CWRN complaint against Geo
Plaintiffs, COTTON & WESTERN MINING, INC. and PANAMERICAN MINERALS
so what is CWRN-for some purposes CWRN is the stockholders, but this is not a stockholder action, so as I said its whatever the judge decides upon whatever basis he decides it
defendants are highlighted below also,
FILED
Jeffrey L. Brown, Esq. [CWRN attorney]
2 SEP -5 FM 2:17
Brown & Farmer, A.P.L.C.
State Bar No. 65321
5520 Wellesley Street, Suite 204
'SAN DIEGO County
La Mesa, California 91942-4401
Telephone (619) 461-6511
Facsimile (619) 464-3824
Attorneys for Plaintiffs
SUPERIOR COURT OF THE STATE-OF CALIFORNIA
COUNTY OF SAN DIEGO, EAST COUNTY BRANCH
COTTON & WESTERN MINING, INCi; CASE NO.: 37-2O12.OOO69241-CU-FR-EC
PANAMERICAN MINERALS VENTURES
S.A. DE C.V., COMPLAINT for
Plaintiffs [CWRN],
1 Fraud - Intentional Misrepresentation;
2 Fraud - False Promise;
V. 3 Fraud in the Inducement;
4 Conversion;
GEO J.S. TECH GROUP, INC.; EDWARD 5 Breach of Contract;
MUI; JIMMY YEE; TMT GLOBAL CORP; 6) Breach of Written Contract;
JWT TRADING CORP., and DOES 1-30, 7) RICO Violation U.S.C. § 1962(c);
inclusive, 8 Conspiracy to Violate RICO;
9 Violation of Unfair Competition Law;
Defendants. 10) Imposition of Constructive Trust;
11 Unjust Enrichment;
12 Injunctive Relief;
13 Accounting and Restitution
Plaintiffs, COTTON & WESTERN MINING, INC. and PANAMERICAN MINERALS
VENTURES, S.A. DE C.V., allege as follows:
GENERAL ALLEGATIONS
1. At all times herein mentioned, PANAMERICAN MINERALS VENTURES S.A.
DE C.V. ("PAN AM"), plaintiff, is a corporation formed in Baja California, Mexico, with its
principal business office located at Blvd. Teniente Azuela No. 130 Int. 213, Ensenada, Baja
California, Mexico, and is a subsidiary of Cotton & Western Mining, Inc. U.S.A., through a
corporate consent resolution, and is a Trustee Company held in trust by officers and directors of
Cotton & Western Mining, Inc., a Nevada corporation.[ elsewhere says PanAM is a wholly owned corp-as I posted]
COMPLAINT
Page 1 of 28 Pages
2. COTTON & WESTERN MINING, INC. is a public company incorporated in the
State of Nevada.
3. Plaintiff is informed and believes and thereon alleges Defendant, GEO J.S.
TECH GROUP, INC. ("GEOTECH"), is a corporation formed in the State of Texas, and is not
registered to do business in California.
4. Plaintiff is informed and believes and thereon alleges: defendant, EDWARD
MUI ("MUI"), is the President, CEO, Director and Registered Agent for defendant, GEO J.S.
TECH GROUP, INC.
5. Plaintiff is informed and believes and thereon alleges: defendant, JIMMY YEE
("YEE"), is the Chairman, Chief Financial Officer, and Director of GEO J.S. TECH GROUP,
INC.
6. Plaintiff is informed and believes and thereon alleges: MUI, YEE, and Does 1
through 10, inclusive, have a present ownership interest in or to defendant, GEO J.S. TECH
GROUP, INC.
7. Plaintiff is informed and believes and thereon alleges: the defendants identified
herein as DOES 11 through 20, inclusive, are officers or directors of defendant, GEO J.S. TECH
GROUP, INC.
8. Plaintiffs are informed and believe a, •reon allege: TMT GLOBAL CORP
("TMT GLOBAL") is and at all times relevant • 'n or a fictitious business name
for EDWARD MUI and/or JIMMY YEE.
9. Plaintiff is informed and' dant, EDWARD
MUI ("MU]"), is the President, Director u „ TMT GLOBAL
CORP.
10. Plaintiff is informed and believes and th, defendant, JIMMY YEE
("YEE"), is the Vice President, Chief Financial Officer, and .tor of TMT GLOBAL CORP.
11. Plaintiffs are informed and believe and thereon allege: JWT TRADING CORP
("JWT TRADING") is and at all times relevant was a corporation or a fictitious business name
for JIMMY YEE.
COMPLAINT
Page 2 of 28 Pages
12. Plaintiff is informed and believes and thereon alleges: defendant, JIMMY YEE
("YEE") is the President, Chief Financial Officer, Director and Registered Agent for defendant,
JWT TRADING CORP.
TRADING, GEOTECH, MUI and YEE are and at all times relevant have been alter egos of
