Innerscope Hearing Technologies Inc (INND)

[Dragon Lady]

Moses Matt : Peddling LEGAL LIES AS "INTERNET LAWYER" !!!

Look folks - "Moses Matt" is 100% FOR CERTAIN a member of the MOORE MORE FAMILY CRIME CLAN and is desperately "trying" to do damage control via pumping 100% LIES, FRAUD and pure GUTTER DECEPTION as to "THE LAW" and practice of same and especially how "THE COURTS" work and what terminology means, etc.

ASS HAT Moses Matt is pumping a false narrative that somehow a "First Case Mgt Conference" being set "on the docket" for Sept is somehow indicative or foreboding a "weak case" or a mal-filed case or blah blah blah UTTER BULLSHIT BS Barbara Streisand WTF !!!

WHEN A CASE (LAWSUIT aka FORMAL COMPLAINT) is filed "With the court" and the $400 or whatever filing fee is paid and the Clerk Of The Court checks all the paperwork, the filing, the law firm BAR licenses, the facts as to IF the complaint is filed with the proper court (you don't file criminal complaints with the civil side of the court of family court etc) , filed according to THAT COURT'S rules and procedures which differ by state and even by county etc - THEN IT IS ENTERED "ONTO THE DOCKET OF THE COURT" by the CLERK OF THE COURT.....it's damn 2024 and it's COMPUTERIZED jack ass clown MOSES MATT the big bastard dumbass....aka Anthony Calabrese....aka MATTY MOORE himself alter ego clown punk........

THEN - a freaking AUTO-SCHEDULING COMPUTER PROGRAM AUTOMATICALLY KICKS-OUT THE NEXT "CASE MGT DATE" for whatever the F judge that case happens to land on WHICH is also done RANDOMLY and BY DIVISION and by SPECIALTY OF THAT JUDGE etc.......

IN CA - their courts are some of the most back-up and jammed-up IN THE NATION.....PERIOD WTF AGAIN !!!! A auto-set calendered date of Sept for a BS "Initial case conference" blah blah blah being generated as Sept DOES NOT MEAN JACK SHIT.....it's not even slightly "off" or remotely "odd" or any such lying bullshit as being peddled by ass hat Moses Matt-ASS !!

ALL civil court matters take a back-seat to CRIMINAL CASES as a criminal has a Constitutional right to a SPEEDY TRIAL....which usually means a YEAR to THREE YEARS.....civil cases.....2, 3, 4 YEARS is not unusual and almost NONE as in NEVER EVER EVER "go to trial"....the court expects and demands MEDIATION and SETTLING OUT OF COURT.......the MOORES HAVE NOTHING TO "SETTLE" as they're BK BROKE.....they will be NO-SHOWS the Vegas odds are showing......

Moreover - the initial "CASE MGT CONFERENCE" DOESN'T MEAN JACK SHIT as to how a case proceeds and how fast it can proceed and who wins or loses or strength of the case blah blah blah !!!!

1) THE SUMMONS MUST BE SERVED - and in the case of Shennib Vs INNER-CRIME IT IS ALREADY "SET IN MOTION" as they paid the fees and The Court + the Plaintiff attorneys will begin SERVING THE DEFENDANTS.....

2) The Defendants MUST ANSWER/RESPOND TO THE FORMAL COMPLAINT once "duly served" per the rules of the court - typically 21 to approx 30 days from WHEN SERVED or WHEN SUMMONS ISSUED......

3) IF THEY DO NOT ANSWER or TIMELY RESPOND FORMALLY TO THE COMPLAINT - they are now in contempt of court and "The Clerk" w/o even needing the Plaintiff attorney to act CAN ENTER A JUDGMENT OF THE COURT DEFAULT and/or THE PLAINTIFF CAN FILE A MOTION INSTANT ACTION FOR "MOVE FOR DEFAULT JUDGMENT" blah blah blah......the date being Sept for Case Mgt #1 conf doesn't mean JACK SHIT....

4) IF THE MOORE CLAN ANSWERS THE COMPLAINT - which is HIGHLY UNLIKELY then this POS gets their NEXT DEFAULT JUDGMENT and Shennib will WIN BY DEFAULT in probably about 60 days or less from today.....THE MOORE CRIME CLAN ARE BK BUSTED BROKE as is INNER-CRIME....they are FAILING TO ANSWER FEDERAL LAWSUITS....so WTF would they answer and LAWYER UP for a damn state lawsuit for........

MOSES MATT IS A CRIMINAL FRAUD ALIAS OF THE MOORE CRIME CLAN - do not listen to the ass clown and NOTHING HE SAYS IS EVEN REMOTELY FACTUAL or accurate as to "THE LAW" or how a court and court case is managed and proceeds etc.

MOTIONS CAN BE FILED - the date of the damn Case Mgt Conf as stated....DOES NOT MEAN JACK SHIT.....it's an auto-generate "DOCKETING/CALENDAR MGT DATE" and nothing more....F-ing DUMB ASS MOORE CRIME CLAN and their "family" pump the crime aliases......

BK IS IN-COMING and nothing on this planet is going to stop it -

THEY OWE THE Q-1 SHIT FILING ALREADY - the damn QTR ended March 31 2024.....WTF....like it's going to be better than the SHIT-CAN STINKING ANNUAL SHAM FILING.....pull head out of ass MOSES MATT.....it's dark and stinky in there you clown.....!!!

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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[Dragon Lady]

INNNER-CRIME: "MosesMatt" Straight Up CRIMINAL !!!

OPERATION BAN MOSES MATT ASAP ON STOCKTWITS - time to kick that POS MOORE CLAN MEMBER to the curb.....w/ extreme prejudice.....

https://stocktwits.com/MosesMatt

Pumpers are in full panic mode. Literally everyone that ever had the displeasure of doing business with Matt Moore is suing him. There's just nothing else to say!

Yepper - and THEE NEXT DAY the MOORE MORE CRIME CLAN create their newest shit-show ID/Alias aka MosesMatt on Stocktwits and jump the shark HARD off into full blown criminal securities fraud......

The jack-F is claiming, "I spoke to Shennibs' law firm and attorney in a private conversation regarding intimate details of the lawsuit and THEY TOLD ME" blah blah blah......MATTY BOY aka THE PUNK is staring down some CLUB FED prison time here folks..... he better learn to shower w/o dropping the soap and learn how to "buy friends" using cigs and condoms....lil MATTY ain't gonna last 1 day inside a lock-down.....I can smell the weakness in that punk......

Matty boy - he's doomed if his ass gets indicted let alone goes to prison even a damn CLUB FED happy camp which is a country club in terms of "prison" .....that little momma's boy teet sucker don't have a chance in a lock-down.......

[trading.jeff]

mattolotmoron, aka Platdumbnuts, isn't suing Matt, to the best of our knowledge.

[PRCubaDog]

Pumpers are in full panic mode. Literally everyone that ever had the displeasure of doing business with Matt Moore is suing him. There's just nothing else to say!

[mattolotmoney]

lmfao just look how hard these clowns here are trying ...lmao just remember kuriloff knows exactly what's going on behind closed doors and he accepted another 1.3 billion shares ..GONNA BE A BIG HAPPY FAMILY AGAIN... OH and remember adnan after a year with the company converted his note to shares..so they all own a big stake in innd and want to see nothing but money ...all will be worked out and all will be happy .....dont fall for the hacks hype here .....BUY IN FEAR AND BUY THE BASH .IVE DONE IT FOR YEARS AND MADE MILLIONS

[Dragon Lady]

INNER-FRAUD: ENTIRE HQ BUILDING FOR LEASE NOW !!!

Well.....IF anyone is not sure this scam is over - just check their ole "2151 Professional Dr, Roseville" blah blah FOR FOR FOR LEASE LEASE LEASE.....all of it....unless the MOORE MORE CLAN are "operating" out of the broom closet or janitor room now LOL ????

Remember - their LIE FILLED OTC PROFILE (which they can update with the click of a mouse - and less than 2 minutes work) says "2nd floor" .....

https://www.otcmarkets.com/stock/INND/profile

THEN they changed-up that game in their latest crap annual filing from "2nd floor" to "Suite 104 or 105" aka the little downstairs office/desk sized cubes basically.....

AND they never updated their NV corp filings "by design" to screw-up process servers and "mailing of summons" from all the lawsuits - by just creating a monkey wrench ULTRA STUPID delay....that a crackjack box law degree attorney "Gets around" in about 2.4 seconds BUT causes them a bit of hassle and a small delay....but lucky for them.....there's some lil birdies out there who drop them "tips" on the ground by their law office where they work on "how and where to serve Innerscope and the Moore more clan".....poof.....lil note dropped right where they see it every time :))

https://www.jerdecre.com/2151-professional-dr.html


Click the "brochure" link to the broker's website - and the "building map" shows ALL OF IT FOR LEASE essentially and especially BOTH LOCATIONS that INNER-CON "claims" they occupied as "INNERSCOPE WORLD HEADQUARTERS" blah blah .....as in 2nd floor is up for grabs and both Suite 104 AND 105 are now up for grabs.....

https://www.jerdecre.com/uploads/2/6/3/7/26372102/2151__suite_100104105200.pdf

Me thinks this scam is gone - as in no more moore....poof.....vacated......BK in-coming like a hot nuke and Shennib and his lawsuit was the final nail IMO....along with the air strike from Hessenn group....they brought serious legal fire power and ain't jacking around....they're after $2.4 million or more and are playing for keeps looks like to me.......


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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[trading.jeff]

LMFAO!! Thanks, but you don't give a reason, so I'll just pass this one by.

[mrmk]

You have joined the ranks of the Ignorant and immature,congratulations!

[Sheddoggie]

Dump Matty Boy!

Dump them shares Matty boy, might be your last chance.

[Dragon Lady]

MMs WASH TRADING TO UNLOAD THE DOG SHIT !!

Here we go with the illusion of heavy trading out of the gates. With bazillions of shares, please disregard. It's probably just Platdumbnuts adding to his stash so he could make more millions in profits.

100% correct - the only "real" vol is likely approx $1K to $2K and ALL ELSE is institutional MM's hired and paid by Kurlioff to SELL HIS BILLION SHARES OF DOG SHIT.......

When a dude gets a BILLION COMMON SHARES OF A STINKY PINKY CRAP TO UN-LOAD - he DOS NOT use a damn E-trade account or whatever....he hires "institutional trading firms" who get a hefty fee to UNLOAD THE DOG SHIT and those firms can WASH-TRADE and CROSS-TRADE and use every scam in the book aka THE GRAND ILLUSION to create the liquidity needed to empty the guy's position.....

Look at the past few weeks - every week at least one or 2X per week they've PUMPED THE FAKE AS SHIT Ask up to .0004 and .0003 and then POOOF buried it back down with DUMP n SELLS as fast as the micro pumps......SOLD INTO SOME DUMB ASSES who see it on a scanner and think "Yeah bros - I'll grab $1K of a 50% or 100% fast move" blah blah.....

THIS SCAM IS OVER - it's a DEAD TICKER ON LIFE SUPPORT so do not be fooled baggies and DO NOT BUY THESE SHITTY SHARES.....this crime scene is in the wind-down mode.....and NOTHING is going to change that bad sick reality......:))

"Captain who ?.....the book you dumbshit....the book......" LOL !!!
Dely - that one's for you :)
UN-LOADING THE DOG SHIT 101.....textbook....this dude invented it....!!!

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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[trading.jeff]

Here we go with the illusion of heavy trading out of the gates. With bazillions of shares, please disregard. It's probably just Platdumbnuts adding to his stash so he could make more millions in profits. 🤪🙃💩🤡

[Midwestrader]

If they don't pay their Registered Agent and Transfer Agent and keep them current it's lights out on this ticker. This ticker is their only way of making money by DUMPING and probably pulling a massive RS to have billions more shares to dump.

Something big will happen soon, BK or a massive RS.

