BOS Agenda Packet 4.4.23 (linked)

Case 1:23-cv-00121 Document 1 Filed 03/27/23 Page 1 of 100 PagelD #: 1
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF RHODE ISLAND
GOTSPACE DATA LLC, GOT CAPITAL, LLC )
GOTSPACE DATA PARTNERS, LLC OCEAN )
DEVELOPMENT PARTNERS, LLC, RI, OCEAN y
DEVELOPMENT PARTNERS, LLC, MA, OCEAN )
DEVELOPMENT PARTNERS PRECINCT 1, LLC. OCEAN )
VACATIONS REALTY TRUST, NICHOLAS FIORILLO
TRUSTEE, NICHOLAS FIORILLO,
individually,
Plaintiffs
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}
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NE EDGE, LLC, THOMAS QUINN NSO GROUP )
TECHNOLOGIES LTD., Q CYBER TECHNOLOGIES, }
LTD., OSY TECHNOLOGIES, SARL, WESTBRIDGE )
TECHNOLOGIES, INC., META PLATFORMS, INC., )
APPLE INC., T-MOBILE, CYBROOK, INC. )
STEIN FIBERS, ATERIAN INVESTMENT )
PARTNERS, ALL OF US AT NORTH, LLC, VERDE )
GROUP LLC, ROUTE 44 DEVELOPMENT, LLC, )
QUEEN ANNE, LLC, GF FUNDING SWANSEA, LLC, )
RISING TIDES, LLC, S&Q DATA, LLC, S&J STORAGE _)
BROS., LLC, CROWD LENDING, LLC, CITY OF BOSTON )
BOSTON POLICE DEPARTMENT, MAYOR MICHELLE _ )
WU, individually, and as Mayor of the City of Boston; )
KEVIN HAYDEN, individually and as District Attorney )
of Suffolk County, BOSTON MUNICIPAL COURT )
OFFICER MICHAEL POWERS, DETECTIVE KARL )
DUGAL, individually and in their official capacity, )
KEVIN T. PETERS, RAYMOND C. GREEN, PETER )
SPITALNY, SAMUEL SPITALNY, STEPHEN QUILLINAN )
THOMAS QUINN, GEORGE MCLAUGHLIN, DANIEL)
MCLAUGLIN, DANIEL NAJARIAN, CHRISTOPHER )
FIUMARA, W-LOFTS, LLC, BSI 254 WESTFIELD, LLC, )
BLUE VISTA CAPITAL MANAGEMENT, LLC,NICHOLAS )
NESGOS, CAMERON PEASE, RACHEL ZOOB-HILL, )
STUART BORNSTEIN, ELLIOT GERSTEIN, JOHN BECK, )
JEFFREY HELLMAN, BRIAN SHEEHAN, LISA SERAFIN, )
JAMES STOLLER, SHAWN TOWNSEND, RACHEL FOX, )
MATTHEW WELNICKI, MICHAEL P. SAMS, MARK )
BLOCK, ALFRED DEMIRJIAN, TECH FUSION, EDWARD )
CASE NO.:
COMPLAINT FOR
DECLARATORY AND
INJUNCTIVE RELIEF

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JURCZYK, KATHERINE JURCZYK, KENNETH KOGUT,
GRAY LELAND, JR., WILLIAM R. SMITH II, JOYCE
WERBISKI, WALTER WERBISKI, CARL ZORN,
DEBORAH ZORN, 421 BARNES ROAD, LLC, 429
BARNES ROAD, LLC, BARNES ROAD FARM REALTY,
LLC, CONNECTICUT ATTORNEYS TITLE INSURANCE
COMPANY, DOWNES-PATTERSON CORPORATION,
GBGB LLC LIVING TRUST, 327-449 HAZELNUT, LLC,
JGJ DEVELOPMENT, LLC, KAMM REALTY, LLC,
MIDWOOD MANAGEMENT CORPORATION,
NORWICH INNOVATIONS, TANK WOOD FARM REALTY,
LLC, JOHN DOES 1-25,
)
)
)
)
)
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)
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Defendants )
and )
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TOWN OF BOZRAH, CONNECTICUT, JEFFREY T. )
LONDREGAN, in his capacity as Attorney for the Townof
Bozrah, Connecticut, TOWN OF GROTON, )
CONNECTICUT, MR. GLENN S. PIANKA, in his capacity )
as Selectman for the Town of Bozrah, Connecticut, )
MR. WILLIAM E. BALLINGER II, in his capacity as )
Selectman for the Town of Bozrah, Connecticut, )
MR. JEREMY TARASEVICH, in his capacity as )
)
)
)
)
)
Selectman for the Town of Bozrah, Connecticut,
THE GREENWALD COMPANY, HERBERT GREENWALD,
Reach and Apply Defendants
Plaintiffs Gotspace Data LLC, Ocean Development Partners LLC et als and Nicholas
Fiorillo. as manager, trustee, and individually (“Plaintiffs”), bring this instant complaint against
NE EDGE, LLC, (“NE Edge Enterprise”) NSO GROUP TECHNOLOGIES LIMITED,
Q CYBER TECHNOLOGIES LTD., OSY TECHNOLOGIES SARL, WESTBRIDGE
TECHNOLOGIES, INC., META PLATFORMS, INC., CYBROOK, INC., APPLE INC.,
T-MOBILE, INC., (“NSO Tech Defendants”), STEIN FIBERS, LLC, ATERIAN INVESTMENT
PARTNERS, ALL OF US AT NORTH, LLC, VERDE GROUP, LLC, ROUTE 44
DEVELOPMENT, LLC, QUEEN ANNE, LLC, GF FUNDING SWANSEA, LLC, W-LOFTS,

