The Enterprise

Kyleen Elisabeth Castro

the controlling owner's current name · b. 22 October · f/k/a Michael Allan Cane (to 2003) · Kyleen E. Cane (2003–) · Kyleen Elisabeth Castro, Ph.D. (2024)

The enterprise's architect and kingpin. The qui tam complaint pleads her as “the enterprise's legal architect and principal” — she “devised the fraudulent schemes, structured the corporate transactions, drafted deceptive SEC filings, [and] created the offshore nominee infrastructure,” directing the enterprise's strategy across four decades. Jan Wallace was her instrument, not her equal. The enterprise's legal architecture. Principal of Cane O'Neill & Taylor and then Cane Clark LLP — registered agent for 219+ companies and EDGAR filing agent (CIK 0001255294). Across three decades she supplied the attorney-escrow accounts, securities opinions, and offshore concealment structures behind the Thomas & Wong escrow fraud, the Davi Skin pump-and-dump, the SDI takeover, and the MOD Systems voting-trust fraud. In United States v. DiScala the EDNY called her "central to the scheme," capturing her on a wiretap setting Cubed price targets to the nickel. Legally changed her name from Michael to Kyleen on 28 June 2001 yet kept filing SEC documents under the abandoned identity; resurfaced in 2024 as Kyleen Elisabeth Castro, Ph.D. The contemporaneous emails place the instruments in her own hand: she personally transmitted the MW Medical / Davi Skin promissory-note package to Wallace,¹ and in her own email she directed the formation of the SDI joint-venture “Secured Lending” (SDL) vehicle.²

1. Email, Kyleen Cane (kcane@caneclark.com) to Jan Wallace, Apr. 11, 2006, subject “docs” — transmitting the $248,325 MW Medical promissory note, the Notice of Partial Cancellation, the Assignment, and the election converting $200,000 of principal into 1,000,000 shares. 
2. Email, Kyleen Cane to Bryan Clark (Cane Clark LLP), May 5, 2006 — directing formation of the SDI joint-venture “Secured Lending” (SDL) LLC layered onto SDI. 

Juanita Mary Jardine

the operator, by her birth name · a/k/a Jan Mary Wallace · Jan L. Wallace · Jan Jardine · Joan Reardon

The enterprise's front. A Canadian citizen who served as CEO, President, or Director of at least three SEC-reporting shells — Dynamic Associates, MW Medical / Davi Skin, and SDI — without work authorization. She cultivated each victim's trust while Cane supplied the legal cover. Her private infrastructure ran on three fraudulent Social Security numbers (one a dead man's, one never issued by the SSA) and a ring of Bermuda nominees at LOM Securities — Hepburn Holdings, Arch Ltd., Sunshine Ltd., and The Chloe Group.  The $1.3M Thomas & Wong judgment against her was ruled nondischargeable for "actual fraud"; at her bankruptcy 341 meeting she swore she had no offshore accounts, then admitted Hepburn Holdings was "in Bermuda." The contemporaneous record ties her hand to each vehicle: she and Cane incorporated MW Fitness (the Savannah Corp shell) as an alter-ego,¹ she maintained the Bermuda LOM nominees Arch Ltd. and Sunshine Ltd. on annual wire-paid renewal invoices² and solicited the whistleblower onto the Hepburn Holdings accounts,³ and she reported the rolled-back SDI shares to Kelly Black.⁴

1. Articles of Incorporation, MW Fitness / Savannah Corp (Jul. 31, 2002) — the Cane-Wallace shell incorporation behind the MW Fitness badge. 
2. Email, Perrin (LOM, Bermuda) to Jan Wallace, Mar. 15, 2006 — annual renewal invoice for Arch Ltd. and Sunshine Ltd., with Bank of Bermuda wire instructions. The renewal payment is addressed to Devi Johal — sister of enterprise CFO Munjit Johal — on the fourth page.   page 4
3. Email, Jan Wallace to M.P., Apr. 18, 2007 — forwarding Hepburn Holdings / Bermuda-account documents, soliciting M.P. as an account signatory. 
4. Email, Jan Wallace to Kelly Black, Sep. 4, 2006 — update on the rolled-back (reverse-split) SDI shares. 

