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  • Affidavit On Fraud by Ban Ki-Moon's Nephew Joo-Hyun Bahn

    Transféré par

    Matthew Russell Lee
    577 vues8 pages
    As ICP Asks Ban Disclosed on Nephew, Affidavit of Fraud Surfaces, Here By Matthew Russell Lee UNITED NATIONS, May 29 -- UN Secretary General Ban Ki-moon was in his native South Korea for five days then headed to Vietnam while Press questions remained and remain unanswered by the UN about his links to the Vietnam related scandal surrounding the suicide of South Korean businessman Sung Wan-jong, and his own nephew Joo-hyun "Dennis" Bahn. Inner City Press asked the UN on May 15, video here. Now a sworn affidavit regarding Ban's nephew Bahn's conduct has surfaced, here. Given the UN's refusal to answer questions -- Ban's deputy spokesperson called Inner City Press an "obnoxious child" for its questions, while Ban's head of peacekeeping outright refuses all Press questions -- the publication of this affidavit should require some response by the UN, given its similarity to what Bahn did, saying Ban spoke to Qatar's Emir about real estate. The affidavit says: I, John Dragone, do hereby make the following Declaration based on personal knowledge and good faith belief: TCI engaged Defendant Bahn in January 2011 as an independent contractor that had the ability to refer customers to TCI for the purpose of attempting to obtain mortgages. In the event such referral led to a loan, Bahn would be paid a commission. In fact, Bahn defrauded the Plaintiff and at least one other person by assuming a title of “Managing Director” of TCI, issuing fake letters purporting to be from TCI, collecting deposit monies from the victims, and then depositing those funds in a bank account of “Terrace Capital LLC”, set up without my or TCI’s knowledge in New Jersey. After investigation, on January 11, 2012, I learned of Bahn’s contact with Peter Salvatori, who I understand has an interest in the Plaintiff. I promptly contacted Mr. Salvatori’s mortgage broker and advised him of Bahn’s fraudulent activities. At no time was Bahn a “Managing Director” of TCI or otherwise authorized to use the title “Managing Director”. Neither TCI nor I had any knowledge with respect to Bahn’s use of the title “Managing Director” of TCI. Bahn’s activities with respect to setting up “Terrace Capital LLC” and a bank account in that name were done without the knowledge or authority of TCI and me. Prior to my investigation in early January, neither TCI nor I had any knowledge that Bahn had allegedly demanded and collected monies from the Plaintiff and deposited them in a bank account bearing the name “Terrace Capital LLC”. 19. If Bahn did demand and collect monies from the Plaintiff and deposit them in a bank account bearing the name “Terrance Capital LLC”, it was done without the knowledge or authority of TCI or me. After my investigation, in February 2012, I contacted the FBI, the Bergen County (NJ) Prosecutor’s Office, the New York Police Department and the Fort Lee Police Department. I filed a police report with the Fort Lee Police Department detailing Bahn’s fraudulent activities with respect to Mr. Salvatori and the other victim of his fraud. After Ban's deputy spokesperson on May 20 told Inner City Press he would get a simple list of UN contracts of Colliers International where Ban's nephew works, video here, he did not return with it on May 21. But on May 22 he had a read out, and Inner City Press had and has more questions. Video here. On May 22 when Inner City Press asked if Ban had disclosed that this nephew works for Colliers which rents to and for the UN, Haq said " I believe the disclosure is reviewed, like I said, by an outside company. I… all I can attest to is what's on the website, and you can see that for yourself." On May 27, Inner City Press asked Ban's lead spokesman Stephane Dujarric: Inner City Press: I’m sorry, it's not to play gotcha, but I'm quite interested in it, the public financial disclosure, which was a major plank of the Secretary-General, okay, yesterday I asked you if [PricewaterhouseCoopers] is still do

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    Affidavit on Fraud by Ban Ki-moon's Nephew Joo-hyun Bahn

