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www.amgglobalentertainmentgroup.com
scaterbone@live.com
717-669-2163
Stanley J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
IN THE UNITED STATES THIRD CIRCUIT COURT OF APPEALS
_______________________________________________________________________________
Lisa Michelle Lambert
:
PETITIONER
:
:
v.
:
CASE NO. 3400-2015
:
:
Lynn Bissonnette, et al.,
:
RESPONDANT
:
:
Stanley J. Caterbone
APPELLANT

:
:
:

SUBMISSION AS EXHIBIT BY APPELANT


806 Authentic Original Documents from 1983 to 2006, November 18, 2015

I hereby on this 18th day of November, 2015, submit for considerations in the above captioned case the
attached document as an EXHIBIT to be considered by the court in the deliberations of this case. This exhibit, like
the previous EXHIBITS, is intended to help the Court understand the complexity of the APPELLANT'S obligation to
provide the Court with the evidence and insight to support the APPELLANT'S claims and statements. These
documents will also provide the Court with sufficient knowledge of the APPELLANT'S claim of the value of the
Appellant's litigation of up to $50 million dollars as stated in the U.S. Bankruptcy Case No. 05-23059. The
APPELLANT does not intend to overburden the Court with unnecessary filings, however this burden of supporting
the claims and statements falls on the shoulders of all those in the government that ignored the APPELLANT'S
pleas for help to resolve these issues dating back to the days immediately following the meeting with International
Signal & Control, Plc., (ISC) Executive Larry Resch on June 23, 1987.

Date: November 18, 2015

/s/ Stanley J. Caterbone


Stanley J. Caterbone, Pro Se
Appellant
1250 Fremont Street
Lancaster, PA 17603
(717)-669-2163
scaterbone@live.com
http://www.amgglobalentertainmentgroup.com/__

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D R A F T -- N O T F O R P U B L I C A T I O N

Escaping the UNIX Tar Pit

Producing CD-ROMs in the UNIX Environment2


Authored in 1991
Stan J. Caterbone

John S. Garofolo

Director of CD-ROM Technologies for


American Helix Technology Corporation
and Director of Advanced Media Group, Ltd.
1857 Colonial Village Lane
Lancaster, PA 17601.

Computer Scientist
National Institute of Standards and Technology
Technology Building, Room A-216
Gaithersburg, MD 20899
Phone: (301) 975-3193
Email: john@ssi.ncsl.nist.gov

Phone: (800) 525-6575


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 be
encountered in using UNIX tar-formatted files as a medium of data submission for CD-ROM
production and some of the issues confronting the next generation of CD-ROM publishers.

UNIX is a trademark of American Telephone and Telegraph, Inc. (AT&T).

Disclaimer: Certain 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 are necessarily the best available for
the purpose.

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D R A F T -- N O T F O R P U B L I C A T I O N
3

Databases developed on non-DOS-based systems which have performance requirements that


exceed MS-DOS capabilities are becoming more commonplace. Ironically, the existing CD-ROM
production infrastructure has been created and supported primarily by DOS-based systems.
Although we are making progress in publishing data on other platforms, a large majority of the CDROMs published today are still designed on DOS machines for use on DOS machines. The current
tendency to link CD-ROM with DOS is making difficult the implementation of CD-ROM
technology on non-DOS systems and, therefore, slowing its widespread acceptance.

DOS is a trademark of the International Business Machines Corporation (IBM) and MS-DOS is a trademark of the
Microsoft Corporation.

2
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D R A F T -- N O T F O R P U B L I C A T I O N
The ensuing paragraphs illustrate the need for the CD-ROM industry become more in tune with the
trends which are shaping information technologies. CD-ROM, which is one such information
technology, is beginning to recruit a new breed of both users and publishers, which are hoping that
CD-ROM will adapt to them, as opposed to them having to adapt to it. The Automated Speech
Recognition Group of the National Institute of Standards and Technology (NIST) is one such CDROM publisher.

The NIST Automated Speech Recognition Group


Sponsored in part by the Defense Advanced Research Projects Agency Information Science and
Technology Office (DARPA-ISTO), the group designs and implements methods of performance
evaluation for spoken language systems. These systems consist of natural language understanding
as well as speech recognition components. Additionally, it distributes databases, or corpora, of
speech recordings as standard reference material for the development and evaluation of these
systems.
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 kHz., 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 archival/lending 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 or more 6250 bpi. half-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 or by rogue tape drives.

NIST and CD-ROM


By early 1988, the NIST Automated Speech Recognition Group had begun investigating optical
disk storage technologies as a means of replacing its tape archives. Initially, Write-Once ReadMany (WORM) technology was considered for use as a universal distribution medium but was
found to lack adequate standardization. Fortunately, in the Spring of 1988, the ISO-9660 file

3
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D R A F T -- N O T F O R P U B L I C A T I O N
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 "TIMIT"
Acoustic-Phonetic Continuous Speech Corpus. Under DARPA sponsorship, TIMIT was jointly
designed, recorded, transcribed, and archived by Texas Instruments (TI) , the Massachusetts
Institute of Technology (MIT), SRI International, and the National Bureau of Standards (now
NIST). The TIMIT corpus was designed to provide speech data for the acquisition of acousticphonetic 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 time-aligned phonetic transcriptions.
NIST felt that TIMIT's unique structure would be of great interest to speech researchers and,
therefore, would probably be ideal for widespread publication on CD-ROM. NIST decided to
publish two-thirds of the corpus on a "prototype" CD-ROM.
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 "visually navigable."
To date, more than 200 "TIMIT Prototype" discs have been distributed to universities and speech
research laboratories worldwide. The discs were well received by the speech research community
4
5
and have been read on PC's, Macintoshes , various UNIX systems, NeXT machines and
6
MicroVAXes . The "experiment" had proved to be 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 more extensive documentation and software
utilities.
After the production of the TIMIT prototype disc, NIST recognized the need to distribute speech
4

Macintosh is a trademark of Apple Computer, Inc.

NeXT is a trademark of NeXT, Inc.

MicroVAX is a trademark of the Digital Equipment Corporation (DEC).

4
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D R A F T -- N O T F O R P U B L I C A T I O N
corpora in a consistent format. Unfortunately, no standard file format existed for storing and
exchanging speech signals. Compounding this problem, almost every speech research laboratory
around the world used different hardware and software configurations for speech signal processing
and analysis.

