MyECheck, Inc. (fka MYEC)

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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.
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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.
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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.