Amogear, Inc. (fka AMOG)

[scion]

The September 6, 2013 Meeting

11. On or about September 6, 2013, MICHAEL AFFA and ANDREW AFFA met in Boston with the UA and another individual to discuss the Amogear Scheme. Among other things, the group discussed the fact that Amogear did not have any legitimate business operations to speak of.

12. The group also discussed plans to tout Amogear's stock and to dump their own shares in the market. Specifically, they discussed plans ( I ) to deposit and trade Amogear shares in foreign brokerage accounts controlled by MICHAEL AFFA; (2) to build a market in Amogear's stock in order to make it appear as though there was legitimate demand for the stock, while also driving up the share price; and (3) to disseminate news releases and promotional materials about Amogear in order to further drive up the price of the stock.

13. On or about January 23, 2014, MICHAEL AFFA traded approximately 10,000 shares of Amogear stock at a price of approximately 10 cents per share, as part of the effort to create the false appearance of demand for Amogear' s shares.
Hiring Other Promoters to Tout Amogear's Stock

14. In furtherance of the Amogear Scheme, on or about February 6, 2014, BROWN sent $30,000, via a wire transfer in interstate commerce, to A&A Capital LLC, an entity controlled by ANDREW AFFA. A&A Capital LLC then forwarded the $30,000, via a wire transfer in interstate commerce, to Stellar Media Group, LLC, an investor relations and market awareness firm in Central Florida, with a note indicating that the funds were for "Marketing."

Artificially Increasing the Price of Amogear's Stock

15. On or about February 7, 2014, MICHAEL AFFA traded approximately 25,000 Amogear shares at a price of approximately 12 cents per share.

16. On or about February 9, 2014, websites controlled by MICHAEL AFFA, ANDREW AFFA, and BROWN sent out blast e-mails touting Amogear's stock. The e-mails were sent via wire communications in interstate commerce to recipients in Massachusetts and elsewhere, by websites including RisingPennyStocks. com, PennyStockPickAlert.com, and SixFigureStockPicks.com.

17. The e-mails contained multiple statements that MICHAEL AFFA, ANDREW AFFA, and BROWN then and there knew and believed to false and misleading. For example, the emails noted that "Amogear Inc. designs and develops sports apparel for mixed martial arts (MMA), similar fighting styles, and other custom athletic sports. It provides training, competition, lifestyle/sportswear, and equipment products . . . Amogear has already designed and has an entire MMA line on the market ready to sell!" As MICHAEL AFFA, ANDREW AFFA, and BROWN knew, however, Amogear had no real operations or assets to speak of.

18. At approximately 8:30 a.m. on February 10, 2014, the SEC issued an order suspending trading in the securities of Amogear.

19. On or about February 11, 2014, Stellar Media Group, LLC wired $29,975 back to A&A Capital LLC with a note stating: "Deal Canceled Sending Money Back."


Conclusion

20. Based on my knowledge, training and experience and the facts set forth in this affidavit, I have probable cause to believe and I do believe that, from at least August 2013 through February, 2014, MICHAEL AFFA, ANDREW AFFA, and BROWN, with others known and unknown to the U.S. Attorney, conspired to commit wire fraud and securities fraud in violation of 18 U.S.C. § 371.


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