[Dragon Lady]

INNERCON: FDA WARNING LABEL "NARCISSIST GRIFTERS" RATED !!

https://stocktwits.com/Tigerrouse111/message/570485012

Best definition I've heard for the MOORE MORE CLAN - and remember boys n girls....BAGHOLDER DILUTION WAS USED TO "PAY OFF MATTY'S AMEX CARD TAB" ....during the 2021 PUMP and DUMP.....yep.....folks here or any shareholders/shit buyers of this scam PAID-OFF THE $100K+ AMEX BILL of MATTY BOY aka THE PUNK.....that's why the case "Settled" suddenly in 2021.....the 2021 massive PUMP the DUMP phase of this crime scene.....never forget kids....never......!!!

The MOORE MORE CRIME CLAN used monies from the P&D to pay-off all kinds of prior shit debts owed: From delinquent property taxes to massive credit card bills to liens on their real estate holdings to god knows WTF else.....grifter clan.....bad wood.....rot gut.....sociopath.....narcissist grifters.....

PLACER COUNTY SUPERIOR COURT :

S-CV-0044030 American Express National Bank vs. Moore, Matthew 11/19/2019 Civil-Roseville Contract: Collections (09) 08/02/2021 2:00 PM Case Management Conference in Department 40 Closed
Dismissal: No ADR 09/07/2021

Over a $100K tab on a damn AMEX CARD - and the MOORE MORE CLAN diluted this shit stock using a pre-planned and pre-meditated P&D grift n dilute to pay it off in 2021......

This Friday April 26th 2024 the MOORE MORE CLAN will "Fail to answer summons" in case titled Hessenn Group LLC v Innerscope et al....and then it heads rapidly to DEFAULT JUDGMENT and it's over $2 MILLION LARGE owed to the "Kiosk and store display maker" that MATTY BOY aka THE PUNK + the MOORE MORE CRIME CLAN ..."stiffed".......tee-up a massive collection effort hunting the Moore clan to the ends of the earth backed by a federal court order....:))

https://www.pacermonitor.com/public/case/52733622/Hessenn_Group_LLC_v_InnerScope_Hearing_Technologies,_Inc_et_al

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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[Dragon Lady]

INNER-FRAUD: IT'S DEAD JIM :)

Adnan Shennib is suing INND.

This crime scene is over folks......just waiting for the coroner's (BK court or receivership) final report now.....cause of death.....sociopath toxic self implosion combined with blunt force gross stupidity and family greed......a bad and lethal combo.....kids.....don't be MOORE MORE CLAN STUPID......

[Dragon Lady]

Bingo !!

Maybe they haven't been paid either. Those are like 500 bucks a pop. And they'll likely insist on cash.

I was literally about to write the same thing.

I figure $500 on the low end and for a real POS like this where they got um over a barrel - probably a $grand is not far fetched ?

I mean - the scammers have no choice, PAY UP for the Ltr or go YIELD.... so looks to me like the scam attorney toilet paper ltr writers got these busted-out tickers in the pickle box and can pretty much demand cash only and name their price.

When their cash line (3 months old now) says $2K and they owe $19 million AND are funding some serious bucks big law firm now (well, unless they quit already) even getting $500 scratch is probably no small task.....

Like the MOORE MORE CLAN are gonna fork up out of their own personal wallets ....really....me no think so.....?

This POS is so ill-liquid now it takes a few days to raise a pittance of even $500 bills in new dilution - the ticker is dead for all intents and purposes in terms of daily $dollar trading volumes.

Kurlioff is clearly trying to dump those BILLION shares - but good luck with that as this crime scene is more toxic now than refined Plutonium :))

[Dragon Lady]

INNER-CRIME: NEW STOCKTWIT ID MosesMatt BAN TIME !!

Getting the family back together!!

Yeah....looks like ole Shennib told MATTY BOY and the MOORE MORE CLAN what they could do with the "family" good-times crap-speak BS LOL !!

Well.....THE MOORE MORE CRIME CLAN have just created their latest FAMILY PUMP THE CRIME ID aka MatToSuCksAlOtaD aka Platdumb aka Plat421 aka Wamuvoodoo aka ANY ID ending in 421 posing about INNER-FRAUD aka Nutsbuster aka EVERY MOORE CLAN MEMBER USES 5 IDS to run smoke n cover fire the hotter and shittier this crime scene gets !!

OPERATION BAN "MosesMatt" - folks....you know the mission....troopers you know what to do....I'll fly top-cover and close air support....I've got your six.....:))

https://stocktwits.com/MosesMatt

BAN THAT JACKASS ASAP - and with extreme prejudice...

Jackass MATTY BOY or Daddy Moore More aka THE DON named themselves "PETER PAN" this go around - the MOORE CLAN....

The MOORE MORE CLAN SET TO MUSIC.....this one's for you Dely.....:))

"My old man's drunker than a barrel full of monkeys
And my old lady she don't care
My sister looks cute in her braces and boots
A handful of grease in her hair
"

DADDY....MOMMA....dumb-brick sister Elizabeth.... and the story being told by MATTY BOY aka THE PUNK.....perfection.....:)

Question for Dely...aka Sckots13 131313 13 1313131131 13....tuning in on my frequencies (my jammer locked on to that 13 131313 13 1331313 coded frequency....Dely..like a kungfu grip) ... on Stocktwitters.... as this is up your area of expertise : HOW DRUNK is a "barrel full of monkeys" ...uh...exactly ?

What if it was only a half barrel of monkeys - would they blow a .08 or hummm.... ?

Help me out here Dely - I'll read your reply on Stocktwits tomorrow and expect some MATTY BOY graphics that involve an image of MATTY BOY + drunks + the old man + monkeys and if the sister and momma are included you can get bonus extra credit points lil smokey boy...ok Dely.....:))

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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[tdbowieknife]

Maybe they haven't been paid either. Those are like 500 bucks a pop. And they'll likely insist on cash.

.

Buyer Beware
Pump and Dump



..


..

.

[Midwestrader]

WHERE IS THE ATTORNEY LETTER FOR THE ANNUAL FINANCIALS EASY BAKE?? That should have been filed the same day or the next after the Annual. BOTH should have been filed on April 1st.

This POS is going to a YIELD SIGN soon!!

[PRCubaDog]

Still out of stock at Walmart. Matt has literally screwed up everything he touches. Pathetic.

[Dragon Lady]

INNER-CRIME: SIX MAJOR LAWSUITS NOW LMAO !!!

FINANCIALS DUE in FOUR WEEKS. Yes...Easy Bake barely got the Annual filed with an EXTENSION which ended up being 105 DAYS to do a 90% copy and paste financial. NOW....she has to have the Q1 out by May 15--exactly four weeks from today.

Get ready for yet another LATE FILING NOTICE. 👈️

IF IF If if if IF if if THEY EVEN FILE THAT POS TOILET PAPER Quarterly DUE May 15 2024 -
THEY BETTER DAMN LIST ALL SIX SIX SIX MAJOR LAWSUITS THIS TIME as they LIED on their POS Annual and intentionally left out a shit ton of their LAWSUIT-a-CON........

The "race is on"......is it BK FIRST or DILUTE THE LAST BILLION SHARES to "pay for" their own BK FILING LMFAO.....they're TOO BROKE TO PAY A BK LAW FIRM and that is no damn joke boys n girls.......there's "maybe" a lousy $200K left to DILUTE and that would be a DUMP IT ALL NOW PRICES and that would be the only coin the MOORE MORE CRIME CLAN could use to BK this shit heap......


https://www.otcmarkets.com/stock/INND/security
DILUTION "WATCH" - they gotta get BK/lawyer funds from somewhere and THAT is where they be sitting as of now.....:))

$2K TOTAL CASH ON-HAND in their corporate crime account.....

$19 Ma Ma MILLION in just "ACCOUNTS PAYABLE" and those were OWED THREE MONTHS AGO aka ALL ARE PAST-DUE AS OF THIS AM.... and many are now SECURING LEGAL CIVIL JUDGMENTS and will ASAP TURN TO "COLLECTION/FORECLOSE ACTIONS" against INNER-FRAUD......

Bottom of the 9th......the MOORE CRIME CLAN are down by 13 BILLION and have no bullpen and no one who can hit and no coach in the dugout.....crowd left that stadium about 2 YEARS AGO.....and there's no more tickets to sell or popcorn and beer even left for sale.....this game is OVER kids.....:))

SIX SIX SIX ...count um kids :

1)
https://www.pacermonitor.com/public/case/51022939/Ledbetter_et_al_v_Innerscope_Hearing_Technologies,_Inc_et_al
POST JUDGEMENT: Worth at least $250K owed and likely 2X that

2)
https://www.pacermonitor.com/public/case/49235021/Kuriloff_v_InnerScope_Hearing_Technologies,_Inc_et_al
SEEKING $MILLIONS OWED - and just the trial lawyer fees are sending the Moore Crime Clan to BK no matter what the outcome......they're broke !

3)
https://www.pacermonitor.com/public/case/52733622/Hessenn_Group_LLC_v_InnerScope_Hearing_Technologies,_Inc_et_al
$2.5 MILLION OWED and the most serious of the bunch - a literal INTERNATIONAL LAW FIRM w/ over 100 trial lawyers "on staff" and they're representing a Taiwanese firm who's going to tell the law firm "DESTROY WHO STOLE OUR MONEY - we don't care win or lose as to the case, DESTROY THEM" as that is the "Asian mindset"....trust me....I know.....I'm not the Dragon Lady for no reason lol.....:))

4) and 5)
TWO-fer special combo plate PLACER COUNTY Superior Court aka USA-TODAY/GANNETT PUBLISHING is going to blow-out INNER-FRAUD like a cluster bomb and daisy cutter combo "air mail special delivery" package !!

S-CV-0051790 LOCALIQ INDY STAR vs. INNERSCOPE HEARING TECHNOLOGIES, INC., a Nevada corporation 12/08/2023 Civil-Roseville Contract: Collections (09) 07/15/2024 2:00 PM Case Management Conference in Department 6 04/08/2024 2:05 PM Case Management Conference in Department 6 Open
S-CV-0051784 INDIANAPOLIS STAR vs. INNERSCOPE HEARING TECHNOLOGIES, INC., a Nevada corporation 12/07/2023 Civil-Roseville Contract: Collections (09) 07/15/2024 2:00 PM Case Management Conference in Department 6 04/08/2024 2:05 PM Case Management Conference in Department 6 Open

6) SIX SIX SIX also in Placer County Superior Court : Only about $15K on the line but a nice cherry on top of the SHIT HEAP LAWSUIT DUNG PILE :))

M-CV-0084231 Air Sea Container Line Inc. vs. Innerscope Hearing Technologies Inc. 06/16/2023 Civil: Limited-Roseville Contract: Collections (09) 04/15/2024 3:30 PM Order to Show Cause in Department 6 Open

Oh but wait......RONCO TV MIDNIGHT SPECIAL COMMERCIAL.....THERE'S MORE....we just got WIN THE LAWSUIT LOTTERY LUCKY NUMERO SEVEN THIS WEEKEND - the MOORE CLAN WON THE LAWSUIT LOTTO LMAO !!!!

7) Hello Shennib MEETS Matty Boy back alley "Saturday Night's Alright For Fighting....get a little action in".......:))
https://trellis.law/case/24cv072452/shennib-et-al-vs-innerscope-technologies-inc-a-nevada-co

OVER $10 MILLION IN DAMAGES BEING SOUGHT.....oh boy....MATTY GETTING HIS SORRY ASS KICKED....get the popcorn and more beer....it just gets better and better kids......LOL !!!

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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[PRCubaDog]

Adnan Shennib is suing INND.

[mattolotmoney]

lmfao pr did you get on that name change yet ..also next time you do a hack tell your buddies to pick the right law firm ...you picked a personal injury firm lmao fools..here's a other one quoting adnan from this bs made up lawsuit "I'm unaware of how much damages there are but let's say it's $10,000,000... lmao that's classic..you think he'd be prepared with a # ... like that clip in the movie Friday.

..also Lawsuit says" Shenibb says that matt Moore said that the companies shares are worth $10s of millions of dollars along with other assertions and Shenibb with that information went into contract with matt moore and innd ... So one would say is that the best due diligence story you ever heard of.... Wow! ..either real or fake matt has a powerful counter in the wings .. oh and also never has there been a 6 month delay in case management..this is hilarious

[PRCubaDog]

Getting the family back together!! 🤣🤣🤣

[Dragon Lady]

INNER-CON For Dely: It Was Never A "Sure Thing" :)

This one's for you Dely - since you've been talking "Movies" a lot lately.

