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Franklin County Ohio Clerk of Courts of the Common Pleas- 2018 Jul 09 8:04 AM-18CV005717

COUNT TWO: CONVERSION 105.

Plaintiff Attorney General incorporates the preceding paragraphs of this

Complaint as if fully rewritten herein. 106.

Chuck Kirk, Marsha Kirk, and Deborah Garrison converted the value of funds and

property owned by Summer Rays and RRC and expended it for their personal benefit. 107.

Chuck Kirk’s, Marsha Kirk’s, and Deborah Garrison’s conversion of the funds

and property of Summer Rays and RRC was intentional, and was contrary to the rights and interests of Summer Rays and RRC. 108.

Separately, Chuck Kirk converted the property of Summer Rays residents when

he assumed control of automobiles that were titled in the name of residents personally and then “resold” these vehicles. Chuck Kirk’s actions were intentional and contrary to the rights of these individuals COUNT THREE: CIVIL CONSPIRACY 109.

Plaintiff Attorney General incorporates the preceding paragraphs of this

Complaint as if fully rewritten herein. 110.

Chuck Kirk, Marsha Kirk, Deborah Garrison, and Tammy Gollihue conspired to

misappropriate the charitable assets of Summer Rays and RRC and use those assets for their own personal benefit. 111.

Chuck Kirk, Marsha Kirk, Deborah Garrison, and Tammy Gollihue have

conspired to use their personal bank accounts, the bank accounts of other family members, and the various bank accounts of Summer Rays and RRC to disguise and conceal the nature and extent of their unlawful activity.

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Complaint- Summer Rays  
Complaint- Summer Rays  
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