MEMORANDUM DECISION AND ORDER I. INTRODUCTION Pending before the Court is Plaintiff’s motion for entry of a default judgment against Defendants MyPayrollHR, LLC, Michael Mann, Valuewise Corporation, and Ross Personnel Consultants, Inc. (collectively “Defaulting Defendants” or “Mann Defendants”). See Dkt. No. 77.1 II. BACKGROUND Plaintiff filed this action against the Defaulting Defendants and others to recover damages it suffered as a result of the Defaulting Defendants’ actions. The Defaulting Defendants failed to answer or otherwise defend this action within the required time frame; and, therefore, Plaintiff requested entry of a Clerk’s default, see Dkt. No. 68, which the Clerk of the Court entered on January 23, 2020, see Dkt. No. 70. Plaintiff now moves for entry of a default judgment against the Defaulting Defendants in the amount of $108,985,455.04, which is comprised of the following: (1) general damages in the amount of $26,418,517.04; (2) consequential damages in the amount of $27,575,000.00; (3) punitive damages in the amount of $52,837,034.08; and (4) prejudgment interest in the amount of $2,154,903.92 through February 24, 2020. See Dkt. No. 77-1 at 24.2 In addition, Plaintiff seeks post-judgment interest at a per diem rate of 1.47 percent. See id. Plaintiff is a national financial services company that focuses on processing automated clearing house (“ACH”) transactions and providing related services for the payroll industry. See Dkt. No. 77-1 at 5 (citation omitted). Plaintiff’s ACH system, when used correctly, provides the electronic mechanism through which funds from employers’ bank accounts are withdrawn and then ultimately deposited into the bank accounts of the employers’ employees. See id. (citation omitted). Payroll processors, i.e., the remarketers, contract with Plaintiff to process tens-of-billions of dollars annually in ACH transactions for tens-of-thousands of employers and millions of employees. See id. (citation omitted). According to Plaintiff, its patented ACH transaction process works as follows: A payroll processor, such as Defendant MyPayrollHR, sends a digital specification batch file to Plaintiff’s automated system, which file includes, among other things, (1) bank and account information of each of the payroll processor’s employer-clients; (2) the amount of deposits to be made by each of the payroll processor’s employer-clients into Plaintiff’s settlement account at Plaintiff’s bank; and (3) the amounts to be directly deposited from Plaintiff’s settlement account to each of the payroll processor’s employer-clients’ employees. See id. at 6 (citation omitted). This batch file also includes the bank information for Plaintiff’s settlement account, albeit through the use of a fictitious account number to protect Plaintiff, so that funds from the payroll processor’s employer-clients transfer directly from their accounts to Plaintiff’s settlement account. See id. (citation omitted). Once Plaintiff’s system receives the batch file from the payroll processor and the file is “balanced,” i.e., the amounts to be withdrawn from the employer-clients equals the amounts to be deposited into the employees’ accounts, Plaintiff’s system automatically initiates the transfer of funds from the employer-clients’ accounts to Plaintiff’s settlement account as delineated in the specifications batch file on the “settlement date” indicated in the file. See id. (citation omitted). Banks have up to two banking days to reject ACH transactions. See id. citation omitted). Plaintiff contends that it had an 11-year contractual relationship with Defendant MyPayrollHR. See Dkt. No. 77-1 at 6. Defendant MyPayrollHR is an employer-outsource payroll processing company that contracts with employers to manage the employers’ payroll. See id. (citation omitted). Defendant MyPayrollHR is one of Plaintiff’s clients, i.e., a remarketer. See id. (citation omitted). The business relationship between Plaintiff and Defendant MyPayrollHR is governed by two written agreements: (1) the Rules, Regulations, and Binding Policies (the “Rules”) and (2) the Cachet Terms and Conditions (the “Terms”), collectively the “Agreement.” See id. at 6-7. Defendant MyPayrollHR executed the most recent versions of these documents on May 1, 2019. See id. (citation omitted). According to Plaintiff, pursuant to the Agreement, Defendant MyPayrollHR agreed, among other things, to the following: (1) To use Plaintiff’s ACH settlement and processing services only for payroll-related transactions and not to use