And I kid you not lil smokie - that I ripped a Blu-Ray of "The Usual Suspects" literally the night before you started writing about Keyser Söze and the boys.

Are you honing in on my signals smokie boy- you know I'm an expert at signal jamming, right...America's finest.... I might have to send some static your way Dely....take out your transmitter even..... :)

I told you lil enigma - you have good taste in movies and music and are well read and recite lyrics not many would know excep genius level peoples like me......me thinks more to story with pretender angry bad-boys talk PI girl 4-finger smokie boy n all ???

So - here's my "movie for Dely" cut special. Just for yu ...I know Matty n now Shenib broke yo heart a lil harder this afernoon smokie.....not happy place....:(

Dely...Dely....smokie boy Dely....I'm "sensing" a lil hurt....a lil loss luv for Matty Boy....maybe missing Momma MOORE MORE and her daily cookies....the ones you eat out of the oven....not her "other" cookies.....

But….but..butt… Dely....ya gots to know in luv....it neva bes a ...."Sure Thing"......ya gots to move on.....there's other Matty Boys n Momma cookie bakers out there.....

Real life never turns out n bes as good as one imagine anyway.....and sarry....me still no can luv yu....not even short time....nots eva...no can do Dely....

yu be lost without me Delys.....but me no can do.....already pledge faever luv to nother long times ago....I neva gonna replace Matty fors yu...or momma Moores n her big warm cushy cookies rack…..no can do smokie boy....so...so....sarry....:))

Does god exist ?
Who invented liquid soap and why, Dely ?

These are question one must ask to find true luvs Dely - you thinks ress of week bouts it n cheer up a bit….. ok… sad n loss smokie boy ?

[Dragon Lady]

Thanks Cuba !

The Michael Moore thing will be corrected tomorrow.

There's a few other "typos" aka scrivner errors in the complaint - things like spelling "Nevada" incorrectly.

There's also a few "things" that IF IT WAS ME filing this complaint - I'd amend it, to strengthen their arguments and underpin a few key points they missed IMO:

If you "have their ear" - I'd point out the following:

1) They should add to the complaint that "Unknown to Mr Shennib, the entire Moore family as named: Matthew Moore CEO, Kimberly Moore CFO and Mark Moore as Chairman, had prior been civilly prosecuted successfully for fraud related to running a series of hearing aid clinics by then CA attorney general Kamala Harris. The resulting actions caused named defendant Mark Moore to lose his CA hearing aid license, and for collectively The Moores to pay-out over $500,000 in restitution to victims. Charges included fraud, false advertising claims related to selling hearing aids to Sr citizens and elder military veterans and other civil violations. Plaintiff Mr Shennib was never made aware of these facts and knowing these facts he may have made a decision not to risk his company, his name and his reputation via entering into the agreement to sell his company and his name and services to the Moores. (Send the links to those civil actions - they're at the bottom of almost every post I make and two key ones are right here)


https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.speechandhearing.ca.gov/public_had/ha-2425_2017_04_10_do.pdf


2) I'd "correct" their wording which they use in several places of "The Moore family own the company".

It should read something along the lines of:

"Innerscope Hearing is a penny stock that trades over-the-counter on the OTC market place (traditionally known as the Pink Sheets) INND is a a non SEC reporting company and thus their financial statements are un-audited and filed under what is known as the "Alternative reporting system" of the OTC markets. Kimberly Moore named defendant acts as the company CFO (chief financial officer) and appears to prepare the financial statements of the company according to their own filings.
See link here: https://www.otcmarkets.com/stock/INND/disclosure
Due to these facts, there is very low if any, reliability as to the accuracy of the financial statements or claims INND and The Moores made to plaintiff Mr Shennib. The OTC "alternative filer" status is the lowest market tier of what is and was, traditionally, known as "Pink sheet stocks". The Moores collectively can essentially "make up" anything they want as to their company financial claims, sales, earnings, assets, cash holdings, etc and no one verifies it when they are a "Alternative filer" company and un-audited as a listed Nasdaq or New York Stock Exchange or similar company would be. Mr Shennib was not made fully aware of these facts by the Moore family when entering into these agreements...blah blah.

The three defendants, here in named "The Moores", despite this being a public traded penny stock - they maintain 100% voting control rights and all controlling rights over this micro sized public company via holding 33% each of the special class of preferred shares of stock. This means that the Moores for all intents and purposes run the public traded stock company INND as a private entity with no outside or independent board of directors or oversight. The Moores have full and total say over any class of common stock or any shareholders, who can never outrank or outvote the Moores "by design". As we've noted elsewhere in this complaint, that means that INND is essentially a Moore family controlled shell and they run it as such, and control it as such.

Something to that effect - it's incorrect to say "The Moores own the company" when it's public traded. They're going to get spanked by the Moore clan IF they even respond to this complaint and/or "lawyer up" which IMO is now highly unlikely. I bet this goes to "DEFAULT JUDGMENT" as in, never even gets an answer !! BK on-deck IMO. But hey - gotta get the complaint right to even have a decent chance at bat !

3) The complaint adding to my point number 2: It should in a footnote or somewhere paste in that OTC MARKET link and state "Their financial statements are posted here, the OTC Markets site" blah blah. THEN note that "In their most recent OTC annual filing dated April 15, 2024 for the fiscal year ending Dec 31st 2023, INND now list their corporate address not as 2151 Professional Dr, 2nd floor, Roseville, CA as stated in their NV corporate filing. But appear in their annual report to have changed their address to 2151 Professional Dr, Suite 105, Roseville blah blah blah.

I'd get that "Address change" aka now "Suite 105" on the record if it was me - as it's also going to be key to where they serve them this lawsuit !

4) I'd make a point to link or list "Page 12" of same annual report showing that each key defendant collectively here called "The Moores" holds "300,000 shares ea of the Class B preferred stock, granting them 100% voting control and total power to rule over the public traded entity INND w/o any outside ability or entity to ever outvote them or override them" See "NOTE A explanatory paragraph as to the Preferred B shares total voting rights control over the public shell entity". Mr Shennib was never made fully aware of the implications of the Moores total voting power control over this public traded entity... blah blah. Something like that.



THOSE ARE THE FIRST THINGS THAT JUMPED OUT AT ME - there's a few other things. Some blatant misspelled words, but no show stoppers and can be caught later.

BUT the defendant and THE KEY ONE aka MATTY BOY (Not MIchael) - they gotta get that fixed ASAP and again, IF IT WAS me get that address correction/mis match to their NV Corp filing "on the record" as it shows BY INTENT they are not keeping their NV secretary of state filings up to date and accurate and "by design" as it throws a wrench in serving process on these ass clowns !!

Also - I'm a stickler for a "tightly written first formal complaints" being filed, and calling the Moore clan "Owners" of a public traded company - it's just flat out incorrect. I explained how to correctly write it above. Since they're going to amend the complaint - fix it now and be done with it. Public traded stocks DO NOT have "owners" - they have shareholders and CONTROLLING SHAREHOLDERS aka Mgt when it's 2-bit POS shady as shit "Alternative filer" crap like INNER-CON.

LISTED STOCKS - you NEVER EVER EVER have ONE PERSON/ONE FAMILY holding all the cards - they have to have independent board members. There's a reason INNER-CON IS NOT AUDITED and NEVER WILL BE and why they will NEVER "LIST ON NASDAQ" as no way in F-ing hell the MOORE CLAN are going to give up board seats to honest, outside, real life BOARD MEMBERS and that was ALL part of the mega lies they told !!

My 2-cents on them apples :))

[PRCubaDog]

The Michael Moore thing will be corrected tomorrow.

[tdbowieknife]

Great, thanks... That will do, I'm going to try another workaround as well.

..


.

[Dragon Lady]

FORMAL COMPLAINT: ALAMEDA COUNTY

Td - I think I pretty much got it. Chrome browser "developer mode" and was able to snag it as a txt file. Probably not perfectly formatted - but I think it's pretty much all there and all in a readable format.

PS: When I get a bit of time I can clean-up the formatting and line end/start alignment and will re-post, but it's all there :

Check it out -

1 Shaumyan & Derbarseghian LLP
2 Aren Derbarseghian (304530)
Alfred Shaumyan (266908)
3 700 N. Brand Blvd., Suite 870
Glendale, CA 91203
4 Telephone: [phone]
Facsimile: 818-875-1810
5 Email: [e-mail]
[e-mail]
6
[e-mail]
7

8 Attorney for Plaintiff: Adnan Shennib and Center for Medical Device Innovations, Inc.

9
SUPERIOR COURT OF THE STATE OF
10 CALIFORNIA FOR THE COUNTY OF ALAMEDA
11

12 Case No.:
Adnan Shennib, an individual, Center for Medical
13 Device Innovations, Inc., a Delaware corporation, Complaint For:
14 Plaintiffs, 1) Breach of Contract
2) Fraud
15 3) Negligent Misrepresentation
v. 4) Fraudulent Incitement
16 5) Fraudulent Concealment
6) Breach of Fiduciary Duty
17 InnerScope Technologies, Inc., a Navada 7) Violation of Rule 10b-5 of the Securities
Corporation, Michael Moore, an individual; Mark Exchange Act
18 Moore, an individual; Kimberly Moore, an
[Jury Trial Demand]
individual; and DOES 1 through 20, inclusive,
19

20 Defendants.
21

22

23

24

25

26

27

28
-1-
COMPLAINT FOR DAMAGES
1 GENERAL ALLEGATIONS

2 1. Plaintiff, Adnan Shennib, is the founder of Ihear Medical, Inc. (hereafter, “Ihear”). Ihear is

3 a hearing aid company located in California. Mr. Shennib is the CEO of Ihear. Ihear has several

4 shareholders, some of whom, like Mr. Shennib, are former employees of the company.

5 2. Sometime before September 30, 2021, Mr. Shennib was approached by Defendants

6 InnerScope Technologies, Inc. (hereafter, “INND”), Michael Moore, Mark Moore, and Kimberly Moore

7 (collectively, the “Moores”).

8 3. The Moores are the owners of INND and serve on the company’s board of directors.
9 When they approached Mr. Shennib, they told him that they were interested in purchasing Ihear.
10 4. Specifically, they told Mr. Shennib that INND was a legitimate hearing technology company
11 and that they were interested in purchasing Ihear’s assets to expand their market share of the hearing aid
12 industry. They claimed that INND was a successful company and that its shares were worth tens-of-
13 millions-of-dollars.
14 5. Based on these representations and other assurances provided by INND and the Moores,
15 Mr. Shennib accepted the purchase offer. The purchase was formalized on September 30, 2021.
16 6. As part of the purchase, the parties executed a packet of documents. The packet includes
17 an “Asset Purchase Agreement” (attached as “Exhibit A”), a “Subscription Agreement” (attached as
18 “Exhibit B”), a “Consulting Services Agreement” (attached as “Exhibit C”), and a “Convertible Note”

19 (attached as “Exhibit D”).

20 7. As these documents show, in exchange for Ihear’s assets, Mr. Shennib (and in part, Ihear’s

21 shareholders) were offered: (a) the equivalent of two million dollars ($2,000,000) of Series C Preferred

22 INND Stock, at five dollars ($5.00) per share, (b) a one million dollar ($1,000,000) Convertible Note, (c) a

23 fifty thousand dollars ($50,000) annual salary to Mr. Shennib, and his entity, the Center for Medical Device

24 Innovations, Inc. (“CMDI”), to remain and serve as consultant for INND, and (d) C Shares of Common

25 Stock for INND, equal to one million dollars ($1,000,000). 1

26
1
27 Mr. Shennib owns and operates CMDI. CMDI is a named plaintiff in this action because it is a party to the
Consulting Servies Agreement, Exhibit C. Mr. Shennib created CMDI exclusively to serve as the entity for the
28 consulting services he provided to INND.

-2-
COMPLAINT FOR DAMAGES
1 8. After the purchase, Mr. Shennib and Ihear diligently complied with all their obligations.

