COMPLAINT against ADAGIO HOUSE I & II PLC, ADAGIO HOUSE II LLC, ADAGIO HOUSE III… — Shao v. Customers Bancorp (Dkt. 1)

Summary

A pro se complaint filed May 22, 2025 as Document 1 in Yang Shao v. Customers Bancorp, Inc., No. 2:25-cv-02640-KSM, in the U.S. District Court for the Eastern District of Pennsylvania, pleading fraud, civil conspiracy, unjust enrichment and violation of federal lending and notarial laws, with a jury trial demand. It also names as defendants Customers Bank, Jay Sidhu, Sam Sidhu, Karl Danielian, Rosemary Dente and Tamara R. Thompson. The plaintiff alleges she bought two Scottsdale, Arizona properties on December 31, 2018 for $698,475.12 in cash and that fabricated agreements and a forged signature were used to support a $3.05 million loan and to force an auction on October 24, 2023. It asserts unjust enrichment of $3.4921 million and invokes the Fifth and Fourteenth Amendments. The 88-page complaint seeks damages, declaratory relief and an injunction.

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YANG SHAO
524 E 14TH AVE NAPERVILLE
IL 60563
shaoyang_suny@163.com
Defendant

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA

Yang Shao
Plaintiff,

Case Number：

vs.
Customers Bancorp, Inc.
Publicly traded holding company (NASDAQ: CUBI)
Address: 701 Reading Avenue, West Reading, PA 19611
Customers Bank
Pennsylvania-chartered bank, wholly owned subsidiary of
Customers Bancorp
Address: 701 Reading Avenue, West Reading, PA 19611
Jay Sidhu
Chairman of Customers Bancorp and Executive Chairman of
Customers Bank
Address: 701 Reading Avenue, West Reading, PA 19611
Sam Sidhu
President and CEO of Customers Bank, Vice Chairman of
Customers Bancorp
Address: 701 Reading Avenue, West Reading, PA 19611
Karl Danielian
Senior Vice President of Customers Bank, SBA National Sales
Manager
Address: 40 General Warren Blvd, Malvern, PA 19355
Rosemary Dente
Vice President, SBA Servicing and Liquidation, Customers
Bank
Address: Remote office, listed business address: 521 Park
Avenue, Freehold, NJ 07728
Tamara R. Thompson
Illinois Notary Public, Owner of Tamara R. Thompson
Consulting, LLC
Address: 718 W Vermont St, Villa Park, IL 60181
et al.,
Defendants

Complaint For Fraud, Civil
Conspiracy, Unjust Enrichment,
Violation of Federal Lending and
Notarial Laws, and for Declaratory
and Injunctive Relief
Jury Trial Demanded

JURY TRIAL DEMANDED


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COMPLAINT FOR FRAUD, CIVIL CONSPIRACY,
UNJUST ENRICHMENT, VIOLATION OF FEDERAL
LENDING AND NOTARIAL LAWS, AND FOR
DECLARATORY AND INJUNCTIVE RELIEF JURY
TRIAL DEMANDED

COMES NOW the Plaintiff, Yang Shao, appearing pro se, and
files this Complaint pursuant to Rule 1007 of the Pennsylvania
Rules of Civil Procedure. In support thereof, Plaintiff avers as
follows:
1. Background
1.1 This Complaint alleges the erroneous and fraudulent
execution of the loan agreement and related documents.
1.2 This Complaint alleges the Defendant’s role in facilitating
the issuance of a loan based on forged signatures and
misrepresentations of property ownership.
1.3 This Complaint seeks remedies for the financial and
reputational harm Plaintiff has suffered as a direct result of
Defendant’s actions.


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2. Facts and Reasons ：
Plaintiff Yang Shao, who has at all times been the sole
individual to fully purchase, with her own funds, the properties at
issue in this case—AZ Property No. 1 (4839 E Charleston,
Scottsdale, AZ) and AZ Property No. 2 (5328 E Anderson Dr,
Scottsdale, AZ). On December 31, 2018, Plaintiff paid the full
purchase price of $698,475.12 in cash to the previous owner, USS
Team Investments III LLC, thereby obtaining the complete and
exclusive ownership rights to AZ Property No. 1 and AZ Property
No. 2.

As the genuine, rightful, sole, and 100% owner of AZ Property
No. 1 and AZ Property No. 2, and with no other person or entity
having ever contributed a single cent toward the purchase of these
properties, no person or entity other than Plaintiff Yang Shao has
any legitimate claim to being the rightful owner of AZ Property
No. 1 and AZ Property No. 2, nor can anyone challenge Plaintiff
Yang Shao’s exclusive and lawful ownership of these properties.

Defendant, through fraudulent means, sought to recover a $3.05
million loan it had erroneously disbursed to Plaintiff’s previous
owner, USS Team Investments III LLC. These fraudulent actions
included fabricating a real estate purchase agreement, a fraudulent
loan agreement, a fraudulent Deed of Trust, a fraudulent guarantee
agreement, forging Plaintiff’s signature, fabricating real estate
valuations, and deceiving the Small Business Administration
(SBA). Despite there being no legitimate purchase agreement


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involving Plaintiff or her company for the Arizona real estate at
$3.495 million, Defendant falsely claimed Plaintiff
had borrowed $3.05 million under her company’s name to
purchase the Arizona real estate, instead of pursuing USS Team
Investments III LLC, which was the actual loan recipient.

On October 24, 2023, Defendant unlawfully forced the auction
Of AZ Property No. 1 and AZ Property No. 2, which Plaintiff had
fully purchased on December 31, 2018, with $698,475.12 in cash.
These actions resulted in the illegal seizure of Plaintiff’s two
Arizona properties, leading to Defendant’s unjust enrichment
amounting to $3.4921 million, significant financial harm to
Plaintiff, and severe damage to her mental health, exacerbating
her hereditary panic disorder.

Under Pennsylvania criminal law, Plaintiff Yang Shao, under
oath, declares that she has never participated in the fraudulent real
estate purchase agreement at the heart of this case, nor in the
resulting fraudulent loan agreement, Deed of Trust, or guarantee
agreement.

3. Legal Basis for Complaint

1). Fifth Amendment to the United States Constitution


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The Fifth Amendment protects Plaintiff’s private property
rights by ensuring that no person shall “be deprived of life,
liberty, or property, without due process of law; nor shall private
property be taken for public use, without just compensation.”
Defendant’s actions unlawfully deprived Plaintiff of her property
without due process and without any compensation.

2). Fourteenth Amendment to the United States
Constitution
The Fourteenth Amendment extends the Fifth Amendment’s
protections to state actions, ensuring that “no state shall deprive
any person of life, liberty, or property, without due process of law;
nor deny to any person within its jurisdiction the equal protection
of the laws. Defendant’s actions, facilitated by the Title
Company’s errors, violated these constitutional protections.

3). Pennsylvania State Constitution**
Pennsylvania’s Constitution further safeguards private property
rights and ensures that any deprivation of property follows strict
legal procedures and compensatory measures.

4). Related Protections
The constitutional guarantees against unlawful seizures and the
protections of private property in the Third Amendment indirectly


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reinforce Plaintiff’s rights to maintain exclusive ownership of
her lawfully purchased properties.

4. Relief Sought

Therefore, Plaintiff files this complaint against Defendant,
respectfully requesting that the Honorable Court:

1). Accept Plaintiff’s complaint to protect her legal
property rights over AZ Property No. 1 and AZ Property No. 2,
which she fully purchased with her own funds.
2). Uphold the protections of the Constitution and impose
penalties on Defendant for violating the constitutional rights of
Plaintiff by unlawfully seizing her lawfully owned properties in
Arizona.

5. Payer For Relief
WHEREFORE, Plaintiff respectfully requests that this Honorable
Court:
a. Grant Plaintiff leave to file this Complaint to assert the claims
set forth herein; and
b. Grant such other and further relief as the Court deems just
and proper.


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PARTIES

6. Defendants ("Defendant" or "Customers Bancorp, Inc., and
Customers Bank"), Pennsylvania corporations, are foreign entities that
have not been duly organized or authorized to conduct business within
the State of Arizona. as required under Arizona Revised Statutes
(A.R.S.) § 10-1501, which mandates foreign corporations to
obtain authority to transact business in the Arizona state.
7.Jay S. Sidhu, an individual and senior executive of Customers
Bancorp;
8.Sam Sidhu, an individual and executive of Customers Bancorp;
9. Karl Danielian, an individual and Senior Vice President of
Customers Bank;
10.Rosemary Dente, an individual and employee of Customers
Bank;
11. Tamara R. Thompson, an individual notary public,
12. Plaintiff Yang Shao ("Plaintiff" or "Yang Shao") is a
single immigrant and a foreign national who resides alternately
between China and Illinois. Since purchasing AZ Properties: AZ
Property No.1 and AZ Property No.2 from the seller, USS Team
Investments III LLC, on December 31, 2018, Plaintiff Yang
Shao has been the sole owner of AZ Property No.1 and AZ
Property No.2.
13. AZ Properties: AZ Property No.1 ， AZ Property No.2
and AZ Property No.3.


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1). AZ Property No. 1: The first house purchased by
Plaintiff, located at 5328 East Anderson Drive, Scottsdale,
Arizona 85254, Lot Size is 10335 sq ft, and was built in 1997
(Tax Parcel No.215-11-399, lot 15).
2). AZ Property No. 2: The Second house purchased by
Plaintiff, located at 4839 East Charleston Avenue, Scottsdale,
Arizona 85254 , Lot size is 8454 sq ft, and was built in 1998 ( Tax
Parcel No.215-11-977, Lot 56 ).
3). AZ Property No. 3: The third house located at 17814
North 56th Street, Scottsdale, Arizona 85254, Lot size is 9994 sq
ft, and was built in 1991. (Tax Parcel No. 215 - 11- 067, Lot 57).
Plaintiff did not purchase AZ Property No. 3.

14. USS Team Investments III LLC (" USS Team" o r
" S e l l e r " ) i s an Arizona limited liability company conducting
business in Maricopa county. At all relevant times, was t h e
s e l l e r o f t h e AZ Properties AZ Property No.1 and AZ
Property No.2 . On December 31, 2018, USS Team Investments
III LLC s o l d AZ Properties : AZ Property No.1 and AZ Property
No.2 to Plaintiff Yang Shao.

15. Endeavor 1 LLC and Endeavor AL LLC were
Plaintiff's Arizona limited liability companies. Kyle Scott
fraudulently copied, cut, and pasted Plaintiff Yang Shao’s
signatures from her prior land sale agreement dated August 3,
2017, and falsely designated his company, “Axcent,” as the
operating manager of these Plaintiffentities. Using this


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fraudulent authority, Kyle Scott colluded with the Defendant to
falsify documents, misrepresenting Endeavor 1 LLC as the owner
of the AZ Properties. He used Endeavor 1 LLC's name to secure a
fraudulent $3.05 million loan from Defendant, with Endeavor
AL
LLC and other entities or individuals acting as false guarantors for
this sham loan. Additionally, Kyle Scott privately opened bank
accounts for Endeavor 1 LLC and Endeavor AL LLC, ensuring
that only he and his wife were designated as the authorized signers
on these accounts. The Plaintiff has never opened any bank
accounts in Arizona for Endeavor 1 LLC or Endeavor AL LLC.
Plaintiff is not a signer on the bank accounts opened by Kyle
Scott for Endeavor 1 LLC and Endeavor AL LLC in Arizona and
had no knowledge of, nor any control over, the alleged monthly
loan repayment transactions between these bank accounts and
Defendant.
16. Kyle Scott is an individual who previously resided in
Illinois and currently resides in Arizona. At all relevant times,
Kyle Scott was and continues to be the manager of "Axcent" and
"Endeavor US " .

17.Maxime Scott is an individual who previously
resided in Illinois and currently resides in Arizona.
18. Axcent LLC ("Axcent") is a Florida limited liability
company conducting business in Florida. At all relevant times,


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Axcent was a foreign corporation not duly registered or authorized
to conduct business within the State of Arizona ， as required
under Arizona Revised Statutes (A.R.S.) § 10-1501, which
mandates foreign corporations to obtain authority to transact
business in the Arizona state. At all relevant times, Kyle Scott
was and continues to be the manager of "Axcent".

19. Endeavor US LLC ("Endeavor US ") is an Arizona
limited liability company conducting business in Arizona. At all
relevant times, Kyle Scott was and continues to be the
manager of Endeavor US LLC.

20. Adagio House II LLC, Adagio House III LLC, and
Adagio House I & II PLC ("Adagio II," "Adagio III," and
"Adagio I & II," collectively "Adagios") are Arizona limited
liability companies conducting business in Arizona. At all relevant
times, the Adagios entered into a fraudulent purchase agreement
with Kyle Scott's Endeavor US LLC to purchase the AZ
Properties ( AZ Property No.1, AZ Property No. 2 and and AZ
Property No.3) — three houses — for $3.495 million.
Concurrently, they were the recipients of the Defendant's
loan
disbursements.
21. Richard Murray is an individual residing in Arizona.
At all relevant times, was and continus to be Kyle Scott's
partner.


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22. Tod Decker is an individual at all relevant times, was
and continus to be Kyle Scott's partner.

23. Alliant National Title Insurance Company （ "Alliant
Title" or " Title company" ), a Colorado limited liability company
conducting business in Colorado. At all relevant times. Alliant
Title was the title company responsible for handing the closing of
the AZ Properties.

