• Report: #949902

Complaint Review: WECOSIGN, RICHARD LEGER,

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  • Submitted: Tue, October 02, 2012
  • Updated: Tue, October 02, 2012

  • Reported By: Enough Noise From Leger — Laguna Beach Cal United States of America
WECOSIGN, RICHARD LEGER,
Little Italy Laguna Beach, California United States of America

WECOSIGN, RICHARD LEGER, BOY THEy MUST BE MAD...... IVE LEARNED THAT ARESH SHIRDEL HAS BEEN SUED ALREADY AND MUST DISQAULIFY HIMSELF FROM THE LAW SUIT filed by PADILLA As promised see the lawsuit run and hide LEGER run and hi freakazoids you need an attorney Laguna Beach, California

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MERCEDES, YOU NHAVE NO IDEA WHERE THESE CARS CAME FROM OR THE MONEY. IM AN INSIDER AND I KNOW JUST FOR YOUR INFORMATION WHAT LEGER AND PADILLA DO NOT WANT YOU TO SEE THE REAL FACTS

PATENT HISTORY FRANK JAKUBAITIS
Patent Buddy

Patents
Patent Owners
Inventors
Technologies
U.S. Patent Attorneys
Patent Firms/Depts
Special Reports
Jakubaitis, Frank J
Inventor

Follow Status Updates
Stats  3 total patents filed
Oct 31, 2007 most recent filing
This is official USPTO record data
Details  3 Filed Patents  3 Total Citation Count

Oct 31, 2007 Most Recent Filing
Sep 2, 2004 Earliest Filing
Work History

Patent Owner
Applications Filed

2005  2007
Inventor Addresses    Address    Duration

Tustin Ranch, CA
Feb 15, 06 - Feb 15, 06

Tustin Ranch, CA
Feb 20, 08 - Feb 20, 08

Tustin, CA
Mar 01, 06 - Mar 01, 06
Technology Profile

Technology  # of Patents


G06Q:
DATA PROCESSING SYSTEMS OR METHODS, SPECIALLY ADAPTED FOR ADMINISTRATIVE, COMMERCIAL, FINANCIAL, MANAGERIAL, SUPERVISORY OR FORECASTING PURPOSES; SYSTEMS OR METHODS SPECIALLY ADAPTED FOR ADMINISTRATIVE, COMMERCIAL, FINANCIAL, MANAGERIAL, SUPERVISORY OR FORECASTING PURPOSES, NOT OTHERWISE PROVIDED FOR

H04L:
TRANSMISSION OF DIGITAL INFORMATION, e.g. TELEGRAPHIC COMMUNICATION

H04R:
LOUDSPEAKERS, MICROPHONES, GRAMOPHONE PICK-UPS OR LIKE ACOUSTIC ELECTROMECHANICAL TRANSDUCERS; DEAF-AID SETS; PUBLIC ADDRESS SYSTEMS
1

Patents / Publication
Patents / Publication #
Year of Publication / Issued
Title
Citations 3

2008/0046,375
2008
Method and System for Distributing Digital Works
Apple Music Card/ cards

2006/0045,301
2006
Speaker enclosure with a liquid chamber for mounting a speaker driver 1

2006/0036,505
2006 Method and system for distributing digital works

Cross Complainant Law Suit
 
FRANK  JAKUBAITIS,
 v.s. CARLOS PADILLA, III;  RICHARD LEGER ARESH SHIRDEL & MILTON C AULT III, Jury Trial demanded  $ 40,000,000.00 In Damages

DOES 1-20 INCLUSIVE Defendants
 
SA CV CASE ?: First Draft, precedent to Federal Complaint
 
 COMPLAINT FOR DAMAGES FOR: JURY TRIAL DEMANDED
 
(1)   CONVERSION
(2)   CIVIL CONSPIRACY
(3)   INJUNCTIVE RELIEF FROM CONVERSION
(4)   BREACH OF NON DISCLOSURE AGREEMENT
(5)   BREACH OF NON SOLICITATION AGREEMENT
(6)   SLANDER PER SE ( DEFAMATION)
(7)   INTERFEARANCE WITH PERSPECTIVE SHAREHOLDER ECONOMIC GAIN
(8)   INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS.
COMPLAINT

1.  Plaintiff Frank Jakubaitis, an individual plaintiff sues CARLOS PADILLA, III, RICHARD LEDGER & ARESH SHIRDEL, Plaintiff is uncertain as to the names of further  participants in this case, however plaintiff  sues such defendants under the names DOES 1-20 INCLUSIVE.  Plaintiff will amend this complaint when the same has been fully ascertained
 
NATURE OF COMPLAINT

CIVIL COPNSPIRACY AGAINST ALL DEFENDANTS

2. The action crosses State Lines from California to Nevada.  This case emanates from the  espionage and deliberate attempts undertaken by Defendants, CARLOS PADILLA,III, MILTON C AULT III ; RICHARD LEGER ; and their attorney of record ARESH SHIRDEL 

3. The defendant  formed a very sophisticated arms length transactional  group of conspirators who amongst themselves and others acted in an illegal enterprise crossing State Lines into the State of Nevada :The primary intent of the defendants was designed to

4.  Discredit the PLAINTIFFS present leadership among its shareholders, in WECOSIGN

5.   Induce shareholders to bring fraudulent litigation against the  plaintiff and his corporation
6.   Attempt to purchase the plaintiffs damaged corporation (after the fact) using straw buyers.  
7.  This action arises out of Defendants violations and conspiring amongst other causes of action.

