Wanderport Corp (WDRP)

[Lexit]

Google Translation for the decision and motion.

Everything is translated except for the title and the addresses.


BUREAU DE DECISION ET DE REVISION

CANADA
PROVINCE DE QUEBEC MONTREAL


DOSSIER No : 2011-026


DECISION No : 2011-026-001

DATE : Le 11 juillet 2011



EN PRESENCE DE : Me ALAIN GELINAS
Me CLAUDE ST PIERRE





AUTORITE DES MARCHES FINANCIERS, 800, Square Victoria, 22e etage, C.P. 246, Montreal, district de Montreal
Partie demanderesse
c. '
EXCEL GOLD MINING, 1411, rue Peel, bureau 600, Montreal (Quebec) H3A 1S5
et
9157-0945 QUEBEC INC. faisant affaires sous le nom d'lnvestment Traders &
Associate inc., 1411, rue Peel, bureau 600, Montreal (Quebec) H3A 1S5 et
9198-6208 QUEBEC INC., 1002, rue Sherbrooke Ouest, 28e etage, Montreal (Quebec)
H3A 3L6 et
CAPITAL CASTELLANE INC., 1002, rue Sherbrooke Ouest, 28e etage, Montreal
(Quebec) H3A 3L6 et
lAB MEDIA INC., 1400, rue Begin, Montreal (Quebec) H4R 1X1 et
MAGMA DRILLING, 492, rue Cuddihy, Rouyn-Noranda (Quebec) J9X 4C4
et
NEURO-BIOTECH INC., adresse inconnue au Quebec et




PROACTIVE COMPUTER SERVICES, 1212, Redpath Crescent, Montreal (Quebec) H3G 2K1
et
CONSEILS HILBROY INC., 1400, rue Begin, Montreal (Quebec) H4R 1X1 et
WANDERPORT CORP., 17445 US Highway 192, Suite 1, Clermont, FL 3471461 USA
.
935063 ALBERTA LTD, 1800, rue McGill College, Montreal (quebec) H3A 3J6 et
6570542 CANADA INC., 2815, rue Cazeneuve, Montreal (Quebec) H4R 1V3 et
JECEMAR IMMOBILIER INC., 1040, avenue Gilles-Villeneuve, Berthierville (Quebec) JOK 1AO
et
JEAN-FRAN<;OIS AMYOT, 237, chemin Langevin, Delage (Quebec), J9E 3A8 et
ANDREW BARAKETT, 2815, rue Cazeneuve, Montreal (Quebec) H4R 1V3 et
SALVATORE BRUNETTI, 320, de Ia Rive-Boisee, app. 802, Pierrefonds (Quebec) H8Z 3M2
et
ANDREA CORTELLAZZI, 1321, rue Sherbrooke Ouest, app. D-120, Montreal (Quebec) H3G 1J4
et
MICHEL DEMONTIGNY, 1220, rue Rembrandt, Brossard (Quebec) J4X 2G2 et
XAVIER DEMONTIGNY , 159, rue Normandin, St-Jean-sur-Richelieu (Quebec) J2Y 1E4 et
DOMINIC GINGRAS, 925, boul. de Maisonneuve Ouest, app. 183, Montreal (Quebec) H3A OA5
et
MARTIN HARVEY, 954, rue Notre-Dame Est, Repentigny (Quebec) J5Y 1C8 et
MICHEL LEBEUF, 5725, avenue McAlear, C6te-Saint-Luc (Quebec) H4W 2G8
et
YANNICK LESSARD, 237, chemin Langevin, Delage (Quebec) J9E 3A8 et
PATRICK LESSARD, 1955, rue Adela-Lessard, Quebec (Quebec) G2K OA3
et
NICOLAS MATOSSIAN, 1951, chemin Nicholas-Austin, Austin (Quebec) JOB 180 et
JEAN-SEBASTIEN OLLU, 7538, rue Querbes, Montreal (Quebec) H3N 286
et




MARC-ALEXANDRE OLLU, 1420, avenue Bernard, app. 16, Outremont (Quebec) H2V 1W3
et
MARJE-CHRISTINE OLLU, 461, rue Linda, St-Roch-sur-Richelieu (Quebec) JOL 2MO
et
SERGE OLLU, 1420, avenue Bernard, app. 16, Outremont (Quebec) H2V 1W3 et
DANIEL PAUZE, 8428, rue Aurele-AIIard, Montreal (Quebec) H2M 2T5
et
DENYSE RAYNAULT, 1420, avenue Bernard,•app.16, Outremont (Quebec) H2V 1W3 et •
PATRICK GAGNE, 1420, avenue Bernard, app. 16, Outremont (Quebec) H2V 1W3 et
MICHEAL D'AMICO, 1420, avenue Bernard, app. 16, Outremont (Quebec) H2V 1W3 et
JACQUES VALLEE, 1420, avenue Bernard, app. 16, Outremont (Quebec) H2V 1W3
et
STEPHANE FRECHETTE, 1420, avenue Bernard, app. 16, Outremont (Quebec) H2V 1W3
Parties intimees
et
INVEST DIRECT HSBC, 5100, rue Sherbrooke Est, bureau 100, Montreal (Quebec)
H1V 3R9 . et
BMO NESBITT BURNS, a/s: Me Julie Gallagher 1501, rue McGill College suite 2800,
Mtl Quebec H3A 3M8 et
CIBC WOODGUNDY, a/s : Mme Maryse Lepine, 600, Soul. Maisonneuve ouest, suite
3050 Mtl, Quebec H3A 3J2
et . .
BMO LIGNE D'ACTION, a!s : Me Julie Gallagher, 1501, rue McGill College suite 2800,
Mtl Quebec H3A 3M8 et
FINANCIERE BANQUE NATIONALE, a/s: M. Gabriel Cere, Edifice Sunlife 1155, rue
Metcalfe, 4ieme etage, MTL, H3B 4S9 et
VALEURS MOBILIERES DESJARDINS INC., a/s: M. Stephane Turmel, 1170, rue
Peel, Bureau 300, Montreal (Quebec) H3B OA9 et
INDUSTRIELLE ALLIANCE VALEURS MOBILIERES, a/s : Mme Linda Boiteau, 6700,
boul. Pierre Bertrand, bureau 300, Quebec G2J 084 et




CORPORATION CANACCORD GENUITY, a/s: M. Marvin Zwikler, 1250, boul. Rene­ Levesque Ouest. bureau 2000 H3B 4W8
et
RBC PLACEMENT DIRECT INC., a/s : M. John Caucci, 1, Place Ville-Marie, bureau
300, Montreal H3B 4R8 et
TD WATERHOUSE CANADA INC., a/s : Mme Christiane Manning, 500, rue St-Jacques
Ouest, 5ieme etage, Montreal H2Y 1S1
Parties mises en cause •




EX PARTE ORDER TO CEASE TRADING AND CLOSING OF A WEB SITE DECISION ON APPLICATIONS FOR TRADING BAN, BAN TO ACT AS ADVISOR, LOCK, site closure
INTERNET AND THE REGISTRY DEP6T LACOUR UPPER AND DECISION FOR A SPECIAL MODE OF SERVICE
[Art. 249, 265, 266, Act / es securities, RSQ, c. V-1.1, ss. 93, 94, 115.9 and
115.12 Act I'Autorite of financial markets, RSQ, c. A-33.2 and Art. 16 Regulations / es rules of procedure and decision of the Office of Review (2004) 136 G.0. II,
4695]




Me Melanie Hebert
(Girard et al.)
Attorney I'Autorite of financial markets






Hearing date: June 30, 2011








DECISION



[1] On June 29, 2011, I'Autorite des marches financiers (the I after "Authority") seized the

Office decision and revision (listed after the "Board") of an ex parte application, that he speaks the following decisions, namely:

• a restraint order;

• an order to cease trading in securities;

• an order interdictlon to exercise counseling;

• an order to close websites;

• an order for deposit to the office of Superior Court Ia, and

• a decision to a special mode of service.

[2] These orders were sought under sections 249, 265 and 266 of Ia mobi/ieres1 Securities Act, articles 93, 94, 115.9 and 115.12 of Ia Act I'Autorite steps and financiers2! Article 16 Regulations / rules of procedure are the
Office decision and Revision3. A Ia response to this request, the Bureau held an ex parte hearing June 30, 2011, is headquartered.

[3] The application was presented I'Autorite under! Section 115.9 of Act Ia
/ Autorité des marchés financiers, that it is lawful for the Board to issue a decision adversely affecting the rights of a person without a prior hearing, when a compelling reason. An ex parte hearing was done at the headquarters of the Office June 30, 2011, that I'Autorite can submit an application.

[4] The Authority has filed with the application! Affidavit required! Article 19 of Regulations on Rules of Procedure of the Office and revision4 decision, under which a claim based on compelling reasons must be accompanied by a declaration
sworn written in support of the facts of Ia demand and compelling reasons. Of
copies of application I'Autorite Ia and Ia sworn declaration annexed to Ia present decision.




R.S.Q. 1, c. V-1.1.
R.S.Q. 2, c. A-33.2.
3 (2004) G.O. II, 4695.
4 Ibid.




HEARING

[5] As noted above, Ia demand and I'Autorite! Affidavit provided for in Regulation are dOment annexes Ia was present decision. The allegations of this application are incorporated Ia present decision as if they were denominated throughout. During
! 'Ex parte hearing of June 30, 2011, Ia I'Autorite attorney has heard the
testimony of an investigator employed by the latter.

