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Consolidated appendix and supplemental proof clips
Authority Chain | Ex. 79
TopDevz was manager-managed, with a member-vote removal rule
Supports the claim that any TopDevz counsel authority had to trace to valid manager authority, not merely to Davis acting as a member or judgment creditor.
Davis-side counsel acknowledged the court-reserved dissolution issue in February 2021
Supports the knowledge claim: before the later arbitration and confirmation filings, Davis-side counsel had written notice that dissolution and winding-up remedies belonged in Superior Court.
Davis's 2021 petition admitted Rajaee was 51%, manager, and CEO
Supports the claim that Davis and his counsel knew Davis lacked the majority-member vote needed to remove Rajaee before later claiming Davis could act for TopDevz.
Davis Petition for Decree of Dissolution Consolidated Appendix Vol. 3, Ex. 62, Bates 1001-1005
Kirk appeared for TopDevz and dismissed TopDevz's claim against Davis
Supports the claim that TopDevz's claim against Davis was removed through a disputed TopDevz appearance rather than through Rajaee-authorized company counsel.
TopDevz amended arbitration demand and Kirk notice of dismissal Consolidated Appendix Vol. 6, Ex. 84, Bates 2401-2403, 2427-2428
Hays filed the conversion motion for TopDevz and Davis and declared personal knowledge
Supports the claim that Hays adopted the same TopDevz/Davis authority chain in bankruptcy while relying on arbitration findings and the asserted manager change.
Bankr. ECF 19 motion to appoint trustee or convert Consolidated Appendix Vol. 7, Ex. 89, Bates 2561-2593
The October 17, 2025 minute order denied the motion to vacate
Adds the procedural anchor for the appeal narrative: the court denied ROA 151, while the later draft motion argues the seven-point procurement chain was not reached on the merits.
Denial of ROA 151 motion to vacate San Diego Superior Court Case No. 37-2022-00026691, ROA 170
ROA 182 lays out the seven-point procurement-fraud theory
Gives readers the compact roadmap of the fraud-in-procurement theory: 2021 knowledge, no-vote authority, unauthorized TopDevz appearance, Davis declarations, and ROA 121.
Rajaee motion to vacate judgment San Diego Superior Court Case No. 37-2022-00026691, ROA 182, pp. 16-19
Rajaee's declaration says he never authorized Davis-selected TopDevz counsel
Supports the factual dispute over authority by pairing Rajaee's sworn no-authorization statement with the Secretary of State page listing Rajaee for TopDevz.
Rajaee declaration ISO motion to vacate San Diego Superior Court Case No. 37-2022-00026691, ROA 183, pp. 1-5, 123
Rajaee moved to disqualify Hays/MHW from purporting to represent TopDevz
Shows Rajaee independently raised the same TopDevz authority objection and traced Hays's authority claim back to the challenged judgment and arbitration ruling.
Rajaee motion to disqualify Hays/MHW San Diego Superior Court Case No. 37-2022-00026691, ROA 203, pp. 1-6
The Bankruptcy Court approved the four settlements described in ECF 124
The order identifies the Davis/TopDevz settlement, its $100,000 payment, and the dismissal, release, claim-treatment, and lien terms approved by the court.
Order granting trustee motion to approve settlements Bankr. S.D. Cal. No. 24-00617-CL7, ECF 159, pp. 1-10
Davis and TopDevz jointly opposed abandonment and offered $80,000
The filing identifies Davis and TopDevz as joint creditors, offers $80,000 for the appellate rights, and asks the trustee to withdraw or the court to deny abandonment.
Davis/TopDevz joint opposition to abandonment Bankr. S.D. Cal. No. 24-00617-CL7, ECF 211, pp. 1-5
The trustee proposed the negotiated $100,000 sale to Davis and TopDevz
The motion defines Davis and TopDevz as the buyers, recounts the $80,000 opposition offer, and states that negotiations produced a $100,000 purchase price.
Trustee motion to approve sale Bankr. S.D. Cal. No. 24-00617-CL7, ECF 288, pp. 1, 4-8
The Bankruptcy Court approved the $100,000 defensive-appellate-rights sale
The order traces the transaction from proposed abandonment through the initial $80,000 offer to the negotiated $100,000 sale and approves the transaction.
Order granting trustee sale of defensive appellate rights Bankr. S.D. Cal. No. 24-00617-CL7, ECF 543, pp. 1-8