Goldie Dickey

Goldie Dickey fraudstress exposed -

Goldie Vicencio Santiago, 28, Redlands, California was sentenced to state prison resulting from felony charges connected to real estate fraud. Santiago appeared in San Bernardino County, Central District, Superior Court Friday, February 8, 2008, and was sentenced, as part of a plea agreement, to sixteen months in state prison for filing a false deed and forgery. The issue of $225,000 in restitution has been reserved for an upcoming hearing.

In May and June 2006, Santiago forged the victim’s name on Quitclaim deeds. She then took out loans against at least two separate parcels of property in the County of San Bernardino, California for approximately $752,000, without the victim’s knowledge. The residential properties were located in the cities of Hesperia and Colton.

On August 11, 2006, Investigators from the San Bernardino County District Attorney’s Real Estate Fraud Unit arrested Santiago at her business located in San Bernardino.

On her web http://goldiesantiago.info/ she says”

“Goldie Santiago established Direct Mortgage Lenders, LLC in California in 2003. As a Broker, Goldie Santiago managed every aspect of the business. With 18 loan officers and a support staff of four, owner Goldie Santiago directed 20 to 50 real estate or loan transactions monthly. Goldie Santiago facilitated conventional credit and real estate dealings, exhibiting exceptional proficiency in the A&D of larger projects with private funding.

Between 2003 and 2007, Goldie Santiago was involved with eight rehabilitative construction projects. Goldie Santiago directed the rehabilitation of single-family homes, as well as two-, three-, and four-unit complexes ranging in price from $100,000 to $765,000.

From 2003 to 2004, Goldie Santiago also supervised the development of a large gated community. By subdividing a 160-acre swathe of ranch land and creating a basic infrastructure, Goldie Santiago converted the property into 14 10-acre parcels. Each has sold for between $325,000 and $425,000.

Goldie Santiago also founded Payday Central in 2003. As de facto business manager, compliance officer, debt collector, accountant, and HR administrator, Goldie Santiago effectively managed check cashing and payday advance requirements for clients at two Redding, California, locations. In addition to screening the Western Union and Moneygram exchanges against IRS protocol, Goldie Santiago maintained services for 600 clients daily.

Goldie Santiago secured undergraduate degrees in banking and finance, as well as accounting, from the University of Santo Tomas in the Philippines, graduating cum laude in 2000. Goldie Santiago subsequently immigrated to the United States and began working for Goliath Financial and Management. Dedicated to charitable endeavors, Goldie Santiago is involved with the March of Dimes, Salvation Army, Army Wives Group, and Goodwill. Goldie Santiago has also been a member of the Chamber of Commerce in Santa Clara, California.”

Domain Name: GOLDIESANTIAGO.INFO
Created On:29-Sep-2010 00:52:29 UTC
Last Updated On:25-Feb-2011 01:09:45 UTC
Expiration Date:29-Sep-2011 00:52:29 UTC
Sponsoring Registrar:Melbourne IT Ltd. (R141-LRMS)
Status:OK
Registrant ID:C12985960700459
Registrant Name:-
Registrant Organization:Private Registration AU
Registrant Street1:P O Box 59
Registrant Street2:Collins Street West
Registrant Street3:
Registrant City:Melbourne
Registrant State/Province:VIC
Registrant Postal Code:3000
Registrant Country:AU
Registrant Phone:+61.386242485

 

She also uses Goldie Dickey <goldie@metrobancorp.net>

Goldie Dickey

Metropolitan Bancorp Ltd.

Level 20, ASB Bank Centre

135 Albert Street

Auckland, New Zealand 1010

Phone: +649 359 7449 Fax: +649 359 7459

 

United States Contact information

California Branch:

2005 De La Cruz Blvd. Suite 180

Santa Clara, California 95050

Office 408-748-1832

Efax 408-904-7595

Mobile 951-990-9509

 

Oklahoma Branch:

502 NW Sheridan Road Suite 6A

Lawton, Oklahoma 73505

Office: 580-355-5800

Fax: 580-355-0433

Mobile: 951-990-9509

Email: goldie@metrobancorp.net

Website: www.metrobancorp.net

Metropolitan Bank

Domain name: metrobancorp.net redirects to the following website: metrofinancialholdings.com

SAMPLE CASE of scammers scamming and suing scammers

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

FORM 8-K

Pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934

Date of Report (Date of earliest event reported): April 27, 2011

ENVIRONMENTAL SERVICE PROFESSIONALS, INC.
(Exact name of registrant as specified in its charter)
NEVADA (State or other jurisdiction of incorporation) 1-14244 84-1214736

(Commission File Number) (I.R.S. Employer Identification No.)
810 N. FERRELL DRIVE, PALM SPRINGS, CALIFORNIA 92262

(Address of principal executive offices) (Zip Code)
(760) 327-5284

(Registrant’s telephone number, including area code)

(Former name, former address and former fiscal year, if changed since last report)

Check the appropriate box below if the Form 8-K filing is intended to simultaneously satisfy the filing obligation of the registrant under any of the following provisions.

