CV 2022-090521

This is an excerpt from our Verified Complaint filed February 06, 2022 at Maricopa Superior Court.

“A verified complaint has a statement at the very end of the complaint, that is signed under penalty of perjury stating that the statements in the complaint are true”

Every statement in our Complaint, filed under oath and penalty of perjury is true. We have written evidence for every claim made in this Complaint and beyond. The List is long and not limited to:

The Fraud in inducing us to sign the lease Guarantee and invest hundreds of thousands of dollars in equipment and renovation.
The Forgery, when Defendants swapped pages in the Final Version of the approved by us lease, after we signed the lease and the lease guarantee.
The illegal lockout. Robson Communities Inc. used the forged lease in an attempt to extort from us over $100,000. Money we never owed them. To the contrary, according to agreements, Robson and RNS OWED US MONEY when they locked us out and confiscated our entire property.
Theft of our food during the raging Pandemic, which is a criminal offence.
Theft of our Private and Financial Files, which is a criminal offence.
The Grand Theft/Conversion of our entire property despite being in compliance with the lease terms.
Depravation of our livelihood.
Metro Phoenix Bank collaboration with defendants to defraud both us and the SBA. (taxpayers money)
Metro Phoenix Bank confiscation of our entire property despite us never being in default.
Robson Communities Inc. confiscation of our over $450,000 equipment and Tenant improvement Funds.
Overcharge of property taxes with intention to defraud. They cheated on property taxes. It might be an unaccounted income, as property taxes are fully deductible. They tried to collect from us over $1,800 more in property taxes. It is incredible. The fraud and deceit goes beyond all imagination and decency. Unfortunately it is all true. Exhibit:

Imagine that it happened to you. Imagine somebody stealing your entire life savings and depriving you of your livelihood using forged document and false baseless claims. Just imagine the situation below.

You buy very expensive car, a collectible for $250,000. You only have $190,000 so you get $60,000 loan to purchase this car from SBA to use it as business (expensive limousine). The SBA loan is provided by a small bank you trust. You put another $100,000 into this car in parts and labor. It is your private car, bought with your savings, the car that you will use to make living. You find a garage for your car. The garage is a wreck, but the owner of the garage promises you one year free rent if you renovate his garage. You both sign the lease agreement. Everything is in writing. You ask your bank to give you permission to store your car in the new garage. The Bank agrees to it and gets a Landlord waiver that is mandatory for every SBA loan. The waiver waives Landlord’s right to the collateral (the car) in the case of a default. Your landlord is aware of the SBA collateral and he voluntarily waives his rights. For eight years you have been paying your SBA loan dutifully, always on time. NEVER LATE. The $360,000 car is almost paid in full. You are so happy. There is only $18,000 left on the loan and you will be debt free. After one year passed, you come to your garage and find the door locked and the lock changed. The landlord informs you that he changed his mind and to get access to your $360,000 car, you must pay not only double the rent to what you have agreed to, but also the back rent that was supposed to be free. It does not end there, the Landlord confiscates all your tools in the garage and other property he has no right to keep, like your passport that was in your car after your last Mexico trip. You are furious and contact your Bank to help you. The law prohibits the landlord to keep SBA collateral hostage. This is the law. Nobody is above the Law. You trust the Law, therefore you make another loan payment, despite the car being illegally held hostage by the landlord. You know that the law is on your side and that he has no right to keep the SBA collateral hostage. You know you DO NOT OWE HIM MONEY. You trust the justice system and that you are entitled to get back your property. It is just a matter of time. Then, one day you discover that someone else is driving your car, the plates had been changed. The car got a new owner. You contact your Bank, telling them that your property, and the SBA collateral, has been stolen by the Landlord and given to an unknown individual. To your horror the Bank informs you, that AFTER you discovered the theft, The Bank decided to give your $360,000 property (car) and the SBA collateral, to the Landlords for $3,600 (yes, THREE thousand six hundred dollars), leaving you with $14,000 in outstanding balance. You can’t believe it being the truth. It is completely illegal. We aren’t in Russia, we are in USA. The illegal transfer of your property was done bypassing the judicial system and the rule of Law in its entirety. Your $360,000 car was stolen from you without a court order, bypassing all required procedures, and given to the Landlord for $3,600. 1% of its true value. You could easily sell for over $200,000. The Landlord further passes your $360,000 car to his friend Melton for unknown amount of money. Again, it is completely illegal. He has no right to confiscate your property, but Melton always wanted to have a car like yours, however Melton did not want to pay for it. Suddenly you realize that you are a victim of a well planned, massive Fraud scheme. It was all planned from the very beginning. You have been duped and used to not only renovate the devastated garage for free, but even to provide Landlord’s friend Melton with a car he always wanted and dreamt of having, but did not want to pay for. You think I am crazy? I assure you I am not. Read the article. The evil is beyond any humane imagination. Melton could not know that my restaurant was closed because the Landlord took down the lockout notice a week after the lockout. Nobody knew I was closed, there was no “For Lease” sign. Melton finally got what he wanted for pennies on a dollar. Again, completely illegal. Exhibit: Melton bragging about the great deal he made.

Robson Communities Inc, RNS, The Brokers and The Bank used us to renovate and equip the restaurant to be able give it away to Melton and Hernandez who always dreamt of having a restaurant there, but did not want to pay for it. This is why our $35,000 (thirty five thousand) pierogi maker was given to them for $35.00 (thirty five dollars). 1% of its true value. It is completely illegal, but offenders were sure that they will never face the justice system they evaded. They went as far as cheating us by overcharging property taxes. The greed goes beyond all human decency. They invoiced me $1,958.33 while the 2018 Property Tax was $1,801.18. Which makes overcharge of $1,866.77/year. Exhibit: Fraudulently invoiced property taxes | Exhibit: Correct Property Taxes

Robson Communities Inc, The Bank, The Brokers and the new owner of the restaurant knew that our stay was dependent on us having a business and hiring American citizens. They were sure, that by depriving us of our business and livelihood we will be forced to leave the country. Counsel Mc Nichol – Metro Phoenix Bank attorney – pointed it out in his Motion to Dismiss. He brazenly claims that we are not entitled to Punitive Damages because we are illegals. Unfortunately and unknowingly for him, we just got our green cards approved. Concepcion Henderson the Vice President of the Metro Phoenix Bank knowingly, intentionally and deliberately placed our private chest freezers on the auctioneers list and let $35,000 pierogi maker to be donated to Robson Communities Inc for $35.00 (yes, thirty five dollars, after all discounts and “storage charges” applied. Ms. Henderson conduct is arguably criminal, as the pierogi makes was never owned by neither Beaver Choice nor BeCe Kitchen and she was informed it was not SBA collateral. Thus Ms. Henderson intentionally and deliberately “sold” property she has no right to touch.

