-1-

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

THE JAMES STREIBICH REVOCABLE 

TRUST OF 2002, an Illinois Trust,

individually, and derivatively, on behalf of 

FOLDING LIGHT, LLC, a Delaware 

Limited Liability Company, 

Plaintiffs,

v.

BROCK H. FLAGSTAD, an individual;

OXFORD MARKETING PARTNERS,

LLC, a Delaware Limited Liability 

Company; OXFORD MEDIA, LLC, an

Illinois Limited Liability Company; 

OXFORD TAX PARTNERS, LLC, an 

Illinois Limited Liability Company;

OXFORD FG, LLC, an Illinois Limited 

Liability Company; OXFORD GP, LLC,

an Illinois Limited Liability Company;

FINANCIAL FREEDOM ADVISORS, 

LLC, an Illinois Limited Liability 

Company; and CLOVERPOINT 

PARTNERS, LLC, an Illinois Limited 

Liability Company; 

Defendants.

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

)

No. 

COMPLAINT FOR INJUNCTIVE RELIEF, DAMAGES, 

AND APPOINTMENT OF A RECEIVER

Plaintiff, THE JAMES STREIBICH REVOCABLE TRUST OF 2002, an Illinois Trust,

individually (“the Trust”), and derivatively, on behalf of FOLDING LIGHT, LLC, a Delaware 

Limited Liability Company (“Folding Light”) (hereinafter collectively “the Plaintiffs”), by its

attorneys, Sheppard, Mullin, Richter & Hampton, LLP, for its Complaint for Injunctive Relief, 

Damages and Appointment of a Receiver, against the Defendants BROCK H. FLAGSTAD 

(“Flagstad”), OXFORD MARKETING PARTNERS, LLC (“Oxford Marketing”), OXFORD 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 1 of 32 PageID #:1
-2-

MEDIA, LLC (“Oxford Media”), OXFORD TAX PARTNERS, LLC (“Oxford Tax”), OXFORD 

FG, LLC (“Oxford FG”), OXFORD GP, LLC (“Oxford GP”) (hereinafter collectively referred to 

herein as “Oxford”), FINANCIAL FREEDOM ADVISORS, LLC (“FFA”); and 

CLOVERPOINT PARTNERS, LLC (“Cloverpoint”) (collectively, “the Defendants”), allege as 

follows:

NATURE OF THE CASE

1. This action arises out of Defendants’ scheme to defraud the Trust of over $2,000,000.00 

by inducing the Trust to invest in Folding Light to provide it with trading capital for

crypto currency and securities trading. Instead, Flagstad converted Trust funds for his 

own personal use and benefit. In order to secure the monies from the Trust, Flagstad 

falsely represented that an investment from the Trust would be used as trading capital for 

Folding Light’s E-mini futures, U.S. Treasury and crypto currency trades. Flagstad 

represented engaging in “live” trading was critical to Folding Light’s ability to 

demonstrate that its proprietary trading platform was viable and would generate actual 

returns. Without active trading, Folding Light would not be able to attract significant 

additional outside capital to build the business. However, with active trading, Flagstad 

represented it would be able to attain significant growth and returns. 

2. The Trust, based upon Flagstad’s representations, invested $2,000,000 into Folding 

Light. Flagstad, however, ended up siphoning trading capital the Trust invested with 

Folding Light to outside banking accounts and his other ventures, including Oxford, 

Financial Freedom Advisors and Cloverpoint. The Trust brings this action individually, 

and derivatively on behalf of Folding Light, both of whom have been irreparably 

damaged as a result of Flagstad’s unlawful conduct for violations of Section 1962(c) of 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 2 of 32 PageID #:2
-3-

the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. § 1962(c) 

(Count I), Conspiracy to Violate Section 1962(c) of RICO, 18 U.S.C. § 1962(d)

(Count II), Common Law Fraud (Count III), Conversion/Theft (Count IV), Breach of 

Fiduciary Duty (Count V), Breach of Contract (Count VI), Civil Conspiracy (VII), and 

for an Accounting (VIII). 

PARTIES

3. Plaintiff The James Streibich Revocable Trust of 2002, (“the Trust”) is an Illinois Trust, 

with its principal office located in Chicago, Illinois. The Trust maintains a membership 

interest in Folding Light. 

4. Plaintiff Folding Light, LLC, (“Folding Light”) is a Delaware Limited Liability 

Company, with its principal place of business located in Chicago, Illinois at 215 W. Ohio 

Street. 

5. Defendant Brock Flagstad (“Flagstad”) is an individual domiciled in Sea Island, Georgia.

Flagstad maintains a membership in Folding Light and acts as its Lead Manager. 

6. Defendant Oxford Marketing Partners, LLC is a limited liability company organized 

under the laws of the state of Delaware with its principal place of business located in 

Chicago, Illinois at 215 W. Ohio Street. Flagstad is a member of and controls Oxford 

Marketing Partners, LLC.

7. Oxford Media, LLC is a limited liability company organized under the laws of the state 

of Illinois with its principal place of business located in Chicago, Illinois at 215 W. Ohio 

Street. Flagstad is a member of and controls Oxford Media, LLC.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 3 of 32 PageID #:3
-4-

8. Oxford Tax Partners, LLC is a limited liability company organized under the laws of the 

state of Illinois with its principal place of business located in Chicago, Illinois at 215 W. 

Ohio Street. Flagstad is a member of and controls Oxford Tax Partners, LLC.

9. Oxford FG, LLC is a limited liability company organized under the laws of the state of 

Illinois with its principal place of business located in Chicago, Illinois at 215 W. Ohio 

Street. Flagstad is a member of and controls Oxford FG, LLC. 

10. Oxford GP, LLC is a limited liability company organized under the laws of the state of 

Illinois with its principal place of business located in Chicago, Illinois at 215 W. Ohio 

Street. Flagstad is a member of and controls Oxford GP, LLC. 

11. Financial Freedom Advisors, LLC (“FFA”) is a limited liability company organized 

under the laws of the state of Illinois with its principal place of business located in 

Chicago, Illinois at 215 W. Ohio Street. Flagstad is a member of and controls Financial 

Freedom Advisors, LLC. 

