UNITED STATES FEDERAL DISTRICT COURT
IN THE MIDDLE DISTRICT OF PENNSYLVANIA
MARIA FULLANA-JORNET & CARLOS
IUDICA, JOSEPH & DAWN
DE LORENZO, KIM & FRANK JURY,
KRISTY & FLINT SCHULZE, LISA
NEWTON, MEGAN & GERALD
SCHAEFER, STEFAN & CLAUDIA
WESSEL, CANDACE BUSHOUSE,
FAYE RAN, TOM & BARBARA
PINGREE, JAYMEE WAPPES,
CHAD & MICHELLE MEENACH,
ANNAMAE & CHRISTOPHER YOUNG
KATHLEEN & MARK WASON
Plaintiffs
v.
) - FRAUDULENT
) - INNOCENT
ADOPTION INTERNATIONAL
PROGRAM, INC.
a Pennsylvania For-Profit Corporation
and
ORSON MOZES
and
CHRISTEN BROWN
and
KEVIN ANDERSON
Individuals
Jointly and Severally
Defendants
_______________________________________________________________________
_
Joni M. Fixel (P56712)
Marlo D. Bruch-Barrett (P70362)
Fixel Law Offices, PLLC
Attorney for Plaintiffs
4990 Northwind Drive, Ste 121
East Lansing, MI 48823
(517) 332-3390
_______________________________________________________________________
_
1
)
) Hon.:
)
) Case No.: 07-
)
)
)
)COMPLAINT FOR VIOLATIONS
) OF: 18 U.S.C. §§ 1341, 1343,
) 18 U.S.C. § 1962(c)
) 18 U.S.C. § 1962(d)
) -UNJUST ENRICHMENT,
) - CONVERSION,
) -CIVIL CONSPIRACY,
) MISREPRESENTATION,
) MISREPRESENTATION.
) -INTENTIONAL INFLICTION
) OF EMOTIONAL DISTRESS,
) -NEGLIGENT INFLICTION OF
) EMOTIONAL DISTRESS
)
)
)
)
) PLAINTIFFS DEMAND A JURY
)
)
Plaintiffs Maria Fullana-Jornet and Carlos Iudica, Joseph and Dawn De Lorenzo, Kim and

Frank Jury, Kristy and Flint Schultze, Lisa Newton, Megan and Gerald Schaefer, Stefan and

Claudia Wessel, Candace Bushouse, Faye Ran, Tom and Barbara Pingree, Jaymee Wappes,

Chad and Michelle Meenach, Anna and Christopher Young, and Kathleen and Mark Wason

hereby allege and state the following Complaint against Defendants Adoption International

Program, Inc., Orson Mozes, Christen Brown and Kevin Anderson (hereinafter referred to

collectively as “Defendants”).

PARTIES

1. Plaintiffs Maria Fullana-Jornet and Carlos Iudica are United States citizens

residing in the State of Pennsylvania.

2. Plaintiffs Joseph and Dawn De Lorenzo are United States citizens residing in

the State of New Jersey.

3. Plaintiffs Kim and Frank Jury are United States citizens residing in the State

of Kansas.

4. Plaintiffs Kristy and Flint Schultze are United States citizens residing in the

State of Michigan.

5. Plaintiff Lisa Newton is a United States citizen residing in the State of

Virginia.

6. Plaintiffs Megan and Gerald Schaefer are United States citizens residing in

the State of Delaware.

7. Plaintiffs Stefan and Claudia Wessel are United States citizens residing in the

State of Rhode Island.

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8. Plaintiff Candace Bushouse is a United States citizen residing in the State of

Michigan.

9. Plaintiff Faye Ran is a United States citizen residing in the State of New

York.

10. Plaintiffs Tom and Barbara Pingree are United States citizens residing in the

State of New York.

11. Plaintiff Jaymee Wappes is a United States citizen residing in the State of

Indiana.

12. Plaintiffs Chad and Michelle Meenach are United States citizens residing in

the State of Ohio.

13. Plaintiffs Anna and Christopher Young are United States citizens residing in

the State of New York.

14. Plaintiffs Kathleen and Mark Wason are United States citizens residing in the

State of Texas.

15. Defendant Adoption International Program, Inc. (“AIP”) is a Pennsylvania

For-Profit Corporation with a principal place of business at 614 Darby Road,

Havertown PA 19083 and a California For-Profit Corporation with a

principal place of business at 1373 Schoolhouse Road, Santa Barbara CA

93108. Defendant AIP is licensed to perform adoptions by the State of

Pennsylvania.

16. Defendant Orson Mozes is upon information and belief a United States

citizen residing in the State of California. Mozes holds himself out to be the

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 founder of AIP, its President and its Director. Mozes worked out of the AIP

California office.

17. Defendant Christen Brown is upon information and belief a United States

citizen residing in the State of California. Brown holds herself out to be the

Executive Director of AIP. Brown worked out of the AIP California office.

(Exhibit X)

18. Defendant Kevin Anderson is upon information and belief a United States

citizen residing in the State of California. Anderson holds himself out to be a

Manager of AIP. Anderson worked out of the AIP California office.

19. Upon information and belief, the Defendants ceased business as AIP in

October 2007.

JURISDICTION AND VENUE

20. This action is brought under the Federal Racketeer Influenced and Corrupt

Organization ("RICO") statute, 18 U.S.C. § 1961 et seq., and various other Pennsylvania

statutes and common law doctrines. The matter in controversy exceeds the sum or value of

Seventy-Five Thousand and 00/100 Dollars ($75,000.00), exclusive of interest and costs,

and is between citizens of different states. Jurisdiction is vested in this Court by virtue of 28

U.S.C. §§ 1331 and 1332.

21. Because claims brought under Pennsylvania law are also so related to

Plaintiffs’ federal claims, over which the Court has original jurisdiction, that

they form part of the same case or controversy under Article III of the United

States Constitution, the Court also has jurisdiction over Plaintiffs’

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 Pennsylvania common law and statutory claims pursuant to 28 U.S.C.

§ 1367.

22. A substantial part of the events and omissions giving rise to the claims stated

herein occurred in this District and all defendants are subject to the personal

jurisdiction of this judicial district. Venue is proper in this District and

Division pursuant to 28 U.S.C. §§ 1391 and to 18 U.S.C. §1965(b).

INTRODUCTORY ALLEGATIONS

Plaintiffs Fullana-Jornet and Iudica

23. Plaintiffs Maria Fullana-Jornet and Carlos Iudica (“Plaintiffs”) decided to

adopt internationally and found Defendant AIP offering adoptions from the Ukraine through

an internet website. In March 2005, the Plaintiffs contacted Defendant Mozes and they were

sent a video of a Ukrainian child, who was advertised on Defendant’s website as a healthy

child. Plaintiffs rejected this child after reviewing the video with a pediatrician due to

medical deformities clear in the video. On April 14, 2005, the Plaintiffs signed an illusory

contract with the Defendants. (See Exhibit X)

24. Several weeks later, Plaintiffs found another little girl on the same website.

Once again Defendant Mozes send a video of the child. When Plaintiffs expressed interest in

this 9 month old girl, Defendant Mozes told Plaintiffs to send money immediately, $3000

for the Ukraine to “secure the little girl” (this is also called a referral) and $7500 to his

agency. Plaintiffs sent the money and Defendant Mozes sent information for the Plaintiffs to

complete a dossier. Defendants never disclosed that they did not have an office in

Pennsylvania.

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 25. Plaintiffs were in the process of completing the home study required to be

completed before an adoption when they were told that it was illegal for the Defendants to

have referrals in the Ukraine. When Plaintiffs asked Defendant Mozes they were told

“Americans do not understand how the adoption process works. Referrals are a

common process, there is nothing illegal, it is 100% o.k.” A few weeks later the

Ukrainian Government issued a moratorium and stopped all international adoptions.

26. Soon the closing of the Ukrainian international adoptions, Defendant Mozes

said that the Plaintiffs had lost the referral and suggested that the Plaintiffs consider a

Russian adoption. Plaintiffs started filling out additional paperwork for a Russian adoption

when they received a request for more money from an associate of Defendants in Russia.

When questioned about this request for funds, Defendant Mozes said the call was a mistake.

27. Over the next 6 months, the Defendants sent several sets of papers for the

Plaintiffs to complete to allow them to adopt from Russia. When the Plaintiffs inquired

about the money they had sent to the Ukraine, Defendant Mozes told them that it would be

deducted from the “international fees”. Finally, Defendant Mozes called and said that

adoptions in Russia had become unstable and that the Plaintiffs needed to chose another

country. He suggested Azerbaijan (“Azer”) or Kazakhstan (“Kaz”). When Plaintiffs

expressed some concerns about the children from Kaz, Defendant Mozes told them that the

kids from Kaz are very healthy due to good baby houses.

28. Once again the paperwork and dossier had to be renewed and it took the

Plaintiffs approximately 9 months. Finally, on or about December 2006, Defendant Mozes

sent the Plaintiffs a referral of a healthy, Caucasian, nine-month old baby girl from the

Almaty region with a request to “make up your minds immediately”. Defendant Mozes

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told the Plaintiffs “If you don’t like your referral, you can choose any other available

kid”. Plaintiffs feeling pressured accepted the referral that evening. Defendants never

disclosed that photo listings and referrals of children are illegal in Kaz.

29. The next morning, after discussing how they felt pressured to accept the

referral, the Plaintiffs telephoned Defendant Mozes to cancel the referral. Defendant Mozes

said he had already sent all the paperwork to the embassy and it was impossible to stop the

process. He stated “the referral was written in stone and there is no way to change your

minds”. Then he told the Plaintiffs “even if you don’t like the baby, you can choose

between other kids in Kaz.” Defendant Mozes repeatedly told the Plaintiffs “IN ALL MY

YEARS OF EXPERIENCE, NOBODY HAS RETURNED WITH EMPTY ARMS”.

30. When Plaintiffs began seeing discrepancies between what the Defendants

would mail and what they would verbally tell their clients, the Plaintiffs asked for

clarification. Defendants assured the Plaintiffs that they could see other babies, all the babies

were healthy and changing regions in Kaz was difficult but not impossible. Defendant

Mozes promised to send health information regarding the referral but none was ever sent to

the Plaintiffs.

31. In early 2007, the Plaintiffs began hearing stories from other AIP clients

where referrals had been lost and many unhappy adoptive parents who had used AIP for an

international adoption. Plaintiffs not wanting to jeopardize their adoption sent Defendant

Mozes sent him an e-mail stating that they didn’t believe all the bad press and expressed

confidence in his integrity.

32. In April 2007, the Plaintiffs and their son went to Kaz to see the baby girl

and other children available for adoption.

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 33. The Defendants arrange for apartments for their clients to live in while

visiting their child in Kaz. The Plaintiffs advised the Defendants that they would prefer to

stay in a hotel but were pressured by Defendant Mozes to stay in the apartment to save

money. Even though the Plaintiffs wanted to be taken to a hotel, the driver took them to the

apartment. The Kaz coordinator, Ekaterina, wanted to charge the Plaintiffs $2000 to stay in

the apartment.

34. The apartment was full of dirt and garbage with only one broken bed. When

the Plaintiffs insisted that they wouldn’t stay in that apartment, Ekaterina and driver took

them to another apartment. This apartment was larger, cleaner and had enough beds.

35. Even though it had only been 36 hours since leaving Pennsylvania, Ekaterina

told the Plaintiffs that they had 15 minutes to be ready to go to the orphanage. They were

told that there was someone from the adoption process waiting for them. When the Plaintiffs

asked if they could cancel because they were so tired, they were told “impossible”.

36. The Plaintiffs were told that the orphanage was in Almaty but it was 2 ½

hours away from the apartment. When the Plaintiffs asked if they could find a home in the

country closer to the orphanage, they were advised that for security reasons, it was not

allowed. When the Plaintiffs finally met the baby that they had been referred to by the

Defendants, it was obvious that she had developmental problems. The baby could not sit up

or rollover.

37. Plaintiff Maria Fullana-Jornet is a medical doctor and recognized several

physical problems immediately. She insisted on seeing the medical records and one of the

orphanage employees told the Plaintiffs the baby was born at 25 weeks. The orphanage

doctor and Ekaterina tried to convince the Plaintiffs that the baby was a healthy baby,

8
plaintiffs were upset and called Defendants to advise them that they would not accept this

referral. Defendant Mozes told them that they would have to change Kaz coordinators.

38. The next day, Kaz coordinator Nigmat arrived and asked for $2000 to make

the changes in the orphanages and complete the paperwork. He told the Plaintiffs it would

take a week to complete. Even though it took several days and Nigmat asked for $300 in

additional funds, the Plaintiffs were having trouble finding a notary to sign the new Power

of Attorney so they could change regions.

39. One evening the Plaintiffs received a call from Ekaterina telling them that

they must return the paperwork back to her or their adoption would be in danger. The

Plaintiffs tried to reach Nigmat but were unsuccessful. Later that night, Nigmat called and

told them that “something was wrong” and he would clarify the next day.

40. Nigmat called the next day and told the Plaintiffs that they were in danger

and that Ekaterina was “after the Plaintiffs”. Nigmat told them to be very careful and not to

leave the apartment. He also told them that he was going away for a few days and they

wouldn’t be able to reach him.

41. The Plaintiffs called Defendant Mozes and told him that they wanted to

move to a hotel if they were in danger. They also expressed concern over Nigmat’s odd

behavior. Defendant Mozes said he would call Nigmat and later called the Plaintiffs and told

them to stay in the apartment. The Plaintiffs were in a strange country with no translator

since the second day of arrival and now were in fear.

42. The next evening, Nigmat called and said he needed to meet with the

Plaintiff to discuss some bad news. When the Plaintiffs and Nigmat met, the Plaintiffs were

told that Ekaterina had threatened Nigmat with reporting to the head of adoptions (in Kaz)

9
and that she would cause problems by exposing problems to the Kaz authorities if the

adoption was turned over to Nigmat. Nigmat advised the Plaintiffs that they had to complete

the adoption with Ekaterina or the only alternative was to return to the U.S. to start all over

again. Nigmat said he would try to get the Plaintiffs dossier back as soon as possible to help

the Plaintiffs be available to adopt. Nigmat also told the Plaintiffs that Defendants would be

returning at least half of the money they had sent.

43. Plaintiffs never heard from Defendants again.

44. In the beginning of the adoption process, the Defendants assured Plaintiffs of

their ability to coordinate the activities in the countries where they offered children for

international adoptions. Defendants sent the Plaintiffs to Kaz with no coordination or

oversight of the process.

45. Defendants assured Plaintiffs that they would receive medical information

on the child that they were going to adopt. Defendants never sent any medical information

to the Plaintiffs. Plaintiffs were told by Ekaterina that the standard second in country visit

would not be necessary for the infant they had met at the orphanage. This would indicate

that all parties knew that the child was a special needs infant and Defendants did not inform

the Plaintiffs. To adopt a special needs child, the home study would have to reflect approval

for a special needs child. The Defendants knew or should have known that the home study

was not approved for a special needs child.

46. Plaintiffs were induced into an adoption that Defendants never intended to

complete through Defendants assurances and misrepresentations. Plaintiffs have been

damaged financially and emotionally by the Defendants illegal activities

Plaintiffs De Lorenzo

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 47. After years of fertility treatments, the Plaintiffs Joe and Dawn De Lorenzo

(“Plaintiffs”) decide to investigate adoptions. On or about April 19, 2006, the Plaintiffs

signed an illusory contract with the Defendants to adopt a child with the Defendants agency.

