DECLARATION OF BRUCE HARLAN
By: nutced
28 Jun 2009, 10:56 AM EDT
Msg. 21042 of 21046
DECLARATION OF BRUCE HARLAN
I, Bruce M. Harlan, hereby aver as follows, on personal knowledge:
1. I am an adult individual, residing in Clearwater, Florida. I am an attorney,
licensed in Florida, practicing primarily in the areas of real estate and corporate
law. I also have acted as a corporate officer and consultant, seeking opportunities
including reverse mergers for small companies.
2. I know Jef~ey G. Turino, and had a close personal and professional relationship
with him ~-om at least 2000 through May 2006. I met Turino in approximately
1998, and worked closely with him as his attorney, on personal and family
matters, starting around 2000. I also represented Turino in handling matters for
Pinnacle Business Management, Znc., the company that Turino controlled. In
addition, Turino would use my attorney trust accounts to hold funds that Turino
received from various individuals. The matters I discuss below do not disclose
confidential attorney-client communications.
3. In late 2003, I became President of Pinnacle Business Management aRer Turino
was barred by the SEC from being an officer and director and subject to a fiveyear
penny stock bar. He appointed me to be president because he no longer
could serve. Previously, Turino had appointed me president ofCorbel Holdings,
a spin-off of Pinnacle. I acted solely under Turino's direction as president of
these companies, before and aRer the ban.
4. At Turino's request, I helped him engage in several Rule 504 penny stock
offerings.
5. I am personally familiar with Turino's ex-wife, Mary Turino, who lived in
Clearwater, Florida from at least 2000-2006.
6. Throughout 2004-2005, Turino lived with Melissa Spooner land me) in Las
Vegas during the week, and with Mary Turino on weekends in Clearwater.
Turino and Mary Turino were divorced in January 2008.
7. I am personally familiar with Turino's mistress and business assistant, Melissa
Spooner. She lived in Las Vegas, at least from 2001 through 2005. I met her in
January 2003. She was an exotic dancer at the Cheetah's nightclub in Las Vegas
fr-equented by Turino, until 2003, at which point she became Turino's mistress. In
2003-2005, I lived with Spooner intermittently in two houses in Las Vegas that
Turino rented. ARer Melissa became Turino's mistress in 2003, she quit dancing
and had very limited financial means. She depended on Turino for her housing,
health, and living expenses. Melissa Spooner regularly confided in me during that
period, and told me that she had no money except as provided by Turino. I
traveled regularly with Spooner and Turino, on various business and vacation
trips.
Case 8:02-cv-00822-EAK Document 39-12 Filed 05/29/2009 Page 1 of 4
8. In approximately June 2005, Spooner replaced me as Turino's primary assistant to
holdf imdsa, ndt o assisht imi n settingu p Rule5 04o fferingisn volvinpge nny
stock. From what I observed, Spooner had no financial background, and would
only act on financial matters under the direction of Turino. I understand Rule
504 offerings to be a method used by a company to raise up to a million dollars by
issuing penny stock shares.
9. In September 2005, Turino traveled with Spooner to Minnesota to set up a
company to assist them in undergoing Rule 504 offerings of penny stock. I
understand that company to be Mountain Passages. They told me about the trip,
and its purpose, before and aRer they traveled. They told me they met with a
broker and shopped at the Mall of America. Turino also told me that he needed to
set the company up in Minnesota, because it was the only state that would allow
an issuer to sell penny stock pursuant to Rule 504.
10. I am personally familiar with Robert Leslie. Turino introduced me in 2003, and
we became friends. I also represented him in a collection·matter. He was the day
manager in the Cheetah's club in Las Vegas where Spooner danced. From what I
know, he did not have any financial training, and did not seem sophisticated in
business matters. In January 2003, Turino invited Leslie, his wife, Cynthia
Leslie, myself, and others, to go to the Superbowl in San Diego.
11. I am personally familiar with Turino's step-daugher, Jennifer Lynch. I know that
she attended UNLV in approximately 2004 and lived in a house nominally owned
by Melissa Spooner, but paid for by Turino.
12. I am personally familiar with Samantha Turino, Turino's daughter. She went to
law school at Villanova, and Turino paid for her tuition. I am also aware that
Adam Barnett, a business associate ofTurino, wrote a $15,000 check to Villanova
to pay for Samantha Turino's tuition.
