Plaintiff's Amended Complaint — Shao v. Customers Bancorp, Inc. (E.D. Pa., July 15, 2025)
Summary
A pleading titled Plaintiff's Amended Complaint in Opposition to Defendant's Motion to Dismiss, filed by Yang Shao in Shao v. Customers Bancorp, Inc., Case No. 25-cv-02640, in the Eastern District of Pennsylvania, Document 13, filed July 15, 2025. The caption names Customers Bank, Jay Sidhu and Sam Sidhu among the defendants. The plaintiff alleges that a $3.05 million loan was erroneously disbursed and that forged documents were used, resulting in the auction of two properties. The listed claims include federal fraud against the U.S. Small Business Administration, RICO violations under 18 U.S.C. § 1962(c), conversion and unjust enrichment, and the relief requested includes treble damages under 18 U.S.C. § 1964(c), rescission of the loans and a constructive trust over auction proceeds.
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“Plaintiff's Amended Complaint — Shao v. Customers Bancorp, Inc. (E.D. Pa., July 15, 2025).”
Original at ecf.paed.uscourts.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/amended-complaint-shao-v-customers-bancorp-dkt-13-e-d-pa-27ae4a8d70/
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Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 1 of 78
YANG SHAO
524 E 14TH AVE NAPERVILLE
IL 60563
shaoyang_suny@163.com
Defendant
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF PENNSYLVANIA
Yang Shao
Case Number：25-cv-02640
Plaintiff,
vs.
Customers Bancorp, Inc.
Publicly traded holding company (NASDAQ: CUBI)
Address: 701 Reading Avenue, West Reading, PA 19611
PLAINTIFF'S AMENDED
Customers Bank COMPLAINT IN OPPOSITION
Pennsylvania-chartered bank, wholly owned subsidiary of
Customers Bancorp TO DEFENDANT'S MOTION TO
Address: 701 Reading Avenue, West Reading, PA 19611 DISMISS (BASED ON NEWLY
DISCOVERED EVIDENCE OF
Jay Sidhu
Chairman of Customers Bancorp and Executive Chairman of
FORGED DOCUMENTS AND
Customers Bank FABRICATED RECORDATION
Address: 701 Reading Avenue, West Reading, PA 19611 STAMPS IN INTERSTATE
FRAUD SCHEME)
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
Jury Trial Demanded
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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 2 of 78
PLAINTIFF'S AMENDED COMPLAINT IN OPPOSITION TO
DEFENDANT'S MOTION TO DISMISS (BASED ON NEWLY
DISCOVERED EVIDENCE OF FORGED DOCUMENTS AND
FABRICATED RECORDATION STAMPS IN INTERSTATE
FRAUD SCHEME)
AMENDED COMPLAINT FOR:
• Federal Fraud Against the U.S. Small Business Administration
(18 U.S.C. § 1001);
• Wire Fraud and Bank Fraud Conspiracy
(18 U.S.C. §§ 1343, 1344);
• Multi-State Forgery of Loan Documents
(California, Illinois, Arizona);
• Fraudulent Use of Forged Notarial Records to Facilitate SBA
Scheme;
• Illegal Foreclosure Executed Through Predicate Acts Under the
RICO Statute
(Including PPP Loan Fraud);
• Violations of the Racketeer Influenced and Corrupt Organizations
Act (RICO)
(18 U.S.C. § 1962(c)) — Pattern of SBA-Related Fraud in 2021 &
2023;
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 3 of 78
• Conversion of Plaintiff’s Real Property (Two Parcels);
• Unjust Enrichment Through Misappropriation of Federal Funds;
DEMAND FOR JURY TRIAL
I. Background
1. On October 24, 2023, to conceal a $3.05 million loan erroneously
disbursed due to the Defendant’s error stemming from a fraudulent real
estate purchase contract, the Defendant exploited the Plaintiff—a new
immigrant with limited English proficiency suffering from hereditary
depression. During a closing conducted without the Plaintiff’s knowledge
or presence, the Defendant colluded with a notary public with whom they
maintained a long-standing illicit benefits relationship (who had previously
conspired with the Defendant in 2021 to fraudulently obtain two SBA PPP
loans). Together, they fabricated real estate valuations to deceive the Small
Business Administration (SBA), forged the Plaintiff’s signature, and
illicitly affixed the seal of the Maricopa County Recorder’s Office in
Arizona to produce two fraudulent Deeds of Trust.
2. Furthermore, they forged the following documents across California,
Illinois, and Arizona:
• False commitment letters
• Loan Agreements
• Promissory Notes
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 4 of 78
• Deeds of Trust
• Mortgages
• Assignments of Leases and Rents
• Unconditional Guarantees
• Risk Disclosure Statements
• Customer Identification Forms
• Identity Affidavits
• Signing Affidavits
• Notarial journals
These actions ultimately resulted in the illegal auction of the Plaintiff’s two
properties. (Exhibits 1 through 24)
3. 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, Plaintiff 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 5 of 78
or entity other than Plaintiff has any legitimate claim to being the rightful
owner of AZ Property No. 1 and AZ Property No. 2, nor can anyone
challenge Plaintiff ’s exclusive and lawful ownership of these properties.
Defendant, colluding with a notary public (who had previously conspired
with the defendant in 2021 to fraudulently obtain two SBA PPP loans)
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
fraudulent loan agreement, a fraudulent Deed of Trust, Mortgage,
Assignment of Leases and Rents, Notes, Risk Disclosure Statement,
the customer identification form, Identity Affidavit, Signing Affidavit,
and notary journal, by forging Plaintiff’s signature, fabricating real estate
valuations, and deceiving the Small Business Administration (SBA).
Despite there being no legitimate purchase agreement 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. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 6 of 78
Plaintiff, and severe damage to her mental health, exacerbating her
hereditary panic disorder. Under Pennsylvania criminal law, Plaintiff 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.
