Background

Filing-stage RICO complaint. The document itself is 45 pages and records only the plaintiffs' allegations and prayer for relief at filing; subsequent procedural events (arbitration, settlement, damages amounts) are not in this document. The 'Dated: July 16, 2000' line in the signature block on PDF p. 45 contradicts the PDF's own metadata (Subject: 'July 16, 2002 Complaint'; CreationDate Tue Jul 16 2002 EDT) and the substantive allegations of 2001-vintage facts; it is recorded here as a typo, not a separate date. Case-caption case number is blank on the filing copy. Related companion document: 2002_statement_commissioner-on-expos-minority-partners (Commissioner's response). The relationship to subsequent franchise-finance events (the Marlins-Expos three-team transaction, the Expos→Nationals relocation, the Lerner family's later purchase of the Nationals from MLB) is external to this document and is the proper subject of metadata for those separate documents where they exist.

Key provisions

• Parties (per case caption, PDF p. 1): Plaintiffs — fourteen Canadian corporate entities (BMO Nesbitt Burns Inc.; BCE Inc.; Cascades Inc.; Esarbee Investments Limited; Fairmont Hotel & Resorts Inc.; Fédération des Caisses Desjardins du Québec; Fonds de Solidarité des Travailleurs du Québec (F.T.Q.); Freemark Holdings Inc.; Loblaws Inc.; M&S Sports Inc.; Provigo Inc.; Telemedia Communications Inc.; 98362 Canada Inc.; 114114 Canada Inc.). Defendants — Jeffrey H. Loria; David Samson; Allan 'Bud' Selig; Office of the Commissioner of Baseball; Robert DuPuy; Baseball Expos GP, Inc.; Baseball Expos L.P.
• Court: U.S. District Court for the Southern District of Florida. Case number: blank on the filing copy (the Civ-No. line on the case caption reads Case No.: ____________________-CIV-________); a docketed number was presumably assigned by the clerk after filing.
• Filing date: July 16, 2002 (per PDF metadata and the substantive allegations of 2001-vintage facts; the signature-line Dated: July 16, 2000 on PDF p. 45 appears to be a clerical typo against the document's own evidence).
• Causes of action (per the complaint's prayer for relief): violations of 18 U.S.C. § 1962 (RICO) with treble damages and statutory fees; fraud by the Loria defendants and the MLB Commissioner defendants; breach of fiduciary duty and negligent misrepresentation by the MLB Commissioner defendants; injunctive relief preventing any sale, relocation, transfer, or contraction of the Montreal Expos MLB franchise; a constructive trust over Expos franchise property pending determination of restoration of plaintiffs' pre-Dec-9-1999 ownership interests; and punitive damages of no less than $100,000,000 USD.
• Stated injury frame (per the complaint's own characterization): the plaintiffs allege that the defendants engaged in 'a conspiracy to eliminate major league baseball in Montreal' that began with Loria's December 1999 acquisition of a 24% / managing-general-partner interest, proceeded through a course of alleged misrepresentations from May–December 2000 and February–March 2001 (regarding MLB's alleged purchase intentions for the plaintiffs' interests), and during 2001 (regarding the alleged plan to contract the Expos in exchange for Loria's acquisition of another MLB franchise).
• [Subsequent procedural history outside this document]: this complaint records only the filing-time allegations and prayer for relief. The arbitration outcome, any settlement, and any damages amounts are not in this PDF and are not recorded here. Where externally verified, those would appear in separate metadata for the relevant subsequent documents.

Notable provisions

This action is filed by the victims of a conspiracy to eliminate major league baseball in Montreal. Plaintiffs are leading corporate citizens of Canada who -- before the events that gave rise to this action -- owned close to 100% of the interests in the Montreal Expos Major League Baseball ("MLB") franchise, which has operated in Montreal for more than thirty years. The defendants – Jeffrey Loria, David Samson, Allan "Bud" Selig, the Office of the Commissioner of Baseball, Robert DuPuy, Baseball Expos GP, Inc., and Baseball Expos L.P. – are the perpetrators of a fraudulent conspiracy and the members of a racketeering enterprise with the object of eliminating major league baseball in Montreal, and removing plaintiffs from standing in the way of that objective.— Complaint ¶ 1 (Introduction), PDF p. 1

WHEREFORE, plaintiffs demand judgment against defendants as follows: (a) compensatory damages in an amount to be determined at trial, for defendants' violations of RICO, plus treble damages, attorneys' fees and costs of this action, all provided by statute as a result of defendants' violations of 18 U.S.C. § 1962; ... (d) punitive damages in an amount no less than one hundred million U.S. dollars ($100,000,000); (e) a constructive trust in favor of plaintiffs with respect to all property of and ownership interest in the Montreal Expos MLB franchise, pending a determination whether the plaintiffs' ownership interests in the franchise should be restored to the position they had prior to December 9, 1999; (f) injunctive relief prohibiting any sale, relocation, other transfer, or contraction of the Montreal Expos MLB franchise or any ownership interests therein...— Complaint, Prayer for Relief, PDF pp. 44-45

Further context

BMO Nesbitt Burns, et al. v. Loria, et al. (S.D. Fla., filed July 16, 2002)

45-page RICO complaint filed by fourteen Canadian corporate minority owners of the Montreal Expos partnership against Jeffrey Loria, David Samson, Allan "Bud" Selig, the Office of the Commissioner of Baseball, Robert DuPuy, Baseball Expos GP, Inc., and Baseball Expos L.P.

Filing date

July 16, 2002, U.S. District Court for the Southern District of Florida. The case caption on PDF p. 1 leaves the Civ-No. line blank (a clerk's-office number was presumably assigned after filing). The PDF's metadata Subject reads "July 16, 2002 Complaint (baseball racketeering suit)" and the PDF CreationDate is Tue Jul 16 11:55:57 2002 EDT. The signature block on PDF p. 45 reads "Dated: July 16, 2000" — this is a clerical typo against the document's own internal evidence (the complaint repeatedly alleges defendant misrepresentations during 2001, which would be impossible to allege in a July 2000 filing).

Causes of action

RICO (18 U.S.C. § 1962) with treble damages; fraud against the Loria defendants and the MLB Commissioner defendants; breach of fiduciary duty and negligent misrepresentation against the MLB Commissioner defendants; injunctive relief; constructive trust over Expos franchise property; punitive damages of no less than $100M.

Scope of this document

This is the filing-stage complaint only. Subsequent procedural history (whether the case proceeded to arbitration, any settlement, damages amounts) is not in this document; where external events are verifiable, they are the proper subject of separate metadata.

Verification status

needs_review. Single source (SABR Box). Date and structural details (court, parties, causes of action, prayer for relief) verified against the PDF itself 2026-05-19; a second independent source for the document's substance would be needed for promotion to verified. The prior 2026-05-19_expos-rico-complaint-2000-vs-2002.md discrepancy note is resolved by this pass.

Related documents

Related documents

Commissioner Statement on Expos Partners (2002), DC-MLB MOU 2002, DC Baseball Stadium Agreement (2004)

Source provenance

• Primary source