CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 1 of 40 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA

Size: px
Start display at page:

Download "CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 1 of 40 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA"

Transcription

1 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 1 of 40 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MINNESOTA TARGET CORPORATION, Civil Action No. Plaintiff, vs. LCH PAVEMENT CONSULTANTS, LLC; UNITED PAVING COMPANY, a division of SUPERIOR PAVING CO, INC.; AMERICAN PAVEMENT SOLUTIONS INC.; ASPHALT MAINTENANCE INC.; ROSE PAVING COMPANY; LESLIE J. BAILEY; KEITH HEUTZENROEDER; SABAS TRUJILLO; TIMOTHY HELSTAD; and JAMES STINSON; COMPLAINT JURY TRIAL DEMANDED Defendants. Plaintiff Target Corporation ( Target ), through its undersigned counsel, hereby alleges as follows for its Complaint against the above-named Defendants: PARTIES 1. Plaintiff Target is a Minnesota corporation with its principal place of business in Minneapolis, Minnesota. 2. Defendant LCH Pavement Consultants, LLC ( LCH ) is a Texas limited liability company with its principal place of business in Pearland, Texas. Defendant Leslie J. Bailey ( Bailey ) is, on information and belief, one of the owners of LCH. Defendant Keith Heutzenroeder ( Heutzenroeder ) was the General Manager of LCH at times relevant to this Complaint. Bailey is a resident of the State of Texas and, upon information and belief, Heutzenroeder is a resident of the State of Colorado. 1

2 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 2 of Defendant United Paving Company ( United Paving ) is a division of Superior Paving Co., Inc., a California corporation with its principal place of business in La Mirada, California. Defendant Sabas Trujillo ( Trujillo ) is the President of United Paving Company and, upon information and belief, resides in the State of California. 4. Defendant American Pavement Solutions Inc. ( American Pavement ) is a Wisconsin corporation with its principal place of business in Green Bay, Wisconsin. Defendant Timothy Helstad ( Helstad ) is the President of American Pavement and, upon information and belief, resides in the State of Wisconsin. 5. Defendant Asphalt Maintenance Inc. ( Asphalt Maintenance ) is a Texas Corporation with its principal place of business in Pearland, Texas. Defendant James Stinson ( Stinson ) is the President of Asphalt Maintenance and, upon information and belief, resides in the State of Texas. 6. Defendant Rose Paving Company ( Rose Paving ) is an Illinois corporation with its principal place of business in Bridgeview, Illinois. JURISDICTION AND VENUE 7. This Court has subject matter jurisdiction over this action pursuant to 28 U.S.C because this is a matter in controversy between citizens of different states and exceeding the sum or value of $75,000, exclusive of interest and costs. This Court also has subject matter jurisdiction over this action pursuant to 28 U.S.C because Plaintiff asserts claims that arise under the laws of the United States, and over Plaintiff s state law claims pursuant to 28 U.S.C

3 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 3 of This Court has personal jurisdiction over all Defendants, and venue is proper in this District pursuant to 28 U.S.C because a substantial part of the events or omissions giving rise to the claims occurred in this judicial district. Defendants United Paving, American Pavement and Asphalt Maintenance have stipulated contractually to personal jurisdiction and venue in this District. Personal jurisdiction and venue in this District are also proper pursuant to 18 U.S.C. 1965(b). FACTUAL ALLEGATIONS 9. Target is a retailer that operates more than 1,700 stores, located throughout the United States. Target stores have parking lots that require periodic maintenance and repair. For some years, Target has used consultants to manage its parking lot repair and maintenance needs. These consultants inspect Target store parking lots and advise the company as to which parking lots are most in need of repair. They recommend needed repairs and maintenance and identify the quantities and types of repairs to be performed. Along with other responsibilities, the consultants function as construction managers. They schedule the performance of the work, coordinate with personnel employed at the Target stores, oversee the performance of the work by the contractors, and certify that the work has been completed and satisfactorily performed. Until 2011, they solicited bids from paving contractors. The consultants are paid a fixed fee to inspect each parking lot, and a percentage of the cost of each project. 10. Beginning in 2009, LCH was retained by Target as a consultant and was assigned responsibility for assessing and managing asphalt pavement work for Target throughout the majority of the United States, excepting only the Upper Midwest. Since that time, LCH has been responsible for managing contracts worth approximately $100 million for parking lot maintenance and repair for Target. 3

4 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 4 of At some point after it began working for Target as a consultant, LCH, through Bailey, Heutzenroeder, and perhaps others employed by that company, in conjunction with other Defendants named herein, devised a scheme to defraud Target. That scheme involved the knowing participation of a number of paving companies, and various principals and employees of those companies, including United Paving, American Pavement, Asphalt Maintenance, Rose Paving, Trujillo, Helstad, and Stinson, and perhaps others not yet known to Target. These paving companies and their respective principals and employees collaborated with each other and with LCH to defraud Target, as described more fully below. 12. The fraudulent scheme which is the subject of this action involved at least the following elements: a. When LCH identified for Target the types and quantities of work that needed to be carried out at each store (e.g., 10,000 square feet of 2-inch asphalt overlay; 20,000 square feet of 6-inch asphalt removal and replacement; etc.), LCH would, at times, overstate the quantities and types of work to be performed. b. Prior to 2011, rather than supervising a competitive bidding process as it represented to Target, LCH in fact organized, with the knowing participation of the Defendant paving contractors, their principals and employees, and perhaps others, a bid-rigging scheme. LCH and the Defendant paving contractors allocated projects on a territorial basis. The Defendants would ensure that the contractor that had been allocated a given territory would be the successful bidder by: (1) not inviting other local companies that were likely to be low-cost competitors to bid; (2) having contractors who were part of the bid-rigging scheme but who were not allocated the project in question submit uncompetitively high bids; and/or (3) when a contractor who was not part of the scheme submitted a competitive, low-cost bid, falsely 4

5 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 5 of 40 reporting an inflated bid amount to Target so that the company that participated in the bidrigging scheme appeared to be the low bidder. The Defendant paving companies collaborated with each other and with LCH by refraining from submitting competitive bids reflecting actual market pricing on any project that had been allocated to another member of the bid rigging scheme, e.g., Rose Paving submitted non-competitive bids for projects allocated to United Paving; Asphalt Maintenance submitted non-competitive bids for projects allocated to American Pavement, etc. As a result of Defendants bid-rigging scheme, Target paid prices for paving work that were substantially higher than competitive rates in the relevant geographic areas. c. With the knowledge and cooperation of the other Defendants, LCH abdicated its contractual responsibility to oversee the work of the paving contractors. In numerous instances, LCH appointed an employee of the contractor itself (or a subcontractor) to oversee and certify the completion of its own work. d. Rather than ensuring that the work on which the Defendants had bid was fully performed, LCH agreed with the Defendant contractors that they would perform only a portion of the work, but would invoice Target as though all of the work which they contracted to do had been performed. In many cases, the most costly work in the contracts the removal and replacement of asphalt all the way down to the subgrade was either not performed at all or was performed in amounts far less than those called for in the contract. This fraud was concealed by applying a surface overlay of asphalt, which provided the outward appearance of completely new pavement. e. LCH and the Defendant contractors would falsely certify to Target that all of the work had been completed; the Defendant contractor would submit a fraudulent invoice seeking payment from Target for all of the work called for in the contract; and LCH would 5

6 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 6 of 40 submit a fraudulent invoice to Target based upon a percentage of the entire project cost, including that portion of the work which was not in fact performed by the Defendant contractors. As a result, on multiple projects, in multiple states, Target paid LCH and Defendant contractors hundreds of thousands of dollars for work that was never actually performed. f. On information and belief, LCH demanded and received kickbacks from the Defendant contractors as further compensation for its role in the fraudulent scheme. 13. In June 2011, Target conducted a sourcing event relating to its parking lot maintenance program in Minneapolis, Minnesota. Leslie Bailey of LCH, along with representatives of the Defendant contractors, including Sabas Trujillo and David Brown of United Paving, Tim Helstad and Roger Myers of American Pavement, and Dave Rivers and C.B. Kuzlik of Rose Paving, traveled to Minnesota and participated in the event on behalf of their respective companies. Upon information and belief, the Defendant contractors conspired both in advance of the sourcing event and during the event itself to fix prices among themselves for Target s paving work. At the sourcing event, each contractor was asked to prepare proposed archetype prices (i.e., unit-prices $X per square foot for task A; $Y per square foot for task B, etc.) for the various types of work that are involved in parking lot repair and maintenance. Subsequent to the sourcing event, Target changed its asphalt procurement practices so that contracts were awarded on the basis of each contractor s archetype pricing. Contractors were assigned primary responsibility for stores on a geographic basis. As a result, the bid rigging scheme that Defendants had engaged in could no longer be carried out in the same manner. The remainder of the scheme, with respect to non-performance of the work, continued to operate. The Defendant paving contractors participated in the scheme with knowledge of the participation of the other Defendant paving contractors, pursuant to a single, common enterprise, the purpose 6