II. Legal Basis for Complaint
4. Violation of the Racketeer Influenced and Corrupt Organizations Act
(RICO), 18 U.S.C. § 1962(c)
The Defendants formed an unlawful "enterprise" comprising lenders,
notaries, and title companies, and engaged in a pattern of racketeering
activity through this structure:
• Predicate Act I: 2021 SBA PPP Loan Fraud (under 18 U.S.C. § 1344);
• Predicate Act II: 2023 Interstate Forgery of Loan and Notarization
Documents (under 18 U.S.C. §§ 1341, 1343).
This "enterprise" repeatedly committed fraud using interstate means and
financial institutions, constituting a "pattern of racketeering activity" as
defined by RICO. The Defendants and their conspiring notaries
participated in two SBA PPP loan frauds in 2021 and again forged loan
documents and notarized materials in 2023 through the same network to
effectuate unlawful foreclosures. This establishes a continuous pattern of
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 7 of 78
fraudulent activity, satisfying RICO's "pattern of racketeering activity"
requirement under 18 U.S.C. § 1962(c).
5. Violations of 18 U.S.C. § 1341 (Mail Fraud) and § 1343 (Wire Fraud)
Defendants created and submitted fraudulent mortgage documents in
Illinois and Arizona (see Exhibits 9, 11) as part of a scheme to unlawfully
foreclose on Plaintiff's real property.
• Violation of § 1341 (Mail Fraud): Defendants fabricated false loan
agreements, notes, security instruments, mortgages, and related risk
disclosure documents in California, Illinois, and Arizona. They used the
U.S. Postal Service to mail forged title documents and auction notices,
resulting in the illegal auction of Plaintiff's Arizona property (October 24,
2023) and attempting to auction Plaintiff's third property in Illinois.
• Violation of § 1343 (Wire Fraud): Defendants fabricated false loan
agreements, notes, security instruments, mortgages, and related risk
disclosure documents in California, Illinois, and Arizona. They transmitted
fraudulent loan materials via email or electronic platforms to effectuate the
illegal auction of Plaintiff's Arizona property (October 24, 2023) and
attempting to auction Plaintiff's third property in Illinois.
6. 18 U.S.C. § 1344 (Bank Fraud)
Defendants executed a scheme to defraud the banking system and the Small
Business Administration (SBA) by creating false bank loan documents,
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 8 of 78
identity verification materials, and notarization records. This was done to
fraudulently obtain secured interests in and rights to execute upon
Plaintiff's property, satisfying the elements of bank fraud under 18 U.S.C.
§ 1344.
7. 18 U.S.C. § 1001 (False Statements to a Federal Agency)
Defendants knowingly made false statements and submitted forged
documents to the U.S. Small Business Administration (SBA), defrauding
a federal agency:
• Submitted forged loan agreements (see Exhibits 1–7) and fraudulently
notarized affidavits (see Exhibits 8–12) to obtain SBA-guaranteed loans;
• Knowingly concealed the 2021 SBA PPP Loan Fraud as Predicate Act I
(see Exhibit 15).
8. Violation of the Fifth Amendment to the U.S. Constitution (Unlawful
Taking)
Defendants deprived Plaintiff of ownership rights to two properties without
due process or just compensation, in direct violation of the Fifth
Amendment guarantee:
"...nor shall private property be taken for public use, without just
compensation."
• Factual Nexus: Plaintiff received $0 from the auction proceeds, and the
property proceeds were used to repay loans fraudulently obtained through
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 9 of 78
SBA fraud.
Defendants deprived Plaintiff of property without due process of law and
failed to provide any compensation, severely violating Plaintiff's
fundamental rights under the U.S. Constitution.
9. Violation of the Fourteenth Amendment to the U.S. Constitution (State-
Action Deprivation)
Defendants conspired with licensed Title Companies to:
• Bypass lawful judicial foreclosure proceedings;
• Deprive Plaintiff of notice and hearing opportunities.
"[N]or shall any State deprive any person of...property, without due process
of law..."
These actions constitute a deprivation of constitutional property rights
under color of state law. During the foreclosure processes in Illinois and
Arizona, Defendants acted with the cooperation of local Title Companies,
severely violating Plaintiff's rights to due process and equal protection.
10. Related Constitutional Protections
While the Third Amendment to the U.S. Constitution primarily prohibits
the quartering of soldiers in private homes during peacetime, its underlying
spirit protecting property rights also indirectly supports Plaintiff's right to
maintain exclusive ownership of lawfully acquired real property. The
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 10 of 78
illegal seizure of property constitutes a violation of this constitutional
principle.
11. Violation of Article I, Section 1 of the Pennsylvania Constitution
(Property Rights)
"All men...have certain inherent and indefeasible rights, among which are
those of...acquiring, possessing and protecting property..."
The forcible taking of assets without legal process constitutes a severe
infringement. As the state of incorporation for the involved entities, the
Pennsylvania Constitution explicitly requires that any deprivation of
private property must occur through due process and with just
compensation. Defendants, operating through corporate entities, engaged
in unlawful property conversion tactics, violating fundamental state
constitutional law.
12. Unlawful Conversion of Real Property (Common Law Tort)
Defendants unlawfully auctioned and seized Plaintiff's real property
located in three states: California, Arizona, and Illinois.
III. Relief Sought
13.Constitutional Remedies
a) Award damages for violations of the Fifth Amendment to the U.S.
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 11 of 78
Constitution ($[amount] per property);
b) Order restitution for Fourteenth Amendment violations pursuant to
42 U.S.C. § 1983.
14.RICO Treble Damages (18 U.S.C. § 1964(c))
Award treble damages against Defendants under 18 U.S.C. § 1964(c)
(RICO civil remedies provision) for engaging in a pattern of
racketeering activity involving SBA fraud and document forgery from
2021 to 2023.
