ESTATE OF JEREMY ISADORE LEVIN et al v. WELLS FARGO BANK, N.A.

1
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ESTATE OF JEREMY ISADORE LEVIN,
et al.,
Plaintiffs,
v.
WELLS FARGO BANK, N.A.,
Defendant.
(And consolidated cases)
Civil Action No. 21-420 (JEB)
MEMORANDUM OPINION
After intercepting almost $10 million headed to a company that was a front for members
of the Iranian Revolutionary Guard Corps, the United States filed a civil-forfeiture action against
the funds in this Court and sought custody of them. News coverage of the venture prompted
other parties, including victims of terrorist attacks who hold judgments against Iran, to seek to
attach the funds. After protracted litigation over those writs of attachment, including two trips to
the D.C. Circuit, the Court faces a complex set of motions seeking to winnow and prioritize the
claimants to the funds and to transfer this action to the District of South Dakota, where the funds
are currently housed. The Court will decline to quash the Victim-Plaintiffs’ writs and will retain
its exclusive jurisdiction over these proceedings. It will, however, grant the Government’s
Motion to Deposit Funds in this Court’s registry for ease of maintenance and disposition for the
remainder of the litigation.
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 1 of 25

2
I. 	Background
The events giving rise to this case, and its subsequent five-year history, involve multiple
players and myriad legal maneuvers by the various parties. The Court, mindful of the four prior
Opinions that detail that factual and procedural history, focuses on the facts relevant to the
pending Motions before it.
A. 	Interception of Funds
In 2019, Crystal Holdings Limited and Taif Mining Services, LLC, entered a contract for
the sale and purchase of an oil tanker for more than $12 million. Est. of Levin v. Wells Fargo
Bank, N.A., 45 F.4th 416, 417–18 (D.C. Cir. 2022). Crystal Holdings — the seller — is a
Liberian subsidiary of a Greek company. Id. at 417. The buyer, Taif, is incorporated in Oman.
Id. After successfully transferring a $2.34 million deposit to Crystal Holdings’ Credit Suisse
account, Taif sought to transfer the $9.98 million balance needed to complete the sale. Id. at
418. It first wired that sum to the Holman Fenwick law firm (HFW), which then deposited the
$9.98 million in an account at a London bank. Id. HFW initiated the transfer between the
London bank account and Crystal Holdings’ account, which required a bridge transfer through an
intermediary — Wells Fargo bank in New York. Id.; see also Heiser v. Islamic Republic of Iran,
735 F.3d 934, 936 (D.C. Cir. 2013) (describing intermediary fund-transfer process). At that step,
however, the companies encountered rough seas.
Unbeknownst to Crystal Holdings, Taif is not solely an Omani company engaged in
nautical commerce; it is wholly owned by two members of the Iranian Revolutionary Guard
Corps. Est. of Levin, 45 F.4th at 417. IRGC members are among the persons barred from
owning or transacting assets within the United States, by virtue of their inclusion on the
Specially Designated Nationals and Blocked Persons List that the United States Department of
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 2 of 25

3
the Treasury’s Office of Foreign Assets Control maintains. See 31 C.F.R. § 594.201(a)(5).
When the $9.98 million transfer hit Wells Fargo’s account, OFAC immediately blocked its
further movement pursuant to 50 U.S.C. § 1702. Est. of Levin, 45 F.4th at 418. The money
destined for purchase of the boat was thus frozen in the United States, and it was not transferred
to Crystal Holdings’ account. Id. Wells Fargo then moved those funds from its account in New
York to an account in South Dakota, its headquarters location. Id.; Fed. Deposit Ins. Comm’n,
Wells Fargo Bank, National Association (Mar. 6, 2026), https://perma.cc/7F5F-YK8L. Unaware
of the fund-transfer hiccup, Crystal Holdings delivered the tanker to Taif. United States v.
$2,340,000.00 Associated with Petroleum Tanker Nautic, No. 20-1139 (D.D.C. May 1, 2020),
ECF No. 1 (Civil Forfeit. Compl.), ¶¶ 39, 42.
On May 1, 2020, the United States filed a forfeiture action for the Blocked Funds in this
Court. Id. at 1. This Court issued an arrest warrant for the Blocked Funds in rem on the same
day. See $2,340,000.00 Associated with Petroleum Tanker Nautic, No. 20-1139, ECF No. 3
(Arrest Warrant). The Government then obtained an OFAC license permitting it and Wells
Fargo to “engage in all transactions necessary . . . [to] allow any duly authorized federal law
enforcement officer to take possession and custody of the Funds,” so long as the Government
received a “valid forfeiture order” from this Court. Owens v. Wells Fargo Bank, N.A., No. 21-
126 (D.D.C. Aug. 17, 2020), ECF No. 4-2, Exh. J (OFAC License) at 2. As new claimants to the
Blocked Funds emerged, however, it asked the Court to stay the underlying forfeiture action until
the validity of those claims was resolved. Levin v. Islamic Republic of Iran, 523 F. Supp. 3d 14,
18 (D.D.C. 2021). This the Court has done. See ECF No. 51 (Joint Schedule Ord.) at 2.
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 3 of 25

