David Stapleton v. JP Morgan Chase Bank, NA

I. BACKGROUND

1 A. Factual Background 2 Since August 2016, Acharya raised over “$119 million from over 250 investors” for 3 his real estate development company, Silicon Sage, and its subsidiaries and affiliates. 4 Compl. ¶¶ 10–14. As founder, president, CEO, and manager of Silicon Sage, Acharya had 5 complete dominion and control over the Receivership Entities and their finances. Id. 6 ¶¶ 12, 61, 150. Stapleton alleges that Acharya used the Receivership Entities to 7 orchestrate a massive fraudulent scheme that left the Receivership Entities insolvent. Id. 8 ¶¶ 39–41, 51. Acharya operated the enterprise using Chase bank accounts held by the 9 Receivership Entities. Id. ¶¶ 60, 61. Stapleton alleges that to elicit investments for the 10 scheme, Acharya told investors that his real estate projects were profitable, but in reality, 11 “the Receivership Entities had exited all but one of their real estate projects without 12 realizing any profits.” Id. ¶¶ 34–36. Acharya used equity interests, membership interests, 13 and promissory notes to solicit investments for Silicon Sage until the SEC obtained an 14 injunction against Acharya and Silicon Sage on February 10, 2021. …