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UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF FLORIDA


MIAMI DIVISION
CASE NO.: 10-cv-21654
VIRENDRA RAJPUT AKA VEDANT
RAJPUT; and MANSINGH RAJPUT;
Plaintiffs,
vs.
CITY TRADING LLC, a Florida company;
CHAND REALTY LLC, a Florida company;
and CHAND SAYED MASOOD, an individual;
Defendants.
/
COMPLAINT AND JURY TRIAL DEMAND
Plaintiffs VIRENDRA RAJPUT aka VEDANT RAJPUT (Vedant Rajput or Vedant)
and MANSINGH RAJPUT (Mansingh Rajput or Mansingh) (collectively, Plaintiffs), sue
defendants CITY TRADING LLC (City Trading), CHAND REALTY LLC (Chand Realty),
and CHAND KAUSAR MOHAMED aka CHAND SAYED MASOOD (Chand Masood or
Chand) (collectively, Defendants) and allege:
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INTRODUCTION
1. This litigation concerns an international scheme undertaken by individuals and the
business entities they formed (collectively referred to as the City Group Companies), including
companies and individuals in Florida, where funds embezzled from thousands of people
including plaintiffs Vedant Rajput and his father Mansingh Rajput were diverted, hidden and
laundered.
2. At the core of this illegal activity is the Masood family, including defendant
Chand Masood (the first wife of Sayed Masood), who resides in Florida. Sayed Masood, a
resident of India who had been on the run from authorities since August 2009, was finally
arrested in India in February 2010 for his role in the pattern of illegal activities at issue here. The
activities of the Masoods and the City Group Companies have been the subject of much press
coverage in numerous international newspapers, as is the India authorities reported belief that
more than Rs 1,000 crore or about $250 million fraudulently obtained from investors
(including Plaintiffs) were diverted to the City Group Companies in the United States run by
defendant Chand Masood, as set forth in the newspaper article attached as Exhibit A.
3. Plaintiffs Vedant Rajput and Mansingh Rajput entrusted nearly $376,000.00 to the
City Group Companies and their officers, management, subsidiaries and affiliates, based on the
promise that they would be paid $1,630,800.00 over the next five years. However, Plaintiffs
now know that they were the victims of activities designed to defraud them and deprive them of
their money.
4. Defendants participated in these illegal activities, including by concealing the
wrongfully obtained money through the City Group Companies wrongdoing by, inter alia,
investing in real property in Florida and laundering the investors converted money through
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Florida businesses, as part of a plan and a practice of getting the money out of India and into the
United States.
JURISDICTION AND VENUE
5. This Court has subject matter jurisdiction over this action pursuant to 18 U.S.C.
1964, 18 U.S.C. 1331 and 28 U.S.C. 1332(a).
6. Venue is proper in this judicial district pursuant to 18 U.S.C. 1965 and 28
U.S.C. 1391(b). Among other things, Defendants are all subject to personal jurisdiction in this
judicial district and reside in this district.
PARTIES
7. Plaintiff Vedant Rajput is a citizen of Canada residing in Mississauga, Ontario.
8. Plaintiff Mansingh Rajput is a citizen of India residing in Mumbai, India.
9. Defendant City Trading is a Florida limited liability company with its principal
place of business in Coral Gables, Florida.
10. Defendant Chand Realty is a Florida limited liability company with its principal
place of business in Miami, Florida.
11. Defendant Chand Masood is an individual residing in Miami, Florida.
GENERAL ALLEGATIONS
12. This action concerns a multi-million dollar fraud, which has depleted life savings,
drained retirement accounts, and caused significant loss to numerous people, including Plaintiffs.
The Masood Family and the City Group Companies
13. At the heart of the wrongdoing is the Masood family, including Sayed Masood,
his first wife and defendant Chand Masood. The Masoods began their wrongdoing with the
formation of the City Group Companies, a group of international companies which, according to
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the website of Defendant City Trading (a copy of which is attached as Exhibit B), include, inter
alia, Defendant City Trading in Florida, City Limouzines (India) Ltd. (City Limouzines) in
India, and City Realcom Ltd. (City Realcom) in India (collectively, City Group Companies).
