UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF FLORIDA

(MIAMI DIVISION)

CASE NO. 1:20-cv-22950-XXXX

ONE TRADE LTD, LLC,

Plaintiff,

vs.

JOHN GLENN and JOHN GLENN, P.C.

d/b/a THE LAW FIRM OF JOHN 

GLENN, P.C.,

Defendants.

_____________________________________/

COMPLAINT

Plaintiff One Trade Ltd, LLC (“One Trade”), by the undersigned, brings the following 

Complaint against Defendants John Glenn (“Attorney Glenn”) and John Glenn, P.C. d/b/a The 

Law Firm of John Glenn, P.C. (the “Glenn Firm”) (collectively, “Defendants”), and alleges: 

I. PARTIES

1. Plaintiff One Trade is a limited liability company formed under the laws of 

Delaware that operates its principal place of business in Miami-Dade County, Florida. One 

Trade’s Managing Member, Simon Librati (“Mr. Librati”), is its sole member and is an individual 

who resides and is domiciled in Miami-Dade County, Florida. Therefore, One Trade is a citizen 

of Florida. 

2. Defendant Attorney Glenn is a practicing attorney who is a member of the Bar of 

the State of Colorado. Attorney Glenn is an individual who resides and is domiciled in the State 

of Colorado. Therefore, Attorney Glenn is a citizen of Colorado.

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3. Defendant the Glenn Firm is a professional corporation that operates as a law firm. 

The Glenn Firm was incorporated in the State of Colorado with its principal place business at 155 

E. Boardwalk Drive, Suite 400, Fort Collins, Colorado 80525. Upon information and belief, 

Attorney Glenn is the sole owner of the Glenn Firm. Therefore, the Glenn Firm is a citizen of the 

State of Colorado. 

II. JURISDICTION AND VENUE 

4. Subject matter jurisdiction exists based on diversity of citizenship under 28 U.S.C. 

§1332, because (a) the parties are citizens of different states (Florida and Colorado); and (b) the 

amount in controversy exceeds $75,000, exclusive of interest and costs. 

5. Personal jurisdiction exists based on Florida Statute § 48.193(1)(a)(1) because 

Defendants provided legal and also escrow services for Florida-based One Trade and 

communicated on numerous occasions with One Trade in Florida, so the communications were 

sent to and/or from Florida and therefore occurred in Florida. 

6. In addition, personal jurisdiction exists based on Florida Statute § 48.193(1)(a)(2) 

because Defendants committed tortious acts which touched, concerned, and affected the operations 

of One Trade in Florida. Because One Trade’s operations and the subject below-described events

occurred in Florida, One Trade was damaged in Florida.

7. Venue is proper in this District under 28 U.S.C. §1391(b)(2), because (a) One Trade 

operates in Miami-Dade County, and thus within this District; and (b) a substantial part of the 

events or omissions giving rise to this action occurred, or a substantial part of property that is the 

subject of this action is or was situated, in Miami-Dade County, and thus within this District. 

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III. ALLEGATIONS 

A. ONE TRADE HIRES DEFENDANTS FOR BOTH 

LEGAL AND ALSO ESCROW SERVICES TO PURCHASE BITCOIN

8. In or around July 2018, One Trade was interested in investing in, and thus 

purchasing, a substantial amount of Bitcoin, a digital currency. 

9. Regarding One Trade’s anticipated purchase of the Bitcoin, Mr. Librati was 

introduced to Defendants. Defendants represented themselves as both a lawyer and also an escrow 

agent who could handle the subject Bitcoin purchase as One Trade’s lawyer and escrow agent. 

10. Therefore, One Trade and Defendants entered a verbal agreement for Defendants

to represent One Trade in two capacities: (a) One Trade’s lawyer; and (b) One Trade’s escrow 

agent. Therefore, Defendants were required to provide the necessary legal and also escrow 

services on One Trade’s behalf, for purposes of One Trade’s subject purchase of Bitcoin from 

seller Diversified Artificial Intelligence Technology Group, LLC (“Diversified”). Diversified is a 

limited liability company believed to be owned and controlled solely by Jeff Hutton, an individual 

residing in Florida. 

11. As part of the subject verbal agreement, Attorney Glenn would have primary and 

sole responsibility for personally providing the services on One Trade’s behalf. 

12. Defendants represented to One Trade that the specific agreed-to legal and also

escrow services included: (a) Defendants would properly handle the Bitcoin closing and release 

One Trade’s escrowed purchase funds (as described below, $3,152,625) to the seller only after

One Trade had received the Bitcoin; (b) the seller would get the full amount of One Trade’s 

purchase funds and One Trade would get the full amount of Bitcoin; and (c) One Trade’s purchase 

funds would be returned to One Trade if One Trade did not receive the Bitcoin.