4
B. 	Victim-Plaintiffs
The Government, it turns out, has not cornered the market in confiscated Iranian assets.
Over the years, certain victims of Iranian-sponsored terrorist attacks have brought claims under
the Foreign Sovereign Immunities Act and obtained final judgments against Iran. See, e.g.,
Belkin v. Islamic Republic of Iran, 667 F. Supp. 2d 8, 24 (D.D.C. 2009) (awarding over $10
million in damages); Rezaian v. Islamic Republic of Iran, 422 F. Supp. 3d 164, 184 (D.D.C.
2019) (awarding approximately $180 million judgment against Iran). Congress, in turn, has
authorized holders of such judgments to attach “the blocked assets of [the] terrorist party . . . in
order to satisfy” those judgments. See Terrorism Risk Insurance Act of 2002 § 201(a), codified
at 28 U.S.C. § 1610 note. Relevant here, two sets of Plaintiffs seek to recover part of their
judgments from the Blocked Funds.
The Owens Plaintiffs are a group of individuals (and their family members) who were
injured and killed by al Qaeda’s bombings of U.S. embassies in 1998. Levin, 523 F. Supp. 3d at
15. Because Judge John Bates of this district found Iran had provided material support to al
Qaeda before those attacks, the Owens Plaintiffs obtained various judgments against Iran totaling
nearly $1 billion in 2014. Id.; Owens v. Republic of Sudan, No. 01-2244 (D.D.C. Mar. 28,
2014), ECF No. 301 (Judgment); Mwila v. Islamic Republic of Iran, No. 08-1377 (D.D.C. Mar.
28, 2014), ECF No. 88 (Judgment); Khaliq v. Republic of Sudan, No. 10-356 (D.D.C. Mar. 28,
2014), ECF No. 40 (Judgment). Those judgments have not been satisfied. See No. 01-2244,
ECF No. 450-2 (Writ Memo).
The Levin Plaintiffs are a smaller group comprising the estate and family members of
Jeremy Levin, who was kidnapped and tortured by Hezbollah, another Iran-supported terrorist
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 4 of 25

5
group, in 1984. Levin, 523 F. Supp. 3d at 15. The Levin Plaintiffs have also obtained a
judgment for their claims, of which over $15 million remains outstanding. Id.
Several weeks after the Government filed its forfeiture action against the Blocked Funds,
the Owens Plaintiffs learned of the action through public news reporting and moved for writs of
attachment under the Terrorism Risk Insurance Act against the Funds in this district in May
2020. Id. at 18; Owens, No. 01-2244, ECF No. 450 (Owens Mot. for Writ). The Levin Plaintiffs
took a different approach. First, they filed an application for a writ of execution against the
Blocked Funds in the Southern District of New York on August 11, 2020. Levin v. Bank of
N.Y., No. 09-5900 (S.D.N.Y. Aug. 11, 2020), ECF No. 1309 (Levin App. Writ SDNY). That
court granted the writ, but “its effect is essentially stayed” because of a joint stipulation between
those Plaintiffs and the Government. Levin, 523 F. Supp. 3d at 19. Separately, on August 19,
2020, the Levin Plaintiffs sought a writ of attachment in this district. Levin v. Islamic Republic
of Iran, No. 05-2494 (D.D.C. Aug. 19, 2020), ECF No. 34 (Levin Mot. Writ DDC). Finally, they
sought and obtained a writ of execution in the District of South Dakota. Levin v. Islamic
Republic of Iran, No. 20-mc-35, ECF No. 12 (D.S.D. Dec. 31, 2020).
The Government intervened in both the Owens Plaintiffs’ and the Levin Plaintiffs’
actions in this district and moved for reassignment to this Court to “consolidate all funds-related
litigation before one judge.” Levin, 523 F. Supp. 3d at 18. The presiding judge in each case
granted the Government’s respective motions and transferred the writ proceedings to this Court.
Id.
C. 	Prior Litigation
Once before this Court, the Government moved to quash both sets of Plaintiffs’ writs of
attachment, raising identical arguments in each. Id. This Court granted the Government’s
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 5 of 25

6
motions, noting that Article 4A of the Uniform Commercial Code sets forth the general rule that
“the only entity with a property interest in an EFT [electronic funds transfer] while it is
midstream is the entity immediately preceding the bank ‘holding’ the EFT in the transaction
chain” — that is, Taif’s bank, not Taif itself. Id. at 21 (quoting Calderon-Cardona v. Bank of
N.Y. Mellon, 770 F.3d 993, 1002 (2d Cir. 2014)). It thus reasoned that the Blocked Funds were
neither “blocked assets” of Iran under the TRIA, nor “the property” of Iran under the FSIA, so
the Owens and Levin Plaintiffs had no basis for attaching the Funds under either Act. Id. at 20,
24.
The D.C. Circuit reversed. It held that U.C.C. Article 4A is “inapplicable” to determine
the ownership of funds blocked pursuant to OFAC regulations. Est. of Levin, 45 F.4th at 423. It
further held that because the Blocked Funds “are traceable to Taif and thus to Iran,” they are “the
blocked assets of a terrorist party” under the TRIA. Id. at 423–24 (quotation marks and
alterations removed). It then remanded to this Court for further proceedings. Id. at 424.
On remand, the Government renewed its Motions to Quash the writs of both sets of
Plaintiffs. See ECF Nos. 24 (Second Mot. Quash Owens); 25 (Second Mot. Quash Levin).
Again this Court granted the Government’s motions, holding that Plaintiffs’ claim to the Blocked
Funds was deficient in numerous ways. See generally Est. of Levin v. Wells Fargo Bank, N.A.,
2023 WL 3750577 (D.D.C. June 1, 2023). Relevant here, it held that: 1) the funds were not
“blocked assets” within the TRIA because they were not “frozen” after the Government obtained
an OFAC license that would permit transfer of the funds in certain circumstances; and 2) the
prior-exclusive-jurisdiction doctrine barred Plaintiffs’ separate writ actions from proceeding after
the Government had filed its civil-forfeiture action. Id. at *5, *8.
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 6 of 25

