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Plaintiff,
ALPHA GRP, INC. and ALPHA GRP, LLC, JURY TRIAL DEMANDED
Defendants.
___________
COMPLAINT
The United States of America, through its undersigned counsel, alleges upon
2. This Court has jurisdiction over the subject matter of this action pursuant to
28 U.S.C. § 1345.
3. Defendants’ actions and the events and omissions giving rise to Plaintiff’s
claims are based primarily upon conduct that occurred in this District. Therefore, venue is
4. As well, defendants have minimum contacts with the State of New York.
As set forth herein: defendants, in the State of New York, solicited and borrowed the
subject funds owed to the United States, entered into the subject promissory note which
Case 1:18-cv-00397-RJA Document 1 Filed 03/29/18 Page 2 of 6
required that payments be sent to the State of New York, and defendants sent payments
owed on the subject promissory note to Plaintiff in the State of New York. Accordingly,
PARTIES
of business in the County of Los Angeles, State of California. Upon information and belief,
Alpha Grp, Inc.’s business activities include coordinating and producing sports events at
information and belief, Alpha Grp, LLC last operated from a location in the County of
Sonoma, State of California, prior to Alpha Grp, Inc. assuming all of its business activities
ALLEGATIONS
8. On or about January 11, 2011, Defendant Alpha Grp, LLC and i2i
Settlement Partners (“i2i”) executed a promissory note (“the Promissory Note”), wherein
i2i agreed to loan Alpha Grp, LLC the sum of $750,000 (“the Principal”). At the time i2i
loaned the Principal to Alpha Grp, LLC and executed the Promissory Note, i2i operated at
a business location in the State of New York. A true and correct copy of the Promissory
9. Pursuant to the terms of the Promissory Note, Defendant Alpha Grp, LLC
was required to repay to i2i the Principal and interest at a rate of 7%. Exhibit A, at pg. 1.
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10. In or about November 2012, i2i and Alpha Grp., LLC executed an
Under the Amendment, i2i and Alpha Grp., LLC consolidated payment of the Principal
11. Pursuant to the Amendment, both the additional funds and Principal were
to be repaid to i2i by Alpha Grp., LLC in quarterly installments through January 2016, at
a rate of 7% interest.
12. In or about 2012, Alpha Grp, Inc. assumed all of Alpha Grp, LLC’s business
activities and liabilities, including the obligation to pay the remaining money owed on the
Promissory Note.
13. Upon information and belief, between January 11, 2011 and November
2015, Alpha Grp, Inc. and/or Alpha Grp., LLC made approximately $512,500 payments
criminally forfeited and assigned to the United States i2i’s interest in the Promissory Note.
15. Dillon criminally forfeited and assigned i2i’s interest in the Promissory
Note as a part of a November 2016 plea agreement with Plaintiff and after this Court issued
a seizure warrant over the Promissory Note, finding probable cause to believe the
Promissory Note was funded with criminal proceeds. A true and correct copy of the
16. Dillon’s plea agreement resolved charges brought against him for
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that money they invested with Dillon’s companies, including i2i, would be used to purchase
17. At or about the time Dillon forfeited and assigned i2i’s interest in the
numerous attempts to obtain repayment from Alpha Grp, LLC and Alpha Grp, Inc.
Specifically, the United States contacted attorneys representing Alpha Grp, Inc. and
entered into an agreement with Alpha Grp., Inc. requiring Alpha Grp, Inc. to pay
$50,000.00 towards the Promissory Note, every quarter with the first payment due at the
19. Alpha Grp, Inc. paid the United States $50,000 in April 2016 and $20,000
in January 2017.
20. Since January 2017, however, neither Alpha Grp, Inc. nor Alpha Grp, LLC
have made any payments towards satisfaction of the Promissory Note, despite the United
21. As of February 28, 2018, the remaining Principal and interest, which
22. Pursuant to the terms of the Promissory Note and Amendment, this amount
COUNT I
(Breach of Contract)
23. Plaintiff repeats and realleges the facts set forth in paragraphs 1 through 22.
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24. The Promissory Note constitutes a valid and binding contract under state
25. Alpha Grp, LLC’s failure to make payment, as required under the terms of
26. By engaging in the conduct and activities described above, Alpha Grp, LLC
has materially breached the terms of the Promissory Note and Amendment and has
damaged Plaintiff.
27. Alpha Grp, LLC, therefore, is liable to Plaintiff for the Principal sum and
28. Additionally, to the extent that, Alpha Grp, Inc. has assumed Alpha Grp
LLC’s operations and/or liabilities, Alpha Grp, Inc. is liable to Plaintiff for the Principal
sum and interest, which continues to accrue, owed on the Promissory Note.
29. Although payment has been demanded, Alpha Grp, LLC and Alpha Grp,
reasonable attorney’s fees from Defendants incurred in the collection of the indebtedness.
judgment against Alpha Grp, LLC and Alpha Grp, Inc., jointly and severally, as follows:
a. For all sums due under the Promissory Note and Amendment in an amount not
b. For costs and attorney’s fees pursuant to the terms of the Promissory Note;
c. For any statutory interest and fees, at the highest rate allowable by law; and
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d. That this Court grant Plaintiff such other relief as the Court may deem just and
proper.