Professional Documents
Culture Documents
CORPORATION
ACCOUNT EXECUTIVE
I'A6E
1'OF
ARMSTRONG SLICK
STATEMENT PaRIoD
STIWLEY K CATERBONE
4331WEST' 14RION ST:
LANCAS T FR
DATE
OEGINNING
PA
17603
SOLDDEUVSREO
ORWORT
'WWHT.RICEIVEO
on LW(I
12-01-83
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ENDING
Tw4aR.
DtSCRIPTION
m a OR e m v
.ML
64.75C
AMOUNT CHARGED
AMOUNT CREOITEI
THE' YTb C l E O I T IWT REST TOT, LS SHOVW OW. TNfSJ ST4RHENT U :LL' BE REPORT EO TO THE I R S
AND ANY ACPROpRIAT STBTE T hX' AUfAORITY'fll' LZFU' JF' FEDER bL: IWFORWATtON RETURN 1099
1
ALL1 PROCEEDS- OF' SA ES TRlNS KTIONS U f t L ' M l R E W I I E O TO T:WE IRS FOR THE PERXOD 8E61NWtN6
7-139. THtIJ' 12-31-13 I N LPEI'OF F E O E R A L ~ M W R R A T ~ ~ ~ ~1 0
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POSITIONS
:WTERYlTfOWAL SISNAL
i CONTROL GROUP PLC
I;EIJSQR~~ATTC'COA LTQ
400
I R t PRICE
PORTFOLIO V4tUES
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Page 1 of 646
Page 2107 of 2953
i
k
i
%
me.
L!
t
.
d
I have several
that warld enable me to slake a very fast and easy
trahsitiar into the industry. I tau3 good aoanuniaticn akilb and I an
very cnafcctable dealing w i t h at-,
acmmtmb, bankers, private
husinees arnere, etc.. I have sane experieme in qrdicaticne and capital
f~ticnfmmr#aeoftheworkthatIhwedDneinthespontsindustry. I
haveagreatdealofknowle&geandexperienceinuorkingwithtaxlareand
regulations c c m m h g the private irmestcPr. I also feel quite c u n S e
wcPrking w i t h the amlytical aapeds of the bmineas
as feasakdity
analysis, cust mections, bu3gets, etc.. I have had paet expriencc in
the efforts of sub aontzadors far different m e c t s .
~~
--
Stanley J. C a t e r k e
4)
r
,
'
55 Butler Ave.
Lancaster, PA 17601
(717) 299-5958
Dear Mr. Z i e l i n s k i :
As per
thatIwouldliketo n w e m a e ~ t h e d i r e c t i c n o f ~ t e f ~ a n d
I am firding that
m
t cccupatian is taMng me further fran that
objective. I have been dealing in the financial in3ustq far the past 4
years, since graduatirq frcm odlege. I have beenvery mtmaskl inmy
field, hmmx I feel that this is a critical time in my cmeer in that it
is only going to b e a h m o r e d i f f i c u l t to make the transiticnas timegoes
on.
BecauseofthefactthatComnaarealthhas~mnesalesand~
driven due to the carpetiticn in the financial services im%stry, my past
sales experience and reoord would be of significant benefit regarding a
transiticn into ycnu -tian.
I have learned the b d m i c a l aspects of
an-prate finance i n mae of an idirect m y thm@~my education regarding
aaprate stru&ums and strategies as relatirq to investmer~ts. I am
familiar w i t h the f h a m i a l statenents of carpanrations, and have a very
broad~tanaingandexperienwin~iness.
E
t
Iwouldbeveryinterestedin~mneabauttheopporhrnitiesthatyou
new have within ycur organization. I am lcoking for a salary in the $30,000
range.
L
L
I want t o thank y m
Page 3 of 646
Page 2109 of 2953
OK P r c p x t i e s
i
h
39 North m k e t Street
Lancaster, PA 17603
ATIN: Don K. lJ@xse
future.
-t
Regards,
Page 4 of 646
Page 2110 of 2953
HOW TO USE
OUR SERVICES
-\
Our services may be retained in any combinaIn necessary to benefit the athlete or to ysist the
ntract advisor in handling the financial affairs
the most competent and efficient manner. We
ve all heard of the horror stories of the famous
Irs and athletes; however, there are far more
bries of less publicized athletes that we never
ar which are the result of improper financial ade. We must remember that as the longevity of a
lyers career siiortens; due to
.~ipetition,injury, attrition, and
momic conditions affecting the
~fessionalsports industry, it
:omes even more important to manage the
ancial affairs in the most prudent manner
iilable.
PRO FINANCIAL
6ROUP, LTD.
-7'
OUR COMMITMENT
Ve guarantee that any and all services rendered
the behalf of any Contract Advisor or Profeslal Athlete will be performed in a satisfactow
,
U.S. 16-4014
RIGHTS
nner or EXHIBIT
we will refund
any andCIVIL
all fees.
W; CLAIM \..
--\.
Property
Advancewill
Media
ntain that
ourofservices
notGroup
only benefit the
"Dedicated to Performance"
/'
,,
OUR SERVICES
*
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Estate Investments.
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Tax Planning
* Cash Management
Page 6 of 646
Page 2112 of 2953
'
'
*
*
*
THE FOUNDERS
Pro Financial Group, LTD. is an outgrowth of
S. J. Caterbone Associates, a Financial Planning
Consulting Firm. S. J. Caterbone Associates
specializes in managing the financial affairs of upper income individuals, small businesses and the
professional athlete. Because of the demand for
an array of diverse and extremely competent advisors in managing the financial affairs of the professional athlete, we feel that our success is due to
the large and ever-expanding information network
that we have developed. After discussing the needs
of several contract advisors across the country, we
have learned that we offer a very unique and
highly qualified financial support system. Pro
Financial Group, LTD. is now in the position to
provide the benefits
of this
support15,
system
Thursday
December
2016 to
other contract advisors.
10/19/2006
mdt eral
002530
SAVINGS- --'&
~
~~
PAY
TO T H E
ORDER
OF
>+
JIM '12 86
.. .
. . ..
BANK
'
8-1
4:
DATE
FEDERAL
HOME L O A N
BANK
1Ie002 5 3011'
oF PmTTsmumo*
PITTSBURTH. PA
C O L 3 0 0 L2 3 51:
D E T A C H A N D R E T A I N T H I S STATEMENT
6/12/86
3s IN P A I M E N T O F l T e H S D E S C R l m E D O E L O I .
o r c o a a E C r P L E I S E N O T I F Y U S PROMPTLY. N O RECEIPT O E S t R E D .
TIlE ATTACHED C H E C K
I FN
DESCRIPTION
LOAN 0 0 1 0 0 7 8 9
AMOUNT
100,000.0(
CATERBONE S.
Page 7 of 646
Page 2113 of 2953
Page 8 of 646
Page 2114 of 2953
US District Court
The Eastern represented
District of Pennsylvana
TheForshares
Federal
False Claim Act
by this certificate have Section
not 3189
been
registered
Page 9 of 646
Page 2115 of 2953
FDR
JULY 1. 1986
LWGBER. PA -TION
Page 10 of 646
Page 2116 of 2953
TABLE OF CDKTENE:
Mission S t a W
Page 2
Corporate Objectives
Page 3
Eusiness Strategies
Pase 4
Distrifiutim Strategies
Page 6
Services Strategies
Page 8
Market R n e t r a t i m Strategies
Page 10
Page 11
Coqwrate Stanrlards
Page 13
I n i t i a l Capitalization
Page 14
Financial Iiiaights
Page 15
Contingency Plans
Page 16
=P -g-
Q-arp
Page 17
Organizational
(harts:
Wit A
Page 20
Wit B
Page 21
Page 11 of 646
Page 2117 of 2953
in
1. To m e the people of the caurty, state and ~ t i m
the hanjlirq of their finances through the m r t of azr financidl
planners ard other advisors, and their persond relationships with their
clients.
2 . To meet the expectations of our various constituercies:
planners, eaployees, stockholderr, and the people residing in the area we
serve.
Page 12 of 646
Page 2118 of 2953
rr~npany
as the major provider an3 setvicer of
financial prducts and advice in the clasely related fields of
invesb-m-~ts,financial mnsultation, mortgage banking, l i f e irmmnce,
prcrPertY and d t y in=-=,
taxes, law, ard real estate.
1. lb position the
2.
!Ib transform
the fra-ted
5.
Page 13 of 646
Page 2119 of 2953
Page 14 of 646
Page 2120 of 2953
Mass m.rM5.q
M. Charitable organization
Counseling center
charitable g i v w s e m b a r s .
estate planning s e m b r s
life planning seminars, etc.
Page 15 of 646
Page 2121 of 2953
1. Current Situation
2.
Cuzlwt
and
w d
Situation
Page 16 of 646
Page 2122 of 2953
PI-rn
Current Situation
(Continued)
-.
Current Situation
are independent and thus use various p1amb-q txxhniques,
Planoffer a limited
ard differ in their areas of expertise.
~~
Page 17 of 646
Page 2123 of 2953
1. current Situation
2.
-
Current Situation
--
Page 18 of 646
Page 2124 of 2953
Currmt Situation
Current
Situaticxr
in wr
Ongoing client m i c e is a desire for m s t &es
marketplace. H m e r , the amstant pressure is a~pliedto plmlers
to produce new clients and new sales as 90% of eKnings is still
. camnission generated. Ihe t i m e required to praspert and close new
sales severely limits the necessary servicing time.
a &annual
Ongoing client m i c e will be =lied
newsletter anl sadannual client investmnt @te
delivered
altermtely every three months. ?he costs of these services will
be borne by client-paid asset m g e r w t fees, innzrance renewals
an3 mtml furd trailing oamnissions. Althmqh this is an
ambiticus, high-tech undertaking, our basic inclination remains
persondl client review ssqsions held on a regular basis.
We also expsct better crossover r e l a t i d p s and broadened
information base for both planners and specialists due to amon
laation.
Page 19 of 646
Page 2125 of 2953
m k e t Penetration Strateqy
1. Ekisting Clients
--
--
--
'Ihese t w o markets w i l l be
3. Business and Retirement Markets
singled cut for specific eqhasis because of the vast potential and
strcsrg reex3 for planning axrg these grou~s. Business benefit plans
and specifically "cafeteria plansv1w i l l be rwketed. RetireJrPnt
mrkets w i l l be expam3ed p r k i l y t 3 m q h increased sedmr
marketing.
Page 20 of 646
Page 2126 of 2953
Planner Sumort S w i c e s
It is cur plan to pruvide necwary office and clericdl m
r
t
services to help each planner or a f f i l i a t e d c t his o r her business.
W
e into limit w office to w r t services and not t o pruvide
-ific
marketim sexvices for individuals.
marketing efforts
will be for the gmup a t large, that is t o say t h a t individual
prospecting w i l l be a m n a l expmse borne by the planner or advisor.
1) Phone H a n d l i r q
including the f a c i l i t y to forward other
business lines to cnu c ~ t r a system
l
should a planner leave the
office.
2) m t i t i v e S t a m l a r d Bn-esmndence
3)
4)
cmwter Services
financial plans and invesbwmt rmnitoring
services w i l l be prarided through data base entry. Yass
distritution an3 hardplan generation w i l l be done on a
5) p D f e s s i o ~ Networkinq
l
our in-house a f f i l i a t e s in law,
accounting, tax, estate, real estate, mortgage brukerage,
portfolio mamgement, l i f e innrranCe and pxqertq/casualty
insurance stand ready to serve clients related financial needs.
6)
7)
8)
Page 21 of 646
Page 2127 of 2953
9)
Page 22 of 646
Page 2128 of 2953
--
(XTR
ST-
.'
...l.
Serves its
custarrers well.
m hi* principles.
3.
~EG&PS
4.
Makes
5.
m ~ ~ l regularly.
g r
6. ~nanrsits mission.
7.
8.
9.
12.
Retains- .
13.
14.
Is value driven.
spirit.
laJest level.
17.
pus.'les d e ~ i ~ i ~ - m a k jto
n gthe
18.
Page 23 of 646
Page 2129 of 2953
Page 24 of 646
Page 2130 of 2953
C u r mgement i
s d t t e d to deriving a large portion of its
personal i x a ~
fmpn serving clients as crpposed to relying on managemmt
i . . 'Ihis should preserve w cash flm and insure its grcrJth.
Page 25 of 646
Page 2131 of 2953
f
i
Page 26 of 646
Page 2132 of 2953
Bob was then pmmoted to division mnager of the West Coast. In eat
position, he tripled the size of the sales force an3 increase3 volume wer
500% in a period of 2 years. His division of American Express handled
w e r $100 million dollars of investor mnies.
Bob was then asked to take wer the largest operation in the
scutheast, located in Atlanta in 1984. With wer 60 financial planners,
ha7dling an wcess of $200 million dollars of investor's mmies, Bob again
simed his territory into the top echelon of the ccnnpany.
With FSC since 1985, Bob has opened the first three aapny-mnd
offices and nm supervises an excess of 75 qloyees. His qmations new
rank 4th in all FSC related planning -ti=.
Bob brings to Financial
Management G r o u p , Irc. 10 years of experience in the financial planning
industry in both sales and sales -gment.
He is a member of the
International Association of Financial Planners and is in the process of
capleting the cwrre wok for r i f i e d FFinancial Planners designation.
Bob is a frequent speaker at both corporation and business financial
planning functions and has been quoted frequently in local an3 national
media pblications. He continues to hardle investments for select
clients.
Bob will serve as president, chaof the board and will be the
largest s ~ o l d e r . Kis e x p r i m in - g i q
and developing large
financial service organizations will pmvide the leadership and expertise
necessary to insure the growth we envision.
Page 27 of 646
Page 2133 of 2953
--
Mike began his Financial Planning career f i v e years ago with ILS a
IXlrhq his career w i t h ILS he
subsidiary of m i c a n Mp-.
amnq
the firm's top planners. He was on the Presiderrts Advisory Cavril for
I= i n 1985 and f m a f i e l d of wer 5,200 lX6 planners, finished amg
the tap 66 financial planners in the cwuntry. In 1983 am3 1984 he was
amg the top three in IR?&Llified
Plan Frcduction. In Septanber, 1985
he left ILS to f o n n h i s om financial planning firm.
-'a'.
Mike currently m g e s i n excess of $14 million in c l i e n t assets.
Page 28 of 646
Page 2134 of 2953
Em Advisory, ........................
..
..........The
Portfolio MaMger
Financial Pla-
&
Market Timer
Finn
&
Xeal Estate
&
Shirk
Please note that the W e f i n s are currently wrler nqotiations and have given
ve.rhl amnnitment for affiliation.
Page 29 of 646
Page 2135 of 2953
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Page 30 of 646
Page 2136 of 2953
,-
.2
In this connection. I would think you would indicate the possible difficulty
of retaining such persons as one of the risk factors. Also, if such persons
will continue to operate or be connected with the businesses from which they
come, you will have to point out the possibility of a conflict of interest
on their part. Further, it is my impression that these businesses are
highly competitive. All in all. you should discuss among yourselves what
type of information about the proposed businesses a sophisticated potential
investor would want to know, and then state your response in vriting.
Obviously, I would err in favor of more, rather than less, discussion.
With reference to the parent corporation, you should give detail sirnilar to that you will give for the subsidiaries. Further, you may want to
discuss how the parent will "manage" the subsidiaries; that is, whether each
subsidiary will be largely autonomous or whether parent company officers
personnel will be directly involved with the subsidiaries' activities.
With further reference to "risk factors". I would think you would add
a section stating that a11 of the business activities are in fields that are
highly competitive. Also. I would think you should state that, while the
founders have had considerable experience in certain of the activities, they
have not had such experience with respect to all of the other subsidiariesr
proposed businesses; further. I presume none has had experience in managing
a group of companies and business activities such as is contemplated in this
case.
,.
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Page 31 of 646
Page 2137 of 2953
prOfessio
As I review the "Business" section, and as a potential investor. I
would want to horj more about how solid the arrangements are with " p l a q
and affiliatesw. and also have some idea of the timetable by which the
c/
corporation believes it can begin to engage in business.
v-
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Page 32 of 646
Page 2138 of 2953
JD*HDistrict
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w z l 2. D O D D ~ O
In Re:
August 7. 1986
1
As we discussed, it will be necessary to file five copies of Form
D not later than 15 days after the first sale of securities in the
proposed limited offering. This requirement is sunnnarized in the first
paragraph of Form D, a partially completed copy which is enclosed. We
will discuss the actual mechanics of filing, as well as completion of
the form, after you have reviewed the enclosed.
Please also note from that paragraph that it is necessary to make
one or more additional filings as the offering progresses and is completed.
This will be your responsibility, as only you will know how long the
offering will continue and when it is completed. It is most important
to make these filings in a complete and timely manner, as failure to
do so will make the exemption under SEC Regulation D unavailable, and
therefore may result in a violation of the registration provisions of
the Securities Act of 1933 and, consequentially, potential liability
for the directors and officers.
You will note that in several places I did not have sufficient
information to complete the form, and I will rely on you to supply this
information. I have marked where these items appear. In particular.
you will have to complete Page 5, which requires you to itemize the
offering expenses, and then allocate the use of proceeds. You will note
Page 33 of 646
Page 2139 of 2953
WJJ: jp
Enclosures
Page 34 of 646
Page 2140 of 2953
In Re:
Dear Stan:
1
The purpose of this letter is to address generally the requirements
you must meet in connection with the actual offer and sale of securities
by the corporation pursuant to the exemption under Section 203(d) of
the Pennsylvania Securities Act of 1972 with respect to which a filing
has been, or is about to be, made with the Pennsylvania Securities
Commission.
Page 35 of 646
Page 2141 of 2953
BY
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
Page 36 of 646
Page 2142 of 2953
Harrisburg, PA
17101
Sincerely,
SJC/mld
Enclosure
Page 37 of 646
Page 2143 of 2953
LAW OFFICES
O'DAY0
SMITH
LANCASTER, PA 17602
MICHAEL P. O ' M Y
EDWARD H. SMlTH
PHIUDELPHLh.PA IS121
1215b763-5280
17171 393-4001
T I M O M A. IAN-
M O W JOY, PA 17552
17V)653-8131
A u g u s t 2 2 , 1986
M r . S t a n l e y J. Caterbone
F i n a n c i a l Management G r o u p , L t d
1755 Oregon P i k e
L a n c a s t e r , PA 17601
Dear S t a n :
Enclosed herewith p l e a s e f i n d i n v o i c e p e r t a i n i n g t o t h e
f o r m a t i o n o f F i n a n c i a l Management Group a n d i t s s u b s i d i a r i e s
t o g e t h e r w i t h a n i t e m i z a t i o n o f a l l c o s t s and e x p e n d i t u r e s
made.
If you h a v e a n y q u e s t i o n s , p l e a s e f e e l f r e e t o c o n t a c t
me.
Very t r u l y y o u r s ,
h SMITH
,A+&Timothy A.
LL--
tinza
TAL:djg
Enclosure
Page 38 of 646
Page 2144 of 2953
O'DAY0 SMITH
243 u o n T n DUKE STREET
LANCASTER, PA 17602
,717) 393--1
eo5 VEST
MAIN m E E T
A u g u s t 25, 1986
Commonwealth o f PA
Department o f S t a t e
Corporation Bureau
308 N o r t h O f f i c e B u i l d i n g
H a r r i s b u r g , PA 17120
Gentlemen:
E n c l o s e d h e r e w i t h p l e a s e f i n d A r t i c l e s of I n c o r p o r a t i o n f o r
a p r o p o s e d b u s i n e s s c o r p o r a t i o n t o b e known a s FMC S e c u r i t i e s ,
lnc.,
$75 r e p r e s e n t i n g f i l i n g f e e s f o r same.
I t r u s t you w i l l f i n d e v e r y t h i n g t o b e i n o r d e r .
V e r y t r u l y yours,,
O'DAY
.,I .\I.
,
:djg
& SMITH
Timothy A.
.
Lanza
Er~closures
cc:
Mr. S t a n l e y J . C a t e r b o n e
Page 39 of 646
Page 2145 of 2953
MICHAEL P. O'DAY
EDWARD H. SMITH
TIMOTHY A. UNU
1
Mr. Stanley J . Caterbone
F i n a n c i a l Management Croup, L t d .
1755 Oregon Pike
Lancaster, PA 17601
-I
- ---
Page 40 of 646
Page 2146 of 2953
LAW OFFICES
O'DAY 0
SMITH
W N O R M DULL ITNEET
LANCASTER, PA 17602
NILH A E L P. O D A Y
I ~ w h w . rI ~
i. SMITH
1 1 # . 4 ~ 1IIY
1
A. U N L A
17171 393-4UOI
A u g u s t 2 5 , 1986
I n t e r n a l Revenue S e r v i c e C e n t e r
P h i l a d e l p h i a , PA 19255
Gentlemen:
E n c l o s e d h e r e w i t h p l e a s e f i n d A p p l i c a t i o n f o r Employer
I d e n t i f i c a t i o n Number f o r F i n a n c i a l Management Croup, L t d . and
F i n a n c i a l S e r v i c e Insurance Agency, I n c .
I t r u s t you w i l l f i n d
e v e r y t h i n g t o be i n o r d e r .
Very t r u l y y o u r s ,
T i m o t h y A . Lanza
Enclosures
cc:
Mr. 2 t a n i e y J . C a t e r b o n e
..
..
Page 41 of 646
Page 2147 of 2953
TO:
Gentlemen:
The undersigned, intending to be legally bound, hereby irrevocably
Shares of Common Stock, no par
tenders this subscription for
value, of Financial Management Group, Ltd. (the "Shares"), at a purchase
in the aggregate), including
price of $per share ( $
my check for the latter amount.
,I
This subscription may be 'rejected by the Company in its sole discretion. If this subscription is rejected, or if it is determined that this
offering will not be consunanated for any reason, the payment tendered by the
undersigned will be returned to the undersigned, without interest, as soon
thereafter as practicable.
i
-
The Company will sell the Shares to the undersigned in reliance upon
the following representations, warranties and agreements of the undersigned,
which the undersigned hereby makes in favor of the Company:
(a) The undersigned has received the Offering Memorandum dated
August-,
1986, prepared solely by the Company, and, prior to signing this
Subscription Agreement, has carefully reviewed the Offering Memorandum, and
has relied solely on the information contained therein, information
otherwise provided to him or it in writing by its officers, or information
from books and records of the Company. The undersigned understands that all
documents, records and books pertaining to this investment have been made
available for inspection by his or its attorney.and/or his or its accountant
and/or his or its purchaser representative, and himself. The undersigned
and/or purchaser representative(s) has had a reasonable opportunity to ask
questions of and receive answers from the officers, concerning the offering
of the Shares and all such questions have been answered to the full
satisfaction of the undersigned. No oral representations have been made or
oral information furnished to the undersigned or his or its purchaser
representative(s) in connection with the offering of the Shares which were
in any way inconsistent with the Offering Memorandum.
(b) The undersigned (i) has adequate means of providing for his or
its current need and possible personal contingencies, (ii) has no need for
liquidity in this investment, (iii) is able to bear the substantial economic
risks of an investment in the Shares for an indefinite period, and (iv) at
the present time, could afford a complete loss of such investment. The
undersigned together with his or its purchaser representative, if any, has
Page 42 of 646
Page 2148 of 2953
(c) The undersigned is acquiring the Shares for his or its own
account for investment, and not with a view to distribution or resale, and
understands that the sale of the Shares has not been registered under the
Securities Act of 1933, as amended (the "Act"), or under any state
securities laws in reliance upon exemptions therefrom for non-public offerings. The undersigned understands that the Shares must be held indefinitely
unless the sale thereof is subsequently registered under the Act and under
certain state securities laws, or an exemption or exemptions from such
registration are available, and that the Company is not required to register
the Shares under the Act, or to take any steps to perfect any exemption
therefrom for any resale of Shares pursuant to Rule 144 under the Act or
otherwise. The undersigned further understands that (i) the Company is
under no obligation to register the Shares on his behalf or to assist him or
it in complying with any exemption from registration, and (ii) the certificates representing the Shares (and representing shares of common stock upon
conversion of the Shares) will bear a legend summarizing the foregoing
restrictions and the 12 month prohibition of sale provided in the Pennsylvania Securities Act of 1972.
Page 43 of 646
Page 2149 of 2953
The undersigned represents and agrees that he or it will not sell his
Shares for a period of twelve months from the date of purchase. The
undersigned understands that he or it has the right to cancel the purchase
of the Shares within two business days after making payment therefor.
The undersigned understands that he or it (A) has the right to withdraw his or its subscription, without incurring any liability to the
Company, and to cancel his purchase of the Shares within two (2) business
days after he or it enters into a binding contract of purchase by executing
and delivering the Subscription Agreement, or within two business days after
the exemption of this offering from registration under the Pennsylvania
Securities Act becomes effective, whichever is later, and (B) cannot sell
his or its Shares for a period of 12 months from the date of purchase if his
or its subscription is not timely withdrawn.
INDIVIDUAL
If you are an individual and meet any of the following tests, please
initial in the appropriate spaces below.
I certify that I am an accredited investor because
1.
I had individual income (exclusive of any income attributable to my spouse) of more than $200,000 in 1984 and 1985 and
I reasonably expect to have an individual income in excess of
$200,000 in 1986. ("Individual income" means adjusted gross
income, as reported for federal income tax purposes, less any
income attributable to a spouse or to property owned by a
spouse, increased by the following amounts (but not including
any amounts attributable to a spouse or to property owned by a
spouse): (i) the amount of any tax exempt interest income under
Section 103 of the Internal Revenue Code (the "Code") received,
(ii) the amount of losses claimed as a limited partner in a
limited partnership as reported on Schedule E of Form 1040,
Page 44 of 646
Page 2150 of 2953
ENTITY
The authorized representative of any entity executing this Subscription Agreement should initial in the appropriate spaces below if the entity
meets any of the following tests.
The undersigned entity is
1.
2.
3.
4.
5.
6.
7.
Page 45 of 646
Page 2151 of 2953
8.
9.
10.
(a)
(b)
(c)
(d)
Page 46 of 646
Page 2152 of 2953
Individuals:
P r i n t o r Type Name
Signature
Date
P r i n t o r Type Name
Signature
Date
Residence Address
J o i n t Tenancy
Tenants
Page 47 of 646
Page 2153 of 2953
Common
Date
Signature
Page 48 of 646
Page 2154 of 2953
ive. if
Address
Taxpayer I..
No.
Date
Signature
Page 49 of 646
Page 2155 of 2953
1986
i o J~ rrar
HARRISBURG.PA.
-IRD
1 1)01*"**
"0.C".
A "kLS
w. JC,,".
,.*OY*L*Y
"LIBCrn, n ""IICI
DAVID I L C * " U
"011"A"
I.. R I I I L
""R*.
."VAN
I I C U R D w *.c*c*50*
C,LLI."
I. C * C S * Y I I
MLNll'l I " r Y l C Y D L I J
rou1c. 2".
WILLI1*
ROBLIT W. CHCRRY
D A n D i DlSMCr
Lcr IWSSCL
L I U I t C C A. ,"lllLl
t.OUIWOLa m011AN
171oe-11e6
..
*.
BY
WJJ/sg
Enclosures
Jamouneau
Page 50 of 646
Page 2156 of 2953
BOX
486
Harrisburg. PA 17408
COMMITTEE ON LEGAL
ETHICS AND PROFESSIONAL
RESPONSIBILITY
Chairrnon
M#Ch.,F A a,:>*
Vice Choirman
.lom-~
'j "=:%*?"
PBA Liaison
,%.IC
;=: :ae,
Page 51 of 646
Page 2157 of 2953
Page 52 of 646
Page 2158 of 2953
.............................
pdh
Enclosure
Page 53 of 646
Page 2159 of 2953
.............................
Page 54 of 646
Page 2160 of 2953
November 2 1 ,
1986
M r . Stanley J. Caterbone
Executive Vice President
F i n a n c i a l Management G r o u p , L t d .
E d e n P a r k I1
1 7 5 5 Oregon P i k e
Lancaster. Pennsylvania
17601
Dear S t a n l e y ,
printer
2 4 0 0 b a u d H a y e s modem
DOS 3 . 1
9=s'L
( S e r i e s 300H) S b /
r7Yd
and C r o s s t a l k X V I
/'$6
I f t h e e q u i p m e n t and s o f t w a r e m e n t i o n e d a b o v e was t o b e i n c l u d e d
w i t h t h e p a c k a g e s y o u s e n t me, p l e a s e l e t me know i m m e d i a t e l y .
Sincerely,
4Jig,*-
R . B r a d f o r d Thomas
Vice President1
D i r e c t o r o f MIS
cc:
R o b e r t E . Kauffman
Steve Franklin
Page 55 of 646
Page 2161 of 2953
Advisory, Inc.
m m w m w
IN',.'
*"N"Gr*E*r
OID",.
Lancarter, PA 17601
717-569-4100
LID
STANLEY J. CATERBONE
PRESIDENT
Stanley J. Caterbone
President
SJC: lmk
CC
Page 56 of 646
Page 2162 of 2953
Executive Vice-President
Stanley Caterbone
Acts as Marketing Officer, Supervision of Registered Investment
Advisor, Supervision of Computers and Word Processing,
Insurance Product Selecsion
1.
2.
3.
4.
5.
6.
7.
Page 57 of 646
Page 2163 of 2953
"tnnovarton m ~ l n o n c ~ srralegres"
al
.
January 5, 1987
Pcnsionr
dn , fkt
heft
Ikfind Contribution
P d t Sharing
ATTENTION:
Kmuglis
Dear Stan:
IRA'S
STAN CATERBONE
Auet Manngrment
Emphyrr &n&t
Plans .
Employee Communicption
Booklets
L n t e Planning
College Funding m
Charitabk Giving
Foun&tlonr
Page 58 of 646
*.~-~L~
.,A=..
A Rrgirrcmd BrokcrlD?lcr
''
1
10/19/2006
2 .
NELM L SHIRK, JR
3CER S REIST
DAVID WAGENSELLER. Ill
KENELM L SHIRK. 111
ATTORNEYS A T LAW
P.0
WILLIAM J PELHAN
STEPHEN R GIBBLE
DORE C VALAVANES
SAMUEL M MECUM
BARBAM RElST DILLON
LANCASTER,
BOX 1 5 5 2
PENNSYLVANIA17603-1552
January 8, 1987
PRINCIPAL OFFICE
132 E. CHESTNUT STREET
AREA CODE 717
LANCASTER-394-7247
AKRON-859-1742
C0127 WO2DV U M I l
Stanley J. Caterbone
Executive Vice President
Financial Management Group, Ltd.
Eden Park I1
1755 Oregon Pike
Lancaster PA 17601
Re:
Dear Stan:
Hope you had a merry Christmas and a good start to your new
year.
Just wanted to let you know that the Umikers paid their bill
within a week,after it was sent. That made me feel better. Thanks
,
: so much for your guidance.
I had a thought before I close the file. Do the Umikers have
powers of attorney? They really should. Given that so many of their
assets are not jointly titled, the incompetency of either one of them
would create enough complications that the appointment of a guardian
would probably be necessary. On the other hand, they might rather go
to that expense at that time than have a power of attorney instrument
done at this point. They could limit the power of attorney to each
other, if that would make them feel better.
At this point in time, we are billing people an average of
about $1,000.00 for appointment of a guardian, as a hearinq is necessary. On the other hand, a power of attorney instrument costs about
$50.00 to $75.00, and so it is obvious why we advise people of its
wisdom.
I know that you are well familiar with the uses, advantages
and disadvantages of a power of attorney, so if you would like to
briefly discuss those concepts with the Umikers and get back to me,
please do so. If you do not feel it is necessary or you have discussed it previously, just let me know. If they wish to discuss it
with me, that is fine. The powers that are now available under the
OTHER OFFICES
107 WEST MAIN STREET
EXHIBIT
U.S. 16-401417522-2014
CIVIL RIGHTS CLAIM
EPHRATA, PENNSYLVANIA
717-733-2588
Property
of Advance Media 117-626-2404
Group
2 5 0 MAPLE AVENUE
Thursday
December
15, 201617566-132C
QUARRWILLE.
PENNSYLVANIA
717-786-1123
10/19/2006
S t a n l e y J. C a t e r b o n e
~ x e c u t i v eV i c e P r e s i d e n t
January 8, 1987
P a g e Two
Page 60 of 646
Page 2166 of 2953
COMMONWEALTH OF PENNSYLVANIA
ROBERT M. IAM
Chairmin
I
DICKTHORNBURGH
Governor
FREDERICK H. PLANK
Commi~sioner
LORI HEISER
Commissioner
--
--
DATE OF FILING:
Dear M r . Caterbone:
2.
3.
4.
-.---.--
Page 61 of 646
Page 2167 of 2953
-'
10/19/2006
Stanley J. Caterbone
F M G Advisory, Inc.
3&1uuy.13, 1987
Page 2
b.
c.
6:
7.
8.
..
CERTIFIED W
EXHIBITRETURN
U.S. 16-4014
CIVILREQUESTED
RIGHTS CLAIM
RECEIPT
Property of Advance Media Group
Page 62 of 646
Page 2168 of 2953
Bob Kauffmn,
Mike M e t t , and
S t a n Caterbum
Pr*
Goal: lb E?e m
i
n
t
e
d President of FIG Emker/D=aler
In the
I w i l l continue to familiarize myself w i t h any detail w h i c h may
aid the hplementation of the B/D while taking no direct responsibility for B/D
pmcessing or hpleinmtaticn.
I k w l d like to continue in the licensing of the Series 114, the Reg. wens
Principal and am requesting that the firm pay for the ticket sim3y mterial and
thecranlc~xlrse~.
I feel that my request for remmemtion was f a i r tut feel that an alternative
would be to eliminate the base salary and increase the over ride to a lwel of
3% for a t least the f i r s t year of operation. This is just a mggesticn and of
c u r s e muld have to be discussed in more detail.
I muld
sincerely m t t e d ,
Carolyn D Royer
I
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
Page 63 of 646
Page 2169 of 2953
ROCKV'
MD 20850
(301) 738.6500
j/\Y 13 E ~ J
CRD #
1092979
SSN:
184-36-7730
DATE:
1/15/87
I
The above named candidate has taken an examination administered by the NASD through the facilities of
the Control Data Corporation
Plato System. The performance of the candidate is shown below:
..
. , .
"
TEST:
GENERAL
. . . SECUR
EXAM DATE:
1/12/87
IPAL EXICMINATION
.
CORE:
SERIES:
24
845
GRADE:
PASS
The following table contains an analysis of the candidate's performance in each of the major sections
of the exa
s indicated by the percentage of questions in each
j
Percent corr
. .
BROKER DEALER #
7461
Page 64 of 646
Page 2170 of 2953
DENISE M. PROPES
Thursday December 15, 2016
10/19/2006
Gm.s. Moon
,)
CHAIRLLINoFrnEmARD
* a d w. I-h
DIRECTORS
~~~~~.~
~
k.
v*. P&n(
k t x hB=+.NYC
*. I..
oyimy.
Re:
C u U
Fo-.
ur. A
F~-u.s.
40
Mortgage Loans
Commercial and Residential
Dear Stan:
&
"
.
.
"
A
Chi,"""
An- W..'"I
C*.
rO u i r m a n norpied
C-nth
d Arrri.
Allan D. Dannatt
President
ADD/slh
Enclosure
LOAN HIFTFOLJO
aJFEimRA!iE~vrms
ma
10 yrs.
Variable
5 yrs.
7 yrs.
Fixed
Fixed
&
e
225 bp wer
03F o r 300 bp
wer 1 yr T- ill
Pay R a t e
Fee
Amortization
Stating
1-2 pts.
30 Y e a r s
1-2 pts.
1 3/4 pts.
30 Y e a r s
30 Y e a r s
@ 9%
9.5%
9.65%
o T-Bill
Retail, O f f i c e , Industrial
10 yrs.
Variable
5-7 yrs.
Fixed
Fixed
1oyrs.
300-350 bp wer
1 yr. T-Bill o r
250 bp wer 03F
1-2 pts.
30 Y e a r s
8.75%
9%
Par-1 pt.
Par-1 pt.
30 Y e a r s
30 Y e a r s
q,
open-ended
REMICS
Beginning in the 2nd W X t e r of 1987, I I A will be placing $100 million
a m n t h into real estate investment mortgage conduits. Innn&iate urdbg lcans
w i l l be made on all types of I n s t i t u t i o n a l quality property.
Fates quoted are test available and m y vary depending on location and quality
of product.
1
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
Page 66 of 646
Page 2172 of 2953
Planning Consultants
Oregon Pike Lamaster, PA 17601 717-569-1100
ROBERT E. KAUFFMAN
PRESIDENT
Payout
We would like to work with a financially sound entity and would
like to cap our payout at 90 percent on all products with a
pass-through of the ticket charge from SSC to HB Inc.
We would like it understood that no other firms be offered a
higher payout. We would further request that we receive a 2
percent overwriting on all shops we bring directly to HE Inc.
as oppossed to becoming a part of FMG. If these independent
"shops" are at less than 90 percent payout, we would like an
additional 1 percent for every 5 percent under 90 percent these
shops are being paid.
0.
Territory
It would be our understanding that we could veto any hires in
the state of PA and that we would need to approve all direct
contracts (outside FMG) in that state. It is further understood
that at any time FMG may solicit other HE Inc. shops in PA to
come under our contract/services.
c.
Stock
-
Prod in Mil
--t
7
-
o+
10%
6- 20
- 3 3 0
30
10%
10
20
30
Full Years
F M G i s to receive credit for direct volume a s well a s for volume
where a 2+percent overwriting i s generated for referring independent shops.
FMG
D.
Divorce Planning
1.
2.
3.
FMG
a.
FMG
b.
FMG
Page 68 of 646
Page 2174 of 2953
Board
of
Directors
meeting
was
on
the
held
26th
at
1755
day
of
Stanley J. Caterbone
Michael M. Hartlett
constituting a quorum of the Board.
The Meeting was called to session and minutes recorded
by Stanley J. Caterbone.
TOPICS DISCUSSED
Review.of the Business Plan
Weaknesses:
a. Specialists
b. RIA Fees
c. Improve client services
d. Organize marketing
e. Profitability
The Board of Directors should be expanded to five
(5) persons. This was agreed upon unanimously and the followi~g
persons were nominated:
a. P. Alan Loss
b. Robert Long Jr.
c. Peter Poneros
d. Richard Braverman
e. Carolyn Royer
f. Kenneth Ray
g. Scott Robertson
h. Harry Radcliffe
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
Page 69 of 646
Page 2175 of 2953
Board
of
Directors
at 4:00 p.m.
would
take
place
on
February
4,
1987
Page 70 of 646
Page 2176 of 2953
,l
As per your recent mane conversation w i t h Bob brig, I would like to give
you scane information reganiing cur lenling ability. I have been selected to
represent a group of Institutiondl Investors that are htemsb3 in projects in
the Eastern part of the acRmtry. We are able to finance projects ranging in
s i z e of $3 t o $100 million.
hrojeds include aparbe&s,
retail, office,
hdwtrial,
health care f a c i l i t i e s , mabile hare parks, hotels and mini
warehouses.
Underwriting can be very f a s t and can often times be approved in
14
days froan time of application.
follow^ is list of underwriting
r q h x m m t s ; pro forma, rent r o l l , financial statemnts, resume of borrower,
and s c a n e under
~
certain c a d i t i o n s an MAI Wraisal. For new a m s t n ~ c t i o n
a sales agreement and cost brealcdowns are r q u i r d .
a copy of our portfolio. I hope that w e on do h i n e s s
together and provide ycmr financing for your next: project, o r possibly prwide
a r e f h n c i q package f o r ycur existing portfolio.
I appreciate the
opportunity to work w i t h you.
~slclosed is
Page 71 of 646
Page 2177 of 2953
. I \
TO: BaARD OF D l X C l D E
Em.
Management
c;ruop, m.
I u n d ~ t h a t a l e t o m a n y c h a n g e s i n t h e l a s t ~(FMG)
w mybe
For that reason I would like to point ak t h a t we have invested a good deal of
mney i n the ADP system. It i s currently able t o allm u s direct order entry.
A t this time scumne needs to organize a system so that we can begin to u t i l i z e
this f e a h r e .
mst
of ycu knm that I was responsible f o r the inplementation of the BTS & DNS
us a-t
retrieval & order entry. I q l e t e d t h i s task
w i t h i n the nnnth of J m , while a t the same time obtauung my series #24
license. I would like the opportunity to amtinue in the direction of
hplemsnting the f u l l services we have a t our dispmal t h r a q h ADP.
..
system w h i c h all-
For the corporate good I feel the direction we w i l l plrsue in the area of the
Broker Dealer should be established by the E ! c a d of Directors.
sincerely Sukmitted,
EXHIBIT U.S.
16-4014
CIVIL RIGHTS CLAIM
Carolyn
D Royer
Property of Advance Media Group
Page 72 of 646
Page 2178 of 2953
Page 73 of 646
Page 2179 of 2953
Page 74 of 646
Page 2180 of 2953
Scott Rabertson
Financial Management Group
1755 Oregon P i k e
Lancaster , P A 17601
February 1 0 1987
Dear Scott :
Enclosed i s a vrrite up o n the prcxperty w e discussed.
The owner desires to refinance for a minimum of
$2,500,000 o n a non-recourse assumable basis.
It i s
understood that the enclosure is ta b e forwarded to a
private investor in Texas and is not to b e shown to
anyone else.
Leonard M. Shendell
Page 75 of 646
Page 2181 of 2953
TOPICS DISCUSSED
Mr. Peter Hibbard was present regarding a merger with
Hibbard Brown.
After four (4) months of considerations,
we are interested in persuing a relationship
a. Due Delligence: Department is growing and
they
do attempt to screen and filter only sound products.
1. Syndication 46M will help us syndicate
b. Product:
All funds will wire order minimum 5,000
c. Custodian Accounts
1. State Street, Recourses Trust, Delaware
d. Variable Annuity -Most of ours
Our Want .List:
a. Wire order materials
b. Naked options, straddles, etc.
c. Revise forms
d. No forms charges
e. Ticket charges pass through
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
Page 76 of 646
Page 2182 of 2953
Meeting
was
adjourned
Page 77 of 646
Page 2183 of 2953
by
Robert
E.
Kauffman
at
February 1 3 , 1987
Stanley 3. Caterbone
Financial Management Group
1 7 5 5 Oregon Pike
Lancaster, PA 17601
Re:
Dear Stan:
Enclosed is a Loan Request for Carter Manor Associates for the
Refinancing of two particular properties that it currently owns
and we would appreciate you consideration of this matter. Please
note that the terms in the Loan Request are negotiable.
If you have any questions, please do not hesitate to contact me.
Sincerely,
Enclosure
,>.
10/19/2006
'
Again my apologies!
Page 79 of 646
10/19/2006
M E R T L KAUrrYW
ICNLLWWLEll.CFV
E.MMVr.-
STANLEY J. C A m E
EnanhrnRrM
P. A U N U s
bmdFM*vl",n*
IRA'S, KEOGH'S
E. Investment Analysis. Implementation & Management
F. Insurance Analysis, Planning & Implementation
G. Legal Services
H. Real Estate Services
A B C D E F G H
A
..
-.."a.--
"I.*
(717) 569-4100
(800) 322.1 128
S.CurIt&s ~ r i n ~ c r k mthrough
s
FSC SIKYrll~esC ~ N ~ ~ I O ~
F~mncialManagement Group, L~,-J
A Rsgbtemd Bmkbr/Cmaler
1755 Oregon Pike
Mmnbar NASD
Member SIPC
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Page 80 of 646
Thursday December 15, 2016
Property of Advance Media Group
10/19/2006
COMMONWEALTH OF PENNSYWANIA
ROBERT P. CASEY
ROBERT M. LAM
ch.innan
Governor
FREDERICK H. PUNK
Commissioner
NANCY L. DIANA
secrasry
EUOTT KLElN
Chid Car-
S t a d e y J. Giterhme, President
F M G Advisory, Inc.
1755 OrPike
Lancaster, PA 17601
IWESBENT AWISER APPLICANT:
Lancaster, PA 17601
Dear M r . Caterme:
This w i l l ackno#ledge receipt of yam subnission on February 20, 1987. In this
respect, before further consideration can be givm, it w i l l be necessary to provide
the follauiq:
)
h
&
2.
3.
W i t h reference
4.
"\
1109 STATE
OFFICE
BUILDING,
191304088;
Telephone
EXHIBIT U.S. 16-4014 CIVIL RIGHTS
CLAIM
Page
81 of 646PHILADELPHIA. PA
Thursday
December
15, 215-56C-205
2016
OFFICES
806 STATE OFFICEPage
BUILDING.
PITTSBURGH. PA 15222-1210; Telephone 412-565-5003
Property of Advance Media Group
2187 of 2953
10/19/2006
F M G Pdvisory, Inc.
February 24, 1987
pase 2
5.
%ference i s made to question 12, Pbrm AW-Rut 11. In this respect, the
follcuirq i s requested:
a.
. .-,
b.
With reference to yw affirmative r e s p n s b ~ & e s t i m12.B.. Fonn AWPart 11, it is noted that Medule F states, "Clients are under m
obligation to plrchase or s e l l seclurities thrmgh FSC Securities mrp.,
Mw,
i f FSC Securities Corporation executes any transactions, fees
already paid to the applicant." Inasnu& as t h i s statement does not appear
to be q l e t e , amnd Schedule F in order to provide ccrrplete disclosure as
to what m y happen to "fees already paid to the applicant".
C
on Schedule F.
a.
b.
c.
d.
Page 82 of 646
Page 2188 of 2953
F M G Advisory, Inc.
February 24, 1987
page 3
b.
c.
NOE: Men a m d i n g Form A W , cmplete all mded pages i n full ard circle the
mnker of t h e i t e m being amended. Each amedmentmst include an emcution
page w i t h an original m a l s i g n a h r e and Mtarization.
Paul M. S d u a r t ~ ,A
Division of Licensing
Director
(3ERTIFIED MAIL
m
r
w RECEIPT R m I E S l m
Page 83 of 646
Page 2189 of 2953
Carolina.
?%h'
Page 84 of 646
Page 2190 of 2953
OWEN KUGEL
39 NORTH MARKET STREET
LANCASTER PA 17603
717-299-4371
2 M a r c h 1987
To:
S t a n l e y J. Caterbone
President
FMG A d v i s o r y , I n c .
E d e n P a r k II
1755 O r e g o n P i k e
Lancaster, - PA 17601
717-569-41 00
From :
Owen K u g e l
Subject:
M o r t g a g e Financing.
I h a v e selected a g r o u p o f 11 p r o j e c t s f o r w h i c h we h a v e completed
pre-development w o r k a n d w h i c h a r e r e a d y f o r d e b t placement;
a n d a t t a c h e d t h e c u r r e n t financial p r o j e c t i o n s o n each.
1 h a v e assumed a 65/35 D e b t l E q u i t y s p l i t , a 9.00% r a t e o f
interest, a 30 y e a r term, a n d a o n e p o i n t o r i g i n a t i o n fee. Note
t h a t t h e L o a n t v a l u e u s i n g a 9 " s a p R a t e averages 56.54%.
Note also t h a t 1 h a v e i n c l u d e d a 2.50% D e b t Placement Fee f o r
y o u r e f f o r t s in p l a c i n g t h i s debt; w h i c h w o u l d t o t a l $433,592
f o r t h e package.
L e t me k n o w if t h e r e i s i n t e r e s t and, if so, what a d d i t i o n a l
information y o u w i l l need.
Regards,
msrlattachments
Page 85 of 646
Page 2191 of 2953
'
'
.
.
I--
In
u-
n DrDw
newsletter
MARCH 24,1987
Page 86 of 646
Page 2192 of 2953
6 Month
1 Year
2 Year
3 Year
4 Year
5 Year
7 Year
10 Year
4/l/97
Yeild 7.90%
l&u~C. T. -,
ex-divisional m g e r of ID6/AM E 'lamjest office,
has joined F K . Tan w i l l be developing an office in MN/St. Paul as
well as d t i n g nationdlly for m.
Barry Schuttler and Bob Kauffman are intexviewhg and p r e p r j n g to
bagin an -type
office in l?X@s% area. W e plan to raise mney
in the same manner as in PA and use the same basi~marketing~lan.
Thmas Asselin of
with me
Tcan mrked
Page 87 of 646
Page 2193 of 2953
The Board
of
Directors
m e e t i n g was
Pike,
Lancaster,
Pennsylvania
on
the
1987.
The M e e t i n g was h e l d a t 1 1 : 2 5 a . m .
held a t
26th
day
1755 Oregon
of
March,
PRESENT :
R o b e r t Kauffman
R o b e r t Long
P.
A l a n Loss
Michael H a r t l e t t
Stanley Caterbone
c o n s t i t u t i n g a quorum o f t h e B o a r d .
TOPICS DISCUSSED
H i b b a r d Brown P r o p o s a l
A.
Agreement now s a t i s f a c t o r y
1.
20% o f H i b b a r d Brown
2.
Loan:
3.
E x c l u s i v e t o s t a t e o f PA
4.
A l l o v e r r i d e s a r e u n d e r FMG
5.
Stock
1 8 Months f o r $ 2 5 , 0 0 0
o f FMG t h a t g o d i r e c t .
Board o f D i r e c t o r s M e e t i n g s
A.
Have a m e e t i n g e v e r y f o u r t h week
B.
F o l l o w i n g Dates:
April
16,
1987
8:00
a.m.
at
the
office
of
Jeff
Jamouneau, o u r C o r p o r a t e A t t o r n e y .
1.
Purpose
May 5 , 1987
to
d i s c u s s r e s t r u c t u r e of
8:00 a . m .
J u n e 2 , 1 9 8 7 8 : 0 0 a.m.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
Page 88 of 646
Page 2194 of 2953
orgar~izatiorl
a.m.
a t Dempsey's
t o 10:OO a.m.
a t Dempsey's
t o 1O:OO
C.
Agree t o b r i n g
Satellites
J e r r y Bavero
to
Board
Keetings:
Richard Podlasek
Tom T u c k e r
R i c h a r d Volpe
Page 89 of 646
Page 2195 of 2953
FlNANClAL SERVICE
CORPORATION
ATLANTA CENTER
250 PIEDMONT AVENUE N.E.. SUITE 2100
ATLANTA. GEORGIA 30365
I100 521-6500
K 3 i N 8. KEEBLE
PREYCXNT
Your recent letter stating that you propose to attempt to transfer the
licenses of some of our representatives to Bibbard Brown, Inc.. possibly as
soon as April 1, 1987. prompts me to vrite this letter to you. on a very
urgent basis.
During the period from early 1985 until January 31. 1987. you vere an officer
of FSC Securities. Up until October 1986 you vere Senior Vice President of
Financial Service Corporation. For this entire period you vere paid a
substantial salary and expenses. Also during this period you vere a
registered representative, the last four months serving as an MFA in Lancaster
(vhile being paid as an officer of FSC Securities Corporation). This dual
relationship called for an unusual amount of trust in you on the part of FSC,
as our letter agreement of October 7. 1986, stated.
Your contractual and fiduciary obligations to us in these capacities include
the following:
1.
You oved and owe FSC and FSC Securities Corporation a strong duty of
fidelity vhich vould prohibit your solicitation or enticement of
their employees and representatives to become employees or
representatives of some other brokerldealer or employer in
competition with FSC.
2.
I I;iI
Page 90 of 646
Page 2196
I of 2953
\
3.
Yours sincerely,
/ ~ o h n B. Keeble
Page 91 of 646
Page 2197 of 2953
FINANCIAL SERVICE
CORPORATION
ATLANTA CENTER
2 5 0 P I E D M O N T A V E N U E N . E . SUITE 2 1 0 0
ATLANTA. GEORGIA 3 0 3 6 5
I4Wl 5 2 1 - 6 5 0 0
To Associates of t h e L a n c a s t e r MFA
We have become aware d u r i n g t h e p a s t s e v e r a l weeks t h a t Bob Kauffman has
determined t o s e v e r h i s r e l a t i o n s h i p w i t h PSC, and t h a t he has been t a l k i n g
w i t h a number of our r e p r e s e n t a t i v e s about j o i n i n g him w i t h a n o t h e r
b r o k e r l d e a l e r . We a r e w r i t i n g you i n t h e hope of avoiding any
misunderstanding between you and t h e Company, which may work t o t h e
disadvantage of both of u s .
I
John B. Keeble
Stephen G. F r a n k l i n
Page 92 of 646
Page 2198 of 2953
Donald S. Aultman
JOHN M. C I C A L A SR.
DEVELOPER
SEAPORT V I L L A G E h a s b e e n d e s i g n e d a s a u n i q u e a n d p i c t u r e s q u e
shopping complex s i t u a t e d a t 22nd S t r e e t i n North Wildwood.
The
complex i s now under c o n s t r u c t i o n on a r e b u i l t , widened p i e r
t h a t w i l l e x t e n d 500 f e e t o u t from t h e boardwalk t o w a d s t h e
ocean. The development, s c h e d u l e d f o r c o m p l e t i o n i n t i m e f o r t h e
s t a r t o f t h e S p r i n g , 1987 season, w i l l f e a t u r e a t o t a l of f o r t y
s p e c i a l t y and f o o d s h o p s . T h e s e s p a c e s a r e now a v a i l a b l e f o r
a n n u a l r e n t a l , a t p r e - c o n s t r u c t i o n p r i c e s r a n g i n g f r o m $30 t o $ 3 6
p e r s q u a r e f o o t . Types of b u s i n e s s e s i n c l u d e d w i l l b e c a r e f u l l y
chosen t o i n s u r e s u c c e s s f o r a l l .
A p e r f o r m a n c e a r e a w i l l be b u i l t a t t h e end o f t h e p i e r . T h i s
a r e a , t o i n c l u d e l i v e t e l e v i s i o n and r a d i o f a c i l i t i e s , w i l l s e r v e
a s t h e s i t e f o r ' p o p u l a r e n t e r t a i n m e n t and o t h e r e v e n t s d e s i g n e d
t o a t t r a c t l a r g e numbers of p e o p l e t h r o u g h o u t t h e s e a s o n as well
a s continued media coverage. Restrooms and o t h e r p u b l i c
a m e n i t i e s w i l l a l s o be included t o help i n c r e a s e f o o t t r a f f i c . A
large
s t a i r w a y w i l l permit beach access.
An e x c i t i n g
a d v e r t i s i n g and p r o m o t i o n campaign i s p l a n n e d t o c a l l a t t e n t i o n
t o SEAPORT VILLAGE.
Our r e p r e s e n t a t i v e , E l l e n Libman, w i l l b e i n y o u r a r e a i n t h e
n e x t two weeks.
S h e w i l l c a l l on y o u t o p r o v i d e you w i t h
a d d i t i o n a l i n f o r m a t i o n . Of c o u r s e p l e a s e f e e l f r e e t o c o n t a c t me
a t anytime.
Page 93
S iofn c646
erely,
Page 2199 of 2953
li
Planning Consultants
Omgon Pike &nuster, M 17601 717-569-4100
ROBERT E. KAUFFMAN
PRESIDENT
FSC Seaxities
250 Piedim& A v e . , N.E.
A t l a n t a , Georgia 30365
Dear John:
ycxl for your letter of March 26,
1987.
It was very
enlighening.
I, of canse, have n, interest in getting into any
legal acticm w i t h anyone, partiaIlarly hhere both parties would be
hurt and only the legal repxesentatives wculd make m y . I knaw
that yau are not easily drawn into litigation and see no need for it.
Thank
I am not irRerested in d t j n g o r p r r s u i n g o t h e r ~ ~ c ~ ~ ~
when I a f f i l i a t s w i t h another b-er.
2.
3.
a t FSC.
While ycu need same relief fnm the possibilities of solicitation by
me
your ather MFA1s, I need to be treated as others wfio have left
I app-te
your willingness to have Don Aultmn
upon my
-.
R.E. Kauffman
Page 94 of 646
Planning Consultants
Omgon Pike &nuster, M 17601 717-569-4100
ROBERT E. KAUFFMAN
PRESIDENT
FSC Seaxities
250 Piedim& A v e . , N.E.
A t l a n t a , Georgia 30365
Dear John:
ycxl for your letter of March 26,
1987.
It was very
enlighening.
I, of canse, have n, interest in getting into any
legal acticm w i t h anyone, partiaIlarly hhere both parties would be
hurt and only the legal repxesentatives wculd make m y . I knaw
that yau are not easily drawn into litigation and see no need for it.
Thank
I am not irRerested in d t j n g o r p r r s u i n g o t h e r ~ ~ c ~ ~ ~
when I a f f i l i a t s w i t h another b-er.
2.
3.
a t FSC.
