Motion to Dismiss 12 B 5 FILING Stamped-1 July 2021.pdf

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Frank-Ojogwa: Ekejija
Email: nvcfund@yahoo.com
Trustee and General Executor for alleged Defendants
Frank Ekejija
FRANK EKEJIJA ESTATE
NVC FUNDS, LLC.
c/o Frank Ekejija
2837 Singletree Cove
Cedar Hill, TX 75104
UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF CALIFORNIA
WESTERN DIVISION
Michael R. of the Sew Hoy House, MICHAEL R.
SEW HOY (Cal. Bar No. 243391), Roberto A. of
the Tercero House, ROBERTO A. TERCERO
(Cal. Bar No. 143760), Manuel of the Vazquez
House, MANUEL VAZQUEZ (Cal. Bar No.
295576), Michele Wein Layne, Regional Director,
Katherine E. Zoladz, Associate Regional Director,
Amy J. Longo, Regional Trail Counsel, U.S.
SECURITIES AND EXCHANGE COMMISSION
and SECURITIES AND EXCHANGE
COMMISSION
350 W 1st Street, Suite 4311
Los Angeles, CA 90012-4565
ALLEGED PLAINTIFF, ACTUAL DEBTOR
vs
Frank-Ojogwa: Ekejija, NVC FUND, LLC,
FRANK EKEJIJA, NVC FUNDS HOLDING
TRUST
c/o 100 Crescent Court, Suite 700
Zip Code Exempt, (DMSR 122.32)
Non-Domestic, Real Land North America
ALLEGED DEFENDANT, ACTUAL CREDTOR
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Alleged Case No. 2:20-cv-08985
MOTION TO DISMISS THE
COMPLAINT FILED ON 30
SEPTEMBER 2020
UNDER RULE 12(B)(6) OF
THE FEDERAL RULES OF
CIVIL PROCEDURE
6/28/21
Case 2:20-cv-08985-ODW-DFM Document 86 Filed 06/28/21 Page 1 of 57 Page ID #:842

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PROCLAMATION MOTION TO DISMISS THE SEC COMPLAINT
i, the living man, frank ekejija, on behalf of the Frank Ekejija Estate and FRANK
EKEJIJA, which is the ens legis not created by the SEC or its agents, in good faith move
the Court to dismiss with prejudice the baseless frivolous complaint filed by Michael R.
of the Sew Hoy House, MICHAEL R. SEW HOY (Cal. Bar No. 243391), Roberto A. of
the Tercero House, ROBERTO A. TERCERO (Cal. Bar No. 143760), Manuel of the
Vazquez House, MANUEL VAZQUEZ (Cal. Bar No. 295576), U.S. SECURITIES AND
EXCHANGE COMMISSION and SECURITIES AND EXCHANGE COMMISSION
(SEC) under Rule 12(b)(6) of the Federal Rules of Civil Procedure and Exodus 20:16.
PLAINTIFF HAS NO BASIS FOR THE COMPLAINT
The SEC falsely alleged that Frank Ekejija, NVC Fund, LLC, and Patrick Johnson
engaged in a “pump and dump scheme” which they failed to prove. Furthermore the SEC
cannot substantiate their complaint or claim any relief because Frank Ekejija and NVC
Fund, LLC did not violate the alleged Rule 10(b)5 of the SECURITIES EXCHANGE
ACT of 1934 and Deuteronomy 5:20. Therefore under Rule 12(b)(6) of the FRCP and
Exodus 20:16 the Court must dismiss the baseless complaint.
The SEC specifically identified themselves as the “Plaintiffs”. However, the SEC, its
agents, and attorneys cannot show how they suffered an economic loss by the alleged
misconduct of the alleged defendants which is the necessary condition to claim relief
according to Rule 10(b)5.
The SEC argument rests on the words “CPA audited financial statement” versus