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LLC, BSI 254 WESTFIELD, LLC, BLUE VISTA CAPITAL MANAGEMENT, LLC, RISING
TIDES, LLC, S&Q DATA, LLC, S&J STORAGE BROS., LLC, CROWD LENDING, LLC,
TECH FUSION, (“Corporate Defendants”) Thomas Quinn, George Mclaughlin, Kevin Peters,
Nicholas Nesgos, Cameron Pease, Rachel Zoob-Hill, Elliot Gerstein, John Beck, Peter Spitalny,
Stuart Bornstein, Raymond C. Green, Samuel Spitalny, Stephen Quillinan, Jeffrey Hellman,
Brian Sheehan, Lisa Serafin, James Stoller, Shawn Townsend, Rachel Fox, Matthew Welnicki,
Michael P. Sams, Eliot Gersten, John Beck, Alfred Demirjian, Daniel Najarian, Christopher
Fiumara (“Enterprise Defendants”) City Of Boston, Boston Police Department, Mayor Michelle
Wu, Individually, and as Mayor of the City of Boston, Kevin Hayden, individually and as
District Attorney of Suffolk County, Boston Municipal Court, Officer Michael Powers, Detective
Karl Dugal, Individually and in their official capacity, (“Judicial/Municipal Defendants”), Mark
Block, Edward Jurezyk, Katherine Jurezyk, Kenneth Kogut, Gray Leland, Jr., William R. Smith
Il, Joyce Werbiski, Walter Werbiski, Carl Zorn, Deborah Zorn, 421 Barnes Road, LLC, 429
Barnes Road, LLC, Barnes Road Farm Realty, LLC, Connecticut Attorneys Title Insurance
Company, Downes-Patterson Corporation, GBGB LLC Living Trust, 327-449 Hazelnut, LLC,
JGJ Development, LLC, Kamm Realty, LLC, Midwood Management Corporation, Norwich
Innovations, Tankwood Farm Realty, LLC, and John Does 1-25, sellers of land in Connecticut
known as the Gotspace Data Digital Infrastructure Project. (“Data Site Land Seller and
Attorney Defendants”)
This Complaint is brought for the Defendants’ systemic pattern of violations of the
Racketeer Influenced and Corrupt Organizations ("RICO") Act (18 U.S.C. § 1961 (c), 1962 (c),
(det seq.Jand (18 U.S.C. 1958(a)(b)(c)), 18 U.S. Code § 1951 - Interference with commerce by
threats or violence addition to the ‘Dodd-Frank Wall Street Reform and Consumer ... (9) in
section 28 (12 U.S.C. 1831e)-- (A) in subsection (e)-- (i) in paragraph of United States , District
Court of Massachusetts, and therefore venue is proper in this district and in this Court pursuant
to 28 U.S.C. §1409(a). Defendants directly and/or indirectly engaged in the criminal wiretapping

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and/or sharing of illegally obtained, privileged and confidential information among
associate-in-fact Defendants, and conspired to commit acts which enumerate at Jeast 24 Federal
causes of action: (1)18 U.S.C. §2511(2)(d), (2) Violations of 18 USC Ch. 96 ~ RICO
Racketeering, (3) Violations of 18 U.S.C. §§ 891 to 896 - Loan Sharking, (4) Violations of 18
US.C. §873 - Extortion (5) Violations of 18 U.S.C. §1956 - Laundering of Monetary
Instruments, (6) Violations of 18 U.S.C. §1962 - Collection of Unlawful Debts and RICO
Conspiracy, (7) Violations of the Privacy Act of 1974, (8) Fifth Amendment Violation - Loss of
Property/Fear of Transfer, (9) Civil Rights Violation under 42 U.S.C. § 1985 -~ Conspiracy to
Deprive, (10) First Amendment Violation - Freedom of Expression and (11) Malicious
Prosecution under §1983 (12) Violations of Fifth Amendment Due Process Through Threats and
Coercion, (13) Fourteenth Amendment Violation - Loss of Privilege, (14) Civil Rights Violations
under 42 U.S.C. § 1983 ~ Discrimination, (15) Civil Rights Violations under 42 U.S.C. § 1983
and the Fifth and Fourteenth Amendments - Threat to Loss of Liberty, (16) Violations of 18 USC
1801 - Patriot ACT, (17) Violations of the 1933 Act, (18) Violations Of The Federal Computer
Fraud And Abuse Act 18 U.S.C. § 1030 (a-dd) (1-10), (19) Violations of the Federal Wiretap
Act, (20) Violations of 124 Stat, 1376 ~ Dodd-Frank Wall Street Reform and Consumer
Protection Act, (21) Violations of the American Anti-Corruption Act - AACA, (22) Violations of
the Electronic Communications Privacy Act of 1986 (ECPA), (23) Violations of 34 U.S.C.
§ 12601, and (24) Violations of 28 U.S. Code §455.
HE MINAL OBJECTI EF TH KE E RI
1. Plaintiffs allege that Defendants, the NE EDGE Racketeering Enterprise,
(‘Enterprise”), also known as the “RGPSQ Enterprise,” are liable for numerous violations of the
Racketeer Influenced and Corrupt Organizations ("RICO") Act (18 U.S.C.§1961, 1962 (c)(d),et
seq.) and (18 U.S.C. 1958(a)(b)(c)), 18 U.S.C §1964 (s,) 18 U.S. Code § 1951 - Interference with
commerce by threats or violence in addition to numerous federal law claims of breach of loan,
investment, extortion, loan sharking, wiretapping, electronic eavesdropping and unlawful

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vexatious debt collection activities.
2. Defendants are associates-in-fact involved in a RICO enterprise couched as shell
corporations like NE Edge, which “includes any individual, partnership, corporation, association,
or other legal entity, and any union or group of individuals associated in fact although not a legal
entity.” Browning v. Flexstee! Indus., Inc,, 955 F. Supp. 2d 900, 908 (N.D. Ind. 2013). This
association-in-fact Enterprise had been in the game long before targeting Plaintiffs, which they
did in furtherance of the tactical objective to conspire to expropriate Plaintiffs’ real estate and
technology interests, via methods including but not limited to extortion and wiretapping (fraud).
3. By and through a pattern of sophisticated, criminal, “gas lighting grand corruption
schemes” inside the Secret Courts of Massachusetts, perpetrated by the NE Edge Enterprise’s de
facto attorneys’ unclean hands and systemic judicial frauds on the courts, the Enterprise member
defendants have “pulled the strings” of certain members of the Boston Police, Suffolk Superior
Court, Boston Municipal Court and Orleans District Court.
4, Within these courts, judicial “insiders,” public officials and corrupted law enforcement
officers, conspired to frame Plaintiff Nicholas Fiorillo, for both fictitiously alleged financial
crimes, and an assault of Defendant Kevin Peters, which never took place. These individual
Defendants and the existing criminal group they had formed, acted in concert, by conspiring,
aiding and abetting each other, to usurp the Plaintiffs rights, title and interest in their valuable
digital infrastructure development rights, intellectual property rights, institutional self-storage
assets, and commercial/residential property interests.
5. | The NE Edge enterprise members conspired to loan-to-own Plaintiffs’ assets, through a
pattern of fraud, obstruction of justice, malicious prosecution, extortion, blackmail, wiretapping,
cyber spying, data theft, threats of bodily harm and murder. As part of the Enterprise’s patterned
acts, were unlawful and vexatious debt collection activities, culminating in a half dozen dubious
inextricably connected debt collection lawsuits being filed against Plaintiffs, across two different
states and three judicial court systems, all of which were and are entirely unlawful.

