IN THE CIRCUIT COURT OF INDEPENDENCE COUNTY, ARKANSAS
LUNDEN ALEXIS ROBERTS PLAINTIFF
vs. Case No: 32DR-19-187
ROBERT HUNTER BIDEN DEFENDANT | 2D DIV I
NOTH AND COUNTERFEITIN'
AND PRODUCTION OF EVIDENCE
COMES NOW the Intervener in this case in support of Plaintiff with this subject Notice,
relative to Defendants failure to answer reasonable discovery requests.
1. Plaintiffs’ attorney Lancaster & Lancaster Law Firm, PLLC. moved this Honorable Court to
compel the DEFENDANT to answer basic discovery questions. Refer to PLAINTIFF's Motion to
Compel submitted on 18 December 2019 to this Honorable Court.
2. The Intervener (AGENCY) has been actively investigating the DEFENDANT, his partners,
associates and business dealings since 8 August 2016.
3, DEFENDANT is the subject of more than one (1) criminal investigation involving fraud,
money laundering and a counterfeiting scheme.
4, On 28 June 2018, DEFENDANT’ partners:
john Galanis a/k/a Yanni, Tvevon Archer and
Bevan Cooney were convicted in the Southern District of New York (SDNY) for the Fraudulent
Issuance and Sale of More Than $60 Million of Tribal Bonds scheme (SCHEME).
5, Witnesses and CO-DEFENDANT's provided evidence showing the DEF! ENDANT Robert
Hunter Biden's association and he did drum up business for the SCHEME.
6. DEFENDANT Robert Hunter Biden, Devon Archer and Christopher Hein: are named
directors of Rosemont Seneca Bohai, LLC, (Delaware 2014 File No. 5482769) a/k/a RSB, LLC. a/k/a
RS Bais, LLC. (Delaware 2001 File No. 3434766) located in the offices of the Hexnz family.
‘The address for these companies, their bank and financial accounts is:
152 W. S7th Street
47th Floor
New York, NY 10019
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onrcval~
D&A investigations, Inc.Rosemont Seneca Bohai, LLC. a/k/a RSB, LLC. a/k/a RS Bais, LLC. corporations were
registered by family members of DEFENDANT Robert Hunter Biden, Devon Archer and
Christopher Heinz who became directors to conceal theit family members ownership.
8, They established bank and financial accounts with Morgan Stanley et al for Rosemont Seneca
Bohai, LLC. a/k/a RSB, LLC. a/k/a RS Bais; LLC. for Burisma Holdings Limited (Limassol,
Cyprus) and China Bank (Makati, Philippines) for the money laundering scherre.
9. Beginning in March 2014 through December 2014, they used the name Rosertont Seneca
Bohai, LLC. In January 2015 through December 2016, they used the name RSB, LLC. with anew
account number. Both accounts are