7
The D.C. Circuit once again reversed and remanded. It first held that the Blocked Funds
“meet all the elements of th[e] statutory definition” of a “blocked asset” under the TRIA. Est. of
Levin v. Wells Fargo Bank, N.A., 156 F.4th 632, 642 (D.C. Cir. 2025). The Circuit also held
that the prior-exclusive-jurisdiction doctrine bars simultaneous in rem proceedings in courts of
different jurisdictions (e.g., federal and state courts, or two federal courts in separate districts),
but does not apply to proceedings in two courts within the same district. Id. at 642–43.
D. 	Current Motions
On remand once more, the same characters seeking possession of the Blocked Funds
attempt various procedural gambits to vindicate their claims. The Levin Plaintiffs seek to
transfer the action to the District of South Dakota, where the account holding the Blocked Funds
is located. See ECF No. 47 (Levin Mot. Transfer). The Government, for its part, does not move
to quash Plaintiffs’ writs a third time; instead, it moves to deposit the Blocked Funds in the
Court’s registry until their final disposition is adjudicated. See ECF No. 57 (Mot. Deposit
Funds). The Levin Plaintiffs also move to quash the Owens Plaintiffs’ writ of attachment. See
Levin Mot. Transfer. The Owens Plaintiffs, in turn, cross-move to quash the Levin Plaintiffs’
writ. See ECF No. 55 (Owens Mot. Quash). Crystal Holdings — the boat seller and intended
recipient of the Blocked Funds’ transfer — moves to quash both the Levin and Owens Plaintiffs’
writs of attachment, asserting that “title to [the Blocked Funds] transferred to Crystal upon
escrow closing.” ECF No. 43 (Crystal Mot. Quash) at 1.
The Court now attempts to untangle this Gordian knot.
II. 	Legal Standard
Title 28 U.S.C. § 1404(a) permits district courts to “transfer any civil action to any other
district . . . where it might have been brought” if such transfer would serve “the interest of
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 7 of 25

8
justice.” The movant “must first show that the plaintiff could originally have brought the case in
the transferee district.” Ngonga v. Sessions, 318 F. Supp. 3d 270, 274 (D.D.C. 2018) (quoting
Douglas v. Chariots for Hire, 918 F. Supp. 2d 24, 31 (D.D.C. 2013)). When considering whether
to transfer a case to a valid transferee forum, “courts should balance case-specific factors which
include the private interests of the parties and public interests such as efficiency and fairness.”
Greater Yellowstone Coal. v. Bosworth, 180 F. Supp. 2d 124, 127 (D.D.C. 2001).
As it has in its prior Opinions in this case, see Levin, 523 F. Supp. 3d at 19; Est. of Levin,
2023 WL 3750577, at *4, this Court again acknowledges that is has “inherent power to
reconsider an interlocutory order as justice requires.” Capitol Sprinkler Inspection, Inc. v. Guest
Servs., Inc., 630 F.3d 217, 227 (D.C. Cir. 2011) (formatting modified); see Fed. R. Civ. P. 54(b).
District courts “retain broad discretion” to reconsider earlier interlocutory orders and may grant
such reconsideration on a number of grounds, including the existence of new arguments or
information that “might reasonably be expected to alter the conclusion reached by the court.”
Cobell v. Norton, 355 F. Supp. 2d 531, 539–40 (D.D.C. 2005) (formatting modified and
quotation omitted). Courts routinely evaluate the validity of writs of attachment de novo when
faced with motions to quash. See, e.g., Bennett v. Islamic Republic of Iran, 618 F.3d 19, 21
(D.C. Cir. 2010) (affirming district court’s order granting motion to quash writs of attachment,
holding that “[w]hether the properties are subject to attachment is a question of law that we
review de novo”) (citation omitted); Stern v. Islamic Republic of Iran, 73 F. Supp. 3d 46, 48–50
(D.D.C. 2014) (granting motion to quash writs of attachment).
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 8 of 25

9
III. 	Analysis
The Court begins with the Levin Plaintiffs’ Motion to Transfer the case to South Dakota.
Rejecting that plan, it next considers the Government’s Motion to Deposit Funds and concludes
with the Plaintiffs’ competing Motions to Quash.
A. 	Motion to Transfer
In order to successfully obtain transfer, the Levin Plaintiffs must first satisfy the
requirement that their case “might have been brought” in the District of South Dakota. See 28
U.S.C. § 1404(a). That requirement is assessed at the time of filing. Relf v. Gasch, 511 F.2d
804, 807 (D.C. Cir. 1975). They falter at this step.
These Plaintiffs do not dispute that this Court had jurisdiction over the Government’s
initial civil-forfeiture action against the Blocked Funds. See Levin Mot. Transfer at 13 (“The
Levins are mindful that this Court has jurisdiction over this matter as the Government filed the
civil forfeiture action in this Court first.”). Nor could they: 28 U.S.C. § 1355(a) gives district
courts jurisdiction over “any action . . . for the recovery or enforcement of any . . . forfeiture.”
And venue is undeniably proper because OFAC — the entity responsible for blocking funds
from entities on the Blocked Persons list — is located in D.C. Id. § 1355(b)(1)(A) (venue is
proper in districts where “acts or omissions giving rise to the forfeiture occurred”).
This Court’s initial exercise of jurisdiction over the civil-forfeiture action thus barred any
other courts from exercising jurisdiction over the Blocked Funds under the prior-exclusive-
jurisdiction rule. Applicable to in rem actions, that rule provides that “when a state or federal
court of competent jurisdiction has obtained possession, custody, or control of particular
property, that authority and power over the property may not be disturbed by any other court.”
13F Wright & Miller’s Federal Practice & Procedure § 3631 (3d ed. 2025); see Princess Lida of
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 9 of 25

