VIRGINIA: IN THE CIRCUIT COURT OF WARREN COUNTY INDUSTRIAL DEVELOPMENT AUTHORITY ) OF THE TOWN OF FRONT ROYAL AND THE COUNTY OF WARREN, VIRGINIA a/kia ECONOMIC DEVELOPMENT AUTHORITY OF THE TOWN OF FRONT. ROYAL AND THE COUNTY OF WARREN, VIRGINIA, Plaintiff, v. Case No. JENNIFER R. MCDONALD, Serve: Jennifer R. McDonald 158 Faith Way Front Royal, VA 22630 DONALD F. POE, Serve: Donald F. Poe 139 Passage Manor Drive Strasburg, VA 22657 JUSTIN APPLETON, Serve: Justin Appleton 1604 W. Commonwealth Drive Front Royal, VA 22630 EARTH RIGHT ENERGY SOLAR ‘COMMERCIAL LLC, Serve: Mandy Newman, Registered Agent 136 Passage Manor Drive Strasburg, VA 22657 TRUC ("CURT") V. TRAN, Serve: Truc ("Curt") V, Tran 9397 Farmingdale Court Great Falls, VA 22066 DANIEL T. MCEATHRON, Serve: Daniel T. McEathron 430 Skyline Forest Drive ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) d } Front Royal, VA 22630 )DABOYZ, LLC, Serve: Jennifer R. McDonald, Registered Agent 158 Faith Way Front Royal, VA 22630 MOVEONS, LLC, Serve: Joseph F. Silek, Jr., Registered Agent 43 Chester Street Front Royal, VA 22630 ITFEDERAL, LLC, Serve: Terry L. Fox, Registered Agent 9460 Wooded Glen Avenue Burke, VA 22015 Defendants, COMPLAINT Introduction 1 From at least 2016 until 2018, Jennifer R. McDonald, in her capacity as Executive Director of the Industrial Development Authority of the Town of Front Royal and the County of Warren, Virginia ("Warren EDA"), engaged in a variety of schemes to unlawfully take money from the Warren EDA for her personal benefit. This is an action against Defendant McDonald and other confederates and co-conspirators to redress these unlawful takings and recover assets that are lawfully the property of the Warren EDA. Jurisdiction 2, This Court has jurisdiction over this matter pursuant to Va. Code § 17.1-513. Venue Venue is appropriate in the Circuit Court for the County of Warren pursuant to Va, Code §§ 8.01-257 and 8.01-262.Parties 4. Warren EDA is the Industrial Development Authority of the Town of Front Royal and the County of Warren, Virginia, with its principal place of business in Front Royal, Virginia. 5. Jennifer R. McDonald is the former Executive Director of the Warren EDA and a resident of Warren County, Virginia. 6. Donald F. Poe is a principal of Earth Right Energy Solar-Commercial, LLC and a resident of Warren County, Virginia. 7. Justin Appleton is a principal of Earth Right Energy Solat-Commercial, LLC and a resident of Warren County, Virginia. 8. Earth Right Energy Solar-Commercial LLC (and related companies) is a Virginia limited liability company conducting business in Warren, Virginia, 9. Truc ("Curt") V. Tran is a resident of Great Falls, Virginia who conducts business in Warren County, Virginia. 10. Daniel T. McEathron is the Sheriff of the County of Warren, a former principal in DaBoyz, LLC, an associate in the financial affairs of Jennifer McDonald, and a resident of the County of Warren. 11. DaBoyz, LLC is a Virginia LLC owned and operated by Jennifer McDonald, doing business in the County of Warren. 12, Moveon8, LLC is a Virginia LLC owned and operated by Jennifer McDonald, doing business in the County of Warren. 13, ITFederal, LLC is a Virginia LLC, on information and belief, owned and operated by Truc ("Curt") V. Tran, and doing business in the County of Warren,