Curiously, at the same time Ms. Henderson omitted 90% of the equipment that was moved to RNS property with Metro Phoenix approval, but on demand of an truly sick and psychotics individual or by her own desire, the discovery process will clear up this problem, Ms. Henderson intentionally placed our private chest freezers on the auctioneers forced sale value list. The list she has no right to either make or execute because we were current on our Loan Payments. The reason for this theft is that one of the new owners of the restaurant – Hernandez – for unknown reason wanted to keep our exempt by Arizona statutes property for his own. See the picture of Hernandez howling away our private not NSF certified chest freezers, while denying entry to sheriff deputy to look for our stolen passports and other personal exempt by law property. Exhibit: Chest Freezers on Hernandez Truck

Robson Communities Inc. attorney in his Motion to dismiss tried to convince the court that our private 6 months food supply, protected by Arizona Statutes Exemptions, belonged to the business. He argues that these billionaires were entitled to render us, hard working elderly immigrants both homeless and starving. These billionaires, these “charity icons” deprived us of food during the raging pandemic. It is only comparable with what Russian are doing in Ukraine today. Russians are too depriving poor people of food and shelter. How low you can a human being sink in his/her psychotics vendetta? The people who authorized our food to be tossed away are worse than NAZIS during second World War. They are not Humans. They are pure monsters.

The most unnerving thing is that the wife of Edward Robson, the chairman who, to this day controls all dealing within the Robson Communities Inc. his wife is running for Governor. The woman who came to my restaurant and assured me not to worry during the raging pandemic, the woman and her husband who had the power to stop the grand Theft, this woman is running for Governor. This cannot happen. This has to be stopped. The Arizona Statute allowing landlords to confiscate property without the due process needs to be changed. The statute violates American Constitution. Nobody can be deprived of property without a due process. Our Constitutional rights have been violated. The offenders MUST face the justice system. WE ARE NOT THE FIRST ONES AND WE WILL BE NOT THE LAST ONE, If this impunity allows to continue. If people like Karrin Robson can run for office and win then God have mercy on us.

PART OF OUR VERIFIED COMPLAINT:

General allegations

Plaintiffs came to USA in June 2010 as E-2 Treaty Investor Visa holders from Canada.
Plaintiffs are originally from Poland.
Hanna lived in Sweden for numerous years.
In or around 2010 Plaintiffs sold their successful business in Canada, their house and all their investments.
More than $250,000 of Plaintiffs’ private funds is to be invested in the USA to receive the E-2 Treaty Investor visa status.
This status expires as soon as applicants loose or sell their business. Ex 1; E-2 Visa Rules | Ex 2; Hanna E-2 Visa | Ex 3; Marek E-2 Visa
Defendants are aware of this condition regarding Plaintiff’s immigration status.
Plaintiffs are founders of one of the most celebrated and featured in the media restaurants (“Beaver Choice”).
Beaver Choice is featured on Food Network, Cooking Channel, and “Check Please Arizona”.
Expensive high-tech equipment is necessary to start a franchise of fast casual restaurant concept featuring European food.
RNS is Plaintiff’s landlord.
East State Street LP and East State Street, Inc. are RNS’ General Partners
Robson Communities is an Arizona Corporation
Edward is the Founder and Chairman of Robson Communities.
Paula Robinson is the Vice President and General Partner of East State Street, Inc.
Concepcion is the Assistant Vice President of Metro Phoenix Bank.
SRS is the real estate broker for Robson Affiliates
Ellsworth is the Vice President of SRS.
Teerink is a Senior Property Manager at Robson Communities.
Michael is the Vice President of Robson Communities.
Pamela is General Counsel of Robson Communities.

Landlord: RNS Center Limited Partnership, an Arizona Limited Partnership by: East State Street Limited Partnership, an Arizona limited partnership, Its: General Partner, by East State Street, Inc an Arizona corporation, its General Partner Paula Robinson

NATURE OF ACTION

This action is to first and foremost establish fraud in the inducement, fraud in factum, and to recover among others, but not limited to, over $456,500 of converted property funds being held hostage by Defendants Robson Affiliates despite fraudulently inducing Plaintiffs to sign the lease guarantee.
All further Claims are corollary of the fraudulent inducement and fraud in factum Claims exposing defendants’ reckless disregard of the law and truth.

