From wamex.com. Very interesting: The Complaint [1-2]
ubb.wamx.com
_____________
Author Topic: Here it is guys - easiest to read from Wamex E-group e-mail
noWAMIES
Member posted 06-20-2000 02:35 PM
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t:
USA v. Cushing, Chhimenti, Detrano, Hidalgo
Date:
Tue, 20 Jun 2000 14:27:37 -0400
From:
Debbie Checkum
To:
wamex@egroup.com
I obtained a copy of the following Legal Complaint from Sharon Walsh of
the Washington Post. I called the press office of the US Attorney's
office to ask for a copy, however, since I'm not a press member was
referred to another section in which it would have taken more than
likely several weeks to obtain a copy. I asked them if there was any
legal reason why the reporter could not give me a copy. The said no, so
Sharon Walsh agreed to fax me a copy. It IS a legit. copy. Reads as
follows:
Approved: (Patrick J. Smith)
(Assistant United States Attorney
Before: HONORABLE FRANK MAAS
(United States Magistrate Judge)
(Southern District of New York)
SEALED COMPLAINT: (Stamped - 00MAG>1118)
Violations of 18 USC, SS 371, 2; 15 USC SS 78j(b) and 78 ff
COUNTY OF OFFENSE: New York
United States of America
v.
MITCHELL CUSHING
RUSSELL CHIMENTI
ROGER DETRANO AND
ANTHONY HIDALGO
Defendants
SOUTHERN DISTRICT OF NEW YORK SS.:
JOHN BROSNAN, being duly sworn, deposes and says that he is a
Special Agent with the Federal Bureau of Investigation, and charges as
follows:
COUNT ONE
(Securities Fraud Conspiracy)
1. From in or about December 1999 to the present, in the Southern
District of New York and elsewhere, MITCHELL CUSHING, RUSSELL CHIMENTI
AND ROGER DETRANO, the defendants, together with others known and
unknown, unlawfully, willfully and knowingly did combine, conspire,
confederate, and agree together and with each other to commit offenses
against the United States, to wit, securities fraud, in violation of
Sections 78j(b) and 78ff of Title 15, United States Code, and Title 17,
Code of Federal Regulations, Section 240. 10b-5.
2. It was a part and object of the conspiracy that MITCHELL CUSHING,
RUSSELL CHIMENTI AND ROGER DETRANO, the defendants, together with others
known and unknown, unlawfully, willfully, and knowingly, by the use of
the means and instrumentalities of interstate commerce, directly and
indirectly, would and did use and employ manipulative and deceptive
devices and contrivances, in violation of Title 17, Code of Federal
Regulations, Section 240.10b-5 by (a) employing devices, schemes and
artifices to defraud; (b) making untrue statements of material facts and
omitting to state material facts necessary in order to make the
statements made, in light of the circumstances under which they were
made, not misleading; and (c) engaging in acts, practices and courses of
business which operated and would operate as a fraud and deceit upon a
person in connection with the purchase and sale of Wamex Holdings Inc.
securities.
3. In furtherance of said conspiracy and to effect the objects thereof,
the following overt acts, among others, were committed in the Southern
District of New York and elsewhere:
a. on or about February 18, 2000 ROGER DETRANO, the defendant, attended
a meeting at the Marriot Financial Center Hotel in New York, New York.
b. on or about April 25, 2000, MITCHELL CUSHING and RUSSELL CHIMENTI,
the defendants, caused Wamex Holdings, Inc. to issue a press release.
(Title 18, United States Code, 371.)
COUNT TWO
(Securities Fraud)
From in or about January 2000 to the present, in the Southern
District of New York and elsewhere, ANTHONY HIDALGO, the defendant,
together with others known and unknown, unlawfully, willfully and
knowingly, by the use of the means and instrumentalities of interstate
commerce, directly and indirectly, would and did use and employ
manipulative and deceptive devices and contrivances in violation of
Title 17, Code of Federal Regulations, Section 240.10b-5 by (a)
employing devices, schemes and artifices to defraud; (b) making untrue
statements of material facts and omitting to state material facts
necessary in order to make the statements made, in the light of the
circumstances under which they were made, not misleading; and (c)
engaging in acts, practices and courses of business which operated and
would operate as a fraud and deceit upon a person in connection with the
purchase and sale of Ramoil Management Inc. Securities.
