1. Plaintiff brings this action to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten monies, and other equitable relief for defendants’ acts or practices.
2. Jurisdiction and venue
3. This court has subject matter jurisdiction pursuant to 28 u.S.C. §§ 1331, 1337A), and 1345
4. Venue is proper in this district under 28 u.S.C. § 1391B)(2), B)(3), C)(1), and C)(2].
5. Statement of the case
6. Plaintiff paid $5,127 into defendants pyramid scheme and got nothing in return. Fraudulent misrepresentations by defendants were made and promises were not kept by defendants and were a direct and proximate cause of plaintiffs losses.
7. Defendants guaranteed me $7,000 to $10,000 profits in a few weeks, but plaintiff has gotten nothing at all after 3 months.
8. Commentary
9. Plaintiff was solicited by defendant in mid feb 2021 to join his business opportunity.
10. Plaintiff was promised free advertising, a return of $7000 to $10000 for his membership and free coaching.
11. Plaintiff paid $3500 on feb 20 2021 to join defendants scheme.
12. Plaintiff paid $447 on feb 24 2021 for an administration fee.
13. Plaintiff was promised free advertising of 50,000 voicemail broadcasts, a return of $7,000 to $10,000 for his investment, and coaching but got nothing at all.
14. Plaintiff had to pay $1000 for advertising on march 16 2021.
15. The scheme was that others would respond to the advertising and also pay the same membership fee of $3500, and plaintif and defendant would share their fees 50/50.
16. Upon paying for advertising plaintiff got over 4000 e mail notifications that prospects called defendant for information and sales opportunities and defendant could make sales from them.
17. Defendant may have made sales and kept the money all to himself. Plaintiff has no way of knowing how many prospects paid into a membership for plaintiff to profit.
18. Defendant promised plaintiff coaching but stopped phone and e mail communication soon after plaintiff paid him.
19. Defendant caused plaintiffs damages of $5,127.
20. Defendants shared testimonials from others who claimed to make over 5 figures in less then a month after buying into the scheme.
21. This case reflects unfair and deceptive trade practices by the defendants.
22. Take judicial notice of case # 2:18-cv-00729-jak f.T.C. Vs. Digital altitude. That case has the same issues and the ftc won a $14 million dollar judgement against defendants for the same thing i am claiming.
23. The $3,500 and $447 fees were charged on my government issued debit card,so defendant defrauded the govt, through me.
24. It has stopped the use of my card, since i filed a dispute with them over the charges.
25. Summary of the case
26. Defendants operate a fraudulent scheme that preys on consumers hoping to earn money while working from home. Defendants falsely tell consumers that through their “system” or “program,” consumers will earn large sums of money operating their own business online. Defendants represent to consumers that defendants’ program will enable consumers to “start and grow a profitable online business” and “make six figures online in the next ninety days or less.” defendants extract steep fees for membership, in this case over $5,000, but the vast majority of consumers who pay defendants never earn substantial income, much less the claimed “six figures.”
27. Defendants’ program consists of a series of tiered membership levels, each with a membership fee higher than the last. Defendants pay a consumer only when the consumer recruits new consumers to join the program, through commissions on the new consumers’ membership fees. Although defendants’ program ostensibly provides business coaching that will help members build a successful business, the goal of that “coaching” is to persuade the member to purchase a higher membership tier.
28. Defendants have charged individual consumers substantial amounts of money, ranging from several thousand dollars to more than $20,000.
29. Plaintiff paid into this pyramid scheme for $5,127 all lost to fraudulent misrepresentations.
30. Plaintiff paid $3500 for meembership, $447 for administration, $1000 for advertising, $160 for website and $20 for a 800# phone link hosting for a total of $5,127.
31. There are other victims found on scamion.
32. Parties
33. Plaintiff patrick farrell is a living man, located at phoenix az. . Phone #
34. Defendants are christian kinney and ck holdings at spring tx.
35. His website is https://memberteamsystem.com/cjs
37. His phone numbers are 832-878-5787 or 305-400-4370 or 281-826-3506
38. Count i fraud misrepresentations regarding earnings
39. In numerous instances in connection with the advertising, marketing, promotion, offering for sale, or sale of their purported money-making opportunities, defendants have represented, directly or indirectly, expressly or by implication, that purchasers of their purported money-making opportunities would earn or were likely to earn substantial income, such as five figures in less then a month and six figures in ninety days or less.
