GREENBERG TRAURIG, LLP 

Philip R. Sellinger, Esq. 

Roger B. Kaplan, Esq. 

200 Park Avenue, P.O. Box 677 

Florham Park, New Jersey 07932-0677 

(973) 360-7900 

Attorneys for Plaintiffs 

UNITED STATES DISTRICT COURT 

DISTRICT OF NEW JERSEY 

CAREONE, LLC, a Delaware Limited Liability 

Company; BURRIS & STRAUS BEACH 

DEVELOPMENT/CRANMER, LLC, a New 

Jersey Limited Liability Company; and BURRIS 

& STRAUS BEACH DEVELOPERS, LLC, a 

New Jersey Limited Liability Company, 

 Plaintiffs, 

vs. 

WILLIAM G. BURRIS, JR.; LINDA BURRIS; 

LINDA BURRIS INC.; JOSEPH FOY; NANCY 

DEANGELIS; ROBERT HEILER; DANIEL 

BOSSI; RICHARD PULASKI; ROLAND 

BORGLUND and DAVID YEAGER, 

 Defendants. 

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Civil Action No. ___________________ 

COMPLAINT AND JURY DEMAND

CareOne, LLC (“CareOne”), Burris & Straus Beach Development/Cranmer, LLC 

(“Burris & Straus-Cranmer”) and Burris & Straus Beach Developers, LLC (“Burris & StrausDevelopers”)(collectively “Burris & Straus,” and the three plaintiffs collectively referred to as 

the “CareOne Companies”), by their undersigned counsel, as and for their Complaint against 

defendants William G. Burris, Jr. (“Burris”), Linda Burris (Linda Burris”), Linda Burris, Inc., 

Joseph Foy (“Foy”), Nancy DeAngelis (“DeAngelis”), Robert Heiler (“Heiler”), Daniel Bossi 

(“Bossi”), Richard Pulaski (“Pulaski”), Roland Borglund (“Borglund”) and David Yeager 

(“Yeager”), state and allege the following: 

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NATURE OF THE CASE

1. This is an action for treble damages under the Racketeer Influenced and Corrupt 

Organizations Act (“RICO”), 18 U.S.C. §§1961-1964, arising from a long-continuing pattern of 

mail fraud and wire fraud committed by defendant Burris, his wife Linda Burris, and the other 

defendants, resulting in the loss of millions of dollars by the CareOne Companies. As set forth 

below, the subject of this action is plaintiffs’ claims for damages and treble-damages as the result 

of a long-continuing pattern of fraudulent and inflated invoices submitted to plaintiffs by vendors 

who are defendants herein, arising from a kickback scheme between and among those vendor 

defendants and defendants Burris and his wife. While this action concerns, and asserts claims for 

damages arising from, those fraudulent and inflated invoices, there is other wrongful conduct 

alleged herein which, although supporting plaintiffs’ claims, is the subject of the claims for relief 

in another action pending in New Jersey Superior Court, Bergen County, Chancery Division (the 

“Bergen Chancery Action”). See Plaintiffs’ Certification Pursuant to L.Civ. R. 11.2. 

2. For nearly ten years, Burris was the Executive Vice President for Construction 

and Development of CareOne and a member of Burris & Straus performing the same functions 

for those entities. As part of CareOne’s and Burris & Straus’ senior management team, Burris 

had significant control and influence over CareOne and Burris & Straus, as he directed their 

construction and development activities. With respect to his position at CareOne, Burris was 

responsible for selecting and acquiring land and existing properties, and then designing, 

developing and converting that real estate into assisted living or healthcare facilities to be run by 

CareOne, its affiliates or subsidiaries. Similarly, Burris selected and acquired land and existing 

properties on behalf of the Burris & Straus entities, and then designed, developed and converted 

that real estate for resale. 

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3. Part of Burris’ job responsibilities was the selection and hiring of vendors (such 

as electricians, framers, architects and other contractors) to perform construction work on the 

properties the CareOne Companies were converting. Defendants DeAngelis, Heiler, Bossi, 

Pulaski, Borglund and Yeager (collectively, the “Vendor Defendants”) were all senior officials 

of such vendors. All allegations made in this Complaint with respect to the Vendor Defendants 

are made upon information and belief. 

4. However, Burris regularly used the Vendor Defendants for his own personal gain 

at the expense of the CareOne Companies by repeatedly conducting and participating in the 

conduct of the affairs of the CareOne Companies by conspiring to use, using, and causing 

numerous uses of, the United States mails and interstate wires, in violation of 18 U.S.C. §§1341 

and 1343, to convert, steal and embezzle millions of dollars from the CareOne Companies over a 

ten year period of time, in concert with the other defendants. These allegations are set forth in 

detail below, and are made upon information and belief based on the factual support outlined in 

Paragraphs 25 to 29, which describes Plaintiffs' good faith basis upon which such allegations are 

made. 

5. Specifically, upon information and belief, Burris abused his senior management 

position at the CareOne Companies by conducting the affairs of the CareOne Companies to 

pressure and obtain kickbacks from the Vendor Defendants in exchange for dispensing with 

competitive bidding resulting in the Vendor Defendants submitting padded and excessive 

invoices to the CareOne Companies which were, as a result, false and fraudulent. As a result, 

these invoices greatly exceeded the actual value of the work performed. Thus, on numerous 

occasions over the course of ten years, the Vendor Defendants submitted false and fraudulent 

invoices to the CareOne Companies. In return for his kickbacks, Burris, with the assistance of 

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another CareOne employee, defendant Joseph Foy, would approve these invoices, arrange for 

payment of the fraudulent invoices by the CareOne Companies, and affirmatively conceal the nobid, kickback scheme from the principal of the CareOne Companies. 

6. By March 4, 2009, the CareOne Companies had uncovered substantial 

wrongdoing by Burris unrelated to this fraudulent invoice scheme and terminated him for cause. 

At that time, the Care One Companies suspected Burris was receiving kickbacks but only 

recently discovered and became aware of evidence of Burris’ schemes, artifices and conspiracies 

to defraud. Before his termination, Burris conspired with the other Defendants to fraudulently 

conceal this fraudulent invoice scheme from the CareOne Companies. Such fraudulent 

concealment was accomplished, by Burris and Foy instructing the construction department at 

CareOne to conceal the fact (from the principal of CareOne) that the projects awarded to the 

Vendor Defendants (as opposed to those projects performed by other vendors) were not awarded 

pursuant to competitive bidding. Because this scheme was the product of an ongoing conspiracy 

and was affirmatively and fraudulently concealed by the defendants, the applicable statute of 

limitations was tolled until the CareOne Companies’ recent discovery of these improper acts.

