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Dubb10

12/31/14 6:33 PM

#36541 RE: Raphael De La Ghetto #36540

Sorry, I made a mistake. It happened between 2008 and 2010, not 2005 and 2010.

Dubb10

12/31/14 8:53 PM

#36542 RE: Raphael De La Ghetto #36540

Best part is on page 13 where the SEC states a VIPR officer signed TJM's term sheet and a subscription agreement 31 times. JC Barbeck and/or John Riccio had to sign off on these agreements. According to the chart, the first offering was on 5/20/09, and the first resale was on 5/22/09. We need to see the details of these agreements. Could be made available via the FOIA eventually. Might be where investors can pay JC back if SEC wins this thing.