14. In 2005, defendant Chand Masood entered, and initially stayed in, the United
States on an L1A visa, which is an intra-company transfer visa, a requirement of which is that
the applicant be coming to the United States to continue providing services to the same
employer. Chand Masood was sent by the City Group Companies in India to set up office in the
United States; she thereby set up and managed Defendant City Trading.
15. The City Group Companies purported to engage in vehicle leasing, fleet
management, and hospitality services. According to a portion of City Tradings website (a copy
of which is attached as Exhibit C):
City Trading LLC is an export outfit of City Limouzines (India) Ltd that
has been operational in the business of vehicle leasing and fleet
management since two decades. Through tremendous growth,
organizational changes and fleet management industry innovations,
Mumbai-based City Limouzines (India) Ltd. now has its offices at Delhi,
Chennai, Bangalore, Hyderabad & even USA and is one of the leading
names in the Indian business scenario of vehicle leasing and fleet
management. Its clientele includes major corporate, SMEs, PSUs, and sole
traders.
16. The City Group Companies also purportedly were involved in exporting
diamonds, jewelry and garments. Another page from City Tradings website, a copy of which is
attached as Exhibit D, states that City Trading is a sourcing and exporting company that
provides compelling results in the areas of Jewelry, diamonds, and garments.
17. The connection between Defendant City Trading and the City Group Companies
in India is further evidenced by the facts, for example, that newspaper advertisements for City
Realcom list the Branch[es] of City Group of Companies as including those in the USA (i.e.,
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City Trading), and newspaper advertisements for City Limouzines lists a branch in the USA, and
includes the phone number, which is the phone number for City Trading in Florida. (See
Exhibits F and G, copies of which are attached). City Limouzines contact us web page
(which has since been taken down from the Internet), a copy of which is attached as Exhibit E,
lists the City Trading office in Florida.
18. The City Group Companies also include common directors, including Mr. Manoj
Vighe, who acts as director for Defendant City Trading, as well as for City Limouzines and City
Realcom.
The Fraud on Plaintiffs and Other Investors
19. The City Group Companies offered investment opportunities to the public,
promising returns as high as 48% annually. Several thousand people worldwide invested with
the City Group Companies, including Plaintiffs Vedant and Mansingh Rajput. The City Group
Companies attracted investors by asking for a minimum investment of Rs 139,000
(approximately $3,021.00) with a promise that the investor would receive 60 monthly payments
of Rs 7,775 (approximately $170.00) over a period of five years. Typically, barring interest,
investors would break even after the seventeenth check was cashed.
20. The money invested in the City Limouzines scheme of the City Group Companies
was to be used to buy cars, which were to be registered in investors names. Investors were to be
paid the profit from the income generated by hiring out the vehicles. The vehicles were to be
returned to investors after five years. Money invested in the City Realcom scheme of the City
Group Companies was to be used to buy properties. Each investor was to be a tentative owner of
a twenty square foot area for a period of five years. Investors were to be paid the monthly profit
from income generated by leasing out the twenty square foot space.
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21. As reported in various newspapers (see, e.g., Exhibit H, a copy of one such
article), the investments were so attractive that the City Group Companies office in India was
bursting at its seams with people bringing in bags full of money, thinking their currency would
get tripled. There were teller machines and currency notes were being calculated. On
information and belief, some investors sold their cars and homes to invest in the City Group
Companies, and others invested their lifes savings and their retirement money. (See id.).
22. Plaintiff Vedant Rajput invested a total of $284,550.00 with City Realcom and
City Limouzines. He invested in what was described in the City Group investment brochure (a
copy of which is attached as Exhibit I) as the Combo Pack scheme. (See Exhibit I at 21).
