STATE OF NORTH CAROLINA
COUNTY OF WAKE
MIRIAM BENARD; MARJORIE BILLER:
MICHAEL BODNAR; ANNE BODNAR;
KEVIN BONNER; SHANNON BONNER;
GREGORY BREUNICH; DANIELLE
BREUNICH; DOUGLAS BROWN;
BENJAMIN CARCAMO; GERARDO
CARCAMO: KAREN CARCAMO; MARIO
CARCAMO; CHARLES CATES; SARAH
CATES; WILLAM CHEAL;
CHRISTOPHER CIACCIO; MARSHALL.
HEATH CLAYTON; RANDALL CORBIN;
PATRICIA CORBIN; MAXFIELD CROOK;
JOANN CROOK; LAWRENCE
DOMONKOS; PATRICIA DOMONKOS:
OBINNA EKEZIE; ROBERT EMORY;
JEREMY FISHMAN; LINDA FRIMPONG;
KEITH GILMORE; JANE IFABANWO;
GABRIEL JARAMILLO; JONATHAN.
LILLY; JAMES MARCHICA; JOHNNY
MARONEY; NADINE MARONEY:
CHARLES McCARTHY; BRIGITTE
MeCARTHY; OWEN McCARTHY:
DOROTHIA McCARTHY: JONATHAN
MeCOY; JAMILA McCOY; JEFFERY
MoNEAL; THEODORE MEEK; JESSICA
MEEK; THEODORE MEEKMA;
KIMBERLY MELTOI
Jr; MARIAN MELTON; RONALD MUSE;
BRAD NORMAN; SUSAN NORMAN;
OBIORA NWUDE; ADRIENNE NWUDE;
NASEEM AFIMED; TANMEENA AHMED,
GREGORY ANDERSON; NATASHA
BEALE; BRANDON GOLDSTEIN; GARY
GRAY;JONATHAN GRAY; MARIAN
GRAY; THOMAS HAAR; MARIA HAAR;
KEVIN HANLEY; TERENCE HAVENS;
RAMONA HAVENS; ROBERT HEADLEY,
Jt; AUDRA HEADLEY; JENNIFER
OBIORA; AKINLOLU OLANEGAN,
LONNIE PARKER, Jr; MICHAEL PEREZ;
STEPHANIE PEREZ: JAMAL
PRITCHARD; BRUCE RANSOM,
(owets,00018)
ALLIAM MELTON,
So poy
IN THE GENERAL Gourr oF JUSTICE
SUPERIOR COURT DIVISION
spol MEILE.NQn OZ EY O14767,
Water ¢
HAE. COUNTY, OSC.
FIRST AMENDED COMPLAINT AND
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H JURY DEMAND
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iREBECCA RANSOM; MICHAEL REED;
CHRISTINE REED; PHILLIP RUSS;
MANAMI RUSS; JANIS SCHLEGEL; JOE
SCHLEGEL; JAMES SCHMEHL;
VICTORIA SCHMEHL; NANCY SCOTT;
MICHAEL STEAD; DONNA STEAD;
SOULEYMANE TALL; ADENIYI TELLA;
OKUBUNMI TELLA; DAVID TERRELL;
MICHAEL UGBOGBO; SAMUEL
WILLIAMOWSKY; TOMIKA WOODS;
TAMIKA WRIGHT; CHARLES ZOMBRO;
MICHAEL CRANDUS; ANIEKAN
EMMANUEL OFFIONG; JOHN COONEY;
MICHAEL COLBERT
Plaintiffs,
VS.
ANTHONY PORTER; SUNSET FUNDING
COMPANY; NEIL O'ROURKE; JOHN
PERRY; SECOR GROUP, LLC; SOURCE
ONE PROPERTIES, LLC; SOURCE ONE
COMMUNITIES, INC; H. LEE FARTHING;
STEPHEN M. RAYBORN; LUIS
CASTILLO; A. GREG ANDERSON;
BRANCH BANKING & TRUST
COMPANY; CAROLINA FIRST BANK;
FIRST CHARTER BANK; UNITED.
COMMUNITY BANK; and JOHN DOE
DEFENDANTS
Defendants.
Now come Plaintiffs identified in Section II(A) below, by and through counsel, and
for their First Amended Complaint allege as follows:
1, INTRODUCTION
1. Plaintiffs are victims of an elaborate and fraudulent Investment Scheme
developed, orchestrated and implemented by Defendants. While Defendants promised
and promoted seemingly legitimate investments in allegedly valuable real property in
Mitchell County, North Carolina, in reality, Defendants were operating a sophisticated
Page 2and highly successful fraudulent scheme designed for their sole benefit and to the
damage of Plaintiffs. As described herein, Defendants cloaked their scheme with
legitimacy lent by the involvement of seemingly sophisticated and reputable persons
and entities.
Wl, PARTIES, JURISDICTION & VENUE
A. Plaintiffs
2. Naseem Ahmed and Tahmeena Ahmed are residents of the State of
California and were induced to invest in the Investment Scheme described herein.
3. Gregory Anderson is a resident of the State of Texas and was induced to
invest in the Investment Scheme described herein.
4. Natasha Beale is a resident of Washington D.C. and was induced to
invest in the Investment Scheme described herein.
5. Miriam Benard is a resident of the State of Florida and was induced to
invest in the Investment Scheme described herein.
6. Marjorie Biller is a resident of the State of California and was induced to
invest in the Investment Scheme described herein.
7. Michael Bodnar and Anne Bodnar are residents of the Commonwealth of
Virginia and were induced to invest in the Investment Scheme described herein.
8. Kevin Bonner and Shannon Bonner are residents of the State of California
and were induced to invest in the Investment Scheme described herein.
9. Gregory Breunich and Danielle Breunich are residents of the State Florida
and were induced to invest in the Investment Scheme described herein.
10. Benjamin Carcamo is a resident of the State of Texas and was induced to
invest in the Investment Scheme described herein.
Page 3