Plaintiff’s services for non-payroll-related transactions, such as company-to-company transfers (Ex. B (Terms) at Introduction Para., §§1B, 2B, 7F); (2) Not to use Plaintiff’s ACH settlement and processing services in a way that violates the laws of the United States (Ex. A (Rules) §1D; (3) Not to allow unauthorized access to Plaintiff’s ACH settlement and processing services (id. §5B; Ex. B (Terms) §1A); (4) To provide accurate information in Plaintiff’s specifications batch files (Ex. A (Rules) §4E); and (5) To pay Plaintiff for all credit entries directed by MyPayrollHR that were made by Plaintiff on MyPayrollHR’s behalf (id. §8A) (collectively, the Security Provisions). See Dkt. No. 77-1 at 7. The Agreement also provides as follows: “’4.F. Offset and Security Interest. To secure the payment and performance of [MyPayrollHR]‘s obligations set forth herein, [MyPayrollHR] grants CACHET a security interest in the funds collected by [MyPayrollHR] into the Settlement Account, as collateral for the obligations contained in this Remarketer Agreement, and any other agreement Remarketer has signed with CACHET.’” See id. (quoting [Ex. A (Rules)] §4F). According to Plaintiff, in or about late August or early September 2019, unbeknownst to Plaintiff at the time, Defendants MyPayrollHR and Mann manipulated Plaintiff’s specifications batch files to cause in excess of $26 million to be routed to MyPayrollHR, the Mann Entities, and other entities (such as non-parties Millennium and P2Bi) to which Defendant Mann or Defendant MyPayrollHR apparently owed an obligation. See id. at 8 (citation omitted). This occurred by way of two separate sets of transactions and two different means of theft — one for more than $19 million (the “$19 Million”) and another for more than $7 million (the “$7 Million”) for a total of $26 million (the “$26 Million”). See id. (citation and footnote omitted). Specifically, with regard to the $19 Million, Plaintiff alleges that Defendants Mann and MyPayrollHR used Plaintiff’s settlement account for non-payroll purposes to steal the $19 Million directly from Plaintiff using classic kiting techniques. See Dkt. No. 77-1 at 8 (citation omitted). According to Plaintiff, Defendants Mann and MyPayrollHR did this by manipulating Plaintiff’s specifications to make it appear as if the $19 Million was being transferred from various entities that Defendant Mann controlled to Plaintiff’s settlement account and that the same amount was then being transferred from Plaintiff’s settlement account to various other entities, i.e., some of the Mann Entities. See id. (citation omitted). Plaintiff contends that, in reality, no funds were transferred to Plaintiff’s settlement account because the accounts from which the funds were supposed to be transferred, i.e., some of the Mann Entities’ accounts, were frozen; and the $19 Million, which was Plaintiff’s money, was transferred from Plaintiff’s settlement account to various accounts that the Defaulting Defendants controlled, which accounts purportedly were also then frozen by the “receiving” banks. See id. (citation omitted). Furthermore, Plaintiff claims that Defendant MyPayrollHR’s specifications appeared to show that the entire $19 Million that was to be credited to Plaintiff’s settlement account was to come from various accounts at Pioneer Bank, i.e., routing number 021000322, called “Primacy-Pioneer,” “Optix-Pioneer,” “Apogee-Pioneer,” “Ross Consultants,” and “OptumInsight” (collectively the “Mann Originating Accounts”). See id. (citation omitted). Plaintiff’s ACH system automatically executed the instructions indicated in the specifications that Defendant MyPayrollHR and Mann provided. See id. Specifically, on Friday, August 30, 2019, the various accounts at Pioneer Bank making up the $19 Million, i.e., the Mann Originating Accounts, were debited, and the $19 Million was credited to Plaintiff’s settlement account (the “Collection Transactions”). See id. (citation omitted). Then, according to Plaintiff, on Friday, August 30, 2019, and Tuesday, September 3, 2019, as instructed in the specifications that Defendants MyPayrollHR and Mann prepared, Plaintiff’s settlement account was automatically debited and the various accounts indicated in the specifications were automatically credited. See id. Significantly, Monday, September 2, 2019, was Labor Day, a bank holiday, which did not count toward the two banking days that Pioneer Bank had to reject the Collection Transactions. See id. (citation omitted). According to Plaintiff, the $19 