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					                                                           IN THE CIRCUIT COURT OF THE 9th
                                                              JUDICIAL CIRCUIT IN AND FOR
                                                                ORANGE COUNTY, FLORIDA

                                                                                CIVIL DIVISON

                                                                                     CASE NO.:



FRANCES CAMILLE ROSS, JOHN
PATRICK ROSS, WINSTON JAMES
HUNTER, BRIAN DUNN, MARK HENRY
And SEAN BELCHER
             Plaintiffs
     vs.
HALLMARK BANK & TRUST LTD., a
foreign corporation, BRIAN TROWBRIDGE,
a foreign citizen, MASTERCARD
INTERNATIONAL INCORPORATED, a New
York corporation, MASTERCARD
INTERNATIONAL, LLC, a Delaware
Corporation, DAVID SMITH, a foreign
citizen, WAYNE SMITH, a foreign citizen,
OVERSEAS LOCKET INTERNATIONAL
CORPORATION, a foreign corporation, THE
TURKS AND CAICOS ISLANDS
INVESTMENT AGENCY, a foreign
corporation, and MICHAEL MISICK, a
foreign citizen, ISAAC MARTINEZ, a Florida
resident, and JARED MARTINEZ, a Florida
resident, JIJ INVESTMENTS, LLC, a Florida
Corporation, I TRADE FX, LLC, a Florida
Limited Liability Corporation, I-TRADE FX
INTERNATIONAL, INC., a Florida
Corporation, and PROFESSIONAL FOREX
ASSOCIATION, INC, a Florida Corporation
Defendants
_____________________________________/

                                         COMPLAINT

      Plaintiffs, FRANCES CAMILLE ROSS (“Frances Ross”), JOHN PATRICK ROSS (“John

Ross”), WINSTON JAMES HUNTER (“Hunter”), BRIAN DUNN (“Dunn”), MARK HENRY

(“Henry”) and SEAN BELCHER(hereinafter collectively “Plaintiffs”), by and through undersigned

counsel, files this, their Complaint against Defendants HALLMARK BANK & TRUST LTD.

(hereinafter “HALLMARK”), BRIAN TROWBRIDGE (hereinafter “TROWBRIDGE”),
MASTERCARD INTERNATIONAL INCORPORATED and MASTERCARD INTERNATIONAL

LLC (together “MASTERCARD”), DAVID SMITH (hereinafter “SMITH”), OVERSEAS LOCKET

INTERNATIONAL CORPORATION (hereinafter “OLINT”), THE TURKS AND CAICOS ISLANDS

INVESTMENT AGENCY (hereinafter “TCII”), MICHAEL MISICK (hereinafter “Misick”), ISAAC

MARTINEZ and JARED MARTINEZ (hereinafter “Defendants Martinez”), and JIJ INVESTMENTS,

LLC (hereinafter “JIJ”), I TRADE FX, LLC (hereinafter “I-TRADE”), I-TRADE FX

INTERNATIONAL, INC. (hereinafter “I-TRADE INT.”), and PROFESSIONAL FOREX

ASSOCIATION, INC (hereinafter “PFA”) (collectively referred to as “Defendants”), and alleges as

follows:

                               PARTIES, JURISDICTION, AND VENUE

   1. Plaintiff, Frances Camille Ross is a citizen of Jamaica and currently resides in Kingston,

       Jamaica.

   2. Plaintiff, John Patrick Ross is a citizen of Jamaica and currently resides in Kingston, Jamaica.

   3. Plaintiff, Winston James Hunter is a citizen of Jamaica and currently resides in Kingston,

       Jamaica.

   4. Plaintiff, Brian Dunn is a resident of the United States and currently resides in South Miami,

       Florida.

   5. Plaintiff, Mark Henry is a citizen of Jamaica and currently resides in Kingston, Jamaica.,

       Plaintiff Sean Belcher is a resident of Florida.

   6. Defendant, Hallmark Bank & Trust, LTD., a foreign corporation based in the Turks & Caicos

       and, based upon information and belief, has significant business contacts with the state of

       Florida as explained in greater detail below.

   7. Defendant, Brian Trowbridge, a foreign citizen, is a principal of HALLMARK and, based upon

       information and belief, has significant business contacts with the state of Florida as explained in

       greater detail below.
8. Defendant, MasterCard International Incorporated, is a New York corporation, maintains a

   wholly owned Limited Liability Corporation and a Florida registered agent based in Broward

   County, Florida, as well as has significant business contacts with the state of Florida.

9. Defendant, MasterCard International LLC, is a Limited Liability Corporation owned by

   MasterCard International Incorporated, maintains an address in Broward County, Florida for

   service of process purposes.

10. Defendant, David Smith, a foreign citizen, is the principal of OLINT and HALLMARK and,

   based upon information and belief, has significant business contacts with the state of Florida as

   explained in greater detail below.

11. Defendant, Wayne Smith, a foreign citizen, is a principal of OLINT and, based upon

   information and belief, has significant business contacts with the state of Florida as explained in

   greater detail below.

