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Max Levine


Country United States
State California
City Oakland
Address 1618 99th Ave
Phone (415) 867-2272

Max Levine Reviews

  • Oct 3, 2021

I had been in business for myself for a couple years in the performance based marketing arena when Max Levine reached out to me. We discussed partnering in a call center endeavor. I was to provide training with my business model and Max was to provide money while taking an executive role.

Max recruited his brother Adrian aka Anthony aka Tony Foley to assist with lead generation and I began training them with my business model while providing scores of leads that I had amassed over 3 years and on day 1 there were opportinities.

I took down my site, the next day Max put up ours. I trained, assisted, directed both Max and Tony until they phased me out in the third month. I was told the companies went out of business and there were only losses. Both Max and Tony lied to me and Max had attorney perpetuiate these lies.

I have a court judgment against Sales Source but they have simply changed websites and hidden this entity to prevent collection. I was homeless on our start date with severe head trauma that wasn't diagnosed until later however both Tony and Max new I had issues with vertigo and memory and they leveraged this to their benefit.

Now that I have improved with therapy I have a better understanding of what happened. I grew up with Max and I have never met a more callous, cruel and cynical person, unless you consider his brother Tony aka Anthony aka Adrian Foley. This was planned and coordinated, When you consider that their motives was to hide their success from me while benefiting from my intellectual property, trade secrets and amassed resources and connections, this is RICO personified.

FACTS AND ALLEGATIONS

11. On September 15th, 2009 Plaintiff Darren Ferguson sent Defendant Max Levine a Facebook message. They had been childhood friends and hadn't seen each other for over a decade.

Plaintiff mentioned his current business arena is the call center industry.

12. On January 15th, 2010 Defendant Max Levine send Plaintiff Darren Ferguson a Facebook response stating that he may have some business for the Plaintiff.

13. Defendant Max Levine had just sold his company and was looking for a new business venture.

14. Plaintiff Darren Ferguson had been in the call center industry for 3 years and had created business models that were developed from his intellectual property and plaintiff had amassed many trade secrets.

15. Plaintiff Darren Ferguson had developed many contacts from prospective clients and partners that wanted to do business prior to starting a business with Defendant Max Levine

16. After discussions Defendant Max Levine proposed a business partnership that combined his financial resources and business experience with Plaintiff Darren Ferguson's call center, trade secrets and business model expertise.

17. Plaintiff agreed to start a business with Defendant Max Levine and severed a current business relationship that offered 33% equity and $35 per hour to partner with Defendant Max Levine for equity.

18. Plaintiff agreed to start a business with Defendant Max Levine and Defendant Tony Foley that would be built and then sold.

19. The goal was to build many businesses utilizing Plaintiff's business model, and get the businesses to $100,000,000 in revenues and then sell them.

20. On February 25, 2010 Defendant Max Levine sent Plaintiff Darren Ferguson an email to determine and define their business partnership titled: "Our Arrangement"

Exhibit A

21. On February 26, 2010 Defendant Max Levine sent Plaintiff email titled,"Our Relationship" confirming a partnership with ownership and equity had been formed.

Exhibit B

23. On March 2, 2010 Defendants and Plaintiff launched their businesses first site Latin America Call Centers.

24. On March 3, 2010 Plaintiff took down his site CPANBR

Plaintiff Darren Ferguson began sharing his trade secrets, contacts and Intellectual Property with Defendants Max Levine and Defendant Tony Foley and training had begun.

25. Plaintiff shared all of his trade secrets, contacts and leads he had amassed over the past three years. He trained Defendants on who to call, how to call and the business models to utilize, the overall business climate and the opportunities they should focus on.

26. Plaintiff delegated duties to Defendants while supporting and overseeing their training and development, he was the engine in this business and all information and questions flowed through him.

27. Defendants Max Levine and Tony Foley relied on Plaintiffs experience continuously requesting information on where to look for business and how to get it. They contacted Plaintiff at all times during the day and night seeking direction and information.

28. Defendants Max Levine and Tony Foley also requested that business models be developed and also requested for leads to be provided to them so they could contact businesses that were interested in the services that Plaintiff had previously offered, prior to engaging in business with Defendants.

29. Plaintiff trained Defendants Max Levine and Tony Foley and shared all his contacts while developing new ones and business picked up immediately.

30. Defendant Max Levine shared many promising emails with Plaintiff regarding business deals that were close to closing

31. Defendant Max Levine was taking flights to meetings.

32. Defendant Max Levine was getting ID's from potential clients that allowed access their databases.

33. Defendant Max Levine had a "pipeline" of business close to closing

"Darren, this feedback is mainly on stuff you are bringing in. Good news on a couple of your leads. Don't read too much in to this just use it to help you steer clear of overworked stuff."

