Letter to Matt Samley of Xakellis Reese & Pugh re ISC Opinion and Invoice

Stan J. Caterbone
220 Stone Hill Road
Conestoga, PA 17516

April 7, 1998
Mr. Matt Samley
Xakellis, Reese & Pugh
129 East Orange Street
Lancaster, PA 17603
Re: Outstanding Invoice
Dear Mr. Samley:
I refute payment of the above mentioned invoice for the following reasons:
1. Reasonable Time As Promised. On or about November 24, 1997, we had a
telephone conversation while at my office of Pflumm Contractors, Inc., when
you had offered to update your progress on my request for a legal opinion
relating to the matters described herein. You had indicated that you were
busy, and that I would have a letter soon. I had stated that I was in no
immediate need, as long as it was within a reasonable amount of time. You
had promised me that it would be forthcoming immediately following the
Christmas Holidays. And I agreed with that time schedule.
I received the document on February 28, 1998, some 50 or so days after your
promised time schedule, and by your own accounting of my billing hours, it
took you approximately 60 days to complete the last 40 minutes of your
efforts.
This certainly does not constitute reasonable, as you had promised, and raises
questions as to your good faith efforts regarding my issues. Furthermore, I had
never had any conversations with you pertaining to these matters since that
conversation on or about November 24th, which you had an ethical obligation
to notify me if you were not able to deliver your opinion as promised.

2. Conflict of Interest. Immediately following my departure of Pflumm

Contractors, Inc., on February 20th, 1998 and my sworn statement to the PA
Unemployment Compensation Review Board, given the fact that you
represent David Pflumm and Pflumm Contractors, Inc., constitutes a conflict
of interest by most if not all of your Professional Code of Ethics . The fact
that you have conveniently delivered your legal opinion immediately

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April 7, 1998

Letter to Matt Samley of Xakellis Reese & Pugh re ISC Opinion and Invoice

following my departure of February 20th, certainly raises some questions as

to the timing of your legal opinion, which is dated February 26th.

3. The Legal Opinion. The following paragraph will serve my purpose,

Regarding the arrest and subsequent prison term, that should have been dealt
with through the appellate process and Post-Conviction Relief Act process and
frankly I do not see anything here at this time that could be done regarding and
arrest ten years ago and that time was served. To expunge a record now would
probably be beyond the statute of limitations for doing so. Finally, even it it
were possible, the fact that this presumably went to a jury and the jury found you
guilty seemed to indicate that at least based on the evidence provided, the jury
had some belief to find you guilty of what you were bound over for trial for.
Where on Gods earth did you find any information to insinuate that I was ever
convicted of any crime. Thank you, you have just proven my point. That
preceding statement, given the wealth of information that you have in your
possession, substantiates the fundamental foundation of the legal issues that I am
questioning, which undermines the framework of my civil, constitutional, and
shareholder rights.
I request that you immediately return all of my documents, and attest that no
copies of both paper and or audio have been retained by you or by Xakellis,
Reese & Pugh.

I remain,

Stan J. Caterbone

cc: Samleyfile

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