7 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 7 of 40 of which was to defraud Target in connection with Target s parking lot repair and maintenance projects. 14. The archetype pricing approach resulted in significantly lower unit prices for asphalt work, thus confirming that Defendants bid rigging scheme had caused inflated and noncompetitive prices to be paid by Target in the years prior to United Paving: Cypress, CA (T-0229), Billings, MT (T-0171), and Peoria, AZ (T-0825). 15. Defendants implemented their fraudulent scheme on at least the following projects that were performed by United Paving: Cypress, California (T-0229), Billings, Montana (T-0171), and Peoria, Arizona (T-0825). Cypress, California (T-0229) 16. On the Cypress project, Defendant Heutzenroeder submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire, on or about May 18, This Pavement Assessment defined the scope of work to be done on the Cypress parking lot and defined the quantities of work to be performed in square feet, inches and so on. This Pavement Assessment fraudulently overstated the size of parking lot area Zone B by over 90,000 square feet. The Pavement Assessment, with its grossly overstated work quantities, was used as the basis for bids submitted by contractors, including United Paving. 17. LCH represented to Target that United Paving was the low bidder on the project, based on United Paving s unit prices as applied to the work quantities identified by LCH. United Paving s bid proposal for Phase 1 of the project, in the amount of $590,345, and for Phase 2 of the project, in the amount of $409,304, were transmitted to Target in Minnesota by interstate mail or wire, on or about August 17, 2010, pursuant to Defendants fraudulent scheme. United Paving s proposal for both phases was subsequently accepted by Target. 7

8 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 8 of On or about July 27, 2010, LCH submitted an estimate for its work on Phase 1 of the project via interstate mail or wire to Target in Minnesota, in the amount of $47,228. On or about August 23, 2010, LCH submitted an estimate for its work on Phase 2 of the project via interstate mail or wire to Target in Minnesota, in the amount of $32, United Paving carried out the work on the Cypress project in August and September 2010, ostensibly under the oversight of LCH. However, the quantity of work that United Paving actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In addition to not performing over 90,000 square feet of asphalt overlay work, United Paving also performed only a small fraction of the nearly 40,000 square feet of 6 asphalt removal and replacement work that it had contracted to perform. 20. On or about October 15, 2010 and November 3, 2010, at the direction or with the consent of Defendant Trujillo, United Paving submitted to Target in Minnesota, via interstate mail or wire, invoices for Phase 1 and Phase 2 of the Cypress project in the amounts of $590,345 and $409,304, respectively. These invoices misrepresented the scope of work that United Paving had carried out on the Cypress project and the quantities of asphalt and other materials that it had installed. This was done pursuant to the Defendants fraudulent scheme. LCH knew that all of the work on the Cypress project had not been completed by United Paving, but nevertheless certified falsely to Target that the work was complete. 21. On or about September 13, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, invoices for Phase 1 and Phase 2 of the Cypress project in the amounts of $47,228 and $32,744, respectively. These invoices sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that United did not actually perform. Upon information and belief, LCH submitted its fraudulent invoices 8

9 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 9 of 40 for the Cypress project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 22. Target has paid United Paving $999,649 and LCH $79,972, representing payment in full for the Cypress project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. Billings, Montana (T-0171) 23. On the Billings project, Defendant Heutzenroeder submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire, on or about April 13, This Pavement Assessment defined the scope of work to be done on the Billings parking lot and defined the quantities of work to be performed in square feet, inches and so on. 24. By the date of the Billings project, Target had converted to the archetype pricing system, so United Paving was automatically selected as the contractor for the Billings project based on geography. 25. United Paving carried out its work on the Billings project, using the services of a subcontractor, during August and September This work was ostensibly done under the oversight of LCH. However, the quantity of work that United Paving actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, United directed its subcontractor to install less than one-half of the asphalt and other materials required for the project as defined by LCH and included in United Paving s contract with Target. 26. On or about September 7, 2011, LCH submitted to Target in Minnesota, via interstate mail or wire, as-built drawings for the Billings project that represented falsely that all 9

10 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 10 of 40 of the work on the project was complete. Upon information and belief, this was done with the knowledge and at the direction of Bailey. 27. On or about September 13, 2011, at the direction or with the consent of Defendant Trujillo, United Paving submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Billings project in the amount of $395,889. This invoice misrepresented the scope of work that United Paving had carried out on the Billings project and the quantities of asphalt and other materials that it installed. This was done pursuant to the Defendants fraudulent scheme. LCH knew that all of the work on the Billings project had not been completed by United Paving, but nevertheless certified falsely to Target that the work was complete. 28. On or about September 28, 2011, LCH submitted to Target in Minnesota, via interstate mail or wire, an invoice for the Billings project in the amount of $26,143. This invoice sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that United did not actually perform. Upon information and belief, LCH submitted its fraudulent invoices for the Billings project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 29. Target has paid United Paving $395,889 and LCH $26,143, representing payment in full for the Billings project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. Peoria, Arizona (T-0825) 30. On the Peoria project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire, on or about February 21, This Pavement 10

11 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 11 of 40 Assessment defined the scope of work to be done on the Peoria parking lot and defined the quantities of work to be performed in square feet, inches and so on. 31. On or about September 13, 2011, United Paving transmitted by interstate mail or wire to Target in Minnesota its bid proposal to perform the Peoria work as defined by LCH s Pavement Assessment, and agreed to carry out that work. 32. United Paving carried out its work on the Peoria project, using the services of a subcontractor, American Asphalt, during September This work was ostensibly done under the oversight of LCH. However, the quantity of work that United Paving (via its subcontractor) actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, United directed its subcontractor to install less than onehalf of the asphalt and other materials required for the project as defined by LCH and included in United Paving s contract with Target. 33. On or about September 22, 2011, at the direction or with the consent of Defendant Trujillo, United Paving submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Peoria project in the amount of $1,074,810, together with a representation that it had completed all of the work within its contractual scope at the Peoria store. This invoice misrepresented the scope of work that United Paving had carried out on the Peoria project and the quantities of asphalt and other materials that it installed. This was done pursuant to the Defendants fraudulent scheme. Trujillo, LCH, Bailey and Heutzenroeder knew that all of the work on the Peoria project had not been completed by United Paving, but nevertheless certified falsely to Target that the work was complete. 34. On or about October 3, 2011, LCH submitted to Target in Minnesota, via interstate mail or wire, an invoice for the Peoria project in the amount of $69,624. This invoice 11

12 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 12 of 40 sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that United did not actually perform. Upon information and belief, LCH submitted its fraudulent invoice for the Peoria project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 35. Target has paid United Paving $1,074,810 and LCH $69,624, representing payment in full for the Peoria project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. American Pavement: Skyline, VA (T-1893), Neshaminy, PA (T-1183), and Monroeville, PA (T-1219) 36. Defendants implemented their fraudulent scheme on at least the following projects that were performed by American Pavement: Skyline, Virginia (T-1893), Neshaminy, Pennsylvania (T-1183), and Monroeville, Pennsylvania (T-1219). Skyline, Virginia (T-1893) 37. On the Skyline project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work to be done on the Skyline parking lot and defined the quantities of work to be performed in square feet, inches and so on. 38. American Pavement prepared bids for the two phases of the Skyline project, totaling $488,203, and transmitted them to Target in Minnesota via interstate mail or wire on or about July 6, 2010 and August 24, American Pavement s proposals for both phases were subsequently accepted by Target. 39. American Pavement carried out the work on the Skyline project in September 2010, ostensibly under the oversight of LCH. However, the quantity of work that American 12

13 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 13 of 40 Pavement actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, American Pavement installed less than onehalf of the asphalt and other materials required for the project as defined by LCH and included in American Pavement s contract with Target. 40. On or about September 21, 2010, at the direction or with the consent of Defendant Helstad, American Pavement submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Skyline project in the amount of $488,203. This invoice misrepresented the scope of work that American Pavement had carried out on the Skyline project. This was done pursuant to the Defendants fraudulent scheme. Upon information and belief, LCH, American Pavement, Bailey, Heutzenroeder, and/or Helstad knew that all of the work on the Skyline project had not been completed by American Pavement, but nevertheless certified falsely to Target that the work was complete. 41. On or about September 21, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, invoices for Phase 1 and Phase 2 of the Skyline project in the amounts of $31,884 and $7,972, respectively. These invoices sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that American Pavement did not actually perform. Upon information and belief, LCH submitted its fraudulent invoices for the Skyline project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 42. Target has paid American Pavement $488,203 and LCH $39,856, representing payment in full for the Skyline project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. 13

14 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 14 of 40 Neshaminy, Pennsylvania (T-1183) 43. On the Neshaminy project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work to be done on the Neshaminy parking lot and defined the quantities of work to be performed in square feet, inches and so on. 44. Helstad, on behalf of American Pavement prepared bids for the two phases of the Neshaminy project, totaling $476,085, and transmitted them to Target in Minnesota via interstate mail or wire on or about July 9, 2010 and August 24, 2010, respectively. American Pavement s proposals for both phases were subsequently accepted by Target. 45. American Pavement carried out the work on the Neshaminy project in August and September 2010, ostensibly under the oversight of LCH. However, the quantity of work that American Pavement actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, American Pavement installed only one-half of the asphalt and other materials required for the project as defined by LCH and included in American Pavement s contract with Target. 46. On or about September 16, 2010 and October 4, 2010, at the direction or with the consent of Defendant Helstad, American Pavement submitted to Target in Minnesota, via interstate mail or wire, invoices for the Neshaminy project in the total amount of $476,085. These invoices misrepresented the scope of work that American Pavement had carried out on the Neshaminy project. This was done pursuant to the Defendants fraudulent scheme. 47. On or about August 30, 2010 and September 20, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, its invoices for the Neshaminy project in the total amount of $38,087. These invoices sought payment from Target for work that LCH did not 14