[_] Written communications pursuant to Rule 425 under the Securities Act (17

     CFR240.14d-2(b))

[_]  Soliciting  material  pursuant  to  Rule  14a-12  under  Exchange  Act  (17
     CFR240.14a-12)

[_]  Pre-commencement   communications  pursuant  to  Rule  14d-2(b)  under  the
     Exchange Act (17 CFR240.14d-2(b))

[_]  Pre-commencement   communications  pursuant  to  Rule  13e-4(c)  under  the
     Exchange Act (17 CFR240.13e-4(c))

TABLE OF CONTENTS

SECTION 1.   REGISTRANT'S BUSINESS AND OPERATIONS..............................1

SECTION 2.   FINANCIAL INFORMATION.............................................1

SECTION 3.   SECURITIES AND TRADING MARKETS....................................1

SECTION 4.   MATTERS RELATING TO ACCOUNTANTS AND FINANCIAL STATEMENTS..........1

SECTION 5.   CORPORATE GOVERNANCE AND MANAGEMENT...............................1

SECTION 6.   [RESERVED]........................................................1

SECTION 7.   REGULATION FD.....................................................1

SECTION 8.   OTHER EVENTS......................................................1

SECTION 9.   FINANCIAL STATEMENTS AND EXHIBITS ................................2

SIGNATURES.....................................................................2

SECTION 1. REGISTRANT’S BUSINESS AND OPERATIONS

Not Applicable.

SECTION 2. FINANCIAL INFORMATION Not Applicable

SECTION 3. SECURITIES AND TRADING MARKETS Not Applicable.

SECTION 4. MATTERS RELATED TO ACCOUNTANTS AND FINANCIAL STATEMENTS

Not Applicable.

SECTION 5. CORPORATE GOVERNANCE AND MANAGEMENT

Not Applicable.

SECTION 6. [RESERVED]

SECTION 7. REGULATION FD DISCLOSURE

Not Applicable.

SECTION 8. OTHER EVENTS

Environmental Service Professionals, Inc., A Nevada corporation (The “Company”), announced today that it, along with two other plaintiffs, had filed a lawsuit in the Circuit Court of Cook County, Illinois on March 14, 2011 against Hayman Private Equity, LLC. and its affiliates for breach of contract and fraud relating to a financing promised by Hayman Private Equity, LLC to the Company as previously disclosed in filings by the Company on Form 8-K with the Securities and Exchange Commission on July 30, 2010. See exhibit 99.1 to this report.

-1-

SECTION 9. FINANCIAL STATEMENTS, PRO FORMA FINANCIALS & EXHIBITS

(a) Financial Statements of Business Acquired

Not Applicable.

(b) Pro Forma Financial Information

Not Applicable.

(c) Shell Company Transactions

Not Applicable.

(d) Exhibits

99.1 Complaint by the Company and other Plaintiffs against Hayman Private Equity, LLC and Affiliated Defendants.

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, the registrant has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

ENVIRONMENTAL SERVICE PROFESSIONALS, INC.
(Registrant)

 

Date: April 27, 2011

                              /s/ Edward L. Torres
             -------------------------------------------------------
                    Edward L. Torres, Chief Executive Officer
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Exhibit 99.1

IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS
COUNTY DEPARTMENT, CHANCERY DIVISION

XXXXXXXXXXXXXXXX,                                    )
ESP, INC.,                                           )
XXXXXXXXXXXXXXXXX                                    )
                                                     )
                                    PLAINTIFFS,      )
                                                     )
V.                                                   )   NO.:     ______________
                                                     )
ROLAND HUSNER,                                       )
ROLAND FRANK BLEYER,                                 )   CALENDAR:______________
ANDREW BACIK,                                        )
CHRISTOPHER M. DIETERICH,                            )
ROBERT MASUD, MASUD & CO.,                           )
                                                     )
AND                                                  )
                                                     )
HAYMAN PRIVATE EQUITY, LLC,                          )
URBAN HAYMAN HOLDINGS, LLC,                          )
URBAN HAYMAN JV, LLC.                                )
                                                     )
                                    DEFENDANTS.      )
                                                     )
AND                                                  )
                                                     )
ROSS GLICKMAN, JAMES NAPOLI AND                      )
KENNETH BARRY,                                       )
                                                     )

RESPONDENTS-IN-DISCOVERY )

COMPLAINT IN CHANCERY FOR EQUITY
AND AT LAW FOR MONEY DAMAGES

NOW COME Plaintiffs, XXXXXXXXXXXX, ESP, INC., XXXXXXXXXXXXXXX, by

Grasso Bass, PC and for Plaintiffs’ complaint against Defendants ROLAND HUSNER

a/k/a ROLAND FRANK BLEYER, ANDREW BACIK, CHRISTOPHER M. DIETERICH, ROBERT MASUD,

-1-

MASUD & COMPANY, P.C., and HAYMAN PRIVATE EQUITY, LLC, URBAN HAYMAN HOLDINGS,

LLC., URBAN HAYMAN JV, LLC., and state:

PARTIES

1. Plaintiff XXXXXXXXXXX (“XXXX”) is located in XXXXXXXX, XXXX and is a

XXXXXXXXXXXXXXX.

2. Plaintiff ESP, Inc. (“ESP”) is located in Palm Springs, California

and its principle business is hiring US military veterans to conduct

environmental inspections of residential and commercial properties.

3. Plaintiff XXXXXXXXXXXXXXXX (“XXX”) is located in XXXXXX, XXXXX and

XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX.

