Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 1 of 33 Page ID #:1
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`2301 Rosecrans Avenue, Suite 3180, El Segundo, CA 90245
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`RYAN D. SABA, ESQ. (State Bar No. 192370)
`rsaba@rosensaba.com
`MICHAEL FORMAN, ESQ. (State Bar No. 260224)
`mforman@rosensaba.com
`2301 Rosecrans Ave, Suite 3180
`El Segundo, CA 90245
`Telephone:
`(310) 285-1727
`Facsimile:
`(310) 285-1728
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`Attorneys for Plaintiff,
`S.S.L INVESTMENTS, LLC
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`UNITED STATES DISTRICT COURT
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`CENTRAL DISTRICT OF CALIFORNIA
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`S.S.L INVESTMENTS, LLC, a
`California limited liability company,
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`Plaintiff,
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`v.
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`ASHA OROSKAR, an individual;
`ANIL OROSKAR, an individual;
`PRIYANKA SHARMA, an individual;
`PULAK SHARMA, an individual;
`GREGORY ROCKLIN, an individual;
`OROCHEM TECHNOLOGIES, INC.,
`an Illinois corporation; KAZMIRA,
`LLC; a Delaware limited liability
`company; and DOES 1 through 10,
`inclusive,
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`
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`Defendants.
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`Case No.:
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`COMPLAINT FOR DAMAGES
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`1. RICO (18 U.S.C. §1962(c))
`2. Conspiracy to Violate RICO
`(18 U.S.C. §1962(d))
`3. Fraud (Intentional
`Misrepresentation)
`4. Fraudulent Concealment
`5. Unlawful Business Practices (Cal.
`Bus. & Prof. Code §§ 17200 et seq.)
`6. False Advertising (Cal. Bus. &
`Prof. Code §§ 17500 et seq.)
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`JURY TRIAL DEMANDED
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`COMPLAINT
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 2 of 33 Page ID #:2
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`TO THIS HONORABLE COURT AND ALL INTERESTED PARTIES:
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`Plaintiff S.S.L INVESTMENTS, LLC (“SSL”) alleges the following claims
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`against Defendants ASHA OROSKAR; ANIL OROSKAR; PRIYANKA SHARMA;
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`PULAK SHARMA; GREGORY ROCKLIN; OROCHEM TECHNOLOGIES, INC.;
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`and KAZMIRA, LLC (collectively “Defendants”) as follows:
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`THE PARTIES
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`1.
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`Plaintiff S.S.L INVESTMENTS, LLC is a California limited liability
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`company. During the relevant time period, SSL’s principal place of business was
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`located at 9419 Mason Avenue, Chatsworth, California 91311. SSL’s current address
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`is 10700 San Monica Blvd, Suite 203, Los Angeles, CA 90025. SSL is and was
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`member managed by Michael Yedidsion, Pedram Salimpour, H. Troy Farahmand,
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`and Bob Kashani, each of whom are domiciled in California.
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`2.
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`Defendant OROCHEM TECHNOLOGIES, INC. (“Orochem”) is a
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`corporation organized under the laws of Illinois with its principal place of business
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`at 340 Shuman Boulevard, Naperville, Illinois 60563. Orochem represents that it is
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`a “leading provider for specialty purification technologies” and “a global expert in
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`chromatography, including Simulated Moving Bed (“SMB”) chromatography.” On
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`information and belief, Orochem is a private company that is wholly owned by Asha
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`Oroskar and Anil Oroskar.
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`3.
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`Defendant ASHA OROSKAR is an individual who is domiciled in
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`Naperville, Illinois. At all relevant times, she was the principal, President, and Chief
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`Executive Officer of Orochem.
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`4.
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`Defendant ANIL OROSKAR is an individual who is domiciled in
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`Naperville, Illinois. At all relevant times, he was the principal and Chief Technology
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`Officer of Orochem.
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`5.
