SEC v. Viktor Gjonaj, No. 2:21-cv-10199, Eastern District of Michigan (Jan. 28, 2021) — Complaint

1
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
UNITED STATES SECURITIES AND
EXCHANGE COMMISSION,
Plaintiff,
Case No. 21-CV-10199
v.Hon.
VIKTOR GJONAJ,
Defendant.
/
COMPLAINT
Plaintiff, the United States Securities and Exchange Commission (“SEC”), alleges as
follows:
SUMMARY OF THE ACTION
1.The SEC brings this civil law enforcement action to address Defendant Viktor
Gjonaj’s (“Gjonaj”) fraudulent offer and sale of securities to at least 24 investors, who invested
approxim
ately $26.4 million from at least mid-2016 to 2019. Most of the investors, like Gjonaj,
are members of the Albanian-American community in the Detroit area. Gjonaj generally told
investors that he would use their funds to purchase, develop, and resell real estate properties for
a profit. In fact, Gjonaj did not use any of their money for real estate investments.
2.Instead, Gjonaj used the investors’ money to support his obsession with winning
the Michigan Lottery, spending at least $10 million of their money on the Daily 3 and Daily 4
Lottery. Gjonaj often spent hundreds of thousands of dollars a week on Lottery tickets, at times
buying as much as $1 million of Lottery tickets per week.

2

3. Gjonaj sent only approximately $7.4 million back to investors in purported
returns on real estate deals. However, all of these “returns” were actually funded by Gjonaj’s
Lottery winnings. None of the money the investors received was generated by real estate
investments. By August 2019, Gjonaj owed the investors approximately $19 million and had
lost all of his own and his investors’ money.
4. By engaging in this conduct, Gjonaj violated Section 17(a) of the Securities Act
of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)]; and Section 10(b) of the Securities Exchange
Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5(a), (b), and (c) thereunder
[17 C.F.R. 240.10b-5(a), (b), and (c)].
5. In connection with this lawsuit, the SEC seeks a permanent injunction against
Gjonaj to enjoin him from future violations of the above-cited provisions of the federal
securities laws. The SEC further seeks an order requiring Gjonaj to pay disgorgement, plus
prejudgment interest, of the ill-gotten gains that he received through his fraud, along with the
imposition of civil penalties pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)]
and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)].
JURISDICTION AND VENUE

6. The Court has jurisdiction over this action pursuant to Sections 21(d) and 27(a)
of the Exchange Act [15 U.S.C. §§ 78u(d) and 78aa] and Sections 20(b) and 22(a) of the
Securities Act [15 U.S.C. §§ 77t(b) and 77v]. Gjonaj, directly or indirectly, has made use of the
means or instrumentalities of interstate commerce, or of the mails, or of any facility of any
national securities exchange in connection with the acts, practices, and courses of business
alleged herein, and will continue to do so unless enjoined.
7. Venue is proper in this Court pursuant to Section 22(a) of the Securities Act [15

3

U.S.C. § 77v] and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa] because certain of the
acts, practices, and courses of business constituting the violations alleged in this Complaint
occurred within the jurisdiction of the United States District Court for the Eastern District of
Michigan. In addition, during the relevant time period, Gjonaj resided and conducted business
within the Eastern District of Michigan.
THE DEFENDANT

8. Viktor Gjonaj is 43 years old and last resided in Shelby Township, Michigan.
He is the sole owner of Title Plus Title Services LLC. During the relevant time period, Gjonaj
operated out of an office in Troy, Michigan.
FACTS

9. From at least mid-2016 to 2019, Gjonaj raised approximately $26.4 million
through the offer and sale of securities in the form of investment contracts to at least 24
investors in at least 66 purported real estate deals. Most of the investors, like Gjonaj, are
members of the Albanian-American community in the Detroit area. Gjonaj was known within
the community to be a successful real estate entrepreneur.
10. Gjonaj’s fraud began with his obsession with winning the Michigan Lottery. In
June 2016, Gjonaj thought he had developed a strategy that would all but guarantee he would
win in both the Daily 3 and Daily 4 Lottery draws. Gjonaj began betting between $25,000 and
$100,000 per week using his strategy.
11. By July 2016, Gjonaj needed additional cash to continue his Lottery playing, and
began raising money through the fraudulent offer and sale of purported investments in real
estate. Gjonaj solicited investors in his community by, among other things, speaking to them in
person and on the telephone.

