IN THE COURT OF CHANCERY OF THE STATE OF DELAWARE
`
`v.
`MOHAMED AZAB YOUSSEF,
`
`Defendant/
`Counterclaim-Plaintiff,
`
`and
`
`JUDE CHIDI OGENE,
`Defendant,
`
`and
`
`
` ARTUR SCHABACK, individually on )
`
`behalf of himself, and derivatively on )
`behalf of Paxful Holdings, Inc.,
`)
`)
`Plaintiff/
`)
`Counterclaim-Defendant,
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`)
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`
`C.A. No. 2023-0026-PAF
`PUBLIC VERSION
`FILED MARCH 31, 2023
`
`PAXFUL HOLDINGS, INC.,
`
`Nominal Defendant/
`Nominal Counterclaim-
`Defendant.
`
`SUPPLEMENTAL UNSWORN DECLARATION OF ARTUR SCHABACK
`IN SUPPORT OF HIS CROSS-MOTION FOR SUMMARY JUDGMENT
`
`Pursuant to 10 Del. C. § 5356, et. seq. (the Delaware Uniform Unsworn
`
`Foreign Declarations Act), I, Artur Schaback, declare under penalty of perjury under
`
`the laws of the State of Delaware as follows:
`1
`
`EFiled: Mar 31 2023 03:48PM EDT
`Transaction ID 69708558
`Case No. 2023-0026-PAF
`
`
`
`v.
`MOHAMED AZAB YOUSSEF,
`
`Defendant/
`Counterclaim-Plaintiff,
`
`and
`
`JUDE CHIDI OGENE,
`Defendant,
`
`and
`
`
` ARTUR SCHABACK, individually on )
`
`behalf of himself, and derivatively on )
`behalf of Paxful Holdings, Inc.,
`)
`)
`Plaintiff/
`)
`Counterclaim-Defendant,
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`C.A. No. 2023-0026-PAF
`PUBLIC VERSION
`FILED MARCH 31, 2023
`
`PAXFUL HOLDINGS, INC.,
`
`Nominal Defendant/
`Nominal Counterclaim-
`Defendant.
`
`SUPPLEMENTAL UNSWORN DECLARATION OF ARTUR SCHABACK
`IN SUPPORT OF HIS CROSS-MOTION FOR SUMMARY JUDGMENT
`
`Pursuant to 10 Del. C. § 5356, et. seq. (the Delaware Uniform Unsworn
`
`Foreign Declarations Act), I, Artur Schaback, declare under penalty of perjury under
`
`the laws of the State of Delaware as follows:
`1
`
`EFiled: Mar 31 2023 03:48PM EDT
`Transaction ID 69708558
`Case No. 2023-0026-PAF
`
`
`
`1.
`
`I hereby submit this Supplemental Sworn Declaration under penalty of
`
`perjury in support of my Cross-Motion for Summary Judgment on (i) Count I of my
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`Supplemental and Amended Verified Complaint, which in pertinent part seeks the
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`appointment of a custodian under Section 226(a)(2) of the Delaware General
`
`Corporation Law; and (ii) Count III of Mr. Youssef’s Counterclaims, which seeks
`
`
`
`
`
`2.
`
`This Supplemental Declaration addresses (i) certain of Youssef’s
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`misrepresentations in his March 20, 2023 Declaration,1 (ii) an update on my and my
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`counsel’s continued investigation into Youssef’s roughly
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` in fraudulent
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`tranfers to EMiR,2 Gemean, KALEM, and the like, (iii) recent developments in the
`
`last several days, including a push by Youssef for an
`
`
`
`, and (iv) the fact that the Company
`
`should be able to continue as a going-concern.
`
`
`1 Unsworn Declaration of Artur Schaback in Support of Cross-Motion for
`Summary Judgment [Trans. ID No. 69341799] (hereinafter “Schaback Dec.”).
`2 Capitalized terms not defined herein have the meaning set forth in the Shaback
`Dec.
`
`2
`
`
`
`
`
`
`
`
`Youssef’s Continued Misrepresentations
`
`
`3.
