debtor

Doc 1

Filed 08/18/17

Page 2 of 29

Case number (if known)

ALEVO MANUFACTURING, INC.
Name

7.

Describe debtor's business

A. Check one:










Health Care Business (as defined in 11 U.S.C. § 101(27A))
Single Asset Real Estate (as defined in 11 U.S.C. § 101(51B))
Railroad (as defined in 11 U.S.C. § 101(44))
Stockbroker (as defined in 11 U.S.C. § 101(53A))
Commodity Broker (as defined in 11 U.S.C. § 101(6))
Clearing Bank (as defined in 11 U.S.C. § 781(3))
None of the above

B. Check all that apply

 Tax-exempt entity (as described in 26 U.S.C. §501)
 Investment company, including hedge fund or pooled investment vehicle (as defined in 15 U.S.C. §80a-3)
 Investment advisor (as defined in 15 U.S.C. §80b-2(a)(11))
C. NAICS (North American Industry Classification System) 4-digit code that best describes debtor.
See http://www.uscourts.gov/four-digit-national-association-naics-codes.

4236
8.

Under which chapter of the
Bankruptcy Code is the
debtor filing?

Check one:

 Chapter 7
 Chapter 9



Chapter 11. Check all that apply:

 Debtor's aggregate noncontingent liquidated debts (excluding debts owed to insiders or affiliates)
are less than $2,566,050 (amount subject to adjustment on 4/01/19 and every 3 years after that).

 The debtor is a small business debtor as defined in 11 U.S.C. § 101(51D). If the debtor is a small
business debtor, attach the most recent balance sheet, statement of operations, cash-flow
statement, and federal income tax return or if all of these documents do not exist, follow the
procedure in 11 U.S.C. § 1116(1)(B).

 A plan is being filed with this petition.
 Acceptances of the plan were solicited prepetition from one or more classes of creditors, in
accordance with 11 U.S.C. § 1126(b).

 The debtor is required to file periodic reports (for example, 10K and 10Q) with the Securities and
Exchange Commission according to § 13 or 15(d) of the Securities Exchange Act of 1934. File the
attachment to Voluntary Petition for Non-Individuals Filing for Bankruptcy under Chapter 11
(Official Form 201A) with this form.

 The debtor is a shell company as defined in the Securities Exchange Act of 1934 Rule 12b-2.
 Chapter 12

9.

Were prior bankruptcy
cases filed by or against
the debtor within the last 8
years?

 No.
 Yes.

If more than 2 cases, attach a
separate list.

10. Are any bankruptcy cases
pending or being filed by a
business partner or an
affiliate of the debtor?
List all cases. If more than 1,
attach a separate list

Official Form 201

District

When

Case number

District

When

Case number

 No

 Yes.
Debtor

ALEVO USA, INC.

District

MIDDLE DISTRICT OF
NORTH CAROLINA

Relationship
When

Voluntary Petition for Non-Individuals Filing for Bankruptcy

AFFILIATE

Case number, if known

page 2

 Case 17-50877
Debtor

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Page 3 of 29

Case number (if known)

ALEVO MANUFACTURING, INC.
Name

11. Why is the case filed in
this district?

12. Does the debtor own or
have possession of any
real property or personal
property that needs
immediate attention?

Check all that apply:



Debtor has had its domicile, principal place of business, or principal assets in this district for 180 days immediately
preceding the date of this petition or for a longer part of such 180 days than in any other district.



A bankruptcy case concerning debtor's affiliate, general partner, or partnership is pending in this district.

 No

 Yes.

Answer below for each property that needs immediate attention. Attach additional sheets if needed.
Why does the property need immediate attention? (Check all that apply.)

 It poses or is alleged to pose a threat of imminent and identifiable hazard to public health or safety.
What is the hazard?

 It needs to be physically secured or protected from the weather.
 It includes perishable goods or assets that could quickly deteriorate or lose value without attention (for example,
livestock, seasonal goods, meat, dairy, produce, or securities-related assets or other options).

 Other

FACILITY REQUIRES UTILITIES TO DETECT AND HANDLE POTENTIALLY
HAZARDOUS GASES AND MATERIALS.

Where is the property?

2321 CONCORD PARKWAY S
Concord, NC, 28027-0000
Number, Street, City, State & ZIP Code

Is the property insured?

 No

 Yes.

Insurance agency

LOCKTON COMPANY LLC

Contact name

DOUGLAS HUTCHERSON

Phone

(404) 460-0700 dhutcerson@lockton.com

Statistical and administrative information
13. Debtor's estimation of
available funds

.

Check one:

 Funds will be available for distribution to unsecured creditors.
 After any administrative expenses are paid, no funds will be available to unsecured creditors.

