Motion to Dismiss in Pina Cesar Vs Robinson Anthony| Trellis.Law

On November 13, 2023 a Motion,Ex Parte was filed involving a dispute between Cesar Pina, Jennifer Pina, and Anthony Robinson, I Close Deals Llc, Nichole Lynell, Llc, Real Estate Rico, Llc, Rona Proof Llc, Tony The Closer Llc, for Defamation in the District Court of Bergen County.

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Alexander Schachtel, Esq. (ID # 128062015)
Law Office of Alexander Schachtel, LLC
101 Hudson Street, Ste. 2109
Jersey City, New Jersey 07302
Attorney for Defendants
(p) 201-925-0660
(e) xschachtel@gmail.com

SUPERIOR COURT OF NEW JERSEY
CESAR PINA and JENNIFER PINA, LAW DIVISION: BERGEN COUNTY
DOCKET NO.: BER-L-6134-23
Plaintiffs,

NOTICE OF MOTION TO DISMISS
v. COMPLAINT PURSUANT TO R. 4:6-
2(b), FOR LACK OF PERSONAL
ANTHONY ROBINSON, TONY THE JURISDICTION
CLOSER LLC, I CLOSE DEALS LLC,
RONA PROOF LLC, REAL ESTATE RICO
LLC, NICHOLE LYNELL LLC,

Defendants.

PLEASE TAKE NOTICE that on Friday, March 1, 2023, or as soon thereafter as

counsel can be heard, all Defendants named above will appear before the Superior Court of New

Jersey, Bergen County, Law Division to request an order dismissing the Plaintiff’s Complaint

and all counts set forth therein, pursuant to R. 4:6-2(b), for lack of personal jurisdiction.

Please TAKE FURTHER NOTICE that in support of this motion Defendants will rely

on the accompanying certifications, letter brief and the annexed exhibits.

Please TAKE FURTHER NOTICE that Defendants request oral argument only if this

motion is opposed.

By: /s/ Alexander Schachtel
Alexander Schachtel, Esq.
Attorney for Defendants
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Dated: February 6, 2024
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SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: BERGEN COUNTY
CESAR PINA and JENNIFER PINA, DOCKET NO.: BER-L-6134-23
Plaintiffs,

v. PROPOSED ORDER

ANTHONY ROBINSON, TONY THE
CLOSER LLC, I CLOSE DEALS LLC,
RONA PROOF LLC, REAL ESTATE RICO
LLC, NICHOLE LYNELL LLC,

Defendants.

THIS MATTER having been brought before the Court by Alexander Schachtel, Esq.

attorney for Defendants, seeking relief by way of Order dismissing the Complaint, pursuant to R.

4:6-2(b), for lack of personal jurisdiction, and the court having considered the submissions of the

movant, opposition of the Plaintiffs, and having heard argument on the matter;

IT IS on this ___________ day of _______________________, 24,

ORDERED that the Complaint is hereby dismissed, with prejudice, pursuant to R. 4:6-

2(b), as this Court lacks personal jurisdiction over all Defendants named in the Complaint; and it

is further

ORDERED that a copy of this order shall be served upon counsel for the opposing party

within ___________ days.
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_________________ OPPOSED

_________________ UNOPPOSED

By order of ______________________________________
J.S.C.
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SUPERIOR COURT OF NEW JERSEY
CESAR PINA and JENNIFER PINA, LAW DIVISION: BERGEN COUNTY
DOCKET NO.: BER-L-6134-23
Plaintiffs,

CERTIFICATION OF ANTHONY
v. ROBINSON IN SUPPORT OF MOTION
TO DISMISS
ANTHONY ROBINSON, TONY THE
CLOSER LLC, I CLOSE DEALS LLC,
RONA PROOF LLC, REAL ESTATE RICO
LLC, NICHOLE LYNELL LLC,

Defendants.

I, Anthony Robinson, being of due age and of sound mind, do hereby say and affirm as

follows:

1. I am named as a Defendant in this lawsuit and therefore I am personally familiar with the

facts which are set forth in this statement.