Statement of Facts and Breach

October 2018, Plaintiff Hanna Gabrielsson contacts defendant Ellsworth regarding property located at 9542 E. Riggs rd. in Sun Lakes (the “Property”).
November 25, 2018, Defendants are presented with Plaintiffs conditions to enter into agreement:
- Conditions for opening before and after March 2019. Ex 4; Email | A.R.S. §47-1303(B; D).
- What needs to be done by both parties to get the project off the ground? Ex 5; Realistic approach.
- Both parties’ equal investment in the project. Ex 6; Chart | Ex 7; Before | Ex 8; After Kitchen | Ex 9; After Dining Room.
November 26, 2018, The First Offer is presented by SRS, Ex 10; First Offer.
November 28, 2018, the Final Offer-Agreement in Principle is produced, Ex 11; Final Offer, the Offer is accepted by both parties, Michael agrees to the conditions, getting power to the building to be turned on. Ex 12; Email getting power.
Robson Affiliates and The Brokers knowingly and intentionally present false cost of the triple net lease (“the Lease”) for the purpose of inducing Plaintiffs to sign the Lease guarantee.
The true cost is more than double of what is presented.
March 24, 2019, Plaintiffs approve final version of the lease. Ex 13; Email
March 25, 2019, Defendants arrive at the Scott Ellsworth office to sign the approved lease.
Scott Ellsworth presents the approved by Plaintiffs’ lease.
The lease includes the requested note ordering 30 days reimbursement of TIA funds. Plaintiffs briefly review the lease and the lease guarantee. Ex 14; TIA Reimbursement note.
Scott Ellsworth asks Plaintiffs to sign the lease ON THE LAST PAGE ONLY and reminds Plaintiffs to sign the lease Guarantee.
The lease is taken away to be signed by Robson Affiliates.
March 25, 2019, Defendant Gulsvig, without authorization alters the final version of the Lease.
Defendants Robson Affiliates and The Brokers conceal the true double or triple NNN charges, to trick Plaintiffs into investing hundreds of thousands of dollars of Plaintiffs private funds in equipment and renovation.
Defendants Robson Affiliates remove pages outlining landlord’s work to be done PRIOR to the delivery.
Defendants Robson Affiliates remove the note, signed by Vice President of Robson Communities Inc. Michael Robson, ordering 30 days TIA reimbursement time frame.
Defendants Robson Affiliates replace the note with an outrageous clause of 1 year waiting time for reimbursement topped with requirement of perfect performance by Plaintiffs to get the funds reimbursed.
The removal of the note is clearly visible in the forged lease.
To keep the page count correct Defendants Robson Affiliates inserted a blank page into the lease.
This is where the note was. The page number is 33 in the forged lease.
This fraudulently inserted 1 year condition was never ever communicated to Plaintiffs during the negations process as it would be a non-starter in negotiations.
This altered/forged instrument is one year later used in an extortion attempt of over $100,000, conversion/ theft of Plaintiffs entire property and libelous allegations to AG Consumer Fraud Division.
June 11, 2019, Plaintiffs send email requesting reimbursement of the TIA funds, according to the note included in the lease.
June 21, 2019. Vice President of Robson Community Inc. confirms receiving receipts and reimbursement of the TIA funds.
The building is delivered July 2019.
Three months free of charge fixturization time kicks in, followed by 10 month rent abatement.
Plaintiffs invest hundreds of thousands of dollars of private funds in both equipment and construction.
July 2019, Due to someone sick in the office, and the delay of reimbursement of TIA, Plaintiffs and Michael Robson agree to apply TIA reimbursement funds, with interest, to NNN monthly charges.
November 2019 defendant Michael is replaced by defendant Teerink to manage the Property.
March 10, 2020, Defendant Teerink pops up in Plaintiffs’ restaurant requesting April 2020 rent payment, claiming delivery day being May 2019, simultaneously denying existence of the 3 months free of charge fixturization time.
Plaintiffs take his strange request for being a simple and innocent mistake of a newly appointed manager.
To correct the wrongful assumptions, Plaintiffs send Teerink email showing a picture of the building being painted June 12, 2019, thus, impossibly to be delivered in May 2019.
Scott acknowledges the fact.
June 11, 2020, handwritten notice with an unaccounted balance is found on the counter when Plaintiffs arrive to work.
Plaintiffs contest the charges.
Defendants Teerink promise to investigate the possible error.
Plaintiffs are provided with no formal invoices or other demands.
July 13, 2020, to save on private residency expenses, Plaintiffs temporary move to a fully furnished house.
A lot of Plaintiffs private exempt property is being moved and stored on the premises at 9542 E. Riggs rd. Sun Lakes (i.a. Plaintiffs’ chest freezers with 6 months food supply due to the raging pandemic.).
These chest freezers will be deliberately auctioned by defendants.
July 24, 2020, after Plaintiffs several request to produce balance (if any), Defendants Robson Affiliates, without providing such a balance, propose Covid Aid.
Covid Aid consisted of: (i) No rent payments until December 31, 2020; (ii) Outstanding balance to be spread over the reminder of the lease; and (iii) Lease amendment to be provided soon. Ex 15; Covid Aid
September 14, 2020, one and a half years later, Plaintiffs discover the fraud in form of the $60,039.48 invoice provided to Plaintiffs, completely inconsistent with the accepted by Defendants Robson Affiliates and The Brokers offer. Ex 16; First Invoice | Ex 17; Final Offer | Ex 18; Presented vs Real charges | Ex 19; Payment Schedule
Plaintiffs refuse to pay the unsubstantiated charges. | Ex 20; Plaintiffs dispute charges
Plaintiffs demand the invoice must be adjusted to what was agreed upon.
Defendants Robson Affiliates refuse to correct the outstanding balance.
Defendants withdraw Covid Aid.
October 12, 2020, Defendant Teerink attempts to extort from Plaintiffs $60,039.48.
Defendant Teerink demanded the fraudulent invoice must be paid right away or face the invoice being recorded against Plaintiffs’ property.
Defendant Teerink, to the horror of Plaintiffs, proposes to take over premises for free with all equipment, totally ignoring Plaintiffs’ information regarding SBA collateral.
Defendant Teerink denies the existence of the 30 days TIA credit note instead referring to the clause added to the lease.
Plaintiffs realize that the lease has been altered/forged without Plaintiffs’ knowledge and approval.
October 19, 2020, Defendants Robson Affiliates lockout Plaintiffs to seal the deal with Melton and Hernandez, confiscating entire content of Plaintiffs’ restaurant. Ex 21; Lockout notice
October 22, 2020, despite the statutory 60 days to provide the correct balance to cure the debt, and for unknown reason 90 days stated on the lockout notice, Defendants Robson Affiliates start removing equipment from the restaurant two days after the lockout. Ex 22; Removing Equipment | A.R.S. §33-361(D)
By removing Plaintiffs’ equipment during the 60 days cure dept period, Defendants Robson Affiliates violate Arizona statutes.
Defendants’ Robson Affiliates actions unilaterally cancel Plaintiffs any further payments obligations.
To solve the dispute, Defendants Robson Affiliates do not correct the charges and instead, Defendants Robson Affiliates find new tenants, Lloyd Melton, and Luis Hernandez.
Melton and Hernandez offer to pay $5,400 for entire content of Plaintiffs’ restaurant. Ex 23; The max price
October 21, 2020. First attempt requesting the release of Plaintiffs exempt by law property.
The pandemic is raging so Plaintiffs ask for food supply to be released.
Defendants Robson Affiliates ignore Plaintiffs’ request.
Defendants Robson Affiliates dispose Plaintiffs’ food supply.
October 29, 2020, the alteration of the agreed upon Lease is vehemently denied by Gulsvig
Subsequently, the forged instrument is used by Defendants Robson Affiliates to confiscate Plaintiffs entire property. A.R.S. §13-2310(A; B; C) | A.R.S. §13-2001(3;5;8) | A.R.S. §13-2002(A1; A3; C).
After the lockout Plaintiffs immediately contact The Bank to get help with securing SBA(7a) loan collateral located on the premises in Sun Lakes.
The Bank promises to take care of it.
