TO WHOM IT MAY CONCERN:

GEET International, Inc. has the exclusive rights to market, manufacture, and teach the technology embodied in U.S. Patent Number 5794601. GEET International, Inc. had entered into a contract with Dennis Lee’s organization to distribute GEET technology made available by GEET International, Inc., but the contract required his organization to feature the GEET logo as prominently as his own, which was not done. The contract did not confer the right to manufacture or teach the technology. Discussions were held which might have eventually led to the right to do some teaching or manufacture if GEET approved it on a case by case basis, but those discussions did not lead to any license being issued. Dennis Lee’s organization did not comply with the requirements for pre-approval of ads by GEET.

Recently, a large number of credible witnesses have contacted GEET to advise Paul Pantone that Dennis Lee is now claiming the GEET technology as his own, is defaming GEET, and is making claims for the technology which are not warranted at the present time. These same witnesses have advised Paul that, in spite of specific warning to Dennis Lee, he continues to encourage the illegal application of furnace technology. Because of the repeated violations of both the contract and GEET’s intellectual property rights, including the claim that Dennis Lee will soon be manufacturing the technology and offering courses in the same in New Jersey, GEET takes the position that Dennis Lee has breached the contract, and no longer has any rights to distribute or perform any other act regarding the GEET technology, or sell the plans to which Paul Pantone has all rights. DENNIS LEE AND HIS ORGANIZATION HAVE NO LICENSE to do either of these, and his proposed course of action appears to be an illegal infringement on GEET’s rights, which GEET intends to pursue in the courts. Anyone doing business with Dennis Lee regarding the GEET technology risks being named as a party in the suit which GEET intends to file.

UPDATE AS OF 10/15/01

ANYONE WHO HAS BEEN PROMISED TRAINING OR LICENSES TO GEET TECHNOLOGY BY DENNIS LEE.

Anyone considering going to Dennis Lee’s "school" in New Jersey to be trained to use MY GEET Technology should first be aware that Dennis Lee has not only NEVER been given a License to open a school competing with mine, he was specifically prohibited from opening a school in competition with the GEET International Institute. Second, if you use my technology without a license from me, the patent holder, you can be sued under FEDERAL LAW for infringing my patent. This includes the sale of my plans or products. Third, DENNIS LEE currently has no right to manufacture any product based on GEET Technology. If you bought plans through Dennis Lee they are not authorized by GEET, and do not give you any rights to install unless you are on the miniscule list of those for which we were paid royalties. you will have to check with GEET to see if you are on that list. if you are not, Dennis Lee has taken your money without giving you a valid license. If you have purchased an “automotive kit” ask for a refund, since GEET has refused to market those until they are fully ready. If you paid Dennis for such a kit, and received it, you paid you received an infringing, unlicensed product.

You should also be aware that, although Dennis Lee has said in then past he would only create 2,000 dealerships, many Dennis Lee dealers have said THEY FEEL THAT HE DOES IN FACT HAVE MORE THAN 2,000 DEALERS AND IS STILL SELLING DEALERSHIPS. On September 27th a man came to the Institute and was checking out what was going on. He said Dennis offered him a dealership while in Salt Lake at $30,000, but that Dennis then called him from New Jersey telling him the price today was $200,000.00, and is expected to be as much as a MILLION by the end of the year, providing Dennis Lee can market the GEET technology and training. (Unfortunately for the dealers, Dennis Lee has no legal rights to my technology, nor, according to many conversations with other inventors, most of the other products he demonstrates.) Right now, though, Dealers from all over are complaining they can’t sell their dealerships for as little as $10,000.

At this time it is my opinion that there are many more distributorships than he is willing to talk about. Why would Dennis Lee tell us at GEET that he does not want our Graduates, who just spent $1,500 to become trained, to not be posted on any website? Why have Dealers from all over told us they aren’t getting any leads from Dennis?

1. I personally would like to know how many dealers there really are. Many of you are sending me lists of the Dealers you know and have met at different events. Thank you very much for this information. I will post the numbers as they come in.

2. The Attorney Generals’ Offices from several states have asked if we had names of any DL Dealers in their states. If you are a Dealer in; KY, TN, NM, LA, IL, WA, AK, NC, SC, CT, ME, GA, DE, VA, NY, TX, NJ or OR, please let them know who you are or send the info to me and I will forward it to the appropriate party.

WHAT WENT WRONG???