12. Cloverpoint Partners, LLC (“Cloverpoint”) is a limited liability company organized under

the laws of the state of Illinois with its principal place of business located in Chicago, 

Illinois at 215 W. Ohio Street. Flagstad is a member of and controls Cloverpoint 

Partners, LLC. 

JURISDICTION AND VENUE

13. Original jurisdiction over this matter exists pursuant to 28 U.S.C. § 1331 and 18 U.S.C. 

§ 1964(c). The Court also has supplemental jurisdiction over Plaintiffs’ claims arising 

under state law pursuant to 28 U.S.C. § 1367.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 4 of 32 PageID #:4
-5-

14. Venue of this action is proper in this District pursuant to 28 U.S.C. § 1391(b)(2) because 

a substantial part of the events or omissions giving rise to the claims alleged herein 

occurred in this District.

FACTUAL ALLEGATIONS COMMON TO ALL COUNTS

15. Flagstad has started numerous limited liability companies (“Flagstad Companies”) in 

Chicago – most, if not all, of which are located at the same address of 215 West Ohio 

Street. Upon information and belief, Flagstad Companies also share the same accountant 

and law firm for advisory services. Flagstad furthermore is the dominant member of each 

Flagstad Company and he maintains control of all financial accounts and matters. 

16. Flagstad has solicited millions of dollars in private equity funds for Flagstad Companies

from numerous prominent Chicago-area investors. Flagstad’s common business model is 

to start a company that purportedly develops a revenue stream through the collection 

and/or sale of data. Flagstad Companies include a variety of industry sectors, including 

healthcare and tax. Upon information and belief, once formed, Flagstad then seeks out 

millions of dollars in investment capital with the promise of rapid growth and above 

market returns to investors. Flagstad’s Companies all take the form of either Delaware or 

Illinois limited liability companies. Most, if not all, do business in Chicago from the 

same offices located at 215 West Ohio Street. Flagstad Companies also share the same 

law and accounting firms for advisory services. 

17. Upon information and belief, the web of Flagstad Companies include:

• Folding Light, LLC (SOS File No. 06762271)

• Folding Light, LLC (SOS File No. 07037198)

• Folding Light BC, LLC (SOS File No. 07036809)

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 5 of 32 PageID #:5
-6-

• Folding Light, FX LLC (SOS File No. 07036787)

• Oxford Marketing Partners, LLC (SOS File No. 07036418)

• Oxford Media, LLC (SOS File No. 07389493)

• Oxford Tax Partners, LLC (SOS File No. 05327865)

• Oxford FG, LLC (SOS File No. 07389566)

• Oxford GP, LLC (SOS File No. 07956983)

• Financial Freedom Advisors (SOS File No. 04225376)

• In Parallel, LLC (SOS File No. 03399729)

• Two Screens Media, LLC (SOS File No. 05132436)

• Press Media Group, LLC (SOS File No. 05902665)

• Channel Clarity Holdings, LLC (SOS File No. 04164334)

• Channel Clarity Holdings, Inc. (SOS File No. 64272624)

• Brookside Capital, LLC (SOS File No. 07046855)

• Cloverpoint Partners, LLC (SOS File No. 04225414)

FLAGSTAD’S SWINDLE

18. On or about May 2018, Flagstad approached the Trust through its Trustee James 

Streibich (“Streibich”) to solicit an investment in Folding Light. Flagstad represented 

that Folding Light had developed a proprietary financial trading platform to trade

securities and bitcoin and other crypto-based currencies. Flagstad represented that 

Folding Light’s proprietary trading platform for block chain currency trading was unique 

in the Financial Technology (“Fin Tech”) industry. He further represented to the Trust 

that Folding Light was looking for trading capital in order to activate its trading 

strategies. With trading capital it could validate its business model and build Folding 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 6 of 32 PageID #:6
-7-

Light into a significant market participant. Flagstad represented that trading platform 

“back testing” had demonstrated significant financial returns. And, with the trading 

capital from the Trust, Folding Light could demonstrate actual returns which would allow 

it to: 1) attract significant additional outside private equity investment, and 2) be able to 

leverage the trading capital at multiple times its value. 

19. Flagstad represented and warranted to the Trust that, in exchange for an investment of 

$2,000,000 to be used for trading capital, the Trust would acquire a preferred interest in 

Folding Light. Flagstad further represented and warranted that the Trust funds received 

would be used only for Folding Light trading capital. As recently as January 29, 2020 

during a conference call with Streibich, and Flagstad’s attorney Stan Sneeringer, Flagstad 

reaffirmed that the Trust’s capital was to be used only for trading capital when he 

explained the rationale behind the creation of the Trust’s $743,000 Promissory Note 

Folding Light owed to the Trust. 

20. The Trust, through its Trustee, Streibich, told Flagstad that the Trust was interested in 

investing in Folding Light to provide trading capital in response to Flagstad’s 

representations. Flagstad reaffirmed his promise that the Trust’s funds would only be 

used for trading capital, not to fund Folding Light business expenses, and that business 

expenses were the responsibility of himself and Folding Light Member, Kasey Klaas. In 

May 2018, the Trust, in reliance upon Flagstad’s representations and warranties, invested 

$2,000,000 into Folding Light. The Trust received in exchange a membership interest in 

the form of preferred capital in Folding Light. 

21. Upon information and belief, only a matter of weeks after the Trust’s investment, 

Flagstad began siphoning money from Folding Light’s account to himself and to Flagstad 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 7 of 32 PageID #:7
-8-

Company FFA. Upon information and belief as of this filing, between June 1 and July 

24, 2018, Flagstad took $340,000 of Folding Light cash and transferred it to himself and 

FFA. In the Fall of 2018, the Folding Light trading team and other members departed to 

start a competing trading company. Folding Light thereafter filed suit against former 

Folding Light Members and employees, including Kasey Klaas, in the United States 

District Court for the Northern District of Illinois. See Folding Light, LLC v. Kasey 

Klaas, et al., Case No. 1:19-cv-03949 (N.D. Ill. filed June 12, 2019). The Defendants 

responded with counterclaims against Flagstad for conversion and breach of fiduciary 

duty. The counterclaims allege that Flagstad converted over $340,000 from Folding 

Light and transferred the funds to a Flagstad Company FFA.