JURISDICTION AND VENUE

7. This Court has federal question jurisdiction over the subject matter of this case, 

pursuant to Section 4 of the RICO Act, 18 U.S.C. §§1961-1964, and 28 U.S.C. §1331. 

8. This Court has supplemental jurisdiction pursuant to 28 U.S.C. §1367, over the 

CareOne Companies’ claims for fraud, conversion, civil conspiracy, fraudulent conversion, and 

related claims under the laws of the State of New Jersey. 

9. Venue properly lies in this District, pursuant to 28 U.S.C. §1391, because 

plaintiffs are residents of New Jersey; and the events, circumstances and occurrences which give 

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rise to the CareOne Companies’ claims occurred substantially in New Jersey. 

THE PARTIES AND DEFENDANTS’ SCHEME AND ARTIFICE TO DEFRAUD

10. Plaintiff CareOne is a family owned Delaware limited liability company with its 

principal place of business in Fort Lee, New Jersey. CareOne, through it subsidiaries, affiliates 

and/or related entities, is in the business of owning, operating and managing skilled nursing 

homes, assisted living centers and a Long-Term Acute Care Hospital with approximately 3,500 

licensed beds in the State of New Jersey. Through subsidiaries, CareOne also controls other 

properties throughout the State of New Jersey (and in eight other states) that it operates, manages 

or intends to develop and/or convert into assisted living or healthcare facilities to be run by 

CareOne or one of its affiliates or subsidiaries. CareOne purchases goods and merchandise in, 

and substantially affecting, interstate trade and commerce. 

11. Plaintiff Burris & Straus-Cranmer is a New Jersey limited liability company with 

its principal place of business in Fort Lee, New Jersey, whose activities were in or substantially 

affect interstate trade and commerce. Burris & Straus-Cranmer was formed in 2003 for the 

purpose of acquiring and developing a former lumber yard site in Beach Haven, New Jersey and 

is owned 50% by Daniel E. Straus (the founder and Managing Member of CareOne) and 50% by 

defendant Burris. 

12. Plaintiff Burris & Straus-Developers is a New Jersey limited liability company 

with a principal place of business in Fort Lee, New Jersey, whose activities are in or substantially 

affect interstate trade and commerce. Burris & Straus-Developers is owned 50% by Mr. Straus 

and 50% by defendant Burris. 

13. Defendant Burris is a New Jersey resident and a former Executive Vice President 

for Construction and Development of CareOne, and performed the same function as a 50% 

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member of the Burris & Straus entities. As discussed in detail below, for his own personal gain 

and at the expense of the CareOne Companies, over a ten year period Burris operated, conducted 

and participated in the conduct of the affairs of the CareOne Companies by repeatedly conspiring 

to use, using and causing the use of the United States mails and interstate wires in violation of 18 

U.S.C. §§1341 and 1343, to convert, steal and embezzle millions of dollars from the CareOne 

Companies, in concert and conspiracy with the other Defendants. 

14. Specifically, Burris used his position at the CareOne Companies to obtain 

kickbacks from the Vendor Defendants in exchange for dispensing with competitive bidding and 

pressuring the Vendor Defendants to submit false and fraudulent invoices to the CareOne 

Companies that greatly exceeded the actual value of the work performed. Thus, on numerous 

occasions over a ten year period, the Vendor Defendants, in conspiracy with Burris, his wife and 

Foy, submitted false and fraudulent invoices to the CareOne Companies. In return for these 

kickbacks, Burris approved the excessive and fraudulent invoices and, with the help of Foy, 

arranged for payment of those invoices by the CareOne Companies, resulting in the fraudulent 

use of the mails and interstate wires. 

15. Defendant Linda Burris is a New Jersey resident and the wife of Burris. Linda 

Burris is the President of defendant Linda Burris, Inc., a New Jersey corporation with a principal 

place of business in New Jersey, whose activities are in or substantially affected interstate trade 

and commerce. Upon information and belief, Linda Burris, Inc., is an entity used by Burris and 

Linda Burris to maintain Burris family assets, including assets obtained, used and invested as a 

result of Burris’ fraudulent activities, which are alleged herein. Burris and Linda Burris 

conducted and participated in the conduct of the affairs of Linda Burris, Inc., through numerous 

and ongoing violations of 18 U.S.C. §§1341 and 1343, and invested and used, directly and 

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indirectly, the proceeds of such mail and wire fraud in, and in the operations of, Linda Burris, 

Inc. 

16. Upon Information and belief, Immobiliare, LLC (“Immoabilaire”), is a New 

Jersey limited liability company owned and controlled by Burris, whose activities were in or 

substantially affected interstate trade and commence. Upon information and belief, Immobiliare 

is an entity used by Burris to maintain Burris family assets, including assets obtained, used and 

invested as a result of Burris’ fraudulent activities. Burris conducted the affairs and participated 

in the conduct of the affairs of Immobiliare through numerous and ongoing violations of 18 

U.S.C. §§1341 and 1343, and invested and used, directly and indirectly, the proceeds of such 

mail and wire fraud in, and in the operations of, Immobiliare. 

17. Upon information and belief, Prestatori-Immobiliare, LLC (“PrestatoriImmobiliare”), is a New Jersey limited liability company owned and controlled by Burris, with 

its principal place of business in New Jersey, whose activities were in or substantially affected 

interstate trade and commence. Upon information and belief, Prestatori-Immobiliare is an entity 

used by Burris to maintain Burris family assets, including assets obtained, used and invested as a 

result of Burris’ fraudulent activities. Burris conducted the affairs and participated in the conduct 

of the affairs of Prestatori-Immobiliare through numerous and ongoing violations of 18 U.S.C. 

§§1341 and 1343, and invested and used, directly and indirectly, the proceeds of such mail and 

wire fraud in, and in the operations of, Prestatori-Immobiliare. 

18. Defendant Foy is a New Jersey resident, and former senior employee of CareOne 

employed by Burris in the Construction & Development Department. Foy assisted and conspired 

with Burris, Linda Burris, Burris family entities and the Vendor Defendants, in the submission of 

the Vendors’ false and fraudulent invoices to the CareOne Companies for work performed at an 

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inflated and excessive, non-competitive price as a result of Burris’ kickback scheme. As such, 

Foy committed and conspired to commit mail fraud in violation of 18 U.S.C. §1341 and wire 

fraud in violation of 18 U.S.C. §1343, and conspired with, aided, abetted and facilitated Burris 

and other Defendants in their fraudulent schemes and artifices. 

