Top Shelf Brands Holdings Corp. (DKTS)

[Carini]

How about these two:

...the parties have stipulated to the following facts...

b. The Outstanding Shares described below [i.e., the disputed, supposedly "fraudulent" shares] were and are duly authorized, validly issued, fully paid and non-assessable.

c. The beneficial owner of the Outstanding Shares is and was Victory Partners. The date of issue of each Outstanding Share is the date represented on each share certificate."

No mention of any "friendly shareholder" though...