1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

AUSTIN DIVISION 

________________________________________________ 

SECURITIES AND EXCHANGE COMMISSION, § 

 § 

 Plaintiff, § 

 § 

v. § 

 § 

META 1 COIN TRUST, § 

ROBERT P. DUNLAP, individually and d/b/a § Civil Action No.: 1:20-cv-273-RP 

CLEAR INTERNATIONAL TRUST, § 

NICOLE BOWDLER, and DAVID A. SCHMIDT, § 

 § 

 Defendants, § 

§ 

and § 

 § 

PRAMANA CAPITAL, INC., § 

PETER K. SHAMOUN a/k/a PETER K. SHAMOON, § 

WANDA IRONHEART TRAVERSIE-WARNER, § 

ALFRED DEWITT WARNER JR. § 

AND IRONHEART TRUST, § 

 § 

Relief Defendants. § 

________________________________________________§ 

DECLARATION OF CAROL HAHN 

I, Carol Hahn, do hereby declare under penalty of perjury, in accordance with 28 U.S.C. 

§1746, that the following is true and correct, and that I am competent to testify to the matters 

stated herein. 

1. I am currently employed as a Staff Accountant with the United States Securities 

and Exchange Commission (the “Commission”) in its Fort Worth Regional Office in Fort Worth, 

Texas. I have been employed by the Commission since April 2005. I hold a B.S. in Economics 

from Texas A&M University. I am a Certified Fraud Examiner. The facts set forth herein are 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 1 of 42
2 

based upon my personal knowledge or upon information contained in the files of the 

Commission. 

2. As a Staff Accountant with the Commission, my responsibilities include, but are 

not limited to, analyzing financial records of non-public corporations, partnerships, limited 

liability companies, other entities, and individuals. During the course of these responsibilities, I 

routinely trace financial transactions to determine how they occurred and their ultimate 

disposition, summarize that information and data into various schedules and charts, and testify to 

such at hearings and trials. 

3. As part of my official duties, I have been involved in the Commission 

investigation of, and subsequent litigation against, Defendants Meta1 Coin Trust (“Meta1”), 

Robert Dunlap (“Dunlap”) individually and d/b/a Clear International Trust (“Clear”), Nicole 

Bowdler (“Bowdler”), and David Schmidt (“Schmidt”) (collectively, “Defendants”), Relief 

Defendants Pramana Capital, Inc. (“Pramana”) and Peter K. Shamoun a/k/a Peter K. Shamoon 

(“Shamoon”) (together, “Shamoon Relief Defendants”), and Warner Relief Defendants Ironheart 

Trust (“Ironheart Trust”), Wanda Ironheart Traversie-Warner (“Traversie”), and Alfred Dewitt 

Warner Jr. (“Warner”) (collectively, “Warner Relief Defendants”), to determine whether there 

have been violations of the federal securities laws in connection with the offer and sale of 

investment contracts in the form of a purported digital currency called the Meta 1 Coin (“the 

Coin”). 

Meta1 Continues to Raise Investor Funds 

4. Dunlap and Meta1 continue to operate and market the investment scheme through 

various means, including its website (https://meta1coin.vision), social media,1

 Zoom calls with 

 

1

 Meta1’s LinkedIn page states that Meta1 “provide[s] the liquidity of gold.” 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 2 of 42
3 

investors and prospective investors, in-person seminars, and on an internet radio show 

(https://www.thejimpriceshow.com). Meta1’s current White Paper now claims that the Meta1 

Coin is backed by $8.8 billion in gold assets (up from $2 billion claimed gold assets in March 

2020). By comparison, the current reported value of United States Treasury-owned gold held in 

reserve at Fort Knox is approximately $6.2 billion. See Status Report of Gold Reserve, available 

at https://fiscaldata.treasury.gov/datasets/status-report-government-gold-reserve/u-s-treasuryowned-gold. Meta1 continues to falsely claim that it is free from U.S. government oversight.

5. As recently as September 12, 2022, Meta1/Dunlap sent an email blast to investors 

and prospective investors inviting them to join the Meta1 “Executive Team” at a “Meta1 

Workshop” to be held in Las Vegas, NV on September 24, 2022. The email featured Dunlap as 

a speaker at the event, and listed the “current value” of the Meta1 Coin at $377. It originally 

sold for $22.22. A true and correct copy of the email sent to investors is attached hereto as 

Exhibit 1.

6. Dunlap continues to operate the Meta1 scheme through various Meta1 associates. 

From the start of the scheme through March 16, 2020, when the Court entered its temporary 

restraining order and imposed an asset freeze [Doc. 8] (the “Initial TRO”), a significant portion 

of the Meta1 investor proceeds were sent or deposited into accounts controlled by the Shamoon 

Relief Defendants, as previously outlined in my declarations dated March 13, 2020 [Doc. 3-2] 

and May 14, 2020 [Doc. 53-1]. 

7. Following the Initial TRO, the Commission discovered $1,317,261 in uncashed 

Meta1 investor checks in Shamoon’s possession. That amount was not included in the agreedupon disgorgement amount of $7,457,998 ordered by the Court against the Shamoon Relief 

Defendants on February 3, 2021 [Doc. 113 (Agreed Final Judgment)]. Shamoon has paid 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 3 of 42
4 

$1,519,817.79 of that amount. Approximately $1.4 million of that was turned over from frozen 

accounts. 

8. After the Court froze Shamoon’s accounts, Meta1 investor funds were directed to 

accounts controlled by the Warner Relief Defendants, as set forth in my declaration dated May 

14, 2020 [Doc. 53-1] in support of the Commission’s application for an asset freeze in 

connection with its Amended Complaint. 

9. After the Court froze the Warner Relief Defendants’ accounts [Doc. 54], Meta1 

investor funds were directed to accounts controlled by Meta1 board member Richard Grassie 

(“Grassie”).2

 

Bank Record Analysis 

10. As part of my official duties in this case, I have reviewed and analyzed bank 

records and other documents to determine the sources and use of funds in connection with the 

Defendants’ efforts to raise money from investors through the offer and sale of the Coin. 

Following the flow of funds, the Commission obtained, and I reviewed, bank records for 

accounts controlled by Grassie. Grassie continued a pattern established by Meta1 and Dunlap: 

open and use a bank account for a short period of time, deposit investor funds, spend investor 

funds on purposes not disclosed to investors, including the withdrawing of investor funds using 

cashier’s checks to pay other related third parties, and then open a new bank account at a 

different bank to repeat the process again. 

