Attorney (formerly Cummins & White, LLP); Davis’s arbitration counsel.
Legal cover
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
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
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
Supports the claim that TopDevz's claim against Davis was removed through a disputed TopDevz appearance rather than through Rajaee-authorized company counsel.
The dismissal is styled as TopDevz's dismissal of its eighth cause of action against Tyler Davis.TopDevz amended arbitration demand and Kirk notice of dismissal Consolidated Appendix Vol. 6, Ex. 84, Bates 2401-2403, 2427-2428 Open record
Supports the claim that the same disputed TopDevz authority was used in the confirmation proceeding.
The filing lists Kirk as attorney for TopDevz and joins Davis and TopDevz in confirmation papers.Kirk notice of appearance and joint confirmation filings Consolidated Appendix Vol. 6, Ex. 85, Bates 2429-2433 Open record
Supports the claim that later TopDevz appearances depended on the premise that an arbitration order made Davis manager.
Davis declared, 'After Order No. 4 was issued... I became the managing member of TopDevz.'Davis declarations and winding-up statement Consolidated Appendix Vol. 6, Ex. 87, Bates 2497-2500 Open record
Supports a timeline of communications among estate counsel, Hays, and Carpenter about Davis/TopDevz matters and related state-court actions.
Fee entries reference calls or emails with E. Hays and S. Carpenter about resolution options and state-court appearances.FTRL fee applications Consolidated Appendix Vol. 8, Ex. 90, Bates 3001, 3052-3054, 3155-3156, 3198-3199 Open record
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
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
Supports the claim that Hays's TopDevz authority traces through Carpenter and Davis rather than an independent TopDevz manager authorization.
The form identifies Hays as new attorney for Tyler Davis and TopDevz, with Carpenter as former representative.San Diego Superior Court substitution of attorney Consolidated Appendix Vol. 11, Ex. 111, Bates 4284-4286 Open record
Supports the claim that Davis-side counsel used revised ownership paperwork after the disputed Order No. 4 authority shift.
Carpenter wrote that Rajaee never updated certificates and attached a new membership certificate.Forged TopDevz membership certificate and transmittal email Consolidated Appendix Vol. 11, Ex. 112, Bates 4287-4288 Open record
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
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 declared he never authorized Davis, Kirk, or Hays to represent TopDevz.Rajaee declaration ISO motion to vacate San Diego Superior Court Case No. 37-2022-00026691, ROA 183, pp. 1-5, 123 Open record
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
The certificate & email
The 8-week blitz
JPMorgan statements (Ex. 83)
Flow of funds: where the ~$15M went
Payments to Lintz/Talentcrowd (Ex. 221)
Flow of funds: where the ~$15M went
Sanctions motion (9th Cir.)
Fraud on the court: the half-truths