1 George Sharp

3525 Del Mar Heights Road, #620

2 San Diego, CA 92130
(310) 498-4455
3 (619) 446-6717 fax
4 In Propria Persona
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6 SUPERIOR COURT OF THE STATE OF CALIFORNIA
7 COUNTY OF SAN DIEGO, CENTRAL DIVISION
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9 GEORGE SHARP, ) Case No.
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10 ) PLAINTIFF GEORGE SHARP’S
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11 Plaintiff, ) COMPLAINT FOR
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12 v. ) 1) Breach of Contract;
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13 Cuba Beverage Company, Mark Hagen, )
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14 Margaret Willett and DOES 1 through 500, )
inclusive, )
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Defendants. )
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____________________________________ )
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COMPLAINT
 1 COMES NOW PLAINTIFF AND ALLEGES AS FOLLOWS:
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3 1. At all times mentioned herein, plaintiff Sharp, “SHARP” was a resident of San
4 Diego County, California. SHARP is a well-known activist against penny stock fraud and a
5 former consultant to OTC Markets Group, Inc., the provider of the trading platform under which
6 microcap stocks such as Cuba Beverage Company, also known as pink sheet stocks, exchange
7 hands. OTC Markets has publicly acknowledged SHARP as an expert in tracking microcap
8 market activity.
9 2. Defendant Cuba Beverage Company (“CUBA”) is a public company traded on
10 OTC Market Group’s OTC Link platform, under the symbol “CUBV”.
11 3. Defendant Mark Hagen (“HAGEN”) is an individual living in La Jolla, California
12 who acts as defacto President of Cuba Beverage, as an alter-ego. The plaintiff is informed and
13 believes that HAGEN has served time in prison for bankruptcy fraud.
14 4. Defendant Margaret Willett (“WILLETT”) is an individual living in La Jolla,
15 California who acts as CUBA’s Corporate Secretary and Chairman of the Board and is an alter-
16 ego of CUBA. The Plaintiff is informed and believes that WILLETT cohabitates with HAGEN
17 and earns her living primarily as a waitress, and is a shill for CUBA’s other alter-ego HAGEN.
18 5. Plaintiff is informed and believes and thereon alleges that Defendants CUBA and
19 WILLETT and HAGEN were alter egos of each other. Plaintiff is informed and believes and
20 thereon alleges that there has existed a unity of ownership and interest between CUBA and
21 WILLETT and HAGEN, such that any individuality and separateness between them did not
22 exist, and that each of those defendants were the alter ego of the other. The entities were mere
23 shells, instrumentalities and conduits through which WILLETT and HAGEN carried on
24 business, exercising complete control and dominance of such business to the extent that any
25 individuality or separateness of the defendants CUBA and WILLETT and HAGEN did not exist.
26 Adherence to the fiction of the separate existence of the entities Defendants as entities distinct
27 from the individual Defendants would permit an abuse of the limited corporate/LLC immunities
28 and privileges and would sanction fraud and promote injustice and bad faith. In addition to the

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COMPLAINT
 1 degree of control that WILLETT and HAGEN had and exercised over CUBA (the entities by
2 virtue of their ownership and control of their business and financial affairs), those defendants
3 have caused and allowed the commingling of funds and other assets of the entities and
4 individuals, the use of the same employees, and use of the entities as a mere shell or conduit for
5 the affairs of the other individual Defendants.
6 6. Plaintiff is ignorant of the true names of defendants sued herein as DOES 1
7 through 500, inclusive, and therefore sues these defendants by such fictitious names. Plaintiff
8 will amend this Complaint to allege their true names and capacities when ascertained. Any
9 allegation against any defendant shall apply to each DOE defendant
10 7. Plaintiff is informed and believes, and on such information and belief alleges, that
11 at all times herein mentioned, each defendant was the agent of each and every other defendant,
12 and in doing the things alleged herein, was acting in the course and scope of its/his agency and/or
13 employment and was acting with the consent, permission and/or authorization of each and every
14 remaining defendant. The acts and conduct of each defendant herein was ratified and approved
15 by every remaining defendant.
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17 Chronological Factual History of Claims
18 8. On June 17, 2019, the Defendants, relying on the Plaintiff’s reputation and
19 experience in the microcap markets, retained the Plaintiff (“the FIRST CONTRACT”) to provide
20 advice on and effect the dissemination of any public statements, including press releases; or the
21 filing of any disclosure with the Secretary of State for the State of Wyoming, United States
22 Securities and Exchange Commission (“SEC”), OTC Markets Group, Inc. (“OTCM”) and the
23 Financial Industry Regulatory Authority (“FINRA”). The Defendants paid the Plaintiff in
24 advance of his services, which were deemed complete upon OTC Markets Group’s designation
25 of CUBA as “Current” in its filings.
26 9. On February 20, 2020, the Defendants again retained the Plaintiff (“the SECOND
27 CONTRACT”), this time as a Consultant acting as a Corporate Advisor, specifically within
28 CUBA’s relationship to its shareholders, OTC Markets Group, accountants, attorneys and