40. Defendants’ representations set forth in this complaint are false, misleading, or were not substantiated at the time the representations were made. Therefore, defendants’ representations as set forth in this complaint constitute a deceptive act or practice in or affecting commerce.
41. Plaintiffs damages are $5,127 plus court costs.
42. Count ii fraud misrepresentations regarding goods, services provided
43. In numerous instances in connection with the advertising, marketing, promotion, offering for sale, or sale of their purported money-making opportunities, defendants have represented, directly or indirectly, expressly or by implication, that purchasers of their purported money-making opportunities would receive business coaching that would provide what the consumer needed to build a successful business.
44. Defendants stopped communication with plaintiff after paying.
45. Defendants’ representations in this complaint are false, misleading, or were not substantiated at the time the representations were made.
46. Therefore, defendants’ representations of this complaint constitute a deceptive act or practice in or affecting commerce.
47. Plaitiff loss was $5,127.
48. The court’s power to grant relief
49. The court, in the exercise of its equitable jurisdiction, may award ancillary relief, including rescission or reformation of contracts, restitution, the refund of monies paid, and the disgorgement of ill-gotten monies, to prevent and remedy any violation of any provision of law.
50. Prayer for relief
51. Wherefore, plaintiff pursuant to the court’s own equitable powers, requests that the court:
52. A. Award plaintiff such preliminary injunctive and ancillary relief as may be necessary to avert the likelihood of consumer injury during the pendency of this action and to preserve the possibility of effective final relief, including but not limited to, temporary and preliminary injunctions, an order freezing assets, immediate access, and the appointment of a receiver;
53. B. Award such relief as the court finds necessary to redress injury to consumers resulting from defendants' violations including but not limited to, rescission or reformation of contracts, restitution, the refund of monies paid, and the disgorgement of ill-gotten monies; and
54. D. Award plaintiff the costs of bringing this action, as well as such other and additional relief as the court may determine to be just and proper.
55. I certify that a true and correct copy was sent by us mail to
56. Christian kinney and ck holdings llc at spring tx,
Coach Christian Kinney Reviews
United states district court
In the district of arizona
Vs. Case no. 2:21-cv-00612-spl
Ck holdings llc
Christian kinney date may 18, 2021
1st amended complaint
1. Plaintiff brings this action to obtain temporary, preliminary, and permanent injunctive relief, rescission or reformation of contracts, restitution, the refund of monies paid, disgorgement of ill-gotten monies, and other equitable relief for defendants’ acts or practices.
2. Jurisdiction and venue
3. This court has subject matter jurisdiction pursuant to 28 u.S.C. §§ 1331, 1337A), and 1345
4. Venue is proper in this district under 28 u.S.C. § 1391B)(2), B)(3), C)(1), and C)(2].
5. Statement of the case
6. Plaintiff paid $5,127 into defendants pyramid scheme and got nothing in return. Fraudulent misrepresentations by defendants were made and promises were not kept by defendants and were a direct and proximate cause of plaintiffs losses.
7. Defendants guaranteed me $7,000 to $10,000 profits in a few weeks, but plaintiff has gotten nothing at all after 3 months.
8. Commentary
9. Plaintiff was solicited by defendant in mid feb 2021 to join his business opportunity.
10. Plaintiff was promised free advertising, a return of $7000 to $10000 for his membership and free coaching.
11. Plaintiff paid $3500 on feb 20 2021 to join defendants scheme.
12. Plaintiff paid $447 on feb 24 2021 for an administration fee.
13. Plaintiff was promised free advertising of 50,000 voicemail broadcasts, a return of $7,000 to $10,000 for his investment, and coaching but got nothing at all.
14. Plaintiff had to pay $1000 for advertising on march 16 2021.
15. The scheme was that others would respond to the advertising and also pay the same membership fee of $3500, and plaintif and defendant would share their fees 50/50.
16. Upon paying for advertising plaintiff got over 4000 e mail notifications that prospects called defendant for information and sales opportunities and defendant could make sales from them.
17. Defendant may have made sales and kept the money all to himself. Plaintiff has no way of knowing how many prospects paid into a membership for plaintiff to profit.
18. Defendant promised plaintiff coaching but stopped phone and e mail communication soon after plaintiff paid him.
19. Defendant caused plaintiffs damages of $5,127.
20. Defendants shared testimonials from others who claimed to make over 5 figures in less then a month after buying into the scheme.
