Restricted stock Certificate
In this case, the certs became all but inert compost.
Useless.
6
and course of business alleged herein.
DEFENDANTS
13.
Michael
A. Affa, 34, resides in Toms River, New Jersey. Michael Affa is
Andrew Affa’s cousin
.
14.
Andrew J. Affa, 30, resides in Huntington Station, New York.
Andrew Affa is
Michael Affa’s cousin
.
15.
Mitchell H. Brown, 49
, resides in Long Branch, New Jersey.
16.
Christopher R. Putnam, 37, resides in Charleston, South Carolina.
17.
Christop
her G. Nix, 34, resides in Charles
ton, South Carolina.
THE SCHEME TO MANIPULATE
THE PRICE AND TRADING OF
AND TO PUMP AND DUMP AMOGEAR STOCK
18.
Beginning
or before August 2012
,
and continuing to
at least February 2014,
defendants Mike Affa, Andrew Affa,
Brown, Putnam, and Ni
x planned and participated in
a
scheme to manipulate the stock price and trading of, and to pump and dump, the publicly traded
stock of Amogear. Amogear was a shell company that had been acquired and controlled
by the
CI, who subsequently acted
in an undercover capacity
in concert
wit
h special agents of the
FBI.
In August 2012
the CI held in his office the physical stock certificate for 40,000,000 restricted
shares of Amogear stock.
Because the 40,000,000 shares of stock were restricted they could not
readily be bought and sold.
The
stock certificate
for the shares
had been issued in the name of an
associate of the CI, but
had been
del
ivered to the CI's office by a
tra
nsfer agent pursuant to the
associate’s
instruction
s
. The CI also held a convertible promissory note
through a compan
y he
owned and
con
trolled
which was converted into 17,000,000 purportedly unrestricted shares
of
Amogear stock
between March 19, 2012 and October 29, 2013.
Unrestricted shares of stock
were able to be bought by and sold to investors in the marketplace
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