14. Estimated number of
creditors

 1-49
 50-99

 1,000-5,000
 5001-10,000
 10,001-25,000

 25,001-50,000
 50,001-100,000
 More than100,000

 $0 - $50,000
 $50,001 - $100,000
 $100,001 - $500,000
 $500,001 - $1 million

 $1,000,001 - $10 million

 $500,000,001 - $1 billion
 $1,000,000,001 - $10 billion
 $10,000,000,001 - $50 billion
 More than $50 billion

 $0 - $50,000
 $50,001 - $100,000
 $100,001 - $500,000
 $500,001 - $1 million

 $1,000,001 - $10 million

 100-199
 200-999
15. Estimated Assets

16. Estimated liabilities

Official Form 201

 $10,000,001 - $50

million
 $50,000,001 - $100 million
 $100,000,001 - $500 million

 $10,000,001 - $50

million
 $50,000,001 - $100 million
 $100,000,001 - $500 million

Voluntary Petition for Non-Individuals Filing for Bankruptcy

 $500,000,001 - $1 billion
 $1,000,000,001 - $10 billion
 $10,000,000,001 - $50 billion
 More than $50 billion

page 3

 Case 17-50877
Debtor

Doc 1

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Page 4 of 29

Case number (if known)

ALEVO MANUFACTURING, INC.
Name

Request for Relief, Declaration, and Signatures
WARNING -- Bankruptcy fraud is a serious crime. Making a false statement in connection with a bankruptcy case can result in fines up to $500,000 or
imprisonment for up to 20 years, or both. 18 U.S.C. §§ 152, 1341, 1519, and 3571.
17. Declaration and signature
of authorized
representative of debtor

The debtor requests relief in accordance with the chapter of title 11, United States Code, specified in this petition.
I have been authorized to file this petition on behalf of the debtor.
I have examined the information in this petition and have a reasonable belief that the information is trued and correct.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on

August 18, 2017
MM / DD / YYYY

X

/s/ PETER HEINTZELMAN

PETER HEINTZELMAN

Signature of authorized representative of debtor

Printed name

Title

18. Signature of attorney

X

PRESIDENT

/s/ Terri L. Gardner

Date August 18, 2017
MM / DD / YYYY

Signature of attorney for debtor

Terri L. Gardner
Printed name

Nelson Mullins Riley & Scarborough LLP
Firm name

4140 Parklake Avenue, Suite 200
Raleigh, NC 27612
Number, Street, City, State & ZIP Code
Contact phone

(919) 329-3800

Email address

terri.gardner@nelsonmullins.com

9809
Bar number and State

Official Form 201

Voluntary Petition for Non-Individuals Filing for Bankruptcy

page 4

 Case 17-50877

Doc 1

Filed 08/18/17

Page 5 of 29

Fill in this information to identify the case:
Debtor name

ALEVO MANUFACTURING, INC.

United States Bankruptcy Court for the:

MIDDLE DISTRICT OF NORTH CAROLINA

Case number (if known)

 Check if this is an
amended filing

Official Form 202

Declaration Under Penalty of Perjury for Non-Individual Debtors

12/15

An individual who is authorized to act on behalf of a non-individual debtor, such as a corporation or partnership, must sign and submit this
form for the schedules of assets and liabilities, any other document that requires a declaration that is not included in the document, and any
amendments of those documents. This form must state the individual’s position or relationship to the debtor, the identity of the document,
and the date. Bankruptcy Rules 1008 and 9011.
WARNING -- Bankruptcy fraud is a serious crime. Making a false statement, concealing property, or obtaining money or property by fraud in
connection with a bankruptcy case can result in fines up to $500,000 or imprisonment for up to 20 years, or both. 18 U.S.C. §§ 152, 1341,
1519, and 3571.

Declaration and signature
I am the president, another officer, or an authorized agent of the corporation; a member or an authorized agent of the partnership; or another
individual serving as a representative of the debtor in this case.
I have examined the information in the documents checked below and I have a reasonable belief that the information is true and correct:












Schedule A/B: Assets–Real and Personal Property (Official Form 206A/B)
Schedule D: Creditors Who Have Claims Secured by Property (Official Form 206D)
Schedule E/F: Creditors Who Have Unsecured Claims (Official Form 206E/F)
Schedule G: Executory Contracts and Unexpired Leases (Official Form 206G)
Schedule H: Codebtors (Official Form 206H)
Summary of Assets and Liabilities for Non-Individuals (Official Form 206Sum)
Amended Schedule
Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 20 Largest Unsecured Claims and Are Not Insiders (Official Form 204)
Other document that requires a declaration

I declare under penalty of perjury that the foregoing is true and correct.
Executed on

