Mark Maloney Scammed!

Thanks to Bajan Citizen for producing relevant links to the latest story making the rounds about Mark Maloney being scammed out of US10 million dollars purported to be a payment for 1 million doses of the AstraZeneca vaccine on behalf of Barbados and two other governments.

The blogmaster has two questions:

  1. On what basis was Maloney’s company Radical Investments Ltd selected to broker this transaction.
  2. Is the government out of pocket because of the errant transaction.
  3. How does being out of pocket USD6.7 million affect Maloney’s financial state to continue to do business.

Mark Maloney Says $12M COVID Vaccine Deal Was A Scam
https://www.law360.com/commercialcontracts/articles/1422923/barbados-co-says-12m-covid-vaccine-deal-was-a-scam

The case is Radical Investments Ltd. v. Good Vibrations Entertainment LLC et al., case number 9:21-cv-81761, in the U.S. District Court for the Southern District of Florida

Radical Investments Ltd. is a St Lucia registered company owned by Mark Maloney. 

He appears to have been swindled out of $6.7 millon USD from the governments of St Lucia, the Bahamas and Barbados who contributed money to buy COVID vaccines for their citizens.

“In April 2021, the Governments of Saint Lucia, The Bahamas and Barbados initiated a bulk purchase of AstraZeneca vaccines, as the minimum purchase from authorized suppliers was one million (1,000,000) vaccines.”
http://www.govt.lc/news/saint-lucia-s-efforts-to-secure-high-demand-covid-19-vaccines.

St Lucia contributed $7.3 million EC
https://www.caribbeannewsglobal.com/approval-of-direct-purchase-for-astrazeneca-radical-investments-ltd/

Mark Maloney is deputy chair of the private sector group put together last March to fundraise and acquire more vaccines.
https://barbadostoday.bb/2021/03/03/high-powered-group-ready-to-assist-with-vaccine-financing/

It is not clear what due dilligence Mr Maloney did before entering into this commercial arrangement with Good Vibrations Entertainment LLC. If you were looking to purchase pharmaceuticals would you do business with a company whith a name that connotes mechanical sexual services, and with an address at 21218 St Andrews Blvd Suite 318 that is a mailbox in a UPS store where 175 other fly by night companies also have their “headquarters”???
http://search.sunbiz.org/Inquiry/CorporationSearch/SearchResultDetail?inquirytype=EntityName&directionType=CurrentList&searchNameOrder=GOODVIBRATIONSENTERTAINMENT%20L210002390860&aggregateId=flal-l21000239086-b92f38d8-b344-45fc-b36d-1320f1675828&searchTerm=GOOD%20VIBRATIONS%20AUDIO%2C%20LLC&listNameOrder=GOODVIBRATIONSAUDIO%20L190000122850

1,254 comments

  • angela cox

    You’re very presumptuous to assume what I’m not worried about.

    However, please explain how ASKING you a QUESTION means I’m “trying to chip away at (your) harmless words which (I) make with effort to interpret?”

    My friend, apparently it’s either English isn’t your first language or you’re semi-literate……… because I’ve realized you seem UNABLE to DIFFERENTIATE a QUESTION from a definitive statement.

    Like

  • ArtaxOctober 21, 2021 7:30 AM

    angela cox

    You’re very presumptuous to assume what I’m not worried about.
    Xxxx

    Maybe so but your preoccupation with my every words gives sufficient evidence for me to make my conclusion
    Xxxcxx

    Yesterday in the house of Parliament a blatant undermining of the rules and laws which directs good governance and laws under a democracy was exposed by Senator Franklyn and your first object of today in your comments to me was one of attacking my intellect
    Be that as it may I could not care less I am comfortable in the way and manner I place my comments and would not be deter by your insults
    Hence I would use my low level of intellect to.speak out against the levelling attacks on Barbados democracy ongoing by the PM and cabinet in.the house of Parliament

    .

    Like

  • angela cox October 21, 2021 8:27 AM

    RE: “Maybe so but your preoccupation with my every words gives sufficient evidence for me to make my conclusion.”

    “Maybe so, but your preoccupation with RESPONDING to my every words gives sufficient evidence for me to make a SIMILAR conclusion” as well.

    RE: “Yesterday in the house of Parliament a blatant undermining of the rules and laws which directs good governance and laws under a democracy was exposed by Senator Franklyn and your first object of today in your comments to me was one of attacking my intellect”

    How do you know whether Caswell Franklyn is correct or not?

    I prefer to wait on more information before making any definitive comments on the issue.

    Ironically, this is the same Caswell Franklyn you used to ‘cuss’ and DISAGREED with on daily basis, when he criticized your former DLP administration, while asking him for more evidence to substantiate his claims.

    RE “Be that as it may I could not care less I am comfortable in the way and manner I place my comments and would not be deter by your insults.”

    Good for you.

    “Hence I would use my low level of intellect to.speak out against the levelling attacks on Barbados democracy ongoing by the PM and cabinet in.the house of Parliament.”

    That’s your prerogative. But, REMEMBER, everyone knows you exhibit a high level of DISHONESTY in so doing. And, this is evidenced by the fact you have a penchant for misrepresenting the truth and RELYING on inaccurate information from sources that are questionable or lack credibility, as your basis to “speak out” …………..

    ………….mainly for reasons of political expediency and to score cheap political points.

    In other words, you DO NOT have any CREDIBILITY in this forum, hence, the reason why you’re asked questions.

    Here endeth the lesson.

    Like

  • Artax
    Here endeth the lesson.

    Xcxcx
    Good riddance knucklehead

    Like

  • No scam news.
    Sigh.
    Story is dead …… ???

    Like

  • heOGazertsOctober 22, 2021 5:32 PM

    No scam news.
    Sigh.
    Story is dead

    Xcccc
    Everything in palm beach court docket
    Be patient

    Like

  • Boys and girls, this dropped off of top posts, top clicks and recent posts.
    Dead even on BU.
    —+—xxx—
    I was called to save the lobby from the music of 555.

    Like

  • Maloney scammed. – BU File 13

    Like

  • Headed for file 13

    Like

  • Reached into file 13 And retrieved this post.

    In all honesty, I think this dog is dead. Maloney got back his money from those who design the scam.

    Like

  • Talking about Scammed
    I put this comment on fb

    Their are holes in the bucket
    How many more left

    Lol.and behold some one reported it to fb
    Fb said I violated community standards
    All.i can say is
    One baffled moment and a blatant attack on freedom of speech
    What de bird

    Like

  • @ TheOGazerts who wrote ” Maloney got back his money “.

