finston v christofferson

8/20/2019 Finston v Christofferson

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UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

MATTHEW FINSTON,

Plaintiff,

v.

TAYLOR CHRISTOFFERSEN, SAMUELCHARLES CARY, BRADY FARRELL, andADDISON BRADLEY BACHMAN,

Defendants. _______________________________________/

VERIFIED COMPLAINT AND JURY DEMAND

Plaintiff Matthew Finston, through counsel, states as follows for his Verified Complaint

against Defendants Taylor Christoffersen, Samuel Charles Cary, Brady Farrell, and Addison

Bradley Bachman (“Defendants”):

1. Matthew Finston is a New York resident who maintains his principal residence in

New York, New York.

2.

Taylor Christoffersen is a Kansas resident who maintains his principal residence

at 1356 155th, Olathe, Kansas 66062.

3. Samuel Charles Cary is a Texas resident who maintains his principal residence at

17810 White Tail Court, Houston, Texas 77084.

4. Brady Farrell is an Arizona resident who maintains his principal residence at

32203 North 16th Avenue, Phoenix, Arizona 85085.

5. Addison Bradley Bachman is a New Mexico resident who maintains his principal

residence in Columbus, New Mexico.

2:15-cv-12013-AJT-DRG Doc # 1 Filed 06/04/15 Pg 1 of 6 Pg ID 1


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6. Upon information and belief, Defendants are the owners, operators, and

administrators of the website www.mmj.today.

7. Upon information and belief, www.mmj.today is not owned or operated by an

independent corporation or partnership.

8. www.mmj.today is a website purporting to “inform the community about the

science, industry, lifestyle, health, business and politics surrounding medical marijuana around

the world and related industry subjects.”

9. www.mmj.today is viewable, and has been viewed, by residents in the state of

Michigan.

10. Jurisdiction is proper in this District pursuant to 28 U.S.C. §§ 1331, 1332 because

the amount in controversy exceeds $75,000 and the dispute is between citizens of different States

and a foreign state.

11. Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(3) because each

of the defendants are subject to this Court’s personal jurisdiction.

General Allegations

12. Finston is an online author who writes about investing and corporations.

13. Fisnton regularly posts articles on a website seekingalpha.com, where he has

posted at least 75 articles on a wide variety of subjects.

14. Finston has published a number of articles regarding companies that are vying to

supply the anticipated legal marijuana market in Canada.

15. On occasion, Finston has been critical of a company called CEN Biotech.

16. CEN Biotech trades under the symbol FITX.



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17. Defendants, through www.mmj.today, published an article on May 8, 2015

entitled “Potential Criminal Indictment of Stock Basher Matthew Finston.” (Ex. A, the

“Article”.)

18. Defendants appear to have updated the Article since May 8, 2015 to include the

words “From our viewpoint” and “allegedly.” Such statements do not make the article any less

defamatory.

19. The Article maliciously and falsely claims that Finston “has engaged in obvious

and admitted fraudulent conduct and willful misrepresentations with the intent to manipulate the

price of FITX and cause a loss of value to shareholder’s stock – as sellers or purchasers. His

alleged fraudulent conduct satisfies all of the elements . . . necessary to constitute a Rule 10b-5

violation.” (Ex. A.)

20. The Article is defamatory. Finston has not engaged in fraudulent conduct, and

Finston has not made willful misrepresentations to manipulate stock prices or cause a loss of

value to shareholder’s stock.

21.

The Article was published maliciously, with knowledge that it was false, or with

reckless disregard as to whether it was false.

22. On May 10, 2015, Finston demanded a retraction of the Article. (Ex. B.)

23. Defendants did not respond to Finston’s demand for retraction, and Defendants

have not removed the article from the website.

24. The Article constitutes defamation per se, which is independently actionable

pursuant to MCL 600.2911.

25. Finston has been damaged as a result of the Article.

26. Finston seeks judgment as set forth below.



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Count I - Defamation

27. Finston incorporates the allegations in the foregoing paragraphs as though fully

set forth here.

28. The Article makes false and defamatory statements about Finston.

29. Specifically, the Article falsely states that Finston committed a crime by

fraudulently manipulating stock prices.

30. The Article is capable of being viewed by anyone in the world with internet

access.

31.

The Article was published maliciously, with knowledge that it was false, or with

reckless disregard as to whether it was false.

32. The Article was per se defamatory pursuant to MCL 600.2911(1).

33. Finston has been damaged by the Article.


Count II – False Light Invasion of Privacy

35.

Finston incorporates the allegations in the foregoing paragraphs as though fully

set forth here.

36. The Article placed Finston in a false light in the public eye.

37. The Article gave Finston unwanted publicity.

38. Upon information and belief, the Article was viewed by thousands of people, if

not millions of people, because it is capable of being viewed by anyone in the world with internet

access.

39. Defendants knew or acted with reckless disregard as to the falsity of the Article

and the false light in which it placed Finston.



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40. Finston has been damaged by the Article.