8. Milton C Ault III name, and adopted the name  Co-Signer.com, using others that are affiliated with  questionable ethics or affiliations in the State of Nevada or affiliations with organized crime. To  further defect and or direct business to other present newly formed competitors, namely a group led by Milton C Ault III, & ARESH SHIRDEL holding themselves out as LetUsCosign.Com a Nevada corporation, operating from the law offices of ARESH SHIRDEL in California.  The group used a copy of WECOSIGNs proprietary methods and business model supplied by Carlos Padilla III a former employee of WECOSIGN . The group then moved the corporation from California to Nevada, washed the corporation down and deleted AULTS name from the corporate ownership records in an effort to conceal his identity from the fruits of the crime. The new Nevada entity is known as Co-signer.com

9.The defendants AS A GROUP misappropriated trade secrets, proprietary business information, converted confidential, information and intellectual property, originally stolen by Carlos Padilla III whilst he was an employee at WECOSIGN.

10. PADILLA and the group then embarked on making false defamatory statements against the plaintiff and his family, threatened them with bodily harm, evicted them from their ten year home, created an entire series of small claim suits (friends of the defendants) designed to additionally disparage and discredit the plaintiff and the company, and further transmitted these false statements to the open public ON RIP OFF REPORT.COM

11.  They then turned their efforts into a frivolous campaign designed to play a sympathetic script for the purpose of double teaming plaintiff using an individual named  STEURT TITUS, an investor AND HIS GIRLFRIEND MYA alleging  FRAUD and breach of contract against WECOSIGN and Jakubaitis, alleging loans in a separate suit in Superior Court designed further to harm Jakubaitis and further their on-going Interest and bring about further doubt as to the credibility of Jakubaitis  the plaintiff in this suit.

12.  Out of the many causes of actions alleged in another State Court action, one of the causes is for breach of contract alleging that Jakubaitis made a loan from TITUS in the amount of $30,000.00. This allegation was set forth under the penalty of perjury by PATRICIA TAKIM, the attorney for TITUS, a defendant in this case.   There is no truth to THE TITUS SUIT breach of contract filed by Patricia TAKIM. 

13.  There is no fraud in that suit, nor has there ever been

14.  There is no loan see (EXIBIT B) attached written by TITUSs own signature.

15.  Moreover if the fact pattern alleged by TITUS is correct and his motive to purchase stock is true as stated TITUS himself is guilty of insider trading, punishable by fine and or imprisonment as a result of his attorneys pleadings.

16.   Telephone recordings now have been retrieved from the previous voice mail of CARLOS PADILLA III (whilst he was an employee)  will evidence and show Carlos Padilla III as the creator of this scenario as he conspired with TITUS to bring this action.

17. TAKIM is also a willful participant in the crime of conspiracy with ARESH SHIRDEL MILTON C AULT, AND CARLOS PADILLA that will be proven at the time of trial. The TITUS SUIT  was  a suit that was  filed by TAKIM, at the suggestion of ARESH SHIRDEL to further induce public scorn against WECOSIGN AND JAKUBAITIS.
ADMINSITRATIVE COMPLAINTS FILED BY JAKUBAITIS

18. The plaintiffs in this case have complained to the California State Bar in regard to ARESH SHIRDEL AND PATRIICIA TAKIM, ON AN ETHICS VIOLATION.

19. The plaintiffs have also logged an active Federal Fair Housing complaint against PADILLA III and complained to the National Association of Farsi Attorneys, ALA- AKBAR in regard to SHIRDEL AND TAKIM AS FARSI ATTORNEY MEMEBRS  

20.  The plaintiff also has formal complaints logged with the SEC, the FBI, and the United States Post Office mail fraud unit against RICHARD LEGER OF LAGUNA BEACH.
THE PlAINTIFFs BUSINESS AND FORMER EMPLOYEES FACT PATTERN

21.  The plaintiffs company WECOSIGN offers a new and unique business service to the community. WECOSIGN enables parties who are credit deficient in FICO score to be admitted to traditional rental housing using WECOSIGN as a guarantor. WECOSIGN is not nor has it ever held itself out as an insurance company. Without WECOSIGN credit deficient applicants would otherwise be excluded from rental housing because of their FICO credit score.

22. WECOSIGN now has less than a 1% default rate nationwide, and has placed hundreds of residents successfully in rental apartments across the country. As of the filing of the instant complaint, WECOSIGN is a profitable entity, (less attorney fees) and has had a previous stellar reputation

23.   FRANK JAKUBAITIS (JAKUBAITIS ) plaintiff is the present CEO, creator and sole director responsible for the concept of WECOSIGNS novel business plan. JAKUBAITIS has created and conceived proprietary underwriting software that rates sub-standard credit applicants and will tell you when and if they will default USING probability algorithms. This software engages highly sensitive and proprietary material and took the better part of two years to develop.

24.  Defendant Carlos Padilla, III (PADILLA) was the CIO (Chief Information Officer) for WECOSIGN.  

25.  PADILLA Introduced Jakubaitis to a guy named David  SERIO, who introduced JAKUBAITIS to a woman named SANDY KIKERPILL a principal of (Cresa Partners now Cresa) in Newport Beach. California.

26.  CRESA is a real estate firm and Jakubaitis entertained the idea that Kikerpill would be a qualified board member at WECOSIGN since she was readily familiar with the real estate community and Jakubaitis was ready to take a break from WECOSIGN.  

27. Jakubaitis then expressed to KIKERPILL that he would be looking for a new CEO as well, for WECOSIGN, because he wanted to take a break.

28. KIKERPILL then informed Jakubaitis that she would make a loan to JAKUBAITIS to allow him to take a break (as she had plenty of money, in excess of 4 Million Dollars in the bank from selling a property) but JAKUBAITIS had to employ her new HUSBAND RICHARD LEGER first. KIKERPILL then went on to tell JAKUBAITIS that she wanted a baby, and did not want the father unemployed.

29. KIKERPILL FIRST agreed to buy stock personally from JAKUBAITIS, in the amount of $50,000.00. Kikerpill first check cleared the bank, and Kikerpill second check SHE WROTE was returned for NON SUFFICIENT FUNDS IN THE AMOUNT OF $25, 000.00 TWO TIMES.