Exhibit C

34. Defendant Max Levine had a fund set up with a call center and wanted the call center to handle the calling campaign.

"I get it. I am okay setting up a fund and letting you run it."

Exhibit D

35. On May 6th 2010 our business launched our second site Sales Source that provided businesses with an outsourced lead generation and sales department.

36. On May 10th 2010 Plaintiff got a lead from Chris Byers of Arriva Medical and forwarded it to Defendant Max Levine. Arriva medical sells hand held blood glucose meters for diabetic patients.

37. The businesses had focused on a number of industries and now Defendants Max Levine and Tony Foley wanted to focus on diabetic and Medicare opportunities and Plaintiff was asked to build a list of prospective Medicare partners and business opportunities.

38. Plaintiff began to check up on some of the original business opportunities we had and began to get emails from Defendant max Levine and Tony Foley that told Plaintiff that none of the deals were closed.

39. Defendant Max Levine sent Plaintiff emails denying getting customers and claiming that the time invested thus far was "exploratory" and “didn't net much” even though he currently was hiding jobs from Plaintiff.

Exhibit E

40. Defendant Max Levine sent Plaintiff an email dated June 6, 2010 requesting Plaintiff work full time.

"Mainly because I don't want people that come in for 1-2 months bail to something else but own a part of a company they are not contributing in to."

Exhibit F

41. Defendant Max Levine's points are moot.

Plaintiff is already an owner of these companies and Plaintiff had earned equity and had contributed on a large scale.

42. Defendants Max Levine and Tony Foley began to stop emailing Plaintiff and stopped informing Plaintiff on deals in the pipeline. In the beginning every email flowed through Plaintiff, now this data was a trickle.

43. On June 10th, 2010 Defendant Max Levine notified Plaintiff in a call that he just received a $7000 check from one of Sales Sources clients in the diabetic arena.

44. Plaintiff had no idea that a client existed or that the companies were generating revenues. Plaintiff had asked many times and was told no.

45. On June 12th, 2010 Plaintiff and Defendant Max Levine spoke on the telephone and Plaintiff notified Defendant that due to the fact that a job was hid from him he would no longer work with Defendants Max Levine and Tony Foley or the businesses that they formed under the training of the Plaintiff.

46. Defendant Max Levine agreed and told Plaintiff that he would be compensated for his training and business model. Plaintiff was told that he would receive payment from every client and equity in every business that Defendants Max Levine and Tony Foley started with Plaintiffs intellectual property and training.

47. Plaintiff would regularly check in with Defendants Max Levine and Tony Foley to see if they had closed any business deals and would receive denials.

48. On June 24, 2011 Defendant Max Levine sent Plaintiff an email stating,

"I have gotten in to a totally different line of business"

Exhibit H

49. Defendant claimed his new venture had absolutely nothing to do with the business models and contacts Plaintiff provided.

Exhibit H

50. On Sept 4, 2011 Defendant Max Levine sent Plaintiff an email stating,

"Darren, Salessource is not operating any longer. It did not and has not made any money. "

Exhibit I

51. On September 11, 2011 Defendant sent Plaintiff an email stating Defendants did not make any money from Plaintiffs contacts, training and / or business model and that Defendants had lost monies and that Sales Source had been closed.

"I have lost most of my money, I have had to take my kids out of school, move out of my house in SF and move to Alabama. I drive a 14 year old car. Trust me if I was making money: 1) I would have taken care of you if you helped me get there 2) I would buy a new car."

52. These statements are contradicted by numerous on line job postings Defendant had posted online looking for employees for Smart Remedies which is located in Alabama. The Defendant was growing a large business and relocated, Defendant Max Levine nor his children were struggling at all.

53. On October 19, 2011 Defendant Tony Foley sent Plaintiff an email claiming to not have made any money while working with Defendant Max Levine.

"I never made any money from this project either.

Also I no longer work with max."

Exhibit J

54. This Statement by Defendant Tony Foley is completely contradicted by a statement he made on his website http://narassociation.com, which the Plaintiff discovered in 2014.

