Of 62 UNITED STATES DISTRICT COURT WESTERN DISTRICT of MICHIGAN SOUTHERN DIVISION CHRISTOPHER JEROME, an Individual
Case 1:16-cv-01116 ECF No. 1 filed 09/09/16 PageID.1 Page 1 of 62 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION CHRISTOPHER JEROME, an individual, LEO JEROME, an individual, and STORY COMPANIES, LLC, a Michigan limited liability company, Plaintiffs, v. Case No.: Hon. PLAINTIFFS DEMAND A TRIAL BY JURY JOEL FERGUSON, an individual, VIRGIL BERNERO, the Mayor of the City of Lansing, in his individual capacity, LANSING ECONOMIC AREA PARTNERSHIP, INC., a Michigan non-profit corporation, ROBERT L. TREZISE, JR., an individual, CLARK CONSTRUCTION SERVICES, LLC, A Michigan limited liability company, CHARLES CLARK, an individual, FRANK KASS, an individual, CONTINENTAL DEVELOPMENT, INC., an Ohio corporation, HALLMARK CAMPUS COMMUNITIES, an Ohio partnership, FERGUSON DEVELOPMENT, LLC, A Michigan limited liability company, CHRISTOPHER STRALKOWSKI, an individual, FERGUSON/CONTINENTAL LANSING, LLC, A Delaware limited liability company, and RED CEDAR INVESTOR, LLC, a Michigan limited liability company, Defendants. COMPLAINT Plaintiffs, Christopher Jerome, Leo Jerome, and Story Companies, LLC, by and though their attorneys, the Mike Cox Law Firm PLLC, for their Complaint against Defendants, Joel Ferguson, Virgil Bernero, the Lansing Economic Area Partnership, Inc., Robert L. Trezise, Jr., Page 1 of 62 Case 1:16-cv-01116 ECF No. 1 filed 09/09/16 PageID.2 Page 2 of 62 Clark Construction Services, LLC, Charles Clark, Frank Kass, Continental Development, Inc., Hallmark Campus Communities, Ferguson Development LLC, Christopher Stralkowski, Ferguson/Continental Lansing, LLC, and Red Cedar Investor, LLC, state as follows: INTRODUCTION 1. Defendant Joel Ferguson (“Ferguson”) has been running and continues to run a racketeering enterprise (“Ferguson Enterprise”)1 with his son David Ferguson and son-in-law, Christopher Stralkowski (“Stralkowski”) through their company, Ferguson Development LLC (“Ferguson Development”).
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