Shaheryar Khan
`2219 W. Olive Ave
`Burbank Ca 91506
`818-433-1823
`
`~ Shaheryar, Khan IN PRO PER
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`~ILcD
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`2Q21 hF'~ -1 ~~ 2~ 31
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`~.,,~•
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`UNITED STATES DISTRICT COURT
`
`CENTRAL DISTRCT OF CALIFORNIA
`
`SHAHERYAR KHAN, S)
`
`L n Cif ['~ ~- ~ O ~ O —VTR '" ~r~~ T~L
`
`Plaintiff(s),
`
`vs.
`
`) Complaint
`1.) BREACH OF CONTRACT
`) 2.) COPYRIGHT INFRIGMENT
`3.) FRAUD
`KENT SETON; ADAM KRAEMER; EDWARD) 4.) OBSTRUCTION OF JUSTICE
`CHARLES FOUNDATION, THRONE; DOES 1-)
`5.) SPOILATION OF EVIDENCE
`10 ROES 1-10,000(S),
`) 6.) CONSPIRACY
`~~`~.
`7.) CORPORATE ESPIONAG~ 7
`8.) CONFLICT OF INTREST
`~~
`~~
`
`Defendant(s).
`
`)
`
`Complaint
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`Plaintiff Shahryar Khan, complains against Defendant Adam Kramer, Edward Charles Foundation,
`and DOES 1-10,000 and Roes 1, 10000.
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`Parties
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`1.) Plaintiff Shaheryar Khan is an individual who is currently and was at all relevant times a
`resident a state of California and had residence in Los Angeles county City of Los Angeles.
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`2.) defendant Adam Kraemer is an individual who was at all relevant times a resident of the state of
`California as far as the plaintiff is aware.
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`3.) Defendant Throne Is a corporation working in California when the relevant events and times
`occurred
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`4.) Defendant Kent Seaton is an individual who was at all relevant times a resident of the state of
`California as far as the plaintiff is aware.
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`5.) Defendant Edward Charles Foundation is a corporation who was at all relevant times doing
`business in of the state of California as far as the plaintiff is awaze.
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`6.) The names and capacitates whether individual, corporate, associate or other wise of the
`defendants and or their alter egos aze sued herein as DOES 1- 10000 and ROES BUSINESS
`ENTITIES 1-10000, inclusive aze presently unknown and Plaintiff will amend this complaint to
`insert the names when ascertained. Khan also due to events where these defendant's spoliation
`evidence will add additional facts and allegations as well as other parties to this case with he the
`courts permission.
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`Facts
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`Plaintiff is the owner of intellectual property named in this complaint as A to Z and was authorized
`to conduct business and to assign the temporary usage of rights through a license of intellectual
`property and their goals as amended to conduct the relevant business activities along with khan's
`partners whom did not have the authority to act on their own against khan's goals without his
`consent. This consent would need to agreements of all partners and khan.
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`Since 2000 plaintiff has engaged in business activities and has had them misappropriated without
`consent. Plaintiff was unaware of who or whom was infringing on the intellectual property and
`trade secrets and copyrights. Plaintiff developed technology, trade secrets used in a copyright in late
`2000. Plaintiff also came up with ideas, technology copyrights and trade secrets to develop
`technology and copyrights and algorithms and used in loss mitigation and software in 2008. On or
`about December 28th 2016 Defendant Adam Kraemer in Los Angeles after conferring with Adam
`Kraemer after khan was referred to Kraemer by Brian Seigrist an associate of khan. Khan met Brian
`Seigrist as Khan developed a real estate soflwaze and Business model back in 2008. Khan found it
`odd that creamer had been asking questions and had concerns Kraemer was copying khan. he was
`claiming he had a service business relevant a different business khan after khan would say his ideas
`but did not declaze so prior to their engagements khan developed these models back in 2000
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`Kramer was referred to Shahryar khan to aid the plaintiff to develop plaintiffl s business model and
`plan to deliver and create and implement khans Platform to be initially used methods for execution
`which were to be applied to platforms using his methods and technology. Kraemer then referred
`khan to meet with Kent Seaton to consult with to develop the appropriate strategies to develop his
`business entities to use khan methods and develop khan's business.
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`Khan and Kent Seaton entered into an agreement and also included Edward Charles Foundation.