    ” show me the money \’ lol

    Like

  • I like this song… It’s about scamming (cheating)

    Like

  • Can you imagine running out of lies?
    What do you do when you realized that your lies are all done what do you do?

    Beg

    Like

  • Sometimes I wonder how many of you are real. Have you ever been deeply in love or are you just partnered up because the music is playing?

    Has someone ever reached in and took up all the space for love in your heart or did you just play it safe and go through the motion of living?

    Have you ever been so deeply in love that you said ‘I will never hurt her. If there is pain then she must be the one who inflicts it first’? Have you ever left yourself vulnerable and exposed?

    Or on seeing misfortune coming to your loved one said ‘Dear God, let me carry this cross’.

    What I am asking is “Do you know what love is?” Have you ever loved without having limits? Without having triggers, alarms, boundaries or an escape clause? Do you have that level of courage?

    Am I getting through to you? Do you know what love is? And if you do, have you ever been loved?

    It is the height of the human experience

    Like

  • Boys and girls… let them know you care

    Like

  • TheoG

    Were you looking for this?

    Like

  • @ TheOGazerts my fellow harrisonian,

    I was going to ask what you smoking but I will respond to this . Sometimes I wonder how many of you are real. Have you ever been deeply in love or are you just partnered up because the music is playing?

    I am real.Never been deeply in love. That is probably why I have two ex- wives.

    Never found a G G clone so had to settle for ,,,,

    Like

  • re the baloney.

    The people of Barbados needs to know the facts. The return of the money is good but there are still questions to be answered.

    Like

  • Sarge A+
    Hants A+.
    Your reward

    Liked by 1 person

  • Elombe Mottley taught me how to play 3 chord blues. I think I was in 4th form.

    For those who care I have been playing guitar since I was about 10 years old.

    Still have the dream of playing on a stage in Barbados but the dream is fading as I approach 70.

    Like

  • Someone will appreciate this

    Liked by 1 person

  • The incomparable Taj Mahal

    Liked by 1 person

  • When is govt going to make a Budget available for the people
    Yesterday in Parliament Atherley questioned the need for a Budget and govt decision of not having prepared one
    This is another violation of the Constitution and governing laws of Barbados by this govt and govt should be called into accountability
    Every penny which is being spent under the laws of governance must be made known to the people
    Barbados is heading towards becoming a Republic and so far many promises under the guidelines of Transparency and accountability has been broken by this govt
    Yes there is a national health crisis however govt cannot take unto itself the health crisis an excuse as not to provide thr the Budget constitutes a Constitutional right of the people right to.know how govt spends the taxpayers money

    Like

  • Having a weak opposition in Parliament does not give govt a right of pushing the Constitution away and making their own rules
    Atherley should at least make a call for a vote of No confidence against Mottley even if as a means of being symbolic however one that would be written into the history books
    This govt reviving laws and rules of good governance is a straight up in the face insult to the people and contains the footprints and leanings of dictatorships

    Like

  • This scam bag not dead
    It is being taken up.in the house of Parliament

    https://fb.watch/8Vsy4GSq_c/

    Like

  • Franklyn calls on Bostic to resign

    OPPOSITION SENATOR Caswell Franklyn wants Minister of Health Jeffrey Bostic to resign over the recent failed attempt by a private sector concern to procure COVID-19 vaccines for Barbados.
    Speaking as the Senate debated the Prevention of Corruption Bill, 2021, yesterday, he described the deal as a “$24 million red herring” or “Vaccinegate”, as he said it had been termed elsewhere.
    Franklyn was again critical of the reported manner in which the attempt was made to acquire the vaccines and expressed disappointment over a claim by Bostic “in a newspaper article”, that “he did not know anything” about the arrangement.
    “I saw a letter . . . signed by a permanent secretary purporting to do the job of the Chief Medical Officer, because the Chief Medical Officer would be the person who is in charge to order these vaccines and then he would send it to the Government Procurement Department. Then the chief supply officer . . . would do the necessary to get the thing here.”
    He added: “The only body who should give that instruction to the permanent secretary should be the minister or somebody senior to the minister, and they ain’t got nobody senior to the minister in the ministry. So that too might be tending towards corruption at ‘brek neck’ speed. It pains me to say that he (Bostic) should resign.”
    During debate in the House of Assembly on Tuesday, Opposition Leader Bishop Joseph Atherley defended Franklyn’s earlier stance on the issue, while Minister in the Ministry of Finance Ryan Straughn denied Franklyn’s claims about the financial transactions and other implications of the arrangement for the procurement of vaccines.
    Franklyn expressed support for the bill, saying it was timely and necessary, and commended Minister of Tourism Senator Lisa Cummins on her introduction of the legislation. “If you want to come to public life and you do not want to declare your assets, don’t come,” he said bluntly. However, he challenged that section of the bill which applied to public servants, arguing that they were already subjected to strict regulation under the Public Service Act.
    He also called for a commission of enquiry to look into the operations of the National Housing Corporation. ( GC)

    Source: Nation

    Like

  • Cannot process centRal bank, covid, Republic, Grenville and the youngster at the same time.

    Processing shams, scams and Caswell.

    Like

  • The PM should resign
    She knew more about the scam than Bostic

    Like

  • You have become my main source of Barbados news.

    Was reluctant to depend completely on you, but I mean with the scams, Republic thing and BarbadosToday wanting subscriptions, I have to depend solely on you.

    Heaven, help me😃

    Like

  • No news. .
    No new scam????
    Has Ram reported in yet? I need my refund.

    Like

  • Pingback: Waste of an Unprecedented Mandate | Barbados Underground

  • Dead as a door nail.
    Maloney made an effort to get back some money. That was all he had to do.
    He will be made whole off the book somewhere.

    Like

  • The island is corrupt as hell.
    Folks who know to eat and keep their beaks clean.

    Next set saying they can hear no evil, speak no evil or see no evil.

    Like

  • Saw my boy was back on the radar. Rushed in to see what’s new.
    Move on. Nothing to see here.

