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LG Capital Funding, LLC v. Vapor Group, Inc
1:16-cv-03951
Filed 7/15/16
5. On or about October 8, 2074, VPOR issued a $115,500.00 8%
Convertible Redeemable Promissory Note to LG ("Note 1") with a maturity date of October 8, 2015 ("Maturity Date"). A true and correct copy of the Note is attached hereto as Exhibit A.
6. On or about May 11, 2015, VPOR issued a $35,000.00 8% Convertible
Redeemable Promissory Note to LG ("Note 2") with a maturity date of May 11,
2016. A true and correct copy of the Note is attached hereto as Exhibit B.
13. After the conversions outlined above were duly made and honored, the
remaining principal balance on Note 1 is 990,000.00.
14. No further conversions were executed under Note 1, and no conversions were executed under Note 2.
15. Shortly after honoring the conversion, on May 21,2015, the Company
became delinquent in its fiIings with the Securities and Exchange Commission despite an obligation to remain'turrent" pursuant to each Note. This delinquency caused the Event of Default contemplated by Section 8(m) of each Note.
19. As of the date of frling, the Notes possess a total value of 165,367.68, consisting of $ 129,515.07 in principal and accrued interest at the date of default and $35,852.61 in default interest accrued thereupon. This amount continues to increase daily at the default interest rate.
Back to court we go ...
1. Plaintiff David Biscan is a resident of Georgia.
2. Defendant Electronic Cigarettes International Group Ltd, f/k/a Victory Electronic Cigarettes Corporation is a Nevada Corporation doing business in Ottawa County, Michigan.
3. This matter concerns events that occurred in and obligations that were to be performed in Ottawa County, Michigan.
4. This Court has jurisdiction over this action pursuant to 28 U.S.C. § 1332 because the matter in controversy exceeds $75,000 and the parties are citizens of different states
5. Venue is proper pursuant 28 U.S.C. § 1391 because Defendants do business in Ottawa and Kent counties and events occurred and obligations were to be performed in this District.
6. Plaintiff was employed by Defendant since September of 2013.
7. In July of 2013, Defendant became a public corporation.
8. In August of 2013, Defendant relocated to the State of Michigan.
9. In July of 2014, Defendant changed its name from Victory Electronic Cigarettes Corporation to Electronic Cigarettes International Group Ltd.
10. Defendant terminated Plaintiff’s employment on July 25, 2014.
...
12. On September 23, 2013, Defendant offered Plaintiff employment with various compensation components.
...
18. Marc Hardgrove, co-founder and Chairman of the Compensation Committee of Defendant, approved the exercise price of the options was $0.25 per share for Plaintiff.
19. John Perner, co-founder and President of Retail Sales, told Plaintiff the exercise price of the options was $0.25 per share.
20. On May 23, 2014, Plaintiff emailed Jim McCormick about exercising Plaintiff’s 25,000 of Plaintiff’s options for $0.25 on June 30, 2014.
21. Plaintiff did not receive a stock option award from Defendant until September 9, 2014 and it was at an option price of $8.82 per share.
22. On September 9, 2014, the stock price was $5.60 per share and the options had no value.
23. At the time of exercise, Defendant’s shares were valued at $8.82 per share.
24. On June 30, 2014, Plaintiff was wrongly denied the exercise of his cashless option of 25,000 shares at $0.25 per share
...
36. During Plaintiff’s time, Plaintiff earned 50,000 options under the annual long term incentive with 25,000 vesting on September 23, 2014 and 25,000 vesting on September 23, 2015.
37. Defendant has not issued Plaintiff any of the 50,000 options under the annual long term incentive at this time.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a judgment against Defendant in the amount of $298,250 and order the issuance of 75,000 shares plus costs, interest, and attorney fees.
WHEREFORE, the Plaintiffs respectfully demand as follows:
A. Judgment against Neah in favor of Agile, in an amount to be determined at trial, but not less than $1,000,000.00, together with interest thereon;
B. Judgment against Neah in favor of Capitoline, in an amount to be determined at trial, but not less than $1,000,000.00, together with interest thereon; and
C. Such other and further relief as the Court deems just and proper
5.4M Liabilities v. 400k Property and Equipment ...