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`Throughout this action, Youssef has had a pattern of making material
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`misstatements of fact to the Court, including in statements sworn under penalty of
`
`perjury.
`
`4.
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`Prior examples of Youssef’s material misstatements include the
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`following, among others:
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`• In his January 25th declaration, Youssef stated that there was an audio
`
`recording of the November 23rd shareholder meeting.3 This statement was
`
`false. Both company counsel and Youssef’s counsel have stated that they do
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`not have a recording of this meeting. 4
`
`
`3 Youssef Jan. 25, 2023 Dec. (Trans. ID No. 68984739) ¶ 11 (“On November 23,
`2023 [sic], I called an informal shareholder meeting and explained the situation to
`the shareholders, all of whom, including plaintiff, were present. An audio recording
`is available for this informal shareholder meeting”).
`4 Ex. 1 (“The November 23 shareholder meeting was not recorded by the
`Company”) Ex. 2 (“Ray was mistaken when he previously stated that the November
`23, 2022 meeting of Paxful’s stockholders was recorded. Ray did not record and is
`not aware of anyone else recording the November 23, 2022 meeting of Paxful’s
`stockholders”).
`
`3
`
`
`
`
`
`
`
`
`• In his February 23rd declaration, Youssef said that Emir pays approximately
`
`80 programmers that are employed by Paxful.5 This was false. They are
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`contractors.6
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`• In his February 23rd declaration, Youssef said that
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`.7 This was false as Company counsel has said that
`
` 8
`
`
`
`
`
`
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`5.
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`Youssef also caused the Court to be provided with materially incorrect
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`information from the outset of this case. He and Ogene caused “the Company” (via
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`then-counsel at McDermott, Will & Emery LLP) to argue against a Status Quo Order
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`based on the false premise that Paxful was not
`
`. MWE pointed to the
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`alleged November 2022 closing of the
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` transaction, saying there was
`
`
`5 Youssef Feb. 23, 2023 Dec. (Trans. ID No. 69201166) ¶ 2 (“EMiR EKiPMAN
`iTHALAT iHRACAT TiCARET LiMiTED SiRKETi (“Emir”) is a Turkish
`company with which Paxful Holdings, Inc. (“Paxful” or the “Company”) contracted
`to pay approximately 80 programmers residing in Russia who are employed by
`Paxful”) (emphasis added).
`6 Motion for Approval of Payment (Trans. ID No. 69328207), Exs. 1-3.
`7 Youssef Feb. 23, 2023 Dec. ¶¶ 2–3 (“Paxful,
`, began paying its employees residing in Russia through Emir”).
`8 Schaback Dec. Ex. 20 at 4 (“With respect to whether Dentons ever represented
`Paxful, we do not believe Dentons has ever provided legal advice, written or
`otherwise, to Paxful”).
`
`
`
`4
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`
`
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`
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`“nothing [more] to enjoin.”9 MWE and Ogene represented that the Company would
`
`not
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`without a stockholder vote to approve
`
`, which they did not
`
`anticipate receiving.10 Seeking to benefit from their successful bad faith efforts to
`
`deprive me from obtaining Company information, MWE, Ogene and ultimately
`
`Youssef caused the Company to argue that I have “not alleged any other pending or
`
`imminent self-dealing transactions” and that my concerns were all “moot, theoretical
`
`or remediable by damages.”11 Youssef knew all such statements were materially
`
`misleading, and he intentionally failed to correct them. In fact, Youssef never
`
`stopped
`
` Paxful, and he still has not.
`
`6.
`
`Youssef’s latest Declaration similarly is rife with materially misleading
`
`statements. Several examples are discussed below.
`
`7.
`
`Youssef alleges falsely that “[p]rior to this action being filed, Schaback
`
`was provided any Company information he asked for.”12 In fact, my prior filings in
`
`
`9 Paxful Opposition to Motion for Status Quo Order (Trans. ID No. 68937743)
`¶ 3.
`10 Id. at ¶¶ 5-6; see also Ogene Jan. 19, 2023 Aff. In Support of Paxful Opposition
`to Motion for Status Quo Order (Trans. ID No. 68937743) ¶ 9.