12. Defendant, OLINT, is a foreign corporation organized under the laws of Jamaica, and operating

   out of the Turks & Caicos and, based upon information and belief, Florida. The Jamaican

   operations of OLINT, based upon information and belief, were being run by Wayne Smith,

   David Smith's brother.

13. Defendant, TCII, is a foreign agency located in the Turks and Caicos which encourages foreign

   investment in the Turks & Caicos islands.

14. Defendant, MISICK, is a citizen of the Turks and Caicos, and until his recent resignation, was

   the Premier of the Turks and Caicos Islands.

15. Defendants, Isaac Martinez and Jared Martinez, are United States Citizen and, upon information

   and belief, operate various business entities out of the state of Florida, jointly and separately,

   and own property in Orange County, Florida.

16. Defendants JIJ, PFA, I-TRADE, and I-TRADE INT., are a Florida Corporations based out of

   Orange County, Florida and run by Defendants Martinez.
17. This is an action seeking damages in excess of $15,000.

18. This court has jurisdiction over Defendant HALLMARK, because, based upon information and

   belief, they have committed a tort, in whole or in part, have sent written materials and card

   products to residents of Florida, or have otherwise transacted business in the State of Florida.

19. This court has jurisdiction over Defendant, TROWBRIDGE, because, upon information and

   belief, said Defendant as principal for HALLMARK was responsible for sending materials and

   card products to Florida, and has committed a tort, in whole or in part, or has otherwise

   transacted business in the State of Florida as described in greater detail below.

20. This court has jurisdiction over Defendants MASTERCARD, as, upon information and belief,

   said Defendants were transact significant business with residents of Florida, send mail to and

   receive mailed applications from Florida, and send card products to residents of Florida,

   maintain a location for service of process within Florida, and said Defendants have committed a

   tort, in whole or in part, or have otherwise transacted business in the State of Florida as

   described in greater detail below.

21. This court has jurisdiction over Defendant David Smith, because, upon information and belief,

   said Defendant was operating a business of foreign currency trading, at least in part, from

   Orlando, Florida, and said Defendant has committed a tort, in whole or in part, or has otherwise

   transacted business in the State of Florida as described in greater detail below.

22. This court has jurisdiction over Defendant Wayne Smith, because, upon information and belief,

   said Defendant was assisting the operation of a business of foreign currency trading, and said

   Defendant has committed a tort, in whole or in part, or has otherwise transacted business in the

   State of Florida as described in greater detail below.

23. This court has jurisdiction over Defendant, OLINT, as, upon information and belief, said

   Defendant was operating a business of foreign currency trading in Orlando, Florida, and said

   Defendant has committed a tort, in whole or in part, or has otherwise transacted business in the
   State of Florida as described in greater detail below.

24. This court has jurisdiction over Defendants TCII and MISICK, because they were active in the

   scheme, described in more detail below, the scheme which was linked with Plaintiffs based in

   Orange County, Florida, and said Defendants have otherwise committed a tort, in whole or in

   part, or has otherwise transacted business in the State of Florida as described in greater detail

   below.

25. This court has jurisdiction over Defendants MARTINEZ, because they own both business

   entities, based in Orange County, Florida, and real property in Orange County, Florida. In

   addition, upon information and belief, they have committed a tort, in whole or in part, or have

   otherwise transacted business in Orange County and the State of Florida.

26. This court has jurisdiction over Defendants JIJ, I-TRADE, I-TRADE INT, and PFA, because

   they are Florida Corporations operated from Orange County, Florida. In addition, based upon

   information and belief, they have committed a tort, in whole or in part, or have otherwise

   transacted business in Orange County and the State of Florida.

27. Venue is proper in this district as one or more of the individual defendant entities lives within

   Orange County, one or more of the individual Defendants is operates a business from Orange

   County, Florida, one or more of the individual Defendants maintains a location for service of

   process within Orange County, and at least one or more of the individual Defendant business

   entities was created in Orange County Florida. Furthermore, Defendants had systematic and

   significant contacts with Orange County, Florida.

28. All conditions precedent to the filing of this action have occurred, been performed, been waived

   or are otherwise excused.

                                 GENERAL ALLEGATIONS

30. Defendant HALLMARK is a banking institution operating out of the Turks & Caicos.

   HALLMARK offers MasterCard card products and conspicuously displays the MasterCard
        logo1, and proudly proclaims their alliance with MasterCard.

    31. Defendant TROWBRIDGE is an attorney operating out of the Turks & Caicos and also serves

        as Director, CEO and Chairman of HALLMARK.2

    32. Defendant, OLINT, and OLINT'S principals, Defendant David SMITH, invests in foreign

        currency exchange trading through various trading platforms (called “FOREX”). Although

        OLINT was a Jamaican corporation, OLINT operated their FOREX trading mainly in the Turks

        & Caicos. Defendant Wayne Smith, David Smith's brother, generally handled OLINT'S business

        in Jamaica (advertising, prospective client meetings and sign-ups, etc.) when David Smith was

        in the Turks & Caicos. As early as 2006, OLINT had announced that it would transfer part of its

        FOREX trading business to Orlando, Florida.3

    33. HALLMARK and OLINT signed an operating agreement whereby HALLMARK agreed to

        operate as a conduit to funnel money from investors into an “investment club,” in this case

        OLINT. Essentially investors [including Plaintiffs] would remit funds to HALLMARK at which

        time HALLMARK would remit the funds to OLINT. [See OPERATING AGREEMENT.