24. Driggs Title Agency Company ( "Driggs Agency" or
"Title Agency" ), a limited liability company conducting business
in Arizona. at all relevant times, Driggs Agency was the title
agency company handing the closing of the AZ Properties.
VENUE
25. Venue is proper in this District under 28 U.S.C. § 1391(b)(2)
because a substantial part of the events or omissions giving rise to this
action occurred in this District. Among other things: a. Defendants
Customers Bank and Customers Bancorp maintain their principal places of
business in Pennsylvania, which is within this District; b. The loan at issue
was issued and approved in Pennsylvania; and c. The planning, approval,
and oversight of the transaction occurred at Defendants’ headquarters in
Pennsylvania.
DISCOVERY TIER
26. Pursuant to Rule 26.2(c)(3) of the Pennsylvania Rules of
Civil Procedure, this case qualifies for assignment to Tier 3 by the
court.


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ALLEGATIONS COMMON TO ALL COUNTS
27. Plaintiff Yang Shao is a Victim of Defendant's Financial
Plaintiff Yang Shao has been subjected to a series of deliberately
orchestrated acts of financial fraud, identity theft, and document
forgery by Defendants, with the intent to deceive, exploit, and
generate unlawful profit. On October 24, 2023, Defendants
unlawfully and forcibly auctioned AZ Property No. 1 and AZ
Property No. 2—two residential properties that Plaintiff had
purchased entirely with her life savings—without due process or
lawful authority. As a direct result of Defendants’ willful and
malicious conduct, Plaintiff suffered not only substantial financial
losses but also severe emotional distress, including psychological
trauma exacerbated by her preexisting hereditary panic disorder.
(1). Defendant initially relied on falsified Arizona real
estate purchase agreements totaling $3.495 million (attached
hereto as Exhibit “1” and Exhibit “2”) without conducting
proper due diligence. Subsequently, for its own financial
benefit, Defendant employed forged documents, manipulated
property appraisals, and fabricated Plaintiff’s participation in
fraudulent loan and guarantee agreements. These fraudulent acts
were intended to deceive the Small Business Administration
(SBA) and obtain approval for a $3.05 million loan and related
guarantees.
(2). As a direct result of these fraudulent schemes, Defendant
unjustly deprived Plaintiff of Arizona real estate ( AZ property
No. 1 and AZ property No. 2) valued at $2.2921 million and net
profits of $1.2 million generated by those properties, resulting in
unjust enrichment totaling $3.4921 million.


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Furthermore, Defendant’s actions caused significant financial harm
and severe damage to Plaintiff’s mental health, exacerbating
her hereditary panic disorder.

(3). Defendant’s fraudulent conduct includes, but is not
limited to:
· Relying on false $3.495 million Arizona real estate
purchase agreements from the beginning : Defendant relied on
fraudulent Arizona real estate purchase agreements, such as those
involving Adagio Houses as sellers—entities that were not the
rightful owners of the Arizona Properties listed in the agreements.
The fraudulent agreements were executed between Kyle
Scott’s company, Endeavor US LLC, and the fictitious entities,
Adagio Houses. These agreements had no connection to
Plaintiff Yang Shao or her companies, Endeavor 1 LLC and
Endeavor AL LLC (attached hereto as Exhibit "1" and "2").

· To generate profit, Defendant fabricated a Loan
Commitment Letter: Defendant fabricated a loan commitment letter
to initiate the fraudulent scheme (attached hereto as Exhibit "3").
· To generate profit, the Defendant fabricated loan
agreements involving the Plaintiff's companies, Endeavor 1
LLC and Endeavor AL LLC, for a fictitious $3.05million loan. It
is well-established that real estate purchase agreements are the
prerequisite and foundation for loan agreements. However, the
Plaintiff’s companies, Endeavor 1


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LLC and Endeavor AL LLC, have never entered into any $3.495
million Arizona real estate purchase agreements with any
individual or entity.
The Defendant’s allegation that Endeavor 1 LLC and Endeavor
AL LLC borrowed $3.05 million from the Defendant to purchase
$3.495 million worth of Arizona real estate is entirely baseless,
lacking any factual foundation or credible source (attached hereto
as Exhibits "1" and "2").
Furthermore, the Defendant created fraudulent loan documents,
including, but not limited to, a Note containing inconsistencies
across multiple versions (attached hereto as Exhibits "4"and"5"),
as confirmed by expert analyses (attached hereto as Exhibits "8"–
"10").

· To generate profit, Defendant created Fraudulent
Guarantee Documents. To generate profit, the Defendant created
fraudulent guarantee documents. These include, but are not limited
to, mortgage documents with inconsistencies across multiple
versions (attached hereto as Exhibits "6"and"7"), as confirmed
by expert analyses (attached hereto as Exhibits "8"–"10").

· To generate profit, the Defendant inflated the 2018
appraised value of the Arizona Properties to $3.09 million,
despite their actual market value being under $1.5837 million.
The Defendant falsified these appraisals to secure SBA approval for
a $3.05 million loan and related guarantees (attached hereto as
Exhibits "11" and "12"). Defendant’s overvaluation of the


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Arizona Properties, falsely appraising them at $3.09 million in
2018 while their actual market value was less than $1.5837 million
(attached hereto as Exhibits "11," Pages 20/6a, 6b, 6c, and
Exhibit "12"), misrepresented their true worth and deceived the
SBA into approving the loan.
· To generate profit, the Defendant forged the Plaintiff's
signature: Defendant forged the Plaintiff's signature on the SBA
7(a) Borrower
Information
Form –
Representations,
Authorizations, and Certifications (attached hereto as Exhibit
"13," Page 2, and Page 6).
Plaintiff's signature on Exhibit "13," Page 2, appears on the
SBA 7(a) Borrower Information Form dated August 29, 2018.
However, the same signature also appears on Exhibit "13," Page
6, which is a sales contract for a piece of land sold by the
Plaintiff in Naperville, Illinois, dated July 3, 2017. These
signatures on Exhibit "13," Page 2 and Page 6, are identical.
It is impossible for the Plaintiff to have signed the same
signature on two entirely different documents, one dated July 3,
2017, and the other over a year later on August 29, 2018, as it is
not feasible for a person to produce two identical signatures on
separate occasions. The Plaintiff's signature on Exhibit "13,"
Page 2, was clearly copied from the Plaintiff's signature on
Exhibit "13," Page 6, and was unlawfully copy, cut and pasted by
Defendant onto the SBA 7(a) Borrower Information Form.


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This forged signature on the SBA 7(a) Borrower Information
Form dated August 29, 2018, was fabricated by the
Defendant through illegal means to deceive the SBA and falsely
implicate the Plaintiff as a guarantor for the fictitious $3.05
million loan (attached hereto as Exhibit "13" Page 2, and Page 6).

· To generate Profit, Defendant Falsified Notarial Records
： The notarial records submitted to the court are falsified.
Plaintiff, under penalty of perjury pursuant to P e n n s y l v a n i a criminal
law, affirms that prior to July 19, 2023, they had never met the
notary in question nor had any interactions with them. The records
lack a specific notarization time, and the stated notarization
location, "735 Executive Dr, Aurora, IL," does not exist. A
Google Maps search for this address yielded no results, and
Plaintiff personally drove along Executive Dr in Aurora, IL, but
found no such location (attached hereto as Exhibit
"14"). Furthermore, multiple handwriting examinations confirmed
that Plaintiff's signature on the notarial records was forged
(attached hereto as Exhibits "8"–"10").

· To generate profit, Defendant withheld Critical
Information: Defendant intentionally withheld critical documents
and information, including but not limited to: the SBA Loan
Authorization, loan-related details, guarantee-related details, and
failed to disclose key discrepancies in the Closing documents.
These discrepancies include contradictions in the identities of the
buyer, seller, and loan applicant, among others (attached hereto as


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Exhibits "1", "2", "3", "4", "5", "6", "7", "11", "12", "13",
"14", "15", "16", "17", "18", "19", "20", "21", "22").
28. Defendant failed to perform its duty of due diligence by
neglecting to verify the authenticity of the loan documents, the
Deed of Trust, and guarantees. Defendant neither confirmed the
Plaintiff's identity nor obtained her explicit consent for the
transactions in question. Furthermore, the Defendant did not inform
the Plaintiff about the loans, guarantees, Deed of Trust, or
mortgage-related matters until four years after the closing, on
August 11, 2022, for the first time (attached hereto as Exhibits
"22").

29. Defendant’s actions constitute gross negligence, fraud,
and breach of fiduciary duty. Defendant knowingly engaged in
fraudulent activities, including relying on false purchase
agreements, such as those involving the Adagio House entities as
sellers, who were not the actual owners of the properties listed in
the sales contracts (attached hereto as Exhibits "1" and "2").
This fraudulent purchase agreement was entirely unknown to
Plaintiff Yang Shao and her companies, Endeavor 1 LLC and
Endeavor AL LLC. Furthermore, neither Plaintiff Yang Shao nor
her companies were involved in or consented to this purchase
agreement. They had no connection whatsoever to the agreement
or the fraudulent transactions arising from it.
30. Plaintiff has suffered substantial financial losses and
emotional distress directly caused by Defendant’s actions.


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Defendant has unjustly enriched itself by approximately $3.4921
million through unauthorized deductions and profits from the
auction of the Plaintiff’s Arizona Properties (Arizona Property
No. 1 and Arizona Property No. 2).

· Unauthorized monthly deductions from the output of
Plaintiff’s Arizona Properties (Arizona Property No. 1 and
No. 2), totaling $1.2 million between 2018 and 2022.
· Illegally and forcibly auctioning Plaintiff’s Arizona
Properties (Arizona Property No. 1 and No. 2) in 2023, from
which the Defendant improperly profited $2.2921 million.
· Irreparable harm to the Plaintiff’s mental health, as well
as personal and professional reputation, compounded by ongoing
legal battles and foreclosure risks.

31. The Plaintiff seeks compensatory and punitive
damages, as well as any other relief the Court deems
appropriate. The Defendant’s egregious conduct warrants
severe
penalties to deter similar fraudulent activities in the future.
32. The Plaintiff requests the Court to order the judicial
authorities to initiate a comprehensive investigation into the
Defendant’s past loan operations and auction of
mortgaged
properties, in order to protect vulnerable consumers who have
had similar harmful experiences as the Plaintiff.


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Facts and reasons
33. In December 2017, Plaintiff Yang Shao ("Plaintiff"
or "Yang Shao") intended to reinvest $750,000 in proceeds from a
prior land sale in Illinois through a Form Section 1031 Like-Kind
Exchange, which was managed by Kyle Scott on July 3, 2017
(attached hereto as Exhibit "23"). As a result, Kyle Scott
gained access to
Plaintiff Yang Shao's identification information, financial
information, and signature (attached hereto as Exhibit "23", Page
5).
34. Due to the requirements of a Section 1031 Like-Kind
Exchange”—which allows reinvestment only in real properties under the
same seller's name—Plaintiff Yang Shao, having sold a real property
under the Form Section 1031 Like-Kind Exchange”on July 3, 2017, was
restricted to reinvesting in similar real properties and was prohibited
from purchasing other types of businesses.
35. Given that the Plaintiff was a new immigrant with
limited English proficiency, she subsequently continued to hire
Kyle Scott to identify suitable real properties for reinvestment.

36. On December 15, 2017, Kyle Scott recommended
twelve real estate projects for Plaintiff's initial consideration.
From these options, Plaintiff narrowed her selection to the
seventh deal including Arizona Properties three houses. On December
29, 2017, Kyle Scott sent a pricing proposal for the AZ
Properties, AZ Property No. 1, AZ Property No. 2, and AZ


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Property No. 3, totaling $1M for real properties and $2.7 M for
business (attached hereto as Exhibit "24").
37. Kyle Scott explained to Plaintiff that, pursuant to the
requirements of a Section 1031 Like-Kind Exchange—allowing
reinvestment only in real properties of a like kind—Plaintiff, who had sold
real property under the Form Section 1031 Like-Kind Exchange”on July 3,
2017, was restricted to reinvesting in similar real properties and was
prohibited from purchasing other types of businesses. As a result,
Kyle Scott advised Plaintiff to purchase the AZ Properties—
AZ Property No. 1, AZ Property No. 2, and AZ Property No. 3—
for a total of $1 million for real properties (exclusively allocated to the
real property portion (not for any business interests..., as prohibited under
the Form Section 1031 Like-Kind Exchange).
Kyle Scott further assured Plaintiff that his business partner,
Tod Decker, would purchase the business operations of the AZ
Properties. After Plaintiff acquired the real property portion of
the AZ Properties, Tod Decker would lease the real properties
from Plaintiff at market value and continue operating the
assisted living home. This arrangement would allow Plaintiff to
earn stable rental income from leasing the AZ Properties to
Tod Decker, ensuring minimal risk and consistent returns from
Plaintiff’s reinvestment (attached hereto as Exhibit "24").
38. At the time of the proposed transaction in 2018, the combined
market median value for the three properties was less than $1,583,700
(attached hereto as Exhibit "12"). Since the Maricopa County official
website only provides property assessments from the past five years, the
closest available reference is the 2020 assessed values:


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1). AZ Property No. 1: The first property purchased by
Plaintiff, located at 5328 East Anderson Drive, Scottsdale,
Arizona 85254, had a market value of $536,600 (attached hereto as
Exhibit "12").
2). AZ Property No. 2: The second property purchased by
Plaintiff, located at 4839 East Charleston Avenue, Scottsdale,
Arizona 85254, had a market value of $557,100 (attached hereto as
Exhibit "12").
3). AZ Property No. 3: The third property, located at 17814
North 56th Street, Scottsdale, Arizona 85254, which Plaintiff
never purchased, had a market value of $490,000 (attached hereto
as Exhibit "12").
The combined 2020 assessed value of all three properties totals
$1,583,700, which corroborates that the 2018 valuation should have
been lower than this figure. These values directly contradict the
Defendant’s inflated $3.09 million appraisal, which was used to
justify the SBA loan and guarantee approval.
39. However, because these three properties were
nonconforming structures,
purchasing them
would
necessitate substantial renovations to bring them into
compliance with Phoenix City's Zoning Rules, requiring an
additional expenditure of at least $500,000. Furthermore, in
2018, the United States was still recovering from an
economic downturn, and one of the property owners was
facing a renewed bankruptcy crisis, creating an urgent need
for cash. As a result, the asking price for the three
properties was 30% below the market median value and was
quoted at $1 million.


