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JOHN M. McCOY III, Cal. Bar No. 166244E-mail: [email protected] MATTESON, Cal. Bar No. 102103E-mail: [email protected] M. WHITE, Cal. Bar No. 171448E-mail: [email protected]
Attorneys for PlaintiffSecurities and Exchange CommissionRosalind R. Tyson, Regional Director5670 Wilshire Boulevard, 11th FloorLos Angeles, California 90036-3648Telephone: (323) 965-3998Facsimile: (323) 965-3908
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
SECURITIES AND EXCHANGECOMMISSION,
Plaintiff,
vs.
CMKM DIAMONDS, INC., URBANCASAVANT, JOHN EDWARDS,GINGER GUTIERREZ, JAMESKINNEY, ANTHONY TOMASSO,KATHLEEN TOMASSO, 1STGLOBAL STOCK TRANSFER LLC,HELEN BAGLEY, NEVWESTSECURITIES CORPORATION,DARYL ANDERSON, SERGEYRUMYANTSEV, ANTHONYSANTOS, and BRIAN DVORAK,
Defendants.
Case No. 2:08-cv-00437-LRH-RJJ
REPLY IN FURTHER SUPPORT OF MOTION BY PLAINTIFFSECURITIES AND EXCHANGE COMMISSION FOR SUMMARY
JUDGMENT AGAINST DEFENDANTS 1ST
GLOBAL STOCK TRANSFERLLC AND HELEN BAGLEY
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I. INTRODUCTIONDefendants 1
st
Global Stock Transfer LLC (1
st
Global) and its principal,Helen Bagley (Bagley) oppose the motion by Plaintiff Securities and Exchange
Commission (Commission) for summary judgment on several grounds, none of
which is sufficient to defeat the motion. First, they argue that the Commission
must show that the Defendants conduct is unreasonable, notwithstanding that
they are securities professionals, and Section 5 is a strict liability provision.
Second, they essentially argue that blind reliance on an attorneys opinion letters is
reasonable without establishing the elements for a reliance on professionals
defense, or addressing the undisputed facts presented by the Commission and
admitted to by Bagley. Specifically, notwithstanding the strict liability nature of a
Section 5 violation, Bagleys admissions establish the unreasonableness of her
conduct in simply taking the restrictive legends off the certificates based on
opinion letters by Defendant attorney Brian Dvorak (Dvorak). Bagley admits
that nothing this company [Defendant CMKM] did made sense to me, including
CMKMs assertion that it had failed to issue 279 billion of its purportedly
outstanding shares, that she may have wondered whether CMKMs assertion was
actually true, and that she did not feel comfortable with Dvorak but nevertheless
relied on his opinions, even though she thought it strange that CMKM had so many
shares. (See Statement of Facts filed by the Commission in support of its summary
judgment motion (Facts) (Docket No. 161-2) 46-47 & 49-50.)
Additionally, like Rumyantsev, Bagley attempts to persuade the Court that
there are genuine issues of fact by introducing facts purporting to show that there
are several bad acts she did notperform in connection with the offering. Like
Rumyantsev, however, she fails to cite to any authority which requires that the
Commission prove a particular set of facts in order to establish that she and her
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firm were necessary participants and substantial factors in the enormous
offering of unregistered CMKM stock, or that the undisputed facts are, as a matterof law, insufficient to establish her liability.
II. ARGUMENTAs the Commission previously explained in its moving papers, it does not
have a very heavy burden to make itsprima facie case that Bagley and 1st
Global
violated Section 5. It need merely show that (1) no registration statement was in
effect as to the securities; (2) the defendants, directly or indirectly, sold or offered
to sell the securities; and (3) the sale or offer was made through interstate
commerce or the mails. SEC v. Phan, 500 F.3d 895, 902 (9th
Cir. 2007). As
further explained, the second element may be satisfied by establishing that the
Defendants were necessary participants or substantial factors in the
unregistered distribution of CMKM stock. Id. at 906; SEC v. Murphy 626 F.2d
633, 648 & 652 (9th
cir. 1980).
Not surprisingly, Bagley and 1st Global seek to impose a greater burden on
the Commission than the Ninth Circuit in fact requires. They also seek to argue
that their status as a transfer agent and its principal essentially frees them from any
liability for violating Section 5, a proposition for which there is no support.
