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Replies to post #50840 on Quantum Materials Corp. (fka QTMM)
08/16/16 11:46 AM
08/16/16 12:55 PM
scion Member Level Friday, 02/20/04 04:36:17 PM
Re: scion post# 56
Post # of 2287
IN RESPONSE TO A PRESS RELEASE BY US GLOBAL LET US MAKE THIS PERFECTLY CLEAR
THIS COMPLAINT WAS FILED BY OUR-STREET.COM WITH THE SEC
WE HAVE NEVER SUGGESTED OTHERWISE AND ANY INDIVIDUAL CAPABLE OF READING CAN SEE THAT FROM OUR PRESS RELEASES, OUR TEXT AND THIS COMPLAINT ITSELF.
http://www.our-street.com/usga_sec.htm
COMPLAINT
Complainant reports that we believe that US Global Nanospace, Inc. (OTC-BBUSGA) has demonstrated a consistent and ongoing practice of issuing false and/or misleading press releases and of including false and/or misleading statements in filings with the Securities and Exchange Commission.
SUMMARY
1. This complaint arises out of what we believe are materially false and/or misleading public statements and omissions made by US Global, John Robinson and Stephen Squires. The false or misleading statements and omissions were made in 2002 and 2003 and related to, among other things, the company’s progress in obtaining certain certifications, contracts and orders the company claimed to have obtained.
2. Beginning in 2002, in press releases and on the Internet, we believe US Global, Robinson and Squires made materially false statements in press releases, in interviews and on the internet in order to promote their stock. We believe Robinson made or approved each statement, and he knew or was reckless in not knowing that these statements were materially false and/or misleading.
3. In 2002 and 2003, we believe Robinson omitted to state material facts in press releases and filings with the SEC that were necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading. We believe Robinson knew or was reckless in not knowing that the material omissions were necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading.
4. By engaging in the conduct alleged herein, the accused appear to have violated the antifraud, periodic
reporting, and registration requirements of the federal securities laws. Unless enjoined, ew believe the
accused are likely to do so in the future.
JURISDICTION AND VENUE
5. It is requested that the Commission bring an action pursuant to Section 20(b) of the Securities Act of 1933 ("Securities Act") [15 U.S.C. § 77t(b)], and Sections 21(d) and 21(e) of the Securities Exchange Act of 1934 ("Exchange Act") [15 U.S.C. §§ 78u(d) and 78u(e)] to permanently restrain and enjoin US Global, Robinson and Squires from engaging in the acts, practices, and transactions stated herein.
6. The Court has jurisdiction over this action pursuant to Section 22(a) of the Securities Act [15 U.S.C. § 77v(a)], and Sections 21(d), 21(e), and 27 of the Exchange Act [15 U.S.C. §§ 78u(d), 78u(e), and 78aa]. Venue lies in the Court pursuant to Section 20(a) of the Securities Act [15 U.S.C. § 77t], and Section 27 of the Exchange Act [15 U.S.C. § 78aa].
7. US Global, Robinson and Squires, directly or indirectly, have made use of the means and instrumentalities of interstate commerce or the mails, or of the means or instrumentalities of transportation or communication in interstate commerce, or of the facilities of a national securities exchange, in connection with the acts, practices, and transactions alleged herein, certain of which occurred within the state of Texas.
THE ACCUSED
8. US Global Holdings, Inc. On November 4, 1992, Caring Products International, Inc. was incorporated
under the laws of the state of Delaware. On December 30, 1993, Caring Products merged with and into
FWCC Merger Corp., and FWCC Merger Corp. became the surviving corporation. The name of the surviving
entity was changed to Caring Products International, Inc. On September 26, 2002, Caring Products
International, Inc. changed its name to US Global Aerospace, Inc. On May 29, 2003, the Board of Directors
and the majority stockholder consented to amend the company’s Certificate of Incorporation to change the
name to US Global Nanospace, Inc.
