Schiff v. Internal Revenue Services et al

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF PUERTO RICO
PETER DAVID SCHIFF,
Plaintiff,
v.
INTERNAL REVENUE SERVICE, et al.,
Defendants.
CIVIL NO. 24-1511 (CVR)
OPINION AND ORDER
INTRODUCTION
The present case arises from the closure of Euro Pacific International Bank (“the
Bank”), owned by Plaintiff Peter David Schiff (“Plaintiff”). 	The Bank was subject to
scrutiny by the Internal Revenue Service (“IRS”) and the Puerto Rico Commissioner of
Financial Institutions (“OCIF” per its Spanish-language acronym) as part of a joint tax
enforcement investigation of the Bank conducted by the Joint Chiefs of Global Tax
Enforcement known as the “J5”. 1
Plaintiff’s grievance stems from his intended sale of the Bank's stock to a company
called Qenta for $17.5 million. OCIF initially supported the sale but ultimately blocked it
on May 16, 2022, allegedly at the request of the J5 Defendants. OCIF instead approved
an asset sale to Qenta for $1.25 million after the Bank entered receivership, resulting in a
considerable loss to Plaintiff. 	As part of the investigation, Jim Lee, former IRS Chief of
1 The J5 combats transnational tax crime through gathering information, sharing intelligence, conducting operations,
and building the capacity of tax crime enforcement. The J5 consists of five individual members, all named defendants
in this case: the IRS, Mr. Will Day, Mr. Eric Ferron, Mr. Niels Obbink, and Mr. Simon York (collectively, the “J5
Defendants”). The Court has already addressed the claims against the IRS in a separate Opinion and Order and will
focus solely on the claims of the aforementioned individuals.
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Criminal Investigations, made statements during a press conference in Puerto Rico to
announce the investigation into the Bank, implying Plaintiff was involved in tax evasion
and money laundering. 	Plaintiff avers these statements were false and as result of the
delay in completing the Bank’s liquidation, Plaintiff's reputation was damaged, and he
suffered significant financial harm. Plaintiff later found out that the IRS and the J5
Defendants were allegedly in a conspiracy and leaked confidential and false information
regarding the investigation to the press, who published it, further harming Plaintiff.
Plaintiff then brough this case against many parties. 	As relevant here, Plaintiff
sued the international members of the J5, Will Day (“Day”), a representative of the
Australian Taxation Office; Eric Ferron (“Ferron”), a representative of the Canada
Revenue Agency; Niels Obbink (“Obbink”), a representative of the Fiscale Inlichtingen-
en Opsporingdienst of the Netherlands; and Simon York (“York”), a representative of His
Majesty’s Revenue and Customs (collectively, the “Foreign Defendants”). Plaintiff brings
claims against them under § 1985(3) (“§ 1985”), and for tortious interference with
business relations and defamation under Puerto Rico law. 2
Before the Court there are Motions to Dismiss by each of the Foreign Defendants
(Docket Nos. 129, 139, 159 and 166) in which they contend the dismissal of all claims
against them is proper under Fed.R.Civ.P. 12(b)1 for lack of subject matter jurisdiction,
under Rule 12(b)(5) for improper service. 	Additionally, Ferron, Day and Obbink (the
2 Plaintiff also brings an independent claim under Bivens v. Six Unknown Named Agents of the Federal Bureau of
Narcotics, 403 U.S. 388 (1971) (the “Bivens claim”), and a claim for violation of his due process rights and unlawful
seizure of property under the Fifth Amendment in the alternative to his Bivens claim. He alleges that this alternative
claim is brought against “All Defendants”. However, none of these causes of action can be brought against non-
government officials. See Hernández-Cuevas v. Taylor, 836 F.3d 116, 119, n. 1 (1st Cir. 2016) (A Bivens action is a civil
action brought against agents of the United States); Gerena v. P.R. Legal Serv. Inc., 697 F.2d 447, 449 (1st Cir. 1983)
(the Fifth Amendment applies only to claims asserted against the federal government, not against private individuals,
or states).
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“Movants”) argue dismissal is proper against them under Rule 12(b)(6) for failure to state
a claim upon which relief can be granted. Plaintiff opposed all motions (Docket Nos. 138,
145, 179, and 180) and the Foreign Defendants and Movants replied. (Docket Nos. 148,
187, 203, 204).
The undersigned had previously referred this case to Magistrate Judge Marcos E.
López (“Magistrate Judge López”) for full pre-trial management, including ruling on non-
dispositive motions and issuing reports and recommendations for dispositive motions.
(Docket No. 66).
