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I haven't seen anything yet about that
Then two more
Time - Volume - Price
11:17:54 - 2000000 - 0.0004 +
11:14:42 - 5000000 - 0.0004 +
10:09:42 - 12500 - 0.0004
They say "All tests are conducted AAOB and ISO 17025 Accredited labs"
but they're not accredited, so they don't do the tests themselves
http://www.a2la.org/dirsearchnew/newsearch.cfm
Maybe she knows more
JoAnn Haberl
Sales and Marketing Director at Inohealth
Tampa/St. Petersburg, Florida Area
http://www.linkedin.com/pub/joann-haberl/21/967/84a
INOHEALTH PRODUCTS, INC.
State of Delaware
Department of State: Division of Corporations
Entity Details
File Number: 4771382
Incorporation Date / Formation Date: 12/30/2009
Entity Name: INOHEALTH PRODUCTS, INC.
Entity Kind: CORPORATION
Entity Type: GENERAL
Residency: DOMESTIC
State: DE
REGISTERED AGENT INFORMATION
Name: AGENTS AND CORPORATIONS, INC.
Address: 1201 ORANGE STREET, SUITE 600 ONE COMMERCE CENTER
City: WILMINGTON
County: NEW CASTLE
State: DE
Postal Code: 19801
Phone: (302)575-0877
I've only talked to Brian once back in Aug 2009
SENTINEL RENEWABLE ENERGY OF ORANGEBURG, LLC
DOMESTIC/FOREIGN: Domestic
STATUS: Good Standing
STATE OF INCORPORATION/ORGANIZATION: SOUTH CAROLINA Profit
REGISTERED AGENT INFORMATION
REGISTERED AGENT NAME: PETER KATZBURG
ADDRESS: 104 ISLAND PARK DR
CITY: CHARLESTON
STATE: SC
ZIP: 29492
SECOND ADDRESS:
FILE DATE: 09/28/2010
EFFECTIVE DATE: 09/28/2010
http://www.scsos.com/index.asp?n=18&p=4&s=18&corporateid=595753
Florida Profit Corporations
Filing Information
PINNACLE ENERGY, INC.
Status - INACTIVE
Last Event - ADMIN DISSOLUTION FOR ANNUAL REPORT
Event Date Filed - 09/24/2010
http://www.sunbiz.org/scripts/corevt.exe?action=DETEVE&inq_doc_number=P08000086395&filing_type_fld=DOMP
MET, S.C. INC.
Status - INACTIVE
Last Event - ADMIN DISSOLUTION FOR ANNUAL REPORT
Event Date Filed - 09/24/2010
http://www.sunbiz.org/scripts/corevt.exe?action=DETEVE&inq_doc_number=P09000061337&filing_type_fld=DOMP
SUN, S.C. INC.
Status - INACTIVE
Last Event - ADMIN DISSOLUTION FOR ANNUAL REPORT
Event Date Filed - 09/24/2010
http://www.sunbiz.org/scripts/corevt.exe?action=DETEVE&inq_doc_number=P09000061341&filing_type_fld=DOMP
I don't know
That's all the info there is regarding the case
Don't forget the SYNJ and Sy-Med websites
They need updating too...
This site is temporally under construction for amendments.
Thank you for your patience.
McCutcheon Marshall, Jr.
President Sentinel Renewable Energies, South Carolina.
http://syndicationinc.net/sentinel_renew.php
Sy-Med Chiropractic & Spinal Decompression Centers for Doctors
2.0 Public Status. The company is currently a wholly owned subsidiary of the public owned Company Syndication Inc. (SYNJ.PK) on the NASDQ, Over the Counter Bulletin Board.
http://www.sy-medchiropractic.com/employment_gaithersburg_spinal_decompression_centers_montgomery_county_md.php
I second that
Great DD Capt
I just don't understand
Vucicevich, who defended himself, told OSC commissioner Patrick Lesage Tuesday that he preferred to be sentenced after all the evidence about the scheme had been submitted and the roles of each participant made clearer.
