Staff make the following specific allegations:
III. ALLEGATIONS
10. Staff make the following specific allegations:
Between February 6, 2006 and January 31, 2007, Vucicevich, Kore, DeVries, Banumus, Shah, and Sam Sulja directly or indirectly, engaged or participated in an act, practice or course of conduct relating to the securities of Sulja Nevada (for greater certainty, in this Part the securities of Sulja Nevada also include the securities of its predecessor companies Loftworks, Loftwerks, and Sulja Bros. Building Products Inc.) that they knew or reasonably ought to have known resulted in or contributed to a misleading appearance of trading activity in, or an artificial price for, the securities of Sulja Nevada contrary to section 126.1(a) of the Act;
Between February 6, 2006 and January 31, 2007, Vucicevich and DeVries traded securities of Sulja Nevada that was a distribution of the securities without a preliminary prospectus and prospectus having been filed and receipts having been issued for them by the Director and without an exemption from the prospectus requirement contrary to section 53(1) of the Act;
Between February 6, 2006 and January 31, 2007, Vucicevich and DeVries traded securities of Sulja Nevada while not registered in accordance with Ontario securities law to trade securities contrary to section 25 of the Act;
Between February 6, 2006 and January 31, 2007, Vucicevich and DeVries, directly or indirectly, engaged in or participated in an act, practice or course of conduct relating to Sulja Nevada securities that they knew or reasonably ought to have known perpetrated a fraud on other persons or companies contrary to section 126.1(b) of the Act;
Between February 6, 2006 and January 31, 2007, Sulja Nevada, Vucicevich, DeVries, and Steven Sulja made statements in the press releases of Sulja Nevada that they knew or reasonably ought to have known in a material respect and at the time and in light of all the circumstances under which they were made, were misleading or untrue or did not state a fact that was required to be stated or that was necessary to make the statement not misleading and would reasonably be expected to have a significant effect on the market price or value of Sulja Nevada securities contrary to section 126.2(1) of the Act;
Between February 6, 2006 and January 31, 2007, Sulja Nevada, Vucicevich, DeVries and Steven Sulja made statements in press releases being documents required to be furnished under Ontario securities law that, in a material respect and at the time and in light of the circumstances under which they were made, were misleading or untrue or did not state a fact that was required to be stated or that was necessary to make the statement not misleading contrary to section 122(1)(b) of the Act; and
Between February 6, 2006, and January 31, 2007, Banumus and Shah traded securities of Sulja Nevada as nominees of Vucicevich and participated in issuing misleading press releases and thereby acted as conduits for illegal activity which was conduct contrary to the public interest.
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