22. The Trust, upon learning of the counterclaim against Flagstad, inquired of the claim. 

Flagstad denied converting funds and represented that the counter claimants did not 

understand accounting. With financial trading on hold due to the abrupt departure of 

Folding Light’s trading team and funds in Folding’s Light’s account, Flagstad 

approached Streibich regarding establishing a Revolving Credit Line of $200,000 with 

Folding Light then loaning up to this amount to Flagstad’s Company Oxford Marketing 

Partners. Streibich agreed to this loan to Oxford Marketing Partners with the inclusion of 

interest payable on a monthly basis to Folding Light. On information and belief, Flagstad 

and Oxford Marketing Partners made the first four interest payments but have not made 

any further payments, and have not returned the $200,000 principal to Folding Light. 

Instead, upon information and belief, Oxford Marketing Partners has kept the Folding 

Light funds for its own personal use and benefit along with Flagstad. 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 8 of 32 PageID #:8
-9-

23. In the summer of 2019, Flagstad moved his residence from Chicago to Sea Island, 

Georgia. Folding Light was no longer operational and remained embroiled a dispute with

its former trading team and Folding Light Members. With Flagstad’s move to Georgia, 

the Trust was finding it difficult to receive information from him regarding Folding 

Light’s finances. Flagstad became increasing unavailable to discuss Folding Light and 

repeatedly ignored the Trust’s requests for updated Company reports regarding its 

financial affairs. 

FLAGSTAD’S CONTINUED EMBEZZLEMENT FROM FOLDING LIGHT

24. Flagstad has a rapacious personal need for cash to support his lavish lifestyle of private 

jets and expensive cars. Upon information and belief, his cash needs exceeded any 

compensation he received from Oxford or his other sources of income. To meet his 

personal spending, Flagstad has been systematically and secretly taking hundreds of 

thousands of dollars in cash from Folding Light and diverting it to bank accounts outside 

of Folding Light including Oxford, FFA and Cloverpoint.

25. Upon information and belief, Flagstad most recently may have created phony invoices 

and/or expense records to substantiate the hundreds of thousands of dollars he transferred 

from Folding Light to Oxford. Since Flagstad retains complete control over Folding 

Light’s books and records, the Trust has little to no understanding of the Company’s

financial affairs. And despite the Trust’s repeated requests to review Folding Light’s 

books and records, Flagstad has refused to produce them and/or to provide an accounting 

of the use of Folding Light assets.

26. The Trust in late 2019 persisted in seeking financial information regarding Folding Light 

from Flagstad, without success. With Flagstad’s failures to communicate to the Trust, its 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 9 of 32 PageID #:9
-10-

concern and suspicion of Flagstad increased. As a result, in February 2020 Streibich 

decided to go directly to one bank where he knew Folding Light maintained an account. 

He was able to obtain partial banking information that startingly revealed that Flagstad—

beginning as early as January 2019 and without notifying Folding Light Members, 

notifying the management committee, providing collateral, or requesting the Trust’s 

consent for a related party transaction as was done just one month prior for the Revolving 

Line of Credit Line—made at least $849,000 in unauthorized secret cash wire transfers 

from Folding Light to bank accounts outside of Folding Light which Flagstad controls. 

Flagstad has refused to provide a justification for his purloining of Folding Light cash. 

27. The partial bank records that were recovered reveal Flagstad’s illegal cash wire transfers

from Folding Light in the following stunning amounts:

Date Account Amount ($)

06-04-19 4494 50,000

06-05-19 4494 25,000

06-14-19 4494 125,000

06-24-19 4494 100,000

07-01-19 4494 100,000

08-15-19 4494 44,269

08-27-19 1146 50,000

09-17-19 4494 100,000

10-21-19 4494 25,000

11-13-19 1146 16,332

11-18-19 4494 25,000

11-20-19 4494 15,000

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 10 of 32 PageID #:10
-11-

12-02-19 4494 25,000

12-10-19 4494 15,000

12-16-19 4494 40,000

12-19-19 4494 7,500

01-09-20 4494 50,000

01-16-20 4494 21,000

02-07-20 4494 15,000

$849,100.73

28. Upon information and belief, Flagstad stole Folding Light funds in order to funnel cash 

through Oxford into his own pockets to feed his lavish life style and maintain his image 

with private equity investors in Flagstad Companies. Flagstad’s conversion of Folding 

Light cash from the Trust and Folding Light is a breach of his fiduciary duty owed to the 

Trust and Folding Light. 

COUNT I

(Violation of RICO, 18 U.S.C. § 1962(c))

29. The Trust and Folding Light reallege paragraphs 1 through 28 as though fully set forth 

herein.

30. The Racketeer Influenced and Corrupt Organizations Act (“RICO”) makes it unlawful 

“for any person through a pattern of racketeering activity . . . to acquire or maintain, 

directly or indirectly, any interest in or control of any enterprise which is engaged in, or 

the activities of which affected, interstate or foreign commerce.” 18 U.S.C. § 1962(c).

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 11 of 32 PageID #:11
-12-

31. Each Defendant is a “person” within the meaning of 18 U.S.C. § 1961(3) who conducted 

or participated, directly or indirectly, in the affairs of the enterprise through a pattern of 

racketeering activity in violation of 18 U.S.C. § 1962(c).

32. The Defendants constitute an “enterprise” within the meaning of 18 U.S.C. § 1961(4) 

because their association furnished a vehicle for the commission of at least two predicate 

acts of racketeering activity enumerated in 18 U.S.C. § 1961(1)(B) (“the Enterprise”).

33. The Enterprise has an ascertainable, legitimate, and ongoing structure separate and apart 

from that inherent in the pattern of racketeering activity that the Defendants engaged in. 