Looks like they have point there, but I'm not an attorney so what do I know.
Thanks for the update
You're welcome
Atlas Capital Partners
BETTER ENVIRONMENT CONCEPTS INC.
Initial Disclosure Statement August 20, 2010
Item XV. The name, address, telephone number, and e-mail address of each of the following outside providers that advise the issuer on matters relating to the operations, business development and disclosure:
COUNSEL: Chris Davies, Esq.
2234 N. Federal Highway Suite 300
Boca Raton, FL 33431
Telephone (561) 289-9780
chris@atlascapitalpartners.org
http://www.otcmarkets.com/otciq/ajax/showFinancialReportById.pdf?id=36018
ATLAS CAPITAL PARTNERS LLC
2234 N. Federal Highway Suite 330
Boca Raton, Florida 33431
ph: (561) 488-7624
fax: (561) 488-7623
info@atlascapitalpartners.org
Atlas Capital Partners is a dynamic investment and consulting firm organized to invest in public and private companies. Our mission is to ensure that you meet your financing objectives by by providing management $1 million to $20 million to finance their vision and the business and financial advice execute on that vision. We also provide bridge loans as one of our financing options. These loans are available to all of our clients that may be receiving larger financing packages from us or as a stand-alone option.
We can provide financial, legal and business strategy expertise as requested. Our staff of professionals specialize in providing quality value- added strategies and legal advice to assist you with meeting your operational goals and objectives. For those companies that seek to go public in order to take advantage of capital markets, we are your one stop shop. We can provide all of the services necessary to take your company public without incurring significant legal fees and costs. Our staff of professionals will allow you to focus on your business while we undertake all of the steps necessary to take your company public. We handle all of the required registrations, filing and documentation. We can provide this service regardless of whether we provide you financing.
Finance Options
$1 MILLION TO $20 MILLION IN FINANCING
For our clients, Atlas is able to provide the most flexible financing arrangements based on your business model and financial circumstances. We can provide $1 million to $20 million as a private equity investment in your company. This is the easiest and quickest form of financing we provide and it can be arranged in less than three weeks. We specialize in closing deals. It is our business.
BRIDGE LOANS
We understand that companies occassionally require short-term capital to meet certain objectives and business goals. We provide the most flexible bridge loans in the industry. Our primary focus is to help you succeed. Please let us know if we may provide you a bridge loan.
Executive Management
Christopher Davies, Chief Executive Officer
Chris is a founding member of Atlas Capital Holdings, Inc. Prior to joining the Company he served as the Senior Managing Attorney and Corporate Secretary for Office Depot, Inc., a $15 Billion fortune 150 company listed on the New York Stock Exchange. At Office Depot, Chris was responsible for all of Office Depot’s corporate finance and securities transactions and compliance activities. He was also responsible for developing and structuring the company’s investments and financing opportunities in the U.S and overseas. Chris also was responsible for managing all of Office Depot’s overseas financing strategies and initiatives and executing them in coordination with the company’s treasury and finance groups. Chris also served as Office Depot’s lead attorney for all of the company’s mergers and acquisitions in the U.S. and Canada. Chris has spent more than 5 years counseling Office Depot’s executive management on finance, securities and corporate acquisitions and joint ventures in the U.S. and overseas. Prior to joining Office Depot, Chris represented some of the largest companies and financial institutions at the law firm of Kirkpatrick & Lockhart, Nicholson, Graham. The law firm has over 1000 attorneys and Chris lead the securities and finance group representing corporations and investment banks in finance, securities compliance, public stock offerings, mergers and acquisitions, and other general corporate matters. In addition, Chris has structured financial products for hedge funds and investment banks looking to expand their product offerings. He has also developed business development strategies for financial institutions entering new markets. Chris received his J.D. from the University of Notre Dame Law School and his undergraduate degree from Southern Illinois University at Carbondale.
http://atlascapitalpartners.org/
Post Unavailable
Additional Information
Domain Name: betterenvironmentconcepts.com
Created on: 2009-06-29 23:33:15
Expires on: 2011-06-29 23:33:15
Last Updated on: 2010-06-30 06:38:51
www.betterenvironmentconcepts.com
Cloyce Riddle, CAPP™
Senior Business Consultant
Nevada Corporate Headquarters, Inc.
