Creedon, and through multiple frauds perpetrated under color of law, unlawfully obtained the paper titles to the five cars for which the Plaintiff held lawful title. At all times relevant to this action, he was an individual, a member and manager of Pugi Kia, LLC, which is licensed as a dealer of new and used cars and operates as a franchise of Kia Motors America, Inc.
Free sex chat with no register - Auto backdating bank cash contract dealerships fraud rebate
CREEDON, Individually and as Director of the Tri-County Auto Theft Unit, OFFICER STEVEN STELTER., Individually and as a Deputy of the Du Page County Auto Theft Task Force, VW CREDIT, INC., KIA MOTORS AMERICA, INC., hereby states as follows: PRELIMINARY STATEMENT This is a claim under the Racketeer Influenced and Corrupt Practice Act, § 18 U. The Plaintiff seeks redress for these frauds suffered as a consequence of Defendant’s scheme. Colando (“Colando”), Anthony Colando (“Anthony Colando”), Dominic L. Hall (“Hall”), controlled, managed and operated Pugi Kia, LLC (“Pugi Kia”) and employed salespeople, accountants, finance managers and attorneys to run the affairs of Pugi Kia and D & M Auto Sales, Inc. With the complicity of its agents and employees, Pugi Kia, Colando, Anthony Colando, Pugliani and Hall planned, organized and committed multiple frauds on the Plaintiff and his property. and Kia Motors America, Inc., the controllers and managers of Pugi Kia, along with its employees, organized and perpetrated a scheme that unlawfully deprived the Plaintiff of money and property. Defendants are found within this District, have agents in this District, conduct business in this District and the activities of the Defendants giving rise to this action occurred, in large part, in this District. Plaintiff David Kramer (“Kramer”) is a citizen and domiciliary of Missouri and resides at 3280 Yaeger Road, St. David Kramer is in the business of buying and selling new and used cars often through auction. Plaintiff Certified Car Sales, LLC is a limited liability company under the laws of Missouri and is wholly-owned by Plaintiff, David Kramer. (“Anthony Colando”) is a citizen and domiciliary of Illinois who currently resides 6N274 Robert Ct, Medinah, Illinois 60157. Michael Colando conducts additional business concerning the purchase, sale, transport, collateralization, and other aspects of trade in cars as D & M Auto Sales, Inc. Michael Colando’s sole partner in Pugi Kia, LLC is Defendant Dominic Pugliani.
Together with a series of related fraudulent acts and through conspiracy with each other and with other organizations, Colando, Anthony Colando, Pugliani and Hall negotiated with Plaintiff and conducted fraudulent 2 Case -cv-02530 Document 1 Filed 05/02/2008 Page 3 of 109 transactions tangential to what was to be the eventual purchase of Pugi Kia and its assets by the Plaintiff. He conducts his business 5 Case -cv-02530 Document 1 Filed 05/02/2008 Page 6 of 109 as Certified Car Sales, LLC and maintains business offices in 5419 Lemay Ferry, St. Its principal place of business is located at 5419 Lemay Ferry, St. At all times relevant to this action, he was an employee and manager of Pugi Kia, LLC, which is licensed as a dealer of new and used cars and operates as a franchise of Kia Motors America, Inc. 6 Case -cv-02530 Document 1 Filed 05/02/2008 Page 7 of 109 10. Creedon (“Creedon”) is a Director of the Tri-County Auto Theft Unit operating principally out of 20 West Washington Street, Joliet, Illinois 60432.
In early December, 2005 Pugliani recommended Plaintiff open an account at Oakbrook Bank and thereafter introduced Plaintiff to Darin Campbell at Oakbrook Bank, with whom Pugliani had a relationship, to facilitate the process of opening an account. In December, The Plaintiff opened an account at Oakbrook Bank under the name Pugi Kia, with Plaintiff as a signatory, and deposited $10,000. The Plaintiff had previously obtained financing in the amount of $500,000.00 from Parish National Bank in Florida and continued working with KMA to execute an effective application to operate a KMA franchise. On December 16, 2005, Plaintiff, Colando, Pugliani and Hall sign a Consulting Agreement whereby Plaintiff was to “assume full responsibility of the day to day operation of [Pugi Kia].” k.
By the end of December 2005, Plaintiff was at Pugi Kia every day running some of the operations. In running some of the day to day operations the Plaintiff became aware of liabilities of Pugi Kia which were not disclosed by Colando, Anthony Colando, Pugliani or Hall. Despite the execution of the Consulting Contracts, discussed infra, which provided that Plaintiff shall have access to all financial accounts and shall receive all funds payable to Pugi Kia as of December 16, 2005, Colando, Anthony Colando, Pugliani and Hall repeatedly refused to provide Plaintiff access to Pugi Kia’s corporate bank account. The Plaintiff remained interested in purchasing Pugi Kia and, upon discussing any discrepancies with respect to the assets and liabilities of Pugi Kia, received assurances 11 Case -cv-02530 Document 1 Filed 05/02/2008 Page 12 of 109 from Colando, Anthony Colando, Pugliani and Hall that his purchase price of shares of Pugi Kia would be reduced by the amounts which were not previously disclosed. As a result of these assurances, Plaintiff continued to partially run the day to day operations of Pugi Kia with the intent of purchasing the dealership.
COLANDO, ) deceased; DOMINIC MANCINI, ) Individually and as an attorney; PUGI KIA, ) LLC; D & M AUTO SALES, INC.; KIA ) ) MOTORS AMERICA, INC.; ) VW CREDIT, INC., ) Defendants.
) Case -cv-02530 Document 1 Filed 05/02/2008 Page 2 of 109 and in support of his VERIFIED COMPLAINT AT LAW against the Defendants, MICHAEL J.
In August and September of 2005, David Kramer was in the business of buying and selling used cars through sales mechanisms such as auction, leverage, and bulk and purchased these cars from diverse locations and markets through the central United States. Kramer conducted his business as the sole shareholder of Certified Car Sales, LLC, which he operated out of St. Shortly thereafter, Kramer contacted Pugi Kia’s fifty-percent owner Michael Colando who confirmed Pugi Kia’s availability and invited Kramer to Chicago.
Through Monthly Financial Statements, The Plaintiff Was Provided With A Fraudulent Rendering of Pugi KIA’s Assets and Liabilities 23. With him was his wife, Christine Kramer, (“Christine”), who is a licensed tax accountant.
Case -cv-02530 Document 1 Filed 05/02/2008 Page 1 of 109 IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION VERIFIED COMPLAINT AT LAW NOW COMES the Plaintiff, DAVID KRAMER, Individually, and as the Sole Owner of CERTIFIED CAR SALES, LLC, by and through his attorneys, KOMIE AND ASSOCIATES, 1 Case No. Plaintiff, DAVID KRAMER, Individually, and as the ) ) President and Sole Owner of CERTIFIED ) CAR SALES, LLC, a Missouri Limited ) Liability Company, ) ) ) ) ) SHERIFF’S DEPUTY STEVEN STELTER;) Individually and as a Deputy of the ) Du Page County Sheriff’s Office; JOHN P.
) ) CREEDON, Individually and as Director ) of the Tri-County Auto Theft Unit; ) MICHAEL J.
HALL, Individually and as a ) Manager of PUGI KIA, LLC; ANTHONY ) J. Individually and as a ) Manager of PUGI KIA, LLC; ANTHONY ) J.