A UNIX-Based CD-ROM Preparation Workstation


In order to implement a full scale CD-ROM production effort, the Automated Speech Recognition
Group built a UNIX-based CD-ROM publishing workstation, which also doubles as a generalpurpose speech research system. CD-ROM images are prepared on a Sun Microsystems server
system with 32 megabytes of main memory, 3 gigabytes of high-speed magnetic disc storage, a 9track tape drive, an 8mm tape drive, and of course a CD-ROM drive. The workstation contains two
1.2 gigabyte magnetic disc drives on which entire CD-ROM images can be assembled and
simulated.
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, object-oriented header
structure was developed for the exchange of speech files, especially on CD-ROM. 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 all speech data in this more consistent format.

A Data Submission Problem


All of the key components for efficient CD-ROM production were in place at NIST, except for a
vehicle for data submission. When NIST initially delved into the world of CD-ROM production, it
was dismayed to learn that most CD-ROM replication facilities accepted only standard ANSIlabeled or ISO-9660 imaged tapes as transfer media. The small Automated Speech Recognition
Group could not justify the expense of purchasing a special-purpose premastering workstation

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dedicated to creating ISO-9660 tapes. Neither could NIST provide standard ANSI-labelled tapes
because the simple structure of ANSI-formatted files would not preserve the extensive directory
structure required by the many files typically contained in speech corpora.

The UNIX tar Answer?


The tar-formatted tape is the standard medium of data exchange in the UNIX world and NIST had
been successfully distributing speech corpora on "tar tapes" for several years.
The UNIX tar (Tape Archive) utility was designed to create a portable archive format for UNIX
files. The tar program generates a single file (usually on magnetic tape) which contains all of the
information necessary for reconstituting directories, files, and UNIX-specific file parameters. What
distinguishes the tar utility from most other archive programs is that the archive format it creates is
portable across machines and operating systems. The key to the tar format's portability is in its
simplicity. Tar does not employ any elaborate compression algorithms when generating an archive.
It simply creates a byte-for-byte copy of each file to be archived with a prepended header block.
The header block contains the path and name of the file (or directory), the file size, the time of last
7
modification, and UNIX ownership and permission flags.
Because the information in the each header block as well as the file itself is byte-encoded, the tar
file can be read by any system which can recognize a stream of bytes. Of course, binary executable
files are system-specific and cannot usually be implemented on differing systems. But text, source
code, and binary data files can be easily exchanged.
8

To date, 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 preserves directory hierarchy, and because a tar file can be
written to a standard ANSI-labelled tape or any other storage medium, NIST concluded that tarformatted ANSI tapes would be the ideal vehicle for providing a CD-ROM-ready file image to a
replication plant.
Unfortunately, NIST has found that most replication plants either refuse to accept tar-formatted
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. 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
7

Sun Microsystems, Inc., "TAR(5)", Unix Interface Reference Manual (Release 3.0), Section 5 File Formats, pp. 429-430., January 1983.
8

VMS is a trademark of the Digital Equipment Corporation (DEC).

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reality, it has rarely been straightforward to implement.

Pitfalls in Extracting a CD-ROM Image from a UNIX tar File


The challenges encountered in producing a CD-ROM from a 630-megabyte tar tape, which contains
over 25,000 files, can at first seem insurmountable . Several problems have occurred during
production, some of which are still not completely resolved. Downloading and extracting a CDROM image from a tar file can be excruciatingly slow, taking 15 or more machine hours of time for
a single disc image. If a tar file is packed with thousands of files, unforseen complications can arise
in the extraction process, and diagnosing and troubleshooting all of the subsystems involved can
become painful for even the most experienced of engineers and technicians.
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 worth the
effort, and is within one's control. Many of the other pitfalls are not as easy to anticipate or avoid.
One of the more frustrating problems encountered while downloading the TIMIT tar file was that of
the overhead created while extracting the 18,900 small transcription files. To illustrate this point,

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during the downloading of the 632-megabyte tar file, containing the 25,241 TIMIT files, the process
aborted on 650-, 850-, and 1200-megabyte partitions due to insufficient disc space!
On UNIX systems, the size of file blocks (similar to the ISO-9660 and DOS sector structures) can
be modified. Although the ISO-9660 standard supports different sector sizes, the individual
operating systems used in the premastering process may present problems. For example, MS-DOS
3.31 does not allow any modifications to sector size. Fortunately, MS-DOS 4.0 is more forgiving.
The TIMIT tar file contained 18,900 transcription files of under 2Kb each. A premastering system
running DOS 3.31 with a 16Kb sector size would require over 300 megabytes of disk storage for
these files which actually amount to less than 32 megabytes of data. This results in disk overhead
of 1 order of magnitude!
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. To
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 be 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 Real "Tar Pit" -- Universal Operability


The real problem facing the CD-ROM industry concerning the production of non-DOS-based discs
lies not in which utilities or platforms to use, but within the deeper abyss of universal operability.
Universal operability encompasses the common methodology of transferring, publishing, and
retrieving many different types of data across different platforms, while using different hardware
9
and software systems.
Attempting to extract a tar file into a DOS-based premastering system is a perfect example of why
9

Brown, T., "Universal Operability: The Technical Challenge", Disc Magazine, pp. 30-34, October 1990.

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universal operability is the next technical challenge for the CD-ROM industry at large. If this issue
is continued to be ignored, entire market segments will be left paralyzed because of the inability to
publish information from beginning to end without experiencing compatibility problems. This
bleak scenario could result in the CD-ROM industry losing the acceptance and respect it has
worked hard to gain.

The Challenge Ahead


This article has illustrated some of the potential problems which can result when using the UNIX
tar format as a data submission medium for CD-ROM replication. More importantly, it has shown
that a much greater variety of CD-ROM applications could blossom if the CD-ROM industry
embraces a diversification of CD-ROM platforms.
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
10
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-ROM has 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 exchange that it was intended to be.

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
10

Helgerson, L. W., "Universal Operability: The Technical Solution",

Disc Magazine, pp. 36-39, October

1990.

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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.

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January 9, 1991
James Tritch
High Industries
Greenfield Corporate Center
1833 William Penn Way
Lancaster, PA 17601
Dear Mr. Tritch:
We represent a (type of company) that is interested in pursuing the CD
technologies business. We understand that High Industries owns and operates
such a company, specifically American Helix.
Stan Caterbone has been advising us in these technologies and has indicated
that there may be opportunities for investment or purchase in your American
Helix company and the CD-ROM technologies.
This letter is a simple letter of interest in efforts to move toward discussions
pertaining to the above.
If you have any interests in continuing these discussions, we would like the
opportunity to meet and visit your facility.
You may respond by calling or writing:

(name)
(address)
(phone), (fax)

Respectfully,

(name)
cc: David D. Dering, President American Helix
Allon Lefever, High Industries
S. Dale High, President, High Industries
Stan J. Caterbone, Director, Advanced Media Group, Ltd.,

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THE BUSINESS

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SURVEY^

FaR

mum CONTRACTORS,
INC.

