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Amended pursuant to Supreme Court Civil Rule 6-1(a) Original Notice of Civil Claim filed on March 14, 2019 SUPREME COURT No. $194992 OF BRITISH COLUMBIA | Vancouver Registry VANCOUVER REGISTRY 28 201 MAY {THE SUPREME COURT OF BRITISH COLUMBIA By Civil Forfeiture Action in Rem Against The L \d Structured situated at #TH22 - 1281 Cordova Street West, Vancouver, British Cohimbi a legal description of parcel identifier 026-130-581 Strata Lot 12 of the Public Harbour of Burrard Inlet New Westminster District Strata Plan BCS1073 together with an interest in the common property in proportion to the unit entitlement of the strata lot as shown on Form V (the “Real Property”), a 2017 Land Rover Range Rover with Vehicle Identification Number SALGW3FESHA366813, a 2018 Land Rover Range Rover with Vehicle Identification Number SALWZ2SE3JA 192099 (collectively, the “Vehicles”) and any funds notionally held by the Bank of Montreal, in particular account numbers 4642127 and 3716674, by Kevin Patrick Hobbs (the “Bank Funds”) and their fruits and proceeds Between Director of Civil Forfeiture Plaintiff and ‘The Owners and all Others Interested in the Real Property, the Vehicles, and the Bank Funds, in Particular, Kevin Patrick Hobbs and Lisa Angela Cheng Defendants AMENDED NOTICE OF CIVIL CLAIM ~ CLAIM FORFEITURE (IN REM) Name and address of each plaintiff: Director of Civil Forfeiture cht Ministty of Asioniey Genstah-besel Sepees Beach Meteria BC VEW SIF Vie- Bax 250) 387-4002 c/o Gudmundseth Mickelson 2525-1075 W. Georgia St mcouver, BC V6E 3C9 Description of property: The Lands and Structures situated at #TH22 - 1281 Cordova Street West, Vancouver, British Columbia, and having a legal description of parcel identifier 026-130-581 Strata Lot 12 of the Public Harbour of Burrard Inlet New Westminster District Strata Plan 90¢729-0030/00273981 -2- BCS1073 together with an interest in the common property in proportion to the unit entitlement of the strata lot as shown on Form V (the "Real Property"), a 2017 Land Rover Range Rover with Vehicle Identification Number SALGW3FESHA366813, a 2018 Land Rover Range Rover with Vehicle Identification Number SALWZ2SE3JA192099 (collectively, the "Vehicles") and any funds notionally held by the Bank of Montreal, in particular account numbers 4642127 and 3716674, by Kevin Patrick Hobbs (the "Bank Funds") and their fruits and proceeds. To the defendants: TAKE NOTICE that this action has been started against you by the plaintiff for the claims set out in this notice of civil claim. IF YOU INTEND TO RESPOND 10 this action, or if you have a set-off or counterclaim that you wish to have taken into account at the trial, YOU MUST FILE a response to civil claim in Form 2 in the above registry of this court within 21 days after being served with a copy of the filed notice of civil claim and SERVE a copy of the filed response to civil claim on the plaintiffs address for service. YOU OR YOUR LAWYER may file the response to civil claim, APPLICATION FOR JUDGMENT AGAINST THE REAL PROPERTY, THE VEHICLES AND THE BANK FUNDS MAY BE MADE IF YOU FAIL to file the response to civil claim within 21 days after being served with a copy of the filed notice of civil claim. CLAIM OF THE PLAINTIFF Part 1: STATEMENT OF FACTS ‘The Defendants. Vehicles, and Bank Funds 1. The defendant, Kevin Patrick Hobbs ("Mr Hobbs"), whose occupation is unknown to the plaintiff, has a last known address at #TH22 - 1281 West Cordova Street, Vancouver, British Columbia, which has a legal description of 026-130-581 Strata Lot 12 of the Public. Harbour of Burrard Inlet New Westminster District Strata Plan BCS1073 together with an interest in the common property in proportion to the unit entitlement of the strata lot as, shown on Form V (the "Real Property"). 2. The defendant, Lisa Angela Cheng (Ms. Cheng"), whose occupation is unknown to the plaintiff, has a last known address at the Real Property. 3. Onor about December 8, 2017, Mr. Hobbs and Ms. Cheng became the registered owners in fee simple of the Real Property. Mr. Hobbs and Ms. Cheng purchased the Real Property for $4.1 Million in cash. 4. Charles Funaro and Gion Muoio Holdings Inc. (the "Mortgagees") currently hold a mortgage and assignment of rents which were registered against the Real Property on December 20, 2018, under charge numbers CA7285930 and CA7285931 004728-0030/00273481 5. The vehicles are: a. a 2017 Land Rover Range Rover with Vehicle Identification Number SALGW3FESHA366813 (the "2017 Range Rover); and b. 2018 Land Rover Range Rover with Vehicle Identification Number SALWZ2SE3JA192099 (the "2018 Range Rover"). (collectively, the "Vehicles") 6. Onorabout February 16, 2018, Mr. Hobbs became the registered owner of the 2017 Range Rover. On or about April 21, 2018, Mr. Hobbs became the registered owner of the 2018 Range Rover. 7. Barlston Mortgage Corp. has a lien registered against the 2017 Range Rover on February 25, 2019, under registration number 334677L. 8 The bank funds are funds held in any accounts with the Bank of Montreal ("BMO") at 595 Burrard Street, PO Box 49500, Bentall Centre Stn., Vancouver, BC, in particular account numbers 4642127 and 3716674 by Mr. Hobbs, and their proceeds (the "Bank Funds"). Etherparty, Vanbex and FUEL Tokens 9. Vanbex Group Inc. is a company formed in 2014 under the Canada Business Corporations Act and extra-provincially registered pursuant to the laws of British Columbia on July 13, 2016 (""Vanbex"), 10, —_Etherparty Smart Contracts Inc. is a company incorporated pursuant to the laws of British Columbia on July 19, 2017 ("Etherparty"), 11, Mr. Hobbs.and Ms. Cheng are the sole directors and operating minds of Vanbex, the parent company of Etherparty, and various other related companies. 12, Beginning in 2017, Mr. Hobbs and Ms. Cheng represented to the public that they operated a Vancouver-based cryptocurrency firm, The firm was interchangeably called Vanbex and Etherparty. In actual fact, Vanbex and its subsidiaries are were shell companies which ‘had in that they only ever had two clients and developed no useable products. 13, In or about 2017, Vanbex launched a cryptocurrency coin called the FUEL token and solicited funds from investors in the development and distribution of the FUEL token. 14, Among other things, Vanbex represented to potential investors that: a, the FUEL token would be capable of being used in the company's forthcoming "smart contract" system, Etherparty; and b. the value of the FUEL token would increase dramatically. 004728-0030/00273481