13. I am personally familiar with Adam Barnett. He and Turino had a business
relationship ~om which Barnett would give cash to Turino. I traveled with
Turino to Miami on several occasions at which Turino told me that Barnett gave
cash to Turino. Barnett was the CEO ofOMDA Oil and Gas.
14. I am personally familiar with Nikolaj Vissokovsky, a Russian-American
businessman. I worked with him for more than 25 years, as his lawyer, on various
personal, real estate, and corporate matters. In 2003, I helped him to ~incorporatea
corporation, Atlantic & Pacific Seafood, for which his daughter, Victbria Lee is a
corporate officer, but that he controls. I was also an officer and registered agent
for Atlantic & Pacific Seafood.
15. I introduced Vissokovsky to Turino in July 2003, and they began doing business
in the areas of corporate stock transactions and financing. Vissokovsky has a
Case 8:02-cv-00822-EAK Document 39-12 Filed 05/29/2009 Page 2 of 4
home in Russia, about an hour from Moscow, and is a frequent international
traveler.
16. Later in November 2005, Vissokovsky and Turino directed me to go to the Czech
Republic to visit a seafood factory. World Wide Cannery & Distribution, Inc.
was created to operate this seafood factory. Vissokovsky and Turino controlled
World Wide Cannery. Later, I understand that World Wide Cannery became
Global Diamond Exchange, Inc., which then traded under the ticker symbol,
GBDX.
17. On April 10, 2006, World Wide Cannery issued a press release claiming that it
had 14.5 million euros in annual revenue for 2005. I know that this press release
was false, because the seafood factory had been losing money and was
subsequently lost in foreclosure in February of2006.
18. I am aware that in December 2003, Turino was barred by the federal district court
in Tampa, Florida from participating in a penny-stock offering for five years. I
know that Turino, at a minimum, violated this penny-stock bar in 2004-2005 by
negotiating the BioTech Medics reverse merger and Rule 504 offering.
19. X am familiar with the circumstances surrounding the BioTech Medics reverse
merger with Corbel Holdings and penny stock offering that took place in mid to
late 2004.
20. Chris Jensen is a close friend ofTurino. In October 2004, Turino told me to meet
with Jensen, and a gentleman, Keith Houser, to look over a medical laser
company, Halo Laser, for a potential reverse merger with Corbel. We met in a
hotel room in Las Vegas, and Houser demonstrated his medical laser treatment on
me.
21. Thereafter, in November 2004, Turino and I, and others, traveled to Houser's
clinic in Dallas, to discuss the terms of the merger with Houser and his partners,
Rim Jacobs and Stephen Crane. Turino told me that I was going to receive 17
million shares of stock in the new company. At that meeting, Turino told the
parties present that all of the contact on this merger had to be with me, though I
had little knowledge of the details of the deal. He then began to structure and
direct the deal, the merger and the ensuing offering.
22. In November 2004, I went to the Czech Republic. While I was in the Czech
Republic, negotiations for the deal continued without my participation.
Subsequently, Turino called me and told me to come back to the U.S. to finalize
the deal. In early December, at Turino's direction, I flew to Las Vegas from
Prague. I met in Las Vegas at the transfer agent, Helen Bagley's office, to sign
the closing agreements, which included the merger documents and a 504 offering.
Present at the closing were Turino, Jensen, Houser, Jacobs, Bagley, myself, and
others.
Case 8:02-cv-00822-EAK Document 39-12 Filed 05/29/2009 Page 3 of 4
23. In early 2005, there was another meeting at Helen Bagley's of~ice to iron out
problems with the BioTech Medics merger and offering. Turino was present and
ran the meeting, and calmed down the dispute.
24. Helen Bagley was the transfer agent on the BioTech Medics, Inc. offering.. She
had a close relationship with Turino. Bagley's company, Ist Global Stock
Transfer, was the transfer agent on several penny stock issuers, CMKX, Pinnacle,
Corbel, and BioTech Medics, where Turino was involved. When in my capacity
as president of Corbel or Pinacle, I would ask Bagley to do something, she would
first say she had to check with Turino.
25. The last discussion I had with Turino was in May 2006. Lbelieve he has since
been living overseas.
I~d~e/c/l~usned er penalty of perjury that the foregoing is true and correct. Executed this
~zC~Y~aoafyN ovember2, 008.
Bru~
