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janice shell

01/29/17 2:07 AM

#117299 RE: shajandr #117298

By "his business", I mean his shell peddling business. The custodianship applications are made in the name of his Nevada company Barton Hollow LLC. Barton Hollow does nothing else.

In the custodianship application, which includes an affidavit signed by Tracy, he explains how many other custodianships he's applied for, and what's happened with them since that time. Among other things, he's supposed to disclose any SEC investigations. He hasn't yet done that, though he's known about the Atlanta District Office's investigation since November 2015.

Here's an example:

https://www.scribd.com/document/336320078/Tracy-Dct-1-and-All-Exhibits

He also appears to be lying about the shareholder meeting he says he's held or at least scheduled.

Once the custodianship is granted, one of the first things he does is issue himself a convertible note. Often, these notes would convert into control blocks. He then sells the note to the buyer of the shell, when he's found one. The buyer can do what he wants with the stock, presumably. I don't know the ins and outs of what happens next, because none of the buyers has gone into detail about that.

But Tracy is unquestionably issuing securities.