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AMERICAN MANAGEMENT
05.04.2007
SERVICES, 1NC.

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ADVANCED MEDIA GROUP, Ltd.


MANAGEMENT CONSULTING PERFORMANCE ANALYSIS

PROJECT:
PARAMETERS:

Rescue Pflumm Contractors From Near Bankruptcy


4 Year Tenure 1994 to 1998

INDICATORS

BEFORE
Advanced Media Group
(4 Yr. Period)

AFTER
Advanced Media Group
(4 Yr. Period)

Highest Annual Sales:

$2,954,184

$4,289,667

Sales Volume:

$10,785,000

$13,931,288

Sales Volume Increase:

+ $3,186,288

Highest Annual Profit:

$ 106,156

$206,735

Net Profits:

$ 24,998

$ 451,706

Gross Profit Margin:

23%

30%

Corporate Equity Position:

$ 11,308

$692,125

Dun & Bradstreet Rating:


Surety Bonding Capacity:

CB3 - BB3
Poor
$1,500,000

BB1 - BA3
Strong Assessment
$3,000,00+

PennDot Prequalification:

$1,000,000

$2,875,000

Banking Status:

WatchDog List

Credit Worthy

Employee Benefits:

Section 125
Disability Income Insurance

Dental Benefits

401K Plan
Uniforms for all employees

Goodwill:

Company Logo
Computer & MIS Systems
Professionalism

Strategic Planning:

New Identity
Public Markets
Restore Good Credit
Restore Bond Rating

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Date Filed: 11/18/2015

Diary of Mental Duress


Pflumm Contractors, Inc.,
I started to log incidents of mental duress in December of 1997 after the incidents
became consistent and demonstrated not be random acts of mere occurrences. This
behavior and malicious treatment was an extreme divergence from the previous 45
months of my tenure and a polarization of my relationships with all employees involved,
including Mr. David Pflumm.
Ms. Susan Bare (Office Manager, Reporting Directly To Me)
In December, her attitude became especially hostile toward me, upon many occasions
challenging my computer knowledge when in fact she has limited experience. She had
continued to persist in wanting to change procedures, which I had repeatedly told her that
systems are reviewed at the end of the fiscal year, and any necessary changes would only
be made during the off-season, as in previous years. She had continued to challenge my
authority, which was out-of -character, and not consistent with her job description. She
had often become upset and snippy when I would not go out and get her lunch, which
was not in my job description.
Mr. James Leonards, (Asphalt Paving Supervisor)
In the week preceding Christmas vacation, Mr. Leonards had requested that I submit a
form to Wholsen Contractors, which was incidental to any contracts. The form requested
banking accounts, which I had refused to answer. I would not release the corporate
confidential banking information to a General Contractor of whom we were at credit risk
for collecting payments for services rendered, not the other way around. Mr. Leonards
continued to harass me about the document, and kept waiving the document in front of
my face. He continued, and I told him to have Wholsen call me. I had counted five
incidents regarding this document, which I never submitted. This information was
immaterial to any negotiations with Wholsen, and was intended only as a means of
mental duress.
Mr. Leonards had shown interest in learning estimating software on the computer. He
persistently requested the opportunity, and I had suggested that he evaluate competing
software before any final decisions were made. He had on his own, obtained a
demonstration of software, which he evaluated. It was not what we required, and before
Christmas, I had procured another demonstration disc for his evaluation. He promised to
evaluate that software over the Christmas vacation. Mr. Leonards kept giving me
excuses, and was never evaluated., merely to inflict mental duress.
On many occasions Mr. Leonards insisted on challenging my computer knowledge with
incidental technical questions, knowing that I was becoming annoyed. Mr. Leonards
only began working on a computer at home, within the past several months.
On January 15th, I went out to start my car, and Mr. Leonards and Mr. Ralph Carruthers
from the lobby door, made gestures at me thinking that I was leaving, when in fact I was
1
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Date Filed: 11/18/2015
merely warming up my car. When I returned to the lobby, Mr. Leonards and Mr.
Carruthers had disappeared.
On or about February 24th, upon logging into my AOL account, a Buddy List message
from Mr. James Leonards appeared on my computer screen that said Stan is that you?.
The only way that I am able to receive Buddy List messages is to sign up for the
service, of which I had never done, which means that Mr. Leonards must have illegally
accessed my account and signed my account up for the service. The evening before, a
neighbor saw me looking for my cats with a spot light, and yelled Stan is that you?.
This is certainly a clear example of mental duress, among other electronic privacy
violations.
Mr. John Brown, (Truck Driver)
On January 9th, Mr. John Brown was receiving his pay check and made the following
remark Stan, why didnt you go to Cancun with Dave, you look like one of those
Mexicans.
LN Dockey (Office Assistant, part-time)
Consistently called my car phone upon leaving the office to ask where I was going, and
when I was coming back, which was none of her business. She reported to me, I did not
report to her. She knew that this annoyed me, and was out-of-character and inconsistent
with prior behavior.
Mr. Brian Langsett (Subcontractor)
Mr. Brian Langsett continued to make calls to my home, and during the week of February
20th, screamed and yelled into my voice mail, which resulted in my changing my line to a
private phone line. Mr. Langsett consistently left messages on my voice mail, knowing
that I was not going to answer them back.
Mr. Ralph Carruthers (General Manager)
On January 22nd, Mr. Ralph Carruthers entered my office and requested that I redo a pay
application for the Lancaster Township Park Avenue project that I had done. I informed
him that I had nothing to do with that pay application because I was on vacation. He
stormed out of my office, mad that I wouldnt redo the pay application and telling me
that I had done it. Immediately following his departure, Mr. David Pflumm stormed into
my office and got inches away from my face and said Do you and Ralph have a
problem, what is your problem? I nervously and quite upset said, Dave, I didnt
prepare that pay application, I was on vacation. Mr. Pflumm replied, Yes you did. I
immediately said, Dave, mental duress is a serious matter, you dont mess with
someones mind, like that you just dont play with someones mind like this., I was on
vacation Mr. Pflumm went on to say that I did do the pay application. I asked him Do
you have a problem with me?. He replied no.

