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RAMESH SARVA: United States Of America, ...: United States Of America, Oct. 9th 2013 Plantiff, g their customers to falsely claim tax deductions to which they ar

2 not entitled.

3

4 JURISDICTION AND VENUE

5 7. This Court has jurisdiction under 28 U.S.C. §§ 1340 and 1345, an

6 I.R.C. §§ 7402(a).

7 8. This action for injunctive relief is brought at the request of the Chie

· 8 Counsel of the Internal Revenue Service, a delegate of the Secretary of th

9 Treasury, and commenced at the direction of a delegate of the Attorney General o

10 the United States, pursuant to I.R.C. §§ 7402 and 7408.

11 9. Venue is proper in this Court under 28 U.S.C. § 1391(b) because

12 substantial part of the events giving rise to this suit took place in this district. Th

13 Court has personal jurisdiction over all named defendants, including those no

14 domiciled in this jurisdiction, because the claims asserted against them arise out o

15 events that took place in this district, and because it was foreseeable they would b

;L6 sued in this district.

17

is THE PARTIES

19 10. Defendant Elliott is a resident of Rancho Santa Margarita, California.

20 Besides his employment with Sea Nine, Elliott conducts business relevant to th

i1 claims in this lawsuit through a variety of entities that he set up for administrativ

22 purposes (e.g. to enable him to separate income streams he derives for the differen

23 kinds of work and services he generally provides through Sea Nine) .

.24 11. Defendant Sea Nine is a Nevada corporation founded by Stephe

'25 Ross. After Ross's death in 2000, ownership and formal control of Sea Nine passe

26 to his widow, Sylvia Ross Calhoun. Elliott (via a management contract betwee

27

28

4

10296991.1 ...

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RAMESH SARVA