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13. Defendants held themselves out to One Trade as a fiduciary looking out for solely 

One Trade’s interests in purchasing the subject Bitcoin.

14. One Trade relied on Defendants’ representations, given that Attorney Glenn is a 

lawyer and member of the Colorado Bar.

15. As it turned out, and as further described below, none of what was represented in 

paragraph 12 happened: (a) Defendants did not provide to One Trade any written closing 

documents such as purchase-sale documents; (b) Defendants broke escrow/trust and disbursed One 

Trade’s escrowed purchase funds before One Trade received any Bitcoin; and (c) One Trade never 

received any Bitcoin and never received back its purchase funds consisting of $3,152,625. 

16. Defendants broke escrow/trust without notice to One Trade and thus without One 

Trade’s knowledge and authorization. As further described below, the money has never been 

returned and is still missing.

17. Below are the specific events that shockingly happened on Defendants’ watch.

B. DEFENDANTS DISBURSED FUNDS FROM ESCROW 

PREMATURELY AND THE MONEY HAS NEVER BEEN RETURNED

18. Defendants instructed One Trade to wire the purchase funds consisting of 

$3,152,625 into the Glenn Firm’s escrow/trust account for purposes of One Trade’s purchasing 

Bitcoin. 

19. On July 16, 2018, July 20, 2018 and July 23, 2018, One Trade wired $1,650,000, 

$1,150,000, and $352,625, respectively, for a total amount of $3,152,625 to the Glenn Firm. 

Again, this $3,152,625 represented One Trade’s buyer’s or purchase funds to be held in 

escrow/trust by Defendants for purposes of the Bitcoin closing/purchase that Defendants handled 

(or in reality, completely mis-handled, as further described below).

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20. Specifically, One Trade’s wires totaling $3,152,625 went to the Glenn Firm’s trust 

account, specifically an account at J.P. Morgan Chase Bank, N.A. (“JP Morgan”) in the name of 

“John Glenn, P.C., Colorado Lawyers Trust Account Foundation Collection Account.” The 

Fedwire references listed “ESCROW SERVICES” and “JOHN GLENN P.C. COLORADO 

LAWYERS FORT COLLINS CO 80525.”

21. The closing was supposed to occur at or near the time of the final transfer from One 

Trade – meaning on or shortly after July 23, 2018.

22. Defendants released the $3,152,625 and broke escrow/trust. Upon information and 

belief, Diversified or its owner received One Trade’s money. This occurred before One Trade 

received any amount of Bitcoin. 

23. No Bitcoin was ever transferred to One Trade by Defendants, Diversified, or 

anyone else regarding the subject transaction.

24. Defendants have refused to provide any details or explanation regarding what 

happened or where Defendants transferred One Trade’s $3,152,625.

25. Defendants have refused to return to One Trade the $3,152,625, let alone one 

penny. 

26. On August 1, 2018, Mr. Librati, on behalf of One Trade, contacted his banker at 

Bank of America and submitted a customer complaint against Defendants, seeking that the Glenn 

Firm’s escrow/trust account be frozen based on what had occurred. 

27. On August 2, 2018, Defendants promised to return the $3,152,625 to One Trade if 

Mr. Librati rescinded his customer complaint. That same day, Mr. Librati agreed to rescind his 

customer complaint, but Defendants still did not return the $3,152,625 to One Trade. 

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28. Upon information and belief, Defendants were actually, and may still be, 

Diversified’s and its owner’s lawyer. If such was true, Defendants had an ethical and legal 

obligation to advise One Trade of such representation, to advise One Trade that such was a conflict 

of interest by also representing One Trade, and to advise One Trade that it should hire its own 

counsel. 

29. All conditions precedent for asserting the claims herein have been satisfied, 

executed, or waived.

30. One Trade has retained the undersigned law firm to bring this action and has agreed 

to pay counsel reasonable attorneys’ fees and costs for its services. 

COUNT I – NEGLIGENCE AGAINST DEFENDANTS

(IN THE ALTERNATIVE TO COUNTS II, III, AND IV)

31. One Trade incorporates paragraphs 1 through 30, as if set forth here. 

32. Defendants owed One Trade a duty of care in the transfer of purchase funds

regarding One Trade’s purchase of Bitcoin from Diversified. 

33. Defendants breached their duty of reasonable care to One Trade by failing to 

conduct the necessary due diligence into the transaction and for prematurely releasing One Trade’s 

funds from escrow. For example, (a) Defendants did not provide to One Trade any closing 

documents such as purchase-sale documents; (b) Defendants broke escrow/trust and disbursed all 

of One Trade’s escrowed purchase funds before One Trade received any Bitcoin; and (c) One 

Trade never received any Bitcoin and never received back its purchase funds consisting of 

$3,152,625. 

