Plaintiffs Trulieve Inc., Trulieve Cannabis Corp. (collectively, “Trulieve”) and Kim Rivers sue Grizzly Research LLC, GeoInvesting, LLC, Siegfried “Siggy” Eggert, Scott A. St. John, and Jean-Joseph W. Lindor, Jr., and allege:
1. Plaintiff Trulieve Inc. (“Trulieve Inc.”) is a Florida corporation with its principal address, as well as facilities, in Gadsden County. Many of Trulieve Inc.’s shareholders are Florida residents. Trulieve Inc. relies on the financial strength and good name of its parent company (Plaintiff Trulieve Cannabis Corp.) such that injury to the parent’s reputation would likewise injure Trulieve Inc., and vice versa. At times in this Complaint Trulieve Inc. and Trulieve Corp. are collectively referred to as “Trulieve.”
STEARNS WEAVER MILLER
2. Plaintiff Trulieve Cannabis Corp. (“Trulieve Corp.”) is a holding company formed in British Columbia, Canada whose only assets are subsidiaries, which subsidiaries include Trulieve Inc. Trulieve Corp. owns no properties – its registered office in the United States is a facility owned by Trulieve Inc. in Gadsden County, Florida. Trulieve Corp. has no employees and instead acts through agents, most of whom are Florida residents employed by and paid through Trulieve Inc. Trulieve Corp. is publicly traded on the Canadian Stock Exchange under the symbol TRUL and over the counter under the symbol TCNNF.
3. Plaintiff Kim Rivers is a resident of Florida, the CEO of Trulieve Inc. and Trulieve Corp., and sues in her official and individual capacities.
4. Defendant Grizzly Research LLC (“Grizzly”) is a Delaware limited liability company who published false and defamatory statements about Plaintiffs and used agents in Florida to trespass on Trulieve Inc. property in order to obtain information and images used to defame Plaintiffs.
5. Grizzly represents itself as being “focused on producing differentiated research insights on publicly traded companies through in-depth due diligence.” See Grizzly’s Twitter Page, attached as Exhibit A.
6. However, Grizzly admits on its website that it may have “short positions in the companies covered,” such as Trulieve, and states: “We are biased in our views, just as investors, the company we publish on, the investment banks, and almost any stakeholder.” See Grizzly’s “About” Page attached as Exhibit B.1 Grizzly further admits: “You should assume that as of the publication date of the reports found on this website, GRIZZLY RESEARCH LLC stands to
1 All emphasis in quotations is added unless otherwise noted. 2
profit in the event the issuer’s stock declines.” See Grizzly’s “Disclaimer” Page, available at https://grizzlyreports.com/ (last accessed January 10, 2020)…
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The Grizzly Website & ReportTrulieve-Report-
The Trulieve Response To Grizzly Report & Their WebsiteTRULIEVE FACT SHEET_Grizzly FINAL
I’m a professional financial investigative journalist who has written for the Greenwich Time, Hearst CT Newspapers, Forbes Magazine, Fortune.com, The Atlantic.com, New York Magazine, New York Post, Trader Monthly, Housingwire, ML-Implode, The Business Insider, Long Island Business News, Dealbreaker, New York Observer, Bitcoin Magazine, DealFlow Media, SIRF.org and more. For the last five years I have been a contributing reporter for Market Nexus Media who publishes a financial trade publication called Growth Capital Investor.
I earned my breaking/investigative news chops reporting during the financial crisis in 2008 for the Sunday edition of the New York Post. I was one of the first to report on the missteps at IndyMac that lead to government investigations and lawsuits against the banks founders. Caught hedge funds like Carrington Capital abusing investors without disclosing conflicts of interest with senior RMBS bond holders; they were sued by Wilbur Ross for Civil RICO. I exposed Bear Stearns misleading their own investors and monoline insurers on the quality of the loans in their mortgage-backed securities, which led to a fraud lawsuit against JP Morgan/Bear Stearns and the $13 billion settlement with the DOJ in 2013. Since 2010 multiple Wall Street firms, that my reporting warned about first, have been [JP Morgan, SpongeTech, Security Savings Bank, SAC Capital, Palm Beach Capital Management, New Stream Capital, NIR Group/Cory Ribotsky, Bear Stearns RMBS Traders, Mike Perry IndyMac CEO, Steven Muehler and the Nanocap MarketPlace, Barry Honig and The Frost Group] investigated or charged for financial violations by the FBI/SEC/State AG or shut down by bank regulators.
The Huffington Post named me the number three most dangerous financial journalist for being willing to challenge the establishment and inform readers best. I’m working on trade-marking “Smashmouth Journalism”
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