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Omer B. Yalincak, Ayfer Yalincak, Hale Yalincak, and Hakan Yalincak v. Michael J. Legamaro, Mary E. Siachitano, Mary E. Hatami, and Barack Ferrazzano Kirschbaum Perlman & Nagelberg, LLP et al RICO Statement

Omer B. Yalincak, Ayfer Yalincak, Hale Yalincak, and Hakan Yalincak v. Michael J. Legamaro, Mary E. Siachitano, Mary E. Hatami, and Barack Ferrazzano Kirschbaum Perlman & Nagelberg, LLP et al RICO Statement

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Published by Hakan Yalincak
Publicly available copy of RICO statement attached to lawsuit filed by Omer B. Yalincak, Ayfer Yalincak, Hale Yalincak, and Hakan Yalincak against their former attorneys and worker, Michael J. Legamaro, Mary E. Siachitano, Mary E. Hatami, Barack Ferrazzano Kirschbaum Perlman & Nagelberg, LLP, and others. Lawsuit was settled in 2009 for undisclosed sum.
Publicly available copy of RICO statement attached to lawsuit filed by Omer B. Yalincak, Ayfer Yalincak, Hale Yalincak, and Hakan Yalincak against their former attorneys and worker, Michael J. Legamaro, Mary E. Siachitano, Mary E. Hatami, Barack Ferrazzano Kirschbaum Perlman & Nagelberg, LLP, and others. Lawsuit was settled in 2009 for undisclosed sum.

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Published by: Hakan Yalincak on Aug 26, 2012
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UNITED STATES DISTRICT COURTFOR THE DISTRICT OF CONNECTICUTOMER BULENT YALINCAK, )AYFER YALINCAK AND HALE YALINCAK, ))Plaintiffs ) CIVIL NO. 3:07-CV00311 (AVC))V. ))BARACK FERRAZZANO KIRSCHBAUM )PERLMAN AND NAGELBERG, LLP, ET. AL., ))Defendants )
PLAINTIFFS’ RICO CASE STATEMENT
The Plaintiffs Omer Bulent Yalincak, Ayfer Yalincak, and Hale Yalincak (hereinafter the “Plaintiffs”), pursuant to this Court’s Standing Order In Civil RICOCases, respectfully submit this RICO Case Statement.
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In support of their RICO Claims as stated in their Claim’s For Relief (the “RICOClaims”), paragraphs 13 to 15 of the Second Amended Complaint, the Plaintiffs, uponpersonal knowledge and information and belief, hereby allege as follows:
I.
 
INTRODUCTION TO DEFENDANTS’ UNLAWFUL ACTIVITY
1.
 
From on or about November 4, 2003, up to and including thepresent, in the District of Connecticut and elsewhere, the defendants Michael J.Legamaro (“Legamaro”) and Mary E. Hatami, f/k/a Mary E. Siachitano (“Hatami”), eachof whom was employed by and associated with the Plaintiffs through their family holdingcompany, their alter ego, HMMH Holdings, LLC (“HMMH”), an enterprise engaged inand the activities of which, affect interstate commerce, did unlawfully, willfully and
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Terms used but not defined herein shall have the meanings ascribed to them in the Plaintiffs’ SecondAmended Complaint.
Case 3:07-cv-00311-AVC Document 101 Filed 08/25/08 Page 1 of 59
 
 
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knowingly conduct and participate, directly and indirectly, in the conduct of HMMH’saffairs through a pattern of racketeering activity, which included, but was not limited to,mail fraud (18 U.S.C. §1341), bank fraud (18 U.S.C. §1344), wire fraud (18 U.S.C.§1343), obstruction of justice (18 U.S.C. §1503), extortion (18 U.S.C. §1951), andmoney laundering (18 U.S.C. §1956), all in violation of the following, as more fullydescribed in Part V below:a.
 
acquired an interest in or control of HMMH, a RICO enterprise, through apattern of racketeering activity, in violation of 18 U.S.C. §1962(b);b.
 
conducting or participating in the conduct of an enterprise’s affairsthrough a pattern of racketeering activity, in violation of 18 U.S.C.§1962(c);c.
 
conspiring to violate 18 U.S.C. §§1962(b) and 1962(c), in violation of 18U.S.C. §1962(d).2.
 
As a result of the foregoing and the conduct of the defendants asmore particularly described below, the Plaintiffs have been damaged.
II.
 
DEFENDANTSA.
 
Michael J. Legamaro
3.
 
Defendant Legamaro is a citizen and resident of the State of Illinois. At all times relevant hereto, Defendant Legamaro served as general counsel tothe Plaintiffs; trustee of all of the Plaintiffs’ trusts; executor of each of the Plaintiffs’estates; board member and counsel to HMMH and its affiliates and subsidiaries;authorized signator on HMMH’s bank accounts at Bank One, n/k/a J.P. Morgan Chase,Chicago, Illinois and UBS, AG, Zurich Swtizerland as more fully detailed below.4.
 
At all times relevant hereto, Defendant Legamaro was employedby Barack Ferrazzano Kirschbaum Perlman & Nagelberg, LLP, n/k/a Barack FerrazzanoKirschbaum & Nagelberg, LLP (“BFKPNLLP”), a Chicago, Illinois law firm.
Case 3:07-cv-00311-AVC Document 101 Filed 08/25/08 Page 2 of 59
 
 
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B.
 
Mary E. Hatami , f/k/a Mary E. Siachitano
5.
 
Defendant Hatami is a citizen and resident of the State of NewYork. At all times relevant hereto, Defendant Hatami served as Vice President of HMMH, including its affiliates and subsidiaries; friend of the trust to the Plaintiffs’trusts; friend of the estate to the Plaintiffs’ estates; board member of HMMH; authorizedsignator on HMMH’s bank accounts at Bank One, n/k/a J.P. Morgan Chase, Chicago,Illinois and UBS, AG, Zurich, Switzerland as more fully detailed below.
C.
 
HMMH AND THE DEFENDANTS
6.
 
HMMH was and is a Delaware limited liability company formedon or about October 1, 2004, by Defendant Legamaro and Defendant Hatami, with aprincipal place of business in Greenwich, Connecticut. At all times relevant hereto,HMMH was affiliated with HMMH St. Lucia, Ltd., a St. Lucia limited company formedand operated by Defendant Legamaro and Defendant Hatami. HMMH was the parentcompany, directly or indirectly, of the following entities:a.
 
Daedalus Capital Partners, LLC, a Delaware limited liability company;b.
 
Daedalus Capital (Cayman), LLC, a Cayman limited liability company;c.
 
Daedalus Capital Relative Value Fund I, LLC, a Delaware limited liabilitycompany;d.
 
Daedalus Capital Relative Value Portfolio, LLC, a Delaware limitedliability company;e.
 
SACS Capital Group, LLC, a Delaware limited liability company;f.
 
SACS Global Trust & Mortgage, LLC, f/k/a Greenwich Trust &Mortgage, Inc., a Delaware limited liability company;g.
 
SACS Special Financing I, LLC, a Delaware limited liability company;h.
 
Yasam Trading, LLC, f/k/a Greenwich Special Financing I, LLC, aDelaware limited liability company;
Case 3:07-cv-00311-AVC Document 101 Filed 08/25/08 Page 3 of 59

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