JB and ZJMY Holding Co (JBZY)

[jpmu]

Dear Judge Ross: Pursuant to Your Honor’s Notice/Order dated October 3, 2017, I respond to the arguments of Docket Nos. 5, 10 and 29 as directed. Since I have been directed to respond by letter not exceeding seven pages, I also request this be treated as a simultaneous cross-motion for leave to amend to address any adverse finding which may arise this proceeding to allow Plaintiff to amend the Complaint to overcome any deficiencies in pleading. I will start by responding to Docket No. 5, the Motion to Dismiss filed on behalf of Defendant Rivie Schwebel. Generalized objections to lack of specificity, failing to meet the pleading standards of, and the absence of specific allegations to comply with, the Private Securities Litigation Reform Act of 1995 (the “PSLRA”), FRCP Rules 8(a), 9(b) and 12(b)(6) comprise one set of the objections.

The essence of Defendant’s argument is that he had a consulting contract. If that is the case, and we do dispute that factually, then when he proves the validity of that contract he may well win, but not on a motion to dismiss. I am not certain what aspect of no consideration Defendant doesn’t understand. Plaintiff argues that Schwebel has rendered no service that can be legally recognized. Plaintiff may disagree but he can hardly contest that the allegation has been made. Case

While the securities law violations are somewhat sparsely pled, the allegations are straightforward, these Defendants and the Company engaged in a subterfuge to disguise the real reasons for the issuance of these shares. Dolat is not a company devoid of meaningful history in this regard. It is a vehicle that was used for the classic “pump and dump” which can also be asserted if need be due to the recent completion of certain proceedings in a criminal case in the District of Connecticut involving persons known to Mr. Hauck, the head of this cabal of lies and deceit.

Defendant Schwebel then asserts that he owns 30,000,000 shares of Dolat common stock, but one would not know this if one looked for the required Forms 3, 4 or 5 that one owning such concentration should have filed. Nor were there any Williams Act filings which were also required. If Defendant Schwebel wants a much more specific assertion of the components of the conspiracy present in this Company Plaintiff is now prepared to lay it out in detail.

Defendant Schwebel and his minions participated in a significant stock fraud whereby no real business was conducted but certain chosen persons were positioned to benefit while the public got screwed. If an opportunity to amend is required this fraud can be spelt out with even more specificity.

Finally, Defendants Chabad of North Hollywood, Glenn S Bordoff, Adam Braun Nechama Kuravkiy, Mazel Property Enterprise Corp. and Elimelech Rosenblat have submitted Docket No. 29, a letter similar to that of Defendants J&M Family Foundation and Benjamin Neuman. The same arguments apply so I will not repeat them and waste the Court’s time further

The objections raised by Defendants J&M Family Foundation and Benjamin Neuman in Docket No. 10 recite the same issues. They allege the same Wyoming Statute 17-16-304(b)(ii) but the argument remains the same is now that the State of Wyoming permits fraudsters to issue stock without consideration to dupe the public. We disagree for the reasons cited above.

https://www.pacermonitor.com/public/case/21296169/Dolat_Ventures,_Inc_v_VStock_Transfer_LLC_et_al