Page 12 of 40 32. On multiple occasions, KJ lobbied SJ for several conference calls with SJ’s associates, attorneys, investors and inner circles. KJ spoke highly of his connection to the Latinum Board of Directors and his close affiliations with Latinum’s purported creator, Dr. Don Basile, who readily would join ZOOM or conference calls to discuss what KJ and Dr. Basile claimed to be the greatest investment of our lifetimes. 33. KJ sent to SJ numerous images and text messages with articles about Latinum. KJ even sent to SJ a vague snapshot of what KJ represented to be and purported to be a personal bank account with funds totaling over $50,000,000.00 as a reinforcement to accredit KJ’s extensive tenure and success within the crypto space. 34. On multiple occasions, KJ made promises to SJ that KJ guarantees personally the money that SJ and others would invest and invested in Latinum. 35. After publication of a text message from the founder of Benzinga, who referred to Latinum as a “Shitcoin”, KJ expressed to SJ that if Latinum were to “tank,” then the funds would be returnable in full to SJ, because KJ claimed that he (KJ) was holding the funds personally. 36. KJ further promised SJ that no withholding would occur, and that Tokens would be disbursed to Latinum’s and KJ’s investors immediately upon launch. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.12 Filed 02/01/22 Page 12 of 40
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