9. John Robinson, Chief Executive Officer, Chairman of the Board of Directors. Mr. Robinson became a
director and our Chief Executive Officer inconjunction with the share exchange that took place with USDR
Global Aerospace, Ltd. on May 17, 2002
10. Stephen Squires – aka S. Brad Squires is the Chief Technology Officer of US Global. He has additionally
claimed the title of Vice Chairman of the company as well.
FACTS
A. Background
11. Through a series of acquisitions in 2002 of USDR Global Aerospace, Ltd., a Delaware corporation,
control of Caring Products was transferred to John Robinson. Robinson then began issuing press releases
and published a website related to the company’s new business ventures. We believe, some of these
releases and parts of the website contained materially false and/or misleading statements or contained
material omissions that were necessary in order to make the statements made, in light of the circumstances
under which they were made, not misleading.
12. We also believe Robinson included materially false and/or misleading information in their SEC filings and,
at the same time, made material omissions that were necessary in order to make the statements made, in
light of the circumstances under which they were made, not misleading. These statements include claims
regarding business relationships with major companies that we believe are either entirely false or significantly
misrepresented. We further believe these materially false and/or misleading statements and material
omissions were included in order to create a false impression of the company and its current business
situation.
B. False or Misleading Statements and Omissions by the Company or its officers or directors
NOTE: WE HAVE BEEN PROVIDED WITH THE EUROPEAN PATENT INFORMATION AND PROVIDE THE LINK HERE. PATENT INFORMATION
ACCORDINGLY WE HAVE REMOVED PARAGRAPH #13 & 14
WE APOLOGIZE FOR ANY INCONVENIENCE THIS HAS CAUSED.
THE REMAINDER OF THE COMPLAINT REMAINS AS WRITTEN.
15a. On September 11, 2002 US Global, (then Caring Products International Inc) and Robinson announced that their “wholly owned subsidiary USDR Global Aerospace, Ltd. and Globus Aviation 2001 Ltd. concluded an agreement with El-Al Israel Airlines to install USDRGA's patent-pending Guardian(TM) Anti-Ballistic Panel Cockpit Security Door on El-Al's 747-200B aircraft.”
15b. On April 25, 2003, US Global and Robinson issued a statement claiming that “it has received new orders totaling $1,440,500 for 38 of the Company's Guardian™ Cockpit Security doors. The new orders include doors for El Al Israel Airlines' Boeing 737, 747, 757 and 767 fleets.”
15c. On March 4, 2003, Squires was quoted by the Reno Gazette as claming “We have 200 firm orders from existing airlines, inside and outside the U.S., including (Israel’s) El Al Airlines,” he said. “That will grow substantially now that the rest of the carriers can see the time savings.”
15d. We believe these statements were materially false and/or misleading based upon the following facts.
15e. On July 11, 2003 US Global and Robinson filed a Form 10K with the SEC claiming that “In April 2003 El Al Israel Airlines, while it was under the control of the government of Israel, submitted an order to USGA for the purchase of Guardian Doors for its fleet of aircraft. Since that time, however, the airline has been privatized. Currently we are unsure whether the change in ownership will have any effect on the purchase of the doors.”
15f. On July 14, 2003, Robinson and US Global published a statement regarding the El Al sale claiming that “Since then, the airline has been privatized and although the airline has indicated that they will honor their commitment to buy the Guardian doors, US Global is unsure whether the change in ownership will have any effect on the purchase of the doors due to El Al management changes.”
15g. On October 2, 2003, Robinson and US Global published a statement disclosing that “the company is continuing discussions with El Al to determine the best way to utilize the Guardian door in their cockpit security program while concurrently fulfilling FAA certification requirements while adhering to the very high Israeli Aviation Authority requirements”
15h. On June 13, 2003, the Jewish Bulletin of Northern California published an article stating that “Government officials said they were pleased with the results of the first stage of El Al's privatization Tuesday, while analysts called the flotation a failure. The government raised $17 million from the sale of from 15 to 24 percent of El Al's shares on the Tel Aviv Stock Exchange. It is unclear how many of El Al's workers bought shares. El Al will remain government-controlled for at least another year.”