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6. Through a series of highly sophisticated, complex, fraudulently-purported loan sharking
lending /investment schemes, Defendants set out to “loan to own” and “bait & switch” Plaintiffs,
in order to usurp their financial assets, real estate and digital infrastructure development
business(s) and future development profits. The defendants’ willful participation in the NE Edge
Racketeering Enterprise, series of “loan to own” schemes and unlawful debt collection actions,
with deliberacy and malice, orchestrated to deprive certain interests of the Plaintiffs, by an
assertion of unlawful and predatory politically and judicially corrupt collection activities. These
patterned activities were designed to usurp Plaintiffs’ bona fide ownership in real estate, digital
infrastructure entitlement and development rights, and prior equitable monetary investment, and
constituted criminal acts.
7, Plaintiffs conduct their development business in the states of Connecticut,
Massachusetts, New Hampshire and Rhode Island, as well as in other states. The defendants live
in the states of Georgia, New York, Ohio, Rhode Island, Connecticut and Massachusetts, as well
as abroad.
8. These defendants have perpetrated a sophisticated racketeering conspiracy, to tortiously
interfere with, derail, and block Plaintiffs’ constitutional rights to due process of law and civil
rights to due process to defend and protect their development efforts of the Gotspace New
England Data Corridor. As a criminal group, the Enterprise Defendants are attempting to extort
and blackmail the release of the Plaintiffs Federal claims against them, to prevent the continued
“loaning to own" of their Gotspace Data and Ocean real estate, development rights, entitlements
and intellectual property.
9. Plaintiffs have invested substantially in, have worked diligently to obtain from the
State of Connecticut and certain local towns therein, and have ultimately received, valuable
municipal community host agreements, to construct data centers pursuant to the Gotspace land
purchase contracts with the Defendant land sellers, including John and Jane Does. The NE Edge

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Enterprise Defendants’ constant and relentless predatory collection activities, have obstructed
Plaintiffs’ ability to develop their valuable rights and title to their data campus sites, and receive
their specific state and local data tax incentive benefits critical to their commitments with
Connecticut’s various labor and construction unions, for the development of the Gotspace Data
Digital Infrastructure Master Plan of New England.
10. It is irrefutable that this unlawful group of individuals referenced herein as the NE
EDGE Enterprise, and its ring leaders, Raymond Green, Peter Spitalny, George Mclaughlin and
Thomas Quinn, along with their co-conspirators, including the Enterprise attorneys, are without
question a criminal group with a tactical understanding amongst members who continue to
unlawful financially decimate and financially bankrupt the Plaintiffs, and their Gotspace
Development Companies. These defendants have made repeated unlawful attempts to abscond
with all of the Plaintiffs intellectual property, real estate assets and exclusive rights to develop
the Gotspace New England Data corridor, in clear violation of the Racketeer Influenced And
Corrupt Organizations Act (RICO) (18 U.S.C. § 1961 et seq.) and have committed numerous
other federal crimes against Plaintiffs.
{l. The Defendants’ ongoing and unlawful racketeering conspiracy, was devised to strip
the plaintiffs of rightful ownership of their existing $100,000,000 million dollar commercial
self-storage assets and luxury single family development portfolio, along with Plaintiffs’ future
rights to upwards of $30,000,000,000.00 billion in hyper scale data center development
providing this region access to data storage, which is now at risk.
12. The sinister insurrection by NE Edge, to take control of and topple Gotspace Data and
usurp future control of the New England Data Corridor away from the Plaintiffs, is egregious and
unlawful. The NE Edge Enterprise’s intentional and reckless manipulation, tortious interference
and multifaceted conspiracy against the plaintiffs, remain focused on the objective of usurping
Gotspace Data’s exclusive and superior purchase contract rights, development rights, and
entitlements rights, and their potential for hundreds of millions of dollars in perpetual real estate

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income and equity creation, for the Company's stockholders.
13. The defendants have conspired together to act in concert as a criminal group or
Enterprise, and, in tacit agreement among its members, and with others known and unknown to
Plaintiffs, traveled in, and caused another to travel in interstate commerce, with the intent to
usurp, embezzie, launder and strip Plaintiffs’ deposit and investment monies, and usurp purchase
and development rights and intellectual property they bargained for, when they entered into
various contracts to purchase land, and other highly valuable real estate.
14. The NE Edge Enterprise defendants have committed numerous violations of
federal laws, in consideration for the receipt of, and as consideration for a promise and
agreement to pay, anything of pecuniary value, specifically United States currency, as those
terms are defined in Title 18, United States Code, Section 1958(b), ss 924(c)(1) 18 U.S. Code §
1951 - Interference with commetce by threats or violence.
15, Plaintiff Nicholas Fiorillo remains in fear of imminent bodily harm, unlawful arrest
and incarceration, as well as harm to his family, due to the violent threats by Defendants and
their judicial and political “insider” influence, well aware of the long-standing plan, conspired
with corrupt Boston Police Officers, stemming from a June 6" 2022 botched “sting”, named
“operation schoolhouse,” during which the NE Edge Enterprise defendant Kevin Peters used
Nicholas Fiorillo’s wife as “bait” to try to provoke an altercation to that an assault and battery
charge could be brought to coerce Fiorillo into “reaching settlement” with Peter’s clients. While
no such assault of Peters ever took place, a malicious criminal prosecution of Fiorillo was
commenced after the deposition of Fiorillo’s wife which resulted in her admission to the cardiac
unit of a local hospital and present evaluation for a pacemaker due to excessive anxiety and
stress.
16. Defendants, through their “investment lending” business dealings with one or more of
the plaintiffs, ultimately made fraudulent claims in relation to investment of capital for the
benefit of the Plaintiffs’ Real Estate holdings and development businesses: Gotspace Data,

