49% minority member of TopDevz; owner/controller of Porter Consulting, Mason Building & Design, and other entities.
Principal organizer
Record-linked conduct
embezzled $750,000 from Porter Consulting via three 2017 bank wires, then called it his "personal investment" to obtain his 49% stake.¶¶214–224
obtained a $328,300 PPP loan for Porter and laundered $37,240 of it through Mason into TopDevz as a "capital call."¶¶237–246
gave false sworn testimony ("I put in 100% of the capital"), producing Interim Order No. 4 granting him 95.308% and "managing member" status.¶¶256,261
ordered the mass theft of trade secrets and personally took part in destroying office servers on Jan. 15, 2022.¶¶277,291–293
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. 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
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
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 the April 19, 2020 false PPP application to Tri Counties Bank, the Jan. 7, 2022 seizure of TopDevz’s Wells Fargo account, and use of Rajaee’s identity to open a new account. ¶¶482–485
States use of Rajaee’s / TopDevz’s tax ID and EIN on fraudulent tax returns, the new account opening, and perjured declarations. ¶¶486–500
States the Jan. 2022 mass download of a proprietary 2.5M-record database (3,784 files by one defendant; a full Zoho Recruit dump by another), corroborated by Google admin audit logs showing thousands of administrative actions. ¶¶501–504
States promotional and transactional laundering — wires from the fraudulent account to fund operations using stolen secrets, and >$10,000 transactions in criminally-derived funds to attorneys and others. ¶¶325–331
States false partnership and Schedule-C returns concealing that the "$750,000" and "$37,240" capital contributions were embezzled / PPP-derived. ¶258
States the Jan. 15, 2022 destruction of computers/servers, the deletion of "over 130 TopDevz client projects," and deletion of evidence from the plaintiff’s email. ¶¶291–298
A sworn bankruptcy filing states a concerted effort to stop Rajaee from testifying: a "Lord"/"attorney" persona (Thomas), a power-of-attorney takeover (Antonucci), and threats "not to testify in this bankruptcy case." See the Intimidation walkthrough. Doc 210 ¶¶7–12
States declarations falsely swearing Davis is the "managing member" of TopDevz, a scheme to convert the case to Chapter 7, a ~$10M false proof of claim, and a forged "Unanimous Written Consent" used in settlement. ¶¶387–431
Belluomini declaration
PPP loan note
Mason $37,240 check
…8768 backfill statement
Davis 2020 K-1 (Section L)
Davis arbitration testimony (Day 2)
Final Award (95.308%)
The certificate & email
JPMorgan statements (Ex. 83)
Payments to Lintz/Talentcrowd (Ex. 221)
Sanctions motion (9th Cir.)
LastPass notice
Kenya gold-fraud news report
Hays declaration
Settlement motion (ECF 124)
Conversion motion (ECF 19)
Trustee contempt motion (Doc 580)
Proposed abandonment (ECF 197)