2. I am also the owner of all LLCs which are named as co-Defendants in this lawsuit.

3. I am currently a resident of Los Angeles, California, and a citizen of the State of

California. I have never been a resident of New Jersey.

4. The business entities named as Defendants in this case are companies that I formed and

registered in the State of North Carolina.

5. I have not intentionally published or broadcast any messages into the State of New
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Jersey, ever.

6. None of my businesses has ever done anything to target Cesar or Jen Pina or the State of

New Jersey.

7. None of my businesses have ever operated in the State of New Jersey.

8. All social media posts that are referenced in the Complaint were made by me personally,

on my personal social media pages.

9. My social media posts did not involve any of the business entity Defendants.

10. I am former professional athlete.

11. After retiring from sports I developed a second career as a realtor.

12. As part of my real estate career, I have used social media frequently under my “screen

name” “Tony the Closer.”

13. Part of my social media use involves the area of “citizen journalism” as I have helped to

expose scams in the real estate industry.

14. I had previously, in 2022 and early 2023, helped to identify Gregory Parker (a/k/a) “Biz

Bizzness” as the operator of a real estate scam.

15. Big Bizzness was a high-profile social media influencer who was operating a

multimillion dollar real estate scam in the Philadelphia area.

16. In the Spring of 2023, after outing Big Bizzness, I earned a reputation on social

media for busting scammers, and I started to receive messages from victims of an investment

scam involving Cesar Pina.

17. By June of 2023, I had heard from over ten separate victims of this scam.

18. The victims that reached out to me were located in New York, New Jersey,

Pennsylvania, Massachusetts, Florida, and other parts of the country.
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19. Most of the victims had a similar story, they said they had signed joint venture

investment contracts for house flipping deals, made large deposits of a hundred thousand dollars

or more to Cesar Pina, Jennifer Pina, or their associates, and were promised payouts within six

months when subject properties were supposed to be sold.

20. Unfortunately, the victims had been ripped off and almost none of them had gotten any

money back. The promised payouts never came through.

21. Most victims that I spoke to had learned of the Pinas by attending real estate seminars

hosted by DJ Envy, or through DJ Envy’s radio show or social media posts.

22. DJ Envy is a well-known DJ who hosts “The Breakfast Club,” a morning talk

radio show broadcast nationally through iHeartRadio.

23. DJ Envy is Cesar Pina’s business partner, and he had a large role in the Pinas’ scam.

24. From May 2023 through August of 2023, I received hundreds of emails, direct

messages, phone calls, and other outreach from more victims of this scam.

25. As of the date of this statement, I have personally spoken to close to one hundred victims

of the Pinas’ scam, and I would estimate that the total amount of money that the Pinas stole from

these people is in the range of $40 Million to $70 Million.

26. I have personally hosted interviews with some of the victims by doing live broadcasts on

my Instagram or Twitter feeds.

27. I have also done interviews with former associates of the Pinas, who chose to speak out

and help bring attention to the Pinas criminal behavior.

28. My motivation for giving a platform to victims was not to make money or build fame for

myself, but to try to help the people who lost money seek justice for what the Pinas had done to

them, mostly by getting their money back.
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29. I have also been interviewed by law enforcement officers and private attorneys in

relation to ongoing criminal and civil legal proceedings against the Pinas.

30. In October 2023 the US Attorney for the District of New Jersey filed a criminal

complaint against Cesar Pina, the Plaintiff in this lawsuit, for wire fraud.

31. The US Attorney’s Office called the Pinas’ scam a “Ponzi-like scheme”

and described the same scheme that had been described to me by the victims I interviewed on

social media.

32. To my knowledge, the Pinas are currently facing at least twenty (20) separate civil

lawsuits from their scam victims.

33. Personally, I have made no money by exposing this scam.

34. I have not charged any money for interviews, media appearances, or received payments

from any third parties for my work on social media exposing the Pinas.

35. In fact, I am losing money because I am now being forced to pay legal fees to defend

this frivolous lawsuit.