    Like

  • Now my boy is off the radar.
    Gonna do my best to bring him back

    Like

  • Have you ever been fully awake and had a nightmare. Something happened, I don’t know what it was.. hallucination, nightmare

    I imagined I was in Barbados and crossing the road to buy
    Water from 🐇/🐰 (sewage/waste)
    Covid vaccine from Maloney
    Face mask from Ram
    Would not walk directly to an isolation center and forget about the
    fake test from J2/Ca

    Like

  • Thought it was over but it got even worse..
    Went into the bank to make a withdrawal from my savings and had a big argument..

    Damn clerk trying to tell me I don’t know the difference between a deposit and a loan.. I owe not own.

    Like

  • This has to end.. I need to sleep.
    Just when I thought it was over
    Lawson started to crack ‘jokes’
    555 started his musical scratchings
    GP started to preach
    AC started to screech
    Lawd, I feeling weak
    Have a Great Day

    Like

  • You win some. lose some.

    Rock Hard not returning to T&T market

    Andrea Perez-Sobers Dec 21, 2021 Updated Dec 21, 2021

    EMBATTLED cement importer, Rock Hard Distributors Ltd, has no intention of returning to the domestic market, despite a statement by Trade and Industry Minister Paula Gopee Scoon that four companies could soon import cement, bringing competition to the market to offset the 15 per cent price hike recently announced by Trinidad Cement Ltd (TCL).

    The price increase took effect yesterday, and in a message to its “valued clients” last week, TCL said: “We have been absorbing rising input costs for a long time and are now unable to continue to maintain our prices.” The cement company did not specify the quantum of increased costs or their contribution to the 15 per cent price increase.

    In August, Rock Hard closed its doors due to the import duties and implemented restrictions in the domestic market for the commodity.

    Speaking with the Express last Friday, managing director of Rock Hard Distributors Ryan Ramhit said the minister’s announcement that increased competition would keep cement prices in check is “too little, too late”.

    “When I was asking and begging the Government for their support when I entered the market in 2016, nobody took me on and a whole host of restrictions started arising with the company. I wish whoever cement importer or manufacturer decides to set up shop in Trinidad all the best.”

    Ramhit said discussions may take place with the Government if it decides to work with Rock Hard Distributors, by giving the cement importer what it has been asking for, which was to allow them to set up a free and open market to compete fairly with TCL.

    “The company has never asked for any incentives, which we all know that TCL has been getting a whole host of incentives. If for some strange reason the Government decides to go back with duties from zero to five per cent and have no quota or restrictions, I would really have to think long and hard if we would re-enter the market, simply because this administration has been very volatile and very unpredictable when it comes to Rock Hard’s business,” he explained.

    Minister Gopee-Scoon in Senate last week said on learning from TCL that it planned to increase the price of locally manufactured cement, Cabinet took a decision that the Ministry of Trade and Industry should approach COTED (the Caricom agency responsible for trade and economic development) to seek a reduction of the Common External Tariff (CET) on other hydraulic cement from 50 per cent to 20 per cent beginning on January 1, 2022 and ending December 31, 2022.

    However, Ramhit said this move by the Cabinet still would not help his business to be profitable in this country.

    “The 20 per cent is not helping us as duties are supposed to be zero to five per cent and I based my business on that. If 20 per cent was ok with me, when the Government was charging me 15 per cent under the wrong classification, I would not have bothered to challenge it before the courts, but still 20 per cent would not help my business, so I would not come back to the market.”

    Ramhit noted that T&T is the only country in the region that was not supportive when another cement competitor came on the market.

    “In Guyana, the correct rate of duty was 15 per cent and their Government realised what competition will go along with them experiencing a construction boom, so they dropped the rate of duty from 15 per cent to 5 per cent earlier this year and the same goes for the other countries in the region.”

    He added that Rock Hard is awaiting judgment from the Caribbean Court of Justice (CCJ), which is expected sometime next month.


    Source: Daily Express

    Like

  • Four companies to be given permission to import cement, after telling RH to get lost? In Trickidad?

    Who is connected to dese four?

    Yuh knoe whah dah soun like?

    Hahaaaaaaa….

    Dese people so sweet nuh? Dem would sell out dem granmudda.

    Like

  • Rock Hard should not bother wid de judgement.

    Should just tell de Trickis to kiss dem Rock Hard.

    Like

  • DISMISS CASE!

    Two defendants in $10.2m AstraZeneca suit to file motion
    By Maria Bradshaw
    mariabradshaw@nationnews.com
    Two of the defendants in the United States-based lawsuit involving the failed delivery of a $10.2 million consignment of AstraZeneca vaccines to Barbadian businessman Mark Maloney are asking the court to dismiss the complaint.
    Attorney at law Charles Stein and his law firm Davidovitch Stein Law Group, which represented the company Good Vibrations Entertainment (GVE), during its transaction with Maloney’s company, Radical Investments Ltd (RIL), have been granted permission by the judge to file a motion to quash the summons and dismiss the complaint by RIL for what they claim was “lack of personal jurisdiction”.
    That is the latest development in the case, which has not gotten off the ground as yet since the complaint alleging a scam and fraud was filed by Maloney back in September.
    Since then summonses have been issued against the seven defendants named and the court has directed that they provide a single response or separate ones to the allegations but so far only the Steins have responded.
    Stein is contending that RIL had reached a settlement agreement with the law firm which indicated that any adjudication in the matter would be settled in California and not Florida, where the complaint has been filed.
    In a nine-page document to the court outlining its reasons for seeking leave to file a motion to dismiss the complaint, the Steins stated: “The Stein defendants seek leave of Court to file a motion to quash summons and to dismiss the complaint for lack of personal jurisdiction. Mr Stein and his law firm are citizens of the State of California and have been brought into this lawsuit despite the absence of minimum contacts with the State of Florida. In fact, the nexus of this lawsuit to Florida, under any legal standard, is tenuous at best.
    “Second, and equally important, plaintiff has already agreed, months ago, in a settlement agreement with Stein, that “The sole venue for adjudication of any dispute or claim . . . related to the matters
    alleged in the complaint is the courts of Los Angeles, California”.
    Producing to the court documented proof of the agreement, they added: “Plaintiff cannot rewrite this agreement and, therefore, the Stein defendants will raise this wellfounded point in their motion to quash and to dismiss.”
    In requesting leave to file the motion, the defendants further submitted that the court’s consideration of the motion to quash and to dismiss was necessary to preserve their due process right, as they added that RIL had indicated that it would not oppose the motion for leave to file a separate response.
    The defendants proceeded to outline the complaint, noting that RIL was a St Lucia company with its principal place of business in Barbados.
    “At all times alleged in the complaint, it was acting as an agent of the Government of the country of Barbados in an effort to procure the COVID-19 vaccine for the people of Barbados,” the Steins noted, adding that defendant Good Vibrations Entertainment was a Florida limited liability company with its principal place of business in Florida and defendant, Alex Moore, “is alleged to be GVE’s sole member and its principal and to have resided in Florida at all times relevant to this action”.
    However, Stein pointed out: “Yet, the agreements which Mr Moore signed on behalf of GVE so that it may transact business with RIL state that GVE is located in California.”
    In granting the motion, the court allowed Charles Stein and Davidovitch Stein law group ten days to file and serve their response.

