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MOTION for Hearing re4 Amended Complaint, Notice of Motion to Dismiss Plaintiffs' First Amended Complaint by Beverly Hills Group, Inc., Randall Brumbaugh, Gene O'Brien, Palm Desert Management Inc., Danielle Thomas, Jacob Thomas, Jeffrey Thomas.(Perlis, Michael)
Minute Order by Judge Jeffrey T. Miller: Submitting,3 MOTION to Dismiss Plaintiffs' Complaint. Motion Hearing set for 8/1/2016 10:00 AM
BHGI UP 260.82%
Buy Vol: 67,889
Sell Vol 1100
16 buy 1 sell
you also need an update. Perlis is current attorney for BHGI
I guess rumour is true after all... that Mikkin hired his family member to distract
of course. did you do DD on the Mikkins? that is the most important DD
since you know so much why not share DD on the Mikkin?
LOL you need an update. BHGI lawyer is Michael F Perlis
http://www.lockelord.com/professionals/p/perlis-michael-f
http://profiles.superlawyers.com/california-southern/los-angeles/lawyer/michael-f-perlis/00037f12-cadb-4022-8f0c-519a34a81727.html
The Mikkin’s Complaint suffers from a number of fatal flaws. Most notably, in
an apparent attempt to avoid alleging the true nature of their investments, the Plaintiffs
piece together a series of allegations that is, at best, abstruse and erratic. For example,
the only information Plaintiffs allege to have received prior to making a $750,000
investment in Defendant BHGI, are emails, a draft subscription agreement and a draft
contract to invest in Motion Picture Hall of Fame, Inc. and Beverly Hills Hemp, Inc.
Without alleging any explanation as to the relationship, if any between these entities,
Plaintiffs allege they paid $750,000 for either six, eight or ten million shares of BHGI.
However, this payment was not made directly to any Defendant, but instead to an
account at JP Morgan which may or may not be related to a separate entity.
Regarding the Mikkin’s wage, breach of contract and conversion claims, the
Complaint alleges that a month after making an investment in BHGI, Donna Mikkin
became an officer and director of BHGI, then moved to San Diego to become Chief
Executive Officer. The Complaint does not explain why, during her two year tenure,
Donna was not aware of or involved with corporate decisions she now claims are
fraudulent, or whether she has an employment contract, as opposed to cryptically
described cell phone conversations, setting forth the terms of her employment.
Although these allegations border on incomprehensible, what is clear is that the
Complaint does not state a claim on which relief can be granted as to each of the
asserted causes of action.
While the Complaint is replete with fanciful terms such as “pump and dump”
and “gypsy swap,” missing entirely are the “who, what, when, where, and how”
DEFENDANTS’ MEMORANDUM OF POINTS AND AUTHORITIES ISO MOTION TO DISMISS COMPLAINT
Case 3:16-cv-01046-JM-WVG Document 3-1 Filed 06/09/16 Page 10 of 33
necessary to satisfy the Private Securities Litigation Reform Act’s (“Reform Act”)
heightened pleading standard to recover under Section 10(b) and Securities and
Exchange Commission (“SEC”) Rule 10b-5. Plaintiffs insist they were the victims of
securities fraud, but do not identify any false statement made to them by any
Defendant, or adequately allege scienter, reliance, economic loss or loss causation.
There are no specifics as to the alleged wrongful conduct, the timing of events, the
parties involved, or the casual connection between any alleged material misstatement
or omission and any economic loss. For these reasons, the 10(b) claim should be
dismissed.
can you do DD on Mikkin family? I heard so many crazy stuff
most likely Mikkin's shorting again... they are known for lunatic stuff
did you had a chance to see what kind of history Ahmad have? he is the one that breached the contract. main focus is Ahmad and Mikkins
I think rumour of Ahmad and Mikkin buddy/family is spreading false rumour is true after all.
Last time when i checked hans didnt do anything to the company. Whats the big deal? take a look at what Ahmad did or xhexk his legal status
can you do a DD and Ahmad and Mikkins? instead of doing DD on some random dude?
Ahmad and Mikkins are the problem not Hans
bid are looking good. where is wack a bid Ed? I guess his master Ahmad is telling him to stop?
its not a shell. it already acquired 1 of 4 business from Groupo Richard.
not here to cheer or destroy BHGI, but at least I can provide actual link instead of assumption
research Grupo Richard and decide yourself
here is the link to 1st finished acquisition
http://www.otcmarkets.com/stock/BHGI/news/BEVERLY-HILLS-GROUP--INC--ANNOUNCES-8-K-FILING-AND-COMPLETION-OF-FIRST-ACQUISITION?id=129774&b=y
CLPI will be a great choice... thinking to get in but not at this pps.
