Record-linked conduct
- 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
- ECF 63 alleges that Tri Counties Bank records identify her as an additional signer on Porter accounts, including the Payroll-PPP account ending 8768, while Davis alone signed the federal Porter PPP application and loan documents. ECF 63 ¶¶103D–103E
- ECF 63 alleges, on information and belief, that she caused, authorized, approved, or coordinated the December 3, 2020 $37,240 transfer from Porter’s Payroll-PPP account to Mason, and the 2017 Porter capital wires. ECF 63 ¶103F
- ECF 63 alleges her § 1962(c) pattern consists, at minimum, of Predicate Acts 1, 4, and 16, each attributed to her on information and belief; no other predicate is attributed to her without a transaction-specific allegation. ECF 63 ¶103B