Free Motion for Order - District Court of Colorado - Colorado

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

CASE NO. 01-CV-645-JLK SECURITIES AND EXCHANGE COMMISSION Plaintiff, v. KENNETH ROY WEARE aka ROY WEAVER, J&K GLOBAL MARKETING CORPORATION, and AAA-AUCTION.COM, INC., Defendants. ________________________________________________________________________________ RECEIVER'S UNOPPOSED MOTION TO ESTABLISH PROCEDURES AND DEADLINE FOR FILING CLAIMS, TO APPROVE MANNER OF NOTICE TO POTENTIAL CLAIMANTS, AND TO ESTABLISH CLAIMS REVIEW PROCEDURES, WITH CERTIFICATE OF COMPLIANCE ________________________________________________________________________________ COMES NOW, the Receiver, Patten, MacPhee & Associates, Inc., by and through its undersigned counsel, Christine J. Jobin, Esq., and respectfully moves the Court for an order establishing procedures and a deadline for filing claims, and establishing notice and claims review procedures in this action. In support of this motion, the Receiver states as follows: I. INTRODUCTION 1. On or about April 10, 2001, the Securities and Exchange Commission ("SEC")

filed this civil action against the Defendants for operating fraudulent investment schemes over the Internet. The Court entered a temporary restraining order and asset freeze the next day, April 11, 2001. According to the SEC's press release issued at that time, the Defendants had

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offered and sold the J&K Global investment to more than 13,000 investors since at least November 1999. In addition, the AAA-Auction.com investment was described as a "previous fraudulent offering" that operated an Internet auction site in 1998 and 1999. 2. On or about January 8, 2002, the Court entered a permanent injunction by default

against Defendants, finding that they had sold $375 investments in a "rent/mortgage free" program that promised returns of 600% annually from funds purportedly invested offshore. At that time, the Court also ordered the disgorgement of profits totaling $6.9 million, prejudgment interest of almost $630,000 and the payment of $330,000 in civil penalties. Later that year, Defendants were found in civil contempt of the Court's orders. In addition, Defendant Weare was indicted by a federal grand jury on March 25, 2003, pled guilty on April 1, 2004, and, was sentenced to 36 months in federal prison on August 3, 2005. At the time of sentencing, Judge Nottingham also ordered Defendant Weare to pay $1,199,355 in restitution to those victims who had responded to a victim survey by the FBI. The press release issued by the United States Attorney's Office at that time provided that Defendants had defrauded over 23,000 investors with their "Offshore Rent/Mortgage Free Program" and that investors had transmitted more than $9 million to bank accounts in the United States, Luxembourg and the West Indies between November 19, 1999 and December 31, 2000. 3. The SEC recovered more than $3 million of those funds for investors. In its

Request for Proposals ("RFP") to select a receiver and distribution agent to establish and administer the claims process for returning the recovered funds to investors, the SEC indicated that it was in possession of an Access database containing more than 48,000 records of historical
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information regarding approximately 23,000 unique investors. Over time, the SEC had also compiled summaries of many of the Defendants' bank records, including checks written to investors by Defendants and deposit items listing in many, but not all, instances investors' names and identification numbers. Thus, one of the critical tasks to be performed by the Receiver was to devise a comprehensive and efficient process for locating and contacting the approximately 23,000 investors identified in the Access database provided by the SEC, and to provide notice to those potential claimants. 4. For reasons described in detail in the Receiver's Third Quarterly Report dated

July 20, 2006, determining the identification and current location of investors has proved to be even more problematic than originally anticipated by the Receiver or the SEC. Nevertheless, since early April 2006, the Receiver has sent more than 78,000 e-mails and mailed approximately 15,000 letters to persons in more than 90 countries, who were identified in the Access database provided by the SEC. Out-of-pocket costs alone for those efforts have totaled more than $25,000. To date, approximately 3,500 potential claimants have registered their current contact information at the Receiver's website as a result of those efforts and are awaiting further direction from the Receiver for filing their claims. 5. While the Receiver and the SEC continue to make attempts to notify potential

claimants, the Receiver is prepared to recommend to the Court procedures and deadlines by which: (1) investors may present their claims to the Receiver; (2) the Receiver may allow or disallow such claims; and (3) a claimant may seek reconsideration and review of the disallowance of his or her claim.
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6.

