jury

COMPLAINT FOR:

1. Breach qf Fiduciary Duty;
2. Conversion;
3. Fraud/Deceit/Concealment;
4. Accounting;
5. Fraudulent Conveyance;
6. Avoidance and Recovery of Fraudulent Transfers;
7. Avoidance of Fraudulent Transfer

• and Obljgation;
  8. Money Had and Received;
• Unjust Enrichment;

1O.Negligence;

22                                II.Negligence;

12.Negligence;

• Aiding and Abetting;

14.Rescission;

• Negligence;

16.I..escission;

• Neghgence;

18. Avoidance of Fraudulent

• Obligations;

19. Av01aance of Fraudulent Transfer

• and Obligation; and

20. .Declaratory and Injunctive Relief

28

87806.2

I                  Plaintiff Arnold W. Klein, M.D. (Plaintiff or “Dr. Klein”) alleges for his

• Complaint against Defendants  Muhammad  Khilji, Jason Roger Pfeiffer,  Khilji-
• Pfeiffer, LLC, Khilji  & Klein, LLP, The Private Bank of California, Excel   National
• Bank, Z & P Investment Services, Inc., TD Ameritrade,  , Able   Investment
• Services, LLC, Nxt Equities Incorporated,  Dominion  Mortgage  Corporation, Allen
• C. Davis, as trustee for Davis Trust No. I U/A/T November  7,  1961 and Does   I
• through 50, inclusive,  as follows:

8                                                                                                                                                                                                           INTRODUCTION

• Plaintiff Arnold  W. Klein, M.D. is a highly respected  doctor who  is

IO            renowned  in his field as a pioneer  in dermatology.   He has maintained  a successful medical practice for more than 35 years  and helped raise over $320 million for HIV  and AIDS research.  Dr. Klein trusted his accountant, Muhammad  Khilji, and his  office manager, Jason Roger Pfeiffer, to fulfill their professional duties with integrity and candor. Dr. Klein also relied upon his long-time financial advisors to protect his assets  and  exercise diligence in managing his investments.

2. Dr. Klein’s trust and confidence were misplaced.   Dr.  Klein discovered that his investment accounts were raided, bank accounts were opened in his name without his knowledge  and then pilfered,  and his assets were jeopardized.   In  the

• process, multiple  documents were  forged, altered or signed under  false
• The discovery of this  covert  scheme was compounded by the  revelation
• that several financial  and banking  institutions  failed to exercise due care in connection
• with Dr. Klein’s    Time and time  again, there were opportunities  for these
• institutions to follow their own procedures and regulations  and mitigate the  harm
• suffered by Dr. Klein at the hands of his trusted advisors. Instead, they failed him.     As
• a result, the assets that Dr. Klein worked long and hard to build have been

business  entity which conducts business in the County of Los Angeles in the    State of

California.

9. Upon information and belief, The Private Bank of California is a corporation organized and existing under the laws of California, with its principal place of business in the County of Los Angeles in the State of   Cailifornia
10. Upon information and belief, Excel National  Bank is an unknown

• business entity which  conducts business in the County of Los Angeles in the State   of
• Upon information  and belief, Z & P Investment  Services, LLC is  a
• limited liability company organized and existing under the laws of California, with its
• principal place of business in the County of Orange in the  State of California.
• Upon information  and belief, TD Ameritrade,  Inc. is a corporation
• organized and existing under the laws of New York, which conducts business   in the
• County of Los Angeles in the State of California. 27

• Upon information  and belief, Able Investment  Services, LLC is a  limited
• liability company organized and existing under the laws of Nevada, which   conducts
• business in the County of Los Angeles in the State of
• Upon information  and belief, NXT Equities Incorporated  is a  corporation
• organized and existing under the laws of California,  with its principal  place of
• business in the County of Los Angeles in the State of
• Upon information  and belief,  Dominion Mortgage  Corporation is a corporation organized and existing under the laws of California, with its principal place of business in the County of Los Angeles in the    State of California.
  16. Upon information and belief, Allen V.C. Davis, as trustee for Davis Trust No. I U/A/T November 7, 1961, is an individual who resides in the County of Los Angeles in the State of
  17. Plaintiff is informed and believes, and on that basis alleges, that Defendants DOES 1 through 50, inclusive, are individually and/or jointly liable to Plaintiffs for the conduct alleged herein. The true names and capacities, whether individual, corporate, associate or otherwise, of Defendants DOES 1 through 50, inclusive, are unknown to Plaintiff at this time. Accordingly, Plaintiff sues Defendants DOES  I  through  50, inclusive, by fictitious names and will amend this

24. Muhammad Khilji and Jason Pfeiffer
25. In 2007, Dr. Klein hired Muhammad Khilji as his accountant. Khilji oversaw accounts payable and receivable for Dr. Klein’s medical office. Khilji told

4

1                Dr. Klein he was a licensed Certified Public Accountant who had experience

• providing comprehensive accounting services.
• Khilji provided accounting services in connection with Dr. Klein’s
• medical practice as well as his personal financial matters. For example, Khiji was
• responsible for handling the processing and payment of Dr. Klein’s personal expenses,
• including mortgage payments, compensation for individuals providing household
• services, car payments and credit card payments. Khilji also was charged with filing
• tax submissions and performing other related financial management
• Jason Roger Pfeiffer began working for Dr. Klein in 2007 as a personal
• assistant and research assistant. Pfeiffer progressively spent more time in Dr. Klein’s medical office and assisted office staff. By early 2009, Pfeiffer became office manager.
  28. Khilji worked closely with Pfeiffer. Over time, Khilji and Pfeiffer began to exercise more and more control over Dr. Klein’s finances. In concert, they instructed subordinate office staff to direct correspondence to their attention. Khilji also supervised other office employees who were involved in processing the accounts payable and receivable for the
  29. Klein placed his trust and confidence in Khilji and Pfeiffer to perform
• their professional duties with integrity. Khilji and Pfeiffer accepted Dr. Klein’s trust
• and confidence, and actively encouraged him to rely upon them to exercise control
• over financial matters. Dr. Klein believed they were acting in his best
• In March 2009, Dr. Klein was suffering from an illness that forced him to
• spend several days away from the office. He went to his home in Laguna Beach,
• California to rest and recuperate from his illness. Pfeiffer and Khilji were aware of
• Klein’s condition and seized on the opportunity to capitalize on Dr. Klein’s
• reduced
• On March 20, 2009, without explaining their intentions to Dr. Klein,
• Pfeiffer and Khilji went to Dr. Klein’s Laguna Beach home. Pfeiffer and Khilji

• brought with them several individuals who were unknown  to Dr. Klein.  When   they
• arrived, Pfeiffer and Khilji told Dr. Klein that they were there to obtain his    signature
• on a document that would permit Pfeiffer and Khilji to make health decisions    from Dr.
• Klein during any period of incapacity.   To keep their actions from being  observed,
• Pfeiffer and Khilji  instructed  Klein’s  caregiver to leave.
• Pfeiffer and Khilji presented  Dr. Klein with a document titled Power   of
• Attorney for Health Care. Pfeiffer  and Khilji would be designated  as agents for

8      Klein and authorized  to make certain decisions relating to Dr. Klein’s health    and

9      medical treatment.

10                  33.       During their visit, Pfeiffer and Khilji also had Dr. Klein    execute a document titled Codicil to Last Will and Testament.  Pfeiffer and Khilji were named    as executors of Dr. Klein’s will, and certain provisions  of the will were revoked   thereby removing Dr. Klein’s family members as beneficiaries under his

will. The significance of this document was not explained to Dr. Klein.  Dr. Klein did not agree  to the changes made by Pfeiffer and Khilji, which would cause them to benefit  from  Dr.  Klein’s death.

34. Pfeiffer and Khilji also instructed Dr. Klein to sign an Amendment to   the

• Arnold William Klein Revocable Trust as Amended  and Restated in 2000.  In  the
• amendment, several changes were made to beneficiaries  of the trust.  Pfeiffer  and Khilji
• were named as co-trustees . Dr. Klein did not sign this in that his trust was from 1998.
• Pfeiffer and Khilji also had Dr. Klein supposedly sign a document    titled
• General Durable Power of Attorney, which is of questionable
• The Private Bank of California
• In August 2009, Khilji  and Pfeiffer opened several bank accounts at   The
• Private Bank of California (“Private Bank”).  The Master Account Agreement   and
• Authorization Business  Signature Card form is signed by Pfeiffer and Khilji,  who
• identify themselves as authorized signers, and dated August 18, 2009. The signature 28

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87806.2

• of Arnold W. Klein as President is reflected  on the document, but Dr. Klein  never
• signed
• In or around August 2009, Khilji  and/or Pfeiffer  signed multiple
• documents that were submitted to Private Bank in connection with accounts in the
• name of Dr. Klein and/or his medical businesses. Klein was not informed  of   these
• documents and did not authorize their It appears that in at least one
• instance Catherine Coler of Private Bank approved forms that were submitted   by
• Khilji and/or Pfeiffer without Dr. Klein’s knowledge  or authorization.   Coler did  not
• contact Dr. Klein regarding this account
• Dr. Klein was not informed of the accounts opened by Khilji    and Pfeiffer

• at Private Bank. He has never    stepped foot inside Private Bank or met with any bank
• representatives until the accounts were closed. In order to cover up their fraud, it appears that Khilji and Pfeiffer had Private Bank send account statements and other documents to an address that was associated  with Khilji’s

39. Private Bank never contacted Dr. Klein to verify any  information relating to the creation or use of the multiple accounts in his name or in the name of his companies. Private Bank was aware that information relating to the multiple bank accounts was not being  sent to Dr. Klein’s personal  or professional  address.   For

• months after the accounts were opened, Private Bank failed to  send account
• statements to Dr. Klein or take other steps to ensure he received notice  of activity
• regarding bank accounts purportedly  opened in his
• In January 2010, Joyce E. Jicka of Private Bank wrote to   Muhammad
• In her email, Jicka stated that she “noticed  that all these account  statements  are
• still ” It is unclear what Jicka meant when she referred to “NKSF”
• and it unclear why Jicka chose to communicate with Khilji via email instead  of
• sending a letter to Dr. Klein’s attention. Jicka asked Khilji to send her a letter    asking
• for the address to be changed. Jicka listed the names and partial account numbers for 28

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87806.2

1                  10 (ten) bank accounts with various names. Again, despite knowledge that account

• statements were not sent to Dr. Klein, Jicka made no effort to contact Dr.
• Apparently in response to Jicka’s request, in February 2010, Khilji wrote
• to Private Bank requesting that the address for account statements for ten (10)
• accounts be changed to 435 North Roxbury Dr., Suite 204, Beverly Hills, CA 90210:
• Arnold Klein MD -xxx799 l
• Arnold Klein MD -xxx8007
• Arnold William Klein MD -xxx2366
• Arnold William Klein MD -xxx2382
• Arnold William Klein MD -xxx2390 Arnold William Klein MD -xxx6409 Khilji-Pfeiffer -xxx2358

Khilji-Pfeiffer -xxx6417 Minimally Invasive -xxx2473 Minimally Invasive -xxx6490

42. At least two of the accounts appear to bear the name “Khilji-Pfeiffer.” Dr. Klein is informed and believes that Khilji and Pfeiffer used an entity they created, Khilji-Pfeiffer, LLC, to facilitate numerous fraudulent transactions and to funnel

• funds that were unlawfully converted from Dr. Klein’s bank and investment
• Private Bank records reveal that Jicka, Coler and other employees of
• Private Bank actively facilitated the fraudulent activities of Khilji and Pfeiffer by
• meeting solely with Khilji, processing transactions affecting Dr. Klein’s accounts
• without proper documentation and concealing the Khilji-Pfeiffer accounts.
• In May 2010, Khilji signed a document titled “Cash Management Client
• Enrollment & Agreements/Disclosures Acceptance Form” for Private Bank and
• representing himself as “Power of Attorney” for accounts in the name of Arnold
• Klein 28

8

87806.245.                     In May 2010, Khilji and Pfeiffer also executed documents to authorize wire transfers and on-line banking access for Dr. Klein’s personal, business and accounts at Private  Bank.

46.                     Dr. Klein’s signature is not evident on any of these documents. 47.                     Khilji and Pfeiffer used the accounts at Private Bank to pilfer hundreds thousands  if not millions  of dollars from Dr. Klein without his  knowledge. 7 8 D. 48. Excel National Bank In November  2009, without  Dr. Klein’s knowledge,  Pfeiffer  and Khilji

of

• opened payroll and revenue  accounts in the name of Dr. Klein’s medical practice   at
• Excel National Bank (“Excel Bank”). It appears that Pfeiffer and Khilji represented themselves as officers of Arnold  Klein MD, A Medical  Corporation.

49. The documents reflect multiple signatures purported to belong to Dr. Klein, but the signatures vary noticeably. Dr. Klein did not sign the documents and was not aware that Pfeiffer and Khilji had opened the
50. Khilji and Pfeiffer used the accounts at Excel Bank to transfer and ultimately embezzle hundreds of thousands if not millions of dollars from Dr. Klein without his
51. Khilji and Pfeiffer also conspired to steal hundreds of thousands  of

• dollars from Dr. Klein through mirror image wire transfers. Khilji would   approve
• substantial wire transfers in favor of Pfeiffer;  and Pfeiffer would tum around   and
• approve substantial wire transfers in favor of Khilji.   These transactions were used  to
• remove substantial  funds from the accounts Khilji and Pfeiffer created at Private   Bank
• and Excel Bank without Klein’s knowledge.   The banks made no effort to   contact
• Klein, took no steps to verify the nature of the transactions, acted without   proper
• documentation or authorization,  and failed to implement and employ standard  industry
• protections for suspicious transaction activity involving Klein’s accounts.
• Pfeiffer also charged  exorbitant amounts to an American  Express  credit
• card account that he made “paperless” so as to evade Dr. Klein believes

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87806.2

• Khilji also participated in and benefitted  from this fraudulent credit card
• Khilji and Pfeiffer used  funds in the Private Bank and Excel Bank accounts to pay   the
• credit card bills without Dr. Klein’s knowledge or authorization.   Their collusion   in
• the scheme let them live a lavish lifestyle at the  expense of Dr. Klein.
• Notwithstanding  suspicious transaction  activity, and in the face  of
• documents which on their  face raise serious questions about the authenticity  of
• signatures, no efforts were made by Private Bank or Excel Bank to contact Dr.   Klein
• directly and confirm his authorization for the accounts or the conduct of Khilji  and

10                                                      E.        Z & P Investment Services, LLC

54. For approximately 25 years, Dr. Klein engaged Z & P Investment Services, LLC to perform  financial management,  advisory and other services.   Jeffrey
55. Zone and Claudia I. Peltier provided broad financial management and accounting services to Dr. Klein and managed his retirement accounts held at TD Ameritrade.
56. Sometime in or around 2007, Z & P Investment Services, LLC sold its CPA practice to Muhammad Khilji and his company, Khilji & Klein, LLP. Thereafter, Khilji and his company handled accounting work for Dr. Klein. Z & P Investment Services continued  to control Dr. Klein’s investment  and  brokerage

• accounts and provided financial management  services to Dr.
• Z & P Investment Services was obligated to exercise due care in its
• management of Dr. Klein’s  investment  accounts and to fulfill its  financial
• management duties to Dr. Klein with the utmost    Z & P Investment  Services
• was also required to keep Dr. Klein informed regarding any activities that might   have
• a material effect on the value of his investments  and other assets under  its
• management and
• In 2009,  contrary to its own policies  and procedures,  Z & P Investments
• accepted oral instructions from Khilji for the liquidation of substantial assets held   by
• Klein at TD Ameritrade. Khilji’s requests for wire transfers  and asset   liquidation

• would typically be received on one day’s This alone should have raised red
• flags for Dr. Klein’s trusted   Z & P Investment  Services did not request    or
• receive written authorization from Dr. Klein for these transactions.   Z & P  Investment
• Services also did not provide Klein with prompt written notice of the fund transfer
• or liquidation requests before the transactions  were completed.   Z & P  Investment
• Services failed to contact Dr. Klein despite having his home, business and   personal
• cellular phone
• Instead,  Z & P Investment  Services processed  repeated transactions until
• Klein’s hard-earned retirement  and investment  funds were almost  completely
• Finally, when there was little money left in Dr. Klein’s    once-lucrative

“<‘

g

• accounts at TD Ameritrade, Z & P Investment  Services washed its hands of its   long-
• time client. In or about August 2009, Z & P Investment Services, LLC stopped providing services to Dr.
  59. In a matter of approximately eight months, over $2.2 million was withdrawn from Dr. Klein’s  investment portfolios  without  his
  60. The Windsor Property
  61. Klein has owned a residence at 553 South Windsor Boulevard in Los Angeles, California since  1976 (the “Windsor Property”).   In 2009, Dr. Klein  had
• significant equity in the property that is viewed as a historic
• In December  2009, without  Dr. Klein’s knowledge  or authority, Khilji
• caused Dr. Klein to sign certain documents in connection with a mortgage  loan
• bearing 11% interest to be secured by the Windsor Property.   The  transaction
• apparently involved NXT Equities Incorporated  (“NXT”)  as broker  and Able
• Investment Services, LLC (“Able”)  as lender.   The terms  of the transaction are
• atypical and lack business justification given the value of the Windsor
• Many of the documents relating to the residential  loan are unsigned.    A
• number of the documents also reflect inaccuracies in information  regarding
• Klein’s age and length of employment, as well  as other obviously  incorrect

2biographical information. In addition, critical information regarding lender costs is blank and documents fail to comply with requirements set forth in Civil Code section 1189.

63. On or about December 16, 2009, in reliance upon the documents described herein, Able distributed the sum of $1.6 million to various
64. Klein first learned about the Able loan secured by the Windsor Property in late summer of 2010.   Dr. Klein ceased all payments  on the Able loan    until an investigation  could be conducted.   Because Dr. Klein did not authorize the  Able loan, and because he believes his signature on the loan documents was either  forged or obtained under false pretenses, Dr. Klein discontinued payments  on the   loan.
65. On or about October 21, 2010, a Notice of Default and Election to Sell Under Deed of Trust was recorded against the Windsor

G.                         The Laguna Property

66. Klein has owned a residence at 31025 Pacific Coast Highway in Laguna Beach,  California  since  1991 (the “Laguna Property”).
67. In or around February 2010, Jason Pfeiffer contacted Inge Bunn, a real estate broker who had worked with Dr. Klein for many years.  Pfeiffer told Bunn that

• he was Dr. Klein’s assnts relating to the residential loan are unsigned.     A

• istant and stated that he would  serve as a liaison between   Bunn
• and Dr.
• Pfeiffer asked Bunn to preliminary-market  the Laguna property as   a
• pocket   After a series of telephone calls in the following months, Pfeiffer   told
• Bunn that Dr. Klein’s CPA, Muhammad  Khilji, would be handling the
• Subsequently, Bunn met with Khilji and presented  a Comparative  Market
• Analysis (CMA) to Khilji.  Khilji initially suggested that the Laguna Property be
• listed for $13 million. On March 25, 2010, Bunn provided  Khilji with a  Listing
• Agreement for his review.  Although the Listing Agreement was not signed,   Khilji
• instructed Bunn to move forward with having the Laguna  Property professionally
• The photographs  were taken in early April  2010.

Pfeiffer and Khilji took extensive steps to conceal their unauthorized attempt to list the Laguna Property from Dr. Klein. Pfeiffer told Bunn to remove any marketing brochures from the Laguna Property because Dr. Klein would be entertaining guests at the home over the weekend. Pfeiffer and Khilji also prohibited Bunn from placing  any signage regarding the listing  at the

70. In April 2010, without Dr. Klein’s knowledge, Khilji submitted a loan application to Dominion Mortgage Corporation for the purposes of obtaining a loan secured by the Laguna Property. Dr. Klein did not sign the loan application and did not know that an application had been completed  in his
71. In June 2010, Khilji emailed Bunn and informed her that Dr. Klein was going through a financial transaction regarding the Laguna Property. Khilji told Bunn that an individual named Loren Thall would be involved in the sale and would receive  a 0.5% commission.  Khilji also said the property had to be listed in the Multiple  Listing Service (MLS). Khilji requested information from Bunn regarding the  property’s value and comparative listings.   Thall also contacted Bunn about placing   the property  on the
72. On June 4, 2010, Dunn received an email from Khilji stating “we have a consensus on listing price of $11,900,000.” Khilji’s email was also sent to Thall and

stated the “[t]hree of us need to work together  and make it happen.   I know it will  take

sometime but we should be shooting for March   2011.”

74. There is a listing agreement dated June 5, 2010 purporting to reflect Dr. Klein’s signature on behalf of the “1995 Klein Arnold W. Trust,” which is not the correct name of the trust that holds Dr. Klein’s Laguna Property. Dr. Klein never signed the listing agreement and had no knowledge that Khilji and Pfeiffer were conspiring to sell his Laguna Property behind his
75. In or around June 2010, Khilji and/or Pfeiffer fraudulently executed certain documents in connection with a mortgage loan bearing 12% interest to be secured by the Laguna Property. The transaction  apparently involved Dominion

13

• Mortgage Corporation  (“Dominion”)  and Allen V.C. Davis, trustee  for Davis Trust
• 1 U/A/T November 7, 1961 (“Davis”) as lender. The terms of the transaction are
• atypical and lack business justification  given the value of the Laguna
• Many of the docume

• number of the documents  fail to comply with requirements  set forth in Civil  Code
• section
• On or about June 8, 2010, in reliance upon the documents    described
• herein, Dominion and Davis  distributed an unknown  sum in connection with  the
• principle loan amount of $1.5
• Dr. Klein first learned about the Dominion/Davis  loan secured   by the Laguna Property in fall of 2010. Because Dr. Klein did not authorize the Dominion/Davis loan, and because he believes  his signature on the loan documents  was either forged or obtained under false pretenses, Dr. Klein did not make payments  on the loan.

79. On or about November 17, 2010, a Notice  of Default  and of Lender’s Intent to Exercise its Remedies Under Loan Documents was recorded against the Laguna Property.

H.                         Dr. Klein Discovers the Fraudulent Scheme

• In late summer of 2010, upon returning  from a trip, Dr. Klein   attempted
• to use his American Express credit  card for a nominal     The card was denied;
• the denial came as a complete shock to Dr.
• Thereafter,  Dr. Klein learned that his finances had been   substantially
• depleted, that several loans had been taken out without his knowledge,  and that
• substantial funds had been fraudulently withdrawn  from his investment  and retirement
• accounts without  his
• In September 2010, Dr. Klein terminated  his relationship  with Khilji. 27

2FIRST CLAIM FOR  RELIEF

(Breach of Fiduciary Duty -Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES  1-50)

83. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
84. Klein placed trust and confidence in Khilji and Pfeiffer to exercise their duties as business managers, bookkeepers and accountants with integrity and good faith. Khilji and Pfeiffer accepted Dr. Klein’s trust and confidence, and actively encouraged him to rely upon them in the conduct of his financial  affairs.
85. By virtue of their provision of business management and accounting services as described above, Khilji and Pfeiffer owed fiduciary duties to Dr. Klein with respect to his business and personal financial affairs, including but not limited to duties to act diligently and faithfully, to disclose all relevant  and material  information, to properly account for all assets, and to act with the utmost care   and

2

86. Khilji and Pfeiffer breached their fiduciary duties to Dr. Klein by, among other things, taking out lines of credit and making other loan arrangements secured by Dr. Klein’s property and using the proceeds for their personal use; diverting and siphoning millions of dollars from Dr. Klein’s bank and investment accounts without his knowledge or authorization; writing and negotiating numerous checks from Dr. Klein’s accounts and concealing their activity; charging unauthorized expenses for credit cards opened in Dr. Klein’s name and using the funds for their personal use; failing and refusing to disclose their activities to Dr. Klein; and putting Dr. Klein in a position of financial ruin and immediate
87. As an instrument of their breaches of duty, Khilji and Pfeiffer used their companies, Khilji-Pfeiffer, LLC and Khilji and Klein, LLP (the “Khilji/Pfeiffer

1        Entities”), to perpetuate their fraudulent transactions  and conversion of Dr.   Klein’s

2  assets and property.

• As a direct, actual, and foreseeable result of Defendants’ breaches   of
• fiduciary duty, Dr. Klein has been damaged in an amount that has not yet been  fully
• ascertained, but in any event an amount not less than $10,000,000.00.
• The aforementioned  conduct of Defendants was intentionally deceitful,
• fraudulent, and done with the intent of depriving Dr. Klein of his property and  legal
• rights and to cause him injury. Defendants’  conduct was and is despicable   and
• subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his  rights
• so as to justify an award of exemplary and punitive

11                                                                                                                                                                 SECOND CLAIM FOR RELIEF

• (Conversion -Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)
  90. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein

91. As described above, Defendants removed funds and property from Dr. Klein’s assets. That property includes, for example, equity in the Windsor Property, which was obtained and used by Defendants through fraudulent transactions. That property also includes credit, which Defendants obtained and used through their excessive and unauthorized use of credit cards belonging to Dr. Klein. Defendants converted the equity and credit into cash, which they kept and used for their personal use and not for the benefit of Dr. Klein or his medical practice. And the property includes cash, which Defendants withdrew from bank, investment and retirement accounts containing  the Dr. Klein’s
92. These uses of property were for Defendants’ sole benefit and were without permission of Dr. Klein, in direct violation of the duties Defendants  owed

Dr. Klein as business managers and trusted bookkeeper/accountant. Accordingly, Defendants took property to which they were not entitled.

93. Defendants also removed valuable personal property from the Laguna Property without Klein’s knowledg .
94. These acts constitute conversion of property that Klein has an ownership interest in.
95. Klein has on several occasions demanded return of the funds taken, but to no avail.
96. As a direct, actual, and foreseeable result of Defendants’ conversion, Klein has been damaged in an amount that has not yet been fully ascertained, but in any event an amount not less than $10,000,000.00.
97. The aforementioned conduct of Defendants was intentionally deceitful, fraudulent, and done with the intent of depriving Klein of his property and legal

rights and to cause him injury.  Defendants’ conduct was and is despicable and

subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights so as to justify an award of exemplary and punitive damages.

THIRD CLAIM FOR  RELIEF

0

87806.2

(Fraud/Deceit/Concealment – Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)

98. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
99. As described herein, Khilji and Pfeiffer obtained Dr. Klein’s signature on key documents under false pretenses and for purposes that were not disclosed to Dr. Klein. Khilji and Pfeiffer made these false statements and misrepresentations with the intention that Dr. Klein would rely thereon. Khilji and Pfeiffer also failed to disclose, and otherwise concealed, material information regarding their activities relating to Klein’s real property assets, bank accounts, credit cards and other property interests.

17

• Klein did in fact rely upon Khilji and Pfeiffer’s representations and    false or
• misleading statements to his detriment, and it was foreseeable that he would  do
• If Dr. Klein had been  aware of Khilji and Pfeiffer’s  true purposes  and
• intentions, he would not have signed the documents  as requested.   In many instances,
• Klein was never made aware of the true nature or purpose of the documents.   If  he
• had known the truth, he would not have permitted Khilji  and Pfeiffer to exercise
• control over his professional and personal  financial
• As described  herein, Khilji and Pfeiffer also forged Dr. Klein’s   signature
• on many key financial documents,  including loan documents,  credit applications,
• investment sell and liquidation requests and other transaction   authorization

0

8       11      documents.

“‘

102. As a direct, actual, and foreseeable result of Defendants’ fraud   and

forgeries, Dr. Klein has been damaged in an amount that has not yet been fully ascertained, but  in any event an amount not less than  $10,000,000.00.

103. The aforementioned conduct of Defendants was intentionally deceitful, fraudulent, and done with the intent of depriving Dr. Klein of his property and legal rights and to cause him injury. Defendants’  conduct was and is despicable and  subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights    so

• as to justify an award of exemplary and punitive
• FOURTH CLAIM FOR RELIEF
• (Accounting – All Defendants)
• Plaintiff repeats and realleges  each and every foregoing and  subsequent
• allegation contained in the Complaint, as though said paragraphs were  set forth in full
• As alleged above, a fiduciary relationship  existed between Dr. Klein   and
• Khilji and Pfeiffer. A fiduciary and/or contractual relationship  also existed   between
• Klein and Z & P Investment Services, LLC, as well as TD Ameritrade. As a result 28

107.  the foregoing, an accounting is required to determine the exact amount Defendants owe Dr.

FIFTH CLAIM FOR  RELIEF

(Fraudulent Conveyance -Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)

108. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
109. As alleged above, Defendants have committed acts constituting, among other things, fraud, breach  of fiduciary duty and
110. Defendants’ acts have removed property from Dr. Klein’s possession and prevented Dr. Klein from accessing his property and other assets. Title to certain property, purchased by Khilji and/or Pfeiffer with Dr. Klein’s funds and without his knowledge or authorization,  has not been properly transferred  to Dr.
111. Klein is informed and believes, and thereon alleges, that Defendants removed assets, monies,  and/or property  of Dr. Klein’s assets and businesses  and

19

• prevented him from accessing  such assets, monies, and/or property to which he   has
• Defendants  have been unjustly  enriched by their acts in contravention  of their
• fiduciary duties. Klein holds  an interest in the assets, monies, and/or properties    at
• issue as described
• Dr. Klein is informed  and believes,  and thereon alleges that  Defendants
• have appropriated these assets, monies,  and/or property,  which in tum has  deprived
• him of his interest in the properties and assets described herein.   Defendants  have
• received benefits as a result of their usurpation of corporate funds and personal    assets
• at the expense of Dr. Klein and his businesses, and under circumstances  that make   it
• unjust for them to retain  such benefits.   By virtue of the unfair advantage Defendants

i     11      have obtained because of their misappropriation and concealment of funds due and

“z<‘

g        12      payable to Dr. Klein, Defendants  should be required  to make restitution  of their  ill-

g\gotten gains.

113. In addition to the properties, funds and assets enumerated and discussed above, the exact additional property and assets to which Dr. Klein is entitled is capable of exact determination after an accounting and through resolution of this action.
114. Accordingly, Defendants are holding these properties and assets   in

• constructive trust for Dr. Klein and are required to return those properties and assets   to
•                                                                                                                                                                       SIXTH CLAIM FOR RELIEF

• (Avoidance and Recovery of Fraudulent Transfers (11U.S.C. § 544, California
• Civil Code section 3439 et seq.) – Against Defendants Muhammad Khilji, Jason
• Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)
• Plaintiff repeats  and realleges  each and every foregoing and  subsequent
• allegation contained in the Complaint,  as though  said paragraphs  were set forth in full
• 28

\

a\’\Khilji and Pfeiffer transferred Dr. Klein’s funds and assets to themselves, the Khilji/Pfeiffer Entities  and/or third

116. Klein is informed and believes, and thereon alleges that Khilji and Pfeiffer made the transfers with actual intent to hinder, delay or defraud Dr. Klein’s creditors.
117. Khilji, Pfeiffer and the Khilji-Pfeiffer Entities took the transfers with actual or constructive knowledge that the transfers were made with funds from Dr. Klein and that the funds were obtained by defrauding Dr.
118. Creditors exist who would be entitled to avoid these transactions under the California Uniform Fraudulent  Transfer
119. Based on the foregoing, Dr. Klein is entitled to set aside the fraudulent transfers pursuant to 11 U.S.C. § 544 and California Civil Code § 3294, et seq., and, if applicable, recover the equivalent  value of the transfer  from Defendants pursuant  to 11 U.S.C.  550.

\

SEVENTH CLAIM FOR RELIEF

(Avoidance of Fraudulent Transfer and Obligation (11U.S.C. § 548) – Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)

121. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
122. Klein received less than reasonably equivalent value in exchange for the funds and assets Khilji and Pfeiffer transferred to themselves, the Khilji/Pfeiffer Entities and/or third parties.
123. Klein is informed and believes, and thereon alleges that (i) by virtue of the above-described transfers, Dr. Klein was insolvent or became insolvent as a result of the transfers; or (ii) by virtue of, and at the time of, the transfers, Dr.   Klein

21

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2

3

4

5

6

7

8

9

10

0

“”0′             11

 

>-<                        “‘     13

was engaged in or was about to engage in business or a transaction for which his remaining  assets were unreasonably  small in relation to the business  or transaction.

124. Based on the foregoing, the transfers constitute fraudulent transfers and may be avoided pursuant to  11 U.S.C.  548.

EIGHTH CLAIM FOR RELIEFh said paragraphs were set forth in full herein.

 

(Money Had and Received -Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)

125. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as thoug
125. As discussed above, Khilji and Pfeiffer were placed in a position of   trust

by Dr. Klein, and they were able to and did access and possess money that was properly for the use of Dr. Klein and his   businesses.

127. As explained herein, Defendants  also withdrew  equity from the Windsor

Property and used Dr. Klein’s funds and credit in violation of their duties and without authorization  and not for the benefit  of Dr. Klein or his businesses.

87806.2

128. As a result of Defendants’  wrongful  and unauthorized  expenditures and

withdrawals of both credit and funds, they are indebted to Dr. Klein in an amount to be proven  at trial, but in any event an amount not less than   $10,000,000.00.

NINTH CLAIM FOR RELIEF

(Unjust Enrichment -Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)

129. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
130. The conduct of Defendants as predicated on the acts above has secured and will secure them assets, profits and value that inequitably unjustly enrich them to the detriment of Dr. Klein and that they would not have but  for Dr. Klein’s assets   and

22TENTH CLAIM FOR RELIEF

(Negligence -Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES  1-50)

131. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
132. As both accountants, bookkeepers and business managers, Defendants owed Dr. Klein a duty to protect his interests  and owed him a duty of care.
133. Defendants breached these duties by engaging in the fraudulent transactions, forgeries, embezzlement  and other misconduct  described
134. As a result of these breaches, Dr. Klein has been, and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but for Defendants’  wrongful
135. The substantial injuries suffered by Dr. Klein were foreseeable  at  the

87806.2

time Defendants failed to comply with their duties of integrity and disclosure and their obligation to refrain  from fraudulent  conduct to Dr. Klein’s  prejudice.

136. Defendants also breached their duty of care owed to Dr. Klein by  engaging in improper activities that resulted in excessive billings to Dr. Klein for services  either never rendered  or rendered below  the professional  standards of care. As a direct and proximate result  of Defendants’  failures of care, Dr. Klein was forced   to pay and did in fact pay excessive amounts for Defendants’  services to his
137. As a direct and proximate result of Defendants’ negligence, Dr. Klein has suffered damages including in an amount to be proven at trial, but believed to be in excess of $10,000,000 (ten million  dollars).

23

1                 ELEVENTH  CLAIM FOR RELIEF

• (Negligence -Against Defendant Z & P Investment Services, LLC
• and DOES 1-50)
• Plaintiff repeats and realleges  each and every foregoing  and  subsequent
• allegation contained in the Complaint, as though said paragraphs  were set forth in   full
• Z & P Investment  Services, by and through  its representatives  Jeffrey  R.
• Zone and Claudia L. Peltier, held itself out as an expert in providing investment   and
• financial management services to individuals like Dr. Klein.   In labeling themselves   as
• financial advisors and investment managers, Defendants encouraged Dr. Klein to rely on Defendants’ special skill and expertise in supervising and managing Dr. Klein’s investment and retirement . In particular, Z & P Investment Services was entrusted with the management of Dr. Klein’s ample investment and retirement  accounts  at TD Ameritrade.