48. The same day Defendant Mozes sent three separate e-mails with children’s’

pictures and information on each of the children. The e-mail states that the Plaintiffs needed

to obtain a Federal Express account to prevent fraud. Once the Plaintiffs had decided to

move ahead with the adoption they could send the contract and money to the Defendants

and they would make sure “no other party would be accepted for the same child”. It also

stated that only 20% of the time the clients lose their referrals and another “equally lovely”

child would be found for the adoptive parents. (See Exhibits X-X) Defendants never

disclosed that photo listings and referrals of children are illegal in Kaz.

49. On April 21, 2006 the Defendants assured Plaintiffs that the process would

take 2 months for a home study and another 2 months for the dossier preparation.

50. On or about April 25, 2006, Plaintiffs decided to adopt baby #879 Alexander

from Kaz and were told that Defendants would hold the child once the Plaintiffs sent

payment.

51. On April 25, 2006, Plaintiffs sent an e-mail questioning Defendants about

negative feedback she had received when she inquired into the Defendant’s reputation in

international adoption. Defendant Mozes assured her that all she is reading is lies and that no

AIP client gets stranded in Kaz or pays additional fees to travel to outlying areas of Kaz. It is

rare that an adoptive parent has to travel to rural areas and then they are only charged an

additional $300.00. Defendant Mozes claims all the negative feedback is from competing

adoption agencies.

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 52. On April 28, 2006, Plaintiff Dawn De Lorenzo who is a school teacher and

inquires about summer travel and receives assurances from Defendants that he can have her

on a plane within 2 months of receiving the dossier packet.

53. Defendant Mozes sends Plaintiffs a positive reference for AIP. Plaintiffs

explain that they don’t want to fall in love with a child and experience another loss.

Defendants reassure Plaintiffs that there should be no loss and only 20% of referrals are lost.

Defendants tell the Plaintiffs that even if a referral is lost, he can find another equally lovely

child for them to adopt.

54. Plaintiffs ask Defendants for a recent photo of Alexander or they will go to

another agency. The negative feedback on the internet from former AIP clients reflects that

the 80% success rate is much lower.

55. On or about May 9, 2006 Plaintiffs were told by Defendants to send an

additional $2,500 immediately for foreign fees.

56. On or about June 14, 2006, Defendants notified all clients that there were

changes in dossier requirements and now additional paperwork needed to be completed.

57. On or about July 25, 2006, Plaintiffs have an almost completed dossier and

ask Defendants which region they will travel to in Kaz. Defendant Mozes tells Dawn De

Lorenzo that she will find out the region right before traveling and she can pay the balance

of the apartment fees when she arrives.

58. On or about August 4, 2006, Plaintiffs ask where the child lives in Kaz but

gets no response from Defendants. When Plaintiffs point out that other AIP clients are told

where their referral child lives, she is told that clients who travel blind (are not matched with

a referral) are told the region but those with referrals are not given regions.

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 59. On or about August 24 2006, Plaintiffs receive a notice that the Defendant’s

employee Jayne is being replaced by Defendant Anderson.

60. On or about August 28, 2006, the Plaintiffs dossier is complete and received

by Defendants. Defendant Anderson said he needs an additional $440 to complete the

paperwork but promises completion before the end of the week. When Plaintiffs ask if the

baby boy is still available and the region he is in, Defendant Mozes advises Dawn De

Lorenzo that “Updates are difficult and she can’t mention updates to anyone”. Mozes

reassures Plaintiff that the child is still available but will only advise her if he gets another

update from Kaz. Plaintiffs ask Defendants generalized questions about travel but

Defendants evade answering the questions.

61. On or about October 5, 2006, Plaintiffs receive a call from Defendant

Anderson advising that 12 dossier documents were not apostilled correctly. Plaintiffs make

special arrangements to get these mistakes corrected immediately but wondered why it has

taken Defendants 6 weeks to identify the problems.

62. Throughout October 2006, the Plaintiffs place several calls to Defendants to

determine the region they will be traveling to in Kaz but Defendants evade answering the

questions and later quit taking calls from the Plaintiffs.

63. Plaintiffs post their frustrations on their on line blog. Defendants threaten to

drop the Plaintiffs as clients because the Plaintiffs have communicated by e-mail with other

AIP clients in violation of the illusory contract. Defendants warn the Plaintiffs if they stop

the process, they will get no refund of the money paid. Plaintiffs send a Demand Letter

asking for a full refund of their money on October 17, 2006.

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 64. The Plaintiffs receive an e-mail from Defendants reminding them that they

must mediate any problems in California before filing any lawsuit. Defendant Mozes

threatens to stop the Plaintiffs adoption because they have violated the contract. No

details on how the contract was violated were noted. Plaintiffs respond to Defendant Mozes

by calling him an emotional rapist by promising services and children but not fulfilling his

obligations.

65. On or about October 24, 2006, Plaintiffs ask Defendants if the dossier has

been translated and is told that it has not been translated yet.

66. In November 2006, Defendant Anderson advises Plaintiffs that the dossier

needs to be translated, then sent to the embassy in Washington DC and then the dossier gets

sent to Kaz. Once it is approved by Kaz, a Letter of Invitation (“LOI”) will be issued by the

Kaz government. Mid-November the Plaintiffs dossier is sent to Kaz and Defendants advise

the Plaintiffs it will take another 6-8 weeks before the LOI is issued by the Ministry of

Education.

67. On or about December 10, 2006, Defendant Mozes sends an e-mail to the

Plaintiffs advising them that the child that they were to adopt, Alexander, was no longer

available but “he was looking for a really wonderful boy” for the Plaintiffs. No reason

was given to explain why Alexander was not available except for a reference to a paperwork

problem. (See Exhibit X)

68. Plaintiffs are devastated by the news from the Defendants and have to take

time off from work to process through the feelings of loss and grief associated with losing

the child they thought they were going to adopt.

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 69. The next day, December 11, 2006, Defendants promise a new referral shortly

and that the Plaintiffs LOI should be issued by the end of December. The Plaintiffs are

advised not to travel blind (without a referral to select an adoptable child) and that they

should be ready to travel in mid-January 2007.

70. On or about December 15, 2006, Plaintiff Joe De Lorenzo communicates to

Defendants that he understands that there are bad feelings between Dawn De Lorenzo and

Orson Mozes but that the Defendants are obligated to complete the arrangements. Plaintiff

Joe De Lorenzo tells Defendants that the travel must have the following requirements; 1) No

remote city, 2) there must be a translator and driver at all times, 3) Plaintiffs expect to be

shown healthy kids in the correct age range, 4) no bribes before arriving at the baby house,

and 5) no bribes under any circumstances.

71. On or about December 27, 2006, the Defendants e-mailed the Plaintiffs the

visa application but evade Plaintiff’s questions on when to book flights. Finally Defendants

tell Plaintiffs that they will travel between January 14th and 21st. Plaintiff Dawn De Lorenzo

had to take a job as a substitute teacher with her school district to accommodate the

continual changes of their travel dates for the adoption.

72. On or about January 8, 2007, Defendants advise that the travel date has been

pushed back to January 28th. The next day, Defendants sent Plaintiffs information on baby

boy, Stanislav (nickname Stas). The defendants accept this child as their new referral.

Defendants send the medical information and information on how to wire money.

Defendants instruct the Plaintiffs to wire $2,000 and that there is an $8,000 balance due

when they arrive in Kaz plus lodging and other amenities. A 42 day stay in Kaz will cost

$7350.00. Clients pay $175.00 per day for an apartment, driver and translator.

15
 73. Plaintiffs inquire whether this will be a two trip visit for adoption (consisting

of 42 days and later an additional 13 days) or a one visit trip of 60 days. Defendants advise

the Plaintiffs for the one trip option the cost is $10,500 or $175/day.

74. Plaintiffs wire the money on January 15, 2007. On or about January 18,

2007, Plaintiffs receive news that the travel date may be pushed back to March 2007. When

the Plaintiffs express anger about the unbearable stress and inconvenience to get time off

from work, they are told that the staff in Kaz is bad and they are incompetent people and it

isn’t the Defendant’s fault. Plaintiffs advise that if there are no guaranteed travel plans, they

want a refund and the dossier returned

75. On or about January 22, 2007, Defendants advise that the travel time is now

February 12, 2007 with only a 10% chance that something will change the date.

76. On February 1, 2007, Defendants sent new pictures of Stas to the Plaintiffs.

77. On February 5, 2007, Defendants push back the travel dates to the end of

February. Defendants blame the delay on incompetence in Kaz.

78. On or about February 7, 2007, Plaintiffs were asked by Defendants what

they were going to name the boy. The Plaintiffs responded “Stephen Joseph”. Defendants

sent wire instructions for the remaining $9950.00 owed.

79. Defendants advise Plaintiffs that they can get an expedited visa if they pay

$180 for visa expedition.

80. Defendant Mozes asks Plaintiffs to have their friends post on line that the

Plaintiffs had received their LOI and to say kind things to make AIP look good to others.

81. On or about February 9, 2007, Defendants tell Plaintiffs they are cleared to

book their flights to Kaz. The first available flight is February 18, 2007.

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 82. While waiting to travel, Defendants encourage the Plaintiffs to take an

additional $2500 to bribe the Kaz judge in charge of the adoption to waive the waiting

period. When questioned about it, Defendants tell the Plaintiffs to only offer it if it appears

that the judge will grant the waiver. Defendants want Plaintiffs to post pictures of Stephen

on her blog but Plaintiffs refuse until the child is back in the United States.

83. On February 18, 2007, the Plaintiffs flew to Kaz. While waiting to go to Ust-

Kamengorsk, the Plaintiffs were met by Nigmat who asked for the remainder of the foreign

fees, apartment fees, driver and translator fees and $1,500 bribe money for the judge. It is a

Tuesday and the translator and driver are available to tell the Plaintiffs that their visit to the

orphanage will be on Thursday since the coordinator, Almagul, is stuck in Astana.

84. Defendants e-mail Plaintiffs while they are settling in Kaz and, once again,

encourage Plaintiffs to post something positive on her blog BUT not to put photos of Stas on

the blog because “he is too cute and you never know who is reading the blog”.

85. On February 22, 2007, Plaintiffs visit Stas and he is sick with a cold. Pictures

are taken and Plaintiffs are told that they can’t visit on the weekends. Later Defendants tell

Plaintiffs that there will be no delays in the adoption and implied that the adoption judge

will take the bribe, waiving the 17 day waiting period.

87. On March 1, 2007, after celebrating Stas’ first birthday at the orphanage,

Plaintiffs receive a phone call from their interpreter who informs them to be ready earlier

than usual in the morning because the representative from the MOE, Oksana, wants to speak

with them about something. Plaintiffs contact Defendants and want to know why Oksana

wants to speak to them and about what. The Defendants warned the Plaintiffs not to

mention referral photos or money to anyone, especially MOE!

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 88. On March 2, 2007, Plaintiffs are told by Nigmat that the birth mother of Stas

has returned and decided not to give him up for adoption. Plaintiffs are encouraged to

choose another child the same day!. Plaintiff Joe De Lorenzo wants to return to the U.S. but

Plaintiff Dawn continues to visit the orphanage until she is matched with another child,

Andrey. After three days of mourning, Joe returns to the orphanage with Dawn and they

accept Andrey and must begin the entire fourteen day bonding process over again. Plaintiffs

name this referral Stephen. From this point forward, references to Stephen, are addressing

Andrey.

89. On or about March 10, 2007, the Plaintiffs ask for more frequent visits with

baby Stephen because Plaintiff Joe De Lorenzo needs to return to the states for his job after

court and only Dawn will have extra bonding time. Plaintiffs are told that they should be in

court at the latest March 19, 2007.

90. On or about March 18, 2007, Claudia Wessel reads Plaintiffs blog and e-

mails the Plaintiffs that she had been promised the same baby by the Defendants. When

Plaintiffs confronted Defendant Mozes, he warns them to keep it quiet. Defendants advise

Plaintiffs that all is well, not to worry.

91. On March 19, 2007, Plaintiffs go to court and their adoption is granted. Joe

flies back to the United States the same day. Dawn stays to complete the mandatory waiting

period.

92. On April 3, 2007, Dawn is anticipating picking up Stephen from the

orphanage. When Almagul arrives to pick her up she inform her that this child’s mother has

filed a complaint in court and that she is fighting the court’s decision to grant the adoption.

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 93. By April 9, 2007, Plaintiff Dawn De Lorenzo is abandoned in the Kaz

apartment without a driver or translator or any other services. When she contacts the

Defendants to find out where the driver and translator are, they promise to look into it.

94. Due to trouble with a wire transfer, the Defendants harassed the Plaintiffs

about money. With Plaintiff Joe De Lorenzo back in the U.S. and Plaintiff Dawn De

Lorenzo in Kaz, Joe advises Defendants to communicate only with him regarding the

money transfer. The delay was caused by banking formalities.

95. On April 12, 2007, Plaintiffs realize that the adoption does not look as if it

will be completed. Plaintiff Joe De Lorenzo warns Defendant Mozes of the emotional harm

that Dawn will suffer if this adoption fails. He demands a full refund if the adoption fails

and no child is brought home.

96. On April 17, 2007 Dawn returns to court to fight for their son, but the

birthmother does not show up and the hearing is postponed to April 19, 2007. This delay

causes Dawn to pay Almagul $250.00 to extend her visa which expires on April 19, 2007.

Dawn has now been in Kaz for 57 days.

97. On April 19, 2007 the courts hear the birthmother’s objections, but the case

needs to go before another court. With no ruling in site Joe and Dawn decide that she must

fly home. Almagul has Power of Attorney and assures them she will attend any and all court

proceedings. Dawn flies back to the United States on April 20, 2007.

98. After several requests for updates, the Plaintiffs finally find out that the first

court date for the appeal will be May 16, 2007. On May 16, 2007, the birth mother and her

attorney are no shows for the hearing. Kaz court adjourns the hearing to May 30, 2007.

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 99. Plaintiffs send e-mails to Defendants requesting updates on the May 30th

hearing but none of the Defendants would tell the Plaintiffs what happened at the hearing.

99. On or about June 15, 2007 Plaintiffs receive a letter from the courts in Kaz.

However, it is written in Russian. They ask the Defendants to have the letter translated, but

they are being put off and told that the translator that AIP works with is on vacation.

100. On June 30, 2007, Plaintiffs called the Kaz embassy who confirmed that

Defendant Mozes is no longer allowed to work in adoptions in Kaz. Plaintiffs are aware that

Nigmat is not an attorney and cannot represent them in Kaz. The Plaintiffs are told that

Almagul would no longer go to court for the Plaintiffs but they were told by Defendants that

she did go to court for them.

101. In July 2007, the Plaintiffs are forced to hire an attorney in Kaz to try to

complete the adoption of Stephen.

102. On July 16, 2007, Defendant Anderson advised that the Defendants stopped

working on behalf of the Plaintiffs at the Plaintiffs request. The Plaintiffs never requested

that the pursuit of the adoption stop. Defendants did no further work to complete the

adoption of Stephen.

103. Plaintiffs hired Defendants to facilitate an adoption. After being matched

with three boys and giving their hearts to each one, they lost them one by one. The

Defendants did nothing to assist the Plaintiffs but induced them into an adoption process by

offering children that were not available through an illegal process, leaving the Plaintiffs

financially and emotionally devastated.

20
 104. The Plaintiffs have lost over $76,785.00 by being induced into a fraudulent

adoption scheme. Plaintiffs have been damaged financially and emotionally by the

Defendants illegal activities.

Plaintiffs Jury

105. In February 2006, the Plaintiffs Jury (“Plaintiffs”) decide to investigate

adoptions through using the Defendants. Defendant Mozes sent photo listings of babies

#815, 913 and 906 to the Plaintiffs to review for a referral.

