Ignat Tuganov v. Celsius Network LLC et al: Complaint (‘Ponzi Scheme Declaration for Crypto Fraud’)
Complaint for a declaratory judgment that "(a) since at least the spring of 2021, the Defendants have been operating their businesses as a Ponzi scheme, (b) the Defendants’ books, records, and businesses are so hopelessly intertwined that the Defendants’ estates should be substantively consolidated, and (c) as a consequence of adjudicating that the Defendants operated as a Ponzi scheme, all contracts with the Defendants on and after the date the Ponzi scheme began, including, without limitation, Terms of Use, are deemed null and void" in Ignat Tuganov, of Cyprus v. Celsius Network LLC, Celsius KeyFi LLC, Celsius Lending LLC,, Celsius Mining LLC, Celsius Network Inc., Celsius Network Limited, of the United Kingdom; Celsius Networks Lending LLC, Celsius US Holding LLC, GK8 Ltd., of Israel; GK8 UK Limited, of Israel, and GK8 USA LLC at the U.S. Bankruptcy Court for the Southern District of New York.