Page 13 of 40 37. As a result of KJ’s representations and inducement, SJ made an initial investment of $140,000 in Tokens. On September 30, 2021, upon and following expressly Defendant KJ’s instructions, SJ wire transferred $140,000 to a Westbury Bank account in the name of “Jason Otto” (…1825). 38. In a text message in or about September 2021, SJ sent a screenshot of his Bitcoin Latimum wallet1 in a text message to KJ. KJ responded by saying “I didn’t tell you to download it…you are violating our contract…that can result in termination of your coins”. 39. In a series of subsequent text messages in or about September 2021, Defendant KJ advised SJ: “You should put big money in cuz” and “Trust me I know a lot” and “Put big money in it it’s better than any investment.” 40. Based upon representations made by KJ and information contained on Latinum’s website, SJ invested a total of $140,000 in 10,000 Tokens at $14 per Token, and an additional $100,000 for 4,000 Tokens at $25 per Token for a total investment of $240,000 for 14,000 Tokens. 41. SJ subsequently made a series of repeated attempts to get more information from KJ regarding his investment in the Tokens. 1 Digital assets, such as cryptocurrencies, are stored in “digital wallets” on the Blockchain owned and controlled by the holder of the digital assets. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.13 Filed 02/01/22 Page 13 of 40
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