15i. On June 2, 2002 Ganden Security Services published an article from “Aviation Week on Homeland Security & Defense Aviation” stating that “El Al cockpits have a heavily secured two-door system that allows pilots to enter the cabin while preventing unauthorized access to the cockpit.”
15j. Based upon these facts, we believe that the statements by US Global, Robinson and Squires were either materially false and/or misleading or contained material omissions that were necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading.
16a. On April 25, 2003 Robinson and US Global announced that “it has received new orders totaling $1,440,500 for 38 of the Company's Guardian(TM) Cockpit Security doors. The new orders include doors for El Al Israel Airlines' Boeing 737, 747, 757 and 767 fleets, and Aer Lingus' Airbus A320 and Boeing 737 fleets.”
16b. We believe this statement is materially false and/or misleading or may contain material omissions that were necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading based upon the following facts.
16c. On April 26, 2003, AER Lingus published the following announcement. “AER Lingus has fitted reinforced cockpit doors to all its planes used for transatlantic flights in the wake of the September 11 terrorist attacks. International regulations stipulate that all airlines install reinforced cockpit doors to prevent unauthorised access to the cockpit by November 2003. The State airline confirmed that it had introduced the reinforced cockpit doors on its seven transatlantic A330 airbuses. The company is now in the process of examining options for the introduction of the doors on all short haul flights. There are 32 planes in the Aer Lingus fleet.”
16d. We believe US Global and Robinson knew or were reckless in not knowing that the statement was materially false and/or misleading or contained material omissions that were necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading based upon the following facts. It should also be noted that the press release as published for that date on the US Global website has been edited from the original announcement released over the wires to remove any mention of Aer Lingus.
17a. On March 4, 2003, Squires was quoted by the Reno Gazette as claming “We have 200 firm orders from existing airlines, inside and outside the U.S., including (Israel’s) El Al Airlines,” he said. “That will grow substantially now that the rest of the carriers can see the time savings.”
17b. We believe this statement is materially false and/or misleading based upon the following facts.
17c. On July 11, 2003, US Global and Robinson filed a Form 10K with the SEC claiming that “We believe
that the major original equipment manufacturers (OEMs) in the aircraft industry have such
overwhelming resources and influence in the marketplace that it will be difficult or impossible for
us to gain entry, even though we believe that the Guardian Door is the best product available.”
17d. In subsequent filings of the company’s 10Q’s on September 10, 2003 and November 14, 2003, there is no mention of any orders, firm or tentative for the purchase of the Guardian anti-ballistic cockpit door.
17e. On December 9, 2003, US Global and Robinson published a Corporate Update and did not even list the Guardian Anti-Ballistic Cockpit Security door as a primary product. In fact the update didn’t even mention the Guardian door at all.
17f. Based upon these facts, we believe Squires knew or was reckless in not knowing that the statement was materially false and/or misleading.
18a. On October 29, 2002, US Global and Robinson published a statement announcing “its acquisition of the Nanosil™treatment technology through an exclusive license agreement with Moose River Consulting, Inc. Nanosil™ is a proprietary super hydrophobic surface modification process that produces surfaces that are designed to repel water completely." Robinson and US Global went on to claim that “USGA believes the market potential for the Nanosil(TM) process will be in excess of $50 million per year.”
18b. We believe this statement was materially false and/or misleading or contained material omissions that were necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading based upon the following facts.
18c. The only other mention of Moose River Consulting and/or the Nanosil super hydrophobic process is in the company’s November 19, 2002 Form 10Q. No other mention of this acquisition exists in company filings, its product descriptions. Further, aside from the press release, no other mention of Moose River Consulting or the Nanosil technology exists elsewhere on the internet based upon the work of approximately 24 search engines.
