ZNext Mining Corporation, Inc (ZNXT)

[scion]

16. These claims are false. PAIM has no equity in PAIM Philippines, does not have any claim over PAIM Philippines' mining assets or operations, and is not entitled to receive any of the profit. In fact, PAIM Philippines is a separate company that is 96% owned by Gamboa. Gamboa never disclosed her controlling shareholder interest in PAIM Philippines or the lack of any direct legal relationship between PAIM Philippines and PAIM.

17. PAIM falsely stated in its 2007 disclosure and financial statements posted on www.pinksheets.com that its directors did not own more than 5% of PAIM stock. Yet Gamboa, PAIM's chairman, has been a controlling shareholder of PAIM. She stated in an email in May 2007 that she owned 2..8 billion shares of purportedly unrestricted PAIM stock, which constituted at least 28% of PAIM's then total shares outstanding.