37.  Plaintiffs bring this action on their behalf and as a class action pursuant to Rules  23(a) & (b)(3) of the Federal Rules of Civil Procedure on behalf of all persons or entities who  purchased any “investment” offered by Defendants from May 6, 2006 until the present day (the  “Class Period”) and who suffered damages as a result (the “Class”).   38.  Excluded from the Class are: a. Defendants; b. members of the immediate family  of each of the Defendants that are not corporate entities; c. any person who was an executive  officer, employee and/or director of any Defendant during the Class Period; d. any person, firm,  trust, corporation, officer, director or any other individual or entity in which any Defendant has a  controlling interest or which is affiliated with any of the Defendants; e. any independent  contractor of any Defendants who participated in the sales of the investment  vehicles outlined  herein; and f. the legal representatives, agents, affiliates, heirs, successors-in-interest or assigns  of any such excluded party.   40.  Plaintiffs‟ claims are typical of the claims of members of the Class. Plaintiffs and  all members of the Class sustained damages as a result of the Defendants‟ unlawful course of  conduct including racketeering, money laundering, fraud, negligence, conversion, breach of  fiduciary duty, and fraud and other malfeasance as specified herein.   41.  Plaintiffs will fairly and adequately protect the interest of the members of the  Class and has retained counsel competent and experienced in class action litigation. Plaintiffs  have no interests that are contrary to or in conflict with those of the members of the Class that  Plaintiffs seek to represent.   42.   A class action is superior to other methods for the fair and efficient adjudication  of this controversy. The damages suffered by individual Class members may be relatively small,  some as little as $5,000; therefore the expense and burden of individual litigation make it  virtually impossible for the Class members individually to seek redress for the wrongful conduct  alleged herein.   44.   Plaintiffs know of no difficulty that will be encountered in the management of  this litigation that would preclude its maintenance as a class action.   45.   The names and addresses of the Defendants‟ customers and investors who  purchased “investments”  during the Class Period are obtainable from information in the  possession of the Defendants and/or their agents. Notice can be provided to such owners via first  class mail or email using techniques and a form of notice similar to those customarily used in  class actions.  46.  TAYLOR has always claimed to come from humble beginnings and bragged that  he started working at 12 and became a millionaire at the ripe old age of 16.  Then he “retired”  with his “vast fortune” but became “bored” and came back to work in 2000.   47.   Beginning in 2000,TAYLOR started touting himself to the public as a “self-made  millionaire at 16” by claiming that in 1998 he launched a company with a high school partner  called GoFerretGo.com that became a multi-million dollar company.     49.   TAYLOR repeatedly claimed in books, newspapers, television interviews,  emails, radio ads and You Tube videos that GoFerretGo.com had a value of $3.5 million at some  point during its less than 3 year history.   However, GoFerretGo.com mysteriously dissolved in  2001.   50.  TAYLOR tirelessly told the GoFerretGo.com story to potential investors, news  and TV reporters, church members, politicians, community leaders, etc. over many years in order  to garner their trust and gain access to other potential investors, who would be introduced to  TAYLOR through trusted members of their community, i.e., church leaders and pastors,  politicians, philanthropic leaders, etc.   51.  In 2004, Defendant TAYLOR formed Christian Capital Group, LLC (“Christian  Capital”), a Missouri limited liability company.  Defendant TAYLOR was the “executive  trustee” of Christian Capital. Throughout his meteoric rise to fame, TAYLOR always went back  to his roots, scamming mainly African-American and minority persons of faith with his  investment schemes.   52.  TAYLOR targeted minority and African American persons of faith because he  knew that there was an unwritten (and sometimes written) tenet imposed upon church members,  particularly in African-American and Christian churches, which can best be described as “what  happens in church stays in church.” The tenets of many Christian religions require disputes  among church members to be handled by the church through its Elders, Deacons and Minister  (assuming the Minister is not involved).     54.  TAYLOR was a master at using verbal constructions to describe the investment  “opportunities” he was hawking so that they sounded extremely impressive but actually were  meaningless. TAYLOR used his confidence trick to take advantage of his targets‟ lack of  investment knowledge. TAYLOR served as a “hub” for the victims recruiting and interacting  with them directly in order to perpetuate the scheme.   55.  The Ponzi schemes orchestrated by the CITY CAPITAL CONSPIRATORS were  particularly well planned because the “investments” of the Plaintiffs and other Class members  were set up to automatically renew or “rollover” each year such that the investors could not  liquidate their investments automatically at the end of the investment period and, in fact, were  not even notified at the end of any investment period that they could withdraw their investment  funds or” choose” to reinvest; the interest that purportedly was being earned on the investment  “appeared” in the investors/victims‟ self-directed IRA accounts at EQUITY TRUST  automatically and regardless of whether the accrued interest had actually been placed in the  account.  (It had not for the majority of investors/victims).     56.  The CITY CAPITAL CONSPIRATORS kept sending out investment account  statements and providing information to investors/victims showing the CITY CAPITAL  investors/victims the extraordinary investment returns they were earning by keeping their money  in their EQUITY TRUST self-directed IRA account thus maintaining the deception that the  schemes of the CITY CAPITAL CONSPIRATORS were providing high returns.    58.  Investors conned by the CITY CAPITAL CONSPIRATORS would reinvest their  money in these schemes because they appeared to pay a much better return than any alternative  investment opportunity. At least the returns appeared much better according to their EQUITY  TRUST account statements.   