11. I reviewed accounts held in the name of Grassie at Arvest Bank, U.S. Bank, N.A. 

(“U.S. Bank”), JPMorgan Chase Bank, N.A. (“JPM Chase”), Navy Federal Credit Union 

 

2

 Grassie was listed in at least one version of Meta1’s whitepaper as a board member. 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 4 of 42
5 

(“NFCU”), Regions Bank, and Wells Fargo Bank, N.A. (“Wells Fargo”) (collectively, “Grassie 

Bank Accounts”).3 Those accounts are as follows: 

Bank Name Account Name Account No. 

(Last 4 Digits) 

Date 

Opened 

Wells Fargo Richard T Grassie -7375 6/26/2018 

U.S. Bank Richard Thomas Grassie -4370 Unknown 

NFCU Richard T Grassie -1588 04/20204

JPM Chase Richard T Grassie -7780 7/14/2020 

Regions Bank Richard T Grassie -7219 4/27/2021 

Arvest Bank Richard Thomas Grassie -1476 4/29/2021 

12. The Commission obtained, and I also reviewed records for accounts controlled by 

Grassie held at Paypal Holdings, Inc. (“Paypal”), Coinbase, Inc., American Express, and Capital 

One, N.A. 

13. Coinbase, Inc. (“Coinbase”) is an online platform for buying selling, transferring, 

and storing cryptocurrencies. Grassie appeared to be operating his Coinbase account like a passthru account where he would transfer money in from his bank accounts, convert to a 

cryptocurrency and send out to various crypto wallets owned by unknown individuals/entities. 

He would also receive cryptocurrencies in, convert to USD, and then transfer to his bank 

accounts. 

14. In total, from May 2020 to December 2021,5

 the Grassie Bank Accounts received 

at least $3,366,411 in Meta1 investor funds or potential Meta1 investor funds from at least 300 

 

3

 Grassie also took out a mortgage loan with Citizens Bank that he defaulted on for a property at 16623 

Wheat Mill Lane, Houston, TX 77095. I am also aware that Grassie has accounts at other financial 

institutions but the Commission has not obtained records for those accounts. 

4

 Account opening documents provided by NFCU were illegible. April 2020 is the first statement date 

provided by the bank. 

5

 This includes funds obtained through Paypal and Coinbase. 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 5 of 42
6 

investors located across the U.S. and from Canada, Australia, New Zealand, and Germany. 

Investors used wire transfers, cashier’s checks, money orders, and checks made out to Grassie to 

make their investments. The memo descriptions on some of these investments include such 

statements as “Meta 1 certificate,” “Meta 1 coin,” “Investment,” “Gold investment,” and 

“purchase of stock.” 

15. The Grassie Bank Accounts had a combined account balance of $38,003.28 as of 

December 2021.6

 

16. After Meta1 investor funds are deposited into the Grassie Bank Accounts, 

Grassie generally distributes the investor funds as follows: he pays other Meta1-related 

individuals, including Penny Cummings (employee), Kevin Job (board member), Marianne 

O’Malley (employee), the Warner Relief Defendants, Justin Morris (Meta1’s COO), Suzanne 

Bertolas (employee), and Ioana Dragan (affiliated with Shamoon), and companies, including 

Artheas Progeny Trust (Kevin Job Trustee), he pays bills including credit card and loan 

payments, and he withdraws cash as cashier’s checks made payable to himself and other Meta1 

employees. The bank records also show a number of payments and wire transfers to unknown 

individuals. 

17. The investor funds that went to third party companies were then, in part, 

transferred back and forth between these company accounts and Grassie’s accounts, transferred 

or wired to other entities, used to pay Meta1-related individuals and other expenses of the 

companies, including rent. I also reviewed Grassie’s credit card statements which were paid 

with Meta1 investor funds and found that expenses were both personal and potentially related to 

Meta1 expenses, with the majority of funds spent on marketing services. 

 

6

 For certain of the Grassie Bank Accounts, the ending balances were prior to December 31, 2021. 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 6 of 42
7 

18. During this same period, Meta1 (through Grassie) issued refunds to investors 

from the Grassie Bank Accounts in a total amount of $138,556. 

19. In addition to Grassie, Meta1 investors sent their investments to Meta1 employee 

Penny Cummings. The Commission obtained, and I reviewed records for accounts controlled by 

Cummings at USAA Federal Savings Bank. Cummings received at least $230,000 from three 

Meta1 investors. In addition to Cummings receiving Meta1 investor funds directly, she also 

received $416,813 of investor funds from the Grassie Bank Accounts. 

Updated Amount of Investor Funds Raised and Investor Totals 

20. Based on my review of updated Meta1 bank records, Warner Relief Defendants 

account records, Shamoon Relief Defendants account records, Grassie Bank Accounts, and the 

Cummings accounts, between April 1, 2018 and December 31, 2021, Meta1 raised at least 

$15,250,847.22 from at least 800 investors in 40 states and 8 foreign countries.7

 

21. Neither Dunlap and his entities, nor Bowdler, nor the Warner Relief Defendants 

produced any kind of accounting, as the Court ordered them to do. Thus, the Commission’s 

calculations are reasonably approximate, based on the information available to it through 

subpoena responses from known third parties. 

Use of Investor Proceeds 

22. To calculate the total amount of disgorgement among all of the parties, I started 

with the total amount of investor funds raised of $15,250,847.22, and subtracted $1,317,260.86 

in uncashed investor checks and $482,373.47 in investor returns. The total amount of ill-gotten 

gains realized among the parties is $13,451,212.89. 

23. The Meta1 investor funds were commingled in the accounts and spent as follows: 

 

7

 This includes $1,317,260.86 in uncashed Meta1 investor checks received by Shamoon. 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 7 of 42
8 

Overall Use of Investor Funds 

Item Description / Entity Name Total Spent 

Shamoon Controlled Accounts $7,457,998 

Individuals/Entities (affiliated with Meta1/Shamoon) $2,422,436 

Personal Expenses/Other $1,496,392 

Individuals/Entities (unknown association/purpose) $516,405 

Withdrawals (unknown reasons) $497,985 

Credit Card & Loan Payments $398,859 

Unknown Use $389,938 

Coinbase Inc. $271,200 

Total $13,451,213

Disgorgement and Prejudgment Interest Calculations 

24. As part of my analysis, I calculated the Defendants’ and Werner Relief 

Defendants’ reasonably approximate disgorgement in connection with the Coin offering. To 

arrive at the disgorgement amount, I started with the amount of known investor funds they 

received and deducted any refunds to investors or uncashed checks. 

