Summary

1. Plaintiff Republic of Kazakhstan, by and through its undersigned counsel, brings this action against Defendants Daniel Chapman, Argentem Creek Holdings LLC, Argentem Creek Partners LP, Pathfinder Argentem Creek GP LLC, and ACP I Trading LLC (collectively, "Defendants"). In support thereof, Plaintiff alleges as follows:

NATURE OF THE ACTION

2. This case arises from Defendants' knowing participation in, conspiracy to commit, and aiding and abetting of, an ongoing fraudulent scheme that has damaged Plaintiff.

THE PARTIES

3. Plaintiff Republic of Kazakhstan ("Plaintiff" or "Kazakhstan") is a sovereign state.

4. Defendant Daniel Chapman ("Chapman") is the founder, Managing Partner, Chief Executive Officer, and Chief Investment Officer of Argentem Creek Partners LP. He also wholly owns Argentem Creek Holdings LLC. Prior to founding Argentem Creek Partners LP, Chapman was a member of the senior management at Black River Asset Management LLC ("Black River"). Chapman resides at 165 West 91st Street, New York, NY 10024.

5. Defendant Argentem Creek Holdings LLC ("Argentem Creek Holdings") is a limited liability company organized under the laws of the State of Delaware. Argentem Creek Holdings is the controlling owner of Argentem Creek Partners LP. Argentem Creek Holdings' principal place of business is at 12 East 49th Street, New York, NY 10017.

6. Defendant Argentem Creek Partners LP ("Argentem Creek Partners") is a registered investment advisor organized as a limited partnership under the laws of the State of Delaware. Both Argentem Creek Holdings and Argentem Creek Partners were formed in connection with a spin-off from Black River in December 2015. Argentem Creek Partners' principal place of business is at 12 East 49th Street, New York, NY 10017.

7. Defendant Pathfinder Argentem Creek GP LLC ("Pathfinder") is organized as a limited liability company under the laws of the State of Delaware. Pathfinder is the general partner of Pathfinder Strategic Credit LP and Pathfinder Strategic Credit II LP. Pathfinder's principal place of business is at 12 East 49th Street, New York, NY 10017.

8. Upon information and belief, Defendant ACP I Trading LLC ("ACP I") is a limited liability company organized under the laws of the Cayman Islands. Its legal address is P.O. Box 309, Ugland House, South Church Street, George Town KY1-1104, Cayman Islands. ACP I's principal place of business is at 12 East 49th Street, New York, NY 10017.

JURISDICTION AND VENUE

9. This Court has personal jurisdiction over Defendants under CPLR § 302(1) and (2) because they transact business within the State and have committed tortious acts within the State. This Court also has personal jurisdiction under CPLR § 302(4) because, upon information and belief, Defendants own, use, or possess real property situated within the State.

10. Venue is proper in New York County pursuant to CPLR §§ 503(a) and 503 (d), because Defendants reside and/or have their principal offices in this County, and a substantial part of the events or omissions giving rise to the claims occurred in this County.

FACTUAL ALLEGATIONS

I. OVERVIEW

11. Defendants are conspiring with, and aiding and abetting, a fraudulent scheme led by Moldovan oligarch Anatolie Stati, his son Gabriel Stati, and a murky web of companies that they control, often secretly (collectively the "Statis").

12. Between 1999 and 2004, the Statis purchased two Kazakh companies ­ Kazpolmunay LLP ("KPM") and Tolkynneftegaz LLP ("TNG") ­ that were licensed to engage in the exploration and production of oil and gas in Kazakhstan.1

13. For the purported purpose of raising funds to finance the operations of KPM and TNG, the Statis sold notes to third-party investors. Specifically, in 2006 and 2007, the Statis used their special-purpose entity Tristan Oil Ltd. ("Tristan Oil") to sell two tranches of notes in the aggregate principal amount of $420 million (the "Tristan Notes") to Noteholders (the "Tristan Noteholders").

14. One of the largest Tristan Noteholders was Black River Asset Management LLC ("Black River"), which invested through several of its funds. Defendant Argentem Creek Holdings and its subsidiary Defendant Argentem Creek Partners (collectively, "Argentem Creek Partners") were spun out from Black River as an employee-owned investment firm in December 2015 and became the successor in interest to Black River, including by assuming ownership of the Tristan Notes. Defendant Chapman, who had managed the investments for Black River, became the owner and CEO of Argentem Creek Partners.2

...