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Kyko Global Inc. Files Complaint against Madhavi Vuppalapati & Prithvi Info Solutions Ltd

Kyko Global Inc. Files Complaint against Madhavi Vuppalapati & Prithvi Info Solutions Ltd

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Published by Megan Finley
This is the complaint copy by United States District Court of Washington filed by Kyko Global Inc against Madhavi Vuppalapati & Prithvi Info Solutions Ltd
This is the complaint copy by United States District Court of Washington filed by Kyko Global Inc against Madhavi Vuppalapati & Prithvi Info Solutions Ltd

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Published by: Megan Finley on Apr 04, 2014
Copyright:Traditional Copyright: All rights reserved

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04/14/2014

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PAGE 1 – COMPLAINT
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S
LINDE
 N
ELSON
 S
TANFORD
601 Union Street, Suite 4400Seattle, WA 98101 p. 206-237-0020; f. 503.417.4250
UNITED STATES DISTRICT COURTWESTERN DISTRICT OF WASHINGTONAT SEATTLEKYKO GLOBAL, INC., a Canadiancorporation, and KYKO GLOBAL GMBH, aBahamian corporation,Plaintiffs,v.PRITHVI INFORMATION SOLUTIONS,LTD., a Pennsylvania corporation, PRITHVICATALYTIC, INC., a Delaware corporation,PRITHVI SOLUTIONS, INC., a Delawarecorporation, PRITHVI INFORMATIONSOLUTIONS INTERNATIONAL, LLC, aPennsylvania limited liability company,INALYTIX, INC., a Nevada corporation,INTERNATIONAL BUSINESSSOLUTIONS, INC., a North Carolina,corporation, AVANI INVESTMENTS, INC., aDelaware corporation, ANANYA CAPITALINC., a Delaware corporation, MADHAVIVUPPALAPATI AND ANANDHANJAGARAMAN, husband and wife and themarital community composed thereof, GURUPANDYAR AND JANE DOE PANDYAR,husband and wife and the marital communitycomposed thereof, and SRINIVAS SISTAAND JOHN DOE SISTA, husband and wifeand the marital community composed thereof,DCGS, INC., a Pennsylvania company, EPP,INC., a Washington corporation, FINANCIALOXYGEN, INC., a Washington corporation,Case No.
COMPLAINTJURY TRIAL DEMANDED
Case 2:13-cv-01034-MJP Document 1 Filed 06/17/13 Page 1 of 27
 
PAGE 2 – COMPLAINT
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601 Union Street, Suite 4400Seattle, WA 98101 p. 206-237-0020; f. 503.417.4250
HUAWEI LATIN AMERICAN SOLUTIONS,INC., a Florida corporation, L3C, INC., aWashington corporation.Defendants.Plaintiffs Kyko Global, Inc. and Kyko Global GmbH (hereinafter, collectively “Kyko”), by and through their counsel, Slinde Nelson Stanford, for its Complaint allege as follows:
I. INTRODUCTION
1. This action arises out of the wrongful acts of Defendants relating to PrithviInformation Solutions, Ltd. and its affiliates, officers, directors and certain individuals acting inconcert to defraud, deceive and/or misrepresent the existence of certain customer accountreceivables pledged to Plaintiffs as security for certain advances made to PISL pursuant to anagreement for the factoring of customer account receivables. Defendants engaged in aconspiracy to create fictitious, counterfeit customers and associated accounts receivable in order to induce Kyko to advance over $17 million in funds, or otherwise to induce Kyko to purchaseover tens of millions of dollars of sham receivables. As a result of such wrongful conduct and bymisrepresenting the true nature of the operations, Defendants concealed the fact that thecustomer accounts receivables did not exist, and, more significantly, hid the fact that Kykowould never be paid back directly from the customers as promised. By May 28, 2013, Kyko wasowed over $17 million from PISL. Due to Defendants’ collective deceptive and wrongfulconduct and prior scheme to transfer assets among the multiple Defendants (both in the U.S. andforeign countries) to evade creditors as part of its fraudulent scheme, Plaintiffs also seek aTemporary Restraining Order and Preliminary Injunction enjoining any transfers or sales of assets and freezing the monies held in certain identified bank accounts, and any other financialinstitutions used to facilitate prior transfers, and any interest any Defendant holds in anymonetary accounts receivables, in order to maintain the status quo. In addition to seeking
Case 2:13-cv-01034-MJP Document 1 Filed 06/17/13 Page 2 of 27
 
PAGE 3 – COMPLAINT
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601 Union Street, Suite 4400Seattle, WA 98101 p. 206-237-0020; f. 503.417.4250
injunctive relief and damages under Plaintiffs’ common law claims, as set forth herein, Plaintiff seeks remedies and damages under RICO as authorized by the federal statutes at 18 USC §1961
et seq,
 including mandatory treble damages.2. Defendant-Guarantors have executed guarantees with Kyko promising to pay infull any and all obligations owed to Kyko under the factoring agreement entered into by PrithviInformation Solutions, Ltd., and Kyko on November 21, 2011. Each of the Defendant-Guarantors have failed to honor or otherwise pay the amounts owed to Kyko on demand.Defendants have engaged in a conspiracy to defraud and embezzle funds from Kyko by creatingcustomer account receivables that do not exist and fictitiously corresponding with Kyko by posing as such customers in order to facilitate additional monetary transfers. Upon discovery of such wrongful conduct, Kyko made demand on the Defendant-Guarantors and such demandshave not been met. More than $17 million is owed to Kyko for fictitious accounts receivablecreated by Defendants’ wrongful acts.
II. PARTIES
3. Plaintiff Kyko Global, Inc. is a Canadian corporation with its principal place of  business in Ontario, Canada. Plaintiff Kyko Global GmbH is a wholly-owned subsidiary of Plaintiff Kyko Global, Inc. with its principal place of business in the Bahamas. Together, Kykooffers accounts receivable factoring services.4. Defendant Prithvi Information Solutions, Ltd., (“PISL”) is a Pennsylvaniacorporation and, on information and belief, conducts business in the State of Washington.Defendant Madhavi Vuppalapati (“Madhavi”) is one of PISL’s directors.5. Defendant Prithvi Catalytic, Inc. (“Catalytic”) is a Delaware corporation and isregistered with the Washington Secretary of State to do business in the State of Washington andwith its principal place of business in Bellevue, Washington. Catalytic’s sole officer isDefendant Madhavi.
Case 2:13-cv-01034-MJP Document 1 Filed 06/17/13 Page 3 of 27

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