| Gray Cary Tries To Obtains First-of-its-Kind Contempt of Court Order Against Alleged Cybersmearing Defendant Floyd Schneider 
 (Neptune, N.J.) August 27, 2000*** Gray Cary who lied to the judge in the "First-of-its-Kind Retraction Order Against Cybersmearing Defendant"  declares War on Free Speech.
 
 One of the highlights of Gray Cray's case is that Floyd Schneider lied about globe trotter and Boiler Room Operator Lynn Briggs being a past President of Ziasun. On must wonder if Secretary of State of Nevada, Good Old Dean Heller will also be brought into the suit for defamation and slander against Ziasun since it was the State of Nevada's web site where the following record was obtained well over a year ago. This time Gray Cary has omitted VPLEPA's and Francois Goelo's affidavit's to support the contempt of Court motion. I wonder why? Maybe its because Goelo in a post said "Ziasun Sucks" or the many posts by VPLEPA which told of the whole dirty truth about Ziasun and the boiler Rooms. Its hard to use someone that says he was given information on press releases prior to them becoming public and now says he would file a affidavit agaist Ziasun. He is a good man.
 
 
 Dean Heller
 Nevada Secretary of State
 Corporate Information Name: ZIASUN TECHNOLOGIES, INC.
 Type: Corporation File Number: 6100-1996 State: NEVADA Incorporated On: March 19, 1996
 Status: Current list of officers on file Corp Type: Regular
 This corporation is in good standing.
 Resident Agent: GATEWAY ENTERPRISES, INC. (Accepted)
 Address: 3230 E. FLAMINGO ROAD SUITE 156 LAS VEGAS NV 89121
 President: LYNN BRIGGS  Address: 4987 S. KINGS ROW CIRCLE
 SALT LAKE CITY UT 84117
 Secretary: JENNIFER MCMINN
 Address: 4987 S. KINGS ROW CIRCLE SALT LAKE CITY UT 84117
 Treasurer: JENNIFER MCMINN
 Address: 4987 S. KINGS ROW CIRCLE
 SALT LAKE CITY UT 84117
 
 But then again its hard enough to believe anything Gray Cary says since Ziasun runs
 Globe Trotter Lynn Briggs web site;
 
 Registrant:Momentum Campaigns Ltd (IASSET-DOM)
 17th Floor, 53 - 55 Lockhart Road Wan Chai, Hong Kong 00000 HK
 Domain Name: IASSET.COM
 Administrative Contact, Technical Contact, Zone Contact, Billing Contact:
 Domain Registrations (DR560-ORG) domreg@MOMENTUMPLUS.COM
 Momentum Internet Inc PO Box 71, Craigmuir Chambers
 Road Town, Tortola 00000 VG +852 - 28778059
 Fax- - ‹=ª‹˜¡h‹=q Record last updated on 21-Oct-1999.
 Record expires on 29-Jul-2000. Record created on 28-Jul-1997.
 Database last updated on 29-Apr-2000 05:11:43 EDT.
 Domain servers in listed order: EXODUS.MOMENTUMPLUS.COM 209.164.39.195
 LEVITICUS.MOMENTUMPLUS.COM 209.164.39.197
 NS2.MOMENTUM.COM.HK 210.176.85.38
 
 But then again the truth was finally obtained in the latest InterNIC domain name change that International Asset Management is really part of Torquay Associates, Ltd. tenkwizard.com
 
 Registrant:Torquay Associates, Ltd (IASSET3-DOM)
 Parkland 5, Unit 10260, 1219/5 Bangna   Road 5   Bangkok, 00000   TH
 Domain Name: iasset.com
 Administrative Contact, Technical Contact, Zone Contact, Billing Contact:
 Registrations, Domain  (RD2645-ORG)  domreg@IASSET.COM
 Torquay Associates, Ltd.      Parkland 5, Unit 10260, 1219/5 Bangna
 Road 5      Bangkok, 00000      TH      662 745 9170
 Record last updated on 05-Jul-2000.   Record expires on 05-Jul-2001.
 Record created on 05-Jul-2000.
 Database last updated on 27-Aug-2000 04:18:52 EDT.
 Domain servers in listed order:   EXODUS.MOMENTUMPLUS.COM	209.164.39.195
 LEVITICUS.MOMENTUMPLUS.COM	209.164.39.197
 NS2.MOMENTUM.COM.HK		210.176.85.38
 
