luis alejandro aguilar p. abogado....2012/09/12 · my name is luis alejandro aguilar pardo, 56...

AH & A Services, LLC.

200 Crandon Boulevard, Suite 360, Key Biscayne, Florida 33149, U. S. A.

Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.

Aguilar & Aguilar Limited.

Level 31, Vero Centre, 48 Shortland Street, Auckland 1140, New Zealand.

Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Luis Alejandro Aguilar P.Abogado.

Aguilar & Aguilar, Abogados.407 Av. Francisco de Miranda, Edif. Panalpina, Piso 1, Ofic. 1-1, Los Ruices, Caracas 1071, Venezuela.Tel. +58-212-237.6877 , +58-212-237.8277, +58-212-237.7526. Fax +1-786-228.0559. Mob. +58-414-118.9381

E-Mail : [email protected] or [email protected] or [email protected] (PGP Services Enabled).

Boca Raton, Florida, September 10, 2012.

Mmes. and Messrs.Financial Industry Regulatory AuthorityFINRA Investor Complaint Center9509 Key West AvenueRockville, MD 20850-3329.United States of America.Ph. (301) 590-6500.

In memoriam of Josef Grootkerk Zeldenrust, LuisEnrique Dávila Perez, Luisa Elena Aguilar Pardo,Janusz Korczak and those others who valiantlyhave made a difference for the lives of others.

This is a matter where there is no space for grays.One or several individuals are lying and one orseveral are being truthful.

Via: Federal Express US Air bill 8007 6256 1542.

Re.: Complaint Filing ID 1960837.

Dear Mesdames and Messieurs,

My name is Luis Alejandro Aguilar Pardo, 56 years old, with address at 3801 Bridgewood Drive, BocaRaton, Florida 33434. Ph. 561-251.7697. Email [email protected].

Please use my email address [email protected] as primary means of communications. I authorize the useof electronic messages and electronic transmission of notices, requests and decisions, Other alternativeemail addresses are shown in the letterhead.

I represent Pimjo Trust CV, a limited partnership; most regretably a client of Oppenheimer & Co., Inc.,a New York based brokerage firm.

mailto:[email protected]




mailto:[email protected].


Luis Alejandro Aguilar P., Abogado. 2407 Av. Francisco de Miranda, Edif. Panalpina, Piso 1, Ofic. 1-1, Los Ruices, Caracas 1071, Venezuela.

September 10, 2012. Mmes. and Messrs. Financial Industry Regulatory Authority. FINRAInvestor Complaint Center.

Note be taken that all persons mentioned in this document acting for Oppenheimer & Co., Inc. are1

actual employees of Oppenheimer & Co., Inc. and they are not independent persons or third parties.



Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

I am not allowed to practice law in the United States of America.

Pimjo Trust CV has no legal counsel since all its funds are being withheld by Oppenheimer & Co., Inc.and has no means to pursue its defense.

From information and belief, knowingly, Oppenheimer & Co., Inc. has engaged in the predatory practicesof unexcusably restricting and delaying access to the funds, assets and information of Pimjo Truct CVaccounts in order to conceal its purported illegal actitivies from Pimjo Trust CV, the federal regulatoryagencies of the United States of America, self-regulatory agency of the United States of America, thenational regulatory agencies of Venezuela in banking, securities and foreign exchange control, createdan illegal flow of money unsupervised by the financial intelligence agencies empowered to monitor thelegality of transfers of money.

I filed complaint Filing ID 1960837 on August 7, 2012.

I complained about Oppenheimer & Co., Inc. Caracas Office Branch Manager and Broker John GaylePettus Jaso (CRD # 2415914) and New York Executive Vice-President and General Counsel Dennis1

P. McNamara (CRD # 2938486).

I now include in my complaint Messrs. Albert Grinsfelder Lowenthal, President and CEO (CRD #313519),Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co.,Inc. (CRD # (1060910), and Arthur W. Lewis, Oppenheimer & Co., Inc. Boca Raton, Florida, OfficeBranch Manager and Broker (CRD # (1438899) and the firm Oppenheimer & Co., Inc. (CRD # 249)itself.

I represent Carisma Prima Limited (IRS assigned FEIN 98-0632390), a New Zealand trustee company,who acts as the trustee of the Joseph Trust (IRS assigned FEIN 98-6065855), a trust settled inaccordance with New Zealand law on July 7, 2009, who in turn is the Managing / General Partner of thelimited partnership Pimjo Trust, CV (IRS assigned FEIN 98-1035735), an originally Dutch limitedpartnership created on July 19, 2001 whose Deed of Creation was amended and reinstated on July 9,2009.

The address of Carisma Prima Limited, the Joseph Trust and Pimjo Trust CV is c/o Aguilar & AguilarLimited, Level 31, Vero Centre, 48 Shortland Street, Auckland 1140, New Zealand. Tel.+64-9-363.3391. Fax +64-9-358.7340. Fax +1-786-228.0559.

Please find below a diagram showing the corporate structure of Pimjo Trust CV:





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

[The remaining of this page has been intentionally left in blank]





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Pimjo Trust CV is the account holder of account number A14-0505833-452 at Oppenheimer & Co., Inc.85 Broad Street, New York, NY 10004, USA, (sometimes also referred to as the “Oppenheimer & Co.,Inc.).

Pimjo Trust CV appears as the account holder or account title of a certain undisclosed and secretchecking account at UMB Bank NA, account number 26201338505041, connected with Oppenheimer& Co., Inc.

Please find below an image of check 1004 which evidences the existence of the account.






Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.






Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

THE STRUCURE

Contrary to Oppenheimer & Co., Inc. allegations about the complexity of the corporate structure createdand managed by its own employees, the structure is fairly simple.

Carisma Prima Limited, a New Zealand private trustee has one shareholder named Aguilar & AguilarLimited who holds in trust those shares - today - for the benefit of such entity to be designated as a resultof the successful conclusion of the Plan of Revitalization dated January 17, 2012.

Carisma Prima Limited is the trustee of two trusts namely, the Xavier Trust and the Joseph Trust.

The Xavier Trust is the Limited Partner of a very simple limited partnership named Pimjo Trust CVwhile the Joseph Trust is the Managing / General Partner of Pimjo Trust CV.

The limited partnership of Pimjo Trust CV is governed by the Deed of Creation as Amended andReinstated as of July 9, 2009.

The representation of Pimjo Trust CV may be accomplished by the acts of the Director / ManagingDirector of Carisma Prima LImited as trustee of the Joseph Trust acting as the Managing / GeneralPartner of Pimjo Trust CV or by a duly issued Power of Attorney.

THE COMPLAINT

The complaint filed with your office contains the following 29 statements:

“I handle the hypothesis that Carisma Prima Limited as Trustee ofthe Joseph Trust acting as Managing Partner of the limitedpartnership Pimjo Trust CV might be involuntarily involved in acase dealing with (1) illegal money movements, (2) violations offoreign exchange controls, (3) lack of regulatory compliance andsupervision, (4) actions contemplated as crimes of organizedgroups qualified as organized associations under Ley Organicacontra la Delincuencia Organizada)in Venezuela, (5) failures ofmandatory Anti-money laundering compliance programs and theeffects of reincidence after Oppenheimer & Co., Inc. NYSEHearing Board Panel Decision 05-181 of December 29, 2005,(6)failures of mandatory Anti-money laundering compliance programsand the effects of reincidence after John Gayle Pettus NYSEHearing Board Decision 06-82 of June 27, 2006, (7) transactionsperformed without trading authorization, (8) money movements out





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

of the account without authorization or registered signatory, (9)opening and operating an account 26201338505041 at UMB BankN.A. without authorization and authorized signatory,(10)concealingfrom Compliance officers vital data of the client, (11) violation ofconflict of interests rules and Code of Ethics, (12) intentional lackof KYC and compliance reviews, (13)illegal exercise of businessesin the financial sector in Venezuela without authorization, (14)performing illegal banking activities such as wire transfersexpressly reserved to authorized banks, (15) concealinginformation concerning compliance duties, (16) redirectingclients´s mail to brokers controlled´addresses different fromclient´s address, (17) acting as director of client without havingcleared conflict of interests and providing misleading and falseinformation about it, (18) denial to supply information concerningtransactions done with account 26201338505041 at UMB BankNA, (19) supplying false information about the Final BeneficiaryOwner in W- 8BEN form, (20) filing misleading information toSEC in Form 10-K concerning the nature of their business and theirlocally operated entity in Venezuela, (21) performing actionsagainst Ley Contra Ilícitos Cambiarios in Venezuela, (22) filingmisleading information to SEC about operations in Venezuela andsources of revenues, (23) recognizing and taking possession ofrevenue produced by illegal activities in Venezuela, (24) exertingundue and unjust pressure threatening client´s representative withan interpleader action while blocking access to the account in orderto, finally, cover up weaknesses due to intentional violation of lawsof Venezuela, (26) performing a movement of funds circa February 15, 2012 while the account was allegedly restricted byOppenheimer and there was no authorized signatory (26) avoidanceof income taxes in Venezuela in order to cover up other hypothesismentioned before, (27) avoidance of value added taxes inVenezuela in order to cover up hypothesis mentioned before, (28)failure to recognize authority of client claiming lack ofunderstanding of a "complex multi-national corporate structure"created without authorization by Oppenheimer employees and withthe participation of those employees as directors of the "complexmulti-national corporate structure" until their forced resignation inNovember 2011, (29) possibly filing misleading information informs U4. (30) I handle the hypothesis that the findings mentionedin the NYSE decisions previously mentioned about transactionsthrough wire transfers and intra-Firm journal transfers between





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

unrelated clients "for no apparent economic benefit" might haveinvolved the use of the account 26201338505041 at UMB BankN.A., the client´s account in Oppenheimer & Co., Inc. and that theeconomic benefit might have been illegal foreign exchangetransactions where the other part of the complete transaction wasdone in Bolivars exchanged in Venezuela. I reserve the right to addmore circumstances.”

This complaint does not address the possibilities of violations of the Foreign Corrupt Practices Act ofthe United States of America. However, for information and beief, it is likely that, in order to maintainthe scheme created and operated by Oppenheimer, Co., Inc., the probability of transgressions to ForeignCorrupt Practices Act of the United States of America is larger than zero.

I must start by saying that, since Pimjo Trust CV and its undesigned representative have been victims ofthe concealment and avoidance tactics used by Oppenheimer & Co., Inc., and its agents and since we lackinquisitive powers to find out the truth behind Oppenheimer & Co., Inc.´s behaviors, we only manageeducated hypothesis about what the real status quo should be.

Pimjo Trust CV has found itself involuntarily immersed within this stage of wrongdoings.

1.- Illegal movements of money.

The first allegation presented to your consideration is that , from information and belief, Oppenheimer& Co., Inc., through its secret, illegal, fictive, unregistered and unauthorized branch office located in thecity of Caracas, Venezuela, under the cover of a local company named today “Brisbane, Mendes de1

Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.”, was involved in illegalmovements of money which affected Pimjo Trust CV.

The movements of money are illegal under three different laws, namely: foreign exchange control laws,banking laws and securities laws.

Venezuela has enacted and enforced a foreign exchange control system since February 5, 2003. Duringthe period of 9 years since its inception, the foreign exchange control system has changed in many ways.One element, though, remained always valid: all transactions with foreign exchange in Venezuela hadto be funneled via Banco Central de Venezuela and Comisión de Administración de Divisas (CADIVI) .2 3

Another constant element was that all legitimate transactions with foreign exchange had to be transactedwith Operadores Cambiarios , namely authorized banks and authorized foreign exchange agents except,4

perhaps, for certain transactions known as “barters of securities”.

Several laws or statutes apply to foreign exchange transactions depending on the date when the





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

transaction took place. The following acts were enacted and in force for the given dates:

Name of Act Date Enacted Date Abrogated

Ley de Régimen Cambiario May 17, 1995 September 13, 2005

Ley Contra los IlícitosCambiarios.

September 14, 2005 December 27, 2007


December 28, 2007 February 26, 2008

Ley Contra los IlícitosCambiarios

February 27, 2008 May 16, 2010


May 17, 2010

From the banking laws standpoint, in accordance with Venezuelan law and depending of the date ofapplicability of the several banking laws enacted since 2001, capturing funds within Venezuela andengaged in transfers of funds or wire transfers are considered either typical or connected bankingactivities reserved exclusively to banks, savings and loans associations and other financial institutionsduly authorized to do business in the banking sector.

Banks, savings and loans associations and other financial institutions do need to be registered andauthorized to do business in the financial sector and are subject to the supervision of the administrativeauthorities overseeing the banking industry, namely: former Superintendencia de Banco y OtrasInstituciones Financieras and today Superintendencia de Instituciones del Sector Bancario.

Additionally, wire transfers are subject to reporting requirements with regulatory agencies in order tocooperate with the efforts of financial intelligence agencies around the globe to prevent money-laundering and terrorism financing.

The following acts or statutes were enacted and in force for the given dates:


Ley General de Banco y OtrasInstituciones Financieras

November 13, 2001 July 30, 2008


July 31, 2008 December 22, 2009





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.


December 23, 2009 August 18, 2010


August 19, 2010 December 27, 2010

Ley de Instituciones del SectorBancario

December 28, 2010 March 1, 2011


March 2, 2011

Under the perspective of the securities laws of Venezuela, Brisbane, Mendes De Leon, Pettus yAsociados, representantes de Oppenheimer & Co., Inc. and Oppenheimer & Co., Inc. claim to be“registered financial advisors” in Venezuela and use this fictive character in order to illegally operatein Venezuela. However, Venezuelan securities laws prohibit “registered financial advisors” from sellingor receiving securities and money save for strictly their professional fees when acting as “registeredfinancial advisors”.

The following acts were enacted and in force for the given dates:


Ley de Mercado de Capitales October 22, 1998 August 16, 2010

Ley de Mercado de Valores August 17, 2010 November 4, 2010

Ley de Mercado de Valores November 5, 2010

From information and belief, Oppenheimer & Co., Inc., through its secret, illegal, fictive, unregisteredand unauthorized branch office located in the city of Caracas, Venezuela, under the fictive cover of alocal company named today Brisbane, Mendes De Leon, Pettus y Asociados, representantes deOppenheimer & Co., Inc., knowingly and intentionally engaged illegally in the business of transferringfunds in Venezuela and in foreign currency in exchange for Bolivars and and engaged in the behavior5

of selling unregistered foreign securities in Venezuela operating in the financial market of Venezuela asan unauthorized brokerage house and engaged in activities reserved to authorized banking institutions.

From information and belief, Oppenheimer & Co., Inc., through its secret, illegal, fictive, unregisteredand unauthorized branch office located in the city of Caracas, Venezuela, under the cover of a fake localcompany named today Brisbane, Mendes De Leon, Pettus y Asociados, representantes de Oppenheimer& Co., Inc., - a company that from information and belief is directly or indirectly controlled by





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Oppenheimer & Co., Inc., under the supervision of Oppenheimer & Co., Inc. Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) , New York Executive Vice-President andGeneral Counsel Dennis P. McNamara (CRD # 2938486) and secret, illegal, fictive, unregistered andunauthorized

I now include in my complaint Messrs. Albert Grinsfelder Lowenthal, President and CEO (CRD #313519) since he should have actual knowledge of the mischievous behaviors taken place, New YorkExecutive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) Allen B.Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD #(1060910), Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch BrokerRené F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. (CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD #2415914) and the firm Oppenheimer & Co., Inc. (CRD # 249) itself, who, from information and belief,engaged in several million dollars of non-security/investment transactions through wire transfers andintra-Firm journal transfers between a large number of intra-account journals through both unrelatedcustomer accounts as well as employees’ personal and employee-related accounts, without relevantsecurity transactions that - in the findings of NYSE Heraing Board Panel Decision and Hearing BoardDecision - appeared to have been mae for no apparent economic benefit.

For information and belief, Mr. Arthur W. Lewis, Oppenheimer & Co., Inc. Boca Raton, Florida, OfficeBranch Manager and Broker (CRD # (1438899), having had firstly actual knowledge of the illegalconducts, failed to take corrective actions and subnissively followed instructions from New YorkExecutive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) and Allen B.Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD #(1060910) in order to cooperate in concealing the mischievous behaviors.

These practices were discovered, mentioned and sanctioned in Oppenheimer & Co., Inc. NYSE HearingBoard Panel Decision 05-181 dated December 29, 2005 and in John Pettus. NYSE Hearing BoardDecision 06-82 dated June 27, 2006. Some practices remained in use irrespective of the conclusions ofsuch decisions.

However, from information and belief, contrary to the findings in Oppenheimer & Co., Inc. NYSEHearing Board Panel Decision 05-181 dated December 29, 2005 and in John Pettus. NYSE HearingBoard Decision 06-82 dated June 27, 2006, some or all of these practices might have had an economicbenefit since they were half the cycle of illegal foreign exchange transactions in which Oppenheimer &Co., Inc.´s clients, under the personal direction and participation of Oppenheimer & Co., Inc. (beforeFahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918),Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) “sold” clients funds in U.S. Dollars inexchange for Bolivars.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Indeed, from information and beief,Oppenheimer & Co., Inc. employees debited the “sold” amount ofU.S. Dollars from the account at Oppenheimer & Co., Inc. of the “US Dollar seller-client” and move theU. S. Dollar amount via intra-account journals or wire transfers to “purchaser” of U. S. Dollars (clients,unrelated cients, employees and related employees accounts. Meanwhile, the other end of the transaction- an Oppenheimer & Co., Inc.´s broker, employee, employee related person or totally unrelated person -would hand out to, or deposit in a Venezuelan bank account of the “US Dollar seller-client” the Bolivarsequivalent of the illegal foreign exchange transaction.

From information and belief, t was necessary for their schema to work to have an account where USdollars credits and debits were transacted and to keep the differential benefits.

From information and belief, at least, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) CaracasOffice Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch BrokerRussell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John GaylePettus Jaso (CRD # 2415914) opened and used the undisclosed, unauthorized and secret checkingaccount at UMB Bank NA, account number 26201338505041, somehow connected with Oppenheimer& Co., Inc., to further this illegal line of business.

From information and belief, it was illegal for Oppenheimer & Co., Inc. To provide checking accountfacilities to its clients.

From information and belief, it seems that the true reason that explains Oppenheimer & Co., Inc.´sattitude of concealment and avoidance denying access to the control of the accounts of Pimjo Trust CV -particularly the information about the account at UMB Bank NA - is because of the revelations thatwould arise after auditing the undisclosed, unauthorized and secret checking account at UMB Bank NA,account number 26201338505041.

From information and belief, these transactions evaded controls and proper reporting requirementsregarding movements of funds both in Venezuela and in the United States of America and that theprobability of being contaminated with tainted money is larger than zero.

2.- Violations of foreign exchange controls.

As said before, Venezuela has enacted 5 five statutes dealing with foreign exchange control violationsduring the period 1995 until today.


Ley de Régimen Cambiario May 17, 1995 September 13, 2005





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.


September 14, 2005 December 27, 2007


December 28, 2007 February 26, 2008


February 27, 2008 May 16, 2010


May 17, 2010

From information and belief, from the periods mentioned below, the articles mentioned below of theapplicable statutes then in force were violated by Oppenheimer & Co., Inc. and its agents and employees.

Name of Act Articles Violated or Affected Consequences

Ley de Régimen Cambiario ofMay 17, 1995 until September13, 2005.

3, 6, 9, 13, 14, 18.Imprisonment, fines,confiscation andreimbursements.

Ley Contra los Ilícitos Cambiarios of September 14,2005 until December 27, 2007.

2 (# 3), 3,6, 9,14, Imprisonment, fines,confiscation andreimbursements.

Ley Contra los IlícitosCambiarios of December 28,2007 until February 26, 2008.

2 (#1), 2 (#3), 4, 9, 12, 19, 22 Imprisonment, fines,confiscation andreimbursements.

Ley Contra los IlícitosCambiarios of February 27,2008 until May 16, 2010.


Ley Contra los IlícitosCambiarios of May 17, 2010until today.


3.- Lack of regulatory compliance and supervision

From information and belief,iIt seems that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.)Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker JohnGayle Pettus Jaso (CRD # 2415914) neither reported nor updated the records of Pimjo Trust CV withOppenheimer & Co., Inc.

From information and belief, the aforementioned omissions were adopted knowingly and intentionally.

From information and belief, even though Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.)Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office BranchBroker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker JohnGayle Pettus Jaso (CRD # 2415914) served as directors and managers within Pimjo Organization, itlooks that no compliance review was performed since well before July 19, 2001.

I have observed that some statements of account of Pimjo Trust CV account number A14-0505833-452included a page entitled “Account Verification Profile” aimed to update the records of the client. Theinformation supplied by Oppenheimer & Co., Inc. in those statements of account reflect that Pimjo TrustCV is a “widower”, is a “retired” person; that is a natural person - not a partnership - and reachable atthe phone number “2122376877" (without country code) which is the phone number of Aguilar &Aguilar, Abogados in Caracas, Venezuela (see letterhead of this letter). The “Investments Objectives”and the “Investment Experience”are both unauthorized and invented.

The text of the “Account Verification Profile” reads as follows:

“Oppenheimer, as a registered Broker Dealer, is required tomaintain updated financial information regrading client accountsand to provide clients with certain information on which it isrelying. Please take a moment to review the ‘Account VerificationProfile’ below that reflects information that you provided aboutyour account. In the event that any of the information is incorrector incomplete, please submit any changes, in writing, to the BranchManager named on the profile.”

From information and belief, I presume that these actions were taken deliberately and intentionally -during circa 11 years - since Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas OfficeBranch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M.Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso(CRD # 2415914) managed to deviate all mail and correspondence to a false address avoiding thuscorrective actions by Pimjo Trust CV.

From information and belief, it seems tat, during circa 11 years, the information was deliberativelywrong.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

The possibility that the same behavior occurred in connection with UMB Bank NA, account number26201338505041 is larger tan zero.

From information and belief, I presume that this deliberative concelamnet of information together withthe intentional deviation of mail was aimed to avoid detection of incorrect information such as that PimjoTrust CV was a “retired” “widower” and it may be connected with the method used to extract funds outof the account without having authorization to do so.

From information and belief, Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD# 2415914), was a participant director of the Pimjo Organization, with full knowledge of thecircumstances, perfectly aware of the events which occurred in 2001 by which Oppenheimer & Co., Inc.(before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD #331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas OfficeBranch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) attempted to take ownership ofthe assets of Pimjo Organization without authorization and who deviated all correspondence to "PimjoTrust CV. CCS 82586, P.O.Box 025323, Miami FL 33102, USA".

From information and belief, the address "Pimjo Trust CV. CCS 82586, P.O.Box 025323, Miami FL33102, USA" is the address of a forwarding and consolidating agent who forwards mail to MBEVenezuela CA, Avenida Orinoco entre Calles Muchuchíes y Perijá, Edificio L&M, Pent House, LasMercedes, Baruta, Caracas. Tel. +58-212-992.2120, +58-212-992.6781 y +58-212-991.1277.

From information and belief, correspondence arrived via the scheme of using the scheme of the theMiami address of the forwarding and consolidating agent is not made available to Pimjo Trust CV.

From information and belief, this is a gross violation of anti-money laundering precautions byOppenheimer & Co., Inc. who sems to be aware of the existence of the scheme and, presumably ,assumes the costs incurred to maintain this scheme in place.

NYSE Hearing Board Panel Decision 05-181of December 29, 2005 found this practice irregular in thefollowing terms:

“In addition, despite apparent anomalies, Oppenheimer did notconduct any regular or periodic reviews of accounts that maintainedpost office box addresses. A large number of the accounts forapparently unrelated customers maintained the same home and/orbusiness address, many of which were post office boxes or “care of”accounts in Florida. Several groups of apparently unrelatedcustomers also shared addresses in foreign jurisdictions, includingan offshore financial center.” (p. 8).





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) NYSE HearingBoard Decision 06-82 of June 27, 2006 did not contemplate the abnormality of redirecting mail but it isextremely likely that the arrangements were made by Oppenheimer & Co., Inc. (before Fahnestock &Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas OfficeBranch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager andBroker John Gayle Pettus Jaso (CRD # 2415914).






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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

4.- Actions contemplated as crimes of organized groups qualified as organized associations under LeyOrganica contra la Delincuencia Organizada in Venezuela.

Organic Law Against Organized Crime (Ley Orgánica contra la Delincuencia Organizada) was enactedon October 26, 2005.

Article 2 (1) defines organized crime as the actions or omissions of three or more persons with theintention of carrying out the actions described in the statute.

In accordance with article 16 (4), the activities carried out by Oppenheimer & Co., Inc. and its employeesmay be expressly typified as topologies of organized crimes.

Article 5 states that the sole action of associating with the intention to performed illegal actionsconstitutes a topology of organized crime.

Article 4 defines the crime of money laundering.

Article 5 covers the hypothesis of money laundering caused by imprudence, negligence, inability ortransgressions of the law.

The effects of the statute extends to those who benefit from proceeds obtained from the illegal activitiescontemplated therein. If such is the case, recognized revenue by Oppenheimer & Co., Inc. contributedfrom Oppenheimer & Co., Inc., through its secret, illegal, fictive, unregistered and unauthorized branchoffice located in the city of Caracas, Venezuela, should fall within the topology of the criminal activity.

It is my conjecture that “tainted money” may have made its way through the undisclosed and secretchecking account at UMB Bank NA, account number 26201338505041, connected with Oppenheimer& Co., Inc.

If “tainted money” is at stake, the participation of the Drug Enforcement Administration should berequested to immediately clear this issue.

5.- Failures of mandatory anti-money laundering compliance programs and the effects of reincidenceafter Oppenheimer & Co., Inc. NYSE Hearing Board Panel Decision 05-181 of December 29, 2005.

Oppenheimer & Co., Inc. was found accountable in NYSE Hearing Board Panel Decision 05-181 ofDecember 29, 2005 of failures to follow mandatory Anti-money laundering compliance programs.

From information and belief, in the case of Pimjo Trust CV, the compliance failures were still presentuntil November 2011.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

IFrom information and belief, It seems that the records of Pimjo Trust CV were not updated for circa 11 years.

The opening documentation for the account number A14-0505833-452 at Oppenheimer & Co., Inc. showa vicious circle of conflict of interests and mutual circular approvals among the broker-dealers CaracasOffice Branch .

The opening documentation was signed by Caracas Office Branch Manager and Broker John GaylePettus Jaso (CRD # 2415914) even when the validity and legality of his actions had been challenged andcontested.






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Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

From information and belief,iIt seems that deliberatively no “Know Your Customer” and “Know YourCustomer Clients” reviews were performed during circa 11 years.

From information and belief, it seems that all transfers out of the account were either unsupported byletters from authorized signatories or supported by false letters.

From information and belief, it seems that the information concerning Pimjo Trust CV was deliberatelykept wrong. It seems that the documentation concerning Pimjo Trust CV maintained in the files ofOppenheimer & Co., Inc. was that revoked set of documents produced between July 19, 2001 andNovember 28, 2001. It seems that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) CaracasOffice Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch BrokerRussell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John GaylePettus Jaso (CRD # 2415914) kept using as if valid the power of attorney dated July 19, 2001 whichwas revoked on November 29, 2001.

I do not know the date when the account at UMB Bank NA was opened. However, if opened afterNovember 29, 2001, the documentation used should have been fraudulent. If opened before November29, 2001, it may seem that UMB Bank NA was deliberatively kept misinformed of the correct corporatestructure of Pimjo Trust CV and its lawful representatives.

The possibility that this bizarre behaviors occurred in connection with UMB Bank NA, account number26201338505041 is larger tan zero.

By information and belief, it seems that some letters might have been faked. The following is a letterdated in September 18, 1996 that, even though old, might support undue practices that were still in useeven until 2011. The letter is signed by “Pimjo”. I believe that this practice may have been used up to2011.






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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

One punctuation of suspicion took place on November 2011, when Caracas Office Branch Manager andBroker John Gayle Pettus Jaso (CRD # 2415914) insisted and exerted pressure over me to incorporatemy signature as an authorized signatory in account number A14-0505833-452 at Oppenheimer & Co.,Inc. and to send him by email - without my signature - the information about wire transfers to be madeand told me that he would execute them. This affirmation took place soon after having disclosed to methat no authorized signatories were registered in account number A14-0505833-452 at Oppenheimer &Co., Inc. .

Another punctuation occurred on February 24, 2012 during the meeting held at Oppenheimer & Co., Inc.offices in New York when Allen B. Holeman, Managing Director and Chief Compliance Officer ofOppenheimer & Co., Inc. (CRD # (1060910) expressed apologetically and disingenuously that they werenot aware of any account with UMB Bank NA even though the check presented to them bore the logoof Oppenheimer.

Two inflection points arose during that meeting which are worth mentioning.

Oppenheimer & Co., Inc. New York Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) acknowledged and admitted that no attorney had reviewed the supportingdocumentation prepared and sent by Luis Alejandro Aguilar Pardo to Allen B. Holeman, ManagingDirector and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) while the lattermade believe Luis Alejandro Aguilar Pardo that the delays were due to outside counsels ́ reviews of thedocumentation. It became evident - and I complained bitterly about it - that none of the lawyers presentat that meeting had reviewed the files. So much expression of mediocrity became evident afterExecutive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) promised topersonally review the documentation which he never did. So, they plainly lied.

The second inflection point was that Allen B. Holeman, Managing Director and Chief ComplianceOfficer of Oppenheimer & Co., Inc. (CRD # (1060910) attitude was defensive and apologetic; franklyincoherent with the duties of his office. Instead of procuring certainty and searching for the true facts,he assumed the position of avoidance.

From then on, both Oppenheimer & Co., Inc. New York Executive Vicepresident and General CounselDennis P.McNamara (CRD # 2938486) and Allen B. Holeman, Managing Director and ChiefCompliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) imposed a tactic of delays andavoidances.

Even though truth arrives at a slow pace, it must be pointed out that, as of Februray 9, 2012, had alreadyreceived the letter from the exdirectors Redmond, Alfonzo and Toro. As it will be seen later on below,as of February 24, 2012, both Oppenheimer & Co., Inc. New York Executive Vicepresident and GeneralCounsel Dennis P.McNamara (CRD # 2938486) and Allen B. Holeman, Managing Director and ChiefCompliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) has had in their possession the





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aforementioned letter for 16 days and deliberatively both concealed and lied above its existence.

6.- Failures of mandatory Anti-money laundering compliance programs and the effects of reincidenceafter John Gayle Pettus NYSE Hearing Board Decision 06-82 of June 27, 2006,

From information and belief Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD# 2415914) engaged in the very same activities for which he was penalized for under NYSE HearingBoard Decision 06-82 of June 27, 2006.

From information and belief, the NYSE Hearing Board - who did exercise powers of investigation whichallegedly full jurisdiction upon Caracas Office Branch even when located in a foreign country andsupposedly acting as independently owned local entity, failed to discover that the actions undertaken inthe Caracas Branch Office were orchestrated for the purpose of actively participating in illegal foreignexchange transactions for several million of dollars perhaps and the anti-money laundering violationswere intentionally part of the schema created to effectuate those illegal foreign exchange transactionsamong unrelated persons. The NYSE Hearing Board failed to ascertain that the operation ofOppenheimer & C., Inc. was secret, illegal, fictive, unregistered and unauthorized in clear violations ofthe laws of Repñublica Bolivariana de Venezuela.Perhaps, the possibility that the investigators of theDivision of Enforcement from NYSE were relying on information contained in previously filed Forms10-K filed and the possibility that they were mislead by Oppenheimer & Co., Inc. (before Fahnestock& Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas OfficeBranch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager andBroker John Gayle Pettus Jaso (CRD # 2415914) were larger than zero.

I am afraid that “tainted money” might have traveled across those·transactions and made that pointtransparently and explicitly clear to the Oppenheimer & Co, Inc. directors and employees at the meetingof February 24, 2012. Of course, it is obvious that Oppenheimer & Co., Inc. New York ExecutiveVicepresident and General Counsel Dennis P.McNamara (CRD # 2938486) and Allen B. Holeman,Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) wereperfectly aware of Oppenheimer & Co., Inc. NYSE Hearing Board Panel Decision 05-181 datedDecember 29, 2005 and in John Pettus. NYSE Hearing Board Decision 06-82 dated June 27, 2006.

On May 1, 2012, even under restriction, a wire transfer was attempted to be made under the initiative ofNew York Executive Vicepresident and General Counsel Dennis P.McNamara (CRD # 2938486) toseveral accounts.One of those accounts, for information and belief, was an account of a person whoseems to be deceased since several years ago; perhaps on June 13, 1997.

From information and belief, itseems that the records of Pimjo Trust CV were deliberatively not updatedfor circa 11 years by Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD #2415914) even though he was a director of Carisma Prima Limited and had actual knowledge of thecharacteristics of the corporate structure.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

From information and belief, it seems that all transfers out of the account were either unsupported byletters from authorized signatories or supported by false letters.

The possibility of faking the signatures or using a facsimile with the signature oo an already deceasedperson is larger than zero.

From informationa and belief, it seems that the information concerning Pimjo Trust CV was deliberatelykept wrong. It seems that the documentation concerning Pimjo Trust CV maintained in the files ofOppenheimer & Co., Inc. was that set of documents produced between July 19, 2001 and November 28,2001. It seems that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office BranchBroker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen,Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD# 2415914) kept using as if valid the power of attorney dated July 19, 2001 which was revoked onNovember 29, 2001. Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office BranchBroker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen,Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD# 2415914) signed the Unanimous Resolution of the Partners of Pimjo Trust CV dated November 29,2001.

From information and belief, it seems that some letters authorizing wire transfers might have been fakedby Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914).

Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) participatedactively in the creation of Pimjo Trust CV and was aware of all changes which affected its corporatestructure. He was aware that he lacked the power to represent Pimjo Trust CV. For information andbelief, Oppenheimer & Co., Inc. Did profit for the creation of such entity. For information and belief,Amicorp International Ltd. Used to share revenue via commissions for clients referrals.

7.- Transactions performed without trading authorization.

I am only aware of one valid form issued to F. C. René Méndez de León falsely dated in New York onMay 20, 2002, entitled “Trading Authorization Limited to Purchases and Sales of Securities andCommodities”.

I am not aware of any other trading authorization validly issued before May 20, 2012 and none wasissued after the death of F. C. René Méndez de León. Sch an authorization would have required thesignature of the undersigned and there are no records ofhavinf done so.

Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C.Mendez de León (CRD # 331918) died on December 18, 2006.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

8.- Money movements out of the account without authorization or registered signatory.

There are no records of any document ever granting authority to Oppenheimer & Co., Inc. (beforeFahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918),Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) to extract funds from the account orgranting them signature powers for the accounts.

We fail to understand how extraction of funds was accomplished and what means were used.

9.- Opening and operating an account 26201338505041 at UMB Bank N.A. without authorization andauthorized signatory.

There are no records of ever Pimjo Trust CV having authorized the opening and operation of the account26201338505041 at UMB Bank N.A.

From information and belief, if Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas OfficeBranch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M.Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso(CRD # 2415914) used the documentation created on July 19, 2001 (revoked on November 29, 2001)for the purposes of opening such account, it might be considered a fraudulent act to defraud Pimjo TrustCV, UMB Bank NA and Oppenheimer & Co., Inc.

10.- Concealing from Compliance Officers vital data of the client.

From information and belief, it seems that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.)Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office BranchBroker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker JohnGayle Pettus Jaso (CRD # 2415914) intentionally concealed vital data about Pimjo Trust CV.

Once their powers of attorney were revoked on November 29, 2001,because the death of Caracas OfficeBranch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M.Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso(CRD # 2415914) were unable to represent Pimjo Trust CV and had the duty to report such facts toOppenheimer & Co., Inc.

Furthermore, as directors of Carisma Prima Limited, they were fully aware of all changes and of thecorporate structure to which Pimjo Trust CV belonged.

There is no credible explanation that during circa 11 years Oppenheimer & Co., Inc. (beforeFahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918),





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) failed to report the existing corporatestructure and failed to produce proper documentation for compliance purposes.

During those years, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office BranchBroker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen,Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD# 2415914) managed to violate reporting requirements to the Internal Revenue Service for taxwithholding purposes which endangered Pimjo Trust CV taxwise.

11.- Violation of conflict of interests rules and Code of Ethics.

From information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas OfficeBranch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M.Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso(CRD # 2415914) intentionally concealed from Oppenheimer & Co., Inc. their services as directors ofFundación Pimjo, A.C. and of Carisma Prima Limited.

If they effectively concealed such information and/or filed wrong FINRA UF forms, heir conduct wasa clear violation of section 4. A. of Oppenheimer & Co., Inc. Code of Conduct and Business Ethics forDirectors, Officers and Employees.

From information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas OfficeBranch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M.Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso(CRD # 2415914) intentionally misrepresented to Pimjo Trust CV that they were authorized to serve inthe offices that they accepted.

12.- Intentional lack of KYC and compliance reviews.

From information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas OfficeBranch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M.Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso(CRD # 2415914) intentionally managed to avoid KYC and compliance reviews of Pimjo Trust CV.

It is most disturbing that, having these entities been originally created by Oppenheimer & Co., Inc. andhaving actively participated in their activities, attorneys for Oppenheimer & Co., Inc. claim in their draftof their Interpleader Complaint the following:

“Considering the complex multi-national corporate structure whichflows from the Pimjo Trust, Oppenheimer is unable to determine





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which entity and/or individuals has the authority to instructOppenheimer with regard to the Account.” (Paragraph 26 ofAugust 3, 2012 draft of Interpleader Complaint prepared bySatterlee Stephens Burke & Burke LLP).

13.- Illegal exercise of businesses in the financial sector in Venezuela without authorization.

Section 3. A. of Oppenheimer & Co., Inc. Code of Conduct and Business Ethics for Directors, Officersand Employees reads as follows:

“You must know, respect and comply with all laws, rules, andregulations applicable to the conduct of Oppenheimer's businessesin the areas in which you work. Oppenheimer actively promotescompliance with the laws, rules, and regulations that governOppenheimer's business. Obeying both the letter and spirit of thelaw is one of the foundations of Oppenheimer’s ethical standards.You must follow and obey the laws of all the states and countrieswhere we operate. While you are not expected to be an expert onevery detail of all the laws that govern our business in everyjurisdiction, you are expected to understand the laws andregulations applicable to your duties at Oppenheimer and tounderstand the regulatory environment within which the firmoperates well enough to know when to seek advice from yourManager, or the Legal and Compliance Departments. In additionthere may be instances when you may want to consult adepartment head, or director or executive officer of Oppenheimer(each, a “Senior Officer”).