"I first co-founded Salessource a marketing company that focused on online lead generation. I then co-founded a cutting edge diabetic supply company called Smart Remedies (now a multi-million dollar company). I exited this company in late 2011 and got involved in several business including Adzoo, Taskrabbit, CIsimple a continuous integration company, and other high tech startups. "

Exhibit K

55. In 2012 Plaintiff discovered that Defendants Max Levine and Tony Foley had started a business "Smart Remedies". Smart remedies is located in Opelika Alabama and sells hand held blood glucose meters and targets Medicare recipients. This product is identical to the product that Defendant Max Levine and Chris Byers from Arriva Medical discussed.

56. Defendants Max Levine and Tony Foley started a business from the contacts that Plaintiff provided them while working together with Sales Source and LACC.

Defendants Max Levine and Tony Foley conspired and hid Smart Remedies from Plaintiff.

57. In 2012 Plaintiff filed a lawsuit in Superior Court in Sonoma County SCV 251254

Ferguson V Levine, Foley, Smart Remedies and Latin American Call Center

58. Defendant Max Levine's attorney stated that Sales Source had closed and that Defendant was out of the call center industry

Exhibit L- other claims

59. Defendant Max Levine's attorney stated Sales Source incurred a debt of $700,000 and if Plaintiff were to prevail in lawsuit Plaintiff would be liable for half of the debt if Plaintiff won the case.

Exhibit L

60. Plaintiff settled case with Defendants and soon thereafter Defendants Max Levine and Tony Foley began to update their social networking sites with the information they hid from Plaintiff and lied about in litigation.

61. These statements contract Defendant Max Levine and Tony Foley's statements prior to and during litigation.

Defendant Max Levine proudly states that he Sales Source does in fact exist and he is a board member.

"He is also a Board Member of Sherwood Design Engineers, an International Green

Civil Engineering firm, SalesSource Marketing Services, a lead generation company and World Support, a property Management company."

Exhibit M

62. Defendant Max Levine also contradicts many facts that Plaintiff has alleged.

Business is good, he and his companies are making a lot of monies and they are in the exact same industries that Plaintiff trained them in.

63. Defendant Max Levines Linkedin post proves that he conspired to hide information from Plaintiff.

64. Plaintiff notified Defendants attorney that Defendant had proven that he lied in litigation with these post.

Soon thereafter Defendant's post were deleted from Linkedin and this theme continues to date.

65. Defendant Max Levine has put up many post on Linkedin that contradict his prior statements. Once Defendant Max Levine finds out that Plaintiff had discovered the postings Defendant Max Levine would delete the post.

66. In 2013 Plaintiff filed another lawsuit SCU 254143 Ferguson V Levine, Foley, Cal City Medical Supplies DBA Smart Remedies and Latin American Call Center to overturn the settlement based on the lies that Defendant Max Levine stated during litigation.

67. In an attempt to show Plaintiff that Defendant Max Levine actually lost money, Defendant Max Levine's attorney mailed Plaintiff Sales Source's 2011 tax returns.

Exhibit N

68. Sales Source's 2011 tax returns contradict Defendant Max Levine and Tony Foleys emails claiming to have not generated revenues, they actually generated $136,9000

69. Sales Sources 2011 tax return contradicts Defendant Max Levine's attorney claim that sales source lost $700,000. Nothing was lost, the business was growing fast and had business expenses of $433,866.

70. Sales Sources 2011 tax return prove Sales Source had generated significant revenues and that Defendants Max Levine and Tony Foley are guilty of many criminal and civil crimes.

71. Defendant Max Levine and Tony Foley's actions were premeditated.

72. Defendants conspired to take advantage of Plaintiff who was suffering from a head injury.

73. Defendant Max Levine and Tony Foley have started many businesses from the jobs they hid from Plaintiff in the USA and abroad and are in violation of many national and international Intellectual property laws.

74. Plaintiff continues to discover new companies that Defendant Max Levine and Defendant Tony Foley have started and not compensated Plaintiff for his contributions, they have lied. This entire venture was conspired by the defendants to not compensate plaintiff for his contributions.

First Cause of Action

(Misappropriation of Trade Secrets against all Defendants and DOES 1-100)

75. Plaintiff hereby incorporates by reference and realleges each of the allegations contained in the foregoing paragraphs 1-xxx, inclusive, as though fully set forth in this cause of action.

76. At all relevant times, Plaintiff was in possession of trade secret information as defined by California's Uniform trade Secrets Act ("UTSA"), Civil Code section 3426.1(d).

77. As described above Defendants were provided access to such trade secrets as co Founders.

78. The proprietary business trade secrets and business models that were shared with Defendants constitutes trade secrets because Plaintiff, as described herein, derives independent economic value from that information, such information is not generally known nor readily ascertainable by proper means by other persons who can obtain economic value from its disclosure or use, and because the information in the subject of reasonable efforts to maintain its secrecy.