 But then again Gray Cary is relying on Ziasun's SEC filings and the many amended 10SB's from their accountant Jones and Jensen;
 
 UNITED STATES SECURITIES AND EXCHANGE COMMISSION
 sec.gov
 SECURITIES EXCHANGE ACT OF 1934
 Release No. 42828/ May 25, 2000
 
 ACCOUNTING AND AUDITING ENFORCEMENT
 Release No. 1261/ May 25, 2000
 
 ADMINISTRATIVE PROCEEDING
 File No. 3-10210/ May 25, 2000
 
 Proceedings Instituted Against R. Gordon Jones and Mark F. Jensen
 
 The Commission has instituted public administrative proceedings pursuant to Rule 102(e) of the Commission's Rules of Practice against R. Gordon Jones and Mark F. Jensen, two CPAs in Salt Lake City, Utah. Jones and Jensen are charged with having engaged in improper professional conduct by recklessly violating professional accounting and auditing standards in their audit of the 1995 financial statements of a now-defunct Utah corporation, Dynamic American Corporation. Jones, the engagement partner, was primarily responsible for the audit field work. Jensen performed the concurring partner review on the audit.
 
 The Commission previously instituted public administrative proceedings against Dynamic and six individuals based on a 1996 "pump and dump" scheme by which about $4 million in Dynamic stock was sold to the public. See, In the Matter of Jethro J. Barlow, CPA, et al., Exchange Act Rel. No. 41689 (August 2, 1999; In the Matter of Dynamic American Corporation, Exchange Act Rel. No. 41688 (August 2, 1999).
 
 In the order, the Division of Enforcement alleges that Dynamic's financial statements, included in the company's amended annual report on Form 10-K/A filed in November 1996, were not prepared in conformity with GAAP. Specifically, the staff contends that Dynamic's balance sheet improperly listed as an asset certain Bolivian mining properties that were materially overvalued at $36,600,000, or 91% of Dynamic's total consolidated assets. Furthermore, in performing their audit of Dynamic's 1995 financial statements, Jones and Jensen also did not act in accordance with GAAS in that they: failed to adequately plan the audit; failed to obtain sufficient competent evidential matter; failed to maintain an attitude of professional skepticism; failed to exercise due professional care in the performance of the audit; failed to issue a proper audit report with respect to the work performed by other auditors; and by using a lower-of-cost-or-market analysis, did not test the balance sheet presentation of certain "ore concentrates" valued at approximately $4.3 million.
 
 A hearing will be held before an administrative law judge to determine whether the staff's allegations are true, and if so, whether Jones or Jensen should be censured or temporarily or permanently disqualified from or denied the privilege of appearing or practicing before the Commission.
 
 One must wonder if Steven Rogers EVER corrected among other things, monitoring message boards, like Raging Bull, and correcting any inaccuracies or misinformation about ZiaSun and any of its subsidiaries. He was too busy signing up under multiple alias's and hyping Ziasun and Titan Motorcycle of America.. It was Steve would was caught by Gus Sidaris defendant. I really do not know why he is even considered one of the Ziasun8 since none of the other 7 defendants even know who he is or posted when he was posting. Ziasun still maintains he is part of a conspiracy. Steve on SI stated it was his company that did public relations in Asia. Later on in amended SEC filings we would find out why Steve was touting Titan Motorcycle. Seems Ziasun had HUGE amounts of stock in Titan Motorcycle that was obtained from related parties and 50,000 shares Titan Motorcycle restricted stock and two Titan Motorcycles which New Age publishing was paid to promote the company. Later in The Wall Street Journal article we would find out exactly how Titan Motorcycle fit into the Boiler Rooms operations. I am sure that discovery will produce the findings if this investigation.
 
