Page 11 of 40 B. Defendants Induced Plaintiff Simon Jonna to Invest in Tokens 29. In or about September 2021, Defendant KJ induced SJ to invest in Latinum. KJ called SJ to praise Latinum as a massively lucrative opportunity that will be backed by large insurance conglomerate, Marsh McLennan. KJ also touted Latinum as a partner of and with prominent sponsors by enumerating many other nameplates and companies, such as Steve Wynn affiliated companies and Monsoon Blockchain, as two examples, either purportedly associated with or backing Latinum. KJ spoke of high-level conference calls with Brian Armstrong, CEO of Coinbase. 30. KJ was well aware of SJ’s novice status and lack of experience in the cryptocurrency space; meanwhile, and at all times relevant hereto, KJ held himself out as a cryptocurrency expert. 31. KJ claimed he would be investing upwards of $3.5 million dollars from his personal funds, and possibly much more. KJ told SJ that investors had very limited time to act to invest in Latinum, and that SJ’s reputation would benefit even more by making aware Latinum to all of his spheres of influence. KJ knew that SJ’s extensive credibility in the investment arena was time-tested with investors around the nation such that KJ could further extend the fraud that he was perpetrating into SJ’s personal network. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.11 Filed 02/01/22 Page 11 of 40
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