        Attached hereto as “Exhibit A.”]

    34. HALLMARK, and/or their principals and agents, traveled to Jamaica to recruit investors for

        this scheme, and co-signed multiple account agreements with investors while in Jamaica.

    35. TROWBRIDGE was paid over $300,000 for his dealings with OLINT and SMITH and was

        unjustly enriched4.

    36. Due to the aggressive advertising of the high rate of returns that Defendants engaged in,



1 Cf. Hallmark Bank & Trust's website which displays the MasterCard logo prominently:
  HTTP://www.hallmarktrust.com/ [last accessed 03/26/09]. Hallmark's website also states “Hallmark is also a principal
  member of MasterCard Worldwide. Hallmark Bank & Trust Ltd. issues the Horizon standard and gold MasterCard.” and
  maintains another website giving more details regarding their card products at www.horizoncard.tc.
2 See TROWBRIDGE'S attorney profile http://www.swannlaw.tc/attorneys.html and the “About Us” page at Hallmark
  Trust HTTP://www.hallmarktrust.com/aboutus.php [both last accessed 03/26/09].
3 Cf. “Olint spreads its wings” published in the Jamaica Gleaner News on April 26, 2006. http://www.jamaica-
  gleaner.com/gleaner/20060428/business/business7.html [Last accessed February 25, 2009].
4 TROWBRIDGE admits to receiving these funds in relation to his work for OLINT.
   Plaintiffs decided to invest large amounts of money in OLINT. At the time of the initial

   investment, principals or agents of OLINT proposed that Plaintiffs invest with assurances that

   they could have access to their money at any time through OLINT's online accounting website

   (the “website”).

37. Plaintiffs were also further encouraged to invest because Defendants MASTERCARD endorsed

   Defendant HALLMARK'S business by partnering with them to offer card products.

   MASTERCARD'S reputation created a situation that made HALLMARK appear to be a strong

   and legitimate banking institution, which further induced multiple investors, including

   Plaintiffs, to feel more secure about investing with OLINT.

38. Defendants MASTERCARD were third-party beneficiaries to HALLMARK'S involvement

   with OLINT, SMITH's, and MARTINEZ'S fraudulent activities.

39. Defendants MASTERCARD are still affiliated with HALLMARK despite their business

   practices and HALLMARK is still using the MASTERCARD name and reputation to gain

   clients.

40. Plaintiffs signed an agreement with Defendant OLINT; the terms of same would govern

   Plaintiffs' account with OLINT. This agreement was co-signed by OLINT [SMITH was the

   actual signatory, being principal of OLINT] and HALLMARK. OLINT and HALLMARK are

   equally liable for damages to Plaintiffs.

41. Plaintiffs entered into agreements with representatives from OLINT and were provided terms

   that apply to the accounts (the “Agreement”) with OLINT, to open accounts whereby OLINT

   was to invest Plaintiffs' funds in foreign currency exchange trading. Based upon the Agreement

   and other representations made by Defendants SMITH and OLINT, and their principals,

   Plaintiffs were to receive a significant return on their respective investment.

42. Plaintiffs were promised that they would be able to access their account information through

   OLINT'S interactive website, including access for deposits, withdrawals, and the general
        monitoring of their accounts as more fully described below.

    43. Plaintiffs made deposits to their accounts at OLINT and were continually promised full access

        to their money, including the ability to withdrawal it fully, if they so desired.

    44. Plaintiffs deposited significant sums of money, including, but not limited to, Hunter depositing

        $85,500, John Ross depositing $773,372.23, Frances Ross depositing $237,617.06, Dunn

        depositing $20,000, and Henry depositing $89,400, Belcher depositing in excess of 1.2 million

        dollars.

    45. Defendant TCII is an independent governmental agency that is mandated to attract offshore
                                                                                                 5
        investment to the Turks and Caicos Islands. Conrad C. Higgs was the CEO of TCII.             TCII

        encouraged investors, some based in Florida, to invest in companies located in, and within the

        islands of the Turks and Caicos. In addition, TCII did nothing to discourage investors from

        investing in OLINT and HALLMARK before or after their fraudulent behavior and business

        practices came to light.

    46. Defendant MISICK was the first Premier of the Turks and Caicos. Defendant MISICK, by

        virtue of his political position was also the Minister for the Commerce and Development and

        The Turks and Caicos Island Investment agency. As Minister to TCII, and in other capacities,

        MISICK encouraged investors, some based in Florida, to invest in companies located in, and

        within the islands of the Turks and Caicos. In addition, MISICK did nothing to discourage

        investors from investing in OLINT and HALLMARK before or after their fraudulent behavior

        and business practices came to light.

