Usacomplaints.com » Business & Finance » Complaint / Review: Pacific West Equity - PWEF Mortgage Fraud? By the biggest scamme. #457780

Complaint / Review
Pacific West Equity
PWEF Mortgage Fraud? By the biggest scamme

Dear Sir or Madam:
Please accept this letter as a formal complaint against the following names and companies, I am over the age of 18, and make this complaint based on personal knowledge

1. Pacific West Equity & Financial and Investment Group, aka (PWEF) aka Pacific West Equity & Financial aka Pacific Entertainment Financing aka Pacific West Business Lending aka Pacific West Equity Private Capital aka Pacific West Equity Venture Partners aka Loancenter1's Investment aka Loancenter1's aka Venture Capital aka Ventureden, is doing business as a Mortgage Broker / Lender at 600 Anton Blvd, Suite 1100, Costa Mesa, California 92626 and 670 Rolling Green Dr, Las Vegas, NV 89169 and 300 Park Ave, Suite 1700, New York, NY 10022 [email protected]

2. Robin R Thompson, aka Rob R Thompson aka Rob Thompson aka Robin Thompson is a Mortgage Broker who is a resident of and practicing his profession at 600 Anton Blvd, Suite 1100, Costa Mesa, California 92626 and 670 Rolling Green Dr, Las Vegas, NV 89169 and 300 Park Ave, Suite 1700, New York, NY 10022 [email protected].

3. Nuway Venture LLC aka Nuway Venture is doing business as a Broker / Lender at 600 Anton Blvd, Suite 1100, Costa Mesa, California 92626 and 670 Rolling Green Dr, Las Vegas, NV 89169 and 300 Park Ave, Suite 1700, New York, NY 10022 [email protected].

4. Lamon Holloway, aka L Holloway is a Mortgage Broker and is doing business at 600 Anton Blvd, Suite 1100, Costa Mesa, California 92626 and 670 Rolling Green Dr, Las Vegas, NV 89169 and 300 Park Ave, Suite 1700, New York, NY 10022 [email protected].

5. Don Hayes, aka D. R Hayes, is an Appraiser / Real Estate Broker who is a resident of and practicing his profession at 600 Anton Blvd, Suite 1100, Costa Mesa, California 92626 and 670 Rolling Green Dr, Las Vegas, NV 89169 and 300 Park Ave, Suite 1700, New York, NY 10022 [email protected].

6. Susan Montgomery, aka S Montgomery, is a Investment Banker / Mortgage Broker / Underwriter who is a resident of and practicing her profession at 600 Anton Blvd, Suite 1100, Costa Mesa, California 92626 and 670 Rolling Green Dr, Las Vegas, NV 89169 and 300 Park Ave, Suite 1700, New York, NY 10022 [email protected].

7. Barons Investment & Trust Service, aka Barons Investment aka Barons Investment & Trust, is doing business as a Lender at 600 Anton Blvd, Suite 1100, Costa Mesa, California 92626 and 670 Rolling Green Dr, Las Vegas, NV 89169 and 300 Park Ave, Suite 1700, New York, NY [email protected]

The enterprise

8. At various times material to this complaint, pacific west equity & financial and investment group, aka (pwef) aka pacific west equity & financial aka pacific entertainment financing aka pacific west business lending aka pacific west equity private capital aka pacific west equity venture partners aka loancenter1's investment aka loancenter1's aka venture capital aka ventureden, robin r. Thompson aka rob r thompson aka robin thompson aka rob thompson, don r hayes aka d. R HAYES, BARONS INVESTMENT & TRUST SERVICE aka BARONS INVESTMENT & TRUST aka BARONS INVESTMENT, SUSAN MONTGOMERY, aka S MONTGOMERY, NUWAY VENTURE LLC aka NUWAY VENTURE, LAMON HOLLOWAY aka L HOLLOWAY (collectively "Defendants"), and others known and unknown to me, were members and associates of an organization whose members engaged in, among other things, conspiracy to commit bank fraud, conspiracy to commit wire fraud, conspiracy to launder money, wire fraud, bank fraud and money laundering. At all relevant times, this organization operated in the Southern District of California and elsewhere. The organization and the individuals who associate with it for criminal purposes constitute an "Enterprise, " as defined by Title 18, United States Code, Section 1961 (4) (hereinafter the "Enterprise"), that is a group of individuals associated in fact. The Enterprise constituted an ongoing organization whose members functioned as a continuing unit for the common purpose of achieving the objectives of the Enterprise. The Enterprise was engaged in, and it's activities affected, interstate and foreign commerce.