The SBA(7(a) loan collateral was never owned by BeCe Kitchen LLC and the lien was perfected in 2013, long before the collateral was moved to 9542 E. Riggs rd. in Sun Lakes.
Robson Affiliates were informed of this fact April 16, 2019.
They have no legal right to keep the SBA collateral hostage.
November 05, 2020, Plaintiffs make payment on the SBA loan, despite the SBA collateral being held hostage by Defendant Robson Affiliates and despite The Bank refusal to demand release of the SBA collateral.
December 2020 Plaintiffs make several request to The Bank for the SBA collateral to be released and moved to a secure location.
Plaintiffs offer to pay for the move. The Bank refuses to claim the collateral.
Claiming the lien being unenforceable.
December 2020, Plaintiffs ask The Bank for few weeks loan deferment, until the situation with the collateral is solved.
Plaintiffs are entitled to both deferment and SBA Covid Aid.
Starting January 2021, SBA will be making payments (10 months) on the behalf of the struggling borrowers due to the raging pandemic.
December 2020, The Bank refuses loan deferment.
December 05, 2020, Plaintiffs refuse to make SBA loan payment, first time ever since April 2013.
Plaintiffs request the collateral to be released and assure resuming loan payment as soon as the release takes place.
December 18, 2020, instead of claiming release of the collateral AFTER THERTEEN DAYS LATE PAYMENT, FIRST EVER IN THE SBA LOAN EXISTENCE, The Bank puts the SBA loan into immediate default and forced sale liquidation status.
The fractional list provided to The Bank by Robson Affiliates is sent to Arizona Auctioneers requesting forced sale value.
October 19, 2020 – February 09, 2021, Defendants Robson Affiliates refuse to correct the invoice, release third party property and Plaintiffs personal property protected by Arizona Statute exemptions.
February 08, 2021, Defendants Robson Affiliates, without giving required by law notice, allow looting of Plaintiffs restaurant to take place.
February 09, 2021, one day after Plaintiffs discovered the looting, The Bank releases the seniority SBA(7a) lien to Defendants Robson Affiliates.
The very same lien, The Bank during the last three months claimed was unenforceable, while Robson Affiliates were refusing to release SBA collateral claiming the SBA(7a) lien never existed.
February 09, 2021, The Bank transfers, over $456,500 worth of property including SBA 7(a) loan collateral (taxpayers’ money), guaranteed personally by Plaintiff, to Defendants Robson Affiliates for $9,000.
Plaintiffs Tools of trade, Plaintiffs exempt property and sensitive Information are given away or sold to unauthorized individuals.
Fifty percent (50%) or $4,500 of the $9,000 is credited back to Defendants Robson Affiliates for storage.
This transfer leaves taxpayers to foot $14,292.00 in outstanding balance and Plaintiffs forced into inevitable bankruptcy.
No correct balance, no 5 days’ notice, no public auction, no attempts to make the disposition commercially reasonable, no proper list, and no accounting of the proceeds from the sale are ever done or provided, as required by law.
Over $456,500.00 worth of property including SBA 7(a) loan collateral (taxpayers’ money), guaranteed personally by Plaintiff is transferred by The Bank and Concepcion to Robson Affiliates for $4,500. 00: 1% (ONE PERCENT) of its fair market value.
Arizona Auctioneers without ever walking the restaurant, seeing, or inspecting the equipment provide The Bank with the “forced sale” value of $12,000.
Despite the lowest possible “forced sale” valuation based on the fractional list provided by Defendants Robson Affiliates to The Bank, Defendant Concepcion, for unknown reasons, discounts the $12,000 price tag to $9,000.
To further minimize the return from the sale, in order to get the worse possible recovery of the loan or to meet Melton’s $5,400 offer for entire content of Plaintiffs restaurant, or both, Defendant Concepcion credits $4,500 or 50% back to Robson Affiliates for storage.
The Bank had three month to claim release of the equipment, Robson Affiliates have held hostage.
Instead of doing what the law requires Robson Affiliates and The Bank decided to engage in civil conspiracy and mock auction to defraud Plaintiffs and Taxpayers by plainly stealing Plaintiffs Tools of trade, Plaintiff Exempt by Law Property, Thirds Party Property and SBA(7a) loan collateral.
All in purpose to further enrich a wealthy swindler and punish Plaintiffs for disobedience in accepting to be defrauded.
The Bank violated Arizona statutes A.R.S §47-9610.
The Bank sold $35,000 (thirty-five thousand dollars) pierogi maker to Defendant Robson Affiliates for $100.00 (one hundred dollars). 0.28% of its value.
Plaintiffs had a buyer who was willing to pay $27,000.
This transaction would have paid the entire SBA(7a) loan balance in full leaving Plaintiffs with $9,000 surplus.
The Bank donated to Defendant Robson Affiliates $10,000 camera surveillance system as the system is not listed.
The Bank donated to Robson Affiliates and its affiliates $10,000 Meat Press.
Robson Affiliates and The Bank omitted 90% of the equipment located at the premises at 9542 E. Riggs rd., Sun Lakes AZ. Pictures available upon request.
The entire contents of Plaintiffs’ restaurant gets plainly stolen by Defendants Robson Affiliates and The Bank through a mock action and further passed on to Melton, and Hernandez.
Melton and Hernandez has since moved in to the Property.
It must be stressed that after October 19, 2020, the day of the lockout, despite Plaintiffs’ countless emails requesting release of third-party property and Plaintiffs’ Exempt, protected by Arizona statute property, nothing is released by Defendants Robson Affiliates and The Bank.
Plaintiffs contact Law Enforcement 3 times to get help in collecting sensitive files and exempt property.
Defendants Robson Affiliates and Hernandez refused access to sheriff deputy asked by Plaintiffs to be a part of a peaceful stand-by to inspect premise in helping Plaintiffs to collect personal belongings, which Plaintiffs’ have proof of being there March 22, 2021.
Additionally, Defendants the Bank and Robson Affiliates violated Arizona Statutes A.R.S.§33-1023 and A.R.S §47-9610.
NO 5 days’ notice ever provided.
NO proper list of the equipment ever provided.
NO public auction.
NO attempts to make the disposition commercially reasonable.
NO correct balance ever provided to Plaintiffs to make it possible to cure debt.
NO accounting of the proceeds from the sale are ever done or provided.
On questions regarding the fraudulent charges, the illegality of the entire process of the hostile takeover of Plaintiffs restaurant, and the disposition of Plaintiffs property and SBA collateral, Plaintiffs are threatened bodily harm by defendant Teerink and informed that billionaires with political connections can do whatever they want and if Plaintiffs do not accept what is served upon them, Plaintiffs will face their very own personal Armageddon.
The Bank and Robson Affiliates use Plaintiffs’ immigration status as the weapon against Plaintiffs.
Plaintiffs are E-2 Treaty Investor Visa holders.
At the time of the lockout Plaintiffs’ ability to live in the USA depends on keeping successful business running and providing employment for American citizens.
Stripped of their business and wealth, Plaintiffs must leave the country.
Robson Affiliates and The Bank want Plaintiffs forced out of the country to prevent any future problems and lawsuits. Ex 24 Plaintiffs E-2 Visa | Ex 25 E-2 Visa Rules.
Defendants Robson Affiliates, counting on Plaintiffs’ limited legal knowledge and immigration status, coupled with the long 13 months’ rent abatement period feel safe, assured that in a year and a half, when the fraud is discovered, Plaintiffs’ faced with a fiat of accompli will be devastated, but will have no evidence to prove the fraud they have fallen victims to and will be forced to pay whatever is served upon them for the next ten years as the contract does not specify NNN charges, facing financial ruin and deportation if they refuse to submit to defendants’ Robson Affiliates extortion.
Plaintiffs are not the only ones Robson Affiliates have conspired to extort and defraud.
The Better Business Bureau has similar complaints regarding defendants’ Robson Affiliates shady and unethical business practices.