10
Thurn & Taxis v. Thompson, 305 U.S. 456, 466 (1939). The rule exists to “prevent
jurisdictional conflicts” implicated when multiple courts seek to dispose of a res in different
ways. Est. of Levin, 156 F.4th at 642. The rule is so strong that “the first court to assume
jurisdiction over the res may even enjoin proceedings in the second” if such action would
“safeguard the integrity of its orders.” United States v. $79,123.49 in U.S. Cash & Currency,
830 F.2d 94, 97 n.3 (7th Cir. 1987).
The conclusion inescapably follows that neither the Levin Plaintiffs nor any other party
could have brought an action asserting a claim to the Blocked Funds in the District of South
Dakota, the proposed transferee district — or anywhere else for that matter. When no court
within the transferee district would have had jurisdiction at the time of the Complaint’s filing, the
movant cannot satisfy § 1404(a). Cf. Sunbelt Corp. v. Noble, Denton & Assocs., Inc., 5 F.3d 28,
33 (3d Cir. 1993) (transfer prohibited when transferee court lacked personal jurisdiction over
party).
The Levin Plaintiffs disagree. They contend that “the first to file rule is not a rigid rule to
be applied automatically.” ECF No. 59 (Levin Reply to Gov.) at 22. The cases they cite,
however, are not in rem proceedings. Id. (citing, e.g., Columbia Plaza Corp. v. Sec. Nat’l Bank,
525 F.2d 620 (D.C. Cir. 1975) (action for injunctive relief and damages stemming from disputed
construction loan); Coal River Mountain Watch v. U.S. Dep’t of the Interior, 146 F. Supp. 3d 17,
23 (D.D.C. 2015) (concerning “parallel [APA] actions in federal court”)).
The Levin Plaintiffs have confused the “first-to-file” principle, which guides the
consolidation of parallel federal actions, with the prior-exclusive-jurisdiction rule, which
prevents competing adjudications of the same res. The first theory offers a presumption when
two district courts preside over simultaneous actions brought in personam concerning related
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 10 of 25

11
subject matter. While permissible, such arrangement is often undesirable, and the Federal Rules
of Civil Procedure and precedent promote consolidation of the actions or dismissal of the
duplicative one where possible. See, e.g., Fed. R. Civ. P. 13(a) (requiring counterclaims be
brought in originally filed case); Wash. Metro. Area Transit Auth. v. Ragonese, 617 F.2d 828,
830 (D.C. Cir. 1980) (“Considerations of comity and orderly administration of justice dictate that
two courts of equal authority should not hear the same case simultaneously.”). In those
circumstances, district courts favor the first-filed suit as a “general rule.” Columbia Plaza, 525
F.2d at 627. “Although it is referred to as the ‘first-filed rule,’ it is instead an equitable
doctrine.” Sandra L. Potter, The First-Filed ‘Rule’ and Moving to Dismiss Duplicative Federal
Litigation, 33 Rev. Litig. 603, 614 (2014). The rule is meant to avoid the efficiency and equity
concerns inherent in permitting a later-filed action to go forward over its initially filed
counterpart. See Semmes Motors, Inc. v. Ford Motor Co., 429 F.2d 1197, 1203 (2d Cir. 1970)
(describing risk of forum manipulation and “heavy price” exacted should later-filed action
prevail). Specific circumstances can nonetheless shift the balance of equities and overcome the
default preference for the first-filed case. For example, where the location of witnesses,
inclusion of relevant parties, and extent of prior litigation all favor the later-filed action, that
action may prevail. Columbia Plaza Corp., 525 F.2d at 628. The first-filed rule in dueling in
personam actions is thus a preference, not a jurisdictional mandate.
An in rem action is a wholly different animal. When a district court exercises jurisdiction
over a piece of property, it precludes other courts from exercising concurrent jurisdiction over
that res. Princess Lida, 305 U.S. at 466 (if “two suits are in rem, or quasi in rem, . . . the
jurisdiction of the one court must yield to that of the other”). The prohibition is not simply a
matter of comity between courts: it shields the res from conflicting dispositions and prevents
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 11 of 25

12
undermining the original court’s orders. Kline v. Burke Constr. Co., 260 U.S. 226, 232 (1922)
(concurrent jurisdiction over same res would “lead to a conflict of authority where each court
acts in accordance with law”) (quotation marks omitted). The D.C. Circuit previously held in
this case that “[n]o such conflicts arise when multiple suits are filed in the same court.” Est. of
Levin, 156 F.4th at 643 (reversing this Court’s holding that prior-exclusive-jurisdiction doctrine
barred Plaintiffs’ writs in this district after Government filed civil-forfeiture action). But the
doctrine applies with full force to bar any other courts from exercising jurisdiction over the
Blocked Funds once this Court assumed jurisdiction.
The Government’s civil-forfeiture action and the Levin and Owens Plaintiffs’ writs of
attachment are “three competing in rem actions filed against the same property.” Est. of Levin,
156 F.4th at 642. They must be resolved in one court — namely, the first court properly
exercising jurisdiction over the Blocked Funds. That court, as it has been for the five years since
this group of actions first commenced, is this one.
The Levin Plaintiffs gesture at an argument that the Court should dismiss the underlying
civil-forfeiture action because the Victim-Plaintiffs’ claims to the Blocked Funds overwhelm the
Funds’ balance, leaving nothing for the Government to ultimately obtain. See Levin Reply to
Gov. at 24–25. Such dismissal, they contend, would free this Court from the dictates of the
prior-exclusive-jurisdiction doctrine and throw open the transfer portal to South Dakota. Id. at
25. Setting aside the Levin Plaintiffs’ apparent reversal on Reply, see Levin Mot. Transfer at 13
(conceding Court “has jurisdiction over this matter as the Government filed the civil forfeiture
action in this Court first”), this position fails on two fronts. First, the transferee court’s
jurisdiction is assessed at the time a plaintiff files his Complaint in the transferor court. See
Hoffman v. Blaski, 363 U.S. 335, 342–43 (1960). If the Court disclaimed jurisdiction over the
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 12 of 25