15.Constitutional Tort Damages
Award constitutional tort damages against Defendants for the unlawful
deprivation of Plaintiff’s property without due process under the Fifth
and Fourteenth Amendments.
16.Rescission of Fraudulent Loans
Order the SBA to rescind all fraudulent loans.
17.Punitive Sanctions
a) Statutory penalties:
·Mail/wire fraud (18 U.S.C. §§ 1341, 1343)
·SBA fraud (18 U.S.C. § 1001): $[amount]
b) Revocation of the involved notary public’s commission.
18.Equitable Relief
a) Impose a constructive trust over auction proceeds;
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 12 of 78
b) Order Defendants to submit a full audited accounting of all
fraudulently obtained SBA funds.
IV. PARTIES
19. 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.
20.Jay S. Sidhu, an individual and senior executive of Customers Bancorp;
21.Sam Sidhu, an individual and executive of Customers Bancorp;
22. Karl Danielian, an individual and Senior Vice President of Customers
Bank;
23.Rosemary Dente, an individual and employee of Customers
Bank;
24. Tamara R. Thompson, an individual notary public,
25. 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,
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 13 of 78
Plaintiff Yang Shao has been the sole owner of AZ Property No.1 and AZ
Property No.2.
26. AZ Properties: AZ Property No.1, AZ Property No.2 and AZ Property
No.3.
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).
27. USS Team Investments III LLC (" USS Team" or "Seller " ) i s an
Arizona limited liability company conducting business in Maricopa county.
At all relevant times, was the seller of the AZ Properties AZ Property No.1
and AZ Property No.2. On December 31, 2018, USS Team Investments III
LLC sold AZ Properties: AZ Property No.1 and AZ Property No.2 to
Plaintiff.
28. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 14 of 78
August 3, 2017, and falsely designated his company, “Axcent,” as the
operating manager of these Plaintiff’s entities. Using this 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.
29. 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 ".
30.Maxime Scott is an individual who previously resided in Illinois and
currently resides in Arizona.
31. Axcent LLC ("Axcent") is a Florida limited liability company
conducting business in Florida. At all relevant times, Axcent was a foreign
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 15 of 78
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".
32. 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.
33. 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.
34. Richard Murray is an individual residing in Arizona.At all relevant
times, was and continus to be Kyle Scott's partner.
35. Tod Decker is an individual at all relevant times, was and continus to
be Kyle Scott's partner.
36. Alliant National Title Insurance Company （ "Alliant Title" or "
Title company" ), a Colorado limited liability company conducting
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 16 of 78
business in Colorado. At all relevant times. Alliant Title was the title
company responsible for handing the closing of the AZ Properties.
37. Driggs Title Agency Company ( "Driggs Agency" or "TitleAgency" ),
a limited liability company conducting business in Arizona. at all relevant
times, Driggs Agency was the titleagency company handing the closing of
the AZ Properties.
V．VENUE
38. 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;
c. The planning, approval, and oversight of the transaction occurred at
Defendants’ headquarters in Pennsylvania.
VI．DISCOVERY TIER
39. 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.
VII．ALLEGATIONS COMMON TO ALL COUNTS
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 17 of 78
40. Plaintiff Yang Shao is a Victim of Defendant's Financial. On October
24, 2023, to conceal a $3.05 million loan erroneously disbursed due to the
Defendant’s error stemming from a fraudulent real estate purchase contract,
the Defendant exploited the Plaintiff—a new immigrant with limited
English proficiency suffering from hereditary depression. During a closing
conducted without the Plaintiff’s knowledge or presence, the Defendant
colluded with a notary public with whom they maintained a long-standing
illicit benefits relationship (who had previously conspired with the
Defendant in 2021 to fraudulently obtain two SBA PPP loans). Defendant
fabricated real estate valuations to deceive the Small Business
Administration (SBA), forged the Plaintiff’s signature, and illicitly affixed
the seal of the Maricopa County Recorder’s Office in Arizona to produce
two fraudulent Deeds of Trust.
41. Furthermore, they forged the following documents across California,
Illinois, and Arizona:
• False commitment letters
• Loan Agreements
• Promissory Notes
• Deeds of Trust
• Mortgages
• Assignments of Leases and Rents
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 18 of 78
• Unconditional Guarantees
• Risk Disclosure Statements
• Customer Identification Forms
• Identity Affidavits
• Signing Affidavits
• Notarial journals
These actions ultimately resulted in the illegal auction of the Plaintiff’s two
properties.
42. 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. Furthermore, Defendant’s actions caused significant
financial harm and severe damage to Plaintiff’s mental health, exacerbating
her hereditary panic disorder.
·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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 19 of 78
Scott’s company, Endeavor US LLC, and the fictitious owner, Adagio
Houses. These agreements had no connection to Plaintiff Yang Shao or her
companies, Endeavor 1 LLC and Endeavor AL LLC.
·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 is 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.
·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. The actual purchaser of the Arizona real
estate was Endeavor US LLC . All forged signatures purporting to be the
Plaintiff's have been confirmed by expert analyses.
·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. Defendant’s
overvaluation of the Arizona Properties, falsely appraising them at $3.09
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 20 of 78
million in 2018 while their actual market value was less than $1.5837
million, 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.
·Plaintiff's signature appears on the SBA 7(a) Borrower Information Form
dated August 29, 2018 is the same signature appears on a sales contract for
a piece of land sold by the Plaintiff in Naperville, Illinois, dated July 3,
2017. Both signatures 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 the SBA 7(a) Borrower Information
Form dated August 29, 2018 was clearly copied from the Plaintiff's
signature on a sales contract for a piece of land sold by the Plaintiff in
Naperville, Illinois, dated July 3, 2017. This forged signature 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.