36. I had been trying to raise funds to help pay for my legal fees by selling t-shirts, which I

have advertised online in some of my social media posts.

37. I have called the Pinas and their associates “Real Estate RICO” operators, because

truthfully, that is what they were doing.

38. The Pinas have stolen tens of millions of dollars from victims in New Jersey who are

mostly black and Hispanic young men.

39. I have tried to stand up for members of my community by giving voices to the victims of

the scam.

40. This lawsuit that has been filed against me is outrageous and absurd, it is like
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Bernie Madoff suing the people who exposed his Ponzi scheme for defamation.

41. Cesar Pina is an abject criminal, con man, and scammer of epic proportions and he

should be in jail.

42. All of my posts about the Pinas contained information that was shared with me by direct

victims of their scam, or by attorneys, journalists, investigators, or other social media researchers

in which case the information was backed up by public record documents.

43. Some of my social media posts about the Pinas were intended for humor and were not

meant to be taken seriously, it was obvious which posts were humorous based on the content.

44. Upon the advice of my attorney, the court does not need to look at the merits of the

claims against me in the complaint because this case should be dismissed for lack of jurisdiction.

45. I have never done or said anything to target the Plaintiffs in the State of New Jersey.

46. No social media post was made about the Pinas by any of the businesses that are named

as Defendants in this lawsuit.

47. Upon the advice of my attorney, I respectfully request that the Court dismiss the lawsuit

against me for these reasons.

48. I certify that I placed my electronic signature below on this statement in place of my

original signature.

49. I hereby certify that the foregoing statements made by me are true, I am aware that if

any of these statements are willfully false, I am subject to punishment.

/s/ Anthony Robinson
Anthony Robinson
Dated: 2/5/2024
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CERTIFICATION OF SERVICE

I, Alexander Schachtel, Esq., hereby certify that the original of the within notice of

motion and supporting papers have been filed with the Court via e-file, and that a true and

accurate copy of same has been served to opposing counsel via regular U.S. mail and via-email

to the following addresses:

Corinne Mullen Esq.
Mullen Law Firm
221 River Street, 9th Floor
Hoboken, New Jersey 07030
Law Office of Alexander Schachtel
Attorney for Defendant

/s/ Alexander Schachtel

Dated: February 6, 2024
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SUPERIOR COURT OF NEW JERSEY
CESAR PINA and JENNIFER PINA, LAW DIVISION: BERGEN COUNTY
DOCKET NO.: BER-L-6134-23
Plaintiffs,

CERTIFICATION OF COUNSEL IN
v. SUPPORT OF MOTION TO DISMISS

ANTHONY ROBINSON, TONY THE
CLOSER LLC, I CLOSE DEALS LLC,
RONA PROOF LLC, REAL ESTATE RICO
LLC, NICHOLE LYNELL LLC,

Defendants.

I, Alexander Schachtel Esq., being of due age and of sound mind, do hereby say and

affirm as follows:

1. I am counsel to the Defendants in this action and therefore I am personally familiar with

the contents of this statement and related subject matter.

2. Attached hereto as Exhibit A is a copy of the Plaintiffs’ filed complaint.

3. Attached hereto as Exhibit B are copies of various local and national media reports which

relate to the Plaintiffs’ operation of a multimillion dollar “Ponzi scheme.”

4. Attached hereto as Exhibit C is a copy of a criminal complaint against Cesar Pina filed

by the United States Attorney’s Office for the District of New Jersey.

5. Attached hereto as Exhibit D is a copy of a press release from the United States
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Attorneys’ Office, dated October 18, 2023, corresponding to the filing of the criminal complaint

against Planitiff Cesar Pina.

6. I hereby certify that the foregoing statements made by me are true, I am aware that if

any of these statements are willfully false, I am subject to punishment.