Molley and I went back to New Jersey to see if Dennis was real or a fraud. We spent 3 days with Dennis, Allison and Dennis' Daughter. He demonstrated a few things including the browns gas unit. He seemed to be real on the surface. We entered an agreement that all GEET Distributors would be granted a Dealership under UCSofA within 14 days, and Dennis gave Paul and Molley a copy of the Dealer agreement. We agreed that I would open the GEET International Institute of Technology in UTAH. We agreed that his dealers would be able to advertise any products that were being marketed to the General Public with specific limited rights; ALL advertisements MUST include the GEET Logo; ALL information on ANY website, including UCSofA, was to approved by PAUL AND MOLLEY PANTONE, PRIOR to posting; ALL funds collected, by Wednesday of each week according to our agreement, were to be deposited in our account by Friday of that week. Dennis was not to sell any plans until he had arranged for someone at his location to be available to answer ALL questions and give out FREE details to those who bought plans. We have been told by many callers that Dennis is sending out plans which are NOT complete, and that he won’t give them the time of day without them paying more money.

For the first few weeks Dennis Lee sent students into the school. Then he sent his own men in for training. His men signed an agreement to not compete or infringe on my Patent. This was supposedly so that THEY could answer the questions of people calling in for the details not included in the plans. Until this training was done, ALL PLANS were to be sold through Paul Pantone.

Now, 4 months later, no GEET Distributor has been granted a Dennis Lee dealership. People who bought plans tell us they are upset that Dennis won’t give them the specifications for the plans which are PART of buying the plans.

The next week of school we went from 25 students to 1 or 2 a week. Not enough to cover the expenses of keeping the doors open. Many people were calling wanting to come to school but were then being told by Dennis that the NEW School will be opening in New Jersey, sometime in about November.

As Dennis began his tour, complaints came in from each City about him mis-representing the GEET Technology. After seeing a video of this I notified Dennis that he had breached his contract with GEET, and directed him to stop marketing our plans, schooling, and products. The final straw that ended any further dealings with Dennis was over my Plans. He sat in my office and said, “in GOD’S name" he did not sell any of my plans. He went on to say that IF any were sold it may have been, Walter, Allison, Sari, Elisabeth, (all denied selling any plans), or someone else at his office. Several times he swore this was true. Then I handed him copies of just a few of the receipts which I had, that proved he had sold over $25,000 in plans and failed to send my portion. Dennis Lee further said he wanted me to not produce any product that worked in the field of power generation as that would hurt his goal of becoming the world's biggest and “RICHEST” Utility Company in history.

When this was posted on my site many Dennis Lee dealers called, faxed and e-mailed Molley and I support. Complaints? YES!!! They are pouring in.

1. People tell us Dennis Lee is knowingly selling Plans, which are not complete, and is not offering the necessary details to enable one to build any unit. In our opinion this is fraudulent.

2. Dennis Lee represents on stage that one can purchase plans to retrofit the furnaces in their own homes for only $300.00. I have personally told Dennis Lee that to modify a furnace to put into a home MUST BY LAW be approved by certified laboratories, in the Country of usage. In my opinion this is not only fraud but dangerous and could cause death of innocent people if an unqualified person attempted such action without any form of training, not to mention it is ILLEGAL. I believe these claims are being made willfully and intentionally in an effort to con people into investing in his company, for a product which has never been offered to Dennis LEE.

3. We have been told by a few students that they were sent by investors who sent them to Salt Lake City, prior to investing in a dealership. The students said that once they confirmed to the investors that GEET Technology worked, the investors gave Dennis their $100,000.00 fee, with the understanding from Dennis that they were Guaranteed ALL GEET Technology. This is certainly not part of our former agreement with Dennis Lee, and appears to be a blatant act of FRAUD and deception.

4. We have been told from the first day of school that Dennis put in writing that the students could bring in their own cars and equipment to be retrofitted with GEET. I told Dennis before we opened that we did not have facilities to accommodate such a feat. The students said they were told NOT to call Paul or Molley for any reason and this caused even more problems. Some students say they were told they could camp out at the institute. Dennis stated that ONLY qualified Mechanics should come to the school, even though we told him they are the most difficult to train because of their preconceptions. I told Dennis we did not have automotive parts in stock yet we have been told that some of you are collecting money from customers and sending it to Dennis Lee. If He is taking money for something which is not available for delivery, then it appears he is committing fraud to con people out of their money.

5. Because we were concerned by the complaints of disgruntled DENNIS LEE Dealers we began calling several people who own the products that Dennis shows on stage or offers to dealers as EXCLUSIVE. One example is Fire-Shaker. Found at www.fireshaker.com. They do NOT sell any products to Dennis Lee and have served him papers to get him to stop pretending they have ANY relationship.

