Deep Blue Marine et al v. Krajewski - OCR extract Part 4
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91. On or about April 20, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"CPRK is not doing well and either is Wilf who is involved in both companies. DPBE and CPRK are both under investigation because of WHAT Wilf did. Not anything I said, but his actions."
92. The preceding statement is false and falsely alleges criminal and unlawful conduct by Blum.
93. On or about April 23, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"I guess the saying goes. 'He's laughing all the way to the bank.' He certainly has more then one Golden Goose, but I hear that he may be paying the piper pretty soon."
94. The preceding statement is false and misleading and implies criminal conduct by Plaintiffs and a criminal investigation against Blum.
95. On or about April 23, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"My statements are not misleading. If Wilf is talking to investors by phone and is giving them inside information. That is illegal. He has to release information publicly. He is not doing that. He has promised from the beginning to keep investors informed. He isn't doing that either. This is a public company, as jrf30 so well pointed out. The CEO has committed multiple SEC violations. (Just like he did when he called a few select investors in Key West, before the stock went up, because of events he told them about, before it was released to the public)."
96. The preceding statement is false and misleading and implies criminal and
unlawful conduct by Blum.
97. On or about April 23, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"I think the investors should be more concerned about the SEC investigation of DPBE's [Deep Blue Marine] CEO. Now from what I just told, It's a lot worse then just the SEC. The Board of Directors might have to look for someone else to run the Company, if there is going to be a Company."
98. The preceding statement is false and misleading and implies criminal and
unlawful conduct by Blum.
99. On or about April 23, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"The SEC Attorney's went to that particular office 2 times taking statements. On the third visit, they brought the Court Reporter. In my opinion that is a Red Flag. On another note. Since the Staff of DPBE is monitoring this board. I'd like to know why they aren't responding to the numerous questions that other posters have asked them on this board'?'?'"
100. The preceding statement is false and misleading and implies criminal and unlawful conduct by Deep Blue and Blum.
101. On or about April 23, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"We now know from you[r] DD that there is a file on DBPE, I suggest that you also ask your friend about a specific file on the CEO about another company and ask him what happens when the SEC Attorney's take a court reporter with them. If you would have read into my post, I said that there was an on going investigation by Federal Authorities that wasn't part of an SEC investigation."
102. The preceding statement is false and misleading and implies criminal and unlawful conduct by Deep Blue and Blum.
103. On or about April 23, 2008, Defendant Krajewski published the following statements on I-hub's Deep Blue Marine message board:
"I hear you my friend. I just have a hard time trying to see where the CEO put $800K into this Company. If the CEO spent 2.4 million of investors money. I think that is too much for what was produced, but to say he put in another $800K in unbelieveable. No I take it back. He paid Capt Joe and Himself $800K."
104. The preceding statement is false and falsely alleges criminal conduct by Blum.
105. On or about April 25, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"Maybe it would be better to pay a security guard a few bucks to watch the Deep Scan, then to pay Capt. Joe $72,000 a year to sit on his butt in Key West."
106. The preceding statement discloses Deep Blue proprietary information regarding employees of Deep Blue and their salaries in direct violation of the Non- Disclosure Agreement.
107. On or about April 29, 2008, Defendant Krajewski published the following statement on I-hub' s Copper King Mining Corporation message board:
"I'll tell you very concisely how WB can dilute publicly traded mining stock. When he gives himself and his friends 10's of millions of shares for putting the deal together and promoting the stock and then sells them."
108. The preceding statement is false and falsely implies criminal improprieties by Blum.
109. On or about April 30, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"I would like to know 2 things concerning the $800K that Wilf said[] that he put into the company. If he is allowed to raise 1 million dollars a year thru DPBM stock sales, and he raised that money. #1. Where did the 2 million go that the investors put into the company? (Besides all expenses paid family vacations.) #2. Where did the $800K11] come from that he loaned DPBM? (He filed for bankruptcy a few years ago. I guess he made it somehow. I'm wondering if it came from the stock that he gave Alexander Lindale and his other companies for promoting DPBM and then sold when the stock hit $1.01 a share). Well I guess running a pink sheet company is pretty good, if you don't have to file financial reports."
110. The preceding statement is false and misleading implying among other things that Blum misappropriated company funds and that Blum obtained funds loaned to the company by illicit means.
111. On or about May 3, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"Jeeper, I don't think there is a reasonable explanation of why the CEO made the decision that he did in picking the 3 wrecks that he picked in the DR.A CEO with any experience in this business would not have picked wrecks without treasure on them. Every knowledgeable person in the Treasure Salvage business knows that you have to do a survey based on research to locate a treasure wreck. Apparently Tracey Bowden did the research, but the CEO of this company didn't want to conduct the survey to find the Treasure Wreck. I call that incompetent, and the ones paying for the incompetence are the stock holders."
112. The preceding statement discloses Deep Blue proprietary information regarding, among other things, locations, discoveries, sources of supply.
113. On or about May 4, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"Once again. I am not the one that has taken investors money. So it doesn't matter if I'm diving in the DR or not. You should worry about who is using the money that was invested and how it is used. Yes Tracey B. made out like a bandit. He sold Wilf the Scipion 20 years after he found it. He sold him the rights to 2 Spanish Ships that are in an Underwater Nature Preserve, which probably means that those wrecks can never be salvaged. Now if those wrecks can't be salvaged and someone took money for them. I would call that at the very least bad business practices for Tracey B. as well as the person that runs the Company and never looked into the fact that he could never salvage 2 wrecks, that he paid several hundred thousand dollars for. I might even call that criminal. The only one that is sure to make money on this deal is Tracey Bowden. $300K for the salvage rights to 3 wrecks. 2 of which probably can't even be salvaged. $3K a day for the lease of Tracy's boat. Yes, Tracy made out very well."
114. The preceding statement is false and discloses Deep Blue proprietary information in violation of the Non-Disclosure Agreement.
115. On or about May 5, 2008, Defendant Krajewski published the following statement on I-hub' s Deep Blue Marine message board:
"If your dividends are coming from a Mr. Shupe [ President of Oceanic Research and Recovery] as Wilf stated on another board, I hope the company he was getting to take over the Key West operation wasn't Oceanic Research and Recovery. (ORRV) You might want to check this stock on Pink Sheets.Com yourself. It looks like trading has been suspended and there is an investigation because of the insiders associated with this company."
116. The preceding statement is false.
117. On or about May 5, 2008, Defendant Krajewski published the following statement on I-hub' s Deep Blue Marine message board:
"The Company (ORRV) is shut down from trading. What else do you need to know? I guess that just tells you a lot about the Company and President that are taking over the Key West Operation."
118. The preceding statement is false.
119. On or about May 5, 2008, Defendant Krajewski published the following statement on I-hub's Deep Blue Marine message board:
"I'm not the one drinking the Kool Aid. ORRV is shut down from trading. If that makes you happy, so be it. It means your dividend shares are worthless."
120. The preceding statement is false.
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