/s/ Alexander Schachtel
Alexander Schachtel Esq.
Dated: 2/6/2024
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EXHIBIT A
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MULLEN LAW FIRM
Corinne M. M Mullen, Esq. (Attorney ID# 035551983)
Hoboken Riverfront Center
221 River Street, 9th Floor
Hoboken, NJ 07030
Phone: (201) 420-1911
Fax: (201) 742-7022
Email: corinne@mullenlawfirm.com

Attorney for Plaintiffs, Cesar Pina and Jennifer Pina

CESAR PINA and JENNIFER PINA SUPERIOR COURT OF NEW
JERSEY
Plaintiffs,
LAW DIVISION: BERGEN
vs. COUNTY
ANTHONY ROBINSON, TONY THE CLOSER DOCKET NO.:
LLC, I CLOSE DEALS LLC, RONA PROOF LLC,
REAL ESTATE RICO, LLC, NICHOLE LYNELL, CIVIL ACTION
LLC.
Defendants. VERIFIED COMPLAINT

Plaintiffs, Cesar Pina (“Mr. Pina”) and Jennifer Pina (“Mrs. Pina”) (collectively “the

Pinas” or “Plaintiffs”), by and through their undersigned counsel, Mullen Law Firm, alleges the

following against Anthony Robinson a/k/a Tony the Closer (“Defendant”), Tony the Closer LLC,

I Close Deals LLC, Rona Proof LLC, Real Estate Rico, LLC, and Nichole Lynell, LLC.

(“Defendants”).

PRELIMINARY STATEMENT

1. In this action, Defendants, knowingly and intentionally, individually and collectively,

have uttered false, slanderous and defamatory statements about the Plaintiffs, which have

and continue to severely damage Plaintiffs. Defendants have engaged in this wrongful

conduct for the purpose of defaming plaintiffs, interfering with Plaintiffs’ prospective

economic advantage and interfering with the contracts entered by Plaintiffs.
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2. As a result of the tortious conduct engaged in by defendants, collectively and

individually, Plaintiffs have suffered loss of reputation, compensatory and punitive

damages in an amount to be determined at trial.

3. Furthermore, as a result of the conduct engaged in by Defendants, the Defendants

individually and collectively have been generating sales of their own products, increasing

traffic on various social media sites operated by Defendant Anthony Robinson and his

associates, and for the personal gain of Anthony Robinson and his associates and

Limited Liability Companies under his control, and limited liability companies under the

control of his partner, Nichole Lynel, operating as Nichole Lynel, LLC. Defendants have

also benefited from their false and defamatory statements against Plaintiffs in the form of

paid advertisements.

4. As such, Plaintiffs bring this suit, inter alia, to enjoin Defendants from making any

further false defamatory or slanderous statements about Plaintiffs, and for damages

against Defendants to recover the losses that Plaintiff has sustained, resulting from

Defendant’s wrongful actions.

NATURE OF THE ACTION

5. This case arises from the Defendant’s false, defamatory, slanderous, and malicious

assertions that Plaintiffs are “thieves” and “scammers” and that they “stole millions”.

6. Defendant has publicly and maliciously spread these false claims on his websites

(https://tonythecloser.com/ and https://www.iclosedealstoo.com/), and through his sizable

social media presence, including accounts on Instagram

(https://www.instagram.com/tonythecloser), Twitter (@tonythecloser_), and YouTube

(https://www.youtube.com/@TonyTheCloser).
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7. As part of a tortious strategy to drive views and engagement with his own brand,

Defendant Robinson frequently makes posts insulting, attacking, or arguing with other

public figures.

8. Defendant Robinson uses his social media presence to promote his own uses his websites

and social media platforms to sell self-promotional real estate “coaching” materials under

various names and through several different companies, including his “Rona Proof

Master Class” course materials; weight-loss drinks, clothing and other items on his social

media platform as well as his associate’s platform, Defendant Nichole Lynett, LLC.

9. Defendant also promotes his real estate investing business and his real estate coaching

business through his social media accounts,

10. Beginning on or about May 25, 2023, Defendant began posting about what he deemed a

“scam” run by the Pinas and Raashauna Casey (“Mr. Casey”), initially asserting in an

Instagram “live” post (a live video broadcast to all of Defendant’s Instagram followers)

that the Pinas had been accused of scamming investors, and that the Pinas were only

famous because they had been “promoted” on Mr. Casey’s radio show.

