Obtained copy of complaint filed by Theresa A. Weiner, attorney William A. Miller.
Plantiff alleges fraud and misrepresentation of EES, EESN and ECMZ by defendants when purchasing debentures for bridge financing. Plantiff invested,9/2/2008, $25K then an additional $15K 7/27/2009 by purchasing 4.0 to 1 Convertible Debentures-Series A with repayment by September 30, 2010. Interest payments were made in 2008 and 2009, no futher interest payments have been made or redemption. Claims for Relief: Count One - Securities Fraud - Arizona Revised Statues (ARS) 44-1991 et seq.; Count Two - Control Person Liability ARS 44-1999, Paricipant Liability ARS 44-2003 and Aiding and Abetting Fraud in the sale of Securities; Count Three Securites Fraud: Sale of Unregistered Securities; Count Four - Unlawful Acts and pattern of Unlawful Activity ARS 13-2314.04;Count Five - Consumer Fraud: Violation of the Arizona Consumer Fraud Act; Count Six Common Law Fraud; Count Seven - Negligent Misrepresentaton; Count Eight - Punitive Damages...seeks a punitive damages award of up to four times her actual damages, and in an amount deemed appropriate by the trier of fact at the trial in this matter, and with constitutionally permitted limits.