    Source: Nation

    Like

  • Motion filed to quash vaccine complaint

    By Maria Bradshaw
    mariabradshaw@nationnews.com
    The Stein defendants who are named in the United States-based case involving the failed delivery of a US$10 million consignment of AstraZeneca vaccinations to Barbados have officially submitted a motion to the court to quash the service of summons and dismiss the complaint brought by Barbadian businessman Mark Maloney for lack of personal jurisdiction.
    Attorney Charles Stein and his law firm Davidovich Stein Law Group (DSLG) are among six defendants being sued by Maloney in the US District Court Southern District of Florida over failure to deliver the vaccines to his firm Radical Investments Ltd. (RIL) last year, after he had engaged Alex Moore, of Good Vibrations Entertainment (GVE), to purchase the vaccines on his company’s behalf.
    The Stein defendants, who acted as escrow agents during the transaction and who are represented by attorneys Seth Kolton and Brian Smith, submitted a 19-page motion last week, putting forward arguments as to why the complaint, which was filed last September, should be thrown out.
    Their main argument was that while the complaint was filed in a Florida court, the entire transaction took place in jurisdictions other than that state and, as a result, the complaint should be dismissed.
    They wrote: “Mr Stein and DSLG are citizens of California and have been brought into this lawsuit despite the absence of minimum contacts with Florida. The Stein defendants understood the parties to the subject transaction to be located in California and St Lucia, and the transfers of funds for the subject transaction were to/from banks in St Lucia, California and New York. In fact, the nexus of this lawsuit to Florida, under any legal standard, is tenuous at best.
    “Closely related to the above, all of the transactional documents state that the seller and buyer are located in California and St Lucia and, furthermore, such documents set forth the parties’ agreement that California law applies to any dispute which may arise thereunder. The escrow agreement – to which Stein is a party – identifies him as a California licensee with a bank account in California. This agreement similarly states that California law governs it. Not the faintest reference to Florida can be found in either the purchase agreement or the escrow agreement,” the defendants stated.
    They also said that exercise of personal jurisdiction over the Stein defendants will not comport with the due process clause of the Fourteenth Amendment.
    “The Stein defendants did not aim any purported tortious act at the citizens of Florida, nor did they cause any harm to Florida,” the defendants noted, adding it was made clear in a settlement agreement that “the sole venue for adjudication of any dispute or claim . . . related to the matters alleged in the complaint is the courts of Los Angeles, California”.
    Late hour
    The plaintiff, they contended, “cannot, at this late hour, litigate with the Stein defendants over whether they committed a tortious act. Rather, the sole issue which perhaps may be litigated between plaintiff and the Stein defendants is whether the settlement agreement has been performed – which issue must be litigated in the forum the plaintiff and Mr Stein voluntarily agreed: i.e., Los Angeles, California”.
    They further submitted that even if the court were to find personal jurisdiction over the Stein defendants and determine it could adjudicate issues arising out of the settlement agreement, the matter relating to the said defendants should be transferred to the US District Court for the Central District of California on the basis of forum non conveniens (a court’s discretionary power to decline to exercise its jurisdiction where another court may more conveniently hear a case).
    “As to his involvement with Radical Investments Ltd., the defendant explained that he met Alex Moore, through a client, and was informed by Moore that he was the CEO of Good Vibrations Entertainment and that this company was located in Santa Monica, California.
    “Mr Moore then introduced Mr Stein to Olivia Watson, who advised Stein that she was an attorney representing a company located in the island nation of St Lucia, known as Radical Investments Ltd. and that RIL would be the buyer of the COVID-19 vaccines in the transaction wherein GVE would be acting as the intermediatory for the manufacturer . . . . Furthermore, she advised that RIL was buying the vaccines on behalf of the Government of the country of Barbados.”
    In relation to the complaint from Maloney alleging that the Stein defendants committed tortious acts in Florida and conspired with co-defendants, Stein noted: “The Stein defendants were not involved in drafting the purchase agreement. [Their] only involvement in the subject transaction was as the escrow agent.”
    Regarding RIL’s contention that the Stein defendants made misrepresentations to it concerning the payment of funds from the escrow account and were negligent with respect to the payment of such funds, again the defendants reiterated that their communications with RIL were directed to St Lucia and the intended beneficiary of the subject transaction was Barbados.
    While submitting that the matter could be resolved “simply by following the settlement agreement entered into between plaintiff and the Stein defendants”, the defendants said that at a minimum the case against them should be transferred to the US District Court for the Central District of California.


    Source: Nation

    Like

  • Democratic or banana republic?

