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scion

10/01/11 12:43 PM

#15783 RE: scion #15780

11. On or about August 2010, Defendant CIFELLI promised Plaintiff EADE that if Plaintiff EADE would gift him 500,000 shares of common stock of Plaintiff IFLM, Defendant CIFELLI would create awareness of Plaintiff IFLM in the financial markets, and raise working capital for the company. The promise was false, and made to induce Plaintiff EADE to transfer the 500,000 shares to Defendant CIFELLI for no consideration.

12. The above-referenced representations of the Defendants, contained within paragraph 11, made to Plaintiff EADE in August 2010 in Delray Beach, Florida, by Defendant CIFELLI, in order to induce Plaintiff EADE to gift 500,000 shares of IFLM stock to Defendant CIFELLI.

13. Based upon Defendant CIFELLI's promise, Plaintiff EADE gifted him 500,000 shares of common stock of Plaintiff IFLM (the "free trading shares"). Defendant CIFELLI removed the restrictive legends from the certificates representing the 500,000 shares and deposited them in his three brokerage accounts.

14. On or about October 1, 2010, Defendant CIFELLI induced the Plaintiffs to enter into a comprehensive consulting contract (the "Contract") with Defendant ARRIV A, whereby Defendant CIFELLI promised to devote his full time to Plaintiff IFLM as a full time consultant, to perform the following duties:

a. Group business strategy, including strategy development, market analysis and research, competitor analysis, product strategy, revenue/commercial models, operational planning, and analyst presentations.
b. Oversee and manage service providers.
c. Third party consulting, including corporate strategy development and execution and business analysis.
d. Identify and recommend potential board members.
e. Review and provide awareness support for the company's quotation on the over-the-counter bulletin board.
f. Develop relationships worldwide for funding the capital needs of Plaintiff IFLM.
g. Assist in Plaintiff IFLM' s private placements of securities.
h. Structure of future funding arrangements, locate, identify, negotiate with and introduce funding sources and placement agents.
i. Financial services administration including supervision of accountants and liaison with auditors, management accounts, annual budget preparation, and annual financial statement preparation.
j. Manage investor relations and public relations, marketing, including advertising concept, layout and design; brochure concept, layout and design; sales materials concept, layout and design, press releases, public relations, copywriting, payoff lines, marketing initiative development (concept and budgeting), alignment of marketing initiatives with business strategy, design and development of all print media for sales and marketing support, advertising across all media (web, print, broadcast), digital sales materials (presentations, sales support), and digital marketing and promotional materials.


OCR extract -
Doc 1 PDF file
https://viewer.zoho.com/docs/sa7F8

nodummy

10/01/11 12:48 PM

#15784 RE: scion #15780

IFLM - Eade/Cifelli lawsuit

I had done a post about the shares given to Arriva Capital/Marc Cifelli back in March

http://investorshub.advfn.com/boards/read_msg.aspx?message_id=61130991

I didn't know the shares were advanced payment for market awareness and IR services.

Marc Cifelli was also one of the executive producers for the film Say It in Russian

http://ww1.prweb.com/prfiles/2009/02/12/61896/PressKit021009.pdf


I now believe that the 13,000,000 Gold Standard Mining (GSTP) shares given to Els Investments, Ltd./Sanford Browne were probably for the very same reason (market awareness).






Renee

10/02/11 10:21 AM

#15868 RE: scion #15780

Golly gee for Judge Dolly Gee....the crooks suing the crooks.

EADE sho is a litigious S.O.B.

Ought to be enuff for the SEC to shut down Independent Flim-Flam.

Not my finest Due Dilly, but that's my story and I'm sticking to it.