2 This includes transferring Ihear’s assets to INND, free and clear of any restrictions. They also transferred a

3 long-term commercial lease to INND for Ihear’s facilities. Mr. Shennib also stayed with INND for 23

4 months to provide the agreed-upon consulting services.

5 9. However, although Mr. Shennib and Ihear performed as they were required, INND and the

6 Moores did not honor their end of the deal.

7 10. First, they intentionally delayed the issuance of the Series C Preferred INND Stock and

8 subsequent conversion to common shares.
9 11. Second, they internationally delayed the conversion of the one-million-dollar ($1,000,000)
10 Convertible Note to iHEAR shareholders (of which Mr. Shennib is a beneficiary).
11 12. Third, they defaulted on the consulting fees owed to Mr. Shennib and CMDI (totaling at
12 least fifty-five thousand dollars ($55,000)).
13 13. Fourth, they never issued the C Shares of Common Stock to Mr. Shenhib.
14 14. Fifth, they stopped paying rent on the commercial lease that Mr. Shennib had assigned.
15 This created additional problems for Mr. Shennib because he was the original guarantor on the lease.
16 15. Mr. Shennib reached out to the Moores on multiple occasions to see what was going on. He
17 tried to understand why they were refusing to follow through on their promises. But Mr. Shennib never got
18 a straightforward answer.

19 16. Eventually, Mr. Shennib learned that he was not the only victim of INND and the Moores’

20 false promises. Mr. Shennib learned that they had entered into similar purchase agreements with other

21 hearing aid companies. But just like they had done with Ihear, they reneged on their promises to those

22 companies as well.

23 17. Apparently, INND was not a successful company at all. That was all a concerted lie.

24 18. INND was just an entity operated by the Moores who were engaging in a “pump-and-

25 dump” scam. Mr. Shennib is informed and believes that the Moores were using INND to purchase the

26 assets of other companies to try and artificially increase INND’s market value. They were then delaying the

27 process of issuing shares to the people from whom they were purchasing the companies to prevent

28 investors from realizing the true extent of INND’s dilution. INND had no inherent value of its own, nor
-3-
COMPLAINT FOR DAMAGES
1 the ability to perform on any of its monetary obligations/other promises.

2 19. To perpetuate the scam, the Moores were going around making false promises and

3 representations to various hearing aid companies.

4 20. Prior to realizing the true extent of the scam, Mr. Shennib tried to reach a compromise with

5 INND and the Moores. In response, INND made even more false promises to him. Although INND

6 eventually issued Mr. Shennib some stock, it placed restrictions on the stock. The stock restrictions were

7 removed only once it was virtually certain that INND’s shares were going to be valueless. Mr. Shennib lost

8 almost all the value he was promised in exchange for the Ihear assets. Had INND honored its original
9 agreement and promises, Mr. Shennib would have received the stock sooner and removed the restrictions
10 sooner. He could have liquidated the stock when it still had value. But, as explained above and throughout
11 this complaint, INND and the Moores intentionally deprived him of this benefit.
12 21. Consequently, Mr. Shennib lost not only the company he founded, but his valuable time
13 and the benefits of his bargain.
14 22. Mr. Shennib is, therefore, suing INND and the Moores, for breach of contract, fraud,
15 fraudulent inducement, violation of SEA Rule 10b-5, and the various other causes of action listed below.
16 23. Mr. Shennib is unaware of the exact amount of his damages, but he believes it exceeds
17 $10,000,000. Mr. Shennib is also seeking punitive damages, penalties, and attorney’s fees, where authorized
18 by law or contract.

19 PARTIES

20 24. Plaintiff, Adnan Shennib, is an individual residing in Oakland, California.

21 25. Plaintiff, CMDI is a Delaware entity, with its principal place of business in Oakland,

22 California.

23 26. Defendants, the Moores, are individuals who, based on information and belief, reside in

24 California. They are owners and directors of Defendant INND.

25 27. INND is a Naveda corporation, with its principal place of business located at 2251

26 Professional Drive, 2nd Floor Roseville, California 95661.

27 28. For simplicity, CMDI and Mr. Shennib shall hereafter be collectively referred to a

28 “Plaintiff.”
-4-
COMPLAINT FOR DAMAGES
1 29. The true names and capacities, whether individual, corporate, associate or otherwise, of the

2 “Doe” defendants are unknown to Plaintiff and, as such, said Doe defendants are being sued under

3 fictitious names. Plaintiff will amend this complaint to insert the true names once known. Plaintiff alleges

4 that the Doe defendants are responsible for the wrongful acts alleged herein and are liable to Plaintiff, in

5 whole or in part, in the same capacity as any other named Defendant(s), either jointly or severally.

6 30. Defendants, inclusive, and each of them, were the agents, employees and co-conspirators

7 engaged in the acts and/or conduct alleged herein, and they acted within the course and scope of their

8 agency and/or employment, and with the permission or consent of each of the other Defendants. Plaintiff
9 is informed and believes, and thereon alleges, that all of the acts alleged herein were ratified by all
10 Defendants.
11 31. Plaintiff is informed and believes, and based on such information and belief, alleges that
12 Defendants, inclusive, and each of them, are all alter egos of one another. Plaintiff is informed and believes,
13 and based on such information and belief, alleges that Defendants, and each of them, comingled assets
14 including personal and corporate funds. Plaintiff is informed and believes, and based on such information
15 and belief, further alleges that Defendants also made important company decisions and performed
16 important company tasks without following the requisite corporate formalities. In fact, The Moores are the
17 owners and directors of INND. INND is undercapitalized and the Moores hold and control all of INND’s
18 assets. Thus, INND is merely a shell for the Moores. Accordingly, there is a unity of interest and ownership

19 between INND and amongst the Moores, such that the separate personalities of the entity and the

20 individuals does not in reality exist. An inequitable result would occur if the acts at issue herein are treated

21 as those of INND alone.

22 32. For simplicity, any reference made throughout this complaint to “Defendants” shall mean

23 INND, the Moores, and all the Doe defendants.

24 JURISDICTION AND VENUE

25 33. The causes of action, all harms, and breaches alleged herein occurred in Alameda County,

26 California. The amount in controversy is also over $25,000. Plaintiff resides in Alameda County, California

27 and is permitted to file this action in this County. Defendants also either reside in California or have a

28 principal place of business in California. Therefore, venue and jurisdiction are proper in this Court/County.
-5-
COMPLAINT FOR DAMAGES
1 FIRST CAUSE OF ACTION

2 Breach of Contract

3 (Against All Defendants)

4 34. Plaintiff incorporates by reference herein all the allegations in the forgoing paragraphs.

5 35. Plaintiff and Defendants entered into a purchase agreement. The various components of

6 the purchase agreement are attached hereto as “Exhibits A-D” (see paragraph 6 above).

7 36. As part of the purchase, Plaintiff was supposed to receive: (a) the equivalent of two million

8 dollars ($2,000,000) of Series C Preferred INND Stock, at five dollars ($5.00) per share, (b) a one million
9 dollar ($1,000,000) Convertible Note, (c) a fifty thousand dollars ($50,000) annual salary to Mr. Shennib to
10 remain and serve as consultant for INND, and (d) C Shares of Common Stock for INND, equal to one

11 million dollars ($1,000,000).

12 37. After the purchase, Plaintiff and Ihear diligently complied with all their obligations. This

13 includes transferring Ihear’s assets to Defendants, free and clear of any restrictions. They also transferred a

14 long-term commercial lease to Defendants for Ihear’s facilities. Plaintiff also stayed with Defendants for 23

15 months to provide the agreed-upon consulting services.

16 38. However, although Plaintiff and Ihear performed as they were required, Defendants did not

17 honor their end of the deal.

18 39. First, they intentionally delayed the conversion of Series C Preferred INND Stock and

19 subsequent conversion to common shares. Second, they internationally delayed the conversion of the one-

20 million-dollar ($1,000,000) Convertible Note to iHEAR shareholders (of which Plaintiff is a beneficiary).

21 Third, they defaulted on the consulting fees owed to Plaintiff totaling at least fifty-five thousand dollars

22 ($55,000)). Fourth, they never issued the C Shares of Common Stock to Plaintiff. Fifth, they stopped

23 paying rent on the commercial lease that Plaintiff had assigned.

24 40. Accordingly, Defendants breached the purchase agreement. As a direct and proximate result

25 of the breach, Plaintiff has been harm and has sustained damages.

26 ///

27 ///

28 ///
-6-
COMPLAINT FOR DAMAGES
1 SECOND CAUSE OF ACTION

2 Fraud

3 (Against All Defendants)

4 41. Plaintiff incorporates by reference herein all the allegations in the forgoing paragraphs.

5 42. Defendants made intentional false representations to Plaintiff.

6 43. The intentional false representations include, but are not limited to, the following: that

7 INND was a successful hearing technology company worth tens-of-millions-of-dollars; that Defendants

8 were genuinely interested in purchasing Ihear’s assets in order to expand their already substantial market

9 share of the hearing aid industry; that they had shares of value that they were willing and able to transfer;

10 that they had the financial resources and means to honor their promises to investors, shareholder, and

11 Plaintiff; that they were not a sham company seeking to artificially inflate their value; and that they were

12 willing and able to issue shares in good faith, which could then be transferred or sold for value.

13 44. The forgoing misrepresentations were material to Plaintiff’s dealings with Defendants.

14 Plaintiff and Defendants owe each other a fiduciary duty, as business partners. Thus, Plaintiff reasonably

15 relied on the false representations of Defendants. These misrepresentations were made by the Moores

16 personally, and as representatives of INND.

17 45. Indeed, Plaintiff eventually learned that Defendants are fraudsters, engaging in an illegal

18 pump-and-dump scheme. Specifically, Plaintiff is informed and believes that Defendants were using INND

19 as a shell entity to purchase assets of other companies to try and artificially increase INND’s market value.

20 They then delayed the process of issuing shares to the people from whom they were purchasing the

21 companies to prevent investors from realizing the true extent of INND’s dilution. INND had no inherent

22 value of its own, nor the ability to perform on any of its monetary obligations/other promises.

23 46. Accordingly, as a direct and proximate result of Defendants’ misrepresentations, Plaintiff

24 has been harmed and has sustained damages therefrom.

25 THIRD CAUSE OF ACTION
Negligent Misrepresentation
26
(Against All Defendants)
27
47. Plaintiff incorporates by reference herein all the allegations in the forgoing paragraphs,
28
-7-
COMPLAINT FOR DAMAGES
1 except paragraph 42.

2 48. Defendants made false representations to Plaintiff which they knew, or should have known,

3 were false, because there was no reasonable basis to believe they were true.

4 49. This includes, but is not limited to, the false representation that INND was a successful

5 hearing technology company worth tens-of-millions-of-dollars, that Defendants were genuinely interested

6 in purchasing Ihear’s assets in order to expand their already growing market share of the hearing aid

7 industry, that they had shares of value that they were willing and able to transfer, that they had the financial

8 resources and means to honor their promises to investors, shareholder, and Plaintiff, that they were not a
9 sham company seeking to artificially inflate their value, and that they were willing and able to issue shares in
10 good faith, which he could then be transferred or sold for value.
11 50. The forgoing misrepresentations were material to Plaintiff dealing with Defendants.
12 Plaintiff and Defendants owe each other a fiduciary duty, as business partners. Thus, Plaintiff reasonably
13 relied on the false representations of Defendants. These misrepresentations were made by the Moores
14 personally, and as representatives of INND.
15 51. Indeed, Plaintiff eventually learned that Defendants are fraudsters, engaging in an illegal
16 pump-and-dump scheme. Specifically, Plaintiff is informed and believes that Defendants were using INND
17 as a shell entity to purchase assets of other companies to try and artificially increase INND’s market value.
18 They were then delaying the process of issuing shares to the people from whom they were purchasing the

19 companies to prevent investors from realizing the true extent of INND’s dilution. INND had no inherent

20 value of its own, nor the ability to perform on any of its monetary obligations/other promises.

21 52. Accordingly, as a direct and proximate result of Defendants’ misrepresentations, Plaintiff

22 has been harmed and has sustained damages therefrom.

