this is the part of CWRN's complaint-sec 32-that explains how shareholders might benefit from the CA case
I havent added up the punitive damages
count 1 complaint asks 10 M (million) for each # (plaintiff-Bob sharon shirley Cwrn or PanAm) against each defendant(^) -Geo, jimmy ,TMJ etc -there are also the baja 30 john and jane does
count 2 asks 5M for EACH # against EACH ^(defendant)
count 3 5M ...same as above " "
count 4 5M ......................
5 undetermined
6 ca 1.2 million actual
7 each # 5M agst each ^
sec 81 treble damages under RICO
8 RICO actual 1.5M plus, plus each # 5M agst each ^ plus att fees and costs
9 each # 5M agst each ^
10 trust
11 each # 5M agst each ^
12 injunctive relief
13 asks Geo to be required to account for all monies
even discounting the infamous baja 30, these could add up to 100's of millions actual and punitive damages but are usually maximum statutory etc amounts,and of course the problem of collecting
sec 31 and 48 Bob et al begin asking for amounts,including punitive damages of 5-10 million on some of the 13 causes of action
The following sec is of special interest to stockholders
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.
28
[stock sold as high as .0315 and I bought some above .0265]
13. Plaintiff is informed and believes and thereon alleges: TMT GLOBAL, JWT
TRADING, GEOTECH, MUI and YEE are and at all times relevant have been alter egos of
each other, there is and at all times relevant was a unity of interest and ownership among them,
they commingled funds, they disregarded corporate formalities and separateness, the entities
were undercapitalized for their purposes and activities, they passed monies back and forth
between accounts and diverted funds from one entity to the other, and from each entity to each
person, and it would constitute an injustice for this Court not to disregard the separateness of
each.
14. Plaintiff is informed and believe and thereon alleges: at all times alleged herein,
each of the defendants was the agent, principal, affiliate, representative, co-venturer, coconspirator,
joint venturer, alter ego and/or partner of each of the other defendants, and in doing
the acts hereinafter alleged, was acting within the scope of such relationship and with the
permission, consent and/or ratification of his, her or its co-defendants.
I havent added up the punitive damages
count 1 complaint asks 10 M (million) for each # (plaintiff-Bob sharon shirley Cwrn or PanAm) against each defendant(^) -Geo, jimmy ,TMJ etc -there are also the baja 30 john and jane does
count 2 asks 5M for EACH # against EACH ^(defendant)
count 3 5M ...same as above " "
count 4 5M ......................
5 undetermined
6 ca 1.2 million actual
7 each # 5M agst each ^
sec 81 treble damages under RICO
8 RICO actual 1.5M plus, plus each # 5M agst each ^ plus att fees and costs
9 each # 5M agst each ^
10 trust
11 each # 5M agst each ^
12 injunctive relief
13 asks Geo to be required to account for all monies
even discounting the infamous baja 30, these could add up to 100's of millions actual and punitive damages but are usually maximum statutory etc amounts,and of course the problem of collecting
sec 31 and 48 Bob et al begin asking for amounts,including punitive damages of 5-10 million on some of the 13 causes of action
The following sec is of special interest to stockholders
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.
28
[stock sold as high as .0315 and I bought some above .0265]
13. Plaintiff is informed and believes and thereon alleges: TMT GLOBAL, JWT
TRADING, GEOTECH, MUI and YEE are and at all times relevant have been alter egos of
each other, there is and at all times relevant was a unity of interest and ownership among them,
they commingled funds, they disregarded corporate formalities and separateness, the entities
were undercapitalized for their purposes and activities, they passed monies back and forth
between accounts and diverted funds from one entity to the other, and from each entity to each
person, and it would constitute an injustice for this Court not to disregard the separateness of
each.
14. Plaintiff is informed and believe and thereon alleges: at all times alleged herein,
each of the defendants was the agent, principal, affiliate, representative, co-venturer, coconspirator,
joint venturer, alter ego and/or partner of each of the other defendants, and in doing
the acts hereinafter alleged, was acting within the scope of such relationship and with the
permission, consent and/or ratification of his, her or its co-defendants.