140. Defendants breached  these duties by failing to prevent Khilji and/or Pfeiffer’ s fraudulent transactions, forgeries, embezzlement and other misconduct described herein, which ultimately caused Dr. Klein’s accounts at TD Ameritrade to  be depleted in excess of $2 million.   In permitting  and/or failing to prevent  this

• misconduct, Z & P Investment  Services failed to adhere to its ordinary standards   of
• care, including but not limited to requiring written authorization for   significant
• transactions involving investment  or retirement  accounts managed  by Z & P
• Investment
• As a result  of these breaches,  Dr. Klein has been, and will be, forced  to
• suffer substantial financial losses and other harms described herein, each   of which
• would not have happened but for Defendants’ neglect  of duties and failures to
• The substantial injuries suffered by Dr. Klein were foreseeable    at the
• time Z & P Investment Services failed to comply with its internal  safeguards   and/or
• fraud prevention policies, failed to alert Dr. Klein to and take reasonable  steps  to

87806.2

::Q        ;c

depositors, account holders and investors. Defendants are subject to numerous laws, policies and regulations that are intended to prevent identify theft, financial fraud, embezzlement and other wrongful conversion of monies and assets. Defendants are obligated to manage accounts, verify account activity and issue appropriate safeguards  in response  to potentially  fraudulent  activity (including filing required  reports of such

• activity), and owe such duties to all depositors, account holders  and investors.
• Defendants permitted  accounts to be opened in the name of Dr. Klein   and
• his businesses without taking reasonable  steps to ensure that Dr. Klein authorized  such
• account By failing to take reasonable  efforts to confirm the propriety  of
• these accounts, or to otherwise fulfill their obligations  of due care,  Defendants
• provided Khilji and Pfeiffer with the mechanisms  by which·to perpetuate  their
• Defendants  allowed and/or failed to prevent  Khilji and Pfeiffer  from
• withdrawing, fraudulently transferring  and conveying,  and otherwise wrongfully
• removing Dr. Klein’s assets that were held with Defendants.   Defendants   also
• performed inappropriate  favors for Khilji and Pfeiffer,  and used atypical banking
• procedures to service the accounts, at the expense of Dr. Klein.  Defendants knew   that

I       Khilji and Pfeiffer were engaged in unlawful activities.  Without Defendants’

• assistance, Khilji and Pfeiffer would have not succeeded in their fraudulent
• Defendants breached these duties by failing to prevent Khilji and/or
• Pfeiffer’ s fraudulent transactions, forgeries, embezzlement and other misconduct
• described herein, which ultimately caused Dr. Klein’s accounts to be depleted in an
• amount believed to be in excess of $10 million. In permitting and/or failing to prevent
• this misconduct, Defendants failed to adhere to ordinary standards of care, including
• but not limited to proper verification of the authenticity of Dr. Klein’s signature on
• signature cards, transaction authorization forms and other key banking

I O                    149.      As a result of these breaches, Dr. Klein has been, and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but for Defendants’ neglect of duties and failures to act.

150. The substantial injuries suffered by Dr. Klein were foreseeable at the time Defendants failed to comply with external and internal safeguards and/or fraud prevention policies and general standards of care governing banking and investment fund
151. As a direct and proximate result of Defendants’ negligence, Dr. Klein has suffered damages including in an amount to be proven at trial, but believed to be in

• excess of $10,000,000 (ten million dollars).
• THIRTEENTH CLAIM  FOR RELIEF
• (Aiding and Abetting – Against Defendants  The Private Bank of  California,
• Excel National Bank, TD Ameritrade,  and DOES  1-50)
• Plaintiff repeats and realleges each and every foregoing and subsequent
• allegation contained in the Complaint, as though said paragraphs were set forth in full
• Defendants had actual knowledge of the unlawful purpose of Khilji and
• Pfeiffer in connection with the conversion of Klein’s money and property through
• fraudulent account and banking

• Defendants  acted with the intent or purpose of committing,   encouraging
• and/or facilitating Khilji and Pfeiffer’s  fraudulent  and unlawful  activities described
• herein, including the wrongful  withdrawal  and  fraudulent  conveyance of Dr. Klein’s
• assets that were held with
• Defendants  knowingly  and intentionally promoted,  counseled, induced
• and provided substantial assistance to Khilji and Pfeiffer  in the commission  of the
• fraudulent and unlawful actions set forth herein,  including the wrongful  conversion  of
• money, property and other assets belonging to Dr.
• As a result  of Defendants’  intentional  misconduct,  Dr. Klein has been,
• and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but  for Defendants’

157. As a direct and proximate result of Defendants’ conduct, Dr. Klein has suffered damages including in an amount to be proven at trial, but believed to be in excess of $10,000,000 (ten million dollars).
158. The aforementioned conduct of Defendants was intentionally malicious, deceitful, fraudulent, and done with the intent of depriving Dr. Klein of his property and legal rights and to cause him injury. Defendants’ conduct was and is despicable and subjected Dr. Klein to cruel and unjust hardship in conscious disregard    of his

• rights so as to justify  an award of exemplary and punitive

20                     FOURTEENTH  CLAIM FOR RELIEF

• (Rescission – Against Defendants Able Investment Services, LLC,
• NXT Equities Incorporated and DOES 1-50)
• Plaintiff repeats  and realleges  each and every foregoing and  subsequent
• allegation contained in the Complaint, as though  said paragraphs were set forth in  full
• At all material times, Plaintiff is and has been the owner    of the Windsor
• 28

27

87806.2

1                                                       161.  Able and NXT have asserted their intent to institute a nonjudicial

• foreclosure sale of the Windsor Property based upon documents, some or all of which
• contain forged signatures purporting to be Plaintiff s or were procured by fraud. As
• such, Able and/or NXT have no right, title, interest or estate in the Windsor
• Plaintiff s interest in the Windsor Property is adverse to Defendants’
• claims of right of
• Plaintiff seeks to rescind the deed, promissory note and/or any other
• documents that were executed in connection with this purported loan transaction as of
• October 21, 2010. Plaintiff will tender the proceeds of the loan that were legitimately
• and appropriately applied to or for the benefit of the Windsor

i    11                   164.      An actual controversy has arisen between Plaintiff and Defendants.

12               Plaintiff has no adequate remedy at law because of the unique nature of the Windsor

“”‘._      g ; 13        Property.

vv,, E.       14                   165.    Plaintiff  seeks a judicial  declaration  that the title to the

Windsor      Property

i      15      is vested in Plaintiff alone and that Defendants, and each of them, be declared to have

;!;

<               16      no estate, right, title or interest in the Windsor Property, and that Defendants, and each

j

::E             17       of them, be forever enjoined from asserting any estate, right, title or interest in the

• Windsor Property adverse to Plaintiff s
• FIFTEENTH CLAIM FOR RELIEF
• (Negligence – Against Defendants Able Investment Services, LLC, NXT Equities
• Incorporated and DOES 1-50)
• Plaintiff repeats and realleges each and every foregoing and subsequent
• allegation contained in the Complaint, as though said paragraphs were set forth in full
• In or about December 2009, Able and NXT obtained documents and
• information affecting right, title and interest to real property belonging to
• Defendants failed to exercise reasonable and due care to ensure that Plaintiff was
• actually the source and the signatory to the above-described

28

87

1                                                       168.      Defendants had a duty to confirm that Plaintiff was in fact the person

• who signed the documents before they encumbered Plaintiff s real property or
• otherwise created any alleged
• Defendants breached their duty to Plaintiff by, among other things,
• failing to notarize the above-described documents in the format and with the forms of
• identification required by
• As a proximate result of Defendants’ actions and failures to comply with
• their duties of care, as herein alleged, Plaintiff has been damaged in an amount to be
• proven at
• SIXTEENTH CLAIM FOR RELIEF

11

(Rescission -Against Defendants Dominion Mortgage Corporation, Allen

“‘

V.C. Davis as trustee for Davis Trust No. 1U/A/T November 7, 1961 and

DOES 1-50)

171. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
172. At all material times, Plaintiff is and has been the owner of the Laguna Property. Plaintiff is the trustee of the 1995 Arnold William Klein Revocable

• Dominion and Davis have asserted their intent to institute foreclosure
• and/or seek other recourse against the Laguna Property based upon documents, some
• or all of which contain forged signatures purporting to be Plaintiff s or were procured
• by fraud. As such, Dominion and/or Davis have no right, title, interest or estate in the
• Laguna
• Plaintiff s interest in the Laguna Property is adverse to Defendants’
• claims of right of
• Plaintiff seeks to rescind the deed, promissory note and/or any other
• documents that were executed in connection with this purported loan transaction as of 28

2November 17, 2010. Plaintiff will tender the proceeds of the loan that were legitimately and appropriately applied to or for the benefit of the Laguna   Property.

176. An actual controversy has arisen between Plaintiff and Defendants. Plaintiff has no adequate remedy at law because of the unique nature of the Laguna Property.
177. Plaintiff seeks ajudicial declaration that the title to the Laguna Property  is vested in Plaintiff alone and that Defendants, and each of them, be declared to have no estate, right, title or interest in the Laguna Property, and that Defendants, and each of them, be forever enjoined from asserting any estate, right, title or interest in the Laguna Property  adverse to Plaintiff s

SEVENTEENTH CLAIM FOR RELIEF

(Negligence -Against Defendants Dominion Mortgage Corporation, Allen

V.C. Davis as trustee for Davis Trust No. 1U/A/T November 7, 1961 and DOES 1-50)

178. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
179. In or about June 2010, Dominion and Davis obtained documents and information affecting right, title and interest to real property belonging to Plaintiff. Defendants failed to exercise reasonable and due care to ensure that Plaintiff was actually the source and the signatory to the above-described
180. Defendants had a duty to confirm that Plaintiff was in fact the person who signed the documents before they encumbered Plaintiff s real property or otherwise created any alleged
181. Defendants breached their duty to Plaintiff by, among other things, failing to notarize the above-described documents in the format and with the fonns of identification  required by

182. As a proximate result of Defendants’ actions and failures to comply with their duties of care, as herein alleged, Plaintiff has been damaged in an amount to be proven at

EIGHTEENTH  CLAIM FOR RELIEF

(Avoidance of Fraudulent Obligations (11U.S.C. § 544, California Civil Code section 3439 et seq.) – Against Defendants Able Investment Services, LLC, NXT Equities Incorporated, Dominion Mortgage Corporation, Allen V.C. Davis as trustee for Davis Trust No. 1U/A/T November 7, 1961 and DOES  1-50)

183. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
184. Klein allegedly incurred the fraudulent obligations  in connection  with

the Windsor Property and the Laguna Property to Able /NXT and Dominion/Davis, respectively,  without receiving  a reasonably equivalent value in exchange  for the

assets and/or money  transferred.

17

185. Klein is informed and believes, and thereon alleges that (i) by virtue of the above-described fraudulent  obligations, Dr. Klein was insolvent  or became

• insolvent as a result of the transfers; or (ii) by virtue of, and at the time of,   the
• transfers, Dr. Klein was engaged in or was about to engage in business  or a transaction
• for which his remaining assets were unreasonably  small in relation to the business  or
• Creditors exist who would be entitled to avoid these transactions   under
• the California Uniform Fraudulent  Transfer
• Based on the foregoing, Dr. Klein is entitled to    set aside the fraudulent
• transfers pursuant to 11 U.S.C.  544 and California Civil Code § 3294, et seq., and,  if
• applicable, recover the equivalent value of the transfer from Defendants pursuant to 27 11 U.S.C. §

28

1                                                NINETEENTH  CLAIM FOR RELIEF

• (Avoidance of Fraudulent Transfer and Obligation (11U.S.C. 548) – Against
• Defendants Against Defendants Able Investment Services, LLC, NXT Equities
• Incorporated, Dominion Mortgage Corporation, Allen V.C. Davis as trustee for
• Davis Trust No. 1U/A/T November 7, 1961 and DOES 1-50)
• Plaintiff repeats and realleges each and every foregoing and  subsequent
• allegation contained in the Complaint, as though said paragraphs were set forth in  full
• Dr. Klein received  less than reasonably  equivalent value in exchange for
• the fraudulent obligations in connection with the Windsor Property and the Laguna Property to Able /NXT and Dominion/Davis, respectively,.
  190. Klein is informed and believes, and thereon alleges that (i) by virtue of the above-described transfers, Dr. Klein was insolvent or became insolvent as a result of the transfers; or (ii) by virtue of, and at the time of, the transfers, Dr. Klein was engged in or was about to engage in business or a transaction for which his remaining assets were unreasonably small in relation to the business or  transaction.
  191. Based on the foregoing, the transfers constitute fraudulent transfers and may be avoided pursuant to 11 U.S.C.  548.

19                                                                                                                                                                       TWENTIETH  CLAIM FOR RELIEF

• (Declaratory and Injunctive Relief -All Defendants)
• Plaintiff repeats and realleges each and every foregoing and  subsequent
• allegation contained in the Complaint, as though said paragraphs were set forth in  full
• An actual controversy has arisen and now exists between Plaintiff  and
• Defendants concerning their respective rights, duties, and interests regarding
• Klein’s monies, real properties and other
• Plaintiff requests a judicial  determination of the parties’ rights and  duties
• as set forth herein and ajudicial determination that Defendants cannot seek to  enforce

1     transactions that were fraudulently entered into by Khilji and/or Pfeiffer,   including

2      without limitation any effort to foreclose upon the Windsor Property   or the Laguna

• A judicial declaration is necessary and appropriate at this time under  the
• circumstances in order that Dr. Klein may ascertain his rights vis-a-vis Able,  NXT,
• Dominion and/or Davis, and as to those Defendants’  claimed right to proceed  with
• the threatened foreclosure of the Windsor Property and/or the Laguna
• Defendants Able, NXT, Dominion  and/or Davis’  actions have
• undermined any purported right to proceed with foreclosure of the Windsor  Property
• or the Laguna Property and have interfered with Dr. Klein’s right of possession as the owner of the Windsor Property and/or the Laguna

197. Klein requests injunctive relief, first as to the threatened foreclosure  of the Windsor Property and the Laguna Property, and second precluding Defendants from engaging in the wrongful  conduct described hereinabove  in the future.
198. A judicial declaration is necessary and appropriate so the parties may ascertain their respective rights, duties and

PRAYER FOR RELIEF

• WHEREFORE, Plaintiff respectfully prays for judgment against Defendants,  as
• follows:

\20       1.         For compensatory and consequential  damages in an amount to be  proven

21      at trial;

• 22 For punitive and/or exemplary damages in an amount sufficient   to

23      punish, deter, and make an example of  Defendants;

25                  4.

For declaratory  and/or injunctive relief;

For a determination that the fraudulent transfers described herein   are

26      fraudulent transfers within the meaning of 11 U.S.C.  § 544 and California  Civil Code 27      § 3439 et seq.;

28

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87806

• For a determination that the fraudulent obligations described herein as
• fraudulent obligations within the meaning of 11 U.S.C. 548;
• For turnover of the fraudulent transfers and obligations pursuant to 11 4        u.s.c. § 542;

5                  7.

6                  8.

For an order compelling Defendants to provide an accounting;

For attorney’s fees, costs and expenses incurred herein to the extent

7      recoverable under law; and

8                  9.         For  such other and further relief as the Court may deem just    and proper. 9

10      DATED:  June 27, 2011                              MILLER BARONDESS, LLP

DEMAND FOR JURY TRIAL

Ifand to the extent available at law, Plaintiff Arnold W. Klein hereby demands a jury trial.

19

20       DATED:  June 27, 2011                              MILLER BARONDESS, LLP

By: J\    

Mira : Hashmall Attorneys  for Plaintiff

24                                                                                   ARNLD W. KLEIN. M.D.

34

87806.2

2

182. As a proximate result of Defendants’ actions and failures to comply with their duties of care, as herein alleged, Plaintiff has been damaged in an amount to be proven at trial.

EIGHTEENTH  CLAIM FOR RELIEF

(Avoidance of Fraudulent Obligations (11U.S.C. § 544, California Civil Code section 3439 et seq.) ­ Against Defendants Able Investment Services, LLC, NXT Equities Incorporated, Dominion Mortgage Corporation, Allen V.C. Davis as trustee for Davis Trust No. 1U/A/T November 7, 1961 and DOES 1­50)

183. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
184. Klein allegedly incurred the fraudulent obligations  in connection  with

the Windsor             Property and the Laguna Property to Able /NXT and Dominion/Davis, respectively, without                   receiving  a reasonably equivalent value in exchange  for the

1        JURISDICTION AND VENUE

• This Court has jurisdiction over this adversary proceeding pursuant to 28 3 U.S.C. §§ 151, 157 and 1334.

• Venue in this Court is proper pursuant to 28 U.S.C. § 1409 as this
• adversary proceeding arises in or relates to a case under Title 11 which is pending in
• this
• This adversary proceeding is a core proceeding as defined by 28 U.S.C. § 8 157(b).

9                                                          FACTUAL BACKGROUND

10                 A.        Dr. Arnold W. Klein

22. Dr. Klein is a pioneer in the field of cosmetic dermatology. After graduating from the University of Pennsylvania, School of Medicine, Dr. Klein completed his post­graduate education at Cedars­Sinai Medical Center and his medical residencies in dermatology at the Hospital of the University of Pennsylvania and the University of Calif

THE PARTIES

4. Arnold W. Klein, M.D. is an individual who resides in the County of Los Angeles  in ;the State of California. Dr. Klein is the trustee of the 1995 Arnold William Klein M.D. Revocable Trust.

.Dr. Klein’s trust  and confidence were misplaced.                                                                                                            Dr.  Klein discovered that his investment accounts were raided, bank accounts were opened in his name without his knowledge  and then pilfered,  and his assets were jeopardized.                                                                                                            In the

• process, multiple  documents were  forged, altered or signed under  false pretenses.
• The discovery of this  covert  scheme was compounded by the revelation
• that several financial  and banking  institutions  failed to exercise due care in connection
• with Dr. Klein’s          Time and time  again, there were opportunities  for thesery

• suffered by Dr. Klein at the hands of his trusted advisors. Instead, they failed him.                                                                                                   As
• a result, the assets that Dr. Klein worked long apon information and belief, Muhammad Khilji is an individual who resides in the County of Orange in the State of

4. Upon information and belief, Jason Roger Pfeiffer is an individual who resides in the

County of Los Angeles in the State of            California.

5. Upon information and belief, Khilji­Pfeiffer, LLC is a limited liability company organized and existing under the laws of California, with its principal place of business in the County of Los Angeles in the State of
6. Upon information and belief, Khilji & Klein, LLP is an  unknown business  entity which conducts business in the County of Los Angeles in the                   State of

California.

7. Upon information and belief, The Private Bank of California is a corporation Upon information and belief ational Bank is an unknownorganized and existing under the laws of California, with its principal place of business in the County of Los Angeles in the State of California.

• 8 of Dr. Klein and/or his medical businesses. Klein was not informed  of these

2

87806.2

• Upon information  and belief, Able Investment  Services, LLC is a  limited
• liability company organized and existing under the laws of Nevada, which                                                                                                                                          conducts
• business in the County of Los Angeles in the State of
• Upon information  and belief, NXT Equities Incorporated  is a  corporation
• organized and existing under the laws of California,  with its principal  place of
• business in the County of Los Angeles in the State of California.
• Upon information  and belief,  Dominion Mortgage  Corporation is a corporation organized and existing under the laws of California, with its principal place of business in the County of Los Angeles in the                State of California.
16. Upon information and belief, Allen V.C. Davis, as trustee for Davis Trust No. I U/A/T November 7, 1961, is an individual who resides in the County of Los Angeles in the State of California.
23. Plaintiff is informed and believes, and on that basis alleges, that Defendants DOES 1 through 50, inclusive, are individually and/or jointly liable to Plaintiffs for the conduct alleged herein. The true names and capacities, whether individual, corporate, associate or otherwise, of Defendants DOES 1 through 50, inclusive, are unknown to Plaintiff at this time. Accordingly, Plaintiff sues Defendants DOEornia at Los Angeles (UCLA).

24.                   Dr. Klein has maintained a private dermatology practice in Beverly Hills

for more than 35 years. He is at the forefront of the latest methods and treatments in

:!

z

18

19      authorized signers, and dated August 18, 2009.  The signature 28

87806.2

• of Arnold W. Klein as President is reflected  on the document, but Dr. Klein  never
• signed it.
• In or around August 2009, Khilji and/or Pfeiffer  signed multiple
• documents that were submitted to Private Bank in connection with accounts in the
• name
• documents and did not authorize their submission. It appears that in at least one
• instance CatheKlein MD. 28

8

87806.2

• rine Coler of Private Bank approved forms that were submitted                 by
• Khilji and/or Pfeiffer without Dr. Klein’s knowledge  or authorization.                                                                                                                                   Coler did not
• contact Dr. Klein regarding this account
• Dr. Klein was not informed of the accounts opened by Khilji and Pfeiffer
• at Private Bank. He has never           stepped foot inside Private Bank or met with any bank
• representatives until the accounts were closed. In order to cover up their fraud, it appears that Khilji and Pfeiffer had Private Bank send account statements and other documents to address of Robery Lorsch’c accountsny39.

Private Bank never contacted Dr. Klein to verify any information relating to the creation or use of the multiple accounts in his name or in the name of his companies. Private Bank was aware that information relating to the multiple bank accounts was not being sent to Dr. Klein’s personal or professional address.                             Form of $1.6 million to various

 

• months after the accounts were opened, Private Bank failed to send account
• statements to Dr. Klein or take other steps to ensure he received notice of activity
• regarding bank accounts purportedly  opened in his name.
• In January 2010, Joyce E. Jicka of Private Bank wrote to                Muhammad
• In her email, Jicka stated that she “noticed  that all these account  statements  are
• still going.” It is unclear what Jicka meant when she referred to “NKSF”
• and it unclear why Jicka chose to communicate with Khilji via email instead of
• sending a letter to Dr. Klein’s attention. Jicka asked Khilji to send her a letter            asking
• for the address to be changed. Jicka listed the names and partial account numbers for 28

7

87806.2

1                                                    10 (ten) bank accounts with various names. Again, despite knowledge that account

• statements were not sent to Klein, Jicka made no effort to contact Dr. Klein.
• Apparently in response to Jicka’s request, in February 2010, Khilji wrote
• to Private Bank requesting that the address for account statements for ten

(10)

• accounts be changed to 435 North Roxbury , Suite 201, Beverly Hills, CA 90210: such that Dr. Klein never receivet the account statements.
• Arnold W. Klein MD ­xxx799 l
• Arnold W. Klein MD ­xxx8007
• Arnold William Klein MD ­xxx2366
• Arnold William Klein MD ­xxx2382
• Arnold William Klein MD ­xxx2390 Arnold William Klein MD ­xxx6409 Khilji­Pfeiffer ­xxx2358 Khilji­Pfeiffer ­xxx6417

Minimally Invasive ­xxx2473 Minimally Invasive ­xxx6490

42. At least two of the accounts appear to bear the name “Khilji­Pfeiffer.” Dr. Klein is informed and believes that Khilji and Pfeiffer used an entity they created, Khilji­Pfeiffer, LLC, to facilitate numerous fraudulent transactions and to

funnel

• funds that were unlawfully converted from Klein’s bank and investment accounts.
• Private Bank records reveal that Jicka, Coler and other employees of
• Private Bank actively facilitated the fraudulent activities of Khilji and Pfeiffer by
• meeting solely with Khilji, processing transactions affecting Klein’s accounts
• without proper documentation and concealing the Khilji­Pfeiffer

• In May 2010, Khilji signed a document titled “Cash Management Client
• Enrollment & Agreements/Disclosures Acceptance Form” for Private Bank and
• representing himself as “Power of Attorney” for accounts in the name of Arnold

• In May 2010, Khilji and Pfeiffer also executed documents to authorize
• wire transfers and on­line banking access for Dr. Klein’s personal, business and
• accounts at Private Bank. 4
  46. Klein’s signature is not evident on any of these documents.

5

47. Khilji and Pfeiffer used the accounts at Private Bank to pilfer hundredsthousands  if not millions  of dollars from Dr. Klein without his knowledge.

7                  D.nts.

Excel National Bank

In November  2009, without  Dr. Klein’s knowledge,  Pfeiffer  and Khilji

other

of

9      opened payroll  and revenue  accounts in the name of Dr. Klein’s medical practice                                                                                                                                          at

• Excel National Bank (“Excel Bank”) with Insider Assistane of Bradley Sharp and attorney John Reitman who are closely eonnected to Priv

dustry

• protections for suspicious transaction activity involving Dr. Klein’s accou

• Pfeiffer also charged  exorbitant amounts to an American  Express  credit

• card account that he made “paperless” so as to evade discove1y. Dr. Klein believes

9

87806.2

activity.

• Khilji also participated in and benefitted  from this fraudulent credit card

• Khilji for the liquidation of substantial assets held               by
• Klein at TD Ameritrade. Khilji’s requests for wire transfers  and asset

liquidationtten authorization from Dr. Klein for these transactions.                   Z & P  Investment

 

10

87806.2

• Khilji and Pfeiffer used  funds in the Private Bank and Excel Bank accounts to pay                                                                                                                                              the

raised         red

request      or

• would typically be received on one day’s notice. This alone should have

• flags for Dr. Klein’s trusted   Z & P Investment  Services did not

• receive wri

• Services also did not provide Dr. Klein with prompt written notice of the fund transfer
• or liquidation requests before the transactions  were completed.                  Z & P Investment
• Services failed to contact Dr. Klein despite having his home, business and                    personal
• cellular phone numbers.
• Instead,  Z & P Investment  Services processed  repeated transactions until
• Klein’s hard­earned retirement  and investment  funds were almost  completely
• Finally, when there was little money left in Dr. Klein’s                 once­lucrative

0″”

• 1

• accounts at TD Ameritrade, Z & P Investment  Services washed its hands of its                    long­
• time client. In or about August 2009, Z & P Investment Services, LLC stopped providing services to Dr. Klein.

59. In a matter of approximately eight months, over $2.2 million was withdrawn from Dr. Klein’s investment portfolios without his authorization.
60. The Windsor Property
61. Dr. Klein has owned a residence at 553 South Windsor Boulevard in Los Angeles, California since 1976 (the “Windsor Property”).                 In 2009, Dr. Klein  had

• significant equity in the property that is viewed as a historic landmark.
• In December  2009, without  Dr. Klein’s knowledge  or authority, Khilji
• with the assitan
• bearing 5% interest to be secured by the Windsor Property.                 The  transaction
• apparently involved NXT Equities Incorporated  (“NXT”)  as broker  and Able
• Investment Services, LLC (“Able”)  as lender.             The terms  of the transaction are
• atypical and lack business justification given the value of the Windsor
• Many of the documents relating to the residential  loan are unsigned.                    A
• number of the documents also reflect inaccuracies in information  regarding
• Klein’s age and length of employment, as well  as other obviously  incorrect

6

7

8

9

 

biographical information. In addition, critical information regarding lender costs is blank and documents fail to comply with requirements set forth in Civil Code section 1189.

63. On or about December 16, 2009, in reliance upon the documents described herein, Able distributed the su

63. Klein first learned about the Able loan secured by the Windsor Property in late summer of 2010.                                                                                           Dr. Klein ceased all payments  on the Able loan                                                                                 until an investigation  could be conducted. Because Dr. Klein did not authorize the  Able loan, and because he believes his signature on the loan documents was either forged or obtained under false pretenses, Dr. Klein discontinued payments  on the             loan.
64. On or about October 21, 2010, a Notice of Default and Election to Sell Under Deed of Trust was recorded against the Windsor
65. The Laguna Property
66. Klein has owned a residence at 31025 Pacific Coast Highway in Laguna Beach, California since  1991 (the “Laguna Property”).
67. In or around February 2010, Jason Pfeiffer contacted Inge Bunn, a real estate broker who had worked with Dr. Klein for many years. Pfeiffer told Bunn that

• and Dr. Klein.
• Pfeiffer asked Bunn to preliminary­market  the Laguna property as                a
• 806.2

1

70. Pfeiffer and Khilji took extensive steps to conceal their unauthorized attempt to list the Laguna Property from Dr. Klein. Pfeiffer told Bunn to remove any marketing brochures from the Laguna Property because Dr. Klein would be entertaining guests at the home over the weekend. Pfeiffer and Khilji also prohibited Bunn from placing any signage regarding the listing at the property.
71. In April 2010, without Dr. Klein’s knowledge, Khilji submitted a loan application to Dominion Mortgage Corporation for the purposes of obtaining a loan secured by the Laguna Property. Dr. Klein did not sign the loan application and did not know that an application had been completed in his name.
72. In June 2010, Khilji emailed Bunn and informed her that Dr. Klein was going through a financial transaction regarding the Laguna Property. Khilji told Bunn that an individual named Loren Thall would be involved in the sale and would receive a 0.5% commission. Khilji also said the property had to be listed in the Multiple Listing Service (MLS). Khilji requested information from Bunn regarding the property’s value and comparative listings.                                                  Thall also contacted Bunn about placing     the property  on the MLS.
73. On June 4, 2010, Dunn received an email from Khilji stating “we have a consensus on listing price of $11,900,000.” Khilji’s email

70. was also sent to Thall and

 

stated the “[t]hree of us need to work together  and make it happen.                   I know it will  take sometime but we should be shooting for March      2011.”

74. There is a listing agreement dated June 5, 2010 purporting to reflect Dr. Klein’s signature on behalf of the “1995 Klein Arnold W. Trust,” which is not the correct name of the trust that holds Dr. Klein’s Laguna Property. Dr. Klein never signed the listing agreement and had no knowledge that Khilji and Pfeiffer were conspiring to sell his Laguna Property behind his
75. In or around June 2010, Khilji and/or Pfeiffer fraudulently executed certain documents in connection with a mortgage loan bearing 12% interest to be secured by the Laguna Property. The transaction  apparently involved Dominion

13

• Mortgage Corporation (“Dominion”) and Allen V.C. Davis, trustee for Davis Trust
• 1 U/A/T November 7, 1961 (“Davis”) as lender. The terms of the transaction are
• atypical and lack business justification  given the value of the Laguna
• Many of the documents relating to the residential loan are unsigned.                                                                                                                          A
• number of the documents  fail to comply with requirements  set forth in Civil  Code
• section 1189.
• On or about June 8, 2010, in reliance upon the documents                 described
• herein, Dominion and Davis  distributed an unknown  sum in connection with  the
• principle loan amount of $1.5 million.
• Dr. Klein first learned about the Dominion/Davis  loan secured                  by the Laguna Property in fall of 2010. Because Dr. Klein did not authorize the Dominion/Davis loan, and because he believes his signature on the loan documents was either forged or obtained under false pretenses, Dr. Klein did not make payments  on the loan.

79. On or about November 17, 2010, a Notice  of Default  and of Lender’s Intent to Exercise its Remedies Under Loan Documents was recorded against the Laguna Property.

H.                         Dr. Klein Discovers the Fraudulent Scheme

19  80.            In late summer of 2010, upon returning  from a trip, Dr. Klein attempted

• to use his American Express credit  card for a nominal                    The card was denied;
• the denial came as a complete shock to Dr.
• Thereafter,  Dr. Klein learned that his finances had been                 substantially
• depleted, that several loans had been taken out without his knowledge, and that
• substantial funds had been fraudulently withdrawn  from his investment  and retirement
• accounts without  his knowledge.
• In September 2010, Dr. Klein terminated  his relationship  with Khilji. 27

28

FIRST CLAIM FOR RELIEF

(Breach of Fiduciary Duty ­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)

83. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full
84. Klein placed trust and confidence in Khilji and Pfeiffer to exercise their duties as business managers, bookkeepers and accountants with integrity and good faith. Khilji and Pfeiffer accepted Dr. Klein’s trust and confidence, and actively encouraged him to rely upon them in the conduct of his financial affairs.
85. By virtue of their provision of business management and accounting services as described above, Khilji and Pfeiffer owed fiduciary duties to Dr. Klein with respect to his business and personal financial affairs, including but not limited to duties to act diligently and faithfully, to disclose all relevant and material information, to properly account for all assets, and to act with the utmost care and

::j

86. Khilji and Pfeiffer breached their fiduciary duties to Dr. Klein by, among other things, taking out lines of credit and making other loan arrangements secured by Dr. Klein’s property and using the proceeds for their personal use; diverting and siphoning millions of dollars from Dr. Klein’s bank and investment accounts without his knowledge or authorization; writing and negotiating numerous checks from Dr. Klein’s accounts and concealing their activity; charging unauthorized expenses for credit cards opened in Klein’s name and using the funds for their personal use; failing and refusing to disclose their activities to Dr. Klein; and putting Dr. Klein in a position of financial ruin and immediate peril.
87. As an instrument of their breaches of duty, Khilji and Pfeiffer used their companies, Khilji­Pfeiffer, LLC and Khilji and Klein, LLP (the “Khilji/Pfeiffer

15

1        Entities”), to perpetuate their fraudulent transactions  and conversion of Dr. Klein’s

2  assets and property.

• As a direct, actual, and foreseeable result of Defendants’ breaches   of
• fiduciary duty, Dr. Klein has been damaged in an amount that has not yet been fully
• ascertained, but in any event an amount not less than $10,000,000.00.
• The aforementioned  conduct of Defendants was intentionally deceitful,
• fraudulent, and done with the intent of depriving Dr. Klein of his property and legal
• rights and to cause him injury. Defendants’  conduct was and is despicable  and
• subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights
• so as to justify an award of exemplary and punitive

11                                                                                                                                                                 SECOND CLAIM FOR RELIEF

• (Conversion ­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)
  90. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.

91. As described above, Defendants removed funds and property from Dr. Klein’s assets. That property includes, for example, equity in the Windsor Property, which was obtained and used by Defendants through fraudulent transactions. That property also includes credit, which Defendants obtained and used through their excessive and unauthorized use of credit cards belonging to Dr. Klein. Defendants converted the equity and credit into cash, which they kept and used for their personal use and not for the benefit of Dr. Klein or his medical practice. And the property includes cash, which Defendants withdrew from bank, investment and retirement accounts containing the Dr. Klein’s
92. These uses of property were for Defendants’ sole benefit and were without permission of Dr. Klein, in direct violation of the duties Defendants owed

110Dr. Klein as business managers and trusted bookkeeper/accountant. Accordingly, Defendants took property to which they were not entitled.

93. Defendants also removed valuable personal property from the Laguna Property without Klein’s knowledg .
94. These acts constitute conversion of property that Klein has an ownership interest in.
95. Klein has on several occasions demanded return of the funds taken, but to no

avail.

96. As a direct, actual, and foreseeable result of Defendants’ conversion, Klein has

been damaged in an amount that has not yet been fully ascertained, but in any event an amount not less than $10,000,000.00.

97. The aforementioned conduct of Defendants was intentionally deceitful, fraudulent, and done with the intent of depriving Klein of his property and legal

rights and to cause him injury. Defendants’ conduct was and is despicable and

z  subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights so as to justify an award of exemplary and punitive damages.

THIRD CLAIM FOR  RELIEF

187806.2

(Fraud/Deceit/Concealment ­ Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)

98. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full
99. As described herein, Khilji and Pfeiffer obtained Dr. Klein’s signature on key documents under false pretenses and for purposes that were not disclosed to Dr. Klein. Khilji and Pfeiffer made these false statements and misrepresentations with the intention that Klein would rely thereon. Khilji and Pfeiffer also failed to disclose, and otherwise concealed, material information regarding their activities relating to Dr. Klein’s real property assets, bank accounts, credit cards and other property interests.

1Klein did in fact rely upon Khilji and Pfeiffer’s representations and

• misleading statements to his detriment, and it was foreseeable that he would  do     so.

• If Dr. Klein had been  aware of Khilji and Pfeiffer’s  true purposes  22

• and
• intentions, he would not have signed the documents  as requested.           In many instances,
• Klein was never made aware of the true nature or purpose of the documents. If  he
• had known the truth, he would not have permitted Khilji and Pfeiffer to

exercise

• control over his professional and personal  financial affairs.
• As described  herein, Khilji and Pfeiffer also forged Dr. Klein’s            signature
• on many key financial documents,  including loan documents,  credit applications,
• investment sell and liquidation requests and other transaction                  authorization

8                11      documents.