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Ocean Development Precinct | et al; Ocean Development et al; W-Lofts Development LLC and;
BSI 254 Westfield St. LLC, et al.
17, The NE Edge Enterprise has defrauded Plaintiffs, by intentionally and fraudulently
deceiving them into forfeiting rights and claims to preferred stock, and equities of their various
companies, investments and bonafide equitable ownership of future development rights, to
Gotspace Data et al, Ocean Development et al, Gotspace Development et al, W-Lofts
Development LLC, and BSI 254 Westfield St. LLC, et al.. This particular scheme was put into
motion by way of an exchange for a promise by Defendants to Plaintiffs, of access to the
necessary capital required to complete their acquisition and future development objectives.
18. Under a “smoke and mirrors” joint venture partnership with Defendants, additional
fraudulent schemes were systematically “presented” to the plaintiffs. Then, after a critical,
so-called “partnership” formation ultimately turned out to be a set up, Defendants continued to
offer promises of “future” capital to the plaintiffs, always with a quid pro quo demand for
additional stock in the plaintiffs' development companies and real estate holdings, as well as cash
which was otherwise not due or owing to them.
19, These defendants never had any intent of honoring their representations to meet
capital investment requirements, yet the partnership continued on, with bad-faith negotiations of
multiple misrepresented loan agreements and fraudulent extension agreements, which Plaintiffs
were always presented with at “the last minute,” timed on the eve of foreclosure(s), default
notice(s), and brink of financial ruin. Plaintiff Nicholas Fiorillo and his family were always
under extreme financial duress, fearful of being financially ruined and on multiple occasions.
They have been unlawfully threatened with being prosecuted criminally for “crimes” they did
not commit and threatened with physical harm and even death.
20. By virtue of these predicate Racketeering Acts, Defendants have committed
federal crimes deemed gross financial negligence at best, and outright fraud in reality. These

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individuals knowingly proffered deceptive loan documents, only to prematurely demand
repayment, at sometimes as much as 1500%, including demand for stock, real estate and cash
which was not due or owing. Through their Rackerting “loan to own" Enterprise, these
Defendants have continued to tortiously interfere with the Plaintiffs ongoing businesses, future
development projects, and rights to upwards of $30,000,000,000 billion in development and
perpetual development profits.
21. Defendants maintain tactical contro! of the NE Edge Enterprise, through their willful
participation with Enterprise Attorney Defendants, in unlawful and concerted “loan shark
attacks” culminating in a series of unlawful, fraudulent, debt collection lawsuits. This criminal
Enterprise routinely obstructs justice, engages in wiretaps, witness tampering and extortionist
extensions of credit, followed by predatory collection of fraudulent credit loans, in violation of
Federal Law.
22. The NE Edge Enterprise continues to commit numerous Violations of the Racketeer
Influenced and Corrupt Organizations ("RICO") Act (18 U.S.C.§1961, 1962 (c)(d),et seq.) and
(18 U.S.C. 1958(a)(b)(c)), 18 U.S.C §1964 (s,) 18 U.S. Code § 1951, including but not limited to
interference with commerce by threats or violence, in addition to a multitude of federal law
claims, for breach of loan, money laundering and wire fraud.
Now come Plaintiffs and state as follows:
NATURE OF THIS CASE
23. This case involves a network of associates in fact, including convicted felons and loan
sharks and rogue law enforcement officers who employ patterns of criminal activity and
campaigns of misinformation to target legitimate companies and individuals with fabricated
claims of purported misconduct, inflicting millions of dollars in damage. The criminal network
hereinafter referred to alternatively, as “NE Edge Enterprise” and the “NSO Tech Enterprise.”

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(NSO Technologies, Q Cyber Technologies, Ltd. Technologies, OSY Technologies SARL,
Westbridge Technologies, Meta Platforms, Apple Inc., TMobile, and Cybrook, Inc.(Trackview)).
24. These respective defendant enterprises engaged in a pattern of criminal and other
misconduct, which includes but is not limited to (i) defrauding Plaintiff with claims of
delinquencies on “legitimate” investment notes; (ii)loan sharking schemes; (iii) intentional and
malicious interference with Plaintiff's business relationships; and (iv) threats of violence and
extortion and “kickback” schemes and; (v) Cyberattacks/data breaches and theft of intellectual
property by and through the Defendants’ cyber spying conspiracy, aiding and abetting,
deployment and thousands of systemic targeted cyber attacks of the Plaintiffs’ digital Apple
devices, operating on the various Apple iOS operating systems, by and through Apple Inc.’s
failure to protect its customers from the unlawful use, hosting, harboring and cyber phishing, and
the NSO/Cybrook, Inc. (Trackview) defendants’ “infiltration” of the Apple Inc iOS operating
systems’ enabling of the Pegasus spyware, to digitally violate and decimate via Israeli
cyber-arms company, NSO.
25. The defendants all willfully participated in or conspired with the NE Edge
Racketeering Enterprise’s series of “loan to own” schemes and unlawful debt collection actions,
with deliberacy and malice. These patterned schemes, orchestrated to deprive certain interests of
the Plaintiffs through perpetration of unlawful, predatory collection activities, were designed to
usurp bonafide ownership in real estate, digital infrastructure entitlement and development
rights, and prior equitable monetary investment. The subject matter of their lawsuit includes that
which "constitutes a claim of a right or title real property or the use and occupation thereof."
26. Defendants have made repeated unlawful attempts to abscond with all of the
Plaintiffs intellectual property, real estate assets and exclusive rights to develop the Gotspace
New England Data corridor, in clear multiple violations of the Racketeer Influenced And Corrupt
Organizations Act (RICO) (18 U.S.C. § 1961 et seq.) and have committed numerous other