(Title 15, United States Code, Sections 78j(b) and 78ff; Title 18,
United States Code, Section 2.)
The bases for my knowledge and for the foregoing charges, are, in
part as follows:
4. I am a Special Agent of the Federal Bureau of Investigation (the
"FBI"). I am assigned to a squad at the FBI's New York Field Office
that is responsible for the investigation of white collar crime,
including securities fraud. I am also a certified public accountant.
The information set forth in this Complaint is based upon by debriefings
of a cooperating witness ("CW-1"), my review of tapes and transcripts of
conversations recorded pursuant to a court-authorizerd monitoring
device, consensually recorded conversations, public filings, witness
interviews and the examination of other documents obtained during the
investigation. Because the limited purpose of the Complaint is to
establish probable cause for the arrest of the above-named defendants,
the defendant, I have not set forth all the facts I have learned in the
course of this investigation.
Background to the Investigation
5. I and other agents have conducted extensive debriefings of CW-1.
CW-1 has pleaded guilty to a felony information in te Southern District
of New York pursuant to a cooperation agreement with the United States
Attorney's Office for the Southern District of New York. CW has
provided reliable information concerning the unlawful activities of
others that I and other Agents have been able to corroborate through
independent investigation, including interviews of other witnesses,
review of pertinent records and review of recorded conversations.
6. Since early 1995, CW-1 has been a principal in DMN Capital
Investments, Inc. ("DMN Capital"), an entity that held itself out as a
financial advisory firm that could assist development stage and
micro-cap companies in raising capital. DMN Capital, together with
several related entities, including Crabbe Capital Group Ltd ("Crabbe
Capital") maintained its office a 5 Hanover Square, New York, New York.
7. CW-1 was an associate of the Bonanno Crime Family of La Cosa Nostra
("LCN") and participated in the affairs of DMN Capital and related
entities under the supervision of Robert A.Lino, a soldier and later a
capo in the Bonanno Crime Family. Prior to CW's arrest and cooperation
with the Government, DMN Capital, among other things, orchestrated a
series of manipulation schemes that, collectively, fraudulently induced
investors at numerous brokerage firms into buying in excess of #25
million in securities. To facilitate these schemes, DMN Capital and
others gained secret control of Monitor Investment Group, a
broker-dealer registered with the United States Securities and Exchange
COmmission (SEC). DMN Capital paid substantially in excess of $5
million in cash bribes to brokers at Monitor and elsewhere to induce
them to participate in these schemes by causing their customers to buy
and hold (or "put away" stock. CW-1 and his partners at DMN Capital
paid a portion of the illegal proceedings of these schemes to Lino and,
in return, Lino provided, among other things, protection and
representation in disputes with LCN-affiliated brokers and stock
promoters arising from the illegal stock fraud activity.
8. At the discretion of the FBI, CW-1 has continued to pose as a
corrupt principal of DMN Capital and Crabbe Capital. CW-1 has
participated in negotiations with numerous persons who have sought his
assistance in engaging in a wide variety of securities fraud schemes,
including schemes to manipulate the market for publicly traded stocks,
to secretly bribe stock brokers to "put away" stock, and to defraud
investors in private placements of securities. In addition to schemes
in which DMN Capital and Crabbe Capital were to be active participants,
CW-1 has also engaged in extensive meetings and telephone conversations
with persons who have sought his advice in structuring fraudulent
transactions.
