IN THE COURT OF COMMON PLEAS GENERAL DIVISION … · IN THE COURT OF COMMON PLEAS GENERAL DIVISION...

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IN THE COURT OF COMMON PLEAS

GENERAL DIVISION

CUYAHOGA COUNTY, OHIO

STATE EX REL. COUNTY OF CUYAHOGA )

1219 Ontario Street ) CASE NO:

Cleveland, Ohio 44113 )

) JUDGE:

Plaintiff, )

)

v. )

)

JONES LANG LASALLE GREAT LAKES )

CORPORATE REAL ESTATE PARTNERS, )

LLC (FORMERLY GREAT LAKES )

CORPORATE REAL ESTATE PARTNERS, )

LLC) )

c/o Statutory Agent, )

CSC-Lawyers Incorporating Service ) COMPLAINT

50 W. Broad ST Suite 1800 )

Columbus, OH 43215 ) (JURY DEMAND ENDORSED HEREON)

)

and )

)

JONES LANG LASALLE, INC. )


CSC-Lawyers Incorporating Service )

7 St. Paul Street, Suite 1600 )

Baltimore, MD 21202 )

)

and )

)

HARVEY G. OPPMANN )

7460 Foxboro Rd. )

Gates Mills, Ohio 44040-9687 )

)

and )

)

944 PROSPECT AVENUE LLC )


U-B Corporation )

Skylight Office Tower, Ste. 1100 )

1660 W. 2nd St. )

Cleveland, Ohio 44113-1448 )

)

and )

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)

VINCENT A. RUSSO )

37245 Beech Hills Drive )

Willoughby Hills, OH 44094 )

)

and )

)

VINCORE, LLC )


Vincent Russo )

22250 Harms Drive )

Richmond Heights, OH 44143 )

)

and )

)

GARIBALDI HOLDINGS )


Vincore, LLC )

1133 Bonnine Ln. )

Mayfield Heights, OH 44124 )

)

and )

)

M2J1, LLC )


Vincent P. Carbone )

5885 Landerbrook Drive Ste 110 )

Cleveland, OH 44124 )

)

and )

)

MIDWEST ENTERTAINMENT VENTURE, )

LLC )


Ernest V. Roncone )

1299 West 9th

Street )


)

and )

)

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ANATOMY NIGHTCLUB )

1299 W 9th St. )


)

Defendants. )

Plaintiff for its Complaint against Defendants, Jones Lang LaSalle Great Lakes Corporate

Real Estate Partners, LLC, formerly known as Great Lakes Corporate Real Estate Partners, LLC

(“Great Lakes”), Jones Lang LaSalle, Inc. (“Jones Lang”), Harvey G. Oppmann (“Oppmann”)

944 Prospect Avenue LLC (“Prospect”), Vincent A. Russo (“Vincent Russo”), VinCore, LLC

(“VinCore”), Garibaldi Holdings (“Garibaldi”), M2J1, LLC (“M2J1”), Midwest Entertainment

Venture, LLC (“MEV”), and Anatomy Nightclub (“Anatomy”) (collectively “Defendants”),

states as follows:

I. PARTIES AND RELEVANT THIRD-PARTIES

1. Cuyahoga County is a body corporate and politic as well as a political subdivision

of the State of Ohio (“Cuyahoga County”).

2. Great Lakes is an Ohio limited liability company doing business in Cuyahoga

County, Ohio. During the relevant time period, Great Lakes did business under the fictitious

name “The Staubach Company – Great Lakes Region” and was a subsidiary of The Staubach

Company, Inc. (“Staubach”). Through the merger of Staubach Company and Jones Lang in 2008

and by operation of law, Great Lakes became a subsidiary of Jones Lang and changed its name

with the Ohio Secretary of State to “Jones Lang LaSalle Great Lakes Corporate Real Estate

Partners, LLC” on August 21, 2008. Great Lakes at all times related hereto was the alter ego of

Staubach.

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3. Jones Lang is a Maryland corporation doing business in Cuyahoga County and is

the successor to Staubach by merger and operation of law.

4. Oppmann is an individual residing in Cuyahoga County, Ohio.

5. Prospect is an Ohio limited liability company doing business in Cuyahoga

County, Ohio. Upon information and belief, Oppmann is a member and manager of Prospect.

6. Vincent Russo is an individual residing in Cuyahoga County, Ohio. Vincent

Russo is the son of Frank Russo, the former Auditor of Cuyahoga County.

7. VinCore is an Ohio limited liability company doing business in Cuyahoga

County, Ohio. Upon information and belief, Vincent Russo is a member and manager of

VinCore.

8. Garibaldi Holdings is an Ohio limited liability company doing business in

Cuyahoga County, Ohio. Upon information and belief, VinCore is a member and manager of

Garibaldi Holdings.

9. M2J1 is an Ohio limited liability company doing business in Cuyahoga County,

Ohio. Upon information and belief, Vincent Carbone is a member and manager of M2J1.

10. MEV is an Ohio limited liability company doing business in Cuyahoga County,

Ohio and was in part owned by Steven Pumper as an “off the book” partner.

11. Anatomy is a nightclub operating as a dba of MEV.

12. Anthony O. Calabrese, III (“Calabrese”) was previously an attorney licensed to

practice law in the State of Ohio.

13. Jimmy Dimora (“Commissioner Dimora”) is a former Cuyahoga County

Commissioner.

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14. J. Kevin Kelley (“Kelley”) worked in the Cuyahoga County Treasurer’s Office

and was part of Commissioner Dimora’s inner circle.

15. Burlwood Holdings, LLC (“Burlwood”) was an Ohio limited liability company

owned and managed by Calabrese.

16. Vincent Carbone was the president of R.P. Carbone Company.

17. R.P. Carbone Company (“Carbone”) is an Ohio corporation who performs

construction and real estate services.

18. Jurisdiction and venue are proper before this Court as Cuyahoga County is where

all or part of the claims for relief arose.

II. FACTS AND BACKGROUND

19. In January of 2003, Great Lakes hired Calabrese and his law firm to act as its

agent.

20. Great Lakes wanted to do work for Cuyahoga County and had not been successful

in obtaining Cuyahoga County’s business.

21. Great Lakes hired Calabrese and his law firm, in part, because they wanted help

getting work from Cuyahoga County.

