Joseph Rainier Attempted Robbery Ex Con Ex Convict Fraud USPI Accreditation Tarpon Springs Florida

Just plain and simple. Google the name Ahmet Sandikci and read the frist post on this guy where it says Turk lies on an american. You will then have the whole truth and understand why this guy keeps posting this slander and using some other person name Rainier gee if you Google the name Joseph Rainier a few people with that name comes up come up. So don't be fooled by scum bags folks.

Also Ahmet sandikci coming up for federal trial april 26, 2012 Courtroom 8-A 9:30 am Tampa federal courthouse. For ripping off numerous smericans and Rainier (my hero) exposed this turk muslim trash. Now you probably understand why they keep posting negative things on Rainier.

If the Tarpon Springs Police would have listen to Rainier people would not have been scammed by Ahmet Sandicki who posted this grabage trying to blemish Rainier's name. Sandikci even shared the money with politicians see below or google political donations and put in Ahmet Sandikic from Palm Harbor. Quite a few people have egg all over their face because they did not listen to Rainier or pay attention to what his company uspi.org does to portect the citizens of the USA from foreign scum. Just take a peek below what Sandikci did to numeorus americans.



Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
UNITED STATES BANKRUPTCY COURT
MIDDLE DISTRICT OF FLORIDA
TAMPA DIVISION
In re: AHMET SANDIKCI, ) Case No.: 8:11-bk-07915-MGW
)
Debtor. ) Chapter 7
)
)
DEJAMES BUILDERS OF FLORIDA, INC., )
a Florida Corporation; )
DETRIE BUILDERS, INC., )
a Wisconsin Corporation; )
DETRIE CONSTRUCTION INC., )
a Wisconsin Corporation; )
MONTANA, INC., )
a Wisconsin Corporation; ) Adv. Pro. No.
ROBERT DETRIE, SR., d/b/a MARKUM, INC.; )
DENNIS DETRIE, individually; and )
DANIEL SCHMIDT, individually, )
)
Plaintiffs, )
)
v. )
)
AHMET SANDIKCI, )
)
Defendant. )
/ )
COMPLAINT
Plaintiffs, DEJAMES BUILDERS OF FLORIDA, INC., a Florida Corporation; DETRIE
BUILDERS, INC., a Wisconsin Corporation; DETRIE CONSTRUCTION, INC., a Wisconsin
Corporation; MONTANA, INC. a Wisconsin Corporation; ROBERT DETRIE, SR., d/b/a
MARKUM, INC.; DENNIS DETRIE, Individually; and DANIEL SCHMIDT, individually,
complaining of the Defendant, AHMET SANDIKCI, allege:
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 2
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
1. This is an adversary proceeding to determine the dischargeability of a debt pursuant to Bankruptcy Rules 4007 and 7001(6).
2. On April 27, 2011, the above named Debtor, Defendant herein, filed a Voluntary Petition for relief under Chapter 11 of Title 11, United States Code; however, on September 14,
2011, this Court, pursuant to the Motion of the United States Trustee, Ordered this matter converted to one under Chapter 7 of Title 11, United States Code.
3. The question of the Debtor's discharge has not as of this date been determined.
4. Debtor/Defendant is indebted to Plaintiffs in the sums of:
a. $728,000.00 as to Plaintiff, DEJAMES BUILDERS, INC.;
b. $400,000.00 as to Plaintiff, DETRIE BUILDERS, INC.;
c. $100,000.00 as to Plaintiff, DETRIE CONSTRUCTION, INC.;
d. $100,000.00 as to Plaintiff, MONTANA, INC.;
e. $100,000.00 as to Plaintiff, ROBERT DETRIE, SR., d/b/a MARKUM, INC.;
f. $728,000.00 as to Plaintiff, DENNIS DETRIE; and,
g. $1,535,000.00 as to Plaintiff, DANIEL SCHMIDT;
moreover, said debts are founded upon claims which are excepted from a discharge in
bankruptcy, as described herein.
Parties
5. Plaintiff, DEJAMES BUILDERS, INC. (DeJames), is an entity organized
pursuant to the laws of Florida, conducting business in Palm Beach County, Florida, with its
principal place of business located at 323 Eagle Drive, Jupiter, Florida.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 3
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
6. Plaintiff, DETRIE BUILDERS, INC. (Detrie Builders), is a Wisconsin
Corporation headquartered at 701 Pine Street, Green Bay, Wisconsin.
7. Plaintiff, DETRIE CONSTRUCTION, INC. (Detrie Construction), is a
Wisconsin Corporation headquartered at 701 Pine Street, Green Bay, Wisconsin.
8. Plaintiff, MONTANA, INC. (Montana), is a Wisconsin Corporation
headquartered at 701 Pine Street, Green Bay, Wisconsin.
9. Plaintiff, ROBERT DETRIE, SR., d/b/a MARKUM, INC. (MarKum) is a
Wisconsin Corporation headquartered at 701 Pine Street, Green Bay, Wisconsin.
10. Plaintiff, DENNIS DETRIE, is an individual over the age of 18 and otherwise sui
juris. At all times relevant hereto, Mr. Detrie was a resident of Palm Beach County, Florida.
11. Plaintiff, DANIEL SCHMIDT, is an individual over the age of 18 and otherwise sui juris.
12. Plaintiffs, DeJames and Dennis Detrie, and Defendant engaged in a joint venture that operated a retail rare currency business and exchange located at 410 S. County Road, Palm Beach, Florida. Mr. Sandikci and Arcades Ponzi Scheme
13. Defendant operated a car repair garage called German Auto Repair Center, Inc. (German Auto), in Palm Harbor, Florida.
14. Plaintiff, Dennis Detrie, was a customer at German Auto and became friendly with Defendant.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 4
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
15. Through their friendship, Defendant became aware that Dennis Detrie owned Plaintiff, DeJames. Further, Mr. Sandikci became aware that DeJames had recently closed out a development in Southwest Florida and paid profits to Dennis Detrie.
16. In 2007, Defendant, Mr. Sandikci, strapped for cash, approached Dennis Detrie at German Auto for loans or agreement to jointly venture Defendants purchase and hopeful sale of rare United States currency.
17. On or about November 2, 2007, at Mr. Sandikcis request made in Tarpon Springs, Florida, Dennis Detrie provided Mr. Sandikci with $100,000.00 to fund a joint venture for the purchase and hopeful sale of rare United States currency.
18. On or about January 10, 2008, at Mr. Sandikcis request made in Tarpon Springs, Florida, Dennis Detrie loaned or jointly ventured with Mr. Sandikci $100,000.00 to fund Mr. Sandikcis purchase and hopeful sale of rare United States currency. A copy of the Promissory Note evidencing the same is attached hereto as Plaintiffs Exhibit A.