STANDARD
Federal Rule of Civil Procedure 8(a) requires plaintiffs to provide “a short and
plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P.
8(a)(2). A “short and plain” statement needs only enough detail to provide a defendant
with “ ‘fair notice of what the ... claim is and the grounds upon which it rests.’ ” Bell Atl.
Corp. v. Twombly, 550 U.S. 544, 555 (2007); see also Erickson v. Pardus, 551 U.S. 89, 93,
(2007) (“Federal Rule of Civil Procedure 8(a)(2) requires only ‘a short and plain
statement....’ Specific facts are not necessary.”). 	To show an entitlement to relief, a
complaint must contain enough factual material “to raise a right to relief above the
speculative level on the assumption that all the allegations in the complaint are true (even
if doubtful in fact).” See Twombly, 550 U.S. at 555.
When evaluating a claim under Rule 12, the Court must “accept as true all well-
pleaded facts in the complaint and draw all reasonable inferences in favor of the
plaintiffs.” Gargano v. Liberty Int’l Underwriters, Inc., 572 F.3d 45, 48-49 (1st Cir. 2009).
Under Twombly, 550 U.S. at 555, however, a plaintiff must “provide the grounds of his
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entitlement [with] more than labels and conclusions”; see also, Ocasio-Hernández v.
Fortuño-Burset, 640 F.3d 1, 12 (1st Cir. 2011). Nor does a complaint suffice if it tenders
“naked assertion[s]” devoid of “further factual enhancement.” Ashcroft v. Iqbal, 556 U.S.
557 (2009). 	A complaint does not need detailed factual allegations, but “[t]hreadbare
recitals of the elements of a cause of action, supported by mere conclusory statements, do
not suffice.” Id., at 678. Thus, a plaintiff is required to present allegations that “nudge
[his] 	claims 	across 	the 	line 	from 	conceivable 	to 	plausible” 	to 	comply 	with 	the
requirements of Rule 8(a). Twombly, 550 U.S. at 570.
The Court may refer dispositive motions to a Magistrate Judge for an R&R. See 28
U.S.C. § 636(b)(1)(B); Fed. R. Civ. P. 72(b). Within fourteen days of receiving a copy of
the R&R, “a party may serve and file specific written objections to the proposed findings
and recommendations.” Id.
Upon filing of a timely objection, a party is entitled to a de novo determination of
“those portions of the report or specified proposed findings or recommendations to which
specific objection is made.” Total Petroleum Puerto Rico Corp. v. Fonseca-Marrero, Civil
No. 16-2436 (PAD), 2018 WL 6131777, at *1 (D.P.R. 2018) (quotation omitted); see also
Ponsa-Rabell v. Santander Securities, LLC, Civil No. 17-2243 (CCC), 2020 WL 4219685,
at *1 (D.P.R. 2022). 	The Court, however, need not “consider frivolous, conclusive, or
general objections.” 	Local Rule 72(d); Fed.R.Civ.P. 72(b)(2); Rodríguez-González v.
Astrue, 854 F.Supp.2d 176, 178 (D.P.R. 2012). And if objections merely repeat arguments
already made to the magistrate judge, a de novo review is unwarranted, and the Court will
review those portions of the R&R for clear error. Id. The Court may “accept, reject, or
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modify, in whole or in part, the findings or recommendations made by the magistrate
judge.” 28 U.S.C. § 636 (b)(1)(C).
ANALYSIS
A. The R&R.
Magistrate Judge López found all Motions to Dismiss shared common issues and
addressed them jointly in his Report and Recommendation (“R&R”) in which he
recommended the claims against the Foreign Defendants be dismissed. (Docket No. 250).
Specifically, Magistrate Judge López first found that the Amended Complaint did not
allege any facts plausibly suggesting that the Foreign Defendants engaged in conduct
outside of their official responsibilities. The Magistrate Judge rejected Plaintiff’s claims
that the actors were personally liable and opined that the fact that the actions complained
of were wrongful did not make them ultra vires or taken in an individual capacity.
Therefore, he found the actions were undertaken in each officer’s official capacity and
they should be treated as the actions of the foreign state itself. For this reason, Magistrate
Judge López concluded the foreign sovereigns, and not the individual persons, were the
real parties in interest and the claims barred by the Foreign Sovereign Immunities Act
(“FSIA”), 28 U.S.C. §§ 1330, 1602 et seq. He further held the commercial activity and the
non-commercial tort exceptions to the FSIA, which allow suits against foreign officials in
limited cases, were inapplicable to this case. In the alternative, if not barred under FSIA,
the claims would still be barred by foreign sovereign immunity under common law. For
these reasons, Magistrate Judge López concluded that the Court lacked jurisdiction to
hear Plaintiff’s claims against the Foreign Defendants.