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COMPLAINT
 1 FINRA. The terms of the contract and duties of the Plaintiff were set forth in an Engagement
2 Agreement for Advisory Services, a true copy of which is attached to this complaint as Exhibit
3 “A”. Plaintiff received his direction and was supervised in his activities by HAGEN
4 10. Under the terms of the SECOND CONTRACT, the Plaintiff was to be paid
5 $15,000 on February 20, 2020 and an additional $15,000 on May 20, 2020.
6 11. On February 25, 2020, the Plaintiff received $7,500 from WILLETT as first
7 payment on the SECOND CONTRACT by PayPal money transfer.
8 12. Under the terms of the SECOND CONTRACT;
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10 The Consultant may, at its own discretion, suspend or terminate this Agreement at any
11 time, if there is a reasonable suspicion of unethical, illegal, or contra-regulatory
12 activities undertaken by the Client. The Consultant may also terminate this Agreement if
13 the Consultant is in breach of the Agreement itself.
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15 and;
16 The Client shall remain responsible for remunerating the Consultant for the entire term
17 of this Agreement, if the Consultant terminates the Agreement under this clause.
18 Termination of this Agreement under this clause shall in no way entitle Client to
19 reimbursement of fees and retainers and Client accepts forfeiture of such fees and
20 retainers, paid or unpaid, upon termination.
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22 13. In spite of numerous promises by HAGEN and WILLETT in their representation
23 of CUBA, the Defendants did not pay the Plaintiff the contracted amount as set forth in the
24 SECOND CONTRACT.
25 14. Among the many unethical, illegal, or contra-regulatory activities undertaken by
26 the Defendants is the misrepresentation to OTC Markets Group that HAGEN had no relationship
27 with CUBA, when in effect, HAGEN is an alter-ego of CUBA and directed the Plaintiff in his
28 activities.

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COMPLAINT
 1 15. As a result of the Defendants’ failure to abide by the terms of the SECOND
2 CONTRACT, including failure to pay the Plaintiff as set forth in the contract and the
3 Defendants’ unethical conduct, the Plaintiff terminated his service under the SECOND
4 CONTRACT on April 30, 2020 and demanded payment.
5 16. Since the Plaintiff terminated his service, he has received assurances from the
6 Defendants that he will receive his renumeration as guaranteed under the SECOND
7 CONTRACT, but to date has not received anything beyond the February 25, 2020 payment of
8 $7,500.
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10 FIRST CAUSE OF ACTION
11 Breach of Contract
12 (against all Defendants)
13 17. Plaintiff hereby re-alleges and incorporates by reference the facts and allegations
14 contained in Paragraphs 1 through 15 as though fully set forth herein.
15 18. The Plaintiff abided by the terms of and performed his duties as defined by the
16 SECOND CONTRACT.
17 19. The Defendants are in violation of the terms SECOND CONTRACT through
18 their unethical conduct and because they did not remunerate the PLAINTIFF as required under
19 the terms of that agreement.
20 20. Under the terms of the SECOND CONTRACT, the Defendants are required to
21 remunerate the Plaintiff for the full value of the agreement, in the amount of $30,000. To date,
22 only $7,500 has been received by the Plaintiff.
23 21. In spite of numerous assurances from the Defendants, before and after his
24 termination of service, the Plaintiff has not been paid the balance owing on the value of the
25 SECOND CONTRACT.
26 22. As a result of the Defendants’ breach of the SECOND CONTRACT, the Plaintiff
27 is owed $22,500 plus reasonable costs and attorneys fees.
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COMPLAINT
 1 WHEREFORE, Plaintiff prays judgment against the Defendants as follows:
2 1. On Plaintiff’s First Cause of Action herein:
3 (a) for damages in the amount of $22,500;
4 (b) for cost of suit herein incurred;
5 (c) for such other and further relief as the court may deem proper.
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7 Dated: June 5, 2020 By: George Sharp, In Propria Persona
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10 ____________________________
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COMPLAINT
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28 EXHIBIT “A”

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COMPLAINT