Replies to post #28477 on Bourque Industries Inc (BORK)

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PARTIES
8. Plaintiff Boss Consulting, Inc. (“Boss”) is a corporation organized in
Utah, and with business offices in California. It is a product distributor.
9. On information and belief, and thereon alleged, Defendant Terminator
Armor, Inc. (“Terminator”) is a corporation organized in Arizona, and is a
distributor and importer of products with headquarters at 1375 N. Miller Road,
Tempe, Arizona 85281.
Case 8:20-cv-01897-MEMF-KES Document 1 Filed 10/01/20 Page 2 of 22 Page ID #:2

COMPLAINT
PAGE 3
10. On information and belief, and thereon alleged, Defendant Bourque
Industries, Inc. (“Bourque Industries”) is a corporation organized in Nevada and
registered as a foreign corporation in Arizona, is a distributor and importer of
products, and maintains a business office in Arizona.
11. On information and belief, and thereon alleged, Defendant Carol J.
Condon (“Condon”) is an individual who is a director and/or officer of both
Defendants Terminator and Bourque Industries, and who is a resident of Arizona.
12. On information and belief, and thereon alleged, Defendant John
Bourque (“Bourque”) is an individual who is a director and/or officer of both
Defendants Terminator and Bourque Industries, and who is a resident of Arizona.
13. On information and belief, Defendant Redstone Investment Group
LLC, (“Redstone”) is an entity that is doing business as Redstone Advisory Trust,
offering investment and escrow services and which has offices in Newport Beach,
California.
14. On information and belief, Defendant Aaron M. McKown
(“McKown”) is an attorney, is associated with the Redstone Investment Group
LLC, maintains offices in Newport Beach, California, and is a resident of
California.
15. On information and belief, Defendant Aaron M. McKown P.A.
(“McKown P.A.”) is an entity organized as a Professional Association in Florida,
having as its principal Defendant McKown, and also being associated with the
Redstone Investment Group LLC.
16. On information and belief, Defendant Ohana Financial (“Ohana”), is a
banking and financial institution that maintains offices in Utah.
17. Plaintiff is informed and believes, and thereon avers, that Defendants
Bourque and Condon, and each of them, are and at all materials times relevant to
this Complaint have been, the agents, servants, and/or employees of Defendants
Terminator and Bourque Industries, purporting to act within the scope of said
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COMPLAINT
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agency, service or employment, in performing the acts and omissions to act as
alleged in this Complaint. Each of said Defendants so named in this paragraph are
believed to, and are alleged to, have been acting in concert with, as employees,
agents, or co-conspirators, or members of a joint venture of, each of the other
Defendants so named in this paragraph, and therefore are alleged to be liable
jointly and severally for the claims set forth herein in relation them.
18. Plaintiff is informed and believes, and thereon avers, that Defendants
McKown, McKown P.A., and Redstone, and each of them, are and at all materials
times relevant to this Complaint have been, the agents, servants, and/or employees
of each other, purporting to act within the scope of said agency, service or
employment, in performing the acts and omissions to act as alleged in this
Complaint. Each of said Defendants so named in this paragraph are believed to,
and are alleged to, have been acting in concert with, as employees, agents, or coconspirators, or members of a joint venture of, each of the other Defendants so
named in this paragraph, and therefore are alleged to be liable jointly and severally
for the claims set forth herein in relation to them.
19. Defendant Condon is, on information and belief, and thereon alleged,
to be a shareholder, director, and/or officer of Defendant Terminator. At all time
relevant to the events alleged herein, it is alleged, on information and belief, that
Defendant Condon maintained actual immediate control over Defendant
Terminator’s assets and operations, such that Defendant Terminator was nothing
more than a mere instrumentality of Defendant Condon, who held effective
ownership of Defendant Terminator’s assets and paid the expenses related to
ownership, maintenance, and operations of Defendant Terminator. It is further
alleged on information and belief Defendant Condon is the alter ego of Defendant
Terminator because she has acted as the principal of Defendant Terminator and
maintained control over its assets, daily fiscal policies, and operations.
20. Defendant Condon is, on information and belief, and thereon alleged,
Case 8:20-cv-01897-MEMF-KES Document 1 Filed 10/01/20 Page 4 of 22 Page ID #:4
Defendant Bourque maintained actual immediate control over Defendant
Bourque Industries’ assets and operations, such that Defendant Bourque Industries
was nothing more than a mere instrumentality of Defendant Bourque, who held
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COMPLAINT
PAGE 6
effective ownership of Defendant Bourque Industries’ assets and paid the expenses
related to ownership, maintenance, and operations of Defendant Bourque
Industries. It is further alleged on information and belief Defendant Bourque is the
alter ego of Defendant Bourque Industries because he has acted as the principal of
Defendant Bourque Industries and maint