STRING ALONG FRAUD

Defendants Robson Affiliates and The Brokers have gaslighted Plaintiffs to enrich themselves during this horrific pandemic.
The process is further disrupted due to Defendants Robson Affiliates refusal to release any of Plaintiffs’ both paper and electronic files and records, that could potentially incriminate Defendants Robson Affiliates, The Brokers, The Bank, and be used in court to prove Defendants Robson Affiliates, The Brokers and The Bank fraud, lies and deceit.
All files, at the time of the lockout, are stored, as required by law, at 9542 E. Riggs rd. in Sun Lakes.
All is sold, given away or disposed by Defendants Robson Affiliates and The Bank. After the lockout, unknown individuals are given unlimited and unsupervised access to all of Plaintiffs’ personal, private, and business files including sensitive information about Plaintiffs’ employees, SS Numbers, phone records, customers information records, medical records, tax records and so on.
Defendants Robson Affiliates refuse to release the backup drives with Plaintiffs’ personal information, business files and camera footage.
Recently Plaintiffs were informed that Plaintiff’s identity was compromised and used in an attempt to defraud Department of Economic Security. Ex 26 Identity Theft.

PLAINTIFFS AS GUARANTORS SUFFERED INJURY, THUS PLEADING FOR REMEDY

This Complaint arises independently of the lease contract because main allegations addressing the fraud in the inducement and fraud in factum refer to pre-contractual negotiations meant to induce Plaintiffs to sign lease guarantee.
Conversion of third-party property, theft of Plaintiffs’ exempt by law property, unauthorized release of electronic records and tampering with Plaintiff’s computers are corollary offenses. A.R.S §13-2310(A; B; C)
All debt and other obligations fall back on Plaintiffs who signed personal guarantee for every credit card, SBA loan and promissory note issued prior, during and after being fraudulently induced to sign the lease guarantee and the contract.
Defendants’ fraudulent actions caused Plaintiffs to amass a huge debt at no fault of Plaintiffs.

CLAIM 1: Fraud in The Inducement

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows: Plaintiffs never owed Defendants Robson Affiliates the alleged sum of $60,039.48 even less $100,810.68.
Defendants Robson Affiliates and The Brokers intentionally make a false representation of NNN costs. Ex 27; Final Offer.
Defendants Robson Affiliates and The Brokers represented $8.15sq.ft. or $2,241.25 in NNN charges to Plaintiffs.
Plaintiffs agree to pay $8.15sq.ft.; or $2,241.25/month. Ex 27; LOI.
Plaintiffs do not and would never agree to the doubled NNN charges of $16.52sq.ft. or $4,541.67/month. Ex 28; Charges.
Robson Affiliates and The Brokers have knowledge the representation is false.
Property taxes alone in 2018 are $1,998.90.
Defendants Robson Affiliates and The Brokers have indisputable knowledge of the total NNN cost including water being ca. $4,500 monthly not $2,241.25.
There is no doubt this misrepresentation is premediated, intentional and with the knowledge of being false when the statement is made. Ex 29; First Statement.

Defendants Robson Affiliates and The Brokers made the representations with the intent of inducing Plaintiffs to sign the Lease guarantee.

Plaintiffs make it very clear, in writing, from the very beginning, that they have very limited funds, the location is challenging, the NNN must not exceed $2,300, it is a fact. Exhibit 5
Plaintiffs are seasoned restaurateurs.
Plaintiffs would have never signed lease guarantee if properly informed about the true NNN costs.
Plaintiffs reasonably relied on the misrepresentations when entering the Lease guarantee.
Relying on this misrepresentation to be true, Plaintiffs sold their restaurant in Mesa and invest hundreds of thousands of dollars in the new premise.
of Defendants Robson Affiliates and The Brokers conducts, Plaintiffs suffer hardship of gigantic proportion.
Plaintiffs signed personal guarantees for loans, credit cards and promissory notes.
Plaintiffs as individuals suffered loss of their life savings, investments and an unmanageable debt, total loss of income, non-monetary losses, all previously mentioned injuries combined with Plaintiffs’ age, makes future recovery, and return to normal life impossible without relief from this Court.
Defendants Robson Affiliates and The Brokers conduct caused Plaintiffs EXTREME mental suffering and Emotional Distress on top of the financial catastrophe
Over $456,500 of Plaintiffs property has been converted/stolen by Defendants Robson Affiliates.
Plaintiffs suffered monetary Injuries due to Defendants Robson Affiliates and The Brokers conduct.

CLAIM 2: Fraud in Factum

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Defendants Robson Affiliates the alleged sum of $60,039.48 even less $100,810.68.
By altering written instrument without proper authorization, and using it in an extortion attempt and conversion of Plaintiffs $456,500 worth of property, depriving Plaintiffs of livelihood defendants violate Civil Code: A.R.S. §47-1202 | A.R.S. §47-3104(A2) | A.R.S. §47-3114 | A.R.S. §47-1304 | A.R.S. §47-3103(A4; A6; A9) | A.R.S §47-3106(A) | and Criminal Code: A.R.S. §13-2001(5;8) | A.R.S. §13-2310(A; B; C) | A.R.S. §13-2002(A1; A3; C) | A.R.S. §13-1804(3;4;8).
March 22, 2019, 6.42am. After months of adjustments and back and forth negotiations, Michael sent the final version of the lease agreement to be signed for review. Exhibit 30, Email
Defendants’ Robson Affiliates work PRIOR to delivery of the building is defined. Ex 31 Approved p32
March 24, 2019, 12.31pm Plaintiffs point out that the ice maker is still missing in the” Landlord’s work” clause as well reimbursement. Ex 32; Missing icemaker.