30. Jakubaitis then became very uneasy as to them both. However after a second and third conversation Jakubaitis felt if KIKERPILL and LEGER had a personal financial interest in WECOSIGN LEGER would be a responsible employee and KIKERPILL would make a responsible board member.

31.  Jakubaitis then interviewed LEGER. LEGER and LEGER told JAKUBAITIS That he held a series SEVEN stock brokers license, and a real estate license..

32. JAKUBAITIS then decided that he could take a break with a loan to do so, since there was no salary to be made at WECOSIGN for him, and offered her unemployed new husband a CEOs job at WECOSIGN, but first their would be some training  

33.  Jakubaitis would then appoint KIKERPILL as a director and LEGER as CEO only on condition that KIKERPILL make the personal loan to Jakubaitis in the amount of $650,000.00 that would enable Jakubaitis to take the time away, and purchase a boat that he was looking at. The loan would be a comfort blanket for JAKUBAITIS regarding the company as he did not want to be CEO and only formed the company to sell it off for a profit so that the investors would make money, since there was no salary for Jakubaitis that could be supported by a start up. Jakubaitis told KIKERPILL about the boat purchase and what he intended for the money

34.  KIKERPILL then called JAKUBAITIS and agreed to visit and appraise the boat on Tuesday afternoon, however at the last minute sent KIKERPILL sent LEGER TO examine the boat at NATIONAL LIQUIDATORS dock on Pacific Coast Highway.. KIKERPILL said quote LEGER knows all about boats and would help JAKUBAITIS make the right choice.  

35. LEGER met with Jakubaitis and Jeff Padilla WECOSIGNS CFO, at the dock and examined the boat.   

36.  LEGER then went home and after a few hours KIKEROPIL called and notified JAKUBAITIS that they would be leaving for a Colorado vacation without any loan proceed being disbursed.

37.  JAKUBAITS Then told KIKERPILL to forget the entire deal as it represented grief for him.

38.  After KIKERPILL manipulated and apologized to JAKUBAITIS for the delay and then explained the bounced check, KIKERPILL then set forth a reduced amount, a compromised amount which turned out to be only $350,000.00 up front, and she would wire the money into the account of FRANK JAKUBAITIS  

39. Jakubaitis reluctantly accepted the amount, since an announcement had already been made to the employees and the plans had been made. Moreover JAKUBAITIS wanted out ! 

40. Kikerpill and Leger then made the promise to pay the balance of the loan ($300,000.00) after he took office as WECOSIGNS CEO.

41. Less than one month later LEGER returned from COLORADO and began going through the ranks of the employees (IN SPITE OF MANY WARNINGS FROM JAKUBAITS TO THE CONTRARY) telling employees that he would be in charge and things are going to change.

42. LEGER then intermittently began to become as he put it OUT OF POCKET not showing up for days, not participating in meetings and having a general disregard for the company. LEGER then began an internal vocal campaign with assertions like Jakubaitis, dont listen to him. This was the message passed to the employees by LEGER

43.The employees (including Padilla) then began to complain of LEGERS management style to Jakubaitis and for the most part wanted to quit.  

44. Finally, LEGER then went on to set up a meetings with RENT.COM, a new client of WECOSIGNs with KIKERPILLS knowledge as a director AND BEHIND Jakubaitiss back.

45.The LEGER plan was to meet the RENT,COM  people at the personal Ocean Front House of KIKERPILL AND LEGER in Laguna Beach

46.  The RENT.COM,/ e bay personnel declined his invitation, and reported this to JAKUBAITIS When Jakubaitis heard this he had enough. JAKUBAITIS immediately fired LEGER at 10 AM and told him to get out right now in front of eight other employees
47. LEGER then began to spread word all over town the very next day that he vowed to destroy The Jakubaitis family, and WECOSIGN after his abrupt exit. 

48.LEGER then embarked on a ghost writing campaign accusing JAKUBAITIS and his Family of criminal conduct in regarding WECOSIGN. Under the pen name of JOHN JUSTICE, with the assistance of David Sero, and Carlos PADILLA III

49.LEGER went to business associates that JAKUBAITIS had a relationship in the marine community with and told them that Jakubaitis was a criminal.. LEGER called people that Jakubaitis had a business relationship with in the NEWPORT BEACH community and told them he was from the SEC and was investigating JAKUBAITIS, The caller (LEGER) then hung up the telephone, when they asked what his telephone number was. 

50.LEGER had the Jakubaitis family harassed by PIs and hang up telephone calls in the middle of the night/

51.In APRIL of 2010 JAKUBAITIS removed PADILLA from the payroll of WECOSIGN AFTER TAKING A CALL from two investors that Carlos Padilla was working with SERIO and LEGER as an inside informant.

52. JAKUBAITIS then approached PADILLA and asked him if he wanted to buy the control block of stock from JAKUBAITIS of WECOSIGN. PADILLA agreed, however he needed the $200,000.00 down payment required by JAKUBAITIS.

53.  PADILLA began to solicit funds from the outside and his friend SERIO introduced him to MILTON C AULT.III, HOWEVER PADILLA never shared this person with JAKUBAITIS or what the trio had planned.

54. In June of 2010, PADILLA kept stonewalling JAKUBAITIS day after day in regard to the money and or deposit and Jakubaitis had other interest and wanted out.

55.PADILLA then began to plant listening devices in the office at WECOSIGN, began monitoring the e mail of Frank Jakubaitis, and otherwise had Jakubaitis followed by gang members of MS-13, Padillas relatives, by his own words.  

56.JAKUBAITIS  then lowered the down payment for PADILLA and finally became tired of his stories when JAKUBAITIS realized that PADILLA was running a con game, and asked PADILLA to leave the premises

57. After Padilla left and was ejected by JAKUBAITIS  PADILLA then retaliated and filed an Unlawful Detainer action on the JAKUBAITIs family using underhanded tactics as to process of service using Block 123 evict

58. Padilla FORGED THE original LEASE AGREEMENT using BLOCK 123 evict, along with USING white out  to cover up his sinister efforts and used the forged document as a vehicle to evict, and did so in retaliation only after JAKUBAITIS ejected PADILLLA from WECOSIGN.

