quote:Originally posted by thesource: But does anyone have anything new or constructive ? All I see are repost of info from Dufus or James G. in which one side is calling the other side a liar and a scammer yet people cannot get enough of it . None of it really matters as I've said before , the company has a default judgement against it and thats that . Rufus should have ante'd up and got a lawyer this time last year or honestly should have had one on retainer since day 1 .
I agree with you there hasn't really been anything constructive to come out as of like the last half year but nevertheless your posting is equally as nonconstructive as theirs.
Posts: 854 | From: Alpharetta, GA | Registered: Mar 2006
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quote:Originally posted by thesource: But does anyone have anything new or constructive ? All I see are repost of info from Dufus or James G. in which one side is calling the other side a liar and a scammer yet people cannot get enough of it . None of it really matters as I've said before , the company has a default judgement against it and thats that . Rufus should have ante'd up and got a lawyer this time last year or honestly should have had one on retainer since day 1 .
Sour-source . since the stock still trades , it isn't in recievership..has an active court case...it has Shareholders which most hold HCC's.... there is a reason to post new DD , pacer filings , postings from the CEO..etc.... your post's are NON-Constructive and frankly the same crap everyday .... so i'll ask again why do you spend so much time wasted on a stock that you have no intrest in ( shares )... is it to make fun or be-little the shareholders that are here ?....what a waste of time...get a life.. Posts: 65 | Registered: Dec 2007
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quote:Originally posted by thesource: But does anyone have anything new or constructive ? All I see are repost of info from Dufus or James G. in which one side is calling the other side a liar and a scammer yet people cannot get enough of it . None of it really matters as I've said before , the company has a default judgement against it and thats that . Rufus should have ante'd up and got a lawyer this time last year or honestly should have had one on retainer since day 1 .
Well his explanation for not having a lawyer is that the lawyers wanted him to back out of the merger. I suspect they know what he knows and didnt think he should tangle with the guys that were running the show when Rufus came along. Obviously backing out of the merger was not what he wanted to do so hence no lawyer. That and he said "I have the information....they dont!".
Ok, now that ive brought you up to date on the lawyer thing did you get a chance to look over those documents i put a link up for today?
Posts: 2308 | From: Michigan | Registered: Jun 2006
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quote:Originally posted by thesource: But does anyone have anything new or constructive ? All I see are repost of info from Dufus or James G. in which one side is calling the other side a liar and a scammer yet people cannot get enough of it . None of it really matters as I've said before , the company has a default judgement against it and thats that . Rufus should have ante'd up and got a lawyer this time last year or honestly should have had one on retainer since day 1 .
Well his explanation for not having a lawyer is that the lawyers wanted him to back out of the merger. I suspect they know what he knows and didnt think he should tangle with the guys that were running the show when Rufus came along. Obviously backing out of the merger was not what he wanted to do so hence no lawyer. That and he said "I have the information....they dont!".
Ok, now that ive brought you up to date on the lawyer thing did you get a chance to look over those documents i put a link up for today?
hes looked... hes prolly trying to find a way to spin it...lol...j/k source.... many more to come also ...keep watching !!...this is just the start !..also keep your eye on Pacer !
Posts: 65 | Registered: Dec 2007
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posted
Rufus can come up with as many excuses for not having legal counsel as the share holders are willing to listen to but the law is the law . The only way a person can represent themself is a term called PRO SE . You cannot represent anyone but yourself . If the company was Rufus P. Harris D.B.A Conversion Solutions Holdings then it would be a sole proprietorship and a totally different situation but this is not the case and has never been .
Rufus has tried from the beginning to seperate himself from the company to represent himself but continues to file motions that include the company . This will not fly in Federal court or even in a simple small claims court of law . He's too damn stupid and stubborn to admit it . The company has not gone into receivership LT and I have never said it has . The next step after the default is going to be to divide up the assets if the company actually has any which I will bet you azz they do not and the company will be put into receivership . As for the actual shell itself , it might continue to trade or it might not . I am not experienced with that part of a publically traded company . I would assume that will be up to the person or persons in charge of the receivership process .