15 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 15 of 40 perform, including the oversight and certification of completion of work that American Pavement did not actually perform. Upon information and belief, LCH submitted its fraudulent invoices for the Neshaminy project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 48. Target has paid American Pavement $476,085 and LCH $38,087, representing payment in full for the Neshaminy project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. Monroeville, PA (T-1219) 49. On the Monroeville project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work to be done on the Monroeville parking lot and defined the quantities of work to be performed in square feet, inches and so on. 50. Helstad, on behalf of American Pavement, prepared a bid for the Monroeville project, totaling $307,444, and transmitted it to Target in Minnesota via interstate mail or wire. American Pavement s bid proposal for the Monroeville project was subsequently accepted by Target. 51. American Pavement carried out the work on the Monroeville project in August 2010, ostensibly under the oversight of LCH. However, the quantity of work that American Pavement actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, American Pavement installed only approximately one-half of the asphalt and other materials required for the project as defined by LCH and included in American Pavement s contract with Target. 15

16 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 16 of On or about August 30, 2010, American Pavement submitted to Target, via interstate mail or wire, a Waiver of Lien form that represented that work on the Monroeville project had been completed and requested payment of $314,671. On or about September 16, 2010, at the direction or with the consent of Defendant Helstad, American Pavement submitted to Target in Minnesota, via interstate mail or wire, an invoice for the Monroeville project in the total amount of $314,671. This invoice misrepresented the scope of work that American Pavement had carried out on the Monroeville project. This was done pursuant to the Defendants fraudulent scheme. 53. On or about August 31, 2010, LCH certified to Target in Minnesota, via interstate mail or wire, that American Pavement had satisfactorily completed its work on the Monroeville project. This certification was false. 54. On or about August 31, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Monroeville project in the amount of $25,174. This invoice sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that American Pavement did not actually perform. Upon information and belief, LCH submitted its fraudulent invoice for the Monroeville project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 55. Target has paid American Pavement $341,671 and LCH $25,174, representing payment in full for the Monroeville project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. 16

17 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 17 of 40 Asphalt Maintenance: Hurst, TX (T-1766), Augusta, GA (T-1090), and Irving, TX (T- 0255) 56. Defendants implemented their fraudulent scheme on at least the following projects that were performed by Asphalt Maintenance: Hurst, Texas (T-1766), Augusta, Georgia (T-1090), and Irving, Texas (T-0255). Hurst, Texas (T-1766) 57. On the Hurst project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work to be done on the Hurst parking lot and defined the quantities of work to be performed in square feet, inches and so on. 58. Asphalt Maintenance transmitted its proposal for the Hurst project via interstate wire to Target in Minnesota. Target approved Asphalt Maintenance s proposal, also via interstate wire. 59. Asphalt Maintenance carried out the work on the Hurst project in August 2010, ostensibly under the oversight of LCH. However, the quantity of work that Asphalt Maintenance actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, Asphalt Maintenance installed less than one-half of the asphalt and other materials required for the project as defined by LCH and included in Asphalt Maintenance s contract with Target. 60. On or about September 16, 2010, at the direction or with the consent of Defendant Stinson, Asphalt Maintenance submitted to Target in Minnesota, via interstate mail or wire, an invoice for the Hurst project in the amount of $277,335. This invoice misrepresented the scope of work that Asphalt Maintenance had carried out on the Hurst project. This was done pursuant to the Defendants fraudulent scheme. 17

18 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 18 of On or about September 14, 2010, LCH certified to Target in Minnesota, via interstate mail or wire, that Asphalt Maintenance had satisfactorily completed its work on the Hurst project. This representation was false and, upon information and belief, was known to be false by Bailey and Heutzenroeder. These misrepresentations by Asphalt Maintenance and LCH were made pursuant to Defendants scheme to defraud Target. 62. On or about August 31, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Hurst project in the amount of $24,102. This invoice sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that Asphalt Maintenance did not actually perform. Upon information and belief, LCH submitted its fraudulent invoice for the Hurst project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 63. On or about October 14, 2010 and September 24, 2010, respectively, Target paid Asphalt Maintenance $277,335 and LCH $24,102, representing payment in full for the Hurst project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. Augusta, Georgia (T-1090) 64. On the Augusta project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work to be done on the Augusta parking lot and defined the quantities of work to be performed in square feet, inches and so on. 65. On or about July 2, 2010, Stinson, on behalf of Asphalt Maintenance, sent to Target in Minnesota via interstate mail or wire a Revised Bid Proposal for the Augusta project of $375,064. Stinson subsequently sent Target via interstate mail or wire a Bid Proposal for Phase 2 18

19 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 19 of 40 of the Augusta project in the amount of $134, Asphalt Maintenance s bid proposals for the Augusta project were subsequently accepted by Target. 66. On or about July 21, 2010, LCH transmitted an estimate of its fee for Phase 1 of the Augusta project, in the amount of $30,005, to Target in Minnesota via interstate mail or wire. 67. Asphalt Maintenance carried out the work on the Augusta project in September 2010, ostensibly under the oversight of LCH. However, the quantity of work that Asphalt Maintenance actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, Asphalt Maintenance installed only approximately one-half of the asphalt and other materials required for the project as defined by LCH and included in Asphalt Maintenance s contract with Target. 68. On or about September 14, 2010, LCH certified to Target in Minnesota, via interstate mail or wire, that Asphalt Maintenance had satisfactorily completed its work on the Augusta project. This certification was false. 69. On or about On October 4, 2010, and October 15, 2010, respectively, Stinson, on behalf of Asphalt Maintenance, submitted to Target in Minnesota, via interstate mail or wire, invoices for the Augusta project in the total amount of $509,201. These invoices misrepresented the scope of work that Asphalt Maintenance had carried out on the Augusta project. This was done pursuant to the Defendants fraudulent scheme. 70. On or about September 14, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Augusta project in the amount of $40,736. This invoice sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that Asphalt Maintenance did not actually perform. Upon 19

20 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 20 of 40 information and belief, LCH submitted its fraudulent invoice for the Augusta project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 71. Target has paid Asphalt Maintenance $509,201 and LCH $40,736, representing payment in full for the Augusta project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. Irving, Texas (T-0255) 72. On the Irving project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work to be done on the Irving parking lot and defined the quantities of work to be performed in square feet, inches and so on. 73. Subsequently, LCH purported to conduct a competitive bidding process for the Irving project and received bids from two contractors. LCH and Bailey represented to Target in a communication sent via interstate mail or wire that Asphalt Maintenance was the low bidder on the Irving project. In fact, another contractor was the low bidder. Subsequently, LCH and Bailey transmitted to Target via interstate mail or wire a spreadsheet that purported to show the bids that LCH had obtained from contractors on various projects, including Irving. In that spreadsheet, LCH altered the bid that was actually submitted by another contractor so that it would appear that Asphalt Maintenance was the low bidder. 74. On or about July 2, 2010, Stinson, on behalf of Asphalt Maintenance, sent to Target in Minnesota via interstate mail or wire a bid proposal for the Irving project of $332,896. Asphalt Maintenance s bid proposal for the Irving project was subsequently accepted by Target. 20

21 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 21 of On or about August 20, 2010, LCH transmitted an estimate of its fee for the Irving project, in the amount of $26,632, to Target in Minnesota via interstate mail or wire. 76. Asphalt Maintenance carried out the work on the Irving project in August 2010, ostensibly under the oversight of LCH. However, the quantity of work that Asphalt Maintenance actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, Asphalt Maintenance installed less than one-half of the asphalt and other materials required for the project as defined by LCH and included in Asphalt Maintenance s contract with Target. 77. On or about August 22, 2010, Stinson transmitted to Target in Minnesota, via interstate mail or wire, a waiver of lien form that represented, falsely, that Asphalt Maintenance had completed its scope of work on the Irving project and was entitled to payment of its contract price of $332, On or about September 16, 2010, at the direction or with the consent of Defendant Stinson, Asphalt Maintenance, submitted to Target in Minnesota, via interstate mail or wire, an invoice for the Irving project in the amount of $332,897. This invoice misrepresented the scope of work that Asphalt Maintenance had carried out on the Irving project. This was done pursuant to the Defendants fraudulent scheme. 79. On or about August 23, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Irving project in the amount of $26,632. This invoice sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that Asphalt Maintenance did not actually perform. Upon information and belief, LCH submitted its fraudulent invoice for the Irving project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 21