Amin Lakha

also rendered Lahka · Amin S. Lakha

The enterprise's outside financier — and its standing threat. Installed on the Davi Skin (CIK 0001059577) board after founder Parrish Medley was ousted in 2006 — the board that authorized the offshore issuance. His signature instrument is the $2,200,000 9% Senior Secured Convertible Note, first disclosed in Davi Skin's Q1-2008 10-QSB (Baum Law Firm filer of record, Acc. 0001173473-08-000049): Lakha is named the “unrelated third party,” takes a board seat and 125,000 options, and the note matures 15 May 2010.¹ A senior secured convertible note is the threat made financial — a friendly lien over the whole company that, on default, converts the financier into the controlling creditor and lets him foreclose on the shell. It is the same instrument the enterprise used elsewhere: Wallace's manufactured MW Medical secured note ($615,871 → 74,000,000 reorganization shares) and her $200,000 Davi note.² Lakha is also associated with that earlier $200,000 promissory-note conversion that, on 3 April 2007, issued 2,295,388 shares (certificates 5309–5312) in four equal 573,847-share blocks across the Bermuda LOM nominees at exactly 3.97% each — one tick below the 5% Schedule 13D disclosure threshold. ² The same secured-financing-as-control pattern runs through Secured Diversified Investment, Ltd. (“SDI” / SDVF, CIK 0000013156) and its real-estate flip vehicle Western Investment Properties (“WIP”) — run for Jan Wallace out of the 3273 E. Warm Springs Road office, with realtor David Leeper signing Wallace's name to the purchase-and-flip contracts.³ The filed charter now names Lakha directly: the  Articles of Incorporation of Western Investments Partners, Inc. (filed 18 July 2005, Cane Clark resident agent over Cane's own signature, forwarded to Wallace by Grace Sim) list Andy (Amin) Lakha as director no. 2, alongside Patrick M. and Jan Wallace — the “outside investor” inside the controllers' vehicle from day one.³

1. SEC Form 10-QSB, Davi Skin, Inc. (Q1 2008) (filed May 20, 2008), Acc. No. 0001173473-08-000049 (Baum Law Firm, filer of record) ($2,200,000 9% Senior Secured Convertible Note to Amin S. Lakha, named the “unrelated third party”; board seat; 125,000 options; maturity May 15, 2010).
2. Davi Skin Active Shareholder Report (July 13, 2007) (Cert. Nos. 5309–5312, each 573,847 shares, dated 04/03/2007; four Bermuda LOM Securities nominees at 3.97% each); SEC Form 10-KSB, MW Medical, Inc. (Wallace secured note $615,871; §1145 reorganization converting $375,000 → 74,000,000 shares).
3. Deposition of David Brian Leeper (Jul. 27, 2006), at 49–52 (Western Investment Properties (“WIP”); property flips executed in Jan Wallace's name; Charlevoix Land/Homes); Secured Diversified Investment, Ltd. (SDVF), CIK 0000013156, real-estate holdings, Attn: Jan Wallace, 3273 E. Warm Springs Rd., Las Vegas. Western Investments Partners, Inc., Articles of Incorporation (Nev. Sec. of State Entity E0458192005-2, filed Jul. 18, 2005; Cane Clark LLP resident agent; directors Patrick M., Andy Lakha, Jan Wallace; Grace Sim incorporator), forwarded to Wallace under Grace Sim's "FW: Articles" email (Jul. 26, 2005). (The Leeper deposition renders the vehicle "Western Investment Properties"; the filed charter reads "Western Investments Partners, Inc." Amin Lakha is a named director on that charter, though he does not himself send email in the emails_wallace corpus.)

