Millennium Franchise Group, LLC v. Bank of America, N.A.

I. BACKGROUND

25 A. Factual Allegations 26 Millennium is an active limited liability company that conducts business in the State 27 of California. Am. Compl. ¶ 1. Millennium also does business as Hacking Solutions. Id. ¶ 8. Anthony Beaman (“Beaman”) is its founder and President. Id. Defendant Lynx is a limited liability company in the State of New York. Id. ¶ 2. Defendant Aric K. is a resident of the State of Pennsylvania and is the chairman of the board, founder, and advisor of Lynx. Id. ¶ 3. Defendant Aric D. is a resident of the State of Pennsylvania and was an employee of Lynx. Id. ¶ 4. Beaman and Aric K. opened a JP Morgan Chase (“JPMC”) bank account to process and pay Hacking Solutions’ payroll. Id. ¶ 11. They were each a signatory to the account. Id. ¶ 12. Millennium alleges that Beaman later discovered that Aric K. and Aric D. secretly opened a Bank of America (“BOFA”) bank account under Millennium’s name without authorization. Id. ¶ 12. Aric K. and Aric D. then instructed Millennium’s clients to make payments to the unauthorized BOFA account, not the authorized JPMC account as Beaman and Aric K.…