Prayer for Relief

WHEREFORE, Finston respectfully requests that this Court enter judgment:

A. Awarding Finston money damages sufficient to compensate him for all forms of

economic loss including, without limitation, actual, incidental, consequential, and/or exemplary

damages;

B. Awarding Finston punitive damages pursuant to MCL 600.2911;

C. Awarding Finston all legal fees and costs associated with bringing this lawsuit;

and

D. Awarding Finston any and all such other relief as this Court deems just, equitable

and appropriate under the circumstances.

Jury Demand

Finston demands a jury for all matters so triable.

Respectfully submitted,

BOYLE BURDETT

By:/s/H. William Burdett, Jr.Eugene H. Boyle, Jr. (P42023)H. William Burdett, Jr. (P63185)

14950 East Jefferson, Suite 200Grosse Pointe Park, Michigan 48230(313) 344-4000 [email protected]

Dated: June 4, 2015 Attorneys for Matthew Finston



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UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF MICHIGAN

MATTHEW FINSTON,

Plaintiff,

v.

TAYLOR CHRISTOFFERSEN, SAMUEL

CHARLES CARY, BRADY FARRELL, andADDISON BRADLEY BACHMAN,

Defendants

_______________________________________/

INDEX OF EXHIBITS

Ex. A - Article published in mmj.today

Ex. B - Requests for Retraction

2:15-cv-12013-AJT-DRG Doc # 1-1 Filed 06/04/15 Pg 1 of 1 Pg ID 7


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EXHIBITA



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P o t e n t i a l C r i m i n a l I n d i c t m e n t o f S t o c k B a s h e r M a t t h e w F i n s t o n –

U p d a t e d

Admin May 8, 2015 Business, Scandal and Tension, Tension 3,506 Views

In light of recent developments surrounding an alleged campaign to destroy the publicly traded

company’s share price. CEN Biotech (OTC: FITX), a Canadian subsidiary actively engaged in seeking a

licence to grow marijuana under Canada’s newly formed MMPR, has had approximately 100 documented

negative and defamatory articles written against the company over the span of just 1 year, almost

exclusively (60+) by just a few individuals. One of these individuals, Matt Finston, has contributed over 20

articles to this… “pool of libel”.

Today, we would like to expound further upon some of the evidence MMJ.TODAY brought to light in a recent

article, and also to explain, just why Mr. Finston could in fact soon be facing criminal indictment for his

feracious attacks on the company’s publicly traded value.

The Securities Exchange Act of 1934 is a law governing the secondary trading of securities (stocks, bonds,

and debentures) in the United States.

Section 10 prohibits the willful manipulation of stock and the stock price as well as other fraud. It

also grants a private right of action in the statute. Section 10 is the predominant all-purpose fraud

provision, which includes similar conduct to that identified in Section 9, but less of a threshold of

intent than that required by Section 9 and, unlike Section 9, Section 10 is applicable to

C h e c k A l s o

C a p r i c i o u s A c t i o n s b y H e a l t h

C a n a d a C a u s i n g D e t r i m e n t a l

R e l i a n c e t o M M P R A p p l i c a n t s

Capricious Actions by HealthCanada Causing DetrimentalReliance to MMPR

Applicants Health Canadaplays favorites ...


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unlisted/OTC companies.

10. SEC. 10. REGULATION OF THE USE OF MANIPULATIVE AND DECEPTIVE DEVICES

11. General Purpose and violations of Rule 10b-5 of the 1934 Act

The purpose of the 1934 Act is, among other things, to ensure a fair and honest marketplace.

Rule 10b-5 of the 1934 Act makes it unlawful in the connection with the purchase or sale of any securities

for any person directly or indirectly by the use of any means or instrumentality of interstate commerce or

of the mails, to: 1) to employ any device, scheme or artifice to defraud; 2) make any untrue statement of a

material fact; 3) to engage in any act, practice or course of business which operates as a fraud or deceit

upon any person.

1. Prohibition of Fraudulent Short Sales

Subsection(a)(1) states, to effect a short sale , or to use or employ

any stop loss order in connection with the purchase or sale, of any

security other than a government security, in contravention of such

rules and regulations as the Commission may prescribe as necessary

or appropriate in the public interest or for the protection of investors.

(b) To use or employ, in connection with the purchase or sale of

any security not so registered, any manipulative or deceptive device or contrivance in contravention

of such rules and regulations as the Commission may prescribe

1. Satisfaction of Essential Elements

2. Fraud or Deception

3. Concerning a material fact

4. In Connection with purchase/sale of a security

5. Scienter (fraudulent intent – knew or should have known it was false when stated)

6. Reliance and Causation – Plaintiff must have relied (detrimental reliance) on deception/fraud causing

damages

The “in connection with” element is an essential one going to the reliance aspect of the tort. As any fraud

action, the plaintiff must have relied on the misrepresentation. In Semerenko v. Cendent Corp., 223 F. 3rd

165 (3rd Cir. 2000), cert. denied, 531 US 1149 (2001), where the Plaintiff shows the defendant’s fraudulent

conduct caused the loss, the “in connection” element in satisfied, however, showing the conduct was in


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connection with the transaction does not necessarily prove reliance. See, Semerenko v. Cendent Corp.,

223 F. 3rd 165 (3rd Cir. 2000), cert. denied, 531 US 1149 (2001).

1. Venue for a Rule 10b-5 Suit

Federal courts have exclusive jurisdiction over Rule 10b-5 claims,

thus they must be filed in federal district court. Plaintiffs may filesuch actions in the federal district court of any district in which any

act or transaction in violation of the rule occurred ; or by traditional venue provisions, in the district where

the defendant is found, resides or transacts business .

1. State court claims.

State claims for common law fraud can be brought in the federal court (Rule 10b-5 action).

1. Application

From our viewpoint, Matt Finston has engaged in obvious and admitted fraudulent conduct and willful

misrepresentations with the intent to manipulate the price of FITX and cause a loss of value to

shareholder’s stock – as sellers or purchasers. His alleged fraudulent conduct satisfies all of the elements

(identified above) necessary to constitute a Rule 10b-5 violation. Finston has stated on more than one

occasion on Twitter that he likes to bash FITX stock and he wanted to short it. He states, “I want to short

it.” “I tried shorting it when it was $.067 would have made a nice 30% return.” On

another occasion Finston tweeted, “I wish your CEO would reverse split so that the

share price would be higher so it’s be easier to short”. On yet another occasion

Finston states the following about FITX, “I’ll bash them all on fb, twtr, I’ll write their

names on the doors of ___________ if I have to. F—k these guys”.

In a one year period commencing with one of the first articles on April 14, 2014,

Matt Finston wrote in excess of twenty articles and hundreds of tweets bashing

Creative Edge; a seemingly inordinate amount of negative articles for one writer to publish about a single

company. Each time an article was published, the stock would suffer a loss in value. In the year long

period during Finston’s fraudulent assault (reasonably concluded as such), the stock went from $0.068 on

May 29, 2014 to $0.0085 on May 4, 2015. If you add the articles written by Chris Parry and Grant


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Robertson to Finston’s, it totals over 60 bash articles in the same year long period, and that does not

include other associated websites and bloggers who jumped in on the action based upon the information

from these writers. Between the three “reporters”, not one positive article was written about the

Company. Each and every one of Finston’s articles published false information with apparent intent to

damage and devalue the Company’s stock price.

1. Latest Finston Article Aimed at Shareholders

During the month of April 2015, fed up with the lack of protection they were receiving from regulatory

authorities, CEN Biotech’s corporate office was cc’d on close to 300 letters shareholders written to theSecurity and Exchange Commission to identify the many instances of fraud perpetrated against FITX,

(including the alleged fraud perpetrated by Finston), and inquiring into the reason why the SEC refused to

investigate such fraud and requesting that an investigation be commenced. On May 3, 2015, Finston

wrote an “article” on the blog site “Seeking Alpha” mocking the hundreds of letters that shareholders had

written to the various SEC offices, by writing his own letter to the SEC offices in Chicago.

The May 3rd article included the content of Finston’s letter to the Chicago SEC office, which espoused to

counter the claims of fraud elicited from FITX shareholders.

Although none of the shareholders who wrote letters of complaint received anything more than a form

letter in response to their complaints, Matt Finston actually received a personal email from an SEC agent

in the Chicago office, within 12 hours of emailing his letter to the office. The response from the SEC agent

stated, “Mr. Finston, if possible can you contact me regarding the information that you sent to the SEC,

Regards, ________”. A second personal email from this SEC agent was sent to Finston stating, “[c]an you call

me at: _________”. Unbelievably, although we will not show the name and contact information for this SEC

agent, Finston actually published the name and personal contact info of this agent as well as showing

screen shots of the actual emails. Conduct that almost certainly violates SEC internal procedure.

Unfortunately, this SEC agent learned the hard way, or at least should have learned, that Mr. Finston is a

person completely out for his own gain who cannot be trusted.

In summary, we have the SEC immediately responding to Finston, a person whom they learned cannot be

trusted, yet upon information and belief, the SEC has as of yet essentially failed to address any of


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the Complaints and concerns raised by the hundreds of shareholders, whom the SEC was empowered to

protect. At the very least, the shareholders certainly weren’t afforded a personal email response from a

specific agent giving them the agents personal contact number, requesting that they call. Therefore, the

basher is treated with more respect than the shareholders.

1. The concept of “Bashing”

As a side note, I found it interesting that the “Bashers” deny on the “boards” that such a thing actually

exists, yet even Wikipedia acknowledges it as a widely known method of stock manipulation, identifying it

as a common method of such Fraud. The entry states

Stock Bashing: “This scheme is usually orchestrated by savvy online message board posters (a.k.a.

“Bashers”) who make up false and/or misleading information about the target company in an attempt to

get shares for a cheaper price. This activity, in most cases, is conducted by posting libelous posts on

multiple public forums. The perpetrators sometimes work directly for unscrupulous Investor Relations

firms who have convertible notes that convert for more shares the lower the bid or ask price is; thus the

lower these Bashers can drive a stock price down by trying to convince shareholders they have bought a

worthless security, the more shares the Investor Relations firm receives as compensation. Immediately

after the stock conversion is complete and shares are issued to the Investor Relations firm, consultant,

attorney or similar party, the basher/s then become friends of the company and move quickly to ensure

they profit on a classic Pump & Dump scheme to liquidate their ill-gotten shares. (see P&D)”

Consequently, it is somewhat incomprehensible that many regulators don’t seem the least bit concerned

with Matt Finston and his cronies’ bashing and stock manipulation.

The company CEN Biotech is now going through the process of Judicial Review with the Federal Courts in

Canada in response to a denial letter of their license. A denial letter that the company believes was issued

on false pretenses or insufficient evidence, such examples of which can be found through factual and

systematic analysis of the company’s progress, coupled with the articles and misrepresentations

mentioned in this article by certain writers.

Mason Godric

Disclaimer: This article does not constitute a recommendation to buy or sell securities. If you have any

doubts as to the merits of an investment, you should seek advice from an independent financial



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adviser. Investment in the securities of smaller companies can involve greater risk than is generally

associated with investment in larger, more established companies that can result in significant capital

losses that may have a detrimental effect on the value of the fund. You should not buy securities unless

you are prepared to sustain a total loss of the money you have invested plus any commission or other

transaction charges.

This article constitutes reasonable opinions of MMJ and the general public based upon a plethora of

evidence in support of it’s subject matter, as well as hundreds of written accounts from the public.

Readers are advised to determine their own opinions based upon any and all evidence available to them

from MMJ.TODAY and other sources.



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EXHIBIT B



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From: matthew finston [email protected]: MMJ.TODAY

Date: May 10, 2015 at 9:59 AMTo: [email protected]

In regards to your latest article,

This is a request to remove my name and any reference to my name from your website MMJ.TODAY that you claim association with. You and

your website have made false statements about me. You have falsely called me a criminal and a fraud. I have not been convicted of any crimenor have committed any crime. A website that you have stated partial ownership of has claimed otherwise. The statements were made withcomplete disregard of the truth. and had you asked seeking alpha whether or not my statements violated any disclosure rules you would havefound that they have not.

This is “defamation per se."

Defamation Per Se

Slander per se consists of any one of the following:

Statement charging an individual with a serious crime; Liberman v. Gelstein, 80 N.Y.2d 429, 435 (1992).

Libel per se consists of

“[a]ny written or printed article . . . if i t tends to expose the plaintiff to public contempt, ridicule, aversion or disgrace, or induce an evil opinion of

him in the minds of right-thinking persons, and to deprive him of their friendly intercourse in society.”Rinaldi v. Holt, Rinehart & Winston, Inc.,

42 N.Y.2d 369, 379 (1977)

In your article, you claim that my statements are evidence of criminal stock bashing. Not only did I confirm with Seeking Alpha that I have

committed no wrong doing, another shareholder went ahead and first asked the SEC whether or not I have broken any laws.

". Each and every one of Finston’s articles published false information with the intent to damage and devalue

the Company’s stock price."

I emailed the managing editor at seeking alpha the following:

"I never shorted FITX but I did state publicly that it would have been nice if I could. Have I violated

any of Seeking Alpha’s disclosure rules? I didn’t think it was wrong to state a desire to make money

as it was clear the stock would inevitably lose in value.

Tuesday, October 07, 2014 8:35:09 PM 42438 Post # of 175204

I am the same Matt Finston that said "I want to short FITX." I called my brokerage and tried shorting it

at .067, well before I wrote that most recent article on the company. Sadly, my brokerage said that to


mailto:[email protected]:[email protected]:[email protected]:[email protected]


17/31

short just 4,000 shares, I had to put up $10,000 for the margin. 4,000 shares? You mean lock-up

$10,000 just to short $268, where my maximum profit would be $268? Yeah, I would love to short

FITX. Just not worth locking up $10,000.

Now If I could have shorted $10,000 worth of FITX at .067, that would've been nice. I could have

taken home $3800 in profit. But $101.84? I'll pass.

Any ideas on how to short this without the crazy margin requirements? Looking at interactive brokers.any others?

I don’t understand why shareholders are making such a big deal about it. Perhaps they are unable to

separate wanting to profit from a stock’s change in value versus holding a grudge against the

company?"

Seeking alpha responded with the following:

No. That exceeds any requirement we have. You had no position and said so. I'd like to go long

10,000 shares of Apple, but I don't have the capital to do so. Saying that's my goal indicates my

bullishness on the company though, which is more valuable to readers.

In sum, you're good.Thanks,

GBM

George B. Moriarty

Managing Editor, Opinion & Analysis

Seeking Alpha"

MMJ.TODAY has committed libel with the following. This is 100% false.

". Each and every one of Finston’s articles published false information with the intent to damage and devalue the Company’s stock price.”----

You claim the following ""Matt Finston has engaged in obvious and admitted fraudulent conduct and willful misrepresentations with the

intent to manipulate the price of FITX and cause a loss of value to shareholder’s stock – as sellers or

purchasers. His fraudulent conduct satisfies all of the elements (identified above) necessary to constitute a

Rule 10b-5 violation. "

This is what the SEC wrote in response to a shareholder with a similar concern:

RE: Recent complaint by one Matthew Finston regarding CEN Biotech

Paggi, Terry A. ([email protected])

Add to contacts

5/05/15

[Keep this message at the top of your inbox]

[email protected]

Opinions provided on internet blogs falls under the First Amendment of Free Speech. Where the line can be crossed is when someone uses a

media to their benefit in securities trading. An example would be if someone held many shares of a stock and spread a rumor online that

would cause others to buy the stock and drive the price up and the person would then sell the stock at the inflated price.

Also, Mr. Finston posting email communication that I sent him is not a violation of any laws. If you have any questions, please feel free to

contact me.

Regards,

__________________________________________________________________________________


mailto:[email protected]:[email protected]


18/31

cid:[email protected]

Terry A. Paggi, CFE, CAMS

U.S. Securities and Exchange Commission

Division of Enforcement

Chicago Regional Office

175 W. Jackson Blvd.

Suite 900

Chicago, IL 60604'Tel: 312.353.1050

*E-mail: [email protected]

" Unbelievably, although we will not show the name and contact information for this SEC agent, Finston

actually published the name and personal contact info of this agent as well as showing screen shots of the

actual emails. Conduct that certainly violates SEC internal procedure. “

and as the SEC states:

"Mr. Finston posting email communication that I sent him is not a violation of any laws. If you have any questions, please feel free to contact

me."

And this laughable but also defamatory statement:

The article has also altered numerous statements that complete change the meaning. According to Masson v. New Yorker

Magazine, Inc. falsely attributing a statement is defamatory.

The article states: "On yet another occasion Finston states the following about FITX, “I’ll bash them all on

fb, twtr, I’ll write their names on the doors of ___________ if I have to. F—k these guys”.’

No. It wasn’t. It was quoting the following https://www.youtube.com/watch?v=vRq8lMXoAxE

I have publicly clarified this quote numerously yet it continues to be misquoted in order to ruin my character. This demonstrates gross

negligence of the truth and malicious intent.

The article has caused enough damage that Brady Farrell posted the following statement:


https://www.youtube.com/watch?v=vRq8lMXoAxEmailto:[email protected]://cid:[email protected]/


19/31

Anyone who has read this article has now come to associate me with criminal activity.

This is a request to please cease and desist publishing defamatory statements about my person. As you have stated publicly thatMMJ.TODAY was your website, or at least you have shared ownership, that tells me you are taking responsibility for the statements that havebeen published. This is the last time I will send an email to you, Taylor Christoffersen, directly. The next time you will hear from me will bethrough an attorney. And the address on file is 1356 155Th, Olathe, KS 66062.



20/31

From: matthew finston [email protected]: For your information

Date: May 25, 2015 at 3:32 AMTo: [email protected]: [email protected]

The following has been posted on your website since May 10th. A similar email was sent to [email protected].

This is not a ‘final warning’ because you have already received that. This is for your records as well as to let you know that I will be filing a

lawsuit.

This is a request to remove my name and any reference to my name from your website MMJ.TODAY. Youand your website have made false statements about me. You have falsely called me a criminal and a fraud.I have not been convicted of any crime nor have committed any crime. The statements were made withcomplete disregard of the truth. and had you asked seeking alpha whether or not my statements violatedany disclosure rules you would have found that they have not.


Defamation Per Se


Statement charging an individual with a serious crime; Liberman v. Gelstein, 80 N.Y.2d 429, 435 (1992).Libel per se consists of

“[a]ny written or printed article . . . if it tends to expose the plainti! to public contempt, ridicule, aversionor disgrace, or induce an evil opinion of him in the minds of right-thinking persons, and to deprive him oftheir friendly intercourse in society.”Rinaldi v. Holt, Rinehart & Winston, Inc., 42 N.Y.2d 369, 379 (1977)

In your article, you claim that my statements are evidence of criminal stock bashing. Not only did I confirmwith Seeking Alpha that I have committed no wrong doing, another shareholder went ahead and first askedthe SEC whether or not I have broken any laws.

MMJ.TODAY States:". Each and every one of Finston’s articles published false information with the intent to damage anddevalue the Company’s stock price."


"I never shorted FITX but I did state publicly that it would have been nice if I could. Have I violated any ofSeeking Alpha’s disclosure rules? I didn’t think it was wrong to state a desire to make money as it was clearthe stock would inevitably lose in value.

Tuesday, October 07, 2014 8:35:09 PM 42438 Post # of 175204I am the same Matt Finston that said "I want to short FITX." I called my brokerage and tried shorting it at.067, well before I wrote that most recent article on the company. Sadly, my brokerage said that to short

just 4,000 shares, I had to put up $10,000 for the margin. 4,000 shares? You mean lock-up $10,000 justto short $268, where my maximum profit would be $268? Yeah, I would love to short FITX. Just not worthlocking up $10,000.Now If I could have shorted $10,000 worth of FITX at .067, that would've been nice. I could have takenhome $3800 in profit. But $101.84? I'll pass.Any ideas on how to short this without the crazy margin requirements? Looking at interactive brokers. anyothers?I don’t understand why shareholders are making such a big deal about it. Perhaps they are unable toseparate wanting to profit from a stock’s change in value versus holding a grudge against the company?"Seeking alpha responded with the following:No. That exceeds any requirement we have. You had no position and said so. I'd like to go long 10,000shares of A le, but I don't have the ca ital to do so. Sa in that's m oal indicates m bullishness on the


mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]


21/31

company though, which is more valuable to readers.In sum, you're good.Thanks,GBMGeorge B. MoriartyManaging Editor, Opinion & AnalysisSeeking Alpha"

This demonstrates that MMJ.TODAY has grossly erred by stating the following 100% false statement:". Each and every one of Finston’s articles published false information with the intent to damage anddevalue the Company’s stock price.”----

The article further falsely claims the following:"Matt Finston has engaged in obvious and admitted fraudulent conduct and willful misrepresentations withthe intent to manipulate the price of FITX and cause a loss of value to shareholder’s stock – as sellers orpurchasers. His fraudulent conduct satisfies all of the elements (identified above) necessary to constitute aRule 10b-5 violation. "


RE: Recent complaint by one Matthew Finston regarding CEN BiotechPaggi, Terry A. ([email protected])

Add to contacts5/05/15[Keep this message at the top of your inbox][email protected] provided on internet blogs falls under the First Amendment of Free Speech. Where the line can becrossed is when someone uses a media to their benefit in securities trading. An example would be ifsomeone held many shares of a stock and spread a rumor online that would cause others to buy the stockand drive the price up and the person would then sell the stock at the inflated price.Also, Mr. Finston posting email communication that I sent him is not a violation of any laws. If you haveany questions, please feel free to contact me.Regards,__________________________________________________________________________________cid:[email protected]

Terry A. Paggi, CFE, CAMSU.S. Securities and Exchange CommissionDivision of EnforcementChicago Regional O"ce175 W. Jackson Blvd.Suite 900Chicago, IL 60604'Tel: 312.353.1050*E-mail: [email protected]

" Unbelievably, although we will not show the name and contact information for this SEC agent, Finstonactually published the name and personal contact info of this agent as well as showing screen shots of theactual emails. Conduct that certainly violates SEC internal procedure. “


"Mr. Finston posting email communication that I sent him is not a violation of any laws. If you have anyquestions, please feel free to contact me."


The article has also altered numerous statements that complete change the meaning. According to Massonv. New Yorker Magazine, Inc. falsely attributing a statement is defamatory.

The article states: "On yet another occasion Finston states the following about FITX, “I’ll bash them all onfb, twtr, I’ll write their names on the doors of ___________ if I have to. F—k these u s”.’


mailto:[email protected]://cid:[email protected]/mailto:[email protected]:[email protected]


22/31

No. It wasn’t. It was quoting the following film https://www.youtube.com/watch? The statement was directed at Chris Parry, Wolf of Weed St, and Matt Finston. It was a quote. And you haveskewed the interpretation of it even though I have made clear on numerous occasions that you havegrossly misconstrued the statements.

Even though I have publicly clarified this quote numerously yet it continues to be misquoted in order toruin my character. This demonstrates gross negligence of the truth and malicious intent.

The article has caused enough damage that Brady Farrell posted that my name and

"Criminal is trending #2 on Bing!"


You have falsely and maliciously called me a fraud. You have made numerous false statement that havecaused irreparable damage. These false statements were made with gross neglect of the truth in hopes ofdestroying me, my name, and my future. They have brought harm to my family and has impinged on ourability to make a living.

I have proven with clear and indisputable evidence that your article makes numerous false claims of factsand I will seek damages. The longer this is up, the greater the damage.

I see no other resolution to this other than legal action.


https://www.youtube.com/watch?


23/31

•

Matt Finston ! NYU Gallatin School of Individualized Study

This is a request to remove my name and any reference to my name from your websiteMMJ.TODAY. You and your website have made false statements about me. You have falsely calledme a criminal and a fraud. I have not been convicted of any crime nor have committed any crime.The statements were made with complete disregard of the truth. and had you asked seeking alphawhether or not my statements violated any disclosure rules you would have found that they havenot.


Defamation Per Se


Statement charging an individual with a serious crime; Liberman v. Gelstein, 80 N.Y.2d 429, 435(1992).Libel per se consists of

“[a]ny written or printed article . . . if it tends to expose the plaintiff to public contempt, ridicule,aversion or disgrace, or induce an evil opinion of him in the minds of right-thinking persons, andto deprive him of their friendly intercourse in society.”Rinaldi v. Holt, Rinehart & Winston, Inc., 42N.Y.2d 369, 379 (1977)

In your article, you claim that my statements are evidence of criminal stock bashing. Not only did Iconfirm with Seeking Alpha that I have committed no wrong doing, another shareholder wentahead and first asked the SEC whether or not I have broken any laws.

MMJ.TODAY States:". Each and every one of Finston’s articles published false information with the intent to damageand devalue the Company’s stock price."


"I never shorted FITX but I did state publicly that it would have been nice if I could. Have I violatedany of Seeking Alpha’s disclosure rules? I didn’t think it was wrong to state a desire to makemoney as it was clear the stock would inevitably lose in value.

