The Plaintiffs plead that the Syndicate should have been, or were aware of their victims’ ages, and mental infirmity during their communications, and as such induced the Plaintiffs to purchase items they knew or ought to have known the victims had no reason to purchase, and seized on the opportunity to engage in deceptive sales practices.

The Plaintiffs did not receive the monies represented by the Syndicate, nor any of the extravagant prizes promised to them, the provisions of which were essential terms of the contracts between the parties.

In the alternative, the Plaintiffs plead that the failure of the Syndicate to fulfill their obligations under their oral contracts constitutes a fundamental breach of these contracts, entitling the Plaintiffs to rescission, or in the alternative, damages.

The Syndicate have conspired together at various times only known to the Syndicate and between themselves to design and implement and act upon a telemarketing program designed to specifically target buyers who are elderly, easily intimidated, misled or unable to appreciate the nature and degree of the representations being made, and to defraud these persons, which include the Plaintiffs, of money. The Plaintiffs suffered and claim damages arising from this conspiracy.

The Plaintiffs plead that at all material times, they were unable to appreciate the nature and effect of any contracts, which they may have entered into.

An example of an especially vulnerable person would be a grieving widow, who --- according to experts --- has temporarily lost her normal decision-making abilities.

The Plaintiffs plead and rely upon the legal doctrines of non est factum and consensus ad idem.

The Plaintiffs plead that the conduct of the Syndicate was unconscionable, and accordingly these oral contracts should be set aside.

The Plaintiffs further plead the conduct of the Syndicate was fraudulent, and that they suffered damages thereby, being the monies paid to the Syndicate and emotional upset, trauma and distress.

The activities of the Syndicate that are complained of herein have resulted in the deterioration of the physical health of all of the Plaintiffs. The Syndicate knew, or ought to have known, that their activities would have consequently impacted on the health and well being of all of the Plaintiffs.

The Syndicate uses a myriad of corporate shells in order to create an appearance that there are unrelated outfits defrauding the Plaintiffs. Further, the Syndicate made efforts to avoid liability by using corporate shells.

In reality, the myriad of corporate shells is merely used by the Syndicate to confuse victims, victims’ investigators, and the police authorities.

The Syndicate used a number of pretexts or "scripts" to convince their victims and the Plaintiffs to send money to the Syndicate. Aside from names, amount, dates and times of these calls, the other particulars of representations made to the Plaintiffs are very similar to the representations made to the Plaintiff Gibbons referred to within this Claim.

After corporate identities are received from the Quebec government, most of the Syndicate’s telemarketing corporations fell into a "Default of Article 29" designation, indicating that they failed to file further information as required by Quebec.

The Syndicate freely abandons company names, offices, and corporate shells within a few months, moving on to another location, but using many of their members and continue to defraud the elderly, the naive, and the vulnerable members of society, such as the Plaintiffs.

The Syndicate, in the course of their telephone solicitation activities, uses different companies, business names and a variety of individuals to contact prospective victims throughout Canada by telephone.

The Syndicate’s modus operandi is as follows: Once a prospective victim is located, the victim is induced to make payments by representations that he or she is in a position to receive a specific benefit, the nature of which varies from victim to victim, but includes representations that the victim has won an extravagant prize or prizes, and/or is able to purchase expensive goods at a nominal cost, and/or has been chosen to receive an expense gift, or cash.

Once the victim expresses an interest in receiving the prize or benefit, they were told they would be notified later as to how to claim the benefit.

Later, other members of the Syndicate contacted the victims, and told the victims that to receive the benefit, some form of up-front administration fees, taxes, or other charges must be paid by the victim to the Syndicate or one of its members.

Some telemarketers working for the Syndicate stated that they were working to recover monies previously lost by Plaintiffs and other victims to the Syndicate.

Some telemarketers working for the Syndicate stated that they were lawyers or authorities who had seized monies on behalf of victims and the Plaintiffs.

Some telemarketers working for the Syndicate stated that they were government, or charitable organizations.

The Syndicate placed unsolicited telephone calls and solicitations to the Plaintiffs and falsely described themselves as "award-centers."

Between 1994 and 1998, as a result of the promises, solicitations and representations made by members of the Syndicate, the Plaintiffs sent various amounts of money to the Syndicate, with the anticipation of receiving prizes, awards and other benefits, which were, in fact, not forthcoming.

After receiving money from victims, the Syndicate sent out unordered merchandise of relatively little value in order to make it appear as if the victims simply purchased merchandise.

Particulars of the Syndicate’s activities against the Plaintiffs have been described in the popular press.

On or about 9 May 1997, The Toronto Sun, in an article titled, "Cops Warn Of Phone Scams," stated;

Police warned yesterday that Montreal -based scam artists again are slipping their slimy fingers into the pocketbooks of the unwary in the Metro area.

Durham Regional Police said a 76-year-old Oshawa woman was told by a telemarketing con man she had won $ 1.2 million, but the victim had to send them a $ 5,000 bank draft to pay the luxury tax on her winnings.

After sending the draft, the Montreal -based con operation called again saying a mistake was made and she had to send more cash. And later more money. In all, the woman was tricked into sending $ 200,000. Police have been unable to track down the culprits.

Police said winners never have to dole out money to claim a large, extravagant prize in legitimate contests, and to never give credit card numbers or other personal information over the phone.

On or about 13 February 1998, the Dallas Morning News stated:

Working out of Canada is the latest wrinkle in the telemarketing fraud game, which is estimated to rake in $ 40 billion annually. Some $ 50 million of that total is collected by Canadian perpetrators who play upon jurisdictional complications to avoid prosecution in our country and their own.

One reformed (fraudulent) telemarketing operator described his former colleagues as drug addicts who really needed the money and were able to read people like a psychiatrist. Gearing their pitch to the needs and nest egg of each potential victim, the boiler-room "yacks" weave fact and fiction in ways most novelists can only dream about.

Frequently, as in your case, they title their company, contest and products after familiar-sounding entities in order to give them legitimacy, and even throw in details such as a check number.

Had you fallen for the scam, you’d be ripe for what insiders call a "recovery room" pitch, in which the scammers claim they can recover your loss from the phony sweepstakes people - for yet another advance fee.

Another bunco [scam] alert are those calls from people claiming to represent the Publishers' Clearinghouse Sweepstakes, that legitimate company famous for its Super Bowl Sunday Prize Patrol, which tends to surprise little old ladies with multimillion-dollar windfalls. In such scam calls, the senior citizen is told Ed McMahon is going to deliver the prize himself and even take him or her to lunch! Then comes the caveat: the prepayment of federal taxes, amounting to between $ 20,000 and $ 270,000, depending upon the perception of the pigeon's ability to pay.