`11 See Trans. 68937743 (Paxful Opp. to Mot. for Status Quo Order) at ¶¶ 6-7.
`12 Youssef Mar. 20, 2023 Dec. ¶ 17.
`
`5
`
`
`
`
`
`
`
`
`this action attach numerous pre-suit information requests that were ignored.13
`
`Additional written requests that were ignored are attached hereto.14
`
`8.
`
`As another example, regarding the
`
` transaction, Youssef
`
`states only as follows: “[a]fter obtaining expedited discovery into this claim in this
`
`action, which showed that Schaback’s allegations relating to the
`
` transaction
`
`were meritless, Schaback has now apparently abandoned that claim.”15 In fact, as I
`
`have explained, “discovery has only concerned and heightened my concerns
`
`regarding this transaction.”16 Among other things, the limited discovery provided
`
`showed (i) Youssef and the Company did not
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` at all, and did no due
`
`diligence of
`
` which actually does not even exist (but another entity
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` apparently does exist, which shares the same purported owner); (ii) the
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`“negotiation” allegedly consisted of a 15-minute meeting; (iii) Youssef had an
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`undisclosed attorney-client relationship with the counter-party’s law firm.17
`
`Youssef also knows that, as I have contended, the
`
` transaction price was a
`
`small fraction of the fair value of
`
`.
`
`
`13 Am. Compl. ¶¶ 49, 64, 66, 71, 86–88, 91, 119.
`14 See Ex. 3.
`15 Youssef Mar. 20, 2023 Dec. ¶ 16.
`16 Schaback Dec. ¶ 104.
`17 Id. at ¶¶ 104-107.
`
`6
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`
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`9.
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`As another example, Youssef writes “…Schaback has had unfettered
`
`access to Company information through RLF since at least mid-February 2023...”
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`In truth, I received read-only access to certain specific Company systems in mid-
`
`February 2023 (in the main, QuickBooks, envoice.eu and BambooHR). Despite
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`earlier promises of access, I still have not received access to Paxful’s accounts
`
`payable wallets, showing payments out of Paxful for supposed business expenses
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`with transaction detail. Youssef has caused the Company to withhold this access
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`because allowing me access would enable me to trace the Bitcoin Youssef has
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`fraudulently transferred out of Paxful. In addition, as all parties were aware, due to
`
`its document production obligations for expedited claims, RLF was not able to begin
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`producing any significant volume of documents
`
`from
`
`the Company’s
`
`communications systems until very recently – Saturday, March 18, 2023. Youssef
`
`also knows that he and his subordinates at the Company refused to comply with my
`
`and Company counsel’s repeated requests for information concerning the EMiR
`
`payments, among other issues.18
`
`10. Other examples could be provided. But the point is straightforward:
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`any information from Youssef cannot be trusted without independent corroboration.
`
`18 Ex. 4 at 21:1–15.
`
`
`
`7
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`
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`Developments into My Investigation of Fraudulent Transfers
`
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`11. My counsel and I have continued to investigate the roughly
`
`
`
`in non-ordinary course, fraudulent transfers, which Youssef authorized from the last
`
`week of July 2022 through late February 2023.
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`12. Following the completion of their production of Company documents
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`for the expedited claims in the litigation, during the week of March 13, RLF ran
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`certain key search terms, including “Emir,” “Kalem,” and “Gemean” over the
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`Company’s email and Slack data it had collected. Beginning on March 18, 2023,
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`RLF began to produce documents hitting upon those terms to my counsel.
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`13. To date, RLF has produced roughly 6,000 documents from that review
`
`set, which my attorneys have reviewed. RLF indicates it will make further
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`productions from approximately 4,000 documents withheld initially for hitting on
`
`potentially privileged terms.
`
`14. With respect to EMiR, to whom Paxful has sent over
`
` in
`
`Bitcoin in the last several months, my counsel’s review to date has not identified any
`
`communications between Paxful and EMiR. Nor do the documents produced
`
`otherwise corroborate that EMiR or any supposed contractors working under
`
`EMiR’s direction have ever done any work for the benefit of Paxful.
`
`8
`
`
`
`
`
`
`
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`15.
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`In addition, as mentioned in my prior Declarations, EMiR’s invoices
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`seemed unusual for a Turkish company for lack of compliance with Turkish law. I
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`am attaching legal opinions from a Turkish law firm, which I obtained earlier today,
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`opining that (i) a representative invoice from EMiR is not valid under Turkish law,
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`and (ii) that the actual EMiR business does not issue invoices in Bitcoin.19 Again,
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`EMiR is a clothing company. Paxful’s supposed business relationship with EMiR
`
`is a sham.
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`16. Similarly, with respect to KALEM, another Turkish company to which
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`Paxful sent roughly
`
` in Bitcoin in December 2022 for what Youssef has
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`averred was a “security audit,” the documents produced by RLF similarly do not
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`contain any communications between Paxful and Kalem. Nor do the documents
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`produced otherwise corroborate that KALEM ever performed any work for the
`
`benefit of Paxful.
`
`17. As previously indicated, KALEM’s invoices look very similar to
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`EMiR’s.20 They similarly are invalid under Turkish law. The legal opinion I
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`obtained earlier today similarly opines that (i) a representative invoice from KALEM
`
`
`
`19 See Ex. 5.
`20 Compare Schaback Dec. Ex. 19 with Motion for Approval of Payment (Trans.
`ID No. 69328207), Ex. 5.
`
`9
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`
`
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`
`
`
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`is not valid under Turkish law, and (ii) the actual KALEM business does not issue
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`invoices in Bitcoin. Paxful’s supposed business relationship with KALEM is a
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`sham.21
`
`18. With respect to Gemean, to which Paxful paid roughly
`
` in
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`Bitcoin from December 2022 to February 2023, RLF’s production of documents
`
`hitting upon “Gemean” did not include any documents supporting the legitimacy of
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`the large non-ordinary course payments made. In addition, the Company’s
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`envoice.eu system indicates that former Paxful employee and Gemean principal
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`George Georgiades, a friend of Youssef’s from high school, used his former Paxful
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`account to upload and approve Gemean’s invoices, which then were approved by
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`Youssef and Natalia Baskakova, without any review by Paxful’s in-house
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`compliance staff, in deviation from Paxful’s normal business practices.22
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`19. With respect to MareMars, the Estonian entity apparently outside of
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`Paxful’s ownership structure, to which Youssef admittedly
`
`
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` and to which Youssef caused Paxful to pay over
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` from late
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`December 2022 to February 2023, RLF’s production of documents hitting upon the
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`term “MareMars” has not yielded any communications with any purported
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`
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`21 Ex. 5.
`22 Ex. 6.
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`
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`10
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`
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`
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`representatives of this entity. Youssef’s Declaration claims that he has “no direct or
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`indirect interest or affiliation” with the entity, which he inaccurately calls a
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`“subsidiary.”23 Youssef omits any mention of basic facts, such as who owns
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`MareMars, and who supposedly is managing this new non-Paxful division now
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`housing a
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`.
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`March 21, 2023 Informational Board Meeting and Later Developments
`
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`20. On March 21, 2023, I attended an informational board meeting, which
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`RLF had noticed at Mr. Youssef’s request. I attended along with my counsel, Mr.
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`Youssef and his counsel, and Company counsel from RLF. No other Company
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`representatives or advisors attended.
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`21. As has been the case throughout, I requested (through counsel) that the
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`Company provide any documentation tending to support or corroborate whatever
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`information Mr. Youssef wished to share a reasonable time in advance of the
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`meeting.24 That request was not honored.
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`22. At the March 21 board meeting, Youssef reported that one of the
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`Company’s vendors, BitGo, had experienced a wallet outage affecting users’ ability
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`to transfer funds from the affected wallet. Youssef claimed that this and along with
`
`
`23 Youssef 3/20/23 Dec. ¶ 25.
`24 Ex. 7.
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`11
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`
`
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`
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`
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` supported a need to
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` Paxful immediately. I disagreed,
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`explaining that BitGo experiences a problem like this about once a year. It was not
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`and is not any reason to
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` Paxful.
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`23. While Youssef pointed to the
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` employees, I
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`responded that according to the Company’s human resources database, the Company
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`continued to have a large number of employees in important positions.