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    As ICP Asks Ban Disclosed on Nephew, Affidavit of Fraud Surfaces, Here By Matthew Russell Lee UNITED NATIONS, May 29 -- UN Secretary General Ban Ki-moon was in his native South Korea for five days then headed to Vietnam while Press questions remained and remain unanswered by the UN about his links to the Vietnam related scandal surrounding the suicide of South Korean businessman Sung Wan-jong, and his own nephew Joo-hyun "Dennis" Bahn. Inner City Press asked the UN on May 15, video here. Now a sworn affidavit regarding Ban's nephew Bahn's conduct has surfaced, here. Given the UN's refusal to answer questions -- Ban's deputy spokesperson called Inner City Press an "obnoxious child" for its questions, while Ban's head of peacekeeping outright refuses all Press questions -- the publication of this affidavit should require some response by the UN, given its similarity to what Bahn did, saying Ban spoke to Qatar's Emir about real estate. The affidavit says: I, John Dragone, do hereby make the following Declaration based on personal knowledge and good faith belief: TCI engaged Defendant Bahn in January 2011 as an independent contractor that had the ability to refer customers to TCI for the purpose of attempting to obtain mortgages. In the event such referral led to a loan, Bahn would be paid a commission. In fact, Bahn defrauded the Plaintiff and at least one other person by assuming a title of “Managing Director” of TCI, issuing fake letters purporting to be from TCI, collecting deposit monies from the victims, and then depositing those funds in a bank account of “Terrace Capital LLC”, set up without my or TCI’s knowledge in New Jersey. After investigation, on January 11, 2012, I learned of Bahn’s contact with Peter Salvatori, who I understand has an interest in the Plaintiff. I promptly contacted Mr. Salvatori’s mortgage broker and advised him of Bahn’s fraudulent activities. At no time was Bahn a “Managing Director” of TCI or otherwise authorized to use the title “Managing Director”. Neither TCI nor I had any knowledge with respect to Bahn’s use of the title “Managing Director” of TCI. Bahn’s activities with respect to setting up “Terrace Capital LLC” and a bank account in that name were done without the knowledge or authority of TCI and me. Prior to my investigation in early January, neither TCI nor I had any knowledge that Bahn had allegedly demanded and collected monies from the Plaintiff and deposited them in a bank account bearing the name “Terrace Capital LLC”. 19. If Bahn did demand and collect monies from the Plaintiff and deposit them in a bank account bearing the name “Terrance Capital LLC”, it was done without the knowledge or authority of TCI or me. After my investigation, in February 2012, I contacted the FBI, the Bergen County (NJ) Prosecutor’s Office, the New York Police Department and the Fort Lee Police Department. I filed a police report with the Fort Lee Police Department detailing Bahn’s fraudulent activities with respect to Mr. Salvatori and the other victim of his fraud. After Ban's deputy spokesperson on May 20 told Inner City Press he would get a simple list of UN contracts of Colliers International where Ban's nephew works, video here, he did not return with it on May 21. But on May 22 he had a read out, and Inner City Press had and has more questions. Video here. On May 22 when Inner City Press asked if Ban had disclosed that this nephew works for Colliers which rents to and for the UN, Haq said " I believe the disclosure is reviewed, like I said, by an outside company. I… all I can attest to is what's on the website, and you can see that for yourself." On May 27, Inner City Press asked Ban's lead spokesman Stephane Dujarric: Inner City Press: I’m sorry, it's not to play gotcha, but I'm quite interested in it, the public financial disclosure, which was a major plank of the Secretary-General, okay, yesterday I asked you if [PricewaterhouseCoopers] is still do