Flagstad, Oxford, FFA, and Cloverpoint are persons distinct from the Enterprise. 

34. At all relevant times, each of the Defendants was associated with the Enterprise, exerted 

control over the Enterprise, and participated directly or indirectly in the operation and 

management of the affairs of the Enterprise.

35. The Enterprise engaged in and affected interstate commerce through the use of the mails 

and wires to communicate through telephone, e-mail and to transfer assets and funds 

between persons in the Enterprise.

36. The Defendants’ committed several acts that constituted an unlawful scheme or artifice of 

racketeering intended to defraud, or to obtain money or property through false or 

fraudulent pretenses, representations, or promises, in violation of 18 U.S.C. § 1341 (mail 

fraud), 1343 (wire fraud), and 2314 (interstate transportation of stolen property).

37. The Defendants conducted and participated in the affairs of the Enterprise through a 

pattern of racketeering activity that includes acts indictable under 18 U.S.C. §§ 1341

(mail fraud), 1343 (wire fraud), and 2314 (interstate transportation of stolen property), as 

described herein. 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 12 of 32 PageID #:12
-13-

38. The mails and wires were used on numerous occasions in furtherance of the foregoing 

scheme or artifice against the Plaintiffs and others. 

39. Upon information and belief, Flagstad, Oxford, FFA and Cloverpoint communicated with 

one another through the use of electronic mail and/or telephone in order for cash transfers 

and “loans” to be made from Folding Light to Flagstad, Oxford, FFA and Cloverpoint. 

Information relating to additional victims is exclusively within the Defendants’ control. 

40. Upon information and belief, Flagstad, Oxford, FFA and Cloverpoint further 

communicated with one another and PNC Bank as well as other financial institutions, 

through the use of electronic mail, internet banking platforms, and/or telephone in order 

to effectuate cash transfers and “loans” from Folding Light accounts to the Defendants. 

Information relating to additional victims of the Defendants’ conduct is exclusively 

within the Defendants’ control. 

41. Folding Light received from the Trust $2,000,000 in funds intended for use as trading 

capital and not to be used for business operating expenses. Flagstad, over the course of 

the past year and a half, siphoned the funds Folding Light received from the Trust to 

himself personally, Oxford, FFA, Cloverpoint and/or to bank accounts outside of Folding 

Light for his own use and personal benefit and for the benefit of Oxford, FFA and 

Cloverpoint.

42. The Defendants’ repeated use of the wires from 2019 to the present, in furtherance of the 

foregoing schemes or artifices, constituted acts of “racketeering activity” within the 

meaning of 18 U.S.C. § 1961(1)(B). Collectively, these violations constitute a “pattern of 

racketeering activity” within the meaning of 18 U.S.C. § 1961(5).

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 13 of 32 PageID #:13
-14-

43. The Defendants engaged in an unlawful pattern of racketeering activity to defraud the 

Plaintiffs and other unknown victims. 

44. By virtue of these violations of 18 U.S.C. § 1962(c), the Defendants are liable to the 

Plaintiffs for three times the damages they have sustained as a result of the Defendants’

conduct, plus the costs of this suit, including reasonable attorneys’ fees, pursuant to 

18 U.S.C. § 1964(c).

WHEREFORE, the Trust and Folding Light pray for the following relief against 

Defendants Flagstad, Oxford, FFA and Cloverpoint:

a. Award the Plaintiffs damages in an amount in excess of $2,000,000;

b. Pursuant to 18 U.S.C. § 1964(c), award the Plaintiffs three times the amount of 

actual damages incurred as a result of the Defendants’ conduct;

c. Award costs of litigation including; but not limited to, attorneys’ fees, court costs 

and expert costs;

d. Award prejudgment interest on any monetary awards to the Plaintiffs; and 

e. For such other and further relief the court deems is just.

COUNT II

(Conspiracy to Violate Section 1962(c) of RICO, 18 U.S.C. § 1962(d))

45. The Trust and Folding Light reallege paragraphs 1 through 44 as though fully set forth 

herein.

46. RICO makes it unlawful for any person to conspire to violate subsection (c) of Title 18, 

Section 1962. See 18 U.S.C. § 1962(d). 

47. Defendants collectively joined in agreement and conspired with one another to commit at 

least two predicate acts of racketeering activity enumerated in 18 U.S.C. § 1961(1)(B), in 

violation of 18 U.S.C. § 1962(d). 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 14 of 32 PageID #:14
-15-

48. By virtue of their violation of 18 U.S.C. § 1962(d), the Defendants are liable to the 

Plaintiffs for three times the damages they have sustained as a result of the Defendants’

conduct, plus the costs of this suit, including reasonable attorneys’ fees, pursuant to 

18 U.S.C. § 1964(c).

WHEREFORE, the Trust and Folding Light pray for the following relief against 

Defendants Flagstad, Oxford, FFA and Cloverpoint:

a. Award the Plaintiffs damages in an amount in excess of $2,000,000;

b. Pursuant to 18 U.S.C. § 1964(c), award the Plaintiffs three times the amount of 

actual damages incurred as a result of the Defendants’ conduct;

c. Award costs of litigation including; but not limited to, attorneys’ fees, court costs 

and expert costs;

d. Award prejudgment interest on any monetary awards to the Plaintiffs; and 

e. For such other and further relief the court deems is just.

COUNT III

(Common Law Fraud)

49. The Trust and Folding Light reallege paragraphs 1 through 28 as though fully set forth 

herein.

50. Folding Light received from the Trust $2,000,000 in funds intended for use as trading 

capital and not to be used for business operating expenses. Flagstad over the course of 

the past year and a half siphoned the funds Folding Light received from the Trust to 

himself personally, Oxford, FFA, Cloverpoint and/or to bank accounts outside of Folding 

Light for his own use and personal benefit and for the benefit of Oxford, FFA and 

Cloverpoint. 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 15 of 32 PageID #:15
-16-

51. At the time that Flagstad represented to the Trust that its investment would be used for 

Folding Light trading capital, Flagstad was soliciting funds from the Trust so he could 

use them personally, for Oxford, FFA and Cloverpoint. Once the Trust funds were 

received at Folding Light, Flagstad began stealing them for his own personal benefit and 

his Flagstad Companies including Oxford, FFA and Cloverpoint.