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“CPA audit reviewed financial Statement.” The SEC received professional audit reports
(EXHIBIT A, EXHIBIT B & EXHIBIT C) affirming the valuation of alleged Defendant’s
assets, financial statements and associated entities before the SEC embarked on the
investigation. After interrupting commerce with a more than a two and half year of
forensic investigation of NVC entities, private trust estate the SEC could not find any
injured party and has no allegation of damages. Despite no injured party and no
allegations regarding damages they proceeded to file the complaint and have been using
the Federal Rule of Civil Procedure to try and win a default judgement on procedural
violations pursuant to the California BAR Attorneys Local Rules and Procedure and not
the merits of the [c]ase. The SEC admitted they have no claim nor allegations regarding
damages, yet they seek relief through civil penalties. NVC Fund duly engaged the
services of Standard and Partners Audit Firm to conduct and render a professional review
(audit) that gave an accurate accounting review of NVC Fund Holding Trust Balance
Sheet /Financial Statements. Black’s Law Dictionary published in 1891 describes
AUDIT as follows: “AUDIT. As a verb, to make an official investigation and
examination of accounts and vouchers. As a noun; the process of auditing accounts; the
hearing and investigation before an auditor.”
To maintain our honor, which is paramount in commerce, the alleged Defendant
delivered to the alleged Plaintiff the certified reports, which accurately meet the criteria of
an audit. I construe the word audit to mean the following:
a. (a) An audience, a hearing

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b. (a). An examination in general; a judicial examination
c. (a). The result of such an examination, or an account as adjusted by auditors,
final account
d. (a). A general receptacle or receiver
e. (v.t.). To examine and adjust, as an account or accounts, as to audit the
accounts of a treasure or of parties who have a suit depending in court.
f. (v). to settle or adjust an account
g. syn. Review, investigation, examination analysis
Standard and Partners Audit Report of NVC Fund Holding Trust financial
statements and balance sheet (EXHIIT A) by the auditors clearly stated on June 30,
2017 that:
“In our opinion, the accompanying financial statements give a true and fair view of
the financial position of the Company as at 30 June 2017, and of its financial
performance and its cash flows for the year then ended in accordance with International
Financial Reporting Standards (IFRS).”
On October 5, 2017 Standard and Partners Auditor of NVC Fund Holding Trust
Valuation Report (EXHIBIT B) further stated:
“We have appraised the subject business in accordance with the Uniform
Standards of Professional Appraisal Practice (USPAP) as promulgated by the Appraisal
Foundation and the International Valuation Standards (IVS) published by the
International Valuation Standards Council.

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This appraisal follows the requirements of a valuation engagement, as that term
is defined in the American Institute of Certified Public Accountants (AICPA)
Statement on Standards for Valuation Services No. 1 (SSVS No. 1)”
The SEC obtained a Court subpoena and obtained over 17 years of NVC Fund Holding
Trust Financial Statements, assets documents, appraisals, accounting records and the
substantive source documents. They verified and reported to the Court Judge that they
have obtained all they needed from us. The SEC has not disputed the accuracy of the
reports nor the true net worth of NVC Fund Holding based on the accounting facts. The
SEC’s perceived government granted authority and their actions created a false
misleading narrative to deceive the general public, to cast a negative view about NVC
Fund Holding which consequently is an abuse of power and a dangerous crime this
honorable Court is obligated to stop.
THE STANDARD FOR RULE 12(B)(6) - FAILURE TO STATE A CLAIM
To defeat a motion to dismiss according to Rule 12(b)(6) of the Federal Rules of Civil
Procedure, a plaintiff must plead “enough facts to state a claim for relief that is plausible
on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007); Reliable
Consultants, Inc. v. Earle, 517F.3d 738, 742 (5th Cir. 2008); Guidry v. American Pub.
Life Ins. Co., 512 F.3d 177, 180 (5th Cir.2007). A claim meets the plausibility test “when
the Plaintiff pleads factual content that allows the Court to draw the reasonable inference
that the defendant is liable for the misconduct alleged. The plausibility standard is not
akin to a ‘probability requirement,’ but it asks for more than a sheer possibility that a