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federal crimes against Plaintiffs. Defendant attorneys Nicholas Nesgos, Cameron Pease, and
Rachel Zoob-Hill have been working in concert since a case filed in early November of 2020,
seeking a monetary judgment the Plaintiff in that matter was not entitled to, sought in order to
leverage against Nicholas Fiorillo, based upon lies, witness tampering and deceit by all the
counsel involved in this action, in order to extort unlawful and usurious “settlement payments.”
27. Defendants Raymond Green, along with Samuel and Peter and Spitalny, have
been working with a group of attorneys including co-defendants Kevin Peters, Michael! Brier,
Nicholas Nesgos and George Mclaughlin, Jeffrey Hellman and Matthew Welnicki, utilizing their
contacts within various court systems to attempt to collect unlawful debt for their own self
enrichment. Their Modus Operandi of this Enterprise (MO), has been to intimidate, harass, and
position the direction of their debt collection activities unlawfully, through the Massachusetts
court systems through a systemic pattern of unlawful prosecution and judicial and political
corruption schemes. Plaintiff Nicholas Fiorillo never stood a chance to have his civil rights to a
fair and just hearing upheld in the lower courts, and each of the Federal violations set forth
within this Complaint must be remedied for the benefit of the basic rights and civil liberties
afforded to all Americans, found under the United States Constitution of America.
28. Nicholas Fiorillo, along with his immediate family and his business associates
have been victimized and cornered into a series of disadvantageous legal positions by these
Enterprise and the judicial and municipal defendants. This group has clearly, through their
various political connections, manipulated the Boston Municipal Court (Boston, MA.), Suffolk
County District Court (Boston, MA.), the Barnstable County District Court (Barnstable, MA.),
the Orleans District Court (Orleans, MA) as well as the U.S. Federal Bankruptcy Court (Boston,
MA).
29. The Plaintiffs have been denied their civil rights in the lower courts where there is
no remedy, recourse and redress against the despicable, systemic pattern of Grand Corruption
within the secret courts of the Commonwealth. This criminal Enterprise’s pattern of fraud,

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extortion, blackmail, wiretapping, threats of bodily harm and murder, as part of a pattern of
unlawful activities extending across two different states and three judicial court systems, are
wholly unlawful.
30. Plaintiffs have sustained significant financial damages, loss of real estate,
intellectual property and physical and emotional damages due to an ongoing pattern of
fraudulent racketeering conduct by NE Edge NE Edge members and their attorneys, led by
Nicholas Nesgos, George Mclaughlin, Kevin Peters, Mathew Welnikki and Jeffery Hellman,
aided at separate and specific times by the other attorneys named as defendants in this action.
These Enterprise defendants, including Thomas Quinn, Raymond C. Green, Peter Spitalny and
others, were aided and abetted by individual, municipal/udicial and corporate defendants,
including but not limited to: Samuel Spitainy, the NSO Group, Meta Platforms, Inc., Trackview,
Apple Inc., T-Mobile the “Boston Secret Court Judicial Insiders,” Boston Police Detectives Karl
Dugal and Michael Powers, Brian Sheehan, Lisa Serafin, Shawn Townsend, Stuart Bornstein and
Enterprise attorneys George Mclaughlin, Kevin Peters, Nicholas Nesgos, Matthew Welnicki and
Jeffrey Hellman, and John and Jane Doe defendants not known to the Plaintiffs at this time.
PARTIES
31. The Plaintiff, Gotspace LLC (“Gotspace”), is a Massachusetts Corporation with a
registered mailing address of 268 Newbury St., 4th Floor, Boston, MA, 02116.
32, The Plaintiff, Ocean Development Partners, LLC (“Ocean”), is a Massachusetts
Corporation with a registered mailing address of 268 Newbury St., 4th Floor, Boston, MA,
02116.
33. The Plaintiff Gotspace Development, LLC, is a Massachusetts Corporation with a
registered mailing address of 268 Newbury St., 4th Floor, Boston, MA, 02116.
34, The Plaintiff Ocean Development Partners Precinct I, LLC, is a Massachusetts
Corporation with a registered mailing address of 268 Newbury St., 4th Floor, Boston, MA,
02116.

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35. The Plaintiff Ocean Vacations Realty Trust, LLC, is a Massachusetts Corporation
with a registered mailing address of 268 Newbury St., 4th Floor, Boston, MA, 02116.
36, The Plaintiff Nicholas Fiorillo, Trustee, is a duly appointed trustee of Ocean
Vacations Realty Trust, and a resident of the Commonwealth with an address of 3 Kales Way,
Harwich Port, MA, 02646.
37, The Plaintiff Nicholas Fiorillo, is an individual with an address of 3 Kales Way,
Harwich Port, MA, 02646.
38, The Defendant, NE EDGE, LLC, is a Massachusetts Limited Liability Company,
with a principal office address of 54 Claremont Road, Belmont, MA, 02478.
39. The Defendant, NSO Group Technologies Limited, an Israeli limited liability
company with a principal office location in Herzliya, Israel, is a subsidiary of the Q Cyber
Technologies, Ltd., a technology group of companies subject to the jurisdiction of this Court,
with its Registered Agent, Joseph N Akrotirianakis, having a principal business location of King
& Spalding, LLP, 1180 Peachtree St NE, Atlanta, GA 30309. Upon information and belief, NSO
designs, develops, and manufactures highly invasive surveillance technology or spyware and
related products and services, including the Pegasus spyware.
40. Defendant Q Cyber Technologies, Ltd. was incorporated in Israel on December 2,
2013, under the name L.E.G.D. Company Ltd. On May 29, 2016, L.E.G.D. Company Ltd.
changed its name to Q Cyber Technologies, Ltd.. Until at least June 2019, NSO’s website stated
that NSO was “a Q Cyber Technologies, Ltd. Technologies company,” and NSO stated as
recently as July 2021 that NSO was a subsidiary of Q Cyber Technologies, Ltd.. Q Cyber
Technologies, Ltd. reportedly acts as a “commercial distributor” for NSO’s products, including
by signing contracts, issuing invoices, and receiving payments from NSO’s customers. Its
Registered Agent, Joseph N Akrotirianakis, has a principal business location of King &
Spalding, LLP, 1180 Peachtree St NE, Atlanta, GA 30309.