Million was then deposited as follows (the “Disbursement Transactions”): Entity/Account Name Amount Bank Heutmaker $7,713,026.23 Bank of America ValueWise Corporation $7,661,261.57 Bank of America Weitz & Associates $669,746.99 Well Fargo Weitz & Associates $655,006.76 Pioneer Cloud Inc. $660,045.85 Pioneer Millennium Funding $415,973.00 Key Bank P2B Inc. $849,357.19 Wells Fargo FPG Bofl $574,758.15 Bank of Internet TOTAL $19,199,175.74 See Dkt. No. 77-1 at 9-10 (citation omitted). Plaintiff refers to the accounts listed above collectively as the “Mann Receiving Accounts” because these accounts received the $19 Million as a result of the Disbursement Transactions. See id. at 10. According to Plaintiff, on September 4, 2019, after its settlement account had already been debited, and the Mann Receiving Accounts already credited, for the Disbursement Transactions, Pioneer Bank rejected the Collection Transactions purportedly within its two-day window because, according to the returns that Pioneer Bank issued, the Mann Originating Accounts were frozen. See id. (citation omitted). When Plaintiff received notice of Pioneer Bank’s rejection of the Collection Transactions for the frozen accounts, it immediately sought to reverse the Disbursement Transactions and thereby claw back the $19 Million that went to the Mann Receiving Accounts. See id. However, Plaintiff learned that each of the Mann Receiving Accounts had purportedly been frozen by the relevant “receiving” banks, i.e., Pioneer Bank, Bank of America, Wells Fargo, Key Bank and Bank of Internet. See id. Thus, Plaintiff could not reverse the Disbursement Transactions. See id. (citation omitted). Plaintiff further states that, because the Mann Originating Accounts were frozen, no funds were actually transferred to Plaintiff’s settlement account. See id. Thus, to effectuate the Disbursement Transactions, funds were transferred from Plaintiff’s settlement account to the Mann Receiving Accounts. See id. (citation omitted). However, Plaintiff never received the $19 Million from the Mann Originating Accounts or any other source. See id. With regard to the $7 Million theft, Plaintiff asserts that Defendants Mann and MyPayrollHR diverted the $7 Million from MyPayrollHR’s employer-clients, which was supposed to be transferred to Plaintiff to be used for payroll for the employees of Defendant MyPayrollHR’s employer-clients. See Dkt. No. 77-1 at 10 (citation omitted). Specifically, Plaintiff contends that Defendants Mann and MyPayrollHR altered account information in Plaintiff’s ACH specifications so that the $7 Million, which belonged to Defendant MyPayrollHR’s employer-clients, was diverted from their accounts and deposited in a bank account that Defendant MyPayrollHR and Mann controlled at Pioneer Bank (the “MPHR Account”), instead of being deposited in Plaintiff’s settlement account as the Agreement required. See id. (citation omitted). Then, pursuant to the ACH specifications which Defendants Mann and MyPayrollHR created, the employees’ accounts were credited via direct deposits in the amount of $7 million. See id. (citation omitted). Pioneer Bank then froze the MPHR Account, purportedly within the two bank day rejection window, which meant that the $7 million of credits to the employees’ accounts were not funded by Defendant MyPayrollHR, but instead came from Plaintiff. See id. (citation omitted). Plaintiff asserts that Pioneer Bank is purportedly still in possession of the $7 Million. See id. (citation omitted). On September 3, 2019, Plaintiff’s Director of Operations called Defendant MyPayrollHR and spoke with one of its representatives and was informed that Defendant Mann was at Pioneer Bank attempting to have Pioneer Bank release funds to Plaintiff. See id. (citation omitted). On that same day, Plaintiff’s Director of Sales spoke with Defendant MyPayrollHR’s Chief Financial Officer, who advised him that Pioneer Bank would release the funds shortly See id. (citation omitted). However, when Plaintiff’s President spoke with two Pioneer Bank officers, they refused to provide information on the frozen account and blamed Defendant Mann for the situation. See id. (citation omitted). Finally, on September 4, 2019, Plaintiff’s representatives called Defendant MyPayrollHR and spoke with Defendant Mann, who said he would call them back in a few minutes. See id. at 12 (citation omitted). Defendant Mann never called back, and Defendant MyPayrollHR thereafter advised its employer-clients that it had ceased operations effective immediately. See