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Tuesday, 07/14/2015 6:22:49 AM

Tuesday, July 14, 2015 6:22:49 AM

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For more than a decade, brazen government informants (“Informants”) with sealed dockets and multiple identities have engaged in an illegal scheme (the “Scheme”) usurping the identities of hundreds of dormant publicly traded companies (Shell Companies). The informants are presently using the names Laura Anthony (Anthony), and Michael Anthony (Pollaccia). Certain market participants only became aware of the government’s use of the Shell Companies after Anthony bragged about her free pass from the FBI to another market participant.

Anthony and Pollaccia operate from the law firm of Legal and Compliance, LLC (the “Firm”), at 330 Clematis Street, Suite 217, West Palm Beach Florida. The Shell Companies are used by corrupt agents in sting operations. In exchange for their assistance, the Informants pocket the proceeds from the sale of the Shell Companies. Pollaccia and Anthony’s operations are intertwined and inseparable and form a common enterprise operating within and outside the state of Florida at the direction of corrupt law enforcement. The Informants have caused more than 200 publicly traded companies to be put into the public markets many of which were used in the most highly publicized enforcement actions of the Securities & Exchange Commission.

Persons reporting the illegal activities of the Informants are targeted, intimidated, or subjected to retaliation at the direction of the corrupt agents. One corrupt agent revealed the identity of a whistleblower reporting the Scheme to the Informants in violation of the Dodd Frank Act and other federal laws.

Agents have improperly used their positions to obtain confidential trade secrets and other information about competitors of the Firm so that the Informants would profit. Securities lawyers and promoters specializing in reverse mergers have been targeted to eliminate the competition of the Informants and enhance the number of defendants produced by the scheme. (See Exhibits 1A – 1J)

Anthony obtains information about issuers, investor relations firms, market makers, transfer agents, securities lawyers, auditors and promoters creating an open stream of information to the government including clients of the Firm. To avoid detection of the Scheme and proper legal representation for the purchasers of the Shell Companies, the vehicles are sold with “all legal included” with Anthony acting as an attorney for both the buyer and seller as well as a fiduciary as the escrow agent in the transactions. One of the many examples involves the indictments of Fotis Georgiadis, David and Donna Levy, the Informants created the shells underlying their indictments, sold the vehicles to private companies seeking to go public while Anthony served as counsel to the Levy’s as well as the issuer purchasers. The informants pocked the lucrative proceeds from the sale of the shell companies sold for the reverse mergers of Health Sciences Group, Inc. which led to the indictment of Thomas Gafney, Cardiac Network (CNWI), formerly Caspian Energy International and Banneker (BANI) formerly Cumetrix Data Systems Corp. (See Exhibits 2-Aand 2-B) which led to alleged schemes and indictments of at least 12 individuals and resulted in millions of dollars of investor losses.

In furtherance of the Scheme, Anthony prepares and disseminates hundreds of fraudulent public filings for the Shell Companies available for viewing by the public at large. Such filings are required by the rules and regulations of the Securities & Exchange Commission (SEC) and are designed for the protection of investors.

At least 67 individuals associated with the Shell Companies have been criminal charged after the vehicles were purchased from the Informants including clients of the Firm.

Defense attorneys and honest federal prosecutors are not aware of Laura Anthony’s cooperation agreement because disclosure would raise critical ethical issues because she was an attorney to many of the defendants pursued by the FBI. Disclosure would thus, eliminate her usefulness as a government informant and the impressive cases agents were producing.


Background of Pollaccia & Laura Anthony

Pollaccia’s broker check report (See Exhibit 3-A) reflects that from August of 1995 through August of 1998, he was a registered broker and branch manager of Joseph Charles & Associates (JCA),formerly JCA Associates, a defunct brokerage firm where Anthony was a director and legal counsel. (See Exhibit 3-B) One of the few pieces of information about JCA on the internet involves an old news article concerning the October 25, 1999 murder of two stock promoters (See Exhibit 3-C) Albert Alain Chalem and Maier Lehmann. At the time of their deaths, they were involved in the promotion of a public company known as Global DataTel (GDIS) on their website www.stockinvestor.com at the time of their murders (See Exhibit 3-D)

Joseph Charles & Associates was in a highly publicized dispute with GDIS concerning the promotion which led them to solicit information concerning GDIS. (See Exhibit 3-E) Mainstream media outlets reported that the two murdered promoters were FBI informants. Chalem ran Toluca Pacific Securities, a trading partner of Felix Sater, whose case was the subject of a secret docket in the Eastern District of New York.