While ycu need same relief fnm the possibilities of solicitation by
me
your ather MFA1s, I need to be treated as others wfio have left
I app-te
your willingness to have Don Aultmn
upon my
-.
R.E. Kauffman
Page 95 of 646
For
,nfL
BOX 4665
LANCASTER. PENNSYLVANIA
17604
17171 397-6174
April 9, 1987
Harry arranged a meeting with Mr. Robert Long, another member of your firm.
After discussing the proposed plan for growth of the corporation and utilization of various assets with Mr. Long and Mr. Radcliffe, we were pleased with
the "team' concept.
This finally has lead to the matter at hand. I wanted Bob Long to prepare my
personal income tax returns for the year 1986. All the information was
compiled and in his hands in February 1987. To date, the work is not completed.
Harry has, on several occasions, asked the status of my returns, and I have
called to be told "it is on the list to be completed."
If
my
is
on
this is the type service the corporation would receive, I am not bettering
position. Therefore, I am of the opinion Financial Planning Consultants
not the proper group to retain for either a personal of corporate adviser
financial matters.
I regret this decision due to the find working relationship with Mr. Harry
Radcliffe. However, your financial group is not delivering your entire product,
service. Should you wish to discuss the situation, please feel free to call.
Page 96 of 646
Page 2202 of 2953
For
,nfL
BOX 4665
LANCASTER. PENNSYLVANIA
17604
17171 397-6174
April 9, 1987
Harry arranged a meeting with Mr. Robert Long, another member of your firm.
After discussing the proposed plan for growth of the corporation and utilization of various assets with Mr. Long and Mr. Radcliffe, we were pleased with
the "team' concept.
This finally has lead to the matter at hand. I wanted Bob Long to prepare my
personal income tax returns for the year 1986. All the information was
compiled and in his hands in February 1987. To date, the work is not completed.
Harry has, on several occasions, asked the status of my returns, and I have
called to be told "it is on the list to be completed."
If
my
is
on
this is the type service the corporation would receive, I am not bettering
position. Therefore, I am of the opinion Financial Planning Consultants
not the proper group to retain for either a personal of corporate adviser
financial matters.
I regret this decision due to the find working relationship with Mr. Harry
Radcliffe. However, your financial group is not delivering your entire product,
service. Should you wish to discuss the situation, please feel free to call.
Page 97 of 646
Page 2203 of 2953
TO:
Bavero
Schuttler
Volpe
a. budget review
b. goal achievmt analysis
2. A discussion of Profit Participation Plan in the form of
4.
R.E. Xauf?imn
a: s. Qterbone
M. Hartlett
R. Long
A. Loss
Page 98 of 646
Page 2204 of 2953
Advisory
11, 1755 Oregon Pr*e
TO:
FROM :
DATE:
Lancaster, PA 17601
717-569-4100
Representatives
Stanley Caterbone
April 21, 1987
FMG
Page 99 of 646
Page 2205 of 2953
newsletter
A P R I L
14,
1 9 8 7
Insmame Manual
m t l y begun t o prt together the contents f o r our Innuance Sezvioes
'Ihe purpose is to have the necessary information to help all -T~S
becoane familiar w i t h the procedures f o r all of our primary insurance carriers.
I t w i l l be an easy reference guide to:
1) Underwriting t
s
2) P r d u c t s & Carriers
3) Processing Procedures
4) Contact Persons
5) Ccanpensation
My gcal is to have this in your hands w i t h i n 30-45 days. This w i l l help a l l of
us w r i t e mre b s u r a x e w i t h less effort. -Stan Qtm%cm
W e have
Manual.
P l a n n h Demrtmnt
the f i r s t week of operation
f o r $1500.00 from Scott Robertson
anyone would like same ideas on
happy to share saane of t h e i r ideas.
After
Retirement Plan
For a l l persons awaiting cxn Retirement Plan, I m y have hit the ja-!
I am
s t a r t i n g to negotiate ard recruit the
thathas developed the retirement
plan f o r a MAJOR brokerage house. mis plan is regarded as one of the best in
the irdustry. L e t s keep our fingers crossed. --Stan Qtexkone
-
taking this project into Financial Senrice Center w i t h FM; as a canpany sponsor
and tenant.
W e w i l l be lcoking to &t
planners and brokers f o r that area.
Anyone w i t h contacts should contact myself o r Bab Kauffman. Your help is
greatly appreciated.
-Stan Caterbone
--
Marketins Seminars
Anyone who is plarvling Seminars f o r t h e i r marketing plan please contact Alan
Loss. Seminars t h a t are available:
1) Half-Time Seminar
2) Successful Money MaMgement Seminar
3) Product Sponsored Seminar
Meetins
Board of Directors
?his week vour board of directors w i l l be d i s a ~ ~ ~ iwith
n g the m p r a t e
attorney thec o r e form for us to:
1) Fersue wntxacts w i t h represa-katives autside of PA.
2) Provide an Equity Participation prcqram f o r F?n%cers.
e -type
capital raising for other locations with& violating
3) m
certain security laws.
It remains an exciting time, as this new business begins to take form. So marry
apportunities, so mch to do, so mch to get organized and developed. Is it
fun! -Bob X a u f m
t -
Assets
nclw
The Board
of
the
P. Alan
Stanley
Michael
I
Jeffrey
constituting a quorum of
Loss
J. Caterbone
Hartlett
Jamouneau, Esq.
the Board.
TOPICS DISCUSSED
Corporate Structure for National Expansion
Because of the growth potential on a national
level, we needed to research the alternatives
to
our
present
organizational structure that
would allow additional equity participation from
other large groups, ie. Barry Schuttler
Tom Turner
Form FMG National, Inc.
This entity would own
100% of Hubbard/Brown Stock.
FMG, Ltd. would
retain 100% ownership of FMG National, Inc.
The above would be conducive for equity
and
also
foz
marketing
participation
the concept.
'
The
for shareholder
A 5:l
Stock Split
~ e % f r eJamouneau
y
advised on subjects of the R.I.A.
%
a.m.
Stan Caterbone
1755 Oregon Pike
Lancaster, PA 17601
Dear Stan,
Enclosed is a contract, and supporting documents for the purchase of Useppa
Village Unit #lo-Left. Please sign all the documents where indicated and
return all three (3) documents to me together with a check in the amount of
$100.00made payable to the Useppa Property Company Escrow Account.
If you should have any questions, I can be reached at the Club, (813) 2831061.
\
Sincerely yours,
Sales Associate
JRKIjnj
Enclosures
May 2, 1987
I
I ' m afraid that as w e go further and further there w i l l be a need for such
information especially w i t h what has h a m this past week w i t h our corporate
officers and board. F i r s t I would l i k e to begin back in ti-&very beginning so
that the f u l l scope of our activities seem to f i t into ane place and also so
that
of the issues that have mme up are tied into what has happmd up to
this point.
After being involved in the business I decided that firrancial planning should
be wre abjective and fee based, so I became one of the larger fee producers
using fees as w e l l as mmnisSion incane. A t about the same time, I became
involved i n the IntermtiAssociation of Financial Planners. A t that time
the local chapter was just being fonwd and I volunmy services to help
on the board.
Menbrs of the board, a t that time, was just being formed and
headed by John Herr.
I became m t i v e vice president and virtually helped
run the chapter and
build it to its largest m
p
. lhat gave m e
as f a r
the apportunity t o meet other people, broaden my horizons and *tian
as the financial planning h3ustry and just haw the hleperdent planners f i t
into the stream of the industry. I had quite a b i t of activity and did alot
for the local chapter and became very involved.
helm
mer the next several years I made a very gwd living. I was never a very big
pmducer, althmgh one of the bigger ones in the Harri.skurg division. But I
was not the biggest, but the premier fee producer for the division and was om
of the leading in the camtry a t that time. I shortly became kmmledgable of
the other pmfucts available in the financial services industry and learned
very quickly that it w a s virtually inpossible to have one canpany manufacture
and produce ccpnpetitive products across the line. A t this the I was setting
l
e Amstrong
up a dhmr meeting for the IFP that was going to sbax2ase A
who was one of the premier planners i n the cumtry. She was very visible and
very widely m. I set up a dinner meeting for her khich attracted close of
om hundred
p r o f e s s i o n a l s a n d o t h e r p e o p l e t o a ~ . l h i s w a s f o u r o r five
times larger that any ather meetirg the chapter had ever had. A f t e r the
meeting I was involved in a -ion
w i t h Alex regarding the financial
planning h l d z y and my aspirations of what was cutside of a pmpriety
envimmnmt.
I told her that I was thinking of lMking a m e and asked her i f
she had any suggestions of wha to q e a k to. A t this point in time, we were all
i n Butler Avenue and Bob Kaufhan was in Georgia, running a division of ID6
back there.
He, a t this time, had become one of the l a q e s t divisional
n g e r s and had shwn very high pm&active
recruith-q skills. He was running
one the largest shop= intheScuthEastandwasbexdtqveryprofitable for
II1S. Alex suggested that I c a l l a gentlwen by the name of John &&le who was
then president of Financial Services COT. a bmkerjdealer based in A t l a n t a ,
Georgia. A t this the Bob Kauffman was probably, as unfamiliar i f not mre
unfamiliar, of the irdependent e n v k m e n t available to the Fimrcial Services
Industry. Specifically Financial Planners.
I phaned Bob a n d t o l d h i m t h a t I w a s ~ i n g t o l o a l c a n d ~ ~ t e l s e w a s l ~ o u t
there."
Before this time, a ccuple months prior, I atb&& a career
conference in Florida with IRS. A t one p i n t I was in a roam w i t h Bob Ihufhan
and R
' mt TUmr, who was the biggest divisicmal l ~ ~ g aet this
r
time with ID6.
I began to disc;uss my dissatisfaction with the ccmparry and the way that they
op=rate and I suggested to them that it pmbably would not be too difficult to
duplicate an organization instead of bebg built araYd a proprietary that was
built solely amund a non-proprietary product. A t the time they both leaked a t
w and I don% m m a k e r i f they l a w , k u t the idea really didn't redlly
interest them, and it just rolled off their shailders. Right after this
meeting is whenIhadthedinnermeetingvithAlexandIsetupthemeetingin
A s I usually did, I always leaked a t Bob Kaufhan as my mentor. H e
virtually w w o f f t h e s t r e e t s a n d m m e a w a y t o w m y i n a w a y
that I never
I a u l d w. I always respected Bob as a very good
sal.esnan, seeming to have a very high financial intellect and I looked up to
him as he taught me alot. So I got on the phone and told him I was going to
v i s i t an imkpn%& planner i n Atlanta.
A t this time, Bob was bemning
dissatisfied with the management of ID6 and was not very happy with the way
they were using him to build areas. Vihen the areas would become profitable to
him they waild mehimtoanotherdistressedamatobebuiltup. Sohewas
doing a l l the work and ID6 was making a l l the mmey because they waild plt i n a
m a ~ g e rfor less money and so on and so forth.
Atlanta.
Bob then told rn that he may be willing to go intD the meeting w i t h me under
the asslrmption that I did not tell them who he was o r who he was w i t h . I
called J&n m l e and told him I wanted to cane dawn and v i s i t him, being
referred by Alex and he was very nice mer the @mne, giving me a cordial
invitation to cane down and actually had me set up the meeting w i t h Ray S m i t h
who was one of the sales ~ g e r s .I set up a two day meeting w i t h myself and
this anonymxls person, Bab KaufBnm.
W e spent two daysatFSCandwhat
essentially happened is that they became infatuated w i t h Bob's recruiting
skills.
On the spat they offered Bcb a position within the a m p n y as far as
recruiting and head of sales manqement of FSC.
I resigned fm m6 January 1985.
Bob m i n d a t ID6 and fnm Octaber to
March w a s negatiating his position and pay and his -tion
w i t h FSC. By
March he actually decided to resign fmn ID6 and he was a k a r h d into the
corporate structure of FSC. January Ist I resigned fmm IS. I was Upstairs
w i t h Mike Harllett, sharing an office space and the rest of district w i t h Alan
Lms was still dwEbks.
A t this time, I began to build my independent
practice of Financial Planning. Basically I took 95% of my clients fmm IC6
and began working w i t h them. Bob began working i n the national recruiting for
FSC and started attracting IDS people to FSC.
the
Fall of
m,
attractive market w i t h alot of wealth being spread cut amDng alot of different
No one was being creative
r " lg their efforts it was just three
players.
o r four brokerage houses, insurance agents, banks and irdependent planners but
iw one had a very strcarg p i t i o n or d a b a x e in the financiae services
-.
I visited w i t h Bcb Kauffman in the Fall of 1985 as I usually did every ccuple
mths ard told him I wished to do scwthing else. A t t h a t time he asked me i f
I wanted t o cane dam to Atlanta and help him work on the concept of o n p n y
awned shops.
W h a I was dawn there, he mmtioned severdl positions i n the
corpration that I may be ini n and he set up a meeting w i t h me and
Steve Franklin.
Stwe m t l y needed smmw to m a ~ g eh i s national sales
office so khj dawn there I spoke to him, just t o verify w h a t was available.
A t this meeting, Steve Fmnklin more of less indicated t h a t I was a ~~kuned
cut
who was just leaking for a place to go. Ncrthing ever happen& and I
left the meeting w i t h very l i t t l e respect for Steve Franklin.
Bob offered me a position w i t h i n his mnpany owned store, writing cases doing
p l m , doingsaneotherthings. CIhatwasearlyOctober. F o r t h e n e x t t h r e e o r
four weeks I prepared myself, relwtmtly, for the transition and moved to
Atlanta and tried to maintain clients up he^^ as well, and plrsue whatever Bob
was doing down in Atlanta. A s th went on I f e l t I really didn't wish to move
away fmn the area and that maybe the opportunity down there wasn't what I
thought it was, o r wasn'twhat Bab said it was.
On Nw&
27 or 28 of 1985, I had a meeting w i t h Bob I c a u f m and Mike
Hartlett a t 1 4 x b n r s m u n t on the Rahrerstawn M,
Ianaster, PA. 'me
pupose of the meeting was to find art i f we a u l d collectively p r t together
xmething in Iancaster w i t h regards to f h i a l planning. I wwld say that
e t i n g was mre of an effort on my part than anyone especially Mike Hartlett.
Mike was, a t this time, also inrlependent, l e f t ID6 anl follckied me to FSC along
w i t h Bob.
?he meetingwas on themorning a t 9:00 a.m. and we dkmxxxdwhat
options we had as far as w i n g sanething tcgether in Iancaster. I guess the
bsic reason for the meeting was to see i f Mike Hartlett wished to do sanething
together w i t h us. A t this time I was qmating my practice, Mike was aperating
his practice, anl the only
we had in amumn w a s a reception man
adjoining ax offices.
A t thistimeBobsawthatifwecculdputsawthbg
together in Lancaster he omld pmbably f u l f i l l same of his recruiting
-ts,
giving h i m a place to actually xecmit people to rather than
using FSC in Atlanta. So that began the process of w i n g together a shop in
I b e s a n t o recruit fran that point forward into our so called plarvling firm.
A t this time the plarvling firm was going to be caprised of financial
Sane of the f i r s t pecplethatItall#dtowasMonaRishel,Dick
and Bab Lnrg. I spoke to other plannezs-about joining our firm and
then I got the idea of adding other professionals mainly legal, a m - ,
& estate and ma@ insurance. It was then that I got the idea for the one
stop financial firm.
Tbmeitseemedapprmt-thatitwasimportanttohave
a l l the individuals working tagether collectively
manage one financial
planners.
-,
'
'affairs.
It didn't seem that d i f f i d t to accaylish that i f yau had the riqht
irdividuals willing to take the risk of a t t m p t h q such a project sod who had
the clientele where they didn't have to rely on attracting new clientele.
Well, ~ t h i n g l e d t o a M t h e r a n d w e s o o n b e g a n t o r e n U i t ~ a t ~ ~ a n d
sizable grcup of individuals. I prcbably was responsible for d t i n g 90% of
the local people and artside pecple, Mike was mrking with Rick Volp in
F h i l a d e l m who he w o w w i t h a t ID6, and a hcst of others. T h e i n i t i a l core
was myself, Mike, Mma, Dick Sherisahn.
A t thistimeIranintoSattRobertsonattheZhreeMilelhsewhowasworking
with Asset Mamgement.
I expressed the idea to him and he became interested
and became one of wr pecple. I also talked to Gmmlyn Royer who was w i t h Pru
Bache and she was interested in joinhg. By February we had a fairly large
group of people who were willing to ammit. F i r s t thing we had to do was find
facilities and Mike f d the place available a t the OregcPl Pike location which
was just urder -on.
A t f i r s t we were looking for 2,000 square feet to
hcuse f w or five i n a i v i d ~ ~ LA~t. this time I talked to Tim Lanza, people a t
the legdl firm, and Danny Beqer as f a r as doing me thing with real
estate.
It was s q p x e 3 to beanaperationfinancedandsqportedbyFSC.
horn December until May FSC was pranking furd to f h m c e the aperation. We
nedd start up funks for fur nit^^?=, caymter systems, salaries for myself and
Mike for ranaging the -tion.
Mat happerred &ing this t h was that FSC
was constantly premising us financing and we had yet to receive any actual
m ~ n e yand the invoices d t t e d w e r e never paid by FSC.
Bob ~ ~ a u f f u n n
was the liaison and -tly
was being directed by Stare
Franklin ard Jdyl m l e . F'ran what I have learned over the past several years
was that they never really interded to finance the aperation brt they were
strirqirq us along ard using us to recruit other people to the operation.
After we rexuited ten o r more people it became apparent t h a t Mike o r myself
g e an operation. We also
did not have the managing skills required to l ~ ~ such
learned we l o s t our financial backing, so we had to figure out what to do with
A t this time we decided to raise the capital a.u-selves,
finance the
financing.
And
operation auselves with quity we raised thmqb the planners.
essentially we learned that no one i n the industry, or very few actually awn
their awn business but are only a distrikrtion for a f i n a d a l product. W e a l l
have seen bmkr/dealers b e b g b a q h t and sold for very sizable m t s of
m y , usually in the vacinity of $1 of quity for $1 of gross ccrmnission
inmne.
We began to see t h a t we were seeing anyi&em hran $1 million of gross
amnksion imxms per year w i t h the grcrup that we had. In the grarp was Ken
Ray and some very m t i v e and talented people.
cur m e e t h p and discussiuns d c h w e r e very long, durable and
mpn L&omber t o May I probably spent every other evening with Bob
tiresame.
i n Atlanta trying to pt this deal together.
Tbx@mt
L e t me go over a couple of other things that had happened up to that time that
I f d ljke mentianed in this document, before I fozget. Back in the sunmer of
u
s
e of
1985, I was contacted by Jdyl Fhilips fmn Blue Pall National Bank. m
)ny v i s i b i l i t y w i t h the local chapter of the IFP J d m wanted to call me and look
a t the o p t i c u s of Blue Bas11 National Bank becane involved in Financial
Planning.
Jchn called a meeting w i t h me ah3 I believe he was looking for
scanmne to head a Financial deparbnent with inside Blue Pall National Bank o r
contract w i t h s ~ n e o n e outside. I had 1-1/2 bar with J d m and his suborbant,
whcan I can't remember his name, I believe it was Joe. H e was the vice
president of the trust m t , I believe. m
y a f t e r the meeting they
did not have the fiath o r the confidence that I was the right person or they
didn't believe t h a t this was really what they wanted to do. But I have never
M firm them s i n .
-.
was going to receive 60,000 shares, I was to receive 40,000 shares andMike
was to receive 40,000. Also, Mike ard I w e r e to receive $3,000 per month and
Bob $5,000 per mnth. Bab and I had a deal as I did not believe he shaild have
more of the canparry than I because I pit it together. We had an agreement
&ereby
I could buy 10,000 shares of his 20,000 a t anytime a t cost so we would
both have 50,000 shares. I had papers drawn u p t o that, however, whenwe began
t o have problens, I l e f t things drop by the wayside.
think it was back a t this time-we r e a l i z e d that Bob was probably going to
fran management and cannit and cane up to Lancaster. I think one of the
reasons whyMaryLynn andIbecameveryclosewasthatsheremindedmesonuch
of my mother i n t&
way that she handled her kids, family and I became
infatuated w i t h that.
I liked her alot. Wt haFpened was that Mike and Bob
resented the fact that we had so rmch fun while we worked. We got m r k done,
but we went out t o lunch for an hour or so and we really enjayed things. To
I
resign
'
them that had no place in business. For me, as 1as I got my work done, I
f e l t better about my work ard it worked art for the best. mis w a s a problem
an3 w i l l ccmne up later.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
section,
most of
~~
W i n g %pteubr we began to have pmblems w i t h Mazy Lynn and the staff and
me.
'Ihis was the beginning of them hying to reduoe and dilute my control of
the canpany as f a r as input was cancerned.
It was a very emotional and
d
r
a
m expsriexe a f t e r a l l t h e w o r k I d i d t o p l t t h i s a l l t o g e t h e r t o f i n d
those twowere trying to plsh me cut. Itrsachedthepointinoctoberor
Noventer where they actually asked me i f I wanted to "get out." 'Ihqr indicated
that I was not right for m a ~ g & ,
m a ~ g e m e n twas nat right for me, t h a t I
wasn't having fun and all this and that. Mnst of t h a t was due to their action
as f a r as their trying to dilute me and weaken my umfidenz. lhey c0Ntantly
made fun of me i n f m n t of all the other planners a t meetings and it was just
ugly.
'Ihey also t r i e d to internqj my relationship w i t h Mary LyM w h i c h was
ruthirq mxe than a very p e r s a d , deep fri-p.
No care lamws this, kR the trauma was so heavy that I went mxier the care of a
Hospital, beginning N m m h e r and I was suffering a
psychologist a t St. J@
severe case of depression. Eecause of d z @ r e n i a being f a v d in my family,
I was not afraid to go seek psydmlogical camseling. I was on medication for
three months.
In September they had it in their minds that they were going to get r i d of Mary
Lynn.
And they tried every opporbmity, finally in N o v e n h r a week before
Thanksgiving, they fired Mary LyM. W i t h o u t cause, for no reason, other than
they just wanted her art ard felt she was incapable of whatever. It actually
reached the point wfiere Bob andMikewhenarnurr].politickingthebrokersto
s q p r t them t h a t M a r y L y M w a s n u t d o i n g h e r j o b w h i c 3 1 w a s m t t r u e . Shehad
the canplete w
r
t of a l l the brokers. Maybe a t times there was a case wfwe
sawom was unhappy w i t h her perfommce, but in general it was a ploy, a plot,
fabricated by Mike and Bcb.
their attarpt to lmy me out and get rid of me so far as my Oontrol and my
interest, I held cut reluctantly often times mxlering i f I were going to give
in an3 by 0lristma.s I decided I wnuld stick it cut. 'Ihere
not other
alternatives, kR the nwney they offered me to get out was $2,50 a share which
canes out to $100,0000.
Iwantednopartsof it, s o b y J a n u a r y I d e c i d e d t o
stay.
After
Bob h a d s e v e r a l c a n v e r ~ a t i ~ ~ l ~ w i t h B o b I c n g s a y i n g t h a t h e w a s ~ i e d a b o u t m y
v
i
a
l efforts and that I was heocming slack. Ihe whole reason was
that they were hamering me daJnandbeatingmeupineverywaytheycculd,
cktmying my confidence. AftarIspenttimeandeffortardIbelieved inso
nu& of Wmt I'd done, and they were trying to take this away franme and get
me art of the picture.
Thraqh N o v and
~
Decc&er
there were meetings between myself, Scott
R c h r k x m , Alan Loss, Bob Long and (luo1ynFlayer rqanibq the activities and
the ~ S t y l e s o f M i k e a n d B o b . ~ w e r e v e r y ~ , w e r e n o t v e r y
trusting and I was always in the middle between the managerwt and financial
planners.
I had relatiMships with everyone and I believe that this -tend
Bob and Mike ard they tried t o g e t m e c u t o f thepicture, kttheplanners
wxlld not allcu this because the planners did not trust Bob and Mike w i t b a r t
havingme to keep them on balance.
I raised most of
memo-
W - m I w a s p l t t i n g a l l t h i s t o g ~ , I w a s i n ~ w i t h A l n Y u l a tItalked
.
abaR having nnr@age,
banking a part of a t I was doing. Nathing ever
happened bebeen the two of us, but in ~anuaryI received a call fran Al askhq
me to see i f I a d d place any mrtgages in the east coast. H e was willing to
pay me xmghly one half a point and this was a t a time, because of the
activities of Bob and Mike, that I tku$~tI would give this a t r y to give me
sane secwity. Should saoething f a i l i n the canpany, I would have sanething to
f a l l back an. A t this time I involved Scott IInbertscn and Bob ~cngand I told
them we would form a three way w
p and we wnuld work an a real estate
project on cur awn. ' I h e r e a s o n I t o l d n o o n e a b c u t t h i s w a s t h a t t h i s w a s m y
ace card in case Bob and Mike ever really threw n~ out. I was mt going to give
&em any r e l a t i m s h i p , and I j u s t TIE&&
sane d t y .
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
we were really doing was lwkirg for 1of 2 millicm dollars and up to
refinance or finance new and existing realestateprojects. Wemadeafew
calls, finding that ax rates are very anpetitive.
A l was mre of less
letting me get plqged into the major Savings and Loans and Inswaxe
mnpanies.
Wefam3cuttherewereveryfewpeopleinthearea, i f a n y a t a l l
who could a q u b s the terms. We began having a great deal of success and what
we found was that almcst everyone was allawing us to bid on their project. We
created a campany called C!rekive Finance Caopany so that we would not a p x e
Fm; t o any l i a b i l i t i e s as far as cur activities. W e agreed fmn the beginning
that FIG wxild receive a m t a g e of cur activities ~IXI
we figured 15%was
f a i r since we actually mnufacturd the pIoduct wfiere FIG *en cut and used
othex manufactured products. We didn't feel they were entitled to a 20 30%
split.
What
of cur amtmzts was w i t h Tony Bongoivi in New York. He a t one time dated
Scott's
sister apprmhmtely ten years ago.
Scott maintained a loose
relationship w i t h Tony, calling him one= in a while regarding business m a t t e r s
and business activities. Scott called Tony one day atcut a real estate project
that he i3mught
Tony said no, but he my have another
project that we would be interested in. Scott asked m e to go up to New York
with him to talk abcxlttheprojectand1 askedwhat itwas. He indicatedit
was a mwie.
I was very reluctant and hesitant to do this because nnvies t o
me, tax shelters, scans, not very econcmic type investment. Me being very
comxvative was not attracted, but I decided to go anyway just to get cut of
town, mre or less just to get away.
(Xle
I got up t h e n I was totally amazed a t the caliber and the people who we
were associating w i t h .
What I found cut was that we were working w i t h the
leading recolding s h d i o in the world. T h e r e d t i a l s , their acccnplidxm~ts
were @enmaml- they were just it. I'm not going to spend alat of time of
this because just the battcm line is what is inporbnt here. After seeing the
project wfien I lcoked a t what Tony was doing, and fran a business perspective
there were just so nary elewnts in this project that were just truly amazing
to me so far as distribution and markeI5.g and riskand eveqtAi.q else.
Bottan line was a pruluct that was worth 15 to 20 million dollars being made
for 4 million w i t h the ability to be one of the -1
movie, video projects
of the years.
biten
a l l ycu have the leading recoxding studio in the world working on the
scan3 for the project that was going to include a follaw up of Tony's previous
band who- was BM Javi who was alreacty one of the hottest thing in nusic as far
as alkum sales.
Then you have the fact that he was going to digitize the
recording which was never done before in the nnvie industzy a t a time when the
vidm market is just going bananas. N o t only that, hut the label that signed
the banl m MN.
You put a l l this together and ycu've got a penmend
business w i t h alot of apportunity
F i r s t of
seeing this, I ammitt& myself to the project not kmwing h o , where or haw we
were going t o raise 4 million dollars but I beliwed in the project so mplch. I
guess because I saw alot of the same elements used in F% in this project, and
even more.
I got instincts when I raised money for Em; I was still very
concerned with the risk elements to my investo~sbut when I looked a t this
project the risk was even less. Iess risk, m r e protection with this project
so I believed in this project. We spent seven or eight weeks developing the
packaging the product for the investors, things have hapxwd during that time
that f e l l into place perfectly
the a r t i c l e in lblling Stone, the marketing.
eight W.
It is mird b o g g l i n g a s f a r a s h t o n c a a e o f t h i s , b u t t h e
project is done, we did sanethjrq, we did not use Fm;, they w i l l receive no
I guess what I'm saying ik that because of the way Bob and Mike treated
split.
me or plshed me to go cut and do things, that did not involve Em; and I did not
feel that they did not deserve to becarre a part of these things. Fran the
beginning I knew Em; was going to get their piece.
The Iceogler grarp was strcng, large, y a q and they were doing nxghly 20
million dollars of gross canmission incane per year but there were saoe people
in the organizaticm we did not feel ccmfortable with. Hikbaxd Brrx~nwas a new
start up, starting up when we did, was a s p l i t f m a previous bmker/Mer in
D.C.,
that involved f m a syrdiotor to a -/dealer
that no one knew
anything a?xut. However, they really enticed us w i t h a very attractive equity
deal.
Bob maintained most of the cmmmications and mmt of the research
involved in this project.
It was brcqht to us in January w h i c h was IpuFplly
20% of their stock . w i t h 90% payout , territorial with override for aqthirg
that w e did.
0fthethingsImtshaildbedoneisthatscmeaneMdbedownthere
a t their t m d i q department, along with the capability of FSC. I tried
to get people down there several tims and I suggestd Qmlyn Royer because of
what had haFpened to her.
Finally Peter Pnneros and Ken Ray bent down, and
this was probably during U a x h . Anyway, this whole thing was dcne w i t h very
l i t t l e mmmicaticn as f a r as me, Bob and Mike. lbre of less, Bob wculd go
cut and do scanethirq and wculd fee3 back to us, but we redlly had very l i t t l e
involvement with what we into do w i t h M Bnmn. One thing Bob
irdmted w a s t h a t i f w e b e n t d o w n t o K i b b a r d m w e w c u l d n o t f i n d i r m c h , they
were just starting up, they were new, they had rmghly 10,000 sq. foot of
office space, a few staff people and the system of operation. He did feel they
w e r e capable of fulfilling cur needs.
One
1
-
I also negotiated the courtship of Tony Pascoti and got him involved.
Fran the perid of A p r i l 1st on, wfien we began transferring license, one of the
main
Jerry Bavero
In A t t e x h x e :
Stan caterbane
Mike naruett
AlanLDss
m
Bob K a u f m
XM Ray
-er
Richard Volp
Meeting opened by Bob Kauffinan
A.
N k r e we are tcday
~~
3.
Eawie.
4.
McCormick.
Raise $4,000,000.
Tony Bongiwi.
in retum for
agents contracts.
Service
B.
Stan
bution.
C.
1.
ming w e l l .
Good
profit scurce.
A.
a.
b.
2.
Down side
Mi.&
VoteOutcoPne-Notto~auSel~e~with~hSXaXx2.
1. Eemett W i l 1 k m - s prqject.
Bennett Williarrs
is major tenant.
Downtclwn Kistorical project w i l l prcbably be a joint venture
instead of a sytxiication.
2.
.
Bob Larq reports on active participation p a r b s d uP.
Partnership investors and Financial Management Gmup to have a
g
gm
p structure. W i l l pass alcslg 99% of tax lcsses to
rs. Financial Managenwit Gmup to keep 10%of cash f l m ,
20% of back erd. Designsd for investors with joint inam2 urder
$100,000, for single irdividuals w i t h inxme under $50,000.
3.
C.
Satellite Offices
1. Columbia, &tryland
a.
a.
b.
3.
A.
Olrrently looking
Reading, FFmSylMnia
a.
a.
Jerry try*
4. Questicm. ShaildwestaywithHBCorreapencnxsearchfor
alternatives?
a.
Decision. Tu work
inthreemonths.
K E N N E PROPERTY
~Y
CORPORAT~ON
A Subsidiaw of Kennedy Health Cars Foundation
May 6, 1987
Michael Lawson
Property Manager
ML/~
Enclosures
10/19/2006
8'
MICHAEL LAWSON
Property Manager
P.O. rn 101s
im E Q nubor
~
M.
1wmn.Il..
WJ mot1
m m
Alan Loss
Absent:
Stan Caterbone
Concern wer relationship with Hib$ard
W O N :
I.
BraJn
Corp.
as a Ebmkr/Dealer.
LDok a t all d o n s .
1.
3.
4.
We waild have a
business.
B.
3.
C.
'ItyO
1.
2.
D.
1.
mvoteonwheulertostaywithHBC.
2.
two rarts.
@CUE.
Bob Long;
BobKauffman; mlathashappenedinthelasttendaystochan@the
boards decision t h a t ms reached in the extended
dated May 5, 1987.
Alan Ioss;
E3Zb Umg;
Alan
k6.S;
ooncernedabouttheduediligenceatHBC. Aretheystrong
enough t o do local d c a t i o n . Why wasn't more due
diligence done in choosing a Em&x/Dealer.
Alan Loss;
.
Bob KaufBnm:
(Xlr
What is
mostimportant.
111-
b v i d R. Schod, President
Bennett Willians, Inc.
30 East King Stre&
Office ax 1364
Yak, PA 17405
Dear Dave:
Enclosed is a prcpsal for ycur splicaticn. Please go wer its contents and
mi*,
we sharld get together to discuss the project
in person. I will be away until the 18th of May.
Stanley J. cat333xme
President
SJC: lmk
cc: file
Robert J. BeNer, Jr.
IV.
V.
m6.
center
SCOPE OF
m s m
that
icka d d i
yorh.
:<
~ I G Y C I
'
JCQ,C
-b-u.rj/lw c r p , n
eY
7)
~ A L Q~
-J-
( l Ci
U L S ~ ~ C T
~ j $ ~6,~r1 1 n c s r
11.
FUNCTION OF
BENNGT WILmmE
- mE GENEmL PARmEE
(G.P.)
A).
B).
C)
D).
- The G.P.
w i l l be r e s p n s i b l e f o r all construction
appreeiati-+the-proje&-forAuhrcprofib
fukre
/I'
r c c : A ; o - yiven
Guersbte
\ n co me
~ C . , - . O ~ C L
co cd;
h o e 5-
11.
FUNCTION OF
BENNGT WILmmE
- mE GENEmL PARmEE
(G.P.)
A).
B).
C)
D).
- The G.P.
w i l l be r e s p n s i b l e f o r all construction
appreeiati-+the-proje&-forAuhrcprofib
fukre
/I'
r c c : A ; o - yiven
Guersbte
\ n co me
~ C . , - . O ~ C L
co cd;
h o e 5-
FIG, Ltd.
-s*W
- General Farher
P v l o r - k j l h ~&S
,-Equity: '26% ok
Income:
5%of N e
/
Equity:
ItIcome:
LQM :
75%
75%of N e t Proceeds
88% of: a h go- )-+a acb-l d e v c l y ~ c ~ t .
m , ~ t d . w i l l receive
of the
-,1;?n~associated with
necessary
cd ;,la f l c o c L - ~
w i l l go in;*
y a c
77
FEiANCIAL SERVICE
cmmm
Financial Planning
2.
3.
4.
R e a l Estate Services
5.
Legdl Services
6.
msrance services
7. Inves-t
HIBBARD BROWN
&COMPANY,INC.
3.
What is the structure of the offering (public, private,
Reg D, 504, 5 or 6)?
4.
5.
If
we need to discuss this matter on the telephone.
necessary,
we should make an appointment for that
phone
conversation.
I will wait to hear your response to these questions and
look forward to hearing from you.
Sincerely,
Ti?/.Richard P. Brown
President
Menzh.r N A S D
M e n h ~ rSlfC
President
UNIVERSAL
"."
7855 W
W Drive
Greenbelt, Maryld 20770
Dear Fete:
As ycu h-w fma cur phone amversation, I feel very poorly about the
Fm; Board of D i r e c t o r ' s decision to leave Hibbard BraJn. Neither
Mike M e t t or I shard the feelings of scmne "key pxducersl1 that
lang-term service shortfalls would exist. We also felt that your
people were bath amptent and intemsted in providing good mice.
Given time, our feelings were that ycu wculd be able to semi= the
needs of a hiqh volume office.
I am very concerned about the attiand mrale of your people
n q a r c l i q the x x x x n t ixrn of events. It wculd be ,wen mre unjust of
Fm; to leave the olblameolon HB anployees for pmr service. In my
opinion, there existed an ovemcsction to sane system @lens w i t h
mch relationship unlerrrmung by PIhad persanal
considerations in mind. mat is a l l !
..
.
I
I believe that I did my level best to avoid the votq and I also did
level best t o m a v t h e v o t e . I r e g r e t t h a t I failedandthatmy
me lrmst be associated w i t h the deckion d announcement
Correspondence.
A t this tine, I am so^ throughthe feelings and
messages sent to nre in this action. I hope you can urxkstand and
that your staff can also I1I.derstand.
I give you my best w i s h e s for the future and believe yau w i l l succeed
i n proving this to be a bad decision by FlG.
Robert E. Kauffman
Sack Dn I11
*,,om
5a"l Dnr
Park R w . NJ 076%
T l l W1-9301WO
Son vde. ems
3651. YX(. 267s
Ovrm N a U iF7es.J
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5.1.c: 3079
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PVVM.1007652
T*: 10l.360.Ym
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D. M. D".ry
R. C G - % ~ .
0 Wax 428
SUI.rmlk. m: 2 8 6 n
'*I. 701412.7424
wart. P W
4
.tMI1
s.1.c; 2291
Oennlr M tavanaugn
Russell Cleary
John H. Dsnaelr
Gwrge H. Dtxon
Rsnald K. Gamey
Roben C, Gtlmore
F. 1. Heliell8nger. I1
Burleqn E. Jacobs
George W. Mead. 11
W~llharnG. Pnciilpr
W811tarnW. Sltnson
Donald F. Swanson
W l N l ~ nR. Wallm
m.511
0b.r
a,m
~o.,Oom
L Narrih.1
NY
SOR W O T C )
.(MI5
.. -. ....
E m 490
9s.: 166.544.272
-OX.
~r r a . NV I ~ I S
li.nn F m IR.rI
Boc
l .no
Johnh MonNUI
Japan)
Executive Headquarters. S W. 57th St.
New York. NY 10019
7el.: 212-371-5800
NY
Sony Drive
Nat(onal Opera. Headqtr.
Park Ridge. N J 07656
1 el.: 201-930-1000
SriE+NYSE
PS Bo Ci MW Ph Ts)
Assets: S5.345.%7.0~
LlabLlrs: 13.132.561.000
Nef mmn 12.212.9BO.000
W r O r . Sic: S6.701.816.000
Enp- 43.000
Mlr 6 S k r 01 E * N D n r r Equrp.. lnrmmmtr 6
,,,M,,
Z R Z .
0,656
- 201IJa1030
Jd'a
lRul
1
.
1
.(Urn
..
lkncer
WrMrlrrm
.
I
-
S O 0 LINE CORPORATION
56% Owned by Canadian Pacific Ltd.
Soo Unt Bldg.
MinneaooI#%MN 55440
-. ~.
Ma1ling'~ddiess: P.O. Box 530
Mlnneapollr. MN 5 s u o
Tel.: 612-347-8000
MN
SOO-(NYSE)
&see: S1.138.205.m
Lntdrles: S830.327.m
Net Wath. W7.878.000
A p m Sk.: 161757OWO
Ew: 73x1
~ransmtsndinp
bn+av
S.1.C: 4011: 6711
DQnrvS M. Cauamnruph (avn 6 Qref Ex-.
~
SOUNDESIGN CORPORATION
Harbor Financial Center. Plaza T w o
Jersey Clty. N J 07302
Ttl.: 201-434-1050
DEArrefs: S74.132.~0
Llab;blder: S40.902.m
Net W m h : s33.230.m
WO..
s1s.: I2W.OOO.000
E w yK)
Mlr. OT T~~YSIOI
Rad'or 6 MW WS.
S.1.C; 3651: 5064
Sad E. *mh.nui KXM. Exec ccmmnee)
Ehl Ashkenam l h . M. 6 Chel Oper m-)
M. Franco (PIC)
R&n
Wuur ( E x e c V.P.)
H. F r a 1%
~ VP.)
C. Chraime (SI. V P 6 TreasJ
S. Lanudo (Sr. V.P.1
Thomas Gtsena ( V P . - M m n . 6 ParoMcl a,)
h a r d Kkln 1Sec.J
AIben Hamay IPu. Dr.)
mlrrr,
.'"(U1
107 1,-l
C o m r n u ~ ~ ~ at M
, . )s
Board of Dlrtnom
Roben L. sorp
Eugene Blanc. Jr.
Eugene Bkm. ~ r .
Ncholas Cawto
Roy A Cardta
Dons S Cunnlon
DOM P a e r s
AIben W. VanQ
(100%)
socpe of Pmject
m k e t i r g and Distrikution
Financial Prcposdl
amtracts
'Ibny m i m i
and F t x e r Station
mast
A).
Wical Overtcn=s
B).
~ 1 o g y
.
D).
C)
m k e t b g ard D i s t r i h k i c n
Limited DJrJrside Risk B t e n t j d
W h a ycxl prt
in any business v
htertairmrent
W i e s available ---the
-.
of P r o f e s s i d
the Scny-
Digital
the
as the Professianl E n v i s m e n t .
to-rt
'Ihe m v i e
in
Marts
the
aanplimentary
rmsic
el&cs
of
Because
~
aE
hasI
sold nine millicn alhms thus far
for Bn Jwi, *&
- Bon Jovi!
Lick.
ever
n, dllxrm has
sold nvre alhms in its f i r s t six ucmths in the history of the recon3iq
I
kbstry.
Because of
saxe
rmsical
profitably!
horror script
'Ib add
the
okritiffil"
this into a
an
aaninate the
rmis is W h e n t h e p j e c t g e t s i n t e r e S t i n g a s f a r a s ~ a n d d i s t r ~ c n
isculzemd.
Because of
xarkthg
the exclusivity of
ad
the te&nicdl
r l i s t r ~ a nsbaild be pxerful
mrventianl
deals.
Property
of Advance Media Group
arr3 the
elacne
in even the
'
the
,
nost
lmxEmxz AND
DlsTmmrION
to biu e1eQmt.s:
a ) . Video
b)
T h e vi-
utren
yrxl
D i g i t a l r6mrd.k~ard playiq
'
' ,'
y that
is in need of product.
-re
~~Fsltertainmet
have an
arnazirg p b m t i a l for d i s t r M m ! !
- )
m l e wfao have yet to hear the digital sm-d. Because of the visibility and
pecple hear digital by way of theatre ard video! As to hckJ mmy pecple? 1
- 10
- 50 - 100 millian?
well, what w i l l be their first reactim? J NEED 'ID HTY A DISC PIAYER!
lheir
VIDEX),
reaction w i l l be I ~ T O H E A R ~ S a U N D I N M y N D L T ? V ~ ,
MXrIE,
a-.
W
e a
-.
lhis
of the theatrical
I.
The
&
-
'Ihe Carmentary w i l l d i s c l l s s t h e S c i y / F S l 3 5 S a M D S Y ~ a n d t h e
will be used.
'Ihe
mnreie
the~FeatmeFilmtousethisSystem.
11.
WEW#I
We w i l l
Sciy
rarket a N1 line of
KMGSlNTCN
w.
the video.
?he offer w i l l
be a t wholesale pri-.
of
the 1m
tudget prduct is that rn hcpe when pezple actually get to the store they w i l l
upsrade an3 tuy a t full retail!
for TcPry's
m t b e ~ w i t h . I t w i l l a l S o p m m o t e a l l ~ f S c n y ' ~ ~
-P
-
m the
Eaqiovi.
m. we
We w i l l amvert the
SSXKTIW.
Say
We
films.
N.
arrl theatre that will be used to pramte the project before the release of
mtant Mania.
--
a.
Frencfi \lick
b.
c.
thescum3.
A spat
'Ihismay sim~"~thedifferenoe**.
h e .
W e warld like to
to yu.~the Say/psa--give
ycll
hpxt cn w h t it is.
p
t warld you rather listed to when 1-
or television.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
ImFaLWJISING DEAL
a ) . Wevisim
b).
-S
ccnpahlent
ViaeD Player
--
Say
will
distritution.
'lbtd will
We want
touakeucmeyonlyif Sonymakesnmq!
-m.
Tcny w i l l ~ 1 u d e i n c q T i g h t A g r e e m D J l t t h a t ~ E q u i p n e n t r m s t : b e u s e d t o b e
EnE.
Scny will
cable ~ ~ / s C SystemT
n y
- Also to be e
d after w
i
n
s are figured.
-.
I.
S C g l y w i l l c n l y p a y f o r a p n s e s t ~ p ~ 6 O s e m n d s p a t s%myand
.
Rwet Station will utilize any anl all s e m i s
am3willallwreimbursaaentforcmlytruecostswithn>mkeup
e
.
x
l
wa l l of Tony's time ~&
11.
w i l l be free.
w-
e~
of the Scllypmdcck ard the sale thatmay result to other film st&ios
UtilizhqScllyequipoerRintheINSSystem.
m.
-\
- Telwisicm,
VCR, Stereo, Etc. that is tcp of the line to help during the pm3ucticn
of the film to be utilized by Marcia, Stan and Scott.
IV.
Scsly
will have first right ard first refusal of all ard any d i s t r W o n
We
willprcmiSenottOeventalkto~else~uefeelthatScnyis
='=F=F'==
m
Thy
Scmy
e talents;
m m m .
AM)
C~RIBVTICN
% of
h i s i n i t i d c a p i t a l account i n s w h j o i n t venture.
T h i s L e t t e r o f I n t e n t i s e n t e r e d i n t o by t h e undersigned u p n t h e
/
following general d e r s t a n d i n g :
Power P r o d u c t i o n s I w i l l b e a j o i n t v e n t u r e t o be
formed under t h e laws o f Pennsylvania, having t h e
s p e c i f i c p u r p s e to invest ( l o a n ) its funds to MUPANIA
PRODUCTIONS,
INC.
to
finance
p r o d u c t i o n o f a motion p i c t u r e .
such c o r p o r a t i o n ' s
The j o i n t v e n t u r e
b e f o r e the d i s t r i b u t i o n o f
'-)
-
Such c o n t r i -
b u t i o n s h a l l be h e l d by S t a n l e y J. Caterbone a t i n t e r e s t , pending a m p l e t i o n
o f all n e g o t i a t i o n s ard execution ard d e l i v e r y of
PRoUlmIOLJS,
2ii
documents w i t h MUTASIA
m.
den&.
S t a n l e y J. Caterbone s h a l l be r e s p n s i b l e f o r c o l l e c t i o n , r e c e i p t ,
f d s c o n t r i b u t e d , and s h a l l be t h e Managing J o i n t V e n t u r e r o f t h e j o i n t
venture.
SIGN
(L.S.) Date: W y
tWE:
-,1987
PRINP
NAME:
STREET
F.
ADDRESS:
STATE:
CITY:
ZIP:
RICHARDC. FOX,PC.
ATTORNEYS AT LAW
HARRISBURG,PENNSYWANIA inlo
RICHARD c
mx*
('ADMllTED ALSO M R W
M r . S t a n l e y J . Caterbone
FMG Advisory, I n c .
Eden Park 11, 1755 Oregon P i k e
Lancaster, PA
17601
For P r o f e s s i o n a l S e r v i c e s rendered i n c o n n e c t i o n w i t h
Power Productions I , i n c l u d i n g c o n f e r e n c e , p r e p a r a t i o n o f
Letter o f I n t e n t , and e x p r e s s m a i l i n g , .and follow-up t e l e p h o n e
check.
Professional Fee
UJP.S.
250 .OO
8.95
FLATBUSH
FIlMS,INC,
May 21, 1987
I spoke to Jerry Vandersonde and Bill Hudson of DeWitt Stern Insurance in Los Angeles, who were recommended by Worldwide. Since
I couldn't show him a budget or a script we did some educated
guessing and came up with a figure of approximately $75,000. The
Production Package policy should include: General liability, cast
insurance, negative film, faulty stock and camera processlng,
props, sets, wardrobe, rented equipment, extra expenses, third
party property damage, non-owned auto, Errors and Ommissions
including a one year bond and a minimum workmen's comp policy
for anything that is not covered by workmen's comp.
person.
4334 STERN
AVE..
H E646
RMAN
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Page
161Sof
1818)
Page 2267
of 995-3417
2953
FLATBUSF LMS,NC,
May 2 3 , 1987
E l l e n Libman
Power S t a t i o n , I n c .
4 4 1 West 5 3 r d S t r e e t
New York, N.Y. 1 0 0 1 9
Ms.
Dear E l l e n :
B a r b a r a a n d I h a v e mapped o u t a s k e l e t o n s c h e d u l e f o r o u r t r i p
t o N e w York a n d I t h o u g h t I ' d s e n d i t o f f a n d see i f i t w o r k s
f o r e v e r y o n e e l s e . By t h e way, w e ' v e d e c i d e d t o s t a y i n N e w
York u n t i l T u e s d a y i n s t e a d o f Monday as o r i g i n a l l y p l a n n e d .
Thursday
A r r i v e a b o u t 3:OOPM. You h a v e t h e e x a c t t i m e
s i n c e y o u ' v e booked o u r f l i g h t s .
Please let
u s know i f someone w i l l p i c k u s u p o r i f w e
should take a t a x i .
W e ' l l come t o Power S t a t i o n a n d g i v e you a n d
Tony c o p i e s o f t h e s c r i p t a n d b u d g e t w h i c h w e ' d
l i k e you t o r e a d Thursday n i g h t . .
B a r b a r a a n d I h a v e a d i n n e r m e e t i n g w i t h a Director of Photography.
Friday
Saturday
Sunday
S t a n C a t e r b o n e a r r i v e s i n New J e r s e y .
M e e t the
r e p from Maury's P i e r t o d i s c u s s l o c a t i o n costs.
Check o u t h o t e l s f o r c r e w a n d c a s t ,
Monday
L a s t m i n u t e d e t a i l s i n New J e r s e y .
L e a v e f o r Mew York a r o u n d noon.
M e e t i n g s a t Power S t a t i o n f o r f i n a l d i s c u s s i o n s
a b o u t s c r i p t , budget, c o n t r a c t s , etc.
Tuesday
Tuesday A f t e r n o o n
L e a v e N e w York a p p r o x i m a t e l y 4FY t o a r r i v e
i . c r ?..nc;i.i r , . ? b o u t $FbI.
.
.
C,lk
<~ i n planning your schedules.
- -.7
7
PO+-T<
Page (SlS]
2268 of975-3Si7
2953
Lancarter. PA 17601
717-569-5555
Table O f Contents
)
.
Section I
Financial MaMgement
Section I1
The Project
Section 111
Section IV
Grc~lp
Bart>ara Peters: D i r e c b r / W r i t e r / P r m h c e r
6urw
Horrvr nwvies, from the investors point of view are the safest type of
m i e to finance. Horror movies have an dLmost cultist follwing. m e
type of audience t h a t attend homr 'movies rarely wait to see what the
critics have to say ahcut the movie. There is a fascination with gore
that this audiens would rather see than have described to them. The
overseas mket for movies of this genre are ~
0
~ In salmost
. all
cases the grass revenues frcan the theatre, w i l l be greater werseas than
in the d-ic
(US and CaMda) market. mis especially holds true for
horror wies.
Over the l a s t few years, we have h e n seeing a trend for wwies t o have a
much heavier nusic score than in the past. The feelings that can be
invoked in an audience from audio are sanetimes as great o r greater than
the visual aspeds of a film. W i t h Bongiwils m i e n c e and past track
record, w e are assured of having one of the best quality sound tracks to a
mmie ever made. 'Ihis prcduction d d very well revolutionize the mavie
hhstq in t h a t this w i l l be the f i r s t time t h a t the sound track w i l l be
totally digitized from the set to the theatre o r home video. W h a t this
means is that the quality of the sound, w h i c h is typically extremely poor
i n a movie theatre o r hoane video cassette, w i l l n a be
~ trewrd~~~ly
crisp. 'Ihis new mavie sound w i l l be similar to the quality you would
expect fmm a laser disc. Nolmdlly the costs involved to prcduce a movie
w i t h this type of sound track would greatly increase the budget to a point
where the project wnuld have an increased element of risk. W i t h Rmer
Station, w h i & already has in place state of the art equipat, sane of
which can be f
a i n only one o r two other studios i n the world, this
sound track can be prcduoed for a fraction of the oosts that another
prcduction wmpany a
d have to pay. This greatly reduces the r i s k to
the investor to be able to pmduce state of the art audio a t a fraction of
the costs.
The home video m k e t has rapidly been charging the ptential mnrie
profits for the industry. A Nighbare On Elm Street was made f o r w e l l
under two million dollars and has earned New Line Cinana more than $24
million a t the domestic box office. In addition, after a short video
release, this pnxtuction has sold wer 3 million cassettes. In the past
videos w e r e sold only to video rental stores for approximately $70
apiece. Recently the price has been lawered to expand the market to the
but they my
general public. The video rentdl stores won't disa-,
beccone more like record stores that also rent their albums. A l l of this
translates into nmre p r o f i t potential f o r prducer and investor.
It is an extremely rare opportunity t o be able to get i n on the ground
floor in an offshoot of an already w e l l established e n t e x t a h t
campany. Any investor willing t o back this project w i l l have f i r s t right
of refusal on any future projects. The prcentages w i l l remain the same
for a t least the f i r s t two projects.
2.
Inv-t
)
.
Structure:
Ihe producer and investor form a limited partnership for the purposes
of pmducing one o r more motion pictures. The investor receives 100%
of the net profits u n t i l reaqmmt, after which the s p l i t is 50-50.
Profit participation of others (actors, director, writer, etc.) oomes
and a writex.
Presale Deals:
1
. .
. .
APPENDIX
$ 300,000 Gross
$ 300,000 X 14 days
= $ 4,200,000 Gross
x $
6.00
2nd Run
50 people
= $25O.OOGrosspershow
hauses
$ 500,000 X 14 days
$ 500,000 Gross
$ 7,000,000 Gross
Forcast A
Total Box
office Gms
$ 11,200,000
15%F~~ me.,-
1,680,000
g 520 000
2,856,000
6,664,000
4,000,000
~~t
profit
2,664,000
1,332,000
1,332,000
199,800
mtion pic-
-fit-
30% ~ i ~ i - ~
F~~
k t i ~ ~
prodUcers
split
50%
Investment Ccrmpany R e t u r n
: General partners S p l i t
-------
15% -----
These are onlv umiections and are f o r informational pwmses only. Any
investment made. based solely on these u r o i e d i o n s would be unadvisable as
actual uerfonnane could vary cyreatly.
Forecast B
Forecast B is based on a total box office gross of $ 28 million
A film that prcduces a theatrical gross of $ 28 million can be expected to
gross at least that much from TV, Cable and video markets. Depnding on h m
distribution a-ts
are negotiated we can expect 50% to be net profits.
Forecast B
--
$ 23,800,000
$
4,200,000
7,140,000
$ 16,660,000
-------
$ 14,000,000
$ 10,670,000
$ 10,670,000
4,000,000
1,600,500
9,069,500
You Oughta Be In
Pictures!
I by Alan Talansky 1
here's explosive growth occurring in the motion picture industry, and growth should always he
music to any investor's cars. -Hut
movies!" you wy? It's time to put
aside your images of Tinseltown and
'Heavm's G:~te,"and to take another
look at an industry with some new,
sound invest~ilentpotmtial.
There's risk in any investment, of
course, rvc-n in real estate - the investment area on which many firms
originally built their reputation and
success. In real estate, it's a matter of
how carefully you assess a variety of
influential factors and how you struclure the deal. Motion pictures are
much the s;arne. You've got to look
for potenti:~l.
-,
a puttry i l 7 5 , O ~ W p ~ u c r i obtrdwt
n
for "She% C<,tla HUM R - i~ilou
$7 millio~rgrr*u.irr#suqriY hi,. Co-slursjulrn Can',nb T&l
(lejll utrd
~ r t . ~ I Ww.1.Photo courtesy Forty ~ c r s s
~sd,,ro,td Hicks f"gkr)
10/19/2006
SPRING 1987
1
In
u-
n u m w
newsletter
Welcome
FMG would like to e x k x l a hearty welcome to Jon Gruh=r & Craig mseli.
Principals in the law firm of &see1 Krafft G n h r & Huber. 'Ihey w i l l
mintain office hours here daily f m 1 t o 5 EM and w i l l be part of our Legal
Referral system. --MICHAEL HARllEW
Parkinq
Fhone Messases
If vou take messaaes a t niaht lease leave the nssaaes in the circular on the
---.
front desk.