Mind you, given a recent bankruptcy, Spoondoolies equipment has done nothing but depreciate since that was reported
I did the math, it's sustainable for exactly 17 hours sooo ... all things considered they did a remarkable job!
They've not disclosed the terms of the lease, we don't know if it's at a discount or premium. We do know it expires in January, it's valued at 510k they've an option to buy it for 775k, and they shut down operations because it's no longer generating cash.
They were leasing that facility ... a transaction regarding such wouldn't involve BTCS ... keep up the good work
If by gaining traction you mean throwing the kitchen sink at the wall, yes
They've 189k cash on hand and currently don't generate revenue ... with BTCS shutting down it's NC operations they'd be a cash burning dynamic duo
Move along
Likely the majority of retail's avg. price
Were those Prototype, Beta 1.0, or Beta 2.0 parts? How many parts are needed for one device?
4 months for parts/assembly, ~4-8 months for third party testing, the timeline continues to expand.
For those taking the .14 to .17 flip it was a great PR.
When one thinks there's no reason for a slide ... look further
2:14-CV-02889
Plaintiff's First Amended Complaint
Filed 6/30/16
34. A dispute has arisen between Plaintiff MYEC on the one hand, and Defendant SWEETSUN on the other concerning the 1,440,000,000 shares issued to SEVEN MILES, SCOTTSDALE, and Defendants SWEETSUN and TITAN. Plaintiff contends that the issuance of the initial 255,000,000 shares to Defendant TITAN was void from the inception and should be cancelled because Defendant SWEETSUN falsely represented to Plaintiff that defendant SWEETSUN had purchased the promissory note from TANGIERS, and that the issuance of the 1,185,000,000 shares of Plaintiff MYEC to SEVEN MILES and Defendant SWEETSUN was void in the inception and should be cancelled because the issuance was without Plaintiff’s MYEC’S authorization; Plaintiff MYEC is informed and believes that Defendants dispute these contentions.
...
43. As a result of Defendant SWEETSUN’S false representations, on January 4, 2013, Plaintiff MYEC’S stock transfer agent transferred 275,000,000 shares of stock in Plaintiff MYEC to Defendant SEVEN MILES.
44. As a result of Defendant SWEETSUN’S false representations, on January 9, 2013, Plaintiff MYEC’S stock transfer agent transferred 260,000,000 shares of stock in Plaintiff MYEC to Defendant SWEETSUN.
45. As a result of Defendant SWEETSUN’S false representations, on May 10, 2013, Plaintiff MYEC’S stock transfer agent transferred 350,000,000 shares of stock in Plaintiff MYEC to Defendant SWEETSUN.
46. As a result of Defendant SWEETSUN’S false representations, on August 22 10, 2013, Plaintiff MYEC’S stock transfer agent transferred 300,000,000 shares of stock in Plaintiff MYEC to Defendant SWEETSUN.
...
52. Plaintiff MYEC is informed and believes, and alleges thereon that unless restrained by this Court, Defendants SWEETSUN, TITAN, and Does 1 – 20, Inclusive, will have the ability to, and are likely to transfer the 530,005,000 shares they now hold because the market price of the shares of Plaintiff MYEC has increased approximately eight-fold since the shares were issued.
53. The existence of 530,005,000 shares held by Defendants SWEETSUN,
TITAN, and Does 1 – 20, Inclusive, represents 13.48% of the outstanding shares of Plaintiff MYEC, and dilutes the value of Plaintiff MYEC’S shares in an amount that is not subject to exact determination and for which monetary damages would be inadequate.
54. Plaintiff MYEC will suffer irreparable injury unless the transfer of the 530,005,000 shares held by Defendants SWEETSUN, TITAN, and Does 1 – 20, Inclusive, is restrained by an Order of this Court, because a transfer to innocent third parties could result in Plaintiff MYEC losing the ability to cancel those shares.