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`24. Youssef became angry, insulting and belittling throughout the duration
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`of the meeting. He repeatedly claimed that I and my counsel must be intoxicated for
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`resisting the idea that Paxful’s business must be immediately
`
`
`
` – before even a custodian or receiver could be appointed. He provided
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`the reason that, supposedly in his view, and without providing any other support,
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`that it necessarily would be
`
` without the
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`support supposedly provided by the “EMiR” engineers.
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`25. Youssef argued “there is only one way to go, and that is what this board
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`agreed to in November, which
`
`
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`25
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`26. Youssef belittled me for considering that a custodian might be able to
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`.26
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`
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`25 Ex. 8 at 80:1–4.
`26 See, e.g., id. at 30:1–7, 53:4–8.
`
`12
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`
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`27. Given the disagreement between the directors, and the potential for a
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`neutral to assess the situation and deliver a solution, RLF repeatedly suggested that
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`Youssef stipulate to the immediate appointment of a custodian who could
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`recommend how best to maintain the Company’s business operations in the near-
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`term. Youssef angrily refused, stating “I only consent to a receiver …
`
`
`
`27
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`28. My counsel then suggested that the directors discuss the topic of setting
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`a reserve to pay the requested custodian or receiver. Youssef refused, repeatedly
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`stating
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`28
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`29. Later that day, my counsel received a call from Youssef’s counsel
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`indicating that Youssef would agree to the appointment of a custodian, but only if I
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`agreed that Paxful immediately
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`Youssef’s counsel explained that, with the EMiR engineers supposedly
`
`, Youssef wanted to use their resources to
`
`
`
`
`
`
`
`
`
` Youssef’s counsel explained that he understood it was technically
`
`
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`27 Id. at 91–92.
`28 Id. at 99:12–13.
`
`
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`13
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`
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`
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`feasible to
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`30.
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`31.
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`32.
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`
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`fraudulent transfers to EMiR, Gemean and the like halted, Paxful should be a
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`profitable business generating significant free cash flow that could be used to sustain
`
`the business, address any issues of need that Youssef may have neglected, and to
`
` With the
`
`14
`
`
`
`
`
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`
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`pay a custodian and other professionals.
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`
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`
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`33.
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`I have attempted to inform myself concerning Youssef’s claims about
`
` Toward
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`that end, I have communicated with Michael Peng, who is Paxful’s Chief
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`Compliance Officer. Mr. Peng confirmed that he intends to remain at Paxful beyond
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`the end of the month. He was not aware of any plan to
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` He also was unaware that Youssef wanted a
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`while I wanted any neutral to have the ability to
`
`
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`,
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`.
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`34. Mr. Peng and I discussed his “wish list” for resources in his division,
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`including regarding staffing and legitimate vendor payments. With basic care and
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`attention to Paxful’s business, I believe everything he requested could be provided.
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`35. At the March 21 board meeting and after, I have repeatedly asked for
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`the opportunity to speak with knowledgeable employees in the Company’s
`
`engineering and finance departments. Company counsel at RLF has attempted to
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`facilitate those discussions. I understand, however, that RLF’s former contacts at
`
`the Company have ceased responding to RLF’s communications. As such, I have
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`not been able to communicate with knowledgeable personnel at the Company.
`
`15
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`36.
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`In light of these developments and my growing sense that Youssef
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`fundamentally misrepresented the nature of this litigation and my goals to Paxful
`
`employees and contractors, on March 22, my counsel sent Company counsel and
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`counsel to Mr. Youssef a draft email for transmission to all employees and
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`contractors describing this action and the forthcoming appointment of a Court-
`
`appointed custodian or receiver. The draft email was accurate and non-
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`argumentative. Despite prompting from Company counsel, Youssef has not
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`responded to authorize its transmission to Paxful’s employees and contractors.29
`
`Paxful Can Remain a Going-Concern
`
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`37. There is no disputing that, at all times leading up to Youssef usurping
`
`control, Paxful was a highly valuable Company. Among other accolades, in March
`
`2022, Paxful was named one of Time Magazine’s 100 Most Influential Companies
`
`in 2022. A true and correct copy of that article is attached hereto as Exhibit 10.
