From CWRN's complaint COMPLAINT Page 3 of 28 Pages

From CWRN's complaint

COMPLAINT
Page 3 of 28 Pages
FACTS -[as alleged-unaltered except I added paragraph spacing in places to aid reading and included a very small amount of bracketed explanatory material as per convention]

"18. The representations by Defendants [Geo et al] to Plaintiffs [CWRN et al] were made during numerous
meetings in 2010, 2011, and 2012, in Nevada, California, USA and Baja California, Mexico, and
during numerous telephone conversations and emails while Plaintiffs were in Nevada,
California, and Mexico and Defendants were in New York, California and Mexico.

19. In or about early in the year 2010, Robert Cotton and Sharon X-caret Vasquez
Monroy were introduced to Edward MUl and Jimmy YEE, by Shirley Lee.

20. In or about early through mid-2010, Plaintiffs, through their representatives,
discussed potentials for MUI and YEE to become joint venture partners in the mine controlled
and operated by Plaintiffs, known as "'Mina Guadalupe", in Baja California, Mexico, under a
mining royalty agreement held by Plaintiffs with the concession owner, and in an a mining
concession being pursued by Plaintiffs known as "El Tepustete" also located in Baja California,
Mexico. TMT GLOBAL and JWT TRADING were never mentioned during these discussions.
The only corporation identified by MUI and YEE during this period was GEO J.S. TECH
GROUP, INC.

21. On or about May 7, 2010, defendants agreed to invest the sums of $100,000.00 in
exchange for security provided by plaintiffs in the amount of 50 million shares of Cotton &
Western Mining Inc ("CWRN") common stock to be held as security, and $150,000.00 in
exchange for receipt of an additional 50 million CWRN common shares as security, locked for
90 days from receipt. At the time of defendants' investment and delivery of the common shares,
50 million shares were publicly trading at a value of approximately $250,000.00 (between .0041
and .0058 per share, or a blended rate of approximately .005 per share). In short, the value of
the security provided to defendants in exchange for $250,000.00 in investment was
approximately $500,000.00 in securities. Plaintiffs were unaware of the existence of JWT
TRADING until YEE provided a check drawn on an account in the name of that corporation.

22. Further, on or about May 7, 2010, defendants agreed to provide an additional
capital contribution of not less than $1,000,000.00 to PAN AM together with the promise to
provide specific equipment of undetermined value.
COMPLAINT
Page 4 of 28 Pages

23. A copy of the written agreement between plaintiff, PAN AM, and defendant,
GEOTECH, entitled Memorandum of Understanding (MOU) and dated May 7, 2010, is attached
hereto as Exhibit A and made a part hereof.

24. A copy of defendant JWT TRADING CORP's HSBC check # 1020 payable to
Pan American Mineral Ventures, LLC, in sum of $100,000.00 and Cotton & Western Mining,
Inc stock certificate provided to defendants for 50 million shares of common stock are attached
hereto as Exhibit B and made a part hereof.

25. As of September 21, 2010, defendants had contributed only the sum of
$500,000.00, secured by 100,000,000 shares of CWRN common stock, and plaintiffs had
become doubtful about whether defendants possessed the financial viability they claimed.

For that reason, PAN AM and GEOTECH entered into a Farm-In Security Agreement dated
September 21, 2010, wherein it was agreed that if GEOTECH failed to provide sufficient capital
for PAN AM to complete project financing through the first shipment of ore from the Guadalupe
mine, GEOTECH would be entitled to only 150% of its cash investment and a rental value for
specific equipment for the period the specific equipment was used by PAN AM at the mine site.
A copy of the Farm-In Agreement between PAN AM and GEOTECH dated September 21, 2010,
is attached as Exhibit C and made a part hereof.

26. Shortly after defendant GEOTECH and plaintiff Pan Am executed the Farm-In
Agreement, GEOTECH represented that it was financially able to provide financing for the
Guadalupe mine operation, and to provide specific equipment for use of mining operations, and
requested that the parties enter into a Joint Venture Agreement (JVA) as referenced in the MOU,
presenting an agreement drafted by its legal counsel. Plaintiffs, without the assistance of legal
counsel, made certain suggested modifications to the draft JVA provided by defendants, the JVA
was again modified by defendants' legal counsel, and provided to PAN AM for signature
approval.