Vedant Rajput made 50 investments with City Realcom and City Limouzines on September 1,
2008 and September 4, 2008, all evidenced by written contracts. Pursuant to his contracts, he
was promised monthly payments comprised of twelve monthly payments of $18,000.00 in the
first year of his investment, twelve monthly payments of $18,350.00 in the second year of his
investment, twelve monthly payments of $18,700.00 in the third year of his investment, twelve
monthly payments of $19,150.00 in the fourth year of his investment, and twelve monthly
payments of $19,600.00 in the fifth year of his investment.
23. Plaintiff Mansingh Rajput invested a total of $91,400.00 with City Realcom and
City Limouzines. He invested in what was described in the City Group investment brochure as
the City Limouzine scheme and the City Realcom Scheme. (See Exhibit I at 5, 22). He
made 35 investments with City Realcom and City Limouzines on the following dates: 5/9/07,
7/31/07, 1/28/08, 6/20/08, 7/7/08, 7/25/08, 8/7/08, 9/9/08, 9/10/08, 9/24/08, 10/24/08, 11/04/08,
11/19/08, 1/17/09 and 3/25/09, all evidenced by written contracts. Pursuant to his contracts, he
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was promised monthly payments totaling approximately $6,000.00 per month for a period of five
years.
24. On information and belief, unbeknownst to Plaintiffs and the other investors, the
City Group Companies promises were fraudulent. On information and belief, the City Group
Companies had no intent to make the payments to investors as promised. Instead, the City
Group Companies converted and embezzled the money from the investors, including from
Plaintiffs, for the benefit of the Masood family, including defendant Chand Masood.
25. In its effort to appear legitimate and lucrative in order to lure investors, the City
Group Companies made payments to investors for a period of time. Plaintiff Vedant Rajput, for
example, received a total of $198,000.00 over 11 months. Plaintiff Mansingh Rajput received a
total of $46,480.00 since the time he made the first investment in May of 2007.
26. Beginning August 11, 2009, however, checks written to Plaintiffs and to other
investors began bouncing. Thereafter, the checks stopped coming. The City Group Companies
closed their doors, keeping for themselves and their principals, the Masood family members, the
wrongfully obtained money. Plaintiff Vedant Rajput is still owed $927,600.00. Plaintiff
Mansingh Rajput is still owed $333,319.00.
27. In or around December 2009, the Economic Offences Wing of the Mumbai police
formed a special investigative team to look into the City Group Companies fraud. Several
police complaints were filed against the City Group Companies in India, against Sayed Masood,
and against other individuals involved with the City Group Companies. As set forth in an April
4, 2010 article in The Financial Press (a copy of which is attached as Exhibit J), the City Group
Companies (or those based in India) are charged with duping 25,000 investors who had invested
in its various schemes promising high returns.
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28. Articles which appeared in the press reported that Sayed Masood hid from the
authorities for some time. (See news report, a copy of which is attached as Exhibit K). He and
his second wife, Seema, eventually were arrested in February 2010 at a resort in Alwar, India at
which they were hiding. Also arrested in connection with the fraud were Seemas brother
Amber, Prateek Kanakia, an accomplice of Sayed Masood, Geeta Razzaki, a City Group
Companies director, and her husband Umar Razzaki, also a director.
Money Laundering and Other Wrongdoing by Defendants
29. The City Group Companies converted and diverted the funds invested by
Plaintiffs and others including, on information and belief, by moving the funds to, among others,
defendants Chand Masood, Chand Trading and Chand Realty in Florida, including by means of
fabricated diamond exports. Some of the diverted funds have been used to purchase real
property in Florida. On information and belief, other funds were placed in a bank account with
Credit Suisse, and were used to purchase resorts, all for the benefit of the Masood family. As set
forth in the copy of the newspaper article attached as Exhibit L, some funds were even used to
fund Bollywood movies, again for the benefit of the Masood family.
