`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 1 of 40
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`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF FLORIDA
` Fort Lauderdale Division
`
`CASE NO. ____________________
`
`
`
`ABS HEALTHCARE SERVICES, LLC,
`HEALTH OPTION ONE, LLC, AND
`ONE STOP QUOTES, INC.,
`
`
`Plaintiffs,
`
`
`
`
`
`
`
`
`
`
`
`
`v.
`
`ANDREW SHADER, COREY SHADER,
`NATIONAL HEALTH SOLUTIONS, INC.,
`INFINIX MEDIA LLC, PRODIGY
`HEALTH GROUP LLC, ADAM
`BEEMAN, JOY STORMONT,
`ALLIANCE MARKETING CORPORATION,
`KRATOS INVESTMENTS LLC, HEALTH
`TEAM ONE LLC, RICHARD RYSCIK,
`SCOTT OFFUTT, BEEMAN’S FUTURE INC.,
`CS MARKETING LLC, and C SHADER
`INVESTMENTS LLC,
`
`
`Defendants.
`____________________________________/
`
`
`
`
`COMPLAINT
`
`Plaintiffs ABS Healthcare Services, LLC (“ABS”) and Health Option One, LLC, (“HOO”),
`
`both doing business as Insurance Care Direct (referred to collectively herein as “ICD”), and
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`Plaintiff One Stop Quotes, Inc. (“One Stop Quotes”), sue Defendants Andrew Shader and Corey
`
`Shader (collectively, the “Shaders”), National Health Solutions, Inc. (“NHS”), Infinix Media LLC
`
`(“Infinix”), Prodigy Healthy Group LLC (“Prodigy”), Adam Beeman (“Beeman”), Joy Stormont
`
`(“Stormont”), Alliance Marketing Corporation (“Alliance”), Kratos Investments LLC (“Kratos”),
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`Health Team One LLC (“Health Team”), Richard Ryscik (“Ryscik”), Scott Offutt (“Offutt”),
`
`
`
`1
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`

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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 2 of 40
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`Beeman’s Future Inc. (“BFI”), CS Marketing LLC (“CS Marketing”), and C Shader Investments
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`LLC (“CSI”) (collectively “Defendants”) and allege upon personal knowledge as to Plaintiffs’
`
`own acts and status, and upon information and belief as to all other matters, as follows:
`
`
`
`NATURE OF THE CASE
`
`1.
`
`This case is about dishonesty, fraud, and greed. Defendants saw that ICD, a
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`family-owned business, had achieved great success and they sought to profit from ICD’s years of
`
`hard work, development, and ingenuity. To that end, Defendants devised a criminal scheme to
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`misappropriate, among other things, ICD’s confidential information, trade secrets, customers, and
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`business through a pattern of racketeering activity spanning years and continuing today.
`
`2.
`
`Defendants, acting in concert, have unlawfully, knowingly, and intentionally
`
`conducted, and are continuing to conduct, through a pattern of racketeering activity an enterprise
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`referred to herein as the “ICD Misappropriation Enterprise,” an association in fact.
`
`3.
`
`The purpose of the ICD Misappropriation Enterprise (or the “Enterprise”) was to
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`surreptitiously and illicitly compete with ICD and steal ICD’s proprietary trade information, trade
`
`secrets, business model, agents, and customer base in order to profit for themselves and to harm
`
`ICD.
`
`4.
`
`The Enterprise was hatched, funded, and directed by Defendants Andrew and
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`Corey Shader, two brothers, working with their close friend and former employee, Defendant
`
`Adam Beeman, their confidant, Defendant Scott Offutt, Beeman’s mother, Defendant Joy
`
`Stormont, and Beeman’s best friend, Defendant Richard Ryscik. While working under non-
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`compete agreements with ICD, the Shaders plotted and started to set up the Enterprise.
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`5.
`
`The Shaders worked in concert with the other Defendants to open competing
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`businesses using figureheads and fraudulently concealing the real owners—so as to go
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`
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`2
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 3 of 40
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`undetected—and induce ICD and others to do business with them. These businesses improperly
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`used information about ICD’s business that was obtained by the Shaders and others during the
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`course of their years of work for ICD.
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`6.