Phone: 1-877-624-2677 ext. 3115
Cell: 702-239-0423
http://www.assetprotectionsociety.org/?a=PG:2467
The German Marshall Fund of the United States
1744 R Street NW
Washington, DC 20009
United States
Tel: +1 202-683-2650
Fax: +1 202-265-1662
E-mail: info@gmfus.org
http://www.gmfus.org/
The German Marshall Fund’s Washington, DC, office serves as the headquarters for GMF’s global activities. Located steps from Dupont Circle in the U.S. capital, it is an excellent location for convening leading thinkers, diplomats, and government officials from both sides of the Atlantic on every transatlantic issues, and often on those yet to arise.
Similar to the work carried out in all of GMF’s offices, the office manages grants, proposals, and exchange programs; it holds seminars, meetings, and other dialogues; and it produces original scholarly work. While most of GMF’s activities are shared across seven offices—including locations in Berlin, Bratislava, Paris, Brussels, Belgrade, Ankara, and Bucharest—the DC headquarters serves as home to the management, administration, and external relations practices of the organization. The U.S. components of flagship programs such as the Marshall Memorial Fellowship, the Transatlantic Trends annual survey, and the Transatlantic Academy are also based in Washington, as are the Foreign Policy & Civil Society and the Economic Policy programs.
Staff
Brent Riddle
Senior Program Officer
Comparative Domestic Policy
briddle@gmfus.org
http://www.gmfus.org/cs/about_gmf/staff
Partnerships
Fundación BBVA
http://www.gmfus.org/cs/partnerships
Fundación BBVA
Paseo de Recoletos, 10
28001 Madrid. SPAIN
Tel.: (+34) 91 374 54 00
Fax: (+34) 91 374 85 22
http://www.fbbva.es/TLFU/tlfu/ing/home/index.jsp
Carlos Serrano
Washington, DC
(202) 623-2877
http://www.iadb.org/aboutus/IV/directory_detail.cfm?notemplate&id=20462&lg=EN
Since June 2005, Carlos serves as Senior Financial Specialist at the Inter-American Development Bank in Washington D.C. Before joining the IADB, he was a Senior Vice-president & Head of The Americas Group & Europe at BBVA International Financial Institutions, in Madrid. In total he spent 18 years with BBVA, where he has held numerous positions both in Spain and overseas, including several years in Tokyo as Chief Representative for Capital Markets & Investment Banking for Asia-Pacific.
Nice find Capt
I know what I expect next
A filing for the FIRST quarter of this year.
I could always set my expectations real high and hope for ungagging the TA.
Hey man, stop harshing on our buzz...
If people want dividends, give them some and let people enjoy them
So the question is, what company is it?
"and a 10% common stock dividend of the purchasing company to be paid to the shareholders of Syndication Inc."
"the distribution of a 3rd party dividend on a specifically designated asset of a Public Company is a uniquely gymnastic legal maneuver."
HIRU ad on Alphatrade
http://www.alphatrade.com/ads/HIRU/thanks.html
You're spot on timmage
If a Judge doesn't agree with a motion, they will deny custodianship. That's it, easy as pie. State law allows it and the process will keep on going and going until the law is changed.
http://investorshub.advfn.com/boards/read_msg.aspx?message_id=54106104
http://investorshub.advfn.com/boards/read_msg.aspx?message_id=54106095
http://investorshub.advfn.com/boards/read_msg.aspx?message_id=54106093
I remember you from the other site
I'm known as Voo... over there
What a ride it was and I can't wait to see what happens with the court stuff
I went to the Conversion Solutions Holdings School of Due Diligence
Also known as CSHDD
You are correct sir
EATR - Eastern Asteria, Inc.