Case 1:23-cv-00121 Document1 Filed 03/27/23 Page 15 of 100 PagelD #: 15
41. The Defendant, OSY Technologies SARL, is Luxembourg-based subsidiary of
NSO Group, and holder of intellectual properties, which, with Q Cyber Technologies, Ltd.
Technologies and NSO Group Technologies, is billed as “a Consortium of cyber-spy companies
run by former Israeli Intelligence Officers,” with its Registered Agent, Joseph N Akrotirianakis,
having a principal business location of King & Spalding, LLP, 1180 Peachtree St NE, Atlanta,
GA 30309.
42. The Defendant, WestBridge Technologies Inc., is the marketing and sales arm of
NSO, with its principal place of business at 6701 Democracy Blvd, Suite #300, Bethesda,
Maryland 20817.
43. The Defendant, Meta Platforms, Inc., doing business as Meta and formerly named
Facebook, Inc., and TheFacebook, Inc., is an American multinational technology conglomerate,
is a publicly traded, for-profit company, incorporated in Delaware and with its principal place of
business at 1601 Willow Road, Menlo Park, CA 94025. Facebook’s principal businesses are in
technologies that facilitate digital interactions and communications, including Facebook Blue,
which provides personal social networking; Instagram, which provides personal social
networking; Facebook Messenger, which provides mobile messaging services; and WhatsApp,
which provides mobile messaging services.
44, The Defendant, Apple Inc., is a California corporation established in 1976, with
its principal place of business in Cupertino, California. Apple designs, manufactures, and
markets smartphones, personal computers, tablets, wearables, and accessories (e.g., iPhone, Mac,
iPad, Apple Watch, and Apple TV), as well as related services (e.g., iCloud, the App Store,
Apple Music, and Apple Pay).
45. The Defendant, T-Mobile Inc., is a California corporation established in 1976,
with its principal place of business in Cupertino, California.
46. The Defendant, Cybrook, Inc., a California corporation with a principal place of
business located at 2901 Tasman Drive # 107. Santa Clara, CA, is a high-tech company located

Case 1:23-cv-00121 Document 1 Filed 03/27/23 Page 16 of 100 PagelD # 16
in the heart of Silicon Valley that develops mobile security products and services, including the
company's flagship product is a cross-platform software app under the trademark of TrackView,
that connects smart-phones, tablets and computers into a mobile security network.
47, The Defendant, Stein Fibers, is a Company with a principal office address of 4
Computer Drive, Albany, New York, 12205, and also operates in North Carolina.
47.a. The Defendant, Aterian Investment Partners, is a New York Limited Liability
Partnership, with a principal place of business at 550 Fifth Avenue, 8th Floor, New York, NY
10036.
48. The Defendant, Ali Of Us At North, LLC, is a Massachusetts Limited Liability
Company, with a principal place of business at 297 North Street, Hyannis, MA 02601
49. The Defendant, Verde Group, LLC is a Connecticut Limited Liability Company,
with a business address of 150 Trumbull Street, 5th Fl., Hartford, CT, 06103.
50. The Defendant, Route 44 Development, LLC, is a Massachusetts Limited
Liability Company, with a principal place of business at 500 Harrison Ave., Suite 4R, c/o Charter
Environmental, Inc., Boston, MA, 02118.
SL. The Defendant Queen Anne, LLC, is a New Hampshire Limited Liability
Company, with a business address of 18 Old Farm Road, No. Conway, NH, 03860.
52. The Defendant, GF Funding Swansea, LLC, is a Massachusetts Limited Liability
Company, with a principal office address of 54 Claremont Road, Belmont, MA, 02478.
53. The Defendant, Rising Tides, LLC, is a Limited Liability Company, with a
principal place of business not known to Plaintiffs at the time of filing.
54, The Defendant, S&Q Data, LLC, is a Rhode Island limited liability company,
with a service of process address at 268 Newbury St., 4th Floor, Boston, MA, 02116.
55. The Defendant, S & J Storage Bros. LLC, is a Rhode Island limited liability
company, with a service of process address at 268 Newbury St., 4th Floor, Boston, MA, 02116.

Case 1:23-cv-00121 Document1 Filed 03/27/23 Page 17 of 100 PagelD #: 17
56. The Defendant, Crowd Lending, LLC, is a Massachusetts Limited Liability
Company, with a principal place of business at 218 Willard St Suite 301, Quincy, MA 02169.
37. The Defendant, City of Boston, is a municipal corporation created under the
laws of the Commonwealth of Massachusetts and at all relevant times hereto, employed the
defendants Officer Michael Powers and Detective Karl Dugal.
58. The Defendant Boston Police Department, is a law enforcement entity created
under the laws of the Commonwealth of Massachusetts with a primary location at | Schroeder
Plaza, Boston, MA 02120.
59. The Defendant Boston Municipal Court, is a Court of the Commonwealth of
Massachusetts, with a principal location at 24 New Chardon Street, Boston, MA 02114.
60. The Defendant, Mayor Michelle Wu, is and was at all times relevant, the Mayor
of the City of Boston. As such, she is responsible for the overall training and conduct of the
Boston Police Department. She is named individually and in her official capacity.
61. The Defendant, Kevin Hayden, is the District Attorney of the County of Suffolk,
State of Massachusetts. He is named individually and in his official capacity.
62. The Defendant, Police Officer Michael Powers, at all times relevant hereto was a
duly appointed officer of the Boston Police Department and a resident of the Commonwealth of
Massachusetts. He is named individually.
63. The Defendant, Detective Karl Dugal, at all times relevant hereto was a duly
appointed officer of the Boston Police Department and a resident of the Commonwealth of
Massachusetts. He is named individually.
64, The Defendants Michael Powers, Karl Dugal and Mayor Michelle Wu, were
acting under color of state law and pursuant to their authority as police officers and Mayor of the
City of Boston, in all actions alleged in this complaint.

Case 1:23-cv-00121 Document1 Filed 03/27/23 Page 18 of 100 PagelD #: 18
65. The Defendant, Kevin T. Peters, is an individual residing in Boston, County of
Suffolk, State of Massachusetts, with a principal place of business at 40 Broad Street, Boston,
MA 02109.
66, The Defendant, Omri Lavie, is a co-founder of NSO Technologies, who, upon
information and belief, is working out of the Washington, D.C. area with NSO’s American sales
arm, WestBridge Technologies, with a principal place of business located at 6701 Democracy
Blvd, Suite #300, Bethesda, Maryland 20817, with a Registered Agent for service, Joseph N
Akrotirianakis, having a principal business location of King & Spalding, LLP, 1180 Peachtree St
NE, Atlanta, GA 30309.
67. The Defendant, Shalev Hulio, is a co-founder of NSO Technologies, who, upon
information and belief, with Omri Lavie, are alumni of Israel’s Unit 8200 Signals Intelligence
Arm, with a Registered Agent for service, Joseph N Akrotirianakis, having a principal business
location of King & Spalding, LLP, 1180 Peachtree St NE, Atlanta, GA 30309.
68. The Defendant, Yaron Shohat, COO of NSO Technologies, has as a Registered
Agent for service, Joseph N Akrotirianakis, with a principal business location of King &
Spalding, LLP, 1180 Peachtree St NE, Atlanta, GA 30309.
69. The Defendant, Raymond C. Green, is an individual residing in Boston, County of
Suffolk, State of Massachusetts, with a principal business address of 155 Federal Street, Boston,
MA 02110.
70. The Defendant, Peter Spitalny, is an individual residing at 14 Pheasant Lane,
Albany, NY, 12204.
71. The Defendant, Samuel B. Spitalny, is an individual residing at 505 Overbrook
Drive, NW, Atlanta, Georgia 30318.
72. The Defendant, Stephen Quillinan (“Stephen”), is an individual residing at 25
Charlton Street, Apt. 115, Everett, MA 02149.