`
`The Shaders developed and built the Enterprise by recruiting individuals whom
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`they could easily threaten and control, including felons involved with drug trafficking. The
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`Shaders dangled the promise of quick riches to pull others into the Enterprise, and obtained their
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`loyalty and silence through intimidation, threats, and bribes. On more than one occasion, the
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`Shaders recruited individuals into the Enterprise out of drug rehab programs. On at least one
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`occasion, a past participant in the Enterprise relapsed under the stress of the Enterprise’s illegal
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`activities and died due to an overdose.
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`7.
`
`To prevent ICD from discovering their criminal scheme, Defendants, among other
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`tactics, utilized fakes names or aliases in their business dealings, set up front companies, installed
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`“figureheads” such as Defendants Stormont and Ryscik to purport to run those front companies,
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`and communicated on temporary “burner” phones rather than their primary cellphones.
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`8.
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`But Defendants were unable to fully hide their fraud and deception and, as is often
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`the case, their text messages and fund transfers have left a trail. The money trail leads directly to
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`Defendants, and the text message trail reveals Defendants’ efforts to conceal facts of their scheme
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`and fabricate a “clean” story.
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`9.
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`ICD and One Stop Quotes bring this action for damages and injunctive relief
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`because Defendants have refused to cease their illegal enterprise and have caused (and continue to
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`cause) ICD and One Stop Quotes substantial harm. Defendants’ acts of racketeering have already
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`caused tens of millions of dollars of harm to ICD and One Stop Quotes, and that harm is continuing.
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`
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`3
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 4 of 40
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`
`
`THE PARTIES
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`10.
`
`Plaintiff ABS is a Florida limited liability company headquartered in Deerfield
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`Beach, Florida.
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`11.
`
`Plaintiff HOO is a Florida limited liability company headquartered in Deerfield
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`Beach, Florida, and acts as a licensed general insurance agency that provides marketing and
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`compliance support and access to products including, but not limited to, limited medical, short
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`term medical, term life, final expense, accidental death, critical illness, dental and discount medical
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`coverage and services such as telehealth access to sub-agencies.
`
`12.
`
`Plaintiffs ABS and HOO do business under the name Insurance Care Direct,
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`commonly referred to as “ICD.”
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`13.
`
`Plaintiff One Stop Quotes is a Florida corporation headquartered in Deerfield
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`Beach, Florida, that markets Medicare insurance coverage. One Stop Quotes is owned by the co-
`
`founders of ICD.
`
`14.
`
`15.
`
`16.
`
`17.
`
`Defendant Andrew Shader is a resident of Broward County, Florida and is sui juris.
`
`Defendant Corey Shader is a resident of Broward County, Florida and is sui juris.
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`Defendant Scott Offutt is a resident of Broward County, Florida and is sui juris.
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`Defendant NHS is a Florida corporation doing business in Florida and
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`headquartered at 2425 E. Commercial Blvd., Suite 300, Fort Lauderdale, FL 33308. At all times
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`relevant hereto, Andrew Shader was the President of NHS.
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`18.
`
`Defendant Infinix is a Florida limited liability company doing business in Florida
`
`and headquartered at 2425 E. Commercial Blvd. Suite 300, Fort Lauderdale, Florida 33308.
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`Infinix is owned and controlled by Andrew and Corey Shader.
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`
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`4
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 5 of 40
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`19.
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`Defendant CSI is a Florida limited liability company headquartered in Fort
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`Lauderdale, Florida. CSI is owned and controlled by Defendant Corey Shader.
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`20.
`
`Defendant CS Marketing is a Florida corporation headquartered in Fort Lauderdale,
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`Florida. CS Marketing is owned and controlled by Defendants Corey Shader and Scott Offutt.
`
`21.
`
`Defendant Prodigy is a Florida corporation headquartered at 551 NW 26th Street,
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`Pompano Beach, Florida 33064. Prodigy is licensed as an insurance agency in Florida, among
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`other states.
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`22.
`
`Defendant Adam Beeman is a resident of Broward County and is affiliated with
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`Prodigy, Kratos, and Health Team and is sui juris.
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`23.
`
`Defendant Joy Stormont is a resident of Palm Beach County and a purported owner
`
`of Prodigy and is sui juris.
`
`24.
`
`Defendant Alliance is a Florida corporation and headquartered at 2425 E.
`
`Commercial Blvd., Suite 101, Fort Lauderdale, FL 33308, and is affiliated with Defendant NHS
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`and is owned by Defendants Corey Shader and Andrew Shader.
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`25.
`
`Defendant Kratos is a Florida limited liability company headquartered in Miami
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`Dade County, Florida. Kratos is a licensed 21-05 Florida insurance agency.
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`26.
`
`Defendant Health Team is a Florida limited liability company headquartered in
`
`Doral, Florida.
`
`27.
`
`Defendant Ryscik is a resident of Broward County, Florida and is sui juris. Ryscik
`
`is the purported president of Kratos. He is also listed as the authorized representative of Health
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`Team.
`
`28.
`
`Defendant BFI is a Florida corporation headquartered in Fort Lauderdale, Florida.
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`BFI is owned and controlled by Adam Beeman.
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`
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`5
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 6 of 40
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`
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`JURISDICTION AND VENUE
`
`29.
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`This court has subject matter jurisdiction over Plaintiffs’ claims under 28 U.S.C.
`
`§ 1331, and under 18 U.S.C. § 1964.
`
`30.
`
`The Court has personal jurisdiction over Defendants because each Defendant has
`
`engaged in a pattern of racketeering activity that both occurred within and targeted this District.
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`In addition, Defendants Andrew Shader, Corey Shader, Adam Beeman, Richard Ryscik, Joy
`
`Stormont, Scott Offutt, CSI, CS Marketing, Beeman’s Future, NHS, Infinix, Alliance Marketing,
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`Kratos, Prodigy, and Health Team reside or have their primary place of business within this
`
`District.
`
`31.
`
`Venue is proper in this District under 28 U.S.C. § 1391(b)(2), as “a substantial part
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`of the events or omissions giving rise to the claim occurred” in or impacted this District.
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`
`
`A. ICD’s Business
`
`FACTUAL BACKGROUND
`
`32.
`
`ICD is a family-owned business established in 2001, which has grown into one of
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`the nation’s largest health and life insurance agencies.
`
`33.
`
`Among other things, ICD offers insurance plans and tailored memberships that
`
`include health benefits, products, and services (“ICD Plans”) to individuals. The ICD Plans
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`include insurance underwritten by a diverse group of benefit companies and insurance carriers.
`
`34.
`
`Individuals become insureds under the ICD Plans by becoming members of the
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`association or other group to which a master group insurance policy has been issued by the
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`insurance carrier. Association membership provides access to benefit services such as telehealth.
`
`35.
`
`To market and sell ICD Plans, ICD enters into contracts with, among others,
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`insurance agencies and insurance agents.
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`
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`6
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 7 of 40
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`36.
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`ICD identifies prospective customers by purchasing “leads” from third parties or
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`by acquiring “leads” through an affiliated subsidiary. These leads consist of the names of
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`individuals who have expressed a desire to obtain health insurance or benefits through insurance
`
`plans such as the ICD Plans.
`
`37.
`
`ICD markets to these prospective customers through insurance agencies with which
`
`it contracts. The insurance agencies are licensed under the laws of the applicable states, including
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`Florida. The insurance agencies operate call centers which place calls to the prospective customers
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`identified in the leads provided by ICD and market the ICD Plans to them.
`
`38.
`
`The individuals who staff the call centers and actually make the sales calls to
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`prospective customers are insurance agents licensed under the laws of the applicable states,
`
`including Florida. The agents list their licenses under the insurance agencies that have contracted
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`with ICD.
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`
`
`B. The Shaders Begin Working for ICD
`
`39.
`
`The Shaders began working for ICD in 2013, which is how they hatched their plan
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`to misappropriate ICD’s business for their own profit, and to sabotage ICD’s business operations
`
`to prevent ICD from effectively competing with the Shaders’ companies. The Shaders are the
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`ringleaders of Defendants’ scheme, but the Enterprise is held together by the coordinated acts of
`
`each individual participant.
`
`40. When Corey Shader first interacted with ICD, he was working at a call center run
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`by his parents and was cycling in and out of rehab. ICD then brought Corey into ICD and taught
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`him how ICD ran its business, including its proprietary and industry-leading distribution model.
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`Corey then brought his brother, Andrew, into the insurance business.
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`7
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 8 of 40
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`41.
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`By 2014, Andrew Shader and the Shaders’ wholly-owned company, NHS, had
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`entered into an exclusive contractual relationship with ICD. NHS is an insurance agency, and was
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`required to market ICD Plans pursuant to its 2014 contract with ICD. This contractual relationship
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`was extended via a further agreement and addenda executed in 2015 and 2016.
`
`42.
`
`During this period, ICD employees conducted trainings for NHS, the Shaders, and
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`their call centers, including through revealing confidential and proprietary information and trade
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`secrets to the Shaders and NHS.
