Page 14 of 40 42. Defendant KJ failed to provide information to SJ regarding the possession or value of the Tokens that KJ represented to SJ reflected SJ’s ownership interest in Tokens. C. Defendants Induced Plaintiff Raymond Jonna to Invest in Tokens 43. In or about September of 2021, Defendant KJ induced RJ to invest in Latinum by, among other things, sending articles to RJ about how Latinum was going to revolutionize the crypto space. As a result of KJ’s representations and inducement, RJ made an initial investment of $100,000 in approximately 7,143 Tokens at $14 per Token. 44. Upon KJ’s instructions, RJ wire transferred $100,000 on or about September 22, 2021. On or about September 22, 2021, KJ confirmed that the wire transfer from RJ was received. 45. On or about October 14, 2021, RJ texted KJ to get an update on the Tokens after receiving no further information from KJ. Defendant KJ responded by saying “Bro it was all a scam man. I’m going to try to get your money back. Lol I’m kidding on phone w Simon.” 46. By virtue of KJ’s admission to RJ that RJ’s investment in Tokens was a “scam,” RJ became very concerned about bona fides of the investment that KJ had induced RJ to make. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.14 Filed 02/01/22 Page 14 of 40
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