Munjit Johal

Appointed a director and Chief Financial Officer of Davi Skin on 20 October 2006, Johal presented a clean public-company résumé: broad accounting, finance and management experience, Chief Financial Officer of Secured Diversified Investment, Ltd. since September 2002, Executive Vice President of Pacific Heritage Bank in Torrance, California from 1990 to 1995, an MBA from the University of San Francisco (1980), and a BS in History from the University of California, Los Angeles (1978).⁹ Inside the enterprise the role was different — a recurring financial officer and SEC filing agent across the Cane network. When the company's auditors began probing the concealed $200,000 Wallace note in March 2006, Johal — with Grace Sim — manufactured the false financial records used to discredit ousted founder Parrish Medley and to paper over the offshore share issuances that handed control of the company to the Cane-Wallace nominees.¹ As CFO he co-certified Davi Skin's SEC filings alongside CEO Wallace, swearing the company had no material related-party transactions and no undisclosed 5%-plus owners — certifications the April 2007 Bermuda nominee conversions rendered false.² Beyond Davi Skin, Johal appears as the SEC filing officer of record for other Cane-network issuers, including Makeup.com Ltd. and Dippy Foods, Inc.³ As SDI's Principal Financial Officer, Johal signed the auditors' management representation letter and certified SDI's periodic filings under Sarbanes-Oxley, then forwarded Wallace an allegation captioned "SDI misleading 10K" concerning the same filing he had just certified.⁴ His sister, Devi (Harjeet) Johal (SEC CIK 0001207601), sits inside the same offshore apparatus. She worked at LOM Securities (Bermuda) — the very brokerage holding the Wallace nominees — as an associate advisor until 2003, was the SEC-registered corporate secretary of the shell Ballistic Ventures, Inc. (Naples, Florida, 2002–2003), and is the named payee on the March 2006 LOM renewal invoice for the Wallace nominees Arch Ltd. and Sunshine Ltd.  In October 2010 she sued LOM Securities (Bermuda) Ltd. in the Supreme Court of Bermuda (represented by Cox Hallett Wilkinson). She later married Dennis Mahoney (Bermuda Official Gazette notice LN 38/2021 — a notice of intended marriage; both parties previously divorced) and today is the sole director, resident in Bermuda, of the UK insurance broker Limehouse Agency Limited (Companies House No. 16201794). It is an active private company limited by shares, incorporated 22 January 2025, registered at Apartment 4, 2 Matthew Parker Street, London SW1H 9NJ, and classified under SIC 66220 — activities of insurance agents and brokers: an insurance brokerage run from Bermuda through a Westminster accommodation address. The filed record is held here —  incorporation,  director particulars, and the  2026 confirmation statement. Public-company directory records also place her on Canadian junior-mining boards — Secretary of the Board of Lake Shore Gold Corp. (TSX-Venture: LSG, formerly Consolidated Takepoint Ventures Ltd.) and secretary and beneficial owner of Sonterra Resources Inc.¹⁰

1. Compl. ¶12, Medley v. Wallace, No. BC351142 (L.A. Super. Ct. Apr. 21, 2006); Davi Skin separation agreement (Mar. 17, 2006).
2. SEC Forms 10-K / 10-Q, Davi Skin, Inc. (FY 2006–2007) (Sarbanes-Oxley certifications of CEO Wallace and CFO Johal).
3. SEC EDGAR filer records, Makeup.com Ltd. and Dippy Foods, Inc. (filing officer Munjit Johal) — establishing Johal as a recurring filing officer across multiple Cane-network shell issuers beyond Davi Skin.
4. Johal to Wallace, May 4, 2006, "for your reading," forwarding an allegation captioned "SDI misleading 10K" — the certifying CFO forwarding, rather than correcting or disclosing, notice that his own certified filing was misleading. 
5. Johal to Wallace, April 10, 2006, transmitting the auditors' management representation letter as CFO — Johal's own written attestation to outside auditors that SDI's financials were complete and fairly stated. 
6. Johal to Ambrosio, February 9, 2006, re Prime Time Auctions / Max Hollis related-party matter — Johal handling an undisclosed related-party dealing inside SDI. 
7. Johal to Wallace, January 20, 2006, re a dissident shareholder's demand for the SDI shareholder list — Johal fielding a shareholder-transparency demand rather than complying with it. 
8. Johal to Wallace, April 15, 2006, re SDI's Form 10-KSB — tying Johal directly to preparation of the periodic filing later alleged to be misleading. 
9. Davi Skin, Inc., SEC filing — biographical disclosure of director and Chief Financial Officer Munjit Johal (appointed Oct. 20, 2006): CFO of Secured Diversified Investment, Ltd. since Sept. 2002; Executive Vice President, Pacific Heritage Bank (Torrance, CA) 1990–1995; MBA, University of San Francisco (1980); BS History, UCLA (1978).
10. Lake Shore Gold Corp. company summary (2009) listing Devi Johal as Secretary of the Board (TSX-Venture: LSG; formerly Consolidated Takepoint Ventures Ltd.).  MarketVisual mapped-relationships record (2009) — Devi Johal as Secretary and beneficial owner of Sonterra Resources Inc. 