Purpose of the enterprise

9. The Enterprise has a Call Center located in Costa Mesa, CA. This Call Center is structured as a boiler room, which is a rented space with desks, telephones and trained scam artists who place hundreds of calls daily to people all across the country. They use a number of different scams but each one is designed to steal and defraud the people, the banks and the taxpayers' money.

10. The Enterprise knows that the person calling their phone numbers doesn't know that. The caller is under the impression that they are calling a legitimate lender/investor, but the truth is that they are not. They are calling a boiler room set up to scam.

11. The Enterprise sells credit and foreclosure orientation services, which require consumers to enroll in a one-year membership club and pay an upfront $575 application fee, $50 enrollment fee and a monthly fee of $69-89, as well as a final success fee that ranges from four to five percent of the loan amount. Although the defendants purport to provide credit services, they have never registered with the CA Secretary of State, or any other State in that matter, as a credit services organization, as required by law.

12. The Enterprise advertises in the yellow and white pages, and online that they will finance anyone that the bank would not.

13. The advertisements are listed without addresses and require use of toll free numbers.

14. The Enterprise is advertised under 21 different names to be able to confuse and defraud its victims.

15. The purposes of the Enterprise included, but are not limited to, the following:
a. Enriching the members of Enterprise through, among other things, the fraudulent mortgages, purchases of real estate and the laundering of proceeds derived from these fraudulent transactions.
B. Fraudulently purchasing properties with mortgages amounting to 125 percent of the purchase price of the properties, thus ensuring that the members of the Enterprise do not have any money at risk in the fraudulent transactions.
C. Recruiting and controlling individuals in every key position relative to the fraudulent financing of real estate, that is, mortgage brokers, real estate agents, real estate companies, escrow agents, escrow companies, real estate appraisers, and loan underwriters for the purposes of limiting the Enterprise members' exposure to criminal liability and maximizing the members' financial gain.

16. Upon information and belief, the defendants and their associates devised and executed scheme and artifice to defraud by fraudulently inducing lenders to provide loans to individuals who could not legitimately qualify for those loans and to fund loans in amounts which exceeded the value of the real property being purchased. Among the means and methods by which the defendants executed the scheme to defraud, and by which the defendants conducted and participated in the conduct of the affairs of the criminal Enterprise, were the following:
a. Members of the Enterprise used the Multiple Listing Service ("MLS") and other methods of identifying properties for sale throughout Southern California and elsewhere that had been on the market for an extended period of time and/or for which the original asking price had been reduced.
B. Members of the Enterprise recruited "straw buyers" to purchase the identified properties, that is, individuals who allowed their names, credit history and other personal information to be used to obtain loans and purchase properties in name only on behalf of the Enterprise.
C. Members of the Enterprise prepared and submitted offers to purchase the identified properties which substantially exceeded the asking price for those properties.
D. Members of the Enterprise hired real estate appraisers to prepare inflated appraisals for the identified properties; the inflated appraisals were then used to fraudulently induce lenders to believe that the loans being given to the "straw buyers" would be fully secured by the value of the properties being purchased.
E. Members of the Enterprise prepared and submitted false loan applications for the "straw buyers" in order to induce lenders to make loans to persons and at terms that the lenders otherwise would not have funded.
F. Members of the Enterprise prepared and submitted false documents and information in response to lender verification inquiries, including "CPA letters, " verification of employment forms, verification of rent forms and "discrepancy letters."
g. Members of the Enterprise ensured that the "straw buyers" purchased the identified properties with mortgages amounting to 125 percent of the purchase price of the property, thus ensuring that the defendants did not have any money at risk in the fraudulent transactions.
H. Members of the Enterprise arranged to have the amount of money that exceeded the asking price (i.E., the "kickback amount") paid at the close of escrow to a shell construction company maintained by the Enterprise.
I. Members of the Enterprise falsely informed the lenders that the "kickback amount" would be used to pay for construction upgrades to the identified properties, thereby falsely inducing the lenders to believe that the entire loan amount would be secured by the value of the identified properties.
J. Members of the Enterprise used the "kickback amount" for personal enrichment, that is, funds were disbursed from the shell construction company maintained by the Enterprise to members and associates of the Enterprise as payment for those individuals' participation in the fraudulent scheme.
K. Members of the Enterprise owned, established and utilized real estate businesses and escrow companies to facilitate the purchase of the identified properties by the "straw buyers" and to generate income for the Enterprise by collecting real estate transaction fees, that is, credit report fees, broker processing fees, broker underwriting fees, broker application fees, notary fees, escrow fees, appraisal fees, broker commissions and transaction coordinator fees, in connection with the purchase of the identified properties.
L. Members of the Enterprise, including the "straw buyers, " would fail to make the required mortgage payments for the fraudulently purchased properties, thereby allowing those properties to go into foreclosure and which resulted in financial loss to the lenders.
FRAUD IN THE INDUCEMENT AND
THE ROLES OF THE DEFENDANTS