9. On or about December 1, 1999, the Government applied for and
obtained the first of five orders authorizing the FBI to intercept and
record oral communications occurring in DMN Capital's office. Pursuant
to these court orders, the FBI installed and monitored two eavesdropping
devices in DMN Capital's office, one in the conference room and one in a
separate office, or "desk area" (together, the "DMN bug"). The FBI
conducted 104 days of monitoring and recording over the DMN Bug between
December 1, 1999 and May 4, 2000. Although I have not done an exact
calculation, I estimate that the FBI obtained at least approximately
1000 hours of audiotapes during the five months of monitoring.
10. I am familiar with the DMN Bug recordings because I have personally
listened to hundreds of hours of tapes and prepared summaries and draft
transcripts of pertinent conversations, and have reviewed summaries and
draft transcripts prepared by other agents. In addition, either I or
another agent responsible for this investigation debriefed CW-1 on a
regular basis via telephone, among other purposes, to identify
participants in conversations that had occurred that day at DMN Capital.
Relevant Persons and Entities
11. At all times relevant to the Complaint, Wamex Holding, Inc.
("WAMEX") was a New York corporation. As of early 2000, WAMEX
maintained its principal place of business at 3040 Nostrand Avenue,
Marine Park, New York. On or about April 1, 2000, WAMEX established an
office in 1 World Trade Center, New York, New York. WAMEX was
purportedly in the business of developing an alternative securities
trading system. WAMEX's common stock traded on the OTC Bulletin Board
under the ticker symbol "WAMX".
12. At all times relevant to this Complaint, Ramoil Management Ltd.
("RAMOIL") was a Delaware corporation that maintained its principal
place of business at 7 Penn Plaza, New York, New York. RAMOIL's common
stock traded on the OTC Bulletin Board under the ticker symbol "RAMO."
RAMOIL held itself out as, among other things, a general contractor in
the hotel development business.
13. At all times relevant to this Complaint, INYC.COM was an Internet
service provider that maintained its principal place of business at 3040
Nostrand Avenue, Marine Park, NY.
14. At all times relevant to this Complaint, MITCHELL CUSHING, the
defendant, was WAMEX's chief executive officer. CUSHING, according to
WAMEX's public filings and its own website, directed the business
affairs of WAMEX.
15. At all times relevant to the Complaint, RUSSELL CHIMENTI, the
defendant, was WAMEX's chief administrative officer. CHIMENTI,
according to WAMEX's public filings and its own website, had managerial
responsibility for, among other things, developing WAMEX's Alternative
Trading System.
16. At all times relevant to the Complaint, ROGER DETRANO, the
defendant, was a New York based stock promoter.
17. At all times relevant to the Complaint,ANTHONY HIDALGO, the
defendant, among other things, owned and operated "INYC.COM" and
directly owned an interest in WAMEX.
Material False Statements Regarding WAMEX's Purported Business
18. I have inspected press releases, WAMEX's March 14 Form 8-K, WAMEX's
website "www.wamex.com" as well as other materials gathered by the
Enforcement Division of the SEC. These materials reveal the following.
a. WAMEX's common stock began publicly trading on the OTC Bulletin
Board in December 1999 after it engaged in a reverse merger with another
company. It its initial press release dated December 9, 1999, WAMEX
described itself as
as internet and technology company dedicated to creating and dominating
an efficient alternative market and exchange for individual and
institutional investors.
The WAMEX lead product, Alternative Trading System, addresses one of the
largest and most active industries wordwide. The System enables a
community of self-empowered investors to consummate transactions more
efficiently and at a lower cost.
b. WAMEX has issued a series of press releases in which WAMEX
represented that it would open and operate an "Alternative Trading
System" for individual investors. For example, in a press release dated
June 7, 2000, WAMEX described this system as follows:
THE WAMEX Alternative Trading System (ATS) empowers investors to
consummate transactions more efficiently and at a lower cost. The WAMEX
ATS provides alternative pools of liquidity for its members and enables
them to trade directly with each other. This dynamic creates the
possibility of price enhancement that is not available to investors
within the current market structure. The ATS will allow investors to
trade amongst themselves, therefore eliminating the losses associated
with proprietary trading so commonly employed against individual
investors. This trading system is bound to become the major alternative
to trading securities on traditional markets and exchanges.