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As to the merits, Magistrate Judge López additionally found that the Amended
Complaint lacked a plausible entitlement to relief against the Movants because the
Amended Complaint only contained conclusory allegations of conspiracy for the § 1985
cause of action which were insufficient to withstand a motion to dismiss. Specifically, that
it failed to state the nature of the conspiracy between the parties, including how the
conspiracy was hatched and furthered, and that there were no facts showing the
conspiracy was motivated by class-based discriminatory animus, an essential element for
this claim to survive. Regarding the tortious interference claim, he found Plaintiff failed
to establish the existence of a contract and even if he had, there were no facts showing the
Movants acted intentionally to interfere with said contractual relationship, also necessary
elements of such a claim. Finally, because none of the allegedly defamatory statements
were attributed to the Movants, he found the defamation claim against them to be
misplaced. 3
B. Plaintiff’s Objections to the R&R.
Plaintiff timely objected to Magistrate Judge López’ R&R. 	(Docket No. 256).
Defendants Ferron, Day and Obbink jointly replied to Plaintiff’s Objections. (Docket No.
265). Defendant York individually replied to Plaintiff’s Objections. (Docket No. 270).
At the outset, the Court must mention that Plaintiff’s Objections begin with a
section titled “Key facts and dates (as pleaded and docketed”), and goes on to discuss
numerous facts, dates and documents that were not even mentioned in the Amended
Complaint. Plaintiff also attached 202 pages of documents to the Objections to salvage
3 The Magistrate Judge also stated that, since he recommended dismissal of all claims under Federal Rule of Civil
Procedure 12(b)(1) and 12(b)(6) arguments, he did not address the additional reason for dismissal, that service of
process was improper under Federal Rule of Civil Procedure 12(b)(5).
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the meager allegations of the Amended Complaint. 	Plaintiff was already granted two
opportunities 	to 	amend 	his 	Complaint 	accordingly 	to 	include 	this 	allegedly 	new
information in his pleadings and failed to take advantage of those opportunities. See U.S.
ex rel. Gagne v. City of Worcester, 565 F.3d 40, 48 (1st Cir. 2009) (affirming the lower
court’s decision that leave to amend was not warranted when the party had multiple
opportunities to cure pleading deficiencies); ACA Fin. Guar. Corp. v. Advest, Inc., 512 F.3d
46, 57 (1st Cir. 2008)( “plaintiffs do not get leisurely repeated bites at the apple”); Badillo-
Santiago v. Naviera-Merly, 378 F.3d 1, 7-8 (1st Cir. 2004) (affirming denial of leave to
amend after fourteen months elapsed from filing of the complaint to plaintiff's request to
amend).
The Court’s job at this stage is to determine whether, accepting as true all well
pleaded facts in the Amended Complaint, Plaintiff has provided “a short and plain
statement of the claim showing that the pleader is entitled to relief” under Fed. R. Civ. P.
8(a)(2) and whether such relief is plausible on those allegations. 	Consideration of
documents outside the pleadings is allowed in limited circumstances, which are not
present here. See Alternative Energy, Inc. v. St. Paul Fire and Marine Ins. Co., 267 F.3d
30, 33-34 (1st Cir. 2001) (noting that, while the Court ordinarily may not consider
documents beyond the Complaint in ruling on a motion to dismiss brought under
Fed.R.Civ.P. 12, there are exceptions, including documents over which there is no dispute
as to authenticity, official public records and documents specifically referenced in the
complaint.). Thus, to the extent that these documents are being brought now in a tardy
attempt to save the scant allegations Plaintiff himself supplied in the now-twice Amended
Complaint, the Court will not consider them. They were not presented to the Magistrate
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Judge either, constituting a separate reason to reject them now. 	See Quirós v. Muñoz,
Civil No. 08-1074 (JAG), 2009 WL 10717764, at *4 (D.P.R. Nov. 25, 2009); Borden v.
Secretary of Health & Hum. Servs., 836 F.2d 4, 6 (1st Cir. 1987).
The Court now examines Plaintiff’s objections de novo and finds them to be
meritless.