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    577 vues8 pages

    Affidavit On Fraud by Ban Ki-Moon's Nephew Joo-Hyun Bahn

    Transféré par

    Matthew Russell Lee
    As ICP Asks Ban Disclosed on Nephew, Affidavit of Fraud Surfaces, Here By Matthew Russell Lee UNITED NATIONS, May 29 -- UN Secretary General Ban Ki-moon was in his native South Korea for five days then headed to Vietnam while Press questions remained and remain unanswered by the UN about his links to the Vietnam related scandal surrounding the suicide of South Korean businessman Sung Wan-jong, and his own nephew Joo-hyun "Dennis" Bahn. Inner City Press asked the UN on May 15, video here. Now a sworn affidavit regarding Ban's nephew Bahn's conduct has surfaced, here. Given the UN's refusal to answer questions -- Ban's deputy spokesperson called Inner City Press an "obnoxious child" for its questions, while Ban's head of peacekeeping outright refuses all Press questions -- the publication of this affidavit should require some response by the UN, given its similarity to what Bahn did, saying Ban spoke to Qatar's Emir about real estate. The affidavit says: I, John Dragone, do hereby make the following Declaration based on personal knowledge and good faith belief: TCI engaged Defendant Bahn in January 2011 as an independent contractor that had the ability to refer customers to TCI for the purpose of attempting to obtain mortgages. In the event such referral led to a loan, Bahn would be paid a commission. In fact, Bahn defrauded the Plaintiff and at least one other person by assuming a title of “Managing Director” of TCI, issuing fake letters purporting to be from TCI, collecting deposit monies from the victims, and then depositing those funds in a bank account of “Terrace Capital LLC”, set up without my or TCI’s knowledge in New Jersey. After investigation, on January 11, 2012, I learned of Bahn’s contact with Peter Salvatori, who I understand has an interest in the Plaintiff. I promptly contacted Mr. Salvatori’s mortgage broker and advised him of Bahn’s fraudulent activities. At no time was Bahn a “Managing Director” of TCI or otherwise authorized to use the title “Managing Director”. Neither TCI nor I had any knowledge with respect to Bahn’s use of the title “Managing Director” of TCI. Bahn’s activities with respect to setting up “Terrace Capital LLC” and a bank account in that name were done without the knowledge or authority of TCI and me. Prior to my investigation in early January, neither TCI nor I had any knowledge that Bahn had allegedly demanded and collected monies from the Plaintiff and deposited them in a bank account bearing the name “Terrace Capital LLC”. 19. If Bahn did demand and collect monies from the Plaintiff and deposit them in a bank account bearing the name “Terrance Capital LLC”, it was done without the knowledge or authority of TCI or me. After my investigation, in February 2012, I contacted the FBI, the Bergen County (NJ) Prosecutor’s Office, the New York Police Department and the Fort Lee Police Department. I filed a police report with the Fort Lee Police Department detailing Bahn’s fraudulent activities with respect to Mr. Salvatori and the other victim of his fraud. After Ban's deputy spokesperson on May 20 told Inner City Press he would get a simple list of UN contracts of Colliers International where Ban's nephew works, video here, he did not return with it on May 21. But on May 22 he had a read out, and Inner City Press had and has more questions. Video here. On May 22 when Inner City Press asked if Ban had disclosed that this nephew works for Colliers which rents to and for the UN, Haq said " I believe the disclosure is reviewed, like I said, by an outside company. I… all I can attest to is what's on the website, and you can see that for yourself." On May 27, Inner City Press asked Ban's lead spokesman Stephane Dujarric: Inner City Press: I’m sorry, it's not to play gotcha, but I'm quite interested in it, the public financial disclosure, which was a major plank of the Secretary-General, okay, yesterday I asked you if [PricewaterhouseCoopers] is still do

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    Case 2:12-cv-00539-EL Document 8-1 Filed 03/19/12 Page 1 of 8

    LAW & ASSOCIATES, LLC

    LOANZON SHEIKH LLC

    One Penn Center


    1617 John F. Kennedy Blvd., Suite 650
    Philadelphia, PA 19103-1806
    (215) 751-0500
    By: Tsiwen M. Law, Esq.

    112 Madison Avenue, 5th Floor


    New York, NY 10016
    (212) 760-1515
    By: Umar A. Sheikh, Esq.
    (Pending Pro Hac Vice Admission)

    Local Counsel for Defendants


    Terrace Capital, Inc. and John Dragone t/a
    Terrace Capital, Inc.

    Attorneys for Defendants


    Terrace Capital, Inc. and John Dragone t/a
    Terrace Capital, Inc.

    UNITED STATES DISTRICT COURT


    EASTERN DISTRICT OF PENNSYLVANIA

    Civil Action No.: 12-cv-539 (EL)

    MMR GENERAL LLC t/a MONTAGE


    MOUNTAIN RESORTS, L.P.,
    Plaintiff,

    -against-

    DECLARATION OF JOHN DRAGONE IN


    SUPPORT OF MOTION TO DISMISS

    TERRACE CAPITAL, INC. and JOHN


    DRAGONE t/a TERRACE CAPITAL, INC.
    and TERRACE CAPITAL, LLC and DENNIS
    JOOHYUN BAHN a/k/a JOOHYUN BAHN,

    Defendants.

    I, John Dragone, do hereby make the following Declaration based on personal knowledge
    and good faith belief:
    1.

    I am one of the defendants named in the within action and respectfully submit this

    Declaration in Support of the instant motion to dismiss by defendants, Terrace Capital, Inc.
    (TCI) and John Dragone t/a Terrace Capital, Inc. (Dragone and with TCI, the Defendants).
    When I refer to myself in this Declaration, I am referring to myself, both personally and trading
    as Terrace Capital, Inc..
    2.

    I am a Managing Director of TCI.

    3.

    I have reviewed the Complaint filed in the within action.

    Page 1 of 5

    Case 2:12-cv-00539-EL Document 8-1 Filed 03/19/12 Page 2 of 8

    4.

    My counsel has advised me that in connection with the instant motion to dismiss

    the Court may not entertain review of all of the facts set forth in this Declaration.
    Notwithstanding, while it is the Defendants position that the motion has merit irrespective of the
    facts set forth herein, in the spirit of candor, the Defendants believe that it is important to set
    forth the relationship between the Defendants and defendant Dennis Joohyun Bahn a/k/a
    Joohyun Bahn (Bahn).

