Investor files 3rd amended complaint vs Quichocho, wife

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Posted on Jun 24 2011
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An investor has filed in federal court a third amended lawsuit against attorney Ramon K. Quichocho and his wife for allegedly engaging in racketeering activity and money laundering.

Jung Ja Kim filed the third amended complaint after the U.S. District Court for the NMI dismissed last month her second amended complaint for being deficient. The court had allowed Kim to cure the deficiency.

The Quichocho couple’s lawyer, Michael Dotts, previously stated that the complaint is just Kim’s “twisted story and is out of touch with reality.”

Dotts said the complaint is severely detective even after more than a year of Kim trying to get it right by filing amended complaints.

In his third try, Kim, through counsel Colin M. Thompson, is suing Quichocho and his wife, Frances Quichocho, the Quichocho’s law firm, and the couple’s company, Karissa LLC, for violation of the Racketeer Influenced and Corrupt Organizations Act, RICO, conversion, fraud, and constructive trust.

She is also suing Quichocho and his law firm for legal malpractice-professional negligence, and legal malpractice-breach of fiduciary duty.

Kim is also suing the Quichocho couple and the Quichocho law firm for breach of lease agreements.

She is seeking damages, court costs, and attorney’s fees and wants the court to establish that all assets, benefits, moneys, or assets received by the Quichochos from Latte Stone LLC and Tan Dingo LLC were held in trust for her benefit.

According to Thompson in the complaint, the Quichochos acquired control of Tan Dingo and Latte Stone through a pattern of racketeering activity. Thompson said the Quichochos used Latte Stone’s bank account in the Bank of Guam to conceal or disguise the source and ownership of the funds generated by poker machines that the Quichochos wrongfully acquired from Kim through wire fraud.

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