“‘

102. As a direct, actual, and foreseeable result of Defendants’ fraud        and forgeries, Dr. Klein has been damaged in an amount that has not yet been fully ascertained, but  in any event an amount not less than  $10,000,000.00.
103. The aforementioned conduct of Defendants was intentionally deceitful, fraudulent, and done with the intent of depriving Dr. Klein of his property and legal rights and to cause him injury. Defendants’ conduct was and is despicable and subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights

so

• as to justify an award of exemplary and punitive
• FOURTH CLAIM FOR RELIEF
• (Accounting ­ All Defendants)
• Plaintiff repeats and realleges  each and every foregoing and  subsequent

• allegation contained in the Complaint, as though said paragraphs were set forth in full
• As alleged above, a fiduciary relationship  existed between Dr. Klein                    and
• Khilji and Pfeiffer. A fiduciary and/or contractual relationship  also existed                      between
• Klein and Z & P Investment Services, LLC, as well as TD Ameritrade. As a result 28

18

87806.2

Klein and

• of the conduct alleged herein, a relationship  also existed between

• Private Bank, Excel Bank, Able, NXT, Dominion  and
• Due to Khilji  and Pfeiffer’ s wrongful  acts as alleged above,

Defendants

• are indebted to Dr. Klein in an amount that can only be ascertained by an accounting.
• For example, an accounting  of the assets held by TD Ameritrade,  Private

Bank  and

• Excel Bank and unlawfully converted or fraudulently transferred  by

Khilji  and

• Pfeiffer is required to determine the amount of indebtedness.                 And the amount       of
• credit and home  equity taken and used by Defendants  (including Dr. Klein’s  interest
• in the Windsor Property, which is currently subject to a claim by Able and/or NXT,
• and Dr. Klein’s interest in the Laguna Property, which is currently subject to a claim

i      11      by Dominion and/or Davis), the extent of which is currently unknown to Dr. Klein,

 

2.2

must be accounted for.

107. Due to the foregoing, an accounting is required to determine the exact amount Defendants owe Dr. Klein.

FIFTH CLAIM FOR RELIEF

(Fraudulent Conveyance ­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)

108. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
109. As alleged above, Defendants have committed acts constituting, among other things, fraud, breach of fiduciary duty and conversion.
110. Defendants’ acts have removed property from Dr. Klein’s possession and prevented Dr. Klein from accessing his property and other assets. Title to certain property, purchased by Khilji and/or Pfeiffer with Dr. Klein’s funds and without his knowledge or authorization, has not been properly transferred to Dr. Klein.
111. Klein is informed and believes, and thereon alleges, that Defendants removed assets, monies, and/or property  of Dr. Klein’s assets and businesses  and

19

• prevented him from accessing such assets, monies, and/or property to which he has
• Defendants  have been unjustly  enriched by their acts in contravention  of their
• fiduciary duties. Dr. Klein holds an interest in the assets, monies, and/or properties at
• issue as described
• Dr. Klein is informed and believes, and thereon alleges that Defendants
• have appropriated these assets, monies, and/or property, which in tum has deprived
• him of his interest in the properties and assets described herein.                  Defendants  have
• received benefits as a result of their usurpation of corporate funds and personal                                                                                                                           assets
• at the expense of Dr. Klein and his businesses, and under circumstances  that make                                                                                                                                       it
• unjust for them to retain  such benefits.            By virtue of the unfair advantage Defendants

i      11      have obtained because of their misappropriation and concealment of funds due and

“z<‘

g      12      payable to Dr. Klein, Defendants  should be required  to make restitution  of their ill8

gotten gains.

113. In addition to the properties, funds and assets enumerated and discussed above, the exact additional property and assets to which Dr. Klein is entitled is capable of exact determination after an accounting and through resolution of this action.
114. Accordingly, Defendants are holding these properties and assets                  in

21                                                                                                                                                                          SIXTH CLAIM FOR RELIEF

• (Avoidance and Recovery of Fraudulent Transfers (11U.S.C. 544, California
• Civil Code section 3439 et ) ­ Against Defendants Muhammad Khilji, Jason
• Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)
• Plaintiff repeats  and realleges  each and every foregoing and  subsequent
• allegation contained in the Complaint,  as though  said paragraphs  were set forth in ful8

 

SEVENTH CLAIM FOR RELIEF

(Avoidance of Fraudulent Transfer and Obligation (11U.S.C. § 548) ­ Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)

121. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
122. Klein received less than reasonably equivalent value in exchange for the funds and assets Khilji and Pfeiffer transferred to themselves, the Khilji/Pfeiffer Entities and/or third parties.
123. Klein is informed and believes, and thereon alleges that (i) by virtue of the above­described transfers, Dr. Klein was insolvent or became insolvent as a result of the transfers; or (ii) by virtue of, and at the time of, the transfers, Dr. Klein

 

was engaged in or was about to engage in business or a transaction for which his remaining assets were unreasonably  small in relation to the business  or transaction.

124. Based on the foregoing, the transfers constitute fraudulent transfers and may be avoided pursuant to  11 U.S.C.  548.

EIGHTH CLAIM FOR RELIEF

(Money Had and Received ­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)

125. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
126. As discussed above, Khilji and Pfeiffer were placed in a position of                   trust

by Dr. Klein, and they were able to and did access and possess money that was properly for the use of Dr. Klein and his            businesses.

…….i                 ::r: .:..;

127. As explained herein, Defendants  also withdrew  equity from the Windsor

Property and used Dr. Klein’s funds and credit in violation of their duties and without authorization and not for the benefit  of Dr. Klein or his businesses.

06.2

128. As a result of Defendants’ wrongful and unauthorized  expenditures and withdrawals of both credit and funds, they are indebted to Dr. Klein in an amount to be proven at trial, but in any event an amount not less than                                                $10,000,000.00.

NINTH CLAIM FOR RELIEF

(Unjust Enrichment ­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)

129. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
130. The conduct of Defendants as predicated on the acts above has secured and will secure them assets, profits and value that inequitably unjustly enrich them to the detriment of Dr. Klein and that they would not have but  for Dr. Klein’s assets   and

22

1

2

3

4::  :.:i

financial resources. Dr. Klein hereby requests the disgorgement of all assets, profits, and value unjustly earned  or retained by  Defendants.

TENTH CLAIM FOR RELIEF

(Negligence ­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1­50)

131. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
132. As both accountants, bookkeepers and business managers, Defendants owed Dr. Klein a duty to protect his interests and owed him a duty of care.
133. Defendants breached these duties by engaging in the fraudulent transactions, forgeries, embezzlement and other misconduct  described herein.
134. As a result of these breaches, Dr. Klein has been, and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but for Defendants’ wrongful
135. The substantial injuries suffered by Dr. Klein were foreseeable  at  the

19

28

87806.2

time Defendants failed to comply with their duties of integrity and disclosure and their obligation to refrain  from fraudulent  conduct to Dr. Klein’s prejudice.

136. Defendants also breached their duty of care owed to Dr. Klein by engaging in improper activities that resulted in excessive billings to Dr. Klein for services either never rendered or rendered below the professional standards of care. As a direct and proximate result of Defendants’ failures of care, Dr. Klein was forced to pay and did in fact pay excessive amounts for Defendants’  services to his
137. As a direct and proximate result of Defendants’ negligence, Dr. Klein has suffered damages including in an amount to be proven at trial, but believed to be in excess of $10,000,000 (ten million dollars).

23

1                 ELEVENTH  CLAIM FOR RELIEF

• (Negligence ­Against Defendant Z & P Investment Services, LLC
• and DOES 1­50)
• Plaintiff repeats and realleges each and every foregoing and subsequent
• allegation contained in the Complaint, as though said paragraphs  were set forth in                                                                                                                                                full
• Z & P Investment  Services, by and through  its representatives  Jeffrey R.
• Zone and Claudia L. Peltier, held itself out as an expert in providing investment                                                                                                                                                    and
• financial management services to individuals like Dr. Klein.                  In labeling themselves                                                                                               as
• financial advisors and investment managers, Defendants encouraged Dr. Klein to rely on Defendants’ special skill and expertise in supervising and managing Dr. Klein’s investment and retirement accounts. . In particular, Z & P Investment Services was entrusted with the management of Dr. Klein’s ample investment and retirement accounts at TD Ameritrade.

140. Defendants breached  these duties by failing to prevent Khilji and/or Pfeiffer’ s fraudulent transactions, forgeries, embezzlement and other misconduct described herein, which ultimately caused Dr. Klein’s accounts at TD Ameritrade to be depleted in excess of $2 million.       In permitting  and/or failing to prevent  this

• misconduct, Z & P Investment  Services failed to adhere to its ordinary standards                                                                                                                                                      of
• care, including but not limited to requiring written authorization for                    significant
• transactions involving investment  or retirement  accounts managed  by Z & P
• Investment Services.
• As a result  of these breaches,  Dr. Klein has been, and will be, forced  to
• suffer substantial financial losses and other harms described herein, each                    of which
• would not have happened but for Defendants’ neglect  of duties and failures to
• The substantial injuries suffered by Dr. Klein were foreseeable                   at the

• time Z & P Investment Services failed to comply with its internal  safeguards                     and/or
• fraud prevention policies, failed to alert Dr. Klein to and take reasonable  steps  to

24

87806.2

0,,..

<

• prevent potentially  fraudulent  activity, and failed to exercise due care in  accordance
• with standards governing the asset management
• As a direct and proximate  result  of Defendants’  negligence,  Dr. Klein has
• suffered damages including in an amount to be proven at trial, but believed                      to be in
• excess of $2,000,000 (two million dollars).
• TWELFTH CLAIM FOR RELIEF

7                                                                   (Negligence ­Against Defendants The Private Bank of California, Excel

• National Bank, TD Ameritrade, Inc. and DOES 1­50)
• Plaintiff repeats  and realleges each and every foregoing and                  subsequent
• allegation contained in the Complaint, as though said paragraphs were set forth in                      full

!    12

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145. Defendants are financial institutions  that owe duties of care to  their

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…              …..,    V’)

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depositors, account holders and investors. Defendants are subject to numerous laws, policies and regulations that are intended to prevent identify theft, financial fraud, embezzlement and other wrongful conversion of monies and assets. Defendants are obligated to manage accounts, verify account activity and issue appropriate safeguards in response to potentially fraudulent activity (including filing required  reports of such

• Defendants permitted  accounts to be opened in the name of Dr. Klein           and
• his businesses without taking reasonable  steps to ensure that Dr. Klein authorized  such
• account activity. By failing to take reasonable  efforts to confirm the propriety  of
• these accounts, or to otherwise fulfill their obligations  of due care,  Defendants
• provided Khilji and Pfeiffer with the mechanisms  by which∙to perpetuate  their fraud.
• Defendants  allowed and/or failed to prevent  Khilji and Pfeiffer  from
• withdrawing, fraudulently transferring  and conveying,  and otherwise wrongfully
• removing Dr. Klein’s assets that were held with Defendants.                 Defendants      also
• performed inappropriate  favors for Khilji and Pfeiffer,  and used atypical banking
• procedures to service the accounts, at the expense of Dr. Klein.  Defendants knew                      that

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87806.2

I              Khilji and Pfeiffer were engaged in unlawful activities. Without Defendants’

• assistance, Khilji and Pfeiffer would have not succeeded in their fraudulent
• Defendants breached these duties by failing to prevent Khilji and/or
• Pfeiffer’ s fraudulent transactions, forgeries, embezzlement and other misconduct
• described herein, which ultimately caused Klein’s accounts to be depleted in an
• amount believed to be in excess of $10 In permitting and/or failing to prevent
• this misconduct, Defendants failed to adhere to ordinary standards of care, including
• but not limited to proper verification of the authenticity of Klein’s signature on
• signature cards, transaction authorization forms and other key banking documents.

I O                 149.  As a result of these breaches, Dr. Klein has been, and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but for Defendants’ neglect of duties and failures to act.

150. The substantial injuries suffered by Dr. Klein were foreseeable at the time Defendants failed to comply with external and internal safeguards and/or fraud prevention policies and general standards of care governing banking and investment fund
151. As a direct and proximate result of Defendants’ negligence, Klein has suffered damages including in an amount to be proven at trial, but believed to be in

19     excess of $10,000,000 (ten million dollars).

• THIRTEENTH CLAIM  FOR RELIEF
• (Aiding and Abetting ­ Against Defendants  The Private Bank of  California,

• Excel National Bank, TD Ameritrade,  and DOES  1­50)
• Plaintiff repeats and realleges each and every foregoing and subsequent
• allegation contained in the Complaint, as though said paragraphs were set forth in full
• Defendants had actual knowledge of the unlawful purpose of Khilji and
• Pfeiffer in connection with the conversion of Klein’s money and property through
• fraudulent account and banking

26

87806.2

• Defendants acted with the intent or purpose of committing, encouraging
• and/or facilitating Khilji and Pfeiffer’s  fraudulent  and unlawful  activities

described

• herein, including the wrongful  withdrawal  and  fraudulent  conveyance

of Dr. Klein’s

• assets that were held with
• Defendants knowingly and intentionally promoted, counseled, induced
• and provided substantial assistance to Khilji and Pfeiffer in the commission of the
• fraudulent and unlawful actions set forth herein, including the wrongful conversion of
• money, property and other assets belonging to Dr.
• As a result of Defendants’ intentional misconduct, Dr. Klein has been,
• and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but for Defendants’

157. As a direct and proximate result of Defendants’ conduct, Dr. Klein has suffered damages including in an amount to be proven at trial, but believed to be in excess of $10,000,000 (ten million dollars).
158. The aforementioned conduct of Defendants was intentionally malicious, deceitful, fraudulent, and done with the intent of depriving Dr. Klein of his property and legal rights and to cause him injury. Defendants’ conduct was and is despicable and subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his

19  rights  so as to justify  an award of exemplary and punitive  damages.

20                                                                                                                                              FOURTEENTH  CLAIM FOR RELIEF

• (Rescission ­ Against Defendants Able Investment Services, LLC,

• NXT Equities Incorporated and DOES 1­50)
• Plaintiff repeats  and realleges  each and every foregoing and  subsequent
• allegation contained in the Complaint, as though  said paragraphs were set forth in  full
• At all material times, Plaintiff is and has been the owner                  of the Windsor
• 28

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87806.2

1                                                    161. Able and NXT have asserted their intent to institute a nonjudicial

• foreclosure sale of the Windsor Property based upon documents, some or all of which
• contain forged signatures purporting to be Plaintiff s or were procured by fraud. As
• such, Able and/or NXT have no right, title, interest or estate in the Windsor
• Plaintiff s interest in the Windsor Property is adverse to Defendants’
• claims of right of
• Plaintiff seeks to rescind the deed, promissory note and/or any other
• documents that were executed in connection with this purported loan transaction as of
• October 21, Plaintiff will tender the proceeds of the loan that were legitimately
• and appropriately applied to or for the benefit of the Windsor

i      11                  164.   An actual controversy has arisen between Plaintiff and Defendants.

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12               Plaintiff has no adequate remedy at law because of the unique nature of the Windsor

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a s § E.                    14  165.     Plaintiff  seeks a judicial  declaration that the title to the Windsor Property

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i       15     is vested in Plaintiff alone and that Defendants, and each of them, be declared to have

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<               16     no estate, right, title or interest in the Windsor Property, and that Defendants, and each

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::E          17     of them, be forever enjoined from asserting any estate, right, title or interest in the

18     Windsor Property adverse to Plaintiff s herein.

• FIFTEENTH CLAIM FOR RELIEF
• (Negligence ­ Against Defendants Able Investment Services, LLC, NXT Equities
• Incorporated and DOES 1­50)
• Plaintiff repeats and realleges each and every foregoing and subsequent
• allegation contained in the Complaint, as though said paragraphs were set forth in full
• In or about December 2009, Able and NXT obtained documents and
• information affecting right, title and interest to real property belonging to
• Defendants failed to exercise reasonable and due care to ensure that Plaintiff was
• actually the source and the signatory to the above­described

28

87806.2

1                                                     168. Defendants had a duty to confirm that Plaintiff was in fact the person

• who signed the documents before they encumbered Plaintiff s real property or
• otherwise created any alleged
• Defendants breached their duty to Plaintiff by, among other

things,

• failing to notarize the above­described documents in the format and

with the forms of

• identification required by
• As a proximate result of Defendants’ actions and failures to comply with
• their duties of care, as herein alleged, Plaintiff has been damaged in an amount to be
• proven at
• SIXTEENTH CLAIM FOR RELIEF
• (Rescission ­Against Defendants Dominion Mortgage Corporation, Allen

“‘

V.C. Davis as trustee for Davis Trust No. 1U/A/T November 7, 1961 and

DOES 1­50)

171. Plaintiff repeats and realleges each and every foregoing and subsequent

allegation contained in the Complaint, as though said paragraphs were set forth in full herein.

172. At all material times, Plaintiff is and has been the owner of the Laguna Property. Plaintiff is the trustee of the 1995 Arnold William Klein Revocable

Trust.

• Dominion and Davis have asserted their intent to institute foreclosure
• and/or seek other recourse against the Laguna Property based upon documents, some
• or all of which contain forged signatures purporting to be Plaintiff s or were procured
• by As such, Dominion and/or Davis have no right, title, interest or estate in the
• Laguna

• Plaintiff s interest in the Laguna Property is adverse to Defendants’
• claims of right of
• Plaintiff seeks to rescind the deed, promissory note and/or any other
• documents that were executed in connection with this purported loan transaction as of 28

29

87806.2

3

4

5

6

7

8

9

10

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20

21

22

23

24

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87806.2

November 17, 2010. Plaintiff will tender the proceeds of the loan that were legitimately and appropriately applied to or for the benefit of the Laguna  Property.

176. An actual controversy has arisen between Plaintiff and Plaintiff has no adequate remedy at law because of the unique nature of the Laguna Property.
177. Plaintiff seeks ajudicial declaration that the title to the Laguna Property is vested in Plaintiff alone and that Defendants, and each of them, be declared to have no estate, right, title or interest in the Laguna Property, and that Defendants, and each of them, be forever enjoined from asserting any estate, right, title or interest in the Laguna Property adverse to Plaintiff s herein.

SEVENTEENTH CLAIM FOR RELIEF

(Negligence ­Against Defendants Dominion Mortgage Corporation, Allen

V.C. Davis as trustee for Davis Trust No. 1U/A/T November 7, 1961 and DOES 1­50)

178. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full
179. In or about June 2010, Dominion and Davis obtained documents and information affecting right, title and interest to real property belonging to Plaintiff. Defendants failed to exercise reasonable and due care to ensure that Plaintiff was actually the source and the signatory to the above­described documents.
180. Defendants had a duty to confirm that Plaintiff was in fact the person who signed the documents before they encumbered Plaintiff s real property or otherwise created any alleged indebtedness.
181. Defendants breached their duty to Plaintiff by, among other things, failing to notarize the above­described documents in the format and with the fonns of identification required by

30

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assets and/or money  transferred.

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185. Klein is informed and believes, and thereon alleges that (i) by virtue of the above­described fraudulent  obligations, Dr. Klein was insolvent  or became

• transfers, Dr. Klein was engaged in or was about to engage in business or a transaction
• for which his remaining assets were unreasonably  small in relation to the business  or
• Creditors exist who would be entitled to avoid these transactions                  under
• the California Uniform Fraudulent  Transfer Act.
• Based on the foregoing, Dr. Klein is entitled to               set aside the fraudulent
• transfers pursuant to 11 U.S.C.  544 and California Civil Code § 3294, et seq., and,  if
• applicable, recover the equivalent value of the transfer from Defendants pursuant to 27 11 U.S.C. § 550.

28

31

87806.2

1                                                NINETEENTH  CLAIM FOR RELIEF

2      (Avoidance of Fraudulent Transfer and Obligation (11U.S.C. § 548) ­

Against Equities

• Defendants Against Defendants Able Investment Services, LLC, NXT

• Incorporated, Dominion Mortgage Corporation, Allen C. Davis as

trustee for

• Davis Trust No. 1U/A/T November 7, 1961 and DOES 1­50)
• Plaintiff repeats and realleges each and every foregoing and subsequent

• allegation contained in the Complaint, as though said paragraphs were set forth in full

• Dr. Klein received less than reasonably equivalent value in exchange for

• the fraudulent obligations in connection with the Windsor Property and the Laguna Property to Able /NXT and Dominion/Davis, respectively,.
  190. Klein is informed and believes, and thereon alleges that (i) by virtue of the above­described transfers, Dr. Klein was insolvent or became insolvent as a result of the transfers; or (ii) by virtue of, and at the time of, the transfers, Dr. Klein was engged in or was about to engage in business or a transaction for which his remaining assets were unreasonably small in relation to the business or transaction.
  191. Based on the foregoing, the transfers constitute fraudulent transfers and may be avoided pursuant to 11 U.S.C.  548.

19                                                                                                                                                                       TWENTIETH  CLAIM FOR RELIEF

• (Declaratory and Injunctive Relief ­All Defendants)

• Plaintiff repeats and realleges each and every foregoing and  subsequent
• allegation contained in the Complaint, as though said paragraphs were set forth in full
• An actual controversy has arisen and now exists between Plaintiff  and
• Defendants concerning their respective rights, duties, and interests regarding
• Klein’s monies, real properties and other
• Plaintiff requests a judicial  determination of the parties’ rights and  duties
• as set forth herein and ajudicial determination that Defendants cannot seek to enforce

1     transactions that were fraudulently entered into by Khilji and/or Pfeiffer, including

2      without limitation any effort to foreclose upon the Windsor Property  or the Laguna

• A judicial declaration is necessary and appropriate at this time under the
• circumstances in order that Dr. Klein may ascertain his rights vis­a­vis Able, NXT,
• Dominion and/or Davis, and as to those Defendants’  claimed right to proceed with
• the threatened foreclosure of the Windsor Property and/or the Laguna
• Defendants Able, NXT, Dominion  and/or Davis’ actions have
• undermined any purported right to proceed with foreclosure of the Windsor Property
• or the Laguna Property and have interfered with Klein’s right of possession as the owner of the Windsor Property and/or the Laguna Property.
  197. Klein requests injunctive relief, first as to the threatened foreclosure of the Windsor Property and the Laguna Property, and second precluding Defendants from engaging in the wrongful conduct described hereinabove in the future.
  198. A judicial declaration is necessary and appropriate so the parties may ascertain their respective rights, duties and

PRAYER FOR RELIEF

• WHEREFORE, Plaintiff respectfully prays for judgment against Defendants, as
• follows:

20      1.        For compensatory and consequential  damages in an amount to be  proven

21      at trial;

∙22                  2.         For punitive and/or exemplary damages in an amount sufficient   to

23      punish, deter, and make an example of  Defendants;

For declaratory  and/or injunctive relief;

For a determination that the fraudulent transfers described herein  are

26      fraudulent transfers within the meaning of 11 U.S.C.  § 544 and California  Civil Code 27

• 3439 et seq.;

 

• For a determination that the fraudulent obligations described herein as

• fraudulent obligations within the meaning of 11 U.S.C. 548;

• For turnover of the fraudulent transfers and obligations pursuant to 11 4

u.s.c. § 542; 5      7.

For an order compelling Defendants to provide an accounting;

For attorney’s fees, costs and expenses incurred herein to the extent

9.         For  such other and further relief as the Court may deem just                    and proper. 9

10      DATED:  June 27, 2011                              MILLER BARONDESS, LLP

DEMAND FOR JURY TRIAL

Ifand to the extent available at law, Plaintiff Arnold W. Klein hereby demands a jury trial.

19

20      DATED:  June 27, 2011                              MILLER BARONDESS, LLP

B                                                                                              Mira : ashmall Attorneys  for Plaintiff

24                                                                                                                              ARNLD W. KLEIN. M.D.

25

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Source: | homeowners bill of rights on WordPress.com

26

Arnold W. Klein, MD

9615 Brighton Way, M110, Beverly Hills, CA 90210

IN THE SUPERIOR COURT OF CALIFORNIA COUNTY OF ORANGE

ARNOLD W. KLEIN, M.D., Plaintiff, v. Ron Freed an individual Bradley SharpI an individual, John Reitman,an indivividua, Al Tippe, An individuall, THE PRIVATE BANK OF CALIFORNIA, a California corporation; BANC OF CALIFORNIA, a California corporation EXCEL NATIONAL BANK, a California banking corporation, CITY NATIONAL BANK, a California and DOES 1-50, Defendants

) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No.: C COMPLAINT FOR: 1.        Elder Abuse; and 2.        Declaratory Relief Dated this___ day of June, 2015 Arnold W. Klein, MD Pro Per 9615 Brighton Way, M-110   Beverly Hills, CA 90210

Plaintiff Arnold W. Klein, M.D. (Plaintiff or “Dr. Klein”) alleges for his Complaint against Defendants Muhammad Khilji, The Private Bank of California, Excel National Bank, City National Bank, Bradley Sharp ,John Reitman,  Al Tippe ,  Ron Freed

INTRODUCTION

Plaintiff Arnold W. Klein, M.D., is a senior citizen subject to the protection of the California State Courts from abuse, specifically financial elder abuse which banks are mandated to report, and is a highly respected doctor and pioneer in cosmetic dermatology and a respected academician His successful practice spans more than 39 years. .. He is the, victim of a money laundering scheme involving his ex-accountant Muhammad Khilji who erected 22 accounts at three Financial   institutions in Dr Klein’s name. The institutions were the Flower St Branch of City National Bank of City, Excel National Bank and Private Bank of California. The Bank insiders who assisted Khilji were Ron Freed and Attorney Al Tippe  of City National Bank and Bradley Sharp and Attorney John Reitman of Private Bank  In California The laws surrounding Money Laundering are extremely severe As will be  shown Bradley Sharp and John Reitman(an attorney) and Ron Freed  together  with Al tippe  erected or as bank insiders helped erect 22 bank accounts by identity theft of Arnold Klein,a 70 year old disabled physician in Collusion with Muhammad Khilj, a foreign national. for the sole purpose of robbing a disabled elder of his life savings by money laundering of $80 million dollar.in exchange for fraudulent mortgages on Dr Klein’s Properties . An attorney who disguises or aid in disguising the source of the funds or  the nature of violation of this section shall be punished by by a fine of not more than two hundred fifty thousand dollars ($250,000) or twice the value of the property transacted, whichever is greater, or  both              five hundred thousand dollars ($500,000) or five times the value of the property transacted, whichever is greater. As the value increase so does the penalty.They  have   stolen over $80 million dollars of  Klein’s  funds including his retirement  Klein was overmedicated by Bradley Sharp and Muhammaf Khilji  into  Bankruptcy court (A B140)(BC400.1) where in he was guaranteed a swift, trial against the the embezzler,bank insider, institutions  fraudulent mortgages.  In that he was overmedicated there this complaint cannotb e heard there The complaint is  The original complaint. Dr. Klein was guaranteed a trial by Jury in Bankruptcy Court and  was his sole  reason for  entering, the court,

Rule 9015. Jury Trials (a) Applicability of Certain Federal Rules of Civil Procedure. Rules 38, 39, 47–49, and 51, F.R.Civ.P., and Rule 81(c) F.R.Civ.P. insofar as it applies to jury trials, apply in cases and proceedings, except that a demand made under Rule 38(b) F.R.Civ.P. shall be filed in accordance with Rule 5005.(b) Consent To Have Trial Conducted by Bankruptcy Judge. If the right to a jury trial applies, a timely demand has been filed pursuant to Rule 38(b) F.R.Civ.P., and the bankruptcy judge has been specially designated to conduct the jury trial, the parties may consent to have a jury trial conducted by a bankruptcy judge under 28 U.S.C. §157(e) by jointly or separately filing a statement of consent within any applicable time limits specified by local rule. Dr Klein was having his cases heard in Superior by Phillip Boesch.Dr. Klein was about to have his first case heard in  2 weeks.

Dr. Klein had received the approval from Michael Jackson to sell some of his unfinished music(Michael Jackson lived with Dr Klein  for  30 years  or get a loan on Dr. Klein’s Laguna Home.

The entrance into Bankruptcy Court was irrational  due to mental incompetence because the fees Charged by Bankruptcy Attorneys are Astronomically high. Dr. Klein had close to $300 million in non financial assets, no debts and a medical practice   as of 2008 generated $ 4 million  and in 2009  generated  $4  to $5  million.

In the complaint he is correctly listed as Trustee “Arnold William Klein MD “when thr trustee used by the court as shown in their second amended complaint, was Arnold William Klein., Dr. Klein’s Judge Richard Neiter must be removed by Federal Judicial guidelines in that he has stock in Private Bank and Dr, Klein has not had a case heard in 5 years in violation of the  Due Process  Clause of the California and US Constitution. All Courts in California must adhere to the California Homeowners Bill of Rights. as well as Elder Abuse Laws.   One of Neiter’s first action’s was to illegally evict a disabled Elder from his medical office. The office was specifically built for Klein’s disability.Without  his associates  which Khilji and Sharp got rid of  Klein’s office sized needed to be decreased. Also the actions of Bradley Sharp together  with Kimberly Wilson and  the Medical Board Ca and Klein’s ex attorney Richard Charmley, Jason Pfeiffer who illegally    Dr. Klein’s Medical records of Michael Jackson in violation of HIPAA Dr, Klein had a covenant with Jackson never to release his records since the First molestation event.Klein’s records clearly showed he used 31 not 51 shots of Demerol reducing it to 100mgweek. Dr, Klein records showed he was one  gone all of May 2009  and Conrad Murray who killed Michael Jackson began work May 1^st.2009. the records of Dr. Klein reveal the long history of Jackson dating to 85 when he was addicted to propofol by Steve Hoefflin  and  how Dr. Klein withdrew Jackson from Propofol dependence in 9 and 2003. During the first molestation event in 93 Michael was dependent on Ativan,Valium.xanax and Propofol..Charnley illegally released the records to Sharp,AEG, Board members at Private Bank, City National Bank Flower St.Harvey Levin and Bradley Sharp to conceal his money laundering at City Nationl bank  on Fower Flower St. Bradley Sharp and John  Reitman  used these records,.purposely destoring the information contained to justify his illegal search and seizure at Klein’s Palm Springs house as well as the illegal seizure of over 200 million dollars worth of  items from Klein’s Windsor house . Sharp has used the written and Social media also to publizie the illegal sale and eviction of  Dr. Klein from his Laguna and Windsor house  based on the fraudulent Dominion and Able  loan. Both of which are well decribed in complaint below. These loans are mortgage fraud by identity theft  as seen in money Launderings Schemes.  Where in Khilji  made the loans with insider assistance of Sharp  and Reitman in Dr., Klein’s name deposited  in  accounts erected by identity theft  of Dr,Klein  at Private Bank.by Sharp and Reitman. Neither of these loans were made by Dr. Klein, contain his trust  or were deposited in accounts Dr Klein knew extisted.  All financial assets ($80 million) and nonfinancial assets(> $250 must be returned  to Dr. Klein whose trust is Arnold William Klein MD as shown in the Orginal Complaint.. The fraudulent trust the court is using as shown in the Original complaint  was never signed by Dr. Klein  the trust the court is using was made on March 20^{th. ,2009}  and is Arnold William Klein.  All court in California must adhere to the Homeowners Bill of Rights  and Rights as well  Elder Abuse Laws. Sharp and Reitman must be removed as Klein’s trustees in they failed to issue a SARS report and have long standing relationships with City National Bank and  Private Bank  Dr. Klein’s ability to survive financially increased when Klein was illegally evicted from his suite by Judge Richard Neiter who attempted to conceal the original complaint because he has stock in Private Bank and must be removed by Federal Judicial guidelines,When Klein asked Neiter to be removed from Bankrutcy Court showing him the letter from  his Neurologist les Weiner revealing the drugging by Sharp and Khilji he told Dr. Klein it was his problem. . Neiter cannot hear this  complaint in he failed to abide by he California Homeowners , Bill of Rights, Elder Abuse Laws and is automically disqualified by his stock in PtiKAdditionally the complaint clearly shows Dr Klein was not bankrupt when he entered the court but had  greater than $300 million in assets and filed a complaint against the fraudulent nature of the Dominion  and Able loan.Loan.Muhammad Khilji,Excel Bank.  And Theft of the  retirement . ecerected  accounts accounts accounts erected of  Dr. Klein of   $6.4  million  was through fraudulents by idetinty theft

.GG G and L the realtor were in contact with Bradley Sharp and once they evicted Dr. Klein they reduced it size for Dr. Klein’s associate

1. (Sharp, Khilji, Private Bank cc3345 $20 million)           AB-381 Estates and trusts: undue influence and elder abuse

 

Bradley Sharp and John Reitman have sold Dr, Klein’s homes based on Mortgage fraud by identity theft which is commonly seen in Money laundering Schemes, Sharp and Reitman helped Khilji make the loans in Dr, Klein’s name by identity theft then deposited the loans into accounts erected in Dr. Klein’s name at Private which were  set up by Sharp and Reitman   Im regard to the fraudulent  Dominion  and Able loans Dr,Klein’s Laguna Home  has been sold based on the basis of the  fraudulent Dominiom loan with a financial loss to  Dr. Klein of $47.6 million(cc4453, Khilji, Sharp,.Reitman, Freed, Tippe City National Bank, Private Bank .) AB-381 Estates and trusts: undue influence and elder abuse Klein’s Windsor residence has been sold on the basis of the  fraudulent  Able loan with a financial loss to Dr. Klein of S  2I4.8. Compassinate Plea for Relief by the Court. Presently, Dr. Klein is in desperate need of funds for  medication of his neuropathy which  includes Rituxin-‘($24,000 for each six month treatment). He needs funds for a Baclofen pump to reduce his spasticity ($ 50,000) as well as funds to  repair of damage from the heart attacks caused when his Trustee  withheld his SSI twice ($90.000), Dr. Klein also requires funds for a caregiver ($50,000) as well as a vehicle outfitted for a disabled  individual ($75,000).

2. Klein must prevent foreclosure on his Palm Springs home. Being without SSI for four days and thus unable to buy his medication compromised his health. Dr. Klein’s retirement funds are rightfully his and by compassionate plea may this be dealt with first to provide Dr. Klein with needed legal counsel, medical management, and a mode of transportation. Dr. Klein’s retirement funds of $6.4 million are rightfully his by State and Federal law and the Bankruptcy Reform Act of 2005. In the complaint below, bank records, forensic accounting, by Barbara Luna and  2^nd Amended Complaint.
3. It shows Muhammad Khilji Laundered $3 million of Dr, Klein’s retiremen through the fraudulent Corporate “Special Account  “ at City National Bank  Flower St with Insider Asstance  of on Freed and Attorney Al Tippe in 2008, In the “Second Amended Complaint” by Sharp, Reitman, Gurfein and the law firm of Landau, Gottfried and Bergaer  they showe  2 million was laundered through  the fraudulent Corporate accounts of Minimally Invasive Aesthetics, at Private  and approximately 1.4 million through the  fraudulent accounts at Excel  In the first page of the “Second Ammended Complaint” Sharp, Reitman, Gurfein and the law firm of Landau, Gottfried and Bergaer  attempt to “settle”  the money laundering  of Dr. Klein by Khilji  through accounts at City National,Bank,Private Bank and Excel Bank al of which is shown in the Original Complainr  They also attempt give Kleins’s Corporate income from 2009 – 2010 of  $ 5 million laundere through  the fraudulent Excel Accounts opened by Identity theft of Dr. Klein  by Khilji and Jason Pfeiffer  Klein’s office manager with Inside Assistance of Sharp and Reitman Presently Peter Gurfein is illegally withhoulding  $150,000 of Dr. Klein’s homestead for taxes due on the fraudulent Excel account as shown to be  fraudulent in the original ComplaintPresentlly Sharp, Reitman and Gurfein   and the Law firm of Landau, Gottfried and Bergerr are withholding $ 6 million dollars that is Rightfully Dr. Klein
4. Both Reitman and Sharp have long standing relationships with Private Bank and have been involved with this money laundering scheme involving Private Bank, Excel Bank , and City National Bank since 2008 as shown in the Second Amended Complaint.In the Second Amended Complaint by Sharp, Reitman and Gurfein   and the Law firm of Landau, Gottfried and Berger the State the Dominion  ana Able loan are fraudulent and  Dr. Klein they admit the accounts opened by Khilji, Pfeiffer and Lorsch were opened by identity theft of Dr. Klein  through which $5 million of Dr. Kleins funds  were laundered. The trustee  they use o trustee is Arnold Wlliam Klein.  Dr Klein’s trustee Arnold William Klein MD as showm in the   which calls for their removal as Klein’s trustee’s and fraud upon the court  and return of all financial
5. CODE OF CIVIL PROCEDURE SECTION 30-35  provides Dr. Klein   a 70 year old disabled Elder a right \ in California for a speedy trial by Jury. Dr. Klein’s rapid trial is critical in that his physician, Dr. Les Weiner, former chief of neurology at the Leslie Weiner Clinic and Neurology Research Institute Keck School at the University of Southern California Dr. Klein can survive another six months in his present condition shorter if Sharp as any contro. This is a plea for support, understanding, and for a rapid trial.
6. Dr. Arnold William Klein is the beneficiary of the Trust 1995 Arnold William Klein MD 553 S. Windsor Blvd.  He is a 70 year old disabled elder who is easily overmedicated. Dr. Klein has been robbed by a series of Bank Insiders and embezzlers who opened Bank Accounts by Identity theft, and Bank Fraud, to launder and steal his funds. Bank insiders Ron Freed  and Attorney Al Tippe of the Flower St Branch City National Bank. In regard to Bradley Sharp and Attorney  Johnom Reitman they have totally ignored Dr. Klein’s  complaint  shown herein

The Private Bank of California violated of Federal and California law These banks have sold his homes with fraudulent mortgages and laundered his funds. From having had close to $300  million in non-liquid assets and S80 million in liquid assets after this theft and massive fraud Dr. Klein is now Penniless.