23 FOURTH CAUSE OF ACTION

24 Fraudulent Inducement

25 (Against All Defendants)

26 53. Plaintiff incorporates by reference herein all the allegations in the forgoing paragraphs.

27 54. Defendants intentionally made false representations to Plaintiff which they knew, or should

28 have known, were false, because there was no reasonable basis to believe they were true.

-8-
COMPLAINT FOR DAMAGES
1 55. This includes, but is not limited to, the false representation that INND was a successful

2 hearing technology company worth tens-of-millions-of-dollars, that Defendants were genuinely interested

3 in purchasing Ihear’s assets in order to expand their already growing market share of the hearing aid

4 industry, that they had shares of value that they were willing and able to transfer, that they had the financial

5 resources and means to honor their promises to investors, shareholder, and Plaintiff, that they were not a

6 sham company seeking to artificially inflate their value, and that they were willing and able to issue shares in

7 good faith, which he could then be transferred or sold for value.

8 56. The forgoing misrepresentations were material to Plaintiff dealing with Defendants.
9 Defendants made these false representations with the intention of convincing Plaintiff to enter into a
10 purchase agreement, the various components of the purchase agreement are attached hereto as “Exhibits
11 A-D” (see paragraph 6 above). Plaintiff and Defendants owe each other a fiduciary duty, as business
12 partners. Moreover, the false representations were conveyed directly by Defendants, as the only reliable
13 source of such information. Thus, Plaintiff reasonably relied on the false representations of Defendants.
14 These misrepresentations were made by the Moores personally, and as representatives of INND.
15 57. However, as Plaintiff eventually learned, Defendants are fraudsters, engaging in an illegal
16 pump-and-dump scheme. Specifically, Plaintiff is informed and believes that Defendants were using INND
17 as a shell entity to purchase assets of other companies to try and artificially increase INND’s market value.
18 They were then delaying the process of issuing shares to the people from whom they were purchasing the

19 companies to prevent investors from realizing the true extent of INND’s dilution. INND had no inherent

20 value of its own, nor the ability to perform on any of its monetary obligations/other promises.

21 58. Accordingly, because of Defendants’ misrepresentations, Plaintiff was fraudulently induced

22 into relinquishing his interests in his company, Ihear, and into signing the purchase agreement. As a direct

23 and proximate result of result, therefrom, Plaintiff been harmed and has sustained damages.

24 FIFTH CAUSE OF ACTION

25 Fraudulent Concealment

26 (Against All Defendants)

27 59. Plaintiff incorporates by reference herein all the allegations in the forgoing paragraphs.

28 60. Defendants concealed/suppressed material facts, including, but not limited to, the following

-9-
COMPLAINT FOR DAMAGES
1 facts: INND’s true financial condition; that Defendants’ true motives in purchasing Ihear’s assets was not

2 to expand their already growing market share of the hearing aid industry, but to instead artificially inflate

3 the company’s value; that they did not have the financial resources and means to honor their promises to

4 investors, shareholder, or Plaintiff; that they were a sham company; and that they were unwilling and

5 unable to issue shares in good faith, which could then be transferred or sold for value.

6 61. Because Plaintiff and Defendants were business partners and engaged in the sale/purchase

7 of Ihear, they owed Plaintiff a duty to disclose the true facts. However, Defendant intentionally concealed

8 or suppressed the above-listed material fact with the intent to defraud Plaintiff.
9 62. At all material times, Plaintiff was, and remained, unaware of the true facts and
10 detrimentally relied on the misrepresentations of Defendants, by, among other things, transferring assets to
11 Defendants and spending his time working for Defendants without compensation.
12 63. As a direct and proximate result of the foregoing concealment/suppression of material
13 facts, Plaintiff has been harmed and has sustained damages.
14 SIXTH CAUSE OF ACTION

15 Breach of Fiduciary Duty

16 (Against All Defendants)

17 64. Plaintiff incorporates by reference herein all the allegations in the forgoing paragraphs.

18 65. Plaintiff and Defendants owe each other a fiduciary duty, as business partners. This includes

19 the duty of loyalty, the duty of candor, the duty of obedience, the duty of care, and the duty of good faith

20 and fair dealing. Defendants, however, breached those duties.

21 66. Specifically, as alleged above, Defendants made material misrepresentations, concealed or

22 otherwise suppressed material facts, and engaged in conduct that was dishonest. This including, but is not

23 limited to, making false claims about INND true financial condition, making false claims about Defendants

24 true motives in purchasing Ihear’s assets, making false claims or omissions about their true motives, which

25 was to artificially increase the INND’s value, failing to candidly disclose that INND did not have the

26 financial resources and/or means to honor the promises made to investors, shareholder, or Plaintiff,

27 concealing the fact that INND was a sham company, and that Defendants were unwilling and unable to

28 issue shares in good faith, which could then be transferred or sold for value.

-10-
COMPLAINT FOR DAMAGES
1 67. As a direct and proximate result of the foregoing conduct, which constitutes a breach of

2 Defendants’ fiduciary duties to Plaintiff, Plaintiff has been harmed and has sustained damages.

3 SEVENTH CAUSE OF ACTION

4 Violation of Rule 10b-5 of the Securities Exchange Act

5 (Against All Defendants)

6 68. Plaintiff incorporates by reference herein all the allegations in the foregoing paragraphs.

7 69. To prove a violation of the federal antifraud provisions of § 10(b) of the Securities

8 Exchange Act of 1934, 15 U.S.C.S. § 78j(b), and Rule 10b-5 promulgated thereunder, 17 C.F.R. § 240.10b
9 5, a plaintiff must prove that, in connection with the purchase or sale of a security, (1) the defendant made
10 a false statement or omission of material fact (2) with scienter (3) upon which the plaintiff justifiably relied
11 (4) that proximately caused the plaintiff’s damages.
12 70. Here, Plaintiff has made allegations sufficient to establish a violation of Rule 10b-5.

13 71. Specifically, Plaintiff alleges that, as part of the sale/transfer of securities, Defendants made
14 intentional false representations to him. The intentional false representations include, but are not limited
15 to, the following: that INND was a successful hearing technology company worth tens-of-millions-of-
16 dollars; that Defendants were genuinely interested in purchasing Ihear’s assets in order to expand their
17 already substantial market share of the hearing aid industry; that they had shares of value that they were
18 willing and able to transfer; that they had the financial resources and means to honor their promises to

19 investors, shareholder, and Plaintiff; that they were not a sham company seeking to artificially inflate their

20 value; and that they were willing and able to issue shares in good faith, which could then be transferred or

21 sold for value.

22 72. Plaintiff also alleges that the forgoing misrepresentations were material to Plaintiff dealing

23 with Defendants. Plaintiff and Defendants owe each other a fiduciary duty, as business partners. Thus,

24 Plaintiff reasonably relied on the false representations of Defendants. These misrepresentations were made

25 by the Moores personally, and as representatives of INND.

26 73. Accordingly, Defendants’ misrepresentations, which were made as part of the sale/transfer

27 of securities, constitutes a violation of Rule 10b-5. As a direct and proximate result therefrom, Plaintiff has

28 been harmed and has sustained damages.
-11-
COMPLAINT FOR DAMAGES
1 PRAYER FOR RELIEF

2 WHEREFORE, Plaintiff seeks judgment against Defendant and each of them, as follows:

3 1. For general damages according to proof;

4 2. For special damages according to proof;
3. For all penalties and civil damages authorized by law;
5
4. For attorneys’ fees and all costs, where authorized by law and/or contract;
6
5. For pre-judgment and post-judgment interest; and
7
6. For any other relief that is just and proper.
8
9

10 DATED: April 19, 2024 By: /s/ Aren Derbarseghian
Aren Derbarseghian
11 Attorney for Plaintiff
Adnan Shennib and
12 Center for Medical
Device Innovations, Inc.
13

14
DEMAND FOR JURY TRIAL
15
Plaintiff respectfully requests that the claims made herein be heard and determined by a jury.
16

17

18 DATED: April 19, 2024 By: /s/ Aren Derbarseghian
Aren Derbarseghian
19 Attorney for Plaintiff
Adnan Shennib and
20 Center for Medical
Device Innovations, Inc.
21

22

23

24

25

26

27

28
-12-
COMPLAINT FOR DAMAGES
EXHIBIT A TO THE COMPLAINT
InnerScope Hearing Technologies, Inc.,

a Nevada corporation ("Buyer"),

iHear Medical, Inc.,

a Delaware corporation ("Seller")

Dated as of September 30, 2021
Executed Version




ASSET PURCHASE AGREEMENT

THIS ASSET PURCHASE AGREEMENT (this “Agreement”) is entered into as of
September 30, 2021 (the "Effective Date") by and between InnerScope Hearing Technologies
Inc., a Nevada corporation, and a public company trading on the OTCPINK Market exchange
under the stock symbol (“INND”), (“Buyer”), iHear Medical Inc, a Delaware corporation
(“Seller”). Seller and Buyer are referred to collectively herein as the "Parties" and individually
as a "Party."

A. Seller located at 15250 Hesperian Blvd. Suite 102 San Leandro, CA. 94578, (the
“Business Location”) is engaged in, among other things, the operation of manufacturing, and
selling direct-to-consumer and over-the-counter hearing solutions through multiple
wholesale/retail distribution channels (collectively, the “Business”)

B. Subject to the terms and conditions contained herein, Buyer desires to purchase the
"Purchased Assets" (as defined below) from Seller, free and clear of all liens and encumbrances,
and Seller wishes to sell those assets to Buyer as specifically set forth herein (the "Transaction").

ARTICLE I

Seller wishes to sell to Buyer, and Buyer wishes to purchase from Seller, all of Seller’s
right, title and interest in and to the Business and the Purchased Assets, subject to the terms and
conditions set forth herein.

NOW, THEREFORE, in consideration of the mutual covenants and agreements
hereinafter set forth and for other good and valuable consideration, the receipt and sufficiency of
which are hereby acknowledged, the parties hereto agree as follows:

ARTICLE II
PURCHASE AND SALE

Section 2.01 Purchase and Sale of Assets. Subject to the terms and conditions set forth herein,
Seller shall sell, transfer, assign, convey, and deliver to Buyer, and Buyer shall purchase and
acquire from Seller, all of Seller’s assets, properties, and rights, and claims that, as of the date of
this Agreement, are owned, held, or used by Seller in connection with the Business of Seller
currently as conducted or has previously conducted (collectively, the "Purchased Assets"), free
and clear of all liens and encumbrances. Purchased Assets shall include but not limited to set forth
on Exhibit A (the “Purchased Assets”) attached hereto and shall include without limitation: (a)
all supplies and inventories, including finished goods, work-in-process, and raw materials; (b) all
deposits and prepaid expenses, including lease deposits, so long as they relate to contracts in
connection of the operation of the Business; (c) all real property in which Seller has fee simple
title, all leasehold/rental interest of Seller in real property, and all leasehold/rental and tenant
improvements; (d) all furniture, fixtures and equipment; (e) all customers/patient lists, potential
customers/patient lists, referral lists, and all medical customers/patients referrals, and other
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records relating to past and current customers/patients (collectively, "Customer Information");
(f) all lists of suppliers, lists of salesmen, sales reports, cost sheets, bills of material, marketing
literature and material, logos and branding material, and all files, financial and business
information and records of Seller relating to the Purchased Assets or used in the Business; (g) all
computer hardware and Software (including Software licenses); (h) all of Seller's right, title and
interest in and to Seller's name, and any variation or derivation thereof and the tradename "iHear
Medical Inc. and/or “iHear Direct” and/or “iHear" and any derivation thereof and any other
Marks, tradenames, trademarks, and domain names used or contemplated to use in connection
with the Business, to the extent transferable or assignable by law, including but not limited to
brand names, copyrights and trademarks used or useful in connection with the operation of the
Business as currently conducted; (i) all other Intellectual Property owned by Seller or to which
Seller has any rights to or licenses which is useful or usable in the Business; (j) all telephone,
facsimile numbers, keys, access codes, and the like; (k) to the extent assignable, all government
licenses and permits necessary to the conduct of the Business; (l) all manufacturers', vendors' and
suppliers' warranties, to the extent assignable, with or without the consent of the manufacturer,
vendor or supplier, as the case may be, in respect of any asset used in the Business; (m) all
confidential information; (n) all goodwill; (o) all general intangibles, contract claims and other
rights of the Business and all other property owned by Seller and used or useable in the Business;
(p) all documentation in Seller's possession relating to the Purchased Assets; and (q) all other
assets with respect to the operation of the Business including any and all current and past
wholesale/retail distribution contracts and/or arrangements and all product manufacturing supply
chain contracts to include but not limited to all past, current and future product engineering
specifications and designs; (r) all Derivative Work in connection with the operation of the
Business; (s) all Object Code(s) in connection with the operation of the Business; (t) all Source
Code(s) in connection with the operation of the Business.