PROOF OF AUTHORITY

[6] He testified that the facts listed in Ia Ia filed application and documentation. He added that June 29, 2011, I'Autorite raided the premises of Montreal's Excel Gold Mining companies (referred to after
"EGM") and LAB Media inc. (The after "LAB"). Boxes of documents and computers were seized there.

[7] During the search, no one ran for local EGM while some people were in the premises of IAB. One of them was interviewed by an investigator I'Autorite. In addition, it was found that Ia IAB company was through his website "ltsallbull.net" Ia promotion titles de.Ia Wanderport Corp. company. (The after "Wanderport"). Respondent! proceedings. He has personally re <; u alerts about this web site as recently as June 25, 2011.

[8] The investigator also noted that recently, the company Neuro-Bi9tech inc., Also respondent, issued false press releases. Thus, 6 April 2011, it produced a press release claiming that a representative of this company had a
Montreal in March 2011 a presentation was a Deputy Minister of Ministry of
Economic Development of Russian Federation Ia. After verification, the
information has been totally disproved.

[9] The investigator also submitted into evidence an operational plan EGM
providing, it seems, the unveiling of new designed to influence the course of
Ia as a society. Still according to the investigator, some of these cases are confirmed by
! Acquisition of assets and Ia conclusion of certain mining contracts he has Ia evidence. The investigator also acknowledged that all the accounts that requested the Bureau to block were inactive and mostly empty of funds.

ARGUMENTS OF AUTHORITY

(10] Counsel for I'Autorite then argues that the folder that was presented to the Board is complex, but it reflects a new market realities. It refers to a group of people who operate in concert and Some of these people were left in files or the Bureau had already been reached. If it's first illegal distributions and solicitations to invest, also looms behind, while a model of stock market manipulation, such that 'would make faith




some evidence obtained through the survey of I'Autorite he reported in Ia request.

[11] In that case, Ia Attorney I'Autorite deals with promoters who were frothing titles, see Ia need to create a volume of transactions. It points out that this is an offense under! Article 195.2 of Act Ia / es

values ??mobilieres5

The facts submitted in Ia demand back essentially to

years 2009 and 2010. But given Ia complexity of the facts, I'Autorite chose to take a step back! Whole file.

[12] But are all the same compelling reasons to intervene, given a market manipulation behind which is an organization. These actions have as it begins in 2009, bring a I'Autorite eta in 2010 to investigate a raid during this year. I'Autorite but decided to wait before appearing before the Board with this matter. Counsel for I'Autorite revise the facts of Ia application, it is a series of manipulations of documents justifying the conclusions urged by I'Autorite.

[13] It places particular emphasis on securities manipulation Ia Wanderport would have taken place recently. The investigator in the record has received three warnings, including one dating back to barely 25 June 2011. There ploy done and therefore, a compelling reason to pronounce the order sought. As a society Ia Neuro Biotech inc., I'Autorite no evidence of promotion of the securities of the latter.

[14] But there is a factual framework of a large network. Press releases were published until April 2011, proving Ia manipulation of securities on the market at hand until that date by publication of new Ia. As a company EGM Ia, the compelling reason to do was revealed by a search of I'Autorite Ia. It revealed a document containing an operational plan for 90 days turned into
2009.

[15] From this, reference is a origin of Ia • promotion of the securities. Some contracts were entered into evidence proving Ia implementation of this plan. Attorney for Ia, a network decided to take contr61e EGM and make Ia promotion. There is convincing evidence for her presence of Ia a ploy of manipulation. Like what securities are traded, even s. 'there is no actual evidence of promotion.

[16] Counsel for I'Autorite proceeds around individuals and entities that would be subject to the prohibitions and blocking it asked the Office to deliver, either in general or specific. She asked the Office to block some accounts, even if it reconnalt they are almost empty and inactive. It



5 above, note 1, art. 195.2. It is an offense to influence or attempt to influence the course or Ia value of a security by means of unfair, improper or fraudulent.



justifies this by submitting that this would prevent their use to other companies that I'Autorite has not yet discovered.

[17] It further requests the Bureau to authorize the filing of its decision to intervene in the office of Superior Court Ia. Asked about the effects of such a decision, she said it was important to strike a balance between protection of Ia walk! "Investor interest but also the rights of private.

ANALYSIS

[18] The Board has carefully read request I'Autorite Ia. He listened to the testimony of its investigator also noted the numerous documents submitted as evidence. Entin, he also listened! 'Argument of Ia Ia representante plaintiff who pleaded to be pronounced the many conclusions sought.

[19] The least that the Bureau can say is that this is a very complex. Its frame is difficult to trace evidence of fa <; is clear. The events in question date back at least until 2008. ALLEGED some that are intertwined in this frame are actually events that the Office has already ruled in some respects in the past, ordering bans and blocks, when necessary.

[20] We will be here in the presence of market manipulation operations initiated by a large number of people, they have tried over the years to promote the titles of some of the corporate respondents to lather Ia value and then sell the securities they owners are to collect the profits due to rising • Ia prices caused by their manCEuvres.

[21] The above is not new, the Bureau has been a few occasions to comment on these methods of enrichment at the expense of investors. They buy securities Ia optimistic faith of representations made to them but find themselves at the end of course with the same titles that have lost most of their value, when the promoters were removed from the game recently, the Bureau delivers a detailed decision that subject6 •

[22] However, the appearance of the folder that holds also! Attention of the court Ia presence or absence of compelling reasons justifying the decision of the decisions requested, but not intimate that can be heard at this preliminary stage. In other words, taut exists in this case a certain urgency to act, justified by real risks including dispossession of investors.


6 Autorite des marches financiers c. Normand Bouchard and at .. Office decision and revision, Montreal, No. 2009-041, June 27, 2011, M85 A. Gelinas and C. St Pierre, 33 pages.




[23] can then be a departure from the principle that a party has the right to state his case before the Office to respond to criticisms by I'Autorite, Ia evidence contradicting it. Done based on the shoulders of the burden of proving I'Autorite! Existence of compelling reasons, proving! Existence of a risk that needs immediate action on the spot.

[24] And that's the rub Ia. Own admission de.Ia I'Autorite attorney, the latter begins to investigate the incident in 2010. She was conducting a search that time. But faced with Ia complexity of this issue, she chose to wait and not to appear before the Board for emergency decisions. She tries to unscramble plut6t the case and assemble more information on the whole.

[25] But the choice of Ia plaintiff has consequences. By acting as it seriously blunts what could have been at the time accounted for compelling reasons that would justify that audi alteram partem rule Ia is rebutted in respect of the many intimate on this occasion. But compliance with this rule is fundamental and very serious reasons alone would justify it being rejected here. By pushing back the time for action, compelling reasons have faded.

[26] This should benefit the intimate giving them the right to be heard and to respond directly to facts proven by I'Autorite. All this being said, all the same apparalt the abundant evidence that certain facts I'Autorite occurred more recently and suggest that certain manipulations of securities took place recently and that should be acting at their regard. In the case of Ia Wanderport company, the interviewer has to I'Autorite re <; u an alert in June 2011 is currently trying to prove that foam Ia value of this stock has increased Ia.

[27] In the case of Ia Neuro-Biotech company inc., A press release was issued in April 2011 Citing a recent meeting between Russian Deputy Minister and a representative of this company. But it was proved by the investigators that no such thing had occurred, suggesting that it was primarily intended to mousseIa value of securities of that company.

[28] In these circumstances, but only under these circumstances, the Board believes that there may be a need to act quickly and "to issue a decision more limited than I'Autorite request, but may have the effect of prevent other investors are deceived by those currently using these means to attract them. reconnalt Office here exists a compelling reason to act and prohibit transactions in respect of such securities.

[29] F <; is a corollary, the Office is also ready to order closure of Ia website "ltsallbull.net" which is operated by Ia company IAB Media inc. served as a relay Alerts Wanderport titles. But these are the only decisions that



Office is ready to decide without hearing the parties. The allegations about the manipulation of the securities of EGM are not contemporary character that would justify prohibiting the Bureau Ia Ia negotiation based on compelling reasons.

[30] The general prohibitions of trading in securities and to act as a consultant are currently not justified without hearing the parties. The freeze orders are requested does not. The Authority acknowledged that the accounts in question
are inactive and do not contain almost anything. The fear that companies which
I'Autorite unknown to the name can use it does not convince the Office of
decide on requests blocks Ia basis of compelling reasons.

[31] Given the limited scope of Ia Ia decision of the Bureau, it does not consider it necessary to file with the Registry of Ia Ia Superior Court. In addition, the Bureau took
knowledge of Ia I'Autorite request for a special mode of service of
Ia this decision to the companies and Wanderport Neuro-Biotech. Plaintiff
desire that their meaning can be made through a press release on the website I'Autorite.

[32) • The Bureau is prepared to allow this type of special meaning, a meaning that Ia condition of the present decision by registered mail to these
companies at their respective addresses in the United States is also accomplished. The
Office is also ready to authorize Ia significance of his decision to put in
cause has to be done! attention of persons described in Ia description of housing
because at the beginning of this decision.

[33] Finally, the Bureau is that it is possible to present a I'Autorite Office an application based on the facts of this case. The court may schedule a hearing so that all parties have! Opportunity to be heard.

DECISION


[34] Considering! Analysis shown above in this case, the Office is ready to pronounce € H! Order to cease trading in securities ex parte
Next, all under! Article 265 of Ia Securities Act and mobilieres7

Articles 93 and 115.9 of Ia Act I'Autorite steps financiers8

It is also ready

made an ex parte as to ensure compliance with Act Ia securities, namely Ia closed website "ltsallbull.net", all under
I'article 94 of Act Ia I'Autorite of financial markets.

