Principe V Curry - 01 Complaint
Principe V Curry - 01 Complaint
Principe V Curry - 01 Complaint
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v. ) INTERFERENCE WITH
) CONTRACTUAL RELATIONS;
14 TIMOTHY GLEN CURRY A/K/A ) DEMAND FOR TRIAL BY JURY
TIMOTHY TAYSHUN, )
15 )
Defendant. )
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17 Plaintiff, Chris Principe (Plaintiff), by and through his attorneys, Tucker Ellis,
18 LLP, files his complaint against Timothy Glen Curry aka Timothy Tayshun
19 (Defendant) for injunctive relief and damages as follows:
20 THE PARTIES
21 1. Plaintiff Chris Principe is an individual residing in Florida.
22 2. Plaintiff is informed and believes, and on that basis alleges, that Defendant
23 Timothy Glen Curry aka Timothy Tayshun is an individual residing in California.
24 JURISDICTION AND VENUE
25 3. Plaintiff is a citizen of the State of Florida and Defendant is a citizen of the
26 State of California. The matter in controversy exceeds the sum of $75,000 exclusive of
27 interest and costs. As such, this Court has original jurisdiction of this civil action
28 pursuant to 28 U.S.C. 1332.
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1 4. This Court has supplemental jurisdiction over the claims in this Complaint
2 that arise under state statutory and common law of the State of California pursuant to 28
3 U.S.C. 1367, because the state law claims are so related to the claims in which this
4 Court has original jurisdiction that they form part of the same case or controversy and
5 derive from a common nucleus of operative facts.
6 5. This Court has personal jurisdiction Defendant because Defendant resides
7 and is domiciled within the Central District of California.
8 6. Venue is proper in this Court pursuant to 28 U.S.C. 1391(b).
9 PLAINTIFFS BUSINESS AND REPUTATION
10 7. Plaintiff is a consultant in transaction banking, finance and technology.
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11 Plaintiffs career as a consultant also focuses on global trade using cryptocurrency and
12 blockchain.
13 8. Cryptocurrency, like BitCoin, is a digital currency in which encryption
TUCKER ELLIS LLP
14 techniques are used to regulate the generation of units of currency and verify the transfer
15 of funds, operating independently of a central bank.
16 9. Blockchain is a digital ledger in which transactions made in cryptocurrency
17 are recorded chronologically and publicly.
18 10. In furtherance of his consulting business, Plaintiff has given numerous
19 speeches and presentations, as well as trainings and workshops, throughout the world.
20 11. Plaintiff has written over thirty published articles in the transaction banking,
21 finance and technology arena.
22 12. Plaintiff is the official Trade Finance Trainer for the certificate program of
23 Florida International University and Florida International Banking Association (FIBA)
24 since 2012.
25 13. Plaintiff was Chairman of the Bankers Association for Finance and Trade
26 (BAFTA) and the International Financial Services Association (IFSA) National Trade
27 Services Product Management Committee from January 2009 to December 2013.
28 Plaintiff was the first non-banker voted as the Chairman of this committee.
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1 14. Plaintiff was also the Founding Chairman of the IFSA Financial Supply
2 Chain Committee in February 2008.
3 15. Furthermore, Plaintiff is an owner and publisher of Financial IT, an online
4 and print resource for Financial Technology market analysis.
5 16. Plaintiff has enjoyed a good reputation both generally and in his occupation.
6 17. Plaintiffs clients have highly recommended him to others and have referred
7 to him as, among other things, a real expert in trade finance and supply chain, one of
8 the most visionary Trade Finance and Financial Supply Chain executives in the space,
9 and a diligent and highly experienced worker.
10 DEFENDANTS BUSINESS
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14 operates BitCoin kiosks, which act like cryptocurrency ATMs, in furtherance of his
15 investment in the BitCoin cryptocurrency.
16 20. Plaintiff is informed and believes, and on that basis alleges, that Defendant
17 supports BitCoin by, among other things, attacking competitors of BitCoin, like
18 OneCoin, over the Internet and on social media.
19 21. Plaintiff is informed and believes, and on that basis alleges, that Defendant
20 uses the Twitter handle @ezCoinAccess.
21 22. Plaintiff is informed and believes, and on that basis alleges, that Defendant
22 frequently comments on the BehindMLM blog posts found at behindmlm.com.
23 23. BehindMLM is a blog or review site on the Internet dedicated to being a
24 resource to people curious about the multi-level marketing (i.e. MLM) industry and the
25 companies that exist within it.
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14 http://behindmlm.com/companies/onecoin/onecoin-payment-delays-triggered-by-hong-
15 kong-account-closure/ there appeared a blog entry entitled OneCoin payment delays
16 triggered by Hong Kong account closure. On November 2, 2016 at 5:20 a.m.,
rd
17 Defendant wrote the 53 comment to that blog entry that includes the following
18 statement: Despite Chris Principe being on OneCoin payroll . . . (Emphasis added).
19 42. On November 15, 2016, on the BehindMLM website at
20 http://behindmlm.com/companies/onecoin/onecoin-lose-last-bank-account-unable-to-
21 accept-wires/ there appeared a blog entry entitled OneCoin lose last bank account,
nd
22 unable to accept wires. On November 15, 2016 at 9:31 a.m., Defendant wrote the 2
23 comment to that blog entry that includes the following statement: Obviously, Chris
24 Principe is a similar reptile. I hope someone will come out with evidence and proof as
25 to the level of his financial wind fall for helping commit crime, as well. Im fairly
26 sure that Financial IT and any of Principes future endeavors will be well received once
27 this begins more rapidly unfolding, unless it is a biography about his criminal
28 involvement written behind cell walls. (Emphasis added).
