Post A Reply
my profile
login
|
register
|
search
|
faq
|
forum home
»
Allstocks.com's Bulletin Board
»
Hot Stocks Free for All !
»
CSHD: The Never-ending Story
» Post A Reply
Post A Reply
Login Name:
Password:
Message Icon:
Message:
HTML is not enabled.
UBB Code™ is enabled.
[QUOTE]Originally posted by LT: [QB] Second filing!!! [b]SUPPLEMENTAL AFFIDAVIT IN SUPPORT OF MOTION FOR RECONSIDERATION AND IN OPPOSITION TO PLAINTIFF’S MOTION FOR DEFAULT JUDGMENT AND SUPPORTING MEMORANDUM OF LAW COMES NOW the Defendant, RUFUS PAUL HARRIS, a/k/a PAUL RUFUS HARRIS, and, after being duly sworn, states that the following statements and facts are true and correct to the best of his knowledge and belief: 1) General Affirmations: A) This Defendant has a meritorious defense to all of the allegations contained in Plaintiff’s Complaint; however, all of the Defendant’s records were seized and are in the possession and control of the Plaintiff and its attorneys. The Defendant has been prevented from properly formulating any timely answer due to the refusal and/or failure of the Plaintiff and its attorneys to make required disclosures to the defendant. B) F.R.C.P.Rule 55. Default; Default Judgment Provides in part: (a) Entering a Default. When a party against whom a judgment for affirmative relief is sought has failed to plead or otherwise defend, and that failure is shown by affidavit or otherwise, the clerk must enter the party’s default. The Defendant, Rufus Paul Harris made a general appearance in this case before this Court on October 30, 2006, submitted documents to this Court as a defense to Plaintiff’s Complaint which were placed under seal by this Court. Defendant also executed a Consent agreement with the Plaintiff which was filed with the Court on November 7, 2006. It is this Defendant’s opinion that he has defended within the provisions of Rule 55(a) to preclude the entry of a default by the Clerk and has been denied due process under the 14th Amendment to the U.S. Constitution. C) On or about the 30th day of October and the 1st day of November 2006, the Defendant furnished a deposition and otherwise provided all relevant information and documents in the Defendants possession to the Plaintiff. On or about the above stated dates, the Plaintiff agreed to obtain the trading records for the Defendant corporation (CSHD) and further promised to send the Defendant a copy of his deposition for reading and signing, further more the Plaintiff agreed to furnish the Defendant a copy of all depositions, affidavits, statements and other documentation obtained from any other source, including third parties. 2) The Plaintiff and its attorneys failed to disclose or furnish anything at all to the Defendant at the initial meeting or subsequent thereto as they are required to do, including, but not limited to the disclosure of everything that could possibly have led to halting the trading of Conversion Solutions stock (CSHD)in the first place. The halt by the Plaintiff and its attorneys has caused the loss to CSHD shareholders of hundreds of millions of dollars and it also raises more than mere suspicions that the halt by the Plaintiff was for improper reasons with no evidentiary basis at all. 3) Conversion Solutions (CSHD) had merged with Fronthaul Group, Inc. (FHAL) and shareholders of FHAL and CSHD who held shares prior to October 16, 2006 of either corporation were to receive an additional 6 shares of Conversion (CSHD) stock for each one they held prior to that date via the Merger agreement. The NASD dividends department and the SEC contacted me and requested to make the 6 to 1 issuance a forward dividend with a Ex-Dividend date forward for 45 days. I refused to do so and was then contacted by the Atlanta Enforcement Office with accusation of a “Pump and Dump” scheme. 4) The entire float of FHAL and CSHD was completely sold out prior to the merger completion. The merger and the 6 additional shares, as I had it set up, would have exposed those who had “Naked Shorted” hundreds of millions of illegal shares of FHAL and CSHD and further exposed the fact that the SEC has knowingly allowed this practice to go on unregulated and with no prosecutions and just looked the other way. 5) The 6 for 1 forward split would have protected the influential “Naked Short Sellers” and also saved the SEC from embarrassment for allowing it to go on, so they halted the stock (CSHD) and allowed those participating in the illegal activity to get rich, protecting those involved in the illegal activity, all at the expense of the innocent shareholders. 6) I was engaged in settlement talks with the attorneys for the Plaintiff (SEC) prior to and after the default was entered by the Clerk about settlement of the case. Alana Black and Bill Hicks told me that if I agreed to return the CSHD Convertible Note Holders money that they would drop everything and dismiss the case. I responded by asking her to provide me the violated regulation by and through issuing the Convertible Notes. She never returned or discussed the issue again. 7)Rule 15c2-11 of the General Rules and Regulations promulgated under the Securities Exchange Act of 1934 requires specified information by market makers prior to initiation or resumption of quotations for stocks. The Plaintiff and its attorneys allowed the shares of Conversion Solutions (CSHD) to resume trading after the halt without enforcing the compliance with Rule 15c2-11. If discovery is allowed I can prove that the current trading Market Makers and Broker dealers are still trading CSHD through the quotation process in direct violation of this rule and that the Plaintiffs knowingly have ignored this illegal practice. The Plaintiffs and its attorneys allowed the trading of CSHD to resume even though I requested that the halt remain in place to the SEC and this Court the first day of proceedings. The resumption in trading allowed more naked shorting and trading of illegal shares that did not exist and caused the innocent shareholders further losses. 