Complaint Review: Larock Investment

The following are the proceedings which I commenced against JONATHAN ABRAMSON, RONALD CORBER et al.

Beware of these individuals. S U P E R I O R

PROVINCE OF QUEBEC

DISTRICT OF MONTREAL  

RHONDA  BINSTOCK  of  the Town of Richmond Hill, Province Ontario L4C  0P9,  and  therein residing   and   domiciled  at   63

NO:    500-17-053479-096  

  L4C  0P9,  and  therein

  Plaintiff

3888304 CANADA INC., a body politic and corporate, having its registered head office at 227 Dali Street, in the City of Dollard-des-Ormeaux, District of Montreal, H9A 3J6 and RONALD CORBER,of the City of Dollard-des-Ormeaux, District of Montreal, and therein residing and domiciled at 227 Dali Street, H9A 3J6 and 9180-8170 QUEBEC INC., a body politic and corporate, having its registered head office in the City and District of Montreal, at 1 Place Ville Marie, Suite 2818, H3B 4R4 and DANIEL JULIEN, residing and domiciled in the City of Varennes, district of De Richelieu, Quebec, at 324, du Champart, J3X 2J5, and JONATHAN ABRAMSON, of the City and District of Montreal, present address unknown, but having an office and place of business at 5490 Thimens, Suite 230, in the City and District of Montreal olidary Defendants and ROYAL BANK OF CANADA duly incorporated according to law, and having an office and place of business in the city and district of Montreal, at 1 Place Ville Marie and TD CANADA TRUST duly incorporated according to law and having an office and place of business at 3339 boulevard des Sources,in the city of Dollard- des-Ormeaux,district of Montreal, des-Ormeaux,district of MontrealCANADIAN IMPERIAL BANK OF OMMERCE duly incorporated according to law, and having an office and place of business in the city and district of Montreal, at 8000 Decarie Boulevard,bsp;  Third party garnishees MOTION TO INSTITUTE PROCEEDINGS

Articles 110, 111.1 IN SUPPORT OF HER MOTION, PLAINTIFF RESPECTFULLY SUBMITS I. <>THAT Plaintiff herein, a divorced mother of two children, separated from her husband during the month of February 2007, after a marriage that lasted approximately ten years.

• THAT on June 21, 2007, the Plaintiff met one of the Defendants, Jonathan Abramson (hereinafter referred to as “Abramson”) at a restaurant in the City of Toronto. THAT notwithstanding the fact that Abramson, at all relevant times, had an apartment in the City of Montreal, their relationship developed via long distance telephone calls and text messages, and Abramson also drove to Toronto on weekends which he spent with the Plaintiff.THAT this relationship continued throughout the summer 2007, after which time, Abramson moved into Plaintiff’s home during the month of September 2007, on the assumption that he would lease an apartment, which he ultimately failed to do.THAT Abramson, during the early stages of his relationship with the Plaintiff, realized intuitively that she was vulnerable and could be manipulated rather easily. THAT the Restraining Order was nonetheless in place and during the month of December 2008, Abramson insisted and demanded that Plaintiff and Abramson attend at the Newmarket Court House in the Province of Ontario, at which time, the Restraining Order was reversed at the request of and with the consent of the Plaintiff herein.

THAT as and from the onset of their relationship and throughout the months thereafter, Plaintiff disbursed thousands of dollars for vacations, travel, restaurants, food, automobile expenses, etc.

THAT in addition, Plaintiff, on two occasions, paid Abramson's rent and settled a claim for past rent due by Abramson in the respective sums of $1,400 and $2,000 and in addition thereto, Plaintiff also disbursed the sum of approximately $550 in order to reinstate Abramson's driver's license which was apparently suspended by the Ontario authorities.

THAT Plaintiff purchased a computer for Abramson which he utilized and apparently is continuing to utilize.

THAT Abramson, not content to benefit from his parasitic existence in that essentially all of his living expenses were being paid for by the Plaintiff, began to lay the foundation for the gross fraud which was ultimately carried out by Abramson's henchmen.

THAT specifically, during the month of December 2008, Abramson suggested that a golden investment opportunity existed and told Plaintiff that they could acquire a 30% interest in a company which he referred to as Madison Medals

THAT Madison Medalscannot be located in any corporate search. 

THAT Plaintiff acquiesced and Abramson then arranged a meeting between Plaintiff and Ronald Corber, one of the solidary Defendants herein.