59. Padilla committed fraud on the courts in department C-4 be asserting that he had no money, or property to pay for the filings and the unlawful detainer services. These services are still unpaid by PADILLA notwithstanding his ability to pay for these court fees.

60.  Padilla THEN TRANSFERRED HIS Washington state POPERTY A CONDOMINIUM THAT HE OWNED OUTRIGHT TO AMI KIM PRIOR TO THE first UD ACTION as a matter of public record denying that he owned any other property at the time of trial.

61. The defense of this suit cost the Jakubaitis family $ 61,000.00, to keep from being put in the street within three days, as due process was circumvented by PADILLA and his process server.

62. PADILLA and Serio also induced the following people to bring law suits to be filed in small claims court against WECOSIGN after his departure
(A) Maud Serio, David Serios Mother
(B) Frank Laurente of Santa Ana, California
(C) Elaine Thobe of Orange California
(D)  Nadine Winocur
(E)  Various other friends of Padilla;s including but not limited to his father.
(F)  Padilla also began meeting with individuals such as Skip Skibicki of Newport Beach holding weekly meetings with SERIO, further conspiring as to how to further damage the Jakubaitis family and WECOSIGN.
 
63. In AUGUST of 2010 Milton C Ault III approached JAKUBAITIS by a telephone call wishing to speak to him. Jakubaitis did not know Milton C Ault WAS THE ORIGINAL MONEY MAN Behind Padilla for the tentative purchase of WECOSIGN.   AULT was then invited to visit JAKUBAITIS by Jakubaitis to WECOSIGN.  AULT then admitted to JAKUBAITIS that he knew and conversed with PADILLA AND SERIO many times and was, to provide the funding to purchase WECOSIGN  

64. The real truth is that AULT never had any intention or money to purchase WECOSIGN, Jakubaitis ascertained. AULT was running a charade of his own to get proprietary information from PADILLA and SERIO to which they ( PADILLA AND SERIO) readily gave him on WECOSIGNs procedures

65.Two months later after JAKUBAITIS refused MILTON C Ault III offer to buy WECOSIGN, Milton C AULT professed that he created and then became the president and CEO of an entity called LETUSCOSIGN.COM The business venture LETUSCOSIGN was located at the same address of his long time silent partner and attorney ARESH SHIRDEL.

66.   When the group failed at the acquisition of WECOSIGN on the following attempts  

67. LEGER was fired for attempting a take -over from the inside, with the cooperation of his wife as she has been heard to say Richard this is what I do step back

68.  PADILLA was ratted out by two outside investors, that called and informed JAKUBAITIS that PADILLA was up to no good

69.AULTs offer of purchase was then rejected by JAKUBAITIS,

70. The group then began a cooperative effort to get even with JAKUBAITIS and engage in an illegal enterprise under the direction of Milton C Ault III, AND ARESH SHIRDEL AULTs long time legal counsel and silent business partner in a perverse pattern of racketeering.  

71.  In addition the Defendants orchestrated led by MILTON C AULT III an impotent illegal & illicit covert hostile corporate takeover attempt in an effort to extinguish the company and its respected corporate leadership, once the said business proprietary information was obtained.

72. The defendants then began to  exchanged and disseminated proprietary information, concerning WECOSIGN, induced other shareholders to bring false litigation THROUGH SHIRDELS friend from law school, PATRICIA TAKIM

73.As a consequence of PADILLA, and LEGERS unlawful conduct, Frank Jakubaitis as a major shareholder AND WECOSIGN have suffered  ir-reparable permanent financial damage, damage to his reputation, unfair competition from the dissemination of WECOSIGNS business proprietary information and trade secrets by PADILLA to AULT.,

74. WECOSIGN now seeks relief, including actual, punitive, and treble damages, along with Plaintiffs costs in investigation and prosecuting this action.

75. Through its conduct, as detailed below, PADILLA, LEGER, SHIRDEL, TAKIM AND AULT conducted or participated, directly, or indirectly, in the affairs of an enterprise through a pattern of racketeering activity, and/or conspired to do so, AND have extended the enterprise to Las Vegas Nevada.
 
PARTIES
A.  The Plaintiffs
 
76. Frank Jakubaitis is, and all times relevant is and was an individual with a principal place of business in the County of Orange, California
 
B. The Defendants
 
77.  Defendant, CARLOS PADILLA, III, is and at times relevant is and was a resident of the County of Orange, California.
 
78. Defendant ARESH SHIRDEL is and at times relevant is and was a residents of the County of Orange, California.
 
79. Defendant RICHARD LEGER AKA Kikerpill is and at times relevant is and was a resident of the County of Orange, California.
 
80.  Defendant, MILTON C AULT, III, is and at times relevant is and was a resident of the County of Orange, California.
 
JURISDICTION AND VENUE
 
81. This Court has; jurisdiction over the subject matter of this action, as the alleged acts were committed in the county of Orange
 
82. Defendant PADILLA is subject to personal jurisdiction on this forum because PADILLA resides in California committed the criminal wrongs described herein in California and engages in continuous and not isolated business in California.
 
83.Defendant LEGER is subject to personal jurisdiction on this forum because LEGER resides in California committed the wrongs described herein in California and engages in continuous and not isolated business in California.
 
84.Defendant ARESH SHIRDEL, is subject to personal jurisdiction on this forum because SHIDEL IS AN ATTORNEY residing in California, committed the wrongs described herein in California and engages in continuous and not isolated business in California.
 
85. Defendant Milton C Ault III, aka Milton T AULT III is subject to personal jurisdiction on this forum because SHIDEL IS AN ATTORNEY resides in California committed the wrongs described herein in California and engages in continuous and not isolated business in California.
 