6. Laundry Balls. I have found several sites while searching for them only to find, while sitting with a Dennis Lee Dealer, a site with pictures of the Dennis Lee Laundry Balls. And the manufacturer says they should last about 1,500 washes. But why does Dennis Lee Guarantee them for life? And why did the manufacturer get upset when they heard Dennis Lee's name? And if these are part of your EXCLUSIVE Dealership why did the manufacturer tell us he won't sell them to Dennis? Or is this just another small Fraud and Deception in gathering money for the Dennis Lee causes. http://www.syntac.net/hoax/scams.php

7. Mosquito Magnet. http://www.mosquitomagnet.com/ GEE!!! Another product that the manufacturer tells us Dennis Lee doesn’t legally represent as an exclusive agent. But how many of you gave him money to represent all of his exclusive products??? Just how many of these products is he falsely representing?

8. On stage in Boise, Dennis told the audience that it only takes about an hour to install the GEET on ANY car. We have shown it can be done in a day, but only by a GEET Qualified person. He said he could do it himself if he wanted. BULL. Just by his presentation, he proved he doesn’t have a clue as to how it works, and he doesn’t seem to care.

9. The Furnace. The furnace displayed by Dennis Lee could not possibly work as described. It appears that most of the information he gave on stage was simply made up as he opened his mouth. He went so far as to tell his audience completely wrong directions of molecular movement in and around the furnace as well as incorrect temperatures of operations. If you hooked the furnace to your septic tank as he describes, it would most likely blow the lid off the tank.

10. Many dealers told us of having purchased his heat pump for thousands of dollars and that the heat pumps NEVER WORKED. He was prosecuted for this one. http://www.users.voicenet.com/~eric/skeptic/

11. Dennis Lee claims that no one knows how GEET works? Well I have successfully taught over 25 Physicists the 48 phenomenons, and they said they were satisfied they did take place. As well as hundreds who have gone through my training who have successfully built their own GEET running equipment. Why does it seem he is lying? I believe it is to keep people from making contact with Me and GEET. We DO teach the GEET Technology, licensed and recognized by the State of Utah, Board of Regents as a school of Higher Education.

12. When Dennis Lee puts his nose at the exhaust and claims there is no Carbon Monoxide, that claim is not true. He tells the audience they can run the generators inside closed building for prolonged periods of time. CAUTION::: The generators he is claiming to be pollution-free, are not!!! If only one person on his tour believes what he said they could be dead by trying to prove that claim. Not even Dennis Lee should be above the law on endangering the lives of others by making false claims to raise money for his cause.

13. One Dennis Lee dealer phoned and told me that Dennis sells a Freon replacement, Propane. This is illegal and banned in most states. If your system leaks it could result in an explosion. Check with ATF or your local authorities.

14. In Casper, Wy, Dennis says the Van he was touring with wouldn’t start. Did it ever run? I inspected it in Salt Lake City as he toured through. The way it was modified, it would NOT run on water, in any amount. I should know, being the inventor. So it appeared he was determined to continue to make excuses and try to con people out of their money. Some dealers are claiming 10 times mileage.

15. Dennis said the “engine” must be pointed North to start, and this is grossly mis-leading. I teach all students the proper relationship of the system and am appalled by the false claims and directions that Dennis gives out in an effort to sell plans. He further stated as fact that all engines will get 3 to 5 times their mileage, while he has a generator that only produces double? I have come to believe this man can't tell any truth. The fact that you can get double is good enough, why claim what it can't do?

16. On stage, Dennis was video taped saying that one of HIS Dealers is getting ZERO emissions. I’d like to meet that Dealer, because I don't believe Dennis can produce him. Zero pollution can be achieved, but not with what I have taught to His Dealers. This is beyond the training to achieve 95 to 99% range we teach.

17. Dennis said that the EPA has said “without pollution, you can’t run your car”. I would like to know who he spoke with at the EPA, because I believe Dennis made that up as he was rambling on. We have made several contacts with the EPA and they never said anything even close to that. If Dennis would have read the literature I supplied him he could have made many legitimate comments about the EPA. ( EPA information about GEET is in our Letters section at www.geet.com.

18. Dennis fails to tell the audience that when running the closed-loop lawnmower there is a 10 to 20% decrease in engine performance. In my opinion the reason he shuts the demo and lawnmower off so quickly is that he and his staff have not figured out how to keep them running for any periods of time.

19. Browns Gas; Dennis claims many things I believe to be false with the browns gas units. His dealers who have come to the school ( all but one) said the units they bought do not work. I have one and it doesn’t work. One Dennis Lee, Browns gas unit in Florida blew up during a demonstration and I don’t see him making any attempt to repair it or make good on any sale. If I were going to buy a Browns Gas unit I would get it from some who stands behind their unit, like George Wiseman, at http://www.eagle-research.com.