[35] The Office also welcomes requests • Special mode of signifi.cation
I'Autorite in Ia form after appearing here, all under! Article 16 of

7 above, note 1.
8 above, note 2.



Regulation respecting rules of procedure of the Bureau of decision and revision9.
However, the Board rejects request I'Autorite Ia with respect to other ex parte interim measures applied for, that other orders of cease trade securities, act as a consultant, locking and closing of
Other Internet sites and deposit in the office of Superior Court Ia, all under sections 249, 265 and 266 of Act Ia securities, 93, 94, 115.9 and
115.12 Act of Ia I'Autorite of financial markets.

1) ORDER CEASE OPERATIONS ON SECURITIES PURSUANT TO SECTION
265 OF THE SECURITIES ACT AND OF ARTICLES 93 AND 115.9 OF THE ACT ON THE FINANCIAL MARKET AUTHORITY:

• It prohibits persons whose names appear below after any activity to effect transactions in securities of Ia company
Wanderport Corp., Namely:

• Wanderport Corp., Its officers, directors and employees;

65705442 • Canada inc., Its officers, directors and employees;

• Advice Hilbroy inc., Its officers, directors and employees;

• Jean-Fri: m is Amyot;

• Andrea Cortellazi, and.

• Andrew Barakett.

• It prohibits persons whose names are listed after any activity to effect transactions in securities of Ia company Neuro
Biotech inc., Namely:

• Neuro-Biotech inc., Its officers, directors and
employees;

• Andrea Cortellazi, and

• Serge Ollu.






Pn3cite 9, note 3.




2) ORDER TO ENSURE COMPLIANCE WITH THE LAW ON VALUE $ SECURITIES PURSUANT TO ARTICLES 94 AND 115.9 OF THE ACT ON THE FINANCIAL MARKET AUTHORITY:

• He ordered Ia company IAB Media inc. to close the website
"Ltsallbull.net" she holds within a period of 24 hours of Ia signification
of the present decision;

3) DECISION ON REQUEST FOR CEASE OPERATIONS IN SECURITIES, CEASE TO ACT AS ADVISOR AND LOCK, UNDER SECTIONS 249, 265 AND 266 OF THE ACT MOBIL SURL VALUE $ / ERES AND ARTICLE 93
AND 115.9 OF THE ACT ON THE FINANCIAL MARKET AUTHORITY:


• It rejects requests ex parte remaining I'Autorite which relate to a cease trade order, a restraining order to act as an advisor and a restraint order;

4) Decision on the ex parte application to issue an MEASURES TO ENSURE COMPLIANCE WITH THE LAW ON VALUE $ SECURITIES PURSUANT TO ARTICLES 94 AND
115.9 OF THE ACT ON THE FINANCIAL MARKET AUTHORITY:

• It rejects Ia I'Autorite ex parte application to close remaining websites;

5) DECISION ON REQUEST FOR SUBMISSION OF THE DECISION AT THE REGISTRY OFFICE OF THE SUPERIOR COURT, PURSUANT TO SECTIONS 115.12 AND 115.9 OF THE ACT ON THE FINANCIAL MARKET AUTHORITY:

• It rejects Ia ex parte application of the present depot decision in the office of Ia Superior Court for the District of Montreal;

6) MODE DECISION FOR A SERVICE UNDER ARTICLE 16 OF f? EGULATION SURL RULES OF PROCEDURE OF THE BOARD OF REVIEW AND DECISION:

• • IT AUTHORIZES that Ia Ia meaning of this decision to the Neuro-Biotech companies inc. and Wanderport Corp. . Is done via Ia publication of a press release on the website of I'Autorite
financial markets, provided that such Ia is also trying to Ia
serve them by registered mail to their respective addresses to
United States;


• authorize the Ia Ia meaning of this decision to put at issue in this case has to be done! Attention of the persons whose names



Ia appear in descriptions of these said defendants at the beginning of the present decision.

[36] Under the second paragraph! Section 115.9 of Act Ia I'Autorite of financial markets, the Office informed the respondents that an ant perfode two weeks
to ask the Bureau to hold a hearing on a Ia present decision. This one
then be held in Courtroom Ia Paul Fortugno which is located at 500 Boulevard
Rene-Levesque West, Suite 16.40, Montreal (Quebec).

[37] It is then up to the intimate contact the General Secretariat of the

Office at 1-877-873-2211 to! Inform that they intend to exercise their right to be heard. The respondents are also asked to note that a party has the right to

be represented by avocat10

The Office also informs the corporate

and entities wishing to be heard in the present case they are required to be represented by counsel at a hearing before the Office 11 •

[38] As for the rejected applications seen! Absence of compelling reasons, the Office reserves the right to I'Autorite to reapply through the process
preyu a! Article 115.8 of Ia Act I'Autorite of financial markets.

Done at Montreal, July 11, 2011.

(5) Alain Gelinas
Me Alain Gelinas, president


(5) Pierre Claude 5t
Mr. Claude St Pierre, Vice President




COPY



10 Rules of / es rules of procedure and decision of the Office of Review, supra note 4, art. 31.
11 / d., Art. 32.


--------------------------------------------------------------------------------------

BUREAU DE DECISION ET DE REVISION

PROVINCE DE QUEBEC MONTREAL
DOSSIER N°

AUTORITE DES MARCHES FINANCIERS,
800 Square Victoria, 22e etage, C.P. 246, Montreal, district de Montreal

DEMANDERESSE

c.

EXCEL GOLD MINING, 1411, rue Peel, bureau
600, Montreal (Quebec) H3A 1SS

9157-0945 QUEBEC INC. faisant affaires sous le nom de Investment Traders & Assocai te
inc., 1411, rue Peel, bureau 600, Montreal
(Quebec) H3A 1ss •

9198-6208 QUEBEC INC., 1002, rue Sherbrooke
Ouest, 28e etage, Montreal (Quebec) H3A 3L6

CAPITAL CASTELLANE INC., 1002, rue Sherbrooke Ouest, 28e etage, Montreal (Quebec) H3A 3L6

JAB MEDIA INC., 1400, rue Begin, Montreal
(Quebec) H4R 1X1

MAGMA DRJLLING, 492, rue Cuddihy, Rouyn­ Noranda (Quebec) J9X 4C4

NEURO-BIOTECH INC., adr sse inconnue au
Quebec

PROACTIVE COMPUTER SERVICES, 1212, Redp?th Crescent, Montreal (Quebec) H3G 2K1

CONSEILS HILBROY INC., 1400, rue Begin, Montreal (Quebec) H4R 1X1

WANDERPORT, 17445 US Highway 192, Suite 1, Clermont, FL 3471461 USA

935063 ALBERTA LTD, 1800, rue McGill­ College, Montreal (Quebec) H3A 3J6



6570542 CANADA INC. 2815, rue Cazeneuve, Montreal (Quebec) H4R 1V3

JECEMAR IMMOBILIER INC. 1040, avenue
Gilles-Villeneuve, Berthierville (Quebec) JOK 1AO

JEAN-FRANCOIS AMYOT, 237, chemin
Langevin, Delage (Quebec), J9E 3A8

ANDREW BARAKETT, 2815, rue Cazeneuve, Montreal (Quebec) H4R 1V3

SALVATORE BRUNETTI, 320, de Ia Rive­ Boisee, app. 802, Pierrefonds (Quebec) H8Z 3M2

ANDREA CORTELLAZZI, 1321, rue Sherbrooke
Ouest, app. D-120, Montreal (Quebec) H3G 1J4

MICHEL DEMONTIGNY, 1220, rue Rembrandt, Brossard (Quebec) J4X 2G2

XAVIER DEMONTIGNY, 159, rue Normandin, St­ Jean-sur-Richelieu (Quebec) J2Y 1E4

DOMINIC GINGRAS, 925, bouL de Maisonneuve
Ouest, app. 183, Montreal (Quebec) H3A OA5

MARTIN HARVEY, 954, rue Notre-Dame Est, Repentigny (Quebec) J5Y 1C8

MICHEL LEBEUF, 5725, avenue McAlear, C6te­ Saint-Luc (Quebec) H4W 2G8

YANNICK LESSARD, 237, chemin Langevin, Delage (Quebec ) J9E 3A8 _

PATRICK. LESSARD, 1955, rue Adela-Lessard, Quebec (Quebec) G2K OA3

NICOLAS MATOSSIAN, 1951, chemin Nicholas­ Austin, Austin (Quebec) JOB 1BO

JEAN:-SEBASTIEN OLLU; 7538, rue Querbes, Montreal (Quebec) H3N 2B6

MARC-ALEXANDRE OLLU, 1420, avenue - Bernard, app. 16, Outremont (Quebec) H2V 1W3

MARIE-CHRISTINE OLLU, 461, rue Linda, St-Roch-sur-Richelieu (Quebec) JOL 2MO



SERGE OLLU, 1420, avenue Bernard, app. 16, Outremont (Quebec) H2V 1W3

DANIEL PAUZE, 8428, rue Aurele-AIIard, Montreal (Quebec) H2M 2T5

DENYSE RAYNAULT, 1420, avenue Bernard, app. 16, Outremont (Quebec) H2V 1W3

PATRICK GAGNE, 1420, avenue Bernard, app.
16, Outremont (Quebec) H2V 1W3

MICHEAL D'AMICO, 1420, avenue Bernard, app.
16, Outremont (Quebec) H2V 1W3

JACQUES VALLEE, 1420, avenue Bernard, app.
16, Outremont (Quebec) H2V 1W3

STEPHANE FRECHETTE, 1420, avenue
Bernard, app. 16, Outremont (Quebec) H2V 1W3



INTIMES Et
INVEST DIRECT HSBC, 5100 rue Sherbrooke
Est, bureau 100, Montreal (Quebec) H1V 3R9

BMO NESBITT BURNS, A/s: Me Julie Gallagher
1501, rue Mcgill College suite 2800, Mtl Quebec
H3A 3M8 .