We -are lo&
&o many afi%r-haur messages fram clients due to
lack of c o o ~ t i o n . --T(D=
KAUFEMAN
---
lb F I G Frcducers f o r A ~ r i l
1. P e t e m m
2. 'Ibm 'nlrlxr
3. P. Alan Loss
4. Harry Radcliffe
5. RabertKauffiMn
--ram
KAUFFMAN
G c d
--ROEBU! KAUFEMAN
30,000
50,000
60,000
70,000
80,000
= -7
-
-'_'
FMG Advisory
m
=
I
Lancarler, PA 17607
717-5694100
XUL * I . L T I M Z N T L l W . L1D
SJC: lmk
CC
encl
m & Y
3-Y
Y-
S t a n Caterkon-e arrives
Please let me kmm if ycu have an:! additions or changes. I ' l l probably
talk to @u a9a!,n c-;.!,>.TY%:J.
.. <&"., .
c:t_::
Barbara Peters
%7=ds,
Arlene
FlATBUSH
FILMS,NC,
May 29, 1987
&
rlene
,avidson
10/19/2006
TIME
S Y S T E M S
MONTH
,-d u g
YEAR
1487
RICHARD L. TRUMP
P.O. BOX 557
SKIPPACK. PA 19474
Bus. (215) 489-2447
June 3, 1987
Dear Stan,
Enclosed is Stock Certificate number 28 that you requested
to be returned to you.
I am concerned about the $2,000 purchases of FMG stock
which I placed via a money order for Michael and Melissa
Metallo.
When registering and printing their certificate please
use the following information:
Michael C. Metallo and
Melissa J. Metallo
Social Security. Number 027-34-9917
Address:
&,&
&zU/&@
Rick Trump
RLT/tpp
Enclosure
2290 of 2953
APage
Registered
BrokerfDealer
Member NASD & SlPC
10/19/2006
June 1 2 . 1 9 8 7
Financial Manag-t
Group
1755 Oregon Pike
lancaster Pa. 17601
Dear Stan:
As you requested here's a schedule for hroject 441 (mrking t i t l e ) :
PRE-Pmmm
Ju~le28-July 11, 1987
July 12-Sept 5, 1987
POST-P~m
Novanber 1-January 30,1988
New York
New Jersey
2-
New Jersey
8 5 day weeks
8weeks
New York
In order to s t i l l get the film made this season we've got to speed everythkq
up. W e originally planned four weeks of pre-production in New York kt t h a t ' s
ID longer possible. I f we start J w 28 we've got only ten weeks to get the
mtant effects going and then w e ' l l have to schedule mutant scenes later in
the film i f t h y aren't ready.
This schedule also takes us to October 31 for the enl of the shoot, which means
we've got to schedule exteriors f i r s t , leaving the interiors f o r later in the
went of bad weather.
S i x e we're on such a tight M u l e I can't r e d l y hreak
down the
costs for
4334 STERN
AVE.,
SHERMAN
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Page
186
of 646 OAKS.CA 91423Thursday December 15, 2016
Property of Advance Media Group
(818)of995-3417
Page 2292
2953
10/19/2006
hill
The editor w i l l
Regards,
n r o u . r m ~ ~ ~ ~ a n a l n d ul n~v w
~ rro~m ar v~m~e i n o a , a ralympanl a n a r n r r o m s m ~ r w c r a r u l m ~ n u n c a s ~ ~ t ~ d ~ m m a r ~ ~ ~ ~ ~ ~ ~ ~ ~ l m ~ s p a y m c n
C m p ~ ~mb
e S T ~ S 1 and 3
0 n y w are .pply4ng la p n t cradftrlnn armnn palm, cornwe *I~ ~ t r pfaamnp
n r
nlamalrn n ~ s c t ~ a2 n.mr inr on8 awlcant
nw.rerorna,v~srsou.~uln.raylw~ncm~,~Uml.
C N ~ s Y P L X ) R a - , . I . ~ ~ . I . ~ . a m m . l n C O m m a I ~ ~ ~ ~ a m ~ e r w l T O n u ~ n ~tor
~ ~r ~c p a l ~ i d ~ h e ~ r e
,bq-tad.
S ~ C I M I . (10n0,~pnpm~ammn
%clan 2 a m IM D~Mal,mny. s
-.
a* mamom- paymantr a nca issatr sou i r e i c h ~ q
J 11ns s.I-~
rehta. to mu plw#ann,dma -msdnandolnr
p r u n l r l I h r q s ) a cmpaatm(r). compbce S % l m 1 an0 3
cmyMe~~
Salary banuses 6 C
O~~~SSMS
Dlvlaenar
Real estace t n c w
Otner mcome W m m ~CNU
.
or
PERSONAL INFORMATION
.IS-
Do yw nave a w
, me 01 ereculor
ml-
.*ar*llop~.-~w~onmi.l.blohr~
-~r.o.*tw-muowdm)
~ , any
e assets pledgeaamr Inan as dercratlea on scneaules? II w, aescrabe
TOTAL
CONTINGENT LIABILITIES
DOyou nave any conlmgent lhabl8ller~11 w, aercntle
As onaor~erCD-make, or guarantor?
On leases or cmlraclr7
S
L-1
cla~ms
S
OlMr specoal aebl
S
M
w
n
l
01 cmtsned mcome tax loens
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIMS
Property of Advance Media Group
10/19/2006
n -Y
Descr~ptm
Ale Thaw
In Nam 01
Marha
Valw
Piedpea?
Number 01 Snares
Are There
ln Nams 01
Sovrce 01
Value
Valve
Pleapea'
SCHEDULE
C PARTIAL INTERESTS
MUtTlES
- ~- - IN REAL
~ESTATE
-
Thlle 10
N01
Address 6 l y p
01Prooeny
Dale
5 01
Ma~kel
valw
Cost
~*nerstnpAcwvea
Mongape
Mrfgagc
Mslwtly
Amunl
Dale
AcqusreO
Tdle I"
Address 6 Type
01Rwuly
Name 0 1
Market
vale
MMQaX
MOU
Y
II
Name 01
Insur-e Ccm~4-y
Benefr~ary
Face
Amml
Cam Surrna
Po1.c~
Value
L-I
I
t
The Informdlon c0nlain.d i n this s t a t m n t is 0rovid.d for tha w m s e of obtaining, or maintaining credit with you on behalf of
undmlgwd.orp~nona, Urms orcorporstlona i n who" b.hantha undenigrvd may aith; uvaraily or jointly with others. e n u u t a 8 guara
in vour favor. Euh undomiand undustandr mat vou am nlvlng on me infomutton providsd h r e l n (lndualng t h designation made a1
o w ~ - h i ~ o i ~ r n p . ~ind.cldlng
)
togmnt or contiriw cndn.
undenlgmd n p n m t s and warrants tttmtth information prov1d.a is t
and comoietand that vou m w consider thIsstrtam.nt ucontlnuln. l o k trueand correct until a written notice of a chsngb i S given toyor
the undarslgned. You .n mtlhorlzed to maka aU inqulrta you dwmnaCa.ury to verlty the accurvy of the statements made herein. an<
detnmlne m y l w r cmdlhrorlhinu. You am authorized to answer questions about your &it
exprlenca with melus.
Euh
Sigmlure (I!ldl#~Oual)
S S No
Dale 01 B~rtn
Date Sognea
19-
Dale ol 0u:n
SW:wc
Enclosures
Via Express Mali
0
C O Group
U N T Y
Property1of 2
Advance
Media
R O A D
O I h 7 O
2 0 1
5 610/19/2006
8 h 8 7 5
PLAN
DIXX
UEEINGS
-T
RIINNG-
El 4101
RtY 1-85
P*YSEAL
S.R,lU*L
-MIL"
PRlNTED IN US
WNTU
LAW O F F I C E S
P H I L A D E L P H I A . P A . 19102
A R T H U R H . SEIDEL
T E L E P H O N E 12151
J O E L 5. G O L D H A M M E R
MlCMAEL P ABBOT7
22 J u n e 1987
TELEX
845
CABLE
GREGORY 3 . LAVORGNA
DANIEL A . MONACO
ROQEFlT H
WAMMER lil
THOMAS J
DURLlNG
GROUP I , I I b
EDWARD
GONDA
O F COUNSEL
SYLVIA A. G O S Z T O N Y I
S C O T T J FIELDS
8*R*
STANLEY H . Z E I H E R
ONLY
Dear Stan:
As requested, I have completed a search in respect t o t h e above-referenced
service mark. The results of t h a t search a r e annexed hereto.
I t is my understanding t h a t t h e mark "FINANCIAL MANAGEMENT GROUP"
is used for services of providing a complete package of legal, accounting, real estate,
insurance, stock brokerage, portfolio management, market timing, financial planning,
mortgage banking and investment banking t o business firms.
Based upon t h e results of t h e enclosed search, it i s my opinion t h a t you
can adopt and use t h e mark in this region of t h e United States. I t is a close question
a s t o whether t h e mark i s federally registrable. Moreover, you may a n t i c i p a t e difficulty
in using t h e mark in California, Arizona, Georgia and Illinois. The possibility of opposition
t o your use of t h e mark also e x i s t s f o r t h e states of Louisiana and Oregon. T h e reasons
for my opinion are explained below.
If t h e only consideration were federal registration, then I would s a y t h a t
t h e mark is probably registrable. The closest registered mark is "FINANCIAL
MANAGERS SOCIETY". T h e marks differ only by t h e last word, and "SOCIETY" and
"GROUP" arguably have a similar connotation. But your services a r e fairly distinguishable
from those of t h e registered mark. Thus, on a federal level, t h e major objection t o
an application t o register may b e a n argument t h a t your mark is descriptive of t h e
services being offered. Descriptive marks are not registrable unless by virtue of their
long use and heavy promotion t h e y have become distinctive. However, t h e r e is at l e a s t
5549
,!I
(1930-19851
NANCY A . R U B N E R
b NI
1 1 6
SIPAT
12151 5 5 8
TELECOPIE-
S T E P H E N J. M E I E R S
AMANDA LAURA NYE'
'DC
see-e3e
22 June 1987
-2-
5. 2
3 c~4?J,0~Ym
. GOLDHAMMER
--*-\
\
.
JSG:md
Enclosure
STANLEY CATERBONE
Eden Park 11, 1755 Oregon Pike Lancaster, PA 17601
569-4 10 0
DATE:
10:OOam
PLACE:
SUBJECT:
Upon the arrival of Mr. Larry Resch, Stan Caterbone met him in the lobby of FMG, Ltd, at which
time Larry Resch said "Carl Jacobson could not attend, we had t o suddenly fly him out of the
country early this mourning?
The meeting was started with the subject of the fmancial difliculties of United Chem Con and
possible alternatives. Larry Resch specifically addressed the possibility of moving the operations
of United Chem Con to another facility, with specific regards to the Renevo Plant. Larry Resch
specifically addressed the financing capabilities of Stan Caterbone, along with possible management
opportunities.
Larry Resch also gave financial statements and documents to Stan Caterbone for the latest fiscal
year for United Chem Con.
Stan Caterbone went on to allege that United Chem Con had embezzled some $15,000,000 from the
United States Government for contracts that contained improprieties.
Stan Caterbone also alleged improprieties of International Signal & Control and James Guerin,
with specific regards to its role in the United Chem Con, and its business activities a s related to
government contracts.
Stan Caterbone noted that he, a s a legal shareholder of International Signal & Control was
concerned about improper business activities.
Larry Resch was taken by surprise by all of the above.
Stan Caterbone became quite upset by the evasiveness and the lack of specifics with regards to
Larry Resch's conversation.
In efforts to thwart any further communication from James Guerin, United Chem Con, or
International Signal & Control, Stan Caterbone demanded a retainer fee of $10,000 before anyone
contacted him again.
NOTE: It should be noted that it was quite evident that Larry Resch was merely acting as a
messenger for James Guerin and or others, and Stan Caterbone has continued a relationship with
Larry Resch that was not reflective of any improper activities or misconduct.
PLAN
TtME %PEN1
arm
WET-
RlWC-
SPIURU-
l V P l RmP
ULNW
RnSCII
rWLI
CR1C L 8 A 0 5 S Y A N
ROBERT D S i L T S
TERRY R 8 0 6 5 C R 7
-I. T H O M A S YENALF'I
CLYDE W M t l N T I R E
!DWARD w ROTHYIN
0 0 8 E I l i A MILL5
W JFFFRY JA*OUNE*U
HERBERT fl NURICK
DAYNO L LEHHAY
STERLING C . YCHEES
ATTORNEYS AT LAW
19.2-1967
100 P I N E STREET
P. 0 B O X 1166
~~
DAVID W . WALLACE
H A R R I S B U R G , PA. 17108-1166
TLLEPHONC (717!232-8000
TELECOPtER (717)236-2665
LL12hB-H
A. DOUGHERTI
A L A N R . BOYHTON. JR
GARY T I E H K O W S K I
DAVID 8 . D l l W L l
H. LEE ROU5SEL
MAURICE A . TRATEll
C C I I I I W C E R BOW***
.(O)tW 5 . 0 1 L F I I
In Re:
DIANE H 7 0 1 A R 5 1 1
JAMES J D O D D - 0
AHIIE I.FIOnENZA
JOHN Y l B F L
RICURD 5. LAHLBIVGII
KEVIN _I. F R L D C R I C L
DlVlD
O f COUWSLL
61LBER1 Y U R I C I
EDWARD C. FIRST, J P .
ROBERT H.GR15WOLD
JETTEISOW C. B I R U H A R I
SAMUEL I . SCHRECIENGIUST..
*.w*ris,JI1.
.4
9
\..
4
Wd
WJJ: jp
Enclosure
INVOICE
Lo&L
CthQba
N-456
RUSSELL
Locksmith - - Safesmith
334 N o r t h Q u e e n S t r e e t
Lancaster, PA 17603
Customer's
Order No.
Phone
No.
sold TO
F*G
Address
Ed-,
PJVISO.-U
&,*
.Sn<- 1755
*~
1987
C'hrtq-p)C'
J u n e 2 6 , 1987
Account $282396
U / O HE240
F i n a n c ~ a lManagement Group, I n c .
Eden Park 1 1
1755 Oregon P i k e
L a n c a s t e r , PA 17601
Navajo
N27623
1.
T r o u b l e s h o o t i n o p e r a t i v e h e a t e r , remove a n d a d j u s t
\ 115.50
h e a t e r p r e s s u r e s u i t c h . I n s t a l l neu b r u s h e s i n h e a t e r
combustion b l o u e r m o t o r . R e p a i r b r o k e n h e a t e r d r a i n h o s e .
2.
C o r r o s i o n i n l e f t e l e c t r i c a l p a n e l , removed
and p a i n t e d .
3.
16.50
4.
Accomplish t h e f o l l t u i n g minor m a i n t e n a n c e :
39.60
A
8.
C.
0.
16.50
corrosion
5.
I n s t a l l neu b r a k e d i s c s and l i n i n g s .
158.40
6.
227.70
Total
1
4
1
2
1
\ 574.20
CFO-100 F i l t e r
387 Lamp e 1 . 7 9
l4P23-1 Cap
25164-14 Brush e 9 . 8 7
4596 L a m p
J u n e 2 6 , 1987
Navajo
U/O H8240
N27623
A508-28 L a m p
H i s c . H a r d u a r e a n d H y d r a u l ~ cF l u l d
Total
L e s s 10%
93.24
9.32
83.92
Total
F o l l o u i n g b r a k e r e p a i r p a r t s b i l l e d a t o u r c o s t p l u s 10%:
Total from above items
2
164-79 D i s c B r a k e @ 214.27
16
66-66 L i n i n g @ 1 0 . 0 0
1
751-898 S e a t
6
68-28 S h i m - b r a k e @ 1 6 . 8 6
Total
$ 775.20
Labor
Parts
7a r
$ 574.20
Total
$1430.36
775.20
00.96
(.-
-Haintenance:
,
'
- FPui leol :t S e r v i c e / f u e l / e t c . :
1 1 ,,142.0@
92 76 12 . 57 89
-Total:
(3,376.3
SHITH
Vice P r e s i d e n t and G e n e r a l Hanager
C.H.
C..
;.
:.:
.. .. . .
~, ~:
METROPOLITAN
10/19/2006
2-month pris
HEW YORI: - Forms,? E I r i
P ~ l c r r b u bu,,nermman
r~
Call E.
J ~ c o b ~ o n w ~ ~ r c n l c by
ncrn
era1 judge on ~uc.srlay t o two
monfhr in oris<>" fa" his
as
the "bsgnlan" in hrihlng a Navy
oll,",al Iorllrr drfrnsr controdr
to Unrlsd ChcmCon Corp and
I
I
I9
I
I
KATHERINE H .
EVERS
Plaintiff/s
v.
J . HERBERT FISHER, J R .
DONA LOU FISHER
and
Defendant/s
Docket No.
103 5
.I9 84
SUBPOENA
DUCES T E C U M
To
r. !
. .M
S. .t. a. . n. . . .C
. . .a. t. .e. .r. b
. .o
..n
. . .e
F i n a n c i a l Management G r o u p , L t d .
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
1755 Orenon P i k e
L a n c a s t e r , PA
..............................
J u l y at
1 5 , 1987
10
a .m
totestifyonbehalfofthe P l a i n t i f f
in the above case, and to remain there (or in such other Court Room
or location to which the case may be assigned) until excused.
2.
P l e a s e b r i n g w i t h you - a n y and a l l l o a n a p p l i c a t i o n s .
f i n a n c i a l s t a t e m e n t s , a s s e t s u m m a r i e s o r a n y o t h e r document a t i o n p r o v i d e d t o you by J. H e r b e r t F i s h e r , J r . a n d / o r
Dona Lou F i s h e r a n d / o r M a r t i n Y . S p o n a u g l e , E s q u i r e a n d / o r
F i s h e r - S p o n a u g l e I n v e s t m e n t Group. l t d . a n d / o r F i s h e r S p o n a u g l e R e a l t y Co. o r a n y o t h e r e n t i t i e s owned o r
c o n t r o l l e d b y J. H e r b e r t F i s h e r . J r . , Dona Lcu F i s h e r a n d /
o r Martin Y . Sponaugle.
3.
I n l i e u of a p p e a r i n g i n p e r s o n a t t h e s c h e d u l e d D e p o s i t i o n
d a t e , you may, i n l i e u of a p p e a r a n c e , make p h o t o c o p i e s o f
a l l r e q u e s t e d d o c u m e n t a t i o n a n d d e l i v e r i t by o n e week i n
a d v a n c e of t h e s c h e d u l e d D e p o s i t i o n d a t e t o t h e o f f i c e s o f
M i c h a e l H . Ranck. E s q u i r e o f Ranck & Ranck, P . C . , 1 0 1 E a s t
C h e s t n u t S t r e e t , L a n c a s t e r . PA 17603.
(SEAL OF
By the C o w ,
THE COURT)
M i c h a e l H. Ranck. E s q u i r e
.................. Par ..Ranc.k. . & Ranck .,... P.. C ................,
Attorne /s or P l a i n t i f f
E a s t C h e s t n u t S t r e e t . P.O.
Address:
L a n c a s t e r , PA 1 7 6 0 3
iOi
Box 1 5 2 4
If U.S.
witness16-4014
is to producc
daumcnlr.
cic.. addCLAIM
iddntionrl w m
r a p h rcrdiw
"2.646
And b r i q with you . . :'
EXHIBIT
CIVIL
RIGHTS
Page
209 of
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EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
\
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mltonm a m k
----
SERVING
Section 3189
Federal
False Claim Act
CENTRAL
PENNsYLvANtb
M E M B E R FDIC
STANLEY J CATERBONE
433 W MARICN ST
LANCASTER PA 1 7 6 0 3 - 3 4 1 6
1057
0002
D I R E C T I N Q U I R I E S TC
717-291-2591
0
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LAST PAGE
l FUND
ACCOUNT NO.
OESCRIPTION OF A C T I V I T Y
REFERENCE
9 9 0 0 - 6 9 4 .7 ~6
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----
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MEMBER FDIC
STANLEY J CATERBCNE
433 W MARIGN ST
LANCASTER PA 1 7 6 0 3 - 3 4 1 6
DIRECT I N Q U I R I E S TO
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Act
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433 W MARION ST
LANCASTER PA 1 7 6 0 3 - 3 4 1 6
DIRECT I N Q U I R I E S TC
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1 41,
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ACCOUNT
556-01 148
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
5.5'
5.5'
5 v O(
4.8'
Page 222 of 646
Page 2328 of 2953
B'hlton
- --
-------
CENTRAL PENNSYLVANIA
MEMBER F O C
MICHAEL CATERBONE
STAfuCEy J CATERBCNE
2 5 5 B U T L E R AVE
CANCASTER PA 176Cl-6308
1057
0'202
DIRECT I N Q U I R I E S To
717-291-2591
----
MICHAEL CATERBONE
STAhCEY J CATERBCNE
255 BUTLER AVE
LANCASTER PA 176C1-6308
OG02
1057
DIRECT INQUIRIES TO
717-291-2591
PAGE
A R CHECKING
ACCOUNT NO.
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0 O E P O S I T S AND
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CIJSTOVFR NUMBER
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PAGE
1
4-30-87
TO
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-----
..............................................................................
' P R E V I O U S BALANCE
. 01
NUYBERITOTAL CREDITS
NUNf3ERITr)TAL D E B I T S
FEES
NEW R 4 L A N
REGULAR C H E C K I N G
53.13
ENCLOSURES
0
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
6
PWNSIAPPOINTMENTS
I 1Z
RESULTSIEXPENSESIETC
--
- ---
- -
MESSAGES RECEIVED
-
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METROPOLITAN
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Commonwealt
National Bank''''
A Mellon Banku'""
July 6,
1987
Mr.
S t a n l e y J. C a t e r b o n e
2323 N e w D a n v i l l e P i k e
C o n e s t o g a , PA 17512
M r . S t a n l e y J. C a t e r b o n e
c/o F i n a n c i a l Management ~ r o u p , ~ t d .
1 7 5 5 Oregon P i k e
L a n c a s t e r , PA 1 7 6 0 1
I n Re:
1978 P i p e r A i r p l a n e
PA 31-325
M a n u f a c t u r e r s S e r i a l Number 31-7812065
S i m p l e I n t e r e s t A i r c r a f t R e t a i l I n s t a l l m e n t C o n t r a c t and
S e c u r i t y Agreement D a t e d J u n e 1 2 , 1 9 8 7
1201-5011006
Dear M r .
3
~.
Caterbone:
T h i s l e t t e r i s to a d v i s e you i n w r i t i n g t h a t o n J u l y 2 ,
1 9 8 7 , t h e Commonwealth N a t i o n a l Bank r e p o s s e s s e d y o u r 1 9 7 8 P i p e r
A i r p l a n e PA-31-325,
Mfg. S.N. 31-7812065, p u r s u a n t t o t h e terms
o f t h e "Simple I n t e r e s t A i r c r a f t R e t a i l I n s t a l l m e n t C o n t r a c t and
S e c u r i t y A g r e e m e n t " d a t e d J u n e 1 2 , 1987 ( r e f e r r e d t o h e r e i n a f t e r
a s " A g r e e m e n t " ) a s a r e s u l t of y o u r d e f a u l t u n d e r said A g r e e m e n t .
I t i s my u n d e r s t a n d i n g you a r e a w a r e o f t h e r e p o s s e s s i o n
p r i o r t o t h e r e c e l p r or t n l s l e t t e r .
-The d e f a u l t s u n d e r t h e Agreement which p r o m p t e d B a n k ' s
a c t i o n are a s f o l l o w s :
1.
a.
I n s u r i n g t h e p l a n e f o r t h e amount owed b y you w h i c h
i s s e c u r e d by a l i e n a g a i n s t t h e a i r p l a n e as r e q u i r e d under
Paragraph 7,
3
-
b.
Naming Bank a s l o s s p a y e e r e q u i r e d u n d e r P a r a g r a p h
7 , " A d d i t i o n a l P r o v i s i o n s " o f Agreement.
Property of Advance
Media Group National Bank. ContinentalPage
2341York.
of 2953
The Commonwealth
Square.
Pa. 17405
10/19/2006
$94,000.00
695 -28
15.60
Total
DST.
IS,
pmd+?
Larry W. Snyder
Manager
Consumer Loan Collections
LWS/mjb
cc:
INC.
HEMORAND UII
TO :
Stan Caterbone
FROM:
Kathy A . D i e h l
R e g i s t r a t i o n Administrator
DATE:
J u l y 8 , 1987
s e c u r i t i e s l i c e n s e w i t h The P l a n n e r ' s
P l e a s e b e a d v i s e d t h a t your
S e c u r i t i e s Group, I n c . h a s been t e r m i n a t e d e f f e c t i v e . J u l y 6 ,
1987.
P l e a s e r e t u r n t h e Compliance Manual which was a s s i g n e d t o you.
We wish you s u c c e s s i n your f u t u r e e n d e a v o r s and hope you w i l l
C.,
c a l l on u s i f we c a n b e o f f u r t h e r s e r v i c e t o you.
ACTIVBF$E%FOR
sun
on
SectionW
3189 Federal False Claim Act
Tues
lC8rcle Onel
Stanley J. Caterbone
Financial Management Group, Ltd.
Eden Park I1
1755 Oregon Pike
Lancaster PA 17601
Re:
Robert F. Kauffman
Financial Management Group, Ltd.
Eden Park I1
1755 Oregon Pike
Lancaster PA 17601
WILLIAM 0. UMIKER
TRUST AGREEMENT
('j
<~.
WILLIAM 0. UMIKER
COMMONWEAL~HOF-PENNSYLVANIA)
COUNTY OF LANCASTER
)
)
SS:
#*
A
(SEA
My Commission Expires:
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
J u l y 1 0 , 1987
S t a n l e y J. C a t e r b o n e
F i n a n c i a l Management Group, L t d .
Eden P a r k I1
1755 Oregon P i k e
L a n c a s t e r PA 17601
Re:
Robert F. Kauffman
F i n a n c i a l Management Group, Ltd.
Eden P a r k I1
1755 Oregon P i k e
L a n c a s t e r PA 17601
NORA A. UMIKER
TRUST AGREEMENT
Notice i s h e r e b y g i v e n t o you t h a t I h e r e b y c a n c e l T r u s t
Agreement d a t e d o c t o b e r 1 7 , 1986, o f which I , NORA A. UMIKER; w a s
S e t t l o r , and o f which S t a n l e y J. C a t e r b o n e was T r u s t e e and
Robert F. Kauffman was A l t e r n a t e T r u s t e e .
I w i l l b e c a l l i n g t o make a r r a n g e m e n t s t o r e t u r n any and
a l l a s s e t s i n your p o s s e s s i o n t o m e .
NORA A.
UMIKER
COIMONWEALTH OF PENNSYLVANIA)
)
COUNTY OF LANCASTER
ON THIS, t h e
SS:
day o f
1987, b e f o r e
(SEI
...
ROBERT 0. ACKERMAN
(312)433-4500
PLANNER'S SECURITIES
CONSULTING SERVICES
PTY.
~ ~ t ~ t f e e i s b a t e d o n t h e m a r k e t ~ ~ l o l u e
S I . ~ ~ ~ X K K ) C ~ M O ~ ~ ~ ~ V O ~ ~
.85%onnext
..
-75%on next
.65% on nad
-6% on next
s i m m o f ~orketva~ue' .
'
~1.OObXXKJ
0f;MarketWil~e
s l ~ I . l O O C 4MarketValue
R X B ) I ~ E m R T m l m
(~axabieor Non TcKable)
and
INVESTMENT MANAGER
Dataform
Name
.(
Address
i city/~tate/Zip
Ownership
VINELAND.
NEW JERSEY
e Feestructure
08360
800-257-7013
DONALD SULAM
SUZANNE GREENBERG
.JUNE 1 9 7 3
Date Founded
PARTNERSHIP
1 Affiliation
NONE
Minimum
Tax-Exempt
fi
c Account Size:
S100.000
Minimum
Fee:
Taxable
Tax-Exempt
$1.500
Taxable
z Manage:
Equity
Only
Telephone
Contact
Name
Contact
Name
Balanced
Acwunts
Corporate
Bond
Fixed
Cash
Income [ia Management (7 Other: MUNICIPAL BONDS
Government
International
Bond
(7 Cash IXI
Securities
(7
Futures
Options
Max Equity
CD' S
Other:
100 %
Min. Equity
- In-HouseCo-Mingled Funds: .
Active
Passive
NIA
Minimum Account
Size (specify):
Convertible Bonds
Government Bonds
INVESTMENT STYLE:
attach statement of investment philosophy and style for each type of management.
f
send a copy o f your current marketing piece, contract(s), ADV andfiscal report.
@ 1886 Richard SchlMMh h Awcdates. Ud.The lnlonnatbn providedhaiein la oblalned lrom the investment manager named herein
.ndPublkly lvailaMe .wroes and la bePsMd to be rdiaMe, bul ma mpwmbtlon or wananly is made w to ks accuracy or axnpleteness.
1 1 u v c 3I MEN I
US District Court For The Eastern District of Pennsylvana
MANAtikH
Dataform
Name
Swanson C a p i t a l Management
Telephone
Contact
Address
4 6 0 0 Fashion Square Blvd. ~ t 109
e
& 111 Name
Contact
Cit~/State/Zi~ Saginaw, M I 48608
Name
Ownership
Incorporated
Affiliation
Minimum
Account Size:
None
Fee Structure
1%F~~~~
Taxable
$100.000
Stephen Swanson
Tax-Exempt
$100,000
(517) 790-1291
Minimum
Fee:
Tax-Exempt
$1,000
Taxable
$1,000
In-HouseCo-Mingled Funds: 0
.
Special Services (check one):
Active
El
Municipal Bonds
El
rn
rn
rn
Convertible Bonds
Government Bonds
Minimum Account
Size (specify):
Convertible Preferreds
NIA
Passive
INVESTMENT STYLE:
Please a m h statement of investment philosophy and sty* for each
of manawment.
i nt"fe rend a m p y of your current marketing piece, wntract(s), ADV and f seal report.
d
01 s f l l c h d SChlmMh I ate^, M.Th. lnform6lbnpmvldad IwreIn b obtained fmm the inwamdnt mamger named herem
~ ~ ~ n W * ~ . . ~ b b e ~ t ~ b e r e ~ s b l e ~ b u l m ~ t l o n o r w ~ ~ k m & ~ t o ~ t s - ~ o r a m
Dataform
(818) 247-5330
Telephone
(213) 245- 7 4 6 1
Contact
Name
Richard A. Snyders
Contact
1 Name
Name
cin//State/zip
Ownership
Date Founded
Affiliation
Minimum
~ c c o u nSize:
t
Tax-Exempt
Taxable
$100,000
$100,000
1969
Minimum
Tax-Exempt
(annual) $2.000
Fee:
Taxable
$2,000
Equity
Only
Balanced
Accounts
Corporate
Bond
Fixed
Cash
Income
Management
Other:
Government
International
Bond
Cash [XI
Securities
Futures
Options
Max Equity
Other:
%
Min. Equity
none
none
Active
Passive
N/A
Minimum Account
Size (specify):
I3
[7
Municipal Bonds
Ed
I3
0
0
rn
Convertible Bonds
El
Ed
Government Bonds
INVESTMENT STYLE:
ease attach statement of investment philosophy and style for ewh type of management.
M a copy of your current marketing piece, contractls), ADV and fiscal report.
a-
10/19/2006
Id
~1enda.k.California 9120)
(213) 247-5330/24;
Investment Counsel
FEE SCHEDULE
Fees are charged QUARTERLY in advance using the following
W A L formula:
Portfolio
Value
Fee as a % of
portfolio Value
First
$100,000
2%
Next
$200,000
1%
Next
$200,000
3/4 9
Amounts
Over
$500,000
2/39
Examples of V A L Fees:
Portfolio
Value
I
I
I
i
Fee as a % of
portfolio Value
Annual
Fee
750,000
7,167
0.96
1,000,000
8,833
0.88
2,000,000
15,500
0.78
3,500,000
25,500
0.73
5,000,000
35,500
0.71
II
I
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! .
... . _...
STATEMENTS O F A S S E T S AND L I A B I L I T I E S
ASSETS:
111,304,255
116,450,421
24,250,255
13,163,605
15,432,951
15,944,284
(7,778,196)
(2,520,983)
28,780
16,695
$143,238,045
$143,054,022
'
INVESTMENT INCOME:
Interest
Dividends
Less investment advisory
fees
Net investment income
REALIZED AND UNREALIZED GAINS
ON INVESTMENTS r
Realized.gain from security
transactions (exclusive
of short-term investments)~
Proceeds from sales
C o s t of securities.aold
Net realized gain
46,156,866
32,383,816
35,070,216
29,263,026
11,086,650'
3,120,790
15,432,951
15,944,284
Unrealized appreciation
of investments:
Beginning of year
End of year
(Decrease) increase in
unrealized appreciation
Net realized and unrealized
gains on investments
(511,333)'
13,715,308
$10,575,317
$l6,896,09B
..:..-:.
-.:.\
;i;\:2:<z,:,
12,304,002
1S,040,381
(22,707,381)
(15,047,521
(10,403,379)
(7,13
184,023
16,903,83
$1431238,045
$143,054,02
NET ASSETS:
Beginning of year
End of year
2.
Investments:
A summary o f
i n v e s t m e n t s is a s f o l l o w s :
/
.
i
:
..-.
4,427,800
35,103,995
$
4,427,800
5,774,937
Value
Cost
6,399,600
39,445,939
5,049,732
_ _ _-
Value
Cost
/,
.:
.. .
6,399,t
34,665,221
37,598,:
9,738,720
$ 10,341,'
55,056,018
65,421,820
49,214,679
61,623,t
26,536,945
26,536,945
25,454,347
25,454,
Continued
6
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
Famh
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Lender liability uses traditional cion, bad faith, breaCh of fiduciary
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Herbert Hunt,
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charge that
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3757 F2d 752 (1985. CA6 Tcnn).
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10/19/2006
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encouraged by the bank to make terrain busi-
Duress
'UCC I-ZOI(19).
Lancarter, P A 1 7 6 0 1
800-312-1128 (PA only,
(..ROBERT E. KAUFFMAN
PRESIDENT
Millard Johnson
3450 Duff Avenue
T-z?c=+tol
PA
17601
r,
w
Rcbert E. X a u f m .
President
Reglncrcd BrokerlDealer
EXHIBIT U.S. 16-4014 CIVIL RIGHTSA CLAIM
Page 263 of Member
646 SlPC
Member NASD
Thursday
die
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ld
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$
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frad
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p.
his"phltoUle1unds.
They areehargLog.mlClar(iis
nOtenUUedtoUammey h e c a w
he sllegodlr used extortim and
Jacobson's sentenc
btrastanwriiW
OaugWendrh
eu
Farmcr Cnned C h e m ~ o n
~ i e r l d e nJaines
l
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scerrlng a six-year prlron ir.im
tordcrraudinethrgoremment
Of115 nliuion. rearlrd uatl,da~
belief and anger today upon
haar8nCthrl Carl E ~ a e ~
had r e c e i v d s ix*s,"nth
!,llhrsnddav'
,
i..
Lancaster, PA 17601
.,
... .
Thursday
December 15, 2016
7 2'r-J
10/19/2006
STANLEY CATERBONE
Eden Park 11, 1755 Oregon Pike
569-4100
Lancaster, PA 17601
6c
MR. S T A N L E Y J (:A'TE:Iy<T:ONE
C/O F M G ACCOUNTING S E R V I C E S
1755 O R E G O N P I K F
LANCASTERt P A 17601.
STATEMENT +
009246
US. W I L L I A M h BETTY O'HARA
S U M M F F ; Y
T h i s s u m m a r y includes a l l t r a n s a c t i ~ n sup t o and including
t h e month end preceding t h i s statement.
Any c r e d i t s or r e c e i p t s
processed a f t e r that d a t e may nut he included and w i L L b e
reflected o n your next statement.
' C)
'
Less: fieta i n e r s
B A L A N C E
Fees for this b i l l
3 0
T o t a l a m o u n t of
New Balance Forward
t h i s bi L L
T O T A L B A L A N C E NOW D U E x - r x * x * a a x w x x u u x x x x
MR. S T A N L E Y J (:A'TE:Iy<T:ONE
C/O F M G ACCOUNTING S E R V I C E S
1755 O R E G O N P I K F
LANCASTERt P A 17601.
STATEMENT +
009246
US. W I L L I A M h BETTY O'HARA
S U M M F F ; Y
T h i s s u m m a r y includes a l l t r a n s a c t i ~ n sup t o and including
t h e month end preceding t h i s statement.
Any c r e d i t s or r e c e i p t s
processed a f t e r that d a t e may nut he included and w i L L b e
reflected o n your next statement.
' C)
'
Less: fieta i n e r s
B A L A N C E
Fees for this b i l l
3 0
T o t a l a m o u n t of
New Balance Forward
t h i s bi L L
T O T A L B A L A N C E NOW D U E x - r x * x * a a x w x x u u x x x x
ACTIVITIES FOR
Thur
Fri
sat
T ~ m eEsriActual
TS4101
185
h 8 ADqebSr
QL 90067
FEB 1
::mA~.Culcrr'b
SEE REVERSE
SIDE FOR
INSTRUCTIONS
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Full name a e g l s t r a n t
ZIPCode
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Name(~)
90038
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City
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Zip Code
1137
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THE L16-4014
m ANGELES
DAILY
Y)URI\IAL
EXHIBIT U.S.
CIVIL
RIGHTS
CLAIM
c.uus+n(
,am
Property of
,=
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. . . . . . .-.
-", I
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Corporation Name
7-
6. New Fict~tiousBusineu
Name Statement
c,N~v(
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Signed
,F
~~~
Zip Code
c-
......... ,_.__-....
Y)URNAL
OF COMMERCE
- REVIEW
Thursday
December
15, 2016
**-.I.
210 h
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10/19/2006
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Court
.*klUS
I- District
Lnr.
,0, For The Eastern District of Pennsylvana
. .
Your riot nam. and l n a t ~ a(if
l loon1 mum. d s a Or* spouse'. turn wd InlUaO
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this lorm with the lntsrnal Rsvenue Service Cnter.wnere you m r t flle y o u r i w n m tir return ;nd;p'.y
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line 6 be:@w.Thls is not an eltenslon of Unw lor payment of tar. Tke k w mqalra that'e pen& beth.f#ed f or late. w$m#IIt
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tar and idle lil~npunless you show relaonible cause for not payon. the tax when due (see 4nstructlonO);,
r1.m .swt to 11Ia a 1981 plt 114 ralurn (form 709) due p h d n a t)r clow of Uw W h dwda awmc of 19ll.chclchnba8 0.
HQbl: file
Ol
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an autornatoc 2.rnontlj eltensoon 01 tln~e'untllJune.15. 1SZ. In whlch
to file F o m 1040 for tho-lender
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w hwal year return until .................... 1................-.- L
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fw th. .tar. year beginning
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and ending ............................................... 19........)<
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;l Total income tar liability for 1981 (You n). e s t i ~ t thla
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I, Mot.: YOU must enter an amount on line
If p. . u do not *Ip.Ct to 0"
enter zero (0).
.
B Federal Income tax withheld
,
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........... .......
,bawd u icredit).
. .
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,r Total gift tax you expect to owe for 1981 (w inshuctian E).Notc This i s the amount you oxput to gw
r for the giit tax return due following the cJow ot me tounh uI*nd.r q u e r h r d 1981
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IfPrepared by Someone Other Than ~w:&Und.rp.d.y,a of pwfuy, I
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rrwnpanying schedules and statemants and to Ui. best of my I&i n d bollof. .kbtiuq- ai+,. .dd
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1 A panon anmlled to practlce beforethe Internal Revenue S.rvlu.
nl h authorized agent holding' a power of .ttorn+. (YOUn w d not u n d in the power of ~ m o unhss
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requv.)
1 A penon in close personal br bu.slnau rektion~hlptq Uu bxpem annot ilgn.pilstormkcaliq of l l t n . 4 ' i ) b l r ~
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BROUT&
COMPANY
CERTICIED PUBLIC A C C O U N T A N T S
v E r 10'1
. LOS A N G Z L E S
W O R m l S V O l N . N d.
1900 A V E N U E O F T H E S T A R S
LOF. A N G E L E S .
213
Dear
7-i 3
CAL~FORN~A
90087
553-1941
'
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@A
9 /YO(
The d u p l i c a t e c o p y i s f o r y o u r f i l e .
Very t r u l y y o u r s ,
BROUT h COMPANY
Enclosures
1115 A T L A N K A M M
s u m 511
cw
ATLAN~Ccm. NJ
MP-Hid539
COUNSELLORS AT LAU1
Ym PAClRC AVUIUt
. N1 O
B
m
MP.7IP-IlIl
IN REPLY REFER TO
Northfield
87/346-001
NLN
July 20, 1 9 8 7
Stanley J. Caterbone
554 Berkeley Road
Stone Harbor, NJ 0 8 2 4 7
Re:
Caterbone
O'Hara
~ l e ~ sfind
e
enclosed our July 17, 1 9 8 7 bill in the above
matter in the amount of $206.25 for services rendered from June 9
through June 16, 1987.
As you can see from the summary statement
attached to the front of the bill, we have deducted this amount
from the $500.00 retainer, leaving a credit balance of $293.75'
against which subsequent fees will be charged.
If you have any questions concerning the enclosed, please do
not hesitate to contact me.
LJS:rlh
Enclosure
36 E A S T I(INC. STREET
LANCASTER. PENNSYLVANIA 1 7 6 0 2
TELEPHONE 17171 3 9 7 - 3 7 9 1
JOSEPH F R O D *
PAUL 5.R O M A N O
Joseph F. Roda
JFR: dlb
Enc.
J u l y 22, 1987
CATERBONE
Attorney
JFR
JFR
JFR
Description
H ours
-
C o n f e r e n c e s w i t h S. C a t e r b o n e ;
telephone c a l l f r o m J .
Jamouneau, E s q . ; l e t t e r t o
R. K a u f m a n .
3.1
Telephone c a l l s t o and f r o m S .
C a t e r b o n e and f r o m R . K a u f f m a n .
-4
L e t t e r f r o m R. K a u f f m a n .
.1
JOSEPH
F. RODA. P.C.
3 0 1 C I P H E R B U I L O I N G 36 E K l N G STREET
LANCASTER PENNSYLVANIA 1 7 6 0 2
I
CATERBONE
$74.48
1.00
July 2 3 , 1987
As
We have excercised our rights under the the terms of the lease, Paragraph
No. 17, and effective July 16, we reclassified the lease into a default
category and have repossessed all of the remaining equipment from the offices
of the Financial Management Group.
For you to satisfy your obligations to DaLa Company and to allow us to return
the computer to you we will require full settlement of the outstanding balance
on the lease. This amount is $1,939.52 plus the balance owed on the repair
service of $524.04, for a total of $2,463.52, payable imnediately to us
by cashiers check of money order.
If we do not have settlement of the lease by August 1, 1987 we will proceed
to sell the s y s t ~iii order to recoup what ever funds are owed on the system.
Should we fail to recover the full amount owed, we would need to look to
you to settle any remaining balance due.
In my discussion with you today, I informed you of an offer received from
one of our suppliers for the computer system listed on the lease. Their
offer is in the amount of $1,500.00, which represents 35% of the original
cost.
You verbally authorized me to proceed with the sale, stating you have no
interest in having the computer back and indicated your written authorization
for the sale will be mailed to me today.
Accordingly, I will implement the sale for the $1,500.00, and satisfy the repair
bill at Dunlap and Kerst. You will find enclosed our invoice in the anount of
$963.52 representing the balance owed to satisfy your obligation to DaLa Co.
Please feel free to call if you have any questions in this regard.
Sincerely,
baul ~erstine
General Manager
PD:em
Enclosure
WAMCMC".
G..O",
,,o
STANLEY J. CATERBONE
EXECUTIVE VICE PRESIDENT
Stone Hartwr, NJ
( W )%7-5184
08247
J u l y 24, 1987
J i m Bly
Sourcz C a p i t a l
6725 (Xlrran Street
W e a n , VA
22101
. .
Dear J i m :
Enclosed is t h e p a c k * f o r t h e Real E s t a t e Deal as per o u r
c o n v e r s a t i o n . Plg i v e me your response as to a n i n d i c a t i o n of i n t e r e s t as
= a n as p o s s i b l e so t h a t I may c o n t a c t someone else if you are n o t i n t e r e s t e d .
I a p p r e c i a t e your t i m e and c o n s i d e r a t i o n .
Zk
ley J. catertxre
10/19/2006
I.
Scope of B u s i n e s s
IV.
V.
Costs
C a p i t a l , I n v e s t o r / I n v e s t o r s , and Bennet
of S y n d i c a t i o n - Bennett W i l l i m F i n a n c i a l Center
Financial Projections
sWswpE..a...~~-~.~.s2
.
.
is a
follwing
The
,
syndication
and
Im.
The
of
to
Bennett
Williams,
Im.
to provide
the
i n downtown York,
function
pr-1
PA.
Swrce Capital
of the p r o j e c t is to r a i r e the ~
plm
million
(excluding
it
entirety
until
will
be
funded
will
provide
is
15%w i t h
year i n order to
R1G w i l l
which
e x i s t s i n Lamaster.
responsible
for
the
1-
up,
f%2 w i l l
a).
Development
The G.P.
will be r-nsible
involved in t k project.
b).
c).
The
will also be
responsible for determining the fair market value of the =paand for attracting attractive t e ~ n t s
with favorable leasing
agreements to maintain a favorable and healthy cash flow.
d).
Management
- The G.P.
LL W L I C N E ~.%...%!?IT.K
MG, Ltd. w i l l be r e q x n s l b l e f o r the follcwing services and factors:
a).
b).
c).
Marketing
- The Syndicator
d).
The
The
Partnership
Private
is a c k s c r ~ p t i o nof the s t r u c t u r e of t k p a r t n e r s h i p .
follcwing
The
will
be
Pla-nt
T k
-lation
T h i s w i l l l i m i t t h e rxlrrber
of u m c c r e d i t e d i n v e s t o r s t o 35.
. .
Eqity:
20% of P a r t n e r s h i p sale d i s t r i b u t i o n s
Incane:
15%of Net c a s h f l o w d i s t r i b u t i o n s
Souroe C a p i w - Marketing F e e s
Eqity:
5% of P a r t n e r s h i p =le proceeds.
Incane:
@ of N e t c a s h flow d i s t r i b u t i o n s
Eqlity:
75%
I m :
85%
Load :
of Net P r c c e d s
in
This
order to perform
Bennett-Williams will receive a 3%G.P. developnent fee for pltting the project
together (building design, construction %pervision
The
.
Broker/Dealer
(if
...etc.).
registration
partnership.
and
j' iltilding
of the partmrship.
FiMnCial
Center
has
M a ~ m n t . Grcup,
to
similar
MG
d e v e l q x d a F u l l Service F i m w i a l C e n t e r t h a t p r o v i d e s a l l of the r e l a t i v e
services
re=essary to
and institutions.
mamge t h e f i ~ n c i a affairs
l
of i n d i v i d a l s , b u s i n e s s e s
1. F i r e n c i a 1 Planning
Finamial
the
2.
3.
k c c u n t i n g and Tax P r e p a r a t i o n
4.
Real E s t a t e Services
5.
Legal Servioes
6.
I ~ r a r c Services
e
7.
Managewnt
Lamaster
role i n
the
that
been
pt
LTD
with
the
and
structured
~ and nMortgage
t
Banking
Group,
location
recruiting
Pave
managerent
dweloped
the
of
and
-ration
used
in
Ft% w i l l p r o v i d e the
and w i l l u s e t h e w r r e n t s y s m
Lancaster.
The
ownership w i l l be
involved.
Enclw_sd is a n o r i g i ~ Busil
P l a n t h a t o u t l i n e s tk c o n c e p t
i n more detail.
following
The
of
i n t e r e s t to s i g n lorg term 1-
this
will
the
be
premier
agreements f o r -ace.
office
q ~ c elocated
P l e a s e be aware t h a t
be
rented
for
$30.00
Parking spa-
c o n s i d e r i n 3 the convienewe.
Bennet
Williams
agreemenb.
and
will
occupy
25%
of
the
space
a t market v a l u e lease
Cum-ican Erpress
York Bank
7 . W Sq. F t .
10,000
"
FIcrxrunting Firm
5,000
"
wraisal Firm
1,1333
"
Bennet ~ i l l i a m s
8,000
Total
3 1 , 5 0 Square F e e t
'
WSH FLOW
WRD COSTS
WISITImi
CCNSTRUCTIa'l
4% CONTINGENCY FEE
$1.960,00CI.O(i
$310,000
TClrPL INCOME
$402,800
$54,003
$38,800
SOFT COSTS
DES1Q.I
FuWISHINGlj
F I W I f f i FEES
TOTAL COSTS
$ 1 ~ , 0 ~ k l . ~
$m,oi3o.ix
15
$Z,~~R,GXJ.IX)
C ; W ON CAW RETURN
$ZB,KKl.Oi,
,,,,,,,,
. ....
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CBrl L J D C O b I o
minimam-rccurlly
nrlran filr
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ir
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j.l,ilC
,illling
5%-11,
to the jtldvo by Edward .I.
ild'Ls
0970s DhYIO)
Dorrlns along s ~ o . n l sin bilhr
rjlil.,iry
tu i~cfr.i,.j
11111
t ~ ~ e , , , , , e ~ , t , ~ , , , ~ ~ t , ~ ~ ~ , ~ , l ,~t ~, , ~, , ~~ ~, , n, bc r , t h c f ~ ~ m e r s u'"c1'e"'~c""""d"'hL'rn"4""k'"~
w r v ~ sl l ~r rirarllcipalrtl
~f
1urCI.b
in
thr
US
District
For The
Eastern
3189 Federal False Claim Act
tnuncv
in a Court
Kav? nll8clal
vlhu
$01-c ~District
~ C ~ ~ I I lilx
Sof
V Pennsylvana
rlifttmh. lie
,'
f h r 1 . m c a s t ~ r Taunts D f l i c ~an1Section
brlllr ,rhumc.scrurdlng,ocuur,
sr;,rr
,,r,n,,
a
,,cc,,rd,nE
uuur, dor,,,,,cn,p
i)r,'ll,nl8on and 1'rrolc"s intcnsivr ,~,,r,~nlcr,t,.
to rccovri
$0" rrrrlrcd :xlx~wt I I
~ ~ r o m , s eLO
d sterr cnntrnrtr to foccii ilrc
chemcon.
82i0,no"ri.~.
\v~,.~,
~n,bl.'ll"n rnunifllns ~ m ~ r r maneiourd
m
hlmbY H
~
ca*h
~
ilnd ~chctki ~l r o , , ~
For the Wcdlccll ~ h i l r ~ in
c
.Inmbn,n, h # w e v e r ,won f.tvnr son wrs ln i.nllr rb,cn(l,rgo,rm.
f"'lulcnll*s.
aflicmlr frnlli ji,,i loI:,
w h ~ he
h was the mtdlt~eman'ror frmxn ~ I ~ O ~ ~ . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ C X ~ I rncllt
The i l l y m r n f s I m m llnlted he~u,n,dou,r,,ltn
,n,r
to berue 11im
I I I I I I I \\,as
I I S trY,'a
r Ills
o
a n .whu has
r efsmtiy
n
11\,1ng Chrm.an
Rsmircl tuut ,,lace
a 8115.WO bnbe. Jacobson re- I ~ I I ~ c ~ ~ ~ ~ ~ c c I I ~ * ~~ l~i l ~: l ~Cr i~l ~~d .i iIl l~~ ~I iCl hOp ~~c ~~ iIw
. .I~
~s~l h
~b r brother
nn ~
the
Jauobrun IS ,,nr or I
CeIved a three-year nvrpendcd u~sligallo!mb. as well i s lhr ear19*, arrord,,,g
Thc fnn:mmrnt lovnd aul he i;wm in C h e s l ~ r N.J
.
, has k n
reconlr,rlthetrmeChcm.
c h u g c d ~ n i h riim,ill,
sentenceandpmbat~an.
i u n l inverlirdllun into Cllfnn m r i n c h d r and rr8iI lllr rubgl8c,
vying to get a cnn,racl
Can lraud m d hr\k,r?
Leisure ordrred lacubson la and lnlcrnati<,#talSlsnal L Con- #i:l LC, ihc l i S c m b r s a ~tllcrc. rollnsellltc youths at a p m g ~ a m ,c
managed bv Hafner and helpine worfh *but mllliun
1ncIud1ns lormrr C ,
turn hlmwlfino"lunc2iUUstt",
troi timup
J~aroliisnu'ar s r r i c d wilh the out at a YMC.4 program in YorLhaprioon k r m .
N~,,~..~~~~~~,,~..
"lbc rllnllgcll 1xHn1 in h l i s u i l y l l m a n l l a r iorlrle h i s ilsCosnty.N.J.
p r c siI
d hrvcpirudud
e n l J r m r r H Chr
far.
gui
Jacobam. 47,- a thebrotherin- Jaeohran'slaror is chat l m n i (he Dasswrt m d irylng to gut a ,sew
Goidberg called Jecobsm a
b LheUredtcrh scheme. ~ s m b hauek~nrenfeneed.
,,
.
~,B,,>~
,,
cl,,,~
,,,
FBI accl
.......-
I Christian angered I
""...*.
wifl
be~nealonc.!heagcnfcontinued.
The rgenl srld Michael D.
Spangler, m ISC public relstiona
manager, mrlld c i a r k saying
that if ISC'5 mergcr partner in
Enyland ,'*new the true finan"La1 picture of ISC. they'd all bc
I","#I
"
M.urr*t*rr.a*
lro
Oblenders
37 South @leenStreet
-,
PA 17603
Dear Sir:
a t Financial Management Group Ltd. (Fm; Ltd.) want to inform you that
Stanley J. Caterbone is no longer an officer of our corpration.
We
lhis letter senres notice that Stanley J. Caterbone nwer has had the right to:
1) Furdnse i t e n s for or thraqh FIG.
2 ) Make C o m b ammlim behalf of FM;.
3) Contract for or in any way obligate Fm; W.
and that we are laat ?xspmsible for any debts, liabilities or obligations which
may arise f m or thmugh him.
If you have any questions, please call Michael Iiartlett or Rcbert Kauffman a t
717-569-5555.
?hank you for your w
r
t of
Ltd.
prosperous kusiness relationship w i t h yau.
We
look
forward to a l q and
A R.p-
M r lPage
D . .2398
h of . 2953
rYrmb.r
S I K
M-b..
NASD
10/19/2006
K L SHIRK.SR (1915-1956
A T T O R N E Y 5 AT L A W
PRINCIPAL OFFICE
P 0 B O X 1552
LANCASTER,
WILLIAM J PELHAN
BARBARA RElST DILLON
PENNSYLVANIA17603-1552
August 5 , 1987
S t a n l e y J. C a t e r b o n e
554 B e r k l e y Road
S t o n e Harbor N J 08247
Mr.
Dear S t a n :
I was v e r y s o r r y t o h e a r of your m i s f o r t u n e when w e spoke
today.
C e r t a i n l y , you a r e w i s e t o o b t a i n c o m p e t e n t , r e l i a b l e l e g a l
c o u n s e l who w i l l g u i d e you w e l l , n o t o n l y l e g a l l y , b u t e t h i c a l l y .
I a m e n c l o s i n g , i n a c c o r d a n c e w i t h your r e q u e s t , a p a c k e t
(of A l l - S t a t e L e g a l Supply Co.) which c o n t a i n s t h e V o l u n t a r y P e t i t i o n i n Bankruptcy ( C h a p t e r 7 ) and a l l accompanying forms which are
n e c e s s a r y t o p r o c e s s s u c h a n i n d i v i d u a l , bankruptcy.
OTHER OFFICES
107 WEST MAIN STREET
EPHRATA. PENNSYLVANIA 17522-2014
717-733-2588
717-626-2404
EXHIBIT
U.S. 16-4014
CIVIL RIGHTS
CLAIM
.10/19/2006
? 3 1
'
I:
By:
FAX: 0 1 1 8 1 ~ 5 5 0
Dear B i l l :
If you no of anyover there that would l i k e a great i n v e s t m n t i n
real estate, I am i n desperate need of fur& for a Prime p i e c e of Real Estate
i n the Heart of I - b l l ~ The
.