20. Dennis claims that dirty water will not gum up his Browns Gas unit. I say Bull!!!

21. If you have any information on Mr. Lee or his activities that may help us in federal court please contact Paul or Molley at 801-558-2425.

Your input is welcome.

Paul Pantone, CEO-Inventor

GEET International Institute

info@geet.com

801-558-2425

The GEET Sheet will be posted below the information on the Dennis Lee Lawsuit.

RICHARD L. MUSICK USB #4098

Law Office of R.L. Musick

333 South Denver Street 7

Salt Lake City, Utah 84111

P .0. Box 1215 FILED IN UNIDED STATES DISTRICT

Sandy, Utah 84091 COURT, DISTRICT OF UTAH

(801) 808-2221 OCT 25 2001

BY MARKUS B. ZIMMER, CLERK

DEPUTY CLERK

Attorney for Plaintiffs

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH

CENTRAL DIVISION

GEET INTERNATIONAL, INC~ a Nevada

Corporation, the GEET INTERNATIONAL

INSTITUTE, a Utah Institute, PAUL PANTONE,

an individual, and MOLLY PANTONE, an

individual, COMPLAINT

Plaintiffs, Case No. 2:O1CV-831ST

V.

UNITED COMMUNITY SERVICES OF

AMERICA, a Corporation, BETTER WORLD

TECHNOLOGIES, INC., a Corporation, Judge Stewart

NASDAC, a "Religious Club" headquartered

in New Jersey, DENNIS M. LEE, an individual,

ALISON DAVID, an individual, CHRIS

ROBINSON, an individual, DAVID TOLEN, an

individual, WILLIAM HENRY an individual, and

ERIC BLANCHARD, an individual,

Defendants.

,

GEET v. UCSA, et al Case No. Page I

Complaint

For causes of action against Defendants, Plaintiffs allege as follows:

PARTIES JURISDICTION AND VENUE

I. Plaintiffs Paul Pantone and Money Pantone are citizens of and reside in the State of Utah. Plaintiff GEET International, Inc. is a Nevada Corporation engaged in the business of selling and marketing GEET technology, with its principal offices in the State of Utah. GEET 1NTERNAnoNAL INSTITUTE is an Institute duly licensed under the Laws of the State of Utah, and a licensee of GEET International, Inc., with a license to teach the GEET technology.

2. Defendant United Community Services of America is a corporation with its headquarters and principal offices in the State of New Jersey, a state other than the State of Utah. Defendant Better World Technologies is a corporation with its headquarters and principal offices in the State of New Jersey, a state other than the State of Utah. Defendant NASDAC is a "religious club” with its headquarters and principal offices in the State of New Jersey, a state other than the State of Utah.

3. Defendants Dennis Lee (aka), Alison David, Chris Robinson, David Tolen, William Henry and Eric Blanchard are citizens of a state other than the State of Utah. The matter in controversy, exclusive of interest and costs, exceeds the sum of $75,000.00

4. All of the Defendants are engaged, among other things, in teaching and marketing GEET technologies in violation of applicable agreements. A substantial part of the events or omissions giving rise to this claim occurred in Salt Lake County, Utah, as set forth below.

5. This Court has jurisdiction pursuant to 28 United States Code, § 1332, and venue pursuant to 28 United States Code, § 1391(a)(2).

6. Defendant Dennis Lee is, on information and belief, an individual and resident of Butler, New Jersey. Dennis Lee is engaged in the business of promoting various products throughout the United

GEET v. UCSA, et al Case No. Page 2

Complaint

States, except where prohibited by orders of the Attorneys General of several states. Dennis Lee is the President of UCSA, and Better World Technologies, Inc.

7. Defendant Alison David is, on inform0ation and belief, an individual and resident of Butler, New Jersey, and an officer in UCSA and Better World Technologies, Inc.

8. Defendants Chris Robinson, David Tolen, William Henry, and Eric Blanchard are, on information and belief, employees of United Community Services of America.

9. Defendants Chris Robinson, David Tolen, William Henry, and Eric B1anchard all attended the GEET International Institute in Utah to learn about the GEET technology, and while they were here, each signed a Non-Disclosure and Non-Compete agreement. On information and belief, Chris Robinson was secretly attending on behalf of Dennis Lee and his entities, and David T olen, William Henry , and Eric Blanchard all openly attended as employees of Dennis Lee.

