11-2548P

FIRST INSERTION
SECOND AMENDED COMPLAINT AND JURY DEMAND
UNITED STATES DISTRICT COURT
District of Nevada
Case No. 3:11-cv-00210-RCJ-VPC
NOTICE TO:
CITRON INVESTMENT GROUP, INC., MICHAEL CITRON, and DANIELLE CITRON
10545 Baracoa Court
Trinity, FL 34655
YOU HAVE BEEN SUED IN THE FOLLOWING MATTER:
LEONARD C. ADAMS, et al.,
Plaintiffs, v.
SILAR ADVISORS, LP, SILAR ADVISORS, LP, COMPASS
PARTNERS, LLC, COMPASS USA SPE, LLC, COMPASS FINANCIAL PARTNERS, LLC, COMPASS
FINANCIAL PARTNERS LLC,
COMPASS FP CORP., COMPASS USA HOLDING, LLC, COMPASS USA, LP, COMPASS USA GP, LLC,
LEONARD MEZEI, DAVID BLATT,
BORIS PISKUN, JAY COHEN, RON FRIEDMAN, SILAR SPECIAL
OPPORTUNITIES FUND, LP,
SMOF A, LLC, SSOP, LLC, ROBERT LEEDS, JAY GRACIN, HIN-KING TAI, CADE LIU, MARK OLSON, WINDEMERE CAPITAL, LLC, OAKBRIDGE CAPITAL INC.,
ECONOMIC GROWTH GROUP, INC., REPOTEX, INC.,
SERVICING OVERSIGHT
SOLUTIONS, LLC, MICHAEL REINER, TYSON LOMAZOW,
CITRON INVESTMENT GROUP, INC., MICHAEL CITRON, and
DANIELLE CITRON,
Defendants.
A lawsuit has been filed against you. The lawsuit alleges the following claims: (1) Violation of Racketeer Influenced and Corrupt Organization Act (RICO) pursuant to 18 §1861, et seq.; (2) Violations of Nevada's Anti-Racketeering Law pursuant to N.R.S. §207.380;
(3) Elder Abuse pursuant to N.R.S. §44.1395(1),(4); (4) Conversion; (5) Civil Conspiracy; and (6) Constructive Trust.
The lawsuit seeks the following relief from each of you, as defendants to the lawsuit: (1) Actual, compensatory, consequential, double, and treble damages in accordance with their fractional beneficial interests in the Loans in an amount to be determined at trial; (2) Punitive damages in an amount to be determined at trial; (3) Costs of Court; (4) Reasonable attorneys' fees and costs incurred by Plaintiffs herein and on any appeal; (5) Pre- and post-judgment interest at the highest lawful rates; (6) The imposition of a constructive trust on funds improperly retained by Defendants to which they are not entitled; and (7) Such other and further relief to which Plaintiffs and the members of the class may be entitled and which this Court deems just and proper.
Within 21 days after notice of this Complaint on you (not counting the day you received it) — or 60 days if you are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ. P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney
whose name and address are:
Lisa A. Rasmussen, Esq.
Law Office of Lisa Rasmussen
601 South 10th Street, Suite 100
Las Vegas, NV 89101
Tel. (702) 471-1436
If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint. You also must file your answer or motion with the court.
The summons naming you as defendants was issued by the Clerk of the Court, United States District Court, District of Nevada, on April 6, 2011.
This service by publication is made pursuant to N.R.C.P. 4(e)(1)(iii).
December 9, 16, 23, 30, 2011 11-2548P