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1). Although the properties are zoned as R1-10, they are
nonconforming structures under Maricopa County and
Phoenix's zoning regulations for the following reasons:
(1). Lot Size Requirements:
·According to Maricopa County’s Zoning Ordinance,
R1-10 lots must have a minimum size of 10,000 square feet
(attached hereto as Exhibit "25").
· However, AZ Property No. 2, built in 1998, has a lot
size of 8,454 square feet (attached hereto as Exhibit "26") .
· Similarly, AZ Property No. 3, also built in 1998, has
a lot size of 9,994 square feet (attached hereto as Exhibit
"26").
(2). Side Yard Requirements:
· Under Phoenix’s Zoning Ordinance, side yards in
R1-10 zoning districts must be at least 7 feet wide (attached
hereto as Exhibit "27").
· All three properties, however, have side yards
measuring less than 7 feet (attached hereto as Exhibit
"28").
· These nonconformities were caused by renovations
made by the seller, who constructed buildings exceeding the
allowable size, resulting in noncompliant side yards.


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Consequently, none of the three properties meet the
requirements for R1-10 zoning. If Plaintiff were to
purchase all three properties, extensive renovations would
be required to bring them into compliance with Maricopa
County’s Zoning Rules, incurring additional costs of at
least $500,000.
2) At the time, in 2018, the United States was still
recovering from an economic crisis. The owner of AZ
Property No. 1 and The owner of AZ Property No. 2, Mrs.
Miheala Micu, was facing a renewed bankruptcy crisis and
urgently needed cash.
(1). Mrs. Mihaela Micu’s Bankruptcy History and
Subsequent Financial Transactions: Mrs. Mihaela Micu, the
previous owner of AZ Property No. 1 and AZ Property No.
2,
had previously filed for Chapter 11 bankruptcy
protection on June 7, 2010, which was discharged on
December 10, 2012 (attached hereto as Exhibit "29"). Six
years later, in 2018, she faced another financial crisis,
which compelled her to sell the AZ Properties—AZ
Property No. 1 (4839 E Charleston, Scottsdale, AZ) and AZ
Property No. 2 (5328 E Anderson Dr, Scottsdale, AZ) to
Plaintiff Yang Shao for $668,475, which was two-thirds
of the then-market price (attached hereto as Exhibit "30")
through a Form Section 1031 Like-Kind Exchange”(attached
hereto as Exhibit
"31").
(2). Purchase Price and Terms:


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i. The two properties, AZ Property No. 1 and AZ
Property No. 2, were sold for $668,475.The Title Company
overseeing the transaction was Alliant National Title Insurance
Company, and the escrow number was No. 18-06-137056JM （
attached hereto as Exhibit "32" ).
A. AZ Property No. 1:
·Address: 5328 East Anderson Drive, Scottsdale,
Arizona 85254 (Tax Parcel No. 215-11-399, Lot 15).
· Ownership History:
The property was owned by Mrs. Mihaela Micu, who
acquired the title on September 1, 2016 (RN#: 20061169428
(attached hereto as Exhibit "33" ).
Mrs. Micu filed for Chapter 11 bankruptcy protection in
the United States Bankruptcy Court for the District of
Arizona on May 27, 2010 (Case Number: 2:09-bk-29894
JMM, attached hereto as Exhibit "29").
She discharged her debts on December 11, 2012, and
retained ownership of AZ Property No. 1 (attached hereto as
Exhibit "29").
· 2018 Financial Crisis:


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Facing another financial crisis in 2018, Mrs. Micu sold
AZ Property No. 1 to USS Team Investments III LLC on
November 5, 2018 (attached hereto as Exhibit "34").
· Subsequent Transactions:
On December 31, 2018, USS Team Investments III LLC
sold AZ Property No. 1 together with AZ Property No. 2 to
Plaintiff Yang Shao under a Section 1031 Like-Kind
Exchange”
(attached hereto as Exhibit "30"and"31" ).
· The Title Company overseeing the transaction was
Alliant National Title Insurance Company, and the escrow
number was No. 18-06-137056JM (attached hereto as
Exhibit "32").

B. AZ Property No. 2:
·Address: 4839 East Charleston Avenue, Scottsdale,
Arizona 85254 (Tax Parcel No. 215-11-977, Lot 56).
·Ownership History:
The property was owned by USS Team Investments
LLC. USS Team Investments LLC acquired the title to AZ
Property No. 2 on December 30, 2013 (RN#: 20131093940)
( attached hereto as Exhibit "35").
USS Team Investments LLC also owned by Mrs.
Mihaela Micu (attached hereto as Exhibit "36").


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· 2018 Financial Crisis:
In 2018, facing a renewed financial crisis, Mrs. Micu's
company USS Team Investments LLC sold AZ Property No.
2 to USS Team Investments III LLC on November 5, 2018
(attached hereto as Exhibit "37" ).
· Subsequent Transactions:
On December 31, 2018 ， USS Team Investments III
LLC sold AZ Property No. 2 together with AZ Property No.
1 to Plaintiff Yang Shao under under a Form 1031
Exchange (attached hereto as Exhibit "30" and "31" ).
· The Title Company overseeing the transaction was
Alliant National Title Insurance Company, and the escrow
number was No. 18-06-137056JM (attached hereto as
Exhibit "32").
ii. The remaining $331,525 for AZ Property No. 3 (
17814 N 56th Street Scottsdale AZ ) was financed directly
by the seller under a rent-to-buy arrangement, bringing the
total purchase price for all three properties to $1 million.
· Alternative Financing for AZ Property No. 3:
As a new immigrant without employment, Plaintiff
did not qualify for a traditional loan. Therefore, the
remaining $331,525 for AZ Property No. 3 was financed
directly by the Seller under a rent-to-buy arrangements.
· Operational Agreement:


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Plaintiff Yang Shao agreed to retain the Seller to
continue managing the operations of the three assisted
living facilities associated with the properties. The
management agreement included an annual management fee
of $100,000.
· The arrangement for AZ Property No. 3 further
highlights the seller’s financial distress and willingness to
negotiate flexible payment terms.
In conclusion, these arrangements provided flexibility
and made the purchase price even more favorable for
Plaintiff.
40. Since the Plaintiff only had $750,000 in cash
proceeds from a prior land sale and, as a new immigrant
without employment, did not qualify for a traditional loan,
she ultimately selected and purchased AZ Property No. 1
and AZ Property No. 2 for an all-cash price of $668,475.12
using a Form Section 1031 Like-Kind Exchange”(attached
hereto as Exhibit
"30" and "31"). The Title Company overseeing the
transaction was Alliant National Title Insurance Company,
and the escrow number was 18-06-137056JM (attached
hereto as Exhibit "32").
On December 31, 2018, Plaintiff purchased AZ
Property No. 1 and AZ Property No. 2 for $668,475 from
the Seller, USS Team Investments III LLC ("USS Team" or
"Seller") using a Section 1031 Like-Kind Exchange”.
Additionally, the


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Plaintiff paid an extra $30,000in transaction-related fees,
bringing the total expenditure for the two houses to
$698,475.12. The transaction was facilitated by Alliant
National Title Insurance Company, under escrow number
18-06-137056JM (attached hereto as Exhibit "30", "31",
"32").
41. Engagement of Kyle Scott for Assistance with the
Arizona Properties Transaction:
The Plaintiff, a new immigrant and first-time entrepreneur in
the United States with very limited English proficiency, hired
Kyle Scott to assist her in completing the Arizona properties
transaction. To facilitate the process, Kyle Scott requested
detailed information regarding the Plaintiff's finances, financial
status, and resources.
42. Payment Request from Kyle Scott:
On February 12, 2018, Kyle Scott requested the Plaintiff
to pay him $130,000 as compensation for services he claimed to
have rendered in 2017 and 2018.

43. Tax Avoidance Suggestion by Kyle Scott:
At that time, Kyle Scott informed the Plaintiff that
issuing him a 1099 form would result in significant tax liabilities.
He requested that the Plaintiff transfer the $130,000 to him as a
gift, assuring her that this was a lawful method of tax avoidance in


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the United States. As a new immigrant unfamiliar with U.S. tax
laws, the Plaintiff believed Kyle Scott's assertions and
agreed to his request.

44. Proposal for Additional Investments by Kyle Scott:
Subsequently, Kyle Scott suggested that the Plaintiff
apply for a loan to purchase additional nursing homes. He
proposed a plan to acquire 15 to 20 nursing homes, renovate them,
and then package and sell them to a larger nursing home company
for profit.
45. Plaintiff's Decision and Acquisition of AZ Properties:
After careful consideration, Plaintiff concluded that Kyle
Scott's plan to acquire and remodel additional more nursing homes
was too risky, moreover, the Plaintiff, due to her lack of English
proficiency, did not have a stable job, thus did not qualify for a
loan. Instead, she opted to use the proceeds from a prior land sale
to purchase the AZ Properties. Plaintiff acquired AZ Property
No. 1 and AZ Property No. 2 for $668,475 through a Form 1031
Exchange (attached hereto as Exhibit "30", and "31") under
Escrow Number 18-06-137056JM (attached hereto as Exhibit
"32").
AZ Property No. 1 and AZ Property No. 2:
Plaintiff used the proceeds from a prior land sale to purchase
these properties for $668,475.12 via a Form Section 1031 LikeKind Exchange” under Yang Shao’s name and Escrow
Number 18-06-137056JM (attached hereto as Exhibit "23", "30",
"31", "32").


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46. On August 18, 2018 Defendant fabricated a loan
commitment letter as the beginning of their fraudulent scheme.

On August 11, 2022, four years after the closing, Defendant
provided the Plaintiff with the loan and guarantee documents for the
first time—documents of which the Plaintiff had no prior knowledge
(attached hereto as Exhibit "22" ). Among these was a commitment
letter dated August 18, 2018 (attached hereto as Exhibit "3" ),
allegedly sent to the Plaintiff via email by Karl Danlelian, the
Defendant's Senior Vice President. However, the Plaintiff never
received this email.

Moreover, the commitment letter contained two sets of
signature pages bearing different signatures attributed to Plaintiff.


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It is impossible for one person to produce varying signatures on
the same document. This blatant inconsistency in the commitment
letter alone serves as compelling evidence that the Defendant had
been orchestrating a fraudulent scheme targeting the Plaintiff,
exploiting her vulnerabilities as a new immigrant with limited
English proficiency and mental health issues from the outset.
This scheme was designed to entangle the Plaintiff in a fraudulent
47. Subsequently, Defendant forged Plaintiff's signature
on SBA7(a) Borrower Information For - Representations ,
Authorizations and Certifications.

Defendant colluded with Kyle fraudulently copied, cut, and
pasted Plaintiff Yang Shao’s signatures from her prior land sale
agreement dated August 3, 2017 (attached hereto as Exhibit "23",
Page 5), forged Plaintiff Yang Shao's signature on SBA7(a)
Borrower Information For - Representations, Authorizations and
Certifications (attached hereto as Exhibit "13").

48. Fraudulent Warranty Deed and Deed of Trust Creation
by Defendant and Title Company

During the Title Company's handling of the sale of AZ
Property No. 1 and AZ Property No. 2 by USS Team Investments
III LLC to the Plaintiff Yang Shao, Defendant colluded with the


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Title Company to produce a fraudulent Warranty Deed and Deed
of Trust .

1). Step One: Incorrect Buyer Name

Defendant, in collaboration with the Title Company, deliberately
listed the buyer of AZ Property No. 1 and AZ Property No. 2 as
Endeavor 1 LLC instead of Plaintiff Yang Shao.

Plaintiff was the sole individual who used her personal funds
totaling $698,475.12, derived from the proceeds of a prior land sale,
to pay the previous owner for the purchase of AZ Property No. 1
and AZ Property No. 2 through a Form 1031 Exchange under
her name (attached hereto as Exhibit "23", "30" and "31"). No
other individual or entity contributed a single dollar towards the
purchase of AZ Property No. 1 and AZ Property No. 2. Accordingly,
no person or entity other than Plaintiff Yang Shao has any legitimate
claim to being the rightful owner of AZ Property No. 1 and AZ
Property No. 2, nor can anyone challenge Plaintiff Yang Shao’s
exclusive and lawful ownership of these properties.

As this was a direct cash transaction facilitated under a Form
1031 Exchange, Plaintiff Yang Shao’s name was required to
appear on Escrow No. 18-06-137056JM for AZ Property No. 1 and


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AZ Property No. 2. Listing another party, such as Endeavor 1
LLC, as the buyer was legally improper.

