Party Notice: Blueberry Funding Ll C Vs Moshe Leor

On June 06, 2023 a Party Notice was filed involving a dispute between Blueberry Funding Llc, and 120 Whitesville Llc, Dov M Moshe, Hanane Moshe, Isaac Odes, Jacob Goldman, Jacob Schlisselfeld, Judy Moshe, Leor Moshe, Moshe Family Grantortrust, Shmuel Kirzner, for Contract/Commercial Transaction in the District Court of Ocean County.

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UNITED STATES DISCTRICT COURT
DISTRICT OF NEW JERSEY
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BLUEBERRY FUNDING, LLC,
Plaintiff, Civil Action No.

- against -
NOTICE OF REMOVAL
LEOR MOSHE, EMUNAH MOSHE, JUDY MOSHE,
DOV MOSHE, HANANE MOSHE, MOSHE FAMILY
GRANTOR TRUST, 120 WHITESVILLE LLC, JACOB
GOLDMAN, ISAAC ODES, SHMUEL KIRZNER,
JACOB SCHLISSELFELD, JOHN DOES 1-10
(FICTITIOUSLY NAMED), XYZ CORPORATIONS
1-10 FICTITIOUSLY NAMED),

Defendants.
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Defendant Isaac Odes (“Odes” or Defendant”) hereby removes this action to the United

States District Court, District of New Jersey pursuant to 28 USC §§ 1441 and 1446 and says:

1. On or about June 6, 2023, Plaintiff Blueberry Funding, LLC (“Plaintiff”) commenced this

civil action by filing a Complaint against Leor Moshe, 120 Whitesville LLC, John Does

1-10 (fictitiously named) and XYZ Corporations 1-10 (fictitiously named) (“Complaint”),

Docket No. OCN-L-001301-23, in the Superior Court of Ocean County (the “Superior

Court Action”). Attached hereto as Exhibit A is true and correct copy of the Complaint.

2. On or about December 20, 2023, Plaintiff filed its First Amended and Verified Complaint

against Defendants Leor Moshe, Emunah Moshe, Judy Moshe, Dov Moshe, Hanane

Moshe, Moshe Family Grantor Trust, 120 Whitesville LLC, Jacob Goldman, Isaac Odes,

Shmuel Kirzner, Jacob Schlisselfeld, John Does 1-10 (fictitiously named) and XYZ

Corporations 1-10 fictitiously named) (“Amended Complaint”). Attached hereto as

Exhibit B is true and correct copy of the Amended Complaint.

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3. A copy of the Amended Complaint was served on Defendant Odes on or about January 4,

2024.

4. Neither Defendant nor his counsel had any prior notice of the Superior Court Action or

the Amended Complaint.

5. Defendants file this Notice of Removal within thirty days of their receipt of the Amended

Complaint and within thirty days of the date on which the Superior Court Action became

removable.

6. The grounds for removal are the original jurisdiction afforded this Court under 28 USC §

1441(c) (claim arising under the Constitution, laws, or treaties of the United States, i.e.

“federal question”).

7. The Superior Court Action is a civil action over which this Court has original jurisdiction

pursuant to 28 U.S.C. § 1441(c).

8. The Superior Court Action is removable to the United States District Court pursuant to 28

U.S.C. § 1441(c), as it includes a claim arising under the Constitution, laws, or treaties of

the United States.

9. The Ninth Cause of Action included in the Amended Complaint is Civil Racketeer

Influenced and Corrupt Organization Act (“RICO”). See Exhibit B, Amended

Complaint, ¶ 171-184.

10. This cause of action arises under the laws of the United States.

11. Though not all of the causes of action included in the Amended Complaint arise under

the laws of the United States, pursuant to 28 U.S.C. § 1441(c), the entire Superior Court

Action and Amended Complaint can be removed to this Court.

12. Plaintiff’s claims are not nonremovable claims as described in 28 U.S.C. § 1445.

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13. Promptly after the filing of this Notice of Removal, Defendant Odes will file a copy of

this Notice of Removal with the Superior Court and give written notice thereof to

Plaintiffs.