22 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 22 of Target has paid Asphalt Maintenance $332,897 and LCH $26,632, representing payment in full for the Irving project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. Rose Paving: Cicero, IL (T-0732), Henrietta, NY (T-1157), and Lake Zurich, IL (T-1036) 81. Defendants implemented their fraudulent scheme on at least the following projects that were performed by Rose Paving: Cicero, Illinois (T-0732), Henrietta, New York (T- 1157), and Lake Zurich, Illinois (T-1036). Cicero, Illinois (T-0732) 82. On the Cicero project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work to be done on the Cicero parking lot and defined the quantities of work to be performed in square feet, inches and so on. 83. Subsequently, LCH purported to conduct a competitive bidding process for the Cicero project and received bids from two contractors. LCH and Bailey represented to Target in a communication sent via interstate mail or wire that Rose Paving was the low bidder on the Cicero project. In fact, another contractor was the low bidder. Subsequently, LCH and Bailey transmitted to Target via interstate mail or wire a spread sheet that purported to show the bids that LCH had obtained from contractors on various projects, including Cicero. In that spread sheet, LCH altered the bid that was actually submitted by another contractor so that it would appear that Rose Paving was the low bidder. 22

23 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 23 of On or about June 23, 2010, Rose Paving sent to Target in Minnesota via interstate mail or wire its bid proposal for the Cicero project of $367,145. Rose Paving s bid proposal for the Cicero project was subsequently accepted by Target. 85. On or about July 21, 2010, LCH transmitted an estimate of its fee for the Cicero project, in the amount of $29,372, to Target in Minnesota via interstate mail or wire. 86. Rose Paving carried out the work on the Cicero project in September 2010, ostensibly under the oversight of LCH. However, the quantity of work that Rose Paving actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, Rose Paving only installed approximately two-thirds of the asphalt and other materials required for the project as defined by LCH and included in Rose Paving s contract with Target. 87. On or about October 15, 2010, Rose Paving submitted to Target in Minnesota, via interstate mail or wire, an invoice for the Cicero project in the amount of $367,145. This invoice misrepresented the scope of work that Rose Paving had carried out on the Cicero project. This was done pursuant to the Defendants fraudulent scheme. 88. On or about September 14, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Cicero project in the amount of $29,372. This invoice sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that Rose Paving did not actually perform. Upon information and belief, LCH submitted its fraudulent invoice for the Cicero project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 89. Target has paid Rose Paving $367,145 and LCH $29,372, representing payment in full for the Cicero project. Target would not have made these payments if it had known of 23

24 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 24 of 40 Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. Henrietta, New York (T-1157) 90. On the Henrietta project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work to be done on the Henrietta parking lot and defined the quantities of work to be performed in square feet, inches and so on. 91. On or about June 23, 2010, Rose Paving sent to Target in Minnesota via interstate wire a bid proposal for Phase 1 of the Henrietta project in the amount of $824,000. Subsequently, Rose Paving sent to Target in Minnesota via interstate wire a bid proposal for Phase 2 of the Henrietta project in the amount of $504,610. Rose Paving s bid proposals for the Henrietta project were subsequently accepted by Target. 92. On or about July 21, 2010, LCH transmitted an estimate of its fee for Phase 1 of the Henrietta project, in the amount of $65,920, to Target in Minnesota via interstate mail or wire. 93. Rose Paving carried out the work on the Henrietta project in December 2010, ostensibly under the oversight of LCH. However, the quantity of work that Rose Paving actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target. In fact, Rose Paving installed less than one half of the asphalt and other materials required for the project as defined by LCH and included in Rose Paving s contract with Target. 24

25 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 25 of On or about October 19, 2010, LCH certified to Target in Minnesota, via interstate mail or wire, that Rose Paving had satisfactorily completed its work on the Henrietta project. This certification was false. 95. On or about October 15, 2010 and November 18, 2010, respectively, Rose Paving submitted to Target in Minnesota, via interstate mail or wire, invoices for the Henrietta project in the total amount of $1,328,610. These invoices misrepresented the scope of work that Rose Paving had carried out on the Henrietta project. This was done pursuant to the Defendants fraudulent scheme. 96. On or about October 19, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, invoices for Phase 1 and Phase 2 of the Henrietta project in the amounts of $65,920 and $43,598, respectively. This invoice sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that Rose Paving did not actually perform. Upon information and belief, LCH submitted its fraudulent invoice for the Henrietta project with the knowledge and at the direction of Bailey, pursuant to Defendants scheme to defraud Target. 97. Target has paid Rose Paving $1,328,610 and LCH $109,518, representing payment in full for the Henrietta project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work. Lake Zurich, Illinois (T-1036) 98. On the Lake Zurich project, LCH submitted a Pavement Assessment to Target in Minnesota, via interstate mail or wire. This Pavement Assessment defined the scope of work 25

26 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 26 of 40 to be done on the Lake Zurich parking lot and defined the quantities of work to be performed in square feet, inches and so on. 99. Subsequently, LCH purported to conduct a competitive bidding process for the Lake Zurich project and received bids from two contractors. LCH and Bailey represented to Target in a communication sent via interstate mail or wire that Rose Paving was the low bidder on the Lake Zurich project. In fact, another contractor was the low bidder. Subsequently, LCH and Bailey transmitted to Target via interstate mail or wire a spread sheet that purported to show the bids that LCH had obtained from contractors on various projects, including Lake Zurich. In that spread sheet, LCH altered the bid that was actually submitted by another contractor so that it would appear that Rose Paving was the low bidder On or about July 13, 2010, Rose Paving sent to Target in Minnesota via interstate wire its bid proposal for the Lake Zurich project in the amount of $658,144. Rose Paving s bid proposal for the Lake Zurich project was subsequently accepted by Target On or about July 21, 2010, LCH transmitted an estimate of its fee for the Lake Zurich project, in the amount of $52,652, to Target in Minnesota via interstate mail or wire Rose Paving carried out the work on the Lake Zurich project in October 2010, ostensibly under the oversight of LCH. However, the quantity of work that Rose Paving actually performed was far less than that which it had agreed to do and for which it sought and received payment from Target On or about November 1, 2010, LCH certified to Target in Minnesota that Rose Paving had satisfactorily completed its work on the Lake Zurich project. This certification was false. 26

27 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 27 of On or about October 29, 2010, Rose Paving transmitted to Target in Minnesota via interstate mail or wire a lien waiver form that represented that Rose Paving had completed its work on the Lake Zurich project. On or about November 17, 2010, Rose Paving submitted to Target in Minnesota, via interstate mail or wire, an invoice for the Lake Zurich project in the total amount of $658,144. This invoice misrepresented the scope of work that Rose Paving had carried out on the Lake Zurich project. This was done pursuant to the Defendants fraudulent scheme On or about November 1, 2010, LCH submitted to Target in Minnesota, via interstate mail or wire, its invoice for the Lake Zurich project in the amount of $52,652. This invoice sought payment from Target for work that LCH did not perform, including the oversight and certification of completion of work that Rose Paving did not actually perform. Upon information and belief, LCH submitted its fraudulent invoice for the Lake Zurich project with the knowledge and at the direction of Bailey and Heutzenroeder, pursuant to Defendants scheme to defraud Target Target has paid Rose Paving $658,144 and LCH $52,652, representing payment in full for the Lake Zurich project. Target would not have made these payments if it had known of Defendants fraudulent scheme and Defendants misrepresentations regarding the status of completion of the work Upon information and belief, Defendants scheme to defraud Target began shortly after LCH became a consultant for Target in early It continued until May 2012, when Target terminated its relationships with Defendants. 27

28 CASE 0:12-cv JRT-FLN Document 1 Filed 08/03/12 Page 28 of Upon information and belief, the projects specifically identified herein are not the only ones where Defendants perpetrated their scheme to defraud Target. Discovery will disclose what other projects may also have been involved Paving contractors and individuals other than those named as Defendants may also have participated in Defendants fraudulent scheme While the full extent of Target s damages are not yet known, Target believes that Defendants have obtained millions of dollars from Target through the fraudulent scheme alleged in this Complaint. COUNT ONE CIVIL RICO (ALL DEFENDANTS) 111. The allegations of paragraphs 1 through 110 are incorporated herein by reference and realleged Target is a person within the meaning of 18 U.S.C. 1961(3) Defendants are each persons within the meaning of 18 U.S.C. 1961(3) Defendants are a group of corporations and individuals associated in fact so as to form an enterprise for the purpose of defrauding Target and other victims and for other illicit purposes (hereinafter the Paving Fraud Enterprise) within the meaning of 18 U.S.C. 1961(4) The Paving Fraud Enterprise was engaged in, and its activities affected, interstate commerce Defendants and other employees of the corporate Defendants participated directly or indirectly in the conduct of the affairs of the Paving Fraud Enterprise through a pattern of racketeering activity within the meaning of 18 U.S.C. 1961(5) as described herein, in violation of 18 U.S.C. 1962(c) and (d). 28

Case 1:17-cv VSB Document 1 Filed 05/16/17 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case 1:17-cv VSB Document 1 Filed 05/16/17 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case 1:17-cv-03680-VSB Document 1 Filed 05/16/17 Page 1 of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, DICK

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA UNITED STATES OF AMERICA, ) INFORMATION ) Plaintiff, ) (18 U.S.C. 371) ) (18 U.S.C. 1957) v. ) ) BRETT A. THIELEN, ) ) Defendant. ) THE UNITED STATES

More information

4:10-cv TLW Date Filed 03/18/10 Entry Number 1 Page 1 of 12

4:10-cv TLW Date Filed 03/18/10 Entry Number 1 Page 1 of 12 4:10-cv-00701-TLW Date Filed 03/18/10 Entry Number 1 Page 1 of 12 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION SECURITIES AND EXCHANGE COMMISSION, Plaintiff,

More information

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY : : : : : : : Hon. INDICTMENT

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY : : : : : : : Hon. INDICTMENT UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY UNITED STATES OF AMERICA v. JANELL ROBINSON : : : : : : : Hon. Criminal No. 18-18 U.S.C. 981(a)(1)(C), 1341, 1346, 1349, 1951(a) and 2; and 28 U.S.C.

