Document for Commonwealth of Massachusetts vs. XEX LTD

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                        COMMONWEALTH            OF MASSACHUSETTS

SUFFOLK,
       ss.                                                                  SUPERIOR COURT
                                                                            CIVIL ACTION NO.
                                                                                   4-16966
COMMONWEALTH           OF MASSACHUSETITS,
                                                                                              mo
                               Plaintiff,




XEX LID.,
                               Defendant.

                                                                                         wu

                                     Affidavit of Diana Hooley

        I, Diana Hooley, make this affidavit in support of the Commonwealth of Massachusetts’

Motion for Alternative Service.

    1   I am currently employed as an Assistant Attorney General at the Massachusetts Attorney

        General’s Office (the “AGO”). I submit this affidavit to place before the Court certain

        facts and documents referred to in the Commonwealth of Massachusetts’ Memorandum

        in Support of its Motion for Alternative Service.

        As part of the AGO’s investigation of the investment scam operated by Defendant, I

        spoke with a Massachusetts victim who indicated that he regularly communicated with

        Defendant’s representatives via WhatsApp and e-mail, and provided copies of his saved

        communications with Defendant’s representatives.

        After Binance granted a temporary freeze on the assets, the AGO received e-mail

        communications from individuals purporting to be wallet holders inquiring about the

        freeze. Two of these individuals communicated       from e-mails,

        xuanxuan25220@gmail.com and ksuperray@gmail.com, that were associated with

        Binance accounts, based on the information provided by Binance. The IP login records
for these accounts show that they are operated from several locations in East Asia. The

        AGO has also successfully sent e-mail to the customer service email address for XEX at

        support@xexpm-support.com.

   4.   Attached to this affidavit are true and correct copies of the following documents:

           a   WhatsApp and e-mail messages between a Massachusetts victim and Defendant’s

               representatives, and the WhatsApp profile of Defendant’s representative (Exhibit

                 1);
               Affidavit of Benjamin Potter, an Investigator of the Investigations Division of the

               Massachusetts Attorney General’s Office (Exhibit 2); and

               Affidavit of Rafal Lepicki, a victim of Defendant’s scheme (Exhibit 3).

               Affidavit of Edward Cherubin, a Senior Investigator of the Investigations

               Division of the Massachusetts Attorney General’s Office (Exhibit 4).



SIGNED UNDER THE PENALTIES OF PERJURY IN BOSTON, MASSACHUSETTS, ON
JUNE 25, 2024.

                                                      B
                                                      Diana Hooley, B
                                                      Assistant Attorney General
                                                      Public Protection & Advocacy Bureau
                                                      Massachusetts Attorney General’s Office
                                                      One Ashburton Place, 18" Floor
                                                      Boston, Massachusetts 02108
                                                      Tel. (857) 383-7025
                                                      diana.hooley@mass.gov