Christopher J. Gray. P.C. and its co-counsel filed a Second Amended Complaint on March 31, 2010 containing substantial new allegations concerning Bank of America's alleged knowledge of and substantial assistance provided to the now-defunct Ponzi scheme operation known as Agape World.
The Second Amended Complaint alleges, among other things, that Bank of America ignored the fact that a total of over $2 billion passed through Agape's accounts despite Agape's having no legitimate business reason for such transfers of money (which are a classic red flag of racketeering and money laundering). The Second Amended Complaint also alleges that Bank of America helped Agape solicit investors from Bank of America's own customers.
In preparing the Second Amended Complaint, counsel for plaintiffs engaged in a substantial investigation that included a comprehensive review of Agape and Bank of America documents produced in accordance with the Court-ordered subpoena to the Agape Bankruptcy Trustee; an analysis of Agape investor documents; scores of interviews with former Agape employees and Agape investors; consultations with a former Federal Reserve official and banking compliance expert; independent research concerning Bank of America procedures; and the review of news accounts, court papers and other publicly available documents.
A full copy of the Second Amended Complaint can be accessed below.
10.3.31 second amended complaint.pdf (196.13 kb)