Never in a million years
With 5.4M in liabilities and billions of potential shares to issue ... I think the discount price would be cerca .000001
Just buy Charles dinner and it's yours essentially
Just short-form for New Generation Consumer Group
Same tagline since inception
Does good filling the page when content lacks
I doubt the market sees through it - pop to .16-.19 at open continue the drip by weeks' end
Good luck all
OTC/Penny-stock timing to a tee
Lol my thoughts exactly ... kick's the can certainly. Still not ready for third party testing per 'Beta 2.0 will be available for external testing' line.
11?
Because a .001 ceasing opprations is attractive...
the AS is 975 million
For now
The irony is Gene O'Brien is a bankruptcy lawyer
Increase AS, and billions of shares to be diluted, then RS
That's news to me ... but agree they're not far from $.0001
5:16-cv-01402 Cantoria v. Element Global Services
Filed 06/29/16
13. On or about January 6, 2015, Plaintiff is alleged to have incurred certain financial obligations to Express Tire, which were primarily for personal, family or household purposes and are therefore a “debt” as that term is defined by 15 U.S.C. §1692a(5).
14. These alleged obligations were money, property, or their equivalent, which is due or owing, or alleged to be due or owing, from a natural person to another person and are therefore a “debt” as that term is defined by the California Civil Code §1788.2(d), and a “consumer debt” as that term is defined by California Civil Code §1788.2(f).
15. Sometime thereafter, but prior to November 20, 2015, Plaintiff allegedly fell behind in the payment allegedly owed on the debt.
16. Sometime prior to November 20, 2015, the alleged debt was assigned, placed or otherwise transferred to Defendant for collection.
17. On or about November 20, 2015, Defendant began attempting to collect the alleged debt.
18. On or about November 20, 2015, Defendant began conducting a campaign of continuous telephone collection calls to Cantoria’s cell phone number (xxx) xxx-3438 (hereinafter “cell phone”), as well as communications made in collection calls with persons other than Cantoria.
...
19. On or about December 14, 2015, Defendant contacted Cantoria’s cell phone at least four times between 8:01 a.m. and 8:17a.m., and has continued to contact Cantoria’s cell phone repeatedly since December 14, 2015.
20. Cantoria did not authorize Defendant to contact her cell phone number
21. These phone calls to Cantoria’s cell phone were “communications” within the meaning of 15 U.S.C. §1692a(2), and “debt collections” as defined in California Civil Code §1788.2(b).
22. At various and multiple times prior to the filing of the instant complaint, including within one (1) year preceding the filing of this complaint, Defendant repeatedly contacted Cantoria in multiple attempts to collect the alleged debt with the intent to annoy, abuse and/or harass her, in violation of 15 U.S.C. §1692d.
23. On or about December 14, 2015, Defendant contacted Cantoria’s father at his home and left a message on his answering machine regarding the alleged debt.
24. Cantoria did not provide her father’s contact information, and in no way authorized Element Global Services to contact her father.
25. The communication with Cantoria’s father was made without the express permission of a court of competent jurisdiction, and for a purpose not reasonably necessary to effectuate a post-judgment judicial remedy, in connection with the collection of a debt, with a person other than the consumer, in violation of 15 U.S.C. §1692b.
26. At all times herein, the Defendant was attempting to collect the alleged debt from Cantoria, and that debt was a debt as defined by 15 U.S.C. §1692a (5) of the FDCPA, and a “consumer debt” as that term is defined by California Civil Code §1788.2(f).
27. By engaging in the foregoing conduct, the natural consequence being harassment and oppression of Cantoria, in connection with the collection of a debt, Defendant violated 15 U.S.C. §1692d and 15 U.S.C. §1692f.
28. Because the Defendant’s actions violated certain portions of the Fair Debt Collection Practices Act as those portions are incorporated by reference in the Rosenthal Fair Debt Collection Practices Act through California Civil Code §1788.17, the Defendant’s conduct also violated California Civil Code §1788.17.
