13. Defendant Pawel P. Dynkowski is a citizen of Poland and a legal resident of the U.S. During the relevant time period, Dynkowski resided in Newark, Delaware.
14. Defendant Richard A. Bailey is a resident of Las Vegas, Nevada. Bailey was the Secretary and the director of GH3 during the relevant time period.
15. Defendant Matthew W. Brown is a resident of Aliso Viejo, California. Brown operates the penny stock website InvestorsHub.com.
16. Defendant Jacob Canceli is a resident of Mission Viejo, California. Canceli is a stock promoter.
17. Defendant Gerard J. D’Amaro is a resident of Pompano Beach, Florida. D’Amaro is a stock promoter.
18. Defendant Gary C. Heath is a resident of Mesa, Arizona. Heath owned and controlled High Plains Enterprises, a now inactive Minnesota corporation.
19. Defendant Joseph Mangiapane Jr. is a resident of Laguna Niguel, California. Mangiapane was a registered representative at AIS Financial, Inc. Mangiapane is the CEO of Rubicon Financial, Inc., which owned AIS Financial, Inc. during the relevant time period.
20. Defendant Nathan M. Michaud is a resident of Boston, Massachusetts. Michaud is an internet web site designer.
21. Defendant Marc J. Riviello is a resident of Redwood City, California. Riviello was a registered representative at AIS Financial, Inc.
22. Defendant Adam S. Rosengard is a resident of Voorhees, New Jersey. Rosengard was a student at the University of Delaware during the relevant time period.
23. Defendant Florian R. Ternes is a resident of Las Vegas, Nevada. Ternes was the CEO of GH3 during the relevant time period.