Replies to post #26221 on Bravatek Solutions Inc (BVTK)

[DC Express]

VNDM NAMED IN 2016 LAWSUIT FOR SUPPOSED NAKED SHORTING

It is upon information and belief that one or more of these brokerage firms are assisting in naked shorting the stock: Automated Trading Desk Financial Services, LLC, Canaccord Genuity Inc., Cantor Fitzgerald & Co., Citadel Securities, LLC, G1 Execution Services, LLC, KCG Americas LLC, Maxim Group LLC, and Vandham Securities Corp.

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caravan Tuesday, 03/01/16 02:44:34 PM
Re: Toxic Avenger post# 54928
Post #
54929
of 56720 Go
The RICO lawsuit against Wallace has not been dismissed or "lost". I guess you missed this recent court filing:

IN THE SUPERIOR COURT OF ROCKDALE COUNTY

STATE OF GEORGIA

R. Martin Spencer and
Elaine G. Spencer, )
)
Plaintiffs, )
)
vs. ) CASE NO. 2015-CV-1800-I

Neil T. Wallace, Bette Wallace, )
The Estate of Harold Wallace, )
and Danielle Sims )
)
Defendants )


NOTICE FOR LEAVE TO FILE SUPPLEMENTAL AMENDED COMPLAINT

COMES NOW Plaintiffs R. Martin Spencer and Elaine G. Spencer in the above styled action, and pursuant to the Georgia Rule of Civil Procedure §9-11-15, the Plaintiffs will provide the court with new and additional information to further support claims made in the original Complaint.
On January 26, 2016 this court granted Neil T. Wallace's ("Wallace") Motion to Dismiss due to Personal Jurisdiction (Exhibit A). This Supplemental and Amended Complaint will provide further information asserting that Plaintiffs do have personal jurisdiction over Wallace due to new and relevant actions by him since the original filing of this Complaint.
This Pleading will demonstrate how Wallace's years of legal and online activities across four state lines and internationally were all done in order to unjustly enrich himself, his family, and his associates in an amount in excess of $2,400,000.
Exhibit B, submitted under O.C.G.A. 9-11-15(d), is a copy of U.S. North Georgia District Court filing by Atlanta SEC attorney Richard W. Jones. Mr. Jones states that Plaintiff Martin Spencer's stock, which was purchased at a Sheriff's Sale in Delaware for $1,000.00 by Wallace, is now valued in excess of $2,400,000.
Wallace has an extraordinarily broad Power of Attorney for his mother, Bette Wallace. As can be seen in Exhibit C, Wallace tried to represent his mother in Delaware by way of his mother's Power of Attorney. (Note: only pages 1, 11 and 12 are included in Exhibit C since those are the only relevant pages in this matter). The Delaware Superior Court denied Wallace's request to represent his mother and his family continues to retain Adam Gerber.
Using that POA Wallace retained Mr. Jones to assist in removing the legends on the stock so it will be free trading and capable of being sold in the public OTC stock market. It is upon information and belief that Wallace intends to give a portion of those shares to his associates, George MacLeod and Greg Stone (both residing in the UK), to cover any naked short positions (selling of stock not actually owned) they have initiated in manipulating the stock of the Plaintiffs' company, GeckoSystems International Corporation. It is upon information and belief that one or more of these brokerage firms are assisting in naked shorting the stock: Automated Trading Desk Financial Services, LLC, Canaccord Genuity Inc., Cantor Fitzgerald & Co., Citadel Securities, LLC, G1 Execution Services, LLC, KCG Americas LLC, Maxim Group LLC, and Vandham Securities Corp.
The remaining stock Wallace will sell and make over two (2) million of dollars per his own belief. The stock was bought by Wallace for only $1,000.00 and was suppose to only cover a $17,100 default judgment awarded to Wallace's parent in Delaware.
Retention of a Georgia attorney by Wallace on his mother's behalf constitutes doing business in the State of Georgia and thus gives the Plaintiffs jurisdiction over Wallace.