106. On or about February 5, 2006, the Plaintiffs are told to wire $8850.00 to

the Defendants and they will “hold” baby #815. The Defendants also sent a lengthy e-

mail describing the adoption process, their experience and why the Plaintiff’s should trust

the Defendants. Much of the inducement for the Plaintiffs centered on the fact that the

Defendants are licensed to perform adoptions by the State of Pennsylvania. (See Exhibit

x)

107. Plaintiffs wired money to the Defendants but expressed concerns over

sending so much money when the required home study hadn’t been done or approved.

Defendants assured Plaintiff Frank Jury that it is rare to have a home study denied but if

denied there would be no refunds of the fees spent up to that date. In March 2006,

Plaintiffs ask Defendants for approximate travel dates, so Plaintiff Frank Jury can plan

for time off of his job working for a professional hockey team. Plaintiffs are told to plan

to travel in “summer to fall 2006.”

108. Plaintiffs ask for information on the region where baby #815 is located but

the Defendants refuse to give any further information. They are told to concentrate on

21
learning the Kaz language. In May, the Plaintiffs wired Defendants additional money to

cover foreign fees. Defendant Kevin Anderson confirmed receipt of the money.

109. In June 2005, Plaintiffs are told by Defendants employees that they have

not completed their Dossier correctly. Plaintiffs ask if the home study needs to be

completed before submitting the I-600A but the Defendant’s staff didn’t have the answer.

The staff told the Plaintiffs that the original home study has to be notarized and apostilled

along with the Doctor’s reports, photos and other documents.

110. In August 2006, Plaintiffs asked Defendants again about the region where

the baby #815 (now called Sanjar) was located. Defendants continued to refuse to tell the

Plaintiffs where Sanjar was located. The Plaintiffs noticed that since the Defendants have

received the $11,850.00, the communication from Defendants had virtually ceased.

Plaintiffs expressed these concerns to the Defendants. Plaintiff Frank Jury also clearly

explained the impact of taking 8 weeks away from his job and how it caused problems.

(See Exhibit X)

111. In September 2006, Defendants advised the Plaintiffs that they were

checking to see if Sanjar was still available. Later they told the Plaintiffs that “they

weren’t able to get the information because the Plaintiff’s dossier wasn’t in Kaz.”

112. In October 2006, Defendants still weren’t sure where the Plaintiff’s

dossier was located but promised to look into it.

113. On or about November 16, 2006, Plaintiffs received a letter advising them

that their dossier had been sent for translation and that they would be updated during the

process. The Plaintiffs were told to begin working on their visa applications.

22
 114. On or about November 30, 2006, the Defendants advised Plaintiffs that

baby #815 was no longer available but sent photo listings of other male children for them

to review and choose. Defendants also told the Plaintiffs “not to share the new boys’

information with anyone.” (See Exhibit X) Defendant Mozes sent e-mails and called

the Plaintiffs several times to pressure them into accepting a new referral, Dmitri Ilyas. In

his calls he stated “If you don’t accept this referral, it could go to someone else and it

may be a long time before another child is available.” When Plaintiff Frank Jury asked

how they could trust Defendants to hold this child, Defendant Mozes stated “If you send

over money each week to the people in Kaz they will be more likely to hold the child

for you.”

115. In December, Plaintiff Kim Jury wrote the Defendants a long letter

explaining how she had given her heart to Sanjar for 9 months and the emotional impact

of losing the referral. She described having to tell friends and family that they weren’t

going to adopt baby #815, Sanjar and how her heart hurt. (See Exhibit X)

116. In January 2007, Defendants advised the Plaintiffs that they could expect

their LOI in 14-21 days and that the Plaintiffs should be prepared to pay the remainder of

the foreign fees at that time. Plaintiffs expressed concern that their home study would

expire in April 2007 but are told by Defendants that it is “yet unexpired”, indicating

there was nothing to worry about.

117. When Plaintiffs advised Defendants that they were only taking one trip

and not two, the Defendants tried to charge the Plaintiffs approximately $2000 extra

dollars. The extra fees were different from the fee schedule that was spelled out clearly in

the adoption information provided earlier by the Defendants. Defendants were adamant

23
about the Plaintiffs taking 2 trips. When in frustration, Plaintiff Kim Jury wrote to the

Defendants telling them that she now understood why Dawn and Joseph De Lorenzo

were threatening to sue the Defendants. Defendant Orson Mozes responded that “the De

Lorenzo’s are very happy.” (See Exhibit X) Defendant Orson Moses told the Plaintiffs

that ‘they needed to travel as soon as possible to ensure that they didn’t lose the new

referral.” Even though this was during the prime hockey season and leaving might mean

that Plaintiff Frank Jury could lose his job, the Plaintiffs felt compelled to follow the

Defendant’s advice. As soon as the Plaintiffs left the apartment in Kaz, Plaintiffs Claudia

and Stefan Wessel traveled and occupied the same apartment. This would indicate the

Defendants wanted Plaintiffs Jury out of the apartment because they had another family

ready to occupy the apartment.

118. While in Kaz, in April 2007, Plaintiff Frank Jury wrote the Defendants

about the multiple bad experiences he was having in Kaz. He titled his e-mail “helpless in

Kazakhstan” and asked when the departure date was for the Plaintiffs. He clearly

described being left helpless in Kaz with a toddler and no outside assistance. Defendant’s

response was “he was letting everyone know”. (See Exhibit X)

119. On or about June 18, 2006, Defendant Kevin Anderson advised the

Plaintiffs that they were missing Powers of Attorney (“POA”) from their package and the

Plaintiffs needed to correct this as soon as possible because “the Judge pushed the

adoption through without the right POA.” (See Exhibit X)

120. On or about July 2007, after the Plaintiffs returned home with the baby,

the Plaintiffs asked for a return of overpayment for the apartment and receipts for tax

purposes. But over the next 2 months, the Defendants used multiple excuses not to refund

24
any money to the Plaintiffs or provide receipts. The Plaintiffs had even provided the

information for the Defendants to produce a receipt. (See Exhibit X)

121. The Plaintiffs returned home with their son, Dmitri, but not before being

fraudulently induced into a referral that failed and later being compelled to travel which

caused Plaintiff Frank Jury to lose his job with the hockey team. The Plaintiffs were

overcharged for much of the work done by or for the Defendants. Due to the Defendants

negligence, the Plaintiffs have lost the apartment that was provided as a member of the

hockey team staff, as well as the salary Frank would have been making. It was through

the Defendants fraud and negligence that these Plaintiffs have suffered financially and

emotionally.

Plaintiffs Schulze

122. During the month of May 2007, Plaintiffs Flynt and Kristy Schulze

(“Plaintiffs”) searched the internet researching international adoptions. They were

confident that an Azerbaijan adoption was what they wanted to pursue. During that search

they sent an e-mail inquiry to Defendants. Almost immediately (after sending a contract),

Defendant Mozes called. Mozes made the adoption seem easy and problem free and

implied that he had the smoothest adoptions in the business. When Plaintiff Kristy

Schulze asked why his agency fees were higher than other agencies, he responded that he

“was not a non-profit agency, but that was good for folks like you who want a quick

adoption.” Mozes said that his agency didn’t have to jump through the hoops that the

others had to as non-profits. He also told the Plaintiffs that he had “connections that

enable him to get the job done quicker, with special perks to AIP families, such as

25
better in country facilities, a better relationship and more rights at the baby

houses.”

123. Plaintiffs contacted Defendants to inquire about adopting from Kaz or

Azerbaijan (“Azer”). Plaintiff Kristy Schulze inquired about 5 different photo listings of

children offered for adoption by the Defendants. Once he knew that the Plaintiffs

preferred a very young child, Defendant Mozes assured Plaintiffs that Kaz adoptions

were better than Azer because the children were younger. Even though Defendant Mozes

had led the Plaintiffs to believe that they were looking at babies from Azer.

124. Plaintiffs were told on May 31, 2007 that they had a 95% chance of

bringing home Baby #87 by the end of 2007. Defendant Mozes told Plaintiffs to send the

agency fees by cashier’s check immediately to hold the child. While Defendant assured

Plaintiffs that he “always gets the most attractive and smartest children because of

his connections.” (See Exhibit X)

125. Plaintiffs signed a contract with the Defendants on June 3, 2007 to begin

an adoption. Part of the instructions for sending money to the Defendants clearly directed

Plaintiffs to send the money to the “satellite office” at 1373 School house Road, Santa

Barbara CA 93108. Although licensed by the State of Pennsylvania, the Defendants were

physically located in California and only used the Pennsylvania license as a mechanism

to gain trust from their clients. (See Exhibit X)

126. On or about June 5, 2007, the Plaintiffs paid $8,850.00 to the Defendants

advising them to hold baby #87. (See Exhibit X)

127. On or about June 6, 2007, the Defendants sent information about baby #87

whose name is Kseniya.

26
 128. On or about June 20, 2007, Plaintiffs inquired about adopting 2 children and

Defendants responded that Defendants would check into it before the Plaintiff’s trip to Kaz.

Defendant Orson Mozes knew at that time that only sibling groups are allowed when

adopting more than one child but withheld this information from the Plaintiffs. Yet on or

about June 28, 2007, Plaintiffs learn from Defendant Kevin Anderson that only sibling

groups are allowed to be adopted. (See Exhibit X)

129. On July 2, 2007, the Plaintiffs received an e-mail instructing them to wire

$3,000 to Ravil Ramazanov. Plaintiff Kristy Schulze questioned why this was different

that the fee packet had instructed them when they first began working with the

Defendants and was told by Defendant Anderson “that email went to a number of

clients, which is why the amount was wrong. A portion of the foreign fee will be

wired at different times during the adoption process. Our coordinator is currently in

Uzbekistan, which is why the money must be wired to him there.” (See Exhibit x)

130. On or about July 18, 2007, Defendant Kevin Anderson called Plaintiff Kristy

Schulze to advise that the child was still available but “she must wire the money to the

coordinator immediately or he couldn’t guaranty that baby #87 wouldn’t go to another

family.” Feeling under pressure, the Plaintiffs wired the money as instructed.

131. On or about August 10, 2007, the Plaintiffs received an e-mail advising them

that the Defendants adoptions were under scrutiny at the U.S. Embassy in Kaz. (See

Exhibit x)

132. On August 13, 2007, Plaintiffs called Defendant Anderson to inquire about

the Embassy investigation and was told that Defendant Mozes had left town and was

missing. He assured Plaintiffs that Defendant Brown (as owner of the Agency) was very

27
ethical, honest and wanted to make sure that all adoptions were completed. He stated at that

time that they would probably complete all adoptions through Heritage Adoptions.

Plaintiffs asked why they were asked to wire money when Defendants Anderson and Brown

knew that Defendant Mozes was gone. Plaintiffs were told that they were the last family

asked to wire money. When Plaintiffs verbally requested a refund they were told to “put it

in writing.”

133. On August 13, 2007 and again on August 15, 2007, the Plaintiffs sent letters

to the Defendants requesting a full refund. They had found out that Defendant Mozes had

disappeared and that the United States Embassy in Kaz was investigating the Defendants.

The Plaintiffs clearly explained how they had been induced to use the Defendant’s agency

by Defendant Orson Mozes and how Defendant Kevin Anderson instructed them to wire

money to Kaz even when he thought it was a bad practice. (See Exhibit X)

134. Plaintiffs were induced into an adoption that Defendants never intended to

complete through Defendants assurances and misrepresentations. Plaintiffs have damages

in excess of $11,850 plus legal fees to recover their money. Plaintiffs have been damaged

financially and emotionally by the Defendants illegal activities

Plaintiff Newton

135.Plaintiff Lisa Newton (Plaintiff) was the founder, Principal, CEO and co-owner

of the Draw Acadamy, a private PreK-8 school with 250 students in Texas, when she

began investigating adopting a child. She contacted the Defendants to check into the

photo listings of five girls. Defendants sent Plaintiff general health information. While

trying to decide which little girl to adopt, the Defendants called to encourage Plaintiff to

“put money down soon to hold the infant.”

28
 136.On or about February 16, 2006, Plaintiff signed the Defendant’s illusory contract

to adopt a child from Kaz. Plaintiff sent her fees and was assured by Defendant Mozes

that “We can hold this child while you do your home study and immigration and get

your dossier together. All agency fees are in this email.” Defendant Mozes also told

Plaintiff that although he couldn’t guaranty the child she had chosen as a referral, there

was a 95% chance of her getting her referral and the adoption would move along very

fast. If she would hurry and send $11,850, he would take the child’s photo down from the

photo listings. (See Exhibit X)

137.On or about March 1, 2006, Plaintiff shared the good news with family that she

was adopting baby girl #906 and that she was assured by Defendants that it would be

competed. Plaintiff put up the picture of the girl at home and in the school where she

worked, using the adoption as a tool to teach students about adoption and geography. Her

business partner was aware of the time required away from the school to travel to visit

her adopted daughter.

138.On or about July 2006, Plaintiff was told by Defendants that she had lost her

referral, little girl #906 but quickly sent an e-mail with information on a “new girl”.

Plaintiff accepted the “new girl”. After giving her heart once again to another little girl

#906, Plaintiff received a series of e-mails from Kaz directly from the other AIP clients

telling her that they were traveling to bring that little girl home and complete their

adoption of her as their child.

139.On or about July 20, 2006, Plaintiff was told by Defendants that her papers had

all been approved by the Kaz government and she should be ready to travel to Almaty in

4-6 weeks. Now Plaintiff was to travel blind to choose a child when she arrived in Kaz.

29
 140.On or about July 28, 2006, Defendant Mozes told Plaintiff that she “may

jeopardize her Kaz adoption” because she posted comments on an on-line group.

Plaintiff responded by removing herself from the group. She also quickly reassured

Defendant Mozes that she didn’t say she had “lost a referral but that she had lost a photo-

listing.” Defendant Mozes knew at this time both referrals and photo-listings were

prohibited by the Kaz government but used the on-line group information to intimidate

the Plaintiff.

141.In August 2006, the Defendants advised Plaintiff that her paperwork had “just

arrived” in Kaz and that the travel dates would now be 6-8 weeks away when she

received her LOI. The Defendants told Plaintiff that the Kaz government closes for

vacation during the month of August so nothing would be done during that time.

142.Over the summer of 2006, Plaintiff’s business partner told her that the stress of

the adoptions and lost referrals had caused her to lose her focus. She was asked to have

limited contact with the school staff and children and she was told that her leadership

abilities had been compromised from the ongoing strain of the adoptions. Plaintiff had to

reduce her hours at work and disseminate some of her duties to her business partner.

143.On or about August 14, 2006, Plaintiff accepted a new photo listing from

Defendants for baby # 951. Child #951 is a child born prematurely and Plaintiff asked

whether baby #951 would be considered a special needs child qualifying for Texas

subsidies. Defendant Mozes replies “They said they could mark special needs because

all children that are orphans have special needs”. Defendants knew that the Plaintiff

wanted a mentally healthy child but would accept a physically challenged child. Later

when the Defendants sent medical paperwork on the child it was obvious that the medical

30
reports belonged to another child, not child #951. The medical report sent had the

incorrect eye color, hair color, birth weight and scores. This was another attempt to hide

the true medical information on the child to induce Plaintiff to continue to adopt.

144.On August 24, 2006, Plaintiff received her LOI and visa support number. On the

same date, Defendant Mozes sent all clients an e-mail advising them that he was aware of

complaints about his service and that due to governmental problems, there was a risk of

losing referrals. In fear of falling out of favor with the Defendants and jeopardizing her

adoption, Plaintiff sent Mozes an e-mail vowing her support.