19. Defendant Nancy DeAngelis is a New Jersey resident and the sister of Burris. 

DeAngelis is an owner of DeAngelis Builders, LLC, a New Jersey limited liability company, 

whose activities were in or substantially affected interstate trade and commerce. At Burris’ 

direction to Day Electrical’s principal, DeAngelis was also employed in a bookkeeping position 

by Day Electrical, a Delaware corporation with a principal place of business in New Jersey that 

was formed specifically at Burris’s direction for the purpose of performing work on CareOne 

projects, and whose activities were in or substantially affected interstate trade and commerce. 

Burris demanded kickbacks from DeAngelis as part of a scheme to eliminate competitive 

bidding, and DeAngelis provided such kickbacks to Burris by submitting to Care One on behalf 

of Day Electric and others false and fraudulent invoices. As a result, DeAngelis conspired with 

Burris to conduct and to participate in conducting the affairs of the CareOne Companies, 

DeAngelis Builders and Day Electrical through the pattern of mail and wire fraud arising from 

Burris’ false and fraudulent invoice scheme. At Burris’s direction, DeAngelis was also employed 

by Heiler to perform the same function as she did for Day Electrical. 

20. Defendant Heiler is a New Jersey resident and an owner of Striper Mechanical, a 

New York corporation, whose activities were in or substantially affected interstate trade and 

commerce. Heiler is also an owner of RNR Mechanical, a New Jersey corporation that was 

formed at Burris’s direction specifically for the purpose of performing work on CareOne 

projects, and whose activities were in or substantially affected interstate trade and commerce. 

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Heiler was also associated in a management position with Main Line Mechanical, a Delaware 

corporation that conducted projects for CareOne in the State of New Jersey, and whose activities 

were in or substantially affected interstate trade and commerce. Burris demanded kickbacks 

from Heiler as part of a scheme to eliminate competitive bidding, and Heiler provided such 

kickbacks to Burris. As a result, Heiler conspired with Burris to conduct and to participate in the 

conduct of the affairs of the CareOne Companies, Striper Mechanical, RNR Mechanical and 

Main Line Mechanical through the pattern of mail and wire fraud arising from Burris’ false and 

fraudulent invoice scheme. 

21. Defendant Bossi is a New Jersey resident and an owner of Extreme Construction, 

a New Jersey corporation that was formed specifically for the purpose of performing work on 

CareOne projects, and whose activities were in or substantially affected interstate trade and 

commerce. Burris demanded kickbacks from Bossi as part of a scheme to eliminate competitive 

bidding, and Bossi provided such kickbacks to Burris. As a result, Bossi conspired with Burris 

to conduct and to participate in the conduct of the affairs of the CareOne Companies and 

Extreme Construction through the pattern of mail and wire fraud arising from Burris’ false and 

fraudulent invoice scheme. 

22. Defendant Pulaski is a New Jersey resident, and an owner and president of 

Pulaski Construction Inc., a New Jersey corporation, whose activities were in or substantially 

affected interstate trade and commerce. Burris demanded kickbacks from Pulaski as part of a 

scheme to eliminate competitive bidding, and Pulaski provided such kickbacks to Burris. As a 

result, Pulaski conspired with Burris to conduct and to participate in the conduct of the affairs of 

the CareOne Companies and Pulaski Construction through the pattern of mail and wire fraud 

arising from Burris’ false and fraudulent invoice scheme. 

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23. Defendant Borglund is a Florida Resident and an owner, Manager and President 

of Borglund Associates, LLC, f/k/a Borglund Tyson, LLC, f/k/a Borglund Tyson Brasseur, LLC, 

a Florida Limited Liability Company that has conducted substantial business over the course of 

approximately ten years in the State of New Jersey, whose activities were in or substantially 

affected interstate trade and commerce. Borglund was also owner of Tektonica Design Inc., a 

Florida corporation administratively dissolved in 2004 for failure to file its annual reports and 

whose activities were in or substantially affected interstate trade and commerce. Burris 

demanded kickbacks from Borglund as part of a scheme to eliminate competitive bidding, and 

Borglund provided such kickbacks to Burris. As a result, Borglund conspired with Burris to 

conduct and to participate in the conduct of the affairs of the CareOne Companies and Borglund 

Associates through the pattern of mail and wire fraud arising from Burris false and fraudulent 

invoice scheme. 

24. Defendant Yaeger is a New Jersey resident and an owner and President of Day 

Electrical, a New Jersey corporation that was formed specifically for the purpose of performing 

work on CareOne projects, and whose activities were in or substantially affected interstate trade 

and commerce. Burris demanded kickbacks from Yaeger as part of a scheme to eliminate 

competitive bidding, and Yaeger provided such kickbacks to Burris. As a result, Yaeger 

conspired with Burris to conduct and to participate in the conduct of the affairs of the CareOne 

Companies and Day Electrical through the pattern of mail and wire fraud arising from Burris’ 

false and fraudulent invoice scheme. 

FACTS FORMING THE GOOD FAITH BASIS FOR PLAINTIFFS’ ALLEGATIONS 

25. Although the Defendants have denied any kickback scheme, Plaintiffs’ good faith 

basis for alleging such a scheme is set forth herein. 

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26. In 2009, after suspecting that Burris obtained kickbacks, perks and other personal 

benefits from his preferred vendors, the CareOne Companies (with the assistance of counsel) 

initiated an investigation into Burris’ conduct. That investigation reveals evidence of Burris’ 

kickback scheme and forms the good faith basis for this Complaint. 

27. For example, a confidential witness (CW-1) continues to provide the CareOne 

Companies with details of Burris’ kickback scheme, including specific instances when Burris 

instructed his subordinates to conceal from the CareOne Companies that, competitive bids were 

usually not required from the Vendor Defendants. 

28. Moreover, another confidential witness (CW-2), who was directly involved in 

construction projects for the CareOne Companies that were managed by Burris, identified 

various individuals involved in the kickback scheme and also confirmed that Burris demanded 

cash payments from certain vendors in return for awarding them non-bidding construction 

contracts. 

29. Additionally, during his nonparty deposition in another lawsuit, defendant Yeager 

revealed that, during the time Burris awarded non-bidding construction contracts to Yeager’s 

electrical contracting company on behalf of the CareOne Companies, Burris (through defendant 

Linda Burris) owned 50% of Yeager’s company, and used the assets of that company (comprised 

almost exclusively of payments made by the CareOne Companies) to pay personal expenses. 