CIBC WOODGRUNDY, A/s: Mme Maryse Lepine,
600, Soul. Maisonneuve ouest, •suite 3050 Mtl, Quebec.H3A 3J2

BMO LIGNE D'ACTION, A/s: Me Julie Gallagher
1501, rue Mcgill College suite 2800, Mtl Quebec
H3A 3M8

FINANCIERE BANQUE NATIONALE, A/s: M. Gabriel Cere, Edifice Sunlife 1155, rue Metcalfe, 4ieme etage, MTL, H3B 4S9

VALEURS MOBILIERES DESJARDINS INC., A/s: M. Stephane Turmel, 1170, rue Peel, Bureau
300, Montreal (Quebec) l-138 OA9

INDUSTRIELLE ALLIANCE VAlEURS
•MOBILIERES, A/s: Mme Linda Boiteau, 6700,



boul. Pierre Bertrand, bureau 300 Quebec G2J
084

CORPORATION CANAC ORD GENUITY, A/s: M. Marvin Zwikler, 1250, boul. Rene-Levesque Ouest bureau 2000 H3B 4W8

RBC PLACEMENT DIRECT INC., A/s: M. John Caucci, 1, Place Ville-Marie, bureau 300, Montreal H3B 4R8

TO WATERHOUSE CANADA INC., A/s: Mme Christiane Manning, 500, rue St-Jacques Ouest 5ieme etage H2Y 1S1



Request I'Autorite of financial markets under Articles 93, 94 and 115.9 and
115.12 Act of Ia J'Autorite of financial markets, RSQ, c. A-33.2, articles 249,
265, 266 of Act Ia / es is / ors securities, RSQ, c. V-1.1, and! Article 16 of
Procedural Regulations of the Bureau of decision and revision, c. V-1.1, r.0.1, 3



FINANCIAL MARKET AUTHORITY respectfully submit the following to the BOARD DECISION AND REVISION:

I. INTROOUCTION

A. The Autorité des marches financiers

1. La.demanderesse I'Autorite des marches financiers (the after "I'Autorite") is the charge! Application of Ia Act. / Es va / mobi ors / Logan Club, R.S.Q. c. V-1.1 (here after Ia
"SA") and Elijah shall serve therein in accordance with article 7 of Act Ia
• J'Autorite on the financial markets, RSQ, c. A-33.2.

B. Excel Gold Mining / Gold mines Excel inc.

2. Excel Gold Mining (here after "EGM") is a corporation incorporated under the Companies Act Ia Act, RSC (1985) c. C-44 (the Ia after "LSA") and registered with the registrar of companies in Quebec in October 1994.

3. The reported activity of this company is I'exploration mining.

4. The directors are of EGM Jacques Vallee and Stephane Frechette, the president is
Jacques Roy and his secretary was Martin Harvey.

5. Daniel Pauze served as President and Chief Executive Officer of Ia EGM.

6. Michel DeMontigny is presented as general manager of EGM, although his name does not appear to the statement of CIDREQ registrairre business of Quebec. • 11 has also chaired, en.novembre 2010, a meeting of shareholders of EGM.




7. EGM is a reporting issuer in Quebec, Ia trading on TSX Venture Exchange Venture
(The after "TSX Venture") as well as list of I'C? TC Market (hereinafter after I "OTC").

C. Investment Traders & Associates inc.

8. 9157-0945 Quebec inc. is a company that was incorporated on 1 June 2005 under Part 1A of Ia Ia Jes Companies Act, RSQ c. C-38, registered with the registrar of companies in Quebec and doing business under the name Investment & Traders
Associates inc. (The after "Investment Traders").

9. The reported activity of Investment Traders is 'holding company'. "

10. • director Dominic Gingras, president, secretary and treasurer of Investment
Traders. It is also! Sole shareholder.

11. Investment Traders has never been registered with I'Autorite as a dealer or adviser under LVM Ia. She has not held any registration office
for one of the disciplines has ntionnees m! section 13 of Act Ia Ia distribution of
and financial services (listed after "Distribution Act").

D. Downshire Capital Inc.. •

12. Downshire Capital Inc. .. (The after "Downshire") is a company which was incorporated on
June 23, 2006 under LSA Ia and registered with the Registrar of companies
Quebec since July 4, 2006.

13. Carol McKeown is the sole shareholder of Downshire. It is egafement Ia President, Secretary and Treasurer.

14. In addition, Daniel F. Ryan, the husband of Carol Mckeown, is one of the directing minds of Downshire.

15. Downshire www.pennystockchaser.corh operated the website, a website that was promoting several Ia stocks.

16. Downshire has never been registered with I'Autorite as a dealer or adviser under LVM Ia. She has not held any registration office for one of
programs listed in! Article 13 of Ia Distribution Act.

17. Carol Mckeown has never been registered with a I'Autorite as an adviser or securities dealer full-Ia under LVM.

18. Daniel F. Ryan is no longer registered with I'Autorite as an adviser or dealer in securities under Exercise piein Ia LVM.


19. June 25, 2010, the Bureau of decision and revision (listed after the "Bureau") advocate ", is restraint orders and cease trading in securities was against Carol
McKeown, Daniel F. Ryan, Downshire and a related company, Meadow Vista Financial
Corporation.



E. Tips Hilbroy inc.

20. Tips Hilbroy inc. (The after "Hilbroy") is a corporation that was incorporated Ie.
September 27, 2005 under LSA Ia, the name under Financial Group
Midland Baring. It is registered with the registrar of companies from the
November 21, 2005.

21. The reported activity of Hilbroy is "holding company", "financial services" being precise.

22. . JeanFran <; ois Amyot is a director, president, secretary and treasurer of Hilbroy.

23. TOYM Capital Inc. is the majority shareholder of Hilbroy. Jean-Fran <; ois Amyot is a director, president, secretary and treasurer of TOYM Capital inc.

24. Tips Hilbroy inc. has never been registered with I'Autorite as a dealer or adviser under LVM Ia. She has not held any registration office
for one of the programs listed in! Article 13 of Ia Distribution Act.

25. Jean-Fran <; ois Amyot.n has never been registered with a I'Autorite as an adviser or dealer in securities acting under Ia • LVM.

F. IAB Media inc.

26. JAB Media inc. (The after "LAB") is a corporation that was incorporated October 23, 2009 under LSA Ia and is registered with the registrar of companies • Since I
October 28, 2009.

27. The IAB is declared activity • "Other advertising services," with precision "promotion of Web sites."

28. The majority shareholder of this company is Hilbroy. Jean-Fran <; ois Amyot is the administrator while Julie Forget, his wife is secretary and Ia Ia Treasurer.

29. JAB owns several websites that are promoting several Ia equities, including:

ltsallbull.net
- Pennystockryder.com
- Hypergrqwthstock.com
- Stockpicksthatmove.net
- Simonsaysstocks.net
- Pennystocksociety.net
- Pennystockparty.net

30, LAB has never been registered with I'Autorite as a dealer or adviser under LVM Ia. She has not held any registration office for one of the disciplines
LISTED! Article 13 of Ia Distribution Act.




G. Wanderport Corp.

31. Wanderport Corp. (The after "Wanderport") is a company that was incorporated on
March 29, 2006, under the name • Temtex Industries, Inc., under the laws of the State of Delaware.

32. January 8, 2007, Temte Industries, Inc. Has changed its name to Wanderport Corp.

33. Wanderport leaders are Richard Martel (President), Jean-Amyot French (Vice
president communications) and Robert Simoneau (Vice President Technology).

34. The address is Wanderport 17445 U.S. Highway 192, Suite 1, Clermont, FL 3,471,461, USA. Wanderport has no known address in Quebec.

35. Wanderport actions are traded on the Pink Sheet. H. Neuro-Biotech inc.
36. Neuro-Biotech Corporation. (The after "Neuro-Biotech") is a company which was incorporated under the laws of the State of Nevada July 26, 1990 under the name of Quantitative Methods Corp.

. 37. January 17, 2007, Quantitative Methods Corp. has changed its name to M45 Mining
Resources Inc.. (The after "M45").

38. On February 11, 2010, M45 changes name to Neuro-Biotech Corporation.

39. Neuro-Biotech currently has no known address in Quebec.

40. Andrea Cortellazzi has been a shareholder of this company. As such, the documents submitted by
Neuro-Biotech Ia Securities and Exchange Commission (the Ia after "SEC") by Neuro
Biotech reveal that on 8 March 2007, Andrea Cortellazzi contr61ait over 56%
company Ia actions, participation has reduced 37.53% as of March 31, 2010.

41. Serge Ollu is a consultant for Neuro-Biotech.

42. The shares of Neuro-Biotech is listed on the Pink Sheet.

43. Andrea Cortellazzi and Serge Ollu have never been registered with a I'Autorite as an adviser or securities dealer full-Ia under LVM.

I. Others involved

44. Several other natural and legal persons are involved in this issue:


- Proactive Computer Services is a company of Andrea Cortellazzi not registered with the registrar of companies in Quebec and has no registration with I'Autorite. This company was used by Andrea Cortellazzi through investments in Wanderport.