    Lack of Personal Jurisdiction


    Neither TCI nor I have ever solicited any business within the Commonwealth of

    5.

    Pennsylvania. Further, neither TCI nor I have visited any property in Pennsylvania.
    6.

    As explained below, the occurrences alleged within the Plaintiffs Complaint (the

    Complaint) between the Plaintiff and Bahn were not authorized by either TCI or me, and Bahn
    did not have the requisite authority on behalf of either TCI or me to engage in the alleged
    activities. Further, neither TCI nor I had any knowledge of Bahns activities with respect to the

    occurrences alleged in the Complaint until after the relevant events had occurred.

    Relationship between TCI and Bahn


    7.

    TCI engaged Defendant Bahn in January 2011 as an independent contractor that

    had the ability to refer customers to TCI for the purpose of attempting to obtain mortgages. In
    the event such referral led to a loan, Bahn would be paid a commission.
    8.

    A true copy of the Independent Contractor Agreement between TCI and Bahn is

    annexed here as Exhibit B.

    Page 2 of 5

    Case 2:12-cv-00539-EL Document 8-1 Filed 03/19/12 Page 3 of 8

    9.

    In fact, Bahn defrauded the Plaintiff and at least one other person by assuming a

    title of Managing Director of TCI, issuing fake letters purporting to be from TCI, collecting
    deposit monies from the victims, and then depositing those funds in a bank account of Terrace
    Capital LLC, set up without my or TCIs knowledge in New Jersey.
    10.

    The first time TCI or I learned of Bahns activities with respect to the Plaintiff

    and the occurrences alleged in the Complaint was in early January 2012 after I was contacted by
    another victim of Bahns fraud and wrongful actions.
    11.

    After investigation, on January 11, 2012, I learned of Bahns contact with Peter

    Salvatori, who I understand has an interest in the Plaintiff. I promptly contacted Mr. Salvatoris
    mortgage broker and advised him of Bahns fraudulent activities.
    12.

    At no time was Bahn a Managing Director of TCI or otherwise authorized to

    use the title Managing Director.


    13.

    Neither TCI nor I had any knowledge with respect to Bahns use of the title

    Managing Director of TCI.

    Prior to my investigation in early January, neither TCI nor I had any knowledge

    14.

    with respect to Bahns alleged issuance of a letter of interest to the Plaintiff.


    15.

    If Bahn did issue the alleged letter of interest to the Plaintiff, it was done without

    the knowledge or authority of TCI or me.


    16.

    Prior to my investigation in early January, neither TCI nor I had any knowledge

    that Bahn had set up a company with the name Terrace Capital LLC in New Jersey or that he
    opened a bank account with that name.
    17.

    Bahns activities with respect to setting up Terrace Capital LLC and a bank

    account in that name were done without the knowledge or authority of TCI and me.

    Page 3 of 5

    Case 2:12-cv-00539-EL Document 8-1 Filed 03/19/12 Page 4 of 8

    18.

    Prior to my investigation in early January, neither TCI nor I had any knowledge

    that Bahn had allegedly demanded and collected monies from the Plaintiff and deposited them in
    a bank account bearing the name Terrace Capital LLC.
    19.

    If Bahn did demand and collect monies from the Plaintiff and deposit them in a

    bank account bearing the name Terrance Capital LLC, it was done without the knowledge or
    authority of TCI or me.
    20.

    Prior to my investigation in early January, neither TCI nor I had any knowledge

    with respect to Bahns alleged issuance of a commitment to the Plaintiff.


    If Bahn did issue the alleged commitment to the Plaintiff, it was done without the

    21.

    knowledge or authority of TCI or me.


    22.

    Neither TCI nor I maintain an office in New Jersey. Terrace Capital LLC is not

    connected in any manner with TCI or me.


    23.

    After my investigation, in February 2012, I contacted the FBI, the Bergen County

    (NJ) Prosecutors Office, the New York Police Department and the Fort Lee Police Department.
    I filed a police report with the Fort Lee Police Department detailing Bahns

    24.

    fraudulent activities with respect to Mr. Salvatori and the other victim of his fraud.

    [THE REMAINDER OF THIS PAGE INTENTIONALLY LEFT BLANK]

    Page 4 of 5

    Case 2:12-cv-00539-EL Document 8-1 Filed 03/19/12 Page 5 of 8

    Case 2:12-cv-00539-EL Document 8-1 Filed 03/19/12 Page 6 of 8

    EXHIBIT B

    Case 2:12-cv-00539-EL Document 8-1 Filed 03/19/12 Page 7 of 8

    Case 2:12-cv-00539-EL Document 8-1 Filed 03/19/12 Page 8 of 8

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