Page 15 of 40 47. In or about October 2021, in a series of text messages between KJ and RJ, KJ provided reassurance to RJ, made lulling representations to RJ, and further induced RJ to invest additional funds in Latinum. Such inducement included, among other things, sending RJ screenshots of what KJ displayed to purport to be LTNM trading at $201 per Token. As a result of KJ’s representations, RJ considered investing and then offered to invest an additional $250,000. On October 26, 2021, KJ sent an additional screenshot of LTNM purporting to reflect trading at $212.64 per Token on Crypto Stake, and another screenshot purporting to reflect LTNM trading at $699.99 per Token. 48. On or about October 27, 2021, after KJ pressed RJ to make an additional investment in Tokens, RJ asked KJ to send wire transfer information. On or about October 28, 2021, RJ sent an additional $100,000 via wire transfer to a Citibank account in New York in the name of GIBF GP, Inc for 4,000 Tokens at $25 per Token. KJ instructed RJ to include “for Kevin Jonna” in the memo line. 49. On or about October 29, 2021, KJ sent to RJ a screenshot of what purported to be a “Congratulations” notification from Latinum regarding RJ’s October 28, 2021 investment in Tokens. 50. On or about November 1, 2021, KJ told RJ that Tokens will be released around the time it launches in the U.S. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.15 Filed 02/01/22 Page 15 of 40
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