Section 2.02 Excluded Assets. The Purchased Assets would not include certain assets that the
Seller typically retains in transactions of these types (e.g., cash / cash equivalents, bank accounts,
pre-closing A/R, tax assets, insurance policies, employee files, attorney-client privileged
information, corporate books and records, rights to actions in respect of the foregoing, etc.)

Section 2.03 No Liabilities. Except as otherwise provided herein, Buyer shall not assume, pay,
perform, discharge or become liable for any liabilities, debts, commitments, or obligations of
Seller, whether currently existing or hereinafter created, or which are otherwise related to the
ownership, sale, or operation of the Business and the Purchased Assets (“Liabilities”) up to the
date of Closing; and it is expressly understood and agreed that Seller shall remain liable and
responsible for, all Liabilities of the Business arising prior to the date of the Closing, including,
without limitation, all operating expenses, accounts payable, warranties and guarantees of Seller
related to the ownership, sale or operation of the Business including any products or goods
returned or refundable claims, and any Liabilities owing to third parties pertaining to the
Purchased Assets.

Section 2.04 Purchase Price. The aggregate purchase price for the Purchased Assets shall be an
amount equal to Three Million Dollars ($3,000,000) which shall be payable by Buyer to Seller in
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accordance with the terms and conditions of certain Stock Securities Documents set forth on
Exhibit B attached hereto (the “One Million Dollar ($1,000,000) Convertible Note” and set
forth Exhibit C (the “Two Million Dollars ($2,000,000) Securities Purchase Agreement and
Subscription Agreement” attached hereto (the “Purchase Price”). The Purchase Price shall be
payable at the Closing Date as follows:

(a) The One Million Dollar ($1,000,000) Convertible Note to be paid to the Seller’s 1st Tier
Noteholder(s) as set forth on Schedule 2.04(a) attached hereto.

(b) The Two Million Dollars ($2,000,000) equivalent of Series C Preferred INND Stock at
Five Dollars ($5.00) per each C Preferred Equity Share equal to Four Hundred Thousand
(400,000) Preferred Equity Shares to be paid to Seller’s 2nd & 3rd Tier Noteholders set forth on
Schedule 2.04(b).

Section 2.05 Allocation of Purchase Price.
Seller and Buyer agree to allocate the Purchase Price among the Purchased Assets for all purposes
(including tax and financial accounting) as reasonably requested by Buyer and agreed by their
respective accountants, negotiating in good faith. Buyer and Seller shall file all tax returns
(including amended returns and claims for refund) and information reports in a manner consistent
with such allocation. Notwithstanding the foregoing, transfer taxes would be split by Buyer and
Seller on a 50-50 basis.

Section 2.06 Third Party Consents. To the extent that any of Seller’s rights under any
Purchased Asset (including any contract constituting a Purchased Asset) may not be assigned to
Buyer without the consent of another person or entity which has not been obtained, this
Agreement shall not constitute an agreement to assign the same if an attempted assignment would
constitute a breach thereof or be unlawful, and Seller shall use its commercially reasonable efforts
to obtain any such required consent(s) as promptly as possible. It is agreed by the Parties that
Buyer will occupy the Seller’s Business Location for no less than 6 months starting on the
Closing Date and at the same monthly rate as the Seller’s current month to month rental
agreement as set forth on Schedule 2.06. Seller shall use reasonable best efforts to obtain the
consent of the landlord for Buyer to sign a new monthly rental agreement for the Business
Location.

Section 2.07 Assignment and Transfer of Patent License Agreement. As part of the
Purchased Assets and the Transaction,
Seller will on the Closing Date transfer 100% of interest without limitation to Buyer for all of
Sellers retained Right to Use Patent Licenses with K/S HIMPP agreement executed on February
1, 2021, as set forth on Schedule 2.07 and described in Section 7.2 of the HIMPP agreement.

Section 2.08 Key Employment Agreements. Buyer within 7 days after the Closing Date will
execute employment agreements to key personnel in connection with the operation of the
Business.


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Section 2.09 Asset Repurchase. If at any time prior to the 7 month anniversary of the Effective
Date the Buyer (or any subsequent transferee of any of the Purchased Assets) becomes insolvent,
or generally does not pay its debts as they become due, or admits in writing its inability to pay its
debts, or makes a general assignment for the benefit of creditors, or (a) if insolvency,
receivership, reorganization or bankruptcy proceedings are commenced against any such party,
and such proceedings are not dismissed within sixty (60) days, or (b) if insolvency, receivership,
reorganization or bankruptcy proceedings are commenced by any such party, the Buyer shall
assign and shall cause to be assigned to Seller all of the Purchased Assets upon receipt by the
Buyer of the Purchase Price paid in property of the Purchaser (or the cash value thereof).


ARTICLE III
CLOSING

Section 3.01 Closing. The closing of the Transaction contemplated by this Agreement (the
“Closing”) shall take place simultaneously with the execution of this Agreement on September
15, 2021 (the “Closing Date”) by delivery of documents required to be delivered hereby by
electronic transmission with original documents promptly delivered thereafter to the appropriate
Party. The consummation of the transactions contemplated by this Agreement shall be deemed to
occur at 12:01 a.m. on the Closing Date.

Section 3.02 Closing Deliveries by Seller. In addition to the other requirements of this
Agreement and as a condition precedent to Buyer's obligation to close the transaction
contemplated herein, Seller shall deliver to Buyer at or prior to the Closing, each of which shall
be reasonably acceptable to Buyer:

(a) Tender of the Purchased Assets;

(b) Assignment and Transfer and Patent Licensed to Buyer as set forth in Section 2.07 herein;

(c) Certified copies of resolutions of Seller's shareholders and directors approving the
execution and delivery of this Agreement, all other agreements referenced herein and therein (the
"Seller Resolutions");

(d) A certificate duly executed by an authorized officer of Seller certifying the incumbency of
each officer of Seller signing this Agreement, and specimen signatures of each such officer;

(e) A Bill of Sale and Assignment, duly executed by Seller (the "Bill of Sale"), transferring
all Purchased Assets to the Buyer;

(f) All consents and permits necessary for the consummation of the Transactions
contemplated by this Agreement including but not limited to, termination of any liens on the
Purchased Assets, and termination of any right of first refusal to the sale of the Purchased Assets
by Seller to Buyer that may exist in favor of any other Party.
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Section 3.03 Closing Deliveries by Buyer. In addition to the other requirements of this
Agreement and as a condition precedent to Seller's obligation to close the transaction
contemplated herein, Buyer shall deliver or cause to be delivered to Seller at or prior to the
Closing:

(a) Stock Security Documents for payment as follows:

(i) The One Million Dollar ($1,000,000) Convertible Note to be paid as set forth on
Schedule 2.04(a) attached hereto.

(ii) The Two Million Dollars ($2,000,000) equivalent of Series C Preferred INND
Stock at Five Dollars ($5.00) per each C Preferred Equity Share equal to Four Hundred
Thousand (400,000) Preferred Equity Shares to be paid as set forth on Schedule 2.04(b).

(b) Certified copies of resolutions of Buyer's directors, approving the execution and delivery
of this Agreement, all other agreements referenced herein, and the consummation of the
transactions contemplated herein and therein (the "Buyer Resolutions");

(c) A certificate duly executed by an authorized officer of Buyer certifying the incumbency of
each officer or director signing this Agreement, and specimen signatures of each such officer or
director.

ARTICLE IV
REPRESENTATIONS AND WARRANTIES OF SELLER

Seller makes the following representations and warranties to Buyer, which representations and
warranties shall be true and correct as of the Closing Date. For purposes of this Article IV,
“Seller’s knowledge,” “knowledge of Seller” and any similar phrases shall mean the actual or
constructive knowledge of Seller, after due inquiry.

Section 4.01 Organization; and Capitalization. Seller is a corporation duly formed, validly
existing, with active status under the laws of Delaware, and has full power and authority to own its
properties and to conduct the Business in which it is now or has been engaged in. Seller has the
power to enter into, execute, and deliver this Agreement to which it is a Party and to consummate
the Transaction. The presently authorized, issued, and outstanding shares of Seller and the names
of all of the record and beneficial owners thereof are as set forth on Schedule 4.01, except as set
forth on Schedules 2.04(a) and 2.04(b), there are no outstanding subscriptions, options, warrants,
calls, agreements, demands, commitments, convertible securities or other contracts or
arrangements of any character or nature whatsoever under which Seller or the shareholders of
Seller are obligated to issue, assign, or transfer any equity interests of Seller or the Purchased
Assets.

Section 4.02 Authority; Binding Effect. The execution, delivery, and performance of this
Agreement and the other agreements referred to herein to which Seller is a party and the
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consummation of the Transaction have been duly authorized by Seller and Seller has taken all
other actions required by applicable law or in the Seller's Governing Documents in order to
consummate the Transaction. This Agreement constitute the valid and binding obligations of
Seller and are enforceable against Seller in accordance with their respective terms, except as
limited by (i) applicable bankruptcy, insolvency, reorganization, moratorium, or other laws of
general application affecting the enforcement of creditors' rights generally, and (ii) applicable
laws relating to the availability of specific performance, injunctive relief, or other equitable
remedies.

Section 4.03 Non-Contravention; Approvals. Neither the execution or delivery of this
Agreement or any of the agreements referred to herein, nor the consummation of the Transaction,
does or will:

(a) violate any law t

[tdbowieknife]

It doesn't allow me to download or print anything without going through the pay wall. I only got screenshots of the first few preview pages.


..


.

[Dragon Lady]

Td - Heads up:

Do you have the complaint?? I'm not paying the many dollars to Alameda County for it. One of the most expensive I've seen.

I'm trying to get it off this Trellis scraper site. They use an "image file" is my guess - BUT the entire complaint is there IF we can find a way to fetch it ?

https://trellis.law/doc/208737669/complaint-filed-by-adnan-shennib-plaintiff-center-for-medical-device-innovations-inc-a-delaware-corporation-plaintiff-as-to-innerscope-technologies-inc-a-nevada-corporation-defendant-michael-moore-defendant-mark-moore-defendant-et-al-document


Yeah - me not paying that outrageous Alameda fees either holy cow !!!

It's the BAY AREA of Kalifornia - TELL me why I'm not surprised LOL !!!!

Many Superior courts uh like freaking PLACER COUNTY not even far away in the same damn state and we can read EVERYTHING FOR FREE aka USA-TODAY v INNERSCOPE etc......welcome to Kali-ForniA WTF !!

[Dragon Lady]

👍️

Good find on the new lawsuit filed April 19th for contractual fraud. Unfortunately, ya got to pay big bucks for docs from Alameda County.

Yeah - I saw that. I'm going to barf-up that coin at this point.

Good thing - is right now before any changes are made or new filings are made one can print the Trellis law page and get the entire formal complaint in total.

Just go there and PRINT THE PAGE and it's all there, the entire formal complaint ASAP. Nice as usually they're truncated on those "scraper" sites !!

I'm doing it as your post popped in -

OOPS - standby !!!

I'm trying "print" but no dice LOL !! The website posts an "IMAGE" looks like. Thus, trying to "print" and it truncates.