4

12. Gjonaj generally told investors that he would use their funds to purchase,
develop, and resell real estate properties for a profit, and pay investors their pro-rata share of
those profits. Gjonaj did not promise investors a specific investment return, but when he paid
certain investors purported profits from their investments, he included a 50% “return” in
addition to their principal.
13. Gjonaj sold some of the investors “membership interests” in a particular limited
liability company that Gjonaj created to purchase, develop, and resell real estate property. Some
of these investments were made pursuant to written operating agreements entered into by the
investor and Gjonaj under which they each acquired membership interests in a company in
exchange for capital contributions.  The capital contributions were to be pooled. These
agreements contemplated the possibility of additional investors, describing Gjonaj and the
investor as “initial Members,” describing their capital contributions as “initial capital
contributions,” and stating, among other things, that they would be “binding on any individuals
and/or entities who may acquire membership interests . . . in the future.” The agreements
designated Gjonaj as the “Operating Manager” responsible for carrying out the business of the
LLCs and provided that the investor/members would receive their pro-rata portion of proceeds
from the sale of the property, and that each member would only profit if the project was
profitable. The agreements further stated that the membership interests could not be sold
without registration under the Securities Act or any other applicable securities laws or an
exemption therefrom.
14. Gjonaj also sold investments pursuant to verbal agreements. These investments
were made pursuant to oral “handshake” deals between the investors and Gjonaj without
written documentation. As he did in connection with the investments that included a written

5

agreement, Gjonaj told these investors that he would be a co-investor in the investments, would
pool his money with the investors, and would use the investment funds to purchase, develop,
and resell real estate properties for a profit.
15. Gjonaj created Title Plus Title Service LLC, a sham real estate title company
with no legitimate business, and represented to investors that it would serve as the closing
agency for the real estate deals. He instructed investors to make out their checks or wire their
funds to himself or Title Plus. Gjonaj deposited and pooled investor funds in an account in the
name of Title Plus. Gjonaj then directed the money from the Title Plus account to his personal
accounts, other Gjonaj entity accounts, or directly to the Lottery. Gjonaj never purchased any of
the real estate properties as he had represented to investors.
16. Of the approximately $26.4 million Gjonaj raised from investors, Gjonaj spent at
least $10 million on lottery tickets and directed millions to his personal checking account. At
times, Gjonaj bought as much as $1 million of Lottery tickets per week.
17. Between 2016 and 2019, Gjonaj won several lottery prizes totaling at least $25
million and used approximately $7.4 million to pay investors purported principal and interest
payments on their investments. Gjonaj made these payments via wire transfer and check. He
claimed the payments were generated by the sale proceeds from the (non-existent) real estate
transactions. His lottery winnings, however, were insufficient to pay what he owed to the
investors because Gjonaj lost far more money than he won.
18. By August 2019, Gjonaj owed the investors approximately $19 million, had lost
all of his own and his investors’ money, and had not purchased any real estate.

6

COUNT I
Violation of Section 17(a) of the Securities Act

19. The SEC re-alleges and incorporates by reference paragraphs 1 through 18 as
though fully set forth herein.
20. Gjonaj, directly or indirectly, in the offer or sale of securities and by the use of
the means or instruments of transportation or communication in interstate commerce or the
mails, (1) knowingly employed one or more devices, schemes, or artifices to defraud, (2)
knowingly or negligently obtained money or property by means of one or more untrue
statements of a material fact or omissions of a material fact necessary in order to make the
statements made, in light of the circumstances under which they were made, not misleading,
and/or (3) knowingly or negligently engaged in one or more transactions, practices, or courses
of business which operated or would operate as a fraud or deceit upon the purchaser.
21. By reason of the foregoing, Gjonaj, directly or indirectly, violated and, unless
enjoined, will again violate Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].
COUNT II
Violation of 10(b) of the Exchange Act and Exchange Act Rule 10b-5