6. Dr. Klein trusted his accountant, Muhammad Khilji, and his office manager, Jason Roger Pfeiffer, to fulfill their duties with integrity and candor. Dr. Klein also relied upon his long-time financial advisors, Jeff Zone and Claudia Peltier to protect his assets and exercise diligence in managing his investments. Sadly, Dr. Klein’s trust and confidence were misplaced. Dr. Klein discovered his investment accounts were raided, bank accounts opened in his name without his knowledge and then his assets pilfered. In the process, multiple documents were forged, altered or signed under false pretenses.
7. The discovery of this covert scheme was long delayed by the actions of Defendants and hidden from Dr. Klein.

Several financial and banking institutions not only failed to exercise due care in connection with Dr. Klein’s accounts, but, they actively participated with the embezzlers with their frauds and passed up many opportunities for these institutions to follow their own procedures and regulations and mitigate the harm suffered by Dr. Klein at the hands of his trusted advisors.

Instead, they did nothing. As explained herein, over a period of months, the fortune that Dr. Klein built through decades of hard work was destroyed. Dr. Klein discovered that his employees Khilji, Pfeiffer and an individual named Robert Lorsch were in collusion with Bradley Sharp an attoney John Reimam of  Private Bank of California and thereby opened ten (10) fraudulent accounts, eight (8) of which were in the name of Dr. Klein or his corporations and two (2) were in the name of Khilji-Pfeiffer, LLC.  These accounts were opened for the sole purpose of laundering most, if not all of Dr. Klein’s assets.  None of these accounts had a valid CIP code attached to them and a they were set-up with insider assistance of Bradley Sharp and Attorney John  Reitman to launder Dr. Klein’s stolen assets.

8. The Private Bank of California is responsible and practiced a careless disregard for legal or regulatory requirements and sound business practice when it opened the ten (10) fraudulent accounts by Khilji, Pfeiffer and Lorsch. Private Bank of California is responsible for its conduct and failure to follow up in the face of information that suggests probable money laundering or illicit activity.
9. Bradley Sharp and Attorney John Reitman at Private Bank, Excel Bank and the vice-presidents Ron Freed and Attorney Al Tippe of  City National Bank  were  aware of the suspicious transactions that were occurring, failed to issue SARS (Suspicious Activity Reports  as required by law and are also responsible for Dr. Klein’s losses.

Dr. Klein’s home in Palm Springs

1. In July 2008 Dr Klein purchased his house at 1401 Via Monte Vista, in Palm Springs giving his ex-accountant Muhammad Khilji a $1million down payment.
2. The home is financed through  City  National Bank on Flower Street which Dr. Klein never heard of and of which  he  was not aware
3. Dr. Klein bought the home furnished,but Michael Jackson put in $500.00 A.V. System and There is no quit trust deed
4. The Mortgage is not  signed by Klein but by Muhammad Khilji over which it is notarized
5. The trustee on the note  is Arnold William Klein
6. Klein’s Trustee “ Arnold William KleinMD”.
7. In California, eviction is a judicial process,
8. albeit summary.
9. However, once forged documents are presented
10. to a court
11. presenters may become guilty of felonies. Khilji
12. placed only $400,00 down
13. Dr Klein gave Muhammad Khiji, his ex accountant $1 million  down payment .Khilji  only placed

11,Keeping $600.000

12The deed of Trust is  Klein, Arnold William

13.which is not Klein’s deed of trust

14Klein, Arnold William is  the same

15fraudulent deed of  Trust used on the Illegal sale of

16Dr. Klein’s Laguna home  by Bradley Sharp of Private Bank,

17who is both a Bank insider at Private Bank   and Bankruptcy  trustee

18Confirming Bradley Sharp’s  involvement in this fraud since 2008,

 

 

City   National Bank on Flower St

 

• In July 2008 Khilji, Richard Charmley-
• Klein’s ex-accountant open 8 account in
• Klein’s name at City National Bank on Flower St
• with insider assistance of Ron Freed and Attorney Al Tippe
• By April 10^th 2010 they depleted $15-20 million from City National Bank Beverly Hills,
• $3 million from Ameritrade.

12. $2.7 million in credit lines and up to $40 million from Klein’s research arm Minimally invasive Aethetics.
13. In California, eviction is a judicial process,
14. albeit summary.
15. However, once forged documents are presented
16. to a court
17. presenters may become guilty of felonies. Khilji
18. placed only $400,00 down
20. Dr Klein gave Muhammad Khiji, his ex accountant $1 million  down payment .Khilji  only placed

11,Keeping $600.000

12The deed of Trust is  Klein, Arnold William

13.which is not Klein’s deed of trust

14Klein, Arnold William is  the same

15fraudulent deed of  Trust used on the Illegal sale of

16Dr. Klein’s Laguna house by Bradley Sharp of Private Bank,

17who is both a Bank insider at Private Bank   and Bankruptcy  trustee

18Confirming BradleySharp’s  involvement in this fraud since 2008, They ,

he will never get clear title

 

 

 

 

 

                  

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

the loan is Juy 2008from City National Flower  Street —Dr Klein has never been there but in July 2008  Khillji  with Dr. Klein’s  Ex-Attorney with  insider assitance of Ron Freed  and  attorney  Al tippe Dr. Klein’s Ex-Attorney would  \would open 8 accounts  in Dr. Klein’s name and launder all of his funds there from City National Bank in Beverly Hills until April 10^th,2010  when funds were depleted $20 million dollars.

3 million from Klein’s retirement  Ameritrade and through Special Account Additionally  40 million through MIA(Minimally Invasive Aesthetics removed about $2-3 million in cash

 

1. the loan is from City National Flower Street Branch
2. Dr, Klein has never been there.
3. In July 2008 Khillji with  Dr Klein’s Ex-Attorney
4. Richard Charnley with insider assistance of Ron Freed ,
5. and Attorney Al Tippe  would open 8 accounts  in
6. Klein’s name at City National Bank.
7. On 2/25/13 without warrant or list Bradley Sharp  of Private Bank  seized
8. 5 million Dollars worth art from  Dr. Klein’s Palm Springs House,
9. (many items gifted from Michael Jackson and not itemized.)
10. $ 2 milllion from Laguna home in art and furnishings that was in storage,. the same day
11. Sharp seizedthe only Car Dr. Klein was capable of driving
12. a 360 Ferrari converted for  his disability.
13. The loan was held by City National Bank  and Bradley Sharp of Private  is illegally seizing it Confirming the Conspiracy between City National Bank and Private Bank –value of car $250,000-300.000
14. POLICE CASE141OP-L3654 Sharp and his associate lawyer Peter Gurfein send  two women to   Klein’s home  in Palm Spings to supposedly help Dr, Klein with his case. They took over $1 million worth of Jewelry as wll as lithograph of Michael Jackson by Warhol  1$Also a book Dr. Klein was writing on Michael Jackson and a watch Michael Jackson gave Dr. Klein from the 9/11 concert in New York. Dr. Klein wants art and  Jewelry returned and car replaced.

Cc 3345 City National Bank. Khilji, Freed.Sharp Tippe, ,Reitman, Private Bank,   Bank $5.5  million )““““““““““““““““““““““`

AB-381 Estates and trusts: undue influence and elder abuse.

THE PARTIES

10. Arnold W. Klein, M.D. is an individual who was a resident of Orange County at 31025 Pacific Coast Highway, Laguna Beach, CA 92651 and 553 S Windsor Los Angeles  when these actions occured forming basis of his complaint. After losing his Los Angeles and and Orang county homes  based on the fraudulent Dominion and Able Loan shown in the original Complaint.“below““““““““`

1_ Defendant Muhammad Khilji (“Khilji”) is an individual who currently resides in the County of Orange, State of California

Defendant Ron Freed is an individual who currently resides in the County of los Angeles in thr, State of California

I

1. Plaint

Plaintiff Arnold W. Klein, M.D. (Plaintiff or “Dr. Klein”) alleges for his

• Complaint against Defendants  Muhammad  Khilji
• The Private Bank of California, Excel   National
• Bank, City National Bank .Bradley Shatp.Ron Freed,John Reitman,Al Rippe Medical Board of Ca and Does   I
• through 50, inclusive,  as follows:

INTRODUCTION To Original Complaint filed on 6/27/11 in LA Venue of Federal Bank ruptcu Court. This Complaint was concealed by Bradley Sharp.

Any alteration Will be noted in Italics

1. Plaintiff Arnold W. Klein, M.D. is a highly respected  doctor who  is

renowned  in his field as a pioneer  in dermatology.   Hesmaintainedasuccessfulmedical practice for more than 35 years  and helped raise over $320 million for HIV  and AIDS research.  Dr. Klein trusted his accountant, Muhammad  Khilji, and his  office manager, Jason Roger Pfeiffer, to fulfill their professional duties with integrity and candor. Dr. Klein also relied upon his long-time financial advisors to protect his assets  and  exercise diligence in managing his investments.

2. Dr. Klein’s trust and confidence were misplaced.   Dr.  Klein discovered that his investment accounts were raided, bank accounts were opened in his name without his knowledge  and then pilfered,  and his assets were jeopardized.   In  the

• process, multiple  documents were  forged, altered or signed under  false
• The discovery of this  covert  scheme was compounded by the  revelation
• that several financial  and banking  institutions  failed to exercise due care in connection
• with Dr. Klein’s    Time and time  again, there were opportunities  for these
• institutions to follow their own procedures and regulations  and mitigate the  harm
• suffered by Dr. Klein at the hands of his trusted advisors. Instead, they failed him.     As
• a result, the assets that Dr. Klein worked long and hard to build have been

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THE PARTIES

4. Arnold W. Klein, M.D. is an individual who resides in the County of Los Angeles in ;the State of California. Dr. Klein is the trustee of the 1995 Arnold William Klein M.D. Revocable
5. Upon information and belief, Muhammad Khilji is an individual who resides in the County of Orange in the State of
6. Upon information and belief, Jason Roger Pfeiffer is an individual who resides in the County of Los Angeles in the State of
7. Upon information and belief, Khilji-Pfeiffer, LLC is a limited liability company organized and existing under the laws of California, with its principal place of business in the County of Los Angeles  in the State of
8. Upon information and belief, Khilji  & Klein, LLP is an  unknown

business  entity which conducts business in the County of Los Angeles in the    State of

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California.

9. Upon information and belief, The Private Bank of California is a corporation organized and existing under the laws of California, with its principal place of business in the County of Los Angeles in the State of
10. Upon information and belief, Excel National  Bank is an unknown

• business entity which  conducts business in the County of Los Angeles in the State   of
• Upon information  and belief, Z & P Investment  Services, LLC is  a
• limited liability company organized and existing under the laws of California, with its
• principal place of business in the County of Orange in the  State of California.
• Upon information  and belief, TD Ameritrade,  Inc. is a corporation
• organized and existing under the laws of New York, which conducts business   in the
• County of Los Angeles in the State of California. 27

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• Upon information  and belief, Able Investment  Services, LLC is a  limited
• liability company organized and existing under the laws of Nevada, which   conducts
• business in the County of Los Angeles in the State of
• Upon information  and belief, NXT Equities Incorporated  is a  corporation
• organized and existing under the laws of California,  with its principal  place of
• business in the County of Los Angeles in the State of
• Upon information  and belief,  Dominion Mortgage  Corporation is a corporation organized and existing under the laws of California, with its principal place of business in the County of Los Angeles in the    State of California.
  16. Upon information and belief, Allen V.C. Davis, as trustee for Davis Trust No. I U/A/T November 7, 1961, is an individual who resides in the County of Los Angeles in the State of
  17. Plaintiff is informed and believes, and on that basis alleges, that Defendants DOES 1 through 50, inclusive, are individually and/or jointly liable to Plaintiffs for the conduct alleged herein. The true names and capacities, whether individual, corporate, associate or otherwise, of Defendants DOES 1 through 50, inclusive, are unknown to Plaintiff at this time. Accordingly, Plaintiff sues Defendants DOES  I  through  50, inclusive, by fictitious names and will amend

Complaint to allege their true names and capacities  after they are   ascertained.

18. Plaintiff is informed and believes, and on that basis alleges, that except as otherwise alleged herein, each of the Defendants is, and at all times relevant to this Complaint was, the employee, agent, employer, partner, joint  venturer,  affiliate,

and/or co-conspirator of the Defendants  and, in doing the acts alleged herein, was  acting within the course and scope of such positions  at the direction  of, and/or with   the permission, knowledge, consent, and/or ratification of the other Defendant. In the alternative, Plaintiff is informed and believes and thereon alleges that each Defendant, through its acts and omissions, is responsible  for the wrongdoing  alleged herein and  for the damages  suffered by Plaintiff.

Muhammad  Khilji and Jason Pfeiffer

22. In 2007, Dr. Klein hDr Klein hired Muhammad Khilji as his accountant
23. He was not to touch retirement funds
24. Jason Roger Pfeiffer began working for Klein
25. in 2007

• . By early 2009,
• Pfeiffer became office manager
• Minimally invasive Aesthetics is Dr. Klein’s research arm that works with Bg Pharm
• Muhammad Khilji illegally altered  MIAllc to  MIAinc  in in  two thousand seven  making himself CFO  and proceed to rob Dr. Klein of $40 million  in Drug Company Settlements
• with insider assistance of Ron Freed and Attorney Al Tippe at City National Bank Flower St. an account was opened in Dr. Klein’s name in 2008 referred to as MIA
• In 2009 2 fraudulent MIA accounts 
• were opened in Dr. Klein’s name at Private Bank of California
• under the name MIA with insider assistance of Bradley  Sharp  and John Reitman.
• As shown in original complaint below One Account was MIA and one was MIA retirement
• Muhammad Khilji illegally transferred $ 2 million dollars of Dr. Klein’s retirement funds from Ameritrade into the  MIA retirement account at Private Bank (as noted in the 2^nd Amended Complaint.)
• The MIA account remained at City National Bank Beverly Hils until 2010

 

1. Khilji had let the MIAllc account remain  at

 ) Lip Augmentation wih Restylane for Medicis\

Study under Jonah Schachnai PresidentMedics

Klein to receive $5 million settlrment

2. Khilji made the settlement with Charnley
3. . Dr. Klein was due a 5$ million settlement from Medicis for inventing LipAugmentation with Restylane( a filler).
4. Medicis Pharma was sold to Valeant for$ 1.6 billion and their # 1 product is Restylane for lips.
5. The illegal settlemenr was done at the office of  a conman  Robert Lorsch
6. robing Dr, Klein of $5 million and  Forging Dr. Klein’s name on the
7. Medicis  Settlement agreement
8. deposited in fraudulent account at MIA 2007 at City National Bank
9. Klein’s Medicis Settlement Value $5-$10 million owed to Dr. Klein.

 

Black Box warning on Botox

 

In 2009 Dr Klein  got the Black Box warning on Botox

Allergan who man factures Botox  claimed dilution of the toxin did not matter

10. Large Dilutions in Children with Cerebral Palsy could cause the toxin to reach the lungs and Stop the children breathing
11. The Total  Whistleblower Settlement  was $600 Million from the Justice Department of Which   Klein  was promised $ 35 million
12. .Klein was working initially with Patty Glaser who Khilji  failed to pay
13. December 22, 2009
14. Sally Quillian YatesRichard B. Russell Federal Building 75 Spring Street, S.W. Suite 600 Atlanta, GA 30303F33
15. Dear Ms. Yates
16. Thank you very much . I filed the papers. PPatty Glaser was to file papers , then Richard Charmley, now Mr Yaspan. I will try to get completed forms to you.
17. I reviewed the Justice Department settlement with Allergan and there are factors that are alarming.
18. Before he met with me Randy Chardash of the US Justice Department was not aware of
19. the promotional courses given by Allergan for the spasticity associated with Botox.
20. As I indicated to him these courses provided a
21. dangerous manner in which to treat Cerebral
22. Additionally I provided him as well as the FBI and INS data concerning unlicensed Canadian physicians Alastair and Jean Carruthers who worked for virtually every company with injectables including Allergan and Medicis
23. Klein gave it to Richard Charnley who gave to Robert Yaspan to complete.
24. Khilji  had erected fraudulent MIA accounts at City National Bank Flower
25. Street and Private Bank Bank /
26. there are over 41 Accounts fraudulent accounts according to Barbara Luna. Forensic
27. Khilji   could use to  rob  Klein of the  $35 million Dollar settlement\

The Black warning on Botox angered  \\  David Pyott of Allergam and Jonah Schacknai’s dishonesty is evident in the murder of his girlfriend in Coronado, California

To his day they have prevented Dr. Klein from teaching or Publishing in Medical Journals

28. All the above is part of Dr. Klein’s intellectual property belonging to  his trust , Arnold William Klein MD and MIA llc
29. ( Khilji, Charnley , Yaspan , Private Bank, Sharp,Reitman,Freed, Tippe City National flower St.Private Bank $40 million cc3345)
30. ( cc3345David Pyott,Allergan,Jonah Schacknai ,$40 million
31. Khilji worked closely with Pfeiffer.
32. Over time, Khilji and Pfeiffer began to exercise more and more control over Dr. Klein’s finances.
33. In concert, they instructed subordinate office staff to direct correspondence to their attention.
34. Khilji also supervised other office employees who were involved in processing the accounts payable and receivable for the office
35. Klein placed his trust and confidence in Khilji and Pfeiffer to performtheir professional duties with integrity.
36. Khilji and Pfeiffer accepted Dr. Klein’s trust and confidence,
37. and actively encouraged him to rely upon them to exercise cont

 

38. over financial matters. Dr. Klein believed they were acting in his best interests
39. Attempted  Homicide an Attempted Ilegal Alteration  of  Klein’sWill, trust  Power of Attorney
40. Klein did not sign any of these documents, used in court (see Second Amended Complaint
41. In March 2009, Klein was suffering from an illness that forced him to
42. spend several days away from the office(A Coumadin Overdose by Khilji, and Pfeiffer attempted Homicide  ).
43. He went to his home in Laguna Beach,
44. California to rest and recuperate from his illness.
45. Pfeiffer and Khilji were aware of
46. Klein’s condition and seized on the opportunity to capitalize on Dr. Klein’sreduced capacity
47. On March 20, 2009, without explaining
48. their intentions to Klein,
49. Pfeiffer and Khilji went to Dr. Klein’s Laguna Beach home.
50. Pfeiffer and Khiji brought  with them several individuals who were unknown  to Dr. Klein
51. (including Bradley Sharp_)
52. When  they arrived,
53. Pfeiffer  and Khilji told Dr. Klein that they were there to obtain his    signature
54. on a document that would permit Pfeiffer and Khilji to make health decisions    from Dr.
55. Klein during any period of incapacity.   To keep their actions from being  observed,
56. Pfeiffer and Khilji  instructed  Klein’s  caregiver to leave.
57. Pfeiffer and Khilji presented Klein with a document titled Power   of
58. Attorney for Health Care. Pfeiffer  and Khilji
59. would be designated as agents for    Klein and authorized  to make certain decisions relating to Dr. Klein’s health    and medical treatment.
60. During their visit, Pfeiffer and Khilji also had Dr. Klein  execute a document titled Codicil to Last Will and Testament.
61. Pfeiffer and Khilji were named    as executors of Dr. Klein’s will, and certain provisions  of the will were revoked   thereby removing Dr. Klein’s family members as beneficiaries under his will.
62. The significance of this document was not explained to Dr. Klein
63. Klein did not agree to the changes made by Pfeiffer and Khilji, which would cause them to benefit  from  Dr.  Klein’s death.
64. Pfeiffer and Khilji also instructed Dr. Klein
65. to sign an. Amendment  to   the Arnold William Klein Revocable Trust  as Amended  and Restated in 2000.
66. In  the amendment,  several changes were made to beneficiaries  of the trust.  Pfeiffer  and Khilji
67. were named as co-trustees .
68. Klein did not sign this in that his trust was from 1998.
69. Pfeiffer and Khilji also had Dr. Klein supposedly sign a document  titled
70. General Durable Power of Attorney, which is of questionable

.                  The Private Bank of California

1. The Private Bank of California

• In August 2009, Khilji  and Pfeiffer , and Robert Lorch opened several bank
•  accounts \
• Private Bank of California  (“Private Bank”) in Dr. Klein’s name\

Dr Klein has never    stepped foot inside Private Bank \

Khilji and Pfeiffer had Private Bank send account statements and other documents to an address that was  associated  with Khilji’s  business.( no  sent Robert Lorsch’ accontant

39. Private Bank was aware that information relating to the multiple bank accounts was not being sent to Dr. Klein’s personal  or professional  address.   For

• months after the accounts were opened, Private Bank failed to  send account
• statements to Dr. Klein or take other steps to ensure he received notice  of activity
• regarding bank accounts purportedly  opened in his
• In January 2010, Private Bank wrote to   Muhammad
• Khilji noticing that all these account statements  are
• ” to “NKSF”(Robert Lorsch’s accountant)
• Jickachose to communicate with Khilji via email instead  of
• sending Dr. Klein’s attention because they considered Khilji the. Client (from deposition)
• the partial account numbers for   the 28

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87806.2

1                  10 (ten) bank accounts  at Private Bank  are listed below with various names.

2                  Private Bank made no effort to contact Dr. Klein.

Khilji wrote to Private Bank requesting that the address for account statements for ten (10)

• accounts be changed to Suite 201 never reaching Dr, Klein)
• Arnold Klein MD -xxx799 l
• Arnold Klein MD -xxx8007
• Arnold William Klein MD -xxx2366
• Arnold William Klein MD -xxx2382
• Arnold William Klein MD -xxx2390 Arnold William Klein MD -xxx6409 Khilji-Pfeiffer -xxx2358

Khilji-Pfeiffer -xxx6417 Minimally Invasive -xxx2473 Minimally Invasive -xxx6490

42. At least two of the accounts appear to bear the name Khilji-Pfeiffer, LLC, to facilitate numerous fraudulent transactions and to funnel

• funds that were unlawfully converted from Dr. Klein’s bank and investment
• (Khilji- Pfeiffer LLc was invisible to Dr. Klein representing Khilji,Pfeiffer
• Robert Lorsch, and Lorsch’s company My Medical Records. Com. Lorsch’s office was
• in Private Bank
• Building and referred to Private Bank as “Bob’s Bank
• Private Bank records  reveal employees nd bank insiders
• Private Bank actively facilitated the fraudulent activities \28

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87806.2

	1 2 3 4 5 6 45.                     In May 2010, Khilji and Pfeiffer also executed documents to authorize wire transfers and on-line banking access for Dr. Klein’s personal, business and accounts at Private  Bank. As commonly used in money laundering 46.                     Dr. Klein’s signature is not evident on any of these documents. 47.                     Khilji and Pfeiffer used the accounts at Private Bank to pilfer hundreds thousands  if not millions  of dollars from Dr. Klein without his  knowledge. 7 8 D. 48. Excel National Bank In November  2009, without  Dr. Klein’s knowledge,  Pfeiffer  and Khilji

other

of

• opened payroll and revenue  accounts in the name of Dr. Klein’s medical practice   at
• Excel National Bank (“Excel Bank”). With insider Assitance of Sharp and Reitman t Pfeiffer and Khilji represented themselves as officers of Arnold  Klein MD, A Medical  Corporation.

49. Klein did not sign the documents and was not aware that Pfeiffer and Khilji had opened the   accounts.
50. Khilji and Pfeiffer used the accounts at Excel Bank to transfer and ultimately embezzle hundreds of thousands if not millions of dollars from Dr. Klein without his
51. Khilji and Pfeiffer also conspired to steal hundreds of thousands  of

• dollars from Dr. Klein through mirror image wire transfers. Khilji would   approve
• substantial wire transfers in favor of Pfeiffer;  and Pfeiffer would tum around   and
• approve substantial wire transfers in favor of Khilji.   These transactions were used  to
• remove substantial  funds from the accounts Khilji and Pfeiffer created at Private   Bank
• and Excel Bank without Klein’s knowledge.(money laundering yet no Suspcious
• Activity report filed as required by law by  Reitman and Sharp .The banks made  effot
• employ standard industry protections for suspicious transaction activity involving
• Klein’s (SARS report
• Pfeiffer also charged exorbitant amounts to an American  Express  credit
• card account that he made “paperless” so as to evade (see 2^nd Ammended Complaint where in

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87806.2

• Khilji also participated in and benefitted  from this fraudulent credit card
• Khilji and Pfeiffer used  funds in the Private Bank and Excel Bank accounts to pay   the
• credit card bills without Dr. Klein’s knowledge or authorization.   Their collusion   in
• the scheme let them live a lavish lifestyle at the  expense of Dr. Klein.
• Notwithstanding  suspicious transaction  activity, and in the face  of
• documents which on their  face raise serious questions about the authenticity  of
• signatures, no efforts were made by Private Bank or Excel Bank to contact Dr.   Klein
• directly and confirm his authorization for the accounts or the conduct of Khilji  and

10                                                      E.        Z & P Investment Services, LLC

54. For approximately 25 years, Dr. Klein engaged Z & P Investment Services, LLC to perform  financial management,  advisory and other services.   Jeffrey
55. Zone and Claudia I. Peltier provided broad financial management and accounting services to Dr. Klein and managed his retirement accounts held at TD Ameritrade.
56. Sometime in or around 2007, Z & P Investment Services, LLC sold its CPA practice to Muhammad Khilji and his company, Khilji & Klein, LLP. Thereafter, Khilji and his company handled accounting work for Dr. Klein. Z & P Investment Services continued  to control Dr. Klein’s investment  and  brokerage

• accounts and provided financial management  services to Dr.
• Z & P Investment Services was obligated to exercise due care in its
• management of Dr. Klein’s  investment  accounts and to fulfill its  financial
• management duties to Dr. Klein with the utmost    Z & P Investment  Services
• was also required to keep Dr. Klein informed regarding any activities that might   have
• a material effect on the value of his investments  and other assets under  its
• management and
• In 2009,  contrary to its own policies  and procedures,  Z & P Investments
• accepted oral instructions from Khilji for the liquidation of substantial assets held   by
• Klein at TD Ameritrade. Khilji’s requests for wire transfers  and asset   liquidation

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87806.2

• would typically be received on one day’s This alone should have raised red
• flags for Dr. Klein’s trusted   Z & P Investment  Services did not request    or
• receive written authorization from Dr. Klein for these transactions.   Z & P  Investment
• Services also did not provide Klein with prompt written notice of the fund transfer
• or liquidation requests before the transactions  were completed.   Z & P  Investment
• Services failed to contact Dr. Klein despite having his home, business and   personal
• cellular phone
• Instead,  Z & P Investment  Services processed  repeated transactions until
• Klein’s hard-earned retirement  and investment  funds were almost  completely
• Finally, when there was little money left in Dr. Klein’s    once-lucrative

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• accounts at TD Ameritrade, Z & P Investment  Services washed its hands of its   long-
• time client. In or about August 2009, Z & P Investment Services, LLC stopped providing services to Dr.
  59. In a matter of approximately eight months, over $2.2 million was withdrawn from Dr. Klein’s  investment portfolios  without  his (the total removed was $6.4 million in the second amended complainted stated that 35% remained in retirement  accounts when opened accounts  at Private Bank, $2 million went into MIA account,$ 3 million removed in Special Account at City National Bank on Flower St. portion to excel
  60. The Windsor Property
  61. Klein has owned a residence at 553 South Windsor Boulevard in Los Angeles, California since  1976 (the “Windsor Property”).   In 2009, Dr. Klein  had
• significant equity in the property that is viewed as a historic
• In December  2009, without  Dr. Klein’s knowledge  or authority, Khilji
• caused Dr. Klein to sign certain documents in connection with a mortgage  loan
• bearing 5% interest to be secured by the Windsor Property
• ( Dr Klein has not one signature on this mortgage). The  transaction
• apparently involved NXT Equities Incorporated  (“NXT”)  as broker  and Able
• Investment Services, LLC (“Able”)  as lender.   The terms  of the transaction are
• atypical and lack business justification given the value of the Windsor
• Many of the documents relating to the residential  loan are unsigned.    A
• number of the documents also reflect inaccuracies in information  regarding
• Klein’s age and length of employment, as well  as other obviously  incorrect

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biographical information. In addition, critical information regarding lender costs is blank and documents fail to comply with requirements set forth in Civil Code section 1189.

63. On or about December 16, 2009, in reliance upon the documents described herein, Able distributed the sum of $1.6 million to various   recipients (the Able loan is a typical money laundering where in the loan is made by identity theft of Dr. Klein with Khilji keeping the assets of Dr. Klein left with  .. The able loan was made with the assistance of Sharp and Reitman and deposited into the accounts They Erected at Private Bank in Dr. Klein’s name)
64. Klein first learned about the Able loan secured by the Windsor Property in late summer of 2010.   Dr. Klein ceased all payments  on the Able loan    until an investigation  could be conducted.   Because Dr. Klein did not authorize the  Able loan, and because he believes his signature on the loan documents was either  forged or obtained under false pretenses, Dr. Klein discontinued payments  on the   loan.
65. Klein did not make  not one signature on Loan and the loan require 2 forms of ID on page 52 there is only one Dr. Klein’s Driver’s license with wrong address
66. Loan has incorrect trust from March 20, 2009
67. On or about October 21, 2010, a Notice of Default and Election to Sell Under Deed of Trust was recorded against the Windsor
68. Dr. Klein has owned a residence at 553 South Windsor Boulevard in Los Angeles, California since 1976 (the “Windsor Property”).
69. In 2009, Dr. Klein had significant equity in the property that people view as a historic landmark in that is in the book
70. ”Great Mansions of LA,” and once was the home of the Wrigley family when they built Wrigley field in
71. Michael Jackson lived there with Dr. Klein’s family for 30 years and had a great many musical compositions there which were half finished
72. It became the most expensive residential structure in Los Angeles when built in 1914
73. It is in a section of Los Angeles called Windsor Sq(corner of HancockPark.)
74. Mr Jackson put in an audio/video kaleidoscope system costing greater than $800,00.00, and built the gym as a rehabilitation center for Dr Klein at a cost of $ 1.5 million( it was 60 feet long )
75. He also procured much of the art and memorabilia for the home
76. and his own room he occupied at times with his children. The art of Jackson’s is listed  below but was not part of Dr Klein’s itemized art.

The fixtures in Michael’s room were Sterling Silver

Much of the art in the home was given  to Dr Klein for services rendered

, Andy Warhol( a friend of Michael’s , he  had an original in is room).

The house on Windsor was a show place for Dr. Klein’s

art furnishings,books and memorabilia. The home had a Professional Elavator costing $350.000 and a 50 foot rehabilitation pool\

In owning the house for over 35 years every the square inch

was impeccable. Their were letters from Dr. Klein’s great Uncle Albert Einstein and his teacher. TShams Pahlavi, late sister of the Shah of Iran gave Dr. Klein several rugs one being a 17th century Silk Persian. she gave Doris Duke a    

similar rug that recently sold for for $ 4 Million.

Michael Jackson also procured much of

the ancient pottery and as well as Carlos Dunlop and Maria Pieces. the American Indian pieces.

Owning the house for over 35 years every the squareinch was impeccable.

m guy Dill from the DeMedici

On  31st October 2010 the home experienced an immense fire .

Frank Gehry was overseeing rebuilding which

would have increased the structural value to $12-15 million with the  metal elevator to the pool by Frank Gehry

 

 

 

The Patriot Act is a Federal law that was designed

to try and stop or detour terrorist

This law effects real estate transactions

by requiring identification disclosure requirements from banks,lenders, mortgage brokers, and escrow agents regarding transfer of title and deposits of

The law also requires new disclosure and signature requirements for buyers and sellers of real estat

The Bank that made the fraudulent mortgage

In addition, critical information regarding lender costs is blank, signatures are missing and documents fail to comply with requirements set forth in Civil Code section

The document requires two forms of identification has one and it presents Dr. Klein’s driver’s license with the wrong address on the On Page 52.  This is a  typical mortgage seen in Money Laundering schemes.

In Which Khilji with the help of Bradley Sharp and John Reitman of Private Bank  made a loan by identity theft leaving Dr. Klein with the

The Private Accounts are unheard of post 9/11

Secret accounts Khiiji-Peiffer llP are invisible to Dr. Klein and represent Khilji,Lorsch , and Lorsh’s Company my records .com.These were also used by Todd Gallinger for Hamas

Below are the funds relating to the Able Loan Khilji Kept.. Relating to the 12/16/09 $1,600,000 second mortgage loan on 553 S. Windsor payable to Able Investment Services,$1,069,172.46

Bank Account 33 1/3% points and usery interest rates greater than 11%. The funds were used to the benefit of Khilji as seen in accounts opened in money laundering Schemes. Mortgage fraud by Sharp, Reitman in Collusion with Khilji. But loan has the Gallinger  trust and they will never get clear title. – below the funds from the fraudulent Able Loanwas deposited into Private

#11012366, as shown in Schedule 7:Of which $32,000 was wired to Excel National Bank for an unauthorized payment to Jason Pfieffer, as shown in Schedule 7;

Of which $116,000 plus $56,000 were paid as loans receivable to officer,

while $140,000 was wire transferred in from First OMA Minim Invasive Aesthetic

DBPP (retirement) and accounted for as a loan payable officer, as shown in Schedules 7 and 1;( theft of Dr. Klein’s retirement from MIA)

Of which $45,000 plus $120,000 were transferred to Excel Bank account #103051 without explanation, as shown in Schedules 7 and 7.1. Of these amounts,

The are all accounts opened by Identity theft of Dr. Klein

85,610.64 was wired to First Commerce LA Car Connections, Inc in 12/09, as shown in Schedule 3,

but this appears to be non business

However it is highly illegal and in California under the financial Elder Abuse Law

a Bank insider such as Sharp and Reitman

are mandated to report action of this type.

Additionally Sharp and Reitman have

been involved in this scheme since 2008 .

On December 16, 2009,

in reliance upon the documents described herein, Able distributed the sum of$1.6 million to various recipients through the fraudulent corporate accounts at Private Bank that was (minus the 33 1/3 points Sharp kept.)

Klein first learned about the Able loan secured by the Windsor Property in late summer of 2010

Klein ceased all payments on the Able loan until an investigation could be conducted and must know if Khilji made any pyments on this note,

Klein did not authorize the Able loan, has not made a mortgage himself since 1991

records of Private Bank were never sent to his office, and because he knows his signature on the loan documents was forged

nor was their any Patriot Act Documentation Klein ceased

On or about October 21, 2”010,

See “original complaint “ this loan was made

by Muhammad Khilji with the insider assistance  of\\

Bradley Sharp by identity theft of Dr Klein ,

In the Second Amended Complaint

Reitman and Sharp admit the money laundering that occurred at Private Bank and the fraudulent nature of Able loan.

The Able loan does not contain Dr. Klein trust. Both Bradley Sharp and John Reitman have long standing relationships with Private Bank

California has mandated reporting of Elder Financial Abuse

All Bank Insiders must file a SARS report

no matter what court you are in

but money laundering is heard in Superior Court and Criminal Court.

As shown by records of Les Weiner

Klein was overmedicated into Bankruptcy Court

but Dr. Klein’s complaint reveals the money laundering at Private Bank,. Excel Account and City National Bank

all of which Reitman and Sharp have been involved with since 2008.

AB-381 Estates and trusts: undue influence and elder abuse.

Everything of Dr. Klein’s belongs to his trustAnd must be returned to him.