On or about 17 June 1998, representative of the Luizos law firm discovered documents from telemarketing boiler rooms at 5250 Decarie Suite 410 and at 8455 Decarie Blvd showing the similar handwriting from the following personations:

Hope Evans, Hope Winters, Hope Waters, Holly, Gina Evans, Janice Stevens

A female identifying herself as the manager at a boiler room called Sunflower Inc. stated that telemarketers use false names "as a policy."

Many of the personal and business names used by the Syndicate’s telemarketers as referenced within this Claim were false and were intended to deceive victims.

The Syndicate uses similar sounding names to that of legitimate companies in order to mislead the Syndicate’s victims into thinking that the Syndicate’s telemarketers are completely legitimate. For example, the Syndicate uses the names "Columbia Group" and "Publisher’s Digest" which are similar to the legitimate companies named "Columbia House" and "Readers Digest."

Police records show that the Syndicate’s telephone number (514) 395-2300 has been used under the following Syndicate telemarketers using these organizational names:

Canadian Lottery Commission, Consumer Group Protection Agency, Revenue Canada, Pro Detail Group Inc., 

Consumer Business Recovery, Consumer Affairs of Canada, Columbia Group, Consumer Group, Bonanza Group,

Canadian Consumer Group, Consumer Group of Canada, First District Court House, Consumer Protection Agency,

Incentive International, Kyle Pendleton, Normes De Travail

On or about February 1998, the RCMP raided a Syndicate telemarketing boiler room in Montreal, Quebec and arrested 9 individuals: Tom Altenburg, Lisa Goldenberg Karp, Dawn Pamela Blake, Cathy Moore, Ted Grossbaum, Pamela Ann Gordon, Andres Tousignant, Richard Narik and Kimberly Dupigny.

Tom Altenburg (also known as, and referred to herein as "Thomas Altenburg") is Blake’s boyfriend and Tom Altentburg is a leader within the Syndicate. Even after their arrest, Blake continued to work with Altenburg.

Blake told her family that she was no longer working at telemarketing outfits. However, a document subsequently found just outside Altenburg’s office at 8600 Decarie, Ste 102, indicates Blake was still involved with the Syndicate’s telemarketing operations.

Suite 126, 1015 Beaver Hall Hill, Montreal, QC is an empty office used as a courier drop site by telemarketing operators working out of 505 Rene Levesque, Ste. 1510. This location is where several telemarketers named herein as being arrested by the RCMP were active.

Dino Del Grosso, Mario Del Grosso, Ian Herman, Marc Anthony Babierri, Herwig Radlgruber, Ted Grossbaum and Morris Weinstein were supervisors of the notorious Syndicate telemarketing boiler room located at Suite 410, 5250 Decarie Blvd, Montreal (hereinafter referred to as "Suite 410.")

Government records show that the Defendant Herwig Radlgruber was the director behind "Publisher’s Digest," "Reader’s Clearing Center", and "Canadian Household Distribution."

After Suite 410 closed its operations, telemarketing victims who sent monies to Suite 410 were further telemarketed by other branches of the Syndicate including East Coast Trading, Heritage Group, and Sunflower Inc.

Ascenza Mancini is a resident 126 Ivan Stockwell, Pt. Claire, QC.

Ascenza Mancini willfully allows Dino Del Grosso to hide his assets under her name.

Dawn Carpenter, is an individual who was operating a boiler room under the name of Sunflower Inc., under the direction of the Syndicate. Dawn Carpenter and her husband Jordan Carpenter controlled the Syndicate’s account #80716 at the Caisse Populaire, Notre Dame de Gras, transit 30226.

Dawn Carpenter also operated the Syndicate’s bank accounts under the business name of Snow-Com Inc. Snow-Com Inc. used the address 5172 Queen Mary Road, Montreal. The Syndicate deposited victims’ payments into accounts under the name of Snow-Com Inc., at Caisse Populaire de Gras, account #810170 and Howlan Mills Realties Trust, account #810122.

As at 1998, Phonebusters had recorded 41 "attempts" by Sunflower, and a total of $72,000 taken from 13 victims.

Triple Crown Industries/Les Industries Triple Crown ("TC") is a business name registered to 9049-4824 Quebec Inc.

TC was registered on July 1997.

TC has a registered office at 4150 Sherbrooke West, Third Floor, Montreal, PQ, H3Z 1C2.

9054-4545 Quebec Inc. was registered on September 15, 1997.

East Coast Trading/Commerce Cote Est ("ECT") is a business name registered to 9054-4545 Quebec Inc., on January 1998.

The Plaintiffs plead that the same directing minds, working for the Syndicate, were behind ECT and TC. These directing minds created these corporations as part of their plan to deceive victims, authorities, and other parties pursuing fraudulent telemarketers.

9054-4545 Quebec Inc. has a registered office at 1010 La Gauchetiere West, Suite 1200, Montreal, H3B 2P9, c/o Mr. Melvin S. Kronish ("Kronish".)

The business names used by 9054-4545 were used prior to their registration with respect to the representations to victims.

Kronish is well known to police authorities for his activities in having incorporated many of the telemarketing outfits.

Carrie Finkelstein ("Finkelstein") is the president of ECT according to government records. Finkelstein resides at 175 Poplar, Dollard-Des-Ormeaux, H9A 2A5.

On or about 27 May 1998, a visit to ECT’s registered office showed that Kronish was not located there.

On or about 27 May 1998, ECT and TC did not have their companies listed on the building directory in which these companies purportedly do business.

On or about 27 May 1998, Shaw was manning the reception and telephone desk at the Greene Avenue location, answering the phone with the greeting, "corporate offices." Shaw identified herself as Shaw, and not Carrie Simon.

Shaw stated that Finkelstein was not present at the time. Shaw stated that Finkelstein was involved with the operation.

Various telemarketers were present, apparently ending their working day with a report to Shaw. When three persons from the Luizos law firm arrived, these telemarketers left quickly. One suspected female telemarketer was observed waiting outside the building in a BMW automobile.

The BMW’s ("BMW") Quebec license plate was 403 CZR

The BMW is owned by Susan Cohen Freedman, with a Date of Birth of September 12, 1952, and is a resident of 650 Carlton Avenue, Westmount, PQ, H3Y 2Y2.