Claire C. Ambrosio

also rendered Claire Ambrosia

Wallace's personal securities counsel and a Director of Davi Skin with signatory authority over the company's corporate bank accounts.¹ She had worked alongside Wallace and Cane at SDI Ventures as the securities attorney on SEC filings, and owned a shell company originating in the MW Medical corporate genealogy — a connection to the enterprise predating Davi Skin. Identified throughout the contemporaneous record as "counsel for Jan Wallace," she worked directly inside the share-engineering and EDGAR-disclosure machinery: a 9 April 2006 email to Munjit Johal and Wallace probed whether "the Edgar files show the amount of outstanding shares" and whether "another class of shares [can] vote other than common," and a May 2006 communication directed all disputes over the Davi Skin obligation and its stock-conversion rights to her.² Her role included approving offshore wire transfers, authorizing share issuances, and signing corporate resolutions prepared by Cane that papered the offshore transactions. She also represented Wallace personally at the December 2006 Medley v. Wallace deposition.³ On April 4, 2006, Ambrosio ghost-drafted a sworn shareholder declaration for Kelly Black reciting that Wallace "issued 15 million shares of company stock to herself" and "stole two million dollars from the sale of the Cannery," pocketing the proceeds without disclosure on Form 8-K.⁴

1. Exhibit List, Artist House Holdings v. Davi Skin (L.A. Super. Ct. Dec. 18, 2006) (identifying "Claire Ambrosio acting as the securities attorney" on the SDI Form 10-QSB); Davi Skin director with corporate bank-account signatory authority.
2. Jan Wallace e-mail production: Ambrosio to Johal & Wallace (Apr. 9, 2006) (EDGAR outstanding-share count; share-class voting structure); communication directing disputes to "Claire Ambrosio, counsel for Jan Wallace" re the Davi Skin obligation and stock-conversion rights (May 15, 2006).
3. Videotaped Deposition of Jan M. Wallace (Dec. 20, 2006), Medley v. Wallace, No. CV 06-3370 R (SSx) (C.D. Cal.) (Wallace represented by Claire C. Ambrosio).
4. Ambrosio to Kelly Black, cc Wallace, April 4, 2006, ghost-drafted sworn shareholder declaration reciting the SDI/Cannery looting allegations verbatim — Wallace's own securities counsel manufacturing the litigation defense to the fraud allegations against her, memorializing the looting narrative in a sworn filing rather than an independent account. 
5. Ambrosio to Wallace, May 2, 2006, re Kagel creditor-pressure letter concerning Davi Skin — Ambrosio managing creditor pressure arising from the concealed Davi Skin/MW Medical note assignment on Wallace's behalf. 
6. Ambrosio to Wallace, September 14, 2006, "I have revised the CDE section" of SDI's investor Executive Summary — Wallace's personal attorney authoring SDI's investor-facing disclosure document while the shell was being emptied. 
7. Wallace to Ambrosio, August 21, 2006, forwarding Cane Clark LLP's Savannah Corp Articles of Incorporation and Certificate of Amendment — placing Wallace's personal securities counsel in receipt of the shell charter used to layer the enterprise's real-estate and share vehicles. 

