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Post by longterm on Sept 12, 2007 19:07:05 GMT -4
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Post by longterm on Sept 12, 2007 19:10:17 GMT -4
I. DISCOVERY CONTROL PLAN
1. Third-Party Plaintiffs request that discovery be conducted under Level II of Texas Rule of Civil Procedure 190,
II. PARTIES
2. Third-Party Plaintiff BioTech Medics, Inc. is a Nevada corporation authorized to do business in the State of Texas.
3. Third-Party Plaintiff Keith Houser is an individual who resides in the State of Texas.
4. Third-Party Defendant William Seminario (hereinafter "Seminario") may be served with process at his residence 3611 SW 113 Ct, Miami FL 33165.
5. Third-Party Defendant Hamilton Holdings PA, Corp. (hereinafter "Hamilton Holdings"), may be served with process by serving its attorney of record, Andrew Jones, Esq., of Tipton & Jones.
6. Third Party Defendant Andrew Jones (“Jones”) is an individual who resides in Dallas, Texas. Jones is also a Texas attorney.
7. Third Party Defendant Jeffrey G. Turino (“Turino”) is an individual who owns a resident in Clearwater, Florida and may be served with process at 3140 Masters Drive, Clearwater, FL 33761.
8. 1st Global Stock Transfer Agents, LLC, is a Nevada limited liability company in Las Vegas, Nevada and was under contract as BioTech’s transfer agent between on or about December 7, 2004, through July 15, 2006 and may be served with process by serving its register agent, Helen G. Bagley at 1st Global Stock Transfer, LLC, 7361 Prairie Falcon Road, Suite 110, Las Vegas, NV 89128.
9. Third Party Chris Jensen is an individual who resides in California and may be served with process at 2950 Aberdeen Lane, El Dorado Hills, CA 95762.
10. Third Party John Edwards is an individual who can be served at 9101 West Sahara Avenue, Suite 105-A33, Las Vegas, NV 89117 or at 6767 W. Tropicana, Las Vegas, NV 89103.
III. JURISDICTION & VENUE
11. Jurisdiction is proper in the District Court insofar as the amount in controversy exceeds the jurisdictional minimum of this Court.
12. Venue in Dallas County, Texas is proper because BioTech has corporate offices within Dallas County, Texas. Hamilton Holdings executed a Promissory Note with BioTech and 1st Global Transfer executed an agreement with Biotech which designate venue within the State of Texas.
IV. FACTS COMMON TO ALL COUNTERCLAIMS
13. BioTech Medics, Inc. (“BioTech”) is a registered Nevada corporation authorized to do business in Texas. BioTech is a publicly-traded company on the Pinksheets under the symbol “BTME” that engages in the business of establishing Pain & Wellness Clinics, distributing medical-use lasers, training laser technicians and developing medical laser protocols. Keith Houser (“Houser”) is BioTech’s Chairman/Chief Executive Officer and Kimberly Peralta-Jacobs (“Jacobs”) is BioTech’s Secretary-Treasurer and board member.
14. On or about mid-October or early-November, 2004, Houser and Jacobs on behalf of BioTech were introduced to Third Party Defendant Jeffrey Turino (“Turino”) by Third Party Defendant Chris Jensen (“Jensen”) in Las Vegas, Nevada. Subsequently in attendance at a luncheon meeting were Counter-Defendant Barnett, and Third Party Defendants William Seminario (“Seminario”), John Edwards (“Edwards”) and Helen Bagley (“Bagley”). Houser and Jacobs were invited to the meeting by Jensen and Turino for the purpose of introducing Houser to investors who would invest $1,000,000 in a reverse/merger with soon to be named Biotech Medics, Inc. (formerly: Corbel Holding, Inc.)
15. The luncheon meeting was run by Turino who paid for the lunch. During the luncheon, Houser talked to several of the “investors” including Edwards. Towards the end of the luncheon meeting, Turino approached Houser and introduced Houser to Barnett whom Turino represented would be the man to raise the $1,000,000. Barnett was accompanied by Seminario, whom Barnett introduced and represented to Houser as Barnett’s “business associate and partner.” Seminario stated that he had a Pennsylvania corporation named Hamilton Holdings PA Corp. (“Hamilton Holdings”). Despite the fact that Barnett, at this same time, was in dispute with Data Evolutions over his consulting arrangement with them to raise funds for that company, Barnett stated to Houser that he (Barnett) and Seminario had worked together on other project funding and had been successful in such projects. Barnett said that he and Seminario, through the vehicle of Hamilton Holdings PA Corp. would provide the $1,000,000 of funding through a 504 placement with Hamilton Holdings in Pennsylvania.
16. Contracts for the sale of BioTech stock were prepared based upon the representations of Turino, Seminario and Barnett to Houser, Jacobs and BioTech at this luncheon. On or about December 17, 2004, Hamilton Holdings executed a common stock warrant, by which Hamilton Holdings was entitled to purchase an aggregate of up to 25,000,000 shares of BioTech’s common stock (the “Common Stock Warrant”). A true and correct copy of the Common Stock Warrant is attached hereto as Exhibit A and incorporated herein by reference.
17. Subsequent to the December 17, 2004 execution of the documents, Counter-Defendant Barnett and Third Party Defendants Turino, Jensen, Edwards, Hamilton and Barnett insisted that the $1,000,000 to be infused into BioTech by the 504 transaction with Hamilton Holdings be spaced out so that it was not all spent at one time (even though this was not a part of the original signed contracts). As a result, the $1,000,000 was to be paid by the Counter-Defendant and Third Party Defendants in weekly installments of $100,000. Accordingly, the Common Stock Warrant was secured by a promissory note (the “Promissory Note”) executed by Hamilton Holdings on December 17, 2004 in favor of BioTech in the principal amount of $1,000,000. A true and correct copy of the promissory note is attached hereto as Exhibit B and incorporated herein by reference. BioTech then completed the necessary filings and disclosures to the Securities and Exchange Commission (“SEC”) and the Pennsylvania Securities Commission regarding the proposed REG D stock sale.
18. However, prior to the execution of the stock warrants and the execution of the promissory note, Third Party Defendant Helen Bagley, unbeknownst to Defendants and Counter Plaintiffs, had already issued two stock certificates to Hamilton Holdings for 4,250,000 shares of Biotech stock each on December 7, 2004 totaling 8,500,000 shares of Biotech stock. Upon information and belief, Bagley acted upon the instructions of Turino and Jensen. Then, on December 17, 2004, in reliance upon the assurances that $100,000 payments would begin pursuant to the promissory note Bagley issued additional shares to Hamilton Holdings.