August 18, 2017

X /s/ PETER HEINTZELMAN
Signature of individual signing on behalf of debtor

PETER HEINTZELMAN
Printed name

PRESIDENT
Position or relationship to debtor

Official Form 202

Declaration Under Penalty of Perjury for Non-Individual Debtors

Software Copyright (c) 1996-2016 Best Case, LLC - www.bestcase.com

Best Case Bankruptcy

 Case 17-50877

Doc 1

Filed 08/18/17

Page 6 of 29

Fill in this information to identify the case:
Debtor name ALEVO MANUFACTURING, INC.
United States Bankruptcy Court for the: MIDDLE DISTRICT OF NORTH
CAROLINA
Case number (if known):

 Check if this is an
amended filing

Official Form 204
Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 20 Largest Unsecured Claims and
Are Not Insiders
12/15
A list of creditors holding the 20 largest unsecured claims must be filed in a Chapter 11 or Chapter 9 case. Include claims which the
debtor disputes. Do not include claims by any person or entity who is an insider, as defined in 11 U.S.C. § 101(31). Also, do not
include claims by secured creditors, unless the unsecured claim resulting from inadequate collateral value places the creditor
among the holders of the 20 largest unsecured claims.
Name of creditor and
Name, telephone number Nature of claim
(for example, trade
complete mailing address, and email address of
debts, bank loans,
including zip code
creditor contact
professional services,
and government
contracts)

Advanced Lithium
Electrochemistry
Co.
2-1, Hsing Hua Road
Taoyuan City, 33068
Taiwan, Province of
China
Alantum Advanced
Technology
Materials
Free Trade Zone
IIIB-611660
Dalian City, China
ATS Automation
Global Services
USA, Inc.
730 Fountain St
North, Bldg 2
Cambridge, ON N3H
4R7
Canada
C.H. Robinson
Worldwide, Inc. and
Subsi
PO Box 9121
Minneapolis, MN
55480-9121
Century
Contractors, Inc.
5100 Smith Farm
Road
Matthews, NC 28104
Duke Energy
PO Box 1090
Charlotte, NC
28201-1090

Official form 204

Indicate if claim
is contingent,
unliquidated, or
disputed

Amount of claim
If the claim is fully unsecured, fill in only unsecured claim amount. If
claim is partially secured, fill in total claim amount and deduction for
value of collateral or setoff to calculate unsecured claim.
Total claim, if
Deduction for value
Unsecured claim
partially secured
of collateral or setoff

Trade

$333,696.00

Trade

$1,021,384.42

Trade

$593,542.00

Trade Debt

$106,741.89

william_hwang@al
echem.com

Amy.Liu@cnemala
ntum.com

rfaulhammer@atsa
utomation.com

Tracey Gall
t.gall@chrobinson.
com
(281) 920-1089

Trade

$2,213,040.04

hsmith@centuryco
ntractors.com
Utility Service

$180,000.00

Yolanda.Simms@d
uke-energy.com

Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 20 Largest Unsecured claims

Software Copyright (c) 1996-2016 Best Case, LLC - www.bestcase.com

page 1
Best Case Bankruptcy

 Case 17-50877

Debtor

Doc 1

Filed 08/18/17

Page 7 of 29

Case number (if known)

ALEVO MANUFACTURING, INC.
Name

Name of creditor and
Name, telephone number Nature of claim
(for example, trade
complete mailing address, and email address of
debts, bank loans,
including zip code
creditor contact
professional services,
and government
contracts)

Imerys Graphite &
Carbon USA, Inc.
C/O T60092U
PO Box 66512
Chicago, IL
60666-0512
Innovative Machine
Corporation
PO Box 9904
Birmingham, AL
35220
Interglas
Technologies
PF 110389151
Erbach Germany
Jonas & Redmann
Kaiserin-Augusta-Al
lee 113
Berlin Germany
Leukert GmbH
Reiftrager Weg 39
Kaufbeuren, 87600
Germany
MSS Fire & Safety,
LLC
PO Box 538178
Atlanta, GA 30353
P.C. Godfrey, Inc.
1816 Rozzelles Ferry
Rd
Charlotte, NC 28208
Recore Electrical
Contractors, Inc.
PO Box 1972
Gastonia, NC
28053-1972
Saint-Gobain
Performance
Plastics Corp
PO Box 743699
Atlanta, GA
30374-3699
Siemens Industry,
Inc.
2201 Crownppoint
Executive Drive
Bldg 2, Ste K
Charlotte, NC 28227
Solith
Via Fattori 6 40033
Casalecchio di Reno
Italy
Official form 204

