Plaintiff, the Islamic Republic of Iran, brings this action against Irans former ruler, Shah Mohammed Reza Pahlavi, and his wife, Empress Farah Diba Pahlavi. It alleges in its complaint that defendants accepted bribes and misappropriated, embezzled or converted 35 billion dollars in Iranian funds in breach of their fiduciary duty to the Iranian people and it seeks to recover those funds and 20 billion dollars in exemplary damages. It asks the court to impress a constructive trust on defendants assets located throughout the world, for an accounting of all moneys and property received by the defendants from the government of Iran, and for other incidental relief.