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Date Filed: 11/18/2015
I later went to the file and retrieved the original pay application for Lancaster Townships
Park Avenue. It was prepared by Mr. David Pflumm with his handwriting. I later
showed it to him and he said nothing. THIS IS MENTAL DURESS.

Mr. David Pflumm (President, Owner, Best Friend)


See Above.
In August of 1997, I was responsible for the formulation, presentation, and collection of a
Change Order for the removal of rock at the Cecil County Community College, which we
subcontracted the work from e.e. Murray Construction Company. We had negotiated a
unit price per cubic yard of rock removed, and we were required to document the
measurements which accounted for a billing of some $275,000 to e.e. Murray.
I had spent several hundred hours on the project, most of which I had done at my office
at home. Through November, it became apparent that the e.e. Murray was trying to pass
on their own problems and mistakes with their contract with the College to us, in an
effort to relieve themselves of the $275,000 contractual liability they had with Pflumm
Contractors, Inc., This process was an enormous burden, given the impact the loss would
have to our financial, and especially considering that e.e. Murray had no legal loophole to
avoid payment to us, irregardless of any dispute they had with the college. I had proven
this through thorough documentation and the specifics of our contractual arrangements.
My policy and the policy of Pflumm Contractors, Inc., up to this point had always been to
take legal action after all other efforts for collections and contract disputes have failed. I
had demonstrated an outstanding performance in reducing the amount of bad receivables,
which had almost caused the company into bankruptcy prior to my affiliation. More Mr.
David Pflumm had always demonstrated a hard line stance in all collection matters, even
to the extreme of causing the dismissal of his own employee for failing to reimburse the
company for a $700 repair bill. Mr. David Pflumm was not known for his fairness or
good faith negotiating. His tendency was to inflate production figures, and was lack in
leniency to anyone that owed him money. This was clearly demonstrated in past
contractual disputes with the Hershey Library, Dutch Family Inn, Consolicated
Construction, and various other small accounts. His policy was consistent no matter
what the amount of the payable. Mr. Pflumm was quick to take legal action in all
disputes as soon as negotiations proved fruitless.
As early as late October I had advised Mr. Pflumm that we were exhausting our efforts
for collection of the $275,000 and that e.e. Murray was not negotiating in good faith and
was in my opinion engaging in fraudulent tactics. This transaction was of even greater
importance than any other bad receivable due to the fact that a majority of the funds at
risk were pure profits. As early as November, it was the advise of our corporate attorney,
Mr. Matt Ssamley of Xakellis, Reeese and Pugh, that a civil law suit should be
immediately filed. I had Mr. Matt Samley detail all of the legal parameters of his legal
opinion supporting his contentions.

3
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Date Filed: 11/18/2015
In November, I had informed Mr. David Pflumm that I personally removed myself form
the dispute on the grounds that e.e. Murray Construction Company was not acting in
good faith, I had exhausted all available resources and means of collecting the monies
without a civil law suit being filed, and Mr. David Pflumm refused to take legal action.
By my departure on February 20th, all efforts for collecting the $275,000 proved fruitless,
and Mr. David Pflumm continued his procrastination of filing a civil lawsuit.
I am of the firm belief that the many of the negotiations and situations surrounding the
collection of payments from e.e. Murray was strategically used as ploy to inflict mental
duress for the following reasons:
1. I had exhausted most of my time during September, October, and November
while also managing my regular duties, and had requested a fee for the
collection of funds that was well beyond the scope of my duties.
2. e.e. Murray Construction Company had no legal foundation for not paying
Pflumm Contractors, Inc., irregardless of whether e.e. Murray collected
the funds from the Cecil County Community College.
3. e.e Murray had collected enough funds from Cecil County Community
College in January, and still refused any payment to Pflumm Contractors,
Inc.,
4. Mr. David Pflumm had exhibited and demonstrated an extreme sense of
leniency toward filing a civil lawsuit that was unprecedented during my
tenure and in the history of the company.
5. Over half of the $275,000 was cash for the company.
6. I allege that during the month of February, communications were used to
deceive the true nature of the situation.
7. Mr. Pflumm had always taken my advice on such matters during my tenure.
8. Lastly, the only reasonable explanation for not filing a civil complaint is that
the situation was not being truly disclosed by Mr. David Pflumm and e.e.
Murray and that a lawsuit would become public record and have adverse and
irrevocable damages to e.e. Murray Construction Company.

In late January Mr. David Pflumm laid an large envelope addressed to his home on my
desk. Inside was a letter addressed to me from AirWays Charter Service, including a
brochure depicting a plane, identical to that which was illegally repossessed from me in
1987. This was clearly a demonstrated tactic for mental duress. In the history of my
tenure, we have never discussed or had any remote need for such a service, and more
importantly, the package was addressed to Mr. David Pflumms home.
On week of February 20th, Mr. David Pflumm had provided me with documentation that
required my signature from Town & Country Leasing for my automobile that that had I
signed would have given the leasing company the right to repossess the automobile at any
given time while providing me with no legal recourse to prevent such repossession. Mr.
Pflumm had agreed to personally guarantee the payments for the automobile for the
duration of the lease, under any and all circumstances. He has breached his agreement.

4
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Wednesday, November 18, 2015

Case: 15-3400 Document: 003112132545 Page: 160


Date Filed: 11/18/2015
During the weeks preceding my departure, in the course of my travels, I had passed many
employees on many different occasions during the course of the day. On every occasion,
not one employee would acknowledge me with a gesture or waive.
During my tenure at Pflumm Contractors, Inc., not only did I resurrect the company from
near bankruptcy, and restore the company to the best financial condition it has ever
experienced, even as important was the management policies that I had implemented that
had for the first time given the employees fair and equitable place of employment. And
their gratitude was often displayed and demonstrated toward me. The behavior of the
company, as a whole, was drastically out of character and malicious, which had resulted
in a hostile environment directly threatening my mental welfare. There is not a reason in
the world where I should have been so maliciously treated. The pain and suffering was
so great, that I specifically sought the advice and help of Fr. Edward Lavelle on January
14th, in the Office of the Bishiop.
Any further detail to this document would greatly compromise my rights for any future
litigation which may or may not transpire.
I Attest,