Kirk Swales

Indicate if claim
is contingent,
unliquidated, or
disputed

Amount of claim
If the claim is fully unsecured, fill in only unsecured claim amount. If
claim is partially secured, fill in total claim amount and deduction for
value of collateral or setoff to calculate unsecured claim.
Total claim, if
Deduction for value
Unsecured claim
partially secured
of collateral or setoff

Trade

$277,920.00

Trade

$366,822.14

Trade Debt

$128,396.55

kirk.swales@imery
s.com

jim@innovativema
ch.com

Henry.Urban@inter
glas-technologies.c
om
Trade

Disputed

$649,220.19

m.dietrich@jonas-r
edmann.com
Trade

$187,895.67

Trade

$391,044.87

Trade

$206,046.00

Trade

$365,977.30

Trade

$261,000.00

Trade

$152,907.72

pleiel.juergen@leu
kert.de
carrie.seay@mmss
olutions.com
jwright@pcgodfrey
.com
blair@recoreelectri
c.com

christopher.p.rhyn
e@saint-gobain.co
m

Nicholas.grothe@s
iemens.com

Trade

Disputed

$279,018.45

benner@sempa.de

Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 20 Largest Unsecured claims

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Best Case Bankruptcy

 Case 17-50877

Debtor

Doc 1

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Page 8 of 29

Case number (if known)

ALEVO MANUFACTURING, INC.
Name

Name of creditor and
Name, telephone number Nature of claim
(for example, trade
complete mailing address, and email address of
debts, bank loans,
including zip code
creditor contact
professional services,
and government
contracts)

Sovema S.P.A.
Via Spagna 13,
37069
Villafranca di
Verona VR
Italy
Superb Industries,
Inc.
100 Innovation Plaza
Sugarcreek, OH
44681
Tongrun
International, LLC
3522 Sam Rayburn
Highway
Melissa, TX 75454

Official form 204

Trade

Indicate if claim
is contingent,
unliquidated, or
disputed

Amount of claim
If the claim is fully unsecured, fill in only unsecured claim amount. If
claim is partially secured, fill in total claim amount and deduction for
value of collateral or setoff to calculate unsecured claim.
Total claim, if
Deduction for value
Unsecured claim
partially secured
of collateral or setoff

Disputed

$165,116.74

Michele.Bonizzato
@sovema.it

Trade

$142,979.02

Trade

$179,015.40

johnmiller@superb
industries.com

connie@tongrunint
ernational.com

Chapter 11 or Chapter 9 Cases: List of Creditors Who Have the 20 Largest Unsecured claims

Software Copyright (c) 1996-2016 Best Case, LLC - www.bestcase.com

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Best Case Bankruptcy

 Case 17-50877

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United States Bankruptcy Court
Middle District of North Carolina
In re

ALEVO MANUFACTURING, INC.
Debtor(s)

Case No.
Chapter

11

VERIFICATION OF CREDITOR MATRIX

I, the PRESIDENT of the corporation named as the debtor in this case, hereby verify that the attached list of creditors is true and
correct to the best of my knowledge.

Date:

August 18, 2017

/s/ PETER HEINTZELMAN
PETER HEINTZELMAN/PRESIDENT

Signer/Title

Software Copyright (c) 1996-2016 Best Case, LLC - www.bestcase.com

Best Case Bankruptcy

 Case 17-50877

Doc 1

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Page 10 of 29

x
a
M
s
A
o
t
i
d
e
r
C
{
1
k
b
}

3M Company
PO Box 371227
Pittsburgh, PA 15250-7227
AC Controls Company Inc.
PO Box 63243
Charlotte, NC 28263-3243
Accounting Principals, Inc.
Dept CH 14031
Palatine, IL 60055
Action Industrial Supply
924 Cochran Street
Statesville, NC 28677
ADP Screening & Selection Services, Inc.
PO Box 645177
Cincinnati, OH 45264-5177
Advanced Lithium Electrochemistry Co.
2-1, Hsing Hua Road
Taoyuan City, 33068
Taiwan, Province of China
Advanced Machining & Tooling, LLC
215 Forbes Avenue
Salisbury, NC 28147
AERIS Enviromental, Inc.
1440 Blueberry Lane
Charlotte, NC 28226
Aerotek, Inc.
3689 Collection Center Drive
Chicago, IL 60693
Airgas USA, LLC
PO Box 532609
Atlanta, GA 30353-2609
Alantum Advanced Technology Materials
Free Trade Zone IIIB-611660
Dalian City, China