4. Defendant Roland Husner a/k/a Roland Frank Bleyer (“Husner”) resides

in Australia and is the chairman of the finance committee and the controlling

principal of Hayman Private Equities, LLC and its affiliates (“Hayman”). Husner

transacts business in Cook County, Illinois through Hayman, and upon information

and belief, the Urban Hayman defendants.

5. Defendant Andrew Bacik (“Bacik”) resides in Ohio and is the

President of Hayman and an owner of the company. Bacik transacts business in

Cook County, Illinois through Hayman, and upon information and belief, the Urban

Hayman defendants.

6. Defendant Christopher M. Dieterich (“Dieterich”) resides in

California and is the Secretary/Treasurer of Hayman and an owner of the Hayman.

Dieterich transacts business in Cook County, Illinois through Hayman, and upon

information and belief, the Urban Hayman defendants.

7. Defendants Robert Masud and Masud & Company, PC (collectively

“Masud”) reside in and operate their law practice and financial businesses in

Boston, Massachusetts and out of that office also serve as the principal,

captive attorneys, agents and representatives for Hayman and Roland Husner in

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the United States in collaboration with Dieterich. Masud transacts business in

Cook County, Illinois through or on behalf of Hayman, and upon information and

belief, the Urban Hayman defendants. Upon information and belief, Masud was

fully familiar with and facilitated Hayman’s acts and omissions herein.

8. Defendant Hayman Private Equity, LLC (“Hayman”) is a Delaware

limited liability company with its principal place of business at 225 Franklin

Street, 26th Floor, Boston, MA 02110 (with Masud) and represented itself to the

public and plaintiffs as an international financial lending company. Hayman

transacts business in Cook County, Illinois through, INTER ALIA, Hayman now and

throughout the pertinent times herein through extensive and continuing actions

described herein by Husner, Masud, Bacik and Dieterich.

9. Defendant Urban Hayman Holdings, LLC, (“UHH”) upon information and

belief, is a limited liability company formed, INTER ALIA, to assume Hayman’s

business dealings with Plaintiffs and others similarly situated. UHH purports to

be a company that combines a substantial source of private funds and real estate

specialists with a proven track record that is looking for suitable projects and

active development partners. As in the case of Hayman’s solicitation of each of

the Plaintiffs, UHH claims on its web-site1 to be a “… force in real estate,

created to help projects proceed in a world where traditional sources of bank

financing are restricted.” UHH is based in and operates from Chicago, Illinois.

10. Defendant Urban Hayman, JV, LLC (“UHJV”) upon information and

belief, is a limited liability company with intertwined ownership and management

shared with UHH. UHJV too is based in and operates from Chicago, Illinois.

-3-

RESPONDENTS-IN-DISCOVERY

11. Ross Glickman is a principal of UHH and UHJV, and upon information

and belief has personal knowledge during all pertinent times of Hayman, its

principals, its funding sources and operations, and its use of SBLCs as forth

herein.

12. Kenneth Barry (“Barry”) resides in Texas and, upon information and

belief, is an owner and principal of Hayman. Barry transacts business in Cook

County, Illinois through, INTER ALIA, Hayman, and upon information and belief,

the Urban Hayman defendants.

13. James Napoli (“Napoli”) resides in Arizona and, upon information

and belief, is an owner and principal of Hayman. Napoli transacts business in

Cook County, Illinois through, INTER ALIA, Hayman, and upon information and

belief, the Urban Hayman defendants where he is also a named principal.

********

14. Estrategia Investimentos (“Estrategia”) is a Rio de Janiero, Brazil

based bank and financial institution with offices in Miami, Florida that INTER

ALIA, provides financial instruments known as Stand-By Letters of Credit

(“SBLCs”) for monetization at a loan to value less than their face amount to

fund businesses such as Plaintiffs. At all material times, Dr. Sindhu Ratna K

Baskar (“Dr. Ratna”) was the Director of Operations and Compliance for

Estrategia. Dr. Ratna provided the SBLCs at issue herein for Estrategia upon the

approval of Hayman, Husner and Bacik.

15. Metropolitan Financial Corporation (“Metropolitan”) is based in

Lawton, Oklahoma and is a financial broker of SBLCs with relationships at all

pertinent times with Hayman and its principals, and Estrategia and Dr. Ratna.

Metropolitan’s principals at all pertinent times were Allen and Goldie Dickie.

16. Richard Weisman at all pertinent times resides and conducts

business as a broker or agent of Hayman from Las Vegas, Nevada and throughout

the events described herein called, contacted and emailed the principals of

Riverside in Cook County, Illinois for the benefit and business of Hayman,

Husner, Bacik, Dietrich and Masud.


1 www.urbanhayman.com
-4-

PERTINENT FACTS

17. In and about July 28 and 29, 2010, Hayman, Husner and Bacik

solicited each of the Plaintiffs through various promotional representations of

Hayman’s international ability to monetize collateral backed SBLCs. Hayman,

Husner and Bacik also informed plaintiffs that they had relations with various

banks and brokers that could provide SBLCs for a fee to Plaintiff which Hayman

would then quickly monetize for a substantial monetization and related trading

fees that would be paid to Hayman.