Case 1:23-cv-00121 Documenti Filed 03/27/23 Page 19 of 100 PagelD #: 19
B. The Defendant, Thomas Quinn (Quinn), is an individual residing at 426 Love
Lane, East Greenwich, CT 02818.
74, The Defendant, George Mclaughlin (“Mclaughlin”), is an individual residing at
54 Claremont Road, Belmont MA, 02478.
75. The Defendant, Daniel Mclaughlin, is an individual with a principal place of
business at 54 Claremont Road, Belmont, MA, 02478.
76. The Defendant, Daniel Najarian, is an individual with a principal place of
business at 218 Willard St Suite 301, Quincy, MA 02169.
77. The Defendant, Christopher Fiumara, is an individual with a principal place of
business at 218 Willard St Suite 301, Quincy, MA 02169.
78. The Defendant, W-Lofts, LLC, is a Rhode Island Limited Liability Company,
with a service of process address at 268 Newbury St., 4th Floor, Boston, MA, 02116.
79. The Defendant, BSI 254 Westfield, LLC, has as its Registered Agent, Eric
Everett, of Darrow Everett, 50 Congress Street, Ste. 1040, Boston, MA 02109.
80. The Defendant Biue Vista Capital Management, LLC Capital, is a Delaware
Corporation with principal operations at 254 Clark Street, Ste. 730, Chicago, IL 60654.
81. The Defendant, Nicholas Nesgos (“Nesgos”), is an individual with a principal
place of business at 80 Boylston Street, 32nd Floor, Boston, MA 02109.
8la. The Defendant, Cameron Pease, is an individual with a principal place of business
at 160 Gould Street, Suite 320, Needham, MA 02494.
81b. The Defendant, Rachel Zoob-Hill, is an individual with a principal place of
business at 160 Gould Street, Suite 320, Needham, MA 02494,
82. The Defendant, Stuart Bornstein, is an individual with a principal place of
business at 297 North Street, Hyannis, MA 02601.
82a. The Defendant, Eliot Gersten, is an individual with a principal place of business
at 214 Main Street, Hartford, CT 06106.

Case 1:23-cv-00121 Document1 Filed 03/27/23 Page 20 of 100 PageiD #: 20
82b. The Defendant, John Beck, is an individual with a principal place of business at
Proskauer Rose, LLP, | International Pl, Boston, MA 02110.
83. The Defendant, Jeffrey Hellman (“Hellman”), is an individual with a principal
place of business at 195 Church Street, 10th Floor, New Haven, CT 06570.
84. The Defendant, Brian Sheehan (“Sheehan”), is an individual residing at 296
Mason Terrace, Brookline, MA 02446.
85. The Defendant, Lisa Serafin (“Serafin”), is an individual residing at 296 Mason
Terrace, Brookline, MA 02446.
85a. The Defendant, James Stoller (“Stoller”), is
86. The Defendant, Shawn Townsend (“Townsend”), is an individual with principal
operations at 254 Clark Street, Ste. 730, Chicago, IL 60654.
87. The Defendant, Rachel Fox, (“Fox”) is an individual with principal operations at
254 Clark Street, Ste. 730, Chicago, IL 60654.
88. The Defendant, Matthew Welnicki, is an individual with a principal place of
business at 10 High Street, Boston, MA 02110.
89. The Defendant, Michael P. Sams, is an individual with a principal place of
business at 10 High Street, Boston, MA 02110.
89.a The Defendant, Mark Block, is an individual with a principal place of business at
138 Main Street, Norwich, CT 06360.
90. The Defendant, Alfred Demirjian, is an individual with a principal place of
business at 87 Blanchard Road, Floor 2, Cambridge, MA 02138.
91. The Defendant, TechFusion, a cyber security data recovery company which has
operated for over three decades, is a Massachusetts Limited Liability Company, with a principal
business address of 87 Blanchard Rd., Cambridge, MA 02138.
92. The Defendant, Edward S. Jurczyk, is an individual residing at 28 Beverly Road,
Milford, Connecticut 06461.

Case 1:23-cv-00121 Documenti Filed 03/27/23 Page 21 of 100 PagelD #: 21
93. The Defendant, Katherine M. Jurezyk, is an individual residing at 28 Beverly
Road, Milford, Connecticut 06461.
94. The Defendant, Kenneth Kogut, is an individual residing at 84 Tankwood Road,
Wallingford, CT 06492.
95. The Defendant, Gray Leland Jr, is an individual with a principal business address
of: c/o Russell Wehner, 34 Power House Road, Uncasville, CT 06382.
96. The Defendant, William R. Smith IJ, is an individual! residing at 15 Kramer Road,
Colchester, CT 06415.
97. The Defendant, Joyce P. Werbiski, is an individual with a principal place of
business at 1069 North Farms Road, Wallingford, CT 06492.
98. The Defendant, Walter Werbiski, is an individual with a principal place of
business at 1069 North Farms Road, Wallingford, CT 06492.
99. The Defendant, Carl L. Zorn, is an individual residing at 3 Fawn Place, Bozrah,
CT 06067.
100. The Defendant, Deborah L. Zorn, is an individual residing at 3 Fawn Place,
Bozrah, CT 06067.
101. The Defendant, 429 Barnes Road LLC, is a Connecticut Limited Liability
Company, with a principal office address of 421 Barnes Road, Wallingford, CT 06492.
102. The Defendant, Barnes Road Farm Realty, LLC, is a Connecticut Limited
Liability Company, with a principal office address of 421 Barnes Road, Wallingford, CT 06492.
103. The Defendant, 421 Barnes Road LLC, is a Connecticut Limited Liability
Company, with a principal office address of 421 Barnes Road, Wallingford, CT 06492.
104. The Defendant, Connecticut Attorneys Title Insurance Company (“CATIC”), is a
Connecticut Limited Liability Company, with a principal office address of 101 Corporate Place,
Rocky Hill, CT 06067.