2:16-cv-01006 Filed 3/30/16
Plaintiff IPOWERUP INC., a Delaware corporation ("iPowerUp"), for its first amended complaint, and demanding trial by jury under Rule 38, Fed. R. Civ.P., and Local Rule 38-1, alleges that ASCENT SOLAR TECHNOLOGIES INC., a Delaware corporation ("AST"), is infringing claim 21 ofU.S. Patentno. 8,080,975 ("the '975 patent" ) and claims 1, 14, and 17 ofU.S. Patentno. 8,604,753 ("the '753 patent") (collectively the "iPowerUp Patents and asserted claims"), by selling, and offeringto sell, in thisjudicial district, Solar Battery PhoneCases that infringe the asserted claims, and by inducing others to infringe the methods of assertedclaims 1, 14, and 17, ofthe '753 patent, for example, by "furnishing" Solar Battery Phone Cases to persons in this judicial district
3:16-1046 First Amended Complaint filed: 7/18/16
If in need of an afternoon read ...
27. On April 22, 2013, BHGI, then named The Motion Picture Hall of Fame, Inc., (BHGI’s former name) filed its Annual Report for the years ended December 31, 2012 and 2011, and disclosed a $180,000 loan with an unspecified third party. The disclosure omits any rights to convert the debt into shares of common stock of BHGI.
28. On April 12, 2014, BHGI filed its OTC Pink Basic Disclosures for the Period Ended December 31, 2013, wherein it disclosed a $180,000 loan. The disclosure omits any rights to convert debt into shares of common stock of BHGI.
…
30. Beginning in April, 2014, the Plaintiffs were solicited via email by Jeffrey; he encouraged them and others to invest in Motion Picture Hall of Fame, Inc., now BHGI, through an attached subscription agreement. Jeffrey represented that he was “in a position of control”, could “ensure this is a win-win-win for everyone”, “I know what I can do…”, “I have control…” and “this is a dunk SWISH for us!” See Exhibit 1.
31. The investment solicitation email from Jeffrey included material, non-public information, including the fact that they are “in the process of bringing on Doug Cole...” a “verbal LOI from Hy-Vee grocery stores…” According to Jeffrey, since such material information was not yet announced to the public, his investment solicitation and “this information, as well as everything else I am telling you is in the strictest confidence.” See Exhibit 1.
32. The email solicitations included prospectus and business description type materials for Motion Picture Hall of Fame, Inc. (now BHGI) and Beverly Hills Hemp, Inc., an apparent subsidiary or other company connected with BHGI and its control persons.
33. On April 25, 2014, Plaintiffs indicated, via email, an interested in investing $250,000 for about one million common shares. See Exhibit 2.
34. Jeffrey, on April 28, 2014, sent Plaintiffs via email, the Subscription Agreements for Plaintiffs to complete, adding, “In addition to me being in control of the tick so there is REALLY no risk.” (emphasis in original). See Exhibit 3.
35. On May 11, 2014, BHGI filed its March 31, 2014 Quarterly Report, wherein it disclosed a one hundred eight thousand ($180,000) loan from an unspecified third party. The disclosure omits any rights to convert the $180,000 debt into shares of common stock of BHGI.
36. On May 15, 2014, BHGI filed an Amended March 31, 2014 Quarterly Report wherein it disclosed a $180,000 loan from an unspecified third party. The disclosure omits any rights to convert the $180,000 debt into shares of common stock of BHGI.
37. On June 9, 2014, BHGI filed a second Amended March 31, 2014 Quarterly Report wherein it made absolutely no mention at all of the $180,000 loan from a related party. There is no disclosure as to whether the $180,000 was repaid, forgiven, assigned or otherwise how it had otherwise been treated so as to cause it to be removed from the financials.
...
39. On July 30, 2014, Plaintiffs wired $750,000 into the JP Morgan Chase account name: “Law Office of Randall V. Brumbaugh re: AE Investment Ltd.” For the purchase of six million (6,000,000) common shares of BHGI.