THAT prior to meeting the Defendant Ronald Corber, Abramson informed the Plaintiff, who was employed as a legal secretary, that as a direct result of this “golden investment opportunity”, their future would be secure, she would not be obliged to work, and that Abramson would ultimately become the sole supporter of the Plaintiff and her children.

THAT in addition, Abramson promised Plaintiff that they would purchase a home in the Laurentians and that Plaintiff would ultimately live in Toronto with her children for one week, another week in Montreal with him, the home in Laurentians would be enjoyed by all concerned and everyone would live happily ever after.

THAT in addition thereto, Abramson told the Plaintiff that he was madly in love with her and that he intended to marry her THAT the investment proposed by Defendant Abramson did not involve any financial advance by him, but conversely required a significant financial advance by the Plaintiff, with the understanding that in the future, when this golden opportunity produced golden eggs Defendant Abramson would re-pay the Plaintiff the sums already invested by her.

THAT during the month of January 2009, Plaintiff borrowed significant sums of money from the Toronto Dominion Bank and was obliged to utilize her home as collateral in order to provide funds for this investment which she was contemplating.

THAT as an immediate and direct consequence of her discussions with Defendant Abramson, Plaintiff was introduced to and met Defendant Ronald Corber, an accomplice of Abramson and the prime organizer of the gross fraud that was ultimately perpetrated.

THAT as an immediate and direct result of her encounter with Defendant Ronald Corber, and for reasons which are entirely incomprehensible, Plaintiff, without any writing or documentation whatsoever, advanced the following sums on the dates indicated to the credit and benefit of the parties hereinafter outlined at the request and pursuant to the instructions of Defendant Ronald Corber Date of Deposit Amount Name of account November 24, 2008: $ 5,036.30& 3888304 Canada Inc December 8, 2008: 3888304 Canada Inc. December 15, 2008: $3,175.00 3888304 Canada Inc. January 20, 2009 $85,080.00 9180-8170 Quebec Inc. January 23,2009 $16,800.00 Ronald Corber personal the whole as may be seen from copies of banking documents, wire transfer information, blackberry and email instructions from Defendants Ronald Corber and Abramson to Plaintiff, debit memo bank receipt, handwritten instructions from Defendant Jonathan Abramson, and fax sheets to the attention of Defendant Ronald Corber, produced herein,en liasse, as Plaintiff's Exhibit P-1 to avail herein as if recited hereinafter at length.

THAT as appears from the bank documents, Exhibit P-1, the advances to the Defendants 3888304 Canada, 9180-8170 Quebec Inc. and Ronald Corber were made by wire transfer directly from Plaintiff's bank to the bank accounts of the corporate Defendants, whilst the sum of $16,800 was transferred directly into the personal bank account of Defendant Ronald Corber, at the TD Canada Trust branch situated at 3339, boulevard des Sources, Dollard-des-Ormeaux.

THAT at one of the earlier meetings between Plaintiff, Abramson and Defendant Ronald Corber in Toronto, Plaintiff gave Defendant Ronald Corber the sum of $10,000 in cash for another golden opportunity described as an investment in a venture known as B &B Directories for which Plaintiff to date has received no valid consideration, nor any document or receipt that would be deemed appropriate in the circumstances.

THAT whilst Plaintiff acted in a reckless manner which can only be explained and/or justified in part by her state of mind at all relevant times, she is nonetheless entitled to be refunded by the solidary co-Defendants for the sums advanced given the fact that there was never any consideration nor justification for these advances.

THAT Plaintiff has received absolutely no benefit whatsoever from the solidary co-Defendants as a result of the sums advanced, and the solidary co-Defendants in turn have benefited totally from the sums advanced.

THAT Defendant Ronald Corber, realizing that he hada markor a live one, completely ignored Plaintiff after having benefited from the proceeds of the gross fraud, but nonetheless continues to enjoy an enhanced lifestyle.

THAT Defendant Ronald Corber and his family live in a very expensive home and own and/or lease expensive automobiles, notwithstanding the fact that he apparently has no tangible form of employment. THAT Plaintiff, after having been victimized by the gross fraud committed herein, became aware that Defendant Ronald Corber pleaded guilty to charges of credit card fraud in the State of Florida and was condemned to pay a fine in excess of $400,000 U.S., the whole as may be seen from a copy of the Judgment produced herein as Plaintiff's Exhibit P-2 to avail herein as if quoted hereinafter at length.

THAT subsequent to January 2009, Defendant Abramson's behavior did not measurably improve notwithstanding the fact that Plaintiff financed a trip to Florida, during which time, he presumably was being trained for the business venture bearing the name of Madison Medals.

