18 U.S.C. §1962(a)
Use of income from racketeering activity.
States defendants used or invested income derived from the pattern of racketeering to operate the enterprise. Brought against all defendants. ¶¶587–605RICO theory
The crimes and predicate acts
This page keeps the legal theory legible: what count is pled, what conduct is cited to satisfy it, and who is named in each predicate category.
18 U.S.C. §1962(b)
Acquisition and control of the enterprise through racketeering.
States defendants acquired or maintained control of TopDevz through the pattern of racketeering. Brought against all defendants. ¶¶606–62318 U.S.C. §1962(c)
Conducting the enterprise’s affairs through racketeering.
States defendants conducted or participated in the enterprise’s affairs through the pattern of predicate acts. Brought against all defendants. ¶¶624–64018 U.S.C. §1962(d)
RICO conspiracy.
States defendants agreed to commit the §1962(a)–(c) violations. Brought against all defendants. ¶641+Predicate acts
Categories cited in the complaint and related filings
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
Tyler Brandon Davis Scott R. Carpenter Joseph W. Scalia J. Douglas Kirk
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
Tyler Brandon Davis Melissa Garcia Amanda Frye Joshua Paul Lintz GBQ Partners LLC
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
Tyler Brandon Davis Joshua Paul Lintz Talentcrowd, LLC GBQ Partners LLC
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
Tyler Brandon Davis Sergio Patrick Antonucci Robert Orville Thomas
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
Authority-chain proof
Record clips that strengthen the fraud-on-the-court claims
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.
Consolidated Appendix Vol. 6, Ex. 79, Bates 2337, 2342, 2354-2356 Open proof clip
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.
Consolidated Appendix Vol. 6, Ex. 81, Bates 2375-2376 Open proof clip
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.
Consolidated Appendix Vol. 3, Ex. 62, Bates 1001-1005 Open proof clip
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.
Consolidated Appendix Vol. 6, Ex. 84, Bates 2401-2403, 2427-2428 Open proof clip
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.
Consolidated Appendix Vol. 6, Ex. 85, Bates 2429-2433 Open proof clip
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.
Consolidated Appendix Vol. 6, Ex. 87, Bates 2497-2500 Open proof clip
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.
Consolidated Appendix Vol. 7, Ex. 89, Bates 2561-2593 Open proof clip
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.
Consolidated Appendix Vol. 8, Ex. 90, Bates 3001, 3052-3054, 3155-3156, 3198-3199 Open proof clip
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.
Consolidated Appendix Vol. 10, Ex. 98, Bates 4041-4044 Open proof clip
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.
Consolidated Appendix Vol. 10, Ex. 102, Bates 4169-4170 Open proof clip
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.
Consolidated Appendix Vol. 10, Ex. 103, Bates 4171-4173 Open proof clip
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.
Consolidated Appendix Vol. 11, Ex. 111, Bates 4284-4286 Open proof clip
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.
Consolidated Appendix Vol. 11, Ex. 112, Bates 4287-4288 Open proof clip
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.
Consolidated Appendix Vol. 13, Ex. 120, Bates 4532-4539 Open proof clip
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.
San Diego Superior Court Case No. 37-2022-00026691, ROA 170 Open proof clip
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.
San Diego Superior Court Case No. 37-2022-00026691, ROA 182, pp. 16-19 Open proof clip
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.
San Diego Superior Court Case No. 37-2022-00026691, ROA 183, pp. 1-5, 123 Open proof clip
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.
San Diego Superior Court Case No. 37-2022-00026691, ROA 196, pp. 2-6 Open proof clip
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.
San Diego Superior Court Case No. 37-2022-00026691, ROA 203, pp. 1-6 Open proof clip