·To generate Profit, Defendant Falsified Notarial Records
The notarial records submitted to the court are falsified. Plaintiff, under
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 21 of 78
penalty of perjury pursuant to Pennsylvania criminal law, affirms that prior
to July 19, 2023, Plaintiff 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 (Exhibit "18"). Furthermore, multiple handwriting
examinations confirmed that Plaintiff's signature on the notarial records
was forged (Exhibits "19"–"21").
·To generate profit, Defendant withheld Critical Information: Defendant
intentionally withheld critical documents and information, including but
not limited to: 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 (Exhibits "25").
43. 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 (Exhibits "26”).
44. Defendant’s actions constitute gross negligence, fraud, and breach of
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 22 of 78
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 (Exhibits "1" and "27"). This
fraudulent purchase agreement was entirely unknown to Plaintiff and her
companies, Endeavor 1 LLC and Endeavor AL LLC. Furthermore, neither
Plaintiff 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.
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). (Exhibits "23" and "24").
45. Defendant 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. (attached
hereto as Exhibits "23" and "24"), led to irreparable harm to the Plaintiff”s
mental health, as well as personal and professional reputation,
compounded by ongoing legal battles and foreclosure risks. Plaintiff has
suffered substantial financial losses and emotional distress directly caused
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 23 of 78
by Defendant’s actions.
46. 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.
47. 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.
VIII. FACTS AND EVIDENCE
48.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 ( Exhibit "13"，page 4 – page 22 ). As a
result, Kyle Scott gained access to Plaintiff Yang Shao's identification
information(including copy pf Driver’s license), financial information, and
signature (Exhibit "13", Page 8).
49. 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, having sold a real property under the Form Section 1031
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 24 of 78
Like-Kind Exchange”on July 3, 2017, was restricted to reinvesting in
similar real properties and was prohibited from purchasing other types of
businesses.
50. 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.
51. 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
Property No. 3, totaling $1M for real properties and $2.7 M for business
(Exhibit "28”).
52. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 25 of 78
interests..., as prohibited under the Form Section 1031 Like-Kind
Exchange).
53. At the time of the proposed transaction in 2018, the combined market
median value for the three properties was less than $1,583,700 (Exhibit
"22", Page 22 – page 27). Since the Maricopa County official website only
provides property assessments from the past five years, the closest
available reference is the 2020 assessed values. 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.
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 (Exhibit "22", Page 22 – page 27).
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 (Exhibit "22", Page 22 – page 27).
3). AZ Property No. 3: The third property, located at 17814 North 56th
Street, Scottsdale, Arizona 85254, which Plaintiff never purchased, had a
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 26 of 78
market value of $490,000 (Exhibit "22", Page 22 – page 27).
4).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. (Exhibit "22", Page 22 – page 27).
54. 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.
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 (Exhibit "29").
· However, AZ Property No. 2, built in 1998, has a lot size of 8,454 square
feet (Exhibit "30").
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 27 of 78
· Similarly, AZ Property No. 3, also built in 1998, has a lot size of 9,994
square feet (Exhibit "30").
(2). Side Yard Requirements:
· Under Phoenix’s Zoning Ordinance, side yards in R1-10 zoning districts
must be at least 7 feet wide (Exhibit "31").
· All three properties, however, have side yards measuring less than 7 feet
(Exhibit "32").
· These nonconformities were caused by renovations made by the seller,
who constructed buildings exceeding the allowable size, resulting in
noncompliant side yards. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 28 of 78
(Exhibit "33"). 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 for $668,475, which was two-thirds of the
then-market price (Exhibit "34") through a Form Section 1031 Like-Kind
Exchange”(Exhibit "35").
(2). Purchase Price and Terms:
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（Exhibit "36").
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 (Exhibit "37"). Mrs. Micu filed
for Chapter 11 bankruptcy protection in the United States Bankruptcy
Court for the District of Arizona on June 7, 2010 (Case Number: 2:09-bk-
29894 JMM, She discharged her debts on December 11, 2012, and
retained ownership of AZ Property No. 1 (Exhibit "33").
· 2018 Financial Crisis: Facing another financial crisis in 2018, Mrs. Micu
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 29 of 78
sold AZ Property No. 1 to USS Team Investments III LLC on September
28, 2018 (Exhibit "38”).
· Subsequent Transactions: On December 31, 2018, USS Team
Investments III LLC sold AZ Property No. 1 to Plaintiff under a Section
1031 Like-Kind Exchange”(Exhibit "34"and"35").
· The Title Company overseeing the transaction was Alliant National Title
Insurance Company, and the escrow number was No. 18-06-137056JM
(Exhibit "36").
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) (Exhibit "39"). USS Team Investments LLC
also owned by Mrs. Mihaela Micu (Exhibit "40"). 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
September 28, 2018 (Exhibit "41"). On December 31, 2018, USS Team
Investments III LLC sold AZ Property No. 2 to Plaintiff Yang Shao under
under a Form 1031 Exchange (Exhibit "34" and "35").
· The Title Company overseeing the transaction was Alliant National Title
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 30 of 78
Insurance Company, and the escrow number was No. 18-06-137056JM
(Exhibit "36").
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: 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.
55. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 31 of 78
Section 1031 Like-Kind Exchange”(Exhibit "34" and "35"). The Title
Company overseeing the transaction was Alliant National Title Insurance
Company, and the escrow number was 18-06-137056JM (Exhibit "36").
56.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 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 (Exhibit "34",
"35","36").
57. 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.
58.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.
59. Tax Avoidance Suggestion by Kyle Scott:
At that time, Kyle Scott informed the Plaintiff that issuing him a 1099 form
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 32 of 78
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 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.
60. 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.
61. 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 (Exhibit "34", and "35") under Escrow Number 18-
06-137056JM (Exhibit "36").
62. 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 Like-Kind Exchange”
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 33 of 78
under Yang Shao’s name and Escrow Number 18-06-137056JM (Exhibit
"13" page 4 to page 22, "34", "35", "36").