At various times material to this complaint, the defendants had the following roles in the Enterprise.

17. Enterprise through it's member/appraiser, Don R. Hayes, misleads and defrauds the consumer by showing up at the properties seeking the finance and/or to be purchased and prepares inflated appraisals for the identified properties. At the same time, to justify the excessive upfront fees the Enterprise charges.

18. On or about January 14 Enterprise issued a Letter of Interest citing an obligation for $36,517, 500.00 to Pacific West Equity & Financial and Investment Group, attached hereto as Exhibit "A".

19. On or about January 15 Enterprise issued a letter of Proof Of Funds which shows a balance of $1.8 billion in Pacific West Equity & Financial and Investment Group's account, signed by Susan Montgomery, attached hereto as Exhibit "B".

20. That on or about January 16 Enterprise seduced me to pay $35,000.00 in order to be able to obtain a Commitment Letter, attached hereto as Exhibit "C.

21. Nevertheless, to seduce me into paying the $35,000.00 all at once, the Enterprise committed Corporate and Mortgage Fraud among other violations set forth below.
A. Falsification of financial information, including false accounting entries, issuing bogus letter of Proof Of Funds which shows a balance of $1.8 billion in Pacific West Equity & Financial And Investment Group's account.
B. Corporate Fraud involve the following activities:
(1) Falsification of financial information, including false accounting entries, bogus trades designed to inflate profit or hide losses, and false transactions designed to evade regulatory oversight;
(2) Self-dealing by corporate insiders, including:
(a) Insider Trading;
(b) Kickbacks;
(c) Misuse of corporate property for personal gain; and,
(d) Individual tax violations related to self-dealing;
(3) Fraud in connection with an otherwise legitimately-operated mutual or hedge fund (including, falsification of net asset values, and other fraudulent, abusive trading practices by, within, and involving a mutual or hedge fund); and,
(4) Obstruction of justice designed to conceal the above-noted types of criminal conduct.

22. To seduce me further, Robin R. Thompson, through a phone conversation, stated,
You are in a good hands. We are going to make it happen for you. We do this all day long. We make any size loans. We're in the real estate business. We do it all. We've been purchasing homes and properties all over the place with a 125% LTV of the purchase price and we don't risk our own money.

