Purple Coffee LLC / Spring Flags LLC / Pink Dime LLC / Trefoil Rooms LLC

4 Italian LLCs purchased 14 Trump SoHo units from Bayrock/Sapir on single day for 10.86M

Purple Coffee LLC, Spring Flags LLC, Pink Dime LLC, and Trefoil Rooms LLC — all formed Feb 15 2013 with consecutive DOS IDs (4361025-4361093) — purchased 14 condo-hotel units at 246 Spring Street from Bayrock/Sapir Organization LLC and Bayrock/Zar Spring LLC on March 12, 2013 for a total of 10,856,546.62. All 4 LLCs listed Andrea Fiocchi, Esq. of Reinhardt LLP at 44 Wall Street 10th Floor as SOP agent. The sellers (Bayrock entities) were at 160 Varick Street 2nd Floor (Bayrock Group HQ). Units: Purple Coffee (2011, 2012, 2101, 3508 = 3217823.73), Spring Flags (1806, 2611, 3511 = 2173555.54), Pink Dime (1006, 1712, 1801, 1908 = 3206594.63), Trefoil Rooms (3703, 3811, 3911 = 2258572.72).

BENEFICIAL OWNERS IDENTIFIED: Magda Pozzo and Giampaolo Pozzo are the Italian clients who purchased all 14 Trump SoHo units via 4 LLCs

All 14 units sold to CIM Group entity Aug 21 2017 at 22.1% loss (8.46M vs 10.86M purchase)

On August 21, 2017, all 4 LLCs sold their combined 14 units to 246 Spring Street (NY) LLC (a CIM Group entity at 540 Madison Avenue 8th Floor) for total 8,456,116.38. Each LLC took exactly 22.1% loss: Purple Coffee sold for 2,506,348.92 (bought 3,217,823.73), Spring Flags sold for 1,692,972.47 (bought 2,173,555.54), Pink Dime sold for 2,497,602.93 (bought 3,206,594.63), Trefoil Rooms sold for 1,759,192.06 (bought 2,258,572.72). The uniform 22.1% discount suggests a negotiated bulk sale. SAGE documents show simultaneous release of Trump International Hotels Management LLC service agreements. CIM had won Trump SoHo in foreclosure auction in Nov 2014 and was consolidating ownership of individual units. The building was rebranded The Dominick in Dec 2017.

14 Italian LLC units represented 50% of all Trump SoHo sales in first 10 months of 2013 - massive single-buyer concentration

Per the Domus Arbiter complaint, the 14 units purchased by the 4 Italian LLCs for 10.86M represented 50% of all Trump SoHo sales during the first 10 months of 2013. This is extraordinary: a single client group (channeled through 4 shells with a common attorney) accounted for half of an entire year's sales at a flagship Trump property. The purchases came at a time when Trump SoHo was struggling badly - only 62 units (15%) had been sold by June 2010, and the building entered foreclosure proceedings. These 14 all-cash purchases through opaque LLCs were exactly the type of transaction that FinCEN would later target with Geographic Targeting Orders in 2016 (for Manhattan purchases over 3M through shell companies). Each individual LLC purchase was near or above the 3M threshold that would later trigger GTO reporting.

ACRIS full transaction detail for 4 Italian LLC Trump SoHo purchases (all dated 2013-03-12): Purple Coffee LLC bought units 2011, 2012, 2101, 3508 for $3,217,823.73 from Bayrock/Zar Spring LLC + Bayrock/Sapir Organization LLC. Spring Flags LLC bought units 1806, 2611, 3511 for $2,173,555.54 from same sellers. Pink Dime LLC bought units 1006, 1712, 1801, 1908 for $3,206,594.63 from Bayrock/ZAE Spring LLC (typo for ZAR) + Bayrock/Sapir. Trefoil Rooms LLC bought units 3703, 3811, 3911 for $2,258,572.72 from same sellers. Total: 14 units, $10,856,546.62. All c/o Andrea Fiocchi, Esq., Reinhardt LLP, 44 Wall Street 10th Floor. Sellers all at c/o Bayrock Group LLC, 160 Varick Street 2nd Floor.

2017 sale detail: All 14 Trump SoHo units sold to 246 SPRING STREET (NY), LLC (540 Madison Ave 8th Fl — CIM Group entity) on Aug 21, 2017. Reinhardt LLP address changed from 44 Wall St to 200 Liberty Street 27th Floor by time of sale. Document 2017082401284 is a single deed covering all 4 seller LLCs. Pink Dime LLC sale recorded at $2,497,602.93 (for its 4 units). Total sale verified $8.46M across all LLCs vs $10.86M purchase = 22.1% loss over 4.4 years.