Record Date: 7/31/2010
Payment Date: 9/10/2010
Dividend Type: Stock Div. payable in another company Dividend
Notes: +.0013 of a restricted share of bNet Communication, Inc. for each held. Will not be quoted Ex.
http://www.otcbb.com/asp/dividend.asp?sym_id=EATR&dDate=7/31/2010&sDateType=Record_date
Hopefully this is it
FORM 10-Q
For the quarterly period ended June 30, 2010
On June 3, 2010, we and Regent Trend Investment Ltd. (soon to be Milestone Biofuels Limited) (“Milestone”) announced an amendment to our non-binding MOU, dated March 12, 2010 to extend the due diligence period an additional 90 days to August 25, 2010 to more fully explore the opportunities available for both parties.
As previously disclosed, the MOU contemplates a strategic relationship between Milestone and us, including a $20 million direct equity investment in us and collaboration with Milestone to fund a joint venture to develop and operate biofuel production plants in the continental United States with a production capacity of 250 million gallons per year. In addition to satisfactory completion of due diligence, any transaction also remains subject to negotiation and execution of definitive agreements and board approval by both parties. The transaction obtained shareholder approval as required under NASDAQ listing rules, at our annual shareholders’ meeting on July 8, 2010.
On August 5, 2010 the Company appeared before a NASDAQ Continued Listing Hearing Panel to present a plan to regain and sustain compliance with the NASDAQ continued listing standards. The Company was deficient on two continued listing standards as of June 30, 2010 when we reported negative stockholders equity of approximately $1.1 million.
The Company offered to the panel that closing of the August 2010 registered direct offering coupled with the subsequent negotiated settlement payments and the conversion of the 90-day secured convertible Notes results in increases in the Company’s stockholders equity. The Company also stated that it expected to be in compliance with the stockholders equity requirement when it files its Form 10-Q for the period ending September 30, 2010.
The Company believes it has the catalysts in place for share price appreciation and long term continued listing standard compliance. With working capital the Company anticipates executing on the short term objectives of reinitiating production activities, shipping fuel out of Baltimore and signing additional sales contracts over the next couple of months. The Company also intends to continue work towards completing the potential Regent Trend Investment Ltd., or Milestone, joint venture agreement and also to continue pursuit of power generation opportunities.
Clark County District Court – Nevada
SHAREHOLDER ADVOCATES, LLC VS. CLEAR CHOICE FINANCIAL, INC.
Clark County District Court – Nevada
SHAREHOLDER ADVOCATES, LLC VS. OMEGA VENTURES GROUP, INC.
Clark County District Court – Nevada
SHAREHOLDER ADVOCATES, LLC VS. RADIAL ENERGY, INC.
Clark County District Court
08/18/2010
Dismissal Pursuant to NRCP 41 (Judicial Officer: Cory, Kenneth)
Debtors: Infinite Networks Corp. (Other)
Creditors: Shareholder Advocates, LLC (Petitioner)
Judgment: 08/18/2010, Docketed: 08/25/2010
08/23/2010
Motion for Appointment (3:00 AM) (Judicial Officer Cory, Kenneth)
Petitioner's Application for Appointment of Custodian
GL COMPANY FOR SRE, LLC.
DOMESTIC / FOREIGN: Domestic
STATUS: Good Standing
STATE OF INCORPORATION / ORGANIZATION: SOUTH CAROLINA
Profit
REGISTERED AGENT NAME: GRANT A. LIVERETT
ADDRESS: 702 CUNNINGHAM ST
CITY: DANIEL ISLAND
STATE: SC
ZIP: 29492
FILE DATE: 04/20/2010
EFFECTIVE DATE: 04/19/2010
DISSOLVED DATE: / /
Corporation History Records
CODE FILE DATE COMMENT Document
Domestic LLC 04/20/2010 SCBOS Filing: AT WILL
http://www.scsos.com/index.asp?n=18&p=4&s=18&corporateid=582157
PINNACLE ENERGY, INC. v. JOHN CALFEE MULVANA as an individual; the LAW OFFICES OF JOHN C. MULVANA; and DOES 1 through 5, inclusive
Plaintiff, Pinnacle Energy, Inc. ("Pinnacle"), by and through its attorneys, Duane Morris LLP, submits this Verified Complaint For: (1) Breach of Contract;
(2) Breach of the Covenant of Good Faith and Fair Dealing;
(3) Money Had and Received; and
(4) Injunctive Relief against Defendants John Calfee Mulvana ("Mulvana"); the Law Offices of John C. Mulvana ("Law Offices"); and DOES 1-5, inclusive, (Mulvana, Law Offices, and DOES are hereinafter sometimes collectively referred to as the "Defendants"), and alleges as follows:
PARTIES AND JURISDICTION
1. Pinnacle Energy, Inc. is a corporation incorporated in the state of Florida with its principal place of business in Charleston, South Carolina.
