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Re: ORCA post# 1813

Tuesday, 07/10/2007 9:47:13 PM

Tuesday, July 10, 2007 9:47:13 PM

Post# of 34865
To put the Reg D and restricted selling fears to rest I spent a few hours of company time to look through the filings of APDR and its predecessor Siam Imports. What I found was a clean and easy to follow history of the stock.

The last Reg. D 504 stock (5.6 million) was issued way back in 2003, so we can safely assume it is already part of the float. There is no other restricted stock in the O/S besides the stock held by the company and Dennis McLaughlin.

APDR was fully reporting until its delisting this spring. As such, APDR stock is still registered with the SEC and APDR is therefore bound by the SEC rules. Never mind it is delinquent on its periodic financial reporting obligations, the company still has to report any material events, etc just like any other reporting company.

But because it is delinquent, APDR is not allowed to file the usual dilutive S-1, S-2, S-8, etc, so common in penny land and even better, APDR does not qualify for Reg. D 504s either. That is, so long APDR is delinquent and does not file a form 15 to de-register its stock, it is pretty much stuck with its present share structure.

That said, the old shell owners still owns (or owned) 7 million shares through MAC Partners LP. These shares are by now freely tradeable if they want to without any 144 filings. They would however have to get the TA to remove the restricted legend

19,900,000 shares - Apollo Resources International, Inc. Restricted
300,000 shares - BMI Consulting $300,000 ($1.00/share) Assume in the float
2,075,000 shares - Nite Capital $500,000 ($0.25/share) Assume in the float
1,000,000 shares - MAC Partners LP The Eldjarnsons)
800,000 shares - 32 investors Regulation D - Rule 504 ($0.05/share) Assume in the float
250,000 shares - Mammoth Corporation ($1.00/share) Assume in the float

Multiply by 7 to get the current post-split count. This does not include Dennis McLaughlin's shares

In the mean time APDR is collecting $15,000/day in revenue from its rig leased to Tex-Mex and will be for at least another year





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