40. That amount was later renegotiated to ten million (10,000,000) of which only eight million (8,000,000) were delivered.
41. During 2014 and 2015, Jeffrey was provided with a JEEP vehicle as transaction based commission compensation, directly related to the amount of Plaintiff’s investment in BHGI.
42. During 2014 and 2015, Danielle received a cash commission based on Jeffrey’s successful solicitation of the Mikkins investment into BHGI; the amount of the commission was based on the amount of Plaintiff’s investment in BHGI.
43. On August 14, 2014, BHGI filed its June 30, 2014 Quarterly Report wherein it has absolutely no mention of the $180,000 loan from a related party. There is no disclosure as to whether the $180,000 was repaid, forgiven, assigned or how it had otherwise been treated.
44. On August 23, 2014, Plaintiff Donna was appointed as officer and director of BHGI, for which she entered into an oral agreement with Defendants James and Paula for payment of two million (2,000,000) BHGI common shares as compensation. She began working approximately forty (40) hours a week and made herself available to sign documents as requests at almost any time, day or night, weeknight or weekend. To date, Plaintiff Donna has not received any common shares of BHGI for her services as an officer and director.
45. Defendants James and Paula asked Plaintiff Donna to move to San Diego from the East Coast to serve as the Chief Executive Officer. She and her family incurred the expense of renting and furnishing a $3,500 a month two-bedroom apartment. Defendants James and Paula chose the luxury building in San Diego for their own convenience; they lived in the same building located at 700 West E Street, San Diego California 92101.
46. Plaintiff Donna realized quickly that she was relegated by Defendants James and Paula to a position that simply required her to sign already completed and negotiated documents which Defendants James and/or Paula presented to her, as opposed to providing any input or advice.
47. On August 26, 2014, seventy-five thousand dollars ($75,000) was wired from Brumbaugh’s IOLTA account on behalf of AE Group Investment, Inc. to a third party- the holder of the one hundred eighty thousand ($180,000) promissory note originally disclosed in the initial March 31, 2014 Quarterly Report.
...
49. On October 1, 2014, BHGI executed a memorandum memorializing the issuance of fifty million (50,000,000) common shares of BHGI with a value of $0.005 per share for an issuance value of two hundred fifty thousand dollars ($250,000) to Palm Desert Management, Inc., pursuant to a Management Services Agreement. The shares were issued well under the fair market value of the 50,000,000 shares at $37,500,000 (50,000,000 x $0.75).
…
52. On October 16, 2014, BHGI’s Board of Directors executed minutes acknowledging that the $180,000 loan had a current balance of $335,850 as a result of accrued interest as of March 31, 2014. The minutes also acknowledged that the promissory note was assigned from a third party named Thomas Foley to AE Group Investments, Ltd. The minutes are silent as to any rights to convert the debt into shares of common stock of BHGI.
53. On October 27, 2014, the Restated March 31, 2014 Balance Sheet reflects a $335,850 Promissory Note convertible into shares of common stock at a price of $0.0025 per share; convertible into approximately 134,340,000 shares of common stock of BHGI. The disclosure indicates that the $335,850 Note replaces the $180,000 loan disclosed on May 15, 2014.
54. Pursuant to the RESTATED June 30, 2014 Quarterly Report (emphasis in original) filed October 27, 2014, there were 818,205 common shares of BHGI issued and outstanding.
55. On October 27, 2014, the common stock of BHGI had a closing price of $0.27 per share on the Over the Counter Pink Sheets.
56. Plaintiffs are informed and believe and thereon allege that, at some time during October and December 2014, AEG transferred or assigned its $335,850 BGHI promissory Note to Global.
57. On December 19, 2014, at 1:26 am GMT, James Po sent Donna Mikkin an email with the Subject “Draft Global Force” with the attachment “Global Force Emerging Mar~”. The attachment is a description of Global Force Trading and includes a description of management as follows: “James Po is a high profile executive with over 40 years of experience in Asia markets and publicly traded companies heads the team and spearheads the investment arm of the organization;” And as the closing line: “as a founding investor you will get stock in BHGI at $2 per share and matching stock in the next three publicly traded companies.”
