Chapter 11 · Federal court, Illinois

Echols & Mosley v. Burke: the Sabina Park money

Two Illinois plaintiffs alleged payments for the 2025 BZR Carnival Edition; the public docket records a jurisdiction challenge and a later judgment whose terms were not available for review.

The Ryan Burke Public Record · Updated November 11, 2026 · How this record was compiled

Hugh Echols and John Mosley filed a verified civil complaint in the Northern District of Illinois on June 13, 2025, over money they said they paid toward BZR WKND Jamaica Carnival Edition 2025. They named Ryan Burke, VEW Live LLC, Vision Entertainment Worldwide LLC and Universal Creative Agency Inc. The five-page complaint alleges four payments totaling $298,145.95 and asks for substantially more in damages and equitable relief. Those are the plaintiffs’ allegations and requests, not an award.¹

The complaint concerns the edition advertised for April 26, 2025, at Sabina Park in Kingston, with Sexyy Red, Shenseea and Dexta Daps. A later Billboard account says that edition was canceled because of inclement weather. The complaint, however, describes disputed contracts, payment handling and a repayment promise before the advertised concert date. It should not be reduced to a claim that bad weather alone caused the financial dispute. The event’s publicity and cancellation history are set out in BZR WKND, edition by edition.²

What the plaintiffs filed

Echols and Mosley filed without counsel. In paragraphs 1 and 2, they describe themselves as domiciled in Illinois. Paragraph 3 describes the individual defendant as a Florida resident; paragraphs 4–6 identify the three corporate defendants and their business offices. The complaint’s jurisdiction section asserts federal jurisdiction and says a substantial part of the events and injuries occurred in the Northern District of Illinois. These statements explain where the plaintiffs chose to sue. They do not establish that the Illinois court had jurisdiction over every named defendant.³

The filing carries a jury demand. On page 4, the plaintiffs affirm that the allegations are true and correct to the best of their knowledge. That verification makes their account a verified pleading, but it does not mean a judge accepted it as true. The complaint contains no judicial findings about the transaction, and the free docket material reviewed does not supply a later merits decision adopting its allegations.¹

Paragraph 9 says the plaintiffs transferred funds in reliance on written and oral representations by Burke and the named entities. Paragraph 10 identifies the company letterheads. Paragraph 11 then draws a distinction between those documents and the payment instructions: it alleges that accompanying invoices for performer payments and disbursements were directed to Burke personally and to VEW Live, with “no payment structure or escrow for independent verification.” The plaintiffs thus challenge both what they were told about the project and how they were instructed to pay for it.⁴

The names on the alleged letterheads matter because the plaintiffs sued three separate entities, not just an event brand. The five-page main complaint does not itself reproduce the contracts or invoices it describes. The docket lists an attachment titled “Notice of Filing of Complaint and Supporting Exhibits,” but that attachment was not available as a free RECAP download on the page reviewed. The description confirms that an attachment was docketed; it does not independently authenticate each alleged agreement or show which entity signed which obligation.⁵

Universal Creative Agency was not first linked publicly to BZR by this complaint. In a July 16, 2023 interview, The Gleaner named UCA among the partners bringing BZR to Jamaica, alongside VEW Live, Solid Agency and Burke Bodley. That contemporary report supports the limited proposition that UCA was publicly identified with the earlier event. It does not establish UCA’s liability for the 2025 payments or prove that all partners had the same role across editions.⁶

Four alleged payments

Paragraph 12 supplies the dates, sums and identified recipients of four payments. Presented chronologically, rather than in the complaint’s original order, the list is as follows. No account identifiers are reproduced.⁷

The total is an arithmetic check of the amounts in the pleading. It is not a bank reconciliation. The plaintiffs say they paid directly from personal funds, but the freely available main complaint does not provide bank statements establishing settlement, receipt or later disposition of each transfer. Nor does paragraph 12 allocate a particular artist fee, venue bill or production invoice to each sum. It identifies the alleged recipients and dates without providing that fuller accounting.⁷

The March 15 payment is attributed to UCA; the March 24 payment to Burke; and the two other payments to VEW Live. Vision Entertainment Worldwide is named as a defendant and in the letterhead allegation, but paragraph 12 does not list a separate payment to Vision. That difference should not disappear in a summary that describes the whole sum as paid to one person or one company. Whether a recipient acted for another defendant is not established by the list alone.^{4 7}

The amount sought in damages is also not the sum of these four payments. The complaint claims additional losses, expenses and recoverable disbursements elsewhere, without a detailed itemization in the five-page main document. The $298,145.95 figure is therefore the checked total of the four expressly listed transactions, not an independently established measure of all losses or the amount of a judgment.⁸

The venue claim, cease-and-desist and repayment promise

Paragraph 13 alleges that the defendants claimed to have wired money to Sabina Park Cricket Stadium but provided no receipt or confirmation that the venue received it. This is an allegation about an asserted transfer and the documentation supplied to the plaintiffs. It does not establish that Sabina Park denied receiving funds, and no venue account statement or direct venue response was available in the free material reviewed.⁹

Paragraph 14 alleges that, despite promising to execute the project, the defendants sent a cease-and-desist email “falsely asserting fraud” and claiming control of the project while retaining the plaintiffs’ money. The quoted characterization is the plaintiffs’ account of the communication. The email itself is not reproduced in the freely available main complaint, so its complete wording, asserted grounds and any response cannot be checked there.⁹

Paragraph 15 says Burke verbally stated that he would pay back all the money on April 8, 2025, while in Jamaica. The sentence gives a repayment date and location but no written undertaking or recording. It does not say in the main pleading when the conversation occurred. The chapter therefore records the alleged promise without assigning a date to the conversation or treating the promise as an admission proved by an independent document.⁹