    By Garth Patterson

    ‘. . . all types of conniving methods are still being used to prevent Negroes from becoming registered voters. The denial of this sacred right is a tragic betrayal of the highest mandates of our democratic tradition. “Give Us the Ballot” address delivered by Martin Luther King Jr at the Prayer Pilgrimage for Freedom, May 17, 1957. Democracy is more than an abstract political concept.
    It is a living conviction, an immutable principle by which all civilised societies that recognise the innate worth and equality of its citizens are governed. It recognises the primacy of the people in the governance of their own affairs and the consensual subordination of the elected representatives to the will of the represented. It embodies the audacious notion of governance by the people.
    In her remarks at the Virtual Summit on Democracy, hosted just over a month ago, on December 9, 2021, by the president of the United States of America, Prime Minister Mia Amor Mottley described Barbados as “a country which, though small in size, has played no mean role in the promotion, preservation and protection of democracy and democratic traditions for several decades”.
    She made her remarks “conscious of our commitment to democracy within our country as the world’s newest parliamentary republic”. Saying that freedom of the press, freedom of elections, freedom of movement or freedom of association are not issues for us in the Englishspeaking Caribbean, the Prime Minister considered that the real issue “is more encouraging active citizenship to support the architecture of our democracy, recognising that democracy comes in many shapes and forms”.
    “Fundamentally, democracy must always be about people,” she declared. “Our people and our countries . . . must be both the agents and beneficiaries of democracy. We must work each and every day on this. We must walk the walk and not just talk the talk.”
    With the General Election mere days away, this Government must decide if it is prepared to walk the walk, or else concede that its much-vaunted commitment to democracy is bare ol’ talk. It must choose the type of republic that our new republic will become and how it will be perceived – either one that leads the world in not just espousing democratic principles, but also staunchly and resolutely defending them; or just another banana republic that eschews the rule of law and democratic norms and subordinates the will and national interests of the body politic to the whim and exigencies of the political ruling class.
    The right to vote is foundational in any democracy; it is the bedrock on which democratic societies are built. It is the megaphone by which the voice of each citizen is heard in the selection of his or her parliamentary representative. One man (woman), one vote – that is the essence of universal suffrage; an affirmation of the inviolate right of every qualified voter to have a say in his or her destiny.
    The Constitution mandates that our electoral laws shall be designed to ensure that any person qualified to vote at a General Election has a reasonable opportunity of voting. And the Representation of the People Act declares that every qualified elector is entitled to vote. With over 4 500 souls in isolation and thousands more in quarantine and no indication that the COVID directives will be lifted and/or any safe and appropriate arrangements will be made to facilitate their voting, the Government is decidedly on a dangerous collision course with democracy.
    The COVID-19 pandemic provides no excuse for the jettisoning of democratic norms and traditions, nor any justification for blithely ignoring the law. In a 2020 briefing paper entitled Managing Elections in the Context Of COVID-19: Perspectives From The Commonwealth, the Commonwealth Secretariat has admonished:
    Rule of law
    “All considerations for managing elections during the pandemic should be framed by the rule of law and should have a legal basis. It is through adherence to the rule of law that the democratic and constitutional order will remain on track despite difficult decisions that may need to be made regarding elections during this period.”
    We are daily witnesses to the unrelenting threats to democracy across the globe and, if Barbados is to retain its standing in the international community, it behooves the Government to heed the sage counsel of the Secretariat and the salutary example of its Commonwealth counterparts. It is no small thing to dismissively disenfranchise thousands of otherwise qualified voters, with no credible justification or explanation.
    If the Government wants to avoid squandering the mandate that it legitimately won in 2018, then it still can, and must, prioritise and respect the inviolate right of all Barbadians of voting age to participate in the electoral process.
    It should immediately suspend the elections for a further 30 days and urgently make the necessary arrangements to facilitate voting by all qualified voters, regardless of their medical status. If more time is needed, then summon Parliament and amend the ROPA to create the extra time. Do whatever is necessary, within the bounds of the law, no matter how inconvenient that may be. As Prime Minister Mottley once declared, “principles only mean something when it is inconvenient to stand by them”. Fundamental democratic principles should never be sacrificed at the altar of expedience. It’s not too late for the Government to demonstrate the inspired leadership that has been the hallmark of this administration by correcting this undemocratic course and supporting the architecture of democracy instead.
    A mandate salvaged from the ashes of democracy is no mandate at all. An electoral process that deliberately excludes thousands of qualified voters lacks the imprint of legitimacy and can only produce an illegitimate Government.
    I appeal to the Prime Minister: let the enduring legacy of this administration be that it forged our republic from the unbreakable steel of democratic principles; and that, when it mattered most, it put the people first. After all, that is who democracy is about.
    Garth Patterson is a senior counsel.

    Source: Nation

    Like

  • I done talking ’bout politics

    There was a time very recently when I used to talk about politics in this column. It was a glorious period. But I refuse to talk about politics in this column today.
    Not to blow my own conch shell, but I am above that. I will not put myself in the line of fire to be labelled a lazy, tall, sexy newspaper columnist. I maintain a space in this publication because Barbados must be saved from the despotic Nation newspaper.
    If you caught all the election 2022 references in the above paragraph, you may be spending too much time on social media. What should be a serious process is turning out to be a comedian’s gold mine of errors. Read on for some nuggets.
    The Nation would have us focus on serious issues like the possible disenfranchisement of voters who are under isolation due to COVID or predictions of the resurrection of International Monetary Fund austerity measures.
    One recent Editorial was so brazen as to highlight the need for a strong Opposition. This dictatorial periodical would be so bold as to impose an air of seriousness in this season of silliness, where investigations and speculations about hinted at hard decisions take a back seat to innuendo and speculations about bedroom orientations.
    In the confusion, promises of a constitution reform process seem to backslide and get put on the back-burner. But I done talking ’bout politics.
    Even though some would prefer to discuss the politics and origins of COVID-19 and the hypothesis that it was created in a Wuhan laboratory. Newly released emails show that Dr Anthony Fauci was told by several scientific advisers that it was very likely that COVID-19 was a man-made virus.
    However, these leaders of the scientific world chose to hide this fact for political reasons. They even went so far as to denounce anyone who shared this opinion as a conspiracy theorist. It seems some people want to keep science out of politics as much as they want to keep out religion.
    Lip service
    In fact, the only factor that really seems welcome in politics is economics. Although some have paid lip service to the fact that our problems are cultural, some politicians still seem to put all their faith and energy into finding economic solutions.
    They say that their only concern is putting food on plates and money in pockets. For them, issues like removing Nelson or installing a Barbadian head of state have no weight or import. They do not understand that without cultural pride industry will lag and we have no firm base of economics. Therefore, we will have to import everything.
    But I am not talking about politics today because that would lead to a deep philosophical discussion in order to explain why a God who, in the Bible, refers to himself as “I am that I am”, who is referred to in the Bible by 950 different names and titles, and whose true name is forbidden to be spoken, would be offended by being called “creator”.
    Maybe we should hold a referendum on which of the nearly 1 000 terms for God we should use.
    ’Tis the season to be silly and if you can’t beat ’em, join ’em. So, rather than write an article about politics, I chose to write a silly article that turned out to be the same thing anyway.

