THIELE | TWO SISTERS DAIRY LLC

CASE OVERVIEW

MATTER IDENTIFICATION

MATTER

THIELE | TWO SISTERS DAIRY LLC

CLAIMANTS

TWO SISTERS DAIRY LLC | ANASTASIA ANNE THIELE

GOVERNING FRAMEWORK

FEDERAL CIVIL RICO | FIFTH CIRCUIT

STATUTORY CLAIM PATHS

18 U.S.C. §§ 1962(a)–(d) | CIVIL REMEDY UNDER § 1964(c)

BUSINESS AND PROPERTY RECORD PERIOD

2005–2026

DOCUMENTED SOLE-OWNERSHIP PERIOD

JANUARY 1, 2012–MAY 5, 2026

ASSERTED RICO CONDUCT PERIOD

2012–2026

CLAIM SUMMARY

CLAIM SUMMARY
THIELE | TWO SISTERS DAIRY LLC ASSERTS FOUR INTERRELATED COURSES OF CONDUCT AFFECTING THE OWNERSHIP, CONTROL, PROPERTY, PROCEEDS, AND ECONOMIC VALUE OF THE DAIRY OPERATION.

The record traces the alleged displacement of Anastasia Anne Thiele’s recorded ownership and governing authority; the exercise of unauthorized control over Two Sisters Dairy LLC and its operating assets; the transfer and allocation of business and property value through financing, collateral, sale, title, closing, and tax transactions; and the institutional enforcement of the resulting economic allocation.

The linked pages identify the relevant actors, dates, transactions, communications, instruments, injuries, financial flows, and supporting source records.

STATUTES18 U.S.C. §§ 1962(a)–(d)
CIVIL REMEDY18 U.S.C. § 1964(c)
OWNERSHIP AND AFFECTED INTERESTS
ANASTASIA ANNE THIELE HELD 100% OF THE MEMBERSHIP INTERESTS IN TWO SISTERS DAIRY LLC THROUGHOUT THE OPERATIVE PERIOD BEGINNING JANUARY 1, 2012.

The record separately traces:

  • Two Sisters Dairy LLC’s business property and operating assets;
  • individually titled real property;
  • dairy revenue and receivables;
  • contractual and governance rights;
  • credit and collateral;
  • sale and closing proceeds;
  • tax attributes and liabilities;
  • and exchange value associated with the dairy and related property transactions.
MEMBERSHIP100% ANASTASIA ANNE THIELE
COMPANY RECORD2005–2026
DOCUMENTED SOLE OWNERSHIPJANUARY 1, 2012–MAY 5, 2026

FINANCIAL INSTITUTIONS, FINANCING & TRANSACTION SEQUENCE

2019 · CONSENT DENIAL & SUBSEQUENT BANK OF THE WEST RECORDING
AGTEXAS DID NOT ISSUE THE REQUESTED CONSENT. BANK OF THE WEST RECORDED DEED OF TRUST NO. 2019-05501 TWENTY-EIGHT DAYS LATER.

Bank of the West stated that it could proceed after AgTexas executed the proposed Consent to Easement. AgTexas denied the request, and the consent was never issued or executed.

Twenty-eight days later, Bank of the West recorded Deed of Trust No. 2019-05501, including road-easement and related covenant rights across the Hoover/Murphree collateral identified in the unsigned consent materials.

This sequence is relied upon in the asserted acquisition-or-maintenance-of-control record under § 1962(b) and the enterprise-conduct record under § 1962(c).

RECORDED INSTRUMENTDEED OF TRUST NO. 2019-05501
REQUESTED CONSENTDENIED | NOT ISSUED | NOT EXECUTED
TIME BETWEEN DENIAL AND RECORDING28 DAYS
2021–2023 · MARTINS-AFFILIATED FINANCING & TRANSFER APPROVAL
AGTEXAS FINANCED MARTINS-AFFILIATED ENTITIES WHILE ANASTASIA ANNE THIELE’S NOTE, LIENS, AND PERSONAL LIABILITY REMAINED.