GENERAL ALLEGATIONS
 
A. Defendants Overall scheme
 
86. FRANK JAKUBAITIS PLAINTIFF met with Defendants, who came recommended by PADILLA a former employee of WECOSIGN. FRANK JAKUBAITIS WAS INTRODUCED TO MS. SANDY KIKERPEL WHO INTRODUCED HER UNEMPLOYED HUSBAND RICHARD LEGER TO FRANK JAKUBAITIS, AND WECOSIGN.

87. In reality THE Defendants after they were refused the opportunity to operate OR TAKE OVER THE COMPANY by sinister methods , the group began acting in concert in a corporate espionage design to obtain and misappropriate business trade secrets, propriety information, and intellectual property from WECOSIGN to deliver to Mr. Milton C Alt III one that was thought capable of raising the money for the purpose of purchasing WECOSIGN, using PADILLA as an inside straw man.

88. Recognizing their peril, and having been caught with a plethora of inconsistencies, material misrepresentations, informants and questionable ethics and poor job performance level at WECOSIGN under  the JAKUBAITIS administration, Defendants undertook a sloppy corporate takeover and slander design leaving many to wonder the authenticity of Defendants characters and job performance abilities once discovered in the midst of their racketeering and alleged unlawful criminal conduct.
 
THE  ENTERPRISE
 
89.  Plaintiff is informed and believes thereupon alleges, that Defendants are members of, and operate as, an associated in fact enterprise (Enterprise) sharing a common purpose and engaged in a scheme, specifically intending to obtain illegally and have already  benefited from WECOSIGNS business propriety information, trade secrets, and intellectual property by posing as legitimate employees  and usurping such information through PADILLA by transmitting to AULT to aid and abet his illegal operation letuscosign.com
90.  Milton C Ault has already been convicted of violating FINRA, AND SEC RULES IN AN AMOUNT THAT EXCEEDS $400,000.00 and has been suspended as a result of previous acts such as these, with the full knowledge and further assisted by his attorney ARESH SHIRDEL.

91.Plaintiff is informed and believes and thereupon alleges, that the Enterprise shares organizational continuity in structure and membership and functions as a continuing unit that is separate and distinct from Defendants in their individual capacities with AULT as its head and HAS NOW BEEN LAUNDERED INTO Las Vegas Nevada WITH Casino and Mob Ties.
 
B. PATTERN OF CONSPIRACY
 
92. Plaintiff is informed and believes, and thereupon alleges, that Defendants are employed by and or associated with the Enterprise and that Defendants have conducted or participated directly or indirectly in the conduct of the Enterprises affairs through a pattern of racketeering activity.  Plaintiff is informed and believes, and thereupon alleges, that racketeering activity consists at least in part of the acts and events described herein which share a similar purpose results participants and/or methods of commission
 
b.  TRAFFICKING IN COUNTERFEIT GOODS
 
93.Plaintiff is informed and believes, and thereupon alleges, that Defendants have intentionally trafficked or attempted to traffic in financial services under spurious, counterfeit goods fobbing off AULTS illegitimate product with WECOSIGNS business proprietary information, strategy & execution, intellectual property, and trade secrets as their own which is likely to cause confusion, to cause mistake or to deceive others regarding the source or origin of Defendants  purported good and services from AULTS Enterprise.

94.Plaintiff is informed and believes and thereupon alleges, that this racketeering activity pattern and these acts of Defendants have adversely affected an interstate enterprise extending into Nevada and this adverse impact proximately cause injury to Plaintiffs business by converting Plaintiffs business proprietary information, trade secrets, and intellectual property and by diverting customers from Plaintiffs genuine services for their own profit gain and greed.
  
C. PADILLAS EMPLOYMENT WITH WECOSIGN AND THE NDA
D.  AKA STRAW MAN
 
95.  Defendant PADILLA was hired with WECOSIGN in or about August 2007

96. PADILLA boasted about his purported professional skills set in the fields of information technology, web design, and database management and creation thereof, in hindsight, PADILLA seemed like the ideal worker for WECOSIGN as new startup company.
 
97.JAKUBAITIS was eager to give PADILLA an opportunity to work for WECOSIGN based on what then appeared to be a good fit commensurate with PADILLAS skills and qualifications as PADILLA had advanced his vast experience is this subject matter, moreover Padilla agreed to sell the Jakubaitis family the house that they rented for a year however, stayed 10 years
 
98. As part of the executive position at WECOSIGN, PADILLA was given the initial title as CEO FOR A VERY SHORT PERIOD, then promptly removed because of his inability to perform the job as a CEO, strange behaviors and strange conduct.  
 
99.  Padilla was then demoted by Jakubaitis after several employees complained about his lies and given the position as CTO with direct responsibilities concerning WECOSIGNS information technologies management. It was at this juncture PADILLA became incensed about his being demoted, which gave him a principal of action and motive to act against JAKUBAITIS.
 
100.Since the proprietary business information, trade secrets, business strategy & execution, and intellectual property would be contained therein, PADILLA et-al and would need to agree not to distribute, nor disseminate any of the confidential business information that would be contained therein.
 
101.On or about August 2008, PADILLA signed the necessary executive contracts and NDA that contained various express terms to keep WECOSIGNS privacy and data protection.
 
102.As mentioned herein and throughout the complaint, PADILLA was merely an instrument from LEGERS and AULTS Enterprise to essentially undertake a corporate espionage and obtained most if not all of WECOSIGNS confidential information where he unconscionably remitted to Milton C Ault III for  LetUsCoSign.Com FORMED in late July of 2011.
 
103. PADILLA, orchestrated these events early on and did so in a perverted effort to receive their financial gain as it was PADILLA who brought SERIO into the purview of WECOSIGN as he held himself out as a person AND DOCTOR of social or otherwise societal contacts to people of means .  Mr. Milton C Ault, was solicited by SERIO  SERIO was found out to be not  a licensed physician of any sorts, yet claimed to be a doctor as evidence by his email title Dr David@yahoo.com
 
104.The bitter fact was PADILLA merely needed a cohort in fact to implement the wrongful design as evidenced by the development of LETUSCOSIGN.COM by AULT.
 
