The RICO Enterprise and the Racketeering Actors
Accountability Matrix

Every person, entity, role, and proof path

Compare the record-linked conduct, source citation, focused proof clips, and full filings. Open a name for the complete dossier.

Tyler Brandon Davis

49% minority member of TopDevz; owner/controller of Porter Consulting, Mason Building & Design, and other entities.

Principal organizer Primary cite: ¶¶37–41

Record-linked conduct

  • embezzled $750,000 from Porter Consulting via three 2017 bank wires, then called it his "personal investment" to obtain his 49% stake. ¶¶214–224
  • obtained a $328,300 PPP loan for Porter and laundered $37,240 of it through Mason into TopDevz as a "capital call." ¶¶237–246
  • gave false sworn testimony ("I put in 100% of the capital"), producing Interim Order No. 4 granting him 95.308% and "managing member" status. ¶¶256,261

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Scott R. Carpenter

Attorney (formerly Cummins & White, LLP); Davis’s arbitration counsel.

Legal cover Primary cite: ¶¶42–46

Record-linked conduct

  • seized TopDevz’s Wells Fargo account on Jan. 7, 2022 by emailing false statements to the bank. ¶¶265–268
  • emailed forged stock certificates showing Davis at 95.308% and assembled Davis’s "managing member" declarations. ¶¶475,358–360
  • His own Feb. 5, 2021 email conceded the dispute belonged in Superior Court — yet the arbitration was maintained. ¶252

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J. Douglas Kirk

Attorney (Kirk & Toberty).

Legal cover Primary cite: ¶¶47–53

Record-linked conduct

  • represented TopDevz "without any lawful authority" (Nov. 2022–Mar. 2023), filing pleadings while knowing Davis was not the lawful manager. ¶49
  • that unauthorized appearance amounts to forgery (Cal. Penal Code §470) and subornation of perjury (§127). ¶¶50,52
  • recruited by Carpenter and received $30,000+ in fees traced to the account. ¶¶51,53

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Joseph W. Scalia

Attorney (solo practitioner); Davis’s lead arbitration counsel, 2021–2023.

Legal cover Primary cite: ¶¶54–57

Record-linked conduct

  • submitted "over 600 pages of falsified tax returns" as arbitration evidence and presented testimony he knew was false. ¶¶56,258
  • maintained the arbitration in a "prohibited venue" after acknowledging in writing that the Superior Court had exclusive jurisdiction. ¶56
  • received "hundreds of thousands of dollars" in fees from the funds at issue. ¶57

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Joshua Paul Lintz

Former TopDevz COO (hired by Rajaee, 2020); later incorporated Talentcrowd.

Operational executor Primary cite: ¶¶58–63

Record-linked conduct

  • incorporated Talentcrowd (Feb. 8, 2022) as the laundering/operating vehicle — testified he did so "with the express authorization of Davis." ¶¶60,316
  • destroyed evidence — helped seize servers and "permanently deleted over 130 TopDevz client projects" from Jira on May 26, 2022. ¶¶291–296
  • received $722,335.83 in direct payments from the fraudulent Chase account. ¶62

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Amanda Frye

Former TopDevz Director of Accounts; now CEO of Talentcrowd.

Operational executor Primary cite: ¶¶64–67

Record-linked conduct

  • downloaded the entire Zoho Recruit database on Jan. 14, 2022 and exfiltrated files to a personal Gmail. ¶¶279–280
  • directed contractors via Slack to migrate from TopDevz to the look-alike domain / Talentcrowd. ¶289
  • boasted Talentcrowd "logged almost 90k hours" in year one (~$10–12M from stolen assets). ¶322

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Melissa Garcia

Former TopDevz Manager of Accounts Payable; now CAO of Talentcrowd.

Operational executor Primary cite: ¶¶68–72

Record-linked conduct

  • downloaded 3,784 confidential files (Jan. 6–14, 2022) on Davis’s direct orders. ¶278
  • Davis testified he told her "to download as much information as humanly possible." ¶¶72,277
  • used stolen accounting data to generate fraudulent invoices; now runs Talentcrowd billing. ¶71

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Micah L. Bailey

Attorney (Purdy & Bailey, LLP); counsel for the Talentcrowd group.

Post-theft legal support Primary cite: ¶¶73–77

Record-linked conduct

  • told the court (Feb. 2, 2023) there was "no evidence" trade secrets had been transferred to Talentcrowd, "despite overwhelming evidence to the contrary." ¶76
  • continued representation after repeated notices of the underlying conduct. ¶76
  • received $4,135+ from the account plus Talentcrowd fees. ¶77

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D. Edward Hays

Attorney (Marshack Hays LLP); entered post-petition (2023).

Bankruptcy-fraud architect Primary cite: ¶¶78–82

Record-linked conduct

  • "architect" of the bankruptcy-fraud schemes; filed declarations (Apr. 2024) swearing Davis is "the managing member of TopDevz." ¶¶81,391,394
  • moved to convert the case to Chapter 7 on false representations and orchestrated the settlements and sale to Davis. ¶81
  • transmitted the forged "Unanimous Written Consent" of TopDevz members. ¶81

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Siarra Wood

Rajaee’s former personal/executive assistant (2016–2022).