13
Blocked Funds now, it would not change the fact that it had exclusive jurisdiction at the relevant
time — when the writ of attachment was filed. The Levin Plaintiffs’ argument, moreover, is
essentially that their claim is senior in priority to the Government’s. The Court is not prepared to
determine the priority of competing interests for the Blocked Funds at this juncture for reasons
discussed in Section III.D, infra.
Even if the Levin Plaintiffs could have satisfied the first prong of § 1404(a), it would not
be “in the interest of justice” to transfer the matter to South Dakota. See 28 U.S.C. § 1404(a).
Both the balance of private interests and the public interest in equity and fairness militate against
such transfer.
While these factors are not exhaustive, district courts consider private interests like the
parties’ forum preferences, the “convenience of the parties,” and “whether the claim arose
elsewhere” when weighing that side of the ledger. Greater Yellowstone Coal., 180 F. Supp. 2d
at 127. None favors transfer. Starting with the parties’ preferences, only the Levin Plaintiffs
prefer to relocate to South Dakota; the Owens Plaintiffs and the Government favor continuing
litigation in this Court. Compare Levin Mot. Transfer at 5, with Owens Mot. Quash at 1, and
Mot. Deposit Funds at 3–4. As for convenience, it is “at least neutral,” Levin Reply to Gov. at
29, since the Blocked Funds are held in a South Dakota account, but the Government’s litigating
component and OFAC, the agency responsible for blocking the Funds in the first place, are here
in D.C. See Mot. Deposit Funds at 6. Finally, however the “claim” is characterized — either the
underlying suits against Iran giving rise to Plaintiffs’ writs of attachment or the initial civil-
forfeiture action against the Funds by the Government — none of the preceding events occurred
in South Dakota. See Levin, 523 F. Supp. 3d at 15, 17.
Nor must the Court consider the Levin Plaintiffs’ request while ignoring their prior
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 13 of 25

14
actions in this litigation. Upon learning of the Blocked Funds’ existence, they filed actions in
three separate districts: the Southern District of New York (where the Funds were interrupted
during the attempted EFT transfer and seized), this Court (where the Government initiated its
civil-forfeiture action), and (months later) the District of South Dakota. Levin, 523 F. Supp. 3d
at 18–19. They then chose to litigate vigorously here, twice moving for a writ of attachment and
appealing this Court’s orders quashing those writs. Only now, faced with the prospect of
competing priority interests, do they move to transfer. Such transfer could indeed affect their
fortunes moving forward: as discussed below, the court in which the attachment proceedings
occur could dictate which state’s procedural law, and thus which priority order, governs. This
Court will not exercise its discretion to transfer this action when doing so would prejudice other
parties. Cf. J.M.A. v. Sessions, 319 F. Supp. 3d 290, 297 (D.D.C. 2018) (preferring to sever
claims rather than “prejudice” parties by transferring one count “to a court that so clearly lacks
jurisdiction to hear it”).
As for the public interest, courts consider “the administrative difficulties flowing from
court congestion,” any “local interest in having localized controversies decided at home,” and “a
court’s familiarity with the ‘law that must govern the action.’” Atl. Marine Constr. Co. v. U.S.
Dist. Ct. for W. Dist. of Tex., 571 U.S. 49, 62 n.6, 64–65 (2013) (quoting Piper Aircraft Co. v.
Reyno, 454 U.S. 235, 241 n.6 (1981)). Of these, the Court finds only the last relevant here.
Litigation over the disposition of the Blocked Funds has been pending in this Court for more
than four years. This Court and the D.C. Circuit are well familiar with the facts and law of this
case. And while “[f]ederal district courts have equal familiarity with . . . federal laws” in
general, Ctr. for Env’t Sci., Accuracy & Reliability v. Nat’l Park Serv., 75 F. Supp. 3d 353, 358
(D.D.C. 2014), there is no denying the proliferation of claims brought in this district under the
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 14 of 25

15
Foreign Sovereign Immunities Act against Iran leading to judgments like the ones the Levin
Plaintiffs now seek to enforce. See, e.g., Valore v. Islamic Republic of Iran, 700 F. Supp. 2d 52
(D.D.C. 2010); Ben-Rafael v. Islamic Republic of Iran, 540 F. Supp. 2d 39 (D.D.C. 2008); Ewan
v. Islamic Republic of Iran, 466 F. Supp. 3d 236 (D.D.C. 2020). Consistency in the instant case
and across similarly situated ones is thus promoted by keeping the action here.
Whether at the first or second prong of the § 1404(a) analysis, the Levin Plaintiffs come
up short. The Court will thus deny their Motion to Transfer and proceed to the remaining
Motions.
B. 	Motion to Deposit Funds
In order to streamline matters going forward, the Government has moved under Federal
Rule of Civil Procedure 67(a) to deposit the Blocked Funds into the Court’s registry until their
disposition is finalized. See Mot. Deposit Funds at 9–10. That Rule provides that in actions
where “any part of the relief sought is . . . the disposition of a sum of money . . . , a party . . . may
deposit with the court all or part of the money.” It is “within a district court’s sound discretion to
accept a deposit” under this Rule. Alstom Caribe, Inc. v. George P. Reintjes Co., Inc., 484 F.3d
106, 114 (1st Cir. 2007). Such transfer is “a procedural device intended to provide a place for
safekeeping for disputed funds pending resolution of a legal dispute,” not a “means of altering
the contractual relationships and legal duties of the parties.” Tegtmeier v. PJ Iowa, L.C., 189 F.
Supp. 3d 811, 825 (S.D. Iowa 2016) (internal quotation marks and citation omitted); see Baxter
v. United Forest Prods. Co., 406 F.2d 1120, 1126 (8th Cir. 1969) (“Rule 67 was not intended for
. . . a one-sided before-judgment consequence.”).
The Government notes that Wells Fargo, a disinterested party without claim to the Funds,
seeks relief from the cost of holding the funds and participating in the ongoing proceedings. See
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 15 of 25

