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Airing out some dirty pink sheet laundry – research

03 Feb Airing out some dirty pink sheet laundry – research



The following information is partially for my own personal reference in my ongoing research into the entire world of penny stocks - not just the pre-promo area.  The promoters are just a front for the insiders (in some cases they are the insiders), but there is another side to penny stocks that is often even more ugly than the pump&dump world that involves dirty toxic financing agreements and illegal stock dilution that often escapes the attention of the investment community and regulators because it occurs primarily on the unregulated non-SEC reporting pink sheet market.  For those that are interested in this ugly side of the penny stock world the following dot connecting may be interesting and/or enlightening.




Randall Goulding / Jonathan Leinwand next in line writing illegal attorney letters?

With Kimberly Graus (aka Kimberly Rudge), Carl Duncan, Guy Jean-Pierre under fire from the authorities and Brian Faulkner and Christopher Davies seemly out of the picture it looks like a certain large uniformed group of toxic financiers and penny stock manipulators are now turning to Randall Goulding and Jonathan Leinwand for the necessary legal opinions needed to keep their dilution scams/insider enrichment schemes running.

Recently Randall Goulding who was in APRU, ARTS, and PBHG did an attorney letter for Capital Art Inc (CAPA).

Prior to hiring Randall Goulding, CAPA was using now banned attorney, Carl Duncan.

Carl Duncan is well linked to Randall Goulding

They show up as associates in this Toxic Financing Settlement agreement with AccessKey IP (AKYI)

Duncan and Goulding used the same scheme in Apple Rush (APRU). They got a state court judgement then converted the obligation into free trading shares.

With APRU Goulding acted as legal counsel and debt Note holder participating on both sides of an illegal stock dilution scheme. The other main toxic financiers involved in APRU were Big Apple and Edward Bronson (Fairhills).

Carl Duncan and Randall Goulding both have roots through Chicago, IL

Randall Goulding has been the long time control person of an entity called Nutmeg Group LLC

"According to the SEC's complaint, Northbrook, IL-based Nutmeg serves as the general partner or investment adviser to 15 unregistered investment pools and claims to have assets under management of more than $32 million. Nutmeg and the Gouldings misappropriated more than $4 million in client assets by transferring them to third parties, and did not fully document the funds' investments. The SEC alleges that they improperly commingled fund assets and cannot value the funds' holdings, and as a result, net asset and other investment values have been incorrectly reported to investors. Nutmeg also has failed to keep required books and records or keep assets with qualified custodians, which has further put client funds at risk."

Page 23 of the following document gives us a partial list as of December 31, 2008 (more could have been added after December 31, 2008 and more exist that are not on that list):

Nutmeg Group LLC/Randall Goulding was named in SEC litigation which accuses Goulding/Nutmeg of falsifying debt Notes, falsifying financial statements, and misappropriating funds.

This amended complaint lays it out best

The litigation is still ongoing

Related link here naming Broker firm Transamerica Financial Advisors f/k/a InterSecurities and Harry Hal Hammond of the Hammond Financial Group for their roles

Without admitting the findings of the FINRA investigation, Harry Hal consented to a $10,000 fine and a 12 month suspension of his broker's license in the case.  Hammond also received a 12 month suspension from the Florida Office of Finance Regulation as a result of the case.

Nutmeg Group LLC/Randall Goulding was also named in a separate suit which involving H3 Enterprises Inc (HTRE) which used Guy Jean-Pierre as legal counsel

Here we have Nutmeg Group LLC named in a lawsuit involving Marine Exploration Inc (MEXP), Robert Stevens, and Paul Enright.

Enright and Stevens are often found hijacking dead Colorado entities that still publicly trade then selling the shells off to get used for a future pump&dump scheme. They have shown up in research I've done on BRYN from my EKNL report


Bryn Resources Inc (BRYN)

The Hijacking

BRYN was once an SEC reporting company registered in Colorado called RnetHealth Inc.

The RnetHealth Inc got abandoned in 2001.  The last SEC filing done by RnetHealth Inc was an 8K on October 19, 2001 announcing to shareholders that the business entity was broke and was filing for Chapter 11 Bankruptcy protection.

On October 1, 2002, the state of Colorado dissolved the entity because it hadn't filed its two previous annual reports and was delinquent in its taxes.

This is where the SEC dropped the ball.  the RnetHealth Inc shell should have been revoked for not doing any required SEC filings and not keeping its business license current.  Instead the SEC let the RnetHealth Inc shell continue to trade over the next 7 years leaving the door open for anybody to come in and hijack the shell and that is exactly what happened.

Robert Stevens came in and hijacked the RnetHealth Inc shell.   Robert Stevens has a long history of hijacking abandoned shells including the VLNX shell (see our VLNX report) then passing them on to crooked people to use for pump&dump schemes.  The reason why these hijacked shells usually end up in the hands of crooked people is because honest people wanting to run a legitimate business look for clean shells to purchase even though the price is usually higher.

Robert Stevens can be linked to such companies as Hoss Capital LLC, Technology Partners LLC, and SHC Capital LLC and is a former officer and very large shareholder in Marine Exploration Inc (MEXP).

