Loskot

STATEMENT OF FACTS1

Loskot and Grishin are both immigrants from Kazakhstan who currently reside in California. They met in 2019. In early 2020, Grishin told Loskot he was in the business of purchasing American mining equipment and reselling it in Kazakhstan and was seeking a $1 million investment in his company. Loskot responded that he did not have $1 million to invest. In August or September, Grishin stated he owned a newly formed company, Minecon LLC, and again spoke with

1 This section is derived from the allegations in plaintiff’s operative complaint as well as the evidence offered in support of defendants’ motions to stay or dismiss.

2 Loskot regarding investing. Grishin claimed he had an agreement with a Florida manufacturer, Costex Tractor Parts (CTP), to sell CTP’s mining equipment parts in Kazakhstan. The parties eventually agreed that Loskot could invest the smaller sum of $400,000 in exchange for a 45 percent ownership interest in Minecon LLC. Grishin would take a 55 percent interest in Minecon LLC and give Minecon LLC the rights to the CTP distribution agreement, using Grishin’s own expertise in the field to conduct the company’s business. If Loskot agreed to the…