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Huggy Bear

04/07/15 12:20 AM

#38434 RE: Cassandra #38418

In addition to obvious accounting fraud in the SEC-filed financial statement, the abuse of the Section 3(a)(10) exemption is an extremely serious infraction which could result in SEC enforcement action(s).



I am fairly certain this is one of the main reason why the 10-Q's have ceased to be filed, the inability to reckon these debts according to GAAP regulations.

I am also thinking that shares have indeed been issued at some unknown "floor price" in accordance with the provisions allowed within a legitimate Section 3 (a)(10) exemption - Problem being this does not qualify as bona fide debt already owed in a most cursory review of actual business practices.

Vencedor has billed for 867K and drilled zero wells according to ancillary evidence that CPN notes paid for that in reality. If memory serves me correct all the Rice leases expire this month.

Why should the public pay for wells not drilled and on top of that expiring leases to drill with the dilution resulting from the issuance of unregistered shares?

The pre-paying for services and the CEO back pay requested before he became CEO, well these are all very creative constructions of what qualifies for a Section 3(a)(10) exemption. I would like to see them all translated into a 10-Q filing.