GENERAL ALLEGATIONS

10. Between 1979 and 1997, Paul Pantone developed a novel fuel and method for pre-treating alternative fuels to render them usable as fuel sources for fuel burning equipment such as internal combustion engines, furnaces, boilers and turbines. The technology is commonly referred to as Global Environmental Energy Technology, or "GEET." His invention can be summarized as follows:

a. Any substance that can be vaporized and then burned in the fuel burning equipment is considered an alternative fuel.

b. The alternative fuel may be introduced, as a liquid into a volatilization chamber, which may be heated to aid in the volatilization process and in most cases, will be heated by the thermal energy from the exhaust and the exhaust conduit of the fuel burning equipment.

GEET v. UCSA, et al Case No. Page 3

Complaint

c. A portion of the exhaust may be bubbled through the alternative fuel to assist in the volatilization of the alternative fuel.

d. The fuel vapor produced in the volatilization chamber is drawn through a heated thermal pre-treater.

e. The thermal pre-treater may be mounted inside the exhaust conduit to be heated by the exhaust gases.

f. The thermal pre-treater serves as a reactor, and is configured as a reactor to having a reactor rod mounted therein with reduced annular space surrounding the rod.

g. The volatilized alternative fuel passes through the annular space where it is subjected to the thermal pre-treatment prior to being introduced into the intake system of the fuel burning equipment.

II. On May 16. 1997. Paul Pantone applied for a patent for his fuel pre-treater apparatus and method with the United States Patent and Trademark Office.

12. On or about August 18, 1998, Paul Pantone obtained Patent Number 5, 794,601 for his fuel pre-treater apparatus and method. Exhibit " A ".

13. In June 2000, Paul Pantone moved his operations to Utah. He has been manufacturing parts for GEET conversions~ converting generators to the GEET system, and teaching the GEET system in Utah since that time.

14. In an attempt to increase the number of students in his classes, and as a method of marketing the GEET system, Paul Pantone, as CEO of the GEET International Corporation, entered into a contract with Dennis M. Lee, who signed as President of Better World Technologies on paper with the, letterhead of World Technologies, Inc., on April 23, 2001.

GEET v. UCSA, et al Case No. Page 4

Complaint

15. This contract (Exhibit "B". ) provided that: "Better World Technologies has the rights to modify small engines to the Geet system and will pay GEET Corp. a 2% of the price that BWT sells it for, per engine royalty when that modified engine is shipped. Larger engines may in the future be modified with a first right of refusal going to B. W .T .for offers to all outside parties) if offered to general public (This agreement excludes Wankel type rotary engines)." No royalties were ever paid.

16. Paragraph 3 of the contract provides that " Any United Community Services of America dealer who desires to modify engines must have an individual in their shop trained and certified by GEET Corp. They will buy their parts from GEET Carp. The individual is certified, not the shop and if that individual leaves the employment of the UCSA dealer then another individual needs to be certified by GEET Corp. in order to continue modifying engines at that shop. BWT will pay GEET their reasonable fees for training.)

17. In a newsletter sent to UCSA dealers on or about, 2001, Alison David, over her signature, stated that "…we have taken over training dealers; and we are modifying generators…"Exhibit "C".

17. Paragraph 5. Of the contract provided that " Any Ads or publications referring to the GEET technology need to be approved by GEET Corp before publication. BWT will correct any infractions brought to their attention within one week or less."

18. Dennis Lee told students that they could modify their cars and motorhomes, as well as campers and trailers, which was far not true, and was never approved by GEET.

19. During the summer of2001 we went from 8 students and income of about $15,000 per week to 27 students and income of about $30,000 per week. Once Dennis Lee started advertising that he was opening his own school and began publishing defamatory comments and GEET and Paul and Molley Pantone the level dropped to l or 2 students per week, and negative net income after paying costs.

GEET v. UCSA. et al Case No. Page 5

Complaint

20. BWT, UCSA, and Dennis Lee's actions have cost GEET well over $200,000.00 to date.

21. On infoffi1ation and belief, Chis Robinson, David Tolen, William Henry, and Eric Blanchard have all violated their non-compete agreements with GEET while working for BWT , UCSA, or Dennis Lee.

23. During two weeks while Paul and Money Pantone were attending the Exotic Research Conference in the summer of 2001, some $12,500 in generators and other products disappeared, as well as all receipts for cash purchases. Dennis Lee later told dealers that he had receipts for the equipment at the GEET Institute. Chris Robinson, who now works for Dennis Lee, and, on information and belief, was surreptitiously working for Dennis Lee while working for and being paid by the GEET Institute, immediately left the State of Utah when he was told that the theft had been reported to the police, who would be investigating.

FIRST CAUSE OF ACTION

(Fraud}

24. Plaintiffs incorporate by this reference paragraphs 1 through 23 of this Complaint as if set forth in full herein.

25. Defendants represented that they would send students to the GEET Institute to be trained, and that they would pay royalties on plans and products using the GEET technology.