E.  PADILLAS POOR JOB PERFORMANCE
 
105. Whilst in the midst of PADILLAS job performance, PADILLA experienced woefully deficient interpersonal relationships that evidenced his general dishonesty.
 
106. On several occasions whilst interacting with various staff members several irregularities came to the attention of various workers with WECOSIGN.  An informal survey of PADILLAS co-workers reveal that 7 employees of WECOSIGN will testify that PADILLA would always leave every day at 2:00 PM.
 
107. PADILLA would not give sufficient explanation of where or why such early recess would be needed for him to attend to personal matters. Perhaps he wanted advance his participation in the criminal Enterprise commencing December 1st 2010.
 
108. Often times PADILLA could not get along with other staff members, raising his voice, unable to keep composure nor professional temperance and became verbally abusive and dismissive in his disturbing interaction with other WECOSIGN employees.
 
109. Finally, for all of the qualifications, and skills set he purportedly claims to have, WECOSIGNS general employee work force described him as incompetent; took forever to get something done; computer problems took forever; could not maintain a database or IT; and will testify that he lied on a continual basis, or told stories a notable common theme voiced throughout PADILLAS tenure. After a time Jakubaitis could no longer explain Padillas conduct and failed to do so.

110.By reason of the Defendants said breaches, tortuous conduct and/or repudiation of the same WECOSIGN has suffered loss and damages more detailed in each of the following specific counts:
 
COUNT ONE CONVERSION
 
111.Plaintiff repeats and re-alleges each of the allegations contained in paragraphs 1 through 113 as if  the same were fully set forth herein

112. At all relevant times FRANK JAKUBAITIS was a person AND THE MAJOR SHAREHOLDER OF WECOSIGN.

113.  At all relevant times, PADILLA, LEGER, SHIRDEL TAKIM and AULT were persons as in residents of Orange County.

114. At all relevant times, PADILLA, AULT, LEGER SHIRDEL TAKIM amongst other conspirators, formed an association-in-fact early on for the purpose defrauding, misappropriating Plaintiffs business propriety information, trade secrets, damaging its CEO FRANK JAKAUBAITIS, AND TARA JAKAUBAITIS IN A PUBLIC INTERNET FORUM and obtaining WECOSIGNS intellectual property.  This association in fact was an enterprise within the meaning of civil conspiracy

115. At all relevant times, this enterprise was engaged in, and its activities affected, interstate, and or out of state commerce

116. At all relevant times, PADILLA, AULT, LEGER SHIRDEL AND TAKIM with this enterprise conducted or participated directly or indirectly  in this conduct of the enterprises affairs through a pattern of racketeering activity within the meaning of civil; conspiracy to commit conversion

117. Specifically, at all relevant times, PADILLA amongst other conspirators engaged in racketeering activity by engaging in the acts set forth above. 

118. The acts alleged were related to each other by virtue of common participants, a common victim (FRANK JAKUBAITIS &WECOSIGN), a common method of commission via espionage, and the common purpose and common result of defrauding WECOSIGN and misappropriating its business proprietary information, trade secrets and intellectual property and enriching all of the conspirators involved at WECOSIGNS expense while concealing PADILLAS stealth and wrongful activities.  These wrongful activities continued for almost 1 year, beginning December and ending in June 2011

119. Specifically, PADILLA, AULT, SHIRDEL TAKIM AND LEGER conspired, confederated, and agreed with each other to conduct and participate in the conduct affairs of AULTS Enterprise through a pattern of racketeering activity and civil conspiracy

120.  Plaintiff has been injured in its business and property as a direct result and proximate result of the foregoing violations, lost all of its business proprietary information and trade secrets to date.

121. As a result of this misconduct, PADILLA and others are liable to FRANK JAKUBATIS for losses in an amount OF NOT LESS THAN $20,000,000.00 ( TWENTY MILLION DOLLARS)
 
122.FRANK JAKUBAITIS is entitled to recover threefold damages, plus costs and attorneys fees from PADILLA,, SHIRDEL, LEGER, AND AULT
 
WHEREFORE, Plaintiff prays for judgment jointly and severally, against Defendants for
1. Treble damages;
2. Interest as allowed by law;
3. Attorneys fees
4. The Costs of the action;
5. Such other relief as the Court shall deem just and appropriate.
 
COUNT II CONSPIRACY
 
123. Plaintiff repeats and re-alleges each of the allegations contained in paragraphs 1 through 96 as if fully set forth herein.

124. At all relevant times FRANK JAKUBAITIS was a natural person

125. At all relevant times, PADILLA, AULT, SHIDEL AND LEGER were persons subject to the jurisdiction of this court

126.  At all relevant times, PADILLA, ALT, LEGER TAKIM AND SHIRDEL amongst other conspirators formed an association-in-fact for the purpose defrauding, misappropriating Plaintiffs business propriety information, trade secrets, and intellectual property.  This association in fact was an enterprise

127.At all relevant times, this enterprise was engaged in, and its activities affected, interstate commerce

128. As set forth in Count One, PADILLA, AULT SHIRDEL AND LEGER, amongst other conspirators and wrong doers associated with this enterprise conducted or participated, directly or indirectly, in the conduct of the enterprises affairs through a pattern of racketeering and conspiracy
 
129.At all relevant times, PADILLA, AULT, SHIRDEL AND LEGER and other conspirators and wrong doers each were associated with the enterprise and agreed to conspire with weekly meetings.
 
130. PADILLA, AULT, SHIRDEL, AND LEGER, amongst other conspirators and wrong doers caused to be committed a series of over acts in furtherance of the conspiracy and to affect the objects there of including but not limited to the acts set forth above.
 