22. The SEC re-alleges and incorporates by reference paragraphs 1 through 18 as
though fully set forth herein.
23. Gjonaj in connection with the purchase or sale of securities, by the use of any
means or instrumentalities of interstate commerce or by the use of the mails, or any national
securities exchange, directly and indirectly used and employed devices, schemes, and artifices
to defraud; made untrue statements of material fact and omitted to state a material fact
necessary in order to make the statements made, in light of the circumstances under which they
were made, not misleading; and engaged in acts, practices, and courses of business which

7

operated or would have operated as a fraud or deceit upon investors.
24. Gjonaj acted with scienter in that he knowingly engaged in the fraudulent
conduct described above.
25. By reason of the foregoing, Gjonaj violated, and unless restrained and enjoined,
will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. §78j(b)] and Rule 10b-5
thereunder [17 C.F.R. 240.10b-5].
RELIEF REQUESTED
WHEREFORE, Plaintiff respectfully requests that this Court grant the following relief:
I.
Enter an Order finding that Gjonaj committed, and unless restrained, will continue to
commit, the violations alleged in this Complaint;
II.

Permanently restrain and enjoin Gjonaj from, directly or indirectly, violating Section
10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5]
thereunder; and Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)].
III.

Order Gjonaj to disgorge the ill-gotten gains that he received as a result of the violations
alleged in this Complaint, plus prejudgment interest;
IV.
Order Gjonaj to pay civil penalties pursuant to Section 21(d)(3) of the Exchange Act [15
U.S.C. § 78u(d)(3)]; and Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)];
V.
Retain jurisdiction of this action in accordance with the principles of equity and the

8

Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and
decrees that may be entered or to entertain any suitable applications or motions for additional
relief within the Court’s jurisdiction; and
VI.

Such other and further relief as the Court deems necessary and appropriate.

JURY DEMAND

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby requests a
trial by jury on all issues so triable.
Dated:  January 28, 2021 Respectfully Submitted,

UNITED STATES SECURITIES AND EXCHANGE
COMMISSION
     /s/  Daniel J. Hayes
Daniel J. Hayes, Illinois Bar No. 6243089
Steven L. Klawans, Illinois Bar No. 6229593
Marlene Key-Patterson, Illinois Bar No. 6296919
James G. O’Keefe, Illinois Bar No. 6293490
U.S. Securities and Exchange Commission
175 West Jackson Blvd., Suite 1450
Chicago, Illinois 60604
(312) 353-7390
(312) 353-7398 (facsimile)
[email protected]
[email protected]
[email protected]
[email protected]

Attorneys for Plaintiff

         LOCAL COUNSEL
Matthew Schneider, United States Attorney
Karen Reynolds, Assistant United States Attorney
211 W. Fort Street, Suite 2001
Detroit, MI 48226
(313) 226-9100
[email protected]

1 

UNITED STATES DISTRICT COURT 
EASTERN DISTRICT OF MICHIGAN 

SOUTHERN DIVISION 

UNITED STATES SECURITIES AND 
EXCHANGE COMMISSION, 

Plaintiff, 
Case No. 21-CV-10199 

v. Hon.

VIKTOR GJONAJ, 

Defendant. 
/ 

COMPLAINT 

Plaintiff, the United States Securities and Exchange Commission (“SEC”), alleges as 

follows: 

SUMMARY OF THE ACTION 

1. The SEC brings this civil law enforcement action to address Defendant Viktor

Gjonaj’s (“Gjonaj”) fraudulent offer and sale of securities to at least 24 investors, who invested 

approximately $26.4 million from at least mid-2016 to 2019. Most of the investors, like Gjonaj, 

are members of the Albanian-American community in the Detroit area. Gjonaj generally told 

investors that he would use their funds to purchase, develop, and resell real estate properties for 

a profit. In fact, Gjonaj did not use any of their money for real estate investments. 