19. On or about February 26, 2008, at Mr. Sandikcis request made in Tarpon Springs, Florida, Dennis Detrie loaned or jointly ventured with Mr. Sandikci $100,000.00, to fund Mr. Sandikcis purchase and hopeful sale of rare United States currency. A copy of the Promissory Note evidencing the same is attached hereto as Plaintiffs Exhibit B.
20. Defendant, Mr. Sandikci, paid Dennis Detrie his investment and profit for the November 2, 2007 joint venture from the alleged proceeds from selling alleged rare United States currency. In addition, Mr. Sandikci repaid Dennis Detrie the January 10, 2008 and February 26, 2008 loans, on information and belief, as the start of Mr. Sandikcis scheme to
get far more funds from Dennis Detrie and Dennis Detries family. In addition, Mr. Sandikci
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 5
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
paid Dennis Detrie alleged profits from the alleged sale of rare United States currency over
and above the principal of the loans.
21. On or about January 10, 2008, Mr. Sandikci persuaded Dennis Detrie to introduce
him to his father, Robert Detrie, Sr. Mr. Detrie, Sr., at all relevant times hereto, was thepresident of Montana, Inc.
22. On or about January 10, 2008, at Mr. Sandikcis request, Mr. Detrie, Sr. loanedor jointly ventured with Mr. Sandikci $100,000.00 to fund Mr. Sandikcis purchase and hopeful sale of rare United States currency.
23. On or about March 1, 2008, at Mr. Sandikcis request, Mr. Detrie, Sr., loaned or jointly ventured with Mr. Sandikci $100,000.00 to fund Mr. Sandikcis purchase and hopeful sale of rare United States currency.
24. On information and belief, Mr. Sandikci repaid these loans as a part of Mr. Sandikcis scheme to get far more funds from Mr. Detrie, Sr., and his family. In addition, Mr.Sandikci paid Mr. Detrie, Sr., alleged profits from the alleged sale of rare United States currency over and above the principal of the loans as a further enticement for future loans.
25. On or about March 26, 2008, at Mr. Sandikcis request, Dennis Detrie loaned or jointly ventured with Mr. Sandikci $200,000.00 to fund Mr. Sandikcis purchase and hopeful sale of rare United States currency. A copy of the alleged Promissory Note evidencing the same is attached hereto as Plaintiffs Exhibit C. To date, neither Mr. Sandikci nor Mr. Sandikcis alter ego business, Arcade Currency Palace (Arcade), has repaid this loan.
26. On or about April 6, 2008, Mr. Sandikci requested Mr. Detrie, Sr. loan or jointly venture with Mr. Sandikci and Arcade $200,000.00 to fund Mr. Sandikcis and Arcades
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 6
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
purchase and hopeful sale of rare United States currency. Mr. Detrie, Sr. explained that as the President of Montana, Inc., he could arrange for a $100,000.00 transfer to be made by Montana, Inc. to Mr. Sandikci and Arcade; and a further $100,000.00 transfer to be made by Mr. Detrie, Sr. to Mr. Sandicki and Arcade. On that same date, Montana, Inc. wired Mr. Sandikci $100,000.00. In addition, on that same date Mr. Detrie, Sr. wired Mr. Sandikci another $100,000.00. A copy of the alleged Promissory Note evidencing the same is attached hereto as Plaintiffs Exhibit D. To date, neither Mr. Sandikci nor Arcade has repaid this loan.
27. On or about April 6, 2008, Mr. Sandikci requested Mr. Robert Detrie, Jr. loanor jointly venture with Mr. Sandikci and Arcade $100,000.00 to fund Mr. Sandikcis and Arcades purchase and hopeful sale of rare United States currency. Mr. Sandikci did not distinguish between himself and Arcade. Mr. Detrie, Jr. explained that he would not personally
fund the loan, but that as President of Detrie Construction, he could arrange for the transfer by Detrie Construction. On that same date, Detrie Construction wired Mr. Sandikci and Arcade $100,000.00. A copy of the alleged Promissory Note evidencing the same is attached hereto as Plaintiffs Exhibit E. To date, neither Mr. Sandikci nor Arcade has repaid this loan.
28. On or about April 21, 2008, Mr. Sandikci requested Dennis Detrie loan or jointly venture with Mr. Sandikci and Arcade another $60,000.00 to fund Mr. Sandikcis and Arcades purchase and hopeful sale of rare United States currency. To date, neither Mr. Sandikci nor Arcade has repaid this loan.
29. On or about April 24, 2008, Mr. Sandikci requested Mr. Detrie, Jr. loan or jointly venture with Mr. Sandikci and Arcade $150,000.00 to fund Mr. Sandikcis and Arcades purchase and hopeful sale of rare United States currency. Mr. Detrie, Jr. explained that he would DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 7
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
not personally fund the loan but that as President of Detrie Builders he could arrange for Detrie Builders to fund the transfer. On that same date, Detrie Builders wired $150,000.00 to Mr. Sandikci and Arcade. A copy of the alleged Promissory Note evidencing the same is attached hereto as Plaintiffs Exhibit F. To date, neither Mr. Sandikci nor Arcade has repaid this loan.
30. On or about April 29, 2008, Mr. Sandikci requested Dennis Detrie loan or jointly venture with Mr. Sandikci and Arcade $67,000.00 to fund Mr. Sandikcis and Arcades purchase and hopeful sale of rare United States currency. To date, neither Mr. Sandikci nor Arcade has repaid this loan.
31. On or about May 12, 2008, at Mr. Sandikcis request, Detrie Builders loaned or jointly ventured with Mr. Sandikci and Arcade another $250,000.00 to fund Mr. Sandikcis and Arcades purchase and hopeful sale of rare United States currency. To date, neither Mr. Sandikci nor Arcade has repaid this loan.
32. On or about July 20, 2008, at Mr. Sandikcis request, Dennis Detrie loaned or jointly ventured with Mr. Sandikci $75,000.00 to fund Mr. Sandikcis purchase and hopeful sale of rare United States currency. To date, neither Mr. Sandikci nor Arcade has repaid this loan.
33. On or about October 26, 2008, at Mr. Sandikcis request, Dennis Detrie loaned or jointly ventured with Mr. Sandikci another $25,000.00 to fund Mr. Sandikcis purchase and hopeful sale of rare United States currency. To date, neither Mr. Sandikci nor Arcade has repaid this loan.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 8