26. This representation was made in an effort to induce reliance on that fact by Plaintiffs.

27. Plaintiffs reasonably relied on Defendants' false representation and was thereby induced to enter into a contract with Defendants while they did not know that Defendants' true intentions were to

steal obtain access to the GEET technology and training and then use it to make profits without making payments to.

GEET v. UCSA, et al Case No. Page 6

Complaint

28. But for said false representations, Plaintiffs would not have entered into a contract with Defendants.

29. Defendants' representations were made intentionally to deceive Plaintiffs to induce them to enter into a contract with Defendants.

30. As a direct result of Defendants' fraud, Plaintiffs have been damaged in an amount to be proved at trial, but which is not less than the sum of $200,0 00.00. In addition, Defendants' actions were undertaken in such a willful manner as to entitle Plaintiffs to an award of substantial punitive damages in an amount to be proved at trial, but which is not less than the sum of$1,000,OOO.00.

SECOND CAUSE OF ACTION (Conversion of Assets}

31. Plaintiffs incorporate by this reference paragraphs 1 through 3 O of this Complaint as if set forth in full herein.

32. On information and belief~ Defendant Chris Robinson took approximately $12,500.00 in generators and oilier parts from Plaintiffs' premises, as well as important business records.

33. Defendants currently either possess property that lawfully belongs to Plaintiffs, or have disposed of such property, permanently depriving Plaintiffs of its use.

34. Defendants have willfully refused to return this property~ thereby depriving Plaintiffs of their use and possession thereof, and damaging Plaintiffs in an amount to be proven at trial.

35. Defendants actions constitutes conversion of the Plaintiffs' property.

36. As a direct result of Defendants' conversion of Plaintiffs' property, Plaintiffs have been damaged in an amount to be proved at trial, but which is not less than the amount of $12,500.00. In addition. Defendants' actions in converting this property were undertaken in such a willful manner as to

GEET v. UCSA, et al Case No. Page7

Complaint

entitle Plaintiffs to an award of substantial punitive damages in an amount to be proved at trial, but which is not less than the sum of $1,000,000.00.

THIRD CAUSE OF ACTION

(Breach of Contract)

37. Plaintiffs incorporate by this reference paragraphs I through 36 of this Complaint as if set forth in full herein.

38. Under the terms of the Agreement, Defendants agreed to send students to GEET

International Institute to learn about GEET technology, and to pay GEET royalties upon the sale of plans or products, or upon manufacturing and selling GEET technology products.

39. Defendants entered into this agreement fraudulently in an attempt to gain access to GEET technology for the purpose of stealing it, as had been done to other inventors.

40. Defendants did not do what they agreed to do. Specifically, they only sent students until they had trained enough of their employees to open a competing school.

41. On inforn1ation and belief, Defendants have told customers that Plaintiffs are out of

business and that Defendants are the only "real GEET." Defendants have copied GEET technology and are . using the same principles of GEET for their own profit in violation of their Agreement to set up a school

to teach GEET principles, and advancements, or other products, which are part of GEET or Paul Pantone.

42. Defendants have continued to use, and profit from the use of GEET technology which we as the subject of the contract between the parties, claiming it as their own in violation of their contract.

43. As a direct result of Plaintiffs’ breach of contract, Plaintiffs are entitled to an award of damages in an amount to be proved at trial, but which is not less than the sum of $1,000,000.00.

GEET v. UCSA, et al Case No. Page 8

Complaint

FOURTH CAUSE OF ACTION

(Breach of Implied Covenant of Good Faith and Fair Dealing)

44. Plaintiffs incorporate by this reference paragraphs 1 through 43 of this Complaint as if set forth in full herein.

45. Defendants' wrongful appropriation of GEET technology in violation of the contract between the parties constitutes a breach of the implied covenant of good faith and fair dealing, inherent in their Agreement.

46. By taking customers away from GEET International and claiming that Defendants are an independent, and the only source for GEET information, Defendants have further violated the implied covenant of good faith and fair dealing.

47. As a direct result of Defendants ~ breach of the implied covenant of good faith and fair dealing, Plaintiffs have been damaged in an amount to be proved at trial, but which is not less than the sum of $l ,000,000.00.

FIFTH CAUSE OF ACTION

(Defamation)

48. Plaintiffs incorporate by this reference paragraphs 1 through 47 of this Complaint as if set forth in full herein.

49. Defendants started posting WebPages on the internet declaring the Plaintiffs were a fraud and out of business, and in letters to UCSA dealers alleged that Plaintiffs had stolen money and used it for illegal drugs.