- Andrew Barakett was involved in handling Ia Wanderport titles and has also compromised on the title of Wanderport through Ia company 6570542
Canada inc. which he is the president and largest shareholder;

- Daniel Pauze, Yannick Lessard, Patrick-Lessard, Nicolas Matossian Ia are involved in handling securities and re EGM "; u shares of EGM, as explained here after.

- 9198-6208 Quebec inc. is a company that was incorporated 17 June 2008 and is registered with the registrar of companies. Annie Lacasse is president and secretary. • The reported activity of Ia company is "mining and natural resources>>: The company re"; u EGM actions within a transaction explained here after.

- 935063 Alberta Ltd.. is a corporation which was incorporated May 18, 2001 and is registered with the registrar of companies and whose president Nicolas Matossian is, this company has rec, u shares of EGM.

- Denyse Raynault Ia is joint Ollu Serge, Jean-Sebastien Ollu, Ollu • Marc Alexandre, Marie-Christine Ollu are the children of Serge Ollu. have read all rec, u shares of EGM. •

- • Capital Inc. Castellane. is a company that was incorporated April 30, 2009 and is registered with the registrar of companies. Jean-Sebastien in Ollu. Is the president and secretary. The declared activity is "Manager - property investment and mining properties." She rec; actions u
EGM.

Salvator Brunetti Drilling Inc. and Magma. have rec, u shares of EGM by anyone-after explained.

- DeMontigny Xavier is the son of Michel DeMontigny. II rec, u shares of EGM.

- Michel Lebeuf is an attorney who has rendered professional services and that Andrea Cortellazzi rec, u shares of EGM by anyone-after explained.

45. These people are not registered with a I'Autorite as an adviser or securities dealer full-Ia under LVM. Yannick Lessard has also already been registered with I'Autorite:

- As a representative in insurance of persons. He has been inactive for June 30
2009 for non-renewal.

- As an investment representative. He has resigned December 31, 2008.

- As a securities representative of 21 November 2005 to January 10
2008.



II. FACTS

A. Summary

46. July 12, 2010, I'Autorite began an investigation in relation to investment activities of Andrea Cortellazzi, Serge Ollu, Wanderport and M45 (now Neuro-Biotech).

47. The investigation showed (the existence of scheme to manipulate the securities of
Wanderport, Neuro-Biotech and EGM, as explained here after.

B. Wanderport

48. As part of the survey, an investor who has subscribed for shares through Wanderport Andrea Cortellazzi, was encountered. 1 The investor made a statement mentioning the following facts:

- He was introduced to Mr. Coftellazzi through an acquaintance in July 2009.

- Mr. Cortellazzi told him he was a securities dealer, it was very profitable investment and that it was the owner of "Shell".

- Mr. Cortellazzi told him he could! Help in pla <; ant his money in a "shell" dqnt contr61e he had a "green way" very profitable: Wanderport. This investment should be safe, he could not lose. .

He has met many times Mr. Cortellazzi, Ia usually has its business offices, at 1212 Redpath Crescent in Montreal.


- It has invested an initial $ 20 000, presented by check at the offices of Mr. Cortellazzi located at 1212 Redpath Crescent. A Ia latter's request, it made the check payable to Proactive Computer Services, a company owned by
Mr. Cortellazzi.

- The check was cashed in a nursing collection.

- Mr. Cortellazzi has donated IARS another meeting at 1212 Redpath Crescent, a Proactive Computer Services letter confirming receipt of Ia! Money as well as investment in Wanderport.

- Mr. Cortellazzi has recontacted a week later, stating that he had made
. Thousands of dollars in profit. He also told her that a second wave of investment coming in VVanderport, that place became free, he dev: is investing
again to make more money and that it was urgent. He has agreed to invest with his business partner, investor 2, another $ 70 $ OQO, again
by two certified checks in the order of a Proactive Computer Services.

Both checks were cashed ant collection centers.

- Although the investor has a demand repayment of its investment, Mr. Cortellazzi him plut6t proposes other investments, including M45, a "v $ rita.ble bomb."




- About the M45, Mr. Cortellazzi told him he was about to do same thing with Wanderport Ia. The title was not yet ready, it was in the process of finalization.
Still has his office in the 1212, Redpath Crescent, he has shown a docu.ment, a
list with all shareholders of M45, according to Mr. Cortellazzi.

- Mr. Cortellazzi he explained that he was trying to recover all the actions of the title, to clean it and restart it.

.- At these meetings, Mr. Cortellazzi was always in front of his laptop on his desk of places third floor of 1212 Redpath Crescent. Said Mr. Cortellazzi receive emails from potential investors.


- Mr. Cortellazzi has said that! It was to get back quickly difficife money because. it was blocked in the U.S. and could not get out that small amounts a Ia
times to avoid detection by the tax in the United States and Canada.

- Mr. Cortellazzi then explained that Wanderport and M45 shells which are if the owner is. It has also expfique what are shells and manner in which Ia
it proceeds to give them value Ia. He said a compromise on these securities from
several accounts that contr61ait with small amounts and in consultation with
associates who were Ia Ia same thing to mount value of the security.

- Mr. Cortellazzi said he paid in shares of the promoters (including "Hilbroy"
"It's all Bull" and "Gold Spoon") and thus controls Ia • put on and the time
or if withdrawing its investment. The goal was to slowly Manter title by attracting other investors. It was the advantage of this factor, there.

- II he also explains how to open accounts with brokers in the United States, especially among and with JH Option Xpress oa • rbie to pass the money.


- Given! 'Inexperience an investor to open brokerage accounts, Mr. Cortellazzi told him to come to open its office, at 1212 Redpath Crescent, in
indicating that it was normal procedure Ia, all accounts have been open for the office. His son which he said usually handled the opening of accounts and he could help.

- The investor and a business partner, investor 2, opened accounts, but nothing rec; u. Lily wanted to get their money, Mr. Cortellazzi Ia constantly delayed delivery of their money under numerous pretexts.

- In September, Mr. Cortellazzi gave them two checks of $ 20,000 in reimbursement game! their investment, they were returned NSF mention Ia. The checks were issued by an associate of Mr. Cortellazzi or Barrecca Domenico.

After a few weeks trying to get back on money, the investor demanded a
Mr. Cortellazzi recognized amounts and gains. Mr. Cortellazzi replied that everything was in his office in 1212, Redpath Crescent. Investor 1
went there in October 2009 and got it a confirmation letter.




- Mr. Cortellazzi He was then awarded for $ 90 000 $ check, issued by company Digital Ia 9198-6166 Quebec inc. and signed by Antonio Savari purports to be an associate of Mr. Cortellazzi. Taus • the checks were issued to an account from the farm in July.

- The investor 1 and investor 2 has threatened to complain Cortellazzi M. M. Cortellazzi told them that if they reveal it all, he could no longer work and therefore, to repay them.

- Another associate, Serge Ollu, presented the investor 2 has a check for $ 15,000 Jean-Sebastien Ollu dated October 23, 2009. This check could be cashed in November 2009.

- Since, by way of the counsel for Mr. Cortellazzi, John • Bracaglia, the investor investor ret 2 rec, u a proposal for settlement of debts
giving them shares of M45, a proposal which they have not acted upon.

49. 2 The investor has been meeting and he gave Ia statement corroborates that of an investor.

50. A third investor has also provided a statement as part of the survey.
This statement declares that:

- Investors have three shows was presented to Mr. Cortellazzi by a friend, Ms. Jade Chabot, in June 2009. t'investisseur 3 was then a company and Mr. Cortellazziindiquait power! assist in its business plan.

- Mr. Cortellazzi has recalled two days later. He said he owned a shell which traded on the stock exchange, named Wanderport. He has made
representations of this shell has the effect that Ia faisair of control that
"Deals" with other companies. Mr. Cortellazzi has stated that the advantage
to invest through it based on the fact that beneticiait inside information. He said, "we buy, we sell))," we buy, we sell>>, "we buy, we sell", etc.. This is the true according to him to make! Money. He said they held millions of shares of that company.


Mr. Cortellazzi told him that by investing in the shell he controlled, he could get a yield of 35% to 40% in thirty days. He told her he could not
lose, there was no risk because they have control was to guarantee the title.


- The investor has presented three offices of Mr. Cortellazzi few days later, at 1212 Redpath Crescent, Montreal. II awarded him a sum of $ 1 800 in cash to invest in Wanderport and has rec, u no document has
• its investment ment.

- Mr. Cortellazzi asked if he knew other people who wanted to make money. The investor has three retere few names, including that of an investor.



- A Ia mid-September, Mr. Cortellazzi gave him a "rebate" of $ 500 in cash on its investment. The money was presented at 1212 Redpath Crescent, and Cortellazzi says was "just the beginning."

Having obtained such a performance and according to the representations of Mr. Cortellazzi as a new wave of investments in Wanderport, the investor has borrowed from three of its credit cards for about $ 5 000. invest with a new
Mr. Cortellazzi. Mr. Cortellazzi knew that! Money came from his credit cards, he said not to worry.

- When Ia request a refund, Mr. Cortellazzi replied that he could not repay it because he had reinvested! Money in another of his
shells, named M45. At no time did Mr. Cortellazzi consult.
3 investor to the investment. Mr. Cortellazzi has reported that M45 was
be a <<bomb "and he would do three times plu_s money. He also told her contr61er this title.

- Investor 3 shows introducing himself a dozen times at the offices of
Mr. Cortellazzi, at 1212 Redpath Crescent in Montreal. Mr. Cortellazzi was always
in front of his computer screen the third floor, and his son Michael, the fourth in
with another man, Tony.

- Mr. Cortellazzi always had an excuse not to pay it back ..