`
`43.
`
`Eventually, the Shaders were making millions of dollars through their business
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`dealings with ICD.
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`C. Defendants Develop a Scheme to Steal ICD’s Trade Secrets, Customers, and
`Business
`
`44. While under contract with ICD, by no later than 2018, the Shaders and NHS,
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`working closely with Adam Beeman, one of their confidants, developed a scheme to set up
`
`businesses—many of which are run by Beeman—that would impermissibly compete with ICD.
`
`45.
`
`In 2018, at the same time that they were negotiating a new contract with ICD, the
`
`Shaders were already plotting to steal key components of ICD’s business, including its trade
`
`secrets and customers, in order to establish these illicit competing businesses.
`
`46.
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`The Shaders’ plot is evidenced by a series of meetings and communications that
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`occurred during these contract negotiations. Beginning in or around November 2018, each of the
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`Shaders fraudulently represented to ICD that they wanted to leave the insurance business. In truth,
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`the Shaders did not intend to get out of the business. Instead, they were already working to
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`establish competing businesses that would not have any contractual obligations to ICD.
`
`47.
`
`As Corey Shader wrote in a November 18, 2018, text message, his brother “Andrew
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`wants to take a year off and come back Cohen free,” referring to Seth Cohen, one of ICD’s
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`
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`8
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 9 of 40
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`founders. But Corey Shader then wrote “we can’t stop for a year” because there was “Too much
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`market share to lose.”
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`48.
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`Because of their desire not to lose market share, beginning in December 2018 and
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`leading into January 2019, Corey and Andrew Shader negotiated via email, phone, and text with
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`ICD to establish a new contractual relationship with ICD based on the false representation that the
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`Shaders were transitioning out of the insurance industry.
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`49.
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`Both Corey and Andrew Shader, through phone and text messages, repeatedly
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`represented to ICD that they were transitioning out of the industry, and that they would need a new
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`contractual basis for their remaining business relationship with ICD.
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`50.
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`Corey Shader subsequently held a series of meetings with the agents working in his
`
`call centers wherein he falsely claimed that he and Andrew had decided to exit the insurance
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`business.
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`51.
`
`On January 19, 2019, ICD and the Shaders entered into an Agreement for Payment
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`of Fees, Compensation and Residuals, as amended (the “Agreement”). Pursuant to the Agreement,
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`their company, NHS, was required to exclusively market the ICD Plans. Section 5 of the
`
`Agreement provides in relevant part that the Shaders cannot solicit an actual or prospective
`
`customer of ICD or solicit independent marketers producing significant sales for ICD:
`
`“Non-Competition, Non-Solicitation. For the period commencing on the
`Effective Date and ending three (3) years thereafter, none of the NHS Parties will
`knowingly, (a) encourage any person known by them to be a then current active
`customer or member, or known by them to be a then prospective customer or
`member in current and active negotiation for a Membership Plan (collectively,
`“Members”) with the ICD Parties, that such Member should change to the health
`insurance program or health products or services of a company other than those
`provided by the ICD Parties or their current carriers or discount plans, or (b) solicit
`or contract with any independent marketer known by them to be then currently
`producing significant sales for either of the ICD Parties, or any known significant
`competitor of ABS or HOO, in a field which directly and materially then competes
`with the ICD parties.”
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 10 of 40
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`Section 5 of the Agreement also provides in relevant part that the Shaders’ company
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`52.
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`Infinix’s ability to sell healthcare leads is limited as follows:
`
`“This paragraph (5) does not apply to independent marketers or agents used
`by either of the ICD parties in connection with Medicare products, including, but
`not limited to, “Medicare advantage” or Medicare supplements. It is agreed by the
`Parties that this Agreement does not apply to Infinix Media, Inc. (“Infinix”) or to
`its business activities, with the exception of the provisions of this Section 5 solely
`with respect to the sale of healthcare plans (the “Plan Exception”). The Plan
`Exception will terminate and no longer be applicable to Infinix upon the sale of a
`majority or controlling interest of its ownership.”
`
`53.
`
`Infinix provides “leads,” which are the names of individuals who have expressed a
`
`
`
`desire to obtain health insurance or benefits.
`
`54.