59.   According to a press release issued by a Missouri entity called ”Christian  Capital” and TAYLOR, Christian Capital was a non-profit ministry “that employs biblical  principles to help individuals increase their financial resources through low-risk investment  opportunities.” (Ex. A). TAYLOR frequently reminded his targets that these were “once in a  lifetime” opportunities and that the potential investor needed to move fast or lose their place in  line for this investment “opportunity.”    60.   TAYLOR in 2004 made investment presentations for the “Prosperity Fund” a/k/a  Prosperity Ministries run by Christian Capital at minority and African-American churches in  Michigan, North Carolina, Pennsylvania and Tennessee.  (Ex. A).     61.  Taylor at times referred to himself as a “Minister” and an “ordained Minister.”   62.  Upon information and belief, TAYLOR never had any formal seminary training  nor had he ever been the minister or leader of a church.    64.   Defendant TAYLOR advertised that participation through investment in the  Prosperity Fund would help participants, many of whom were church-goers who heard  TAYLOR speak at their church, learn about how to: “eliminate consumer debt without  consolidation or refinancing; retire in 10 years or less; and be a part of a low-risk investment  with high performances” which were also “beneficial to the financial success of the church and  community.” (Ex. B).     65.  TAYLOR told the potential Prosperity Fund investors that God had helped him  find the perfect investment opportunity for the church and its members. This investment scam by  TAYLOR was a prelude to the Socially Conscious Investment Ponzi Scam of which Plaintiffs  and other Class members are victims, as discussed below.   66.  In September of 2004, TAYLOR was sued for fraud in the case of Williford et al  v. Ephren Taylor, Jr. (“Williford Complaint”) in Missouri both personally and as trustee of the  Prosperity Ministries trust.  Also named as defendants in the suit were his wife, Meshelle Taylor,  his father, (also named Ephren Taylor) and his father‟s church, Johnson County Church of Christ  (“Johnson County Church”).  (Ex. C).    67.  After this set back, rather than give up on his scams, TAYLOR decided to go  bigger.   69.   TAYLOR started holding himself out to the public in books, newspapers,  television, emails, radio ads and videos as a successful businessman overseeing $250 million  dollars in assets of two publicly traded companies.   70.  An essential part of TAYLOR‟S scam, as with other Ponzi schemes, was and is to  make investors want to invest in him via his wildly successful “companies.”  While some of  TAYLOR‟S investment success “stories” and personal financial dealings may have been real, the  majority of them were purely fabricated.    71.  Upon information and belief, Defendants BRANTLEY, WEB3 and MCCARTHY  were instrumental in helping TAYLOR create the fictional character that TAYLOR assumed and  which permitted him to bilk millions of dollars from hundreds or thousands of investors.   72.  Through numerous press releases and hundreds of speaking engagements, books,  blogs, You Tube videos, radio and television commercials and interviews and public  appearances, TAYLOR convinced the world that he was a “Minister,” financial guru, investment  wizard, multi- million dollar business manager and philanthropic rock star.   73.   A Ponzi scheme or fraudulent enterprise cannot be successful or even operate  without the help of a number of individuals both inside and outside the company perpetuating the  scheme.  The facts will show that TAYLOR was part of a carefully orchestrated con-not a solo  act.     A.  THE CREATION OF EPHREN TAYLOR'S IMAGE    CONSPIRACY  (against all Defendants)  502.  Plaintiffs incorporate by reference and reallege herein paragraphs 1-503 above as  if fully set forth herein.  503.  At all relevant times, all Defendants joined in a common effort to commit the  tortuous conduct and violations of state and federal law alleged in this complaint.  504.  Defendants made their fraudulent misstatements and committed fraud as alleged  above in part in order to induce Plaintiffs and the other Class members to invest in CITY  MONEY LAUNDERING  (Against all Defendants)  451.  Plaintiffs incorporate by reference and reallege herein paragraphs 1-450 above as  if fully set forth herein.  452.   Further, as part of Defendants‟ operation of the Socially Conscious Investment  Ponzi Scam and the Sweeps Machine Investment Ponzi Scam, they engaged in, and otherwise  caused, numerous financial transactions and transfers through financial institutions in the United  States, which transactions violated 18 U.S.C. Sections 1956 and 1957.  453.  Defendants committed acts of money laundering, namely financial transactions, to  promote their unlawful misappropriation of investor funds in violation of 18 U.S.C. Section 1956  (a) (1) (A) and to conceal their unlawful activity in violation of 18 U.S.C. Section 1956 (a) (1)  VIOLATION OF NORTH CAROLINA SECURITIES ACT  Chapter 78A-10  (Against all Defendants)   542. Plaintiffs incorporate by reference and reallege herein paragraphs 1-541 above as  if fully set forth herein.  543.  The acts and practices of the Defendants alleged herein violated Chapter 78A-10  of the North Carolina Securities Act, in that Defendants made, or caused to be made,  representations or statements which were false, where (i) they knew the truth, or (ii) with  reasonable efforts could have known the truth, or (iii) made no reasonable effort to ascertain the  truth, or (iv) did not have knowledge concerning the representations or statements made, where  said representations or statements were engaged in to induce or promote the issuance,  distribution, exchange, sale, negotiation, or purchase within or from this state of securities.  VIOLATION OF NORTH CAROLINA SECURITIES ACT Chapter 78A-11  (Against all  Defendants)  546.  Plaintiffs repeat and re-allege paragraphs 1 through 545 above as if fully incorporated  herein.    547.  The acts and practices of the Defendants alleged herein violated Chapter 78A-11 of  the North Carolina Securities Act, in that they involved the use or employment of a fraud, deception,  concealment, suppression, or false pretense, where said uses or employments were engaged in to  induce or promote the issuance, distribution, exchange, sale, negotiation, or purchase within or from  this state of securities by the use of unlawful telephone rooms in violation of Chapter 78A-11. 