51. On June 17, 2011, research on the Internet MADE pa (I'Autorite investigators have found that the website itsallbull.net, operated by LAB, is promoting such as Ia Wanderport.

52. In addition, LAB sent to members of the website alerts that are promoting as Ia Wanderport and contain analyst:! S surl price of that security. • •


C. Neuro-Biotech

53. As part of an investigation prior to Ia this investigation, three investors said they invested in company Ia M45 following representations by Andrea Cortellazzi and Serge Ollu.

54. One of these investors, the investor, 4, shows that:

- 4 The investor and his wife invested a total of $ 285 000, Ia or all of their pension funds during the year 2008 in HE-5 Resources. The representations regarding the investment were made by Jacques Gagne, first, and then by Andrea Cortellazzi Serge Ollu.

Lily went to the offices of Mr. Cortellazzi at 1212 Redpath Crescent in Montreal, to meet Mr. and Mr. Cortellazzi Ollu with Mr. Gagne to January 2008.

The investor conriaissances 4 investment are slim and it is therefore not in me • sure to clearly explain the type of product in which it invests.



- II, however, indicates that the return has been promised by Mr. Gagne, M. and M. Cortellazzi Ollu was high. 4 The investor was to receive $ 60 000 per year and after
one year, Ia value of its investment would exceed $ 400 000.

- The investment in HE-5 Resources ultimately failed, according to Mr. Gagne and they lost everything.

Mr. Ollu responded to none of communications and notice that the investor has sent 4.

- On September 2, 2010, Mr. Gagne has found the investor for four! Inform that he managed to get Mr. and Mr. Cortellazzi Ollu 400,000 shares and 275,000 shares M45 Neuro-Biotech in compensation for its past losses.

- Mr. Gagne explained that he was Ia same company and he did open a brokerage account for him in the United States to deposit the share certificates. Actions vaudraierit 4 cents today, but watch pourra.ient 50 cents.

55. Note that Jacques Gagne is already the subject of a cease trade order issued by the Office folder 2005-04.

56. On September 8, 2010, I'Autorite to conduct searches at the offices of Andrea Cortellazzi at 1212 Redpath Crescent, Montreal and offices in Ollu Serge 4020 St-Ambroise, Suite 497, Montreal.

57. In search of the offices of Ia Andrea Cortellazzi, it made a statement freely and voluntarily collected by an investigator of the Authority.

58. Andrea Cortellazzi stated:

- He was pleased that I'Autorite be aware of! Existence of ltsallbull and
M. Amyot, but unrelated to them.

- He knows in what area they ceuvrent or Ia promote stocks.

- He would have met Mr. Amyot there are 2 or 3 years. This would have presented at 1212 Redpath Crescent to discuss the possibility to Ia Ia promotion of securities held by Mr. Cortellazzi. II, however, states that he never dealt with him.

- He said Ia ltsallbull similar technique used by the Pump & Dump.

- II indLque it is an effective strategy for the project sponsor and title, but it creates no \ (alue for Ia company itself.

- Mr. Cortellazzi states have never used this technique, as it considers illegal.

- Mr. Cortellazzi added that press releases issued for a period of promotion is misleading ("misleading," "its all bullshit"), especially when s'? Git empty shells.



Wanderport

- About Wanderport, it indicates that this is not his project, but that of Andrew Barakett, Conna • issance a long time.

- He was contacted by him there are more than two years to! Help establish a stock market that shell.

- His duties were to find for Mr. Barakett a transfer agent and a lawyer in the United States.

- To do this, he obtained more than two million shares of Wanderport, actions he has since sold or distributed.

Mr. Barakett, which has no specific title. Wanderport, was commissioned by
! Former board Wanderport. .

- Following a transaction with a Quebec company, represented by a certain Richard Martel, Wanderport had to have a real asset, a technology in water heaters.

- The transaction Wanderport Ia shells that owns the assets would still not completed ..

- Mr. Cortellazzi contends that at no time did solicit investors to purchase shares of Company Ia.

- He knows that Hilbroy ltsallbull and are involved in promoting Wanderport Ia, but that he had not been involved at this level.

- In fact, Mr. Cortellazzi pretend to have had a very limited role in Wanderport or only to find a transfer agent and a company lawyer to Ia.

M45 (Neuro-Biotech)

Mr. Cortellazzi said to have been in the past owner of several "shells"
publicly traded shells.

- The main have been M45. Mr. Cortellazzi said it was his "baby" and the main project he was involved over the last year.

- • M45 is a company listed on the Pink Sheet would have bought several years ago. The company was the central goal! Acquisition and! Exploration of mineral properties in the Matagami region Ia.

- The company had spent all his money in! Acquisition of securities ("claims").

- A Ia question how financial M45 <; has its operations, Mr. ' Cortellazzi responds that financial <; is itself Ia company.



Then Mr. Cortellazzi says he personally borrowed money from individuals and invested it in the M45.

Mr. Cortellazzi goes on to say that all Semmes collected from these individuals went to racq.uisition of "claims" mining.

- M45 had no bank account. Mr. Cortellazzi was gathering! Money from individuals personally, and he invested in M45. He says he never care! Money from investors for him.

- The terms agreed with the varied individual investors, some lent! Money to Mr. Cortellazzi and expecting a return to a gent. Others expected a return to action M45.

Mr. Cortellazzi states have lost much money with M45.

- It goes on to say that he has two options with M45 when things started to deteriorate (when the financial markets have collapsed).

- Either he continued to raise money from individuals to finance activities dia company, or it was setting up a "stock play."

Mr. Cortellazzi explains that a "stock" play "is a technique that is a mandate to a developer to rapidly increase the title and can sell the shares.

Mr. Cortellazzi nods when asked if it is a technique which is similar to Pump & dump.

- It states that this technique would Coate 20 to 30 million shares in new company shares Ia, and it would have had a short effect.

- He did not use this technique and, considering now in search Ia
. Course has its offices, he was very happy not to be used.


About solicited investors, he said it was people who heard about what he did, through the ((word of mouth. "

- Mr. Cortellazzi said he had, until recently, a lot of money to these individuals.

- Serge Ollu M45 and it would have taken would have made a new company, Neuro-Biotech. He added not being involved in this transformation and be very satisfied with the work of Serge Ollu.


- Mr. Cortellazzi would have signed letters of release from its investors, and qu'illeur handed actions of Neuro-Biotech in exchange qe debt.

lnvestisseurs 1 and 2



- On 1 and 2 investors, Mr. Cortellazzi pretend they have not lost money avec.lui, in that it still has to repay them.

- It seeks to have e_xplique! Money from these investors by stating that he had complete discretion in managing their money Ia. Thus, he said, they were not investing in a specific product.

He told them he was able. to give a yield of 20% to 30%, but shows! their own making no promises.

- It adds that rer, u of these investors! Cash, but mostly checks.

- On the path! Money collected from investors, he said avqir rec;; u! Money in the account of his company, Proactive Computer Services, and qu'ill'a transferred his brokerage account.

When the investigator • I'Autorite him reported seeing the pieces banking documents, and they say they have been collected in collection centers, he responds Cortellazzi • not remember.

- He said he lost! Money investors 1 and 2. The steps were very difficult since they have invested with him.

- Under their threats, it indicates that investors 1 and 2 have a strong hand over a letter of recognition of debt. •

- He says they have repaid a portion of money he owes them • and that plans always pay the remainder.

- Mr. Cortellazzi like to point out they were victims of harassment and threats from both Ia and investors have filed three police complaints Ia in this direction.

Although he admits to having received funds from investors in Quebec, Mr. Cortellazzi said it had completely stopped doing for over a year.

- He says sorry to have done and it was destroyed. Mr. Cortellazzi admits thinking about suicide AOAT in 2009 with the constant calls from investors and at the fact that he was rendered penniless. It would then "touches the bottom of the barrel" and would stop its activities from private investment.

- He added that to raise money from individuals was a mistake and "c,, a does not work."

59. The analysis of documents seized during the searches of September 8, 2010 and the steps subsequent survey have confirmed! Existence of a scheme to manipulate shares of Neuro-Biotech include the following elements:

- The agenda of a meeting for Neuro-Biotech scheduled for 6 December 2009
Quebec has an item on a schedule for press release
be published on the activities of Neuro-Biotech.





- The agenda includes topics for several press releases to come. Expects to release an order in advance the subject of press releases and dates
which they will be published.

- According to this, thirty-two (32) press releases Neuro Biotech will be published between January 8, 2010 and July 30, 2010. In handwritten notes also attached to the document, i! mention is made that the public relations strategies adjustment according Ia reactio.n of the market.

- In a press release issued January 25, 2011, Neuro-Biotech. announces signing of a Ia '. Ia letter of intent with Sigma-Aldrich Company, a company with headquarters in Israel.

- A Ia Following this publication, a representative of Sigma-Aldrich send an email to a Neuro-Biotech to be provided the name of person with whom Ia
it was in contact because he had no recollection of discussions. that may have occurred 'between the two companies.

- Neuro-Biotech Ia indicates that person with whom she was in contact is
Mr. McElligott. But selo [the representative of the Sigma-Aldrich, that person is no longer
Ia is the use of company since February 2007.

- In a press release of Neuro-Biotech dated April 6, 2011, mention is made that a representative of Ia company had. Meeting a Russian deputy minister
a! occasion of the <<Quebec / Russia Innovations Forum "held in Montreal March 28
2011.

After checking with the Ministry of Economic Development,
! Innovation and! Export Trade, Directorate Europe - Desk Germany, Central and Eastern Europe April 8, 2011, it appears that no person of Neuro-Biotech has participated in meetings with Russian delegation Ia.


