Plaintiffs Angelina Masheyeva, Vadim Vorobyov, Jean Jones, Victor Jones, BenVarkey, Leela Varkey, Thomas Varkey, George Harrington, Jr., JoAnn Harrington, MikeWood, Colleen Petrishin, Patsy Biondo, Salvatore Biondo, Charlene Farino, CynthiaStewart, Todd Dean, Isiah Slaughter and Beverly Deas (collectively, "Plaintiffs"), by andthrough their undersigned attorneys, Davis Polk & Wardwell LLP, and Linda
Mullenbach and Meredith Horton, appearing on behalf
the Lawyers' Committee forCivil Rights Under Law (the "Lawyers' Committee"), as and for their complaint againstthe Law Offices
Green, Green Law Group PLLC, SBLC Consultants LLC(a/k/a American Home Crisis Center), American Economic Advocates LLC (a/k/aLincoln First Credit Services), Law Office
Brett Margolin, P.C.,
Capital, Inc.,David M. Green, Jason Green, Chris Rascionato, Tom Liguori, Barry Cohen, JosephRivera, Michael Dreitlein, Peter Orena, Marilyn Mader, Corey Singer, Karen Clark,Howard Gelfand, Brett Margolin, Dan Phillips, and Kevin Allison (collectively,"Defendants"), hereby allege the following based upon personal knowledge as toPlaintiffs and their own acts and documents, and information and belief
to all othermatters based upon,
the investigation conducted by and through Plaintiffs'attorneys, which included, but was not limited to, a review
Defendants' publicdocuments, public filings, interviews
Plaintiffs and other homeowners and personswho have had contact with Defendants, and information readily obtainable on the Internet.
Plaintiffs are a group
homeowners who were defrauded out
dollars as a result
loan modification scams perpetrated by Defendants.