18. Within days thereafter, through relationships with Metropolitan and

Estrategia, Plaintiffs and Hayman, together and collectively, made arrangements

through Metropolitan and Estrategia to provide Hayman with four (4) SBLCs

totaling $1.5 billion. Metropolitan brokered the transaction and Estrategia

provided the customary collateral totaling $1.5 billion for the SBLCs.

19. Material to the transaction, Hayman knew and insisted that the

Plaintiffs would each have to pay advanced fees totaling $1.35 million for these

4 SBLCs based upon Hayman’s prior approval and execution of a collateral

agreement between Hayman, Metropolitan and Estrategia.

20. Throughout their dealings, Hayman told Plaintiffs that Hayman had

extensive actual experience in monetizing SBLCs. Hayman insisted Plaintiffs pay

all these fees as a pre-condition to Hayman agreeing to monetize the SBLCs and

provide funding to each of the Plaintiffs.

-5-

21. If Plaintiffs paid the fees, and provided the collateral backed

SBLCs, Hayman agreed and promised to each of the Plaintiffs that Hayman would

promptly monetize each of these SBLCs and provide funding to XXXX, ESP and XXXXX

for each of their respective business operations in the following amounts:

XXXX:             $900 million
XXXX:             $200 million
ESP:              $200 million
XXXX:             $200 million
                --------------
TOTAL:          $1,500 BILLION

22. Hayman was well aware that time was of the essence for funding of

XXXX, ESP and XXXXXX and, in fact, used the timing pressure to urge Plaintiffs

to pay the fees and cause Estrategia to issue the SBLCs to Hayman. Hayman

further assured Plaintiffs that Hayman’s international banking relations and

ease in monetizing such instruments was a primary reason for Plaintiffs to do

business with Hayman and provide Hayman with these SBLCs.

23. Plaintiffs paid the following fees to cause these SBLCs to be issued to Hayman:

XXXX:          $850,000
ESP:           $250,000
XXXX:          $250,000
             ----------

TOTAL FEES: $1,350,000

24. Plaintiffs caused each of these SBLCs to be issued to Hayman

through what is known as MT 760 bank-to-bank SWIFTs totaling $1.5 billion in

collateral from Estrategia. Three of the SBLCs were each in the face amount of

$200 million (totaling $600 million), and the fourth SBLC was in the face amount

of $900 million. Each SBLC listed XXXX, ESP, and XXXXX as the applicants and

Hayman as the beneficiary. Copies of these four SBLCs are attached as EXHIBITS

A1-A4.

25. Hayman negotiated and executed LOAN AGREEMENTS for these four SBLCs

with XXXX, ESP and XXX respectively prior to the SBLCs being sent by SWIFT to

-6-

Hayman. Copies of those respective loan agreements are attached as EXHIBITS

B1-B3. The loan agreements each provide that Hayman will be prepared to start

funding Plaintiffs within five (5) to fourteen (14) banking days of delivery and

acceptance of the SBLC’s. Funding would occur upon draw down requests from each

of the Plaintiffs.

26. These loan agreements, INTER ALIA,

a. contain a SPECIFIC PERFORMANCE CLAUSE in favor of Plaintiffs that was material to the negotiations and execution of the loan agreements between the Plaintiffs and Hayman;

b. contain Hayman’s GUARANTY to monetize the SBLCs at 100% of value;

c. require Hayman to PERFORM ALL ITS OBLIGATIONS TO PLAINTIFFS WITHIN NINETY (90) DAYS from execution date of the loan agreements;

d. require Hayman to RETURN THE SBLCS TO PLAINTIFFS if Hayman failed to monetize the SBLCs and fund Plaintiffs within 90 days.

27. On August 2, 2010, Hayman approved, verified, and accepted the

SBLCs prior to them being sent. Upon information and belief, Hayman used one of

more of the SBLCs for Hayman’s benefit and not for the benefit of any of the

Plaintiffs. Yet, Hayman has not funded XXXX, ESP or XXXXX any amount as promised

and provided in the loan agreement and consistent with the collateral

agreements.

28. As part of Hayman’s plan and scheme, it negotiated and executed a

collateral agreement with Metropolitan for these SBLCs based upon Plaintiff’s

promise to pay the fees for the SBLCs. A copy of that collateral agreement is

attached as EXHIBIT C.

29. At all pertinent times, Hayman and its principals (Husner, Bacik,

Dieterich, Masud) never possessed the financial ability, wherewithal, banking

relationships, experience or knowledge to monetize these SBLCs.

30. Rather, upon information and belief, it was always the intention of

Husner and his fellow defendant principals and agent representatives named

herein to improperly use these SBLCs to falsely bolster the balance sheet of the

-7-

Royal Bank of Baku, Baku, Azerbaijan where Husner was or was trying to become a

shareholder and officer of the Bank for other business dealings through Hayman.

31. Whenever Plaintiffs questioned Hayman’s principals about delay and

performance, Hayman reiterated through Husner, Bacik, Masud, and Dieterich,

Hayman’s ability to monetize the SBLC’s within the contracted time periods.

32. As of November 1, 2010, Hayman has possessed each of these SBLC’s

for over 90 consecutive business days. Over that time period, Hayman has evaded,

stalled and given XXXX, ESP, and RPD numerous unsubstantiated, irrelevant and

ultimately false explanations for not funding Plaintiffs under the executed loan

agreements.