Plaintiff’s first objection is that the R&R misapplied FSIA to determine that the
real parties in interest were the sovereigns and not the individual Defendants and
requests the Court to permit limited jurisdictional discovery. However, Plaintiff fails to
rebut Magistrate Judge López’ thorough analysis of why he determined the officials were
acting in official and not personal capacity and the multitude of cases cited by him that
supported this finding. 4 	In fact, Plaintiff’s Objection contains not a single citation to
caselaw, making it automatically non-compliant with Local Rule 7(a). (“Unless otherwise
allowed by the Court, all matters to be submitted for consideration by the court shall be
presented by written motion filed with the clerk incorporating a memorandum of law as
appropriate, including citations and supporting authorities”).
As to the request for jurisdictional discovery, the same is rejected as untimely and
waived. 	See Bramson v. Winn, 136 F. App’x 380, 382 (1st Cir. 2005) (“We deem this
argument waived, as it was raised for the first time in Bramson's objections to the
magistrate’s report and recommendation”); Maine Green Party v. Maine, Sec’y of State,
173 F.3d 1, 4 (1st Cir. 1999).
4 Magistrate Judge López also separately found the Foreign Defendants were also immune under common law
sovereign immunity, so this argument is a non-starter.
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The second objection is that the discretionary function exception analysis to FSIA
was overbroad and not act-specific, and that foreign sovereign immunity under common
law was misapplied. Actions taken by foreign governments are considered sovereign acts
and are protected from the exercise of jurisdiction of federal courts unless one of the
exceptions to immunity applies. 	One of these, the discretionary function exception,
shields officers from liability for tort claims based on an employee’s exercise of judgment
or choice provided that the decision is based on social, economic, or political policy. Thus,
to find the officer liable, the officer must act pursuant to an “applicable statute, regulation,
or policy bearing the requisite degree of specificity”, not based on choice or have
discretion. Muñiz-Rivera v. United States, 326 F.3d 8, 16 (1st Cir. 2003). Plaintiff failed
to show this.
On the contrary, after a comprehensive discussion, Magistrate Judge López
specifically found that Foreign Defendants acted by choice, not by obligation. 	There is
nothing overboard about this conclusion. Plaintiff’s additional assertion that the Foreign
Defendants 	incurred 	in 	misconduct 	and 	allegedly 	acted 	“outside 	their 	legitimate
functions” does not change this conclusion, as the officer is protected even if he/she
abused that discretion or was negligent, if the action involved discretion. Therefore,
Magistrate Judge López correctly concluded that exceptions to the FSIA do not apply to
the Foreign Defendants’ alleged tortious conduct and the FSIA bars all three causes of
action against them.
Regarding the common law sovereign immunity, it protects for official acts
performed within the scope of an officer’s duty, but not for private acts where the officer
purports to act as an individual and not as an official. 	As noted by Magistrate Judge
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López, “the Plaintiff has not pled any actions on the part of the Foreign Defendants that
were taken in their individual capacity. 	Their actions, while tortious as pled, are still
official acts taken within the scope of that duty”. 	(Docket No. 250, p. 14). 	Thus,
Magistrate Judge López correctly decided that the Foreign Defendants were also
protected under common law sovereign immunity, and Plaintiff’s objections offer no
justification to alter his recommendation.
The third objection is that the R&R applies an unduly demanding pleading
standard as to the § 1985 claim and attempts to rely on the same documents and pleadings
not in evidence to sustain this argument. 	Pleading a conspiracy under § 1985 requires
facts alluding to: (1) a conspiracy; (2) a conspiratorial purpose to deprive a class of
persons of equal protection of the laws; (3) an overt act in furtherance thereof and; (4)
either (a) an injury to person or property, or (b) a deprivation of a constitutionally
protected right or privilege. Stand With US Ctr. for Legal Just. v. Massachusetts Inst. of
Tech., 158 F.4th 1, 24 (1st Cir. 2025); Rolón v. Rafael Rosario & Assocs., 450 F.Supp.2d
153, 159 (D.P.R. 2006). But Plaintiff simply failed to include any allegations as to almost
all these elements, so this cause of action cannot prosper. See, e.g., Iqbal, 556 U.S. at 678
(threadbare 	recitals 	of 	the 	elements 	supported 	by 	conclusory 	statements 	are
insufficient). 5
5 Although not mentioned by Magistrate Judge López, this provision is also seemingly inapplicable to the Movants, as
it applies “If two or more persons in any State or Territory” who conspire. 42 U.S.C.A. § 1985 (West); Sturdza v. U.A.E.,
281 F.3d 1287 (D.C. Cir. 2002) (foreign government not a person under § 1985); Ohno v. Yasuma, 723 F.3d 984, 995
(9th Cir. 2013) (explaining foreign governments are not bound by the U.S. Constitutions); see also Gerritsen v. de la
Madrid Hurtado, 819 F.2d 1511, 1515 (9th Cir. 1987) (finding that action of the Mexican government cannot be
considered arising “under state law”); Tabaka v. Leyre, No. 220CV06600 (BRMJAD), 2021 WL 5506910, at *2 (D.N.J.
