The United States of America, by its undersigned attorneys, brings this Complaint for Forfeiture in Rem and alleges as follows in accordance with Rule G(2) of the Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions (the "Supplemental Rules").

NATURE OF THE ACTION

1. The plaintiff is the United States of America.
2. The defendants in this action (the "Defendant Res') are funds in the amount of approximately 73,293,750 AED (the "Defendant Funds") in the custody of the Ras Al Khaimah Investment Authority ("RAKIA") in the United Arab Emirates ("UAE") as well as a legal claim (the "Defendant Claim") for the Defendant Funds filed and asserted by VI2 Partners GmbH ("VI2") in VI2 Partners GmbH v. Ras Al Khaimah Investment Authority Georgia LLC (Case No. 2b/4319-17), which is currently pending before the Tbilisi Court of Appeals in the Republic of Georgia (the "Georgia Action"). The Defendant Funds were deposited by VI2's predecessors in interest while seeking to purchase a hotel in Tbilisi, Georgia, from its owner, the Ras Al Khaimah Investment Authority Georgia LLC. The Georgia Action was filed by VI2 on or about February 19, 2016, seeking a return of the Defendant Funds and damages when the purchase of the hotel did not occur.

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