As for PACER , Dufus can file anything he'd like at this point but its merely in vain . As I've said before , a default judgement is non appealable and I am not aware of any situations where it can be put aside especially for some lame azz excuse like Dufus has come up with so far . I am sure the judge is getting a real kick from this idiot and his little games .
-------------------- ----- Game Over ----- Posts: 1536 | From: San Antonio - Texas | Registered: Oct 2006
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quote:Originally posted by Mr. CATIAEngineer: Source....if you are still so interested in CSHD even after selling you can find some interesting reading here......
Name Arrestee Used HARRIS, RUFUS JR Date of Arrest Sep 12 2005 Offender Tracking No. 001
Judicial Record
Judicial Agency COLQUITT COUNTY SUPERIOR COURT Case Number Date Case Appealed Judicial Court Count 01 Court Count 1 01 Court Disp. Date Feb 15 2006 Judicial Citation 40-5-58(C) General Offense
posted
No but he could very well be picked up at court if he's got a bench warrant from the failure to appear on his last DUI court setting . I would also bet they are going to MTR (motion to revoke) his current probation since he's received another DUI charge .
None of this has anything to do with the SEC case , I just thought it was funny where it said "HABITUAL VIOLATOR" . That sounds like Dufus to me ........
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posted
Owning several businesses and dealing with legal issues though out my life , I've picked up a few things along the way . I am very famaliar with suits (mainly in the small claims courts of Texas) but some bigger ones as well . Now days , no one can deal with each other person to person and figure things out , everyone files suit against each other and clogs up the civil courts with B/S suits . I am sure the SEC has a crap load of suits filed against publically traded companies and CSHD is just one of a whole bunch just in the Georgia district alone .
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posted
I am sure the SEC has a crap load of suits filed against publically traded companies and CSHD is just one of a whole bunch just in the Georgia district alone .
hint:
there is a place where you can actually look that up instead of guessing...
i for one expect the SEC to make a good case in spite of the fact that Rufufu doesn't follow process.
you haven't got a clue just how many "dirty tricks" are played in the market do you?
you have focused on this one because you feel burned, but there's a hundred a day that people just ignore.
-------------------- Don't envy the happiness of those who live in a fool's paradise. Posts: 36378 | From: USA | Registered: Sep 2003
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posted
there's hundreds that go by unnoticed by the SEC, or uncomplained about to the SEC too...
if i could make a suggestion? being rude to people for sticking to this play is bad karma.
they are either going to win or lose and you're uh,less than polite input odds no value to the board...
if people were promising, say 15$ dollars a share, ? then you would be adding value by trying to point out that it prolly won't happen. some of us actually did that, and recommended taking profits and protecting capital as it went up... others were determined to stay in for the "reset"...
currently? this thing is pretty dead, and more than a few of us are interested to see the final disposition, even if we don't have any $ to gain out of it... Rufufu? he's lost IMO... but there's other issues here....
esp if the bonds did exist at one time, or are still there...
the SEC is run by people... say you wanna short a stock? and you have a pretty good idea that something is wrong? it doesn't hurt to report them to the SEC does it? the SEC should be able to make its case no problem if things are as bad they appear... people do make mistakes on occasion, and no i'm not saying they did or didn't here, but i wanna see the goods laid out on the table...
and that will only happen if peopl keep pushing...
scamsters depend on people not admitting they got scammed, or and they depend on the system to not follow thru cuz there's other stuff that's more important, but it's really all important...
-------------------- Don't envy the happiness of those who live in a fool's paradise. Posts: 36378 | From: USA | Registered: Sep 2003
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posted
Glassman, Thank you, thank you!! I do not post very often anymore because there was a source of irritation on here "all the time" I will not add more because I do not want to be rude.
Miss chatting with most of ya.
