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03/29/10 1:21 PM

#14312 RE: scion #14311

DEFENDANTS

13. Defendant Pawel P. Dynkowski is a citizen of Poland and a legal resident of the U.S. During the relevant time period, Dynkowski resided in Newark, Delaware.

14. Defendant Richard A. Bailey is a resident of Las Vegas, Nevada. Bailey was the Secretary and the director of GH3 during the relevant time period.

15. Defendant Matthew W. Brown is a resident of Aliso Viejo, California. Brown operates the penny stock website InvestorsHub.com.

16. Defendant Jacob Canceli is a resident of Mission Viejo, California. Canceli is a stock promoter.

17. Defendant Gerard J. D’Amaro is a resident of Pompano Beach, Florida. D’Amaro is a stock promoter.

18. Defendant Gary C. Heath is a resident of Mesa, Arizona. Heath owned and controlled High Plains Enterprises, a now inactive Minnesota corporation.

19. Defendant Joseph Mangiapane Jr. is a resident of Laguna Niguel, California. Mangiapane was a registered representative at AIS Financial, Inc. Mangiapane is the CEO of Rubicon Financial, Inc., which owned AIS Financial, Inc. during the relevant time period.

20. Defendant Nathan M. Michaud is a resident of Boston, Massachusetts.
Michaud is an internet web site designer.

21. Defendant Marc J. Riviello is a resident of Redwood City, California. Riviello was a registered representative at AIS Financial, Inc.

22. Defendant Adam S. Rosengard is a resident of Voorhees, New Jersey. Rosengard was a student at the University of Delaware during the relevant time period.

23. Defendant Florian R. Ternes is a resident of Las Vegas, Nevada. Ternes was the CEO of GH3 during the relevant time period.


SEC AMENDED COMPLAINT
http://sec.gov/litigation/complaints/2010/comp21463.pdf