More information

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS AUSTIN DIVISION. Case No.

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS AUSTIN DIVISION. Case No. UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS AUSTIN DIVISION, Individually and on behalf of all others similarly situated, Plaintiff, v. MANITEX INTERNATIONAL, INC., DAVID J. LANGEVIN, DAVID

More information

Case 2:18-cv SJF-AYS Document 3 Filed 06/28/18 Page 1 of 7 PageID #: 7

Case 2:18-cv SJF-AYS Document 3 Filed 06/28/18 Page 1 of 7 PageID #: 7 Case 2:18-cv-03745-SJF-AYS Document 3 Filed 06/28/18 Page 1 of 7 PageID #: 7 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK CIVIL DIVISION LORETTA A. ALLBERRY, } ON BEHALF OF HERSELF

More information

FILED US DISTRICT COURT

FILED US DISTRICT COURT Case 4:09-cv-00447-JLH Document 1 Filed 06/18/2009 Page 1 of 12 JOHN RICKE FILED US DISTRICT COURT EASTERN DISTRICT ARKANSAS UNITED STATES DISTRICT COURT FOR JUN 81009 THE EASTERN DISTRICT OF ARKANSAS

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, VASCO DATA SECURITY INTERNATIONAL, INC., T. KENDALL

More information

Courthouse News Service

Courthouse News Service Case 2:33-av-00001 Document 6395 Filed 08/17/2009 Page 1 of 21 Trisha M. Connors, Esq. ZISA & HITSCHERICH 77 HUDSON STREET HACKENSACK, NEW JERSEY 07601 (201) 342-1103 Attorneys for Plaintiffs PERRY MUGNO

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION. No. INDICTMENT UNDER SEAL COUNT ONE

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION. No. INDICTMENT UNDER SEAL COUNT ONE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA vs. BARRY CROALL and RONALD FORD No. Violations: Title 18, United States Code, Sections 371, 666 and

More information

Artisan Contractors Application

Artisan Contractors Application Artisan Contractors Application All questions must be answered in full. Application must be signed and dated by the applicant. APPLICANT S NAME AND MAILING ADDRESS AGENT / PRODUCER INFORMATION APPLICANT

More information

Case 2:18-cv Document 3 Filed 06/07/18 Page 1 of 8 PageID #: 7 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK CIVIL DIVISION

Case 2:18-cv Document 3 Filed 06/07/18 Page 1 of 8 PageID #: 7 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK CIVIL DIVISION Case 2:18-cv-03340 Document 3 Filed 06/07/18 Page 1 of 8 PageID #: 7 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK CIVIL DIVISION NICHOLAS GIORDANO, } ON BEHALF OF HIMSELF AND } ALL

More information

UNITED STATES DISTRICT COURT MIDDLE DISTRICTOF FLORIDA. Plaintiff. Defendants. CLASS ACTIONCOMPLAINT

UNITED STATES DISTRICT COURT MIDDLE DISTRICTOF FLORIDA. Plaintiff. Defendants. CLASS ACTIONCOMPLAINT PLAINTIFF, Individually and On Behalf of All Others Similarly Situated, v. UNITED STATES DISTRICT COURT MIDDLE DISTRICTOF FLORIDA Plaintiff, WALTER INVESTMENT MANAGEMENT CORPORATION, GEORGE M. AWAD, DENMAR

More information

EVENT PARTY OR WEDDING PLANNER SUPPLEMENTAL APPLICATION

EVENT PARTY OR WEDDING PLANNER SUPPLEMENTAL APPLICATION EVENT PARTY OR WEDDING PLANNER SUPPLEMENTAL APPLICATION Applicant s Name TO BE USED WITH COMMERCIAL GENERAL LIABILITY APPLICATION (ACORD 125) All questions must be answered in full. Application must be

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION. Plaintiff, Defendants

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION. Plaintiff, Defendants UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION 1 1, Individually and on Behalf of All Others Similarly Situated, vs. Plaintiff, THE CRYPTO COMPANY, MICHAEL ALCIDE POUTRE III,

More information

Case 2:18-cv Document 3 Filed 10/10/18 Page 1 of 11 PageID #: 11

Case 2:18-cv Document 3 Filed 10/10/18 Page 1 of 11 PageID #: 11 Case 2:18-cv-05664 Document 3 Filed 10/10/18 Page 1 of 11 PageID #: 11 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK CIVIL DIVISION STEPHANIE HEATON, } ON BEHALF OF HERSELF AND } ALL

More information

MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION

MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION CLAIMS MADE AND REPORTED FORM WITH OPTIONAL COMMERCIAL GENERAL LIABILITY OCCURRENCE FORM AND/OR COMMERCIAL PROPERTY COVERAGE ALL QUESTIONS MUST BE ANSWERED

More information

Commercial General Liability Application

Commercial General Liability Application Commercial General Liability Application All questions must be answered in full. Application must be signed and dated by the applicant. Applicant s Name Agent Applicant Mailing Address Applicant s Phone

More information

COUNT ONE (The Tax Shelter Fraud Conspiracy) Background

COUNT ONE (The Tax Shelter Fraud Conspiracy) Background UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - x UNITED STATES OF AMERICA : -v- : FELONY INFORMATION DOMENICK DEGIORGIO, : 05 Cr.

More information

Courthouse News Service

Courthouse News Service IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILIINOIS EASTERN DIVISION ) UNITED STATES SECURITIES ) AND EXCHANGE COMMISSION, ) ) Plaintiff, ) ) CIVIL ACTION v. ) FILE NO. ) SCOTT M.

More information

Case 5:09-cr D Document 1 Filed 04/16/09 Page 1 of 8

Case 5:09-cr D Document 1 Filed 04/16/09 Page 1 of 8 DAB UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION UNITED STATES OF AMERICA V. I N D I C T MEN T SCOTT ARTHUR WADDELL The Grand Jury charges that: INTRODUCTION

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA UNITED STATES SECURITIES AND EXCHANGE COMMISSION. Plaintiff, vs. Civil Action No.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA UNITED STATES SECURITIES AND EXCHANGE COMMISSION. Plaintiff, vs. Civil Action No. Case 1:18-mi-99999-UNA Document 3221 Filed 09/28/18 Page 1 of 27 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA UNITED STATES SECURITIES AND EXCHANGE COMMISSION Plaintiff, vs. RUSSELL CRAIG,

More information

Employee Leasing/Temporary Employment Agency Application

Employee Leasing/Temporary Employment Agency Application Employee Leasing/Temporary Employment Agency Application All questions must be answered in full. Application must be signed and dated by the applicant. Applicant s Name Agent Applicant Mailing Address

More information

muia'aiena ED) wnrn 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA

muia'aiena ED) wnrn 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 2:15cw05146CA&JEM Document 1 fled 07/08/15 Page 1 of 15 Page ID #:1 1 2 3 4 6 8 UNITED STATES DISTRICT COURT 9 CENTRAL DISTRICT OF CALIFORNIA 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 on

More information

Case 3:17-cv VAB Document 1 Filed 02/02/17 Page 1 of 16 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT. v. ) Civil Action No.