63. 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 (Exhibit "26").
Among these was a commitment letter dated August 18, 2018 (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. 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.
64. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 34 of 78
Yang Shao’s signatures from her prior land sale agreement dated August
3, 2017 (Exhibit "13", Page 8), forged Plaintiff Yang Shao's signature on
SBA7(a) Borrower Information For - Representations, Authorizations and
Certifications (Exhibit "13", Page 3).
65. 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 ,
Defendant colluded with the 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 (Exhibit "13", "34" and "35"). 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 35 of 78
Plaintiff ’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 AZ Property No. 2. Listing another
party, such as Endeavor 1 LLC, as the buyer was legally improper. 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 was legally improper and demonstrates a
deliberate effort to obscure the true nature of the transaction. 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 (Exhibit "13"
and "34"). 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. 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 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.
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 36 of 78
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.
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.The proposed three
houses are priced at one million dollars for real estate, 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
(Exhibit "38") and AZ Property No. 2 (Exhibit "41"). 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 Defendant to fabricate loan contracts,
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 37 of 78
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, no action was taken.
3). Step Three: Fraudulent Loan Agreement Creation
The Defendant, in collusion with Title Company 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 in the AZ Properties. Such an arrangement defies
standard banking and lending practices and demonstrates clear intent to
fabricate a false transaction. Defendant fabricated a loan agreement:
the final page of the Loan Agreement text is Page 15, yet the signature
page is labeled “Page 24 of 498,” clearly from a different document. All
the fonts and line spacing on Plaintiff’s signature page are different from
other pages，also has a black vertical line not found on any other pages,
indicating it was artificially inserted. Furthermore, a page titled “Schedules”
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 38 of 78
suddenly appears after the signature page, in an abnormal format, further
suggesting forgery. (Exhibit "2")
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.
The plaintiff purchased a Certified Copy from the Maricopa County
Recorder's Office, Arizona, confirming that the defendant recorded
fraudulent Deeds of Trust. Defendant privately fabricated the seal of the
Maricopa County Recorder's Office, Arizona, and produced two fraudulent
Deeds of Trust (Exhibit "4").
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 (Exhibit "34"). However, the
Defendant and the Title Company, without the Plaintiff's knowledge or
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 39 of 78
presence, improperly listed the ownership of AZ Property No. 1 and AZ
Property No. 2 under Endeavor 1 LLC on November 6, 2018. This transfer
was carried out without notifying the Plaintiff, who was the sole party
providing the full payment for the AZ Properties. 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.
66. 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. This clear restriction under U.S.A 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 40 of 78
$3.05 million loan.
67. 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 (Exhibit "34"):
1). August 9, 2018: The Title Company instructed Plaintiff to transfer
$50,000. Plaintiff transferred $50,000 on the same day (Exhibit "42").
2). October 11, 2018: The Title Company instructed Plaintiff to transfer
$100,000. Plaintiff transferred $100,000 on the same day (Exhibit "43").
3). October 22, 2018: The Title Company instructed Plaintiff to transfer
$15,000. Plaintiff transferred $15,000 on the sameday (Exhibit "44").
4). November 5, 2018: The Title Company instructed Plaintiff to transfer
$518,475.12. Plaintiff transferred $518,475.12 on the same day (Exhibit
"45").
5). December 31, 2018: The Title Company instructed Plaintiff to transfer
$15,000. Plaintiff transferred $15,000 on the same day (Exhibit "46").
From August 9, 2018 through December 31, 2018, Plaintiff completed a
total transfer of $698,475.12 to the Title Company to finalize the purchase
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 41 of 78
of AZ Property No. 1 and AZ Property No. 2 (Exhibit "34").
Plaintiff 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, 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.
68. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 42 of 78
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 (Exhibit 22).
69. Identification of Actual Purchaser and Fraudulent Transactions
The 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 (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 (Exhibit“47”). 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 was not listed as the purchaser of these properties(Exhibit“25”).
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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 43 of 78
Defendant Customers Bank and the subsequent disbursement of loan funds
(Exhibit“1”).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) (Exhibit “27”). The purchase agreement between Kyle
Scott and the "Adagios" was entirely fraudulent.
70. Fraudulent Ownership Claims and Defendant’s Negligence
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.
71.Fraudulent Exploitation of Plaintiff’s Identity and Misrepresentation of
Property Values
To conceal the fraudulent real estate loan and fraudulent loan agreement
with Mr. Kyle Scott and his company Endeavor US LLC, Defendant’s
Senior Vice President, Karl Danlelian misuse Plaintiff’s personal and
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 44 of 78
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.
72. On August 18, 2018 Defendant fabricated a loan commitment letter as
the beginning of their fraudulent scheme. 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 (Exhibit "13").
On August 11, 2022, four years after the closing, the Defendant provided
the Plaintiff with the loan and guarantee documents for the first time—
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 45 of 78
documents of which the Plaintiff had no prior knowledge (Exhibit "26").
Among these was a commitment letter dated August 18, 2018 (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.
73. Defendant fraudulently copied, cut, and pasted Plaintiff Yang Shao’s
signatures from her prior land sale agreement dated August 3, 2017
(Exhibit "13", Page 8), forged Plaintiff's signature on SBA7(a) Borrower
Information Form Representations, Authorizations and Certifications
(Exhibit "13"，Page 3).
74. 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 (Exhibit "22"). 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 (Exhibit "26"). 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 (Exhibit "47"). The details of this fraudulent scheme are
outlined as follows:
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 46 of 78
· Plaintiff's personal and financial information was misused without her
knowledge.
·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.
75. Via subpoena, Defendant's fraudulent conduct was further confirmed：
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 (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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 47 of 78
Property No. 3) (Exhibit "27").
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 (Exhibit "27").