Contemporaneous herewith, the Receiver has filed with the Court a motion to

reverse pierce the two corporate defendants and hold their respective assets liable for the obligations of Defendant Weare ("Motion to Reverse Pierce"). The procedures proposed herein assume the Court will order that the assets of Defendants J&K Global Marketing Corporation and AAA-Auction.com, Inc. are liable for the obligations of Defendant Weare. If the Motion to Reverse Pierce is granted by the Court, the Receiver proposes that each investor with an Approved Claim, defined below, shall receive a pro rata share of the Available Distribution, defined below, from the consolidated assets currently held in the registry of the Court (hereinafter referred to as the "Receivership Estate"), based on the aggregate amount of Approved Claims. II. PROPOSED CLAIM PROCEDURES Definitions 7. "Approved Claim" shall mean the final amount of a Potentially Eligible

Claimant's asserted Claim that is ultimately approved pursuant to the Claims Administration Process. 8. "Available Distribution" shall mean the funds held in the registry of the Court,

less any amounts expended or to be expended for administering the Receivership Estate, including but not limited to, reasonable fees and expenses incurred or to be incurred in administering the Claims Administration Process, reasonable fees and expenses related to the

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preparation and filing of income tax returns1 for the Receivership Estate, and all applicable taxes on income earned by the Receivership Estate. 9. "Claim" shall be broadly defined to include any right to payment, whether or not

such right is reduced to judgment, is liquidated or unliquidated, is fixed or contingent, is matured or unmatured, is disputed or undisputed, is legal or equitable, or is secured or unsecured, existing as of April 11, 2001. The term "Claim" should also include any right to an equitable remedy for a breach of performance which gives rise to a right to payment, whether or not such right is reduced to judgment, is fixed or contingent, is matured or unmatured, is disputed or undisputed, or is secured or unsecured. In addition, the Receiver requests that the term "Claim" be defined such that it does not include any claim the Receiver has or may have against any defendant or other individual or entity. 10. "Claims Administration Process" shall mean the procedures set forth in this

motion and approved by the Court. 11. "Claims Bar Date" shall mean the deadline by which a Potentially Eligible

Claimant's Proof of Claim Form must be received by the Receiver to avoid the barring of any right of the Potentially Eligible Claimant to participate in any distribution from the Receivership Estate. The Receiver proposes that the Claims Bar Date shall be midnight Mountain Standard Time (0700 UTC GMT) ninety (90) days from the date of entry of the Court's order establishing the Claims Administration Process.

1

The Receiver anticipates tax returns for 2006 and 2007 will be necessary in connection with this Receivership Estate.
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12.

"Claims Determination Date" shall mean the date on or before which the Receiver

is to reach its determination concerning the validity and amount of each Claim by a Potentially Eligible Claimant. The Receiver proposes that the Claims Determination Date shall be on or before sixty (60) days following the Claims Bar Date. 13. "Claims Period" shall be the period of time from the date of the Court's approval

and establishment of the Claims Administration Process until the Claims Bar Date. 14. "Determination Notice" shall mean the notice sent by the Receiver to a

Potentially Eligible Claimant stating the Receiver `s determination of the validity and amount of the Claim of the Potentially Eligible Claimant. 15. "Eligible Claimants" shall mean those Potentially Eligible Claimants filing a

Proof of Claim Form with the Receiver on or before the Claims Bar Date and who are finally determined by the Receiver to be eligible for a distribution from the Receivership Estate, as provided herein, as a result of their investment in J&K Global Marketing Corporation and/or AAA-Auction.com, Inc. "Eligible Claimants" shall not include, under any circumstances, any director, officer, owner or employee, or any former director, officer, owner or employee, of J&K Global Marketing Corporation and/or AAA-Auction.com, Inc., or any of the following individuals or entities identified by the SEC: Defendant Kenneth Roy Weare a/k/a Roy Weaver; Jeremiah Weaver a/k/a Bray Weaver; Got a Niche Software; Dan Barnicle; Telsa Financial Group; Doug Weare; Beemer Balloons; Top Notch Cable; Thomas J. Currey; Thomas Productions; Thomas Promotions; John Caraballo; Dome Associates, Inc.; Xavier Burgess; Snipes Holdings; Larry Hearn; Communication Investment Corp.; Nick Malfara; Lillian Malfara;
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Malfara Importing/Exporting; Sherri Weare; Margaret Jabro Weare; William Joseph Owen; and Vidor Corporation. 16. "Final Determination Notice" shall mean the Receiver's written or e-mail

response to a request for reconsideration of the Receiver's Determination Notice. 17. "Late Filed Claim" shall mean any Claim received by the Receiver after the