Yeager also admitted Burris made many of the business decisions for that vendor, including 

hiring and compensation decisions. As noted in Paragraph 1, above, other than supporting 

plaintiffs’ claims arising out of, and relating to, the fraudulent and inflated invoices submitted by 

Yeager and his company, the conduct alleged in this paragraph is not the subject of this action, 

but, rather, is the subject of the claims asserted, and pending, in the Bergen Chancery Action. 

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30. Further, another confidential witness (CW-3) has stated that Burris used the 

CareOne Companies’ employees and vendors to perform work on his Moorestown, New Jersey 

mansion, his boat and his other properties, and submitted invoices, costs and/or expenses of the 

work performed to the CareOne Companies for payment. The same source advised that Foy 

used the CareOne Companies’ assets to pay for work for Foy’s personal benefit. This 

investigation also revealed that Burris opened a secret, unauthorized Burris & Straus bank 

account to divert income from Burris & Straus development projects away from Burris’ other 

partner. As noted in Paragraph 1, above, other than supporting plaintiffs’ claims arising out of, 

and relating to, the fraudulent and inflated invoices submitted by Yeager and his company, the 

conduct alleged in this paragraph is not the subject of this action, but, rather, is the subject of the 

claims asserted, and pending, in the Bergen Chancery Action. 

DEFENDANTS’ ONGOING AND CONTINUING PATTERN OF RACKETEERING 

ACTIVITY INVOLVING MAIL FRAUD AND WIRE FRAUD ARISING FROM THE 

_____________________FRAUDULENT INVOICE SCHEME_____________________ 

31. In concert with the other Defendants, Burris conducted and participated in the 

conduct of the affairs of the CareOne Companies by conspiring to use, using, and causing 

numerous uses of, the United States mails and interstate wires in violation of 18 U.S.C. §§1341 

and 1343 to convert, steal and embezzle millions of dollars from the CareOne Companies. 

Specifically, plaintiffs allege that Burris used his senior management position at the CareOne 

Companies to obtain kickbacks from the Vendor Defendants in exchange for the Vendor 

Defendants not being required to bid on projects and submitting false and fraudulent invoices to 

the CareOne Companies. 

32. Thus, on numerous occasions over the course of ten years, plaintiffs allege that 

the Vendor Defendants submitted false and fraudulent invoices to the CareOne Companies. In 

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return for his kickbacks, Burris, with the participation of Foy, would operate and conduct the 

affairs of the CareOne Companies by approving these invoices and facilitating payment of the 

fraudulent invoices by the CareOne Companies, and by concealing the no-bid, kickback scheme. 

33. In violation of 18 U.S.C. §§1341 and 1343, each of these invoices was submitted 

using the United States mails or interstate wires, and were paid pursuant to checks and/or wire 

transfers where the checks were transmitted through the mails and cleared through the mails or 

interstate wires, and each wire transfer payment resulted in the use of the interstate wires. 

34. As such, each and every fraudulent invoice and payment resulted in an unlawful 

use of the mails and wires in violation of 18 U.S.C. §§1341 and 1343, and are specifically 

identified below and in the schedules attached as exhibits hereto. 

A. The Heiler, Striper Mechanical, RNR Mechanical and Main Line Mechanical 

Pattern of Fraudulent Invoices and Payments__________________________

35. Upon information and belief, Burris demanded and received kickbacks from 

Heiler as part of a scheme to eliminate competitive bidding, and in return, permitted Heiler to 

conduct the affairs of Striper Mechanical, RNR Mechanical and Main Line Mechanical by 

submitting false and fraudulent invoices to the CareOne Companies. These invoices were for 

work performed at an inflated price, made possible by the lack of competitive bidding and the 

kickbacks to Burris. 

36. A listing of these false and fraudulent invoices, and the corresponding payments 

from the CareOne Companies, is attached hereto as Exhibit A. Each one of the transactions 

listed in Exhibit A caused or resulted in the use of mails or the interstate wires in violation of 18 

U.S.C. §§1341 and 1343. 

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B. The Bossi and Extreme Construction Pattern 

of Fraudulent Invoices and Payments______

37. Upon information and belief, Burris demanded and received kickbacks from 

Bossi as part of a scheme to eliminate competitive bidding, and in return, permitted Bossi to 

conduct the affairs of Extreme Construction by submitting false and fraudulent invoices to the 

CareOne Companies. These invoices were for work performed at an inflated price, made 

possible by the lack of competitive bidding and the kickbacks to Burris. 

38. A listing of these false and fraudulent invoices, and the corresponding payments 

from the CareOne Companies, is attached hereto as Exhibit B. Each one of the transactions 

listed in Exhibit B caused or resulted in the use of mails or the interstate wires in violation of 18 

U.S.C. §§1341 and 1343. 

 C. The Pulaski and Pulaski Construction 

Pattern of Fraudulent Invoices and Payments

 

39. Upon information and belief, Burris demanded and received kickbacks from 

Pulaski as part of a scheme to eliminate competitive bidding, and in return, permitted Pulaski to 

conduct the affairs of Pulaski Construction by submitting false and fraudulent invoices to the 

CareOne Companies. These invoices were for work performed at an inflated price, made 

possible by the lack of competitive bidding and the kickbacks to Burris. 

40. A listing of these false and fraudulent invoices, and the corresponding payments 

from the CareOne Companies, is attached hereto as Exhibit C. Each one of the transactions 

listed in Exhibit C caused or resulted in the use of mails or the interstate wires in violation of 18 

U.S.C. §§1341 and 1343. 

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 D. The Yeager, DeAngelis and Day Electrical 

Pattern of Fraudulent Invoices and Payments

41. Upon information and belief, Burris demanded and received kickbacks from 

Yeager and DeAngelis as part of a scheme to eliminate competitive bidding, and in return, 

permitted Yeager and DeAngelis to conduct the affairs of Day Electrical by submitting false and 

fraudulent invoices to the CareOne Companies. These invoices were for work performed at an 

inflated price, made possible by the lack of competitive bidding and the kickbacks to Burris. 

42. A listing of these false and fraudulent invoices, and the corresponding payments 

from the CareOne Companies, is attached hereto as Exhibit D. Each one of the transactions 

listed in Exhibit D caused or resulted in the use of mails or the interstate wires in violation of 18 

U.S.C. §§1341 and 1343. 

E. The DeAngelis and DeAngelis Builders 

Pattern of Fraudulent Invoices and Payments

43. Upon information and belief, Burris demanded and received kickbacks from 

DeAngelis as part of a scheme to eliminate competitive bidding, and in return, permitted 

DeAngelis to conduct the affairs of DeAngelis Builders by submitting false and fraudulent 

invoices to the CareOne Companies. These invoices were for work performed at an inflated 

price, made possible by the lack of competitive bidding and the kickbacks to Burris. 