-r
of Gomillion Studios, of which I am
Executive V i c e P r e s i b n t . The Film and Sound Studio is doing f i n e , kaever he
was i n the middle of r a i s i n g 6 m i l l i o n dollars by way of a Bond Offering,
ha*rever
the I-bent
Firm was caught i n a Scardal, which sears l i k e a n
everyday occurram. H e rmst declare p e r m 1 Barcruptcy by -st
6 t h unless
he can f i n d $200,000. He owns the R e a l Estate p e r s o ~ l l yand r e n t s it to the
Film Studio. The R e a l Estate ard all E ~ i p n e n tis worth o v e r 6.6 m i l l i o n
Dollars. He was paying $300.aX)per year i n Rent. I c a n worU a very
attractive deal f o r Ior E ~ i t iyf i n t e r e s t e d . Enclosed are sune piof i n f o m t i o n .
Thanks f o r ycur a x s i d e r a t i o n .
I
cc: T. G a n i l l i o n
Commonwealt
National Bank
August 7, 1987
Mr. S t a n l e y C a t e r b o n e
554 B e r k e l e y Road
S t o n e H a r b o r , N.J. 08247
Dear Mr. C a t e r b o n e :
M r . S i e g e l h a s r e v i e w e d w i t h me t h e s u b s t a n c e o f h i s t e l e p h o n e c o n v e r s a t i o n
w i t h you oii August 5 , i927, and has askei me Zo r e s p o n d t o you d i r e c t l y .
A s a r e s u l t o f t h e c o n c e r n s which you e x p r e s s e d , w e have a g a i n r e v i e w e d
t h e f a c t u a l background o f t h e s i t u a t i o n which r e s u l t e d i n t h e bank
r e p o s s e s s i n g your a i r p l a n e on J u l y 2 , 1987. You are a d v i s e d t h a t , g i v e n
t h e c i r c u m s t a n c e s , w e are s a t i s f i e d t h a t t h e r e p o s s e s s i o n was b o t h l a w f u l
and a p p r o p r i a t e . T h e r e f o r e , we are n o t i n c l i n e d t o a c c e p t y o u r s e t t l e m e n t
demand o f $5 m i l l i o n which you communicated t o Mr. S i e g e l .
Vice P r e s i d e n t
cc:
J a c k F. Ream, Esq.
I r w i n H. S i e g e l
The Commonwealth
Pa. 17603
Property of Advance
Media Group National Bank, 28 Venn square;
Page Lancarter.
2402 of 2953
10/19/2006
MINNESOTA
MULTIPHASIC
PERSONALITY
INVENTOR'
US District Court For The Eastern District
of Pennsylvana
Section 3189 Federal
False Claim Act
S.R. Hathaway and J.C. McKinley
-=-
J / / ,7
.,
The invento~ycantained in this booklet has been designed for use with the Group Form answer sheets
distributed and authorized by National Computer Systems If other answer forms are used. National Computer
Systems takes no responsibility for the meaningfulness of scores
0
I
'i)
4 4
C,
/'
/-
- \
/j/
3
.
)(
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fi
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/C
/
\
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&
40. Most any time I would rather sit a d dayaream than t o do anything else.
Go on to next page
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM Page 299 of 646
Property of Advance Media Group
couldn't "get go
nig
..
.-
.c
49. It would be
thrown away.
L Ce
W
seem to
health as most
/C
c?
&w
51. 1 am in just as
(
,. ~ .
of my friends.
ttracted by members of
1.7
-
i'
k-
palns over
p
'
\
/
57. 1 am a good mixer./\
/
)
f-
<
Go on to next page
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
//
>,
..
.. >. .... .
..
(I;
88.
cross.
yI d 9
/
1 usually feel that life is worth while. \
tomorrow
2 . I would like to be a n u s
0
..
. ....
:i
*-
do some-
>
/P"
116. 1 enjoy a ra
on it.
-r'
sent to thc
Go on t o next pagl
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
P
: 7/h-wsor ,
:
Tifib
'i=
223. 1 very much like huntin
7
like to flifl. f
-p
at night.
?m
f=
P
P
e particularly to see
&I$
F=
<
T?P
3.
Ci
IAJ (
F-
Go on to next page
10/19/2006
worry.
not going
7"
I
-i
I am so crossand
'p
bad.
auite reaularlv
-
&
(-
[/
1 have to urinate no more often than ottiers. 4
an alcoholic drink.
portment were
grouchy.
of a ciowd.l(
wina p c ~ s o m e o n who
e has opposed
me.
starting or holding
my urine.
(-1
--
an ignorant belief.
all).
555. 1 sometimes
to pieces.
that I am about to go
"Oman.'
P
pried
stories.
when I am o n a
by forgetting where I
/
1
W*W,II
YIUS,*I*I
ROBERT E. KAUFFMAN
PRESIDENT
Mr. stanley C
554 BerEley
Stone
mad
New Jersey
08247
note offer-
to sell shares or
-,
2.
We w i l l
3.
4.
m
y
, you feel strongly abcut yrur debt to B i l l Johnson
a d want it to be paid. So do we. You also have several
other d t o r s who we wculd like to see paid. To be sure
that they are paFd, we will dsdud their paynent f m m any
pmcsds.
A t t a w you will f i r d a l i s t t h a t w e n a ~ h o u
abart.
As for the price of the &xk, we are willing to pay $2.50 per
share for 40,000 shares and $5.00 per share for y a r 400 shares or
$102,000 less debts* lhat is what we are w i l l *
to pay this W!
I~ the future,
1.
m
' e build up of any debt,
2.
its value
3.
Dur time
penaingbjnlauptcy
your
Please Sr aa~ised.+
&
t
tm this p i n t we have tried to urderstand
cirumstances, W i v e s an3 corditions to your actions.
In Lne
flhlre, we w i l l not be unjersming.
prepsred to pursue
We
enkezzlemnt
(we
crimiral
for
attempted
,theft
'
~ d'~&Yye
~ i t ~ j ~ ~a~
J qige~ ~
s x 1 s oterm,
n
E!e aadvised that Ure
sli&test p r u v m t i o n of m l r m q n r a t l n n will result in tho filinj of
the &bVe mfs,
'&e filiny o f Chargffi ha^ rmthirq tn dn with this
negotiation.
It has to do with amtinued kritten ard v-1
assault lfeon cur ffm.
w a n t l y ,
$55,000
for ycur s M c
a1 1 cmlitors are paid. You, or course, have the
option to hold your stock hlefinitely, offer it to us at a later
time or
R 131tlmrepmsentative offer it ta us. It is up to
ym. YOU have rn best offer.
me Board of
DinXtom
ROBERT
E. KAUFFMAN
PRESIDENT
M r . Stanley J. Qterimne
554 *?Hey RCx5.1
Stone Harbor, New Jersey 08247
Dear Stan:
your
R.E.
Kauffman
10/19/2006
< -
.\ , .1 - -
c,,sroMEn
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- ,-;,:
(609) 652-5888
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C.O.D.
OCHARGESO M O S E .R E T O .
I
YON.
DESCRIPTION
OF WORK
TUES:
WED.
THURS.
FRI.
SAT.
SUN:
TOTAL
MATERIAL
SALES T A X
TOTAL
I
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SIGNED
-NT
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--. ., , i l,?:c!ry g;ant:;! f c i such eatme men! ar:d prc ed2res.
;:,,rranz! ph:.sici:n
is t o bp selerlp~ t or o n l;r!:-!' :.' 11%- p l r i r t : :..
. ..-;- - :'
TI;,
<,-rs,q:?;!
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0 CHF
0 Diabetes
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Ei E P ~ ~ ~ P S V
M.I.
0 Pulma>ary Condation
J
Medical
0Trauma
0 Psycho Service
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rJ
Notification
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Orher
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Family
Social Service
0I V
0 Monitor
OD
Police
0
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Clergy
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A""eb
nMental Health
-
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Backboard
Phila. Collar
~ ~ ~ ~ l s
Prerrure Orerring
OBJECTIVE
ASSESSMENT
I NURSING DIAGNOSIS
/'&- li q
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SPECIAL PROCEDURES
0Ace Applied
C3 u?.
0 Lab Stix
0 Irrigations
0 Ice Applied
0Dressing Applied
Cervical Collar
L A B WORK
0 Urine
Bld
Hct
Hgb-
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rot
Ph
0Cap GI"
OCul~re
DISCHARGE PLANNING
0Smial Service
0Cart Care
0 Wound Care
0 Head Trauma
X43AYS
nER Inrt.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM Page 312 of 646
Property of Advance Media Group
10/19/2006
1. ;:-zc:rmce
a.
and Behavior
Thin, (herweight,
Pnysical Characteristics:
2
Other:
Dress/Graxing:
b.
ticulous, Disheveled,
Ina$propriate/bizarrz.
Other:
c.
b a t o r Activity:
L*,
Other :
Facies:
d.
Facial Eqression:
Other:
e
Contact:
0
Mobile
Futed, Blank
.:
@,Avoided.
SiarUg.
Other:
c. A t t i t u d e ! b w a d Examiner:
Cooperative,
Playful,
Other:
2.
Affect/bW
a.
changes) Flat.
!.hod (a p r v a s i v e and sustained internal f e e l i n g s t a t e / e m t i o n ) :
b. Lkpresscd, @Anxious,
% &a
~ u s ~ i c i c kaiiltY1shdnefu1,
s,
~ c r :
IP.
~ ; ~ s a i rw
r dh ~ ~ ( 5t~ ~s: : : : .
O;l~ei-:
b.
Tn,ic$t.
Process:
Ov?r&straction,
Dtclusively ~a::'.:
(:.Y : :
s&-related
ideas)
:: : :
~ -i.,
t
T
3
:
=
&
otiix :
2.
dZt+
'Iii~GJlltCO!~~~II'C:
::.. :,
C.
1r:~xircclrc.?lity t e s t i n g , Persevcratio::
hx F-I'?(~.-.
i A *a%
' In&
iC
1
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l, I- ,.;
: .
ft ~
LLG;
Ot!lcr :
2.
1. l ' r ~ m ~ p t i o n(specify
s
content) : O
Cs:r;;ulsions
., ,.
- .
:.
rl
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A.:.:
f <c
:'=
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3.
n.:-, :i:
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r?rcc$ion:
2.
V:
.. :
kw4.
h r k d LU.*
r.:
2?*,k
vJ-
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crl.
4.
Scnsorim:
,.
a.
Orientation:
Orientcd to:
c.
I.'m-oqf: recent:
In-paired,
Pamte:
Inpaked,
c.
e.
--
OLhzr:
~fcllig~?:
rcc
& l o t average, i
age,
./
Othcr:
f . J u 2 q ~ ~ x t?ppropriate,
:
O t i k r:
5.
Insicht:,
Ph?Li'i~i!llncss and attributes
ness
hiit
.-
-..
trmtwxt.
Other :
111.
b.
-~
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..
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DATE
--D 4 i C
.illERAP I ST
n /
/?
fl
,-
by Tim Mekeel
and Ernest Schreiber
hew Era Slafl Wr ters
I * o d . r l r a YURICIPa I R A I H I C I .
MUNiClf'AL
COURT OF
Address:
BOROUGH OF A V A L O N
DEFENDANT'S COPY
I TO
Stanley J. Caterbone
2323 New Danville Pike
Conestoga, PA 17516-36
0.p.e.e....df.oho1.....coLLt.i%i.n.e.K
....i.n....!!
MOlrWO"
Violation Date shown above and a summons was issued for your appea
(-'
,!
. .
Since you failed to appear in Court and have not paid the prescribed fine,
YOU ARE ORDERED to appear .in t h.~ scourt on .- 12-2-87 -STONE BARBOR COURT
(D.tO)
to plead not puilty, you must notify this court a? least 3 days prior to the new court date.
. at
7:30 p.m.
...................................................
lf you wish
PARKING OFFENDERS Residents and Nondesidents: In addition to the consequences listed above, a civil judgment may be entered
against you.
BY OROER OF THE JUD6E
.....
Mary Monks
......................................................
"
Office Houn:
(609) 967-4457
(609) 967-8200
Telephone: .........................................................................................................................................................
(Please return
this Notice
and your
Summons
when making
A receipt will be sent toThursday
you only ifDecember
your payment
accompanied I
EXHIBIT
U.S. 16-4014
CIVIL
RIGHTS
CLAIM
Page payment.
320 of 646
15,is2016
a
self-addressed
envelope.)
- - Property of Advance Media Group
Page 2426 of 2953
10/19/2006
1 4 0
MUNICIPAL COURT OF
Address:
BOROUGH OF AVALON
DEFENDANT'S COPY
Date ..
D.L. NO.
Caterbone
Stanley .I.
2323 New Danville Pike
Conestoga, PA 17516-36
18 195 782 PA
Unregistered
Unregistered
-
EYE
CODE
7-15-58
......................
VIOlAT1ON(S)
SECTION
39: 3-17
VIOLATION
DATE IL TIME
8-14-87
SEX
8:42 p.m.
was filed in this court on
th
~.-.16_:8~.-sST~E!~...~P
.- .........
Violation Date shown above and a summons was issued for your appearance in this Court on
mts)
Since you failed to appear in Court and have not paid the prescribed fine,
YOU ARE ORDERED to appear in this court on
12-14-87
-.!.3~..~.&
.......... If you wisl
to plead not guilty, you must notify this court at least 3 days priw to the new court date.
Office Hours
Telephone:
8:3O
Mary A. Monk:
(609) 967-4457
EXHIBIT
16-4014
CIVIL
CLAIM
of 646
15, is2016
(PleaseU.S.
return
this Notice
andRIGHTS
your Summons
when Page
making321
payment..
A receipt will be sent Thursday
to you only December
if your payment
accompvlied
Property
of Advance Media
Group
a salfuddressed
envelope.)
10/19/2006
l.iUNlClPAL
COURT OF
Address:
Date
BOROUGH OF AVALON
DEFENDANT'S COPY
11-12-87
.............................................................................................
Stanley J. Caterbone
2323 New Danville Pike
Conestoga, PA 17516-36
DATE
(L
TIME
(violmon)
.................. HARBOR, N
Violation Date shown above and a summons was issued for your appearance in this Court on ..................... 9 - 16-87-STONE
(ruts)
Since you failed to appear in Court and have not paid the prescribed fine,
YOU ARE ORDERED to appear in this court on
at
(Dale)
to plead not guilty, you must notify this court at least 3 days prim to the new court date. If you wish to plead guilty, you must pay ;
80.00
total penalty of $
your payment.
......... before your new court date. You must sign the back of the summons and return summons wit1
NOTE: Canadian Residents Please Send U.
S. Currency.
PARKING. OFFENDERS Residents and Non4esidents: In addition to the consequences listed above, a civil judgment may be entered
against you.
BY ORDER DF THE JUDGE
................................................
Mary Monks
...................................................
EXHIBIT
CIVIL
CLAIM
of 646
15, is
2016
(PleaseU.S.
return16-4014
this Notice
andRIGHTS
your Summons
when Page
making322
payment
A receipt will be sent Thursday
to you only December
if your payment
accompanied
Property
of Advance Media
Group
a selfsddrened
envelope.)
10/19/2006
MUNICIPAL COURT OF
Address:
BOROUGH O F A V A L O N
DEFENDANT'S COPY
Date
TO
Stanley J. Caterbone
2323 New Danville Pike
Lonestoga, PA 1151b-36
6 STATE
Unregistered
REG. EXP.
DATE
Unregistered
DATE OF
EYE
CODE
7=-15-58
SEX
wOUTION(sl
39:3-4
SECTION
VIOLATION
having
..... an unregistered vehicle
MoIaWon)
p6~&
Violation Date shown above and a summons was issued for your appearance in t ~ b r @
&'
L....I
Since you failed to appear in Court and have not paid the prescribed'fine,
YOU ARE ORDERED to appear in this court on .......12.
-2-aZ.-STQNE...WB...C(lURT
ccuq
...................
at ......Z.:.30 ...p.m
-. . . . If you wish
to plead not guilty, you must notify this court at least 3 days priw to the new court date.
Mary Monks
.........................................................................
EXHIBIT
CIVIL
CLAIM
Page 323
of 646
15, is2016
(Please U.S.
return16-4014
this Notice
and RIGHTS
your Summons
when making
payment.
A receipt will be sent Thursday
to you only December
if your payment
accompanied
Property
of Advance Media
Group
a self-addressed
enve1ope.J
10/19/2006
I ,
Section
3189 Federal False Claim Act
WESTMORELAND, GOULD. VESPER &
SCHWARTZ
h PROILSSII1NAL COiJQRAnOS
-
S T A N L E Y J. CATE:RIiONL'::
F M G ACCtJLlNTING L;EIiUICE:S
17C
-ra OREGON PIKC
1-ANCASTER,
F'A
17Xr31
1.8 1
877344h.-C
AUGUST
C/O
FILE
STATEMENT
()0~:8.24
US+ W I L L I A M h BE-TTY iJ'tlRrir:
G I J M M R R Y
T h i s s u m m a r y i nc ludec; a I. L i : r a n 3 a c t ion-: up t o a n d i nc Lud i ng
t h e m o n t h end P I - r c e d i ng tl-ii s s t a t e m e n t .
A n y cl-ed i t s o r r e c e i p t s
p r o c e s s e d a f t e r . t h a t d a t e m a r n o t be i n c ludea and w i L L be
reflected o n y o u r n e x t s t a t e m e n t .
Previ o u s
Less:
Statements
R e t a i ners
B A L A N C E
Fees f o r t h i s b i L L
T o t a L amount
N e w R a Lance FOI-ward
T O T A L EcALANCE NOW flLlE
this b i L L
x*wX.x3c-xxx**xw*crx.*
o f
MR.
S T A N L E Y .J
CuMnK~nos
C;ATETITIOE.IE
C / O FMG ACCOUNTING S E R V I C E S
1755 OREGON P I K E
F'&
17601
:..ANCAST-ER,
STATEMENT
VS.
-i
::
W I L L I A M h B E T T Y OiHARA
J U L Y 09 07
J U L Y 21 87
JI.JLY 23 87
.lULY 2 4 67
J U L Y 27 67
nJULY
27 67
J U L Y 28 B 7
J U L Y 29 87
8
J U L Y 31 87
, :-,
AUG
009824
03 87
I N T E K E S T WII-I..
B E CIiARGELI AT TkIE R A T E
PAYMENT I S D U E UPON R E C E I P T .
O F 1%PER MONTH ON EALANCEG R E M A I N I N G U N P A I D AFTER T H I R T Y DAYS.
Twenty-five
...........
lJous??d,,Se~enH
x.
..
(Stanle~_J~-!terbohe_L
............................
NOTE IN FAVOR OF
Millard E. and Dorothy A. Johnson , AND AGAINST
THE UNDERSIGNED, CONTAINING A CONFESSION OF JUDGMENT.
DATED :
C'i
July 1, 1987
AMOUNT :
$25,733.00
2.
4:
.;&
:
!
before me this
eel
J / day
.+
.c
.j
ROBERT E. KAUFFMAN
PRESIDENT
Mr.
Millard Johnson
Dear Bill :
Robert E. Kauffman
President
REK: lmk
CC
Scrurl*ler Offer&
tnrovph
Scrumles Group. InG
Page
2433 ofPtanner's
2953
A R r p m l n d ilrokcrlL%.ler
Member SlPC
M m k r NASD
10/19/2006
._-.
-
Defamation of C h a r a c t e r
Slander
Mental Duress
Malice
Unfair C a T p e t i t i o n
Wrongful I n t e r f e r e with BusiRelations
Wrongful I n t e r f e r e m w i t h C o n t r a c t s
Trezpass to P e r s s n
Burglary
Theft
Criminal Mischief
I n v a s i o n o f Privacy
T r e z p a s s to Personal P r o p e r t y
Undoinf l u e m
Fraud
Conspiracy
EMxzzlmnt
Breach of C o n t r a c t
Extortion
Forgery
S b r h o l d e r Freeze-cut
- -
Cornno-lth
M t l 0 ~Bank
1
Penn m a r e
Lancaster, PA
176432
W l l o n Bank
Pittsburg, PA
Parent Carpany
Mike W o l f , Executive Vice President of Comnercial Lending
f ' w PEAJBLOS
U(;ATIONS.:
Defamation o f Character
Slander
Mental Duress
Malie
Unfair Cocrpetition
Wrongful I n t e r f e r e ~ zw i t h Business Relations
Wrongful Interference w i t h Contracts
Trespass t o Person
T M t
Criminal Mischief
Invasion o f Privacy
Trespass to Personal Property
Undoinf luenoe
Fraud
Conspiracy
EntEzzlement
Breach of Contract
Extortion
Defamation of Character
Slander
Mental IXlress
Malice
Unfair Conpetition
Wrowful Interference with BusiRelatiom
Wrowful Interference w i t h Contracts
T r e s p a s to Person
Theft
C r i m i m l Mischief
Invasion of Privacy
Trespass to Personal Property
Urdoinf luence
Fraud
? Corqsiracy
I EmSezzlement
Breach of Contract
Extortion
r/Aw ,455
PLLE%~.ICNS:
Defamation of Character
Slaoder
Mental Duress
Mall03
Unfalr Corrpetr t i o n
Wrongful Interference w l t h BusiRelations
Wrongful Interference w l t h Contracts
T r e z p a s t o Pemn
,ary
.
- .
Theft
Invaslon of Prlvacy
Trespass t o Perzonal
Undolnfluence
Fraud
Cor?zplracy
Breach of Contract
t Extortion
Property
C'
Hunllton Bank
Oregon Plke
Lamaster, PA
17601
Defamation of Character
Slander
Mental Duress
Malice
Unfair Conpetit i o n
Wrongful Interference with Business Relations
Wrongful Interference with Contracts
Trt o Person
Trto Personal Prcperty
Undoinf luence
Fraud
Coqiracy
Breach of Contract
Extortion
F u l t o n Bank
O l d Hickory B r a n c h
Stor L a n c a s t e r . PA
17601
?6tl
U n f a i r Conpeti t i o n
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o m
Wrongful I n t e r f e r e with Contracts
Undoinfluem
Fraud
Comiracy
Erkezzlement
B r e a c h of C o n t r a c t
Extortion
Cor
Brc
Berdett T m l l n Hospital
Cape Nay County Courthouse
Stone Harbor, NJ
08247
Social Worker
Psychiatrist 1
Psychiatrist 2
WEGAT IONS:
Defamation of Character
Slarder
k n t a l Duress
Malice
Unfalr Carpetrtlon
Wrongful Interferew l t h Busines Relatiow
Wrongful Interference w i t h Contracts
Tnzspass to Person
Irwa~lon
of Prrvacy
Trespass to Percsml Property
Undolnf luence
Fraud
Cowpiracy
Breach of Contract
~orgsry
Neg11gsnce
Officer Dean
Fat Aswrciate
Defamation of Character
Slander
Mental Duress
Malice
Unfair Conpetition
Wrongful Interference with Business Relations
Wrongful Interference with Contracts
Trespass to Percan
Burglary
Theft
Criminal M i x h i e f
Itwasion o f Privacy
Trto Personal Property
Undoinf l u e n z
Fraud
Conspiracy
En'&ezzlmnt
Breach of Contract
Extortion
Forsew
Sharholder Freeze-out
mligence
k n h i m Towrship P o l i c e Deparbnent
C i r c l e Drive
Lancaster, PA
17601
D e t e c t i v e Mathias
Officer 1
Officer 2
Officer 3
Officer 4
Defamation of C h a r a c t e r
Slander
k n t a l hresr
Malice
'j
Wrongful I n t e r f e r e n c e w i t h Business R e l a t i o n s
Wrongful I n t e r f e r e with Contracts
T r e s p a s s to Person
8urglat-y
Theft
C r i m i n a l Mischief
Invasion of Privacy
T r e s p a s s to Personal P r o p e r t y
Undoinf l u e m
Conspiracy
Breach of C o n t r a c t
Negligznce
L a n e a s t e r P o l l c e Department
W. Chestrwt S t r e e t
L a n e a s t e r , PA
17602
Defamation of C h a r a c t e r
Slander
Mental DuMalioe
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o w
Wrongful I n t e r f e r e n c e w i t h C o n t r a c t s
Trto Person
Undoinfluence
Fraud
Conspiracy
Breach of C o n t r a c t
Negligence
Jocsh R c d a , E s q .
301 C l p k r Building
36 E. K i y Street
L a m a s t e r , PA
17602
(717) 397-5791
Defamation of Character
Slander
k n t a l Duress
Malice
Unfair Conpeti t i o n
Wrongful I n t e r f e r e w i t h Business R e l a t i o m
Wrongful I n t e r f e r e with Contracts
Undoinfluence
Fraud
Colqriracy
Embezzlenmt
Breach of Contract
Extortion
S h a r b l d e r Freeze-cut
Neglisnce
Lou S c ~ l l e r Esq.
,
V a l o r e , M c A l l i s t e r , W i x o r e l a n d , Gould, V e s p e r & Sctwartz
Northfield, NJ
(609) 64-1111
Mental Duress
Malice
U n f a i r Gorrpetltion
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o n s
Wrongful I n t e r f e r e n c e w i t h C o n t r a c t s
Undoinf l u e n c e
Fraud
Conspiracy
mzzlement
Breach of C o n t r a c t
Extortion
Negligence
D r . W r s h a l l L e v i r e , E ffl D P A
l a 1 T i l t o n Road
N o r t h f i e l d , NJ
(653) 646-2011
D e f a m t i o n of C h a r a c t e r
Slander
Mental LXlresr
Malice
Unfair C a r p e t i t i o n
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s Relations
Wrongful Interference w i t h C o n t r a c t s
T r e a s s to Person
I n v a s i o n of P r i v a c y
Undoinf l u e e
Fraud
Comiracy
Fdxzzlmnt
Breach of C o n t r a c t
Extortion
Neglige-
B I L L TO: :S J CgJEEf#EAIZSOCIATES
HARBOR,
TRACKING NOS
REFERENCE
08247
1 SHIPPED
PAC
DAl
ACCOUNT NO.
I N V O I C E NO. 6 - 2 5 0 - 7 3 1 9 7
PACKAGES
8 WEIGHT
R E C I P I E N T INFORMATION AND
PROOF OF DELIVERY
1/
D I A N E SAWYER
CBS
555 W 5 7 T H S T
NEW YORK C I T Y
NY 1 0 0 1 9 AA
DELIVERED 0 8 / 3 7 / 8 7 11:2 2
SIGNED: 0 PARKER
STAN CATERBONE
S J CATERBONE ASSOCIATES
554 BERKELEY AVE
STONE HARBOR,
N J 08247
5587942463
4632584
NJ
SENDER A C T I V I T Y SUMMARY
08/28/87
(SENDER SUBTOTAL
CHARGES
SERVICES
14.0C
1 0 . OC
NA OVRNIGHT L T R
S A T SERVICE
2 4 . 0 0 1 ~T H~ I ~S AMOUNT
RODA. P.C.
A T T O R N E Y S AT L A W
301 ClPHER BUILOINC.
36 E A S T K I N G STREET
LANCASTER. P E N N S Y L V A N I A 17602
TELEPHONE (7171 3 9 7 - 3 7 9 1
.JOSEPH F R O D A
PAUL
5 ROMANO
September 2 ,
1987
M r . S t a n l e y J . Caterbone
5 5 4 B e r k l e y Road
S t o n e H a r b o r , N J 08247
Dear S t a n :
Our r e c o r d s show a p a s t due amount o f $525.48 o n your
a c c o u n t , as r e f l e c t e d on o u r s t a t e m e n t o f J u l y 22, 1 9 8 7 , a
copy o f which i s e n c l o s e d f o r your c o n v e n i e n c e . A s you w i l l
r e c a l l , t h i s i n c l u d e d copying c h a r g e s which w e advanced on
your b e h a l f .
Your immediate a t t e n t i o n i n b r i n g i n g t h i s a c c o u n t
c u r r e n t would be a p p r e c i a t e d .
I know t h a t you w i l l t a k e
c a r e o f t h i s , and t h i s n o t e i s s e n t s i m p l y by way o f a
reminder.
I saw Tom t h e o t h e r n i g h t and had a n i c e c o n v e r s a t i o n
w i t h him.
C a t h o l i c High s h o u l d h a v e h i r e d him.
With k i n d e s t r e g a r d s ,
Sincerely,
A
w
&
G
z
k
ose h F. Roda
JFR:dlb
Enc .
..--
^-"
--
. "..,..,," ,...
"..,,...
., -.,. ~ , ,
JUSTICE
US District Court For The DISTRICT
Eastern District
of Pennsylvana
MAGISTERIAL DISTRICT NO{;>14>
_ 7--I
ox;'y.&gaw
.,..__
i I>-I>>u
OTN
b384SbCi-13
L-.::
C O M M O N W E A L T H OF P E N N S Y L V A N I A
vs.
DEFENDANT
- ,1
7 . .
PLxJ~oir;lT
of
*,
.a;..>
-- ,-:."fAffi",,l/
(NO##,<
j:.,*
i\
p *lice
..%
..
mflle
ADoREss 2323
.,is:
Lu'i;.
/ti
RSA
A K A
s;j
>*
2:-3;fi3
do hereby slate:
I accuse the above named defendant, who lives at the address set iorLh above or,
(1)
I accuse an individual whose name is unknown to me but who is described as
-:
4
'
his nickname or popular designation is unknown Lo me and, therefore, 1 have designated him herein as Johr
' ~ b d p
with violating the penal laws of the Commonwealth of Pennsylvania a t
.
?
(Plur.~.Polirieol Subdivis#onl
in
.x
Participants Were
(iftl#ere
~&&&"k
County on or about
tlulvtsr
U,
s-py
J, p&&.;., ;.(2) The acts committed by the accused were:@
~ p , ~ ~ ; r L y ~ , ~r~~;j;:2~,j,;;
;;~~!;
?
:
.?r
Said &tor did tlurakn ta d
t auy c r h of v i o l u ~ ~uiih
o ti& intat to txazwka atme
to IXSUSO cvczautian or' a
>laso US irc;maLly as facility. of pub310 tzasrmt;rtLq
;is1%&4 ?O
,
OiU130 G&W
pCbU b i C Q l ? S G l h i ~ c tOX b ~CCii'L6wd l W X q p d 0
f
~
~
tmmx a;c b c o w ~ e Yo
, Uitr
actor
p k z e ii @1oiu1 w l l to
P f f h af
y& 2,- thqpsu~t
cL~u.9 1755 Crcr*
2 2 h
~i~
~ taFL. b ~ h e t i n
hru & licroa W
- 1 %yt. i]?. Tiic uiU w atxmxd by J u u Eai;c.r, ~ 1 ;k i p l ~ y w ,crtxi tis c a l l e r utatsd I r
&-visa yiru all to but out of a x 3 bdlriiy: if yarr v;luc ycjur a2.t-b".
. i i cziUm2 %.id6ut.j
fa
byliisvlacutus &at d iheakr~ecict3L.b~ikzXiaqiz-.
k i d a ~ t u bkrmx'pr:
r ~
!@ ~ ~ ~ e t i e o ~ p a e w s i n t L o ~ c - ~
-,
'$6
..
"
all of url~ichwere against the peace and dignity of the Commonweallh of Pennsylvania and contrary to the Actof Ass,
and
of the Act of .
.
.. . .. .
or in violation o f . q$ r''r,ur,/
.
(Sub.rurriorrl
or the
'l%W ib -.WO
Ordinance of
(l'ubtirul Sub-divisirml
(3) I ask that a wanant of arrest or a summons be issued and that the accused be required to answer the charge!
have made.
(4)
I verify that the facts set forth in this complaint are true and correct to the best of my.knowledge or informati
and belief. Thii verificition is made subject to the penalties of Section 4904 -of t. h e W i u Coc)t?.(l8 Pa. C. S.
..-...
54904) relating to unsworn falsification to authorities.
.
.
.S*..' , , L . ...
.-
Clark, Guerin
K-17-9a
~~
!Tee"
r-r
..--*--I-
--A
>.
~~
II
;..,,LL-yJ
...
>.<JJ.
~ o r n p l m n nruuanurrs
LGII'
81
vtnrr v a r $ ~ c ~ p i l n f s
;;-1-02
<,;;f&+,,,~'f&<j~()G i > i ~ i - ~ ~ y l
C O M M O N W E A L T H O F PENNSY L V A N l A
vs.
DEFChOANT
do hereby state:
I accuse Lhe above named defendant, who 1ivt.s aL the address set forth above or,
(1)@!
I accuse an individual whose namc is unknown Lo me but who is described as
X
0
his nickname or popular designation is unknown to mc and, therefore, I have desigt!ated him herein as Johl
wilh violating the penal laws of the Commonwe;tlth of Pennsylvarlia a t 1'755 Ore&on 'i'k- -caste:
(I'lucc.I'~,lir!..ulSt,h,finlio,al
$
~ : a d ~ e iTn~ i p
<
Participants were
>
Uc-
in
kllc&sCt?r
County on or about
2230 t o 2330
3
07
l!Yf3
.Fr%&:
-
1)
O C;ur:t
'
pa/
~
as T o entl;in,jrr PerLiufi
02 jiI.Opcr:y.
1111 of which were against the peace and dignity of the Commonwealth of Pennsylvania and cotitrary t o the Act of Ass,
or in violation of 2 ~ : .
and
rp,.e
o f the Act of ,Ph Critueu Co2e
%~'.,,XW~
or the
&.ub-sc.-tru;d,
Ordinance of
--
(Politicel Subdil.irinn)
(3j I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charge:
have rnadi.
(4)
I verify that the facts set forth in this complaint are true and correct t o the best of my lmowledge or informati
and belief. This verification is made subject to the penalties of S e c t i o ~4904 of the C r i e s Code (i8Pa. C. S.
4904) relating to unswom falsification t o authorities.
/
3 NOW, on this dale
. . .
---
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Count # : d G n l a w f u l R e s t r a i n t - A c c u s e d d i d u n l a w f u l l ySection
and3189kFederal
n o w iFalse
n g lClaim
y rAct
estr:
a n o t h e r u n l a w f u l l y i n c i r c u m s t a n c e s e x p o s i n g s a i d o t h e r p e r s o n o t r i s k ol
s e r i o u s b o d i l y harm, t o w i t : a c c u s e d d i d p u l l S t a c y L. ' d a t e r s by t h e w r i s t
t h r o u g h o u t a b u i l d i n g w h i l e h e c a u s e d damage t o s a i d b u i l d i n & and s t o l e j
'-on ';he f i l e s .
Accused t h r e a t e n t o harm Waters i f s h e would n o t cooper:
a con?
EBPPB -3$
x.
ccused did unfaefuily t a k e o r e x e r c i s e c i n t r l
moveabl n r o u e r t g of a n o t h e r t o w i t , z c c u s e d d i d remove numerous f i l e s i'
t h e r e c o r d s a r e a s of Y l n a n c i a l Mgt. Group 1755 Oregon Pk. L a n c a s t e r , Pa.
w i t h t h e i n t e n t t o d e p r i v e t h e owner t h o use t h e r e o f .
S e c t i o n 3921 ( a )
L i s t o f A c t s Committed by Accused:
B u r g l a r y Sec-3502, C r i m i n a l Mjsc:l.ief
Sec-3304 S u b s e c - ( a ) (.2.) .. U n l a w f u l R e s t r a i n t Sec-2902 S u b s e o - ( I )
U n l a w f u l Use of G o q p u t e r Sec-3933 ~ u b s e c - ( a ) ( 1 ) ( 2 ) , and ~ o b 5 e r yS e c 37
Sujsec-(a) (I ) ( i i )
..
ilof which were qainst thepeace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of X
<
-..- . ~ - 7 ? ? - . 7 L
-5: 7 .- ;,-,-r in violation of . . .
o f t h e ~ c t o f ' q ,rim??. %,f?
l~crrionl
andT: CiYlrrrnu,,/
....
.-_ . . . - -.-.---,--.. .. .. . - . Ordinance of '. " - :.:
. - :....... >:-. ...........
.
r the '
fPoIirirar SubUivtrronl
;I I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the c h q
have made.
L) I. Det. L a r r v G. P I a t h i ~ s
verify that the facts set forth-in this complaint are true
correct to the best of'my knowledge. information and belief.
. . penalties of Sec
4904 of the Crimes Code (18P a C. S. s 4904) relatine.
to
ontles.
-
, kc/.,./ / /-&&-
, 19
4 Seu
(Signah.rc of Complninanc)
6'WDNOW.on
this d a t e 4 S ~ 87
D
. 1 9 ,
that there is probable cause for the issuance of process.
-fl3+.-&-..-
- ,.
( . ~ I z ~ ; r r = r #Oistr;<c#
al
l I s x u t ~ 2A~ ~ ~ h o r ~ r v ~
RECEIVED FROM
. .L.,.;'
(,
! I
. ,
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90/100----------
------------,------------L---~-~--~~
. ..
DOLLARS
.<
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THE SUM OF
/: i
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%,.
+.
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1755 Oregon .
.. .
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i,
Manheim Township police ar!
i rested a Conestoga man Thursday
i , n$ht on charges that he erased
.'.
1 ormation from a township company's computers, stole files and
. I damaged equipment.
Stanley J. Caterbone, 29, of
2323 New Danvilie Pilte. . was
I
, charged with btsrglary, thetl, un,f l a d u l restraint, robbery, unlawuse of a computer, criminal
I..., . . ful
mischief and terroristic threats.
' ~ e t e c t i v eLarry ~ a k i said
s
- w e . victim, Financial ManageI'
$60 Wo-as
.I
1.
I
i'
,'
EX-~orkei,Charg&d
In Bvrglgry
.
at Firm
,
crimes.
He also was servgl a warrant'
for terroristic threats tn a case Invoivin another female employee ,
ofthe-firm. .
.
CAterbone, a former 'employ. /
ee of the coppany, was commit- ,
ted to prLson 1n l ~ e u
of $20,OW bar\.. :I
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I F MORE THAN ONE L I N E I S CHECKED, THE REQUEST WILL BE RETURNED UNANSWERED. I T I S IMPORTANT
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I F MORE THAN ONE L I N E I S CHECKED, THE REQUEST WILL BE RETURNED UNANSWERED. I T I S IMPORTANT
THAT YOU GIVE A COMPLETE EXPLANATION.
(PROVIDE ALL NEEDED INFORMATION) AS TO THE
REQUEST YOU ARE SUBMITTING. T H I S WILL ALLOW A FASTER ANSWER. YOU ARE TO PLACE THE REQUEST
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BOYD/WILSoN COMPANY
MARY L. CLINTON
APPRAISAL ASSOCIATES, INC.
PRESIDENT
DATED:
SEPTEMBER 1, 1985
.,.
. ..,
.. . .. .-
October 2 3 , 1985
BoydfWilson Company
208 Oregon Pike
L a n c a s t e r , PA 17601
ATTN: Dale Witmer
RE:
Dear M r . Witmer:
I n accordance with your r e q u e s t , I have examined t h e above p r e m i s e s , c o n s i s t i n g
of a group of townhouses, 3.0 s t o r y e l e v a t o r garden apartment b u i l d i n g s , a l o c a l
shopping c e n t e r , ( 2 ) o f f i c e b u i l d i n g s , a r a c q u e t c l u b and miscellaneous improvements
i n c l u d i n g a swimming p o o l , a 30 a c r e g o l f c o u r s e and t e n n i s c o u r t s l o c a t e d on
approximately 100 a c r e s of l a n d i n Manheim Township, L a n c a s t e r County, Pennsylvania.
The purpose of my examination and s t u d y i s t o v a l u e t h e premises i n t h e c u r r e n t
market .
I n a r r i v i n g a t my v a l u a t i o n , I have among o t h e r f a c t o r s c o n s i d e r e d t h e following:
(1)
(2)
(3)
I n l i g h t of t h e s e c o n s i d e r a t i o n s and o t h e r f a c t o r s s e t f o r t h i n my a p p r a i s a l r e p o r t
which f o l l o w s , I have a r r i v e d a t t h e aforementioned v a l u a t i o n .
Respectfully submitted,
C l i nCIVIL
t o n RIGHTS CLAIM
EXHIBITMary
U.S. L.
16-4014
p
r
e
s
i
d
e
n
t
Property of Advance Media Group
INCOME APPROACH
Residential
Commercial Income
Golf & Swimming
$2,224,766
$1,072,465
275,714
204,182
93,310
(11,870)
Racquet Club
Total
CHESTNUT
EXHIBIT U.S.
Page 363 of 646STREET, IANCASTER,
Thursday
December 15,
2016
x P 16-4014
P a S a 1CIVIL
~ S SRIGHTS
O C S . ~ SCLAIM
430 WEST
PENNSYLVANIA
116m
Property of Advance Media Group
10/19/2006
INCOME APPROACH
Mills
County
February 28th F i s c a l Year:
.5
Township
February 28th F i s c a l Year:
4.5
School D i s t r i c t
June 30th F i s c a l Year:
TOTAL :
,
! !
35.75
45.25
i i.
EXHIBIT U.S.
RIGHTS CLAIM
Page
364 of 646STREET, LANCASTER,
Thursday
December 15,178m
2016
& m16-4014
S i s r CIVIL
l assoeiat~s
430 WEST
CHES&UT
PENNSYLVANIA
10/19/2006
COST APPROACH
1.
2.
3.
4.
5.
&pdiSd
a S RIGHTS
S 0 ~ l a eCLAIM
S430 WEST
CHES~NUT
PENNSYLYANtA
178m
EXHIBIT U.S.
16-4014 CIVIL
Page
365 of 646STREET, LANCASTER.
Thursday
December 15,
2016
Property of Advance Media Group
10/19/2006
COST APPROACH
SUMMATION
REPRODUCTION COSTS:
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
V i l l a g e of Olde Hickory
V i l l a g e Square ( S t r i p Shop)
Olde Hickory Racquet Club
Boyd/Wilson Building
Community Center (Barn)
Stone Farm House
Pool F a c i l i t i e s
Golf Course & Shed
Tennis Courts
S i t e Improvements
Tot a1
Bldg. D e p r e c i a t i o n
Functional
Obsolescence
Economic
Obsolescence
Total
-
-0-0-0-0-0-0-
(1)
30%
15%
10%
(2)
20 %
(3)
25%
10%
(4)
5%
-0(5)
30 %
20%
(6)
25%
15%
(7)
35%
10%
-0(8)
5%
(9)
40 %
-0(10)
35%
-0T o t a l Accrued D e p r e c i a t i o n
-020%
-0-0-
$15,908,414
acres
acres
acres
acres
= $1,867,920
=
330,552
@ $72,000 p e r a c r e =
308,088
@ $21,500 p e r a c r e
@ $72,000 p e r a c r e
@ $72,000 p e r a c r e =
306 000
$2,812,560
2,812,560
$18,720,974
Rounded $18,700,000
I 1:
EXHIBIT U.S.
16-4014 CIVIL
RIGHTS CLAIM
Page
366 of 646STREET. UNCASTER,
Thursday
December 15,l7bd
2016
&~pmsal
assocIaIS.
430 WEST
CHESTNUT
PENNSYLVANIA
10/19/2006
WEDGEWOOD
Layout of Each Building
1st - 3rd Floors
3 Buildings
24
72
Rooms
108
324
Baths
36
108
Balconies
24
72
Apartments
Parking Spaces
97
Carports
32
TOWNHOUSES
Rooms
House
Type
24
-
Baths
Fireplaces
Courtyards
Burgess
246
2.5
102.5
41
Burgess
120
2.5
50.0
20
20
Landis
260
1.5
78 .O
52
Landis
95
1.5
28.5
19
19
Haymarket
270
2.5
112.5
Haymarket
36
2.5
15.0
Passmore
605
1.5
181.5
Passmore
120
1,752
1.5
36.0
-
328
604.0
132
24
69
TOTALS
Units
,
,
,
,
i i.~.
,-
,
,,
72
328
400
Baths
324
1,752
2,076
604
133
714
157
108
Ftreplaces
24
co~rt~ards/Balconies
72
65
137
, .
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TOTALS :
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WEDGEWOOD SECTION:
T h i s p a r c e l h a s an a r e a of 5.9134 a c r e s . The improvements c o n s i s t s o f t h r e e 3.0
s t o r y medium r i s e apartment b u i l d i n g s which a r e of non-fireproof c o n s t r u c t i o n w i t h
b r i c k e l e v a t i o n s and c e d a r mansards a t t h e t h i r d f l o o r roof l e v e l . Each apartment
has an enclosed wooden s c r e e n e d porch, some o f which have g l a s s e n c l o s u r e s . The
s t r u c t u r e s were e r e c t e d by t h e C l a b e l l Company, according t o p l a n s by W . F . L a n d i s .
The r o o f s I understand a r e a l l f l a t r u b e r o i d . Windows a r e wood double hung and t h e
e n t r a n c e t o each of t h e t h r e e b u i l d i n g s c o n s i s t of a c o l o n i a l wood type a r c h i t r a v e
with columns and two p l a t e g l a z e d wood doors a t b r i c k s t o o p . V e s t i b u l e s o r lobby
have b r i c k f l o o r i n g , p l a s t e r w a l l s w i t h e l e c t r i c a l w a l l b r a c k e t s and 3.0 s t o r i e s i n
h e i g h t w i t h b a l c o n i e s a t t h e 2nd and t h i r d f l o o r s w i t h wrought i r o n r a i l i n g s . The
ceilings are plaster.
Each v e s t i b u l e c o n t a i n s 28 approved m a i l r e c e p t i c a l s w i t h
push b u t t o n s . Only 24 a r e used. There i s one Dover s e l f - s e r v i c e e l e v a t o r of
1,500 l b s . c a p a c i t y w i t h paneled cab which t r a v e l s from t h e 1 s t f l o o r t o t h e 3rd f l o o
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LANCASTER,
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Thursday
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I h e r e b y c e r t i f y t h a t I h a v e no p a s t , p r e s e n t o r c o n t e m p l a t e d
f u t u r e , u n d i s c l o s e d i n t e r e s t i n t h e p r o p e r t y a p p r a i s e d h e r e i n and
n e i t h e r t h e employment t o make t h e a p p r a i s a l nor t h e compensation
i s c o n t i n g e n t upon t h e a p p r a i s e d v a l u e of t h e p r o p e r t y .
R e s p e c t f u l l y s u b itt
Mary L. C l i n t o n
President
APPRAISAL ASSOCIATES.
d
INC.
EXHIBIT U.S.
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1971
1971 to Present
1978 to Present
1982 to Present
APPRAISAL EDUCATION
5.
6.
7.
8.
Residential Appraising
Commercial Appraising
New Construction
Real Estate Law
Real Estate Financing
Real Estate Sales
Right-of-way
Real Estate Theory annd Practice
COURSES:
I
I
xpp&iSal
.sscW~~US
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16-4014 CIVIL
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Page
371 of 646STREET,LANCASTER,
Thursday
December 15,
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,,
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.,
SCV
CRP
CRV
RMU
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CIVIC ACTIVITIES:
Member of Upper Leacock Zoning Board
Director of the Soroptimist International of Lancaster
Director of the Ressler's Mill Foundation
Life Member of the Lancaster Osteopathic Hospital Blood Bank
Member of Leola United Methodist Church
Member of Upper Leacock Women's Club
EXHIBIT U.S.
16-4014 CIVIL
RIGHTS CLAIM
PageC372~
of 646
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Kppl~is.1
associaes
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16-4014 CIVILassociaf5s
RIGHTS CLAIM
Page 373 of 646 STREET, IANCASTER,
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December 15,12016
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--
ICHARGEISI.
I DATE OF
CHAR,
- .
U r r l ~ w i u l Use of k n p u t e r (13j, T h e f t
O N a r n i r i a l Bail
$
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N E X T COURT ACTION
AND TIME
LOCATION
I1
JUOGE O R
for
ISSUING
THIS
BONO
AND
IS
&&-hard L. ,Qcset, D, J.
Mrton, M s t r i c t Justice
VALID
UNTIL FULL
INCLUDING
FINAL
y the defendant,
c59(
DISPOSITION
OF ANY
PROCEEDINGS
PETITION
W R I T OF C E R T I O R A R I OR APPEAL T I M E L Y F I L E D
SUPREME COURT OF THE U N I T E D STATES.
A N D F I N A L DISPOSITION OF T H E CASE
this
FOR
IN
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A P P E A R A N C E OR B A I L B O N D
Other
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Refund o f cash bail w i l l be made w i t h i n 2 0 days afrer
final disposition. 1Pa.R.Cr.P. 4 0 1 5 ( b ) I
AUTHORITY
i+urray R.
176i
SECURITY O R SURETY ( I F A N Y )
a s u r e t v Company
professional Bondsman
ORealtv
Cother
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2205
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WE, THE UNDERSIGNED, defendant and surety. our successors, heirs and assigns, are j o i n t l y and severally b o u n d t o pay t o the
20,COO-GCI
M a c y tbouslnd-dollars ($
).
>:
S*d&
J. Czterbone
,Ptincipal, and
and that no further sum or sums i s l a be paid therefore by the said Principal or anyone on his behalf.
We lurther certify that said Principal has given to said Surety counter indemnity consisting of
/rur&
of the value of 5
and no further counter indemnity is to be given the said Surety
as followr:
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We further certily that there are no judgments against the said corporate surety outstanding and'unpid f a r d p e r i p d a f w h i r t y days from thedat
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e n l ~ o l s u c hjudgment except thorein which apetition to openorvacate the judgment hasbeenfileda"dkmainrundirpbred of:
Oated:
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M U S T BE SIGNED I N PERSON
B Y T H E APPROVED AGENT
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IA C K N O W L E D G E T H A T I A M L E G A L L Y RESPONSIBLE F O R
THE FULL A M Q U ~ T OF THE BAIL.
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EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
I r * Property
In case of
corporate
surew
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PENNSYLVANIA
G U I D E
if y o u h a v e ' q u e s t i o n s ,
questions.
I.
ADMISSION PROCEDURE
For safety reasons, the staff will. check your personal
belongings o n admission and will check other packages brought
into the unit thereafter.
Any sharp objects, medications,
glassware, or electrical appliances will be kept within a bin
at t h e n u r s i n g station.
Any l u g g a g e and personal i t e m s
should be labeled with your name.
Any valuables or money should be sent home or placed
within t h e hospital safe. You are encouraged t o keep no more
than $10.00 on the unit. Each person is responsible for his/
her own belongings.
p;Y
7:00 p.m.
8:00 p.m.
GROUND PRIVILEGES
Ground privileges allow a patient to leave the Inpatient
Unit and visit: ( 1 ) the Hob-Nob, ( 2 ) the Gift Shop, and (3)
the Chapel.' Visits to the hospital Library must be approved
by the patient's treatment team.
NOTE:
IV.
ATRIUM H O U R S
F o r a l l p a t i e n t s e x c e p t w h e n c o n t r a i n d i c a t e d by t h e
patient's psychiatrist and treatment team t h e h o u r s a r e 7:30
a.m.
9:00 p.m. daily. No'smoking i s allowed i n t h e Atrium.
L i g h t snacks and beverages are allowed in the Atrium for
visitors and patients.
Alcohol and other chemicals are
strictly forbidden.
P a t i e n t s and. v i s i t o r s a r e a s k e d t o
d i s p o s e o f cups, napkins, etc.
v.
PHONE C A L L S
VI.
SMOKING
T h e hospital discourages smoking in the interest of
better h e a l t h care. S m o k i n g is permitted only i n t h e multip u r p o s e rooms o n t h e South and West Units and in the
d e s i g n a t e d s m o k i n g a r e a o n t h e A c u t e C a r e Unit.
Smoking is
p e r m i t t e d in t h e Hob-Nob if ground privileges a r e granted.
Visitors m a y s m o k e only in t h e Hob-Nob.
No s m o k i n g u n d e r t h e a g e o f 16 i s allowed u n l e s s t h e
s t a f f r e c e i v e s permission f r o m t h e parents.
No c i g a r e t t e
lighters o r matches a r e allowed t o be carried o r used o n t h e
Units. P l e a s e u s e a s h t r a y s
not papercups o r wastecans.
VII
PASSES
T h e r a p e u t i c passes a r e approved by t h e t r e a t m e n t team.
p a s s e s a r e arranged o n a n individual basis. ~ 1 patients
1
m u s t be Picked UP and returned by approved arrangements m a d e
with t h e treatment team.
P a t i e n t s a r e e x p e c t e d t o a t t e n d a n d 9otf n a1 1
designed by the t r e a e
e n ot s- a
a t t e n d t h E m T s a n d Thursday
e v e n i n g c o m m u n i t y m e e t i n g u n l e s s e x c u s e d by t h e t r e a t m e n t
team.
P a t i e n t s a r e a s k e d t o be d r e s s e d i n s t r e e t c l o t h i n g and
ready t o begin t h e day's a c t i v i t i e s a f t e r h r p a k f a q t ,
P a t i e n t s a r e e x p e c t e d t o b a t h e o r shower a t l e a s t e v e r y
o t h e r day.
P a t i e n t s a r e asked t o a s s i s t i n keeping t h e public a r e a s
c l e a n by p u t t i n g c u p s , t r a s h , a n d o t h e r d i s c a r d a b l e items
i n t o t h e wastecans.
E a c h p a t i e n t i s r e q u i r e d t o b e h a v e i n a manner t h a t is
c o u r t e o u s t o o t h e r s and t h e s t a f f .
The manner o f d r e s s
s h o u l d n o t b e o f f e n s i v e b u t show r e s p e c t f o r o t h e r members o f
t h e community.
Laundry f a c i l i t i e s a r e provided s o t h a t each p a t i e n t can
have c l e a n c l o t h i n g .
XIII.
TREATMENT PLANS
~ a t i e n t s h a l l have a w r i t t e n , i n d i v i d u a l i z e d
,Each
t r e a t m e n t p l a n t n a t i s b a s e d on t h e a s s e s s m e n t s o f h i d h e r
c l i n i c a l neeas.
T h i s p l a n s h a l l b e d e v e l o p e d w i t h i n 72 h o u r s
o f t h e p a t i e n t ' s admission.
When a p p r o p r i a t e , t h e p a t i e n t
s h a l l p a r t i c i p a t e i n t h e development o f h i d h e r t r e a t m e n t
plan.
Any c o n c e r n s o r d i s a g r e e m e n t s r e g a r d i n g t r e a t m e n t
should be handled on an informal b a s i s before u t i l i z i n g a
formal grievance procedure.
0
XIV.
VIII.
MEALS/FOOD
Approximate Hours:
Breakfast
Lunch
Dinner
7:15 a.m.
12:OO noon
5 : 1 5 p.m.
TV AND RADIO
. TV and radio are allowed when not interfering with other
Ix.
\.
X.
XI.
MEDICATIONS
Patients are encouraged to know what medications they
a r e taking. M e d i c a t i o n s c h e d u l e s a r e p o s t e d o n t h e u n i t
bulletin board. Patients are encouraged to be prompt for the
scheduled medication.
N o m e d i c a t i o n i s t o be k e p t at t h e bedside.
All
medication brought in from home is t o be kept at the nursing
station.
XV.
We encourage former p a t i e n t s t o r e t u r n t o t h e I n p a t i e n t
M e n t a l H e a l t h S e r v i c e f o r v i s i t s t o keep i n c o n t a c t w i t h
supportive staff.
However, r e t u r n i n g f o r t h e p u r p o s e of
v i s i t i n g p a t i e n t s w i t h whom t h e former p a t i e n t has developed
a f r i e n d s h i p i s not encouraged. T h i s may i n t e r f e r e w i t h t h e
current patient's treatment.
i
nd Health Care Center
Direct Dial Number: 291-8163
To:
Stanley Caterbone
2323 New Danville Pike
Conestoga, Pa. 17516
Amount Due:
$3,064.60
Account Number:
081609802
7);,L7c
DRB@LA
10/19/2006
-----I-
,--
-I-
,-AMY(
".YLIU*I
c-.
llD
.NLEY J. CATERBONE
Dear Diane:
Regretfully,
Emlollre
:
Barry Capello
10/19/2006
Subject:
Date of
Conference:
September 6 1987
Place
of
Conference:
0
0
Relationship to
James Guerin:
ISC Shareholder
Debtor to Parent Federal Savings and Loan
The following transcriptsd represent a few of the converstions recorded during the meeting.
Stan Caterbone
Stan Caterbone
"Jim Christian owned it now I hear rumors that I was tied to ISC and I am
close to several people in that organization. Why they sent someone'in to
California to see me, I don't know. They wobt answer me."
Stan Caterbone -
"they wanted me to talk to a guy from D.C., New York, a guy from the
Caribbean. I don't know what the hell is going on."
" Chem Con is the big local minority-held corporation that was doing a lot
of Defense contracts-it was associated with ISC. They went under last
spring, beginning of the summer, and there was a lot of criminal auegations
made, none of them substantiated. And I was connected with that. They
sent a board member in to see me a week before this happened. Why. I
don't know."
Howard Eisler
"the supposition was - I don't know how true it was a front for ISC."
Stan Caterbone -
"It was, I'll tell you why. Because when Chem Con was started, back to their
inception, you look at ISC's books. They didn't have any money. Well, the
f i s t thing Chem Con did was they went and got all that free money from the
government and you look where that money went. I bet I know where it
went."