We have full access to the MLS and websites to place this real estate for sale for our group and we have in house real estate mortgage brokers, escrow agents, appraisers and loan underwriters to be able to control the transactions and to not pay a third party.
We make sure that our lender makes the loan, even though sometimes the individuals cannot qualify for those loans, but with our work we get 125% LTV of the real property being purchased. Our in house staff prepares and submits the loan documents to be funded.
These properties we're talking about have been on the market for a while and the owners keep reducing the asking price and this is when we come in with our people and purchase these properties, just like I told you.
We have someone obtain the loan and purchase the property with their name and their credit on our behalf. If he doesn't keep up with the payment of the mortgage, it's not our problem. We even make money from that. One of the ways we do it is that we make offers and purchase the properties over the asking price and our in-house appraiser, underwriter and everyone else does their part. Then, the lenders fund the loans, even though most of the time it's very hard to fund.
Everyone gets paid their share at the closing. The full loan gets funded assuming we're going to be putting the difference in upgrading the property.
The extra funds go to our construction company to do the upgrades. This is when we make the money. So if you know anybody who wants to buy a property and cannot qualify, I will be more than happy to help, just like I told you

23. The Enterprise, to seduce me to pay $35,000.00, sent a letter on January 16 with a closing date for January 30, attached hereto as Exhibit "D".

24. They knew full well that I was relying on their representations and the proof of funds letter and that the loan would be funded from those funds.

25. On March 2 the Enterprise informed me that there would not be a closing and there is no money to fund the loan and my $35,000.00 was earned.

26. Numerous demands were made to fully refund the deposit, from March 3 through and including today's date, as is established by numerous emails.in addition, despite these numerous demands, the Enterprise refused to REFUND the upfront fee deposit.

27. During the course of approximately three (3) months, they fraudulently induced me to pay in excess of $35,000.00 by falsely stating and representing that prior to issuing a Commitment Letter, I must pay this amount and that these monies would be listed as a credit on the closing statement.

28. The Enterprise knew that the statements were false because they never intended to give credit, as represented to me. They knew that the statements were false because they never issued a Commitment Letter, as represented to me.

29. The Enterprise knew full well that I was relying on their representations to obtain a loan and that the loan would be funded from their account and upon complaining to the Better Business Bureau, below is what they reported on their website. The Better Business Bureau report, on it's website, indicates:

On March 30th we requested information from the company concerning their relationship with Barons Investment & Trust, in which they claim to have some $1.3 billion dollars in brokerage accounts. Our concern was heightened because the administrative contact for Barons Investment & Trust listed Robin Thompson, the principal of Pacific West Equity & Financial on its website, www.baronsinvestments.com, Also, we could find no record of a corporation or any brokerage firm under the name Barons Investment & Trust. The company responded to our request stating that they will contact Barons to find out why Robin Thompson's name is listed as the administrative contact on their website. The company also said that it does not know what type of information Barons Investment has or does not have, and they don't know if they are required to be registered with the Securities and Exchange Commission. The administrative contact's name on the website of Barons Investment & Trust has changed, but we are still very concerned that the funds claimed to be held by Barons Investment may not exist.

30. That the Enterprise intended for me to rely on their false statements and representations and were intentionally fraudulent and deceitful in order for them to manipulate and steal my money for their own personal use.

31. That the Enterprise manipulates and steals the publics' and the banks' money. Moreover, purchasing among other things, the most expensive cars and private jets for their own personal use. Attached hereto as Exhibit "E" and F, photos of the model of cars and jets the Enterprise owns.in addition to, this photo, I believe that Robin R Thompson in the picture is telling his victims that he's above the law and his scams are paying off.