52. At the time that Flagstad made the representations to the Trust, he knew that his 

representations were false and that he needed the Trust’s cash to support his lavish 

personal lifestyle and his other Flagstad Companies including Oxford, FFA and 

Cloverpoint.

53. Flagstad made the representations to the Trust with the intent to fraudulently obtain its 

money so he could use the Trust’s funds for his personal use and benefit as well as 

Oxford, FFA and Cloverpoint. He did not and not for Folding Light’s trading account. 

54. The Trust was reasonably induced by Flagstad’s representations to invest funds into 

Folding Light and did so. 

55. Flagstad’s representations and wrongful conduct constitute fraud. 

56. The Trust and Folding Light have incurred damages in excess of $2,000,000. 

57. The Trust and Folding Light have no adequate remedy at law. Money damages alone 

will not, and cannot, compensate the Trust and Folding Light for the loss of goodwill, or 

the loss of business opportunities, which they will suffer as a result of the actions of these 

Defendants. 

58. By their conduct, Defendants have demonstrated their willingness to continue to engage 

in continuous fraudulent acts. It is clear that the injury to the Trust and Folding Light is 

immediate and irreparable.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 16 of 32 PageID #:16
-17-

59. The Trust and Folding Light have demonstrated that these Defendants have, and unless 

restrained will continue to, engage in conduct which is alleged herein. There is a 

likelihood that the Trust and Folding Light will prevail on the merits of this action.

60. Should the Court grant interlocutory injunctive relief to the Trust and Folding Light, the 

burden on these Defendants will be slight compared to the injury to the Trust and Folding 

Light if it is not granted. No injury to these Defendants will result from an order which 

requires these Defendants to comport their actions to the law.

61. The granting of an injunction will not disserve the public interest. Indeed, injunctive 

relief would protect against the continuing fraud that Flagstad Companies continue to 

engage in. 

62. Whereas here, Flagstad Companies including Folding Light business operations are 

permeated by fraud, the Trust and Folding Light have made the requisite showing that 

assets will be dissipated during the pendency of the proceedings unless Defendants’

assets are frozen and a receiver appointed to marshal and protect them.

WHEREFORE, the Trust and Folding Light pray for the following relief against 

Defendants Flagstad, Oxford, FFA and Cloverpoint:

a. Entry of a preliminary and permanent injunction against these Defendants, and 

each of them, from engaging in fraudulent acts and practices in violation of the 

Illinois law;

b. Entry of a preliminary and permanent injunction against these Defendants, and 

each of them, enjoining and restraining them from destroying or disposing of any 

books, records, or accounts or of any property, whether real, personal, or mixed;

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 17 of 32 PageID #:17
-18-

c. Entry of a preliminary and permanent injunction against the Defendants enjoining 

and restraining any Defendant or person acting on their behalf, from withdrawing 

transferring or disposing of any property owned by these Defendants, and each of 

them, whether real, personal, or mixed;

d. Entry of an order appointing a receiver with the power to sue for, collect, receive 

and take into his possession all the goods and chattels, rights and credits, moneys 

and effects, lands and tenements, books, records, documents, papers, choses in 

action, bills, notes and property of every description, which were derived by 

means of the illegal practices described above;

e. Entry of a judgment in favor of the Trust and Folding Light against the above 

Defendants, and each of them, for compensatory damages in an amount to be 

proven at trial, but which is not less than $2.0 million;

f. An award of punitive damages in an amount to be proven at trial;

g. Entry of an order freezing the assets of these Defendants and ordering the 

appointment of a receiver over Defendants’ assets;

h. The imposition of a constructive trust on these Defendants on all monies or 

property obtained by or through their wrongful conduct as alleged herein;

i. An order prohibiting the Defendants from filing a petition for relief under the 

United States Bankruptcy Code, 11 U.S.C. § 101 et seq., without prior permission 

from this Court;

j. An order awarding the Trust its costs and attorney’s fees; and

k. Such further and additional relief as the Court may deem appropriate.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 18 of 32 PageID #:18
-19-

COUNT IV

(Conversion/Theft)

63. The Trust and Folding Light reallege paragraphs 1 through 28 as though fully set forth 

herein.

64. Folding Light received from the Trust $2,000,000 in funds for use as trading capital and 

which were not to be used for Folding Light business operations. Flagstad, Oxford, 

FFA, and Cloverpoint had no legal right to take or use Folding Light funds the Trust had 

invested in Folding Light for their own use and benefit. 

65. Upon information and belief, beginning in May 2018 Flagstad, Oxford, FFA and 

Cloverpoint began siphoning Folding Light cash into other accounts Flagstad controls 

outside of Folding Light. He did this without Folding Light or the Trust’s consent and 

for his own personal use and benefit and to Folding Light and the Trust’s detriment.

66. Upon information and belief, the wrongful cash transfers amount to at least $849,000. 

The illegal cash transfers were made without the consent of Folding Light Members or 

the Trust.

67. Flagstad, Oxford, FFA and Cloverpoint’s transfers constituted the conversion of funds 

from Folding Light. None of the funds converted have been repaid to Folding Light or 

returned to the Trust. 

68. Flagstad, Oxford, FFA and Cloverpoint continue to possess, control, or have wrongfully 

benefitted from their conversion of Folding Light cash and funds the Trust invested.

69. Flagstad, Oxford, FFA and Cloverpoint wrongfully assumed control and possession of 

Folding Light cash from its bank accounts, and have used Folding Light cash wrongfully 

for their personal use and benefit and to the detriment of Folding Light and the Trust. 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 19 of 32 PageID #:19
-20-

70. The Trust has made demand upon Flagstad for the return of the cash stolen from Folding 

Light. 