50. Additionally, in furtherance of Defendants' schemes, Defendants posted WebPages and had conference calls with dealers broadcast that Plaintiffs were no longer in business and that the only way to obtain GEET was through Defendants.

GEET v. UCSA, et al Case No. Page 9

Complaint

51. These web pages and broadcasts were prepared by the Defendants and were intentionally broadcast by the Defendants with reckless disregard of the truth and/or falsity of the statements made and/or, with the knowledge that the statements were false

52. The broadcast of the false and defamatory statements was a proximate cause of Plaintiffs, loss of sales, loss of income, loss of reputation, and loss of enjoyment of life.

53. As a direct result of Defendants' defamation, Plaintiffs are entitled to an award of damages in an amount to be proved at trial, but which is not less than the sum of $1,000,000.00. In addition" Defendants’ actions in defaming Plaintiffs were undertaken in such a wi1lfuJ manner as to entitle Plaintiffs to an award of substantial punitive dan1ages in an amount to be proved at trial, but which is not less than the sum of $1,000,000.00.

SIXTH CAUSE OF ACTIQN

(Accounting)

54. Plaintiffs incorporate by this reference paragraphs 1 through 53 of this Complaint as if set forth in full herein.

55. Pursuant to the terms of the Agreement between the parties, Defendants were required to pay royalties on GEET plans and products to GEET.

56. On information and belief, Defendants made numerous sales for which they never paid royalties.

57. In information and belief Defendants are in possession of property of the Plaintiffs.

58. Accordingly, Plaintiffs are entitled to an accounting of all plans and products sold by Defendants, and of assets in the Defendants possession, custody, or control, and should be awarded damages in an amount to be proved at trial.

GEET v. UCSA, et a! Case No. Page 10

Complaint

SEVNTH CAUSE OF ACTION

(Tortious Interference with Economic Relations)

59. Plaintiffs incorporate by this reference paragraphs 1 through 58 of this Complaint as if set forth in full herein.

60. On infom1ation and belief, Defendants' actions in making unauthorized use of GEET International Institute's technology and property has interfered with and is continuing to interfere with the Plaintiffs existing and potential economic relations.

61. Defendants' actions in using this technology and property have been taken for an improper purpose and/or have been effected through improper means.

62. Defendants have told potential and new customers that Plaintiffs are out of business and that the Defendants are the only authorized dealers of GEET in an effort to take over the business.

63. As a direct result of Defendants' interference with prospective economic relations, Plaintiffs have been damaged in an amount to be proved at trial, but which is not less than the sum of $1,000,000.00. In addition, Defendants' actions in interfering with Plaintiffs economic relations were undertaken in such a willful manner as to entitle Plaintiffs to an award of substantial punitive damages in an amount to be proved at trial, but which is not less than the sum of $1,000,000.00.

EIGHTH CAUSE OF ACTION

(Civil Conspiracy)

64. Plaintiffs incorporate by this reference paragraphs 1 through 63 of this Complaint as if set

Forth in full herein.

65. On information and belief, Dennis Lee agreed with Alison David, Chris Robinson, David To fen, William Henry , and Eric Blanchard to have the latter four defendants attend the GEET Institute to

GEET v. UCSA, et al Case No. Page 11

Complaint

become knowledgeable in the GEET technology so as to be able to teach it in violation of the rights of Plaintiffs and of the non-compete agreement required of all students, and with Chris Robinson to seek employment. with the GEET International Institute fraudulently so as to be able to spy upon the Pantones and the Institute, and to steal certain property from the Institute.

66. This act injured Plaintiffs because they were deceived into accepting the co-conspirator as bona- fide students, and, in the case of Chris Robinson, employees, allowing the conspirators to acquire skills to teach GEET techno-logy, and to steal records and property of the Institute. As a result customers have been diverted to Defendants' School instead of GEET' s rightful owner, the Plaintiffs.

67. The entering into a contract with GEET, sending students with the knowledge they would compete with the GEET International Institute, and stealing of property was committed in furtherance of the common scheme to cheat that was planned by Dennis Lee, Alison David, Chris Robinson, David Tolen, William Henry, and Eric BIanchard.

68. As a direct result of Defendants' civil conspiracy, Plaintiffs are entitled to an award of damages in an amount 10 be proved at trial, but which is not less than the swn of $1,000,000.00, in addition to treble damages.

NINTH CAUSE OF ACTION

(Injunctive Relief)

69. Plaintiffs incorporate by this reference paragraphs 1 through 68 of this Complaint as if set forth in full herein.

70. Plaintiffs are being irreparably harmed by Defendants' breaches of the contract and the non- compete agreements by teaching GEET technology and selling plans and products, and untrue factual claims concerning the technology which create a crisis of unrealistic expectations.

