Case 1:18-cr-00693-RMB Document 172 Filed 12/19/19 Page 1 of 3

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------UNITED STATES OF AMERICA
- v. RICHARD GAFFEY,
a/k/a “Dick Gaffey,” and
HARALD JOACHIM VON DER GOLTZ
a/k/a “H.J. von der Goltz,”
a/k/a “Johan von der Goltz,”
a/k/a “Jochen von der Goltz,”
a/k/a “Tica,”
a/k/a “Tika,”
Defendants.
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GOVERNMENT’S FORFEITURE
BILL OF PARTICULARS
S6 18 Cr. 693 (RMB)

Pursuant to United States v. Grammatikos, 633 F.2d 1013, 1024 (2d Cir. 1980), the
Government respectfully gives notice that the property subject to forfeiture as a result of the
offenses alleged in Counts Two and Three of the Indictment, as alleged in the Forfeiture
Allegations and/or the Substitute Assets Provision in the Indictment, includes but is not limited to
the following:
a) Any and all assets, wherever they may be located, held in the name of Revack
Holdings Foundation;
b) Any and all assets, wherever they may be located, held in the name of EMJO
Investments Limited, including but not limited to:
i. Any and all funds formerly on deposit in First Republic Bank
Account Number 966-0070-3479, held in the name of EMJO
Investments Limited;
ii. Any and all funds formerly on deposit in First Republic Bank
Account Number 50019044473, held in the name of EMJO
Investments Limited;

 Case 1:18-cr-00693-RMB Document 172 Filed 12/19/19 Page 2 of 3

iii. Any and all funds formerly on deposit in First Republic Bank
Account Number 50019047005, held in the name of EMJO
Investments Limited;
iv. Any and all funds or assets held in investment accounts by
Brooke Private Equity Associates and any funds administered
by or associated with Brooke Private Equity Associates in the
name of EMJO Investments, Ltd.;
c) Any and all assets, wherever they may be located, held in the name of Union
Properties Inc., including but not limited to:
i. Any and all funds formerly on deposit in Credit Suisse Bank
Account Number 2G5-002657, held in the name of Union
Properties, Inc.;
d) Any and all assets, wherever they may be located, held in the name of
Worldwide Investment Services and Holdings, Ltd.;
e) Any and all funds on deposit in First Republic Bank Account Number ending
in 0098, held in the names of Harald Joachim Von Der Goltz and Belle Von
Der Goltz;
f) Any and all funds on deposit in First Republic Bank Account Number ending
in 0534, held in the names of Harald Joachim Von Der Goltz and Belle Von
Der Goltz;
g) All that lot or parcel of land, together with its building, appurtenances,
improvements, fixtures, attachments and easements, located at 590 Charles
River Street, Needham, Massachusetts 02492, held in the name of Robert K.
Hamshaw, Wolfgang Traber, and Richard Gaffey, as Trustees of the Harald
Joachim Von Der Goltz Children’s Trust;
h) All that lot or parcel of land, together with its building, appurtenances,
improvements, fixtures, attachments and easements, located at 177 Ocean
Lane Drive, Key Biscayne, Florida 33149, held in the name of Robert K.
Hamshaw, Wolfgang Traber, and Richard Gaffey, as Trustees of the Harald
Joachim Von Der Goltz Children’s Trust; and
i) The painting known as “Regates a Henley,” by the artist Raoul Dufy.

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 Case 1:18-cr-00693-RMB Document 172 Filed 12/19/19 Page 3 of 3

Dated: New York, New York
December 19, 2019
Respectfully Submitted,
GEOFFREY S. BERMAN
United States Attorney for the
Southern District of New York
DEBORAH CONNOR
Chief, Money Laundering and
Asset Recovery Section
Criminal Division
By: ____________________________
Eun Young Choi/Thane Rehn
Assistant United States Attorneys
(212) 637-2187/2354
Michael Parker/Parker Tobin
Trial Attorneys, Criminal Division
(202) 514-0421/305-3903

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