2. On information and belief; John Calfee Mulvana is a resident of the state of California and presently resides in Orange County, California. At all relevant times herein, Mulvana was and is licensed to practice law in the State of California
3. On information and belief, the Law Offices of John C. Mulvana is located at 100 Pacifica Suite 220, Irvine, California 92618.
4. The true names and capacities, whether individual, corporate, associate, or otherwise, of the defendants herein named as "DOES" 1-5, inclusive, are unknown to Pinnacle, who therefore sues said defendants by such fictitious names pursuant to Code of Civil Procedure section 474, and Pinnacle will amend this Complaint to show their true names and capacities when the same have been ascertained. Pinnacle is informed and believes that all defendants fictitiously sued herein as "DOES" 1-5, inclusive, are in some manner responsible for the acts herein alleged.
5. Pinnacle is informed and believes that at all relevant times mentioned herein, each of the Defendants was the agent, servant, representative, partner, joint venturer, alter ego, coconspirator, and/or employee of each or some of the other Defendants, and in doing the acts mentioned herein was acting within the course and scope of their authority as such and with the express and/or implied approval, permission, knowledge, consent and ratification of all Defendants.
6. Venue is proper pursuant to California Code of Civil Procedure section 395.
7. Pinnacle reserves the right to amend this Complaint upon discovery of new evidence supporting other causes of action.
FACTUAL BACKGROUND
8.Pinnacle entered into a Memorandum of Understanding ("MOU")(1), with Grant A. Liverett of GL Company for SRE, LLC on April 20, 2010. A true and correct copy is attached as Exhibit A.
(1)The MOU was signed by Peter Katzburg, a treasurer/financial officer with Pinnacle. Pinnacle is a start-up company. By and through this transaction, Katzburg committed virtually all of Pinnacle's operating capital to a transaction the validity of which is highly questionable. Pinnacle reserves all of its rights against Katzburg, and others as to the transaction.
9.Pursuant to the terms of the MOU, Pinnacle was to deposit five hundred ninety-two thousand, nine hundred and sixty-eight dollars and seventy-five cents ($592,968.75) (the "Funds") into an escrow account in exchange for the issuance of a valid Standby Letter of Credit for five million dollars ($5,000,000.00).
10. The Funds were to be held in an escrow aecount controlled by the "Neutral Holder", Mulvana and Law Offices.
11. Execution of the Neutral Holder Agreement, which defined the duties of the Neutral Holder, was required by the MOU (Page 2, paragraph 2). Pursuant to the MOU, Liverett was required to execute the Neutral Holder Agreement.
12. A Neutral Holder Agreement was executed by Liverett and Mulvana and a second party on or about April 16, 2010. A true and correct copy of the Neutral Holder Agreement in the form it was delivered to Pinnacle is attached as Exhibit B.
13. Both the MOU and the Neutral Holder Agreement require that Liverett deliver a valid Standby Letter of Credit to Pinnacle within 21 banking days after the escrow funded.
14. Pursuant to the MOU (Page 3), if Liverett failed to deliver a valid five million dollar ($5,000,000.00) Standby Letter of Credit to the Neutral Holder within 21 banking days after the escrow funded, then on Pinnacle's demand the Neutral Holder was required to return the Funds held by him in escrow to Pinnacle without delay.