    Adrian Green is a communications specialist. Email: Adriangreen14 @gmail.com

    Source: Nation

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  • Maloney’s attorneys argue for jurisdiction

    By Maria Bradshaw mariabradshaw@nationnews.com

    The United States attorneys representing Barbadian businessman Mark Maloney in the case involving the failed transaction of a US$10 million consignment of AstraZeneca vaccines for Barbados have asked the judge to use Florida’s long arm statute to reach the law firm, which acted as the escrow agent during the transaction.
    Two weeks ago, Charles Stein and his law firm Davidovich Stein Law Group submitted a motion for dismissal to the Florida Court, mainly arguing lack of personal jurisdiction.
    However, earlier this week Maloney’s attorneys Gerardo A. Vazquez and Ralph R. Longo IV, responded to the motion by outlining how the transaction occurred and showing its nexus to the state of Florida.
    Maloney, who was sourcing the vaccinations through his company Radical Investments Ltd (RIL), has filed a lawsuit in the United States District Court Southern District of Florida against six defendants, including Alex Moore of Good Vibrations Entertainment (GVE), charging that he was deceived and lured into an elaborate scam in 2021 to advance the sum of US$10.2 million for one million doses of the AstraZeneca vaccine, which never materialised.
    In their response to the motion for dismissal, Maloney’s lawyers argued that the Stein defendants were a member of a conspiracy that began in and has its roots firmly entrenched in the state of Florida and that they had systematic contacts with the main perpetrator of the conspiracy, co-defendant Moore, who “at all times material to the allegations in the complaint” worked and lived in Florida. “The Stein Defendants’ motion makes the argument that they are not subject to the jurisdiction of this court because they have not been to Florida, the plaintiff is not from Florida, and because there is a settlement agreement between the Stein defendants and plaintiff which the Stein defendants assert must be litigated in California. However, the Stein defendants’ argument does not match the wellsettled case law in Florida that Florida courts may exercise personal jurisdiction under Florida’s long arm statute over parties to a Florida civil conspiracy even if the alleged civil conspirator otherwise has no connection to the state,” they submitted.
    They added that the Stein defendants “undoubtedly played a critical role in the scheme to mislead and defraud plaintiff out of millions of dollars, which Plaintiff had deposited with the Stein Defendants in order to procure vaccines for the nation of Barbados, and which were ultimately grossly misappropriated by Stein.
    “Had Stein not transmitted nearly seven million dollars in unauthorized wire transfers, nearly twothirds of which were sent to Moore via GVE, we would not be in front of this Court litigating this dispute. This, coupled with the fact that the Stein defendants were continuously in contact with a Florida citizen and a Florida entity for
    months upon months in order to carry out this fraud, undoubtedly subjects the Stein defendants to being hailed into a Florida Court.”
    They added: “Thus, not only are the Stein defendants co-conspirators in a fraud that originated and largely took place in the state of Florida, they also dealt directly with the Florida person and LLC, both avenues of which independently would be sufficient to bring the Stein Defendants under this Court’s jurisdiction.”
    Furthermore, the attorneys charged that the Stein defendants provided the service of acting as an attorney/escrow agent in a transaction involving a Florida citizen and a Florida LLC.
    They also pointed out that it was based on evidence which the defendants produced showing that Moore was involved in the medical supply and distribution business that Maloney deposited the $12.2 million.
    In addition, the attorneys contended that “despite clear instructions from Plaintiff to Stein to send the $10.2 million only to AstraZeneca or a qualified intermediary, Stein, for some reason which is yet to be fully ascertained, took it upon himself to wire nearly $6.7 million out of the escrow account, $4.2 million of which went to GVE.”
    They further argued that the Stein defendants “committed tortious acts in the state of Florida, both through their direct communications with a Florida resident/the principal of a Florida company to effectuate the fraud, and through their role as a co- conspirator as an escrow agent gone bad…”
    In terms of the defendants’ argument that they and Maloney had entered into an agreement that any dispute arising from the escrow agreement would be settled in California, the lawyers said while this was true the defendants had breached the agreement thereby rendering it invalid and void.
    The concluded: “Given the depth of the Stein Defendants involvement with the scheme here alleged, any argument by the Stein Defendants that they are jurisdictionally isolated from Florida simply is not credible.”

    Source: Nation

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  • DEFAULT JUDGMENT
    By Maria Bradshaw
    mariabradshaw@nationnews.com

    A default judgment has been granted against two of the defendants in the US$10.2 million case involving the non-delivery of AstraZeneca vaccinations to Barbados.
    Last week, the United States attorneys for Barbadian businessman Mark Maloney, the owner of Radical Investments Ltd (RIL), filed a motion for entry of a default judgment against defendant Moniladai Coley and her company Prestige Pegasus, which received US$2 million from the US$10.2 million which Maloney paid to Alex Moore of Good Vibrations Ltd to provide the vaccines.
    Though served with a copy of the complaint and a summons, Coley never appeared in court on the assigned date of January 28, 2021, neither did she respond to the pleadings.
    On January 31 this year, presiding judge Aileen Cannon, sitting in the US District Court of Southern Florida, granted the motion, stating: “Having considered the motion and the file in this action, and with good cause appearing, it is hereby ordered and adjudged that: 1. Plaintiff’s motion for entry of default as to defendant Moniladai Coley hereby granted; 2. Plaintiff’s motion for entry of default as to defendant Prestige Pegasus, LLC, is hereby granted.
    The judge also gave Radical Investments Ltd until February 16 to file a motion for default final judgment against Coley and Prestige Pegasus.
    The order noted: “The motion for default final judgment must include affidavits of any sum certain due by defendant, and any other supporting documentation necessary to determine Plaintiff’s measure of damages.”
    It further advised: “If defendant fails to move to set aside the clerk’s default or respond to the motion for default final judgment within the time permitted by the rules, default final judgment may be entered, which, simply put, means that plaintiff may be able to take defendant’s property or money, and/or obtain other relief against defendant.”
    Coley and her company, Prestige Pegasus, were introduced to Maloney by Moore and represented as an intermediary with the capacity to procure and deliver the vaccines. She was supposed to act as the liaison with respect to
    obtaining the vaccines for RIL from AstraZeneca.
    In the court filings, Maloney charged that they were informed that Prestige was a licensed distributor and because AstraZeneca did not sell directly to anyone other than governments, it would necessitate Prestige’s involvement.
    After the AstraZeneca deal went sour, Moore told Maloney that Prestige had a contract with Serum Pharma Ltd, which would enable them to finally procure the vaccines. However, despite involvement this time with the Ministry of Health in Barbados, that, too, never materialised.
    Coley and Prestige Pegasus were the subject of another lawsuit in New York in 2020 in which a corporation, Diamond Hoo Media, LLC (“Diamond Hook”) obtained a judgment against them in November of 2020 for $335 083.75 over the failed delivery of PPEs.
    In that case, Coley and Prestige held themselves out as a New York corporation doing business in the PPE sector. It was alleged that Coley and Prestige held themselves out to be able to procure 1 000 000 FDA 3-ply face masks, for the price of $670 000, and that she could deliver them within 48 hours of payment of 50 per cent of the purchase price, $335 000.
    Diamond Hook tendered the 50 per cent payment to Coley and Prestige. Apparently, Coley disappeared, and Diamond Hook never received any of the masks, nor did they receive a refund for their 50 per cent deposit. A judgment for the deposited amount was later rendered by the Court in New York against Prestige and Coley.
    So far, only the Stein defendants have responded to the pleadings. Two weeks ago, they filed a motion to quash the service of summons and dismiss the complaint, citing lack of personal jurisdiction.