    47. The governor of the Turks and Caicos, upon suspicion of corruption within the government,

        requested a Commission of Inquiry be dispatched from London, with The Right Honorable Sir

        Robin Auld serving as the Commissioner of Inquiry. Sir Auld was tasked with investigating the

        corruption charges, levied at MISICK himself, members of his immediate and extended family,

5 See “About Us” HTTP://www.tcinvest.tc/tcinvest.htm [last accessed 03/29/2009].
       among others.

   48. Sir Robin Auld's report suggested that there was “systemic” corruption within the government

       of the Turks & Caicos and suggested that the Constitution of the Turks and Caicos be partially

       suspended, with governmental duties being handled by the British.

   49. Upon the release of the report, MISICK resigned his political position.6

   50. Plaintiffs repeatedly made written and oral requests for the withdrawal of Plaintiffs' funds, to

       Defendant OLINT, and several principles and employees of same, in accordance with the terms

       of Plaintiffs' Agreement.

   51. Notwithstanding such demands by Plaintiffs, OLINT has failed to respond to Plaintiffs' requests

       for the withdrawal of the Plaintiffs' funds, in breach of the Agreement.

   52. Upon information and belief, Defendants OLINT and David Smith sent multiple wire transfers

       to the United States, through defendant bank HALLMARK and others, to Defendants

       MARTINEZ, in order to evade the Jamaican and Turks & Caicos authorities that were

       investigating OLINT and SMITH'S business practices.

   53. Also upon information and belief, multiple wire transfers totaling roughly $100 million from

       OLINT and/or SMITH were sent to the United States, at least part of which to defendants

       MARTINEZ, and based upon information and belief, HALLMARK was involved in wire

       transfers to and from OLINT and SMITH.

   54. Defendants MARTINEZ operated their own FOREX trading business out of Orange County,

       Florida by such names as JIJ INVESTMENTS, I TRADE FX, and PROFESSIONAL FOREX

       ASSOCIATION, INC.7Defendants MARTINEZ had traveled to Jamaica on multiple occasions


6 See “Turks and Caicos Premier Michael Misick resigns as Britain prepares to seize control”
  HTTP://www.timesonline.co.uk/tol/news/world/article5964728.ece [Last accessed 03/29/09].
7 See
  http://www.sunbiz.org/scripts/cordet.exe?action=DETFIL&inq_doc_number=P07000081283&inq_came_from=OFFFW
  D&cor_web_names_seq_number=0003&names_name_ind=P&ret_names_cor_number=&ret_cor_web_names_seq_nu
  mber=&ret_names_name_ind=&ret_names_comp_name=&ret_names_filing_type=&ret_cor_web_princ_seq=&ret_prin
  c_comp_name=MARTINEZISAAC&ret_princ_type=
   to acquire clients and knew defendants SMITH personally. Defendants MARTINEZ are under

   criminal investigation in multiple jurisdictions for fraudulent activity and were investigated by

   the NFA for failing to report suspicious activities relating to receiving such large amounts of

   money from SMITH and OLINT to the NFA.

55. Upon information and belief, MARTINEZ used the funds transferred to them from OLINT

   and/or SMITH to invest in several parcels of real property and business entities in and around

   Orange County, Florida.

56. Plaintiffs never authorized the transfer of funds from their accounts at OLINT to any other

   person or business entity. The money wire transfer to defendants MARTINEZ, and unknown

   others, was done without knowledge or permission from Plaintiffs.

57. Based upon information and belief, principals from OLINT and HALLMARK, including but

   not limited to, SMITH and TROWBRIDGE conspired to defraud investors, including Plaintiffs,

   and HALLMARK, TROWBRIDGE, and defendants MARTINEZ were instrumental in

   laundering money for OLINT and defendants SMITH.

58. Defendant David Smith and OLINT chartered Learjet’s and various other private aircraft to fly

   between Jamaica and the Turks and Caicos, the Turks and Caicos and the United States, and

   various other destinations, at least partly in furtherance of the scheme. The funds to pay for the

   charter of the aircraft came from the accounts of clients, including Plaintiffs.

59. Plaintiffs never authorized the transfer of funds from their accounts at OLINT to fund private

   air travel. The charters were done without knowledge or permission from Plaintiffs.

60. Based upon information and belief, Defendant David Smith plundered the accounts of

   customers, including Plaintiffs, to fund his gambling excursions to the casinos of the Turks and

   Caicos.

61. Plaintiffs never authorized the transfer of funds from their accounts at OLINT to fund

   Defendant David Smith's gambling. The gambling was done without knowledge or permission
       from Plaintiffs.

   62. Defendants have refused the repeated requests to return Plaintiffs' money.

   63. Upon information and belief, OLINT'S principals have fled Jamaica to avoid the Jamaican

       authorities and have absconded with Plaintiffs' funds and deposited and/or invested them into

       several entities, including entities owned by Defendants MARTINEZ, with the intent to hinder,

       delay, or defraud Plaintiffs' efforts to recover their funds with the assistance of HALLMARK

       and TROWBRIDGE.

