This situation should be both shocking and chilling, as it could happen to any distributor. Consider how flimsy the evidence of fraud is. To understand how the jury could reach such an incorrect verdict, you must recognize that none of the data or testimony presented was truthful. The case was fundamentally misleading, as the government filtered out $28 million in commission gains, used as the “source” of the alleged victims’ payments. The reported loss reports were fabricated by the government’s manipulation of the data. While $40 million in product sales occurred, $38 million was paid to distributors deemed to be the alleged victims.
Evidence against Hosseinipour in the I2G Case
The Proof offered regarding Hosseinipour disproves criminal intent and that a crime occurred, as the innocent acts described would apply equally to any distributor in the company. The government’s primary evidence against Hosseinipour was her partner’s “guilty plea.” However, Anzalone testified that he and Hosseinipour lacked criminal intent wrongdoings.(Doc 505 4730)
At trial, the Prosecution never claimed that Hosseinipour had criminal intent. Hosseinipour was described in closing remarks as an ibo who joined with other ibos with good intent. (R.690, #9411.) Her crime was receiving red flags and staying with the company.” (R.671, #7705.) They told the Court that criminal intent was not required to prove guilt. ( Doc 505 #4741) The prosecution used Anzalone’s “guilty plea” and “cooperation” admissions to imply Hosseinipour’s guilt despite dozens of statements that he and they never believed they were doing anything wrong. (Doc 505 4730), believed in Maike (Doc 505 4651,52, 4570-72, 4761, 4661,4684, 4697, 4705 ) believed in Koerner (Doc 505 4801, 4570, 4719 ) believed issues would be fixed (doc 505 4570) believed in the products (doc 505 4759-61, 4730), believed there was a good legal team and everything was legal. (Doc 504 4462, 4345, 4422, 4454, 4772). He stated that Hosseinipour would not knowingly mislead, lie, or deceive. (Doc 505 4730 doc 511 #4830) and described her as honest, trustworthy, loyal, a good person, smart, had a desire to help others, would not lie, and would help anyone without care less if money was made on them. (Doc 511 $843, 4844) Anzalone affirmed that he and Susan, his wife, were excited about the i2G Touch Product and introduced it to Maike. Susan provided ongoing company training on the i2G Touch and G1e Touch (doc 505 4680-4684) and had a strong belief in the company and its products. (doc 505 4671, 72, 81, 84, 4759) Anzalone stated that Hosseinipour was all about getting customers (doc 465 #3602 701 #10948) and sent detailed customer acquisition emails to Maike. (doc 505 4564) (Hosseinipour’s affidavit sending exculpatory emails to her Manning 9 times, but he did not present them or question Anzalone on them) Logan and Dugger stated she cared deeply about her team and invested huge amounts of time to support and help her team and provide training.( doc 701 #10944)
The government claimed that Hosseinipour was a top distributor with “insider knowledge” of I2G. R.504:#4479-4480)
Anzalone explained “insider” as a term that loosely connotes the courtesy given to top producers warranting an occasional “heads-up” on future plans; however, the term “insider” is misrepresented by the government (R.504: #4479-4480). In contrast, Hosseinipour did not receive the same courtesy from Maike. She was described as being distant from Maike and was excluded from most discussions (465 #3579). Additionally, she had “no influence with Maike,” which led her to copy the Azalones on emails to ensure he read them (504 #4372). Furthermore, there is no documented communication with Barnes..
The government argued that Hosseinipour knew that Emperors had “zero” chance of recovering their investment through casino profits (R.465: #3601-3602). However, this was never promised or offered. In all five hangout videos presented as evidence, Hosseinipour stated that “the only guarantee was that no one would earn a single dime without extremely hard work,” as would be required in any business. (155 1:44-2:20 Doc 701 #10944)
In contrast to the government’s claims, multiple witnesses—including Anzalone, Dugger, Logan, Fredericks, and Aiello—testified that Hosseinipur did not present i2G as an investment (Doc 701 #10943, 44). Instead, she described it as a legitimate multi-level marketing (MLM) program that required hard work (ex145, ex151, Fredericks). The notion of recouping “investments” from casino profits was never presented as part of the i2G plan. She emphasized the importance of driving casino customers to the i2G products, with the business volume tied to commission payments (155 20:35-22:30 Doc 701 #10948).
From Hosseinipour Video Script:
Once you understand you won’t be able to sleep at night
because our customer volume and online
entertainment counts as the recurring volume that you
get paid on, that you cycle on, and that you hit
leadership bonuses on. As a matter of fact, we’ve got
Tony Adimy and his partner just prequalified for Ruby
and about 50k from customers from the casino helped
them hit that qualification. 25% of the worldwide bets
count as volume. Can you see how this can create
unbelievable sustainability? Because you’re not only
getting paid on the packages you sell and the recurring
auto-ships you are getting paid on customer volume. If
you’ve got someone who signs up as a customer in the
casino and they just want to play in the casino because
people play with or without you and they spend $1000
next month- $250 goes back into your binary tree.
