1. At all times relevant to this Complaint, Defendant Cesar Humberto Pina, a/k/a "Flipping NJ" ("Pina"), resided in New Jersey and held himself out to be a
real estate investor, developer, and "flipper." 2. Pina and his business partner, a well-known disc jockey and radio personality ("Individual-1"), operated a
company that conducted real estate seminars around the country. Together, they used Individual-l's celebrity to promote various real estate enterprises that
Pina controlled. During real estate seminars, private one-on-one sessions, advertisements, public appearances, and otherwise, Pina represented that he
was a highly successful real estate investor, owned thousands of properties in multiple states, and had business relationships with numerous celebrities.
Through these efforts, Pina developed a significant following that included hundreds of thousands of social media followers. 3. Pina owned and/or
controlled numerous business entities, which held real property apd/or were used to open bank accounts that Pina used in furtherance of the charged
offense. These included: a. Whairhouse LLC ("Whairhouse"), a New Jersey limited liability company with a principal place of business in Wayne, New
Jersey; and b. FromStart2Flip LLC, a/k/a "From Start 2 Flipping LLC" ("From Start 2 Flipping"), a New Jersey limited liability company with a principal place
of business in Totowa, New Jersey. 4. Starting at least in or around 2017, Pina began accepting investments from individual investors (the "Victims") for the
alleged purchase, remodel, and sale of specific real estate projects in New Jersey and other states. Pina generally entered into contracts with the Victims
that specified, among other things, the purpose of the investment, promised interest payments, and the timeframe for repayment. But rather than using the
Victims' investments as promised, Pina engaged in a Ponzi-like