Defendant Michael Robson assures that the ice maker and the 30 days reimbursement clause will be promptly added to the landlord’s work prior to delivery fixture/furniture contract clause when Plaintiffs arrive March 25, 2019, latest at 3pm to sign the lease guarantee and lease.

March 25, 2019, 11.26am Michael Robson according to agreement orders defendant Gulsvig to add the missing icemaker and the 30 days reimbursement clause before Plaintiffs arrive to sign the lease.
The language of the Vice President of Robson Community, Inc. Michael Robson is pure and unambiguous; “$11,028.25 to be reimbursed within 30 days of the following: Landlord’s receipt of paid invoice and Tenant opening for business”. Ex 33; TIA Reimbursement
March 25, 2019, 12.25pm, Plaintiffs are on their way to sign final version of the contract approved just 24 hours earlier.
Defendants Gulsvig, Robson Affiliates and The Brokers without Plaintiffs’ knowledge and approval, remove landlord’s work prior to delivery pages, alter the contract and change landlord’s work PRIOR to delivery clause to a one-year reimbursement timeframe conditioned on Plaintiffs perfect performance. Ex 34; Forged p30.
she has no right to alter the terms of the contract without prior consent of both parties.

March 25, 2019, around 3pm Plaintiffs arrive at defendant Ellsworth office.
Ellsworth prints the lease and the lease guarantee and reassures Plaintiffs the lease has the same conditions as the one approved 24 hours earlier.
Ellsworth asks Plaintiffs to sign the lease ON THE LAST PAGE ONLY.
Ellsworth reminds Plaintiffs to sign the lease guarantee.
To Plaintiffs’ detriment, Ellsworth does not utter a word about the alteration made after Plaintiffs final approval of the contract, thus aiding Robson Affiliates in their illegal conduct and securing payment of his double commission. Ex 35; Scott commission.
The contract and the personal guarantee is sent to R.N.S. Limited Partnership for signage.
Defendant Paula Robinson does not inform Plaintiffs about the alteration either.
October 29, 2020, after Plaintiffs’ refusal to reconcile with the extortion, Defendants Robson Affiliates legal counsel Gulsvig lies and denies her own alteration and forgery, using the forged instrument in an extortion scheme to confiscate Plaintiffs entire property. Ex 36; Gulsvig-no discrepancies.
Defendants violate Criminal Code A.R.S. §13-1804A(3;4;8)
Plaintiffs suffered monetary Injuries due to Defendants Gulsvig, Robson Affiliates and The Brokers conduct

CLAIM 3: Promissory Estoppel 1 / Promissory Fraud
Tenant Improvements Allowance Reimbursement

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Defendants Robson Affiliates the alleged sum of $60,039.48 even less $100,810.68.
March 25, 2019, Defendant Michael Robson makes a promise: “Landlord shall reimburse Tenant for Tenant’s work in the amount equal or less than $11,028.12. This Tenant improvement Allowance shall be paid by Landlord to tenant within thirty (30) days of the following: Landlord’s receipt of paid invoice and Tenant opening for business.” Ex 37; TIA.
Plaintiffs rely on the promise being binding as it is in writing and ruled by statute A.R.S. §47-3104(A)
June 11, 2019, Plaintiffs provide Defendants Michael with receipts. Ex 38: Providing receipts
June 21, 2019, defendant Michael Robson, reaffirms the promise, via text message approving reimbursement of Tenant Improvements Allowance. Exhibit 39; SMS Contradictory Instrument is ruled by A.R.S. §47-3104 | A.R.S. §47-3114
The promise is in writing, thus binding, is agreed upon during the pre-contractual negotiations and confirmed twice in writing by defendant Michael Robson.
Promisee is protected by Arizona Statute, and it is customarily settled in Arizona that the Tenant Improvement Allowance is paid within 30 (thirty) days of Landlord’s receipt of paid invoice.
It is unheard of 1 year waiting time for TIA reimbursement conditioned on perfect performance.
Plaintiffs never heard about such a condition and would never accept such a condition.
Plaintiffs suffered monetary Injuries due to Defendants Michael Robson and Robson Affiliates conduct.

CLAIM 4: Promissory Estoppel 2: Withdrawn Covid Aid: written

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed defendants Robson Affiliates the alleged sum of $60,039.48 even less $100,810.68.
July 24, 2020, Defendants Robson Affiliates propose Covid-19 aid. Exhibit 40; Covid Aid | Ex 41; First Invoice | Ex 42; 100,810.68 Invoice | A.R.S. §44-101
No Rent: August 01, 2020, through December 31, 2020.
The remaining balance to be amortized over reminder of the lease term (9 years).
The addendum to be delivered for signage
The offer is signed and in writing, thus legally binding.
In late February 2020, mere 5 months after the full opening of the restaurant, the COVID-19 global pandemic takes hold in the United States.
Defendants Robson Affiliates proposed Covid Aid is in line with the rest of the world due to the raging pandemic.
The offer is signed and in writing, thus legally binding. A.R.S. §44-101 | A.R.S. §47-2206.
October 12, 2020, the written promise is verbally withdrawn by defendants Robson Affiliates representative Teerink and the incorrect alleged delinquency of $60,039.48 is requested to be paid immediately.
February 2021 the alleged delinquency of $100,810.68 is requested to be paid immediately.
October 19, 2020, Defendants Robson Affiliates perform lockout, depriving Plaintiffs of their entire property and livelihood.
Defendants Robson Affiliates request, again, the incorrect $60,039.48 balance to be paid in full immediately to reenter the premise.
Defendant Gulsvig refuse to adhere to accepted offer, instead referring to her forged contract as binding. Ex 43; Final Offer | Ex 44; TIA reimbursement | Ex 45; Gulsvig no discrepancies.
Plaintiffs suffered monetary Injuries due to Defendants Teerink, Gulsvig and Robson Affiliates conduct.

