There are a number of other likely suspects, although your guess is obviously a very good and likely one.
1. Jim Carroll
2. The Novak Group as God only knows how many free shares they were given and the usual modus operedi for stock promoters is to take the money and spend it on their cocaine habit.
3. Mr. Holden as he is on record as owning over 10,000,000 shares.
4. Numerous others who are just plain getting fed up with waiting.
One wonders why Mr. Holden has disclosed his holdings by filing the appropriate documents and the other 2 Directors have not. Is this a voluntary thing or is it required when there is a change of control? Can you help me with that as I am really wondering what is going on here.