22. As a result of hiring Calabrese and his law firm as its agent, in February of 2003,

Great Lakes began having meetings with Cuyahoga County officials.

23. As a result of hiring Calabrese and his law firm as its agent, in March of 2003,

Great Lakes had a private meeting with then Commissioner Dimora.

24. Shortly after meeting with Commissioner Dimora, Great Lakes made a proposal

to Commissioner Dimora to provide services to Cuyahoga County (“Proposal”).

25. The Proposal was sold to Cuyahoga County as being a “no cost” agreement.

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26. In April of 2003, Great Lakes and Calabrese met to discuss a strategy to obtain

work for Great Lakes from Cuyahoga County.

27. As a result of hiring Calabrese and his law firm as its agent, Great Lakes had

another private meeting with then Commissioner Dimora in May of 2003.

28. By September of 2003, Great Lakes’ Proposal was accepted and it was hired to

provide services to Cuyahoga County in connection with Courthouse Square and the Marion

Building.

29. Great Lakes’ fee for the work it was to do on Courthouse Square and the Marion

Building was to come from third parties and therefore, according to Great Lakes, was a “no cost”

fee to Cuyahoga County.

30. By November 2003, Great Lakes had structured a deal on both Courthouse Square

and the Marion Building.

31. Despite the “no cost” fee to Cuyahoga County, after the deal was structured on

Courthouse Square and the Marion Building, Great Lakes suggested financing a total of

$295,000 into the transaction cost to be paid by Cuyahoga County and indicated that doing so

would save Cuyahoga County money.

32. On November 25, 2003, Cuyahoga County issued a Request for Proposal for

services related to the proposed consolidation of the County’s agencies into one building or

campus (“RFP”).

33. The responses to the RFP were due on January 30, 2004.

34. On December 11, 2003, while Great Lakes was planning its response to the RFP,

Calabrese and Great Lakes had a private meeting with then Commissioner Dimora.

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35. In February of 2004, Staubach, on behalf of what would become Great Lakes,

submitted its RFP response.

36. In its RFP response letter, Great Lakes, through its employees, Robert Roe,

Christopher Livingston and Michael McShea stated as its Guarantee of Value “if Cuyahoga

County ever believes that [Great Lakes] has not performed on this assignment in accordance with

your expectations, the County has the unilateral right to adjust our fees. To our knowledge, no

other firm in the country will put their reputation, resources and fees 100% at risk.”

37. The Great Lakes RFP response indicated that its subcontractors would perform

much of the initial work: DLZ would be leading the effort on space planning; RCJ Resources

LLC would be providing public participation, program and project facilitation and management,

government relations and community needs assessments; Johnson Controls, Inc. would be

providing energy saving and building controls solutions; and Carbone would provide services

that were unclear; however, the RFP response listed work previously completed by Carbone for

Cuyahoga County.

38. The Great Lakes RFP stated that, if Cuyahoga County pursued a leasehold interest

in a building as opposed to a purchase, its fee would range between 2%-4% of the gross

aggregate value of the lease.

39. The Great Lakes RFP stated that, if Cuyahoga County decided to purchase a

property, the fee would be paid by the seller at a rate of $5.00-$7.00 per square foot calculated

on gross building area.

40. The Great Lakes RFP stated that Cuyahoga County would need to provide a

retainer of an uncertain amount at the outset of the project, which would be credited or given

back upon completion of the project.

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41. In March of 2004, Great Lakes proposed in response to the RFP and was selected

as one of five in which Cuyahoga County would further evaluate.

42. The other four selected RFP responses stated a sum certain in the range of

$300,000-$400,000 for phases I and II of the project.

43. During April of 2004, all five finalists made presentations to Cuyahoga County.

44. In April of 2004, while the decision was pending, Great Lakes had meetings with

Cuyahoga County officials arranged by Calabrese.

45. A contract was not awarded on the RFP proposals until October 5, 2004.

46. In the meantime, while waiting to learn who would be selected, on June 1, 2004,

Great Lakes entered into an agreement with Vincent Russo through VinCore. (“VinCore

Contract”).

47. The VinCore Contract provided that VinCore’s services would be limited to

“providing certain government relations and similar consulting services.”

48. As payment for the services, Great Lakes agreed to pay VinCore $2,000 in June

of 2004 and $2,000 in July of 2004.

49. In June of 2004, Great Lakes and Calabrese held additional meetings with

Cuyahoga County officials.

50. On July 2, 2004, Staubach sent in a pricing proposal for the RFP services because

their initial RFP response was not clear as to cost.

51. The July 2, 2004 pricing proposal indicated that because Cuyahoga County did

not yet know if it was going to lease or purchase a property, it proposed to be paid $5.85 per

gross building square foot for any type of transaction that took place in Phase III of the project.

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52. Staubach proposed to provide consulting and strategic planning services on

Phases I and II of the project on an hourly basis for a lump sum of $396,000 to be paid in four

consecutive monthly installments, with the amount to be credited back to Cuyahoga County once

Cuyahoga County entered into a lease or purchase agreement.

53. Great Lakes was selected, and in September of 2004, Great Lakes’ agent

Calabrese was negotiating a contract for Great Lakes with Cuyahoga County on the work

described in the RFP.

54. Purportedly, on October 1, 2004, Great Lakes entered into another contract with a

Vincent Russo entity, “Garibaldi Holdings” (“Garibaldi 1 Contract”).

55. Garibaldi Holdings used Great Lakes’ agent Calabrese’s law firm address as its

address.

56. The Garibaldi 1 Contract provided that Garibaldi Holdings would provide

government relations work in exchange for $150,000.

57. The government relations work referenced in the Garabaldi 1 Contract was to be

limited to “services provided by [Great Lakes] pursuant to [the Cuyahoga County Contract].”

58. The Garibaldi 1 Contract for government relations work specifically references by

date an event that had not yet occurred, i.e., the October 5, 2004 contract Great Lakes would

enter into with Cuyahoga County.

59. As of October 1, 2004, Great Lakes did not know the terms of the final contract

with Cuyahoga County or when the contract would be signed.

60. Purportedly, on October 1, 2004, Great Lakes entered into a contract with

Carbone which provided that Carbone would provide government relations work in exchange for

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a percentage of the amount Great Lakes made on the Cuyahoga County Contract (“Carbone

Government Relations Contract”).

