On Friday, 10/10/08, I filed my Amended Complaint for Injunctive Relief with the court. The Amended Complaint recombines my original complaint with the Ex Parte Motion (which were both filed and served the same day, 6/17/08). The facts underlying the complaint were in the Ex Parte Motion, while the charges were in the complaint itself.
The Amended Complaint updates the facts through Oct. 10th to account for the acts and behavior of the Board and Comanco. It also adds a number of charges based on allegations of financial improprieties, raising the total number of charges to 21.
These additional charges include: 1) Breach of fiduciary duty, 2) Fraud in the concealment and/or omission, 3) constructive fraud, 4) Civil conspiracy, 5) aiding and abetting, 6) Theft by unauthorized control over property and by deception, 7) Embezzlement – Fraudulent misappropriation by fiduciaries, 8.) Fraudulent misrepresentation by corporate officer or agent, 9) Defamation by libel and slander.
Charing Cross Lawsuit Freedom of Information Weblog 