Scott Doney

The enterprise's opinion-letter signature. A Cane Clark LLP attorney who produced and signed the Rule 144 / Section 5 legal opinions that stripped restrictive legends off restricted shares — converting locked insider stock into free-trading float. In the SDI → Galaxy Gaming shell cycle (June–October 2006), Doney drove the Iomega legend-removal sequence: he calendared the opinion's signature precisely to the Rule 144 affiliate-clock anniversary (27 October 2006), while the "holder's" own legend-removal request was drafted issuer-side by Munjit Johal and routed to him rather than authored by the holder's counsel.¹ His own words capture the practice — to a transfer-agent contact seeking an opinion, he wrote: "If you have a form letter, I would be happy to sign it." The sequence culminated in the SDI Form S-8 Exhibit 5.1 legality opinion, signed by Doney and transmitted to EDGAR on 5 October 2006 — the drafting counsel and the EDGAR-signing counsel being the same firm.² Doney, as Cane Clark's securities attorney of record, supplied the Form S-8 registration and Exhibit 5.1 opinion letter converting restricted shell stock into free-trading shares and proposed issuing new shares to Wallace and Black, deferring: "Let me run this by Kyleen."³

1. Forensic sub-brief — Cane Clark, Wallace, Doney: Iomega opinion-letter sequence and the SDI shell cycle (Jun.–Oct. 2006) (the "form letter" admission, Aug. 2, 2006; Rule 144 affiliate-clock calendaring, Sept. 20, 2006; issuer-side drafting of the holder's request by Johal).
2. Secured Diversified Inv., Ltd., Registration Statement (Form S-8), Reg. No. 333-137837, Ex. 5.1 legality opinion signed by Scott Doney, Cane Clark LLP, Acc. No. 0001255294-06-000687 (filed Oct. 5, 2006).
3. Doney to Serota, September 21, 2006, transmitting the draft S-8 Registration Statement and Exhibit 5.1 opinion letter, "Please bill the company directly." — Doney supplying the legal mechanism that converted restricted shell stock into publicly tradeable shares. 
4. Doney to Wallace, August 30, 2006, proposing new share issuances to Wallace and Black, "Let me run this by Kyleen." — Doney proposing self-dealing share issuances to the officers he represented, subject only to Cane's sign-off. 
5. Doney, March 15, 2006, SDI plan for the Form 8-K documenting Iomega's preferred conversion into 15,000,000 common shares and the appointment of a WIP member (Peter R.) as director — the conversion consolidating a large block of voting control while installing a WIP insider on the board. 
6. Doney to Wallace, July 31, 2006, on the 20-to-1 reverse split and an unexplained correction of SDI's authorized shares from 100 million to 300 million — Doney executing the share-count manipulation underlying the rollback. 
7. Doney to Johal, August 10, 2006, re SDI's response letter to the SEC — the same firm drafting SDI's SEC correspondence while its own filings were alleged to be misleading. 

Grace Sim

A recurring financial officer and corporate secretary across the enterprise's earliest shells. Sim served as CFO of Dynamic Associates and Secretary/Treasurer of MW Medical, and was in place as CFO when Dynamic acquired Genesis Health Management — the $25.4M Medicare-fee acquisition that gave the shells their commercial veneer.¹ In the MW Medical bankruptcy she held a self-dealt promissory note alongside Wallace — debt the insiders manufactured and converted into reorganization equity, extinguishing the outside holders.² At Davi Skin she and CFO Munjit Johal manufactured the false financial records used in 2006 to discredit ousted founder Parrish Medley and to paper over the offshore share issuances. The SDI record states her function plainly: she “formed the shell entities on Cane's instruction.”³ Sim incorporated Western Investments Partners, Inc. on July 18, 2005 with Cane Clark LLP as resident agent and Wallace and Lakha as directors, then personally managed Wallace's bank account, payroll, and the Secured Lending banking relationship.⁴

