Mr. Bordynuik, as stated, served as a promoter of his own personal stock in inducing the Plaintiff to work for the company. Mr. Bordynuik also acted outside the scope of his employment in forming an oral contract between Plaintiff and Mr. Bordynuik personally (as to Mr. Bordynuik's personal stock).
Further, the Complaint and the attached evidence establish that Mr. Bordynuik committed fraud or intentional misconduct against the Plaintiff, a Florida resident. Plaintiff also seeks leave to amend his Complaint to further allege such misconduct, as explained in more detail below.
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