19. However, the installments due on December 17, 2004, December 24, 2004 and December 31, 2004 were not paid to Biotech. As a result, Houser communicated this default and his displeasure to both Jenson and Barnett. Barnett and Jensen assured Houser that every one of the investors at the luncheon meeting were going on vacation or holiday and they would take care of it right after the first of the New Year. Houser subsequently learned that his communications to Jensen were relayed to Turino. When Houser did not receive any communications or funding after the first of the New Year he called Jensen and demanded that a meeting be held to discuss the, by now, $400,000 default.
20. Subsequently, on January 7, 2005, a meeting was held at the offices of Third Party Defendant 1st Global Transfer Agent, which was BioTech’s transfer agent for the sale of its stock. Turino, Barnett, Seminario, Edwards and other investors were present at the meeting. Turino was the leader of the meeting and did most of the talking. It was represented to Houser that they (i.e., Turino, Edwards, Barnett and Seminario, etc.) would take care of the default during the week of January 7, 2005. Toward that end of the meeting, Barnett issued to Houser his personal check for Fifteen Thousand Dollars ($15,000.00) as a “down payment” toward the cure of the default by Hamilton Holdings (see Exhibit “C”).
21. During this and the preceding meeting, Barnett referred to himself and Seminario as “we.” Seminario indicated that he had executed the Subscription Agreement and placed it in escrow with a Florida attorney so that a legal opinion could be issued to legally purchase shares of BTMD stock, and such purchase was secured by the Promissory Note.
22 At the insistence of Turino and Jensen, Houser produced on behalf of BioTech a NOBO list of non-objecting shareholders, Turino went through the list in the presence of Edwards, Barnett, Seminario and Jensen because he wanted to know if there were any “enemies” who would cause problems down the road and indicated that he controlled certain companies holding Biotech stock, including Federal One Investments, 71st Street Holdings, T&T Equity Funds, LLC, and KRKA, LLC. Barnett indicated he controlled Hamilton Holdings.
23. Turino then went around the room asking each “investor” for a commitment. Barnett indicated he would handle the initial couple hundred thousand at 12 cents per share, Jensen indicated he could handle about 100,000 shares between 12 cents and 20 cents per share, another investor indicated he would handle the stock between thirty cents and 50 cents for another 100,000 shares and Edwards indicated he would handle the balance between 50 cents and one dollar.
24. On this same date of January 7, 2005, Data Evolution, trading symbol: DTEV filed a “Verified Complaint” and request for a “Temporary Restraining Order” in US Dist. Court- Eastern Dist. Of Louisiana, Civil Action No. 05-0051 against Barnett, Seminario and Hamilton. It was alleged in the matter that:
“As a result of Barnett’s malicious actions, the price of the Company’s stock has fallen from a closing price of $7.25 per share on November 30, 2004, to a closing price of $3.20 on January 5, 2005. The most precipitous drop in the Company’s stock price occurred on December 1, 2004, the day that Barnett overtly threatened to destroy the Company’s public existence. On such day, the Company’s stock price closed at $3.80 per share down from a closing price of $7.25 on the previous day.”
25. Counter Defendant Barnett subsequently entered into a settlement agreement (attached hereto as Exhibit “D” and incorporated herein by reference, with DETV after failing to raise funds for the company and then driving down the price of the company’s stock.
26. After the January 7, 2005 Las Vegas meeting, however, no further funds were received by Biotech and Hamilton Holdings fell further into default. Nevertheless, on January 26, 2005, Bagley issued a stock certificate to Hamilton Holdings for 4,500,000 shares of stock and on February 11, 2005 Bagley issued a stock certificate to Hamilton Holdings for 4,000,000 shares of stock and on March 16, 2005 Bagley issued a stock certificate to Hamilton Holdings for 765,306 shares.
27. Additionally, a second stock certificate for 500,000 free trading shares were issued to Barnett despite the fact that Biotech had not received any funds from Hamilton Holdings and no consideration other than the $15,000 down payment from Barnett and without any consultation or authorization from Biotech’s Board of Directors. On information and belief, Bagley was communicating with Turino and Jensen during this time.
28. At all times alleged herein, Turino was subject to a “final judgment” rendered by the Federal District Court Judge for the Middle District of Tampa, Florida prohibiting him from engaging in the activities described above. A true and correct copy of the final judgment is attached hereto as Exhibit E. Both the Counter-Defendant and Third Party Defendants knew of the final judgment yet assisted, aided and abetted Turino in violating the terms of the court’s final judgment. The scheme upon which Turino was prosecuted bears remarkable resemblance to the fraudulent scheme perpetrated upon the Defendants by Turino, Barnett, Jensen, Edwards, 1st Global and Bagley.
29. In March, 2005, Biotech sent a notice letter Hamilton Holdings indicating it was in default of the Promissory Note after receiving only $15,000 of the promised $1,000,000. However, at this time, Bagley had issued over Seventeen million (17,000,000) shares of BioTech stock to Hamilton Holdings. Of these 17 million shares, only 4.25 million shares have been returned by Hamilton Holdings to BioTech after Hamilton Holdings’ default under the Promissory Note. The remaining shares, on information and belief, have found their way into the marketplace.
30. Thereafter, Third Party Plaintiffs terminated the services of Bagley, Jensen and Global and obtained all of the stock transfer records from them. In the process of a continuing audit of the records received from Bagley and Global, Counter-Plaintiffs discovered that prior to the reverse merger Bagley issued a BioTech free trading stock certificate for 500,000 shares of common stock to Counter-Defendant Barnett. After making due inquiry, Third Party Plaintiffs have determined that there was no authorization for the issuance of the stock and no consideration received from Counter-Defendant Barnett. The 1,000,000 shares of Biotech’s common stock received by Counter Defendant Barnett were subsequently placed into CEDE and, upon information and belief, were sold by Counter Defendant Barnett.
31. As a result of the fraudulent scheme perpetrated by the Third Party Plaintiff and Third Party Defendants, at an average price per share of $.08, Hamilton Holdings, Counter Defendant and Third Party Defendants have received stock in BioTech worth approximately one million twenty thousand dollars ($1,020,000) for the payment of fifteen thousand dollars ($15,000). Counter Defendant Barnett has obtained stock worth $80,000 for which Third Party Plaintiffs have not received any consideration.