Stan Caterbone
"this guy named Geurin, James Geurin. And I know that they were selling
contracts back. He runs ISC and he also has his fmgers pretty deeply into
Chem Con. He's the one who started Chem Con, Guerin is the one who
started it."
Howard Eisler
(I
'C\
"You bet. They were tied, you'd better believe they were tied with Wedtech.
The same guys in Wedtech were invoked with ISC and Chem Con."
"ISC is sold over the London Exchange. (I bought my shares from Gib
Armstrong) I owned a thousand shares."
"
N
"
Stan Caterbone -
"What they did was, they fronted all that money and started the contracts,
went bankrupt, and now the government is stuck for $18,000,000."
Stan Caterbone -
"I know right now in this town's viewpoint, I stole money, I am insane, and
I am a lunatic I tell you I will not condemn Jm
i
Christian until he tells to
my face what happened."
C)
Stan Caterbone
Stan Caterbone -
/?
$.fibne of
- somehow
somebody associated with - oh, someone associated - in your District Office? Yea. Of
0"
course you were also one of the principals in the - I still am the minor one
Financial Management Group
- yes, the
are all very similar so I have to be --- Financial Management Group Ltd. filed for 202B
exemption. Now all the security sold in PA had to be registered. Some securities are
exempt but you have to apply the detention type of thing. It is a registration, not a
registration that
- explanation of
it is going to be run, who runs the corporation and all that sort of thing. Now under
the umbrella of this Financial Management Group there is a whole (now I a m repeating
what is in the 203D which I spent some time Friday reading)
- there is about
15, 14 - I
guess under that there is about 5 other corporations which are going to be an insurance
agency, an investment advising agency, a group
- now a lot of
come about. Well we simplified it. What do you mean simplified it? They are operating
but because of the accounting procedures they would have been a nightmare with all
those stubs. So, they a r e operating
Everything else is operating under Financial Management Group Limited. So these other
corporations have not really come into being. Technically, legally, no.
I seen also; I guess there is an application for a n investment advisor. Now, if you are
that time I was President, but now there is another application i n that is being acted on
now by somebody else. There is? I don't know who. Is that for the advisor? Yes, the
investment advisor.
Do your current records in Harrisburg indicate that he is still an executive with FMG?
Yes, because this offering memorandum was given back last March I think,
- last August
when I initially did it. Oh, no, pardon me. We are talking about two different
things. You a r e talking about your application for the investment advisor. No, I a m
talking about FMG
when
I started raising the money. August of 1986 is when I did the initial filing for the
offering memorandum
- the
144
after conception. Alright, yea. There is a report that is due a year after
that's what is coming up
- Right,
spent with the idea then of protecting investors. The idea of the
your are
limited to like 35 investors. You can't sell to 105 - you are limited. What the state
does is comes in and says, how are you going to raise the money in your offering
they comc i n
and say, now what did you do with the money. You raised 4 hundred and some odd
thousand, now how did you spend it? Now that has not been filed yet. It is due, in
fact I think it is overdue. It is due October 20. I got the letter right here. They just
sent me the letter. You guys just sent me the letter, I have it right here.
I have nothing to do with that end of it. I just came. well whenever I called you
I didn't get a hold of you the next day; it was the following day which was
Friday t h a t w e made contact.
Our idea in coming here was to let you ask whatever questions you had in terms of the
investigation. Of my limited knowledge of the type of securities these guys deal with
and securities in general, the things that came t o interest me was the fact that there
, that there
are with the annual report, his name is forged by someone else. This gentleman has
some involvement with the original group and the President suggested that he make false
reports to the bonding company so that he can get money back. They are the three
things that stuck out to me as a regular criminal attorney, that I thought you might be
interest in because, but like I say. we a r e here to have you ask questions of anything
that you might.
O.K., this offering then
their
203D, I get the idea they were going to raise four hundred and some odd thousand
dollars. At that time, they listed Bob Kauffman a t 60,000 shares and you and Hartlett
40,000 a piece. So, Kauffman a t this point is the main factor? Or, when 1 was talking
to you, it was really your idea that put this whole thing together. I put i t all together.
I brought him up from Atlanta to be president because I have a lot of business interests
and I didn't want to be tied down to the day-to-day operation. Plus, I never had any
management experience. Most of my work was consulting, business deals, this and that,
so I actually brought him up from Atlanta to be president. And, Hartlett
- is he a
complete local person. He's local. We all started together in IDS back in 1982. That's
your connection with Kauffman. you know him through IDS? He's the one that got me
started in business. I am the one who took him to FSC, that was our broker/dealer and
C
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
we started putting it together. Are they registered as FSC? Yes, that's John Keegel.
This similarity in names is a hassle; you are going to have to bear with me because you
throw these names out at me
-----.
So then, you had the public offering which you were going to sell another 120,000 shares
and raise $435,000. That would be in addition to what yon people put in. We put in 20
grand a piece. Well, we had 5 people. You were allowed 5 shareholders
- so we put in
5. Five put in 100,000 - five a t 20,000 yon mean? No, it was a little bit more than
that. Three of us put in 20; two put in 25. What we are talking roughly is one half
million dollars? Right. Financial Management Group now is responsible for maintaining
proper control over that money and it would be invested as 5
many people
- there is roughly
- now I don't
know how
I have that here. Do you mind if I look at it. That's 0.k. I went through a half hour
of frustration to get here. I wasn't running late until I got caught in the
The
way you described it, I assumed it was going to be in the country and I knew ...I stopped
a t the Post Office. I said where is 2300 New Danville Pike. I don't know. I was here
on Friday and I drove past it this morning. You'll bear with me then.
This is interesting. I've got about 40 shareholders. Is this as a result of the 203 deal?
Yes. Did you know about that. These are all the ones that are forged by the other
guys? No, no, just one is forged.
Now, yon people were acting as your own sales
properly accounted for? Were they all collected and put in the bank and the people
received their stock certificates. Uh, huh. Who all would have been in charge of that.
Mainly me. I was in charge of just about everything. Now, we have one-half a million
dollars or there about in the bank account. Where? They never would show me the
book
- my partners - never.
shut out literally. What brought that about? They were trying to take the company
from me from day one. I had too much power, too much control. They wanted to cheat
and be dishonest and I wouldn't. What happened was we had to acquire a n interest in a
broker/dealer to assume our equity, to realize our equity potential. So back in January,
we drummed u p this deal with a broker/dealer called
The deal was we were going to acquire 20% of their broker/dealer in return for aligning
our group with them. What I found was
them not doing what we needed, I got scared. I had so much money and time into this
company. I went down there myself and found an empty shell
- nothing.
Now, as a
corporate office, I know how liable I am, for everything, personally. Then what I find
out is that Hebron is a born-again, just like Kauffman. Oh, Kauffman is - yes. And,
is a Jehovah Witness. I get pissed off, so I swing the whole bore, change
everything and I line us with Planner's Security Group in Atlanta
that group is Wade Webster. Bill Carter
- Bill Kaker.
Now, in
ISP?
around, turned the whole board over, aligned up with them. The day after I get back
from Atlanta, Kauffman calls me into his office and goes through this spiel with I
thought I was president, who's running the company? I said 1 don't care who runs it, it
just got to be run right and for the right reason. Two weeks later, I am in New Jersey
working on a movie and doing some things
security reasons. I find that they have all these stock certificates and everything that
were in my office. You had the locks changed? You had them changed yourself, but
they still got into your office? I don't know how. They stole my files. July 1, I went
in and took all my files out of the office and went to an attorney, Joe Roda, and
explained what happened. Nothing. I met with attorneys in New York, New Jersey,
Boston. I found all these security violations and everything else, but no one could help
me. Then, about four weeks later. I called the FBC, the NAFC, the FBI, the Attorney
General, Senator, Governor, everybody. And, they all think I am bluffing.
Actually, they all thought he was crazy. They all thought I was crazy. And that was
started because of Robert Kauffman. That's what he did. The day after I went out and
got my files out, he spread rumors that I left the company, that I was thrown out, that
I was mentally unstable, that I was spending money. At that same time, I get
blackballed by all the local lending institutions. They repossessed my claim three weeks
before my first payment, with the files in it, of which a brother of the broker in FMG
is one of the lending officers. It gets ugly. That was before he spent the 5 days in
jail. I tried to get arrested. I had to. Then after you were arrested, you were in the
hospital at St. Joseph. I was coerced into going there.
No, that was my idea. I wanted him in a place where we were going to satisfy the
victim so to speak, and the police a t one point, that he would still be able to work with
them. In reality, he was in the hospital but had his car in the parking lot. He was
going to play basketball and come back. He was not committed. He was just there. I
walked in to satisfy the bail. Are you on medication? No.
One of the police officers mentioned to me that he was
alright now. Again, this might be one of these stories coming from FMG. What
Kauffman did was, back when they started doing this I had a psychiatrist that was my
client. I was depressed. I mean they were making a fool out of me in public; they were
firing people that were very close to me for no reason other than they were close to
me. So I went to A1 Schultz, a psychiatrist, because I was depressed. Very normal,
given the environment I was thrown in after putting this big thing together then having
these guys slam i t in my face, then take all the credit for what I did. He diagnosed me
as having biphola, depression. My father was schizophrenic and my brother committed
suicide two years ago. The reason he diagnosed that was because I was on a low, and
a t previous'times he thought I was on a high when I put this company together. So,
what I did was, three weeks before July 1, this previous July 1, I told Kauffman that I
went to see a psychiatrist because of how depressed I was because of what he and
Hartlett were doing. They fed on that, and tried to use that to use as their alibi for
'
- I didn't
- I just
haven't
to make inquiry a t the police office and one said that you were taken
not.
I was
with my family to have me committed and take guardianship over my assets so he could
buy the stocks from them a t what ever price he felt like it.
Incidentally, you may want to point out that as late as mid-August of this year,
Kauffman wanted t o buy you out for $2.50 a share or something like that. We have that
documented. Eight weeks prior t o that, I was working with the attorneys to do a 5 to 1
split. That makes the stock worth $25. Either he is ripping me off or he is ripping the
people off who are paying $25 a share.
The offering as you people had it was 3
issue completely sold
- that
120,000 shares? No. Was the best part of it? There was
4 hundred and some thousand sold. Did you buy any of that stock? No, I was in the
organizational sale. You don't know how that money is being accounted f o r now. I have
the corporate books. When I went in there June 30, I mean I was in there. I mean it
is not like I went in from the outside; I had a plane and was flying back and forth for
me. In fact, what happened was, I was granted a 60-day leave of absence late June with
pay. Really, what I wanted to do was meet with legal counsel and find out how I was
going to resolve all these problems that I was finding. What happened was, in June I
copied everything in that office (June 30th). and I copied the books. You see, I
developed a computer system. So I just took one of the copies
I've got the books. I don't know how accurate they are because the way that the guys
kept the records, the accounting is all screwed up too. I have an idea, but I found a
lot of money going to people that should not have been. In what way? What they did
was, there was a lot of Jehovah Witnesses that were hired in that firm
- receptionist,
cleaning, etc. Then what they did was replace all the staff people that I brought in
with their own. Then, there was money going out to a fellow by the name of Tom
Turner in Minneapolis. Now Tom Turner was the biggest divisional manager in IDS. Hc
was terminated by IDS in February because of religious convictions
- another born-again.
Then I find this guy was making $750,000 a year with IDS and I find FMG loaning him
money? Is that what they are going after
money are we talking about going to Tom. 12-15 grand. Then. I find checks going to
(-1
Kauffman's wife. Large amounts? Are you talking a hundred dollars? No, a thousand
here, $800 here.
FSC, which is a registered broker/dealer, was an entity started by you? No. What
happened was, back in 1983 I had a dinner meeting
the IAFC - and I drummed up a business meeting and had Alex Armstrong. Do you know
who Alexandria Armstrong is? Yea. She was one of the most prominent financial
planners in the company, a woman from DC. I brought her up to speak a n d I told her
that I wanted to get out of thc proprietary business. She said, go talk to John
FSC. Now, this is when Kauffman, Hartlctt, everybody was still a t IDS. So, I went a n
had a meeting a t FSC in Atlanta. At this time, Bob Kauffman was the Divisional
Manager for IDS in Atlanta. The next thing I know. I left; then he was hired by FSC to
be an officer and to run their sales force.
Then the idea of the company you a r e forming up here is to invest other people's
money? No, it is a one-stop financial entity
They are
that line. I mean big. We're talking an office of 10,000 sq. ft. right here and 35
people; then we travel all over the country. When I say offering services, we have 2
attorneys in there, we have 2 realtors, 4 insurance people, a portfolio manager, 8
financial planners, 5 brokers
- I mean, in depth.
mortgage banking. I had started a mortgage banking operation and the minimal loan I
wa looking a t was $3,000,000. 1 bet you I bid on S150,000,000 in the first 6 months of
1987. These were loans that you were going to provide the people with? You bet.
Where was those funds going to come from? They were coming from the largest biggest
insurance companies, the largest pension funds, and some of the largest banks. 0 . K . you
were going t o be a s a mortgage banking type of thing. That is right. You were not
lending the money; you were putting the lenders together with the borrowers and you
get a finders fee, or whatever. Yes.
(--')
&:how
did you get into this? You were an initial investor? No. I've been with Stan
since he started in business in 1982. I had come into some money and I was investing. I
had lent Stan some money and things got really screwed up with
with them, they more or less asked me to say to the bonding company (that they took
out after June 30th of this year) - t h e y wanted me to tell the bonding company that I
gave Stan the money to invest for me and
&fm
with the funds, which I flat our
refused to do. As a matter of fact, I damn near punched Kauffman in the mouth when
he was asking me to commit a very serious crime.
Now, Kauffman's background, is decent, is it not? Clean on paper. I mean he worked
for
- clean on paper;
there's a lot of people after that man. What he did to FSC was,
he was double dipping. He was telling FSC that we were going to stay with FSC the
rest of our lives; in reality, he was telling me that we were telling them what I wanted
them to hear that we were going to do our own broker/dealer so we could obtain our
own equity. And then, I find out that he is receiving a salary from FSC up until
February this year. Plus, his salary is in violation of the offering memorandum. Two
weeks before I left, he had the Board approve a salary of about 2-3 times what is in the
offering memorandum.
Maybe this is why the 203D
what to do. I did all that legal work; they don't know how to do it. This offering
memorandum we are talking about
- I just
9 and 10 because the type of information that is in it. That is the only thing we do
not have a copy here of. Well, we have a copy in the office if you need one. It is
public information; there is no problem with it. So are the books public - I got thrown
in jail for trying to get them. Well, we will try to resolve this; it is not going to
happen overnight.
Who is Kauffman connected with here. He called up everybody I know and told them I
left the company; told them I was stealing money from clients; told them I was mentally
insane. I was doing business everywhere. I was doing business with the Japanese; I was
doing business with the President, Stoney; I was doing business with High at New York,
Boston, Houston. Everybody all over the country heard that I was insane. Everybody.
f'\-
I've been 4 months without money. I haven't paid a bill since June 30. What do I do?
No one believes me. I tried going to the unemployment office. Do you know what they
did? When 1 was in the hospital, that was over $3,000. They called up the insurance
carried and told them to terminate me
- my hospitalization.
Did Kauffman in the initial offering that you had, the preorganizational offering - each
of you put up $20,000
other 10 for the remainder of the shares. He was supposed to put in 30 for his 50 $50 a share. The three of you put in 20. Then, he had a back agreement with me to
sell me 10; so we both would have 50,000 shares. I got that contract and he never
fulfilled that. I said no way are you getting more shares than me when 1 put it
together. I said you can be equal with me. But how did that come about? We signed a
back agreement so Hartlett wouldn't get mad. I had to write to buy about 10,000 shares
from Kauffman, 50, to give us both 50 a t anytime a t $.50 a share. You have that
agreement? Yes, he never signed it after he got his 50. It was a bad move on your
part. There is nothing wrong with the idea but do you think a t that point he was
conniving to d o
was in the middle constantly between Kauffman and Hartlett. In fact, a t one time
Kauffman was going over an idea
into the
office - about how he could set Hartlett up to get him out. Then, when he couldn't get
Hartlett out then the two of them tried to get me out.
Now, everything is in place and it is operational? But obviously you have a lot of
Ci
contacts to make this thing go. I'm out. I haven't talked to anybody? But you did
have initially. You already made them and they now have the
But now they've picked up your contacts really, so to speak? Exactly right. They are
acting as mortgage bankers, etc. The whole bit
they just
stole away from me. See, I never communicated with people. I couldn't, only because I
couldn't find competent legal counsel to tell me what to do. All they did, was send me
bills. I didn't even want to send a letter to everyone explaining the situation until I got
a competent legal counsel to tell me what is right, what is wrong, and what to do. I
went to 3 attorneys and they tell me there is no violation
- and I'm
- forged my name.
had an Annual Shareholder's Meeting; they never let people examine the books that have
wanted to.
Of course, all of this would boil down to their getting money from somewhere, extracting
money. Either they are cheating somebody and putting it in their pockets or taking
exorbitant salaries
We are paced to do
$4,000,000 PC1 a year, that's a lot of money passing through your hands.
skeptical of what's happening? I have no idea. I know the clients that 1 have talked to
to, that came down from New Jersey to find out what really went on ran the other way
as soon as they talked to me. In fact, one woman got so sick, she went downstairs and
threw up when I told her.
Well, you know the corporation, regardless of what the situation is when there is a
problem like this with you, or anyone, the corporation has to continue to function? The
fact that somebody has signed your signature to a financial management semi-annual
report. I don't know if that is a security violation, in that end of it. If it would be
corporate law, it may be, but not at the security end of it. Well, someone changed my
address. Who knows who gets my mail? I never changed it. From where? From 1755
Oregon Pike, FMG. It goes here; it goes down to New Jersey. 1 never did it; who did
it. They go through all my mail
days later. This is the Financial Management Group that does this? Of course, it is
coming to you as one of the principals in the corporation, and if i t comes in from their
standpoint, they wouldn't know if it had to do with corporate business or your business
personally. The fact that they opened it may not be ethical, but I don't know that
-.
If you change my address, that is forgery. You got to go to the Post Office and sign to
change an address, don't you? Well, I don't know. If you are no longer associated with
them
that. If somebody comes in and says you are no longer here, you're over there - I don't
know that the Post Office - somebody there should not have done it.
These are things that show this is not fabricated or something; they are actually
happening. I got so desperate I already wrote 60 Minutes.
How much money are we talking? Millions. That they have taken? I was Executive
Producer of the first digital movie ever, in the world. I was to get 40% of the profits.
I could have made 100-200 million dollars. I was ready to do a deal with the owner of
Turkey Hill. I was supposed to receive a check in July for $200,000; after he heard the
rumor, he backed off. How much have they squandered? How do I know? I can't get
at their books.
These stock certificates that you
2,000 shares of stock. Now the signature that is forged on yours is the secretary. It
should have been yours, but there is nothing wrong with the certificate as such
- aside
from the secretary signing the certificate? There is something shady about that stock
deal too. You see this is a year, not quite a year. Would this be part of the of 203
offering? Yes, everything is. All stock is part of the 2030. What I a m saying is, Scott
Robinson bought the 2,000 at $5 a share or whatever; he put up $10,000 and he was
entitled to get a certificate. If you weren't there to sign i t
Telephone call
'
If Scott Robinson put up the money and Peter Ponderose put up 8,000 shares, if he paid
$5 a share
- they didn't
pay $5; they paid $2.50. Regardless, they were entitled to the
-- why couldn't
in that office. Oh, you were still there in June. Yes. Even according to them. When
were you actually locked out? July 1. That's when I went in there and took my files,
when I found out they were doing that. Because they only way they could get the
certificates was to break into my office, because I had them. You had the stock
certificate book? Yes, I did everything
- they didn't
stuff. That's how I caught them. I knew the law because I did it. I did the
memorandum and everything.
The thing that is wrong with these certificates basically is the fact that Long is signing
as secretary and at that point, on the 25th of June, you're the secretary. As f a r a s we
know, these things could have really been negotiated a t the end of July a n d backdated.
I am not trying to beat you down. I got them July 1 - my attorney copied them for me.
That's how I got those copies. What you are saying, prior to your being locked out of
this place, they were already bypassing you. They found out that I was talking to an
attorney. Now what would they be afraid of when you were talking to the attorneys.
11
Page 397 of 646
Page 2503 of 2953
What they were doing. Of course, they do have control of the corporation
- between
Hartlett and - I did, I controlled the Board. That is why they threw me out. When I
made a decision, the Board followed it. But now, they are gaining control of the Board
I have no idea. I have never heard of a Board Meeting. Who is on the Board of
Directors? Me, Bob Kauffman, Mike Hartlett, Bob Long and Alan Loss. I heard those
names; I can't remember where. They were the signatures on the semi-annual report. Is
Long a born-again Christian. No, he is the accountant who hired from Main Herdman.
Were you a party to hiring all of these. Everybody. Pete
was terminated by
Shearson and I was the only person in time to give him a job. He already had some
trouble with the NASD. He was suspended; it took about 5 months just to get him
relicensed
- they had charges against him, allegations - forgery - in fact what he did
in
June was he went and used another persons rep number a t FSC to do options trading and
that person supposedly reported him, or wanted to report him
from Lancaster?
- Greek.
- Dick Sherbach.
Is he
Harrisburg a t Shearson. They fired him in November. I saw his name but I can't
connect it. So many names came up as a result of this
- I'm
get everybody straight. It's not easy, believe me. Time is one thing that I have a lot
of
- so do I.
or
They had a big shindig down a t the Strasburg Inn. A lot of people from New York came
in. The whole thing fell through although Environmental Technologies are is a local
corporation in business a n d they were trying to merge with
Corporation out of New York. I a m not familiar with it.
Shell
Again, it was a lot of born-
again people that would meet; they would push on the idea that all things stock up.
Well, I know h e is running advertisements on the radio that deals with the religious
sect.
Now, that they are set up, does the Financial Management Group need money or do they
have enough money to operate. No, they've got money. They are a self-sustaining
operation then; anything they get from selling securities they will pick up the
commission, if there is brokers mortgages they will pick up the commission on the
mortgages, and that's enough to keep them going, right? Oh, yea. They a r e not pressed
for money? No. Have the handled the customers/investor's money correctly. No. You
.
i
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
12
Page 398 of 646
Page 2504 of 2953
have mentioned they've given money to Tom Turner and Kauffman's wife, what else
have they mishandled? I know the Federal people wanted to investigate Kauffrnan's
books, of his stock book that he was managing. This is when he was down at Atlanta?
No, this is now. That's why they wanted him to liquidate his mutual funds so he could
manage it f o r him. They wanted you to liquidate your mutual funds? I told him that 1
was a little unhappy with the performance of the mutual funds that I had; he wanted me
to liquidate it and go into the stock market and let him work it for me. He was going
to act as your financial planner? I would imagine, yea, broker, buy and sell stock.
Have they acted as financial planners?
Is the one that you
last year
- illegally.
see it? Yea, let me. Who is registered now? No one is registered. I was that close to
getting it registered when I got shut it. It was all ready set to go; I got the papers. I
think it was just some questions. Were you working with Jamino? Yea, he is the
corporate attorney that I got
He is good. There's
no problem with him. No, Jeff's a good guy. He taught me securities law. I am trying
to think, this application here? Paul Short is who I was working with. I asked to see
the file quickly on Friday
C'!
- I didn't
They threw me out of the Financial Management Group; they never mentioned FMG
Advisory which I was President of. Is this the one that applied to
using the initials FMG. that's Financial Management Group? Right. I set up an umbrella
so it would be consistent. What threw me off was. when Financial Management Group
was registered there was a whole lot of other entities involved which used the initial
FMG Advisory Service, Accounting Service. That was for continuity. O.K., then FMG
Advisory Service was never really, up to now. was never really registered a s an
investment advisor, right? Correct. They were registered
state?
Right
1986
until now. they have done investment advisory services a n d these a r e the fees that they
collected? I charged some. You are allowed to charge up to, what is it
- 14 people?
think it is only 5. I was careful about that one. I know I only charged 5 clients, I am
sure of it. T h e FCC really gave me a rough time getting that thing filed
- I couldn't
even understand their questions half of the time. They are a mess, they really are. I
13
must have spent 100 hours. I agree with you, there is a lot of attorneys work in the
Harrisburg, and the question is the application
the
answer is Not Applicable. Yea, it takes you 3 hours to figure out that you don't answer
it. I agree with you. I have a tendency to want to throw it away. Well, after 5
months of fooling with it myself, I called Jeff up and said, Jeff, you got to help me get
through this thing. I got to get this registered. I called Jeff on the RIA probably in
January
- no, probably
February or March.
So, June 1987 was the last correspondence you had. Yea, right there it is. Right there,
it was done on June 23. I am going to want a copy of this. I need to get a copier in
here and copy it for you. I can't leave these out of here without copying them. These
files are just to valuable to me
- if
whatever you want, but I want to get a copier in here and make copies f o r you and you
can just run. I don't know where I am going to get money for a copier but
--.Well,
these files have been literally all over the country. In fact, most of these files are in 2
law firms in California and New Jersey. I was all over the place.
This is the application for your registration as an investment advisor. I would like to
see what the new one says on it. As you can see, they are all like a standard form.
Like I said, I have difficulty looking a t these things. If I am looking a t something I can
find it, but~justto look over and say its alright or whatever. But I would like to see
who they have listed on as officers. I just looked at it Friday and didn't take particular
notice other than I knew that Kauffman and Hartlett were some of the people. My name
wasn't on it. Oh, no, no, your name wasn't on it. Well if they are using FMG
Advisory, I am still President of that company. Well, I don't know in corporate law
what it takes to do away with a President at the Board of Directors meeting. I'll tell
you what it takes.
----- that's
Meeting. No, the shareholders must vote on the Board. Shareholders must vote and
approve, and shareholders must exempt people on the Board. Shareholders have to vote
to remove someone from the Board. Yes, but the Board of Director would be elected for
a year to two years, whatever the situation would be. So that corporate officer would
be there for that entire period. The three of us were elected to the board for a period
of 3-5 years. The initial Board members
control over a one-year term. Me, Kauffman, and Hartlett were 3-5 year terms. When
did that take place? We did that back in June of 86 when we started the company.
I
.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
14
Your only connection with the company now is the fact that? I have no connection.
They will not let me
money. That is something that you two are going to iron out. See, my involvement is
criminal charges
- that's
- FMG
Management Limited; Financial Management Limited owns all the other subs. O.K., 100%
- that's
had mentioned that there are offices throughout the country. How are those people
connected here? Shareholder and they are aligned with us through the broker/dealer.
They go through us to the brokerjdealer, rather than direct. We own 5% of Planner's
Security Group in Atlanta. We get the same deal that we 're supposed to with
Brown with this outfit in Atlanta. They are a fairly large broker/dealer. They are
doing about 15-20 million dollars a year right now, gross commission and
Is it Heubert? No, they are the born-agains that I left, I moved away from. What's the
name of the Atlanta Group? Planners Security Group
- Bill Kegler.
There's nothing
wrong with that group? Yea. they terminated me for no reason. As a registered rep?
Yep. I am sure they will come up with a reason; there is a reason why they did i t
because with the NFAC they had to file. I would like to know why? You know, you
were termed because you were sick or, you know there is going to be a reason.
Whether it is true or not. Lying has become a n accepted norm for all of this. Well, in
their compliance department, all of these broker/dealers should and generally do keep
very good close track of their sales people. How can they when 1 did the deal? But
Financial Management Group owns 5% of Planners Security? Bill Kegler was with FSC
and got angry when he couldn't run FSC 3 years ago. Then he started his own
broker/dealer. This is with Planners Security? That's right. He left John Keebel
because of a power struggle with them.
But now, other than terminating you when they shouldn't have, they are not doing
anything bad? How do I know? Do you suspect they are? Yea, they terminated me,
you bet. You better believe I suspect. If they are doing that to me, what are they
doing to the poor clients who don't know anything. The same thing with FMG
- if
they
are doing all this to me, what are they doing to the clients that don't know anything.
My clients are pissed.
So, what they could do is withdraw their money from the organization whether its in the
form of stock or whatever, but there is nobody making investments
? I've got the former Medical Director
St. Joseph Hospital that owns 10,000 shares with FMG that is very upset about all of
this. He,is away; I couldn't get him last night to come to the meeting. They got 35,000
of his. He went through everything from that company
What did they offer you $2 a share or something? They didn't offer me anything. But
in that letter they did. They offered me when it came time for me to get the check
because they knew what I was going to do. Well, you wouldn't have taken the $2 a
share would you, because you were talking about a 5-1 split. I would have taken i t but
I would have pursued my civil and legal rights and sued them for the rest. I went 5
days without food
- I was starving.
- people
look at me a n d laugh. Did you ever go 5 days without food? when you are worth a
considerable amount of money?
Kauffman told me that he was going to offer Stan $1-1.25 a share to settle it out, to
buy his
and out of the proceeds of that he was going to pay me the money
that is owed to me first, right off the top, I was his first consideration
- that he
wouldn't buy the stock unless my note was satisfied. You have a note with First
Financial Group claiming they are liable for it. So you took the money and put it into ?
No, I don't know who has the money. A bank either has it or Lancaster Aviation. It
was embezzled from me, I don't know who has it. But they are acknowledging that they
have custody of it? They were acknowledging liability for it. We don't know who has
it. Either Commonwealth Bank has it or Lancaster Aviation, I don't know. But you put
it in the bank? No, I didn't put it anywhere. He gave you the money, what did you do
with it? I gave it to Lancaster Aviation for the airplane. Then they repossessed the
airplane before my first payment for, I don't know why. And I don't know where the
$25,000 down payment is. He don't have it and I don't have it. But the $25,000 went to
7
him, not as an officer of the corporation? To me personally. The airplane is not part
of this corporate complex? No. But now Financial Management Group is saying they
will pay you back that $25,000? Uh, huh. They sent letters to all my creditors. They
told me that on 3 different occasions
company. Then they gave me a letter saying basically that if 1 wanted to talk about it,
talk to their attorney. Well, did you tell him about the bonding company? Yea. They
wanted you to sort of make the allegation that I gave Stan the money to invest f o r me
and that he had scuffled the money
that,
which I refused to do. They took out the bond after July 1. I got a thing in the mail
about a bond; I thought what is going on. Then he told me about a week later
that's what that is
- a $4,000,000 bond.
- I said
seen the $25,000. No, I don't know, maybe they have it. They might have it. Well, the
only way they could get it is if it were a reimbursement made on the airplane. They
were the ones calling the bank and the Aviation Company about the plane, asking what I
was doing with it, where I was going? They were the ones that initiated all the
conspiracy with the lending institutions. My credit rating was excellent up until August
I : (
This-is going to drag out; I will keep in touch with you. Now. you also have
investments through mutual funds through Financial Management Group? And how much
money are we talking about roughly? About 170,000. Now. do you have the certificates
for this. No, they were never issued. They are held in
the broker in this case was? His probably weren't transferred yet, it was probably FSC.
So, it would still be a monthly statement from them
- FSC is noted as
the broker/dealer, I a m sure. I doubt that they were yet to Planners Security. I get
the interest off that money, I get a check every month. But your investment is not in
jeopardy now, as f a r as you know.? No, but he is on disability a n d 25 grand meant a lot
to him.
Now, Kauffman wants you to sell these the mutual funds a n d give him t h e $100,000 to
invest as a broker? Right. Of course, you are reluctant to do that because you still
have confidence in Stan. I have confidence with Stan and I am not very comfortable
dealing in the stock market just now. I like more settled investments - the stock
market idea and I don't get along very well. I am looking for safety of my investments.
Like Stan said, I a m on disability a n d I d o need income. And K a u f f m a n promised you a
fortune if you made this transaction? He didn't come right out and promise me a
fortune but he insinuated that I could d o a lot if I let him work the stock market.. He
was doing all options, that's all he does. Well, I don't want no d a m n parts of options.
You look a t his client files; they are all option accounts. All of them, little old ladies
down to
--.
Here again, which you know, the broker when he is talking to you, or the registered rep
when he is talking to you, should file a form as to what you want. Now you just
mentioned to me that you are a conservative of man. I had him in government
securities.
- And
they should have these on file. Now, if you are conservative and you
give him the moncy and he starts dealing in options, he is really violating the trust that
the government and the NAFC is trying to establish between the client. I tell you what.
I feel sorry f o r you guys. You guys got a hell of a nightmare. Stan always backed me
up; there were times I pulled my investments out and put them in CDs for a while
because I was just not comfortable with what was happening. And, I tell him what CDs
to buy a t local banks. I have the utmost confidence in Stan. Mr. Kauffman tried
extremely hard to shake that confidence.
He tried to shake up my own family. He had my own family believing. Do you want to
know something. I n August, I was on my way to Hollywood to the film studio and to
see some legal clients I was working with one day
to get a night's rest. I get thrown in
- that
order against my family that didn't understand what was going on - I get retained in the
police station f o r two hours, get taken to a hospital. That day, someone called the
Stone Harbor police and said I had a gun and was running to the beach to kill myself.
This thing is ugly.
As a matter of fact, I would believe I am the only one left to believe Stan is still sane.
Well, I caught on real ~ u i c k . I don't believe he had anyone to talk to except me. I
didn't. 1 could talk to him every other day since April; someone had to believe what
was going on. I have tapes
client of mine
that I shouldn't been, and wasn't taking care of my clients. He told me the same thing.
that Stan had wasted away somewhere between $45,000 and $70,000 of his own money,
And, they
were both picked up last week, as a matter of fact. I was involved in that too. Right
there. I thought I heard
- is he connected with
- one of
that common a name, and I heard the name mentioned in the newscast of the NFL strike
and it was like - what was that, but it was too late. That Thursday, right after I called
you, was when I got the call.
Stan held his own free agent camp so that the players who didn't get chances in the
bigger camps had an opportunity to do it. 50 people showed up, from all over the
country. The most innovative camp
- I taped
55 teams. When was that, 84? Yes, right there it is. And some of them got picked up
as a result of this? Only one, my brother. I guess they had to have some body. Yea,
that was a fun day that day. That camp cost me 5 grand and generated so f a r
$200,000.00 in salaries for my brother.
That airplane that 1 bought would have made me $3,000 net profit a month, leasing it
out. I had a t least 20 hours of leasing every month for 350 a month a t $7,000, and my
payment was $1500.00. You were leasing it to? My contacts, my network. With you as
a pilot, you mean? No. It's a big plane. I hired my own pilot. When I'm doing
business all over the country I can't fly commercially. I three weeks, my charter bill
was 4 grand for using another person's plane 5 times. Then, you bought this. and before
the first payment was due they grabbed it back. Can they do that? No they can't.
Why do you think I've got a large lawsuit against 3 banks. One of the reasons they said
they did it was because it wasn't properly insured, but he had insurance. The other
reason they said, he took it to Florida. Now I don't know why you would buy $100,000
airplane and leave it a t the airport. Do you know why I was taking it to Florida? I
bought a place on a n island, another very good investment. Now they are suing me
because I couldn't settle because I got blackmailed 2 months later. They said I was
going to Florida to run away and hide. I was going to Florida to settle my property.
They had to come up with a reason so that's the reason that was around I guess. But,
Pete
anything about United ChemCon? They are being investigated right now by the FBI and
Attorney General. Chemcon is the big local minority-held corporation that was doing a
lot of defense contracts
beginning of the summer, and there was a lot of criminal allegations made, none of them
substantiated. And I was connected with that. They sent a Board Member in to see me
a week before this happened. Why, I don't know. Is this Lancaster based. Yes, Jim
Christian owned it
- now I hear
people in that organization. Why they sent someone to California to see me, I don't
know. They won't answer me. Who is this, the FBI? No, this is Chemcon. I said if
you ever come back or you have someone else call me, I want a $10,000 retainer fee.
Never heard from them since. Then, two weeks ago, Jim Christian called me while I
was in the hospital. That guy hated my guts for five years. Why, he called me, I don't
know. What did he want? I don't know. You didn't speak to him to find out? I spoke
to him, he said nothing. The same thing the Board Member said when he came from
California. Asked if I could go get ChemCon another building; asked if I would be
interested in saving the company from bankruptcy
guy from
Belgium, they wanted me to talk to, a guy from DC and New York, a guy from the
Caribbean. I don't know what the hell is going on. Then I find out the Commonwealth
Bank went and nailed ChemCon. Commonwealth Meridian said Christian personally signed
for the $18,000,000 that was invested or lost of the governments money for these
contracts. I don't know. I am sick of asking questions and people lying to me.
You don't have any connection with that, other than you knew some people? No, I've
got their files, I got their financial statement, everything
- they wanted
me to do
something. But you're not connected with the company? You're not an investor? No, 1
sold my ISC stock June 8.
A lot of people were saying that ChemCon. which is a minority - Christian is a black
guy
- was getting all the minority government contracts because he was one of the
leading minority defense contractors around, and actually the supposition was
know how true it would be
- I don't
Because when ChemCon was started, back to their inception, you look at ISC's book.
They didn't have any money. Well. the first thing ChemCon did, was they went and got
all that free money from the government and you look and see where that money went.
I bet you I know where it went.
This guy named Geurin, James Geurin. And I know that they were selling contracts
back. He runs ISC and he also has his fingers pretty deeply in ChemCon. He's the one
who started ChemCon, Geurin is the one who started it. Wasn't there some allegations
about a tie with Wedtack You bet. They were tied, you'd better believe they were tied
with Wedtack. The same guys in Wedtack were involved with ISC and ChemCon. ISC is
.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
21
exchange-.
and Control? I owned a thousand shares. I sold it when things started to hit the
Now they just did a multibillion dollar merger with a company in London
They probably think it is going to cover their tracks. You mean United ChemCon is a
local corporation. Yes, they went bankrupt as of this last 3 months. What was it,
$18,000,000 in liabilities? What they did was, they fronted all that money and started
the contracts, went bankrupt, now the government is stuck for $18,000.00. They weren't
paying employees, they weren't producing the product. they weren't paying their
unemployment and everything else. Did they pay the withholding taxes? No. It turns
out that Christian, who I have had a few dealings with, had a n office that would be
I know right now in this town's viewpoint, I stole money, I am insane, and I am a
lunatic. I tell you I will not condemn Jim Christian until he tells me to my face what
happened. I was framed and set up and I know (I see what you mean, your experience).
I don't know, maybe Jim Christian doesn't have the money. Maybe Geurin has it or
somebody else. $18,000,000 is a lot of money and he is broke because he lives with one
of my best friends,
if he took it, he would have something. You're pretty nice, Stan, to somebody who has
hated your guts for 5 years. I know what I am going through, a n d who knows, maybe
he was innocent too. Is this Christian you are talking about. Yes.
You were going to make copies of these. I can't make copies. I can f a x them to you.
I will make copies for you, in fact, what I should do is get everything copied for you.
Well, no, because that is a tremendous expense. I would rather, if you have the time, or
can stick me in the corner somewhere, maybe say, this and this, a n d this, I a m sure we
can eliminate half of it. O.K.but you should tell me what you want and I will make
copies. I just don't want this stuff to leave my hands anymore. I can get them to you
overnight. Well, there is nothing we can do overnight. I can't elevate your problem as
far as being out of the corporation
- oh, I thought
before you leave. So, anything that I would be involved in is going to be long and
drawn out; it is not going to be a n answer to your immediate problem.
I know, but I had to get someone involved. I had to get authorities to start taking
action for me.
the FCC
They said
they were sending 2 guys up here last week for 2 days. Did you talk to them about
what was going on? How did you happen to talk the FCC. I was just trying to get m y
money back. They promised me my money and they didn't come up with it. So, I called
. If
------
no, they were curious as to some of the other things that were
going on. I talked to them a couple of times. They were curious for one thing,
Kauffman wanting to take my investment and putting i t in the stock market and working
it for me, they were curious about that. They were curious about the allegations of
Stan's alleged insanity and forcing him out of the corporation, and I think they were a
little confused about why they would accept liability for the money if it wasn't there
liability. That would be a question that I would ask. I think that aroused their
curiosity, but he also said that they have never been checked, and they are about due,
so we might just as well go up there and dig into it and find out what was going on.
As f a r as I know, that is what they did, what they call a compliance examination. I
don't know that they were there looking
they looked into some items like that, but I think basically it was just a compliance
examination. What did they find? I don't know. They were there though? There was
two people supposed to be up there. Were they there last week? Well, it was recent,
the report isn't even written, but the report I think will be more on the lines that they
don't have a client complaint form filed
Proper
procedures, etc.
I am still interested as to how you wcrc alerted to it. I have yet to get it
- I was
coming down as an appointment last Tuesday o r Wednesday, which ever day, it was the
next day I called you. I had an appointment here i n Lancaster. I had gotten a call
about 4 3 0 in the afternoon from the Phila office, and my supervisor down there said
there is a newspaper clipping of your break-in of the Financial Management Group. I
don't know whether to make a n investigation out of it or not. It seems there are some
securities involved. The only 2 articles that appeared are right over there and none of
them say anything about it. They just know my name, right? They just knew that I
was involved with the company?
- it doesn't
Nothing a t all? Then how it came to our office I don't know, unless somebody sent it.
Even if they sent the articles, there is nothing i n there to indicate who
- they just
called me an ex-worker. That is the interesting thing about it. "burglary, theft,
unlawful restraint, robbery, unlawful use of computer, criminal mischief, and terroristic
threats." I've never seen the article. There it is, pull them down. No, that's alright.
They were supposed to send it up to me and they didn't. I'm leasing that building and
accused of burglarizing his own building.
See, he called me and said, you are going down to Lancaster. See if we should start an
investigation. Stop up to the
-- exemployee.
officer? Mathias, they said Lancaster Detective Mathias. He's not, he's Manheim Twp.,
fortunately I found that out. I called Township 2 months ago and they didn't help me.
Then they throw me in jail when my partners call.
So anyhow, I stopped up that evening, Tuesday or Wednesday night, the next day I called
you but did not get you until Thursday or Friday, so that is my association. They were
supposed to send up the newspaper clipping or whatever it was they had. But the only
thing I know is that your name was associated in our office computer file with Financial
Management Group. Your not telling me anything new. But you see I was supposed to
have this. Why I don't, I don't know because they were supposed to send it up. But
the state in their own way to save a .40 postcard, they have a messenger service to
Harrisburg. So, its alright if you get it in the mail, like if I was in the office this
morning and put it in the mail before 10:OO it goes to the central office and gets
distributed
you miss that 10:OO mail, it don't leave our office until the next day then the next day
in the central file. then somebody drives it down to Philadelphia. I should buy you
guys some stamp. I had to deal with the State that long so you know these are just
little quirks that keep popping up every now and then.
1'11 tell you an interesting part that I had when I went out to view - they had to
I was there to
get property returned to Stan, and Hartlett started going through things and paying a lot
of attention to what was there, and had already admitted wasn't his. There was a lot of
correspondence there, he was very interested in, and the policeman even came to my aid
and made him not be nosey. even its yours or it isn't, and he released everything to me.
Do you know what I took out of the office was on the books, everything that I wanted
to see. Did they let you keep that? No, no, in fact the inventory from the service
warrant, just about everything on here is Stan's files, even labeled as such. Then I
found a
they returned that to Kauffman. K & H, what do you think that stands for? Kauffman
and Hartlett. Well, that's what the initials stand for but what type of business? I
never heard of it. You don't know what it would be? I can imagine what it would be.
A brokers business somehow? It's something fishy. I can't remember the bank, I think
Well, who mentioned to you about medicine. I t wasn't Mathias; Seigler was involved.
Why, how did they get wind of that? Harlctt and I were there and Hartlett was talking
!
That's what Hartlett was telling him. And Hartlett was saying is he taking care of
himself and all of this stuff. That son of a bitch. He is really painting a nice picture.
Well, the cops didn't really buy it because they asked Hartlett to leave and they gave me
the information that they told Hartlett they weren't going to give me.
Yea, well they mentioned the things that you had taken, a couple of items, that they had
given back and allowed you to have them. They gave all the files back to FMG before
we were involved and then he gave me the personal correspondences, but they kept his
camera. Apparently, Stan was doing the policeman's work when he was in there the
night he was accused of burglarizing the place. He took pictures of all his files i n their
office and they said they had better keep that.
This is June 30th. It is my files in their office. That's the night I left. Who's taking
the pictures? A friend of mine. You were with someone? This was 3 o'clock in the
morning. Oh, you weren't arrested on the premises, were you? No, but this is when I
was in the office. This is when they stole my files out of my locked doors. He was
there then, I guess. These aren't the films that you are talking about? No, the films he
is talking about I took of my files again in their office, and attorneys say they didn't do
anything wrong
for 5 days.
This is the stock certificate book here, this big black book? Yea. You are still
connected with the company here? This is June 30th. The funny thing is, even the
second one is not breaking in
He
is still President and a t the time he was still Secretary I guess. I don't think the police
feel too awfully strong that they have a burglary type charge. I know. Well, I tell you
what, they abused me the night they arrested me.
me up here left me ride on the front seat and everything. When I get to Township,
handcuffed me, put my hands to the belt, threw me in a cell, bounced me around the
car. They wouldn't even listen to who I was. I had all the documents to hold them
that I was lease holder of the building
- wouldn't
anything. I know why they a r e acting nice now. They are going to hear from my
attorney.
I don't know who even made the complaint, whether it was the girl who made the
complaint. You were arrested the next day? No, that night. I told 5 people that I
wanted to arrested that night: I had to. But then somebody had to call the Manheim
police. Do you know what they did? They called up the police that day and said 3 days
previous t o that, that I made a bomb threat to that building
picked me up for. Oh. really?
- that's
for. Then, while I was there they charged me with the burglary. They initially picked
me up for a terroristic bomb threat, that took FMG three days to report, they couldn't
even remember when the phone call was, and the person that reported it, I don't even
know who she is
roughly what time? I went there about 10:30 Thursday night; you were there an hour?
Not even that, about a half hour. I left and dropped off at
, had a drink,
and got a girl to take the car I had, I borrowed somebody's car because my cars were in
New Jersey
- I flew back,
Conestoga police were right behind me. I said, great, they're here. And when the
Conestoga Twp. cop, I said, let me take all these files with me so I can show you guys
who I a m and what I was doing. Well, they just took everything and threw me in the
.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
26
Well, let me get started. I didn't read these letters yet. Read that one letter right
there.
That's right we have that other thing now. Yea, he's being sued civilly f o r this office
furniture here which was purchased from FMG. But FMG then tells the Office Supply
Store that he has not connection with us. When they have my suite of furniture in that
building. Oh, that what the pictures, is that your personal furniture? You bet. I
purchased this in June to go down to Stone Harbor; see the movie that I was working
on, FMG was to get 15% of the profit f o r my endeavors down there. This was purchased
as a n agent of Financial Management Group.
admitted
by Guerin
company
by Ernest Schreiber
andTim Mekeel
L A W OFFICES
CRAIG V R U S S E L L
GARY G
KRAFFT. G R U B E R & H U B E R
~
KRhFFT
J O N M GFIUDFR
dOHN E
*USER
(717)569-5383
CHRISTINA C. HAUSNER
October 2, 1987
2.
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TO:
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18 Pa.C.S.
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HUBER
~anagement~ro&, Ltd
1729 Lititz Pike
.Lancaster, PA 17601
(717) 569-5383
Date:
October 2, 1987
cc:
COMMONWEALTH OF PENNSYLVANIA
. CATERBONE
STANLEY J
WAIVER OF ARRAIGNMENT
Ocbbber 5, 1987
AND NOW,
that mycasels
before the Criminal Division of the Court of Common Pleas of Lancaster County,
, . . will be called-for!trial
,
'Pa., a t thekourt House, Lancaster;Sa., on
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(trial date)
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STAXTLEY J
. .CATERBONE
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Attorney'for Defendant
ROBERT D. BEYER
By signing the above Waiver of Arraignment, the undersigned attorney for defendant hereby certifies thpt he has
given said defendant all of the advice required for an effect~veand valid walver of arraignment.
Robert D. Beyer
Attorney for Defendant
1 1 0 81 Kinp S t r e e t . Lancaster, PA
Address
17602
344-7204
Telephone No.
:6 2
10/19/2006
REMIT TO
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AVID G. HoMsHER
ARNOLD. BRKKEX BEIEII G BA
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LESLIE GORBEY
IAMES P COHO
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ROBERT D. BEYER
& HUYER
1729 L i t i t z Pike
Lanczster: PA 17601
Dear C r i s s :
October 2 , 1987
Mr. Caterbone on
as well as t h
a r y Hearing t h e
a g e tcio
Christina L. Hausner, Esquire
Cctober 9, 1987
Robert D. Beyer
RDB/reg
cc:
Stanley Caterbone i/
A R I ? ~ T R O D U C T ~ GTO
~ J IKTERCON SPECIAL SERVICES INCOk\PORATED
The o f f i c e r s a f I c t e r c o n r e a l l f o r m e r S p e c i r ! \ g e n t s o f
t h e F . B . 1.
T h e i r combi.:ed e x p r i e n c e i n g o v e r n m e n t i n v e s t i g a t i v e and p r i v a t e s e c u r i t y f i e l t ! : : t o t a l s o v e r 100 y e a r s .
The
members o f I n t e r c o n ' s i r ~ v e s t i c , ; ., i v e s t a f f h a v e a1 1 h t ~ dp u b 1 i c
l a w enforcement and p r i v a t e i n s t i g a t i v e e x p e r i e n c e and t h e y
i n c l u d e C e r t i f i e d P u b l i c A c c 3 ~ : i a n t . s w i t h b o t h b u s i n e s s and
I n t e r n a l kevenue S e r v i c e e x p e r i e n c e .
We h a v e c o n d u c t e d s u c c e s s ! i i l i n v e s t i g a t i o n s f o r some 3 f
t h e m o s t p r e s t i g i o u s l a w f i r m s . a n d some o f t h e l a r g e s t c o m p a n i e s
i n the world.
T ; ~ e j e i n v e s t i g a ' t i o n s have i n c l u d e d 3 r e - t r i a l
i n v e s t i g a t i o n s o f %any t y p e s i . ! t . l u d i n g c o n t r a c t v i o l a t i o n s ,
fraud, t o r t s , d e f a l c a t i ~ n s , l . i > e l s , embezzlements, p a t e n t and
c o p y r i g h t , a r s o n a n d i n s u r a n c e r e c o v e r i e s . He h a v e h i d s u c c e s s f u l i n v e s t i g a t i o n s i n v o l v i n g c.!rporate a c q u i s i t i o n s , takeovers.
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e n ~ e r t a i n m e n tf i e l d .
We h a v e c o n d u c t e d d e t a i l e d S e c u r i t y s u r v e y s f o r some o f t h e
p r i n c i p a l banks, c o r p o r a t i o n s , u n i v e r s i t i e s and governmental
agencies i n t h e U n i t e d S t a t e s t o a s s i s t them i n enhancing t h e
physical sesurit y o f t h e i r prenises.
F o r l a n d l o r d s a n d l e a d i n g r e a l t y management f i r m s we h a v e a l s o
conducted such s e r v i c e s as - s e c u r i t y s u r v e y s , b u r g l a r y i n v e s t i g d t i o n s and work up o f t e n a n t s " p r i m a r y r e s i d e n c e " t y p e c o u r t cases.
( ,
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O u r o r g a n i z a t i o n was e s t a b l i s h e d i n 1 9 7 2 a n d i s l i c e n s e d a s
p r i v a t e s e c u r i t y a g e n c y b y t h e S t a t e s o f New Y o r k a n d C o n n e c t i c u t .
We a r e b o n d e d a n d f u l l y i n s u r e d .
W CIVIL
EAST 42N0
STREET-SUITE
370-4430 15, 2016
EXHIBIT U.S. 16-4014
RIGHTS
CLAIM 1045.NEW
Page 425YORK.
of 646NEW YORK 10165. TELEPHONE
Thursday(212)
December
Property of Advance Media Group
?Gfi
10/19/2006
M i c h a e l M. O ' R o u r k e .
St.. J o s e p h ' s C o l l e g e , A.B.,
U n i v e r s i t y , M.B.A.
F . B . I . 1942-1965, L i a i s o n and
New YTF~
Pub1 i c R e l a t i o n s S u p e r v i s o r .
Director o f Security, A l l i e d
S t o r e s 1965-1968.
D i r e c t o r c f S e c u r i t y , American B r o a d c a s t i n g
Company i 9 6 8 - 1 9 7 6 , r e o r g a n i z t d a n d d i r e c t e d t h e p l a n t a n d
After
p e r s o n n e l s e c u r i t y f o r ABC a1.d i t s many a f f i l i a t e s .
r e t i r e m e n t f r o m ABC, c o n t i n u e d a s t h e i r c o o r d i n a t o r o f
s e c u r i t y f o r World Olympics a t Innsbruck and Montreal.
Paul P i c c o t t i .
George k a s h i n g t o n U n i v e r s i t y .
University
o f S c r a n t o n , M a j o r i n E d u c a t . ~ o n a n d I n d u s t r i a l Management.
E x p e r i e n c e o v e r t w e n t y y e a r s i n e l e c t r o n i c computer and
c o m p u t e r s e c u r i t y f i e l d w i t h RCA C o m p u t e r D i v i s i o n a n d MSC
Computer Systems, I n c .
Has s e r v e d g o v e r n m e n t a g e n c i e s a n d
b u s i n e s s f i r m s i n c l u d i n g bani:ing, t r a n s p o r t a t i o n and i n s u r a n c e
t o r e v i e w and e s t a b l i s h s e c u r i t y f e a t u r e s f o r b o t h computer
programs and computer o p e r a t i o n s .
111 1 LKLUN
SPECIAL bERVlCES,
INC.
Section
3189 Federal False Claim Act
Frank R. Ger,rity.
S c r a n t o n U n i v e r s i t y , B.S. i n
a u s i n e s s A d m i n i s t r a t i o n , G e o r q e t o w n U n i v e r s i t v . ' LLB.
F.B.I.
1950-197:.
S u p e r v i s o r M a j o r i h e f t Squad, c r i m i n a l D i v i s i o n .
C o o r d i n a t o r Organized Crime S e c t i o n .
F.B.I.
Polygraph
Coordinator.
D e m o c r a t i c N a t i o n a l C o n v e n t i o n , New Y o r k C i t y
1976, o r g a n i z e d ayd s u p e r v i s e d F.B.I. s e c u r i t y d e t a i l and
managed l i a i s o n w i t h a l l o t h e r a g e n c i e s .
John J . Danahy.
Columbia
G e o r g e r o w n U n i v e r s i t y , A.B.,
linive-y
LLB.
F . B . I . 1942-19.63.
B o t h C o u n t e r 1 . n t e l l i q- e n c e
and C r i m i n a l S u p e r v i s o r .
Director o f Security, National
F o o t b a l l Leasue 1968-1980.
A u d i t e d s t a d i u m s e c u r i t y f o r 28
member t e a m s .
S u p e r v i s e d a1 : s e c u r i t y a r r a n g e m e n t s f o r 1 2
S u p e r B o w l s , i n c l u d i n g game s i t e , t e a m r e s i d e n c e s a n d p r a c t i c e
s i t e s , p r e s s and o f f i c i a l s ' p e r s o n a l s e c u r i t y .
Lectured American S o c i e t y I n d u s t r i a l S e c u r i t y and I n t e r n a t i o n a l
A s s o c i a t i o n o f Campus Law E n f o r c e m e n t A d m i n i s t r a t o r s .
Has
o r g a n i z e d and s u p e r v i s e d m a j o r s e c u r i t y a u d i t s p e r f o r m e d b y
i n t e r c o n i n b o t h p r i v a t e and p u b l i c s e c t o r s .
.
; i o m a s ?i.,iolan.
St. t.. . : I I I I ' S U n i v e r s i t y , 6 . S . - i t , > i i 5 . : . 1 : $ ~
Administration:
S t u d i e d e l e c t r i c a l e n a i n e e r i n q Mantiattan
L 3 1 1 ege, M i s s i s s i p p i S t a t e a n d ~ e o r ~ i a - ~ e c hf o. m m u n i c a t i o n s
O f f i c e r , U.S. A r m y .
N.Y.C.P.D.
1946-1951.
F.B.I.
1951-1959,
Criminal Supervisor.
President, Tolan Investigations, Inc.
1 9 5 9 - 1 9 8 0 , i n v e s t i g a t i v e and s e c u r i t y c o n s u l t a n t s s p e c i a l i z i n n
i n i n d u s t r i a l , r e t a i l and r e a l t y problems.
Joined Intercon
1980. P o l y g r a p h e x a m i n e r .
Supervises and conducts a l l t y p e s
o f i n v e s t i g a t i o n s and s e c u r i t y s u r v e y s .
