First Amended Complaint "ALTER EGO, Pierce The Corporate Veil" MOWAT v. DJSP Enterprises

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First Amended Complaint “ALTER EGO, Pierce The Corporate Veil” MOWAT v. DJSP Enterprises

First Amended Complaint “ALTER EGO, Pierce The Corporate Veil” MOWAT v. DJSP Enterprises

Excerpts:

COUNT I

Alter Ego – Piercing the Corporate Veil of DJSP BVI

99. The Plaintiffs, on behalf of themselves and other persons similarly situated, repeat and reallege
the allegations of the preceding paragraphs as if fully restated herein.

100. As alleged above, at all relevant times herein, DJSP BVI, by its complete exercise of
dominion and control, is the alter ego of DJSP FL, DAL Group and its operating subsidiaries
DJS Processing, Professional Title, and Default Servicing, which constitute a single employer.
Indeed, as set forth above, there is a high interdependency of operations; there is commonality
between management, directors and officers; there is a consolidation of financial, strategic, legal
and human resources operations; and, at all relevant times, DJSP BVI has used and continued to
use DAL Group and its operating subsidiaries and the assets of these entities for its own
purposes.

COUNT II

Alter Ego – Stern

103. The Plaintiffs, on behalf of themselves and other persons similarly situated, repeat and reallege
the allegations in paragraphs one through eighty-five (1-85) as if fully restated herein.

104. As alleged above, at all relevant times herein Stern, by his complete exercise of dominion
and control over said entities, is the alter ego of DJSPA, DJSP BVI, DJSP FL, DAL Group and
its operating subsidiaries DJS Processing, Professional Title, and Default Servicing. The
foregoing entities combine to constitute a single employer, all under the direction and control of
Stern personally. Indeed, as set forth above, there is a high interdependency of operations; there
is commonality between management, directors and officers; there is a consolidation of financial,
strategic, legal and human resources operations; and, at all relevant times, Stern has used and
continued to use DJSPA, DJSP BVI, DJSP FL, DAL Group and its operating subsidiaries and the
assets of these entities for his own purposes.

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2 Responses to “First Amended Complaint “ALTER EGO, Pierce The Corporate Veil” MOWAT v. DJSP Enterprises”

  1. IRIS says:

    I KNEW THE LORD JESUS WILL OCM FOWARD, I KNEW HE HAD EVERYTHING UNDER CONTROL, I KNEW HIS PROMISES ARE REAL, I KNEW ALL THE EVIL DOERS WILL FACE THE DISCIPLINE OF THE LORD JESUS.

    THANK U GOD, THANK THANK THANK THANK
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    MILLIONS OF TIMES.

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