Robert Stevens also runs a transfer agency called X-Clearing Corp located in Denver, Colorado together with his wife, Jodi K Stevens.  X-Clearing Corp is a wholly owned subsidiary of Fincor Inc (FINC).  Here is their website.  Here is a list of publicly traded companies they currently service. Jodi K Stevens is currently the CEO of Forever Valuable Collectibles (FVBC).

More on Robert Stevens and Paul Enright

Robert Stevens originally came in and hijacked the RnetHealth Inc with his partner, Paul Enright (Hoss Capital LLC, Technology Partners LLC, Marine Exploration Inc) on March 31, 2005.

Here is a great article about MEXP that mentions Stevens, Enright, and many of their entities.  Funny that the transfer agent for MEXP was Steven's, X-Clearing Corp and they had a controversy with a promoter that was paid in shares.

For whatever reason (maybe they couldn't find a buyer for the shell) they let the shell go delinquent again and once again get dissolved by the state of Colorado.

On January 11, 2008, Stevens and Enright returned to once again reinstate the dead shell.  This time they would end up finding a buyer = Rocco DiBenedetto.

Paul Enright is also a Director for Sierra Resource Group Inc (SIRG).  If you find Paul Enright's name attached to a Colorado entity that had once gotten dissolved, but is still publicly traded you can pretty much bet that he and Robert Stevens hijacked the abandoned shell and it will probably get passed off to be used for a dirty pump&dump in the future.

The passing of the shell

This time after hijacking the shell, Robert Stevens and Paul Enright were able to find a buyer for the shell, Rocco DiBenedetto.

On February 11, 2008, Robert Stevens filed a form 15 voluntarily terminating the registration of the RnetHealth stock so that the shell wouldn't have to report to the SEC any more.  Technically this was grounds for a suspension since you aren't allowed to terminate registration of your stock unless you are current with your SEC filings, but the SEC dropped the ball again.

Now with the shell hiding on the non-regulated OTC, Rocco DiBenedetto would have any easier time executing his pump&dump scheme.

Enter Diane Dalmy.  On November 25, 2008, Diane Dalmy did a filing with the Colorado SOS changing the name of the entity from RnetHealth Inc to Bryn Resources Inc and raising the authorized share count to 100,000,000.  Four months later in early April of 2009, Dalmy would file to raise the authorized share count again to 250,000,000.  Diane Dalmy is a banned SEC attorney that can be linked to several scam companies and several dirty penny stock individuals.

On November 25, 2008, BRYN did a 1:20 reverse split to wipe out all the previous shareholders so that the new owners of the shell could increase the value of their future holdings.


Newspaper articles put out by Medical Services International Inc. (MSITF) [Robert Talbott] and Tropical Beverage (TPBV) [Chris Lotito] go into detail about how Goulding pledged funds but required shares up front then sold the shares illegally to raise the funds to covering the financing agreement.

Turns out that before he was running this scam with Nutmeg Group, Goulding was running an identical scheme with an entity called Financial Alchemy LLC

It is obvious that Goulding sues and harasses to get control of companies just like Big Apple used to.


And what is up with this letter that talks about mail getting mixed up between Randall Goulding and Brian Lebrecht?

There is a definite link between Lebrecht and Goulding as this exhibit from the Nutmeg case shows:


From: Brian A. Lebrecht, Esq. [mailto:[email protected]]
Sent: Tuesday, June 02, 2009 11:55 AM
To: Bill Hartman; [email protected]; Randy Goulding; James R. Williams
Subject: INverso Status Update
Yesterday, I talked with Andrew, the enforcement attorney from the SEC who is involved in the Nutmeg
matter. Andrew’s position is that, because Randy is the sole officer and director of INverso, and because
Nutmeg funds own over 90% of the stock of INverso, that ANY transaction involving INverso must be approved by the Court first. I strongly disagree with Andrew, and so does Randy. Nonetheless, in light of all the facts and all the people involved, Randy has decided to seek approval from the Court before proceeding.


Brian Lebrecht links back to E Rex Inc with Big Apple, Carl Dilley, Marc Harris, Donald Mitchell, Jeffrey Harvey, Kyle Kennedy

Too many dots can be connected from there back to Orlando and Tampa Bay based individuals involved in lots of penny stock scams.

Lebrecht worked with M. Richard Cutler from 1996 - 2001 and had links to Pinnacle Business Management and Jeffrey Turino

More recently his named showed up in the SNPK filings.

Lebrecht learned before the Graus, Jean Pierre, Huffman, Essman era.

He is usually smart enough not to let his name show up in public filings.


Back to Randall Goulding

The OTC requires that an attorney letter must state to the best knowledge of counsel, after inquiry of management and the directors of the Issuer, whether or not the issuer of the Securities, any 5% holder, or counsel is currently under investigation by any federal or state regulatory authority for any violation of federal or states securities laws, and if so, the details of such investigation must be provided in such letter.

