Spongetech Delivery Systems, Inc. (fka SPNGQ)

[cowtown jay]

"Mossack Fonseca was just one of a number of firms in Panama offering such services...The cost of doing business there was quite low, relatively speaking...So what you would have is Panama operating as a conduit to the Swiss banks and the trust companies to set up these facilities for clients around the world."

Sound pretty familiar? It should. We've brought it to the court's attention on multiple occasions. For example:

10-13647-smb Doc 457 Filed 12/04/13 Entered 12/04/13 10:46:15

"IIROC Settlement with Canaccord, and my Dec 2011 Report
Jay Booth
to:
Judge Bernstein
12/03/2013 08:33 PM
Hide Details
From: Jay Booth <[e-mail]>
To: Judge Bernstein <[e-mail]>

Dear Judge Bernstein,

I reviewed the Settlement Agreement IIROC reached with Canaccord, and compared the facts presented in the Settlement Agreement to information I provided to the Court in my December 2011 Report of Examination.
The Settlement and my Report both concern issuances to Canaccord that went through Panama, and pose questions as to ownership of some of these shares. Relevant sections from both my Report and the Settlement Agreement follow.

From December 2011 Report of Examination.

"As I recall the SEC Complaint documentation, it referred to both Diomede and Maremmano as close corporations. These companies, according to the WST Transaction Journal, share the same Panama City address as do Ardee Trading Company and Fribourg Enterprises, at 10 Elvira Mendez Street. I previously traced the issuance of some of the shares that went through Panama City to Pike Capital (see example below).

Example
>Cert 4158 was issued to Diomede in the amount of 16,500,000 shares.
>It was canceled into cert 4217 and issued to Canaccord
>Cert 4217 was canceled into Cede cert 4250
>Cert 4250 was purchased/called by Pike Capital

>Cert 4159 was issued to Maremmano. It also went through Canaccord as cert 4220, and is now Outstanding, as Cede cert 4252. I suspect that these Cede shares, which now number 24,150,000 currently holding 160 million shares in cert form, which is about 22 million fewer shares than
reflected on his Form 4. If these shares don't belong to Pike Capital, then they may represent an example of equity assets to the company, held by close corporations. There is a similar example regarding an accumulation of shares into some European accounts, and additional issuances to Diomede and Maremmano, as well.

What this suggests is that the company did, in all likelihood, use foreign clearing firms and close corporations to accumulate shares, and that they took various steps to mask that accumulation. To that end, based on the Broadridge data, there is no accounting for the 22 million shares Pike Capital reported on their Form 4, beyond the 160 million shares for which they hold certs. Neither Pike Capital, Diomede, nor Maremmano show up on the NOBO list. Canaccord Genuity only reflects 237,500 shares on their NOBO list, and 238,440 shares on the Security Position Listing. It would appear that the 22 million shares are either held by a foreign, non-reporting entity, or that these shares are simply not reported by Broadridge.

My notes taken from the Settlement Agreement, which was reached at the end of October, but did not hit the internet message boards until yesterday. These are not verbatim.

from Canaccord Settlement Agreement with IIROC

31. DS was an RR (Registered Rep) at Canaccord's head office in Vancouver. He was the RR responsible for client accounts for six different Panamanian corporations that were beneficially owned by individual Europeans. The New Client Applications Form ("NCAF") for each account indicated that the clients shared the same address which was the Panamanian address for a corporate trust services firm which managed each of the corporate identities...

33. Between April and September 2009, these six Canaccord clients received in share certificates for a total of 194 million shares of an OTCBB company,SpongeTech Delivery Systems, Inc...There were 12 deposits for all 194 million shares.** Almost immediately after they were deposited to the accounts at Canaccord, these shares were then sold for proceeds of just over $15 million...The sale proceeds were then wired to bank accounts in Hungary."

** I previously noted also that there were two additional issuances to Diomede and Marremano, for 3 million shares each, that are still in certificate form as part of the OS, and so were not subject to the IIROC Enforcement Action. I should also add that, as I recall, the corporate trust services form was called Intertrust.

So why bring up old news? Well, the first paragraph is NOT old news. It's from an interview of Bradley Birkenfeld, who seems to think that the CIA may have leaked the Panama Papers.

"Bradley Birkenfeld is the most significant financial whistleblower of all time, so you might think he'd be cheering on the disclosures in the new Panama Papers leaks. But today, Birkenfeld is raising questions about the source of the information that is shaking political regimes around the world."

http://www.cnbc.com/2016/04/12/swiss-banker-whistleblower-cia-behind-panama-papers.html

Again, it just gets back to the issue of what the government knew, when did they know it, and what did they do about it? Remember also, that we have seen SpongeTech Relief Defendants Cavanagh and Nicolois granted the criminal court's permission to travel to Europe, quite recently for Nicolois.