Specializes i n investigations involving r e a l t y matters.
Member o f N a t i o n a l Law
Enforcement A s s o c i a t e s and A # l e r i c a n S o c i e t y f o r I n d u s t r i a l
Security (holds t h e i r C e r t i f i e d Protection Professional Rating).
New Y o r k C i t y F i r e depart men^ a p p r o v e d F i r e S a f e t y D i r e c t o r .
Page
427 YORK.
of 646NEW YORK
1045. NEW
520 (TATS)
PageTELEX
2533 of236
2953
Thursday(2123
December
10165. TELEPHONE
3704430
15, 2016
10/19/2006
The only
will need
than both
costs is
By law, I need a
One other condition still needs resolved.
certificate from the City of Lancaster which states that the
property meets all City Code requirements. Section 6 (b) requires
that the responsibility of this lies with the Seller. Therefore,
I will insist on reimbursement for all fees and work performed to
bring this property to Code standards. The fee for the City Code
inspection is $50.00, which I paid today, and there is some
electrical work needed which is scheduled for later in the week.
D
L
P
~
/
B
Sin erely,
anes D. Warner
w,reaid(e> D ~ 0 1K velaware N A
US District Court For C
The
Eastern
of Pennsylvana
RE
D I T District
ACCOUNT
CENTER
COLLECTION DEPARTMENT
P.O. BOX 8 9 2 3
bJTLMINGTON, DELAWARE 1 9 8 9
'
10)
833-3012
CONTACT:
I
M FERRIOLA
OCTOBER 28,
@@
CoreStates Ban
of Delaware H A
1987
STAN J CATERBONE
2 3 2 3 NEW D A N V I L L E P I K E
CONESTOGA
PA
17516
ACCT.
NO.
4261620027015
BALANCE
CREOIT L I M I T
AMT PAST DUE
$3559.27
$3500.00
$280.00
....
..
DEAR STAN J CATERBONE
(3
C O L L E C T I O N DEPARTMENT
C R E O I T ACCOUNT CENTER
CD8Y0,
t.,c
h a d l a i l c i l t n r u ~ ~ p l y ~ n l o r r nbut
~ti~
e,t~ ~all, of ~ c r r a ~ t , . ~
" " t i an nccounl of any profitr
to backuplllsrerslolluft~bmfs
<ourl r l a i m s a C a l n s t ~ u ~ r i n ,
mndetllmuyhtheallepedfraud,
C a r i # n ,who buill l n l r r n a t ~ o a Jartlce l l a f f m n n said Cuerin a" ("II Fcrranla who else was
Br8tish iustlce < d a y ur. a1 Slilrial & Contrnl mtcl an hacl fclilrd to explain what h a p in'o1"edinlhrsrhrme.
U : ~ WOrld~idrconelumriatrdllrlng p ~ n r dto money mlsring fmm
Gu*rin, i n a brief telephone
deren former L ~ ~ I C ~ S dc.
ienrcronlrarlor
H G L S C . th? I!IHUS. had t r . ~?haiged
the accounts of ISC ~
~ ronversatlon
~
fmm
h hi, hame
~
n n to pay SIW million to lr,,
lalu 1989 with rhratini: F ~ ~ C . Z I plea ~ t d and
.
ISC ~~~d~~ PLC
Naples. F I ~ , said he was una~
~
~
~
~
t 11. ia nrltish
~
~defense
b
~ a- ~
d of, the~
~
~ in
~ hi; ~ ware of the court deciaon. ~e
,ha, hr~
rorpol
two
r e i c r r d calls t o his
Ilsn, out of an rstimafcd $350
conplomeratc.
legedlydrfravde~l.
High Coud Jusl8ee MI. IPII~
m ~ l l ~ o n r l i c n l h r t w o c o n ~ p ~ ~ n i In
i s addition to repaying the Joseph A. Tate of Philadelphia,
m a n r c ~ ~ r tGr UdC ~ ~ ~ drnial
,'S
of m r r e e d
m8srxnp manry, the judge
who could be reached immedir e i p ~ n s l b s l # l yfor the ollcgud
Brlthrll press RCCOUII~S i m d t i ~ e i i nmust pay u n p ~ e i t i o d a t e l y f o r e o m m m l .
frauds brrruae, h r raid, Gaerin t o d a ~ ' s d r r i s ~ o n r r r u l r rsome.
1lrmn8cs and rorlr, give ~ e r F c r r a n t i a t t o r n e y .
d
had
%*fmedschrelber
sIBIIW~I~~
~~8
'
law"~a ' m d m
l the company's
~
s"'Lthal
inheclted subsldlar
ieswhose value was grn=ls i n
fldted by fake dcfmse c o n
~~t~~~~ 1 0 ~ 4md 19m,
F~~
rant, claimed, i t p a d
s4i0
man c o m p a n ~ r rf n r u
flcr~llarurrontrarts
When queslloned
contracis. ~
~
rin yrvc " n a n - a d m ~
"dc"ials." lluL no1 a n
wha'lladacrurred
~ ~ ~W C U
~ E RbI I
LANCASTER
NEW ERA
METROPOLITAN
w-.r-
s,m.W.6+
Residential
Appraisal
Specialists
Inc.
October 29, 1 9 8 7
Mr. Michael Caterbone
Mr. Stanley J . Caterbone
HD 1 New Danville Pike
Conestoga, PA 17516
Dear Sirs:
day
or
so we-will call
you
to
set
up
an
l i l i i 394-7204
,AVID G. HOMSHER
l O H N WILLIAM BEYER
LESLIE GORBEY
IAMES P. COHO
,1919-I9861
ROBERT D. BEYER
M r . S t a n l e y J . Caterbone
2323 New D a n v i l l e P i k e
Conestoga, PA 17516
Dear M r . Caterbone:
I am e n c l o s i n g h e r e w i t h your copy of t h e waiver of a r r a i g n m e n t
I r e c e n t l y f i l e d on your b e h a l f . Accordingly, you may now d e l e t e t h e
scheduled a r r a i g n m e n t from your calendar.
which
I a m i n t h e p r o c e s s o f p r e p a r i n g a n i n f o r m a l d i s c o v e r y r e q u e s t t o be
s e r v e d upon t h e L a n c a s t e r County O f f i c e of t h e District A t t o r n e y . A s s o o n
as I have r e c e i v e d a r e s p o n s e from them, I w i l l be i n touch w i t h you i n o r d e r t o
schedule
a m u t u a l l y c o n v e n i e n t d a t e and time t o d i s c u s s o u r p o s s i b l e d e f e n s e s .
Very t r u l y y o u r s ,
,-..,
Robert D. Beyer
RDB/reg
Encl .
NOTICE
~ O M M O N W E A L TOF
H PENNSYLVANIA
US DistrictCEPARTMENT
Court For The Eastern
District
of Pennsylvana
OF LABOR
AND
INDUSTRY
0F
Page 2 o f 2
1 2 1 0 1 0 1 4 1 6 1 0 1 9 1 5 1 91
I
PD U C
Type Claim
RIGHT OF APPEAL
I F YOU OLSAGREE WlTH THIS OETERMINATION,
YOU MAY APPEAL IF YOU WISH TO FILE AN
APPEAL. YOU MUST DO SO ON OR BEFORE THE
DATE SHOWN ABOVE. SEE BELOW FOR APPEAL
INSTRUCTIONS.
Claimant
Stanley J. Caterbone
2323 New D a n v i l l e P i k e
Conestoga, PA 17516
and
10-1 8-87
AE Date
Name
11-2&-87
is
DETERMINATION
FINDINGS OF FACT
DETERMINATION
'402('
DISAPPROVED undn ~ k t i o n ( d
under Sstlonlsl
of ma Law:
Application fw ~
of ma ~ m :
t Dated
1
pCY-M
mwd
lS2h47
10-31-87
Miladon:
11-9-87
mli~radon:
SIGNATURE OF OES REPRESENTATIVE
DATE
APPEAL INSTRUCT^. Undw S o d o n 601(el d tho Pmnwkanb Unmplovm*m Comwnmlon Law. thk r(.trml~tion b r o m r fl-I ur
a p m l lstlrr*lvfll.d. I f you dltagm.wlth thlldmrmlru!lon. vou r n . v f I l * ~ n a ~ a
~ tI h e 0fllnwh.nvov.n
chlmlnpb.n.(morfll.~n.p~l b
I+the .
-I
Is n1.d In -n.
It mum be fl1.d on or b d o n the Intd.v m .pp..l *om in th.u p p r
Ifme .pwI Is f1l.d by MII. the nppoml l m o r mum lnelud. v w r rum. and
r s u r l t y numbr, and sua p c H l a l l v mn you w l h
an . o w l from thls d*t.rmlrutlon. The a p p u l lmr m u l t be add&
m
Pmt"vlv.nh
O f f l w of dmploym.ntScurlty whish .pr
the l o w , rl*t corn* and p0stm.rk.d on w bofon tho 1a.t dav ta a p p n lhorrn In t h - u p w rlght conwr.
EMPLOYER: THlS IS NOT A DETERMINATION ON RELIEF FROM CHARGES
STATE JOB SERVICE OFFICE
rwt -.
Employer
C?
49.5.C
Name
And
Address
uc-44
ma
-I
PY;-.-L
:s,.:
F-9-y-r-+
5.c..2
:,',::,,,
- h,
:trcct
f r.::,2ce
FA lib03
0312
-I
L
~
'2::
for
Provisions of t h e
Law
COMMONWEALTH O F PENNSYWANIA
Section 3189 FederalNANCY
False Claim
Act
L. DIANA
ROBERT P. CASEY
Secretary
ROBERT
M. LAM
US District Court
For The
Eastern District of Pennsylvana
Chairman
Governor
EDERICK H. PLANK
ELIOTT KLElN
Chief Counsel
J. Caterbone
New Danville Pike
Conestoga, PA 17516
2323
RE:
Yours truly,
Howard L. Eissler
Securities Investigator
HLE:sec
Enclosure
j.
10/19/2006
I I
STANLEY .J.
CATERBONE
HOAU
STONE WARBOR. N J 08247
MR.
c.=-.sa-? HERKEI..EY
ACCOUNT P R E V I O U S L Y RENDERED
US.
STATEMENT
BALANCE
INTEREST
W I L L I A M h BETTY O'klAFiA
9824 AUGUST
18 1987
3.0026 SEPTEMBER 21 1987
Slt362.50
ss0.00
$46.57
$1.14
CATERDONE.
%1.4(
e:
STANLEY J
' J017
I N T E R E S T WILL HE CHARGEKI AT
1.00%
PER MONTH ON ACCOUNTS U N P A I D 30 DaYS
AFTER
T H E DCIVIL
A T E RIGHTS
OF THE
STATEMENT.
EXHIBIT
U.S. 16-4014
CLAIM
Page 437 of 646
----
-..-r..h."m n
lUUJlllOl
JCI V l C e S
..-..-..--
GLOBAL E N T E R T A I N M E N T
GROUP LTD.
PO BOX 40
CDNESTOGA, P A
17516
SAME
DEPT: 2
1
<
DUPLICATES
DIAZO DUPLICATES
SILVER
~..
'8
c
GROSS AMOUNT
930.54
TAX
55.84
9
-
FREIGHT
1.
(
ORIGINAL INMiCE
:*\
C
2 unwr
t
.tt****'
R
*
RE:
Dear P o s t a l Customer:
I have r e c e i v e d a complaint concerning t h e a l l e g e d f i l i n g o f a f a l s e
change o f address o r d e r f o r y o u r m a i l .
<-,
Sincerely,
Postal Inspector
215-921-7101
Enclosure
QUESTIONNAIRE
(FALSE CHANGE O F ~ D R E S S )
YOUR NAME:
{0./3&
ADDRESS:
COMPLAINT NO:
\-.-
08662
A/L---Q~&~
/4/7LT/6
PHONE NO:
1.
7Zd
/.d-f
Yes
NAME:
%4,/3
/7$3-
ADDRESS:
L] No i]
- 20~mL-r
~ F A W
o&w~-&
/dgc,/~&r/ J ~ L T L & / T
?A,+
Aurs
,A
J /
d d L
3.
flqAzcn?&
/
'
Yes
N0I-I
4.
(i.e.,
Yes
No
&$&7,2.
'
YouyIsiy6ature
F+L.
Date
..
k. ..
I..
COMPLAINT NO.
DOCKET NO.
NOTICE DATE:
717 569-8?74
PLAINTIFF:
DEFENDANT:
Scott Robertson
1755 Gregon P i k e
vs.
LancJster,PA
17601
J.
L
THlS IS TO NOTIFY YOU THAT:
q THE DEFENDANT
(name) StaAl~?yC a t e r t a n c
=JUDGMENT WAS ENTERED FOR
OJUOGMENT WAS ENTERED AGAINST Inamel S m t t RObaztson
I N THE AMOUNT OF
ON (date) Jao3JaEY 7. 19BO
q DAMAGES WlLL BE ASSESSED ON Idate & time)
O T H I S CASE STAYED UNTIL FURTHER NOTICE.
THlS CASE DISMISSED WITHOUT PREJUDICE
POSSESSION GRANTED
q POSSESSION NOT GRANTED
q LEVY IS STAYED F O R OAYSOR OGENERALLY
STAYED
07:
$2035.42
1:
'i.
*;
OTHE
PLAINTIFF
,:
,/
..
'
I &
&?
. .;.
t&?&&b2$ :J$>Z~@..:
(signed)
(SEAL)
/District Justice)
31684
. .... :...
..i
,s, .,! >'.
.
'
nPlalntiff'$ Anornsy
nDefandant'r Attorney
PLAINTIFF OR PLAINTIFF'SATTORNEY
_(
I__.-.
Thursday December
15, 2016
i/
10/19/2006
-~~
~
Christian denied
reduced sentence
- .
-- ..- . --..-.
...
c..-nuauas
R EDistrict
V d.81 Court For The Eastern District of Pennsylvana
US
,.
~ vnc ~K C V I C R
REFEREE'S DECISION
5 . 5 . A C C T . NO.
APPEAL NO.
/ \
rStanlev
Cat9rbne
23?3 N e w Danvillc Pike
Conestcqa, Pa. 17516
,T.
I
D A T E A N 0 N A T U R E O F OFFICE O F E M P L O Y M E N T S E C U R I T Y 5
OECISION:
- -- -
- c'
12/16/87
HEARING APPEARANCES:
_ ___
- Lancaster,
O A T E O F APPLICATION
FOR BENEFITS
Penn~lvania
COYPENSABLE WEEK CNO
10/18/87
10/31/R7
CLAIMANT
EMPLOYER
OES REPRESENTATIVE
10/24/87
CLAIMANT APPEAL
EMPLOYER A P P E A L
FINDINGS OF FACT:
Cj
1.
2.
me
0
- 3.
- 4.
i'
5.
The c l a j m t , tcqether with the president and other vice president, set pnlicv
f o r the corporation.
6.
The claimant w a s rcspcmsihle, alnnq with the other two corporate principles,
f o r h i r i n g and f i r i n q . me claimant siqned checks for t h e c o ~ p o r a t i o nand had
as much authoritv as e i t h e r of the other t m persons.
7.
clamant f
on &une ,
%:00 W cm ilulv 1, 19P7, the claimant entered t h e e m p l m r ' s premises and
r
~ ~ k cmpxtcr
s ,
alscs, tiles, m r d s and s o w o-rl
m
e
v
'
s o f f i c e a f t e r which he
Property
of Advance
Media
Groupthe
NOTICE:
You
have
-.
2550 of 2953
10/19/2006
r i g h t t o f i l e aPage
further'appesl
within 15 davs a f t e r the mail
in^ d ~ t e
~IFMG
Advisory, Im.
l
N
Edrn Par* 11, 1755 O n g o n Pike
=?L2!!-w-5"
Lancastrr. PY 1760f
717-560-4100
STANLEY J. CATERBONE
PRESIDENT
A P P ~ Amm:
L
300
- YL- o 9 C 7
/#/=s/87
I will outline to to you the circunstances that lead to the Action taken
by mgself and James Warner on July 1, 1987. First you w s t read the enclosed
transcript that was placed cn the Complter System that I desijmed at 1755
Oregon Pike, hilding to which I, Stanley J. Caterbone, is currently a
leaseholder of title. This transcript was proceased on or about May 2. 1987.
- -
QI June 23th, 1987 I had the locks on my office changed for Security
Reasons. I will not defend my CONSTImIONAL Right for Privacy regarding this
issue! On June 29th, 1987 I was told by Mr. Kauffman that he had issued a
Stock Certificate to Peter Peneros for 8,000 shares of Financial Elanagement
Group, LTD.. Although I quickly asserted that I was the Corporate Secretary
and only I was authorize to Issue the said Certificate, and my signature was
needed to finalize the transaction. This can be substantiated by New Jersey
Bell, since I was in Stone Harbor, where I w a s calling from. However my real
problem----My Office was burglarize by the President, Robert Kauffman, and the
Executive Vice President, Michael Hartlett. That was a NO NO ! ! ! !!!
hring the course of our First Year, I have discovered many action and
activities of Michael Hartlett and Robert Kauffman, as well as other persons
affiliated with this tragic but true nightmare. These allegations have been
revealed to several authorities and various representatives of the respective
local, state, and federal agencies, specifically the Pennsylvania Securities
and Exchange Comnission, and the Office of the Postal Inspector in Harrisburg,
to which official Complaints were already filed. During the month of May, I
have found substantial evidence to collaborate the said allegations, however
due to the complexity of the Corporations and Buainesses involved as well as
the relationships of all involved, I wanted to handle these affairs in the most
delicate and professional manner possible. W e n making this more bizarre is
the presently turbulent and mismanaged Securities Industry. This can be
substantiate in my letter to Diane Sawyer of CBS 60 MINWES, on August 28,
1987. I had several conversations with outside legal counsel, in particular,
Randy Grespin of The Underwriters Group, of Harrisburg, one of my affiliates.
We had discussed several courses of action, one specifically was a 90 leave of
ah-,
with pay, to take the appropriate time necessary to unravel this legal
NIGH'IMRE! As I began to gather material evidence to these allegations, my
life became very difficult because business was taking me out of town on a
daily purpose, which was the reason for the p m h a s e of my Navajo Cheiften
Airplane. I was virtually supervising every aspect of our operation, trying to
keep within the appropriate LBW9, Rules, and Regulations of the respective
authorities. I more than anyone was especially sensitive to these anrtters,
because of my knowledge of the said Rules, Laus, and Regulations. I was also
concerned for the following Reasons:
1.
2.
IR"
wanted
UNTIL THIS 1lTH DAY OF JANUARY, 1988, STANLEY J . CATERBMJ3 HAS NEVER
CORRXATB RECOW)S, TO WHICH I AM ENTITLED,
I HAVE NBVER
RECEIVED ANy w R 1 m OR a?AL coEf.IuNICATION mad ANY PERSONS AVTIMRIZED BY IRIE
CORRRATE BY LAWS REG4RDINC ANY TERMINATION mad THE ABOVE MENTIONED OFFICBS!
RECEIVED
I would ask that you copy me a copy of the transcript of the Appeal
Hearing.
<.
Regretfully,
Grandview Offices
796A Rear. New Holland Avenu
Lancaster. PA 17602
717-299.8914
Stan Caterbone
--
(717) 464-2601
(717) 464-2311
Section 3189 Federal False Claim Act
2718 W i l l o w Street Pike
WILLOW STREET, PENNSYLVANIA 17584
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written request for a hearing within 15 days of the p s t m r k date of this letter. T
ring may be on-ducted by a telephone conference call. Therefore, you nwst inciude yo
is request
kle&one number. Fkquests f o r hearings must state the reason(s) that a hear*
ud must k sent f i r s t class, register& or certified m i l to: Chief Counsel H e a r i
Request, Eemsy1vani.a HOUS~I?=J Finance Agency, 2101 North Front S t r e e t , P. 0. Eox 15628
with
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s-Y,
EXHIBIT
U.S. 16-4014 CIVIL RIGHTS CLAIM
I t
Property of Advance Media Group
EXHIBIT "E"
Page 450 of 646
Page 2556 of 2953
65y
NO.
A c t i o n i n Mortgage
Foreclosure
1988
VS.
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NOTICE TO DEFEND
-? (0
Court A d m i n i s t r a t o r
Court Administrator's O f f i c e
L a n c a s t e r County C o u r t h o u s e
50 North Duke S t r e e t
L a n c a s t e r , P e n n s y l v a n i a 17602
Telephone Number (717) 299-8041
.-
N O T I C I A
S i usted quiere
Le h a n demandado a u s t e d en l a c o r t e .
d e f e n d e r s e d e estas dernandas e x p u e s t a s en l a s p a q i n a s s i q u i e n t e s
u s t e d t i e n e v i e t e (20) d i a s d e plazo a 1 p a r t i r d e l a f e c h a d e l a
dernanda y l a notification. U s t e d d e b e p r e s e n t a r u n a a p a r i e n c i a
e s c r i t a o e n p e r s o n a o p o r abogado y a r c h i v a r en l a c o r t e e n
forma e s c r i t a s u s d e f e n s a s o s u s o b j e c i o n e s a l a s demandas e n
contra de s u persona.
S e a a v i s a d o que s i u s t e d no se d e f i e n d e ,
l a c o r t e t o m a r a m e d i d a s y p u e d e e n t r a r una o r d e n c o n t r a u s t e d si:
p r e v i o a v i s o o N o t i f i c a c i o n y p o r c u a l q u i e r q u e j a o a l i v i o q u e e:
p e d i d o e n l a p e t i c i o n d e demanda.
Usted puede p e r d e r d i n e r o o
s u s propiedades o o t r o s derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. S I NO TIENI
ABOGADO 0 S I NO TIENE EL DINER0 SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABASO PARA AVERIGUAR DQNDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Court Administrator
Court A d m i n i s t r a t o r ' s O f f i c e
L a n c a s t e r County C o u r t h o u s e
50 N o r t h Duke S t r e e t
Lancaster, Pennsylvania
17602
T e l e p h o n e Number (717) 299-8041
HZXTMAN UNDERHILL & BRUBAKER
Attorneys f o r P l a i n t i f f
By:
221 E a s t C h e s t n u t S t r e e t
L a n c a s t e r , PA 1 7 6 0 2
(717) 299-7254
Date:
For professional services rendered from September 8 , 1987 through March 15, 1988 a s
follows:
09/08/87
Prison visit
09/09/87
09/09/87
conference a t M.T.P.D.
checks
Letter to client
Letter to client
Telephone to Atty. Russel
Telephone to Atty. Russel
Telephone from attorney re:
District Justice
Letter to client
Telephone from client; telephone to Attv. Russel; telephone from Atty.
Russel "today"
Letter to District Attorney, letter to client with discovery request
Telephone from District Justice Horton
Prepare release
Telephone from client
Letter to client
Conference with District Attorney
Telephone from client
Phone call a t home
Conference with client
Letter to client re:
Corestates
03/03/88
03/04/88
03/08/88
03/15/88
$2,274.00
$ 200.00
Final Bill
RDB/ds
LANCASTER. PA 17602-2876
IOHN W. BEYER
HARRIS C. ARNOLD
i i l i l 394-i204
DAVID C. HOMSHER
JOHN WILLIAM BEYER
t1911-l91bl
LESUE GORBEY
JAMES P COHO
ItVIP-19861
ROBERT D. BEYER
w .
3
3
Mike McDonald intends t o enter his appearance on your behalf in those civil
cases which a r e currently pending in Lancaster County. Until he does, however, I
will be on the hook f o r them, so I certainly hope he a c t s without delay. If you
speak with him, you may want t o remind him t o enter his appearance at his earliest
convenience.
(-.
RDB/reg
Encl.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
A MEETINGS PROFESSIONAL
March 22, 1988
I haven't Forgotten you but I've been racing around on other programs. I'm
the lady you met on the plane From Dallas.
Here is a list OF persons I've given your name to in case they need a Freelance AV prrsurl For- ti lei,- p , - u y ~ - d ~ s :
Mr. Bob Lazar
Audio Visual Specialist
7617 Mountain Ave
Elkins Park, PA 19117
215/635-6649
also theater contacts
Jim Stoup
Lyons Group
715 Orange
Wilmington, OE 19801
302/654-6146
AV
Dave
Graber
R T G E
604 W. 10th
Wilrnington, OE 19801
302/652-3211
AV
Mark 0. Sullivan
Producer-Consultant
Box A-3793
177 Webster St.
Monterey, CA 93940-3182
408/373-7099
AV
That's all I know to date. IF you have something you can put together as to
what you've done regarding AV or that Sony deal you mentioned .... it would give
all of them an idea of what you can do.
Free-lancing with AV can get you in
touch with other clients and you can take it from there.
Good luck with this! Hope you have Followed up with Ted Turner and 60 Minutes!
Sincerely,
P. 0.BOX EIGHT
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
Property of Advance Media Group
'DE 19899
Page 459 of 646
WILMINGTON.
U M e r l l l GUr 1 lpdl ly
yullly 5-f8-7a
Section 3189 Federal False Claim Act
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~ a n a ~ e kRecruitment
,
INC.
Stanley Caterbone
865 M.E. 74th. Street
Iliami, Fl. 33138
We have had the opportunity to review your resume which you
recently sent to us.
Your background is of interest, therefore, we would
appreciate your contacting us at 749-7000 to arrange an
appointment to sit down and have an in-depth discussion
regarding your employment needs and requirements.
We look forward to speaking and meeting with you soon.
Sincerely,
KAHN AGENCY, INC.
Martin Kahn
MK/1
9 1
EXHIBIT U.S.
RIGHTS
of 646 Lauderdale, Florida
Thursday
7 716-4014
7 0 WestCIVIL
Oakland
ParkCLAIM
Boulevard.Page
Suite462
405.fort
3335 1 December
(305) 7 4 915,
- 7 02016
00
Property of Advance Media Group
10/19/2006
AGREEMENT
THIS AGREEMENT is made this
- day
of
fi,-+,&.
.-
Voluntary Execution.
this Agreement are fully understood by all parties and each party
acknowledges that the Agreement is fair and equitable, that it is
being entered into voluntarily, and that it is not the result of
any duress or undue influence.
ties hereto further covenant and agree for himself and his heirs,
executors, administrators and assigns, that he or it will never
at any time hereafter sue the other party or his heirs, executors, administrators or assigns, or its officers, directors,
officials, employees and agents, in any action, or contend,
directly or indirectly, that there was any absence or lack of
full disclosure, fraud, duress, or undue influence.
2.
3.
7.
A.
B.
(L~ k ~ cm~
h oc
10.
~ C I t=L,
fis
&C.<-C
gGc-,,;skee)
B.
C.
demands and liabilities whatsoever in law or equity, and particularly, without limitation of the generality of the foregoing,
of and from any actions, causes of action, suits, proceedings,
debts, judgments, damages, claims, demands, and liabilities
arising from or in any way connected with Caterbone's employment
and association with Financial Management Group, Ltd., the termination of said association and employment, and any conduct or
actions after said termination.
If Caterbone fails
to exercise this right within three (3) months from the date of
this Agreement, he relinquishes all right to said personal
effects and office furniture, and title to said goods shall pass
to Financial Management Group, Ltd.
11.
the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth
herein.
RELEASE
KNOW ALL MEN BY THESE PRESENTS:
That the undersigned, a duly authorized officer of
Financial Management Group. Ltd, a corporation located at 1755
Oregon Pike, Lancaster, Pennsylvania 17601, for and in consideration of the sum of Fifteen Thousand Dollars ($15,000.00),
the receipt and sufficiency of which are hereby acknowledged,
hereby release, remise and forever discharges, on behalf of
Financial Management Group, Ltd., its officers, directors, officials, employees, successors, transferees, executors, and agents
from any and all actions, causes of action, suits, proceedings,
debts, judgments, damages, claims, demands, and liabilities whatsoever in law or equity, and particularly, without limitation of
the generality of the foregoing, of and from any actions, causes
of action, suits, proceedings, debts, judgments, damages, claims,
demands, and liabilities arising from or in any connection with
Stanley J. Caterbone's employment and assocation with Financial
Management Group, Ltd., the termination of said association and
employment, and any conduct or actions taking place after said
termination.
It is further agreed that this Release expresses a full
and complete settlement of liability claimed and denied, and that
said payment and the acceptance of the Release shall not operate
as an admission of liability on the part of Stanley J. Caterbone.
IN WITNESS WHEREOF, the undersigned has hereunto set his
hand and seal this
day of
, 1988.
FINANCIAL MANAGEMENT GROUP, LTD.
BY:
EXHIBIT "A"
40,000
E X H I B I T 'B'
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM Page 471 of 646
Property of Advance Media Group
STANLEY J . CATERBONE
1250 Fremont Street
Lancaster, PA 17603
(717) 394-7710
Stanley J.
Caterbone
Enclosure
STANLEY J.
CATEXBONE
CAREER O B J E C T I V E
P o s i t i o n as Marketing/Business C o n s u l t a n t w i t h an aggressive company i n
need o f enthusiastic, experienced professional. Seeking long-term opport u n i t y t o commit myself t o innovative, challenging p r o j e c t s where income i s
commensurate w i t h service and results.
DEMONSTRATED QUALIFICATIONS
Diverse experience i n a l l phases o f organizational management, i n c l u d i n g
s t r a t e g i c planning, sales and marketing planning, and employee r e t e n t i o n
programs.
F u n c t i o n best when operating w i t h specific goals and objectives i n an
autonomous environment; w i l l i n g l y assume a c c o u n t a b i l i t y f o r actions.
E n j o y m o b i l i t y ; r e l a t e w e l l t o new people and new situations.
Able t o
"break ground" i n expanding e x i s t i n g and developing new clientele.
H i g h l y developed understanding o f f i n a n c i a l management operations; able t o
apply t h i s knowledge t o various business settings.
EXPERIENCE
S. J . CATERBONE ASSOCIATES, Lancaster, PA
OwnerlMarketing & Business Consultant (1987-present)
Start-up venture t o provide business and marketing expertise t o c l i e n t s via
advice o n money management, business and marketing development. Design
and develop m a r k e t i n g and business plans f o r individuals and corporations.
i n c l u d i n g m a j o r r e c o r d i n g studio i n New York C i t y ( i n proposed j o i n t
venture w i t h Sony Corporation).
F I N A N C I A L MANAGEMENT GROUP, LTD., Lancaster, PA
Cofounder; E x e c u t i v e V i c e President and Corporate Secretary (1985-1987)
Developed full-service financial organization o f f e r i n g services ranging from
conventional brokerage t o real estate, accounting, and legal services.
Organization i n c l u d e d over 60 professionals o n s t a f f as full-time, part-time,
and a d j u n c t employees. Raised over $100 m i l l i o n i n new c a p i t a l per year.
Managed business and marketing plans.
Developed f i n a n c i a l forecasts.
Secured f i n a n c i n g f r o m p u b l i c stock o f f e r i n g f o r capitalization; produced
and f i l e d o f f e r i n g memorandum w i t h federal and state securities and
exchange commissions.
Recruited s t a f f professionals; n e g o t i a t e d their
contracts. Designed, developed, installed, and administered state-of-the-art
n e t w o r k i n g computer system and i t s software. Conceptualized and founded
the Registered Investment Advisor, an FMG subsidiary which-on
a fee-forservice basis-consulted,
administered, and managed investments f o r clients.
CONTINUED
CATERBONE, S T A N L E Y J .
Page 2
D e f i n e d and i m p l e m e n t e d s t r a t e g i c p l a n n i n g process f o r c o r p o r a t e g r o w t h .
C o o r d i n a t e d e d u c a t i o n a l seminars f o r c o r p o r a t e c l i e n t s . P r o d u c e d c o r p o r a t e
video f o r m a r k e t i n g purposes. C o r p o r a t e l i a i s o n f o r a l l l e g a l m a t t e r s .
I D S / A M E R I C A N EXPRESS. Minneapolis, Minnesota. M N
Sales R e p r e s e n t a t i v e (1981-1985) .
P r o m o t e d comoanv's
. , f i n a n c i a l o r o d u c t s a n d services: d e v e l o o e d e n t i r e
c l i e n t l i s t through prospecting.
Ranked 7 t h i n n a t i o n f o r c o r p o r a t e sales
a m o n g h u n d r e d s o f " r o o k i e " r e p r e s e n t a t i v e s i n 1982.
D e v e l o p e d and
m a r k e t e d L i f e P l a n n i n g seminars f o r p r e s e n t a t i o n t o c o r p o r a t i o n s . N a t i o n a l
l e a d e r i n sales o f " f e e - f o r - s e r v i c e V i n a n c i a l
plans.
~.
EDUCATION
M I L L E R S V I L L E UNIVERSITY, M i l l e r s v i l l e ,
B.S. i n Business A d m i n i s t r a t i o n , 1980
Emphasis i n M a r k e t i n g
P A 17551
AFFILIATIONS
INTERNATIONAL ASSOCIATION FOR F I N A N C I A L PLANNERS
Member; f o r m e r e x e c u t i v e v i c e p r e s i d e n t
IACC
Member; p a s t t r e a s u r e r
INSTITUTE OF CERTIFIED F I N A N C I A L PLANNERS
Member
N A T I O N A L F O O T B A L L LEAGUE
C e r t i f i e d C o n t a c t Advisor
PERSONAL D A T A
Age: 30
M a r i t a l Status: S i n g l e
E x c e l l e n t health.
E n j o y t r a v e l i n g , sports,
W i l l i n g t o travel.
and reading.
REFERENCES
A v a i l a b l e u p o n request.
US District
Court For
The Eastern
District
of Pennsylvana
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August 9, 1990
David C. Hostetter
Executive Vice President
Fulton Bank
One Penn Square
Lancaster, PA 17602
Dear Mr. Hostetter.
I have become very disappointed in your ability to correct a problem
that your bank has made regarding my personal banking account
#0118-74848. In fact, your actions have not only caused me great
concern for my investments that I have entrusted in your institution,
but I am now being humiliated and intimidated by your lack of
concern. This incident has now caused me to question whether you
have simply stolen my assets. The amount of money in question is
some $S,UW. 1,m sure not one of your larger accounts, however 1'11
fight like hell for $5,000.
You must be aware of the implications of this incident with regards
to the past performance of both commercial and, savings and loan
institutions. The public has already grown insecure and has lost a
great deal of confidence in the banking community a t large. And
maybe this is a n example of how mismanagement and abuse can
cause some of the same public insecurities a s the actual failures
themselves.
The following will depict a chronological accounting of the above
mentioned incident:
On July 31, 1990 a t 2:18pm (see MAC meipt) I was denied
withdraw privileges from my checking and Fulton Fund accounts a t
the Greenfield center. After another unsuccessful attempt, I decided
to inquire inside to a teller. I could not understand the problem,
knowing that L should have a t least $5,000 in the accounts.
The teller began an inquire on my accounts in the computer system.
After 15 minuets, she informed me that my checking account had a
0 balance. I informed her that I also had a Fulton Fund account
with sweep, and maybe there was a problem wifh that fund. Again
after 15minuets she came back with the same answer. The manager
began to become annoyed with my problem and my concern over the
situation. L asked to see some accounting, and she said she could
provide a n account activity report.
--
TODAY LS A U G U S 9,U)90
I HAVE A CURRENT BAUNCE OF S 129.61I STILL RECEXVE CANCELLED CHECK NOTICES
YOUR
Regards,
Stan J. Caterbone
"Just" a Customer
ENCLOSURES
CC
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FOIlKi'.OM
SUITE 203
1:E
September 2 4 , 1990
Facsimile
General S e r v i c e s Board of Contract Apaeals
General S e r v i c e s Administration
10 & F S t r e e t s , N . W .
Washington, DC 2 0 4 0 5
Attn:
c l e r k of Court
\,..
n.',~
-
T h i s p r o t e s t is being f i l e d pursuant t o t h e R u l e s 5 ( a ) ( 2 )
and 7 ( b ) ( 2 ) of t l i e GSBCA by P h i l i p s and Du Pont O p t i c a l Company
("PDO") t o p r o t e s t t h e a c t i o n s of t h e Defense ~ s p p i n gAgency
Aerospace Center/AQM i n t h e evaluatior. and award o f a c o n t r a c t i n
c o n n e c t i o n w i t h Recpest f o r Proposal bearing S o l i c i t a t i o n
KDMA700-90-R-0011 d a t e d June 1, 1 9 9 0 ( t h e " S o l i ~ i t a t i o n ~ ~ ) .
P u r s u a n t t o R u l e 5 ( b ) ( 3 ) (ii)t h i s p r o t e s t is b e i n g f i l e d w i t h i n
PDQ
t e n ( 1 0 ) dnys a f t e r t h e b a s i s f o r t h e p r o t e s t w a s known.
p u r s u a n t t o Rule 1 9 ( a ) ( 2 ) r e q u e s t s a suspension h e a r i n g t o
suspend procurement a u t h o r i t y pending a d e c i s i o n on t h e m e r i t s .
Backqround
PDO , a j o i n t v e n t u r e between Nederlandse philips B e d r i j v e n
B.V. and E . I . du Dont d e Nemours and Company, r e c e i v e d t h e
above-referenced S o l i c i t a t i o n . o n June 6 , 1990 from t h e Defense
Mapping Agency, Aerospace Center/AQM, 3200 S o u t b Second S t r e e t ,
S t . Louis, MO
63118-3399.
The C o n t r a c t i n g O f f i c e r i n charge ,of
t h e S o l i c i t a t i o n i s William M. Nelson.
The S o l i c i t a t i o n was f o r
t h e p u r c h a s e o f conversion of mapping, charting and g e o d e t i c d a t a
t a p e s t o compact d i s c read only memory (CD-ROM) s t o r a g e m e d i a
a n d , t h e r e f o r e , GSBCA h a s j u r i s d i c t i o n as t h i s i n v o l v e s
procurement o f automated d a t a p r o c e s s i n g equipment.
According t o S e c t i o n M-2 of t h e S o l i c i t a t i o n , e v a l u a t i o n o f
p r o p o s a l s was t o made u s i n g t h e G r e a t e s t Value S c o r e t e c h n i q u e
and award would be made t o t h e proposal d e t e r m i n e d t o be t h e most
advantageous t o t h e Government, c o s t o r p r i c e and o t h e r f a c t o r s
considered.
F u r t h e r , p r i c e was s t a t e d t o be a s u b s t a n t i a l f a c t o r
b u t n o t as i m p o r t a n t a s t e c h n i c a l and was n o t n e c e s s a r i l y
c o n t r o l 1i n q .
A N D
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A t t h e d e b r i e f i n g c o n f e r e n c e , i t was lea-ned t h a t t h e p r i c e s
q u o t e d by PDO were s u b s t a n t i e l l y lower thzn tie a p p a r e n t
The t e c h n i c a l disc d e f e c t d e s c r i b e d above
awardeels prices.
formed t h e b a s i s o f t h e t e c h n i c a l s c o r e . It i s c l e a r t h a t b a s e d
upon t h e e v a l u a t i o n p r o c e s s s e t f o r t h i n t h e s o l i c i t a t i o n a n
o p p o r t u n i t y t o r e s u b m i t d i s c s damzqed k7'nilc in t h e p o s s e s s i o n o r
t h e Agency would h a v e p o t e n t i a l l y r a i s e d t h e t e c h n i c a l s c o r e o f
PDO t h e r e b y making PDO e l i g i b l e f o r award of a c o n t r a c t .
3,
.:
A t t h e d e b r i e f i n g c o n f e r e n c e , i t was l e a r n e d t h a t
he b a s i s
f o r t h e s e c o n d B e s t and F i n a l O f f e r was t h e need t o o b t a i n
f u r t h e r p r i c e a n d d e l i v e r y i n f o r m a t i o n from t h e a p p a r e n t awardee
o f t h e c o n t r a c t , D i g i t a l Audio Disc Corp. ("DADC"), Sony
Corporation.
Communication w i t h a l l o f f e r e r s must b e i n l i n e
w i t h l a w s a n d p r o c u r e m e n t r e g u l a t i o n s r e q u i r i n q f u l l and open
c & n p e t i t i o n among a l l q u a l i f i e d o f f e r e r s and f u r t h e r r e q u i r i n g
equal t r e a t m e n t o f o f f e r e r s during t h e evaluation process.
If
c l a r i f y i n g i n f o r m a t i o n was r e q u e s t e d f r c x Sony, it would a p p e a r
t h a t p r o v i d i n g a n o p p o r t u n i t y f o r PDO t o r e s u b m i t discs would b e
proper.
W e r e s p e c t f u l l y r e q u e s t prompt c o n s i d e r a t i o n a n d a c t i o n o f
our protest.
Very t r u l y y o u r s ,
"
Rushton T. c a p e r s
CD-ROM P r o d u c t Manager
P h i l i p s a n d Du P o n t o p t i c a i Compan:
address:
P h i l i p s a n d Du P o n t O p t i c a l Company
1409. F o u l k R d . , S u i t e 200
Wilmington, DE 19803
t e l e p h o n e numbers:
(302) 479-2501
f a : (302) 479-2512
cc:
Tho DefidUve
Source of CD-ROM
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2
"How can you possibly keep the same consistent depth, quality and variety of
zirtides?" This question and tons of kudos wers the reactions to the premier issue of
DISC Magazine. Certainly we worked hard, but so did you and it showed. I cannot
thank you enough for your initiat contribaion. Istrongly encourage you to continue with
the depth and quality of your first effort.
--
Most authors I have talked with have said how many telephone e i l s they have
received as a result of their articles. This pleases me, because my interest in publishing
DlSC is to increase the communication among the experts and those that need to learn.
The articles themselves provide this. By giving authors FULL credit, we are also providing
a means for follow-on discussions.
Beginning in January 1991, we intend to publish DlSC Magazine each month.
!Each issuewill contain a CD-ROMcalled disc/in/DlSC, feature articles, regular columns,
departments such as multimedia, standards, hardware, etc., and finally a covar story,
comprised of a series of in-depth descriptive, educational and analytical articles. The
1991 calendar for the cover story in DlSC follows:
l!dQ!Xb
Cover Story
January
February
March
April
May
June
July
August
September
October
November
December
All copy is due 45 days BEFORE the month cf publication. Therefore, your next
column or article far the January issue is due by November 15th. We prefer to have
hardcopy of the article accompanied by a diskette with the text. We can conven almost
anything as long as we know the original word processing program. Vde use WordPerfect
5.1 in DOS. Please send a hardcopy of each of your charts, graphs or tables. We also
appreciate photographs, either black and white or color if they are appropriate.
PHOTOGRAPHS: We would like to have photographs for ALL columnists to
accompany their signatures. We intend to vary the photographs from month to month,
depending on the tone of your column, SO therefore we kvill need many different poses.
Would you please supply us with three color and three black/white photos. If you only
have one type available, please provide the three black/white photcs.
(-'
Your picture should be taken frotn the Tie Knot (or equivalent) up. The following
over your left shoulder. The
poses are suggested: one smiling, one serious, one Io~king
background should be a neutral grey. We would prefer to receive the phdos in 3' x 5"
color proofs, but negatives or slides are acceptable.
SUGGESIIONS. ADVICE&OTHER GREAT IDEAS: Now that we have produced
and you have studied the premier issue of DISC, you should know that we are VERY
open to suggestions and comments. For example, there are many people out there with
an informative story to tell others. Please suggest to them that they contribute to DISC,
or let me know and Iwill contact them directly. Although the first issue seems io contain
most all of the basic CD-ROM Information, we have only just begun. There is so much
to clarify, demystify, explain and so many people who want to learn. We ate particularly
looking for articles that tell how firms published discs themselves, the problems. the
decisions, the trials and opportunities. Help us to find them, if you would.
TRADE SERVICE
1 0 9 9 6 TORREYANA ROAD
S A N DIEGO. CALIFORNIA 92121-1192 PHONE (619) 4 5 1 ~ 5 9 2 0
Telephone
703 790 9844
L&
sames A. Schretter
Executive Vice President
JAS:nn
Enclosure
AfhllateRIGHTS
of
EXHIBIT U.S. 16-4014AnCIVIL
CLAIM Page 489 of 646
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T H E A S S I S T A N T S E C R E T A R Y OF D E F E N S E
WASHINGTON. D. C . 20301-1300
In order to be of service to you, I have referred this matter to the appropriate agency within
the Department of Defense for direct reply to you.
C0NUI"C~
VICE CHAlRMAN
:$LNCE. SPACE A N 0 TECHNOLOGY
$joust of Beprerjentatiberj
ZiT4ar?!1ington, BE 20525
October 31, 1990
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James Guerln
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F I I R F M . VIRGINIA 22031~2131
American H e l i x T e c h n o l o g y Corp.
ATTN:
Mr. S t a n C a t e r b o n e
1857 C o l o n i a l V i l l a g e Lane
L a n c a s t e r , PA 1 7 6 0 1
Dear Mr. C a t e r b o n e :
T h i s l e t t e r is t o i n f o r m you t h a t t h e Defense Mapping Agency
A e r o s p a c e C e n t e r (DMAAC) h a s d e t e r m i n e d t o t e r m i n a t e C o n t r a c t
Number DMA700-90-DO011 w i t h D i g i t a l Audio D i s c C o r p o r a t i o n a n d
t o p r o v i d e a l l c o m p a n i e s which s u b m i t t e d p r o p o s a l s u n d e r R F P
Number DMA700-90-ROO11 a n o p p o r t u n i t y t o r e c o m p e t e f o r award o f
t h i s contract.
T h i s a c t i o n is being taken i n response t o a
p r o t e s t which o n e o f t h e c o m p e t i t o r s f i l e d w i t h G e n e r a l
S e r v i c e s Board of C o n t r a c t Appeals.
'
I n r e s p o n s e t o t h e p r o t e s t , t h e DMAAC a g r e e d t o t e r m i n a t e i t s
c o n t r a c t w i t h D i g i t a l Audio D i s c C o r p o r a t i o n a n d t o r e o p e n
discussions w i t h a l l o f f e r o r s i n competition for c o n t r a c t
award.
T h i s a g r e e m e n t was n e c e s s a r y b e c a u s e t h e DMAAC f a i l e d
t o disclose correctable deficiencies i n the arotester's
p r o p o s a l d u r i n g d i s c u s s i o n s w i t h t h e p r o t e s t e r a s r e q u i r e d by
FAR 1 5 . 6 1 0 ( ~ ) ( 2 ) .
Accordingly, I have determined t h a t under t h e c i r c u m s t a n c e s t h e
most a p p r o p r i a t e c o u r s e o f a c t i o n is t o p r o v i d e a l l o f f e r o r s a n
o p p o r t u n i t y f o r m e a n i n g f u l d i s c u s s i o n s by r e o p e n i n g t h e
p r o c u r e m e n t u n d e r t h e c o n d i t i o n s s e t f o r t h below.
The u n i t p r i c e s c o n t a i n e d i n t h e c o n t r a c t awarded t o D i g i t a l
Audio Disc C o r p o r a t i o n were d i s c l o s e d d u r i n g t h e d e b r i e f i n g
process.
A s a r e s u l t , i t is necessary t o place a l l c o m p e t i t o r s
on a e q u a l f o o t i n g with regard t o t h e d i s c l o s e d u n i t p r i c e s .
::
:
;
Accordingly, s h o r t l y b e f o r e t h e n e g o t i a t i o n s a r e reopened, t h e
DMAAC w i l l p r o v i d e e a c h o f f e r o r who e l e c t s t o p a r t i c i p a t e , i n
a c c o r d a n c e w i t h t h e p r o c e d u r e s s e t f o r t h below, t h e most r e c e n t
u n i t p r i c e s o f f e r e d by a l l p a r t i c i p a t i n g c o m p e t i t o r s . , The
DMAAC w i l l t h e n r e o p e n n e g o t i a t i o n s w i t h a l l p a r t i c i p a t i n g
competitors.
A l l p a r t i c i p a t i n g c o m p e t i t o r s w i l l be i n f o r m e d o f
the
d e f i c i e n c i e s o r weaknesses of t h e i r p r e v i o u s p r o p o s a l . A t t h e
completion of the negotiations, a l l p a r t i c i p a t i n g competitors
w i l l be given t h e o p p o r t u n i t y t o r e v i s e t h e i r p r o p o s a l s and
s u b m i t a b e s t and f i n a l o f f e r (BAFO).
S h o u l d you d e t e r m i n e t h a t you do n o t w i s h t o h a v e t h e u n i t
p r i c e s from your p r e v i o u s p r o p o sa l r e v e a l e d , o r t h a t your
company d o e s n o t w i s h t o c o n t i n u e i n t h e p r o c u r e m e n t p r o c e s s
f o r o t h e r r e a s o n s , I r e q u e s t t h a t you t e l e p h o n e me a t ( 3 1 4 )
2 6 3 - 8 5 0 2 no l a t e r t h a n t h e c l o s e o f b u s i n e s s o n 5 November
1990. P l e a s e f o l l o w - u p t h e phone c a l l w i t h w r i t t e n r e s p o n s e .
Send w r i t t e n r e s p o n s e t o :
D e f e n s e Mapping Agency
ATTN:
DFCO(STL)/William M .
3200 S o u t h Second S t r e e t
S t . L o u i s , MO 63118-3399
Nelson
I f you d o n o t w i s h t h e u n i t p r i c e s f r o m y o u r most r e c e n t
p r o p o s a l r e l e a s e d , y o u r r e q u e s t w i l l be h o n o r e d ; however, you
w i l l b e g i v e n no f u r t h e r i n f o r m a t i o n c o n c e r n i n g t h e DMAAC'S
assessment of your proposal nor u n i t p r i c i n g information
c o n c e r n i n g t h e o t h e r o f f e r o r s . Moreover, w h i l e y o u r p r e v i o u s
p r o p o s a l w i l l be e v a l u a t e d and c o n s i d e r e d f o r p o t e n t i a l
c o n t r a c t award, n o f u r t h e r r e v i s i o n s t o your p r e v i o u s p r o p o s a l
w i l l be allowed.
I f I d o n o t t o h e a r from you, I w i l l a s s u m e
t h a t you h a v e n o o b j e c t i o n t o y o u r p r e v i o u s p r o p o s a l p r i c e s
being released.
I w i l l l e t you know a s s o o n as t h e s c h e d u l e f o r n e g o t i a t i o n s i s
developed.
Sincerely,
"'I
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NELSON
Contracting Officer
WILLIAM M.
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W I i N I N G T O N OFIS,
MARC T. PHlLClP
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VICE CHAIRMAN
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ZZJa5f~irrgton,33C 20515
... .
November 8, 1990
'-
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I trust that this information will be helpful to you and that you
will not hesitate to contact me whenever you feel I may be of
assistance.
dc
Enclosure
!
D E F E N S E MAPPING AGENCY
M O LEE
HIGHWAY
F l l R F U . VIRGINIA 220312137
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3 1 0CT 1990
p r o c u r e m e n t s y s t e m . The a p p r o a c h we a r e u s i n g h a s b e e n u s e d
s u c c e s s f u l l y i n t h e p a s t under s i m i l a r c i r c u m s t a n c e s by o t h e r
a g e n c i e s . T h e r e f o r e , we a r e c o n f i d e n t t h a t t h i s p r o c e d u r e w i l l
e l i m i n a t e any p r e j u d i c e s u f f e r e d by y o u r c o n s t i t u e n t .
.Sincerely,
B r i g a d i e r G e n e r a l , USAF
C h i e f of S t a t t
D R A F T -- N O T F O R P U B L I C A T I O N
John S. Garofolo
C o m ~ u l uScicnlist
National lnstitulc of Slandardr and lirhnology
Tcchnolom Llu:ldinc. Room A.216
Fax:(717) 392-7897
Just when things are going smoothly, and we begin to feel a little too comfortable and too
confident with CD-ROM technology, someone or something puts us in our place -- and
thankfully so. It's these challenges that facilitate our progress toward broadening the
horizons of CD-ROM technologies.
This article is intended to inform publishers and manufacturers of the problems that can he
encountered in using UNIX tar-formatted files as a medium of data submission for CDROM production and some of the issues confronting the next generation of CD-ROM
publishers.
.3
2Disclaimer: Cenain trade names and company products are mentioned in the text in order to adequately
specify procedures and equipment used. In no case does such identification imply recommendation or
endorsement by the National Institute of Standards and Technology, nor does it imply that the products arc
necessarily the best available for the purpose.
'DOS is a trademark of the International Busiliesb Machines Corporation (IBM) and MS-DOS is a
trademark of the Microsoft Corporation.
'i
-I
Traditionally, these speech corpora have been recorded and stored in a digital form rather
than in an analog audio format. This allows the data to be easily loaded, stored, and
manipulated in computers and prevents signal degradation in copies. The speech is digitized
at a sampling rate of between 10 and 20 Hz., as opposed to the 44.1 kHz. sampling rate
used in CD-audio. Digitizing speech at these sampling frequencies keeps intact the
properties of the speech signal that are important for automatic speech recognition while
minimizing storage requirements. These corpora typically consist of thousands of spoken
phrases or sentences which are stored in separate files for ease of computer manipulation.
In the mid 1980's, the NIST began an archivalnending library for public domain speech
corpora. The corpora were originally maintained and distributed on half-inch reel-to-reel
digital magnetic computer tapes. Initially, these corpora were small, but as recognition
systems became more sophisticated, their appetite for "training" data grew tremendously.
By the end of the decade these corpora were each occupying 50 o r more 6250 bpi. halE-inch
magnetic tapes and even larger databases were on the horizon. Managing these colossal
databases of speech had become a real problem. Simply storing, copying, and distributing
the corpora had become unwieldy. Furthermore, maintaining the integrity of the corpora
was even more difficult as tapes were frequently damaged in shipment o r by rogue tape
drives.
the SO-9660 file format standard for CD-ROM was adopted and CD-ROM was chosen by
NIST as a new "experimental" medium for distributing speech corpora.
NIST decided that the first corpus to be produced on CD-ROM would be the DARPA
' T I M I T Acoustic-Phonetic Continuous Speech Corpus. Under DARPA sponsorship, TIMIT
was jointly designed, recorded, transcribed, and archived by Texas Instruments IT11 , the
Massachusetts Institute of Technology (MIT), SRI International, and the National Bureau
co~puswas designed to provide speech data for the
acquisition of acoustic-phonetic knowledge and for the development and evaluation of
automatic speech recognition systems. The corpus contains recordings of 630 speakers from
8 major dialect divisions of American English each speaking 10 phonetically-rich sentences.
In addition to standard orthographic (text) transcriptions, TIMIT contains unique timealigned phonetic transcriptions. NIST felt that TIMIT's unique structure would b e of great
interest to speech researchers and, therefore, would probably be ideal for widespread
..
on a "prototype"
publication on CD-ROM. NIST decided to publish two-thirds of the corpus
CD-ROM.
8 (-1.L.
)
,5?
Because of the ISO-9660 restrictions on filename length and format, the chosen two-thirds
of the corpus to be placed on CD-ROM was restructured from a flat directory structure with
lengthy unique UNIX filenames into a dense 5-level directory hierarchy which reflected the
design of the corpus and conformed to ISO-9660. The resulting directory structure
contained 4200 bottom-level subdirectories -- one for each sentence-utterance, and 3 files
per utterance for a total of 12,600 data files! This new organization required the use of the
entire path and filename to uniquely identify a file but was 'Gisually navigable."
T o date, more than 200 "TIMIT Prototype" discs have been distributkd to universities and
speech research laboratories worldwide. The discs were well received by the speech
research community and have been read on PC's, Macintoshes4, various UNIX systems,
NeXT5 machines and ~ i c r o ~ ~ The
~ e"experiment"
s ~ .
had proved to b e successful.
As of this writing, NIST has produced four releases of speech corpora on eight discs.
Recently, NIST completed production of its most ambitious speech disc so far. The new disc
is a complete revision of the TIMIT Prototype disc and contains the speech for the complete
630-speaker corpus as well as all-new time aligned word-boundary transcriptions. The new
TIMIT CD-ROM contains 25,200 data files (4 files per utterance) as well as morcextensive
documentation and software utilities.
After the production of the TIMIT prototype disc, NIST recognized the need to distribute
DRAFT
speech corpora in a consistent format. Unfortunately, no standard file format existed f c l '
storing and exchanging speech signals. Compounding this problem, almost every speecl:
research laboratory around the world used different hardware and software configurations
for speech signal processing and analysis.
Each CD-ROM is now organized entirely in the UNIX environment. Many of the standard
UNIX utilities and capabilities have proven ideal tools for CD-ROM preparation. Tar files
are now submitted for CD-ROM replication on one 8mm tape, instead of 5 or 6 half-inch
reel-to-reel tapes. UNIX-based CD-ROM premastering software is planned to be added in
the near future to help alleviate some of the complications NIST has experienced in
submitting data for replication. By performing ISO-9660 formatting in house, an ISO-9660
image can be submitted to the replication facility. The ISO-9660 image can then be directly
loaded into a mastering system - thus circumventing the problems which can occur
downloading tar-formatted files.
