Evidence walkthrough.
The facsimiles are reading aids. The PDF links open the underlying documents that should control.
Theme · Knowledge of Falsity
Not a mistake — they knew
A fraud theory needs intent. The filings state these weren't honest errors: counsel admitted the key facts in writing, were personally served the proof, and proceeded anyway. Scroll the evidence of knowledge.
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Bottom lineThis wasn’t a mistake: counsel admitted in writing that dissolution belonged in court and that Davis couldn’t get the votes — then proceeded anyway.
1
They admitted, in writing, the case belonged in court
Before pursuing arbitration of the dissolution, Davis's own counsel wrote that the claim was "within the exclusive jurisdiction of the Superior Court." You cannot accidentally arbitrate something you've acknowledged in writing can't be arbitrated.
From: Scott R. Carpenter (counsel for Davis) To: Scalia, Davis Date: February 5, 2021 (RICO complaint ¶252) Re: Dissolution jurisdiction
"We contend that the Complaint for Dissolution of the LLC and the concomitant procedures and remedies under Corporation Code §§ 17707.03, et seq. for the dissolution and winding-up of the LLC, are within the exclusive jurisdiction of the Superior Court."
Admitted in writing — then ignoredMaintained the arbitration anyway (Compl. ¶253)
The intent markerThe complaint states they "maintained the fraudulent arbitration proceeding to avoid judicial oversight and discovery of the underlying criminal activity." (¶253.)
2
They admitted Davis could never get the votes
Removing Rajaee as manager required a member vote. In his own October 2021 petition, Davis admitted he could not obtain it — yet the arbitration "removed" Rajaee anyway, and Davis later swore he "became the managing member."
DAVIS'S OWN PETITION · October 15, 2021 (Sacramento dissolution proceeding)
—Per the sanctions motion, Davis's petition admitted: "The Manager can only be removed by a majority of Members. Effectively, Davis cannot obtain a vote."
Yet Davis's later confirmation declarations swore: "After Order No. 4 was issued on January 6, 2022, I became the managing member of TopDevz." The two cannot both be true.
"Davis cannot obtain a vote"His own words — before claiming he became manager
They were personally served the proof — and continued
The sanctions motion states each attorney was personally served the PPP/money-laundering evidence, with page-pin citations, on specific dates — then kept advancing the same positions. Knowledge isn't inferred here; it's documented by service.
The "actual knowledge" packet
Served with PPP/laundering evidenceCarpenter, Kirk, Bailey,
Hays, Finlayson, Toffer
Notice dates (examples)Oct 27, 2023 · Jan 17, 2024 · Feb 15, 2024
Formpage-pinned evidence citations
Responsecontinued the same positions
Served, dated, page-pinnedThen they proceeded anyway
Fraud, RICO, and sanctions all turn on intent. Documented prior admissions plus documented service convert "they were wrong" into "they knew and did it anyway" — the difference between a losing argument and a knowing falsehood.
The three knowledge markers
1. Written admissiondissolution = Superior Court (Feb 2021)
2. Own-petition admission"Davis cannot obtain a vote" (Oct 2021)
The rule it triggers
"The court cannot and will not tolerate members of the bar employing the use of known falsehoods to further their objectives." — In re Girardi, 611 F.3d 1027, 1067 (9th Cir. 2010); Cal. Bus. & Prof. Code §6068(d) (duty of candor).