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defendant has acted unlawfully.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (internal
citations omitted). While a complaint need not contain detailed factual allegations, it must
set forth “more than labels (such as “pump and dump”) and conclusions, and a formulaic
recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555
(citation omitted). The “[f]actual allegations of [a complaint] must be enough to raise a
right to relief above the speculative level . . . on the assumption that all the allegations in
the complaint are true (even if doubtful in fact).” Myers v. TOG Hotels Downtown Dall.,
LLC, Civil Action No. 3:19-CV-1916-L. When the allegations of the pleading do not
allow the Court to infer more than the mere possibility of wrongdoing, they fall short of
showing that the pleader is entitled to relief. *Iqbal, 556 U.S. at 679.
In reviewing a Rule 12(b)(6) motion, the Court must accept all well-pleaded facts in
the complaint as true and view them in the light most favorable to Plaintiff. Sonnier v.
State Farm Mutual Auto. Ins. Co., 509 F.3d 673, 675 (5th Cir. 2007); Martin K. Eby
Constr. Co. v. Dallas Area Rapid Transit, 369 F.3d 464, 467 (5th Cir. 2004); Baker v.
Putnal, 75 F.3d 190, 196 (5th Cir. 1996). In ruling on such a motion, the Court cannot
look beyond the pleadings. Id.; Spivey v. Robertson, 197F.3d 772, 774 (5th Cir. 1999),
cert. denied, 530 U.S. 1229 (2000). The pleadings include the complaint and any
documents attached to it. Collins v. Morgan Stanley Dean Witter, 224 F.3d 496,498-99
(5th Cir. 2000). Likewise, “‘[d]ocuments that a defendant attaches to a motion to dismiss
are considered part of the pleadings if they are referred to in the plaintiff’s complaint and

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are central to [the plaintiff’s] claims.’” See Venture Assocs. Corp. v. Zenith Data Sys.
Corp., 987 F.2d 429, 431 (7th Cir. 1993)).
The ultimate question in a Rule 12(b)(6) motion is whether the complaint states a
valid claim when it is viewed in the light most favorable to the Plaintiff. Great Plains
Trust Co. v. Morgan Stanley Dean Witter, 313 F.3d 305, 312 (5th Cir. 2002). While well-
pleaded facts of a complaint are to be accepted as true, legal conclusions are not “entitled
to the assumption of truth.” Iqbal, 556 U.S. at 679 (citation omitted). Further, a court is
not to strain to find inferences favorable to the Plaintiff and is not to accept conclusory
allegations, unwarranted deductions, or legal conclusions. R2 Invs. LDC v. Phillips, 401
F.3d 638, 642 (5th Cir. 2005) (citations omitted). The Court does not evaluate the
Plaintiff’s likelihood of success; instead, it only determines whether the Plaintiff has
pleaded a legally cognizable claim. United States ex rel. Riley v. St. Luke’s Episcopal
Hosp., 355 F.3d 370, 376 (5th Cir. 2004). Stated another way, when a court deals with a
Rule 12(b)(6) motion, its task is to test the sufficiency of the allegations contained in the
pleadings to determine whether they are adequate enough to state a claim upon
which relief can be granted. Mann v. Adams Realty Co., 556 F.2d 288, 293 (5th Cir.
1977); Doe v. Hillsboro Indep. Sch. Dist., 81 F.3d 1395, 1401 (5th Cir. 1996), rev’d on
other grounds, 113 F.3d 1412 (5th Cir. 1997) (en banc). Accordingly, denial of a 12(b)(6)
motion has no bearing on whether a plaintiff ultimately establishes the necessary proof to
prevail on a claim that withstands a 12(b)(6) challenge. Adams, 556 F.2d at 293.
CHALLENGES WITH THE SEC COMPLAINT

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First of all, SEC claims to be the “PLAINTIFF”. The SEC is a regulatory agency and
has never purchased anything from alleged defendants; therefore, they have no basis upon
which relief can be granted under the 10(b)5 rule. There is no injured party making a
claim or alleging that Frank Ekejija Estate has harmed them. The SEC is attempting to
deceive the Court to extort civil penalty from Frank Ekejija and NVC Fund, LLC by filing
a baseless, false, self-serving complaint against Frank Ekejija, NVC Fund, LLC and the
alleged defendants. The SEC willingly and recklessly interrupted our businesses, creating
unquantifiable damages, mental anguish, and emotional distress. The SEC admitted they
had no claim or allegations regarding damages and therefore agreeing to the nefarious and
deceptive nature of their COMPLAINT, see Case 2:20-cv-08985-ODW-DFM Document
60-1 Filed 03/02/21 Page 1 of 21 Page ID #:466 page 10 lines 10 and 11.
Other reasons to dismiss the baseless frivolous complaint includes the following truths:
1. The Attorneys for the SEC are foreign agents who are receiving benefits, titles of
nobility, and/or other considerations from the foreign entity known as the BRITISH
ACCREDITATION REGISTRY et al. See the Foreign Agent Registration Act of
1938.
2. The SEC is an entity created by the federal corporation known as the UNITED
STATES according to 28 USC 3002 §§ 15a and 15b, which requires that a valid
contract be established by two or more parties with full disclosure and entered into
knowingly, willingly, and voluntarily. The SEC has no such contract with NVC
FUND, LLC nor any part of the Frank Ekejija Estate.

