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Gregg D. Trautmann, Esq.TRAUTMANN & ASSOCIATES, L.L.C.262 East Main StreetRockaway, New Jersey 07866(973) 983-7700Attorneys for Plaintiff 
UNITED STATES DISTRICT COURTDISTRICT OF NEW JERSEY
 EAST FORK INVESTMENT GROUP, LLC (ALimited Liability Company organized under thelaws of the State of North Carolina)Plaintiff v.KENNEDY FUNDING, INC. (A New JerseyCorporation); JEFFREY WOLFER; KEVINWOLFER; GREGG WOLFER; JOHN DOE 1
 – 
 100 (Fictitious names for the person(s),attorneys and/or entity responsible for thedamages complained of by the Plaintiff herein)DefendantsCivil Action No.:
COMPLAINT AND JURY DEMAND
 
Civ. Rule 10.1 Statement
PLAINTIFF:
EAST FORK INVESTMENT GROUP, LLC is a Limited Liability Company organizedunder the laws of the State of North Carolina.LEGASUS OF NORTH CAROLINA, LLC is a corporation organized under the laws of the State of North Carolina. LEGASUS OF NORTH CAROLINA, LLC is the sole member of EAST FORK INVESTMENT GROUP, LLC.
DEFENDANTS:
Case 2:09-cv-01193-SDW-MCA Document 1 Filed 03/17/2009 Page 1 of 122
 
 
KENNEDY FUNDING, INC., is a corporation organized under the laws of the State of New Jersey and has its corporate offices and principal place of business located at TwoUniversity Plaza, Suite 402, in the City of Hackensack, County of Bergen and State of NewJersey.JEFFREY WOLFER is an individual, a citizen of the United States and a resident of theState of New Jersey. JEFFREY WOLFER is a shareholder of KENNEDY FUNDING, INC. andmaintains a business office at Two University Plaza, Suite 402, in the City of Hackensack,County of Bergen and State of New Jersey.GREGG WOLFER is an individual, a citizen of the United States and a resident of theState of New Jersey. GREGG WOLFER is a shareholder of KENNEDY FUNDING, INC. andmaintains a business office at Two University Plaza, in the City of Hackensack, County of Bergen and State of New Jersey.KEVIN WOLFER is an individual, a citizen of the United States and a resident of theState of New Jersey. KEVIN WOLFER is a shareholder of KENNEDY FUNDING, INC. andmaintains a business office at Two University Plaza, Suite 402, in the City of Hackensack,County of Bergen and State of New Jersey.
JURISDICTION
1.
 
Plaintiff brings these claims against Defendants to redress violations of the statutes of theState of New Jersey and the common law.2.
 
This Court has jurisdiction over this matter pursuant to 28 U.S.C. §§1332.3.
 
The amount in controversy exceeds $75,000.00.4.
 
Venue is proper in this District pursuant to 28 U.S.C. §1391.
Case 2:09-cv-01193-SDW-MCA Document 1 Filed 03/17/2009 Page 2 of 122
 
 
FACTS COMMON TO ALL COUNTS OF COMPLAINT
 
Plaintiff EAST FORK INVESTMENT GROUP, LLC by way of Complaint against theabove named Defendants says:1.
 
KENNEDY FUNDING, INC., (hereinafter referred to as “KFI”)is a corporation
organized under the laws of the State of New Jersey.2.
 
KFI has its corporate headquarters and principal place of business located at TwoUniversity Plaza, Suite 402, in the City of Hackensack, County of Bergen and State of New Jersey.3.
 
JEFFREY WOLFER is, upon information and belief, a resident of the State of NewJersey.4.
 
JEFFREY WOLFER maintains a business office at Two University Plaza, Suite 402,in the City of Hackensack, County of Bergen and State of New Jersey.5.
 
JEFFREY WOLFER is the President and Co-Chief Executive Officer of KFI.6.
 
JEFFREY WOLFER derives income from KFI.7.
 
GREGG WOLFER is, upon information and belief, a resident of the State of NewJersey and a citizen of the United States.8.
 
GREGG WOLFER maintains a business office at Two University Plaza in the City of Hackensack, County of Bergen and State of New Jersey.9.
 
GREGG WOLFER currently is an Officer and one third shareholder of KFI.10.
 
GREGG WOLFER derives income from KFI.11.
 
KEVIN WOLFER is, upon information and belief, a resident of the State of NewJersey and a citizen of the United States.
Case 2:09-cv-01193-SDW-MCA Document 1 Filed 03/17/2009 Page 3 of 122
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