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Alevo Group S.A.
c/o Markus Adler
Chief General Counsel
Rue des Finettes 110
1920 Martigny   Switzerland
Alfa International Ent. Ltd.
6540 Gottardo Court
Mississauga Canada
Allied Caster & Equipment Co.
3841 Corporation Circle
Charlotte, NC 28216
Allied Electronics, Inc.
7151 Jack Newell Boulevard South
Fort Worth, TX 76118
Ally Financial, Inc.
PO Box 9001948
Louisville, KY 40290
American Safety Clothing, Inc.
30 East Park Avenue
Sellersville, PA 18960-2731
Applied Industrial Technologies-Dixie, I
22510 Network Place
Chicago, IL 60673-1225
Armstrong Relocation
4400 Westinghouse Boulevard
Charlotte, NC 28273
Atlas Copco Compressors LLC
3042 Southcross Boulevard, Suite 102
Rock Hill, SC 29730
ATS Automation Global Services USA, Inc.
730 Fountain St North, Bldg 2
Cambridge, ON N3H 4R7
Canada

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Automation Technology, Inc.
PO Box 348
Charlotte, NC 28206
AutomationDirect.com, Inc.
PO Box 402417
Atlanta, GA 30384-2417
Bahnson, Inc.
4731 Commercial Park Court
Clemmons, NC 27012
Barefoot Oil
754 Concord Parkway N
Concord, NC 28027
Bearing Distributors
PO Box 887
Columbia, SC 29202
Bec-Car Printing Co., Inc.
128 West Plaza Drive
Mooresville, NC 28117
Bertelkamp Automation Inc.
PO Box 11488
Knoxville, TN 37939
BK Giulini
Giulinistrasse 276065
Ludwigshafen/Rhein Germany
BLR (Business & Legal Resources)
PO Box 5094
Brentwood, TN 37027
Blue Cross Blue Shield
PO Box 580017
Charlotte, NC 28258-0017
Brenntag Mid-South Inc.
PO Box 752094
Charlotte, NC 28275-2094

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Brookfield Ametek
11 Commerce Boulevard
Middleboro, MA 02346
C&C Boiler Sales and Services, Inc.
6000 Preston Lane
Charlotte, NC 28270
C.H. Robinson Worldwide, Inc. and Subsi
PO Box 9121
Minneapolis, MN 55480-9121
Cabarrus County Tax Collector
65 Church Street S
Concord, NC 28025
Callaway Industrial Service, Inc.
PO Box 3128
Mooresville, NC 28117
CardsandKeyfobs.com
PO Box 205
Saint Anthony, ID 83445
Career Builders.Com
13047 Collectoin Center Drive
Chicago, IL 60693-0130
Carolina Brush Company
PO Box 2469
Gastonia, NC 28053
Carolina Cat-Power Systems Division
PO Box 75054
Charlotte, NC 28275-0054
Carolinas HealthCare SystemMedical Group
920 Church Street North
Concord, NC 28025
Carotek, Inc.
PO Box 890140
Charlotte, NC 28289-0140

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Carrier Corporation
PO Box 93844
Chicago, IL 60673-3844
Carter's Machine Co., Inc.
540 Lake Lynn Road
Concord, NC 28025
Catawba Industrial Rubber Co.
4629 Dwight Evans Road
Charlotte, NC 28217
Center for Occupational Diagnostics, LLC
9710 Northcross Center Court
Huntersville, NC 28078
Century Contractors, Inc.
5100 Smith Farm Road
Matthews, NC 28104
ChemTreat, Inc.
15045 Collection Center Drive
Chicago, IL 60693
Cimtec Automation LLC
3030 Whitehall Park Drive
Charlotte, NC 28273
Cintas Corp No. 2
PO Box 630803
Cincinnati, OH 45263-0803
City of Concord - Collections
PO Box 540469
Charlotte, NC 28258-0469
Civil & Enviromental Consultants, Inc.
PO Box 644246
Pittsburgh, PA 15264-4246
Cleatech LLC
221 W. Dyer Road
Santa Ana, CA 92707

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CNP Technologies, LLC
806 Tyvola Road
Suite 102
Charlotte, NC 28217
CogencyGlobal, Inc.
10 E 40th Street, 10th Floor
New York, NY 10016
Cole-Parmer Instrument Company LLC
13927 Collections Center Drive
Chicago, IL 60693-0139
Cort Furniture Rental
PO Box 17401
NC 27297
Cummins Atlantic LLC
PO Box 741295
Atlanta, GA 30384-1295
Custom Safety Solutions
(BS&B Safety Sysems, LLC)
7664 West 78th Street
Minneapolis, MN 55439
D A Moore Corporation
PO Box 1150
Concord, NC 28026-1150
DecisionPathHR
8720 Red Oak Boulevard, Suite 300
Charlotte, NC 28217
DGI Supply, A Do All Company
4830 Solution Center
Chicago, IL 60677-4008
Diamond Springs Water Inc.
PO Box 667887
Charlotte, NC 28266
Dienes Corporation
27 West Main Street
Spencer, MA 01562

