Evidence walkthrough.
The facsimiles are reading aids. The PDF links open the underlying documents that should control.
Theme · Follow the Money
Where the ~$15 million went
After the company's bank accounts were taken over, the complaint states the funds were routed through a new account and fanned out — to the cloned business, to the operator who built it, and to the lawyers. Scroll the map.
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Bottom lineAbout $15 million moved through the seized accounts; the named outflows go to the cloned business and the lawyers, and the rest were transfers Rajaee never authorized.
1
The accounts that were taken over
In January 2022 the complaint states TopDevz's Wells Fargo operating account was seized and a new JPMorgan Chase account was opened to capture client payments. Those accounts are the source of the flow that follows.
The source accounts (as stated)
Wells Fargo (…1128)seized Jan. 7, 2022
JPMorgan Chase (…0516)opened to receive redirected payments
Aggregate moved~$15 million
~$15M through these accountsThe pool the money was distributed from
Complaint cite · Complaint ¶¶265–268, 325–331 · figure at ¶272
View the JPMorgan statements →Source: JPMorgan Chase bank statements and Chase payments ledger exhibits. Verify operative exhibit numbering against the filing set being used.
2
The money map
From the Chase account, the complaint traces the specific outflows below. The two largest — to Talentcrowd and to Lintz — fund and reward the cloned business; the rest pay the lawyers who provided "legal cover."
JPMorgan Chase (…0516) → out
Figures from pleadings in the complaint (¶¶325–331) and shown in the JPMorgan Chase payments ledger (Ex. 112).
Fraudulent JPMorgan Chase account
~$15,000,000
redirected client payments + transfers
Talentcrowd, LLC
the cloned business (seed funding)
$838,554.30
Joshua Lintz
operator who formed Talentcrowd
$722,335.83
Cummins & White (Carpenter)
Davis's arbitration counsel
$196,768+
Kirk & Toberty (Kirk)
unauthorized TopDevz counsel
$30,000+
Purdy & Bailey (Bailey)
Talentcrowd-group counsel
$4,135+
Specific itemized wires
Feb 28 / Jun 12 / Jul 7, 2022
$43,768 · $70,000 · $83,000
Remaining balance — unauthorized transfers
transfers out of the accounts that Rajaee (51% member/manager) did not make or authorize
balance of ~$15M
The named outflows above are a fraction of the ~$15M. Per the complaint, the remainder consists of transfers Rajaee neither made nor authorized — all pled as transactions in criminally-derived funds (money laundering, 18 U.S.C. §§1956 & 1957).
One wire worth a closer look: $70,000 to Davis's lawyers
Among the outflows, the complaint highlights a $70,000 wire from the TopDevz Chase account to Davis's lawyers — booked, it states, to a Davis personal invoice. Company money paying a personal legal bill is the core of the honest-services / fiduciary-breach theory.
The $70,000 wire (as stated)
FromTopDevz JPMorgan account
ToCummins & White (Davis's counsel)
DateJuly 7, 2022
Amount$70,000
Booked toa Davis personal invoice
Company funds, personal billThe honest-services / fiduciary-breach hook
Why the map mattersThe complaint's theory is that these are not ordinary business payments — they are the distribution of money derived from the scheme, to the people who built and protected it. Each line is traceable to a bank record.
4
The rest: transfers Rajaee never made or authorized
The named outflows above are only a slice of the ~$15M. The complaint states the remaining balance left the accounts as transfers that Rajaee — the 51% member and lawful manager — neither made nor authorized, after control of the accounts had been seized.
The balance left without authorizationRajaee, the 51% member/manager, didn't make or approve it
Complaint cite · Complaint ¶¶265–268, 325–331 · bank records (Chase ledger Ex. 112)
Why this mattersIt is not only that money went to the wrong people — the complaint states the lawful 51% owner/manager was locked out of his own company's accounts while the balance was moved without his knowledge or consent. The bank statements are the source for reconstructing exactly where the remainder went.