   64. Defendant SMITH has been arrested, in the Turks & Caicos, for his involvement in OLINT'S

       fraudulent activities and charged with fraud. 8

   65. By this action, Plaintiffs are seeking to recover the principal and profit of their accounts with

       OLINT. According to the terms of the Agreement, OLINT was to use Plaintiffs' funds for

       foreign currency exchange trading. HALLMARK and TROWBRIDGE are equally responsible

       for the mis-dealings of OLINT and SMITH because they co-signed Plaintiffs' Agreement.

       Defendants MARTINEZ'S actions have assisted the furtherance of this scheme, personally and

       through their various business entities such as JIJ, PFA, I-TRADE, and I-TRADE INT.

       However, due to Defendants' fraudulent misconduct, Plaintiffs have lost access to their funds

       and/or have completely lost the money in their accounts, and as a result have suffered

       substantial damages.

   66. Plaintiffs are also seeking damages for OLINT and HALLMARK'S breach of the Agreement by

       failing to honor requests made by Plaintiffs for the withdrawal of their funds, depriving Plaintiff

       of his property for an indefinite period of time, which resulted in OLINT, HALLMARK, and

       their principals (including Defendants SMITH and TROWBRIDGE) being unjustly enriched.

   67. Plaintiffs are also seeking treble damages, especially in light of Defendant David Smith's usage

8 See Jamaica Observer article “Smith Arrested,” published Feb. 6, 2009.
  HTTP://www.jamaicaobserver.com/news/html/20090206T010000-0500_145834_OBS_SMITH_ARRESTED.asp [last
  accessed 03/29/09]
   of Plaintiffs' funds to charter aircraft for his personal use and gain, and also the usage of

   Plaintiffs' funds to fund his many visits to the casinos of the Turks and Caicos.

68. Plaintiffs have had to hire the undersigned attorney in an attempt to recover their funds, and

   have had to pay attorney's fees for same.

69. Plaintiffs have suffered losses of over $1.20 million in principal alone due to the misconduct of

   Defendants.

                                     COUNT I
                 CIVIL RICO PREDICATED UPON MAIL AND WIRE FRAUD
                 PURSUANT TO CHAPTER 895 OF THE FLORIDA STATUTES



70. Plaintiffs reassert and re-allege the allegations set forth in paragraphs 1 through 69 as though

   fully set forth herein.

71. This is an action for civil RICO predicated upon mail and wire fraud against all Defendants

   pursuant to Chapter 895 of the Florida Statutes.

72. Defendants intentionally participated in this scheme to defraud Plaintiffs of both money and

   property.

73. Defendants carried out the scheme by means of material misrepresentations regarding OLINT,

   and the aforementioned returns on Plaintiffs' investment, Plaintiffs' access to principal and

   profit, and other such benefits continuing through the present time, both orally and through

   various documents, through the Website, and through emails from OLINT.

74. Defendants through their principals and agents, including Defendants SMITH, used both the

   United States mail and United States wires to effectuate the scheme. Beginning in or about early

   2007, Defendants used the mail to send OLINT related information, to obtain monies from

   Plaintiffs, and to aid in the inducement of additional investment in OLINT. In addition,

   Defendants, through their principals, including Defendants SMITH, made extensive use of the

   United States wires in connection with the scheme in several ways, including but not limited to:
   telephonic conversations with Plaintiffs, in which misrepresentations were made, the use and

   transferring of funds paid by Plaintiffs, especially the wire transfer to Defendants MARTINEZ,

   and the misrepresentations made through the website and emails of OLINT, as part of

   Defendants' continued scheme to defraud.

75. Defendants TCII, MISICK, and MARTINEZ were aware [or became aware] of OLINT'S,

   SMITH'S, and/or HALLMARK'S activities and business practices and did nothing to

   discourage investors from investing in the scheme.

76. Defendants Martinez accepted incoming wire transfers, in furtherance of the conspiracy after

   they were aware that the fraud was ongoing in order to allow defendants OLINT and SMITH to

   dispose of monies located in accounts with defendant HALLMARK, among other accounts,

   before they were seized by the authorities in the Turks and Caicos.

77. Defendants MARTINEZ knew of the incoming wire transfers and did not report them to the

   NFA, as is standard policy in the FOREX industry.

78. Defendants committed a number of overt acts that constitute sufficient racketeering activity in

   furtherance of the conspiracy including but not limited to:

       a. Making misrepresentations through their agents both verbally and through materials

       provided to Plaintiffs including misstatements as to the accessibility of their investment, its

       purpose, and return thereon, as follows:

           I. Defendants, and their agents, falsely represented and warranted that Plaintiffs would

           have continued access to their investments via OLINT'S online portal, which would

           allow Plaintiffs to monitor, adjust, and withdrawal their investments immediately;

           II. Defendants, and their agents, falsely represented and warranted that Plaintiffs'

           investment would be used for foreign currency exchange trading. Upon information and

           belief, Defendant OLINT'S principals, including Defendants SMITH, have absconded

           with Plaintiffs' funds and/or transferred them into affiliated entities or to affiliated
           parties, including defendants HALLMARK and defendants MARTINEZ, for personal

           gain and/or with the intent to hinder, delay, or defraud Plaintiffs' efforts to recover their

           funds and based upon information and belief, HALLMARK and defendants

           MARTINEZ assisted OLINT in laundering and/or transferring money from OLINT after

           they were made aware of OLINT'S true business practices; and

           III. Defendants OLINT, SMITH and HALLMARK, and their agents, falsely represented

           and warranted that Plaintiffs would receive a significant return on their investment.