A. Bagley Has Not Presented Any Genuine Issue Of Material FactThat She Violated Section 5
The undisputed facts establishing that Bagley and 1st
Global were necessary
participants and substantial factors in the multi-billion share unregistered offering
of CMKM stock are simple. These Defendants admit that from December 2002
through September 2004, on numerous occasions, they issued billions of shares of
unrestricted CMKM stock in certificate form without a restrictive legend to numerous
individuals and entities. (Facts 39.) By removing the restrictive legends from the
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stock certificates, Bagley and 1st
Global enabled the stock to be freely traded.
Because the previously restricted stock was unregistered, and these Defendantsremoval of the restrictive legends enabled it to be freely traded, these Defendants
were necessary participants and substantial factors in the overall scheme to make
the multibillion share offering of unregistered CMKM stock to the public.
1. It Is Undisputed That Unregistered CMKM Stock WasOffered And Sold
As a threshold matter, these Defendants argue that the Commission has not
established that there were specific offers and sales of stock; they do not, however,
present evidence that no offers or sales occurred. (Opposition at 18-19.) Among
other things, they argue that no effort was made by the Commission to link trading
activity by Defendant Edwards to particular issuances of shares by the transfer
agent Defendants to Edwards. This argument of course ignores the key undisputed
fact that 1st
Global served as CMKMs Transfer Agent at all relevant times,
beginning in 2002 (Facts 6; see also Declaration of Helen Bagley in support of
Opposition to Commissions motion (Bagley Declaration) 3.) There was no
other transfer agent; the restrictive legends were removed by 1st
Global and
Bagley. Bagley and 1st
Global admitted in their Answer that from December 2002
through September 2004, on numerous occasions, they issued billions of CMKM
shares in certificate form without restrictive legend (Facts 39), and that Bagley
caused 1st
Global to issue substantial numbers of stock certificates without
restrictive legends in late 2002 and 2003, purportedly based on attorney opinion
letters. (Facts 45.)
Once a restrictive legend is removed, the stock is freely tradable. This is, of
course, the entire purpose of removing the legend, and of Defendants scheme.
Once the restrictive legend was removed by Bagley, the unregistered stock became
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indistinguishable from other freely trading CMKM stock.
Without citation, Bagley and 1
st
Global argue that the Commission musttrace the billions of shares of unregistered stock they caused to be dumped into the
market from the original certificates restricting the shares issuance, to their
removal of the legends, to Defendant Edwards offering and selling those specific
shares through Defendant broker-dealer NevWest. This is not the law. For
example, in SEC v. Murphy, 626 F.2d 633 (1980), the Ninth Circuit granted the
Commissions motion for summary judgment that Defendant was liable for
violating Section 5 notwithstanding that no one knows how many offerees were
contacted on any of the offerings. Id. at 645. InMurphy, the defendant was
arguing that the offering was exempt from registration as a private offering. Id.
Once the Commission had presented evidence that there was no control placed on
the number of offerees, it was incumbent upon Murphy, in opposing summary
judgment, to rebut that evidence. Id. Without introducing evidence on the number
of offerees, Murphy could not satisfy even the small burden imposed on a party
resisting summary judgment. Id.
Bagley admits she issued 279 billion unrestricted CMKM shares that had
previously been labelled restricted. (Facts 43 & 46.) This was over one-third of
the total amount of outstanding CMKM shares. (Id. 43.) It is undisputed that
Defendant broker-dealer NevWest received stock certificates from 1st
Global, that it
contacted Bagley and/or 1st
Global to verify that the certificates were validly issued
and unrestricted, and that Bagley and/or 1st
Global vouched for the subject stock
certificates. (Facts 52-53.) It is undisputed that Defendant Edwards hand-delivered
to NevWest newly issued stock certificates (Facts 57-58), that those newly issued
certificates can only have been issued by 1st
Global because it was the transfer agent,
that Edwards sold CMKM stock through more than 30 different brokerage accounts
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(Facts 62), and that Edwards was liquidating his position in CMKM. (Facts 59.)
Of course, as a broker-dealer, NevWest offered and sold shares to an unrestrictednumber of offerees in interstate commerce; that was their business.