Case 1:23-cv-00121 Document 1 Filed 03/27/23 Page 22 of 100 PagelD #: 22
105. The Defendant, Downes-Patterson Corporation, is a Connecticut Limited Liability
Company, with a principal mailing address of c/o Waterford Group L.L.C., 914 Hartford
Turnpike, Waterford, CT 06385.
106. The Defendant, GBGB LLC Living Trust, is a Florida Trust with a mailing
address of 418 North Federal Hwy Suite 18, Lake Worth, Florida 33460.
107. The Defendant, 327-449 Hazelnut, LLC, is a Connecticut Limited Liability
Company, with a principal mailing address of % John P. Holstein, 12 Roosevelt Avenue, Mystic,
Connecticut.
108. The Defendant, JG] Development LLC, is a Connecticut Limited Liability
Company, with a principal mailing address of c/o Pasquale Camputaro, Jr., 1293 Norwich Road,
Plainfield, Connecticut 06374-1930.
109. The Defendant, Kamm Realty, LLC, is a Florida Limited Liability Company, with
a principal office address of 8341 Glenfinnan Circle, Fort Myers, FL 33912.
110. The Defendant, Midwood Management Corporation, is a Connecticut Limited
Liability Company, with a principal business address of 430 Park Avenue, Suite 201, New York,
NY 10022.
ill. The Defendant, Norwich Innovations, is a Connecticut Limited Liability
Company, with a principal mailing address of % Robert Cappelletti, 46 Reder Road, Northfield,
Connecticut.
112. The Defendant, Tankwood Farm Realty LLC, is a Connecticut Limited Liability
Company, with a principal office address of 421 Barnes Road, Wallingford, CT 06492.
113. Upon information and belief, John and Jane Does are sellers of Connecticut
properties, officers of the Boston Police Department, members of the Boston Municipal Court,
Suffolk District Attorneys’ Office, and others.
JURISDICTION

Case 1:23-cv-00121 Document1 Filed 03/27/23 Page 23 of 100 PagelD #: 23
114. This action is brought under 42 U.S.C. § 1983 and the Fourth, Fifth, Eighth and
Fourteenth amendments of the United States Constitution. Jurisdiction is founded on 28 U.S.C.
§§ 1331 and 1343.
115. This Court has subject matter jurisdiction under 28 U.S.C. § 1331 as the cause of
action arises under federal statute, to wit, the Computer Fraud and Abuse Act, 18 U.S.C. § 1030.
116. The United States Code of federal proceedings arising in or related to cases under
such of the United States Code, and this proceeding may be commenced and prosecuted in the
District Court of Massachusetts. This matter is a core proceeding as defined in 28 U.S.C.
§157(b)(2)(H), and is brought pursuant 18 U.S.C. §1964(c).
117. The Court has personal jurisdiction over corporate Defendants because they
operate in the United States, have obtained financing and investments from corporate America,
have US based business interests, aka NSO-Westbridge technologies the sales arm of North
America, who have directed and targeted their “cyber spying” actions at U.S. consumers who
purchase goods and services from U.S. businesses, like Apple Inc. In addition, the claims in this
Complaint arise from Defendants’ actions in Massachusetts, tortious conduct directed at and
causing harm in Massachusetts, and systematic and continuous contact with Massachusetts,
including NSO, Trackview, Apple, and T-Mobile, the tech Defendants’, unlawful cyber spying,
unlawful infiltration and cyber phishing and 700 million megabytes of data and use of Fiorillo’s
Apple account, which is maintained on servers located in Massachusetts.
118. Moreover, NSO Defendants’ malicious and harmful activities brought them well
within the long arm of the law and the jurisdiction of this Court, which has the authority to hold
them to account for their violations of U.S. federal and Massachusetts laws and for the damages
they have inflicted on Plaintiffs.
119. NSO Defendants design, develop, manufacture, market, distribute, and operate
various surveillance technology, including malware, spyware, and other hacking devices

Case 1:23-cv-00121 Documenti Filed 03/27/23 Page 24 of 100 PagelD #: 24
designed to secretly intercept and extract information and communications from mobile phones
and electronic devices. NSO Defendants’ products include highly invasive spyware known as
“Pegasus,” described as “a world-leading cyber intelligence solution that enables the end user to
remotely and covertly extract valuable intelligence from virtually any mobile device.”
FACTUAL ALLEGATIONS
120. The Enterprise, led by Raymomd Green and Peter Spitalny, with the help of
Alfred Demirjian, utilized this sophisticated digital surveillance software and related equipment
to wiretap his electronic devices and spy on him, his family and his business associates, starting
as far back as December 2020, actively distributing the Fiorillo’s private and confidential
information amongst the other members of the Enterprise.
121. The Enterprise’s ongoing wiretaps enabled their egregious pattern of intimidation,
obstruction of justice and unlawful eavesdropping, motivated by a desire to financially destroy
and silence the Fiorillos, These defendants have broken numerous Federal and State laws in their
relentless and unlawful pursuit of Fiorillo’s assets and business interests.
122. Defendants Blue Vista Capital Management, LLC, Townsend, Fox, Sheehan and
Serafin (Mrs. Sheehan), intentionally misrepresented to Plaintiff Nicholas Fiorillo over a period
of 18 months, their ability to quickly obtain loan commitments for upwards of $150,000,000,
from Blue Vista Capital Management, LLC and the Sheehans’ Capstack Mortgage Brokerage
Company, for the entire first phase of the data development project.
123. These defendants intentionally steered Fiorillo right into their predatory lending
trap, with a continued pattern of fraudulent representation of loan commitments, and the
promised certainty that “big money” was always just four to six weeks away, was used as
additional “bait,” to induce Fiorillo, in detrimental reliance, to turn over ownership shares of his
Company’s Gotspace Data Equity Fund, and upwards of 300% interest returns, to the
Defendants.

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124. The pattern of fraudulent manipulation from Fiorillo’s so-called “commercial
mortgage brokers,’ Sheehan and Townsend, and the rest of the Enterprise defendants, was
clearly predatory in nature, and