61. The October 1, 2004 the Carbone Government Relations Contract specifically

references an event that had not yet occurred, i.e., the October 5, 2004 contract Great Lakes

would enter into with Cuyahoga County.

62. As of October 1, 2004, Great Lakes did not know what the terms of the final

contract would be with Cuyahoga County or when it would be signed.

63. On October 5, 2004, Cuyahoga County entered into a contract with Great Lakes

for Great Lakes to provide the services as set forth in their RFP response (the “Cuyahoga County

Contract”). A copy of the Cuyahoga County Contract is attached hereto as Exhibit 1.

64. Article 4 of the Cuyahoga County Contract states:

[Great Lakes] will be solely and entirely responsible for its

acts and the acts of its agents, employees, servants and

subcontractors during the performance of this Agreement.

See Cuyahoga County Contract, P. 20.

65. The Cuyahoga County Contract also provides in Article 13 that:

[Great Lakes] agrees to comply with all applicable federal,

state and local laws, regulations, and codes…. See

Cuyahoga County Contract P. 26.

66. The Cuyahoga County Contract also provides in Article 16 that Great Lakes shall:

. . .act solely on behalf of the Client and recognizes that its

fiduciary responsibility is to the Client in all matters related

to this Agreement. See Cuyahoga County Contract P. 27.

67. On November 1, 2004, Great Lakes entered into a second contract with Carbone

for Carbone to provide services in connection with the Contract (“Carbone Work Contract”).

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68. Great Lakes agreed in the Carbone Work Contract to pay Carbone $30,000 for its

time and services in connection with work required in Phase I & II of the Cuyahoga County

Contract.

69. Also, on November 1, 2004, Great Lakes entered into yet another agreement with

VinCore, but this time doing business as Garibaldi (“Garibaldi 2 Contract”).

70. The Garibaldi 2 Contract provided that VinCore’s services would be government

relations and marketing services and promoting the services of Great Lakes.

71. The Garibaldi 2 Contract specifically stated that Garibaldi would provide

governmental and marketing services in “regard to assisting, advising and counseling the

Company in regard to any of its contracts with Cuyahoga County, Ohio.”

72. As payment under the Garibaldi 2 Contract, Great Lakes agreed to pay $140,000.

73. The services required by Carbone and Garibaldi in the Carbone Government

Relations Contract, Garibaldi 1 Contract and Garibaldi 2 Contract had no beginning and no

ending date.

74. Carbone, Garibaldi and Great Lakes were all represented by Calabrese.

75. Garibaldi was paid $140,000 by Great Lakes between December of 2004 and

October of 2005.

76. Great Lakes charged the $140,000 paid to Garibaldi as costs associated with the

Cuyahoga County Contract.

77. Great Lakes has no records of what the actual services were that were provided by

VinCore or Garibaldi other than the contracts and the checks it paid.

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78. Vincent Russo, the owner of VinCore and Garibaldi, was indicted and pled guilty

to bribery, aiding and abetting, conspiracy to commit bribery and HOBBS Act conspiracy

charges related to federal funds.

79. Great Lakes paid $324,800 to Carbone or one of his entities on the Carbone

Government Services Contract.

80. Great Lakes has no records of what services Carbone provided under the Carbone

Government Services Contract other than the contract and the checks it paid.

81. The payments under the Carbone Government Services Contract were charged as

a cost by Great Lakes to the Cuyahoga County Contract.

82. Neither VinCore, Garibaldi, Vincent Russo, Vincent Carbone nor Carbone make

their principal living or profits by providing government relations services.

83. Carbone was indicted and pled guilty to conspiracy and money laundering related

to bribery to gain governmental contracts.

84. In November of 2004, Great Lakes wrote its agent Calabrese and thanked him for

helping it get the Cuyahoga County Contract.

85. By November 19, 2004, Great Lakes had already completed the initial phase of

the work and reported the results to Cuyahoga County.

86. In that report, Great Lakes placed the Ameritrust property owned by The Richard

E. Jacobs Group as being in 4th place overall as a potential location for the consolidated

Cuyahoga County location.

87. In December of 2004, Great Lakes and its agent Calabrese had a dinner scheduled

with then Commissioner Dimora that had to be rescheduled.

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88. On January 21, 2005, Great Lakes, its agent Calabrese and then Commissioner

Dimora met at the Holiday Inn on Rockside Road.

89. On January 25, 2005, Great Lakes reported to Cuyahoga County that they had

completed the initial phases of the work – Phases I & II.

90. The Phase I & II work was completed in under 4 months.

91. The report on Phase I & II recommended that Cuyahoga County proceed with the

Ameritrust site.

92. This recommendation was made only 2 months after Ameritrust was in 4th place.

93. Great Lakes has no records which demonstrate that additional facts were gathered

or that additional information was learned between the time Ameritrust was ranked in 4th place

by Great Lakes and when it was selected as the site Cuyahoga County should pursue.

94. On March 31, 2005, Great Lakes wrote Cuyahoga County and indicated that it

was seeking the then Cuyahoga County Commissioners’ approval to move into Phase III of the

Cuyahoga County Contract.

95. Great Lakes never received the approval of Cuyahoga County to move into Phase

III of the contract.

96. Instead, the then Cuyahoga County Commissioners and Great Lakes agreed that

Great Lakes would cease work on the contract and would be paid an additional $2,615,000 along

with keeping the $385,000 retainer (“Cease Work Contract”).

97. Great Lakes was therefore paid $3,000,000 for approximately 5 months of work.

98. Much of the work on the Cuyahoga County Contract was done by subcontractors

of Great Lakes.

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99. Had Great Lakes continued and completed the Cuyahoga County Contract, it

anticipated returning the $385,000 and disbursing 35% of the future payments made under the

Cuyahoga Contract to subcontractors.

100. Great Lakes anticipated that its portion of the fee would be $2,850,000 had it

completed the Cuyahoga County Contract.

101. Instead, Great Lakes received $3,000,000 and did not have to finish the work,

incur the costs or take any risks.

102. The Cease Work Contract provided that Great Lakes would be paid once the deal

for the Ameritrust site was closed.

103. Cuyahoga County paid Great Lakes as required by the Cease Work Contract.

104. Vincent Carbone, through his lawyer Calabrese, formed a new LLC in October of

2005 known as M2J1.