id. (citation omitted). Finally, Plaintiff asserts that the Defaulting Defendants stole the $26 Million from it and that, as a result, it was forced to use its own funds to cover the $26 Million loss. See id. (citation omitted). In addition, Plaintiff borrowed $5.050 million from National Services, Inc. (“NSI”) and another $1 million from HB Foundation pursuant to Secured Promissory Notes executed on or about October 22, 2019. See id. at 13-14 (citation omitted). Furthermore, on October 23, 2019, Bankcorp notified Plaintiff that it had (1) terminated its Payroll Processing ODFI Agreement with Plaintiff, thus terminating Plaintiff’s ability to originate ACH transactions, (2) frozen all of Plaintiff’s accounts, including its settlement account that had more than $100 million in it, which funds were transferred by remarketers and employers, and its operating account, and (3) swept more than $5 million from Plaintiff’s operating account. See id. at 14 (citation omitted). Plaintiff contends that, as a result of the freeze on these accounts and its inability to process ACH transactions, it was effectively out of the ACH processing business and is no longer operating in such capacity. See id. (citation omitted). Moreover, Plaintiff asserts that, as a result of Bancorp’s freezing its accounts, which resulted in Plaintiff’s inability to process its ACH transactions, on or around October 23, 2019, various employers and employees filed class action claims for damages against it. See id. According to Plaintiff, these class actions generally allege damages for fees and penalties that employers and employees incurred as a result of overdrawn accounts, damages for being unable to pay bills and care for their families, among other things, as well as more general damages for negligence, unjust enrichment, and violation of California’s unfair competition laws. See id. As a result, Plaintiff filed a voluntary petition for relief under Chapter 11 of the Bankruptcy Code in the United States Bankruptcy Court for the Central District of California, Los Angeles Division, on January 21, 2020. See id. at 15. Based on these allegations, Plaintiff asserted five causes of action against the Defaulting Defendants and others: (1) breach of contract, (2) fraud, (3) conversion, (4) unjust enrichment, (5) a RICO claim, and (6) a RICO conspiracy claim. See, generally, Dkt. No. 1, Complaint. Plaintiff moves for entry of a default judgment as follows: (1) against Defendant MyPayrollHR for breach of contract; (2) against Defendants MyPayrollHR and Mann for fraud; (3) against all the Defaulting Defendants for conversion; and (4) against all the Defaulting Defendants for unjust enrichment. See Dkt. No. 77-1 at 16-21. III. DISCUSSION A. Standard of review “Rule 55 of the Federal Rules of Civil Procedure provides a two-step process for obtaining a default judgment.” Priestley v. Headminder, Inc., 647 F.3d 497, 504 (2d Cir. 2011). First, under Rule 55(a), the plaintiff must obtain a clerk’s entry of default. See Fed. R. Civ. P. 55(a) (providing that, “[w]hen a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter the party’s default”); N.D.N.Y. L.R. 55.1 (requiring a party seeking a clerk’s entry of default to “submit an affidavit showing that (1) the party against whom it seeks a judgment of affirmative relief is not an infant, in the military, or an incompetent person (2) a party against whom it seeks a judgment for affirmative relief has failed to plead or otherwise defend the action…and (3) it has properly served the pleading to which the opposing party has not responded”). Second, under Rule 55(b), the plaintiff may apply for entry of a default judgment by the clerk, “[i]f the plaintiff’s claim is for a sum certain” or by the court “[i]n all other cases[.]” Fed. R. Civ. P. 55(b)(1), (2); N.D.N.Y. L.R. 55.2(b) (providing, among other things, that “ [a] party shall accompany a motion to the Court for entry of a default judgment pursuant to Fed. R. Civ. P. 55(b)(2), with a clerk’s certificate of entry of default…, a proposed form of default judgment, and a copy of the pleading to which no response has been made”). Furthermore, N.D.N.Y. L.R. 55.2(b) requires that “[t]he moving party…also include in its application an affidavit of the moving party or the moving party’s attorney setting forth facts as required by L.R. 55.2(a).” N.D.N.Y. L.R. 55.2(b). These required facts include the following: (1) “The party against whom it seeks judgment is not an infant or an incompetent person;” (2) “The party