Claims Bar Date. If the Claims Bar Date falls on a weekend day or a legal holiday, as defined in the Federal Rules of Civil Procedure, then the action required to be taken by the Claims Bar Date must be taken on the first day after the weekend or legal holiday. 18. "Motion for Review" shall mean a motion filed with the Court by a Potentially

Eligible Claimant seeking review of the Receiver's Final Determination Notice disallowing all or part of his/her/its Claim. 19. "Person" shall also be defined broadly to mean all persons and entities including,

without limitation, individuals, partnerships, corporations, estates, governmental units, unions, trusts and trustees holding or wishing to assert a Claim against the Receivership Estate, individually or collectively. 20. "Potentially Eligible Claimants" shall mean those Persons who invested funds

with either J&K Global Marketing Corporation or AAA-Auction.com, Inc., identified by the Receiver as having possible claims to the Receivership Estate, or Persons asserting that they have possible claims to the Receivership Estate. 21. "Proof of Claim Form" shall mean the form designed by the Receiver, and

approved by the Court, for the filing of proof of a Claim by a Potentially Eligible Claimant.
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22.

"Unpaid Principal Balance" shall mean the principal amount of an investment, net

of any return on, or of, the investment received by an Eligible Claimant. Procedures for Filing Claims 23. Notwithstanding that the Receiver is requesting the Court to define Claim

broadly, the Receiver requests that the Court, at this time, limit the amount of each Claim to the amount of the Unpaid Principal Balance. This request is based upon the Receiver's recognition that the aggregate Unpaid Principal Balance for all Eligible Claimants may exceed the funds available for distribution that are currently held in the registry of the Court. However, the ultimate determination of that issue cannot be made until the Claims Period has ended and the Receiver has resolved all outstanding issues regarding each Claim. 24. The court in In re: Independent Clearing House Co., 77 B.R. 843, 858 (D. Utah

1987), addressed this very issue in a case involving a Ponzi scheme. The court reasoned that "in some cases, `the interest of the public, rather than the equitable standing of the individual parties, is of determining importance'. . . To allow an undertaker to enforce his contract to recover promised returns in excess of his undertaking would be to further the debtor's fraudulent scheme at the expense of other undertakers." Id. at 858, cites omitted. 25. In In re M&L Business Machine Co., Inc., Case No. 90-15491 CEM, the

Bankruptcy Court for the District of Colorado held that investors in another Ponzi scheme were entitled to claims in the amount of the unpaid principal balance of their investments. The court sustained the trustee's objections to claims for interest and/or which were asserted in amounts in excess of the unpaid principal balance of the creditor's investment. Two unpublished opinions
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issued in the M&L case on March 31, 1999 provide further support for the Receiver's request to limit a "Claim" in the instant case to the amount of the unpaid principal balance of each investor's undertaking. 26. The Receiver is not aware of any action pending against any or all of the

Defendants but requests, if there is any such action by a Person, that the Person shall not be permitted to file a Claim against the Receivership Estate unless and until either (1) such pending action has been dismissed without prejudice and a certified copy of the order of dismissal is included with the Claim, or (2) such action has been prosecuted to a judgment that may then be filed as a Claim against the Receivership Estate. 27. The Receiver requests that the Court set as the Claims Bar Date for filing a Claim

against the Receivership Estate ­ in order for a Potentially Eligible Claimant to be eligible to share in any distribution of assets from the Receivership Estate ­ midnight Mountain Standard Time (0700 UTC GMT) on the date that is ninety (90) days from the date an order is entered by the Court on this motion. 28. The Receiver requests that in order to be deemed properly and timely filed, each

Claim must be submitted by the Potentially Eligible Claimant on an official Proof of Claim Form, a proposed form of which is attached hereto at Exhibit A (the "Claim Form"), and actually received by the Receiver on or before the Claims Bar Date. The Receiver further requests that the Court allow Potentially Eligible Claimants the opportunity to complete and submit their Proof of Claim Form online so that the Receiver can collect such data electronically. The Receiver proposes that, alternatively, a completed Proof of Claim Form may be mailed to
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the Receiver at the following address: Patten, MacPhee & Associates, Inc., Post Office Box 18309, Denver, Colorado 80218, or sent by e-mail to the Receiver at the following e-mail address: [email protected]. The Receiver requests that facsimile submissions not be deemed acceptable and that Claims will only be deemed filed when actually received by the Receiver by one of the methods specified above. 29. The Receiver proposes that, in its discretion, the Receiver may require a