25. Meta1 and Dunlap, either directly or indirectly, through accounts Dunlap and 

others controlled, including Shamoon, Grassie, and Cummings, received at least $14,133,530.47 

in investor funds. Meta1 and Dunlap acted together as one economic unit, commingling investor 

funds and using them as one account. From the total amount raised, I subtracted $1,519,817.79 

paid back by Shamoon, $1,317,260.86 in uncashed checks, $427,465.35 in investor refunds, and 

$19,210 paid to Schmidt leaving a total disgorgement of $10,849,776.47. From this amount, 

$3,370,916.78 is owed by Meta1 jointly and severally with Dunlap, $5,938,180.21 is owed 

jointly and severally between Meta1, Dunlap and the Shamoon Relief Defendants, and 

$1,540,679.48 is owed jointly and severally between Meta1, Dunlap and Bowdler. 

26. The Shamoon Relief Defendants jointly and severally with Meta1 and Dunlap 

originally owed $7,457,998 in disgorgement; however, Shamoon paid $1,519,817.79 of that 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 8 of 42
9 

amount (which I subtracted) leaving $5,938,180.21 still owed. 

27. Bowdler received at least $1,540,679.48 in Meta1 investor funds. Bowdler 

ultimately deposited and commingled most of those funds in Meta1 bank accounts controlled by 

Dunlap and Meta1-related individuals. It is not possible to trace what happened to the money 

Bowdler received beyond that point, as Dunlap had a pattern of closing bank accounts and 

moving funds to new accounts. 

28. A true and correct copy of portions of Schmidt’s deposition transcript is attached 

hereto as Exhibit 2. Schmidt admitted in his deposition that Dunlap paid him approximately 

$2,000 per month for six to seven months via online transfers or cashier’s checks. He received 

$5,000 of investor funds from the Warner Relief Defendants, and another $19,210 from Meta1 

and Dunlap. This amount is a low approximation, because it does not include money he received 

from his workshops where he pitched Meta1 investors, as those amounts are unknown. 

29. The Warner Relief Defendants received at least $1,117,316.75 in investor funds 

after accounting for amounts transferred to Meta1 or affiliated entities that is included under 

Meta1 and Dunlap above. From this amount I subtracted out investor refunds ($54,908.12) and 

amounts paid to Schmidt ($5,000). This left $1,057,408.63 of investor funds in their possession, 

to which they have no legitimate claim. Traversie and Warner are a married couple who both 

control Ironheart, and investor funds were commingled in accounts held in all three of their 

names. Both individuals and the entity they control equally possess Meta1 investor funds, and it 

is not possible to apportion amounts among them. 

30. To calculate prejudgment interest (“PJI”) on the Commission’s calculated 

disgorgement amounts, I used a prejudgment interest calculator. This calculator uses an annual 

interest rate based on the rate used by the Internal Revenue Service to calculate underpayment 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 9 of 42
10 

penalties.8 Exhibit 3 attached to this Declaration reflects the calculator’s prejudgment interest 

calculations for the Defendants and Relief Defendants for the period beginning March 16, 2020 

through September 1, 2022. 

31. In summary, the disgorgement amounts and prejudgment interest calculations are 

summarized in the chart below, along with requested civil penalty amounts: 

32. A true and correct copy of a Meta1 “news alert” sent via email blast on June 13, 

2022 is attached hereto as Exhibit 4.

 

8

 That rate is defined as the Federal short term rate plus three percentage points. See 26 U.S.C. § 

6621(a)(2). 

9

 This amount excludes the amount the Commission has collected from the Shamoon Relief Defendants. 

Party Disgorgement PJI Penalty Total 

Meta1 and Dunlap, jointly and 

severally

$10,849,776.47 $939,183.45 $10,849,776.47 $22,638,736.39 

 Of that total disgorgement: 

Meta1 and Dunlap, jointly 

and severally 

$3,370,916.78 $291,794.87 

Meta1/Dunlap, jointly and 

severally with Shamoon Relief 

Defendants 

$5,938,180.219 $514,023.55 

Meta1/Dunlap jointly and 

severally with Bowdler

$1,540,679.48 $133,365.03 

Bowdler, jointly and severally with 

Meta1/Dunlap 

$1,540,679.48 $133,365.03 $1,540,679.48 

(individual 

penalty) 

$3,214,723.99 

Schmidt $24,210.00 $2,095.68 $24,210.00 $50,515.68 

Warner Relief Defendants, jointly 

and severally 

$1,057,408.63 $91,531.90 N/A $1,148,940.53 

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 10 of 42
11 

33. True and correct copies of screen prints of the LinkedIn pages of Meta1 and 

Nicole Bowdler are attached hereto as Exhibit 5. Although Bowdler’s LinkedIn page lists her 

name as “Nicole M.,” the photo image of her is identical to the photo of Bowdler on Meta1’s 

Whitepaper (also attached hereto as part of Exhibit 5), and her middle name is Marie.

I declare under penalty of perjury that the foregoing is true and correct. 

Dated: September 21, 2022 

 Carol Hahn Carol Hah

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David Schmidt 

8/12/2020

(424) 239-2800

GRADILLAS COURT REPORTERS

1

1 IN THE UNITED STATES DISTRICT COURT

2 FOR THE WESTERN DISTRICT OF TEXAS

3 AUSTIN DIVISION

4

5 SECURITIES AND EXCHANGE COMMISSION, ) Civil Action No.

 ) 1:20-cv-273-RP 

6 Plaintiff, )

 )

7 v. )

 )

8 META 1 COIN TRUST, )

ROBERT P. DUNLAP, individually and d/b/a )

9 CLEAR INTERNATIONAL TRUST, )

NICOLE BOWDLER, and DAVID A. SCHMIDT, )

10 )

 Defendants, )

11 )

 and )

12 )

PRAMANA CAPITAL, INC., )

13 PETER K. SHAMOUN a/k/a PETER K. SHAMOON, )

WANDA IRONHEART TRAVERSIE-WARNER, )

14 ALFRED DEWITT WARNER JR., and )

IRONHEART TRUST, )

15 )

 Relief Defendants. )

16 _________________________________________)