against whom it seeks judgment is not in the military service, or if unable to set forth this fact, the affidavit shall state that the party against whom the moving party seeks judgment by default is in the military service or that the party seeking a default judgment is not able to determine whether or not the party against whom it seeks judgment by default is in the military service;” (3) “The party has defaulted in appearance in the action;” (4) “Service was properly effected under Fed. R. Civ. P. 4;” (5) “The amount shown in the statement is justly due and owing and that no part has been paid except as set forth in the statement this Rule requires;” and (6) “The disbursements sought to be taxed have been made in the action or will necessarily be made or incurred.” N.D.N.Y. L.R. 55.2(a). A court has significant discretion to consider numerous factors in deciding whether to grant a default judgment, including the following: “(1) whether the grounds for default are clearly established; (2) whether the claims were pleaded in the complaint, thereby placing defendants on notice of the relief sought, see Fed. R. Civ. P. 54(c) (providing that “[a] default judgment must not differ in kind from, or exceed in amount, what is demanded in the pleadings”); Enron Oil Corp., 10 F.3d at 95-96; cf. King v. STL Consulting, LLC, No. 05 CV 2719, 2006 WL 3335115, *4-5 (E.D.N.Y. Oct. 3, 2006) (holding that Rule 54(c) is not violated when a court awards damages that accrued during the pendency of a litigation, so long as the complaint provided notice that the plaintiff may seek such damages); and (3) the amount of money potentially involved — the more money involved, the less justification for entering default judgment. See Hirsch v. Innovation Int’l, Inc., No. 91 Civ. 4130 (MJL), 1992 WL 316143, *2 (S.D.N.Y. Oct. 19, 1992).” Jiangsu Gtig Esen Co., Ltd v. Am. Fashion Network, LLC, No. 5:20-CV-222 (MAD/ATB), 2020 WL 3453643, *3 (N.D.N.Y. June 24, 2020). The plaintiff bears the burden of establishing its entitlement to recovery. See Greyhound Exhibitgroup, Inc. v. E.L.U.L. Realty Corp., 973 F.2d 155, 158 (2d Cir. 1992). Although the defendants are deemed to have admitted all well-pleaded factual allegations in the complaint pertaining to liability, they are not deemed to have admitted legal conclusions or allegations relating to damages. See id. Thus, it is the plaintiff’s burden to demonstrate that the uncontroverted facts establish each defendant’s liability on each cause of action asserted. See Finkel v. Romanowicz, 577 F.3d 79, 84 (2d Cir. 2009). In determining whether the plaintiff has met its burden, the court draws “all reasonable inferences in its favor.” Id. (quoting Au Bon Pain Corp. v. Artect, Inc., 653 F.2d 61, 65 (2d Cir. 1981) (noting that, where a party moves for a default judgment after another party’s default, the moving party is “entitled to all reasonable inferences from the evidence offered”)). If the plaintiff is able to establish each defendant’s liability, then the plaintiff must establish its entitlement to damages to a “‘reasonable certainty.’” Gunawan v. Sake Sushi Rest., 897 F. Supp. 2d 76, 83 (E.D.N.Y. 2012) (quotation omitted). “[A]lthough the court must ensure that there is a basis for the damages specified in a default judgment, it may, but need not, make the determination through a hearing.” Fustok v. Conticommodity Servs., Inc., 122 F.R.D. 151, 156 (S.D.N.Y. 1988) (collecting cases), aff’d, 873 F.2d 38 (2d Cir. 1989). “Rather,…, the court may rely on detailed affidavits or documentary evidence…to evaluate the proposed sum.” Id. (citations omitted). In this case, Plaintiff has complied with the procedural requirements necessary for entry of a default judgment set forth in Rule 55(b) of the Federal Rules of Civil Procedure and Local Rule 55.2. Specifically, Plaintiff filed the Clerk’s entry of default, see Dkt. No. 77-10, a proposed default judgment, see Dkt. No. 77-11, a declaration setting forth all of the required information, see Dkt. No. 77-5, and a certificate of service demonstrating that service was properly effected on the Defaulting Defendants, see Dkt. No. 77. B. Causes of action 1. First cause of action — breach of contract against Defendant MyPayrollHR “Under New York law, the elements of a breach of contract claim are (1) the existence of an agreement; (2) adequate performance of the contract by the plaintiff; (3) breach of contract by the defendant; and (4) damages.” Swan Media Group, Inc. v. Staub, 841 F. Supp. 2d 804, 807 (S.D.N.Y. 2012) (citing