From information and belief, espite the declarations quoted above, Oppenheimer & Co., Inc.and otherdeclarations contained in stated in Form 10-K filed for the fiscal year ended December 31, 2011 whichare found below, as knowingly and intentionally violated the laws of Venezuela by usurping functionsreserved by law to authorized entities.

Oppenheimer & Co., Inc. arrogated the function to participate without authorization, under cover and insecrecy in the securities sector and in the banking sector of Venezuela against clear rules of Venezuelapublic policy.

This section is devoted to violations of securities laws.

Fronm information and belief, Oppenheimer & Co., Inc. operates in Venezuela as a full service branch





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much in the way as Citibank, NA operates in Venezuela. But with substantial differences. While CitibankNA operates openly, legally and fully authorized and supervised as a registered branch of Citibank, NA,of New York, Umited States of America, Oppenheimer & Co., Inc. does it under the cover of a localentity named “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co.,Inc.”

As it will be seen later below, for information and belief, this is even in contradiction with what wasdisclosed in Form 10-K filed for the fiscal year ended December 31, 2011.

In accordance with Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) and Executive Vice-President andGeneral Counsel Dennis P. McNamara (CRD # 2938486), “Brisbane, Mendes de Leon, Pettus yAsociados, representantes de Oppenheimer & Co., Inc.” is an authorized investment advisor in Venezuelaby Superintendencia Nacional de Valores.

However, for information and belief, the reality is that “Brisbane, Mendes de Leon, Pettus y Asociados,representantes de Oppenheimer & Co., Inc.” is a fictive company used to cover up the activities of a fullservice broker-trader brokerage house offering and dealing with unregistered foreign securities withinthe internal market of Venezuela without authorization, supervision and controls even from Oppenheimer& Co., Inc. itself.

With due respect, from information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.)Caracas Office Branch is a renegade and normally defecting operation out of control and supervisionwhere normally prohibited behaviors seem to be the order of the day.

For information and belief, the main line of business of Oppenheimer & Co., Inc. (before Fahnestock &Co., Inc.) Caracas Office Branch does not constitute trading in Venezuela registered securities withinVenezuela.

From information obtained from Bolsa de Valores de Caracas, it seems that neither Oppenheimer & Co.,Inc., nor Fahnestock & Co., Inc. nor “Brisbane, Mendes de Leon, Pettus y Asociados, representantes deOppenheimer & Co., Inc.” nor Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD# 2415914) are members of the Caracas Stock Exchange.

The current list of members of Bolsa de Valores de Caracas (Caracas Stock Exchange) are:

Banacci Casa de Bolsa, C.A. Valores Vencred Casa de Bolsa, S.A. Valores Occidentales Corporativos, C.A. Activalores Casa de Bolsa S.A. Unitas Valores Sociedad de Corretaje De Valores, C.A.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Mercantil Merinvest, Casa de Bolsa, C.A. Citibank Mercado de Capitales, C.a. (Citimerca) Asesora de Inversion y Casa de Bolsa Merge Capital Casa de Valores, C.a. Cavelba Casa de Bolsa, S.A. Caja Caracas Casa de Bolsa, C.A. Inversiones Dundee C.A. Interbursa Casa de Bolsa, C.A. Financorp Valores Casa de Bolsa, C.A. Fivenca Casa de Bolsa, C.A. Bfc Casa de Bolsa, C.A. Francisco Jose Briceño Bod Valores Casa de Bolsa, C.A. Incorp Casa de Bolsa, S.A. Valcredi Casa de Bolsa, C.A. Provincial Casa de Bolsa, C.A. Victor Julio Flores Rojas Bernard Graham Mario D´alfonso Schaffino Ecoplus Casa de Bolsa, C.A. Mercosur Casa de Bolsa, S.A. Corp Casa de Bolsa, C.A. 3intersec Casa de Bolsa, C.A. Edac Casa de Bolsa, C.A. Luis Alejandro Pulgar Corao Venevalores Casa de Bolsa, C.A. Sofimerca Casa de Bolsa, C.A. Valores Santander Casa de Bolsa, C.A. Maximiza Casa de Bolsa, C.A. Profesional Operador de Bolsa, C.A. Interactivos Servicios Financieros Isf, Casa de Bolsa, C.A. Delsur, Inversiones 11022011, C.A. Miguel Alfredo Calvo Behrens Corinvest Casa de Bolsa, C.A. Intertrust Asesoria Financiera, C.A. Manuel Alberto Alonso Rebareda I.S.C. Invermercado Sociedad de Corretaje, C.A. Aida Devesa Latorre Bencorpcap 20111, C.A. Bt Capital Casa de Bolsa, C.A. Bestinvest Casa de Bolsa C.A. B.n.h. Casa de Bolsa , C.A.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Globalcorp Casa de Bolsa S.A.

From information obtained from Superintendencia Nacional de Valores (National Superintendency ofSecurities) , it seems that neither Oppenheimer & Co., Inc., nor Fahnestock & Co., Inc. nor “Brisbane,Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.” are authorized broker-dealers.

The current list of active broker - dealers registered with Superintendencia Nacional de Valores inVenezuela are:

Abaco Sociedad de Corretaje de Valores, C.A. Actimarket Sociedad de Corretaje de Valores, C.A. Actinvest Sociedad de Corretaje de Títulos Valores, C.A.Activalores Casa de Bolsa, S.A. Banacci Casa de Bolsa, C.A. Bestinvest Casa de Bolsa, C.A.BFC Casa de Bolsa, C.A.BNH Casa de Bolsa, C.A. Bod Valores Casa de Bolsa, C.A. BT Capital Casa de Bolsa, C.A. Caja Caracas Casa de Bolsa, C.A.Capitalfin Sociedad de Corretaje de Títulos Valores, C.A.Citibank Mercado de Capitales, C.A. (Citimerca) Asesora de Inversión y Casa de Bolsa Corinvest Casa de Bolsa, C.A. Corp Casa de Bolsa, C.A. Cuadra y Degwitz Casa de Bolsa, S.A. Ecoplus Casa de Bolsa, C.A.Efincorp, Sociedad de Corretaje de Valores, C.A. Fabesta, Estructuración y Asesoría Financiera Sociedad de Corretaje de Valores, S.A. Financorp Valores Casa de Bolsa, C.A. Fivenca Casa de Bolsa, C.A. GL4 Valores Sociedad de Corretaje, C.A. Global Capital Valores Sociedad de Corretaje, C.A. Global Markets, C. A., Casa de Bolsa Globalcorp Casa de Bolsa, S.A. Incorp Casa de Bolsa, C.A. Interbono Sociedad de Corretaje de Valores, C.A.Interbursa Casa de Bolsa, C.A. Intersec Casa de Bolsa, C.A. Masvalor Sociedad de Corretaje de Valores, S.A.Maximiza Casa de Bolsa, C.A.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Mercantil Merinvest, Casa de Bolsa, C.A. Mercosur Casa de Bolsa, S.A.Pablo Gonzalo Mercado de Capitales, C.A.Palogrande Casa de Bolsa, C.A. Proinversion Sociedad de Corretaje de Titulos Valores, C.A. Provincial Casa de Bolsa, C.A. Ratio Sociedad de Corretaje de Títulos Valores, C.A. Rendivalores Sociedad de Corretaje de Valores, C.A. Sequoian Sociedad de Corretaje de Valores, C.A. Solfin Sociedad de Corretaje de Valores, C.A. Suma Sociedad de Corretaje de Valores, C.A. U21 Casa de Bolsa, C.A. En Liquidación Ver Ficha Unitas Valores Sociedad de Corretaje de Valores, C.A. Valcredi Casa de Bolsa, C.A. Valoralta Sociedad de Corretaje de Títulos Valores, C.A. Valores Santander Casa de Bolsa, C.A. Valores Vencred Casa de Bolsa, C.A. York Servicios Financieros Sociedad de Corretaje de Títulos Valores, C.A. Zafiro Valores Sociedad de Corretaje de Títulos Valores, C.A. Zoom Sociedad de Corretaje de Valores, C.A.

From information and belief obtained from Superintendencia Nacional de Valores , it seems that CaracasOffice Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) is not registered as broker-dealer in Venezuela.

The current list of active broker - dealers individuals registered with Superintendencia Nacional deValores in Venezuela are:

Adaulfo Enrique Jiménez Landaeta Adelso González Socorro Adriana Gutiérrez GallegosAdriana Carolina Díaz Mendez Adriana Josefina Duarte Colina Aída Sofía Devesa Latorre Albert Detlev Schumacher Zibeil Alberto Benshimol Medina Alberto José Lucca Franceshi Alegría Benarroch Mahfoda Alejandro Sandoval Urosa Alejandro Pizzorni Guarnaschelli Alejandro Recio Pinto





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Alejandro Abascal Rodulfo Alejandro Ignacio Cardot Escovar Alejandro José Oliveros Muñoz Alejandro Rafael Betancourt Matos Alfonso Manuel Angrisano Blank Alfredo Adrián Medina Alfredo Enrique Bozo Cohen Alfredo José Larrazábal Delgado Alí Rafael Johnston Romero Altina Mercedes De Sousa De Abreu América Mercedes Yánes Chacón Ana Karina Vásquez Parada Andrea Ramírez Beck Andrés González Clavelli Andrés Antonio Arráiz Santana Andrés José Vicentini Correa Angel Alberto Buenaño González Angel Alberto Peréz Serrano Angel Luis Pico Lagarda Antonio Rojas Segovia Antonio Javier D'elia Smith Antonio Jesús Dálbano Rivero Antonio José Golding Hernández Arelin Virginia Narvaez Duran Armando Delgado Rodríguez Armando Luis Grisanti Capriles Aurelio Laureano Useche Kislinger Bernardo José Pérez Romero Betzaida Thaís Villarroel Escalona Camilo Felipe Manrique Huizi Candelario José Lorbes Velazco Carla Regina Pedrós Rabasso Carlos Alberto Machado López Carlos Alejandro Vera Pérez Carlos Daniel González Bello Carlos Eduardo Maza Anduze Carlos Eduardo Rodríguez Castellvi Carlos Enrique Lippo Laporta Carlos Enrique Quintero Pérez Carlos José Acosta López Carlos José Gregorio Meneses Urdaneta





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Carmelo Brucato Fruscione Carolina Muci Fernández Christian Anthony De Veer Rodríguez Claudio Pecchio Vetencourth Cosme Eduardo Betancourt Quarto Daniel Antero Nuñez Vasquez Daniel Jesús Nuñez Febres Daniel Simón Fermin Giménez David Alberto Rosales Romero Diana Iris Tulipano Martínez Diego Fernández Tinoco Diego Vicente Arnal Vallenilla Diógenes Augusto Sáenz Miranda Dolores María Rodríguez Bento Edda María González Bello Edgar Leonardo Nava Zambrano Eduardo Picón Iturriza Eduardo Alberto Betancourt Frías Eduardo Simón Meinhard Zerpa Eleanor Arcia Jurado Elisa Elvira París Casanova Emilio Antelo Rey Enrique Lerner Rais Enrique Antonio Maimone Leal Enrique Eduardo Rosal González Enrique Javier Zambrano Garriga Ernesto Antonio Hurtado Ubeda Felipe Aguerrevere Ruiz Fernando Giordano Palancares Fernando Araujo Medina Fernando José Mendoza Casanova Fortunato Benacerraf Saias Francisco García Fernández Francisco Arana Sanchez Francisco Fontiveros Francisco Zuñiga Robles Francisco Antonio Cabral Cruz Francisco José Briceño Corrales Freddy Alexis Zambrano Jiménez Freddy Jesús Mijares Aguilar Gabriel Guillermo Salas Ely





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Gerardo José Serra Horobec Germán García Velutini Gerónimo Alfredo Paolini García Gilberto José Varela Román Giorgio Giovanni Milani Fachinelli Gladys Elizabeth García Szuvajcer Graciela Rodríguez Sousa Gregorio Tomassi González Guillermo Benigno Montero González Gustavo Adán Medina Rosales Gustavo Adolfo Martín Betancourt Álvarez Gustavo Alberto Hernández Pérez Gustavo Antonio Lauria Romero Gustavo Antonio Marturet Medina Gustavo José Arenas Gustavo Vladimir Pulido Medina Harry Oswaldo Carvajal Romero Helvio Jorge Sánchez Martínez Hernan José Sorate Orestes Humberto José Ramírez Urdaneta Ibrahim José Velutini Sosa Ildefonso Augusto Gonzalez Aguilar Iván Antonio Márquez Bustamante Jesús Eduardo Herrera Hernández Jesús Nolberto Liendo Algarín Joaquín Emigdio Vera González Jorge Enrique Oquendo Reyes Jorge Luis Martínez Castro José Esayag Tendler José Alfredo González Briceño José Antonio Miguez Fernández José Antonio Oliveros Febres Cordero José De Jesús Salvatierra Quintero José Félix Luzón Melo José Gregorio Tineo Nottaro José Gregorio Rangel Fornez José Gregorio Hernández Hernández José Javier Valera Ventura José Luis Falcón Mendoza José Luis Vethencourt D'elia José Rafael Fernandez Navarrete





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

José Ricardo Velasco Quintero Josepe Zeittouni Juan Andrés Alamo Acedo Juan Andrés Mancera Basalo Juan Carlos Rangel González Juan Carlos Maldonado Bermúdez Juan Carlos Briquet Mármol Juan Domingo Pérez Esclusa Juan Domingo Cordero Marcano Juan Guillermo Otañez Ugueto Julia Beatríz Goncalves Mendes Julio César Pérez Klaus Diethe Moreau Pardo Laura Josefina Pisani Siebert Leonardo Antonio González Matamoros Leonardo Francisco Emperador Márquez Liberato Martucci Díaz Luis Alejandro Pulgar Corao Luis Alfredo Farache Benacerraf Luis Andrés Navarrete Hanza Luis Eduardo Blanco Luis Eduardo Baptista Zuloaga Luis Fernando Doza Villamizar Luís Fernando De Oteyza Pacanins Luis Guillermo Planas Luis Guillermo Degwitz Brillembourg Luis Manuel Bulnes Muñoz Luis María Cuadra Echeverría Luis Miguel Segovia Gonzalez Luisa Elena Vidaurre De Gomez Magaly Rainoa García Manuel Martínez González Manuel Alberto Alonso Rebareda Manuel Angel Suena Cagiao Manuel Eduardo Aranguren Aranguren Manuel Gonzalo Torres Gomez Manuel Ricardo Baquero Méndez Marcelino Abascal Hernández Marco Fulvio Gasperini Gandino María Alexandra Dao Sarquis María Carolina Hernández González





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Maria Milagros Andrade Briceño Marina Del Valle Lugo Peralta De Nava Mario D' Alfonso Schiaffino Mario Alejandro Oliva Otero Mario José Montero Pardo Mario Roberto Simoza Carrasco Marisela Coromoto Villavicencio Mendoza Maybe Madeleyne Quenza Arellano Mercurio Mario Bruno Colledanchise Michel Goguikian Michele Paradiso Miguel Alfredo Calvo Behrens Mónica Acosta Bond Nelson Arenas Nelson Alberto Corrie Soto Nestor Alberto Perez Hernandez Nestor José Noguera Manzanilla Nestor José Fernández García Noel Arturo Manzano Chirinos Nora Esperanza Buenaño Riera Omar Enrique Montesinos Ferrer Omar Enrique Nucete Velandia Orlando Josë Sthory Sosa Oscar Brito Rojas Oscar Rubén Taylhardat García Oswaldo González Sanabria Oswaldo Enrique Rangel Oswaldo José Lairet Rodríguez Pablo Celio Gonzalo Aranda Pablo Emilio Gonzalo Dam Pedro Elías Cárdenas Pélaez Pedro Gustavo Ott Itriago Pedro Miguel Guedez López Pedro Pablo González Peña Rafael Díaz Casanova Rafael Erasmo Osechas Melgarejo Rafael Eugenio Gill Ramirez Rais Meyer Malka Raquel Costoya López Raúl Enrique Maestres Useche Reinaldo Getulio Alvarez Cohén





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Remberto Antonio Uzcátegui De La Cabada Renato Paulino Modernell Guerra Ricardo Mariño Vega Ricardo Martínez Maldonado Ricardo Iv Montilla Osorio Ricardo José Méndez Peña Ricardo José Arapé Rodríguez Ricardo José Larrazabal Vera Rogelio Andrés Cardozo Socorro Ronald Oscar Alemán Bali Ronald Osias Rostoker Hubschman Ronnie Efrén Eidelman Solís Royden Roman Pico Martínez Samuel Levy Duer Saúl Levine Seir Sharim Karina Rubio Sheurich Tomas Fernando Montana Henríquez Tulio Jesús Bracho Méndez Vicente Hernández García Victor Eduardo Gonzalez Velandia Victor Julio Flores Rojas Wendy Del Carmen Izarra Vivas Wilmer Leonel Estrada Ruiz

As it may observed from the following information obtained from Registro Nacional de Valores(National Registry of Securities), the company which seems to be registered and active is namedBrisbane, Mendes de León & Asociados.

The information shows Norman J. Brisbane and Francois Mendes de León as “President”. CaracasOffice Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) has no position or office.Rene F. C. Mendes de Leon died on December 18, 2006. I do not know the whereabouts of Norman J.Brisbane nor if Mr.Brisbane is still registered with any securirites agency within the United States ofAmerica.






Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

From information and belief obtained from Superintendencia Nacional de Valores , it seems that CaracasOffice Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) is not a registeredinvestment advisor.

The current list of active investment advisor individuals registered with Superintendencia Nacional deValores in Venezuela are:

Alonso José Rodríguez Segarra Aída Sofía Devesa Latorre Albert Detlev Schumacher Zibeil Alberto José Cárdenas Hernández Alejandro Recio Pinto Alejandro Gabriel Salcedo Thielen Alexis Andrés Olivares Pulido Alfredo José Puerta Rodríguez Alix Margarita Ortega Aguilera Ana Laura González Gutierrez Andrés Chiodi Enrico Andrés González Clavelli Andrés Antonio Arráiz Santana Angel David Alayon Peña Angel Rafael Rodríguez Grado Apolonia Barbara Marval Navarro Armando Delgado Rodríguez Armando Luis Grisanti Capriles Arnoldo Prieto Domingo Van Bezooyen Piet Astrid Amaranta Arias Ruiz Beatriz Elena Aleman Sánchez Belkis María Reyes Fernández Bernardo José Pérez Romero Candelario José Lorbes Velazco Carlo Cristoforo Lupini D'Aambrosio Carlos Eduardo Rodríguez Castellvi Carmelo Brucato Fruscione Carmen Carolina Henríquez León Daniel Abreu Mendoza Daniel Antonio Lahoud Carrero Daniela Carola Delgado Pérez Daniella Rachadell Contreras David Alberto Rosales Romero David Alejandro Tabernero Quintela





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Diana Iris Tulipano Martínez Diógenes Augusto Sáenz Miranda Eccio Teodoro León Rodríguez Eduardo Picón Iturriza Eduardo Alberto Betancourt Frías Eduardo Alfredo Vale Nieto Edwin Azael Escalona González Eleanor Arcia Jurado Eligio César Peraza Huizi Enrique Lerner Rais Fortunato Benacerraf Saias Francisco José Briceño Corrales Freddy Alexis Zambrano Jiménez Freddy José Fiorillo De Freitas Giampiero Riccio Frojo Gustavo Enrique Morales Briceño Gustavo Alberto Hernández Pérez Henrique Knotschke Larrazabal Ibrahim José Velutini Sosa Irene María Vilagut Vega Isabel Mercedes Pallarés Vivas Jacqueline Kannee De Alibert Jesuardo Eneas Areyán Salazar JesúsTadeo Prato Fontiveros Johny De Jesús Zafra Ramírez José Grasso Vecchio José Oliveras Mesequer José Antonio Sucre Troconis José Esteban Pérez Montenegro José Gonzalo Muci Borjas José Tomás Carrillo Batalla José Antonio Courtois Matos José Antonio Miguez Fernández José Gregorio Tovar José Guillermo De Pool Sánchez José Javier Llanos Mancisidor José Luis Falcón Mendoza José Raul Alegrett Ordoñez José Ricardo Velasco Quintero Josefina Lucía Baronetto Ricupero Juan Muci Muci





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Juan Carlos Escotet Rodríguez Juan Domingo Cordero Marcano Juan Germann Ramírez Barráez Juliet Amalia Amado Katharine Lucía Del Carmen Millán Méndez Klaus Diethe Moreau Pardo Laila Luisa Galvez Bittar Leopoldo Enrique Ferris Wallis Luis Alberto Pérez Lavatelli Luis Alejandro Pulgar Corao Luis Alfredo Farache Benacerraf Luis Carlos Garrido Paulo Manuel Alejandro Dopazo García Manuel Angel Suena Cagiao Manuel Antonio Gutiérrez Núñez Manuel Eduardo Aranguren Aranguren Marcel Ignacio Rodríguez Carvallo Marco Fulvio Gasperini Gandino María Eugenia Picón Carrillo Maria Adriana Nunes María Elvira Novillo Díaz María Inmaculada Carabaño Mele Marina Del Valle Lugo Peralta De Nava Mario Alejandro Oliva Otero Marisabel José Marcano Vasquez Maura Pía Mulas Presi Mauro Francisco Ferraro Perdomo Miguel Alberto García Díaz Mirca Ramona Lara Borges Nelly Parra Hernández Noel Arturo Manzano Chirinos Oly Arlette Ball Ferrero Orocio Eduardo Contasti Arosemena Oswaldo Enrique Rangel Pedro Enrique Penzini López Pedro Gustavo Ott Itriago Ralph Howel Salazar Vilanova Raúl Armando Pérez Mollegas Raymond José Duarte Sandoval Roberto Rodríguez Vázquez Roberto Isasi Vantini





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Rodney Burns James Ronald Osias Rostoker Hubschman Rosa Parada De Carbonell Sabin Ormaza Epalza Saúl Levine Seir Saúl Roger Cuenca Vivas Sebastián Andrían García Simón Chocron Nahon Vicente Dávila Arreaza Victor Julio Flores Rojas Victor Manuel Rafael Silva Ricci Yalitza Josefina Lárez Marán Yanida Cañizales Tancredi

A search of John Gayle Pettus Jaso in Registro Nacional de Valores, shows “John Pettus” as alternatedirector of Inversions Crecepymes, C.A. but the record of Inversions Crecepymes, C.A. shows nineprincipal directors and nine alternate directors none of which is “John Pettus”.

For information and belief, it seems that neither Oppenheimer & Co., Inc., nor Fahnestock & Co., Inc.nor “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.” norCaracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) are members ofthe stock exchange of Caracas, are authorized broker-dealers or registered investment advisors whichdirections the conclusion that their activities ar vilolative of the legislation of República Bolivariana deVenezuela.

Furthermore, Oppenheimer & Co., Inc. stated in Form 10-K filed for the fiscal year ended December 31,2011 the following:

“Through its Private Client Division, Oppenheimer provides acomprehensive array of financial services through a network ofapproximately 1,427 financial advisers in 96 offices locatedthroughout the United States and in two offices in Latin Americathrough locally incorporated and independently owned businesses.”(Page 2). Underlined added.

And also stated in Form 10-K filed for the fiscal year ended December 31, 2011 the following:

“As at December 31, 2011, the Company provided its services from94 offices in 26 states located throughout the United States, officesin Tel Aviv, Israel, Hong Kong, China, and London, England andin two offices in Latin America through local broker-dealers.”





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

(Page 43). Underlined added.

And also stated in Form 10-K filed for the fiscal year ended December 31, 2011 the following:

“Oppenheimer operates as Fahnestock & Co. Inc. in LatinAmerica.” (Page 79). Underlined added.

Concerning “Regulation” , Oppenheimer & Co., Inc. has stated in Form 10-K filed for the fiscal yearended December 31, 2011 the following:

“REGULATION”

“Self-Regulatory Organization Membership – Oppenheimer is amember firm of the following self-regulatory organizations(“SROs”): the Financial Industry Regulatory Authority (“FINRA”),the Intercontinental Exchange, Inc., known as ICE Futures U.S., andthe National Futures Association. In addition, Oppenheimer hassatisfied the requirements of the Municipal Securities RulemakingBoard (“MSRB”) for effecting customer transactions in municipalsecurities. Freedom is a member of FINRA. Oppenheimer EuropeLtd. (formerly called Oppenheimer E.U. Ltd.) is regulated by theFinancial Services Authority in the United Kingdom. OppenheimerIsrael (OPCO) Ltd. is regulated by the Israeli Securities Authority.Oppenheimer Investments Asia Ltd. is regulated by the Securitiesand Futures Commission in Hong Kong. Oppenheimer is also amember of the Securities Industry and Financial MarketsAssociation, a non-profit organization that represents the sharedinterests of participants in the global financial markets. TheCompany has access to a number of regional and national marketsand is required to adhere to their applicable rules and regulations.

“Securities Regulation – The securities industry in the United Statesis subject to extensive regulation under both federal and state laws.The Securities and Exchange Commission (“SEC”) is the Federalagency charged with administration of the Federal securities laws.Much of the regulation of broker-dealers has been delegated toSROs such as FINRA and the National Futures Association. FINRAhas been designated as the primary regulator of Oppenheimer andFreedom with respect to securities and option trading activities andthe National Futures Association has been designated as





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Oppenheimer’s primary regulator with respect to commoditiesactivities. SROs adopt rules (subject to approval by the SEC or theCommodities Futures Trading Commission (“CFTC”), as the casemay be) governing the industry and conduct periodic examinationsof Oppenheimer’s and Freedom’s operations. Securities firms arealso subject to regulation by state securities commissions in thestates in which they do business. Oppenheimer and Freedom areeach registered as a broker-dealer in the 50 states and the District ofColumbia and Puerto Rico.”

“Broker-dealer Regulation – The regulations to which broker-dealersare subject cover all aspects of the securities business, including salesmethods, trade practices among broker-dealers, the use andsafekeeping of customers’ funds and securities, capital structure ofsecurities firms, record keeping and the conduct of directors, officersand employees. The SEC has adopted rules requiring underwriters toensure that municipal securities issuers provide current financialinformation and imposing limitations on political contributions tomunicipal issuers by brokers, dealers and other municipal financeprofessionals. Additional legislation, changes in rules promulgatedby the SEC, the CFTC and by SROs, or changes in the interpretationor enforcement of existing laws and rules may directly affect themethod of operation and profitability of broker dealers. The SEC,SROs (including FINRA) and state securities commissions mayconduct administrative proceedings which can result in censure, fine,issuance of cease and desist orders or suspension or expulsion of abroker-dealer, its officers, or employees. These administrativeproceedings, whether or not resulting in adverse findings, can requiresubstantial expenditures of time and money and can have an adverseimpact on the reputation of a broker-dealer. The principal purpose ofregulating and disciplining broker-dealers is to protect customers andthe securities markets rather than to protect creditors andshareholders.” (Page 10). Underlined added.

Oppenheimer & Co., Inc. has stated in Form 10-K filed for the fiscal year ended December 31, 2011 thefollowing:

The Company runs the risk that employee misconduct could occur.Misconduct by employees could include:• holding securities of third parties;• executing securities trades that fail to settle at the required time





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

due to non-delivery by the counterparty or systems failure byclearing agents, exchanges, clearing houses or other financialintermediaries; and• extending credit to clients through bridge or margin loans or otherarrangements.• employees binding the Company to transactions that exceedauthorized limits or present unacceptable risks to the Company(rogue trading);• employee theft and improper use of Company or client property;• employees conspiring with third parties to defraud the Company;• employees hiding unauthorized or unsuccessful activities from theCompany; or• the improper use of confidential information.” (Page 26).Underlined added.


“To the extent the Company conducts business outside the UnitedStates, it is subject to risks including, without limitation, the riskthat it will be unable to provide effective operational support tothese business activities, the risk of non-compliance with foreignlaws and regulations, the general economic and political conditionsin countries where it conducts business and currency fluctuations.As a result of the Company’s January 2008 acquisition from CIBCWorld Markets Corp., the Company acquired operations in Israel,the United Kingdom, and Hong Kong,China. If the Company isunable to manage these risks relating to its foreign operationseffectively, its reputation and results of operations couldbe harmed. (Page 27)


“To the extent the Company conducts business outside the UnitedStates, it is subject to risks including, without limitation, the riskthat it will be unable to provide effective operational support tothese business activities, the risk of non-compliance with foreignlaws and regulations, the general economic and political conditionsin countries where it conducts business and currency fluctuations.As a result of the Company’s January 2008 acquisition from CIBC





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

World Markets Corp., the Company acquired operations in Israel,the United Kingdom, and Hong Kong,China. If the Company isunable to manage these risks relating to its foreign operationseffectively, its reputation and results of operations could beharmed.” (Page 27). Underlined added.

The question now is: What does it do Oppenheimer & Co., Inc. in Venezuela, providing full services andtrading unregistered foreign securities within the Venezuela internal market, impossibilitated to offerservices and locally registered securities since it is not a member of the Caracas Stock Exchange, not anauthorized broker - dealer, not having employees authorized as broher - dealers, not having a registeredinvestment adviser, with a branch office violating all commercial rules, unauthorized, un registered ,without supervision, inadquatedley staffed and supported and lying to Securities Exchange Commissionconcerning its line of business, local regulatory compliance, and regularity of operations, misleadin aboutthe existence of locally and independently owned entities (not authtoized to be engaged in this line ofbusiness neither in Venezuela nor in the United States of America and run by direct employees ofOppenheimer &v Co., Inc.? The following acts or statutes were enacted and in force for the given dates:


Ley de Mercado de Capitales October 22, 1998 August 16, 2010

Ley de Mercado de Valores August 17, 2010 November 4, 2010

Ley de Mercado de Valores November 5, 2010

For the periods mentioned below, the articles mentioned below of the applicable acts and statutes thenin force were violated.


Ley de Mercado de Capitalesfrom October 22, 1998 until

August 15, 2010

1, 9 (2), 9 (8), 9 (20), 9 (29),21, 68 (4), 68 (5), 68 (6), 70,75, 76, 77, 78, 80, 85, 85, 95

(2), 136 (6), 137 (6), 139, 140.Fines and imprisonment





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Ley de Mercado de Valoresfrom August 17, 2010 untilNovember 4, 2010.

1, 4, 8 (1), 8 (2), 16, 19 (1), 19(3), 19 (4), 19 (5), 20, 21 (2 .nd

paragraph), 22, 27 (2), 49, 50(1), 50 (4), 50 (11), 50 (12), 50(22), 51 (8), 51 (9), 51 (10).

,

Fines and imprisonment

Ley de Mercado de Valoresfrom November 5, 2010 untiltoday.

1, 4, 8 (1), 8 (2), 16, 19 (1), 19(3), 19 (4), 19 (5), 20, 21 (2 .nd

paragraph), 22, 27 (2), 49, 50(1), 50 (4), 50 (11), 50 (12), 50(22), 51 (8), 51 (9), 51 (10).

Fines and imprisonment

14.- Performing illegal banking activities such as wire transfers expressly reserved to authorized banks.

From information and belief, Oppenheimer & Co., Inc. usurped activities in the financial sector of thebanking services industry without authorization and engaged in performing activities of foreign exchangeand transfers of funds which are reserved for the financial institutions governed by Ley General de Bancoy Otras Instituciones Financieras and Ley de Instituciones del Sector Bancario.

From information and belief, these abovementioned activities were engaged knowingly, intentionally andin secrecy obstructing the supervisory duties of international financial agencies. The behaviors placedat risk the national security of the countries involved and violated rules of public policy.

The following acts were enacted and in force for the given dates:



November 13, 2001 July 30, 2008


July 31, 2008 December 22, 2009


December 23, 2009 August 18, 2010


August 19, 2010 December 27, 2010





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.


December 28, 2010 March 1, 2011


March 2, 2011

For the periods mentioned below, the articles mentioned below of the applicable statutes then inforce were violated.


Ley General de Banco y OtrasInstituciones Financieras fromNovember 13, 2001 until July

30, 2008.

2, 3, 4, 11, 18, 25, 29, 30, 32,45, 67, 69, 73, 147, 172, 179,216, 235 (1), 235 (2), 235 (3),235 (12), 235 (13), 235 (21),236, 237, 413 (2), 413 (3),430, 445.

Intervention, suspension ofactivities, occupation ofpremises, seizure of assets,control over assets andactivities, freezing of assets,fines, prohibition to abandonthe country, imprisonment.

Ley General de Banco y OtrasInstituciones Financieras fromJuly 31, 2010 until December22, 2009.

2, 3, 4, 11, 18, 25, 29, 30, 32,45, 67, 69, 73, 147, 172, 179,216, 235 (1), 235 (2), 235 (3),235 (12), 235 (13), 235 (21),236, 237, 413 (2), 413 (3),430, 445.


Ley General de Banco y OtrasInstituciones Financieras fromDecember 23, 2009 untilAugust 18, 2010.

2, 3, 4, 18, 25, 29, 30, 32, 45,67, 69, 73, 147, 172, 179, 216,235 (1), 235 (2), 235 (3), 235(12), 235 (13), 235 (21), 236,237, 360 (2), 360 (3), 377,392.






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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Ley General de Banco y OtrasInstituciones Financieras fromAugust 19, 2010 untilDecember 27, 2010.

2, 3, 4, 18, 25, 29, 30, 32, 45,67, 69, 73, 147, 172, 179, 216,235 (1), 235 (2), 235 (3), 235(12), 235 (13), 235 (21), 236,237, 360 (2), 360 (3), 377,392.


Ley de Instituciones del SectorBancario from December 28,2010 until March 21, 2011.

1, 2, 3, 5, 7, 8, 9, 13, 18, 22,23, 25, 27 (1), 27 (2), 27 (3),28, 53, 67, 73, 101 (4), 151,154, 171 (1), 172 (2), 172 (3),172 (9), 172 (15), 176, 177,186, 211, 223.


Ley de Instituciones del SectorBancario from March 22, 2011until today.

1, 2, 3, 5, 7, 8, 9, 13, 18, 22,23, 25, 27 (1), 27 (2), 27 (3),28, 53, 67, 73, 101 (4), 151,154, 171 (1), 172 (2), 172 (3),172 (9), 172 (15), 176, 177,186, 214, 226.


15.- Concealing information concerning compliance duties.

From information and belief and since Oppenheimer & Co., Inc. conducts its businesses illegally and insecrecy, it has violated the mandatory anti-money laundering regulations in Venezuela enacted by thebanking and securities agencies and has created a parallel flow of money which goes undetected byregulatory agencies in Venezuela empowered of preventing money laundering and terrorism financing.

This illegal flow of money - concealed from authorities - presented a threat to the national security ofVenezuela and of the United States of America.

16.- Redirecting clients´s mail to brokers controlled´addresses different from client´s address.

From information and belief, Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas OfficeBranch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M.Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso(CRD # 2415914) without authorization deviated all correspondence addressed to Pimjo Trust CV tothe false address "Pimjo Trust CV. CCS 82586, P.O.Box 025323, Miami FL 33102, USA".





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

The address "Pimjo Trust CV. CCS 82586, P.O.Box 025323, Miami FL 33102, USA" is a forwardingand consolidating agent who forwards mail to MBE Venezuela CA, Avenida Orinoco entre CallesMuchuchíes y Perijá, Edificio L&M, Pent House, Las Mercedes, Baruta, Caracas. Tel.+58-212-992.2120, +58-212-992.6781 y +58-212-991.1277.

As it may be seen from the several exhibits incorporated herein, Oppenheimer & Co., Inc. has used fakeaddresses, incorrect phone numbers, omitted the Federal Employer Identification Number of Pimjo TrustCV, filed false W-8BEN, portrayed Pimjo Trust CV as a retired widower human being and has refusedto correct this situation even though it has been validly instructed to do so.

From information and belief, Oppenheimer & Co., Inc. and its employees and agents either destroy ordispose of the correspondence and is not delivered to Pimjo Trust CV

17.- Acting as director of client without having cleared conflict of interests and providing misleadingand false information about it.

Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C.Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD #2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914)intentionally concealed from Oppenheimer & Co., Inc. their services as directors of Fundación Pimjo,A.C. and of Carisma Prima Limited.

Their conduct was a clear violation of section 4. A. of Oppenheimer & Co., Inc. Code of Conduct andBusiness Ethics for Directors, Officers and Employees.

Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C.Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD #2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914)intentionally misrepresented to Pimjo Trust CV that they were authorized to serve in the offices that theyaccepted

18.- Denial to supply information concerning transactions done with account 26201338505041 at UMBBank NA.

After having received several requests to supply information concerning transactions funneled throughaccount 26201338505041 at UMB Bank NA, Oppenheimer & Co., Inc. has knowingly lied about theiraccess to such information and has failed to supply the requested information.

It must be said that Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) instructed Allen B. Holeman, Managing Director and Chief Compliance Officer ofOppenheimer & Co., Inc. (CRD # (1060910) to deliver to Luis Alejandro Aguilar Pardo the statements





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

of account number A14-0505833-452 at Oppenheimer & Co., Inc.

Delivery of such statements took place on March 6, 2012 but Executive Vice-President and GeneralCounsel Dennis P. McNamara (CRD # 2938486) and Allen B. Holeman, Managing Director and ChiefCompliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) omitted any information concerningaccount 26201338505041 at UMB Bank NA.

At the time of delivery of the statements of account number A14-0505833-452 at Oppenheimer & Co.,Inc., Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) and AllenB. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD #(1060910) should have been clearly aware of the existence and nature of account 26201338505041 atUMB Bank NA. as it was later explained by Michelle L. Sullivan, Vice President, Director of FiduciaryCompliance, IWM & Corporate Compliance Assessment Team, UMB Financial Corporation816.860.5076 Phone, 816.860.7503 Fax, [email protected], 1010 Grand Boulevard, KansasCity, MO 64106.


mailto:[email protected],





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

19.- Supplying false information about the Final Beneficiary Owner in W- 8BEN form.

Oppenheimer & Co., Inc. managed to supply to the Internal Revenue Service and false misleadinginformation about the tax status of Pimjo Trust CV.

Pimjo Trust CV is unaware of how many, if any, wrong W-8BEN forms have been filed. Wrong filinghave impacts in taxes withheld at source and may endanger Pimjo Trust CV





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

20.- Filing misleading information to SEC in Form 10-K concerning the nature of their business andtheir locally operated entity in Venezuela.

Oppenheimer & Co., Inc. stated in Form 10-K filed for the fiscal year ended December 31, 2011 thefollowing:

“Through its Private Client Division, Oppenheimer provides acomprehensive array of financial services through a network ofapproximately 1,427 financial advisers in 96 offices locatedthroughout the United States and in two offices in Latin Americathrough locally incorporated and independently owned businesses.”(Page 2).

