I believe they were required to get a new CUSIP number and submit documentation to FINRA/NASDAQ before they submitted to the pinks, and I think FINRA is where they got held up in terms of the issues with Avalon stores and the history of this shell...maybe sammy would understand better than I can. But I believe they did submit everything and this is how they found out about the issues that the shell had.
I don't see any reason why Jason would NOT submit the paperwork for the RS, especially after announcing it. I mean, you saw what happened here after he announced it - and I am sure he already expected that response. If he wasn't going to do it in the first place I highly doubt he would have issued that PR.
But I've been wrong before.