15. Pursuant to the Neutral Holder Agreement (page 3, paragraph I), if the valid five million dollar ($5,000,000.00) Standby Letter of Credit was not delivered to Pinnacle and Pinnacle's bank account within 21 banking days after the escrow funded, then on Pinnacle's demand the Neutral Holder was required to return the Funds held by him in escrow to Pinnacle without delay.
16. On May 24,2010, Pinnacle funded the escrow account with the Funds.
17. After the eserow was funded on May 24, 2010, Liverett provided Pinnacle with a document that he represented was a valid Standby Letter of Credit ("Liverett's SLC"). A true and correct copy of Liverett's SLC is attached as Exhibit C.
18. Pinnacle presented Liverett's SLC to three separate banking institutions. All three banks rejected Liverett's SLC and advised Pinnacle that Liverett's SLC was not a valid Standby Letter of Credit.
19. On June 23, 2010, Pinnacle, through its counsel, sent a letter to Mulvana and Law Offices demanding the return of the Funds in the escrow account because Pinnacle had not received a valid Standby Letter of Credit. A true and correct copy is attached as Exhibit D.
20. Defendants did not respond to the June 23rd letter and did not return the Funds to Pinnacle. Accordingly, on June 25, 2010 Pinnacle, through its counsel, also emailed Mr. Mulvana and again demanded that he return the Funds as requested in the June 23rd letter. A true and correct copy is attached as Exhibit E. Defendants continued to refuse to return the Funds or respond to the June 23 letter or the June 25th email.
21. Finally, on June 28,2010 Pinnacle, through its counsel, sent another letter to Mulvana and Law Offices again demanding the return ofthe Funds held in the escrow acccunt, and further advised that if the Funds were not retumed by the close of business on June 28,2010 legal proceedings would be brought. A true and correct copy is attached as Exhibit F. Defendants did not return the Funds held in escrow and did not respond to the June 28th letter.
FIRST CAUSE OF ACTION FOR BREACH OF CONTRACT (Against AU Defendants)
22. Pinnacle repeats and re-alleges paragraphs 1 through 21 above.
23. The Neutral Holder Agreement was executed by Liverett, Mulvana, and a second party to engage Mulvana as the neutral holder for purposes of the MOU transaction.
24. Pinnacle has fully performed all obligations.
25. Defendants were required to hold the Funds in an escrow account until either a valid Standby Letter of Credit was delivered to Pinnacle or, if no delivery occurred, until Pinnacle demanded return of the Funds.
26. A valid Standby Letter of Credit was not delivered to Pinnacle within 21 banking days from May 24,2010.
27. Since a valid Standby Letter ofCredit was not delivered, Pinnacle is entitled to the return ofthe Funds on its demand.
28. Pinnacle demanded return of the Funds. (Exhibit D, E, and F)
29. Defendants willfully refused and continue to refuse to return the Funds to Pinnacle.
30. Pinnacle has been damaged by Defendants' refusal to return the Funds.
31. Pinnacle is entitled to damages in the amount of the Funds.
SECOND CAUSE OF ACTION FOR BREACH OF THE COVENANT
OF GOOD FAITH AND FAIR DEALING (Against AU Defendants)
32. Pinnacle repeats and re-alleges paragraphs 1 through 31 above.
33. Pinnacle and Mulvana entered into the Neutral Holder Agreement.
34. Pinnacle did everything it was required to do under the Neutral Holder Agreement.
35. Defendants were required to hold the Funds in an escrow account until either a valid Standby Letter of Credit was delivered to Pinnacle or, if no delivery occurred, until Pinnacle demanded return ofthe Funds.
36. A valid Standby Letter of Credit was not delivered to Pinnacle within 21 banking days from May 24,2010.
37. Since a valid Standby Letter of Credit was not delivered, Pinnacle is entitled to the return of the Funds on its demand.
38. Defendants have unfairly interfered with Pinnacle's right to the retum of all the Funds by refusing to return the Funds upon demand.