Posts: 360 | Registered: Aug 2006
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VERIFIED MOTION TO COMPEL DISCOVERY AND MOTION FOR SANCTIONS FOR FAILING TO DISCLOSE
COMES NOW the Defendant, RUFUS PAUL HARRIS, a/k/a
PAUL RUFUS HARRIS, and moves this Court to compel discovery/
disclosure and allow this defendant all allowable discovery
prior to a hearing on the pending motions, also to further
expand the time allowed for the Defendant to file pleadings
and affidavits to supplement his Motion For Reconsideration
until such time as the Plaintiffs produce all discovery
contemplated under Rules 26, 27, 30, 34, 36 and 45 of
the Federal Rules of Civil Procedure, and Local Federal Rules
26, 26.1, 26.3, 30, 37, 37.1, and further moves this Court to
impose sanctions against the Plaintiff and its individual
Attorneys, including, but not limited to a dismissal of
Plaintiff’s Complaint and in support thereof states the
following under oath:
1) 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, said defense documents were placed
under seal by this Court and executed a Consent agreement
with the Plaintiff, also filed with the Court on November
7, 2006.
2) Rule 26 F.R.C.P. provides, in part as follows: (a) Required Disclosures; Methods to Discover Additional Matter. (1) Initial Disclosures. Except in categories of proceedings specified in Rule 26(a)(1)(E), or to the extent otherwise stipulated or directed by order, a party must, without awaiting a discovery request, provide to other parties: (A) the name and, if known, the address and telephone number of each individual likely to have discoverable information that the disclosing party may use to support its claims or defenses, unless solely for impeachment, identifying the subjects of the information; (B) a copy of, or a description by category and location of, all documents, electronically stored information, and tangible things that are in the possession, custody, or control of the party and that the disclosing party may use to support its claims or defenses, unless solely for impeachment; (C) a computation of any category of damages claimed by the disclosing party, making available for inspection and copying as under Rule 34, the documents or other evidentiary material, not privileged or protected from disclosure, on which such computation is based, including materials bearing on the nature and extent of injuries suffered. A party must make its initial disclosures based on the information then reasonably available to it and is not excused from making its disclosures because it has not fully completed its investigation of the case or because it challenges the sufficiency of another party's disclosures or because another party has not made its disclosures. (Emphasis added)
3) Pursuant to Rule 26 of the Federal Rules of Civil
Procedure, the Plaintiff’s attorneys and the Defendant talked
on November 3rd & 6th 2006 to consider the nature and basis of
their claims and defenses and the possibilities for a prompt
settlement or resolution of the case, to make or arrange
for the disclosures required by Rule 26(a)(1), to discuss
any issues relating to preserving discoverable information,
and to develop a proposed discovery plan.
4) Pursuant to the agreement at the aforesaid Rule 26
meeting, the Defendant furnished a deposition and provided
all relevant information and documents in the Defendant’s
possession to the Plaintiff. The Plaintiff agreed to obtain
the trading records for the Defendant corporation (CSHD)
and further promised to send the Defendant a copy of his
and/or allowing the Defendant a copy of all depositions,
affidavits, statements and other documentation obtained
from any other source, including third parties.
5) The Plaintiff and its attorneys failed to disclose
or furnish anything at all to the Defendant at the initial
meeting as they are required to do, including, but not
limited to the disclosure of everything that could have led
to halting the trading of Conversion Solutions stock in the
first place; said halt causing the loss to CSHD shareholders
of hundreds of millions of dollars and raising more than mere
suspicions that the halt by the Plaintiff was for improper
reasons with no evidentiary basis at all.
6) The Plaintiff and its attorneys, with total
disregard for Rule 26 F.R.C.P., have failed to disclose,
furnish or provide anything to the Defendant pursuant to the
agreement at said Rule 26 meeting and in fact, the attorneys
for the Plaintiff kept the Defendant in negotiations by
promising to provide trading records and other disclosure
until after they caused the Clerk to improperly file a
default against the Defendant, contrary to the agreement at
said meeting, contrary to the provisions of Rule 26 F.R.C.P
and contrary to the fact that this Defendant had made an
appearance before this Court, submitted evidence in his
defense to the Court and filed pleadings in this case in the
form of the consent agreement filed with the Court. All of
the foregoing actually constituted enough appearance, filing
of pleadings and defense evidence filed with the Court to
preclude the entry of a default by the Clerk. Any default
against the Defendant must have come out of a noticed hearing
and an order from this Court, not from the Clerk.