18d. Based upon these facts, we believe the Robinson knew or was reckless in not knowing that the announcement of October 29, 2002 was materially false and/or misleading or contained material omissions that were necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading.
19a. On March 3, 2003, the Reno Gazette published an article based upon an interview with Stephen Squires. In that interview Squires is described as US Global’s “Vice Chairman”. A reasonable man would conclude this to mean that Squires was a member of the Board of Directors of US Global.
19b. On May 11, 2003, the Nanobusiness Alliance held a conference and introduced Squires as “Stephen Squires, Vice Chairman, US Global Aerospace”.
19c. We believe this statement is materially false and/or misleading based upon the following facts.
19d. No US Global filings with the SEC list squires as a director of the company.
19e. All other publications and press releases refer to Squires as the company’s Chief Technology Officer.
19f. We believe Squires knew or was reckless in not knowing that his claim to be the company’s Vice Chairman was materially false and/or misleading.
20a. On March 3, 2003, the Reno Gazette reported that Squires claimed that “About 50 of the Carson City-based company’s nearly 500 employees are involved in this program. The Reno Gazette also reported that “We hope for 2003 to have 5 percent market in the U.S. and 10 percent of the world share,” the executive said. “That’s $56 million in revenues — and we think that’s conservative.” Also according to the Reno Gazette, “US Global Aerospace Inc.’s previous work was mostly classified, “so you wouldn’t see a lot about us,” said Vice Chairman Steve Squires.
20b. We believe this statement is materially false and/or misleading based upon the following facts.
20c. On July 11, 2003 US Global and Robinson filed a Form 10K with the SEC for the year ending March 31,
2003 and disclosed that “We currently have 11 full-time employees. Depending on the project, we
also retain the services of between 12 and 15 consultants.”
20d. Evidence submitted in paragraphs 17 through 19 above disputes the existence of 200 firm orders and also suggest the likelihood that management knew or was reckless in not knowing that projecting $56 Million in revenues for the subsequent 9 months with no income at all since the company’s origination was not only not conservative but highly improbable.
20e. On July 11, 2003 US Global filed its Form 10K with the SEC and disclosed that, prior to acquiring US
Global Aeronatics, Ltd. along with the rights to the Guardian Door, “As Caring Products International,
Inc., USGA and its subsidiaries
designed a line of proprietary urinary incontinence products with disposable liners that were sold
under the Rejoice brand name in the U.S., Canada and Europe.” A reasonable person would not
conclude that the design and marketing of incontinence products constitutes classified work.
20f. We believe that Squires knew or was reckless in not knowing that each of those statements was materially false and/or misleading.
C. False and/or misleading statements or material omissions made in filings with the SEC
NOTE: WE HAVE BEEN PROVIDED WITH THE EUROPEAN PATENT INFORMATION AND PROVIDE THE LINK HERE. PATENT INFORMATION
ACCORDINGLY WE HAVE REMOVED PARAGRAPH #21
WE APOLOGIZE FOR ANY INCONVENIENCE THIS HAS CAUSED.
THE REMAINDER OF THE COMPLAINT REMAINS AS WRITTEN.
22a. On July 11, 2003, US Global and Robinson filed a Form 10K with the SEC and disclosed that “In April
2003 El Al Israel Airlines, while it was under the control of the government of Israel, submitted an
order to USGA for the purchase of Guardian Doors for its fleet of aircraft. Since that time, however,
the airline has been privatized. Currently we are unsure whether the change in ownership will
have any effect on the purchase of the doors. In April 2003 we also received a purchase order
from Aer Lingus, the national airline of Ireland, for Guardian Doors. Shortly after we received the
purchase order, Aer Lingus notified us that it intended to award the contract for the cockpit doors
to Airbus.”
22b. We believe this statement is materially false and/or misleading or contained material omissions that were necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading based upon the following facts.