105. M2J1 never operated as a business.

106. Despite having contracted with Carbone on the Carbone Government Relations

Contract, Great Lakes was requested to, and did pay, M2J1 instead of Carbone.

107. Great Lakes paid M2J1 on the Carbone Government Relations Contract two

checks, one for $25,000 and one for $299,800 for a total of $324,800.

108. The $324,800 paid to M2J1 was charged by Great Lakes to the Cuyahoga County

Contract.

109. Despite being charged internally by Great Lakes to the Cuyahoga County

Contract, the $324,800 due to Carbone and paid to M2J1 was not included on the Great Lakes

budgets kept on the Cuyahoga County Contract while work on it was ongoing.

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110. Carbone was paid $30,000 by Great Lakes on the Carbone Service Contract and

that $30,000 was accurately reflected on Great Lakes’ ongoing project budgets.

111. Once M2J1 was paid on the Carbone Government Relations Contract, it

distributed the money to three others.

112. One payment in the amount of $99,000 was paid to Burlwood, an entity owned by

Calabrese.

113. One payment in the amount of $70,000 was made to a Calabrese friend.

114. One payment in the amount of $70,000 was made to an individual who was given

instructions to, and did pay, the $70,000 to Kelley.

115. Great Lakes’ agent Calabrese was indicted on July 16, 2013, and pled guilty to an

indictment in Cuyahoga County, in part, based on his actions out of the Ameritrust site and the

$99,000 payment that was from Great Lakes to Carbone to Calabrese.

116. By virtue of his guilty plea, Great Lakes’ agent Calabrese admitted that the

$70,000 payment to Kelley was an unlawful bribe related to the Ameritrust project.

117. It was not until the Cuyahoga County indictment against Calabrese was filed that

Cuyahoga County was aware that there was corruption associated with the Ameritrust site.

118. Calabrese was indicted and pled guilty to federal charges, including multiple

counts of RICO conspiracy, bribery and conspiracy to commit bribery concerning programs

receiving federal funds, Hobbs Act conspiracy, mail fraud and conspiracy to commit mail fraud.

119. Three of the people who either owned companies or who personally worked with

Great Lakes and to whom Great Lakes paid over $500,000 for government relations work on the

Cuyahoga County Contract have been indicted and pled guilty on charges of corruption related to

public officials.

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120. Three of the people who either owned companies or who personally worked with

Great Lakes, and to whom Great Lakes paid over $500,000 for government relations work on the

Cuyahoga County Contract, have been indicted and pled guilty on charges of corruption related

to public officials and have admitted to engaging in corruption with numerous other former

government officials that have either pled guilty to or been found guilty of corruption while in

office, with that corruption stemming from their dealings with the same people Great Lakes

hired.

121. Great Lakes hired VinCore, Garibaldi, Carbone and Calabrese because Great

Lakes knew they could influence the decision makers in Cuyahoga County.

122. Great Lakes paid VinCore, Garibaldi, Carbone and Calabrese an inflated amount

of money because it knew or should have known that VinCore, Garibaldi, Carbone and

Calabrese needed funds to provide to public officials in order to influence them in Great Lakes’

favor.

123. Great Lakes benefited from the corrupt activities of VinCore, Garibaldi, Carbone,

M2J1, Burlwood and Calabrese by, among other things, being selected for the Ameritrust project

and receiving $3,000,000 for work worth substantially less money.

124. But for the corruption in its dealing with Cuyahoga County, Great Lakes would

not have been selected and would have been paid less.

125. But for the corruption in its dealing with Cuyahoga County, Great Lakes would

not have selected the Ameritrust site as the best site for Cuyahoga County to pursue.

126. Selection of the Ameritrust site cost Cuyahoga County millions of dollars it

should not have had to incur.

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127. As part of the purchase of the Ameritrust site, Cuyahoga County needed

additional parking.

128. Oppmann and Prospect owned a parking garage in close proximity to the

Ameritrust site (“Parking Garage”).

129. Oppmann and Cuyahoga County began negotiations regarding a purchase by

Cuyahoga County of the Parking Garage.

130. Oppmann was aware that Steven Pumper (“Pumper”) was part of then

Commissioner Dimora’s inner circle.

131. Oppmann contacted Pumper because he was having issues with Cuyahoga County

regarding the sale of the Parking Garage.

132. Oppmann told Pumper that he wanted to sell the Parking Garage but that

Cuyahoga County was dragging its feet and he asked Pumper to get the sale pushed through.

133. Pumper told Oppmann that he would need money to get the sale pushed through.

134. Oppmann agreed to pay Pumper $250,000 from the sales proceeds of the Parking

Garage if Pumper got Cuyahoga County to close the purchase.

135. The agreement for $250,000 to be paid was an oral agreement and there are no

letters or writings of any kind evidencing the terms of the agreement.

136. Oppmann called Pumper several times to encourage him to get the deal going.

137. Pumper talked to then Commissioner Dimora and told him that if he got the deal

for the purchase of the Parking Garage moving as Oppmann requested, Pumper would give

Dimora $35,000 because Pumper was helping Oppmann.

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138. The sale of the Parking Garage was consummated with the Garage Contract

entered on May 29, 2007 between Cuyahoga County, Oppmann and Prospect (“Garage

Contract”).

139. The Garage Contract required Cuyahoga County to pay Oppmann and Prospect

$5,145,000.

140. The Garage Contract was finalized at a price higher than Cuyahoga County’s

appraised value of the Parking Garage.

141. The sale of the Parking Garage was closed and Oppmann was satisfied that

Pumper had kept his end of the oral bargain and agreed the $250,000 was owed to Pumper.

142. Pumper began making payments to then Commissioner Dimora, as agreed, after

the sale of the Parking Garage was completed.

143. Pumper asked Oppmann not to pay Pumper directly.

144. Oppmann agreed to help Pumper hide the payments.

145. Pumper requested that the $250,000 be paid in part to his father, in part to the

company he worked for, DAS Construction Company (“DAS”), and the rest to the owner of the

nightclub Anatomy, MEV.

146. Oppmann paid Pumper’s father even though he provided no services for the

payment.

147. Oppmann requested, and Pumper’s father agreed, to generate a false invoice to

Oppmann in the amount of $50,000 for government relations work.