145.Plaintiff called to verify that baby #951 was indeed still available at the baby

house before she traveled to Kaz. The day the Plaintiff flew to Kaz, the other AIP family

arrived in the U.S., having completed their adoption of the second referral the Plaintiff

had been promised by the Defendants.

146.Plaintiff arrived at the baby house to find a very sick baby #951, now named

Dinara. Plaintiff decided to complete the adoption of this special needs child and brought

Dinara home. Once home, Dinara was evaluated by a specialist for international adoption

medical evaluations and found her to be Severally Delayed One Year. Dinara was 16

months behind in all ways. This was not just a premature baby, Dinara has special needs

and may always need Special Education. Dinara continues to be evaluated as a special

needs child and learning disabled.

147.The Plaintiff began this adoption as a CEO/Principal who at the time of her

adoption with the Defendants she was earning $124,000.00 per year with full benefits

paid. She was forced to resign her position and sell her business due to the ongoing stress,

delays and actions of the Defendants. Plaintiff now works in the public schools systems

31
as a contract employee, making half of her former wages and has to contribute to fund

her benefits through the public school system. Plaintiff has been unable to secure an

administrative position in the new school district. Plaintiff has been damaged financially

and emotionally by the Defendant’s illegal activities

Plaintiffs Schaefer

148.On or about March 27, 2007, Plaintiff’s Gerald and Megan Schaefer

(“Plaintiffs”) inquired information on the photo listings for child #45. Plaintiffs advised

the Defendants that their homestudy was already done and wondered what the timing was

for completing an adoption with the Defendant’s agency. Defendant Mozes responded

with “When you give us the dossier most clients are on the plane 2 to 2 ½ months

later. The Kazakhstan embassy takes about two weeks to process our client’s

dossiers. We have never had a client refused. Very good chances we are really

working closely with the area. It would be almost impossible to adopt a Caucasian

child without holding her too much competition. Remember no one can adopt her

until July so that is really in your favor…” (See Exhibit X)

149.Plaintiffs signed the Defendant’s illusory contract and began discussing fees.

Defendants demanded $10,100 to hold the child ($8,850 agency fee plus $1250 foreign

fees with the foreign fee balance being $15,200). Defendants are told that the Plaintiffs

will need to transfer money but can send half of the money now. Defendants urge the

Plaintiffs to send some money.

32
 150.On or about March 29, 2007, Defendants take Baby #45 off of the photo listings

and write to the Plaintiffs to tell them that there are now two other families interested in

the same child that showed interest “the minute we took the listing down.”

151.On or about April 5, 2007, Defendant Anderson sent the Plaintiffs e-mails with

the dossier packet as an attachment.

152.On or about April 16, 2007, Plaintiffs advise Defendants that their current home

study provider, Bethany, will not update their home study to reflect a Kaz adoption

because it would jeopardize Bethany’s ability to do adoptions in Kaz. Bethany told the

Plaintiffs that their Kaz facilitator had never heard of AIP. Defendant Mozes responded

“This is not true. No one would be jeopardized.” (See Exhibit X)

153.Throughout the month of April 2007, Defendant Anderson helped the Plaintiffs

complete their dossier. On or about May 7, 2007, Defendant Anderson told the Plaintiffs

that their dossier looked to be in “perfect order”.

154.On or about May 30, 2007, the Plaintiffs inquired about the dossier clearance

since it was sent for translations three weeks prior. Defendant Anderson advised that the

“Courier has to get two more documents apostilled.” Anderson blamed the embassy

and said that they (the embassy) were not doing things on schedule. He advised that the

Courier could go in 2 days to have the documents apostilled.

155.The next day, June 1, 2007, Anderson sent an e-mail that admitted that he is the

courier but since it is a Friday, he wouldn’t be able to go until the following Monday.

Plaintiffs told Defendant Anderson that they had paid extra to expedite the dossier and

there had been nothing but delays by the Defendants. Plaintiff’s offer to do part of the

work if it would help.

33
 156.On or about June 5, 2007, Defendant Anderson told the Plaintiffs that the

documents were finally apostilled and the dossier would be sent to Kaz on this date. He

told the Plaintiffs that they would go to Ust region for their adoption.

157.In June and July 2007, the Plaintiffs e-mail the Defendants for updates but were

told that they (Defendants) won’t know anything until the LOI is issued.

158.On or about August 6, 2007, Plaintiff Megan Schaefer had a telephone

conversation with Defendant Brown. Plaintiff asked for an update as Defendant Anderson

told her that they hadn’t heard from the Kaz coordinators in over 2 weeks. Defendant

Brown indicated that the other adoption agencies rushed in to the MOE to report that

there were changes at AIP and the changes were why the MOE was asking for new

paperwork from AIP before they would start processing adoptions again. Defendant

Brown said “This is all just part of International Adoption! There have been other

times when dossiers were held up for a month. It will start moving again, you just

need to have faith. Everything happens at the right time so you will be over there at

the perfect time to meet YOUR child.”

159.On or about August 27, 2007, Plaintiffs called and wrote the Defendants. It had

now been 4 months since the dossier was sent to Kaz. Plaintiffs told Defendant Anderson

how their lives have been on hold during this wait because they never knew if they would

have to travel. Plaintiffs tell Defendant Anderson how they are afraid that their papers

will expire. Defendant Anderson responds “I understand your frustration.

Unfortunately, every one of our clients is in the same situation you are in. With

documents expiring, time is of the essence for everyone except the Ministry of

Education, who has the final say in the matter. At this time, I have no updates on the

34
status of dossiers or children. We are finishing an agreement with another agency, so

we can submit dossiers through them, but that process is not finished yet….”

160.On or about September 19, 2007, Plaintiffs received the Transfer Notice that their

adoptions were being transferred to Heritage Adoptions.

161.On or about October 9, 2007, Defendant Anderson sent his new contact

information to the Plaintiffs. It came from a Heritage adoption e-mail account and he

gave the Plaintiffs the new telephone numbers. (See Exhibit X)

162.In October 2007, Plaintiffs received an e-mail greeting from the Directors of

Heritage Adoptions welcoming Defendant Anderson as an employee working in

California, offering the Plaintiffs a chance to sign a new contract with Heritage for the

small fee of $1,000.00. (See Exhibit X)

163.On or about October 10, Plaintiff Megan Schaefer e-mailed Defendant Anderson

to advise that she wanted her files returned to her and did not want Heritage to have her

personal information. Defendant Anderson replied “I know nothing about your request

for documents to AIP. I am no longer involved with that agency in any way.” (See

Exhibit X)

164.Plaintiffs have not received a refund and have paid for documents and home

studies that have or will soon expire. Defendants have been unjustly enriched by inducing

the Plaintiffs into an adoption using illegal photo listings. Plaintiffs have been damaged

financially and emotionally by the Defendants illegal activities

Plaintiffs Wessel

165.xxxx

166.

35
Plaintiff Bushouse

167.On or about November 29, 2004, Plaintiff Candace Bushouse (“Plaintiff”) signed

the Defendant’s illusory contract to adopt a child through the Defendant’s agency. On or

about that date she sent $12,850 to the Defendants and wired $5,000 to Kaz to “hold a

child” which was a little girl that she had seen on the Defendant’s photo listings. The

Defendants sent the Plaintiff the package to get her dossier completed.

168.In February 2005, Plaintiff gave up her referral knowing that she had just began

the adoption process and the little girl was able to be adopted during the time it would

take to get the dossier approved. At the time she gave up her referral, Defendant Mozes

told her “I guarantee that we will have another girl available in three weeks.”

169.In June 2005, Plaintiff discussed with Defendant Mozes that she knew that she

was traveling blind but wanted some assurances that she could get her dossier returned if

she didn’t find a child to adopt. She also reminded him that it was now five months later

and the Defendants have not given her another referral. She requested some new photo

listings to choose prior to traveling. Defendant Mozes responds “No children before you

leave they must be off the registry and we will show you a wonderful child girl fare

healthy Caucasian under a year when you get there. We went over this. Money has

to be paid when you get there. Yes you can get your dossier back. No one has more

children than us so that would be a mistake but like you said it is a life decision so I

understand.”

170.On or about September 9, 2005, Defendants sent Plaintiff a photo listing of child

#823. Defendants sent a message that the Plaintiff has made a mistake on her fee payment

and a demand for payment to “hold the child”.

36
 171.On or about September 19, 2005, Plaintiff accepted child #820 as a referral. The

child’s name is Abramova Vilena. The Plaintiff told Defendants that she had some

concern about their interpreter and was concerned about traveling as a single mom with a

child. Later the Plaintiff found out that this little girl was adopted by another family.

172.On or about November 1, 2005, Defendants promises that the LOI should be

coming by November 12th. But Defendants claimed that they were having trouble

“connecting with Kaz”.

173.Plaintiff told Defendants that she had already adopted her first son from Kaz by

traveling blind and it only took 9 months from start to finish and now with Defendants

agency, she has to worry about her documents expiring before she gets her LOI.

174.On or about January 25, 2006, Plaintiff asked Defendant if 8 weeks to issue the

LOI was still correct and was told by Defendant that “the agency was taking care of the

LOI.”

175.On or about March 24, 2006, Plaintiff finally left Michigan for Kaz to arrive on

March 26, 2006. Plaintiff was to be working with coordinator named Gabit. Plaintiff was

told by Defendants that she was traveling to Ust-Kamagorsk and had purchased plane

tickets to Ust-Kamagorsk. Upon arrival she was told that she would be traveling instead

to Uralsk. No reason was given and the funds for the extra plane ticket were wasted.

176.By April 13, 2006, Gabit had disappeared. After several inquiries, Plaintiff was

told that Gabit was working with another family in Astana. During this period, Plaintiff

was bonding with her baby McKayla.

177.On or about April 19, 2006, Plaintiff completed her required bonding period but

Gabit was still missing and no court date had been arranged. From April 19th to the 23rd ,

37
the Plaintiff was left messages by Gabit and Defendant Mozes giving her 3 different court

dates. Plaintiff told the translator that with Gabit missing and no confirmed court dates

that she was going to call the American Embassy. Gabit returned on April 24, 2006 and

the Plaintiff had to remind Gabit to get a court date.

178.On or about May 6, 2006, Plaintiff finally went to Court and the adoption was

granted for McKayla. Plaintiff had paid an extra $2,000.00 to have the 15 day waiting

period waived, which the court granted. On May 10, 2006, the new birth certificate was

issued after being submitted incorrectly twice due to bad instructions by Gabit the

coordinator. Due to the delays caused by Gabit and the Defendant’s, Plaintiff needlessly

spent the $2,000.00 because she could not return home with McKayla until long after the

15 day waiting period. Plaintiff asked Defendant Mozes for a return of these funds which

he refused.

179.Plaintiff found out while in Kaz that the Defendants coordinator failed to arrange

for a passport for baby McKayla and that would take an additional week before McKayla

could travel. Plaintiff’s visa expired on May 18, 2006 and McKayla’s passport wouldn’t

be ready until May 19, 2006. Plaintiff had to pay additional funds for the embassy fees,

additional medicals for McKayla and additional living expenses for a 9 week stay in Kaz.

180.Plaintiff encountered another family who were clients of AIP while in Kaz. The

other family had multiple problems with their adoption and had threatened to contact the

American Embassy but they told the Plaintiff that they didn’t contact the Embassy

because Defendant Mozes told them that he would make sure that the Plaintiff’s adoption

would fail if they made any calls to the American Embassy. This family didn’t want to

threaten the Plaintiff’s adoption so they didn’t make any calls.

38
 181.On or about May 19, 2006, Plaintiff and baby McKayla were able to go to

Almaty. They were taken to an apartment provided by the Defendants. The apartment was

filthy, there was no running water in the bathroom sink, and most of the time the electric

didn’t work. The Plaintiff couldn’t warm up food for the baby. When the Plaintiff asked

the coordinator to be moved to a different apartment, she was told that there were no

other apartments available. Yet when the Plaintiff told the coordinator that she was going

to call the American Embassy to report the unsanitary and unsafe conditions of the

apartment, they found an apartment within 2 hours.

182.Plaintiff and McKayla finally returned home on May 30, 2006. The delays from

the disappearance of Gabit and untimely filing of the paperwork made the Plaintiff lose

30 days of wages, 30 days lost being with her 3 year old son and a 30 day delay in getting

proper medical care for McKayla. The adoption from beginning to end cost the Plaintiff

almost $49,500.00 without taking in to account the costs of the delays. Plaintiff has been

damaged financially and emotionally by the Defendant’s illegal activities.

Plaintiff Ran

183.Plaintiff Faye Ran (“Plaintiff”) is the Assistant Provost at a small private college

in New York where she has worked for the past 26 years. Blessed with financial and

physical stability, she wished to add to her family. In March 2005, while researching

European adoptions, Plaintiff came across an internet photo listing of a little boy who

resembled her birth daughter.

184.On or about March 18, 2005, Plaintiff contacted Defendants and told them that

she was interested in adopting 2 children, a boy and girl. She told him that she was

particularly interested in child #665 on the photo listings. Defendant Mozes told Plaintiff

39
“once you sign the contract, the little boy will be taken off of the listing and the

orphanage will be told that a prospective parent had started the process, so no one

else can take the child. The child will be yours.” (See Exhibit XXX)

185.Defendants required all clients to open a Federal Express account so the

Defendants could ship documents at the expense of the clients. When Plaintiff discovered

exorbitant charges made to the Plaintiff’s Fed Ex account by AIP not having to do with

the Plaintiff’s papers, she called them, complained and cancelled the Fed Ex account. The

Plaintiff told them “I will mail my papers directly from New York City and my College

mailroom where I trust the staff to tell me the correct amounts of postage.”

186.On or about April 15, 2005, Plaintiff signed a contract with the Defendants. She

was sent more pictures, a video of the little boy and the child’s medical report. As the

Plaintiff watched the video with her daughter, child #665, Eliezer, became her son and

her daughter’s brother. Defendants assured Plaintiff Eli would be home by October or

November.

187.The Plaintiff did not see any photo listings of girls that she was interested in

adopting but Defendants assured her that once she arrived in the Ukraine, she would see

many more pictures a the central adoption agency. Plaintiff specifically asked whether

adopting 2 children required that the kids be siblings. Defendants responded “No.”

Defendants did tell Plaintiff that all of her paperwork would need to be done in duplicate

and there would be additional fees.

188.Later the Plaintiff found out that she would only be allowed to adopt one child or

siblings but not 2 unrelated children. Plaintiff paid extra costs of duplicate notarizations

and apostilles and copying (8 sets of everything had to be submitted). Plaintiff had to do

40
her paperwork over again in March and April and November and December due to the

documents expiring and continuous Power of Attorney changes by the Defendants.

189.Defendants recommended Phyllis Labella to perform her home study. According

to the Defendants “she has a good relationship with AIP and knows just what to do.”

Ms. Labella did a quick interview with the Plaintiff and approved her for adoption.

190.Defendant Mozes made it very clear to the Plaintiff early in the adoption process

that if a client proved to be what he called “troublesome” he would drop the adoption and

no monies would be refunded. Defendant Mozes yielded enormous power of their clients

because adoptive parents were afraid to offend him and end their adoption. Defendant

Mozes could be nice to an adoptive parent but would quickly turn nasty and become

verbally abusive if challenged by an adoptive parent.