33. To date Hayman has not met any of its obligations in the loan

agreement or kept any of its promises. Thus, Hayman is in breach of its

contracts with XXXX, ESP and XXXXXXX.

34. Throughout the non-performance period after receiving the SBLCs,

Hayman on several occasions promised to provide third-party documentation and

third-party references about Hayman’s ability to fund and pay fees and

performance of actual deals. Hayman never provided any proof of Hayman’s ability

to perform.

35. Upon information and belief, Hayman instead forwarded these SBLCs

to the Royal Bank of Baku with Hayman falsely listed as the beneficiary.

36. Upon information and belief, Hayman provided all the instructions,

SWIFTs, Account Numbers and detailed MT760 language for the issuance and

delivery of the SBLC’s to be sent to the Royal Bank of Baku as directed by

Hayman.

37. Prior to release and delivery of the SBLCs, Hayman provided written

approval of the collateral provider as an inducement to have the SBLCs delivered

to Hayman.

-8-

38. Within the first week of the funding timeline Hayman informed the

Plaintiffs that due to European summer vacations the process was delayed; this

statement was not true, Hayman and each of the defendants knew it was not true

at the time, and it was made to Plaintiffs for them to rely upon as an excuse

for Hayman’s failure to perform.

39. The following week, Hayman told the Plaintiffs that funding was

going through the United States Federal Reserve and therefore Hayman would have

to complete clearance that would further delay the funding; this statement was

not true, Hayman and each of the defendants knew it was not true at the time,

and it was made to Plaintiffs for them to rely upon as an excuse for Hayman’s

failure to perform. Neither evidence nor documentation has been provided that

this funding source was available.

40. Plaintiffs have met all their obligations. The Plaintiffs have

never materially impeded Hayman from meeting its obligations.

41. Plaintiffs made all required written draw-down requests and

submitted them to Hayman to facilitate funding on August 20, 2010, the target

funding date. Hayman accepted these draw requests without comment. Copies of the

draw requests from XXXX, ESP and XXXXX are respectively attached at EXHIBITS D1,

D2, AND D3.

42. In an e-mail dated August 20, 2010, Roland Husner on behalf of

Hayman again confirmed that the SBLC’s and the collateral were sufficient to

complete the transaction. EXHIBIT E. That e-mail also stated that a confirmation

SWIFT was required and upon receipt funding would occur within the five (5) to

seven (7) seven banking days; this statement was not true, Hayman and each of

the defendants knew it was not true at the time, and it was made to Plaintiffs

for them to rely upon as an excuse for Hayman’s failure to perform. This funding

never occurred.

-9-

43. On August 25, 2010, the Plaintiffs received an e-mail from Roland

Husner stating that Hayman was now funding from a Middle Eastern bank. EXHIBIT

F. Mr. Husner was now purportedly traveling there to complete the transaction

and Robert Masud had successfully completed the negotiations. These statements

were not true, Hayman and each of the defendants knew they were not true at the

time, and they were made to Plaintiffs for them to rely upon as an excuse for

Hayman’s failure to perform. Again, funding was never forthcoming.

44. On September 7, 2010, the Plaintiffs received an e-mail from Roland

Husner stating that Hayman would now fund through both a USA bank and a top five

world bank. EXHIBIT G. It further stated Royal Bank of Baku would pay all

required fee’s to set-up a new corresponding bank relationship and SWIFT fee’s

to transfer the SBLC’s as required. Deal completion was promised within two

weeks. Again, these statements were not true, Hayman and each of the defendants

knew they were not true at the time, and they were made to Plaintiffs for them

to rely upon as an excuse for Hayman’s failure to perform. Again, Hayman failed

to provide any confirmation of its representations to the Plaintiffs, and did

not fund the transactions.

45. On September 18, 2010, the Plaintiffs received an e-mail from

Roland Husner stating that Hayman had completed a separate $100 million

transaction and was going to monetize the Instruments and fund the Plaintiffs as

promised utilizing the same banks and SWIFT procedures. EXHIBIT H. In this same

e-mail, Husner stated that there would be little or no due diligence period by

the funding bank and that the process was only a formality because the SBLCs and

the collateral were sufficient. These statements were not true, Hayman and each

of the defendants knew they were not true at the time, and they were made to

Plaintiffs for them to rely upon as an excuse for Hayman’s failure to perform.

46. On September 22, 2010, the Plaintiffs had a conference call with

Roland Husner and were informed that Hayman was in possession of executed bank

-10-

loan documents to fund the Plaintiffs and that funding would occur within the

next two banking weeks. Hayman provided no back-up or documentation to verify

these new assertions. This statement was not true, Hayman and each of the

defendants knew it was not true at the time, and it was made to Plaintiffs for

them to rely upon as an excuse for Hayman’s failure to perform.

47. On September 23, 2010, Husner sent the Plaintiffs an e-mail quoting

the proposed lender in which Hayman allegedly had contracts and advising us that

the lender had several remaining questions. EXHIBIT I. This email statement was

not true, Hayman and each of the defendants knew it was not true at the time,

and it was made to Plaintiffs for them to rely upon as an excuse for Hayman’s

failure to perform.