148. Oppmann paid DAS even though DAS had not provided services for the payment.

149. Oppmann agreed to and did make the three payments to Pumper as requested by

Pumper.

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150. Pumper was a silent partner in Anatomy.

151. Anatomy was in need of a bank loan and did not have the assets to support a loan.

152. In order to get the loan, Pumper asked Oppmann to give $180,000 of the

$250,000 to MEV to be passed along to Anatomy.

153. Oppmann agreed that Anatomy and/or MEV would give Oppmann a promissory

note and then once Anatomy and/or MEV had a bank loan, the $180,000 would be withdrawn

from Anatomy and/or MEV by Pumper and Oppmann would destroy the promissory note.

154. Oppmann was aware that the only purpose to the fake promissory note was to

make the loan to Anatomy and/or MEV appear legitimate.

155. The fake promissory note was purportedly signed in August of 2007 and did not

require payments until March of 2009.

156. The payments on the fake promissory note therefore were not due until after the

Cuyahoga County corruption scandal was generally known.

157. There was no security taken by Oppmann for the loan that had no payments on it

for two years.

158. Oppmann performed no due diligence on MEV and/or on Anatomy before

making the $180,000 loan.

159. The $180,000 was not a legitimate loan and the payments to Pumper’s father and

DAS were not payments for legitimate debts, but rather a way to hide the payment to Pumper for

his having engaged in corruption to benefit Oppmann and Prospect.

160. As a result of the bribes paid to Pumper and others, Cuyahoga County paid more

under the Garage Contract than it should have.

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COUNT ONE

(Violation of R.C. § 309.12—All Defendants)

161. Cuyahoga County realleges and reavers all of the allegations contained in the

foregoing Paragraphs of this Complaint.

162. All Defendants received public funds for which they were not entitled.

163. The receipt of the public funds by all Defendants was in violation of R.C.

§§309.12 and 309.13.

164. Cuyahoga County has sustained damage as a result of Defendants’ conduct.

165. As a direct and proximate result of Defendants’ violations of R.C. §§309.12 and

309.13, all Defendants are liable to Cuyahoga County in an amount to be proven at trial in excess

of $25,000, plus interest, costs and all other remedies provided under R.C. §§309.12 and 309.13.

COUNT TWO

(Breach of Contract – Great Lakes)



167. Cuyahoga County has fully performed according to the terms of the Cuyahoga

County Contract.

168. Great Lakes has breached the Cuyahoga County Contract.

169. As a direct and proximate result of Great Lakes’ breach, Cuyahoga County is

entitled to recover from Great Lakes damages in an amount to be proven at trial in excess of

$25,000, plus interest and costs.

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COUNT THREE

(Unjust Enrichment—All Defendants)



171. Cuyahoga County conferred a benefit upon all Defendants.

172. All Defendants had knowledge of the benefit conferred by Cuyahoga County.

173. All Defendants have been unjustly enriched by the benefit conferred upon them

by Cuyahoga County and have retained the benefit under circumstances where it would be unjust

for them to retain that benefit and would be to the detriment of Cuyahoga County.

174. As a direct and proximate result of their unjust enrichment, all Defendants are

liable to Cuyahoga County in an amount to be proven at trial in excess of $25,000, plus interest

and costs.

COUNT FOUR

(Fraud – Great Lakes)



176. Great Lakes had a duty to disclose important and material facts to Cuyahoga

County regarding its work for Cuyahoga County.

177. Despite this duty, Great Lakes and/or its agents acted in contravention of law,

illegally, corruptly and fraudulently to procure the Cuyahoga County Contract, to select the

Ameritrust site and to procure the Cease Work Contract.

178. Great Lakes knew it and/or its agents were concealing material facts from

Cuyahoga County, and did so with the intent to mislead Cuyahoga County.

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179. Great Lakes knew Cuyahoga County was relying on Great Lakes and its agents to

be truthful and complete.

180. Cuyahoga County’s reliance upon Great Lakes and its agents’ conduct and

concealment was justifiable and reasonable.

181. As a direct and proximate result of its fraud and corruption upon Cuyahoga

County, including the concealment of important and material facts, Great Lakes is liable to

Cuyahoga County in an amount to be proven at trial in excess of $25,000, plus interest, costs and

attorney fees.

COUNT FIVE

(Breach of Fiduciary Duty—Great Lakes)



183. Great Lakes had a fiduciary relationship and duty to Cuyahoga County and

breached and/or failed to observe that duty.

184. Great Lakes’ breach of fiduciary duty directly and proximately caused damage to

Cuyahoga County.

185. As a direct and proximate result of Great Lakes’ breach of fiduciary duty, Great

Lakes is liable to Cuyahoga County for damages in an amount to be proven at trial in excess of

$25,000, plus interest and costs.

COUNT SIX

(Fraud in the Inducement—Great Lakes)



187. Great Lakes entered into the Cease Work Contract with the Cuyahoga County.

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188. Great Lakes had a duty to disclose important and material facts to Cuyahoga

County regarding the Cease Work Contract, and had a duty not to mislead or misstate material

facts related to the Cease Work Contract.

189. Great Lakes knew that it was committing a fraud upon Cuyahoga County by

concealing material facts and/or providing misleading and/or misstated facts related to the Cease

Work Contract with the intent to mislead Cuyahoga County.

190. Great Lakes knew Cuyahoga County was relying on Great Lakes to be truthful

and complete with regard to the Cease Work Contract.

191. Cuyahoga County’s reliance upon Defendant Great Lakes’ conduct and

concealment was justifiable and reasonable.

192. As a direct and proximate result of its fraud upon Cuyahoga County, including the

concealment, misleading, and misstatement of important and material facts, Great Lakes is liable

to Cuyahoga County in an amount to be proven at trial in excess of $25,000, plus interest, costs

and attorney fees.

COUNT SEVEN

(Declaratory Judgment-Great Lakes)

193. Cuyahoga County realleges and reavers all of the above allegations contained in

the foregoing Paragraphs of this Complaint.

194. Great Lakes induced the Cuyahoga County to enter into the Cease Work Contract

through fraud.

195. The Cease Work Contract was entered into as a result of the fraud committed by

Great Lakes against Cuyahoga County and, as a result, the Cease Work Contract is null and void.

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196. Great Lakes and Cuyahoga County dispute the enforceability of the Cease Work

Contract; therefore, a justiciable controversy exists between the parties as to whether the Cease

Work Contract is enforceable.