191.In mid-April, Plaintiff began to receive e-mails from the Defendants instructing

her to send $3000 of the foreign fees to Gulshad Minulina in Almaty, Kaz. When the

Plaintiff asked why she was sending money to anyone in Kaz when she was adopting in

Ukraine. Defendant Mozes responded by stating “this person is the head lawyer for

AIP’s Ukraine operation and he pressures me to send the money as soon as

possible.” (See Exhibit XXX)

192.In mid-September, Plaintiff was told that her application had been translated but

not submitted and that she had missed the submission date by a few days because the

Ukraine had closed its doors on September 19th for foreign adoptions due to political

upheavals. At that time, Plaintiff put a stop on the $3,500 foreign fee check she had just

sent to the Defendants.

41
 193.On or about October 20, 2005, Defendant Mozes called the Plaintiff and swore

her to secrecy. Mozes said that he was able to get a few families registered and said

that her application in the Ukraine would be grandfathered in but she had to send

him $3,500 immediately.” The Plaintiff was so happy to be able to move forward with

the adoption and sent the money. (See Exhibit XXX)

194.In January 2006, it appeared that the Ukraine would re-open for adoptions. The

Plaintiff thinking she was already registered was ready to travel. The Defendants stalled

and avoided answering the Plaintiff’s questions about her registration. Finally,

Defendants admitted to the Plaintiff that she was not registered. (See Exhibit XXX)

195.Again more documents would need to be redone and more money was required

for translations. Plaintiff paid these additional fees. (See Exhibit XXX)

196.Defendants had promised Plaintiff that her adoption would be submitted in

January or February 2006 but when asked the Defendants avoided answering why her

papers weren’t submitted. Finally, Defendant Mozes told the Plaintiff that his in-country

representative was pregnant and having difficulties. Mozes yelled at the Plaintiff when

she asked why he didn’t have a back-up representative. Within a week, Defendants

advised the Plaintiff that they had a new representative, Igor Ruban.

197.Defendant Mozes later called the Plaintiff and told her that she needed to redo her

paperwork because her Notary’s license was expiring. Upon investigation, Plaintiff found

this to be false. Later Orson told the Plaintiff that Igor Ruban would “doctor the

documents to make sure they are good.” Plaintiff told the Defendants that they were

not to falsify, alter or tamper with her documents or any of her records.

42
 198.Defendant Mozes called two days later and said that Igor Ruban couldn’t submit

her documents because Ukraine wasn’t accepting single parent adoptions. Again, upon

investigation and inquiry, the Plaintiff was able to find out that the Ukraine was allowing

single family adoptions. Plaintiff sent the information on to the Defendants but they

refused to submit her adoption paperwork.

199.When Plaintiff asked for her dossier to be returned and her money to be refunded,

the Defendants tried to get her to switch her adoption to Kaz and directed her to look at

their Kaz children photo listing. Kaz adoptions cost more money. Plaintiff said no and

again demanded her money back.

200.After this the Defendant Mozes refused to answer any calls from the Plaintiff.

Through her own efforts the Plaintiff was able to retrieve her dossier from Igor Ruban.

(See Exhibit XXX)

201.Plaintiff continued to try to call Mozes and finally was able to reach Defendant

Anderson to request her money to be refunded. Defendant Anderson wanted to know why

she wanted a refund since she “left” the agency. Plaintiff explained that she didn’t leave

the agency, the Defendants refused to complete her adoption and she wanted her money

and documents back. Despite numerous e-mails and calls, nothing was received from the

Defendants. (See Exhibit XXX)

202.Plaintiff was induced into sending money and giving her love to a child in the

photo listing through an illegal process. Plaintiff has been damaged financially and

emotionally by the Defendant’s illegal activities.

Plaintiffs Pingree

43
 203.Plaintiffs Tom and Barbara Pingree (“Plaintiffs”) began investigating foreign

adoptions in late 2006 and in early 2007 contacted the Defendants for information on the

photo listing of child #900.

204.On or about January 3, 2007, Defendants sent Plaintiffs the contracts, fee

schedule, information packet and application. The e-mail asked for $8,850 to “hold” the

child and to be able to let all other parties know that the Plaintiffs had selected the child.

Defendants would send dossier package once the check clears. Defendant Mozes tells

Plaintiffs they would be working with Defendant Anderson. (See Exhibit XXX)

205.In April, Plaintiff Barbara wrote Defendants with questions and concerns about

problems she had read about with Kaz adoptions. She told Defendants how they already

consider this baby their son and want to avoid broken hearts due to unreliable adoption

coordinators. Defendant Mozes responds “No adoption is problem free. Birth Mothers

or relatives can come back even after court. This has only happened once but it can

happen…….” and “..I would say that almost all of our clients come home with

children they love. The few that do not cannot because they cannot find a child they

like even if healthy.” (See Exhibit XXX)

206.Throughout spring and summer 2007, Plaintiffs frequently requested more

information, (including a name) on child #900 but Defendants do not provide any further

information.

207.In June 2007, Plaintiffs learned that photo listing, holding and referrals of

children are prohibited in Kaz. When Plaintiff Tom questioned Defendant Anderson about

these facts, he was assured that “AIP’s partners in Kaz are able to “put aside”

44
children at the orphanage, and our clients are able to get their referrals 80-90% of

the time.”

208.On or about July 12, 2007, after confirming the Kaz laws with the United States

embassy, the Plaintiffs sent the Defendants a demand letter asking for the refund of their

money for being fraudulently induced into an illegal process of adopting children. (See

Exhibit XXX)

209.The Plaintiffs heard nothing back from the Defendants until they received an e-

mail on August 10, 2007, where the Defendants were asking clients to contact the US

Embassy to help move their adoptions forward. (See Exhibit XXX)

210.Plaintiffs were induced into sending money and giving their love to a child in the

photo listing through an illegal process. Plaintiffs have been damaged financially and

emotionally by the Defendants illegal activities.

Plaintiff Wappes

211.On or about May 9, 2006, Plaintiff Jaymee Wappes (“Plaintiff”) asked the

Defendants about a photo listing on their website. That same day Defendant Orson Mozes

called the Plaintiff and told her that he would “hold the child while she completed her

paperwork.” The Plaintiff told the Defendant that she didn’t have the money available

because she was going to take out a loan. Defendant Mozes told the Plaintiff to “Send all

the money you have right now or I won’t take the photo listing down.” Plaintiff sent

the Defendants all the money she had in the bank account because she was afraid that she

needed to move quickly. The next week, Plaintiff obtained a loan for the balance of the

fees.

45
 212.Between May 9 and December 11, 2006, the Plaintiff worked on getting all of the

necessary paperwork completed. Each time a document needed to be notarized and

apostilled, she took a day off from work (Indiana State offices are not open on the

weekends) and drove the 200 miles to Indianapolis. At times, the Defendants “forgot” to

send her all of the documents and later the Plaintiff again had to take time off of work

and travel to Indianapolis. During that time Defendant Mozes told Plaintiff that she

would be working with Defendant Anderson. He also said “20% of the time clients will

lose their referral because a birth parent or relative comes back to claim the child or

some other unforeseen circumstance happens.” (See Exhibit XXX)

213.On or about December 11, 2006, the Plaintiff’s dossier was completed and sent to

Kaz for the first time.

214.On or about January 24, 2007, Defendants called to advise Plaintiff that her

dossier had been declined in Kaz because she had a female roommate sharing home

expenses. Defendants referred Plaintiff to move her adoption to the Ukraine. Plaintiff

asked for a refund but Defendants would not discuss returning her money.

215.On or about February 5, 2007, Defendant Mozes called Plaintiff and told her that

if her homestudy was revised to reflect that her roommate had a separate entrance to the

home, she would still qualify for a Kaz adoption. Plaintiff had the homestudy revised on

February 8, 2007.

216.On or about February 19, 2007, the Plaintiff sent the documents to the

Defendants. On the same date Defendant Anderson wrote the Plaintiff telling her she

needed another FBI Clearance and asking for “cashiers checks for $1150 for Nina and

46
$200 to AIP as well as the $440 postal money order for the embassy of Kazakhstan.”

(See Exhibit XXX)

217.On or about June 7, 2007, Plaintiff’s dossier was resubmitted to the Kaz

government. On or about June 18, 2007, Defendant Anderson sent the visa information to

the Plaintiff. When the Plaintiff called the Defendants with questions on the Visa packet

she received an e-mail from Defendant Anderson on June 22 2007, telling her that he had

sent it prematurely. (See Exhibit XXX) Plaintiff called Defendants several times over the

next few days but received no return calls.

218.On or about July 5, 2007, Plaintiff e-mailed Defendant Anderson for an update on

her adoption and he responded that there was nothing to report. Not satisfied with that

answer, Plaintiff e-mailed Defendant Mozes and got a response from Defendant Anderson

using Defendant Mozes’s e-mail account. This response advised her that Orson Mozes no

longer worked for AIP and that Defendant Anderson had taken over his duties. When the

Plaintiff told Defendant Anderson that “SOMETHING IS NOT ADDING UP”,

Defendant Anderson responded “Orson had a nervous breakdown and left. He just

disappeared. Luckily, he had me do a backup of his computer, so I have all of his files.

I have taken over the position and things are running smoothly….” (See Exhibit

XXX)

219.After several days, telephone calls and e-mails to the Defendants, on July 31,

2007, Plaintiff sent a note to Defendants asking who Christen Brown Moses (sp) was,

whether it was legal to have photo listings for Kaz adoptions and requesting an

appointment in person. Defendant Anderson replied “There is a debate on the legality

of putting photos on websites. I have always been told, and continue to be told that

47
certain areas of Kazakhstan forbid it, but other areas do not. That is why we would

only post children from certain areas. Because I question what I am being told, I

have removed all the children from the websites until I am certain as to the legality

of it. Christen is Orson’s wife. They have been going through a divorce for the last

year. When he left, she decided to continue on with the company in order to finish

the adoptions for the clients who have already signed up with us. We are not taking

new customers and neither Christen nor myself, are interested in pursuing this line of

work. Christen has never been involved with the company but feels a moral

responsibility to the clients that Orson has left behind. So, that’s the story. We are

continuing on to finish adoptions. I understand your concern, but we are completing

adoptions and sending clients over….” (See Exhibit XXX)

220. On August 1st and later August 3rd, the Plaintiff wrote to the Defendants for some

reassurance. She expressed that she needed details and wanted to know if the Defendants

would refund her money if the Agency were to close. Defendant Anderson responded that

the adoptions were just slowed down with Orson’s departure. He told her “he expected

her LOI to be issued soon.”

221.On or about August 17, 2007, Plaintiff sent a note demanding her money back.

She had spent over $22,000 and 15 months at that point with nothing to show for her

time, efforts and heartache. Plaintiff received no response. (See Exhibit XXX)

222.On or about September 17, 2007, Plaintiff e-mailed Defendants to inquire why

other AIP clients had received a Notice of Dissolution of AIP but she didn’t have one sent

to her. Defendant Anderson responded by sending her a notice and stated “We are trying

48
to find out who would be willing to transfer their adoptions to Heritage. The

transfer is not finalized at this time, but will be shortly.” (See Exhibit XXX)

223.Plaintiff sent an e-mail to Defendants on or about September 19, 2007 again

demanding her money back as a transfer was not part of the contract and the Defendants

had breached the contract. Plaintiff also requested her files back from Defendants.

Plaintiff has been damaged financially and emotionally by the Defendant’s illegal

activities

Plaintiffs Meenach

224.Plaintiffs Chad and Michelle Meenach (“Plaintiffs”) contracted to adopt a child

through the Defendants. On or about August 15, 2006, Defendants presented a photo

listing of child #58, representing that this was a healthy female infant approximately 3

months old and in good health with no special medical or psychological needs.

Defendants assured the Plaintiffs that they could have this child #58 if they sent their

fees.

225.The Plaintiffs sent their fees and began the process of completing their dossier

and home study. Once the money was sent to the Defendants, the Defendants promised to

hold the child they had selected and assured the Plaintiffs that the baby would be their

referral.

226.On or about February 2007, the Plaintiffs had sent the dossier to the Defendants

and inquired about whether it had been reviewed yet. The Plaintiffs wanted to know the

timeline for travel but Defendant Mozes said that Defendant Anderson was in charge of

the timeline. The Plaintiffs were sent updated pictures of the child the Defendants had

referred to them.

49
 227.On or about March 19, 2007, Defendants told the Plaintiffs to wire money to

Roza Ligay in Uzbekistan and advised them that the balance of the foreign fees would be

$12,500 after wiring the money to Roza.

228.On or about May 23, 2007, Plaintiffs receives their visa information from

Defendants. Defendant Anderson instructed the Plaintiffs to lie on the application about

where they were staying while in Kaz. (See Exhibit XXX)

229.In early June 2007, after submitting the visa application on May 24, 2007,

Plaintiff Michelle Meenach wanted information on travel dates but was told by

Defendants that the travel agency is having trouble getting flights. Defendants advised

Plaintiff to go on a waiting list for flights and to put her travel plans on hold.

230.On or about July 9, 2007, Plaintiffs ask Defendant Anderson about a rumor that

Defendant Mozes had left the agency. Defendant Anderson confirmed that Defendant

Brown is now the director. Defendants told Plaintiffs that their LOI should be coming in

approximately 5 days. (See Exhibit XXX)

231.On or about July 12, 2007, Plaintiffs asked about the prices for the apartments,

what the baby girl’s name is and whether the child was still available. Defendant

Anderson advises “the child’s name is Janna and that he has sent an e-mail to see if

she is still available.” (See Exhibit XXX)

232. On or about August 8, 2007, Plaintiffs tried to access the Defendants website for

photo listings but find it has been taken off line. Defendants told Plaintiffs that the site is

just down for a few days.

233.On or about August 23, 2007, Plaintiffs advised the Defendants if they cannot

complete the adoption, the Plaintiffs want a full refund sent to them. Defendant Anderson

50
writes to the Plaintiffs “The current status is that AIP’s dossiers are sitting on the

desk of Raissa, who is the head of the Ministry of Education in Kazakhstan.

Christen spoke to her last week and was told that she has been holding them due to

the fact that the US Embassy has put pressure on her to do so…..” (See Exhibit

XXX)

234.On or about September 12, 2007, Defendants sent the Plaintiffs the Transfer

Notice and Notice of Dissolution of the Agency. Plaintiff’s questioned the Defendants

and Defendant Anderson advised that Heritage Adoptions is working with the Ministry of

Foreign Affairs in Kaz to complete the adoptions. (See Exhibit XXX)

235.In October 2007, Plaintiffs decided to use a new agency to complete a Kaz

adoption.

236.The Plaintiffs have suffered both emotionally and financially. The Plaintiffs have

been victimized by the Defendants fraudulent inducement and misrepresentation.

Plaintiffs Young

237.Plaintiffs Annmae and Christopher Young (“Plaintiffs”) decided to add to their

family by adopting a baby. In May 2005, they sent an e-mail to the Defendants to inquire

about baby # 749, Natalia, they found on Adopting.com’s photo listings for AIP.

Defendants instruct Plaintiffs to send signed contracts and $12,850 to AIP and once he

gets his payment he will remove baby #749 from the photo listings and no one else can

adopt her. Defendants assure the Plaintiffs that he can hold the child pending home study

completion. (See Exhibit XXX)

238.As Plaintiffs prepare their home study and dossier papers, and 24 hours after

sending the $12,850, the Defendants ask the Plaintiffs to wire via Western Union $5000

51
foreign fees to the Ukraine as soon as possible. The Plaintiffs are asked to wire the money

to Maryam Ramazoanova. Plaintiffs comply.

239.On or about July 28, 2005, Defendants send an e-mail to all clients listing the

employees of AIP and what their roles are within the agency. (See Exhibit XXX)

240.On or about September 13, 2005, Plaintiffs are told that they must hire Nina

Vzorova to translate their documents. In the past the Kaz embassy handled the translation

but now Plaintiffs needed to send $600 for the translations. AIP clients are reminded that

their contract allows Defendants to charge additional expenses without notice. Plaintiffs

were sent updated pictures for baby #749.

