PROPOSED Second Amended Complaint for a Class Action Filed This Week!

Two new documents were filed in United States District Court, Central District of California, on Jan. 30, 2011 by attorneys Thomas Easton, Jonathan Levy and co-counsel, Richard E. Joseph.

The first (Document 79) is a Notice of Motion and Motion to Amend Complaint, which is a request to the Court for an order allowing the filing of Plaintiffs’ proposed Second Amended Complaint.

The second document (Document 80) is the actual PROPOSED MotionVerified Second Amended Complaint, Class Action, Jury Trial Requested. It is:

“a class action in which named Plaintiffs bring this action on behalf of themselves and all others similarly situated who have been victimized by Defendants. The events herein occurred from May 2007 to the present. The Second Amended reduces the number of causes of action to just two counts, Fraud and RICO, reduces the number of named Defendants and adds three Plaintiffs.”

As I understand it the primary differences between the first Amended Complaint and this one are:

John Paul Raygoza, David Sipes and Ted Molina and Raygoza’s various business entities are the only remaining named defendants.

****When investigation determined that their identities and/or material had been stolen by the RCE, the names of Jeff Alderson, Charles Kirkland, Chris Cobb, John Denton, Ron Davies, Craig Beckta, and Jonny Andrews were withdrawn from the previous list of defendants. THEY ARE NO LONGER NAMED IN THE ACTION AGAINST RAYGOZA****

Others were dropped to simplify and facilitate the action. The change to a  “class action”  and reducing the “number of causes of action to just two counts, Fraud and RICO (RICO is an acronym for Racketeer Influenced and Corrupt Organizations Act) will also simplify and facilitate.

As we wait for the judge’s ruling on acceptance by the court of this Second Amendment,  we know that, regardless of the outcome, Raygoza, his partners and business enitities are recorded on the internet (for all time) as dishonest and heartless criminals. Hopefully that means they will have a hard time doing business online in the future.

The actual Motion to Amend and PROPOSED Second Amended Complaint for a Class Action may be seen in their entirety at:

http://www.pushtrafficswindle.com

Comments: (copied to be immediately visible)

Donald On April 3, 2011 at 22:12

The case is interesting, but for some of us it does not make any difference, we are already ruined and will never recover any of the money those in the Pushtraffic Empire stole.

We now have to work out with our credit card companies the debt solution, which can result in a further loss to the Tax Man for any debt excused which is treated as taxable income. And any money drawn from an IRA to pay the credit card Companies is taxed again. Try that as a Senior on a fixed income after retirement.
Don

  • Ann On April 4, 2011 at 10:00

    Don, I’m sure you’ve tried to argue the matter with your bank? If not, I hope you take them to task for not checking out the merchants they approve of. In the meantime each name added to the suit lends more credibility.

    So far as the criminal behaviour of John Raygoza and his criminal enterprises, not much new can be said.

    I carry on with this blog in hopes of forewarning “newbies” who may get sucked into the scams Raygoza and his partners continue to run.

    Sorry for your losses – I can relate obviously. Thank you for your comment – each comment brings a little more notice to this blog and helps publicize our cause.

    Ann

  • Sandy On February 5, 2011 at 11:18

    This is so exciting…I bet Raygoza and his Thugs are s**tting bricks right now. Actually, I hope the bricks are stuck…if you know what I mean; then maybe those scum bags will get a taste of their own backed up bull s**t. LOL I can hardly wait until we victims win this case… wiping that smug smile off their faces is going to be so, over the top, sweet. Sandy

Ann  On February 5, 2011 at 12:33

Hey Sandy – why don’t you tell us how you really feel!!!? LOL

Your comments always tell it like the rest of us would like to :)

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Comments

  • Donald  On April 3, 2011 at 22:12

    The case is interesting, but for some of us it does not make any difference, we are already ruined and will never recover any of the money those in the Pushtraffic Empire stole.

    We now have to work out with our credit card companies the debt solution, which can result in a further loss to the Tax Man for any debt excused which is treated as taxable income. And any money drawn from an IRA to pay the credit card Companies is taxed again. Try that as a Senior on a fixed income after retirement.
    Don

    • Ann  On April 4, 2011 at 10:00

      Don, I’m sure you’ve tried to argue the matter with your bank? If not, I hope you take them to task for not checking out the merchants they approve of. In the meantime each name added to the suit lends more credibility.

      So far as the criminal behaviour of John Raygoza and his criminal enterprises, not much new can be said.

      I carry on with this blog in hopes of forewarning “newbies” who may get sucked into the scams Raygoza and his partners continue to run.

      Sorry for your losses – I can relate obviously. Thank you for your comment – each comment brings a little more notice to this blog and helps publicize our cause.

      Ann

  • Chris  On February 13, 2011 at 21:34

    Keep it up, Ann;
    I was considering sending a new year’s message for 2011 to Raygoza, but I’m not sure how to get it to the right address. A message I sent to Pushtraffic in early 2010, just before the whole rotten pile of filth collapsed, appears on my website.
    The more victims who come forward, the stronger our attack. I have been trying to seek out some more of the many international victims of Raygoza’s racketeering. It is made harder by the multitude of different identities which the Raygoza Gang took on – names such as Incfortune, Dotintel, Affiliatelandmine and others I can’t recall.
    Apart from this, I renewed my challenge to one of my credit card banks to explain why they are aiding and abetting fraud. So far, the bank’s silence has been deafening.

  • Ann  On February 5, 2011 at 12:33

    Hey Sandy – why don’t you tell us how you really feel!!!? LOL

    Your comments always tell it like the rest of us would like to 🙂

  • Sandy  On February 5, 2011 at 11:18

    This is so exciting…I bet Raygoza and his Thugs are s**tting bricks right now. Actually, I hope the bricks are stuck…if you know what I mean; then maybe those scum bags will get a taste of their own backed up bull s**t. LOL I can hardly wait until we victims win this case… wiping that smug smile off their faces is going to be so, over the top, sweet. Sandy

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