AgTexas extended $15,020,628 to Martins-affiliated borrowers on September 16, 2021, followed by additional financing in April 2022 and May 2023.

After receiving the Martins-specific lease and sales contracts, AgTexas approved the identified possession-and-purchase structure while Anastasia Anne Thiele’s existing note, liens, and personal liability remained.

The financing and approval sequence is relied upon to identify institutional participation, acquisition or maintenance of control, and the use of financial channels in the alleged enterprise.

INITIAL FINANCING$15,020,628
INITIAL EXTENSION DATESEPTEMBER 16, 2021
ADDITIONAL FINANCINGAPRIL 2022 | MAY 2023
2022 · BUYER-ENTITY FORMATION & 1,436.178-ACRE APPRAISAL
TJLR PROPERTIES LLC WAS FORMED THREE DAYS BEFORE THE EFFECTIVE DATE OF THE BANK-COMMISSIONED APPRAISAL.

TJLR Properties LLC was formed on September 16, 2022. The Bank of the West-commissioned appraisal became effective on September 19, 2022.

A contemporaneous email described the assignment as the “Anastasia 100 AC improved pasture.” The completed appraisal valued the entire 1,436.178-acre operation, including land, improvements, equipment, and fixtures.

Tony Martins was first identified to Anastasia Anne Thiele on December 30, 2022.

The entity-formation and appraisal sequence is relied upon to connect transaction preparation, the full property scope, and actor-specific participation in the asserted acquisition and control structure.

ENTITY FORMATIONSEPTEMBER 16, 2022
APPRAISAL EFFECTIVE DATESEPTEMBER 19, 2022
EMAIL-DESCRIBED SCOPE100 ACRES
APPRAISED SCOPE1,436.178 ACRES
2023–2026 · CLOSING DISTRIBUTIONS, ACQUISITION FINANCING & REFINANCING
THE FEBRUARY 22, 2023 CLOSING PAID $2,778,895.49 TO BANK OF THE WEST, $703,840.60 TO AGTEXAS, AND $0.00 TO ANASTASIA ANNE THIELE.

The February 22, 2023 Heifer Ranch closing distributed $2,778,895.49 to Bank of the West and $703,840.60 to AgTexas. The settlement statement reported $0.00 cash to Anastasia Anne Thiele.

BMO later recorded $17,000,000 in real-property debt and an equipment-and-fixtures UCC in connection with the Martins-affiliated acquisition.

AgTexas refinanced the acquired position for $33,000,000 on November 26, 2025. The recorded Martins-affiliated credit facility later totaled $118,696,740.50.

The closing distributions and subsequent financing are relied upon to trace the asserted injury to business or property, the disposition of transaction proceeds, and the acquisition and maintenance of the Martins-affiliated position.

TO BANK OF THE WEST$2,778,895.49
TO AGTEXAS$703,840.60
TO ANASTASIA ANNE THIELE$0.00
AGTEXAS REFINANCE$33,000,000
RECORDED MARTINS-AFFILIATED FACILITY$118,696,740.50