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`Plaintiff KAZMIRA, LLC (“Kazmira”) is currently a Delaware limited
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`liability company with its principal place of business at 34501 E. Quincy Ave.,
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`COMPLAINT
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 3 of 33 Page ID #:3
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`Building 35, Watkins, Colorado, 80137. In January 2017, Kazmira was formed by
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`Anil Oroskar, Asha Oroskar, and Orochem as a Colorado limited liability company
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`with its principal place of business is located at 34501 E. Quincy Ave., Building 35,
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`Watkins, Colorado 80137. In May 2020, Kazmira registered as a Delaware limited
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`liability company. On information and belief, Kazmira is a private company that is
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`owned by Asha Oroskar and Anil Oroskar, and is a subsidiary, partner, and/or
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`licensee of Orochem. Kazmira uses Orochem’s chromatography equipment to make
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`cannabidiol oil that is derived from hemp. Kazmira’s co-Chief Executive Officers
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`are Defendants Priyanka Sharma and Pulak Sharma, who are the children of Asha
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`Oroskar and Anil Oroskar. The land on which Kazmira’s facility is located is owned
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`by APPoGee Kazmira, LLC, a real estate holding company with the sole purpose of
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`holding title to the property. The only members of APPoGee Kazmira, LLC are Asha
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`Oroskar and Anil Oroskar.
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`6.
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`Defendant PRIYANKA SHARMA is an individual who is domiciled in
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`Denver, Colorado. Mrs. Sharma is the daughter of Defendants Anil Oroskar and
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`Asha Oroskar, and the wife of Defendant Pulka Sharma. At all relevant times, she
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`was the co-CEO of Kazmira.
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`7.
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`Defendant PULAK SHARMA is an individual who is domiciled in
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`Denver, Colorado. Mr. Sharma is the son-in law of Defendants Anil Oroskar and
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`Asha Oroskar, and the husband of Defendant Priyanka Sharma. At all relevant times,
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`he was the co-CEO of Kazmira.
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`8.
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`Defendant GREGORY ROCKLIN is an individual who is domiciled in
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`Atherton, California. At all relevant times, he was the business development agent
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`for Defendants Asha Oroskar, Anil Oroskar, Priyanka Sharma, Pulak Sharma,
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`Orochem, and Kazmira.
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`9.
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`The true names and capacities, whether individual, corporate, associate,
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`or otherwise, of the defendants named herein as DOES 1 to 10, are unknown to
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`Plaintiff at this time and therefore said defendants are being sued by such fictitious
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`2
`COMPLAINT
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 4 of 33 Page ID #:4
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`proximately caused damage to Plaintiff, either through their own conduct or the
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`conduct of their agents, servants, or employees, or due to their ownership,
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`supervision, and/or management of the employees, agents, entities, and/or
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`instrumentalities that caused said damages, or in some other manner or means that is
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`presently unknown to Plaintiff. Plaintiff will hereafter seek leave of the Court to
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`amend this Complaint to show the fictitiously sued defendants’ true names and
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`capacities, after the same have been ascertained.
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`10. At all times mentioned herein, each of the Defendants was the agent,
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`principal, partner, alter-ego,
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`joint venturer, employee, and/or authorized
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`representative of every other Defendant and, in doing the things hereinafter alleged,
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`was acting within the course and scope of such agency, service, and representation
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`and directed, aided and abetted, authorized, and/or ratified each and every act and
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`conduct hereinafter alleged.
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`11. Plaintiff is informed and believes, and based thereon alleges, that the
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`business affairs of Orochem, Asha Oroskar and Anil Oroskar are, and at all times
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`relevant were, so mixed and intermingled that they cannot reasonably be segregated,
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`and are in inextricable confusion such that a unity of interest and ownership existed,
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`including the comingling of assets and the use of Asha Oroskar and Anil Oroskar
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`personal telephone, cellular phone, computers, computer software, portable
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`electronic devices, email accounts, bank accounts, and other personal devices and/or
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`accounts in carrying out the actions alleged herein as and/or on behalf of Orochem.