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3. The SEC does not operate in constitutional jurisdiction and does operate in
admiralty jurisdiction. The SEC’s actions as a de jure “government” agency is
unclean and false. The SEC, therefore, operates under colorable law pursuant to 18
USC 242 and 241. See EXHIBIT D, COL Forms for the SEC agents.
THE SEC COMPLAINT SHOULD BE DISMISSED WITH PREJUDICE
The complaint filed by the SEC on 30 September 2020 should be dismissed for lack of
merit, it is frivolous and baseless, there is no injured party nor allegations regarding
damages against the alleged Defendants.
Items 1 – 302 of the SEC complaint are rejected and must be dismissed with prejudice
because of the SEC infractions herein mentioned, including the fact that the attorneys who
filed the complaint are foreign to the United States of America republic pursuant to the
Foreign Agent Registration Act of 1938 and are acting dangerously against an American
citizen.
Items I – X in the PRAYER FOR RELIEF section of the complaint are all moot points.
The SEC as Plaintiff cannot demonstrate a legitimate claim against Frank Ekejija or NVC
FUND, LLC or any part of the Frank Ekejija Estate. Furthermore the SEC has not and
cannot name an injured party nor allegations regarding damages against the alleged
defendants. Therefore the complaint is repugnant constitutionally, commercially and
morally and must be dismissed with prejudice ab initio.
The subterfuge, the false allegations and attempt to deceive the public and the Court by
the SEC and their agents provide the basis for my motion to dismiss the complaint and

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demand that the SEC be ordered to honor the NVC FUND, LLC claim against the SEC.
In closing, the SEC’s complaint is demonstratively baseless, prejudicial, deliberate and
calculated to damage my name, reputation, estate in the public market. The SEC’s
strenuous attempt at redefiniting an audit review is most unfortunate and frivolous at best
when viewed from the English definition of the word “Audit”. The SEC’s unfounded 3
year long forensic inverstigation has been costly in lost revenues, defamation of character
pursuant to USC 28 Section 4101, significant emotional distress, and years of mental
anguish. Justice demands dismissal and recompense. I, therefore, move the Court to
grant our motion to dismiss the complaint under Rule 12(b)6 of the FRCP. Repair is
required, necessary and demanded.
CONCLUSION
For the reasons herein stated, I move the Court grant Defendants Frank Ekejija and
NVC Fund, LLC Motion to Dismiss the SEC complaint under Federal Rule of Civil
Procedure 12(b)(6) and Deuteronomy 5:20, with prejudice. The Court, as required by
Rule 58 of the Federal Rules of Civil Procedure, to issue a Dismissal with Prejudice
judgment by separate document.
Dated: 26 June 2021 Respectfully Tendered
/s/ Frank Ojogwa Ekejija
Frank Ojogwa Ekejija
Trustee for the FRANK EKEJIJA ESTATE

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NVC FUND HOLDING TRUST
VALUATION OF TRUST
CERTIFICATE UNIT
5 October 2017
EXHIBIT B

1
Index Page
Valuation Cover Page 2
1. NVC Company Profile 3
2. Financial Statements 7
2.a Balance Sheet 7
2.b Income Statement 9
3. Valuation Methodology 10
4. Valuation Calculation 11