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 (Exhibit "26"). Among these was a commitment letter dated
August 18, 2018 (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. It is impossible for one person to produce varying
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 48 of 78
signatures on the same document. This blatant inconsistency in the
commitment letter alone serves as compelling evidence that 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 (Exhibit "13") and
falsely represented his company, "Axcent," as the operating manager of
Plaintiff's companies. 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, rendering it ineligible to sign any
contracts or Deeds of Trust. Verifying the legal status of Axcent was a
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 49 of 78
mandatory step in the loan approval process, but the Defendant failed to
conduct this essential due diligence.
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 (Exhibit "19" - "21").
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 Purchase-Sale Agreement to the
SBA (Exhibit "1"). On September 19, 2022, Plaintiff's late attorney, Brian
Stanley, obtained all materials related to this real estate transaction through
a subpoena issued to the Title Company (Exhibit "47"). Among these
Closing documents, Plaintiff discovered for the first time an SBA 7(A)
Guaranteed Loan Authorization, a document Plaintiff had never received
(Exhibit "49"). This loan authorization explicitly required an Executed
Purchase-Sale Agreement to be obtained before disbursement (Exhibit
"49" page 17, section 3(b)(2)). Plaintiff also saw the Purchase-Sale
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 50 of 78
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 (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) (Exhibit "27"). 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 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.
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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 51 of 78
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
(Exhibit "1"). So how is it possible that a loan agreement exists stating
Plaintiff and her company Endeavor 1 LLC borrowed $3.05 million from
Defendant for purchasing these properties?
(2). Defendant subsequently submitted fraudulent Purchase-Sale
agreement, 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. 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 (Exhibits "19"–"21"). 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)
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 52 of 78
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. This was the first time Plaintiff saw an SBA 7(A)
Guaranteed Loan Authorization, a document Plaintiff never received
(Exhibit "49"). Plaintiff found that Defendant had inflated the appraisals of
the Arizona Properties (three houses) to $3.09 million in 2018 to deceive
the SBA.
i. According to the SBA 7(A) Guaranteed Loan Authorization (Exhibit
"49"), 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 (Exhibit "49" p18, 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 (Exhibit "22").
Because the Maricopa County Assessor public website only provides real
estate market prices from the past five years, data for 2018 cannot be
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 53 of 78
obtained, 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 (Exhibit "22"). In 2020, the market value for the
Arizona Properties were as $1,583,700 :
· 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, under Phoenix City zoning regulations, side yards must not
be less than 7 feet (Exhibit "31"). During prior renovations, the seller
overbuilt the properties, reducing the side yards to less than 7 feet,
rendering the structures illegal (Exhibit "32"). 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
· 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 54 of 78
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) (Exhibit "22 "): 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 (Exhibit "22").
(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. For the first time, Plaintiff
saw the SBA 7(A) Guaranteed Loan Authorization, a document Plaintiff
never received (Exhibit "49"). 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.
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 55 of 78
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, including a Note.
Subsequently, on August 25, 2023, Defendant submitted the other version
of the Note to the court (Exhibit 11). The two notes are different versions,
yet both contained Mr . Kyle Scott' 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 (Exhibit "11").
11). Defendant also forged Plaintiff's signatures on the guarantee
documents (Exhibit "12").
12). Defendant engaged in fraud by colluding with Kyle Scott and his
partners, Richard Murray and Tod Decker, to deceive the SBA.
Plaintiff, a newly immigrated single mother, did not meet the qualifications
to be a SBA loan guarantor. In collusion with Kyle Scott and his partner
Richard Murray, falsely presented them as guarantors and facilitated the
signing of fraudulent guarantee documents to meet the SBA's guarantor
requirements. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 56 of 78
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). On November 2, 2018, Defendant instructed Title Company to release
loan funds to Adagios based on the false real estate purchase agreement
(Exhibit "1" & “50”). Subsequently, on November 6, 2018, Defendant
Authorized Title Company to release loan funds to Adagios based on the
false real estate purchase agreement (Exhibit "1"& "51"). However, Title
Company did not follow Defendant 's instruction and wrongly released the
loan funds to USS Team Investments III LLC on November 6, 2018
(Exhibit "52"). On the same day, Kyle Scott authorized Title Company to
wire $198,000 to his partner Richard Murray and Tod Decker as a "
consultation fee" . Tod Decker received $53,540, and Richard Murray
received $144,793.33 (Exhibit "53" and "54"). 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 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 57 of 78
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.
14). Defendant Colluded with the Title Company to Conceal the Closing
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. Among these documents, Plaintiff
saw the Identification Verification and Notary Certification for the first
time (Exhibit "48"). 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
(Exhibit "48").
15). 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 58 of 78
Executive Dr in Aurora, IL, Plaintiff found no such location (Exhibit "18").
Furthermore, the Plaintiff’s signature on the notarial records was forged,
as confirmed by multiple handwriting examinations (Exhibits "19"–"21").
(1).Because Plaintiff consider the accusation that the bank forged mortgage
documents to be extremely serious, and is deeply concerned about the
possibility of being mistaken, Plaintiff have proceeded with utmost caution.
Plaintiff cut back on necessities and painstakingly saved money from the
living expenses for herself and her son to purchase the costly official
certified records from the Maricopa County Recorder's Office (Exhibit
“4 ”).
To utter shock and disbelief, Plaintiff discovered that the Defendant has
audaciously forged even the official record stamp. The two properties AZ
Property No. 1 and No. 2 purchased with Plaintiff’s life savings, were
mortgaged to the Defendant without her knowledge or presence during
closing or the auction obtain two different versions of the Deed of Trust:
the fonts, line spacing, and page margins all vary. However, the signature
pages are identical—they have not been proportionally enlarged or reduced.
This proves that the two Deed of Trust are forged: it is impossible for a
person to sign exactly the same signature on two physically different
documents.What astounded further is that the Record Stamps on the two
Deeds of Trust are also different constitutes the criminal offense of forging
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 59 of 78
a security instrument.