79. Plaintiffs trade secret information described herein is not and was not generally known to Plaintiffs competitors in the industry.

80. Plaintiff is informed and believes and therefore alleges that Defendants have actually misappropriated and continues to threaten and misappropriate Plaintiffs trade secrets in violation of CUTSA.

81. As a result of Defendants high level position as co Founders Defendants had access to Plaintiff's most valuable trade secrets. Defendants continues to have knowledge of that information, notwithstanding the fact that Defendants are still in business while hiding it from Plaintiff.

82. Defendants have and will continue to wrongfully use Plaintiff's trade secrets unless enjoined. Despite many attempts by Plaintiff to be compensated Plaintiff has yet to be told the truth.

83. Because Plaintiff's remedy at law is inadequate, Plaintiff seeks temporary, preliminary and permanent injunctive relief. Plaintiff is threatened as Defendants continue to use trade secrets and continue to deny using them.

84. Defendants actual and threatened misappropriation has been willful and malicious and intentional therefore Plaintiff is entitled to an award of punitive or treble damages and attorney's fees pursuant to Civil Code sections 3426.3(c) and 3426.4

Second Cause of Action

Intentional Misrepresentation

(Against Max Levine, Tony Foley, Sales Source, LACC, Smart Remedies)

85. Plaintiff incorporates by reference and re alleges each and every allegation set forth in the foregoing complaint as though fully set forth herein.

86. Max Levine and Tony Foley intentionally misrepresented the truth by telling Plaintiff that Sales Source and LACC were out of business.

87. The Defendant made these representations knowing them to be false and made these statements with reckless disregard as to their truth or falsity.

88. Max Levine intentionally misrepresented the truth in an attempt to induce my reliance on the misrepresentation.

89. Plaintiff relied on these misrepresentations and acted on behalf of these misrepresentations. Plaintiff would have litigated against the Defendants if Defendants were intentionally not being truthful.

90. Plaintiff is justified in his reliance of these misrepresentations and would not have pursued legal recourse had Plaintiff known the truth.

91. Due to Plaintiff's reliance on these intentional misrepresentations, Plaintiff sustained damages.

THIRD CAUSE OF ACTION

Fraud in the Inducement

(Against Max Levine)

92. Plaintiff incorporates by reference and re alleges each and every allegation set forth in the foregoing paragraphs as though fully set forth herein.

93. Defendant Max Levine intentionally made false statements regarding his intention of compensating Plaintiff for his contributions. Defendant told Plaintiff that he would receive equity for all the companies Plaintiff help start.

94. These misrepresentations were material to Plaintiff's decision to enter into our contract.

95. Plaintiff relied on these misrepresentations and believed them to be true.

96. Plaintiff would not have entered into contract if Plaintiff was aware that these statements were false, intentional and an attempt to steal the Plaintiffs trade secrets and intellectual property.

97. Max Levine falsely stated that he had never made any money with Sales Source.

98. Max Levine falsely stated that no revenues had flowed through his call center business.

99. Due to Plaintiff's reliance on intentional false statements, Plaintiff sustained significant damages.

FOURTH CAUSE OF ACTION

Intentional Deceit

(Against Max Levine, Tony Foley, Sales Source, Smart Remedies, LACC)

100. Plaintiff incorporates by reference and re alleges each and every allegation set forth in the foregoing paragraphs as though fully set forth herein.

101. Defendants Max Levine Tony Foley intentionally concealed the fact that they were still in the call center business and using Plaintiffs trade secrets.

102. Plaintiff was told this arena was defunct due to losses.

103. This was a key material fact to Plaintiff and Defendants Max Levine and Tony Foley were aware that these statements that they were out of the call center industry and not using Plaintiff's trade secrets was false.

104. Defendants lied and concealed the truth from Plaintiff intentionally so they would not have to compensate him.

105. Defendants intent was to induce Plaintiff to think Defendants had not made any money and were out of business.

106 If Plaintiff was aware of this concealment, Plaintiff would have litigated much earlier.

107 Plaintiff relied on Defendant Max Levine and Tony Foley's statements and Plaintiffs decisions were based on these statements that proved to be false.

108. Plaintiff would have not have agreed to partner with Defendants and share all his Trade Secrets and intellectual property if he had been aware of the truth, that Defendants were concealing jobs and businesses Plaintiff helped secure.

109. Due to Plaintiff' being unaware of this concealment, Plaintiff sustained damages.

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