Plaintiff alleges that from 2011 to the present, she and as many as
250,000 other members of her purported class were misled about the financial
structure and likelihood of financial gain from their participation (through initial and
monthly membership fees) in WorldVentures’ business.
Plaintiff alleges that, despite what appeared to be truthful and encouraging Annual Disclosure Statements, the only way to generate income as a Sales Representative was not through the sales of travel-related services, but through the recruitment of additional Sales Representatives.
Plaintiff alleges that nearly all Sales Representatives lost money through their involvement with WorldVentures.
Plaintiff’s Complaint contains three causes of action arising under the Racketeer Influenced and Corrupt Organizations Act, (“RICO”) 18 U.S.C. §§ 1961- 1968, over which this Court has original jurisdiction pursuant to 28 U.S.C. § 1331. Count IV of Plaintiff’s Complaint alleges violations of 18 U.S.C. § 1962(a) arising out of a purported conspiracy which involved the investment of ill-gotten funds in an allegedly fraudulent enterprise. Count V of Plaintiff’s Complaint alleges that the defendants named in the State Court Action conducted their purportedly fraudulent affairs as an enterprise through a pattern of racketeering in violation of 18 U.S.C. § 1962(c). Count VI of Plaintiff’s Complaint alleges a section 1962(d) conspiracy by and between the defendants named in the State Court Action to violate sections 1962(a) and (c).
Plaintiff also alleges damages well in excess of $5,000,000.
Plaintiff alleges that “99.7% of WorldVentures enrollees average a loss of -$1057.77 per year.”
Based on Plaintiff’s allegation of a 250,000 member class and an alleged loss of $1,057.77 per member, the total loss per year alleged is $264,442,500.00.
As Plaintiff alleges losses occurring from 2011 to present, Plaintiff’s total alleged damages on behalf of the class are in excess of $1.5 billion.
Plaintiff alleges that, despite what appeared to be truthful and encouraging Annual Disclosure Statements, the only way to generate income as a Sales Representative was not through the sales of travel-related services, but through the recruitment of additional Sales Representatives.
Plaintiff alleges that nearly all Sales Representatives lost money through their involvement with WorldVentures.
Plaintiff’s Complaint contains three causes of action arising under the Racketeer Influenced and Corrupt Organizations Act, (“RICO”) 18 U.S.C. §§ 1961- 1968, over which this Court has original jurisdiction pursuant to 28 U.S.C. § 1331. Count IV of Plaintiff’s Complaint alleges violations of 18 U.S.C. § 1962(a) arising out of a purported conspiracy which involved the investment of ill-gotten funds in an allegedly fraudulent enterprise. Count V of Plaintiff’s Complaint alleges that the defendants named in the State Court Action conducted their purportedly fraudulent affairs as an enterprise through a pattern of racketeering in violation of 18 U.S.C. § 1962(c). Count VI of Plaintiff’s Complaint alleges a section 1962(d) conspiracy by and between the defendants named in the State Court Action to violate sections 1962(a) and (c).
Plaintiff also alleges damages well in excess of $5,000,000.
Plaintiff alleges that “99.7% of WorldVentures enrollees average a loss of -$1057.77 per year.”
Based on Plaintiff’s allegation of a 250,000 member class and an alleged loss of $1,057.77 per member, the total loss per year alleged is $264,442,500.00.
As Plaintiff alleges losses occurring from 2011 to present, Plaintiff’s total alleged damages on behalf of the class are in excess of $1.5 billion.
Comments
Post a Comment