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1 49. Due to Skyways relationship with Plaintiff, Skyway was also identified as
2 a Ponzi scheme by BehindMLM and Defendant. Skyway did not want to be associated
3 with Plaintiff because of the adverse effect it would have on Skyways business,
4 reputation and ability to find investors.
5 50. In 2017, Skyway canceled its agreement with Plaintiff because Skyway
6 found statements by Defendant on the Internet linking Plaintiff directly as a promoter of a
7 Ponzi scheme and Plaintiff did not want to be associated with Plaintiff.
8 51. As a result of Defendants defamatory statements, Plaintiff has been forced
9 to protect his reputation and prevent Defendant from making intentionally false
10 statements which have adversely affected Plaintiffs business.
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1 57. Defendants statements are false and unprivileged because Plaintiff has not
2 helped OneCoin Ltd. commit a crime, or done anything illegal involving OneCoin or
3 engaged in any criminal activity relating to OneCoin.
4 58. Defendant knew that these statements were false.
5 59. Defendants statements expose Plaintiff to hatred, contempt, ridicule or
6 obloquy because they challenge his business ethics, accuse him of a crime, and falsely
7 claim he is associated or affiliated with a criminal enterprise.
8 60. Defendants statements cause Plaintiff to be shunned or avoided, and which
9 have a tendency to injure him in his occupation, because they challenge his business
10 ethics, accuse him of a crime, and falsely claim he is associated or affiliated with a
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11 criminal enterprise.
12 61. Defendants statements are defamatory per se because they charge Plaintiff
13 with committing a crime.
TUCKER ELLIS LLP
14 62. Defendants statements are defamatory per se because they tend directly to
15 injure Plaintiff in respect to his profession, trade or business by imputing to him general
16 disqualification in those respects which his occupation peculiarly requires.
17 63. Defendants statements are defamatory per se because they tend directly to
18 injure Plaintiff by imputing something with reference to his profession or business that
19 has a natural tendency to lessen its profits.
20 64. As a proximate result of these statements, Plaintiff has been damaged
21 because Plaintiff has suffered the loss of his reputation, loss of business and loss of
22 income in excess of $75,000. Defendants statements had the effect of discouraging
23 businesses from dealing with Plaintiff, by lowering the reputation of Plaintiff, and
24 deterring other businesses from dealing with him.
25 65. As a proximate result of these statements, Plaintiff has been damaged
26 because Plaintiff has been forced to pay an outside consultant to help repair the damage
27 to Plaintiffs reputation.
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1 66. Defendant made these statements intentionally, with malice and without any
2 evidence to support them. As such, Plaintiff is entitled to exemplary damages.
3 67. Defendants statements have irreparably harmed and, if not enjoined, will
4 continue to irreparably harm Plaintiff and his business reputation.
5 68. By reason of Defendants acts, Plaintiffs remedy at law is not adequate to
6 compensate for the injuries inflicted by Defendant. Accordingly, Plaintiff is entitled to
7 entry of a temporary restraining order against Defendant and preliminary and permanent
8 injunctive relief.
9 Second Cause of Action
10 (Tortious Interference With Contractual Relations)
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14 statements would reach current or prospective clients of Plaintiff because Defendant used
15 Plaintiffs Twitter handle @cmpleo and Financial ITs Twitter handle @financialit_net
16 on most of Defendants false and defamatory Tweets.
17 71. Defendant knew or should have known of the relationship between Plaintiff
18 and Skyway when he made the false and defamatory statements because Defendant
19 commented on the blog entry at the BehindMLM website entitled OneCoins Chris
20 Principe also promoting Skyway Capital Ponzi scheme.
21 72. Defendants statements have induced or will induce Plaintiffs clients, like
22 Skyway, to breach their agreements with Plaintiff.
23 73. Defendants statements have induced or will induce Plaintiffs prospective
24 clients not to enter into any agreements with Plaintiff.
25 74. As a proximate result of these statements, Plaintiff has been damaged
26 because Plaintiff lost clients, business, potential clients and income in excess of $75,000.
27 Defendants statements had the effect of discouraging businesses from dealing with
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1 Plaintiff, by lowering the reputation of Plaintiff, and deterring other businesses from
2 dealing with him.
3 75. Defendant made these statements intentionally, with malice and with the
4 intent to interfere with and disrupt the contractual relationships between Plaintiff and his
5 clients. As such, Plaintiff is entitled to exemplary damages.
6 76. Defendants statements have irreparably harmed and, if not enjoined, will
7 continue to irreparably harm Plaintiff and his contractual relationships with his clients
8 and prospective clients.
9 77. By reason of Defendants acts, Plaintiffs remedy at law is not adequate to
10 compensate for the injuries inflicted by Defendant. Accordingly, Plaintiff is entitled to
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11 entry of a temporary restraining order against Defendant and preliminary and permanent
12 injunctive relief.
13 Prayer for Relief
TUCKER ELLIS LLP
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15 By: /s/Howard A. Kroll
16 Howard A. Kroll
Attorneys for Plaintiff
17 CHRIS PRINCIPE
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Lovelace, Susan C.
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The following transaction was entered by Kroll, Howard on 4/4/2017 at 4:31 PM PDT and filed on 4/4/2017
Case Name: Principe v. Curry
Case Number: 8:17-cv-00608
Filer: Chris Principe
Document Number: 1
Docket Text:
COMPLAINT Receipt No: 0973-19631596 - Fee: $400, filed by Plaintiff Chris Principe. (Attorney
Howard A Kroll added to party Chris Principe(pty:pla))(Kroll, Howard)
8:17-cv-00608 Notice has been delivered by First Class U. S. Mail or by other means BY THE FILER to :
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