c. In press releases issued during May 2000, WAMEX has stated that July
4, 2000 will be "independence day" for investors and that its ATS will
be "deployed" on that date.
d. WAMEX's website, www.wamex.com, likewise claims that February 4,2000
will be "independence day." on several occasions since early May 2000,
most recently today, I have viewed a video clip on www.wamex.com that
purports to describe how WAMEX's ATS will "empower" investors by, among
other things, freeing them from fees imposed by broker-dealers.
19. I have been advised by the SEC Enforcement Staff that WAMEX is not
a registered broker-dealer and has not filed a Form ATS with the SEC.
(1) (Footnote 1 - "ATS" refers to alternative trading system SEC
regulation ATS requires that any alternative trading system be a
registered broker-dealer and give notice of its operations to the SEC on
Form ATS.) In addition, while WAMEX has announced its acquisition of a
NIPHIX, Inc., a registered broker-dealer that had previously filed a
Form ATS with the SEC, WAMEX has not sought or obtained approval for its
supposed acquisition of NIPHIX. The SEC enforcement staff has further
advised me that, given these facts, WAMEX cannot lawfully operate an ATS
in the manner it has repeatedly represented to the public as early as
July 4, 2000.
20. My review of WAMEX's many press releases shows that both MITCHELL
CUSHING and RUSSELL CHIMENTI, the defendants, frequently gave direct
quotes on the nature of WAMEX's business and the prospects for success
of WAMEX's proposed ATS.
Material False Statements Regarding WAMEX's Source of Funding
21. The SEC Enforcement Staff has advised me that, in a series of press
releases and a Form 8-K filed with the Commission, WAMEX has claimed
that it has obtained substantial funding for its business operations.
These statements are materially false and misleading, among other
things:
a. According to the Form 8-K filed on March 14, 2000, WAMEX stated that
it had raised $1.8 million in "convertible debt" from "a foreign
company" that was later "converted into equity." The Form 8-K fails to
disclose that the "foreign company" was the World Auction Market and
Exchange, PLC, a Gibraltar entity that is majority owned and controlled
by MITCHELL CUSHING, the defendant, and the other principal officers of
WAMEX.
b. The Form 8-K further represents that in November 1999, WAMEX "was
successful in placing a $1,000,000 offering under Rule 504 of Regulation
D to private investors." WAMEX failed to disclose that the $1,000,000
"offering" involved the sale of a $1 Million debenture convertible into
shares of common stock at $.05 per share to BVH Holdings, LLC ("BVH").
According to a check register produced by WAMEX to the SEC Enforcement
Staff, the monies "loaned" to WAMEX under the terms of the debenture
were not received until February and March 2000. However, MITCHELL
CUSHING and RUSSELL CHIMENTI, the defendants directed WAMEX's transfer
agent to issue 19.5 million shares of free trading common stock to BVH
in December 1999 and February 2000. Shortly thereafter, all 19.5
million shares were transferred from BVH to Randolph Management, Inc., a
consulting firm controlled by ROGER DETRANO, the defendent. Through
February 2000, Randolph transferred 2.9 million shares to an account in
the name of Dottenhoff Financial Ltd. ("Dottenhoff") at Union Securities
in Vancouver, Canada. Between January and March 2000, Dottenhoff sold
approximately 16.4 million in proceeds. A portion of those funds were
sent by Dottenhoff to DETRANO, who, in turn, paid a portion of those
monies to WAMEX. Thus, the monies due under the "debenture" were
advanced by DETRANO from the proceeds that DETRANO received from the
public sale of free-trading common stock that had been issued at the
direction of CUSHING and CHIMENTI.
c. On April 25, 2000, WAMEX issued a press release entitled "WAMEX
Holdings, Inc. Consummates Transaction for $6.9 million in Funding from
Private Investment Group." MITCHELL CUSHING, the defendant, was quoted
in this press release and referred to the "closing of $6.9 million in
funding from an Investment Group." In a May 12, 2000 press release,
WAMEX referred to the purported $6.9 million financing as follows:
"WAMEX recently raised $6.9 million dollars to deploy on July 4th,
"Independence day for investors" -- its proprietary WAMEX Alternative
Trading System (ATS)." According to CUSHING, who testified before the
SEC on June 6, 2000, this funding related to a convertible debenture
issued to Randolph Management, Inc. the company controlled by DETRANO.