197. Cuyahoga County hereby requests pursuant to R.C. §2721 et seq., that this Court

declare the Cease Work Contract null and void and unenforceable between the Cuyahoga County

and Great Lakes.

COUNT EIGHT

(Fraud-Oppmann and Prospect)



199. Oppmann and Prospect had a duty to disclose important and material facts to

Cuyahoga County regarding the Garage Contract, but instead Oppman and Prospect acted in

contravention of law, illegally, corruptly and fraudulently to procure the Garage Contract and to

conceal material facts.

200. Oppmann and Prospect knew that they were concealing material facts from

Cuyahoga County and did so with the intent to mislead Cuyahoga County.

201. Oppman and Prospect knew Cuyahoga County was relying on Oppman and

Prospect to be truthful and complete with regard to the Garage Contract.

202. Cuyahoga County’s reliance upon Oppman and Prospect was justifiable and

reasonable.

203. As a direct and proximate result of Oppman and Prospect’s fraud, including the

concealment of important and material facts, Oppman and Prospect are liable to Cuyahoga

County in an amount to be proven at trial in excess of $25,000, plus interest, costs and attorney

fees.

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COUNT NINE

(Violation of the Ohio Corrupt Practices Act—Great Lakes, Jones Lang, Vincent Russo,

VinCore, Garibaldi Holdings, and M2J1)

204. Cuyahoga County realleges and reavers the allegations in the foregoing

Paragraphs.

205. Cuyahoga County and Great Lakes, Jones Lang, Vincent Russo, VinCore,

Garibaldi Holdings, and M2J1 are persons under the Ohio Corrupt Practices Act (“OCPA”), also

known as R.C. § 2923.31(G).

206. Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi Holdings, and M2J1

along with other persons constituted an “enterprise” as that term is defined under the OCPA in

that they were a group of persons associated in fact.

207. The enterprise constituted an ongoing organization with a formal and/or informal

framework or organizational structure whose members functioned as a continuing unit with a

common purpose of achieving the objectives of the enterprise.

208. The structure of the enterprise featured a purpose, relationships among those

associated with the enterprise, and longevity sufficient to permit those associated with the

enterprise to pursue the enterprise’s purpose.

209. The purpose of the enterprise was to use the power and influence of Cuyahoga

County public officials for the personal and financial benefit of Great Lakes, Jones Lang,

Vincent Russo, VinCore, Garibaldi Holdings, and M2J1.

210. The enterprise existed separate and distinct from Great Lakes, Jones Lang,

Vincent Russo, VinCore, Garibaldi Holdings, and M2J1.

211. Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi Holdings, and

M2J1were associated with the enterprise.

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212. The enterprise existed separate and distinct from the pattern of corrupt activity,

insofar as each associate of the enterprise engaged in some lawful activity that is not at issue in

this case.

213. The enterprise is complicit in the pattern of corrupt activity.


M2J1, their employees, agents and associated third parties did attempt to, and did conspire to

conduct and/or participate in the affairs of the enterprise through a pattern of corrupt activity in

violation of R.C. §2923.32(A)(1).

215. The pattern of corrupt activity was, in part, targeted toward obtaining the

Cuyahoga County Contract, and securing the purchase of the Ameritrust site.


M2J1, either firsthand or by and through their respective employees, agents and/or associated

third parties, engaged in, attempted to engage in, conspired to engage in, and/or solicited others

to engage in two or more incidents of corrupt activity, specifically including, but not limited to,

conduct constituting violations of R.C. §2921.02 (“Bribery”); R.C. §2921.03 (“Intimidation”);

R.C. §1315.55 (“Money Laundering”); R.C. §2923.31(I)(1) (“Racketeering”); and R.C. §2921.32

(“Obstructing Justice”).

217. Pursuant to R.C. §2923.02 (“Attempt”), Great Lakes, Jones Lang, Vincent Russo,

VinCore, Garibaldi Holdings, and M2J1 purposefully and/or knowingly engaged in, or used

other persons to engage in conduct that, if successful, would have the effect of violating of R.C.

§2921.02 (“Bribery”); R.C. §2921.03 (“Intimidation”); R.C. §1315.55 (“Money Laundering”);

R.C. §2923.31(I)(1) (“Racketeering”); and R.C. §2921.32 (“Obstructing Justice”).

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218. Pursuant to R.C. §2923.01 (“Conspiracy”), Great Lakes, Jones Lang, Vincent

Russo, VinCore, Garibaldi Holdings, and M2J1 did, with a purpose to commit, promote, or

facilitate a pattern of corrupt activity, plan or assist in planning conduct, or agree that one of

them would engage in conduct that, if successful, would have the effect of violating R.C.


R.C. §2923.31(I)(1) (“Racketeering”); and R.C. §2921.32 (“Obstructing Justice”). To this end,

the overt acts specified herein were taken by Great Lakes, Jones Lang, Vincent Russo, VinCore,

Garibaldi Holdings, and M2J1, or someone with whom Great Lakes, Jones Lang, Vincent Russo,

VinCore, Garibaldi Holdings, and M2J1.


M2J1, knowingly and by force, and through the enterprise, attempted to, conspired to and did

influence public officials in the discharge of their duties, which constitutes Intimidation and/or

Bribery, attempted Intimidation and/or Bribery and/or Conspiracy to commit Bribery and/or

Intimidation.


attempted to, conspired to and did conduct one or more transactions with the knowledge and

purpose to promote, manage, establish, further, carry on, or facilitate the promotion,

management, establishment, or carrying on of corrupt activity, which constitutes Money

Laundering, attempted Money Laundering and/or Conspiracy to commit Money Laundering.


attempted to, conspired to and did destroy or conceal physical evidence of the pattern of corrupt

activity in order to hinder the discovery of the corrupt activity, which constitutes Obstruction of

Justice, attempted Obstruction of Justice and/or Conspiracy to commit Obstruction of Justice.

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222. Great Lakes’ and Jones Lang’s agent Calabrese used his political influence to

bribe members of county government to award them the Cuyahoga County Contract and to enter

into the Cease Work Contract.

223. Following Great Lakes and Jones Lang receiving $3.0 million from Cuyahoga

County, Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi Holdings, and/or M2J1,

through one or more persons and entities caused approximately $99,000.00 to be paid to

Burlwood to reward Great Lakes’ agent Calabrese.