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Dover Flexo Electronic, Inc.
217 Pickering Road
Rochester, NH 03867
Duke Energy
PO Box 1090
Charlotte, NC 28201-1090
Duke Energy
PO Box 1080
Charlotte, NC 28201-1090
Eclipse Automation Southeast, LLC
2920 Whitehall Park Drive
Charlotte, NC 28273
Edison Welding Institute
Dept L1660
Columbus, OH 43221
EIS Inc.
File 98059
PO Box 98059
Chicago, IL 60693
Emergency Medical Products, Inc.
25196 Network Place
Chicago, IL 60673-1251
Endress + Hauser Inc.
Dept 78795
PO Box 78000
Charlotte, NC 28278
Engineering Search Firm
17-611 Weston Road
Woodbridge Canada
Eri Soots Painting & Trim
11670 Pioneer Mill Road
Midland, NC 28107
Erik Seals and Plastics, Inc.
46704 Fremont Boulevard
Fremont, CA 94538

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Eurotainer SA
5810 Wilson Road, Suite 200
Humble, TX 77396
Ever Bank Commercial Finance, Inc.
PO Box 911608
Denver, CO 80291-1608
Fairborn Equipment Co Inc.
PO Box 123
Upper Sandusky, OH 43351
Fastbolt Corp
200 Louis Street
South Hackensack, NJ 07606
Fastenal Company
PO Box 1286
Winona, MN 55987-1286
Fedex
PO Box 371461
Pittsburgh, PA 15250-7461
Fisher Scientific Company, LLC
PO Box 404705
Atlanta, GA 30384-4705
Flir Commercial Systems, Inc.
9 Townsend West
Nashua, NH 03063
Fluid Flow Products, Inc.
PO Box 751278
Charlotte, NC 28275
Fusite B.V.
Konigweg 167600
Almelo Netherlands
G4S Secure Solutions (USA), Inc.
PO Box 277469
Atlanta, GA 30384-7469

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GDF

Gesellschaft Fur Dichtungstechnik mbH
Hofwiesen-Strasse 7
Brackenheim Germany
GP Rumierz, LLC
4024 Windward Drive
Tega Cay, SC 29708
Grainger
74336 Brackenheim
Palatine, IL 60038
Grant Thornton LLP
1901 S. Meyers Road, Suite 455
Oakbrook Terrace, IL 60181
Graybar Electric Company, Inc.
2500 Wilkinson Boulevard
Charlotte, NC 28208
Grenzebach Corporation
10 Herring Road
Newnan, GA 30265
Harrington Industrial Plastics, LLC
PO Box 638250
Cincinnati, OH 45263
Harris Landscaping & Irrigation, Inc.
4833 Flowes Store Road
Concord, NC 28025
Haz-Mat Enviromental Services, LLC
PO Box 37392
Charlotte, NC 28237
Health Works
PO Box 601428
Charlotte, NC 28260-1428

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Heat Treating Services Unlimited, Inc.
PO Box 1889
Simpsonville, SC 29681
Hellma Usa Inc.
80 Skyline Drive
Plainview, NY 11803
Hendrix Business Systems, Inc.
2040-A Independence Commerce Drive
Matthews, NC 28105
HYG Financial Services Inc.
PO Box 14545
Des Moines, IA 50306-3545
iConnect Technologies
7136 Weddington Road, Suite 104
Concord, NC 28027
IFM Efector Inc.
PO Box 8538-307
Philadelphia, PA 19171-0307
Imerys Graphite & Carbon USA, Inc.
C/O T60092U
PO Box 66512
Chicago, IL 60666-0512
Innovative Machine Corporation
PO Box 9904
Birmingham, AL 35220
Integro Technologies Corp.
301 South Main Street
Salisbury, NC 28144
Interglas Technologies
PF 110389151
Erbach Germany
Internal Revenue Service
PO Box 7346
Philadelphia, PA 19101-7346

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Internal Revenue Service
Office of Chief Counsel
Alamance Building, Mail Stop 24
4905 Koger Boulevard
Greensboro, NC 27407-2734
Jaguar Financial Group c/o Chase
PO Box 78074
Phoenix, AZ 85062-8074
Johnson Controls Inc.
9844 Southern Pines Boulevard, Suite 8
Charlotte, NC 28273
Jonas & Redmann
Kaiserin-Augusta-Allee 113
Berlin Germany
Ketchie, Inc.
201 Winecoff School Road
Concord, NC 28027
Keyence Corporation of America
Dept CH 17128
Palatine, IL 60055-7128
Kumatec Sondermaschinebau &
Kunstoffverarbeitung GmbH
IndustriestraBe 1496524
Neuhaus-Shierschnitz Germany
Lee Spring Company LLC
140 58th Street, Suite 3C
Brooklyn, NY 11220
Legacy Concord Land, LLC
5020 Avent Drive NW
Concord, NC 28027
Let It Shine Cleaning Sv.
3906 Caldwell Ridge Parkway
Charlotte, NC 28213

