And these are CWRN's RICO causes of action against Geo

New Post Public Reply Private Reply Replies (0) Message Board
microcaps microcaps #5612
And these are CWRN's RICO causes of action against Geo alleging criminal activity, which the govt may be interested in (emphasis is mine)

SEVENTH CAUSE OF ACTION
RICO Violation U.S.C. 6 1962(c)

74. Plaintiffs re-allege and incorporate herein Paragraphs 1- 73 above.
75. Defendants, and each of them, have violated the federal Racketeer Influenced and
Corrupt Organizations Act ("RICO"), specifically, the provision codified at 18 U.S.C. § 1962(c).

76. Defendants operate a RICO enterprise. MUI and YEE, together with each the
other defendants with whom they are separately related, have formed an association in fact and
upon information and belief all Defendants are associated with the criminal enterprise.
Defendants had and have a pre-existing and ongoing relationship which extends beyond their
unlawful behavior. The RICO enterprise has an identifiable structure, in that MUI and YEE, and
COMPLAINT
Page 18 of 28 Pages

each of their related companies, are based on information and belief, partners in the enterprise of
defrauding people such as investors and mining owners, and partners in other activities, lawful
and unlawful. Upon information and belief, MUI and YEE are, and at all times relevant have
been, in communication with each other discussing and plotting strategies for the scheme and
carrying out in concert with each other for joint benefit. Upon information and belief, MUI and
YEE have shared the fruits of their scheme, including the monies which investors paid them and
the monies that are owing to Plaintiffs from pledged capital contributions and proceeds of sale of
ore produced by Plaintiffs from mining operations. The enterprise is also embodied in the
fraudulent scheme detailed in this complaint. The RICO enterprise may, upon information and
belief, also operate under the name TMT GLOBAL CORP and JWT TRADING CORP . The
criminal enterprise operates in interstate commerce, as evidenced above.

77. MUI and YEE, separately and together with each of the other Defendants with
whom they are separately related, have jointly engaged in a pattern of racketeering activities in
that each has committed two or more RICO predicate acts , within the last ten (10) years.
Specifically, upon information and belief, and without limitation, MUI and YEE have each,
within the last ten (10) years committed two or more acts of wire fraud in violation of 18 U,S,C,
§ 1343, and upon informal and belief, one or both MUI and YEE have traveled Interstate to
facilitate the scheme in violation of 18 U.S.C. 1952.

78. Plaintiffs are not the only victims of said Defendants' criminal enterprise. On
information and belief, there are other victims of Defendants' fraudulent conduct, including
without limitation, (a) Defendants MUI and YEE, representing that they were raising funds for
direct investment into the Joint Venture, sold their personal stock in GEOTECH to investors, and
failed to invest said funds into the Joint Venture based on their claim that they sold personal
stock in GEOTECH and not treasury stock, (b) without the knowledge of investors who
purchased GEOTECH stock from MUI and YEE, MUI and YEE loaned funds they received
from the sale of their stock back to GEOTECH, charging interest on these loans to GEOTECH
and to the investors, while also allegedly loaning a portion of these funds to the Joint Venture
rather than investing funds as capital contributions in the Joint Venture, (c) MUI, YEE and
COMPLAINT
Page 19 of 28 Pages

GEOTECH charged both investors and the Joint Venture with interest on their alleged loans and
repaid themselves for these alleged loans from gross sales receipts of Joint Venture ore, (d) MUI,
YEE and GEOTECH have allegedly failed to pay corporate expenses and structured litigation
through others to sue the investors individually, who bought GEOTECH stock from MUI and
YEE, to pay these GEOTECH corporate obligations, (e) created one or more foreign
corporations allegedly to transfer equipment to the Joint Venture, collected repayment for their
alleged investment of equipment in the Joint Venture in violation of the JVA provisions, failed
to effect the transfer of title from the foreign corporation to PAN AM or to the Joint Venture,
then demanded through the foreign corporation that was not a party to the JVA , for PAN AM to
return the equipment, (f) created foreign corporations to receive letters of credit for Joint Venture
transactions to create false invoices and charges for services rendered to the Joint Venture by
others, (g) substantially overpaid for standard services such as brokerage, shipping, agency fees,
and transport fees, in order to receive portions of the amounts collected from the respective
purveyors of services allegedly rendered to the Joint Venture, (h) routinely overstated costs and
expenses and paid themselves and affiliates for these costs from Joint Venture funds, (1)
siphoned funds from GEOTECH owing to investors for their personal obligations, (j)
represented personal obligations as corporate or business obligations to investors, shareholders,
lenders, and partners and paid these obligations with funds legally owed to others.