Tuesday, October 07, 2014 8:35:09 PM 42438 Post # of 175204I am the same Matt Finston that said "I want to short FITX." I called my brokerage and triedshorting it at .067, well before I wrote that most recent article on the company. Sadly, mybrokerage said that to short just 4,000 shares, I had to put up $10,000 for the margin. 4,000

shares? You mean lock-up $10,000 just to short $268, where my maximum profit would be $268?Yeah, I would love to short FITX. Just not worth locking up $10,000.Now If I could have shorted $10,000 worth of FITX at .067, that would've been nice. I could havetaken home $3800 in profit. But $101.84? I'll pass.Any ideas on how to short this without the crazy margin requirements? Looking at interactivebrokers. any others?I don’t understand why shareholders are making such a big deal about it. Perhaps they are unableto separate wanting to profit from a stock’s change in value versus holding a grudge against thecompany?"Seeking alpha responded with the following:No. That exceeds any requirement we have. You had no position and said so. I'd like to go long



24/31

10,000 shares of Apple, but I don't have the capital to do so. Saying that's my goal indicates mybullishness on the company though, which is more valuable to readers.In sum, you're good.Thanks,GBMGeorge B. MoriartyManaging Editor, Opinion & Analysis

Seeking Alpha"

This demonstrates that MMJ.TODAY has grossly erred by stating the following 100% falsestatement:". Each and every one of Finston’s articles published false information with the intent to damageand devalue the Company’s stock price.”----

The article further falsely claims the following:"Matt Finston has engaged in obvious and admitted fraudulent conduct and willfulmisrepresentations with the intent to manipulate the price of FITX and cause a loss of value toshareholder’s stock – as sellers or purchasers. His fraudulent conduct satisfies all of the elements(identified above) necessary to constitute a Rule 10b-5 violation. "


RE: Recent complaint by one Matthew Finston regarding CEN BiotechPaggi, Terry A. ([email protected])Add to contacts5/05/15[Keep this message at the top of your inbox][email protected] provided on internet blogs falls under the First Amendment of Free Speech. Where theline can be crossed is when someone uses a media to their benefit in securities trading. Anexample would be if someone held many shares of a stock and spread a rumor online that wouldcause others to buy the stock and drive the price up and the person would then sell the stock atthe inflated price.Also, Mr. Finston posting email communication that I sent him is not a violation of any laws. If youhave any questions, please feel free to contact me.Regards,

__________________________________________________________________________________cid:[email protected] A. Paggi, CFE, CAMSU.S. Securities and Exchange CommissionDivision of EnforcementChicago Regional Office175 W. Jackson Blvd.Suite 900Chicago, IL 60604'Tel: 312.353.1050*E-mail: [email protected]

" Unbelievably, although we will not show the name and contact information for this SEC agent,Finston actually published the name and personal contact info of this agent as well as showing

screen shots of the actual emails. Conduct that certainly violates SEC internal procedure. “


"Mr. Finston posting email communication that I sent him is not a violation of any laws. If you haveany questions, please feel free to contact me."


The article has also altered numerous statements that complete change the meaning. According toMasson v. New Yorker Magazine, Inc. falsely attributing a statement is defamatory.



25/31

The article states: "On yet another occasion Finston states the following about FITX, “I’ll bash themall on fb, twtr, I’ll write their names on the doors of ___________ if I have to. F—k these guys”.’

No. It wasn’t. It was quoting the following film https://www.youtube.com/watch?The statement was directed at Chris Parry, Wolf of Weed St, and Matt Finston. It was a quote. Andyou have skewed the interpretation of it even though I have made clear on numerous occasions

that you have grossly misconstrued the statements.

Even though I have publicly clarified this quote numerously yet it continues to be misquoted inorder to ruin my character. This demonstrates gross negligence of the truth and malicious intent.

The article has caused enough damage that Brady Farrell posted that my name and

"Criminal is trending #2 on Bing!"


You have falsely and maliciously called me a fraud. You have made numerous false statement thathave caused irreparable damage. These false statements were made with gross neglect of thetruth in hopes of destroying me, my name, and my future. They have brought harm to my familyand has impinged on our ability to make a living.

I have proven with clear and indisputable evidence that your article makes numerous false claimsof facts and I will seek damages. The longer this is up, the greater the damage.

I see no other resolution to this other than legal action.

Reply ! Like ! 1 ! Follow Post ! May 10 at 10:16am

o

Matt Finston ! NYU Gallatin School of Individualized Study

so you didn't see this^^^^^???

Reply ! Like ! 1 ! May 17 at 7:33am

•

Chris Warner ! Northern Illinois University

And personally I appreciate people like Finston for shedding light and DD on corrupt companies!

Reply ! Like ! 1 ! Follow Post ! May 10 at 8:01am



26/31

•

Heyam C.Farrell ! HFCC

Finston can't take a taste of his own Medicine !!Karma is a Bitch isn't it Finston !!!!

Reply ! Like ! 1 ! Follow Post ! May 9 at 10:40pm

•

Brian Kaufmann

Let's hope the shareholders voices will finally be heard!


•

Brady Farrell ! Top Commenter ! Phoenix, Arizona

Matt Finston and criminal is trending #2 on Bing!!


•

Robert Young ! Follow ! Works at Retired and having a ball.

Look at him run for the bathroom to CHANGE HIS UNDERWEAR




27/31

•

Genghis Hill ! Everything at Everywhere

This is good info. DoorMatt is done.


•

Ericstevenc Sven Cantares ! Follow ! Works at Self-Employed

Tawdry escepades sorry


•

Ericstevenc Sven Cantares ! Follow ! Works at Self-Employed

Never does it again......