71. Despite the Trust’s demands for payment, Flagstad has refused and continues to refuse to 

return the cash converted from Folding Light.

72. The Trust and Folding Light have no adequate remedy at law. Money damages alone 

will not, and cannot, compensate the Trust and Folding Light for the loss of goodwill, or 

the loss of business opportunities, which they will suffer as a result of the actions of these 

Defendants. 

73. By their conduct, Defendants have demonstrated their willingness to continue to engage 

in the conversion and theft of Folding Light assets. It is clear that the injury to the Trust 

and Folding Light is immediate and irreparable.

74. The Trust and Folding Light have demonstrated that these Defendants have, and unless 

restrained will continue to, engage in conduct which is alleged herein. There is a 

likelihood that the Trust and Folding Light will prevail on the merits of this action.

75. Should the Court grant interlocutory injunctive relief to the Trust and Folding Light, the 

burden on these Defendants will be slight compared to the injury to the Trust and Folding 

Light if it is not granted. No injury to these Defendants will result from an order which 

requires these Defendants to comport their actions to the law.

76. The granting of an injunction will not disserve the public interest. Indeed, injunctive 

relief would protect against the continuing fraud that Flagstad and Flagstad Companies

continue to engage in. 

77. Whereas here, Flagstad’s Companies and Folding Light are permeated by fraud, the Trust 

and Folding Light have made the requisite showing that assets will be dissipated during 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 20 of 32 PageID #:20
-21-

the pendency of the proceedings unless Defendants’ assets are frozen and a receiver 

appointed to marshal and protect them.

WHEREFORE, the Trust and Folding Light pray for the following relief against 

Defendants Flagstad, Oxford, FFA and Cloverpoint:

a. Entry of a preliminary and permanent injunction against these Defendants, and 

each of them, from engaging in acts and practices in violation of the Illinois law;

b. Entry of a preliminary and permanent injunction against these Defendants, and 

each of them, enjoining and restraining them from destroying or disposing of any 

books, records, or accounts or of any property, whether real, personal, or mixed;

c. Entry of a preliminary and permanent injunction enjoining and restraining any 

Defendant or person acting on their behalf, from withdrawing transferring or 

disposing of any property owned by these Defendants and each of them whether 

real, personal, or mixed;

d. Entry of an order appointing a receiver with the power to sue for, collect, receive 

and take into his possession all the goods and chattels, rights and credits, moneys 

and effects, lands and tenements, books, records, documents, papers, choses in 

action, bills, notes and property of every description, which were derived by 

means of the illegal practices described above;

e. Entry of a judgment in favor of the Trust and Folding Light against the above 

Defendants, and each of them, for compensatory damages in an amount to be 

proven at trial, but which is not less than $2.0 million;

f. An award of punitive damages in an amount to be proven at trial;

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 21 of 32 PageID #:21
-22-

g. Entry of an order freezing the assets of these Defendants and ordering the 

appointment of a receiver over Defendants’ assets;

h. The imposition of a constructive trust on these Defendants on all monies or 

property obtained by or through their wrongful conduct as alleged herein;

i. An order prohibiting the Defendants from filing a petition for relief under the 

United States Bankruptcy Code, 11 U.S.C. § 101 et seq., without prior permission 

from this Court;

j. An order awarding the Trust its costs and attorney’s fees; and

k. Such further and additional relief as the Court may deem appropriate.

COUNT V

(Breach of Fiduciary Duty)

78. The Trust and Folding Light reallege paragraphs 1 through 28 as though fully set forth 

herein.

79. At all times relevant hereto, Flagstad was a Folding Light Member and acted as its Lead 

Manager and was an agent for his principal Folding Light. 

80. As an agent for Folding Light and as its Lead Member, Flagstad had a fiduciary duty of 

loyalty and good faith and is required to behave in a manner consistent with and solely 

with Folding Light and the Trust’s best interest.

81. Flagstad was further required to preserve and promote Folding Light’s business and to 

preserve its assets for Folding Light’s benefit and its members, including the Trust.

82. Flagstad intentionally and willfully breached his fiduciary duty owed to Folding Light

and the Trust by embezzling cash from Folding Light for his own personal use and 

benefit through unauthorized cash transfers from Folding Light bank accounts to himself 

personally, Oxford, FFA, Cloverpoint and other accounts outside of Folding Light.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 22 of 32 PageID #:22
-23-

83. Flagstad further breached his fiduciary duty owed to the Trust and Folding Light by 

otherwise generally in mismanaging Folding Light assets and by the actions complained 

of above. 

84. As a direct and proximate result of one or more of Flagstad’s foregoing wrongful acts or 

omissions, Flagstad has caused and is causing irreparable harm, as well as substantial 

monetary damages to the Trust and Folding Light in an amount of at least $2,000,000.

The Trust and Folding Light have no adequate remedy at law. Money damages alone 

will not, and cannot, compensate the Trust and Folding Light for the loss of goodwill, or 

the loss of business opportunities, which they will suffer as a result of the actions of these 

Defendants

WHEREFORE, the Trust and Folding Light pray for the following relief against 

Defendants Flagstad, Oxford, FFA and Cloverpoint:

a. Entry of a preliminary and permanent injunction against these Defendants, and 

each of them, from engaging in acts and practices in violation of the Illinois law;

b. Entry of a preliminary and permanent injunction against these Defendants, and 

each of them, enjoining and restraining them from destroying or disposing of any 

books, records, or accounts or of any property, whether real, personal, or mixed;

c. Entry of a preliminary and permanent injunction enjoining and restraining any 

Defendant or person acting on their behalf, from withdrawing transferring or 

disposing of any property owned by these Defendants and each of them whether 

real, personal, or mixed;

d. Entry of an order appointing a receiver with the power to sue for, collect, receive 

and take into his possession all the goods and chattels, rights and credits, moneys 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 23 of 32 PageID #:23
-24-

and effects, lands and tenements, books, records, documents, papers, choses in 

action, bills, notes and property of every description, which were derived by 

means of the illegal practices described above;

e. Entry of a judgment in favor of the Trust and Folding Light against the above 

Defendants, and each of them, for compensatory damages in an amount to be 

proven at trial, but which is not less than $2.0 million;

f. An award of punitive damages in an amount to be proven at trial;

g. Entry of an order freezing the assets of these Defendants and ordering the 

appointment of a receiver over Defendants’ assets;

h. The imposition of a constructive trust on these Defendants on all monies or 

property obtained by or through their wrongful conduct as alleged herein;

i. An order requiring Flagstad to forfeit all compensation received from Folding 

Light during the time in which he breached his fiduciary duties owed to Folding 

Light and the Trust; 

j. An order prohibiting the Defendants from filing a petition for relief under the 

United States Bankruptcy Code, 11 U.S.C. § 101 et seq., without prior permission 

from this Court;

k. An order awarding the Trust its costs and attorney’s fees; and

l. Such further and additional relief as the Court may deem appropriate.