Bagleys argument is opaque. It is not clear whether she is arguing that the
previously restricted shares she caused to be disseminated as freely trading shares
were somehow exempt from registration. If she is, she has the burden of proof to
establish she is entitled to an exemption; furthermore, such exemptions are
construed narrowly. SEC v. Platforms Wireless Intl Corp., 617 F.3d 1072, 1086
(9th
Cir. 2010), citing SEC v. Murphy, 626 F.2d at 641. For example, if she were
to assert the private offering exemption, as Murphy did, she would be required to
establish that the exemption was met not only with respect to each purchaser, but
with respect to each offeree. SEC v. Murphy, 626 F.2d at 645. Contrary to
Bagleys suggestion, however, the reverse is not true; the Commission is not
required to prove every offer and/or sale. Rather, once the Commission introduced
evidence that there was no control placed on the number of offerees, a factor in
determining whether the private offering exemption exists, the burden shifted to
the defendant to rebut that evidence. Id.
Here, Bagley has not even suggested what exemption would apply. Newly
issued unrestricted CMKM shares were delivered to NevWest, a broker-dealer, and
sold by Defendant Edwards, who was liquidating his CMKM holdings.
Defendants Bagley and First Global were necessary participants and substantial
factors in that distribution.1
1To the extent Bagley and 1
stGlobal argue that they may have a defense
based upon opinion letters of counsel (Opposition at 18-19), they are confused asto who has the burden of proof. Contrary to their suggestion, it is not theCommission who has the burden to prove which issuances were based on theopinion letters of Dvorak, but the Defendants who have the burden of showingeach of the elements of a reliance on counsel defense. See SEC v. Goldfield Deep
Mines Co. of Nevada, 758 F.2d 459, 467 (9th
cir. 1985). Moreover, even if the
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2. The Additional Facts Asserted By 1st Global And Bagley DoNot Controvert That They were Necessary Participants AndSubstantial Factors In The Unregistered Offering
Like Rumyantsev, 1st
Global and Bagley seek to argue that there are genuine
issues of fact precluding a finding of liability by presenting a laundry list of bad
acts that they did notengage in, and that the Commission never claimed they
engaged in. These include the facts set forth in paragraphs 5-8 &11-12 of the
Defendants Separate Statement Of Undisputed Facts (Defendants Facts). That
they ever personally owned CMKM stock, for example, is not something the
Commission ever alleged; nor is it a required element for Section 5 liability.
Much of the remainder of the Defendants Facts purports to address
Bagleys level of knowledge. (Defendants Facts 8-9, 13-15.) Some of the
Facts are argument, or set forth Bagleys own legal opinions, and are therefore
inadmissible. (Id. 14-15 & 24.) Others clearly support the Commissions
Statement of Facts, including that the Defendants simply relied on opinion letters.
(Id. 16-23, 26-27, 29-31 & 33-34.) The Defendants reliance on opinion letters,
notwithstanding Bagleys view that nothing CMKM did made sense to her and
her distrust of Dvorak, is addressed below.
Bagley also cites to thirty-two pages of Dvoraks testimony in purported
support of the assertion that Dvorak fully investigated the factual claims
underlying his opinions. (Defendants Facts 32.) In fact, Dvorak testifies,
among other things, that he did not receive cancelled checks he requested (Ex. 1,
121:18-122:1), and that he did not recall or know certain facts (id. 123-124). It is
difficult to ascertain why the Defendants believe that their overbroad factual
Commission were to prove the date of offer or sale, this would not establish whenthe restrictive legend was removed.
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assertion is supported by these thirty pages, some of which are specifically cited by
the Commission because they support its claims that Dvorak acted recklessly.Bagley also sets forth a fact which is not helpful to her, and which helps
establish her liability. She explains that:
From a stock transfer agents perspective, the most common type oftransaction that might raise the issue of securities law compliance isthe request from a shareholder to remove a restrictive legend from acertificate and reissue a certificate without restrictive legend.
(Id. 14.) The remainder of the paragraph is objectionable, however, as it appears
to constitute her own expert opinion as to whether she acted as other stock transfer
agents do, and whether her own conduct was legally sufficient to constitute a
defense to her liability.
Bagley also tries to blame the Commission by asserting that At no time did
any representative of the SEC ever raise issues regarding the content of the opinion
letters, or that issuance of shares without a restrictive legend may violate Section
5. (Defendants Facts 25.) Not only is this Fact objectionable because it has
no legal relevance, but it is also obviously untrue, as the Commission filed this
action against Bagley.2
Finally, Bagley seeks to contest the appropriateness of the injunctive relief
sought by the Commission by asserting that she is not presently involved in the
stock transfer business and does not intend to be in the future. (Defendants Facts
3-4.) For the reasons explained in the Commissions Reply regarding its motion
as to Rumyantsev, (Docket No. 164 at 9-12), such assertions are insufficient to
defeat the Commissions request for injunctive relief. Bagley also inserts an
irrelevant paragraph that she paid back a loan from Defendant Edwards, even
2The Commission objects to paragraph 35, that the trading volume
skyrocketed after Edwards & Angell were retained, as irrelevant.