`Kraemer and Seaton were both paid a consulting fee by khan to help him with the development of
`the IP and Copyright agreed to be performed by Khan. Khan a conversation and khan Gottlieb had
`agreed to work on khan ideas and concepts to develop them as they had been doing for over 20
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`yeazs.
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`The defendants Kraemer and Seton were paid consultants and also entered into an agreement to
`conduct business on 1/10/17 and itemized those details or about 3/16/17.
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`Due to the plaintiffl s inability to access information plaintiff relied on the advice of the consultants
`to help him execute the business. Khan was unawaze at that time of the defendant's intent and
`continuation of a conspiracy he had been involved in spanning over 20 years to harm the plaintiff.
`Defendant Adam Kraemer sole purpose was to infringe on Shaheryar Khans intellectual property,
`trade secrets and copyrights. After years of questions on who was hacking Khan. It became evident
`that Kraemer and his accomplices had been tracking khan and using conflict of interest fraudulent
`tactics to mislead khan into signing non-beneficial contract based on their advice and
`recommendations which is not what was requested by khan to be devised. This advice had an
`ulterior motive to legally steal from khan and have a private benefit to embezzle these right and
`ownership that khan owned to transfer illegally to these conspirators and the defendants in this
`action. Khan had signed a contract and had language that referred to privacy in this language to
`infringing on the rights of khan. Khan realized later that Kramer was stealing his ideas when on
`June 29th 2018 these emails were being deleted after Kramer denied copying khans copyrights.
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`On or about April 7th, 2017 Adam Kramer violated the copyrights of khans and illegally and
`immediately purport rated this fraud. when he was copying khans copyright and intellectual
`property onto his companies site after khans was telling him what khan had or was developing. On
`or shortly after this date the defendant started to secretly develop these strategies using khans,
`business income, intellectual property and violated the licensing agreement that was produced to
`ties khan and the defendants to the privacy and infringement issues. Khans contract with Seton and
`ECF which was developed in bad faith by the defendants was terminated on or about May 2017.
`This contract was terminated after khan found out later by method of Computer hacking and falsely
`making accounting disbursements online using khan computer which he did not do nor authorize.
`Between April 10th and The transfer to ISI Seton had waited 45 days before he imitated the transfer
`injuring khan's ability plan and conduct business. I was later found that Seton and Kramer had been
`developing the businesses behind khans back during this time there were "stalling" Khan then was
`transferred to ISI after ECF refused to let khan transfer to fox WM to transfer his project. Khan met
`with WM and FOX as well as ISI and Loren Cole. khan was unaware at this time that his computers
`were hacked and had unauthorized activity being conducted on them.
`
`On or about sometime in May 2018 Kraemer met khan in San Francisco to discuss khan's business
`and Kramer was having a whispering conversation about his meeting with apple and discussing a
`meeting with a Sandler group for funding. he also said under his breath that he had been working
`with a group related to MLB to his friend in which he had to leave khan to finish this private
`conversation.
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`On or about 3/17/2018 khan was told that Kraemer had been developing khan's intellectual
`property with IBM. On or about 3/18/18 Khan noticed that intellectual property rights and notes
`were stolen from him while he was Indian wells conducting business. On or about 3/17/2018 khan
`sent creamer a cease and desist letter to stop infringing on khan's copyrights. Kraemer denied the
`allegations and did not surrender nor stop or address these issues to the plaintiff s knowledge. he did
`deny that he had been conducting fraud or infringing on khan's copyrights. On or about May 25th
`2018 a random event occurred when khan's images were being delete off his phone after he was
`investigation some matters related to software he developed in 2009 related the creative commons
`and Wiley group. I was unsure what this was about. On or about 6/29/2018 all of khan's email
`related to the media and food platforms and evidence was being deleted by apple using developers
`access to illuminate the conversation and emails and digital evidence khan owned and compile from
`his phone and lap top. It was determining that Kramer and ECF and Seton had been using khans
`own access to his emails to send emails as to themselves and other pretending to be khans if they
`were khan from khan's devices to upload request to the defendants for money and email them
`information khan had not approved or authorized. After Kramer denied these allegations to khan by
`email in March 2018 The information being deleted was relevant Ophir Gottlieb, Adam Kramer,
`Kent Seton and Edward Charles foundation and my emails about ESPN Khan was able to retrieve
`and preserve some of the information. This made it evident that Kramer had lied to khan in March
`2018 but these action of deleting this information off his email phones, and laptops on or about
`6/29/2018 and this was the date Khan affirmed in his mind that this fraud was real and the cover up
`began. On or about July 10th 2018 the lap top that had been hacked had been stolen out of khan's
`hotel room. In Los Angeles CA. He had also been planting fake evidence and spoliation evidence.
