FACTS RELEVANT TO COUNTERCLAIMS 84. Plaintiff dev

FACTS RELEVANT TO COUNTERCLAIMS
84. Plaintiff developed a scheme whereby it preys upon publicly trading companies in
desperate need of operating capital and makes usurious loans convertible into common stock .
85. Plaintiff set up its “loan arrangements” with defendant with the intent to convert the
defendant’s debt into publicly trading stock at a usurious rate of interest.
86. Plaintiff assured defendant that it would not convert defendants’ stock and would, rather,
work with defendant to avoid enforcing the illegal usurious terms of the agreement.
87. As a result of the subject loan agreement, plaintiff is attempting to usurp common trading
stock from the defendant and then, effectively, dump it into the market and drive the
price of defendant’s stock into near oblivion while enjoying substantial profit.


http://ypdcrime.com/penal.law/article190.htm#p190.42

S 190.42 Criminal usury in the first degree.
A person is guilty of criminal usury in the first degree when, not
being authorized or permitted by law to do so, he knowingly charges,
takes or receives any money or other property as interest on the loan or
forbearance of any money or other property, at a rate exceeding
twenty-five per centum per annum or the equivalent rate for a longer or
shorter period and either the actor had previously been convicted of the
crime of criminal usury or of the attempt to commit such crime, or the
actor`s conduct was part of a scheme or business of making or collecting
usurious loans.
Criminal usury in the first degree is a class C felony.