30. Although defendant Chand Masood purportedly ran Defendant City Trading in
Florida, Sayed Masood was involved in hiring City Tradings employees, who purportedly were
to report to him, and signed checks for Defendant City Trading. On information and belief,
Sayed Massod traveled to Florida from India with books and records of the City Group
Companies in India, and instructed City Trading employee(s) to enter the information from those
books and records into the records of City Trading, in connection with the laundering of money
taken from the City Group Companies investors. On information and belief, Sayed Masood
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eventually stopped coming to the City Trading office, and the employees thereafter reported to
defendant Chand Masood.
31. Large sums of money stolen from the City Group Companies investors were
transferred from the City Group Companies in India to Defendant City Trading in Florida. On
information and belief, some of the large transfers were recorded on the City Trading books as
loans from the City Group Companies in India; other deposits were recorded as commissions
paid to City Trading by the City Group Companies in India. For example, as stated on the
ABN-AMRO Bank letter dated November 8, 2005, a copy of which is attached as Exhibit M,
City Limouzines made several transfers to City Trading as investments, including $100,000.00
on February 25, 2005, $50,000.00 on May 10, 2005 and $50,000 on November 2, 2005. On
January 2, 2007, City Limouzines transferred another $85,000.00 to Defendant City Trading as
equity participation, as reflected on the ABN-AMRO Bank letter dated January 10, 2007, a
copy of which is attached as Exhibit N.
32. On information and belief, City Trading had few or no legitimate customers, and
operated on the funds embezzled from Plaintiffs and the other City Group Companies investors.
On information and belief, City Trading purchased 100 rugs from India to make it appear that the
company was selling rugs, but in the last five years, not one rug was sold.
33. On information and belief, despite its lack of income, City Trading paid a salary
to defendant Chand Masood, whose salary was, in reality, laundered proceeds of the massive
fraud perpetrated on the City Group Companies investors. Chand Masood, who never came to
the office or did any work, drew a salary of several thousand dollars per month.
34. Although this salary was insufficient to allow her to afford and maintain real
property worth millions of dollars, and despite the lack of other legitimate means of income,
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Chand Masood, on August 30, 2005 just months after setting up City Trading in January 2005
purchased a villa at 2000 S. Bayshore Drive, Villa 19, Coconut Grove, FL for $1.2 million.
(See Exhibit O, a copy of the MiamiDade.gov sales history detail showing that the property was
sold in August 2005 for $1.2 million; see Exhibit P, a copy of a Quit Claim Deed indicating the
owner of the property as Chand Masood). On information and belief, the property was
purchased and maintained with cash converted from the City Group Companies investors and
diverted to defendant Chand Masood. On November 4, 2008, Chand executed a quit claim deed
to defendant Chand Realty for $10. (See Exhibit P; see also Exhibit Q, a copy of the
MiamiDade.gov property information report). On information and belief, Chand Realty also
operates using money converted from the City Group Companies investors. Chand Realty paid
$18,478.84 in property taxes on November 30, 2009 using funds which, on information and
belief, were converted from the City Group Companies investors. (See Exhibit R, a copy of the
2009 tax information page for the property from the miamidade.gov website).
35. Although her City Trading salary again was insufficient to allow her to afford and
maintain real property worth millions of dollars, and despite the lack of other legitimate means of
income, Chand Masood, in May 2008, again purchased real property, at 2627 S. Bayshore Drive,
Suite 2202 Miami, FL 33133, for $2.6 million, and subsequently maintained and paid taxes and
fees on said property. (See Exhibit S, a copy of the MiamiDade.gov property report showing
Chand Masood as the owner of the property, and Exhibit T, a copy of the sales history detail
from the same website showing that the property was purchased in May 2008 for $2.6 million).
On information and belief, the property again was purchased with cash converted from the City
Group Companies investors and laundered through defendant Chand Masood. On information
and belief, Chand Masood used such converted funds to pay more than $40,000 in property taxes
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in December 2009. (See, Exhibit U, a copy of the 2009 tax information page for the property
from the miamidade.gov website).
