People, entities, records, and roles
The RICO Enterprise and the Racketeering Actors
A record-first map of the people, companies, authority chain, and court filings. Open any dossier to move from the act, to the citation, to the underlying PDF.
Follow the 11-record authority chain
The central authority question
Who could lawfully act for TopDevz?
The record is clearest in this order: establish the governing rule, show what each participant knew, identify the substitute placed in the record, and then follow the orders that depended on it.
- 11
- linked record checkpoints
- 24
- focused proof clips
- 19
- people and entities mapped
People at the center
Each face opens a complete accountability dossier
Principal organizer
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
Legal cover
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
Legal cover
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
Legal cover
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
Operational executor
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
Operational executor
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
Operational executor
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
Post-theft legal support
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
Bankruptcy-fraud architect
"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
Intelligence / evidence
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
SA
Associated actor
Per a sworn bankruptcy filing, took 100% power of attorney over Rajaee’s litigation (June 23, 2022) and cut him off from his own counselDoc 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
RT
Associated actor
Per Rajaee’s sworn declaration, posed as an "international attorney," "organized crime fighter," and "Lord" and was retained via Astute Dynamic, LtdDoc 210 ¶7
Sworn statement that he "is not an attorney or a Lord" and obtained ~$2M while "posing as an attorney."Doc 210 ¶9
Bankruptcy record participants
Two additional roles tied directly to the consent and sale records
These dossiers use the participants' filed motions, signatures, billing entries, and court orders. They are separated here so the reader can distinguish a docketed role from a pleaded predicate category.
Chapter 7 trustee counsel
signed the ECF 124 motion asking the Bankruptcy Court to approve four settlements and the trustee's execution of the TopDevz Unanimous Written ConsentBankr. 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 mattersConsolidated Appendix Ex. 90, Bates 3052-3054, 3155-3156, 3198-3199
Chapter 7 trustee
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 membersBankr. ECF 124, pp. 47-48
proposed abandoning the defensive appellate rights and TopDevz interest, listing the property at $0.00Bankr. ECF 197, pp. 1, 4-6
Companies and instruments
Entities tied to the money, control, and successor-operation paths
Rule | proof | consequence
Eleven record checkpoints explain the authority chain from governance to sale
Every checkpoint below links to an appendix clip or bankruptcy docket filing. Read the records in order, then decide whether each later act traces to the governance authority required at the beginning.
- 1What rule controlled?Start with the Operating Agreement and California governance rule.
- 2Who knew what?Use dated petitions, emails, declarations, and billing entries.
- 3What entered the record?Identify each appearance, declaration, consent, motion, and signature.
- 4What followed?Trace the confirmation, conversion, settlement, abandonment, and sale orders.
- 5Did the premise matter?Test whether each later result depended on the disputed authority premise.
TopDevz Operating Agreement
What the record shows
The document states that the business is managed by the Manager and limits removal of a member-manager to the required member vote.
Why it matters
Every later TopDevz appearance and entity act can be tested against this governance requirement.
Consolidated Appendix Vol. 6, Ex. 79, Bates 2337, 2342, 2354-2356
Davis petition for decree of dissolution
What the record shows
The petition supplies a dated, party-filed baseline for ownership and management before the later authority shift.
Why it matters
The reader can compare that filing with later statements that Davis had become TopDevz's manager.
Consolidated Appendix Vol. 3, Ex. 62, Bates 1001-1005
February 2021 counsel email chain
What the record shows
The email says the statutory dissolution and winding-up procedures were within the Superior Court's exclusive jurisdiction.
Why it matters
That contemporaneous statement is the knowledge benchmark for the later arbitration and confirmation positions.
Consolidated Appendix Vol. 6, Ex. 81, Bates 2375-2376
Arbitration demand and dismissal record
What the record shows
The filing records the TopDevz claim and the later dismissal signed by Kirk as attorney for TopDevz.
Why it matters
The authority question matters because the dismissal affected finality and removed a company claim against Davis.
Consolidated Appendix Vol. 6, Ex. 84, Bates 2401-2403, 2427-2428
San Diego appearance and proposed-judgment record
What the record shows
The record shows Kirk appearing for TopDevz in the confirmation proceeding that produced the San Diego judgment.
Why it matters
This is the bridge from the disputed company representation to the judgment later used in bankruptcy.
Consolidated Appendix Vol. 6, Ex. 85, Bates 2429-2433
Davis declarations in confirmation
What the record shows
The declarations state that Order No. 4 made Davis TopDevz's managing member.
Why it matters
The declaration supplies the manager premise that the authority-chain challenge asks readers to test against Ex. 79 and Ex. 62.
Consolidated Appendix Vol. 6, Ex. 87, Bates 2497-2500
Bankruptcy ECF 19 / Appendix Ex. 89
What the record shows
The motion identifies Hays as counsel for both judgment creditors and uses the arbitration and manager recitals in support of conversion.
Why it matters
The disputed state-court authority premise became the movant and evidentiary premise for federal relief.
Consolidated Appendix Vol. 7, Ex. 89, Bates 2561-2593
FTRL fee applications / Appendix Ex. 90
What the record shows
The entries record calls and emails about resolution options, dismissal, notices of appearance, and the San Diego action.
Why it matters
The entries document continued participation after the judgment and conversion rather than an isolated earlier role.
Consolidated Appendix Vol. 8, Ex. 90, Bates 3052-3054, 3155-3156, 3198-3199
Trustee settlement motion and TopDevz consent
What the record shows
The motion calls the trustee and Davis the sole members, seeks approval of their consent, and states the document was intended to eliminate uncertainty over Davis's authority.
Why it matters
The filing itself identifies the unresolved authority problem and the document used to answer it.
Bankr. ECF 124, pp. 2, 19, 25-26, 46-48
Order granting the trustee's motion to approve settlements
What the record shows
The order identifies the Davis/TopDevz settlement, the $100,000 payment, and the related dismissal and release terms.
Why it matters
This is the operative order produced by the settlement-authority presentation.
Bankr. ECF 159, pp. 1-10
Bankruptcy ECF 197, 211, 288, and 543
What the record shows
ECF 197 listed the property at $0.00; Davis and TopDevz jointly offered $80,000 in ECF 211; ECF 288 proposed the negotiated $100,000 sale; ECF 543 approved it.
Why it matters
The four filings let readers verify the complete transaction sequence in the participants' and court's own records.
Bankr. ECF 197, pp. 1, 4-6; ECF 211, pp. 1-5; ECF 288, pp. 1, 4-8; ECF 543, pp. 1-8
Full evidence walkthroughs
Move from the authority chain into the money, control, concealment, and bankruptcy chapters
1
The Founding Lie & the $750,000How Davis got his 49%.
2
The $37,240 Money TracePPP funds, an intermediary check, a K-1 entry, and 95.308%.
3
The 8-Week BlitzBank seizure, new account, and the 4.692% certificate.
4
Talentcrowd: The Cloned BusinessSame database, same clients, new banner.
5
Flow of FundsWhere the money went.
6
They KnewWritten admissions and notice of proof.
7
Fraud on the CourtThe half-truths to judges.
8
The Inside MoleLastPass access, email monitoring, and deletion claims.
9
The Bankruptcy ManeuversManager declarations, settlement, forged consent claims.
10
Intimidation: Don't TestifyPower of attorney, pressure, and bankruptcy testimony claims.
11
Victim LedgerThe pleaded losses in one reference ledger.