241.On or about November 20, 2005, Plaintiffs discovered baby #749, Natalia, on the

Sapp family’s on line adoption blog. The Sapp family were also adopting through the

Defendants agency. When Plaintiffs confronted Defendants they are told “We have

checked and this is not the same girl you are adopting.”

242.After receiving this assurance from the Defendants, the Plaintiffs contacted the

Sapp family via e-mail and explained what had happened. Plaintiffs asked the Sapp

family to check on their baby #749 as both children were in the same baby house and the

Defendants has assured them that these were two separate babies.

243.On November 24, 2005, Plaintiffs were notified that baby #749, Natalia, was

indeed being adopted by the Sapp family through the Defendants. Even though their

hearts were breaking the Plaintiffs had the grace to congratulate the family who was

adopting this little girl, now named Leah. (See Exhibit XXX)

244.On or about November 25, 2005, Plaintiffs write to Defendants to tell them how

heartbroken they are over the loss of their referral. Plaintiffs explain how devastating this

52
event has been to their little boy and how they have had to attempt to explain it to him as

well. Defendants respond to Plaintiffs questions on how their baby could be coming

home with another AIP family by stating “I am so sorry this has never happened

before; but we will find you the greatest baby. There is nothing I can say that will

make it better at this time. It will take sometime to heal this bad situation…..” (See

Exhibit XXX)

245.On or about November 25, 2006, Plaintiffs receive another letter of explanation

from the Defendants. This letter blamed the mistake on the Kaz coordinators and told the

Plaintiffs “Please try and keep the stupid mistake in your own family because I am so

embarrassed by this and so is everyone else involved.” (See Exhibit XXX)

246.On or about February 26, 2006, Defendants finally sent new photos of two babies

for the Plaintiffs to review, and instructed to pick the baby they would like to accept to

adopt.

247.Plaintiffs accepted this 2nd referral, however by May 2006, again the Plaintiffs

find out via online communication with other adoptive parents (in Kaz at the time) that

this referral is being adopted by an Irish family who are with a different adoption agency.

When the Plaintiffs again confront the Defendants about the status of their 2nd referral, the

Defendants ask for proof of this claim in the form of a photo. The Plaintiffs e-mailed the

photo and the Defendants advise that they will check this information for accuracy. Upon

Defendants investigation into the adoption of the 2nd referral to another family, the

Plaintiffs are notified by telephone that indeed referral number 2 had been adopted by a

family in Ireland.

53
 248.Having been emotionally traumatized again, the Plaintiffs request baby #1011,

another photo listed baby that captured their hearts. This request was again granted by the

Defendants and became the Plaintiff’s 3rd referral. In early June 2006, Plaintiffs were

instructed to make travel arrangements to arrive in Kaz by June 21, 2006. The Plaintiffs

comply and become hopeful. Airline tickets and VISA’s are paid for and in the Plaintiff’s

hands. On June 17, 2006, the Defendants notify plaintiffs by telephone that travel plans

must be chanted to mid-July as “the baby house director is on vacation and adoptions will

not take place until her return.” Again the Plaintiffs comply at the added expense of travel

date changes. The night before traveling to Kaz, the Plaintiffs were informed by

Defendants that this 3rd referral was no longer available and a 4th referral was emailed to

the Plaintiffs.

249.Prior to departure on or about July 11, 2006 the Plaintiffs called the Defendants

on last time prior to boarding the plane to inquire about the 4th referral’s status, and were

told verbally by the Defendant “I don’t know what child you will be getting, I don’t

know what is going on over there.”

250.On or about July 11, 2006, Plaintiffs fly to Kaz emotionally drained and doubtful

that there is a female baby under 12 months (as contracted for with Defendants) available

for adoption. Upon arrival to the baby house, the Plaintiffs are presented with baby

#1011, the 3rd referral whom they were told by Defendants was no longer available.

Defendant’s in-country staff told Plaintiffs that this child had been turned down by three

other families prior to the Plaintiff’s arrival in Kaz, but it is this child that the Plaintiffs

would ultimately bond with and adopt in Kaz. The Plaintiffs have their court date and on

August 3, 2006, Leah Natalya’s adoption was approved by the Kaz court.

54
 251.While in Kaz on the return trip to take custody of their child, Plaintiffs learn from

the Kaz coordinator that both Defendants and the Sapp’s that adopted child #749, knew

that she was referred to the Plaintiffs. However, the Defendants allowed the other family

to adopt child #749 because the Sapp’s had their dossier in order first. The Defendants

couldn’t locate a female child of age 5 available for adoption as the Sapp’s had originally

contracted for with the Defendants.

252.On or about August 21, 2006, the required 15 day waiting period was complete

and the Plaintiffs could return to Kaz to bring home their daughter. However the

Defendants claim a delay in the paperwork, therefore the return trip is also delayed.

253.On or about September 22, 2006, the Plaintiffs return to Kaz to take custody of

their daughter. The Plaintiffs return home with their daughter on October 6, 2006.

254.The Plaintiffs have suffered both emotionally and financially. They have been the

victims of the Defendants bait and switch baby scheme and have had to endure much to

complete their adoption. The Plaintiffs have been victimized by the Defendants

fraudulent inducement and misrepresentation.

Plaintiffs Wason

255.On or about February 18, 2006, Plaintiffs Kathleen and Billy Mark Wason

(“Plaintiffs”) inquired of Defendants about child #919 on the photo listings. Defendant

Mozes explained the fees in an e-mail to Plaintiffs and told them to call and speak to

Defendant Anderson. Defendants told the Plaintiffs “…20% of the time clients will lose

their referral because a birth parent or relative comes back to claim the child or

some other unforeseen circumstance happens….” (See Exhibit XXX)

55
 256.Plaintiffs told Defendants know that they were hesitant to send $11,850 to the

Defendants without knowing if child #919 was really available. Defendant Mozes

advised that they wouldn’t check to make sure the child is available until the check from

the Plaintiffs arrived at his office.

257.On or about February 20, 2006, Plaintiffs advised Defendants that they would

like updated information on child #919 or want information on other children because

another family may be interested in child #919. Plaintiffs were still hesitant to send

money with the Defendant’s no refund policy. Defendant Mozes responds “You will not

get nay (sp) more information until you go over, we cannot get updates. We do too

many adoption and not enough manpower. Plus they do not like it very much in the

foreign country sorry.” (See Exhibit XXX)

258.Plaintiffs asked Defendants how long it would be before they would travel to Kaz

once their homestudy was been completed. Defendants advised 2 months.

259.On or about March 3, 2006, Plaintiffs inquired on the possibility of adopting a

second child in the same region. Defendants advised that the fees are $4,000 for the

second child, a reduction of $1000 on the foreign fee for the second child but it must be

done through blind travel. Defendants offered to locate a child 1 month before the

Plaintiffs traveled to Kaz.

260.On or about April 10, 2006, Defendants e-mailed the Plaintiffs that they have

“never had a problem with a child that has come to the states older or younger…”

Defendants cautioned the Plaintiffs that child #919, named Marina, may have issues

when she is adopted. Next the Defendants offered to swap children if it doesn’t work out.

Defendant Mozes states “If you prefer when you get there we can also prepare an

56
infant girl for you to adopt Caucasian beautiful in case you cannot handle an older

girl. The foreign fee will be $16,000 in the case of a girl under three. Just to let you

know…..” (See Exhibit XXX)

261.On or about May 17, 2006, Plaintiffs contacted the Defendants about traveling to

another country to adopt during the summer to accommodate their son’s school schedule.

The Plaintiffs reasoned that with no guaranties that Marina was available, it may be a

better choice. Defendants respond “Marina is there they told me for sure.” (See

Exhibit XXX)

262.Throughout June and July 2006, Plaintiffs tried to get the Defendants to advise

the region where Marina was located so they could make travel plans. Defendants refused

to tell the Plaintiffs the region where they would be traveling until they have been invited

to travel.

263.On or about July 16, 2006, Defendants sent Plaintiffs an e-mail advising that a

family member has returned to “claim your girl.” Defendants immediately offer to

replace the girl with another and tell Plaintiffs that their trip won’t be delayed at all. They

are told there is an 80% chance that they will travel to Almaty region. (See Exhibit

XXX)

264.On or about July 23, 2006, Plaintiffs received their LOI but no visa. Defendants

promise to send additional pictures of young girls for the Plaintiffs to review. When

Plaintiffs advise that the Defendants had promised other pictures and referrals quickly,

they are told “Adoption is not perfect.”

265.On or about August 17, 2006, the Plaintiffs prepared to travel to Germany and

then to Kaz. Prior to traveling, the Plaintiffs were asked to wire $2,000 to a person named

57
Roza in Kaz and then another $4,000 the night before they traveled. They planned to

travel to Shymkent but asked if they can change regions quickly if needed. Defendant

Mozes assures them that it wouldn’t be a problem to change regions and there were

“thousands of children available for adoption.”

266.On or about August 29, 2006, while in Germany, the Plaintiffs received an e-mail

from the Defendants advising them that the LOI from Shymkent cannot be changed to

another region and there is only a four year old boy available for adoption. Plaintiffs had

to turn around and fly back to Texas. (See Exhibit XXX)

267.Plaintiffs contacted the American Embassy in Washington and were assured that

their adoption agency should not turn their backs on the Plaintiffs. Plaintiffs repeatedly

try to reach the in-country coordinator, Nigmat. Nigmat doesn’t answer their calls.

Defendants told Plaintiffs that Nigmat was trying to get them changed into another

region.

268.Plaintiffs told Defendants that the Defendants or Nigmat should reimburse

Plaintiffs airfair and fees for the aborted trip.

269.On or about October 5, 2006, Plaintiffs expressed their frustration with

Defendants and Nigmat in not finding another child for adoption and Nigmat’s apparent

inability to have the regions switched for the Plaintiff’s adoption. (See Exhibit XXX)

270.In late October 2006, Orson called the Plaintiffs and told them that they needed

to wire $4,000.00 and be ready to travel the next day to Kaz because Nigmat had finally

gotten their LOI changed to another region. Plaintiff Mark explained to Defendants that

they couldn’t wire the money because it was a Sunday and the banks were closed. He

explained to Defendant Mozes that they would not wire any more money. Defendant

58
Mozes began cussing at Plaintiff and the Plaintiff hung up the telephone. Afraid to

jeopardize their adoption, the money was paid and Plaintiff Kathleen left for Kaz.

271.Plaintiff Kathleen traveled back to Kaz, traveling blind to the Ust region and

began the bonding process with little Valeena. Plaintiff paid Nigmat $2500 to request the

Court to AIPive the second trip requirement. The Judge denied the waiver and Nigmat

told the Plaintiff he would refund that money on her second trip. Nigmat was advised the

second trip will be on December 5, 2006. Nigmat then asked Plaintiff for an additional

$2500.00 to expedite the return trip when she returns to get custody of Valeena.

272.Plaintiffs Mark and Kathleen Wason were induced and extorted into wiring

additional funds to complete their adoption of Valeena. The Plaintiffs were induced into

adopting through illegal photo listings and fraudulent promises by the Defendants.

Plaintiffs have been damaged financially and emotionally by the Defendant’s illegal

activities

DEFENDANT ADOPTION INTERNATIONAL PROGRAM’S

SCHEME TO DEFRAUD

59
 273.Defendant AIP has engaged in a scheme to defraud people seeking to become

parents. The Defendant AIP conducted this scheme to defraud through a system of offering

children to the new parents and demanding a signed illusory contract and a wire of

thousands of dollars.

274.Through this scheme, the Defendant AIP gathered money and requested wired

payments for additional unspecified fees with the threat that if these fees aren’t paid, the

adoption will cease.

275.Throughout the course of the process, the Defendant AIP engaged in a series of

fraudulent representations designed to induce the continued interest and to gain additional

money from the parents.

276.The Defendant AIP is willing to engage in such brazenly criminal activity given the

hyper-sensitive and vulnerable state of people who desperately want to be parents.

277.Moreover, the Defendant AIP faces little to no threat of civil action by the adoptive

parents because of the constant threat of the Defendant AIP stopping any adoption that is

currently in the system. In fact, it is suspected that there are hundreds of families like the

Plaintiffs in this case who were so scared of the Defendant AIP that they could not come

forward for fear of losing their adoption.

278.Once the Defendant AIP had obtained the money from the prospective parents, the

Defendant AIP abruptly stopped communicating and informed the prospective parents that

“they are too impatient” when they ask too many questions regarding the adoption process.

279.Defendant AIP would promise to “hold” a child for adoptive parents when the

Defendants knew it was illegal by the Kaz government to have photo listings, referrals or to

hold children.

60
 280.Defendant AIP would wait until the adoptive parents were within a week or less of

traveling to Kaz, to tell the parents that the child they had been tricked into believing was

their child, was no longer available. Thereby forcing the emotionally shocked parents into

traveling blind to choose a child which was the approved procedure of the Kaz government.

281.Upon information and belief, Plaintiffs were victimized by the Defendant AIP’s

scheme to defraud to the extent they relied upon the Defendant AIP’s fraudulent “factual”

representations regarding the adoptions, the ability to “hold” a child, birth mother or family

returning for children, status of dossier, the Kaz attorneys and in-country coordinators

involved in the adoptions and the status of the adoptions.

282.Since November 2004, Plaintiffs have been the victim of the Defendant AIP’s

scheme to defraud to the extent that they incurred substantial expense pursuing an adoption

that would not come to fruition unless they succumbed to the Defendant AIP’s scheme to

defraud and to the extent Plaintiffs relied on the Defendant AIP’s fraudulent representations

that these adoptions would take place. The Defendant AIP has refused to return money and

personal property and continue to use these for its own illegitimate benefit. To this day,

Plaintiffs continue to be so victimized by the Defendant AIP’s scheme to defraud. See

supra ¶¶ 23 – 272.

283.Upon information and belief, Plaintiffs allege that other unknown prospective

parents have sustained and continue to sustain similar injuries by reason of the Defendant

AIP’s scheme to defraud.

DEFENDANTS’ MOZES, BROWN AND ANDERSON’S SCHEMES TO

SOLICIT BRIBES, EXTORT, AND DEFRAUD

61
 284.Defendants Mozes, Brown and Anderson have engaged in schemes to solicit bribes

and extort money and property from prospective parents seeking to adopt children from

Guatemala. Defendants Mozes, Brown and Anderson have conducted their scheme of

bribe solicitation and extortion through enterprises consisting of their corporate entity

and/or an association-in-fact enterprise consisting of the Corporate Defendant AIP.

285.Through their patterns of bribe solicitation and extortion, Defendants’ Mozes,

Brown and Anderson seek to wrongfully obtain money from prospective parents who are

desperately hoping to adopt a child.

286.Plaintiffs were victimized by the schemes of bribe solicitation and extortion of

Defendants’ Mozes, Brown and Anderson in that, Defendants’ Mozes, Brown and Anderson

caused the Plaintiffs to send money for adoptions that have not been completed, may not

ever be completed or adoptions that were already completed and the money was sent due to

the fear of Defendants’ Mozes, Brown and Anderson preventing its completion.

287.Defendants’ Mozes, Brown and Anderson repeated schemes to defraud caused

Plaintiffs to incur substantial expenses pursuing a dream of being parents that would never

come to fruition unless Plaintiffs succumbed to the patterns of bribe solicitation, extortion

or fraud.

288.Upon information and belief, Plaintiffs allege that other unknown prospective

parents have sustained and continue to sustain similar injuries by reason of Defendants’

Mozes, Brown and Anderson schemes of bribe solicitation, extortion and mail/wire fraud.