•

Joey Strickland ! Wingate University

Someone is in trouble.




28/31

•

Susan Barbee ! Top Commenter ! Owner at Self-Employed

Paulo Pincaro ,You seem to be at least somewhat objective. And I appreciate that.!

I have to ask you, Is this really your view on what has gone on with Cen Biotech? you made thiscomment.

"To me, it's pretty obvious that instead of actually seeking real answers for why the FITX groundswere never brought up to code in order to be re inspected and licensed, a bunch of naiveinvestors have essentially started looking for the boogeyman. But guess what? Even if Matt isindicted (wouldn't it be considered libel to suggest that when you have no evidence of such anoutcome forthcoming???), you still have to ask why months after the initial inspection, Bill didn'tsimply bring the building to code to satisfy the requirements as outlined in HC's initial evaluation.

You still have no answers as to why during the last three months you ... See More

Reply ! Like ! Follow Post ! Edited ! May 11 at 10:55am

o


From The FAQ .

WHY WAS THE PRE-LICENSE INSPECTION REPORT MADE PUBLIC?

A known shareholder to the company did a Freedom of Information Act request, and receivedfrom the Privacy Commissioner under the Authority from Health Canada, the full inspectionreport. So as to not allow this shareholder sensitive inside information, CEN Biotech, Inc.immediately released the inspection report per their legal obligations to the SEC.

The press release states clearly: “As CEN Biotech Inc. continues in its effort to be transparent, itreleases its Health Canada Pre-License inspection report.” The report can be viewed HERE. - Thepress release can be found HERE.

To address your concern around our inspection report being released; that report was neverprovided to us after inspection by Health Canada. A shareholder filed a Freedom of Informa... SeeMore

Reply ! Like ! May 11 at 10:59am

•



29/31

James Smiley

I guess the bashers dumped 9,000,000 shares in the final hour and caused the pps to decrease11%. Maybe not, insiders are making a nice profit on recently unrestricted shares.

Reply ! Like ! Follow Post ! May 14 at 9:45pm

•

Paulo Pincaro ! Follow ! Top Commenter ! Stock Broker at First Colonial Group

Few problems.

1: you have failed to prove anything he said was false2: if there was an actual valid claim to be made, why would FITX not take any actual legal steps3: people short and make their opinions all the time, just ask Bill Ackman... If we're at a point ofcompletely disregarding first amendment rights, I think we've hit rock bottom. But as I said, thereare many prominent cases of people shorting and making it public. The Soros pound short alsocomes to mind. There is nothing fraudulent about that any more than saying you're going long astock and posting a positive opinion or fact.

To me, it's pretty obvious that instead of actually seeking real answers for why the FITX groundswere never brought up to code in order to be re inspected and licensed, a bunch of naiveinvestors have essentially started looking for th... See More


o


Ok I stand corrected there is a doc against the minister of health...

Reply ! Like ! 1 ! May 8 at 9:34pm

o




30/31

http://finance.yahoo.com/news/creative-edge-nutrition-inc-zoning-172646503.html

The Building was absolutely "up to Code" ZOning and the preinspection.

we would like to release the fact that Health Canada, as a result of their pre-license inspection on July 31, 2014 did state they were satisfied with our facility and were, in their words, "...the

applicant (CEN BioTech Inc.) will be ready and able to meet the requirements of the MMPRprovided the deficiencies addressed during the inspection debrief meeting were addressed...". Weare happy to report to our shareholders that those deficiencies were immediately addressed andask for your continued patience as Health Canada assesses that information given the tremendousworkload they currently have with the vast array of applicants currently before them.

Nice to see you jump on board to Alan.!

Reply ! Like ! 1 ! May 8 at 10:09pm

o


That's one way not to disprove anything I said. And for the record, I think Alan is an idiot (see:growlife). Stop being naive, start accepting the con job. If you were building a company in Canada,would you use the little excess capital you have to buy an apartment in Manhattan? If you caredfor your shareholders, would you make up a story about having purchase orders from GNC andonly PR that it fell through after it got blown up on twitter? This is not a company worth trusting,period. I think it's hilarious people are still even discussing it and haven't moved on. You sayclaims were false but can't point to a single one. What does that tell you?

Reply ! Like

! May 9 at 6:35am

View 2 more

•

Joe Pannu ! Top Commenter ! UC Davis

Its a investment... i dont think any person made money on these stocks other then people thatwere permoting lemons. Im not saying all companies are bad but 99.9% otc is pump and dumpIMHO. IF you loss money in otc (OF THE COUNTER) PLEASE dont blame anyone but youself.




31/31

•

Chris Warner ! Northern Illinois University

FITX is still moving? I thought it was dead. What do thy have going for it now that Health Canadashot it down? Sorry but it looks like all the "bashers" were right about this bs company!

Reply ! Like ! Follow Post ! May 10 at 7:59am

•

Brady Farrell ! Top Commenter ! Phoenix, Arizona

Fantastic way to illustrate the potential criminal behavior by this punk. I warned him a long timeago as did many others, this is the big leagues not a classroom. Oh and Alan please go p*ss onthe CEN property so you will be arrested for trespassing.



finston v christofferson

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