`
`The Agreement was amended on January 29, 2019, to add the following provision
`
`with respect to Section 5:
`
`Notwithstanding any language to the contrary in the “Agreement for
`Payment of Fees, Compensation, and Residuals", ("Agreement") (executed by the
`NHS Parties on January 19, 2019), the ICD Parties now agree that the NHS Parties,
`and their affiliated Alliance Marketing Corp, may only offer, sell and bill for
`Wellness, Lab and Dental plans through downlines/agents identified in "Exhibit C"
`to the Agreement. The NHS parties have been made aware that such
`downline/agents should first offer and sell ICD Party core and addon products prior
`to offering any other product. This paragraph shall take precedence over any
`contrary or conflicting terms set forth in the Agreement.
`
`As a result of the amendment, the Shaders and NHS were permitted to market other
`
`55.
`
`insurance plans, but only after first offering and selling ICD core and add-on products.
`
`56.
`
`In accordance with the Agreement, the Shaders and NHS represented that, through
`
`call centers, they would solicit customers for ICD products. But the Shaders and NHS never
`
`intended to abide by the Agreement. Nor did they disclose to ICD that they were already in breach
`
`of their obligations to ICD and were working with Beeman to set up illicit competing businesses.
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`10
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 11 of 40
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`57.
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`To avoid detection by both ICD and regulators, the Shaders and Beeman hid
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`Beeman’s involvement in the businesses, setting up figureheads that supposedly “owned” the
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`competing companies, but in fact did not. The Shaders and Beeman then had former ICD agents
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`or people with knowledge of ICD’s business operation and trade secrets serve as “managers” of
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`the businesses, which Beeman and the Shaders in fact operated.
`
`58.
`
`To carry out the scheme, the Defendants have conspired with others, including
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`exclusive licensed agents of ICD, to steal ICD’s business by, among other things, setting up sham,
`
`competing entities, interfering with the ICD Exclusive Agent Agreements, illicitly soliciting ICD’s
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`customers and prospective customers, and misappropriating ICD’s confidential information and
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`trade secrets.
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`59.
`
`Even with the Enterprise already in motion, and with the Shaders and other
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`Defendants already having set up competing businesses built upon information and trade secrets
`
`stolen from ICD, the Shaders continued to fraudulently represent to ICD, including through phone
`
`conversations, emails, text messages, and otherwise, that they would not engage in the very illegal
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`conduct they had, in fact, been engaging in.
`
`60.
`
`Instead of complying with the Agreement, Defendants have engaged in a scheme
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`by which they solicit customers for Plans offered by agencies other than ICD. In this way,
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`Defendants are improperly soliciting ICD’s actual and prospective customers and illegally
`
`competing with ICD. Utilizing Corey and Andrew Shader’s network of businesses that they
`
`control and operate, such as NHS, Infinix, Alliance, CS Marketing, and CSI, the Defendants have
`
`worked to create an underground parallel operation to provide the foundation for the Enterprise.
`
`61.
`
`Defendant Alliance is in the business of selling ancillary insurance products. Like
`
`Infinix, Defendant CS Marketing is involved in the identification of prospective customers.
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`11
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 12 of 40
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`Defendant CSI is Corey Shader’s personal management company that represents his interests in
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`his assorted network of businesses. All three businesses, alongside NHS and Infinix, are controlled
`
`by Corey and Andrew Shader.
`
`62.
`
`In reliance upon Defendants’ fraudulent misrepresentations, Plaintiffs permitted
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`Defendants to continue working for ICD and to continue having access to the trade secrets,
`
`customers, and other valuable information that Defendants stole to run their competing businesses.
`
`63.
`
`Beyond the ICD’s exclusive agents, Defendants have conspired with others, such
`
`as Kyle McAndrews, a confidant of Adam Beeman’s, and Jamie Ryscik, the brother of Beeman’s
`
`best friend, Richard Ryscik. Each of the Ryscik brothers were installed by the Shaders and Adam
`
`Beeman as figureheads for businesses that directly compete with ICD.
`
`64.
`
`The Enterprise has also worked closely with others such as First Enroll, LLC,
`
`Enrollment 123, Inc., and Affordable Healthcare 123. First Enroll, LLC, provides a platform for
`
`billing and enrollment purposes. Enrollment 123, Inc. provides the frontend and backend systems
`
`that enable Defendants to operate. Affordable Healthcare 123 is an independent marketing website
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`that directs insurance agencies to individuals who may want to buy additional healthcare coverage.
`
`D. How the Enterprise Operates
`
`65.
