Chen Scouts Influencers for “Eduard Grigoriann“

14. In or about December 2022, Chen began working with an individual operating under the fictitious name “Eduard Grigoriann,” and three purported representatives of “Eduard Grigoriann” (PersonaOne and two additional purported representatives, “PersonaTwo” and “PersonaThree“) to launch a new YouTube channel, initially under the name “Viewpoint Productions.” On or about January 10, 2023, PersonaTwo told Chen that Chen‘s “first task” was to “find a personality that could serve as the face of the channel,” and that “[f]or the right candidate we’re willing to pay around $1-2 million per year.” On or about January 13, 2023, PersonaTwo sent Chen a proposed contract for Chen‘s “Influencer Talent Scouting” services, with Chen listed as the “Agent” and a Hungarian entity (“HungarianShellEntityOne“) listed as the “Client.” HungarianShellEntityOne has no publicly available website. In exchange for Chen‘s services, the proposed contract awarded Chen $8,000 per month, plus a percentage of any deals that Chen “closed” with influencers. Over the next several months, while Chen continued to negotiate Chen‘s contract, Chen accepted interim payments and began to “scout” for influencers for the new YouTube channel for Eduard Grigoriann.
15. Beginning in or about February 2023, Chen solicited Dave Rubin and Tim Pool to perform work on behalf of “Eduard Grigoriann.” For example:a. On or about February 6, 2023, PersonaOne emailed Chen a “shortlist of candidates'” for the YouTube channel, including Dave Rubin and Tim Pool. In the same email, PersonaOne attached a receipt for an $8,000 money transfer from an entity in the Czech Republic (CzechShellEntityOne“) to Chen‘s Canadian company, CANADIAN TENET MEDIA . PersonaOne requested that Chen submnit an invoice for Chen‘s consultation services” to CzechShellEntityOne, which PersonaOne described as “our Czech sister company.” CzechShellEntityOne has a website purporting to sell automobile parts, but also listing unrelated services (e.g., “CyberAmor Suite, Fortifying Your Digital Defenses”). The website makes no mention of “Eduard Grigoriann,” PersonaOne, PersonaTwo, PersonaThree, Viewpoint Productions, or HungarianShellEntityOne.b. On or about February 6, 2023, Chen responded to PersonaTwo that Chen had let Donovan, “who I work with and who handles finances, know to get an invoice done.” Donovan subsequently prepared an invoice from CANADIAN TENET MEDIA to CzechShellEntityOne, which Donovan transmitted to Chen, and which Chen then emailed to PersonaOne. In Chen‘s February 6, 2023 response to PersonaOne, Chen also advised that Chen had reached out to Dave Rubin and “will be speaking with him today.” With respect to Tim Pool, Chen cautioned that a contract would likely cost “well over 2 million a year.” The next day, on or about February 7, 2023, PersonaOne responded that “Mr. Grigorian”—misspelling the name of PersonaOne‘s purported employer, Eduard Grigoriann—was OK with over $2m as long as we get the right person on board, under the right conditions.” Chen agreed to contact Tim Pool as well.c. On or about February 8, 2023, Chen reported to PersonaOne on Chen‘s outreach to Dave Rubin and Tim Pool. Chen advised that Dave Rubin said “it would need to be closer to 5 million yearly for him to be interested,” and that Tim Pool said “it would take 100k per weekly episode to make it worth his while.” Chen cautioned that “from a profitability standpoint, it would be very hard for Viewpoint [i.e., the initial public-facing name of the new venture] to recoup the costs for the likes of [Dave Rubin] and [Tim Pool] based on ad revenue from web traffic or sponsors alone.” Despite Chen‘s warning that Dave Rubin and Tim Pool would not be profitable to employ, on or about February 14, 2023, PersonaOne informed Chen that “[w]e would love to move forward with [Dave Rubin and Tim Pool].”d. On or about February 17, 2023, Chen sent an email introducing Tim Pool to “Eduard Grigoriann,” PersonaOne, and PersonaTwo. The parties arranged a call between Tim Pool and “Eduard Grigoriann,” which took place on or about February 22, 2023. In scheduling the call, Tim Pool requested that “Eduard Grigoriann” call Tim Pool‘s cellphone. Instead, PersonaTwo asked that the call take place on WhatsApp or Zoom. Both applications offer encrypted communications and the ability to place voice calls through voice-over-IP technology capable of obfuscating the physical location of a caller.e. On or about February 22, 2023, Chen emailed PersonaOne that Chen had spoken with Tim Pool, who was “happy with the licensing arrangement that was discussed” on Tim Pool‘s call with “Eduard Grigoriann.” Chen continued, however, that Tim Pool “still would like to know more about the company and who he will be working with.” Chen added that Chen had “assured [Tim Pool] that as we finalize the contract and begin working to put his show together and coordinate the launch, everyone will have time to get to know each other better and feel less like strangers!”f. On or about February 28, 2023, Chen emailed PersonaOne that Chen had spoken with Dave Rubin, who would “like some material about Mr. Grigoriann to learn a bit about who [Dave Rubin would] be working with.” Chen asked if there were “any links (press release, interviews, LinkedIn, profiles, etc.) we can forward” to Dave Rubin about Eduard Grigoriann.” On or about March 2, 2023, PersonaOne responded to Chen‘s email, writing that PersonaOne was unsure that “Mr. Grigoriann… gave out any public interviews, but you could send [Dave Rubin] our LinkedIn page,” with a hyperlink to a LinkedIn page for Viewpoint Productions. PersonaOne also attached a receipt for another $8,000 money transfer from CzechShellEntityOne to CANADIANTENETMEDIA .g. On or about April 21, 2023, and again on or about April 24, 2023, Chen performed Google searches for “Eduard Grigoriann” and for “[Bank-1] Eduard Grigoriann.” As of in or about August 2024, neither Google search returns any results for a person by that name, much less any webpages describing an “Eduard Grigoriann” as a finance professional affiliated with Bank-1.

    h. On or about April 24, 2023, Chen emailed PersonaOne that Dave Rubin was “really insisting on seeing some materials (profile, article, whatever) on Eduard before [Dave Rubin] feels comfortable moving forward. Is there anything we can provide [Dave Rubin] with?” PersonaOne responded that “we’ll send you a profile on Mr. Grigoriann that you could send over to [Dave Rubin].”

    i. On or about May 4, 2023, PersonaOne emailed Chen “the CV” to provide to Dave Rubin. That profile is reproduced with redactions and blurring below: