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application fee of $2,000 to create an offshore investment
package, which consisted of a legal opinion letter regarding the
U.S. tax law compliance of CLGs,12 and an investment portfolio
that included CLGs and petitioners’ Leadenhall bank account and
Mastercard credit card. Mr. Wright, acting through Hal Jones
(Mr. Jones), a Cash-4-Titles promoter, created the CLGs to be
conduits to funnel his and his clients’ funds to a new mutual
fund.
The mutual fund was set up and run in the Bahamas by
Cardinal International, which, in turn, was supposed to have
invested the funds in the U.S. title loan business a.k.a Cash-4-
Titles. Ms. Mohr invested in a CLG called Blues Brothers Limited
(Blues Brothers), and petitioners invested in CLGs called
Britannia, Footpaths Limited, and Sarasota Investment Club #2.
The Mastercard credit card that Leadenhall issued to, and that
was used by, petitioners was in the name of one of their CLGs,
Sarasota Investment Club #2.
Shortly after petitioners and Ms. Mohr made the investments,
Cash-4-Titles was shut down by the SEC. A class action lawsuit
and a lawsuit by the court-appointed receiver were commenced
against Bank of Bermuda by or on behalf of the American
11(...continued)
No. 18, sec. 7 (1992).
12The opinion letter was issued by Dean & Heimos, L.L.C., a
Colorado law firm.
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