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Leukert GmbH
Reiftrager Weg 39
Kaufbeuren, 87600
Germany
Liftone LLC
PO Box 602727
Charlotte, NC 28260-2727
Lincoln County Fabricators, Inc.
513 Jason Road
Lincolnton, NC 28092
M+W U.S., Inc.
1001 Klein Road, Suite 400
Plano, TX 75074
M.C. Schroeder Equipment Company Inc.
PO Box 1089
Denver, NC 28037
Marposs Corporation
3300 Cross Creek Parkway
Auburn Hills, MI 48326
McMaster-Carr Supply Company
PO Box 7690
Chicago, IL 60680-7690
McNaughton-McKay Electric Southeast Inc.
PO Box 890976
Charlotte, NC 28289
Mec-Tric Control Company Inc.
4110 Monroe Road
Charlotte, NC 28205
Meier Prozesstechnik GmbH
Vennweg 846395
Bochalt Germany
Metrohm USA, Inc.
6555 Pelican Creek Circle
Riverview, FL 33578

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Microsoft Corporation
1950 N Stemmons Freeway
Suite 5010 LB #842467
Dallas, TX 75207
MIne Safety Appliances Company LLC
PO Box 640348
Pittsburgh, PA 15264
Mistras Services Division
PO Box 405694
Atlanta, GA 30384-5694
Msc Industrial Supply
PO Box 953635
Saint Louis, MO 63195-3635
MSS Fire & Safety, LLC
PO Box 538178
Atlanta, GA 30353
My Townhome LLC
1500 South Boulevard, Suite 101 B
Charlotte, NC 28203
National Vision, Inc.
PO Box 957505
Duluth, GA 30095
NCDENR Div of Wast Management
1646 Mail Service Center
Raleigh, NC 27699
NCDMV
PO Box 29620
Raleigh, NC 27626-0620
NEDEC America Corporation
2251 Nicholas Boulevard
Elk Grove Village, IL 60007
New Electric Charlotte, LLC
1715 Orr Industrial Court
Charlotte, NC 28213

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Nordson EFD LLC
PO Box 777959
Chicago, IL 60677-7009
North Carolina Department of Revenue
Office Services Division
Bankruptcy Unit
PO Box 1168
Raleigh, NC 27602-1168
Nuvation Research Corporation
151 Gibraltar Court
Sunnyvale, CA 94089-1301
Optima Engineering
1927 S Tryon Street, Suite 300
Charlotte, NC 28203
P.C. Godfrey, Inc.
1816 Rozzelles Ferry Rd
Charlotte, NC 28208
Parker Hannifin Corporation
7851 Collection Center Drive
Chicago, IL 60693
Perigon International
13816 E Independence Blvd
Indian Trail, NC 28079
Piedmont Natural Gas Co, Inc.
PO Box 660920
Dallas, TX 75266-0920
Process Technical Sales, Inc.
PO Box 25069
Greenville, SC 29616
Production Engineeering
1344 Woodman Drive
Dayton, OH 45432
Project Integration, Inc.
PO Box 170065
Spartanburg, SC 29301

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PSNC Energy
PO Box 100256
Columbia, SC 29209-3256
Pureflow, Inc.
1241 Jay Lane
Graham, NC 27253
R.L. Kunz, Inc.
PO Box 5875
Greenville, SC 29606
Radio Communications Company
PO Box 68
Cary, NC 27512
Rapid-Rooter Plumbing Service, Inc.
PO Box 562002
Charlotte, NC 28256
Reaction Search International Inc.
5000 Executive Parkway, Suite 450
San Ramon, CA 94583
Recore Electrical Contractors, Inc.
PO Box 1972
Gastonia, NC 28053-1972
Red Dynamics, Inc.
2173 Hawkins Street, Unit E
Charlotte, NC 28203
Rhinehart Fire Services
22 Piney Park Road, Unit G
Asheville, NC 28806
Ryeco, Inc.
810 Pickens Industrial Drive
Marietta, GA 30062
S & D Coffee Inc.
PO Box 1628
Concord, NC 28026-1628