32. At various times material to this complaint, the defendants had the following roles in the Enterprise:
a. Robin R. Thompson acted as the leader of the Enterprise and had oversight responsibility for the recruitment of the charging of upfront fees and dealing with potential clients, including but not limited to straw buyers" and their purchase of real property. Don R. Hayes is associated with Pacific West Equity & Financial And Investment Group, a business operated by Thompson.
B. Robin R. Thompson and other members of the Enterprise used Don R Hayes to facilitate the fraudulent purchase of real estate and charging of upfront fees.in particular, Don R Hayes recruited "straw buyers" and had them use Pacific West Equity & Financial And Investment Group to process their real estate transactions.
C. Robin R. Thompson and Lamon Holloway established a business known as Venture Capital, a subsidiary of Nuway Venture LLC, a business owned and operated by Lamon Holloway and other members of the Enterprise. Defendants then utilized Venture Capital to conduct fraudulent real estate transactions.
D. As the leader of the Enterprise, Robin R. Thompson also maintained bank accounts in the name of Pacific West Equity & Financial at Wachovia Mutual Bank, FA, Lake Elsinore City Center Financial Center, 31600 Grape St., CA 7104, Lake Elsinore, CA 92532 and also at California Bank & Trust, Temecula Office, 41619 Winchester Rd., Temecula, CA 92590.
E. Robin R. Thompson and other members of the Enterprise used these accounts to obtain and disburse the proceeds of their fraudulent activities. During the time period of this complaint, over $15,000, 000 in proceeds from the illegal activities of the Enterprise were deposited into the above-noted accounts maintained by Robin R. Thompson.
F. Don R Hayes also used his status as a long-standing member of the Costa Mesa Park Street Gang to recruit some of the "straw buyers" and to maintain discipline within the Enterprise.
G. Don R Hayes practices as an appraiser / real estate broker in the State of California. For a flat fee of $25,000 per month, Don R Hayes allows Robin R Thompson and Lamon Holloway to gain access to the MLS and to conduct fraudulent real estate transactions on behalf of the Enterprise. Susan Montgomery submitted false verification of fund forms in connection with some of the fraudulent real estate transactions.in addition to the $15,000 monthly payment, Susan Montgomery also obtains the real estate agent's commission and broker's fees in connection with real estate purchases made and or a percentage of the up front fees collected on behalf of the Enterprise.
H. During the time period of this complaint, Susan Montgomery obtained over $1,000, 000 in proceeds from the fraudulent activities of the Enterprise.
I. Lamon Holloway was employed at real estate businesses in Nevada, which were used by members of the Enterprise to facilitate the fraudulent purchases of identified properties. As employee at those businesses, he prepared and submitted false loan applications on behalf of "straw buyers", in addition to preparing and/or submitting false information in response to lender verification inquiries, including false letters from tax advisers ("CPA letters"), (investment company) verification of employment forms, verification of rent forms and "discrepancy letters."

The racketeering conspiracy

33. Beginning in or about January and continuing up to and including May 8, within the Southern District of California and elsewhere, the Defendants, PACIFIC WEST EQUITY & FINANCIAL AND INVESTMENT GROUP, aka (PWEF) aka PACIFIC WEST EQUITY & FINANCIAL aka PACIFIC ENTERTAINMENT FINANCING aka PACIFIC WEST BUSINESS LENDING aka PACIFIC WEST EQUITY PRIVATE CAPITAL aka PACIFIC WEST EQUITY VENTURE PARTNERS aka LOANCENTER1'S INVESTMENT aka LOANCENTER1'S aka VENTURE CAPITAL aka VENTUREDEN, ROBIN R. Thompson aka rob r thompson aka robin thompson aka rob thompson, don r hayes aka d. R HAYES, BARONS INVESTMENT & TRUST SERVICE aka BARONS INVESTMENT & TRUST aka BARONS INVESTMENT, SUSAN MONTGOMERY, aka S MONTGOMERY, NUWAY VENTURE LLC aka NUWAY VENTURE, LAMON HOLLOWAY aka L HOLLOWAY and others known and unknown to me, being persons employed by and associated with the Enterprise (as defined above), which Enterprise was engaged in, and the activities of which affected interstate and foreign commerce, did knowingly and intentionally conspire with each other, and with other persons, to violate Title 18, United States Code, Section 1962 (c), that is, to conduct and participate, directly and indirectly, in the conduct of the Enterprise's affairs through a pattern of racketeering activity involving multiple acts indictable under the following provisions of federal law:
a. Title 18, United States Code, Section 1343 (wire fraud);
b. Title 18, United States Code, Section 1344 (bank fraud);
c. Title 18, United States Code, Sections 1956 (h) and 1957 (conspiracy to launder money); and
d. Title 18, " United States Code, Section 1957 (money
laundering).

34. It was a further part of the conspiracy that each Defendant agreed that a conspirator would commit at least two acts of racketeering activity in the conduct of the affairs of the Enterprise.

