This case arises out of defendant Ms. Cane’s conduct as the Trustee of a voting trust imposed upon plaintiff MP to control his majority shares in MOD Systems, Inc. (hereinafter “MOD”), a company he founded and operated for over four years. Defendant was an adviser and confidant of plaintiff as he struggled to maintain control of his company against allegations of wrongdoing. Unbeknownst to plaintiff, defendant Ms. Cane is the long-time friend, lawyer and co-conspirator of plaintiff Mr. MP’ main antagonist, the long-time fraud Jan Wallace. The failure of Ms. Cane to disclose her obvious, entrenched conflicts of interest, conflicts of interest so obvious that she was removed as trustee by the Honorable John P. Erlick, Judge of the Superior Court of the State of Washington. But the failure of Ms. Cane to disclose her conflicts of interest was not mere negligence, but followed a pattern of fraud that she and her co-conspirator, defendant Jan Wallace, had employed to gain control of companies in jurisdictions across the Western United States. Once designated as the trustee, Ms. Cane breached her contractual obligations, abrogated her fiduciary duty, and failed to take into account plaintiff’s interests in exercising her duties as executor of the trust. Instead, Ms. Cane took steps in pursuit of her own interests as well as the interests of her co-conspirator, Ms. Wallace. As their long and nefarious business history has proven, Ms. Cane and Ms. Wallace intended to take control of MOD at a time when it received a $35 million investment, for their own personal gain. The direct result of Ms. Cane’s fraud and deceit, MOD was destroyed and plaintiff lost not only his business, but all of his personal assets as well. This Complaint seeks to recompense plaintiff for all of the damages suffered as a result of defendants’ actions.