CUSHING admitted that DETRANO had made payments of less than $1 million
on the $6.9 million funding announced by WAMEX. RUSSELL CHIMENTI, the
defendant, in testimony before the SEC on June 7, 2000, gave a
conflicting explanation" CHIMENTI testified that the $6.9 million in
funding involves a transaction involving Credit Suisse First Boston and
no monies have been received by WAMEX on this transaction. Regardless
of whether one or both of CUSHING or CHIMENTI testified falsely, each
has caused WAMEX to fail to disclose to the public that WAMEX has not
actually receivedf either any or most of the $6.9 million that it
supposedly "acquired" or "raised" as rerouted in the April and June
press releases.
DETRANO'S Offer to Bribe Brokers to "Put Away" WAMEX Stock.
22. On February 15, 2000, two conference calls took place in DMN
Capital's conference room among ROGER DETRANO, the defendent, CW-1 and
others, including a corrupt stock broker ("The Broker"). In this
conversation, DETRANO offered The Broker and his partner a 20% kickback
for retail sales. DETRANO requested a three to six months "put away"
period in return for the 20% payment. DMN Bug tapes reveal that the
following exchanges took place during these conversations, among others
(2) (Footnote reads: The summaries or recorded conversations set forth
in this Complaint are based upon draft transcriptions of portions of the
conversations and are not verbatim accounts of the conversations. Voice
identifications are in part based upon further debriefings of CW-1 and
are in part contextual. "UI" refers to a portion of the recording that
the preparer deemed unintelligible at the time of preparation of the
draft transcription.)
a. The Broker "All kidding aside, how long do you wanna it held for?
DETRANO: What I wanna know is what you're doing. Most of the people we
deal with, on a stock like this, tell us what the're doing. If you're
telling me that your gonna loosen some up, I wanna know you're loosening
it up. The Broker: Well, there's a three-to-six month month holding
period. That works? DETRANO: That works. And you're lookin' to buy
three hundred, you want a thousand. The Broker: Between three and
four, figuring on the (UI) called you earlier. It's easier buyin'
things on the way up than it is buying things on the way down.
b. DETRANO: Well it depends on what I pay you. How much ... (UI)
Normally on something like this I would probably do somewhere around
twenty percent.
c. The Broker: And how would that be accommodated? DETRANO: In
paper. I'd deliver paper whereever you tell me or... The Broker: Could
it be done the other way? DETRANO: I don't know. I'll have to (UI).
Let me come back to you.
d. DETRANO: What I'll do is I'll give it to you in paper and I'll buy
ir right back from you, so you'll have the cash. I can't do it the
other way. I just can't. I don't do that. I don't have the
capability. The Broker: We're gonna have to work a little closer on
those numbers for that price. DETRANO: How are you planning on doing
the acquisiiton ..one shot, one day?, two, three days? The Broker:
Probably three or four days. Fifties in a clip. DETRANO: Okay, That
can work.
23. On February 18, 2000, CW-1 attended a breakfast meeting at the
Marriott Financial Center hotel with ROGER DETRANO, the defendant. The
broker and the Broker's partner. CW-1 wore a recording device during
the meeting. During the meeting, DETRANO reiterated his offer to pay
20% on retail sales of WAMEX stock generated The Broker. DETRANO and
CW-1 discussed the fact that The Broker would recruit other brokers who
would in turn be paid off. DETRANO stated that 20% was a fair payment
because he intended to work the "bid" higher (increqse WAMEX's share
price). CW-1 and DETRANO discussed the means of payment; transfers of
stock to brokerage accounts controlled by The Broker and his partner and
them simply buying the stock back, thereby generating cash in the
Broker's brokerage accounts. DETRANO guarangeed CW-1 that if he bought
two hundred thousand shares, the stock would not go to 2 or 3 dollars.
