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33. Matrix, its agents and associates, at the time those representations were made, were ignorant of their falsity and believed them to be true. For minimal fees [$15,000US] accrued over a period of six (6) years for the storage, handling and shipping of Purewater corporate records, Matrix delivered to Defendant, John Schmitz, those requested Purewater control shares of Stock (with legend) together with all available corporate records, save only the reservation of the Corporate Minute Book and the Corporate Seal to protect Matrix from unconsented and unauthorized action. But, had Matrix, its agents and associates, known the true facts, they would not have delivered those said control shares of Purewater stocks nor those available corporate records.
34. As a proximate result of the false representations of these Defendants, and each of them, and their pre-conceived unconscionable plan to steal these valuable assets of Matrix, then implementing this plan with a subsequent course of action, Matrix has been the victim of a blatant and illegal theft of Purewater Sciences International, Inc., and its remaining assets; and has been forced to initiate litigation incurring extensive attorney fees and costs and claims against unknown third persons amounting to undetermined damages according to proof at trial.
35. At all times herein mentioned, Defendants, and each of them, knew that Matrix, its agents and associates would unquestionably rely upon those representations of Defendants, and each of them, and the protection of that irrevocable requirement for removal of the legend on those said shares, as provided in corporate minutes, so as to restrict transfer and voting of those control shares and could be easily duped. Then, pursuant to their long-range plan, formed by Defendants, and each of them, joined to even prevent the sale of those remaining shares held by Matrix for Roberts and Shaw and, executed their illegal and amoral plan to steal and cheat Plaintiffs with their clandestine fraudulent, malicious and oppressive conduct caused Plaintiffs, Roberts and Shaw, to suffer great mental languish, mortification, humiliation and shame to their damage in amount of $5,000,000; and, because this |