The total purchase funds of $698,475.12 for AZ Property No. 1
and AZ Property No. 2 were paid entirely out of Plaintiff’s
personal finances (attached hereto as Exhibit "23" and "30"). No
other individual or entity paid any amount to the previous owner
for the acquisition of these properties. Despite this, Defendant and
the Title Company deliberately and unlawfully listed Endeavor 1
LLC as the buyer instead of Plaintiff Yang Shao.

The Defendant knowingly orchestrated this misrepresentation to
fabricate loan agreements falsely identifying Endeavor 1 LLC as
the borrower. Endeavor 1 LLC neither entered into any purchase
agreements with the previous owner of AZ Property No. 1 and AZ
Property No. 2 nor paid any funds for their acquisition. Listing
Endeavor 1 LLC as the buyer instead of Plaintiff Yang Shao was
entirely illegal. Had Plaintiff Yang Shao’s name been listed as
the buyer, it would have been apparent that a cash purchaser like
the Plaintiff would not require a loan.

Despite Plaintiff’s repeated requests to the Title Company
to correct this misrecording, the Title Company failed to act.
Listing Endeavor 1 LLC as the buyer instead of Plaintiff Yang
Shao was legally improper and demonstrates a deliberate effort to
obscure the true nature of the transaction.


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2). Step Two: Fraudulent Inclusion of AZ Property No. 3

The Defendant had the Title Company also improperly included
AZ Property No. 3 in the Escrow No. 18-06-137056JM Warranty
Deed (attached hereto as Exhibit 32). This inclusion facilitated the
Defendant in creating a false narrative that Endeavor 1 LLC
purchased all three AZ Properties—AZ Property No. 1, AZ
Property No. 2, and AZ Property No. 3—through loans and
fabricated guaranty documents.

Under U.S. tax law, Section 1031 Like-Kind Exchange”s require
that the value of new properties purchased not exceed 20% more than the
value of the previously sold property. The Plaintiff’s prior land
sale yielded $750,000, meaning the maximum allowable purchase
amount for the new properties was $900,000 (attached hereto as
Exhibit "23" and Exhibit "31"). The propsed three houses are
priced at one million dollars for real estate (attached hereto as
Exhibit "24"), exceeded this limit.

Furthermore, as a new immigrant without loan eligibility,
Plaintiff could not have financed the purchase of three
properties, particularly AZ Property No. 3. Therefore, the
Plaintiff’s Form Section 1031 Like-Kind Exchange proceeds
were used exclusively to purchase the two properties actually owned
by USS Team Investments III LLC—AZ Property No. 1 (attached hereto
as Exhibit "34") and AZ Property No. 2 (attached hereto as Exhibit


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"37"). The inclusion of AZ Property No. 3 in the Warranty Deed
was baseless and fraudulent.

The fraudulent inclusion of AZ Property No. 3 in Escrow No.
18-06-137056JM created a false record of the Plaintiff acquiring
all three properties. This misrepresentation further enabled the
Defendant to fabricate loan contracts, Deed of Trust and guaranty
documents associated with the purchase of the AZ Properties.
Despite the Plaintiff’s repeated requests for the Title Company
to correct this fraudulent Warranty Deed (attached hereto as
Exhibit "32"), no action was taken.

3). Step Three: Fraudulent Loan Agreement Creation

The Defendant, in collusion with T i t l e C o m p a n y executed
A fraudulent $3.05 million loan agreement. This agreement falsely
listed Endeavor 1 LLC—a shell company that neither signed a
purchase agreement for the AZ Properties nor contributed any
payment toward their purchase—as the borrower.

Under normal circumstances, it is inconceivable and
unreasonable for a bank to enter into a $3.05 million loan
agreement with a shell company like Endeavor 1 LLC. This
company neither signed a purchase agreement for the AZ
Properties, nor had involvement in the financial contributions of
AZ Properties purchase, and had no legitimate ownership interest


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in the AZ Properties. Such an arrangement defies standard banking
and lending practices and demonstrates clear intent to fabricate a
false transaction.

4). Step Four: Fraudulent Deed of Trust Creation

The Defendant colluded with Kyle Scott to execute a
fraudulent Deed of Trust in Endeavor 1 LLC's name. Under normal
circumstances, it is inconceivable for a bank to accept a Deed of
Trust from Endeavor 1 LLC, a party that neither signed a purchase
agreement for the AZ Properties nor contributed any payment,
there for, it is unreasonable to consider Endeavor 1 LLC as the
owner of the AZ Properties and allow it to execute a Deed of
Trust. This fraudulent conduct caused substantial harm to
Plaintiff Yang Shao’s ownership interests in the AZ Properties,
undermining her rightful claims and property rights of AZ Property
No. 1, AZ Property No. 2.

5). Step Five: Fraudulent Transfer of Ownership

The Plaintiff completed the full cash purchase of AZ
Property No. 1 and AZ Property No. 2 on December 31, 2018
(attached hereto as Exhibit "30"). However, the Defendant and
theTitle Company, without the Plaintiff's knowledge or presence,
improperly listed the ownership of AZ Property No. 1 and AZ
Property No. 2 under Endeavor 1 LLC on November 6, 2018. This


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transfer was carried out without notifying the Plaintiff, who was
the sole party providing the full payment for the AZ Properties
(attached hereto as Exhibit "30," "31," and "32"). This action is
both unreasonable and illegal.

This fraudulent conduct caused substantial harm to Plaintiff s
ownership interests in the AZ Properties, undermining her
rightful claims and property rights of AZ Property
No. 1, AZ Property No. 2.

49. Tax Law Limitations and Plaintiff’s Financial
Ineligibility

Plaintiff was advised by her accountant that under U.S. tax
law, when purchasing properties through a 1031 exchange, the
purchase price of the new properties cannot exceed 120% of the
sale price of the previously exchanged property. Based on the prior
land sale price of $750,000, the maximum allowable transaction
amount for the Arizona Properties was $900,000.

Given this legal limitation, it would have been impossible for
the Plaintiff to purchase three properties or to sign a real estate
purchase agreement for $3.495 million with the Seller.
Additionally, the Plaintiff could not have taken out a $3.05
million loan from the Defendant, as she lacked both the
financial means and eligibility for such a loan.


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This clear restriction under U.S. tax law, combined with the
Plaintiff’s financial situation, directly contradicts any claims
that the Plaintiff entered into agreements to purchase three
properties or obtained a $3.05 million loan.
50. Payment Breakdown for the Purchase of AZ Property
No. 1 and AZ Property No. 2
To complete the purchase of the two properties (AZ Property
No. 1 and AZ Property No. 2), Alliant National Title Insurance
Company ("Title Company") instructed Plaintiff to make five
separate wire transfers from August 9, 2018 through December 31,
2018, amounting to a total of $698,475.12. This sum comprised
$668,475.12 for the purchase price and $30,000 for transaction
fees. The wire transfers were made as follows (attached hereto as
Exhibit "30"):
1). August 9, 2018: The Title Company instructed Plaintiff to
transfer $50,000. Plaintiff transferred $50,000 on the same day
(attached hereto as Exhibit "38").
2). October 11, 2018: The Title Company instructed Plaintiff
to transfer $100,000. Plaintiff transferred $100,000 on the same
day (attached hereto as Exhibit "39").
3). October 22, 2018: The Title Company instructed Plaintiff
to transfer $15,000. Plaintiff transferred $15,000 on the same
day (attached hereto as Exhibit "40").


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4). November 5, 2018: The Title Company instructed
Plaintiff to transfer $518,475.12. Plaintiff transferred
$518,475.12 on the same day (attached hereto as Exhibit "41").
5). December 31, 2018: The Title Company instructed
Plaintiff to transfer $15,000. Plaintiff transferred $15,000 on
the same day (attached hereto as Exhibit "42").
From August 9, 2018 through December 31, 2018, Plaintiff
Yang Shao completed a total transfer of $698,475.12 to the Title
Company to finalize the purchase of AZ Property No. 1 and AZ
Property No. 2 (attached hereto as Exhibit "30").
Plaintiff Yang Shao did not complete the final payment for
the purchase of AZ Property No. 1 and AZ Property No. 2 until
December 31, 2018. However, prior to this, on November 6, 2018,
the Defendant and the Title Company improperly transferred the title of
AZ Property No. 1, AZ Property No. 2, and AZ Property No. 3
to Endeavor 1 LLC. This transfer was made despite the fact that
Endeavor 1 LLC had neither entered into a purchase agreement
with the seller nor contributed a single penny toward the purchase
of the AZ Properties.
This act is unreasonable and improper. Such an arrangement
defies standard banking and lending practices and demonstrates
clear intent to fabricate a false transaction. This fraudulent conduct
caused substantial harm to Plaintiff ’s ownership interests in the
AZ Properties of AZ Property No. 1, AZ Property No. 2,
undermining her rightful claims and property rights.


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51. Absence of a Signed Purchase Agreement
Plaintiff never signed a real estate purchase agreement with
the previous owner USS Team Investments III LLC for $3.495
million to acquire the Arizona Properties. Moreover, Plaintiff
never borrowed $3.05 million from Defendant Customers Bank.
The real estate purchase agreement was purportedly intended to
serve as the foundation for the loan contract. Without Plaintiff
having signed a $3.495 million real estate purchase agreement
with the Seller, it would have been impossible for a $3.05
million loan contract between Defendant and Plaintiff to exist.
Even if Plaintiff had considered purchasing the three Arizona
properties, it would have been illogical and unreasonable for
Plaintiff to agree to a $3.495 million purchase price when the
market value of the three properties at the time was under
$1,583.700 million (attached hereto as Exhibit 12).

52. Identification of Actual Purchaser and Fraudulent
Transactions
The fraudulent purchaser of the Arizona Properties valued at
$3.495 million, was Kyle Scott's company, Endeavor US LLC
which never contributed any funds towards the purchase of these
properties (attached hereto as Exhibit "1").
Plaintiff’s late attorney, Brian Stanley, obtained all
closing documents pertaining to this real estate transaction by
subpoenaing the Title Company with court approval (attached


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hereto as Exhibit “43”). Among these documents, the "Buyer /
Seller （ Owner ） Information (Please Complete and Return)"
explicitly identifies Kyle Scott as the purchaser of Arizona
Properties three houses (AZ Property No. 1 and AZ Property
No. 2 and AZ Property No. 3). Plaintiff is not listed as the
purchaser of these properties (attached hereto as Exhibit “15”).
On June 12, 2018, Kyle Scott and his company, Endeavor
US LLC ("Endeavor US"), entered into a fraudulent purchase
agreement with Adagio House I & II PLC, Adagio House II LLC,
and Adagio House III LLC (collectively, "Adagios") to acquire
Arizona Properties (AZ Property No. 1, AZ Property No. 2, and
AZ Property No. 3) for $3.495 million. This fraudulent agreement
served as the foundation for the fraudulent loan to
Defendant Customers Bank and the subsequent disbursement of
loan funds (attached hereto as Exhibit “1”and “2”).
53. Fraudulent
Negligence

Ownership

Claims

and

Defendant’s

Adagio House I & II PLC, Adagio House II LLC, and Adagio
House III LLC (collectively, "Adagios") were never the rightful
owners of the Arizona Properties (AZ Property No. 1, AZ Property
No. 2, and AZ Property No. 3) (attached hereto as Exhibit “2”).
The purchase agreement between
Kyle Scott and the
"Adagios" was entirely fraudulent.


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Had Defendant conducted even minimal due diligence, such
As verifying ownership records through the Maricopa
County Assessor's website, it would have been clear that the
"Adagios" did not hold legal ownership of the Arizona
Properties. Verifying property ownership is a standard and
essential step in the loan approval process, yet Defendant failed to
perform this critical task.
Based on this fraudulent purchase agreement, Defendant entered
the $3.05 million loan agreement with Kyle Scott and his
company Endeavor US LLC, without conducting the necessary
verification. This failure to exercise due diligence directly enabled
the fraudulent loan approval and subsequent disbursement of
funds.

54. Fraudulent Exploitation of Plaintiff’s Identity and
Misrepresentation of Property Values
To conceal the fraudulent real estate loan application,
Defendant’s Senior Vice President, Karl Danlelian misuse Plaintiff
Yang Shao’s personal and financial information，had access to
Plaintiff's sensitive information while representing her in the
sale of a previous property, exploited her position as a
vulnerable new immigrant with limited English proficiency and
a mental health condition. forged loan and guarantee documents,
falsely implicating Plaintiff and fabricating a narrative that she
and her company Endeavor 1 LLC had applied for a loan and
provided collateral to Defendant.


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On August 18, 2018 Defendant fabricated a loan commitment
letter as the beginning of their fraudulent scheme.
On August 11, 2022, four years after the closing, the Defendant
provided the Plaintiff with the loan and guarantee documents for
the first time—documents of which the Plaintiff had no prior
knowledge (attached hereto as Exhibit "22"). Among these was a
commitment letter dated August 18, 2018 (attached hereto as
Exhibit "3), allegedly sent to the Plaintiff via email by Karl
Danlelian, the Defendant's Senior Vice President. However, the
Plaintiff never received this email.
Moreover, the commitment letter contained two sets of
signature pages bearing different signatures attributed to Plaintiff
Yang Shao. It is impossible for one person to produce varying
signatures on the same document. This blatant inconsistency in the
commitment letter alone serves as compelling evidence that the
Defendant had been orchestrating a fraudulent scheme targeting
the Plaintiff, exploiting her vulnerabilities as a new immigrant with
limited English proficiency and mental health issues from the
outset. This scheme was designed to entangle the Plaintiff in a
fraudulent loan transaction of which she had no awareness.
Subsequently, Defendant forged Plaintiff's signature on
SBA7(a) Borrower Information For - Representations
, Authorizations and Certifications (attached hereto as Exhibit
"13").