In addition, July 13, 2010, Neuro-Biotech has announced creation of its subsidiary Ia Neuro Biotech Lab Canada Inc. in Montreal.

Although it appears as president and director of The Lab Ia company
Neuro-Biotech Canada inc. the REQ, Abdelkrim Louze told the investigator
I'Autorite, August 6, 2010, • he never agrees to hold such positions.

- Mr. Lauze is safety officer for the agency Garda at the airport in Dorval.

- When advised that his name has apparalt dE.l as president, sole director and secretary of Neuro-Biotech Lab report CIDREQ Inc_ Canada Business Register, which indicates that Ia company is registered since July 15,
M. Lauze was surprised to be appointed to these titles € since he never signed although
whatsoever. • He does not know who submitted this information.




D. EGM

60. In search of Ia B in September 2010, investigators seized I'Autorite a document entitled "90 days operationalist plan" prepared by Investment Traders for EGM, which describes the stages of the scheme to manipulate shares of EGM.

61. This document must include the following:

- The procedure for issuing and control of the shareholding.

- Individuals through which the shareholders will be left.


The timing and Ia fa <; on which promotion takes Ia.


- The shares in order to control the ownership of EM is shared among some leaders of EGM and other individuals associated with these half namely:

i. Daniel Pauze ii. Martin Harvey iii. Patrick Lessard
iv. Nicolas Matossian
v. Investment Traders
vi. Y nnick Lessard & other

62. In terms of 1a to promote I'action EGtyl, ceHe it is divided into three stages:

- The investor relations firm and a group of 20 Promotion Starts
May 2009 and have a goal to bring the price! action has $ 0.12 / share with
an average volume of 300,000 shares per day until June.

- Ia from early June to late August, a second promotion group will aim to bring the price! Action between $ 0.25 and $ 0.39.

- Between May 20 and June 21, an average of two press releases a week is planned and will be supported by a program of communication with shareholders, through publications and financial statements.

63. Checks I'Autorite investigators have confirmed that the site www.pennystockchaser, old opera by Downshire, was promoting as Ia before Ia EGM significance of Ia Bureau's decision dated June 25, 2010.

64. In parallel to the steps above. mentioned, the action plan provides for a scenario of EGM acquisitiori of mining properties for Ia period beginning in May 2009.

65. In this regard, investigators also seized I'Autorite, in search of Ia
September 8, 2010, contracts for the acquisition of mining properties occurred between EGM,
Capital Inc. and Castellane. (Jean-Sebastien Ollu, president), between EGM and Investment
Traders (Dominic Gingras, president), between EGM and 9198.-6208 Quebec inc. {Annie
Lacasse, president having given a proxy has Dominic Gingras) and finally, between
EGM and Denyse Raynault (joint Serge 011 \ - l).



66. These contracts are signed by the following:


- The purchase agreement reached between mining properties and EGM Capital Inc. Castellane. is signed by Jacques Vallee (for EGM) and Jean-Sebastien Ollu (for Castellane Capital inc.)

- The contract to acquire mining properties made between 9157-0945 and EGM
Quebec inc. is signed by Daniel Pauze (for EGM) and Dominic Gingras (for 9157 -
0945 Quebec inc.)

The contract for the acquisition of mining properties interveriu between 9198-6208 and EGM
Quebec inc. is. signed by Daniel Pauze (for EGM) and Patrick Gagne (for 9198 -
6208 Quebec inc.)

- The contract for the acquisition of properties m1n1eres reached between EGM and Denyse
Raynault is signed by Daniel Pauze (for EGM) and Denyse Raynault.


67. These contracts provide Ia sale of mining rights in exchange for equity issues of EGM Capital Inc. Castellane. (Jean-Sebastien Ollu, president), Investment Traders

(Dominic Gingras, president), 9198-6208 Quebec inc. (Annie Lacasse, president having given a proxy has Dominic Gingras) and Denyse Raynault (joint Serge Ollu).

68. The shares obtained by the companies mentioned prerequisites are transferred to several people, including Downshire apital inc., Magma Drilling, Xavier DeMontigny, Salvatore Brunetti, Michel Lebeuf, Patrick Gagne, 935063 Alberta Ltd., Michael D'Amico, Jean-Sebastien Ollu, Marc-Alexandre and Marie-Christine Ollu Raynault-OIIu.

69. The analysis of transactions bou rsieres • MICA in the reports found that people mentioned above as well as those involved in the scheme of manipulation are traded on the title of EGM;


70. This analysis also reveals that the stock transactions were made at
same number of brokerage accounts identified in the attached table A;


71. More precisely, Downshire Capital Inc.., Magma Drilling, Xavier DeMontigny, Salvatore Brunetti, Michel Lebeuf, Patrick Gagne, 935063 Alberta Ltd., Michael D'Amico, Jean Sebastien Ollu, Marc-Alexandre Ollu, Marie-Christine Raynault-OIIu, Jecema ( lmmobilier
inc. (A company related to Martin Harvey) Harvey Martin, Dominic Gingras, Daniel Pauze,
Denyse. Raynault, Patrick Lessard, Investment Trader & Associates,

72. The shares obtained by the companies mentioned prerequisites are. TRANSFERRED
• more related persons, namely Denyse Raynault, Jean-Sebastien Ollu, Marc
Ollu Alexandre, Marie-Chiristine Ollu, Xavier DeMontigny, Magma Drilling inc. Michel
Lebeuf and Salvatore Brunetti.

73. The analysis of stock trading in the reports MICA reveals that many of these people compromise on the title of EGM.



74. Yannick Lessard, one of the people involved in this scheme, sent emails which demonstrate his knowledge of the scheme:

- An email from Yannick Lessard saying he is now a millionaire reterant its investment in EGM. He mentions that EGM is going to $ 0.08 to $ 0.36

- An email from an investor Yannick Lessard indicating that this half "this stock will explode" and that, in reference to EGM.

- An email from Yannick Lessard investors stating that he has been wronged by "Serge and Ollu Cortellazzi for EGM, but he does not plan to take aggressive action because it is aware of a plan back to EGM.

75. January 20, 2011, investigators have questioned Serge I'Autorite Ollu. The latter mentions the following:

- Daniel Ryan makes Ia stock manipulation by sending millions of emails to Manter the "stock".

- Jean-Fran9ois Amyot is Ia same thing that Daniel Ryan. II parte I never n-Fran9ois Amyot. He has met Daniel Ryan once or twice when he worked on with Michael Peel Ia DeMontigny.

- Castellane Capital inc. Which is contr61ee 'by Serge Ollu, sold a mining re9u EGM and in return shares of EGM. These mining claims came from Andrea Cortellazzi.

- Serge Ollu Ia negotiated sale of mining rights with Michel DeMontigny and then President in EGM or Martin Harvey.


- Following a sale of these securities Ia mining Ia from Capital Castellane, Michel DeMontigny a request Serge Ollu to transfer shares held by EGM Capital Castellane several individuals.

- Serge Ollu agreed to transfer the shares he had sold Ia re9ues a result of mining as it re9u all kinds of pressure.

- Serge Ollu transferred its shares in EGM Michel Lebeuf because Andrea Cortellazzi owed him legal fees. Michel Lebeuf a request to transfer Ollu Serge in his own name.

- • Michel DeMontigny also asked Serge Ollu to transfer shares of EGM
a son, Xavier DeMontigny, a Magma Drilling eta Salvatore Brunetti.

- Salvatore Brunetti works with the offices of DeMontigny Ia Peel Street.

- Serge Ollu has given his actions of Ia EGM for peace.



76. September 30, 2010, a I'Autorite re9u a claim of the investor 5, against a
Yannick Lessard.

77. Investors blame a 5 Yannick Lessard for having brought him to invest $ 40 000 and complained of his inability to repay.

78. Among the elements in support of its complaint, the investor has delivered five I'Autorite phone records of conversations he had with Yannick Lessard and email exchanges with him.

79. These records tE Iephoniques took place on July 2, 2010, September 8, 2010,
September 16, 2010 and September 20, 2010.

80. These telephone conversations show the following:

- Yannick Lessard mentioned that care ab developers to decree the volume and Ia after selling shares in order to pay it back.

- The promoters are paid in shares and the latter being unable to get the levee Ia Ia escrow period linked to the actions of U-Mining, they can not begin Ia promotion.

- The services of lawyers are selected to obtain levee Ia Ia period of escrow shares.

- Serge Ollu reussiIa a promotion on HE-5.

- After Ia promoting ET-5, it was planned to start the U-Mining.


- Yannick Lessard witnessed eta Benetice promotion of EGM when he was in office Cortellazzi. The price! Action rose from $ 0.08 to $ 0.40. It has a
$ 35 000 profit in two weeks.

Yannick Lessard Ia evaluates possibility of going to notify the authorities and all those involved.

- Yannick Lessard has participated in! "Operation on Ia promotion of EGM and it re9u
2 million shares for help • the financing of this operation.

- Yannick Lessard says he could not know qu'EGM, which is listed on
TSX, was making a shell I'objet fraud. E. Another element
81. In December 2008, I'Equipe INTEGRATED Ia Market Enforcement (the after
"ElPMF") began a criminal investigation named "Project Crossroads."

82. The investigation of a particular demonstrates I'EIPMF! Existence of tm market manipulation scheme in which Gerald Parkin was involved.




83. Gerald Parkin e t Monimpex president of International Ltd., A company with a mandate to assist companies so that they are side by Ia scholarship. .