    Source: Nation

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  • Radical Investments denies allegations
    Maloney’s lawyers: A conspiracy to defraud . . .
    Radical Investments Ltd. (RIL) has denied “each and every” allegation made by Good Vibrations Entertainment (GVE) in its counter lawsuit filed.
    Calling the US$10 million failed COVID-19 vaccine scheme a fiction, the US attorneys for Barbadian businessman, Mark Maloney, have rejected GVE’s attempt to claim damages for breach of contract telling the court that its chief executive officer, Alex Moore, should not benefit from its own wrongdoing.
    In its counter-claim the attorneys stated: “As its First Affirmative Defense, RIL asserts that GVE is barred from recovering damages via its counterclaim because GVE has unclean hands, committed numerous torts against RIL, and has acted as a co-conspirator in a scheme to defrauded RIL out of millions of dollars. What is more, GVE and its principal, co-defendant Alex Lee Moore, were the masterminds of a conspiracy to defraud RIL.”
    They claimed that GVE and Moore “fabricated the AstraZeneca invoice to fraudulently induce RIL to continue with the transaction and also repeatedly assured RIL throughout the transaction that they would procure the COVID-19 vaccines.
    “Unfortunately, the entire COVID vaccine transaction scheme was a fiction. There was never a genuine invoice to purchase vaccines from AstraZeneca. Accordingly, GVE should not benefit from its own wrongdoing.”
    The attorneys also told the US Federal Court that GVE “is barred from proceeding in this action because they have failed to state a cause of action. More specifically, GVE has failed to state plausible or sufficient causes of action and provides implausible conclusions for what is apparently an attempt to plead breach of contract and tortious interference claims”.
    They further asserted that “GVE has failed to satisfy conditions precedent to bringing this action” such as what was expressly stipulated in the purchase and sale agreement dated April 16, 2021, which
    required GVE to provide an invoice from AstraZeneca within 24 hours of the funds being deposited in the Escrow Account, as they charged that the invoice provided was a forgery.
    The attorneys further affirmed that GVE “is stopped from asserting what appears to be claims for breach of contract or tortious interference. GVE fabricated the AstraZeneca invoice to fraudulently induce RIL to continue with the transaction”.
    They charged: “Unfortunately, the entire COVID vaccine transaction scheme was a fiction fabricated by GVE and its co-conspirators. GVE never possessed a genuine invoice to purchase vaccines from AstraZeneca, nor the vaccines from AstraZeneca which it contracted to procure for RIL benefit.”
    Continuing, they wrote that “GVE’s complaint must fail because of the doctrine of anticipatory repudiation. GVE among other wrongful acts, fabricated and delivered to RIL, a fabricated AstraZeneca invoice. RIL relied upon the same to its detriment. GVE repudiate the agreement upon delivery and RIL’s discovery that the AstraZeneca invoice was a forgery.”
    RIL’s counterclaim was sent to the court following Moore’s filing a counter lawsuit against RIL claiming breach of contract.
    Moore has asked the court to dismiss the complaint against them; that GVE be awarded judgement against RIL for its lost profits and expenses and they have also demanded a jury hearing in the matter. (MB)

    Source: Nation

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  • LAWSUIT TWIST

    Florida company countersuing Maloney over US$10m vaccine contract
    In a twist, the man at the centre of the failed delivery of US$10.2 million in AstraZeneca vaccines to Barbados has denied any claim of fraud and is countersuing Barbadian businessman Mark Maloney and his Radical Investments Ltd. (RIL).
    Alex Moore, the chief executive officer of the company Good Vibrations Entertainment (GVE), which Maloney contracted last year to procure the vaccines for Barbados and St Lucia, has charged that Maloney breached the contract by terminating it after discovering vaccines cheaper than the US$10 per dose charged by GVE.
    Moore further charged that Maloney did this to pocket the profits and asked the court to dismiss the lawsuit and award GVE judgement for its lost profits and expenses.
    The case is being heard by a United States Federal Court.
    Deny allegations
    However, the US attorneys for Maloney filed a counterclaim denying all of Moore’s allegations as “GVE has unclean hands, committed numerous torts against RIL, and has acted as a co-conspirator in a scheme to defraud RIL out of millions of dollars”.
    Moore, who denied the majority of the pleadings filed by Maloney in his amended lawsuit wrote to the court stating: “Now assuming the role of counter plaintiff, Good Vibrations Entertainment LLC sues RIL and avers and alleges as follows: that after the execution of the contract RIL discovered that the pricing through intermediaries that was being paid through GVE was substantially less than what RIL had agreed to pay GVE. More particularly, GVE was able to obtain the AstraZeneca vaccine for substantially less than US$10 per dose. As a result, RIL realised it had effectively paid substantially more than that which it might have been able to obtain the vaccine assuming that it was available to RIL.
    “After execution of the agreement, and after the orders were placed, RIL discovered that AstraZeneca had agreed to provide dosing through Covax in perpetuity at the rate between $3 and $4 per dose to low and middle income countries which would have also included Barbados and RIL’s other client. The Government of Barbados ultimately discovered this as well.
    He added: “In effect, RIL had made a bad investment and rather than making whatever the price differential was between the $12 per dose (including commission) and RIL’s agreement with the governments that it had apparently overcharged, it sought to cancel the agreement and reap the benefit of the price differential between the roughly $3 to $4 per dose that GVE and its intermediaries would have paid and that which they had paid for the dosing, yielding a profit to RIL of an additional $6 to $7 million.”
    Moore claimed that RIL breached the agreement by cancelling it and attempting to go behind the back of GVE and its intermediaries; that RIL interfered with GVE and its intermediaries in an effort not to help the citizens of Barbados but in an effort to extract the profit for itself.
    Lower price
    “Upon information and belief, the governments purportedly represented by RIL have found their vaccines elsewhere at substantially lower prices than quoted by RIL to provide the dosing. They have demanded the return of the funds. Such was done after RIL had cancelled the agreement and attempted to go directly to the manufacturer to obtain the vaccines, something that it was not entitled to do as it was not in the approved vendor chain, and after GVE expended sums of monies to intermediaries and for transportation of the vaccines.”
    Continuing, he claimed that RIL’s predicament was of its own making as, had it not wrongfully cancelled the contract, GVE would have realised a profit well in excess of the funds demanded by RIL.
    Moore also gave notice that his company was suing RIL for the profits lost as a result of the wrongful cancellation and all expenses it has incurred to fulfil its obligations.
    In relation to RIL’s lawsuit against Moniladai Coley and her company Prestige Investments, Moore said that to the extent that RIL was in anyway defrauded or the victim of unfair and deceptive actions on the part of Coley or Radical, that each was also the victim of the very same actions and that he was entitled to recover an equal amount from Prestige and Coley.
    In relation to the amended lawsuit in which he stands as a defendant, Moore suggested that Maloney had sued the wrong GVE company.
    “GVE/Moore admit there is a Florida LLC with the same name and under the same control as the entity involved in the transactions which are the subject of this litigation. However, the agreement was entered into in April 2021 and that GVE is an Ohio Limited Liability Company that had its principal place of business in Newport Beach, California.
    “GVE/Moore deny that at the time of the agreement the Florida LLC was even in existence or that Moore resided in Florida.”

