I like that-the Baja 30-maybe they will be require
Post# of 8054
I like that-the Baja 30-maybe they will be required to walk the plank until they cough up whatever judgment is awarded to CWRN
Defendants in CWRN case against Geo et al in Calif-none have appeared-entry of default ca Dec 1 2012,hearing June 7 to what? -since defendants apparently not cooperating w discovery, either to compel production or enter default judgment-court has personal jurisdiction imo over those who signed any of the docs in Calif -if they have commingled, defendants may not be able to produce records or refuse to do so because incriminating-courts take commingling seriously-so does the bar and the relevant CPA associations
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.
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, co-conspirator,
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.
15. Defendants, and each of them, formed, conceived and operated a conspiracy
against Plaintiffs, and each of them. Said Defendants committed the acts alleged herein in
furtherance of their common design.
16. Plaintiff does not know the names, capacities, or bases of liability of the
defendants sued as Does 1 through 30....
17. Plaintiff is informed and believes and thereon alleges: at all times mentioned,
each of the defendants, including Does 1 through 30, inclusive, was and now is the agent..