BHGI has some noise from former insider but what I heard is that "Commercio" will be worth billions of dollar within years
shoot me a PM with your email or contact info on Firday after hour (you can free PM during that time)
CLPI is in similar business as BHGI. 1 is in India and 1 is in Mexico.
both will be acquired by bigger fish imo
this is very interesting stock..hmmm
this is very interesting stock..hmmm
really? lol what I see is a great opportunity
do you know about SPEA? and what happened to it?
it's our money so we can do what we want to do. do you know why we closed green today? because....... I hit the ask duh.
sitting bid does not do anything but depress the stock. hitting ask? pps goes up and up and up. stock does not move by sitting on the bid
if Mikkin and Ahmad are indeed shorting then only way to squeeze them is to hit the ask not sitting on the bid.
Ahmad is pro crook and Mikkin is Ahmad wannabe
Ahmad is a clever boy but Mikkins? he is a pet of Ahmad. I bet he does not even know what he is doing
Ahmad breached the contract and shorted same time. he is the one responsible for 1st damage and BHGI file a lawsuit against him and Ahmad lost big time
and
Mikkin is a puppet of Ahmad. they are working together to shot down pps
dilution? where? float is increased by 7 million shares and that it!
26m to 33m and that is a dilution? nonsense
one must wonder why Mikkin family is keep spreading lies after lies. why? do they just want their money back? nope! they want more and way more
victims are current shareholders and Mikkins and Ahmad caused all this mess
2 former insider made a lawsuit against BHGI and screaming it has no money, no asset and etc. if so why lawsuit a company that has no money, asset and etc..? does this make sense? I would never lawsuit a street bum why? they don't have any money that I can collect!
they know that BHGI will be big and that is why they are doing this nonsense to steal money from BHGI. I never heard 2 insider making a lawsuit in pinky stock that has no money
rememberer Winklevoss twins aka facebook dudes?
from 10Q, 10K and every other filing
I guess Donna lied about all the information LOL
Issuer Certification
The issuer shall include certifications by the chief executive officer and chief financial officer of the issuer (or any
other persons with different titles, but having the same responsibilities).
The certifications shall follow the format below:
I, DONNA MIKKIN, CEO/PRESIDENT certify that:
1. I have reviewed this AMENDED QUARTERLY DISCLOSURE STATEMENT of BEVERLY HILLS GROUP, INC.
FKA THE MOTION PICTURE HALL OF FAME, INC.;
2. Based on my knowledge, this disclosure statement does not contain any untrue statement of a material fact or
omit to state a material fact necessary to make the statements made, in light of the circumstances under which such
statements were made, not misleading with respect to the period covered by this disclosure statement; and
3. Based on my knowledge, the financial statements, and other financial information included or incorporated by
reference in this disclosure statement, fairly present in all material respects the financial condition, results of
operations and cash flows of the issuer as of, and for, the periods presented in this disclosure statement.
November 12, 2015 [Date]
/S/ DONNA MIKKIN [CEO’s Signature]
CEO/PRESIDENT [Title]
maybe she was unable to read?? if any Mikkin should file a lawsuit against Ex-CEO Donna Mikkin for signing all those papers!
Mikkins claims that they are the victim but they signed the all the papers? WTF?
I think Notice of Motion to Dismiss Complaint date is on the Aug 1st of 2016
DEFENDANTS’ MEMORANDUM
OF POINTS AND AUTHORITIES
IN SUPPORT OF MOTION TO
DISMISS
ORAL ARGUMENT
REQUESTED
Date: August 1, 2016
Time: 10:00 a.m.
Courtroom: 5D
[Filed Concurrently with Notice of
Motion to Dismiss Complaint]
don't forget that $4.75m is in 2014 and today is 2016 not 2014. my guess is they 2-5x the revenue by now
These established Mexican corporations for fiscal year ending December 31st, 2014 had gross sales of approximately US$ 4.75 million with roughly US$35 million in Real Estate assets. The Company currently does business with AB-InBev (Bud Light and Corona) in their different business units. The corporations to be acquired were founded as early as 2005 and others as recently as 2014, with approximately 150 full-time employees.
current float is 33 mil and 2015 was 26 mil. is 7 mil a deal breaker?
it was grey trade. it could have been a test trade
it means nothing important
whomever selling has to pay for its price. Ahmad, Mikkin and few other Ihubber have been notified. if it was someone else as Mikkin claims then he/she has to pay as well
FINRA AND SEC have been notified and you should file as well