22c. Based upon evidence brought forth in paragraphs 17 through 19 above supports our belief that Aer
Lingus already had ordered its international cockpit doors from another supplier and that it had not made
any determination regarding the rest of its fleet. If further suggest that El Al already had installed
anti-ballistic security doors on its entire fleet of aircraft prior to the announcement by US Global of its
“firm” sale. The subsequent backpeddling and eventual disappearance of these “firm” orders from company
disclosures would lead a reasonable person to conclude that these statements were materially false and/or
misleading or contained material omissions that were necessary in order to make the statements made, in
light of the circumstances under which they were made, not misleading.
22d. We believe Robinson knew or was reckless in not knowing that this disclosure was materially false
and/or misleading or contained material omissions that were necessary in order to make the statements
made, in light of the circumstances under which they were made, not misleading.
D. Sales of Company stock by Officers, Directors and Executives of the company
23a. On July 18, 2003, US Global and John Robinson as controlling shareholder of the company granted
860,343 shares of common stock under the 2002 Stock Plan to employees in lieu of salaries and expenses
with an award valuation of $344,147, equaling 100% of the fair market value per share on the date of
grant of the award. This equals a value of $.40 per share which was the closing price on July 18, 2003.
23b. On July 25, 2003, John Robinson as controlling shareholder of the company granted himself 1,000,000
shares of common stock under the
2002 Stock Plan with an award valuation of $250,000, which was also claimed to be the fair market value
per share on the date of grant of the award. This equals a value of $.25 per share. The closing price on
July 25, 2003, however was $.335 a price. Accordingly, Mr. Robinson appears to have awarded himself his
shares at a discount of 24.4% below the closing price on the stock.
23c. Based upon S8 filings Robinson sold approximately 80,468 shares between July 25, 2003 and October
8, 2003, prior to the stock experiencing a significant move upward in price. Between October 9, 2003 and
December 22, 2003, he sold another 411,238 shares. During this time the stock experienced a significant
increase in volume and share price moving significantly beginning November 14, 2003 from a closing price
of $.23 on October 8, 2003 to a high of $1.39 and closing on December 22 at $1.14. On December 22,
2003, Robinson re-registered the remaining 508,283 of his 1,000,000 shares on another Form S8.
23d. On January 15, 2004, Stephen B. Squires, aka S. Brad Squires filed a form 144 with the SEC to sell
204,000 shares of his US Global stock. On January 15, 2003 the stock price opened at $1.69 and moved up
to $1.71 before selling drove the stock down to a close at $1.57. The following day, an the volume doubled
from the previous due to the heavy selling and the stock fell to a low of $1.42. Based upon the closing
price of the stock on January 14, 2003, Mr. Squires the stock Mr. Squires registered was valued at $344,760.
23e. Our-Street.com estimates that the gross proceeds realized by Robinson and Squires from the sale of
their stock, assuming Robinson has sold the remaining 508,283 shares of his stock, would equal well in
excess of $1,000,000.
FIRST CLAIM
We believe US Global, Robinson and Squires Violated Section 10(b) of the Exchange Act and Exchange Act Rule 10b-5
(Materially False and Misleading Statements and Failure to Disclose Material Facts in Connection with the Purchase or Sale of Securities)
24. Paragraphs 1 through and 22 above are re-alleged and incorporated herein by reference.
25. During 2002 and 2003, we believe US Global made materially false and misleading statements, and/or omitted to state material facts in press releases and on the Internet and in SEC filings relating to, among other things their sales. US Global knew, or was reckless in not knowing, that the statements were materially false or misleading, and that the omissions were material.
26. In 2002 and 2003, we believe Robinson and Squires made materially false and misleading statements, and/or omitted to state material facts in press releases and on the Internet and in SEC filings relating to, among other things their sales. Robinson and Squires knew, or were reckless in not knowing, that the statements were materially false or misleading, and that the omissions were material.