Dated: New York, New York
January 10, 2019
TWERSKY PLLC

By: __________________________
Aaron Twersky, Esq.
Ilana Neufeld, Esq.
Mia Guttmann, Esq.
747 Third Avenue, 32nd Floor
New York, New York 10017
Tel: (212) 425-0149

Attorneys for Defendant Isaac Odes

To:

Clerk of the Court

Michael Roberts, Esq.
The Roberts Law Firm, LLC
33 Princeton Avenue
Brick, New Jersey 08724
Tel: (732) 813-7080

Attorneys for Plaintiff Blueberry Funding, LLC

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EXHIBIT A
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Michael Roberts Esq. ID No. 27832-2019
The Roberts Law Firm, LLC
1072 Madison Avenue, Lakewood, New Jersey 08701,
Suite D, Madison Avenue Executive Complex
(732) 813-7080
Attorney for Plaintiff, Blueberry Funding, LLC
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Blueberry Funding, LLC, Superior Court of New Jersey

Ocean County
Plaintiff, Law Division

CIVIL ACTION
-against- Docket No.

Leor Moshe, 120 Whitesville LLC, John Does 1-10

(Fictitiously named), XYZ Corporations 1-10 fictitiously named)

Defendants
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COMPLAINT
Plaintiff, Blueberry Funding LLC, (hereinafter “Plaintiff”, or “Blueberry”), by its

attorney Michael Roberts, Esq. as and for its complaint against Leor Moshe (“Defendant 1” or

“Moshe”), and the 120 Whitesville LLC, (“Defendant 2” or “Whitesville”) (collectively, the

“Defendants”), the Plaintiff herein, alleges as follows:

1. Plaintiff, Blueberry Funding LLC, is a Delaware limited liability

company, having an address at 756 Gail Chambers Road, Jackson, New Jersey 08527.

2. Upon information and belief, Defendant, Leor Moshe, is an individual

with an address at 437 Brentwood Avenue, Toms River, New Jersey 08755.

3. Upon information and belief, Defendant, 120 Whitesville LLC, a New

Jersey limited liability company, with an address at 437 Brentwood Avenue, Toms River, New

Jersey 08755.

BACKGROUND

4. On or about March 16th 2023, the Defendants executed a Promissory Note and
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other related documents (the “Agreement”) for a line credit up to Eight Million ($8,000,000.00)

Dollars.

5. Soon thereafter, Defendants received the sum of Three Million Five Hundred

Thousand ($3,500,000.00) Dollars from Plaintiff pursuant to the Agreement.

6. Thereafter, Defendants returned partial payment of One Million of

($1,000,000.00) Dollars.

7. Upon information and belief, as of todays date, Defendants have defaulted and

absconded with the remaining Two Million Five Hundred Thousand ($2,500,000.00) Dollars.

VENUE

8. Venue is Proper in Ocean County as Defendant resides in Ocean County and is

where the cause of action arose.

FIRST COUNT

9. Plaintiff incorporates by reference the allegations set forth in Paragraphs 1

through 8 as if fully set forth herein.

10. Defendants have absconded with Plaintiff’s Two Million Five Hundred

Thousand ($2,500,000.00) Dollars.

11. Defendants have fraudulently induced Plaintiff to provide Defendants not less

than Two Million Five Hundred Thousand ($2,500,000.00) Dollars with no intention of

returning said moneys.

12. Defendants have been unjustly enriched by the sum of not less than Two Million

Five Hundred Thousand ($2,500,000.00) Dollars of Plaintiff’s money, with no intention of

returning said moneys to Plaintiff.

13. Consequently, Defendants owe Plaintiff a sum in the amount of not less than Two

Million Five Hundred Thousand ($2,500,000.00) Dollars.

