Page 16 of 40 51. In a series of text messages that KJ sent to RJ in November 2021 that purported to be from the Latinum website, RJ noted multiple grammatical and spelling errors on the Latinum website, which were suspicious, particularly in light of KJ’s previous admission that Latinum was a “scam.” In a series of subsequent emails, RJ made repeated attempts to obtain from KJ a status update on his investment in Tokens, as well as the investments of SJ and FJ. 52. Defendant KJ repeatedly was evasive in with respect to RJ’s messages, as KJ dodged RJ’s text messages and phone calls until November 29, 2021. On November 29, 2021, KJ claimed that he instructed that the Tokens will be released in February 2022. 53. On November 29, 2021, RJ asked KJ for confirmation of RJ’s $200,000 investment, which amounted to a total of 11,143 Tokens. Neither KJ nor Latinum provided to RJ confirmation of RJ’s $200,000 investment or the 11,143 Tokens. 54. On or about January 8, 2022, RJ asked KJ to return all money that RJ, SJ and FJ invested with Latinum through KJ in Tokens, with instructions to wire the money back within three business days. 55. As of the date of this Complaint, neither RJ, SJ, nor FJ have received return of funds they invested in Latinum through KJ in Tokens. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.16 Filed 02/01/22 Page 16 of 40
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