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
No Distinction Between Mr. Sandikci and Arcade
34. Defendant and Arcade were allegedly in the business of buying and selling rare currency in a retail store located in Tarpon Springs, Florida, at the retail location in Palm Beach, Florida, and through the website eBay.
35. Defendant, Mr. Ahmet Sandikci, is the sole shareholder and officer of Arcade. Further, Arcade, has no board of directors.
36. In 2003, Defendant established a personal eBay account under the name PORSCHEAHMET.
37. Defendant sells personally-owned rare currency through his PORSCHEAHMET account, and Arcades corporate-owned rare currency through Mr. Sandikcis PORCHEAHMET account.
38. Defendant wrongfully sold inventory from the joint venture store, described below, which had been purchased with funds provided by Dennis Detrie, through Mr. Sandikcis PORCHEAHMET account.
39. Defendant has a personally-owned PayPal account through which payments are made for the PORCHEAHMET eBay account.
40. Defendants personally-owned PayPal account is the sole means through which payment for items sold through the PORCHEAHMET eBay account are funded, regardless of who owns the items sold.
41. All funds received into the Mr. Sandikcis personal PayPal account for sales of items through the PORCHEAHMET eBay account, regardless of whether the item was owned by
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 9
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
Defendant or joint venture, were deposited into Defendants personal bank account at Bank of America in Tarpon Springs, Florida.
42. Defendant does not distinguish between himself and Arcade.
43. Defendant used the corporate form of Arcade to defraud customers and investors for an improper purpose, to wit: to give the appearance that customers and investors are dealing with a well-heeled entity rather than with Mr. Sandikci himself.
44. Moreover, Defendant used the corporate form of Arcade to further his aforementioned scheme of acquiring funds.
45. Defendants use of the corporate form of Arcade caused injury to the Plaintiffs in that Plaintiffs were lured into believing that they were loaning money or investing in a sophisticated and well-heeled entity, wherein Plaintiffs in reality were simply funding Defendants fraudulent scheme. Rare Currency Fraud
46. Each piece of rare United States currency contains a unique serial number, which allows for identification.
47. In addition, persons who deal in rare currency use the Friedberg Numbering System (Friedberg numbers), to further identify and classify rare currency.
48. Serial numbers and Friedberg numbers are very important to identify and catalogue rare currency.
49. The value of any rare currency is dependent upon the grade, quality and rarity of the currency.
50. Defendant held himself out as expert in rare United States currency.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 10
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
51. On or before May 12, 2008, Mr. Sandikci represented to Plaintiff, Mr. Daniel Schmidt, while in Wisconsin, that he was the foremost numismatist in the United States.
52. On or before May 12, 2008, Mr. Sandikci induced and encouraged Mr. Schmidt to rely upon Mr. Sandikcis skill, knowledge and expertise in collecting rare U.S. currency and coins to develop a collection of rare currency.
53. On or before May 12, 2008, Mr. Sandikci approached in Wisconsin. Mr. Schmidt and solicited his purchase of certain alleged rare US coin, to wit: a 2 Gold Eagle coin set.
54. Mr. Sandikci represented that the retail value of the 2 Gold Eagle coin set was greater than $510,000.00.
55. On or about May 10, 2008, based upon Mr. Sandikcis representations, Mr.Schmidt gave Mr. Sandikci $200,000.00 for the purchase of collectable currency.
56. On or about July 2, 2008, based upon Mr. Sandikcis representations Mr. Schmidt gave Mr. Sandikci an additional $510,000.00 for the 2 Gold Eagle coin set.
57. Mr. Sandikci never delivered possession of the graded 2 Gold Eagle coin set or the collectable currency to Mr. Schmidt.
58. Mr. Schmidt subsequently discovered that the true value of the 2 Gold Eagle coin set was $2,400.00, despite Mr. Sankikcis direct representations to the contrary. The Palm Beach Joint Venture
59. On or before March 18, 2008, Defendant approached Plaintiffs, Dennis Detrie and DeJames, at Dennis Detries home in Jupiter, Florida, and solicited their involvement as a partner in a retail rare currency business in Palm Beach, Florida.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 11
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
60. Specifically, Defendant sought a business partner to open a rare U.S. currency  tore in Palm Beach, Florida.
61. Based on Defendants solicitation, Plaintiff, DeJames, agreed to jointly venture the business.
62. Plaintiff, DeJames agreed to: (1) supply the initial start-up capital for the joint venture; specifically including the purchase of rare currency to be used as inventory; (2) store rare currency inventory purchased in the safety deposit box of Mr. Dennis Detrie; (3) locate a suitable retail location for the joint venture: (4) co-sign the lease for the retail location of the joint venture; (5) perform any needed build out of the retail location of the joint venture; and, (6) physically work in the joint venture location.
63. Moreover, Plaintiff, DeJames, and Defendant, agreed that Defendant would provide: (1) certain inventory of rare currency for the business; and, (2) the skill, knowledge and experience required to operate the business by physically working in the store.
64. On or before March 8, 2008, DeJames, through its President, Mr. Dennis Detrie, searched for a suitable retail location for the joint venture and located 410 S. County Road, Palm Beach, Florida.
65. On or before April 1, 2008, Plaintiff DeJames, through its President, Mr. Detrie, negotiated the terms of a lease for the retail rental property located at 410 S. County Road, Palm Beach, Florida, for the joint venture.
