Found it - not sure the formatting will be great but this helps fill in the gaps.
On January 1, 2016, Arrayit issued irrevocable transfer agent instructions to its transferagent, Standard Register and Transfer Co., Inc. (Schena Decl. mr 4, 13 Ex. G.)
On May 26,2016, the Arrayit board of directors, by written consent, agreed to re-register the Collateral (the 6,600,000 Avant shares) in Iconic's name which would thereafter allow Iconic, at Iconic's option, to sell the Collateral into the public markets and reduce Arrayit's obligation under the Convertible Note. (Schena Decl. ~ 14, Ex. H.)
On June 1,2016, Arrayit sent Iconic's attorney, Randolf Katz of Baker & Hostetler, stock powers with medallion signatures for the Collateral. (Schena Decl. ~ 15, Ex. 1.)
On the date of surrender, the Collateral had a market value of$0.3511 per share or $2,317,260. (Id.) On June 15,2016, Iconic asked Arrayit's CEO bye-mail if Arrayit had sold Avant shares in the last 90 days. (Schena Decl. ~ 16, Ex. J.) Ms. Schena notified Iconic bye-mail 4 minutes later that Arrayit had not sold any Avant shares in the last 90 days. (Id.) This information is important because the answer, had it been yes, could have impacted Iconic's ability to sell the Collateral into the public market. (Id.) However, because Arrayit had not sold any of the Collateral in the preceding 90 days, it had no impact on Iconic's ability to sell the Collateral. (Id.)
On August 8, 2016, several months before the Convertible Note matured, Iconic sued Arrayit in San Diego County Superior Court, case number 37-2016-00026937-CU-BC-CTL, styled as Iconic Holdings, LLC v. Arrayit Corporation ("Iconic Lawsuit"). (Schena Decl. ~ 17, Ex. K;
Declaration of Tamara Leetham In Support Of Arrayit Corporation's Ex Parte Application For Temporary Restraining Order And Order To Show Cause Re: Preliminary Injunction ("Leetham Dec!.") ~ 2.)
The Iconic Lawsuit alleges that under the Convertible Note, Arrayit owed Iconic $780,889.27 in principal, fees, and penalties and requested money damages in that amount. (Schena Decl. ,-r 17.) Iconic did not pursue the Iconic Litigation. (Id.)
On December 23, 2016, the date the Convertible Note matured, Arrayit did not pay the outstanding principal as the Iconic Litigation was pending and the parties' rights and obligations under the various documents were in dispute and Arrayit had some months prior had sent stock powers with medallion guarantees for the Collateral. (Schena Decl. ,-r 18.)
In November 2017, Arrayit requested that Iconic release the reserve for 1.4 billion shares held on reserve at Standard. Iconic did not release the reserve. (Schena Decl. ,-r 24.)
On or about December 15,2017, as part ofthe Iconic Litigation, Arrayit's attorneys issued a Deposition Subpoena For Production of Business Records to VStock Transfer, LLC, 18 Lafayette Place, Woodmere, New York 11598. (Leetham Decl. ,-r 3, Ex. A) At that time, VStock was the
transfer agent for a publicly traded company named Avant Diagnostics. (Id.)
Arrayit had pledged shares in Avant Diagnostics as collateral to a convertible exchange note with Iconic and the VStock records were, and are, relevant and important to show when Iconic took ownership of the Avant shares. (Id.)
On or about December 15, 2017, Arrayit's attorneys served Avant's transfer agent, VStock Transfer, with a subpoena. (Schena Decl. ,-r 19.) Arrayit's attorney, Tamara Leetham, has attached a copy of the VStock subpoena to her declaration as Exhibit A
On January 2,2018, VStock produced documents pursuant to the subpoena. (Schena Decl. ,-r 20; Leetham Decl. ,-r 4, Ex. B.) On review of the VStock document production, Arrayit noted the following: (Schena Decl. ,-r 21; Leetham Decl. Ex. B)
a. On May 30, 2017, VStock cancelled Arrayit's Collateral (the 6,600,000 Avant Shares) and issued 6,600,000 shares at $.37 price per share in Iconic's name by book entry.
b. On June 2, 2017, VStock cancelled Iconic's book entry and issued a physical stock certificate for 6,600,000 million shares of Avant stock as evidenced by stock certificate number 1336.
c. On June 9, 2017, Iconic's share certificate 1336 was cancelled and issued in "street name" to CEDE & Co by book entry. Iconic was required to do this to sell the Avant shares into the public market.
d. VStock's internal documents from the Depository Trust Company (known as DTC), which is the electronic trading platform for shares held in CEDE & CO.'s name, note that the Collateral was valued at $528,000 when DTC accepted it for electronic trading .
On January 17,2018; surprisingly, Iconic dismissed the Iconic Litigation without prejudice as trial was scheduled for February 2,2018. (Schena Decl. ,-r 22; Leetham Decl. ,-r 5, Ex. C.)
Arrayit did not receive any information from Iconic between January 2018 and July 2018.
(Schena Decl. ,-r 23.) Iconic had dismissed the lawsuit and sold the Collateral and Arrayit's understanding was that the Collateral had satisfied any claims Iconic had against Arrayit. (Id.)
In June 2018, Arrayit requested that Iconic reduce the reserve shares. (Schena Dec!. ,-r 25.) Iconic did not release any reserve. (Id.)
On July 18, 2018, Standard forwarded a letter from Iconic attorney Randolf Katz whereby Iconic was requesting issuance certification, without restrictive legend, of 25,068,871 shares of Arrayit's common stock. (Schena Decl. ,-r 26, Ex. L.)
Iconic provided no notice to Arrayit of the conversion request and provided no accounting support. (Id.) Iconic also submitted a Rule 144
Seller's Rep Letter For Non-Affiliates and Exhibit A Form Of Conversion Notice to Standard Registrar. (Id, Ex. M.)
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