It's the issuer (DCGD) that sends a letter, along with an attorney letter, to the T/A to get the restriction removed. If it was shareholders from a previous version of the company that requested the removal of the restrictive legend all he had to do was say no. He's majority owner and CEO of the issuer. If they threatened to sue he'd say go ahead. He'd spend $50,000 or so and the case could go on for years
"Even if you’ve met all the conditions of Rule 144, you still cannot sell your restricted securities to the public until you’ve had the legend removed from the certificate. Only a transfer agent can remove a restrictive legend. But the transfer agent won’t remove the legend unless the issuer consents—usually in the form of an opinion letter from the issuer’s counsel to the transfer agent." https://www.sec.gov/fast-answers/answersrestrichtm.html
From the 10-12G/A "The practical effect is that these restricted shares are essentially illiquid and are unable to be sold by such holders into any public market, unless and until the requirements set forth in Rule 144 (i)(2) as set forth above have been met. Brokers will not even allow the deposit of the shares, nor will the transfer agent allow the removal of the restrictive legend." https://www.otcmarkets.com/filing/html?id=12948529&guid=6i4fUW5ugLP_gth
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