66. On or before April 1, 2008, the lease was reduced to writing by the landlord, LenDan, Inc., at Plaintiff DeJames request.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 12
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
67. On or before April 1, 2008, Plaintiff DeJames paid the initial monies required by the Retail Lease, to wit: $96,000.00.
68. The joint venture agreement between Plaintiff DeJames and Defendant is evidenced, inter alia, by that certain Retail Lease that was the product of Plaintiffs efforts to locate a suitable location for the joint venture and secure a lease for the same, a copy of which is attached hereto as Plaintiffs Exhibit G. The Retail Lease is between LenDan, Inc. as
Landlord and Arcade and DeJames as Tenant. Further, both Plaintiff and Defendant executed the Retail Lease as Tenant.
69. On or after April 1, 2008, Plaintiff and Defendant, as a joint venture, took possession of the retail premises located at 410 S. County Road, Palm Beach, Florida.
70. The joint venture agreement of the parties is further evidenced by that certain First Addendum to Lease, a copy of which is attached hereto as Plaintiffs Exhibit H and that certain Second Addendum to Lease, a copy of which is attached hereto as Plaintiffs Exhibit I.
71. As signors to the Retail Lease, First Addendum to Lease and Second Addendum to Lease, both Plaintiff DeJames and Defendant maintained the joint right to access and control the premises where the joint venture was located.
72. Plaintiff DeJames, through its President, Mr. Dennis Detrie, purchased materials to build out the joint venture retail premises. Further, Plaintiff staffed, supervised and managed the build out of the joint venture retail premises, and paid for the same.
73. Between on or around March 18, 2008 through on or about June 12, 2008, almost weekly, Mr. Sandikci held meetings with Dennis Detrie whereupon Mr. Sandikci provided alleged rare U.S. currency that was to become the initial inventory of the joint venture retail
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 13
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
premises, and Dennis Detrie provided Mr. Sandikci cash to purchase the same. Dennis Detrie stored the alleged rare U.S. currency in his personal safety deposit box in Palm Beach County at the request of Mr. Sandikci until the opening of the joint venture retail premises.
74. On or about June 12, 2008, upon completion of the build out of the joint venture retail premises, Plaintiff DeJames, though its President, Mr. Dennis Detrie, began to work in the retail store full time.
75. Further, upon completion of the joint venture retail premises and the provisioning of an adequate safe in which to store alleged rare U.S. currency, Mr. Dennis Detrie moved the alleged rare U.S. currency from his personal safety deposit box into the safe in the joint venture retail premises.
76. Subsequent to the opening of the joint venture retail premises Mr. Sandikci and Arcade represented to the public that DeJames and Dennis Detrie were partners in the joint venture retail premises.
77. Mr. Dennis Detrie, as a joint venture partner in the Palm Beach store created an index of the serial numbers and Friedberg numbers for each piece of currency that became a part of the inventory of the joint venture retail premises. A copy of the inventory is attached hereto as Plaintiffs Exhibit J.
78. Plaintiff DeJames and Defendant shared a community of interest in the performance of the common purpose of operating the retail rare currency business.
79. Plaintiff DeJames and Defendant maintained joint control or right of control of the retail rare currency business, including physical possession of keys for all exterior locks and knowledge of the operation of the security systems therein, until Defendant excluded DeJames.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 14
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
80. Plaintiff DeJames and Defendant maintained a joint proprietary interest in the subject matter of the business, to wit: retail sales of rare U.S. currency.
81. Plaintiff DeJames and Defendant both had equal right to share in the profits of the joint venture from the sales of rare U.S. currency.
82. Plaintiff DeJames and Defendant both had equal duty to share in any losses which may be sustained by the joint venture.
83. On or about December 14, 2008, Defendant, without explanation, reason or basis, wrongfully excluded Plaintiff DeJames from the joint venture retail business location by changing the locks and physically excluding Plaintiff from the retail joint venture location.
84. Defendant wrongfully converted and sold the joint venture inventory, keeping the proceeds from the same as personal assets, using Mr. Sandikcis PORCHEAHMETs eBay account. Mr. Sandikcis Embezzlement from DeJames and Dennis Detrie
85. As described herein, the inventory of the joint venture, consisting of greater than 900 pieces of rare currency and coins, was in Mr. Sandikcis possession and control as a joint venture partner in the Palm Beach store.
86. In addition, the proceeds from the sales of the inventory of the joint venture were in Mr. Sandkcis possession and control as a joint venture partner in the Palm Beach store.
87. Defendant, Mr. Sandikci, intentionally appropriated the joint ventures inventory and assets for a use other than that for which it was entrusted, to wit: personal use.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 15
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
88. Defendant refused to account for the joint ventures inventory/assets, cannot account for the joint ventures inventory/assets, and now claims that the joint venture inventory has been sold through eBay; however, Defendant cannot account for the proceeds of such sales.
89. Pursuant to Section 523(a)(4) of said Title 11, the discharge of the Debtor would not release the Debtor from the aforesaid debt. Mr. Sandikcis Embezzlement from Detrie Builders, Inc.
90. As described herein, Detrie Builders entrusted Defendant with $400,000.00, at Defendants request, for the purpose of purchasing rare U.S. currency for resale.
91. Defendant intentionally appropriated Detrie Builders property for use other than debt for which it was entrusted, to wit: Defendants personal use.
