Evidence walkthrough.
The facsimiles are reading aids. The PDF links open the underlying documents that should control.
Theme 1 · The Founding Lie
"I put in $750,000" — but whose money was it?
The complaint states Davis acquired his 49% of TopDevz by claiming a $750,000 personal investment — when the money belonged to Porter Consulting, a company he co-owned with someone who says he never knew. Scroll to follow it.
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Bottom lineDavis got his 49% of TopDevz by claiming a $750,000 “personal investment” — but a co-owner swears the money was Porter Consulting’s, taken and concealed from him.
1
The claim that bought a 49% stake
The complaint states Davis told Rajaee he would "personally invest $750,000" to earn his 49% membership in TopDevz — a representation it lists as the enterprise's very first predicate act.
Why it mattersThe entire ownership structure flows from this representation. If the $750,000 was not Davis's to invest, the 49% rests on a misstatement.
2
The money came from Porter Consulting
The complaint states the $750,000 was moved out of Porter Consulting, LLC in 2017 — a company Davis controlled but co-owned with Todd Belluomini — via three large wires, then characterized to Rajaee as Davis's own funds.
Porter Consulting → TopDevz (as stated)
May 3, 2017$250,000
May 24, 2017$250,000
Nov. 22, 2017$250,000
SourcePorter Consulting funds
Presented to Rajaee asDavis's personal money
Porter's money — not Davis'sDavis controlled Porter but did not own it alone
Complaint cite · Complaint ¶¶214–224 (three Tri Counties Bank wires)
The setupPorter had another owner. That owner says he was never told — and never agreed.
3
The co-owner: "it belonged to Porter, and Tyler took it"
Todd Belluomini — a member-owner of both Porter and Mason — submitted a sworn declaration in February 2024. He swears he did not know about, and would not have authorized, the use of Porter's funds.
U.S. DISTRICT COURT, S.D. CALIFORNIA · No. 24CV0001-RSH-KSC DECLARATION OF TODD BELLUOMINI · Executed Feb. 11, 2024
3."I was a member-owner of Porter Consulting, LLC, from 2017 to 2021 and a member-owner of Mason Building & Design, LLC, from 2018 to 2021."
7."I did not, and would not, have authorized the misappropriation of Porter's partnership funds for a $750,000 personal investment in TopDevz by Tyler Davis. The $750,000 did not belong to Tyler Davis; it belonged to Porter, and Tyler took it by abusing his position and access, while concealing the transactions from me."
6."I was not aware until after the San Diego Judgment … that Tyler Davis had used Porter Consulting, LLC monies to invest into TopDevz, LLC. … Tyler Davis has always deprived me of access to the bank accounts of Porter Consulting, LLC."
"I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 11th day of February, 2024 at Winters, California." — Todd Belluomini
Sworn: "it belonged to Porter"The co-owner says he never knew and never agreed
Belluomini further swears that, denied financial records and fearing tax exposure for Davis's conduct, he relinquished his entire Porter ownership in 2021 — and only learned of the tax credits Davis took in late 2023.
DECLARATION OF TODD BELLUOMINI (cont’d)
13."Despite various requests … Tyler Davis always refused to provide me the financials of Porter Consulting, LLC. … I was forced to relinquish my entire ownership interest in Porter for nothing in 2021."
9."I was not aware until Ashkan Rajaee showed me TopDevz tax returns in late August 2023, that Tyler Davis took a $750,000 and $37,240 personal tax credit from funds belonging to Porter Consulting, LLC and Mason Building & Design."
The through-lineThe same pattern here — using a co-owned company's money, then concealing it from the co-owner — is the pattern the next theme follows with the PPP loan and the $37,240.