11. During his first May 25, 2023, “live” post regarding Mr. Casey, Defendant was careful to

state that these were “allegations,” and “claims,” by investors who claimed to be

defrauded by the Pinas, and not factual statements.

12. Throughout June 2023, Defendant continued to refine his new business model and

increased social media success as an enemy of “scammers,” posting attacks against

alleged “scammers,” and then quickly advertising his real estate courses.
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13. On July 19, 2023, and then again on September 21, 2023 Defendant posted on Instagram

“Tony The Closer Top Ten List of Scammers 2023 drops [] today #RealEstateRico

#NoRefundsNoPeace HowtoCatchaScammer.” appearing below:

14.

15. This image falsely accuses Plaintiffs of being scammers and is defamatory as it claims

that Plaintiffs’ are not legitimate and that they steal money from investors.

16. On June 29, 2023, Defendant posted an updated list of “Tony The Closer Top 10

Scammer List,” on Twitter and Instagram, generating thousands of likes, more than 1,300

comments, and hundreds of thousands of “views” across both platforms.

17. These false statements regarding Plaintiffs continue to generate substantial publicity for

Defendant and his companies through the sale of his real estate “guru” investment

courses and other services to “first time” buyers who want to earn “$20k” per month.

18. On August 11, 2023, Defendant stated, “I'm gonna say so Goddamnit heavy you

say right beside flipping in Cesar running the whole full blown Ponzi scheme you

got lygus come into my career talking about you're running a criminal organization

there's drugs involved in everything and I need to shut up [] Did you just go get the

you got the blog's involved after you had come to my career with drugs and all

kinds of shit, you know how they shouldn't make you to tell me to shut up you can't
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be a smart liquid because now he just gave all the eyeballs on me Hey over so I'm

happy to be here because this is one of the full drug organization.”

19. On August 11, 2023, Defendant stated, “Because he's used his platform to talk

about pushing education to the people and people who are out here right now

suffering because his business partner, stole millions of dollars, and we're not

talking about one or $2 million, there's only 50 victims are ready to have come

forward and over $25 million.”

20. During a live video conference hosted on August 15, 2023, Defendant stated the

following:

a. “from the words that I’ve already had speaking to attorneys, as well over 25

million already that happen that he has spoken to and in victims, and this could be

potentially a 50 to $100 million Ponzi scheme once it’s all said and done.”

b. “ And here's the thing I want to talk about I Heart Radio is very, very much liable

for it. I'm using it for allowing DJ envy to use and promote a known felon who

was a drug trafficker, a scammer from the 90s He allowed that same dude to come

out there and do the same exact crime to millions of people. He promoted a flat

out fraud a scammer and a drug dealer on the platform. And guess what they did?

They scammed as they drove they sold drugs. They're involved with drug dealers.

They were involved in a very nasty I'm telling you, I don't give a fuck these

motherfuckers were involved in drugs. They were involved in money laundering.

If you look at some of the actual some of the actual videos even looking at

Lutchy's page, they're saying they're collecting rent. You're gonna look at the

money and the way that the money is wrapped and rubber bands this shit doesn't
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nobody turns into rent money this way. Nobody nobody turns in rent money and

fucking 20s strapped around in the fucking and rubber bands and stacks like that

only people that put their money like that is dope boys and to sit back and watch

and see.”

c. “If you see these messages where he was literally coercing people, to give them

200…300…400,000 in order to run his fucking Ponzi scheme, yet, none of that

money was used in real estate transactions.”

21. On September 11, 2023, Defendant falsely asserts that Plaintiffs were involved in a slip

and fall lawsuit, appearing below, and claims that Plaintiffs were awarded $425,000,

further alleging that Plaintiffs the lawsuit was an, “insurance finesse”:

22.
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23. This post falsely asserts that Plaintiffs’ are liars and pushes Defendant’s defamatory

statement that Plaintiffs are scammers, criminals, and dishonest.