32. Upon information and belief, Counter Defendant and Third Party Defendants, in active concert with each other and in furtherance of inflate the value of BioTech’s stock through the public dissemination of misinformation regarding the current financial condition of BioTech, the sale of the fraudulently obtained 504 stock and the controlled purchase and sale of BioTech stock utilizing the fraudulently obtained 504 stock.. The misinformation was disseminated by Counter Defendant and the other Third Party Defendants, including but not limited to William Seminario.
33. Based upon court records from other jurisdictions, the wrongful acts of Counter Defendant Barnett are a modus operandi of his pattern to illegally manipulate the value of publicly traded stock. In a similar lawsuit against him, Barnett agreed to: a) return over 1.8 million shares of stock; b) cease from engaging “in any cross-selling with account owned and/or controlled by Barnett or any affiliate or acquaintance of Barnett for the purpose of increasing the daily trading volume of the Company’s ‘Common Stock’”; and c) “Barnett agrees that he will not issue any communications, written or otherwise, that would disparage or reflect adversely upon the Company, its subsidiaries or any affiliated organizations, or their products or services.”
34. On November 21, 2005, Counter-Plaintiffs issued a press release concerning the default involving the failed 504 transaction between BioTech and Hamilton. A copy of the press release is attached hereto as Exhibit F and incorporated herein by reference. On November 23, 2005, Third Party Defendant Andrew Jones, a business associate and the personal attorney of Barnett, caused to be published a press release which is attached hereto as Exhibit G and incorporated herein by reference.
35. Subsequently, during 2005, Counter Defendant and Third Party Defendants, under several different aliases including but not limited to “inthemoment88”, “stockwizard001,” “zero_tolerance12”, “Woody9721” and “experto.credite”, began making public posts on the “Raging Bull” stock message board. “Raging Bull’ is an internet message board on which investors, potential investors, and industry observers and analysts can comment and share information on stocks. The messages posted by Counter Defendant and Third Party Defendants were defamatory messages on Raging Bull regarding BioTech and Houser, including personal attacks on Mr. Houser’s character and business reputation and misinformation regarding the financial condition of BioTech, including, but not limited to, the following messages
36. On March 9, 2006, this Court signed an “Agreed Order” which was a mutually agreed temporary injunction between the parties. One specific part of the Order was that “Barnett, Seminario and Hamilton…and all other persons, firms, and entities acting directly or indirectly or on behalf of them or who are in concert with them are hereby immediately and temporarily restrained from: a. posting messages regarding Houser, BioTech or BioTech’s employees, shareholders, customers, or related business entities, on any public Internet forum.”
37. On March 16, 2006, just 7 days subsequent to this Court signing the Agreed Order, on information and belief, Counter-Defendant Adam Barnett or another person acting directly or indirectly or on behalf of Barnett started posting defaming and disparaging posts regarding Houser on the Raging Bull internet investor bulletin board under the name “Woody9721”. Twelve (12) posts in all were published on the Raging Bull by Woody9721. One such post published on March 17, 2006, reads:
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Post by longterm on Sept 12, 2007 19:12:19 GMT -4
and BTMD was merged into the Corbel shell.....where Jcline used to post on RB claiming the evil shorters had opened CBLH for trading...without the owners knowing.
hahahahhhahaa.
CBLH was a sham dividend from PCBM...where all the fools like Cline, Silvergullet, Mqlilweenie, and others claimed the stock was massively short. Edwards and others, including PA Holdings helped dump 24 Billion shares without telling anyone.
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Post by longterm on Sept 12, 2007 19:13:29 GMT -4
38. The Barnett/Woody9721 post above defames and disparages Houser’s name by falsely stating Houser is also posting on the Raging Bull as “Destiny 315”, which is false and would be a violation of the Agreed Order. It also defames and disparages Houser by calling Houser a “retard”. Then Barnett/Woody9721 falsely accuses Houser of “painting the tape”. Further, Barnett/Woody9721 defames Houser by falsely stating: “Man Keith..your (sic) so weak”. Barnett/Woody9721 also falsely accuses and defames Houser by posting that Houser is “lying” about “504 fundings”. Barnett/Woody9721 further defames Houser by stating that he should “Stop running around Dallas like a moron.” Barnett/Woody9721 defames Houser with a demand Houser resign: “Resign already and enjoy your 60’s in Dallas doing what you love and are good at. Acting like a total nut in life.” Finally, Barnett/Woody9721 falsely signs the message as “Ed Surfit”. It is commonly known this is an alias for Edward Thompson.
39. Simultaneously, while Barnett/Woody9721 is defaming and disparaging Houser’s good name and reputation on the Raging Bull, Barnett conspired with Third Party Defendant Turino and/or Turino’s known associate Larry Jim Priest (“Priest”) to defame and disparage Houser’ good name and reputation as well as BioTech Medics. Upon information and belief, Larry Priest is the Raging Bull Member who uses the alias: “sine.nomine”. Turino and Priest are known to have traveled together and have been associated together with other penny stock companies. Turino is known for using other peoples aliases and emails to post and send messages.
40. Sine.nomine posted 294 posts regarding BioTech and Houser. Most of them were defaming and disparaging of Houser and BioTech with half-truths twisted to give the Raging Bull readers a false impression of Houser and Biotech. In Sine.nomine’s post # 11418, issued on March 31, 2006, Sine.nomine “thanks” Barnett/Woody9721 for his “thoughts” which were more defaming and disparaging statements about Houser and Biotech. Sine.nomine’s posts continued through September 7, 2006. These messages were seen by investors, potential investors, and industry observers and analysts of BioTech and have a devastating effect on the public image of a company and its CEO Houser’s good name and reputation.
41. Contemporaneously with the posting of these messages on “Raging Bull” Counter Defendant, again using an alias of “Wheruat’, began sending a series of derogatory e-mails to Houser, including, but not limited to the following:
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Post by longterm on Sept 12, 2007 19:15:00 GMT -4
42. These e-mail contained personal attacks on Mr. Houser’s character and business reputation and personal attacks on the character and reputation of Mr. Houser’s wife.
COUNT ONE
Default on Promissory Note
42.Third Party Plaintiffs re-allege each and every allegation in paragraphs 6-15 above and incorporate them herein by reference.
43. On December 17,. 2004, the Third Party Defendant Hamilton Holdings duly executed a $ 1,000,000 promissory note. Copies of the promissory note are attached as Exhibit G and are incorporated by reference herein for all purposes.
