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Dkt. #272 — Defendants' Statement of Material Facts
Defendants' competing statement of material facts, demonstrating genuine disputes that preclude summary judgment. Includes blockchain evidence, investor testimony, and expert analysis showing no investor harm.
Document Details
Date Filed
October 17, 2023
Agency
Court Filing
Recipient
U.S. District Court, N.D. Illinois
File
Defendants_Statement_Material_Facts_Dkt272.pdf
217 KB
Page 1 / 24
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IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
COMMODITY FUTURES TRADING
COMMISSION,
Plaintiff,
v.
SAM IKKURTY A/K/A SREENIV ASI
RAO, RAVISHANKAR AVADHANAM,
AND JAFIA LLC,
Defendants,
IKKURTY CAPITAL, LLC D/B/A ROSE
CITY INCOME FUND, ROSE CITY
INCOME FUND II LLP, AND SENECA
VENTURES, LLC,
Relief Defendants.
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Case No. 1-22-CV-02465
Hon. Mary M. Rowland
Magistrate Judge Jeffrey Cummings
MEMORANDUM OF LAW IN SUPPORT OF DEFENDANTS SAM IKKURTY AND
JAFIA, LLC’S MOTION FOR SUMMARY JUDGMENT, MOTION TO DISMISS, AND
MOTION FOR JUDGMENT ON THE PLEADINGS
Defendants Sam Ikkurty (“Mr. Ikkurty”) and Jafia LLC (“Jafia”) (together, “Defendants”)
respectfully submit this memorandum of law in support of their Motion for Summary Judgment,
Motion to Dismiss Plaintiff Commodity Futures Trading Commission’s (the “CFTC’s” or the
“Commission’s”) Complaint for Injunctive Relief, Civil Monetary Penalties, and Other Equitable
Relief [Dkt. #1] (the “Complaint”), and Motion for Judgment on the Pleadings pursuant to Federal
Rules of Civil Procedure 56, 12(b)(1) and 12(c). This Motion cites to the contemporaneously filed
Defendants’ Sam Ikkurty and Jafia, LLC’s Statement of Material Facts Pursuant to Local Rule
56.1(A)(2), referred to hereinafter as “Def. Stmt.”
Case: 1:22-cv-02465 Document #: 271 Filed: 10/16/23 Page 1 of 24 PageID #:4291
IN THE UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
COMMODITY FUTURES TRADING
COMMISSION,
Plaintiff,
v.
SAM IKKURTY A/K/A SREENIV ASI
RAO, RAVISHANKAR AVADHANAM,
AND JAFIA LLC,
Defendants,
IKKURTY CAPITAL, LLC D/B/A ROSE
CITY INCOME FUND, ROSE CITY
INCOME FUND II LLP, AND SENECA
VENTURES, LLC,
Relief Defendants.
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
Case No. 1-22-CV-02465
Hon. Mary M. Rowland
Magistrate Judge Jeffrey Cummings
MEMORANDUM OF LAW IN SUPPORT OF DEFENDANTS SAM IKKURTY AND
JAFIA, LLC’S MOTION FOR SUMMARY JUDGMENT, MOTION TO DISMISS, AND
MOTION FOR JUDGMENT ON THE PLEADINGS
Defendants Sam Ikkurty (“Mr. Ikkurty”) and Jafia LLC (“Jafia”) (together, “Defendants”)
respectfully submit this memorandum of law in support of their Motion for Summary Judgment,
Motion to Dismiss Plaintiff Commodity Futures Trading Commission’s (the “CFTC’s” or the
“Commission’s”) Complaint for Injunctive Relief, Civil Monetary Penalties, and Other Equitable
Relief [Dkt. #1] (the “Complaint”), and Motion for Judgment on the Pleadings pursuant to Federal
Rules of Civil Procedure 56, 12(b)(1) and 12(c). This Motion cites to the contemporaneously filed
Defendants’ Sam Ikkurty and Jafia, LLC’s Statement of Material Facts Pursuant to Local Rule
56.1(A)(2), referred to hereinafter as “Def. Stmt.”
Case: 1:22-cv-02465 Document #: 271 Filed: 10/16/23 Page 1 of 24 PageID #:4291
Key Points
Demonstrates genuine factual disputes precluding summary judgment
Includes blockchain evidence ignored by CFTC investigators
Documents 100% investor opposition to CFTC's liquidation
Supported by expert report finding no misappropriation