           However, Defendant OLINT never intended to return Plaintiffs' funds and has created an

           elaborate suspension of operations to avoid same and delay/escape suspicion of their

           actions.

   b. causing Plaintiffs to enter into an agreement and requiring Plaintiffs to provide Defendants

   with large sums of money to invest in OLINT;

   c. denying Plaintiffs access to their funds and/or accounts and records through the actions of

   Defendants, and/or their principals or agents;

   d. through the actions of Defendants, and/or their principals or agents, misrepresenting to

   Plaintiffs the status of OLINT and/or their investments in same to prevent them from

   discovering the fraud; and

   e. acting in concert with one another to continue the concealment of their fraudulent conduct.

79. Defendants have derived income, and continue to derive income, from their racketeering

   activities as described above.

80. Plaintiffs reasonably relied on Defendants' misrepresentations, which contained false

   representations and warranties that reasonably induced Plaintiffs to “invest” in OLINT.

81. As a consequence of Plaintiffs' reasonable reliance, Plaintiffs have suffered, and continue to

   suffer, injuries and damages.

82. Plaintiffs have retained undersigned counsel and are obligated to pay their attorney a reasonable
       fee. Pursuant to Chapter 895 of the Florida Statutes, Plaintiffs are entitled to recover their

       attorney's fees from Defendants in this action.



       WHEREFORE, Plaintiffs respectfully requests this Court enter judgment in their favor and

against Defendants, awarding Plaintiff damages, including but not limited to, treble damages, together

with interest, reasonable attorney's fees and costs and any other such remedy as this Court deems

necessary.

                                                 COUNT II
                                          FRAUDULENT CONVEYANCE

   83. Plaintiffs reassert and re-allege the allegations set forth in paragraphs 1 through 69 as though

       fully set forth herein.

   84. This is an action for fraudulent conveyance pursuant to Chapter 726 of the Florida Statutes

       against all Defendants.

   85. Defendant OLINT, and their agents and principals, including Defendant SMITH, knowingly

       made misrepresentations of material fact that induced Plaintiffs to remit funds to OLINT for the

       Defendant's financial gain and Defendants MARTINEZ, or their business entities, did not reject

       or report the transfers even after knowing the source of the transfers. Defendants HALLMARK,

       MISICK, and TCII continued to encourage investment in OLINT. These misrepresentations

       include, but are not limited to:

             a. Making misrepresentations through their agents both verbally and through materials

             provided to Plaintiffs including misstatements as to the accessibility of their investment, its

             purpose, and return thereon, as follows:

                I. Defendants, and their agents, falsely represented and warranted that Plaintiffs would

                have continued access to their investments via OLINT'S online portal, which would

                allow Plaintiffs to monitor, adjust, and withdrawal their investments immediately;
           II. Defendants, and their agents, falsely represented and warranted that Plaintiffs'

           investment would be used for foreign currency exchange trading. Upon information and

           belief, Defendant OLINT'S principals, including Defendants SMITH, have absconded

           with Plaintiffs' funds and/or transferred them into affiliated entities or to affiliated

           parties, including defendants HALLMARK and defendants MARTINEZ, for personal

           gain and/or with the intent to hinder, delay, or defraud Plaintiffs' efforts to recover their

           funds and based upon information and belief, HALLMARK and defendants

           MARTINEZ assisted OLINT in laundering and/or transferring money from OLINT after

           they were made aware of OLINT'S true business practices; and

           III. Defendants OLINT, SMITH and HALLMARK, and their agents, falsely represented

           and warranted that Plaintiffs would receive a significant return on their investment.

           However, Defendant OLINT never intended to return Plaintiffs' funds and has created an

           elaborate suspension of operations to avoid same and delay/escape suspicion of their

           actions.

   b. causing Plaintiffs to enter into an agreement and requiring Plaintiffs to provide Defendants

   with large sums of money to invest in OLINT;

   c. denying Plaintiffs access to their funds and/or accounts and records through the actions of

   Defendants, and/or their principals or agents;

   d. through the actions of Defendants, and/or their principals or agents, misrepresenting to

   Plaintiffs the status of OLINT and/or their investments in same to prevent them from

   discovering the fraud; and

   e. acting in concert with one another to continue the concealment of their fraudulent conduct.

86. As a direct and proximate result of Defendants' actions, Plaintiffs have suffered, and continue to

   suffer, injuries and damages.
WHEREFORE, Plaintiffs respectfully requests this Court enter judgment in their favor and against

Defendants awarding Plaintiff damages, together with interest, costs and such further relief as this

Court deems necessary, just and proper.

