Some of the documents related to the lawsuit Dinar Corp filed against Sterling last year,

I think some of this is different that what we have already seen.

There are 32 pages.  Peruse slowly.


https://www.iraqidinar.org/dci/149-1/r3-exhibit-1to5-6979658-1--20347ab.pdf

It appears to be documents related to the lawsuit Dinar Corp filed against Sterling last year, specifically Sterling's response to Dinar Corp's allegations/questions in the discovery process. It does not appear to have anything to do with the Federal actions against either company. Note the case number...

Dinar Corp, Inc. et al v. Sterling Currency Group, LLC et al
Georgia Northern District Court, Case No. 1:14-cv-00714
District Judge Amy Totenberg, presiding

Looks like it was originally filed in Nevada in 2013.

https://www.iraqidinar.org/dinar-corp-complaint/



Dinar Corp Complaint Review

  Our review shows that Husam Tayeh, owner of Dinar Corp, Inc. (DCI), filed a lawsuit against Sterling Currency Group (SCG) (excerpt from Case 2:13-cv-02106-APG-PAL) on 11/22/2013 stating “Defamation, Business Disparagement, False Advertising and Unfair Competition under the Lanham Act, False Light Invasion of Privacy, Tortious Interference with Current and Prospective Business Relationships, Aiding and Abetting Defamation, and Conspiracy”:

NOTE! Not too long after Dinar Corp filed this amended complaint with mention of money laundering in item 78 below, the FBI and US Marshall’s office raided Sterling Currency Group & Ty Rhame’s property in Georgia and also filed a Federal Complaint concerning money laundering against Sterling and others!

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA
DINAR CORP, INC., a Nevada corporation; and HUSAM TAYEH, an individual, Plaintiffs,
vs.
STERLING CURRENCY GROUP, LLC, dba DINAR BANKER; TYSON RHAME and JANE DOE RHAME, husband and wife; FRANK BELL and JANE DOE BELL, husband and wife; JORDAN DOE and JANE DOE, husband and wife; MATTHEW ADAMS and JANE DOE ADAMS, husband and wife; MARK DILEO and JANE DOE DILEO, husband and wife; TAMER DENIZ and JANE DOE DENIZ, husband and wife; DOE DEFENDANTS I-X, INCLUSIVE; and ROE DEFENDANTS I-X, INCLUSIVE. Defendants.
Dinar Corp. Inc. et al v. Sterling Currency Group, LLC et al
Assigned to: Judge Amy Totenberg
Demand: $75,000
Case in other court: Nevada, 2:13-cv-02106
Cause: 28:1332 Diversity-Fraud
Date Filed: 08/15/2014
Jury Demand: Both

Nature of Suit: 370 Fraud or Truth-In-Lending
Jurisdiction: Diversity

New Dinar Corp Complaint requested
A Motion to Amend Amended Dinar Corp Complaint was entered. Basically, Dinar Corp found new evidence and is asking the judge to allow adding it to the case (it was allowed), stating:
IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION
No. 1:14-cv-00714-AT

DINAR CORP, INC., a Nevada corporation; and HUSAM TAYEH, an individual,
Plaintiffs,
vs.
STERLING CURRENCY GROUP, LLC, dba DINAR BANKER; TYSON RHAME; FRANK BELL; JORDAN DOE; MATTHEW ADAMS; and MARK DILEO,
Defendants.

MOTION FOR LEAVE TO FILE AMENDED COMPLAINT
Pursuant to Fed.R.Civ.P. 15(a)(2), DINAR CORP, INC. (“DCI”) and HUSAM TAYEH (“Sam”) (collectively “Plaintiffs”), by and through counsel, respectfully request that the Court enter an order allowing Plaintiffs to file an amended complaint for the purposes of adding a fraud claim against Defendants, as well as supplementing the applicable factual allegations. The proposed Second Amended Complaint (“SAC”) has been attached to Exhibit “A” hereto and is incorporated herein by this reference. This Motion is supported by the following Memorandum of Points and Authorities and all pleadings and documents on file with the Court, which are all hereby incorporated by reference.

MEMORANDUM OF POINTS AND AUTHORITIES

I. Background; Relevant Facts.
DCI owns a website, dinarcorp.com, which provides customers with a safe and reliable means to acquire new Iraqi Dinar currency. Sterling Currency Group, LLC (“SCG”) owns a similar website, sterlingcurrencygroup.com (which was previously dinarbanker.com), and is one of DCI’s largest competitors. For approximately two years, SCG and the other Defendants have defamed and unfairly competed with Plaintiffs.

This matter was initially filed in the United States District Court for the District of Nevada (2:13-cv-02106-APG-PAL (“Nevada Action”)) and was then transferred to this District. However, prior to the case being transferred to this District, the Nevada Court permitted the parties to engage in limited discovery, during which Plaintiffs learned that Defendants had been purchasing currency from DCI for over a year, and that this was being done to obtain information that Defendants could use to interfere with Plaintiffs’ business, defame and unfairly compete with Plaintiffs.