COUNT VI

(Breach of Contract)

85. The Trust and Folding Light reallege paragraphs 1 through 28 as though fully set forth 

herein.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 24 of 32 PageID #:24
-25-

86. The Trust acquired all interest in Folding Light pursuant to the Folding Light Limited 

Liability Agreement effective as of February 1, 2018 (“the Agreement”) and attached 

hereto as Exhibit 1.

87. The Trust has fully performed all obligations under the Agreement.

88. Pursuant to the terms of the Agreement, among other things, Flagstad was to act in the 

best interest of Folding Light and its Members. Flagstad as a Member and Lead Manager 

furthermore had fiduciary duties owed to Folding Light and its Members, including the 

Trust.

89. The Agreement further requires unanimous written consent of the Members before the 

Company or its Mangers could dilute a Members’ interest as Flagstad did here with the 

outright theft of Folding Light cash. The Agreement also requires that Flagstad as a 

Folding Light Manager and its Lead Manager keep or cause to be kept complete and 

accurate books and records of the Company along with supporting documentation for 

transactions with respect to the conduct of the Company’s business. Flagstad materially 

breached the Agreement in failing to keep or have kept accurate books and records as the 

Agreement requires. 

90. Flagstad further materially breached the Agreement in acquiring real and/or personal 

property through converted Folding Light cash and holding it in his name or a Flagstad 

Company such as Oxford, FFA or Cloverpoint. 

91. Flagstad’s outright conversion of Folding Light cash constitutes a material breach of the 

Agreement.

92. The Trust has made demand upon Flagstad for the return of the cash stolen from Folding 

Light. The Trust has further made a demand upon Flagstad for an accounting and to 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 25 of 32 PageID #:25
-26-

inspect the books and records of Folding Light which has he has failed or refused to 

provide. 

93. Despite the Trust’s demands for payment, Flagstad has refused and continues to refuse to 

return the cash converted from Folding Light.

94. The Agreement provides that in the event of a breach or even threatened breach of one or 

more provisions of the Agreement, that the party who is or may be injured shall be 

entitled to the following preliminary and permanent injunctive relief (i) restraining and 

enjoining any act which would constitute a breach, (ii) compelling the performance of 

any obligation under the Agreement that if not performed would constitute a breach of 

the Agreement, and such relief may be obtained without the showing of actual irreparable 

harm and no bond or security shall need to be furnished. 

WHEREFORE, the Trust and Folding Light demand, prays for the following relief 

against Flagstad:

a. Entry of a preliminary and permanent injunction against Flagstad from engaging 

in acts and practices in violation of the Agreement;

b. Entry of a preliminary and permanent injunction against Flagstad enjoining and 

restraining him from destroying or disposing of any books, records, or accounts or 

of any property, whether real, personal, or mixed;

c. Entry of a preliminary and permanent injunction enjoining and restraining 

Flagstad or any person acting on their behalf, from withdrawing transferring or 

disposing of any Folding Light property whether real, personal, or mixed;

d. Entry of an order appointing a receiver with the power to sue for, collect, receive 

and take into his possession all the goods and chattels, rights and credits, moneys 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 26 of 32 PageID #:26
-27-

and effects, lands and tenements, books, records, documents, papers, choses in 

action, bills, notes and property of every description, which were derived by 

means of the illegal practices described above;

e. Entry of a judgment in favor of the Trust and Folding Light against Flagstad for 

compensatory damages in an amount to be proven at trial, but which is not less 

than $2.0 million;

f. An award of punitive damages in an amount to be proven at trial;

g. The imposition of a constructive trust on all monies or property Flagstad obtained 

by or through his wrongful conduct as alleged herein;

h. An order awarding the Trust its costs and attorney’s fees; and

i. Such further and additional relief as the Court may deem appropriate.

COUNT VII

(Civil Conspiracy)

95. The Trust and Folding Light reallege paragraphs 1 through 28 and paragraph 49 through 

94 as though fully set forth herein.

96. The Defendants acted in concert, and conspired with each other to violate the common 

law as alleged herein in the preceding Counts III, IV, V and VI. Flagstad, Oxford, FFA 

and Cloverpoint were aware of the conspiracy and knowingly participated therein.

Oxford, FFA and Cloverpoint participated in accepting and wrongfully transferring funds 

from Folding Light in coordination with Flagstad. The scheme Flagstad, Oxford, FFA 

and Cloverpoint participated in led to the conversion of Folding Light trading capital and 

which the Trust had invested in Folding Light. Flagstad, Oxford, FFA and Cloverpoint 

acted in concert to commit illegal acts, including but without limitation, the claims 

alleged herein.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 27 of 32 PageID #:27
-28-

97. Flagstad, Oxford, FFA and Cloverpoint had a meeting of the minds on the course of 

action as alleged in the preceding Counts III, IV, V and VI, including the conversion, and 

wrongful use of Folding Light cash the Trust had provided through its investment. 

98. The Trust’s damages, including but not limited to the diminution of the value of Folding 

Light and loss of business opportunities, cannot be adequately compensated through 

remedies at law alone, thereby requiring equitable relief in addition to compensatory and 

punitive relief. Furthermore, the Agreement permits and allows for injunctive relief under 

these circumstances of a material breach as Flagstad has done herein. 