Potentially Eligible Claimant to provide documentary evidence it deems necessary or appropriate to substantiate any Claim greater than $375, including but not limited to receipts, copies of money orders or cancelled checks. 30. The Receiver proposes that the submission of any Claim shall be deemed to be

the sworn declaration of the Potentially Eligible Claimant under penalty of perjury, in accordance with the laws of the United States of America. 31. The Receiver requests that no claim from a Potentially Eligible Claimant in an

amount determined to result in a distribution of less than $10.00 be paid. In determining the amount of the distribution for the purposes of this paragraph, the Receiver may aggregate the accounts held by a Person in accordance with the aggregation rules proposed herein. The Receiver proposes that each Person who would like to aggregate accounts shall so designate in the Proof of Claim Form, provided that a Person may only aggregate accounts as follows: a. with respect to an individual Person, such Person may aggregate his or her accounts, with the accounts of his or her parent, child or spouse (collectively, "family"), such Person's or his or her family's retirement
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accounts, and accounts owned by a corporation or partnership in which such Person or such Person's family is a majority owner or which is controlled by such Person or such Person's family; and, b. with respect to a Person that is a corporation or partnership, such Person's accounts and the accounts of such Person's affiliates. The Receiver requests that, in its discretion, it may require each Person seeking to aggregate accounts with a another individual, corporation, partnership or other entity to provide the Receiver with a statement of authorization/consent from each individual, corporation, partnership or other entity with which such Person seeks to aggregate accounts. 32. The Receiver requests that any Claim must clearly indicate the name and, if

applicable, the form of legal entity of the Potentially Eligible Claimant. 33. The Receiver requests that all Claims must be filed in the English language, and

that the amounts allegedly due be stated in the lawful currency of the United States. 34. The Receiver requests the Court to order that the Claim filing requirements are

not applicable to any claims of the Receiver or the Tax Administrator appointed by the Court, their counsel, other professionals and others employed by them, or entities and persons employed by them to assist in the carrying out of their duties and responsibilities, or other claims that relate to or are incurred during the administration of the Receivership Estate. 35. The Receiver proposes that any Late Filed Claim be disallowed and no

distribution of assets from the Receivership Estate be made with respect thereto.

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36.

The Receiver requests that if any Claim is sent to any person or entity other than

the Receiver and is not actually received by the Receiver by the Claims Bar Date, such Claim shall be deemed to not have been properly filed, shall not constitute the timely filing of a Claim, and shall not be allowed. 37. The Receiver requests the Court to confirm that nothing set forth in the order on

this motion will preclude the Receiver from objecting to any Claim, whether or not timely filed, on any grounds. 38. The Receiver requests the Court to order that if a timely-filed Claim is transferred

or assigned, the transferor or assignor must mail a notice of transfer and/or assignment of the Claim to the Receiver within twenty (20) days of the transfer and/or assignment, along with a true and accurate copy of such transfer and/or assignment. Notice to Potential Claimants 39. The Receiver requests the Court to approve, as to form and content, the Claim

Form and the Claims Bar Date Notice attached hereto as Exhibits A and B, respectively. 40. Since early April 2006, the Receiver has maintained a website for investors to

register their current contact information with the Receiver. That website is accessible directly and through a hyperlink on the SEC's website, and provides detailed information regarding the nature and status of the SEC's enforcement action and this receivership. In addition, the Receiver has determined that the more popular internet search engines such as Google, MSN.com and Yahoo, readily direct any person interested in learning more about the J&K

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Global Marketing or AAA-Auction.com investment to both the Receiver's and the SEC's websites. 41. Shortly after sending its first e-mail to potential claimants, the Receiver learned

from an investor of the existence of at least two Internet forums/bulletin boards at which J&K Global Marketing investors periodically posted information regarding the efforts of the SEC and others to bring the Defendants to justice and/or recover investors' funds. At the request of the Receiver, that investor subsequently posted notice of this action and the need for investors to register their current contact information at the Receiver's website on at least two such Internet forums/bulletin boards. Thus, the Receiver has been advertising notice of this matter on the Internet since April 2006. 42. As indicated above, since early April 2006, the Receiver has sent more than