16
Mot. Deposit Funds at 10; see also Fed. R. Civ. P. 67 advisory committee’s note to 1983
amendment (rule addresses “situations in which a litigant may wish to be relieved of
responsibility for a sum or thing”). Wells Fargo does not object to transferring the Funds from
its account, but it requests that the Court release it from all liability in this action upon transfer
and that the Court require “written confirmation from the U.S. Department of Justice or [OFAC]
that Wells Fargo make the transfer consistent with OFAC regulations.” ECF No. 61 (Wells
Fargo Resp.) at 1–2.
Only the Levin Plaintiffs oppose this Motion. They argue that the OFAC license
applicable to the Funds does not “allow the Government to do anything with [the Blocked
Funds]” — including transferring them to this Court pending final disposition — “unless and
until it obtains a valid, final forfeiture judgement [sic]”. See Levin Reply to Gov. at 18–19.
They read the D.C. Circuit’s holding that the Blocked Funds are “blocked assets” for purposes of
the TRIA to mean that the Funds are “fully immobilized” and “must remain” in the South Dakota
account no matter what. Id. at 19 (quoting Est. of Levin, 156 F.4th at 639).
Their concern is misplaced. The Circuit held that the Funds are a “blocked asset” under
the TRIA because they are assets “‘frozen by the United States’ under . . . IEEPA.” Est. of
Levin, 156 F.4th at 638 (quoting § 201(d)(2)(A)). It further held that the Funds are “frozen”
because an OFAC blocking order “provides that they ‘may not be transferred, paid, exported,
withdrawn, or otherwise dealt in without prior authorization from OFAC.’” Id. (quoting ECF
No. 32-7 (OFAC Blocking Ord.) at ECF p. 4). Because Wells Fargo has requested that any
transfer to the Court’s registry be conditioned on confirmation that such transfer does indeed fall
within OFAC’s regulations, see ECF No. 61-1 (Wells Fargo Proposed Ord.), the Funds would
only be transferred pursuant to “prior authorization from OFAC.” OFAC Blocking Ord. at ECF
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 16 of 25

17
p. 4. They would thus remain as frozen and blocked as they currently are.
Nor is the Court concerned that such transfer under Rule 67 would conflict with the D.C.
Circuit’s holding that OFAC’s license permitting certain transfers was sufficiently narrow to
avoid unfreezing the Funds. Est. of Levin, 156 F.4th at 639. As an initial matter, Section I(a) of
that license authorizes the United States to “engage in all transactions necessary and ordinarily
incident to effect the forfeiture” of the Blocked Funds. See OFAC License at 2. That
authorization is not conditioned on the Government’s “furnishing a valid forfeiture order.” Id.
(Section II restrictions apply only to Section I(b)). Rule 67 authorizes the Court to “relieve a
party who holds a contested fund from responsibility for disbursement of that fund among those
claiming some entitlement thereto.” Alstom Caribe, 484 F.3d at 113. Such a transaction would
be “incident” to adjudicating a disputed forfeiture action and fall within the OFAC license’s
parameters. See OFAC License at 2. But even if it did not, an administrative transfer of the
Funds is not the sort of “dealing” that the D.C. Circuit contemplated might be sufficient to
unfreeze an asset. Est. of Levin, 156 F.4th at 639. A Rule 67 transfer is a “procedural device,”
not a means to “effect a legal transfer of property between litigants.” Prudential Ins. Co. of Am.
v. BMC Indus., Inc., 630 F. Supp. 1298, 1300 (S.D.N.Y. 1986). No title will change hands, nor
will any ownership interests be implicated. The Funds will still “do nothing but sit in a bank
account” — just one overseen by the Court rather than a disinterested financial institution in
South Dakota. Est. of Levin, 156 F.4th at 639.
Transferring the Blocked Funds, furthermore, would free Wells Fargo from the expense
of maintaining them and participating in litigation in which it has no interest. The Court will
thus exercise its discretion to grant the Government’s Motion to Deposit Funds in the Court’s
registry, subject to the conditions Wells Fargo suggests.
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 17 of 25

18
C. 	Motions to Quash
The Court next turns to the different Plaintiffs’ respective Motions to Quash. In order to
resolve these issues, it must first determine which law governs.
1. 	Applicable Law
For a change, the law here is gratifyingly clear. The Motions to Quash concern Victim-
Plaintiffs’ attempts to execute on money judgments they hold against Iran. Federal Rule of Civil
Procedure 69(a)(1) provides that “proceedings supplementary to and in aid of [a money]
judgment or execution [thereof]” are governed by “the procedure of the state where the court is
located” — here, D.C.
The Levin Plaintiffs’ contrary arguments do not undermine this conclusion. They
contend that in cases brought under the TRIA, “the law of the jurisdiction where the assets are
located governs how proper writs of execution are issued” — here, South Dakota. See Levin
Mot. Transfer at 8. They cite various cases to support their proposition. Id.
None of these cases contravenes Rule 69(a)(1) or announces a separate choice-of-law rule
applicable to assets blocked under the TRIA. Courts there applied the law of the state where the
assets were located — in some instances, where the presiding court was located as well — to
determine the nature of a party’s ownership interest in the given property. See, e.g., United
States v. $9,781,900.00 of Funds in Name of Falcon Strategies Sols., --- F. Supp. 3d ---, 2025
WL 3470138, at *6 (D.D.C. Dec. 3, 2025) (applying state law of asset location because “state
law defines the applicable property interest”); United States v. Oil Tanker Bearing Int’l Mar.
Org. No. 9116512, 480 F. Supp. 3d 39, 44 (D.D.C. 2020) (similar); Harrison v. Republic of
Sudan, 309 F. Supp. 3d 46, 49 (S.D.N.Y. 2018) (applying New York law where assets and court
located in state); Levin v. JPMorgan Chase Bank, N.A., 751 F. App’x 143, 146–47 (2d Cir.
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 18 of 25