Nov. 24, 2021) (holding Plaintiff's § 1983 claims do not apply to foreign government officials or foreign entities). As
candidly argued by Defendants Ferron and Day in their respective motions, § 1983 and § 1985 have been interpreted
consistently with each other and §1983 does not apply to foreign governments. (Docket No. 129, p. 15; Docket No. 159,
p. 14).
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Plaintiff’s fourth objection is that the R&R misreads Puerto Rico law as to the
tortious interference claim. He argues that at this stage he need only to “plausibly” allege
a contract or legally protected business relationship. 	But Puerto Rico law requires a
contract and does not apply when there is simply a profitable financial relationship. Gen.
Office Prods. Corp. v. A.M. Capen’s Sons, Inc., 780 F.2d 1077, 1081 (1st Cir. 1986);
Dolphin Int’l, Inc. v. Ryder Truck Lines, Inc., 127 D.P.R. 869, 883 (1991).6 As Magistrate
Judge López correctly noted, the Complaint merely discussed a “$17.5 million sale to
Qenta” that was allegedly blocked, and the allegations failed to identify any other
contractual terms or obligations binding the parties, that defendants knew of this
relationship or intentionally acted to interfere with it. This claim cannot move forward if
these allegations are lacking.
The last objection is that Magistrate Judge López imposed an unduly demanding
standard 	for 	the 	defamation 	cause 	of 	action 	and 	ignored 	that 	Plaintiff 	pleaded
“defamation 	by 	implication.” 	Magistrate 	Judge 	López 	determined 	the 	Amended
Complaint did not successfully allege any false statements, libel or slander made by the
Foreign Defendants because all the allegedly defamatory statements were specifically
attributed to other parties, i.e. the Media Defendants and IRS agent Jim Lee. 	If the
Movants neither said nor wrote anything, no defamation claim may lie. Additionally, as
far as the Court can tell, there is no “defamation by implication” under Puerto Rico law.
Plaintiff cites to no caselaw in support of this proposition and fails to explain how it even
applies to his factual scenario. 	Even giving Plaintiff, the widest berth possible, the
6 The Supreme Court in Dolphin additionally held that in addition to the existence of a contract, it had to be for a specific
or finite period/term. Id. No such allegations have been made in this case.
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Amended Complaint simply lacks enough facts to meet even this initial and basic pleading
standard.
In sum, upon an independent review of the record and consideration of the
analysis contained in Magistrate Judge López’ R&R and after conducting its own research
and de novo analysis of the issues presented for the Court’s consideration, the Court
adopts in full the Magistrate Judge’s findings and legal conclusions that the requests to
dismiss filed by the Foreign Defendants should be granted and the causes of action against
them dismissed. 7
CONCLUSION
In view of the foregoing, the R&R (Docket No. 250) is ADOPTED in its entirety. As
such, the Motions to Dismiss filed by the Foreign Defendants (Docket Nos. 129, 139, 159
and 166) are GRANTED. 	All claims against Will Day, representative of the Australian
Taxation Office; Eric Ferron, representative of the Canada Revenue Agency; Niels
Obbink, 	representative 	of 	the 	Fiscale 	Inlichtingen-en 	Opsporingdienst 	of 	the
Netherlands; and Simon York, representative of His Majesty’s Revenue and Customs, in
their official and personal capacities, are DISMISSED WITH PREJUDICE.
Judgment to be entered accordingly.
IT IS SO ORDERED.
7 The Court, like the Magistrate Judge, does not reach the arguments made by all Foreign Defendants under
Fed.R.Civ.P. 12(b)(5) for insufficiency of service of process, but notes that service appears to have been improper for all
of them under both the Hague Convention as well as under the laws of their respective countries. This would be an
additional reason to dismiss the case against all of them. See e.g., Herndon v. Ridgway, 58 U.S. 424, 425 (1854) (proper
service of process is a prerequisite for litigating in federal court, and in its absence, a court lacks personal jurisdiction
over the defendant unless the defendant has waived service or otherwise consented to personal jurisdiction).
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In San Juan, Puerto Rico, on this 12 th day of March 2026.
S/CAMILLE L. VELEZ-RIVE
CAMILLE L. VELEZ RIVE
UNITED STATES DISTRICT JUDGE
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