Eternity Global Master Fund Ltd. v. Morgan Guar. Trust Co., 375 F.3d 168, 177 (2d Cir. 2004); Johnson v. Nextel Comm’s. Inc., 660 F.3d 131, 142 (2d Cir. 2011)). Plaintiff argues that there is no question that the factual allegations in its complaint establish a breach of contract. First, Plaintiff and Defendant MyPayrollHR entered into the Agreement. See Dkt. No. 77-1 at 17. Second, Plaintiff performed all of its obligations under the Agreement. See id. Third, the evidence clearly demonstrates that Defendant MyPayrollHR breached the Agreement’s Security Provisions by fraudulently manipulating Plaintiff’s specifications batch files to cause the $19 Million to be diverted from Plaintiff to the Defaulting Defendants and others and the $7 Million to be diverted from MyPayrollHR’s employer-clients to the Defaulting Defendants. See id. In fact, Plaintiff contends that Defendant Mann, in a criminal action in this District, United States v. Mann, 1:20-CR-199 (LEK), admitted that he made a calculated “‘decision to route MyPayrollHR’s clients’ payroll payments to an account at Pioneer [Bank] instead of directly to Cachet.’” See id. (quoting Farber Aff., Ex. 2 (Wabby Aff.) 15).3 Finally, Plaintiff asserts that it suffered damages in the amount of $26,418,517.04 as a result of Defendant MyPayrollHR’s breach of the Agreement since Defendants Mann and MyPayrollHR caused Plaintiff’s ACH system to transfer the $26 Million to various accounts without actually providing $26 million to Plaintiff to fund the transfers, thus causing Plaintiff to fund the transfers with its own money. See id. Based on the allegations in the complaint, the Court finds that Plaintiff has plausibly alleged that Defendant MyPayrollHR breached the contractual agreement that it had with Plaintiff as evidenced by Defendant MyPayrollHR’s execution of the most recent versions of the “Rules, Regulations, and Binding Policies” (the “Rules”) and the “Cachet Terms and Conditions” (the “Terms”). Therefore, the Court grants Plaintiff’s motion for entry of a default judgment against Defendant MyPayrollHR with regard to Plaintiff’s breach of contract claim on the issue of liability. 2. Second cause of action — fraud against Defendants MyPayrollHR and Mann With regard to its second cause of action for fraud against Defendants MyPayrollHR and Mann, Plaintiff asserts that, to prevail on such a claim under New York law, a plaintiff must show “‘(1) a material misrepresentation or omission of fact, (2) made with knowledge of its falsity, (3) with an intent to defraud, and (4) reasonable reliance on the part of the plaintiff, (5) that causes damages to the plaintiff.’” See Dkt. No. 77-1 at 17-18 (quoting Allstate Ins. Co. v. Rozenberg, 2009 U.S. Dist. LEXIS 132654 at *9-10 (E.D.N.Y. Jan. 26, 2009)). Plaintiff asserts that each of these elements is satisfied. As to the first element, Plaintiff states that the specifications batch file contained two sets of material misrepresentations — first, that the $19 Million would be transferred from various entities, including Defendant MyPayrollHR, to Plaintiff’s settlement account, and that the same $19 million would be transferred from the settlement account to various other entities; and, second, that Defendant MyPayrollHR’s employer-clients would deposit $7 million into Defendant MyPayrollHR’s account, albeit in breach of the Agreement, since the funds should have been deposited into Plaintiff’ settlement account and the employer-clients’ employees would be paid $7 million for Defendant MyPayrollHR’s account. See id. at 18. Plaintiff asserts that both of these representations were false because (1) the $19 Million never went to Plaintiff’s settlement account, but the same amount was diverted from the settlement account to accounts that the Defaulting Defendants and others controlled and (2) the $7 Million was never deposited in Plaintiff’s settlement account but instead was diverted to accounts that the Defaulting Defendants and other entities such as non-parties Millennium and P2Bi controlled. See id. With regard to the second element, Plaintiff contends that Defendants MyPayrollHR and Mann knew the misrepresentations were false because they provided the fraudulent information to Plaintiff through the specification batch files. See id. In fact, Plaintiff asserts that, in United States v. Mann, Defendant Mann admitted to borrowing large sums of money “under false pretenses” and specifically admitted to stealing and fraudulently obtaining the $7 Million. See id. (citing Farber TRO Decl.