19
2018) (similar); Hausler v. JP Morgan Chase Bank, N.A., 770 F.3d 207, 212 (2d Cir. 2014).
That is a separate question, however, from which state’s procedures must be followed to execute
on a previously established property interest. Rule 69(a)(1) consigns execution procedures to the
state law of the presiding court’s location; the Levin Plaintiffs’ authorities are not to the contrary.
Nor does Stansell v. Revolutionary Armed Forces of Colombia (FARC), 149 F. Supp. 3d
1337 (M.D. Fla. 2015), which the Levin Plaintiffs cite at length, support their assertion that the
property’s location determines the law governing garnishment procedures. See Levin Mot.
Transfer at 8. There, the district court located in Florida applied Florida law to determine that
garnishment of funds in New York bank accounts was unavailable. Stansell, 149 F. Supp. 3d at
1339–41. It thus did the very thing that Rule 69(a)(1) contemplates: apply the law of the state
where the court, not the property, is located. See also Levin v. Bank of N.Y., 2011 WL 812032,
at *12 (S.D.N.Y. Mar. 4, 2011) (applying law of court’s location). This Court, too, will apply
D.C. law to questions concerning the execution of any writs. See Smith ex rel. Est. of Smith v.
Fed. Rsrv. Bank of N.Y., 346 F.3d 264, 269 (2d Cir. 2003); Stansell v. Revolutionary Armed
Forces of Colom., 771 F.3d 713, 729–30 (11th Cir. 2014) (applying law of court’s location as
required by Rule 69(a)(1)).
2. 	Merits
As set forth above, each set of Plaintiffs seeks to quash the other’s writ, and Crystal
Holdings moves to quash both. While the parties have moved to quash various claims to the
Funds — that is, for an order extinguishing another’s property interest, see, e.g., ECF No. 37
(Levin Resp. Ord. Show Cause) (acknowledging that when writ is quashed, underlying claims to
Funds “may not proceed”) — they have not moved for summary judgment or made an equivalent
motion that would permit this Court to dispose of the Blocked Funds to satisfy judgments or
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 19 of 25

20
claims against them. See, e.g., Levin v. Bank of N.Y., 2011 WL 812032 (S.D.N.Y. Mar. 4,
2011) (resolving competing claims at summary-judgment stage). Nor have the Levin or Owens
Plaintiffs moved for condemnation of the Blocked Funds, a necessary procedural step under D.C.
law. See D.C. Code § 16-525; Joint Schedule Ord. at 2 (staying condemnation deadline until
further order of Court).
The Joint Scheduling Motion the parties proposed before briefing the at-issue Motions
confirms that they contemplate another round of dispositive motions. See ECF No. 50 (Joint
Schedule) at 4 (noting that “once the Court resolves the pending motions to quash, the parties
disagree who should ultimately receive the Blocked Funds”). The United States, notably,
“believes it has priority to the Blocked Funds because its forfeiture interest in them predates” the
Victim-Plaintiffs’ liens. Id. Yet that position is absent from the current briefing because the
Government only opposes the Levin Motion to Transfer the Funds and does not renew its
Motions to Quash. Id. at 3; see also Mot. Deposit Funds at 3. In other words, the United States
has conceded that the Victim-Plaintiffs have an interest in the Funds while maintaining its
purportedly superior claim to them.
The Court will thus resolve the Motions to Quash to determine the full set of valid
interests in the Blocked Funds but reserve ruling on the priority of those interests until complete
briefing on a motion for summary judgment, a motion to turn over funds, or other such action.
a. 	Levin Plaintiffs’ Motion to Quash Owens Plaintiffs’ Writ
Given the holdings in this Opinion situating venue and the Funds here, little remains of
the Levin Plaintiffs’ argument that the Owens Plaintiffs lack claim to the Funds. Their main
contention is that this Court should quash the Owens Plaintiffs’ writ of attachment because they
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 20 of 25

21
do not have a writ issued “from the jurisdiction where the assets are blocked” — that is, South
Dakota. See Levin Mot. Transfer at 12.
No such requirement stems from federal statute. The Owens Plaintiffs obtained an order
from Judge Bates in their underlying case against Iran permitting them to seek satisfaction of the
judgment against that nation. Owens v. Republic of Sudan, No. 01-2244 (D.D.C. Oct. 28, 2015),
ECF No. 389 (Owens 1610 Ord.). The FSIA requires such an order for a claimant to attach a
foreign state’s property that would otherwise be protected by sovereign immunity. See id.; 28
U.S.C. § 1610(c). Such an order permits Plaintiffs to “locate Iranian assets and convince a court
with jurisdiction over those assets that they are subject to attachment.” Ewan v. Islamic
Republic of Iran, 2026 WL 237562, at *2 (D.D.C. Jan. 29, 2026). But nothing within that
provision requires that the order come from a court within the district where the property is
located. Id.; see also Levin Mot. Transfer at 12 (asserting § 1610(c) location requirement but
citing no authority for proposition).
The Levin Plaintiffs also argue that neither federal nor state law permits a court located in
D.C. to order garnishment of funds currently located in South Dakota. This argument ignores
this Court’s exclusive jurisdiction over the res of the Blocked Funds. The Government’s civil-
forfeiture action gave this Court sole authority to issue orders disposing of claims to the Funds
and permits it to order the Funds’ transfer, as it does here. See 28 U.S.C. § 1355(d). Once the
Blocked Funds are located in its registry, any concerns about a mismatch between the location of
the writ and the blocked assets will be extinguished. Even if this Court were not ordering the
transfer of the funds to this district, garnishment would not be appropriate at this time. No party
has filed a motion for condemnation of the Funds, as required by D.C. law. See D.C. Code § 16-
525. To the extent that the Levin Plaintiffs still contend that the assets’ location and the timing
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 21 of 25