39. Pinnacle has been harmed by Defendants' conduct.
40. Pinnacle is entitled to damages to be proven at trial.
THIRD CAUSE OF ACTION FOR MONEY HAD AND RECEIVED (Against All Defendants)
41. Pinnacle repeats and re-alleges paragraphs 1 through 40 above.
42. Mulvana received the Funds from Pinnacle. Those Flmds were to be used to pay for a valid Standby Letter of Credit, or returned to Pinnacle if no valid Standby Letter of Credit was issued within 21 banking days ofthe deposit ofthe Funds in escrow.
43. No valid Standby Letter of Credit was delivered to Pinnacle.
44. Pinnacle demanded return of the Funds from Mulvana and Law Offices.
45. Mulvana and Law Offices refuse to return the Funds to Pinnacle.
46. Pinnacle is entitled to damages in the amount of the Funds.
FOURTH CAUSE OF ACTION FOR INJUNCTIVE RELIEF (Against AU Defendants)
47. Pinnacle repeats and re-alleges paragraphs 1 through 46 above.
48. Pinnacle is entitled to an injunction against the Defendants barring them from transferring, encumbering, secreting, hiding, or otherwise affecting or disposing ofany money held in the escrow account pursuant to the MOU and the Neutral Holder Agreement.
49. In particular, Pinnacle is entitled to an injunction barring Defendants from taking any actions affecting the transfer of any money held in the escrow account without Pinnacle's cxpress written consent.
50. Pinnacle has a protectable right pursuant to the MOU and thc Neutral Holder Agreemcnt.
51. Pinnacle believes that the Defendants or a third party may attempt to interfere with Pinnacle's right to the return of the Funds held in the escrow acount.
52. Pinnacle will suffer irreparable harm if the requested injunction is not granted because once thc Funds are distributed Pinnacle may not be able to recover them from another source.
53. There is no adequate remedy at law because the Defendants have refused. and continue to refuse to adhere to the Neutral Holder Agreement.
54. Pinnacle is informed and believes that Defendants will continue to refuse to return the Funds and Defendants may distribute the Funds to an unauthorized party.
55. Pinnacle has a likelihood of success on the merits because Pinnacle has fully performed its contractual obligations under thc MOU and the Neutral Holder Agreement, and the Defendants have repeatedly breached their obligations and acted negligently or in bad faith.
56. As a result thereof, Pinnacle seeks an order requiring Defendants to show cause, if they have any, why they should not be enjoined from transferring, the Funds during thc pendency of this action.
PRAYER
WHEREFORE, Pinnacle prays for judgment against Defendants and each ofthem as follows:
A. For breach of contract of paragraph I, subparagraph 4 of the Neutral Holder Agreement, to require Defendants to return the Funds to Pinnacle;
B. For an injunction against Defendants prohibiting them from taking any actions to transfer, encumber, secret, hide, conceal or otherwise affeet or dispose of any of the Funds held in escrow pursuant to the MOU and Ncutral Holder Agreement;
C. For damages tor Defendants' willful refusal to return the Funds to Pinnacle as required by the Neutral Holder Agreement, the June 23rd Letter, the June 25th Email, and the June 28th Letter;
D. For costs of suit;
E. For interest on the amounts in escrow;
F. For all other obligations and amounts to be proven at trial; and
G. For such other and further relief as the Court deems just and proper.
Dated: June 30, 2010 DUANE MORRIS LLP
Patricia P. Hollenbeck
Heather U. Guerena
Attorneys for Pinnacle Energy, Inc.
I, the undersigned, certify and declare that I have read the foregoing Verified Complaint and know its contents. I am the Chief Executive Officer for Pinnacle Energy Inc., the plaintiff in this action, and am authorized to make this verification for and on its behalf, and I make this verification for that reason. The matters stated in the Verifled Complaint are true and correct except for those matters stated on information and belief. As to those, I believe them to be true.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Executed this 30 day of June 2010
Brian Sorrentino
Let's EATR through those 5's today
Four on the Ask now...