224. Great Lakes and Jones Lang, through its agent Calabrese, promised Kelly that if

he helped them he would receive something of value.

225. On or about October 26, 2005, after Great Lakes and Jones Lang received

$3,000,000, Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi Holdings, and/or

M2J1, through one or more persons or entities, caused $70,000.00 to be paid to Kevin Kelley or

on his behalf.


have and continue to attempt to conceal their involvement and complicity in the corrupt activity

by destroying records from the relevant time periods and from individuals with knowledge of

their bad acts.


each had reason to know or should have known that their employees, agents and/or

representatives were conspiring with others to commit the offenses specified above.

228. Pursuant to R.C. §2923.03 (“Complicity”), Great Lakes, Jones Lang, Vincent

Russo, VinCore, Garibaldi Holdings, and M2J1 were complicit in the acts of their employees,

agents and/or representatives, such as Calabrese and Kelley, insofar as they solicited and/or

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procured Calabrese and Kelley to exert influence and/or intimidation upon public officials in

exchange for monetary gain from the procurement of the Cuyahoga County Contract and the

Cease Work Contract.


have knowingly received proceeds derived directly and/or indirectly from the pattern of corrupt

activity, and have used the specified proceeds in the operation of the enterprise, in violation of

R.C. § 2923.32(A)(3).

230. Cuyahoga County has been injured through Great Lakes, Jones Lang, Vincent

Russo, VinCore, Garibaldi Holdings, and M2J1’s violation of R.C. § 2923.32, and are therefore

eligible to bring this action pursuant to R.C. § 2923.34 and are allowed all damages recoverable

by law.

COUNT TEN

(Civil Conspiracy— Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi

Holdings, and M2J1)



232. Defendants Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi

Holdings, and M2J1, along with other persons (the “Co-Conspirators”), constituted a malicious

combination of two or more persons with the intent to injure Cuyahoga County.

233. Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi Holdings, M2J1 and

the Co-Conspirators intentionally conspired to obtain and inflate the price of the Cuyahoga

County Contract and the Cease Work Contract for their own personal gain.

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234. Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi Holdings, M2J1 and

the Co-Conspirators had a common understanding or design to obtain and inflate the price of

Cuyahoga County Contract and the Cease Work Contract for their own personal gain.

235. Cuyahoga County has been damaged by the tortious conduct of Great Lakes,

Jones Lang, Vincent Russo, VinCore, Garibaldi Holdings, M2J1 and the Co-Conspirators in an

amount to be determined at trial, in excess of $25,000.00, punitive damages due to the malicious

and intentional nature of Great Lakes, Jones Lang, Vincent Russo, VinCore, Garibaldi Holdings,

and M2J1’s conduct, reasonable attorneys’ fees and court costs and expenses.

COUNT ELEVEN

(Violation of the Ohio Corrupt Practices Act— Oppman, Prospect, MEV and Anatomy)



237. Cuyahoga County and Oppman, Prospect, MEV and Anatomy are persons under

the Ohio Corrupt Practices Act (“OCPA”), also known as R.C. §2923.31(G).

238. Oppman, Prospect, MEV and Anatomy along with other persons constituted an

“enterprise” as that term is defined under the OCPA in that they were a group of persons

associated in fact.

239. The enterprise constituted an ongoing organization with a formal and/or informal

framework or organizational structure whose members functioned as a continuing unit with a

common purpose of achieving the objectives of the enterprise.

240. The structure of the enterprise featured a purpose, relationships among those

associated with the enterprise, and longevity sufficient to permit those associated with the

enterprise to pursue the enterprise’s purpose.

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241. The purpose of the enterprise was to use the power and influence of public

officials for the personal and financial benefit of Oppman, Prospect, MEV and Anatomy.

242. The enterprise existed separate and distinct from Oppman, Prospect, MEV and

Anatomy.

243. Oppman, Prospect, MEV and Anatomy were associated with the enterprise.

244. The enterprise existed separate and distinct from the pattern of corrupt activity,

insofar as each associate of the enterprise engaged in some lawful activity that is not at issue in

this case.

245. The enterprise is complicit in the pattern of corrupt activity.

246. Oppman, Prospect, MEV and Anatomy, their employees, agents and associated

third parties did, did attempt to, and did conspire to conduct and/or participate in the affairs of

the enterprise through a pattern of corrupt activity in violation of R.C. §2923.32(A)(1).

247. The pattern of corrupt activity was, in part, targeted toward obtaining the Garage

Contract.

248. Oppman, Prospect, MEV and Anatomy, either firsthand or by and through their

respective employees, agents and/or associated third parties, engaged in, attempted to engage in,

conspired to engage in, and/or solicited others to engage in two or more incidents of corrupt

activity, specifically including, but not limited to, conduct constituting violations of R.C.


R.C. §2923.31(I)(1) (“Racketeering”); and R.C. §2921.32 (“Obstructing Justice”).

249. Pursuant to R.C. §2923.02 (“Attempt”), Oppman, Prospect, MEV and Anatomy

purposefully and/or knowingly engaged in, or used other persons to engage in, conduct that, if

successful, would have the effect of violating of R.C. §2921.02 (“Bribery”); R.C. §2921.03

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(“Intimidation”); R.C. §1315.55 (“Money Laundering”); R.C. §2923.31(I)(1) (“Racketeering”);

and R.C. §2921.32 (“Obstructing Justice”).

250. Pursuant to R.C. §2923.01 (“Conspiracy”), Oppman, Prospect, MEV and

Anatomy did, with purpose to commit, promote, or facilitate a pattern of corrupt activity, plan or

assist in planning conduct, or agree that one of them would engage in conduct that, if successful,

would have the effect of violating R.C. §2921.02 (“Bribery”); R.C. §2921.03 (“Intimidation”);

R.C. §1315.55 (“Money Laundering”); R.C. §2923.31(I)(1) (“Racketeering”); and R.C. §2921.32

(“Obstructing Justice”). To this end, the overt acts specified herein were taken by Oppman,

Prospect, MEV and Anatomy or someone with whom Oppman, Prospect, MEV and Anatomy

conspired.

