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
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
Accounting professional; ECF 63 alleges she served as Porter Consulting’s CFO or de facto CFO and as an administrative agent for Davis-controlled entities.
ECF 63 alleges that in a February 26, 2024 federal filing made on her behalf, she stated she provided accounting services to Davis and his companies. ECF 63 ¶103A
ECF 63 alleges, on information and belief, that she served from inception as TopDevz’s agent of record and agent for service of process, and as agent for service for Mason and other Davis entities. ECF 63 ¶103A
ECF 63 alleges that between May 8 and May 24, 2017 she supplied agreement templates to TopDevz, received Operating Agreement revisions, and transmitted the signed Operating Agreement page and membership certificates reflecting a 51/49 structure. ECF 63 ¶103C
California attorney (Miller Miller Gerber LLP); counsel for Amanda Frye in San Diego Superior Court Case No. 37-2022-00012247. ECF 63 limits his alleged role to conduct from February 1, 2024 on.
§ 1962(d) only (as pleaded)
Primary cite: ECF 63 ¶¶119A–119E
Record-linked conduct
ECF 63 alleges he appeared remotely on May 12, 2023 for the moving defendants, including Frye, when the San Diego Superior Court stayed the action and discovery. ECF 63 ¶119A
ECF 63 alleges that on October 27 and November 13, 2023, Rajaee sent him notice letters and materials; ECF 63 states these notices establish receipt, not the truth of every characterization in them. ECF 63 ¶119D
ECF 63 alleges he signed a January 29, 2024 anti-SLAPP motion and a February 1, 2024 joinder adopting a motion to dismiss in Case No. 3:24-cv-00001-RSH-KSC. ECF 63 ¶119E
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
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
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
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
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