7) The failure of the Plaintiff to obtain and disclose
the trading records for the Defendant Corporation (CSHD)
shows a material and intentional disregard for the rights
of the Defendant and the shareholders of CSHD, or in the
alternative, those records would vindicate this
Defendant and the corporation and would actually show that
the Plaintiff had absolutely no reason to halt the stock
from trading and had no reason for the filing of the
lawsuit, especially when those very trading records are
needed by the Plaintiff to prove the largest allegation of
their complaint, which was a “pump and dump” scheme by this
Defendant.
8) The Plaintiff and its attorneys have done all they
could to deny this Defendant his “due process” and in doing
so have violated Rule 26, F.R C.P as well as Local Court
rule 26 by withholding any and all information, documents,
records or anything else of an evidentiary nature that this
Defendant would have needed to file an answer, defenses and
counterclaims.
9) Rule 26(a)(1) requires all disclosure to be
furnished by the Plaintiff and its attorneys even without a
discovery request from this Defendant and is further
required to supplement that disclosure as it is obtained
under Rule 26(e), F.R.C.P.. The Plaintiff and its attorneys
did none of the above; instead of furnishing any disclosure
to the Defendant, they just withheld disclosure and tricked
him into a default situation so he wouldn’t be able to file
an answer. The Plaintiff’s attorneys still continued to
negotiate with the Defendant thereafter for an extended
period of time until he attempted to file his first answer
and then dropped any and all communications with said
Defendant by using the Clerk’s default as a shield.
10) The Defendant needs the opportunity to have the
Plaintiff and its attorneys deposed to verify the facts
contained in this motion, as well as secure the disclosure
that he has been denied due to the unethical practices of
the Plaintiff’s attorneys. Defendant is guaranteed these
rights even after the default because no Default Judgment
was entered by the Clerk and all further proceedings needed
to be done before this Court and the Defendant is entitled to
discovery to prepare for the final hearing.
11) The Plaintiff had seized the records of the
Defendant and would not grant the Defendant access to those
records or any other records in the possession or control
of the Plaintiff, thus denying the Defendant the ability to
file his answer in the past or even now without disclosure
by the Plaintiff.
12) The Defendant hereby certifies that he has made a
good faith attempt on multiple occasions, pursuant to Rule
37(a)(2), F.R.C.P., and Local Rule 37 to confer with Alana
Black and other attorneys in the office of the Plaintiff in
an effort to resolve the discovery dispute and secure copies
of the CSHD trading records, depositions, statements and/or
affidavits without Court action but all efforts have been
repulsed or just ignored by the Plaintiff’s attorneys,
contrary to the provisions of Rule 26 F.R.C.P and Local Rule
26.
13) This is a case of great public interest which
affects thousands of innocent shareholders as well as the
integrity of the Plaintiff and its attorneys. To avoid the
appearance of any impropriety, favor or prejudice, this
Court must allow proper discovery and hold the Plaintiff’s
attorneys accountable should it become known that this
entire lawsuit was filed to protect large naked short
sellers rather than to protect the innocent shareholders of
CSHD.
14) The actions and the integrity of the Plaintiff
(SEC) and its attorneys have come into public scrutiny
recently and this case is a classic example of the SEC
“unclean hands” and of some of the abuses of the Court
process that come into question. The failure of the Plaintiff
and its attorneys to allow or furnish any required disclosure
to the Defendant, as required by Rule 26 F.R.C.P as well as
other discovery Rules should be dealt with harshly by this
Court in the form of appropriate sanctions, fines, dismissal
of the case or any such other punishment deemed appropriate
by this Court, along with a referral to the U.S. Attorney
General and the Georgia Bar Association for Investigation.
15) The Defendant requires an extended period beyond his
previously requested January 2nd 2008 date to supplement his
initial Motion to Set Aside Default and Motion For
Reconsideration because of the time involved for discovery.
The time extension needed is for 60 days after the Plaintiff
complies with and furnishes the discovery allowed under the
Federal Rules of Civil Procedure.
15) The Defendant requests an open hearing before this
Court, as due process requires, and an opportunity to argue
and defend this Defendant’s position.
WHEREFORE, THE Defendant, RUFUS PAUL HARRIS, a/k/a
PAUL RUFUS HARRIS, moves this Court for an Order compelling
discovery from the Plaintiff, including, but not limited to
taking the depositions of Officers of the Plaintiff and
Plaintiff’s attorneys and an extension of time to supplement
previous pleadings; Plaintiff further moves for sanctions to
be entered against the Plaintiff and its attorneys for
refusing to allow the Defendant any discovery further.
