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The investigation that gave rise to this SEC lawsuit is about Vuuzle TV, Vumu Music, and its motion picture studio and Television production company in Dubai. The SEC filled a fraud case against the company and Flynn without every seeking out any information whatsoever from Vuuzle during its investigation.
There were no requests to Vuuzle to provide information voluntarily. There were no administrative subpoenas to Vuuzle. Voluntary requests or administrative subpoenas to the corporation with active business operations which are usual hallmarks of a fair fact-finding regulatory investigation that should precede any SEC Enforcement action.
There was not even a Wells Notice to afford Vuuzle the opportunity to dissuade the SEC from filing a case. Undoubtedly, to the SEC’s dismay, Vuuzle answered the Complaint, disputing the SEC’s narrative and conveying that Vuuzle is a real company with brick-and-mortar buildings housing a state-of-the-art studio in the United Arab Emirates, functioning operations in the Philippines and Las Vegas, and employing staff across its creative, marketing, and programming multi-media departments.
BRIEF OF VUUZLE MEDIA CORP. IN OPPOSITION TO PLAINTIFF’S MOTION FOR ENTRY OF PROTECTIVE ORDER
Now the SEC wants this Court to put its imprimatur on the SEC’s limitless and discretionary use of discovery that the SEC will receive in litigation – under and subject to Fed. R. Civ. P. 26(b)(1) – for purposes well beyond what the SEC itself previously decided was unnecessary and irrelevant during and to advance its investigation.
The SEC and Department of Justice working closely in parallel investigations indicted Ronald Flynn charging that Vuuzle was not real when in fact anyone who has a mobile phone or CPU can download the free application and watch free TV and listen to free music.
Vuuzle has produced over a 2-year period its own content with more than 500 prime time TV shows including news, special interest shows, dramas, and sports which can be seen on www.Vuuzle.tv
The rouse by the SEC and DOJ includes a threat to one of the directors of Vuuzle TV who is a retired dentist age 73, Dr. Richard Marchitto. The AUSA Jenifer Weir along with the FBI have threatened the Doctor to close all the bank accounts down at Vuuzle TV or she would be put him in jail.
The fact is the government did no investigation and there is no evidence to prove any of their claims. This is vendetta and a fraudulent investigation tainted by the FBI and S.E.C that has their fingerprints all over it.
Rather than abide by the Federal Rules of Civil Procedure that govern all parties in civil litigation, the SEC’s proposed language in a protective order attempts to manipulate the Protective Order so that the SEC may continue to use litigation-sourced discovery from its own a la carte menu of “Routine Uses,” all invariably to the detriment of the Defendants and their ability to defend against the SEC’s allegations.
Vuuzle would prefer even to prohibit the transfer of any discovery to the Department of Justice, Vuuzle believes it is constrained by the language of the two referenced statutes. There is a fundamental lack of fairness and denial of equal protection attendant to enabling the SEC to advance the work of DOJ, where DOJ is desperately trying to shore up a criminal case against someone not even in its custody but against whom it made public a returned indictment for the apparent purpose of circuitously disparaging the Defendant company in the SEC’s civil proceeding.
The case against Mr. Ronald Flynn is untrue and false. Vuuzle Media is a real entity while both the S.E.C and the F.B.I continuing to call and send letters to shareholders in an all-out attempt to spread disinformation and untrue statements to close the company down.
Voluntary requests or administrative subpoenas to a corporation with active business operations are hallmarks of a fair fact-finding regulatory investigation that should precede any SEC Enforcement action. There was not even a Wells Notice to afford Vuuzle the opportunity to dissuade the SEC from filing a case. Undoubtedly, to the SEC’s dismay, Vuuzle answered the Complaint, disputing the SEC’s narrative and conveying that Vuuzle is a real company.
Flynn wrote his response while in the hospital the DOJ. Once his statement was received the FBI and weir arranged a grand jury to file a inditement against Flynn for mail fraud.
Flynn then replied in a article that can be seen in this link.
On April 8, 2021, Attorney Jacob Frenkel the attorney for Vuuzle wrote,
See link below for original article
https://www.law.com/legalnewswire/news.php?id=2860128
“Wednesday’s indictment of Vuuzle Media Corp. founder Ronald Shane Flynn by the U.S. Attorney’s office in Los Angeles seeks to perpetuate, indeed, even to memorialize, a series of false and faulty assumptions about Vuuzle Media that the U.S. Government first advanced through the Securities and Exchange Commission (SEC) when the SEC filed its civil complaint against the company in January of this year.
Now, as then, it is absolutely essential that we present a fair and accurate record of what Vuuzle Media is, and its place in the realm of readily available, globally accessible, free media.
First, let’s focus on what Vuuzle Media is not. Unlike the brash contentions made first by the SEC and now the DoJ, Vuuzle Media is not, nor has it ever been, a “Ponzi scheme.” Vuuzle Media is not, nor has it ever been, a shell company covering for a “boiler room”-enabled cash generating scheme, characterized by “aggressive” selling tactics with no measurable returns for the company’s investors.
To the readily verifiable contrary, Vuuzle Media is an award-winning, multi-continental, multi-platform, multi-capability media company whose intention is to play a leading role in restoring balance to the international media landscape by providing free video, musical and social media-driven programming for audiences worldwide.
Vuuzle Media is administered by a fully functioning Board of Directors, and the company has offices and studio space in multiple cities world-wide, with state-of-the-art studios in the United Arab Emirates. Vuuzle Media creates its own proprietary programming, it continues to develop revolutionary new means for its advertisers to interact with its vast audiences, and for those audiences to interact directly with its creators and hosts, as well as with high-level international talent who appear directly on its video streaming services.
In short – Vuuzle Media is an entertainment sector disruptor, and one whose global importance is all the more vital during pandemic-era restrictions and lockdowns. Vuuzle, via its app and streaming services, seeks to democratize entertainment in ways that at once harken back to the era of free, over-the-air television, while catapulting audiences into new realms of immediacy and interaction.
Vuuzle’s audiences are just as much a part of the entertainment experience as are its content creators. Vuuzle Media isn’t a ploy or a ruse. It’s a media landscape revolutionary force. Vuuzle Media is aggressively contesting the SEC’s allegations and has filed a response on the public record denying the SEC’s substantive allegations (https://rb.gy/uofnbx).
Additionally, and very importantly, Vuuzle Media is not a defendant or accused party in any DoJ case, so it is unclear why DoJ felt uncharacteristically compelled to include in its April 7th press release a discussion of Vuuzle Media in a manner that appears to be inconsistent with DoJ policy, fails miserably to distinguish between multiple companies with the Vuuzle Media name, and recycles the old news of an actively contested SEC civil lawsuit that was filed three months ago.
Today in a statement by Flynn, He said, Vuuzle Media Corp Limited is real company set up offshore in the United Arab Emirates. We will continue to create TV programs and deliver movies and music 24 hours a day. It is our intention to continue being a disrupter in Media as we believe free entertainment backed by advertising is fair and profitable for all.