1. MW Medical, Inc., Chapter 11 docket, No. 2:02-bk-01090-RTB (Bankr. D. Ariz.) (officers: Jan Wallace, President; Grace Sim, Secretary/Treasurer); Dynamic Associates Form 10-KSB (Genesis Health Management acquisition, $25,373,000; Dec. 2, 1996).
2. MW Medical Joint Plan of Reorganization (Feb. 4, 2002) and FY2002 10-KSB ($375,000 of insider notes converted to 74,000,000 reorganization shares at $0.005).
3. SDI forensic brief — “Grace Sim ('Sim') formed the shell entities on Cane's instruction”; Davi Skin manufactured-records sequence (Mar.–Apr. 2006, with Munjit Johal).
4. Sim to Wallace, July 18, 2005, confirming Western Investments Partners, Inc. filed with the Nevada Secretary of State — documenting Sim's formation of the concealed WIP takeover vehicle later used to control SDI. 
5. Sim to Wallace, July 26, 2005, "FW: Articles," forwarding the filed WIP Articles of Incorporation naming Sim as incorporator and Lakha and Wallace as directors — the anchor filing showing Sim as the incorporator who hand-delivered the takeover vehicle's charter. 
6. Sim to Wallace, June 23, 2006, reporting an overdraft transfer on Wallace's Secured account and payroll funding email to Munjit Johal — the WIP incorporator shown personally running Wallace's private and payroll banking. 
7. Sim to Martin, August 30, 2006, corresponding with Americash on the Secured Lending account — extending Sim's bookkeeping role into the SDI lending subsidiary used to strip assets. 
8. Sim to Wallace, July 4, 2005, earliest WIP formation correspondence naming and structuring the entity — showing Sim originating the concealed-ownership vehicle from inception. 

Kelly Black

Wallace's associate and the enterprise's offshore-distribution channel in the SDI → Galaxy Gaming takeover. Black entered alongside Wallace under a “Wallace Black Financial” consulting arrangement,¹ and the record ties her to the 15,000,000-share SDI control block (Feb. 2, 2006) and a 48.97% control transfer executed without shareholder approval. Her signature act was opening the foreign sales channel: a 12 July 2006 email forwarding Frankfurt Stock Exchange listing documents to Wallace, seeking to place SDI stock on Germany's Freiverkehr segment to reach “European retail investors” — the offshore conduit through which the manufactured float would be distributed.² The emails make her role concrete: she forwarded the Frankfurt / Freiverkehr listing documents to Wallace,³ was the recipient of the new shares issued to “Wallace and Black” and “run by Kyleen,”⁴ was updated on the rolled-back shares,⁵ papered the Wallace Black, LLC entity,⁶ and is the subject of the ghost-drafted declaration reciting the looting allegations.⁷

1. Secured Diversified Inv., Ltd., Form 8-K at 1–2 (Sept. 15, 2005), Acc. No. 0001255294-05-000562 (“Wallace Black Financial” consulting agreement).
2. Email from Kelly Black to Jan Wallace forwarding Frankfurt Stock Exchange / Freiverkehr listing documents (July 12, 2006); SDI forensic brief (15,000,000-share Iomega/Wallace control block; 48.97% control transfer without shareholder approval).
3. Email, Kelly Black to Jan Wallace, Jul. 12, 2006 — forwarding Frankfurt Stock Exchange / Freiverkehr listing documents to place SDI stock before European retail investors. 
4. Email, Scott Doney to Jan Wallace, Aug. 30, 2006 — proposing new share issuances to “Wallace and Black,” “Let me run this by Kyleen.” 
5. Email, Jan Wallace to Kelly Black, Sep. 4, 2006 — update on the rolled-back (reverse-split) SDI shares. 
6. Email, Kayla Dickson (Cane Clark LLP) to Jan Wallace, Jun. 16, 2006 — re the Wallace Black, LLC name change. 
7. Email, Claire Ambrosio to Kelly Black, cc Wallace, Apr. 4, 2006 — the ghost-drafted sworn shareholder declaration reciting the SDI / Cannery looting allegations. 

Pierre Ergas

"The General"

Known within the enterprise as “The General.” A French national operating through the Epsilon Group and the OB1 Trust at ANZ Bank Singapore, Ergas was brought into the SDI takeover as the international-investor front: his physical presence at meetings signaled to existing management that Wallace and Cane were “backed by serious international investors,” lending credibility to the offshore distribution channel Kelly Black had opened through Frankfurt.¹ He is the human face of the cross-border stock-and-money movement that concealed beneficial ownership of the manufactured float.

1. SDI forensic brief — Pierre Ergas (“The General”), French national operating through the Epsilon Group and OB1 Trust at ANZ Bank Singapore; introduced to signal international-investor backing for the SDI offshore distribution channel.