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though the Commission does not seek disgorgement of that loan. (Id. 10.)
3. It Is Undisputed That The Defendants Knew Or Had
Reason To Know That An Illegal Distribution Would Occur
Most of the Opposition is devoted to arguing that (1) transfer agents are
virtually never sued for violating the federal securities laws; and (2) the
Commission was required to prove that Bagley and 1st
Global knew or had reason
to know that an unregistered distribution would occur in connection with the
transactions pending before them. (See Opposition at 5.) The first argument is
completely irrelevant to these Defendants liability although it does highlight the
egregiousness of their illegal conduct in facilitating the distribution of 279 billion
shares of unregistered stock. The second argument simply does not help Bagley or
1st
Global. Although the Commission does not concede that it has a burden to
prove that these Defendants knew or had reason to know the likely consequences
of their acts, even if it does have such a burden, the Commission has satisfied it.
The Defendants rely heavily on the SEC Staff Reply inDefrees, Fisk,
Voland, Alberts & Hoffman, [1971-72 Transfer Binder] Fed. Sec. L. Rep. 78,745
(April 12, 1972).3
This is not a pronouncement by the Commission itself; it is a
staff response to a letter. Additionally, the Defendants choose to emphasize the
language that if the agent knows or has reason to know an illegal distribution
would occur it should take appropriate steps to forestall it. They ignore, however,
the preceding language in that paragraph that:[T]he particular procedures a company and its transfer agent may wishto adopt concerning the removal of restrictive legends in the contextof sales pursuant to rule 144 is within the discretion of those partiesand the responsibility for the effectiveness of those procedures lieswith them.
3For the Courts convenience, a copy ofDefrees is attached as Exhibit 1.
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(See Opposition at 5 [emphasis supplied].) Notably, this language would appear to
impose an affirmative duty on both the issuer, CMKM, and its transfer agent, 1
st
Global, to make sure that their procedures are effective in preventing an illegal
distribution.
The Defendants also ignore the remainder of the Staff Reply, which sets
forth the text of the Letter of Inquiry prompting that Reply, including what the
writers represent is typical procedure for removing restrictive legends from Rule
144 stock. That procedure does not resemble what occurred in this case.
First, the writers explain the conditions under which issuers would be
allowed to remove the restrictive legends:
We interpret the Rule to allow the issuer to remove legends andstop transfer instructions if the issuer has filed its period reports, thetwo year period has elapsed, and the other conditions of Rule 144have been complied with. . . .
Defrees, 78,745 at p. 81,554 [emphasis supplied]. Here, it is undisputed that
CMKM was not filing its required periodic reports. (See Facts 86.) Additionally,
this was not a situation where Bagley verified that the two year restricted period
had elapsed; to the contrary, she admits she may have wondered whether it was
actually true that the 279 billion shares were outstanding and should have been
issued two years earlier. (See Facts 47.)
The writers also explain that the physical removal of the restrictive legends
from the stock certificates may take thirty to sixty days, and in some events had
been known to take six months:
This delay is attributable to the typical routine, which is that thesecurity holders attorney must give an opinion, the opinion must bereviewed and approved by counsel of the issuer, and then the newsecurities must be physically reissued.
Defrees, 78,745 at p. 81,554 [emphasis supplied]. In this case, the opinion letter
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was not issued by the holder of the Rule 144 stock and reviewed by issuers
counsel. Rather, only one attorney was involved, and that was counsel to theissuer, Dvorak. Clearly, the procedure employed by Bagley was not the careful
one employed by the writers to whom the staff was responding inDefrees.
Notwithstanding all of her legal arguments that she and her company should
not be held liable unless the Commission proves that she knew or had reason to
know that an unregistered distribution would occur when she removed the
restrictive legends from the stock certificates, Bagley has not disputed the facts
presented by the Commission which establish that they in fact not only had reason
to know, but acted with scienter. In particular, Bagley:
(1) Issued the shares notwithstanding that nothing this company did
made sense to me, including CMKMs assertion that it had failed to
issue 279 billion of its purportedly outstanding shares. (Facts 46.)