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Defendant fraudulently copied, cut, and pasted Plaintiff Yang
Shao’s signatures from her prior land sale agreement dated
August 3, 2017 (attached hereto as Exhibit "23", Page 5), forged
Plaintiff's signature on SBA7(a) Borrower Information For Representations, Authorizations and Certifications (attached hereto
as Exhibit "13").
Furthermore, Defendant manipulated the property appraisal to
secure approval from the Small Business Administration (SBA) for
the fraudulent loan. Defendant inflated the appraisal value of the
Arizona Properties from their actual 2018 market value of under
$1,583,700 to $3.09 million, deceiving the SBA into granting
approval (attached hereto as Exhibit "11" and "12").
This scheme came to light only after Plaintiff’s persistent
efforts over four years. On August 11, 2022, four years after the
transaction was completed, Defendant provided Plaintiff with the
loan and guarantee documents for the first time, which Plaintiff
had never seen before (attached hereto as Exhibit "22").
Subsequently, Plaintiff’s late attorney, Brian Stanley, filed a
subpoena with the court on September 19, 2022, obtaining
materials that confirmed the fraudulent nature of this transaction
(attached hereto as Exhibit "43"). The details of this fraudulent
scheme are outlined as follows:

· Plaintiff's personal and financial information was misused
without her knowledge.


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·Real estate purchase agreement, Loan and guarantee
documents were forged to falsely implicate Plaintiff.
·The appraisal value of the properties was fraudulently inflated
to deceive the SBA.
· Plaintiff was unaware of the loan and guarantee documents
until August 11, 2022.
· Defendant's fraudulent conduct was further confirmed by
documents obtained via subpoena.
1). Fraudulent Purchase Agreement as Basis for Defendant's
Loan
On June 12, 2018, Kyle Scott and his company, Endeavor
US LLC ("Endeavor US"), entered into a fraudulent purchase
agreement with Adagio House I & II PLC, Adagio House II LLC,
and Adagio House III LLC (collectively "Adagios") to purchase
the Arizona Properties (AZ Property No. 1, AZ Property No. 2,
and AZ Property No. 3) for $3.495 million. This fraudulent
agreement served as the premise and basis for Defendant's fraudulent
loan application and subsequent loan disbursement (attached
hereto as Exhibit 1).

2). Fraudulent Ownership Claim by the "Adagios"
In fact, Adagio House I & II PLC, Adagio House II LLC, and
Adagio House III LLC (collectively "Adagios") were not the actual
owners of the Arizona Properties (AZ Property No. 1, AZ Property
No. 2, and AZ Property No. 3) (attached hereto as Exhibit "2").


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3). Failure to Verify Ownership in Fraudulent Real Estate
Purchase Agreement
This real estate purchase agreement was entirely fraudulent. If
the Defendant had conducted a simple inquiry on the Maricopa
County Assessor's website, they would have discovered that
Adagio House I & II PLC, Adagio House II LLC, and Adagio
House III LLC (collectively, "Adagios") were not the actual
owners of the Arizona Properties (AZ Property No. 1, AZ Property
No. 2, and AZ Property No. 3). Verifying property ownership is a
critical step in the loan approval process, yet the Defendant failed to
fulfill this fundamental requirement (attached hereto as Exhibit
"2").
4). Fabrication of a Loan Commitment Letter
The Defendant fabricated a loan commitment letter as part of
their fraudulent scheme.
On August 11, 2022, four years after the closing, the Defendant
provided the Plaintiff with the loan and guarantee documents for
the first time—documents of which the Plaintiff had no prior
knowledge (attached hereto as Exhibit "22"). Among these was a
commitment letter dated August 18, 2018 (attached hereto as
Exhibit "3"), allegedly sent to the Plaintiff via email by
Karl Danlelian, the Defendant's Senior Vice President. However, the
Plaintiff never received this email.
Moreover, the commitment letter contained two sets of
signature pages bearing different signatures attributed to Plaintiff.


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It is impossible for one person to produce varying signatures on the
same document. This blatant inconsistency in the commitment letter
alone serves as compelling evidence that the Defendant had been
orchestrating a fraudulent scheme targeting the Plaintiff, exploiting her
vulnerabilities as a new immigrant with limited English proficiency
and mental health issues from the outset. This scheme was designed
to entangle the Plaintiff in a fraudulent loan transaction of which she
had no awareness.

5). Forgery of Operating Agreements
On September 4, 2018, in collusion with Defendant's internal
bank personnel, Karl Danlelian, Kyle Scott forged the
operating agreements of Plaintiff's companies Endeavor 1 LLC
and Endeavor AL LLC (collectively, "Endeavors"). Kyle Scott
copied, cut, and pasted Plaintiff's signatures from her prior land
sale agreement dated August 3, 2017 (attached hereto as Exhibit
"23") and falsely represented his company, "Axcent," as the
operating manager of Plaintiff's companies (attached hereto as
Exhibits "8"-"10"). This scheme was designed to entangle the
Plaintiff in a fraudulent loan transaction of which she had no
awareness.

6). Failure to Verify Axcent's Legal Status
Defendant's internal bank personnel entered into forged loan
documents and a Deed of Trust. A simple search on the Arizona
Corporation Commission website would reveal that Kyle Scott's
company, Axcent, is an unregistered foreign entity in Arizona,


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rendering it ineligible to sign any contracts or Deeds of Trust.
Verifying the legal status of Axcent was a mandatory step in the
loan approval process, but the Defendant failed to conduct this
essential due diligence (attached hereto as Exhibit "44").

7). Handwriting Examination Confirms Forgery
Defendant's internal bank personnel entered into forged Note,
guarantee documents, and Mortgage. These forgeries were
confirmed through three rounds of handwriting examinations
(attached hereto as Exhibit "8" - "10").

8 ) . Unauthorized Signing of Documents
Plaintiff never authorized any individual or company to sign
AZ real estate purchase agreement at price for $3.495 M with any
Seller , let alone loan documents, Notes, Deed of Trust, guarantee
documents, or Mortgages on her behalf or on behalf of her
company.
9). To secure SBA approval for the loan, Defendant
engaged in fraudulent activities to deceive the SBA:
(1). Defendant submitted a fraudulent PurchaseSale Agreement to the SBA (attached hereto as Exhibit "1").
On September 19, 2022, Plaintiff's late attorney,
Brian Stanley, obtained all materials related to this real estate


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transaction through a subpoena issued to the Title Company
(attached hereto as Exhibit "43"). Among these Closing
documents, Plaintiff discovered for the first time an SBA
7(A) Guaranteed Loan Authorization, a document Plaintiff
had never received (attached hereto as Exhibit "11"). This
loan authorization explicitly required an Executed PurchaseSale Agreement to be obtained before disbursement (Exhibit
"11" page 12, section 3(b)(2)).
Plaintiff also saw the Purchase-Sale Agreement for the
first time among these Closing documents: on June 12, 2018,
Kyle Scott and his company, Endeavor US LLC
("Endeavor US"), entered into a purchase agreement with
Adagio House I & II PLC, Adagio House II LLC, and Adagio
House III LLC (collectively, "Adagios") to acquire the
Arizona Properties—AZ Property No. 1, AZ Property No. 2,
and AZ Property No. 3—for $3.495 million (attached hereto
as Exhibit "1"). This agreement served as the premise and
basis for Defendant's $3.05 million loan and its
disbursement.
All of these actions occurred without Plaintiff’s knowledge
or involvement.
However, Adagio House I & II PLC, Adagio House II
LLC, and Adagio House III LLC ("Adagios") were not the
actual owners of the Arizona Properties (AZ Property No. 1,
AZ Property No. 2, and AZ Property No. 3) (attached hereto
as Exhibit "2"). This Purchase-Sale Agreement is fraudulent.
A simple search on the Maricopa County Assessor's website
would have revealed that Adagios had no ownership of the
Arizona Properties. This verification is a standard and


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essential step in loan approval processes, yet Defendant failed
to perform it.
Instead, Defendant approved the loan application
Submitted by Kyle Scott and his company Endeavor US LLC
based on this fraudulent Purchase-Sale Agreement.
The fraudulent Purchase-Sale Agreement was the
foundation and starting point of the scheme to secure the SBA
loan and disbursement fraudulently.

(2). Defendant subsequently submitted fraudulent PurchaseSale a greement, loan documents, guarantee agreements, Deed
of Trust, and Mortgage to the SBA. The Purchase-Sale
Agreement served as the premise and foundation of the loan
documents. Without a legitimate purchase, how could there be
a loan? Without a legitimate purchase, why would a loan be
necessary? A fraudulent Purchase-Sale Agreement could only
result in a fraudulent loan.

Plaintiff and her company Endeavor 1 LLC never
entered a purchased the AZ Properties at the price for $3.495
M. How could Plaintiff possibly take out a $3.05 million
loan from Defendant for purchasing these properties? In this
case, it was Kyle Scott and his company, Endeavor US
LLC ("Endeavor US") , who were involved in the purchase of
the AZ Properties (attached hereto as Exhibit "2"). So how is
it possible that a loan agreement exists stating Plaintiff and


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her company Endeavor 1 LLC borrowed $3.05 million from
Defendant for purchasing these properties?

The only explanation is this: the loan agreement was also
fabricated, and any guarantee agreements based on this
fraudulent loan agreement are equally fraudulent. After three
rounds of handwriting examinations, it has been conclusively
determined that all signatures on the guarantee documents
were forgeries (attached hereto as Exhibits "8"–"10").
In this case, the fraudulent Purchase-Sale Agreement was
the initial step in the scheme, while the guarantee agreements
were the final product in the scheme. With both the purchase
and guarantee agreements proven to be fraudulent, how could
the loan agreement in between be genuine?
(3). Defendant inflated the appraisals of Arizona Properties
(three houses) to deceive the Small Business Administration
(SBA). Through a subpoena issued by Plaintiff’s late
attorney Brian Stanley on September 19, 2022, the
complete documentation of the real estate transaction was
obtained from the title company (attached hereto as Exhibit
"43"). This was the first time Plaintiff saw an SBA 7(A)
Guaranteed Loan Authorization, a document Plaintiff never
received (attached hereto as Exhibit "11"). Plaintiff found
that Defendant had inflated the appraisals of the Arizona
Properties (three houses) to $3.09 million in 2018 to deceive
the SBA.


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i. According to the SBA 7(A) Guaranteed Loan
Authorization (attached hereto as Exhibit "11"), Defendant
was required to ensure that the appraised value of the Arizona
Properties (three houses) was not less than $3.09 million
before disbursement of the loan (attached hereto as Exhibit
"11" p13, Term“6”- Appraisal):
· AZ Property No. 1 (5328 E Anderson Drive, Scottsdale,
AZ): Not less than $1 million.
· AZ Property No. 2 (4839 E Charleston Ave, Scottsdale,
AZ): Not less than $1 million.
· AZ Property No. 3 (17814 N 56th Street, Scottsdale, AZ):
Not less than $1.09 million.
ii. However, the actual median market value of the
Arizona Properties in 2018 was less than $1,583,700—
under $1.6 million (attached hereto as Exhibit "12").
Because the Maricopa County Assessor public website
only provides real estate market prices from the past five
years, data for 2018 cannot be obtained. However, since the
United States was still in the midst of an economic crisis in
2018, real estate prices were generally lower than in 2020.
The actual median market value of the Arizona Properties
(three houses) in 2018 was less than $1,583,700 (attached
hereto as Exhibit "12").
In 2020, the market value for the Arizona Properties
were as $1,583,700 :


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· AZ Property No. 1 (5328 E Anderson Drive, Scottsdale,
AZ): $536,600
· AZ Property No. 2 (4839 E Charleston Ave, Scottsdale,
AZ): $557,100
· AZ Property No. 3 (17814 N 56th Street, Scottsdale,
AZ): $490,000
iii. Moreover, the Arizona Properties were zoned as R110, and under Phoenix City zoning regulations, side yards
must not be less than 7 feet (attached hereto as Exhibit "27").
During prior renovations, the seller overbuilt the properties,
reducing the side yards to less than 7 feet, rendering the
structures illegal (attached hereto as Exhibit "28").
If Plaintiff had purchased the three properties, she
would have needed to invest at least $500,000 to bring the
buildings into compliance with Phoenix City zoning
regulations. This significant required renovation lowered their
appraised value.
Even in 2023, after three years of a real estate boom, and
assuming the properties are considered legal structures, their
median combined market value was $2,254,700:

· AZ Property No. 1 (5328 E Anderson Drive, Scottsdale,
AZ): $770,100
· AZ Property No. 2 (4839 E Charleston Ave, Scottsdale,
AZ): $773,000


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· AZ Property No. 3 (17814 N 56th Street, Scottsdale, AZ):
$711,600
Even in 2023, after three years of a real estate boom,
Arizona properties's value was still far below $3.09 million,
Defendant's 2018 appraisals of the Arizona Properties which
Defendant submitted to for deceiving Small Business
Administration (SBA) (attached hereto as Exhibit "11 " and
Exhibit "12" ):

It is inconceivable that Defendant valued the properties at
$3.09 million in 2018. This inflated valuation demonstrates
Defendant’s fraudulent scheme to deceive the SBA by
artificially increasing the appraised value of the collateral to
secure a SBA loan (attached hereto as Exhibit "11" and
"12").