27. We believe US Global, Robinson and Squires, directly or indirectly, singly or in concert with others, in connection with the purchase or sale of securities, and by use of the means or instrumentalities of interstate commerce or by use of the mails, or by use of any facility of any national securities exchange: (a) employed devices, schemes or artifices to defraud; (b) made untrue statements of material facts or omitted to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and/or (c) engaged in acts, practices or courses of business which operated or would operate as a fraud or deceit upon any person.
28. By reason of the foregoing, we believe US Global, Robinson and Squires have, directly or indirectly, singly or in concert, violated Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5].
SECOND CLAIM
We believe US Global, Robinson and Squires Violated Section 17(a) of the Securities Act
(Making Materially False and Misleading Statements and Failing to Disclose Material Facts in the Offer or Sale of Securities)
28. Paragraphs 1 through 22 above are re-alleged and incorporated herein by reference.
29. During 2003, we believe US Global made materially false and misleading statements, and/or omitted to state material facts in press releases and on the Internet and in SEC filings relating to, among other things their sales. US Global knew, or was reckless in not knowing, that the statements were materially false or misleading, and that the omissions were material.
30. In 2003, we believe Robinson and Squires made materially false and misleading statements, and/or omitted to state material facts in press releases and on the Internet and in SEC filings relating to, among other things their sales. We believe Robinson and Squires knew, or were reckless in not knowing, that the statements were materially false or misleading, and that the omissions were material.
31. We believe US Global, Robinson and Squires, directly or indirectly, singly or in concert with others, in connection with the purchase or sale of securities, and by use of the means or instrumentalities of interstate commerce or by use of the mails, or by use of any facility of any national securities exchange: (a) employed devices, schemes or artifices to defraud; (b) made untrue statements of material facts or omitted to state material facts necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; and/or (c) engaged in acts, practices or courses of business which operated or would operate as a fraud or deceit upon any person.
32. By reason of the foregoing, we believe US Global, Robinson and Squires violated Section 17(a) of the Securities Act [15 U.S.C. §78q(a)].
THIRD CLAIM
We believe US Global Violated Section 13(a) of the Exchange Act and Exchange Act Rules 13a-1, 13a-13, and 12b-20
(Materially False and Misleading Statements, and Omissions of Material Fact, in Filings with the Commission)
33. Paragraphs 1 through 12 and 21 through 22 above are re-alleged and incorporated herein by reference.
34. On July 11, 2003, US Global filed with the Commission its Form 10K with the SEC. In this filing, we believe US Global made false and/or misleading statements of material fact, or omissions of material fact, regarding their true sales. We believe Robinson knew, should have known, or was reckless in not knowing that the statements were materially false and/or misleading, and/or that the omissions were material.
35. Section 13(a) of the Exchange Act [15 U.S.C. §78m(a)] and Exchange Act Rules 13a-1, 13a-13, and 12b-20, [17 C.F.R. §§ 240.13a-1, 240.13a-13, and 240.12b-20] require that quarterly, annual and other reports and statements filed by issuers with the Commission not contain untrue statements of material facts or omissions of material facts.
36. By reason of the foregoing, we believe US Global violated Section 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Exchange Act Rules 13a-1, 13a-13, and 12b-20 [17 C.F.R. §§ 240.13a-1, 240.13a-13, and 240.12b-20].
FOURTH CLAIM
We believe Robinson Aided and Abetted US Global’s Violations of Section 13(a) of the Exchange Act and Exchange Act Rules 13a-1, 13a-13, and 12b-20
(Aiding and Abetting Materially False and Misleading Statements, and Omissions of Material Fact, in Filings with the Commission)
37. Paragraphs 1 through 12 and 21 through 22 above are re-alleged and incorporated herein by reference.
38. On July 11, 2003, US Global filed with the Commission its Form 10K with the SEC. In this filing, we believe US Global made false and/or misleading statements of material fact, or omissions of material fact, regarding their true sales. We believe Robinson knew, should have known, or was reckless in not knowing that the statements were materially false and/or misleading, and/or that the omissions were material.
