Saydam

I. BACKGROUND

1 The following facts are undisputed. Defendant was born in 1938 in Turkey. [Docket No. 2 34-1 (Dep. Tuncay Saydam) 13:7-15.] He worked as a professor in Turkey, and then moved to the 3 United States in 1980 to teach computer science at the University of Delaware. Id. at 16:5-23; 4 18:25. He became an American citizen in 1988 or 1989. Id. at 19:15-17. He maintained dual 5 Turkish citizenship and would travel to Turkey once or twice a year throughout the relevant time 6 period. Id. at 23:16-24:12. In the late 1980s and for a period of time in the 1990s, Defendant also 7 worked and taught in Switzerland. Id. at 20:18−25; 27:5−22; 32:2−6. 8 Defendant has maintained bank accounts in Turkey with Akbank T.A.Ş. (“Akbank”) since 9 around the 1980s. Id. at 82:6-13. At some point before 2009, he opened bank accounts with 10 Zürcher Kantonalbank (“ZKB”) in Switzerland, in which he kept his university salaries and 11 consulting fees—a major part of his life savings. Id. at 39:17−40:11; 66:22−67:9; 80:2-12. 12 Sometime before 2012, he also opened a bank account with M&T Bank in America. [Docket No. 13 34-22 (M&T Bank Statement).] 14 In 2012, ZKB terminated…