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scion

06/01/09 11:23 AM

#7306 RE: scion #7305

g. Between on or about September 1, 2006 and on or about September 8, 2006, defendant BROWN and P.D., together with others known and unknown to the grand jury, bought and sold, and directed the buying and selling of, all 7,750,000 Asia Global shares out of the 2005 Plan Participant's accounts at MS.

h. On or about August 22 and 24, 2006, defendant BROWN communicated via the instant messaging function of America OnLine with P.D. about the touting of Asia Global stock on on-line message boards, as well as an Asia Global press release, wherein P.D. instructed BROWN to "make it sound good like AAGH announces record revenue net profits increase of 300% etc."

i. On or about August 29, 2006, Asia Global issued a press release claiming that the company's net income for the second quarter of 2006 increased 370% over second quarter 2005 figures.

j. On or about September 1, 2006, defendant BROWN communicated via the instant messaging function of America OnLine with P.D. about the number of shares to be issued in Asia Global's future S-8 filing, wherein P.D. noted to BROWN that Asia Global should "do [a] bigger S-8, 25 mil[lion] shares instead of 15 [million shares] and we'll sell it all extra 10 mil[lion shares] . . . ."

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Matthew W. Brown: 04/16/2009 3 REDACTED VERSION of 2 Indictment by USA as to Defendant Sealed. (rpg) (rpg). (Entered: 04/22/2009)
Doc 3 OCR extract