Attorneys for Plaintiff Justin K. Prince
IN THE FOURTH JUDICIAL DISTRICT COURT UTAH COUNTY, STATE OF UTAH
Justin K. Prince, an individual, Plaintiff, vs.
Modere, a business enterprise that is part of Maple Mountain Enterprises, Inc., a Nevada corporation; Maple Mountain Group, Inc., a Utah corporation (formerly known as Neways, Inc.), dba Neways, Inc.; James J. Zenni Jr., an individual; George Russell, an individual; Z Capital Partners, LLC, a Delaware Limited Liability Company; Z Capital Commercial Finance L.L.C.;
Z Capital Group, LLC, a Delaware limited liability company; and John Does 1-99, Defendants.
COMPLAINT
Discovery Tier 3
Plaintiff Justin K. Prince (“Justin”) hereby alleges and complains against the Modere Defendants, Z Capital Defendants, and John Does 1-99 as follows:
INTRODUCTION
1. Until recently, Justin was the largest distributor for a multi-level marketing business enterprise known as “Modere.”
2. Justin went from selling products out of a mall kiosk with no college education to becoming an equity holder/partner in the company and the number one earner at Modere, generating during his time there over $2.5 billion dollars in total revenue and over 4 million customers.
3. Modere came under the control of a private equity investor, Z Capital. Revenues grew and Z Capital seized an opportunity to restructure its debt on the back