The government claimed that ninety percent of Hosseinipour and Anzalone’s earnings came from recruitment, R.504:#4413, and they only ever saw “negligible” casino profits, R.504:#4528-4529; R.505:#4553. Nevertheless, Hosseinipour falsely claimed in an April 2014 promotional video that casino profits had gone up every month. GX.155(24:37- 25:05); see R.683:#8712-8713.
Anzalone’s and Keep’s recruitment focus opinions are merely semantics and lack evidence. In contrast, government witness Reynolds explained that “product sales” drove the I2G compensation plan, describing I2G revenues as 93% of product sales. (doc 498 4246)
The same accusations were directed at Neora, claiming that 90% of its focus was on recruitment. However, these allegations were dismissed as “rigid theoretical opinion.” An expert from the FTC pointed out that there is no established “recruitment test” to assess the balance between recruitment efforts and customer sales. Moreover, there are no criteria that favor “retail sales” over “internal consumption.” It was unreasonable to expect Hosseinipour to understand a formula that does not exist. As Anzalone noted, they relied on Rick and compliance attorney Koerner, believing that sound legal practices were in place. (doc 504 4462, 4345, 4422, 4454).
Customer Spots
The government accused Hosseinipour of committing fraud by secretly holding “customer spots” that were not disclosed to the public. However, data from i2G in 101i revealed that the distributors maintained 2,650 such customer positions. Reynolds had programmed the $19.95 position into the pay plan as the base rank (Doc 497#4032, 4047). There is no evidence that this information was kept secret. Both Reynolds and Anzalone stated that this practice was common and legal. Reynolds emphasized that the rank level did not affect a distributor’s earnings, as hard work is required to make money (Doc 498#4213). Logan testified that he acquired a fantasy sports customer spot (Doc 701 #10919). Despite the lack of evidence showing that Hosseinipour withheld this information from anyone, the government misinterpreted the law, claiming that holding customer spots constituted the concealment of material facts (Doc 671 #7710).
Bonus Change Email
The government argued that Hosseinipour’s receipt of an email announcing a change in the bonus structure—claimed to be withheld from others was evidence of fraud. This is absurd. There was no evidence showing that this information was necessary for achieving a bonus or that it was beneficial. The “bait and switch” led to Hosseinipour losing $35,000, as Maike never paid the bonus. Additionally, there was no proof that Hosseinipour withheld this information. Anzalone stated that he was a networker and likely shared the information (Doc 504 4485 4486). Learning about a change in an MLM sales bonus does not constitute fraud. For a material omission to be proven, it must be connected to a specific statement. See Doc 671 #7710, #7712.
Get Paid to Play Tagline- “The Whole I2G Plan”
The government accused Hosseinipour of fraud for using the tagline “Get Paid to Play,” which was included in every distributor PowerPoint presentation. However, this tagline refers to the i2G compensation plan, which generates commissions based on “customer usage” or “play” of the casino, fantasy sports, and social casino games. The government presented overwhelming evidence that tied product usage to distributor pay including exhibits 101B, 101C, 145, and 158, as well as testimonies from Reynolds, Keep, and Anzalone. This evidence connected I2G business volume to 2200 casino and 2200 fantasy sports transactions which were payable as commissions. (155 20:35-22:35) Both Glen Logan and Catrina Dugger confirmed that their commissions were tied to customer usage. (Doc 701 10920,24, Doc 690 9466-71)
Q. And can you make — can you make money doing fantasy
Sports? A. You can, and I did. (doc 690 9467 9487, 9499, 9500 9502)
Q. And was there — were there ways through the pay plan or
the system for you to earn income by the people
participating in the Fantasy Sports programs?
A. Yes. We earned business volume on our own personal play as
well as downline and customers. (doc 701-10924)
Dugger: “The product that I really, really played
was the fantasy sports.” (doc 690 #9487) A. — playing it because you have to — there’s an entry, you know, when — there’s an entry fee when you’re buying your players or whatever, so I — I can only say that or the tokens on the G1E Boardwalk. You purchase tokens there. Doc 690 #9499 #690 9500 A. Yeah. If you have — if you get customers playing, like — you know, the way the fantasy sports would work is that you would send a link out — you know, they say, “Oh, I want to play.” You would send a link to them. They’re playing. Whatever their bet is
is going to be their customer, so now whatever percentage of their play is going to roll to you.Q. Okay. This is the customer question I have for you,
ma’am. Did you get paid commissions on bringing customers in?