(4). Defendant engaged in covert operations and concealed
all facts and information from Plaintiff.
Through a subpoena issued by Plaintiff’s late
attorney, Brian Stanley, the complete documentation of
the real estate transaction was obtained from the title company
(attached hereto as Exhibit "43"). For the first time,
Plaintiff saw the SBA 7(A) Guaranteed Loan Authorization,
a document Plaintiff never received (attached hereto as
Exhibit "11").


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The SBA 7(A) Guaranteed Loan Authorization, on page
13, section 7(a)(1), explicitly required that a copy of this
document be provided to the borrower before the loan
disbursement. However, Plaintiff and Plaintiff's company
Endeavor 1 LLC never received this document.
Without being the borrower, it would have been
impossible for Plaintiff and her company Endeavor 1 LLC
to receive the SBA Authorization document or to have any
knowledge of its contents. This demonstrates Defendant's
deliberate withholding of critical information from Plaintiff,
further reinforcing the fraudulent nature of this transaction.
10). Defendant forged Loan documents: Note.
On August 11, 2022, four years after the closing, Defendant
sent the loan documents and guarantee document to Plaintiff
for the first time, documents of which Plaintiff had no prior
knowledge (attached hereto as Exhibit "22" ), including a Note
(attached hereto as Exhibit " 4" ). S u b s e q u e n t l y , o n
August 25, 2023, Defendant submitted the other version o f t h e
Note to the court (attached hereto as Exhibit 5 ).
These two notes are different versions, yet both contained
M r . K y l e S c o t t ' s identical signature pages. It is
impossible for a person to produce two different version
documents with identical signatures on both. The appearance of
these two Notes provides unequivocal evidence that Defendant
forged loan documents, specifically the Note (attached hereto as
Exhibit "4" and "5" ).


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11). Defendant forged mortgage documents for the property
at 524 E. 14th Avenue, Naperville, Illinois.
On August 11, 2022, four years after the closing, Defendant
sent the loan document and guarantee document to
D e f e n d a n t for the first time, of which Plaintiff had no
prior knowledge (attached hereto as Exhibit "22" ), including a
mortgage document for t h e p r o p e r t y a t 524 E.14th
Avenue, Naperville, Illinois (attached hereto as Exhibit "6" ),
which Plaintiff had no prior knowledge. S u b s e q u e n t l y , o n
August 25, 2023, Defendant submitted the other version o f
mortgage document for t h e p r o p e r t y a t 524 E. 14th
Avenue to the court (attached hereto as Exhibit " 7").
These two mortgage documents are different versions,
however both contained Plaintiff identical signature pages.
It is impossible for a person to produce two different version
documents with identical signatures on both. The appearance of
these two mortgage documents provides clear evidence that
Defendant forged loan documents, specifically the mortgage
documents (attached hereto as Exhibit "6" and "7" ).

12). Defendant engaged in fraud by colluding with Kyle
Scott and his partners, Richard Murray and a n d
Tod Decker, to deceive the SBA.
Plaintiff, a newly immigrated single mother ,did not meet the
qualifications to be a SBA loan guarantor. Despite this


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Defendant, i n c o ll u s io n with Kyle Scott and his partner
Richard Murray, f a l s e l y p r e s e n t e d them as
guarantors and f a c i l i c a t e d t h e signing of fraudulent
guarantee documents to meet the SBA's guarantor
requirements. Defendant also forged Plaintiff's signatures on the
guarantee documents (attached hereto as Exhibit "8" - "10").
On November 2, 2018, Defendant instructed Title Company to
release loan funds to Adagios based on the flaudent real estate
purchase agreement (attached hereto as Exhibit "1", "16").
S u b s e q u e n t l y , o n November 6, 2018, Defendant Authorized
Title Company to release loan funds to Adagios based on the
flaudent real estate purchase agreement (attached hereto as Exhibit
"1", "17").
However, Title Company did not follow Defendant 's instruction
and wrongly released the loan funds to USS Team Investments III
LLC o n November 6, 2018 (attached hereto as Exhibit "18" ).
On the same day, Kyle Scott authorized Title Company to
wire $198,000 to his partner Richard Murray a n d Tod
Decker as a " consultation fee" . Tod Decker received
$53,540, and Richard Murray received $144,793.33
(attached hereto as Exhibit "19" and "20").
When recommending that Plaintiff purchase the
AZ Properties,
Kyle Scott further introduced
Plaintiff to his partners, Richard Murray and
Tod Decker, claiming that they would purchase the
business. Kyle Scott assured Plaintiff that she
could lease the properties she purchased AZ property


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No.1 and AZ property No.2 to
Tod Decker for
profit. However, this promise was never fulfilled.
Instead, the AZ Properties (specifically AZ Property No.
1 and AZ Property No. 2), which Plaintiff purchased
using $698,475.12 from her own funds, were
fraudulently transferred to Endeavor 1 LLC,the
company that neither signed any purchase agreement for
the AZ Properties nor contribute a single dollar toward
the purchase. Subsequently, the Defendant forcibly
auctioned the Defandant's properties AZ Property No. 1
and AZ Property No. 2 which Plaintiff purchased using
$698,475.12 from her own funds.
After forcibly auctioning off Plaintiff's Arizona
Properties, Defendant unilaterally withdrew the claims in
this case against Kyle Scott and his partner,
Richard Murray, allowing them to evade their full
guarantor liabilities for the loan. This carefully
orchestrated scheme clearly demonstrates Defendant's
intentional fraudulent conduct while enabling key
accomplices to escape accountability.
This sequence of events clearly demonstrates that
the entire transaction was a deliberate scheme from the
outset.

13). Defendant Colluded with the Title Company to Conceal
the Closing from Plaintiff.


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Through a subpoena issued by Plaintiff’s late attorney,
Brian Stanley, the complete documentation of the real estate
transaction was obtained from the title company (attached hereto as
Exhibit "43"). Among these documents, Plaintiff saw the
Identification Verification and Notary Certification for the first
time (attached hereto as Exhibit "21").
This Closing document clearly identifies four parties involved
in the transaction: Kyle Scott, Richard Murray,
William Phillips, and Mrs. Mihaela Phillips. Plaintiff was not a
party to this Closing and had no knowledge of its existence or any
related details. Defendant colluded with the Title Company to
intentionally conceal the Closing from Plaintiff (attached hereto
as Exhibit "21").

14). Defendant engaged in fraud by providing false notarial
records, which included a date but lacked a specific time,
contained a forged signature, and listed a fictitious notarial
location. Defendant hired a notary to commit perjury. Plaintiff
has never met or contacted the notary hired by Defendant.
The notarial records submitted to the court on behalf of
Defendant are falsified. They lack a specific notarization time, and
the stated notarization location ： 735 Executive Dr, Aurora, IL,
does not exist. A Google Maps search for this address yields no
results, and upon physically driving along Executive Dr in Aurora,
IL, Plaintiff found no such location (attached hereto as Exhibit
"14").


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Furthermore, the Plaintiff’s signature on the notarial
records was forged, as confirmed by multiple handwriting
examinations (attached hereto as Exhibits "8"–"10").

15). On November 2, 2018, Defendant instructed the Title
Company to release $3.05 million to the fraudulent seller :
Adagios which based on fraulent a real estate purchase agreement
on June 12, 2018, with Kyle Scott's company, Endeavor US
for the Arizona Properties at a price of $3.495 million (attached
hereto as Exhibit "1", "16"). In Defendant's instruction letter to the
Title Company, Defendant explicitly stated: "If Title Company does
not release the $3.05 million loan funds to Adagios as instructed by
Defendant, Title Company will not receive any service
fees."(attached hereto as Exhibit "16").
This directive was tied to a fraudent real estate purchase
agreement executed on June 12, 2018, between Adagios and
Kyle Scott’s company, Endeavor US LLC, for the Arizona
Properties at a price of $3.495 million. This agreement served as
the premise and basis for Defendant's loan and its disbursement
(attached hereto as Exhibit "1").
This evidence clearly demonstrates that the instruction to
release the $3.05 million loan funds had no connection to
Plaintiff.

16). On November 6, 2018, Defendant authorized the Title
Company to release $3.05 million in loan funds to the


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fraudulent seller : Adagios which based on fraulent a real estate
purchase agreement on June 12, 2018, with Kyle Scott's
company, Endeavor US for the Arizona Properties at a price of
$3.495 million (attached hereto as Exhibit "1", "17"). This
evidence clearly demonstrates that Defendant's authorization to
release the $3.05 million loan funds had no connection to
Plaintiff.

17).
On the same day (November 6, 2018), Kyle
Scott authorized Title C o m p a n y to wire $198,000 to his
partner Richard Murray a n d Tod Decker as a
" consultation fee" . Tod Decker received $53,540, and
Richard Murray received $144,793.33 (attached hereto
as Exhibit "19" and"20").

18). Defendant has deliberately concealed parts of the
conversation between Plaintiff and Defendant, hiding the fact
such as that Plaintiff was unaware of loan and the interest rate.
Plaintiff declares under penalty of perjury under the laws of the
State of Arizona that Defendant has intentionally concealed parts of the
conversation, thereby creating a false impression that Plaintiff was
aware of the loan terms. Even assuming Plaintiff knew about the
loan, does that mean Plaintiff executed the loan?


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The facts are as follows: On August 28, 2020, after two years of
persistent effort, Kyle Scott finally provided Plaintiff with the
contact information for the bank representative, Mrs. Cristina Fierroz.
The facts are outlined in Exhibit "45".

Defendant clearly acknowledged in correspondence with Plaintiff
that Defendant was obligated to inform Plaintiff about the loan, but
Defendant failed to do so. Defendant’s responses to Plaintiff’s
inquiries included:
• "That’s ok. I apologize for the delay in getting back to you. I
thought you had the information already." [sic]
• "Hi, good morning, can you please tell me what the interest rate
is? Thank you so much!" [sic]
Defendant did not respond.
• "Good afternoon, can we have a meeting next week?" [sic]
Once again, Defendant did not respond and ceased further
communication. (attached hereto as Exhibit "45").
Plaintiff made numerous attempts to communicate with
Defendant, but Defendant intentionally ignored her. How could Plaintiff
have signed a loan agreement, guarantee document, or mortgage


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document in 2018 without knowing the principal or the interest rate?
In fact, what Plaintiff discovered was a blank loan agreement left
behind by Kyle Scott, with the loan amount of $3.05 million
filled in but no interest rate indicated, and the signature section left
blank. Plaintiff repeatedly contacted Defendant to request a meeting
to clarify the situation, but Defendant ignored her.

19). Plaintiff swears under penalty of perjury that until
August 28, 2020, she had never even heard of the name
“Customers Bank,” let alone had any knowledge of the
existence of any so-called loan.
Defendant Customers Bank claims to be a Pennsylvania
corporation. Plaintiff disputes the legitimacy of Defendant’s
status as a Pennsylvania corporation engaged in banking services
in 2018, the period during which Defendant alleges that Plaintiffs
borrowed and guaranteed a loan.
After conducting an official search on Pennsylvania’s
government company registration website, Plaintiff Yang Shao
discovered that three separate entities named “Customers Bank”
are registered in Pennsylvania. These entities are as follows:


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(1). Customers Bank (Entity No. 2572797), a Name
Reservation entity active only from March 25, 1994, to July 23,
1994, and subsequently dissolved;
(2). Customers Bank (Entity No. 3978974), a Fictitious Name
active since September 10, 2010, which lacks the legal authority to
operate as a lending institution;
(3). Customers Bank (Entity No. 4036716), a Domestic
Financial Institution formed on March 29, 2011, which was not
formally recognized as “Customers Bank” until June 10, 2022.
It remains unclear which of these entities is the Defendant in this
case. Without this clarification, Defendant’s allegations cannot be
properly evaluated. (attached hereto as Exhibit “46”)
If the Defendant is the first entity, Customers Bank (Entity No.
2572797), it is inconceivable that Defendant could claim Plaintiffs
borrowed funds in 2018 from an entity dissolved in 1994.
Similarly, if the Defendant is the second entity, Customers Bank
(Entity No. 3978974), which operates under a Fictitious Name, it
does not possess the legal status of a lending institution and thus
could not have lawfully issued any loans. Finally, if the Defendant is
the third entity, Customers Bank (Entity No. 4036716), it did not
legally operate under the name “Customers Bank” until June 10,


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2022. Any actions conducted under the name “Customers Bank”
between 2011 and June 2022 would constitute fraudulent activity,
exploiting the credit of a legitimate bank for improper gain and
carried out under the false pretense of being a lawful financial
institution. Consequently, any actions taken during this period are
invalid. (attached hereto as Exhibit “46”)
Therefore, Plaintiffs respectfully request that the Court
compel Defendant to clarify its legal identity and address these
significant discrepancies.
Defendant’s claim of being Customers Bank, a Pennsylvania
corporation, is highly questionable. As confirmed through
Plaintiff’s search of the Pennsylvania government’s company
registration records, Defendant was not established until March 29,
2011, and did not formally adopt the name “Customers Bank”
until June 10, 2022. Any business activities Defendant conducted
under the name “Customers Bank” before June 10, 2022,
represent fraudulent misuse of a bank’s name and its associated
credit. These actions raise serious doubts about Defendant’s claims
regarding the loan allegedly borrowed and guaranteed by
Plaintiffs in 2018. (attached hereto as Exhibit “46”)


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Plaintiff was unaware of both the so-called principal and
the interest rate. Defendant never provided her any loan documents,
Deed of Trust, guarantee documents, or mortgage documents.
It was not until August 11, 2022—two full years after repeated
requests—that Defendant finally sent Plaintiff the alleged loan,
guarantee, and mortgage documents for the first time (attached
hereto as Exhibit "22"). At this point, almost four years had
passed since the Closing, . On September 19, 2022, through a
subpoena issued by Plaintiff’s late attorney,

Brian

Stanley, the complete documentation of the real estate
transaction was obtained from the title company (attached
hereto as Exhibit "43"). It was only then that Plaintiff had the
opportunity to review these alleged documents. Upon review,
Plaintiff immediately discovered that:
(A). The so-called Purchase-Sale Agreement, loan, guarantee,
Deed of Trust, and mortgage documents contradict each other and
fail to corroborate the transaction:
i. The Closing documents provide conflicting information
regarding the Buyer and Seller:
· According to the Buyer And Seller Information form in the
Closing documents, the Buyer is Kyle Scott, and the Seller is
USS Team Investments III LLC (attached hereto as Exhibit "15").