`
`The Shaders sought to keep the Enterprise and its criminal activity hidden from
`
`ICD by preventing ICD’s own agents from revealing anything that would give away the Enterprise.
`
`66.
`
`To hide the existence of the Enterprise, the Shaders lied to ICD as well as to
`
`individuals working at their own call centers, falsely representing that they were getting out of the
`
`insurance business.
`
`67.
`
` Instead, the Shaders, working in concert with the other Defendants, have funded a
`
`series of companies to carry out the Enterprise, and have provided financial incentives to agents
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`12
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 13 of 40
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`to convince them to violate their contracts with Plaintiffs and to provide information regarding
`
`ICD’s trade secrets.
`
`68.
`
`At all times relevant hereto, Andrew Shader and Corey Shader created and funded
`
`Defendant Prodigy, a call center for health insurance sales, with Adam Beeman’s assistance, and
`
`through leads provided by Infinix.
`
`69.
`
`Prodigy, in turn, contracts with Ryan Kelty, an ICD agent, to serve as manager for
`
`Prodigy.
`
`70.
`
`In a complaint filed in February 2021 in Broward County, Florida, Prodigy
`
`admitted that it has an agreement with Beeman’s company, Defendant BFI, to provide certain
`
`unspecified “marketing, management, and consulting services.” BFI is a shell company owned
`
`and controlled by Adam Beeman.
`
`71.
`
`Defendants used Prodigy and Infinix to surreptitiously and illicitly compete with
`
`ICD and steal ICD’s proprietary trade secrets, business model, agents and customer base.
`
`72.
`
`Similarly, Defendant Kratos is an insurance agency, incorporated in 2019. On
`
`paper it is controlled by Adam Beeman, a felon who was convicted of trafficking in opioids, and
`
`Ryscik, who has no experience in the insurance industry and works for a fire-sprinkler business.
`
`73.
`
`By their own prior admissions, neither Beeman nor Ryscik have substantial capital
`
`of their own. In reality, the Shaders have provided the funding for Kratos, including by funneling
`
`funds through Beeman and/or BFI.
`
`74.
`
`Indeed, the February 2021 Broward Complaint describes how a company
`
`controlled by Corey Shader, Defendant CSI, “has entered into financial transactions with BFI.” In
`
`other words, the Broward Complaint admits that the Shaders have provided funding for their
`
`friend, Beeman, and others engaged in the Enterprise.
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`13
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 14 of 40
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`75.
`
`Because Beeman is closely connected to the Shaders, he and the Shaders decided
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`to install Beeman’s best friend, Ryscik, as a figurehead, or a front to hide their scheme from ICD.
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`Specifically, the Shaders and Beeman, working in concert with other Defendants, had Ryscik on
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`paper assume a majority ownership interest in Kratos, Health Team, and their affiliates.
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`76.
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`Ryscik, who previously had no meaningful background in the insurance business,
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`controls Kratos and its affiliates only on paper.
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`77.
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`In reality, Beeman controls Kratos and its affiliates, including making all key
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`financial decisions, but Defendants have falsely represented that Ryscik is the sole owner of Kratos
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`and its affiliates.
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`78.
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`The truth is that the Enterprise set up Kratos and its affiliates such that, on paper,
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`Beeman only has a less than ten percent interest in order to evade insurance regulations that
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`prohibit a convicted felon from having a stake larger than ten percent in an insurance business.
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`79.
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`For example, on January 24, 2020, Kratos represented in its 2020 Florida Limited
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`Liability Company Annual Report filing to the Florida Secretary of State that Ryscik was the
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`“President” of Kratos, when, in reality, he plays no role beyond that of a façade for Beeman.
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`80.
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`Similarly, also on January 24, 2020, Health Team represented in its 2020 Florida
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`Limited Liability Company Annual Report filing to the Florida Secretary of State that Ryscik was
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`a manager of Health Team, when, like Kratos, he plays no role beyond shielding Beeman from
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`regulatory scrutiny. Beeman has also facilitated this practice of hiding his true ownership interest
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`for other business entities established to compete with ICD.
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`81.
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`Belying this dubious corporate structure, Ryscik, a purported owner of Kratos and
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`its affiliates, has not made any capital contributions or other monetary contributions into any of
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`these entities that he claims to “own” or “control.”
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 15 of 40
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`82.