NIST has developed strategies to maximize the portability of its CD-ROMs by organizing
speech data into a consistent format and providing utilities which can be linked into each
laboratory's unique hardware and software systems. To accomplish this, a flexible, objectoriented header structure was developed for the exchange of speech files, especially on CDROM. The header is an ASCII-based structure prepended to each speech file and allows
an utterance to be uniquely identified (even if the file is copied from CD-ROM and
inadvertently renamed) and describes basic attributes of the speech signal to aid in digital
to analog operations. A set of software utilities have been written, "Speech Header
Resources" (SPHERE), to provide a low-level interface for importing and manipulating these
files. NIST now publishes aU speech data in this more consistent format.
TOdate, the tar program has been ported to many operating systems, including MS-DOS
and VMS' as well as the many variants of UNIX.
Because the tar format is portable and preselves directory hierarchy, and because a tar file
can be written to a standard ANSI-labelled tape or any other storage medium, NIST
concluded that tar-formatted ANSI tapes would be the ideal vehicle for providing a CDROM-ready file image to a replication plant.
Unfortunately, NIST has found that most replication plants either refuse to accept tarformatted files or they charge considerable "data conversion" fees to download the files into
their premastering systems. To say the least, the acceptance of tar as-an input medium for
CD-ROM production has been less than universal by the CD-ROM replication industry.
-
'Sun Microsystems, Inc, TAR(5)". Unu Interface Reference Manual (Relense 3.0). Section 5 -FileFomtars,
pp. 429-430.. January 1983.
'VMS is a trademark of the Digital Equipment Corporation (DEC).
DRAFT
1907' F O R P U B L I C A T I O N
The replication facilities that have ventured into the "tar pit" with NIST have frequently
encountered technical delays and cost-overruns. In theory, the tar-tape to CD-ROM process
should be simple. But in reality, it has rarely been straightforward to implement.
a c'!
L...
>
I
Extracting the file structure from a tar file for a CD-ROM such as the new TIMIT disc
requires a great deal of time and attention because of the extraordinary number of
directories and files. The subsystems involved in the tar extraction process require seamless
integration. These include the PC hardware platform and MS-DOS operating system, the
premastering system, the device drivers, controller cards, tape back-up systems, and the tar
utility. Limitations inherent in the MS-DOS operating system, device drivers, and file
structures can result in breakdowns in any one of these subsystems resulting in the loss of
hours of man and machine time in the production process.
Eight-mm tape subsystems can be especially vulnerable when extracting exceedingly large
numbers of files. This is because 8mm tape drives are mechanically suited for streaming
operations. They are not as accommodating as 9-track tape drives in the quick stopping and
starting movements which become necessary when extracting many thousands of small files.
Additional loss of efficiency occurs when 8mm drives must interface with a system which has
become bogged-down with overloaded magnetic disk sub-systems. The only way to optimize
their operation is to load and buffer large blocks of raw data before it is tar-extracted.
Subtle problems may also arise when the controller cards of some 8mm tape systems are not
entirely compatible with the publishing system being used. These and other unforseen
problems can cause a tape drive to abort operations well before completion of the extraction
process.
Worse yet, because the tar format does not guarantee that directories and files are stored
in any particular order, an entire tar file must be scanned to extract any subset of files
contained in it. If the tar-extraction process aborts before the end of the tar file is reached,
the entire process must be restarted from the beginning to insure that all files are loaded.
These constraints require that special efforts be taken to prepare backup tapes and even
second backup tapes during production. This is one area of risk where the insurance is well
-\
I
However, by switching to DOS 4.0, the sector size can be reduced to as little as 512 bytes.
This significantly reduces the overhead being used by the DOS partition. It is therefore
important to adjust the sector size to accommodate the size of the database files to be
downloaded. T o maximize disk usage, the sector size should be set high when premastering
a database with a few large textual files. But when a database (such as TIMIT) contains
many small files, the sector size should b e greatly reduced. Likewise, it is also important to
allow for this kind of overhead on the CD-ROM itself. Although CD-ROMs are generally
created with a 2Kb sector size, the sector size can be reduced on the ISO-9660 image in the
premastering phase to as little as 512 bytes. By decreasing the sector size on the TIMIT
ISO-9660 image to 512 bytes, potential disc overhead was reduced by about 32 megabytes.
Finally, a hidden source of potential problems lies within the implementation of the utility
used to extract the tar file. There are currently a number of tar utilities that have been
written and are in use today. Many of these utilities are suboptimal in speed and efficiency.
The time required for downloading a tar file can become critical when extracting large
numbers of files. Therefore, using the right tar implementation is a must.
-\
'
The ISO-9660 standard has provided a good basis for the exchange of CD-ROMs across
different hardware and software platforms. It is now time for the CD-ROM industry to
address and overcome the many obstacles faced by the challenge of universal operability.
The increasing need for a standard media- and platform-independent format for data
submission is just one such obstacle?'
In the short term, manufacturers of CD-ROM premastering workstations should publish
specifications indicating the limitations of their systems. This would allow publishers and
replicators of "atypical" CD-ROMs to avoid many of unforseen pitfalls they must now face.
In the long term, these premastering systems must be made more robust.
The next generation of CD-ROM publishers and users will help CD-ROM technology reach
new heights, but they will become far less forgiving as CD-ROM becomes more
commonplace. For NIST, the UNIX road to CD-ROMhas certainly been "the road less
travelled." Currently, the development, production, and use of CD-ROM technology in
UNIX and other environments is still in its infancy. However, by increasing support for
development and production in these environments, CD-ROMs may someday be produced
and used on a variety of platforms as easily as they are on MS-DOS-based systems today.
It is only in this way that the CD-ROM will become the truly universal medium of data
%own. T.. "Universal Operability: The Technical Challenge'. Dirc Magazine, pp. 30-34, October 1990.
'%elgerson, L W., "Universal Operability: The Technical Solution: Dirc Magazine, pp. 36-39, October
1990.
Acknowledgments
The authors wish to thank the following people which have helped them in their quest for
solutions to the problems this article has outlined: Joe Bradley and Clayton Summers at
Philips and Dupont Optical Co., Dennis Clark, formerly of Meridian Data, Inc., Leon
Whidbee and Gisele Venczel at Disc Manufacturing, Inc., Lance Buder and Sylvester Pefek
at Optical Media International, and Tom Brown at Reflective Software.
'
8011 L C I l t Z m Y A I
fF4RFM. VRaIW ePml.21Sf
14 NOV EN
AQAF-S
--..*----.
e x c e e d e d t h e maximum i n f n r m a t i a n d i a m e t e r l M T D I a n d a l l t h r e e
( 3 ) d i s c s exceeded t h e t r a c k p i t c h (TRP) s t a t i c d a t a
specif icatione.
c o n s i d e r the f a c t t h a t you w i l l be s u b c o n t r a c t i n q
p r e w s t e r i n g / m a s t e r i n g and p r i n t i n g / f f n i s h i n g of t h e artwork.
The p r o p o s a l i d e n t i f i e d 100 s f t of
T h i r d , s t o r a g e of GPP
s t o r a g e s p a c e , t h i s is n o t s u f f i c i e n t t o s t o r e magnet c t a p e s
f o r l a r g e o r d e r s ( o v e r 200 t i t l e s ) .
Request t h a t any i n f o r m a t i o n p r o v i d e d i n r e s p o n s e t o t h i s
1 c C t c r be oont t o the following a d d r o o o and m a i l e d to a x r i v e
n o t l a t e r t h a n 1600 ( 4 P.M.
1990.
C e n t r h l ) on Wednesday, 2 1 Nov
ATTN: AQAP-S/Mr.
Chn
+<ma -p-nICJ-1
-L-u-.
t l l A \
9+7-Qzn?
Sincerely,
Contracting Officer
'
. .
i... .
,. .
.. ,.
.:
? .
2.
Thw
Sincerely,
Stan J. Caterbone
Director, CD-ROM Technologies
ENCLOSURE
December 6, 1990
Honorable Robert S. Walker
House of Representatives
Washington, D.C. 20515
Dear Mr. Walker:
Enclosed you will f i d copies of my latest correspondence and
procurement proceedings for the above mentioned contract.
As you can see, I was requested to submit information regarding the
Stan J. Caterbone
Director of CD-ROM Technologies
P.S. It has come time for me to reveal the truth about the summer
of '87. Unfortunately, this will involve many of you constituents, in
fact you may want to inquire to Mrs. Walker regarding our telephone
conversation in July of 1987. I mean no harm, and appreciate your
integrity and support.
\rnrr<an Helix Te~hnulc~gyCorponlr~n
IS57 Colonial \ ~ i l Lane
~g
A-8
MONDAY,JANUARY 14,1991
4EuStScMeiber
T ."d,rn
Mekeel
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e
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3
Williarncbr*
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z:?:2?A,ler
METROPOLITAN
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'Blackmail'
Continuedfrom A-1
In the acquisition, Ferranti
~-~ used
"The one thing I will look for savs. "Guerin and others
you to do, Bill, after we close this faise' contracts to overstate the
out, is ...(that) you look me in the value of ISC by at least $350 mileye and you say, I've destroyed lion, and Fcrranti officials relied
those packages," Guer~nsays. on those material misrepresentaClark assures his boss that after tions in agreeing to (a) stock
he gets his last payment, he will swap."
"take a trip, and I don't mean a
Ferranti says it is entitled to
vacation trip.
get the money back because it
"And when I get back from that was "illegally obtained propertrip, I will tell you that I have ty" that Guerin had no right to
been to certain places, and I have give toClark.
recovered the packages that are
The court testimony of an IRS j
there, and I have destroyed agent last May shows that $1.3
million of the funds were direct
them," Clarksays.
"I will take a book of matches results of the ISC swindle, Ferand they will be done away ranti says.
Another $700,000, it says, was
with," hesays.
Guerin testified here in Janu- illegally diverted from an ISC :
i
ary 1990 that Clark had attempt- subsidiary.
ed to extort $2.75 million from
Clark is not entitled to the
him, using 11 packages of al- funds, the company says, belegedly damaging information cause he knew the money was
tainted and used that knowledge,
about Guerin and his associates.
(
to force payments from Guerin.
!
The packages
alleged
"What Clark had in mind was
wrongdoing,
illegal
salefinancial
of arms
to South Africa, conflicts of inter- blackmail, not settlement of real i
est and cheating on government or imagined grievances about his
contracts, Guerin said.
employment," Ferranti charges
Clark's demand for money in its filing.
came during delicate financial
negotiations when Guerin was attempting to buy back a portion of
Ferranti.
Guerin believed the packages
particularly those alleging
Guerin had inflated its financial
worth would have scuttled the
buyback.
Clark suggested masking the
payments as a severance agreement in which he left the company due to health problems and
promised not to "bad mouth" the
company. Guerin agreed.
In Anril and Mav of 1989. while
the buiback negoiiations were in
progress, Guerin p a ~ dClark $1
million, according t o court documents.
But after the negotiations collapsed, Guerin stopped further
payment. Clark sued for the r e
mainder. and Guerin set it aside
in- a hankescrow
- ---- - ...- - account
-.
..-- -.
In Wednesday's filing, however, Ferranti, which in 1987 had
acauired Guerin's International
~ i d n a l & control cornoanies.
~~~.
claims that -ieitht.r Guerin nor
t the money.
Clarkhad any r ~ g hto
Since autumn 1989, the compai
nv has claimed that Guerin and
management
vict~mized
EXHIBIT U.S. 16-4014 CIVIL RIGHTS ISC
CLAIM
Page 517
of 646 it in
Thursday December 15, 2016
what its attorneys
Property of Advance Media Group
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EXHIBIT U.S.
16-4014
CIVIL RIGHTS
CLAIM
Page
519
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non-member
agencies
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child
welfare(a1I
114th Year-
No. 35,649
METROPOLITAN
Story: deals
by ISC sent
Iraq bornbs,
but Guerin
denies sales
----Tlrn Mekeel
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shot down todav. th
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ston also said a sei
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ston told reDorters i
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noted that Iraq's cluster bombs A sailor aboard the frigate USS Curts escorts a wounded Iraqi POW,
"There's no offe
pose a major threat to American
ing going on,v Ro,
who is blindfolded and bound, past a guard on the ship Wednesday.
t r o ~,s if ground fighting begins.
G ~ O UCapt.
~
NiaU
today. "They tend t
IS :was founded in Lancaster The Navy captured about 20 Iraqis on a mine-laying vessel in the
by C l e m , who now lives in Persian Gulf.
and disperse. The p
Napli-s, Fla. Guerin has denied
selling weapons know-how to
. Cardoen, said 20120.
In an interview today, Guerin
blasted the broadcast as "totally
untrue."
~ ~ - - ~ "It's such a distortion, it's so
disturbing to us, I can't remain
(API
- of
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Bush invoked Thursday
silent.
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thingCIVIL
to do,"
"and his anguishduringtheCivil
EXHIBIT
16-4014
RIGHTSWASIIINGTON
CLAIM
Page
520
646
December 15, 2016 War
God
and
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memory
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of
Abraham
Lincoln
today as
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Page 2626 of 2953
10/19/2006
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Is4 I
I NEWER4
BUSINES
TUESDAY,
JANUARY 29,1991
1 I990 property
:I transfers lowest
I here since '84
down 13.6 percent from the comparable 1989period.
The economv's slide into reces..-I
.
~ c o~u n t ~y .real
~ ~ estate
~
[ slon~ and~ incrhasing ~ i d d l eEast
iarket turned chillv in late 1990. tensions were bllamed for the real
estatemarket'sdecline.
laking the full ykargs
lance thecoolestsince 1984.
"The bieeest slowdown we've
seen
is in the higher priced ~ O W Some 11,916 property transfers
mk place in 1990, the fewest lng, from $150,000 and UP," said
lnce 1984's 10.954. according to Ronald N. Cohen, recorder of
aeeas.
.gures from the La'ncaster &nf Recorder of Deeds Office.
Cohen added that the market
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--
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JUN 1 9 1986
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EXHIBIT U.S.
16-4014
CIVIL RIGHTS CLAIM Page 525 of 646
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Property
of Advance
Media Group
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US District CourtARTICLES
For The EasternOF
District
of Pennsylvana
INCORPORATION
FEE
$75 00
.'
COMMONWEALTH OF PFNNSVLVANIA
,'~PIC-P~HTUENIof STATE - WRPORIION
UURUU
.'
'#*INOHTU OFPICE BUILMNG. WRISBLRG. PA 17120
........
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DU ZIP CODf
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1-nncaster ................
L a..n c a-.s t e r PA
- 0 - 8 . r,n !,s r,raroa.rOH ?&*w,v s o f int con
RATID*
To h a v e unlimited power T o e n g a g e i n and t o d o a n y l a w f u l a c t c o n c e r n i n g
a n y o r a l l l a w f u l b u s i n e s s for w h i c h b u s i n e s s c o r p o r a t i o n s may b e i n c o r Itorated u n d e r t h e B u s i n e s s C o r p o r a t i o n Law, Act of Hay 5 , 1933, P.L. 364
a s amended.
..
ll...t"
1114
18..,#,,1
I1
A . d , t ~ n $ * l l r NtmtDer
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and Pa# V a l u Of S l m r r l W l c h
...........
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Corpormllon Sh1
.1
509
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CUSS01 s n s r n SubunbM t o
by ~ a c incolporamoi
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:E USE ONLY ~
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s
NUMBER
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DATE HCJECTED
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MI CORPORATION NUMBER
.....
..........
VERICII D 8 1
I"l."
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US District Court
For The Eastern
of Pennsylvana
ARTICLES
OFDistrict
lNCORPORATlON
COMMONWEALTli OF PENMSYLVANIA
IJCPAF(1UENT OF STATE U))(POAITlON LIUHEAU
.A!+ NOMTli OFFICF WILDING. MARRISBVHG PA 11120
FEE
I75
-. W
W M E S I I C PROFESSIONAL CORPORATION
ENTER BOARD L I a N S E N O
...
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17601
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To h a v e u n l l m i e e 8 power t o engage i n and t o do any l a w f u l a c t c o n c e r n i n g
a n y o r a l l l a w f u l b u s i n e s s f o r w h i c h b u s i n e s s c o r ~ o r a t i o n smav be i n c o r [ n o r a t e d under t h e B u s i n e s s C o r p o r a t i o n Law, A c t o f Hay 5,
1933, P.L. ~ 3 6
l.nnca.ster
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23
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amended.
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Par v . 1 ~ ~01 ~nmao. wnartt t h Corpontlon Shall Mn Aulhatly 10I~IU.
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i Page 527 of 646
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EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM
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US District Court For The Eastern District of Pennsylvana
ARTICLES OF INCORPORATION
COMMONWEALTH Of PENNSVLVINIA
DEPA'ARTYENT Of STATE W R K Y ( A l K 1 Y BUIEAU
*h NORTH OfFICt BUILMNG, M R I S L U A G . PA 11120
....................
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1755 Oregon
Pike
.................
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DU ZIP C O M
].ancaster
PA
17601
--- - Lancaster
. .- I a w A,N in1 PUIPO~ FOH R J PI
s or lnt loai R A ~ I O N
T o h a v e unllmife3 power t o engage in and t o d o any lawful act concerning
any or all lawful business for which business corporations may be incorporated under the Business Corporation Law, Act of May 5, 1933, P.L. 3 6 4 ,
n s amended.
1
8.
34.
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ARTICLES
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INCORPORATION
.F i n a...n c i a l
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Inc.~
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s n y o r a l l l a w f u l b u s i n e s s f o r w h i c h b u s i n e s s c o r p o r a t i o n s may b e i n c o r p a r a t e d u n d e r t h e B u s i n e s s C o r p o r a t i o n Law, Act of Hay 5 , 1933. P.L. 3 6 4 ,
a s amended.
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175 16
IN 1 E STIMONY WHEREOF. THE INCORPORATORIS) HAS (HAVE) S I G N E D AND S E A L E D THE ARTICLES OF INCORPORATIC
THIS
.............
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EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM Page 530 of 646
' uOlMR
Property of Advance Media Group
..
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....
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ARTICLES
OF
INCORPORATION
US District Court
For The Eastern
District
of Pennsylvana
Y L L I I L
4~
UrnEln V"L,
."YI.,"IL
WMEsT1c
I .TS
runrunr,,un
CORPORATION
Section 3189 Federal False Claim Act
COMMONMALTH OF PENNSVLVANIA
D WMESTIC PROFESSIONAL CORPLXATION
DFPARTMENT OF STATE - WRPORATION BUREAU
ENTER BOARD LICENSE NO
XM NORlH OfFlCE WILDING. WRRlSBUAG, PA 17110
.
.............
.
.
NIUl 0 1 C&PWIIIO.
I W S T CONIIIN A C W P W A l l INDICAIO. UNLESS E l l Y P l UNDCR 35 P S
81
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ortgage S e r v i c e s , I n c.
...............-...
r13014+ksor
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ob.
$'La"
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1 - a n c a s t e. .r. . . . . . . . . . . . .
PA
17601 .).I#* IMt PUmPO..f OH PUIPO 6 Of l b + l COD? RAllON
T o h a v e u n l i m i t e z p o w e r %o e n g a g e i n a n d t o d o a n y l a w f u l a c t c o n c e r n i n g
a n y o r a l l l a w f u l b u s i n e s s f o r w h i c h b u s i n e s s c o r p o r a t i o n s may b e i n c o r p n r a t e d u n d e r t h e B u s i n e s s C o r p o r a t i o n Law, Act of May 5 , 1933, P.L. 3 6 4 ,
a 3 amended.
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shares,
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common .....
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S
....
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LOG I N IHEFILEI
FINANCIAL
M?mGmmm emz?.L m
LCCENSE AGREEmm
dayof
October
19-8,%etween
Agreementmadethis 17th
Financial MaMgement Group, Ltd., 1755 Oregon Pike, Lancaster, PA, 17601,
(hereinafter called "lTGts) I
and
stanlev J. Caterbone
(hereinafter called
"a-I1
and services.
marketing of financial p
4. Ccaooensation
In consideration for the services performed hereunder
by FIG, Licensee agrees to utilize the insurance marketing services of FIG
or its apprcpriate affiliate, as mch and as often as possible. Lifurther agrees to use his best efforts to place sales of insurance
products through FIG or its affiliates in all cases where such products
are appropriate and suitable for License's clients. FIG or its
appropriate affiliate agrees to pay Licensee in acmndanx w i t h individual
amnnission contracts signed by Licensee, of whatever gross conmissions are
payable, including all overrides and renaYdl anrmissions on those
contracts.
...
bargaining
-1
6 . Office Owration
Licmsee shall be responsible for all operating
expnses of his office, including but not limited to, -,
insurance!
payroll, advertking, rent telephme, leased or rented equipaent, M
t
losses, etc. Licensee shall not &ligate F X for any dlaims or actions
which may arise or be asserted against FMG by reason of Licensee's
operation of his office. 'Ihe relationship of the parties is one of
L i m r and Licensee and nothing herein contained shall be construed to
constitute them as partners or joint venor the Licensee as agent or
employee of FMG for any pupose whatsxver.
BY:
Witmess :
LICENSm :
AWImRY. INC.
P s m T E D PERSON AGFmlmm
m-,
~ n v m ~aviLr
t
a Reg'
(hereafter referred to as I'EMG1' ) and
dtanleymerbone
I
an individual (hereinafter referred to as l1
caterbone
11)
1986, by and between F I G AWLWRY, INC.
certain
, an
M r . Caterbone
services
M v i d u a l , agrees t o provide
and perform certain duties and responsibilities on behalf
of FM;:
mties.
M r . Caterbone
w'==:
clients.
allmezl by
D. Toperformany other w
m y be inc*tal
rn that
duties.
m.
4.
M r . Caterbone
I s
LW.
A.
M r - Caterbone
furnish
and
a&inistxative assistance, am3 any other facilities. 6 - t
supplies that F X in its sole discretion determines as adequate for the
performance of Mr. Caterbone Is duties and reqmnsibilities.
7. Relationshiu
A. Mr. Caterbone
seeking
%.
B.
~ r Caterbone
.
shall timely apply for, obtain
and maintain a l l necessary licenses, m
t
s and registrations as shall be
required by any statue, or regulation in corrnection
with
M r . C&&
, bone
I s activities hereunder.
C.
M r . Caterbone
shall not use in comection with
his solicitation activities hereunder, whether by direct mail, personal
distribution of printed materials, newspapers, radio, telwision or by any
other media, any sales or advertising litemture not specifically supplied
and authorized by FMG for that purpose u n t i l he has f i r s t obtained prior
written apprwal of his praposed use of such literature by the a-mpriate
officer of FIG who has been designated responsible for such approval.
A.
W i t h o u t Cause
1. miSLqeeumtmaybeterminatedbyeitherparty
without cause a t any t b by placing written notice of such tenrimtion in
the U.S. mails, addressed to the other party hereto, either
a t Mr. Caterbone
I s last k x m address as contained in FMG1s records
(such address may be changed from t k to tink= by written notice thereof
being sent to and filed with FMG) or to FMG a t its then principal place of
business. In addition, the
shall a w t i c a l l y terminate in the
event of the death of M r . Caterbone
2 . I f termination of this Pqreaoent is
ne
terms of Section 6(a) (1). FMG shall continue to pay eter
after termination or to his estate after his death, so long as such action
is not wntrary t o law, all fees on those services received from and
appmved and accepted by FMG prior to the date of termination and which
9.2-
were earned under Section 4 hereof less such deductions or set offs as FIG
may be atitled to heremder.
B. With Cause
1. ~n
the event Mr. Caterbone
is declared a
ban)uupt, makes an assignent for the benefit of cxeditons, has a receiver
or trustee a p p o h t d for this property, f a i l s t o canply with any of the
terms, corditions and obligations of this Agmement, conduds himself in
any manner which FMG, in its unrestricted discretion, determines to be
detrhmtd to its b u s h or reputation, or in any way acquires, obtains
or engages in any interest, affiliation or enploymerit relating to the
solicitation of the plrchase or sale of securities or i n v m t s or
m f e r i n g of inveslnmt advice, either direct or indirect, either alone or
w i t h the person or entity other than FMG, FMG my irmnediately terminate
this Agmement, such termination being retroactive to the h a m of
such went(s) and FIG'S &ligation to pay fees, shall hndiately cease
upon such termination, without notice; and such termhation shall in no
way affect FIG'S right to mllect any
- be due it
- amnmts which may
f
&
M r C i l t ~ ~
2. If anv of the aram%sfor termination srecified in
Sedion 6(b) (1) above &
l
EX&
at the' time of a &tion
pursuant to
a
ternuna
tion
pursuant
to
section
6(b)(1)
=ion
6(a), it shall be .deemed
.
for the purpose of determvLlng whether any fees are
MT. c
n
e
aftex termination. Failure of FIG to
after kncxildge that gnxlnds for termination
tenni~tethis
&st u d e r Section 6(b) (1) above shall not be deemed a waiver by FPG of
its rights to terminate this Agrement under such Section at any later
date.
zither party until the executim of a lease agreemnt by Lessor and the
delivery of HI executed original copy thereof to Tenant or its
representative. FlmAemure. the parties shall mt be band by q
written or oral representatb benreen them, directly or thnxgh any
representatim, except as specLLcally i ~ ~ r p ? d t e
indche lease
a g r e m t referred to above.
EXRIBIT D
J-
,IJS'~NESSLEASE A
EDEN PAPS
ASSOCIATES 11
AND
[-
LEASE
i- ~ d ethe ldgldaY
P.o. Box
GUA-
of
2 5 4 , New
~~~~
15/a#
I
.
?
of any character
es
~ B ETW E N
w~c~~
GROUP,
miLTD.
~ is a pennsylvania business torigned have agreed to personally guarantee the Tenant's P C Lease.
the Undersigned
On demand all
fa1 expenses)
the liability of
f
.&
lr shall be
gists of snore
Le hereunder,
lnts by a e
It and to be
ned by the law
'e* the
court Of
rsi9ned and,
~dgment's',
'cessors and
by the
htecest
!ection an
th.
Lngs that
I Or execu-
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF LANCASTER
,JIu~ i&
I HEREBY CERTIFY, t h a t o n t h i s E h d a y o f
1986,
b e f o r e m e , t h e undersi'gned, a N o t a r y P u b l i c f o r t h e a f o r e / s a i d S t a t e and County,
p e r s o n a l l y a p p e a r e d Raymnd E. I x , who acknowledged h i m s e l f t o b e t h e Managing
G e n e r a l P a r t n e r o f Eden P a r k A s s o c i a t e s 11, a P e n n s y l v a n i a g e n e r a l p a r t n e r s h i p , and
t h a t h e a s s u c h Managing G e n e r a l P a r t n e r , b e i n g a u t h o r i z e d t o d o so, e x e c u t e d
t h e f o r e g o i n g G u a r a n t y f o r t h e p u r p o s e s t h e r e i n c o n t a i n e d on b e h a l f o f t h e p a r t nership.
I N WITNESS WHEREOF, I h a v e h e r e u n t o a f f i x e d my hand and s e a l t h e d a y and
y
.e a r f i r s t above w r i t t e n .
fiG+fi
'J/.
bhLcy:~i
N o t a r -y P u b l i c
My Commission E x p i r e s :
of
t 198L,
a t e a n d County,
&--0.f 5 p@r?cl'a
c
c r'
7. C C I ~ - V ~ - - .
r r ,.& 'k)c:b t+
F- f,fi b . 6 - n r L . n .P I & !cr 9
known t o m e ( o r s a t i & f a c t o r i l y p r o v e n ) to b e t h e w r s o n s dhos'e names a r e
s u b s c r i b e d to t h e f o r e g o i n g ~ ; a ; a n t y , - a n d t h e y acicnowledged t h a t t h e y e x e c u t e d
t h e same f o r t h e p u r p o s e s t h e r e i n c o n t a i n e d .
y e a r f i r s t above w r i t t e n .
h % h a.aJ'%lM4.i,
~ o t a r yP u b l i c
MY' C o m i s s i o n E x p i r e s :
3 2 . CONSENTS.
I n a n y i n s t a n c e i n which t h e " c o n s e n t " o r " a p p r o v a l n o f
L a n d l o r d o r T e n a n t is r e q u i r e d h e r e u n d e r , s u c h r e q u i r e m e n t s h a l l n o t b e
i n t e r p r e t e d a s j u s t i f y i n g a r b i t r a r y r e j e c t i o n but s h a l l connote a r e a s o n a b l e
a p p l i c a t i o n o f judgment.
L
"LANULORD"
WITNESS:
ASSOCIATES I1
/@Z!L:(~
[&L3
GROUP, L t d .
By:
Secretary
WITNES
&-/5/Jh?--
/president
, Individual
man, I n d i v i d u a l
OPTION AGREEMENT
AGREEMENT made t h i s
, .A.D.,
day o f
19E
by a n d b e t w e e n R o b e r t F. K a u f f m a n ( h e r e i n a f t e r r e f e r r e d t o a s
"Kauffman") a n d S t a n l e y J . C a t e r b o n e ( h e r e i n a f t e r r e f e r r e d t o
a s " C a t e r b o n e " 1.
W I T N E S S E T H :
T h a t i n c o n s i d e r a t i o n o f One D o l l a r ( $ 1 . 0 0 )
*
receipt of
w h i c h is h e r e b y a c k n o w l e d g e d a n d o t h e r g o o d a n d v a l u a b l e c o n s i d e r a t i o n , a n d i n t e n d i n g t o b e l e g a l l y bound h e r e b y , t h e p a r t i e s
h e r e t o mutually a g r e e as follows:
1.
Option.
Kauffman h e r e b y g r a n t s t o C a t e r b o n e t h e o p t i o r
t o p u r c h a s e t e n t h o u s a n d ( 1 0 , 0 0 0 ) common s h a r e s of F i n a n c i a l
Management G r o u p , L t d . ,
a Pennsylvania b u s i n e s s c o r p o r a t i o n , on
t h e terms s e t f o r t h h e r e i n .
2.
.,
P u r c h a s e P r i c e . , The p u r c h a s e p r i c e p a y a b l e f o r s u c h
s h a r e s s h a l l b e p a r v a l u e , s p e c i f i c a l l y f i f t y c e n t s (50C) p e r
s h a r e , i n c a s h o r by c e r t i , f i e d c h e c k t o b e p a i d by C a t e r b o n e t o
..
Kauffman upon d e l i v e r y of s u c h s h a r e s .
3.
Exercise o f Option.
T h i s o p t i o n t o purchase s h a l l be
e x e r c i s e d by C a t e r b o n e upon n o t i c e i n w r i t i n g t o Kauffman a t t h e
registered offices of t h e corporation.
C a t e r b o n e may e x e r c i s e
o f s h a r e s set f o r t h h e r e i n o r any p a r t t h e r e o f .
4
Closing.
D e l i v e r y of s h a r e s a n d p a y m e n t o f t h e p u r c h a s
(48) h o u r s a f t e r
r e c e i p t by K a u f f m a n o f t h e n o t i c e o f t h e e i e r c i s e o f t h e o p t i o n
a t s u c h time a n d a t s u c h p,lace a s t h e p a r t i e s s h a l l m u t u a l l y a g r
5.
Representations.
a)
Kauffman r e p r e s h t s t h e f o l l o w i n g :
He i s . t h e s o l e o w n e r a n d h a s ? h e r i g h t t o s e f l
t h e t e n t h o u s a n d ( 1 0 , 0 0 0 ) s h a r e s of F i n a n c i a l Management
Group, Ltd.
b)
S u c h s h a r e s a r e now a n d u n t i l t h e c l o s i n g w i l l b e
f r e e o f a l l encumbrances.
C)
C a t e r b o n e s h a l l r e c e i v e good a n d m a r k e t a b l e t i t l e
6.
Benefit.
T h i s Agreement s h a l l b e b i n d i n g upon t h e
p a r t i e s , t h e i r h e i r s , l e g a l ' r e p r e s e n t a t i v e s , s u c c e s s o r s and
1
assigns.
I N W ~ T N E S S WHEREQF, t h e p a r t i e s h e r e t o h a v e h e r e u n t o s e t
I
t h e i r h a n d s a n d s e a l s t h e d a y a n d y e a r f i r s t ~ b o v ew r i t t e n .
Witnesses:
R o b e r t F. Kauffman
S t a n l e y J. Caterbone
NOTE
$20,000.00
November
1986
F o r v a l u e r e c e i v e d , I , t h e u n d e r s i g n e d , p r o m i s e t o pay t o t h e
a t 1755 Oregon P i k e ,
o r d e r o f F i n a n c i a l Management G r o u p , L t d . ,
Lancaster, Pennsylvania,
D o l l a r s ($20,000.00)
i n i n s t a l l m e n t s , a s s e t f o r t h as follows:
J a n u a r y 3 0 , 1987
F e b r u a r y 2 8 , 1987
March 3 0 , 1987
A p r i l 3 0 , 1987
May 3 0 , 1987
J u n e 3 0 , 1987
J u l y 3 0 , 1987
August 3 0 , 1987
Upon d e f a u l t i n t h e payment o f a n y s u c h i n s t a l l m e n t when d u e ,
t h e whole o f t h e p r i n c i p a l sum t h e n r e m a i n i n g u n p a i d s h a l l , a t t h e
o p t i o n o f F i n a n c i a l Management G r o u p , L t d . ,
become i m m e d i a t e l y d u e
and p a y a b l e w i t h o u t demand o r n o t i c e .
And f u r t h e r , t o s e c u r e t h e payment o f s a i d a m o u n t , I h e r e b y
a u t h o r i z e , i r r e v o c a b l y , any a t t o r n e y o f a n y c o u r t o f r e c o r d , t o
a p p e a r f o r me i n s u c h c o u r t , i n t e r m , t i m e o r v a c a t i o n , a t any
tim e h e r e a f t e r , and c o n f e s s a judgment, w i t h o u t p r o c e s s , i n f a v o r
o f t h e h o l d e r o f t h i s N o t e , f o r s u c h amount a s a p p e a r s t o b e
unpaid t h e r e o n , whether due o r n o t , t o g e t h e r w i t h c o s t s , i n c l u d i n g
c o l l e c t i o n c o s t s a n d a t t o r n e y ' s commission o f f i v e p e r c e n t ( 5 x 1 ,
and t o w a i v e a n d r e l e a s e a l l h e i r s w h i c h may i n t e r v e n e a t a n y
s u c h p r o c e e d i n g s a n d c o n s e n t t o i m m e d i a t e e x e c u t i o n upon s u c h
j u d g m e n t , h e r e b y r a t i f y i n g and c o n f i r m i n g a l l tha-y
said attorney
may do by v i r t u e h e r e o f .
S H Y Robeftson
W e , FMG, L t d . , d o h e r e b y a g r e e t o s e l l 1 0 , 0 0 0 s h a r e s o f FMG,
L t d . s t o c k t o S c o t t R o b e r t s o n f o r a p r i c e o f $2.50 p e r s h a r e .
The a b o v e n o t e i s f o r t h e b a l a n c e o f t h e f u l l 2 5 , 0 0 0 a g g r e g a t e
p r i c e o f w h i c h $ 5 , 0 0 0 . h a s a l r e a d y b e e n p a i d by S c o t t R o b e r t s o n .
A l l s t o c k c e r t i f i c a t e s w i l l b e i s s u e d upon c o m p l e t i o n o f payment.
I f ~ a v m e n tc e a s e s , a l l c o l l e c t e d f u n d s w i l l b e u s e d t o p u r c h a s e
s h a r e s a t $5.00 p e r s h a r e .
. ..
February 12
Ten Thousand
AN
f//47/' / Pr=eJ/;.,+A: /.
f
I
i. un-rr ~
...................................
o
//lI~,/~/~i;~~fi/t~fit,t~~~/~I/d_a_te
k.+w
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v = s d m @ f - .
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t ~~
nm rFaun
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ArrJtkMdcd
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l ~ udr ~;
~ ~b
~
c * ~ ~ t ~ r u n l, yu . ir ~
n *~w r ; ~
~ ~~ ~ ~ a r * r r r ~ ~ t ~
T f f g % z ~m
irnw
q ~ ~m" d ."dUC
& lard.
A a t O/]lce Ada'n~s.
Page 548 of 646
.~/)RR
10/19/2006
Schedule D of
Form ADV
Page 2
F M G Advisory, Inc.
mu:
7/15/58
4
12.)
llRS Emol. Ident. No.:
1 200-46-0959
1 1024102
(C~IY)
Stanley J. Caterbone
3. (a) lmideocc of inhvidlul:
2/18/87
MI. 28743
Dae:
Conestwa
I(c) Cily:
I
(Ute)
[(d) S u l e or Province:
b~
I PA
I p an caster
(Zip Code)
PA
NAMES USED. Li all ma-other lhthe one giwn in 1 1 6 2 above 1h.l the individual has uud, iaeludine maiden lumn.
(W)
(Firu)
(Miidle)
N/A
5. EDUCATION. Scan with lul hiph v h d attended. Ifno dqrec rreclved, slate "none."
Ycan
Atunded
la76
1980
Series
Series
Series
Series
~~
Year
rdluced
BSDA/Manaaement
US District
Court For The
Schedule
of Eastern District of Pennsylvana
F6rm AD\I
Page 2
F M G Advisory, Inc.
801-
.J
Pan 1 Items
Date:
28743
2/18/87
II and 12.)
F M G Advisory, Inc.
23-2431433
Robert E. K a u f f m
3. (a) Rcsidenm of individual:
190-44-9057
829384
(city)
(Zip Ccdc)
PA
17601
Rearing Sprinq
5/31/54
(State)
Lancaster
(c) City:
(e) Counlry:
PA
USA
NAMES USED. Lisl a11 M m n other than the one given in ltcm 2 above that the individual has u d . ineludin* maiden rumcs.
(hr)
(Firn)
(Middle)
4.
EDUCATION. Start with last h i ~ xh h w l atlrndcd. I1no desrce raelved. stale "none."
Years
Year
Allended Graduated
1976
B.S. Mathematics
Vice Pres.
RIA
Advisory, Inc.
I
7.
1972
I ~inancialplan./ President
I
Fm;
12
86 Prese
EXAMlNATlONSlPROFESSlONAL DESIGNATIONS. List a l l jurisdiilion. ull.re(ulalory or#anization. and prornsional ercarninations and dna(
loons G ~ r erxam~naloonor dui;ruloon lumc (include any eaaminalion's titlr a d number). body sirin8 it. and dale taken or conferred. I f cramsrul
was waived, ;ivc details.
m)
WHEREAS,
F K ; ~ a c c p l t r o l l h q ~ i n F K ; A d v ~ , I n c . , F K ; A u x x l n tI i n g
the
F!
and that,
. parties desire that Kauffman bearme affiliated with G
asmectlon thi.lewth,
Kaufhan be granted a certain -tary
arrangement for his work.
WHEREAS,
in
N&.l, -,
for and in considexation of the mtual pmnises herein
Contained, and other good and valuable considetation, the receipt and
sufficiency of which are hereby aclrmlakjed, the parties hereto do hereby
agree as follm:
1.
b).
A boaus
a).
b)
a)i
~ r m r ~ f l t h e l c s t v e s t i n g o f ~ e ~ ~ ~ s
signed on m y 18, 1987. K a u f h m could, however, petition
release fran any &ligatim. Icauffnw could also be
released ha any abligatim to enplayment with FM= shauld
PSGnameswxsxstoIhuffbDanintheiragreementwith
FX dated Uay 18, 1987.
IN wmmsWHEREXF, t h e p & z i e s h e r e t o h a v e ~ * ~ t h e d a ~ a
year first above written.
On this 21st day of May, 1987,
FINANCIAL-GIMUP,
IUD.
before me a notary public, the under7
signed officer, personally appeared
Robert R. Long, Jr. and Robert E.
Kauffman, known to me to be the perso
whose name is subscribed to the withi
instrument, and acknowledged that they
5executed the same for the purposes
1
1
M
therein contained.
In witness whereof, I hereunto set my hand and official seal.
.,
*:
I
mmission ex ires 12/10/90
AGREEMENTS
CD-ROM Raw Disc Replication - American Helix will receive 90% of the raw disc price.
Stan J. Caterbone will receive 10% of the raw disc price. All pricing below $1.00 will be
negotiated on a case by case basis. American Helix will be guaranteed a minimum price
of $ .85 on all projects. Any mastering costs above a wash to American Heliu, will be
recovered against replication commissions.
Mastering - American Helix will receive 15% of the net margin of the premastering and
data preparation services performed by Stan J. Caterbone, American Helix is guaranteed
at least a net wash of all mastering costs.
will be paid upon invoicing of projects. Any past due accounts over 90
a reversal of commissi
reinstated upon paym
"
.-
STATE OF GEORGIA
COUNTY OF COBB
THE FINANCIAL GROUP, INC.
STOCK OPTION AND OWNERSHIP AGREEMENT
T h i s A g r e e m e n t , made a n d e n t e r e d i n t o t h i s - d a y o f
A p r i l . 1 9 8 7 . b y a n d b e t w e e n THE FINANCIAL GROUP, I N C . , a G e o r g i a
c o r p o r a t i o n ( " T F G " ) , THE PLANNER'S SECURITIES GROUP, I N C . . a G e o r g i a
c o r p o r a t i o n ( " P S G " ) a n d ROBERT E . KAUFFMAN, a r e s i d e n t o f
Pennsylvania ("Kauffman").
NOW, THEREFORE, f o r a n d i n c o n s i d e r a t i o n o f t h e p r e m i s e s
a n d m u t u a l p r o m i s e s h e r e i n c o n t a i n e d . a n d o t h e r good and v a l u a b l e
c o n s i d e r a t i o n . t h e r e c e i p t and s u f f i c i e n c y of which a r e hereby
acknowledged, t h e p a r t i e s h e r e t o do hereby a g r e e a s f o l l o w s :
1.
A f f i L i a c i o n w i c h PSG a n d O p t i o n o f S h a r e s .
Kauffman
s h a l l c a u s e t h e P l a n n i n g Company t o b e c o m e a f f i l i a t e d w i t h PSG a s
s o o n a s p r a c t i c a b l e and-^^^ S h a l l a c c o m m o d a t e a n d e x p e d i t e s u c h
affiliation.
Upon t h e a f f i l i a t i o n o f t h e P l a n n i n g Company w i t h PSG,
TFG s h a l l g r a n t a n o p t i o n t o K a l i f f m d n f o r s u c h n u m b e r o f common
s h a r e s o f PSG a s d e t e r m i n e d b e l o w :
Company f o r t h e t h r e e y e a r s e n d i n g J u n e 3 0 ,
1988, June 30, 1989 and June 30, 1990.
2.
Option P r i c e and E x e r c i s a b i l i t y .
The o p t i o n p r i c e of
t h e o p t i o n e d s h a r e s s h a l l be t h e par v a l u e of s u c h s h a r e s ( 8 . 0 5 per
share).
The o p t i o n s h a l l be e x e r c i s a b l e i m m e d i a t e l y upon g r a n t o f
t h e o p t i o n , b u t t h e i s s u e d s h a r e s s h a l l be s u b j e c t t o t h e f o r f e i t u r e
provisions l a t e r described a s well a s t o the adjustment i n the
number o f o p t i o n e d s h a r e s a s a r e s u l t o f a n n u a l g r o s s c o m m i s s i o n
f iguces.
3.
Vestinq Schedule.
The e x e r c i s e d s h a r e s s h a l l be
t h i r t y ( 3 0 % ) v e s t e d as of J u n e 30. 1988, a n d t h e v e s t e d p o c t i o n of
s u c h s h a r e s s h a l l i n c r e a s e by t e n ( 1 0 ) p e r c e n t a g e p o i n t s e a c h y e a r
t h r o u g h J u n e 3 0 . 1 9 9 5 , a t w h i c h p o i n t o n e h u n d r e d ( 1 0 0 % ) p e r c e n t of
t h e e x e r c i s e d s h a r e s s h a l l be v e s t e d ; however, i n t h e e v e n t of a
s a l e o f t h e Company o r a p u b l i c o f f e r i n g . a l l e x e r c i s e d s h a r e s s h a l l
be f u l l y v e s t e d .
4.
F o r f e i t u r e and Riqht of F i r s t R e f u s a l .
I n the event
t h e a f f i l i a t i o n o f P l a n n i n g Company w i t h PSG t e r m i n a t e s f o r a n y
r e a s o n . o r i f Kauffman t e r m i n a t e s h i s r e l a t i o n s h i p w i t h P l a n n i n g
Company f o r a n y r e a s o n , t h e o p t i o n s h a l l b e c o m e n u l l a n d v o i d , a n d
a l l non-vested s h a r e s s h a l l immediately be f o r f e i t e d ; t h e v e s t e d
s h a r e s s h a l l b e s u b j e c t t o r e p u r c h a s e b y TFG o n t e r m s c o r r e s p o n d i n g
t o t h o s e i n t h e o p t i o n s i n f a v o r of c e r t a i n of PSG's o t h e c
planners.
Any v e s t e d s h a r e s s h a l l a l s o b e s u b j e c t t o a r i g h t o f
f i r s t r e f u s a l i n f a v o r o f TFG p r i o r t o s a l e .
5.
Related Matters.
TFG a n d PSG a c k n o w l r d g e t h a t c h i s
A g r e e m e n t i s b e i n g e n t e r e d i n t o i n e x c h a n g e f o r t h e s e r v i c e s and
b e n e f i t s t o b e r e n d e r e d b y K a u f f m a n . i n d i v i d u a l l y , a n d PSG a n d TFG
a g r e e t o c o o p e r a t e and a s s i s t Kauffman t o t h e e x t e n t n e c e s s a r y s u c h
c h a t t h e o p t i o n and ownership b e n e f i t s d e s c r i b e d h e r e i n s h a l l i n u r e
t o t h e b e n e f i t of Kauffman, i n d i v i d u a l l y . r a t h e r t h a n t o Planni-nq
Company.
6.
Formal Option Aqreement.
The p a r t i e s a g r e e t h a t . a s
s o o n a s may b e p r a c t i c a l s u b s e q u e n t t o t h e e x e c u t i o n o f t h i s
Agreement, t h e p a r t i e s s h a l l e x e c u t e a more f o r m a l o p t i o n agreement
incorporating the points s e t forth herein. a s well a s other
p r o v i s i o n s which a r e customary and a p p r o p r i a t e w i t h r e s p e c t t o
arrangements of t h i s n a t u r e .
IN WITNESS WHEREOF, t h e p a r t i e s h e r e t o h a v e e x e c u t e d t h i s
Agreement t h e d a y and y e a r f i r s t above w r i t t e n .
C U S H I N&
G MORRIS
ATTORNEYS
AT LAW
W HAMPTON MORRIS
CHARLES M CUSHING. JR
KEVIN R ARMBRUSTER
ROY M JONES
LILA L NEWBERRY
May
5,
TELECOPIER
656-9865
1987
Dear Bill:
Enclosed please find the above-referenced agreement, as
amended to reflect Bob's company as the beneficiary of the stock
option. rather than Bob, individually. I understand that, except
for this change. Bob had no comments on the draft of the agreement
presented to him last week.
Please let me know if any further modifications are needed.
With best wishes
--
CMCjr:dsk
Enclosure(s)
cc: Mr. Chris
S.
Guerin (w/encls.)
19885
STATE OF GEORGIA
COUNTY OF COBB
THE FINANCIAL GROUP, INC.
STOCK OPTION AND OWNERSHIP AGREEMENT
day of May,
This Agreement, made and entered into this
1987, by and between THE FINANCIAL'GROUP, INC., a Georgia
corporation ("TFG"), THE PLANNER'S SECURITIES GROUP, INC., a Georgia
corporation ("PSG"), FINANCIAL MANAGEMENT GROUP, LTD., a
Pennsylvania
("Planning Company") and ROBERT E.
KAUFFMAN, a resident of Pennsylvania ("Kauffman").
g r o s s c o m m i s s i o n s g e n e r a t e d by P l a n n i n g
Company f o r t h e t h r e e y e a r s e n d i n g J u n e 30,
1 9 8 8 , J u n e 30, 1 9 8 9 and J u n e 30, 1 9 9 0 .
i
2.
O p t i o n P r i c e and E x e r c i s a b i l i t y .
The o p t i o n p r i c e of
t h e o p t i o n e d s h a r e s s h a l l be t h e p a r v a l u e o f s u c h s h a r e s ( 5 . 0 5 p e r
s h a r e ) . The o p t i o n s h a l l be e x e r c i s a b l e i m m e d i a t e l y upon g r a n t of
t h e o p t i o n , b u t t h e i s s u e d s h a r e s s h a l l be s u b j e c t t o t h e f o r f e i t u r e
provisions l a t e r described a s w e l l a s t o t h e adjustment i n the
number o f o p t i o n e d s h a r e s a s a r e s u l t o f a n n u a l g r o s s commission
figures.
3.
V e s t i n q S c h e d u l e . The e x e r c i s e d s h a r e s s h a l l be
t h i r t y ( 3 0 % ) p e r c e n t v e s t e d a s o f J u n e 30, 1 9 8 8 , and t h e v e s t e d
p o r t i o n o f s u c h s h a r e s s h a l l i n c r e a s e by t e n ( 1 0 ) p e r c e n t a g e p o i n t s
e a c h y e a r t h r o u g h J u n e 3 0 , 1 9 9 5 , a t which p o i n t o n e h u n d r e d ( 1 0 0 % )
p e r c e n t o f t h e e x e r c i s e d s h a r e s s h a l l be v e s t e d ; however, i n t h e
e v e n t o f a s a l e o f t h e Company o r a p u b l i c o f f e r i n g , a l l e x e r c i s e d
s h a r e s s h a l l be f u l l y v e s t e d .
4.
F o r f e i t u r e and R i g h t o f F i r s t R e f u s a l .
In the event
t h e a f f i l i a t i o n o f P l a n n i n q Company w i t h PSG t e r m i n a t e s f o r a n y
r e a s o n , o r i f Kauffman t e r m i n a t e s h i s r e l a t i o n s h i p w i t h p l a n n i n g
Company f o r a n y r e a s o n , t h e o p t i o n s h a l l become n u l l a n d v o i d , a n d
a l l n o n - v e s t e d s h a r e s s h a l l i m m e d i a t e l y be f o r f e i t e d ; t h e v e s t e d
s h a r e s s h a l l be s u b j e c t t o r e p u r c h a s e by TFG on terms c o r r e s p o n d i n g
t o t h o s e i n t h e o p t i o n s i n f a v o r o f c e r t a i n o f PSG1s o t h e r
planners.
Any v e s t e d s h a r e s s h a l l a l s o b e s u b j e c t t o a r i g h t o f
f i r s t r e f u s a l i n f a v o r o f TFG p r i o r t o s a l e .
5.
F o r m a l O p t i o n Agreement.
The p a r t i e s a g r e e t h a t , a s
s o o n a s may b e p r a c t i c a l s u b s e q u e n t t o t h e e x e c u t i o n o f t h i s
~ g r e e m e n t , - t h ep a r t i e s s h a l l e x e c u t e a more f o r m a l o p t i o n a g r e e m e n t
incorporating the points s e t f o r t h herein, a s well a s other
p r o v i s i o n s which a r e c u s t o m a r y and a p p r o p r i a t e w i t h r e s p e c t t o
arrangements of t h i s nature.
I N WITNESS WHEREOF, t h e p a r t i e s h e r e t o h a v e e x e c u t e d t h i s
Agreement t h e d a y and y e a r f i r s t a b o v e w r i t t e n .
(SEAL)
ROBERT E. KAUFF'YAN
R.E. Icsiufiman
NOTES OF STOCK OPTION
A.
m.
w i l l read:
B.
Bill
1.
We
2.
FMG
3.
IT S H O U I D W 3 N O T m ' M A T E ' S G W I L L N O T O O ~ ~ F I G S E P A R A T E
FROM ITS INVOL-
m m s:
WlIM
XAUFFMAN.
President
Investigators
tie Guerin's
son to seized
-
-2
o^mnr.l.
- Stan
Published l i e s a b u t
Caterbane on
Septem@r 4, 1987
regarding fabricafed
crlninal chawes that
w r e filed bj the ilanheim
I o n s h i Pollee Department,
Distric! Justice b r a y Norton,
the L+ncqter District,Attorney,
and Plstrlct Justice Rlchard Rpeser.
SW 618 IIPISIAMIG
- Fomlosed
on
- )lamer
Uorked with Jim
the residence
on t k
of Stan Caterbone Lancaster k t e
in lbvember '87. Uanageynt Bond
Issue in '87.
Stan Caterbone
J
o
h
Depatto
told
that "Guerin i s in
trouble" in Nov '87.
I St
MIID W
l CON, INC.,
- Filed
suit against
J u e s Christian.
Stan Caterbane
- Stan
Caterbane
atten ted to
hu
CARL JMOBSOH
WMAli Ck#K
I
- Carl Jacobson uas
rve,&cu*tnts
o Glb Anstrong
in the PB Ca i t o l
building in
1987 -- Gib ran
away!!
scheduled to meet
uith Stan Caterbone
and Larm Resch on
June 23 1987 a t
FNG ~ t d . , "Ue had
to /IY car1 out of
the country early
~ & ~Said ~
DETECTIVE BmM
discussed business
and personal
matters
daily.
COIPIOMIMM BIVa(
- Stan Caterbane
MRRY
- Judgement
of $191 Hillion
iY Farranti,
Int.
Caterbane.
~ JOSEPH
f 'AODB
Illegally rewsseed
Stam Caterbane plane
with f i l e s on board.
- Discuss rescue
- Stan Caterbone
discussed business
anddally
p r s o nbasls.
at.utters
on
co keration
n con. for United
- for
Indicted & Convicted
- Revieu
financials
- Attorney
Pennsylvania
UEDIECH Scandel.
- Represented Uillian
of Ckm Con Stan
- Partner
uith Larm
General's
Clark us. J u e s Guerin
Caterbane a i l e r s
Rpsch in Military
- Guerin's brotkr-in-lau . ~n $2 mlll~on ay
Office.
$17 Million em&zzled Loglstlcs
dispute/ htorfion?
Stan Caterbone
discusses allegations
a n d i w r o p ~ i e t i r sand
misconduct of J w s
Guerin and ISC, uith
specifics to D.0.D
contracting activities
Engineering, Inc.
Fowr h h t i n g
Rep for United
them Con Office, in
Uashington, D.C.,
HWARD EISSlEA
(KIG)
Name
$0.50
Bavera. J e r r y
Braverman, Richard
Caterbone, Stanley
Clark, Glenn
Coho, T h e b e 8 .
H a r t l e t t , Michael
Kauffman, Robert
Kennedy. David
Long. Robert
Loss, Alan
Loss. Nathan
Ncnell, Linda
Oischger, Donald E.
Paneros, Pete
Podlasek, Richard
Radcliffe. Harry
Ray, Kenneth
Robertson, Scott D.
Roesser, Steve
Royer, Carolyn D
Trump, Richard C.
Trump, Richard L.
Umiker , Nora A.
Volpe. Gary
Volpe, Richard J .
40000
40000
60000
'
Total Shares
Total Capital
Raised
140000
65000
35000
$70.000~$162,500 $122.500
Offering Memorandum
Total
Shares
$5.00
45000
35000
5500
245500
$27,500 $382,500
40000
G
j($
-Capital Raised
54 million
100 million
*tal
2.7 million
5.0 million
.5 million
million
1.0 million
- 5 million
3 . o million
6.0 million
4. o million
camnksions
-mtal
GKSS
- m a e
.3
lbmiqs
-Affiliate
Revenue
less Orsmnissions
.76 million
1.52 million
'
llion
N/A
SALES FORCE
-=w-'=
37 P==ns
50 Persons
48 plSotl.5
--Hires
10 persons
14 persons
14 persons
-Retention
90%
85%
95%
m N C I A L S (All MlPRberS
in Millions of Dollars)
Revenue
.76
1.8
N/A
--Retained Profits
.21
-501
N/A
--Return On FqUity
70%
66.6 %
N/A
--Capital Base
.300
-785
N/A
.300
.725
.30O-
--Book V d l u e / S h a r e
1.60
3.05
4.00
-480
1.526
N/A
$5.60
$10.67
$14.00
$10.00
$13.33
$17.00
-Net
Traditional
-
(at 1
*.sham?
>;
Total Grms R e J e r f ~ e )
-15-
U N I T E D STATESOF AMERICA
DEPARTMENT OF TRANSPORTATION - FEDERAL A V I A T I O N ADMINISTRATION
AIRCRAFT
SERIALNO
27623
..
3 1-7812065
PIPER
PA-31-325
This car,l~lcexr a
,lS".d
$0. ras,,trs
,,,la
The Fadarsl Aule
,ton Admlnlslr.uon
Of
INDIVIDUAL
.