251. Oppman, Prospect, MEV and Anatomy, knowingly and by force, and through the

enterprise, attempted to, conspired to and did influence public officials in the discharge of their

duties, which constitutes Intimidation and/or Bribery, attempted Intimidation and/or Bribery

and/or Conspiracy to commit Bribery and/or Intimidation.

252. Oppman, Prospect, MEV and Anatomy attempted to, conspired to and did

conduct one or more transactions with the knowledge and purpose to promote, manage, establish,

further, carry on, or facilitate the promotion, management, establishment, or carrying on of

corrupt activity, which constitutes Money Laundering, attempted Money Laundering and/or

Conspiracy to commit Money Laundering.

253. Oppman, Prospect, MEV and Anatomy attempted to, conspired to and did destroy

or conceal physical evidence of the pattern of corrupt activity in order to hinder the discovery of

the corrupt activity, which constitutes Obstruction of Justice, attempted Obstruction of Justice

and/or Conspiracy to commit Obstruction of Justice.

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254. Oppman and Prospect asked Pumper to use his political influence to bribe

members of county government to award them the Garage Contract in exchange for personal

gain.

255. Following Oppman and Prospect obtaining the Garage Contract on May 29, 2007,

Oppman and Prospect were paid $5,145,000 from Cuyahoga County.

256. Oppman and Prospect then paid, for the benefit of Pumper, $250,000, which

would include payments to be made by Pumper to then Commissioner Dimora for securing the

Garage Contract.

257. Through a complex scheme as stated herein, bribe monies were passed through

Pumper’s father, DAS, MEV and Anatomy.

258. Oppman, Prospect, MEV and Anatomy have and continue to attempt to conceal

their involvement and complicity in the corrupt activity by destroying records from the relevant

time periods and from individuals with knowledge of their bad acts.

259. Oppman, Prospect, MEV and Anatomy each had reason to know that their

employees, agents and/or representatives were conspiring with others to commit the offenses

specified above.

260. Pursuant to R.C. § 2923.03 (“Complicity”), Oppman, Prospect, MEV and

Anatomy were complicit in the acts of their employees, agents and/or representatives, such as

Pumper, insofar as they solicited and/or procured Pumper to exert influence and/or intimidation

upon public officials in exchange for monetary gain from the procurement of the Garage

Contract.

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261. Oppman, Prospect, MEV and Anatomy have knowingly received proceeds

derived directly and/or indirectly from the pattern of corrupt activity, and have used the specified

proceeds in the operation of the enterprise, in violation of R.C. §2923.32(A)(3).

262. Cuyahoga County has been injured through Oppman, Prospect, MEV and

Anatomy’s aforesaid violation of R.C. §2923.32, and are therefore eligible to bring this action

pursuant to R.C. §2923.34 and are allowed all damages recoverable by law.

COUNT TWELVE

(Civil Conspiracy— Oppman, Prospect, MEV and Anatomy)



264. Oppman, Prospect, MEV and Anatomy, along with other persons (the “Co-

Conspirators”), constituted a malicious combination of two or more persons with the intent to

injure Cuyahoga County.

265. Oppman, Prospect, MEV, Anatomy and the Co-Conspirators intentionally

conspired to insure the sale of the garage, and to obtain and inflate the price of the Garage

Contract.

266. Oppman, Prospect, MEV, Anatomy and the Co-Conspirators had a common

understanding or design to obtain and insure the sale of the garage, and inflate the price of the

Garage for their own personal gain.

267. Cuyahoga County has been damaged by the tortious conduct of Oppman,

Prospect, MEV, Anatomy and the Co-Conspirators in an amount to be determined at trial, in

excess of $25,000.00, punitive damages due to the malicious and intentional nature of Oppman,

Prospect, MEV and Anatomy’s conduct, reasonable attorneys’ fees and court costs and expenses.

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COUNT THIRTEEN

(Civil Liability for Criminal Acts—All Defendants)



269. All Defendants engaged in criminal acts, including but not limited to, violations

of R.C. §2921.02 (“Bribery”); R.C. §2921.03 (“Intimidation”); R.C. §1315.55 (“Money

Laundering”); R.C. §2923.31(I)(1) (“Racketeering”); and R.C. §2921.32 (“Obstructing Justice”).

270. That Cuyahoga County is entitled to recover damages in an amount to be proven

at trial in excess of $25,000, plus interest, costs and attorney fees from each Defendant caused by

their criminal act(s) pursuant to R.C. §2307.60.

WHEREFORE, Cuyahoga County respectfully requests judgment against Defendants as

follows:

1. For compensatory damages against all Defendants in excess of $25,000 plus

prejudgment and post judgment interest;

2. For punitive damages;

3. For triple the amount of actual damages pursuant to the Ohio Corrupt Practices

Act;

4. For Cuyahoga County’s reasonable attorney fees, costs and expenses;

5. For a declaratory judgment declaring the Cease Work Contract null and void; and

6. For all other relief which this Court deems equitable and just.

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Respectfully submitted,

/s/ Kerin Lyn Kaminski

Karen L. Giffen (0042663)

Kerin Lyn Kaminski (0013522)

Wm. Joseph Baker (0072845)

GIFFEN & KAMINSKI LLC 1300 East Ninth Street, Suite 1600

Cleveland, Ohio 44114

Telephone: (216) 621-5161

Facsimile: (216) 621-2399

E-Mail: [email protected]

[email protected]

[email protected]

/s/ Donald W. Davis, Jr.

Donald W. Davis, Jr. (0030559)

BRENNAN, MANNA & DIAMOND LLC 75 East Market Street

Akron, Ohio 44308

Telephone: (330) 253-5060

Facsimile: (330) 253-1977

Email: [email protected]

/s/ Joseph W. Boatwright, IV

Joseph W. Boatwright, IV (0078304)

Cuyahoga County Department of Law

1219 Ontario Street, 4th Floor

Cleveland, OH 44113

(216) 698-6464 (Telephone)

(216) 698-2744 (Facsimile)

[email protected]

[Representation and designation pursuant to

August 27, 2013 Agreement governing the

division of duties between the Cuyahoga

County Prosecutor’s Office and Department

of Law]

Attorneys for Cuyahoga County

mailto:[email protected]





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JURY DEMAND

Cuyahoga County hereby demands a trial by jury of all issues so triable.

/s/ Kerin Lyn Kaminski

Kerin Lyn Kaminski (0013522)

Mschill

Rounded Exhibit Stamp

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