21. This case reflects unfair and deceptive trade practices by the defendants.
22. Take judicial notice of case # 2:18-cv-00729-jak f.T.C. Vs. Digital altitude. That case has the same issues and the ftc won a $14 million dollar judgement against defendants for the same thing i am claiming.
23. The $3,500 and $447 fees were charged on my government issued debit card,so defendant defrauded the govt, through me.
24. It has stopped the use of my card, since i filed a dispute with them over the charges.
25. Summary of the case
26. Defendants operate a fraudulent scheme that preys on consumers hoping to earn money while working from home. Defendants falsely tell consumers that through their “system” or “program,” consumers will earn large sums of money operating their own business online. Defendants represent to consumers that defendants’ program will enable consumers to “start and grow a profitable online business” and “make six figures online in the next ninety days or less.” defendants extract steep fees for membership, in this case over $5,000, but the vast majority of consumers who pay defendants never earn substantial income, much less the claimed “six figures.”
27. Defendants’ program consists of a series of tiered membership levels, each with a membership fee higher than the last. Defendants pay a consumer only when the consumer recruits new consumers to join the program, through commissions on the new consumers’ membership fees. Although defendants’ program ostensibly provides business coaching that will help members build a successful business, the goal of that “coaching” is to persuade the member to purchase a higher membership tier.
28. Defendants have charged individual consumers substantial amounts of money, ranging from several thousand dollars to more than $20,000.
29. Plaintiff paid into this pyramid scheme for $5,127 all lost to fraudulent misrepresentations.
30. Plaintiff paid $3500 for meembership, $447 for administration, $1000 for advertising, $160 for website and $20 for a 800# phone link hosting for a total of $5,127.
31. There are other victims found on scamion.
32. Parties
33. Plaintiff patrick farrell is a living man, located at phoenix az. . Phone #
34. Defendants are christian kinney and ck holdings at spring tx.
35. His website is https://memberteamsystem.com/cjs
36. His e mail is [email protected]
37. His phone numbers are 832-878-5787 or 305-400-4370 or 281-826-3506
38. Count i fraud misrepresentations regarding earnings
39. In numerous instances in connection with the advertising, marketing, promotion, offering for sale, or sale of their purported money-making opportunities, defendants have represented, directly or indirectly, expressly or by implication, that purchasers of their purported money-making opportunities would earn or were likely to earn substantial income, such as five figures in less then a month and six figures in ninety days or less.
40. Defendants’ representations set forth in this complaint are false, misleading, or were not substantiated at the time the representations were made. Therefore, defendants’ representations as set forth in this complaint constitute a deceptive act or practice in or affecting commerce.
41. Plaintiffs damages are $5,127 plus court costs.
42. Count ii fraud misrepresentations regarding goods, services provided
43. In numerous instances in connection with the advertising, marketing, promotion, offering for sale, or sale of their purported money-making opportunities, defendants have represented, directly or indirectly, expressly or by implication, that purchasers of their purported money-making opportunities would receive business coaching that would provide what the consumer needed to build a successful business.
44. Defendants stopped communication with plaintiff after paying.
45. Defendants’ representations in this complaint are false, misleading, or were not substantiated at the time the representations were made.
46. Therefore, defendants’ representations of this complaint constitute a deceptive act or practice in or affecting commerce.
47. Plaitiff loss was $5,127.
48. The court’s power to grant relief
49. The court, in the exercise of its equitable jurisdiction, may award ancillary relief, including rescission or reformation of contracts, restitution, the refund of monies paid, and the disgorgement of ill-gotten monies, to prevent and remedy any violation of any provision of law.
50. Prayer for relief
51. Wherefore, plaintiff pursuant to the court’s own equitable powers, requests that the court:
52. A. Award plaintiff such preliminary injunctive and ancillary relief as may be necessary to avert the likelihood of consumer injury during the pendency of this action and to preserve the possibility of effective final relief, including but not limited to, temporary and preliminary injunctions, an order freezing assets, immediate access, and the appointment of a receiver;
53. B. Award such relief as the court finds necessary to redress injury to consumers resulting from defendants' violations including but not limited to, rescission or reformation of contracts, restitution, the refund of monies paid, and the disgorgement of ill-gotten monies; and
54. D. Award plaintiff the costs of bringing this action, as well as such other and additional relief as the court may determine to be just and proper.
55. I certify that a true and correct copy was sent by us mail to
56. Christian kinney and ck holdings llc at spring tx,
________________________________
Ucc-1-308 patrick farrell
phoenix az
[email protected]