SUMMONS

(CITACION JUDICIAL) NOTICE TO DEFENDANT:

(A VIS 0 AL DEMANDADO):

Turan Petroleum, Inc., a Nevada corporation;

NRG Resources, Inc., a Nevada corporationi

Hiep Trinh, aka Alex Trinh, an individual; Anatoly Vanetik, aka Tony Vanetik, an individual; Mitch Ngo, an individual; and

Does 1 through 10, inclusive

YOU ARE BEING SUED BY PLAINTIFF:

(LO ests DEMANDANDO EL DEMANDANTE):

The People of the State of California, by and through the Cal~fornia Corporations Commissioner

FOR COURT USE ONL Y (SOLO PARA USO DE LA CORTE)

ELECTRomCALL V FILED Superior Court 01 California, County 01 Orange

0111512010 at 01 :48:45 PM Clerk of the Superior Court By Rachelle \t.3vra, Deputy Clerk

SUM-100

You have 30 CALENDAR DAYS after this summons and legal papers are served on you to file a written response at this court and have a copy served on the plaintiff. A letter or phone cafl will not protect you. Your written response must be in proper legal form if you want the court to hear your case. There may be a court form that you can use for your response. You can find these court forms and more information at the California Courts Online Self-Help Center' (www.courtinfo.ca.gov/selfhelp). your county law library, or the courthouse nearest you. If you cannot pay the filing fee, ask the court clerk fora fee waiver form. If you do not file your response on time, you may lose the case by default, and your wages, money, and property may be taken without further warning from the court.

There are other legal requirements. You may want to call an attorney right away. If you do not know an attorney, you may want to call an attorney referral service. If you cannot afford an attorney, you may be eligible for free legal services from a nonprofit legal services program. You can locate these nonprofit groups at the California Legal Services Web site (www.lawhelpcalifornia.org), the California Courts Online Self-Help Center (www.courtinfo.ca.gov/selfhelp). or by contacting your local court or county bar association.

Tiene 30 DiAS DE CALENQARIO·despues de que Ie entreguen esta citecion y papeles legales para presentar una respuesta por escrito en esta corte y hacer que se entregue .una cople al demandante. Una carta 0 una /lamada telef6nica no 10 protegen. Su respuesta por escrito tiene que ester en formato legal correcto si desea que procesen su caso en la corte. Es posible que haya un formula rio que usted pueae usar para su respuesta. Puede encontrar estos tormutertoe de la corte y mas informacion en el Centro de Ayuda de las Cortes de California (www.eourtinfo.ca.gov/selfhelplespanoll). en la biblioteca de feyes de su condado 0 en la corte que Ie quede mas cerea. Si no pued~ pagar la cuota de presentacion, pida al secretstto de·la corte que Ie de un formulario de exencion de pag9 de cuotas. Si no presenta su respueste a tiempo, puede perder el caso por incumpllnliento y la corte te poare quitar su sueldo, dinero y bienes sin mas adverteneia.

Hay otros requisitos legales. Es recomendable que /lame a urfabogado intnedietemente. Si no conoce a un abogado, puede lIamar a un servicio de remision a abogados. Si no puede pagar a un -abogado, es posible que cumpla con los requisitos para obtener servieios legales gratuitos de un programa de servicios legales sin fines de tucro. Puede encontrar estos grupos sin fines de lucro en 131 sitio web de California Legal Services, (www.lawhelpcalifomla.org), en el Centro de Ayuda de las Cortes de California, (www.eourtinfo.ca.gov/selfhelplespanoll) 0 poniendose en contacto con. la corte ° el eo/eglo de abogados locales.

The name and address of the court is: (EI nomote y direcci6n de la corte es}:

superlor Court for the County of Orange 700 civic Center Drive West

CASE NUMBER: 30-2010-00389990- C u- S L· CJ C (Nrim9'o ".1 Cas,

Judge <azuharu tvt3kino

Santa Ana, CA 92701 Central Justice Center

The name, address, and telephone number of plaintiffs attorney, or plaintiff without an attorney, is:

(EI nombre, la otreccion y el numero de tetetono del abogado del demandanie, 0 del demandante que no tiene abogado, es):

Joyce Tsai ~41908 ~19-525-4043 619-525-4045

California Department of Corporations

1350 Front Street, Suite 2034 ~.; ... ,-.l

San Diego, CA 92101 Rachelle IJ.3Vr.3

DATE: (17/1512010 .A.L..AN CARLSON, Clerk of the Court Clerk, by -:- --'...::.:::'-- ' Deputy