2
Standards and Partners
E.Buyukdere caddesi Destegül Sokak
Orkun Plaza No:5 4. Levent Istanbul
Tel + 90 212 266 2033
www.standardsandpartners.com
To: Shareholders of NVC Fund Holding Trust
100 CRESCENT COURT #700
DALLAS, TEXAS, USA 75201.
Re: Valuation of Trust Certificate Unit
We have been engaged to estimate the trust certificate unit value of the trust
fund known as NVC Fund Holding Trust as of October 5, 2017 for the purpose of
issuing the shares to financial institutions be exchanged against currency units
and digital currency units.
We have appraised a fully marketable, controlling ownership interest in the
assets of the subject business.
Based on the information contained in the report that follows, it is our estimate
that fair market value of one trust certificate unit of NVC Fund Holding Trust is:
One Trust Certificate Unit: 48.881 USD (forty-eight-thousand-eight-hundred-
and-eighty-one US Dollar)
Trust Certificate Unit Value includes Net Asset Value method, which includes
deducting the liability items from total asset items. The valuation is subject to the
Auditors’ Report as of 30 June 2017 provided to assumptions as well as, the
financial information, which appear in the report.
We have appraised the subject business in accordance with the Uniform
Standards of Professional Appraisal Practice (USPAP) as promulgated by the
Appraisal Foundation and the International Valuation Standards (IVS) published
by the International Valuation Standards Council.
This appraisal follows the requirements of a valuation engagement, as that term is
defined in the American Institute of Certified Public Accountants (AICPA)
Statement on Standards for Valuation Services No. 1 (SSVS No. 1).
Sincerely,
Guvenc Dusko
Certified Public Accountant (CPA), MBA
Partner, Standards and Partners

3
1. NVC Company Profile
NVC Fund Holding Trust was established on 2000.
The Company is controlled by Frank Ekejija.
The address of the Company’s registered office is, 100 CRESCENT COURT #700
DALLAS, TEXAS USA 75201.
Company’s contact email is trustee@nvcfund.com.
Company’s phone number is +1-214-459-8183, +1-972-291-4219
NVCFUND HOLDING TRUST Equity Assets Value are divided into 1 Billion Trust
Shares. The trust shares are regarded also as Units Investment Trust (UIT). On
March 27, 2009, the NVC trust shares were registered with the SEC form 6 as NVC
FD HLDG TR UIT, March 2009 with the CUSIP # 67074B105: CUSIP stands for:
Committee on Uniform Securities Identification Procedures. The trust ISIN #
US67074B1055 : ISIN stands for: International Securities Identification Number.
STATEMENT OF INTENT AND PURPOSE
1. NVCFUND Transaction Platform is available to serve the commercial operation of
contracted Rights Owners, Financial Institutions, Sovereigns, Governments, Asset
Owners, Accredited Investors, Title Holders, Insurers and Money Managers, that are
qualified under the SEC definition of sophisticated or Institutional Investors.
2. NVCFUND and related entities have collectively over $48,000,000,000,000 (Forty
Eight Trillion USD) of owned Assets/ Equity under management.
3A. A party is considered and accepted to become a Participant when the sponsored
project is qualified by the management of the Transaction Platform through an
agreement to provide services. The project can be initiated by any of the current
entities and enter into a bidding agreement and contract with any subsidiary of
NVCFUND HOLDING TRUST, NVCFUND TRUST or NVC FUND, LLC, NVC DEVELOPMENT,
LLC, NVC CAPITAL CORPORATION, NVC INVESTMENT, LTD, and be issued a Project
Trust Account Number.
3B. The Annex list of 100 Funds is SPV, SPC and SPT collectively NVC FUND 100. The
NVC100 are related and annexed as integral internal management Special Purpose
Vehicles (SPV). Special Purpose Companies (SPC) and Special Purpose Trust (SPT) are
properties of NVC FUND HOLDING TRUST to accomplish NVC interest and purpose for
and on behalf of NVC Partners, Clients and Institutional transactions.
4. NVCFUND has the capacity and capability as a Qualified Institutional Participant to
securitize, monetize, collateralize, leverage, deleverage, borrow, lend trade, invest,
insure, assure, re-insure, hypothecate, assign, divide, and leverage NVCFUND
corporate assets as necessary with any member of the Transaction Platform.
5. From time to time, NVCFUND may issue Capital Securities, Bonds, Promissory Notes,
Bills of Exchange, Trust Accounts and Ledger Accounts to facilitate investments and
financial commitments to participants.