Stanley J. Caterbone

5
Third Circuit 15-3400

Page 159 of 806

Wednesday, November 18, 2015

Case: 15-3400

JAN

FEB

MAR

Document: 003112132545
budget
APR

MAY

JUN

JUL

Page: 161

AUG

Date Filed: 11/18/2015

SEP

OCT

NOV

DEC

JAN-02

BIG TICKETS

1101
$2,202

882
$1,764

1241
$2,482

310
9
0
254
9
279
78
261
343
177
1720
$3,440

Mike

357
$268

262
$197

262
$197

340
$255

340
$255

350
$263

350
$263

350
$263

Mike
Greg Prokott
Bill Gahagan
Anne-Marie Fearnow
Ric Anthony
Kevin Ramsier
Scott Napier
Dixie Thornton
Mark Schon
Jim Cushman
TOTALS
Total Email Revenues
$50,041

2429
1170
1001
1956
1886
1494
0

1986
585
797
2918
1010
1504
1656

1980
585
1372
1486
1126
1504
1657
1717
250
11677
$2,102
$4,780

2004
615
1892
1546
1312
1524
1520
1712
984
882
13991
$2,518
$4,173

2675
617
2365
1542
2066
1905
1900
2140
1230
882
17322
$3,118
$4,736

2140
617
1892
1542
1410
1524
1520
1844
984
1323
14796
$2,663
$4,628

900
986
736
1308
1134
640
600
780
406
710
8200
$1,476
$2,082

2250
493
1840
1962
1134
1600
1500
1950
1015
882
14626
$2,633
$3,809

2250
493
1840
1962
1701
1600
1500
1950
1015
882
15193
$2,735
$3,781

960
1530
1170

10456
$1,882
$3,843

1995
615
1906
1516
1277
1436
1530
1716
992
1325
14921
$2,686
$5,363

960
900
1170

9936
$1,788
$4,258

2475
589
2430
2229
1178
1880
1935
2123
1250
0
17001
$3,060
$6,755

882
7963
$1,433
$1,833

1332
8267
$1,488
$1,882

$1,747
$413
$250
$940
$526
$845
$0

$1,165
$192
$443
$935
$301
$635
$470
$0

$5,095

$4,441

$1,294
$182
$343
$821
$340
$625
$436
$697
$389
$5,549

$1,491
$165
$608
$909
$313
$896
$504
$904
$911
$7,286

$1,298
$154
$477
$687
$351
$668
$469
$425
$641
$5,582

$1,262
$154
$473
$580
$354
$608
$290
$434
$301
$4,693

$1,331
$154
$591
$550
$543
$535
$342
$481
$579
$5,337

$1,277
$154
$473
$556
$371
$440
$364
$446
$533
$4,902

$162
$247
$184
$479
$284
$115
$108
$230
$345
$2,257

$821
$123
$460
$353
$296
$378
$270
$639
$553
$4,093

$747
$123
$460
$353
$443
$346
$270
$591
$571
$4,082

$564
$123
$276
$118
$0
$173
$162
$371
$0
$1,854

$466
$123
$368
$0
$0
$173
$275
$375
$0
$1,847

Mike
Greg Prokott
Bill Gahagan
Anne-Marie Fearnow
Ric Anthony
Kevin Ramsier
Scott Napier
Dixie Thornton
Mark Schon
Jim Cushman
TOTALS
Total BT Revenues

432
60
0
294
27
288
0

240
23
122
205
24
182
86

305
18
0
277
29
177
69
194
172

257
0
0
207
16
205
97
58
231
140
1211
$2,422

232
0
0
151
13
167
8
63
62
0
696
$1,392

206
0
0
136
13
96
0
48
179
0
678
$1,356

227

139
9
83
45
57
178
113
851
$1,702

208

171

120

115

6
45

9
29

45
136

144
185

120
194

80

82

303
$606

588
$1,176

523
$1,046

200
$400

197
$394

1800
493
1104
654

1310
493
1472

122

FAXES

EMAIL

TOTAL UNITS
Mike
Greg Prokott
Bill Gahagan
Anne-Marie Fearnow
Rick Anthony
Kevin Ramsier
Scott Napier
Dixie Thornton
Mark Schon
TOTALS

Third Circuit 15-3400

PagePage
160 of
1 806

Wednesday, November 18, 2015

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 162

Date Filed: 11/18/2015

STATEMENT IN ACCOUNT WITH

DOMINICK INVESTOR SERVICES

CTSY IYDIVIbUlrLS SECUPITIES LTI


@'NORTH QUEFN S T
bbnc4sTER
P A 175i

CORPORATION

W BROADSmEET.NM YOllU. N.Y. 1


II2.W.IDO

CUSTOMER ACCOUNT NO.

ACCOUNT EXECUTIVE

280 1QeOO3 452

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
*mOlWTEIIEm

ENDING

Tw4aR.

DtSCRIPTION

m a OR e m v

.ML

IMEREST :REBITE0 "0 YOUR Al:COUNT. I N 1 9 8 3 , WAS- r k i i i b l

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
~ 9F9O
8~~~

* *
12-3 0-83

utxvxr

FOR THIS

PER~OD

**

rnr
tLUV5t
'ROll 1 1 / 3 0 TO 1 2 / 2 9
:.2129BAL
SWiBlCR
(LVS 8ALi
SBbi6lCR

*
1000

**

POSITIONS

:WTERYlTfOWAL SISNAL
i CONTROL GROUP PLC
I;EIJSQR~~ATTC'COA LTQ

400

I R t PRICE

PORTFOLIO V4tUES

***

1
WCF

*.

16ot.60

4.019

r
I

EE REVERSE SIDE FOR IMPORTANT INFORMATION

Third Circuit 15-3400


Property of Advance Media Group

Page 161 of 806


Page 2107 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 163

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

High Assaiates LTD.


1861 W i l l i a m Perm Way
Lamaster, PA 17601
Attn: Paul Lewis

Deat Mr. Lewis:

i
k

i
%

I have beenrefarred to ynu fran EdwaxdGordcnof the HorstC;rollp. I am


ccnsiderirq making a career change into the real estate devalopnent i d u s t r y
an3 I warld U k a to have yaur -t
amsmtims. I have almys
ctmsiderd the real estate inQstry exciting an3 chllengirrg, especially
after beomdng mpe faniliar with it through limited ips MB tax
shelters.Wofthereasa~~farthecareer-inUghtofaverygmd
home, is the lack of enthudam and hspiraion that I gat frun vatching
tax retmm an3 financial s t a w t s cbange withait s6eitig any material
evi.dm=eof pmgmss, md-t as a newly developed tact of land, or a
rehabilitated darntom building or mall. I do not fear or krdc any
~ t a d b q o f t h e a n a l y t i c a l a s p e c t s o f b u s i n w s , ~ t h e y t e n a tbe
o
mare stjnulating and meanirrgN ipn applied to material prochjcts ar

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 .

