Leonid Zavlunov v. Stanislav Shvartsman et al: Complaint (‘Fraudulent Bank Guarantee’)

Complaint seeking damages of $4.1 million alleging fraud and forgery in Leonid Zavlunov, derivatively and on behalf of Strategic Global Experts Inc. v. Stanislav Shvartsman, William Joseph Mudolo, of London, England, and African Development Funding Group, as Defendants, and Strategic Global Experts Inc., as Nominal Defendant, at the Supreme Court of the State of New York, New York County.