The Skull Valley pile of gravel has no "compliant technical documentation" either, so trying to justify it's "value" at $432 million is just sheer bullshit. Already being under the SEC microscope, it takes big cojones for RITE to stick with that bogus valuation. They'll get another comment letter about today's 10Q, and the SEC letter will probably will include language stating that the comment letters will be posted on Edgar for all to see since they are not complying. That'll be an extra fun day to read the letters and responses.
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