M. GRANT BETTINGEN, an individual and as co-trustee of the BETTINGEN 1999 TRUST, and CHRISTI BETTINGEN, an individual and as cotrustee of the BETTINGEN 1999 TRUST, Case No.: 30-2009-00290797 (Consolidated With 30-2009-00124138)
Plaintiffs,
v.
RUBICON FINANCIAL INCORPORATED, a Delaware Corporation; GRANT BETTINGEN, INC., a California Corporation; JOSEPH MANGIAPANE, JR., an individual; DEBORAHSCOTT, an individual;KATHLEEN MCPHERSON, an individual; SUZANNE HERRING, an individual; KIT KESSLER, an individual; TERRANCE DAVIS, an individual; MATT BROWN, an individual; MARC RIVIELLO, an individual; TODD VANDE HEI, an individual; DOES 1-300, inclusive,
Defendants. [...]
GENERAL ALLEGATIONS
34. This case involves the continuing saga of a ring of serial stock manipulators, criminals, frauds and con-men, all of whom are seeking to get rich quick on the hard work and money of innocent people like the Plaintiffs in this matter and the investing public. See SEC v. Dynkowski, et al, United States District Court, District of Delaware, Case No. 09-361, filed on or about May 20, 2009; U.S. Department of Justice press release, “Seven Indicted in ‘Pump and Dump’ Stock Schemes,” Dated May 21, 2009 (Collectively attached hereto and incorporated herein by reference as Exhibit “A”; and United States of America v. Dynkowski, Mangiapane and Riviello, United States District Court, District of Delaware, Criminal Action No. 09-23-UNA, Second Superseding Indictment, filed on or about April 16, 2009 (attached hereto and incorporated herein byreference as Exhibit “E”). The callousness of the individually named Defendants’ actions towards the Plaintiffs demonstrate their complete disregard for the health and welfare of those around them, the victims’ families and dependants, and shocks the conscious. Moreover, despite knowing of the fraudulent and criminal activities of members of their Boards of Directors, officers and key personnel as stated above and detailed below, neither the executives nor the Boards of Directors of Defendants RUBICON or GBI (NEWPORT COAST SECURITIES, INC.) have taken any corrective action, but have, in fact, ratified all of the illegal, fraudulent, criminal and/or negligent activities of their respective Boards of Directors, officers and key personnel as herein set forth. [...]
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