c. Grisaffi concealed and surreptitiously authorized the issuance 11,000,000 shares of stock to Epic and 10,000,000 shares of stock to Li for no consideration and without board approval in advance of these actions.
d. Grisaffi surreptitiously authorized the issuance of 113,688,625 shares of stock to the Radcliffe Group at deeply discounted prices as a part of a conspiracy to help them amass Rocky Mountain stock