Both TC and ECT use the same phone and fax number, which are 846-3323 and 846-3888 respectively.

According to phone directories, the telephone number 846-3323 is registered to S. Lerner, at 1259 St. Marc, Montreal, since 1996.

According to phone directories, the number 846-3888 is registered to Ricardo Paima, at 1000 Ste. Marguerite.

Heritage Group, ECT and TC are well known to police authorities.

"Macy’s," a department store, of Mason, Ohio, 45040-8058, USA, has records of purchases by "Ms. Finkelstein" at her Poplar address.

"The Fashion Bug," a clothing store chain in the USA has records of purchases by "Ms. Finkelstein" at her Poplar address.

I.D.C. ("IDC") is a courier company with offices at 240 Peel Street, an address used by ECT for receiving incoming mail.

ECT used IDC’s address as a nominal "front" address, without the knowledge or consent of IDC’s management.

According to records at IDC, a Christine Shaw ("Shaw") made arrangements for special negotiated rates for several telemarketing outfits, including, without limitation:

Cap Can Trading, 49 Jean Talon

Canadian Business Supplies, 1425 Rene Levesque, Ste. 669

East Coast Trading, 1310 Greene, Ste. 910

According to documents existent at IDC, Shaw sent faxes and received deliveries on behalf of these telemarketing outfits.

Prior to the discovery of these records IDC, it was previously generally thought that these telemarketing outfits were unrelated to each other.

Shaw is believed to be a fictitious name used by an unknown person or persons associated with fraudulent telemarketing outfits in Montreal.

Cap Can Trading and Canadian Business Supplies were telemarketing outfits where Sheldon Caplan ("Sheldon") had arranged office leases with building owners.

Sheldon is well known to police for his telemarketing activities.

Canadian Business Supplies, ECT, TC, Family Clearance Centre, used award certificates issued by Canadian Winners Circle as part of the telemarketing scheme.

Sheldon is a principal in the telemarketing firm Lighthouse Direct International ("LDI"), along with Peter Trodjman and George Warash.

An elderly victim from Ontario who suffered a loss of over $130,000 from several telemarketers previously litigated LDI.

Documents found at LDI’s abandoned offices belonged to the following telemarketing operations which represented themselves to the Plaintiffs and other victims as having different locations:

Greenview Marketing (with Bernie Kay)

Gifting House

Consumers Clearing House

National Collection of Awards

Payments received by Consumer Group and East Coast Trading were deposited into a single account at the Caisse Populaire, St. Matheu, transit #30348, account #80893.

LDI victims were subsequently telemarketed by the following telemarketing outfits:

Consumer Group/Omega

Montreal Interactive Communications (MIC)

Delta

GITA

Frontier

PDN

Some victims were telemarketed by Heritage Group with a promise to obtain their money back from the alleged bankruptcy of Cap Can Trading.

The phone directory states that a "C. Simon" resides at 175 Poplar, Dollard-Des-Ormeaux, tel 684-5321, fax 421-0534 (hereinafter referred to as "175 Poplar.")

Finkelstein is also known as "Carri Finkelstein," "Carri Simon," and "Carrie Simon."

On or about 12 May 1998, a person identifying himself as "Mr. Simon" at telephone number 684-5321, denied any knowledge of Finkelstein, Carrie, or of telemarketing activities.

Jessica Simon is a resident of Poplar. On 24 May 1998, Jessica attended a social function given by Helene ("Helene") who has a telephone number of 696-5604.

Helene lives with Ronald Shear AKA Ronnie Shear ("Ronnie") of 205 Montpellier, Dollard-Des-Ormeaux. (Hereinafter referred to as "Montpellier.")

Phone directories include a listing for Ronnie Shear, telephone number 696-5604.

Montpellier is an address used by several prize/awards outfits associated with telemarketing outfits, including, without limitation "Great Canadian Giveaway," "Classic Jackpot," and "Canadian Winners Circle" --- all names registered by 9026-0803 Quebec Inc, a corporation controlled by "Steven Shear."

Award certificates issued by Canadian Winners Circle were used by Canadian Business Supplies a s part of a telemarketing scheme.

In fact, Steven Shear is not a resident of 205 Montpellier.

According to government documents, 9026-0803 Quebec Inc. is owned by a "Steven Shear."

9026-0803 Quebec Inc’s lawyers are Shaffer & Shaffer, who are located at the same floor as TC’s government-registered address.

In or about 17 June 1998, Montpellier was listed for sale with the "A. Shear" Realty Company.

The only residents at Montpellier according to school election records are:

Bernard Fishman, Male, Date of Birth of May 22 1926
Helene Fishman, Female, Date of Birth of December 1 1956
Ronald Shear, also known as Ronnie Shear, Male, Date of Birth of November 15 1955
Sandra Stober, Female, Date of Birth of April 23 1937

Steven Shear is either a fictitious name or an alias used by Ronald (Ronnie) Shear.
Ronald ("Ronnie") Shear is a name that is well known to police authorities.
Ronald Shear had signing authority for TC at the TC account Royal Bank at 13135 Guinea Blvd. W., Pierrefonds, QC.
Ronnie was the signing authority for Canadian Winners’ Circle at Royal Bank, Royalmount and Royden, Mt. Royal.

Royal Business Supplies is a company name used by the Syndicate.

Ronnie (using the name Ronald) Shear had signing authority for Royal Business Supplies’ bank account at Laurentian Bank, transit 01091, account 109-49007-601, along with Leslie Pinsky, and Morris Staszower.

Pinsky and Staszower were arrested for fraudulent telemarketing, according to police records. They were not prosecuted further due to lack of resources.

Summit Group is another company name used by the Syndicate.

Ronnie was also a signatory for the Summit Group at National Trust, 5800 Cavendish Blvd, Montreal, account 0414034596. Summit Group was a fraudulent telemarketing outfit. Ronnie was a signatory along with Scott Chadwick, Audrey Gilman, Eyal Artzy, Ilal Artzy.

Ronnie, along with Eyal Artzy ("Eyal") was a co-signatory at the TC account at the CIBC.

Helene Fishman is the spouse of Ronnie.

Eyal is known to police authorities for his telemarketing activities.

Audrey ("Audrey") Fishman Gilman, with a Date of Birth of April 9 1958, is well known to police authorities. Audrey and Ilal Artzy ("Ilal") have signing authority for the Summit Group, a telemarketing company with dozens of complaints known to police, at the National Trust at 5800 Cavendish, Montreal.