~~

resune and @xmemmber wtrre I may he reached. 1f


I wculd appeciate the. d m ~ to
~ =met
you have any msihle -ties
with YOU. 1 -iate
your time and csnsideratM, and wish ycu the best
in your future ventures.
Ehlosed you will find my

--

Stanley J. C a t e r k e
4)

P.S. This inquiry is in strictest


confidence.
Page 162 of 806

Third Circuit 15-3400

Property of Advance Media Group

Page 2108 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

r
,

'

Document: 003112132545

Page: 164

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

55 Butler Ave.
Lancaster, PA 17601
(717) 299-5958

M r . Larry Zielinski, V i c e President


Ommmealth Naticmal Bank
28
Square
Lancaster, PA 17603
1

Dear Mr. Z i e l i n s k i :
As per

our conversation this past mxuntng, enclosed you will find my


resune. One of the main ream^^ for my decision to make a career cfirrnge is

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

for y a m time and m i d e r a t i o n .

Third Circuit 15-3400


Property of Advance Media Group

Page 163 of 806


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 165

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Iwouldliketo thankycu forycurtimaandaonsideraticnregardingthe


positicn that is currently vacant in the crganization. I sense that (ken
Kugal m i a t e s is a very dynanic and exciting cqmizaticn that is lrnving
and graring very rapidly. The positim that you are trying to f i l l would be
a very challenging and interesting project. I feel very amfident that I
carld be very effective and h
e
l
w to ycur m z a t i c n in beirrg
regpanswe for the equity ne.ds for your p?mjecb. I would bc int%rested
in prtsuFng ax e i a t i a n s for the pos5ticn. lhere are a few queetians
that I have, ha*ever until ycu and ycur assodates +each a Badsian, I w i l l
wait to hear fran ycu. I would ilks to review th-,
andwill
leturn it to you in the very near future.
Please eend my thanks to Ed and Owen for thier ansidemticns.
Again, thanks, and I look faa*wrd to w i b l y WXking with yrxl in the

future.

-t

Regards,

Third Circuit 15-3400


Property of Advance Media Group

Page 164 of 806


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10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 166

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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
Circuit
15-3400
nner or Third
we will
refund
any and all fees. W;
Property
of
Advance
Media
ntain that our services will
notGroup
only benefit the

,
\..

--\.

1755 Oregon Pike


Lancaster, PA 17601
165 of 806
(717)Page
299-5958
Page 2111 of 2953

"Dedicated to Performance"
/'

,,

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 167

Date Filed: 11/18/2015

OUR SERVICES
*

Pro Financial Group, LTD., is a highly


phisticated network of various professional ad;ors needed to perform financial advisory ser:es specifically for the professional athlete. The
twork consists o f several attorneys, accounnts, a Financial Planning Consulting Firm, a
zgistered Investment Advisor, a Broker Dealer
pport organization for some of the most compe11 Financial Planners in every state, and a group
investment advisors.

*
*
*

Estate Investments.

: ,

,. .
,

,:

, ,

:.

.
8

. .
..
. . .*:..

. -

..
'

Dore Valnvanw. ESQ.: Representing the h w Firm


of Shirk. Relst, Wagenseller, & Shirk,
Legal Counsel for Estate Planning.

Our purpose is to provide Financial Advisory


rvices to professional athletes and support ser:es to other contract advisors that d o not have
:necessary resources to provide sound financial
vice. We wish to work right along with your
ntract negoliations to ensure the best financial
ckage given the athlete's individual situation.
e d o not wish to get involved in the actual
gotiations; howcver, we d o feel that it is impori t to realize the financial implications of certain
ategies in conjunction with given situations.

Flnsnclai Plsnnlng Consullane. R.I.A..


FPC is the Rcgirtcrcd lnvcslmcnl Advisor, and is
a firm that provides various financial services for individuals and small businesses.
Financial Sewices Cotporatlon, of Atlanta. Gs.,
FSC is a Broker Dealer and support organization
for Independent Financial Planning Firms in all 50
states. They have a very large and sophisticated due
diligence department for life insurance products, investments and tax shelters. They also provide a network of some of the nations most competent Independent Financial Planning Firms that will be
available for your use.
Stanley 1. Caterbone. Certified Contracl Advisor,
NFLPA,
Responsible for all coordination of services and
President of S.J. Caterbone Associates, an indcpcndent Financial Planning firm catering to upper income individuals and small businesses.
Carl J. Frederick, M.E.D..
Strength Coordinator.

Third Circuit 15-3400


Property of Advance Media Group

Tax Planning

* Cash Management

Page 166 of 806


Page 2112 of 2953

'
'

*
*
*

Individual Portfolio Management


Due Diligence Services for Tax Shelters and
Insurance Contracts
Third Party Negotiations for Deferred
Compensation Packages
Retirement Planning
Business Planning and Negotiations in
Mergers and Acquisitions
Real Estate Investment & Feasability Analysis
Estate Planning
Contract Advisory Services
Third Party Representation for Professional,
Business and Labor Contracts

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
support18,
system
Wednesday,
November
2015 to
other contract advisors.
10/19/2006

mdt eral

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

......

>+

SAVINGS- --'&
~

~~

PAY
TO T H E
ORDER

OF

Document: 003112132545

Page: 168

.. .
. . ..

BANK

'

002530
Date Filed: 11/18/2015
JIM '12 86
8-1
4:
Section 3189 Federal False Claim Act

DATE

TIMOTHY LANZA, ATTY.


AND STANLEY J. CATERBONE
AND MICHAEL T. CATERBONE

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

PARENT FEDERAL SAVINGS BANK


DATE

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

6/12/86

DESCRIPTION

LOAN 0 0 1 0 0 7 8 9

AMOUNT

100,000.0(

CATERBONE S.

DEBIT 1 0 1 0 - 0 1 FIRST CONVL MORTGAGE LOAN

Third Circuit 15-3400


Property of Advance Media Group

Page 167 of 806


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Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 169

Page 168 of 806


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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court
The Eastern represented
District of Pennsylvana
TheForshares

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Federal
False Claim Act
by this certificate have Section
not 3189
been
registered
Page: 170
Date Filed: 11/18/2015

Document: 003112132545

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Case: 15-3400

Document: 003112132545

Page: 171

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

CYWTER BUSINESS PlAN

FDR

JULY 1. 1986

Third Circuit 15-3400


Property of Advance Media Group

LWGBER. PA -TION

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Case: 15-3400

Document: 003112132545

Page: 172

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

TABLE OF CDKTENE:

Third Circuit 15-3400


Property of Advance Media Group

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

Planner Support Services

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

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Case: 15-3400

Document: 003112132545

Page: 173

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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.