36. Again, although her salary was insufficient to allow Chand Masood to afford and
maintain real property worth millions of dollars, and despite the lack of other legitimate means of
income, Chand Masood, together with Jabeen Masood (daughter of Chand and Sayed Masood),
through Kanu Realty Pvt Ltd. (which is owned 50% each by Chand and Jabeen Masood),
purchased real property in Mumbai, India worth 15 crores (approx $3.3 Million). As reported in
newspapers accounts (see, e.g., Exhibit V), the property was attached by the Enforcement
Directorate in Mumbai, because [t]he amount collected from investors was used to buy it.
(See Exhibit V).
37. On information and belief, the City Group Companies in India also diverted the
proceeds from the defrauded investors directly to Chand Masood. In connection with the pattern
and practice of laundering the ill-gotten gains, Chand Masood deposited some of the money into
the accounts of City Trading, including $25,000 in November 2009, and $15,000 in
January 2010.
38. On information and belief, the money fraudulently obtained from the City Group
Companies investors was also laundered though City Trading by means of fake diamond
exports, utilizing the black hawala system of money laundering, as described by the U.S.
Treasury at http://www.treas.gov/offices/enforcement/key-issues/hawala/FinCEN-Hawala-
rpt.pdf. On information and belief, City Limouzines and City Realcom pretended to purchase
diamonds from diamond merchants in India, and had the merchants prepare fake invoices, in
exchange for 1% of the invoice amount. Attached hereto as Exhibit W are copies of some such
invoices. The City Group Companies in India then gave the cash they converted from Plaintiffs
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and the other investors to hawala persons who, for a small fee deducted from the cash
received, contacted counterparts diamond traders in New York, Hong Kong and elsewhere
who then (again for a small fee) purchased the diamonds and thereby returned laundered cash
to the City Group Companies.
39. Attached hereto as Exhibit X is a copy of a City Group spreadsheet listing
purported diamond transactions; in the last column (Remitting Info), Defendant City Trading
is listed as the purchaser of the diamonds on behalf of a diamond merchant consignee for
numerous transactions. For example, attached as Exhibit Y is a letter dated February 26, 2009
from City Limouzines to DBS Bank in Mumbai, India explaining that, per City Limouzines
Export Invoice No. EXP/149/2008/09, City Trading was the purchaser of the diamonds, and the
funds received into City Limouzines DBS account in Mumbai came from the consignee,
Brilliant Jewellery Co Ltd. On information and belief, City Trading not only thereby helped
facilitate the hawala laundering of the fraudulently obtained funds, but also received a fee or
commission for its efforts.
40. On information and belief, in some instances, the money used to purchase the
purported diamonds was wired directly through City Trading. For example, shortly after
Plaintiff Vedant Rajput made his investment, four wires totaling $1 million were sent to City
Trading on September 24, 25 and 26, 2008 from a diamond merchant, Jatania DR. Then, on
October 3, 4 and 5, close to or the same amount was wired back from City Trading to Jatania
DR.
41. On information and belief, there is no evidence of diamonds ever being exported,
just falsified paperwork to show diamonds sent to City Trading. According to one recent news
report, a copy of which is attached as Exhibit A, the Economic Offences Wing (EOW) of
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Mumbai police confirmed that a large diamond trade did happen through City Limouzine.
However, the report continues,
when investigating agencies questioned the concerned traders they said they never
sold any diamonds to City Limouzine. We suspect the diamonds were fake and
the transaction was forged to get remittances from Singapore. This is a clear case
of money laundering. Several unscrupulous businessmen do this regularly to turn
black money into white. We suspect Masood too has siphoned off investors
money to his company in the US and then conducted a fraudulent diamond trade
to bring part of it back as legitimate money. To avoid detection he has taken the
Singapore route and certain other tax havens. He has turned it into a liability so
that it cannot be recovered, said the officer.
Much of the Details and Information Regarding Defendants
Actions is Particularly Within Their Knowledge
42. The full scope of, and additional specific details concerning, Defendants actions,
including their laundering of the funds converted from the City Group Companies investors, is
peculiarly within the exclusive knowledge or control of Defendants.
