The RICO Enterprise and the Racketeering Actors
Exhibit library

What each filing tends to show

Search by person, dollar figure, docket number, filing name, or proof point. Each row identifies the source, states the limited point it supports, and opens the underlying PDF.

Start with the 11-record authority chain

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.

TopDevz Operating Agreement Consolidated Appendix Vol. 6, Ex. 79, Bates 2337, 2342, 2354-2356
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Authority Chain | Ex. 81

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.

Feb. 26-27, 2021 counsel email chain Consolidated Appendix Vol. 6, Ex. 81, Bates 2375-2376
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Authority Chain | Ex. 62

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
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Unauthorized TopDevz Appearance | Ex. 84

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
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Unauthorized TopDevz Appearance | Ex. 85

Kirk's TopDevz appearance carried into confirmation filings

Supports the claim that the same disputed TopDevz authority was used in the confirmation proceeding.

Kirk notice of appearance and joint confirmation filings Consolidated Appendix Vol. 6, Ex. 85, Bates 2429-2433
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Manager-Authority Filings | Ex. 87

Davis declared that Order No. 4 made him TopDevz's managing member

Supports the claim that later TopDevz appearances depended on the premise that an arbitration order made Davis manager.

Davis declarations and winding-up statement Consolidated Appendix Vol. 6, Ex. 87, Bates 2497-2500
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Bankruptcy Authority Chain | Ex. 89

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
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Bankruptcy Authority Chain | Ex. 90

Trustee-counsel fee entries show communications with Hays and Carpenter

Supports a timeline of communications among estate counsel, Hays, and Carpenter about Davis/TopDevz matters and related state-court actions.

FTRL fee applications Consolidated Appendix Vol. 8, Ex. 90, Bates 3001, 3052-3054, 3155-3156, 3198-3199
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Unauthorized TopDevz Appearance | Ex. 98

Carpenter described his TopDevz work as routine litigation tasks

Supports the claim that Carpenter treated TopDevz representation as authorized through Davis's asserted manager status.

Carpenter declaration re motion to disqualify Consolidated Appendix Vol. 10, Ex. 98, Bates 4041-4044
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Notice and Objection | Ex. 102

Rajaee directly told Kirk he was not authorized to represent TopDevz

Supports the notice claim: Kirk had direct written objection before continuing as TopDevz counsel.

Apr. 16, 2023 email to Douglas Kirk Consolidated Appendix Vol. 10, Ex. 102, Bates 4169-4170
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Manager-Authority Filings | Ex. 103

Carpenter used Davis's asserted authority with Wells Fargo

Supports the claim that the disputed manager premise was used outside court to control TopDevz bank access.

Jan. 17, 2022 Carpenter email to Wells Fargo Consolidated Appendix Vol. 10, Ex. 103, Bates 4171-4173
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Hays Handoff | Ex. 111

The San Diego substitution moved TopDevz representation from Carpenter to Hays

Supports the claim that Hays's TopDevz authority traces through Carpenter and Davis rather than an independent TopDevz manager authorization.

San Diego Superior Court substitution of attorney Consolidated Appendix Vol. 11, Ex. 111, Bates 4284-4286
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Manager-Authority Filings | Ex. 112

Carpenter transmitted a revised membership certificate

Supports the claim that Davis-side counsel used revised ownership paperwork after the disputed Order No. 4 authority shift.

Forged TopDevz membership certificate and transmittal email Consolidated Appendix Vol. 11, Ex. 112, Bates 4287-4288
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Hays Handoff | Ex. 120

Hays continued to file for TopDevz in the Ninth Circuit

Supports the claim that the challenged TopDevz authority chain continued after the issue was raised in appellate proceedings.

Ninth Circuit Case No. 25-8172 DE 33.1 and 40.1 Consolidated Appendix Vol. 13, Ex. 120, Bates 4532-4539
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Supplemental San Diego Record | ROA 170

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
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Supplemental San Diego Record | ROA 182

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
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Supplemental San Diego Record | ROA 183

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
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Supplemental San Diego Record | ROA 196

Mobile Monster sought a threshold entity-authority ruling on MHW/Hays

Shows the TopDevz authority issue was raised directly before the court treated Hays/MHW filings as TopDevz filings.