Dr Klein lived on Windsor for 30 years

AB-381 Estates trusts: undue influence and elder abuse.

Documents intended for court eviction

You may be able to use fraudulent documents obtain a non judicial foreclosure,

but those documents will not support the eviction of the rightful owners In California,  eviction is a judicial process, albeit summary.

However, once forged document are presented to a court, the presenters may become guilty of felonies  Windsor was specifically designed for Klein’s disability, Klein

70 and disabled cannot be expected to drive 8 hours per day from his Palm Springs home to work.

His health will not tolerate this and he has been Penniless.

restoration of his home was prevented by  Bradley Sharp

1400 stored boxes of Klein’s art, collectables,and personal items preventing By Jules Bensonat Oakwood .

He then sold these items many of these items

which violate HIPAA having very personal information

on Klein’s patient’s. These acts of preventing repair of Klein’s home and selling damaged art without repair violate State ,Feederal l

lost income. To Dr. Klein

16 million

$40 million in art and furnishing, Dr, Klein wishes returned , restored, or replace

$100 million Jackson’s Song, etc…lived in Klein’s home on Windsor for 30 years Klein Wishes returned Jackson decorated his own suite of 3 rooms himself.

He had a small portrait  of himself by Warhol,Degas and Renoir Asian art $15 million

Elevator $300,000

$2.5 million,gym, a-v system put in Jackson

Cher;s Bentley- from Bonham’s $150,000

Vik Munez Elizabeth Taylor returned $200.

$2.3 Bonham unsold art returned

Georg Friedrich Bernhard Riemann letters from Albert Einstein

$ 5 million returned

Albert Einstein letters (great uncle) $5 million returne

$5.5 in rug from, Shams Phalavir restore, replace or return\

Death of Jesus David Lachapelle-$ 500,000 retur

Home rebuilt by Gehry $12 million

cc3345 $214.8 Million( Private Bank, Reitman, Sharp. Law firm Landau Gott fried and Berger)

To help with Chartis insurance and the correct rebuilding

Klein Hired Philip Boesch as an attorney whdealt with the fraudulent Dominion loan

and was dealing with the Able loan, Bank of American loan

Chartis would not properly restore Klein’s

Klein was getting a 2^nd trust deed on laguna to pay the attorney fees and

Michael said before he died Dr Klein could sell some of the songs but keep the 2003 wills(2).covenant and AEG Agreement to be paid for rebuilding Jackson face for The film “This is it

“

Klein has been continually overmedicated and it would happen again,

From Dr. Les Weiner about the overmedication of Dr. Klein into bankruptcy court

Arnold Klein is a 70 yr. disabled elder who is the Tesla of Medicine.

There is not one part of Modern Medicine he has not improved through Dr Klein’s practice and research from information Dr. Klein provided

The above individuals     have robbed Dr Klein through an organized conspiracy involving Identity theft, Bank fraud, and money l

He has saved a generation of women and men but the above individuals took advantage of his disability to overmedicate him so while confused they robbed

But how can a disabled Elder be evicted on the basis of a mortgage he never made that contains a trust hat is not his.

I take care of many disabled individuals so this question must be answered.

Sharp and Khilji overmedicated Dr. Klein with a toxic and potentially fatal dose of the

atypical anti-­‐psychotic Moban combined with elevating his

This would make Dr Klein incapable of rational thought.

While in this condition of mental incompetence

M Sharp secured 4 attorneys to convince Dr. Klein  to enter Bankruptcy court for immediate trial against the embezzlers.

Klein had not made one of the fraudulent mortgages and was about to have his cases heard in SuperiorCourt

but entered Bankruptcy Court wherein they guaranteed Dr. Klein a trial against the embezzlers

I have seen the complaint Dr. Klein filed

showing the Accounts established by Bradley Sharp at Private Bank, Excel Bank and the fraudulent theft of his retirement fund by Muhammad Khilji of 6.4 million from Ameritrade.

Because of these fraudulent

Accounts, Dr. Klein is presently in desperate need of funds for his ongoing neurologic condition which has deteriorated since he has unable to pay for

Additionally, the same is true of his cardiac status

. Klein is in desperate need of funds for medication of his neuropathy which includes Rituxin- ‘($24,000 for each six-month treatment).

He needs funds for a Baclofen pump to reduce his spasticity ($ 50,000) as well as funds to repair of damage from the heart attacks caused when his Trustee withheld his SSI twice ($90.000)

, Dr. Klein also requires funds for a caregiver ($50,000) as well as a vehicle outfitted for a disabled individual. Dr. Klein’s retirement is rightfully his

They are attempting to give these to these funds to the embezzlers.

In Dr. Klein’s Complaint from 6/27/11 he reveals how these were laundered from ameritrade through illegal accounts at Excel Bank, City National Bank and Private Bank

as well as the the $5 million from the Excel Accounts.

A Mr. Peter Gurfein is attempting to  withhold $150,000.

From Dr. Klein’s Homestead saying Dr. Klein owes taxes on Excel Accounts. From which Khilji and Pfeiffer laundered funds of $4-5 million.

Being a Neighbor of Dr. Klein on Rimpau

I saw how Bradley Sharp illegally stopped the restoration of Dr. Klein’s home on Windsor

on the basis of lead toxicity failing to realize Dr, Klein is an expert on Toxin’s.

I never saw the scaffold’s necessary for a “lead abatement.”

I saw the auction of Dr. Klein’s treasured art valued at over 200 million that was seized without a list or warrant and I was forced to write the Medical board of Ca over his capabilities as a physician.

I saw Bradley Sharp and Mr. Gurfeiin illegally evict  Dr Klein and  and his  invalid aunt  and

sell Klein Incomporable home on Windsor of the basis  of the fraudulent Able loan which

was was made  by Muhammad Khilji and Bradley Sharp and deposited  in  Fraudulent accounts

at Private Bank opened by Sharp

which did not contain his trust..

Dr Klein will not survive another six months if he Is forced to commute from  Palm Springs

. If Bradley Sharp is allowed in any way to prevent Dr. Klein’s access to medicationhe will not last that long..

When Dr, Klein entered the court he was mentally incompetent ,He had great homes, art, cars and an incomparable book collection.  And a great retirement fund.

How can he now be penniless?

There must an attorney somewhere willing to get this case started.

My daughter who is an attorney states there are codes CODE OF CIVIL PROCEDURE .SECTION 35-38

for accelerated trial for a 70 year old individual who’s case must be heard rapidl Les Weiner,Former Chief of Neurology Leslie Weiner Neurology Clinic and Research Institute, Keck School of Medicine at USKlein is protected from these actions by AB140  and BC1400.1.

Dr, Klein was very aware that Private Bank was owned by the lawyers and /Judges of the LA and /Orange County Venue’s of Federal Bankruptcy  Court,

Klein was mentally incompetent from the drugging but was convinced by Neale

\lthat he could enter the court as a Plaintiff not a debtor and have a trial

topped restoration of Klein’s home as well as bankruptcy law designed to increase value of assets

State law Supercedes bankruptcy law

Klein was not bankrupt, he went there for a trial.

Sharp stole Klein’s assets based on the fraudulent Able loan, a money laundering mortgage he helped create and evicted Dr. Klein.

Mr  Sharp has seized over $200 million of Dr.  Klein’s assets without as required by California law all three of the following  a warrant or a list and without Judicial Cause. Despite Neiters positon as Judge this is California law

By Law Klein cannot be a debtor in bankruptcy court

In regard to the IRs and taxes on non financial and financial items

 

Asset Forfeiture – The asset forfeiture program is one of the federal government’s most effective tools against drug trafficking, money laundering, and organized crime.

In conjunction with other federal, state, and local law enforcement agencies, Criminal Investigation uses asset forfeiture statutes

to dismantle criminal enterprises by seizing and forfeiting their assets. Most of Criminal Investigation’s seizures and forfeitures

are the result of Title 18 and Title 31 money laundering and currency investigations.

Title 31 allows to be heard on a Civil level

and he must be removed by Elder Abuse laws and Bankruptcy laws. AB140 1

Also Sharp must be removed as Klein’s trustee.

The Able loan contained the fraudulent Gallinger trust.

16. Klein’s Windsor Home belongs to Dr. Klein and must be returned to him

17. by the California Homeowners Bill of Rights and Elder abuse laws

18. AB-381 Estates and trusts: undue influence and elder abuse

19. One cannot evict the right full owner of a home,

20. Courts have power to vacate a foreclosure sale

21. where there has been fraud in the procurement of the foreclosure decree

22. or where the sale has been improperly, unfairly or unlawfully conducted,

23. or is tainted by fraud, or where there has been

17such a mistake that to allow it to stand would be inequitable to purchaser

18and parties.

19. Hence,  forged  signatures cannot be used  to obtain a foreclosure  in  California20.Windsor  has been Dr. Klein’s home for Almost 40 years and by California Law must be returned to  Dr KLein-

1. Dr, Klein was very aware that Private Bank was owned by the lawyers and /Judges of the LA and /Orange County Venue’s of Federal Bankruptcy  Court,  ‘
2. Klein was mentally incompetent from the drugging but was convinced by Attorney David Neale who had stock
3. In Private Bank
4. that he could enter the court as a Plaintiff not a debtor and have a trial
5. . Dr. Klein was very much aware of Bradley Sharp’s involvement in the  scheme
6. was reassured he would be a plaintiff and have a trial and have nothing to do with Sharp and be out of the court in 2-3 weeks and  return to Superior Court
7. Klein had no trial Bradley Sharp who setup the laundering accounts was appointed Dr. Klein’s trustee,
8. Klein protested and Sharp Prevented his access to SSI and Dr, Klein had 2 heart attacks,

 

24. Sharp illegally stopped Dr. Klein’s Alternative Living Expenses as well as restoration of Klein’s homes restora
25. Intersections of Bankruptcy Law and Insurance Coverage

Litigatio Richard L. Epling, Kerry A. Brennan

& Brandon Johnson

©2012 Pillsbury Winthrop Shaw Pittman LLP

Bankruptcy and insurance law

26. Klein is guaranteed, by California State law the restoration of his home that supersedes Bankruptcy Law
27. until his home is restored,
28. Sharp illegally seized Klein’s home and in violation of elder Abuse laws

21.under California Homeowers Bill of Right

AB381 Estates and trusts: undue influence and elder abuse to which all courts in California

 Amount owed Dr. KLein

 

Jackson decorated his own suite of 3 rooms himself.

He  had a  portrait  of himself by Warhol,Degas and Renoir an Asian art $15-20 million

Elevator $300,000

$2.5 million,gym, a-v system put in Jackson, other Jackson art.

Cher;s Bentley- from Bonham’s 150,000

$2.3 Bonham unsold  art

Georg Friedrich Bernhard Riemann letters from Albert Einstein$ 5 million

Albert Einstein letters (great uncle) $5 million

$5.5 in rug  from, Shams Phalavi

Death of Jesus David Lachapelle-$ 500,000

Home rebuilt by Gehry $12 million

$16.,imillion  in lost income. 

$40 million in art and furnishing, Dr, Klein wishes returned , restored, or replaced

100 million  Jackson’s  Song, etc…lived in Klein’s home on Windsor for 30 years Klein Wishes returned

AB-381 Estates and trusts: undue influence and elder abuse. cc3345  $214.8 Million Private Bank,Muhammad Khilj,

Bradley Sharp,

 

Estates and trusts

ho disguises

.

2. An attorney who disgAan attorney a attorney who  aids in disguising the source of the funds or the nature of violation of this section shall be punished by  a fine of not more than two hundred fifty thousand dollars ($250,000) ortwice the value of the property transacted, whichever is greater, or by both five hundred thousand dollars ($500,000) or five times the value of the property transacted, whichever is greater. As the value increases so does the punishment associated with

G.                         The Laguna Property

68. Klein has owned a residence at 31025 Pacific Coast Highway in Laguna Beach,  California  since  1991 (the “Laguna Property”).
69. In or around February 2010, Jason Pfeiffer contacted Inge Bunn, a real estate broker who had worked with Dr. Klein for many years.  Pfeiffer told Bunn that

• he was Dr. Klein’s assistant and stated that he would  serve as a liaison between   Bunn
• and Dr.
• Pfeiffer asked Bunn to preliminary-market  the Laguna property as   a
• pocket   After a series of telephone calls in the following months, Pfeiffer   told
• Bunn that Dr. Klein’s CPA, Muhammad  Khilji, would be handling the
• Subsequently, Bunn met with Khilji and presented  a Comparative  Market
• Analysis (CMA) to Khilji.  Khilji initially suggested that the Laguna Property be
• listed for $13 million. On March 25, 2010, Bunn provided  Khilji with a  Listing
• Agreement for his review.  Although the Listing Agreement was not signed,   Khilji
• instructed Bunn to move forward with having the Laguna  Property professionally
• The photographs  were taken in early April  2010.

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70. Pfeiffer and Khilji took extensive steps to conceal their unauthorized attempt to list the Laguna Property from Dr. Klein. Pfeiffer told Bunn to remove any marketing brochures from the Laguna Property because Dr. Klein would be entertaining guests at the home over the weekend. Pfeiffer and Khilji also prohibited Bunn from placing  any signage regarding the listing  at the
71. In April 2010, without Dr. Klein’s knowledge, Khilji submitted a loan application to Dominion Mortgage Corporation for the purposes of obtaining a loan secured by the Laguna Property. Dr. Klein did not sign the loan application and did not know that an application had been completed  in his
72. In June 2010, Khilji emailed Bunn and informed her that Dr. Klein was going through a financial transaction regarding the Laguna Property. Khilji told Bunn that an individual named Loren Thall would be involved in the sale and would receive  a 0.5% commission.  Khilji also said the property had to be listed in the Multiple  Listing Service (MLS). Khilji requested information from Bunn regarding the  property’s value and comparative listings.   Thall also contacted Bunn about placing   the property  on the
73. On June 4, 2010, Dunn received an email from Khilji stating “we have a consensus on listing price of $11,900,000.” Khilji’s email was also sent to Thall and

19

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87806.2

stated the “[t]hree of us need to work together  and make it happen.   I know it will  take

sometime but we should be shooting for March   2011.”

74. There is a listing agreement dated June 5, 2010 purporting to reflect Dr. Klein’s signature on behalf of the “1995 Klein Arnold W. Trust,” which is not the correct name of the trust that holds Dr. Klein’s Laguna Property but similar to the trust used on the illegal sale of Klein’s Laguna Property and on thr Purchase of Klein’s Palm Springs home suggesting Sharp’s involvement since 2008 and involvement with City National Bank and creation wth Khilji and Attorney Attorney Attorney John Retmam the mortgage fraud with identity theft . seen in money Laundering Dr. Klein never signed the listing agreement and had no knowledge that Khilji and Pfeiffer were conspiring to sell his Laguna Property behind his
75. In or around June 2010, Khilji and/or Pfeiffer fraudulently executed certain documents in connection with a mortgage loan bearing 12% interest to be secured by the Laguna Property. The transaction  apparently involved Dominion

13

• Mortgage Corporation  (“Dominion”)  and Allen V.C. Davis, trustee  for Davis Trust
• 1 U/A/T November 7, 1961 (“Davis”) as lender. The terms of the transaction are
• atypical and lack business justification  given the value of the Laguna
• Many of the documents relating to the residential loan are unsigned.     A
• number of the documents  fail to comply with requirements  set forth in Civil  Code
• section
• On or about June 8, 2010, in reliance upon the documents    described
• herein, Dominion and Davis  distributed an unknown  sum in connection with  the
• principle loan amount of $1.5 To Khilji. Loan is typical mortgage fraud by
• identity theft
• Dr. Klein first learned about the Dominion/Davis  loan secured   by the Laguna Property in fall of 2010. Because Dr. Klein did not authorize the Dominion/Davis loan, and because he believes  his signature on the loan documents  was either forged or obtained under false pretenses, Dr. Klein did not make payments  on the loan.

79. On or about November 17, 2010, a Notice  of Default  and of Lender’s Intent to Exercise its Remedies Under Loan Documents was recorded against the Laguna Property. AB-381 Estates and trusts: undue influence and elder abuse.

 

 

The Home at 7100 Hope Circle

71. The house was listed at $5.7 million,
72. , Klein’s cousin had agreed to a Price of$ 2.4 million.
73. Klein had been overmedicated by the embezzlers and bank insiders not to visit the Laguna Property
74. Hope Circle was much more  compatible with Dr. Klein’s disability.
75. Khili came to Dr. Klein home in Palm Springs at 1401 Via monte  Vista
76. with papers  for Dr Klein to sign for the purchase of the Hope Circle  Home
77. Klein waited 2 hours for Khilji to arrive
78. The Notary asked for Mr Sharp because Khilji was late
79. Dr Kjein sign the papers and gave Khilji a down payment from  City National Bank Beverly Hills   account for $500,000 and Cash of $500,00  as a deposit on  the Hope  Circle Home
80. Klein ask Khilji who Bradley Sharp was, he was at Dr. Klein’s house when they altered his will

Unknown to Dr,Klein all funds at City National Bank Beverly Hills had

 

 been depleted  by April 10^th  2010. By Khili and Charnley over

$15-20 million.+ $40 million – funds went to fraudulent accounts at

 Private Bank i.e., Klein’s research arm minimally invasive aesthetics (MIA) had accounts  at City National Bank Flower St, and Private Bank

from Detective Scott Ross

81. While Dr. Klein was purchasing  the Hope Circle home Khilji and
82. Sharp twere attempting to sell Dr. Klein’s Laguna Home behind his back 
83. Dr Klein felt ill ,but was  drugged not visit Laguna Property by Sharp
84. and Khilji
85. Klein send a down payment on the  Rancho Mirage  Property to
86. realtor Joel Cohen via Khilji of a check fp
87. Khilji had Given Dr. Klein 4 pages of a document to sign.
88. The Document was part  of the Dominion Loan ,
89. the fraudulent  exit loan Muhammad Jason Pfeiffer, Bradley Sharp(of Private Bank of California )John Reitman  of Private Bank of  California, and Loren Thall made on Klein’s Laguna Properties.
90. The Dominion note is shown to be fraudulent in the 6/27/11 Complaint or Original Complaint 
91. As stated Khilji,Pfeiffer, Thall Sharp and Reitmen had made
92. the Dominion loan on the Attempted  sale of Klein’s Laguna Property  behind his back
93. The interest rate on this note for$ 1. 5 million was 12 % with points of 331/3 %. Included in this note is payment on a  $1million dollar fraudulent Bank of America loan made by Khilji and Charnley. 
94. In the note there is reference to two cars of Dr. Klein’s stolen by Khilji, Pfeiiffer and Lorsch  valued at $150.000.
95. The note was deposited into the fraudulent  Accounts at Private Bank opened by Sharp and Reitman and Khilji, Pfeiffer and Lorsch kept the funds.
96. In regard to theft of the cars it is grand theft auto.
97. Michael Jackson loved the SSR truck and Mercedes 500SL.
98. Both were stolen by Jason Pfeiffer, Muhammad Khilji,
99. And Robert Lorsch
100. Ramirez@dmv.ca.gov of the DM
101. he stopped the investigation of the car theft  
102. Federal Marshal Brian Salt and Bradley Sharp who intimidated Ramirez to  stop investigating
103. The house was listed at $5.7 million,
104. , Klein’s cousin had agreed to a Price of$ 2.4 million.
105. Klein had been overmedicated by the embezzlers and bank
106. insiders not to visit the Laguna Property
107. Hope Circle was much more  compatible with Dr. Klein’s disability.
108. Khili came to Dr. Klein home in Palm Springs at 1401 Via monte  Vista
109. with papers  for Dr Klein to sign for the purchase of the Hope Circle  Home
110. Klein waited 2 hours for Khilji to arrive
111. The Notary asked for Mr Sharp because Khilji was late
112. Dr Kjein sign the papers and gave Khilji a down payment from  City National Bank Beverly Hills   account for $500,000 and Cash of $500,00  as a deposit on  the Hope  Circle Home
113. Klein ask Khilji who Bradley Sharp was,
114. Unknown to Dr,Klein all funds at City National Bank Beverly Hills
115. had been depleted by April 10^th By Khili and Charnley
116. over $15-20 million.+ $40 million – funds went to fraudulent accounts at
117. Private Bank i., Klein’s research arm minimally invasive aesthetics
118. (MIA) had accounts at City National Bank Flower St, and Private Bank
119. and 41 other account

from Detective Scott Ross

120. While Dr. Klein was purchasing  the Hope Circle home Khilji and Sharp twere attempting to sell Dr. Klein’s Laguna Home behind his back
121. Dr Klein felt ill ,but was
122. send a down payment on the  Rancho Mirage  Property to realtor Joel Cohen
123. Khilji had Given Dr. Klein 4 pages of a document to sign.
124. The Document was part  of the Dominion Loan ,
125. the fraudulent  exit loan Muhammad Jason Pfeiffer, Bradley Sharp(of Private Bank of California )John Reitman  of Private Bank of  California, and Loren Thall made on Klein’s Laguna Properties.
126. The Dominion note is shown to be fraudulent in the 6/27/11 Complaint or Original Complaint
127. As stated Khilji,Pfeiffer, Thall Sharp and Reitmen had made  the Dominion loan on the Attempted  sale of Klein’s Laguna Property  behind his back
128. The interest rate on this note for$ 1. 5 million was 12 % with points of 331/3 %. Included in this note is payment on a  $1million dollar fraudulent Bank of America loan made by Khilji and Charnley.
129. In the note there is reference to two cars of Dr. Klein’s stolen by Khilji, Pfeiiffer and Lorsch  valued at $150.000.
130. The note was deposited into the fraudulent  Accounts at Private Bank opened by Sharp and Reitman and Khilji, Pfeiffer and Lorsch kept the funds.
131. In regard to theft of the cars it is grand theft auto.
132. Michael Jackson loved the SSR truck and Mercedes 500SL.
133. Both were stolen by Jason Pfeiffer, Muhammad Khilji,
134. And Robert Lorsch
135. Ramirez@dmv.ca.gov of the DM
136. he stopped the investigation of the car theft  
137. Federal Marshal Brian Salt and Bradley Sharp who intimidated
138. Ramirez to  stop investigating
139. Klein has owned his home in Laguna Beach California at
140. 31025 Pacific Highway since 199It is held by
141. his trust of Which the trustee is Arnold William Klein MD
142. and he had little debt on the home,
143. In July of 2008 Muhammad Khilji together with Richard
144. Charmley,Dr. Klein’s ex attorney
145. opened 8 accounts in Dr. Klein’s name at City National Bank Flower Street Branch  with inside assistance ofRon Freed Vice President
146. of City National Bank(CNB) Flower St Branch  and attorney Al TippeOne of the accounts
147. Khilji made was “Arnold William Klein , a Medical group which is a medical group that does not exist,
148. Muhammad Khilji  on May 8th 2009 made The following loan # 113005483/00001 from the funds of Dr. Klein’s  at City National Bank Flower St. Bank
149. which had been laundered From Dr. Klein’s funds from  the Beverly Hills Branch of City National Bank. ( the only bank Dr. Klein used )
150. a corporate credit line  for $1.6 million Dollars
151. The Note is not signed by Klein Uses the fraudulent trust  created on March 20^th, 2009 
152. which is Arnold William Klein 435 N. Roxbury Dr. When Dr. Klein’ s trust is  Arnold William Klein MD 553 S. Windsor Blvd
153. Address on note is 553 S. Windsor Dr. Suite 204
154. which is not Klein’s address in Los Angeles,
155. Klein’s address in Los Angeles is 553 S Windsor BlvdThe note has wrong years in practice.  And Khilji could not spell Doctor.
156. This note is fromMay 8th 2009 # 113005483/00001
157. In selling Klein’s Laguna Property
158. the fraudulent quit trust deed is not signed by Dr. Klein  but Bradley Sharp who is not a family member. (Exhibit 3 the fraudulent quit trust deed is not signed by  Dr Klein
159. has no validity to transfer ownerhip of a home
160. quitclaim deeds are commonly used to transfer the ownership of property between two parties. Quitclaim deeds do not offer a guarantee
161. to the grantor that the grantor holds the property free
162. and clear of any type of lien on the title, unlike warranty deeds. Because of this, quitclaims are most often used for transfer as from spouse to spouse or from parent to child.
163. The deed should lists the names of the grantors and grantees.
164. It also includes a complete legal description of the property.
165. The grantor signs the deed in the presence of a notary public, which was not done.here and then the deed should be recorded with the county land
166. records system. The Title Companies have committed  fraud   on Klein’s homes in Laguna, LA and Palm Springs
167. clear title may not derive from a fraud fraudulent mortgage(including a bona fide purchaser for value).
168. In the case of a fraudulent transaction California law is settled. The Court in Trout v. Trout (1934) 220 Cal. 652 at 656 made as much plain
169. It is the general rule that courts have power to vacate a foreclosure Sale

 

170. where there has been fraud in the procurement of the foreclosure decree .or where the sale has been improperly, unfairly or unlawfully conducted, or is tainted by fraud,

 

171. or where there has been such a mistake that to allow it to stand would be inequitable to purchaser and parties. .

 

172. Hence, forged signatures cannot be used to obtain the foreclosure in California that to allow it to stand would be inequitable to purchaser and parties.

 

173. in violation in violation of California Homeowners   the fraudulent  grant deed has  Doctor Klein’s Windsor Address (Exhiibit 4) The Fraudulent Deed of Trust  was the same  fraudulent deed of trust used on the purchase of Klein’s Palm Springs Home.

 

174. They wiil never get clear title  and Dr Klein wishes return of this and his  Windsor Propertinvolving

 

175. Bradley Sharp and Attorney John Reitman  have violated the Home owners Bill of Rights and Elder Abuse Laws of California. And laws relating to mortgage fraud and money Laundering.  Under money laundering statutes this is mortgage fraud at Private Bank  and  City National Bank by  Ron Freed and Al Tippe of City National Bank Flower

 

176. In California An attorney who disguises or aids in disguising the source of the funds or the nature of violation of this section shall be punished by  a fine of not more than two hundred fifty thousand dollars ($250,000) or twice the value of the property transacted, whichever is greater, or by both five hundred thousand dollars ($500,000) or five times the value of the property transacted.

 

1. The above  funds were  laundered from City National Beverly Hills .
2. Eight accounts would be established at City National  Bank Flower St
3. by identity theft of Arnold Klein MD.which were opened  by Muhammad Khilji together  With Dr. Klein’s ex-lawyer  Richard Charnley,
4. One account was the special account used to remove $3 million from Dr.Klein’s Ameritrade retirement account

 

5. but there is more than one fraudulent illegal promissory note issued to Khilji.
6. CNB promissory note see 112636013 /00001 for $1.1 million.Dr Klein’s Correct Trust is 1995 Arnold William Klein MD 553 S. Windsor Blvd
7. The fraudulent Trust Khilji used was 1995 Arnold William Klein 435 N. Roxbury Dr which was produced on March 20,2009
8. This was presented in Court as a mortgage made by Klein on  his Laguna House  as was the Dominion loan
9. And used to illegally evict Dr. Klein from his home in Laguna Beach in 7 days by Bradley Sharp  and Attorney John Reitman of Private Bank
10. In violation of the Homeowners Bill of Rights
11. The above note is Corporate not personal
12. and was fraudulently presented in Court  by
13. Al Tippe as a Mortgage made by Dr. Klein on his Laguna home at City National Bank Flower St.( there is no mention of Laguna Beach Property.
14. On the note,
15. Gehry was putting in an elevator from the Ocean
16. the last Frank Gehry house built on the ocean sold for$ 60
17. elevator to Ocean for  Klein’s disability.
18. the lost to Dr. Klein by illegal sale of Laguna home is $ 20 million Dollar structure
19. furnishisings and art $5 million.
20. 2 stolen Cars 150,000 Bulgari Diamond Clock from Mufack Al Midani- $250,00
21. Signed letters by Elizabeth Taylor and Letters,Music  of Michael Jackson-$10 million
22. Maquette of Michael Jackson and Bubbles (Jeff Koon$) $5 million
23. Audemars Piguet Watches – Royal Oak Offshore Baguette $1.4 million Style No:  15130BC.ZZ.8042BC.01Given to Michael Jackson by Prince Azim,
24. Dominion Note 1.5 Millon

ad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)

90. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
91. As described herein, Khilji and Pfeiffer obtained Dr. Klein’s signature on key documents under false pretenses and for purposes that were not disclosed to Dr. Klein. Khilji and Pfeiffer made these false statements and misrepresentations with the intention that Dr. Klein would rely thereon. Khilji and Pfeiffer also failed to disclose, and otherwise concealed, material information regarding their activities relating to Klein’s real property assets, bank accounts, credit cards and other property interests.

17

• Klein did in fact rely upon Khilji and Pfeiffer’s representations and    false or
• misleading statements to his detriment, and it was foreseeable that he would  do
• If Dr. Klein had been  aware of Khilji and Pfeiffer’s  true purposes  and
• intentions, he would not have signed the documents  as requested.   In many instances,
• Klein was never made aware of the true nature or purpose of the documents.   If  he
• had known the truth, he would not have permitted Khilji  and Pfeiffer to exercise
• control over his professional and personal  financial
• As described  herein, Khilji and Pfeiffer also forged Dr. Klein’s   signature
• on many key financial documents,  including loan documents,  credit applications,
• investment sell and liquidation requests and other transaction   authorization

0

8       11      documents.

“‘

102. As a direct, actual, and foreseeable result of Defendants’ fraud   and

forgeries, Dr. Klein has been damaged in an amount that has not yet been fully ascertained, but  in any event an amount not less than  $10,000,000.00.

103. The aforementioned conduct of Defendants was intentionally deceitful, fraudulent, and done with the intent of depriving Dr. Klein of his property and legal rights and to cause him injury. Defendants’  conduct was and is despicable and  subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights    so

• as to justify an award of exemplary and punitive
• FOURTH CLAIM FOR RELIEF
• (Accounting – All Defendants)
• Plaintiff repeats and realleges  each and every foregoing and  subsequent
• allegation contained in the Complaint, as though said paragraphs were  set forth in full
• As alleged above, a fiduciary relationship  existed between Dr. Klein   and
• Khilji and Pfeiffer. A fiduciary and/or contractual relationship  also existed   between
• Klein and Z & P Investment Services, LLC, as well as TD Ameritrade. As a result 28

18

87806.2

• of the conduct alleged herein, a relationship  also existed between  Klein and
• Private Bank, Excel Bank, Able, NXT, Dominion  and
• Due to Khilji  and Pfeiffer’ s wrongful  acts as alleged  above, Defendants
• are indebted to Dr. Klein in an amount that  can only be ascertained by an accounting.
• For example, an accounting  of the assets held by TD Ameritrade,  Private Bank  and
• Excel Bank and unlawfully converted or fraudulently transferred  by Khilji  and
• Pfeiffer is required to determine the amount of indebtedness.   And the amount   of
• credit and home  equity taken and used by Defendants  (including Dr. Klein’s  interest
• in the Windsor Property,  which is currently subject to a claim by Able and/or NXT,
• and Klein’s interest in the Laguna Property, which is currently subject to a claim

i    11      by Dominion and/or Davis), the extent of which is currently unknown to Dr. Klein,

“‘

19

20

21

22

23

24

25

27

28

87806.2

must be accounted  for.

107. Due to the foregoing, an accounting is required to determine the exact amount Defendants owe Dr.

FIFTH CLAIM FOR  RELIEF

(Fraudulent Conveyance -Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-50)

108. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein.
109. As alleged above, Defendants have committed acts constituting, among other things, fraud, breach  of fiduciary duty and
110. Defendants’ acts have removed property from Dr. Klein’s possession and prevented Dr. Klein from accessing his property and other assets. Title to certain property, purchased by Khilji and/or Pfeiffer with Dr. Klein’s funds and without his knowledge or authorization,  has not been properly transferred  to Dr.
111. Klein is informed and believes, and thereon alleges, that Defendants removed assets, monies,  and/or property  of Dr. Klein’s assets and businesses  and

19

• prevented him from accessing  such assets, monies, and/or property to which he   has
• Defendants  have been unjustly  enriched by their acts in contravention  of their
• fiduciary duties. Klein holds  an interest in the assets, monies, and/or properties    at
• issue as described
• Dr. Klein is informed  and believes,  and thereon alleges that  Defendants
• have appropriated these assets, monies,  and/or property,  which in tum has  deprived
• him of his interest in the properties and assets described herein.   Defendants  have

Aids in South Africa

prevalence among sex workers varies between 34 and 69 percent depending on the geographical area. 13 14 15 In 2010, sex work accounted for an estimated 19.8 percent of all new HIV infections in South Africa. 16

Sex workers in South Africa also face high levels of stigma and discrimination and are restricted by the by the laws under which they have to work. Moreover, many sex workers also inject drugs exacerbating their vulnerability to HIV infection. 17 Female sex workers (FSW) are particularly affected with one study reporting an HIV prevalence of nearly 60 percent among FSW compared to 13 percent among women in the general population. 18

Educational organisations have reported difficulties in delivering HIV prevention services to sex workers due to on-going police harassment. One study found that up to 70 percent of women who sold sex had experienced abuse by the authorities: 19

“He put me on the floor. The police officer raped me, then the second one, after that the third one did it again. I was crying after the three left without saying anything. Then the first one appeared again… He let me out by the back gate without my property. I was so scared that my family would find out. ” – Female sex worker, Cape Town 20

In light of this, the South African National AIDS Council (SANAC) recently commissioned the first ever study assessing the number of sex workers in the country. It is hoped that this report will enable South Africa to develop policy and better estimate the need for HIV services among this group. 21

People who inject drugs (PWID) and HIV in South Africa

In 2012, an estimated 16.2 percent of people who inject drugs (PWID) in South Africa were living with HIV. However, PWID account for a comparatively low 1.3 percent of new HIV infections. 22 Data on HIV prevalence among PWID in South Africa is very limited, and where it does exists, is based on small sample sizes. 23

One study has reported that up to 86 percent of South Africans who inject drugs share injection equipment such as syringes and other drug paraphernalia. 24 Another study reported that some PWID re-use equipment between 2 and 15 times. 25

PWID are also associated with other high-risk behaviours such as sex work and unsafe sexual practices. For example, the IRARE study demonstrated a strong link between drug use and risky sexual practices with up to 65 percent of PWID in South Africa thought to practice unsafe sex. 26

Children, orphans and HIV in South Africa

In 2012, an estimated 410,000 children aged 0 to 14 were living with HIV in South Africa. From 2002 to 2012, HIV prevalence declined among children, due mainly to the programme to prevent mother-to-child transmission of HIV. The scaling up of antiretroviral treatment has reduced child mortality by 20 percent. 27

Children at the Raphael Centre in Grahamstown

There are over 2.5 million children in South Africa who have been orphaned by HIV and AIDS. 28 Orphans are particularly vulnerable to HIV transmission; they are often at risk of being forced into sex, have sex in exchange for support, and typically become sexually active earlier than other children. 29

Orphans often have to relocate, and siblings may be split apart, all of which can harm their development. The National Strategic Plan 2012-2016 aims to lessen the impact of HIV on orphans, vulnerable children and youth by ensuring they have access to vital social services, including basic education. 30

Women and HIV in South Africa

An HIV survey in 2012 found that HIV prevalence among women was nearly twice that in men. Rates of new infections among young women aged 15-24 were more than four times greater than that of men in the same age range, and accounted for 25 percent of new infections in the South Africa. Among the analysed populations, the highest HIV prevalence was detected among black African females aged 20-34 (4.5 percent). 31

An HIV-positive woman, South Africa

A number of reasons have been reported for this disparity between men and women. For example, studies have shown how due to the high HIV-positive man-to-woman ratio in South Africa, HIV transmission rates from men to women have increased. 32 Poverty, the low status of women and gender-based violence have also been cited as reasons for the disparity in HIV prevalence between men and women in South Africa. 33 34

Despite these barriers, HIV prevalence among women aged 15-24 is thought to have declined overall between 2002 and 2012. 35

HIV testing and counselling (HTC) in South Africa

The National Strategic Plan 2007-2011 aimed to get 25 percent of all South Africans to test annually and 70 percent of all people to have at least one HIV test. 36 In 2010, a quarter of the population aged between 15 and 49 had been tested for HIV in the previous 12 months. 37

The launch of the national HIV counselling and testing (HTC) campaign in April 2010 resulted in a remarkable increase in the number of people accessing testing. Between 2008 and 2012, annual HIV testing increased from an estimated 19.9 percent to 37.5 percent among men, and from 28.7 percent to 52.6 percent among women. The higher testing figures seen among women have been attributed to the added effect of the PMTCT programme, which enables women to access HIV testing services when they go for antenatal appointments. 38

In South Africa, the link has also been made between an individual’s socio-economic background and the likelihood that they will test for HIV. Those who have taken an HIV test and know their status, are more likely to have a higher level of education, be employed, have accurate HIV knowledge and a higher perception of risk. 39 This suggests that an improvement in the general standard of living would lead to an increase in the uptake of HTC services.

