Daily Legal News - Common Pleas Notices

  • LEGAL NOTICE

    907570—Raida Allan vs. Tareq Allan, et al.

    Tareq Allan, whose last known place of residence is 6986 Whitedove Lane, Apartment 102, Middleburg Heights, Ohio 44130, otherwise whose place of residence is unknown, will take notice that on February 5, 2019, the undersigned, Raida Allan, filed her amended complaint in the Court of Common Pleas, 1200 Ontario Street, Cleveland, Ohio 44113, of Cuyahoga County, Ohio, alleging that the fraudulent transfer, pursuant to R.C. 1336.06(A)(2)(a), occurred immediately before the commencement of this action; that Defendant Tareq Allan did not cause Defendant 871 Rocky River Drive to pass a corporate resolution authorizing the sale of shares of common stock from Defendant Tareq Allan to Defendant Qais Allan; that Defendant Tareq Allan and Defendant Qais Allan did not exchange consideration; that Defendant Qais Allan did not make any payment of money or release Defendant Tareq Allan and/or non-party Tallan, LLC from their obligation due Skliros Construction Company; that Defendant Qais Allan did not issue a security interest to Defendant Tareq Allan in Defendant 871 Rocky River Drive of his shares of common stock to ensure his performance; that Defendant 871 Rocky River Drive remains and is truly the asset of Defendant Tareq Allan.

    Raida Allan has a valid and legal title to 49 shares of common stock to Defendant Pearl Road; that the fraudulent transfer, pursuant to R.C. 1336.06(A)(2)(a), occurred immediately before commencement of this action; that Defendant Tareq Allan did not cause Defendant Pearl Road to pass a corporate resolution authorizing the sale of shares of common stock from Defendant Tareq Allan to Defendant Qais Allan; that Defendant Tareq Allan did not comply with Defendant Pearl Road's Close Corporation Agreement's share restrictions; that Defendant Tareq Allan and Defendant Qais Allan did not exchange consideration; that Defendant Qais Allan did not make any payment of money to Defendant Tareq Allan for Defendant Pearl Road; that Defendant Qais Allan did not issue a security interest to Defendant Tareq Allan in Defendant Pearl Road or his shares of common stock to ensure his performance; that Defendant Pearl Road remains, and is truly the asset of Defendant Tareq Allan.

    Defendant Tareq Allan's fraudulent transfers of 871 Rocky River Drive, Inc. and Pearl Road, Inc. to Defendant Qais Allan, and Defendant Qais Allan's acceptance of the fraudulent transfers were willful, malicious, and done in conscious disregard of Plaintiff Raida Allan's rights.

    Wherefore, Plaintiff Raida Allan prays for judgment in her favor and against Defendants, Tareq Allan, Qais Allan, 871 Rocky River Drive, Inc. and Pearl Road, Inc., jointly and severally; and

    A. Appointment of a receiver to take control of 871 Rocky River, Inc. and Pear Road, Inc., and other assets of Tareq Allan pursuant to R.C. 1313.56 and R.C. 2735.01; and

    B. Appointment of a receiver to take charge of other property of Qais Allan pursuant to R.C. 1336.07(A)(3)(b); and

    C. Avoidance of the transfers of 871 Rocky River Drive, Inc. and Pearl Road, Inc. to the extent necessary to satisfy Raida Allan's judgment ($567,887.28) pursuant to R.C. 1336.07(A)(1); and

    D. Attachment of garnishment against 871 Rocky River Drive, Inc. and Pear Road, Inc. and other property of Qais Allan pursuant to R.C. 1336.07(A)(2); and

    E. An injunction against further disposition by both Tareq Allan and Qais Allan of 871 Rocky River Drive, Inc. and Pearl Road, Inc. or of other property pursuant to R.C. 1336.07(A)(3)(a); and

    F. Compensatory damages in an amount in excess of $25,000, to be proven at trial; and

    G. Punitive Damages;

    H. Interest; and

    I. Attorney fees and the cost of this action; and

    J. Any other relief this Honorable Court deems the circumstances require.

    The defendant named above is required to answer on or before the 26th day of June, 2019.

    RAIDA ALLAN.

    By Jorge Luis Pla, Erika Molnar and Nadia R. Zaiem, Attorneys for Plaintiff.

    Apr24May1-8-15-22-29, 2019

About your information and the public record.