 By: PresCEO $
 Reply To: None  Sunday, 28 Mar 1999 at 12:47 AM EST
 Post # of 25574
 
 
 ZIASUN TO INVESTIGATE
 
 Steven Rogers is an employee of Momentum Asia Inc, a wholly-owned subsidiary of ZiaSun Technologies Inc (ZSUN).
 
 Mr Roger's responsibilities include, among other things, monitoring message boards, like Raging Bull, and correcting any inaccuracies or misinformation about ZiaSun and any of its subsidiaries.
 
 We will be looking carefully at Mr Roger's recent activities on Raging Bull to ascertain whether he has overstepped his brief, and (if deemed necessary) take appropriate action.
 
 ZiaSun is a serious company with a great future, which we do not want jeopardized.
 
 I am not a regular follower of this message board. Too busy working on a number of exciting projects about to be launched and/or expanded!
 
 But, I would be happy to answer any questions by e-mail.
 
 Anthony L Tobin
 President and CEO
 ZiaSun Technologies Inc
 atobin@ziasun.com
 www.ziasun.com
 
 The there is Bryant Cragun. How does he fit into Titan Motorcycle which has a good chance of go belly up?
 
 Gee, the origional Titan Motorcycle prospectus says "Intestment Manager: International Asset Management, Barceloa Spain, Via Augusta 13-15, Suit 612, 08006, Barcelona, Spain, tel 34-3-217-5204 fax 34-3-416-0492 and International Asset Management, Brussels, Avenue Louise 149, box 40, 1050 Brussels,Belgium, tel: 32-2-535-7550 fax 32-2-535-7549.
 
 Titan Index, Oh Goodie, #2 ties everything in very nicely
 "Bryant Cragun , the third-party investor, is the principal of an investment banking firm that has assisted the Company in capital raising functions."
 TITAN MOTORCYCLE CO OF AMERICA INC filed this 10SB12G/A on 09/02/1998.
 tenkwizard.com.
 1) thetruthseeker.business.directnic.com
 
 2) thetruthseeker.business.directnic.com
 
 3) thetruthseeker.business.directnic.com
 
 4) thetruthseeker.business.directnic.com
 
 5) thetruthseeker.business.directnic.com
 
 6) thetruthseeker.business.directnic.com
 
 7) thetruthseeker.business.directnic.com
 
 8) thetruthseeker.business.directnic.com
 
 9) thetruthseeker.business.directnic.com
 
 10) thetruthseeker.business.directnic.com
 
 ===============================================
 "Bryant Cragun , the third-party investor, is the principal of an investment banking firm that has assisted the Company in capital raising functions."
 
 TITAN MOTORCYCLE CO OF AMERICA INC filed this 10SB12G/A on 09/02/1998.
 
 tenkwizard.com
 ====================================================
 the lets not forget oxford
 
 The letter dated 11/26/99 with the letter head PT. Pasifica Pratama Investindo signed by William Strong (President) .The one that says PT. Pasifica Pratama Investindo purchased Oxford International Management, Inc a Philippine registered company in August of 1997. Its funny though because I do not see it on his NASDR employment history.
 Kind Sir, for your viewing pleasure. Oh Goodie. Ziasun is in there.
 209.130.49.78 (says PT. Pasifica Pratama Investindo purchased Oxford International Management, Inc a Philippine registered company in August of 1997. Its funny though because I do not see it on his NASDR employment history.)
 
 209.130.49.78 (TITAN MOTORCYCLE OF AMERICA)
 
 209.130.49.78 (UNIFORMS OF AMERICA, HOMEFOOD CLUB)
 
 209.130.49.78 ( Hartcourt)
 
 209.130.49.78 (HartCourt, Ziasun)
 
 209.130.49.78 (CHEQUEMATE INTL INC)
 
 209.130.49.78 (CHEQUEMATE INTL INC)
 
 Promissory Note with Oxford International Management dated December 9, 1996. 10.10 Modification of Promissory Note with Oxford International Management dated December 16, 1997. 10.11 Promissory Note with Oxford International Management dated July 22, 1999
 