WHEREFORE, Plaintiff demands judgment against Defendants
jointly and severally, for;
(1) Compensatory damages;
(2) Punitive damages;
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(3) Attorney's fees;
(4) Lawful interest;
(5) Costs of suit;
(6) Payment of Two Million Five Hundred Thousand ($2,500,000.00) Dollars;
(7) For such other relief as the Court deems equitable and appropriate

Dated: June 6, 2023

The Roberts Law Firm, LLC
Attorneys for Plaintiff

By:_
Michael Roberts, Esq.
33 Princeton Avenue
Brick, New Jersey 08724
(732) 813-7080
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CERTIFICATION OF NO OTHER ACTIONS

Pursuant to NJ Court Rule 4:5-1(b)(2), it is hereby stated that the matter in controversy is not
the subject of any other action pending in any other court or of a pending arbitration proceeding to
the best of my knowledge or belief, other than the arbitration proceeding described in the Complaint.
Also, to the best of my belief, no other action or arbitration proceeding is contemplated. Further, other
than the parties set forth in this pleading, I know of no other parties that should be joined in the above
action. In addition, I recognize the continuing obligation of each party to file and serve on all parties
and the Court an amended certification if there is a change in the facts stated in this original
certification.

By:_ ________________
Michael Roberts, Esq.

CERTIFICATION OF COMPLIANCE WITH R. 1:38-7(c)

I certify that confidential identifiers have been redacted from documents now submitted to the court, and
will be redacted from all documents submitted in the future in accordance with R. 1:38-7 (b).

By:___________________
Michael Roberts, Esq.
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Civil Case Information Statement
Case Details: OCEAN | Civil Part Docket# L-001301-23

Case Caption: BLUEBERRY FUNDING LL C VS MOSHE Case Type: CONTRACT/COMMERCIAL TRANSACTION
LEOR Document Type: Complaint
Case Initiation Date: 06/06/2023 Jury Demand: NONE
Attorney Name: MICHAEL ROBERTS Is this a professional malpractice case? NO
Firm Name: THE ROBERTS LAW FIRM, LLC Related cases pending: NO
Address: 33 PRINCETON AVENUE If yes, list docket numbers:
LAKEWOOD NJ 08724 Do you anticipate adding any parties (arising out of same
Phone: 7328137080 transaction or occurrence)? NO
Name of Party: PLAINTIFF : Blueberry Funding LLC Does this case involve claims related to COVID-19? NO
Name of Defendant’s Primary Insurance Company
(if known): Unknown Are sexual abuse claims alleged by: Blueberry Funding LLC? NO

THE INFORMATION PROVIDED ON THIS FORM CANNOT BE INTRODUCED INTO EVIDENCE
CASE CHARACTERISTICS FOR PURPOSES OF DETERMINING IF CASE IS APPROPRIATE FOR MEDIATION

Do parties have a current, past, or recurrent relationship? NO
If yes, is that relationship:
Does the statute governing this case provide for payment of fees by the losing party? NO
Use this space to alert the court to any special case characteristics that may warrant individual
management or accelerated disposition:

Do you or your client need any disability accommodations? NO
If yes, please identify the requested accommodation:

Will an interpreter be needed? NO
If yes, for what language:

Please check off each applicable category: Putative Class Action? NO Title 59? NO Consumer Fraud? NO

I certify that confidential personal identifiers have been redacted from documents now submitted to the
court, and will be redacted from all documents submitted in the future in accordance with Rule 1:38-7(b)

06/06/2023 /s/ MICHAEL ROBERTS
Dated Signed
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EXHIBIT B
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Ocean County
Plaintiff, Law Division

CIVIL ACTION
-against-
Docket No. L-1301-23
Leor Moshe, Emunah Moshe, Judy Moshe, Dov Moshe,

Hanane Moshe, Moshe Family Grantor Trust,

120 Whitesville LLC, Jacob Goldman,

Isaac Odes, Shmuel Kirzner, Jacob Schlisselfeld

John Does 1-10 (Fictitiously named), XYZ

Corporations 1-10 fictitiously named)

Defendants
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First Amended and Verified Complaint
Plaintiff, Blueberry Funding LLC, (hereinafter “Plaintiff”, or “Blueberry”), by its

attorney Michael Roberts, Esq. as and for its complaint against Leor Moshe (Leor Moshe”),

Emunah Moshe (“Mrs. Moshe”), Judy Moshe (“Judy”), Dov Moshe (“Dov”), Hanane Moshe

(“Hanane”), Moshe Family Grantor Trust (“Trust”) , Jacob Goldman (“Goldman”), Isaac Odes

(“Odes”), Jacob Schlisselfeld (“Schlisselfeld”), and 120 Whitesville LLC, (“Whitesville”)

(collectively, the “Defendants”), the Plaintiff herein, alleges as follows:

1. Plaintiff, Blueberry Funding LLC, is a Delaware limited liability

company, having an address at 756 Gail Chambers Road, Jackson, New Jersey 08527.