    Source: Nation

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  • Court victory for Maloney
    BARBADIAN BUSINESSMAN Mark Maloney has scored a victory against one of the defendants who he claimed defrauded his company Radical Investments Ltd (RIL) of millions of dollars paid for COVID-19 vaccines.
    On February 16, judge Aileen Cannon, sitting in the United States District Court of Southern Florida where the civil case is being heard, granted a default judgement against defendant Moniladai Coley and her company Prestige Pegasus, for US$2 million, the exact amount they received from the US$10.2 million which Maloney paid to Alex Moore of Good Vibrations Ltd to provide the vaccines. A default judgement can be issued when a defendant fails to respond to a summons or fails to appear before the court.
    Coley, who goes by the name ‘Millionaire Babe’ on her social media pages, and is owner of the company Prestige Pegasus, was introduced to Maloney by Moore, and represented as an intermediary with the capacity to procure and deliver the vaccines. She was supposed to act as the liaison with respect to obtaining the vaccines for RIL from AstraZeneca.
    $2 million
    The judge stated: “Plaintiff Radical Investments Ltd, a St Lucia company, with its current address of 20 Micoud Street, Castries, St Lucia, shall have and recover from defendants Prestige Pegasus LLC, a Colorado limited liability company, domiciled at 7182 Edgewood Drive, Highlands Ranch, CO 80130 and its principal, defendant Moniladae D. Coley, aka Moniladai D. Coley, individually and as principal of Prestige Pegasus LLC, currently domiciled at 6625 Reseda Blvd, Reseda, CA 91335, jointly and severally, the sum certain of $2 million for let execution issue forthwith.
    “Post-judgment interest shall accrue at the current legal rate allowed under 28 USC. § 1961 as of the date of this final default judgment until this judgment is satisfied.”
    In their application for the default judgement, the US attorneys representing Maloney charged that Coley controlled, operated and managed Prestige, and that she was its sole principal.
    They said the company “was a mere instrumentality of Coley, and was used by Coley to conduct her illicit and fraudulent dealings. As plead, there does not appear to be any other business function of Prestige Pegasus LLC other than to commit this fraud”. The lawyers further told the court that “Coley repeatedly lied, misrepresented and defrauded the plaintiff into believing that defendants could obtain these vaccines and to not to cancel the transaction, which ultimately cost plaintiff nearly $7 million, $2 million of which was retained by Coley via Prestige”.
    Referring to Maloney’s complaint and exhibits, the attorney added: “Coley has publicly flaunted her new-found wealth on social media, purchasing Rolls Royce vehicles, designer shoes and handbags, multiple diamond-encrusted Rolex watches, and other luxury items that did not appear on her social media pages prior to these events.
    “Undoubtedly, Coley has enormously benefited from the funds which were transmitted to Prestige, which further demonstrates that Prestige was merely a sham that Coley hoped would shield her from liability stemming from her ill-gotten gains.” ( MB)


    Source: Nation

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  • Radical case set for next March

    The case involving the failed delivery of the US$10 million COVID-19 vaccines to Barbados and St Lucia will be heard in the United States District Court Southern District of Florida next March.
    Judge Aileen Cannon, who for the past several months during a pretrial motion heard claims and counter claims from plaintiff Radical Investments, a company owned by prominent Barbadian businessman Mark Maloney, and defendant Good Vibrations Ltd. a US company owned by Alex Moore, set a jury trial for March 13, 2023.
    The judge also notified both parties of a strict calendar of events which must be adhered to beginning from April 29, 2022, through to February 2023.
    Maloney filed a lawsuit claiming that he was lured into an elaborate US$10. 2 million scam when he tried to procure one million doses of the AstraZeneca vaccine for Barbados and St Lucia through the US-based Good Vibrations Ltd.
    In the motion, Maloney
    outlined how he was introduced to Moore in March 2021 as someone who had the ability to secure the vaccines.
    The price was set at US$10.2 million. A commission of $2 million was to be paid to Good Vibrations upon delivery of the drugs to Radical Investments.
    Around April 27, 2021, Radical Investments released the US$10.2 million based on assurances received from Moore’s attorney but the vaccines were never received. Radical Investments managed to get back about US$5.4 million of its initial deposit, leaving approximately US$6.7 million in arrears.
    So far Radical Investments has been awarded a US$2 million default judgement against defendant Moniladai Coley and her company Prestige Pegasus, who was supposed to act as the intermediary for securing the vaccines.
    Maloney has never spoken publicly about the matter but Prime Minister Mia Amor Mottley assured Barbadians that even though Government was aware of the plans to secure the vaccines, it never advanced any money. (MB)

    Source: Nation

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