1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  24.  Defendant Singer owned The Key and served as Chief Executive Officer of KWF.      25.  The Key was a for-profit college counseling and preparation business that Singer  founded in or about 2007 and incorporated in the State of California in or about 2012.   26.  KWF was a non-profit corporation in Newport Beach, California, that Singer  established as a purported charity in or about 2012.    Plaintiffs KERI FIDELAK, LAUREN FIDELAK, TYLER BENDIS, JULIA BENDIS,   KALEA WOODS, JAMES JOHNSON and NICHOLAS JAMES JOHNSON, individually and on  behalf of all others similarly situated, brings this action based upon personal knowledge as to  themselves and their own acts, and as to all other matters upon information and belief, based upon,  inter alia, the investigations of their attorneys.   