2. Upon information and belief, Defendant, Leor Moshe, is an individual

with an address at 437 Brentwood Avenue, Toms River, New Jersey 08755.
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3. Upon information and belief, Defendant, Emuna Moshe, is an individual

with an address at 437 Brentwood Avenue, Toms River, New Jersey 08755.

4. Upon information and belief, Defendant, Judy Moshe, an individual with

an address at 20 Lundi Court, Staten Island, New York 10314.

5. Upon information and belief, Defendant, Dov Moshe, is an individual

with an address at 20 Lundi Court, Staten Island, New York 10314.

6. Upon information and belief, Defendant, Moshe Family Grantor Trust, is

an entity with an address at 20 Lundi Court, Staten Island, New York 10314.

7. Upon information and belief, Defendant, Hanane Moshe, is an individual

with an address in Denver Colorado.

8. Upon information and belief, Defendant, Jacob Goldman, is an

individual with an address at 378 Brentwood Avenue, Toms River, New Jersey 08755.

9. Upon information and belief, Defendant, Isaac Odes, is an individual

with an address at 229 Benjamin Avenue, Toms River, New Jersey 08755.

10. Upon information and belief, Defendant, Jacob Schlisselfeld is an

individual with an address within the tristate area.

11. Upon information and belief, Shmuel Kirzner is an individual with an

address at within the tristate area.

12. Upon information and belief, Defendant, 120 Whitesville LLC, a New

Jersey limited liability company, with an address at 437 Brentwood Avenue, Toms River, New

Jersey 08755.

BACKGROUND

13. On or about March 16th 2023, the Defendant, 120 Whitesville LLC in conjunction

with Leor Moshe executed an Investment Agreement (“Shtar Iska”), Promissory Note and other

related documents (collectively, the “Investment”) finalizing an investment and loan of Two
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Million ($2,000,000.00) Dollars.

14. Leor Moshe personally guaranteed the two million Dollar Investment.

15. While this was structured as a loan, in reality, this was an investment with loan

documents securing the investment. See Shtar Iska at Exhibit A.

16. For the Investment and based upon the false and fraudulent representations and

information provided by Leor Moshe, as described hereunder, at the direction of Leor Moshe,

Blueberry caused the sum of Two Million ($2,000,000.00) Dollars to be wired Capital Funding

ASAP LLC to the account ending at 7004.

17. Leor Moshe provided false verifications, representations and information to

Plaintiff in order to secure the Investment.

18. As an inducement for Plaintiff to make the above Investment, Leor Moshe

provided an apparently falsified and altered bank statement (the “Bank Statement”) with the

name Iruka Funding, LLC (“Iruka”) to demonstrate Leor Moshe’s financial soundness and

business dealings and investments that Leor Moshe had by Iruka. See attached at Exhibit B.

19. The Bank Statement was apparently altered to provide the address of 162 Elmora

Ave #211 Ellizabeth, NJ 07202.

20. Apparently, the correct address for Iruka Funding, LLC is 437 Brentwood

Avenue, Toms River NJ, Leor Moshe’s personal address.

21. Mr. Moshe instead provided the Plaintiff a Bank Statement with an altered

address of 162 Elmora Ave #211 Ellizabeth, NJ 07202 which is the address of Iruka Capital

Group, a supposed reputable cash advance business, not Iruka Funding LLC.

22. While reviewing the Investment, Mr. Moshe and Plaintiff had several discussions

about Mr. Moshe having investments with Iruka Capital Group.

23. During those discussions Mr. Moshe represented to Plaintiff multiple times that

he and his interests had $25,000,000.00 in investments at Iruka Capital Group.

24. Mr. Moshe used the Iruka name and apparently falsified address of Iruka Capital
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Group on the Bank Statement to fraudulently demonstrate approximately $25,000,000.00 being

deposited with Iruka as proof of business investments being made by Mr. Moshe or on his behalf

at Iruka.