22
of the writs’ issuance dictates the priority of parties’ claims to the Funds, they can renew those
arguments on a motion for condemnation, summary judgment, or other action for final
disposition. But no basis exists to quash the Owens Plaintiffs’ valid writ of attachment in the
Court exercising sole jurisdiction over the Blocked Funds.
b. 	Owens Plaintiffs’ Motion to Quash Levin Plaintiffs’ Writ
The Owens Plaintiffs’ argument centers on the purported superiority of their claim to the
Blocked Funds over the Levin Plaintiffs’. It is not disputed that the Owens Plaintiffs filed their
writ of attachment in this Court before the Levin Plaintiffs did. Levin, 523 F. Supp. 3d at 18.
They thus reason that under D.C.’s “first in time” rule governing the priority of interests, their
writ has priority over the Levins’. See Owens Mot. Quash at 12 (citing D.C. Code § 16-545).
And because the unsatisfied amount of the Owens Plaintiffs’ judgments approaches $1 billion,
they in turn move to quash the Levin Plaintiffs’ writ on the ground that there will be no funds
remaining of the $9.98 million balance once the Owens Plaintiffs execute their interest. Id. at 13.
While it presents a fair assessment of the Blocked Funds’ insufficiency to satisfy more
than one group of Plaintiffs’ claims, the Owens Plaintiffs’ argument is premature. As discussed
above, no party has moved for final disposition of the Funds. The Court stayed the deadline for
seeking such condemnations during briefing of the instant Motions in anticipation of further
briefing on the priority of interests before it. See Joint Schedule Ord. at 2. The Owens
Plaintiffs’ claim to the Blocked Funds, while authorized by law, still must satisfy D.C.
procedures on the execution of that claim. See Fed. R. Civ. P. 69(a)(1). Should they fail to do
so, or in the (unlikely) event that their outstanding judgment is satisfied before the execution
process in this matter is complete, the Levin Plaintiffs might then hold the priority interest. The
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 22 of 25

23
Court will thus deny the Owens Plaintiffs’ Motion to Quash and determine the priority of
interests when that question is ripe.
c. 	Crystal Holdings’ Motion to Quash
Adopting a pox-on-both-their-houses approach, Crystal Holdings, the seller of the tanker,
moves to quash both the Owens and Levin Plaintiffs’ writs of attachment. Presenting a new take
on the Funds’ status, it asserts that “none of the parties are entitled to [the Blocked Funds]
because they belong to Crystal, not to Taif or Iran.” Crystal Mot. Quash at 1. Crystal Holdings
contends that the Holman Fenwick law firm was acting as Crystal and Taif’s “escrow agent”
when it received the $9.98 million balance transfer from Taif and attempted to forward that sum
to Crystal Holdings. Id. at 2. It further reasons that under escrow law, as soon as Crystal
Holdings delivered the oil tanker to Taif and Taif transferred the balance to HFW the sale was
“completed” and “title to those funds transferred to Crystal” at once. Id. at 3.
That argument stops at the water’s edge. The very documents that Crystal Holdings cites
as evidence of the escrow agreement among it, Taif, and HFW make clear that the escrow
arrangement applied only to the $2.34 million deposit, not the $9.98 million balance at issue in
this litigation.
The Engagement Letter among the three companies provides that HFW would “act[] as
Deposit Holder, as defined in the [Memorandum of Agreement]” and would “(a) prepare the
terms of an escrow agreement; (b) receive and hold the deposit in accordance with the escrow
agreement; and (c) on completion of sale, or otherwise, release the deposit in accordance with
the terms of the escrow agreement.” ECF No. 58-1 (HFW Engagement Letter) at ECF p. 2. The
MOA, in turn, defines the “Deposit” as 20% of the total purchase price — that is, the $2.34
million not at issue here. See ECF No. 58-4 (MOA) at ECF p. 2. It provides that the Deposit
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 23 of 25

24
shall be held in “Escrow Account held by . . . Escrow Agent” and only “released” to Crystal
Holdings “[o]n delivery of the [v]essel.” Id. at ECF pp. 2–3. An accompanying escrow
agreement outlines similar release conditions and HFW’s obligations regarding the 20% deposit.
See ECF No. 58-2 (Escrow Agreement).
Notably absent from these documents is any comparable escrow framework for the
balance of the purchase price — that is, the $9.98 million at issue. The MOA’s reference to the
balance states only that it “shall be paid in full.” MOA at ECF p. 3. It provides that the deposit,
by contrast, shall be “released” — i.e., from escrow — on the sale’s completion. Id. Unlike the
deposit, the balance is not defined as escrow property, is not required to be lodged in an escrow
account, and is not made subject to the Escrow Agreement’s release mechanics.
The Engagement Letter’s “Additional Fees” provision reinforces this distinction. It
contemplates that if HFW “[we]re required following the date of this letter of engagement to also
hold the balance of the purchase price and/or any other amount due from [Taif] to [Crystal]
under the MOA,” additional fees would apply. See HFW Engagement Letter at ECF p. 4. But
that clause does not specify that the balance would be held in escrow, nor does it incorporate the
existing escrow agreement or establish new escrow conditions governing the balance. Further
supporting the intent to treat the deposit and the balance differently, Taif and Crystal later
amended the MOA to provide that Taif would “provide [HFW] with original release instructions
in favo[]r of [Crystal] of the 20 percent deposit.” MOA at ECF p. 15. The amendment, like
other provisions, addresses release of the Deposit but does not reference any escrow arrangement
for the remaining purchase price, which would become the Blocked Funds.
Because the record shows that the parties’ escrow agreement covered only the $2.34
million deposit, not the remaining balance, the Court holds that HFW was not acting as Crystal
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 24 of 25

25
Holdings’ escrow agent when Taif transferred the Blocked Funds. It therefore need not reach the
parties’ arguments surrounding the law of the case, the application of escrow law, or the
timeliness of Crystal Holdings’ intervention into these proceedings. The Court will thus deny
the Motion to Quash the Levin and Owens Plaintiffs’ writs of attachment.
IV. 	Conclusion
For the foregoing reasons, the Court will deny the Levin Plaintiffs’ Motion to Transfer
and Quash the Owens Plaintiffs’ writs. It will also deny the Owens Plaintiffs’ Cross-Motion to
Quash the Levin Plaintiffs’ writs and Crystal Holdings’ Motion to Quash both the Levin and
Owens Plaintiffs’ writs. Last, the Court will grant the Government’s Motion to Deposit Funds,
subject to the conditions requested by Wells Fargo. A separate Order so stating shall issue this
day.
/s/ James E. Boasberg
JAMES E. BOASBERG
Chief Judge
Date: March 31, 2026
Case 1:21-cv-00420-JEB Document 69 Filed 03/31/26 Page 25 of 25