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`Orochem is, and at all times relevant hereto was, used by Defendants Asha Oroskar
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`and Anil Oroskar as a shell and conduit for the conduct of certain of their affairs and
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`is, and was, the alter ego of Defendants Anil Oroskar and Asha Oroskar. The
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`3
`COMPLAINT
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`names. The full extent of the facts linking such fictitiously sued Defendants is
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`unknown to Plaintiff. Plaintiff is informed and believes and based thereon allege that
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`each of the defendants designated herein as a DOE was, and is legally responsible in
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`some manner or means for the events and happenings referred to herein and
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 5 of 33 Page ID #:5
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`recognition of the separate existence of Orochem would be unfair and would not
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`promote justice, in that it would permit Asha Oroskar and Anil Oroskar to wrongfully
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`insulate themselves from liability to Plaintiff. Accordingly, Defendant Orochem
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`constitutes the alter ego of Asha Oroskar and Anil Oroskar, and the fiction of its
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`separate existence should be disregarded.
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`12. Plaintiff is informed and believes, and based thereon alleges, that the
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`business affairs of Kazmira, Orochem, Anil Oroskar, Asha Oroskar, Priyanka
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`Sharma, and Pulak Sharma are, and at all times relevant were, so mixed and
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`intermingled that they cannot reasonably be segregated, and are in inextricable
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`confusion such that a unity of interest and ownership existed, including the
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`comingling of assets and the use of Orochem, Anil Oroskar, Asha Oroskar, Priyanka
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`Sharma, Pulak Sharma’s personal telephone, cellular phone, computers, computer
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`software, portable electronic devices, email accounts, bank accounts, and other
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`personal devices and/or accounts in carrying out the actions alleged herein as and/or
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`on behalf of Kazmira. Kazmira is, and at all times relevant hereto was, used by
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`Defendants Orochem, Anil Oroskar, Asha Oroskar, Priyanka Sharma, Pulak Sharma
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`as a shell and conduit for the conduct of certain of their affairs and is, and was, the
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`alter ego of Defendants Orochem, Anil Oroskar, Asha Oroskar, Priyanka Sharma,
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`Pulak Sharma. The recognition of the separate existence of Kazmira would be unfair
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`and would not promote justice, in that it would permit Orochem, Anil Oroskar, Asha
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`Oroskar, Priyanka Sharma, Pulak Sharma to wrongfully insulate themselves from
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`liability to Plaintiff. Accordingly, Defendant Kazmira constitutes the alter ego of
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`Orochem, Anil Oroskar, Asha Oroskar, Priyanka Sharma, Pulak Sharma, and the
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`fiction of its separate existence should be disregarded.
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`JURISDICTION AND VENUE
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`13. The Court has jurisdiction over the subject matter of this action under
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`28 U.S.C. §§1331 and 1338 in that this action arises under the laws of the United
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`COMPLAINT
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 6 of 33 Page ID #:6
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`14. This Court has personal jurisdiction over all Defendants because they
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`conducted business with Plaintiff and committed wrongful acts and/or directed
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`wrongful acts toward and/or that were committed within the County of Los Angeles,
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`California giving rise to this Complaint. Defendants all traveled to Los Angeles,
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`California to meet with Plaintiff and induce Plaintiff to do business with them.
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`15. This Court also has personal jurisdiction over all Defendants pursuant
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`to 18 U.S.C.A. §1965(b) as Plaintiff alleges that Defendants Anil Oroskar, Asha
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`Oroskar, Priyanka Sharma, Pulak Sharma, and Gregory Rocklin conspired to commit
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`wrongful acts and tortious activities within the County of Los Angeles, California
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`including conspiring to violate RICO under 18 U.S.C. §1962(d)); one or more of the
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`Defendants is subject to personal jurisdiction in this Court; the ends of justice require
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`that other parties residing in any other district be brought before the court; and there
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`is no other district in which a court will have personal jurisdiction over all of the
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`alleged coconspirators.
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`16. The exercise of personal jurisdiction over Defendants is reasonable and
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`proper because, at the time pertinent to these allegations, Defendants transacted
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`business and derived substantial revenue from services rendered in the State of
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`California. Defendants
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`participated
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`in
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`transactions,
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`negotiations,
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`communications, and other activities within and/or targeted at California that give
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`rise to the claims in this Complaint. Moreover, Defendants have committed tortious
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`acts causing injury to Plaintiff in California.