Per O.C.G.A. §9-11-15(a) Exhibit D is entered as additional information. This letter dated May 22, 2015 from Wallace to Plaintiffs' SEC attorney in Florida, is extremely insightful for a number of reasons: (1) he states that the shares in question have new owner registration and yet to date he will not allow the Delaware court to mark his parents' $17,100 default judgment satisfied with those shares; (2) he signs the letter as attorney for his mother, Bette Wallace who is a resident of Florida. At the time Wallace wrote the letter he was, and still is, ineligible to practice law in Florida, according the Florida Bar Association. This is a deliberate misrepresentation of his status with the Florida Bar Association and is only meant to be intimidating to the Plaintiffs' SEC attorney; (3) he has no basis for complaining to the Plaintiffs' SEC attorney about stock issuances; (4) the last sentence of his letter is a personal threat toward the Plaintiffs. This letter is an excellent example of Wallace's attempt to harass, threaten and intimidate. He has written many similar letters over the past eight years to the Plaintiffs' business partners and associates.
Plaintiffs assert that Wallace's misrepresentation to Mr. Leinwand goes further than just intimidation. Making a false statement regarding his status as an attorney such as Wallace has done in this letter constitutes interstate fraud, either wire or mail depending on how this letter was sent to Mr. Leinwand from Virginia.
O.C.G.A.§16-14-4 (a) states that it is unlawful for any person, through a pattern of racketeering activity or proceeds derived therefrom, to acquire or maintain, directly or indirectly, any interest in or control of any enterprise, real property, or personal property of any nature, including money.
The Plaintiffs will be able to show during Discovery and Trial how, since 2007, Wallace has conducted multiple, serially connected activities outlined in the original complaint in order to acquire or maintain, directly or indirectly, any interest in or control of any enterprise, real property, or personal property of any nature, including money."
In order to accomplish this unjust enrichment of receiving stock his SEC attorney has valued in excess of $2,400,000.00, Wallace has used the mail, telephone, computers, the internet and various courts. Since Wallace is barred in Florida and New York he has been able to use his legal knowledge to manipulate the courts to further and enhance his advantage, as will be shown herein.
. The Plaintiffs' attorney, Donald Gouge, addressed the Delaware Court of Common Pleas, in a recent letter dated January 21, 2016 (Exhibit E), submitted per O.C.G.A. §9-11-15(d). His letter obviously expresses frustration with Wallace and gives an excellent summary of the matter. Wallace informed the Delaware court on August 27, 2013 (Exhibit F) he and his family would satisfy the judgment after sale of the stock and ownership registration had changed. That happened and yet he still refuses to have the court mark his parents' default judgment of $17,100 satisfied. It is believed that Wallace does not want the default judgment marked satisfied at this time because having that legal declaration will not fit into his plans for receiving unjust enrichment in excess of $2,400,000.00 in stock for himself, his family and his cohorts in the United Kingdom.
To begin Discovery, Interrogatories and Document Request were mailed to Defendant Sims and this court on February 2, 2016. After she legally responses to these requests, Plaintiffs believe they will be able to show with substance Wallace's involvement with this Georgia resident and why that involvement constitutes a Predicate Act.
Other Predicate Acts committed by Wallace were submitted to this court September 9, 2015 wherein the Plaintiffs' argue that jurisdiction in Georgia is appropriate. O.C.G.A. §16-14-3 (c) states that it is a crime for "a person to put false information into a computer." Wallace has been putting false information into his computer and sending it out via emails, the internet, and letters for years which have culminated in a pattern of illicit activities against the Plaintiffs.

WHEREFORE, having filed this Notice for Leave to File Supplemental Information, Plaintiffs pray that this Court will allow submission of this new information based on facts uncovered after the original filing. Plaintiffs also pray the court will review all facts and statements provided in this filing to declare Georgia as the state of Jurisdiction over Neil T. Wallace.