                                               COUNT III
                                            CIVIL CONSPIRACY

   87. Plaintiffs reassert and re-allege the allegations set forth in paragraph 1 through 69 as though

       fully set forth herein.

   88. This is an action for civil conspiracy against all Defendants.

   89. Defendants conspired with each other to defraud Plaintiffs of monies intended to be invested

       only for foreign currency exchange trading in OLINT.

   90. Defendants committed a number of overt acts in furtherance of the conspiracy including, but

       not limited to:

           a. Making misrepresentations through their agents both verbally and through materials

           provided to Plaintiffs including misstatements as to the accessibility of their investment, its

           purpose, and return thereon, as follows:

               I. Defendants, and their agents, falsely represented and warranted that Plaintiffs would

               have continued access to their investments via OLINT'S online portal, which would

               allow Plaintiffs to monitor, adjust, and withdrawal their investments immediately;

               II. Defendants, and their agents, falsely represented and warranted that Plaintiffs'

               investment would be used for foreign currency exchange trading. Upon information and

               belief, Defendant OLINT'S principals, including Defendants SMITH, have absconded

               with Plaintiffs' funds and/or transferred them into affiliated entities or to affiliated

               parties, including defendants HALLMARK and defendants MARTINEZ, for personal

               gain and/or with the intent to hinder, delay, or defraud Plaintiffs' efforts to recover their

               funds and based upon information and belief, HALLMARK and defendants
                 MARTINEZ assisted OLINT in laundering and/or transferring money from OLINT after

                 they were made aware of OLINT'S true business practices; and

              III. Defendants OLINT, SMITH and HALLMARK, and their agents, falsely represented and

              warranted that Plaintiffs would receive a significant return on their investment. However,

              Defendant OLINT never intended to return Plaintiffs' funds and has created an elaborate

              suspension of operations to avoid same and delay/escape suspicion of their actions.

       b. causing Plaintiffs to enter into an agreement and requiring Plaintiffs to provide Defendants

       with large sums of money to invest in OLINT;

       c. denying Plaintiffs access to their funds and/or accounts and records through the actions of

       Defendants, and/or their principals or agents;

       d. through the actions of Defendants, and/or their principals or agents, misrepresenting to

       Plaintiff the status of OLINT and/or their investments in same to prevent them from discovering

       the fraud; and

       e. acting in concert with one another to continue the concealment of their fraudulent conduct.

   91. Plaintiffs reasonably relied on the misrepresentations described above, which induced Plaintiffs

       to “invest” in OLINT.

   92. As a direct and proximate result of Defendants' actions, Plaintiffs have suffered, and continue to

       suffer, injuries and damages.

   93. Plaintiffs have retained undersigned counsel and are obligated to pay their attorney a reasonable

       fee.



WHERFORE, Plaintiffs, respectfully requests this Court enter judgment in their favor and against

Defendants, awarding Plaintiffs damages, together with interest, costs and such further relief as this

Court deems necessary, just and proper.

                                                COUNT IV
                             FRAUDULENT MISREPRESENTATION

94. Plaintiffs reassert and re-allege the allegations set forth in paragraphs 1 through 69 as though

   fully set forth herein.

95. This is a cause of action for fraud against Defendants OLINT, Defendants SMITH,

   HALLMARK, TROWBRIDGE, and TCII.

96. Defendants OLINT, SMITH, HALLMARK, TROWBRIDGE, and TCII knowingly made

   misrepresentations of material fact that induced Plaintiffs to remit funds to OLINT for

   Defendants' financial gain. These misrepresentations include, but are not limited to:

       a. Making misrepresentations through their agents both verbally and through materials

       provided to Plaintiffs including misstatements as to the accessibility of their investment, its

       purpose, and return thereon, as follows:

           I. Defendants, and their agents, falsely represented and warranted that Plaintiffs would

           have continued access to their investments via OLINT'S online portal, which would

           allow Plaintiffs to monitor, adjust, and withdrawal their investments immediately;

           II. Defendants, and their agents, falsely represented and warranted that Plaintiffs'

           investment would be used for foreign currency exchange trading. Upon information and

           belief, Defendant OLINT'S principals, including Defendants SMITH, have absconded

           with Plaintiffs' funds and/or transferred them into affiliated entities or to affiliated

           parties, including defendants HALLMARK and defendants MARTINEZ, for personal

           gain and/or with the intent to hinder, delay, or defraud Plaintiffs' efforts to recover their

           funds and based upon information and belief, HALLMARK and defendants

           MARTINEZ assisted OLINT in laundering and/or transferring money from OLINT after

           they were made aware of OLINT'S true business practices; and

       III. Defendants OLINT, SMITH and HALLMARK, and their agents, falsely represented and

       warranted that Plaintiffs would receive a significant return on their investment. However,
           Defendant OLINT never intended to return Plaintiffs' funds and has created an elaborate

           suspension of operations to avoid same and delay/escape suspicion of their actions.

       b. causing Plaintiffs to enter into an agreement and requiring Plaintiffs to provide Defendants

       with large sums of money to invest in OLINT;

       c. denying Plaintiffs access to their funds and/or accounts and records through the actions of

       Defendants, and/or their principals or agents;

       d. through the actions of Defendants, and/or their principals or agents, misrepresenting to

       Plaintiffs the status of OLINT and/or their investments in same to prevent them from

       discovering the fraud; and

       e. acting in concert with one another to continue the concealment of their fraudulent conduct.

