Bourque Industries Inc (BORK)

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COMPLAINT
Comes now, Plaintiff Boss Consulting, Inc. (“Plaintiff” or “Boss”), sues
Defendants, and alleges in this Complaint as follows:
NATURE OF ACTION
1. This is a civil action for fraud and racketeering activities, breach of
contract, conversion, and unfair business practices.
2. Plaintiff is a product distributor of goods. Plaintiff was authorized by
Case 8:20-cv-01897-MEMF-KES Document 1 Filed 10/01/20 Page 1 of 22 Page ID
COMPLAINT
PAGE 2
a buyer to act as its representative to acquire certain personal protective equipment
(PPE), quantities in the millions. Plaintiff entered into a transaction with a seller
who claimed to have goods meeting the specifications and quantity requested, but
who provided counterfeit goods. This transaction was made through the services of
an investment group, and when the entire transaction was rejected, no money was
refunded to Plaintiff, leaving her liable for millions of dollars to the buyer of the
goods.