17

18

19 VIDEO DEPOSITION OF DAVID ALAN SCHMIDT 

20 VIA VIDEOCONFERENCE

21 Wednesday, August 12, 2020

22

23

Reported by:

24 Marcia S. McEntee

CSR No. 13399

25 Job No. 200812MSM

2

1 IN THE UNITED STATES DISTRICT COURT

2 FOR THE WESTERN DISTRICT OF TEXAS 

3 AUSTIN DIVISION 

4 SECURITIES AND EXCHANGE COMMISSION, ) Civil Action No.

 ) 1:20-cv-273-RP 

5 Plaintiff, )

 ) 

6 v. ) 

 ) 

7 META 1 COIN TRUST, ) 

ROBERT P. DUNLAP, individually and d/b/a ) 

8 CLEAR INTERNATIONAL TRUST, ) 

NICOLE BOWDLER, and DAVID A. SCHMIDT, ) 

9 ) 

 Defendants, ) 

10 ) 

 and ) 

11 ) 

PRAMANA CAPITAL, INC., ) 

12 PETER K. SHAMOUN a/k/a PETER K. SHAMOON, ) 

WANDA IRONHEART TRAVERSIE-WARNER, ) 

13 ALFRED DEWITT WARNER JR., and ) 

IRONHEART TRUST, ) 

14 ) 

 Relief Defendants. ) 

15 _________________________________________) 

16

17

18 Video deposition of DAVID ALAN SCHMIDT, 

19 taken on behalf of Plaintiff in Sedona, Arizona, 

20 beginning at 8:07 a.m. PDT and ending at 2:03 p.m. PDT, 

21 on Wednesday, August 12, 2020, all parties appearing 

22 remotely via WebEx videoconference, before Marcia S. 

23 McEntee, Certified Shorthand Reporter No. 13399.

24

25

3

1 APPEARANCES:

2

3 For Plaintiff SEC:

4 UNITED STATES SECURITIES AND EXCHANGE COMMISSION

 BY: JENNIFER D. REECE, ESQ.

5 Burnett Plaza, Suite 1900

 801 Cherry Street, Unit 18

6 Fort Worth, Texas 76102

 817-978-6442

7 reecej@sec.gov

8 For Defendant David A. Schmidt:

9 -- IN PRO PER --

 DAVID ALAN SCHMIDT

10 2519 North Ocean Boulevard, Number 413

 Boca Raton, Florida 33431

11 928-254-0287

 daveschmidt@msn.com

12

For Relief Defendants Pramana Capital and Peter Shamoun:

13

 SHEPPARD, MULLIN, RICHTER & HAMPTON

14 BY: JOSEPH JAY, ESQ.

 2099 Pennsylvania Avenue, NW, Suite 100

15 Washington DC 20006

 202-747-1900

16 jjay@sheppardmullin.com

17 Also Present:

18 James Etri

 Angela Stewart

19

Videographer:

20

 Daniel Ortega

21

22

23

24

25

4

1 INDEX

2 WITNESS EXAMINATION

3 DAVID ALAN SCHMIDT

4 BY MS. REECE 8

5 BY MR. JAY 239

6

7 EXHIBITS

8 EXHIBIT NO. DESCRIPTION PAGE

9 Exhibit 1 Investigative subpoena dated 7/31/19 78

Exhibit 2 Meta 1 Coin white paper 84

10 Exhibit 3 10/3/18, Sedona Connection radio show 132

 transcript

11 Exhibit 4 4/24/19, Sedona Connection Radio Show 168

 transcript

12 Exhibit 5 10/9 program transcript 176

Exhibit 6 11/6/19, radio program transcript 191

13 Exhibit 7 1/15/20, radio program transcript 194

Exhibit 8 1/29/20, Blog Talk radio program 199

14 transcript

Exhibit 9 2/12/2020, radio program transcript 205

15 Exhibit 10 Temporary Restraining Order and other 220

 and other orders entered 3/16/20

16 Exhibit 11 3/24/2020, newsletter 223

Exhibit 12 Notice of Nonconsent 3/24/20 226

17 Exhibit 13 4/1 Cosmic Connection Blog Talk 227

 transcript

18 Exhibit 14 Order in contempt issued 4/21/20 232

Exhibit 15 Letter witness wrote to Judge Pitman 235

19 filed in Court 4/14/2020

20

21

22

23

24

25



2

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 21 of 42
David Schmidt 

8/12/2020

(424) 239-2800

GRADILLAS COURT REPORTERS

21

1 Q But your hesitating on that. Do you --

2 A Well, I have some money that I invested in Meta 1

3 Coin --

4 Q Oh.

5 A -- that has a cash value of about $6,300. So

6 that would be my other financial account.

7 But those four bank accounts, the two brokerage

8 accounts, and the Meta 1 account, that is the total sum of

9 all of my financial assets.

10 Q Okay. So you had $6,300, you said. Is that the

11 amount that you've invested in Meta 1 Coin?

12 A Yes. That is what I -- what I call the "cash

13 value."

14 Q Okay. Do you know any of the accounts where

15 Meta 1 investor money is located?

16 A No.

17 Q Do you have control over any of those accounts?

18 A None whatsoever.

19 Q Did investor funds that you know of ever go into

20 your account?

21 A No.

22 Q Do you own a home?

23 A I have received no money from Meta 1 whatsoever.

24 Q Okay. We'll talk about that in a little bit, the

25 distinction, because you have received money from

22

1 Robert Dunlap; correct?

2 A Yes.

3 Q Okay. And have you received money from any other

4 entity that Robert Dunlap is related to?

5 A No.

6 Q So you received money from Clear International

7 Trust?

8 A No.

9 Q Okay. And we'll talk about the details of that

10 in a minute.

11 Do you own a car?

12 A Yes.

13 Q What kind of car?

14 A A 2012 Kia Sorento.

15 Q And do you own a home?

16 A No.

17 Q Any other assets do you own that are valued over

18 a thousand dollars?

19 A Honda Gold Wing motorcycle.

20 Q Anything else?

21 A No.

22 Q What is your annual income? Or monthly, if it is

23 easier?

24 A Well, it was depending. See, when I was doing my

25 workshops, you know, a couple years ago, I was receiving

23

1 3- to $5,000 from each one, but that went down to only

2 receiving about 2,000. But I haven't done a workshop now

3 in five months. I used to do them about every three

4 weeks. So without doing the workshops, my annual income

5 is only around $24,000 a year.