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`17. Venue is proper in this District because a substantial part of the events
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`or omissions giving rise to this Complaint occurred, and a substantial part of property
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`that is the subject of the action is situated in this District.
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`States, specifically 18 U.S.C. §1962(c) (RICO) and 18 U.S.C. §1962(d) (Conspiracy
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`to violate RICO). The Court also has supplemental jurisdiction over Plaintiff’s state
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`and common law claims pursuant to 28 U.S.C. §1367, which form part of the same
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`case or controversy.
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 7 of 33 Page ID #:7
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`18. Tetrahydrocannabinol (“THC”) is the psychoactive compound present
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`in cannabis. Crude THC oil contains impurities such as pesticides, heavy metals,
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`color components, and sugars. California law requires that THC oil be processed to
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`FACTUAL ALLEGATIONS
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`the point that it only contains trace amounts of impurities. See e.g., Cal. Code Regs.
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`tit. 16, §§ 5714 et seq. The key requirement to producing a marketable supply of
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`THC oil is retaining 90% THC concentration.
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`19. Plaintiff was engaged in the processing and wholesale distribution of
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`THC oil for Original Balboa Caregivers, an entity licensed by the State of California
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`to conduct business in the cannabis industry. Plaintiff managed and operated
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`Original Balboa Caregivers’ 100,000 square-foot production facility at 9419 Mason
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`Avenue, Chatsworth, California. Before entering into a business relationship with
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`Defendants, Plaintiff used the processes of flash chromatography and molecular
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`distillation to process the product.
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`20. Defendants held themselves out as biotechnology organization that
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`utilized patented column chromatography and SMB chromatography systems to
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`purify and concentrate biopharmaceutical, chemical, and food products. Defendants
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`represented that they designed, constructed, and installed multiple commercial scale
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`column chromatography and SMB chromatography systems, including in India,
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`Peru, and at Kazmira’s facility in Colorado.
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`21. Column chromatography is a technique used to separate the components
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`of mixtures, such as crude THC oil. The basic process of column chromatography is
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`as follows: In the mobile phase, crude THC oil is mixed with a fluid that carries it
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`through a large column, which contains a different material called the “stationary”
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`phase. The components of the mobile phase travel through the stationary phase at
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`different speeds, causing the components to separate. Simulated Moving Bed
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`chromatography (“SMB”) uses a similar process. In SMB chromatography, the
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`mobile phase travels in a continuous loop through multiple smaller columns, moving
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`6
`COMPLAINT
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 8 of 33 Page ID #:8
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`countercurrent to a constant flow of solid (stationary phase). The countercurrent flow
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`enhances the potential for the separation and makes the process more efficient.
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`22.
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`In May 2018, Plaintiff was approached by Gregory Rocklin, the
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`business development agent for Asha Oroskar, Anil Oroskar, Priyanka Sharma, and
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`Pulak Sharma, Orochem, and Kazmira. Mr. Rocklin represented that that
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`Defendants’ proprietary technology would upgrade Plaintiff’s existing process and
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`provide solvent-free, “full spectrum” THC oil in commercially viable quantities.
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`23. On May 7, 2018, Gregory Rocklin sent an email to Plaintiff touting
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`Defendants’ Stevia One facility in Peru, “where we recently designed, built and
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`started up a new operation for extraction of Stevia.” Mr. Rocklin gave a slide deck
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`to Plaintiff containing photographs of Defendants’ facility in Peru and said the
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`pictures showed a fully operational, commercial-scale SMB facility. This was
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`significant because the production process Defendants were pitching to Plaintiff is
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`substantially similar to the way Stevia is produced, where leaves of the stevia plant
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`are processed into crude oil and then purified to remove contaminants.
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`24. Each of the Defendants represented they had a fully operational
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`production process for the production of full spectrum cannabidiol oil (“CBD”) oil
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`at their facility in Colorado, which is substantially similar to the THC oil purification
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`process Defendants were pitching to Plaintiff. Defendants operated the Colorado
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`facility under the banner of their subsidiary/partner, Kazmira. Asha Oroskar and Anil
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`Oroskar installed their daughter (Priyanka Sharma) and her husband (Pulak Sharma)
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`as chief executives of Kazmira to give the appearance that Kazmira was not
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`controlled by Asha Oroskar and Anil Oroskar. Gregory Rocklin represented to
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`Plaintiff that Kazmira was “currently processing about 150-200kg of THC-free oil
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`and isolate in total per month with revenue reaching about $2 Million per month in
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`December. The business is profitable.”