 TITAN MOTORCYCLE CO OF AMERICA INC filed this S-3 on 10/15/1999
 tenkwizard.com
 ====================================================
 
 Bryant Craguns letter dated 2/7/97 Chairman OXFORD INTERNATIONAL MANAGEMENT, INC. to veiw origional fortunecity.com
 
 OXFORD INTERNATIONAL MANAGEMENT, INC
 
 February 7, 1997
 
 To our valued clients,
 
 Due to the recent reports in your local media criticizing offshore brokers, discount brokers or a stock wholesaler. Oxford serves as an investment manager focusing on the funding of emerging growth companies. We operate as a venture capital management company. Our aim is to identify young growth companies, participate in ownership through funding these companies and ultimately benefit from their success. Our investment philosophy is not one short term quick profits but long term steady growth. We have shared that philosophy with our clients and client companies since our beginning in 1991.
 
 Oxfords management spends extensive time working with the management of our client companies. We have enclosed messages from the chief executive officer of each company acknowledging Oxford's role in their development and our professionalism.
 
 A point of clarification about the Power Report. The Power Report is an independent market news letter used by investors, investment managers and brokers from New York to London to Hong Kong. The overall advice given in the report over the past years has been outstanding. All investment services world wide use the same tool, which include market research, reports and news releases all communicated via the telephone. As investors, it is important to qualify who is giving you investment advice. The fastest way to qualify any investment service is to qualify the advice or recommendation given by contacting the company directly. We welcome any of our clients to call or visit any of our client companies. Oxford is proud of its past and current client companies and their success which has been shared by clients.
 
 We are aware of a small number of groups, representing themselves as retail brokers or stock wholesalers, who have recently ( Within the last two years) begun operating in Manila.
 
 When requested by our clients to research some of their recommendations, we have on many occassions reported back to the company either did not exist or was substancially different from had been represented. Unlike many media sources, we refuse to instill panic in the investing public with scaremongering.
 
 If there is any additional information we can provide for you, please call your Oxford representative. We look forward to a long term and profitable relationship.
 
 Yours Sincerely,
 
 (His signature here)
 
 Bryant D. Cragun
 Chairman
 
 Suite 1402, 14th Floor, PDCP Bank Centre, 8737 Paseo de Roxas corner Makati City, Philippines Swithchboard (632) 893-7713 * Fax (632) 817-0709 * Direct (632) 892-1994 * Fax (^32) 892-6989
 
 ZIASUN MAKES front page of todays wall street journal
 
 Beyond the SEC's Reach, Firms Sell Obscure Issues to Foreign Investors
 
 By JOHN R. EMSHWILLER and CHRISTOPHER COOPER
 Staff Reporters of THE WALL STREET JOURNAL
 please visit wsj.com
 
 The call couldn't have been timed better. Adrian Lawlor, a Dublin computer-systems salesman, and his wife had just received a $17,000 settlement from a car accident his wife had been in when a broker from International Asset Management in Brussels rang him up. Speaking with an American accent, the broker told Mr. Lawlor he had just the ticket for entering the red-hot U.S. stock market.
 
 "They said they had a wonderful investment opportunity for me," Mr. Lawlor says.
 
 Although "absolutely green" when it came to stocks, Mr. Lawlor decided to sink most of the settlement into the broker's recommendations. That was in 1996, and he was happy for a time and unruffled when his broker moved from Brussels to Barcelona, Spain. But then he tried to sell some shares of a small-cap issue that had begun to stumble. The broker said he would make the sale only if Mr. Lawlor agreed to plow the proceeds -- and $10,000 more -- into shares of a tiny California company called ZiaSun Technologies Inc.
 
 A Matter for the Police
 
 Mr. Lawlor refused and then complained to Spanish regulators. Though the brokerage was based in Barcelona, Spanish regulators said they had no jurisdiction because IAM apparently didn't sell to Spaniards. "If you consider this situation a matter of fraud," Spanish regulators wrote, "the normal procedure is to get in touch with the police."
 