25. In apparent furtherance of the fraud, Mr. Moshe also provided Plaintiff a letter

(the “Iruka Letter”) with the Iruka Capital Group letterhead and Mark Neuman’s name in the

signature line stating that Capital Funding ASAP had an accounts receivable balance of

$21,545,000.00 that was invested in cash advance deals. See Exhibit C.

26. On March 1, 2022, Plaintiff asked Mr. Moshe, “Do you have a list of investors

that were paid out in the past few months so we can match back the investor payouts?”

27. As additional inducement for Plaintiff to make the Investment to Mr. Moshe, Mr.

Moshe provided a list of investors investing with him in the sum of approximately Twenty-

Three Million Five Hundred Thousand ($23,500,000.00) Dollars. See attached investor list (the

“List”) at Exhibit D.

28. Additionally, Leor Moshe responded, “Yes - there is approximately $25-$30

million invested. That being said, there are 2 things I would like to see to confirm – 1) Asset

balances that total approx $25 mil give or take. 2) The minimum investor return is 30% - and

the money being lent out is approx. 100% APR -so we would expect returns on $25 million in

the $8 mil - $15 mil range in Iruka - if there is no money withdrawn from Iruka.”

29. Leor Moshe additionally represented, “With regards to investor paid back….

once they are paid back they get taken off the list. Below are some names of investors that gave

and money was returned. Most of the investors have not taken back money as they are extremely

happy.”

30. Leor Moshe also provided TD Bank statements (the “TD Bank Statement”) to

Plaintiff. See the TD Bank Statements attached at Exhibit E.

31. Upon current review of the TD Bank Statements, at the time Leor Moshe was

defrauding Plaintiff and took millions of dollars from Plaintiff, Leor Moshe, was also apparently
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actively engaged in a Ponzi scheme stealing millions of dollars from multiple parties while using

fresh capital investment monies from new investments to provide returns on old investments.

See TD Bank Statements at Exhibit E and Goldstien Affidavit at Exhibit F.

32. By way of example, in January 2023, Leor Moshe apparently paid out

approximately Six Million, Six Hundred Forty Thousand, Seven Hundred Eight-Four Dollars

($6,640,748.00) to investors. See TD Bank Statements at Exhibit E.

33. However, apparently the income Leor Moshe used to pay these investors was

from the Six Million, Five Hundred Sixty Thousand, One Hundred Twenty ($6,560, 120.00)

Dollars of new investors money coming in. See TD Bank Statements at Exhibit E.

34. Simply put, Leor Moshe was apparently using new investor money to pay old

investor money.

35. Leor Moshe used these records of the apparently fraudulent funds obtained

through the ponzi scheme to trick and induce Plaintiff to make the Investment by using such

funds to demonstrate apparently false financial stability and to induce Plaintiff to Invest millions

of dollars with the Investment Defendants (hereinafter defined).

36. Additionally, apparently numerous parties benefitted from the monies stolen by

Leor Moshe.

37. Leor Moshe has been living at 437 Brentwood Avenue, Jackson, New Jersey

08527 (the “Property”) for the last five years.

38. The Property is owned by the Moshe Family Grantor Trust, which is controlled

by Leor Moshe and other family insiders.

39. The Moshe Family Grantor Trust is an alter ego for Leor Moshe as he represented

to Abraham Miller that the Trust is controlled by him and other family insiders.

40. The Moshe Family Grantor Trusts’ address is listed at 20 Lundi Court, Staten

Island, NY 10314 the same address as Leor Moshe’s parents’ home.

41. Further, while living at the Property over the past several years, apparently Leor
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Moshe renovated the Property at significant cost.

42. Upon information and belief, Emuna Moshe, Leor Moshe’s wife, was a co-

conspirator as Leor Moshe represented to Abraham Miller that Leor Moshe’s wife, Emuna

Moshe, works together with him; additionally, she benefitted tremendously from the significant

monies Leor Moshe spent to her benefit.