4
6. NVCFUND is empowered to invest, contribute, assign, securitize, and deposit assets
for equity in companies and humanitarian organizations as necessary.
7. NVCFUND will manage the platform to enable Participants to facilitate mutually
beneficial buy and sell agreements with each other within the Transaction Platform so
Participants may facilitate funding, execute and manage joint ventures, buy-sell
contracts, underwrite, and ensure and guaranty of Participants projects.
8. The NVCFUND TRANSACTION PLATFORM offers opportunities to qualified investors
to participate as commitment holders, buyers, sellers, lenders, partners and
facilitators in specific offerings.
9. NVCFUND is authorized to appoint any administrator to administer assignments on
behalf of contracted Parties.
10. Each contract will be executed with participants using an LLC, Trust or Partnerships
under the umbrella of NVC FUND TRUST as a Master Custodian Trust where each SPV
may be issued a subsidiary account by the Master Custodian Trustee. An
Administrative Agent may be engaged to facilitate and manage the execution of the
contracts to ensure that all transactions, fiduciary obligations and statutory
requirements of each entity are performed and accounted for accordingly.
NVCFUND is to enter into mutually beneficial agreements for investments, Securities,
Financing, Administration, Assets Management, Collateral Management Contracts
with ready, willing, able Companies, governments, Pension Funds, Lenders, Hedge
Funds, Banks and Financial Institutions to accomplish the purpose and programs of
NVCFUND Transaction Platform.
Partial List of Completed NVC Transactions
NVCFUND has an equity interest in over 55 companies that NVC supports as joint
venture partners, or with capital investments, ranging from 25% to 85% interest in
the respective businesses. NVC has established precedents’ for the use of NVC trust
units certificates as an acceptable value in private placement transactions with
counterparties.
Here are some sample investments
and initiatives:
• In January 2008, NVCFUND sold $4.8 Billion of equity units and received
payment in promissory notes and international Bills of Exchange.
• In June 2008, NVCFUND contributed a significant amount of equity in return
for a $10 Billion oil and gas energy bond position in a program in which $21
Billion of private placement capital was raised by Pacific Atlantic Asia
Foundation to fund their Global Humanitarian Initiatives.
• In June of 2009, NVCFUND HOLDING TRUST reached a deal to purchase a 55%
interest in the Gooch Companies for $10 Billion. As of today, the Gooch
Companies manage construction projects, both current and in the pipeline,
worth $1.5 Trillion USD, around the world.

5
• In July of 2009, NVCFUND deposited $84 Billion of the Trust Equity
Certificate into a Sovereign Trust account in exchange for a Certificates of
Deposit along with a Safe Keeping Receipts (SKR) for the deposit.
• The $84 Billion Certificate of deposit was accepted as payment for the
purchase of Sovereign Central Bank Treasury Bills. The Treasury Bills were
received, monetized, and reinvested in high yield private placement
investment programs.
• In August 2009, NVCFUND issued $25 Billion Trust Certificate as deposits to
establish a Trust Investments accounts in The Standard and Poor’s AA+ rated
US Capital Trust.
• In October 2009 NVCFUND entered into a working arrangement to support
Pedison USA in it the business of providing financial services and mortgage
lending across the broad business spectrum with an open line of credit and
balance sheet enhancement.
• In November of 2009, NVCFUND signed a five years lessee agreement to
lessee $100 Million value in Trust Certificate Collateral Security to enhance the
balance sheet to American Indemnity Guarantee.
• In March 2010, NVC Fund invested $1.3 trillion as the base collateral asset to
support the private placement transaction involving the purchase order of
$2.4 trillion wholesale warehouse loan financing involving buy-sell contracts
with recurring revenue streams. The result of all the members business to a
business network of financial transactions continue to accrue as credit and
benefit to NVCFUND HOLDING ACCOUNTS.
• In April 2010, NVCFUND appointed Estrategia Investimentos of Brazil through
the Florida office to act as one of NVC’s Asset Custodian and Depository for
$16 Billion Trust Fund. Estrategia invested the trust fund in trading programs
and continues to grow in value.
• In October 2010, NVCFUND executed a swap agreement in which NVC
promissory Note was exchanged for income surplus certificate and equity
interest in OICM Insurance Company.
• In February 2011, NVC deposited an additional $50 Billion of NVC trust
certificate with US Capital Bank and Trust through a Custody and Deposit
Contract agreement.
• In March 2011, NVCFUND established an SPV trust and invested 57,000,000
Trust Units of NVCFUND HOLDING TRUST Certificate Shares as Capital
Security to support Global Underwriters Coalition. The GUC network provides
a global peer-to-peer banking platform and operates as a repository trust
domain for the exchange goods and services on a global scale.
• In March 2011, NVCFUND agreed to purchase equity interest in Immune
Modulation, Inc, Immune Modulation, Incorporated (IMI) is an early
development stage company conducting research and developing

