12. Mitchell, age 36, is a resident of Queens, New York.
13. During the Relevant Period, Mitchell assumed the alias David Dangote and claimed to be the nephew of Aliko Dangote, one of Africa’s richest persons.
14. In addition to lying to investors about his name and familial relationship, Mitchell also falsely claimed that he was raised in London, graduated from Harvard Business School, worked in the financial field, and had a net worth of $1 billion.
15. While claiming to be Aliko Dangote’s nephew, to have a net worth of $1 billion, and to be a graduate of Harvard Business School, Mitchell solicited investments from two individuals.
16. At the time he solicited these two investors, Mitchell knew, or recklessly disregarded that, he was not Aliko Dangote’s nephew, he did not have a net worth anywhere close to $1 billion, and did not graduate from (or even attend) Harvard Business School...