World Surveillance Group Inc (fka WSGI)

[rwehapi2003]

Joe did respond in PACER and this is his conclusion (responses due to Joe and Luis motion to dismiss by 1/28/08). Joe's defense is that the SEC failed to make a proper case?:


IV. CONCLUSION
As described above, Mr. Monterosso is charged with violating the federal securities laws,
and with aiding and abetting GlobeTel’s violations of the federal securities laws, by creating
false invoices and CDRs and submitting them to GlobeTel, who incorporated information from
the false invoices and CDRs into its books and records, and used information from the false
invoices and CDRs in its periodic reports, press releases, and securities registration statements.
The Commission, however, has completely failed to satisfy the Federal Rules of Civil
Procedure’s pleading requirements by failing to adequately plead Mr. Monterosso’s primary or
secondary violations. Based upon that complete failure, it should not be allowed to proceed in its
claim against Mr. Monterosso.