The Purchase Agreement between Bayrock/Sapir and Spring Street/4 LLCs expressly named Paramount Realty Group of America Corp as sole broker; contains indemnification clause protecting Bayrock from broker commission claims

All 4 Italian LLCs used CPLR 3020(d)(3) attorney-verification dodge: Fiocchi alone verified answers, stating each LLC 'does not maintain offices in the county in which counsel's office is located' — no LLC member signed

NYSCEF business search for each of Zampolli's four Italian shell-LLCs (Purple Coffee, Spring Flags, Pink Dime, Trefoil Rooms) returns EXACTLY ONE case each: Domus Arbiter Realty Corp v. Bayrock Group LLC et al (Index 651970/2014). This confirms that in NY state civil litigation, these four entities are named ONLY as co-defendants/parties inside the Domus Arbiter-Bayrock Trump SoHo broker-commission suit. The four LLCs do not appear in any other NY Supreme Court action — no independent commercial, contract, or tort litigation. Combined with earlier finding #10327 (not in NY/FL/PA/NM/TX state registries), reinforces that the four LLCs functioned as a single-purpose Trump SoHo unit/broker-commission shell cluster tied to Bayrock.

SYNTHESIS: BOI evasion timeline confirmed — the 4 Italian LLCs were dissolved June 14, 2024, which was approximately 7 months before the original FinCEN BOI reporting deadline of January 1, 2025 for entities formed before 2024. However, the entire CTA/BOI reporting requirement was subsequently suspended for domestic companies on March 26, 2025 by Treasury. The dissolution still appears strategically timed: in mid-2024, compliance was still expected and the LLCs had been dormant since the 2017 sale. The beneficial owners of the 4 LLCs remain permanently unknown — no BOI filings were ever made, and the dissolution preempted the requirement.

Beneficial owners of 4 Italian LLCs remain unknown - no FinCEN BOI filing found, LLC structure shields identity

Despite extensive searching, the actual beneficial owners of the 4 LLCs remain unidentified. Key factors: (1) NY LLC filings do not require disclosure of members/managers. (2) FinCEN BOI reporting only began Jan 1, 2024 - all 4 LLCs dissolved Jun 14, 2024 (potentially before filing or exempt due to dissolution). (3) All ACRIS documents list only the LLC names c/o Reinhardt LLP - no individual names appear as grantees. (4) No mortgages recorded (all-cash purchases). (5) The LLCs were formed before FinCEN Geographic Targeting Orders covered Manhattan (GTOs started Mar 1, 2016 for purchases over 3M). (6) The Domus Arbiter lawsuit describes them as Italian clients of Rispo but does not name individuals. (7) The court opinion does not mention the LLC names. The purchases were pre-GTO all-cash transactions through opaque shells - exactly the structure FinCEN later targeted.

No evidence found linking the 4 Italian LLCs to Kazakh/BTA Bank money flows

Despite investigation, no evidence connects the Italian LLC buyers to Kazakh stolen funds. The Ablyazov/Khrapunov money trail traced through FBME Bank (Tanzania/Cyprus/Russia), not Italian banks. The Khrapunov purchases at Trump SoHo (3 units, Apr 2013, 3.1M via Martin Jajan) were separate transactions from the Italian LLC purchases (14 units, Mar 2013, 10.86M via Fiocchi/Reinhardt). Key differences: (1) Different attorneys (Jajan vs Fiocchi). (2) Different timing (Apr vs Mar 2013). (3) Different seller entities (though both from Bayrock/Sapir). (4) The Khrapunov money came through FBME Bank/Cyprus, not Italian banks. (5) No OCCRP or court evidence connects Italian banks to the Kazakh laundering scheme. However, Ablyazov's wife was living in Italy (arrested/deported from Rome May 2013), and the Ablyazov network maintained presence in Italy. The absence of evidence is not evidence of absence, particularly given the complete opacity of the LLC beneficial ownership.

4 Italian LLCs (Purple Coffee, Spring Flags, Pink Dime, Trefoil Rooms) NOT found in NY corporate registry (data.ny.gov), Florida registry (Sunbiz), or any other jurisdiction in registry.db. Delaware registry search blocked by OpenCorporates rate limit. The LLCs were likely formed in a jurisdiction where the registry does not disclose beneficial owners (DE or NY with limited disclosure). Combined with the Domus Arbiter lawsuit naming them only by LLC name and Reinhardt LLP address, the beneficial owners remain completely shielded.