`On or about June 22 2019 khans I phones were hacked and emails and images uploaded to the cloud
`had been delete live while that were being screen shot were being delete live. Khan at this time
`realized that it was Ophir Gottlieb and Adam Kramer's groups that had been hacking him using the
`authority from Mr. Fox to hide or delete the information. Khan was able to email some these images
`to his lawyer and other. after the images were being delete the content on the Internet was being
`edited and erased from the web live while the screen shots were being delete he had just taken off
`the phone. Due to the nature of this activity and the fraud this has been agonizing and frightening to
`khan's ability to successfully use computers emails or keep and hold on to evidence and has caused
`emotions distress and these criminal acts.
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`In October 2018 Khan found out that These groups had sold khans ideas for over 300,000,000
`million dollars for his media platform And may be involved in the loss of a multi Trillion Dollar
`Platform as indicated on the 6/22/19 hacking date.
`
`On or about December 2019 I had found out that khan assistant was accepting and participating in
`payoffs and this conspiracy and khan's assistant had been stealing intellectual property, money, and
`is appropriating copyrights as well to foreign and local companies and delivering these documents
`to the conspirators. Khans assistant was deleting information related to khans' partnership and his
`father's business and relevant information needed for their law suits and relevant evidence to his
`fathers and partners many real estate complaints and other evidence related to software development
`from khans notes and copyrights.
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`~I
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`~►~:~
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`Defendants conspired to injure khan prior to engaging with khans on December 28th, 2016 to steal
`and mislead khan to sign these agreements as consultants with ulterior motives to assign his
`intellectual property
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`I did find out that there has been about 20 years of conspiracy on or about June 22nd 2019. On July
`10th 2020 intellectual property had been stolen from my father residence as I was preparing for
`these case which is relevant. the parties also revealed more Fraud. On or about august 2020 I found
`out that the parties I had been working with were manipulating me and stealing information and
`intellectual property and lying to me about the people I was meeting with. I found out that these
`parties were actually stealing information and then passing along this information to conspirator
`related to developing my Trade Secrets from the past 20 years. I may need to add more parties to
`this case as investigations are ongoing and wish to ask the court the right leave to amend as needed.
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`Plaintiff suffered irrepazable harm due to the negligence and fraud of the defendants
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`Claim for relief
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`a.) Breach of Contract
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`Plaintiff and defendants entered into agreements as set forth above
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`plaintiff performed his obligations under the agreement and contract
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`defendants breached the contract as set forth above
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`Misappropriation of intellectual property
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`Copyright infringement
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`Plaintiff exercised his right to work and allow the usage only of a license which was infringed upon
`in violation of federal rule 501 as provided by sections 106 through 118 and in violation of 602
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`Fraud
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`Defendants violated the title 18 USC 1341
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`Obstruction of Justice
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`Defendants violated title 18 chapter 73 section 1519
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`Defendants violated title 18 chapter 73 section 1519
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`Conspiracy
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`The defendants violated title 18 USC 371
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`'~'~ `~ ~ ~ ~ ~ ~ ~ ~ ~ S~ ~~
`Co orate es ions e
`r'P
`P g ~~~f't
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`Defendants acted in concert to defraud the Plaintiff in violation of title 18 USC 1831 and title 18
`USC 1832
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`Conflict of Interest
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`defendants violated title 18 USC 208
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`Prayer for relief
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`Plaintiff prays to have intellectual property issue resolved and damaged to the plaintiff be restored
`to include monetary damages to be paid to plaintiff equal to losses over $2 Billion Dollars.
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`I declare under the penalty of perjury that following is true and correct
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`DATED: April 7, 2021
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`Your signature
`SHAHERYAR KHAN
`In Pro Per
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