Case 3:17-cv VAB Document 1 Filed 02/02/17 Page 1 of 16 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT. v. ) Civil Action No. Case 3:17-cv-00155-VAB Document 1 Filed 02/02/17 Page 1 of 16 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT ) SECURITIES AND EXCHANGE COMMISSION, ) ) Plaintiff, ) ) v. ) Civil Action No. ) MARK

More information

UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND (Greenbelt Division) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND (Greenbelt Division) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) UNITED STATES DISTRICT COURT DISTRICT OF MARYLAND (Greenbelt Division PLAINTIFF, Individually and on Behalf of All Others Similarly Situated, v. TERRAFORM POWER, INC. 7550 Wisconsin Ave. 9th Floor Bethesda,

More information

Case 3:12-cr HZ Document 25 Filed 04/24/13 Page 1 of 7 Page ID#: 37 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON

Case 3:12-cr HZ Document 25 Filed 04/24/13 Page 1 of 7 Page ID#: 37 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON Case 3:12-cr-00108-HZ Document 25 Filed 04/24/13 Page 1 of 7 Page ID#: 37 FILED24 APR J 1312;18HSTIC ljrp IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OREGON PORTLAND DIVISION UNITED STATES

More information

Case 2:18-cv Document 3 Filed 10/16/18 Page 1 of 10 PageID #: 15

Case 2:18-cv Document 3 Filed 10/16/18 Page 1 of 10 PageID #: 15 Case 2:18-cv-05774 Document 3 Filed 10/16/18 Page 1 of 10 PageID #: 15 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK CIVIL DIVISION Kyle A. Page, } On behalf of Himself } All Others

More information

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT. Plaintiff, COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT. Plaintiff, COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES LAWS UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT PLAINTIFF, on behalf of itself and all others similarly situated, Civ. A. No. CLASS ACTION v. Plaintiff, COMPLAINT FOR VIOLATIONS OF THE FEDERAL SECURITIES

More information

Case 1:18-cv MKB-RML Document 5 Filed 06/22/18 Page 1 of 8 PageID #: 14

Case 1:18-cv MKB-RML Document 5 Filed 06/22/18 Page 1 of 8 PageID #: 14 Case 1:18-cv-03628-MKB-RML Document 5 Filed 06/22/18 Page 1 of 8 PageID #: 14 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NEW YORK CIVIL DIVISION JAROSLAW T. WOJCIK, } ON BEHALF OF HIMSELF

More information

MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION

MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION CLAIMS MADE AND REPORTED FORM WITH OPTIONAL COMMERCIAL GENERAL LIABILITY OCCURRENCE FORM AND/OR COMMERCIAL PROPERTY COVERAGE ALL QUESTIONS MUST BE ANSWERED

More information

Case 2:18-cv TC Document 1 Filed 11/13/18 Page 1 of 36

Case 2:18-cv TC Document 1 Filed 11/13/18 Page 1 of 36 Case 2:18-cv-00892-TC Document 1 Filed 11/13/18 Page 1 of 36 Thomas L. Simek, tsimek@cftc.gov Jennifer J. Chapin, jchapin@cftc.gov Attorneys for Plaintiff COMMODITY FUTURES TRADING COMMISSION 4900 Main

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION UNITED STATES OF AMERICA ) No. ) v. ) Violations: Title 18, United ) States Code, Sections 2, 666, STUART LEVINE, ) 1341, 1343,

More information

Case 7:18-cv NSR Document 1 Filed 08/23/18 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. JURY TRIAL DEMANDED vs.

Case 7:18-cv NSR Document 1 Filed 08/23/18 Page 1 of 6 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. JURY TRIAL DEMANDED vs. Case 7:18-cv-07683-NSR Document 1 Filed 08/23/18 Page 1 of 6 BARSHAY SANDERS, PLLC 100 Garden City Plaza, Suite 500 Garden City, New York 11530 Tel: (516) 203-7600 Fax: (516) 706-5055 Email: ConsumerRights@BarshaySanders.com

More information

Convenience Store Application

Convenience Store Application Convenience Store Application All questions must be answered in full. Application must be signed and dated by the applicant. Applicant s Name Agent Applicant Mailing Address Applicant s Phone Number Web

More information

Commercial General Liability Application

Commercial General Liability Application > Commercial General Liability Application All questions must be answered in full. Application must be signed and dated

More information

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION ) ) ) ) ) ) ) ) ) ) ) COMPLAINT IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF TENNESSEE NASHVILLE DIVISION FORBA HOLDINGS, LLC, Plaintiff, v. ZURICH AMERICAN INSURANCE CO., Defendant. Civil Action No: COMPLAINT Comes

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Plaintiff R.J. Zayed ( Plaintiff or Receiver ), through his undersigned counsel

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Plaintiff R.J. Zayed ( Plaintiff or Receiver ), through his undersigned counsel CASE 0:11-cv-01319-MJD -FLN Document 1 Filed 05/20/11 Page 1 of 14 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA R.J. ZAYED, In His Capacity as Court- Appointed Receiver for Trevor G. Cook, et al.,

More information

Courthouse News Service

Courthouse News Service Case :0-cv-00-SRB Document Filed 0//00 Page of 0 JOHN M. McCOY III (Cal. Bar No. ) Email: mccoyj@sec.gov DAVID S. BROWN (Cal. Bar No. ) Email: browndav@sec.gov Attorneys for Plaintiff Securities and Exchange

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA. Case No.

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA. Case No. Case 2:15-cv-05427-MAK Document 1 Filed 10/01/15 Page 1 of 18 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF PENNSYLVANIA STEVEN P. MESSNER, Individually and On Behalf of All Others Similarly Situated,

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA Case :-cv-0-cjc-jc Document Filed /0/ Page of Page ID #: 0 KENNETH J. GUIDO, Cal. Bar No. 000 E-mail: guidok@sec.gov Attorney for Plaintiff Securities and Exchange Commission 0 F Street, N.E. Washington,

More information

Corporate Directors and Officers Liability, Employment Practices Liability and Fiduciary Liability

Corporate Directors and Officers Liability, Employment Practices Liability and Fiduciary Liability USLI.COM 888-523-5545 Corporate Directors and Officers Liability, Employment Practices Liability and Fiduciary Liability THE ANSWER All questions must be answered and application must be signed by the

More information

Case 1:18-cv Document 1 Filed 03/15/18 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. : : Plaintiffs, : : vs.

Case 1:18-cv Document 1 Filed 03/15/18 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK. : : Plaintiffs, : : vs. Case 118-cv-02319 Document 1 Filed 03/15/18 Page 1 of 14 UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK x GLENN EISENBERG, on Behalf of Himself and All Others Similarly Situated, Plaintiffs,

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA. ) Civil Action No. ) CV-03-J-0615-S. Defendants. )

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA. ) Civil Action No. ) CV-03-J-0615-S. Defendants. ) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SECURITIES AND EXCHANGE COMMISSION, ) ) Plaintiff, ) vs. HEALTHSOUTH CORPORATION ) AND RICHARD M. SCRUSHY, ) ) Defendants. ) ) ) Civil Action No.

More information

Case 1:09-cr RJL Document 3 Filed 12/11/09 Page 1 of 15 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:09-cr RJL Document 3 Filed 12/11/09 Page 1 of 15 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Case 109-cr-00349-RJL Document 3 Filed 12/11/09 Page 1 of 15 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Holding a Criminal Term Grand Jury Sworn in on November 16, 2009 UNITED STATES OF

More information

Hired and Non-Owned Liability Supplemental Application All questions must be answered in full. Application must be signed and dated by the applicant.

Hired and Non-Owned Liability Supplemental Application All questions must be answered in full. Application must be signed and dated by the applicant. Agency Name: Address: Contact Name: Phone: Fax: Email: Applicant s Name Hired and Non-Owned Liability Supplemental Application All questions must be answered in full. Application must be signed and dated

More information

Roofing Supplemental Application

Roofing Supplemental Application Roofing Supplemental Application TO BE USED WITH COMMERCIAL GENERAL LIABILITY APPLICATION (ACORD 125) All questions must be answered in full. Application must be signed and dated by the applicant. APPLICANT

More information

CV 01,496 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. ROGER DAVIDSON, on behalf of himself ' and all others similarly situated,

CV 01,496 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK. ROGER DAVIDSON, on behalf of himself ' and all others similarly situated, ROGER DAVIDSON, on behalf of himself ' and all others similarly situated, UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CIVIL ACTION No. CV 01,496 V. Plaintiff, CLASS ACTION COMPLAINT FOR

More information

Part One Small Firm Application for Miscellaneous Professionals Liability

Part One Small Firm Application for Miscellaneous Professionals Liability Part One Small Firm Application for Miscellaneous Professionals Liability Contractors Bonding and Insurance Company Peoria, Illinois 61615 This application applies to firms with revenues less than $1,000,000.

More information

us OJ $TRICT COUR-1 RIO/\

us OJ $TRICT COUR-1 RIO/\ Case 6:16-cr-00178-RBD-TBS Document 1 Filed 09/13/16 Page 1 of 10 PageID 1 FILED UNITED STATES OF AMERICA UNITED STATES DISTRICT COURTZUI& SEP I 3 PH ~: 28 MIDDLE DISTRICT OF FLORIDA ORLANDO DIVISION us

More information

Plaintiff, JURY TRIAL DEMANDED. Defendants. CLASS ACTION COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS

Plaintiff, JURY TRIAL DEMANDED. Defendants. CLASS ACTION COMPLAINT FOR VIOLATION OF THE FEDERAL SECURITIES LAWS UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. PLAINTIFF, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, JURY TRIAL DEMANDED FARMLAND PARTNERS INC.,

More information

Case 1:16-cv BCW Document 2 Filed 05/26/16 Page 1 of 9

Case 1:16-cv BCW Document 2 Filed 05/26/16 Page 1 of 9 Case 1:16-cv-00059-BCW Document 2 Filed 05/26/16 Page 1 of 9 Daniel J. Wadley (10358) wadleyd@sec.gov Amy J. Oliver (8785) olivera@sec.gov Attorneys for Plaintiff Securities and Exchange Commission 351

More information

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA SECURITIES AND EXCHANGE COMMISSION, v. Plaintiff Civil Action No. 09-cv-0063-PD JOSEPH S. FORTE and JOSEPH FORTE, L.P., Defendants.