58. On December 23, 2014, Edward G. Mikkin & Donna A Mikkin JT TEN was issued certificate #1466 for 1,525 shares of common stock of BHGI. The physical certificate was sent to Plaintiffs from their online brokerage account, after purchasing them in the open market as part of the “test trades” being conducted at the direction and request of Defendants James and Jeffrey while BHGI was listed on the “grey sheets.”
59. On December 29, 2014, Don A. Paradiso, P.A. executed a legal opinion addressed to Interwest Transfer Company, Inc., relating to Global’s five million eighty-one thousand seven hundred thirty-four (5,081,734) common shares of BHGI (“Legal Opinion”). The Legal Opinion contains several false statements, misrepresentations, and omissions such as: a. the fact that Global is not an affiliate of BHGI and had not been one within 90 days of the letter; b. that BHGI has reported all existing debts in its public filings; c. The fact that the firm did not review the 2014 filings and financial statements; d. That the holding period can tack back to the original security date; e. That the conversion rights afforded under the Promissory Note does not make Global a control person of the affiliate; That BHGI has never been a “shell corporation” since inception; and g. That the shares do not need to be registered and are unrestricted.
60. Plaintiffs are informed and believe and thereon allege that the fraudulent Legal Opinion allowed Defendant Global and its control person to unlawfully sell the BHGI common shares to Plaintiffs and other shareholders as part of the overall “pump and dump” and “gypsy swap” stock fraud scheme.
61. During January 2015, Plaintiff Edward was sent a template “Mutual NonCircumvention and Non-Disclosure Agreement” for Global Force Trading Inc.[sic], with Defendants James and Paula’s home address of 700 W. E. Street Unit 501, San Diego, CA 92101 listed as Global’s principal mailing address.
62. In February 2015, three months after Plaintiff’s $750,000 investment was made, Plaintiffs were issued eight million shares (8,000,000) out of the ten million (10,000,000); evidenced by certificates numbered 1486 and 1485.
63. On May 6, 2015, at 1:17pm, Defendants James Poe sent Jeffery Thomas, and copied Plaintiff Donna Mikkin an e-mail with the subject line “FW:follow up” with an attachment tilted “Global Force Trading Limit~”. The e-mail and attachment outlines the organizational structure of “the Company” The attachment contains an organizational chart showing BHGI labeled as “pubco” being the parent or other sort of control entity of Global Force Trading Limited.
64. During 2014 and 2015, Plaintiffs also invested an additional $25,000 to purchase shares for family members, at $0.25 per share. Plaintiffs are informed and believe and allege thereon that during this time, Jeffrey was offering common shares of BHGI to others at a price per share of $0.12.
65. During 2014, 2015 and the beginning of 2016, Plaintiffs were asked to wire various amounts of money into Defendant Brumbaugh’s IOLTA account to cover various business and personal expenses of Defendants BHGI, James, Paula and Jeffrey. Plaintiffs estimate the total amount sent for these expenses are approximately two hundred fifty thousand dollars ($250,000); One hundred and fifty thousand ($150,000) was wired directly to Defendant Brumbaugh’s account and the balance was paid via cash and credit card expenses.
66. Plaintiffs made an oral agreement with Defendants Paula and James that the money sent, in excess of Plaintiff’s original $750,000 would be repaid through either cash or BHGI stock.
67. On September 23, 2015, at 5:22pm, BGHI’s transfer agent sent an email to Randy Brumbaugh and copied Donna Mikkin with the subject “BEVERLY HILLS” with air bill and copies of certificates broken out from a Palm Desert Management certificate, labeled for the “Palm transfer” attached. The air bill is address to Paula Poe of Palm Desert Management, Inc. at Defendants James and Paula Poe’s home address of 700 West E. Street Unit 501, San Diego, CA 92101.