Audrey Fishman Gilman is related to Bernard Fishman.

Audrey Fishman Gilman is related to Helene Fishman.

On or about 17 June 1998, representatives of the Luizos law firm discovered documents from th ese telemarketing "outfits" at an office formerly occupied by Frontier Enterprises at 8455 Decarie Blvd, Montreal:

Lighthouse Direct Enterprises

Impact Marketing Group, 4544 Decarie Blvd, Suite 3, Montreal

Central Distributers, 4400 Cote de Liesse, Suite 117, Town of Mount Royal

Michael Johnson cob Frontier Enterprises, 8455 Decarie Blvd, Ste. 200, Montreal

Impact Marketing

True North Enterprises, Impact Marketing and Frontier Enterprises indicating that these "outfits" employed the same staff (e.g.- Payroll records for Ann David.)

Bernie Kay’s (Bernie Karachinsky) name was used to operate the Bell Canada account for Greenview Marketing.

Greenview Marketing’s documents were found at offices formerly used by Lighthouse Direct Enterprises and subsequently abandoned. This office was located at 2340 Lucerne Suite 31, Montreal.

Invoice forms used by three outfits, LDI, Impact Marketing Group, and Select Marketing Systems are nearly identical in form and content. Although these outfits were located at different addresses, they were created and controlled by the Syndicate.

Identical invoice forms were printed by many of the biggest company names in Montreal telemarketing boiler rooms, including "The Omega Group", "Montreal Interactive Communications", "Delta International," RCC, Protocall Consumer Innovations and "G.I.T.A."

TC and ECT used the same address, same dot-matrix printer to produce their invoices, the same invoice forms, and the same text and terms on their invoices.

The following outfits used identical endorsement stamps, style of endorsement, and handwriting on cashed drafts from telemarketing victim and Plaintiff, Elsa Horvath:

Impact Group

Lighthouse Direct International

S.M.S. (a.k.a. Select Marketing System)

Readers Clearing Center ("RCC") was a company located at 5290 Ferrier Street, Suite 400, Montreal. G.I.T.A. was a company located at 615 Rene Levesque, Suite 610, Montreal. Delta International and Omega Group were companies located at 5250 Decarie Blvd., Suite 410. These companies names were used by the Syndicate to obtain money from victims.

RCC, Omega Group, Montreal Interactive Communications, and Delta International used the same GST and QST tax numbers on their invoices.

Montreal Interactive Communications, Protocall Consumer Innovations, and G.I.T.A. used the same inventory numbers on their invoices.

Protel Resources at 1405 Bishop Street, Suite 100 also used the same form and inventory number as G.I.T.A. and Montreal Interactive Communications.

First Avenue Productions ("FAP") was a company located at 5465 Queen Mary Road. First Call Distributing ("FCD") was a company located at 5465 Queen Mary Road. Residential Gift House ("RGH") at 5264 Queen Mary Road, Montreal. These companies names were used by the Syndicate to obtain money from victims.

FAP and RGH used similar text ("Premium/Prime - delete {product}), and forms as Omega Group, Delta International, Protel Resources, G.I.T.A., and Delta International.

FAP’s and FCD’s invoices stated that their GST number was 138615802.

Lodgyk Enterprises was a company located at 3049 D. Deacon, Dollard-Des-Ormeaux, QC, H9B 2M5. C.G.W. Incorporated ("CGW") was a company located at 1637 St. Catherine West, Suite 301, Montreal. London House Novelties ("LHW") was a company located at 4230 St. John’s Blvd, #231, Dollard-Des-Ormeaux, QC. These companies names were used by the Syndicate to obtain money from victims.

Lodgyk Enterprises, LHW and CGW used the exact same:

Invoice forms
Registration Fee of $40 per invoice
Shipping and Handling Fee of $30
"Prepayment" text
"Guaranteed" text on the comment box

FAP, FCD, RGH, LHW, TC, ECT, Impact Group, Impact Marketing Group, Delta International, Montreal Interactive, G.I.T.A., Consumer Group, Omega, Lighthouse Direct International, Lodgyk Enterprises, CGW were among the myriad of company fronts used by the Syndicate to extract money from their victims.

The Plaintiffs plead that it is plainly obvious that a unified organisation directed the creation of these documents, and the Syndicate’s underlying telemarketing scheme.

Mario Del Gross, Dino Del Grosso, Herwig Radlgruber were some of Syndicate’s directing minds behind these companies.

On or about 17 June 1998, representative of the Luizos law firm discovered a filing drawer at an abandoned telemarketing boiler room at 1831 Rene Levesque, ground floor, Montreal which contained the following labels:

ISP

Protek

Atlantic Communications

At this same location, a file folder was found which contained the following label: "Follow up – Spectrum."

At this same location, documents for the following parties were discovered:

Leonard Amari

ISP Inc.

Seweryn Kryk

ISP/Marc Gregwell

Spectrum Trading, which claimed to be at 4531 Des Sources Blvd Suite 100, Montreal, is well known to police authorities for telemarketing activities.

According to OPP Phonebusters' records, other telemarketers names and outfits using the location of 1831 Rene Levesque, Montreal, included the following:

Duvois & Associates, Stevenson Duvoir, Bernstein & Bernstein (drafts payable to James Bell), 

International Security Premium (ISP), Stevenson Duvorr, Global International, 

Max Greenburg (drafts payable to John Barker), James Noel.

"Prime Group" is a trade name operated by 9051-1254 Quebec Inc. AKA "LDG Supersound."

Bank drafts payable to Prime Group were deposited in LDG Supersound’s account at the Bank of Montreal.

Prime Group also used offices at 1434 St. Catherines West.

Kryk was also a directing mind behind Prime Group along with Lenn Gomes and Barbara Gomes.

Prime Group was not registered with the province as doing business at 1434 St. Catherines West.

The directors of LDG Supersound/Prime Group are Lenn Gomes and Barbara Thompson. Both these directors cannot be located at their respective declared addresses in government records.

After Prime Group closed its operations, an outfit calling itself "Oasis" called previous telemarketing victims of Prime Group. Oasis stated that they were taking over Prime Group.

The Prime Group is known to police circles as being part of the "David Rost" arm of the Syndicate.

"Oasis" is known to police authorities as a David Rost boiler-room operation.

On or about 29 November 1995, Pierre Savigny ("Savigny") incorporated 9025-5263 Quebec Inc which subsequently identified itself as "Procan," "Pro-Can Inc.," and "Pro Can" to telemarketing victims.