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· However, the Purchase-Sale Agreement within the Closing
documents identifies the Buyer as Endeavor US LLC, an Arizona
limited liability company, and the Sellers as Adagio House I & II
PLC, Adagio House II LLC, and Adagio House III LLC
(collectively referred to as "Adagios") (attached hereto as Exhibit
"1").
These two critical Closing documents, intended to define the
Buyer and Seller in this transaction, directly contradict one
another, creating irreconcilable conflicts.
ii. The Purchase-Sale Agreement in the Closing documents
identifies the Buyer as Endeavor US LLC, an Arizona limited
liability company (attached hereto as Exhibit "1").
Accordingly, the loan applicant and the issuer of the Deed of
Trust for Defendant’s loan should also be Endeavor US
LLC.
However, the Closing documents list the loan applicant and the
issuer of the Deed of Trust as Endeavor 1 LLC (attached hereto as
Exhibit "18").
These three key Closing documents, which are meant to define
the loan applicant and the issuer of the Deed of Trust as
Plaintiff's company Endeavor 1 lLC , are inconsistent and
irreconcilable.


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Defendant

Document 1

Customers

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Bank's

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Instruction

Letter

for

Disbursement to the Title Company (attached hereto as Exhibit
"16")

and

Defendant

Customers

Bank

Authorization

for

Disbursement (attached hereto as Exhibit "17") clearly identify
the loan recipients (Sellers) as Adagio House II LLC, Adagio
House III LLC, and Adagio House I & II PLC.
However, the Closing Information document (attached hereto
as Exhibit "18") and the Final Closing Statement (attached hereto
as Exhibit "19") show that the loan funds were disbursed to USS
Team Investments III LLC.
These four critical Closing documents, all of which are
supposed to establish the loan recipients, are inconsistent and
contradictory.
iv. The Purchase-Sale Agreement in the Closing documents
specifies the Real Estate Price as $2,250,000 (attached hereto as
Exhibit "1", page 11).
However, the Final Closing Statement in the Closing
documents lists the Real Estate Price as $2,975,000 (attached
hereto as Exhibit "19").
These two critical Closing documents, meant to define the
agreed-upon price for the real estate transaction, are directly
contradictory and cannot be reconciled.


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In summary, the above analysis of the Purchase-Sale
Agreement, loan, guarantee, Deed of Trust, mortgage documents
and closing documents demonstrates that these documents are
riddled with contradictions and fail to corroborate one another.
These inconsistencies serve as clear evidence that the PurchaseSale Agreement, loan, guarantee, Deed of Trust, and mortgage
documents are not genuine.
(B). Identification Verification and Plaintiff’s Exclusion from
the Closing
The Identification Verification and Notary Certification
document in the Closing file (attached hereto as Exhibit "21")
clearly lists four individuals involved in the Closing transaction:
Kyle Scott, Richard Murray, William Phillips, and
Mrs. Mihaela Phillips. Plaintiff was not a participant in this
Closing transaction and had no knowledge of its occurrence.
Defendant, in concert with the Title Company, knowingly
withheld material information regarding this Closing from
Plaintiff. Furthermore, all signatures attributed to Plaintiff on
these documents have been confirmed as forgeries through three
separate rounds of handwriting analysis conducted by expert
examiners (attached hereto as Exhibits "8", "9", "10").


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Upon discovering this, Plaintiff identified the matter as a
case of identity theft and financial fraud. Plaintiff immediately
reported the matter to the State of Illinois, DuPage County, and the
Naperville Police Department (attached hereto as Exhibit "47").
55. Initiation of Investigations into Identity Theft and
Fraudulent Activity
On July 31, 2023, the State of Illinois, DuPage County,
Naperville Police Department, and the Illinois Police Department
Financial Crimes Unit initiated an investigation into the identity
theft case under case number 9023-000602.
On August 1, 2023, Plaintiff reported the matter to the
United States Small Business Administration (SBA), which
initiated a separate investigation and assigned case number ID
0083040002585.
The case is currently under review by the United States Secret
Service (USSS) (attached hereto as Exhibit "47").

56. Defendant’s Unjust Enrichment Totaling $3.4921
Million
Defendant has unjustly enriched itself $3.4921 million through
unauthorized deductions and profits from the auction of


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Plaintiff's Arizona Properties ： Arizona Properties No.1 and
Arizona Properties No. 2.
Between 2018 and 2022, Defendant, in alleged collusion with
Kyle Scott, exploited forged documentation falsely identifying
Kyle Scott's company "Axcent" as the Operating Manager for
Plaintiff Yang Shao's companies Endeavor 1 LLC and Endeavor
AL LLC. Using this falsified authority, Kyle Scott opened
bank accounts for Endeavor 1 LLC and Endeavor AL LLC at Bank
of America (BOA) in the state of Arizona, designating only
himself and his wife, Mrs. Maxime Scott, as account signers
(attached hereto as Exhibit "48"). These accounts were then used
to initiate unauthorized monthly automatic deductions purportedly
as repayments for the fraudulent loan. Despite Plaintiff’s
repeated objections, Defendant refused to halt these deductions,
ultimately withdrawing approximately $1.2 million the benefits
and profits from Plaintiff's properties AZ Property No. 1 and AZ
Property No. 2. from Plaintiff’s account without authorization.
Plaintiff, nearing the age of 60, invested almost her entire life
savings of $698,475—earned through decades of hard work—to
purchase AZ Property No. 1 and AZ Property No. 2. However, all
the benefits and profits from Plaintiff's properties were
completely taken by Defendant and Kyle Scott through their
collusion. Since making the final payment for the properties on
December 31, 2018, Plaintiff has not received a single dollar in
return. Her life, along with that of her school-aged son, who relied
on her support, fell into extreme hardship. Plaintiff was forced to
work as a janitor to provide for herself and her son, often sleeping
in abandoned restrooms to survive.


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In desperation, Plaintiff traveled multiple times to Arizona to
demand Deed of AZ Property No. 1 and AZ Property No. 2 from
Kyle Scott, only to be met with hostility and ultimately thrown
out of his office. Despite Plaintiff’s repeated efforts, Kyle
Scott disclosed the existence of Defendant's loan for the first time on
August 2020. Plaintiff swears that It was not until August 2020
that Kyle Scott informed Plaintiff for the first time about a
supposed loan with a bank called Customers Bank, alleging that
Plaintiff owed $3.05 million.
This shocking revelation caused Plaintiff severe mental
anguish, triggering a relapse of her hereditary depression. On
multiple occasions, she attempted suicide but was fortunately
saved by her son, who intervened in time. Plaintiff was rushed to
the hospital for emergency treatment and later transferred to a
psychiatric hospital in Illinois for further care. Although Plaintiff
was educated in China, she has been unable to work in the United
States due to her limited English proficiency and a hereditary
mental illness. Prior to immigrating, Plaintiff had suffered from
this mental illness for over 10 years and had been receiving
treatment at a psychiatric hospital in Shanghai. Since arriving in
the U.S., Plaintiff has not been employed, remaining at home in
Illinois to care for household duties and transport her son to and
from school. She continues to receive psychiatric medication and
has undergone inpatient treatment at Dupage County Hospital in


Case 2:25-cv-02640-KSM

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For this reason, Maricopa County in Illinois once

appointed a government official as a guardian for the Plaintiff，
Plaintiff was under the guardianship of the Dupage County
Public Guardian. (Exhibit “49”). However, due to the severity
of the Plaintiff's condition, the Plaintiff was forced to return to
China in 2023 to undergo nearly a year of psychiatric treatment
(Exhibit “50”). The Plaintiff was compelled to terminate the
bankruptcy case filed on July 9, 2023, in the Northern District of
Illinois Bankruptcy Court against Customers Bank （ Exhibit
“51).

As Kyle Scott and Mrs. Maxime Scott were the sole
signers on the Endeavor 1 LLC and Endeavor AL LLC bank
accounts, they alone controlled the accounts and executed all
purported loan repayment transactions. This further confirms that
the actual borrower of the $3.05 million loan was Kyle Scott,
not Plaintiff Yang Shao or her companies Endeavor 1 LLC and
Endeavor AL LLC . Between 2018 and 2022, as sole signers of the
Endeavor 1 LLC and Endeavor AL LLC bank accounts in,
Kyle Scott and Mrs. Maxime Scott enabled Defendant to execute
unauthorized monthly deductions amounting to $1.2 million in
fraudulent withdrawals. Despite Plaintiff's protests these
deductions continued unchecked. Plaintiff Yang Shao or her
companies Endeavor 1 LLC and Endeavor AL LLC never entered
the phurchase of AZ properties at the price of $ 3.493 million, nor
did they borrow $3.05 million from Defendant for phurchase of AZ


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74 of 88 or
properties
at the price of $Document
3.493 million,
did they
establish
authorize the creation of any bank accounts for Endeavor 1 LLC or
Endeavor AL LLC in the state of Arizona, nor did Plaintiff
and her companies Endeavor 1 LLC or Endeavor AL
LLC acknowledge or repaid any loan in connection with these
accounts.

In 2023, Defendant further profited by forcibly auctioning the
Arizona Properties (AZ Property No. 1, AZ Property No. 2, and
AZ Property No. 3) for $ 3.3135 million, including AZ Property
No. 1 and AZ Property No. 2 for $ 2.2491 million which
Plaintiff had fully purchased using $698,475 from her own
funds. The auction generated Defendant a profit of $3.3135 million,
severely infringing upon Plaintiff’s property ownership rights.
(Attached here as to Exhibit “52”- Exhibit “53”).
The plaintiff has established that notary Tamara Thompson colluded
with defendant Customers Bank on April 2, 2021, and May 25, 2021, to
fraudulently obtain duplicate PPP loans through a non-existent entity,
with the total amount exceeding $20,000 (Exhibit 68). Of critical
significance: the purported corporate borrower lacked legal standing at
the time of loan disbursement, as its formal incorporation was
recorded 11 months post-funding (Exhibit 69), creating an 11-month
gap of unsubstantiated financial transactions. This material temporal
inconsistency demonstrates a potentially illicit financial scheme between
Thompson and Customers Bank, thereby irreparably compromising the
validity of her 2018 notarizations performed for the defendant.
In total, Defendant has unjustly enriched itself by approximately
$3.4921 million through its unauthorized actions, including
fraudulent deductions $1.2 M and profits $2.2921 million from the
forced auction of Plaintiff's Arizona Properties: AZ Property No.
1, AZ Property No. 2.
CONCLUSION

57. Plaintiff who has at all times been the sole
individual to fully purchase, with her own
funds, the properties at issue in this case—AZ Property
No. 1 (4839 E Charleston, Scottsdale, AZ) and AZ


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Property No. 2 (5328 E Anderson Dr, Scottsdale, AZ).
On December 31, 2018, Plaintiff paid the full
purchase price of $698,475.12 in cash to the previous
owner, USS Team Investments III LLC, thereby
obtaining the complete and exclusive ownership rights
to AZ Property No. 1 and AZ Property No. 2.
As the genuine, rightful, sole, and 100% owner
of AZ Property No. 1 and AZ Property No. 2, and with
no other person or entity having ever contributed a
single cent toward the purchase of these properties, no
person or entity other than Plaintiff Yang Shao has
any legitimate claim to being the rightful owner of AZ
Property No. 1 and AZ Property No. 2, nor can anyone
challenge Plaintiff Yang Shao’s exclusive and lawful
ownership of these properties.
Defendant, through fraudulent means, sought to
recover a $3.05 million loan it had erroneously
disbursed to Plaintiff’s previous owner, USS Team
Investments III LLC. These fraudulent actions included
fabricating a real estate purchase agreement, a
fraudulent loan agreement, a fraudulent Deed of Trust,
a fraudulent guarantee agreement, forging Plaintiff’s
signature, fabricating real estate valuations, and
deceiving the Small Business Administration (SBA).
Despite there being no legitimate purchase agreement


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involving Plaintiff or her company for the Arizona
real estate at $3.495 million, Defendant falsely accused
Plaintiff before this Honorable Court on January 17,
2023. Defendant claimed Plaintiff had borrowed $3.05
million under her company’s name to purchase the
Arizona real estate, instead of pursuing USS Team
Investments III LLC, which was the actual loan
recipient.
On October 24, 2023, Defendant unlawfully forced
the auction of AZ Property No. 1 and AZ Property No.
2, which Plaintiff had fully purchased on December
31, 2018, with $698,475.12 in cash. These actions
resulted in the illegal seizure of Plaintiff’s two
Arizona properties, leading to Defendant’s unjust
enrichment amounting to $3.4921 million, significant
financial harm to Plaintiff, and severe damage to her
mental health, exacerbating her hereditary panic
disorder.
Under Arizona criminal law, Plaintiff Yang
Shao, under oath, declares that she has never
participated in the fraudulent real estate purchase
agreement at the heart of this case, nor in the resulting
fraudulent loan agreement, Deed of Trust, or guarantee
agreement.