(Fecha) (Secreta rio) (A djun to)

(For proof of service of this summons, use Proof of .Service of Summons (form POS-010).) (Para prueba de entrega de esta citation use et formufario PrOQf of Service of Summons, (POS-O 1 0)). No.TICE TO. THE PERSON SERVED: You are served

1. I as an individual defendant.

2.: as the person sued under the fictitious name of (specify):

3. t on behalf of (speCify):

under: I CCP 416.10 (corporation)

I CCP 416.20 (defunct corporation)

j CCP 416.40 (association or partnership) , i other (specify):

4. 1 by personal delivery on (date):

j CCP 416.60 (minor)

.J CCP 416.70 (conservatee)

I CCP 416.90 (authorized person)

Form Adopted fo' Mandatory use Judicial Council of Cal~omla SUM-loe IRev January 1. 20041

SUMMONS

Page 1 of 1

So~nS" Le_Ftus

Code of Civil Procedure §§ 412.20. 465

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28 PRESTON DuFAUCHARD

California Corporations Commissioner ALAN S. WEINGER

Deputy Commissioner

ALEX CALERO (SBN 238389) Corporations Counsel

JOYCE TSAI (SBN 241908) Corporations Counsel

CALIFORNIA DEPARTMENT OF CORPORATIONS 1350 Front Street, Room 2034

San Diego, California 92101

Telephone: (619) 525-4043

ELECTRomCALL V FILED Superior Court of Califomia, County of Orange

0711512010 at 01 :48:45 PM Clerk of the Superior Court By Rachelle \t.:lVra, Deputy Clerk

Attorneys for the People of the State of California

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF ORANGE

THE PEOPLE OF THE STATE OF CALIFORNIA, by and through the CALIFORNIA CORPORATIONS COMMISSIONER,

Case No.:

30-2010-00389990- C U- S L- CJ C

Judge kazubaru Makino

COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF

[CORPORATIONS CODE SECTIONS 25530 AND 25535]

Plaintiff,

vs.

TURAN PETROLEUM, INC., a Nevada corporation;

NRG RESOURCES, INC., a Nevada

UNQUALIFIED OFFER AND SALE OF SECURITIES

[CORPORATIONS CODE SECTION 25110]

corporation;

HIEP TRINH, aka ALEX TRINH, an MISREPRESENTATIONS OR OMISSIONS

individual; IN THE OFFER AND SALE OF

ANA TOL Y V ANETIK, aka TONY V ANETIK, SECURITIES

an individual; [CORPORATIONS CODE SECTION 25401J

MITCH NGO, an individual; and

DOES 1 through 10, inclusive,

Defendants.

THE PEOPLE OF THE STATE OF CALIFORNIA, by and through Preston DuFauchard,

California Corporations Commissioner, acting to protect the public from unlawful and fraudulent

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COMPLAINT FOR fNJUNCTfVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF

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28 sales of securities, bring this action in the public interest. The People of the State of California allege:

VENUE AND JURISDICTION

1. Plaintiff, The California Corporations Commissioner C'Commissioner"), brings this

action to enjoin the defendants from violating the Corporate Securities Law of 1968, California Corporations Code sections 25000 et seq. ("CSL"), and to request necessary civil penalties and ancillary relief. The Commissioner is authorized to administer and enforce the provisions of the

CSL.

2. The Commissioner brings this action pursuant to Corporations Code section 25530

and Government Code sections 11180 et seq. in his capacity as head of the California Department of Corporations ("Department").

3. Defendants have transacted and continue to transact business within Orange

County and throughout the State of California. Defendants Turan Petroleum, Inc. ("Turan Petroleum") and NRG Resources, Inc. ("NRG Resources") each maintain principal places of business in Orange County, California.

4. Defendants Hiep Trinh, also known as Alex Trinh ("Trinh"), Anatoly Vanetik, also

known as Tony Vanetik ("Vanetik"), and Mitch Ngo ("Ngo") (collectively, "Individual Defendants") reside in Orange County. Trinh, Vanetik, and Ngo have offered or sold securities in Orange County.

5. Turan Petroleum, NRG Resources, Trinh, Vanetik, and Ngo (collectively,

"Defendants") have offered and sold securities to multiple residents of Orange County. The violations of law described herein have occurred and will continue to occur within Orange County and throughout the State of California unless enjoined.