43. Before filing this action, Plaintiffs undertook efforts to obtain such additional
information. Through their investigative efforts, plaintiff Vedant Rajput identified and located in
West Virginia the accountant for Defendant City Trading, Vipin Madan. Mr. Madan has a
number of relevant documents, but would not produce them without a subpoena. Accordingly,
Mr. Rajput filed a Petition with the Circuit Court in Kanawha County, West Virginia, for the
issuance of a subpoena requesting production of, inter alia, e-mails related to the City Group
Companies, financial statements for City Trading, and bank statements for City Trading and
Chand Masood. By Order dated February 10, 2010, the court issued the requested subpoena,
which was then served on Mr. Madan.
44. Shortly before the documents were to be produced, however, defendants Chand
Masood and City Trading filed a Motion to Quash the subpoena. Therein, they acknowledged
that the defendants engaged the services of Vipin Madan, and argued, among other things, that
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the subpoena was improper because there was no pending state or federal action to which said
subpoena would be ancillary.
45. On March 25, 2010, the Circuit Court in Kanawha County, West Virginia granted
the Motion to Quash on the ground that there was no pending action.
46. Although Plaintiffs efforts to obtain City Trading and related books and records
were thwarted, the facts alleged herein on information and belief are the result of Plaintiffs
diligent investigation of other sources.
COUNT I
Racketeering Influenced and Corrupt Organizations, Title 18 USC 1962(c)
47. Plaintiffs incorporate by reference the allegations of paragraphs 1 through 46.
48. Each Defendant is now and at all relevant times has been a person within the
meaning of 18 U.S.C. 1961(3) and 1962.
49. From at least 2002, continuously through the present, Defendants and others,
known and unknown including Sayed Masood, City Limouzine and City Realcom in Miami-
Dade County, Florida, Mumbai, India, and elsewhere, formed an association in fact for the
common and continuing purposes and goals described herein, which constitutes an enterprise
within the meaning of 18 U.S.C. 1961(4) (the City Group Enterprise). The City Group
Enterprise functions as a continuing unit within an ascertainable structure separate and distinct
from that of the conduct or pattern of racketing activity.
50. The City Group Enterprise is an enterprise engaged in and whose activities affect
interstate commerce because, among other things, the illegal activity involved the transportation
of fraudulently obtained money internationally and across state lines into and out of Florida, and
the use of illegally obtained money to purchase real and other property in Florida.
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51. Defendants are employed by or associated with the City Group Enterprise.
Defendants agreed to and did conduct and participate in the conduct of the City Group
Enterprises affairs through a pattern of racketeering activity and for the unlawful purposes of
perpetrating a fraud upon investors, including Plaintiffs, generating illegally obtained money,
and investing and concealing such fraudulently obtained money by means of a plan and a
practice of getting the money out of India and into the United States, in order to unjustly enrich
the City Group Enterprises members, their co-racketeers and others.
52. Pursuant to and in furtherance of their fraudulent and otherwise illegal scheme,
Defendants committed multiple related acts of racketeering that have the same or similar
criminal intents, results, accomplices, victims or methods of commission or that otherwise are
interrelated by distinguishing characteristics and are not isolated acts of racketing activity,
including:
a. Money laundering, in violation of 18 U.S.C. 1956. Defendants
knowingly conducted and attempted to conduct financial transactions affecting interstate and
foreign commerce, knowing that the property involved represents the proceeds of specified
unlawful activity, that is, the proceeds of one or more violations of Title 18 U.S.C. 1952
(travel in interstate or foreign commerce in aid of racketeering), 1957 (engaging in monetary
transactions in property derived from specified unlawful activity), 2314 (transportation of stolen
monies), and 2315 (receipt or possession of stolen monies), with the intent to promote the
carrying on of the above-specified unlawful activity. Defendants further transported, transmitted
or transferred, or attempted to transport, transmit or transfer, funds to a place in the United States
from or through a place outside the United States, and from a place in the United States to or
through a place outside the United States, knowing the funds represent the proceeds of some
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form of unlawful activity and knowing that such transportation, transmission, or transfer is
designed in whole or in part to conceal or disguise the nature, location, source, ownership or
control of the proceeds of above-specified unlawful activity. Further, Defendants, with the intent
to promote the carrying on of the above-specified unlawful activity and to conceal or disguise the
nature, location, source, ownership or control of property believed to be the proceeds of the
above-specified unlawful activity, conducted or attempted to conduct financial transactions
affecting interstate and foreign commerce involving property used to conduct or facilitate
above-specified unlawful activity.