2. Instead, Gjonaj used the investors’ money to support his obsession with winning

the Michigan Lottery, spending at least $10 million of their money on the Daily 3 and Daily 4 

Lottery. Gjonaj often spent hundreds of thousands of dollars a week on Lottery tickets, at times 

buying as much as $1 million of Lottery tickets per week. 

Case 2:21-cv-10199-PDB-DRG   ECF No. 1, PageID.1   Filed 01/28/21   Page 1 of 8



 

2  

3. Gjonaj sent only approximately $7.4 million back to investors in purported 

returns on real estate deals. However, all of these “returns” were actually funded by Gjonaj’s 

Lottery winnings. None of the money the investors received was generated by real estate 

investments. By August 2019, Gjonaj owed the investors approximately $19 million and had 

lost all of his own and his investors’ money. 

4. By engaging in this conduct, Gjonaj violated Section 17(a) of the Securities Act 

of 1933 (“Securities Act”) [15 U.S.C. § 77q(a)]; and Section 10(b) of the Securities Exchange 

Act of 1934 (“Exchange Act”) [15 U.S.C. § 78j(b)] and Rule 10b-5(a), (b), and (c) thereunder 

[17 C.F.R. 240.10b-5(a), (b), and (c)]. 

5. In connection with this lawsuit, the SEC seeks a permanent injunction against 

Gjonaj to enjoin him from future violations of the above-cited provisions of the federal 

securities laws. The SEC further seeks an order requiring Gjonaj to pay disgorgement, plus 

prejudgment interest, of the ill-gotten gains that he received through his fraud, along with the 

imposition of civil penalties pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] 

and Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)]. 

JURISDICTION AND VENUE 
 

6. The Court has jurisdiction over this action pursuant to Sections 21(d) and 27(a) 

of the Exchange Act [15 U.S.C. §§ 78u(d) and 78aa] and Sections 20(b) and 22(a) of the 

Securities Act [15 U.S.C. §§ 77t(b) and 77v]. Gjonaj, directly or indirectly, has made use of the 

means or instrumentalities of interstate commerce, or of the mails, or of any facility of any 

national securities exchange in connection with the acts, practices, and courses of business 

alleged herein, and will continue to do so unless enjoined. 

7. Venue is proper in this Court pursuant to Section 22(a) of the Securities Act [15 

Case 2:21-cv-10199-PDB-DRG   ECF No. 1, PageID.2   Filed 01/28/21   Page 2 of 8



 

3  

U.S.C. § 77v] and Section 27(a) of the Exchange Act [15 U.S.C. § 78aa] because certain of the 

acts, practices, and courses of business constituting the violations alleged in this Complaint 

occurred within the jurisdiction of the United States District Court for the Eastern District of 

Michigan. In addition, during the relevant time period, Gjonaj resided and conducted business 

within the Eastern District of Michigan. 

THE DEFENDANT 
 

8. Viktor Gjonaj is 43 years old and last resided in Shelby Township, Michigan. 

He is the sole owner of Title Plus Title Services LLC. During the relevant time period, Gjonaj 

operated out of an office in Troy, Michigan. 

FACTS 
 

9. From at least mid-2016 to 2019, Gjonaj raised approximately $26.4 million 

through the offer and sale of securities in the form of investment contracts to at least 24 

investors in at least 66 purported real estate deals. Most of the investors, like Gjonaj, are 

members of the Albanian-American community in the Detroit area. Gjonaj was known within 

the community to be a successful real estate entrepreneur.  

10. Gjonaj’s fraud began with his obsession with winning the Michigan Lottery. In 

June 2016, Gjonaj thought he had developed a strategy that would all but guarantee he would 

win in both the Daily 3 and Daily 4 Lottery draws. Gjonaj began betting between $25,000 and 

$100,000 per week using his strategy.  

11. By July 2016, Gjonaj needed additional cash to continue his Lottery playing, and 

began raising money through the fraudulent offer and sale of purported investments in real 

estate. Gjonaj solicited investors in his community by, among other things, speaking to them in 

person and on the telephone. 