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Property of Advance Media Group

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Case: 15-3400

Document: 003112132545

Page: 174

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

market of independent financial planners

into a quality group of clutstanling professionals nezketing under one


name, thus bringing order to the financial marketplace.
3. To place client interest first a t a l l times by delivering a
diversified prcduct through multiple qxmsors so as to always deliver
high-quality and fairly priced products representing the top 25%
percentile of the matketplace.
4. Tb dwelop and maintain quality m i c e on previcllsly delivered
products by nranaging assets a t a reasoMble fee, thus freeing planners
frcaa the constant pressure of lMking new sales.

Fa insure the g-rwth of the business by hiring professional planners


in sufficient number so as to become the preeminent financial micc~npanyin the area served.

5.

6. !Ib use invcapital rather than loans and long-term leases to


minimize monthly expmses ard maximize profits, hereby assuring our
business gmwth and dwe1cpm-k.

7 . 'Ib enolxuage our planners t o beome stockholders in the finn, thus


satisfying their desire for mnazhip in a ccanpany of redl value. Also to
assure a more stable d e v e l o p a t of cur business through stronger ties
w i t h cxlr top planners.
8. To react to changes in the marketplace ahead of cur amptitim in
creative and thomqhly considered ways.

9. To maintain a strong professional/client relationship throuqh frequent


prsondl c o n t a d while using high-ted-oxrlcqy
.
.
. equipnent to enhance the
-

quality of our work.

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Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 175

Page 174 of 806


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 176

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

corporate benefit plans and the media


continues to g m as a s q n e n t of the financial services business.

Mass m.rM5.q

Dwelap wrprate sales thrmgh the concept of cafeteria plans


hhich will dvlnge the enployee benefit mrket by a l l w i g
employees to w e t a prcentage of benefit dollars to the areas of
their choice. Also, continue to en@asize seminars targeting unique
organizations hhich have a strong relationship with the pblic for
specific financial products:

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.

Additionally, we will develop plblic awarmess by constantly advertiskg


the corporate mme via nekspaper ard radio.

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

1. Current Situation

Page: 177

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

W e crurently have 14 financial plannezs and 5 other pmfessiondls


Wtted to an August campncy in cur new space on the Oregon Pike
y anwng
,
the 16 people involved, we
i n Lancaster. ~ t i ~ l fman
have selected m g e r s for w offiin ,
lewkhq,
Reading an3 Landale. Based on l a s t year's business by those
dLready irnrolved, we e x p z t to g-te
2.7 millicsl dollin

revenue, and invest 54 million dollars in 1987.

an lancaster staff to 18 financial plWe plan to


6 othes p m f e s i d s . W e we plan t o locate and devela;, in
areas, we will OYIEentrate during w first year on w
operati-.
,

2.

Cuzlwt

and

w d

Situation

A t least 80% of our staff is caprcanprised of professiumls established

in business for a t least f w years.

We will m n t h to seek predaninately self-sufficient,


professional lVeteranstl of the industry. (Xrr desire is to
agpeal to their need for the fnxdan to plan and ccumnmicate rmre
effectively with their clients. We'll also offer a higher paycut,
mre varied products, Md a mre professiondl envkment. We w i l l
duplicate d y the msst criticdl brokexage house semi-.

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Case: 15-3400

Document: 003112132545

PI-rn

Current Situation

Page: 178

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

(Continued)

-.

Planners have been stable in their relationship with past employers.

a very stable core of top planners in Lancaster, Pa., due


We
to strong nnnagement, staSle planners, strong local w
r
t systems,
an3 equity mmrship. We will m m t r a t e on local development
ahead of satellite dwelqment. We
a x satellite retention
*ere equity vmership is strong and mediocre
to be
where equity a n w d ~ pis weak.

Current Situation
are independent and thus use various p1amb-q txxhniques,
Planoffer a limited
ard differ in their areas of expertise.

~~

Zhe w i s e a d techniqaes of cau planners ard ather professionals


wjll be p l e d to provide clients with higher quality m i c e and
a broader line of products.

Third Circuit 15-3400


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Case: 15-3400

Document: 003112132545

Page: 179

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

1. current Situation

Invesbnent products are predceninately delivered t k a q h captive


prcducts and manage
sales organizatims who manufacture their
which
all mmies. 'Ihis leads to limited product offerfrequently do not entirely satisfy specific mnsumer needs. It
also leadsto a d o n e product because there is no free mket
pressure to insme top qmlity products that are axpetively
priced.

planners w i l l be free to deliver the highest quality prcducts fran


of sponsors so as to work exclusively for the
-fit
of the client. Zhe p l m my chccse top h % s t r y
pzrforuers, solid ard sizeable mopanies and a variety of ~~nichevt
products to f i l l wery client need.
mong

2.
-

Current Situation

Fee-paid financial plans vary widely i n price and quality and


deperd mmt heavily on the individual developing the plan or
inteqxeting it. With regard to oonsumer expedations, the
marketplae is in disarray.

Fee-bsd plans in advance? of prduct sales shculd beccme sinpler


due t o tax reform. Ihe mjority of ad,plans were originally
purrhased for tax planning wfiich my no longer be needed. (Xlr
eqhsis w i l l be an a business being revived by tw r e f m
Asset m g e m m t or InvMonitoring. With clients paying
their taxes ard investing for appreciation rather than seeking
shelters, this business is eqected to bocmn. We plan to have an
in-hportfolio manger and mket-tk. W e plan to charge
clients an average of .75% for the service. A s planners gain
assets under nwagement, their annual h a m e fmn this ~ x l r c e
should alleviate pressure for new clients.

--

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Case: 15-3400

Document: 003112132545

Currmt Situation

Page: 180

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Associated prufessirmals sucfi as attorneys, acamtants, bankers,


and insuranoe a d real estate agents seldcan -te
to help
clients attain their g d s . Ihe ultimate contrul of the
lusiness tends to bacome divided, m a k b q pecrple
client's
defensive ard prducing fear of e x p u r e in the event of error.
Zhis often leads to professionals dxaditing one another or
taking W e nedit for advice leading clients to inaction.

In-hmse legal and real estate professionals will eMble a p l m


to get sudr services for his client witha-t fear of losing the
It will also help omsreve revenue
client to artside .
n
i
normally spent for sucfi mi-.