KEY DOCUMENTED SEQUENCE

NO. DATE OR PERIOD DOCUMENTED EVENT RICO CLAIM CONNECTION RECORD PATH
01 2005 | JANUARY 1, 2012 Two Sisters Dairy LLC was formed as a dairy business in 2005. Anastasia Anne Thiele acquired 100% of the membership interests effective January 1, 2012, and held the company’s governing authority throughout the operative period. CLAIMANT STATUS | BUSINESS AND PROPERTY INTERESTS | ENTERPRISE AND INJURY FOUNDATION V | VIII
02 SEPTEMBER 2018–AUGUST 2019 An $18,000,000 financing package was distributed to seventeen lenders. AgAmerica proposed financing at 60% loan-to-value, Capital Farm Credit reported favorable underwriting, and Bank of the West stated that its requested first-lien position depended on senior-lien clearance. DOCUMENTED FINANCEABILITY | CREDIT ACCESS | COLLATERAL CONTROL | CAUSAL RECORD II | VIII | IX
03 AUGUST 21–22 | SEPTEMBER 19 | DECEMBER 16, 2019 AgTexas denied and did not execute the consent Bank of the West stated it required. Twenty-eight days later, Bank of the West recorded Deed of Trust No. 2019-05501. On December 16, 2019, AgTexas separately recorded a lien subordination benefiting Lone Star NGL. NOTICE TO BANK OF THE WEST | DIFFERENTIAL EXERCISE OF SENIOR-LIEN AUTHORITY | RECORDED COLLATERAL CONTROL | ASSERTED § 1962(b) PATH II | VI | IX
04 SEPTEMBER 16, 2021–MAY 12, 2023 AgTexas extended $15,020,628 to Tony Martins-affiliated entities on September 16, 2021, followed by $7,092,112.50 in April 2022 and $8,500,000 on May 12, 2023. BUYER-SIDE FINANCING | ACQUISITION STRUCTURE | INSTITUTIONAL PARTICIPATION | ASSERTED §§ 1962(b), (c), AND (d) PATHS II | VII | IX
05 APRIL–AUGUST 2022 Anastasia Anne Thiele was excluded from the company books. During the same period, the operating-line balance increased from $4,474,897.21 to $6,146,401.90, the account sweep was discontinued, and Bank of the West classified the facility as an exit credit. INFORMATION AND FINANCIAL CONTROL | DEBT INCREASE | OPERATION OR MANAGEMENT OF ENTERPRISE AFFAIRS | INJURY CAUSATION III | VI | VII
06 SEPTEMBER 16–19 | OCTOBER 3, 2022 TJLR Properties LLC was formed three days before the effective date of the Bank of the West-commissioned appraisal. A contemporaneous email described a 100-acre assignment; the completed appraisal valued the full 1,436.178-acre dairy operation. The October 3 asset statement reported $39,161,323.90 in assets against $11,549,923.14 in debt. BUYER-ENTITY TIMING | TRANSACTION PREPARATION | PROPERTY SCOPE | VALUE AND FINANCIAL CONDITION | ASSERTED CONTROL AND CAUSATION PATH IV | VII | VIII
07 DECEMBER 30, 2022–JANUARY 2023 Tony Martins was first identified to Anastasia Anne Thiele on December 30, 2022. The January 2023 Good Faith Agreement then established an exclusive transaction period. BUYER DISCLOSURE TIMING | EXCLUSIVE TRANSACTION CONTROL | ASSERTED ACQUISITION AND AGREEMENT PATHS UNDER §§ 1962(b) AND (d) II | V | VI
08 FEBRUARY 18–22, 2023 The herd auction realized $5,171,994.43. Four days later, the Heifer Ranch closing distributed $2,778,895.49 to Bank of the West, $703,840.60 to AgTexas, and reported $0.00 cash to Anastasia Anne Thiele. PROPERTY DISPOSITION | PROCEEDS DISTRIBUTION | DIRECT BUSINESS-OR-PROPERTY INJURY | PROXIMATE CAUSATION VII | VIII | IX
09 MARCH–MAY 2023 AgTexas received the Tony Martins-specific lease and sales contracts, retained its acceleration rights, and approved the identified transaction structure. The documents placed the Martins-affiliated entity in possession effective April 7, 2023, while Anastasia Anne Thiele’s note, liens, and personal liability remained. POSSESSION AND PURCHASE RIGHTS | CONTINUING COLLATERAL AND LIABILITY | ACQUISITION OR MAINTENANCE OF CONTROL | ASSERTED §§ 1962(b) AND (d) PATHS II | V | VI
10 JULY 26–29, 2024 The dairy closed for $10,250,000. The closing allocated $4,450,000 in real-property value to Klaas Talsma, routed $3,814,738.56 to his qualified intermediary, and sent the $963,830.47 “Two Sisters Dairy — Unsecured Creditors” pool to Talsma Dairy. BMO recorded $17,000,000 in real-property debt and an equipment-and-fixtures UCC in connection with the Martins-affiliated acquisition. PROCEEDS ROUTING | BUSINESS-AND-PROPERTY INJURY | ASSERTED USE OR INVESTMENT UNDER § 1962(a) | ACQUISITION OR MAINTENANCE OF CONTROL UNDER § 1962(b) | ENTERPRISE CONDUCT AND AGREEMENT UNDER §§ 1962(c) AND (d) VII | VIII | IX
11 NOVEMBER 26, 2025–MAY 5, 2026 AgTexas refinanced the acquired position for $33,000,000. BMO terminated its UCC and released its deeds of trust. The recorded Martins-affiliated facility later totaled $118,696,740.50 across ten notes and five cross-guaranteed entities. ASSERTED REINVESTMENT AND REFINANCING PATH UNDER § 1962(a) | CONTINUED ACQUISITION OR MAINTENANCE OF CONTROL UNDER § 1962(b) | ENTERPRISE AND PATTERN CONNECTION II | IX