Intelligence / evidence Primary cite: ¶¶83–86

Record-linked conduct

  • accessed Rajaee’s personal Gmail without authorization beginning ~Feb. 2021. ¶¶85,298
  • monitored attorney-client communications and reported Rajaee’s legal strategy to Davis. ¶¶85–86
  • deleted exculpatory evidence Rajaee needed for his defense. ¶298

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Talentcrowd, LLC

Wyoming LLC formed Feb. 8, 2022; sold to GBQ ~Feb. 2025.

Instrumentality Primary cite: ¶¶102–107

Record-linked conduct

  • "primary vehicle for laundering proceeds" and operating the stolen TopDevz business. ¶¶102–107
  • seeded with $838,554.30 in wires from the fraudulent Chase account. ¶329

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GBQ Partners LLC

Ohio accounting/advisory firm; acquired Talentcrowd ~Feb. 2025.

Successor participant Primary cite: ¶¶87–101

Record-linked conduct

  • acquired Talentcrowd with knowledge of the pending theft litigation and retained the original principals. ¶¶87–101
  • "continues to exploit" the stolen database, pled as ongoing post-petition violations. ¶¶432–438

Direct filing proof

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TopDevz, LLC

The company at the center of the case (formed May 9, 2017).

Nominal defendant Primary cite: ¶¶115–119

Record-linked conduct

  • Named as a nominal defendant — the company whose control sits at the center of the case and whose authority chain is mapped through the record. ¶¶115–119

Direct filing proof

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SA

Sergio Patrick Antonucci

Identified in filings as having coordinated with Davis to pressure Rajaee during the bankruptcy; held Rajaee’s power of attorney over the Davis litigation; later arrested in Kenya for a gold fraud.

Associated actor Primary cite: Bankr. Doc 210

Record-linked conduct

  • Per a sworn bankruptcy filing, took 100% power of attorney over Rajaee’s litigation (June 23, 2022) and cut him off from his own counsel. Doc 210 ¶8
  • Arrested in Kenya and charged with defrauding a businessman of $1,271,200.74 in a fake gold deal (public reporting). News · Doc 210 ¶10

Direct filing proof

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RT

Robert Orville Thomas

Identified in filings as having coordinated with Davis to pressure Rajaee; presented as an "international attorney" / "Lord"; per a sworn filing, is neither.

Associated actor Primary cite: Bankr. Doc 210; UK SRA

Record-linked conduct

  • Per Rajaee’s sworn declaration, posed as an "international attorney," "organized crime fighter," and "Lord" and was retained via Astute Dynamic, Ltd. Doc 210 ¶7
  • Sworn statement that he "is not an attorney or a Lord" and obtained ~$2M while "posing as an attorney." Doc 210 ¶9
  • Subject of an open UK Solicitors Regulation Authority case (RGC-000132373) — the proceeding that can bar him from working in/with a law firm. UK SRA

Direct filing proof

This dossier currently relies on the cited filing passages and any focused proof clips below.

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Jesse S. Finlayson

Attorney at Finlayson Toffer Roosevelt & Lilly LLP; counsel for Chapter 7 trustee Christopher R. Barclay.

Chapter 7 trustee counsel Primary cite: Bankr. ECF 124; ECF 288; Consolidated Appendix Ex. 90

Record-linked conduct

  • signed the ECF 124 motion asking the Bankruptcy Court to approve four settlements and the trustee's execution of the TopDevz Unanimous Written Consent. Bankr. ECF 124, pp. 1-2, 29
  • trustee-counsel fee applications record calls and emails with Hays and Carpenter about resolution options, dismissal, and related state-court matters. Consolidated Appendix Ex. 90, Bates 3052-3054, 3155-3156, 3198-3199
  • signed the ECF 288 sale motion proposing a $100,000 sale of the defensive appellate rights and TopDevz interest to Davis and TopDevz. Bankr. ECF 288, pp. 1, 4-8, 31

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Christopher R. Barclay

Chapter 7 trustee appointed after conversion in Bankruptcy Case No. 24-00617-CL7.

Chapter 7 trustee Primary cite: Bankr. ECF 124; ECF 197; ECF 288

Record-linked conduct

  • signed the October 15, 2024 TopDevz Unanimous Written Consent solely in his capacity as Chapter 7 trustee; the instrument states its signers constitute all TopDevz members. Bankr. ECF 124, pp. 47-48
  • proposed abandoning the defensive appellate rights and TopDevz interest, listing the property at $0.00. Bankr. ECF 197, pp. 1, 4-6
  • later proposed selling those assets to Davis and TopDevz for $100,000 after their joint opposition to abandonment. Bankr. ECF 211, pp. 1-5; ECF 288, pp. 1, 4-8

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