As we have seen before, the locally incorporated and independently owned business in Venezuela is asecret, illegal, fictive, unregistered and unauthorized branch office located in the city of Caracas,Venezuela, under the cover of a local company named today “Brisbane, Mendes de Leon, Pettus y6

Asociados, representantes de Oppenheimer & Co., Inc.” illegally engaged in the line of busines itpurports to be engaged and is far from independent since it is run by employees of Oppenheimer & Co.,Inc.


“As at December 31, 2011, the Company provided its services from94 offices in 26 states located throughout the United States, officesin Tel Aviv, Israel, Hong Kong, China, and London, England andin two offices in Latin America through local broker-dealers.”(Page 43).

As we have seen before, Oppenheimer & Co., Inc. provides full brokerage services and tradingunregistered foreign securities within the Venezuela internal market, impossibilitated to offer servicesand locally registered securities since it is not a member of the Caracas Stock Exchange, not anauthorized broker - dealer, not having employees authorized as broker - dealers, not having a registeredinvestment adviser, with a branch office violating all commercial rules, unauthorized, un registered ,without supervision, inadquatedley staffed and supported and lying to Securities Exchange Commissionconcerning its line of business, local regulatory compliance, and regularity of operations, misleadin aboutthe existence of locally and independently owned entities (not authtoized to be engaged in this line ofbusiness neither in Venezuela nor in the United States of America and run by direct employees ofOppenheimer &v Co., Inc.? Oppenheimer & Co., Inc. stated in Form 10-K filed for the fiscal year ended December 31, 2011 the





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

following:

“Oppenheimer operates as Fahnestock & Co. Inc. in LatinAmerica.” (Page 79).

At least in the case of Venezuela, this statement is false.


“Oppenheimer Europe Ltd. (formerly called Oppenheimer E.U.Ltd.) is authorized by the Financial Services Authority (“FSA”) ofthe United Kingdom to provide investment services under theMarkets of Financial Instruments Directive (“MiFID”). Under itscurrent status, Oppenheimer Europe Ltd.’s capital resourcerequirement is the higher of the base capital resource requirement(€50,000), or the sum of the credit risk capital and the market riskcapital requirements, or the fixed overheads requirement, which isequal to 25% of the firm’s relevant fixed expenditures as definedby the FSA.

On February 12, 2010, Oppenheimer Investments Asia Ltd. wasapproved by the Hong Kong Securities and Futures Commission toplace securities of U.S. listed companies with institutional clientsand to provide corporate finance advisory services to Hong Konginstitutional clients. Oppenheimer Investments Asia Ltd. is requiredto maintain Required Liquid Capital of the greater of HKD$3,000,000 or 5% of Adjusted Liabilities as defined by the HongKong Securities and Futures Financial Resources Rules.

See note 15 to the consolidated financial statements for the yearended December 31, 2011 appearing in Item 8 for furtherinformation on the Company’s regulatory capital requirements.”(Page 13).

The interesting and relevant issue showing from this paragraph is that - while securing governmentalapprovals and authorizations in other countries, no approval or authorization exists in Venezuela tosupport their operations there.

Concerning “Regulation” , Oppenheimer & Co., Inc. stated in Form 10-K filed for the fiscal yearended December 31, 2011 the following:





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

“REGULATION”

“Self-Regulatory Organization Membership – Oppenheimer is amember firm of the following self-regulatory organizations(“SROs”): the Financial Industry Regulatory Authority (“FINRA”),the Intercontinental Exchange, Inc., known as ICE Futures U.S., andthe National Futures Association. In addition, Oppenheimer hassatisfied the requirements of the Municipal Securities RulemakingBoard (“MSRB”) for effecting customer transactions in municipalsecurities. Freedom is a member of FINRA. Oppenheimer EuropeLtd. (formerly called Oppenheimer E.U. Ltd.) is regulated by theFinancial Services Authority in the United Kingdom. OppenheimerIsrael (OPCO) Ltd. is regulated by the Israeli Securities Authority.Oppenheimer Investments Asia Ltd. is regulated by the Securitiesand Futures Commission in Hong Kong. Oppenheimer is also amember of the Securities Industry and Financial MarketsAssociation, a non-profit organization that represents the sharedinterests of participants in the global financial markets. TheCompany has access to a number of regional and national marketsand is required to adhere to their applicable rules and regulations.

“Securities Regulation – The securities industry in the United Statesis subject to extensive regulation under both federal and state laws.The Securities and Exchange Commission (“SEC”) is the Federalagency charged with administration of the Federal securities laws.Much of the regulation of broker-dealers has been delegated toSROs such as FINRA and the National Futures Association. FINRAhas been designated as the primary regulator of Oppenheimer andFreedom with respect to securities and option trading activities andthe National Futures Association has been designated asOppenheimer’s primary regulator with respect to commoditiesactivities. SROs adopt rules (subject to approval by the SEC or theCommodities Futures Trading Commission (“CFTC”), as the casemay be) governing the industry and conduct periodic examinationsof Oppenheimer’s and Freedom’s operations. Securities firms arealso subject to regulation by state securities commissions in thestates in which they do business. Oppenheimer and Freedom areeach registered as a broker-dealer in the 50 states and the District ofColumbia and Puerto Rico.”





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

“Broker-dealer Regulation – The regulations to which broker-dealersare subject cover all aspects of the securities business, including salesmethods, trade practices among broker-dealers, the use andsafekeeping of customers’ funds and securities, capital structure ofsecurities firms, record keeping and the conduct of directors, officersand employees. The SEC has adopted rules requiring underwriters toensure that municipal securities issuers provide current financialinformation and imposing limitations on political contributions tomunicipal issuers by brokers, dealers and other municipal financeprofessionals. Additional legislation, changes in rules promulgatedby the SEC, the CFTC and by SROs, or changes in the interpretationor enforcement of existing laws and rules may directly affect themethod of operation and profitability of broker dealers. The SEC,SROs (including FINRA) and state securities commissions mayconduct administrative proceedings which can result in censure, fine,issuance of cease and desist orders or suspension or expulsion of abroker-dealer, its officers, or employees. These administrativeproceedings, whether or not resulting in adverse findings, can requiresubstantial expenditures of time and money and can have an adverseimpact on the reputation of a broker-dealer. The principal purpose ofregulating and disciplining broker-dealers is to protect customers andthe securities markets rather than to protect creditors andshareholders.” (Page 10).

Again, while affirming adoption of rules and regulations, compliance methods and businessprocedures, the secret Caracas Office Branch is a rogue operation involved in illegal activities.


The Company runs the risk that employee misconduct could occur.Misconduct by employees could include:• holding securities of third parties;• executing securities trades that fail to settle at the required timedue to non-delivery by the counterparty or systems failure byclearing agents, exchanges, clearing houses or other financialintermediaries; and• extending credit to clients through bridge or margin loans or otherarrangements.• employees binding the Company to transactions that exceedauthorized limits or present unacceptable risks to the Company





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

(rogue trading);• employee theft and improper use of Company or client property;• employees conspiring with third parties to defraud the Company;• employees hiding unauthorized or unsuccessful activities from theCompany; or• the improper use of confidential information.” (Page 26).

“To the extent the Company conducts business outside the UnitedStates, it is subject to risks including, without limitation, the riskthat it will be unable to provide effective operational support tothese business activities, the risk of non-compliance with foreignlaws and regulations, the general economic and political conditionsin countries where it conducts business and currency fluctuations.As a result of the Company’s January 2008 acquisition from CIBCWorld Markets Corp., the Company acquired operations in Israel,the United Kingdom, and Hong Kong, China. If the Company isunable to manage these risks relating to its foreign operationseffectively, its reputation and results of operations could beharmed.” (Page 27).

The part missing in this statement is that the Directors and Executive Officers made the intentionaldecision of running an operation in Venezuela knowingly despising compliance with foreign lawsand regulations.

We respectfully challenge the statement that the Caracas Branch Office operated by Oppenheimer & Co.,Inc. is or may be considered as an independently owned business and that the services provided are sothrough a locally incorporated entity.

“Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co., Inc.” looks likea fictive or fictitious company being used as a facade to cover up the activities of a full service branchof Oppenheimer & Co., Inc. offering services illegally within Venezuela.

In order for the statements to be accurate, “Brisbane, Mendes de Leon, Pettus y Asociados, representantesde Oppenheimer & Co., Inc.” should be the one offering the services of Full-Service Brokerage, WealthPlanning, Margin Lending, Securities Lending, Discount Brokerage, Separate Managed Accounts, OtherManaged Accounts, Investment Advisory Services, Discretionary Portfolio Management, Free-BasedNon-Discretionary Accounts, Institutional Investment Management, Alternative Investments, InvestmentBanking, Financial Advisory, Equities Underwriting, Debt Underwriting, International Equity Sales andTrading, Equity Research, Equity Options and Derivatives, Convertible Bonds, Event Driven andTrading, Fixed Income - High Yield & Secutirized, Fixed Income Research, Public Finance, MunicipalTrading, Equities, Fixed Income, and Proprietary Trading and Investments Activities.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

If such was the case, entity rendering the services would be “Brisbane, Mendes de Leon, Pettus yAsociados, representantes de Oppenheimer & Co., Inc.” and this entity is not a brokerage house nor abroker-dealer.

A review of “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co.,Inc.” Venezuela income tax returns and value added tax returns will surely indicate that no income isrecognized by “Brisbane, Mendes de Leon, Pettus y Asociados, representantes de Oppenheimer & Co.,Inc.” and that no value added taxes are declared in Venezuela for the transactions performed inVenezuela.

Additionally, if the 10-K from statements were true, the only way for “Brisbane, Mendes de Leon, Pettusy Asociados, representantes de Oppenheimer & Co., Inc.” of contributing to the revenue of Oppenheimer& Co., Inc. would require purchase of foreign exchange in order to transfer income earned in Venezuelato Oppenheimer & Co., Inc. via profit sharing agreements which seem not to be the case. Few companieshave ever received foreign exchange proceeds at preferential exchange rates to contribute to foreignprofit sharing agreements.

The truth of the matter is that all transactions - save the illegal foreign exchange line of business - areperformed by Oppenheimer & Co., Inc., using its qualifications as brokerage house, using its platformof licenses and technological systems and offering its products as offered within the United States ofAmerica.

It is my belief that the statements contained in Form 10-K are false, misleading and seriously undermineOppenheimer & Co., Inc.´s credibility.

A word of caution should be said regarding the existence in Venezuela of a “permanent establishment”for purposes of income taxes and, perhaps, the possibility of income tax evasion in Venezuela for incomeearned by the “permanent establishment”.

What seems to be more likely is the statement that Oppenheimer & Co., Inc. is operating in secrecy andillegally in Venezuela, violating securities, banking, tax and foreign exchange laws with impunity andthat it is concealing those facts from the regulatory authorities in Venezuela and in the United States ofAmerica.

21.- Performing actions against Ley Contra Ilícitos Cambiarios in Venezuela.

Oppenheimer & Co., Inc. engaged in selling non registered foreign securities in Venezuela within theinternal market and in foreign currency violated the prohibition set forth in Ley Contra IlícitosCambiarios in Venezuela.

22.- Filing misleading information to SEC about operations in Venezuela and sources of revenues.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Oppenheimer & Co., Inc. filed misleading information with the SEC about the nature of its operationsin Venezuela - one of the two branch offices located in Latin America - and presented as legal thoserevenues contributed by the operations of its branch office located in Venezuela.

23.- Recognizing and taking possession of revenue produced by illegal activities in Venezuela.

Oppenheimer & Co., Inc. recognized as legitimate revenue proceeds obtained from illegal activities andin so doing became a cooperator at the moment it took possession of proceeds obtained from illegalactivities.

24.- Exerting undue and unjust pressure threathening client´s representative with an interpleaderaction while blocking access to the account in order to, finally, cover up weaknesses due tointentional violation of laws of Venezuela.

Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) has illegally andunjustly restricted the account. Oppenheimer & Co., Inc. asserts that “...is currently restricting theAccount and has not made any transfers or allowed any withdrawals from the Account since this disputearose in February 2012.”

In reality, this is nothing more than a posture in order to cover up its weaknesses due to most disturbingregulatory transgressions by Oppenheimer & Co., Inc.

The truth behind this posture is that Oppenheimer & Co., Inc. - most conveniently - changed its strategyof delays and avoidances since Luis Alejandro Aguilar Pardo confronted them and exposed its liesconcerning the true about the account 26201338505041 at UMB Bank NA.

On March 13, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) an email to me wrote which read as follows:

“Mr. Aguilar:

I apologize that you have called so often without my being available.We are in the process of checking how far our statements for theaccount(s) go back. The account is restricted so no assets can beremoved from the account. We are trying to complete the review ofany questions we may have on the structure. You should be aware that I have [received] correspondence fromMr. Redmond expressing concern about our ceding control of theaccount to you. I have told him that he needs to considerrecognizing you as having control of the account, working out an





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amicable resolution amongst you and the other directors (or formerdirectors) or be prepared to take legal action. I have not heard backfrom him as of today. I hope to be in a position to send you our final open items todaywhen I know more about the statements.”

It is most obvious that Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) was lying since the statements of the account number A14-0505833-452 at Oppenheimer &Co., Inc. dating back to circa year 2000 had already been delivered to Luis Alejandro Aguilar Pardo onMarch 6, 2012.

It is also interesting to note that I became more suspicious since Executive Vice-President and GeneralCounsel Dennis P. McNamara (CRD # 2938486) used the term “account(s)” and continued avoidingrecognition that this corporate structure was created originally by their employees Oppenheimer & Co.,Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD# 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas OfficeBranch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) participated actively in theseentities and did intentionally conceal the vital information to Oppenheimer & Co., Inc.

But if we look the events from a time line, the truth is that Executive Vice-President and GeneralCounsel Dennis P. McNamara (CRD # 2938486) disclosed the existence of the letter received from theexdirectors 34 days late(from February 9, 2012 until March 13, 2012). At the time of my meeting withOppenheimer & Co., Inc. Directors at its former location at 125 Broad Street, Executive Vice-Presidentand General Counsel Dennis P. McNamara (CRD # 2938486) had already had had in his hands the letterdated February 9, 2012 sent by the exdirectors for 16 days. Such concealment took place even after myraising the issue that I was unable to speak freely due to confidentiality issues in accordance withVenezuelan law

Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) not onlyconcealed the existence of the letter dated February 9, 2012 but has never disclosed its terms eventhough he knew it contained derogatory terms and accusations which would have freed me from myduties of confidentiality but obstaculizing the initiation of mandatory mediation and arbitrationproceedings that might have solved this problem swiftly and efficiently.

It is my belief that Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) orchestrated and manipulated the parties in order to conceal Oppenheimer & Co., Inc.unbecoming conducts and the Pandora Box that might escape from an audit of the Pimjo Trust CVaccounts both at Oppenheimer & Co., Inc. and at UMB Bank NA.

Contrary to Oppenheimer & Co., Inc. biased assertions, the letter sent by the exdirectors on February 9,





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2012 to Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486)purportedly requests moral and legal explanations of the actions “recently” taken by Luis AlejandroAguilar Pardo.

Such letter, purportedly, does not challenge the office and authority of Luis Alejandro Aguilar Pardo norhis powers to take control of the account.

It seems that the letter expressly states that the protesting exdirectors are uncapable, incapacitated,unable, powerless, ignorant as to how to discern how they became directors and how they may becomedirectors and it seems that spontaneously confess that the protesting exdirectors consider themselves asceased directors. This is the first of several spontaneous and unsolicited confessions admitting their lackof capacity to represent Pimjo Trust CV.

Obviously, Oppenheimer & Co., Inc. is not an ADR center and it does not exist to teach negligentexdirectors what to do having failed with their most elementary duties as directors of any entity, eventhough Luis Alejandro Aguilar Pardo explained to them their duties and obligations as directors basedupond the new trends and standards established after the Sarnaes -Oxley Act and based upon the contentsof “The Role of Independent Directors After Sarbanes-Oxley”. Bruce F. Dravis. 2006. ABA Section ofBusiness Law and “Guidebook for Directors of Nonprofit Corporations”. 2nd Ed. Committee onNonprofit Corporation. 2002. ABA Section of Business Law.

No wonder the dissenting exdirectors ignored the explanations once it is observed that their characterimpulses them toward unbecoming actions incompatible with the abovementioned standards and trendsof diligence required from any director not because being expressed in the laws of the United States ofAmerica but because have global validity, justification and applicability.

The letter of the protesting exdirectors contains astonishing shadows for mature persons. One is thatclaim in their favor their own negligence, another is that provide no single proof and the third one is thatassume the role of the victimized.

However, behind the fallacy of self-pitty lies the truth that the wrongdoing is not to cease corruptdirectors. The regrettable behaviors are having felt prey of achieving solutions by using unbecomingmeans. The cessation of the protesting exdirectors is just one of the remedies and one of the adverseconsequences facing those who caught and find themeselves in processes aimed to redress the infringedlegal situation created by their defecting actions.

Having so much power within the privileged and money at their personal accounts, it is unexplainablenot having placed in motion the ADR rules governing conflict resolution within Pimjo Trust CV to mendLuis Alejandro Aguilar Pardo alledged wrongdoins and evil intentions but they have not stoped yetrunning from all the requests and demands made to attend mandatory mediation and to submitt anyunresolved issues to arbitration.





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It must be pointed out that Executive Vice-President and General Counsel Dennis P. McNamara (CRD# 2938486) failed to disclose, when requested, whether or not he had received contrary instructions fromRedmond, Toro and Alfonzo and has failed to do so all through out this period of time.

Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) failed todisclose to Luis Alejandro Aguilar Pardo the existence of derogatory language against hin in the letterdated February 9, 2012 and failed to indicate to the protesting exdirectors the only path available to themto solve their ignorance, lack of documentation and protests against Luis Alejandro Aguilar Pardo whichare clearly exposed in the Deed of Creation of Pimjo Trust CV dated as of July 9, 2009 which states:

“31. The partners understand that conflicts may and will arise.The partners agree to honor conflicts as means of progress, learningand evolution.32. The partners agree to use their very best efforts to handleand manage any potential conflicts in an exemplary, cooperative,interest - oriented, elegant and fair manner applying their higheststandards of diligence, expertise and truthfulness in order tomasterly solve such potential conflicts and to make thoseproceedings and decissions good examples and sound precedents forall persons involved or who may get in contact with the partnership.33. The partners agree that they will protect the partnership, itsgoals and assets, no matter the results of any controversy in whichanyone of them may eventually participate.34. The partners agree that they will not withdraw from thepartnership or any existing entities or businesses downstream or inany way affect the partnership solely because a conflict orcontroversy is solved in terms adverse to their interests.35. The partners agree not to withdraw precipitously and/orhasty from the partnership or any existing entities or businessesdownstream or in any way affect the partnership solely because aconflict or controversy is solved in terms adverse to their interests.36. The partners agree to solve all conflicts in propria persona(in one's own person).37. The partners agree that mediation and successive arbitrationare the only valid and acceptable tools to solve a conflict between:a. the partnership with any person, orb. any member or partner with any person, or director orofficer or body or employee or any third party, orc. any director or manager with any of the persons or entitiesmentioned before, or d. any officer with any of the persons or entities mentioned





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before, or e. any body of the partnership with any of the persons orentities mentioned above, orf. any employee with any of the persons or entities mentionedbefore, org. any third party with any of the persons or entities mentionedbefore.38. The partners agree that the persons and entities mentionedabove have legitimate interests in the conflicts being solved bymediation and/or arbitration and that they may participate in thoseproceedings if the mediator or arbitrator accepts such intervention.39. The partners agree not to submit any controversy, conflict,motion, demand, appeal, request for interpretation or action to anycourt of any jurisdiction, state or country except for obtainingcompulsory compliance of the decissions and or injunctions - finalor temporary - properly adopted.40. The partners agree that, in case of conflicts, they will submitthe terms of the controversy to one or several mediators orconciliators.41. The partners agree that mediation or conciliation is themandatory, exclusive, foremost and initial tool to solvecontroversies42. The partners agree to choose the mediators among thosegood and honest persons publicly recognized for their wisdom andcommon sense. Mediators must be perfectly fluent in Spanish.43. All other factors being equal, the partners shall prefernon-lawyers to serve as mediators.44. The partners agree that they will attend in person, physicallypresent, and that they will initiate, participate and terminate inperson all potential mediation proceedings. 45. The partners agree that all mediation proceedings will lastno less than 80 hours. One hour is such in which the parties and themediators are physically or electronically present simultaneously insession.46. No other proceedings may be initiated until the mediationproceedings have properly ended unless emergency relief is soughtin which case any party - including the mediator - shall be entitledto initiate arbitration proceedings for that purpose.47. The mediator is free to set the rules and proceduresgoverning the mediation as (s)he seems fit provided however that:a. Nothing said or discussed with the mediator in private is to





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be disclosed to others without the prior consent of the interestedparty.b. Nothing said or discussed in brainstorming or "what if"sessions during the mediation may be used as evidence in otherproceedings.48. The partners agree to settle any unsolvable conflict foundedin contractual, extra contractual, tort, statutory or common law byindividual binding arbitration presided by one single arbitrator withsimilar characteristics as those mentioned supra.49. No controversy or subject matter shall be considered ultravires (beyond the powers) for the arbitrator.50. The arbitration shall be conducted in Spanish.51. The arbitration shall be conducted in the city of Caracas,Venezuela or such other place as the partners may agree.52. The arbitrator shall be appointed by the parties in conflict.53. If the parties do not appoint an arbitrator within 5 days, thearbitrator shall be appointed following the then prevailing (or lastknown) rules of the Centro Empresarial de Conciliación y Arbitrajeof the Cámara Venezolano-Americana de Industria y Comercio.54. The paramount rule of substantive and procedural (lexarbitri) laws governing the arbitration is that the conflict is to besolved, and the arbitration is to be governed, "ex aequo et bono"(according to the right and good or from equity and conscience),applying exclusively equity and disregarding any technicalitiesand/or formalisms. Thus, the partners agree to grant the arbitratorthe powers to dispense with consideration of the law and considersolely what (s)he considers to be fair and equitable in the case athand.55. The arbitrator shall set aside all formal arguments and shallfocus on the material and substantial aspects of the conflict and onthe legitimate interests of all parties involved.56. The arbitrator shall apply such law(s) as (s)he deemsapplicable to the substance of the conflict57. The arbitrator is free to base remedies on sound principlesof lex ferenda (the law as it ought to be).58. The arbitrator is not bound to apply any rules regardingstatute of limitations if such rules in her/his opinion are conduciveto unfair solutions or may constitute an undesirable precedent for thewell-being of the partnership. The procedural rules of the arbitration(lex arbitri) shall be established by the arbitrator.59. The arbitrator may decide suo motu (upon one's own





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initiative) that all proceedings be kept sub rosa (privately orconfidentially).60. The arbitrator is empowered ex officio (by virtue of theoffice or position one holds) to issue injunctions and temporaryorders from the very same moment in which (s)he accepts the officeof arbitrator.61. The arbitrator is empowered to solve any issues and to applysuch temporary remedies as necessary or convenient in order tosuccessfully proceed with the arbitration until the end even againstthe will of one or of several (but not all) of the parties.62. The arbitrator shall grant such relief as necessary in orderto place the parties in conflict in the position of attending thearbitration free from pressures and duress. It is the fundamental dutyof the arbitrator to equalize the leverage of each party in order tosecure that no party is precluded from exercising and/or seekingand/or obtaining effectively justice in equity because of the adverseconsequences borne because of the passage of time or because ofdifferences in monetary resources and/or because the overwhelmingspending, usage, or attempts to deplete one party, of monetaryresources.63. The arbitrator is free to accept the intervention of a thirdparty as amicus curiae (a third party allowed to argue in a court) andto determine the extent of such intervention64. The arbitrator is free to attribute value to the evidencepresented, to shift the burden of proof, to request further evidences,to make inquiries and to consider proven in conscience one orseveral facts if (s)he considers it necessary or convenient for thesolution of the conflict.65. The arbitrator is bound to explain to the parties in disputethe ratio decidendi (reasoning of the decision) during a sessionspecifically convened for that purpose. The complete ratio decidendimust be explained, at least, verbally to the parties. The arbitratormay decide to restrict the access of any other person to the sessionin order to preserve the well being and reputation of any party orperson.66. The arbitrator is bound to issue the arbitration award inwriting. The arbitration award must include the decission of thearbitrator. The arbitrator may suppress from the arbitration awardthose issues, facts, evidences, allegations or events that may bedetrimental to the well being and reputation of any party or person.67. Any remedy, if one exists, has to correspond and be applied





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in proportion to the damage(s) suffered.68. No extra domus (removal of a person from a group)remedies may be imposed.69. The arbitration award is final and not subject to appeal orfurther revision.70. The partners irrevocably agree to waive the rights to trial byjury for any matters not submitted to arbitration in respect to anylitigation based in, connected or related with the partnership in anyjurisdiction.”

It is clear and transparent that the proper path to be followed by the protesting directors is clearly andfairly designed within the Deed of Creation of Pimjo Trust CV.

One particular governing principle of Pimjo Trust CV being violated by Oppenheimer & Co., Inc. in itsexercise of unjust pressure is the following :

“62. The arbitrator shall grant such relief as necessary in orderto place the parties in conflict in the position of attending thearbitration free from pressures and duress. It is the fundamental dutyof the arbitrator to equalize the leverage of each party in order tosecure that no party is precluded from exercising and/or seekingand/or obtaining effectively justice in equity because of the adverseconsequences borne because of the passage of time or because ofdifferences in monetary resources and/or because the overwhelmingspending, usage, or attempts to deplete one party, of monetaryresources.”

As long as Oppenheimer & Co., Inc.is restricting the Pimjo Trust CV account at Oppenheimer & Co.,Inc. and delays without excuse the normal proceedings obstaculizing the solution alleging perpetuallythat it has cause tofile an Interpleader Complaint and doing nothing, the truth of the matter is that thefunds are at risk and being managed or mismanaged by those who are most reposnsible for the causesof their lack of knowledge.

It is my belief that Oppenheimer & Co., Inc. is creating a framework of pressures and duress in order topreclude Pimjo Trust CV from exercising and/or seeking and/or obtaining effectively justice creating asituation where the cost of enforcement surpasses the capabilities of Pimjo Trust CV and of itsrepresentatives.

On March 23, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) wrote to Luis Alejandro Aguilar Pardo the following:





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“Mr. Aguilar: This matter will be resolved next week. I have given Mr. Redmonduntil early next week to respond to me. I appreciate your patienceand again apologize for the length of time this review has taken.”

One point should be highlighted and it is Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) failed to analyze the situation correctly. Luis Alejandro Aguilar Pardo wasappointed as per clause 17.1 of the Constitution of Carisma Prima Limited. The protesting exdirectorswere appointed in accordance with clause 17.2 ejusdem and the protesting exdirectors were removed bythe same shareholders who appointed them in accordance with clause 17.5 ejusdem.

In the particular case of Director and Managing Director Luis Alejandro Aguilar Pardo, the shareholders,since January 17, 2012 and, after that date, at every meeting of shareholders, have ratified, convalidated,extended and continued without interruption and limitations in time and in space since the creation ofCarisma Prima Limited Mr Luis Alejandro Aguilar Pardo as Director and the sole Managing Directorof Carisma Prima Limited entrusting upon him all of the powers exercisable by the Board of Directorsto be exercised by the Managing Director as he may think fit without terms, restrictions or conditions.

Indeed, General Counsel should have read the Constitution of Carisma Prima Limited rules governingappointment and removal of directors:

“7 APPOINTMENT AND REMOVAL OF DIRECTORS

First Directors

17.1 A person named as a director in the application forregistration of the company [namely, Luis Alejandro Aguilar Pardo]g the company holds office as a director from the date of registrationor the date the amalgamation proposal is effective, as the case maybe, until that person ceases to hold office as a director in accordancewith the Act or this constitution [§153(1)].

Subsequent Directors

17.2 Subsequent directors of the company must be appointed byordinary resolution [§153(2)].

17.3 Two or more directors may be appointed by a singleresolution[§155(1)].





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Consent Required

17.4 A person must not be appointed a director of the companyunless he or she has consented in writing to be a director andcertified that he or she is not disqualified from being appointed orholding office as a director of the company [§152].

Removal

17.5 A director of the company may be removed from office byordinary resolution passed at a meeting called for the purpose or forpurposes that include the removal of the director [§156(1)].

17.6 The notice of meeting must state that the purpose or apurpose of the meeting is the removal of the director [§156(2)].”

The time intervals of the persons serving as directors of Carisma Prima Limited are shown below:





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It is important to make two remarks: the first one is that from nformation and belief, none of theexdirectors have challenged my being the actual Director and Managing Director of Carisma PrimaLimited. The outburst of the exdirectors is that they wish to control the shares of Carisma Prima Limitedand appoint themselves as shareholders of Carisma Prima Limited. The second remark is that during 955days in office as directors of Carisma Prima Limited the exdirectors now confess their gross negligence,and attempt now to base their sheding tears because of sadness, rage, pain or, a sudden need of fundsfrustrated. Being defeated thrice in one's attempts to defraud others is sometimes cause ofdissappointment.

On April 15, 2012, Carisma Prima Limited incorporated within its Constitution the Plan of Revitalizationof Pimjo Organization aproved on January 17, 2012 and adopted within its Constitution the followingclauses for protection:

“ Protection.1.1. For purposes of this Schedule, Clause 2, "Other Provisions",the term "company" refers to Carisma Prima Limited and to anyrelated or connected person or entity engaged in business and othereconomic activities, whether or not organized for profit, includingany entity controlled by a state or a territorial subdivision thereof;it includes a parent and its controlled trusts, subsidiaries, related orconnected entities, Third Parties subject to the control ordetermining influence of the company, including but not limited toagents, business development consultants, sales representatives,customs agents, general consultants, resellers, subcontractors,franchisees, lawyers, accountants, auditors, or similarintermediaries, acting on the company's behalf in connection withmarketing or sales, the negotiation of contracts, the obtaining oflicenses, permits or other authorizations, or any actions that benefitthe company or as subcontractors in the spply chain, BusinessPartners which include (i) Third Parties and (ii) joint ventureand consortium partners as well as contractors and suppliers,anywhere in the world.1.2. The company incorporates by reference Part I of theInternational Chamber ofCommerce Rules on Combating Corruption, 2011 edition.1.3. The company, when possible, shall incorporate by referencein its contracts Part I of the International Chamber of CommerceRules on Combating Corruption, 2011 edition.1.4. The company shall cease any director or representative ofthe company if it is determined by the remaining compliant directorsthat such person:





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1.4.1. fails to carry out her duties with responsibility;1.4.2. fails to exercise adequate skill and care with proper regardto the interests of the company's creditors and employees;1.4.3. fails to show the skill expected of a person with theknowledge and experience to act as a director or representative;1.4.4. fails to act as a reasonable person would do looking aftertheir own business;1.4.5. uses the powers granted by the company for her own benefitor undisclosed interests;1.4.6. makes personal profits at the company's expense;1.4.7. takes undisclosed benefits from the company;1.4.8. accepts undisclosed benefits from third parties;1.4.9. fails to treat all partners or shareholders equally;1.4.10. participates in undisclosed interested transactions with thecompany;1.4.11. fails to avoid conflicts of interest;1.4.12. fails to disclose conflicts of interest;1.4.13. fails to produce truthful reports or to make truerepresentations to the internal and external stakeholders;1.4.14. participates in wrongful actions against internal or externalstakeholders of the company;1.4.15. fails to treat all internal and external stakeholders fairly;1.4.16. fails to maintain the secrecy of confidential information andtrade secrets;1.4.17. fails to disclose important information to internal andexternal stakeholders;1.4.18. fails to make proper, legal and adequate use of Internet,communications services or banking, financial or investmentsservices.1.4.19. prepares, files, delivers, signs, approves false financialstatements and, in general, false, forged or adultered documentsor exhibits of any kind or any of the items mentioned beforethat contain information or data which fails to represent tha financialcondition of the company or participate as principals, accomplices,cooperators or assistants in actions, omissions, negotiations ortransactions of any kind in violation of the laws, regulations,recommendations, generally accepted best practices of behavior,rules of ethics, recommendations from multilateral bodies, legally,financially, administratively in República Bolivariana de Venezuela,New Zealand, United States of America and any other country.1.4.20. allows the company to continue to trade when unable to pay





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its debts;1.4.21. fails to participate and colaborate, truthfully, diligently, andcooperatively, with the legitimate authorities of any democratic andfree country, in inquiries or investigations aimed to protect theplanet or a particular society against the crimes such as moneylaundering, corruption, financing terrorist activities, drug trafficking,human trafficking, and crimes against the humanity.1.5. The non-compliant director or representative who falls inany of the hyphotesis set forth in 1.4 above, has the duty to promptlyresign to her offices, relinquish her powers and to stop voluntarilyto represent the company or to trade on behalf of the companygiving immidiate notice to the Chair of the Board of Directors,to other Director, to any chief executive officer or to any officerencharged of the protection of the company including, if necessary,Third Parties and Business Partners in order to contain damages thatmay have been caused or may be caused in the future.1.6. The non-compliant director looses its legitimacy from thestand point of the shareholders and of the internal stakeholders at themoment of the inception of her unfit conduct.1.7. The non-compliant director:1.7.1. forfeit immediately all offices held by, and powers grantedto, her;1.7.2. May not act as receiver of the company´s property;1.7.3. May not, directly or indirectly, be concerned or take part inthe promotion, formation, management, growth or liquidation of thecompany;1.7.4. May not be a director of any company;1.7.5. May not act like a director - even without being formallyappointed;1.7.6. May not act like a director - even if being formallyappointed;1.7.7. May not influence the running of the company through thedirectors or representatives;1.7.8. May not influence the running of the company through thestakeholders;1.7.9. May not influence voting proceedings at any level of thecompany or its boards, committees or bodies, in order to approve,directly or indirectly, her perfomance and matters in which she hasinterests.1.7.10. May not be involved in the formation of a new company ofthe company;





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1.7.11. May not act in a way that promotes a new company of thecompany;1.8. The company may at its discretion severe all connections andrelationships with the non-compliant director.”

As a consequence of the above governing rules of the Constitution of Carisma Prima Limited, ExecutiveVice-President and General Counsel Dennis P. McNamara (CRD # 2938486) should have figured it outthat there is no way for the protesting exdirectors to be appointed as directors of Carisma Prima Limitedsince any appointment will by itself terminate their office and powers.

Luis Alejandro Aguilar Pardo considered that an strategy of avoidances and delays was in motion. Iwrote that day - March 23, 2012 - to Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) the following:

“Messrs Lowenthal, McGuire and Holeman,Dear Mr. McNamara,

I very much regret that you have treated me the way you did. Youmay still be an excellent lawyer while being caring with others.

I spent 60 days cooperating with you. Now, I propose to you that thegame be different. It is called “tit-for-tat”. I will reciprocate youractions. Your last action was to continue with your tactic ofpostponing and obstaculizing our legitimate interests. This game –for your information - has the characteristic that it forgives previouspredatory actions so it is up to you to avoid my next action.

You must understand that your word is not something that I may relyupon. As I said, your delay tactics have a chronological unit of oneweek.

Today elapsed the term that I gave all directors of Chocolates ElRey, C.A. and Chocolates El Rey, Inc. on Sunday, March 18, 2012to give and [submit] their comments, clarifications, corrections,objections or protests to the Aviso al Comisario de Chocolates ElRey, C.A.. No answer was received. Please find attached the finalversion thereof.

Mr Holeman, Mr McGuire and Mr. McNamara did receive the emailI sent to Mr. Jorge M. Redmond S., the directors and theshareholders of certain companies asking to come forward. It was



The “letters” - not of my liking - were mere consequences of my duty as Compliance Officer2

overseeing these entities vis-a-vis the duty of protection and disclosure to the National Compliance Team, the

Inland Revenue Department and the Companies Office of New Zealand and the duty towards the financial

institutions in Venezuela as instructed by the National Compliance Team of New Zealand.



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sent Tuesday, March 20, 2012. As you have seen, none has comeforward and no one ever will. The most important part of thatdocument is what I believe still to be the truth even though certainunexplainable circumstances might temporarily show otherwise: “Lapersona que yo conocí en Ud [Jorge M. Redmond S.] es una personabuena, generosa y honesta.” Today the document “Aviso al Comisario” is being delivered to theComisario de Chocolates El Rey, C.A..

Since you and Mr. Redmond do believe in the power and merits of“letters” , another letters are being sent, following your example, to2

the Compliance Officers of 14 commercial banks in Venezuela,namely: Banco Exterior, Banco Mercantil, BANESCO, BancoNacional de Crédito, Banco Venezolano de Crédito, BancoVenezuela, Banco Provincial, Norvalbank (BOD), Central, BancoUniversal, CORPBANCA, Banco Caroní and Banco Banplus.

Since the Compliance Officers of those banking institutions arecompelled to notify the financial regulatory authorities in Venezuelaand not even the presidents and directors of such banks areempowered to stop their respective Compliance Officers, I will waitfor my next actions which will involve a denunciation before theOffice of the General Prosecutor, the Superintendente de lasInstituciones del Sector Bancario and the Presidente del Fondo dePtotección Social de los Depósitos Bancarios.

The end result will be an investigation of the facts mentioned in thedocument “Aviso al Comisario”.

It is possible that banks declare all loans to Chocolates El Rey, C.A.in default and that action might accelerate the bankruptcy ofChocolates El Rey, C.A. and the layover of all its employees.However, their directors and shareholders have acted so arrogantlythat they may feel to be beyond the reach of the law and reason.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Since the process of denunciation has started already, I am liberatedfrom any duty of professional secrecy. Unfortunately, it may not bestopped now.

Please find attached the Aviso al Comisario. In this document Irelate facts and circumstances that – after the proper corporate,administrative and judicial actions and investigations - translate intothe possibility of criminal prosecution.

The charges that may be pressed against the resulting responsiblepersons (who might eventually coincide with your protectees) are:

Under the Ley General de Bancos y Otras Instituciones Financierasand for actions from August 19, 2010 up to and including December28, 2010, the violation of its article 381 (Providing false informationto perform banking transactions) which is punished with jail for aterm from 8 to 10 years.

Under the Ley de Instituciones del Sector Bancario and for actionfrom December 28, 2010 up to an including the date hereof, theviolation of its article 213 ([Misappropriation] and distraction ofresources of the banks) which is punished with jail for a term from10 to 15 years and a fine of 100% of all resources extracted from thebanking sector via loans or otherwise using false financialstatements.

Under the Código Orgánico Tributario, the violation of its articlesdealing with tax frauds which is punished with jail for a term of 6months to 7 years.

Under the Criminal Code, the violation of its articles dealing withfraudulent bankruptcy which is punishable with jail for a term of 3to 5 years.

Add up the maximum jail terms because of eventual concurrence ofconducts, add the fact that this might be considered plainwhite-collar criminal actions against the general public and mightqualify as frauds to the banking systems and reach your ownconclusions.

[A chart showing crime descriptions, supporting articles of law and





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consequences has been omitted] Unfortunately, I have to go back to Caracas, Venezuela. Eventhough I do not believe it and consider it absolutely impossible tohappen, five of my colleagues – all respectable lawyers - haveexpressed in writing concerns for my well being while in Venezuela.They claim – and I do not believe them, of course, since otherwiseI would not dare to go there - to have heard stories of persons thatare “invited” against his or her will to certain informal meetingsduring which they are “convinced” to adopt or abandon certainactions. They even claim to have heard stories of persons who arearrested because ceratin substances are “[mystically]” found in theirluggage while going through customs. They change their minds inanother way which you can see at our website www.aguilar.pro,“Conflicto 23-03-2012” (the date hereof, by the way), “La Masacred e U r i b a n a ” . Y o u ma y v i s i t i t d i r e c t l y a thttp://www.aguilar.pro/conflicto2332012/lamasacredeuribana.html.

As you may observe, my website is already loaded with alldocuments, emails, evidences, and supporting documents. Today,the accesses to those sections are protected. But, if somethinghappens to me, precautions have been taken in order to secure mysuccession, open up the libraries and to continue this unfortunatestory. Actually, Monday morning I am executing my last will.

With respect to Oppenheimer & Co., Inc. I had no quarrel and I hopethat your next action is known to me before mine is executed.Unless something extraordinary happens, it is not my intention –now and today - to contact you.

I personally make you responsible, together with Jorge M. RedmondS. and his collaborators, for all sufferings of the children that mighthave suffered because of your tactics. You will never know but if Ilearn of one, I will let you know. In Chaos Theory, it is known as theButterfly Effect where small actions have [immense] effects innon-linear systems. Anyhow, that is up to you to fix.

Since you operate in Caracas, I imagine that you have means to havethe documents that I have drafted in Spanish translated into English.Do not blame Johnny Pettus for not telling these facts. He wasbound under a Confidentiality Agreement which I attach.





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Nothing said has the intention of offending anyone or to initiate astruggle or to cause harm.

Best regards.”

Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) had actualnotice since March 23, 2012 that the persons who wrote the undisclosed letter dated February 9, 2012were facing serious - and confessed - imputations of falsification of financial statements to defraudfinancial institutions, supplying false information to induce fraud, misappropriation of funds fromfinancial institutions, tax frauds in order to commit the previously mentioned actions, fraudulentbankruptcy, embezzlement, and other conspiracies. In addition, a plan to misappropriate funds from aUSA compny for personal gain was discovered as well the execution - out of the funds of Pimjo TrustCV - of unauthorized wire transfers to fund unauthorized projects personally linked to the dissentingexdirectors; one of which resulted in a narcissistic behavior of self public promotion.

Another event came up on March 24, 2012 and despite my previous statement of not to contact moreOppenheimer & Co., Inc unless an extraordinary event would come up, I wrote again to Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) in the following terms:

Messrs Lowenthal, Mr. McNamara and McGuire,

Dear Mr. Holeman,

As you well know, the first objective that I pursued was toincorporate in this matter the Office of the Chief ComplianceOfficer of Oppenheimer & Co., Inc. for the protection of theinstitution that I represent and my own protection.

Today, Saturday, March 24, 2012, at 8:10 am, a new developmenttook place: I received by email the sixth warning. This time, itcomes from a person with a background different from the legalprofession. I believe in this person more than in the sworn instatements of one million public notaries.

After quoting him literally, I will freely translate his words intoEnglish as best as I can:

“Sé que podrás salir legalmente adelante pues te asiste la razón yla ley, y podrás limpiar a Pimjo de todos estos personajes en quienconfiaste, pero no dudo que por su peso social específico tutranquilidad y hasta tu vida corren peligro.”





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

I know that you will be able to succeed legally because you areassisted by reason and law, and that you will be able to clean Pimjofrom all those persons whom you trusted but I have no doubts thatdue to their social specific weight your tranquility and even yourlife are in danger. (Free translation. Please verify with your ownsources).

I myself in my heart fervently wish to believe that the author of thequoted words is mistaken. Reason and probabilities, nevertheless,should also be allowed to influence [decisions].

Therefore, I have [two] requests:

1.- Protect my life and my famly, and

2.- Tell me the truth of what you know.

In order to achieve the first and paramount objective, I herebyrequest that Oppenheimer & Co., Inc. assumes the cost and hire theservices of Mr.Jesús Briceño (+58-414-372.6582) in order toascertain the probabilities of the occurrence of any risks.

I am perplexed by so many conflicting situations, conducts and[statements]. It seems to me that you know something that I do notand that you are hiding something that I can not figure out what itis.

Your Mr. Lewis in Boca Raton told me that “the lawyers” wereexamining my instructions ans supporting documents. Someone inyour organization induced, or made, or allowed, me to believe thatsuch “lawyers” were Sullivan & Cromwell. Suddenly, the membersof that firm that I had contacts with, cut all communications withme. Sergio Galvis was unable or refused to receive me in NewYork, at their offices at 125 Broad Street on February 24, 2012.

On February 24, 2012 I had my only meeting with Mr. McNamara(General Counsel), Mr. Holeman (Chief Compliance Officer), Mr.McGuire (Deputy General Counsel Director of Litigation). Only afourth gentleman present whose name I can not recall had read allthe material. Mr. Holeman seemed to have had some generalknowledge of the supporting documents. Mr. McNamara and Mr.





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McGuire (the “lawyers”) had none.

The issue of the registered address being used for the account wasbrought up again during that meeting. That address “CCS 82586.PO BOX 025323, MIAMI FL 33102-5323” is the same addressused in your unauthorized Oppenheimer-connected checkingaccount number 26201338505041 at certain UMB Bank, N.A.(ABA 101278856) whose signatory is John Gayle Pettus Jaso. Igive you actual notice that such address should be connected witha forwarding agent named Mail Boxes Etc. that seem to bephisically located at 2250 NW 114th Avenue, Unit 1C, Miami, FL33172-3652 and in Venezuela at MBE VENEZUELA CCA,Avenida Orinoco entre Calles Mucuchíes y Perijá, Edificio L&M,Pent House, Las Mercedes, Baruta, Caracas. Tel.+58-212-992.2120, +58-212-992.6781 and +58-212-991.1277.

Why are you still sending the statements of the account to theaddress “CCS 82586. PO BOX 025323, MIAMI FL 33102-5323”having actual knowledge that such address is not the correctaddress and you know that you have reasons to believe that suchaddress is wrong and strange[?].

I have asked you to investigate the account at UMB Bank, N.A.which is clearly identified with Oppenheimer. You are very wellaware that a rogue [management] of the checking account isdangerous. You are also aware that, to the best of my knowledge,it is not possible that the signatory in October 18, 2004 of checknumber 1004 had authority to open such account or [mobilize]funds. I have asked you for the statements of this account and toinvestigate it. Report what have you done about it, please[ ].

Mr. McNamara affirmed that the access of the account wasrestricted but I saw in the statement for the period ended February29, 2012 that some one was capable of moving funds. The MoneyMarket Funds were reduced from $4.104.536,55 to $ 2.533.928,95during February 2012 even though I had requested the interventionand protection of the Office of the Compliance Officer on January23, 2012. Investments [decisions] involving more than US$1.500.00,00 have been made while you know that the legitimacy ofthe trading authorities and investments profiles may have beencompromised.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

I expressly asked you to find out the trading strategy of Mr. JohnGayle Pettus Jaso and you have failed to do so. Several persons aresurprised that the account had $ 4.104.536,55 in cash by the end ofJanuary 2012 which is 34,85% of Total Value Asset. They claimthat the return of those $ 4.104.536,55 is 0,01% p/a.

One other factor aggravating these conflicting situations is that Mr.McNamara had expressed since February 24 that he would reviewthe supporting documents – even during a weekend, I recall – andthat he would come back to me with certain questions. Then, afterrepeating several times the same pattern, he acknowledged that thetruth was that he was giving time to Mr. Jorge M. Redmond S. inorder to do something; perhaps initiating legal actions. Had MrMcNamara been truthful from the beginning, I would now believein him. The factor is even more sour since Mr McNamara knowsthat the Deed of Creation of Pimjo Trust CV has specific rules forsolving conflicts via [mandatory] mediation and arbitration.

The other disturbing factor is that Mr. McNamara mentioned thathe gave Mr. Jorge M. Redmond S. until early next week to respondto Mr. McNamara who had previously affirmed that he had“…received correspondence from Mr. Redmond expressingconcern about our ceding control of the account to you…”

There are letters and there are letters. I might write to a letter to afinancial institution stating that I express my concern about the wayPresident Obama is managing his account (wherever he might haveit) and you would find it absurd that the receiving financialinstitution [acknowledge] to President Obama after several weeksthat his account [is] restricted and that “…I have told him that heneeds to consider recognizing you as having control of the account,working out an amicable resolution amongst you and the otherdirectors (or former directors) or be prepared to take legal action.”

Mr.McNamara and Mr. McGuire have not delivered to me a copyof the letter or correspondence [dated February 9, 2012] sent to himby Mr. Jorge M. Redmond S. as I requested. I can not imagine thatthe Vice President and General Counsel of Oppenheimer & Co.,Inc. would restrict an account just because someone has merelyexpressed her concerns. Therefore, Mr. Jorge M. Redmond S.should have mentioned some grounds which should have been





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serious and grave enough as to restrict the account in order to allowhim at least 31 days to begin to respond to the Vice President andGeneral Counsel of Oppenheimer & Co., Inc. Please kindly sendme a copy of such letter. I do need it and I deserve to have it.

I have been advised to strike first and initiate criminal actionsagainst certain individuals in Venezuela. I have mentioned that –knowing the conditions of the jail and detention [institutions] inVenezuela as you may ascertain in the following link -http://www.aguilar.pro/conflicto2332012/lamasacredeuribana.html- I will never do that since I am not that kind of person.

I wrote back to my advisor the following and, as before, afterquoting him literally, I will freely translate his words into Englishas best as I can:

‘No estoy de acuerdo con recurrir a la vía penal para resolverconflictos de dinero.

Dada las condiciones carcelarias y penitenciarias en Venezuela, meparece que sería un delito contra la humanidad.

¿Qué me diferenciaría del SS-Obersturmbannführer Adolf OttoEichmann?

Yo no soy así. Por cierto, una debilidad mia es que Redmond sabecomo pienso en este sentido.

Si no puedo lograr que prevalezca la razón, prefiero vivir con lahumillación de ser un fracasado que cargar con la culpa de actosinhumanos.’

I am not in agreement to pursue criminal actions to solve moneyrelated conflicts.

Due to the jails and penitentiaries conditions in Venezuela, Ibelieve that it would be a crime against humanity.

¿What would make me different from SS-ObersturmbannführerAdolf Otto Eichmann?





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

I am not that way. By the way, one of my weaknesses is thatRedmond knows how I think on this matter.

If I can not achieve that reason prevail, I´d rather live with thehumiliation of being a failure than to carry the burden of guilt forinhuman acts. (Free translation. Please verify with your ownsources).

I do not wish that fate for me so if you know something, please, letme know.

I sincerely hope you will not be my SS-ObersturmbannführerOppenheimer.

I wish that you treat me with transparency, honesty andtruthfulness. Really, believe me, there is no need to be uncaring toothers in order to be [successful] in life.”

It seems that the complaining exdirectors sent a second letter dated March 26, 2012 but this timepurportedly signed by Carlos Zuloaga.

This letter has not been disclosed by Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) even though it is being quoted in the draft of Interpleader Complaintcirculated by Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486)on August 2, 2012.

From information and belief, Executive Vice-President and General Counsel Dennis P. McNamara(CRD # 2938486) failed to ascertain the alledged representation of Carlos Zuloaga and whether or notthe said Carlos Zuloaga was acting under authority in writing.

From information and belief, the said Carlos Zuloaga asserts facts allegedly occurred between the monthsof July 2011and January 2012 even though the said Carlos Zuloaga was never present in any of theopportunities that the said Carlos Zuloaga relates in his letter to Executive Vice-President and GeneralCounsel Dennis P. McNamara (CRD # 2938486).

From information and belief, the said Carlos Zuloaga poses to Executive Vice-President and GeneralCounsel Dennis P. McNamara (CRD # 2938486) three questions. Once Executive Vice-President andGeneral Counsel Dennis P. McNamara (CRD # 2938486) decide to stop concealing such letter, LuisAlejandro Aguilar Pardo will answer the questions since obviously Executive Vice-President and GeneralCounsel Dennis P. McNamara (CRD # 2938486) has not been capable of answering since it has beenunable to understand the structure that Oppenheimer & Co., Inc. and has preferred not to risk





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Oppenheimer & Co., Inc. own self-rescue plan by asking Luis Alejandro Aguilar Pardo for the answers. From information and belief, it seems that the said Carlos Zuloaga - again - voluntarily andspontaneously confessed again that his alledged represented dissenting exdirectors recognize thatthey are no longer directors and that have no powers to become directors of Carisma Prima Limited.

It must be remembered that no matter what the expelled directors do or omit to do, they areprohibited to exercise any office in Carisma Prima Limited or in any of its entities or in any entityresulting from the successful culmination of the Plan of Revitalization of Pimjo Organization datedJanuary 17, 2012 which is now integral part of the Constitution of Carisma Prima LImited and of theDeed of Creation of Pimjo Trust CV. On the other hand, the anti-corruption clauses existing in theConstitution of Carisma Prima LImited and of the Deed of Creation of Pimjo Trust CV shall ceasetheir powers and appointments as of and since May 16, 2011 which is the date when the exdirectorsperfected their unbecoming actions. But, additionally, as a Compliance Officer overseeing CarismaPrima Limited and its entities downstream, Luis Alejandro Aguilar Pardo, acting in cooperation withNational Compliance Team of New Zealand, the Inland Revenue Department and the CompaniesOffice of the Ministry of Economic Development of New Zealand will face the predicament ofsection 151 of the Companies Act of 1993 of New Zealand which states:

“151 Qualifications of directors(1) A natural person who is not disqualified by subsection (2) maybe appointed as a director of a company.(2) The following persons are disqualified from being appointedor holding office as a director of a company:(a) a person who is under 18 years of age:(b) a person who is an undischarged bankrupt:(ba) a person who would, but for the repeal of section 188Aor section 189 or section 189A of the Companies Act1955, be prohibited from being a director or promoterof, or being concerned or taking part in the managementof, a company within the meaning of that Act:(c) a person who is prohibited from being a director or promoterof or being concerned or taking part in the managementof a company under section 199K or section199L of the Companies Act 1955 or who would be soprohibited but for the repeal of that Act:(d) a person who is prohibited from being an officer or promoterof or being concerned or taking part in the managementof a company under section 199N of the CompaniesAct 1955 or who would be so prohibited but forthe repeal of that Act:





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(e) a person who is prohibited from being a director or promoterof or being concerned or taking part in the managementof a company under section 382 or section 383or section 385:(ea) a person who is prohibited from being a director or promoterof, or being concerned or taking part in the managementof, an incorporated or unincorporated bodyunder the Securities Act 1978 or the Securities MarketsAct 1988 or the Takeovers Act 1993:(eb) a person who is prohibited from 1 or more of the followingunder an order made, or a notice given, under alaw of a prescribed country, State, or territory outsideNew Zealand:(i) being a director of an overseas company:(ii) being a promoter of an overseas company:(iii) being concerned or taking part in the managementof an overseas company:(f) a person who is subject to a property order made undersection 30 or section 31 of the Protection of Personaland Property Rights Act 1988:(g) in relation to any particular company, a person who doesnot comply with any qualifications for directors containedin the constitution of that company.(3) A person that is not a natural person cannot be a director of acompany.(4) A person who is disqualified from being a director but whoacts as a director is a director for the purposes of a provisionof this Act that imposes a duty or an obligation on a directorof a company.”

The National Compliance Team of New Zealand, the Inland Revenue Department and the CompaniesOffice of the Ministry of Economic Development of New Zealand have been properly notified of all thecircumstances surrounding this regrettable case and all my actions have been coordinated and/or notifiedto those agencies.

From information and belief, it seems that the said Carlos Zuloaga has affirmed that they have not madea proper review of the facts, that they do not have any information and that you and them will reviewthe entire situation to try to arrive at some conclusion beneficial to them and Oppenheimer & Co., Inc.

On March 28, 2012, after receiving an email from Michelle L. Sullivan, Vice President, Director ofFiduciary Compliance, IWM & Corporate Compliance Assessment Team, UMB Financial Corporation





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816.860.5076 Phone, 816.860.7503 Fax, [email protected], 1010 Grand Boulevard, KansasCity, MO 64106, I wrote to Allen B. Holeman, Managing Director and Chief Compliance Officer ofOppenheimer & Co., Inc. (CRD # (1060910) et al. exposing his deviated statements from the truth.

The email from Ms. Sullivan which I conveyed to Oppenheimer & Co., Inc. read as follows:

“Mr. AguilarWe are in receipt of your inquiry regarding the Pimjo Trust CVaccount. After further review we have identified that the check inreference is drawn off an Oppenheimer account that clears theiraccounts through UMB Bank. In this case our client isOppenheimer and we are not authorized to share any furtherinformation related to this account. I would suggest you contactOppenheimer directly at 1 (800) 225.5677 so they can furtherassist you.It is anticipated that this correspondence has been responsive toyour request, but if there are additional questions or concerns thatI can answer, my contact information is below.Respectfully,”

My email to Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer &Co., Inc. (CRD # (1060910) et al. on March 28, 2012 was the following:

“Messrs Lowenthal, Mr. McNamara and McGuire,

Mr. Holeman,

Please find quoted below, the email that I received from Ms.Michelle L. Sullivan, Vice President, Director of FiduciaryCompliance, IWM & Corporate Compliance Assessment Team,UMB Financial Corporation.‘Mr. Aguilar,We are in receipt of your inquiry regarding the Pimjo Trust CVaccount. After further review we have identified that the checkin reference is drawn off an Oppenheimer account that clearstheir accounts through UMB Bank. In this case our client isOppenheimer and we are not authorized to share any furtherinformation related to this account. I would suggest you contactOppenheimer directly at 1 (800) 225-5677 so they can furtherassist you.It is anticipated that this correspondence has been responsive to

mailto:[email protected],





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your request, but if there are additional questions or concernsthat I can answer, my contact information is below.Respectfully, Michelle L. SullivanVice President Director of Fiduciary ComplianceIWM & Corporate Compliance Assessment TeamUMB Financial Corporation’

I had the impression that you had told me on February 24 thatOppenheimer & Co., Inc. did not have any connection with thisaccount. I think that I was lead to believe that you had noinformation on this account.

Would you, please, provide me with the information requested:opening documents, authorized signatories and statements of theaccount?

Let me share with you, Mr. Holeman, that I take this matter very[seriously] and I am very sensitive with these issues.

In 1991 – 1992, my life and the life of my wife and my – then –four sons were threatened by a Colombian drug cartel because Iacted as one of the many attorneys in the case UNITED STATESOF AMERICA (plaintiff) vs ALL FUNDS ON DEPOSIT INTHE ACCOUNTS OF CERTAIN INDIVIDUALS ANDENTITIES AT CERTAIN FINANCIAL INSTITUTIONS ANDALL FUNDS DEPOSITED INTO SAID ACCOUNTS ORTRANSFERRED TO, THROUGH AND OR BY SAIDFINANCIAL INSTITUTIONS FOR THE BENEFIT OF SAIDINDIVIDUALS AND ENTITIES (defendant), Civil Action No.CV-91-0881 (Warrant for Arrest of Article in Rem), JudgeThomas C. Platt, U.S. District Court for the Eastern District ofNew York. I know how it feels receiving threats of kidnappings,bombs, assasination, and being unable to obtain protection fromany authority anywhere.

Mr. McNamara,

Would you please authorize UMB Bank NA to grant me fullaccess to this account and to share with me the information they





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have about this account?

Have you received a response from Mr. Jorge M. RedmondSchlageter?

Thank you very much.”

Immediately thereafter, Oppenheimer & Co., Inc. officers became uncooperative, silent and illmannered. If before March 28, 2012, the time unit of Oppenheimer & Co., Inc. officers was the period of one week,after such date, it adopted the position of denial, avoidance and silence.

Furthermore, there were traces of contempt and indifference for the well being of others just to achievetheir own goals as illegitimate as they might be.

By March 28, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) had already received the letter from Redmond, Toro and Alfonzo dated March 26, 2012.

The content of such letter has been kept in secret and only partially disclosed in the draft of the“Interpleader Complaint” circulated by Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) on August 2, 2012.

Four points must be clearly stated for the record. One is that my mandate did not include to aggressOppenheimer & Co., Inc. The second one is that I offered cooperation to mend the problems for allunderstanding that we had a common goal. I also understood that Oppenheimer & Co., Inc. was as mucha victim of unsought circumstances as Pimjo Trust CV was in their respective dimensions and legitimateinterests. Third was that I had the burden of preserving the attorney duty of confidentiality andprofessional secrecy. And fourth, this most disturbing state of affairs and difficulties were caused by theiremployees Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker RenéF.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD #2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914)who participated actively in these entities and did intentionally conceal the vital information toOppenheimer & Co., Inc.

From information and belief, it seems that the exdirectors concurred with the fourth statement in writing.

On April 9, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) wrote the following letter addressed to Jorge Redmond and Luis Alejandro Aguilar Pardo:

“For some time now I have been discussing with each of you oryour representatives, either personally or by phone, issues related





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to the Pimjo Trust account (the "Pimjo Trust Account") custodiedat Oppenheimer & Co. Inc. ("Oppenheimer"). Each of you, or yourrepresentatives, has provided me with documentation concerningthe Pimjo Trust Account and the authority of certain individuals toprovide instructions on how the Pimjo Trust Account should behandled.

According to the information provided to Oppenheimer, the PimjoTrust C.V., the purported owner of the Pimjo Trust Account, is partof a complex corporate structure with entities created under thelaws of various jurisdictions.

The communications as well as the documentation provided toOppenheimer make it clear that the assets in the Pimjo TrustAccount should be used to further the purposes of the FundacionPimjo, A.C. as well as the intentions of the late Mr.JozefGrootkerk.

However, the communications as well as the documentationprovided also demonstrate the existence of an ongoing bona fidedispute in respect of which individuals have the authority to controlthe assets in the Pimjo Trust Account.

As a result of the foregoing Oppenheimer requests that each of youas well as Mr. German Taro Arevalo, Rafael Alfonzo Hernandezand Astrid Kristina Redmond mutually agree on what individualshave authority to instruct Oppenheimer on the Pimjo TrustAccount. We would then request that all five individuals jointlyinstruct Oppenheimer in writing as to which person(s) has (have)the ability to control the Pimjo Trust Account.

To the extent that Oppenheimer does not receive a joint writteninstruction executed by the five individuals named above by theclose of business, New York time, on Friday, April 13, 2012,Oppenheimer intends to file an action in interpleader in the UnitedStates District Court for the Southern District of New York (the"U.S.D.C.") and petition the U.S.D.C. to determine what person(s)has (have) the right to control, and accordingly, instructOppenheimer in regards to, the Pimjo Trust Account.

Please direct any communications regarding the foregoing to the





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undersigned at the address set forth in this letter.

Very Truly Yours,

Dennis P. McNamaraExecutive Vice Presidentand General Counsel

cc: Mr. German Toro ArevaloMr. .Rafael Alfonzo HernandezMr. Astrid Kristina RedmondMr. John PettusCarlos Zuloaga Travieso, Esq.Geoffrey Cone, Esq.Matthew Riccardi, Esq.John McGuire, Esq.Mr. Allen Holeman”






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This letter contained five disturbing punctuation points presented as fallacies hidden within the rationale.

“According to the information provided to Oppenheimer, the PimjoTrust C.V., the purported owner of the Pimjo Trust Account, is partof a complex corporate structure with entities created under the lawsof various jurisdictions.”

Firstly, there are no “purported owners”. Since Oppenheimer & Co., Inc. and its employees opened thisaccount, possibly with the intention of taking advantage from the funds at the time of death of JosefGrootkerk Zeldenrust while disrupting the express wishes of Josef Grootkerk Zeldenrust, the account titleshave been vested upon Pimjo Trust CV.

Secondly, the so called “complex corporate structure” not only is not such but it was the creation ofOppenheimer & Co., Inc. itself and of its employees - directly under its control, instructions, rules anddirections - who both failed intentionally to know and understand the corporate structure and failed tocomply with their legal duties.

In any civilized jurisdiction Oppenheimer & Co., Inc should not be entitled to allege in its own defenseits own negligence, its own fault and even less if it has failed to exercise proper control concerning thecompliance of its duties, became knowingly engaged in illegal activities and profited accepting resourcesand revenues arising out of the exercise of illegal activities.

A clear explanation of what is really true behind the words of Oppenheimer & Co., Inc. is by paraphrasingand dramatizing its content:

“ Oh poor me Oppenheimer & Co., Inc.! I am a victim of externalcircumstances! I have not analyzed as promised the documentationthat I have been provided by Pimjo Trust CV which I should havebeen aware of 11 years ago but I failed to do so - then and today -because I - Oppenheimer & Co., Inc. - and my employees wereknowingly illegally involved in criminal activities in Venezuela (i)very busing exploiting a market to whose access was prohibited bylaw, (ii) profiting and recognizing revenues arising out of illegalactivities - possibly organized crime - (iii) suffering deeply becauseI - Oppenheimer & Co., Inc. - was not aware that my accomplices inVenezuela had another hidden agenda for their personal benefit (iv)because I - Oppenheimer & Co., Inc. - failed again to supervise myCaracas Branch Office and my rogue employees even after I -Oppenheimer & Co., Inc. - and such employees were exposed byNYSE (v) knowing that Venezuela has become a real threat for the





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security and protection of the global financial system. Oh, now Ineed a U.S. Court to tell me what to do. But, on the other hand, I donot wish to do that and I do not have basis to do it.”

“The communications as well as the documentation provided toOppenheimer make it clear that the assets in the Pimjo TrustAccount should be used to further the purposes of the FundacionPimjo, A.C. as well as the intentions of the late Mr.JozefGrootkerk.”

Thridly, Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) invertedthe reality. Pimjo Trust CV account - created by Oppenheimer & Co., Inc. and its employees who benefiteconomically from those actions - should be used to further the intentions of the late Josef GrootkerkZeldenrust. Not the other way around.

All entities are mere instrumentalities useful while helping to achieve legitimate goals. Fundación Pimjo,A.C, became a risk factor primarily because of Oppenheimer & Co., Inc. and I had to take the decision toshut it down permanently because we were advised by then Banco Venezolano de Crédito, S. A.Compliance Department that Fundación Pimjo, A.C. had been receiving deposits in Bolívares thoroughchecks drawn by unknown individuals funneled from the offices of Oppenheimer & Co., Inc. (beforeFahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918),Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914.

So, while it is true that Oppenheimer & Co., Inc. and its employees Oppenheimer & Co., Inc. (beforeFahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918),Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) created and actively participated in the socalled “complex corporate structure” and intentionally deviated the intentions of Josef GrootkerkZeldenrust for their own agenda, it is also true that they were the sole responsible parties that caused theshutting down of Fundación Pimjo, A.C.

On the other hand, it must be pointed out for the information of Executive Vice-President and GeneralCounsel Dennis P. McNamara (CRD # 2938486) that being a primary beneficiary in a discretionary trustdoes not entail being a final beneficiary at the vesting date of the trusts.

The fourth punctuation issue was this strange and absurd statement from Executive Vice-President andGeneral Counsel Dennis P. McNamara (CRD # 2938486):

“However, the communications as well as the documentationprovided also demonstrate the existence of an ongoing bona fide





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dispute in respect of which individuals have the authority to controlthe assets in the Pimjo Trust Account.”

I believe that Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) hasno basis to support such determination and furthermore has hidden such basis from the parties scrutiny.

I will explain more about this god-like, “erga omnes”, unsupported conclusion - not verifiable by the parties- since its basis have been kept in secrecy.

The fifth and last punctuation point at this stage was the inconsistency of the treatment of the exdirectors.While my actions with respect to the resignation of Caracas Office Branch Manager and Broker John GaylePettus Jaso (CRD # 2415914) as director of Carisma Prima Limited when unchallenged and silenced, thevery same exercise of powers become challenged and Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486) did not requested the execution requested in his letter byseemingly renegade and defector Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD# 2415914) .

Following receipt of that letter, I took several actions one of which - as mandated and obliged to by theDeed of Creation of Pimjo Trust CV - was to initiate mandatory mediation as per articles 41 to 47 of theDeed of Creation of Pimjo Trust CV.

I wish to point out that this private mediation process was unanswered by the exdirectors, avoided duringmonths and plainly refused on April 20, 2012.

Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) obstaculizedduring months the exercise of the ADR rules governing conflict solutions in Pimjo Trust CV.

“Simile modo”, Oppenheimer & Co., Inc. refused to mediate as well as per FINRA Dispute ResolutionMediation Department letter dated June 22, 2012.

Additionally, Redmond, Toro and Alfonzo failed to appear at the audience - properly served - convenedby Centro Empresarial de Conciliación y Arbitraje (CEDCA) of the Venezuelan American Chamber ofIndustry and Commerce (VENAMCHAM) in Caracas, Venezuela, in accordance with a request ofinstitutional mediation properly filed. It must be pointed out that CEDCA was created during the term inwhich Jorge Redmond acted as president of VENANCHAM and that both Toro and Alfonzo are activemembers of that institution.

Additionally, I pledged for support from public figures in Venezuela who might be able to stop thiscombination of “stalemate” and “brinkmanship” tactics being in motion. Among the many personsapproached were Jorge Cardinal Urosa, Archbishop of Caracas, Auxiliary Bishop of Caracas FernandoCastro A. and Chief Rabbi of Caracas Pynchas Brener. I made my case and I do not know if those





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personalities did or did not intervene. The line of my argumentation was that Pimjo Trust CV would beforced to suffer losses because of huge attorneys fees and because it was a clear violation of articles 32 and33 of the Deed of Creation of Pimjo Trust CV besides a selfish behavior in detriment of the persons mostneedy.

On April 16, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486)sent the following email:

“As you are aware in my letter of April 9, 2012, I informed you thatOppenheimer would seek to file an interpleader action in the UnitedStates District Court in New York. Since my April 9th, letter I havebeen contacted by either the directors or their representatives askingfor that deadline to be extended. In the hopes that a mutuallysatisfactory resolution can be obtained as to the control of the PimjoTrust Account, Oppenheimer has agreed to extend the deadline tofile an interpleader action until the close of business Friday, April27th, 2012.”

On April 17, 2012, I announced the exdirectors that I would travel to Caracas, Venezuela and that I wouldmake myself present at the offices of Jorge Redmond in Caracas, Venezuela at 3:00 pm on April 20, 2012.Toro and two lawyers acting for the exdirectors were present and after several hours of senseless struggleand exhibitions of coercion, they finally agree to work out a complete, transparent, legal, definitive andpermanent solution without partial interlocutory solutions based upon the Plan of Revitalization of PimjoOrganization dated January 17, 2012.

The agreement was a fake position and their tactic consisted in waiting until near the end of Friday, April27 deadline to impose their demands which consisted in my transferring to them of the control of CarismaPrima Limited. Accounts of the proceedings and their admission that the agreement was just a fake are onfile and signed by independent witness.

On April 30, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486)sent the following email:

“As you are aware in my letter of April 9, 2012, I informed you thatOppenheimer would seek to file an interpleader action in theUnited States District Court in New York. That deadline wassubsequently extended until April 27th, 2012 by an email from meon April 16th . Since my April 9th, letter and my April 16th email,I have been contacted by either the directors or their representativesasking for that deadline to be extended. In the hopes that amutually satisfactory resolution can be obtained as to the control of





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the Pimjo Trust Account, Oppenheimer has agreed to extend thedeadline to file an interpleader action once more until the close ofbusiness Friday, May 11th, 2012. Oppenheimer request that the parties do all they can within theirpower to reach an amicable settlement of the issues surrounding thePimjo Trust prior to May 11th.”

On May 7 and 8, 2012, I requested Executive Vice-President and General Counsel Dennis P. McNamara(CRD # 2938486) to proceed with the filing of the interpleader complaint. As of September 10, 2012, 127day have elapsed since that request was made.

No response neither reaction came from Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) on or after May 11, 2012 after expiring the last deadline.

Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) will not show upagain until noon of August 2, 2012; that is 155 days after announcing his idea of the interpleader actionand 232 days after receiving my first correspondence.

On May 13, 2012, the following email was transmitted to Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486):

“Please note that on May 13, 2012, Fundación Pimjo A.C. has beenremoved as beneficiary of the Xavier Trust in accordance withsub-clause 37(1)(b) of The Xavier Trust Deed of June 27th, 2001and as beneficiary of the Joseph Trust in accordance with sub-clause7(1)(b) of The Xavier Trust Deed of July 7th, 2009.

Please note that on April 15, 2012, Aguilar & Aguilar Limitedremoved Fundación Pimjo A.C. and issued a new Deed ofNomination and [Acknowledgment] of Beneficial Interest.

Please note that on April 15, 2012, Carisma Prima Limited[amended] its Constitution and it was registered in the Register ofCompanies of New Zealand.”

Supporting documents were forwarded to Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) upon his request on May 14, 2012.

On June 21, 2012, Luis Alejandro Aguilar Pardo wrote to Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486) the following:





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Mr. McNamara,

Oppenheimer & Co., Inc. received my request to incorporate mysignature as [authorized] signatory on February 24, 2012; that is150 days ago.

Besides being aware that I am the sole director of Carisma PrimaLimited and the sole representative of Pimjo Trust CV, you mustrealize that I will always be director of Carisma Prima Limited withfull and unlimited powers as Manging Director of Carisma PrimaLimited no matter what is the result of the interpleader action.

“As you are aware, my mission consists in:

1.- Execute the Plan of Revitalization of Pimjo Organization datedjanuary 17, 2012, and, among others, execute the internal audit ofthe dealings of Pimjo Trust CV (notified to you in writing onFebruary 1, 2012).

2.- Obtain and secure control of Pimjo Trust CV account atOppenheimer & Co., Inc.

3.- Obtain and validate information regarding Pimjo Trust CVportfolio account at Oppenheimer & Co., Inc.

4.- Obtain and validate information regarding Pimjo Trust CVaccount facility at UMB Bank N.A. - Oppenheimer & Co., Inc.

5.- Transfer assets to SunTrust Bank, N.A. while maintainingopened the account at Oppenheimer & Co., Inc. free from moneylaundering and/or criminal taints.

6.- Recover damages caused by former directors.

Oppenheimer & Co., Inc. has delayed the Revitalization of PimjoOrganization since mid February 2012. Your last delay wasconstrued around your unfulfilled threat of filing an interpleaderaction in the U. S. Court for the Southern District of New York.

The last deadline set by you expired on May 11, 2012; that is 42days ago. No action has been taken by you ever since.





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I understand that you intend to postpone the circulation of the draftof the complaint of the interpleader action and the filing of theinterpleader action as well.

It seems that all your postponements are unilaterally aimed by youto give someone else another chance for a non-judicial resolution;a never ending story of deceptive failures, predatory avoidancepractices and frustrations to all.

I wish to convey to you (i) that the exdirectors have nothing neededby Pimjo Trust CV to induce us to negotiate with the exdirectors,(ii) that Pimjo Trust CV will not accept anything different to anunconditional withdrawal by the exdirectors of all claims, and (iii)that Pimjo Trust CV will use all means available to secure that itreceives funds free from money laundering and/or criminal taints.

Hopefully, Mr. Sean C. Sheely incorporation might serve as acatalyst to bring this conflict to an end.

Save for recovering damages caused by the exdirectors, it is notwithin my mandate to prosecute the exdirectors on behalf of PimjoTrust CV (even though I am personally free to act as I see fit). Thatdecision will be adopted by the new authorities of PimjoOrganization as a result of the Revitalization Plan of PimjoOrganization.

I urge you to circulate your interpleader action complaint since Ineed it for initiating mediation proceedings at CEDCA in Caracas,Venezuela. Please find attached my request for mediation readysince June 7, 2012 to be filed just waiting for your circulation ofthe draft of the complaint of the interpleader action.

It is quite abnormal that Oppenheimer & Co., Inc. restraints at will,without time limits and without justification access to the accountto its legitimate owner. You have alledged that you feel the need tofile an interpleader action. I hereby request that you either grant meunlimited access to the account or else file the interpleader action.

As the authorized representative of Pimjo Trust CV, I have beendeprived of access to the account for an extended period of time.





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I understand that no person outside Oppenheimer & Co., Inc. hasbeen allowed to monitor the account of Pimjo Trust CV eventhough several concerns have been raised with the Office of theChief Compliance Officer about the actions or omissions affectingthe account.

It is my understanding that no authorized person representing yourclient Pimjo Trust CV has been allowed to monitor your actions,that your brokers lack trading authority and that there are no goalsand investment strategies agreed upon. Furthermore, I understandthat there were unauthorized movements in the account during themonth of February 2012 which have been brought up to yourattention already.

In the menatime, Pimjo Trust CV has issued Oppenheimer & Co.,Inc. precise instructions during the months of February and March2012 in order to prevent notorious risks.”

On June 22, 2012, FINRA Dispute Resolution Mediation Department informed that Oppenheimer & Co.,Inc. was not interested in mediating.

On July 9, 2012, Luis Alejandro Aguilar Pardo wrote to Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486) the following:

“Mr. McNamara,

I write to you again to request from you again to grant me unlimitedaccess to the account of Pimjo Trust CV.

I remind you of Mr. Zuloaga´s spontaneous confession admittingthe lack of empowerment of the exdirectors while recognizingimplicitly my powers to represent Carisma Prima Limited and,therefore, Pimjo Trust CV: ‘Please be advised that myaforementioned principals will reserve their right to take any and alllegal actions against you in order to reinstate the board of directorsas originally elected pursuant to the applicable statutoryrequirements of Carisma Prima Limited, in view that your actionsare devoid of any legality.’

Messrs. Redmond, Toro and Alfonzo and Ms. Redmond, throughtheir attorney and representative, have confessed and acknowledged





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to all of us in writing and spontaneously that (1) they are not todaydirectors of Carisma Prima Limited, that (2) they require to exerciselegal actions – different from the action in interpleader - to have anunknown authority in an undetermined jurisdiction reinstate them asdirectors of Carisma Prima Limited (perhaps, in any case and underthe best of the circumstances, with effects ‘ex nunc’), that (3) quite‘gipsyly’ they intend to take ‘any and all legal’ actions against me– Luis Alejandro Aguilar Pardo – for them to be reinstated andbecome directors members of the board of directors of CarismaPrima Limited. Additionally, and again quite gipsyly’, theirintention is ‘…to reinstate the board of directors as originallyelected…’ whilst the original board of directors included only andexclusively Luis Alejandro Aguilar Pardo as the sole director andmanaging director. In the case that Zuloaga was referring to themoment when the exdirectors were originally appointed, it must bepointed out that still then Luis Alejandro Aguilar Pardo had fullpowers and authority which have never lost.

The only way for Oppenheimer & Co., Inc. to suffer a risk ( a lab´sspeculation) is if the unknown authority in such an undeterminedjurisdiction do void my appointment as director of Carisma PrimaLimited with effects ‘ex tunc’ since the moment after the initialappointment of the exdirectors but, even so, it would be impossibleby virtue of New Zealand law because it is a fundamental and anessential element for the existence of Carisma Prima Limited to haveat least one director. Therefore, even if considering the effect ofvoiding my appointment or exercise of the office of director ormanaging director, the effects will be ‘ex nunc’

Mr Zuloaga confession coincides with our opinion expressed in myletter to you dated May 7, 2012.

I, therefore, point out again that:

1.- the exdirectors were originally elected by the shareholders ofCarisma Prima Limited and not by Luis Alejandro Aguilar,

2.- the exdirectors were ceased by the shareholders of CarismaPrima Limited and not by Luis Alejandro Aguilar,

3.- the exdirectors would require to start a compulsory mediation





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and an arbitration proceeding instead of those “any and all legal”actions against Luis Alejandro Aguilar.

I trust that you instructed already to close down your office inCaracas, Venezuela and reorganize. I am acting under that premise.”


“Mr. McNamara,

Please, be advised that:

1.- The new Constitution of Carisma Prima Limited has beenregistered with the Companies Office in New Zealand.

2.- The Request for Mediation has been filed with CentroEmpresarial de Conciliación y Arbitraje (CEDCA) on Friday, July13, 2012 at 11:13.

3.- A request for the expulsion of Mr. Jorge Redmond from theHigh Counsil of Universidad Metropolitana was introduced on July13, 2012.”

For reason on confidentiality I am unable to further explain the reasons behind this fourth blockade.


“Please be advised that, in connection with the Request for Mediationhas been filed with Centro Empresarial de Conciliación y Arbitraje(CEDCA) on Friday, July 13, 2012 at 11:13, I have been informedthat all parties have been summoned and served. The first audiencewith the agenda to appoint the mediator has been fixed for July 25,2012 at 11:00 am.

Please find attached the Request for Mediation has been filed withCentro Empresarial de Conciliación y Arbitraje (CEDCA) on Friday,July 13, 2012 at 11:13 for your files.

Please find attached the request addressed to the High Council of





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Universidad Metropolitana for your files.

I trust that you have already shut down Oppenheimer & Co., Inc.´sbranch office in Caracas.”

On July 19, 2012, Luis Alejandro Aguilar Pardo wrote to Allen B. Holeman, Managing Director and ChiefCompliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) et al. via Executive Vice-President andGeneral Counsel Dennis P. McNamara (CRD # 2938486) the following:

“Mr. Holeman,

Please find for your files [Amended] and Reinstated Deed ofCreation of Pimjo Trust CV and the new Constitution of CarismaPrima Limited.”


“Mr. McNamara,

Please find attached the act by which Centro Empresarial deConciliación y Arbitraje (CEDCA) terminated the process ofobligatory mediation due to the absence of the other persons andtheir failure to attend the audience fixed by the Executive Directorof CEDCA.

Pimjo Trust CV is now entitled to initiate the arbitration beforeCEDCA. I imagine, however, that you will not accept an arbitralaward from an arbitrartor in Venezuela and that you would ratherprefer a decission from the U.S. Court for the Southern District ofNew York.

I would appreciate that you inform me of your [decision(s)]regarding the control of the account of Pimjo Trust CV.”


“Please find attached for your records the following documents:

1.- Request for obligatory mediation before Centro Empresarial de





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Concialiación y Arbitraje (CEDCA).

2.- Request made by Jorge Mateo Redmond S. acting as attorney infact and on behalf of all respondents for an unspecifiedpostponement of the audience to appoint a mediator.

3.- Answer by Pimjo Trust CV to the petition made by Jorge MateoRedmond S. acting as attorney in fact and on behalf of allrespondents for an unspecified postponement of the audience toappoint a mediator.

4.- Decision of the Executive Director of CEDCA to terminate themediation due to denial of the required persons to attend theaudience.

I wish to draw your attention to the new unsolicited, voluntary andexpontaneous confessions made Jorge Mateo Redmond Schlageterin his letter to CEDCA.

Mr. Redmond and those other helping him to commit thesemisdeeds, pretended in a mandatory mediation to subject theirattendance the[ ] procedure to receiving answers to four questions.

Those four questions were answered – under protest – in order todefuse their victim strategy. However, they failed to show up.

Questions 1 and 2 – apparently drafted by an English speakingperson – do confess that Redmond and his accomplices have beenremoved as directors of Carisma Prima Limited. Of course, again,the drafter of the question – perhaps for her lack of knowledge ofthe case – included in the question the possibility of being removedas directors from the ‘enterprises’(in plural) the trusts (as if thetrusts had directors) which is another sign of the ignorance of theseindividuals.

From what I may understand, question 1 translates something likethe following: ‘Which is the reason by which Mr Agular feels theneed to unilaterally remove the other directors of the companies /trusts linked to Pimjo Trust CV?’

Conclusion: Redmond and his accomplices are not directors of





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Carisma Prima Limited and have no right to control the account ofPimjo Trust CV.

Question 2 translates something like the following: ‘Who grantedthe power to Mr. Aguilar to take this unilateral and consulteddecision and in what manner that power reflects legally?’

The answer was given but, please, find below two additional issuesfor you to consider.

You must be aware that by letter dated November 21, 2001 I wasentrusted, with the authorization of Mr. Josef Grootkerk Zeldenrustwith the power to take any and all legal decisions concerning theorganization and reorganization of Pimjo Organization. Mymandate has not been revoked.

Please note that the last will of Jorge Redmond Schlageter – whileknowingly the ownership of the shares of Carisma Prima Limited- specifically states that: ‘The shares issued by Carisma Limitedand Carisma Prima Limited do not belong to my Estate.’


“Due to the fact that Oppenheimer & Co, Inc., Jorge MateoRedmond Schlageter, Astrid Kristina Redmond Horn, Rafael JesúsAlfonzo Hernández and Germán Toro Arévalo have refusedmediation and since Oppenheimer & Co., Inc. has failed to file theaction in interpleader, I have initiated legal actions in Venezuela.”

On August 2, 2012, at noon, Executive Vice-President and General Counsel Dennis P. McNamara (CRD# 2938486) circulated his draft of Interpleader Complaint which is attached hereto following the endnotesof this letter.

It is my belief that the action of circulating the draft of Interpleader Complaint was a joint and concertedaction masterminded together with Alfonzo, Toro and Alfonzo as a means of exacting leverage to be usedduring a conciliatory attempt initiated by Ms Carolina Jaimes Branger and Dr. Bernardo Neher Borjas.

Four facts must be pointed out.

The first one is that Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486)





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is aware that he controls all the funds available and existing. So by restricting the account he achieves thepractical effect of depriving Pimjo Trust CV of funds to attend to its defense against Oppenheimer & Co.,Inc. predatory practices.

Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) became aware ofthis fact during a phone call when he requested supporting legal opinions from New Zealand and Dutchattorneys to support his then purportedly cooperative actions.

As we shall below, Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486)refused later on the offer made by Pimjo Trust CV to obtain from New Zealand and Dutch counselssupporting legal opinions alleging that the sole means to solve this conflict was via the Interpleader Action.

The second one is that Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) had been given actual notice that Pimjo Trust CV was not to grant Oppenheimer & Co., Inc.releases nor indemnities. Therefore, no envelope for negotiations were available for Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) in order to mitigate Oppenheimer& Co., Inc. eventual losses.

The third one is that Pimjo Trust CV is entitled to be reimbursed for all those funds that might have been illegally extracted from its accounts, if any.

And the fourth fact is that any funds credited to either account of Pimjo Trust CV would seem “primafacie” owned by Pimjo Trust CV while those funds extracted illegally would have to be reimbursed.

Only by a cooperative conduct of the parties based upon an independent and reliable forensic audit of theaccounts - as it was proposed on February 24, 2012 but refused - would have found and equitable solutionto this unwanted situation. I wish to point out that Pimjo Trust CV was not interested in coming intocontact with matters pertaining to the weaknesses of Oppenheimer & Co., Inc. vis-a-vis the actions of itsagents.

Th conciliatory meeting on August 2, 2012 turned out to be an ultimatum presumably thinking that LuisAlejandro Aguilar Pado was destined to accommodate to their requests. Be it well known that myacceptance to such ultimatum was made under protest and solely for humanitarian reasons.

Since Luis Alejandro Aguilar Pardo first learnt of the existence of the quoted arguments from Redmondand his accomplices on August 2, 2012, he wrote and sent, on August 3, 2012, an email to Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) in the following terms:

“As a voluntary action, independent of the agreement accepted byRedmond on behalf of himself, Toro, Alfonzo, and his daughter,and without modifying or related with what it has been agreed upon





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in writing, I hereby request, in order to protect myself fromeventual actions of kidnapping and extorsion by criminals andirregular armed forces who might know that I have possible controlof such large amount of money, please consider my limited, partial,confidential, revocable, temporary, with effects ex nunc and underprotest, withdrawal as authorized signatory in Pimjo Trust CVaccount A14-0505833-L52.

My request for your consideration and approval is limited to thefollowing: Until further notice, you are excused of following myinstructions regarding purchase and sale (including short sales) ofstocks, bonds, options and other securities, commodities andcommodity futures, on margin or otherwise, on exchanges of whichyou are member or otherwise; to receive on behalf of Pimjo TrustCV or transfer to any person money, securities and similarproperty, and to dispose of same.

No other powers, matters and attributes are included.

This request and your acceptance is confidential and may not bedisclosed to any other person.

My request and the effects of same – approved or not by you – arerevocable as I seem fit.

I consider this request temporary.

The effects shall take place after your acceptance and fron thenforward. All previous instructions remain in force.

My actions are taken under protest since other people might assumethat I have access to those funds and because other reasons.

I only agreed to what it was written and signed by Redmond andAlfonzo. They unconditionally accepted my acceptance pure andsimply. What I am doing in this email does not alter anything towhich I have agreed upon.

Be it well known and understood that the party who accepted theterms of the agreement accepted today is Luis Alejandro AguilarPardo.





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The contract was a “take it or leave it” contract (contrato deadhesión) in which drafting I did not have any participation.

The phrase “Facing the reality that Luis Alejandro Aguilar does nothave confidence in the above mentioned persons, and that thecontrary is the same,…” is their own creation and responsibility.”

On August 15, 2012, in Boca Raton, Florida, at the lobby of the building where Boca Raton branch officeof Oppenheimer & Co., Inc. are or were then currently located, none of the other parties assisted toadvance in the execution of the ultimatum - agreement.

It is worthy to point out that Executive Vice-President and General Counsel Dennis P. McNamara (CRD# 2938486) prohibited me from entering into Oppenheimer & Co., Inc. premises to deliver the current validdisclosure of foreign structure for purposes of compliance with the Internal Revenue Service together withmandatory W-8 forms and that prohibition just followed Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486) unseemly suggestion that matters should be dealt with at theirillegal premises located in Caracas, Venezuela, with the participation of Caracas Office Branch Managerand Broker John Gayle Pettus Jaso (CRD # 2415914) who is a main contributor to these wrongdoings.

Based upon the draft of the Interpleader Complaint - biased, plagued with mistakes and errors in facts andpersons) circulated by Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) on August 2, 2012, the Interpleader Action seems to be based upon one allegation.

It must be pointed out that none of the exhibits mentioned in the draft were circulated by Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) on August 2, 2012.

It seems that Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486)supports his interpleader action upon dispe rse texts quoted from the letter dated February 9, 2012 towhich Pimjo Trust CV has had no access.

The text manipulated is embodied in paragraph 21 of the draft of the Interpleader Complaint:

“21. More specifically, on February 9, 2012, Messrs Redmond,Hernandez and Arevalo and Ms. Redmond Horn wrote toOppenheimer advising that they were "very concerned" regardingthe recent actions of Mr. Aguilar to "undermine the structure" ofPimjo Trust, including the purported unilateral removal of them asdirectors of Pimjo Trust. The February 9th letter also alleges thatMr. Aguilar, in July of 2011, announced that he was resigning fromPimjo Trust. However, despite his alleged resignation, the letteralleged that Mr. Aguilar has "has taken steps that have not been





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authorized by the Board of Directors." The letter also requestsOppenheimer to restrict any further transactions in the account. Acopy of the February 9, 2012 letter is annexed hereto as Exhibit D.”

While it is not possible to pass an opinion upon disperse quotations, being “very concerned” and to“undermine the structure” - that Executive Vice-President and General Counsel Dennis P. McNamara(CRD # 2938486) admits in its draft that does not understand it -, is a biased appreciation.

Indeed, the draft of Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486)failed to mention that signatories of the aforementioned letter are being charged of white-collar criminalactions with the intention to defraud financial institutions, knowingly falsifying financial statements withthe intention to defraud financial institutions, the creditors of the company, the shareholders of thecompany and the public in general while exercising their offices as directors of a Venezuelan company andone of them incurred in unbecoming actions of embezzlement and fraud while serving as officer of a USAcorporation.

While I did not have the authority to revoke their mandates in the victimized Venezuelan companies, I hadthe legal and fiduciary duties to protect Carisma Prima Limited and Pimjo Trust CV both under the lawsof New Zealand and under the Venezuela Code of Ethics for the legal professionals.

Nothing was mentioned of the existence of the Plan of Revitalization of Pimjo Organization approved onJanuary 17, 2012 and the precautions and check and balances incorporated to successfully and withtransparency achieve the mandate of restoring the organization to a sound operating group of entities underthe instructions of founder Josef Grootkerk Zeldenrust. Not even mattered the fact that Oppenheimer &Co., Inc. outside counsel Sullivan & Cromwell and other outstanding US and New Zealand professionalswere participating or helping in the design and execution of the Plan of Revitalization of PimjoOrganization.

From information and belief, no exdirector has ever read the Plan of Revitalization of Pimjo Organizationdated January 17, 2012.

While being portrayed as an individual disturbing Oppenheimer & Co., Inc. with multiple calls and emails,the real fact of the matter is that my actions were aimed to create interdependence to equalize the powersof Oppenheimer & Co., Inc. due to its tactics of avoidance, despise, and plain bad manners; all of whichwere blatant and conspicuous violations of Oppenheimer & Co., Inc. Code of Conduct and Business Ethicsfor Directors, Officers and Employees.

The tactic of creating interpendence was successful and equalized the misuse of power exerted byOppenheimer & Co., Inc.

The draft of the Interpleader Complaint circulated by Executive Vice-President and General Counsel





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Dennis P. McNamara (CRD # 2938486) supported his interpleader action upon another text quoted fromthe letter dated March 26, 2012.

"We must also reserve our right to question any decision on yourpart to give [Mr. Aguilar] access to the funds without allowing usto make a proper review of documentation which you indicateempowers him to make the changes he apparently made."

While it is obvious that any party always asserts a given right or privilege, this quote is curious andtimorous. It seems that - even though Oppenheimer & Co., Inc. is not a public library - what Redmond andaccomplices were requesting from Oppenheimer & Co., Inc. “was allowing us to make a proper reviewof documentation which you indicate empowers him to make the changes he apparently made.”

It is quite obvious to conclude that they lack any documents at all. Luis Alejandro Aguilar Pardo knowsfor sure that he has supplied and delivered timely and clearly every conceivable piece of information anddocument that have been by Oppenheimer & Co., Inc. and even those which have not been requested bythe latter.

The real unsurmountable problem for the exdirectors is that they are uncapable to do anything without thecooperation of Carisma Prima Limited. Section 10 of the Companies Act of 1993 of New Zealand lists theessential requirements for the existence of a company as follows:

“10 Essential requirementsA company must have—(a) a name; and(b) 1 or more shares; and(c) 1 or more shareholders, having limited or unlimited liabilityfor the obligations of the company; and(d) 1 or more directors.”

The sentence “to make the changes he apparently made” indicates that they have no knowledge about thestatus quo and that they simply embarked in a fishing expedition to collect information.

A word of caution should be raised since the probability that usurping and arrogating oneself attributions,identities or characters not properly granted with the intention to defraud someone else might beconsidered as a criminal offense is larger than zero.

It must be pointed out as well that all corporate procedures to effectuate the removal of the exdirectors oftheir respective offices and revocation of the powers of attorney and ratification of Luis Alejandro AguilarPardo as Sole Director and Managing Director were thoroughly, carefully and impeccably complied with.





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Increasingly disturbing is the omission by Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) of the fact that Oppenheimer & Co., Inc. and its employees Oppenheimer& Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C. Mendez de León(CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and CaracasOffice Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) were signatories of theNovember 29, 2001 Resolutions Unanimously Adopted by the Partners of Pimjo Trust CV and that - underconflict of interests - Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918) wasappointed as attorney in fact in that instrument. However, it was expressly contemplated that therepresentation as attorneys in fact were to exercised by two of the attorneys in fact simultaneously.

The conclusion of the above paragraph is that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.)Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch BrokerRussell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager and Broker John GaylePettus Jaso (CRD # 2415914) did have actual knowledge of the revocation of the power of attorney datedJuly 19, 2001, the limitation of the powers granted and they failed to report the corporate structure in whichthey actively participated to Oppenheimer & Co., Inc.

Even though the matter of my desire to discuss my eventual intentions to resign as director of CarismaPrima Limited has been manipulated, it has no bearing on or connection with the subject matter at issuesince - even under the denied assumption that I had indeed resigned - the shareholder of Carisma PrimaLimited during the Special Meeting held on January 17, 2012 not only sustained my continuous exercisewithout interruption of the office of Sole Director and Managing Director of Carisma Prima Limited,ratified all my actions as duly appointed and elected officeholder and then - the Special Meeting ofShareholders of Carisma Prima Limited - ceased the former directors.

None of the exdirectors has attempted to redress the decision of the Special Meeting of Shareholders ofCarisma Prima Limited of January 17, 2012.

None of my actions were adopted before January 17, 2012.

On the other hand, and from a practical standpoint, had I not been a director and officeholder of CarismaPrima Limited, what was the purpose of my presence at the meeting on December 13, 2011?

On August 6, 2012, Luis Alejandro Aguilar Pardo sent the following email to Executive Vice-Presidentand General Counsel Dennis P. McNamara (CRD # 2938486):

“Mr.(*) Dennis,

I wonder if you would send me a copy of the February 9, 2012 thatMessrs Redmond, Hernandez and Arevalo and Ms. Redmond Hornwrote to Oppenheimer and mentioned as Exhibit in your draft of





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Interpleader Complaint.

I wonder if you would send me a copy of the March 26, 2012 letterwrote by counsel for Messrs Redmond, Alfonzo, Toro and Ms.Redmond to Oppenheimer and mentioned as Exhibit in your draftof Interpleader Complaint.

I would like to know what demands I made that are unreasonableor against the [well-being] of the portfolio.

It is simply impossible that I had resigned as director of PimjoTrust. It is just impossible.

I am not [opposed] that you allow them to make a proper review ofdocumentation. If this is the problem, please tell them to make a listof the documents they wish to review and everyone is happy. I willreserve confidential all and every letter and communicationsexchanged between Oppenheimer and us. But any documentspertaining oficially to Pimjo Trust CV or Carisma Prima Limitedmay be inspected by them.

So ask them to make the list of documents they wish to see, Iauthorize those corporate documents, I will ask for approval tosurrender those documents to the exdirectors for their review.

On the other hand, you have in your hands my request to considermy voluntary action, independent of the agreement accepted byRedmond on behalf of himself, Toro, Alfonzo, and his daughter ofAugust 3, 2012 that satisfies their request: I simply do not haveaccess to the funds.

They even had the means and rights to force me to do it themandatory mediation and subsequent arbitration in a matter ofhours. I am very impressed for this paragraph of your complaint:

“Counsel’s letter again references several alleged resignations byAguilar as a director of Pimjo Trust, as well as Aguilar’s allegedimproper refusal to make books and records of Pimjo Trustavailable to its directors, and the subsequent alleged wrongful





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removal of all of Pimjo’s Trust’s directors, aside from himself. Inclosing, counsel’s letter advises Oppenheimer, “We must alsoreserve our right to question any decision on your part to give[Aguilar] access to the funds without allowing us to make a properreview of documentation which you indicate empowers him tomake the changes he apparently made.”

If I resigned, if I really refused to make books and records of PimjoTrust available to its directors, if I wrongfullly removed all ofPimjo Trust´s directors, aside from myself, they have had alwaysthe right to force me to do it the mandatory mediation andsubsequent arbitration in a matter of hours.

One point: One thing is to review the documents (which frankly Iimagine that they do not have a clue which ones are) and anotherthing is to transfer the custody of the records to a peson chargedwith unbecoming actions.

In a nutshell; I am willing to grant them access to the corporatedocumentation of Pimjo trust CV and of Carisma Prima Limitedupon approval by my constituents and Oppenheimer was thecreator of “this complex multi-national corporate structure” andyour employees managed it.

Please send me the U4 filings of the following brokers:

Francois C. R. Mendez de Leon (Central Registration Depositorynumber 331918) now deceased ,

Branch Manager John Gayle Pettus Jaso (Central RegistrationDepository number 2415914) and,

Russell Morris Dallen Jr. (Central Registration Depository number2445026.

Best regards, Mr. McNamara.

P. S.: I am sure if I address you as Dear Dennis, I will get thedocuments tomorrow at noon as you did with Dear Jorge.

(*) I have been asked to address to you as Mr. I accepted under





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protest. You decided not to write to me anymore since the daywhen I sent you the email of March 28, 2012 regarding theinformation received from Ms. Michelle L. Sullivan, VicePresident, Director of Fiduciary Compliance, IWM & CorporateCompliance Assessment Team, UMB Financial Corporation.”

Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) showed up onAugust 10, 2012 stating “ The Oppenheimer offices in Boca Raton cannot be used for this meeting. Isuggest you contact Johnny Pettus who can help arrange a suitable meeting place in Caracas.”

On that very same day, August 10, 2012, Luis Alejandro Aguilar Pardo sent the following email toExecutive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486):

“Dear Mr. Dennis,

Thank you for your email.

I imagined your answer. It was made for you to answer exactlywhat you did end evidencing FINRA and SEC your lack ofcooperation.

As to the city Caracas, either you have not learnt to read or youskipped certain courses in law school about contracts or you aresimply biased and [biased]in favor of your dear exdirectors.

What you should do is to allow your dear exdirectors to examinethe documents as you said they asked you.

If you are not allowing the use of your offices in Boca Raton andif you are not planning to attend, what is it your business to suggestCaracas and invlove John Pettus in this matter exactly contrary tomy instructions?

I am surprised that you now write to me but, frankly, think betterthe next time if you really have something constructive tocontribute.

By the way, I am making records of all my calls and the ones youdo not answer. I read at the SEC complaint filing form if you havebeen cooperative. I called yesterday you, Holeman and Pettusbefore the deadline of 9:00 am and you did not take my call and





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missed again the deadline.”

And later that day:

“Dear Mr. Dennis,

What a refreshing gift today…

The legal Obersturmbannführer of Oppenheimer & Co., Inc. isopenly telling a disgruntled client to meet in Caracas (where heconfessed having an illegal office and thus mislead SEC on form10-K) with a broker that is operating illegally in Venezuela andwho has reincided in violations already found by FINRA andfurther refusing to participate to solve a matter of a corporatestructure that the very same Oppenheimer created and manageduntil November 4, 2011 within their line of businesses as describedin form 10-K.”

And later that day:

This is a confidential message.

If you defect on confidentiality, I will defect swiftly.

I suggest a truce. There is no sense in causing more damages thanthose caused already.

You treat me with respect and I will treat you with respect.

There are fundamental problems to be addressed and there is nosense in exerting damages. Control of the account is the least of mylegitimate interests.

The [successful] execution of the Plan of Revitalization is myobjective.

Refunds if applicable, compensation of damages, reasonableattorneys´fees and fair outcomes are on the agenda.

Assurances that assets are tainted free is of the upmost importance.





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I think that there are large envelopes of solutions acceptable toeveryone and enforceable to any renegade.

I understand that good mediators may terminate this conflict.

This technique is known as the humanitarian tit-for-tat, allowingthe possibility of ending an endless chain of defections by openinga new nice opportunity of cooperation to allow parties to correctfor coyuntural unforeseen circumstances.

Please note that it is forgiving and not a sign of weakness but areassurance that upon your eventual defection, I will be fullyinduced to execute my strategy until the very end against allpersons involved in unbecoming behaviors, male of female. (Termsin red are technical terms from Game Theory).

You have already lost your leverage with the [threat] of the actionin interpleader.

If you need to correct something, I will cooperate for you toachieve your legitimate interests provided Pimjo Trust CV getswhat it belongs to it.

Playing TAPS or hearing its lyrics is senseless:

Day is done, gone the sunFrom the lakes, from the hills, from the skyAll is well, safely restGod is nigh.Fading light dims the sightAnd a star gems the sky, gleaming brightFrom afar, drawing nearFalls the night.Thanks and praise for our daysNeath the sun, neath the stars, neath the skyAs we go, this we knowGod is nigh.

As a token of good will, I suggest you and Holeman do not eventhink to come to Caracas. This suggestion may be valid for severalyears.”





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On August 11, 2012, Luis Alejandro Aguilar Pardo sent the following email to Executive Vice-Presidentand General Counsel Dennis P. McNamara (CRD # 2938486):

[Terms in red are technical terms used in Game Theory. Quotedand author credits have been ommitted. There is no intent ofplagiarization, therefore, consider all ideas as someone else´s andnot mine].

Concerning my offer of yesterday, August 10, 2012, at 11:03 pm,it must be understood that whatever actions are taken under andduring the truce must be transparent, ethical, objetive, legal, honest,truthful, loyal, in good faith, and respecting the rights of evryoneinvolved including Messrs Redmond, Alfonzo and Toro and MsRedmond.

I even offer to assist drafting a common interpleader complaint andfiling it, supplying all material obtainable via discovery, cleaningall issues that might be disruptive or misleading to confuse the trial,agreeing on the fundamental issues that have to be resolved, waiveall further steps, and [submit] the controversy to the U.S. Southern[District] of New York in as many hearings as possibly and in goodfaith we can and admit the [verdict] of the court without appeal.

If [verdict] of the court favors the exdirectors, well, so be it. If the[verdict] of the court favor Pimjo Trust CV represented by me,well, so be it.

Due to the fact that all exdirectors and myself have places to livein Southern Florida, Oppenheimer has a branch in Boca Raton, (Ibelieve that the account should have beeen lodged in Boca Raton)we might think in submitting the controversy to the jurisdiction ofthe US Disctrict Court with competence in Southern Florida. I haveno clue what district it is.

All open, transparent and respecting the legitimate interests ofeveryone, including the exdirectors and the beneficiaries of thegrants of Pimjo Trust CV.

I even offer to exclude from the controversy any positive or adverseeffects in court or elsewhere that might arise from authorizing those





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well late grants owed by Pimjo Trust CV to the already approvedbeneficiaries. I will not sign them but I will grant inmunity fromtrial or claims, waive claims and release and save harmeless anyperson who do help in good faith to make available those funds tothose beneficiaries I have mentioned.

Dear Dennis, and at this time I mean it, I think in the future not intomorrow. It might happen that tomorrow or one month from todaywill be our last move and who has benefited from our previousmoves?. More important than the present is the future. The futureof Pimjo Trust CV is greater and better than the present interests ofall of us. It is possible that the iteration may not continue. Neverdefecting when meeting a tit-fot-tat strategy is the best collectiveattitude which leads to the best payoff available and mutualcooperation. Society at large benefits at the end of the conflict.

Please, help me change the payoffs. You may think the followingis bravado but this conflict is already solved. It only takes moreiteration and it is finished.

Even though, it might be considered by you that the followingstatement is an insencere expression unsupported by my realconvictions, I do believe in teaching and helping others to careabout each other. I adhere to reciprocity and believe in it andpractice it.

I wish to recognize you as an extraordinary attorney and gentleman:if I am wrong or if I have committed any unbecoming action,please, let me know and I will mend my wrongdoings.

Robert Alxerod wrote:

‘The advice takes the form of four simple suggestions for how todo well in a durable iterated Prisoner´s Dilemma:

Don´t be envious, Don’t´be the first to defect, Reciprocate both cooperation and defection, Don´t be too clever’





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I hereby disclose that my strategy is "Tit-for-Tat" and, therefore, asthe essence of "Tit-for-Tat" is instantly forgiving, my actions willbecome immediately cooperative upon such person abandoningpredatory and vulturous actions and becoming cooperative. Myactions shall replicate your actions.

On August 10, 2012 at 11:03 pm, I adopted and switchedtemporarily to “Generous Tit-for-Tat” strategy and I am offeringone single action to stop the cycle of retaliation andcounterrretaliation.

‘The obvoius way to stop a cycle of retaliation andcounterrretaliation is for one side to stop retaliating. ‘Alwaysforgive your enemies,’ said Oscar Wilde, ‘nothing aanoys them somuch.’ It aanoys them because it removes their justification forcontinuing with the fight’

On August 14, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) sent the following email:

“You will not be admitted to our offices in Boca Raton.”

Since August 14, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) has remained hidden.

It is Pimjo Trust CV belief that Oppenheimer & C., Inc. and its agents are engaged in an unjust exactingto the detriment of Pimjo Trust CV by misusing their position, using threats of unjust damages to PimjoTrust CV, impeding Pimjo Trust CV’ s defense and demanding exorbitant behaviors from Pimjo Trust CVby coercion and illegitimate and unlawful tactics of avoidance, undue exertion of power, misleading theclient and hiding vital information to Pimjo Trust CV.

25.- [Missing due to my mistake when drafting the online complaint submitted to FINRA and SEC.However, this section will be used to show the different requests and instructions issued to Oppenheimer& Co., Inc.which have not been complied with ].

It is important to point out that the following requests or questions have been unfulfilled or unansweredand during the period of 225 days since my first interaction with Oppenheimer & Co., Inc. up to andincluding September 3, 2012. It also must be pointed out that, as of today, the client Pimjo Trust CV hasno information on any aspects concerning its assets.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Date (at least) InstructionsJanuary 23, 2012February 12, 2012

Request to incorporate my signature as authorized signatory.

February 1, 2012February 12, 2012

Severance of all contacts with Venezuela and Cuba.


Reuqest to change the branch where the account is lodged at from Caracasto Boca Raton, Florida, USA.

February 1, 2012 Direct contact without using Oppenheimer Caracas Branch Office asintermediary.

February 1, 2012 Stop all wire transfers out of the account until further notice.February 1, 2012 Receive from Oppenheimer & Co., Inc. instructions as to how to give wire

transfer instructions directly to Oppenheimer & Co., Inc.February 1, 2012 Request to undergo full “Know your client” and “Know your client´s

clients” inquiryFebruary 1, 2012 Request of not engaging Pimjo Trust CV in trade or business within United

States of America, The Netherlands and New Zealand.February 1, 2012 Authorization to Change Address.February 1, 2012February 12, 2012

Request to receive the contractual terms of the account with Oppenheimer& Co., Inc.


Request to assign to Pimjo Trust CV a temporary account officer as a directcontact while we conclude our internal audit


Request to identify who has authority to take trading decisions and who havetrading authority in the account of Pimjo Trust CV.


Request to disclose and send via email existing trading uthorizations for theaccount of Pimjo Trust CV.


Request to disclose the levels of authorized risks in the account of PimjoTrust CV.

February 1, 2012 Request to disclose the identities of the persons authorized as signatories inthe account of Pimjo Trust CV since its inception status quo October 11,2001 until January 31, 2012.


Request to determine goals and investmens strategies for the account ofPimjo Trust CV.

February 12, 2012March 25, 2012

Request to obtain from John Gayle Pettus Jaso details of the investmentstrategy being applied to Pimjo Trust CV.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

February 12, 2012 Request to determine risky assets within portfolio.


Request to issue credentials to access and log on to Pimjo Trust CV accountat your website.

February 1, 2012March 17, 2012

Note and file W-8BEN and W-IMYs together with FEIN numbers.

February 12, 2012 Request to disclose all existing accounts of Pimjo Trust CV.February 12, 2012 Notice of revocation of any eventual existing trading authority of John Gayle

Pettus Jaso and Alfredo Quintana or Russ Dallen or any other broker orofficer of Oppenheimer & Co., Inc.

February 12, 2012 Request to issue new trading authority.February 12, 2012 Request of statements of account at UMB Bank NA, account number

26201338505041.February 12, 2012 Request to disclose the authorized signatories in account at UMB Bank NA,

account number 26201338505041.February 12, 2012 Notice of revocation of all signatories in account at UMB Bank NA, account

number 26201338505041March 13, 2012March 19, 2012

Request of copy of letter sent by Redmond and accomplices on February 9,2012.

March 25, 2012 Explanation of investments decissions involving more than US$ 1.500.00,00made while the account was blocked.

March 28, 2012 Request to explain why are you avoiding delivery of information regardingthe account at UMB Bank NA, account number 26201338505041 after theexplanations given by Ms. Michelle L. Sullivan, Vice President, Director ofFiduciary Compliance, IWM & Corporate Compliance Assessment Team,UMB Financial Corporation.

March 25, 2012 Request of explanation why so much liquid assets were held in the account($ 4.104.536,55 in cash by the end of January 2012 which is 34,85% ofTotal Value Asset)List of all wire transfers made.

April 19, 2012 Disclosure of all my future actions.

Regarding Carisma Prima Limited.

On Friday, April 20th 2012, after the close of business in New York, USA,the limited offer dated Wednesday, April 14th 2012, to appoint Redmonds,Toro and Alfonzo as directors of Carisma Prima Limited shall expire.

The offer made by Carisma Prima Limited on April 11th 2012 to grant thema limited power of attorney was both refused and later on revoked.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

I hereby disclose that I have approached the National Enforcement Unit ofNew Zealand to request authorization to appoint the Redmonds, Toro andAlfonzo as directors of Carisma Prima Limited even under a regime ofunanimity and safeguard against directors deadlocks.

Regarding Pimjo Trust CV.

On Friday, 20th April 2012, at 1500 Caracas time, I will visit the offices ofJorge M. Redmond Schlageter, at La Urbina, Caracas, Venezuela. The mainobjective is to start the mandatory mediation proceedings contemplated inthe current Deed of Creation of Pimjo Trust CV.

Further actions are intended to take place at CEDCA in order to compell theRedmonds, Alfonzo and Toro to solve this conflict via mediation andarbitration. Indeed, I will offer them to reduce the mandatory period of 80hours to 8 hours and to submitt the matter to arbitration to be solved in 48hours.

Therefore, be it known by all parties involved that this conflict about theauthority over and control of the account of Pimjo Trust CV at Oppenheimer& Co., Inc. may be solved definitively and permanently by mediation andarbitration in 72 hours.

It is my bona fide belief that the Redmonds, Alfonzo and Toro, at least,might or possibly be trying to hide actions, at least, involving the use of US$35,633.33. In order to do that, Redmonds, Alfonzo and Toro are willingforce Pimjo Trust CV to spend between US$ 600,000.00 to US$1,800,000.00 in legal fees and expenses pursuing the interpleader action.Even if they were directors today of Carisma Prima Limited, they areactually and expressly prohibited to allow this interpleader action to takeplace, not because of the action itself but, because they had the duty toprotect the assets of Pimjo Trust CV, They have the fiduciary duty to avoidspending this money in the interpleader action. The difference of US$35,633.33 to US$ 1,800,000.00 is 192,235%. Worse of: the Redmonds,Alfonzo and Toro have, cruelly impeded that the actual beneficiaries of thegrants and gifts of Pimjo Trust CV – even a woman alledgedly in an hospicein Sarasota, Florida, USA – receive the contributions.

After the actions to be taken in Caracas, Venezuela, I will come back toUSA and, on behalf of Pimjo Trust CV, I will file a claim before FinancialIndustry Regulatory Authority on the grounds that the interpleader action is





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

being used inadequately and, possibly, with the objective of impeding myaccess to the information regarding the account at UMB Bank NA.

Regarding Oppenheimer & Co., Inc. branch office and branch manager inCaracas, Venezuela.

I will file a petition for investigation of Oppenheimer & Co., Inc. activitiesas an unauthorized branch of a foreign brokerage house within Venezuela,alledgedly and knowingly using a certain legal person known asBRISBANE, MENDES DE LEON, PETTUS Y ASOCIADOSREPRESENTANTES DE OPPENHEIMER & CO. INC., sociedadmercantil, inscrita en el Registro Mercantil de la Circunscripción Judicialdel Distrito Federal y Estado Miranda, en fecha 27 de mayo de 1974, bajoel N° 147, Tomo 25-B.

I will file petitions for investigation of Oppenheimer & Co., Inc. activitiesin Venezuela connected with eventual lack of diligence in the application ofcompliance standards of vigilance to prevent legitimation of capitals andother objectives.

The petitions will be filed with the Superintendencia de InversionesExtranjeras, the Superintendencia de Instituciones del Sector Bancario,Superintendencia Nacional de Valores, Comisión de Administración deDivisas and Oficina Nacional Antidrogas.

No action will be taken with Servicio Nacional Integrado de AdministraciónAduanera y Tributaria since it will preclude Oppenheimer & Co., Inc.

To protect your clients assets, i hereby request to disconnect allcommunications links and sofware access points between your offices incaracas and wherever your mainframe is located.

Regarding Oppenheimer & Co., Inc. I will file a claim with a claim beforeFinancial Industry Regulatory Authority covering all the aforementionedevents, actions and omissions and the violation of Oppenheimer Code ofConduct and Business Ethics and I will request an investigation by the NewYork Stock Exchange LLC concerning the abovementioned events.

Regarding Chocolates El Rey, C.A. and since all these matter has its originand inception in the alledgedly lack of character of just one and only singleand sole individual to manage the funds of a nonprofit organization because





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

presumably involved in knowingly alduterartion of financial statements toobatin loans from financial institutions and other grievances as fullyexplained in Aviso al Comisario de Chocolates El Rey, C.A. dated March23, 2012, a petiton for action will be filed with Superintendencia deInstituciones del Sector Bancario and Fondo de Protección Social de losDepósitos Bancarios.

I hereby disclose that as the Compliance Officer of Aguilar & AguilarLimited, I have already shared twice information concerning the eventualand to-be-determined-crimes against financial institutions with Mercantil,S. A., Banco Universal, Banco Caroní, Venezolano de Crédito, S. A., BancoUniversal, Banco Exterior, BANESCO, Banco Universal andVENECREDIT, Bank and Trust Ltd.

Actions at Superintendencia de Instituciones del Sector Bancario and Fondode Protección Social de los Depósitos Bancarios are aimed to demandinformation as to what actions have the aforementioned banks taken as aconsequence of facts learnt from another Compliance Officer.

Regarding Jorge Redmond Schlageter, Astrid Kristina Redmod Horn,Rafael Alfonzo Hernández and Germán Toro Arévalo and in accordancewith the exisiting Masters Agreements and Deeds of Creation andConstitutions in force, a mediation request will be made in order to resolvethe issues of eventual slander, defamation, damages and civil liability.

Upon failure to accept mediation and arbitration proceedings, I will file apetition for investigation of activities which might be in violation of Ley deDefensa de la Soberanía Política y Autodeterminación Nacional foralledgedly using funds of a nonprofit foreign organization for objectiveswhich will be determined in such investigation. It is my understanding thatMinisterio del Poder Popular para Relaciones Interiores y Justicia.

Regarding Jorge Redmond Schlageter and Astrid Kristina Redmod Horn andin accordance with the existing Master Agreement, a mediation offer –instead of criminal actions - will be presented in order to solve the damagescaused by a meeting alledgedly convened by Ms. Astrid Kristina RedmondHorn in which, alledgedly, she qualified me as an unbecoming person interms later alledgedly repeated by Luis Ugalde, s.j. and which caused thatthe said Ugalde refused my proposal of him to appoint two or three or fourindependent individuals to whom granting them the power and authority to





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

move the account of Pimjo Trust CV for humanitarian reasons.

Regarding Germán Toro Arévalo and in accordance with the existing MasterAgreement, a mediation request will be made in order to resolve the issuesof damages and civil liability.

April 30, 2012 Request to report to me if there is any contacts between Pimjo Trust CVaccount at Oppeneheimer & Co., Inc. and/or at Oppenheimer / Co., Inc. –UMB Bank NA account with Finter Bank Zurich (Claridenstrasse 35, 8001Zurich, Switzerland), account 1.000779.01 of APV Foundation, IBAM: H370825 6100 0779 0. SWIFT FBZUCHZZ.

April 30, 2012 Request to mediate our apparent differences.The objectives of the mediation were:

1.- Solve once and for all the recognition erga omnes of my legitimaterepresentation of Pimjo Trust CV. Logic precludes any other resut.

2.- Deactivate your threat of an interpleader action which is the onlypossible action that benefits only the exdirectors who were ceased for havingincurred in corruption practices within the meaning of the InternationalChamber of Commerce recommendations, by obstructing the mediation andarbitration procceedings.

3.- Repair economical damages caused by your actions to Pimjo Trust CV.

4.- Surrender all information - financial and otherwise - concerning Pimjo,S.A., Pimjo Trust CV and all accounts that are or were ever opened withFanhestock & Co., Inc., Oppenheimer & Co., Inc., UMB Bank, NA or anyother and actively cooperate in determining (i) whether or not theOppenheimer Caracas Branch Managers mishandled resources of Pimjo,S.A. or Pimjo Trust CV (no Clinton “definitions”, please), (ii) how theaccounts were used by your Caracas Branch Managers withoutauthorizations, (iii) whether or not the accounts were connected with thetrnsactions exposed in NYSE HEARING BOARD DECISION 06-82 of June27, 2006, (iv) whether or not the accounts were connected with PEPs, (v)whether or not the accounts were connected with “tainted money” and (vi)whether or not the accounts were connected with any organization withpolitical objectives.

5.- Surrender all information – financial and otherwise – concerning anyaccount open in Venezuela banks by John Gayle Pettus Jaso in Banco del





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Sol or any other entity and actively cooperate in determining whether or notthe Oppenheimer Caracas Branch Managers mishandled resources of Pimjo,S.A. or Pimjo Trust CV.

6.- Intervene your Caracas Branch Office, close your Caracas Branch Officeand either reopen it under proper authorizations or leave having fulfilledwith your tax obligations.

Please, read well the clauses governing the mediation since there are certainattributes that might be of your interest.

This invitation has not been extended to the exdirectors since they are boundby the mediaition procedure already initiated by me. However, theirresponsabilities have shifted since I personally make them moral andethically responsible for the death of my partner Luis Enrique Dávila Pérezon April 26, 2012 who endured to the limit the sufferings induced by theexdirectors and their counsel. There are now a widow and four orphanchildren in their account.

Please note that your next action must be cooperative in order to fulfillconstructively “tit-for-tat”.

It is my intention to transform this conflict into a constructive process andavoid destructive actions.

April 30, 2012 Invitation to Exert Preemptive Corrections.

Please find attached the draft of the document to be delivered to the Ministryof Interior and Justice of Venezuela on Wednesday, May 3, 2012.

You are hereby invited to make any comments, suggest ideas, and ask forcorrections of facts, rationales or conclusions.

Your comments will be received until Tuesday, May 1, 2012 at 24:00 hours.

This document is being delivered to you since you reacted this morningcooperatively by granting a two week extension. Exdirectors are not beingparticipants of this action because they have behaved unbecomingly.

I hereby reiterate my offer to mediate our apparent differences. You havenothing to loose.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

I also reiterate that you have rights to be treated fairly. If you consider anyof my actions unbecoming, please address the issue directly with CarlosIgnacio Aguilar Lopez at [email protected].

April 30, 2012 Offer of legal opinion to be issued by independent New Zealand solicitor /barrister covering those issues required by Oppenheimer & Co., Inc.

April 30, 2012 Offer of legal opinion to be issued by independent Dutch attorney coveringthose issues required by Oppenheimer & Co., Inc.

May 4, 2012 Questions to John Gayle Pettus Jaso.I wish that you never again send me an email or any type of communicationabout Pimjo Trust CV addressed as well to the Redmonds, Alfonzo, Toroand Zuloaga. I have drawn a clear line between their actions and mine andthey are mutually exclusive. There are no grays in this conflict: there is, atleast, one party who is lying and cheating. I do not know if you are sending your email with or without McNamara´sparticipation and/or consent. Since you are still employed by Oppenheimer& Co., Inc., acting as its Caracas branch manager and transmittingconfidential information, I assume that you represent Oppenheimer & Co.,Inc. I believe that your report is as mediocre as the ones presented by Mendes deLeón. Considering the magnitude of the problems on the table, I frankly donot understand what the intentions of Oppenheimer & Co., Inc. are bysending this information. Please specify what value you are referring to. Please specify what assets are risky. Please specify unrecognized losses. Please specify what actions have you taken to avoid exposure to risky assets.Please specify your investment strategy. Please specify your investment guidelines. Please disclose your earnings and fees. Please send me the statements of all the accounts of Pimjo Trust CV ofFebruary, March and April 2012. I believe that you carry the heaviest load of responsibility for the events thatI have witnessed since October 2011. Unfortunately, you must understandthat it is difficult if not impossible to believe you and that is an inmenseobstacle for a final, complete, permanent and definitive solution of all theissues involved in this matrix. I am sure that it has not escaped from your chain of thoughts theconsideration of how strange, incredible and cruel are the circumstances thatwe are living. The only missing scene in this movie is the next appearanceof an ODESSA representative from Patagonia, Argentina, claiming rights





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

over the assets of Pimjo Trust CV. I have many questions and since you are reporting I will make the questionsand expect that you answer them. What personal or professional experiences have you had with Mr. Toro thatmight support his so negative and denigratory opinion about you? Please disclose if the Redmonds, Alfonzo and Toro have referred to me asa dishonest person. Please disclose if the Redmonds, Alfonzo and Toro have imputed me of anycrime, offense or wrongdoing ever in my professional life. Why Mr. Mendes de León reported a value of the portafolio of Pimjo S.A.before July 19, 2001 and you report so different numbers now? Who orchestrated the actions of July 19, 2001 and what was yourparticipation? Please surrender and return to me the Participation Certificate issued in yourname on July 19, 2001 for 24,999975% of Pimjo Trust CV. Who paid the fees and expenses billed by Amicorp and upon whoseauthorization? Who pays now the fees and expenses of Amircorp and upon whoseauthorization? Who did authorize the transfer of the assets from the account of Pimjo S.A.to the account of Pimjo Trust CV on October 11, 2001? Why did you open the account of Pimjo Trust CV having had actualknowledge that the transactions of July 19, 2011 had been challenged by Mr.Grootkerk himself and I had personally confronted Mendes de León for hisactions? Who did authorize Mendes de Leon, Dallen and you (hereinafter the“Oppenheiemer Caracas Managers”) to become limited partners of PimjoTrust CV and to receive almost 25% participation interests each as limitedpartners of Pimjo Trust CV? Who did authorize the transfer of the ownership and control of the assets ofPimjo S.A. to Stichting Panthalassa? Who did own and control Stichting Panthalassa? Who did give you the advice to rupture the wishes of Mr. Grootkerk byaltering the effects of his last will and giving away 75% of the wealth of Mr.Grootkerk to the Oppenheiemer Caracas Managers? Please, show me the authorization from Mr. Grootkerk that gave youauthority to create Pimjo Trust CV and to transfer control and ownership ofthe portfolio of Pimjo S.A. to Stichting Panthalassa? Please, indicate when and where did the Oppenheiemer Caracas Managerssign the “Quickclaim Deed”? Did any of the Oppenheiemer Caracas Managers or others obtain benefits





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

from the account of Pimjo S.A. or Pimjo Trust CV? Is there money missing from Pimjo S.A. or Pimjo Trust CV accounts? Who instructed you to open the account of Pimjo Trust CV on October 11,2001 and what was the chain of supervision? Did the Oppenheiemer Caracas Managers cleared his conflict of interests bybeing brokers, a limited partners of Pimjo Trust CV and later directors ofCarisma Prima Limited? How much money did each of the Oppenheiemer Caracas Managers earnedin fees or otherwise while serving as brokers, limited partners of Pimjo TrustCV and later directors of Carisma Prima Limited? Please specify for eachof Oppenheiemer Caracas Managers his earnings by trading stock and bytrading bonds and/or other instruments such as options, futures and the like.Were the accounts of Pimjo S.A. and/or Pimjo Trust CV ever overtraded forthe personal benefit of the Oppenheiemer Caracas Managers? Please disclose to me the actual address of record of all the accounts ofPimjo Trust CV. Please explain who hired the services of the USA address “Pimjo Trust CV.CCS 82586, P.O.Box 025323, Miami FL 33102, USA”? Please explain which cost unit of Oppenheimer & Co., Inc. supports thepayment of the services of the USA address “Pimjo Trust CV. CCS 82586,P.O.Box 025323, Miami FL 33102, USA”? Is the Office of the Chief Compliance Officer of Oppenheimer & Co., Inc.aware of Oppenheimer & Co., Inc. sending mail to the very sameOppenheimer & Co., Inc. against clients´wishes? Please explain who else receive mail at that address and for what purpose?Please explain how that address is connected with Pimjo Trust CV? Please surrender and deliver to me all statements in your posession of theaccounts of Pimjo S.A. (account number ), Pimjo Trust CV (account numberA140505833L52) and of the checking facility arranged by Oppenheimer &Co., Inc. with UMB Bank NA account number 26201338505041. Please explain what Mr. Art Lewis meant on February 13, 2012 with thefollowing phrase: “I’m sure you know what is going on with this account;Allen Holeman has spoken to you in regards to this situation.” Please explain how many private meetings you had with the Redmondsand/or Alfonzo and/or Toro. Please explain the subject matters and items discussed during thosemeetings. Have you ever discussed with anyone the possibility of investing, directlyor indirectly, in equity or bonds to be issued by Chocolates El Rey, C.A. orany related entity? Please disclose why the Redmonds, Alfonzo and Toro are dedicated to





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

escalate this conflict. Please disclose why the Redmonds, Alfonzo and Toro refuse to mediate orarbitrate as they are obliged to. Have you ever discussed with anyone the possibility of giving money,directly or indirectly, to any PEP, candidate, excandidate, politician orpolitical organization, NOGs, their instrumentalities or related entities? Have you ever sent Pimjo Trust CV money to Switzerland or any other fiscalparadises? List all of them, please. Please explain the reason why between 1/3 and ¼ of the value of theportfolio (status quo between US$ 3,5 million and US$ 4,5 million werepermanently uninvested and kept in quasi-cash positions considering that theexpenditures of Pimjo Trust CV in any full year never exceeded US$245,755.00? What event were you expecting that would trigger the investment of thoseliquid assets representing between 1/3 and ¼ of the value of the portfolio?Please give a full and detailed report of all wire transfers made from January1 2007 until and including the last wire transfer made in 2011. Please explain why the file of Pimjo Trust CV was never updated during 9years since its inception. Please explain why the Compliance Department of Oppenheimer & Co., Inc.was not aware of the all the changes in the structure of Carisma PrimaLimited. Please explain how the Compliance Department of Oppenheimer & Co., Inc.“discovered” that you were director of Fundación Pimjo A.C. if you havenever been appointed director of Fundación Pimjo A.C. Please explain how the Compliance Department of Oppenheimer & Co., Inc.“discovered” that you were director of Carisma Prima Limited and whatspecific steps were taken. Please be specific as to the steps taken to trade andmove the accounts. Please explain why you failed to communicate your office as director ofCarisma Prima Limited to the Compliance Department of Oppenheimer &Co., Inc. Please explain why you failed to disclose your interests to Carisma primaLimited which were not registered in the Register of Interests of CarismaPrima Limited in New Zealand incurring in a violation to the law. Please explain why the W-8BEN of Pimjo Trust CV in 2001 disclosed at thevery same Pimjo Trust CV as the ultimate beneficiary. Please disclose how many file, documentation and compliance reviews weremade to Pimjo Trust CV since its inception. Please explain how many W-8BEN of Pimjo Trust CV were filed and whosigned them.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Please explain upon whose authority and show supporting documentationallowing the Oppenheiemer Caracas Managers to trade in the account ofPimjo Trust CV. Please indicate every person with past, present or attemptedtrading authority. Please disclose upon whose authority do you exercisepowers in the accounts of Pimjo Trust CV. Please disclose who moved the account of Pimjo Trust CV status quoFebruary 15, 2012 for status quo US$ 1.500.000 and upon whose authorityand supporting documentation. Please explain upon whose authority and show supporting documentationallowing the Oppenheiemer Caracas Managers to transfer money out theaccount of Pimjo Trust CV. Please indicate every person with past, presentor attempted authority to transfer money out of the account. Please disclose who instructed you to open the checking account of PimjoTrust CV with Oppenheimer & Co., Inc. clearing facility at UMB Bank, NA,Kansas. Please show the supporting documentation used to open the checkingaccount of Pimjo Trust CV with Oppenheimer & Co., Inc. clearing facilityat UMB Bank, NA, Kansas. Please explain upon whose authority and show supporting documentationallowing the Oppenheiemer Caracas Managers to transact businesses withthe checking account of Pimjo Trust CV with Oppenheimer & Co., Inc.clearing facility at UMB Bank, NA, Kansas. Please indicate every personwith past, present or attempted authority to move the account. Please disclose any and all past and/or existing accounts of Pimjo Trust CVanywhere in the world and surrender all documentation in your posession.Please disclose if you opened and/or operated and/or know of any accountopened in the name of Pimjo Trust CV and/or Fundación Pimjo A.C. inBanco del Sol or any related entities in Venezuela or abroad. Please explain who authorized the investment policy and show theinvestment policy of Pimjo Trust CV. Please explain to me if any of the accounts of Pimjo Trust CV or FundaciónPimjo A.C. vía U. S. Dollars or via equivalent Bolivares had, at least, onecontact with the hundreds of accounts and several of millions of US dollarsreferred to in the following paragraph of the NYSE Hearing Board Decision06-82 of June 27, 2006. “As set forth below, during the period of 2002through 2004, (the “relevant period”), Pettus, while employed as branchoffice manager at the Foreign branch office, failed to adequately superviseand follow-up on certain activities in his branch, including but not limitedto, registered representatives and non-registered employees facilitating alarge number of intra-account journals through both unrelated customeraccounts as well as employees’ personal and employee-related accounts.





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



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These money movements occurred in hundreds of accounts and amountedto several million dollars. Pettus and 15 other Foreign branch officepersonnel took part in the money movements, which involved 31 employeeor employee-related accounts. Pettus’ failure to adequately supervise thesemoney movements contributed to the Firm’s failure to properly identify andreport those transactions that were suspicious within the meaning of theBank Secrecy Act.” Please disclose if those money movements in hundreds of accounts whichamounted to several million dollars were related to illegal foreign exchangetransactions between U.S. Dollars and Bolivars and what benefit did youobtain from them. Please explain step by step with full detail how you managed to effectuatewire transfers out of the accounts of Pimjo Trust CV including checkingaccount of Pimjo Trust CV with Oppenheimer & Co., Inc. clearing facilityat UMB Bank, NA, Kansas. Please disclose who authorized the wire trnasfers to CERPE, CEDICE andFe y Alegría disclosed in your email of November 30, 2011 and show thesupporting documentation of such transactions. Please identify correctly who are CERPE, CEDICE and Fe y Alegria. Please disclose who the ultimate beneficiaries were of those wire transfers.Please identify correctly “venezuela competitive” (sic.) Please disclose if it is within Oppenheimer & Co., Inc.´s accepted practicesto transfer without authorization money to an unrelated party such asCERPE for the latter to donate that money to an unknown unrelated otherparty. Please disclose who authorized the wire transfer made to CEDICE and showsupporting documents. Please identify the character of CEDICE under Leypara la Protección de la Autodeterminación y Soberanía Nacional.. Please disclose who authorized the wire transfer made to Fe y Alegria andshow supporting documents. Please disclose when did you learn that the financial statements ofChocolates El Rey, C.A. had been presumably adultered with the intentionto ilegally obtain loans from banks in Venezuela and presumably by theRedmonds, Alfonzo and, perhaps, Toro. Please disclose if the Redmonds, Alfonzo and Toro have attempted toregister their signatures as authorized signatories in any account of PimjoTrust CV and show their supporting documentation. Please specify what titlealledged to incorporate their respective signatures. Please disclose how many forms to incorporate their signatures do you hador have in your posession, who signed those forms and provide me withimages of those forms.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Please show me the image of the form signed by Alfonzo where he wrotethat he was incorporating his signature provided and upon the condition thatToro incorporated his signature as well. Please disclose under what title and representation the Redmonds, Alfonzoand Toro attempted to register their signatures as authorized signatories inany account of Pimjo Trust CV and show supporting documentation. I demand from you that you do protect Alfredo Quintana. I make youpersonally liable of his wellbeing.

May 7, 2012May 8, 2012

Request to file Interpleader Complaint.

May 15, 2012 Request for mediation at FINRAAugust 3, 2012 Request to approve my withdrawal as authorized signatory in the terms

presented.August 3, 2012 Request to be included as defendant if the Interpleader Complaint.August 5, 2012 Request to be treated fairly and equitably under OPPENHEIMER

HOLDINGS INC. OPPENHEIMER & CO. INC. CODE OF CONDUCTAND BUSINESS ETHICS FOR DIRECTORS, OFFICERS ANDEMPLOYEES (Revised April 2011): “You may not take unfair advantageof anyone through unethical or illegal measures, such as manipulation,concealment, abuse of privileged information, misrepresentation of materialfacts, or any other unfair practices.” (§ 7 A. Fair Dealing.)

August 8, 2012 Request to send copies of letters mentioned as exhibits in the draft of theInterpleader Complaint and copies of UF filings of Oppenheimer & Co., Inc.(before Fahnestock & Co., Inc.) Caracas Office Branch Broker René F.C.Mendez de León (CRD # 331918), Caracas Office Branch Broker RussellM. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager andBroker John Gayle Pettus Jaso (CRD # 2415914).

August 10, 2012 Truce and mediation. Humanitarian tit-for-tat.

26.- Performing a movement of funds on January 2012 and status quo February 15, 2012 while the accountwas allegedly restricted by Oppenheimer and there was no authorized signatory.

Contrary to what Oppenheimer & Co., Inc. claims, some one has been able to move US$ 1.570.607.60during the month of January 2012 and circa US$ 1.500.000 circa February 15, 2012.

The absurdity of the status quo is that today the client Pimjo Trust CV has no information of what obvioustransgressor and lack of character Oppenheimer & Co., Inc. is doing with Pimjo Trust CV assets andinvestments. 27.- Avoidance of value added taxes in Venezuela in order to cover up hypothesis mentioned before.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Having rendered services within Venezuela, it seems that Oppenheimer & Co., Inc. has failed to complywith its obligations concerning value added taxes whose compliance would have exposed the real natureof its activities and its revenues arising out of them.

In this case, voluntary non-compliance seems to have been adopted as a manner to cover up their illegalactivities in Venezuela.

28.- Failure to recognize authority of client claiming lack of understanding of a "complex multi-nationalcorporate structure" created without authorization by Oppenheimer employees and with the participationof those employees as directors of the "complex multi-national corporate structure" until their forcedresignation in November 2011.

It has been abundantly explained above that the so called "complex multi-national corporate structure"being alleged by Oppenheimer & Co., Inc. was its own creation and was actively managed with theparticipation of its employees who managed to conceal to everyone their involvement and participation.

29.- Possibly filing misleading information in forms U4.

If it is found true that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office BranchBroker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr.( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD #2415914) concealed their participation in the Pimjo Organization, then information supplied at sections13 and14 of FINRA forms U4 (Uniform Application for Securities Industry Registration or Transfer), filedunder oath or affirmation, should be reviewed.

30.- Findings mentioned in the NYSE decisions previously mentioned about transactions through wiretransfers and intra-Firm journal transfers between unrelated clients "for no apparent economic benefit"might have involved the use of the account 26201338505041 at UMB Bank N.A., the client´s account inOppenheimer & Co., Inc. and that the economic benefit might have been illegal foreign exchangetransactions where the other part of the complete transaction was done in Bolivars exchanged in Venezuela.

It is our belief that Oppenheimer & Co., Inc., through its branch office located in the city of Caracas,Venezuela, under the cover of a local company named today Brisbane, Mendes De Leon, Pettus yAsociados, representantes de Oppenheimer & Co., Inc.,engaged illegally in the business of transferringfunds in Venezuela and in foreign currency in exchange for Bolivars and selling unregistered foreign7

securities in Venezuela operating in the financial market of Venezuela as an unauthorized brokerage houseand engaged in activities reserved to authorized banking institutions..

It is our belief that Oppenheimer & Co., Inc., through its branch office located in the city of Caracas,Venezuela, under the cover of a local company named today Brisbane, Mendes De Leon, Pettus y





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Asociados, representantes de Oppenheimer & Co., Inc., engaged in several million dollars ofnon-security/investment transactions through wire transfers and intra-Firm journal transfers between a largenumber of intra-account journals through both unrelated customer accounts as well as employees’ personaland employee-related accounts, without relevant security transactions and for no apparent economicbenefit.

These practices were mentioned in Oppenheimer & Co., Inc. NYSE Hearing Board Panel Decision 05-181dated December 29, 2005 and in John Pettus. NYSE Hearing Board Decision 06-82 dated June 27, 2006.

However, these practices did have an economic benefit since they were half the cycle of illegal foreignexchange transactions in which Oppenheimer & Co., Inc.´s clients “sold” U.S. Dollars in exchange ofBolivars.

Indeed, Oppenheimer & Co., Inc. employees debited the “sold” amount of U.S. Dollars from the accountat Oppenheimer & Co., Inc. of the “seller-client” and move the U. S. Dollar amount via intra-accountjournals or wire transfers to “purchaser” of U. S. Dollars. Meanwhile, the other end of the transaction - anOppenheimer & Co., Inc.´s broker, employee, employee related person or totally unrelated person - wouldhand out to, or deposit in a Venezuelan bank account of, the “seller-client” the Bolivars equivalent of theillegal foreign exchange transaction.

It was necessary for their schema to work to have an account where US dollars credits and debits weretransacted and to keep the differential benefits.

It is my belief that Oppenheimer & Co., Inc. (before Fahnestock & Co., Inc.) Caracas Office Branch BrokerRené F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD# 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914)opened and used the undisclosed, unauthorized and secret checking account at UMB Bank NA, accountnumber 26201338505041, somehow connected with Oppenheimer & Co., Inc., to further this illegal lineof business.

It is my belief that the true reason that explains Oppenheimer & Co., Inc.´s attitude of concealment andavoidance denying access to the control of the accounts of Pimjo Trust CV - particularly the account atUMB Bank Na - is because of the revelations that would arise after auditing the undisclosed, unauthorizedand secret checking account at UMB Bank NA, account number 26201338505041.

It is my belief that these transactions evaded controls and proper reporting requirements regardingmovements of funds both in Venezuela and in the United States of America and that the probability ofbeing contaminated with tainted money is larger than zero.

It must pointed out that Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) has handled this case disrespectfully, exhibiting a wide array of bad manners, prohibiting my





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access to Oppenheimer & Co., Inc. premises, practicing unprofessional tactics of inexcusable delays,avoidance, misinformation and hiding the truth.

BACKGROUND

Remote background: Pimjo, S.A.

The company PIMJO, S.A. was incorporated in Panama on May 16, 1986 for Fahnestock & Co., Inc. clientJosef Grootkerk Zeldenrust and his wife Marie de Haan de Grootkerk.

Josef Grootkerk Zeldenrust was born in The Netherlands on July 25, 1909 within a Jewish family and diedin Caracas, Venezuela, on December 15, 2002, alone, atheist, after a long lasting and painful illness.

Josef Grootkerk Zeldenrust married Marie de Haan de Grootkerk who was born in The Netherlands anddied in Caracas on September 10, 1992.

Josef called his wife Marie with the nickname of "Pim" and she nicknamed him as "Jo". Hence the originof the name "Pimjo".

Josef and Marie suffered the rigors of World War II. I believe that they were persecuted by Nazis.

During or after World War II, Josef and Marie established their domicile and residence in Caracas,Venezuela. They had no issue.

Josef was engineer by profession and practiced in the food industry area as supplier of industrial equipmentand technical assistance.

Josef Grootkerk Zeldenrust and his wife Marie de Haan de Grootkerk were clients of Fanehstock & Co.,Inc. Caracas Office Branch.

I understand that Josef Grootkerk Zeldenrust and his wife Marie de Haan de Grootkerk were clientspersonally of Fahnestock & Co., Inc. before the account of Pimjo, S.A. was opened. I seems that therelationship between Josef Grootkerk Zeldenrust and his wife Marie de Haan de Grootkerk and Fahnestock& Co., Inc. lasted circa 40 years.

Pimjo S.A. was a company with bearer shares created by the Panama law firm of Arias, Fabrega & Fabregaupon instructions of John E. Bennett from the New York law firm Emmet, Marvin & Martin with anaddress at 48 Wall Street, New York, NY 10005.

Emmet, Marvin & Martin was hired and received instructions from Mr. Roger M. Gerber, then atFahnestock & Co., Inc. then located at 110 Wall Street, New York, NY 10005.





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Since its incorporation, Pimjo, S.A. had Fahnestock & Co., Inc. Caracas Office Branch Broker René F.C.Mendez de León (CRD # 331918) as director.

Pimjo, S.A. had the account numbered A14-013200 with Fahnestock & Co., Inc. Such account wasmanaged by Fahnestock & Co. Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918).

All corporate documents were kept by Fahnestock & Co., Inc. Caracas Office Branch Broker René F.C.Mendez de León (CRD # 331918).

As a prophecy of what it would become to be common practices in Fahnestock & Co., Inc. Caracas OfficeBranch, all documents were kept in blank and under the custody of Fahnestock & Co., Inc. Caracas OfficeBranch Broker René F.C. Mendez de León (CRD # 331918).

It is important to point out that since the very beginning of the initial structure for client Josef GrootkerkZeldenrust and his wife Marie de Haan de Grootkerk, Fahnestock & Co., Inc., and Caracas Office BranchBroker René F.C. Mendez de León (CRD # 331918) were actively present and managing their creation.

As we will see later when dealing with the threat of the Action in Interpleader, the participation ofFahnestock & Co., Inc. and the active involvement - sometimes under severe conflict of interests - ofCaracas Office Branch Broker René F.C. Mendez de León (CRD # 331918) precludes Oppenheimer & Co.,Inc. to claim lack of knowledge and understanding about this structure.

The creation of Pimjo Organization.

Mrs. Marie de Haan de Grootkerk died in Caracas, Venezuela on September 10, 1992.

Mr. Josef Grootkerk Zeldenrust was then very ill.

In 1994, Josef Grootkerk Zeldenrust - allegedly following a recommendation from the late Hans Neumann- requested help from Jorge M. Redmond Schlageter to create and manage with others a foundation -Fundación Pimjo, A.C. - to whom he transferred all his assets. Luis Alejandro Aguilar Pardo helped JosefGrootkerk Zeldenrust in this legal assignment and Josef Grootkerk Zeldenrust asked Luis AlejandroAguilar Pardo to serve as founder member and as principal director member of the Board of Directors.

Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918) acted as director of FundaciónPimjo, A.C. until his death on December 18, 2006. Upon René F.C. Mendez de León´s death, his place wastaken by Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914).

Note that both: Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918) and CaracasOffice Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) were actively involved inthe management of this entity and were fully aware of all details.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Luis Alejandro Aguilar Pardo drafted the final last will of Josef Grootkerk Zeldenrust, the articles ofincorporation and bylaws of Fundación Pimjo, A. C., the donation contract an ancillary documentation andwas the custodian of the bearer shares of Pimjo, S. A.

The initial plan consisted in creating a non-for-profit civil law partnership with foundational character -8

Fundación Pimjo, A. C. - to whom Josef Grootkerk Zeldenrust donated, by means of a civil law donationcontract, a portfolio of shares issued by companies domiciled in Venezuela (which are still under custodytoday by Venezolano de Crédito, S. A., Banco Universal ) and whom - the civil law partnership - he9

appointed as universal heir of all his assets (in particular, the bearer shares of the company created anddomiciled in Panama named Pimjo, S. A. who owned the most important asset consisting of the thenportfolio number A14-0132000-452 in Fahnestock & Co., Inc., New York ).10

Fundación Pimjo, A.C. is a non-for-profit civil law partnership with foundational character, created by deedregistered in Oficina Subalterna del Primer Circuito de Registro del Distrito Sucre del Estado Miranda,Venezuela, on January 25, 1995 and recorded under number 14, Tome 9, First Protocol.

Josef Grootkerk Zeldenrust appointed Fundación Pimjo, A.C. as his sole and universal testamentary heirby testament given and recorded in Oficina Subalterna del Cuarto Circuito de Registro del MunicipioAutónomo Sucre del Estado Miranda, Venezuela, on February 10, 1995, under number7, Fourth Protocol .11

The main assets of Fundación Pimjo, A. C. consist today of a portfolio of shares in custody by Venezolanode Crédito, Banco Universal, S. A. and a dormant checking account at that bank. The authorized signatoriesin that checking account are or should be Jorge M. Redmond Schlageter and Luis Alejandro Aguilar Pardosigning jointly.

The Board of Directors of Fundación Pimjo, A. C. is appointed by the General Meeting of Partners ofFundación Pimjo, A.C.

The events of 2001: the first corrupt deviation.

In 1999 started the stampede of restructurings in Venezuela as a consequence of the then coming imminentextinction of the territorial taxation system on income (taxation only on Venezuela connected income)which was in force until December 31, 1999 and the entering into force of the taxation system uponworldwide income which entered into effect on January 1, 2000.

During 2001 an unconsented and unheralded structural deviation took place which needed our interventionto be corrected: Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918), CaracasOffice Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office Branch Manager andBroker John Gayle Pettus Jaso (CRD # 2415914), acting jointly, created Pimjo Trust CV, a civil law Dutchlimited partnership, on July 19, 2001, and conveyed to such partnership all assets held in the account ofPimjo, S. A. number A14-0132000 at Fahnestock & Co., Inc.





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The account number of Pimjo Trust CV at Fahnestock & Co., Inc. is A14-0505833-452. It was opened onOctober 12, 2001 and the documents used to open the account are dated October 11, 2001.

Please, find below a diagram of the schema created by Fahnestock & Co., Inc. Caracas Office BranchBroker René F.C. Mendez de León (CRD # 331918), Caracas Office Branch Broker Russell M. Dallen, Jr.( CRD # 2445026) and Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD #2415914).






Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



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The unauthorized schema had four serious fundamental problems in addition to the lack of authorization:

The general partner of Pimjo Trust CV was a Dutch foundation - Stichting Panthalassa - controlledby unknown persons which had relationships with a certain organization named AmicorpInternational Limited, a service provider company established in Curaçao then a black listedjurisdiction.

We had reasons to suspect that such general partner foundation - Stichting Panthalassa - wasequally and simultaneously general partner of a large number of other Dutch partnerships whichwere created by unknown persons clients of Amicorp International Limited. Being the generalpartner severally and jointly liable for civil liability of the acts of the partnerships, it exposed thepatrimony of Pimjo Organization and created an unmeasurable number of instances of risksrelated to money laundering and legitimacy of funds.

The limited partners of Pimjo Trust CV were natural individuals residing in Venezuela subject toincome and estate taxes.

Fahnestock & Co., Inc. Caracas Office Branch Broker René F.C. Mendez de León (CRD #331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and CaracasOffice Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914), then brokersworking for Fahnestock & Co., Inc. in Caracas, Venezuela, had acquired the character of limitedpartners with personal property rights over the portfolio.

Luis Alejandro Aguilar Pardo promoted and conducted the process of fixing the aforementioned corruptsituation.

Josef Grootkerk Zeldenrust entrusted Jorge M. Redmond Schlageter and Luis Alejandro Aguilar Pardo therestructuring of the organization and its supervision by means of a letter of instructions signed by JosefGrootkerk Zeldenrust on October 5, 2001. We have a copy of a ceratin letter dated "October 2001"allegedly signed by Josef Grootkerk Zeldenrust instructing the transfer of the assets out of Pimjo, S. A.account number A14-0132000 to an unknown account of "Pimjo CV".

The resolution to this deviation finally took place on November 29, 2001 and took the form describedbelow which comprised a New Zealand trustee company managed by Jorge M. Redmond Schlageter andLuis Alejandro Aguilar Pardo, the Xavier Trust settled in accordance with New Zealand law on June 27,2001 acting as the limited partner of Pimjo Trust CV and the Dutch Pimjo Homeland Foundation actingas the Managing / General Partner of Pimjo Trust CV.

[The remaining of this page has been left intentionally in blank]





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Fahnestock & Co., Inc. Caracas Office Branch Broker René F.C. Mendez de León (CRD # 331918),Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) executed a letter (they called it a quickclaim deed) dated August 30, 2001, addressed to Pimjo Trust CV in Amsterdam, The Netherlands, (whichwas sent from New York using an envelope with the letterhead of Fahnestock´s Caracas address,postmarked in New York on November 26, 2001 via U.S. Mail, with a seal reading "Returned for additionalpostage. Foreign mail must be prepaid." and addressed to “Alejandro Aguilar" without mentioning countryor city) in which they "...remise, release and forever quitclaim all our interests in Pimjo CV (sic), if any,and in and to any assets or property owned by Pimjo C.V. (sic)."

The corrected structure was initially a sort of transactional compromise in order to solve the "impasse"created by the late Francois R. C. Méndez de León.

It seems that Fahnestock & Co., Inc. Caracas Office Branch Broker René F.C. Mendez de León (CRD #331918), Caracas Office Branch Broker Russell M. Dallen, Jr. ( CRD # 2445026) and Caracas OfficeBranch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) never gave notice to their employer





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Fahnestock & Co., Inc. of these changes and it seems that all documentation submitted on October 11, 2001remained being used as if valid and updated. Actually, it seems that no periodical review of the files ofPimjo Trust CV was ever made, or if made, it was tampered with.

Mr. Josef Grootkerk Zeldenrust passed away on December 15, 2002. It seems that the account at UMBBank NA was active and operative on 2004. Mr Francois R.C. Mendez de León passed away on December18, 2006. Fahnestock & Co., Inc. Caracas Office Branch Manager and Broker John Gayle Pettus Jaso(CRD # 2415914) assumed the position left by Mr. Mendez de León.

In year 2008, there was an amendment to the structure due to New Zealand requirements. The changeentailed replacing Carisma Limited as trustee by Carisma Prima Limited. In year 2009, Pimjo HomelandFoundation was replaced by the Joseph Trust settled on July 7, 2009. The diagram of the structure as of2009 is shown below.

Again, it seems that Fahnestock & Co., Inc. Caracas Office Branch Manager and Broker John Gayle Pettus





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Jaso (CRD # 2415914) never gave notice to his employer Fahnestock & Co., Inc. of these changes. It alsoappears that superseded documentation was being used by Fahnestock & Co., Inc. Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) .

The 2009 Pimjo reorganization proposal.The events occurred during 2001 taught us that institutionality was of the upmost importance to preservethe will of Josef Grootkerk Zeldenrust.

The elements of institutionality that seemed important to us and which we urged the directors of CarismaPrima Limited to adopt since 2009 were:

To adopt a proposal drafted by Luis Alejandro Aguilar Pardo in 2008 and 2009 for a modern andadvanced regime of corporate governance.

To incorporate the fiduciary vision of the activities of the directors and to grant them powers andattributions in order to warrant the correct exercise of such powers.

To adopt an ownership regime that (I) separated the Pimjo Organization from Venezuela, (ii)institutionalized the ownership and control over the organization, (iii) unified the appointments forthe different offices in all the entities and (iv) established a framework of ownership and controlclear and transparent with a projection towards the future further away from our active lifetime.

To incorporate an audacious and fearless regime for the solution of conflicts via daring alternativedispute resolution mechanisms to eradicate from the Pimjo Organization the threats of conflictsill managed or resolved transforming the persons associated with the Pimjo Organizationinvulnerable to fear or intimidation. This would imply to incorporate the same clauses of conflictsolving in the creation documents of all the entities within the structure.

To eliminate all connections with The Netherlands and to transform Pimjo Trust CV into a limitedliability company in Florida or to replace Pimjo Trust CV by a new limited liability company.

Since the times when Fahnestock & Co., Inc. Caracas Office Branch Manager and Broker John GaylePettus Jaso (CRD # 2415914) assumed the management of the portfolio in Oppenheimer & Co., Inc., theenactment of the foreign exchange control system in Venezuela and the threats aired against foreignfinancing to local non-governmental organizations, we decided that all contributions were to be madethrough Pimjo Trust CV and from USA, in foreign currency, delivered to the beneficiaries abroad, in orderto unlink the donations in Bolivars, not to participate in the transactions known as "barter of public debtsecurities", and not to acquire Bolivars from private individuals. We have been pursuing this strategy forseveral years now.

The last Board of Directors of Carisma Prima Limited failed to implement the transformation plan prepared





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for implementation on March 31, 2009 or any other. It is further our opinion that such plans might havebeen blocked either intentionally or because of plain ignorance.

The directors Rafael Alfonzo Hernández and Germán Toro Arévalo were invited in 2009 to participate asdirectors of the Pimjo Organization with the aim of achieving the objectives of standing on transparency,corporate substance and the best practices of corporate governance.

The director Jorge M. Redmond Schlageter imposed in 2009 his very young daughter, Astrid K. RedmondHorn, as director. Even though that appointment was accepted then, it was made clear that it was not quiteappropriate and it has now proven to be a disadvantage. This appointment was a concession made inexchange for the appointments of Rafael Alfonzo Hernández and Germán Toro Arévalo. The agreed uponidea concerning new young participants was the designation of young candidates as trainees who wouldassist to the meetings of the organization and would be trained as future directors being appointed for theirproven merits.

The events of 2010 - 2011.

During the first quarter of 2011, as certain unacceptable corrupt practices had been discovered in themanagement of Chocolates El Rey, C.A., a Venezuelan company, and its affiliates, Rafael AlfonzoHernández and Germán Toro Arévalo - as it was agreed upon with Luis Alejandro Aguilar Pardo -pretended to have resigned from their offices of directors of Chocolates El Rey, C.A.

It turned out that Rafael Alfonzo Hernández and Germán Toro Arévalo did not resign from their officesbut pretended to have done it.

Luis Alejandro Aguilar Pardo did not accept the corrupt practices.

Do note, please, that among the members of the Board of Directors of Chocolates El Rey, C.A. there arefive individuals whose arrests, imprisonments, trials and sentences for white collar criminal activitieswould have unimaginable devastating effects in Venezuela.

The resignation of Luis Alejandro Aguilar Pardo was delayed waiting for Rafael Alfonzo Hernández andGermán Toro Arévalo actions but actually they has assumed an avoidance pattern.

During the months of February and March 2011, Luis Alejandro Aguilar Pardo further had to opposecertain additional corrupt transactions that were taking place in a USA company related with ChocolatesEl Rey, C. A. The name of the USA entity is Chocolates El Rey, Inc. Because of his opposition to thosetransactions, Luis Alejandro Aguilar Pardo was ousted from Chocolates El Rey, C.A.- even though it wasprivately meant that he would resign - and subjected to disqualifications, labor and social measures ofcoercion, threats, health and psychological sufferings.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Rafael Alfonzo Hernández, Germán Toro Arévalo and Luis Alejandro Aguilar Pardo, the three directorsof Chocolates El Rey, C.A. were also directors of Carisma Prima Limited. The other three directors ofCarisma Prima Limited were Jorge M. Redmond Schlageter, his daughter Astrid Kristina Redmond Hornand Oppenheimer & Co., Inc. Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD# 2415914) who had been appointed as director against our recommendation and warning of conflict ofinterests even though he had stated that he had cleared those conflicts of interests with Oppenheimer & Co.,Inc.

During the months of October and November 2011, Oppenheimer & Co., Inc. Caracas Office BranchManager and Broker John Gayle Pettus Jaso (CRD # 2415914) resigned as director of Carisma PrimaLimited allegedly because the Compliance Department of Oppenheimer & Co., Inc. had discovered thathe was acting as director of “Fundación Pimjo”.

This was a punctuation issue since Oppenheimer & Co., Inc. Caracas Office Branch Manager and BrokerJohn Gayle Pettus Jaso (CRD # 2415914) was never appointed director of Fundación Pimjo, A.C. but hewas appointed director of Carisma Prima Limited.

Oppenheimer & Co., Inc. Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD #2415914) claimed also that he had resigned as "authorized signatory" in the account of Pimjo Trust CV inOppenheimer & Co., Inc. and mentioned that the account lacked authorized signatories.

Oppenheimer & Co., Inc. Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD #2415914) claimed that he was the "sole authorized signature" in the account of Pimjo Trust CV.

Without knowing their hidden agenda, Rafael Alfonzo Hernández and Germán Toro Arévalo stated thatthey did not wish to continue as directors of Carisma Prima Limited. Luis Alejandro Aguilar Pardo himselfwished to separate as well but noticed that the organization would fall under the control of Jorge M.Redmond Schlageter since supposedly Rafael Alfonzo Hernández and Germán Toro Arévalo wereuninterested, did not wish to participate, both claimed that they had never been consulted and that they hadnot been called to solve someone else´s problems. The only other director was his daughter Astrid KristinaRedmond Horn who was unlikely to bring the Pimjo Organization into balance or equilibrium.

On November 30, 2011, Mr Luis Alejandro Aguilar Pardo had actual knowledge given by Oppenheimer& Co., Inc. Caracas Office Branch Manager and Broker John Gayle Pettus Jaso (CRD # 2415914) ofcircumstances that suggested the use of funds to finance an unapproved project and circumstances thatsuggested the use of funds to finance the activities of a certain organization politically active in Venezuela.

In both hypothesis, it would have been a wrongdoing.

In the first hypothesis, there are large sums of money and one of them with contradictory information aboutits use.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

In the second hypothesis, besides being ultra vires, it would mean or it would have meant a criminalviolation of the law of Venezuela. Irrespective of how each one of the directors may feel about the legalityor legitimacy of such laws, it is unacceptable to conspire to break the law.

Be noted that if the second hypothesis is true and the members of the forces of the opposition are successfulin overthrowing the actual political regime, Luis Alejandro Aguilar Pardo will be considered as an outcastand a traitor.

On the other hand, if the second hypothesis is true and the members of the opposing group are discoveredwith these financial schema, Luis Alejandro Aguilar Pardo would surely end up in prison.

On December 23, 2011, Luis Alejandro Aguilar Pardo had actual notice that Jorge M. Redmond S., AstridKristina Redmond and Rafael Alfonzo Hernández had committed white collar crimes punishable withprison terms. As of that date, Jorge M. Redmond S., Astrid Kristina Redmond, Rafael Alfonzo Hernándezand Germán Toro Arévalo were acting in unison and concurrence.

The events from January 17, 2012 until March 28, 2012: The Oppenheimer obstacle and the first 65 days.

On January 17, 2012, Carisma Prima Limited and Pimjo Trust CV launched the Plan of Revitalization ofPimjo Organization.

On that day, exdirectors of Carisma Prima Limited Jorge M. Redmond S., Astrid Kristina Redmond, RafaelAlfonzo Hernández and Germán Toro Arévalo were ceased as directors. Notice was given to the Registrarof Companies of the Companies Office of the Ministry of Economic Development of New Zealand inaccordance with the law.

On January 23, 2012, Luis Alejandro Aguilar Pardo delivered the first set of documentation toOppenheimer & Co., Inc.

The package contained:

Document 1.- Oppenheimer´s form 104 entitled "Partnership Account Authorization",

Document 2.- Certified copy by Notary Public of the Commonwealth of Massachusetts of the driver licenseissued by the State of Florida to Luis Alejandro Aguilar Pardo,

Document 3.- Original of the Power of Attorney issued by Pimjo Trust to Luis Alejandro Aguilar Pardoet al. on January 23, 2012 witnessed by three witnesses and executed and acknowledged in the presenceof a Notary Public of the Commonwealth of Massachusetts,





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Document 4.- Certified copy by Notary Public of the State of Florida of the Resolution UnanimouslyAdopted by the Partners of Pimjo Trust dated January 17, 2012,

Document 5.- Certified copy by Notary Public of the State of Florida of the Deed of Incorporation of PimjoTrust as amended and reinstated on July 7, 2009,

Document 6.- Certified copy by Notary Public of the State of Florida of the Special Resolution of theShareholder of Carisma Prima Limited dated January 17, 2012, acknowledged in the presence of NotaryPublic on January 17, 2012,

Document 7.- Certified copy by Notary Public of the State of Florida of the Register of Directors ofCarisma Prima Limited dated January 17, 2012,

Document 8.- Certified copy by Notary Public of the State of Florida of the Company Extract of CarismaPrima Limited issued by the Registrar of Companies of the Companies Office of the Ministry of EconomicDevelopment of New Zealand dated January 20. 2012 (New Zealand Time), with validation codeEXT63419399 at www.companies.govt.nz issued by the said Companies Office on the said January 20,2012 (New Zealand Time) at 03:59 PM (New Zealand Time),

Document 9.- Certified copy by Notary Public of the State of Florida of the Company Constitution ofCarisma Prima Limited lodged in the Companies Office of the Ministry of Economic Development of NewZealand.,

Document 10.- Certified copy by Notary Public of the State of Florida of the Company Certificate ofIncorporation of Carisma Prima Limited issued by the Registrar of Companies of the Companies Officeof the Ministry of Economic Development of New Zealand on March 31, 2008.

Luis Alejandro Aguilar Pardo Aguilar instructed to stop all wire transfers out of the account of Pimjo Trustuntil further notice and stated that all prior authorities were revoked.

On January 25, 2012, Luis Alejandro Aguilar Pardo notified Oppenheimer Caracas Office Branch ManagerJohn Gayle Pettus Jaso (CRD # 2415914) that he had sent to Oppenheimer & Co., Inc. former mainoffices in New York City the documents necessary to incorporate Luis Alejandro Aguilar Pardo´ssignature.

By several emails and phone calls , Oppenheimer Caracas Office Branch Manager John Gayle Pettus Jaso(CRD # 2415914) requested several times to Luis Alejandro Aguilar Pardo since November 11, 2011 toincorporate his signature as authorized signatory in The Oppenheimer & Co., Inc. Account.

On January 31, 2012, Luis Alejandro Aguilar Pardo sent to Oppenheimer & Co., Inc. at New Yorkprincipal offices a letter:





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Announcing that an internal audit had to be conducted covering all the affairs of Pimjo Trust CV, whichhad to go back to 1995, when the account was A14-0132000-452 in Fahnestock & Co., Inc. under theaccount title "Pimjo, S.A.", until December 31, 2011,

Asking Oppenheimer & Co., Inc. to communicate directly with Luis Alejandro Aguilar Pardo, (3) askingOppenheimer & Co., Inc. to severe all contacts with Venezuela due to the social and political conditionsprevailing in Venezuela,

Ratifying the instructions to stop all wire transfers out of the account of Pimjo Trust until further notice,

Aasking Oppenheimer & Co., Inc. information as to proper procedure to give wire transfer instructionsdirectly to Oppenheimer & Co., Inc.,

Requesting Oppenheimer & Co., Inc. to initiate a full "Know your client" and "Know your client´s clients"inquiry on Pimjo Trust CV,

Advising Oppenheimer & Co., Inc. that Pimjo Trust CV may not engage in trade or business within UnitedStates of America, The Netherlands and New Zealand,

Advising that Pimjo Trust would provide W-8BEN forms during that week,

Document 10.- Enclosing an Oppenheimer & Co., Inc. Change of Address Authorization form to Level31, Vero Centre, 48 Shortland Street, Auckland 1140, New Zealand signed by Luis Alejandro AguilarPardo before a Notary Public,

Requesting the terms of the Oppenheimer & Co., Inc. Account.

Luis Alejandro Aguilar Pardo made the following requests:

"I would like to kindly request the statements of account fromJanuary 1, 1995 until December 31, 2011 in PDF format."

"Would it be possible to deliver them to my email address,[email protected], protected with the password "alberttucker",please?."

"Would it be possible to assign to us a temporary account officeras a direct contact while we conclude our internal audit?"

"Would it be possible to give instructions and contact Oppenheimer& Co., Inc. & Co., Inc. directly without having the intervention of





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

your office in Caracas?"

"Please, review our account´s file and, please, put me in contactwith your Compliance Department in order to start the "Know yourclient" and "Know your client´s clients" inquiry."

"Please, would you please find out what was the date when theassets / portfolio in the account A14-0132000 of Pimjo S.A. weretransferred to the account A14-0505833-452 of Pimjo Trust CV?"

"At the time of the transfer, was the final balance of the accountA14-0132000 of Pimjo S.A. equal to the initial balance of theaccount A14-0505833-452 of Pimjo Trust CV?"

"Who makes the trading decisions for the investments in theaccount of Pimjo Trust CV?"

"How many "trading authorizations" do exist after the tradingauthorization given to the late Francois Rene Mendez de Leon onMay 20, 2002?"

"Would you kindly send me copies of those trading authorizationsto my email address, [email protected], protected with the password"alberttucker", please?"

"What levels of investment risks are authorized in the account ofPimjo Trust CV?"

"Please, would you kindly confirm the identities of the personsauthorized as signatories in the account of Pimjo Trust CV since itsinception status quo October 11, 2001 until today January 31,2012?"

On February 1, 2012, Luis Alejandro Aguilar Pardo sent a letter to Oppenheimer & Co., Inc. enclosingdocuments to initiate the Luis Alejandro Aguilar Pardo-requested KYC compliance audit. Luis AlejandroAguilar Pardo provided:

Document 11.- A diagram of the corporate structure of Pimjo Trust.

Document 12.- Certified copies of the passport and driver license of Luis Alejandro Aguilar Pardo.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Certified copies of the following documents:

Document 13.- Certificate of Incorporation of Aguilar & Aguilar Limited.

Document 14.- Company Extract of Aguilar & Aguilar Limited

Document 15.- Constitution of Aguilar & Aguilar Limited.

Document 16.- Unanimous Resolution of Shareholders and Directors dated January 16, 2008 of Aguilar& Aguilar Limited..

Document 17.- Certificate of Incorporation of Carisma Prima Limited.

Document 18.- Company Extract of Carisma Prima Limited.

Document 19.- Constitution of Carisma Prima Limited.

Document 20.- Unanimous Resolution of Shareholders and Directors dated March 31, 2008 of CarismaPrima Limited.

Document 21.- The Xavier Trust Deed dated June 27, 2001.

Document 22.- Deed of Retirement and Appointment of The Xavier Trust dated July, 7, 2009.

Document 23.- The Joseph Trust Deed dated July 7, 2009.

Document 24.- The Joseph Trust. Assignment of Property to Trust dated July 7, 2009.

Document 25.- Reinstated and Amended Deed of Creation of Pimjo Trust CV dated July 7, 2009.

Document 26.- Participation Certificate 6 issued on July 7, 2009 by Pimjo Trust CV to Carisma PrimaLimited as Trustee of the Joseph Trust.

Document 27.- Participation Certificate 7 issued on July 7, 2009 by Pimjo Trust CV to Carisma PrimaLimited as Trustee of the Xavier Trust.

Document 28.- Register of Partners of Pimjo Trust CV as per 18 of the Reinstated and Ammended Deedof Creation of Pimjo Trust CV dated July 7, 2009.

Document 29.- Luis Alejandro Aguilar Pardo addresses, phone numbers, fax numbers and email addresses.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

On February 1, 2012, Luis Alejandro Aguilar Pardo sent a letter to Oppenheimer & Co., Inc. requestingOppenheimer & Co., Inc. to:

Transfer the account of Pimjo Trust CV from its present location at Caracas, Venezuela to yourBoca Raton, Florida, USA, branch office.

Severe all access to this account from secured or unsecured, encrypted or uncrypted, servers, phonelines, dedicated lines, satellite connections or any other means of electronic, digital, audio, video,fax with origin in, or destination to, Venezuela or Cuba.

Consult with Luis Alejandro Aguilar Pardo all movements and transactions in the Oppenheimer& Co., Inc. Account at +1-561-251.7697.

Disclose who had trading authority in the Oppenheimer & Co., Inc. Account

Review and determine the goal and investments strategies for the Oppenheimer & Co., Inc.Account as soon as possible.

Secure from Mr. John Gayle Pettus Jaso any strategic or tactical information that there might exist(in potentiality or in actuality) concerning investments in the Oppenheimer & Co., Inc. Account.

Issue Luis Alejandro Aguilar Pardo the necessary credentials to access and log on to Oppenheimer& Co., Inc. wbesite as client.

To change the phone numbers showing in the Oppenheimer & Co., Inc. Account since LuisAlejandro Aguilar Pardo had noticed that the phone numbers showing in the Oppenheimer & Co.,Inc. Account belong to Aguilar & Aguilar, Abogados Caracas office.

On February 6, 2012, Luis Alejandro Aguilar Pardo sent a letter to Oppenheimer & Co., Inc. enclosingdocuments and enclosing therewith:

Document 30.- Statement of Foreign Structure as February 2012 together with:

Document 31.- W-8BEN of Fundación Pimjo, A. C.

Document 32.- W-8IMY of Carisma Prima Limited as trustee of the Xavier Trust.

Document 33.- W-8IMY of Carisma Prima Limited as trustee of the Joseph Trust.

Document 34 W-8IMY of Carisma Prima Limited.





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

This Statement of Foreign Structure was later amended on March 16, 2012 by Luis Alejandro AguilarPardo correcting an involuntary mistake (Documents 35, 36, 37, 38 and 39)..On February 9, 2012, Luis Alejandro Aguilar Pardo met Arthur W. Lewis, Oppenheimer & Co., Inc.Boca Raton, Florida, Office Branch Manager and Broker (CRD # (1438899) Managing Director, BocaRaton, Florida, USA, branch office of Oppenheimer & Co., Inc. during which, among other things,requested the intervention of an Oppenheimer & Co., Inc. compliance officer.

I was naive and exhibited a childlike simplicity and credulity when I based my strategy of cooperationapproaching The Office of The Chief Compliance Officer when, in fact, Oppenheimer & Co., Inc. wascaving trenches because the findings of NYSE had resurfaced again.

Four punctuation points during that meeting were: the disingenuous attitude of Arthur W. Lewis,Oppenheimer & Co., Inc. Boca Raton, Florida, Office Branch Manager and Broker (CRD # (1438899)Managing Director, Boca Raton, Florida, USA, branch office of Oppenheimer & Co., Inc., the obstaclesand excuses placed to get in contact with a Compliance Officer m the initial attempts to delay the attentionof this matter in terms of months and the question about how much was I expecting to obtain from myactions and the contradiction that while claiming lack of rights to access accounts lodged at other brancheshe showed and gave me an unformatted printout of the statement of account as of that day of February2012.

On February 12, 2012, Luis Alejandro Aguilar Pardo sent a letter to Oppenheimer & Co., Inc. to theattention of Allen Holeman, Chief Compliance Officer of Oppenheimer & Co., Inc., in which LuisAlejandro Aguilar Pardo:

Ratified his wish to meet personally with an officer of the Compliance Department ofOppenheimer & Co., Inc. either Mr. Allen Holeman or a designated a junior Compliance Officerto work with Luis Alejandro Aguilar Pardo on the matters concerning the Oppenheimer & Co., Inc.Account at Oppenheimer & Co., Inc. Boca Raton, Florida, branch office,

Requested disclosure to Luis Alejandro Aguilar Pardo of all accounts existing in the name of PimjoTrust CV,

Ratified Luis Alejandro Aguilar Pardo´s authorization to transfer the Oppenheimer Account andany other accounts that might exist from its present location at Caracas, Venezuela to your BocaRaton, Florida, USA, Oppenheimer branch office,

Ratified Luis Alejandro Aguilar Pardo´s request to severe all access to the Oppenheimer & Co.,Inc. Account and to any other accounts that might exist from secured or unsecured, encrypted oruncrypted, servers, phone lines, dedicated lines, satellite connections or any other means ofelectronic, digital, audio, video, fax with origin in, or destination to, Venezuela or Cuba,





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Ratified that all movements and transactions in the Oppenheimer Account should be consulted withLuis Alejandro Aguilar Pardo at +1-561-251.7697,

Without implying or admitting knowledge of its existence or origination, Luis Alejandro AguilarPardo revoked any trading authority that may have been exercised by John Gayle Pettus Jaso,Alfredo Quintana, Russ Dallen or any other broker or officer of Oppenheimer & Co., Inc. inCaracas, Venezuela,

Informed Oppenheimer & Co., Inc. that the power of attorney dated July 19, 2011 was revoked,

Requested information about the steps to provide new trading authority.

Requested the steps to incorporate Luis Alejandro Aguilar Pardo signature as authorized signatoryin the accounts of Pimjo Trust CV,

Requested the necessary credentials to access and log on to Oppenheimer & Co., Inc. website asclient,

Requested the statements from January 1, 1995 until that date in PDF format of the UMB BankAccount and its balance,

Inquired who were the authorized signatories in the UMB Bank Account,

Revoked all powers of all authorized signatories on the UMB Bank Account,

Inquired, after having noticed that the address appearing on the upper left hand side of the checkdrawn of the UMB Bank Account is exact to the address showing in the Oppenheimer & Co., Inc.Account statement of account: - Pimjo Trust CV, CCS 82586, PO Box 025323, Miami, FL 33102- if Oppenheimer & Co., Inc. had the means to investigate whose address was that,

Requested the statements of account of Pimjo, S. A. (account number A14-0132000) and of theOppenheimer & Co., Inc. Account at Fahnestock & Co., Inc and Oppenheimer & Co., Inc.,respectively from January 1, 1995 until December 31, 2011 in PDF format,

Requested the contractual terms of the Oppenheimer & Co., Inc. and the statement of client´srights,

Informed that:

"During 2001 an unconsented and unheralded structural deviationtook place in Pimjo, S. A. which needed my intervention to be





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Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

corrected: Messrs. Russell M. Dallen, Jr., John Gayle Pettus Jaso andFrancois René Méndez de León, joint or individually, created PimjoTrust CV, a civil law Dutch partnership, on July 19, 2001, andconveyed to such partnership all assets held in the account of Pimjo,S. A. number A14-0132000 at Fahnestock & Co., Inc. The accountnumber assigned to Pimjo Trust CV was A14-0505833-452 and theopening documents are dated October 11, 2001. Besides depletingPimjo, S. A. of three fourths of its assets, the unauthorized schemahad four serious fundamental problems in addition to the lack ofauthorization: (1) The general partner of Pimjo Trust CV was a Dutchfoundation - Stichting Panthalassa - controlled by unknown personswhich had relationships with a certain organization named Amicorp,a service provider company established in Curaçao then a black listedjurisdiction. (2) We have reasons to suspect that such general partnerfoundation - Stichting Panthalassa - was equally and simultaneouslygeneral partner of a large number of other CVs which were createdby or for unknown persons clients of Amicorp. Being the generalpartner severally and jointly liable for civil liability of the acts of theCVs, it exposed the patrimony of Pimjo Organization and created anunmeasurable number of instances of risks related to moneylaundering and legitimacy of funds. (3) The limited partners ofPimjo Trust CV were natural individuals residing in Venezuelasubject to income and estate taxes in Venezuela. (4) Messrs. RussellM. Dallen, Jr., John Gayle Pettus Jaso and Francois René Méndez deLeón, then brokers working for Fahnestock & Co., Inc. in Caracas,Venezuela, had acquired the character of limited partners withpersonal property rights over the portfolio. Messrs. Russell M.Dallen, Jr., John Gayle Pettus Jaso and Francois René Méndez deLeón executed a letter (they called it a quick claim deed) datedAugust 30, 2001, addressed to Pimjo Trust CV in Amsterdam, TheNetherlands, (which apparently was sent from New York using anenvelope with the letterhead of Fahnestock´s Caracas address,postmarked in New York on November 26, 2001 via U.S. Mail, witha seal reading "Returned for additional postage. Foreign mail must beprepaid." and addressed to Alejandro Aguilar" without mentioningcountry or city) in which they "...remise, release and foreverquitclaim all our interests in Pimjo CV (sic), if any, and in and to anyassets or property owned by Pimjo C.V. (sic).",

Requested information about what was the date when the assets / portfolio in the accountA14-0132000 of Pimjo S.A. were transferred to the account Oppenheimer & Co., Inc. Account,





Tel. +1-561-459.1980 , +1-561-459.1980. Fax +1-786-228.0559. Mob. +1-561-251.7697.



Tel. +64-9-363.3391, +64-9-889.2143 Dir. Fax.+64-9-358.7340 or +1-786-228.0559.

Requested information about if, at the time of the transfer, the final balance of the accountA14-0132000 of Pimjo S.A. was equal to the initial balance of the Oppenheimer & Co., Inc.Account, what was the final balance of the A14-0132000 of Pimjo S.A., what was the initialbalance of the Oppenheimer & Co., Inc. Account,

Informed that:

"status quo October 18, 2011, John Gayle Pettus Jaso informed meverbally that the Compliance Department of Oppenheimer & Co.,Inc. had instructed him to resign as director of Fundación Pimjo, A.C. and to relinquish his powers as authorized signatory in theaccount of Pimjo Trust, CV. John Gayle Pettus Jaso resignedverbally and finally, thereafter, resigned as director of CarismaPrima Limited on October 31, 2011. Since October 24 on, I havebeen finding out details that, in aggregate, are very disturbing. Ithink that I understood and heard from John Gayle Pettus Jaso thathe had been hiding from Oppenheimer & Co., Inc. his participationas director of Carisma Prima Limited. Why was he hiding it fromOppenheimer & Co., Inc.? Obviously, he knew that he did not havepower of attorney from Carisma Prima Limited as trustee of theJoseph Trust as Managing Partner of Pimjo Trust CV and he didnot have sufficient powers to grant a power of attorney to himself.How the Compliance Department of Oppenheimer & Co., Inc.could have requested John Gayle Pettus Jaso to resign from anoffice it did not know he was holding and without knowing theexistence of the Joseph Trust and of Carisma Prima Limited? WhenI was asked to include my signature as authorized signatory withoutproper corporate procedures of authorization and to submit aW-8BEN, I noticed that the information about Pimjo Trust CV waswrong. I then realized that Pimjo Trust CV might had not been keptcompliant concerning withholding reporting requirements to theIRS and KYC enquiries. Hence, my respectful request to meetpersonally with the Compliance Department to solve these doubts,if any, for the benefit of both: Oppenheimer & Co., Inc. and PimjoTrust CV."

Asked, as soon as practicable, to provide Luis Alejandro Aguilar Pardo with a list of all wiretransfers made during 2011 following a format similar to the following:





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“Date Beneficiary Amount W/T instructions Authorized signatory."

On February 13, 2012, Luis Alejandro Aguilar Pardo sent an email to Arthur W. Lewis, Oppenheimer &Co., Inc. Boca Raton, Florida, Office Branch Manager and Broker (CRD # (1438899) Managing Director,Boca Raton, Florida, USA, branch office of Oppenheimer & Co., Inc. in which Luis Alejandro AguilarPardo:

Thanked Mr. Arthur W. Lewis for his kind attentions Thursday, February 9, 2012 at Oppenheimer& Co., Inc. offices,

Requested to schedule an appointment with Mr. Arthur W. Lewis Monday, February 20, 2012afternoon or thereafter,

Ratified that the Oppenheimer & Co., Inc. Account should be managed conservatively,

Stated the following list of issues to discuss with Mr. Arthur W. Lewis:

"Registering my signature as authorized signatory in Pimjo TrustCV account",

"Registering my signature as authorized signatory inaccount.26201338505041 at UMB Bank NA",

"Reviewing Investments Objectives of Pimjo Trust CV [and][g]ranting necessary trading authority if needed"

"Discussing information supplied by Johnny Gayle Pettus Jasoconcerning on going investment strategies and tactics",

"Reviewing composition of portfolio and receive suggestions aboutchanges",

"Determining risky assets within portfolio (Argentina public debt,for instance)."

"Confirming the change of branch of Pimjo Trust CV account fromCaracas to Boca Raton [confirming] assignment of broker to lookafter Pimjo Trust CV account.”





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“Issuing me the necessary credentials to logon in the account.Receiving terms of the account and clients rights."

On February 13, 2012, another punctuation point took place when I received Arthur W. Lewis,Oppenheimer & Co., Inc. Boca Raton, Florida, Office Branch Manager and Broker (CRD # (1438899)Managing Director, Boca Raton, Florida, USA, branch office of Oppenheimer & Co., Inc., email to ,Oppenheimer Caracas Office Branch Manager John Gayle Pettus Jaso (CRD # 2415914) with copy to AllenB. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD #(1060910) which read as follows:

“Johnny

I’m sure you know what is going on with this account; AllenHoleman has spoken to you in regards to this situation.

I’m writing you for your authorization to move this account fromyour Venezuelan office to the Boca Raton office as instructed by theTrustee, Luis Aguilar.”

Thank you for your attention to this matter.

Art LewisBranch ManagerManaging DirectorSouth Florida Area”

One of the characteristic of Oppenheimer & Co., Inc. main switchboard design is that the calls at theirNew York premises are redirected to its Caracas Branch Office. This is accomplished by identifying thefirst three letters and digits of the account number. In Pimjo Trust CV case, the mentioning of “A14"invariable meant being redirected to Caracas, Venezuela, via the switchboard of Oppenheimer & Co., Inc..

In order to bypass the intervention of the Caracas Branch Office, Luis Alejandro Aguilar Pardo requesteda meeting at the Boca Raton, Florida, Oppenheimer & Co., Inc. premises and he was received on February9, 2912 by Arthur W. Lewis, Oppenheimer & Co., Inc. Boca Raton, Florida, Office Branch Manager andBroker (CRD # (1438899) as mentioned above.

I then decided that it had became a matter of urgency to contact directly the Office of the Chief ComplianceOfficer Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer & Co., Inc.(CRD # (1060910).

On February 15, 2012, Luis Alejandro Aguilar Pardo phoned Allen B. Holeman, Managing Director and





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Chief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) and sent him afterward thefollowing email:

“Mr. Holeman,

My kind call this morning to you was following the invitation madeto me by Arthur Lewis this morning to deal directly with you. I didnot have plans to call you.

I wish to make sure that I have been polite, clear and transparent inall my dealings with Oppenheimer.

I, reciprocally, would like to be treated with friendliness.

I am here to help.

I expect to be “…treat[ed] (…) fairly and equitably” asrepresentative of a customer of Oppenheimer.

If you so prefer, I may deal with the Office of the General Counselor with Mr. Dennis McNamara, Esq. or any one of their team or withSullivan & Cromwell.

My objective to involve the Office of the Compliance Officer hasbeen accomplished already.

My call this morning had several purposes:

1.- Foremost: to offer my full cooperation with documents andexplanations.

I was offering my help, I am pleased with the full review that it istaking place now and I volunteer to cooperate.

2.- To advise you that my meeting with Arthur Lewis scheduled forFriday [February 17, 2012] was not going to take place because youhad instructed him so because of your reviewing of thedocumentation. It seems to me that you were not aware of thismeeting. I think that you told me that you had not talked to ArthurLewis in the last two days. Since these inconsistencies infusenegative feelings and are not necessary, I suggest opening just one





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channel of friendly communication.

3.- That, [nevertheless] there will not be a meeting with ArthurLewis, I had asked him to do perform an analysis of the portfoliowhich is an activity that will have to be done anyway in order tosecure a conservative approach in the investment objectives ofPimjo Trust CV.

4.- That I was pleased that your lawyers are reviewing alldocumentation so the file of Pimjo Trust CV is finally, once and forall complete. That was one of my objectives since the verybeginning of my activities and it is being accomplished even with allthe obstacles that I have faced to get there. I am a compliance officeras well and do tend to go directly towards where these issues aredealt with.

5.- I have a mandate to perform an internal audit to all entitiesinvolved in this organization; not only Pimjo Trust CV. This is agood, sound and prudent practice for those who are leaving theiroffices (not only John Gayle Pettus Jaso) as well to those that willreplace those who have left. Unfortunately, the events of 2001 andOctober 2011 need explanations and may not be silenced.

6.- I am not aware of any unbecoming, indecent, risky or irregulartransactions with this account whatsoever except certain position in[Argentina] debt. I wish to state for the record that I have not madesuch statements neither expressly nor tacitly and did not insinuateor give to understand anything different.

7.- It is obvious that the account lacked documentation. I understandthat the account is old. That may explain a delay in findingdocuments but not a delay in recognizing my authority. Please notethat I helped you and gave you all documents concerning the correctconstruction of the organization legal, corporate and taxwise and thebasis of my full representation today. I also revoked all existingauthorities (without admitting the regularity of their origins since Ihave no idea how those authorities were granted and I need todetermine that fact). If you need more documents, I will be pleasedto provide them to you, if appropriate.

Please, be advised that I did include in my last courier to you some





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copies not listed in my letter which might be helpful to you: atimeline, a check, a letter of resignation, a quick claim deed, and acopy of the Unanimous Resolution Adopted By The Partners ofPimjo Trust CV on November 29, 2001 by which René Méndez deLeón, John Gayle Pettus Jaso et al. acknowledge revocation of thepower of attorney dated July 19, 2001. Regarding Jorge RedmondSchlageter´s authority, one must determine first the date of [the] actwhen he exercised that authority since different rules apply alongthe years.

8.- I have the upmost respect for John Gayle Pettus Jaso and I wishto state for the record that I have not made statements neitherexpressly nor tacitly and did not insinuate or give to understandanything different. I expressly asked that the issues to be discussedwere discussed directly with me because “…I would like to save himany disappointments…” I know perfectly well the idiosyncracy andEthos of Caracas and I imagine that I have now a foe that I did notwant to have and I did not need at all.

9.- Lastly, I was going to thank you and apologize for not havinganswered your call when you received my first letter. I found[yesterday] afternoon your voice message in my voice mailboxwhich I never check.

From your statements and from Arthur Lewis questions, it isobvious that you are holding the recognition of my actual and fullrepresentation of Pimjo Trust CV - today and now - because you arereviewing the past of this account.

I have full control over Pimjo S.A. since 1995 and have full controland unlimited [continuous] authority over Pimjo Truct CV sinceNovember 21, 2001.

I would have wished that you focus and recognize my full powersand authority concerning Pimjo Trust CV and allow me to do theinvestigations that I have to do. But, since that is not being the case,be aware that you have the responsibility to preserve the value of theaccount due to trading [decisions], lack of trading authority oractions taken against my express desire to review and issueconservative investment objectives for Pimjo Trust CV.





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I have questions as you do and I have the mandate to provideanswers.

It is obvious that there might be recent conflicts of interest issuesand curiosity about past events concerning the events from July 19,2001 until November 29, 2001. I can not avoid addressing thoseissues.

It is obvious to me from your statements and questions that you arenow digging in the past. I had the impression from the verybeginning that you – Oppenheimer - would need my help and that iswhy I offered myself to go over the documentation personally witha Compliance Officer or a designee and have asked repeatedly to doso.

If you wish to question me, I am available for answering anyquestions. At this very moment, we share the same objectives andgoals.

I will be glad to meet you in March in South Florida. However, I amexpecting the recognition of my authority much sooner. I expectedthat to happen during this week. Please, give me an estimate of howlong is this process going to take.

Thank you.”

After many emails, phone calls, avoidances, delays, delivery of documents, unfulfilled promises, evasions,excuses, lies and bad manners, I decided to travel to the New York area and force a meeting in New YorkCity with Oppenheimer & Co., Inc. officers which finally took place on February 24, 2012 circa 11:00 am.

Actually, Oppenheimer & Co., Inc. New York Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) confirmed the meeting on February 23, 2012 well after - and inconsiderately- the close of business hours of that day after I had sent an email assuming that the meeting was not to takeplace due to Oppenheimer & Co., Inc. New York Executive Vice-President and General Counsel DennisP. McNamara (CRD # 2938486) silence and avoidance.

On February 24, 2012, Luis Alejandro Aguilar Pardo met - at his request - with Dennis P. McNamara,Oppenheimer & Co., Inc. New York Executive Vice-President and General Counsel Dennis P. McNamara(CRD # 2938486) , Allen B. Holeman, Managing Director and Chief Compliance Officer of Oppenheimer& Co., Inc. (CRD # (1060910) , John T. McGuire, Oppenheimer & Co., Inc. Deputy General Counsel andDirector of Litigation and another gentleman whose name I - most regrettably - may not recall. This last





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person was the only one with knowledge of the documentation already sent to Oppenheimer & Co., Inc.

Lack of knowledge of the facts shown by Dennis P. McNamara, Oppenheimer & Co., Inc. New YorkExecutive Vice-President and John T. McGuire, Oppenheimer & Co., Inc. Deputy General Counsel andDirector of Litigation (who had brought in five minutes before in accordance with his own account)produced disappointment since it was not true the lines of the attorneys review of the documentation whilstthe disingenuous, apologetic, “I-told-you-looks” towards General Counsel Dennis P. McNamara (CRD# 2938486) and absent minded corporal and verbal attitude of Allen B. Holeman, Managing Director andChief Compliance Officer of Oppenheimer & Co., Inc. (CRD # (1060910) indicated to me thatOppenheimer & Co., Inc. knew well too much more than it pretended to.

Unfortunately for me, at that time, I had to be very cautious about revealing Venezuela professional dutiesof confidentiality. Had I known the content of the letter dated February 9, 2012, my disclosures wouldhave been broader and specific.

On February 29, 2012, as agreed upon on February 24, 2012, Luis Alejandro Aguilar Pardo sent to NewYork Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486) thefollowing documents:

Document 40.- Most recent time line.

Document 41.- Present structural diagram (functional diagram omitted).

About Fundación Pimjo A.C.:

Document 42.- Deed of Creation of Fundación Pimjo A.C.

Document 43.- Venezuela ID tax [certificate] of Fundación Pimjo A.C.

Document 44.- Last will of Josef Grootkerk.