6 Q And in 2019 before COVID and you were unable to

7 do the workshops, what would you say your annual income

8 was?

9 A Probably around maybe 60- to 70,000.

10 Q Did you file a tax return?

11 A I haven't yet. I haven't filed an '18 or '19 tax

12 return.

13 Q Why haven't you?

14 A Because I don't owe anything, so I just haven't.

15 Q Do you intend to?

16 A Yes.

17 Q So let's talk about the money that you received

18 from Robert Dunlap. I think you told the Court that you

19 currently receive a monthly amount from him; is that

20 correct?

21 A I was receiving $2,000 a month from him for

22 probably about six to seven months. And that was to help

23 subsidize my living expenses.

24 Q And did you perform work for him?

25 A No.

24

1 Q So that was just -- he just gave you that money

2 for nothing?

3 A Yes, yeah, yeah. Well, I mean I moved to Florida

4 to basically be near him again, so other reasons that are

5 there. And my living expenses in Florida went up over

6 two thousand to two and a half thousand dollars a month

7 when I was living in Sedona.

8 Q How -- how is it paid -- how does he pay you the

9 $2,000 a month --

10 A The first two or three months, it was basically

11 an online transfer, and after that it was a cashier's

12 check.

13 Q When is the last time you were paid from him?

14 A Would have been in -- let's see -- April -- April

15 or May.

16 Q And how did he -- how did you get paid? In a

17 cashier's check?

18 A It was a cashier's check, yeah. Yes.

19 Q Do you know what account he paid you from?

20 A No.

21 Q Do you know what Mr. Dunlap's sources of income

22 are?

23 A All I know is he is a master market trader, and

24 he makes a lot of money trading markets. He is very, very

25 good at it. That is what I know.

23 A I have received no money from Meta 1 whatsoever.

24 Q Okay. We'll talk about that in a little bit, the

25 distinction, because you have received money from

1 Robert Dunlap; correct?

2 A Yes.

22

22 Q What is your annual income? Or monthly, if it is

23 easier?

24 A Well, it was depending. See, when I was doing my

25 workshops, you know, a couple years ago, I was receiving

1 3- to $5,000 from each one, but that went down to only

2 receiving about 2,000. But I haven't done a workshop now

3 in five months. I used to do them about every three

4 weeks. So without doing the workshops, my annual income

5 is only around $24,000 a year.

6 Q And in 2019 before COVID and you were unable to

7 do the workshops, what would you say your annual income

8 was?

9 A Probably around maybe 60- to 70,000.

10 Q Did you file a tax return?

11 A I haven't yet. I haven't filed an '18 or '19 tax

12 return.

13 Q Why haven't you?

14 A Because I don't owe anything, so I just haven't.

15 Q Do you intend to?

16 A Yes.

17 Q So let's talk about the money that you received

18 from Robert Dunlap. I think you told the Court that you

19 currently receive a monthly amount from him; is that

20 correct?

21 A I was receiving $2,000 a month from him for

22 probably about six to seven months. And that was to help

23 subsidize my living expenses.

24 Q And did you perform work for him?

25 A No.

1 Q So that was just -- he just gave you that money

2 for nothing?

3 A Yes, yeah, yeah. Well, I mean I moved to Florida

4 to basically be near him again, so other reasons that are

5 there. And my living expenses in Florida went up over

6 two thousand to two and a half thousand dollars a month

7 when I was living in Sedona.

8 Q How -- how is it paid -- how does he pay you the

9 $2,000 a month --

10 A The first two or three months, it was basically

11 an online transfer, and after that it was a cashier's

12 check.

13 Q When is the last time you were paid from him?

14 A Would have been in -- let's see -- April -- April

15 or May.

16 Q And how did he -- how did you get paid? In a

17 cashier's check?

18 A It was a cashier's check, yeah. Yes.

19 Q Do you know what account he paid you from?

20 A No.

21 Q Do you know what Mr. Dunlap's sources of income

22 are?

23 A All I know is he is a master market trader, and

24 he makes a lot of money trading markets. He is very, very

25 good 

24

at it. That is what I know.

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 22 of 42
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213

1 operation.

2 Q That is not what he said.

3 You said -- you asked the question, "How many

4 people are you looking to hire within the next two

5 months?" Nothing about "public."

6 A That is -- he's not going to hire 200 people

7 right now when the coin isn't even public, and it can't --

8 and they can't move a lot. That is common sense.

9 Q He told investors they --

10 A That was his intention --

11 Q -- would. So when you told investors that, that

12 was just false?

13 A Jennifer, put your common-sense hat on.

14 Q It's on.

15 A Bad question.

16 No, it's not. You're making insinuations that

17 are -- that are inaccurate.

18 Q He's telling people -- I mean, it's in

19 black-and-white, and it's also on audio -- that he will be

20 hiring 200 people, most of them -- a lot of them from your

21 listeners. He says they seem like ideal candidates. I

22 don't know how he knows that, but seem like ideal

23 candidates in the next two months, and that was --

24 A Yes.

25 Q -- true.

214

1 A -- and -- and we already talked about -- we had

2 already talked about that in a previous conversation, and

3 it's about potentially doing that when the coin was going

4 to go public.

5 Q And you did --

6 A And wasn't able to do that.

7 Q You didn't tell that to investors?

8 A What does this have to do with a legal document

9 before a court? That is an opinion issue.

10 Q What?

11 A This feels like an entrapment question from

12 you --

13 Q I don't --

14 A I want to be very direct with that.

15 Q Simple --

16 A It's like you're trying to entrap me in something

17 that has no legal basis whatsoever. So let's get back to

18 the factual questions.

19 Q I'm talking about factual questions, what you

20 told investors. You did not tell investors that he was

21 going to hire 200 --

22 A Jennifer, drop it. Drop it. Drop it.

23 Q Don't scream at me. You can lower your voice and

24 behave.

25 A I will scream at you if I want to scream at you.

215

1 And -- fucking file charges against you for what you've

2 done against me if you keep this up.

3 Q You need to calm down.

4 A You flat-out -- a million dollars, an absolute

5 flat-out lie. I can bring criminal charges against you if

6 I want to for what you've done to me.

7 Q What kind of charges do you --

8 A Let's come back to the factual questions.

9 Q Okay. You need to calm down and stop cussing.

10 A How do you -- I will say what I want to say. You

11 don't just tell me what I can say. Okay.