92. Defendants conduct in taking the property under the pretense of purchasing rare U.S. currency and absconding with the same, in the midst of a Ponzi-type scheme, smacks of fraud.
93. Pursuant to Section 523(a)(4) of said Title 11, the discharge of the Debtor would not release the Debtor from the aforesaid debt. Mr. Sandikcis Embezzlement from Detrie Construction, Inc.
94. As described herein, Detrie Construction entrusted Defendant with $100,000.00, at Defendants request, for the purpose of purchasing rare U.S. currency for resale.
95. Defendant intentionally appropriated Detrie Constructions property for use other
than debt for which it was entrusted, to wit: Defendants personal use.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 16
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
96. Defendants conduct in taking the property under the pretense of purchasing rare U.S. currency and absconding with the same, in the midst of a Ponzi-type scheme, smacks of fraud.
97. Pursuant to Section 523(a)(4) of said Title 11, the discharge of the Debtor would not release the Debtor from the aforesaid debt. Mr. Sandikcis Embezzlement from Montana, Inc.
98. As described herein, Montana entrusted Defendant with $100,000.00, at Defendants request, for the purpose of purchasing rare U.S. currency for resale.99. Defendant intentionally appropriated Montanas property for use other than debt for which it was entrusted, to wit: Defendants personal use.
100. Defendants conduct in taking the property under the pretense of purchasing rare U.S. currency and absconding with the same, in the midst of a Ponzi-type scheme, smacks of fraud.
101. Pursuant to Section 523(a)(4) of said Title 11, the discharge of the Debtor would not release the Debtor from the aforesaid debt. Mr. Sandikcis Embezzlement from Robert Detrie, Sr., d/b/a MarKum, Inc.
102. As described herein, MarKum entrusted Defendant with $100,000.00, at Defendants request, for the purpose of purchasing rare U.S. currency for resale.
103. Defendant intentionally appropriated MarKums property for use other than debt for which it was entrusted, to wit: Defendants personal use.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 17
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
104. Defendants conduct in taking the property under the pretense of purchasing rare U.S. currency and absconding with the same, in the midst of a Ponzi-type scheme, smacks of fraud.
105. Pursuant to Section 523(a)(4) of said Title 11, the discharge of the Debtor would not release the Debtor from the aforesaid debt. Mr. Sandikcis Embezzlement from Daniel Schmidt
106. As described herein, Daniel Schmidt entrusted Defendant with $1,535,000.00, at Defendants request, for the purpose of purchasing rare U.S. currency for resale.
107. Defendant intentionally appropriated Daniel Schmidts property for use other than debt for which it was entrusted, to wit: Defendants personal use.
108. Defendants conduct in taking the property under the pretense of purchasing rare U.S. currency and absconding with the same, in the midst of a Ponzi-type scheme, smacks of fraud.
109. Pursuant to Section 523(a)(4) of said Title 11, the discharge of the Debtor would not release the Debtor from the aforesaid debt.Mr. Sandikcis Larceny from DeJames and Dennis Detrie
110. As described herein, DeJames and Dennis Detrie owned or had a legal interest in the inventory, and proceeds from the sale of the inventory, of the joint venture.
111. Defendant carried away the property of DeJames and Dennis Detrie with felonious intent, to wit: to sell or secret such property for personal use.
112. Pursuant to section 523(a)(4) of said Title 11, the discharge of the debtor would not release the debtor from the aforesaid debt.
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 18
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
Mr. Sandikcis Larceny/Civil Theft from Daniel Schmidt
113. As described herein, Daniel Schmidt provided Defendant with greater than $510,000.00 for a 2 Gold Eagle coin set.
114. Defendant carried away Daniel Schmidts 2 Gold Eagle coin set with felonious intent, to wit: to sell or secret such property for personal use.
115. Pursuant to section 523(a)(4) of said Title 11, the discharge of the debtor would not release the debtor from the aforesaid debt.
Mr. Sandikcis Frauds Committed While In a Fiduciary Capacity Against DeJames and Dennis Detrie
116. As described herein, Defendant owed fiduciary duties of care and loyalty to DeJames and Dennis Detrie as a joint venture partner.
117. Defendant breached those fiduciary duties by defrauding DeJames and Dennis Detrie of property and funds as described herein.
118. Pursuant to section 523(a)(4) of said Title 11, the discharge of the debtor would not release the debtor from the aforesaid debt.
119. Pursuant to Bankruptcy Rule 7008 plaintiff states that this proceeding is core.[10]
WHEREFORE, Plaintiffs pray for an order determining said debts to be nondischargeable and for judgment against the Debtor in the sums of:
a. $728,000.00 as to Plaintiff, DEJAMES BUILDERS, INC.;
b. $400,000.00 as to Plaintiff, DETRIE BUILDERS, INC.;
c. $100,000.00 as to Plaintiff, DETRIE CONSTRUCTION, INC.;
d. $100,000.00 as to Plaintiff, MONTANA, INC.;
DeJames Builders of Florida, Inc. v. Ahmet Sandikci
Case No.: 8:11-bk-07915-MGW
Adv. Pro No.: _______________
Page 19
Leopold~Kuvin, P.A.
2925 PGA Boulevard, Suite 200, Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400 Facsimile (561) 515-1401
e. $100,000.00 as to Plaintiff, ROBERT DETRIE, SR., d/b/a MARKUM, INC.;
f. $728,000.00 as to Plaintiff, DENNIS DETRIE; and,
g. $1,535,000.00 as to Plaintiff, DANIEL SCHMIDT;
together with interest, and for such other and such further relief as this Court deems just. DEMAND FOR JURY TRIAL
Plaintiffs demand a jury trial on all issues so triable as a matter of right.
Dated: October 6, 2011. s/ GREGORY S. WEISS
GREGORY S. WEISS
Florida Bar No.: 163430
DANIEL A. THOMAS
Florida Bar No.: 168262
Email: gweiss@leopoldkuvin.com
Email: dthomas@leopoldkuvin.com
LEOPOLD~KUVIN, P.A.
2925 PGA Boulevard, Suite 200
Palm Beach Gardens, FL 33410
Telephone: (561) 515-1400
Facsimile: (561) 515-1401
Attorneys for Plaintiffs