Another determining factor is whether an individual lives in an urban or rural setting. One study revealed that people living in rural areas are only half as likely to have been tested as those in urban areas, with mobile testing units suggested as a means of reaching rural populations. 40

The latest National Strategic Plan has set out more ambitious targets aiming to overcome these barriers to ensure that everyone in South Africa is voluntarily tested annually. 41

Mobile HIV testing in South Africa

Mobile HIV testing has become increasingly popular in South Africa in recent years. For example, in 2008, the Desmond Tutu HIV Foundation (DTHF) launched the Tutu Tester Mobile Clinics. The mobile clinics offer immediate HIV testing as well as testing for tuberculosis, diabetes, high blood pressure as well as breast and testicular cancer. 42

Since its inception, over 35,000 people have used the service. 43 Its success is largely due to the fact that it offers testing for a number of chronic illnesses, so patients can avoid HIV-related stigma:

“Many of our patients have told us that they prefer not to go to public clinics for an HIV test because they are afraid of being seen by people they know. Because we test for other diseases too, like diabetes and high blood pressure, the outside world does not know for what reason patients are waiting at our doors.” – Liz Thebus, Tutu Tester health worker 44

Some have argued that adding mobile HIV clinics to existing testing programs in South Africa would improve survival rates and be cost-effective in resource-limited settings. 45

Home-based HIV testing in South Africa

Other innovative ways of delivering HTC services have also been explored in South Africa such as home-based HIV counselling and testing (HBHCT). HBHCT enables individuals to perform some, or all aspects of an HIV test in a location chosen by them. As a result, home testing has the potential to increase HIV testing uptake, enabling more people to know their status and subsequently present for treatment. 46

One study of door-to-door rapid testing offered by trained counsellors in Kwazulu-Natal had a 75 percent acceptance rate showing the potential of HBHCT in rural areas. However, the study stressed that future programmes should consider community context and tailor messages to a range of key affected groups in order to achieve a high acceptance rate. 47

HIV prevention in South Africa

HIV prevention in South Africa is centred on the National Strategic Plan (NSP). The previous NSP (2007-2011) oversaw a dramatic scaling up of South Africa’s antiretroviral treatment (ART) programme with the purpose of decreasing the number of new HIV infections.

The current National Strategic Plan 2012-2016 is framed primarily around the UNAIDS vision of “zero new HIV infections, zero discrimination and zero AIDS-related deaths.” Perhaps more significantly, it has also committed to “zero new infections due to mother-to-child transmission.” 48 49

Preventing mother-to-child transmission (PMTCT) in South Africa

The latest NSP highlights South Africa’s commitment to ending mother-to-child transmission (MTCT) of HIV. Over the past decade, the country has made great progress in this area due largely to improvements in the choice of antiretroviral drugs (ARVs) and the widespread accessibility of the PMTCT programme. 50

When South Africa first launched its PMTCT programme in 2001, there was very limited intervention before and after childbirth. Guidelines have since been revised several times and are now largely based on recommendations from the World Health Organisation. 51

By 2010, PMTCT services were being offered at 98 percent of all healthcare facilities in the country. Moreover, by June 2011, the national HTC campaign had tested 274,000 women with 78.5 percent of those diagnosed as positive being referred onto treatment. 52 As a result, mother-to-child transmission of HIV in South Africa has fallen to 3.5 percent – meeting the previous NSPs target of less than 5 percent. 53 Between 2009 and 2011, new annual HIV infections among children fell from 56,500 to 29,100. 54

However, maternal mortality has not followed this trend. A review of a large district referral hospital in Johannesburg showed there had been no reduction in the proportion of maternal deaths since 2007, despite improvements in PMTCT. 55

The current National Strategic Plan aims to reduce MTCT rates to under 2 percent at six weeks after child birth and less than 5 percent at 18 months by 2016. 56 Moreover, with the latest WHO-based PMTCT guidelines implemented as of April 2013, it is widely believed that South Africa has reached a point where the elimination of paediatric HIV is a distinct possibility. 57

Condom use and distribution in South Africa

South Africa has responded to its HIV epidemic with a rapid expansion of its condom programme. Male condoms are widely available and the female condom programme is one of the biggest and most established in the world. 58

Between 2007 and 2010, the distribution of male condoms increased by 60 percent, from 308.5 million to 495 million. However, in terms of condoms per adult male (15-49) this only represents a small increase – from 12.7 in 2007 to 14.5 in 2010. In the same period, the number of female condoms distributed increased from 3.6 million to 5 million (a 39 percent increase). However, it is widely acknowledge that female condoms are not a readily available as they should be. 59

Moreover, in recent years, condom usage in South Africa has fallen. In 2008, 85 percent of 15-24 year males reported using a condom during their last sexual encounter – by 2012, this had fallen to 68 percent. Condom use among men aged 25-49 also decreased, from 44 percent to 36 percent. The same survey reported that 53 percent of participants had never used condoms. 60

Voluntary medical male circumcision (VMMC) in South Africa

During the development of the 2007-2011 National Strategic Plan, research emerged in sub-Saharan Africa that voluntary medical male circumcision can reduce the risk of HIV transmission by up to 60 percent. 61 When it was found that some men on the waiting list in South Africa failed to have the procedure, a second analysis reported a 76 percent reduction in the risk of HIV infection for circumcised men compared to non-circumcised men. 62

As a result, in 2010, the South African government quickly rolled out a national voluntary medical male circumcision (VMMC) programme, which aimed to reach 80 percent of HIV-negative men (4.3 million) by 2016. Specifically, the programme aims to offer all men aged 15-49 VMMC at public health facilities in all provinces by 2011. In April 2010, KwaZulu-Natal became the first province to offer VMMC services and by late 2012, there were over 80 VMMC sites. 63

By April 2011, more than 150,000 operations had been conducted with an estimated one new HIV infection averted for every 5 VMMCs conducted. 64 The VMMC programme in South Africa has mostly been well received with 78 percent of women preferring their partner to be circumcised according to the 2011 youth sex survey. 65

HIV education in South Africa

Since 2000, the HIV and AIDS Life Skills Education Programme has been implemented in all public primary and secondary schools in South Africa. The main objectives of the programme are to integrate HIV and AIDS education into the school curriculum as a means of averting new HIV infections as well as to provide care and support for pupils already living with HIV. The programme is mostly implemented through Life Orientation lessons, with other aspects (such as nutrition) covered in other subjects. 66

However, in many places there is a shortage of teacher training on these issues. This means that many schools have few, if any teachers who are able to provide HIV and AIDS education. Furthermore, some schools are resistant to the subject matter. In 2008, teaching unions called for a Life Orientation module to be included in all teacher training. 67 In some cases, gaps in the delivery of the Life Orientation curriculum are filled by independent organisations. 68 In other instances, teachers report feeling uncomfortable about teaching a curriculum that contradicts with their own values and beliefs. 69

High dropout rates in schools also compromise effective HIV, AIDS and sex education. It has been suggested that prevention programmes should be focussed towards younger children while more of them are in education and before they become sexually active. 70

HIV awareness in South Africa

In South Africa, there have been a number of HIV awareness campaigns, which have been supported by the government, the private sector or both.

The 2012 National Communication Survey on HIV/AIDS found that the country’s HIV and AIDS communication programmes were overall having a positive effect, particularly on youth (aged 15-24) with an increase in condom usage, uptake of HTC and male circumcision. By contrast, knowledge around safe breast-feeding practices among pregnant mothers living with HIV remains low. 71 The main HIV awareness campaigns are detailed below.

• Soul City and Soul Buddyz

Soul City and Soul Buddyz were two government multi-media campaigns targeting adults and children respectively. Soul City utilised the concept of ‘edutainment’ to broadcast TV dramas and radio programmes to audiences at prime time to maximise its reach. Soul City is widely regarded as the leading source of information on HIV and AIDS in South Africa (72 percent). The intervention was thought to have reached over 70 percent of all over 16s in the country including 65 percent of rural people and 50 percent without any formal education. Indeed, the initiative has lead to a significant increase in HIV knowledge and has encouraged positive behaviour change. 72

Soul Buddyz was the judged to be the most successful family television show to be produced in South Africa. 67 percent of 8-12 year olds had watched, read or listened to Soul Buddyz (about 4 million children). 73

• loveLife

  A loveLife poster

Since 1999, the loveLife campaign utilised a range of media in order to reduce the number of new HIV infections among young people (aged 12-19). It engages with South Africa youth through outreach and support programmes facilitated by peer educators. loveLife also runs youth centres or ‘Y-centres’ providing sexual health information, clinical services and skills development. 74

• Khomanani

Khomanani was an AIDS awareness campaign launched by the Department of Health. The campaign utilised mass media including radio announcements and situational sketches on television. It aimed to reduce the rate of new HIV infections by 50 percent. Compared with other campaigns, Khomanani had fairly mixed outcome with condom usage unchanged but knowledge of safe sex practices did improve significantly. 75

Antiretroviral treatment (ART) in South Africa

South Africa has the largest antiretroviral treatment (ART) rollout programme in the world, achieving a 75 percent increase in HIV treatment services between 2009 and 2011. 76 77

By October 2012, over two million people were receiving ART, surpassing the country’s universal access target (80 percent) in accordance with the 2010 WHO treatment guidelines (offering treatment to people with a CD4 count under 350). 78

In three provinces, the life expectancy of people receiving ART is now about 80 percent of normal life expectancy provided they do not start treatment late. One study from rural South Africa found that HIV incidence has fallen by 17 percent for every 10 percent increase in the number of people receiving ART. 79

The huge scale-up of treatment in South Africa is especially impressive in the context of years of doubting the effectiveness of treatment at the highest levels of government, and the initial delay and slow pace of delivering a public antiretroviral drug (ARV) programme.

Late initiation of treatment

Though the antiretroviral treatment programme was expanding rapidly, many South Africans were starting treatment with particularly low CD4 counts. Current World Health Organisation guidelines call for initiation onto treatment when a person’s CD4 count drops below 500cells/mm³.

Demonstrations at the 2009 South African AIDS Conference, Durban

In 2009, it was reported that the average CD4 count at which patients started on treatment in South Africa was just 87 cells/mm³ – a level unchanged in four years. 80 One study based in two Durban clinics found that 60 percent of patients were tested when their CD4 counts were below 200 cells/mm³. Of these patients, just 42 percent had begun treatment within 12 months. Of those who were eligible for treatment, more than a fifth died, mostly before beginning treatment. 81

In other cases, individuals simply refuse treatment despite being eligible. A study in Soweto found that of 743 newly diagnosed HIV-positive adults eligible to begin treatment immediately, 20 percent refused. More than a third gave “feeling healthy” as the reason for refusing treatment despite having a low CD4 count with many also co-infected with tuberculosis. 82

Task shifting

In order reach 80 percent of those in need of antiretroviral treatment (ART) by 2011, the South African government employed task shifting. Task shifting refers to the reallocation of tasks among available staff.

ART services in South Africa had initially been hospital-based and doctor-led. However, the rapid rollout of ART overburdened HIV and AIDS clinics demanding that nurses (rather than doctors) initiated antiretroviral therapy; lay counsellors (rather than nurses) carried out HIV tests; and pharmacy assistants (rather than pharmacists) prescribed ARVs. This increased the number access points to treatment and care by reducing the ‘bottlenecks’ in the healthcare system created by a shortage of staff able to provide vital HIV services. 83

Indeed, task shifting proved very successful. As well as increasing access to ART, quality of HIV care remained stable and even increased in some places. Moreover, a number of clinics reported higher job satisfaction, lower workloads and less usage of sick leave among their staff. 84

The future of antiretroviral treatment in South Africa

The new 2013 WHO guidelines (treatment for those with CD4 counts under 500) have since made many more people eligible for treatment in South Africa. 85 The South African government is yet to make this move primarily due to the cost yet it is argued that early treatment would actually save money by preventing illnesses like tuberculosis in people living with HIV:

“The prevention benefit of early ARV therapy cannot be overlooked and contributes also to improved life expectancy to (HIV-negative) partners and decreased costs over time.” – Rochelle Walensky, Harvard University 86

HIV and tuberculosis (TB) in South Africa

South Africa currently has the world’s third largest tuberculosis (TB) epidemic – TB prevalence has increased by over 400 percent in the last 15 years. 87 TB is the leading cause of death in South Africa. In 2011, of the half a million people who died in South Africa, 12 percent of men and 10 percent of women died from TB. 88

The HIV epidemic in South Africa fuels the TB epidemic. People living with HIV are at a far higher risk of developing active tuberculosis as a weakened immune system facilitates the development of the disease. Similarly, TB can accelerate the course of HIV. 89

Roughly 1 percent of the South African population develops TB every year and the number of TB cases continues to rise. 70 percent of people living with HIV in South Africa are co-infected with TB.

However, more promisingly, the TB cure rate has improved in the last decade, from 54 percent in 2000 to 71 percent in 2009. 90 Between 2010 and 2011, the number of people living with HIV who received preventative TB medication nearly tripled, from 146,000 in 2010 to 373,000 in 2011. 91

The 2007-2011 NSP promoted the integration of HIV and TB services to ensure that people who are co-infected receive the appropriate treatment and care.

“We cannot fight AIDS unless we do much more to fight TB.” – Nelson Mandela 92

Funding the response to the HIV epidemic in South Africa

Despite having the world’s biggest antiretroviral treatment programme, South Africa had been paying significantly more than other low and middle-income countries for its antiretroviral drugs. In 2010, bound by the terms of its existing tender for ARVs, the government only bought one third of its products at internationally completive prices. 93

Over the following two years, a 53 percent reduction in the cost of ARV drugs with savings of $640 million was made. 94 This new tender introduced a three-in-one or fixed-dose combination (FDC) drugs helping to reduce the pill burden and improve adherence. 95

South Africa largely funds its HIV and AIDS programmes, with donors accounting for less than 25 percent of its HIV response. 96 However, based on National Strategic Plan 2012-2016 targets, the gap between funding requirements and available funding for HIV, Sexually Transmitted Infections (STIs) and TB is expected to grow.

The future of HIV and AIDS in South Africa

Now, over 2.5 million people are on antiretroviral treatment making the country’s public HIV treatment programme the biggest worldwide. Moreover, these efforts are now largely funded from South Africa’s own resources, enabled by the introduction of a three-in-one or FDC ARV, which has already saved billions of rands.

HIV prevention initiatives are having a significant impact on mother-to-child transmission rates in particular, which are falling dramatically. New HIV infections overall have fallen by half in the last decade. Moreover, while South Africa is yet to make significant inroads into the reduction to TB deaths, the country has made great progress in the scaling up of ARV access for co-infected people.

However, there were still 370,000 new HIV infections in 2012, the world’s highest. While the short term financing of South Africa’s HIV epidemic is secure, in the longer term, the South African government needs to explore other strategies in order

– See more at: http://www.avert.org/hiv-aids-south-africa.htm#sthash.I0dcTvex.dpuf

Klein Complaint

Arnold W. Klein, MD

9615 Brighton Way, M-­110 Beverly Hills, CA 90210

310-­721-­5550

SUPERIOR COURT OF CALIFORNIA FOR THE COUNTY OF ORANGE

ARNOLD W. KLEIN, MD.

vs.

Plaintiff,

MUHAMMAD KHILJI, an individual;;;; JASON ROGER PFEIFFER, an individual;;;; KHILJI-­ PFEIFFER,LLC, a California limited liability company;;;; KHILJI& KLEIN, LLP, an unknown business entity;;;; THE PRIVAYE BANK OF CALIFORNIA, a

California  Corporation BANC OF CALIFORNIA, a California  Corporation;;;; EXCEL NATIONAL BANK, a California banking corporation;;;; CITY NATIONAL BANK, a California corporation;;;; Z &  P INVESTMENT  SERVICES,LLC;;;; a

California limited liability company;;;; ABLE INVESTMENT SERVICES, LLC an individual;;;; RICHARD GOODRICH, PETER GURFEIN,JOHN REITMAN,BRADLEY SHARP,RICHARD CHARNLEY,ROBERT LORSCH, TODD GALLINGER

)

)

)

)

)

INTRODUCTION

22.A.

Compassionate Plea for Relief by the Court. Presently, Dr. Klein is Dr Klein in desperate need of funds for medication of his neuropathy which includes Rituxin-­‘($24,000 for each six month treatment)as funds to repair of damage from the heart attacks caused when his Trustee withheld his SSI twice ($90.000), Dr. Klein also requires funds a vehicle outfitted for a disabled individual ($75,000) similar to the one taken from him illegally

on 2/25/2003 when Dr. Klein was subject to an illegal search and seizure by Sharp, Bradley Sharp and Eugene when they performed an illegal search and seizure on his Palm Springs home removing $4-­5 worth of items without a list or warrant.

23. Dr. Klein must prevent foreclosure on his Palm Springs home the trust of which is fraudulent and is listed as Klein, Arnold William. The home was financed through City National Bank Flower with a mortgage not signed by Klein. The date on this mortgage is July 2008 and is same fraudulent trust used by Sharp on the illegal sale of Klein’s Laguna Home suggesting that Sharp has been involved since then as Khilji’s records indicate, Being without SSI for 54 days and thus unable to buy his medication compromised his health. Dr. Klein’s retirement funds are rightfully his and by compassionate plea may this be dealt with first to provide Dr. Klein with needed legal counsel, medical management, and a mode of transportation. Dr. Klein’s retirement funds of $6.4

Klein v. Khilji et al. -­​  7

million are rightfully his by State and Federal law and the Bankruptcy Reform Act of 2005. Bradley Sharp( an insider at Private Bank-­ see

Narva-­Namco case) has illegally attempted to withhold these funds from Dr. Klein and give them to embezzlers who have laundered Klein’s retirement through fraudulent corporate accounts at City National Bank,Private Bank and Excel.(Sharp has no control over Corporate Accounts,(see Second Amended Complaint) He also is attempting to give Klein’s Corporate income from 2009-­2010 of $4-­5 million Laundered

through the fraudulent Excel Account to the embezzlers.24. CODE OF CIVIL PROCEDURE SECTION 631-­636 provides Dr. Klein with the right in California for a speedy trial by Jury. Dr. Klein’s rapid trial is critical in that his physician, Dr. Les Weiner, former chief of neurology at the Leslie Weiner Clinic and Neurology Research Institute Keck School at the University of Southern California doubts Dr. Klein’s ability to survive the next six months in his present condition. This is a plea for support, understanding, and the need for a rapid trial.

25. Dr. Arnold William Klein is the beneficiary of the Trust 1995 Arnold William Klein MD 553 S. Windsor Blvd. He is a 70 year old disabled elder who is easily

Klein v. Khilji et al. -­​  8

overmedicated. Dr. Klein has been robbed by a series of Bank Insiders and embezzlers who opened Bank Accounts by Identity theft, and Bank Fraud, to launder and steal his funds. Bank insiders Ron Freed of the Flower St Branch City National Bank and Todd Nielson and Bradley Sharp of The Private Bank of California (TPBOC) in violation of Federal and California law (although after these events TPBOC was bought out by Banc of California, which thereby assumes TPBOC’s obligations, the primary bank entity will continue to be referred to as TPBOC in what follows.) These banks have sold his homes with fraudulent mortgages and laundered his funds. From having had

$80 million in non-­liquid assets such as homes and art and

$40 million in liquid assets after this theft and massive fraud Dr. Klein is now Penniless. Because of the overmedication Dr. Klein only began to become aware of these nature of these frauds by late June 2011 after  the Moban was gone and his own medication began to stabilize;;;;

. Muhammad Khilji had a fiduciary duty to Dr. Klein requiring trust and professional responsibility. These banks allowed Khilji to

Klein v. Khilji et al. -­​  9

open accounts without CIP Codes and launder Klein’s funds without issuing SARS (Suspicious Activity Reports).

The Banks who allowed this to occur -­ TPBOC, City National Bank and Excel must be reported to the FDIC and the IRS. Both Ron Freed, an insider at City National Bank, and Bradley Sharp, an insider at Private Bank( see Narva Namco case) are responsible for these actions. Sharp and Khilji used the toxic Anti-­ Psychotic Moban combined elevating his Zanaflex on Dr.

Klein as his medical records show. This would make Dr. Klein incapable of rational thought and enter Bankruptcy Court, a decision he would never have made if not mentally impaired. This has been confirmed by Dr. Leslie Weiner, ex-­Chief of Neurology of the Neurology Clinic and Research Institute, Keck School of Medicine at the University of Southern California. (AB140-­undue influence)

28, C. Fraud Upon the Court: Mortgages as Documents are not recordable without good notarization. In California, the reason these documents are notarized in the first place is because otherwise they will not be accepted by the County recorder. Moreover, a notary who helps commit real estate fraud is liable for

$25,000 per offense. Once the document is recorded, however, it is entitled to

a “presumption of validity” (Civil Code§2924). Therefore, the notarization of a false document by fraudulent

signature not only constitutes fraud, but is every bit intended as part of a larger conspiracy to commit fraud upon the court. Dr. Klein’s homes were sold aware the trust on Klein’s mortgages is fraudulent as was his entrance into bankruptcy court due to his mental incompetence caused by intentional over medication by his fiduciaries and financial caretakers. He was over medicated \e for the purpose of incapacitating him and allowing the perpetrators to both alter his will and trust and to enter the court. In violation of all the above Sharp and Freed are attempting to make Dr. Klein homeless without even his retirement funds in violation of State, Federal Law and the Bankruptcy Reform act of 2005.

28. B. Undue Influence:  Dr. Arnold  Klein is a 70 year old disabled elder whose disability allowed Khilji and Pfeiffer to take advantage of him  by over-­medicating him so while he was confused they could rob him. But how can a disabled Elder be evicted  from his homes on the basis of a mortgage he never made, deposited in accounts he never opened containing a  trust that is not his? Khilji overmedicated Dr Klein with  the toxic atypical antipsychotic  Moban to get him to enter Banruptcy Court.

Klein v. Khilji et al. -­​  11

1. Klein was in a great financial position in 2008. His corporate income was approximately $4 million per year. He owed very little or

next to nothing on his homes, of which there were three homes held by his Trust, “The 1995 Arnold William Klein MD Revocable Trust” which hold Dr. Klein’s homes, art, cars, memorabilia and his Medical Practice.

1. Dr. Klein trusted his accountant, Muhammad Khilji, and office manager, Jason Roger Pfeiffer, to fulfill their professional duties with integrity and devotion. Dr. Klein relied upon his long-­time financial advisors, Jeff Zone and Claudia Peltier, to protect his assets and exercise diligence in managing his investments. Dr. Klein

had trusted Zone and Peltier for over twenty-­five years and was shocked when he realized he had been robbed by his office manager, Jason Pfeiffer, and accountant Muhammad Khilji (referred to him by Zone and Peltier).

1. Zone and Peltier did not call Klein even once as Khilji depleted his retirement funds to which Khilji was to have no access. Khilji and Pfeiffer, in concert with insiders at TPBOC, City National Bank, and Excel Bank took every penny Klein had. The scope and complexity of this robbery indicates that his accountant,

Klein v. Khilji et al. -­​  12

Muhammad Khilji, must have had help. The help came from TPBOC, which was owned by judges, lawyers and Trustees of the Bankruptcy Court, from various insiders at City National Bank, and insiders at Excel Bank. Unknown to Dr. Klein, he had been almost continually over medicated by the embezzlers to varying degrees so he would not comprehend what was occurring (AB-­381 Estates and Trusts: Undue Influence and Elder Abuse,

AB-­140 Undue Influence). This is supported by the reports of Detective Scott Ross, Dr. Klein’s internist, Allen Metzger, and Dr. Les Weiner. Dr. Klein would check the prefilled medicine boxes he received weekly from the pharmacy and there was no evidence of alteration.

32. But in a very stealthy manner, one of the embezzlers, who was also Klein’s caregiver, would alter Klein’s medications prior to giving them to him. Klein did not suffer from failing health, but was drugged. At times Dr. Klein seemed incapable to make appropriate business, financial or personal decisions because Khilji and Pfeiffer also had altered his medications. At one time, they dangerously elevated his Coumadin level and illegally changed Klein’s Will and Trust with

Klein v. Khilji et al. -­​  13

Todd Gallinger, an Orange County attorney who is the membership Chairman of Cair. Cair recently has been found involved in a large money laundering scheme in Washington DC involving the Muslim Brotherhood and Hamas. Hamas itself has been involved with South American Drug Gangs and Mexican Drug Gangs and the assination of Jews.Gall

case so something happens to Dr. Klein.” Klein is disabled and depends on others for procuring and dispensing his medications. From the records of Detective Scott Ross it appears the Coumadin overdose was intended to kill Dr. Klein making Khilji and Pfeiffer executors of his estate.

. Dr. Klein was over medicated with the dangerous atypical anti-­psychotic, Moban, to make him mentally incompetent and easily persuaded to enter Bankruptcy Court a decision he would never have normally made. Three fraudulent loans were made on Klein’s properties using the fraudulent trust created by Gallinger. the illegal Able and Dominion loans were deposited into fraudulent corporate accounts at TPBOC by , Muhammad Khilji, J. The manner in which the title was transferred to Robert Raskin after purchasing Klein’s Laguna home was illegal in that these loans are

fraudulent. Therefore clear title cannot be achieved with the sale of the Windsor or Laguna Properties.

37. E. How 22 Acc ounts were opened

1. On June 24th, 2008 Dr. Klein met with 10 individuals at City National Bank in Beverly Hills over a recent embezzlement of his assets by a former employee

Bruce Ayres. He had paid for items without approval using the Minimally Invasive Aesthetics LLC Credit Card and forged checks with the Minimally Invasive Aesthetics LLC (though Khilji had illegally changed MIA LLC to MIA INC he never obtained Dr. Klein’s approval and remained his accountant as late as 200ounts Were Opened by Khilji and Others: City National Bank Flower Street accounts were opened by identity theft of Dr. Klein by Khilji, Charmley, and Gallinger in 2008 with insider assistance of Ron Freed.

Khilji in association with Richard Charnley,Robert Lorsch, City National Bank, Bank of California Ron Freed, Bradley Sharp would be responsible for a loss to Dr, Klein from MIA llc of at least 9 million dollars CC3345

1. In June of 2008 At the meeting with City National officials it was agreed only Dr. Klein could sign checks of any of his banking accounts and that he was to be called for any check over $10,000.00. At City National Bank Flower Street Richard Charnley was largely responsible with Muhammad Khilji for the total depletion of all of Klein’s Corporate savings, and all of Klein’s Financial Assets which were in the Beverly Hills branch

of City National Bank. Dr. Klein used only one Bank, the Beverly Hills branch of City National Bank.

Klein v. Khilji et al. -­​  16

1. Khilji and Richard Charnley,Dr Klein attorney, starting in 2008 with the help of Ron Freed, Vice President of the City National Bank Flower

St Branch (CNBFS), opened eight accounts in Dr. Klein’s name One account

was “Arnold William Klein, A Special Account” by which they would launder funds from Dr. Klein’s retirement fund at Ameritrade of over $3 million.. By the time the illegal accounts were opened at TPBOC 35% remained in Klein’s retirement. $2 million was deposited in the Fraudulent Minimally Invasive Aesthetics retirement accounts at TPBOC and an amount to fraudulent Excel Accounts, The total in Klein’s retirement that was laundered was $ 6.4 Million.

1. The accounts at CNBFS were opened by identity theft and bank fraud to launder corporate savings, personal savings, retirement CDs, research savings (Minimally Invasive Aesthetics), and ready cash from the accounts in Dr. Klein’s name at Beverly Hills branch of City National Bank to those accounts at CNBFSB. Charnley totally depleted Klein’s accounts at City National Bank Beverly Hills. By April 29 .2010. Through Corporate Account Arnold William Klein, A

Medical Group, (a group that does not exist) Khilji made two illegal corporate l

Credit Lines, one in 2008 and one in 2009 at CNBFS, One in 2008 was for

$1.1 million. On May 10th, 2009 Khilji made the second credit line deposited in an account “Arnold William Klein, a Medical Group” at the CNBFS..

1. The loan had the address of Dr. Klein as 553 S. Windsor Drive #204, while Klein’s real address is 553 S. Windsor Blvd. It has wrong years in practice and Khilji could not spell ‘doctor’ correctly. It was not signed by Dr. Klein. There is no reference to Klein’s Laguna Home on this note and this is an illegal Corporate credit line of $1.5 million, This would be illegally presented in court as a mortgage on Klein’s Laguna home and Bradley Sharp in conspiracy with Freed would illegally evict Dr. Klein a disabled elder in 7 days in violation of the California Homeowners Bill of rights based on this fraudulent Corporate Credit. The trust on this note is the fraudulent trust produced by Todd Gallinger of which Sharp was aware from Dr. Klein’s meeting with Reitman
2. The loss to Klein by this action is $20 million from City National Bank, $15 million Laguna home,$4 million Laguna furnishings, $ 2.6 million in fraudulent credit lines, $5 million Frank Gehry Plans, $1.5 million fraudulent Dominion note

Klein v. Khilji et al. -­​  18

Lost income d having to move to Palm Springs over four years $16 million.CIVIL CODE § 3345Treble Fines, Penalties, or Remedies) -­ loss to Klein by Actions of Freed,Sharp, Charnley, Gallinger TPBOC,CityNat Bank-­

$71 Million -­ Fines, , (AB-­381 Estates and trusts: undue influence and elder abuse.)

In July of 2008, Dr. Klein’s bought a home in Palm Springs, This home was financed through  CNBFS, the note is not signed by Dr. Klein an has the fraudulent trust that Sharp used when he sold Klein’s Laguna home. Klein,

Arnold William45. F. The Dispossession of Financial Assets: The only Bank Dr. Klein ever used was CNBBH over a small embezzlement. It had to do with Accounts of Minimally Beverly Hills. On June 24th, 2008 Klein had a meeting with 10 individuals at Invasive Aesthetics LLC and all agreed Klein would be called on all Checks over $10,000.00 and only Klein could

sign checks. Yet eight fraudulent accounts were opened at City National Bank FS including the loan on Klein’s Palm Springs home which also has a fraudulent  trust and Deed of Trust, and trust. Accounts were opened by July

2008  by Khilji, Charnley, with the help

46. In Aug 2009 10  fraudulent accounts were opened at TPBOC’s by Khilji,Pfeiffer and Robrt Lorsch with insider assistance of Sharp and Reitman, Of the accounts two were named Khilj-­PfeifferLLP and represented

Khilji, Pfeiffer, Lorsch, and Lorsch’s Company My Medical Records.Com. In the” Second Amended Complaint, Attorney to the Trustee Bradley Sharp( an Insider at Private Bank) States Klein was “ill to the point of incapacity and unable to make rational personal,financial  and Business decisions.” Klein was not ill but drugged when they altered his will and trust and  he entered,

Bankruptcy Court. Sharp,Gurfein

and Reitman state all the accounts at Private Bank were opened by identity theft of Dr, Klein, and bank fraud for money laundering by Khilji, Lorch and Pfeiffer. The financial total they list including the Able and Dominion loan( which they state are fraudulent is  $ 7.0 million laundered through TPOC

but there is more laundered through TPOC. They then attempt to give Klein’s retirement of $ 6.4 million to the embezzlers as well as as his Corporate income of $4-­5 million that was laundered by the embezzlers.(CC. 3345 Sharp,Gurfein, Reitman,TPBOC Khilji, Pfeiffer Lorsch-­ >$18 million.) This is an obvious

Klein v. Khilji et al. -­​  20

conspiracy. The purpose of TPOC was to bankrupt Klein to the extent he could no longer mount a proper legal defense and get him into bankruptcy court.. TPBOC also violated the Bank Secrecy Act by allowing mirror image wiring of funds between the fraudulent corporate accounts at TPBOC and Excel accounts in amounts to be proven at trial. Cash from the accounts at CNBFS, Excel Bank and TPBOC equal to $1.3 million or more was removed by the embezzlers. A full forensic accounting including the Khilji-­Pfeiffer LLC Accounts is required.

1. In November 2009, without Dr. Klein’s knowledge, Pfeiffer and Khilji opened corporate payroll and revenue accounts in the name of Dr. Klein’s medical practice at Excel National Bank (“Excel Bank”).Dr. Klein never entered Excel Bank and was not aware of this. It appears that Pfeiffer and Khilji represented themselves as officers of Arnold W. Klein MD, a Medical Corporation.
2. The accounts were opened under the following names and account numbers: Arnold W. Klein MD – A Medical Corporation

Arnold W. Klein MD – Payroll xx3275 Arnold W. Klein MD – Payroll Old xx306 Arnold W Klein MD.

stated, Khilji and Pfeiffer also conspired to launder millions of dollars from Dr. Klein through mirror image wire transfers. Khilji would approve substantial wire transfers in favor of Pfeiffer;;;; and Pfeiffer would turn around

and approve substantial wire transfers in favor of Khilji.

1. These transactions were used to remove or launder substantial funds from the corporate accounts Khilji and Pfeiffer created at TPBOC and Excel Bank without Dr. Klein’s knowledge. The banks made no effort to contact Dr. Klein, took no steps to verify the nature of the transactions, and failed to implement and employ standard industry protections for suspicious transaction activity involving Dr. Klein’ s accounts. Activity of this type would be termed a violation of the Bank Secrecy Act or money laundering, which Khilji and Pfeiffer did at Excel Bank.
2. Pfeiffer also charged exorbitant amounts to a corporate American Express credit card account that he made “paperless” so as to avoid leaving a paper trail that could be discovered by Dr. Klein. They also made fraudulent charges to Dr. Klein’s own credit card including boat cruises, plane trips, diamonds, clothing and European travel. Khilji also participated in and benefitted from this fraudulent credit card activity. to $1.4 million

well as $2 to 3 million from the MIA LLC accounts at City National Bank FS and were designed to rob Dr. Klein’s retirement funds from MIA, LLC.

55. Khilji illegally changed the name on the email address of the MIA retirement fund to that of his own suite with Dr. Klein’s former Roxbury building office tp directly confirm his authorization for the liquidation of the

retirement funds which were then embezzled although an large IRS income tax was then wrongly imputed to Dr. Klein who neither authorized nor benefited from the liquidating of his retirement accounts.

1. Khilj, Pfeiffer and Lorsch opened accounts at TPBOC by identity theft with Sharp and Gurfein, This bank is owned by Judges and Lawyers of LA Bankruptcy Court and run by Trustees. Account statements were sent to an address other than that of Dr. Klein.
2. June 2010 Khilji, Pfeiffer, Thall, and Gallinger attempted to sell Klein’s Laguna Home behind his back with a mortgage made with the help of Sharp. Dr. Klein was drugged so he would not visit this property.
3. On October 31, 2010 Klein’s house on 553 S. Windsor Blvd. was set ablaze. Klein and his aunt almost

Klein v. Khilji et al.

-­​ 25

died. Chartris moved Dr. Klein into a rental pending repairs of the house and allotted him an Alternative Living Expense which Klein is due until house is repaired

1. Bradley Sharp, in collusion with Chartis, prevented restoration of the primary Klein residence at 553 S. Windsor and after Klein entered Bankruptcy Court Sharp denied Klein access to his home by a phony “lead abatement” treatment (i.e.

pre-­painting the interior walls) and then forced Klein out of his rental, close to his practice, by cutting off his ALE. Klein was forced into an arduous daily commute from his Laguna Beach house to his place of work in Beverly Hills.