(3) (Footnote - WAMEX closed at 8 3/16 on February 18, 2000.) CW-1
asked DETRANO if he wanted to stock locked up for a minimum time
period. DETRANO replied that he did not want to see the stock "back
in his face." DETRANO then asked if CW-1 wanted to be a "trading
partner" in WAMEX. DETRANO propsed having CW-1 buy large blocks of
stock with DETRANO agreeing to buy it back later. DETRANO also
explained that WAMEX did not have a big float and that "the float is
very tightly controlled for the outstanding."
24. WAMEX's share price increased from $1.12 per share on December 9,
1999, to $19.50 per share on February 28, 2000. In my experience
investigating securities manipulation schemes, bribes to retail brokers
who agree to "put away" stock coupled with tight control of free trading
shares, or "float" is an effective means of artificially inflating the
price of a security.
HIDALGO'S Plan To Bribe Brokers and Fund Managers to Sell His Personal
Holdings of WAMEX and RAMO
25. According to CW-1, in or about late March 2000, ANTHONY HIDALGO,
the defendant, sought CW-1's advice in connection with the sale of his
interest in INYC.COM, in a stock for stock transaction with RAMOIL. In
the course of these discussions, HIDALGO revealed details of the scheme
to defraud investors in WAMEX. HIDALGO was a friend and business
partner of MITCHELL CUSHING and RUSSELL CHIMENTI, the defendants, who
had, among other things, previously worked with CUSHING and CHIMENTI in
a fraudulent securities sales operation in Europe (4) (Footnote reads
HIDALGO revealed the details of this prior relationship in a
conversation recorded on the DMN Bug on April 27, 2000) and had
permitted WAMEX to base its operations at INYC.COM's office in Marine
Park, New York. HIDALGO was also working with ROGER DETRANO, the
defendant, among other things, in negotiating the terms of the sale of
INYC.COM to RAMOIL. DETRANO and a partner ("The Promoter") have worked
the RAMOIL deal in similar fashion to WAMEX.
26. RAMOIL, according to its press releases, used the same public
relations firm as WAMEX: DeMonte Associates. RAMOIL's trading history
has also been similar to WAMEX's RAMOIL's price rose from $8.25 on
January 7, 2000 to $11.50 on February 25, 2000, never trading more than
10,000 shares per day. The price then rose to $20 in just two trading
days on volume of 150,000 on February 28, 2000 and 502,100 on February
29, 2000. A five for one split was declared on April 14, 2000.
27 In conversations with CW-1 recorded on the DMN Bug, ANTHONY HIDALGO,
the defendant, revealed detailes of the schemes:
a. On March 31, 2000, the followikng exchanges took place with respect
to RAMOIL:
1) CW-1: Let me lay it out for you. You know you gotta be a little
distanced from what's goin on here cause this is a whole big ****in
scheme. HIDALGO: That's why we (UI) We got stabilization clause and
all these other clauses. CW-1: Who's gettin the S-8 shares and how you
gettin them offshore. (5) (Footnote S-8 stock refers to stock registered
with the SEC on Form S-8. Such registrations are permitted for the
issuance of stock to company employees and certain bona fide
consultants. S-8 stock may not be issued to raise capital. In my
experience, fraudulent S-8 stock is a typical device used to place cheap
or free stock in the hands of promoters who need stock to sell to pay
off brokers.) Who's doin that for you? HIDALGO: ROGER (DETRANO)
CW-1 Roger is supposed to take care of that.