Pierre Savigny claimed a home address of 3822 St. Denis, Montreal. Investigations to that location did not reveal the presence of Savigny.

On or about 14 December 1995, Savigny incorporated 9029-1485 Quebec Inc., cob KP Canada Promotions.

On or about 13 December 1995, Savigny and Michael Gagnon incorporated 9029-0362 Quebec Inc., which identified itself as "National Administration" to victims.

Savigny, along with David Rost, was a directing mind behind the telemarketing operation, which called itself "Prosave" or "Pro Save Inc." to victims.

Savigny, along with David Rost, was a directing mind behind the telemarketing operation, which called itself "LGBO" to victims. Savigny identified his home address as 268 Strasbourg, Dollard-Des-Ormeaux.

David Rost, along with Savigny and Luc Philippe McCuiston, were the signing authorities at an account owned by Prosave at the Bank of Nova Scotia, 1715 Victoria Square, Montreal.

On or about 20 June 1996, Savigny incorporated 9022-1714 Quebec Inc., claiming an address of 268 Strasbourg, Dollard-Des-Ormeaux.

Protocall Consumer Innovations was a name used by the Syndicate members operating out of 3535 Queen Mary Road, Suite 401, Montreal.

Thomas Altenburg, Dino Del Grosso, Elias Bakomichalis were signing authorities at an account owned by 3130100 Canada Inc cob "PCI" and cob "Protocall Consumer Innovations." The PCI account was established at the Royal Bank, 5469 Queen Mary, Snowdon, Montreal.

On or about July 1997, Kryk named "Elias Bachamichalis of Telecoat at 514-340-3656, fax 514-340-3658" as his credit reference in Kryk’s Sprint Canada credit application. As of 4 September 1998, both numbers were not in service. Telecoat is known to police authorities.

Payments from Blundell and Reineke were cleared by the Syndicate through their account operating under the Defendant 2547-8918 Quebec Inc.

Blundell’s payment was payable to "Consumer Group Reg’d" and Reineke’s payment was for "East Coast Trading." The account for 2547-8919 Quebec Inc. was held at the Caisse Populaire St. Matheu, transit #30348, account #80893.

PCI/Protocall Consumer Innovations used GST #140637505, which was precisely the same GST number used by these other telemarketing outfits with varying addresses:

Publishers Digest at 7881 Decarie Blvd, Suite 400, Montreal

Columbia Group at 615 Rene Levesque Blvd. W., Suite 625, Montreal

Consumer Group at 5250 Decarie Blvd., Suite 410, Montreal

Montreal Interactive (Communications) at 1425 Rene Levesque Blvd. W., Suite 508, Montreal

Delta International at 5250 Decarie Blvd., Suite 410, Montreal and at 8600 Decarie Blvd., #102, T.M.R.

Fortress Marketing at 2110 Decarie Blvd, Suite 100, Montreal and at 3535 Queen Mary Rd., Suite 410

Protel Resources at 1405 Bishop Street, Suite 100, Montreal

Protel Resources at 3535 Queen Mary Rd, Suite 410, Montreal

Corporate Investment Center at 5170 St. Patrick, Suite 119, Montreal

The Montreal telephone number of 514-484-1804 was used by the following "outfits":

LGBO

Pro Save Inc.

East Coast Trading used advertising materials identical to the ones implemented by the branch of the Syndicate known as the Collin Grant-David Rost telemarketing group.

LGBO and Pro Save Inc are legal entities used as corporate disguises by the David Rost arm of the Syndicate.

Karachinsky is known to police as a member of the Syndicate’s branch known as the "Pinsky Group."

Karachinsky was a directing mind behind Syndicate boiler rooms using names such as "Greenview Marketing" and "Action Enterprises."

Karachinsky was charged by police for fraud. The charges were later dropped by the Crown. Due to the lack of resources, the Crown Attorneys have been forced to drop charges against white-collar criminals, including fraudulent telemarketers, including Syndicate’s "Pinsky Group."

Action Enterprise’s business account at Caisse Populaire, Cote St. Luc, account no. 86175 is registered to 9049-1895 Quebec Inc., signing authority Michael Johnson, DOB of Feb 25 1959.

Michael Johnson was the person responsible for the telephone accounts with Cantel at a Syndicate operation called "Frontier Enterprises."

On or about 18 June 1998, one of Karachinsky’s telemarketing associates who was knowledgeable of Karachinsky’s involvement with Marketing attended at Karachinsky’s boiler room at 3285 Cavendish Boulevard, Ste. 481, Montreal for a meeting with Karachinsky.

Karachinsky’s associate drives a red Cadillac convertible which according to government records should be a gold-coloured Cadillac, registered to Jack Pashlin, DOB of Jan 25 1924, at 4635 Calaranald, Apt 312, Montreal. However, Pashlin was not the driver (Karachinsky’s associate) of the red Cadillac.

Leonardo Amari ("Amari") is known to police as an operator of the Pro Detail Group ("PDG") telemarketing operation.

Amari signed as company president of PDG with Sprint. As of March 1998, PDG owed Sprint $14,897.

Amari, using the address of 22 Surrey, Dollard-Des-Ormeaux, was the signing authority at the PDG bank account at National Bank, Ste. Catherine West, Transit 01431, and tel 514-954-4400.

Amari stated that he has dealings with Triton Industries. Triton Industries is another telemarketing outfit known to police.

PDG’s account with the Bank of Montreal was opened on Feb 10 1997. Deposits in excess of $36,260.35 were made to PDG’s account between June 3 1997 and June 23 1997.

The Defendants Luigi and Stefania Amari conspired with Leonardo Amari to use the address of 22 Surrey as a fraudulently business address for Leonardo Amari’s businesses, whereas in fact, Leonardo Amari’s telemarketing operations were conducted elsewhere.

Luigi and Stefania Amari wilfully allowed Leonardo Amari to fraudulently conceal his assets in their names.

In the alternative, Luigi and Stefania Amari were wilfully blind to the fraudulent activities conducted by Leonardo Amari at their 22 Surrey residence.

Seweryn Kryk is the signatory for Shoppers Import Group (AKA Shoppers International) with Sprint Canada Inc.’s cellular phone service.

Herwig Radlgruber, Ted Grossbaum, and Morris Weinstein are known to police as being the principal operators of Montreal Interactive Communications, Delta International, Consumer Group, and Columbia Group, all alleged fraudulent telemarketing outfits.

According to police records, Radlgruber along with Morris Weinstein and Ted Grossbaum operated 9049-9625 c.o.b. National Distributers.

