Following the Reorganization Transactions and the Offering Transactions described below, loanDepot, Inc. LD Holdings was formed as a Delaware limited liability company on October 16, 2015. was formed as a Delaware corporation on November 6, 2020. There exists, and at all times herein mentioned there existed, a unity of interest and ownership between Defendants LDLLC, LDI and LD HOLDINGS (collectively, the “Corporate Defendants” or “LoanDepot”), such that any individuality and separateness between the Corporate Defendants have ceased, and they are each an alter ego of the other, in that Defendant LDLLC and LD HOLDINGS are completely controlled, dominated, managed and operated Defendant LDI as the Defendants all share the same board members and corporate officers, as described in the LDI’s Amended Form S-1 dated Janufiled with the Securities and Exchange Commission as follows: “loanDepot, Inc. Plaintiff will hereafter seek leave to amend this Complaint to set forth the true names and identities of the unknown named DOE Defendants when they are ascertained. Plaintiff is informed and believes, and thereupon alleges, that each of the Defendants designated herein as a DOE, was and is legally, equitably, or in some other actionable manner, responsible for the events and happenings hereinafter referred to, and thereby negligently, carelessly, with deliberate indifference, or by reason of direct or imputed negligence or vicarious fault or breach of duty arising out of the matters herein alleged, legally and proximately caused the hereinafter alleged injuries andĭamages to the Plaintiff. Plaintiff is unaware of the true names and capacities of those defendants sued herein as Defendants DOES 1 through 10, and therefore, sue said Defendants by such fictitious names. Plaintiff is informed and believes and thereupon alleges that Defendant Peter MacDonald (“MacDonald”) is an individual and the Chief Legal Officer at Loan Depot who resides in the County of Orange, State of California and at all times was acting as an executive with authority to act on behalf of all other defendants identified in this Complaint. Plaintiff is informed and believes and thereupon alleges that Defendant Anthony Hsieh (“Hsieh”) is an individual and the Chief Executive Officer at Loan Depot who resides in the County of Orange, State of California and at all times was acting as an executive with authority to act on behalf of all other defendants identified in this Complaint. Plaintiff is informed and believes and thereupon alleges that Defendant LD Holdings Group, LLC, is a Delaware limited liability company whose principal place of business is in the County of Orange, State of California. Plaintiff is informed and believes and thereupon alleges that Defendant LoanDepot, Inc., is a Delaware corporation whose principal place of business is in the County of Orange, State of California. Plaintiff is informed and believes and thereupon alleges that Defendant, LLC, is a Delaware limited liability company whose principal place of business is in the County of Orange, State of California. Plaintiff Tamara “Tammy” Richards, and at all relevant times herein, was a resident of the County of Orange, State of California. (“LDI”), a Delaware corporation, ANTHONY HSIEH (“Hsieh”), an individual, PETER MCDONALD (“MacDonald”), an individual and DOES 1through 10, inclusive, as follows: PARTIES 1. Intentional Infliction of Emotional Distress 9. Wrongful Termination Based Upon Public Policy 7.
Retaliation for Complaining About Harassment and Discrimination 5. Retaliation for Reporting Illegal Activities (Whistleblowing) 2. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF ORANGEġ. Plaintiff TAMARA “TAMMY” RICHARDS (“Richards”) hereby alleges for her Complaint against defendants LOANDEPOT.COM, LLC (“LDLLC”), a Delaware limited liability company, LD HOLDINGS GROUP, LLC (LD HOLDINGS), a Delaware limited liability company,
LOANDEPOT, INC., LOANDEPOT.COM, LLC, LD HOLDINGS GROUP, LLC, ANTHONY HSIEH, PETER MACDONALD, and DOES 1 through 10 inclusive, (MSN 10071) (Not Yet Admitted) THE COCHRAN FIRM 4929 Wilshire Boulevard, Suite 1010 Los Angeles, California 90010-3856 Telephone: (323) 435-8205 Facsimile: (323) 282-5280Īttorneys for Plaintiff Tamara “Tammy” Richards
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