44. Pursuant to the terms of the promissory note, the Third Party Defendant Hamilton Holdings was obligated to pay the plaintiff $1,000,000 by December 17, 2004. The note is subject to the laws of the State of Texas.
45. The Third Party Defendant Hamilton Holdings defaulted by not paying the plaintiff the installments due beginning on December 24, 2004.
46. By reason of this default, and in accordance with the terms of the promissory note, the third party plaintiff by letter of March, a copy of which is attached as Exhibit H and incorporated by reference herein, made demand on the Defendant Hamilton Holdings for payment of the overdue amount together with accrued interest Third Party Defendant Hamilton Holdings has wholly refused and failed to make any payments pursuant to the promissory note other than a $15,000 payment made by Counter Defendant Barnett on behalf of Hamilton Holdings.
47. Pursuant to the terms of the note, the Third Party Defendant Hamilton Holdings is liable to the plaintiff for $1,000,000 plus “20% of the note for reasonable attorney's fees” and expenses of collection, in the amount of $250. Accordingly, Third Party Defendant Hamilton Holdings owes Third Party Plaintiff the sum of $1,000,000 by reason of failure to pay the note under the promissory note and security agreement, in addition to $200,000 in reasonable attorney's fees, less $15,000 from Barnett, plus statutory 10% interest making a total of $1,390,950 due and payable.
COUNT TWO
Breach of Contract
48. As part of the Reverse Merger Agreement which created Biotech Medics, Inc., on or before December 17, 2004, William Seminario, as President of Hamilton Holdings executed on behalf of Hamilton Holdings a series of contracts with Bruce Harlan, former President of Corbel (the predecessor of Biotech Medics, Inc.) through the law firm of Laura Anthony in West Palm Beach, Florida consisting of a stock “Subscription Agreement”, a “Stock Warrant” and a binding “Promissory Note” (“Note”) to BioTech for ONE MILLION DOLLARS ($1,000,000).
49. Hamilton breached the agreement within one week of signing the contract and continues to date having breached the Promissory Note and not paid the One Million Dollar Note, together with interest, legal fees and costs.
50. Under Paragraph 9 of the Warrant under “Representations and Warranties by the Holder.” Hamilton Holdings, represented:
“a) This Warrant is being acquired for the Holder’s own account,
for investment and not with a view to, or for resale in connection
with, any distribution or public offering thereof within the meaning
of the Securities Act of 1933, as amended (the “Securities Act”).
Upon exercise of this Warrant, the Holder shall, if so requested by
the Company, confirm in writing, in a form reasonably satisfactory
to the Company, that the Shares issuable upon exercise of this
Warrant are being acquired for investment and not a view toward
distribution or resale.’
51. Hamilton, Barnett & Seminario breached their representations and warranties to BioTech, Houser and Jacobs in that upon issuance of the stock, they immediately sold the shares into the public retail market and kept the profits for their own personal gain (save and except for $15,000 paid by Barnett with his personal check); they did not hold the shares for any long term investment purposes; and they were NOT “accredited investors” within the meaning of Reg D and the federal and Texas Securities Act.
52. As a result of the breach of the December, 2005 Agreements, BioTech, Houser and Jacobs have incurred damages that are the natural, probable and foreseeable consequences of Hamilton’s, Barnett’s and Seminario’s breach in an amount which exceeds the jurisdictional limits of this court.
COUNT THREE
Alter Ego
53. Third Party Plaintiffs re-allege each and every allegation in the paragraphs above and incorporate them herein by reference.
54. Counter Defendant Barnett, Third Party Defendant Seminario and the other Third Party Defendants utilized the Hamilton Holdings entity as a sham to perpetrate their fraudulent scheme upon Defendant Biotech and its shareholders, officers and directors and Barnett, Seminario and the other Third Party Defendants utilized Hamilton Holdings as a conduit to fraudulently obtain Biotech stock never intending that Hamilton Holdings pay the $1,000,000 promised to Defendant Biotech and never intending that Hamilton Holdings hold the Biotech stock for investment.
55. Accordingly, each of Barnett, Seminario and Third Party Defendants are individually and jointly and severally liable for the default by Hamilton Holdings on the $1,000,000 note, plus pre-judgment and post-judgment interest.
COUNT FOUR:
Defamation
56. Third Party Plaintiffs re-allege each and every allegation in the paragraphs above and incorporate them herein by reference.
57. As set forth in detail above, Barnett and Third Party Defendants, using a series of aliases, published defamatory statements of fact on the “Raging Bull” message board referring to BioTech and Houser, BioTech’s Chief Executive Officer. In addition, Third Party Defendant Jones caused to be published a press release casting aspersion upon and defaming Houser.
58. Barnett and Third Party Defendants and Third Party Defendant Jones knew that the defamatory statements posted on the “Raging Bull” message board and the press release was false.
59. Barnett and Third Party Defendants acted with malice in making each and every of the false, defamatory statements posted on the “Raging Bull” message board and contained in the press releases.
60. As a result of these defamatory statements made by Barnett and Third Party Defendants, both BioTech and Houser have suffered pecuniary injury.
61. The conduct of Barnett was such that both Biotech and Houser are entitled to exemplary damages, of which they pray for herein.
COUNT FIVE:
Business Disparagement
62. Third Party Plaintiffs re-allege each and every allegation in the paragraphs above and incorporate them herein by reference.
63. As set forth in detail above, Barnett, and Third Party Defendants using a series of aliases, published disparaging statements of fact on the “Raging Bull” message board regarding the economic interests of BioTech and Houser, BioTech’s Chief Executive Officer.
64. The disparaging statements of fact published by Barnett and Third Party Defendants on the “Raging Bull” message board regarding the economic interests of BioTech and Houser were false.
65. Barnett and Third Party Defendants acted with malice in making each and every of the false, disparaging statements he posted on the “Raging Bull” message board.
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Post by longterm on Sept 12, 2007 19:16:31 GMT -4
67. The above-referenced disparaging statements made by Barnett and Third Party Defendants have caused special damages to BioTech, with such pecuniary losses having been realized as of the date of the filing of this Counterclaim.
68. The conduct of Barnett and Third Party Defendants was such that Biotech is entitled to exemplary damages, of which it prays for herein.
COUNT SIX:
Conversion
69. Third Party Plaintiffs re-allege each and every allegation in the paragraphs above and incorporate them herein by reference.
70. As set forth in detail above, BioTech is entitled to the immediate possession of the outstanding 12.75 million shares of BioTech stock that were transferred to Hamilton Holdings, Seminario, Barnett and the other Third Party Defendants under the terms of the Common Stock Warrant and Promissory Note.