131. Specifically, PADILLA, LEGER, AULT,TAKIM & SHIRDEL and other wrongdoers conspired, confederated and agreed with each other to use and invest income and proceeds generated from a pattern of racketeering activity, which constituted violations of wire fraud statute, transportation and receipt of stolen property to another
 
132. As a result of PADILLA, LEGER, AULT, TAKIM SHIRDEL, and others, plaintiffs lost nearly all of their business proprietary information and trade secrets.
 
133.As a result PADILLA, LEGER, AULT TAKIM SHIRDEL, and other conspirators are liable to Plaintiff for its losses in an amount to be proven at trial
 
WHEREFORE, Plaintiff prays for judgment jointly and severally, against Defendants PADILLA, AULT, SHIRDEL,TAKIM PADILLA LEGER pursuant 18 U.S.C 1964 for:
1. Treble damages;
2. Interest as allowed by law;
3. Attorneys fees
4. The Costs of the action;
5. Such other relief as the Court shall deem just and appropriate.
///
COUNT III INJUNCTIVE RELIEF FROM CONVERSION
 
134.  Plaintiff repeats and re-alleges each of the allegations contained in paragraphs 1 through 64 as if fully set forth herein.

135.  On or about June 2011 at Orange County, California, the business proprietary information and trade secrets property described above had a value of $2,000,000.00

136. On or about June 2011 named Defendants took the property described above  and listed in Counts from Plaintiff's possession and was converted the same to their own use to advance the criminal enterprise under AULTS, PADILLA TAKIM SHIRDEL AND LEGERS leadership

137.On or about August 2011 Plaintiff (orally AND IN WRITING) plaintiff demanded the immediate return of the above-mentioned property but Defendants failed and refused, and continue to fail and refuse, to return the business proprietary information and trade secrets as described above to Plaintiff.

138.No adequate remedy exists at law for the injuries suffered by Plaintiff herein, insofar as further harm will result to Plaintiff from Defendant's wrongful act of conversion absent injunctive relief. If this court does not grant injunctive relief of the type and for the purpose specified herein, Plaintiff will suffer irreparable injury. Therefore, Plaintiff requests the following injunctive relief: an order enjoining Defendants from using and disseminating Plaintiff's business proprietary information, trade secrets, business strategy & execution, and intellectual property as it relates to Plaintiffs novel and unique business plan of co-signing for once deemed noncredit worthy tenants from advertising, using Plaintiffs proprietary software and algorithm calculations and an order to reveal all 3rd parties who may have this information to date of plaintiff's work to enable containment of Plaintiffs trade secrets.
 
WHEREFORE, Plaintiff prays for judgment jointly and severally, against Defendants  for:
1. Injunctive order and relief from conversion;
2. Attorneys fees
3. The Costs of the action;
4. Such other relief as the Court shall deem just and appropriate.
//
COUNT IV BREACH OF NON DISCLOSURE AGREEMENT
 
139. Plaintiff repeats and re-alleges each of the allegations contained in paragraphs 1 through 69 as if fully set forth herein.
 
140. Plaintiff and Defendants entered into a non-disclosure agreement concerning PADILLAS employment and the confidential nature of Plaintiffs business proprietary information and trade secrets, this was further extended to LEGER in relation to a possible availability of personal stock options that were to be made available to  LEGER would be privy to this trade secret and business proprietary information for explanation purposes only.
 
141. Between 2010 and 2011, Defendants breached the said non-disclosure agreement by revealing and making known Plaintiffs trade secret and business proprietary information to advance AULTs TAKIM AND SHIRDELS LETUSCOSIGN.COM enterprise.
 
142. Due to Defendants breach of said non-disclosure agreement, Plaintiff has suffered damages in the sum of no less than $500,000.00 against each Defendant.
 
143. By the terms of said non-disclosure agreement, Plaintiffs is entitled to recover reasonable attorney fees incurred in the enforcement of the provisions of the agreement.
 
WHEREFORE, Plaintiffs prays for judgment against Defendants as follows:
1. For compensatory damages in the sum of $100,000.00;
2. Attorneys fees
3. The Costs of the action;
4. Such other relief as the Court shall deem just and appropriate.
 
 
COUNT V BREACH OF NON SOLICITATION AGREEMENT
 
144. Plaintiff repeats and re-alleges each of the allegations contained in paragraphs 1 through 81 as if fully set forth herein:
 
145.Plaintiffs and Defendants into a non-solicitation agreement concerning the business proprietary information, business strategy and execution, trade secrets, and intellectual property of which both Defendants became privy thereto.
 
146.The consideration set forth in the agreement for employment and consultation that were to be remunerated thereof Defendants agreed expressly not share nor disseminate the confidential nature of Plaintiffs affairs and professional relationships.  Plaintiffs have performed all conditions, covenants, and promises required by them in their part to be performed in accordance with the terms and conditions of the non-solicitation agreement.
 
147.  Between 2010 and 2011, Defendants PADILLA, AND LEGER breached the said non-solicitation agreement by revealing and making public the confidential nature of Plaintiffs affairs business proprietary information, business strategy and execution, trade secrets, and intellectual property to the public at large and AULTS Enterprise.  Due to Defendants breach of said confidential agreement, Plaintiffs has suffered damages in the sum of no less than $300,000.00 against each named Defendant.
 
148.By the terms of said non-solicitation agreement, Plaintiffs is entitled to recover reasonable attorney fees incurred in the enforcement of the provisions of the agreement.
 
WHEREFORE, Plaintiffs prays for judgment against Defendants as follows:
1. For compensatory damages in the sum of $100,000.00;
2. Attorneys fees
3. The Costs of the action;
4. Such other relief as the Court shall deem just and appropriate
 
COUNT VI  SLANDER  PER- SE AGAINST  RICHARD LEGER,
 & CARLOS PADILLA III
 
149. Plaintiff repeats and re-alleges each of the allegations contained in paragraphs 1 through 88 as if fully set forth herein:

150. DEFENANTS, LEGER AND PADILLA after being dismissed from the employ of WECOSIGN for criminal conduct, the defendants and each of them jointly and severally began a smear campaign designed to have the entire WECOSIGN investment community bring frivolous actions against WECOSIGN and Frank Jakubaitis.  