I, RUFUS PAUL HARRIS a/k/a PAUL RUFUS HARRIS, after
being duly sworn according to law, do state and affirm,
under penalty of perjury, that the facts set forth in
the foregoing VERIFIED MOTION TO COMPEL DISCOVERY AND
MOTION FOR SANCTIONS FOR FAILING TO DISCLOSE are true and
correct to my best knowledge and belief.Posts: 65 | Registered: Dec 2007
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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.
continued below...
Posts: 65 | Registered: Dec 2007
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No certified fraudulent financial statements ever existed or
were filed. To the best knowledge and belief of Conversion
Solutions and me, all certified financial statements were
true and correct at the time that they were filed. I am not a
CPA and would have no knowledge of any misstatements in
financial statements.
Allegation D: INJUNCTIVE RELIEF
33) Alana Black is attempting to allege self-serving
facts that do not apply to Conversion Solutions or to me.
There was no massive fraudulent scheme on the part of
Conversion Solutions or me. Everything contained in any
filings, reports or releases was true and correct to the best
knowledge and belief of Conversion Solutions and myself at
the time they were filed. I have proof and witnesses to
substantiate the truthfulness of every release, report and
filing.
Allegation E: HARRIS SHOULD BE BARRED FROM ACTING AS AN OFFICER OR DIRECTOR IN THE FUTURE
34) This is an allegation that has no merit. This Court
entered an order allowing Conversion Solutions and me to
continue operating the Corporation as usual. Nothing has
transpired to change the reason for allowing me to continue
as before. The fact is that the Plaintiff (SEC) and the
Plaintiff’s attorneys have prevented Conversion Solutions and
me from doing any further business because they seized all
company records and will not grant me access to those
records.
Allegation F: CIVIL PENALTIES SHOULD BE IMPOSED
35) I have no knowledge of any misstatements,
omissions, fraud or any security violations committed
by me that would give rise to any civil penalties. The
only losses sustained by shareholders were caused by
the SEC and its attorneys when they filed a lawsuit
that is without merit and halted trading of the CSHD
stock and then allowed it to later continue trading
without enforcing any compliance with Rule 15c2-11 of the General Rules and Regulations promulgated under the Securities Exchange Act of 1934, this can be proved via discovery. Alana Black prevented me from drawing down on the bonds which would have funded the business. Alana Black is responsible for any shareholder loss.
Allegation G: ADDITIONAL INFORMATION AND REQUEST FOR HEARING
36) Alana Black makes an erroneous statement that there were fraudulent misrepresentations that caused shareholder losses rather than her own unethical and fraudulent actions. I also request a hearing to present witness testimony to show that all filings, reports and releases were truthful and accurate and that no fraud or misrepresentation was done by Conversion Solutions or by me, as well as testimony to show that any and all shareholder loss was due to the unethical actions of the Plaintiff and especially attorneys Alana Black and Bill Hicks.
37) Due to the refusal of the Plaintiff and its attorneys to furnish any disclosure required by Rule 26 F.R.C.P., this Defendant needs additional time for preparing and filing supplemental affidavits and documentation beyond the originally requested January 2, 2008 date. The enlargement needed is 30 days from the date that the Plaintiff completes all discovery allowed under all Federal Rules of Civil Procedure.
I, RUFUS PAUL HARRIS a/k/a PAUL RUFUS HARRIS, after
being duly sworn according to law, do state and affirm,
under penalty of perjury, that the facts set forth in
the foregoing SUPPLEMENTAL AFFIDAVIT IN SUPPORT OF MOTION
FOR RECONSIDERATION AND IN OPPOSITION TO PLAINTIFF’S MOTION
FOR DEFAULT JUDGMENT AND SUPPORTING MEMORANDUM OF LAW
are true and correct to my best knowledge and belief.
