The RICO Enterprise and the Racketeering Actors
Joseph W. Scalia
Accountability dossier

Joseph W. Scalia

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

Legal cover

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
Focused record proof

Documents naming, authorizing, contradicting, or materially affecting this role

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.

The agreement defines Majority of Members, says the business is managed by the Manager, and limits member-manager removal to a vote of all other members.
TopDevz Operating Agreement Consolidated Appendix Vol. 6, Ex. 79, Bates 2337, 2342, 2354-2356 Open record
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.

The email says dissolution and winding-up procedures are within the Superior Court's exclusive jurisdiction.
Feb. 26-27, 2021 counsel email chain Consolidated Appendix Vol. 6, Ex. 81, Bates 2375-2376 Open record
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's petition says Rajaee was manager and CEO, held 51%, and Davis 'cannot obtain a vote.'
Davis Petition for Decree of Dissolution Consolidated Appendix Vol. 3, Ex. 62, Bates 1001-1005 Open record
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 asserted Davis had authority to hire counsel including Carpenter, Scalia, or Kirk for TopDevz.
Carpenter declaration re motion to disqualify Consolidated Appendix Vol. 10, Ex. 98, Bates 4041-4044 Open record
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.

Carpenter told Wells Fargo that Davis was manager and that transfers to Rajaee were not authorized.
Jan. 17, 2022 Carpenter email to Wells Fargo Consolidated Appendix Vol. 10, Ex. 103, Bates 4171-4173 Open record
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.

The motion frames the issue as fraud in procurement of the judgment, not simple disagreement with the result.
Rajaee motion to vacate judgment San Diego Superior Court Case No. 37-2022-00026691, ROA 182, pp. 16-19 Open record
Full filing proof

Complete documents tied to this dossier

Davis 2020 K-1 (Section L) The tax-fraud layer Davis arbitration testimony (Day 2) The arbitration takeover Final Award (95.308%) The arbitration takeover Sanctions motion (9th Cir.) Fraud on the court: the half-truths
Pleaded predicate categories

Complaint categories that directly name this actor

States a 2022 campaign of "hundreds of fraudulent mass emails to TopDevz clients" via a look-alike domain redirecting payments to a fraudulent bank account, transmission of forged stock certificates, and "over 130 fraudulent pleadings" filed through courts’ e-filing systems. ¶¶466–479
States false partnership and Schedule-C returns concealing that the "$750,000" and "$37,240" capital contributions were embezzled / PPP-derived. ¶258
Scheme map

Where this role appears in the larger record

The tax-fraud layer Falsified returns using Rajaee’s tax identity to build the ownership story. ¶258 The arbitration takeover False testimony + fake returns → 95.308% ownership and "manager" status. ¶¶256–261,350–351 They knew: knowledge of falsity Written admissions + service of the proof — intent, not mistake. ¶¶252–261; 9th Cir. 25-8172 The professional enablers Four attorneys who supplied "legal cover" and were paid from tainted funds. ¶¶42–77 Fraud on the court: the half-truths Counsel relied on a void award while omitting the law that voids it. 9th Cir. 25-8172; Compl. ¶¶252–253