12 Q Please calm down. I'm asking you to calm down

13 because --

14 A You're the one who is going to be on the

15 defensive. You're going to have to define for a judge why

16 you accused me of stealing a million dollars when you have

17 absolutely no facts for that. How are you going to

18 explain that before a judge?

19 Q I --

20 A I can't hear you.

21 Q I simply asked you to stop screaming and to calm

22 down.

23 A Okay. I will be calm.

24 You're the one who is going to have to explain

25 for a judge why you accused me of stealing a million

216

1 dollars when you have absolutely no facts whatsoever, and

2 I testified here that I had none of that money. I've

3 never received a dime of that money.

4 Q Okay --

5 A And you knew that back in my statement back in

6 April that I had nothing when I made that statement in

7 that -- in that radio program that I had that I never

8 received a dime from Meta 1.

9 You knew it all the way back then, but you still

10 filed these charges against me. And you're still trying

11 to hold to them. What is your facts? What is -- what is

12 your truth that I did any of that? You don't have any.

13 You're going to be the one that is going to have

14 to answer that before a judge, not me.

15 Q I'm fine with that. You and I have differing

16 opinions on that. And I will be happy to show you the

17 evidence, which by the way, are you planning on

18 participating in this lawsuit since you've not filed an

19 answer?

20 A What lawsuit?

21 Q The lawsuit that you're here testifying in, the

22 one that was filed in Federal Court against you.

23 A I will talk to my counsel about that -- what I

24 will do.

25 Q Who is your counsel?

3 You said -- you asked the question, "How many

4 people are you looking to hire within the next two

5 months?" Nothing about "public."

6 A That is -- he's not going to hire 200 people

7 right now when the coin isn't even public, and it can't --

8 and they can't move a lot. That is common sense.

9 Q He told investors they --

10 A That was his intention --

11 Q -- would. So when you told investors that, that

12 was just false?

13 A Jennifer, put your common-sense hat on.

14 Q It's on.

15 A Bad question.

16 No, it's not. You're making insinuations that

17 are -- that are inaccurate.

18 Q He's telling people -- I mean, it's in

19 black-and-white, and it's also on audio -- that he will be

20 hiring 200 people, most of them -- a lot of them from your

21 listeners. He says they seem like ideal candidates. I

22 don't know how he knows that, but seem like ideal

23 candidates in the next two months, and that was --

24 A Yes.

25 Q -- true.

1 A -- and -- and we already talked about -- we had

2 already talked about that in a previous conversation, and

3 it's about potentially doing that when the coin was going

4 to go public.

5 Q And you did --

6 A And wasn't able to do that.

7 Q You didn't tell that to investors?

8 A What does this have to do with a legal document

9 before a court? That is an opinion issue.

10 Q What?

11 A This feels like an entrapment question from

12 you --

13 Q I don't --

14 A I want to be very direct with that.

15 Q Simple --

16 A It's like you're trying to entrap me in something

17 that has no legal basis whatsoever. So let's get back to

18 the factual questions.

19 Q I'm talking about factual questions, what you

20 told investors. You did not tell investors that he was

21 going to hire 200 --

22 A Jennifer, drop it. Drop it. Drop it.

23 Q Don't scream at me. You can lower your voice and

24 behave.

25 A I will scream at you if I want to scream at you.

214

1 And -- fucking file charges against you for what you've

2 done against me if you keep this up.

3 Q You need to calm down.

4 A You flat-out -- a million dollars, an absolute

5 flat-out lie. I can bring criminal charges against you if

6 I want to for what you've done to me.

7 Q What kind of charges do you --

8 A Let's come back to the factual questions.

9 Q Okay. You need to calm down and stop cussing.

10 A How do you -- I will say what I want to say. You

11 don't just tell me what I can say. Okay.

12 Q Please calm down. I'm asking you to calm down

13 because --

14 A You're the one who is going to be on the

15 defensive. You're going to have to define for a judge why

16 you accused me of stealing a million dollars when you have

17 absolutely no facts for that. How are you going to

18 explain that before a judge?

19 Q I --

20 A I can't hear you.

21 Q I simply asked you to stop screaming and to calm

22 down.

23 A Okay. I will be calm.

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 23 of 42
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GRADILLAS COURT REPORTERS

217

1 A I'm not telling you my counsel at this time.

2 First of all, I don't know yet. I'm in the process of

3 acquiring counsel.

4 Q Okay. But as you sit here today, you're not

5 represented by any counsel?

6 A I'm in the process of acquiring counsel.

7 Q But, again, to answer the question, currently you

8 are not represented by counsel?

9 A No, not currently.

10 Q Okay.

11 A I can't hear you. You didn't come through.

12 Q Okay. So go to page 67 of Exhibit 9. Caller

13 comes in and asks you and Mr. Dunlap -- he says, "Dave and

14 Robert, the assets are backed today by about two billion;

15 is that correct?"

16 And Dunlap says, "Yes, right now."

17 And the caller says, What sorts of distribution

18 are the types of asset? Gold, silver, real estate, fine

19 art, gold mining, stock? What is the spread on the

20 portfolio of the assets that back the coin?"

21 And Mr. Dunlap says, "So right now Article 5, you

22 have to have 6 percent of metal in vault for your

23 issuance, and we are falling within that standard."

24 The caller says, "Physical metals?"

25 He says, "Yes."

218

1 And you say, "But as far as standard, it's pretty

2 close to the highest standard you can get for having your

3 assets verified."

4 And then he goes on, says some other stuff and

5 basically answers the question with, "All gold,

6 100 percent gold."

7 So what -- what did you mean when you said that?

8 Your response to the caller was what? Explain --

9 A I --

10 Q -- that.

11 A -- don't know. I'd have to -- I -- I don't know.

12 I don't know how to answer.

13 Q Well --

14 A I don't know how to answer that question. I

15 don't know what I meant by that.

16 Q Okay. So as you sit here today, do you have any

17 understanding of, like, what standard you're talking

18 about, what this Article 5 is?

19 A Well, my understanding of the standard is,

20 again -- is in the independent auditing firm, third-party

21 independent audit. That is the standard. That is how I

22 recall it.

23 Q Okay. So at this point you're telling investors

24 in February of 2020 that the one -- the $2 billion in

25 assets is 100 percent in gold. I guess that's it; right?

219

1 A I -- I didn't say that. That is what Mr. Dunlap

2 said.