Kayla Dickson

Cane Clark LLP corporate/legal staff — the administrative hand inside Cane's own office at 3273 E. Warm Springs Rd., Las Vegas. In Wallace's email correspondence, Dickson is the person who drafts the corporate resolutions and entity paperwork for the enterprise's shells: a 16 June 2006 message to Jan Wallace and Kelly Black (cc Scott Doney) on the “Wallace Black, LLC” name change has her asking for the operating agreement “before we can draft the resolution for the name change.” She writes from KDickson@caneclark.com (alias Reception@CaneClark.com), placing her at the front desk and document-production line of the firm that served as EDGAR filing agent and Nevada registered agent across the network. She is administrative staff — not alleged to have directed any scheme — but her correspondence is the day-to-day record of how the shell entities were papered.¹ Dickson held and transmitted the Savannah Corp charter documents and circulated the corporate director consent effecting SDI's 20-to-1 reverse stock split, instructing recipients: "Please circulate THIS document for signature, NOT the previous one."²

1. Email, Kayla Dickson (Cane Clark LLP) to Jan Wallace & Kelly Black, cc Scott Doney, “FW: Wallace Black, LLC Name Change” (June 16, 2006) (KDickson@caneclark.com / Reception@CaneClark.com; 3273 E. Warm Springs Rd., Las Vegas) (“Before we can draft the resolution for the name change I will need you to provide me with an Operating Agreement for this entity.”); Wallace email corpus, Dickson recurring as sender / cc on Cane Clark entity-formation correspondence.
2. Dickson to Wallace, August 21, 2006, transmitting Savannah Corporation's Articles of Incorporation and Certificate of Amendment — Dickson holding and transmitting the charter documents for a shell inside the Cane-Wallace network. 
3. Dickson to Johal, August 1, 2006, circulating the corrected corporate director consent to the 20-to-1 stock split, "Please circulate THIS document for signature, NOT the previous one." — Dickson managing the signature drive behind the share rollback. 
4. Dickson to Wallace, August 3, 2006, routing SDI's Form 8-K for signature — tying Dickson to execution of the current-report filing closing the share actions. 
5. Dickson to Wallace, June 16, 2006, re the name change for Wallace's personal consulting entity, Wallace Black, LLC — Dickson papering Wallace's personal entity in the same period as the SDI share manipulation. 
6. Dickson to Wallace, August 23, 2006, following up on Savannah Corp's missing EIN — confirming Dickson's continued custody of the Savannah Corp shell's formation records. 

Jay Kister

WIP-linked SDI insider · Secured Lending (SDL) participant

A WIP-linked insider installed as interim president of the enterprise's “Secured Lending” (SDL) joint venture layered onto SDI. In a June 2006 email captioned “Money,” Kister put in writing a round-trip designed to deceive the outside auditor: he would “get the 250K,” “wire it to SDI from Infinity Lending Services, Inc.,” place it in “the Secured Lending Account with Wells Fargo” so “the CPA can do his Verification and Audit,” then “transfer the money out and return it to its place and everything has been accomplished” — coordinating with the CPA “so that the audit runs smoothly.” Wallace kept it off the record: “Jay lets talk about the process tomorrow.”¹ The same $250,000 runs through the SDI joint-venture structuring — “contributed by SDI as a loan in some form (note most likely) … not sure if this is loan or contribution — see Jan”² — and he pressed to have SDI reimburse his own money put into a Scottsdale property.³

1. Email thread, Jay Kister (Infinity / iLend Services) to Jan Wallace, “Money” (June 14–15, 2006) — Kister describes securing the $250,000, wiring it into SDI so “the CPA can do his Verification and Audit,” then transferring it back out (“return it to its place and everything has been accomplished”); Wallace replies, “Jay lets talk about the process tomorrow.” 
2. Email, Jan Wallace to Jay Kister, May 10, 2006, transmitting the SDI joint-venture / Secured Lending draft articles and operating agreement — the $250,000 “probably contributed by SDI as a loan in some form (note most likely) … not sure if this is loan or contribution — see Jan,” with Kister as interim president. 
3. Email, Jay Kister to Jan Wallace, May 24, 2006 — pressing for an SDI reimbursement of the money he put into the Scottsdale property (Mark Henry; ~$250,000). 