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6 BY MR. JUDD: 7 Q. Are you familiar with whether Amazon filed with the SEC 8 a form 10-KSB on November 20th, 19987 9 A. Yes. I don't know the date it was filed. I think it 10 was earlier than that. 11 Q. Is it your belief that Amazon filed with the SEC a form 12 10-KSB sometime in November, 19987 13 A. Yes. 14 Q. Is it your belief that in that form, Amazon stated to 15 the SEC that the company initiated legal action in the 16 Federal Courts in seeking the cancellation of another 17 9,740,000 shares of common stock? 18 A. Yes. 19 Q. And who are the defendants in those various legal 20 actions in the Federal Courts as of November 19987 21 A. Joseph Andy Mann, Charles Kricfalusi, Greg Pheifer, 22 Michael Zapara.
23 Q. Who? 24 A. Michael Zapara. 25 Q. Anyone else?
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1 A, No. 2 Q. So Zapara action pertains to 540,000 shares? 3 A. Yeah. I got to double check on that. Hang on. Let me 4 add something up here. Can I -- I can't write on here.
5 THE CLERK: No. Don't write on there. That's an
6 exhibit.
7 THE WITNESS: No, no. I can add up.
8 THE COURT: Give him a blank piece of paper.
9 (Colloquy not on the record.) 10 THE WITNESS: I don't believe it includes Zapara. 11 BY MR. JUDD:
12 Q. You mentioned Andy Mann, and that is 4,000,000 shares? 13 A. It's Joseph Andy Mann, Shoreline, Whitecliffe, and
14 everybody named in the lawsuit.
15 Q. It was 4,000,000 shares in this case. 16 A. 4,480,000. 17 Q. 4,480,000. The next person you mention was Power
18 (phonetic)? 19 A. Charles Kricfalusi, Greg Teifer (sic), Wanda Kricfalusi 20 (phonetic), Nextech.
21 Q. Nextech involves 224,000 shares, correct? 22 A. Yeah. 23 Q. Now, this Faluchi (sic) -- 24 A. It's all part of the Nextech/Greg Teifer conspiracy. 25 Q. So Nextech, Teifer, and the Faluchis (sic) all involve
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1 the 224,000 shares. 2 A. 4,224,000 restricted shares, not -- not no reg S, just 3 totally restricted preferred shares.
4 Q. 4,224,000 shares. 5 A. Preferred shares, yeah. 6 Q. Where are the balance of the 9,740,000 shares in
7 dispute?
8 A. Well, you have 4,480,000 plus 4,220,000. 9 Q. Where's the balance of 9,740,000.
10 MR. LANDISH: And my math is off. I'm sorry.
11 BY MR. JUDD: 12 Q. I understand --
13 A. Okay. What's the difference? How many share 14 differences are you looking at, and let's see if I can 15 remember. 16 Q. I think I'm looking at a million some odd thousand 17 shares. 18 A. No, no. Well, maybe it includes Michael Zapara. I can 19 check because its -- its got to be listed of all the shares 20 of everything that -- that was illegally issued by the group 21 of Andy Mann, Charlie, and et cetera, et cetera. 22 Q. Are you contending that Andy Mann is associated with 23 Charlie? 24 A. I know Andy Mann is associated with Charlie, and we 25 intend to prove that.
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1 Q. Who is Charlie? 2 A. Charlie Kricfalusi, the gentlemen who introduced us to 3 Andy Mann and Greg Teifer (sic). You see, it's the group.
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