24. On September 24, 2023, Defendant continues to assert that Plaintiff Cesar Pina has

“finessed” investors, appearing below:

25.

26. This image improperly advances the narrative that Plaintiff Cesar Pina is a greedy

scammer who takes advantage of innocent individuals.

27. As recently as August 2, 2023, Defendant falsely asserted on Twitter that “Raashaun

Casey & Cesar Pina Real Estate Ponzi Scheme Leaves Investor in Financial Ruins After

350k Investment.”
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28. On August 18, 2023, Defendant posted on Instagram, “DJ Envy can you explain if Cesar

ever wrote you a $527,000 bad check or does he only do that to investors?” appearing

below:

29.

30. On September 30, 2023, Defendant posted, “Bruh we got Cesar Bank records from

Flip2Dao and boy has -$6 left! Some of the transactions were Popeyes Chicken, Door

Dash, Gucci, and more #RealEstateRico” appearing below:

31.
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32. This post is an invasion of privacy and improperly asserts that Plaintiff Cesar Pina is

scamming investors and using their money for personal use.

33. Defendant hosted a live meeting on or around October 4, 2023 with the title, “Cesar Pina

& DJ Envy Real Estate Fraud Scheme Victims” appearing below:

34.

35. On October 9, 2023, Defendant posted on Instagram, “Husband and wife power couple

scams over 80 million and count! Lives ruined all over while they block and avoid

investors.” appearing below:
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36.

37. On October 14, 2023, Defendant posted, “Cesar owes over $900,000 to a man who

passed away. When the family went to claim his money what y’all thing Cesar said” and

then reposted the statement on Instagram on the same day, stating, “No one should be ok

with this violating good people for personal benefit is disgusting.” appearing below:
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38.

39. This post improperly depicts Plaintiff Cesar Pina as a cold hearted individual who steals

money from his investors.

40. On an indeterminable date, Defendant posted on his Instagram story reel picture of cash

and the caption, “DJ Ponzi & Flipping pancakes I just want y’all to know that these

people want they damn money back…Money laundering DJ Envy” appearing below:
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41.
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42. This image improperly asserts that Plaintiffs have been laundering money with the help

of DJ Envy.

43. Defendant accuses Plaintiff Cesar Pina of using his daughter, Taylor Pina, to hide assets

from investors and calls Cesar, “Americas(sic) dumbest criminal[]” appearing below:

44.

45. This post improperly asserts that Plaintiffs are using their daughter to hide assets from

investors, calling them criminals.

46. Defendant posted a comment stating that “hundreds of people who trusted Cesar with

millions of dollars…I began to uncover a web of lies deceit and fraud…people who
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wanted to build generational wealth through real estate and got scammed just like I did

years ago by Jay Morrison…This scandal has well over 40 million dollars and lives have

been ruined by this scam.” appearing below:

47.

48. This post improperly pushes the narrative that Plaintiff Cesar Pina is a scammer who

takes advantage of the Black and Hispanic community.

49. Defendant asserts that Cesar has also scammed Snoop Dog, appearing below:
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50.

51. Defendant continues to advance the false narrative that Plaintiff Cesar Pina is a scammer

by asserting that Plaintiff Cesar Pina has also scammed Snoop Dog.

52. It is clear that Defendant will continue to make knowingly false, malicious, and

defamatory statements about Plaintiffs across his social media channels, because those

statements generate publicity, increase his social media following, and further his

financial interests by allowing him to increase engagement with new customers and make

money selling real estate “courses” to new viewers.
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53. In May 2023, Plaintiff Mr. Pina, was rejected on a business loan for 500k because of

what they saw on social media.

54. In June 2023, Plaintiff Mr. Pina’s 2.5 million dollar refinance was rejected because the

lenders saw Tony the Closer’s social media posts.

55. In June 2023, Plaintiff Mr. Pina’s million dollar refinance chicago was denied because

they saw social media.