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`25. On May 17, 2018, Pulak Sharma traveled to Los Angeles County,
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`California on behalf of Defendants and visited the offices of one of Plaintiff’s
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`7
`COMPLAINT
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 9 of 33 Page ID #:9
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`Kazmira facility regarding CBD oil, meaning that Defendants represented they could
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`purify commercial quantities of crude THC oil to a minimum of 90% THC
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`concentration with non-detectable levels of pesticides, heavy metals, color,
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`phospholipids, neutral lipids, color components, solvents, or sugars, as required by
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`Cal. Code Regs. tit. 16, §§ 5000, et seq. and Cal. Code Regs. tit. 17, §§ 40200 et seq.
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`(“California Specifications”). Pulak Sharma was used as a prop by his in-laws, Asha
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`Oroskar, and Anil Oroskar, to sell Plaintiff on the notion that Defendants’ technology
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`was fully developed and capable of performing as represented.
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`26.
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` Gregory Rocklin gave a slide deck to Plaintiff touting Defendants’
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`success with Kazmira. The deck stated: “Orochem’s journey to improve the quality
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`and lower the cost of Cannabinoid products began in 2016 with the formation of
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`Kazmira, LLC… Orochem Technologies developed a chromatographic method to
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`produce CBD from Industrial Hemp, which completely removes THC and enables
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`ton-level production of CBD and other high-value products. Orochem has
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`exclusively licensed this technology to Kazmira.” The deck also identified Mr.
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`Rocklin as Kazmira’s corporate development representative and a member of
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`Kazmira’s “management team.”
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`27. On June 13, 2018, Anil Oroskar and Gregory Rocklin traveled to Los
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`Angeles County, California on behalf of Defendants and met with Plaintiff’s
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`principals at their Chatsworth facility. Anil Oroskar and Gregory Rocklin toured the
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`facility and touted Defendants’ ability to purify commercial quantities of THC oil
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`from cannabis trim, cannabis crude oil, as well as from cannabis oil that was left over
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`from other production processes, as demonstrated by Defendants’ success with
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`Kazmira and Stevia One. They represented that Defendants would use their expertise
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`8
`COMPLAINT
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`principals, H. Troy Farahmand. Pulak Sharma boasted about Defendants’
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`technology, Kazmira facility in Colorado, and active accounts. He represented that
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`Defendants could achieve the same results regarding THC oil as were achieved at the
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 10 of 33 Page ID #:10
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`to install and operate column chromatography and SMB systems, and recommended
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`certain changes to the facility such as upgraded electrical output capability.
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`28.
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`In subsequent oral and written communications, Anil Oroskar and
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`Gregory Rocklin continued to assure Plaintiff that the output of Defendants’
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`processes would be finished oil containing THC purity levels of 90% or above, while
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`retaining all other cannabinoids present in the raw material. They also continued to
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`assure Plaintiff that such results would be achieved with no more than a 5% loss in
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`total mass of the raw material, and that Plaintiff would make a significant profit. This
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`was significant because loss of any more than 5% of mass during post-production
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`would impair profitability. For example, on June 18, 2018, Anil Oroskar represented
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`that Defendants “…can work with low quality feedstocks as well. So if the whole
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`plant is cheaper then we should focus on that.” On July 20, 2018, Mr. Rocklin
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`represented that Defendants could provide “…not only an increase in margins due to
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`increase in yields and lower cost of manufacturing, but additional revenue streams
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`due to our ability to meet and greatly exceed the California specifications.”
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`29.
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`In July 2018, Defendants began proof-of-concept work to demonstrate
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`that its chromatography technology could be used to separate impurities from a small
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`sample of contaminated cannabis oil (“small batch test”).