99. Flagstad, Oxford, FFA and Cloverpoint’s actions will continue to cause harm to Folding 

Light and the Trust unless restrained. 

100. Should this court grant injunctive relief to the Trust and Folding Light , the burden on the 

Defendants would be slight compared to the injury to the Trust and Folding Light if it 

was not granted. No injury to the Defendants would result from an order requiring them 

to comport their actions under the law. There is a likelihood that the Trust and Folding 

Light will prevail on the merits.

101. The granting of an injunction will not disserve the public interest. Indeed, granting the 

injunction would ensure that the Defendants are not able to injure others with their 

continued unlawful conduct. And, the Agreement provides for the issuance of an 

injunction whereas here Flagstad has materially breached the Agreement. 

WHEREFORE, the Trust and Folding Light pray for the following relief against 

Defendants Flagstad, Oxford, FFA and Cloverpoint:

a. Entry of a preliminary and permanent injunction against these Defendants, and 

each of them, from engaging in acts and practices in violation of the Illinois law;

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 28 of 32 PageID #:28
-29-

b. Entry of a preliminary and permanent injunction against these Defendants, and 

each of them, enjoining and restraining them from destroying or disposing of any 

books, records, or accounts or of any property, whether real, personal, or mixed;

c. Entry of a preliminary and permanent injunction enjoining and restraining any 

Defendant or person acting on their behalf, from withdrawing transferring or 

disposing of any property owned by these Defendants and each of them whether 

real, personal, or mixed;

d. Entry of an order appointing a receiver with the power to sue for, collect, receive 

and take into his possession all the goods and chattels, rights and credits, moneys 

and effects, lands and tenements, books, records, documents, papers, choses in 

action, bills, notes and property of every description, which were derived by 

means of the illegal practices described above;

e. Entry of a judgment in favor of the Trust and Folding Light against the above 

Defendants, and each of them, for compensatory damages in an amount to be 

proven at trial, but which is not less than $2.0 million;

f. An award of punitive damages in an amount to be proven at trial;

g. Entry of an order freezing the assets of these Defendants and ordering the 

appointment of a receiver over Defendants’ assets;

h. The imposition of a constructive trust on these Defendants on all monies or 

property obtained by or through their wrongful conduct as alleged herein;

i. An order prohibiting the Defendants from filing a petition for relief under the 

United States Bankruptcy Code, 11 U.S.C. § 101 et seq., without prior permission 

from this Court;

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 29 of 32 PageID #:29
-30-

j. An order awarding the Trust its costs and attorney’s fees; and

k. Such further and additional relief as the Court may deem appropriate.

COUNT VIII

(Accounting)

102. The Trust realleges paragraphs 1 through 28 as though fully set forth herein.

103. Flagstad’s conduct as alleged herein constitutes fraud, conversion and breaches of his

respective fiduciary duties to Folding Light and its members, including the Trust.

104. Flagstad, Oxford, FFA and Cloverpoint, through their actions and outright theft of 

Folding Light cash have funneled assets to various persons and entities unknown to the 

Trust. 

105. The Trust has made a demand for an accounting from Flagstad as Folding Light’s Lead 

Manager and the controlling Member of Oxford, FFA and Cloverpoint, and he has failed 

or otherwise refused to provide one. 

106. The Trust is entitled to an accounting because of Flagstad, Oxford FFA and Cloverpoint’s

conversion of Folding Light assets, and fraud, conversion and breach of fiduciary duties 

as alleged herein. The accounting requested should be conducted in equity because:

• The Trust has no adequate remedy at law for an accounting;

• The accounting would be complex and intricate as Flagstad, Oxford, FFA

and Cloverpoint have engaged in numerous complex scams in order to 

steal Folding Light assets; and

• The total amounts due from Flagstad, Oxford, FFA and Cloverpoint are 

unknown to the Trust because the individual Defendants have exclusive 

knowledge of the accounts and cash transfers made from Folding Light 

and in and out of Oxford, FFA and Cloverpoint. Only Flagstad, Oxford, 

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 30 of 32 PageID #:30
-31-

FFA and Cloverpoint have the records necessary to conduct an accounting 

that would reveal how and when Flagstad funneled assets from Folding 

Light, to Oxford, FFA and Cloverpoint and where the assets are now 

located.

WHEREFORE, for all the forgoing reasons, the Trust respectfully request the following 

relief:

a. An order compelling Flagstad, Oxford, FFA and Cloverpoint to account for all 

transactions with Folding Light and in particular when Folding Light assets were 

converted into their own interest;

b. A judgment entered in favor of the Trust and Folding Light and against Flagstad, 

Oxford, FFA and Cloverpoint for all loses sustained resulting from the 

Defendants’ fraud, conversion and breach of fiduciary duties; 

c. An order awarding the Trust and Folding Light its costs and attorney’s fees

incurred in this action; and

d. Such further and additional relief as the Court may deem appropriate.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 31 of 32 PageID #:31
-32-

Respectfully submitted,

THE JAMES STREIBICH REVOCABLE TRUST 

OF 2002, an Illinois Trust, individually, and 

Derivatively, on behalf of FOLDING LIGHT, LLC, 

a Delaware Limited Liability Company

By: /s William K. Kane 

One of Its Attorneys

William K. Kane, Esq. (6194466)

David M. Poell, Esq.(6302765)

SHEPPARD MULLIN RICHTER & HAMPTON

LLP

Three First National Plaza

70 West Madison Street, 48th floor

Chicago, Illinois 60602

Telephone: 312.499.6300

Facsimile: 312.499.6301

wkane@sheppardmullin.com 

dpoell@sheppardmullin.com

Counsel for Plaintiffs, The James Streibich

Revocable Trust of 2002, an Illinois Trust,

individually, and derivatively, on behalf of Folding 

Light, LLC, a Delaware Limited Liability 

Company.

Case: 1:20-cv-02242 Document #: 1 Filed: 04/09/20 Page 32 of 32 PageID #:32