79. Due to Defendants' operation of their criminal enterprise and/or their commission
of crimes which are predicate acts under the RICO statute, Plaintiffs, and each of them, have
been harmed and injured in at least the amounts and bases set forth above, for which Defendants
are jointly and severally liable.

80. The foregoing conduct by Defendants, and each of them, was fraudulent,
malicious and oppressive, and each Plaintiff is entitled to recover punitive damages In the
amount of at least $5,000,000.00 against each of the Defendants, respectively.

81. Plaintiffs, and each of them, are each entitled to recover treble [triple] damages against
Defendants, and each of them, in amounts according to proof, for which Defendants are jointly
and severally liable .
COMPLAINT
Page 20 of 28 Pages

82. Plaintiffs are also entitled to recover reasonable attorneys' fees, investigation,
litigation-related expenses in an amount subject to proof.

EIGHTH CAUSE OF ACTION
Conspiracy To Violate RICO (18 U.S.C. § 1962(d))

83. Plaintiffs re-allege and incorporate -herein Paragraphs 1 - 82 above.
84. Defendants, and each of them, have violated the federal Racketeer Influenced
Corrupt Organizations Act ("RICO"), specifically, the provision codified at 18 U.S.C. § 1962(d)
in that each has conspired with the other to violate RICO (specifically, to violate 18 U.S.C.
10 § 1962(c)).

11 85. Due to the conspiracy of defendants, and each of them, to violate the RICO
statute, Plaintiffs have been damaged in an amount according to proof at trial, not less than
$1,500,000.00 , plus interest thereon at 10% per annum from each transfer date through August
24, 2012, with interest continuing to accrue.

86. The foregoing conduct by Defendants, and each of them, was fraudulent,
malicious and oppressive, and each Plaintiff is entitled to recover punitive damages [above and beyond actual damages] in the
amount of at least $5,000,000 against each of the Defendants, respectively .

87. Plaintiffs are also entitled to recover reasonable attorneys' fees, investigation and
litigation-related expenses in an amount subject to proof.

Cotton & Western Mining Inc. (CWRN) Stock Research Links

CWRN Board Company Profile Buy Rating Time & Sales News Filings Financials
Scroll down for more posts ▼

Top 10 Most Recent News Articles

UWM Faces Class Action Deadline: Key Insights for Investors

Updated Category News Views 3

The High Stakes Reality for UWM Investors If there's one thing that's certain in this jittery world of investing, it's that losses have a way of waking you up. Right now, anyone tied up with UWM Holdings Corporation (NYSE: UWMC) shares needs to keep their wits about them; we're barreling toward an October 13, 2026 deadline for a class action lawsuit. The clock's ticking...

Continue Reading
First-Time Homeowners: Unseen Pitfalls of Insurance

Updated Category News Views 6

Understanding Homeowners Insurance: Beyond the Basics Most folks diving into homeownership for the first time get caught up in the whirlwind of price tags, loans, and knick-knacks for their new place. Meanwhile, the nitty-gritty of homeowners insurance often gets tossed to the side. But take it from a weary watchdog of financial storms—it’s those details in the policy...

Continue Reading
Ris-Rez May Set New Standard in Relapsed SCLC

Updated Category News Views 7

The Game-Changing Results Innovation in pharmaceuticals sometimes feels like a waiting game, but when a fresh breakthrough like this rolls in, it lights up the whole landscape. Risvutatug rezetecan, or Ris-Rez for short, has shown promising potential in the fight against relapsed small-cell lung cancer (SCLC) that has progressed after platinum-based therapy. Survival...

Continue Reading
GORGIE Unleashes Berry Burst: Target's New Drink Star

Updated Category News Views 6

GORGIE Targets Taste Buds with Berry Burst Ever feel like you're missing out on that energy drink everyone seems to be raving about? Well, GORGIE's out there making some noise again, and this time it's got a new punchy player in the game: Berry Burst. It's not just another drink; it's shaking things up in the energy aisle with its exclusive launch at Target. Modern style...

Continue Reading
Tam-Peli Steps Up in SCLC Battle: Trial Insights

Updated Category News Views 5

Noteworthy Developments in Small-Cell Lung Cancer Treatment Let's dive into a story straight from the world of small-cell lung cancer (SCLC) that doesn't take any prisoners. The antidote making waves is tambotatug pelitecan, or Tam-Peli for short, showcasing its might in the unrelenting fight against relapsed SCLC. The phase III TAISHAN-302 trial puts Tam-Peli...