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`30. On July 17, 2018, Priyanka Sharma, Pulak Sharma, and Gregory
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`Rocklin traveled to Los Angeles County, California on behalf of Defendants and
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`visited Plaintiff’s facility. Priyanka Sharma, Pulak Sharma, and Gregory Rocklin
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`touted Defendants’ technology and its effectiveness at the Kazmira facility in
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`Colorado. Priyanka Sharma and Pulak Sharma talked about their personal experience
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`at the Kazmira facility and represented that Defendants would produce the same
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`results for Plaintiff, including THC purity levels of 90% while retaining all other
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`cannabinoids present in the raw material, losing no more than 5% of the total mass
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`of the raw material. Priyanka Sharma and Pulak Sharma were used was used as props
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`by Defendants, including their parents Asha Oroskar and Anil Oroskar, to sell
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`9
`COMPLAINT
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`Plaintiff on the notion that Defendants’ technology was fully developed and capable
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`of performing as represented by Defendants.
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 11 of 33 Page ID #:11
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`31. On July 26, 2018, Mr. Salimpour traveled to Illinois on behalf of
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`Plaintiff to meet with Defendants. Gregory Rocklin also traveled from California to
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`Illinois and attended the meetings. Mr. Salimpour was given a presentation about
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`Orochem and Kazmira’s capabilities, as well as a tour of Orochem’s facility in
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`Illinois by Asha Oroskar and Anil Oroskar. He was also presented with the small
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`batch test results which purported to show that Defendants successfully eliminated
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`pesticides and other contaminants from the oil. Asha Oroskar and Anil Oroskar
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`assured Mr. Salimpour that Defendants could produce the same results on a
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`commercial scale using their column chromatography and SMB chromatography
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`systems. Asha Oroskar spoke to Mr. Salimpour about her vast experience in science
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`and showed him a section of Defendants’ facility that could produce gel caps for use
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`in the production of soft get capsules. She represented that the Defendants’ existing,
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`“patented water-soluble technology” could be used in Plaintiff’s facility to make
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`beverages infused with cannabinoids such as THC and CBD. This was significant
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`because it was highly desirable to add soft get capsules and cannabis infused drinks
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`to a cannabis product line. However, Defendants never brought their soft-gel
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`manufacturing equipment or “patented water-soluble technology” to Plaintiff’s
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`facility. Defendants just dangled this and other business opportunities in front of
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`Plaintiff as part of their confidence game.
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`32. Unbeknownst to Plaintiff, Defendants were misrepresenting their
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`capabilities and track record. The true state of affairs was that Defendants’
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`“proprietary technology” was not fully developed and Defendants’ actual intent in
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`associating with Plaintiff was to conduct research and development at Plaintiff’s
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`facility and at Plaintiff’s expense, and then abandon Plaintiff and use the fully
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`developed technology for their own purposes. When Defendants made their
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`representations to Plaintiff, Defendants knew they could not purify THC oil to the
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`10
`COMPLAINT
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 12 of 33 Page ID #:12
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`unit was not commercial-grade and would never actually be delivered because it
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`could not function as promised.
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`33. This is the same scam that Defendants committed on another company,
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`Arjuna Natural Extracts (“Arjuna”), a foreign corporation with is principal place of
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`business in India. In 2015, Defendants represented to Arjuna that their SMB
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`chromatography machines could purify commercial quantities of omega-3 oils to
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`90% purity. Based on Defendants’ representations, Arjuna contracted with
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`Defendants to provide, install, and supervise operation of a commercial grade SMB
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`unit. After Arjuna spent millions of dollars to purchase Defendants’ equipment, built
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`a new factory and purchased raw materials, Defendants installed a SMB unit at
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`Arjuna’s facility. However, it failed to purify the oil to Arjuna’s specifications.
