Arifur Bhandari Scam. Beware!!!! Tampa Florida

Breach of Subscription Agreement and Demand for Refund and Rescission. Dear Ms. Bhandari: This firm represents Ivan Warnakulasooriya (“Ivan”) in connection with the subscription agreement dated October 28, 2023 (the “Subscription Agreement”), and letter of terms dated April 1, 2024 (“LOT”) (together, the “Agreement”), between International Petroleum Investments, LLC (“International Petroleum”) and Ivan in which International Petroleum has failed to fulfill its obligations. On October 28, 2023, in accordance with paragraph 2.2 of the Subscription Agreement, Ivan paid the sum of $100,000.00 (the “Initial Investment”) to International Petroleum to acquire preferred membership units. Pursuant to paragraph 2.2 of the Subscription Agreement, International Petroleum was obligated to pay Ivan monthly profits in the amount of $7,000.00. Subsequently, on April 1, 2024, the parties entered the LOT amending the terms of the Subscription Agreement, in which Ivan paid an additional $50,000.00 (the “Second Investment”) to acquire additional units in International Petroleum. In exchange, International Petroleum was required to pay Ivan the sum of $10,500.00 per month as required under paragraph 1 of the LOT. However, it has come to our attention that International Petroleum has ceased making the total monthly payments to Ivan as of August 1, 2024, and currently owes Ivan an outstanding amount in the sum of $17,500.00 for the months of August 2024 and September 2024. The referenced failure to pay Ivan all amounts as agreed to constitute a material breach of the Agreement. Moreover, paragraph 2.4(b) (misnumbered paragraph 2.3(b)) of the Subscription Agreement provides that— “Preferred Member may request a full refund of his or her investment at any time before the end of the five-year subscription term.” Thus, Ivan is at a International Petroleum Investments, LLC Re: Breach of Subscription Agreement and Demand for Refund and Rescission. September 23, 2024 Page 2 of 3 minimum entitled to terminate and rescind the Agreement upon written request for a full refund of the Investment. Additionally, contrary to your position that the transaction is usury, a subscription agreement for preferred shares in a company coupled with monthly profit payments would likely not be considered usurious under Florida law as profit participation is authorized by the usury statute and does not constitute additional interest. See Oregrund Ltd. Partnership v Sheive, 873 So. 2d 451 (Fla. 5th DCA 2004). Further, an agreement not characterized as a “loan” under the usury statute would not be subjected to its provisions. See Nolden v. Summit Financial Corporation, 244 So. 3d 322 (Fla. 4th DCA 2018). Moreover, the retention of funds after termination of a contract can constitute a conversion. See Eagle v. Benefield-Chappell, Inc. 476 So. 2d 716, 718 (Fla. 4th DCA 1985). Lastly, International Petroleum has been unjustly enriched, at the expense of Ivan, by retaining the funds as Ivan lost the benefit of his bargain when International Petroleum failed to pay Ivan as set forth in the Agreement. Rosado v. Barry Univ. Inc., 499 F. Supp. 3d 1152, 1160 (S.D. Fla. 2020). In sum, because of International Petroleum’s material breach, Ivan hereby terminates the Agreement and demands a full refund of the Initial Investment and Second Investment in addition to the outstanding amounts he is owed for the months of August 2024 and September 2024. Ivan is deeply dismayed by the utter lack of professionalism, negligence, and business ethics that you have displayed in failing to perform under the Agreement. Ivan has been damaged not only in the amount of his investment, but in the form of his lost anticipated profits that he expected to generate had the Agreement been performed as promised. Based on the foregoing, we hereby demand that, within thirty (30) days of your receipt of this letter, you tender the amount of ONE HUNDRED SIXTY-SEVEN THOUSAND FIVE HUNDRED AND 00/100 DOLLARS ($167,500.00), either in accordance with the enclosed wire instructions or via check made payable to The Carlin Law Firm, PLLC Trust Account and delivered to The Carlin Law Firm, PLLC to One Financial Plaza, 100 S.E. 3rd Avenue, Suite 1103, Fort Lauderdale, Florida 33394, during this firm’s business hours (8:30 a.m. to 5:00 p.m., Monday through Friday, exclusive of legal holidays). Time is of the essence of this demand. If you fail to timely or fully comply with this demand, then Ivan will have no choice but to commence legal action against you to collect the amounts owed to him. International Petroleum Investments, LLC Re: Breach of Subscription Agreement and Demand for Refund and Rescission. September 23, 2024 Page 3 of 3 GOVERN YOURSELF ACCORDINGLY. Sincerely yours, MARSHALL R. BERNER MRB/mp Enclosures: cc: Ivan Warnakulasooriya