56. In July 2023, Plaintiff Mr. Pina’s six properties that were going to be sold were canceled

because of what they saw on social media.

57. In August 2023, Plaintiff Mr. Pina’s ride along event in St. Louis had to be canceled

because of death threats; an estimated 2,000 tickets are sold per event.

58. Plaintiff Mr. Pina’s Real estate platform, “flip2Dao” has been destroyed, first years

earnings was 900k, projected 5 million dollars over next 5 years.

59. Plaintiff Mr. Pina’s TV Show with AE has been placed on hold, endorsement deals alone

are an estimated 500k.

60. Hubzu, the second biggest auction house in the US, canceled their partnership with

Plaintiff Mr. Pina and DJ envy, estimated income 1 million dollars.

61. All of Plaintiff Mr. Pina’s real estate partnerships with lenders, realtors, private lenders,

insurance companies have been canceled, estimated income 300k.

62. Plaintiff Mr. Pina’s One on One income, estimated worth of 360k a year, has been

canceled due to death threats, fear of safety, and overall bookings have decreased.

63. Plaintiff Mr. Pina is unable to lend because of the posts and information after Googled.

64. Plaintiff Mrs. Pina faces possible suspension or loss of her Real Estate license.

65. Plaintiff Mrs. Pina is unable to list or show homes due to death threats via text messages.
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66. Plaintiff Mrs. Pina is unable to engage in speaking engagements.

67. Plaintiff Mr.s Pina is unable to conduct agent referrals and co listings.

68. Plaintiff Mrs. Pina’s Braids shop business has been negatively affected by Defendant’s

actions.

JURISDICTION

69. Plaintiffs are residents of Franklin Lakes, Bergen County, New Jersey.

70. Defendants do business individually and collectively in the State of New Jersey.

71. Each and every defamatory statement sued on was of and concerning plaintiffs, New

Jersey residents. Accordingly, the torts and other causes of action alleged herein had

their effect in the State of New Jersey.

VENUE

72. Venue is properly laid in this Court pursuant to Plaintiffs’ residence in Bergen County,

New Jersey.

PARTIES

73. Plaintiff Cesar Pina is a New Jersey resident residing in the Borough of Franklin Lakes,

County of Bergen, and State of New Jersey.

74. Plaintiff Jennifer Pina is a New Jersey resident residing in the Borough of Franklin

Lakes, County of Bergen, and State of New Jersey.

75. Defendant, Anthony Robinson, is, upon information and belief, a California resident with

an address of 1330 South Sante Fe Avenue, Unit 201, 90021. By virtue of his committing

tortious acts in the State of New Jersey, he is subject to the jurisdiction of the State of

New Jersey.
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76. Defendants, Tony the Closer LLC, is, upon information and belief, a North Carolina

business with a principal place of business located at 13200 Strickland Road, Raleigh,

North Carolina. By virtue of doing business in the State of New Jersey and committing

tortious acts in the State of New Jersey, Tony the Closer LLC is subject to the jurisdiction

of the State of New Jersey.

77. Defendant I Close Deals LLC is, upon information and belief, a North Carolina business

with a principal place of business located at 13200 Strickland Road, Raleigh, North

Carolina. By virtue of doing business in the State of New Jersey and committing tortious

acts in the State of New Jersey, Defendant I Close Deals, LLC, is subject to the

jurisdiction of the State of New Jersey.

78. Defendant Rona Proof LLC is, upon information and belief, a North Carolina business

with a principal place of business located at 13200 Strickland Road, Raleigh, North

Carolina. By virtue of doing business in the State of New Jersey and committing tortious

acts in the State of New Jersey, Defendant Rona Proof LLC is subject to the jurisdiction

of the State of New Jersey.

79. Defendant Real Estate Rico, LLC is, upon information and belief, a North Carolina

business with a principal place of business located at 13200 Strickland Road, Raleigh,

North Carolina. By virtue of doing business in the State of New Jersey and committing

tortious acts in the State of New Jersey, Defendant Real Estate Rico LLC is subject to the

jurisdiction of the State of New Jersey.