Let me dink here with it - I "think" I can find a way to save the entire complaint and read top to bottom in total ?

https://trellis.law/doc/208737669/complaint-filed-by-adnan-shennib-plaintiff-center-for-medical-device-innovations-inc-a-delaware-corporation-plaintiff-as-to-innerscope-technologies-inc-a-nevada-corporation-defendant-michael-moore-defendant-mark-moore-defendant-et-al-document

Juicy stuff - Adnan is "speculating" losses as "High as $10,000,000 and plus attorneys fees and punitive" WOW !!! The dude is going for broke - and rightfully so as the MOORE MORE CLAN wiped any "reputation" the poor guy had and wasted as he stated about 2.5 yrs of his life so far and NEVER had a chance in hell or "intent" to pay him etc.

It's the Kurlioff SCAM version 2.0 and IMO only bigger - it's a doosy lawsuit.

I'm getting BK vibes like pegging my instruments off the scale - needle bent kinda pegged and "bitching Betty" screaming in the helmet "EJECT EJECT EJECT" and "PULL UP PULL UP PULL UP" as this POS is about to plow itself into the desert floor in a spectacular ball of flames and heaping wreckage :))

[tdbowieknife]

Do you have the complaint?? I'm not paying the many dollars to Alameda County for it. One of the most expensive I've seen.

..


.

[tdbowieknife]

Good find on the new lawsuit filed April 19th for contractual fraud. Unfortunately, ya got to pay big bucks for docs from Alameda County.

Edit: I see PRCubaDog was keeping track of this one. Be nice to see the complaint.


..

[Dragon Lady]

ALERT: SCRIVNER ERROR "MICHAEL MOORE" LOL !!

"Someone" aka a birdy needs to "tip" the Shennib legal team to AMEND THEIR COMPLAINT ASAP - as they have MICHAEL MOORE LOL !!!

Maybe the law clerk at that firm watches shitty MICHAEL MOORE flicks or WTF..... who knows ????

I think they used "MICHAEL MOORE" not only on the cover BUT in every page of their formal complaint. I hate sloppy legal filings - I mean geez laweez GET THE NAMES RIGHT of the people you're freaking suing !!

EARTH TO Adnan lawfirm: MATTHEW....it be MATTHEW...MATTHEW MOORE aka CEO.....not "MICHAEL" WTF ??????????

I need to get those Plaintiff attorney emails off that cover page - a tad hard to read. They need to amend that filing ASAP as it just looks "sloppy" and they're gonna be going out to process serve the idiot MOORE CLAN so might as well have your damn complaint CORRECT when you hand it to them !!!

https://trellis.law/doc/208737669/complaint-filed-by-adnan-shennib-plaintiff-center-for-medical-device-innovations-inc-a-delaware-corporation-plaintiff-as-to-innerscope-technologies-inc-a-nevada-corporation-defendant-michael-moore-defendant-mark-moore-defendant-et-al-document

[Dragon Lady]

LAWSUIT: PRCuba NAILED iHear "FRAUD" v MOORE CLAN !!

Alameda County Superior Court - that be "San Fran + Silicon Valley" for all intents and purposes for those not familiar and would be "up the road" literally from INNER-CON HQ !!

This is the company MATTY BOY STIFFED in the "buy out" SCAM aka "the iHear guy" aka Adnan Shennib !!!
https://iheardirect.com/

Adnan TOOK BACK his rightfully owned website + company name + trademarks + patents etc and now is SUING THE MOORE MORE CLAN for straight-up FRAUD among numerous other violations of civil/contract law.......

https://eportal.alameda.courts.ca.gov/?q=Home

CASE NO: 24CV072452
(very common numbering for a CA court : 24 = 2024, C = civil, and 072452 is the case number basically)

Shennib et all v Innerscope Technologies a Corporation and Matthew Moore, Kimberly Moore and Mark Lee Moore as individuals.....

FRAUD and and and the real JUICY ALLEGATION: "SECURITIES FRAUD" whoah whoah daddy oh.....oh boy.....this is getting TOASTY HOT for the MOORE MORE CLAN......

SEC regulators often wait on these civil suits - and let them do "Discovery" and un-cover all the dirt and THEN the SEC files CRIMINAL CHARGES as their leg work is all done easy-peasy for them in the civil discovery process and legal filings.....SLEEP LIGHT MATTY BOY.....CLUB FED is in your bad future me thinks.....:))



ADD IT TO THE GROWING SHIT LIST - and FRIDAY NEXT WEEK the $2.5 MILLION MOTHER LOAD CASE of Hessenn Group v INNERSCOPE aka "KIOSK DISPLAY BUILDERS" will be "DEFAULT READY" when the MOORE MORE CLAN fail to answer/respond to "SERVED SUMMONS" on April 26 aka D-DAY.....:))

https://www.pacermonitor.com/public/case/52733622/Hessenn_Group_LLC_v_InnerScope_Hearing_Technologies,_Inc_et_al


**********************************************


********************************* :))))))))))))



*********************************************






https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[Dragon Lady]

MATTY WIFE: RUNS REAL ESTATE FROM HQ BUILDING !!

ADD NEWEST LAWSUIT TOO - gonna be a BAD BAD WEEK and YR for the MOORE MORE CLAN and INNER-CRIME !!

https://trellis.law/case/24cv072452/shennib-et-al-vs-innerscope-technologies-inc-a-nevada-co

New discovery folks - been checking ALL the Moore More clan social media to see :

1) HOW THEY LIVE THE HIGH LIFE while 100% "willingly" stiffing their own employees by FAILING TO PAY THEM WAGES + stiffing vendors for literal $millions and millions etc

2) Monitoring their social media to see their extensive HIGH LIFE such as continuing their "luxury ways" even as they literally robbed shareholders blind in a epic Pump and Dump criminal level con-job, stealing $10's of millions from baghodlers etc.

3) Monitoring for BK watch - any social media clues as to their behind-the-scenes legal scrimmage to avoid paying-out, hiding personal assets while draining INNER-CON cash to $ZERO......etc

WELL - found a "new gem" and nugget of info I'd never seen prior !!

MAGGIE MAY and we ain't talkin the Rod Stewart song here Dely..... (hides her real name of MOORE !!) aka MAGGIE MOORE MORE aka WIFE OF MATTY BOY aka THE PUNK - Ole Maggie.....it appears she's been "Running a real estate biz" out of the 2151 Professional Dr building aka INNER-CRIME PAYS THAT RENT/LEASE + pays the 50% of the building owned by DADDY MOORE MORE aka MORE co-mingling of the public penny stock CON JOB used to pay the MOORE CLAN PERSONAL ENRICHMENT FUND and MILLER HIGH LIFE COUNTRY CLUB GIG n CRIB LIFESTYLE slush fund etc.

https://www.realtor.com/realestateagents/568046520fa417010072aa59
[color=blue]ADDRESS BOTTOM OF PAGE - shazam, the INNER-CON BUILDING !!!

MCM Development

2151 PROFESSIONAL DR STE 200, ROSEVILLE, CA, 95661

[/color]

http://www.maggiemayrealestate.com/
She even had a personal website - I'll ping the history on that one fa sure when I get a bit of time.

https://www.facebook.com/MaggieMayRealEstate/
Has dedicated Facebook under name MAY and not MOORE - nice...hiding that identity from their shitty tainted lawsuit riddled background if you ask me...!!

AND NOTICE - she operated under some likely micro private held LLC named "MCM Development" (Bet that is Maggie C. Moore and/or Maggie C. May aka MCM ?) - wonder how many of the MOORE MORE CLAN are tied to that ??? Will chk CA Secretary of State Site eh :

WHY DOES SHE HIDE HER NAME "MOORE" when conducting her Real Estate biz eh - a bit "tainted" perhaps....LAWSUITS etc....maybe ?

THIS one is going to be "tipped" to every lawsuit plaintiff they're facing - as the MOORE MORES appear almost for certain to be co-mingling funds for self benefit while STIFFING their own employees paychecks owed and creditors owed and vendors owed - THIS might be the golden needle to PIERCE THE CORP VEIL BALLOON going POP.... and go after their personal assets in the too many to count "collection actions" about to get steam rolling here REAL FAST and REAL SOON !!!

It's 100% FOR CERTAIN the wife of MATTY BOY per their social media - not even a doubt the face matches perfectly to their stupid Facebook etc !!

https://www.fastpeoplesearch.com/address/5142-westbury-cir_granite-bay-ca-95746
MAGGIE MAY aka "MOORE" aka 1501 Deer Hollow Way, Roseville aka MATTY BOYS OTHER HOUSE they keep - must be nice !

Maggie May
Roseville, CA
Age: 39
Full Name: Maggie C May
Current Home Address:
1501 Deer Hollow Way
Roseville CA 95661

It lists one of her many prior addresses as no less than 5001 Manchester Ct, Granite Bay aka COUNTRY CLUB MILLER HIGH LIFE CENTRAL - aka the MOORE MORE CRIB n GIG......


Soooooo here so far are the MOORE MORE "social media" aka BK watch and HIDE THE ASSETS WATCH -

X-Twitter of course and the PUMPER PROFUSELY BOY aka MATTY has gone moore MORE silent than a church mouse ......legal issues me thinks....P&D no more MOORE aka self incrimination pumping not allowed by legal counsel if their worth a broken nickel of advice.....

https://www.facebook.com/matthew.moore.5648137
THIS one is going to be "tipped" to every lawsuit plaintiff they're facing - as the MOORE MORES are co-mingling funds for self benefit while STIFFING their own employees and creditors and vendors - THIS might be the golden needle to PIERCE THE CORP VEIL and go after their personal assets in the too many to count "collection actions" about to get steam rolling here REAL FAST and REAL SOON !!!

https://www.facebook.com/MaggieMayRE
Maggie Moore aka Maggie MAY one in the same !

https://www.facebook.com/elizabeth.moore.3152
Elizabeth Moore MORE aka Ho Ho Jr - SELFIE PICS SHOT RIGHT INSIDE THE INNER-CON BUILDING while "on the payroll" WTF ....wanna know where shareholder money got smoked and burned....SHE was shooting selfie-shit pics of "look at my botox fake face" and posting to FacePLANT while "on the company dime" doing absolutely nothing but sucking down a MOORE CLAN PAYCHECK....

As if paying Matty Boy + Momma + Daddy EACH over $220K a piece per yr aka over $1/2 MILLION LARGE ANNUAL for a 99.99% LOSER SHAM STOCK wasn't enough for these cons to live on WTF !!!

Her best FACEPLANT POST - "Oh oh we down here at my BROTHER MATTY BOYS TIME SHARES slumming n beaching lifeing and partying it up in luxury" blah blah blah.....RIGHT UNTIL MATTY BOY FAILED TO PAY and them Time Shares got REPOD LMAO !!! Hell - ya can't make this level of sociopath deadbeat crap up, ya really can't !!

https://www.facebook.com/profile.php?id=100006879939310
Momma MOORE MORE aka EASY BAKE - Ho Ho Sr the book cooker n chief......

https://www.facebook.com/profile.php?id=100070167143939
Daddy Mark Lee MOORE MORE aka THE DON - he scrubbed his face and ALL photos and a shit ton of Youboob etc where he "used to" PAST TENSE pump this shit same as Matty boy - I guess the dude doesn't like the heat of the limelight when the gig goes bad eh ???

https://www.facebook.com/InnerScopeHearing
INNER-CON Corp Facebook - DEAD AS A BENT DOORNAIL since Feb 2023 or so....went SILENT and MIA aka OFF-AIR aka WTF it was their big pump the dump channel....well...one of their many.......

https://twitter.com/inndstock?lang=en
Their X-Twitter PROFUSE PUMP the DUMP channel - now nearly DEAD SILENT....MIA....WHERE DID THEY GO WTF ????

And their Youboob - ain't made a PUMP or HYPE or PROMOTE THE SCAM vid in a loooooong time now....MIA....SILENT....gee why would that be kids...???

https://www.youtube.com/@innerscopehearingtechnolog9211

AND of course we can't forget:
innd.com
DEAD and GONNER - again, why why why would that be ? Too much self incriminating lies and "evidence" LOL ???
Nor worries- here's the entire history of that scam site :

https://wayback-api.archive.org/web/20240000000000*/innd.com

https://web.archive.org/web/20230601082054/https://innd.com/


https://web.archive.org/web/20180805044745/http://www.innd.com/
SCAM CENTRAL -
"MEMORIES....Like the corners of my mind
Misty watercolor memories
Of the way we were.....
"
BS BARBARA STREISAND....it was ALL BS kids......all of "it".....scam central......