44. A listing of these false and fraudulent invoices, and the corresponding payments 

from the CareOne Companies, is attached hereto as Exhibit E. Each one of the transactions 

listed in Exhibit E caused or resulted in the use of mails or the interstate wires in violation of 18 

U.S.C. §§1341 and 1343. 

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F. The Borglund, Borglund Associates, LLC and Tektonica Design, Inc. 

Pattern of Fraudulent Invoices and Payments___________________

45. Upon information and belief, Burris demanded and received kickbacks from 

Borglund as part of a scheme to eliminate competitive bidding, and in return, permitted Borglund 

to conduct the affairs of Borglund Associates, LLC and Tektonica Design, Inc. by submitting 

false and fraudulent invoices to the CareOne Companies. These invoices were for work 

performed at an inflated price, made possible by the lack of competitive bidding and the 

kickbacks to Burris. 

46. A listing of these false and fraudulent invoices, and the corresponding payments 

from the CareOne Companies, is attached hereto as Exhibit F. Each one of the transactions listed 

in Exhibit F caused or resulted in the use of mails or the interstate wires in violation of 18 U.S.C. 

§§1341 and 1343. 

COUNT I

(RICO §1962(c) - The CareOne Enterprise)

47. Plaintiffs repeat and reallege paragraphs 1 through 43, above, as though set forth 

in full herein. 

48. Defendants Burris and Foy are each “persons” within the meaning of 18 U.S.C. 

§1961(3) who were “employed by” and “associated with” CareOne within the meaning of 18 

U.S.C. §1962(c). 

49. CareOne is an “enterprise” within the meaning of 18 U.S.C. §1961(4) whose 

activities are in, or substantially affect, interstate trade and commerce. 

50. As set forth above and in Exhibits A-F, Burris and Foy used, and caused 

numerous uses of, the United States mails and interstate wires, including, but not limited to, the 

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transmission therein of false invoices, checks, and wires, in furtherance and as a result of the 

schemes and artifices to defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of 

these violations constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

51. As set forth above and in Exhibits A-F, Burris and Foy engaged in a “pattern of 

racketeering” because: (a) said crimes and illegal acts bore a relationship to each other by reason 

of having similar objects, methods of commission, common victims, and similar means of 

transmission, and all of which related to Burris’ fraudulent misuse of his position at the CareOne; 

and (b) they were continuing in nature in that they continued for a substantial period of time and 

threatened to continue indefinitely until Burris was terminated in March 2009. 

52. In violation of 18 U.S.C. §1962(c), Burris and Foy conducted and participated, 

directly and indirectly, in the conduct of the affairs of the CareOne enterprise through a “pattern 

of racketeering” within the meaning of 18 U.S.C. §1961(5). 

53. As a result of this violation of 18 U.S.C. §1962(c), CareOne has been injured in 

its business and its property. 

COUNT II

(RICO §1962(d) - The CareOne Enterprise)

54. Plaintiffs repeat and reallege paragraphs 1 through 50, above, as though set forth 

in full herein. 

55. Defendants Linda Burris, DeAngelis, Heiler, Bossi, Pulaski, Borglund, Yeager, 

and Linda Burris, Inc are all “persons” within the meaning of 18 U.S.C. §1961(3). 

56. In violation of 18 U.S.C. §1962(d), defendants Linda Burris, DeAngelis, Heiler, 

Bossi, Pulaski, Borglund, Yeager, and Linda Burris, Inc. conspired among themselves and with 

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Burris and Foy to conduct and participate in the conduct of the affairs of CareOne through a 

“pattern of racketeering” violation of 18 U.S.C. §1962(c). 

57. As a result of this violation of 18 U.S.C. §1962(d), CareOne has been injured in 

its business and its property. 

COUNT III

(RICO §1962(c) - The Burris & Straus Enterprises)

58. Plaintiffs repeat and reallege paragraphs 1 through 54, above, as though set forth 

in full herein. 

59. Defendant Burris is a “person” within the meaning of 18 U.S.C. §1961(3) who 

was “employed by” and “associated with” the Burris & Straus entities within the meaning of 18 

U.S.C. §1962(c). 

60. The Burris & Straus entities are “enterprises” within the meaning of 18 U.S.C. 

§1961(4) whose activities are in, or substantially affect, interstate trade and commerce. 

61. As set forth above and in Exhibits A-F, Burris used, and caused numerous uses of, 

the United States mails and interstate wires, including, but not limited to, the transmission 

therein of false invoices, checks, and wires, in furtherance and as a result of the schemes and 

artifices to defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of these 

violations constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

62. As set forth above and in Exhibits A-F, Burris engaged in a “pattern of 

racketeering” because: (a) said crimes and illegal acts bore a relationship to each other by reason 

of having similar objects, methods of commission, common victims, and similar means of 

transmission, and all of which related to Burris’ fraudulent misuse of his position at the Burris & 

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Straus entities; and (b) they were continuing in nature in that they continued for a substantial 

period of time and threatened to continue indefinitely until Burris was terminated in March 2009. 

63. In violation of 18 U.S.C. §1962(c), Burris conducted and participated, directly 

and indirectly, in the conduct of the affairs of the Burris & Straus enterprises through a “pattern 

of racketeering” within the meaning of 18 U.S.C. §1961(5). 

64. As a result of this violation of 18 U.S.C. §1962(c), the Burris & Straus entities 

have been injured in their business and property. 

COUNT IV

(RICO §1962(d) - The Burris & Straus Enterprises)

65. Plaintiffs repeat and reallege paragraphs 1 through 61, above, as though set forth 

in full herein. 

66. In violation of 18 U.S.C. §1962(d), defendants Linda Burris, DeAngelis, Heiler, 

Bossi, Pulaski, Borglund, Yeager and Linda Burris, Inc. conspired among themselves and with 

Burris to conduct and participate in the conduct of the affairs of the Burris & Straus enterprises 

through a “pattern of racketeering” and in violation of 18 U.S.C. §1962(c). 

67. As a result of this violation of 18 U.S.C. §1962(d), the Burris & Straus entities 

have been injured in their businesses and property.

COUNT V

(RICO §1962(a) - The Linda Burris, Inc., 

Immobiliare and Prestatori Immobiliare Enterprises)

68. Plaintiffs repeat and reallege paragraphs 1 through 64, above, as though set forth 

in full herein. 

69. Defendants Burris and Linda Burris are “persons” within the meaning of 18 

U.S.C. §1961(3). 

