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To: Jeffrey S. Mitchell who wrote (15636)	1/12/1999 3:36:00 PM
From: Spider Valdez	Read Replies (1) \| Respond to of 26163

jeffy boy you better understand wellrich was shut down by sec, & you believe them over aznt lawyer & part time judge who was in supreme court in carson city & sylver who was with other aznt lawyer negotiating with defendant from federal case. yes jeffy we believe 'camera' story like we believe you & janice are scanning "judgement" wellrich won over aznt! lolololol ! September 2, 1998 Securities and Exchange Commission Washington, D.C. 20549 RE: United States Of America vs. WellRich & Company Attention: xxxxxxxxx xxxxxxxx Division of Enforcement RE: WellRich & Company Dear xxxxxxxx: As always it was indeed a great pleasure speaking with you today. Please find the requested information, I hope this will help you with your action. 1.xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 2.xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 3. WellRich is not a licensed broker/dealer, but may be functioning as such in violation of Section 15(a)(1) of the Securities Exchange Act of 1934 (the "Exchange Act"). See Polannin, John, Jr., "Finder's Exception From Federal Broker-Dealer Registration," CATHOLIC UNIVERSITY LAW REVIEW, Vol. 40, summer 1991, Number 4. 4. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 5. WellRich has not or does not have the ability to indemnify any company, In the event that the company is sued as a result of Wellrichs's actions. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx WellRich does not have adequate financial resources to compensate any company in the event of a judgment. 6. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx 7. WellRich receives compensation predicated upon a percentage of the sales price of the stock that they SOLICIT to people over the phone.xx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx. This establishes that WellRich is functioning as a broker/dealer. See SIDNEY MARKS, SEC No-Action Letter, 1977 No-Act LEXIS 2057 (July 7, 1977); JOHN DIMENO, SEC No-Action Letter, 1978 No-Action. LEXIS 2188 (Oct. 11, 1978); and RICHARD S. APPEL, SEC No-Action Letter, 1983 No-Act. LEXIS 2035 (Jan. 13, 1983). 8. All of the issues raised by this letter is enough to indite and convict WellRich of all charges. xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx. Yours Truly, xxxxxxxxxx xxxxxxxx ESQ. Attorney and Counselor At Law xxxxxx xxxx xxxxxxx Washington, D.C. xxxxx cc: State of California Securites And Exchange Commission State of Califirnia Office Of The Attorney General, Telemarketing Division. EFS:rab also guy AAA says this; This is in response to your e-mail sent to Ms. Willauer and Mr. Chin. The American Arbitration Association policy is that we cannot confirm or deny whether a given case exists with us, except with the parties involved. If a case exists with us, any and all information regarding the case is solely between the American Arbitration Association and the parties involved. Cindy 'so who gives your info guy? wellrich? ok guy allow janice to explain all this . she will have the chance i think. spider