LDI is an operation that is alleged by police to have connections to Sheldon Caplan.

LDI’s government filings disclose that Sheldon Caplan and Peter Trodjman are directors.

LDI’s account at a Caisse Populaire has a "George Warash" as the signatory.

The Syndicate is behind a telemarketing outfit calling itself "Aquarian of Canada" and "Aquarian Canada" in the Montreal area.

At various times the Plaintiff Fournier was induced by the Syndicate to make payments to Aquarian Canada through the Syndicate’s deceit and misrepresentations.

As of 8 December 1998, Phonebusters had received 82 complaints against Aquarian of Canada. There were also 70 attempts reported for $58,832 as well as 12 victims reporting a loss of $28,551.62.

The Syndicate is behind other telemarketing outfits calling themselves "International Shoppers Network:", "Silver Selection Awards", "Canadian National Digest", CND Inc.", "Impact Marketing Group", "Impact Group", "KML", "Consumer Rewards Promotion", and "Kings Merchandising Line."

Kovacs was a signatory for the Syndicate’s account Bank of Nova Scotia, transit 40501-002,account 00101-11, 5501 Westminster Ave, Montreal. Account was frozen by bank due to suspicious activity. Kovacs used various business names including Mediaplex, Panmark Holdings, Concorde International, and Tri-Mex Holding.

On or about 24 July 1998, George Warash wrote a letter to Paulos Luizos, a barrister, which stated that he, George Warash, was not involved with Lighthouse after February 26 1997.

Warash further stated that his true domicile "is and continues to be 3040 Levesque Avenue W. #712, Laval."

On or about 3 September 1998, Ms. Martine Allaire of the Caisse Populaire Desjardins on St. Laurent stated that George Warash opened on account (#92277) for Lighthouse on February 24 1997. Allaire provided information which indicated:

George Warash was the original sole signatory for this account.

There were substantial deposits and withdrawals on the account.

George Warash issued a letter to this Caisse Populaire which allowed Peter Trodjman to become a signatory to the account.

George Warash issued a letter to this Caisse Populaire which allowed a Mr. Robert Scheuer to receive statements and other documents on behalf of Lighthouse.

The account was active until November 1997.

At all material times, the Caisse believed that George Warash was the directing mind behind the Lighthouse account, and there was no contrary reason on file to believe otherwise.

George Warash did not inform the Caisse that, at the time, his true domicile was 4583 Rue Foster, Pierrefonds. On or about November 1997, George Warash sold his house at 4583 Rue Foster to Ronnie Midlash and Anastasia Bairaktoris.

George Warash did not inform the Caisse that Peter Trodjman was not in fact domiciled at Trodjman’s stated address of 5802 Trans Island, Montreal.

The landlord owning 5802 Trans Island, Montreal, stated that Peter Trodjman was not the name of known at that address.

Michael Jerry Granofsky ("Granofsky") is a chartered accountant.

Michael Jerry Granofsky arranged Kryk’s corporate identities.

Granofsky purposely listed his name in the Montreal whites pages as "Granofski" in order to thwart pursuers.

Granofsky provides a "cover" for the Syndicate’s encashing of the Plaintiffs’ and other victim’s payments.

Particulars of Granofsky’s activities for the Syndicate are as follows:

Setting up as many as 30 corporate shells, which Granofsky admitted to on or about 6 October 1998.

Granofsky fraudulently used the name of his brother-in-law, Ontario lawyer Alan Cracower to acquire a corporate shell from Marque D’Or, which was subsequently used by Seweryn Kryk.

Granofsky also purchased from Marque D’Or other corporate shells used by telemarketers.

Granofsky vouched for bank accounts opened by Kovacs including a Panmark account at TD Bank at 1130 Sherbrooke Street West, Montreal. Kovacs referred to Granofsky, a.k.a. Granovsky, as his accountant. This account was used to defraud telemarketing victims.

On or about 6 October 1998, Granofsky admitted that Kryk came to him due to referrals by other telemarketers.

On or about 6 October 1998, Granofsky admitted that it was rather unusual for a chartered accountant to engage in incorporation work.

On or about 6 October 1998, Granofsky’s telephone operator admitted that there was "no Cracower" and that they "were not a law office." She further admitted not knowing of an Alan Cracower although she had been employed for about a year in Granofsky’s office.

On or about 6 October 1998, Granofsky admitted that Cracower was not an associate in his office.

On or about 6 October, Granofsky admitted that he could not have purchased the corporate shell for Kryk had Granofsky not pretended to be a law office for Alan Cracower.

On or about 6 October 1998, Granofsky admitted that he failed to investigate the purpose of Kryk’s corporate shell.

On or about 6 October 1998, Allan Cracower stated that he had never been associated with Granofsky. Rather, Cracower stated that Granofsky was his brother-in-law.

With Granofsky’s assistance or complicity, Kryk was able to further his fraudulent activities against elderly and vulnerable members of society. As such, Granofsky’s conduct warrants exemplary damages as a deterrent.

Granofsky is well-known to police authorities.

Granofsky was involved as a principal with cheque cashing operation called Bureau Dechange Universal (roughly translated as Universal Exchange Bureau.)

Granofsky personally endorsed payments payable to the Syndicate in Florida.

Granofsky personally endorsed payments payable to Universal Inc. at a Royal Bank branch. Universal Inc. is a company name used by the Syndicate.

Marjorie Ireland is a senior citizen and resident of 89 Brunel Road, Huntsville, Ontario.

Marjorie Ireland has sent approximately $20,000 to fraudulent Quebec telemarketers.

Granofsky endorsed a payment drawn on the TD Bank to fraudulent Quebec telemarketers from Marjorie Ireland.

Granofsky personally double-endorsed payments payable to a Syndicate companies called "Procan," "First Choice Distributors," from Marjorie Ireland, of Huntsville, Ontario.

Police stated that Granofsky has a history of fronting for the Syndicate.

Granofsky is a directing mind behind 9006-3983 Quebec Inc, which operated an account at Caisse Populaire Notre Dame Sacre Coure Ville, La Salle, where substantial payments from telemarketing activities were deposited. Granofsky double and triple endorsed payments to 9006-3983 Quebec Inc.

Granofsky is a directing mind behind 9006-3983 Quebec Inc.

Granofsky works under, or with "Jean Grande Accounting and Bookkeeping," (hereinafter called "Grande") which has a phone book listed address of 384 St. Jacques St., Montreal, Ste. 111, QC, H2Y-1S1. The "contact telephone number" used by Grande, at the Caisse Populaire was 514-849-3850. This is precisely the same number used by Granofsky.

