Mark N. Wright and Erica Y. Wright - Page 10

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          unaware that Cash-4-Titles was a Ponzi scheme, but was aware of             
          the offshore credit cards and the tax evasion opportunity they              
          offered, at the time he recommended it to Ms. Mohr and invested             
               Petitioners and Ms. Mohr made several investments in Cash-4-           
          Titles.  The investments in which petitioners and Ms. Mohr both             
          participated resulted in class action lawsuits.  Another                    
          investment, in which only Ms. Mohr participated, resulted in a              
          National Association of Securities Dealers (NASD) claim by Ms.              
          Mohr against Mr. Wright for “violations of the Florida Securities           
          and Investor Protection Act; violations of federal securities               
          laws; breach of contract; common law fraud; breach of fiduciary             
          duty; negligence and gross negligence.”                                     
                    1. Class Action Lawsuit                                           
               In the first type of investment in Cash-4-Titles,                      
          petitioners and Ms. Mohr invested in offshore entities known as             
          “companies limited by guarantee” (CLGs).11  Mr. Wright paid an              

          affect the Court’s conclusions.  Thus, notwithstanding the trial            
          ruling admitting Mr. Sullivan’s testimony, the Court has not                
          considered his testimony in that regard in deciding this case.              
               11A company limited by guarantee (CLG) is an entity of                 
          United Kingdom origin that does not have an exact counterpart in            
          U.S. tax law.  Bahamian law defines a “company limited by                   
          guarantee” as “a company [that] is formed on the principle of               
          having the liability of its members limited to such amount as the           
          members respectively undertake to contribute to the assets of the           
          company in the event of a winding up”.  Companies Act 1992, Act             

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Last modified: May 25, 2011