78,000 e-mails and mailed approximately 15,000 letters to potential claimants in more than 90 countries, notifying them of the SEC's enforcement action and appointment of the Receiver. A sample copy of the form of notice sent by the Receiver with each e-mail and letter is attached hereto at Exhibit C. 43. To date, all of the Receiver's notices to potential claimants and requests for

registration of current contact information with the Receiver have encouraged all Potentially Eligible Claimants to inform friends and family of the appointment of the Receiver and the importance of registering their current contact information at the Receiver's website. The Receiver intends to continue seeking out Potentially Eligible Claimants and allowing them to register and submit a Claim Form throughout the Claims Period.
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44.

It is the Receiver's understanding that the fraudulent investments sold by the

Defendants were offered over the Internet and not through traditional media. Given the global scope of this investment fraud and the apparent lack of any common interest or demographical attribute among the victims, such as geographical location, age, gender, employment, activity/hobby or political/religious affiliation, the Receiver believes that publication of the Claims Bar Date Notice through traditional media would yield minimal benefits with respect to identifying other Potentially Eligible Claimants and would result in considerable out-of-pocket expenses being incurred by the Receivership Estate. 45. The Receiver proposes that, unless postal delivery has been expressly requested

by a potential claimant, the Claims Bar Date Notice, the Claim Form and any other documents may be sent by e-mail to each Potentially Eligible Claimant who has registered his/her/its current contact information with the Receiver pursuant to its notice of this receivership and requests for such registration. 46. The Receiver proposes that the Claim Form and the Claims Bar Date Notice,

which shall set forth the procedures and deadlines established by the Court's order on this motion, be sent as soon as practicable after entry of the Court's order, but in no event later than fifteen (15) days from the date of the Court's order. The Receiver further proposes that electronic copies of the Claim Form and the Claims Bar Date Notice, along with a copy of the Court's order establishing the Claims Administration Process, shall be posted on the Receiver's website no later than five (5) days from the date of the Court's order.

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47.

Notwithstanding the above efforts by the Receiver, given the incompleteness of

the data received from the Defendants via the SEC, there may exist Claims or Potentially Eligible Claimants of which the Receiver currently is unaware and/or the Receiver has been unable to contact. These Potentially Eligible Claimants may include, for example, investors who have moved or relocated, or who have changed their e-mail and/or postal address since making an investment with the Defendants. Unknown Claims may include those that, for various reasons, were not recorded on the Defendants' books and records, or which have not been previously submitted to the Receiver. 48. Taking all of the above into consideration, the Receiver believes that publication

of the Claims Bar Date Notice through traditional media may not prove to be effective. To the contrary, the Receiver believes that such publication could be counterproductive in that it would increase the risk of false and/or fraudulent Claims, which would only cause the Receivership Estate to incur additional expense validating Claims. 49. The Receiver, therefore, requests that the Court not require publication of the

Claims Bar Date Notice through any form of traditional media. Claims Review Procedures 50. Given the number of Potentially Eligible Claimants, the Receiver requests that it

have sixty (60) days from the Claims Bar Date to e-mail or mail a Determination Notice to each Potentially Eligible Claimant submitting a Claim. 51. As indicated in Paragraphs 1 and 2 above, it has now been a minimum of five

years and as many as eight years since each Potentially Eligible Claimant would have invested
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with Defendants. Given the significant passage of time, the relatively small amounts invested by most Potentially Eligible Claimants, and the manner in which many investors' funds were transferred to Defendants (e.g., postal money orders), the Receiver anticipates the filing of a substantial number of Claims with limited or no documentary evidence substantiating the Claim. Moreover, the Receiver seriously doubts the ability of Potentially Eligible Claimants to obtain such documentary evidence now, several years later. The Receiver therefore requests that, in its discretion, it may supplement Claims lacking documentary evidence with information derived from the Access database and bank records provided by the SEC, such that any Claim for $375, or less, may be validated with information from the Access database only and Claims greater than $375 may be validated with banking records provided to the Receiver by the SEC. The Receiver further proposes that, if in the Receiver's discretion, the Receiver determines such supplemental information does not support any Claim, the Receiver shall send a Determination Notice to the Potentially Eligible Claimant, disallowing all or part of the Claim. 52. The Receiver proposes that a Potentially Eligible Claimant whose Claim has been