First of all folks go to the federal bureau of prison website and search the name John A. Maragoudakis then go to Trusted Traditions a company in the currency market doing business out of Lauderdale by The Sea the guy who started this posted and lies about Rainier.

You will notice that the owner of trusted traditions is now using the a/k/a name of John Markis to hide his true identity and prior federal prisoner status for financial crimes. mr. markis and the Arcade Currency Palace are into price fixing and racketering and worried Rainier knows to much while working with Ahmet Sandikci and will have Markis , Lipka and Sandikci arrested. Their plan start bad rumors about Rainier and keep the attention off of their Ponzi scheme con games. Just visit a site key currency . com and click on bad grade link and see the evidence. Then go to the site USPI . org and click on accomplishment link and see why the real crooks are afraid.

run the names through rip off report for other complaints you will see none other than these scammers.

The bible says revenge is mine says the lord. I am sure once Rainier's investigators in Tarpon Springs & Palm Beach are complete with their investigations you will find out the real liar.

The person who filed the false complaint against Rainier you might want to google Arcade Currency Palace read the dirt that has been going on for over two years once it had been uncovered.

I suggest you go you visit a web site key currency and click on the bad grade link read (87) pages of evidence. So you see folks, it really is looking like Rainier turns in a foreignor scammer and he gets charged by the scammer with false accusations by police.

By the way I am told by some of Rainier's witnesses the cops NEVER talked to even though the police had their names. The police response to not speaking to those witnesses. I don't have to! Hmmmm maybe that is why Tarpon Springs Police has on a prior occasions been under federal scrutiny for violating the civil rights of their community members.

How about that!!!! Thank God For Rip Off Report to enable the public to get it out quick and not censored like the media.

Gee you think that after reading this report and the story printed by the press that it would be very obvious that this is a he said she said after a failed business partnership when one of them tried to get greedy after a buisness deal. The one who tried to get greedy of course is the owner of the Arcade Currency Palace who tried to change an agreement that Rainier had after the fact. Also folks Rainier is STILL waiting for the reporter to contact him after leaving numerous messages for her on that contact number listed at the end of the story to return his call.

Further, the reporter noted in the story that Rainier or Sandikci could not be reached for comment. I know for a fact Rainier was "never" contacted by any reporter. Rainier would love to tell his side of this story. Gee, if you check directory assistance you will find the home listing of Rainier and when you call that number their is an answering machine.

