from CWRN's complaint against Geo filed 9-5-12 in CA
32. Plaintiffs are informed and believe that GEOTECH has sold the CWRN common
18 stock provided to GEOTECH as security for its investment for sums possibly greater than the
19 total amount of defendants' investment in the Joint Venture. Moreover, the warrant/option
20 obtained by defendants as additional security for the investment, which was redeemed by
21 Defendants at $0.005 per share, traded between May 5, 2010 and April 6, 2011, at between
22 approximately $0.005 at start and up to over $0.0265 per share. The potential return to
23 Defendants from trading 150,000,000 shares of CWRN common stock that was to be held as
24 security for the invested funds, if traded at $0.0265 per share, could have provided
25 $5,300,000.00 to Defendants. Plaintiffs have requested an accounting from Defendants
26 regarding any CWRN shares that were sold by Defendants, but Defendants have failed and
27 refused to provide such an accounting.
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32. Plaintiffs are informed and believe that GEOTECH has sold the CWRN common
18 stock provided to GEOTECH as security for its investment for sums possibly greater than the
19 total amount of defendants' investment in the Joint Venture. Moreover, the warrant/option
20 obtained by defendants as additional security for the investment, which was redeemed by
21 Defendants at $0.005 per share, traded between May 5, 2010 and April 6, 2011, at between
22 approximately $0.005 at start and up to over $0.0265 per share. The potential return to
23 Defendants from trading 150,000,000 shares of CWRN common stock that was to be held as
24 security for the invested funds, if traded at $0.0265 per share, could have provided
25 $5,300,000.00 to Defendants. Plaintiffs have requested an accounting from Defendants
26 regarding any CWRN shares that were sold by Defendants, but Defendants have failed and
27 refused to provide such an accounting.
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