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`Then, Defendants spent months, and millions of dollars of Arjuna’s money in an
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`unsuccessful attempt to fix the process, but all Defendants ended up doing was
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`continuing to test their nonfunctional equipment at Arjuna’s facility and at Arjuna’s
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`expense. Ultimately, however, the SMB unit was nonfunctional and unusable for the
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`purposes of purifying omega-3 oil. Arjuna discovered that Defendants did not deliver
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`the commercial grade SMB unit they promised, but rather had delivered a “pilot”
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`SMB unit with unproven functionality. Defendants refused to refund any of Arjuna’s
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`money. Arjuna sued Orochem in the United States District Court for the Northern
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`District of Illinois (Arjuna Natural Extracts v. Orochem Technologies, N.D.Ill. case
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`no. 20-1644) alleging claims for Fraud and Breach of Contract, and seeking $15
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`million in damages. The case settled in October 2020. Defendants never told
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`Plaintiff about the failed experiment with Arjuna.
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`34. On August 3, 2018, Anil Oroskar represented to all of Plaintiff’s
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`principals that “we are able to purify using our technology the black crude into a nice
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`11
`COMPLAINT
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`California Specifications. They knew that the column chromatography would not
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`function as promised, as it was incapable of refining the oil to 90% purity without
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`significant losses in mass during processing. Defendants also knew that the SMB
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`looking high purity THC oil (without pesticides). We can set this system up in your
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`facility in August.”
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 13 of 33 Page ID #:13
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`35. On August 8, 2018, Priyanka Sharma, Asha Oroskar, Anil Oroskar, and
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`Gregory Rocklin traveled to Los Angeles County, California and toured Plaintiff’s
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`facility in Chatsworth. Once again, each of them made representations about the
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`ability of Defendants’ technology to process commercial quantities of THC oil to the
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`California Specifications. Priyanka Sharma talked specifically about her personal
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`knowledge of how well Defendants’ processes worked at the Kazmira facility, which
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`gave credence to Defendants’ representations that their processes would work just as
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`well for Plaintiff. Priyanka Sharma was used as a prop by Defendants to “seal the
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`deal.”
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`36.
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`In the days following the August 8, 2018 meeting, Gregory Rocklin and
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`Anil Oroskar increased the aggressiveness of their representations. On August 8,
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`2018, Mr. Rocklin represented to Plaintiff: “We have proven that we can meet the
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`required California Specifications and thereby set precedent in the state, if not the
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`country. Moreover, we have proven time and time again that we can scale up to any
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`required volumes with appropriate capital, and improve economies at each level.”
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`On August 11, 2018, Mr. Rocklin represented to Plaintiff: “…Orochem can make a
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`substantial impact on yield and quality by implementing our cannabinoid-specific
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`process, and we are willing to structure the deal to guarantee it. As I’m sure you
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`understand, the greater yield will have a direct and immediate impact on your raw
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`material expense, cash flow and profitability.” (emphasis in original). On August 12,
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`2018, Anil Oroskar represented that Defendants “have the technology to make SSL
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`the largest THC-Oil producer in California...perhaps the world.”
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`37.
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`In reliance on Defendants’ false representations and concealment of
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`material facts, Plaintiff entered into a business venture with Defendants whereby
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`Plaintiff would supply the facilities and raw materials and capital, and Defendants
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`would install and operate their column chromatography and SMB chromatography
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`12
`COMPLAINT
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`machines to create 90% pure THC oil with no impurities in accordance with the
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`California Specifications. Defendants would own all manufacturing-related
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`Case 2:22-cv-02953-PVC Document 1 Filed 05/03/22 Page 14 of 33 Page ID #:14
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`intellectual property developed during the course of the parties’ engagement.
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`Defendants would also receive 20% of the profits from the sale of products produced.
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`Anil Oroskar wrote an email to Plaintiff, Asha Oroskar, Priyanka Sharma, Pulak
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`Sharma, and Gregory Rocklin congratulating everyone on the business venture.
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`38.
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`In November 2018, Defendants installed their equipment in Plaintiff’s
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`facility, which would be operated by Defendants’ technicians. Significantly,
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`Defendants installed large column chromatography units but did not install SMB
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`chromatography units. Defendants promised that the column chromatography units
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`could produce THC oil that met the required specifications and that the SMB unit
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`could be installed at a later time. However, delivering the SMB at a later time was
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`not part of the deal. Ultimately, Defendants refused to deliver the SMB unless
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`Plaintiff paid extra for it, and the SMB was never delivered.
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`39.
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`In reliance on Defendants’ representations, Plaintiff sp