ACTS VIOLATING THE MAIL AND WIRE FRAUD STATUTES

18 U.S.C. §§ 1341, 1343

62
 289.Pursuant to the events described in paragraphs 23 – 272., supra, the Defendants

AIP, Mozes, Brown and Anderson knowingly devised or knowingly participated in the

schemes or artifices to defraud Plaintiffs or to obtain the money or property of Plaintiffs by

means of false or fraudulent pretenses, representations, or promises.

290.Pursuant to the events described in paragraphs 23 – 272, supra, the Defendants AIP,

Mozes, Brown and Anderson could foresee that the mails would be used “for the purpose

of” advancing, furthering, executing, concealing, conducting, participating in or carrying

out the schemes, within the meaning of 18 U.S.C. §§ 1341 and 1343. In particular,

Defendants could foresee that the mails would be used to receive and/or deliver, inter alia,

money and false or fraudulent representations regarding the adoptions, facilitators and the

agreement among the parties; the status of ongoing adoptions and the remedies for

problems with adoptions. Defendants AIP, Mozes, Brown and Anderson continued

possession of Plaintiffs money and private information; gained through Defendants AIP,

Mozes, Brown and Anderson bribe solicitation and extortionist demands.

291.Defendants AIP, Mozes, Brown and Anderson acting singly and in concert,

personally or through their agents, as co-conspirators, or as aiders and abettors, used the

mails or caused the mails to be used “for the purpose of” advancing, furthering, executing,

concealing, conducting, participating in, or carrying out the schemes, within the meaning of

18 U.S.C. §§ 1341 and 1343.

292.In advancing, furthering, executing, concealing, conducting, participating in, or

carrying out the schemes, the Defendants AIP, Mozes, Brown and Anderson specifically

used the wires/ mails or caused the wires/mails to be used to receive or deliver, inter alia,

63
every email, facsimile, letter or telecommunication described in paragraphs 23 – 272,

supra.

293.In advancing, furthering, executing, concealing, conducting, participating in, or

carrying out the schemes, the Defendants AIP, Mozes, Brown and Anderson also

specifically used the wires/mails or caused the wires/mails to be used to receive or deliver,

inter alia, the emails, facsimiles, letters or telecommunications with the Plaintiffs regarding

all adoption matters.

294.Each and every use of the mails and wires described above was committed by the

Defendants AIP, Mozes, Brown and Anderson with the specific intent to defraud Plaintiffs

or for obtaining the money or property of Plaintiffs by means of false or fraudulent

pretenses, representations, or promises.

295.Defendants’ acts of mail and wire fraud are in violation of 18 U.S.C. §§ 1341 and

1343 and constitute racketeering activity as defined by 18 U.S.C. § 1961(1)(B).

COUNT ONE
RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT
18 U.S.C. § 1962(c)
(Defendant AIP)

296.Plaintiffs reallege and restate paragraphs 1 through 295.

297.At all relevant times, some or all of the following individuals constituted an

“enterprise,” within the meaning of 18 U.S.C. §§ 1961(4) and 1962(c), in that they were “a

64
group of individuals associated in fact”: Adoption International Program, Inc., Orson

Mozes, Christen Brown and Kevin Anderson.

(a) Adoption International Program, Inc., (the “AIP”) is

individually a “person,” within the meaning of 18 U.S.C.

§§ 1961(3) and 1962(c), who associated with and/or

participated in the conduct of said enterprise’s affairs.

(b) From at least November 2004 and continuing through the

present, the Defendant AIP, personally or through their agent

or agents, conducted, participated in, engaged in, conspired to

engage in, or aided and abetted, the conduct of the affairs of

the enterprise through a pattern of racketeering activity

within the meaning of 18 U.S.C. §§ 1961(1), 1961(5)

and 1962(c). The Defendant AIP’s pattern of racketeering

activity consisted of:

(i) a scheme to defraud (see supra ¶¶ 23-272) that AIPs

knowingly and intentionally devised by the
Defendant AIP to obtain Plaintiffs money or property
by means of false or fraudulent pretenses,
representations, or promises; and, for the purpose of
executing such scheme, the Defendants placed or
caused to be placed in a post office, or authorized
depository for mail, matter that furthered the scheme
to defraud (including but not limited to the
communications described in ¶¶23-272); each
Defendant committed mail fraud, in violation of 18
U.S.C § 1341, each time it used or caused the mails to
be used to distribute the materials described in
paragraphs 23-272 and elsewhere;

(ii) a scheme to defraud (see supra ¶¶ 23-272) that was

knowingly and intentionally devised by Defendant
AIP to obtain Plaintiffs money or property by means

65
 of false or fraudulent pretenses, representations, or
promises; and, for the purpose of executing such
scheme, the Defendant AIP transmitted or caused to
be transmitted by means of wire, radio, or television
communication in interstate or foreign commerce
matter that furthered the scheme to defraud (including
but not limited to the communications described in ¶¶
23-272); each Defendant committed wire fraud, in
violation of 18 U.S.C § 1343, each time it used or
caused interstate wires to be used to distribute the
materials described in paragraphs 23-272 and
elsewhere;

(iii) receiving and/or possessing Plaintiffs property, in

violation of 18 U.S.C. § 2315, valued at $5,000 or
more, which crossed a state or international boundary
after the Defendant AIP stole, unlawfully converted,
or took Plaintiffs property and which the Defendants
knew was stolen, unlawfully converted, or taken
(including but not limited to the events described in
paragraphs 23-272 and elsewhere);

(v) transporting, transmitting, or transferring in interstate

commerce any goods, wares, merchandise of the
value of $5,000 or more, knowing the same to have
been stolen converted or taken by fraud, each and
every time that the Defendant AIP caused Plaintiffs to
transmit property across state or international
boundaries and each time that the Defendant AIP
transmitted Plaintiffs property to third-parties across
state or international boundaries as (including but not
limited to the events described in paragraphs 23-272),
in violation of 18 U.S.C. § 2314.

These acts all occurred after the effective date of RICO and more than two such acts

occurred within ten years of one another.

298.At all relevant times, the enterprise alleged in paragraphs 23-272 was engaged in,

and its activities affected, interstate commerce and foreign commerce.

299.All of the predicate acts described above were related so as to establish a pattern of

racketeering activity, within the meaning of 18 U.S.C. § 1962(c), in that their common

66
purpose was to defraud Plaintiffs or other similar prospective adoptive parents of property

or money; their common result ass to defraud Plaintiffs or other similar prospective

adoptive parents of property or money; the Defendant AIP, through their agent or agents,

directly or indirectly, participated in all of the acts and employed the same or similar

methods of commission; Plaintiffs or other similar prospective adoptive parents were the

victims of the fraudulent acts; and/or the acts were otherwise interrelated by distinguishing

characteristics and were not isolated events.

300.All of the predicate acts described above were continuous so as to form a pattern

of racketeering activity in that:

a) The Defendant AIP engaged in the predicate acts described

above over a substantial period of time (from at least

November 2004 through the present); or

b) The pattern of racketeering activity engaged in by the

Defendant AIP continues or threatens to continue because it

has become a regular way of conducting the Defendant AIP’s

on-going business activities.

300.As a direct and result of, and by reason of, the activities of the Defendant AIP, and

their conduct in violation of 18 U.S.C. §§ 1962(c), Plaintiffs have been injured in their

business or property, within the meaning of 18 U.S.C. § 1964(c). Among other things,

Plaintiffs have suffered damages to the extent they invested time and resources in pursing

what they thought and were led to believe was a legitimate international adoption, to the

extent their ability to adopt was delayed by the Defendant AIP’s wrongful actions, and to

the extent their property has been misappropriated. Plaintiffs are, therefore, entitled to

67
recover threefold the damages that they have sustained together with the cost of the suit,

including reasonable attorneys' and experts' fees.

COUNT TWO

RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT

18 U.S.C. § 1962(d)
(Defendant Adoption International Program, Inc.)

301.Plaintiffs reallege and restate paragraphs 1 through 300.

302.Defendant AIP conspired with Defendants Mozes, Brown and Anderson to

conduct or participate, directly or indirectly, in the conduct of the affairs of the enterprise

through a pattern of racketeering activity (as described in paragraphs 23-272) in violation

of 18 U.S.C. § 1962(d). In particular, Defendant AIP intended to further an endeavor of

Mozes, Brown and Anderson which, if completed, would satisfy all of the elements of a

substantive RICO criminal offense and adopted the goal of furthering or facilitating the

criminal endeavor.

303.As a direct and proximate result of, and by reason of, the activities of the

Defendant AIP, and their conduct in violation of 18 U.S.C. §§ 1962(d), Plaintiffs have

been injured in their business or property, within the meaning of 18 U.S.C. § 1964(c).

Among other things, Plaintiffs have suffered damages to the extent they have invested

time and resources in pursing what they thought and was led to believe was a legitimate

international adoption opportunity with Defendant AIP, to the extent their ability to

complete the adoptions were delayed by the Defendant AIP’s wrongful actions, and to the

extent their property has been misappropriated. Plaintiffs are, therefore, entitled to

68
recover threefold the damages that they have sustained together with the cost of the suit,

including reasonable attorneys' and experts' fees.

COUNT THREE

RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT

18 U.S.C. § 1962(c)
(Mozes, Brown and Anderson)

304.Plaintiffs reallege and restate paragraphs 1 through 304.

305.At all relevant times, AIP constituted an “enterprise,” within the meaning of 18

U.S.C. §§ 1961(4) and 1962(c), in that it was a corporation.

(a) Mozes, Brown and Anderson are an individual “persons,”

within the meaning of 18 U.S.C. §§ 1961(3) and 1962(c),

who associated with and/or participated in the conduct of said

enterprise’s affairs.

(b) For an unknown and indefinite period of time, Mozes, Brown

and/or Anderson has conducted, participated in, engaged in,

conspired to engage in, or aided and abetted, the conduct of

the affairs of the enterprise through a pattern of racketeering

activity within the meaning of 18 U.S.C. §§ 1961(1), 1961(5)

and 1962(c). Mozes, Brown and Anderson’s pattern of

racketeering activity consisted of:

(i) bribe solicitation (see supra ¶¶ 28) that was designed

to extract direct or indirect personal rewards from
Plaintiffs in exchange for AIP’s recommendation to
the Kazakhstan officials that they assist in Plaintiffs
or other prospective adoptive parents’ adoptions;

(ii) extortion (see supra ¶¶ 23-272) that was designed to

extract direct or indirect personal rewards from

69
 Plaintiffs; if Plaintiffs or another prospective adoptive
refused to succumb to Mozes, Brown and/or
Anderson demands for money or foreign and
administrative fees, they would stop the adoption or
adoption activities and prevent the Plaintiffs from
moving forward in the adoption, for personal gain; all
or some said acts of extortion were in violation of 18
U.S.C. § 1951;

(iii) a scheme to defraud (see supra ¶¶ 23-272) that was

knowingly and intentionally devised by Mozes,
Brown and/or Anderson to obtain Plaintiffs money or
property by means of false or fraudulent pretenses,
representations, or promises; and, for the purpose of
executing such scheme, Mozes, Brown and/or
Anderson placed or caused to be placed in a post
office, or authorized depository for mail, matter that
furthered the scheme to defraud (including but not
limited to the communications described in ¶¶ 23-
272); Mozes, Brown and/or Anderson committed
mail fraud, in violation of 18 U.S.C § 1341, each time
they used or caused the mails to be used to distribute
the materials described in paragraphs 23-272 and
elsewhere.

(iv) a scheme to defraud (see supra ¶¶ 23-272) that was

knowingly and intentionally devised by Mozes,
Brown and/or Anderson to obtain Plaintiffs money or
property by means of false or fraudulent pretenses,
representations, or promises; and, for the purpose of
executing such scheme, Mozes, Brown and/or
Anderson transmitted or caused to be transmitted by
means of wire, radio, or television communication in
interstate or foreign commerce matter that furthered
the scheme to defraud (including but not limited to
the communications described in ¶¶ 23-272); Mozes,
Brown and/or Anderson committed wire fraud, in
violation of 18 U.S.C § 1343, each time it used or
caused interstate wires to be used to distribute the
materials described in paragraphs 23-272 and
elsewhere;

(v) receiving and/or possessing Plaintiffs property, in

violation of 18 U.S.C. § 2315, valued at $5,000 or
more, which crossed a state or international boundary
after Mozes, Brown and/or Anderson stole,

70
 unlawfully converted, or took Plaintiffs property and
which Mozes, Brown and/or Anderson knew was
stolen, unlawfully converted, or taken (including but
not limited to the events described in paragraphs 23-
272 and elsewhere);

(vi) transporting, transmitting, or transferring in interstate

commerce any goods, wares, merchandise of the
value of $5,000 or more, knowing the same to have
been stolen converted or taken by fraud, each and
every time that Mozes, Brown and/or Anderson
caused Plaintiffs to transmit property across state or
international boundaries and each time that Mozes,
Brown and/or Anderson transmitted Plaintiffs
property to third-parties across state or international
boundaries as (including but not limited to the events
described in paragraphs 23-272), in violation of 18
U.S.C. § 2314;

(viii) traveling in interstate and foreign commerce or using the mail

or any facility in interstate or foreign commerce with intent to
distribute the proceeds of extortion or otherwise promote,
manage, establish, or carry on a scheme to extort and
thereafter performed or attempted to perform said acts, in
violation of 18 U.S.C. § 1952.

These acts all occurred after the effective date of RICO and more than two such acts

occurred within ten years of one another.

306.In the alternative to paragraph 305, at all relevant times, some or all of the

following individuals constituted an “enterprise,” within the meaning of 18 U.S.C. §§

1961(4) and 1962(c), in that they were “a group of individuals associated in fact”:

Adoption International Program, Inc., Orson Mozes, Christen Brown and/or Kevin

Anderson.

(a) Mozes, Brown and/or Anderson are each individual “persons,”

within the meaning of 18 U.S.C. §§ 1961(3) and 1962(c), who

71
 associated with and/or participated in the conduct of said enterprise’s

affairs.

(b) For an unknown and indefinite period of time, Mozes, Brown

and/or Anderson have conducted, participated in, engaged in,

conspired to engage in, or aided and abetted, the conduct of

the affairs of the enterprise through a pattern of racketeering

activity within the meaning of 18 U.S.C. §§ 1961(1), 1961(5)

and 1962(c). Mozes, Brown and/or Anderson’s patterns of

racketeering activity consisted of:

(i) bribe solicitation (see supra ¶¶ 28) that was designed

to extract direct or indirect personal rewards from
Plaintiffs in exchange for AIP’s recommendation to
the Kazakhstan officials that they assist in Plaintiffs
other prospective adoptive parents’ adoptions;

(ii) extortion (see supra 23-272) that was designed to

extract direct or indirect personal rewards from
Plaintiffs; if Plaintiffs or another prospective adoptive
refused to succumb to Mozes, Brown and/or
Anderson’s demands for money or foreign and
administrative fees, they would stop the adoption or
adoption activities and prevent the Plaintiffs from
moving forward in the adoption, for personal gain; all
or some said acts of extortion were in violation of 18
U.S.C. § 1951;

(iii) a scheme to defraud (see supra ¶¶ 23-272) that was

knowingly and intentionally devised by Mozes,
Brown and/or Anderson to obtain Plaintiffs money or
property by means of false or fraudulent pretenses,
representations, or promises; and, for the purpose of
executing such scheme, Mozes, Brown and/or
Anderson placed or caused to be placed in a post
office, or authorized depository for mail, matter that
furthered the scheme to defraud (including but not
limited to the communications described in ¶¶ 23-
272); Mozes, Brown and/or Anderson committed

72
 mail fraud, in violation of 18 U.S.C § 1341, each time
they used or caused the mails to be used to distribute
the materials described in paragraphs 23-272 and
elsewhere.

