COMES NOW, Plaintiff the United States of America (the “United States”), by and through the Acting United States Attorney for the District of Columbia, which alleges as follows and brings this verified complaint for forfeiture in a civil action in rem against the Defendant Properties (defined and displayed below), namely:

• 171 “Dehlavieh” anti-tank guided missiles (“Defendant Property 1”)
• Eight type “358” surface-to-air missiles (“Defendant Property 2”)
• Ten Rayan Roshd Afzar RU60G thermal weapons optics (“Defendant Property 3”)
• One USV KIT GM2 35-1, which includes: two optics, one gear box controller, one USV control panel, one hydraulic control, one antenna adaptor AMP FK-2, one USV 10 panel, three 3 outlet connectors (bronze), and one mounting hardware kit (“Defendant Property 4”)

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