6
pharmaceutical drugs in the areas of transplantation, inflammation, oncology,
and virology.
• In June 2011 NVCFUND established a US Treasury Direct Account to act as the
back stop to NVC trust asset accounts. As the global sole super power and
trusted government institution, The US Government Treasury is a safe heaven
and custodian for all global credit and debt public and private for NVCFUND
HOLDING TRUST.
• In October 2012, NVCFUND issued a multi billion dollar donation to The
Church of God, The Maranatha Church to support and fund collaboration with
Atlantis Global and Faith Group Trading Platform and so the profits can be
used to fund humanitarian courses around the world.
• In November 2011, NVCFUND entered into a Joint venture agreement with
Diamond Access, Inc. DIAMOND is gold, diamond and precious/semi/precious
minerals aggregator and reseller who purchases and accepts consignments of
its products from its network of 10,200 artisan/small miner network system
established in 22 countries on the African Continent.
• In December of 2011,NVC extended a $12 Billion long term facilities in
partnership with Banque Internationale to support merger and acquisition
activities and balance sheet lending to transactions in Russia, Ukraine, Turkey,
North Africa and the Middle East.
• In April of 2012, NVCFUND agreed with the Law Firm of Albert Bakker
Vorster and Pillay and Associate to act as asset manager, custodians and
Fiduciary Agent and Trustee for a $10 Billion trust fund invested in high yield
investment program with HSBC in Hong Kong.
• In April of 2012, NVCFUND signed a full corporate offer and definitive
agreement to the purchase 10,000 metric tones of Gold Bullion valued at $550
Billion in a private buy-sell arrangement.
• In August of 2013, NVCFUND opened $50 Billion trust account, an
Institutional Custodial Trust Agreement with the Global Clear Banking
Platform to support the Global Network of the member banks, credit unions,
community development agencies financial capacity to provide capital and
funds to the millions of their customers. In exchange, Global clear Banks will
provide back office ledger settlement and clear for NVC Transactions as may
be needed.

7
BALANCESHEET Note 30.06.2017 31.12.2016 31.12.2015 31.12.2014
CurrentAssets 180.711.390.034 178.693.267.735 178.073.103.305 126.761.944.500
Inventories 0 0 0 0
DuefromRelatedParties 0 0 0 0
OtherInvestments 10 0 0 0 0
Prepayments 0 0 0 0
CurrentTaxAssets 0 0 0 0
Tradeandother Receivables 12 68.832.390.034 66.814.267.735 66.194.103.305 65.980.444.500
CashandCashEquivalents 13 111.879.000.000 111.879.000.000 111.879.000.000 60.781.500.000
Non-currentAssets 49.218.759.122.145 43.659.984.444.639 41.191.948.601.354 57.211.472.219.008
Property,plant,equipment 9 44.552.321.388.895 38.993.561.711.389 36.918.395.868.104 54.379.724.485.758
Intangibleassets 0 0 0 0
EquityAccountedinvestees 0 0 0 0
OtherInvestments 10 4.666.437.733.250 4.666.422.733.250 4.273.552.733.250 2.831.747.733.250
DuefromRelatedParties 0 0 0 0
Prepayments 0 0 0 0
TotalAssets 49.399.470.512.179 43.838.677.712.374 41.370.021.704.659 57.338.234.163.507
2. Financial Statements
a. Balance Sheet
NVCFUNDHOLDINGTRUST
CondensedInterimBalanceSheet asat30June2017andannualBalanceSheetasat31December2016,2015and2014
(AllamountsareexpressedinUSDollars(USD)unlessotherwisestated.)

