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SUMMARY OF FACTS 40. Plaintiff, STEVEN HOOPER, repeats, realleges and reiterates each and every allegation contained in Paragraphs “1” though “39” of the Complaint. 41. Defendant, GERARD WARRENS, individually and as an Officer , Sole Director and Sole Manager of STEALTH SOFTWARE, LLC, actively recruited plaintiff, HOOPER , who became an Employee of STEALTH SOFTWARE, L.L.C., on or about July 1, 2013 after retirement from the F.B.I. GERARD WARRENS is a non immigrant citizen of The Netherlands but resides in Cave Creek, Arizona. 42 WARRENS never disclosed to HOOPER at the time of his employment or subsequently when WARRENS solicited money from HOOPER, that the sole manager of STEALTH SOFTWARE, L.L.C was STEALTH SOFTWARE, B.V., a Netherlands business entity …show more content…

Plaintiff alleges that "STEALTH SOFTWARE, L.L.C.", "STEALTH SOFTWARE, B.V.", "STEALTH SOFTWARE HOLDING B.V., "WARRENS HOLDING, B.V., and STEALTH SOFTWARE HOLDINGS S.A.R.L. are alter egos of GERARD WARRENS. 58. Plaintiff alleges that under an alter ego theory, there is no requirement of a showing of fraud, even though in the instant matter, all elements of fraud are present. 59. Plaintiff has clearly illustrated that each of the foreign business entities named herein as co-defendants are the alter ego of WARRENS because each share unity of ownership, officer, directors, management and actually operated as a single economic entity such that it would be inequitable to uphold a legal distinction between them. 60. Each of the above noted foreign entities share common ownership of all of the legal and equitable interests in each other; share the same common officer, and director; the same or similar common marketing image on the website of STEALTH SOFTWARE; the same managerial and supervisory personnel, and business structures for handling investments from outside of The Netherlands, or Luxemburg, and all investor funds were solicited totally within the state of Arizona and from Arizona

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