(2) Never asked anyone whether it was actually true that the 279 billion
shares were outstanding and should have been issued two years
earlier, instead relying solely on attorney opinion letters, including by
Dvorak, notwithstanding that she apparently wondered whether the
shares were truly outstanding. (Facts 47.)
(3) Relied on Dvoraks opinion letters notwithstanding that she had
previously learned from a Commission examiner that certain other
opinion letters issued by a different attorney regarding CMKM were
incorrect, causing her to request corrected letters. (Facts 48.)
(4) Relied on Dvoraks opinion letters notwithstanding that she just did
not like him, and did not feel comfortable, to the point where, at
the end of the relevant period, she asked that any opinions from
Dvorak go through another attorney hired by CMKM. (Facts 49.)
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(5) Thought it strange that CMKM had so many shares. (Facts 50.)
Contrary to Bagleys assertions, simply requiring CMKM to submit Dvoraksopinion letters to another attorney after June 2004 did not render her conduct any
more reasonable. (See Bagley Declaration 20.) First, this does not address the
problems raised by her purported reliance on Dvoraks opinion letters prior to June
2004. Second, the representative July 27, 2004, letter from the second law firm,
which Bagley attaches to her Declaration as Exhibit 2, explicitly states that we
have relied upon opinions dated July 20, 2004 of Dvorak & Associates, Ltd., and
makes certain other key assumptions before rendering an opinion that the shares
need bear no restrictive legend.
There is no evidence that Bagley took the simple step of checking the
Commissions public EDGAR system in order to determine whether a registration
statement had been filed for any of the billions of shares from which she was
removing restrictive legends. Nor is there evidence that she was induced to issue
the unrestricted shares by a representation that the shares were registered, or that
she was provided with false registration statements by CMKM or anyone else, as
was the case with regard to the transfer agent in SEC v. Diversified Corporate
Consulting Group, 378 F.3d 1219, 1222 & n.9 (11th
Cir. 2004), which Bagley cites.
Finally, Bagleys suggestion that she was required timely to issue the
certificates without restrictive legend by Commission regulations and Nevada State
law and therefore cannot be held liable for violating Section 5 is tortured and facially
absurd. (See Opposition at 7-10.) Nothing in federal or state law requires a transfer
agent to act in violation of another law Section 5. Indeed, there would be no
purpose to having transfer agents if they are required to simply transfer ownership of
shares without any regard to whether such transfer is legally proper. Additionally,
that others, such as the issuer and attorneys who write opinion letters, also have legal
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responsibilities does not render Section 5 inapplicable to transfer agents.
In short, Bagley has not presented any genuine issue of material fact or crediblelegal argument that would preclude her from being held liable under Section 5.
B. Bagley Has Not Presented Any Genuine Issue Of Material Fact AsTo The Appropriateness Of The Disgorgement Sought
Bagley asserts that genuine issues exist regarding disgorgement.
(Opposition at 21-22.) However, she presents no actual evidence to refute the
reasonableness of the Commissions approximation of her ill-gotten gains,
notwithstanding that the burden has shifted to her to demonstrate that the
disgorgement figure was not a reasonable approximation. SEC v. Platforms
Wireless, 617 F.3d at 1096. If the monies received from other defendants are truly
not related to CMKM, Bagley would presumably easily be able to establish this
fact. As the Ninth Circuit has explained, the burden is placed on the defendants
because they are more likely than the SEC to have access to evidence
demonstrating that the Commissions approximation is not reasonable; for this
reason, the risk of uncertainty should fall on the wrongdoer whose illegal conduct
created that uncertainty. Id. [citation omitted.]
III. CONCLUSIONFor the reasons stated, the Commissions motion for summary judgment
should be granted.
Dated: January 27, 2011 Respectfully submitted,
/s/ Karen MattesonKaren MattesonAttorney for PlaintiffSecurities and Exchange Commission
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PROOF OF SERVICE
I am over the age of 18 years and not a party to this action. My business address is:
[X] U.S. SECURITIES AND EXCHANGE COMMISSION, 5670 WilshireBoulevard, 11th Floor, Los Angeles, California 90036-3648Telephone No. (323) 965-3998; Facsimile No. (323) 965-3908.