8
Note 30.06.2017 31.12.2016 31.12.2015 31.12.2014
Short-term Liabilities 7.462.000 0 0 0
Loans and borrowings 0 0 0 0
Trade and Other Payables 15 7.462.000 0 0 0
Employee Benefits 0 0 0 0
Provisions 0 0 0 0
Due to Related Parties 0 0 0 0
Long-term Liabilities 520.129.733.250 519.858.733.250 519.858.733.250 519.858.733.250
Loans and borrowings 0 0 0 0
Trade and Other Payables 15 520.129.733.250 519.858.733.250 519.858.733.250 519.858.733.250
Due to related parties 0 0 0 0
Deferred Tax Liabilities 11 0 0 0 0
Equity 48.879.333.316.929 43.318.818.979.124 40.850.162.971.409 56.818.375.430.257
Share Capital 14 76.477.136.119.123 76.477.121.119.123 76.084.251.119.123 74.591.348.619.123
Adjustment to Share Capital 14 0 0 0 0
Revaluation Reserve 14 -27.366.356.730.228 -32.925.116.407.734 -35.000.282.251.019 -17.538.953.633.366
Legal Reserve 14 0 0 0 0
Retained Earnings 14 -231.446.071.966 -233.185.732.265 -233.805.896.695 -234.019.555.500
Non Controlling interest 0 0 0 0
Total Liabilities and Equity 49.399.470.512.179 43.838.677.712.374 41.370.021.704.659 57.338.234.163.507
NVC FUND HOLDING TRUST
Condensed Interim Balance Sheet as at 30 June 2017 and annual Balance Sheet as at 31 December 2016, 2015 and 2014
(All amounts are expressed in US Dollars (USD) unless otherwise stated.)

9
b. Income Statement

10
3. Valuation Methodology
Net Asset Value method is used in the calculation of the value of the trust certificate
unit.
What is 'Net Asset Value - NAV'
Net asset value (NAV) is value per share of a trust fund on a specific date or time.
The per-share dollar amount of the fund is based on the total value of all the
securities in its portfolio, any liabilities the fund has and the number of fund shares
outstanding.
Example Trust Fund Net Asset Value Calculation
The formula for a trust fund's NAV calculation is straightforward:
NAV = (assets - liabilities) / number of outstanding shares
In this context, assets include total market value of the fund's investments (priced
using the closing price of all the assets on the day the NAV is calculated), cash and
cash equivalents, receivables and accrued income. Liabilities equal total short-term
and long-term liabilities, plus all accrued expenses, such as staff salaries, utilities and
other operational expenses.

11
4. Valuation Calculation
Net Asset Value Method Calculation
Asset
30.06.2017
Trade and other Receivables 68.832.390.034
Cash and Cash Equivalents 111.879.000.000
Property, plant, equipment 44.552.321.388.895
Other Investments 4.666.437.733.250
Accrued Income 2.013.506.387
Total Assets 49.401.484.018.566
Liabilities
Trade and Other Payables (short-term) 7.462.000
Trade and Other Payables (long-term) 520.129.733.250
Accrued Expenses 278.462.000
Total Liabilities 520.415.657.250
Asset – Liabilities 48.881.068.361.316
Number of shares of Trust certificate 1.000.000.000
One Certificate Value (in USD) 48.881

EXHIBIT C

EXHIBIT D

PROOF OF SERVICE
PROOF OF SERVICE ON CLERK OF COURT KIRY K. GARY
I am over the age of 18 years and not a party to this action. My business address is:
SHALAMOOR BEY TRUST
1700 Northside Drive, Suite 770
Atlanta, Georgia [30318]
On 28 June 2021, I caused to be served the documents bearing filing named MOTION TO DISMISS THE
COMPLAINT FILED ON 30 SEPTEMBER 2020 UNDER RULE 12(B)(6) OF THE FEDERAL RULES OF CIVIL
PROCEDURE, EXHIBIT A, EXHIBIT B, EXHIBIT C AND EXHIBIT D on all the parties to this action addressed
as stated on the attached service list:
☒ ELECTRONIC MAIL: By transmitting the document by electronic mail to the electronic mail address as
stated on the attached service list.
☒ E-FILING: By causing the document to be electronically filed via the Court’s CM/ECF system, which
effects electronic service on counsel who are registered with the CM/ECF system.
Delivered to Kiry K. Gary Clerk of Court via eFiling System and Michael R. Sew Hoy, Roberto Tercero
and Manuel Vazquez via email.
I declare under penalty of perjury that the foregoing is true and correct.
28 June 2021
Date Mark Irvin Ritchie, Trustee
All Rights Reserved and Exercised
is true and correct.
n Ritchie, Trustee

Motion to Dismiss 12 B 5 FILING Stamped-1 July 2021.pdf

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