 Instead of calling the police, Mr. Lawlor managed to sell some shares "by complaining bitterly to my broker." But still, he hasn't been able to unload his biggest holding, a stake in a troubled start-up that he bought for $6,000 and that is now worth about $90. He has lost contact with his IAM broker, who went by the name Steve Young.
 
 "An Irish citizen buying U.S. stocks through a dealer based in Spain," Mr. Lawlor says. "The whole experience made me realize how alone I was."
 
 Alone in a growing crowd, that is. Nurtured by economic liberalization and the steady rise in U.S. markets over the past decade, legions of Europeans and Asians have developed a strong appetite for stock investments. Much of the focus is on the U.S.; in just the 12 months ended March 31, foreigners bought $2.8 trillion worth of U.S. shares, up 65% from the previous 12 months, the U.S. Treasury says. After accounting for stock sales, net foreign purchases totaled $159.6 billion during the period. About 85% of that was from Europe.
 
 Many Affiliates, Many Names
 
 But as the global investor base broadens, a big problem has arisen: Investors are often venturing into a gray area that national regulators are either unable or unwilling to police. And that makes them particularly vulnerable to the likes of International Asset Management. This outfit and its many affiliates operating under many names throughout Europe and East Asia buy shares in small, obscure U.S. companies, some linked to IAM through equity or other ties, and then sell the stock to foreigners who often are ill-informed about the companies they are investing in, the difficulty of trading the stock and their own lack of regulatory protection.
 
 IAM officials turned down repeated requests for interviews and have refused to identify the precise location of their Barcelona offices.
 
 In recent years, investors from Athens to Australia have purchased millions of dollars of stock in U.S. companies from IAM and its affiliates. Many, like Mr. Lawlor, have found themselves unable to sell their shares or even get stock certificates, and nearly all are unable to get help from regulators.
 
 Sudden Disappearance
 
 Guy Fletchere-Davies, a 62-year-old carpet manufacturer in Melbourne, Australia, bought ZiaSun and other small U.S. stocks over several years from the Manila office of Oxford International Management, a brokerage firm with ties to IAM. Mr. Fletchere-Davies says his account was passed around among several Oxford salespeople and then to a successor firm. Late last year, "suddenly, the phone calls stopped and paperwork dried up," he says.
 
 The Australian has since embarked on a frantic telephone journey from Manila to Jakarta to Manhattan to the British Virgin Islands in hopes of learning the fate of the nearly $150,000 that was to be his retirement nest egg. "We don't know who to talk to,'' he says. "We don't know where to go."
 
 Nikolas Morokutti, a 26-year-old owner of a computer business in Innsbruck, Austria, thought he knew where to go when he had trouble getting his ZiaSun share certificates from IAM. He called the U.S. Securities and Exchange Commission. The agency, he says, told him that it couldn't help because the shares were issued under Regulation S.
 
 These Regulation S stock sales are allowed under a 10-year-old provision of U.S. securities law that is intended to allow American public companies to raise capital from experienced foreign investors without the onerous registration process required to sell stock in the U.S. Once sold abroad, Regulation S shares cannot legally be resold to U.S. investors for at least a year; they can, however, be sold to other foreigners during that period.
 
 While hundreds of perfectly legal and legitimate S-share transactions occur each year, unscrupulous operators have found a way to exploit Regulation S to their advantage. The way it often works, a promoter that is at least nominally based outside the U.S. buys large blocks of S shares from American issuers at deep discounts and then sells them at huge markups to neophyte investors abroad.
 
 The SEC doesn't comment on specific cases and won't comment on the current state of Regulation S. Non-U.S. regulators aren't much help either, though they periodically warn citizens to avoid boiler-room brokers operating outside of their home country. British stock regulators recently noted a sharp rise in the number of boiler rooms in continental Europe that target English residents. "The firms are not registered here, so it's up to our counterparts in other nations to regulate them, which is very frustrating," says Sarah Modlock of Britain's Financial Services Authority.
 
