My favorite game when reading SEC administrative actions is looking for the exact minute in the procedural history where a responsible, professional adult had the switch flip from Business as Usual to Oh My God You’re A Fraud. https://www.sec.gov/litigation/complaints/2018/comp-pr2018-160.pdf …
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It's between paragraph 60 and 61 and when they say "The Co-Investor demanded" you should read "The Co-Investor, for the first time, raised this matter to their attorney, who promptly created a new project in his billing software and then started drafting A Pointed Letter."
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