disallowed by the Receiver, in whole or in part, may seek review of the Receiver's Determination Notice by delivering a request for reconsideration to the Receiver within twenty (20) days after the date of the Receiver's sending the Determination Notice to the Potentially Eligible Claimant by e-mail, or United States mail if so requested. The Receiver requests the Court to order that a failure to timely request reconsideration of the Determination Notice shall constitute a waiver of the Potentially Eligible Claimant's right to object or contest the Determination Notice. In addition, the Receiver requests the Court to order that within (10) days
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following the Receiver's receipt of the request for reconsideration, the Receiver shall e-mail or mail a Final Determination Notice to the Potentially Eligible Claimant which contains the Receiver's decision concerning the request for reconsideration. 53. The Receiver further proposes that any Potentially Eligible Claimant who is

dissatisfied with the Receiver's Final Determination Notice concerning a Claim may seek review by the Court, by filing a Motion for Review with the Clerk of the Court for the United States District Court for the District of Colorado at 901 ­ 19th Street, Denver, Colorado 80294, and mailing or e-mailing a copy to the Receiver. The Receiver requests that the Motion for Review must be filed with the Court by the Potentially Eligible Claimant seeking review in sufficient time that it is received by the Clerk of the Court no later than twenty (20) days after the date on which the Final Determination Notice was e-mailed or mailed to the Potentially Eligible Claimant by the Receiver, with the burden of ensuring such timely receipt by the Court upon the Potentially Eligible Claimant. The Receiver further requests that the failure to timely file a motion for review of a Final Determination Notice shall constitute a waiver of the Potentially Eligible Claimant's right to object to or contest the Final Determination Notice. The Receiver requests that it shall have ten (10) days to file and serve on the Potentially Eligible Claimant a written response to any Motion for Review. 54. The Receiver proposes that within thirty (30) days following completion of the

processing of all Claims in accordance with the Court's order, including the issuance of any Final Determination Notices by the Receiver, the Receiver shall prepare and file with the Court a status report setting forth: (1) a list of all Eligible Claimants and the amount of the Approved
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Claim for each Eligible Claimant; (2) a summary of all Motions for Review filed with the Court, efforts made by the Receiver to resolve such motions without Court intervention, and a proposal for expeditious resolution of such motions by the Court; and (3) any other matters that are material to administration of this Receivership Estate. 55. The Receiver further requests the Court to order that the Receiver may petition

the Court at that time for the authority to distribute a specified amount from the Receivership Estate to the Eligible Claimants, taking into consideration a reasonable reserve for all Motions for Review pending before the Court, the Receiver's fees and expenses incurred or expected to be incurred in the performance of its remaining duties, and all anticipated income taxes and other expenses payable by the Receivership Estate. III. CERTIFICATE OF COMPLIANCE 56. Undersigned counsel has conferred with Leslie Hughes, counsel for the SEC, and

provided her with a copy of this motion prior to filing. Undersigned counsel is authorized to represent that Ms. Hughes does not oppose the instant motion. WHEREFORE, the Receiver respectfully requests that the Court enter an order establishing the procedures and deadlines proposed herein, and grant such other and further relief as the Court deems just and proper.

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DATED this 22nd day of November, 2006.

s/Christine J. Jobin Christine J. Jobin, Esq. #12335 The Jobin Law Firm, P.C. 1900 Grant Street Suite 815 Denver, Colorado 80203 Telephone: (303) 839-1390 FAX: (303) 839-1113 E-mail: [email protected] Attorney for Receiver

CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on this 22nd day of November, 2006, I electronically filed the foregoing RECEIVER'S UNOPPOSED MOTION TO ESTABLISH PROCEDURES AND DEADLINE FOR FILING CLAIMS, TO APPROVE MANNER OF NOTICE TO POTENTIAL CLAIMANTS, AND TO ESTABLISH CLAIMS REVIEW PROCEDURES with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] [email protected] /s/ Christine J. Jobin Christine J. Jobin, Esq. #12335 Attorney for the Receiver The Jobin Law Firm, P.C. 1900 Grant Street Suite 815 Denver, Colorado 80203 Telephone: (303) 839-1390 FAX: (303) 839-1113 E-mail: [email protected]
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