 A Lot in Common
 
 Over the past few years, IAM and related brokerage firms have marketed shares in about a dozen small U.S. companies. Overseas customers of IAM's offices in Barcelona often receive a monthly publication called "The Capital Growth Report," which mixes glowing reviews of the small companies in IAM's stable with commentary about well-known companies such as Compaq Corp. Several of the small companies have held stock in each other, used the same investor-relations firm or employed Jones, Jensen & Co., a Salt Lake City accounting firm, which is auditor of ZiaSun, a company that looms large in IAM's pitches.
 
 In May, the SEC filed administrative charges against the accounting firm's two named partners, R. Gordon Jones and Mark F. Jensen, for "recklessly violating professional accounting and auditing standards" in an audit of a company unrelated to ZiaSun. Mr. Jensen denies wrongdoing. Mr. Jones didn't return phone calls.
 
 The tale of IAM and its affiliates is deeply entwined with that of ZiaSun, based in Solana Beach, Calif., just north of San Diego, in a modest ground-floor office suite nestled between a freeway and the sea. An IAM affiliate has an address on the same floor of a Hong Kong office building as ZiaSun's office in that city, and ZiaSun maintains the Web sites of IAM and of some of its affiliates.
 
 ZiaSun has operated under various names since it was founded and went public in 1996, and it has engaged in businesses ranging from motorcycles to soda dispensers. In news releases, it now bills itself as "a leading Internet technology holding company focused on international investor education and e-commerce." About 85% of ZiaSun's 1999 revenue came from a business that operates traveling seminars on Internet stock trading for $2,995 a pop. "You Can Become a Millionaire on Regular Pay," says one seminar flier.
 
 In an April 1999 news release, ZiaSun said its 1998 audited earnings totaled $1.15 million, on $3.5 million in revenue. When the company filed financial results with the SEC last September, the audited 1998 sales had dropped to $2.3 million. In a later SEC filing, ZiaSun again revised downward its 1998 sales, to $760,529, and cut net income to $769,320. ZiaSun earnings included profits from securities transactions involving other public companies. Some of ZiaSun's securities holdings include companies that also issue large amounts of Regulation S stock and whose shares have been sold by IAM and affiliates.
 
 ZiaSun officials decline to be interviewed, citing a pending lawsuit filed by ZiaSun in federal court in San Francisco against a group of Internet critics of the company for allegedly mounting a "cybersmear campaign" against ZiaSun. In a written statement in response to written questions, ZiaSun officials say they are "fully committed to preserving and developing the shareholders' equity."
 
 More than half of ZiaSun's own 27 million shares outstanding have been sold to foreigners under Regulation S, according to the company's SEC filings. In two transactions in 1997, ZiaSun sold 15 million shares at 10 cents a share under Regulation S to foreign investors, whose identities didn't have to be disclosed in public records. At about the same time, investors in Europe and Asia say they received calls from salesmen from IAM and related brokerages offering ZiaSun stock at $4.50 or more a share. In the U.S. during the same period, ZiaSun, under previous corporate names, was trading on the Nasdaq Bulletin Board at between $1.25 and $5.50 a share on average daily volume of several thousand shares.
 
 Vladimir Kaplan, a Zurich doctor, bought some of those ZiaSun S shares. His Barcelona-based IAM broker, Lynn Briggs, offered ZiaSun at $4.50 a share on Oct. 7, 1998 -- when the stock was trading in the U.S. for between $2.50 and $4 a share. Unable at the time to independently determine ZiaSun's stock price, Dr. Kaplan bought nearly 8,000 shares to start, and more over the ensuing weeks. Dr. Kaplan knew his broker as a senior portfolio manager at IAM and trusted his judgment, especially after Mr. Briggs flew to Zurich to make a personal sales call. What he says he didn't know: According to SEC filings, Mr. Briggs also was one of ZiaSun's founders. Mr. Briggs couldn't be located for comment.
 
 Tapping Overseas Buyers
 
 Titan Motorcycle Co., a Phoenix, Ariz., motorcycle manufacturer, is another favorite of IAM brokers. Between 1996 and 1998, Titan issued about 5.3 million shares of Regulations S securities in chunks to unidentified overseas buyers for an average price of $1.32 a share, even as clients such as Dr. Kaplan were purchasing stock in the company for far more. According to SEC filings, about a third of the company's total shares outstanding have been sold to foreigners.
 