71. Despite their default under the Promissory Note, Barnett, Seminario, the other Third Party Defendants and/or Hamilton Holdings continue to wrongfully exercise dominion or control over a portion of the12.75 million shares of BioTech stock. Despite demand by Houser and BioTech, Barnett, Seminario, the other Third Party Defendants and/or Hamilton Holdings refuse to turnover the outstanding shares of stock.
72. Further, Third Party Defendants in active concert with Counter-Defendant Barnett, have caused to be issued to Counter-Defendant Barnett an additional 1,000,000 shares of Biotech stock without any authorization from Biotech’s Board of Directors and without any consideration received by Biotech.
73. BioTech has suffered and continues to suffer damages as a result of the actions of Barnett and the Third Party Defendants.
74. The conduct of Barnett and the Third Party Defendants was such that Biotech is entitled to exemplary damages, of which it prays for herein.
COUNT SEVEN:
Theft Liability Act
75. Third Party Plaintiffs re-allege each and every allegation in paragraphs 6-15 above and incorporate them herein by reference.
76. As set forth in detail above, BioTech has a possessory right to the 12.75 million shares of BioTech stock that were transferred to Hamilton Holdings, Seminario and/or Barnett and the other Third Party Defendants under the terms of the Common Stock Warrant and Promissory Note. In addition, Biotech has a possessory right to the 1 million shares of stock transferred without authority or consideration to Counter-Defendant Barnett
77. Barnett, Seminario the other Third Party Defendants and/or Hamilton Holdings appropriated the 12.75 million shares of BioTech stock with intent to deprive BioTech of said stock and made such appropriation without BioTech’s effective consent due to their default under the terms of the Common Stock Warrant and Promissory Note. Additionally, Counter-Defendant Barnett has appropriated an additional 1 million shares of Biotech Stock with the intent to deprive Biotech of said stock and made such appropriation without Biotech’s effective consent.
78. Despite demand by Houser and BioTech, Barnett, Seminario, the other Third Party Defendants and/or Hamilton Holdings refuse to turnover the outstanding shares of stock.
79. BioTech has suffered and continues to suffer damages as a result of the actions of Barnett and the Third Party Defendants.
80. The conduct of Barnett and the Third Party Defendants was such that Biotech is entitled to exemplary damages, of which it prays for herein.
81. BioTech prays for recovery of the $1,000.00 statutory penalty as against Barnett and each of the Third Party Defendants, in addition to its actual damages.
82. BioTech further prays for recovery of its attorney fees, costs, and expenses incurred in prosecuting this claim.
COUNT EIGHT:
Conspiracy
83. Third Party Plaintiffs re-allege each and every allegation in the paragraphs above and incorporate them herein by reference.
84. As set forth in detail above, Barnett acted in concert with one or more co-conspirators, including but not limited to each of the Third Party Defendants, for the purposes of a) wrongfully depriving BioTech of 13.75 million share of its stock, and b) unlawfully manipulating the value of BioTech’s stock through the posting of messages on the internet which would cause unsuspecting investors to either buy or sell Biotech stock and through the control of both the buy and the sell of Biotech stock.
85. BioTech has suffered and continues to suffer damages as a result of Barnett and his co-conspirator’s actions.
86. The conduct of Barnett and his co-conspirators was such that Biotech is entitled to exemplary damages, of which it prays for herein.
COUNT NINE:
Unjust Enrichment
87. Defendants re-allege each and every allegation in the paragraphs above and incorporate them herein by reference.
88. As set forth in detail above, BioTech provided to Barnett, Seminario the other Third Party Defendants and/or Hamilton Holdings seventeen million shares of its stock. Pursuant to the terms of the Common Stock Warrant and Promissory Note, BioTech was to be compensated by Barnett, Seminario, the other Third Party Defendants and/or Hamilton Holdings for the transfer of its stock.
89. Barnett, Seminario, the other Third Party Defendants and/or Hamilton Holdings accepted the stock shares and, despite their default under the Promissory Note, continue to hold and reap the benefit of the outstanding12.75 million shares of BioTech stock and also the 1,000,000 shares of Biotech stock Barnett and Third Party Defendants conspired to have issued to Barnett..
90. For cause of action herein, BioTech seeks to recover the value of its stock shares from Barnett and the Third Party Defendants based upon the equitable principle of unjust enrichment; that a person receiving benefits which were unjust for him to retain ought to make restitution.
91. BioTech’s recovery of its damages from Barnett is based on fundamental principles of justice, equity, and good conscience which give rise to Barnett’s implied or quasi-contract to repay.
COUNT TEN
Violation of Court Order
92. Beginning on March 16, 2006, Counter-Defendant Barnett and Third Party Defendants acting in concert with Barnett have made numerous posts under the names “woody9721” and “zero_tolerance12”, “barnburner1998” among other names, which disparage both Houser and Biotech.
93. These posts violate this Court’s order which was entered on March 9, 2006 which prohibited Counter-Defendant Barnett and those in active concert with him from posting internet messages which defame and disparage Third Party Plaintiffs Houser and Biotech.
94. Accordingly, Counter-Defendant is in contempt of this court’s March 9, 2007 Agreed Order. Counter-Plaintiffs have suffered pecuniary and special damages as a result of Counter-Defendant’s contempt.
95. As a result, this court should enter its order holding Counter-Defendant in contempt and ordering sanctions and other relief authorized by the Texas Rules of Civil Procedure and the Texas Civil Practice and Remedies Code.
COUNT ELEVEN
Aiding and Abetting the Violation of a Federal Court Order
96. On December 5, 2003, this the Federal District Court for the Middle District of Florida entered a Final Judgment as to Third Party Defendant Jeffrey G. Turino, a true and correct copy of which has been attached hereto as Exhibit A and incorporated by reference herein for all purposes. Among other things the Court ordered that :
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Post by longterm on Sept 12, 2007 19:17:17 GMT -4
“Defendant [Turino] and Defendant’s agents, servants, employees, attorneys, and all persons in active concert or participation with them who receive actual notice of this Final Judgment by personal service or otherwise are permanently restrained and enjoined from violating Section 17(a) of the Securities Act. . . in the offer or sale of any security . . . to employ any device, scheme or artifice to defraud … to obtain money or property by means of any untrue statement of a material fact . . . or to engage in any transaction, practice or course of business which operates or would operate as a fraud or deceit upon the purchaser.”