Overt acts

35.in furtherance of the conspiracy and to accomplish the objects of the conspiracy, the Defendants and their coconspirators committed the following overt acts, among others, in Costa Mesa, CA, within the Southern District of California, and elsewhere, on or about the dates set forth below:
a. On or about February 5, defendant, ROBIN R. THOMPSON, caused a wire transfer in the amount of $35,000.00 to be issued to defendant PACIFIC WEST EQUITY & FINANCIAL AND INVESTMENT GROUP.
B. On or about February 5, defendant, NUWAY VENTURE LLC, caused a wire transfer in the amount of $35,000.00 to be issued to defendant PACIFIC WEST EQUITY & FINANCIAL AND INVESTMENT GROUP.
C. On or about February 5, defendant, LAMON HOLLOWAY, caused a wire transfer in the amount of $35,000.00 to be issued to defendant PACIFIC WEST EQUITY & FINANCIAL AND INVESTMENT GROUP.
D. On or about February 5, defendant, DON R HAYES, caused a wire transfer in the amount of $35,000.00 to be issued to defendant PACIFIC WEST EQUITY & FINANCIAL AND INVESTMENT GROUP.
E. On or about February 5, defendant, SUSAN MONTGOMERY, caused a wire transfer in the amount of $35,000.00 to be issued to defendant PACIFIC WEST EQUITY & FINANCIAL AND INVESTMENT GROUP.
F. On or about February 5, defendant, BARONS INVESTMENT & TRUST SERVICE, caused a wire transfer in the amount of $35,000.00 to be issued to defendant PACIFIC WEST EQUITY & FINANCIAL AND INVESTMENT GROUP.

36. On or about January 15, defendant BARONS INVESTMENT & TRUST SERVICE issued and submitted a " Proof Of Funds " letter for defendant Pacific West Equity & Financial and Investment Group in connection with charging up front fees.

37. On or about January 15, defendant SUSAN MONTGOMERY signed and submitted a " Proof Of Funds " letter for defendant Pacific West Equity & Financial and Investment Group in connection with charging up front fees.

38. On or about January 15 Robin R Thompson caused a "Letter of Explanation for Terms and Conditions of Offer" to be sent in connection with the charging up front fees, which required a payment to Pacific West Equity & Financial and Investment Group.

39. At all the times herein, defendant Don R Hayes prepared and submitted all appraisals for all financing and or the purchases.
All in violation of Title 18, United States Code, Section 1962 (d).