GEET v. UCSA. et a! Case No. Page 12

Complaint

71. Plaintiffs do not have an adequate remedy at law.

72. Plaintiffs are entitled to preliminary and permanent injunctive relief mandating that Defendants:

a. Cease conducting training in the GEET technology;

b. Cease presenting any presentation or claims concerning the GEET technology, or claiming he has the right to market the technology;

c. Restore all assets of GEET International; and

d. Cease all willful, malicious deceitful statements about Plaintiffs on the Internet, radio, conversation or otherwise.

PRAYER FOR RELIEF

WHEREFORE, Plaintiffs pray for judgment against Defendants, jointly and severally, as follows:

I. That the Court enter judgment in favor of Plaintiffs and against Defendants, jointly and severally, on the first cause of action, alleging fraud, in an amount to be established at trial, but which is not less than the sum of $200,000.00, plus substantial punitive damages in an amount to be proved at trial, but which is not less than $1,000,000.00.

2. That the Court enter judgment in favor of Plaintiffs and against Defendants, jointly and severally, on the second cause of action, alleging conversion of assets, in an amount to be established at trial, but which is not less than the sum of$12,500.00, plus substantial punitive damages in an amount to be proved at trial, but which is not less than $1000,000,00.

3. That the Court enter judgment in favor of Plaintiffs and against Defendants, jointly and severally, on the third cause of action, alleging breach of contract, in an amount to be established at trial, but which is not less than the sum of $1,000,000.00.

GEET v. UCSA, et al Case No. Page 13

Complaint

4. That the Court enter judgment in favor of Plaintiffs and against Defendants, jointly and severally, on the fourth cause of action, alleging breach of the implied covenant of good faith and fair dealing in an amount to be established at trial, but which is not less than the sum of $ 1,000,000.00 plus substantial punitive damages in an amount to be proved at trial, but which is not less than $1,000,000.00.

5. That the Court enter judgment in favor of Plaintiffs and against Defendants, jointly and severally, on the fifth cause of action, alleging defamation, in an amount to be established at trial, but which is not less than the sum of $1,000,000.00 plus punitive damages in the amount of $ I .000.000.00.

6. That the Court enter judgment in favor of Plaintiffs and against Defendants, jointly and severally, on the sixth cause of action, for an accounting, in an amount to be established at trial.

7. That the Court enter judgment in favor of Plaintiffs and against Defendants, jointly and severally, on the seventh cause of action, alleging tortious interference with economic relations, in an amount to be established at trial, but which is not less than the sum of $1,000,000.00.

8. That the Court enter judgment in favor of Plaintiffs and against Defendants, jointly and severally, on the eighth cause of action, alleging civil conspiracy, in an amount to be established at trial, but which is not less than the sum of $1,000,000.00 plus treble damages.

9.Defendants jointly and severally, on the Fourteenth Cause of Action, alleging injunction, that Defendants, its officers, directors, agents, servants, employees, representatives, attorneys, related companies, successors, assigns, and all others in active concert or participation with the Defendants, be temporarily, preliminarily, and permanently restrained from and ordered as follows:

a. Cease conducting training in the GEET technology;

b. Cease presenting any presentation or claims concerning the GEET technology, or claiming he has the right to market the technology;

GEET v. UCSA, et al Case No. Page 14

Complaint

c. Restore all assets of GEET International; and

d. Cease all willful, malicious deceitful statements about Plaintiffs on the Internet or any other forum.

10. That Plaintiffs be awarded pre- and post-judgment interest.

11. That Plaintiffs be awarded their costs of suit, including reasonable attorney's fees. 12. That the Plaintiffs be awarded such other and further relief as the Court deems just and proper.

JURY TRIAL DEMAND

Plaintiffs hereby demand a jury trial of all issues so triable. DATED this 25^th day of October, 2001.

Richard L. Music

Law Office of R.L. Musick

Attorney for Plaintiffs

Plaintiffs' Addresses:

Paul and Molley Pantone

625 West 5300 South #A136

Murray, UT 84123

GEETIntemationa1, Inc.

625 West 5300 South #A136

Murray, UT 84123

GEET International Institute

625 West 5300 South #A136

Murray, UT 841232

GEET v. UCSA, et al Case No. Page 15

Complaint

 ----------------------------------------

pages exposing Joe Newman and  Dennis Lee who some people suspect of leading a nationwide scam.  Also, Tilley, Bearden, Greer Mills (who may be legit?)  and Tewari more info on Bearden