8) During the negotiations with Alana Black and Bill Hicks, I told Alana Black that I was going to draw down on one of the bonds in question to prove it was real and valid, But Alana told me that it would still be considered as fraud If I tried to do that. 9) At one point during the negotiations, I supplied $2,000,000,000.00 in treasury checks to Alana Black and her assistant, I asked Alana to work with me and place them into CSHD to fund it and she stated that she would talk with the higher up’s and contact me back. She never made the return call or followed up. 10) The SEC, Alana Black and Bill Hicks filed the complaint against Conversion Solutions and myself alleging a “pump and dump” scheme without even having obtained the necessary trading records for FHAL or Conversion (CSHD). On the same day that I gave them my deposition and furnished them with other Rule 26 documentation, they admitted that they had not subpoenaed or obtained the trading records but promised that they would obtain them and furnish them to me as soon as possible. I needed the trading records to prove my innocence. I supplied the entire Market via Press releases and public web site to include the Security Exchange Commission via 8K with proof that the entire float of the stock was dried up within the first two stock CUSIP number changes associated with FHAL and CVSU (CSHD predecessor) which would be proven by acquiring the trading records, which they did not do. 11) The Plaintiff’s poor effort to prove the allegation of “Pump and Dump” filed against the defendant via the obtaining of trading records which is necessary to prove the selling of illegal shares of the corporation is evident through the plaintiffs own comment in the “Plaintiffs brief to opposition” filed on the 16th day of November as followed “There is uncertainty about how many shares of Conversion’s shares are outstanding”. 12) By Alana Black admittance that they don’t know how many shares of Conversion (CSHD) actually exist, which the trading records would show, The Plaintiff either has not obtained the trading records as promised or has concealed them and those trading records will show that Conversion Solutions (CSHD) and myself have a valid defense to the Complaint that was filed. 13) This Court entered a consent order on November 7, 2006, allowing CSHD and myself to continue in business as usual subject to certain restrictions, however, the Transfer Agent, Atlanta SEC, Alana Black and Bill Hicks would not release the EDGAR codes to me so we could continue normal business without them and the Transfer Agent would not recognize me as the CEO without the EDGAR Codes, further harming the interests of the shareholders and violating the disclosure requirements of Rule 26 F.R.C.P. Multiple accesses to the filing codes were requested via telephone and via the EDGAR filing site to obtain the codes prior to the halt and thereafter. 14) The sealed envelope that I presented to and was accepted by this Court included a trading/handling contract with one of the largest bond traders which included contracted bank accounts for the bonds. This accepted evidence was one of the many evidentiary defenses to the complaint filed by the Plaintiff (SEC). 15) The SEC, Alana Black and Bill Hicks have, at all times material hereto, refused to provide me with any discovery, including but not limited to the trading information which will show who actually sold shares that did not exist and who profited at the expense of the innocent shareholders. 16) The failure to file an answer by Conversion Solutions and myself was not due to excusable neglect or inadvertence but was a result of the unethical and inappropriate actions of the Plaintiff, Alana Black and Bill Hicks in order to prevent me from obtaining the information necessary to file an answer and defenses and they kept the negotiations open until well after they obtained the unauthorized default. The following affirmations pertain to the Motion For Default Judgment and supporting memorandum of law with Alana Black’s mistaken version of the Factual Allegation, filed by Alana Black in November 2007: 17) The allegations of the complaint are not true and should not be accepted as true because the default entered by the clerk was unauthorized and did not conform to Rule 55 F.R.C.P. 18) Factual allegation # 4: None of the documents referred to in #4 overstated Conversion,s assets. Everything contained on all reports referred to therein were true and correct to my best knowledge and belief at the time they were prepared. 19) Factual allegations #5 and #6: None of the allegations referred to in #5 and #6 are false. The September 26 Form 8-K that stated that “Conversion’s Board of Directors has approved a contract extension with the Caracas Group and accepted into its Asset Management Portfolio an additional 5 Billion Euro denominated Global Bonds on the Republic of Venezuela with an 11% annual coupon.” Everything contained in or referred to therein were true and correct to my best knowledge and belief at that time. 20) Factual allegation # 9: This allegation is being misstated. This is not what the September 26 8-K says. The initial validation was for 700 million and the 5 billion was a contract extension. The Court has these sealed documents in its possession to prove her allegations false. 21) Factual allegations # 10-12: The 5 billion was a contract extension that was taken into the portfolio as previously stated. The authorization was for up to 1.4 billion by the Venezuelan State Department, not 700 million, it was a best efforts offering. I even supplied copies of the bar codes and a letter from the Ambassador. 22) Factual allegations # 13-16: Alana’s facts are on “information and belief” which are wrong, she doesn’t understand what she is reading. All supporting evidence is in the sealed envelope in the Courts possession and everything contained in or referred to in the sealed envelope in evidence was true and correct to my best knowledge and belief at that time. 23) Factual allegation # 18: The bond was authorized up to 2 billion dollars. Our bond was only 500 million of the original 2 billion authorized. Alana is talking about something different. Everything contained in or referred to in factual allegations #16 and #17 was true and correct to my best knowledge and belief at that time.[/b] continued below... [/QB][/QUOTE]
Instant Graemlins
Instant UBB Code™
What is UBB Code™?
Options
Disable Graemlins in this post.
*** Click here to review this topic. ***
Contact Us
|
Allstocks.com Message Board Home
© 1997 - 2021 Allstocks.com. All rights reserved.
Powered by
Infopop Corporation
UBB.classic™ 6.7.2