So you see folks the cover of the book is not to be judged, read the story to really find out the details and FACTS. Don't be smoke screened by people robbing elderly Americans.

Name:
RAINIER, JOSEPH V

DOB:
5/31/1958

Docket #:
1332818

Arrest Date:
12/9/2008 12:32:46 PM

Race:
WHITE

Sex:
MALE

Name RAINIER, JOSEPH V
Docket No. 1332818
Booking Date 12/9/2008 12:32:46 PM
Arresting Agency TARPON SPRINGS POLICE


Address
1396 WELLINGTON ST
TARPON SPRINGS
FL
34689

Race WHITE
MALE
5/31/1958
NJ
50

Eyes BLU
Hair GRY
Complexion LGT
Height 509
Weight 140

Scars, Marks & Tattoos
heart -mom right calf

Cell Location/Status
SPIN
Booking Type -FELONY-

CSOD-INTAK-PRO-01-020
2808973

Aliases

Charge Number:
1

Agency Report Number:
TS08003275

Offense Description:
SCHEME TO DEFRAUD ($50,000 OR MORE)

Statute:
817.034(4)(A)(1)/F

Court Case Number:
CRC0825947CFANO

Bond Assessed:
$50,000.00

Bond Amount Due:
$50,000.00

OBTS:
5206040391

2008 Pinellas County Sheriff's Office

Name:
RAINIER, JOSEPH V

DOB:
5/31/1958

Docket #:
1332818

Arrest Date:
12/9/2008 12:32:46 PM

Race:
WHITE

Sex:
MALE

Name RAINIER, JOSEPH V
Docket No. 1332818
Booking Date 12/9/2008 12:32:46 PM
Arresting Agency TARPON SPRINGS POLICE


Address
1396 WELLINGTON ST
TARPON SPRINGS
FL
34689

Race WHITE
MALE
5/31/1958
NJ
50

Eyes BLU
Hair GRY
Complexion LGT
Height 509
Weight 140

Scars, Marks & Tattoos
heart -mom right calf

Cell Location/Status
SPIN
Booking Type -FELONY-

CSOD-INTAK-PRO-01-020
2808973

Aliases

Charge Number:
1

Agency Report Number:
TS08003275

Offense Description:
SCHEME TO DEFRAUD ($50,000 OR MORE)

Statute:
817.034(4)(A)(1)/F

Court Case Number:
CRC0825947CFANO

Bond Assessed:
$50,000.00

Bond Amount Due:
$50,000.00

OBTS:
5206040391

2008 Pinellas County Sheriff's Office

Name:
RAINIER, JOSEPH V

DOB:
5/31/1958

Docket #:
1332818

Arrest Date:
12/9/2008 12:32:46 PM

Race:
WHITE

Sex:
MALE

Name RAINIER, JOSEPH V
Docket No. 1332818
Booking Date 12/9/2008 12:32:46 PM
Arresting Agency TARPON SPRINGS POLICE


Address
1396 WELLINGTON ST
TARPON SPRINGS
FL
34689

Race WHITE
MALE
5/31/1958
NJ
50

Eyes BLU
Hair GRY
Complexion LGT
Height 509
Weight 140

Scars, Marks & Tattoos
heart -mom right calf

Cell Location/Status
SPIN
Booking Type -FELONY-

CSOD-INTAK-PRO-01-020
2808973

Aliases

Charge Number:
1

Agency Report Number:
TS08003275

Offense Description:
SCHEME TO DEFRAUD ($50,000 OR MORE)

Statute:
817.034(4)(A)(1)/F

Court Case Number:
CRC0825947CFANO

Bond Assessed:
$50,000.00

Bond Amount Due:
$50,000.00

OBTS:
5206040391

2008 Pinellas County Sheriff's Office

Name:
RAINIER, JOSEPH V

DOB:
5/31/1958

Docket #:
1332818

Arrest Date:
12/9/2008 12:32:46 PM

Race:
WHITE

Sex:
MALE

Name RAINIER, JOSEPH V
Docket No. 1332818
Booking Date 12/9/2008 12:32:46 PM
Arresting Agency TARPON SPRINGS POLICE


Address
1396 WELLINGTON ST
TARPON SPRINGS
FL
34689

Race WHITE
MALE
5/31/1958
NJ
50

Eyes BLU
Hair GRY
Complexion LGT
Height 509
Weight 140

Scars, Marks & Tattoos
heart -mom right calf

Cell Location/Status
SPIN
Booking Type -FELONY-

CSOD-INTAK-PRO-01-020
2808973

Aliases

Charge Number:
1

Agency Report Number:
TS08003275

Offense Description:
SCHEME TO DEFRAUD ($50,000 OR MORE)

Statute:
817.034(4)(A)(1)/F

Court Case Number:
CRC0825947CFANO

Bond Assessed:
$50,000.00

Bond Amount Due:
$50,000.00

OBTS:
5206040391

2008 Pinellas County Sheriff's Office

TARPON SPRINGS At one time, Joseph Rainier and Ahmet Sandikci were best friends who shared a common interest: money.

Rainier has a rare coin shop next to Sandikci's paper currency store in the old Arcade Hotel building at 210 S Pinellas Ave.

But it was money $155,000, to be exact that would ultimately tear the two apart.

Tarpon Springs police say that over the summer, when Sandikci traveled out of the country, he asked Rainier to look after his store and bring in the mail.

