Page 2 of 40 criminal securities fraud cases involving sales of interests in cryptocurrencies. KJ, an unregistered person, and Latinum, an unregistered entity, are subject to control person liability, and are liable to Plaintiffs for fraud, false advertising in violation of California law, unfair competition under California law, breach of contract, conversion, fraudulent misrepresentation, and unjust enrichment. KJ’s and Latinum’s premeditated and sinister fraud prominently came to light when they failed to fulfill multiple requests from Plaintiffs to deliver evidence of their ownership of Tokens, and, upon refusing to do so, failing to fulfill multiple requests to return to Plaintiffs that Latinum return $541,045 that Plaintiffs invested in Tokens. THE PARTIES 2. Plaintiff Raymond Jonna (“RJ”) is a resident of West Bloomfield, Oakland County, Michigan. 3. Plaintiff Simon Jonna (“SJ”) is a resident of Birmingham, Oakland County, Michigan. 4. Plaintiff Farid Jamardov (“FJ”) is a resident of Commerce Township, Oakland County, Michigan. 5. Defendant Kevin Jonna (“KJ”) is a resident of San Diego, San Diego County, California. Defendant KJ is a cousin of Plaintiffs RJ and SJ. Case 2:22-cv-10208-RHC-JJCG ECF No. 1, PageID.2 Filed 02/01/22 Page 2 of 40
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