Case 2:21-cv-10199-PDB-DRG   ECF No. 1, PageID.3   Filed 01/28/21   Page 3 of 8



 

4  

12. Gjonaj generally told investors that he would use their funds to purchase, 

develop, and resell real estate properties for a profit, and pay investors their pro-rata share of 

those profits. Gjonaj did not promise investors a specific investment return, but when he paid 

certain investors purported profits from their investments, he included a 50% “return” in 

addition to their principal.  

13. Gjonaj sold some of the investors “membership interests” in a particular limited 

liability company that Gjonaj created to purchase, develop, and resell real estate property. Some 

of these investments were made pursuant to written operating agreements entered into by the 

investor and Gjonaj under which they each acquired membership interests in a company in 

exchange for capital contributions.  The capital contributions were to be pooled. These 

agreements contemplated the possibility of additional investors, describing Gjonaj and the 

investor as “initial Members,” describing their capital contributions as “initial capital 

contributions,” and stating, among other things, that they would be “binding on any individuals 

and/or entities who may acquire membership interests . . . in the future.” The agreements 

designated Gjonaj as the “Operating Manager” responsible for carrying out the business of the 

LLCs and provided that the investor/members would receive their pro-rata portion of proceeds 

from the sale of the property, and that each member would only profit if the project was 

profitable. The agreements further stated that the membership interests could not be sold 

without registration under the Securities Act or any other applicable securities laws or an 

exemption therefrom.  

14. Gjonaj also sold investments pursuant to verbal agreements. These investments 

were made pursuant to oral “handshake” deals between the investors and Gjonaj without 

written documentation. As he did in connection with the investments that included a written 

Case 2:21-cv-10199-PDB-DRG   ECF No. 1, PageID.4   Filed 01/28/21   Page 4 of 8



 

5  

agreement, Gjonaj told these investors that he would be a co-investor in the investments, would 

pool his money with the investors, and would use the investment funds to purchase, develop, 

and resell real estate properties for a profit. 

15. Gjonaj created Title Plus Title Service LLC, a sham real estate title company 

with no legitimate business, and represented to investors that it would serve as the closing 

agency for the real estate deals. He instructed investors to make out their checks or wire their 

funds to himself or Title Plus. Gjonaj deposited and pooled investor funds in an account in the 

name of Title Plus. Gjonaj then directed the money from the Title Plus account to his personal 

accounts, other Gjonaj entity accounts, or directly to the Lottery. Gjonaj never purchased any of 

the real estate properties as he had represented to investors.  

16. Of the approximately $26.4 million Gjonaj raised from investors, Gjonaj spent at 

least $10 million on lottery tickets and directed millions to his personal checking account. At 

times, Gjonaj bought as much as $1 million of Lottery tickets per week. 

17. Between 2016 and 2019, Gjonaj won several lottery prizes totaling at least $25 

million and used approximately $7.4 million to pay investors purported principal and interest 

payments on their investments. Gjonaj made these payments via wire transfer and check. He 

claimed the payments were generated by the sale proceeds from the (non-existent) real estate 

transactions. His lottery winnings, however, were insufficient to pay what he owed to the 

investors because Gjonaj lost far more money than he won. 

18. By August 2019, Gjonaj owed the investors approximately $19 million, had lost 

all of his own and his investors’ money, and had not purchased any real estate.  

  

Case 2:21-cv-10199-PDB-DRG   ECF No. 1, PageID.5   Filed 01/28/21   Page 5 of 8



 

6  

COUNT I 
Violation of Section 17(a) of the Securities Act 

 
19. The SEC re-alleges and incorporates by reference paragraphs 1 through 18 as 

though fully set forth herein. 

20. Gjonaj, directly or indirectly, in the offer or sale of securities and by the use of 

the means or instruments of transportation or communication in interstate commerce or the 

mails, (1) knowingly employed one or more devices, schemes, or artifices to defraud, (2) 

knowingly or negligently obtained money or property by means of one or more untrue 

statements of a material fact or omissions of a material fact necessary in order to make the 

statements made, in light of the circumstances under which they were made, not misleading, 

and/or (3) knowingly or negligently engaged in one or more transactions, practices, or courses 

of business which operated or would operate as a fraud or deceit upon the purchaser. 