80. Defendant Nichole Lynel, LLC is, upon information and belief, a North Carolina business

with a principal place of business located at 13200 Strickland Road, Raleigh, North

Carolina. By virtue of doing business in the State of New Jersey and committing tortious
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acts in the State of New Jersey, Defendant Rona Proof LLC is subject to the jurisdiction

of the State of New Jersey.

COUNT I

Defamation and Slander

Plaintiffs incorporate by reference all forgoing paragraphs of this Complaint, as if fully set forth

therein.

81. Defendant Tony Robinson falsely asserts that Plaintiffs scammed investors through an

investment scheme.

82. Defendant Tony Robinson falsely asserts that Plaintiff Cesar owes, “over $900,000 to a

man who passed away.”

83. Defendant Tony Robinson falsely asserts that Plaintiff Cesar writes bad checks to

investors.

84. There is no basis in fact for Defendant’s endless stream of malicious false statements

outlined above.

85. There was never any basis in fact for any of these accusations or inferences.

86. The statements made by Defendant Robinson concerning Plaintiffs were malicious,

reckless, and/or negligently made, and had the purpose and effect of damaging and

injuring each individual Plaintiff’s good name and reputation in the eyes of the public,

and Plaintiffs’ business interests and partners.

87. The statements made by Defendant Robinson were broadcast to thousands of third parties

by Defendant using his social media platforms, including without limitation Defendant’s

accounts and/or handles on YouTube, Instagram, and Twitter.
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88. The statements made by Defendant Robinson concerning Plaintiffs were defamatory and

slanderous per se.

89. Prior to these communications by Defendant Robinson, Plaintiffs had maintained and

enjoyed a distinguished and unblemished reputation for honesty and integrity with the

public and with their business interests and partners.

90. Plaintiffs’ reputation has been irreparably harmed by the defamatory statements made by

Defendant and by the wrongful and illegal actions falsely attributed to Plaintiffs by

Defendant Robinson.

91. Plaintiffs have suffered damages and are entitled to recover compensatory damages in the

amount of $10,000,000.00 and punitive damages in an amount to be determined by the

Court from Defendant Robinson as a result of the malicious and reckless false statements

and accusations Defendant made against them.

92. Based on the forgoing, Plaintiffs are substantially likely to prevail on the merits in this

action.

93. Plaintiffs will be substantially and irreparably harmed without injunctive relief to address

the defamation by Defendant.

94. The equities strongly favor Plaintiffs, and any harm to Defendant will be greater if the

restraints were denied than Defendant would suffer if the restraints were granted.

COUNT II

Claim for Tortious Interference with Prospective Business Relationships

95. Plaintiffs incorporate by reference all forgoing paragraphs of this Complaint, as if fully

set forth therein.
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96. Plaintiffs Cesar Pina and Jennifer Pina had existing ventures with numerous businesses

including real estate partnerships, a TV show, a ride along event, and other real estate

related business transactions based upon Plaintiffs’ reputation for honesty and integrity

with the public and with their business partners.

97. Defendants’ false and defamatory statements concerning Plaintiffs have damaged their

reputation for honesty and integrity with the public and with his business partners.

98. This has harmed Plaintiffs’ economic and/or contractual relationships with their existing

business partners by reducing the value of their endorsements as a direct and proximate

result of Defendant’s malicious and/or reckless harm to Plaintiffs’ reputation and public

image.

99. Plaintiffs are entitled to recover compensatory damages in the amount of $10,000,000.00

and punitive damages in an amount to be determined by the Court from Defendants as a

result of Defendant’s interference with their business relationships.

COUNT III

Claim for Tortious Interference with Business Relationships

100. Plaintiffs incorporate b

Case Info

Judge

Anthony R Suarez Track Judge’s New Case

Case No.

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Document Filed Date

February 06, 2024

Case Filing Date

November 13, 2023

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Motion,Ex Parte: Pina Cesar Vs Robinson Anthony

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