Continue Reading
Regeneron Faces Legal Heat: Lead Plaintiff Deadline Looms

Updated Category News Views 6

Regeneron’s Tight Spot: Legal Showdown Well, here we go again—Regeneron Pharmaceuticals (NASDAQ:REGN) is under some serious heat. If you're an investor who faced significant losses with this biotech juggernaut, remember that the clock’s ticking down to the wire. By tomorrow, September 14, 2026, you need to decide if you're going to throw your hat in the ring for...

Continue Reading
Trial Disappointment: No Significant Gains in NSCLC

Updated Category News Views 21

Dissecting the Nuances of the EVOKE-03/KEYNOTE-D46 Trial Every once in a while, we come across a trial that rattles cages in the research community. Today, it's the EVOKE-03/KEYNOTE-D46 trial, a collision of hope and hard-knock reality. This Phase 3 trial, which sought to explore the potential combo of sacituzumab govitecan (SG) and pembrolizumab on metastatic non-small...

Continue Reading
Surfing Dogs Ride Waves, Support Orphan Pets

Updated Category News Views 3

Waves, Paws, and Passion Who would've thought that dogs catching waves could also catch hearts and wallets? Well, that's exactly what's happening today at Del Mar Dog Beach with the 21st Annual Surf Dog Surf-A-Thon revving up the excitement. It's a sun-soaked day in Rancho Santa Fe, California, right in the thick of things at the longest-running dog surf competition. For...

Continue Reading
PANDAG G1 Debuts: Revolutionizing Lawn Care Efficiency

Updated Category News Views 6

The Future of Landscaping Unveiled Get this—PANDAG is set to shake things up at GaLaBau 2026 with their futuristic G1 autonomous mower. This isn't just another piece of lawn equipment; it's practically a tech marvel on wheels, weaving together LiDAR, AI Vision, RTK, and 4G tech to make it the ultimate multitasker for the landscaping industry. We're talking obstacle...

Continue Reading
PwC US and India Unite for Global Consultancy Powerhouse

Updated Category News Views 7

Rearranging the Consultancy Chessboard Piling onto the game of consultancy realignments, PwC just made a move reminiscent of playing strategy poker. They're tossing together PwC US and PwC India's advisory capabilities for a new joint venture. It’s like pushing two puzzle pieces to make a single colorful picture that stretches from the U.S. all the way to the...

Continue Reading

Top 5 Most Recently Viewed Articles

Major Refinancing Deal in Multifamily Sector by Newmark Group

Updated Category News Views 168

Newmark Group Secures $690 Million for West Shore Portfolio Newmark Group, Inc. (NASDAQ: NMRK), a prominent name in commercial real estate advisory, has successfully arranged a substantial $690 million loan aimed at refinancing a diverse collection of 13 multifamily properties owned by West Shore. These properties are located in several states, including vibrant areas...

Continue Reading
MassageLuXe Expands Its Relaxation Services in Grand Rapids

Updated Category News Views 193

MassageLuXe Expands Its Relaxation Services in Grand Rapids MassageLuXe, a leading spa franchise known for its exceptional massage, facial, and waxing services, is gearing up to enhance wellness offerings in the Grand Rapids area. This strategic initiative marks the company's intent to further establish its footprint in Michigan's second-largest city, driven by the...

Continue Reading
Taylor Heise Joins Upper Deck: A Milestone in Women's Sports

Updated Category News Views 454

Taylor Heise Joins Upper Deck's Elite Team of Athletes Leading the charge in the realm of sports collectibles, Upper Deck recently announced an exciting partnership with Taylor Heise, a standout player in the Professional Women's Hockey League (PWHL). This collaboration highlights the growing prominence of women athletes in sports collectibles, specifically with Heise,...

Continue Reading
Eminent Gold Strengthens Team with Ivan Bebek's Expertise

Updated Category News Views 81

Eminent Gold Welcomes Ivan Bebek as Strategic Advisor Eminent Gold Corp. (TSXV: EMNT) (OTCQB: EMGDF) is making headlines with the recent appointment of Ivan Bebek as a Strategic Advisor for Corporate Development and Finance. This strategic move aims to bolster the company's efforts in identifying and advancing new gold discoveries in Nevada. Ivan Bebek: A Wealth of...

Continue Reading
B. Riley Financial Plans Hearing for Nasdaq Compliance Status

Updated Category News Views 167

Understanding B. Riley Financial's Nasdaq Situation B. Riley Financial, Inc. (Nasdaq: RILY) has announced a significant event regarding its listing status on the Nasdaq exchange. The company received a Staff Determination Letter from the Nasdaq Listing Qualifications Staff, pointing out non-compliance issues that date back to earlier notifications. These notifications...

Continue Reading