corporate instrumentalities
shell entity
count (пункт искового заявления?)
proceeds
plethora of improprieties

Спасибо за помощь!

V. FACTS COMMON TO ALL COUNTS (a)

Corporate Instrumentalities and Agents of Defendants

Defendants used in their enterprise a significant number of corporate
instrumentalities, essentially all being shell entities, none of which operated for real
business purposes, that are identified below.

Defendants misappropriated proceeds, in particular, through Hines Investments, S.A. and
Pine Brook S.A., both Panamanian offshore companies, Okke Financial Ltd. Alcina
Company Corp., and Pington Investments Ltd., all three being Belize offshore
companies. On admissions, more than $5 million was routed to those offshore accounts.

On June 16, 2006, Turan filed a complaint, Docket No. 06cv3795, against KEC
and Bektayev in the U.S. District Court for the Central District of California, essentially
alleging breach of contract and a plethora of improprieties. That complaint was brought
in bad faith, because Turan refused to cooperate in discovery and did not intend to bring
the case to trial.