The RICO Enterprise and the Racketeering Actors
Evidence walkthrough. The facsimiles are reading aids. The PDF links open the underlying documents that should control.
Theme · Intimidation of the Witness

"Don't testify" —
pressure during the bankruptcy

A sworn, filed bankruptcy motion describes two men — one later arrested in Kenya for a gold fraud — who took control of Rajaee's litigation, then threatened him not to testify. Scroll the record.

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Bottom lineTwo men — one later arrested in Kenya for a $1.27M gold fraud — took control of Rajaee’s litigation and pressured him not to testify; the Trustee even moved to have him arrested.
1

May 2022: a "Lord" and "international attorney" appears

Per Rajaee's sworn declaration, in May 2022 Robert Orville Thomas presented himself as an "international attorney," "organized crime fighter," and "Lord," and was retained through his firm Astute Dynamic, Ltd. — then brought in his partner, Sergio Antonucci.

U.S. BANKRUPTCY COURT, S.D. CALIFORNIA · No. 24-00617-CL7
DECLARATION OF ASHKAN RAJAEE · Doc 210 · Filed 02/20/25 (sworn)
7."In May of 2022, Robert Orville Thomas ('Thomas') represented himself to me as an international attorney, organized crime fighter with high-ranking credentials and Lord. … I retained Thomas and his firm Astute Dynamic, Ltd. … Thomas immediately brought business partner and California resident Sergio Patrick Antonucci ('Antonucci') to also help represent our interests."
Sworn under penalty of perjury · Bankr. ECF Doc 210 (Cate Legal Group for debtors).
A grandiose persona"International attorney … Lord" — per the sworn declaration
Bankr. ECF Doc 210 ¶7 (facsimile) · sworn declaration
Source: Bankr. S.D. Cal. No. 24-00617-CL7, Doc 210 (filed 2/20/25) — debtors' application to seal the creditors' meeting + Rajaee declaration.
Fact vs. sworn statementThat Thomas presented these credentials is sworn testimony. Whether the credentials were false is addressed in Step 4 — and rests on Rajaee's sworn statement, which a bar-registry check can corroborate.
2

June 23, 2022: 100% power of attorney to Antonucci

On June 23, 2022, Rajaee executed a general durable power of attorney naming Antonucci his attorney-in-fact over the Davis litigation — and, per the declaration, was then cut off from his own lawyers and told all communication must go through Antonucci and Thomas.

POWER OF ATTORNEY · "Attorney in Fact Representation of Ashkan M. Rajaee"
Executed June 23, 2022
I.A"I appoint Sergio Antonucci to serve as my Attorney-in-Fact" — with authority "to retain Attorneys … file lawsuits, file any court documents," and to "settle … to litigate against Tyler Davis and or any third parties" in Tyler Davis v. Rajaee, San Diego Super. Ct. No. 37-2022-00015126.
decl ¶8"On June 23, 2022, Thomas and Antonucci demanded that we give 100% power of attorney to Antonucci, which we did. Thereafter, we were prohibited from speaking to any of our own attorneys and were … threatened that all communications were to go through Antonucci and Thomas, only."
Total control of the litigationPOA to Antonucci + cut off from his own counsel
POA (June 23, 2022) + Doc 210 ¶8 (facsimiles)
View the power of attorney → Source: "Ashkan POA" — general durable POA naming Antonucci attorney-in-fact (the document itself is fact; the surrounding coercion is sworn statement).
3

December 2024: Antonucci arrested in Kenya for a gold fraud

The man holding Rajaee's power of attorney was charged in a Nairobi court with defrauding a businessman of $1,271,200.74 in a fake gold deal — public knowledge, reported in the press and corroborated by Rajaee's sworn declaration.

INSIDER BITS NEWS (insiderbits.co.ke) · December 16, 2024
US National Charged with Defrauding Kenyan Businessman of Over $1.2 Million in Fake Gold Deal

"A US national, Sergio Patrick Antonucci, has been charged in a Nairobi court with defrauding a Kenyan businessman of 1,271,200.74 US dollars in a fraudulent gold deal. … Antonucci denied two criminal charges: conspiracy to commit [an offense and] obtaining money by false pretenses. … Magistrate Situbi granted Antonucci bail…"

Arrested for a $1.27M gold fraudPublic knowledge — reported in the press
News report · Insider Bits News, Dec. 16, 2024 · corroborated by Doc 210 ¶10
View the news report → Source: Insider Bits News (Kenya), 12/16/2024 — public reporting. Rajaee's declaration ¶10 states the same (~$1,271,000). Note: the gold-deal victim was a U.S. person ("Cook"), not Rajaee.
Why it matters hereThe arrest is independent, public corroboration that the man given control over Rajaee's litigation was engaged in fraud — and undercuts the legitimacy of the "representation" he and Thomas provided.
4

July 2024: not an attorney, not a Lord

Per the sworn declaration, by mid-2024 Rajaee discovered Thomas and Antonucci had obtained nearly $2 million while Thomas "pos[ed] as an attorney" — and that Thomas "is not an attorney or a Lord" and Antonucci "was not an investment banker."

DECLARATION OF ASHKAN RAJAEE · Doc 210 ¶9 (sworn)
9."Around July 2024, we discovered that Antonucci and Thomas were defrauding us and had obtained nearly $2 million in connection with Thomas posing as an attorney and giving us legal instructions, to our detriment. Specifically, we discovered that Thomas is not an attorney or a Lord and that Antonucci was not an investment banker, or qualified legal consultant…"
A payment trail corroborates funds flowing to Thomas: a TDZ IT Services email (Nov. 27, 2023) confirms a wire to "Lord Robert O Thomas" "for … the payment of legal fees on behalf of Ashkan Rajaee."
"Thomas is not an attorney or a Lord"Sworn statement — corroborate with a bar-registry check
Doc 210 ¶9 (facsimile) · wire email (TDZ → Thomas, Nov. 2023)
View the wire confirmation → Source: TDZ IT Services email confirming a wire to "Lord Robert O Thomas" for "legal fees on behalf of Ashkan Rajaee" (Nov. 27, 2023). The "not an attorney" finding is Rajaee's sworn statement; a State Bar registry search would independently confirm it.
Outside corroboration: an open UK regulator fileThis isn't only Rajaee's say-so. The conduct is the subject of an open UK Solicitors Regulation Authority (SRA) case against Thomas (Case No. RGC-000132373) — the proceeding that can permanently bar him from working in or with a law firm. An outside regulator's active file corroborates the "posing as an attorney" claim.
5

The threat: "do not testify in this bankruptcy"

The reason this matters to the case: Rajaee swore he received death threats and was specifically instructed — by phone — not to testify in the bankruptcy about the criminal activity. That's why the debtors moved to hold the creditors' meeting under seal.

DECLARATION OF ASHKAN RAJAEE · Doc 210 ¶¶11–12 (sworn)
11."Within the past two months, I have received death threats related to the criminal activity of Antonucci, Thomas and Davis. I have been specifically instructed over the phone not to testify in this bankruptcy case … under threats of death and serious harm to my family by Thomas and others."
12.The debtors seek to testify "without the threat of coercion" and "to avoid the fear and threat of intimidation from Antonucci, Thomas, Davis and those working on their behalf."
Told not to testify — under threatFiled, sworn, tied to the bankruptcy
Bankr. ECF Doc 210 ¶¶11–12 (facsimile) · sworn
Precise attribution The filing ties the intimidation to the bankruptcy and names Antonucci, Thomas, and Davis as the concerted group. The specific death-threat phone call in ¶11 is attributed to "Thomas and others."