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Material Misrepresentation Documented

Case Summary:
Unlawful Retention of Funds Based on Material Misrepresentation

This digital case file documents the unlawful withholding of $194,253.11 in legitimate business funds by Truist Bank for over 13 months. The bank's justification relies on a demonstrably false statement regarding the origin of wire transfers, directly contradicted by the bank's own transaction records.

Duration
413 Days
Amount Withheld
$194,253.11
Primary Claim
Fraud / Conversion

Material Evidence

The following exhibits demonstrate the contradiction between Truist Bank's stated justification for withholding funds and the objective transaction records.

EXHIBIT ACounsel's Representation

DATE: JAN 6, 2026
"The bank that sent Truist the payment order for $519,832.36—HSBC—demanded that Truist return the wire‑transferred funds."
JK
Justin Kerner, Esq.
Counsel for Truist Bank

Note: Counsel explicitly identifies "HSBC" as the originating bank and the party demanding return of funds.

EXHIBIT BTransaction Record

DATE: DEC 26, 2024
OFFICIAL WIRE RECEIPT
Originating BankKEB HANA BANK
SWIFT CodeKOEXKRSE
Amount$519,832.86

Note: Official wire receipt identifies "KEB Hana Bank" as originator. No reference to HSBC exists in the transaction record.

Legal Analysis

The discrepancy between Counsel's representation (Exhibit A) and the objective transaction record (Exhibit B) constitutes a material misrepresentation of fact. This false statement has been cited as the sole justification for the continued retention of client funds. Under applicable banking regulations and common law principles of conversion, a bank may not rely on demonstrably false assertions to deny a customer access to legitimate deposits.

Procedural History

Chronology of events regarding Account #11800097382844

Funds Received

Legitimate wire transfers totaling $646,006.77 received from Korean partners TYM Corp and Root Corp via KEB Hana Bank.

Account Frozen

Truist blocks the account citing vague "suspicious activity" with $194,253.11 remaining. No specific reason provided to account holder.

Documentation Submitted

Comprehensive documentation of legitimate business activities submitted to Truist. Request for release of funds ignored.

False Statement Made

Truist's counsel claims "HSBC" demanded funds back. This statement contradicts the wire documentation proving KEB Hana Bank was the originator.

Settlement Demand

Fraud discovered. Formal settlement demand issued citing material misrepresentation. Regulatory complaints prepared for filing.

Damages Assessment

Quantifiable harm resulting from unlawful retention of funds.

Direct Financial Damages
Principal Withheld$194,253.11
Interest (13+ Months)~$20,000.00
Legal Fees Incurred~$135,000.00
Subtotal$349,253.11
Business & Punitive Damages
Lost Business Opportunities$150,000.00
Operational Disruption$100,000.00
Punitive Damages (Settlement)$900,000.00
Total Demand$1,750,000.00

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