Remember the Crown King Twiter PUMP CLOWN SHOW - that was the true JUMP THE SHARK MOMENT when MATTY BOY aka THE PUNK paid for and flew-out to HQ scam central one of the dirtiest and most notorious PENNY HUSTLERS on all of then Twitter - I've got the photo below of MATTY BOY posing with that ass-hat criminal con....in front of a stack of ALIBABA DILUTION BOUGHT SHIT ....which STILL hasn't been sold to this day LMAO !!!

https://twitter.com/onlycrownking?lang=en
THAT criminal STINKY PINKY pumper clown - yepper....never forget folks....!!

For Dely today - a ZZ TOP GOLDEN MOLDY RONCO RE-SPIN and REPLAY crap-o-matic Series SPECIAL.....$9.99 on VHS tape :

THEN - MATTY "STIFFED" ole ZZ for like $800 bucks to PUMP THE STOCK LMAO ....STIFFED HIS PAID-CON PROMOTER....don't get no better than that !!!


LAWSUIT "WATCH" Week of April 21 2024 :

https://trellis.law/case/24cv072452/shennib-et-al-vs-innerscope-technologies-inc-a-nevada-co
HOT OUT OF ALAMEDA COUNTY (Bay Area Cali for those not familiar !) - MOORE CLAN + INNER-FRAUD newest lawsuit filed days ago - it's GAME OVER boys n girls.....lights out "soon" and I mean like seconds hand on the count down clock to BK kinda soon......:))

https://www.pacermonitor.com/public/case/51022939/Ledbetter_et_al_v_Innerscope_Hearing_Technologies,_Inc_et_al

https://www.pacermonitor.com/public/case/49235021/Kuriloff_v_InnerScope_Hearing_Technologies,_Inc_et_al

https://www.pacermonitor.com/public/case/52733622/Hessenn_Group_LLC_v_InnerScope_Hearing_Technologies,_Inc_et_al

PLACER COUNTY SUPERIOR COURT :

https://www.placer.courts.ca.gov/online-services/online-case-access

Case Number Case Name Filing Date Case Type Category Next Event Previous Event Status
S-CV-0051790 LOCALIQ INDY STAR vs. INNERSCOPE HEARING TECHNOLOGIES, INC., a Nevada corporation 12/08/2023 Civil-Roseville Contract: Collections (09) 07/15/2024 2:00 PM Case Management Conference in Department 6 04/08/2024 2:05 PM Case Management Conference in Department 6 Open
S-CV-0051784 INDIANAPOLIS STAR vs. INNERSCOPE HEARING TECHNOLOGIES, INC., a Nevada corporation 12/07/2023 Civil-Roseville Contract: Collections (09) 07/15/2024 2:00 PM Case Management Conference in Department 6 04/08/2024 2:05 PM Case Management Conference in Department 6 Open
M-CV-0084231 Air Sea Container Line Inc. vs. Innerscope Hearing Technologies Inc. 06/16/2023 Civil: Limited-Roseville Contract: Collections (09) 04/15/2024 3:30 PM Order to Show Cause in Department 6 Open

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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[PRCubaDog]

Adnan accuses the Moore's of running a pump and dump scam in his lawsuit!

[trading.jeff]

Just because he's a shareholder means insider trading???? Most court information is public, but nice try, anyway. BWAHAHAHAHAHAHAHA!!!!!

[PRCubaDog]

Game over! Adnan vs INND

https://trellis.law/case/24cv072452/shennib-et-al-vs-innerscope-technologies-inc-a-nevada-co

[mattolotmoney]

correct ..read it ADNAN NOT IHEAR .. WE OWN IHEAR LOL TELLS ME ADNAN AND KURILOFF ARE PISSED THAT THEY SEE THE REVENUES ARE CURRENTLY POURING IN AND THEY WANT THEIR COMPANIES BACK ..LMAO NOT GONNA HAPPEN . MATT OBVIOUSLY HAS NOTHING TO HIDE OR WORRY ABOUT .HE DIDNT GIVE INTO TO ADNANS DEMANDS .....ADNAN WILL BE COUNTERED LOL what's even better pr is we got you and dragon on insider trading as you are are stock holders of innd and having this information 3-4 weeks before it went public is insider trading ..id be concerned i have all your posts stating you have someone on the inside saved ..id be CAUTIOUS .....matt will counter with same powerful counter against kuriloff.... big deal WE STILL GOT IHEAR AND WILL NEVER RETURN IT TO ADNAN

[PRCubaDog]

What do we have here!!! Adnan vs INND

https://trellis.law/case/24cv072452/shennib-et-al-vs-innerscope-technologies-inc-a-nevada-co

[PRCubaDog]

Correction lawsuit from Adnan incoming

[PRCubaDog]

Ihear lawsuit coming any day now! Wait and see!

[PRCubaDog]

OUT OF STOCK AT WALMART
NOT SELLING ANYWHERE
CHINESE JUNK

[mattolotmoney]

lmao this clown pulls crap out of his you know what... he is obviously a paid hack ..he been making shiat up since day 1... where is the ihear lawsuit you been screaming about for months..where is it..show us .. wanna be cub scout field medic

[tdbowieknife]

Thats a good possibility. And will very likely bring more questions of theft and fraud, and maybe interest from the SEC...

.

Buyer Beware



..

[Dragon Lady]

INNER-CRIME: 50% SPREAD = OTC SCAM TICKER !!!

Look boys n girls and even Dely too - ANY STINKY PINKY POS crime scene that is on a DAILY 50% SPREAD is a SCAM SCAM SCAM SCAM SCAM....insert 1000X more SCAMS......it's a SCAM TICKER.....thee end.....nothing more needs to be said......

The ONLY ones left on the Bid/Ask are the "who's who" of gutter dilution MM's AND "paid to move the dog shit" institutional "share handlers" aka Fidelity and Big Bank Inc etc who MOVE DOG SHIT DILUTION/LARGE BLOCK DUMPS for the likes of Kurlioff un-loading his BILLION shares and the MOORE MORE CRIME CLAN never ending dilution trickle-spout to FUND THE LAST DAYS.....etc......

NO retail is moving this shit ticker 50% spreads for months and on a daily basis - this is DEATH BED TRADING NOW......last day....thee end is in sight....and game over at the MOORE MORE CRIME CLAN GIG n CRIB......MILLER HIGH LIFE COUNTRY CLUB SPREAD....it's about to go lights out.....:))

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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[Dragon Lady]

INNERCON THEORY: FILING WAS SET-UP FOR BK ?

I've got a theory as to why this SCAM filed the cooked-books worthless "alternative filer" and totally un-audited scam filing - and why they "might" file ONE LAST Qtr filing in less than 30 days from now.......

https://www.otcmarkets.com/stock/INND/disclosure

Their crap-o-matic filing (not worth the paper it was printed on).... it shows...IMO "with intent and by design"....shows they are BUSTED BK BROKE !!!

I "think" this may have been done (and the MOORE MORE CRIME CLAN intentionally drained the cash line to just shy of literal $ZERO.... w/ intent) may have been done to show the lousy $2K cash against JUST accounts payable of almost $19 ma ma MILLION LARGE OWED.... (bills due NOW or 30 to 45 days max from Dec 31 which means past due now already)....ALL done "with intent and mal intent"..... to show a BK and/or a lawsuit judgment holder and/or CREDITOR COLLECTION ACTION aka Lebetter SIX SIX SIX aka Kurlioff aka Hessenn group aka USA-TODAY/Gannett...et al.....that....

"Hey bros n dude n law firms - we'd really love to pay you BUT LOOK AT OUR FILINGS MAN...we gots $2K bills left in da bank and we gots a penny stock on a 50% scam spread now and going more ill-liquid that a slab of granite at the GRANITE BAY MOORE CRIME CRIB COUNTRY CLUB MILLER HIGH LIFE GIG n CRIB....and we gots $19 MIL LARGE owed to some bad homres....so.... bros n dudes.... we owes them bad dudes and is trying to pay at like $50 a weeks to our bookmakers...we on the 6,435 day re-pay bookie payments plan and gots Gabe Sayegh GS capital ons our ass too froms NY and he say he gonna break Matty's knee caps or slam his hand n da trunks of a 1974 Lincoln Continental....ouch dudes ....sooos bros n collection agencies n shit....ya can'ts get blood from a turnips and we'll just be forced to gos BK on ya alls or ya can just sit n pound sand...it's all in our super duper annual filing" blah blah blah......

THAT is why I think they even wasted time and a few dilution bucks to file - to "SHOW THEIR BK PROOF" and get it on the record to shield the MOORE MORE CLAN private assets.....

NO WAY does MATTY BOY aka THE PUNK aka SPAZ BOY aka the talking puppet clown of daddy MARK LEE MOORE MORE ...do those two ass hats believe for a NY nano-second that their Alibaba CRAP-o-Matic SHIT-n-EAr-CaNs are suddenly going to start selling....when they have NEVER sold worth a broken wooden nickels' worth.....ever.....the fugazi is up....the smoke n mirrors crime scene is exposed.....it's ALL up to the civil court action now and "maybe" down the road a criminal DOJ/SEC and or some state AG criminal charges for MATTY BOY and DIRTY DADDY MARK LEE MOORE MORE aka THE DON to take their trip to CLUB FED ........

This filing to me looks like "LAWSUIT COVER-FIRE and POP SMOKE-a-CON" - their last shot at running some interference and setting-up the LAST BILLION SHARE DUMPER to "fund their BK filing" and then let the fat lady sing and last one out hit the one light switch left and install the missing door knob for Dely.....

I "bet" the MOORE MORE CRIME CLAN keep the shell just barely alive on life support aka keep it from being a revoked ticker and re-spin the crime scene a few yrs down the road with some new pump and dump scheme or getting a partner to re-light some new-old scan n con....their sociopahts....serial grifter cons...

ONLY "hope" is these big mother load companies SUE THEM INTO POVERTY by piercing the corporate veil and driving both MOORE CLAN households into personal BK and life in a VAN DOWN BY THE DIRTY RIVER.....again....thus their spending their last coin on the shit-filing....they HAD TO SHOW....dudes we gots $2K cash on them corporate books and we tried our damned hardest to "sell some shitty hearing aids"....sort of.....while paying ourselves like running a Fortune 500 real biz......

We'll know by when the Q-1 filing is due + the outcome of these big-hitter mother load lawsuits ALL about to go DEFAULT JUDGEMENT no later than early May it appears to me - IF THIS IS A BK END GAME HERE.....at a 50% spread and near ZERO dollars per day now and silence from INNER-CRIME...the dilution days to get out of the scam are OVER.....they can flip those last BILLION share up into the common for diluting but but but they would fetch not even .0001 IF even a micro sell a day occurred .....the buy-side is deader than a corpse on Halloween and NOTHING is gonna re-pump this stinky pinky crime scene now......

STILL WAITING ON ATTORNEY SCAM LETTER - so they ain't even out of the woods yet on their crappy annual.....MOMMA MOORE MORE aka EASY BAKE aka Ho Ho Sr she owes us the Q-1 filing on MAY 15th 2024.....or she be LATE as always......

That's the "battlefield analysis" as I see it this AM - did my recon and that's what I come up with or some variant very close to that.....

I think we're in the bottom of the 9th and INNER-CRIME is down in the hole so low they can never get out now......just buying time and treading water....MAYBE TO BROKE TO EVEN PAY FOR BK.....literally......they sure as hell are DEAD SILENT and that is also a ACE UP THE BUTT card of Matty thrown on the table...it's looking grim in Roseville....the reaper is knocking and has their numbers......:))

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https://www.speechandhearing.ca.gov/forms_pubs/20171006_mcdonald.pdf

https://www.theunion.com/news/local-news/state-settles-suit-against-mcdonald-hearing-aid-centers/article_05558dac-3602-55f1-b9c5-5199716692cb.html

[PRCubaDog]

💀💀💀💀💀

[PRCubaDog]

The only knowledge we have here is that Matt couldn't run a profitable lemonade stand even if he was given all the lemons, sugar and cups for free.