CLAIM 5: Promissory Estoppel 3: Withdrawn verbal Covid Aid

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Defendants Edward and Karrin Robson come to Plaintiffs’ restaurant assuring Plaintiffs not to worry, promising the help being on the way.
The promise is July 24, 2020, confirmed in writing, thus legally binding.
Plaintiffs assume, that what was promised by defendants Edwards Robson and Karrin Taylor Robson was materialized in writing July 24, 2020.
October 12, 2020, defendant Teerink claims the visit and promise never took place. Ex 46; Covid Aid.
Defendants Edward and Karrin Robson promise materializes in writing July 24, 2020.
Given Covid-19 circumstances, Plaintiffs took their promise as true and binding.
October 12, 2020, the verbal, and the written promise is withdrawn.
October 19, 2020, Defendants Robson Affiliates perform lockout.
Plaintiffs’ property is confiscated, access to personal financial files is denied as well as the release of all third-party property.
Plaintiffs’ personal sensitive information as well as employees’ sensitive information and business financial records are being released to unknown individuals.
Plaintiffs suffered monetary damages due to Defendants Robson Affiliates, Edward and Karrin and Robson Affiliates conduct.

CLAIM 6: Mock Auction

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Defendants Robson Affiliates the alleged sum of $60,039.48 even less $100,810.68.
Nobody was allowed to see or inspect the equipment.
Robson Affiliates is the only bidder who need to satisfy the $5,400 max offer for the entire content of the restaurant, provided to them by Melton-the new tenant.
Henderson wrote: “ONLY MAJOR EQUIPMENT is captured” for sale.
Thus, the rest is given away.
Only ca 10% of the equipment is listed the rest is given away.
The “forced sale” desktop appraisal is valued to be $12,000
The Bank releases SBA loan collateral lien to Robson Affiliates and its associates to the discounted $9,000.00.
$4,500 or 50% is credited back to the Robson Affiliates. (the only bidder) for storage, even though Robson Affiliates held the SBA collateral hostage from October 19, 2020. Exhibit 47; Lien release.
Plaintiffs suffered monetary damages due to Defendants Henderson, Gulsvig, Teerink, Robson Affiliates and The Bank conduct.

CLAIM 7: Conversion 1: Plaintiffs Personal Property + Tenant Improvements

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Robson Affiliates the alleged sum of $60,039.48 even less over $100,000.00.
Defendants Robson Affiliates and The Brokers fraudulently induced Plaintiffs to sign lease and lease Guarantee and altered the lease after Plaintiffs signed it.
Plaintiffs never owed Defendants Robson Affiliates alleged over $100,000.00. Exhibit 48; Payment Schedule.
Defendants Robson Affiliates and The Bank Conversion by Wrongful Act Inconsistent with The Property Rights of Plaintiffs’.
Plaintiffs suffered monetary damages due to Defendants Robson Affiliates, The Bank and The Brokers conduct.

CLAIM 8: Conversion 2: Exempt Property

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Robson Affiliates the alleged sum of $60,039.48 even less the later claimed over $100,000.00.
Arizona Statue Tile 33, Chapter 8 Protects Exempt Property from being seized by Defendants Robson Affiliates and The Bank
Defendants Robson Affiliates and The Bank Conversion by Wrongful Act Inconsistent with The Property Rights of Plaintiffs’. Ex 49; Asking for food and chest freezers
Plaintiffs suffered monetary damages due to Defendants Robson Affiliates and The Bank conduct.

CLAIM 9: Theft of financial records and cash intended to pay TPT and Payroll taxes + accounting charges to prepare tax filings + penalties

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Robson Affiliates the alleged sum of $60,039.48 even less over $100,000.00.
Arizona Statue Tile 33, Chapter 8 Protects Exempt Property from being seized by defendants. A.R.S. §33-1123.
Robson Affiliates and The Bank Conversion by Wrongful Act Inconsistent with The Property Rights of The Plaintiff.
Plaintiffs’ identities got compromised.
All Financial records, both business and private has been stolen and compromised.
Plaintiffs suffered monetary damages due to Defendants Robson Affiliates and The Bank conduct.

CLAIM 10: Unjust Enrichment – In the Alternative

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, in the alternative to Claims 1-8, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Robson Affiliates the alleged sum of $60,039.48 even less over $100,000.00.
During the negotiations both parties agree to invest equally. Ex 50; Equal Investment.
The Defendants Robson Affiliates received a benefit.
Plaintiffs spend more than $60,000 on cleaning and construction.
Plaintiffs bring in $300,000 equipment.
$100,000 of Plaintiffs Exempt Property is stolen.
Defendants Robson Affiliates never reimbursed Tenant Improvements Allowance.
Defendants Robson Affiliates steal purchased by Plaintiffs’ TIA property, keeping both the funds and the property.
Over $8,000 TIA Dining furniture purchased using Plaintiffs personal credit cards gets transferred to Plaintiffs via a mock auction for $550.00 or 6.8% of what Plaintiffs paid.
$10,000 in third party property personally guaranteed by Plaintiffs is stolen.
Defendants Robson Affiliates steal cash designated to pay TPT and Payroll Taxes.
The Defendants Robson Affiliate received a benefit at the Plaintiff’s expense.
Plaintiffs purchased all property using personal funds.
Plaintiffs cleaned, renovated, and fully equipped restaurant that Defendants Robson Affiliates now can lease to a new tenant after October 19, 2020, lockout.
Under circumstances that it would be unjust for the Defendants Robson Affiliates to retain the benefit without commensurate compensation.
Should Plaintiffs’ other causes of action fail, Plaintiff is without an adequate remedy and Defendants shall be enriched to the detriment and impoverishment of Plaintiffs.
Plaintiffs never owed Robson Affiliates the alleged over $100,000.00 to the contrary according to accepted terms and the payment schedule defendants owe Plaintiffs $983.33. Exhibit 51 Payment Schedule.
Plaintiffs suffered monetary damages due to Defendants Robson Affiliates conduct.

CLAIM 11: Loss of Future Income

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Robson Affiliates the alleged sum of $60,039.48 even less over $100,000.00.
Plaintiffs created one of the most successful and awarded restaurants in the Valley, were featured on Food Network, Cooking Channel, Check Please Arizona and all major media outlets.
Plaintiffs were finalists in the Shark Tank, but Covid hit and all restaurants were out of picture.
There was an enormous potential for growth which Defendants Robson Affiliates, The Brokers and The Bank actions nullified through their wrongful, illegal, and fraudulent conduct.
Plaintiffs suffered monetary damages due to Defendants Robson Affiliates, The Brokers and The Bank conduct.

