Allegations
(1) ReconAfrica’s plan for using unconventional means for energy extraction (including fracking) in the fragile Kavango area; (2) ReconAfrica would begin unlicensed drilling tests; (3) ReconAfrica would illegally use water for well testing; (4) ReconAfrica would illegally store used water in unlined pools; (5) ReconAfrica would skirt Namibian law and hire an inadequate and inappropriate consultant; (6) as a result, ReconAfrica risked future well, drilling, and water-related licenses in Namibia and Botswana; (7) as opposed to its representations, ReconAfrica did not reach out nor provide adequate information (including in relevant local languages) through accessible means to those to be impacted by its testing and potential energy extraction; (8) ReconAfrica’s interests are in the Owambo Basin, not the so-called Kavango Basin; (9) ReconAfrica has continuously engaged in stock pumping; and (10) as a result of the foregoing, Defendants’ public statements were materially false and/or misleading at all relevant times.