68. On June 26, 2015 at 1:26pm, BGHI’s transfer agent sent an email to Defendants Randy Brumbaugh and copied Donna Mikkin with the subject “BEVERLY HILLS.” Donna Mikkin forwarded this e-mail to James Poe two minutes later at 1:28pm. In this email, the transfer agent states: “Randy, I have received the Global Force certificate that was issued on the 24th for additional breakdown. 500,000 shares are to be registered to you in free-trading form. We are concerned about your affiliate status since you are a signer for the company as well as my direct liaison. If you believe that you are not an affiliate we will need a letter from you stating that your role is purely administrative and you have no knowledge of the day to day activities of the Issuer. We will also need the instruction letter from Global to contain the rep that Global has discussed this with Paradiso.” emphasis added.
69. On February 1, 2016, Defendant Paula sent by email, to Plaintiff Edward, the Promissory Notes and Security Agreements, for fraudulent back-dating execution, to document: a. a $550,000 loan from Edward Mikkin to Palm Desert Management, Inc. dated July 21, 2014; b. a $200,000 loan from to Edward Mikkin to James Po, on Palm Desert Management letterhead, dated July 31, 2014; and c. a $130,000 loan from Edward Mikkin to James Po, on Palm Desert Management letterhead, dated April 1, 2015.
70. In February, 2016, Plaintiffs realized that BHGI was trying to fraudulently back date documents to treat their initial $750,000 share purchase and subsequent $250,000 expense payments as loans, as described above.
71. During February 2016, Plaintiffs questioned Defendants James, Paula and Brumbaugh as to this fraudulent backdating and incorrect documentation.
72. On March 2, 2016, Defendant Brumbaugh sent Plaintiff Donna an email stating that the Board of Directors of BHGI, requesting that she resign as officer and director of BHGI.
73. On March 2, 2016, Donna sent an email to Defendant Brumbaugh with her letter confirming that effective March 3, 2016, she had resigned as Director and Officer of BHGI.
74. On April 6, 2016, Defendant Paula filled out and sent a Customer Stock Deposit Representation form to Plaintiff Donna, that indicated the eight million (8,000,000) BHGI shares owned by Plaintiffs were issued pursuant to a “Management Contract.”
75. Plaintiffs, allege that neither Plaintiffs Edward nor Donna have entered into a Management Contract with BHGI and Plaintiff Donna has not been issued BHGI common shares in connection with her service as officer and director.
76. On April 5, 2016 Defendant Paula sent a text message to Plaintiff Donna’s cell phone seeking the address to which she would send a two million (2,000,000) share certificate of BHGI stock, pursuant to fulfill the balance of their seven hundred fifty thousand ($750,000) investment for ten million (10,000,000) shares. Defendant Paula asked Plaintiff Donna if she wanted them issued as “an employment contract” to which she replied “no.”
77. At all times relevant here to, Plaintiffs were storing personal items, described below, in a storage unit being rented by Defendant Paula.
78. On April 24, 2016, Plaintiffs were notified by the Property Manager of the storage facility that the Plaintiff’s personal property listed below (“Plaintiff’s Personal Property”) was no longer in the unit: a. One (1) 65-inch curve wide screen television; b. Two (2) 50-inch flat screen televisions; c. Three (3) decorative television armoires and stands; d. One (1) decorative bench; e. Four (4) decorative mirrors; f. One (1) decorative cross; g. One (1) air mattress; h. Various camping gear.
79. Plaintiffs, based on information received through their son from Defendant Paula and belief in the truth of such information, do hereby allege thereon, Paula gave the Plaintiff’s Personal Property to Jeffrey.
80. Plaintiffs have emailed and texted Defendants Paula and Jeffrey to arrange a time and place in which to pick up the Plaintiffs’ Personal Property from Jeffrey; all communications have been ignored.
81. During March and April 2016, Defendants James and Jeffrey directed Plaintiff Edward to purchase shares of common stock of BHGI on the open market in an attempt to keep the stock’s price per share from dropping.
