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 t 1 i ! 1 | | ' i t i | | } i ! | 1 i ' | | | | } | i H JURY DEMAND i | | t t | | i | i H ' ! [ { 1 | i | ' | i | i ' | | iREBECCA 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 2and 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