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`After intentionally appointing Ryscik, someone unknown to ICD, as a figurehead
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`owner, Beeman, along with Kratos and Health Team, has facilitated the appointment of numerous
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`agents who have Exclusive Agent Agreements with ICD and has provided the vehicle and
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`infrastructure through which these agents have violated their obligations to ICD.
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`83.
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`In addition to facilitating the appointment of numerous agents, Kratos, working
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`with NHS, and utilizing BFI and CSI, has facilitated the overall operation and financing of the
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`Enterprise. For example, to provide money to the former ICD agents who the Enterprise needed
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`to set up the competing companies, the Shaders paid them funds from NHS that they characterized
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`as severance payments. In truth, this money was to compensate the agents for their time while
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`they worked to establish companies such as Prodigy and Kratos.
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`84.
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`Defendants have worked in concert to keep the Enterprise and its criminal conduct
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`hidden from ICD for long as possible. Upon information and belief, Corey Shader went so far as
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`to issue threats to individuals at the Shaders’ call centers regarding potential communications with
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`ICD.
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`85.
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`The Shaders, in furtherance of the Enterprise, enforced these restrictions on
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`communications with ICD by threatening to withhold access to valuable leads, provided by
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`Defendant Infinix and working alongside Alliance and CS Marketing. Throughout the duration of
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`the Enterprise, the Shaders used access to these valuable leads, which are the lifeblood of the
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`insurance marketing business, to bribe and coerce individuals to violate their pre-existing
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`contractual duties to ICD.
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`86.
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`Specifically, Corey Shader threatened individuals under contract with ICD who
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`worked in the Shader-controlled call rooms that he, Andrew Shader, and their businesses,
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 16 of 40
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`including NHS, Alliance, and CS Marketing, would cut off access to leads from Infinix, among
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`others, to any ICD agent who revealed any aspect of the Enterprise to ICD.
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`E. The Enterprise’s Pattern of Racketeering Activity
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`87.
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`The ICD Misappropriation Enterprise, which consists of all Defendants, has as its
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`primary purpose the enrichment of Defendants through a continuing pattern of criminal activity
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`directed at ICD involving bribery, fraud, and theft. Each Defendant has participated in the affairs
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`of the Enterprise and its racketeering activity, including as described herein.
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`88.
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`The Enterprise consists of a close-knit group of persons and entities with extensive
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`ties to one another.
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`89.
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`The Enterprise has been in operation since at least 2018, and has worked throughout
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`the last three years in order to effectuate its criminal purpose, becoming increasingly aggressive in
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`its efforts to harm ICD and to enrich Defendants.
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`90.
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`Defendants Andrew and Corey Shader and Defendant Beeman have direct or
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`indirect ownership or control over many of the other Defendants who constitute the Enterprise.
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`The Shaders own and/or control Defendants NHS, Infinix, CSI, CS Marketing, and Alliance
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`Marketing.
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`91.
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`The Shaders’ close friend and former employee, Adam Beeman, owns or controls
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`Defendants BFI, as well as Kratos and Health Team, each of which was established with financing
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`from the Shaders, much of it funneled through BFI.
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`92.
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`Defendant Ryscik, Adam Beeman’s longtime best friend, is the front person and
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`registered officer for Kratos, Health Team, and their affiliates.
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`93.
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`Defendant Offutt is a close confidant of the Shaders, working at both Infinix and
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`CS Marketing, among other Shader-related companies. Offutt assists both Corey and Andrew
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`Case 0:21-cv-60859-RKA Document 1 Entered on FLSD Docket 04/21/2021 Page 17 of 40
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`Shader with the management of their assorted business interests and was actively involved in the
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`scheme to establish new, illicit competing businesses, such as Defendant Prodigy.
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`94.
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`The Shaders and Beeman created, funded, and supported Prodigy, which on paper
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`is owned by Beeman’s mother, Defendant Joy Stormont. Prodigy works closely with Defendant
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`Infinix. For example, to support Prodigy’s operations when it was first founded, Infinix provided
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`Prodigy computers.
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`95.
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`The close coordination between Defendants relating to the Enterprise is also
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`reflected in extensive communications among and between Defendants.
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`96.
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`For example, in one text message exchange dated March 12, 2019, Defendant
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`Beeman is coordinating with Christopher “Brett” Mason, a confidant, the logistics for setting up
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`the operations for Prodigy. Beeman wrote: “Have the courier call Allison,” and Beeman then
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`provided Allison’s phone number. Beeman’s message refers to Allison Neidler, who is Corey
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`Shader’s personal assis