A. You — I do believe you did get — because you get paid a
percentage of their play. That was the — that was the —
Q. But that wouldn’t be commissions, correct?
A. No. That was — no. That would be — well, what do you
mean — that wouldn’t be commissions. That would be —
Q. Okay. When I looked at the pay structure —
A. Uh-huh. I can’t remember the pay structure —
Q. It’s fine.
A. Okay.
Q. Just trying to clarify. When you look at the play
structure, you — I realize you get paid for customers coming
in, but did you get a certain commission for bringing a
customer in?
A. I don’t think you received a commission for bringing a
customer in. It’s when the customer played, that’s where you
would receive a percentage of what they used to play. So it
wasn’t like, oh, I — you know, $10 a customer. I don’t
recall.
Q. Right. That was important to you even though you didn’t
receive from the normal pay to bring these customers in for
what purpose?
Dugger. “Because you want them to play so you can get a percentage
of the money that they play.
Q. Gotcha. So you —
A. You get paid when they play.
Sales are up email.
“Sales are way up. People are over the moon excited. The new products with Fantasy Football are creating hundreds of new customers and thousands of people using it. It’s the biggest and easiest thing that has ever come to MLM. You are missing out big time. Real customer,
very streamlined, great odds, and paying on every game played,
win, lose, or draw.”
The government used a truthful statement to a non-witness email as evidence of fraud. Anzalone confirmed the truthfulness of Hosseinipour’s statements. Both Logan and Dugger also affirm the accuracy of these statements and expressed excitement about fantasy sports (Doc 505, pp. 4589, 4590; Doc 690, pp. 9500, 9501, 9468).
They noted, “After the acquisition of FantasySports, the volume was increasing” (Doc 701, p. 10909).
Hosseinipour attempted to present video evidence showing the increase in excitement and customer sales following the introduction of fantasy sports. However, her counsel, Manning, struggled to articulate its relevance to the Court. Barne’s attorney clarified that the video’s purpose was to demonstrate product usage. The Court permitted the evidence to be presented; however, Manning repeatedly failed to showcase Hosseinipour’s video evidence. (doc 701 #10938-42)
On July 26, 2022, the court permitted several hearsay emails to be introduced as evidence. However, these emails could not be used to establish the “truth of the matter.” Despite this ruling, 30 days later, the court declined to provide a further limiting instruction. As a result, the prosecution was allowed to present improper and prejudicial hearsay, as well as facts not in evidence, as if they were the “truth of the matter” regarding the critical question of whether i2G was a pyramid scheme. The prosecution’s actions should be assessed for possible abuse of discretion.
7707 Volume 24, Page 30
Ferrari email
The government presented an email with suggestions to improve the website as evidence of fraud. Hosseinipour’s response demonstrated her efforts to address his concerns. (Doc 504 #4470,71)
Maike responded that they could address some of the issues. Anzalone stated the issues were resolved when Koerner came on board. (Doc 504 #5771,72) Forwards to Koerner to ensure everything was legal (#4436, 37) “I had full belief and trust in this company and Rick and the people running it….I wanted them to be aware (4436, 37)
Ferrari was featured in a government video just two days before the email was sent, where he praised the I2G Touch product as a great and technologically advanced platform. He also commended Rick Maike for his integrity, mentioning a lengthy phone conversation they had, and stated, “Maike has all his ducks in a row.” Additionally, Ferrari appeared in the Syn Beast video, which was presented as evidence on the same day he sent his email. Unfortunately, none of this was shown to the jury because Hosseinipour’s counsel was unable to operate the equipment. The government was aware that presenting the email would have manipulated the jury with hearsay that could not be challenged.
Syn Beast Video – Just Simple No Secret You Have to Work (151 11:30 13:35, 48:44,55:55)
11:30-12:36 Common things we have in common- Very simple- Just
we are working like hell, 24 hours a day, like I am thinking we are working
24 hours a day, while I’m sleeping, I’m thinking of, like tomorrow I have
to do something, and I have to see someone. I have to travel.
Wherever my downline needs me, I have to go. I go to Korea, Japan,
Hawaii, New York, Las Vegas, wherever they need me, I go to help
them
12:50- This is not a selling job, This is a people relationship job
13:35 I work hard, that’s it. It’s just simple, no secret. You have to
work like hell
The claim that Hosseinipour promoted passive income by hosting the “Beast Video” is based on a brief two-second statement by Syn, which suggested that one could earn income in the future even while on an island. However, this remark is just a small part of the 1.5-hour video, during which the emphasis was placed on the importance of hard work. Throughout the video, Hosseinipour consistently highlighted the value of hard work and included income disclaimers. Additionally, Syn pointed out that after selling the 5,000 emperor packages, the primary focus shifted to directing customers to the casino, and no one had to sell “packages.” (151 41;51-44:45) He pointed out this was where the future of the company lay.