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Saint-Gobain Performance Plastics Corp
PO Box 743699
Atlanta, GA 30374-3699
Schindler Elevator Corporation
PO Box 93050
Chicago, IL 60673
Schlenk
Barnsdorfer HauptsraBe 5
91154 Roth
Germany
Sempa Systems GmbH
GrenzstraBe 131109
Dresden Germany
SFA Fire Protection, Inc.
4809 S Main Street
Salisbury, NC 28147
Sherpa LLC
1001 Morehead Square Drive, Suite 600
Charlotte, NC 28203
SHI International Corp
PO Box 952121
Dallas, TX 75395-2121
Siemens Industry, Inc.
2201 Crownppoint Executive Drive
Bldg 2, Ste K
Charlotte, NC 28227
Solith
Via Fattori 6 40033
Casalecchio di Reno
Italy
Soltex, Inc.
PO Box 204668
Dallas, TX 75320-4668

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Southeastern Freight Lines, Inc.
PO Box 100104
Columbia, SC 29202-3104
Sovema S.P.A.
Via Spagna 13, 37069
Villafranca di Verona VR
Italy
Spiroflow Systems, Inc.
1609 Airport Road
Monroe, NC 28110
Staff Masters
PO Box 19306
Charlotte, NC 28219
Staples
Dept. ATL
PO Box 405386
Atlanta, GA 30384-5386
State Electric Supply Co.
PO Box 890889
Charlotte, NC 28289-0889
Stephen Hall
2308 Coneflower
Charlotte, NC 28213
Stockcap
123 Manufacturers Drive
Arnold, MO 63010
Sunbelt Rentals, Inc.
PO Box 409211
Atlanta, GA 30384-9211
Superb Industries, Inc.
100 Innovation Plaza
Sugarcreek, OH 44681
Superior Service & Supply
PO Box 5753
Concord, NC 28027

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Swagelok North Carolina   East Tennessee
221 Beltway Boulevard
Matthews, NC 28104
Tencarva Machinery Company LLC
PO Box 409897
Atlanta, GA 30384
Terminix Service, Inc.
3612 Fernandia Road
Columbia, SC 29210
The Massey Company, Inc.
9006-A Permiter Woods Drive
Charlotte, NC 28216
Thermotech LLC
1302 S 5th Street
Hopkins, MN 55343
Thompson Construction Group, Inc.
100 N Main Street
Sumter, SC 29150
Time Warner
PO Box 70872
Charlotte, NC 28272-0872
Tongrun International, LLC
3522 Sam Rayburn Highway
Melissa, TX 75454
U.S. Securities & Exchange Commission
Office of Reorganization
950 East Paces Ferry Road, Suite 900
Atlanta, GA 30326-1382
Uline, Inc.
PO Box 88741
Chicago, IL 60680-1741
United States Treasury
1901 Cross Beam Drive
Charlotte, NC 28217

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United Way of Central Carolina's, Inc.
PO Box 890685
Charlotte, NC 28289-0685
Verantis Corporation
7251 Engle Road, Suite 300
Middleburg Heights, OH 44130
Verizon
PO Box 660108
Dallas, TX 75266-0108
Waggoner Manufacturing Co., Inc.
1065 Hall Road
Mount Ulla, NC 28125
Waste Pro of North Carolina, Inc.
PO Box 865505
Orlando, FL 32886-5505
Windstream
PO Box 9001908
Louisville, KY 40290-1950
World International Testing, Inc.
2228 Sunset Boulevard, Suite 1
Steubenville, OH 43952
Wurth Recvar Fasteners, Inc.
3845 Thirlane Road
Roanoke, VA 24019
Yes Energy Management
PO Box 82571
Goleta, CA 93118-2571

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United States Bankruptcy Court
Middle District of North Carolina
In re

ALEVO MANUFACTURING, INC.
Debtor(s)

Case No.
Chapter

11

CORPORATE OWNERSHIP STATEMENT (RULE 7007.1)
Pursuant to Federal Rule of Bankruptcy Procedure 7007.1 and to enable the Judges to evaluate possible disqualification or
recusal, the undersigned counsel for ALEVO MANUFACTURING, INC. in the above captioned action, certifies that the
following is a (are) corporation(s), other than the debtor or a governmental unit, that directly or indirectly own(s) 10% or
more of any class of the corporation's(s') equity interests, or states that there are no entities to report under FRBP 7007.1:
Alevo International SA

 None [Check if applicable]

August 18, 2017

Date

/s/ Terri L. Gardner
Terri L. Gardner 9809

Signature of Attorney or Litigant
Counsel for ALEVO MANUFACTURING, INC.
Nelson Mullins Riley & Scarborough LLP
4140 Parklake Avenue, Suite 200
Raleigh, NC 27612
(919) 329-3800 Fax:(919) 329-3799
terri.gardner@nelsonmullins.com

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