82. Plaintiffs, at all times relevant hereto, and based on information and belief do hereby allege thereon, that Defendants James and Jeffrey also directed others to purchase shares of common stock of BHGI on the open market in an attempt to keep the stock’s price per share from dropping.
83. Plaintiffs, at all time relevant hereto, and based on information and belief, do hereby allege thereon, that the Defendants James and Jeffrey were, at that same time, the shareholders selling the shares that they were directing Plaintiff Edward and others to purchase at an inflated price per share.
84. Plaintiffs, at all time relevant hereto, and based on information and belief do hereby allege thereon, that Danielle regularly received bank wire transfers and checks from Defendant Brumbaugh’s bank account pursuant to a consulting agreement.
85. Defendant Paula told Plaintiff Donna that Defendant Danielle’s consulting agreement existed solely as a vehicle in which Jeffrey could be paid commissions for his fund raising efforts without paying him directly. Defendant Paula told Plaintiff Donna that Defendant Jeffrey was not a licensed broker dealer and that he has “tax issues.”
86. Plaintiffs, at all time relevant hereto, and based on information and belief do hereby allege thereon, that Defendants James, Paula, Gene and Brumbaugh are in control and receive the benefits of AE Investment Group, Inc., Global Force Trading, Inc., and Palm Desert Management, Inc.
87. Plaintiffs, at all time relevant hereto, and based on information and belief do hereby allege thereon, Donna was merely a placeholder officer and director of BHGI, unknowingly appointed with the fraudulent intent to concealing the identity of the true persons exercising the power or authority of an officer or director in furtherance of their unlawful conduct.
88. Plaintiffs, at all time relevant hereto, and based on information and belief do hereby allege thereon, My Hoang Le is merely a “nominee” or “straw person” officer and director of Palm Desert Management, Inc., appointed with the fraudulent intent to concealing the identity of the true persons exercising the power or authority of an officer or director in furtherance of their unlawful conduct.
89. Plaintiffs, at all time relevant hereto, and based on information and belief do hereby allege thereon, Rosa D Cordero Castro is merely a “nominee” or “straw person” officer and director of AE Group Investment, Inc., appointed with the fraudulent intent to conceal the identity of the true persons exercising the power or authority of an officer or director in furtherance of their unlawful conduct.
27M PM T-trades
Entity Name: JT CONCEPTS & DESIGNS, INC.
Entity Number: C3354835
Date Filed: 01/27/2011
Status: DISSOLVED
Jurisdiction: CALIFORNIA
Entity Address: 609 N REXFORD DR
Entity City, State, Zip: BEVERLY HILLS CA 90210
Agent for Service of Process: JONG AE LEE KIM
Agent Address: 1118 S SANTA FE AVE
Agent City, State, Zip: LOS ANGELES CA 90021
Well that was abrupt ... 250k+ wanted out
Give me them .12's already
Put a few bills in $6.3 after being a sally PM ... 30-40 S&P handles then fleeing the POS
From: Tom Kim [mailto:tomkim999@gmail.com]
Sent: Thursday, July 21, 2016 1:49 PM
Subject: Re: NGCG
That depends on the idiots who file frivolous lawsuits. Like the one im working on now re Jason Ruppert. Found out he was linked to Calvin Ross.
The company is very viable. Whats taking most of my time was cleaning it up. Remember Phil,Mike, and Arvin all resigned at the end of April, the same month I started!!!!
So I was pretty much doing this blind. Im also fixing the webpage issue. Since I didnt have the proper channels to get it done right and the host company is a piece of crap its taking longer than usual. It should be done by next week, thats what they are telling me.
Re business, Im having meetings with other companies and update will be posted on our new webpage.
Sent: Thursday, July 21, 2016 8:46 AM
To: 'tomkim999@gmail.com'
Subject: NGCG
Tom,
When will this company be able to go a quarter without judicial proceedings plaguing it from years past?
Is this still a viable business?
.0009 ... .0008 ... yes ... falling