More information

Convenience Store Application

Convenience Store Application Convenience Store Application All questions must be answered in full. Application must be signed and dated by the applicant. Applicant s Name Agent Applicant Mailing Address Applicant s Phone Number Web

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA MISSOULA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA MISSOULA DIVISION Case 9:13-cr-00034-DWM Document 24 Filed 02/23/14 Page 1 of 6 TIMOTHY J. RACICOT Assistant U.S. Attorney U.S. Attorney s Office P.O. Box 8329 Missoula, MT 59807 105 E. Pine, 2d Floor Missoula, MT 59802

More information

Case 1:17-cv LMB-TCB Document 1 Filed 06/20/17 Page 1 of 21 PageID# 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA

Case 1:17-cv LMB-TCB Document 1 Filed 06/20/17 Page 1 of 21 PageID# 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA Case 1:17-cv-00696-LMB-TCB Document 1 Filed 06/20/17 Page 1 of 21 PageID# 1 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF VIRGINIA JEREMY A. LANGLEY, Individually and On Behalf of All Others Similarly

More information

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff, Defendants. CLASS ACTION COMPLAINT

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Plaintiff, Defendants. CLASS ACTION COMPLAINT UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN ROBERT STROUGO, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff, ROADRUNNER TRANSPORTATION SYSTEMS INC., MARK A. DIBLASI,

More information

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA NO. CLASS ACTION COMPLAINT

IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA NO. CLASS ACTION COMPLAINT IN THE UNITED STATES DISTRICT COURT DISTRICT OF ARIZONA BLOOMFIELD, INC., on behalf of itself and all others similarly situated, Plaintiff, v. SYNTAX-BRILLIAN CORP., VINCENT SOLLITTO, JR., JAMES LI and

More information

Case 2:13-cr LDD Document 24 Filed 06/19/13 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

Case 2:13-cr LDD Document 24 Filed 06/19/13 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA Case 2:13-cr-00253-LDD Document 24 Filed 06/19/13 Page 1 of 10 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA UNITED STATES OF AMERICA : DATE: 6-19-13 v. : CRIMINAL NO.: 13

More information

Case 1:13-cv PLM Doc #8 Filed 12/23/13 Page 1 of 17 Page ID#44

Case 1:13-cv PLM Doc #8 Filed 12/23/13 Page 1 of 17 Page ID#44 Case 1:13-cv-01338-PLM Doc #8 Filed 12/23/13 Page 1 of 17 Page ID#44 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION JOHN P. HUNTER and BRIAN HUDSON, for themselves and class

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS (Kansas City Docket) Case No. 09- I N D I C T M E N T COUNT ONE THE CONSPIRACY

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS (Kansas City Docket) Case No. 09- I N D I C T M E N T COUNT ONE THE CONSPIRACY IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS (Kansas City Docket) UNITED STATES OF AMERICA ) ) Plaintiff, ) ) v. ) ) ) aka Bill Washington ) and ) EMMA JEAN HOLMES, ) ) Defendants. )

More information

MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION

MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION MISCELLANEOUS PROFESSIONAL LIABILITY APPLICATION CLAIMS MADE AND REPORTED FORM ALL QUESTIONS MUST BE ANSWERED IN FULL. APPLICATION MUST BE SIGNED AND DATED BY THE PRINCIPAL, OFFICER OR PARTNER Applicant

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA. Case No.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA. Case No. Case 1:18-cv-00830-ELR Document 1 Filed 02/23/18 Page 1 of 82 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA NORMAN MACPHEE, Individually and On Behalf of All Others Similarly Situated, v. Plaintiff,

More information

Case 3:17-cv Document 1 Filed 06/30/17 Page 1 of 10

Case 3:17-cv Document 1 Filed 06/30/17 Page 1 of 10 Case :-cv-0 Document Filed 0/0/ Page of 0 JEFFREY KALIEL (CA ) TYCKO & ZAVAREEI LLP L Street, NW, Suite 00 Washington, DC 00 Telephone: (0) -000 Facsimile: (0) -00 jkaliel@tzlegal.com ANNICK M. PERSINGER

More information

THE SURETY & FIDELITY ASSOCIATION OF AMERICA MEMORANDUM

THE SURETY & FIDELITY ASSOCIATION OF AMERICA MEMORANDUM THE SURETY & FIDELITY ASSOCIATION OF AMERICA MEMORANDUM TO: FROM: RE: Government Affairs Advisory Committee Daniel Wanke Contract Surety Legislation DATE: June 3, 2016 There are 11 states and the District

More information

CARRIER: Applicant s name: City: State: Zip code: Website address: address of primary contact:

CARRIER: Applicant s name: City: State: Zip code: Website address:  address of primary contact: CARRIER: This application is for a Claims Made policy. Please read your policy carefully. Defense costs shall be applied against the deductible (except in New York). Applicant may qualify for an INSTANT

More information

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION SECURITIES AND EXCHANGE COMMISSION, Plaintiff, vs. ENI, S.p.A. and SNAMPROGETTI NETHERLANDS B.V., Defendants. Civil Action No. 4:10-cv-2414

More information

Case 2:16-cv Document 1 Filed 09/22/16 Page 1 of 16 Page ID #:1

Case 2:16-cv Document 1 Filed 09/22/16 Page 1 of 16 Page ID #:1 Case :-cv-0 Document Filed 0// Page of Page ID #: 0 R. GABRIEL D. O MALLEY, MA BAR # (Email: gabriel.o malley@cfpb.gov) (Phone: 0--) SARAH PREIS, DC BAR # (Email: sarah.preis@cfpb.gov) (Phone: 0--) PATRICK

More information

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION. Case No.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION. Case No. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION PLAINTIFF, Individually and On Behalf of All Others Similarly Situated, Plaintiff, V. AZZ, INC., THOMAS E. FERGUSON, and PAUL

More information

Paintball Field/Course Supplemental Application

Paintball Field/Course Supplemental Application Agency Name: Address: Contact Name: Phone: Fax: Email: Paintball Field/Course Supplemental Application TO BE USED WITH COMMERCIAL GENERAL LIABILITY APPLICATION (ACORD 125) All questions must be answered

More information

Case 3:13-cr KI Document 1 Filed 07/16/13 Page 1 of 9 Page ID#: 1 UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION

Case 3:13-cr KI Document 1 Filed 07/16/13 Page 1 of 9 Page ID#: 1 UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION ;.I Case 3:13-cr-00332-KI Document 1 Filed 07/16/13 Page 1 of 9 Page ID#: 1 UNDER SEAL UNITED STATES DISTRICT COURT DISTRICT OF OREGON UNITED STATES OF AMERICA, PORTLAND DIVISION 0033~ Case No. 3:13-CR

More information

8:18-cv DCC Date Filed 01/03/18 Entry Number 1 Page 1 of 12

8:18-cv DCC Date Filed 01/03/18 Entry Number 1 Page 1 of 12 8:18-cv-00014-DCC Date Filed 01/03/18 Entry Number 1 Page 1 of 12 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA ANDERSON/GREENVILLE DIVISION JONATHAN ALSTON and DARIUS REID, individually

More information

FILED JAN ~ ATTORNEY FOR PLAINTIFF UNITED STATES OF AMERICA IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA BILLINGS DIVISION

FILED JAN ~ ATTORNEY FOR PLAINTIFF UNITED STATES OF AMERICA IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA BILLINGS DIVISION Case 1:14-cr-00001-SPW Document 1 Filed 01/16/14 Page 1 of 12 CARL E. ROSTAD Assistant U.S. Attorney U.S. Attorney's Office P.O. Box 3447 Great Falls, Montana 59403-3447 Direct Line: (406) 771-2001 Phone:

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA THE UNITED STATES GRAND JURY CHARGES THAT: INTRODUCTION

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA THE UNITED STATES GRAND JURY CHARGES THAT: INTRODUCTION UNITED STATES OF AMERICA, v. UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA Plaintiff, (1}KALIN THANH DAO, (2)NGHIA TRONG DAO, and (3)THU NGUYET LE, Defendants. ) INDICTMENT ) (18 U.S.C. ) (18 U.S.C.

More information

Case 2:14-cv JFW-MRW Document 24 Filed 03/12/15 Page 1 of 8 Page ID #:91

Case 2:14-cv JFW-MRW Document 24 Filed 03/12/15 Page 1 of 8 Page ID #:91 Case :-cv-00-jfw-mrw Document Filed 0// Page of Page ID #: 0 DAVID R. ZARO (BAR NO. ) TED FATES (BAR NO. 0) TIM C. HSU (BAR NO. ) ALLEN MATKINS LECK GAMBLE MALLORY & NATSIS LLP South Figueroa Street, Ninth

More information

2G17 SEP 2 6 Prl 3 22 UNITED STATES OF AMERICA,('--,,; _.._ "9RIMINAL NO. 3:17CFJ:lj._J_/ftfn

2G17 SEP 2 6 Prl 3 22 UNITED STATES OF AMERICA,('--,,; _.._ 9RIMINAL NO. 3:17CFJ:lj._J_/ftfn Case 3:17-cr-00220-JAM Document 14 Filed 09/26/17 Page 1 of 8 UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT FILED N-16-2 2G17 SEP 2 6 Prl 3 22 UNITED STATES OF AMERICA,('--,,; _.._ "9RIMINAL NO.