RICO CLAIM FRAMEWORK

PROVISION ELEMENTS AS PLEADED
18 U.S.C. § 1962(a)
  • Receipt of income derived from an asserted pattern of racketeering activity.
  • Direct or indirect use or investment of that income or its proceeds in the acquisition, establishment, or operation of an enterprise.
  • Injury caused by the asserted use or investment.
18 U.S.C. § 1962(b)
  • Acquisition or maintenance, directly or indirectly, of an interest in or control of an enterprise through an asserted pattern of racketeering activity.
  • Injury caused by the acquisition or maintenance of that interest or control.
18 U.S.C. § 1962(c)
  • An identified RICO person distinct from the pleaded enterprise.
  • Conduct of or participation in the operation or management of the enterprise’s affairs.
  • An asserted pattern of racketeering activity.
18 U.S.C. § 1962(d)
  • Agreement to facilitate a violation of § 1962(a), (b), or (c).
  • Knowledge of the essential nature and overall objective of the asserted scheme.
  • Actor-specific conduct furthering that objective.
18 U.S.C. § 1964(c)
  • Direct injury to business or property by reason of the asserted § 1962 violation.
  • Proximate causation.
  • Treble damages, recoverable costs, and attorney’s fees.

CLAIMANTS & INJURY RECORD

CLAIMANT BUSINESS OR PROPERTY INTERESTS ASSERTED INJURY PRINCIPAL QUANTIFIED ENTRIES RECORD PATH
TWO SISTERS DAIRY LLC Operating revenue; working capital; company-owned land and operating property; herd; equipment; contract rights; tax attributes; credit; collateral; proceeds; equity; and company enterprise value as a valuation measure. Unpaid operating consideration; diversion or allocation of revenue and business assets; herd and equipment disposition; allocation of company-owned property; routing of § 1031 proceeds and the unsecured-creditor pool; and loss of reinvestment capacity, expansion value, equity, and enterprise value. Approx. $2,400,000 in lease consideration | $31,478,447 in depreciation | $10,152,263 in excluded assets | $3,814,738.56 qualified-intermediary wire | $22,356,050 appraisal-to-price differential VIII | IX
ANASTASIA ANNE THIELE Separately titled real property; personal sale proceeds; contract and governance rights; exchange rights; tax position; cash; homestead title; personal credit; and investment capital. Heifer Ranch disposition; allocation of personal closing proceeds; unperformed tax-priority and true-up provisions; tax misattribution; federal lien, levy, and passport certification; continued retention of seized capital; and loss associated with exchange or replacement-property rights. $3,500,000 Heifer Ranch sale | $0.00 cash to owner at closing | $4,450,000 closing allocation | $1,036,631 tax overstatement | $293,805.14 seized and retained | $911,568 exchange boot or shortfall III | VII | VIII

CURRENT RECOVERY POSITION

COMPENSATORY MODEL $65,392,236
§ 1964(C) TREBLE DAMAGES $196,176,708

RECORD INDEX