46. The trust agreement and other trust documentation was filed with DS as part of the “Know Your Client” documents with respect to 1683091 Trust’s account at DS. The DS trust account initially held 6,000 shares of John Bordynuik Inc.. In or about October 2009 an additional share certificate representing 1 million shares was deposited to the trust account at DS.
47. Immediately thereafter, on or about October 23, 2009, Bordynuik caused the shares represented by these certificates to be transferred to fourteen different transferees, none of whom were beneficiaries of the trust.