The Court further ordered that:
“Defendant [Turino] be hereby is prohibited, pursuant to Section 20(g) of the Securities Act . . . for a period of five years from the entry of this Final Judgment from participating in an offering of penny stock, including engaging in activities with a broker, dealer, or issuer for purposes of issuing, trading, or inducing or attempting to induce the purchase or sale of any penny stock. A penny stock is any equity security that has a price of less than five dollars . .. …”
97. Despite their actual knowledge of this court’s final judgment in this case, the Counter-Defendant and Third Party Defendants other than Turino, in active concert with the Defendant Turino, have participated in a device, scheme or artifice to defraud both Biotech and the purchasers of Biotech’s stock through initiating purchases and sales of Biotech’s stock designed to control price of Biotech’s stock to the benefit of Defendant Turino and the remaining Respondents.
98. Third Party Defendant Turino, in active concert with and aided and abetted by the Counter-Defendant and Third Party Defendants other than Turino, have caused the purchase and sale Biotech’s stock in furtherance of Turino’s plan and scheme to defraud Biotech and the purchaser’s of Biotech’s stock for his own benefit in violation of this Court’s final judgment
99. Third Party Defendant Turino has further violated the Court’s final judgment by engaging in activities with an issuer (i.e., Biotech) for purposes of issuing, trading, or inducing or attempting to induce the purchase or sale of any penny stock by his activities in orchestrating the “purchase” of 25,000,000 shares of Movant’s stock through a “504 Transaction” with Third Party Defendants Hamilton Holdings and Seminario and Counter Defendant Barnett; orchestrating the subsequent sale and purchase of the 25,000,000 “504 Shares” through Third Party Defendants Hamilton Holdings, Barnett, Seminario, Edwards and Jensen and conspired with Third Party Defendant 1st Global and Bagley to issue additional shares of stock to the Counter Defendant and Third Party Defendants.
100. Counter-Defendant Barnett and Third Party Defendants Seminario, Edwards and Jensen aided and abetted the Defendant Turino to violate this order by facilitating their action described above
101. The actions of Counter-Defendant Barnett and Third Party Defendants have caused damages to Biotech in an amount in excess of the jurisdictional limits of this court.
COUNT TWELVE
Intentional Misrepresentation and Fraud
102. Defendants re-allege each and every allegation in the paragraphs above and incorporate them herein by reference.
103. Counter-Defendant and Third Party Defendants made countless false representations to Counter-Plaintiffs concerning their success and ability to provide funds to Counter-Plaintiff Biotech through a 504 placement and also intentionally failed to disclose material facts to Third Party Plaintiff Biotech.. In reliance upon these material misrepresentations and intentional omissions, Counter-Plaintiff Biotech agreed to a 504 transaction with Hamilton Holdings which Counter-Defendant and Third Party Defendants never intended to honor.
104. Counter Defendant and Third Party Defendants either knew that their representations to Third Party Plaintiff Biotech was false when they made them or made the representations recklessly without any knowledge of the truth as positive factual assertions. Further, Counter Defendant and Third Party Defendants omitted to state material facts, including, but not limited to, the lawsuit filed against them by Data Evolution, attached hereto as Exhibit F and incorporated herein by reference, Counter Defendant Barnett had a New Jersey series license which was revoked or terminated., Barnett was no longer a Florida “investment advisor”, required in his type of alleged “investment banking business”, Barnett had an investment advisor license which has expired, terminated or stopped due to disciplinary action and Turino, who introduced Barnett to Counter-Plaintiffs, had an SEC Complaint filed against him in the US District Court-Middle Dist. Of Florida, in the matter of SEC v. Pinnacle Business, Jeffery G. Turino, et al., Case No. 8:02-CV-822-T-17EAJ, enjoining Turino from violating various SEC laws, at the time Counter Defendant and Third Party Defendants were inducing Counter-Plaintiff Biotech to enter into the 504 transaction.
105. Counter Defendant and Third Party Defendants made their false representations and omitted to state material facts with the intention that Third Party Plaintiff rely and act upon them, which caused Third Party Plaintiff to suffer damages in an amount in excess of the jurisdictional limits of this court.
COUNT THIRTEEN
Negligent Misrepresentation
106. Defendants re-allege each and every allegation in paragraphs 6-15 above and incorporate them herein by reference.
107. Counter-Defendant and Third Party Defendants made countless false representations to Counter-Plaintiffs concerning their success and ability to provide funds to Counter-Plaintiff Biotech through a 504 placement. In reliance upon these material misrepresentations, Counter-Plaintiff Biotech agreed to a 504 transaction with Hamilton Holdings which Counter-Defendant and Third Party Defendants never intended to honor.
108. Counter Defendant and Third Party Defendants made their representations to Third Party Plaintiff Biotech recklessly and negligently without regard as to their truth as positive factual assertions. Further, Counter Defendant and Third Party Defendants negligently omitted to state a material fact, i.e., the lawsuit filed against them by Data Evolution, attached hereto as Exhibit F and incorporated herein by reference, had been filed at the time Counter Defendant and Third Party Defendants were inducing Counter-Plaintiff Biotech to enter into the 504 transaction.
109. Counter Defendant and Third Party Defendants made their false representations with the intention that Third Party Plaintiff rely and act upon them, which caused Third Party Plaintiff to suffer damages in an amount in excess of the jurisdictional limits of this court.
COUNT FOURTEEN
SANCTIONS FOR FRIVOLOUS FILING OF PLEADINGS
110. Third Party Plaintiffs adopt and re-allege those allegations contained in the paragraphs above as if fully set forth herein.
112. Plaintiff Adam Barnett’s signature on the five Petitions constitutes a certification that he had read the pleading, and to the best of his knowledge, information or belief, formed after reasonable inquiry, that the Petition was not groundless, having a basis of law and in fact, and not brought in bad faith or for the purpose of harassment. Jones authored the words.
113. Plaintiffs Barnett and Jones knew, or should have known, that the causes of action asserted against Third Party Plaintiff Biotech and Third Party Plaintiff Houser individually are groundless, have no basis in law or in fact, and were brought in bad faith or for the purpose of defamation of Houser, harassment or worse a means to extort shares of BioTech or money from Houser and BioTech.
116. Pursuant to Rule 13 of the Texas Rules of Civil Procedure, Third Party Plaintiffs are entitled to recover appropriate sanctions as set forth in Rule 215.2(b) of the Texas Rules of Civil Procedure.