THAT Plaintiff has never met the co-Defendant Daniel Julien but became aware of the fact that he was the principal of the Defendant company 9180-8170 Quebec Inc., as and when her undersigned attorney of record conducted a corporate search.< THAT although being duly called upon to remit the sum of $85,080, which the corporate Defendant 9180-8170 Quebec Inc. has already received, neither Daniel Julien nor any representative of the aforesaid corporate co-Defendant communicated with Plaintiff's undersigned attorney of record.

THAT the corporate Defendant 3888304 Canada Inc. has a registered office which apparently is also the home address of Defendant Ronald Corber.

THAT according to corporate records, the Defendant Ronald Corber is also the sole shareholder, director and officer of the Defendant 3888304 Canada Inc.

THAT the Plaintiff was advised that the company called Madison Medalscarries on business at 5490 Thimens, Suite 230, St-Laurent, Quebec, which address was visited and there was no listing on the business directory for the aforesaid Madison Medals.

THAT it is self-evident that Plaintiff was victimized by a fraud inasmuch as Plaintiff never received any shares, business plan nor contractual documentation establishing her shareholdings in any business enterprise or corporation(s), in conjunction with the co-Defendant Ronald Corber, or either of the corporate co-Defendants herein.

THAT it is self-evident that the co-Defendant Ronald Corber representing himself and the other corporate co-Defendants herein, as well as the co-Defendant Daniel Julien utilized Jonathan Abramson in order to commit gross fraud upon the Plaintiff herein and obtain the sum of $120,098.80 from her in an illegal manner.

THAT given the fact that Plaintiff's advances were made conditional upon future investments, these advances should have been escrowed, conditional upon the conclusion of legal and valid business arrangements, which was not done.

THAT Plaintiff received absolutely no consideration whatsoever from 9180-8170 Quebec Inc., a company which has its head office at a law firm situated in Suite 2818 in Place Ville-Marie, Montreal.

THAT as a consequence of the gross fraud more fully described herein, Plaintiff is entitled to lift the corporate veil of Defendants 3888304 Canada Inc. and 9180-8170 Quebec Inc. and ask that this Honourable Court condemn the principals therein, co-Defendants Ronald Corber and Daniel Julien, as well as the corporate entities, co-Defendants 3888304 Canada Inc. and 9180-8170 Quebec Inc., as well as the other co-Defendant Jonathan Abramson, to re-pay Plaintiff for the sums advanced by her and for which she received absolutely no consideration.

THAT there was absolutely no justification or valid reason for Plaintiff's advances already described herein, save and except for the fact that Plaintiff's state of mind enabled the co-Defendants herein and more particularly, Defendants Ronald Corber and Jonathan Abramson to conceive, perpetrate and carry out the gross fraud to the benefit of all of the co-Defendants herein and to the prejudice of the Plaintiff. III.LIABILITY THAT it is beyond a shadow of a doubt that the solidary co-Defendants  3888304 Canada Inc., 9180-8170 Quebec Inc., and Jonathan Abramson, represented at all relevant times by Defendant Ronald Corber, have committed gross fraud against Plaintiff, tantamount to theft of the sum of $130,098.80. THAT in light of the foregoing, the other co-Defendant Daniel Julien knew or should be presumed to have known of the fraudulent acts of Ronald Corber perpetrated through the corporate vehicles, 3888304 Canada Inc., as well as 9180-8170 Quebec Inc., given the fact that the sum of $85,080,00, without any notice or any correspondence or documentation, was suddenly deposited into the corporate bank account of 9180-8170 Quebec Inc.

THAT as an immediate and direct consequence, the co-Defendants, 9180-8170 Quebec Inc. and Daniel Julien benefited from the funds deposited into the corporate bank account situated at the Royal Bank of Canada branch, situated at 1 Place Ville Marie, Montreal, Quebec.

THAT as a consequence of the gross fraud perpetrated upon the Plaintiff herein, Plaintiff is entitled to ask that this Honourable Court, in virtue of the Judgment to be rendered herein, lift the corporate veil of the co-Defendants 3888304 Canada Inc. and 9180-8170 Quebec Inc. and condemn Defendants Ronald Corber and Daniel Julien, personally, given the fact that they are the principals and apparently the sole shareholders, officers and directors of their respective corporate entities.

THAT although being duly called upon to satisfy Plaintiff's claim, the co-Defendants herein have refused and/or neglected to do so, the demand letters of Plaintiff’s attorney of record dated September 10, 2009, are hereinafter filed and produced, en liasse, as Plaintiff’s Exhibit P-3, to avail as if quoted hereinafter at length.