43. Upon information and belief, Leor Moshe’s relatives, Dov Moshe, Judy Moshe

and Hanane Moshe, were all co-conspirators who actively participated, benefitted, and had

knowledge of, Leor’s Moshe’s fraudulent actions and ponzi scheme, and benefitted from monies

that Leor Moshe provided them.

44. By way of example, per the TD Bank Statements, Leor Moshe paid his father,

Dov Moshe, not less than One Hundred Fifty-Two Thousand Three Hundred Twenty-Five

($152, 325.00) Dollars.

45. Upon information and belief, Leor Moshe used his relatives, Dov Moshe, Judy

Moshe and Hanane Moshe, to create cover entities and the like to hide the stolen moneys Leor

Moshe obtained.

46. Upon information and belief, Leor Moshe’s relatives benefitted from the stolen

moneys hidden by them and given to their control.

47. Upon information and belief, the monies stolen by Leor Moshe through the ponzi

scheme and fraudulent business activities were comingled in other accounts as well.

48. Indeed, Leor Moshe together with Emunah Moshe, Jacob Goldman, Isaac Odes,

Shmuel Kirzner, and Jacob Schlisselfeld (the “Enterprise”) conducted an enterprise designed to

perpetrate an ongoing and continuous ponzi scheme on numerous victims including Blueberry

Funding LLC over the course of the last few years. See TD Bank Statements at Exhibit E,

Goldstien Affidavit at Exhibit F.

49. Leor Moshe in collusion with the Brokers (as defined hereunder) solicited

victims for investments that were not actual legitimate investments but was rather a ponzi
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scheme. See TD Bank Statements at Exhibit E, Goldstien Affidavit at Exhibit F.

50. During early 2023, Mr. Moshe, as a principal of the Enterprise, fraudulently

induced Blueberry Funding LLC to invest and wire millions of dollars to a bank account

controlled by Leor Moshe which monies were then stolen in the ponzi scheme.

51. During mid-2021, Mr. Moshe in collusion with Isaac Odes, as principals of the

Enterprise, fraudulently induced Creg Goldstien to invest and wire hundreds of thousands of

dollars to a bank account controlled by Leor Moshe which monies were then stolen in the ponzi

scheme. See Goldstien Affidavit at Exhibit F.

52. Upon information and belief, Jacob Goldman, Isaac Odes, Shmuel Kirzner, Jacob

Shliselfeld, and other “brokers” (the “Brokers”), as principals of the Enterprise, aided and

abetted Leor Moshe in this enterprise and the ponzi scheme by actively marketing Leor Moshe

as an investment opportunity and receiving commissions for such marketing. See email at

Exhibit G.

53. Jacob Goldman received at least $3,047,365.00 in payouts per the TD bank

Statements.

54. Additionally, in March 2023, Jacob Goldman apparently received outgoing wires

for $64,999, $49,038 and a check for $826,261. See email at Exhibit G.

55. Apparently, Jacob Shlisselfeld received from Leor Moshe quarterly commissions

of $205,250. See email at Exhibit G.

56. Apparently, Isaac Odes received from Leor Moshe quarterly commissions of

$213,625. See email at Exhibit G.

57. Apparently, Jacob Goldman received from Leor Moshe quarterly commissions

of nearly $1,000,000.00 plus additional monthly payments. See email at Exhibit G.

58. Upon information and belief, the monies fraudulently obtained by Leor Moshe

from Plaintiff were, at least in part, used and given to the Brokers as payment for their activities

in the ponzi scheme. See TD Bank Documents and email at Exhibits E and G respectively.
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59. The Brokers received millions of dollars as payments for actively participating

in the ponzi scheme and fraudulent business activities. See TD Bank Documents and email at

Exhibits E and G respectively.

60. By way of another example, apparently Leor Moshe has a gambling habit and

addiction and has wasted tremendous amounts of stolen money on gambling and similar

pursuits. See TD Bank Statements at Exhibit E.

61. Additionally, Leor Moshe used the stolen monies obtained through the Enterprise

and ponzi scheme to fund an extravagant and luxurious lifestyle over the last couple of years.

62. By way of example, upon information and belief, Mr. Moshe, during April of

2023, took Emunah Moshe and his family to the Galapagos Islands for the week of Passover for

an approximate Eighty-Five Thousand ($85,000.00) Dollar vacation.

