I was asked to post this. It looks pretty in
Post# of 39368
From: GENEPASTE@aol.com
To: genepaste@aol.com
Sent: 7/3/2012 11:01:21 A.M. Eastern Daylight Time
Subj: TREATY LEGAL SUITES
EASTERN DISTRICT OF LOUISIANA
TREATY ENERGY CORPORATION, *
* CIVIL ACTION
Plaintiff, * NO. 2:11-cv-01314
*
VERSUS * SECTION “J ”
* Judge Carl J. Barbier
JOHN DOES 1-7, *
* MAG. DIV. 5
Defendants. * Magistrate Judge Alma L. Chasez
*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"*"!
!!
SECOND AMENDED AND SUPPLEMENTAL COMPLAINT
NOW INTO COURT, through undersigned counsel, comes plaintiff Treaty Energy
Corporation (“TECO”), which respectfully amends and supplements its original Complaint filed
in this matter on June 2, 2011, as well as its First Amended and Supplemental Complaint filed on
December 21, 2011, as follows:
1. By amending Paragraph 2 of the Complaint and First Amended and Supplemental
Complaint to state as follows:
“2.
Defendants John Does 1-11 are persons of the full age of majority whose identity is not
presently known to plaintiff. Upon information and belief, none of these defendants is a resident
of the State of Louisiana.”
2
2. By adding the following paragraphs after the new Paragraph 34(h) of the
Complaint and First Amended and Supplemental Complaint to state as follows:
“34(i).
Defendant John Doe 10 aka “geopressure” has posted a number of defamatory comments
on iHub concerning TECO, its officers, and employees. In one post dated May 14, 2012,
“geopressure” suggests that TECO’s Co-CEO has a “drug dealer” and has paid another iHub
poster to “promote [his] stocks & lie about them when necessary…”, which is categorically false.
34(j).
In a post dated May 27, 2012, “geopressure” proclaims that TECO’s Co-CEO “chose to
intentionally mislead shareholders” in company press releases and that TECO’s “management”
attempted to “cover up” a “fraudulent discovery” in violation of federal securities regulations, all
of which is also false.
34(k).
In that same post, “geopressure” states that TECO’s Co-CEO sabotaged the company’s
logging operations in order to “avoid[] a Federal Prison sentence for Securities Fraud”, which is
likewise false, and that there’s a “high probability” that he “ends up spending a few years in
Federal Prison after this is all said & done…”
34(l).
Defendant John Doe 11 aka “tdbowieknife” also has posted a number of defamatory
comments on iHub concerning TECO, its officers, and employees. In one post dated June 20,
2012, “tdbowieknife” falsely claims that “these guys are collaborating in a scheme to defraud
investors.”
3
34(m).
The following day, June 21, 2012, “tdbowieknife” incorrectly reported that TECO’s Co-
CEO was “barred … from associating in any capacity with any FINRA/NASD member firm due
to his conversion of customer funds.”
34(n).
A few minutes later, “tdbowieknife” posted on iHub that TECO’s CEO “was found to
commit fraud in a very similar way that [TECO’s other Co-CEO] is now being accused”, which
is also false.
WHEREFORE, plaintiff Treaty Energy Corporation respectfully prays for all relief
requested in its original Complaint and First Amended and Supplemental Complaint, a judgment
in its favor and against John Does 1-11, and all other equitable relief to which it is entitled.
Respectfully submitted,
________________________________________
Andrew L. Kramer, T.A. (La. Bar # 23817)
Binford E. Parker III (La. Bar # 31908)
201 St. Charles Avenue, Suite 2504
New Orleans, Louisiana 70170
Telephone: (504) 599-5623
Facsimile: (866) 667-3890
Email: akramer@kramerllc.com
tparker@kramerllc.com
Counsel for Plaintiff Treaty Energy Corporatio