48. On September 24, 2010, Husner sent the Plaintiffs an e-mail stating

he had just received the executed bank documents and all that was needed was

Hayman’s review and signature. Hayman indicated he was traveling to see the bank

the following week to complete the transaction. EXHIBIT J. In this e-mail,

Husner wrote and stated:

“There have been verbal and other suggestions made and hence, we are also going to request confirmation by Masud & Company on the law firm’s letterhead to be sent to you/your firm by the end of business Friday PST September 24th, 2010 and copy all involved in these pending transactions of Masud & Company our law firm also having received the signed contract now only requiring our law firms and our review, correction or clarification, if any and our counter signature for and on behalf of Hayman Private Equity LLC.”

49. The Plaintiffs to date have never received any documents from

Robert Masud as promised in the e-mail and the funding has not occurred. These

statements were not true, Hayman and each of the defendants knew they were not

true at the time, and they were made to Plaintiffs for them to rely upon as an

excuse for Hayman’s failure to perform.

50. On October 3, 2010 the defendants Roland Husner and Robert Masud

met with a representative of the Plaintiffs in Zurich, Switzerland and stated

that if they could not produce written third party verification that Hayman

-11-

could monetize the SBLC’s and fulfill the conditions of the loan agreements and

the collateral agreement with the Plaintiffs by October 8, 2010, Hayman would

quote “walk away from the deal” and return the Instruments to Metropolitan and

Estrategia. Again, Hayman and the defendants have not met their promises.

51. On October 9, 2010 the defendants Roland Husner and Robert Masud

met again with a representative of the Plaintiffs in Zurich, Switzerland and

stated that if they could not produce written third party verification that

Hayman could monetize the SBLC’s and fulfill the conditions of the loan

agreements and the collateral agreement with the Plaintiffs by October 18, 2010,

Hayman would return the SBLC Instruments to Metropolitan and Estrategia. Hayman

has not provided any information to the Plaintiffs as of October 29, 2010. To

date Hayman has not returned the SBLC Instruments to the issuer as promised on

October 9, 2010.

52. On October 21, 2010, Andrew Bacik, President of Hayman, sent an

e-mail to the Plaintiffs that Hayman would provide an update from Roland Husner

by October 24, 2010. EXHIBIT K. No such update was received from Hayman.

53. The Plaintiffs’ have reasonably relied on Hayman’s funding

commitments and representations. The ongoing delays have caused severe

consequential damage to each of the Plaintiffs and have put their business in

jeopardy.

54. In addition to $1.35 million in fees paid to issue the SBLC’s to

Hayman, the Plaintiffs have also continued to invest hundreds of thousands of

dollars to maintain their companies and hold business transactions in place. The

Plaintiffs reliance on the Hayman contract and the Hayman failure to fund has

placed the Plaintiffs at significant risk and potential loss of hundreds of

millions of dollars.

55. On October 25, 2010 XXXX, ESP and XXXXXX, through counsel, sent

written demand to Hayman, Husner, Bacik and Dieterich setting forth all these

breaches and misrepresentations and demanding the immediate return of the

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Instruments. Defendants have not complied with this demand. A copy of that

demand letter is attached as EXHIBIT L.

56. Despite repeated requests from the Plaintiffs, Hayman has not

provided customary and verifiable documentation as to Hayman’s ability to

monetize the SBLCs and fund the Plaintiffs.

57. For all the reasons stated herein and more, the Plaintiffs demand

the return of the $1.5 billion in SBLC Instruments to Metropolitan and

Estrategia immediately.

58. In November 2010 Hayman was contacted by the Defendants requesting

the funding be completed per the agreements and that the SBLC be returned.

Husner, Bleyer and Bacik each stated that they will not return any SBLC without

a payment of at least $500,000 from the Defendants.

59. From May 2010 to November 2010 Hayman and its principals promoted

their capability to fund by referencing Urban through conversations and E Mails

with the Defendants. Defendants’ representatives met with representatives of the

Urban in August 2010 and Urban confirmed and promoted that Hayman was a viable

lender and Urban had personally witnessed Proof of Funding related to Hayman

lending capabilities.
COUNT I
BREACH OF CONTRACT
(Hayman, Husner, Bacik, Dieterich)

60. Plaintiffs have met all their obligations under the loan agreements

and collateral agreements and oral promises of Hayman.

61. Defendants Hayman, Husner, Bacik, Dieterich have not met any of

their material obligations under their oral promises, loan agreements or the

collateral agreements.

62. Defendants Hayman, Husner, Bacik, and Dieterich are in breach of

these contracts, all and each.

-13-

63. As a consequence of these breaches, Plaintiffs XXXX, ESP and XXXX

have lost in excess of $100 million in business opportunities and contracts,

plus fees paid to Defendants in excess of $1 million, plus attorneys’ fees and

costs.

64. Plaintiffs have lost in excess of $1.35 million in costs, fees and

expenses related to the issuance of the SBLCs, their unauthorized use by

defendants, and defendants’ failure to return them.

65. Plaintiffs demand specific performance per the contracts and

agreements.

WHEREFORE, Plaintiffs ask the court to order SPECIFIC PERFORMANCE in

favor of each Plaintiff and against each of the Defendants in the following

amounts: XXXX: $1,100 Billion, ESP: $200 million and XXXXXX: $200 million, or in

the alternative only if Hayman admits or is found that it cannot perform such

financing deals, (a) injunction against Hayman, its principals and venturers

from engaging in any financing deals or transactions and referral of these

matters to the Illinois and Massachusetts Attorney Generals, (b) immediate

return of the SBLCs; (c) $1.35 million in lost fees, (d) the expenses and costs

each plaintiffs proves that have been incurred since Hayman breached these

contracts and agreements, (e) lost profits as to each plaintiff as demonstrated

by the evidence, and (f) any further and additional order and awards as the

court deems just under the circumstances.