1. Trustee Bradley Sharp removed 1,400 boxes of Klein’s possessions from the 553 S. Windor house in storage without a warrant or a list knowing the mortgage is fraudulent as stated in the “Amended Complaint” (See Appendix A.)
2. The Trustee then sold Klein’s Windsor house unrepaired with a fraudulent Mortgage. This created a loss to Klein, a disabled elder, of $50

million by mortgage fraud. It should be noted that Dr. Klein had invested heavily into making the house compatible with his disabilities, includin

1. G. The Dispossession of Other Valuable Non-­Li

1. Encinas also refused to pay the $1.3 million to repair the Laguna home from damage done and art stolen by Khilji and Pfeiffer in their attempt to sell that home.
2. Dr. Klein holds Chartis responsible for the loss of his Windsor home, his art, and a year’s loss of income all of which totaled $70 million. (CIVIL CODE § 3345 Treble Fines, Penalties)
3. Klein’s Windsor home was sold on the basis of fraudulent Able Loan made by Khilji with the fraudulent trust deposited in the illegal corporate account established in Dr. Klein’s name at TPBOC . Bradley Sharp his Attorney John Reitman are both insiders at Private Bank and are in conspiracy with the embezzlers and City National Bank. They have sold Klein’s homes with a fraudulent loans and stolen is assets($40 million Art) By Congressional law he must be removed as Dr. Klein’s trustee but Dr. Klein never properly entered the court.both by Elder Abuse Laws (AB140 undue influence) and Bankruptcy Law(1004.1)Sharp and Reitman’s position calls for fraud upon

the court with no statute of limitations. They are attempting to make Klein homeless and penniless so he without a warrant or a list in violation of U.S. constitutional protections of due process, knowing the mortgage was

fraudulent as stated in the “Second Amended

Klein v. Khilji et al. -­​  28

Complaint.” However in the complaint they ignored the theft of two of Klein’s Cars by Khilji, Lorsch, and Pfeiffer and paying a fake loacannot present a defense or afford legal counsel.

65, In regard to Dr. Klein’s Laguna home, Bradley Sharp evicted Dr. Klein and his family on seven days’ notice with the help of Ron Freed on the basis of a fraudulent Corporate loan (not a mortgage) made and deposited in the fraudulent Corporate Accounts at City National Bank Flower Street branch. The deed of trust under which the home was registered is the 1995 Klein, Arnold William trust again, not the real trust, and Klein demands return of his two homes. In regard to Windsor, in that it was

1. Gurfein, Sharp, Reitman, Khilji, Pfeiffer, and Lorsch have also stolen over a million dollars’ worth of jewelry of Dr. Klein gifted to Klein by various patients. The financial loss to Klein by the sale of Laguna is $10 million home, $4 million in art and furnishings, $1 million in Frank Gehry’s Plans. CODE OF CIVIL PROCEDURE SECTION 631-­

1. The Trustee Bradley Sharp removed 1,400 boxes of Klein’s

possessions

1. In the “Second Amended Complaint” Reitman and Gurfein admitted that Khiji, Lorsch. and Pfeiffer had laundered $ 7 million from Dr. Klein and that they gave the embezzlers Klein’s retirement fund of $6.4 million and corporate income of $4 million. Sharp and John Reitman are insiders at TPBOC. Sharp and the former head of TPBOC, R. Todd Neilson, were

co-­Trustees in the “Narva-­Namco” case. Admitting the accounts are opened by identity theft at TPBOC for money laundering is admitting their own guilt.

1. They did not report this to the U.S. Treasury Department Financial Crimes Enforcement Network (FINCEN) and as this has harmed one disabled elder the laundering this person’s individual funds could have serious consequences for all other disabled, elderly singles, couples, widows and widowers, as all are vulnerable to embezzlement by their banks, accountants, financial advisers. They are then left without liquid assets and their consequent inability to protect themselves from creditors, due to the predatory nature of the L.A. Venue of the

Klein v. Khilji et al. -­​  30

U.S. Bankruptcy Court, with “bankruptcy boutique” legal firms specializing in depriving the robbed and wronged of their non-­liquid assets at cheap prices and then flipping them for sale to insiders.

1. The cases against TPBOC, Khilji and Pfeiffer were never heard and in violation of California law. Dr. Klein was denied due process of Law. WHEREFORE, Plaintiff seeks relief as set forth below.

FIRST CLAIM FOR RELIEF

(Breach of Fiduciary Duty -­ Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­Pfeiffer, LLC, Khilji & Klein, and LLP and DOES 1-­50)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. Dr. Klein placed trust and confidence in Khilji and Pfeiffer to exercise their duties as two business managers, bookkeepers and accountants with integrity and good faith. Khilji and Pfeiffer accepted Dr. Klein’s trust and confidence, and actively encouraged him to rely upon them in the conduct of his financial affairs.
2. By virtue of their provision of business management and accounting services as described above, Khilji and Pfeiffer owed fiduciary duties to Dr. Klein with

Klein v. Khilji et al. -­​  31

respect to his business and personal financial affairs, including but not limited to duties to act diligently and faithfully, to disclose all relevant and material information, to fully account for all assets, and to act with utmost care and loyalty.

1. Khilji and Pfeiffer breached their fiduciary duties to Dr. Klein by, among other things, taking out lines of credit and making other loan arrangements secured by Dr. Klein’s property and using the proceeds for their personal use;;;; diverting and siphoning millions of dollars from Dr. Klein’s bank and investment accounts without his knowledge or authorization;;;; writing and negotiating numerous checks from Dr. Klein’s accounts and concealing their activity;;;; charging unauthorized expenses for credit cards opened in Dr. Klein’s name and using the funds for their personal use;;;; and failing and refusing to disclose their activities to Dr. Klein.
2. Putting Dr. Klein in a position of financial ruin and immediate medical peril. Dr. Klein’s neurologist has stated “Dr. Klein is a disabled yet Brilliant Physician who’s use of Botox in neurology has revolutionized the field.

These people are determined to destroy him and he cannot remain in their

hands.” Les Weiner, form

Klein v. Khilji et al. -­​  32

chairm of Neurology at the Leslie Weiner Neurology Clinic and Research institute at Keck Medical Center USC.

1. The embezzlers and insiders at the banks and individuals have erected Websites and used the written, visual and social media to expose Dr. Klein to invidious investigations by Kimberly Wilson of the California Medical Board. He has been totally cleared but their actions tarnished Doctor Klein’s imaged to the extent his office income cannot support him and his physical state he must return to Orange County or Los Angeles and have funds to restore his reputation.
2. As an instrument of their breaches of duty, Khilji and Pfeiffer used their companies, Khilji-­ Pfeiffer, LLC and Khilji and Klein, LLP (the “Khilji/Pfeiffer Entities”), to perpetuate their fraudulent transactions and conversion of Dr. Klein’s assets and property. As a direct, actual, and foreseeable result of Defendants’ breaches of fiduciary duty, Dr. Klein has been damaged in an amount that has not yet been fully ascertained, but in any event an amount not less than $10 millions.
3. The aforementioned conduct of Defendants was intentionally

deceitful, fraudulent, and done with the intent of depriving Dr. Klein of his property and

Klein v. Khilji et al.

-­​ 33

legal rights and to cause him injury. Defendants’ conduct was and is despicable and subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights so as to justify an award of exemplary and punitive damages.

SECOND CLAIM FOR RELIEF

Conversion -­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-­50)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. Defendants removed funds and property from Dr. Klein’s assets.
2. That property includes, for example, equity in the Windsor Property, which was obtained and used by Defendants through fraudulent transactions. That property also includes credit, which Defendants obtained and used through their excessive and unauthorized use of credit cards belonging to Dr. Klein. Defendants converted the equity and credit into cash, which they kept and used for their personal use and not for the benefit of Dr. Klein or his

medical practice and the property includes cash, which Defendants withdrew from bank, investment and retirement accounts containing Dr. Klein’s funds.

Klein v. Khilji et al. -­​  34

1. These uses of property were for Defendants’ sole benefit and were without permission of Dr. Klein, in direct violation of the duties Defendants owed Dr. Klein as business managers and trusted bookkeeper/accountant. Accordingly, Defendants took property to which they were not entitled. Defendants also used valuable personal property from the Laguna Property without Klein’s knowledge. These acts constitute conversion of property that Dr. Klein has an ownership interest in. Dr. Klein has on several occasions demanded return of the funds taken, but, to no avail.
2. As a direct, actual, and foreseeable result of Defendants’ conversion, Dr. Klein has been damaged in an amount that has not yet been fully ascertained, but in any event an amount not less than $10,000,000.00. The

aforementioned conduct of Defendants was intentionally deceitful, fraudulent, and done with the intent of depriving Dr. Klein of his property and legal

rights and to cause him injury. Defendants’ conduct was and is despicable and subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights so as to justify an award of exemplary and punitive damages.

Klein v. Khilji et al. -­​  35

THIRD CLAIM FOR RELIEF

(Deceit/Concealment -­ Against Fraud Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-­50)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. As described herein, Khilji and Pfeiffer obtained Dr. Klein’s signature on key documents under false pretenses and for purposes that were not disclosed to Dr. Klein. Khilji and Pfeiffer made these false

statements and misrepresentations with the intention that Dr. Klein would rely thereon. Khilji and Pfeiffer also failed to disclose, and otherwise concealed, material information regarding their activities relating to Dr. Klein’s real property assets, bank accounts, credit cards and other property interests.

1. Dr. Klein did in fact rely upon Khilji and Pfeiffer’s representations and false or misleading statements to his detriment, and it was foreseeable that he would do so. If Dr. Klein had been aware of Khilji and Pfeiffer’s true purposes and intentions, he would not have signed the documents as requested. In many instances, Dr. Klein was never made aware of the true nature or purpose of

the documents. If he had

Klein v. Khilji et al. -­​  36

known the truth, he would not have permitted Khilji and Pfeiffer to exercise control over his professional and personal financial affairs.

1. As a direct, actual, and foreseeable result of Defendants’ fraud and forgeries, Dr. Klein has been damaged in an amount that has not yet been fully ascertained, but in any event an amount not less than $10,000,000.00.
2. The aforementioned conduct of Defendants was intentionally deceitful, fraudulent, and done with the intent of depriving Dr. Klein of his property and

legal rights and to cause him injury. Defendants’ conduct was and is despicable and subjected Dr. Klein to cruel and unjust hardship in conscious disregard of his rights so as to justify an award of exemplary and punitive damages.

FOURTH CLAIM FOR RELIEF

(Accounting -­ All Defendants)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. As alleged above, a fiduciary relationship

existed between Dr. Klein and Khilji and Pfeiffer. A fiduciary and/or contractual relationship also existed

Klein v. Khilji et al. -­​  37

between Dr. Klein and Z & P Investment Services, LLC. As a result of the conduct alleged herein, a relationship also existed between Dr. Klein and Bank of California, Excel Bank, City Bank, Able, NXT and Dominion.

87. Due to Khilji and Pfeiffer’s wrongful acts as alleged above, Defendants are indebted to Dr. Klein in an amount that can only be ascertained by an accounting. For example, an accounting of the assets held by TD Ameritrade, Bank of California, Excel Bank and City Bank and unlawfully converted or fraudulently transferred by Khilji and Pfeiffer is required to determine the amount of indebtedness. And the amount of credit and home equity taken and used by Defendants (including Dr. Klein’s interest in the Windsor Property), which is currently subject to a claim by Able and/or NXT, and Dr. Klein’s interest in the Laguna Property, which is currently subject to a claim by Dominion and/or Davis), the extent of which is currently unknown to Dr. Klein, must be accounted for. Due to the foregoing, an accounting is required to determine the exact amount Defendants owe Dr. Klein.

FIFTH CLAIM FOR RELIEF

(Fraudulent Conveyance -­ Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­Pfeiffer, LLC, Khilji & Klein, LLP and DOES

1-­50)

Klein v. Khilji et al. -­​  38

88. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. As alleged above, Defendants have committed acts constituting, among other things, fraud, breach of fiduciary duty and conversion. Defendants’ acts have removed property from Dr. Klein’s possession and prevented Dr. Klein from accessing his property and other assets. Title to certain property, purchased by Khilji and/or Pfeiffer with Dr. Klein’s funds and without his knowledge or authorization, has not been properly transferred to Dr. Klein. Dr. Klein is informed and believes, and thereon alleges, that Defendants removed assets, monies, and/or property of Dr. Klein’s assets and businesses and prevented him from accessing such assets, monies, and/or property to which he has rights. Defendants have been unjustly enriched by their acts in contravention of their fiduciary duties. Dr. Klein holds an interest in the assets, monies, and/or properties at issue as described above. Dr. Klein is informed and believes, and thereon alleges that Defendants have appropriated these assets,

monies, and/or property, which in tum has deprived

Klein v. Khilji et al. -­​  39

him of his interest in the properties and assets described herein. Defendants have received benefits as a result of their usurpation of corporate funds and personal assets the expense of Dr. Klein and his businesses, and under circumstances that make it unjust for them to retain such benefits. By virtue of the unfair advantage Defendants have obtained because of their misappropriation and concealment of funds due and payable to Dr. Klein, Defendants should be required to make restitution of their Ill-­gotten gains.

89. In addition to the properties, funds and assets enumerated and discussed above, the exact additional property and assets to which Dr. Klein is entitled is capable of exact determination after an accounting and through resolution of this action. Accordingly, Defendants are holding these properties and assets in constructive trust for Dr. Klein and are required to return those properties and assets to him.

SIXTH CLAIM FOR RELIEF

(Avoidance and Recovery of Fraudulent Transfers (11 U.S.C. § 544, California Civil Code Section 3439 et seq.) Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-­50)

Klein v. Khilji et al. -­​  40

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. Khilji and Pfeiffer transferred Dr. Klein’s funds and assets to themselves, the Khilji/Pfeiffer Entities and/or third parties.
2. Dr. Klein is informed and believes, and thereon alleges that Khilji and Pfeiffer made the transfers with actual intent to hinder, delay or defraud Dr. Klein’s creditors. Khilji, Pfeiffer and the Khilji-­Pfeiffer entities took the transfers with actual or constructive knowledge that the transfers were made with funds from Dr. Klein and that the funds were obtained by defrauding Dr. Klein.
3. Based on the foregoing, Dr. Klein is entitled to set aside the fraudulent transfers pursuant to 11 U.S.C. § 544 and California Civil Code § 3294, et seq., and, if applicable, recover the equivalent value of the transfer from Defendants pursuant to 11 U.S.C. § 550.

SEVENTH CLAIM FOR RELIEF

(Avoidance of Fraudulent Transfer and Obligation (11 U.S.C. § 548) -­ Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-­50)

Klein v. Khilji et al. -­​  41

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. Dr. Klein received less than reasonably equivalent value

in exchange for the funds and assets Khilji and Pfeiffer transferred to themselves, the Khilji/Pfeiffer Entities and/or third parties. Dr. Klein is informed and believes, and thereon alleges that (i) by virtue of the

above-­described transfers, Dr. Klein was insolvent or became insolvent as a result of the transfers;;;; or (ii) by virtue of, and at the time of, the transfers, Dr. Klein was engaged in or was about to engage in business or a transaction for which his remaining assets were unreasonably small in relation to the

business or transaction. Based on the foregoing, the transfers constitute fraudulent transfers and may be avoided pursuant to 11 U.S.C. § 548.

EIGHTH CLAIM FOR RELIEF

(Money Had and Received -­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-­50)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs

were set forth in full herein. As discussed above, Khilji and Pfeiffer were placed in a position of

Klein v. Khilji et al. -­​  42

trust by Dr. Klein, and they were able to and did access and possess money that was properly for the use of Dr. Klein and his businesses. As explained herein, Defendants also withdrew equity from the Windsor Property and used Dr. Klein’s funds and credit in violation of their duties and without authorization and not for the benefit of Dr. Klein or his businesses.

1. As a result of Defendants’ wrongful and unauthorized expenditures and withdrawals of both credit and funds, they are indebted to Dr. Klein in an amount to be proven at trial, but in any event an amount not less than

$10,000,000.00.

NINTH CLAIM FOR RELIEF

(Unjust Enrichment -­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­ Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-­50)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. The conduct of Defendants as predicated on the acts

above has secured and will secure them assets, profits and value that inequitably unjustly enrich them to the detriment of Dr. Klein and that they

would not have but for Dr. Klein’s assets

Klein v. Khilji et al. -­​  43

and financial resources. Dr. Klein hereby requests the disgorgement of all assets, profits, and value unjustly earned or retained by Defendants.

TENTH CLAIM FOR RELIEF

(Negligence -­Against Defendants Muhammad Khilji, Jason Roger Pfeiffer, Khilji-­ Pfeiffer, LLC, Khilji & Klein, LLP and DOES 1-­50)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. As both accountants, bookkeepers and business managers, Defendants owed Dr. Klein a duty to protect his interests and owed him a duty of care. Defendants breached these duties by engaging in the fraudulent transactions, forgeries, embezzlement and other misconduct described herein.
2. As a result of these breaches, Dr. Klein has been, and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but for Defendants’ wrongful acts. The substantial injuries suffered by Dr. Klein were foreseeable at the Defendants failed to comply with their duties of integrity and disclosure and their

obligation to refrain from fraudulent conduct to Dr. Klein’s prejudice. Defendants also breached their duty of

Klein v. Khilji et al. -­​  44

care owed to Dr. Klein by engaging in improper activities that resulted in excessive billings to Dr. Klein for services either never rendered or rendered below the professional standards of care. As a direct and proximate result of Defendants’ failures of care, Dr. Klein was forced to pay and did in fact pay excessive amounts for Defendants’ services to his detriment.

1. As a direct and proximate result of Defendants’ negligence, Dr. Klein has suffered damages including in an amount to be proven at trial, but believed to be in excess of $10,000,000 (ten million dollars).

ELEVENTH CLAIM FOR RELIEF

(Negligence -­Against Defendant Z & P Investment Services, LLC and DOES 1-­50)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. Z & P Investment Services, by and through its representatives Jeffrey

1. Zone and Claudia L. Peltier, held itself out as an expert in providing investment and financial management services to individuals like Dr. Klein. In labeling themselves as financial advisors and investment managers,

Defendants encouraged

Klein v. Khilji et al. -­​  45

Dr. Klein to rely on Defendants’ special skill and expertise in supervising and managing Dr. Klein’s investment and retirement accounts. .

1. In particular, Z & P Investment Services was entrusted with the management of Dr. Klein’s ample investment and retirement accounts at TD Ameritrade. Defendants breached these duties by failing to prevent Khilji and/or Pfeiffer’ s fraudulent transactions, forgeries, embezzlement and other misconduct described herein, which ultimately caused Dr. Klein’s accounts at TD Ameritrade to be depleted in excess of $2 million. In permitting and/or failing to prevent this misconduct, Z & P Investment Services failed to adhere to its ordinary standards of care, including but not limited to requiring written authorization for significant transactions involving investment or retirement accounts managed by Z & P Investment Services.
2. As a result of these breaches, Dr. Klein has been, and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but for Defendants’ neglect of duties and failures to act. The substantial injuries suffered by Dr. Klein were foreseeable at the time Z & P

Klein v. Khilji et al. -­​  46

Investment Services failed to comply with its internal safeguards and/or fraud prevention policies, failed to alert Dr. Klein to and take reasonable steps to prevent potentially fraudulent activity, and failed to exercise due care in accordance with standards governing the asset management industry.

1. As a direct and proximate result of Defendants’ negligence, Dr. Klein has suffered damages including in an amount to be proven at trial, but believed to be in excess of $2,000,000 (two million dollars).

TWELFTH CLAIM FOR RELIEF

(Negligence -­ Against Defendants Bank of California, Excel National Bank, City Bank and DOES 1-­50)

1. Plaintiff repeats and realleges each and every foregoing and subsequent allegation contained in the Complaint, as though said paragraphs were set forth in full herein. Defendants are financial institutions that owe duties of care to their depositors, account holders and investors. Defendants are subject to numerous laws, policies and regulations that are intended to prevent identify theft, financial fraud, embezzlement and other wrongful conversion of monies and assets. Defendants are obligated to manage accounts, verify account activity and issue appropriate safeguards in

response to potentially fraudulent activity (including

Klein v. Khilji et al. -­​  47

filing required reports of such activity), and owe such duties to all depositors, account holders and investors.

1. Defendants permitted accounts to be opened in the name of Dr. Klein and his businesses without taking reasonable steps to ensure that Dr. Klein authorized such Account activity. By failing to take reasonable efforts to confirm the propriety of these accounts, or to otherwise fulfill their obligations of due care, Defendants provided Khilji and Pfeiffer with the mechanisms by which to perpetuate their fraud. Defendants allowed and/or failed to prevent Khilji and Pfeiffer from withdrawing, fraudulently transferring and conveying, and otherwise wrongfully removing Dr. Klein’s assets that were held with Defendants. Defendants also performed inappropriate favors for Khilji and Pfeiffer, and used atypical banking procedures to service the accounts, at the expense of Dr. Klein. Defendants knew that Khilji and Pfeiffer were engaged in unlawful activities. Without Defendants’ assistance, Khilji and Pfeiffer would have not succeeded in their false scheme.
2. Defendants breached these duties by failing to prevent Khilji and/or

Pfeiffer’s fraudulent transactions, forgeries, embezzlement and other misconduct described

Klein v. Khilji et al. -­​  48

herein, which ultimately caused Dr. Klein’s accounts to be depleted in an amount believed to be in excess of $10 million. In permitting and/or failing to prevent this misconduct, Defendants failed to adhere to ordinary standards of care, including, but not limited to proper verification of the authenticity of Dr. Klein’s signature on signature cards, transaction authorization forms and other key banking documents.

1. As a result of these breaches, Dr. Klein has been, and will be, forced to suffer substantial financial losses and other harms described herein, each of which would not have happened but for Defendants’ neglect of duties and failures to act. The substantial injuries suffered by Dr. Klein were foreseeable at the time Defendants failed to comply with external and internal safeguards and/or fraud prevention policies and general standards of care governing banks and investment institutions.
2. As a direct and proximate result of Defendants’ negligence, Dr. Klein has suffered damages including in an amount to be proven at trial, but believed to be in excess of $10,000,000 (ten million dollars).

PRAYER FOR RELIEF:

Klein v. Khilji et al. -­​  49

NOW THEREFORE, Plaintiff respectfully prays for judgment against Defendants and each of them, as follows: For compensatory and consequential damages in an amount to be proven at trial:

1. For punitive and/or exemplary damages in an amount sufficient to punish, deter, and make an example of Defendants;;;;
2. For declaratory and/or injunctive relief;;;;

1. For a determination that the fraudulent transfers described herein are fraudulent transfers within the meaning of 11 U.S.C. § 544 and California Civil Code § 3439, et seq.;;;;
2. For a determination that the fraudulent obligations described herein as fraudulent obligations within the meaning of 11 U.S.C.

• 548;;;;

1. For turnover of the fraudulent transfers and obligations pursuant to 11 4

U.S.C. § 542

6. For an order compelling Defendants to provide an accounting;;;;

Klein v. Khilji et al. -­​  50

1. For punitive and/or exemplary damages in an amount sufficient to punish, deter and make Plaintiff whole in an amount to be determined at trial;;;;
2. For attorney’s fees, costs and expenses incurred herein to the extent recoverable under law;;;; and
3. For such other and further relief as the Court may deem just and Proper.

DATED: The th day of June, 2015 Arnold W. Klein, _

9615 Brighton Way, M-­110 Beverly Hills, CA 90210

Klein v. Khilji et al. -­​  51

Orange County Money Laundering Capitol

The Fresno office of the IRS which deals with Criminal money laundering suggested  Dr Klein    contact the Office of the District Attorney of Orange  County Directly. Dr Arnold Klein is 70 yo physician  who  has been a   victim of money laundering at 3 financial institutions   . This  was a well organized scheme conceived  by  Muhammad Khilji  a  foreign   national  of Orange County and    executed with the assistance of Bradley Sharp(Banc of California) and  Ron Freed( City National Bank.) Dr. Klein has reported the Criminal  Financial Elder Abuse in the form  of money laundering to  the Beverly Hills Police, Laguna Beach  Police ,Again Laguna Beach Police,   John Minn of Orange County District Attorney’s Office,   Barbara Kruger, Los Angeles Elder Abuse,    Eric Press, Health and Human Services, San Francisco,  Maria Aguilar,Orange County Elder Abuse, Detective Billingsley and   Police Chief Snowden Beverly Hills.  De. Kle

in has spent over a million dollars on attorneys to no avail.   Recently, Dr.Klein reported his entire case to Summer Bakotich.   Economic Crimes Investigator Orange County District Attorney’s Office    Bureau of Investigation  Real Estate Fraud Unit  who totally failed  to understand the   significance and and threat that exists to every Elder in  Orange County in light of Dr. Klein’s  experience. Dr Klein  has been illegally    evicted  from his Laguna Beach  home at 31025 Pacific Coast Highway based   on  the basis of  fraudulent credit line, not even a mortgage made by  Muhammad Khilji, a Muslim loyalist together with Todd Gallinger,  the membership Chairman of Cair- Hamas.

  Dr. Arnold Klein  is a  70 year old  disabled Professor of Medicine and  Dermatology at UCLA. He is one of a handful of Doctors who has

  revolutionized modern medicine. If you have heard the words Aids, Botox,  Genetic Mapping  Collagen you know the work of’

   Dr. Klein,.  Dr. Klein works 2  days per week and considers Orange County    his home, yet  not one agency reacted as required in  that it

     is    mandated  to report financial elder Abuse in California and Florida.

      Todd Gallinger   is unknown to Dr. Arnold Klein .  He is an attorney and the Members Chairman of   CAIR, Congress of   

       American Islamic Relations which is an  unindicted co-conspirator in The  largest terrorist financing     trial in US history,

       The Holy Land Trial. He is  located at 20 Truman #109, Irvine, CA 92620 and Washington, DC. Mr. Gallinger has never met

        Dr. Arnold Klein yet on March 20th,2009 Mr.  Gallinger altered Dr. Klein’s Will and Trust while Dr. Klein was

       overmedicated on Coumadin in an act of attempted homicide by Muhammad  Khilji and Jason Pfeiffer ( also of Orange County)

        at the Doctor’s home in  Laguna Beach, California.  The interoffice memo between Khilji and  Gallinger states the alteration must

        occur in Klein’s Will” in case something  happens to Dr. Klein, ”.Klein is disabled and depends on other for medication.

           From the records of Detective Scott Ross it appears the Coumadin  overdose was intended to kill Dr, Klein . Secretary of State

         John Kerry  had  referred Dr. Klein to attorney Jaffrey Krinsk of San Diego  who was of no help.

         Illegal attempted Sale of Dr. Klein’s Laguna Home by Muhammad Khilji

          Jason    Pfeiffer,Loren Thall, Todd Gallinger, Bradley Sharp with realtor Inge Bunn

Jason Pfeiffer Dr, Klein’s ex-office manager contacted Inge Bunn to sell Dr. Klein’s Laguna home behind his

Back with realtor Inge Bunn. Khilji and Pfeiffer had overmedicated Dr. Klein so he would not visit the property.

0n March 25. Inge  requested  approval to move forward with having the home professionally  photographed, and Khilji indicated  She should proceed (even though  Inge  did not have a signed listing agreement). Photos were taken in

early April; Inge even hired a helicopter for aerial shots.One day Jason phoned Inge and requested that there be no marketing

brochures at the property, as Dr. Klein would be spending the  weekend there and was having company. Inge  was never permitted to

have any signage on the property. In Early June, Khilji called and  informed Inge that Dr. Klein had purchased property in Palm Springs ( which was true ) and that Loren Thall had to now be involved in the sale . Thall wanted 0.5 % interest on the sale, Inge said she  never heard of such a thing but never called Dr. Klein, Inge  was  surprised  at caliber of professionals were serving Dr. Klein — as

Dr.Klein had been a client of  Inge’s for 23 years and always had a  very professional team. Inge  checked​ ​Thall’s license status but noted  no discrepancies Khilji requested information on the property’s value  and comps. Thall contacted me and indicated the prop​erty needed  to be in multiple listing services.June 4 inge  received an  email message indicating, “we have​ ​a consensus on listing

price of$11,900,000.” Listing Agreement dated June 5 was  signed June 8. ( not by Dr. Klein).

            /inge ​ proceeded to actively market the property — She     spent considerable time and funds on this project.Dr. Klein

            then phoned  Inge and indicated he did not want to sell the home. The same day,  she notified the staff  servicing the home

              to have the locks and code to the  security system changed.​ Allen V.C. Davis Trustee for David  Trust   made an ilegall exit

loan on Klein’s property the above individuals kept. The fraudulent exit loan was  ​1,500,000,Title Fees and Escrow Charges all to the

           Benefit of Khilji, Pfeiffer, Thall,  Robert Lorsch, Bradley Sharp . The loan was deposited into a fraudulent account at

         Private   Bank/Banc of California opened by Khilji,Gallinger,Pfeiffer, Lorsch with the help of Bank insider Bradley Sharp.

          Khilji and the group would open 10 accounts in Dr. Klein’s name at Private/ Bank in Dr. Klein’s name. There were

           two secret Accounts invisible to Dr. Klein  Khilji-Pfeiffer LLP  which represented Khilji, Pfeiffer. Lorsch and Lorsch’s

          Company mymedicalrecords. com. Gallinger could have easily sent funds to through these secret accounts to Hamas.

          Accounts like this are unheard of post 9/11. In regard to the exit loan -$112,500  was paid to Hemar, Rousso & Herald, LLP for

          the    fraudulent  Bank of America loan,$5,000 paid to Goins Underkofler  Crawford wired out of state to texas and ​53,000 was wired to

         First Commerce Bank  regarding the  theft  of 2 cars of Arnold  William Klein MD a Medical Corp by

         Khilji and  Pfeiffer valued at over $150,000. Bra dley Sharp is an insider at Private Bank/ Banc of California  which is

         owned by the Lawyers and Judges of the LA Venue of Federal  Bankruptcy Court.  Khilji then together with Sharp overmedicated Dr.

        Klein with a potentially fatal antipsychotic called Moban and once Mentally incompetent placed   Klein  in the LA Venue of

      Federal Bankruptcy court  with an attorney David Neale who was set-up to  guarantee Klein a swift trial against the embezzlers

     including     Banc of Cal  CEO R. Todd Neilson. Dr. Klein has not had a case heard in 4 years and in violation of Congressional law

    Sharp  became Klein’s trustee and is both  an insider at Private Bank , in conspiracy  with City National Bank Flower

   St  and the embezzlers. Klein’s Judge became Richard Neiter who has  stock in Private Bank .Sharp  has allowed Khilji and his group   Gallinger,  Thall, Pfeiffer to keep $40 million Dollars of Dr. Klein’s financial  assets they have laundered   and

has sold Klein’s  homes with fraudulent loans and mortgages  made by Khilji and deposited into fraudulent bank accounts Khilji

opened.   They have sold everything  Klein owns  including  his Laguna  Home, windsor home and art worth $80 million and left Klein penniless.…Bankruptcy Court must adhere to the California Homeowners Bill  of rights and they will never get clear title on Klein’s properties

Dr. Arnold Klein a 70 yr. disabled elder who is the Tesla of Medicine. There is not one part of Modern Medicine he has not improved through Dr Klein’s

practice and research , the above individuals have  robbed Dr Klein through an  organized conspiracy involving Identity theft,

Bank fraud, and money  laundering. He has saved a generation of women and men but the above

individuals took advantage of his disability to over medicate him so while confused they robbed him.

But how can a disabled Elder be evicted on the basis of a mortgage he never made that contains a trust

that is not his. I take care of many disabled individuals so this question must be answered.  Mr. Sharp and Khilji overmedicated Dr. Klein with a toxic dose of  the Atypical Antipsychotic Moban combined with

elevating his Zanaflex. This would make Dr Klein or anyone incapable of rational thought and  mentally incompetent and easily convinced to enter Bankruptcy Court  though he was not bankrupt and had not one debt. If in a lucid or sensible

Mental  state Dr. Klein would never have taken this action. Les Weiner, MD  former  Chief of Neurology

Leslie Weiner Neurology Clinic and Research Institute¨ Keck School of  Medicine at USC

Arnold William Klein MD has had one of the most important and  humanitarian careers in the annals of medicine He is a Professor of Medicine and Dermatology at UCLA¨  a retired Professor Dermatology at Stanford The inaugural Visiting Professor

of  Cosmetic Dermatology at Harvard and a  Dean of the Royal Society of Medicine He is THE doctor who pioneered the  fi

entire field of cosmetic dermatology. He developed the use of Botox and  fillers and is a highly respected academician worldwide

having published five books and 200 academic papers. He has maintained a  dermatology practice for more than 39 years In addition to his private  practice Dr Klein has raised in excess of $300 million for  HIV research and opened Aids Clinics in South Africa. He raised significant

funds for breast cancer and after the FDA approval of  the drug¨ Herceptin  for use in breast cancer he was the first to employ it. He was also part of the  group that discovered the first human gene. Though disabled and requiring a  caregiver for medication it has n.

ot prevented Dr Klein from enjoying a superb reputation among his peers and patients worldwide In 2008 L’uomo Vogue named

Dr Arnold Klein one of  the 10 best  architects in the world along with Frank Gehry for his understanding of facial

architecture. They referred to him as a modern day Leonardo Da Vinci Klein was in a great financial position in 2008. His corporate income was $4 million  dollars/ year   and  everything of Dr¨Klein’s including his homes¨ art, cars ,memorabilia and Medical Practice was in his trust,

 1995 Arnod William Klein md  553 S. Windsor Blvd. Dr. Klein’s home on PCH was being rebuilt by Frank Gehry because of Klein’s disabillty which would have significantly raised the value furnished to over $20 millon. It was sold to a friend of Bradley Sharp for $ 7 millionon  based on a fraudulent corporate loan Khilji made through the illegal accounts he opened at City National Bank on Flower St. The Corporate loan lists Klein’s address as 553 S. Windsor Dr. #204. It has the wrong years in practice, Khilji could not spell doctor and it was made by bank insider Ron Freed who is in  contact with Sharp. The note is not signed by Klein.. Sharp has sold everything of Dr, Klein’s and in violation pf State and  Federal law and the Bankruptcy reform act of 2005 has given Klein’s retirement of $6.4 million  to the embezzlers who have laundered $40 million of Klein’s assets to the embezzlers. A mentally incompetent elder is protected from entering Bankruptcy Court  both by California Elder Abuse law(AB140 undue influence and the Bankruptcy Act 1004.1.

    Dr. Klein is in desperate need of funds for medication of his neuropathy which includes Rituxan-­‘($24,000 for each six month   treatment).

     He needs funds for a Baclofen pump to reduce his spasticity  ($ 50,000) as well as funds to repair of damage from the heart attacks

    caused when his Trustee withheld his SSI twice ($90.000), Dr. Klein also  requires funds for a caregiver ($50,000) as well as a vehicle

     outfitted for a  disabled individual ($75,000).  Dr. Klein must prevent foreclosure on his Palm Springs home. Being without

   SSI for 54 days due to the Trustee   Dr. Klein was  unable to buy his medication which  compromised his health. Dr. Klein’s retirement

    funds   are rightfully his and by compassionate  plea may this be dealt with first to provide Dr. Klein with needed

     legal counsel, medical management, and a mode of transportation. Dr. Klein’s retirement funds of $6.4 million are rightfully his

    by State    and Federal law  and the Bankruptcy Reform Act of 2005. Bradley Sharp( an insider at ‘

     Private  Bank-­ see Narva-­Namco case) has illegally attempted to withhold these

     funds from Dr. Klein  and give them to embezzlers  who  have laundered Klein’s retirement through fraudulent corporate accounts at

    City    National  Bank,Private Bank and Excel.(Sharp has no control over Corporate  Accounts,(see Second Amended Complaint) He also

     is   attempting to give  Klein’s Corporate income from 2009-­2010 of $4-­5 million Laundered through

    the fraudulent Excel Account to the embezzlers. There must be an attorney in the district attorney’s office who can hear this Criminal Case.