COUNT FIFTEEN
VIOLATION OF THE
SARBANES-OXLEY “WHISTLEBLOWERS” ACT
117. BioTech, Houser and Jacobs re-allege and incorporate by reference all allegations and facts previously set forth herein.
118. Barnett, Hamilton, Seminario and Jones have stated and re-stated countless false representations to this Court and the general public regarding this lawsuit and the actions of BioTech, Houser and Jacobs. Barnett, Hamilton, Seminario and Jones knew their allegations were false when they made them, or made them recklessly without any knowledge of the truth as positive factual assertions. Barnett, Hamilton, Seminario and Jones made their false representations with the intention that the general public and this Court would act adversely toward BioTech, Houser and Jacobs which has caused BioTech, Houser and Jacobs to suffer injury.
119. Specifically, in all 6 of Barnett’s complaints, Jones as a partner of Tipton & Jones law firm, as senior overseer of this lawsuit for and on behalf of Barnett has repeatedly misstated as “FACT” the following false statement to this Court and the general public:
“Paragraph 16, Sixth Amended complaint: “Houser’s statements in the November 23, 2005 Letter, unlawfully published to numerous third parties including, at a minimum, the ‘SEC-Enforcement Division, Washington, DC [and the] SEC-Enforcement Division, Fort Worth, TX,’ go beyond the pale of any rational person and are once again false, malicious, unconscionable, defamatory, and falsely disparaging.”
120. The Sarbanes-Oxley Act of 2002 (“the Act”), Public Law 107-204. was signed on July 30, 2002. The Act now codified at 18 U.S.C. §1514A specifically provides an employee (Houser) of a public company (BioTech) with several persons and offices to which he can submit a good faith report of corporate wrongdoing, including the Securities & Exchange Commission (SEC), and/or Congress. Under the Act, once a whistleblower report of alleged corporate misconduct is received, the corporation/employer, agents and related third parties (Barnett, Hamilton, Seminario, Jones & Turino) may not act in a retaliatory manner towards the reporter (Houser).
121. BioTech, Houser and Jacobs are complying fully under the Sarbanes-Oxley Act by forwarding a letter to the Securities and Exchange Commission regarding the activities of Barnett, Hamilton, Seminario, Jones & Turino. Counter Defendant and the Third Party Defendants have retaliated against the Counter-Plaintiffs for reporting the suspicious activity to the SEC by filing this civil lawsuit.
122. Third Party Plaintiffs have been damaged by the retaliatory acts of the Counter Defendants and Third Party Defendants and are eligible for actual and exemplary damages.
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Post by longterm on Sept 12, 2007 19:18:03 GMT -4
COUNT FIFTEEN
A. Application for Injunctive Relief
123. Barnett=s & Turino’s continued wrongful acts, including the acts done in furtherance of the conspiracy, the business disparagement of BioTech, the attempts to unlawfully manipulate the value of BioTech stock, and the conversion of BioTech stock, present a threat of immediate and irreparable harm to BioTech.[1]
124. More specifically, the sale of BioTech stock on the open market by Barnett and his co-conspirators will render it functionally impossible to return the converted property to BioTech.
125. The risk to BioTech is immediate and it has no adequate remedy at law. More specifically, should Barnett continue his very public defamatory and disparaging statements against BioTech and Houser, BioTech would be immediately and irreparably harmed and would suffer grave damage to its business. Furthermore, BioTech fears that Barnett and his co-conspirators will continue to try to unlawfully manipulate the value of its stock and transfer the stock to third-parties on the open market.
126. The nature of Counter-Defendant’s actions, combined with the irreparable and immediate nature of the damage being suffered by BioTech mandate the invocation of the Court=s equitable power and the entry of immediate relief.
127. Houser and BioTech ask that this Court enter a temporary restraining order directing Barnett and Turino and all other persons, firms, and entities acting directly or indirectly or on behalf of them or who are in concert with them from continuing to commit the acts complained of in this Petition. Specifically, Houser and BioTech seek the entry of a temporary restraining order enjoining Barnett from:
a. posting messages regarding Houser, BioTech or BioTech=s employees, shareholders, customers or related business entities, on any public Internet forum;
b. selling or attempting to sell, transfer, manipulate (including but not limited to) controlling the “Bid” and/or “Ask” of the stock via any brokerage firm and/or firms and/or market makers, investor relations party and/or persons, anywhere in the world or otherwise change the status of any BioTech stock held, controlled, overseen by them, or any other entities acting in concert with them and/or other entities known by Barnett, Seminario and/or Hamilton Holdings to be controlling the “Bid” and/or “Ask” of BTME shares in the marketplace;
c. selling or attempting to sell (including short selling) securities or other interests in BioTech;
d. contacting in any manner, including but not limited to: telephone; personal contact; facsimile transmission; mail; or, internet posting; Houser, Houser’s spouse, BioTech or BioTech=s employees, shareholders, customers or related business entities, save and except contact through their legal representatives;
e. Destroying any document and computer records in their possession, custody or control which relate in any way to the factual allegations contained herein or related thereto.
128. It is probable that Houser and BioTech will recover from Barnett after trial on the merits.
129. There is not enough time to serve notice on Barnett and to hold a hearing on this application based on the past activities of the parties involved, and it is Houser and BioTech=s belief that were Barnett given notice of a hearing for injunctive relief, he and his co-conspirators would amplify the harassment of BioTech and Houser and/or attempt to sell whatever remains of the 12.75 million shares of BioTech stock or any portion thereof currently in their possession.
B: Application for Temporary Injunction
130. Houser and BioTech further request the Court to set their application for temporary injunction for a hearing and, after the hearing, issue a temporary injunction against Barnett.
C: Request for Permanent Injunction
131. Houser and BioTech ask the Court to set their request for a permanent injunction for a full trial on the merits and, after the trial, issue a permanent injunction against Barnett.
WHEREFORE, KEITH HOUSER and BIOTECH MEDICS, INC. defendants and counter-claimants, request that ADAM BARNETT be cited to appear and answer, and that on final trial, Third Party Plaintiffs have the following:
1. Temporary Restraining Order.
2. Temporary Injunction.
3. Permanent Injunction.
4. Judgment against Adam Barnett for their pecuniary damages in an amount within the jurisdictional limits of the Court.
5. Exemplary damages.
6. Pre-judgment interest as provided by law.
7. Post-judgment interest as provided by law.
8. Cost of suit.
9. Such other and further relief to which Third Party Plaintiffs may be justly entitled.
Respectfully submitted,
L.S._/s_________________________
David F. Morris
State Bar No. 14476500
14785 Preston Road, Suite 550
Dallas, Texas 75254
Telephone: 972-789-5122
Fax: 972-789-5123
ATTORNEY FOR DEFENDANTS AND THIRD PARTY PLAINTIFFS
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Post by mineralsrus on Sept 12, 2007 19:26:15 GMT -4
And the plot thickens!