About Pimjo Trust CV:Document 45.- Original Deed of Creation of Pimjo Trust CV,

Document 46.- Resolution of the original partners of Pimjo Trust CV dated July 19, 2001 by which newlimited partners were illegitimately admitted, namely: Josef Grootkerk, John Pettus, Francois Rene Méndezde Leon and Russ Dallen. At that moment. Pimjo Trust CV had a general partner named StichtingPanthalassa and four limited partners,

Document 47.- Certificate of Incumbency of Pimjo Trust CV dated July 19, 2001,





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Document 48.- Register of Partners as of Pimjo Trust as of July 19, 2001,

Document 49.- Participation Certificates number 1, 2, 3 and 4 issued by Pimjo Trust to Josef Grootkerk,John Pettus, Francois Rene Méndez de Leon and Russ Dallen.,

Document 50.- Resolution of the partners of Pimjo Trust dated July 19, 2001 appointing attorneys-in-fact,

Document 51.- Power of Attorney issued by Pimjo Trust dated July 19, 2001,

Document 52.- Resolution of the Partners of Pimjo Trust dated November 29, 2001 by which (i) StichtingPanthalassa is replaced by Stichting Pimjo Homeland in its role of general/managing partner and JosefGrootkerk Zeldenrust voluntarily, and Oppenheimer & Co., Inc. Caracas, Venezuela, branch officeemployees and brokers Francois C. R. Mendez de Leon (Central Registration Depository number 331918),Branch Manager John Gayle Pettus Jaso (CRD # 2415914) and Russell Morris Dallen Jr. (CentralRegistration Depository number 2445026) under demand are replaced by the Xavier Trust in their rolesof limited partners,

Document 53.- Resolution of the Partners of Pimjo Trust CV dated November 29, 2001 revoking the powerof attorney granted on July 19, 2001,

Document 54.- Register of Partners of Pimjo [Trust] CV as of November 29, 2001 (later [amended]),

Document 55.- Participation Certificate number 5 issued by Pimjo Trust CV on November 29, 2001 to TheXavier Trust,

Document 56.- Reinstated Deed of Creation of Pimjo Trust CV dated July 7, 2009 where the rules forAlternative Dispute Resolution for conflicts in Pimjo Trust CV are contained,

About Stichting Pimjo Homeland:

Document 57.- Deed of Creation of Stichting Pimjo Homeland dated December 28, 2000.

Document 58.- Extract of the Chamber of Commerce of Amsterdam dated January 3, 2001.

Document 59.- Decision of the Directors of Stichting Pimjo Homeland dated June 27, 2001 appointingJorge Redmond and Luis Alejandro Aguilar Pardo as the directors of Stiching Pimjo Homeland,

About Carisma Limited (the first trustee of the Xavier Trust was Carisma Limited. The first trustee CarismaLimited was replaced by the actual trustee: Carisma Prima Limited):

Document 60.- Resolution of the Shareholders of Carisma Limited dismissing Geoffrey P. P. Cone as





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director and instructing the creation of Carisma Prima Limited under the supervision of the NationalEnforcement Unit of New Zealand,

Document 61.- Resolution of the Shareholders of Carisma Limited by which the businesses of CarismaLimited were to be transferred to Carisma Prima Limited and ordering the removal of Carisma Limitedfrom the Register of Companies,

Document 62.- Resolution of the Shareholders of Carisma Limited authorizing several activities to beperformed on behalf of Carisma Limited,

About Carisma Prima Limited as Trustee of the Xavier Trust:

Document 63.- Resolution of Carisma Prima Limited as trustee of the Xavier Trust.

Document 64.- Deed of Retirement and Appointment by which Carisma Limited is replaced by CarismaPrima Limited as trustee of The Xavier Trust,

Document 65.- Inland Revenue Department Form 607 filed by Carisma Prima Limited as the trustee of TheXavier Trust with the Inland Revenue Department on July 21, 2009,

Document 66.- Inland Revenue Department Form 607 filed by Carisma Prima Limited as the trustee of TheXavier Trust with the Inland Revenue Department on July 20, 2011.

About Carisma Prima Limited as trustee of the Joseph Trust:

Document 67.- Deed of Assignment to Trust dated July 7, 2009 by which Stichting Pimjo Homelandassigns its participation as general/managing partner in Pimjo Trust CV to Carisma Prima Limited astrustee of the Joseph Trust,

Document 68.- Inland Revenue Department Form 607 filed by Carisma Prima Limited as the trustee of TheJoseph Trust with the Inland Revenue Department on July 21, 2009,

Document 69.- Inland Revenue Department Form 607 filed by Carisma Prima Limited as the trustee of TheJosephTrust with the Inland Revenue Department on July 20, 2011.

About Carisma Prima Limited.:

Document 70.- Resolution of the Shareholders of Carisma Prima Limited of November 4, 2011 acceptingresignation of director John Gayle Pettus Jaso,

Document 71.- Letter of resignation of John Gayle Pettus Jaso.Resolution of the Shareholders of Carisma





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Prima Limited on January 17, 2012 approving the process of revitalization of Carisma Prima Limited,

Document 72.- Resolution of the Shareholders dated February 3, 2012 ammending the Constitution ofCarisma Prima Limited adopting anti-corruption clauses.

Document 73.- Inland Revenue Department letter assigning IRD number.

Document 73.- Income Tax Return [Acknowledgments] [for fiscal years] ended 2008, 2009 and 2010.

Document 75.- Income Tax Return [for fiscal] year ended 31 May 2011.

Document 76.- IRS form 8822. Change of Address. February 6, 2012.

Document 77.- Documents used to open the Oppenheimer & Co., Inc. Account.

About Aguilar & Aguilar Limited:

document 78.- Deed of Nomination and Appointment of Beneficial Interest dated March 30 2009 (later[amended]).

On March 7, 2012, Luis Alejandro Aguilar Pardo received fron Allen B. Holeman, Oppenheimer & Co.,Inc. Managing Director and Chief Compliance Officer under instructions of Dennis P. McNamara,Oppenheimer & Co., Inc. Executive Vicepresident and General Counsel, a letter dated March 6, 2012together with a package containing statements of the Oppenheimer & Co., Inc. Account but none of theUMB Bank Acount.

Over the next several weeks, Luis Alejandro Aguilar Pardo made numerous phone calls and sent numerousemails to Oppenheimer & Co., Inc., demanding that Oppenheimer & Co., Inc. grant him full control overthe Oppenheimer & Co., Inc. Account and over the UMB Bank Account.

For example, in his email dated March 9, 2012, Luis Alejandro Aguilar Pardo stated Executive Vice-President and General Counsel Dennis P. McNamara (CRD # 2938486):

"Dear Messrs McNamara, Holeman and McGuire, I noted that theopening balance of the account in 2002 was US$ 8.4 m. I hadunderstood that the amount contributed by Mr Grootkerk wasbetween US$ 13.5 m. and US$ 15 m. I will check my records forassurances. Since the range of US$ 13.5 m. and US$ 15 m. was inthe mind of many persons, I will need to produce an explanation.Therefore, I would like to ask for your best efforts to search for thestatements of account from 1995 until 2000. I would very much





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appreciate that you recognize my authority immediately over theaccount as the legitimate representative of Pimjo Trust CV. As Isaid earlier, it was not within our plans to move the assets awayfrom Oppenheimer & Co. Inc. but I feel extremely insecure withOppenheimer & Co. Inc. I wish to share with you the panoramathat I am viewing and which makes me feel insecure and .(sic.).Please, feel free to comment, argue or clarify. It is somehow asfollows:1.- Oppenheimer & Co., Inc. operates irregularly a branchin Venezuela. 2.- Employees of Oppenheimer & Co., Inc. inVenezuela made an irregular transfer of the assets in 2002 whichmight have entailed the loss of 75% of the assets of PimjoOrganization. 3.- While the persons related with Pimjo thought theportfolio was worth between US$ 13.5 m. and US$ 15 m., theopening statement of Pimjo Trust CV shows the value of US$ 8.5m. 4.- The same persons mentioned under 2 supra managed seemto have been able to conceal from their employer their positions asdirectors of their client and seem to have been able to knowinglymanipulate the controls and procedures of their employer givenwhat might seem as misleading information concerning KYC andtax reporting. These interventions in th employer´s controls lastedfor status quo 9 years. 5.- We do not know yet how the personsmentioned under 2 supra were able to transfer funds out of theaccount of Pimjo Trust CV. 6.- One of the persons mentionedunder 2 supra has been reported by FINRA with a regulatory eventpresumably connected with lack of KYC supervision. 7.- You havemore than 47 days delaying recognition of my obvious andlegitimate powers to access the account. 8.- In the mean time, theaccount remains at risk lodged in your Caracas office, no one issupervising the account, there are no guidelines for investmentstrategies and your delays continue. I had hopes that we would hadbeen able to cooperate and work together. I do really hope thatthere are no private hidden agendas. This is a most disturbingsituation. Please, do proceed to grant me full and unrestrictedaccess to Pimjo Trust CV account upon which I will transfer theassets in the account while maintaining the account open withOppenheimer & Co., Inc. Best regards."

On March 13, 2012, Executive Vice-President and General Counsel Dennis P. McNamara (CRD #2938486) wrote to Luis Alejandro Aguilar Pardo:

"Mr. Aguilar:





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I apologize that you have called so often without my beingavailable. We are in the process of checking how far our statementsfor the account(s) go back. The account is restricted so no assetscan be removed from the account. We are trying to complete thereview of any questions we may have on the structure. You shouldbe aware that I have recieved correspondence from Mr. Redmondexpressing concern about our ceding control of the account to you.I have told him that he needs to consider recognizing you as havingcontrol of the account, working out an amicable resolution amongstyou and the other directors (or former directors) or be prepared totake legal action. I have not heard back from him as of today. Ihope to be in a position to send you our final open items todaywhen I know more about the statements."

Luis Alejandro Aguilar Pardo wrote an email again Executive Vice-President and General Counsel DennisP. McNamara (CRD # 2938486) on the very same March 13, 2012 stating the following:

"Dear Messrs McNamara, Holeman and McGuire,

Thank you very much for your email.

Thank you very much for letting me know that Mr. Redmond didsend you correspondence "…expressing concern about our cedingcontrol of the account to you."

Yesterday afternoon, we were considering that as the most probablecause of the delay in recognizing my authority and I was supposedto ask you that very same question today and - additionally - whetheror not you have received instructions contrary to my instructions.

It is of paramount importance to me to know the terms of the lettersent by Mr. Redmond to you since it might be the triggering eventto allow me to speak freely on this matter.

Would it be possible to send me a copy of such letter and of thecorrespondence exchanged with Mr. Redmond, please?

In accordance with Venezuelan law and our Code of Ethics, I willbe relieved from any limitations to tell the truth publicly and I willbe released from any professional secrecy duty if (1.-) Mr. Redmondhas made derogatory remarks about me and or my reputation and or





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my behavior or (2.-) if he initiates legal actions against me or PimjoTrust CV or Carisma Prima Limited or Aguilar & Aguilar Limited.

I am relieved that the account is restricted.

However that seems to me not to be enough for three reasons:

(1.-) It seems that there is 1/3 of the portafolio in cash earningalmost nothing,

(2.-) Arthur Lewis from your Boca Raton office pointed out to methat there were certain risky assets in the portfolio (and/or that somerestructuring was needed) and someone should oversee those assetsand

(3.-) it seems that there are no investing guidelines for the portfolioinstructing a conservative approach.

I would appreciate whatever it could be done regarding (2.-) and(3.-) supra since they would be [reasonable] actions aimed topreserve the portfolio and match my previous instructions toOppenheimer & Co., Inc.

I will start the process of creating the Advisory Committee thisafternoon.

If you wish to participate in this process, I can include you as aparticipant "Bcc" in my communications if that provides you withcomfort as to what we are doing is right, correct, legal and just.

Just let me know.

I am very sorry that this matter has set us apart.

Lastly, I wish to report that the approval of SunTrust Bank, N.A. iswell underway.

Best regards.

P.S.: I have given some thought to your status in Venezuela. I willshare with you my suggestions for you to consider with your local





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counsel in Venezuela after we finish with this assignment. I have nointerest whatsoever in any person getting into trouble that mightundermine our efforts to replace the existing group in control ofpolitical power in my country. Best". (Underlined added).


"I will look into the ability to share any communications to you. Ihave a mostly all day meeting tomorrow but will try and get back toyou Thursday or Friday of this week."

On March 13, 2012, Luis Alejandro Aguilar Pardo wrote to Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486):

"The following has nothing to do with the matter on hand. I havegiven some thought to your situation in Venezuela.

If I were you, I would look with your legal counsel in Venezuelainto the following matters:

(1.-) Having a permanent establishment in Venezuela may trigeertaxation of revenue earned in Venezuela by the Venezuelanpermanent establishment.

(2.-) You might wish to consider the effects of the treaty betweenUSA and Venezuela to avoid double taxation.

(3.-) Beware of the application of a law entitled "Ley para laDefensa de las Personas en el Acceso a los Bienes y Servicios"since you are directly rendering services within Venezuela.

(4.-) Note that "Ley para la Defensa de las Personas en el Accesoa los Bienes y Servicios"has specific rules concerning the "sectorfinanciero" and you might be included there. I am not sure aboutbrokerage services but the insurance industry is included withoutdoubt.

(5.-) All your employees in Venezuela are governed by the OrganicLabor Law which contemplates important severance payments toemployees. This law is supposed to be reformed this year going





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back to the superseded system which is much more expensive

(6.-) Be very cautious with your rendering of brokerage services inVenezuela and any actions taken in Venezuela destined to attractfunds towards your firm in USA. Brokerage firms have been[severely] targeted during past years.

All arguments seem very reasonable until there is an investigationconcerning legitimation of capitals or drug-related tainted moneyor illegitimate financial transactions. In such cases, all "reasonablearguments" are worthless. Best."


"Thank you. We have considered much of what you lay out belowbut perhaps we can discuss once we get past our present discussionof the Pimjo account.”

On March 14, 2012, Luis Alejandro Aguilar Pardo wrote to Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486) :

“Not a problem as long as my suggestions are considered as mereexploratory suggestions and it is done on a friendly and informalbasis to you (as a matter of professional courtesy) and not toOppenheimer & Co., Inc. I am not soliciting any business nor is itmy intention to be involved in your professional relationships inVenezuela which undoubtedly should be first class and mycomments are totally unconnected with the assignment of PimjoTrust CV. Best and good luck. I think you will succeed".

On March 23, 2012, Luis Alejandro Aguilar Pardo wrote to Messrs Lowenthal, McNamara, McGuire andHoleman another email in the following terms:

"Messrs Lowenthal, McNamara, McGuire and Holeman, Sixty dayshave elapsed since I requested for our protection the intervention ofthe Compliance Deparment of Oppenheimer & Co., Inc. and thismatter has not been solved."






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"Mr. Aguilar: This matter will be resolved next week. I have givenMr. Redmond until early next week to respond to me. I appreciateyour patience and again apologize for the length of time this reviewhas taken."

On March 23, 2012, Luis Alejandro Aguilar Pardo wrote to Messrs Lowenthal, McNamara, McGuire,Holeman, Lewis, Pettus and Redmond, another email in the following terms:

"Messrs Lowenthal, McGuire and Holeman,

Dear Mr. McNamara,

I very much regret that you have treated me the way you did. Youmay still be an excellent lawyer while being caring with others.

I spent 60 days cooperating with you.

Now, I propose to you that the game be different. It is called"tit-for-tat". I will reciprocate your actions. Your last action was tocontinue with your tactic of postponing and obstaculizing ourlegitimate interests.

This game - for your information - has the characteristic that itforgives previous predatory actions so it is up to you to avoid my nextaction. You must understand that your word is not something that I may relyupon. As I said, your delay tactics have a chronological unit of oneweek.

Today elapsed the term that I gave all directors of Chocolates El Rey,C.A. and Chocolates El Rey, Inc. on Sunday, March 18, 2012 to giveand [submit] their comments, clarifications, corrections, objectionsor protests to the Aviso al Comisario de Chocolates El Rey, C.A..

No answer was received.

Please find attached the final version thereof.

Mr Holeman, Mr McGuire and Mr. McNamara did receive the emailI sent to Mr. Jorge M. Redmond S., the directors and the shareholders





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of certain companies asking to come forward.

It was sent Tuesday, March 20, 2012.

As you have seen, none has come forward and no one ever will.

The most important part of that document is what I believe still to bethe truth even though certain unexplainable circumstances mighttemporarily show otherwise: "La persona que yo conocí en Ud [JorgeM. Redmond S.] es una persona buena, generosa y honesta."

Today the document "Aviso al Comisario" is being delivered to theComisario de Chocolates El Rey, C.A..

Since you and Mr. Redmond do believe in the power and merits of"letters", another letters are being sent, following your example, tothe Compliance Officers of 14 commercial banks in Venezuela,namely: Banco Exterior, Banco Mercantil, BANESCO, BancoNacional de Crédito, Banco Venezolano de Crédito, BancoVenezuela, Banco Provincial, Norvalbank (BOD), Central, BancoUniversal, CORPBANCA, Banco Caroní and Banco Banplus.

Since the Compliance Officers of those banking institutions arecompelled to notify the financial regulatory authorities in Venezuelaand not even the presidents and directors of such banks areempowered to stop their respective Compliance Officers,

I will wait for my next actions which will involve a denunciationbefore the Office of the General Prosecutor, the Superintendente delas Instituciones del Sector Bancario and the Presidente del Fondo dePtotección Social de los Depósitos Bancario.

The end result will be an investigation of the facts mentioned in thedocument "Aviso al Comisario".

It is possible that banks declare all loans to Chocolates El Rey, C.A.in default and that action might accelerate the bankruptcy ofChocolates El Rey, C.A. and the layover of all its employees.

However, their directors and shareholders have acted so arrogantlythat they may feel to be beyond the reach of the law and reason.





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Since the process of denunciation has started already, I am liberatedfrom any duty of professional secrecy. Unfortunately, it may not bestopped now.

Please find attached the Aviso al Comisario. In this document I relatefacts and circumstances that - after the proper corporate,administrative and judicial actions and investigations - translate intothe possibility of criminal prosecution.

The charges that may be pressed against the resulting responsiblepersons (who might eventually coincide with your protectees) are:

Under the Ley General de Bancos y Otras Instituciones Financierasand for actions from August 19, 2010 up to and including December28, 2010, the violation of its article 381 (Providing false informationto perform banking transactions) which is punished with jail for aterm from 8 to 10 years.

Under the Ley de Instituciones del Sector Bancario and for actionfrom December 28, 2010 up to an including the date hereof, theviolation of its article 213 ([Misappropriation] and distraction ofresources of the banks) which is punished with jail for a term from 10to 15 years and a fine of 100% of all resources extracted from thebanking sector via loans or otherwise using false financial statements.

Under the Código Orgánico Tributario, the violation of its articlesdealing with tax frauds which is punished with jail for a term of 6months to 7 years.

Under the Criminal Code, the violation of its articles dealing withfraudulent bankruptcy which is punishable with jail for a term of 3 to5 years.

Add up the maximum jail terms because of eventual concurrence ofconducts, add the fact that this might be considered plain white-collarcriminal actions against the general public and might qualify asfrauds to the banking systems and reach your own conclusions.

Please find below a table showing the above mentioned information.

[Table and quotations of articles violated have been omitted]





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Unfortunately, I have to go back to Caracas, Venezuela. Even thoughI do not believe it and consider it absolutely impossible to happen,five of my colleagues - all respectable lawyers - have expressed inwriting concerns for my well being while in Venezuela.

They claim - and I do not believe them, of course, since otherwise Iwould not dare to go there - to have heard stories of persons that are"invited" against his or her will to certain informal meetings duringwhich they are "convinced" to adopt or abandon certain actions. Theyeven claim to have heard stories of persons who are arrested becauseceratin substances are "[mystically]" found in their luggage whilegoing through customs.

They change their minds in another way which you can see at ourwebsite www.aguilar.pro, "Conflicto 23-03-2012" (the date hereof,by the way), "La Masacre de Uribana". You may visit it directly athttp://www.aguilar.pro/conflicto2332012/lamasacredeuribana.html.

As you may observe, my website is already loaded with alldocuments, emails, evidences, and supporting documents. Today, theaccesses to those sections are protected. But, if something happens tome, precautions have been taken in order to secure my succession,open up the libraries and to continue this unfortunate story. Actually,Monday morning I am executing my last will.

With respect to Oppenheimer & Co., Inc. I had no quarrel and I hopethat your next action is known to me before mine is executed. Unlesssomething extraordinary happens, it is not my intention - now andtoday - to contact you.

I personally make you responsible, together with Jorge M. RedmondS. and his collaborators, for all sufferings of the children that mighthave suffered because of your tactics.

You will never know but if I learn of one, I will let you know. InChaos Theory, it is known as the Butterfly Effect where small actionshave [immense] effects in non-linear systems. Anyhow, that is up toyou to fix.

Since you operate in Caracas, I imagine that you have means to havethe documents that I have drafted in Spanish translated into English.





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Do not blame Johnny Pettus for not telling these facts. He was boundunder a Confidentiality Agreement which I attach.

Nothing said has the intention of offending anyone or to initiate astruggle or to cause harm.

Best regards.”

Together with the above quoted email, Executive Vice-President and General Counsel Dennis P.McNamara (CRD # 2938486) received:

Document 79.- Aviso al Comisario de Chocolates El Rey, C.A. Document 80.- Actual proofs of criminal actions perpetrated by exdirectors of Carisma Prima Limited.

On March 24, 2012, Luis Alejandro Aguilar Pardo wrote to Messrs Lowenthal, McNamara, McGuire,Holeman, and Lewis, the following email:

“Messrs Lowenthal, Mr. McNamara and McGuire,

Dear Mr. Holeman,

As you well know, the first objective that I pursued was toincorporate in this matter the Office of the Chief ComplianceOfficer of Oppenheimer & Co., Inc. for the protection of theinstitution that I represent and my own protection.

Today, Saturday, March 24, 2012, at 8:10 am, a new developmenttook place: I received by email the sixth warning.

This time, it comes from a person with a background different fromthe legal profession. I believe in this person more than in the swornin statements of one million public notaries.

After quoting him literally, I will freely translate his words intoEnglish as best as I can:

‘Sé que podrás salir legalmente adelante pues te asiste la razón yla ley, y podrás limpiar a Pimjo de todos estos personajes en quienconfiaste, pero no dudo que por su peso social específico tutranquilidad y hasta tu vida corren peligro.’





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I know that you will be able to succeed legally because you areassisted by reason and law, and that you will be able to clean Pimjofrom all those persons whom you trusted but I have no doubts thatdue to their social specific weight your tranquility and even yourlife are in danger. (Free translation. Please verify with your ownsources).

I myself in my heart fervently wish to believe that the author of thequoted words is mistaken. Reason and probabilities, nevertheless,should also be allowed to influence [decisions].

Therefore, I have to requests:

1.- Protect my life and my [family], and2.- Tell me the truth of what you know.

In order to achieve the first and paramount objective, I herebyrequest that Oppenheimer & Co., Inc. assumes the cost and hire theservices of Mr.Jesús Briceño (+58-414-372.6582) in order toascertain the probabilities of the occurrence of any risks.

I am perplexed by so many conflicting situations, conducts and[statements]. It seems to me that you know something that I do notand that you are hiding something that I can not figure out what itis.

Your Mr. Lewis in Boca Raton told me that "the lawyers" wereexamining my instructions [and] supporting documents. Someonein your organization induced, or made, or allowed, me to believethat such "lawyers" were Sullivan & Cromwell.

Suddenly, the members of that firm [whom] I had contacts with, cutall communications with me. Sergio Galvis was unable or refusedto receive me in New York, at their offices at 125 Broad Street onFebruary 24, 2012.

On February 24, 2012 I had my only meeting with Mr. McNamara(General Counsel), Mr. Holeman (Chief Compliance Officer), Mr.McGuire (Deputy General Counsel Director of Litigation). Only afourth gentleman present whose name I can not recall had read allthe material. Mr. Holeman seemed to have had some general





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knowledge of the supporting documents. Mr. McNamara and Mr.McGuire (the "lawyers") had none.

The issue of the registered address being used for the account wasbrought up again during that meeting. That address "CCS 82586.PO BOX 025323, MIAMI FL 33102-5323" is the same addressused in your unauthorized Oppenheimer & Co., Inc.-connectedchecking account number 26201338505041 at certain UMB Bank,N.A. (ABA 101278856) whose signatory is John Gayle Pettus Jaso.

I give you actual notice that such address should be connected witha forwarding agent named Mail Boxes Etc. that seem to be[physically] located at 2250 NW 114th Avenue, Unit 1C, Miami,FL 33172-3652 and in Venezuela at MBE VENEZUELA CCA,Avenida Orinoco entre Calles Mucuchíes y Perijá, Edificio L&M,Pent House, Las Mercedes, Baruta, Caracas. Tel.+58-212-992.2120, +58-212-992.6781 and +58-212-991.1277.

Why are you still sending the statements of the account to theaddress "CCS 82586. PO BOX 025323, MIAMI FL 33102-5323"having actual knowledge that such address is not the correctaddress and you know that you have reasons to believe that suchaddress is wrong and strange.

I have asked you to investigate the account at UMB Bank, N.A.which is clearly identified with Oppenheimer & Co., Inc..

You are very well aware that a rogue [management] of the checkingaccount is dangerous.

You are also aware that, to the best of my knowledge, it is notpossible that the signatory in October 18, 2004 of check number1004 had authority to open such account or [mobilize] funds.

I have asked you for the statements of this account and toinvestigate it. Report what have you done about it, please?

Mr. McNamara affirmed that the access of the account wasrestricted but I saw in the statement for the period ended February29, 2012 that some one was capable of moving funds.





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The Money Market Funds were reduced from $4.104.536,55 to $2.533.928,95 during February 2012 even though I had requested theintervention and protection of the Office of the Compliance Officeron January 23, 2012.

Investments [decisions] involving more than US$ 1.500.00,00 havebeen made while you know that the legitimacy of the tradingauthorities and investments profiles may have been compromised.

I expressly asked you to find out the trading strategy of Mr. JohnGayle Pettus Jaso and you have failed to do so.

Several persons are surprised that the account had $ 4.104.536,55in cash by the end of January 2012 which is 34,85% of Total ValueAsset. They claim that the return of those $ 4.104.536,55 is 0,01%p/a.

One other factor aggravating these conflicting situations is that Mr.McNamara had expressed since February 24 that he would reviewthe supporting documents - even during a weekend, I recall - andthat he would come back to me with certain questions.

Then, after repeating several times the same pattern, heacknowledged that the truth was that he was giving time to Mr.Jorge M. Redmond S. in order to do something; perhaps initiatinglegal actions.

Had Mr McNamara been truthful from the beginning, I would nowbelieve in him.

The factor is even more sour since Mr McNamara knows that theDeed of Creation of Pimjo Trust CV has specific rules for solvingconflicts via mediation and arbitration.

The other disturbing factor is that Mr. McNamara mentioned thathe gave Mr. Jorge M. Redmond S. until early next week to respondto Mr. McNamara who had previously affirmed that he had"…received correspondence from Mr. Redmond expressingconcern about our ceding control of the account to you…"

There are letters and there are letters. I might write to a letter to a





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financial institution stating that I express my concern about the wayPresident Obama is managing his account (wherever he might haveit) and you would find it absurd that the receiving financialinstitution [acknowledge] to President Obama after several weeksthat his account os restricted and that "…I have told him that heneeds to consider recognizing you as having control of the account,working out an amicable resolution amongst you and the otherdirectors (or former directors) or be prepared to take legal action."

Mr.McNamara and Mr. McGuire have not delivered to me a copyof the letter or correspondence sent to him by Mr. Jorge M.Redmond S. as I requested.

I can not imagine that the Vice President and General Counsel ofOppenheimer & Co., Inc. would restrict an account just becausesomeone has merely expressed her concerns.

Therefore, Mr. Jorge M. Redmond S. should have mentioned somegrounds which should have been serious and grave enough as torestrict the account in order to allow him at least 31 days to beginto respond to the Vice President and General Counsel ofOppenheimer & Co., Inc. Please kindly send me a copy of suchletter. I do need it and I deserve to have it.

I have been advised to strike first and initiate criminal actionsagainst certain individuals in Venezuela. I have mentioned that -knowing the conditions of the jail and detention [institutions] inVenezuela as you may ascertain in the following link -http://www.aguilar.pro/conflicto2332012/lamasacredeuribana.html- I will never do that since I am not that kind of person.

I wrote back to my advisor the following and, as before, afterquoting him literally, I will freely translate his words into Englishas best as I can:

"No estoy de acuerdo con recurrir a la vía penal para resolverconflictos de dinero.

Dada las condiciones carcelarias y penitenciarias en Venezuela, meparece que sería un delito contra la humanidad.





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¿Qué me diferenciaría del SS-Obersturmbannführer Adolf OttoEichmann?

Yo no soy así. Por cierto, una debilidad mia es que Redmond sabecomo pienso en este sentido.

Si no puedo lograr que prevalezca la razón, prefiero vivir con lahumillación de ser un fracasado que cargar con la culpa de actosinhumanos."

I am not in agreement to pursue criminal actions to solve moneyrelated conflicts.Due to the jails and penitentiaries conditions in Venezuela, Ibelieve that it would be a crime against humanity.¿What would make me different from SS-ObersturmbannführerAdolf Otto Eichmann?I am not that way. By the way, one of my weaknesses is thatRedmond knows how I think on this matter.If I can not achieve that reason prevail, I´d rather live with thehumiliation of being a failure than to carry the burden of guilt forinhuman acts. (Free translation. Please verify with your ownsources).

I do not wish that fate for me so if you know something, please, letme know.

I sincerely hope you will not be my SS-ObersturmbannführerOppenheimer & Co., Inc..

I wish that you treat me with transparency, honesty andtruthfulness. Really, believe me, there is no need to be uncaring toothers in order to be succesful in life.@

As asserted in the draft of Interpleader Complaint circulated by Executive Vice-President and GeneralCounsel Dennis P. McNamara (CRD # 2938486) on August 2, 2012:

“On March 26, 2012, counsel for Messrs Redmond, Alfonzo, Toroand Ms. Redmond sent a letter to Oppenheimer & Co., Inc. objectingto Aguilar's demands. Counsel's letter again references severalalleged resignations by Aguilar as a director of Pimjo Trust, as well





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as Aguilar's alleged improper refusal to make books and records ofPimjo Trust available to its directors, and the subsequent allegedwrongful removal of all of Pimjo's Trust's directors, aside fromhimself. In closing, counsel's letter advises Oppenheimer & Co.,Inc., "We must also reserve our right to question any decision onyour part to give [Aguilar] access to the funds without allowing usto make a proper review of documentation which you indicateempowers him to make the changes he apparently made." A copyof the March 26th letter is annexed hereto as Exhibit F.”

On March 28, 2012, Luis Alejandro Aguilar Pardo wrote to Messrs Lowenthal, McNamara, McGuire,Holeman, and Lewis, the following email:

"Messrs Lowenthal, Mr. McNamara and McGuire,

Mr. Holeman,

Please find quoted below, the email that I received from Ms.Michelle L. Sullivan, Vice President, Director of FiduciaryCompliance, IWM & Corporate Compliance Assessment Team,UMB Financial Corporation.

‘Mr. Aguilar-We are in receipt of your inquiry regarding the Pimjo Trust CVaccount. After further review we have identified that the check inreference is drawn off an Oppenheimer & Co., Inc. account thatclears their accounts through UMB Bank. In this case our client isOppenheimer & Co., Inc. and we are not authorized to share anyfurther information related to this account. I would suggest youcontact Oppenheimer & Co., Inc. directly at 1 (800) 225-5677 sothey can further assist you.It is anticipated that this correspondence has been responsive to yourrequest, but if there are additional questions or concerns that I cananswer, my contact information is below. Respectfully, Michelle L. SullivanVice President Director of Fiduciary ComplianceIWM & Corporate Compliance Assessment TeamUMB Financial Corporation’





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I had the impression that you had told me on February 24 thatOppenheimer & Co., Inc. did not have any connection with thisaccount. I think that I was lead to believe that you had noinformation on this account.

Would you, please, provide me with the information requested:opening documents, authorized signatories and statements of theaccount?

Let me share with you, Mr. Holeman, that I take this matter very[seriously] and I am very sensitive with these issues.

In 1991 - 1992, my life and the life of my wife and my - then - foursons were threatened by a Colombian drug cartel because I acted asone of the many attorneys in the case UNITED STATES OFAMERICA (plaintiff) vs ALL FUNDS ON DEPOSIT IN THEACCOUNTS OF CERTAIN INDIVIDUALS AND ENTITIES ATCERTAIN FINANCIAL INSTITUTIONS AND ALL FUNDSDEPOSITED INTO SAID ACCOUNTS OR TRANSFERRED TO,THROUGH AND OR BY SAID FINANCIAL INSTITUTIONSFOR THE BENEFIT OF SAID INDIVIDUALS AND ENTITIES(defendant), Civil Action No. CV-91-0881 (Warrant for Arrest ofArticle in Rem), Judge Thomas C. Platt, U.S. District Court for theEastern District of New York. I know how it feels receiving threatsof [kidnaping], bombs, [assassinations], and being unable to obtainprotection from any authority anywhere.

Mr. McNamara,

Would you please authorize UMB Bank NA to grant me full accessto this account and to share with me the information they have aboutthis account?

Have you received a response from Mr. Jorge M. RedmondSchlageter?

Thank you very much”

The continuance of the events may be found back under the explanations given on paragraph 24at page 34of this document whose merits are hereby reproduced and incorporated by reference.





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On May 8, 2012, Luis Alejandro Aguilar Pardo filed a petition for judicial assistance in Venezuela.

On May 9, 2012, Luis Alejandro Aguilar Pardo filed a report at Ministerio del Poder Popular para lasRelaciones Interiores y Justicia of República Bolivariana de Venezuela.

On May 10, 2012, Luis Alejandro Aguilar Pardo filed a report at Superintendencia de Instituciones delSector Bancario of República Bolivariana de Venezuela.

On May 10, 2012, Luis Alejandro Aguilar Pardo filed a report at Superintendencia Nacional de Valoresof República Bolivariana de Venezuela.

On May 10, 2012, Luis Alejandro Aguilar Pardo filed a report at Fondo de Protección Social de losDepósitos Bancario of República Bolivariana de Venezuela.

On May 18, 2012, Luis Alejandro Aguilar Pardo filed a report at the Office of the General Prosecutor ofRepública Bolivariana de Venezuela.

On July 10, 2012, Luis Alejandro Aguilar Pardo filed a report at Dirección General de Inspección yFiscalización of Ministerio del Poder Popular de Planificación y Finanzas.

On August 7, 2012, Luis Alejandro Aguilar Pardo filed FINRA Complaint 1960837 at the FinancialIndustry Regulatory Authority of the United States of America.

On August 8, 2012 Luis Alejandro Aguilar Pardo filed SEC Complaint TCR1344465787941 at theSecurities and Exchange Commission of the United States of America.

Timely, Luis Alejandro Aguilar Pardo sent to New York Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486) the following documents:

Document 81.- Request for FINRA Mediation,

Document 82.- Report file at Ministerio del Poder Popular para las Relaciones Interiores y Justicia ofRepública Bolivariana de Venezuela.

Document 83.- Report filed at Superintendencia de Instituciones del Sector Bancario of RepúblicaBolivariana de Venezuela.

Document 84.- Report filed at report at Superintendencia Nacional de Valores of República Bolivarianade Venezuela.

Document 85.- Report filed at Fondo de Protección Social de los Depósitos Bancario of República





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Bolivariana de Venezuela.

Document 86.- Report filed at the Office of the General Prosecutor of República Bolivariana deVenezuela.

Document 87.- Report filed at Dirección General de Inspección y Fiscalización of Ministerio del PoderPopular de Planificación y Finanzas.

Document 88.- Proceeds of CEDCA Mandatory Mediation initiated in Caracas, Venezuela.

Document 89.- Proceeds of frustrated agreement of August 2, 2012.

Document 90.- FINRA Complaint 1960837 filed at the Financial Industry Regulatory Authority of theUnited States of America.

Document 91.- SEC Complaint TCR1344465787941 filed at the Securities and Exchange Commission ofthe United States of America.

On September 4, 2012, Luis Alejandro Aguilar Pardo sent to New York Executive Vice-President andGeneral Counsel Dennis P. McNamara (CRD # 2938486) et al.:

Document 92.- Draft of FINRA Expanded Complaint 1960837 to be filed at the Financial IndustryRegulatory Authority of the United States of America for their review prior to delivery to FINRA and SEC.

Your Sincerely,

Luis Alejandro Aguilar P.

Encl.: Draft of Interpleader Complaint circulated by Executive Vice-President and General CounselDennis P. McNamara (CRD # 2938486) on August 2, 2012.





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1. We have seen documents where the last name is written “Mendes” and in other “Méndez”. It

corresponds to the last name of Francois René Constance Méndez de León (CRD # 331918) or Francois R. C.

Méndez de León or René Méndez de León.

2. Central Bank of Venezuela.

3. Commission for the Administration of Foreign Exchange.

4. Foreign Exchange Operators.

5. Bolivars is the currency of legal tender in Venezuela.

6. We have seen documents where the last name is written “Mendes” and in other “Méndez”. It

corresponds to the last name of Francois René Constance Méndez de León (CRD # 331918) or Francois R. C.

Méndez de León or René Méndez de León.

7. Bolivars is the currency of legal tender in Venezuela.

8. We used the figure of a non-for-profit civil law partnership with foundational character because in

Venezuelan law the foundation technically speaking may end up controlled by the State. In order to avoid the

interference of governmental entities, we appeal to the figure of a non-for-profit civil law partnership, we add to

it a foundation character and incorporate the word “fundación” in the name of the entity.

9. Formerly Banco Venezolano de Crédito, S. A.

10. Fahnestock & Co., Inc. is, later on, replaced by Oppenheimer & Co., Inc. status quo 2003 because of a

name change or an acquisition and a name change. In both firms worked and/or work Messrs. Francois René

Méndez de León (now deceased), Russell M. Dallen, Jr. and John Gayle Pettus Jaso who have been the persons

managing the portfolio. The portfolio is now lodged with Oppenheimer & Co., Inc., under the title of Pimjo

Trust CV and is being managed directly by John Gayle Pettus Jaso. We are aware of the possible existence of an

account with a bank named UMB Bank, N. A., number 26201338505041.

11. Due to the fact that the portfolio formerly owned by Pimjo, S. A. was transferred to Pimjo Trust, CV,

the effectiveness of the last will vis-a-vis the transfer of the shares of Pimjo, S. A. was not significant.

Endnotes.