21. By reason of the foregoing, Gjonaj, directly or indirectly, violated and, unless 

enjoined, will again violate Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

COUNT II 
Violation of 10(b) of the Exchange Act and Exchange Act Rule 10b-5 

 
22. The SEC re-alleges and incorporates by reference paragraphs 1 through 18 as 

though fully set forth herein. 

23. Gjonaj in connection with the purchase or sale of securities, by the use of any 

means or instrumentalities of interstate commerce or by the use of the mails, or any national 

securities exchange, directly and indirectly used and employed devices, schemes, and artifices 

to defraud; made untrue statements of material fact and omitted to state a material fact 

necessary in order to make the statements made, in light of the circumstances under which they 

were made, not misleading; and engaged in acts, practices, and courses of business which 

Case 2:21-cv-10199-PDB-DRG   ECF No. 1, PageID.6   Filed 01/28/21   Page 6 of 8



 

7  

operated or would have operated as a fraud or deceit upon investors. 

24. Gjonaj acted with scienter in that he knowingly engaged in the fraudulent 

conduct described above. 

25. By reason of the foregoing, Gjonaj violated, and unless restrained and enjoined, 

will continue to violate, Section 10(b) of the Exchange Act [15 U.S.C. §78j(b)] and Rule 10b-5 

thereunder [17 C.F.R. 240.10b-5]. 

RELIEF REQUESTED 

WHEREFORE, Plaintiff respectfully requests that this Court grant the following relief: 

I. 

Enter an Order finding that Gjonaj committed, and unless restrained, will continue to 

commit, the violations alleged in this Complaint; 

II. 
 

Permanently restrain and enjoin Gjonaj from, directly or indirectly, violating Section 

10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Rule 10b-5 [17 C.F.R. § 240.10b-5] 

thereunder; and Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]. 

III. 
 

Order Gjonaj to disgorge the ill-gotten gains that he received as a result of the violations 

alleged in this Complaint, plus prejudgment interest; 

IV. 

Order Gjonaj to pay civil penalties pursuant to Section 21(d)(3) of the Exchange Act [15 

U.S.C. § 78u(d)(3)]; and Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)]; 

V. 

Retain jurisdiction of this action in accordance with the principles of equity and the 

Case 2:21-cv-10199-PDB-DRG   ECF No. 1, PageID.7   Filed 01/28/21   Page 7 of 8



 

8  

Federal Rules of Civil Procedure in order to implement and carry out the terms of all orders and 

decrees that may be entered or to entertain any suitable applications or motions for additional 

relief within the Court’s jurisdiction; and 

VI. 
 

Such other and further relief as the Court deems necessary and appropriate. 
 

JURY DEMAND 
 

Pursuant to Rule 38 of the Federal Rules of Civil Procedure, Plaintiff hereby requests a 

trial by jury on all issues so triable. 

Dated:  January 28, 2021 Respectfully Submitted, 
 

UNITED STATES SECURITIES AND EXCHANGE 
COMMISSION 

  /s/  Daniel J. Hayes  
Daniel J. Hayes, Illinois Bar No. 6243089  
Steven L. Klawans, Illinois Bar No. 6229593 
Marlene Key-Patterson, Illinois Bar No. 6296919 
James G. O’Keefe, Illinois Bar No. 6293490 
U.S. Securities and Exchange Commission  
175 West Jackson Blvd., Suite 1450 
Chicago, Illinois 60604 
(312) 353-7390 
(312) 353-7398 (facsimile) 
[email protected]  
[email protected] 
[email protected] 
[email protected] 
 
Attorneys for Plaintiff 
 

         LOCAL COUNSEL 
Matthew Schneider, United States Attorney 
Karen Reynolds, Assistant United States Attorney 
211 W. Fort Street, Suite 2001 
Detroit, MI 48226 
(313) 226-9100 
[email protected] 

Case 2:21-cv-10199-PDB-DRG   ECF No. 1, PageID.8   Filed 01/28/21   Page 8 of 8