b. Transportation of money obtained by conversion or fraud, in violation of
18 U.S.C. 2314. Defendants in furtherance and for the purpose of executing their fraudulent
scheme described above, transported, transmitted or transfered in interstate or foreign commerce,
monies of the value of $5,000 or more, knowing the same to have been stolen, converted or taken
by fraud, belonging to Plaintiffs.
c. Sale or receipt of money obtained by conversion or fraud, in violation of
18 U.S.C. 2315. Defendants received, possessed, concealed, stored, bartered, sold or disposed
of money of the value of $5,000 or more, which crossed a state or United States boundary after
being stolen, unlawfully converted or taken, knowing the same to have been stolen, unlawfully
converted or taken.
d. Engaging in monetary transactions in property derived from specified
unlawful activity, in violation of 18 U.S.C. 1957. Defendants knowingly engaged and
attempted to engage in monetary transactions by, through or to a financial institution, affecting
interstate or foreign commerce, in criminally derived property of a value greater than $10,000,
that is, the deposit, withdrawal, transfer or exchange of U.S. Currency, funds or monetary
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instruments, such as property having been derived from a specified unlawful activity, that is, the
proceeds of one or more violations of Title 18 U.S.C. 1952 (travel in interstate or foreign
commerce in aid of racketeering), 2314 (transportation of stolen monies), and 2315 (receipt or
possession of stolen monies).
e. Travel in interstate and foreign commerce in aid of the City Group
Enterprise, in violation of 18 U.S.C. 1952. Defendants knowingly and willfully traveled in
interstate or foreign commerce or used the mail or any facility in interstate or foreign commerce,
with intent to distribute the proceeds of an unlawful activity and to further an unlawful activity
and otherwise promote, manage, establish, carry on, or facilitate the promotion, management,
establishment, or carrying on, of any unlawful activity, in violation of 18 U.S.C. 1952.
f. Fraud in the procurement of a visa, in violation of 18 U.S.C. 1546.
Defendants Chand Masood and City Trading knowingly falsely made an immigrant visa for
entry into or as evidence of authorized stay or employment in the United States, or used,
attempted to use, possessed, obtained, accepted or received such visa, knowing it to be falsely
made or to have been procured by means of a false claim or statement or to have been unlawfully
obtained, in order to establish defendant Chand Masood in the United States, in aid of the City
Group Enterprises goal of concealing and laundering the fraudulently obtained spoils of the City
Group Companies wrongdoing in the United States.
53. The acts listed herein, including in the previous paragraph, constitute a pattern of
racketing activity pursuant to 18 U.S.C. 1962(5) which began in 2002 or before and continues
through and including the date upon which this complaint is filed, and which Plaintiffs expect to
continue.
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54. Defendants were associated with and/or exerted control over the City Group
Enterprise and have conducted or participated, directly or indirectly, in the conduct of the City
Group Enterprises affairs through the pattern of racketeering activity described herein, in
violation of 18 U.S.C. 1962(c).
55. The benefits derived from the pattern of racketing activity consist of hundreds of
millions of dollars in funds stolen from Plaintiffs and the other investors in the City Group
companies.
56. As a direct and proximate result of Defendants racketeering activities and
violations of 18 U.S.C. 1962(c), Plaintiffs have been damaged.