CLAIM 12: Intentional infliction of emotional distress

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Robson Affiliates the alleged sum of $60,039.48 even less over $100,000.00.
Defendants Robson Affiliates and The Brokers are experienced in the real estate business.
Defendants Robson Affiliates have made fortune doing it in the last 40 years, fully aware of their actions when committing fraud and brazenly defying the law.
Defendants Robson Affiliates, and The Brokers intentionally misrepresented the true cost of the NNN.
Defendants Robson Affiliates and The Brokers intentionally altered/forged the lease.
Defendants Robson Affiliates and The Bank intentionally disposed Plaintiff’s food supply during the pandemic.
Defendants Robson Affiliates and The Bank intentionally deprived Plaintiffs of their livelihood.
Defendants Robson Affiliates and The Bank intentionally converted/stole Plaintiffs entire property.
Defendants Robson Affiliates and The Bank intentionally tossed away Plaintiffs most cherished souvenirs and memorable and awards.
Defendants Robson Affiliates, The Bank and The Brokers conduct must be extreme and outrageous.
Defendants Robson Affiliates are billionaires, they own properties in seize of cities.
The systematic and consistent efforts to cover up and to ensure complete immunity from deliberately and knowingly committed fraud is well planned and masterly executed.
Instead of trying to correct the fraudulent behavior, Defendants Robson Affiliates continue to double down on their lies and unfounded accusations.
The conduct is clearly displayed in their lied filled response to AG.
Plaintiffs have suffered severe emotional distress as a result of Defendants Robson Affiliates, The Brokers and The Bank conduct.
Plaintiffs, extremely successful, happy couple, living out their American Dream, suddenly are struck by this string along fraud.
After being deprived of livelihood and property Plaintiffs live in constant need of therapy and medication, Plaintiffs suffer from constant suicide thoughts and depression, caused by Defendants Robson Affiliates, The Brokers and The Bank never ending lies, and threats.
Plaintiffs have suffered severe emotional distress as a result of Defendants Robson Affiliates, The Brokers and The Bank conduct.

CLAIM 13: Defamation

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Robson Affiliates the alleged sum of $60,039.48 even less over $100,000.00.
February 8, 2021, Defendants Robson Affiliates and The Bank made public that Plaintiffs’ property is being given away and sold to unknown individuals due to nonpayment.
Even the most sensitive information and private belongings are being released.
Pictures and videos with strangers carrying out personal belonging available upon request.
This irreparably ruined Plaintiff’s reputation and exposed Plaintiffs to ridicule.
Plaintiffs’ file Consumer Fraud Complaint to Attorney General Office.
In their response to Attorney General Office Defendants Robson Affiliates lie providing several false statements.
Defendants Gulsvig and Robson Affiliates made libelous claim about Plaintiffs’ defaulting on SBA Loan when The Bank contacted them regarding release of the SBA Collateral.
This is a lie.
Plaintiffs were not in default and not even late with loan payments.
Plaintiffs were current on loan payments.
Defendants Gulsvig and Robson Affiliates made libelous claim about Plaintiffs’ owing Defendants Robson Affiliates the astronomical sum well more than $100,000.00 despite Defendants Robson Affiliates and The Bank confiscation of Plaintiffs entire property.
This is a lie.
Plaintiffs never owed Defendants Robson Affiliates any money.
Defendants Robson Affiliates owed Plaintiffs $983.33. Exhibit 51; Payment schedule.
Defendants Robson Affiliates know that the statements are false.
Defendants Robson Affiliates act in a reckless disregard of the truth.
Defendants Robson Affiliates know, especially Defendant Gulsvig, who personally altered the lease, that the lease was doctored after Plaintiffs signed it.
That’s why Defendants Robson Affiliates did not want to use DocuSign.
DocuSign would make the removal of the note and the page swap impossible. DocuSign would make future theft of Plaintiffs entire property unachievable.
Defendants The Brokers and Robson Affiliates know that they fraudulently induced Plaintiffs to sign the lease and the lease guarantee.
Defendants Robson Affiliates know that Plaintiffs did not owe them money.
Defendants Robson Affiliates and The Bank knew that Plaintiffs were current on SBA Loan Payments.
Defendants Robson Affiliates and The Bank knew that they breached all Arizona statutes by confiscating Plaintiffs personal property, exempt by law property and third-party property bypassing judicial system and the rule of law in its entirety.
After Plaintiffs filed Consumer Complaint instead of apologizing and trying to repair the harm and damage caused to Plaintiff, Defendants Robson Affiliates doubled down on lies, false accusations and fabricated claims alleging enormous debt Plaintiffs never owed to defendants, smearing Plaintiffs’ name with accusations of defaulting on the SBA loan.
Plaintiffs suffered monetary damages due to Defendants Robson Affiliates, The Brokers and The Bank conduct.

CLAIM 14: Civil Conspiracy

Plaintiffs adopt and reassert the foregoing allegations and further for its cause of action, should facts be proven which support this cause of action, allege as follows.
Plaintiffs never owed Robson Affiliates the alleged sum of $60,039.48 even less over $100,000.00
The Bank transfer over $450,000.00 worth of Plaintiffs property to Defendants Robson Affiliates for $4,500.00 1% (ONE percent of its fair market value).
This is an illegal act and must be thoroughly investigated during the discovery process.
During this unlawful act Conspirators breached all applicable Arizona statues.
The correct outstanding balance to cure debt (if any) was never delivered.
Required by law notices were never delivered.
The commercially reasonable sale was never performed.
The public auction was never done.
The exempt by law property was never released.
The Third-party property was never released.
Plaintiffs’ sensitive information protected by law, i.e. Plaintiffs’ passport and financial files, were released causing Plaintiffs’ identity being stolen.
The scope of this action is still undetected.
SBA collateral was never released, and SBA was defrauded by The Bank who first refused to claim collateral and later transferred the collateral for a fraction of the market value causing both Plaintiffs and the SBA to amass huge losses.
The joint efforts of The Bank and Robson Affiliates are reminiscent of two dirty gangsters from the thirties who help each other get extortion money from businesses.
If someone refuses to obey, he/she must be completely obliterated as a warning to others.
This is exactly what happened in Plaintiffs’ case.
Plaintiffs refused to pay the extortionist.
Therefore, Defendants Robson Affiliates and The Bank have turned their happy lives into a hell on earth by depriving them of all their wealth of life.
The best evidence clearly displaying Defendants Robson Affiliates and The Bank lies, civil conspiracy, and evil mind is their two responses to the Consumer Fraud Complaint filed by Plaintiffs to Attorney General Office.
There is not a one sentence in the Two Reponses to Attorney General Office that is true.
The two letters consist of a string of never-ending lies, false accusations, and alternative facts.
Plaintiffs suffered monetary damages due to Defendants Robson Affiliates, The Brokers and The Bank conduct.