The Government claims that representing a truthful’ Get Paid to Play” as the I2G was a fraudulent claim when it was well documented that distributors earned 25% of casino and fantasy sports play. 101C 101B 145 Doc 690 9500, 9501, 9468. Doc701 10844, 45, 10909, 10918 Doc 701 #10909
The government suggested that some distributors had viewed Hosseinipour’s videos. Evidence showed that every distributor who purchased an emperor package was influenced by the representations made by their sponsors. No one claimed that Hosseinipour misrepresented any of the content. Sieb stated that she watched Hosseinipour’s videos after joining through her direct sponsor, Chris Lamont (R.683: #8704, #8706, #8737).
Fredericks was introduced to I2G and was sponsored by Breakiron (doc 683 #8753), whom he met while prospecting for MLM (multi-level marketing) opportunity seekers (R-683 8782-8786).
Aiello saw Hosseinipour’s video after he saw his sponsor’s video. (673 6720 6783) He stated “he couldn’t remember” over 20 times (Doc 673 6720, 22, 29, 30, 31, 59), including the content of Hosseinipour’s video, “It was so long ago.”(Doc 673 6786)
Vougeot said she was influenced by her sponsors, Lena and Steve West, and didn’t recall speaking with Hosseinipour. (Doc 669 6927-29)
The government claimed that Hosseinipour stated that Songstagram was backed by major companies and celebrities, a claim that was widely reported by Maike and Wright. At the launch event for Songstagram, recordings were presented as evidence, showing Wright announcing the involvement of various celebrities. In its closing remarks, the government had to concede that there was no proof that Hosseinipour disbelieved these announcements. However, they argued that she acted irresponsibly by repeating the information without proper due diligence.
The government contended that Hosseinipour participated in promotional “check flashing,” despite Anzalone discussing his concerns with her (R.504: #4453-4456, 4489-4490). Although Anzalone believed he had voiced his concerns, he later clarified that he considered the “check recognition events” to be a positive situation. He trusted that Rick had a capable legal team, stating, “I figured it was legal” (Doc 504 #4454-56). Anzalone confirmed that the “recognition checks” he received alongside Hosseinipour were accurate (Doc 504 #4453, 4510). In contrast, an Asian check he received on his own was disputed due to an unpaid bonus (Doc 504 #4454, Doc 505 4711-12, Doc 504 #4490). The disputed check was not presented as evidence.
The prosecution misled the jury with statements of “we” to infer Anzalone meant Hosseinipour when he referred to Maike or the company instead. ( doc 504 4449-51) For example, Anzalone admitted, “We did flash checks in Asia” (504 4447), referring to Maike or other distributors in Asia. Hosseinipour was never in Asia and never posed with the referenced check which Anzalone stated he destroyed and never brought home from Asia. Anzalone claimed all domestic checks he received with Hosseinipour were accurate. (505 47104715)
Anzalone stated that Hosseinipour believed in the company, the products, and Maike and wanted to fight false claims “outside of our control” with positive information (doc 504 4397, 98). Lack of Intent to conspire is proven by Hosseinipour forwards to Koerner at i2g@compliance.com as the in-house compliance attorney and Maike with Anzalone’s affirmation that she wanted issues to be addressed(504 #4384,85 #4438 Doc 505 4589, 4561Doc 505 4565, 4573, 74, 75)
Sewell asked Catrina Dugger seven completely improper questions, implying that Hosseinipour was aware of the casino profits. For example, he asked, “If Faraday knew that the casino profits were negligible, would you have expected her to inform you before you invested $5,000 in this?” (Doc 690 9518-9521). This question was inappropriate because there was no evidence to suggest that Hosseinipour had any knowledge of the casino profits.
During Anzalone’s direct examination, he was repeatedly asked, “You and Faraday, or Faraday and you?” The government mischaracterized Anzalone’s opinions to suggest something about Hosseinipour’s “state of mind.” However, Anzalone consistently emphasized that he and Hosseinipour never believed they were doing anything wrong; they trusted i2G’s attorneys to address any issues. He also stated that Hosseinipour would not lie, mislead, or deceive anyone and that she had confidence in the product. Anzalone praised Faraday, describing her as an honest, kind, and intelligent person who was motivated to help others.
The government instructed the jury that Hosseinipour’s crime was simply “staying with the company,” even though all distributors remained. The evidence against Hosseinipour consisted of innocent and lawful actions that were misrepresented as fraudulent.