THAT furthermore, the mise en demeure, Exhibit P-3, forwarded to the corporate Defendant 9180-8170 Quebec Inc. was returned to sender, with the notation as more fully appears from a copy of the envelope returned from the post office hereinafter filed and produced as Plaintiff’s Exhibit P-4.

THAT in fact, the co-Defendants Daniel Julien, as well as Jonathan Abramson have not even responded to the mise en demeure, Exhibit P-3, received by them.

 THAT in addition to the foregoing, as a result of the fact that the Defendants took advantage of Plaintiff who was not emotionally healthy at all relevant times, Plaintiff is entitled to claim an additional sum of $60,000 in punitive damages, the co-Defendants’ behavior being particularly egregious, malicious, dishonest and felonious.

 THAT Plaintiff is furthermore entitled to claim a sum of $45,000, representing anticipated legal fees and costs envisaged as a consequence of the present litigation, in the event that the litigation proceeds to trial.

THAT as a consequence, Defendants 3888304 Canada Inc., Ronald Corber, 9180-8170 Quebec Inc., Daniel Julien, and Jonathan Abramson are indebted to Plaintiff for the sums of $103,298.80, representing the gross fraud, as well as $60,000 in punitive damages and $45,000 in legal fees and costs, the whole forming a total sum of $208,298.80.  

 THAT Defendant Ronald Corber, in addition thereto, is furthermore indebted to Plaintiff in the sum of $26,800.00, consisting of the sums of $16,800 and $10,000 remitted to him personally by Plaintiff, without any justification or consideration.

 THAT the aforesaid sum of $26,800.00 again was obtained by Defendant Ronald Corber personally, as an immediate and direct consequence of gross fraud of which clearly, he is an accomplished practitioner.

 THAT the solidary Defendants herein enriched themselves without justification at the expense of the Plaintiff.

 THAT Plaintiff’s Motion is well-founded in fact and in law and should be maintained.

 THAT the Seizure before Judgment by garnishment practiced in the present case be declared good, valid, binding and sufficient.

 THAT any and all sums seized herein, property of the Defendants, in the hands of the garnishees be retained by the said garnishees or deposited by the garnishees into the Office of the Court pursuant to law until Judgment is rendered herein.

 WHEREFORE MAY IT PLEASE THIS HONOURABLE COURT BY JUDGMENT TO BE RENDERED HEREIN:

 GRANT the present Motion; and  LIFT the corporate veil of 3888304 Canada Inc. and 9180-8170 Quebec Inc. due to the gross fraud practiced by the principals thereof and more fully described herein;  and  CONDEMN the co-Defendants, 3888304 Canada Inc. Ronald Corber, personally, 9180-8170 Quebec Inc., Daniel Julien, personally, and Jonathan Abramson, solidarily, to pay to Plaintiff the sums of $103,298.80, representing the gross fraud practiced by them, as well as the sum of $60,000 in punitive damages and the sum of $45,000 in legal fees and costs, the whole forming a total sum of $208,298.80; and  CONDEMN Defendant Ronald Corber to pay to Plaintiff the sum of $26,800.00, representing the gross fraud practiced by him upon the Plaintiff; and  CONDEMN all of the co-Defendants herein, solidarily, to pay the condemnations upon them with interest, as well as the additional indemnity provided for in Article 1619 of the Civil Code of Quebec, as of September 10, 2009, including judicial costs, as well as the costs of any expertise in the event that same is required;  and  DECLARE the seizure practiced in the present case good, valid, binding and sufficient; and  ORDER that any and all sums seized herein, property of the Defendants, in the hands of the garnishees, be remitted to the Plaintiff’s undersigned attorney of record, in trust, in order to satisfy, in whole or in part, the Judgment rendered herein.

MONTREAL, October 1, 2009

JACOB L. ROTHMAN

Attorney for Plaintiff

NOTICE TO DEFENDANTS

(Article 119.C.c.p.)

Take notice that the Plaintiff has filed this Motion in the office of the Superior Court of Quebec for the judicial district of Montreal.

 To file an answer to this Introductory Motion, you must first file an Appearance, personally or by advocate, at the Courthouse of Montreal located at 1 Notre-Dame Street East, Montreal, Quebec, within ten (10) days of service of this Motion.

 If you fail to file an Appearance within the time limit indicated, a judgment by default may be rendered against you without notice upon the expiry of the ten (10) day period.