- -
I( IS ~ ~ r t i that
f ~ ~&he
d ahor. d e u r i b ~ ds~rcrafth u k m .nured on the resls-r of ihr Feder.1
accur&nce with the Convention on
~ " , . f ~ " " *dminu,..,,on.
united stsu.
A~.,,C.,
rllb the ~.d.nl AVI.GIO~ *a of
~ ~ t . ~ . t , ~ CIV,,
, , d A V , . ~ ~ Odated
~
~~~~~k~
7. 1914.
1858, .nd rqul.liun. *surd thereunder
US. Daplrtmoni
DATE OF ISSUE
JULY 22s
-,"
CATERBONE STANLEY J
I 1755 ORE60N PIKE
s LANCASTER PA 1 7 6 0 1
....
..
..
.
0
a
z
..
..
11 1 1
U.S. Department
of Trsnrportslion
F&wl Aviation
AdminisIntion
MI*. ~ . ~ , t ) n c v~ e r o n a u t ~canter
ul
P O . Box 15504
o k t a b m . c i w . OK 73116
Offac#alBus#nssl
pen.lty for Prwal. Ur. $300
AC Form 806C-3 17831
27623
ro:
CATERBONE STANLEY J
1 7 5 5 ORE60N PIKE
UNCASTER PA 1 7 6 0 1
198
Advisory, Inc.
-1*"K,.'
Y.*LI*I*I
'"OW L I D
STANLEY J. CATERBONE
PRESlDENT
In
it made
a very bad
impression
--
My. financial statements are very accurate and are on the conservative approach if any.
If you don't believe me, visit
my office at 1755 Oregon Pike.
,,
,,
president
SJC: lmk
cc: P. Wolfsen
J. Steuernagle
D. Loose
~ m e l w c ed3sran
r
PHILADELPHIA- James H. ~ u e r i n
used a bogus company headquartered in
a New York post office box to send numerous shivments of embarroed military hardware to South Africa and circulate money used to mastermind a $1
billion fraud, an FBI agent testified
Wednesdar.
fenselelectronics company, International Signal & Control Corp., now Ferranti International PLC.
The first accounts of Guerin's alleged
illegal dealings with South Africa were
~~
,-".
..
TIME
S Y S T E M S
'
YEAR
MOM
1q87
-m
S
V)
I
I
k
TS 4101
RV ~ 8 5
INC
PRNT~
NUS
May 2 9 , 1 9 8 7
Stan Caterbone
554 B e r k l e y Avenue
S t o n e Harbor, N . J .
Mr.
Dear S t a n :
I'm e n c l o s i n g a f i r s t d r a f t of t h e s c r e e n p l a y , c o m p l e t e w i t h
t y p o s and a c o u p l e o f o t h e r e r r o r s . ( F o r i n s t a n c e , Kennie
Queens i s a l s o Kenny P e t e r s o n . )
This
well
very
talk
s h o u l d g i v e you s u f f i c i e n t t i m e t o s t u d y t h e s c r i p t as
I t would be
a s t h e b u d g e t , which I ' m a l s o e n c l o s i n g .
h e l p f u l i f you c o u l d have n o t e s p r e p a r e d which w e c a n
a b o u t when B a r b a r a and I a r e i n N e w J e r s e y n e x t week.
@
rlene
avidson
10/19/2006
COMMONWEALTH OF PENNSYWANIA
ROBERT
M. LAM
US District Court
For The
Eastern District of Pennsylvana
Chairman
ROBERT P. CASEY
Governor
L. DIANA
Section 3189 Federal NANCY
False Claim
Act
Secretary
ELIOTT KLElN
Chief Counsel
'
O C i
Yours truly,
Hovard L. Eissler
Securities Investigator
HLE :sec
Enclosure
'73
10/19/2006
Guerin:
corn.
rerelvingaboutf10.rminfcesfo0
i s m i a m e n andpmductionex. hEnise.
and did sa with the apDm"~l"fwP.*I.
%%p%
~ C I \ I \ ~~Yv H i u i H
HUU>II\Ib
tII\IAI\ILt A t i t N L Y
Section
3189 Federal False Claim Act
Mortgage Assistance
Program
Stanley J. Caterbone
RD 1
2323 New Danville Pike
Conestoga, PA 17516
Re:
Mortgagor is not suffering financial hardship due to circumstances beyond mortgagor's control: Mortgagor was fired from
job. (Act 91, Section 404-C(A))
,.,
, , , r S I I ~ L~U~~ ~
C ne musc provlde
Section 3189 Federal
Claim Act
25 days in order to refute
the False
Bureau
of
Employment Security's determination of willful misconduct. The Appellant indicated that he had appealed this determination and would
provide evidence supportive of his position.
US District
Court For The Eastern
District of Pennsylvana
documentary
evidence
within
Hearing ~xakin&;
cc:
file
decision file
1 THE MIGHTY YEW AND FIERCE COMPETITION ARE FORCING IT INTO HEW MARKET
1 '
BUSlNtSS
WEEKIJUNE
1987
EXHIBIT 04
U.S.
16-4014
CIVIL1 RIGHTS
CLAIM
-.
--- -
5
"3
C O V M STOW
10/19/2006
BUSINESSWEEKIJUNE 1,1987 67
I I R TO sow
relatively cheap $32 Walkman just for Morita still insists has technological adthe U. S. market
vantages that can be exploited. Says one
Betamax $ also one of the reasons competitor: "If Sony switched to VHS
Sony is showing more willingness to co- format in their products, they would be
operate with competitors. In developing No. 3 after one year." This summer, VIE
the technology for compact disks and makers plan to unveil an improved verplayers, Ohga forged an alliance with sion in the U.S. thdt eould make l i e
Dutch electronics giant Philips. Sony has even more difficult for both Betamax
since become the world's largest suppli and the 8mm camcorder.
er of CD players, with 35% of the U. S.
Sony's boldest move for dealing with a
market, and is one of the largest produc- cutthmat consumer electronics market is
its diversification into nonconsumer busiers of the disks themselves.
m w p l ~ u u w Sony
.
has even started nesses. There, the theory goes, the comassembling products for its competitors. pany will be less dependent on coming
In an effort to win wider acceptance for up with a steady stream of relatively
it4 8mm camcorder, which is incornpati- short-lived hit products-and able to use
ble with VHS video players,'it has agreed its unique talents in video and semiconwith 127 manufacturers on standards ductor technology to create its version
for 8mm gear. Sony makes the 8mm of the office of the future. Sony engiequipment marketed by Pioneer, Fuji, neers envision an office where they can
"call up" their colleagues around the
and others.
Ultimately, the Betamax experience world by speaking their names to a vidwas "a blessing in disguise," says Yoshi eo console on their desks. They could
Tsununi, a professor of international dictate memos to the same screen and
business a t the City University of New send them with a voice command. They
York and a friend of Morita. "Mr. Mor- might carry a Walkman-size version
ita has become more receptive to other with a tiny screen so they can review
ideas and has been listening better." documents from the office files while
Tsummi says he wouldn't be surprised entertaining clients on the golf course.
Sony's U. S. operation, which already
to see Sony make an acquisition to
strengthen its nonconsumer businesses. gets 35% of its sales from nonwnsumer
It's not clear just how deep the new
attitudes go, however. Song's commitment to the VHS-incompatible8mm camTheBetamaxdebacle
corder resembles its stubbornness with
Betamax. But this time, Sony executives
taught Sony the value of
say, the format could pay off in differ
sharing technology and
eut products, such as individual movie
players that could he rented on airnot going it alone
; planes. More puzzling is Sony's unwillingness to give up on Betamax, which
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM Page 584 of 646
Thursday December 15, 2016 COVER ST
68 BUSINESS WEEKIJUNE 1,1987
10/19/2006
Technology
..
22 SKY
May
1987
EXHIBIT
U.S.
16-4014
%
.,
--
....>--
-v#F-.*-.-
,..
., ..
, , .
..
10/19/2006
,,,
! r
i L
of
7
w
n EmblemJewelryProgram
Please call - I have some questions.
Address
CityiStatelZip
Telephone Number
II
24 SKY
1987
EXHIBIT
U.S.May
16-4014
CIVIL RIGHTS CLAIM Page 587 of 646
. . .
SKY May
1987
25
Thursday December
15,
2016
10/19/2006
cial-ell'ccts possih~lities-as well as de- Section 3189 Federal False Claim Act
creasing industry headaches such as
"comet-tailing" and blurring.
The 35mm film format has also been
the industry standard for decades.
Numerous industry leaders are quick to
point out its obvious obsolescence. The
70mm film size, they note, offers much
more than a 100-percent improvement
i n cinematographic possibilities. "Most
people. including large film manufacturers, do not really understand how much
detailed information can be put on 70mm
film." asserts Optical Radiation's Bergpren, "and shown back on the screen."
A central point. i n an overall sense.
that bringsthese debates into focus is that
there i s an already-existing arsenal of
new cinema systems. Each camp points
inarguably to the future, andeach system
is now offering spectacular new cinematic experiences.
some o f the new fomlats first debuted
Theater at the Museum o f Scient
in what the industry calls "specialChicago's O M N I M A X Theater (loca.
venue" theaters - noncommercial, musei n the Henry Crown Space Center at
um, and other educational halls. CurMuseum of Science and Industry).
rently the granddaddy o f these is the
O M N l Theater at the Fort Wonh Mu
um o f Science and History, and the S
IMAXm/OMNIMAXb system, now
amazing audiences at Washington. D.C.'s
mce Museum o f Minnesota in St. Pat
Smithsonian, Boston's Mugar O M N l
among others. Several of these "spa,
~~~~
~~~~~~
I
1
;
i
:
1
theaters were designed by the architectural firm of HammelGreen and Abraharnson of Minneapolis, which estimated that 20 million people attended
OMNIMAX theaters around the world in
1985.
The heart of the IMAX system is a
unique projection appuach; the large-
to
anilablllty
I Mnrrdr+Benz ol
I North America. lnc.,
I Marketing
Cornrnunicntjonr
-. . .
Name
Address
SKY May15,
1987
27
Thursday December
2016
10/19/2006
.3
World Famous
Architectural
Antique Auction
Starts 10:00a.m.
Bmm
Several of t h e b e s t hand-calved
panelled r o o m s p a i l a b l e
8 Bronzewalls &formal enhyways
Carved wood embellishments
Chandeliers
Magnificent mantels
Saloon & h o m e back bars
Marble staluary
Museum quality Victorian
Furnishings
Something For Evelyone
AsNwp. PloMlnlmum-NOReserve
CMnpllrnentaIy Butkt and LhinLa
GATSBY'S
dept 5
(404) 457-1905
Shipments arranged Worldwide
1I
EXHIBIT
16-4014 CIVIL
28 SKYU.S.
May 1987
Property of Advance Media Group
RIGHTS CLAIM
Sincerelydyours,
,
'
Jeffrey C. Ulin
Associate Director of
Legal and Business Affairs
JCU:gg
Enclosure
Tclex
330499
LFL SRFL
Page
2698
of 2953
10/19/2006
Thomas L. Flanne
lntelligencer ~ourna7~tafI
James H. Guerin and three of his former International Signal & Control
Corp. executives were sued for almost
$200 million for fraud Thursday by Ferranti International Signal PLC.
Ferranti charged in a lawsuit filed in
London that the former Lancaster business leader and the others "knowingly
participated in a dishonest scheme to
Ferranti buyout.
The suit, or writ, claims that from
February 19% to July 198%the Panamanian companies Sestri Associated. S.A. :
Technology Associated International;
Elverton, S.A.; Navarino Development
Corp.; and Lerwick Holdings, S.A. collectively prwessed 29 bogus sales and/
or purchase contracts for misslle systems destined for the Republ~cof Chlna,
A-4
FROM PA1
.....
ti&'6eco~n,
f d r d i t i o n to his involvement
n.
Guerin arrives
:o testify on
12.75-million
pay dispute
1y Ernest Schwlber
bnd Tlm Mekeel
James H. Guerin, right, founder of International Signal and Control, walks into a law office il
today. He isaccompanied by his attorney, Joseph A. Tate, of Philadelphia.
-b4
'A
paid Clark $1 million in spring $750,000 for Clark's estate in
Court documents 1
1989, but halted payment Of the York County - because, he indicate that be wa:
remainder, claiming that Clark charges, Clark "extorted'' the tion Guerin about
+ lieves the
secrec.
had
broken
a secrecy. ~
~.~~
. ~ -~~
~ .
- r o v ~ s l o n o faeremrentfmrrrhiftr.
- - ~- ~
the agreement.
. 7Today's
session was intended
and wh
In addition, Guerin has agrue@'
to allow Clark's attorney, Joseph
in court, he should not be
quired to pay the.
money - $1 million
See GUEl
~
-.
-L
A-4
FROM P I
~-~
~~
....
~~
-py&
'
1'
Guerin is expected
to testify ~uesday
?ewn mEraMekeel
Stafl Wrlter
James H.Guerin is scheduled to give preliminary testimony Tuesday in his $2.75 million severance dispute with his former corporate
attorney.
If Guerin appears, it would be the first time his whereabouts have
been established since September.
Guerin. the founder of International Signal & Control, is disputing
the validity of the deal with William A. Clark, formerly its vlce
president and general counsel.
Guerin's deposition is set for 9:30 a.m. in the office of Clark's
S m s i o n is closed to the
attorney, Joseph F. Rod? 36
.- E. King
-.ns.hlie
r
UU....
I'Eideoosition
was scheduled in December at the order of Judge
-~
~..
Michael A. Georgelisof Lancaster County Common I'leasCourt.
Geargelis denled Guerin's bid to ha\.e the session delayed. pending
resolutl'on of ~ossiblecriminal charges aaainst him. and denied his
rique.it lolimit questionsstr~ctlyt o t h c a g k n e n t .
In court papers. Hoda has indicated he \ r i l l ask Guerin about issues
currmll\. under investigation b?' British and American authorltlcs.
becauseihey relate toGierln's stateof mlnd whcn he signed thedcdl
lnternatlonal Signal is being prubcd for posslblecontract fraud and
~llevalexDorts. Nocharges hare been fllcd
But Guerin
is beine sued bv International Signal's merger Dartner.
~Ferranti, torallegcdly participating ina $331)nilllion cont?acifraud.
Guerin's whereabouts have been a mystcry slncr. news 01 thc frautl
broke in Se~tember.Though he has homes in Naples. Fla.. and Lancaster. f r b r k ~~nattemnts
t ~ . . 6v
~the~Dress
- toreach hiin ha've been unsuc~.
cessful He reportedly has been t ; a v e l ~ nabroad.
~
In court DaDers. Guerin has said Roda's questioning \rill force him
to choose between defending himself against Clark and asserting his
constitutional right against self-incrimination. thereby posslbly losing to Clark.
Guerin also has said that answers to Roda's questions could "expose facts" that could hamper his defense against possible criminal
charges.
Tuesday's deposition is the latest development in seven months of
legal jousting between Clark and Guerin.
Clark signed the deal March 28 with Guerin and Parent Industries
Inc., at that time Guerin's holding company.
Guerin paid $1 million of the agreement. then balked at paying the
rest. Clarkstartedcourt proceedingslast July to collect the balance.
Guerin contends that Clark used extortion and coercion to obtain
the deal, and broke a secrecy provision in it. so the deal is void.
Guerin also claims that he has audiotapes of Clark that prove extortion was used.
Clark denies he used extortion to win the deal. He argues that it is a
legitimate agreement to compensate him for unfulfilled financial
promises.
Parcnt Industries Inc. presldenl Michael A. Peck is schcduled for
de~ositlonWednesdas. Peck bought
- Parent Industries Inc from Gutriliin September. In other developments today:
Ferranti is expected this week to report a loss of at least $8
million for the six months ended Sept. 30, in part because of the
restructuring costs from the fraud, said The Guardian newspaper.
The French firm Thomson-CSF is unlikely to complete a rescue
bid for Ferranti before Ferranti's Feb. 5 deadline, The London Times
reported.
~
.~~
----
~~~
~~
~~~~
-~
~~
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... .....
r l ' U C l i l l iilJlllOri[l
' -..: Section
.'. 3189 Federal False
US District Court
For Thehave
Easternbeen
District of Pennsylvana
Claim Act
criminal
charges
biggest defense
in Europe, but one of the
,nost
: ; ;1 $
t;$
;lfiled.
cleverly
orchestrated
99
ucts
wcre
actual\\
Guerin has steadfastlv" denied
"illegal" products
any wrongdoing.
a former Ferranti financial official
looking at whether
Guerin's attorney. Joseph A.
products were ship
Tate, said this week it is impossibiled military purp
ble to provide a detailed rebuttal
h r.~a
Whatev~r
~..
~- .. t.
...
to the fraud allegations because
of the ongoing criminal investi- suit as Lerwick Holdings S.A. ifying the French Mirage fightcr ranti bcgan raisi
gation. He said he cannot allow Marwick, an outside auditipg jet that would carry the missiles, about the Tech Ltc
Guerin to present his explanation firm that regularly checked In- the missiles were not shipped to ments from South i
a sudden halt.
of the alleged fraud. Nor, hesaid, ternational Signal's figures, took the Middle East kingdom.
Ferranti has wri
is there anyone who can steps to verify thecontract.
Turning that delay to its advanFerranti auditors and officials tage, Tech Ltd. signed the UAE $50 million that it
knowledgeably give Gucrin's
even visited Pakistan, where to a contract for a more sophistiside at present.
Shireman, the Marietta man they interviewed a man believed cated version of the Hakim, and
Fcrranli-is cxnec
who was head of finance at Tech to be Major Gen. Talat Masood, sold, or supposedly sold, the old
Ltd.. was out of town this week then in charge of Army ord- missiles to the People's Republic
and could not be reachedfor com- nance, and received satisfactorv of China.
Durine those
ment on the detailed fraud ac- answers to their questions, iimFerranti
officials
say
auditors
Guerin
and the 0th
count. His attorney didnot return pany officials say.
from Peat Manvick ins~ected
will have an oppo
.
phonecalls.
The alleged fraud began to un- portions of the old mi~silc
vr(1c.r.
The other two employees ravel as Guerin left the company orwhat they though1 a a s t h c mis- fend themselves
explanation (
named in the suit, Radcliife of in May to organize a Leveraged sile order, in a warehouse in 19nh. their
Pass
contract.
buyout
that
would
have
returned
Lancaster, and Resch, of San
But afte'r the missiles were
Meanwhile, the c
Clemente, Calif., have declined several divisions - including shipped from the warehouse, tigation
into Intet
comment on their lawyers' ad- TechLtd. -to hisownership.
they vanishcd. Private investigaThat deal collapsed when Gue- tors hired by Ferranti to find nal's business deal
vice. Radcliffe has told the Brituing.
ish court that he intends to o p rin was unable to get financing, them have beenunsuccessful.
Federal author?
after being turned down by Drexpose Ferranti's lawsuit.
are working "in c
During
a
chairman's
commitel
Burnham,
Citibank
and
Ferf the three losses idention" with their cc
tified by Ferranti, the ranti itself. Had the buyout been tee meeting, however, Sir Derek Britain's Serious :
Alun-Jones,
Ferranti
chairman,
completed,
investigators
believe
fictitious "Khyber
congratulated Guerin on the sale Taking part in the
Pass" contract was the alleged contract fraud might of
the missiles, which were then U.S. Attorney's 01
by f a r the most dam- not have come to light.
code-named
Project Alpha, one Department, IRS,
The
first
substantial
sign
that
aging. accounting for about $250
and other agencies.
director
recalls.
something was amiss came when
~ 1 1 l i k othe
f totdloss.
SO,
wherever
those
missiles
Ferranti
officials
noticed
a
lack
The contract, brought to the
company in late 1986 by Guerin of consistency on dates on con- are today, Ferranti says it had to
swallow a loss on them totaling
nersonall\~.called for delivery of tract documents.
about $100 miltion.
Further
financial
discrepanbroductiin systems for at least
The final shortage discovincorrect date
three missile systems - air-to- cies came to tight in summer, ered by Ferranti financial inves- theAnspeech
Retire,
andin
mid-July,
the
front
compaair, air-to-ground and ground-tonies abruptly were dissolved. At tigators is the smallest - under Richard Scott will
air.
$50 million - and the simplest to Lancaster Histori
~
was month's end, payments on the understand.
Tech Ltd.'s S U.D. D O S ~role
about his escape frc
Pakistan
deal
stopped
altogetht u pnll the pieces together. in this
Since the late 1970s. Ferranti prisoner of war ca
rase buyins h;~rd\vareand tech- e..r. ~
Ferranti officials now are con- officials say, Tech Ltd. and its rect day is Tuesdaj
n o l o ~ from
r
South Africa. and asvinced
the Pakistan1 contract predecessor ISC companies had New Era regrets the
sembling the systems for resale
been selling large volumes of
wasenttrely f~ct~ttous.
to Pakistan.
electronics - integrated cirJoseph C. Kauff
They
say
the
front
companies
Its contract called for supply of
cuits, antennas and other hightooling, technological "how-to" were all controlled by Guerinand tech communication equipment been re-appointed
ship roadmaster by
data, test facilities and missile had no ties to the CIA or South
to South Africa, a nation supervisors. A stor
Africa.
prototypes, all supplied by an
The contract managers, a shunned by many U.S. eorpora- day's New Era inco:
arms subsidiarv of BarlowFerranti official says. tions because of its racial segre- that another towr
high-level
Rand, a South ~ j r i c a ncorporahad been named to
wcre
people
simply posing in that gationpolicies.
tion, and a second as-yet unidenThose. sales were based on New Era regrets thc
role.
tified company.
The major general either was
Even by Tech Ltd.'s normal another impostor, paid by the
~
~
*
~
=
5
3
s
s
~
standards for high secrecy, the Perpetrators, or was a genuine rll
"Khyber Pass" contract had ex- official mistakenly responding to
ccptionalsecurity safeguards.
questions about a different misFirst, it was not accompanied sile project, company officials
a bank's now suspect.
by a letter of credit
guarantee that Tech Ltd. would
All the known contract docube paid. Supposedly, Pakistan ments were fabricated for the auobjected to such a letter, fearing ditors' benefit, a former Ferranti
news of the deal might
- leak official says, Other documents
through the bank.
that would have supported a real
Second, Pakistan's payments contract are nowhere to be found.
Clutches Billfolds- French
were routed indirectly to Tech
"If you'rean accountant, evRoute 340 o n The P l a ~ n& Fancy Far
Ltd. through a Swiss bank ac- erything is there for you. But the
O p e n Dally 9-5,Frl 9-8. Closed Sun 7~
count managed by a front compa- only paper is what was generated
s
a
~
~
~
~
~
~
ny. identified in Ferranti's law- for the financial people." another h
~
-..r..>4n
OUlrll,llL1Ci),
VUI
~~
I,"
~~~
fku&
-LLu
g;
/-5-98
$,irkel's o f New Y
BUXTON WALLE
I.'
necords seized at
local home aid probe
of Guerin-South Africa
Mekeel
!?ewTlmErastaff
Writer
-C.
45-'
~~
&-
LANCASTER 1\II
METROPOLITAN
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reportedly
to Haig by
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$8
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whonc~.a.s attorney. m e p h ~Roda.
.
sttempted to extract precise detsib on
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cueti.,.
inwye,.
Joseph rite. . d v d
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k$,ma"
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citing his constitutionalrights a e a i ~ cwm:
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fOav~dself-incrlmination. holdin m m n~ P a m t '"dueies Im..
nw &ban %&tinlnc; and Urban's
president and l w - t i m e O u e Mmnfidant,
M C h d A. Peek Wallegedly balklngon
; $ ~ : ~ t ~ ~ ~ f t
~ a ~ m & ~ $ ~ $ ~ ~ ~ $ & ~ $
."
~Ama&tsnworfOmIgnP"licY
m.
This wasmtlhc f b t nor the last, time
a r k elaimed O w t i n w i d him $1 milHaig a n d G u e r i n w d k i t h e i r . e l a t a n ~ Uonantheagrerment. thenped. Gueshipmu0uwbaefbaefcial.
t i o e o u n t e ~mying~~artharPvio~hted
a
ReagsnandFomipnPoU~~.~also~sldforin iPBB.awr k f m t h e politiealaffair
m v h m in lhe agmment mby the Halg-For-President committee organizedbylSCandheldatUKFwrSea. de
the daument null and void, and
JuUaUm
atoffed in art by lSC e m ~ i o N@
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.
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local
COP oPfieials attended the f u c t i m , r i n w d Four S e a m Sports Canpl?r. tosecu~etheagrecment.
aceording to n e u s p ~ w rreports of the the tw d e cdly nardinated a lucrauve
0~6rinetsimed~lsrLmre~taed
to tell CHRISTIANS
eventth.tralsedmmcW.WOlorHai~.
m
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n
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h
m
rewrts
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former
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BpoLes
PahsturimmmenlOlGen.Mohammad
jwy
invemgamn
into
U
k
alarms
ship
Achefording
the daummts, the wy.
made derp,te
W,I.
man '8s quoled as gsylng the eom~sny ZL~UI.H~~.
mm to south ~tricaandlad altered or m i l Y m
fabricated ISC% boob, infl.tingtheeom.
TmsdW ChwI.1
uam~ . ~ l ~ ~ k t ~ l s ~ ~ had
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~ r interest
i ~ ~in~&ig,
d ~sodt felt
h his
~ r f AndHligmmWmvi.thIXafterib
~ ~
wouid"heahe~litf0rus."
November 181 m er wlth lhe British pony's w r U l to s e a m a November 1%
crptlm" bY h n
me eontnbutims wre ,ue presidency
~
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mrrgerwlthBtiti~hd~ense@antPemn.
Isd to rn ~ l u
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tive,
and
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"inner
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reee
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i
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lor
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M
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attomy admitted u d o r
a t h he
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CLIENT LIST
National Institute of
Standards & Technology (NIST)
Groller Electronic Publishing
E. Giovanetti
Dialcom
Vaghi Periodicles
Clahritas
Advanced Systems Development
Compaq Computers
Applied Optical Media Corporation
Commodore Business Machines
DRI/McGraw Hill
Meridian Data
Pennsytvania Blue Shield
INFO ONE lnternational
University of Montana
National Technical Information Senrice
Rochester Institute of Technology
NEC
Amp, Incorporated
Parkway School District
H i c h i Systems Division
Department of Commerce
Mathew Bender Co., Inc.
Nortek Computers, Ltd.,
University Microfilm International
Bell Atlantic
Aspen Systems Corporation
Microsoft Corporation
Arther Anderson
PC Solutions Plus
capitol Records
Digital Audio Disc Corporation (SONY)
lngram Customer Systems
University of Hawaii at Manoa
National Bibliographic Sewice
International Business Machines (IBM)
TUTASTAT
JUTASTAT
~os1.l address: PO Box 1 0 1 3 . Kenwyn, 7780 -Physical addreas: Mercvny Crescent. W e M n , 7764
TeI(021) 191-5101 - Fax (021) 78f-5010
31 January 1991
Mr S J Caterbone
Advanced Media Group, Ltd
1857 Colonial Village Lane
Lancaster, Pennsylvania 17601
USA
Dear Mr Caterbone
CD-DIAGNOSTIC
Further to my letter of 17 December 1990, 1 look forward to receiving further information on
the above product at your earliest convenience. Thank you.
Yours sincerely
,
S P SEPHTON
PC SYSTEMS
TO
S.A.
--
Aug 8, 1990
Gentlemen,
We are one o f t h e biggest IBM / COMPAQ k u t h a r l z e d De:ier
Greece, and we have a s p e c l f f c enquiry f o r
in
C D - G e n e r a t i o n - S i m u l a t i o n Software w i t h t h e f o l l o w i n g requiremeilts :
1. I n p u t from magnetic tape ANSI l a b e l l e d , EBCDIC.
2. Creates d i r e c t o r y and hard d i s k i d e n t i t y h i g h S i e r r a / I s o .
3 . D i s k image e d i t o r h i g h S i e r r a .
4 . Loads new f i l e s i n d i r e c t o r i e s .
Best Regards
C h r l s Giataganas
Sales Manager
PC SYSTEMS S.A. / ATHENS/ GREECE
=-S*-sis
-
@a
1 3 C L = =:
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM HEWLETY
Page 609 of 646
-Property of Advance Media
Group .-
PACKARD
10/19/2006
,,,I,!
FAX MESSAGE
6 June 1990
USA
Dear Sir,
We are interested in having your cornyany master n 50MB CD-ROMdisc for us and
press 750,000 duplicates of it. The discs will be i~rsenedinto magazines, so will no!
r y u i r e jewei boxes but will rcquirt soft plastic encasement. I would like to have a
quotation on what the cost for (he lot w o ~ ~bc,
l d for both 2- and 4-colour artwork.
if you q u i r e more detniled infomstio~ibefort: you can give 4 prccise quotation, please
do not hesitate to contact us; however, wc would appreciate a rough estimate in the
m m time.
Yours sincereiy,
M a i n e Winchester
hlanaging Director
Thursday
2016
T e l (8521668
I t 1 8 December
F z x i 8 5 ? ) 515,
4 5 n7?0
10/19/2006
21 July 1990
American Helix Technology Corporation
1857 Colonial Village Ln.
Lancaster, PA
17601 USA
Dear Sirs,
A recent article in Personal Computing' I camc across a reference to your organization. I would
appreciate as much information that you could send me on your Indexing and retrieval software and
service bureau. If possible could you also include price lists and turn around times.
Sipcerely,
,-
A.R. Kruger
Chief Exec~rtiveOgicer
Section 3189I?
Federal
False
Claim M~tchc
Act
Statcon
Street,
V~ci.?r~o,
313"LALlrol
Carrespondence
P -.,si3::
c! CIC~ICSI
Disc ?eC!1iiOiOQIPS Ply. Lla.(111~.in Vic.)
T e l e f ax
~ m t i w a l +513
:
873 5679
...................
1 . . . . . . . . . . . l l . . . . . . . . . . . . ~ . . . . . . . . . . . . . . . . . * . . . . . . . . . . . . . .
mto
W.of ~aqsei1
3 1 F . m Gt' MARKETIS
AmIm
HELIX T m
Irftf3
FaxNo.
m CCRPCRRTICN
: 18ch S p C 90
..............................................................................
The p&uct
will be bssd on a n IBM platform, full text only, w i t h a ! - ~ y p z
t s x t f a c i l i t y available.
Given this is our first project, I w u l d appreciate as much infornntion a s y>u
m11ld provils w w i t h .
I ! w k forward to
hearFng f m you.
RILHA.tcD 51sIflr9.mging D i r e c t o r
CD RCB! & ILascxiates
I -
Ins
Informac8es,
..~.~
~
SSo P a u l n ,
i 0 t h September 1790
Sinc:erely
yours,
O p t i c a l Pub1 i s h i n s D i v i s i o n D i r e c t o r
Tel
Direct:
( @ i s ) 575-5600
( 0 1 i ) 547-6474
(011) 575-6454
OPTiCAL
M E D I A
DIVlSlON
Datum / Date:
F( /n/h
Absendei: / from:
weiterleiten an: / CC:
Rvkn Si? bitte ehestm6glich an,falls Sle nicht alle Seiten emalten haben sollten !
If you do not receive all pages, please call as soon as posslble !
M e d l a D l v l s l o n
Eine Abteiii-~ngder / a dlvlsion of
Digital
Image
Systems
Computertechnil<
Gesellschaft
mbH 15, 2016
EXHIBIT U.S. 16-4014 CIVIL
RIGHTS
CLAIM
Page 614
of 646
Thursday December
Property of Advance Media Group
Page 2720
10/19/2006
Am Wlnterhafen
13of 2953A-4020 Linz Austria
Optical
-,
.-
--
2 3 d Oct;.
90
American H e l i x T e c h n o l o q y Corp.
1857, C o l o n i a l V i l l a c i e t n .
L a n c a s t e r , P.; 17601
U.S.A.
ue-r S i r ,
.'iea r e rvorkina or! 2 p r o j e c t t h a t v d i l l r e q u i r e p u h l i s h i n q
CD-RGh: i < i s c . We b e l i e v e , yo12 o f f e r s e r v i c e s & p r o d u c t s
required for ~ubli.hir!,>
CD-RCt!: : < i s c s . 'fie w i l l be g r a t e f u l , i f you i o c l d s e n d u s d e t a i l . of y o u r s e r v i c e s and
p r o d u c t s i n c l u d i n s t h e Code Scheme you f o l l o w f o r i n d e x ir..r a n d r ~ t r i c v z l , s o t h ~ '::o
t
c a n a p p r o a c h ycu a t t h e .
r r !
'?lc . : c ~ : d l i k f : t o ,;c?t p r i c i n q of t h s s e i t e n i s
f o r cur budgetary purpose.
It w i l l a l s o h e l p us t o get
a l i s t of y o u r c l i e n t s a n d t y p e o i s e r v i c c s you h a v e
o f f e r e d t h ~ m5n t h i s a r e a .
R e p r i n t s of r e v i e t v a r t i c l e s
on your proc!ucts w i l l be o f o r p a t h e l p t o u s .
d
,-c e a r l y r e n l y "\)ill
be h i q h l y ~ ~ n r e c i a t e d .
T h a n k i n g ycu.
Yours s i n c e r e l y ,
p z d i i i ~ ;\en
Principal Scientist
: 1 1 3 l - 7 ? 7 4 1 IRIS IN
Northwest
Territories Culture & Communications
August 20, 1990
Al Granger
Territorial Printer
10/19/2006
SOCIEDAD E S T A W
PARA LA EJECUCION
DE PROGIWMAS
DEI. QIJINTO C E N T E N M O
American H e l i x
A l e x a n d r i a VA
5 t h March, 1990.
U.S.A.
Dear S i r s ,
May we k i n d l y t a k e t h i s o p p o r t . u c l t y t o ! n t r o d u c e o u r s e l v e s .
We a r e an i n t e g r a l p a r t o f t h e "Sociedad E s t a t a l Q u i n t o C e s t e n z r i o " ,
~ l i i i l ?i s c u r r e n t l y s o r k i n g on inany p r o j e c t s c o m n ~ m o r a t i n g t h e d i s c o , ~ e r y
c f America 500 y e a r s ago.
31ir p r o j e c t f r p a r t i c u l a r i s sa'11ed "530 Years r
, af?d i t s sge::Fic
c i m i s m a i n l y t h e c r e a t i o n o f an i n r e r s c t ! v e o p t i c a l i n f o r m a t i o n system
eiicc3passi ny an e x t e n s i YE rh!:ge o i l ! ~ f o r m a t i o r l l i ~ c c r p o r a t ~ n gt h e
rrinjority o f South America arid P a r t s o f Europe.
!+e b e l i e v e y o u w i l l
be r u r ! n i n g
specific
s e ~ i i l n a r s on
the
follo'dlng
s:~bjects:
1990)
Implernentlng L a s e r d i s c Technology ( 1 8 t h t o 1 9 t h A p r i l , 1 9 9 0 ) .
'~(9
P.T.O.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM Page 617 of 646
Property of Advance Media Group
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ASSET
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Mortgage Banking
Activities
Stanley J. Caterbone
07/01 187
'MUTANT MANIAg
Digital Movie
Stanley J. Caterbone
& Tony Bongiovi
07/01/87
Navaho 'CHIEFTEN'
Airplane
Stanley J. Caterbone
07/01/87
Stanley J. Caterbone
09/03/87
I
i
ESTIMATED
VALUE
TOTALS
A 12% growth rate is used on all assets accruing from July 1, 1987 to January 1, 1991.
?he capital required to produce the movie "MUTANT MANIA, as seen in the budget developed and created by
California, as sent to Stan Caterbone from Arlene Davidson, Associate Producer.
EXHIBIT U.S. 16-4014 CIVIL RIGHTS CLAIM Page 622 of 646
Property of Advance Media Group
11
1
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ASSET
OWNERSHIP
Stanley J. Caterbone
50,000 Shares of
Financial Management
Group Ltd., Stock
Stanley J. Caterbone
DATE
LOST
ESTIMATED
VALUE
A 12% growth rate is used on all assets accruing from July 1, 1987 to January 1, 1991.
This real estate investment was financed by Parent Federal Savings and Loan, owned by James GI
Parent Federal had filed foreclosure proceedings in November of 1987. The property was sold
before the pending Sheriff's Sale in July of 1988 for approximately $140,000 to the first offeror.
?his real estate investment was sold under duress in October of 1987 to James Warner in order tc
proceedings.
4
In the Financial Services Industry, companies with substantial distribution of financial products ano
valuation formula in order to determine value and worth. Industry statistics suggest that a companies va
Gross Commission Income generated by that company. The standard formula suggests that for every $ C
Income (GCI) Equals $ .70 to $1.00 of Equity. In June of 1987, Financial Management Group, Ltd., had re
Commission Income (GCI) of approximately $3,000,000. In addition FMG, Ltd., had recently consumrn;
of Planners Securities Group, an Atlanta based Broker Dealer, which was selected by Stan J. Caterbon
PLAZA
P H I L A D E L P H I A , PA. 1 9 1 0 2
A R T H U R H. S E I D E L
TELEPHONE:(215) 5 6 8 ~ 8 3 8 3
3 O E L S. GOLDHAMMER
M I C H A E L P . ABBOTT
p~
2 5 J u n e 1987
p~
GROUP
I. I , b I 8 4
E D W A R D C. G O N D A
I 1 9 3 0 I S e 5 i
DURLiNG
S T E P H E N J. M E I E R S
AMANDA L A U R A N Y E *
NANCY A
845~218
CABLE. SIPAT
TELkCOP$ER 1 2 1 5 1 5 6 8 ~ 5 5 4 9
G R E G O R Y J. LAVORGNA
D A N I E L A . MONACO
THOMAS J
TELEX
OF C O U N S E L
SYLVIA A . G o s r T o r r v l
S T A N L E Y H. Z E I H E R
RUeNER
SCOTT J FIELDS
N r . S t a n l e y Caterbone
FMG A d v i s o r y , I n c .
Eden P a r k I 1
1 7 5 5 Oregon Avenue
L a n c a s t e r , PA 1 7 6 0 1
RE:
Power S t a t i o n
Our F i l e :
7351-G
Dear S t a n :
I h a v e now r e c e i v e d t h e r e s u l t s o f a s e a r c h
p e r t a i n i n g t o t h e above s u b j a c t .
I have a l s o r e v i e w e d t h e f i l e
f o r w a r d e d w i t h y o u r l e t t e r o f May 2 9 .
The f o l l o w i n g i s my
a n a l y s i s and e v a l u a t i o n of t h e r i g h t t o u s e "Power S t a t i o n " a s
d e f i n e d below.
A s I understand the s i t u a t i o n , your b u s i n e s s c l i e n t ,
Power S t a t i o n S t u d i o , h a s , s i n c e 1 9 7 7 , o p e r a t e d a r e c o r d i n g
s t u d i o with a widely regarded r e p u t a t i o n f o r providing high
q u a l i t y r e c o r d i n g s e r v i c e s u s i n g s t a t e of t h e a r t e q u i p m e n t .
The
e n c l o s e d r e p o r t r e v e a l s t h a t Power S t a t i o n s t u d i o h a s r e g i s t e r e d
t h e t r a d e m a r k "Power S t a t i o n " f o r s o u n d r e c o r d i n g s t u d i o s .
(See
Reg. No. 1 , 4 3 3 , 3 2 8 r e g i s t e r e d March 1 7 , 1 9 8 7 . )
You h a v e a s k e d me
t o i n v e s t i g a t e t h e p o s s i b i l i t y o f Power S t a t i o n e x p a n d i n g t h e u s e
o f i t s mark i n t o m e n ' s and women's c l o t h i n g i n c l u d i n g b e a c h w e a r ;
a n d f o r a u d i o a n d vide(:, e l e c t r o n i c s f o r c o n s u m e r s a n d
professionals.
I h a v e assumed t h a t t h i s l a t t e r c a t e g o r y i n c l u d e s
radios, television receivers, video c a s s e t t e r e c o r d e r s , a u d i o
r e c o r d e r s , compact d i s c players, turn t a b l e s , amplifiers,
r e c e i v e r s , t u n e r s , c o n t r o l p a n e l s , mixing b o a r d s and c o n s o l e s ,
among o t h e r t h i n g s .
Based upon t h e r e s u l t s of t h e e n c l o s e d s e a r c h , i t i s
my o p i n i o n t h a t i t would be i n a d v i s a b l e f o r Power S t a t i o n , I n c .
t o u s e i t s mark f o r c l o t h i n g a s a f o r e s a i d .
The b a s i s f o r my
SEIDEL, GONDA,GOLDHAMMER
& ABBOTT;F! C .
Mr.
S t a n l e y Caterbone
-2-
25 J u n e 1 9 8 7
o p i n i o n i s R e g i s t r a t i o n No. 1 , 4 3 1 , 2 4 2 r e g i s t e r e d :.larch 3 , 1 9 8 7
Eor "Power S t a t i o n " .
The r e g i s t r a n t c l a i m s a f i r s t d a t e o f u s e
o f A p r i l 3 , 1986 f o r w o m e n ' s c l o t h i n g i n c l u d i n g s w i m w e a r a n d
o t h e r goods a s l i s t e d .
A l t h o u g h y o u r c l i e n t h a s a s t r o n g r e p u t a t i o n , and
a l t h o u g h i t h a s p r i o r i t y o f u s e f o r t h e mark, t h i s r e g i s t r a n t h a s
a s t r o n g p o s i t i o n f o r arguing t h a t it has superior r i g h t s f o r
women's c l o t h i n g .
One would n o t o r d i n a r i l y a s s o c i a t e c l o t h i n g i n
a n y way w i t h r e c o r d i n g s t u d i o s e r v i c e s .
Thus, your c l i e n t ' s
r i g h t s i n i t s mark d o n o t a p p e a r t o d o m i n a t e t h o s e o f t h e
registrant's.
A c c o r d i n g l y , u s e of t h e Power S t a t i o n mark f o r
women's ( o r m e n ' s ) c l o t h i n g would i n v o l v e a s i g n i f i c a n t r i s k o f
b e i n g a c c u s e d of t r a d e m a r k i n f r i n g e m e n t .
Use o f t h e Power S t a t i o n m a r k f o r c o n s u m e r a n d
p r o f e s s i o n a l a u d i o and v i s u a l e l e c t r o n i c e q u i p m e n t r a i s e s some
i s s u e s , b u t o n t h e w h o l e I am o f t h e o p i n i o n t h a t i t i s
permissible.
A g a i n , I a s s u m e , a s I have b e e n i n f o r m e d , t h a t t h e
Power S t a t i o n s t u d i o i s w e l l k n o w n a n d d o e s h a v e a g o o d
reput-ation f o r its e x i s t i n g s e r v i c e s .
Given t h a t , i t s movement
i n t o e l e c t r o n i c e q u i p m e n t s h o u l d be p e r m i s s i b l e .
Here t h e good
w i l l a s s o c i a t e d w i t h i t s c u r r e n t s e r v i c e s c a n be more r e a d i l y
extended t o audio v i s u a l e l e c t r o n i c equipment.
T h e s e a r c h r e v e a l s t h a t M a n v i l l e C o r p o r a t i o n ' s Ken
C a r y l Ranch i s t h e owner o f t h e mark "Power S t a t i o n " f o r b a t t e r y
o p e r a t e d emergency e l e c t r i c a l 2ower s u p p l y u n i t s .
S e e Reg. No.
1 , 0 4 0 , 3 0 8 r e g i s t e r e d May 2 5 , 1976 and c l a i m i n g a f i r s t d a t e o f
u s e of November 2 3 , 1970.
I n my o p i n i o n , a u d i o v i s u a l e l e c t r o n i c
e q u i p m e n t c a n b e c o n s i d e r e d t o be s u f f i c i e n t l y u n r e l a t e d t o
emergency e l e c t r i c a l power s u p p l y u n i t s t o a v o i d a l i k e l i h o o d of
c o n f u s i o n even though t h e marks a r e i d e n t i c a l .
I r e a c h t h e same c o n c l u s i o n r e g a r d i n g t h e pending
a p p l i c a t i o n by E l e c t r i c a l C o n d u c t o r s , I n c . f o r a m u l t i p l e o u t l e t
power s t r i p .
A c l o s e r q u e s t i o n is r a i s e d by G o u l d ' s S u p p l e m e n t a l
R e g i s t e r r e g i s t r a t i o n f o r Power S t a t i o n f o r m i n i a n d
microcomputers.
G o u l d ' s mark is r e g i s t e r e d on t h e S u p p l e m e n t a l
R e g i s t e r u n d o u b t e d l y b e c a u s e "Power S t a t i o n " a s a p p l i e d t o
computer equipment is considered t o be d e s c r i p t i v e .
A
Supplemental R e g i s t e r r e g i s t r a t i o n h a s none of t h e p r o c e d u r a l
b e n e f i t s of a P r i n c i p l e R e g i s t e r r e g i s t r a t i o n .
Moreover, i f
G o u l d ' s u s e o f t h e mark i s l i m i t e d t o a p a r t i c u l a r m a r k e t w h i c h
f,lr. S t a n l e y C a t e r b o n e
-3-
25 J u n e 1987
is d i s t i n c t from your c l i e n t s , t h e r e d o e s n o t a p p e a r t o b e a
l i k e l i h o o d of confusion.
T h u s , G o u l d may b e s e l l i n g i t s
c o m p u t e r s i n t o a s p e c i a l i z e d c o m m e r c i a l m a r k e t i f i t is p r e s e n t l y
s e l l i n g computers a t a l l .
Next I c a l l y o u r a t t e n t i o n t o t h e f a c t t h a t s e v e r a l
r a d i o s t a t i o n s have a d o p t e d a n d a r e u s i n g t h e t r a d e m a r k "The
Power S t a t i o n " i n v a r i o u s c i t i e s throughout t h e Unlted S t a t e s .
Conceivably, these radio s t a t i o n s could o b j e c t t o t h e
i n t r o d u c t i o n o f consumer e l e c t r o n i c s i n t o t h e i r market a r e a on
t h e g r o u n d t h a t t h e u s e o f t h e same mark i m p l i e s s p o n s o r s h i p b y
them.
I n o t e t h a t a l l o f t h e s e m a r k s were r e c e n t l y r e g i s t e r e d ,
and I s u s p e c t t h a t a l l of t h e s e r a d i o s t a t i o n s a r e r e l a t e d o r
c o m m o n l y owned.
I a l s o s u s p e c t t h a t t h e a d o p t i o n o f t h i s mark
may b e o f r e c e n t v i n t a g e .
Thus, your c l i e n t i n any n e g o t i a t i o n
w i t h t h e s e p e o p l e would have t h e a d v a n t a g e of b e i n g a p r i o r u s e r ,
and t h e r e l a t i o n s h i p between r e c o r d i n g s e r v i c e s a n d e l e c t r o n i c
e q u i p m e n t on t h e o n e hand and r a d i o s t a t i o n s e r v i c e s and
e l e c t r o n i c equipment on t h e o t h e r hand i s a t l e a s t c o - e q u a l .
Thus, your c l i e n t should have t h e dominant p o s i t i a n .
I n v i e w o f t h e f o r e g o i n g , i t i s my o p i n i o n t h a t The
Power S t a t i o n s h o u l d n o t a d o p t o r u s e " P o w e r S t a t i o n " f o r m e n ' s
a n d w o m e n ' s c l o t h i n g , b u t i t may a d o p t a n d u s e t h e m a r k f o r
p r o f e s s i o n a l and consumer e l e c t r o n i c s a s d e s c r i b e d above w i t h t h e
u n d e r s t a n d i n g t h a t t h e m a t t e r is n o t e n t i r e l y w i t h o u t d o u b t a n d
issues could arise.
I t i s , h o w e v e r , my o p i n i o n , b a s e d u p o n t h e
f a c t s p r e s e n t l y a v a i l a b l e t o me, t h a t The Power S t a t i o n , I n c .
should prevail i f those issues arise.
I f you have any q u e s t i o n s concerning t h e f o r e g o i n g ,
p l e a s e f e e l f r e e t o c a l l me.
With k i n d e s t p e r s o n a l r e g a r d s ,
Sincerely yours,
,'.
JSG:mp
Encl.
TRACK
10/12/91
1987 RECORDED AUDIO CONVERSATIONS "SELECTIVE CONVERSATIONS"
TITLE
DATE
PERSONS
BEGIN
END
PA SEC I
09/29/87
ISC ALLEGATIONS
Howard Eissler
Bill Johnson
Robert Byers
Stan Caterbone
0000
0-1 6-01
0792
11-51-40
Sandra Gray
02/24/88
Sandra Gray
Stan Caterbone
0793
11-51-58
1230
20-14-00
Lanc. Aviation
07/10/87
Chuck Smith
Stan Caterbone
1236
20-14-08
1467
25-11-06
Dave Drubner
07/07/87
Dave Drubner
Stan Caterbone
1470
25-11-10
1581
27-43-26
Avalon Police
08/27/87
1582
27-43-32
1960
52-56-03
Gamillion
Studios, Inc.
07/21/87
Ted Garnillion
Stan Caterbone
Marcia Silen
04358
52-26-15
06718
56-57-00
Family
07/26/87*
Stan Caterbone
Steve Caterbone
Phil Caterbone
Mike Caterbone
Tom Caterbone
1967
End A
Robertson
07/12/87
Scott Robertson
Stan Caterbone
OOOOB
04348
/ DATE:
7
TITLE:
10/12/91
1987 RECORDED AUDIO CONVERSATIONS "SELECTIVE CONVERSATIONS"
TRACK TITLE
Power
Station Studios
r
3
DATE
PERSONS
07116/87
Bob Walters
Stan Caterbone
0672B
56-57-10
09408
61-01-1 0
10/28/87
Howard Eissler
Stan Caterbone
09428
61-53-10
10418
64-40-1 0
Detective Bodan
Stan Caterbone
1093B
64-50-10
12628
68-18-1 0
10
PA SEC II
11
PA ATTORNEY
10/28/87
GENERAL OFFICE
BEGIN
END
LOCAL NEWS
n national to
reading. And
:W Era Alma-
by N m W e e l
New Era Staff Wnter
itb bank,
. ,,
. ..
._-.
-
Defamation of C h a r a c t e r
Slander
Mental Duress
Malice
Unfair C a T p e t i t i o n
Wrongful I n t e r f e r e with BusiRelations
Wrongful I n t e r f e r e m w i t h C o n t r a c t s
Trezpass to P e r s s n
Burglary
Theft
Criminal Mischief
I n v a s i o n o f Privacy
T r e z p a s s to Personal P r o p e r t y
Undoinf l u e m
Fraud
Conspiracy
EMxzzlmnt
Breach of C o n t r a c t
Extortion
Forgery
S b r h o l d e r Freeze-cut
- -
Cornno-lth
M t l 0 ~Bank
1
Penn m a r e
Lancaster, PA
176432
W l l o n Bank
Pittsburg, PA
Parent Carpany
Mike W o l f , Executive Vice President of Comnercial Lending
f ' w PEAJBLOS
U(;ATIONS.:
Defamation o f Character
Slander
Mental Duress
Malie
Unfair Cocrpetition
Wrongful I n t e r f e r e ~ zw i t h Business Relations
Wrongful Interference w i t h Contracts
Trespass t o Person
T M t
Criminal Mischief
Invasion o f Privacy
Trespass to Personal Property
Undoinf luenoe
Fraud
Conspiracy
EntEzzlement
Breach of Contract
Extortion
Defamation of Character
Slander
Mental IXlress
Malice
Unfair Conpetition
Wrowful Interference with BusiRelatiom
Wrowful Interference w i t h Contracts
T r e s p a s to Person
Theft
C r i m i m l Mischief
Invasion of Privacy
Trespass to Personal Property
Urdoinf luence
Fraud
? Corqsiracy
I EmSezzlement
Breach of Contract
Extortion
r/Aw ,455
PLLE%~.ICNS:
Defamation of Character
Slaoder
Mental Duress
Mall03
Unfalr Corrpetr t i o n
Wrongful Interference w l t h BusiRelations
Wrongful Interference w l t h Contracts
T r e z p a s t o Pemn
,ary
.
- .
Theft
Invaslon of Prlvacy
Trespass t o Perzonal
Undolnfluence
Fraud
Cor?zplracy
Breach of Contract
t Extortion
Property
C'
Hunllton Bank
Oregon Plke
Lamaster, PA
17601
Defamation of Character
Slander
Mental Duress
Malice
Unfair Conpetit i o n
Wrongful Interference with Business Relations
Wrongful Interference with Contracts
Trt o Person
Trto Personal Prcperty
Undoinf luence
Fraud
Coqiracy
Breach of Contract
Extortion
F u l t o n Bank
O l d Hickory B r a n c h
Stor L a n c a s t e r . PA
17601
?6tl
U n f a i r Conpeti t i o n
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o m
Wrongful I n t e r f e r e with Contracts
Undoinfluem
Fraud
Comiracy
Erkezzlement
B r e a c h of C o n t r a c t
Extortion
Cor
Brc
Berdett T m l l n Hospital
Cape Nay County Courthouse
Stone Harbor, NJ
08247
Social Worker
Psychiatrist 1
Psychiatrist 2
WEGAT IONS:
Defamation of Character
Slarder
k n t a l Duress
Malice
Unfalr Carpetrtlon
Wrongful Interferew l t h Busines Relatiow
Wrongful Interference w i t h Contracts
Tnzspass to Person
Irwa~lon
of Prrvacy
Trespass to Percsml Property
Undolnf luence
Fraud
Cowpiracy
Breach of Contract
~orgsry
Neg11gsnce
Officer Dean
Fat Aswrciate
Defamation of Character
Slander
Mental Duress
Malice
Unfair Conpetition
Wrongful Interference with Business Relations
Wrongful Interference with Contracts
Trespass to Percan
Burglary
Theft
Criminal M i x h i e f
Itwasion o f Privacy
Trto Personal Property
Undoinf l u e n z
Fraud
Conspiracy
En'&ezzlmnt
Breach of Contract
Extortion
Forsew
Sharholder Freeze-out
mligence
k n h i m Towrship P o l i c e Deparbnent
C i r c l e Drive
Lancaster, PA
17601
D e t e c t i v e Mathias
Officer 1
Officer 2
Officer 3
Officer 4
Defamation of C h a r a c t e r
Slander
k n t a l hresr
Malice
'j
Wrongful I n t e r f e r e n c e w i t h Business R e l a t i o n s
Wrongful I n t e r f e r e with Contracts
T r e s p a s s to Person
8urglat-y
Theft
C r i m i n a l Mischief
Invasion of Privacy
T r e s p a s s to Personal P r o p e r t y
Undoinf l u e m
Conspiracy
Breach of C o n t r a c t
Negligznce
L a n e a s t e r P o l l c e Department
W. Chestrwt S t r e e t
L a n e a s t e r , PA
17602
Defamation of C h a r a c t e r
Slander
Mental DuMalioe
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o w
Wrongful I n t e r f e r e n c e w i t h C o n t r a c t s
Trto Person
Undoinfluence
Fraud
Conspiracy
Breach of C o n t r a c t
Negligence
Jocsh R c d a , E s q .
301 C l p k r Building
36 E. K i y Street
L a m a s t e r , PA
17602
(717) 397-5791
Defamation of Character
Slander
k n t a l Duress
Malice
Unfair Conpeti t i o n
Wrongful I n t e r f e r e w i t h Business R e l a t i o m
Wrongful I n t e r f e r e with Contracts
Undoinfluence
Fraud
Colqriracy
Embezzlenmt
Breach of Contract
Extortion
S h a r b l d e r Freeze-cut
Neglisnce
Lou S c ~ l l e r Esq.
,
V a l o r e , M c A l l i s t e r , W i x o r e l a n d , Gould, V e s p e r & Sctwartz
Northfield, NJ
(609) 64-1111
Mental Duress
Malice
U n f a i r Gorrpetltion
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s R e l a t i o n s
Wrongful I n t e r f e r e n c e w i t h C o n t r a c t s
Undoinf l u e n c e
Fraud
Conspiracy
mzzlement
Breach of C o n t r a c t
Extortion
Negligence
D r . W r s h a l l L e v i r e , E ffl D P A
l a 1 T i l t o n Road
N o r t h f i e l d , NJ
(653) 646-2011
D e f a m t i o n of C h a r a c t e r
Slander
Mental LXlresr
Malice
Unfair C a r p e t i t i o n
Wrongful I n t e r f e r e n c e w i t h B u s i n e s s Relations
Wrongful Interference w i t h C o n t r a c t s
T r e a s s to Person
I n v a s i o n of P r i v a c y
Undoinf l u e e
Fraud
Comiracy
Fdxzzlmnt
Breach of C o n t r a c t
Extortion
Neglige-