Paragraph 16 concludes that the plaintiffs later discovered misrepresented or incomplete artist agreements, invoices, venue statements and financial communications, and that the defendants failed to meet contractual or fiduciary obligations. It does not identify an artist’s own statement disputing a booking or attach a venue cancellation notice within the main complaint. The allegations are broader than a simple unpaid invoice, but their factual basis would require the agreements, communications and payment records referred to in the filing.⁹

The counts and requested relief

The complaint pleads four civil counts: unjust enrichment; fraud and misrepresentation; conversion; and civil RICO, invoking section 1962(c), the federal provision in 18 U.S.C. § 1962(c). Under unjust enrichment, the plaintiffs allege retention of their funds without the promised services. Under fraud and misrepresentation, they allege misstatements about artist participation, payment handling, venue arrangements and authority to bind parties. The conversion count alleges diversion and retention of personal funds without lawful justification.⁸

The civil RICO count alleges an association-in-fact enterprise and a pattern of racketeering involving wire and bank fraud and misuse of interstate commerce. That language belongs to the civil pleading. The docket’s “Racketeer/Corrupt Organization” classification similarly identifies a category assigned to the action; it is not a criminal charge, a prosecutor’s finding or proof of racketeering. The free records reviewed establish that the count was pleaded, not that its legal or factual requirements were met.^{8 10}

The plaintiffs ask jointly for $1,767,284.68 in compensatory damages and $3,534,569.37 in punitive damages, a total of $5,301,854.05. The addition is correct. The complaint describes the punitive component as “triple damages authorized under RICO, fraud, and equitable relief doctrines.” This chapter reports the plaintiffs’ formulation without endorsing the asserted entitlement or supplying a calculation that the pleading does not explain.⁸

They also request a constructive trust over traceable funds and property, an equitable lien, and an injunction against transfers or dissipation of assets. Page 4 asks for a declaratory judgment concerning fraud, conversion and racketeering, along with interest, fees and costs. These requests are part of the prayer for relief. Nothing in the freely accessible material establishes that the court granted a lien, imposed a trust, restrained assets or awarded the requested damages.⁸

Status reports and attempted service

Judge Jeffrey I. Cummings was assigned on June 16, 2025. A July 1 minute entry, docket entry 7, instructed the parties to file an initial joint status report by July 30. It set a tracking date and said no appearance was required. That order called for case-management information; it did not adjudicate the complaint.¹¹

On August 25, entry 8 said no report had been filed. The court extended the deadline to September 5 and instructed the plaintiffs to report on service if the defendants had not been served. It warned that failure to comply could result in dismissal for want of prosecution. The warning was conditional. The entry does not say the case was dismissed that day.¹¹

The September 18 entry, number 9, again noted missing reports, but also recorded a notice problem: the plaintiffs’ email addresses were not on file and they apparently had not consented to electronic notice. The court ordered a status report on service by October 3, repeated the dismissal warning and directed the clerk to mail the order to the plaintiffs. Omitting this notice issue would give an incomplete account of the court’s response to the missed deadlines.¹¹

On October 3, Echols and Mosley filed a status report on service, entry 10. The reproduction confirms the filing and date but does not display the report itself. It therefore cannot be used to say which defendants were successfully served, how service was attempted or whether the court accepted the plaintiffs’ position on service.¹¹

The appearance and jurisdiction defense

On October 23, 2025, lawyer Saurish Appleby-Bhattacharjee entered an appearance described as being on behalf of “Putative Defendant Ryan Matthew Burke, erroneously sued as ‘Ryan Burke’.” On the same date, he filed a status report on attempted service of that putative defendant. Both descriptions appear in Justia’s docket reproduction.¹²

The wording must be kept intact. It establishes the full name used by the lawyer and the contention that his client was erroneously sued. It does not, without the underlying filing, establish that a different individual was served or explain precisely what counsel meant by the error. This publication does not infer identity from the name alone or treat the defense description as a court finding.¹²

On November 13, counsel filed entry 13, a motion to dismiss for lack of jurisdiction. Justia lists a supporting memorandum, a declaration of Ryan Matthew Burke, a declaration of counsel and exhibits among the attachments. The declarations’ existence is verified by the docket; their substantive testimony was not available as free text or PDFs in the sources reviewed. No particular statement about Illinois contacts, contracts, residence or responsibility for payments can safely be attributed to the declarant on that basis.¹²

No independently verified public statement by the promoter addressing the Echols and Mosley allegations was found. Statements Burke made about other BZR editions do not answer this complaint. The documented response here is the appearance and jurisdiction motion, subject to the limits of the available docket descriptions.¹²

The judgment and later orders

CourtListener’s docket, last updated September 16, 2026, extends beyond Justia’s November 2025 extract. It lists entry 15 on December 18, 2025, as an “Order on Motion to Dismiss/Lack of Jurisdiction.” On January 20, 2026, it lists entry 18, “Order,” and entry 19, “Judgment - AO450.” The presence of a judgment is verified. Its beneficiary, grounds and effect on particular defendants are not.¹³

The February 17 motion’s purpose and the September orders’ results are not disclosed by their generic docket labels. The free page supplies PACER purchase links for these documents, not their text. On the reviewed page, the complaint is the only document with a free RECAP PDF download. The supporting exhibits, defense declarations, December order, January judgment and later orders were not available there as free copies.^{5 13}

What remains unresolved

The missing orders and judgment are the principal procedural gap: whether dismissal occurred, its grounds, its scope and the effect of the later motions remain unverified. The underlying contracts, invoices, exhibits, bank reconciliation, venue receipt and cease-and-desist email were also unavailable for independent verification. The April 8 repayment promise remains an allegation. The complaint is linked at its original archival source but is not re-hosted here because it contains private residential and financial data; this chapter omits those details.^{1 5 13}