84. On December 7, 2009, the Bureau delivered a block, a cease trade order, a ban has to act as adviser and a measure to
ensure compliance with Ia Act in respect of several people including Gerald Parkin and M? nimpex International Ltd. •

85. The Authority has taken the servant of the survey project on Carrefour and Gerald Parkin
Monimpex International Ltd. and is investigating about ace.

86. As part of this investigation, an investigator I'Autorite seized under a search warrant, several documents that had I'EIPMF itself seized • under a search warrant under of the criminal investigation of Project Crossroads.

87. However, analysis of documents seized by I'Autorite demonstrate links between particular
Gerald Parkin I Monimpex International Ltd., Jean-Fran ois Amyot and Daniel Ryan.

88. These documents indicate that Mr. Parkin • working in collaboration with Jean-Fran ois Daniel Amyot and Ryan to find dormant companies, or "shells" in order to take stock of Ia and Ia after Ia to promote these companies. Mr Parkin was paid in shares of companies he led to be listed on stock exchange Ia.

F. Conclusions

89. Testimony and evidence gathered through the investigation of
I'Autorite SHOW Ia presence of a network that has developed a scheme to
manipulate the securities of companies Wanderport, Neuro-Biotech and EGM.

90. More precisely, they use a network of associates and brokerage accounts to deal in securities of companies whose securities are artificially manipulated to create a volume tra'nsactionnel. .

91. Simultaneously, the promoters of services such as equities LAB Hilbroy Downshire and are held to promote the titles of the company with potential investors.

92. The evidence indicates that the following individuals are or were involved in this scheme:

- Michel DeMontigny
Jean-Fran9ois Amyot
- Serge Ollu
- Andrea Cortellazzi
- Yannick Lessard
- Dominic Gingras
- Jean-Sebastien Ollu
- Denyse Raynault
- Jacques Vallee
- Patrick Gagne



- Stephane Frechette
Daniel Ryan
- Carol McKeown
Andrew Barakett
- Martin Harvey
Patrick Lessard
- Nicolas Matossian
- Daniel Pauze

93. Finally, his proof has revefe egafement Andrea Cortelfazzi recueilfi money from investors by promising them quebecois shares of both companies, Exen; f'activite ant and a dealer without registration.


Ill ORDERS SOUGHT

94. A manure heaps fa aforementioned facts, f'Autorite has reasonable and probable grounds to believe that his intimate participation in various capacities, has activities
Organized fa handling during different titles and they take advantage of these organized activities, to the detriment of investors.


95. These unfair and abusive acts including causing harm to investors who had previous operations on his shares based on news releases fa
release or the recommandationcontenues on websites owned by LAB.

96. These acts also unfair and abusive cause injury to stock markets • Canadian and U.S. as they call into question their integrity and destroy his confidence of investors as a whole.

97. The Authority requests done for Ia Protection Fund, Martha and the integrity of. F'interet in public office pronounces that fe Jes restraining orders sought in blocking and F herein.

98. Take also the Authority requests \ 3nt, for his protection of investors and! The public interest, that fe Bureau issued orders to close his Internet sites held by JAB.

99. Moreover, if is necessary, for his protection of investors and the public, that his decision the Office decides, on ant fa present application is filed at the Registry of F Superior Court District Monfrea_l.

100. The Authority has reasonable and probable grounds that his activities are continuing in the intimate date hereof.

101. Without an immediate decision of the Bureau, if is a fear, among other things, Jes respondents' activities continue to the detriment of! All investors.


102. If Ia is done for urgent protection of the public works that the e_t f'integrite fe Burea u • makes its decision without a prior hearing, in accordance with! Section 115.9 of F LAMF.




ACCORDINGLY, Ia plaintiff requested that the Office decision and reconsideration under section 93, 94 and 115.9 and 115.12 of Ia Act respecting the Autorité des marches financiers, RSQ, c. A-33.2, articles 249, 265, 266 of Act Ia / es mobilieresLR.Q values., C.
V-1.1, and! Article 16 of the Rules / es of the Bureau of decision procedures and
revision, c. V-1.1, R.0.1.3

Claim for the imposition of prohibition orders

To prohibit all the values ??of Excel Gold Mining, Neuro-Biotech inc., Wanderport Corp.;

To prohibit intimate Excel Gold Mining, Neuro-Biotech inc., Wanderport
Corp., 9157-0945 Quebec inc. (Doing business as Investment Traders
. & Associates inc.) IAB Media inc., Tips Hilbroy inc., Castellane Capital inc., Proactive Computer Services, 9198-6208 Quebec inc., 935063 Alberta ltd.
6570542 Canada inc., Jecemar lmmobilier inc. Jean-Fran <; ois Amyot, Andrea
Cortellazzi, Serge Ollu, Andrew Barakett, Michel DeMontigny, Dominic Gingras, Martin Harvey, Yannick Lessard Patrick Lessard, Nicolas Matossian, Daniel Pauze, Patrick Gagne, Michael D'Amico, Jacques Vallee, Stephane Frechette and Jean-Sebastien Ollu any activity to effect any transaction in securities;

To prohibit intimate Magma Drilling, Xavier DeMontigny, Salvatore Brunetti, Michel Lebeuf, Marc-Andre Ollu, Marie-Christine Ollu and Denyse Raynault any activity to carry out any transaction in securities in the securities of Excel Gold Mining;

To prohibit intimate IAB Media inc., Tips Hilbroy inc., Jean-Fran <; ois
Amyot to carry on business as defined in conseillertelle! Article 5 of Ia LVM;

The making of claims for restraint order

To order lnvestDirect HSBC, does dispose of funds, securities or other property on deposit or she has doht Ia custody or control on behalf or on behalf of Daniel Pauze, particularly in the following account:
6Y67F9E;

To order BMO Nesbitt Burns, not to dispose of funds, securities or other property, it has on deposit or under its custody or Ia • control behalf or on behalf of Daniel Pauze and Martin Harvey, particularly in the following accounts: 3351622620 and 3352345627;

To order CIBC WoodGundy, not to dispose of funds, securities or other property, it has on deposit or under its custody or control of Ia in the name or account I 935063 Alberta Ltd. and Nicholas Matossian, including in the following account: 3103496026;

To order BMO, not to dispose of funds, securities or other property, it has on deposit or under its custody or control his behalf or on behalf of Jean-Sebastien Ollu, Dominique Gingras ET_ Patrick Lessard n <,> larly in the following accounts: 2206183614, 2161352113,



2160264814, 2154853218, 2153304718, 2153246513, 2151353410,
2146444514 and 2154902114;

To order National Bank Financial, not to dispose of funds, securities or other property, it has on deposit or under its custody or control of Ia in the name or lecompte of 9157-0945 Quebec inc. Traders and Investment or Dominique_ Gingras & Associates, including the following account:
1B8BK5A;

TO ORDER Desjardins Securities inc., Not to dispose of shares of Excel Gold Mining, it has on deposit or under its custody or control of Ia in the name or lecompte Xavier DeMontigny, especially in the following account: 64ATDA3;

To order lndustry) the Alliance securities, not to dispose of shares of Excel Gold Mining it has on deposit or under its custody or control of Ia behalf or on behalf of Magma Drilling, especially in the following account: 3EW686A; •

To order Canaccord Genuity, not to dispose of shares of Excel Gold Mining it has on deposit or under its custody or control of Ia behalf or on behalf of Michel Lebeuf, particularly in the following account : 58F857A1;

To order RBC Direct Investing Inc.., Not to dispose of shares of Excel Gold Mining it has on deposit or under its Ia gan;: fe or control on behalf or on behalf of Mary- Christine Ollu and Salvatore Brunetti, especially in the following accounts: 6873224114 and 6824468315;

To order TD Waterhouse Canada Inc.., De.ne not dispose of shares of Excel Gold Mining it has on deposit or under its custody or control of Ia behalf or on behalf of Marc-Alexandre Ollu, particularly in the following account: 577852A;:



Other findings

DECLARE under! Section 115.9 of Act Ia / Markets Authority Ia financial decision of the Bureau of decision and revision comes into force without a prior hearing and give the parties! Opportunity to be heard within a period of fifteen (15) days;


Direct the respondents IAB Media inc., Tips Hilbroy inc. and Jean Fran ois Amyot PROCEEDING Ia closed following websites:

- LtsallbuiLnet
- Pennystockryder.com
- Hypergrowthstock.com
- Stockpicksthatmove.net
Simonsaysstocks.net
- Pennystocksociety.net



- Pennystockparty.net

within a period of 24 hours of service of F Ia Ia decision to intervene on this application;


TO AUTHORIZE, if any fe, fe depot in the office of Ia Superior Court District of Montreal Ia inteNenir a decision;

TO AUTHORIZE fa significance of Ia decision to be rendered in this case close to Neuro-Biotech Inc. and Wanderport Corp. through a press release posted on the website of I'Autorite of financial markets.

TO AUTHORIZE Ia Ia meaning of decision to be rendered in this case the defendants. through a meaning! attention of the persons mentioned in Table A, and the address on the same
table.









GIRA TAL.
Attorneys I'Autorite of financial markets














revision

-... ... .. -.. • ..:... .'.;)....




AFFIDAVIT




I, David Gallant, exercisable at 800 Victoria Square, 2nd floor, in Ia City and the District of Montreal, solemnly affirm that:

- I I'Autorite investigator of financial markets.

I am the investigator assigned to this case.

Tousle facts alleged in this application is true Ia.





IN WITNESS WHEREOF, I have signed in Montreal, June 29, 2011.
II: • • •
- .. /. I, / r Vl f vV
David Gallaht







Affirmed before me a

Montreal, June 29, 2011.







Commissioner of Oaths in.




by -
Office of
revision