Read Randall Goulding's recent attorney letter again - No disclosure about his lawsuit:

We have Goulding and Carl Duncan working together again with Star8 Corp (STRH)

And once again we have Goulding failing to disclose his legal issues in his recent STRH attorney letter




Speaking of Attorney Letters missing required information

Jonathan Leinwand is now doing the attorney letters for abused/badly diluted/toxic shell ProTek Capital Inc (PRPM)

PRPM is run by Edward Vakser who was also CEO of ARTS and PBHG while those shells were being used by Big Apple, Bronson, Kramer and others for illegal dilution schemes.

Because of the way ARTS was illegally used for an insider enrichment scheme to illegally issue billions of shares to toxic financiers it got suspended by the SEC in June of 2011

An SEC investigation ensued and since that time several of the people involved in the ARTS scam have been named in litigation.

Guy Jean-Pierre

David Delaney (Delaney Equity Group) also names PRPM

Much much more here

Bottom line is that Jonathan Leinwand does not disclose in his PRPM attorney letters about the SEC investigation against Eddie Vaksar

Jonathan Leinward has been very active in other pink sheet tickers that can be linked to toxic financiers like Bronson and Kramer and Sason like Smart Holdings Inc (SMHS). Here is a list of his current issuers




More on ProTek Capital Inc (PRPM) (information I drafted in December)

So Edward Vakser moved from ARTS to PRPM

After what he did with ARTS how is he still allowed to be an officer of a publicly traded shell?

The PRPM ticker came back to life recently thanks some new OTC flings which include "letter of intents" news like this:

On November 30, 3012, the Company signed a letter of intent to acquire a hundred percent interest in Legal Clicks dot Com LLC.

On December 13, 2012, the Company signed a letter of intent to acquire a hundred percent interest in Superstar Management Group, Inc. in exchange for $350,000 in restricted shares of the Company

I see Gary Ball used to be in the PRPM filings as a debt holder. Look up some of the other shells he can be linked to (like AQLV). All crap.

And I see some entity known as Green Life Inc at 3011 Yamato Road, A-17, Boca Raton owns 800,000 preferred C shares convertible into 1000 common shares each for a total of 800,000,000 common shares

Green Life is controlled by Dr. Barry A Ginsberg

Dr. Barry A Ginsberg was involved in getting shares from other tickers recently named in litigation (CTYX, GRBG, SNDY, SUTI, EHSI, TDEY, and others)

Dr. Barry A Ginsberg also owned debt in World Series of Golf (WSGF) and Savanna East Africa (NVAE). Both WSGF and NVAE have another common link - James D Tilton Jr.

James D Tilton Jr was also an officer for Numobile Inb (NUBL). Another name connected to NUBL and NVAE is Philip Verges.

The name Philip Verges takes us full circle back to Protek Capital (PRPM) where Jonathan Verges was the CEO prior to Edward Vakser taking over in October of 2012.

Those preferred C PRPM shares used to belong to Owen Dukes and Robert Zysblat (they used to own 400,000 series C preferred shares each). Owen Dukes and Robert Zysblat are common names in several shells abused by toxic financiers like CLDR, AQLV, TDEY, NEGS, and others.

Why did they transfer those shares into Dr. Ginsberg's name? Does it really matter who holds the stock in name to the PRPM shareholders when they convert into 800,000,000 common shares and there is a CEO with a history of allowing free trading stock to be issued to insiders with no regard to the retail shareholders?

Edward Vakser illegally signed away over 69 billion shares in Artfest International (ARTS) to toxic financiers and other insiders causing ARTS shareholders to lose over $30 million over the course of less than 2 years which including a couple of huge reverse splits.

Edward Vakser got in bed with some very dirty players and caused ARTS to get suspended by the SEC.

PRPM has seen ridiculous amounts of volume since November 23, 2012 with well over 3 billion shares traded. All those trades and the stock price could not get above $.0004/share. That is a sure sign that hundreds of millions of newly issued shares have been getting dumped into the market. Probably a very ugly money laundering scheme in action.^PRPM


Is it a coincidence that Pacific Stock Transfer (Joseph Meuse) was the TA for all of these tickers:

Artfest International (ARTS)
PBS Holdings Inc (PBHG)
Aqua Liv (AQLV)
Protek Capital (PRPM)
Apple Rush (APRU)

PRPM is ARTS all over again.

I wouldn't be surprised to see the attorney writing the legal opinions to make those shares free trading end up in future SEC litigation.




The regulators are making progress with litigation against David Delaney, Big Apple, Edward Bronson (Fairhills), Joshua Sason (Magna), Guy Jean-Pierre, Carl Duncan, Joseph Meuse, Cameron Linton, etc. But many of these toxic financiers and insiders continue to operate the same schemes using a revolving door of CEOs and attorneys. The regulators have much more work ahead of them.

Fact is that there are too many patterns in all of these dirty penny stocks that use these various toxic financiers and attorneys. To me it looks more like an enterprise than a group of random events that blend together. There are so many people mixed together in the same shells that there has to be collusion to make it work and keep everybody happy. They have to be working together.

If it is an enterprise then there has to be a leader (or leaders) that control the enterprise from the top and since these dirty toxic financiers are still active it is obvious that the SEC hasn't reached the top yet.




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