----------------------------------------------
Oh yeah everything was copied to the following;
United States Attorney General U.S. Department of Justice 950 Pennsylvania Avenue, NW Washington, DC 20530-0001
Office of the Attorney General State of Georgia 40 Capitol Square, SW Atlanta, GA 30334
There has also been another filing sudmitted and 2 more to follow!!! Posts: 65 | Registered: Dec 2007
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"Now if someone wants to write letters to the SEC now, just take the FACTS provided in the filing and see if you get a response to them!!!!
What you will get is another poor attempt to point everything at me as a “PLAN” to scheme!!!!
I am going to start a signature letter to go to a few selected individuals on the Hill, It will be posted on my site Gabreeders.com via PDF, WORD and works, if interested print it out, sign and fax it to the numbers provided!!!
It is now time to flood the fires with gasoline and end this illegal activity!!!!
Rufus Paul Harris
P.S. Yes the filing was received by the clerk but just has not made it to the Pacer system for some reason!!!! Where is that person that always called the clerk to see if anything has been received in the past!!! What hapen to you!!!" Posts: 65 | Registered: Dec 2007
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This, to me, is the most telling point in the filing...
"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."
Now it doesn't get any worse than this. They are wanting the convertible noteholders money returned!!! Not one damm word about the shareholders money. We see who they care about, and who they are protecting, and it sure as hell ain't us. Of course, we knew this.... it smells of bribery.
Posts: 65 | Registered: Dec 2007
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This actually looks very compelling! The statements made by Rufus make him sound like Perry Mason! If true, and I think that many of them are since some of the claims and presentations do make a lot of sense, this could drag on for years in the courts.
quote:Originally posted by thesource: No but he could very well be picked up at court if he's got a bench warrant from the failure to appear on his last DUI court setting . I would also bet they are going to MTR (motion to revoke) his current probation since he's received another DUI charge .
None of this has anything to do with the SEC case , I just thought it was funny where it said "HABITUAL VIOLATOR" . That sounds like Dufus to me ........
You are seriously reaching now........
So, did you get that Pacer account like I suggested some time ago? Theres a new filing to check out.
edit : never mind I see LT helped out. Thanks LT Posts: 2308 | From: Michigan | Registered: Jun 2006
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quote:Originally posted by TimW: Lawyers are corrupt, I think he wants to go as far as he can alone. Plus they always want a HUGE piece of the pie..
And thats the shareholders pie
Its america, its apple pie, and its made with GOLDEN delicious! Rufus for president!
^lol Darn i think i should go get some koolaid for lunch.
Well, he could use the excuse that since the SEC is holding the the company assets and/or bond he has no funds to hire a lawyer?? Posts: 2498 | Registered: Mar 2006
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Well the SEC didn't allow him to draw down on the bonds, so yea wheres he going to get funds for a lawyer from?
Posts: 854 | From: Alpharetta, GA | Registered: Mar 2006
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Thats his problem . When the IRS comes in and seizes accounts from businesses , the fact that they are cash broke so they cannot hire legal counsel does not fly in court . Its just like ignorance of the law is not an defense either .
-------------------- ----- Game Over ----- Posts: 1536 | From: San Antonio - Texas | Registered: Oct 2006
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So how else is rufus going to get legal counsel without funds? Going to give them magic fairy dust?
Posts: 854 | From: Alpharetta, GA | Registered: Mar 2006
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quote:Originally posted by thesource: No but he could very well be picked up at court if he's got a bench warrant from the failure to appear on his last DUI court setting . I would also bet they are going to MTR (motion to revoke) his current probation since he's received another DUI charge .
None of this has anything to do with the SEC case , I just thought it was funny where it said "HABITUAL VIOLATOR" . That sounds like Dufus to me ........
You are seriously reaching now........
So, did you get that Pacer account like I suggested some time ago? Theres a new filing to check out.
edit : never mind I see LT helped out. Thanks LT
IMO please do not waste anymore time responding to him.If EVERYONE ignores him, maybe he will go away.I doubt it because he seems to like to argue.He has stated he has no shares, no interest blah , blah, so let him go to a board of one of the other places that he was pumping awhile back.He can no longer say that he is "protecting" other people from buying in.If the SEC had requested RPH's request to kept this on halt, than we would all be in a better place.
Have a great day!
Posts: 360 | Registered: Aug 2006
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