Granofsky also has signing authority for "Margill Company" at the Caisse Populaire Notre Dame, 7625 Edouard Street, La Salle, QC, H8P 1S9, tel (514) 365-0211. Police opine that this company could be part of a downstream, money-laundering operation for the Syndicate.

In the alternative, Granofsky conducted his business negligently which resulted in damages to victims.

In the further alternative, Granofsky conducted his business with such reckless abandon that in effect he became an accomplice of the Syndicate.

Victor Danchak ("Danchak"), DOB of Nov 17 1955, is a directing mind of the Syndicate’s branches known as Heritage Group, Cap Can Trading. In the alternative, Danchak was a participant in cashing victims’ payments. Danchak is also known as "Victor Banchak."

Danchak operated at least one of the Syndicate’s Caisse Populaire accounts, where the police authorities launched an investigation.

Danchak owned or operated account no. 67981 at the Caisse Populaire Provost de Lachine. This account was operated for the Syndicate.

On or about 17 March 1998, Danchak deposited a victim’s Canada Trust $12,000 draft payable to Lawrence Walker through Caisse Populaire Des Sources, for credit to his account no. 67981 at Caisse Populaire Provost de Lachine.

Police eventually raided Danchak’s Caisse Populaire. Police discovered documents indicating that Danchak controlled an account where telemarketers deposited drafts made out to victims and routed through a front-man operating with the Syndicate in the name of Cap Can Trading.

Cathy Wilson ("Wilson") co-habits with Danchak. Wilson is known as Danchak’s second wife.

Cathy Wilson allowed Danchak to fraudulently conceal his assets in her name, including a valuable riverfront property recently listed for sale with Remax.

Cathy Wilson’s Pierrefonds mansion was listed for sale for $800,000 with Mark Moore of Remax.

Danchak signed the document authorising the offering for sale of Wilson’s Pierrefonds mansion by Remax.

Mark Moore, Mrs. (Mark) Moore and the Remax staff understand that the Pierrefonds mansion is owned and controlled by Danchak.

The Defendant Myron Shrybman ("Shrybman") is involved in the encashing and money-laundering operations of the Syndicate.

Shrybman opened businesses called "Mister. Bagel" and "Mr. Baker" in Nepean, Ontario.

Shrybman’s businesses were "fronts" for laundering monies received by the Syndicate.

Myron Shrybman collected payments that were dropped off by couriers for the Syndicate at his business location at 1600 Merivale Road, Nepean, Ontario, K2G 5J8.

These payments to Shrybman’s Nepean business address came from victims in Ontario as well as the U.S.

Some of these monies were subsequently sent to the Syndicate in Quebec.

Shyrbman also directed the deposits from telemarketing activities into an account at the Royal Bank, 1460 Merivale Road, Nepean, Ontario, transit number 00496-003. Victims’ monies payable to "Robert Quinn" were deposited to this account.

A Plaintiff’s payment to Frontier Ent (Frontier Enterprises) was deposited in an Ontario corporate account controlled by Shrybman.

Victims were told to make payments to straw-men such as "Robert Marshall."

Payments to Robert Marshall and Robert Quinn were actually deposited in Syndicate accounts. Shrybman’s business address in Nepean, Ontario was used in these instances.

Shrybman is known to police authorities and the Federal Bureau of Investigation (the "FBI") in the United States.

On or about November 1998, Shrybman was given a notice to attend a U.S. Justice Department pre-grand jury disposition request, to provide statements about his alleged telemarketing activities for the Syndicate.

The Syndicate cleared payments through bank accounts operated by, or fronted by, Aaron Mizrahi ("Mizrahi".)

Mizrahi cleared victims’ payments through the Royal Bank at Bois Briand, 1400 Grande Allee Blvd, Bois Brian, QC, G7J 2Z8.

The bank warned Mizrahi about the "double-endorsements" and prohibited Mizrahi from further such endorsements.

It is alleged that, as part of the Syndicate, Mizrahi works under Marty Wiseman, Terry Mulderrig, James Farmer, and Defendant David Rost.

Weinstein co-owns a "detox halfway house" called Second Glance Cooperative which shares offices with a Syndicate operation called "Millenium One." This detox house which purports to aid drug users, is also used to recruit telemarketers.

Second Glance Cooperative’s detox halfway house is located at 394 Chemin Des 14 Iles, St-Hippolyte, QC, and tel 514-735-5757 and 514-224-9939.

Other directing minds behind Second Glance Cooperative include Marc Andre Blouin and Glenn Walsh.

The office lease for the Millenium One office at 4480 Cote de Liesse, Suite 360, was arranged by Weinstein.

Morris Weinstein, Marc-Andre Blouin, Jacques Dagenais, Daniele Smith, Nathalie Dudragne are among the directing minds behind the arm of the Syndicate which calls itself as Millenium One, division of Second Glance Cooperative.

Millenium One and Second Glance Cooperative obtained funds from the Plaintiffs through the usual promises of false and extravagant prizes.

Second Glance Cooperative’s brochures listed (514) 735-5757 as one of its phone number.

Police authorities have received complaints wherein another phone number listed on Second Glance’s colour brochure, namely, (514) 735-5757, was referenced to false-prize scams from outfits calling themselves:

"Madison Group", of 299 Fifth Ave., Verdun, QC

"Consumer Catalogue Distributors", of Plymouth Avenue

"Imperial Investment Group Inc."

"Canadian Lottery Commission"

"Millenium One", of 4480 Cote de Liesse, Ste. 360

Police authorities have received complaints whereby the phone number of (514) 340-9909, was referenced to Consumer Catalogue Distributors.

Plaintiffs know Consumer Catalogue Distributors as an outfit that attempted to re-victimize them, after they had already been "taken" by previous telemarketers.

The Plaintiffs plead that Consumer Catalogue Distributors is yet another one of the many company names used by the Syndicate as a vehicle for fraud.

After the Plaintiffs sent monies to the Syndicate via Weinstein and Blouin, the Syndicate sent out "Class-E" shares to their victims in order to make the payments appear as charitable donations, or alternatively, sales of shares of corporate stock of the "Second Glance Help And Support Service Workers Cooperative."

Second Glance Cooperative is not registered with the Ontario Securities Commission for the sale of stock to the public.

Weinstein and Blouin used award certificates from "Heritage Group" in deceiving the Plaintiffs with false prizes.