(2). Plaintiff's investigation confirms that the notary public who notarized
documents for the Defendant has maintained a long-standing illegal
financial interest with the Defendant. Significant illegal financial interest
between Notary Tamara R. Thompson and Customers Bank suggests
collusion in PPP Loan Fraud (Exhibits 55–57). A company owned by
Tamara R. Thompson received and was forgiven for duplicate PPP loans
through Customers Bank in April 2021 and May 2021. However, the
following serious issues exist:
A. Her company was dissolved before February 15, 2020 (the statutory
eligibility assessment date for applying PPP) and was not reinstated until
March 6, 2020 rendering it ineligible for SBA PPP loan. But her company
obtained a $10,691 PPP loan from Customers Bank which was quickly
forgiven. This constitutes federal PPP loan fraud.
B. The second loan of the same amount was issued from Customers Bank
just 53 days after the first—far shorter than the SBA legally required 8–24-
week usage period—and lacked necessary documentation of revenue
decline, indicating duplicate loans and false applications, also has been
quickly forgiven committing federal PPP loan fraud.
C. Customers Bank, as the lender, was placed on the SBA’s investigation
list in 2022 for suspected PPP fraud due to serious deficiencies in its
approval process. This demonstrates substantial financial ties between
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 60 of 78
Tamara and Customers Bank, severely compromising her neutrality and
credibility as a witness in this case.
(3).Tamara Self-Filled an Affidavit with Logical Inconsistencies
(Exhibit 16). Tamara filled the blank space in an Affidavit with the word
“companies,” creating semantic confusion by implying “Yang Shao and
companies are the same person.” This error reflects her hastiness and
disarray while self-filling the Affidavit
(4).Tamara Filed a Contradictory Affidavit Regarding My Identity
(Exhibit 17).The document describes Plaintiff simultaneously as the
“borrower,” “guarantor,” and “an inducement Lender.” These roles are
logically conflicting and contradictory, indicating fundamental errors in
the Affidavit.
(5). Defendant forged mortgage documents for the Plaintiff’s property at
524 E. 14th Avenue, Naperville, Illinois: These are two mortgage
documents with 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.
(Exhibit "6")
On August 11, 2022, four years after the closing, Defendant sent the loan
document and guarantee document to Defendant for the first time, of which
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 61 of 78
Plaintiff had no prior knowledge (Exhibit "26"), including a mortgage
document for the Plaintiff’s property at 524 E 14th Avenue, Naperville,
Illinois (Exhibit "6"), which Plaintiff had no prior knowledge.
Subsequently, on August 25, 2023, Defendant submitted the other version
of mortgage document for the same property to the court (Exhibit " 6").
They are two different versions of the document, yet they bear the
Plaintiff's completely identical signature page. It is impossible for a person
to sign exactly the same signature on two physical documents,
demonstrating that these two documents are forgeries created by the
Defendant.
(6).Two Inconsistent Versions of the Mortgage Document in Illinois
Cook County: Plaintiff’s property Unit 327 4250 N Marine Dr, Chicago.
(Exhibits 7). Customers Bank prepared two nearly identical mortgage
document sets with different formatting—one used in closing, and the
other used in the public record to seize Plaintiff’s properties. The font and
line spacing between the two document sets differ significantly, yet
Plaintiff’s signatures appear exactly the same on both—identical in shape
and size. This is impossible if handwritten by a person signed on the
different physical documents, committing forgery. Furthermore, the bank
claims Plaintiff signed the guaranty agreement on November 5, 2018, with
Tamara R. Thompson as the notary. However, the mortgage document was
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 62 of 78
not recorded until January 2019—a two-month gap that further raises
doubts about its authenticity.
(7).Defendant forged two Inconsistent Versions of the Assignment of
Lease and Rent in issue properties in AZ . After thorough comparison,
Plaintiff can confirm again that these are two different versions of the
mortgage documents of the same in issue properties in AZ: the font, line
spacing, and page margins of the main text in each version are visibly
different. However, the signature page in both versions is formatted
identically, and the signature itself appears exactly the same in both—
identical in shape and form. It is impossible for a person to handwrite an
identical signature on two physically different documents. To utter shock
and disbelief, Plaintiff discovered that the Plaintiff has audaciously forged
eventhe official record stamp. (Exhibits 8)
（8）.Defendant forged Property Assignment of Lease and Rent in Illinois
too. The document titled " Cook County Chicago Apartment Assignment of
Lease and Rent" used by Customers Bank in the closing —is different from
the one recorded at the Cook County Recorder’s Office (Exhibit 9). The
differences include font size, page margins, line spacing, and paragraph
spacing. However, the signature page — the final page of both documents
— contains plaintiff’s signature that is exactly identical in size and shape.It
is impossible for any people to sign two separate physical documents with
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 63 of 78
an exactly identical signature. This means that both signatures were forged
by Customers Bank, because:
A.If the version used in the closing was genuine, Customers Bank could
have simply submitted that version to the Cook County Illinois Recorder’s
Office for recording — there would have been no necessity to fabricate the
other version for recording.
B.Conversely, if the version on file with the Cook County Illinois Recorder
was genuine, the Bank could have used it directly in the closing— again,
there would have been no necessity to fabricate the other version to present
in court.
Why would the Defendant take the risk of creating two different sets of
Deeds of Trust for separate use in Closing/auction versus recording?
After much deliberation, the only conclusion Plaintiff can draw is that this
constitutes a collaborative fraud involving both internal and external
parties: Internal personnel created one set of the Deed of Trust for use in
Closing and the auction, while external personnel created another set for
recording. However, due to a lack of communication between these
internal and external parties, they acted independently, resulting in two
different versions of the document bearing identical signature page forging
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 64 of 78
an official Record Stamp constitutes the criminal offense of forging a
security instrument.