                                                      Thank you, Arnold Klein

                                                       1401 via Monte Vista,  Palm Springs, Ca. 92262

The truth about Jackson’s death, the 2003 Will

H)Dr. Arnold Klein and Michael Jackson

the year After His Death Michael Jackson’s Catalogue made 1 Billion Dollar

1. 
2.          On the day Michael Jackson’s Will was signed in Los Angeles
3. Michael was in NYC with Al Sharpton 7/7/02
4. Michael Jackson’s lst Son’s name is Michael Joseph Jackson Jr.
5. Michael requested all documents be returned from John Branca in 2003 this will is a fraud.
6. In 2003 Michael made 2 wills — a copy of the second of which was in Dr. Klein’s Windsor House.
7. Dr. Klein had a covenant with Michael never to release his recordsafter the first molestation event
8. Michael lived in Dr. Klein’s Windsor house intermittently for 30 years.
9. Michael’s Son is Michael Joseph Jackson Jr. but the Will they used to settle the estate said his name was  Prince Michael Jackson Jr.
10. John Branca  the questionable trustee  of the Jacken estate has 2 seats  on the Board of Private Bank of California.
11. Robert Lorsch who is friendly with Branca   arrived in Dr. Klein’s Office the Day Michael  Died.
12. To open 10 bank accounts  under Dr. Klein’s name at Private Bank of California(Banc of California) under Dr. Klein’s name.
13. The records for these accounts were never  sent to Klein Office
14. In 2003 Michael requested all documents be returned from John B/ranca
15. This will above is a fraud and  not Michael’s 2002 will
16. In 2003 Michael made 2 wills — a copy of the second of which was in Dr. Klein’s Windsor House.
17. Michael lived in Dr. Klein’s Windsor house intermittently for 30 years
18. The only person Michael trusted was not a family memberor musician but Arnold Klein -Joel Kassimir MD New York
19. The Death of Michael Jackson was not accidental
20. Had one person had the sense to understand Propofol addiction, look at the records of Hoefflin’s use of Propofol on Jackson or understand the records from Klein’s office were of three doctors not one the cause was obvious.
21. Again, Dr Klein was in Europe all of May 2009., Murray started work on  May 1st.,2009.
22. When Dr. Klein returned from Europe Michael acted like a Zombie He said it was due to heavy use of antihistamines,
23. In retrospect It had to do with the manner in which Murray used Ativan combined with Propofol which should never be  combined.
24. Doctor Klein rebuilt Michael Jackson’s    face    from  endless surgeries performed by Steven Hoefflin for the film “This Is It.” For AEG.
25. The AEG agreement was at Dr. Klein’s Windsor House.
26. Klein  worked over 250 hours  on Jackson’s face but 150 from May 1st until his death.
27. Klein used  31 shots of Demerol not 51 from May 1st until Michael’s Death..
28. However Dr. Klein’s work on Jackson’s face preceeded that by months beginning when Jackson first arrived from Las Vegas,t the Time Khiljji opened the first fraudulent accounts at City National Bank on Flower Street.
29. Dr. Klein will take action against AEG for the loss of his homes and financial assets and their active participation  in the conspiracy with Khilji, Peiffer, and Harvey Levin in the destruction of Dr. Klein reputation, income ,Health, .loss of his homes  and  assets (  cc.3345 A Randy Phillips, Harvey Levin,City National Bank. Bank of California,Rob Freed,Bradley Sharp )
30. As  stated above In March of 2009 in an act of attempted homicide  Khiji, together with  Pfeiffer  attempted to overdose Klein  with Coumadin.
31. The attorney they used to  Change Dr, Klein will was  Todd  Gallinger Todd Gallinger is the membership Chairman of  the Muslin Brotherhood- Cair Hamas,
32. Cair has been found to be in a huge money Laundering Scandle in DC.
33. Hamas is also involved in a money Laundering  with the Mexcan drug Cartels and all the drug  gangs of South America. thrPhillips,Private Bank of California,City National Bank, Richard Charnley, Jason Pfeiffer,
34.   Muhammad Khilji would proceeded to open  22 bank accounts in  Dr ough out S. America.
35. Dr. Klein was referred to Jeffrey Krinsk of San diego by Secretary  state  John Kerry regarding  this Cartel and money  laundering.
36. Krinsk met with Bradley Sharp, with Attorney Mark Putnam of AEG. and filed the case against MIA, Krinsk was  close  to  Kamala Harris
37. Krinsk though aware of the money laundering refused to report it to the IRS criminal division. Dr. Klein will take action against Krinsk because his lack of action cost the oss of  of Klein his
38. Returning to the treatment of Jackson Klein reduced his dose 100 mg /week in the last 2 weeks he saw Michael. Dr. Klein was in Europe all of May 2009
39. These doses are in no way addicting or dangerous.
40. Dr Klein worked with an addiction specialist and Michael’s internist while treating him. Michael Jackson’s death had nothing to with Michael or Dr. Klein.
41. Besides being a Dermatologist Arnold Klein is a recognized authority on Drug Abuse. He published “Drug Trip Abroad : American Addicts in Amsterdam and London which dealt with direct use of heroin maintenance of heroin addicts as a successful form of therapy. Dr Klein was also a member of the. National Research Council expert Coucil of Drug Dependence
42. Michael Jackson’s death was caused by a group of people or an investment consortium who were more interested in Michael’s Immense Music Catalogue   than his survival.
43. Kim Wilson of the Med Board of California attempted to blame The death of   Michael Jackson on Demerol while the Coroner found only Propofol and Ativan.
44. Dr. David Rish who helped to overdose  Klein  wth Coumadin said to Kimberly Dr, Klein had asked fo r Coumadin to Kimberly Wilson .
45. Klein could have prescribed  Coumadn for  himself
46. Rish is admitting his own guilt i when they tried to kill Klein with  the  Coumadin overdose, stole 2000 charts from Dr. Klein’s Office.
47. Dan Timko was very close to Rish and Rish was close to Khilji and Pfeiffer.
48. Dan Timko illegally laundered Millions from  the Illegal Excel opened in. Klein’s name,
49. Rish had a Private Deal with G and L to have them reduce the Office Space for him and not Klein in Violation of ADA
50. Rish illegally released Klein Medical records  and those of Michael Jackson in a distorted manner that greatly damaged Klein. As Klein’s treating Physician and in regard to covenant with Jackson this violates Klein’s ADA and HIPAA and Jackson’s HIPAA
51. Rish has caused Klein to undergo needless and useless Psychiatric exams because the lies contaned in the information he released.
52. Rish has stolen from Klein and has a known family member who is an addict to which he supplied drugs though he claimed  Dr. Klein will take action against Rish(cc3345$ 24 million decreased income caused by Rish) , AB140 undue influence.
53. David Rish  is the most probable source of the Moban(AB140 undue influence )
54. Maritza Shulman tried to sabotage the Medavoy trial by altering Irena’s records  which almost cost Dr,, Klein the case. In violation of HIPAA she stole the names and addresses of Dr. Klein’s patient’s.
55. Harry Glassman knowingly supplied drugs to one of his ex-wifes was an addict, was in collusin with Hoefflin and illegally released Klein’s records in Violation of HIPAA.
56. Glassman was  also a treating physician of Klein.
57. Jackson’d death was clearly due to totally improperly administration of the general anesthetic Propofol.
58. The attorney who represented Dr, Klein at the Murray trial was Garo Ghazarian
59. Garo was paid by Muhammad Khilji extremely well with funds laundered through the illegal Excel Accounts
60. Ghazarian claimed to Dr, Klein he was never paid,
61. Ghazarian never mentioned Dr.. Klein was in Europe all of May 2009 during the Murray Trial
62. .Dr. Klein contacted US Robert Dugdale concerning   the money laundering and Ghazarian told Dugdale not to speak to Dr. Klein regarding money laundering.
63. Steven Hoefflin was the plastic Surgeon who first addictedMichael to Propofol.
64. Propofol is a general anesthetic with a narrow margin between life and death.
65. It soon became the only way Michael could sleep on tour
66. Propofol It is not a shot it is a general anesthetic emulsion
67. Propfol  should be administered only by persons trained in  the  administratio of general anesthesia.
68. Sedated patients must be continuously    monitored and facilities for maintenance of an open airway  providing artificial ventilation,
69.    administeration of supplemental oxygen,
70. and instituting cardiovascular resuscitation  must be immediately available.
71. Patients must be continuously monitored for early signs of low lblood pressure,
72. airway obstruction, and/or low oxygen .
73. You must have proper equiptment,know how to keep the patient’s airway open, and carefully monitor patients
74. Before Joan River’s recent death people never heard of it because the media rarely mentioned it in association with Jackson’s
75. With Michael it began with the excessive surgeries Hoefflin Beginning In the late 80’s. and continuing for 10 years.
76. It was first in the medical writings in 92
77. “Mr Jackson would be anesthetized with Propofol and the clocks in the operating room would be turned ahead
78. Mr Jackson would then be revived, look around the room and settle back to sleep.
79. The clocks would then be reset to reflect the correct This gave Mr Jackson the perception that he had just undergone a nasal surgery of several hours, when in fact he was only unconscious for several minutes but on Propofol for several hours.
80. On endless occasions Dr Hoefflin had Mr Jackson’s wristwatch turned ahead and later returned to the correct time so that the scheme would be perfect.
81. Eventually Dr Hoefflin was deceiving the reclusive singer so regularly that other doctors tried to intervene, arguing that the constant anaesthetic was dangerous, .
82. Dr Hoefflin defended himself, saying if he didn’t pretend to work on the star he would go to another surgeon who was prepared to do the work
83. The dangers with Propofol  besides addiction is the manner in which it is delivered,.,
84. he available equipment and the education and experience of the individual delivering it.
85. In 2003 Michael wrote a cease and desist letter to Hoefflin after he did a VH1 special on MIichael’s Surgeries.
86. In 2003 Dr. Klein had an addiction specialist and anesthesiologist withdraw Michael for the second time from Propofol. The warning was,”if he ever fell off the wagon call or only with an anesthesiologist.
87. In 2003 Michael Jackson issued a detailed letter to John Branca firing him and requesting all documents including his will be returned to him. Jackson had questioned for many years the behavior of Sony   Music Entertainment and whether Branca had a private deal with Son
88. Jackson discovered that the attorney who represented him in this  deal Branca, also represented Sony
89. Sony had failed to promote Michael ‘s album “Invincible” and were essentially stealing his Catalogue from him.“ Michael wanted nothing to do with    Branca or Sony
90. ever again even a week before he died
91. He called Branca and Sony the Devil
92. Michael had essentially lost all his assets.
93. his immense priceless MusicCatalogue valued at $2 billion to Sony and Branca.
94. In 2006 Michael Jackson went to Vegas from Ireland to work for Jack Wishna
95.  Jackson was broke.
96. When his family showed up with theie immense demands Michael became     so  debilitated.
97. Jackson could not do 2 shows a month.
98. Jermaine then introduced Jackson to a con man Tome Tome .
99. Tome Tome knew a realtor Tom Barrack.
100. Barrack knew Phillip Anschutz the head of AEG
101.  Anschutz is a very rich notorius conservative from Colorado
102. Anshutz  together with Branca bought out the Prince of Bahraine’s interest in the immense Music Catalogue of Jackson’s.
103. Barrack also happened to be foreclosing on Conrad Murray’s house in the Red Rock Canyon Section of Vegas and Murray was up to his neck in debt & desperately needed a job, and agreed to care for  Jackson at night Starting May 1st 2009.
104. Starting May 1st 2009meaning deliver Propofol. .
105. Murray was hired to care for Jackson When the filming of“this is it  was completed “ and there was no longer a need for Michael Jacks
106. Murray was not licensed in England because England was never in their plan.
107. Before Jackson died he  told Klein to take care of Jackson’s Chidren,
108. don’t  let Sony or Branca get his music.
109. As it is stated in the     2003   Will “ Michael Joseph Jackson Jr. Paris-Michael Katherine Jackson and Prince Michael Jackson II  were to receive all rights to his music and   Neverland restored for their enjoyment. .
110. He removed David LaGrand and named Al Whitman head of his foundation.
111. He also held specific instructions. For certain key people key people he trusted run his empire he worked so hard to build which included neither Branca nor Weitzman.
112. Additionally he left specific amounts to approximately 10 people         3 or 4 of which Dr. Klein can recall.
113. During Dr. Klein’s interview with Reitman, the attorney for Sharp he told Reitman he had to get to the storage boxes at Windsor.
114. Bradley Sharp  has illegally seized all the art,furnishings, papers from Dr. Klein’s residence in Windsor Stored at Oakwood without a warrant or a list
115. as Stated in “The second amended Complaint “ the mortgages on Klein’s  Windsor and Laguna are fraudulent  but they fail to say they do not contain Klein’s  trust
116. clear title can never be achived,
117. Dr. Klein did not enter bankruptcy court of his own volition but was drugged to enter with potent  Atyical Anti Psychotic Mobam(AB under influence).
118. Dr. Klein wishes return of all items but doubts he will get the Jackson Documents returned.
119. Returning to Murray
120. he was hired to give Jackson Propofol  Murraywas totally ignorant on the use of Propofol
121. AEG made sure he was ill equipped.
122. The dangerous effects of Propofol are more likely to occur following rapid large shots as used by Conrad Murray.
123. Propofol administration depends on a skilled Physician as described above and requires proper equipment.
124. “Murray and the people who hired him are responsible for Michael’s death.
125. Murray did not know how to deliver Propofol and was ill equipped and dangerously combined it with Ativan.
126. On the day of his death when Murray entered Jackson’s room in the afternoon and found Jackson in bed and not breathing.
127. Jackson had a weak pulse, his body was still warm and with proper equipment he could have been saved.
128. Murray tried to revive Jackson for five to ten minutes, at which point he realized he needed to call for help.
129. Murray stated that he was hindered because there was no landline in the house.
130. Murray also stated that he could not use his cell phone to call 911because he did not know the    exact   address which everyone in the world knew
131. Murray stated that he also phoned security, but did not get an answer.
132. Kim  Wilson  attempted  to  blame  the  death  of    Michael  Jackson  on  Demerol  while  it  was clearly due to  totally improperly administration of the  general anesthetic  Propofol.
133. Michael dies and what does the Coroner find, acute propofol and benzodiazepine intoxication after suffering cardiac arrest -‐-‐-‐there is no Demerol.
134. An anesthesiologist is easy to find at $ 150,000.00/ month
135. These people wanted an incompetent physician and Michael’s Catalogue.
136. During the AEG trial it was  revealed that AEG employed Conrad Murray and Jackson did not sign the contract for the above-cited employment. [
137. Michael thought Conrad Murray was incompetent, Murray was not an anesthesiologist and was totally incapable of administering Propofol properly.
138. Michael Jackson and Doctor Klein had a HIPAA covenant never to release his records since the first molestation event.
139. What follows are all HIPAA violations,
140. One group wanted to blame Dr. Klein because he knew their desire was the Catalogue and the will was a fraud.Others want to blame Dr. Klein to conceal their money laundering.
141. Harvey Levin knew Branca and Howard Weitzman was  aware of the fraudulent accounts set -up  in Dr. Klein’s name at Banc of California.
142. Levin was aware of immense news conference AEG held in front of Klein’s office. Harvey  Levin was  constantly in contact with  Bradley Sharp and kept mentioning Michael’s death was due to Klein’s 51 shots,  the illegal sale of Klein’s Laguna house  with a fraudulent trust was due to to 51 shots, the illegal search and Seizure was due to Klein’s 51, the illegal sale  of Klein’s  Windsor Home was due to  51 shots of Demerol. He even mentioned the 51 shots of Demerol in regard to the illegal openiing of Klein’s  new office when Klein only used 31 shots and he Levin was in contact with Charnley, Khiji. and Pfeiffer
143. Levin will always lie to makr Harvey Levin money
144. He did in 94 about Marcia Clark arriving at OJ’s with out a warrant.Jason
145. Pfeiffer illegaly  released Dr. Klein’s records on Michael Jackson to Randy Phillips of AEG and Bradley Sharp .
146. Pfeiffer erects a website to contact the Medical Board over Dr. Klein.
147. Pfeiffer, tried to kill Dr. Klein  twice, when he illegally changed Dr. Klein’s Will and Trust and when he used Moban to get Klein into Bankruptcy Court.
148. Pfeiffer is  part of the conspiracy that opened 22 fraudulent bank accounts in Dr. Klein’s name to launder his funds.
149. 10 of the money laundering accounts were at John Branca’s Banc of California
150. Pfeiffer reported  Dr. Klein to the Medical Board.
151. This .would conceal Pfeiffer’s actions and create a chaos to prevent Klein’s survival
152. DrKlein was a disabled elder easy for Khiji, Pfeiffer to drug
153. Richard Charnley then illegally released records on Michael Jackson to Harvey Levin, Randy Phillips of AEG, and Bradley Sharp of Banc of Californi
154. Richard Charnley participated in the illegal Medicis Settlement   together with Muhammad Khilji at the Office of Robert Lorsch the funds going to the fraudulent MIA inc acconnts at City National Bankl then laundered to  MIA Banc of California accounts  the theft from Klein was$ 5 million
155. (cc. 3345 City National Bank,Banc of California, Bradley Sharp, Robert Lorsch, Robert Freed,Muhammad Khilji,John Reitman, Peter Gurfein Loss from illegal Medicis Settlement $5 )
156. Charnley did not complete Whistleblower Settlement  from Botox to prevent Klein’s ability to Survive- loss to Klein. 35$million.
157. the embezzer and insiders wanted to kill Dr Klein or prevent finances for a legal recourse. Charmley failed to settle the Hoefflin case which was corporate and illegally settled by Reitman, With Charmley Klein would have one in excess of 2 million
158. cc3345 City National  Bank. Banc of California, Reitman, Gurfein and Sharp  $37 million.
159. The truth did not matter they have the media and Politician’s on their Anschutz is very close to Governor Brown and Branca is the largest supporter of of District Attorney’s Cooley’s run for Governor.
160. Governor Brown  seems to forget he appointed Dr Klein Commissiner  of Malpractice and Commissioner of Health of California
161. This was  when Mark Nathanson was  Coastal Commissioner.
162. Nathanson went to jail   for trying to Shake down Klein’s patient’s Barry Diller and Sandy Gallin for wanting to build things on the Beach, but Nathanson gave Brown Money . Klein knew Jody Evans and Frank Gehry who were close to Brown but Klein did not give Brown money,
163. The lies will no longer work.
164. Michael did not hire Conrad Murray
165. the ridiculous trial where Dr. Klein could not speak is long gone.
166. Michael was dependent on Propofol but had successfully withdrawn.
167. The thieves use his death to screen the truth
168. Michael Jackson would be alive today if the used a competent
169. The blame sits on the people who thought Michael Jackson’s catalogue was more important than his life.Recently Bradley Sharp reported Klein to the Nevada medical Board
170. on April2015 they want his finger prints.
171. Klein will take action against ,Muhammad Khilji, Bradley Sharp, Banc of Californiad its board of directors,Peter Gurfein Todd Gallinger,
172. Robert Lorsch, John Reitman, Ron Freed , Harvey Levin, City National Bank and its Board of Directors, Excel Bank, its Board of  Directors,  Randy Phillips, for  decreased income,destruction of his reputation, continuous, severe and potentially dangerous overmedication, HIPAA violations, illegal alteration of Will and Trust,mortgage fraud, financial elder abuse,physical elder abuse in including 4 attempted homicides violation of Homeowners Bill of Rights, loss of 40 million assets and 80 million in assets

Justice

To Whom It May Concern:

Arnold William Klein, MD has had one of the most important and humanitarian careers in them annals of medicine. He is a Professor of Medicine and Dermatology at UCLA, a retired Professor ofDermatology at Stanford,The inaugural Visiting Professor of Cosmetic Dermatology at Harvard and Dean of the Royal Society of Medicine. He is THE doctor who pioneered field entire field of dermatology. He developed the use of Botox and fillers and is a highly respected academician worldwide

having published five books and 200 academic papers. He has maintained a dermatology practice fomore than 39 years. In addition to his private practice, Dr. Klein has raised in excess of $300 million for HIV research and opened Aids Clinics in South Africa. He raised significant funds for breast cancer andafter the FDA approval of the drug, Herceptin for use in breast cancer, he was the first to employ it. He was also part of a group that discovered the first human gene. Though disabled and requiring a caregiver for medication, it has not prevented Dr. Klein from enjoying a superb reputation among his peers and patients worldwide Dr. Klein. In 2008 L’uomo Vouge named Dr. Arnold Klein one of the 10 best

architects in the world along with Frank Gehry for his understanding of facial architecture. They referred to him as a modern day Leonardo DaVinci. Klein was in a great financial position in 2008. His corporate

income was approximately $4 million per year.  He owed very little or next to nothing on his homes, of which there were three homes held by his Trust, “The 1995 Arnold William Klein MD Revocable Trust

which owned everything of Dr, Klein including his homes, art, cars, and memorabilia Klein has saved a generation of Men from Aids and Generation of women from Breast Cancer. Dr, Klein now wants to save every victimized disabled Elder from the torture he has endured.

To Whom it may concern:

.Muhammad Khilji is a foreign national involved with Todd Gallinger Membership Chairman of CAIR-Hamas- Muslim  Brotherhood  ( known terrorist  groups involved with the Mexican Drug Cartel and anti-semetic acts including the murder of Jews.) Khilji  opened 22 fraudulent Bank accounts in Dr. Klein’s name . He has  laundered in excess of   $40 millions from Arnold Klein and left  penniless. Khilji has laundered Dr, Klein’s retirement of $ 6.4 million through the 3 fraudulent Banks. A bank or financial institution is required to identify the nominal and beneficial owners of any Bank account opened and maintained in the U.S. by non-U.S. citizens but Banc of California, City National Bank Flower Street and Excel Bank failed to do so and have assisted Khilji and Gallinger in their fraudulent activities. Khilji and Gallinger attempted to kill Dr Klein by overdosing him with Coumadin and Change his will and trust   They then overmedicated Dr. Klein with a potent toxic  drug called Moban to get him into bankruptcy court.  Because Dr. Klein  is disabled this was easy to do. Bradley Sharp is an insider at Banc of California  and a trustee who was in conspiracy  with Khilji. The Lawyers and Judges of the LA venue of Federal Bankruptcy court  own the Banc of Califonia. Despite not one Debt in Dr. Klein’s name  or containing his trust they have    sold $80 million of Klein Assets.,Gallinger have received through Sharp illegally seized computers from Dr. Klein home   that contain privileged information on Presidents, Cabinet Members, Religious Leaders, Royals, Jewish Diplomats, Mid -East Royals and wealthy Jewish business  icons who  themselves, their wives or their children could become targets . They have attempted to kill Dr. Klein 4  times. Dr. Klein is taking action against Sharp and Khilji in Orange County Superior Court. He will act as his own lawyer but there must be  an attorney willing to Help or individuals who are able to bring publicity to Dr. Klein’s plight. While they have attempted to destroy Dr. Klein for  5 years he was much stronger than they expected.
Arnold William klein

Michael Jackson and Arnold Klein

Come to the real Michael Jackson trial where you can hear the truth!

Michael Jackson’s Catalogue brought in one billion Dollars the

the year after his Death.

• On the day Michael Jackson’s Will was signed in Los Angeles .
• Michael was in NYC with Al Sharpton 7/7/02.
• Michael requested all documents be returned from John B/ranca in
• In 2003 Michael made 2 wills — a copy of the second of which was in Klein’s Windsor House.
• Michael lived in Klein’s Windsor house intermittently for 30 years.
• Michael’s 1st son’s name is Michael Joseph Jackson Jr.

The only person Michael trusted was not a family member or musician but Arnold Klein MD

-Joel Kassimir MD New York

      The Death of Michael Jackson was not accidental.

Had one person had the sense to understand Propofol addiction, look at the records of Hoefflin’s use of Propofol on Jackson or understand the records from Klein’s office were of three doctors not one the cause was obvious.

• Doctor Klein rebuilt Michael Jackson’s face     from the      endless surgeries performed by Steven Hoefflin for the film “This Is  it”
• Klein worked over 150 hours using 31 shots of Demerol not 51. Dr. Klein also reduced the doses to 100 mg /week in the last 2 weeks he saw Michael.
• These doses are in no way addicting or
• Dr Klein also worked with an addiction specialist and Michael’s internist while treating Michael Jackson’s death had nothing to with him or Dr. Klein.
• Besides being a Dermatologist Arnold Klein is a recognized authority on Drug He published “Drug Trip Abroad : American Addicts in Amsterdam and London which dealt with direct use of heroin maintenance of heroin addicts a successful form of therapy

• He was also a member of the Expert Panel of Drug Dependence of the National Research Council .

8       Michael Jackson’s death was caused by a group of people who were more interested in Michael’s Immense Music Catalogue than his survival.

• Kim Wilson attempted to blame the death of   Michael Jackson on Demerol while it was clearly due to totally improperly administration of the general anesthetic
• Steven Hoefflin was the plastic Surgeon who    first addicted Michael to Propofol

What is Propofol?

• Propofol is a general anesthetic with a narrow margin between life and death which soon became the only way Michael could sleep on tour .

12    Propofol It is not a shot it is a general anesthetic emulsion which should be administered only by persons trained in the administration of general anesthesia.

• Sedated patients must be continuously monitored, and facilities for maintenance of a t open airway, providing artificial ventilation, administering supplemental oxygen,
• and instituting cardiovascular resuscitation must be immediately
• Patients must be continuously monitored for early signs of low blood pressure,
• airway obstruction, and/or low oxygen .
• You must have proper equiptment,know how to keep the patient’s airway open, and carefully monitor patients
• Before Joan River’s recent death people never heard of it because the media rarely mentioned it in association with Jackson’s
• With Michael it began with the excessive surgeries Hoefflin Beginning In the late 80’s. and continuing for 10 years
• “Mr Jackson would be anesthetized with Propofol and the clocks in the operating room would be turned ahead by Mr Jackson would then be revived, look around the room and settle back to sleep.
• The clocks would then be reset to reflect the correct This gave Mr Jackson the perception that he had just undergone a nasal surgery of several hours, when in fact he was only unconscious for several minutes.
• On endless occasions Dr Hoefflin had Mr Jackson’s wristwatch turned ahead and later returned to the correct time so that the scheme would be
• Eventually Dr Hoefflin was deceiving the reclusive singer so regularly that other doctors tried to intervene, arguing that the constant anesthesia was dangerous, .
• Dr Hoefflin defended himself, saying if he didn’t pretend to work on the star he would go to another surgeon who was prepared to do the work..
• The dangers with Propofol is the manner in which it is delivered, the available equipment and the education and experience of the individual delivering
• In 2003 Michael wrote a cease and desist letter to Hoefflin after he did a VH1 special on MIichael’s plastic surgery
• In 2003 Klein had an addiction specialist and anesthesiologist withdraw Michael for the second time from Propofol. The warning was,”if he ever fell off the wagon call or only with an anesthesiologist.

28    In2003 Michael Jackson issued a detailed letter to John Branca firing him and requesting all documents including his will be returned to him.

• Jackson had questioned for many years the behavior of Sony Music Entertainment and whether Branca had a private deal with Sony?
• Jackson discovered that the attorney who represented him in this deal ,Branca, also represented Sony
• Sony had failed to promote Michael ‘s album “Invincible” and were essentially stealing

his Catalogue from him.“ Michael wanted nothing to do with Branca ever again even a week before he died.

• Michael had essentially lost his immense priceless Music Catalogue valued at $2 billion to Sony and Branca.
• In 2006 Michael Jackson went to Vegas from Ireland because he was .broke
• He was going to work with Jack Wishna but once his family showed up with their immense demands Michael became debilitated and could not do 2 shows a
• Klein went to see Michael In Vegas in 2007 and met Dr. Conrad Murray who Micheal said was incompetent.. Klein asked Murray to leave and had a long talk with Michael about Propofol. “Only with an anesthesiologist if you fall off the wagon.”
• “Michael still needed money but was in no physical condition to do 30 shows
• Jermaine introduced Michael to a conman Tohme Tohme who knew Tom Barrack
• Barrack  a realtor who knew  Philip Anschutz  of AEG a very rich notorius conservative from Colorado together with Branca they bought out the Prince of Bahraine’s interest in the immense Music Catalogue of Jackson’s.

        Barrack also happened to be foreclosing on Conrad Murray’s house in the Red Rock Canyon Section of Vegas

         Mand Murray was up to his neck in debt & desperately needed a job, and agreed to care for

         Jackson at night meaning deliver Propofol. Murray was hired to care for Jackson

         Murray  was not  Licensed in England?

        England was never a part of their  plan,

Murray started work on May 1st and Klein was in Europe all of May 09.

• He was hired to give Jackson Propofol and was totally ignorant and AEG made sure he was ill-equiped
• These dangerous effects of Propofol are more likely to occur following rapid large shots as used by Conrad
• Propofol administration depends on a skilled Physician as described above and requires proper “
• Murray and the people who hired him are responsible for Michael’s
• Murray did not know how to deliver Propofol and was ill equipped and dangerously combined it with Ativan
• On the day of his death when Murray entered Jackson’s room in the afternoon and found Jackson in bed and not Jackson had a weak pulse, his body was still warm and with proper equipment he could have been saved.
• Murray tried to revive Jackson for five to ten minutes, at which point he realized he needed to call for
• Murray stated that he was hindered because there was no landline in the
• Murray also stated that he could not use his cell phone to call 911 because he did not know the        exact        address       which         everyone     in   the        world knew
• Murray stated that he also phoned security, but they did not answer,
• Finally, Murray ran

downstairs, yelled for help, and told a chef to bring security up to the room.

• By the time security called 911, Murray’s lawyer stated that at least 30 minutes had
• When the paramedics arrived Murray said he only used Ativan
• Michael dies and what does the Coroner find, acute propofol and benzodiazepine intoxication after suffering cardiac arrest -­‐-­‐-­‐there is no
• Demerol
• An anesthesiologist is easy to find at $ 150,000.00/ month
• These people wanted an incompetent physician and Michael’s
• During the AEG trial it was revealed that AEG employed Conrad Murray and Jackson did not sign the contract for the above-cited [
• Michael thought Conrad Murray was incompetent, Murray was not an anesthesiologist and was totally incapable of administering Propofol
• Michael Jackson and Doctor Klein had a HIPAA covenant never to release his records since the first molestation What follows are all HIPAA violations,
• One group wanted to blame Klein because he knew their desire was the Catalogue and the will was a fraud.
• Others want to blame Klein to conceal their money laundering.
• Harvey Levin was the worst he will always lie for Weitzman
• He did in 94 about Marcia Clark arriving at OJ’s with out a warrant
• Jason Pfeiffer illegaly released Klein’s records on Michael Jackson to Randy Phillips of AEG and Bradley Sharp .
• Pfeiffer erects a website to contact the Medical Board over Klein.
• Here is Pfeiffer, a man who tried to kill Klein twice, when he illegally changed Dr. Klein’s Will and Trust and when he used Moban to get Klein into Bankruptcy Court.
• Pfeiffer was part of the conspiracy that opened 22 fraudulent bank accounts in Klein’s name to launder his funds. 10 of the money laundering accounts were at John Branca’s Banc of California and reporting Dr. Klein to the Medical Board.. Why? Because it would conceal Pfeiffer’s actions and create a chaos to prevent Klein’s survival. Klein was a disabled elder easy to drug
• Richard Charnley then illegally released records on Michael Jackson to Harvey Levin, Randy Phillips of AEG, and Bradley Sharp of Banc of California
• Richard Charnley participated in the illegal Medicis Settlement together with Muhammad Khilji,
• Set-­‐up the 8 accounts at   City National Bank Flower Street by Identity theft of Klein with insider Ron Freed
• and works  with 10 accounts at John Branca’s Banc of California set up by Bradley Sharp and John Reitman using the identity theft of Klein
• Bob Lorsch showed up the day Michael died in Klein’s office to eventually open the
• fraudulent 10 accounts At Branca’s Banc of California with Khilji, Pfeiffer, Lorsch, Sharp, and Reitman by identity theft.

• But the Media courtesy of Jason Pfeiffer, Richard Charnley ,John Reitman,Muhammad Khilji,David Rish,Harvey Levin,Vanity Fair,John Branca,Randy Phillips,Howard Weitzman, Kimberly Wilson and Bradley Sharp are going to try to blame Michaels death on the small doses of Demerol Klein and try to kill him. How?
• Burn down his house,stop his Medicare and give a heart attack. Knowing he did nothing wrong.
• On November 16, 2010 Dr, Klein was suppose to go to the premier of Burlesque with Ronni Chasen  and she was shot through the passenger Window of her car.
• Harvey Levin is the most disgusting and worst of them all. He cost Dr. Klein a year of his life trying to make sure Howard became a Trustee. He lied about my use of Demerol trying to conceal how Jackson died.

Harvey is a  Cross   between Vlad III, Prince of Wallachia and Roy Cohen.

He is a very very dangerous man because peple believe his lies.

• The truth did not matter they have the media and Politician’s on their side Anschutz of AEG  is very close to Governor Brown and Branca is the largest supporter of of District Attorney’s Cooley’s run for Governor. They must distance themselves from Murray and put the blame on Klein’s small doses of Demerol. With the public totally ignorant on the dangerous nature of Propofol it will work but no longer..Michael did not hire Conrad Murray and the ridiculous trial where Dr. Klein could no speak is long gone.
• Michael was dependent on Propofol but had successfully withdrawn in the
• The thieves use his death to screen the truth.
• Michael Jackson would be alive today if the used a competent
• The bl
  • Come and watch Dr. Klein question Jason about his  Michael is gay lie.
  • they set-up 22 fraudulent bank accounts in Dr. Klein’s name
  • They overmedicated Dr. Klein into banruptcy court he did no have a single mortgage on his homes.
  • The killed Michael for his Catalogue and according to the second 2003  Will his Catalogue and Neverland  belongs to his Children.    The Will of Mr. Michael Jackson written in 2002 that was used to settle Michael’s estate was neither current nor the one produced by Jackson. Michael was concerned about the potential welfare of his children and created two subsequent wills that were well known to his  friend Dr. Arnold Klein. The will written in 2002 was hastily created at the request of some of Michael’s lawyers at the time and representatives of Michael’s management (from his old accounting firm) but its legitimacy should be called into question  because the one presented in Court was not the one written by Jackson. . Why? Because he supposedly signed this document in Los Angeles on a day he was actually in New York with the Reverend Al Sharpton. Michael’s 1st son’s name was Michael Joseph Jackson Jr not Prince Michael Jackson Jr; So how did the lawyers use such a flagrantly inaccurate document that Michael could never have signed and they mispelled his Children’s names. Because you believe the LA Courts and Harvey Levin. This explains the presence of Diana Ross in this will. It should be noted almost all the people associated with the first Will written in 2002 had been fired by Michael. In January/February 2003 Michael drew up another Will in Florida. In this document the executors were Al Malnik, his new advisor and a well-known businessman and former tax lawyer, and John McClaine, a long time business associate and friend. In addition, a new lawyer of Michael,s named David LaGrand, and Michael’s new accountant, Allan Whitman, were named the head of Michael Jackson’s foundation. The foundation was supposed to have kept Neverland Ranch running for his children to live in and kept the ranch preserved in its current state forever.  Al Malnik was to become the guardian of Blanket and Michael became the guardian of one of Al Malnik’s young children Three months later Michael changed his Will and Will three is written. Michael found out the  underworld history history of Al Manick. removed David LaGrand and named Al Whitman sole head of his foundation. He Left his Catalogue and Neverland to Michael Joseph Jackson Jr,Paris-Michael Katherine Jackson and  Prince Michael Jackson Jr.  He also included specific instructions for certain key people he trusted whom were to have specific jobs related to the running of the empire he had worked so hard to build which did not include Branca and Weitzman Additionally he left specific amounts to approximately 10 people.  I don’t remember all but a few I do!

      Who are the people who thought Micheal Jackson’s catalogue was more important than his survival

• Recently Bradley Sharp reported Klein to the Nevada medical Board and on April

• 2015 they want his finger prints.

• Klein will take action against , Bradley Sharp, Banc of California
• its Board of Jason Pfeiffer, Richard Charnley, City National Bank, and its board of directors. Robert Lorsch, John Reitman, Ron Freed for Dr. Klein’s decreased income,destruction of his reputation, continuous, severe and potentially dangerous overmedication, HIPAA violations, illegal alteration of Will and Trust,mortgage fraud, financial elder abuse,physical elder abuse, violation of Homeowners Bill of Rights