From: b.daviesmd6605

COMPLAINT:

COMES the State of Tennessee ex rel. Barrett Bates, on behalf of real parties in interest, the counties of the State of Tennessee, above-named and hereby complains of Defendants as follows:

STATEMENT OF THE CASE
Plaintiff Barrett Bates seeks recovery pursuant to Tenn. Code Ann. § 4-18-103, the False Claims Act, because Defendants made false representations in order to avoid payment in full of all recording fees reflecting the establishment and/or transfer of secured interests in real property in the State. After having recorded false, fraudulent, misleading and untruthful documents with the land records of the counties of this State, Defendants intentionally failed to cure/correct said false, misleading and untruthful documents and further failed to record subsequent assignments, deeds and other documents evidencing accurate changes in ownership interests in real property and, thereby, avoided, decreased and/or diminished their obligation to pay fees or monies to the counties of the State of Tennessee, the above-named real parties in interest.

PARTIES
1. Barrett Bates, relator, is a resident of the State of Nevada and an original source of information and authorized to bring this action pursuant to Tenn. Code Ann. § 4-18-101, et seq., and as the qui tam Plaintiff because Bates has worked in the secondary mortgage market business and, during the course of his work in June 2009, became aware Defendants were concealing and avoiding the payment of recording fees or other monies to the above-named counties in this and other states and brings this action under Tenn. Code Ann. G 4-18-103 against Defendants for violations of these sections.

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