COUNT II
COMMON LAW FRAUD
(Hayman, Husner, Masud, Bacik, Dieterich)

1-59. Plaintiffs restate and re-allege paragraphs 1-59 as paragraphs

1-59 of this Count II.

60. At all times material to this Count, Hayman, Husner, Masud, Bacik,

Dieterich and Weisman, jointly and severally, made the aforementioned statements

and/or remained silent when they each new these statements to be false.

61. Defendants made these statements and/or remained silent for the

express purpose of gaining Plaintiffs money, confidence and reliance to send

-14-

them fees and Instruments when they all knew that Hayman, Husner, Bacik and

Dieterich, and their principals, attorneys, agents and representatives, all

Defendants herein, never possessed the financial ability, wherewithal, banking

relationships, experience or knowledge to monetize these Instruments for

Plaintiffs Metropolitan and Estrategia nor fund Plaintiffs XXXX, ESP and XXXXX.

62. Plaintiffs reasonably relied upon Defendants and their

representatives and statements, and thereafter took action to demand return of

the Instruments

63. As a consequence of these frauds upon Plaintiffs by Defendants

Hayman, Husner, Bacik, Dieterich, and Masud, jointly and severally, Plaintiffs

XXXX, ESP and XXXXXXX have lost in excess of $100 million in business

opportunities and contracts, plus fees paid of $1.35 million, plus attorneys’

fees and costs.

WHEREFORE, Plaintiffs ask the court to order SPECIFIC PERFORMANCE in

favor of each Plaintiff in the following amounts: XXXX: $1,100 Billion, ESP:

$200 million and XXXXX: $200 million, or in the alternative only if Hayman

admits or is found that it cannot perform such financing deals, (a) injunction

against Hayman, its principals and venturers from engaging in any financing

deals or transactions and referral of these matters to the Illinois and

Massachusetts Attorney Generals, (b) immediate return of the SBLCs; (c) $1.35

million in lost fees, (d) the expenses and costs each plaintiffs proves that

have been incurred since Hayman breached these contracts and agreements, (e)

lost profits as to each plaintiff as demonstrated by the evidence, and (f) any

further and additional order and awards as the court deems just under the

circumstances.

In addition, Plaintiffs ask the court to award them PUNITIVE DAMAGES in

the total amount of $10 million.

-15-

COUNT III
STATUTORY CONSUMER FRAUD
(Hayman, Husner, Masud, Bacik, Dieterich)

1-59. Plaintiffs restate and re-allege paragraphs 1-59 as paragraphs

1-59 of this Count III.

60. At all material times to this Complaint, there existed as the law

of Illinois a consumer fraud act commonly known as the CONSUMER FRAUD &

DECEPTIVE BUSINESS PRACTICE ACT, 815 ILCS 505, ET. SEQ. as a set of regulations

of business practices for consumer protection (“Illinois Act”).

61. At all material times to this Complaint, and in the alternative,

there existed as the law of the Commonwealth of Massachusetts a consumer fraud

act commonly known as the MASSACHUSETTS CONSUMER PROTECTION ACT, Title XV,

Chapter 93A as a set of regulations of business practices for consumer

protection (“Massachusetts Act”).

62. These statutory Acts pertained in all their respective provisions and amendments to the deceptive acts and omissions of Defendants, jointly and severally, stated and set forth in this Complaint.

63. All the Defendants, jointly and severally, violated the provisions of the Illinois Act and the Massachusetts Act by engaging repeatedly and knowingly, and in concert, in a pattern of conduct to deceive Plaintiffs for the unlawful monetary gain of Defendants.

WHEREFORE, Plaintiffs each ask for damages against Hayman, Husner, Bacik, Dieterich, and Masud, jointly and severally, in excess of $100 million as proven by the evidences, PLUS PUNITIVE DAMAGES in excess of an equal amount ($100 million), plus costs and fees and for an order from this court ordering each of the Defendants to return or cause the return of the four SBLCs, and for any additional relief and damages the court deems just under the circumstances.


RESPONDENTS-IN-DISCOVERY

ROSS GLICKMAN, JAMES NAPOLI AND KENNETH BARRY

64. As set forth in paragraphs 11, 12 and 13, Ross Glickman, James Napoli and Kenneth Barry are each jointly and severally principals in UHH and UHJV who likely possess personal knowledge at all pertinent times herein of Hayman, its principals, Hayman’s sources of funding and operations, Hayman’s use and experience with SBLCs, and potentially Hayman’s dealings with one or more of the Plaintiffs.

65. Messrs. Glickman, Napoli and Barry, jointly or severally, also may be vicariously responsible to one or more of the plaintiffs based upon their roles, management or membership directly or indirectly with Hayman in UHH and/or

UHJV.

WHEREFORE, Plaintiffs designate Ross Glickman, James Napoli and Kenneth Barry each as a Respondent-in-Discovery in this action pursuant to 735 ILCS

5/2-402.

