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04/20/20 6:42 PM

#66056 RE: TenKay #66051

In granting the TRO, these are the judges words

"The declarations lay out in detail the factual basis of the concern that PBC may immediately “divert [plaintiffs’] remaining $2.8 million to other accounts, companies or individuals..



Sworn statement from CANN CFO:

"On December 30, 2019, Craig instructed PBC through Hawkins to issue a wire tax payment to the California Department of Tax and Fee Administration (“CDTFA) in the amount of approximately $1 million. On January 15, 2020, Craig received a statement on PBC letterhead indicating that an approximately $1 million deduction had been made from the CANN account on December 30, 2019. On February 21, 2020, I received a delinquency notice from CDTFA that the $1 million tax was not paid. Based on the actions of PBC, Costello and Hawkins to date, I am concerned that PBC has, or may at any time, divert the remaining $2.8 million of CANN and CCSAC funds to other accounts, companies or individuals."

"I declare under penalty of perjury that the foregoing is true and correct. Executed on March 25, 2020 in Oakland, California Ed Ng, CFO, CANN and CCSAC "