 If you file an appearance, the Introductory Motion will be presented before the Court on November 13, 2009 at 9:00 a.m. in Room 2.16 of the Courthouse.  On that date, the Court may exercise such powers as are necessary to ensure the orderly progress of the proceeding or the Court may hear the case, unless you make a written agreement with the Plaintiff’s advocate on a timetable for the orderly progress of the proceeding.  The timetable must be filed in the office of the Court.

 In support of the Introductory Motion to Institute Proceedings, the Plaintiff discloses the following exhibits:

 Exhibit P-1 en liasse:      Wire transfer information, blackberry and email instructions from Defendants  Ronald Corber and Abramson to Plaintiff, debit memo bank receipt, handwritten instructions from Defendant Jonathan Abramson, and fax sheets to the  attention of Defendant Ronald Corber,

Exhibit P-2:       Copy of Judgment;

Exhibit P-3 en liasse:  Letters of Demand dated September 10, 2009;

Exhibit P-4:  Copy of envelope addressed to 9180-8170 Quebec Inc. “return to sender”.

The foregoing Exhibits will be remitted to Defendants upon request.

 Montreal, October 1, 2009

                                                            JACOB L. ROTHMAN

                                                            Attorney for Plaintiff

C A N A D A   S U P E R I O R  C O U R T

PROVINCE OF QUEBEC

DISTRICT OF MONTREAL                              RHONDA  BINSTOCK

NO:

                                                                                                    Plaintiff

                                                                      vs.

                                                                      3888304 CANADA INC.

                                                                      and

                                                                      RONALD CORBER

                                                                      and

                                                                      9180-8170 QUEBEC INC

                                                                      and

                                                                      DANIEL JULIEN

                                                                      and

                                                                      JONATHAN ABRAMSON

                                                                                Solidary Defendants

                                                                      and

                                                                      ROYAL BANK OF CANADA

                                                                      and

                                                                      TD CANADA TRUST

                                                                      and

                                                                      CANADIAN IMPERIAL BANK OF COMMERCE

                                                                                Third party garnishees

LIST OF EXHIBITS

Exhibit P-1:   

en liasse:        Wire transfer information, blackberry instructions from Defendants   Ronald Corber and Abramson to Plaintiff, debit memo bank receipt,  handwritten instructions from Defendant Jonathan Abramson, and  fax sheets to the attention of Defendant Ronald Corber.

Exhibit P-2:    Copy of Judgment;

 Exhibit P-3 en liasse:        Copies of letters of demand dated September 10, 2009;

 Exhibit P-4:    Copy of envelope addressed to 9180-8170 Quebec Inc. “return to sender”.

                                                            MONTREAL, October 1, 2009

                                                                       JACOB L. ROTHMAN

                                                                        Attorney for Plaintiff                        

SUPERIOR COURT

CANADA

PROVINCE OF QUEBEC

DISTRICT OF MONTREAL

 DATE:                                     2012

 NO:  500-17-053479-096

IN THE PRESENCE OF :

RHONDA BINSTOCK

                                                Plaintiff

vs.

3888304 CANADA INC. et al.

                                                Defendants

JUDGMENT

(1)      WHEREAS Plaintiff’s action contains a conclusion to condemn co-Defendants, 3888304 Canada Inc. Ronald Corber, personally, 9180-8170 Quebec Inc., Daniel Julien, personally, and Jonathan Abramson, solidarily, to pay to Plaintiff the sums of $103,298.80, representing the gross fraud practiced by them, as well as the sum of $60,000 in punitive damages and the sum of $45,000 in legal fees and costs, the whole forming a total sum of $208,298.80;

(2)      WHEREAS the Defendant Jonathan Abramson has not appeared in the present file;

                                             2

(3) WHEREAS Judgment was rendered against Defendant Ronald Corber in the sum of $100,000;

(4) WHEREAS co-Defendant Daniel Julien has paid to Plaintiff, the sum of $3,000.00;

(5) WHEREAS Plaintiff is justly and truly entitled to request that Judgment by default be rendered in her favor against the Defendant Jonathan Abramson for the balance of her claim being in the sum of $105,298.80;

(6) WHEREAS Plaintiff’s action is well-founded in fact and in law.

FOR THESE REASONS, MAY IT PLEASE THIS HONOURABLE COURT TO:

GRANT Judgment by default in favor of the Plaintiff in the sum of $105,298.80, against co-Defendant Jonathan Abramson, including debt, interest and special indemnity, as of October 8, 2009;

I apologize.  When googling, try:

 Jonathan or Johnathan Abramson.

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 Siimply do your due dilligence.