39. By reason of the foregoing, and pursuant to Section 20(e) of the Exchange Act [15 U.S.C. § 78t(e)], we believe Robinson is liable as an aider and abettor of US Global’s violations of Section 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Exchange Act Rules 13a-1, 13a-13, and 12b-20 [17 C.F.R. §§ 240.13a-1, 240.13a-13, and 240.12b-20].
PRAYER FOR RELIEF
WHEREFORE, the complainant respectfully requests that the SEC halt trading of US Global Nanospace, Inc. stock pursuant Section 12(k) of the Exchange act and to file a civil action against US Global, Robinson and Squires seeking relief from the court as follows:
I.
Issue a Final Judgment of Permanent Injunction and Other Relief restraining and enjoining US Global from, directly or indirectly, violating Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5]; Section 17(a) of the Securities Act
[15 U.S.C. § 77q(a)]; and Section 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Exchange Act Rules 12b-20, 13a-1, and 13a-13 [17 C.F.R. §§ 240.12b-20, 240.13a-1, and 240.13a-13].
II.
Issue an Order of Permanent Injunction restraining and enjoining Robinson and Squires from, directly or indirectly, violating Section 10(b) of the Exchange Act [15 U.S.C. § 78j(b)] and Exchange Act Rule 10b-5 [17 C.F.R. § 240.10b-5]; Section 17(a) of the Securities Act [15 U.S.C. § 77q(a)]; and from aiding and abetting violations of Section 13(a) of the Exchange Act [15 U.S.C. § 78m(a)] and Exchange Act Rules 12b-20, 13a-1, and 13a-13 [17 C.F.R. §§ 240.12b-20, 240.13a-1, and 240.13a-13].
III.
Issue an Order pursuant to Section 20(e) of the Securities Act [15 U.S.C. § 77t(e)] and Section 21(d)(2) of the Exchange Act [15 U.S.C. § 78u(d)(2)] permanently barring Robinson and Squires from acting as an officer or director of any issuer that has a class of securities registered pursuant to Section 12 of the Exchange Act [15 U.S.C. § 78l] or that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d)].
IV.
Issue an Order pursuant to the Court's equitable powers permanently barring Robinson and Squires from acting as an officer or director of any issuer that is required to file reports pursuant to Section 15(d) of the Exchange Act [15 U.S.C. § 78o(d).
V.
Issue an Order, pursuant to Section 603 of the Sarbanes-Oxley Act of 2002 [Public Law No. 107 - 204, 116 Stat. 745 (July 30, 2002)], Section 21(d)(6) of the Exchange Act [15 U.S.C. § 78u(d)(6)] and Section 20(g) of the Securities Act [15 U.S.C. § 77t(g)], and pursuant to the Court's equitable powers, permanently barring Robinson and Squires from participating in an offering of penny stock.
VI.
Issue an Order requiring Robinson and Squires to prepare an accurate accounting of all stock sales and trading profits from the sale of US Global stock by them in accounts that they controlled or exercised influence over during the period May 1, 2002 through January 30, 2004.
VII.
Issue an Order requiring Robinson and Squires to disgorge (i) all ill-gotten gains from sales of US Global securities in accounts that he controlled or exercised influence over between May 1, 2002 through January 30, 2004, plus prejudgment interest; and (ii) all ill-gotten gains from violations of the federal securities laws, plus prejudgment interest.
VIII.
Issue an Order requiring Robinson and Squires to pay civil money penalties pursuant to Section 20(d) of the Securities Act [15 U.S.C. § 77t(d)] and an Order requiring Robinson and Squires to pay civil money penalties pursuant to Section 21(d)(3) of the Exchange Act [15 U.S.C. § 78u(d)(3)].
IX.
Retain jurisdiction of this action in accordance with the principles of equity and the Federal Rules of Civil Procedure in order to implement and carry out the terms of all Orders and Decrees that may be entered, or to entertain any suitable application or motion for additional relief; and
X.
Grant such other and further relief as this Court may deem necessary and appropriate under the circumstances.