PARTIES

6. Defendant Turan Petroleum was originally incorporated under the laws of Nevada

in March 2001 under the name Elite Registry, Inc. ("Elite"). Elite changed its name to Turan Petroleum, Inc. in December 2004. Turan Petroleum's principal place of business is currently 940 South Coast Drive, #100, Costa Mesa, CA 92626. Its principal place of business was formerly

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COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF

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28 3720 S. Susan Street, Suite 100, Santa Ana, CA 92704.

7. Defendant NRG Resources was incorporated under the laws of Nevada on

November 29, 2001. Its principal place of business is currently 18301. Von Karman Avenue, Suite 1050, Irvine, CA 92612. Its principal place of business was formerly 3720 S. Susan Street, Suite 100, Santa Ana, CA 92704.

8. Defendant Vanetik was the president and a control person of Turan Petroleum until

at least June 2008. At all relevant times, Vanetik was the chairman of the board of directors, CEO, co-founder, and a control person ofNRG Resources. Vanetik offered and sold securities on behalf of Turan Petroleum and NRG Resources.

9. Defendant Trinh was a control person of Turan Petroleum until at least June 2008.

At all relevant times, Trinh was the vice president, co-founder, and a control person of NRG Resources. Trinh offered and sold securities on behalf of Turan Petroleum and NRG Resources.

10. Defendant Ngo offered and sold securities on behalf of Turan Petroleum and NRG

Resources.

11. Defendants sued herein under the fictitious names Does 1 through 10, inclusive, are

unknown to Plaintiff, who therefore sues such defendants by such fictitious names, pursuant to the provisions of Code of Civil Procedure section 474. Plaintiff requests leave of the Court to amend the Complaint and allege the true names and capacities of such defendants at such time as they become known.

STATEMENT OF FACTS

12. Defendants Turan Petroleum and NRG Resources claim to be in the oil and gas

business. NRG Resources claims to develop and market lubricants and fuel supplements. Turan Petroleum claims that it owns an oil concession in Kazakhstan, which it is exploring in order to extract oil and gas products.

13. In 1991, Defendant Vanetik was convicted by the United States District Court for

the Central District of California of a felony, namely, subscribing to false income tax returns in violation of Title 26, United States Code section n06( 1), and sentenced to probation for a period of five years and ordered to pay a fine of $5,000.00.

COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF

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28 14. In 2001, Defendant Trinh was barred from ever associating with any National

Association of Securities Dealers ("NASD,'" now the Financial Industry Regulatory Authority, or "FINRA") member in any capacity, based on the finding that he had converted $10,000 of customer funds for his own use. In 2001, based on similar findings, Trinh was barred by the Office of Thrift Supervision from ever associating with certain banking institutions.

15. At all relevant times, Trinh and Vanetik also controlled several other entities,

including Capital Marketing Systems, Inc. ("Capital Marketing Systems") and Valueluck. Capital Marketing Systems was incorporated under the laws of Nevada on July 15, 2004. Its principal place of business is 3720 S. Susan Street, Santa Ana, CA 92704. Valueluck is an entity of unknown form located at 7660 Beverly Blvd., Los Angeles, CA 90036.

16. Beginning in 2005 or earlier, NRG Resources, Ngo, Trinh, and Vanetik offered and

sold securities in the form of common stock in NRG Resources to California residents. From June

2005 through December 2008, they sold approximately $7,051,998.60 worth of common stock to at least 173 investors inside 1l;11d outside of California.

17. Beginning in 2004 or earlier, Turan Petroleum distributed stock worth

$12,250,996.60 to insiders, such as control persons of Turan and entities controlled by them, such as Valueluck.

18. Beginning in 2005 or earlier, Turan Petroleum, Ngo, Trinh, and Vanetik offered

and sold securities in the form of common stock in Turan Petroleum to California residents. From

January 2005 through May 2008, they sold more than $2,612,610.00 worth of common stock to at least 50 investors inside and outside of California.

19. In addition, Ngo, Trinh, and Vanetik offered and sold stock ofTuran Petroleum and

NRG Resources through third parties, such as Valueluck and Capital Marketing Systems, whieh had not paid money for the stock.

20. Defendants offered these securities by means of general solicitation, including but

not limited to an investor referral network throughout the Vietnamese-American community in Orange County.

