Again, Blum, Tynan and Dr Richard E. Goulding are also involved in GRPS which got one of those mystery "ESC donations" (as did HALB--see below). Richard has since distanced himself but look at all the Goulding kids with stakes in it on page 5. Former CEO Richard's involvement is detailed on pages 19-20 of this latest disclosure https://www.otcmarkets.com/otcapi/company/financial-report/389065/content