151.The defamation began by anonymous letter writing under the phony pen name of John Justice AN ATTORNEY more specifically designed and sent out by RICHARD LEGER ARESH SHIRDEL When the plaintiffs discovered where the letters originated from (after an intense investigation) they issued a cease and DESIST LETTER TO LEGER, PADILLA. AND SERIO.  

152. LEGER and PADILLA mocked the plaintiffs IGNORED THE cease and desist letters AND BEGAN INCRESING their DISPARGING writings and oral statements ACCUSING THE JAKUBAITIS FAMILY OF COMMITTING CRIMES IN REGARD TO WECOSIGN.

153. As of September 21st 2012 the false postings are now public on the Internet for the entire world to see, are irreparable, and amount to Slander Per Se. The acts and or intentional acts omissions and or representations of the defendants, LEGER , PADILLA, SHIRDEL, and AULT to the other shareholders along with accusing the Jakubaitis family of, theft embezzlement and fraud, and irregular business conduct along with an entire host of criminal assertions and are now irreparable (SEE EXHIBIT A)  the JAKUBAITIS FAMILY AND WECOSIGN are entitled to $ 40,000,000.00 as an aggregate sum IN DAMAGES, whereby they are presumed damaged under the law in per se categories
 
WHEREFORE, Plaintiffs prays for judgment against Defendants as follows:
1.      For compensatory damages in the sum of $ 4,000,000.00 against each defendant
2.      For punitive damages in the amount of $ 40,000,000.00  
3.      Reasonable Attorney fees by motion
4.      The Costs of the action;
5.      5. Such other relief as the Court shall deem just and appropriate.
 
COUNT VII  INTERFEARANCE WITH PERSPECTIVE ECONOMIC GAIN OF THE  PRESENT SHAREHOLDERS OF WECOSIGN
 
154. Plaintiff repeats and re-alleges each of the allegations contained in paragraphs 1 through 127 as if THE SAME HAS BEEN fully set forth herein:
 
155. DEFENANTS, LEGER, (FIRST) and then  PADILLA ( SECOND) after being dismissed from the employ of WECOSIGN (in that order) for what was corporate criminal conduct, the defendants and each of them jointly and severally teamed up with SHIRDEL, & AUlT planned together to institute a smear campaign designed to have the entire WECOSIGN investment community bring frivolous actions against its founder and  FRANK JAKUBAITIS IN CONSPIRACY USING ARESH SHIRDEL as their COUNSEL. SHIRDEL legally manipulated and set forth a scenario of untruths, paving his way through the legal system on behalf of his silent business partner MILTON C AULT III.
 
156. SHIRDEL AND TAKIM have known that MILTON C AULT III has been involved in shady transactions in regard to his previous ventures as evidenced by AULTS recent participation and being fined by the SEC. With full knowledge of this SHIRDEL, and TAKIM proceeded forward in still yet another unsavory event on behalf of AULT to damage the Jakubaitis family. The defamation ACTS WERE DESIGNED TO THWART THE GROWTH OF WECOSIGN, INTERFERE WITH THE PROSPECTIVE ECONOMIC GAIN OF THE COMPANY AND THE JAKUBAITIS FAMILY. AND ADVANCE THE ENTERPRISE LETUSCOSIGN.COM.  
 
157.SUCH ACTS WERE INTENTIONAL, PLANNED AND ACTED OUT WITH MAILCE TO DESTROY THE REPUTATION OF THE COMPANY WECOSIGN, THE SHAREHOLDERS INVESTMENT AND THE JAKUBAITIS FAMILY.
 
WHEREFORE, Plaintiffs prays for judgment against Defendants as follows:
1. For compensatory damages in the sum of $ 2000,000.00 against each defendant
2. Attorneys fees
3. The Costs of this action;
4. Such other relief as the Court shall deem just and appropriate.
 
 (COUNT VIII) INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS AGAINST ALL DEFENDANTS

158. Plaintiff repeats and re-alleges each of the allegations contained in paragraphs 1 through 157 as if the same has been fully set forth herein: The defendants and each of them not only embarked on a mission to destroy the plaintiff and WECOSIGN, each defendant and severally carried out a plan to intentionally cause emotional and physical distress on the plaintiff and his family by: Threatening daily arrest in writing by the district attorney, threatening the plaintiff in writing by the SEC, notifying all of the share holders that in deed the plaintiff was and is part of a conspiracy to steel from the shareholders. Such conduct by LEGER and company went on for a period of six months in writing and still at this instant complaint is continuing. As a proximate cause of the defendants action and each of them the plaintiff has been injured emotionally is entitled to compensatory, and punitive damages according to law.
 
WHEREFORE, Plaintiffs prays for judgment against Defendants as follows:
1. For compensatory damages in the sum of $ 1000,000.00 against each defendant
2. Attorneys fees
3. The Costs of this action;
4. Such other relief as the Court shall deem just and appropriate.
 
Respectfully Submitted,

Wait Until You See The Federal Complaint LEGER 

By:__________________________________________
 

This report was posted on Ripoff Report on 10/02/2012 04:29 PM and is a permanent record located here: http://www.ripoffreport.com/r/WECOSIGN-RICHARD-LEGER/Laguna-Beach-California-92704/WECOSIGN-RICHARD-LEGER-BOY-THEy-MUST-BE-MAD-IVE-LEARNED-THAT-ARESH-SHIRDEL-HAS-BE-949902. The posting time indicated is Arizona local time. Arizona does not observe daylight savings so the post time may be Mountain or Pacific depending on the time of year.

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