More information

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Plaintiff(s) Case No: 09-cv-3332 MJD/JJK

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA. Plaintiff(s) Case No: 09-cv-3332 MJD/JJK Case 0:09-cv-03332-MJD-JJK Document 352 Filed 07/23/10 Page 1 of 12 UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA U.S. COMMODITY FUTURES TRADING COMMISSION, v. Plaintiff(s) Case No: 09-cv-3332 MJD/JJK

More information

Complaint for Violation of the Federal Securities Laws (Nadler v. Clarent Corp., et al., Case No. C BZ)

Complaint for Violation of the Federal Securities Laws (Nadler v. Clarent Corp., et al., Case No. C BZ) Complaint for Violation of the Federal Securities Laws (Nadler v. Clarent Corp., et al., Case No. C-01-3406-BZ Source: Milberg Weiss Date: 09/07/01 Time: 3:57 PM MILBERG WEISS BERSHAD HYNES & LERACH LLP

More information

Case 3:18-cv Document 1 Filed 10/25/18 Page 1 of 23 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

Case 3:18-cv Document 1 Filed 10/25/18 Page 1 of 23 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA Case :-cv-0 Document Filed 0// Page of Lesley Elizabeth Weaver (0) BLEICHMAR FONTI & AULD LLP th Street, Suite 00 Oakland, CA 0 Telephone: () -00 Facsimile: () -00 lweaver@bfalaw.com Counsel for Plaintiff

More information

Case 1:14-cr PLM Doc #1 Filed 07/24/14 Page 1 of 13 Page ID#1 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

Case 1:14-cr PLM Doc #1 Filed 07/24/14 Page 1 of 13 Page ID#1 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION Case 1:14-cr-00136-PLM Doc #1 Filed 07/24/14 Page 1 of 13 Page ID#1 UNITED STATES OF AMERICA, vs. Plaintiff, UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION GREGORY A. DERUE,

More information

Plaintiff brings this securities fraud action individually on behalf of himself

Plaintiff brings this securities fraud action individually on behalf of himself UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ---------------------------------------------------------x On Behalf of Himself and All Others Similarly Situated, Plaintiff, --against-- C. A.

More information

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION Case 1:17-cv-02405-CAP Document 1 Filed 06/27/17 Page 1 of 59 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION RANDALL RICHARDSON and JANITORIAL TECH, LLC, Individually

More information

Case 3:17-cr HEH Document 12 Filed 07/19/17 Page 1 of 8 PageID# 27

Case 3:17-cr HEH Document 12 Filed 07/19/17 Page 1 of 8 PageID# 27 Case 3:17-cr-00083-HEH Document 12 Filed 07/19/17 Page 1 of 8 PageID# 27 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division UNITED STATES OF AMERICA v. VICTOR M.

More information

Case 1:19-cv Document 1 Filed 01/16/19 Page 1 of 18 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK

Case 1:19-cv Document 1 Filed 01/16/19 Page 1 of 18 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Case 1:19-cv-00448 Document 1 Filed 01/16/19 Page 1 of 18 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK Bureau of Consumer Financial Protection and the People of the State of

More information

Machinery, Equipment And Rigging Supplemental Application

Machinery, Equipment And Rigging Supplemental Application Machinery, Equipment And Rigging Supplemental Application TO BE USED WITH COMMERCIAL GENERAL LIABILITY APPLICATION (ACORD 125) All questions must be answered in full. Application must be signed and dated

More information

I. GENERAL INFORMATION 1. Name of Applicant: a. Principle Address: b. Policy Contact Name & Title. c. Contact Address: II. WORKFORCE INFORMATION

I. GENERAL INFORMATION 1. Name of Applicant: a. Principle Address: b. Policy Contact Name & Title. c. Contact  Address: II. WORKFORCE INFORMATION Name of Insurance Company to which Application is made A capital stock company (the Insurer ) Wage and Hour Edge (SM) APPLICATION Wage and Hour Liability Insurance Notices: If a policy is issued, defense

More information

Convenience Store Application

Convenience Store Application > Convenience Store Application All questions must be answered in full. Application must be signed and dated by the applicant.

More information

Case: 1:14-cv Document #: 3 Filed: 04/11/14 Page 1 of 18 PageID #:20

Case: 1:14-cv Document #: 3 Filed: 04/11/14 Page 1 of 18 PageID #:20 Case: 1:14-cv-02646 Document #: 3 Filed: 04/11/14 Page 1 of 18 PageID #:20 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION WILLIAM C. BRAMAN, MARK MENDELSON,

More information

U.S. DEPARTMENT OF JUSTICE ANTITRUST DIVISION. National Tax Liens Association

U.S. DEPARTMENT OF JUSTICE ANTITRUST DIVISION. National Tax Liens Association Presentation By The U.S. DEPARTMENT OF JUSTICE ANTITRUST DIVISION To National Tax Liens Association February 26, 2015 DISCLAIMER: The views expressed in this presentation are not purported to reflect those

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND * * * * * * * * * * ******* SECOND SUPERSEDING INDICTMENT

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND * * * * * * * * * * ******* SECOND SUPERSEDING INDICTMENT MWC:USAO# 2013R00394 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND UNITED STATES OF AMERICA v. MICHAEL WESTBROOK, ANTHONY SIMPSON, and BENJAMIN BLAND Defendants * * * * * * * * * * *******

More information

Case 1:18-cv AJT-MSN Document 1 Filed 08/16/18 Page 1 of 16 PageID# 1

Case 1:18-cv AJT-MSN Document 1 Filed 08/16/18 Page 1 of 16 PageID# 1 Case 1:18-cv-01034-AJT-MSN Document 1 Filed 08/16/18 Page 1 of 16 PageID# 1 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division STACY P. CHITTICK, 108 Lake Cook

More information

2: 16-cv GMN-NJK

2: 16-cv GMN-NJK ,, Case 2:16-cv-0-GMN-NJK Document 1 Filed 0/15/16 Page 1 of 1 1 Susan B. Padove, Senior Trial Attorney Susan Gradman, Chief Trial Attorney 2 Division of Enforcement U.S. Commodity Futures Trading Commission

More information

Case 1:18-cv LTS-DCF Document 1 Filed 01/11/18 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO.

Case 1:18-cv LTS-DCF Document 1 Filed 01/11/18 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. Case 1:18-cv-00262-LTS-DCF Document 1 Filed 01/11/18 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK BLESSINGS, INC. D/B/A BLESSINGS SEAFOOD A/KA BLESSING AND BLESSING SEAFOOD, Plaintiff,

More information

Case 2:18-cv MCE-CMK Document 1 Filed 03/22/18 Page 1 of 25 1

Case 2:18-cv MCE-CMK Document 1 Filed 03/22/18 Page 1 of 25 1 Case :-cv-00-mce-cmk Document 1 Filed 0// Page 1 of 1 JINA L. CHOI (N.Y. Bar No. ) ERIN E. SCHNEIDER (Cal. Bar No. ) STEVEN D. BUCHHOLZ (Cal. Bar No. ) Email: buchholzs@sec.gov JOHN P. MOGG (Cal. Bar No.

More information

Plaintiff Securities and Exchange Commission (the Commission), for its Complaint

Plaintiff Securities and Exchange Commission (the Commission), for its Complaint GEORGE S. CANELLOS Regional Director JACK KAUFMAN PHILIP MOUSTAKIS Attorneys for Plaintiff SECURITIES AND EXCHANGE COMMISSION New York Regional Office 3 World Financial Center Suite 400 New York, NY 10281

More information

BEFORE THE HEARING BOARD OF THE ILLINOIS ATTORNEY REGISTRATION AND DISCIPLINARY COMMISSION ANSWER

BEFORE THE HEARING BOARD OF THE ILLINOIS ATTORNEY REGISTRATION AND DISCIPLINARY COMMISSION ANSWER BEFORE THE HEARING BOARD OF THE ILLINOIS ATTORNEY REGISTRATION AND DISCIPLINARY COMMISSION In the Matter of: JUSTIN JOSEPH TEDROWE, Attorney-Respondent, Comm. No. 2014PR00091 No. 2804905. ANSWER COUNT

More information

CLASS ACTION COMPLAINT

CLASS ACTION COMPLAINT Case 1:15-cv-06002-GHW Document 1 Filed 07/30/15 Page 1 of 54 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK THE EMPLOYEES RETIREMENT SYSTEM OF THE CITY OF MONTGOMERY, on behalf of itself and

More information

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION

UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION Case :-cv-0 Document Filed 0// Page of Page ID #: 0 ALANNA B. CARBIS (CA Bar No. 0) alanna.carbis@cfpb.gov LEANNE HARTMANN (CA Bar No. ) leanne.hartmann@cfpb.gov 00 G Street, NW Washington, DC 0 Telephone:

More information

Case 1:08-cr Document 3 Filed 08/07/2008 Page 1 of 18 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

Case 1:08-cr Document 3 Filed 08/07/2008 Page 1 of 18 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Case 1:08-cr-00246 Document 3 Filed 08/07/2008 Page 1 of 18 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, : CRIMINAL NO. Plaintiff, VIOLATION: 18 U.S.C. 371 and 15

More information