(iv) a scheme to defraud (see supra ¶¶ 23-272) that was

knowingly and intentionally devised by Mozes,
Brown and/or Anderson to obtain Plaintiffs money or
property by means of false or fraudulent pretenses,
representations, or promises; and, for the purpose of
executing such scheme, Mozes, Brown and/or
Anderson transmitted or caused to be transmitted by
means of wire, radio, or television communication in
interstate or foreign commerce matter that furthered
the scheme to defraud (including but not limited to
the communications described in ¶¶ 23-272); Mozes,
Brown and/or Anderson committed wire fraud, in
violation of 18 U.S.C § 1343, each time it used or
caused interstate wires to be used to distribute the
materials described in paragraphs 23-272 and
elsewhere;

(v) receiving and/or possessing Plaintiffs property, in

violation of 18 U.S.C. § 2315, valued at $5,000 or
more, which crossed a state or international boundary
after Mozes, Brown and/or Anderson stole,
unlawfully converted, or took Plaintiffs property and
which Mozes, Brown and/or Anderson knew was
stolen, unlawfully converted, or taken (including but
not limited to the events described in paragraphs 23-
272 and elsewhere);

(vi) transporting, transmitting, or transferring in interstate

commerce any goods, wares, merchandise of the
value of $5,000 or more, knowing the same to have
been stolen converted or taken by fraud, each and
every time that Mozes, Brown and/or Anderson
caused Plaintiffs to transmit property across state or
international boundaries and each time that Mozes,
Brown and/or Anderson transmitted Plaintiffs
property to third-parties across state or international
boundaries as (including but not limited to the events
described in paragraphs 23-272), in violation of 18
U.S.C. § 2314;

73
 (viii) traveling in interstate and foreign commerce or using the mail
or any facility in interstate or foreign commerce with intent to
distribute the proceeds of extortion or otherwise promote,
manage, establish, or carry on a scheme to extort and
thereafter performed or attempted to perform said acts, in
violation of 18 U.S.C. § 1952.

These acts all occurred after the effective date of RICO and more than two such acts

occurred within ten years of one another.

307.At all relevant times, the enterprises alleged in paragraphs 302-306 were engaged

in, and their activities affected, interstate commerce and foreign commerce.

308.All of the predicate acts described above were related so as to establish a pattern of

racketeering activity, within the meaning of 18 U.S.C. § 1962(c), in that their common

purpose was to solicit bribes, extort and defraud Plaintiffs or other similar prospective

adoptive parents of money or property; Mozes, Brown and/or Anderson each personally

or through their agents or agents, directly or indirectly, participated in all of the acts and

employed the same or similar methods of commission; Plaintiffs, other similar

prospective adoptive parents, were the victims of the fraudulent acts; and/or the acts were

otherwise interrelated by distinguishing characteristics and were not isolated events.

309.All of the predicate acts described above were continuous so as to form patterns of

racketeering activity in that:

a) Mozes, Brown and/or Anderson engaged in the predicate acts

described above over a substantial period of time; or

b) The patterns of racketeering activity engaged in by the

Mozes, Brown and/or Anderson continue or threaten to

continue because the patterns have become a regular way of

conducting Mozes, Brown and/or Anderson on-going

74
 business activities (see, e.g., ¶ 19, 20, 21, 28, 37, 53, 55, 56,

59, 66, 69, 73, 81, 84, 93, 98, 99-108).

310.As a direct and result of, and by reason of, the activities of Mozes, Brown and/or

Anderson, and their conduct in violation of 18 U.S.C. §§ 1962(c), Plaintiffs have been

injured in its business or property, within the meaning of 18 U.S.C. § 1964(c). Among

other things, have suffered damages to the extent the Plaintiff invested time and resources

in pursuing what they thought and were led to believe was a legitimate adoption

opportunity with AIP, to the extent its ability to complete adoptions and or facilitate

adoptions was delayed by Mozes, Brown and/or Anderson’s wrongful actions, and to the

extent their property has been misappropriated. Plaintiffs are, therefore, entitled to

recover threefold the damages they sustained together with the cost of the suit, including

reasonable attorneys' and experts' fees.

COUNT FOUR

RACKETEER INFLUENCED AND CORRUPT ORGANIZATIONS ACT

18 U.S.C. § 1962(d)
(AIP, Mozes, Brown and Anderson)

311.Plaintiffs reallege and restate paragraphs 1 through 310.

312.AIP conspired with Mozes, Brown and Anderson to conduct or participate,

directly or indirectly, in the conduct of the affairs of the enterprise through a pattern of

racketeering activity (as described in paragraphs 302-306) in violation of 18 U.S.C.

§ 1962(d). In particular, AIP intended to further an endeavor of Mozes, Brown and/or

Anderson’s which, if completed, would satisfy all of the elements of a substantive RICO

criminal offense and adopted the goal of furthering or facilitating the criminal endeavor.

75
 313.Mozes conspired with AIP, Brown and Anderson to conduct or participate, directly

or indirectly, in the conduct of the affairs of the enterprise through a pattern of

racketeering activity (as described in paragraphs 302-306) in violation of 18 U.S.C.

§ 1962(d). In particular, Mozes intended to further an endeavor of AIP, Brown and

Anderson which, if completed, would satisfy all of the elements of a substantive RICO

criminal offense and adopted the goal of furthering or facilitating the criminal endeavor.

(See supra, e.g, ¶ 28.)

314.Brown conspired with AIP, Mozes and Anderson to conduct or participate, directly

or indirectly, in the conduct of the affairs of the enterprise through a pattern of

racketeering activity (as described in paragraphs 302-306) in violation of 18 U.S.C.

§ 1962(d). In particular, Brown intended to further an endeavor of AIP, Mozes and

Anderson which, if completed, would satisfy all of the elements of a substantive RICO

criminal offense and adopted the goal of furthering or facilitating the criminal endeavor.

(See supra, e.g, ¶ 28.)

315.Anderson conspired with AIP, Mozes and Brown to conduct or participate, directly

or indirectly, in the conduct of the affairs of the enterprise through a pattern of

racketeering activity (as described in paragraphs 302-306) in violation of 18 U.S.C.

§ 1962(d). In particular, Anderson intended to further an endeavor of AIP, Mozes and

Brown which, if completed, would satisfy all of the elements of a substantive RICO

criminal offense and adopted the goal of furthering or facilitating the criminal endeavor.

(See supra, e.g, ¶ 28.)

316.As a direct and proximate result of, and by reason of, the activities of AIP, Mozes,

Brown and Anderson, and their conduct in violation of 18 U.S.C. §§ 1962(d), Plaintiffs

76
have been injured in their business or property, within the meaning of 18 U.S.C. §

1964(c). Among other things, Plaintiffs have suffered damages to the extent they invested

time and resources in pursing what they thought and were led to believe was a legitimate

adoption opportunity with AIP, to the extent the ability to complete adoptions and or

facilitate Kazakhstan adoptions were delayed by AIP, Mozes, Brown and Anderson

wrongful actions, and to the extent their property has been misappropriated. Plaintiffs are,

therefore, entitled to recover threefold the damages that they have sustained together with

the cost of the suit, including reasonable attorneys' and experts' fees.

COUNT FIVE

UNJUST ENRICHMENT
(AIP, Mozes, Brown and Anderson)

317.Plaintiffs reallege and restate paragraphs 1 through 316.

318.AIP, Mozes, Brown and Anderson have, directly or indirectly, wrongfully

received all or part of Plaintiffs property and money related to the adoptions.

319.Despite Plaintiff’s repeated requests, AIP, Mozes, Brown and Anderson have

refused to fully compensate Plaintiffs for the value of the property and money related to

the adoptions received.

320.As a result, AIP, Mozes, Brown and Anderson have been unjustly enriched.

321.By reason of the foregoing, and as a direct and proximate result, Plaintiffs are

entitled to a judgment in an amount to be determined by the Court, but which is in excess

of seventy-five thousand ($75,000).

COUNT SIX

CONVERSION
(AIP, Mozes, Brown and Anderson)

77
 322.Plaintiffs reallege and restate paragraphs 1 through 321.

323.AIP, Mozes, Brown and Anderson have converted to their own use and benefit

Plaintiffs property and money related to the adoptions.

324.As a direct and proximate result of AIP, Mozes, Brown and Anderson’s

conversion of Plaintiffs assets, Plaintiffs have incurred and/or will continue to incur

substantial damages in an amount to be determined by the Court, but which is in excess

of seventy-five thousand ($75,000).

COUNT SEVEN

CIVIL CONSPIRACY
(AIP, Mozes, Brown and Anderson)

325.Plaintiffs reallege and restate paragraphs 1 through 324.

326.Defendants AIP, Mozes, Brown and Anderson illegally, maliciously, and

wrongfully conspired with one another with the intent to and for the illegal purpose of

committing fraudulent adoptions through a bait and switch scheme, an adoption

scheme that offered illusory promises and conversion of the money and property of the

Plaintiffs.

327.Defendants AIP, Mozes, Brown and Anderson, in combination, conspired to

obtain money through their fraudulent adoption schemes.

328.This conspiracy resulted in the illegal, unlawful, or tortious activity of fraud and

violations of the Racketeer Influenced and Corrupt Organizations Act.

329.As a result of the conspiracy and Defendant AIP, Mozes, Brown and Anderson’s

illegal, wrongful, or tortious acts, Plaintiffs sustained the following damages: loss of

money for adoptions, administrative fees, translation fees, travel fees, lodging costs,

78
fees for hiring adoption facilitators, foreign fees, loss of employment and housing,

emotional damages and other damages that may have yet to be determined.

330.As a direct and proximate result of AIP, Mozes, Brown and Anderson’s

conspiracy to obtain Plaintiff’s assets, Plaintiffs have incurred and/or will continue to

incur substantial damages in an amount to be determined by the Court, but which is in

excess of seventy-five thousand ($75,000).

COUNT EIGHT

FRAUDULENT MISREPRESENTATION
(AIP, Mozes, Brown and Anderson)

331.Plaintiffs reallege and restate paragraphs 1 through 330.

332.Defendants AIP, Mozes, Brown and/or Anderson’s intentionally made false

representations of material facts to Plaintiffs regarding the success of the adoptions, the

ability of selecting a child from photo listings, the ability of the Defendants to “hold” a

child for adoption, the ability of Defendants to complete adoptions due to their

relationship with Kazakhstan officials, the ability to switch regions while in the process

of adoptions, the cost of services, the availability of children available to adopt, as set

forth in the preceding paragraphs.

333.Defendants AIP, Mozes, Brown and/or Anderson’s representations were false

when they were made.

334.Defendants AIP, Mozes, Brown and/or Anderson knew that the representations

were false when they were made or made them recklessly, without knowing whether

they were true.

335.Defendants AIP, Mozes, Brown and/or Anderson intended that Plaintiffs rely on

the representations.

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 336.Plaintiffs relied on Defendant’s false representations by signing an illusory

Adoption Contract in the hopes of adopting a child.

337.As a direct and proximate result of AIP, Mozes, Brown and/or Anderson

fraudulent misrepresentation, Plaintiffs have incurred and/or will continue to incur

substantial damages in an amount to be determined by the Court, but which is in excess

of seventy-five thousand ($75,000).

COUNT NINE

INNOCENT MISREPRESENTATION
(AIP, Mozes, Brown and/or Anderson)

338.Plaintiffs reallege and restate paragraphs 1 through 337.

339.Defendants AIP, Mozes, Brown and/or Anderson’S representations, as set forth

in the preceding paragraphs, were made in connection with the making of a contract

between Plaintiffs and Defendants AIP, Mozes, Brown and/or Anderson.

340.Plaintiffs would not have entered into the contract to adopt a Guatemalan child

if Defendants AIP, Mozes, Brown and/or Anderson had not made the representations.

341.Plaintiffs suffered substantial economic losses as a result of entering into the

contract, and these losses benefited Defendants AIP, Mozes, Brown and/or Anderson.

342.As a direct and proximate result of AIP, Mozes, Brown and/or Anderson

fraudulent misrepresentation, Plaintiffs have incurred and/or will continue to incur

substantial damages in an amount to be determined by the Court, but which is in excess

of seventy-five thousand ($75,000).

COUNT TEN

INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS

(AIP, Mozes, Brown and/or Anderson)

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 343.Plaintiffs reallege and restate paragraphs 1 through 343.

344.Defendants AIP, Mozes, Brown and/or Anderson’s fraudulent representations

and illegal activities were made intentionally, outrageously and maliciously and have

caused Plaintiffs to suffer humiliation, outrage, indignation, sleepless nights, and

severe emotional distress.

345.Defendants AIP, Mozes, Brown and/or Anderson continued in their enterprise of

fraudulent behavior with reckless disregard to the emotional impact to the Plaintiffs.

346.As a direct and proximate result of AIP, Mozes, Brown and/or Anderson’s

Intentional Infliction of Emotional Distress, Plaintiffs have incurred and/or will continue

to incur emotional distress and substantial damages in an amount to be determined by

the Court, but which is in excess of seventy-five thousand ($75,000).

COUNT ELEVEN

NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS

(AIP, Mozes, Brown and/or Anderson)

347.Plaintiffs reallege and restate paragraphs 1 through 346.

348.Defendants AIP, Mozes, Brown and/or Anderson’s fraudulent representations

and illegal activities were made intentionally, outrageously and maliciously and have

caused Plaintiffs to suffer humiliation, outrage, indignation, sleepless nights, and

severe emotional distress.

349.Defendants AIP, Mozes, Brown and/or Anderson continued in their enterprise of

fraudulent behavior with reckless disregard to the emotional impact to the Plaintiffs

and their spouses or partners.

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 350.As a direct and proximate result of AIP, Mozes, Brown and/or Anderson’s

Negligent Infliction of Emotional Distress, Plaintiff’s spouses and family members have

incurred and/or will continue to emotional distress and substantial damages in an

amount to be determined by the Court, but which is in excess of seventy-five thousand

($75,000).

WHEREFORE, Plaintiffs demand judgment from the Court as follows:

1.To award damages against Defendants AIP, Mozes, Brown and/or

Anderson, jointly and severally, for a sum of money equal to the amount

of damages and/or losses Plaintiffs have sustained or will sustain;

2.To treble the amount of said damages pursuant to 18 U.S.C. § 1964(c);

3.To award prejudgment interest on the amount of damages and/or losses

that Plaintiffs have sustained;

4.To award all costs of litigation incurred by Plaintiffs, including their

reasonable attorneys’ fees and experts’ fees, pursuant to 18 U.S.C. §

1964(c), ; and

5.To award damages in an amount in excess of $75,000 resulting from

Defendant’s intentional and malicious actions;

6.And to award such other and further relief as the Court deems just and

equitable.

FIXEL LAW OFFICES, PLLC

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December 15, 2007 ___________________________________
Joni M. Fixel (P56712)
Marlo D. Bruch-Barrett (P70362)
4990 Northwind Drive, Suite 121
East Lansing, MI 48823
Telephone: (517) 332-3390
jfixel@fixellawoffices.com

Jury Demand

Plaintiffs demand a Jury Trial.

FIXEL LAW OFFICES, PLLC

December 15, 2007 ___________________________________

Joni M. Fixel (P56712)
Marlo D. Bruch-Barrett (P70362)
4990 Northwind Drive, Suite 121
East Lansing, MI 48823
Telephone: (517) 332-3390
jfixel@fixellawoffices.com

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