Mario's name pops up again, along with Pearl and other assorted DOM characters.
PAUL, HASTINGS, JANOFSKY & WALKER LLP
CHRISTOPHER H. McGRATH (SB#149129)
(chrismcgrath@paulhastings.com)
DANIEL J. LICKEL (SB# 224510)
(daniellickel@paulhastings.com)
3579 Valley Centre Drive, San Diego, CA 92130
Telephone: (858) 720-2500
Facsimile: (858) 720-2555
Attorneys for Plaintiff
Black Forest International, LLC
FILED
Clerk of the Superior Court
JUN 21 2007
By: M. GARLAND, Deputy
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN DIEGO
NORTH COUNTY BRANCH
BLACK FOREST INTERNATIONAL. LLC, a Delaware limited liability company,
Plaintiffs.
v.
LEGENT CLEARING LLC, a Delaware limited liability company; CAMBRIA CAPITAL, LLC, a California limited liability company, FIRST PUBLIC SECURITIES TRANSFER CORPORATION, an Oregon limited liability company, DAVID KORMAN A.K.A. MARK PEDLEY, BRANCH VINEDRESSER, DR. TZEMACH “BEN” DAVID NETZER KOREM, PHD., an individual, GAMBOA PROPERTIES, INC., an Oregon corporation, PEARL ASIAN MINING INDUSTRIES, INC., a Wyoming corporation, E. PEARL ASIAN, A.K.A. ELVIRA GAMBOA, A.K.A. BAE KATIGUMAN, an individual, PHILIPPINES ROYAL OIL AND ALTERNATIVE ENERGY COMPANY, INC., FORMERLY KNOWN AS PHILIPPINES GOLD MINING CORPORATION, a Wyoming corporation, GLOBAL DEVELOPMENT PARTNERS, LLC, a Nevada limited liability company, RANDY LITHICUM A.K.A. RANDY SAWYER, an individual, MARIO PINO, an individual, STANDARD REGISTRAR & TRANSFER COMPANY, INC., a Utah corporation, AGN ASSOCIATES & STOCK TRANSFER SERVICES, LLC, a Nevada limited liability company, MOHAMAD TOUFIC NEHMEH, an individual, DEPOSITORY TRUST AND CLEARING CORPORATION, a New York corporation, ABEGAIL DORMITORIO, an individual, RANDOLF VILLANUEVA, an individual, JEFFREY ALAN BOSAW, an individual, and DOES 1 through 50, inclusive
Defendants. Case No. 37-2007-00052133-CU-BC-NC
PLAINTIFF BLACK FOREST INTERNATIONAL, LLC’S FIRST AMENDED COMPLAINT FOR
(1) BREACH OF CONTRACT
(2) BREACH OF FIDUCIARY DUTY-LEGENT & CAMBRIA;
(3) NEGLIGENCE;
(4) DECLARATORY RELIEF;
(5) SPECIFIC PERFORMANCE;
(6) INTENTIONAL INTERFERENCE WITH CONTRACT;
(7) BREACH OF FIDUCIARY DUTY – PAIM OFFICERS;
(8) AIDING AND ABETTING;
(9) VIOLATION OF ARTICLE 8 OF THE UNIFORM COMMERCIAL CODE; AND
(10) CONVERSION
Complaint Filed: April 25, 2007
Plaintiff Black Forest International, LLC, (“BFI”), hereby alleges as follows:
NATURE OF THE ACTION
1. This First Amended Complaint seeks to unfreeze the brokerage account of Plaintiff Black Forest International, LLC, which has been frozen as a result of the Defendants wrongful conduct, including the refusal to issue a dividend that BFI is owed. BFI seeks injunctive relief releasing its brokerage account and ordering issuance of the dividend, and monetary damages caused by Defendants’ wrongful conduct.
2. BFI bought common stock shares in Pearl Asian Mining Industries, Inc. (“PAIM”), from Global Development Partners (“GDP”). BFI is informed and believes that GDP’s president is Randy Lithicum. BFI was introduced to GDP and Mr. Lithicum by Mario Pino. Unbeknownst to BFI at the time, Pino and Lithicum were part of a complicated network of securities scam operators intending to defraud BFI through a scheme of manipulating, first, the transfer of the purchased PAIM stock certificates and, ultimately, a dividend owed on the PAIM stock.
3. BFI is further informed and believes that the scheme involved the active participation of a transfer agent named David Korman, who goes by an assortment of aliases and who initially gained notoriety as a founder of a fictitious country known as the Dominion of Melchezedek. BFI is informed and believes that Elvira Pearl Asian, the namesake of PAIM and a self-represented executive of PAIM, is involved and also goes by a variety of pseudonyms and may be the wife of David Korman. BFI is further informed and believes that these individuals have been named as defendants in multiple civil complaints around the country and they are the object of investigations by federal regulating agencies.