WHEREFORE, Plaintiffs request that this Court enter judgment against Defendants for
the damages each Plaintiff suffered in an amount to be proven at trial, which amount, as provided
for by statute, is to then be trebled, plus attorneys fees, costs, interest and such further relief as
the Court deems proper.
COUNT II
Racketeering Influenced and Corrupt Organizations, Title 18 USC 1962(d)
57. Plaintiffs incorporate by reference the allegations of paragraphs 1 through 56.
58. From at least as early as 2002 through the present, Defendants have unlawfully,
knowingly, and willfully combined, conspired, confederated, agreed, and reached an
understanding with each other and with others known and unknown, to violate 18 U.S.C.
1962(c) by conducting and participating, directly and indirectly, in the conduct of the affairs of
the City Group Enterprise, which engaged in, and the activities of which affected, interstate and
foreign commerce.
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59. The racketeering activity described in Count I was part of a sophisticated and well
organized scheme wherein each of the predicate acts relates to and directly advances on or more
of the purposes of the scheme, as described above.
60. The goal of the conspiracy was to enrich Defendants, their co-conspirators, and
those who aided and abetted them, at the expense of Plaintiffs and the other investors, by
facilitating, directing, or engaging in several overt acts, which consisted of a pattern of
racketeering activity as described in Count I.
61. As a result of the unlawful actions of the conspiracy, Plaintiffs have been
damaged.
WHEREFORE, Plaintiffs request that this Court enter judgment against Defendants for
the damages each Plaintiff suffered in an amount to be proven at trial, which amount, as provided
for by statute, is to then be trebled, plus attorneys fees, costs, interest and such further relief as
the Court deems proper.
COUNT III
Racketeering Influenced and Corrupt Organizations, Title 18 USC 1962(a)
62. Plaintiffs incorporate herein by reference the allegations of paragraphs
1 through 61.
63. The City Group Enterprise is an enterprise engaged in and whose activities affect
interstate commerce.
64. Defendants used and invested income that was derived from a pattern of
racketeering activity in an interstate enterprise, as alleged herein.
65. The racketeering activity described herein constitutes a pattern of racketeering
activity pursuant to 18 U.S.C. 1961(5).
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66. As direct and proximate result of Defendants racketeering activities and
violations of 18 U.S.C. 1962(a), Plaintiffs have been damaged.
WHEREFORE, Plaintiffs request that this Court enter judgment against Defendants and
for the damages each Plaintiff suffered in an amount to be proven at trial, which amount, as
provided for by statute, is to then be trebled, plus attorneys fees, costs, interest and such further
relief as the Court deems proper.
COUNT IV
Unjust Enrichment
67. Plaintiffs incorporate herein by reference the allegations of paragraphs 1
through 46.
68. Plaintiffs provided Defendants with a benefit in the form of a financial investment
in the City Group Companies, which investment was, on information and belief, converted by
the City Group Companies and diverted to Defendants.
69. On information and belief, Defendants were aware of, and benefited from, the
receipt of the funds invested by Plaintiffs.
70. On information and belief, Defendants knew that Plaintiffs were promised by
contract, and expected to compensated for the investment they provided to the City Group
Companies, but were not so compensated.
71. Under these circumstances, it would be inequitable for Defendants to retain the
benefits without compensating Plaintiffs for them.
72. As a result of the foregoing, Defendants have been unjustly enriched to the
detriment of Plaintiffs.
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WHEREFORE, Plaintiffs demand judgment against Defendants for damages plus costs
and such further relief as the Court deems proper.
JURY TRIAL DEMAND
Plaintiffs demand a trial by jury for all matters so triable as provided by Rule 38 of the
Federal Rules of Civil Procedure and by the United States Constitution.
/s/ John P. Marino
John P. Marino (FBN 814539)
E.K. Cottrell (FNB 013579)
FOWLER WHITE BOGGS P.A.
50 N. Laura Street, Suite 2800
Jacksonville, FL 32202
Tel: (904) 598-3100
Fax: (904) 598-3131
Email: jmarino@fowlerwhite.com
Attorneys for Plaintiffs
42728437
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