3/24/2023
From the complaint:
1. On or about March 24, 2023, Plaintiff provided Defendants with a cashier's check in the amount of $99,972.92. It was Plaintiffs intent based upon Defendants representations that for the payment of $99,972.92 Plaintiff would receive in return from Defendants 2,707 one-ounce generic silver rounds at $27.56 each for a total of $74,604.92. Plaintiff further anticipated receiving, based upon Defendants' representations, 12 one-ounce gold Krugerrands valued at $2,114.00 each for a total of $25,368.
2. Defendants then advised Plaintiff that these specific items and precious metals were not in stock which would require the Defendants to seek out and purchase those items identified above from a wholesale supplier.
3. Evidence of this purchase was notated in Defendants internal sales order agreement
12 #21487.
4. On or about April 6, 2023, Defendants did deliver to Plaintiff 12 gold Krugerrands upon receipt from their wholesale supplier.
5. On April 6, 2023, Plaintiff, based upon the representations of Defendants, placed an additional order of four (4) 1,689 generic silver rounds valued at $29.60 each and paid the total $49,994.40 with a cashier's check identified in sales order agreement #2169.
6. As of today, the 12 gold Krugerrands are the only products ever delivered to Plaintiff by Defendants.
7. As of today's date, Defendants have failed to deliver to Plaintiff 4,396 one-ounce generic silver rounds at a total cost of $124,599.32