Forfeiture allegation

40. All of the allegations contained in this complaint are hereby realleged and incorporated by reference herein as though fully set forth for the purpose of alleging forfeiture pursuant to the provisions of Title 18, United States Code, Section 1963. Pursuant to Federal Rules of Criminal Procedure, Rule 32.2, notice is hereby given to the above-named defendants that I'm seeking forfeiture as part of any sentence in accordance with Title 18, United States Code, Section 1963 in the event of any defendant's conviction under this Code.
A. Any and all interests defendants, pacific west equity & financial and investment group, aka (pwef) aka pacific west equity & financial aka pacific entertainment financing aka pacific west business lending aka pacific west equity private capital aka pacific west equity venture partners aka loancenter1's investment aka loancenter1's aka venture capital aka ventureden, robin r. Thompson aka rob r thompson aka robin thompson aka rob thompson, don r hayes aka d. R HAYES, BARONS INVESTMENT & TRUST SERVICE aka BARONS INVESTMENT & TRUST aka BARONS INVESTMENT, SUSAN MONTGOMERY, aka S MONTGOMERY, NUWAY VENTURE LLC aka NUWAY VENTURE, LAMON HOLLOWAY aka L HOLLOWAY have acquired and maintained in violation of Title 18, United States Code, Section 1962, which interests are subject to forfeiture to the United States pursuant to Title 18, United States Code, Section 1963 (a) (1); and
b. Any and all interest in, security of, claims against, property or contractual rights of any kind affording a source of influence over, of defendants PACIFIC WEST EQUITY & FINANCIAL AND INVESTMENT GROUP, aka (PWEF) aka PACIFIC WEST EQUITY & FINANCIAL aka PACIFIC ENTERTAINMENT FINANCING aka PACIFIC WEST BUSINESS LENDING aka PACIFIC WEST EQUITY PRIVATE CAPITAL aka PACIFIC WEST EQUITY VENTURE PARTNERS aka LOANCENTER1'S INVESTMENT aka LOANCENTER1'S aka VENTURE CAPITAL aka VENTUREDEN, ROBIN R. Thompson aka rob r thompson aka robin thompson aka rob thompson, don r hayes aka d. R HAYES, BARONS INVESTMENT & TRUST SERVICE aka BARONS INVESTMENT & TRUST aka BARONS INVESTMENT, SUSAN MONTGOMERY, aka S MONTGOMERY, NUWAY VENTURE LLC aka NUWAY VENTURE, LAMON HOLLOWAY aka L HOLLOWAY which afford a source of influence over, the Enterprise described herein which the defendants established, operated, controlled, conducted, and participated in the conduct of, in violation of Title 18, United States Code, Section 1962, which interests, securities, claims, and rights are subject to forfeiture to the United States pursuant to Title 18, United States Code, Section 1963 (a) (2) ; and
c. Any and all property of defendants pacific west equity & financial and investment group, aka (pwef) aka pacific west equity & financial aka pacific entertainment financing aka pacific west business lending aka pacific west equity private capital aka pacific west equity venture partners aka loancenter1's investment aka loancenter1's aka venture capital aka ventureden, robin r. Thompson aka rob r thompson aka robin thompson aka rob thompson, don r hayes aka d. R HAYES, BARONS INVESTMENT & TRUST SERVICE aka BARONS INVESTMENT & TRUST aka BARONS INVESTMENT, SUSAN MONTGOMERY, aka S MONTGOMERY, NUWAY VENTURE LLC aka NUWAY VENTURE, LAMON HOLLOWAY aka L HOLLOWAY constituting and derived from proceeds obtained, directly and indirectly, from the racketeering activity described in this complaint, in violation of Title 18, United States Code, Section 1952, which property is subject to forfeiture to the United States pursuant to Title 18, United States Code, Section 1963 (a) (3).

41. The interests of the defendants subject to forfeiture to the United States pursuant to Title 18, United States Code, Sections 1963 (a) (1), (a) (2) and (a) (3), include but are not limited to all interests and proceeds traceable thereto. Each of the defendants is jointly and severally liable for the forfeiture obligations alleged above. If any of the above-described forfeitable property, as a result of any act or omission of the defendants:
a. Cannot be located upon the exercise of due diligence;
b. Has been transferred or sold to, or deposited with, a
third person;
c. Has been placed beyond the jurisdiction of the Court;
d. Has been substantially diminished in value; or
e. Has been commingled with other property which cannot
be subdivided without difficulty, it is my intent, jointly with your office, pursuant to Title 18, United States Code, Section 1963 (m), to seek forfeiture of any other property of said defendants up to the value of the above forfeitable property. All pursuant to Title 18, United States Code, Section 1963.

WHEREFORE, I, respectfully request that this office:
a) Orders this Enterprise to seize its businesses in California and or elsewhere forthwith.
B) Freezes all bank accounts this Enterprise owns and operates out of.
C) Indicts this Enterprise for all this as defined by Title 18, United States Code, Section 1961 (4), Section 1962 (c), Section 1343, Section 1344, Sections 1956 (h), Section 1957,1962 (d), Sections 1963 (a) (1), (a) (2) and (a) (3).
D) Sentences the entire Enterprise to the maximum term under these guidelines.
E) Orders said Defendants to refund my deposit in the sum of the $35,000.00, plus interest, to be refunded as part of any sentence in accordance with Title 18, United States Code.

DATED this 11th day of May.

Ripoff buster
San Jose
Costa Rica


Offender: Pacific West Equity

Country: USA   State: California   City: Costa Mesa
Address: 600 Anton Blvd, Suite 1100
Phone: 5629720762

Category: Business & Finance

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