On January 28, 2011, I caused to be served the document entitled REPLY INFURTHER SUPPORT OF MOTION BY PLAINTIFF SECURITIES ANDEXCHANGE COMMISSION FOR SUMMARY JUDGMENT AGAINSTDEFENDANTS 1
STGLOBAL STOCK TRANSFER LLC AND HELEN
BAGLEY on all the parties to this action addressed as stated on the attached servicelist:
[X] OFFICE MAIL: By placing in sealed envelope(s), which I placed for
collection and mailing following ordinary business practices. I am readilyfamiliar with this agencys practice for collection and processing ofcorrespondence for mailing; such correspondence would be deposited withthe U.S. Postal Service on the same day in the ordinary course of business.
[ ] PERSONAL DEPOSIT IN MAIL: By placing in sealedenvelope(s), which I personally deposited with the U.S. Postal Service.Each such envelope was deposited with the U.S. Postal Service at LosAngeles, California, with first class postage thereon fully prepaid.
[ ] EXPRESS U.S. MAIL: Each such envelope was deposited in a facilityregularly maintained at the U.S. Postal Service for receipt of ExpressMail at Los Angeles, California, with Express Mail postage paid.
[ ] HAND DELIVERY: I caused to be hand delivered each such envelope tothe office of the addressee as stated on the attached service list.
[ ] UNITED PARCEL SERVICE: By placing in sealed envelope(s)designated by United Parcel Service (UPS) with delivery fees paid orprovided for, which I deposited in a facility regularly maintained by UPS ordelivered to a UPS courier, at Los Angeles, California.
[X] ELECTRONIC MAIL: By transmitting the document by electronic mailto the electronic mail address as stated on the attached service list.
[X] E-FILING: By causing the document to be electronically filed via theCourts CM/ECF system, which effects electronic service on counsel whoare registered with the CM/ECF system.
[ ] FAX: By transmitting the document by facsimile transmission. Thetransmission was reported as complete and without error.
I declare under penalty of perjury that the foregoing is true and correct.
Date: January 28, 2011 /s/ Karen MattesonKaren Matteson
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SEC v. CMKM DIAMONDS, INC., et al.United States District Court - District of Nevada
Case No. 2:08-CV-00437-LRH-RJJ(LA-3028)
SERVICE LIST
Irving M. Einhorn, Esq. (served via electronic and U.S. mail)Law Offices of Irving M. Einhorn1710 10th StreetManhattan Beach, CA 90266Email: [email protected]
Attorney for Defendant John Edwards
Mark S. Dzarnoski, Esq. (served via CM/ECF only)
Gordon & Silver, Ltd.3960 Howard Hughes Parkway, Ninth FloorLas Vegas, NV 89169Email: [email protected]
Attorney for Helen Bagley and 1st Global Stock Transfer LLC
Urban A. Casavant (served via electronic and U.S. mail)RR 5 Site 16 Box 29Prince Albert, Saskatchewan S6V 5R3CanadaEmail: [email protected]
John Wesley Hall, Jr., Esq. (served via CM/ECF only)
1311 BroadwayLittle Rock, AR 72202-4843Email: [email protected]
Attorney for Brian Dvorak
Kathleen Tomasso (served via U.S. mail only)9580 Lake Serena DriveBoca Raton, FL 33496Email: [email protected]
Anthony Tomasso (served via U.S. mail only)9580 Lake Serena DriveBoca Raton, FL 33496
Email: [email protected]
Sergey Rumyantsev (served via electronic and U.S. mail)1951 North Jones Boulevard, #G-202Las Vegas, NV 89108Email: [email protected]
Anthony Santos (served via electronic and U.S. mail)6965 North Durango Drive, Suite 1115-208Las Vegas, NV 89149Email: [email protected]
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NevWest Securities Corporation (served via U.S. mail only)
c/o Anthony Santos6965 North Durango Drive, Suite 1115-208Las Vegas, NV 89149Email: [email protected]
Douglas E. Griffith, Esq. (served via electronic and U.S. mail)Kesler & RustMcIntyre Building, 2
ndFloor
68 S. Main StreetSalt Lake City, UT 84101Email: [email protected]
Attorney for Daryl Anderson
Eric N. Klein, Esq. (served via electronic and U.S. mail)Eric N. Klein & Associates, P.A.1200 N. Federal Highway, Suite 200Boca Raton, FL 33432Email: [email protected]
Michael R. Bakst (served via electronic and U.S. mail)PMB 702222 Lakeview Avenue, #160West Palm Beach, FL 33401Email: [email protected]
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