Defendant Todd Kaplan and his co-conspirators defrauded Plaintiff Francine Shulman and her companies, stealing her interest in a cannabis cultivation operation that Defendants admitted could have become one of the world’s largest by 2019. Ms. Shulman, an experienced farmer in Santa Barbara County, invested in the Iron Angel Ranch in 2014, with plans to cultivate organic produce and medical cannabis. By 2017, she expanded her operation and positioned herself to take advantage of California’s evolving cannabis laws, which presented an opportunity to scale her business significantly. In June 2017, Ms. Shulman met Todd Kaplan, the founder and CEO of Vertical Brands, who immediately recognized the value of her business. Kaplan, a convicted felon with a history of fraud, had been indicted on multiple charges, including healthcare fraud and conspiracy to