3 Q Okay. But you agreed with it?

4 A That was his statement.

5 MS. REECE: Okay. You can close that out.

6 So I want to talk a little bit about the

7 temporary restraining order that was entered in this case.

8 Oh, you know what? Before we do that, let's go

9 off the record.

10 Are we off the record?

11 THE VIDEOGRAPHER: The time is now 1:12 p.m. We

12 are off the record.

13 (A brief recess was taken.)

14 THE VIDEOGRAPHER: The time is now 1:26 p.m.

15 We're back on the record.

16 MS. REECE: Okay. Let me show you --

17 (Deposition was interrupted.)

18 MS. REECE: All right. Okay. I'm going to show

19 you what we've marked as Exhibit 10, and I'm sure you've

20 seen it before. I will show you on the screen.

21 That -- okay. Exhibit 10 is the temporary

22 restraining order and other orders that were entered in

23 this case on March 16th, 2020, and it is Document Number 8

24 on the Court's docket.

25 Do you recognize this document?

220

1 THE WITNESS: Yes. Vaguely.

2 (Plaintiff's Exhibit 10 was marked for

3 identification.)

4 BY MS. REECE:

5 Q Well, have you read it?

6 A Well, I read it back when it came through but not

7 recently.

8 Q Well, you understand that there are several

9 provisions in here that you're required to comply with;

10 correct?

11 A Yeah. I will do that now.

12 Q Okay. So I just want to kind of skip down to the

13 section -- the paragraph on accounting. Hold on one

14 second.

15 MS. REECE: Angela, can you mute? I'm having

16 some technical issues. All right. I don't know what is

17 going on, but. Okay.

18 BY MS. REECE:

19 Q Let's look at the accounting provision paragraph

20 12, which is page 14 of this document. Have you seen this

21 before?

22 A Yes.

23 Q And you will see that if you read the second

24 sentence, that you're required to file a sworn accounting.

25 Actually, start at the first sentence. It says that you

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 24 of 42
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GRADILLAS COURT REPORTERS

233

1 parts of the Court's order requires you to take down some

2 of the statements that you have made that are publicly

3 available regarding Meta 1?

4 A Show me where they are, so I can take them down.

5 I don't know which ones those would be.

6 Q Well, I mean we just went through a few of them,

7 the further exhibits, that audio files that -- where

8 you're talking with Mr. Dunlap --

9 A Okay.

10 Q -- promoting --

11 A I will go back. Now, all right. I can't access

12 that program here because it has a password that I can't

13 remember what it is. I will be able to do that when

14 I get to the computer at home, and I will just -- I will

15 work on it.

16 Q Okay. Did you talk to Mr. Dunlap about the

17 contempt order before you were actually arrested?

18 A Briefly, yes.

19 Q What did you say?

20 A I don't recall what I said. Just the fact that,

21 you know, we didn't know if it is -- I mean I took his

22 lead. He was the one that said that he didn't want to

23 show up. And I was not in a position to go against him at

24 the time.

25 And looking back, I should have been responsible

234

1 for myself. And, you know, this is where I've, you know,

2 made, you know, change to my position on it because I'm

3 not working with Meta 1 on this issue. It's just me here

4 now.

5 And so, you know, I was surprised it took five

6 weeks from the time that Judge Pitman put the order out

7 before they arrested -- I was under the impression it

8 wasn't going to seriously happen because it had taken so

9 long.

10 Q Do -- so you said you're not working with Meta 1

11 anymore. Are you saying now that you're not going to talk

12 about Meta 1 at any point?

13 A Not until this stuff is cleared up.

14 Q Okay. So you're not actively -- right now you're

15 not actively encouraging your listeners to go out and

16 invest in Meta 1 Coin?

17 A No. I'm saying -- I basically -- I mean you can

18 go back and listen to my last three or four programs. I

19 say, "Folks, I'm not talking about Meta 1. I'm not going

20 to talk about that until this issue is cleared up. People

21 need to make their own decisions what they are going to

22 do, but I'm not telling you to go do anything."

23 I'm staying away from it until this is cleared

24 up.

25 Q Okay. And, then, there is another thing I'm

235

1 going to show you. I'm going to show you what we've

2 marked as Exhibit 15, and this is a letter that you wrote

3 to Judge Pitman. Looks like it was filed by the Court on

4 April 14th, 2020, and it is Document 42 on the Court's

5 docket.

6 Do you recognize this document?

7 A Yes.

8 Q Okay. And what is this?

9 A This was a statement that I had put together at

10 that time in conjunction with Mr. Dunlap.

11 (Plaintiff's Exhibit 15 was marked for

12 identification.)

13 MS. REECE: Who drafted this document?

14 THE WITNESS: I was the one that drafted it

15 originally, and Mr. Dunlap did some --

16 THE COURT REPORTER: I'm sorry? "Mr. Dunlap"

17 what?

18 THE WITNESS: Did some editing on the document.

19 MS. REECE: "Editing."

20 THE WITNESS: Yes, that is "editing."

21 BY MS. REECE:

22 Q Okay. And that is your signature right there?

23 A Yes.

24 And that is when I was still in the state, that

25 I was -- the time I was taking -- still following his

236

1 lead.

2 Q Okay. What is this Texas Secretary of State UCC,

3 and, then, there's a number under your name? What does

4 that mean?

5 A Oh, I can't really tell you. That is

6 Mr. Dunlap's doing. Basically means that we're a secured

7 party credit. It's a -- it's a status. It's a legal

8 filing status.

9 Q Is that part of that Sovereign Citizen movement?

10 A I think it is.

11 Q What is your -- what is your understanding of

12 that number? Like, what does that number mean?

13 A It is just my registered number. It's a secured

14 party creditor. That is the only thing I know about it.

15 Q Okay. And, then, underneath it says "U.C.C.

16 1-308 Jus soli (of the soil)." What does that mean?

17 A I don't know.

18 He was the one who put that together, and I let

19 him do it.

20 Q Okay. Well, then you may have the same answer,

21 but on this international immunity, and then there's a

22 long number. What does that mean?

23 A Yeah, I'm -- I'm a registered international

24 diplomat.

25 Q Where are you registered?

1 for myself. And, you know, this is where I've, you know,

2 made, you know, change to my position on it because I'm

3 not working with Meta 1 on this issue. It's just me here

4 now.

5 And so, you know, I was surprised it took five

6 weeks from the time that Judge Pitman put the order out

7 before they arrested -- I was under the impression it

8 wasn't going to seriously happen because it had taken so

9 long.