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58. Plaintiff is a Victim of Financial Fraud, Identity Theft, and
Forgery.
Plaintiff Yang Shao has been subjected to a series of fraudulent
activities, identity theft, and forgery orchestrated by Defendant Customers
Bank and its internal collaborators, including Karl Danielian (Senior Vice
President of the Defendant) and Kyle Scott. Between 2018 and 2023, these
parties engaged in fraudulent schemes with the aim of generating illicit
profit.
1). Defendant Customers Bank initially relied on false $3.495
million Arizona real estate purchase agreements (attached
hereto as Exhibit "1" and "2") without proper verification.
Subsequently, Defendant, for financial gain, employed forged
documents and deceptive methods, falsified property appraisals,
and fabricated Plaintiff’s involvement in fraudulent loan
agreements and guarantees. These fraudulent actions were
designed to secure SBA approval for a $3.05 million loan and
related guarantees.

2). As a direct result of these fraudulent schemes, Defendant
unjustly deprived Plaintiff's Arizona real estate ( AZ property
No. 1 and AZ property No. 2) valued at $2.2921 million and net
profits of $1.2 million generated by those properties, resulting in unjust
enrichment totaling $3.4921 million. Furthermore, Defendant’s
actions caused significant financial harm and severe damage to
Plaintiff’s mental and severe damage to Plaintiff’s mental health,
exacerbating her hereditary panic disorder.


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3). Defendant’s fraudulent conduct includes, but is not
limited to:
· Relying on false $3.495 million Arizona real estate
purchase agreements from the beginning : Defendant relied on
fraudulent Arizona real estate purchase agreements, such as those
involving Adagio Houses as sellers—entities that were not the
rightful owners of the Arizona Properties listed in the agreements.
The fraudulent agreements were executed between Kyle
Scott’s company, Endeavor US LLC, and the fictitious entities,
Adagio Houses. These agreements have no connection to
Plaintiff Yang Shao or her companies, Endeavor 1 LLC and
Endeavor AL LLC (attached hereto as Exhibit "1" and "2").
· To generate profit, Defendant fabricated a Loan
Commitment Letter: Defendant fabricated a loan commitment letter
to initiate the fraudulent scheme (attached hereto as Exhibit "3").
· To generate profit, the Defendant fabricated fraudulent
loan agreements involving the Plaintiff's companies,
Endeavor 1 LLC and Endeavor AL LLC, for a fictitious $3.05
million loan. It is well-established that real estate purchase
agreements are the prerequisite and foundation for loan
agreements. However, the Plaintiff’s companies, Endeavor 1
LLC and Endeavor AL LLC, have never entered into any $3.495
million Arizona real estate purchase agreements with any
individual or entity.


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The Defendant’s allegation that Endeavor 1 LLC and Endeavor
AL LLC borrowed $3.05 million from the Defendant to purchase
$3.495 million worth of Arizona real estate is entirely baseless,
lacking any factual foundation or credible source (attached hereto
as Exhibits "1" and "2").

Furthermore, the Defendant created fraudulent loan documents,
including, but not limited to, a Note containing inconsistencies
across multiple versions (attached hereto as Exhibits "4"–"5"), as
confirmed by expert analyses (attached hereto as Exhibits "8"–
"10").

· To generate profit, Defendant created Fraudulent
Guarantee Documents. To generate profit, the Defendant created
fraudulent guarantee documents. These include, but are not limited
to, mortgage documents with inconsistencies across multiple
versions (attached hereto as Exhibits "6"and "7"), as confirmed
by expert analyses (attached hereto as Exhibits "8"–"10").

· To generate profit, the Defendant inflated the 2018
appraised value of the Arizona Properties to $3.09 million,
despite their actual market value being under $1.5837 million.
The Defendant falsified these appraisals to secure SBA approval for
a $3.05 million loan and related guarantees (attached hereto as
Exhibits "11" and "12"). Defendant’s overvaluation of the
Arizona Properties—falsely appraising them at $3.09 million in
2018 while their actual market value was less than $1.5837 million


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(attached hereto as Exhibits "11," Pages 20/6a, 6b, 6c, and
Exhibit "12")—misrepresented their true worth and deceived the
SBA into approving the loan.
· To generate profit, the Defendant forged the Plaintiff's
signature: Defendant forged the Plaintiff's signature on the SBA
7(a) Borrower
Information
Form –
Representations,
Authorizations, and Certifications (attached hereto as Exhibit
"13," Page 2, and Page 6).
Plaintiff's signature on Exhibit "13," Page 2, appears on the
SBA 7(a) Borrower Information Form dated August 29, 2018.
However, the same signature also appears on Exhibit "13," Page
6, which is a sales contract for a piece of land sold by the
Plaintiff in Naperville, Illinois, dated July 3, 2017. These
signatures on Exhibit "13," Page 2 and Page 6, are identical.
It is impossible for the Plaintiff to have signed the same
signature on two entirely different documents, one dated July 3,
2017, and the other over a year later on August 29, 2018, as it is
not feasible for a person to produce two identical signatures on
separate occasions. The Plaintiff's signature on Exhibit "13,"
Page 2, was clearly copied from the Plaintiff's signature on
Exhibit "13," Page 6, and was unlawfully copy, cut and pasted by
Defendant onto the SBA 7(a) Borrower Information Form.
This forged signature on the SBA 7(a) Borrower Information
Form dated August 29, 2018, was fabricated by the Defendant
through illegal means to deceive the SBA and falsely implicate the


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Plaintiff as a guarantor for the fictitious $3.05 million loan
(attached hereto as Exhibit "13" Page 2, and Page 6).
· To generate Profit, Defendant Falsified Notarial Records
The notarial records submitted to the court are falsified.
Plaintiff, under penalty of perjury pursuant to Arizona criminal
law, affirms that prior to July 19, 2023, they had never met the
notary in question nor had any interactions with them. The records
lack a specific notarization time, and the stated notarization
location, "735 Executive Dr, Aurora, IL," does not exist. A
Google Maps search for this address yielded no results, and
Plaintiff personally drove along Executive Dr in Aurora, IL, but
found no such location (attached here to as Exhibit
"14"). Furthermore, multiple handwriting examinations confirmed
that Plaintiff's signature on the notarial records was forged
(attached hereto as Exhibits "8"–"10").

· To generate profit, Defendant withheld Critical
Information:
Defendant intentionally withheld critical documents
and information, including but not limited to: the SBA Loan
Authorization, loan-related details, guarantee-related details, and
failed to disclose key discrepancies in the Closing documents.
These discrepancies include contradictions in the identities of the
buyer, seller, and loan applicant, among others (attached hereto as
Exhibits "1", "2", "3", "4", "5", "6", "7", "11", "12", "13",
"14", "15", "16", "17", "18", "19", "20", "21", "22").


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59. The Defendant failed to perform its duty of due diligence
by neglecting to verify the authenticity of the loan documents,
the Deed of Trust, and guarantees. The Defendant neither
confirmed the Plaintiff's identity nor obtained her explicit
consent for the transactions in question. Furthermore, the Defendant
did not inform the Plaintiff about the loans, guarantees, Deed of
Trust, or mortgage-related matters until four years after the
closing, on August 11, 2022, for the first time (attached hereto as
Exhibits "22").

60. The Defendant’s actions constitute gross negligence,
fraud, and breach of fiduciary duty. The Defendant knowingly
engaged in fraudulent activities, including relying on false
purchase agreements, such as those involving the Adagio House
entities as sellers, who were not the actual owners of the properties
listed in the sales contracts (attached hereto as Exhibits "1" and
"2"). This fraudulent purchase agreement was entirely unknown to
Plaintiff Yang Shao and her companies, Endeavor 1 LLC and
Endeavor AL LLC. Furthermore, neither Plaintiff Yang Shao nor
her companies were involved in or consented to this purchase
agreement. They have no connection whatsoever to the agreement
or the fraudulent transactions arising from it.

61. The Plaintiff has suffered substantial financial losses
and emotional distress directly caused by the Defendant’s
actions. The Defendant has unjustly enriched itself by approximately
$3.4921 million through unauthorized deductions and profits from


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the auction of the Plaintiff’s Arizona Properties (Arizona
Property No. 1 and Arizona Property No. 2).

· Unauthorized monthly deductions from the output of
Plaintiff’s Arizona Properties (Arizona Property No. 1 and
No. 2), totaling $1.2 million between 2018 and 2022.
· Illegally and forcibly auctioning Plaintiff’s Arizona
Properties (Arizona Property No. 1 and No. 2) in 2023, from
which the Defendant improperly profited $2.2921 million.
· Irreparable harm to the Plaintiff’s mental health, as well
as personal and professional reputation, compounded by ongoing
legal battles and foreclosure risks.

62. The Plaintiff seeks compensatory and punitive
damages, as well as any other relief the Court deems
appropriate. The Defendant’s egregious conduct warrants
severe
penalties to deter similar fraudulent activities in the future.
63. The Plaintiff requests the Court to order the judicial
authorities to initiate a comprehensive investigation into the
Defendant’s past loan operations and auction of mortgaged
properties, in order to protect vulnerable consumers who have
had similar harmful experiences as the Plaintiff.

EVIDENTIARY BASIS


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64. Fraudulent misrepresentation through fabricated
documents and forged signatures (attached hereto as Exhibit
"8", "9","10","13", "23" ).
.
65. Failure to perform basic due diligence, such as verifying
county land records (attached hereto as Exhibits "1", "2", "3",
"4", "5", "6", "7", "11", "12", "13", "14", "15", "16", "17",
"18", "19", "20", "21", "22").
66. Gross overvaluation of collateral to deceive the SBA to
secure fraudulent loan approval (attached hereto as Exhibit
"11" and "12").

67. Unauthorized use of the Plaintiff’s personal
information and forged signatures, as confirmed by expert
analysis (attached hereto as Exhibit "8", "9","10","13", "23" ).
68. The Plaintiff respectfully pleas that the Court
recognize the Defendant's gross misconduct, hold the Defendant
accountable, and grant relief commensurate with the financial
and emotional harm suffered by the Plaintiff.

Legal Basis


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69. Fifth Amendment to the United States Constitution**
The Fifth Amendment protects Plaintiff’s private property
rights by ensuring that no person shall “be deprived of life,
liberty, or property, without due process of law; nor shall private
property be taken for public use, without just compensation.”
Defendant’s actions unlawfully deprived Plaintiff of her property
without due process and without any compensation.

70. Fourteenth Amendment to the United States Constitution**
The Fourteenth Amendment ment extends the Fifth Amendment ’s
protections to state actions, ensuring that “no state shall deprive
any person of life, liberty, or property, without due process of law;
nor deny to any person within its jurisdiction the equal protection
of the laws.” , Defendant’s actions, facilitated by the Title
Company’s errors, violated these constitutional protections.

71. Arizona State Constitution**
Pennsylvania’s Constitution further safeguards private property
rights and ensures that any deprivation of property follows strict
legal procedures and compensatory measures.

72. Related Protections


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The constitutional guarantees against unlawful seizures and the
protections of private property in the Third ment indirectly
reinforce Plaintiff’s rights to maintain exclusive ownership of
her lawfully purchased properties.

CLAIMS FOR RELIEF

73. Monetary Damages:
The Plaintiff respectfully pleas that the Court award:
· Compensatory Damages: To compensate the Plaintiff for
financial and emotional losses caused by the Defendant's actions,
in
an amount to be determined at trial.
· Punitive Damages: To punish the Defendant for egregious and
fraudulent conduct and to deter similar behavior in the future.

74. Declaratory Relief:
The Plaintiff prays that the Court declare the Defendant's
actions, including the fraudulent loan, guarantee, and mortgage
agreements, as illegal, void, or unenforceable under applicable law.

75. Injunctive Relief:
The Plaintiff requests that the Court issue an injunction to:


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· Prevent the Defendant from enforcing the fraudulent loan,
guarantee, and mortgage agreements.
· Halt any ongoing or future collection actions related to these
fraudulent agreements.

76. Attorney's Fees and Costs:
The Plaintiff respectfully requests the Court to award
reasonable attorney's fees and costs incurred in defending against
the Defendant's claims and pursuing this complaint.

77. Plaintiff respectfully requests that the Honorable
Court to issue an Order initiating a regulatory investigation
into all of Defendant's loan and auction transactions
since its inception. This investigation aims to assist
vulnerable individuals who, like the Plaintiff, have suffered
harm due to Defendant's fraudulent practices.

78. Other Relief:
The Plaintiff prays for any additional relief the Court may
deem just and proper under the circumstances.

Attachment: Compliance Issues Regarding Defendant


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RESPECTFULLY SUBMITTED this 22 day May, 2025.
/s/ Yang Shao
YANG SHAO
YANG SHAO

524 E 14TH AVE
NAPERVILLE IL
60563
shaoyang_suny@163.com
Defendant

ORIGINAL of the foregoing e-filed
this 22 day of May, 2025, with:
Clerk of the Court–United States District Court for the Eastern District of Pennsylvania

/s/ Yang Shao
YANG SHAO

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