Pollaccia’s was employed at Concorde Trading Group, Inc., from May 4, 1994 – September 26, 1994, Eiger International, Inc. from September 29, 1994 - March 31, 1995 and FSG International Incorporated from March 30, 1995 to May 18, 1995.(Exhibit 3-F)

In March of 1999, while Pollaccia was not associated with a broker-dealer, he sold interests in viatical contracts offered by American Benefits Services Inc (ABS). In connection with such activity, Pollaccia was the subject of an investigation by the Florida Department of Banking & Finance Securities and Investor Protection for his sale of ABS’s fraudulent viaticals. (See Exhibit 3-G) By the end of 2000, more than 20 persons including sales persons were indicted in connection with the sale of ABS viatical contracts.

While the Florida action against Pollaccia was ongoing, he sought employment at First Madison Securities a small broker dealer in Boca Raton, Florida. On October 11, 2000, Ray Vahab, the firm’s owner was indicted in connection with a reverse merger transaction involving Bookdigital.com, (See Exhibit 3-H), a public shell created by government informant and securities lawyer, Peter E. Berney (See Exhibit Exhibit 3-I) Mary Jo White then the United States Attorney for the Southern District of New York and Mary Shapiro then the head of the National Association of Securities Dealers announced the indictments of 120 defendants including members and associates of the five Organized Crime Families of La Cosa Nostra in the New York City area. (See Exhibit 3-J)

The following month, on November 8, 2000 Pollaccia changed his name to Michael Anthony. (See Exhibit 3-K). By February of 2001, Pollaccia and Anthony applied for a marriage license and were married on April 7, 2001. Pollaccia and Anthony (then known as Laura E. Arnoff) were married and she changed her name to Laura Anthony. (See Exhibit 3-L)

Anthony ensured that their pasts was not discovered others including by state regulators. An action by the Florida Division of Banking and Finance resolved almost two years after Pollaccia’s name change, reflects an enforcement action against Michael Pollaccia while represented by Anthony, allowing his identity as Michael Anthony to remain unblemished and their decade long crime spree under the watch of law enforcement. (See Exhibit 3-M)

The Corporate Hijackings & Box Jobs

On August 17, 1999, Peter E. Berney, a securities lawyer and shell manufacturer, was indicted in Nevada and two weeks later was charged in the Southern District of New York in connection with his creation shell companies for reverse mergers (See Exhibit 3-H) At the time of the indictment of Berney, he had an inventory of more than 40 “Box Job” shell companies which were forfeited as part of his plea agreement. (See Exhibit 3-I) In December 2001, Berney pled guilty to conspiracy to defraud the United States, and impeding and impairing the IRS. Berney was sentenced to 30 months in federal prison, and he forfeited $21 million in property and cash. Many of Berney’s shells have been used by the Informants. The Berney case documents reflect he had manufactured shells throughout the 90’s.

Berney’s shells can be traced to numerous securities violaters and pump and dump schemes including Donald Mintmire, Joseph Meuse, Marc Jablon, Michael Lauer,

Using complicit transfer agents and corporate registered agent services, Anthony, Pollaccia using the name Michael Anthony and other co-conspirators (the “Participants”) locate financially distressed public companies (Distressed Company) that have allowed their good standing status with the Secretary of State to become inactive or revoked by not filing an annual report and paying a fee. This inactive status can be cured by the filing of a one page reinstatement form and payment of a fee of less than $1,000.

Upon locating the Distressed Company whose good standing status has been revoked, the Participants file a state court action seeking to be appointed as a custodian for the benefit of the Distressed Company’s shareholders. Upon a custodian’s appointment, the Participants eliminate the interests of the Distressed Company’s shareholders, and sell control of the Distressed Company for reverse merger transactions. Upon sale, the proceeds are not distributed to the Distressed Company’s shareholders, pocketed by Anthony and Pollaccia who have profited approximately $30 million from the decade long Scheme.

In furtherance of the Scheme, Anthony submits fraudulent filings with the Securities & Exchange Commission (SEC) and with the Financial Industry Regulatory Authority (FINRA), concealing among other matters, the regulatory actions against Pollaccia and illegal use of the custodianship actions. These filings are viewable by the public at large and relied upon by the public to make investment decisions.

Pollaccia functions as an unregistered broker selling the Public Shells to be used in reverse merger transactions. In the transactions, LAnthony operates as a securities lawyer preparing public disclosures and preparing agreements and other documents for the sale of the Shell Company. SEC and OTC Markets filings reflect that LAnthony has assisted Pollaccia in putting at least 200 unlawfully obtained publicly traded entities into the penny stock markets. After entering the markets, certain of the Shell Companies were used in ‘pump and dump’ and other fraudulent schemes harming thousands of investors and causing millions of dollars of losses.

Publicly filed documents reflect that LAnthony and Pollaccia took a portion of the illegally obtained shell inventory of Berney and another securities attorney, David Stocker who was indicted in connection with shell companies he manufactured.

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