   97. Plaintiffs justifiably relied upon Defendants' false statements and misrepresentations, as

       Plaintiff and Defendant entered into the agreement described above, each performed under its

       terms, and Defendant did not provide any objective indication of intent to defraud Plaintiff

       throughout the parties' discussions and negotiations.

WHEREFORE, Plaintiffs respectfully requests this Court to enter judgment in their favor and against

Defendants, awarding Plaintiffs damages, together with interest, costs and such further relief as this

Court deems necessary, just and proper.

                                          COUNT V
                                     BREACH OF CONTRACT

   98. Plaintiffs reassert and re-allege the allegations set forth in paragraphs 1 through 69 as though

       fully set forth herein.

   99. This is a breach of contract action against Defendants OLINT, Defendants SMITH,

       HALLMARK, and TROWBRIDGE

   100.                                             Defendant OLINT and HALLMARK, and their

       principals and agents, provided Plaintiffs with terms that would govern their accounts, including
       the assurance that Plaintiffs could withdrawal any or all of their money at any time. These terms

       represent a contract with Plaintiffs. Additionally representations were made to Plaintiffs orally

       by principals or agents of OLINT and HALLMARK that also represent a contract with

       Plaintiffs.

   101.                                               After these contracts were finalized, Plaintiffs

       invested a substantial sum of money with OLINT. Pursuant to the contracts, Plaintiffs were to

       have continuous access to their account and significant returns on their investment.

   102.                                               According to the informational materials and

       representations of OLINT, OLINT was to use Plaintiffs' funds for foreign currency exchange

       trading through various trading platforms. All of the relevant account information was to be

       accessible through OLINT'S interactive website, including immediate access by Plaintiffs for

       deposits, withdrawals, and the general monitoring of the accounts.

   103.                                               Plaintiffs have repeatedly made written and oral

       requests to Defendants OLINT, SMITH, and HALLMARK, providing Defendants with

       sufficient notice, to withdrawal funds from their accounts with OLINT.

   104.        Despite such demands, Defendants OLINT, defendants SMITH, HALLMARK, and

       TROWBRIDGE breached the Agreement by failing to return the requested principal and

       profits, totaling over $1.20 million, owed to Plaintiffs.

   105.        Defendants' breach has caused, and will continue to cause, Plaintiffs injury and damages.

WHEREFORE, Plaintiffs respectfully requests this Court enter judgment against Defendants

awarding Plaintiffs damages and such further relief as this Court deems necessary, just and proper.

                                                COUNT VI
                                        UNJUST ENRICHMENT
   106.        Plaintiffs reassert and re-allege the allegations set forth in paragraph 1 through 69 as

       though fully set forth herein.

   107.        This is an action for unjust enrichment against all Defendants.
    108.       Plaintiffs have conferred upon Defendants a substantial benefit in the form of monies

       which were solely intended to be invested in foreign currency exchange trading to be conducted

       by OLINT, in an amount in excess of $1.20 million.

    109.       Defendants have failed to return the monies to Plaintiffs, despite the fact that OLINT

       represented the fact that Plaintiffs would have access to and receive substantial profits from

       keeping the money in their accounts at OLINT.

    110.       It is inequitable for Defendants to retain the monies.

WHEREFORE, Plaintiffs respectfully requests this Court to enter judgment for the Plaintiffs against

Defendants, awarding Plaintiffs damages, and such further relief as this Court deems necessary, just

and proper.

                                               COUNT VII
                                              ACCOUNTING

    111.       Plaintiffs reassert and re-allege the allegations set forth in paragraphs 1 through 69 as

       though fully set forth herein.

    112.       Defendants failed to honor Plaintiffs' withdrawal requests for the return of their funds

       and remittance of profits thereon.

    113.       Through misrepresentation, deceit, abuse of a confidential relationship, conversion and

       unjust enrichment, Defendants have absconded with substantial funds belonging to Plaintiffs.

    114.       Plaintiffs are entitled to an accounting of all actions taken and property transferred.

WHEREFORE, Plaintiffs respectfully requests this Court enter an order requiring Defendants to

account for all actions taken and property transferred, awarding Plaintiffs their attorney's fees and costs,

and with such relief as this Court deems necessary, just and proper.



                                     DEMAND FOR JURY TRIAL

Plaintiff demands trial by jury of all claims triable.
Respectfully submitted,




                          _________________________

                                         David P. Rowe
                              Florida Bar No.: 373575
                          Law offices of David P. Rowe
                                 110 E. Broward Blvd.
                                             Suite 1700
                            Fort Lauderdale, FL 33301
                                         (305)731-0019

				
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