10 Q Do -- so you said you're not working with Meta 1

11 anymore. Are you saying now that you're not going to talk

12 about Meta 1 at any point?

13 A Not until this stuff is cleared up.

14 Q Okay. So you're not actively -- right now you're

15 not actively encouraging your listeners to go out and

16 invest in Meta 1 Coin?

17 A No. I'm saying -- I basically -- I mean you can

18 go back and listen to my last three or four programs. I

19 say, "Folks, I'm not talking about Meta 1. I'm not going

20 to talk about that until this issue is cleared up. People

21 need to make their own decisions what they are going to

22 do, but I'm not telling you to go do anything."

23 I'm staying away from it until this is cleared

24 up.

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 25 of 42
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GRADILLAS COURT REPORTERS

245

1

2

3

4 I, the undersigned, a certified shorthand

5 reporter of the State of California do hereby certify:

6 That the foregoing proceedings were taken

7 before me at the time and place herein set forth; that

8 any witnesses in the foregoing proceedings, prior to

9 testifying, were placed under oath; that a verbatim

10 record of the proceedings was made by me using machine

11 shorthand which was thereafter transcribed under my

12 directions; further, that the foregoing is an accurate

13 transcription thereof.

14 I further certify that I am neither

15 financially interested in the action nor a relative or

16 employee of any attorney of any of the parties.

17 IN WITNESS WHEREOF, I have this date

18 subscribed my name.

19

20 Dated: August 17, 2020

21

22

23 __________________________________

 Marcia S. Mc Entee,

24 CSR No. 13399

25

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 26 of 42
9/2/22, 1:53 PM

1/1

U.S. SecuriƟes and Exchange Commission

Prejudgment Interest Report

Meta1/Dunlap

Quarter Range Annual Rate Period Rate Quarter Interest Principal+Interest

Violation Amount $10,849,776.47

04/01/2020-06/30/2020 5.00% 1.24% $134,881.10 $10,984,657.57

07/01/2020-09/30/2020 3.00% 0.75% $82,835.12 $11,067,492.69

10/01/2020-12/31/2020 3.00% 0.75% $83,459.78 $11,150,952.47

01/01/2021-03/31/2021 3.00% 0.74% $82,486.50 $11,233,438.97

04/01/2021-06/30/2021 3.00% 0.75% $84,019.97 $11,317,458.94

07/01/2021-09/30/2021 3.00% 0.76% $85,578.59 $11,403,037.53

10/01/2021-12/31/2021 3.00% 0.76% $86,225.71 $11,489,263.24

01/01/2022-03/31/2022 3.00% 0.74% $84,989.07 $11,574,252.31

04/01/2022-06/30/2022 4.00% 1% $115,425.42 $11,689,677.73

07/01/2022-08/31/2022 5.00% 0.85% $99,282.19 $11,788,959.92

Prejudgment Violation Range Quarter Interest Total Prejudgment Total

04/01/2020-08/31/2022 $939,183.45 $11,788,959.92



3

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 27 of 42
	








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4

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9/19/22, 6:30 PM (99+) META 1 Coin: About | LinkedIn

https://www.linkedin.com/company/meta-1-coin/about/ 1/4

META 1 Coin

META 1 is a Private Digital Currency backed by humanity's

greatest assets. We provide the liquidity of gold.

International Trade and Development · Sedona, Arizona · 146 followers

See all 7 employees on LinkedIn

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Overview

META 1 Coin is an asset-backed “Smart” Private Digital Currency secured

by Humanity’s greatest assets. Such as gold, in ground assets and

advanced intellectul property. META 1 Coin is a coin for Humanity, built on

the framework of abundance. This currency is designed to track the value

of the META 1 gold portfolio using Smart Contracts. Smart Contracts are

unbreachable

contracts on the blockchain and are designed to ensure appreciation,

never devaluation. META 1 Coin has a Private Bank and Private Exchange

allowing unencumbered transactions as well as superior liquidity and

security.

Website

http://www.meta1.io

Phone

928-494-0976

Industry

International Trade and Development

Company size

Home My Network Jobs



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Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 38 of 42
9/19/22, 6:30 PM (99+) META 1 Coin: About | LinkedIn

https://www.linkedin.com/company/meta-1-coin/about/ 2/4

Headquarters

Sedona, Arizona

Founded

2018

Specialties

Private Bank, Private Exchange, Private Digital Currency, Blockchain, Gold

Standard, and Asset Management

Locations (1)

2370 W State Route 89A, Suite 11-117, Sedona, Arizona 86336, US

Get directions

Primary

Home My Network Jobs

Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 39 of 42
9/19/22, 6:25 PM (99+) Nicole M. | LinkedIn

https://www.linkedin.com/in/nicole-m-216757160/ 1/5

173 connections

Message

Nicole M.

Global Visionary at META 1 Coin

Sedona, Arizona, United States · Contact info

· 3rd

META 1 Coin

More

About

Technical sales and relations within the market place. Team lead educator

for Business Development and strategic launch within the Private Digital

Currency space. Currently working on exchange fluidity and market

placement. Client liaison and global ambassador for META 1 Coin.

Featured

Link

METANOMICS

YouTube

Link

META 1 Coin White Paper

Explained

YouTube

Image

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Case 1:20-cv-00273-RP Document 133-1 Filed 09/22/22 Page 40 of 42
9/19/22, 6:25 PM (99+) Nicole M. | LinkedIn

https://www.linkedin.com/in/nicole-m-216757160/ 2/5

abundance and equity for

Humanity. It is a financial

platform using Blockchain

Coin White Paper describes

in detail the inner workings

of our coin and the...

Meta1

Welcom

Activity

172 followers

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Experience

META 1 Coin

4 yrs 9 mos

Asset Management Specialist

2018 - Present · 4 yrs 9 mos

Director Of Business Development

Mar 2018 - Present · 4 yrs 7 mos

Sedona, Arizona

Strategically placing assets in the private digital currency market.

Relationships include Gold, In Ground Assets, International Trusts,

Trading Platforms, International Exchanges and more. We

endeavor to bring META 1 to humanity, offering a chance to build

their personal portfolio. When you invest with META 1 coins, you

are buying a piece of our current assets, that you will own and can

trade on the private digital currency market.

META 1

Welcome Home!

Developing relationships within the Fine Art community to ensure

stability within our coin. We are merging science, art & ...see more

Interests

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APP364

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