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COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCTLLARY RELIEF

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28 21. In connection with the offers and sales of these securities, Individual Defendants

told potential investors that NRG Resources and Turan Petroleum would make an initial public offering within three months or a few months. They claimed that each company had taken all of the necessary steps in order to prepare for the initial public offering, including making filings with the Securities and Exchange Commission ("SEC"). Each of the Individual Defendants made specific representations regarding NRG and/or Turan Petroleum's preparations to go public. In fact, neither company had filed anything with the SEC in order to prepare for an initial public offering. To date, neither company has gone public.

22. In connection with some of the offers and sales of securities in Turan Petroleum

and NRG Resources, Defendants told investors they would be purchasing shares of stock directly from the issuer (i.e. Turan Petroleum or NRG Resources). Defendants failed to disclose to the investor that the stock was actually being purchased from a private party, such as Capital Marketing Systems and Valueluck. Defendants failed to disclose that entity from whom the stock was actually being purchased, i.e. Capital Marketing Systems or Valueluck, was controlled by Trinh and Vanetik.

23. In connection with the offers and sales of these securities, Defendants omitted to

disclose to potential investors that a control person of NRG Resources and Turan Petroleum, Vanetik, had been convicted of a felony, namely, subscribing to false income tax returns.

24. In connection with the offers and sales of these securities, Defendants omitted to

disclose to potential investors that a control person of NRG Resources and Turan Petroleum, Trinh, had been barred from the securities industry and the banking industry.

FIRST CAUSE OF ACTION

OFFER AND SALE OF UNQUALIFIED, NON-EXEMPT SECURITIES IN VIOLATION OF CORPORATIONS CODE SECTION 25110 (AGAINST ALL DEFENDANTS)

25. Plaintiff incorporates by reference paragraphs 1 through 24 of this Complaint as

though fully set forth herein.

26. Corporations Code section 25110 provides, in pertinent part, as follows:

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COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF

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28 It is unlawful for any person to .offer or sell in this state any security in an issuer transaction ... whether or not by or through underwriters ... unless such sale has been qualified under Section 25111, 25112 or 25113 ... or unless such security or transaction is exempted or not subject to qualification under Chapter 1 [commencing with Section 25100] of this part.

27. Beginning in at least January 2005 and continuing thereafter, Defendants Turan

Petroleum, Trinh, Vanetik, and Ngo offered and sold securities in the form of common stock to at least 50 investors, raising at least $2,612,610.00.

28. Beginning in at least June 2005 and continuing thereafter, Defendants NRG

Resources, Trinh, Vanetik, and Ngo offered and sold securities in the· form of common stock to at least 173 investors, raising at least $7,051,998.60.

29. The common stock offered and sold by Defendants are "securities" within the

meaning of Corporations Code section 25110.

30. The securities were offered and sold in "issuer transactions" within the meaning of

Section 25 11 O.

31. Defendants, and each of them, offered and sold the securities within the State of

California within the meaning of Corporations Code sections 25008 and 25017.

32. The Commissioner has not issued a permit or other form of qualification

authorizing the offer and sale of the securities by Defendants in the State of California.

33. The offer and sale of securities referred to herein were not exempt from the

requirement of qualification under Section 25110.

34. Unless enjoined by this. Court, Defendants will continue to violate Corporations

Code section 25110.

SECOND CAUSE OF ACTION MISREPRESENTATION OR OMISSION OF MATEIUAL FACTS IN VIOLATION OF CORPORATIONS CODE SECTION 25401 (AGAINST ALL DEFENDANTS)

35. Plaintiff incorporates by reference paragraphs 1 through 34 of this Complaint as

though fully set forth herein.

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COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF

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28 36. Corporations Code section 25401 provides:

It is unlawful for any person to offer or sell a security in this state or buy or offer to buy a security in this state by means of any written or oral communication which includes an untrue statement of a material fact or omits to state a material fact necessary in order to make the statements made, in the light of the circumstances under which they were made, not misleading.

37. In offering and selling the securities referred to herein, Defendants, and each of

them, made untrue statements of material fact and omitted to state material facts to investors and potential investors. The untrue statements and omissions include, but are not limited to, the following:

A. Defendants omitted to disclose, to investors and potential investors, that a control person of Turan Petroleum and NRG Resources, Vanetik.had been convicted of a felony, namely, subscribing to false income tax returns.

B. Defendants omitted to disclose, to investors and potential investors, that a control person of Turan Petroleum and NRG Resources, Trinh, had been barred from the securities industry and the banking industry.