 Titan officials didn't return calls. In a brief written statement, Titan Chief Executive Frank Keery said that all company Regulation S sales "were conducted precisely as required by law." Titan's "knowledge of subsequent resale activities is essentially nil as these resales take place exclusively outside the U.S.A.," he added.
 
 ZiaSun and Titan have something in common besides IAM. Bryant Cragun, a former president and chief executive of ZiaSun and now a consultant to the company, describes himself in court documents as "investment adviser and fund-raiser" for ZiaSun, Titan and other small companies whose shares are sold by IAM and related brokerages. He co-owns four Titan motorcycle dealerships.
 
 Several investors say their brokers referred to Mr. Cragun as a senior official of IAM. Stefan Van Rooyen, a Swiss investor, says he was told by his Barcelona-based broker in June that Mr. Cragun was IAM's president. A recent SEC filing shows IAM has the same U.S. address as Mr. Cragun, at a gated condominium project in Solana Beach, not far from ZiaSun's headquarters.
 
 In a letter, Mr. Cragun says he was never an IAM officer. He says he leases the condominium in Solana Beach. He acknowledges that between 1991 and 1997, he was chairman of Oxford International, a Philippine brokerage firm that markets many of the stocks IAM touts and that, according to SEC filings, has bought Regulation S shares in two such companies.
 
 Mr. Cragun says the SEC spent five years investigating his role in selling Regulation S shares overseas and "never filed anything against me." An SEC spokesman declines to comment. An offering statement for an overseas investment fund founded by Mr. Cragun says he has a U.S. securities broker's license. The National Association of Securities Dealers says its records show that Mr. Cragun hasn't held a license since 1988. Mr. Cragun, in a written response, says that putting his license status in the present tense was a "typographical error."
 
 Mr. Cragun says he sold his interest in Oxford in 1997 to a company headed by William Strong, who shows up as an account representative on monthly statements received by several IAM customers. Mr. Strong, who says he was merely an IAM consultant, confirms that he bought Oxford. He says IAM and Oxford are "essentially the same company. They are two different entities in the same arena with the same people."
 
 In an April filing, Titan said it issued 724,638 shares of Regulation S stock early this year to Oxford International in connection with a 1996 loan. As Oxford's owner, Mr. Strong says he never received any of the stock (doing so could violate Regulation S, since he's an American). Titan officials didn't respond to questions on this matter.
 
 No Outward Signs
 
 In Barcelona, IAM has in the past shared offices, telephones and personnel with at least three other brokerage firms -- including one owned for at least a time by Mr. Strong. But the exact location of IAM's current office is a mystery. A phone receptionist provides only a mailing address. That address leads to a small office building that has no identifying signs and that on three visits during business hours was locked and dark. Another location, often cited on IAM's correspondence, is an unmarked and rundown suite of offices in an unfashionable part of town staffed by a woman who appears to run a phone service for dozens of companies. A woman who answered the phone at the firm's Manila office said all sales operations had ceased.
 
 Several investors say their brokers, though hard to locate, have recently been pushing them to exchange stock in ZiaSun and other companies for shares in a British Virgin Islands-registered mutual fund called the Morgan Fund. Mr. Fletchere-Davies says he agreed to move his money into the Morgan Fund as an alternative to losing a large chunk of his investment in individual stocks, though he says he has been told he might not be able to cash out of the fund for at least several months.
 
 A Morgan Fund brochure shows that Mr. Cragun, the former ZiaSun executive and former Oxford owner, is one of the fund's two directors. Mr. Cragun says he set up the fund because buying companies' shares directly "is way too much risk to individual investors."
 
 Write to John R. Emshwiller at john.emschwiller@wsj.com and Christopher Cooper at christopher.cooper@wsj.com
 
 I wonder if John Emshwiller and Christopher Cooper will file a truthful afadivit in the latest episode? They know much much more which is going on and would make great witnesses. Gray Cary's client Bryant Cragun is getting desperate. Its going to get a lot hotter on the Ziasun Island....
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