But, according to Tarpon Springs police Detective William Peters, Rainier helped himself to some of Sandikci's blank checks during his periodic visits to the store. Peters said Rainier made four of them out to himself for $20,000, $30,000, $50,140 and $54,860 and deposited them into his bank account.

Rainier was arrested Tuesday on a charge of scheme to defraud and booked into the Pinellas County Jail. He was released after posting $50,000 bail.

Neither Rainier nor Sandikci could be reached for comment Wednesday.

Peters said that when Sandikci, owner of Arcade Currency Palace, discovered what had happened, he tried to get the money back from Rainier, owner of USPI Inc. When that failed, he went to police.

"He (Rainier) said he had permission to cash these things,'' Peters said. "(Sandikci) is saying no one had permission to go into the accounts.''

Eileen Schulte can be reached at schulte@sptimes.com or (727) 445-4153.

210 S. Pinellas Av.
Suite 154
Tarpon Springs, FL 34689
727-943-0041
727-692-2411
F: 727-943-0019
email

Cert. of Incorporation




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Defendant Joseph Rainier appeals from judgments entered in the United States District Court for the Southern District of New York following jury trials before John S. Martin, Jr., Judge , convicting him on a total of three counts relating to his falsely conveying the impression that he was an employee or representative of the United States, in violation of 18 U.S.C. 712, 912, and 913. On appeal, Rainier contends principally (1) that he was denied due process at his first trial because the district court gave the jury a supplemental instruction that constituted a constructive amendment of counts one and two of the original indictment; (2) that the second trial was barred by principles of double jeopardy; and (3) that his Sixth Amendment right to a fair trial was violated in his second trial because materials created by the first jury remained in the jury room and were seen by the second jury. We see no basis for reversal.

Rainier's contention that there was an impermissible amendment of the indictment with respect to counts one and two of the indictment provides no basis for reversal. Assuming arguendo that the court's instruction constituted such an amendment, the error was harmless. The jury was unable to reach a verdict on those counts, and a mistrial was declared. Rainier was thereafter retried on a superseding indictment that did not contain the language that Rainier complains was effectively eliminated in the court's supplemental instruction on the first indictment.

Rainier's contention that the second trial violated his right to be free from double jeopardy is without merit. Under the applicable test, see Blockburger v. United States , 284 U.S. 299, 304 (1932); Witte v. United States , 115 S. Ct. 2199, 2204 (1995), counts one and two were not duplicative of the count on which Rainier was convicted at the first trial. Further, whether or not the evidence at a first trial was sufficient, if the result was a hung jury the granting of a new trial after the consequent declaration of a mistrial does not violate the Double Jeopardy Clause. See , e.g. , Richardson v. United States , 468 U.S. 317, 323-26 (1984).

Finally, Rainier's contention that he was denied a fair trial by reason of the charts improperly left in the jury room provides no basis for reversal. While "extra-record information that becomes known to the jury is 'presumptively prejudicial,'" Bibbins v. Dalsheim , 21 F.3d 13, 16 (2d Cir.) (quoting Remner v. United States , 347 U.S. 227, 229 (1954)), cert. denied , 115 S. Ct. 261 (1994), exposure to such information does not automatically require a mistrial or a new trial. Rather, the court must consider the nature of the extra-record information, compare it to the evidence properly before the jurors, and assess the possibility of prejudice by determining the likely effect of the extra-record information on a typical juror. See , e.g. , Bibbins v. Dalsheim , 21 F.3d at 17; United States v. Weiss , 752 F.2d 777, 783 (2d Cir.), cert. denied , 474 U.S. 944 (1985); United States ex rel. Owen v. McMann , 435 F.2d 813, 818 (2d Cir. 1970), cert. denied , 402 U.S. 906 (1971). The trial court has wide discretion in determining how to pursue an inquiry into the effects of extra-record information on a jury, see , e.g. , United States v. Chang An-Lo , 851 F.2d 547, 558 (2d Cir.), cert. denied , 488 U.S. 966 (1988), and we will not overturn the court's assessment that the error was harmless unless we find an abuse of discretion, see , e.g. , United States v. Weiss , 752 F.2d at 783.

In the present case, the trial court received a note from the jury stating: "In the jury room there are four poster charts, and one of the posters was visible to all the jury members. The jurors recognized names that are familiar to the case. At that point, we turned over the poster so as not to see the chart. Does the Court want to remove these poster charts? Please advise." After the court and counsel for both sides viewed the charts, the court stated that it would ask the jurors whether they felt they had been affected in any way, and if they did not, it would allow them to proceed. The note indicated that only one of the charts had been visible; it did not indicate which of the four was seen or how much of the visible chart was read by the jurors. Counsel for Rainier did not request that either of these questions be put to the jurors. The court proceeded to inquire whether any juror felt there was anything on the charts that would influence him or her in any way in deciding the case. The jurors shook their heads in the negative. Counsel did not request any further substantive inquiry, or ask that the jurors be polled individually, or move for a mistrial. Given the jurors' negative responses, which were consistent with the indication in the note itself that upon recognizing familiar names the jury had promptly made an effort not to be influenced ("we turned over the poster so as not to see the chart"), the trial court permissibly concluded that there was no possibility of prejudice resulting from the presence of the charts. In the absence of any requests by counsel, we see no abuse of discretion in the procedure adopted by the district court, and we see no error in the court's conclusion that there was no prejudice.

We have considered all of Rainier's contentions on this appeal and have found in them no basis for reversal. The judgments of conviction are affirmed.