C. Defendants misrepresented that NRG Resources and Turan Petroleum would make an initial public offering within three months or a few months. Defendants claimed that each company had taken all of the necessary steps in order to prepare for the initial public offering. Each of the Individual Defendants made specific representations regarding NRG and/or Turan Petroleum's preparations to go public? such as making filings with the SEC. In fact, neither company had made any filings with the SEC in order to prepare for an initial public offering.

D. Defendants misrepresented that investors would be purchasing shares of stock directly from Turan Petroleum and NRG Resources, and not from a private party. Defendants omitted to disclose, to some investors, that their shares were being purchased from a private party and that the issuer would not receive the money from the sale.

38, The misstatements and omissions referred to herein were "material facts" within

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COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF

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28 the meaning of Corp. Code section 25401 because they were facts that a "reasonable investor" would consider in deciding whether to invest.

39. Defendants' offer and sale of securities were by means of misrepresentations and

omissions within the meaning of Section 25401.

40. Defendants' misrepresentations and omissions of material fact took place "within

the state" of California within the meaning of Corp. Code section 25008.

41. Unless enjoined by this Court, Defendants will continue to violate Section 25401.

PRAYER FOR RELIEF

WHEREFORE, Plaintiff prays for judgment against Defendants Turan Petroleum, Inc., NRG Resources, Inc., Hiep Trinh, aka Alex Trinh, Anatoly Vanetik, aka Tony Vanetik, Mitch Ngo, and Does 1 through 1 0, inclusive, as follows:

I. INJUNCTIVE RELIEF FOR THE VIOLATIONS

For an Order of Preliminary Injunction and ultimately, a Permanent Injunction, pursuant to California Corporations Code section 25530, enjoining Defendants from directly or indirectly:

1. Violating California Corporations Code section 25110 by offering to sell, selling,

arranging for the sale of, issuing, engaging in the business of selling, or negotiating for the sale of and security of any kind, unless such security or transaction is qualified or exempt;

2. Violating California Corporations Code section 25401 by offering to sell or selling

any security of any kind, including but not limited to the securities described in this Complaint, by means of any written or oral communication which includes any untrue statement of material fact or omits or fails to state any material fact necessary in order to make the statements made, in the light of the circumstances under which they are made, not misleading;

3. Removing, destroying, mutilating, concealing, altering, transferring, or otherwise

disposing of, in any manner, any books, records, computer programs, computer files, computer printouts, correspondence, brochures, manuals, or any other "writing" or "document" of any kind

as defined under California Evidence Code section 250, relating to the transactions and course of conduct as alleged in the Complaint of this action, unless authorized by this Court; and

4. Withdrawing from any bank account or disposing of any real or personal property

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COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF

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28 in their possession, custody', or control, without leave of the Court.

II. DISGORGEMENT, RESCISSION, AND RESTITUTION

1. For a Final Judgment requiring Defendants to rescind each and all of the unlawful

transactions alleged in this Complaint, or according to proof, pursuant to California Corporations Code section 25530, subdivision (b), and further requiring Defendants to pay full restitution to each investor determined to have been subject to Defendants' acts or practices which constitute violations of the Corporate Securities Law of 1968, in an amount of at least $9,664,608.60, or according to proof In addition, to pay either the contracted rate of interest or the legal rate of interest on the amount invested by the investors from the date of their investments to the date of judgment herein; and

2. For a Final Judgment requiring Defendants to disgorge, pursuant to California

Corporations Code section 25530, subdivision (b), all benefits received, including but not limited to, salaries, commissions, fees, profits, and any other remuneration, derived directly or indirectly from the actions or practices which constitute violations of the Corporate Securities Law of 1968.

III. CIVIL PENALTIES

For a Final Judgment requiring Defendants to pay to the Department of Corporations $25,000.00 as a civil penalty for each act in violation of the Corporate Securities Law of 1968, pursuant to California Corporations Code section 25535, in an amount of at least $11,150,000.00

or according to proof.

IV. OTHER RELIEF

For such other and further relief as this Court may deem necessary and proper,

Dated: July 15,2010

/ .. , PRESTON DuF jXUCHARD

California Co . ' ra, O}S Commissioner

By:

JO Corporations Counsel

Attorney for the People of California

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COMPLAINT FOR INJUNCTIVE RELIEF; CIVIL PENALTIES; AND ANCILLARY RELIEF