63. Additionally, Leor Moshe threw multiple lavish parties at his house costing

upwards of $100,000.00 each.

64. Also, upon information and belief, Leor Moshe has a severe gambling habit and

supported this habit by gambling millions of dollars over the last couple of years.

65. Further, Leor Moshe has represented to Abe Miller, President of Blueberry

Funding that he does not have and does not intend to pay back Plaintiff the moneys Leor Moshe

fraudulently received from the Blueberry Investment.

66. Upon information and belief, as of today’s date, Defendants, Leor Moshe and

120 Whitesville LLC (the “Investment Defendant”) have defaulted, misappropriated, and

absconded with Two Million ($2,000,000.00) Dollars of Plaintiff’s money.

VENUE

67. Venue is Proper in Ocean County as Defendant Leor Moshe resides in Ocean

County and is where the cause of action arose.

FIRST COUNT (conversion)

68. Plaintiff incorporates by reference the allegations set forth in Paragraphs 1
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through 67 as if fully set forth herein.

69. Defendants, Leor Moshe, and 120 Whitesville LLC (“Investment Defendants”)

received a total Two Million ($2,000,000.00) Dollars from Plaintiff. Leor Moshe provided

multiple false verifications and information to Plaintiff in order to secure the Investment.

70. As an inducement for Plaintiff to make the above Investment, Leor Moshe

fraudulently provided falsified bank statements to Plaintiff from Iruka Funding LLC showing

millions of dollars passing through the Iruka bank account.

71. Additionally, Defendant, Leor Moshe, provided a false letter from Iruka Capital

Group demonstrating false investments being made by Leor Moshe with Iruka Capital Group.

72. As additional inducement for Plaintiff to make the Investment to Leor Moshe,

Leor Moshe provided a list of investors providing money toward investments with him in the

sum of approximately Twenty-Three Million Five Hundred Thousand ($23,500,000.00) Dollars.

73. Upon information and belief, the list of investors provided by Leor Moshe to

Plaintiff as fraudulent inducement to obtain the Investment from Plaintiff was a partial list of

investors which Leor Moshe, as a Principal of the Enterprise, engaged in the Ponzi scheme with

to defraud them and Plaintiff out of those millions of dollars.

74. Upon information and belief, Leor Moshe’s relatives along with the Brokers, as

detailed above, have received and benefitted from the stolen moneys.

75. Defendants have absconded with Plaintiff’s Two Million ($2,000,000.00)

Dollars.

76. Consequently, Defendants owe Plaintiff a sum in the amount of not less than Two

Million ($2,000,000.00) Dollars.

WHEREFORE, Plaintiff demands judgment against Defendants
jointly and severally, for;
(1) Compensatory damages;
(2) Punitive damages;
(3) Attorney's fees;
(4) Lawful interest;
(5) Costs of suit;
(6) Payment of Two Million ($2,000,000.00) Dollars;
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(7) For such other relief as the Court deems equitable and appropriate

SECOND COUNT (Unjust Enrichment)

77. Plaintiff incorporates by reference the allegations set forth in Paragraphs 1

through 76 as if fully set forth herein.

78. Defendants, Leor Moshe, and 120 Whitesville LLC received a total Two Million

($2,000,000.00) Dollars from Plaintiff.

79. Leor Moshe provided multiple false verifications and information to Plaintiff in

order to secure the Investment.

80. As an inducement for Plaintiff to make the above Investment, Leor Moshe

fraudulently provided falsified bank statements to Plaintiff from Iruka Funding LLC showing

millions of dollars passing through the Iruka bank account.

81. Additionally, Defendant, Leor Moshe provided a false letter from Iruka Capital

Group demonstrating false investments being made by Leor Moshe with Iruka Capital Group.

82. As additional inducement for Plaintiff to make the Investment to Leor Moshe,

Leor Moshe provided a list of investors providing money toward investments with him in the

sum of approximately Twenty-Three Million Five Hundred Thousand ($23,500,000.00) Dollars.