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70. Linda Burris, Inc., Immobiliare, LLC, and Prestatori Immobiliare, LLC, are 

“enterprises” within the meaning of 18 U.S.C. §1961(4) whose activities are in, or substantially 

affect, interstate trade and commerce. 

71. As set forth above and in Exhibits A-F, Burris used, and caused numerous uses of, 

the United States mails and interstate wires, including, but not limited to, the transmission 

therein of false invoices, checks, and wires, in furtherance and as a result of the schemes and 

artifices to defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of these 

violations constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

72. As set forth above and in Exhibits A-F, Burris and Linda Burris engaged in a 

“pattern of racketeering” because: (a) said crimes and illegal acts bore a relationship to each 

other by reason of having similar objects, methods of commission, common victims, and similar 

means of transmission, and all of which related to Burris’ fraudulent misuse of his position at the 

CareOne Companies; and (b) they were continuing in nature in that they continued for a 

substantial period of time and threatened to continue indefinitely until Burris was terminated in 

March 2009. 

73. In violation of 18 U.S.C. §1962(a), Burris and Linda Burris received income 

derived, directly or indirectly, from this pattern of racketeering activity, and used or invested, 

directly or indirectly, a such income or the proceeds of such income, to acquire an interest in, 

establish and/or operate Linda Burris, Inc., Immobiliare, LLC, and Prestatori Immobiliare, LLC.

74. As a result of this violation of 18 U.S.C. §1962(a), the CareOne Companies have 

been injured in their businesses and property. 

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COUNT VI

(RICO §1962(c) - The Linda Burris, Inc., 

Immobiliare, and Prestatori Immobiliare Enterprises)

75. Plaintiffs repeat and reallege paragraphs 1 through 71, above, as though set forth 

in full herein. 

76. Defendants Burris and Linda Burris are “persons” within the meaning of 18 

U.S.C. §1961(3) who were “employed by” and/or “associated with” Linda Burris, Inc., 

Immobiliare, LLC, and Prestatori Immobiliare, LLC, within the meaning of 18 U.S.C. §1962(c). 

77. In violation of 18 U.S.C. §1962(c), Burris and Linda Burris conducted and 

participated, directly and indirectly, in the conduct of the affairs of Linda Burris, Inc., 

Immobiliare, LLC, and Prestatori Immobiliare, LLC, through a “pattern of racketeering” within 

the meaning of 18 U.S.C. §1961(5). 

78. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT VII

(RICO §1962(d) - The Linda Burris, Inc., 

Immobiliare and Prestatori Immobiliare Enterprises)

79. Plaintiffs repeat and reallege paragraphs 1 through 75, above, as though set forth 

in full herein. 

80. In violation of 18 U.S.C. §1962(d), defendants Foy, DeAngelis, Heiler, Bossi, 

Pulaski, Borglund and Yeager directly and indirectly, conspired among themselves and with 

Burris and Linda Burris to obtain income derived, directly or indirectly, from this pattern of 

racketeering activity, and used or invested, directly or indirectly, a portion of such income, to 

acquire an interest in, establish, or operate the Linda Burris, Inc., Immobiliare, LLC, and 

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Prestatori Immobiliare, LCC, enterprises in violation of 18 U.S.C. §1962(a). 

81. In violation of 18 U.S.C. §1962(d), Defendants Foy, DeAngelis, Heiler, Bossi, 

Pulaski, Borglund and Yeager directly and indirectly, conspired among themselves and with 

defendants Burris and Linda Burris to conduct and participate in the conduct of the affairs of the 

Linda Burris, Inc., Immobiliare and Prestatori Immobiliare enterprises through a “pattern of 

racketeering” in violation of 18 U.S.C. §1962(c). 

82. As a result of these violations of 18 U.S.C. §1962(d), the CareOne Companies 

have been injured in their businesses and property.

COUNT VIII

(RICO §1962(c) - Striper Mechanical, RNR 

Mechanical and Main Line Mechanical Enterprises) 

83. Plaintiffs repeat and reallege paragraphs 1 through 79, above, as though set forth 

in full herein. 

84. Defendant Heiler is a “person” within the meaning of 18 U.S.C. §1961(3) and, as 

owner and president of Striper Mechanical, RNR Mechanical, and Main Line Mechanical, was 

“employed by” and “associated with” Striper Mechanical, RNR Mechanical and Main Line 

Mechanical within the meaning of 18 U.S.C. §1962(c). 

85. Striper Mechanical, RNR Mechanical and Main Line Mechanical are 

“enterprises” within the meaning of 18 U.S.C. §1961(4) whose activities are in, or substantially 

affect, interstate trade and commerce. 

86. As set forth above and in Exhibit A, Heiler used, and caused numerous uses of, 

the United States mails and interstate wires, including, but not limited to, the transmission 

therein of false invoices, checks, and wires, in furtherance and as a result of the schemes and 

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artifices to defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of these 

violations constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

87. Heiler engaged in a “pattern of racketeering” because: (a) said crimes and illegal 

acts bore a relationship to each other by reason of having similar objects, methods of 

commission, common victims, and similar means of transmission, and all of which related to 

Burris’ fraudulent misuse of his position at the CareOne Companies; and (b) they were 

continuing in nature in that they continued for a substantial period of time and threatened to 

continue indefinitely until Burris was terminated in March 2009. 

88. In violation of 18 U.S.C. §1962(c), Heiler conducted and participated, directly 

and indirectly, in the conduct of the affairs of Striper Mechanical, RNR Mechanical and Main 

Line Mechanical through a “pattern of racketeering” within the meaning of 18 U.S.C. §1961(5). 

89. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT IX

(RICO §1962(d) - RNR Mechanical and Main Line Mechanical Enterprises) 

90. Plaintiffs repeat and reallege paragraphs 1 through 86, above, as though set forth 

in full herein. 

91. In violation of 18 U.S.C. §1962(d), defendants Burris, Linda Burris, Foy and 

Linda Burris, Inc. conspired among themselves and with Heiler to conduct and participate in the 

conduct of the affairs of Striper Mechanical, RNR Mechanical and Main Line Mechanical 

through a “pattern of racketeering” in violation of 18 U.S.C. §1962(c). 

92. As a result of this violation of 18 U.S.C. §1962(d), the CareOne Companies have 

been injured in its businesses and its property.

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COUNT X

(RICO §1962(c) - The Extreme Construction Enterprise)

 

93. Plaintiffs repeat and reallege paragraphs 1 through 89, above, as though set forth 

in full herein. 