2) CW-1; But they're juicing up RAMO too. HIDALGO: Yeah. (UI) let
them juice it. CW-1: Tell me how you play. You got accounts up in
Canada? You got Prime Broker accounts? HIDALGO (UI) CW-1: If you
wanna lay it out in advance. Get some liquidity without them ever
knowing. HIDALGO: (UI). They get paid to (UI). CW-1: We understand
that. Buy how much did they pay for their RAMO shares about 10 cents?
HIDALGO: About 20 cents.
b. On March 31,2000 the following exchanges took place with respect to
WAMEX:
(1) CW-1: You got these WAMEX shares but what if ehey shut that ****in
stock out? HIDALGO: It's not real. There's no revenues. CW-1 I'm
not picking on it. You're making ridiculous news claims. They have like
a $300 million market capitalization. HIDALGO: More. (UI) CW-1: You
can't do that ****, they're promoting stupidity. They're goiung wild.
They're making ridiculous claims. That they can never fulfill.
HIDALGO: I agree. CW-1: What if they stop tradin on this thing?
HIDALGO : I consider it a loan (UI). CW-1: Why's that? HIDALGO:
Cause I don't believe him. I don't trust him. I know it's bull****.
(2) HIDALGO: ROGER calls the shots here. ROGER does all the
negotiating. They met (The Promoter) WAMEX was the first deal they did
together. ROGER and (The Promoter) (UI). CW-1 (We want nothing to do
with (UI) and this guy ROGER. HIDALGO: If he's the one promoting it
what is ROGER doing?
28. Over the next several weeks, ANTHONY Hidalgo, the defendant,
explored with CW-1 ways to exploit the fraudulently inflated markets for
WAMEX and RAMOIL by selling his own stock in transactions illegally
motivated by secret payments to brokers and fund mangers. In a
conversation recorded over the DNM Bug on April 27, 2000, CW-1 and
HIDALGO discussed how CW-1 could assist in selling RAMOIL stock if the
INYC.COM deal were to close. The following exchanges on this topic took
place, among others:
a. CW-1: So, if you get htis ****in' kid (in London) within three or
four days, I'll play with the spin out and I'll participate in that as
well. Now when (The Promoter) starts promoting your deal, cause I know
you ca control the (UI), not (The Promoter), I can then start to do what
I have to do, if you control INYC. HIDALGO: I've always controlled
it. We might not control the float when he has it..CW-1: You can
control the transfer agent, meaning, I can start getting liquid into
(The Promoter's) buying. HJIDALGO: which means that you can help me.
CW-1: on the short side. HIDALGO: and you can help me on the flip
side. CW-1: and you can give me the fill when you get the money. Now
I could also put brokers on the thing when we start gettin' goin' but
it's probably gonna cost me thrity percent, fourty percent to (UI) the
stock up. HIDALGO: Yeah, we can do it while he's runnin' the stock
up. CW-1: Yeah. You don't have any problems with that right?
HIDALGO: No.
b. CW-1 You got any way to get cash? HIDALGO: What do you mean?
CW-1 Stock deal. In other words, do you have any way to launder like a
hundred (UI) for real money. HIDALGO: Yeah. CW-1 (How? HIDALGO: I
have a hundred in restricted RAMO stock that we can put out. CW-1:
No. I'm talkin' about gettin' cash so I could pay brokers. I'm not
givin' checks. HIDALGO: Yeah. I could probably get it. Don't you
have a way I could do somethin'? CW-1: Yeah, but I can't keep usin'
(UI) in certain ways. If you have a way, then do it.
c. HIDALGO: If I get this RAMO stock, will you help me get out of some
of it. CW-1: Sure.
29. The conversation on April 27, 2000 then turned to WAMEX and
HIDALGO's desire to sell a large block of restricted stock that he been
paid by CUSHING and CHIMENTI:
a. HIDALGO: Maybe some WAMEX stock too? CW-1: How much WAMEX stock do
you have? HIDALGO: Well, we're probably gonna do a different deal with
them. CW-1: W
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