83. Upon information and belief, the list of investors provided by Leor Moshe to

Plaintiff as fraudulent inducement to obtain the Investment from Plaintiff was a partial list of

investors which Leor Moshe engaged in the Ponzi scheme with to defraud them out of those

millions of dollars.

84. Upon information and belief, Leor Moshe’s relatives along with the Brokers, as

detailed above, have received and benefitted from the stolen moneys.

85. Defendants have absconded and been unjustly enriched with Plaintiff’s two

million ($2,000,000.00) dollars.

86. Consequently, Defendants, as applicable, were unjustly enriched and owe

Plaintiff a sum in the amount of not less than two million ($2,000,000.00) dollars.
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WHEREFORE, Plaintiff demands judgment against Defendants
jointly and severally, for;
(1) Compensatory damages;
(2) Punitive damages;
(3) Attorney's fees;
(4) Lawful interest;
(5) Costs of suit;
(6) Payment of Two Million ($2,000,000.00) Dollars;
(7) For such other relief as the Court deems equitable and appropriate

THIRD COUNT (Legal Fraud)

87. Plaintiff incorporates by reference the allegations set forth in Paragraphs 1

through 86 as if fully set forth herein.

88. Defendants, Leor Moshe, and 120 Whitesville LLC received a total Two Million

($2,000,000.00) Dollars from Plaintiff.

89. Leor Moshe provided multiple false verifications and information to Plaintiff in

order to secure the Investment.

90. As an inducement for Plaintiff to make the above Investment, Leor Moshe

fraudulently provided falsified bank statements to Plaintiff from Iruka Funding LLC showing

millions of dollars passing through the Iruka bank account.

91. Additionally, Defendant, Leor Moshe provided a false letter from Iruka Capital

Group demonstrating false investments being made by Leor Moshe with Iruka Capital Group.

92. As additional inducement for Plaintiff to make the Investment to the Investment

Defendants, Leor Moshe provided a list of investors providing money toward investments with

him in the sum of approximately Twenty-Three Million Five Hundred Thousand

($23,500,000.00) Dollars.

93. Upon information and belief, the list of investors provided to Plaintiff as

fraudulent inducement to obtain the Investment was a partial list of investors which Leor Moshe

engaged in the Ponzi scheme with intent to defraud them out of those millions of dollars.

94. Upon information and belief, Leor Moshe’s relatives along with the Brokers, as

detailed above, have received and benefitted from the stolen moneys.
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95. Defendants have absconded and been unjustly enriched with Plaintiff’s Two

Million ($2,000,000.00) Dollars.

96. The Investment Defendants falsely represented to Plaintiff that Defendants were

financially stable and knowingly produced false documents demonstrating the same.

97. The Investment Defendants knew this was a false representation as they were

engaged in a Ponzi scheme at the time.

98. The Investment Defendants intended and knew that Plaintiff would rely upon the

representations made to them to give Defendants the Millions of Dollars as an investment.

99. Plaintiff reasonably relied upon Investment Defendants’ statements and

information provided, and the Investment Defendant used such statements and information to

fraudulently obtain the Investment of not less than Two Million ($2,000,000.00) Dollars.

100. Consequently, in reliance upon Investment Defendants’ fraudulent statements,

Plaintiff was damaged in the amount of not less than not less than Two Million ($2,000,000.00)

Dollars.

WHEREFORE, Plaintiff demands judgment against Defendants
jointly and severally, for;
(1) Compensatory damages;
(2) Punitive damages;
(3) Trebled damages;
(4) Attorney's fees;
(5) Lawful interest;
(6) Costs of suit;
(7) Paymen

Case Info

Judge

Valter H Must Track Judge’s New Case

Case No.

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Document Filed Date

February 05, 2024

Case Filing Date

June 06, 2023

County

Parties

120 Whitesville Llc Defendant
Blueberry Funding Llc Plaintiff
Dov M Moshe Defendant
Hanane Moshe Defendant
Isaac Odes Defendant
Jacob Goldman Defendant
Jacob Schlisselfeld Defendant
Judy Moshe Defendant
Leor Moshe Defendant
Megan J Muoio Attorney for the Defendant
Michael Roberts Attorney for the Plaintiff
Moshe Family Grantortrust Defendant
Shmuel Kirzner Defendant

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