94. Defendant Bossi is a “person” within the meaning of 18 U.S.C. §1961(3), and, as 

owner and president of Extreme Construction, was “employed by” and “associated with” 

Extreme Construction within the meaning of 18 U.S.C. §1962(c). 

95. Extreme Construction is an “enterprise” within the meaning of 18 U.S.C. 

§1961(4) whose activities are in, or substantially affect, interstate trade and commerce. 

96. As set forth above and in Exhibit B, Bossi used, and caused numerous uses of, the 

United States mails and interstate wires, including, but not limited to, the transmission therein of 

false invoices, checks, and wires, in furtherance and as a result of the schemes and artifices to 

defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of these violations 

constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

97. Bossi engaged in a “pattern of racketeering” because: (a) said crimes and illegal 

acts bore a relationship to each other by reason of having similar objects, methods of 

commission, common victims, and similar means of transmission, and all of which related to 

Burris’ fraudulent misuse of his position at the CareOne Companies; and (b) they were 

continuing in nature in that they continued for a substantial period of time and threatened to 

continue indefinitely until Burris was terminated in March 2009. 

98. In violation of 18 U.S.C. §1962(c), Bossi conducted and participated, directly and 

indirectly, in the conduct of the affairs of Extreme Construction through a “pattern of 

racketeering” within the meaning of 18 U.S.C. §1961(5). 

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99. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XI

(RICO §1962(d) - The Extreme Construction Enterprise)

 

100. Plaintiffs repeat and reallege paragraphs 1 through 96, above, as though set forth 

in full herein. 

101. In violation of 18 U.S.C. §1962(d), defendants Burris, Linda Burris, Foy and 

Linda Burris, Inc. conspired among themselves and with Bossi to conduct and participate in the 

conduct of the affairs of Extreme Construction through a “pattern of racketeering” in violation of 

18 U.S.C. §1962(c). 

102. As a result of this violation of 18 U.S.C. §1962(d), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XII

(RICO §1962(c) - Pulaski Construction Enterprise) 

103. Plaintiffs repeat and reallege paragraphs 1 through 99, above, as though set forth 

in full herein. 

104. Defendant Pulaski is a “person” within the meaning of 18 U.S.C. §1961(3), and, 

as owner and president of Pulaski Construction, was “employed by” and “associated with” 

Pulaski Construction within the meaning of 18 U.S.C. §1962(c). 

105. Pulaski Construction is an “enterprise” within the meaning of 18 U.S.C. §1961(4) 

whose activities are in, or substantially affect, interstate trade and commerce. 

106. As set forth above and in Exhibit C, Pulaski used, and caused numerous uses of, 

the United States mails and interstate wires, including, but not limited to, the transmission 

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therein of false invoices, checks, and wires, in furtherance and as a result of the schemes and 

artifices to defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of these 

violations constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

107. Pulaski engaged in a “pattern of racketeering” because: (a) said crimes and illegal 

acts bore a relationship to each other by reason of having similar objects, methods of 

commission, common victims, and similar means of transmission, and all of which related to 

Burris’ fraudulent misuse of his position at the CareOne Companies; and (b) they were 

continuing in nature in that they continued for a substantial period of time and threatened to 

continue indefinitely until Burris was terminated in March 2009. 

108. In violation of 18 U.S.C. §1962(c), Pulaski conducted and participated, directly 

and indirectly, in the conduct of the affairs of Pulaski Construction through a “pattern of 

racketeering” within the meaning of 18 U.S.C. §1961(5). 

109. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XIII

(RICO §1962(d) - The Pulaski Construction Enterprise)

 

110. Plaintiffs repeat and reallege paragraphs 1 through 106, above, as though set forth 

in full herein. 

111. In violation of 18 U.S.C. §1962(d), defendants Burris, Linda Burris, Foy and 

Linda Burris, Inc. conspired among themselves and with Pulaski to conduct and participate in the 

affairs of the Pulaski Construction enterprise through a “pattern of racketeering” within the 

meaning of 18 U.S.C. §1961(5) and in violation of 18 U.S.C. §1962(c). 

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112. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XIV

(RICO §1962(c) - The Day Electrical Enterprise)

 

113. Plaintiffs repeat and reallege paragraphs 1 through 119, above, as though set forth 

in full herein. 

114. Defendants Yeager and DeAngelis are “persons” within the meaning of 18 U.S.C. 

§1961(3). 

115. As owner of Day Electrical, Yeager was “employed by” and “associated with” 

Day Electrical within the meaning of 18 U.S.C. §1962(c). Defendant DeAngelis was also 

“employed by” and “associated with” Day Electrical within the meaning of 18 U.S.C. §1962(c). 

116. Day Electrical is an “enterprise” within the meaning of 18 U.S.C. §1961(4) 

whose activities are in, or substantially affect, interstate trade and commerce. 

117. As set forth above and in Exhibit D, Yeager and DeAngelis used, and caused 

numerous uses of, the United States mails and interstate wires, including, but not limited to, the 

transmission therein of false invoices, checks, and wires, in furtherance and as a result of the 

schemes and artifices to defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of 

these violations constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

118. Yeager & DeAngelis engaged in a “pattern of racketeering” because: (a) said 

crimes and illegal acts bore a relationship to each other by reason of having similar objects, 

methods of commission, common victims, and similar means of transmission, and all of which 

related to Burris’ fraudulent misuse of his position at the CareOne Companies; and (b) they were 

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continuing in nature in that they continued for a substantial period of time and threatened to 

continue indefinitely until Burris was terminated in March 2009. 

119. In violation of 18 U.S.C. §1962(c), Yeager and DeAngelis conducted and 

participated, directly and indirectly, in the conduct of the affairs of Day Electrical through a 

“pattern of racketeering” within the meaning of 18 U.S.C. §1961(5). 

120. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XV

(RICO §1962(d) - The Day Electrical Enterprise) 

121. Plaintiffs repeat and reallege paragraphs 1 through 127, above, as though set forth 

in full herein. 

122. In violation of 18 U.S.C. §1962(d), defendants Burris, Linda Burris, Foy and 

Linda Burris, Inc. conspired among themselves and with Yeager and DeAngelis to conduct and 

participate in the affairs of the Day Electrical enterprise through a “pattern of racketeering” 

within the meaning of 18 U.S.C. §1961(5) and in violation of 18 U.S.C. §1962(c). 

123. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XVI

(RICO §1962(c) - DeAngelis Builders Enterprise) 

124. Plaintiffs repeat and reallege paragraphs 1 through 130, above, as though set forth 

in full herein. 