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Post by longterm on Sept 12, 2007 19:26:45 GMT -4
ragingbull.quote.com/mboard/boards.cgi?board=BTMD&read=145BioTech Medics Inc (OTCF: BTMD) BTMD Quote | BTMD Msg Board | BTMD LiveCharts | BTMD Chart | BTMD News | BTMD Company Info | BTMD Insider | BTMD Analyst Recs | BTMD Top Holders « BTMD Message list | Reply to msg. | Post new msg. « Older | Newer » By: jcline 29 Oct 2004, 07:09 PM EDT Msg. 145 of 14413 Jump to msg. # Do I smell TOAST? )) - - - - - View Replies »
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Post by longterm on Sept 12, 2007 19:27:12 GMT -4
Nope...you're smelling your pump farts
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Post by longterm on Sept 12, 2007 19:36:10 GMT -4
Here's one of the first BTMD pumpers....and look at the other stocks he was pumping away at the same time...
Floor_Specialist
All Postings Last 30 posts on all boards » Posts by ticker Board Symbol Total Posts Serac Holdings Inc SRCI 13 (last 30) CMKM Diamonds Inc CMKX 10 (last 30) US Canadian Minerals Inc USCA 7 (last 30) (null) CBLH 6 (last 30) (null) NNOS 4 (last 30) OMDA Oil & Gas Inc OMOG 3 (last 30)
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Post by longterm on Sept 12, 2007 19:46:42 GMT -4
Uhghhhh Truffles....fat hack attorney's usually do DD before they invest. You mysteriously end up disappearing when the scam is exposed. Throw in ECNI where you issued some fluff PR's, your CSHD holdings which is linked to BBAN and Urban's dumping with Stocklein's "aid"...all headed back to CMKX--->directly related to PCBM-->back to the Econnect days. Nice one fatty. By: andy_dufrense 14 Nov 2004, 04:06 PM EST Msg. 834 of 14414 (This msg. is a reply to 831 by webmoney.) Jump to msg. # Stocks I invested in.. that I went on the chatboards to giv e positive feedback... DNAP.. bought in at .02 and sold at .13 ECNI.. bought in at .10 and sold at $5.00 PCBM.. bought in at .02 and sold (partial) at .23 ONMC.. bought in at.003 and sold at .012 CBLH.. bought in at .02 and is currently at .25 Many stocks I have told about were longer plays, like CBLH and others were short run plays, like ONMC or IVSO... If I tell people about a stock tip I have and it doubles, if the people do not get out to at least cover their investment, that is their fault. Everyone of those stocks allowed for huge profits ...taking them are the responsibility of the investor... I gave them the good stock tip, do I have to hold their hands the entire way through? Just because the bashers are too stupid to take profits and not attack me out of bitterness, that is their own fault .. ragingbull.quote.com/mboard/boards.cgi?board=BTMD&read=834
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Post by longterm on Sept 12, 2007 19:49:54 GMT -4
Anyone recognize this posting tactic?
By: IBAFT $$$$$ 27 Feb 2001, 01:19 PM EST Msg. 242707 of 723869
Folks.. this is our one chance to own the MM's
Just hang in there.. do not sell.. the MM's have all of these bashing Elgindyswine out in incredible force today in an effort to destroy this stock. They are scared to death of the solidarity on this board. Hold tight and we will see many dollars on this stock!! Go baby go!!! MM.s eat sjit!
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Post by longterm on Sept 12, 2007 19:52:09 GMT -4
This was from PCBM and this fat slob was bugging Frizzle in the not too recent past.
IBAFT $$$$$ 23 Feb 2001, 12:42 PM EST Msg. 232023 of 762290
NOTHING BUT UPSIDE..DON'T SELL ON THE DIPS..
THE MM'S ARE STILL SHORTING THE STOCK TO DRIVE THE PRICE DOWN TO SCARE YOU INTO THINKING THAT IT WILL DROP THROUGH THE FLOOR. SIMPLE FACTS TO CONSIDER:
1. PCBM HAS BEEN RADICALLY SHORTED, IN AN AMOUNT ESTIMATED TO BE ABOUT 300-500 MILLION...
2. THERE WILL BE ONLY ABOUT 30-50 MILLION ACTUAL, CERTIFICATE-BACKED SHARES AVAILABLE ...
3. IF THE MM'S AND BROKERAGE HOUSES DO NOT POSSESS ACTUAL CERTIFICATE-BACKED SHARES BY THE DIVIDEND DATE (MARCH 2, OR WHATEVER GRACE PERIOD AFTER THAT DATE), THEY WILL NOT BE ABLE TO DELIVER THE DIVIDEND TO THE SHAREHOLDERS. THEREFORE, THEY HAVE TO BUY THROUGH ALL THE CYBER-SHARES FIRST TO GET TO THE CERTIFICATE-BACKED SHARES.
4. SUPPLY AND DEMAND EQUATION TO CONSIDER: IN A MATTER OF DAYS THE MM'S HAVE TO COVER HUNDREDS OF MILLIONS OF SHARES, PLACING A RADICAL DEMAND ON THIS STOCK. IF YOU DO NOT SELL, WE HAVE THE POWER IN OUR HANDS TO SEND THE STOCK AS HIGH AS WE WANT! THE MM'S HAVE TO PAY WHATEVER WE HOLD OUT FOR OR FACE THE POTENTIAL OF NOT BEING ABLE TO DELIVER A DIVIDEND.
5. FACT: WE OWN THE MM'S RIGHT NOW. THIS IS A GOLDEN OPPORTUNITY TO TEACH THOSE SCUMBAGS A LESSON THEY WILL NEVER FORGET!
HOLD ON TIGHT.. DO NOT SELL!!!! CONSIDER AN EXIT STRATEGY OF SMALL PORTIONS FIRST BUT NOT TOO EARLY. LAUGH AT THE LOSER BASHERS... THEY ARE DESPERATE AS ARE THEIR BOSSES.. HAHAHAHA WE OWN THEM.... FOR ONCE.. WE ARE BACK IN CONTROL!!!
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