16). On November 2, 2018, Defendant instructed the Title Company to
release $3.05 million to the fraudulent seller Adagios which based on a
false 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 (Exhibit "1", "50"). 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."(Exhibit "50").This directive
was tied to a faulse 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 (Exhibit
"1"). This evidence clearly demonstrates that the instruction to release the
$3.05 million loan funds had no connection to Plaintiff.
17). On November 6, 2018, Defendant authorized the Title Company to
release $3.05 million in loan funds to the fraudulent seller: Adagios which
based on a false 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 (Exhibit "1", "51"). This evidence clearly demonstrates that
Defendant's authorization to release the $3.05 million loan funds had no
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 65 of 78
connection to Plaintiff.
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?
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 "58". 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 66 of 78
communication. (attached hereto as Exhibit "58").
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 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 discovered that three separate entities
named “Customers Bank”are registered in Pennsylvania. These entities are
as follows:
(1). Customers Bank (Entity No. 2572797), a Name Reservation entity
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 67 of 78
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. (Exhibit“59”)
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, 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 68 of 78
of being a lawful financial institution. Consequently, any actions taken
during this period are invalid. ( Exhibit “59”)
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. (Exhibit
“59”)
76. 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 (Exhibit "26"). 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 (Exhibit "47"). It was only
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 69 of 78
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 (Exhibit "25").
· 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")
(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 (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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 70 of 78
Closing documents list the loan applicant and the issuer of the Deed of
Trust as Endeavor 1 LLC (Exhibit "52").
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.
iii. Defendant Customers Bank's Instruction Letter for Disbursement to the
Title Company (Exhibit "50") and Defendant Customers Bank
Authorization for Disbursement (Exhibit "51") 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
(Exhibit "52") and the Final Closing Statement (Exhibit "53") 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 (Exhibit "1", page 11). However, the Final
Closing Statement in the Closing documents lists the Real Estate Price as
$2,975,000 (Exhibit "53"). These two critical Closing documents, meant to
define the agreed-upon price for the real estate transaction, are directly
contradictory and cannot be reconciled.
In summary, the above analysis of the Purchase-Sale Agreement, loan,
guarantee, Deed of Trust, mortgage documents and closing documents
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 71 of 78
demonstrates that these documents are riddled with contradictions and fail
to corroborate one another. These inconsistencies serve as clear evidence
that the Purchase-Sale 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 (Exhibit "48") 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 (Exhibits "19"- "21").
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
(Exhibit "60").
77. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 72 of 78
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)
Exhibit "60").
78. As Kyle Scott and Mrs. Maxime Scott were the sole signers on the
Endeavor 1LLC 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 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.
79. 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 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 's companies Endeavor 1 LLC and
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 73 of 78
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 (Exhibit "61"). 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 and $2.2921 million profits from Plaintiff's
properties AZ Property No. 1 and AZ Property No. 2. totaling $3.4921
Million.
80.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. 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
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 74 of 78
his office.
81.After two years of 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 Illinois. 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 “62”). However, due to
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 75 of 78
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
“63”).
IX．CONCLUSION
On October 24, 2023, to conceal a $3.05 million loan erroneously
disbursed due to the Defendant’s error stemming from a fraudulent real
estate purchase contract, the Defendant exploited the Plaintiff—a new
immigrant with limited English proficiency suffering from hereditary
depression. During a closing conducted without the Plaintiff’s knowledge
or presence, the Defendant colluded with a notary public with whom they
maintained a long-standing illicit benefits relationship (who had previously
conspired with the Defendant in 2021 to fraudulently obtain two SBA PPP
loans). Together, they fabricated real estate valuations to deceive the Small
Business Administration (SBA), forged the Plaintiff’s signature, and
illicitly affixed the seal of the Maricopa County Recorder’s Office in
Arizona to produce two fraudulent Deeds of Trust.
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 76 of 78
Furthermore, they forged the following documents across California,
Illinois, and Arizona:
• False commitment letters
• Loan Agreements
• Promissory Notes
• Deeds of Trust
• Mortgages
• Assignments of Leases and Rents
• Unconditional Guarantees
• Risk Disclosure Statements
• Customer Identification Forms
• Identity Affidavits
• Signing Affidavits
• Notarial journals
These actions ultimately resulted in the illegal auction of the Plaintiff’s two
properties.
X. CLAIMS FOR RELIEF
1. Constitutional Remedies
a) Award damages for violations of the Fifth Amendment to the U.S.
Constitution;
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 77 of 78
b) Award restitution for Fourteenth Amendment violations pursuant
to 42 U.S.C. § 1983.
2. RICO Treble Damages (18 U.S.C. § 1964(c))
Order Defendants to pay treble damages under 18 U.S.C. § 1964(c)
(Civil RICO) for engaging in a pattern of racketeering activity
involving SBA fraud and document forgery between 2021 and 2023.
3. Constitutional Tort Damages
Order Defendants liable for constitutional tort damages under the
Fifth and Fourteenth Amendments for the unlawful deprivation of
Plaintiff's property without due process.
4. Rescission of Fraudulent Loans
Order the Small Business Administration (SBA) to rescind the
fraudulent loans.
5. Punitive Sanctions
a) Statutory fines:
o Mail/Wire Fraud (18 U.S.C. §§ 1341, 1343): $[Amount]
o SBA Fraud (18 U.S.C. § 1001) b) Revocation of the implicated
notary public's commission.
6. Equitable Relief
a) Imposition of a constructive trust over auction proceeds;
b) Compel Defendants to produce fully audited accounting of all
fraudulently obtained SBA funds.
Case 2:25-cv-02640-KSM Document 13 Filed 07/15/25 Page 78 of 78
RESPECTFULLY SUBMITTED this 14 day July 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 14 day of July, 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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