125. Defendant DeAngelis is a “person” within the meaning of 18 U.S.C. §1961(3). 

126. As owner of DeAngelis Builders, DeAngelis was “employed by” and “associated 

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with” DeAngelis Builders within the meaning of 18 U.S.C. §1962(c). 

127. DeAngelis Builders is an “enterprise” within the meaning of 18 U.S.C. §1961(4) 

whose activities are in, or substantially affect, interstate trade and commerce. 

128. As set forth above and in Exhibit E, DeAngelis used, and caused numerous uses 

of, the United States mails and interstate wires, including, but not limited to, the transmission 

therein of false invoices, checks, and wires, in furtherance and as a result of the schemes and 

artifices to defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of these 

violations constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

129. DeAngelis engaged in a “pattern of racketeering” because: (a) said crimes and 

illegal acts bore a relationship to each other by reason of having similar objects, methods of 

commission, common victims, and similar means of transmission, and all of which related to 

Burris’ fraudulent misuse of his position at the CareOne Companies; and (b) they were 

continuing in nature in that they continued for a substantial period of time and threatened to 

continue indefinitely until Burris was terminated in March 2009. 

130. In violation of 18 U.S.C. §1962(c), DeAngelis conducted and participated, 

directly and indirectly, in the conduct of the affairs of DeAngelis Builders through a “pattern of 

racketeering” within the meaning of 18 U.S.C. §1961(5). 

131. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XVII

(RICO §1962(d) - The DeAngelis Builders Enterprise)

132. Plaintiffs repeat and reallege paragraphs 1 through 138, above, as though set forth 

in full herein. 

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133. In violation of 18 U.S.C. §1962(d), defendants Burris, Linda Burris, Foy and 

Linda Burris, Inc. conspired among themselves and with DeAngelis to conduct and participate in 

the affairs of the DeAngelis Builders enterprise through a “pattern of racketeering” within the 

meaning of 18 U.S.C. §1961(5) and in violation of 18 U.S.C. §1962(c). 

134. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XVIII

(RICO §1962(c) - Borglund Associates, LLC and Tektonica Design, Inc. Enterprises) 

135. Plaintiffs repeat and reallege paragraphs 1 through 141, above, as though set forth 

in full herein. 

136. Defendant Borglund is a “person” within the meaning of 18 U.S.C. §1961(3). 

137. As owner of Borglund Associates, LLC and Tektonica Design, Inc., Borglund 

was “employed by” and “associated with” Borglund Associates, LLC and Tektonica Design, Inc. 

within the meaning of 18 U.S.C. §1962(c). 

138. Borglund Associates, LLC and Tektonica Design, Inc. are “enterprises” within the 

meaning of 18 U.S.C. §1961(4) whose activities are in, or substantially affect, interstate trade 

and commerce. 

139. As set forth above and in Exhibit F, Borglund used, and caused numerous uses of, 

the United States mails and interstate wires, including, but not limited to, the transmission 

therein of false invoices, checks, and wires, in furtherance and as a result of the schemes and 

artifices to defraud, in violation of 18 U.S.C. §1341 and 18 U.S.C. §1343. Each of these 

violations constitutes “racketeering activity” within the meaning of 18 U.S.C. §1961(1). 

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140. Borglund engaged in a “pattern of racketeering” because: (a) said crimes and 

illegal acts bore a relationship to each other by reason of having similar objects, methods of 

commission, common victims, and similar means of transmission, and all of which related to 

Burris’ fraudulent misuse of his position at the CareOne Companies; and (b) they were 

continuing in nature in that they continued for a substantial period of time and threatened to 

continue indefinitely until Burris was terminated in March 2009. 

141. In violation of 18 U.S.C. §1962(c), Borglund conducted and participated, directly 

and indirectly, in the conduct of the affairs of Borglund Associates, LLC and Tektonica Design, 

Inc. through a “pattern of racketeering” within the meaning of 18 U.S.C. §1961(5). 

142. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

COUNT XIX

(RICO §1962(d) - The Borglund Associates, LLC and Tektonica Design, Inc. Enterprises) 

143. Plaintiffs repeat and reallege paragraphs 1 through 149, above, as though set forth 

in full herein. 

144. In violation of 18 U.S.C. §1962(d), defendants Burris, Linda Burris, Foy and 

Linda Burris, Inc. conspired among themselves and with DeAngelis to conduct and participate in 

the affairs of the Borglund Associates, LLC and Tektonica Design, Inc. enterprises through a 

“pattern of racketeering” within the meaning of 18 U.S.C. §1961(5) and in violation of 18 U.S.C. 

§1962(c). 

145. As a result of this violation of 18 U.S.C. §1962(c), the CareOne Companies have 

been injured in its businesses and its property. 

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COUNT XX

(Fraud)

146. Plaintiffs repeat and reallege paragraphs 1 through 152 above, as though set forth 

in full herein. 

147. Defendants Burris, Linda Burris, Foy, DeAngelis, Heiler, Bossi, Pulaski, 

Borglund, Yeager, and Linda Burris Inc., directly and indirectly, engaged in such fraud, as 

described in detail in the Complaint and Exhibits. 

148. The CareOne Companies have been injured and have sustained damages as a 

result of Defendants’ fraud. 

COUNT XXI

(Civil Conspiracy)

149. The CareOne Companies repeat and reallege paragraphs 1 through 158, above, as 

though set forth in full herein. 

150. Defendants Burris, Linda Burris, Foy, DeAngelis, Heiler, Bossi, Pulaski, 

Borglund, Yeager, and Linda Burris Inc., directly and indirectly, conspired to, aided, abetted and 

facilitated the fraud and conversion, as described in detail in the Complaint and Exhibits. 

151. The CareOne Companies have sustained injuries and damages as a result of 

Defendants’ actions. 

WHEREFORE, the CareOne Companies demand judgment against Defendants: 

 (a) awarding plaintiffs’ compensatory and punitive damages, plus interest; 

 (b) awarding three-fold their damages sustained as a result of defendants’ 

RICO violations; 

 (c) awarding their reasonable attorney’s fees and costs of suit; and, 

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 (d) granting such other and further relief as the court deems just and proper. 

JURY DEMAND

Pursuant to Federal Rule of Civil Procedure 38(b), plaintiffs demand trial by jury on all 

issues triable by jury. 

Dated: May 6, 2010 GREENBERG TRAURIG, LLP 

200 Park Avenue, P.O. Box 677 

Florham Park, New Jersey 07932-0677 

(973) 360-7900

BY:Philip R. Sellinger

 Philip R. Sellinger, Esq. 

 Roger B. Kaplan, Esq. 

Attorneys for Plaintiffs 

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