Respectfully Submitted,


Gary A. Grasso, attorney for Plaintiffs

Gary A. Grasso, Esq.
GRASSO BASS, P.C.
Willis Tower  233 South Wacker Drive Suite 2101
Chicago, Illinois 60606
312.234.9100
********
760 Village Center Drive
Suite 200 Burr Ridge, Illinois 60527
630.654.4500
Cook County #: 38825
***********************************

Goldie Dickey Fraud Goldie Dickie Scam

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6 Responses to Goldie Dickey

  1. Fanatical Researcher says:

    http://www.rbnz.govt.nz/finstab/nbdt/4274737.html

    Notice: Metropolitan Financial Holdings Limited
    Notice: Metropolitan Financial Holdings Limited formerly known as Metropolitan Bancorp

    This entity trades using the website:

    http://metrofinancialholdings.com/index.php

    This company is not licensed or prudentially supervised by the Reserve Bank of New Zealand or any other New Zealand authority. It is not registered as an “Offshore Financial Corporation” as claimed on its website – no such type of entity is recognised under New Zealand law. The company does not have any physical presence in New Zealand.

    Refer to the caution on this website page about “New Zealand offshore finance companies”.

    http://metrofinancialholdings.com/index.php – see foot of page:
    In order to meet the compliance measures of the new laws of New Zealand, Metropolitan Bancorp LTD name has been legally changed to
    Metropolitan Financial Holdings LTD. Metropolitan Financial Holdings is offering financial services as a Finance Company and not as a registered bank under supervision by the Reserve Bank of New Zealand. Services are not available to the public in New Zealand.

  2. Fanatical Researcher says:

    see: http://lawtonftsillok.usachamber.com/custom2.asp?pagename=members&reason=search&intID=90&typesearch=ALPHA&searchcriteria=A

    A.T. Financial Services
    Goldie Dickey
    502 NW Sheridan Road
    Ste 6A
    Lawton, OK 73505
    (580) 355-4800
    http://www.atfin.net/ (the contact page on this site gives email info@atfin.net )
    email: info@metrobancorp.net (this email address is the contact for Golden Dick according to the above link)
    Contact telephone numbers & address from the actual site http://www.atfin.net 2304 NW Fort Sill Blvd, Lawton, OK 73507
    Office: 580-351-1819 Fax: 580-351-1868

    Domain name: atfin.net

    ATFIN.NET SITE INFORMATION
    IP: 64.14.68.11
    IP Location: Kwun Tong, Hong Kong

  3. Handy Andy says:

    http://goldiedickey.multiply.com/journal/item/1/About_Estrategia_Investimentos_S.A.?&show_interstitial=1&u=%2Fjournal%2Fitem
    About Estrategia Investimentos S.A. Jun 15, ’11 12:23 AM
    for everyone
    By Goldie Dickey

    I serve as the International Banking Relationship Manager for Metropolitan Financial Holdings Ltd., formerly known as Metropolitan Bancorp Ltd. That function requires me to form new relationships with banks in the national and international marketplaces, which allows Metropolitan to broaden its outreach and economic goals. Through my work, I became the Institutional Affiliate for Estrategia Investimentos S.A., a bank located in Brazil. Estrategia Investimentos S.A. is an open-ended investment company looking to capitalize on burgeoning markets in India, as well as Eastern and Central Europe.

    Specifically, Estrategia Investimentos S.A. hopes to expand into the areas of western-style offices, residences, production units, retail outlets, and more. Starting out, Estrategia Investimentos S.A. conducts business on the micro level, all the while targeting investments in infrastructure projects. Toward that goal, Estrategia Investimentos S.A. works in tandem with various investment companies and local banks. Primarily, Estrategia Investimentos S.A. aims to create a vast network of business complexes, serving traveling businesspeople.

    Each accommodation and business complex would feature all the business and residential amenities one might need to live comfortably and conduct business while traveling. Estrategia Investimentos S.A. hopes to position these complexes in major cities, all within easy access to airports and/or freeports. Estrategia Investimentos S.A. encourages interested parties to seek further information at http://www.estrategiainvestimentos.com.

    Tags: banking, investimentos, estrategia, international, manager, goldie dickey

  4. Metro_Crusader says:

    Goldie Dickey is Goldie Santiago, a convicted felon, married to Allen Dicke, also a convicted felon. Randall Kohl and Koray Gurocak are listed as Managing Directors. Dickey is also listed a Founder of Kohls company IEG – Integrated Energy Group Inc. dba IEG Capital, Inc.

    We purchased a SBLC, wired the funds to Metro at a BofA account. Metro never acquired the SBLC, and a transaction that should have taken two weeks is ongoing for 5 months now, and after hundreds of excuses, they all of a sudden claim we never sent them any funds. This is the most blatant and easy to disprove lie.

    Metropolitan Financial Holdings operates like a bank in the US without being licensed. They claim to be a registered bank in New Zealand, Australia and Panama.

    NZ and AUS does not have any valid registration in their banking registries. Panama has a shell corp that fuctions as owner and parent company for the US activity. They are circumventing US banking laws and regulations. This way these criminals can operate in the financial sector.

    Metro actually has or had a relationship with Bank of America who handled their customer accounts. We are contacting BofA asking why they are dealing with these fraudsters. We are also in the process of contacting any banking authorities to put an end to these crooks.

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