Heritage Group used the telephone number of (514) 342-4101.

Heritage Group is a name that is well-known to police authorities as being involved with fraudulent telemarketing operations.

The telephone number (514) 342-4101 was registered to R. Dery, at a residential address.

The telephone number (514) 342-4101 was answered by an answering machine with the voice mail stating that this was a company in the name of "Heritage Group."

The Plaintiffs plead that the telephone number (514) 342-4101 was a number used in the scam whereby they were told that their monies would be refunded out of the "Cap Can bankruptcy" if only they would send additional monies to 7455 Boul St. Anne, Montreal, QC, H4B 1T5.

The Plaintiffs plead that the telephone number (514) 342-4101 was also used in attempts to obtain monies from victims under the name of Second Glance Cooperative.

The Syndicate’s front men, Weinstein and Blouin, advised their victims that Millenium One was a division of Second Glance Cooperative.

Government records disclose that Second Glance Cooperative was not authorized to use the name Millenium One.

The Plaintiffs plead that Blouin allowed the wholly inoperative endorsements on payments to Second Glance Cooperative and caused payments to be diverted to Weinstein.

The Plaintiffs plead that such wholly inoperative endorsements are forgeries within the meaning of the Bills of Exchange Act, R.S.C. 1985.

When a rift developed between Blouin and Weinstein, Blouin assaulted Weinstein. Weinstein notified the police of this matter.

St. Hippolyte was a quiet village in the outskirts of Montreal.

The crime rate in St. Hippolyte has increased since Blouin and Weinstein opened Second Glance Cooperative.

Victims of telemarketing fraud are not being protected under the Competition Act because the Competition Bureau does not have the resources to prosecute boiler-room operators.

Between April 1 and September 30 1997, the Competition Bureau received 538 criminal matter complaints. However, none were referred to the Attorney General.

Between April 1 and September 30 1997, the Competition Bureau received 2,859 marketing practices complaints. However, only 6 inquiries were started and only 1 was referred to the Attorney General.

According to the Competition Bureau’s Annual Report ending March 31 1996, only 8 out of 6,751 complaints to their Bureau were investigated.

On or about 29 June 1998, Ontario Asst. Crown Attorney Hugh Paisley stated that – as a policy – their department does not prosecute white-collar crime because the Crown only has enough resources to prosecute "violent" criminals. This statement was made at the National Forum on Fraud.

On or about 28 June 1998, RCMP commissioner Phillip Murray stated that the RCMP only resources to track down 1 out of 18 known major criminal groups. This was reported in the Globe and Mail.

RCMP commissioner Murray further stated that the criminals were "on a roll," and that the RCMP was "not resourced to really have a serious, concerted attack on organized crime. If we’re focusing on one group, the rest of them have a free run."

On or about 26 October 1998, an RCMP officer stated - in a CBC News documentary on telemarketing fraud – that the RCMP only investigates about 10% of reported telemarketing fraud.

On or about 26 October 1998, a former Toronto Police Fraud Squad officer stated – in a CBC News documentary on telemarketing fraud – that their officers were practically laughed at by telemarketers, as these telemarketers knew about the lack of police resources to investigate telemarketing fraud. In some instances, the police officers had to ask the telemarketers to ‘please return the money’ to victims. The former officer further stated that he believed that fraudulent telemarketers had the perception that they were "beyond prosecution."

Police estimate that Quebec-based telemarketing fraud at $40M-$80M per year.

On or about 29 June 1998, leaders of the elderly community present at a national forum on scams and frauds stated their belief that the elderly are especially vulnerable to fraud because of their weakened cognitive ability. These leaders included Yves Poirier of the Poirier Foundation, a noted charitable organization.

On, or about 29 June 1998, Detective Barry Elliott of OPP Operation Phonebusters stated that about 80% of telemarketing fraud victims are elderly.

Standard textbooks consulted by Social Workers State that people who are in grief have temporary loss of cognitive ability and "should not make any important decisions."

Many victims of Quebec-based telemarketing fraud are such persons in grief, and hence, are especially vulnerable to frauds.

The Plaintiffs plead that speed is required in the dispensation of justice in this case, as most of them are very advanced in their years and may not live to see the end of a prolonged court procedure. The Plaintiffs plead that speed is necessary in the court’s determination of this case, as several of them are of extremely fragile health and are undergoing cancer or coronary care.

On or about 20 November 1998, RCMP Staff Sgt. Peter Montague raided a Burnaby, BC-based telemarketing operation, seizing a reported $4M in assets. However, Sgt. Montague did not arrest anyone because, "the prosecution would have taken years."

On or about 20 November 1998, RCMP Staff Sgt. Jeff Wright, describing telemarketers’ modus operandi, stated, "The problem is they become, in some of these cases, their [victims’] best friend. They’ll believe them over anybody else." Sgt. Wright’s comments were reported and published in The Province, a newspaper.

Some victims and at least one social worker believe that Quebec-based telemarketing fraudsters may be using the obituaries as "sales leads" for their telemarketing campaigns.

Many of the Plaintiffs live alone, and hence, are especially vulnerable to fraud. The Plaintiffs plead that the Syndicate’s telemarketers prey on the loneliness of victims. This allegation is supported by the notes made by telemarketers at the time of their calls. These notes were found at telemarketing boiler rooms used by the Syndicate.

The actions by these telemarketing fraudsters are reprehensible and call for large exemplary and punitive damages as a deterrent, to protect the public from further similar harmful deceit to the public.

Suite 410 at 5250 Decarie is a well-known location to police authorities. A roomful of papers nearly 3 inches thick that was abandoned by the Syndicate reveals that thousands of people were being actively telemarketed, catalogued, and indexed in a systematic campaign. A "sales chart" left behind by the Syndicate reveal that this location alone could produce millions in annualized revenue for the Syndicate. This sales chart showed names and revenues produced by individual members of the Syndicate.

Sales literature and documents used by the Syndicate discovered at Suite 410, 5250 Decarie belonged to a myriad of company names and addresses. The Plaintiffs plead that these seemingly unrelated companies in fact belong to the Syndicate.

The Plaintiffs plead that the Syndicate left these incriminating documents at former boiler room locations with studied abandon because the members of the Syndicate believe that the authorities would not have the resources to prosecute them criminally.

Deceptive and predatory activities by telemarketers against seniors are a practice that has been universally condemned. The Plaintiffs plead that only large exemplary and punitive damages will serve as deterrence, in order to protect the public interest.