`
`38. A Court-appointed custodian could readily stabilize Paxful’s business.
`
`With fraudulent non-ordinary-course payments stopped, Paxful should quickly
`
`
`
`29 Ex. 9.
`30 Schaback Dec ¶¶ 129-130.
`
` it once was.30
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`16
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`
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`39. To my knowledge, no company comparable to Paxful has
`
`
`
`, which Youssef now is using as a pretext to
`
`
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`40. Youssef apparently
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` of former employees, who
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`for some time have had “contractor” titles, does not pose an insurmountable obstacle
`
`to Paxful. The several supposedly key contractors (e.g., Dmitrii Moiseev, Andrei
`
`Skopenko and Natalia Baskakova) who
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` all worked and continue to
`
`work hand-in-glove with Youssef in his
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` They are all
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`replaceable from within Paxful.
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`41. Traditionally, even if
`
`
`
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`
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`42.
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`I am willing to assist the Custodian by immediately resuming my
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`traditional duties overseeing Paxful’s day-to-day business operations as its Chief
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`Operating Officer. If helpful to the Custodian, I also would be willing to assume
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`duties of an interim Chief Executive Officer.
`
`43.
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`I have repeatedly conferred with Michael Peng, Paxful’s Chief
`
`Compliance Officer, who has confirmed his intentions to stay at Paxful beyond
`
`17
`
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`
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`
`
`
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`March 31. We have discussed means of continuing the business and how best to
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`assist his department going forward. Peng also shared his view that customers
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`uniquely like Paxful’s product, observing that, even after the FTX collapse, volume
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`rebounded extremely promptly. Peng concurs there could be greater opportunity for
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`Paxful given the recent stresses upon traditional financial institutions.
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`44. Paxful’s former Chief Accountant,
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` who was a
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`“whistleblower” fired for questioning the EMiR payments, could return to work and
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`oversee accounting/finance functions.
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`45. While former Chief Technology Officer (currently a contractor)
`
`, he has a number of talented people working under
`
`him who hold the titles of VP, director, manager, and team leads who can move the
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`business forward.31
`
`46. Paxful continues to have the necessary engineering resources. Paxful
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`continues to employ or contract directly with 53 software engineers and 19
`
`infrastructure engineers. They are fully capable of maintaining the current Paxful
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`platform and constantly improving it. These individuals hold a range of titles,
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`including C-level executives, Vice Presidents, managers, and team leads.
`
`31 Ex. 11.
`
`
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`18
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`
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`47.
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` other talented former colleagues
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`
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` I am happy to assist any custodian in recruiting and hiring
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`additional talent.
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`48.
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`I also remain available to help any custodian raise new equity or debt
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`financing if needed.
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`, and still
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`fundamentally sound business stabilized, I expect Paxful could raise any additional
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`necessary financing.
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`49. To my knowledge, Youssef has not undertaken any assessment or
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`analysis supporting that
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` Paxful now would be value-
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`maximizing.
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`50. To my knowledge, Youssef also has no plan for orderly transition or
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`governance by a custodian or receiver. As indicated, he has refused my request to
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` a custodian or receiver.
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`51. To the contrary, Youssef’s current plan appears to be to complete the
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` of Paxful, which he never paused,
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`, as he
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`always planned to do. His apparent pretext now is the unsupportable premise that it
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`is
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`Thus he presently is
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`19
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` given challenges of his own making.
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`, including one with the necessary ability to pursue Paxful’s strong claims
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`against Youssef.
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`52.
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`I disagree with Youssef’s unsupported and self-serving purported
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`opinions. The issue of whether
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` would be value-maximizing
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`is a legitimate inquiry for any custodian that the Court may appoint.
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`*
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`*
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`*
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`20
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`16043017
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`
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`I am physically located outside the geographic boundaries of the United
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`States, Puerto Rico, the United States Virgin Islands, and any territory or insular
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`possession subject to the jurisdiction of the United States.
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`Executed on the 24th day of March, 2023, at Tallinn, Estonia.
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`Artur Schaback
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`21
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