Motion to determine entity authority and disqualify Hays/MHW San Diego Superior Court Case No. 37-2022-00026691, ROA 196, pp. 2-6
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Supplemental San Diego Record | ROA 203

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
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Bankruptcy Orders | ECF 159

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
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Abandonment-to-Sale Record | ECF 197

The trustee proposed abandoning the appellate rights and TopDevz interest at $0.00

The notice lists the property at $0.00 and states that abandonment would return it to Rajaee because it could not be liquidated for creditors.

Trustee notice of proposed abandonment Bankr. S.D. Cal. No. 24-00617-CL7, ECF 197, pp. 1, 4-6
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Abandonment-to-Sale Record | ECF 211

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
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Abandonment-to-Sale Record | ECF 288

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
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Bankruptcy Orders | ECF 543

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
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The money trail (PPP & the $37,240)

Porter PPP Loan Note

Porter Consulting’s $328,300 PPP loan (Tri Counties Bank); the restricted, payroll-designated source.

Money Trace
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Mason check ($37,240)

A non-member entity (Mason) fronts Davis’s exact $37,240 capital-call amount to TopDevz; memo “Capital Call.”

Money Trace
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Mason …9876 statement (Ex. 48)

$37,240 transferred INTO Mason from Porter’s PPP account …8768 — the same exact amount, the round-trip’s closing leg.

Money Trace
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Davis 2020 TopDevz K-1

Section L books $37,240 as Davis’s “capital contributed during the year” — PPP money presented as his personal capital.

Money Trace
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Belluomini declaration

Sworn: the $750,000 “belonged to Porter… Tyler took it,” and he never knew of the PPP/$37,240 diversion.

Founding Lie
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Belluomini Porter membership certificate

Documents Belluomini as a concealed Porter co-owner (undisclosed on the PPP application).

Founding Lie
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The takeover & the cloned business

Davis arbitration testimony (Day 2)

Under oath: “I did not write that check… my business partner at Mason wrote it” — contradicted by the …8768 record.

Money Trace
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Final Arbitration Award (5/12/2023)

“Davis owns 95.308%…” — ownership fixed by capital contributed, with the tainted $76,000 call in the denominator.

Money Trace
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Forged membership certificate + email (Ex. 83)

Certificate cutting Rajaee to 4.692%, signed only by Davis, with conflicting dates; emailed by Carpenter.

The Blitz
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Talentcrowd Wyoming formation

The cloned-business vehicle formed Feb. 8, 2022 in Wyoming (members not listed publicly).

Talentcrowd
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Flow of funds & laundering

JPMorgan Chase bank statements

The fraudulent account that captured redirected client payments (~$15M through it).

Flow of Funds
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Chase payments to Lintz/Talentcrowd (Ex. 112)

$838,554.30 to Talentcrowd, $722,335.83 to Lintz, plus attorney wires — the laundering ledger.

Flow of Funds
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Knowledge, candor & the bankruptcy

9th Cir. sanctions motion (Finlayson/Hays)

The “half-truth/fraud-on-the-court” theory; quotes Finlayson’s admission the forged consent was “forwarded by Ed Hays.”

Fraud on the Court
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Hays declaration

April 2024 declaration swearing Davis is “the managing member of TopDevz.”

Bankruptcy
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Hays conversion motion (ECF 19)

The motion that converted the case to Chapter 7, resting on the arbitration award / manager status.

Bankruptcy
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Trustee settlement motion (ECF 124)

Asks the court to approve the “Unanimous Written Consent”; signed by Davis as “Manager”; releases the RICO suits.

Bankruptcy
Open PDF

Trustee contempt motion (Doc 580)

The Trustee moving to hold Rajaee in contempt for trying to vacate the dismissals (seeks sanctions, not arrest).

Bankruptcy
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The inside mole & the intimidation

LastPass account notice

Corroborates the retained master-password access used to enter Rajaee’s accounts.

Inside Mole
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Power of attorney to Antonucci

Rajaee’s 100% POA over the Davis litigation handed to Antonucci (June 23, 2022).

Intimidation
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Antonucci Kenya gold-fraud news report

Public reporting: Antonucci charged in Nairobi with a $1,271,200.74 fake-gold fraud.

Intimidation
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Wire to “Lord” Thomas (legal fees)

A TDZ IT Services wire to Thomas “for legal fees on behalf of Ashkan Rajaee” — the money trail to Thomas.

Intimidation
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