Did Heathrow ever really exist before it was created to provide cover to complete his distribution of over 5 billion shares to himself and others?
Pagnano and a business partner owned/controlled the private Heathrow and agreed to be acquired by Pagnano's publicly-traded company.
The SEC should look even further back to the World Golf League and the memberships for shares deals where his partner got tons of shares for memberships supposedly sold. I'm not sure any of the memberships were actually "sold" to real persons. When the shares were then sold into the market, I wonder who split the proceeds and was some of this money used to represent "sales"?
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