TopDevz, LLC

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. 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. 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.

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

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.

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

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 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

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.

The motion identifies Hays as counsel for judgment creditors TopDevz and Davis and says the January 6 ruling made Davis manager.

Bankr. ECF 19 motion to appoint trustee or convert Consolidated Appendix Vol. 7, Ex. 89, Bates 2561-2593 Open record

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.

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

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

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.

The email says Kirk and his firm were 'not authorized to represent TopDevz, LLC.'

Apr. 16, 2023 email to Douglas Kirk Consolidated Appendix Vol. 10, Ex. 102, Bates 4169-4170 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

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.

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

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.

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

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.

The Ninth Circuit filing identifies Hays/MHW as attorneys for appellees Tyler Davis and TopDevz.

Ninth Circuit Case No. 25-8172 DE 33.1 and 40.1 Consolidated Appendix Vol. 13, Ex. 120, Bates 4532-4539 Open record

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.

The minute order denies the motion to declare the proceeding or judgment void.

Denial of ROA 151 motion to vacate San Diego Superior Court Case No. 37-2022-00026691, ROA 170 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

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 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

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.

The motion asks the court to determine TopDevz authority before considering merits arguments supposedly made by TopDevz.

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

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.

The motion says Hays cannot use the judgment as the source of authority while that authority is disputed.

Rajaee motion to disqualify Hays/MHW San Diego Superior Court Case No. 37-2022-00026691, ROA 203, pp. 1-6 Open record

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.

The order states that the court grants the motion and approves all four settlements.

Order granting trustee motion to approve settlements Bankr. S.D. Cal. No. 24-00617-CL7, ECF 159, pp. 1-10 Open record

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.

The opposition says the creditors offer to purchase or settle the claims for $80,000.

Davis/TopDevz joint opposition to abandonment Bankr. S.D. Cal. No. 24-00617-CL7, ECF 211, pp. 1-5 Open record

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.

The motion says the proposed abandoned assets would be sold to Davis and TopDevz for $100,000.

Trustee motion to approve sale Bankr. S.D. Cal. No. 24-00617-CL7, ECF 288, pp. 1, 4-8 Open record

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.

The order states that the rights were headed for abandonment at zero dollars and that the estate received $100,000.

Order granting trustee sale of defensive appellate rights Bankr. S.D. Cal. No. 24-00617-CL7, ECF 543, pp. 1-8 Open record