34. Defendants’ breaches proximately caused One Trade to incur damages.

35. As a result, One Trade has incurred damages in the principal amount of $3,152,625.

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WHEREFORE, One Trade respectfully demands judgment for (a) damages against 

Defendants; (b) prejudgment interest from the date of Defendants’ breaches; and (c) any further 

relief that is just and proper. 

COUNT II – BREACH OF CONTRACT AGAINST DEFENDANTS

(IN THE ALTERNATIVE TO COUNTS I, III, AND IV)

36. One Trade incorporates paragraphs 1 through 30, as if set forth here. 

37. Defendants and One Trade entered into a valid verbal attorney-client and also 

escrow agreement, in which Attorney Glenn would personally provide both legal and also escrow

services, wearing two hats as One Trade’s lawyer and also escrow agent. 

38. The agreed-to legal and also escrow services included: (a) Defendants would 

properly handle the Bitcoin closing and release One Trade’s escrowed purchase funds (the 

$3,152,625) to the seller only after One Trade had received the Bitcoin; (b) the seller would get 

the full amount of One Trade’s purchase funds and One Trade would get the full amount of Bitcoin; 

and (c) One Trade’s purchase funds would be returned to One Trade if One Trade did not receive 

the Bitcoin.

39. Defendants breached the agreement because: (a) Defendants did not provide to One 

Trade any written closing documents such as purchase-sale documents; (b) Defendants broke 

escrow/trust and disbursed One Trade’s escrowed purchase funds before One Trade received any 

Bitcoin; and (c) One Trade never received any Bitcoin and never received back its purchase funds 

consisting of $3,152,625. 

40. One Trade has incurred damages resulting from Defendants’ breaches.

WHEREFORE, One Trade respectfully demands judgment for (a) damages against 

Defendants; (b) prejudgment interest from the date of Defendants’ breaches; and (c) any further 

relief that is just and proper. 

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COUNT III – BREACH OF FIDUCIARY DUTY AGAINST DEFENDANTS

(IN THE ALTERNATIVE TO COUNTS I, II, AND IV)

41. One Trade incorporates paragraphs 1 through 30, as if set forth here.

42. One Trade entrusted its funds with Defendants, who accepted them.

43. Defendants had special duties to act as lawyer and also escrow agent for One 

Trade’s purchase of the subject Bitcoin.

44. One Trade reposed trust and confidence in Defendants, and Defendants had 

influence over One Trade moving forward with the subject transaction.

45. Defendants also had superior knowledge of, and access to, the subject transaction.

46. As such, Defendants owed One Trade fiduciary duties.

47. Defendants breached their fiduciary duties because: (a) Defendants did not provide 

to One Trade any closing documents such as purchase-sale documents; (b) Defendants broke

escrow/trust and disbursed One Trade’s escrowed purchase funds before One Trade received any 

Bitcoin; and (c) One Trade never received any Bitcoin and never received back its purchase funds 

consisting of $3,152,625. 

48. As a direct and proximate cause of Defendants’ breaches, One Trade has incurred 

damages in the principal amount of $3,152,625.

WHEREFORE, One Trade respectfully demands judgment for (a) damages against 

Defendants; (b) prejudgment interest from the date of Defendants’ breaches; and (c) any further 

relief that is just and proper. 

COUNT IV – ATTORNEY MALPRACTICE AGAINST DEFENDANTS

(IN THE ALTERNATIVE TO COUNTS I, II, AND III)

49. One Trade incorporates paragraphs 1 through 30, as if set forth here.

50. One Trade maintained an attorney-client relationship with Defendants.

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51. Defendants breached their duty of trust and loyalty and care because: (a) 

Defendants did not provide to One Trade any closing documents such as purchase-sale documents; 

(b) Defendants broke escrow/trust and disbursed One Trade’s escrowed purchase funds before One 

Trade received any Bitcoin; and (c) One Trade never received any Bitcoin and never received back 

its purchase funds consisting of $3,152,625. 

52. As a direct and proximate cause of Defendants’ breaches, One Trade has incurred 

damages of at least $3,152,625.

WHEREFORE, One Trade respectfully demands judgment for (a) damages against 

Defendants; (b) prejudgment interest from the date of Defendants’ breaches; and (c) any further 

relief that is just and proper. 

Date: July 16, 2020 Respectfully submitted,

SALLAH ASTARITA & COX, LLC

Counsel for One Trade

3010 North Military Trail

Suite No. 210

Boca Raton, Florida 33431

Tel.: (561) 989-9080

Fax: (561) 989-9020

/s/Joshua A. Katz, Esq.

James D. Sallah, Esq.

Fla. Bar No. 0092584

Email: jds@sallahlaw.com

Patrick J. Rengstl, Esq.

Fla. Bar No. 0581631

Email: pjr@sallahlaw.com

Joshua A. Katz, Esq.

Fla. Bar No. 0848301

Email: jak@sallahlaw.com

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