On approximately 25 occasions, over the last year, Defendants, by and through Frank Bell (“Bell”), induced DCI to sell currency to Defendants, as well as provide Defendants with sensitive information (including bank account information), by misrepresenting Bell as a legitimate customer. Bell induced DCI to enter into the transactions by using fake names and different addresses located throughout the country. Defendants then used the fraudulently obtained information to send false, misleading, and defamatory information to various banking institutions with whom Plaintiffs did business (the “Banks”), the Better Business Bureau (“BBB”), and various regulatory agencies (the “Agencies”).

NOTE: See [url=https://www.iraqidinar.org/websites-discovered-promoting-sterling-currency-group#Frank Bell]mention of Frank Bell in Counter-Lawsuit[/url] against Sterling by Maurer.

Defendants’ purpose and intent with sending false, misleading and defamatory information to the Banks was to cause the Banks to cease doing business with DCI in an attempt to limit the amount of orders DCI was able to process thereby driving those customers to do business with SCG. Similarly, by filing various complaints with the BBB, which utilized the fraudulently obtained information in conjunction with false and misleading statements, Defendants turned DCI’s “A” rating with the BBB to an “F” rating. Additionally, SCG would use the fraudulently obtained information when sending false and misleading information to all conceivable Agencies that could cause Plaintiffs to suffer further business interruptions or lost profits. Notably, when reporting to many Agencies, SCG would cite to the “F” rating by the BBB that SCG fraudulently created.

II. Legal Analysis.
Federal Rule of Civil Procedure 15(a)(1) states that an amendment is a matter of course until the amending party is served with a responsive pleading, or within 21 days of being served, if a trial date is not yet set. Fed.R.Civ.P. 15(a). However, “[i]n all other cases, a party may amend its pleading only with the opposing party’s written consent or the court’s leave. The court should freely give leave when justice so requires.” Id. at 15(a)(2). “There must be a substantial reason to deny a motion to amend.” Laurie v. Alabama Court of Criminal Appeals, 256 F.3d 1266, 1274 (11th Cir.2001).

However, where the motion to amend is filed after the deadline of district court’s scheduling order, Rule 16(b) imposes a further “good cause” requirement on the party seeking to amend. Fed. R. Civ. P. 16(b)(4) (“A schedule may be modified only for good cause and with the judge’s consent.”); Sosa v. Airprint Sys., Inc., 133 F.3d 1417, 1419 (11th Cir.1998) (“If we considered only Rule 15(a) without regard to Rule 16(b), we would render scheduling orders meaningless and effectively would read Rule 16(b) and its good cause requirement out of the Federal Rules of Civil Procedure.”).

Because Plaintiffs are seeking leave of the Court well before the 30 day deadline set forth in the Joint Preliminary Report and Discovery Plan (“JPRDS”, Doc. 26), it appears Plaintiffs need not demonstrate good cause. Moreover, to the extent good cause is required, the circumstances demonstrate that good cause exists: (1) Plaintiff is only adding one substantive claim, which is based upon information not previously available; and (2) a claim for fraud has a four-year statute of limitations, and the alleged fraud transpired within the last four years.¹


III. Conclusion.
Therefore, based upon the foregoing, Plaintiffs respectfully request that the Court enter an order allowing Plaintiffs to file the SAC, attached to Exhibit A hereto, and granting such other and further relief as the Court finds reasonable and necessary.
¹Where, as here, there is an allegation of fraud, however, the statute of limitations is tolled until such time as the fraudulent conduct was discovered, or by exercise of due diligence ought to have been discovered. OCGA §§ 9-3-96; 9-3-98; Shipman v. Horizon Corp., 245 Ga. 808, 267 S.E.2d 244 (1980); Jones v. Spindel, 239 Ga. 68, 235 S.E.2d 486 (1977); Saffold v. Scarborough, 91 Ga.App. 628, 86 S.E.2d 649 (1955).

Respectfully submitted this 5th day of November, 2014.

/s/Daniel R. Warner
Daniel R. Warner
Kelly / Warner, PLLC
8283 N. Hayden Road, Ste. 229
Scottsdale, AZ 85258
Phone: (480) 331-9397
Facsimile: (866) 961-4984
dan@kellywarnerlaw.com
and
/s/ Alycen A. Moss
Alycen A. Moss
Georgia Bar No. 002598
Cozen O’Connor
303 Peachtree Street, N.E., Ste. 2200
Atlanta, GA 30308
Phone: (404) 572-2052
Facsimile: (877) 728-1396
Email: amoss@cozen.com
Attorneys for Plaintiffs Dinar Corp., Inc. and Husam Tayeh

CERTIFICATE OF SERVICE
I hereby certify that the foregoing pleading, on the date stated below, was filed with the Clerk of the Court using the CM/ECF system, which automatically and contemporaneously sends electronic notification and a service copy of such filing to the following counsel of record:

David M. Lilenfeld
Robin L. Gentry
2970 Peachtree Road, NW, Suite 530
Atlanta, Georgia 30305
david@lilenfeldpc.com
robin@lilenfeldpc.com
Dated: November 5, 2014.
/s/Daniel R. Warner, Attorney for Plaintiffs

Actually the Federal charges were filed and the raids occurred about a year and a half later.

I really hope that this is only the tip of the iceberg and that not only are the rest of the dealers being investigated for possible prosecution but I REALLY hope the gurus are in the FBI's sights! Nothing would would make me happier than to see these scum doing the perp-walk with their thieving hands in cuffs!!!!!!!!