Evidence walkthrough.
The facsimiles are reading aids. The PDF links open the underlying documents that should control.
Theme 5 · The 8-Week Blitz
Eight weeks to seize a company — and a certificate cutting Rajaee to 4.692%
In January 2022 the complaint states a rapid sequence: an arbitration order, a bank-account seizure, a new account, and a membership certificate — signed only by Davis — reducing Rajaee's stake to 4.692%. Scroll through it.
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Bottom lineIn about two weeks (Jan. 2022) the company’s bank account was seized and a certificate — signed only by Davis — cut Rajaee from 51% to 4.692%.
1
Jan. 6, 2022 — the order that started the clock
Interim Order No. 4 (covered in depth in the money-trace walkthrough) granted Davis 95.308% and "managing member" status. Within days, the complaint states, that paper authority was used to take physical and financial control.
The lever (recap)
Jan. 6, 2022Interim Order No. 4
Grants Davis95.308% + "manager"
Built onthe $76,000 capital call (incl. $37,240)
See the money-trace walkthrough, Steps 5–7 · Complaint ¶261
2
Jan. 7, 2022 — the bank account is seized
The complaint states that the day after the order, Davis's counsel emailed false statements to Wells Fargo to seize TopDevz's operating account — then a new JPMorgan Chase account was opened to receive redirected client payments.
The account moves (as stated)
Jan. 7, 2022Wells Fargo acct seized
Methodfalse statements to the bank
Thennew JPMorgan Chase account opened
Purposereceive redirected client payments
Control of the money, in one dayBank-fraud predicate acts, per the complaint
Complaint cite · Complaint ¶¶265–268, 482–485
3
The certificate: Rajaee cut to 4.692%
A TopDevz membership-interest certificate (No. 2) was issued reducing Rajaee to 4.692% — signed solely by "Tyler Davis, Manager." Note the two conflicting dates on its face: the body says "as of January 6, 2022," but the signature is hand-dated "01-20-22."
NO. 2
Membership Interest
4.692%
TopDevz, LLC · a California Limited Liability Company
"This Certifies that Ashkan Rajaee is the registered holder of a 4.692% Membership Interest in TopDevz, LLC … In Witness Whereof, the said Company has caused this Certificate to be signed by its duly authorized Manager as of January 6, 2022."
Tyler Davis
TYLER DAVIS, MANAGER
dtd 01-20-22
Two different dates on one certificateBody: "as of Jan. 6"; signature hand-dated "01-20-22"
View the certificate & email →Source: the membership certificate and transmittal email. The complaint identifies this certificate as forged (¶475), pointing to the date discrepancy and sole-Davis signature.
Why the certificate mattersThe complaint states the certificate is forged. On its face it is signed only by Davis as "Manager" and carries conflicting dates — the bases for that charge.
4
Jan. 21, 2022 — Davis's lawyer sends it to Rajaee
The certificate was transmitted by Davis's arbitration counsel, Scott Carpenter, framing it as Rajaee's "new membership certificate" that the manager was merely "required to update."
From: Scott R. Carpenter <scarpenter@cwlawyers.com> (Cummins & White, LLP) To: Connor Lynch Cc: Joe Scalia Date: Friday, January 21, 2022, 9:10 AM Subject: TopDevz, LLC — Membership Certificate — W383
"Per 7.3 of the operating agreement, the managing member is required to update the membership certificates over time as the capital changes. Mr. Rajaee never did this. Please see attached Mr. Rajaee's new membership certificate."
— Scott R. Carpenter, Cummins & White, LLP · Newport Beach, CA
Forwarded the same day → Connor Lynch (Lynch LLP) → Jordan Matthews (Weinberg Gonser) → Ashkan Rajaee ("See page 21").
"Mr. Rajaee's new membership certificate"Sent by Davis's counsel — Rajaee did not create it
The blitz, in sequenceOrder (Jan. 6) → bank seizure (Jan. 7) → new account → certificate reducing Rajaee to 4.692% (issued ~Jan. 20, sent Jan. 21). The complaint frames this two-week sequence as the operational seizure of the company.