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.

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Case: 15-3400

Document: 003112132545

Page: 181

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

m k e t Penetration Strateqy

1. Ekisting Clients

--

Planners an3 other professional joining

aur g-rw.xp w i l l have dwelaped deep perrcaral c l i e n t relationship

which a d d allw new investment dollto be handled by w


people. A s f o l l w systems are inp1ement.d we
65% of dl
businesstoccPnefmanthissalrce.

-presence-We plan to present fax seminars on a


joint basis with institutions mch as mlleges, wities, business
organizations and corporations. Cur semirrars include
vl,successful1 4 m Manaclemen++"- a sauptc-nuts on inva l i f e planning s e n k a , wolaritable
products, vtpalf4mew
and Retirenent Plannim S m h z ! s . CUrrently aur plarrners
regularly a p p e ~a t Millersville State CBllege, RCA, AZIXIA, St.
Jcseph's limpitdl ard e l m . W e also plan regular seminars for
the general public.
2.

--

--

'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.

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Case: 15-3400

Document: 003112132545

Page: 182

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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.

Inherent in cur e r t services w i l l be the follwing:

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.

a sample of tbank you,


referral appointrent setting, data requests, and ammnly
wd review l e t t e r s m y be selected and generated. Rzsonal
mrnsprdence w i l l
handled by our s t a f f , frea of charge.

2) m t i t i v e S t a m l a r d Bn-esmndence

3)

Business process^ ompleted applications w i l l be checked,


logged, oopied and m i l e d by aur cashiers. F o l l w p with
broker/dealer or p r d u c t qonsors w i l l be offered to premier
pIDducers only.

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

piece by piece and pmentage fee basis respectively.

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)

Suwlv S c c k i m p m z p d u s , applications, trust a-ts


and
other forzs needed to conduct kusinesS w i t h cur r&
prcduct
suppliers w i l l be maintained.

7)

Reference and Pericdicals professiondl journals an3 data


services meet* the ammn need of cur advisors w i l l be
plrchased and w i l l be mintdine3 by cur office s t a f f .
Material unique to specialized areas w i l l be provided by those
planners K+-IO work in those areas.

8)

Cornrate Marketinq we w i l l p m t e the me of our firm along


w i t h all planner a f f i l i a t e s to gain p&lic awareness in wiess
of k h a t any irdividtual alone cauld achieve. W
e w i l l become the
best h m f
in Central Pennsylvania.

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9)

Document: 003112132545

minim and Education

Page: 183

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Ro1h-g cur production will give us


additional lcut with sponsors, i r d u s t q t d m r s ard those
wishing to address cur e
p
. (bst shculd be 1ard
quality higher. It is cur plan to provide a mnstant f l u s of
information, new product profiles, ard specialized p 1 a m . h ~
techniques.

Size and strength of cur gmup should


allw us to t
Dirrcreaseconoessions made by sponsors wer m t s
m d l y negotiable by M v i d u a l s .

10) G m s Pavout Neaotiation

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--

(XTR

ST-

Page: 184

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

FQR A GREAT CCMPANY

.'

Having w e l l established busprinciples is critical to the


success of any new business. m y p e r s i m , hard vork an3
sufficient capital oan rival its impJrtance. W e feel the need to state
the basic values of this firm so that the basis for the decision-making is
well established ard urdersbx5.
A great ampmy..

...l.

Serves its

custarrers well.

m hi* principles.

3.

~EG&PS

4.

Makes

5.

taa.rds the interests of stakholders and


emplw-.

m ~ ~ l regularly.
g r

6. ~nanrsits mission.
7.

KnaJs its p i t i o n i n the nar-lace.

8.

~ e s i r e s s o l i dommmity ard corpxate


citizenship.

9.

Hires mprior people ani pays than vell.

lo. Will cha.qe carne innidst cfvlngirq tines.


11.

Has the vision to see cpprtunity.

12.

Retains- .

13.

Has a bias for action (do it, try it,


fix i t ) .

14.

Is value driven.

spirit.

15. Regards people as its greatest asset.


16. Uses a lean staff , a shple f o m management

laJest level.

17.

pus.'les d e ~ i ~ i ~ - m a k jto
n gthe

18.

W t e s deserving people, rqaxdless


of race, sex, or religion.

3We hereby resolve to W d such a t x n p n y .

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Page: 185

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

'Ihe abo\~epages have been mitted due to the legality of precedbg


in mnjunction with Federal and State Securities
the O f f e r h I~~~
Regulations. An Offerins P I e m o w w i l l be issued to a l l htere&&
parties upon registration w i t h the apprapriate authorities. 'Ihir; M c l
happen on or before August 1, 1986.

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Page: 186

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

The begining phase of n o s t businesses phase is dma~teriZdby


erratic sales trerds, fluctuating m k e t share, increashq dependence on
inproving technological systems, and possible cash flm losses. We do not
exped to face any of these pmblems because of the established nature of
the planners we are hiring. H-er,
we wauld be foolish to believe that
we scnnehm were inmme fmm such potentidl pmblems and therefore need not
to plan for these wentudlities.
(Xzr very first need a
d be to raise capital thrmgh stock plrcXases
beyonrl cur initial capitalization t
s
to the extent of at least
$loo,OOo to cover any initial shortfall in revenue or budget projections.
'Ibis wmld protect us from going the way of nwst mdercapitalized
businesses---.
m y , we e q e t to invest heavily in state-of-the-art
technological s y s k m so that we do not face ned hardware/sofbare charges
e ~ l yin cur business developwlt. Stan Catertune will devote m r h of his
mamgenent tine to this area.
h-iority will be given to rwiewiq perfoOmarm against objectives on
All abjectives will be quantifiable aid measuable, ard
as necesaq adjustments will ke made and mnitored accordbqly. Such
scrdiny of perfomaxe will allw us to oonstantly assess and respand to
any pmsible s h o ~ i r g aid
s to market needs.
a m t h l y basis.

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.

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Page: 187

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Stanley J. Catertam is axrently proprietor of S. J. Q W n e


Associates, a Financial Planning Firm specializing in but not limited to
upper inwne individuals. He is also president and founder of Pro
Financial Grarp,
, a firm prwiding financial -ices
and amtractual
negotiations to Professid Athletes an3 Agents.

Stan began his career with a financial sdxidiary of m i c a n


Express, I E Financial Services. He was hired by and worked w i t h Bob
Kauffmm for six mths before Bab was prcnmted to the Florida area. Stan
developed a practice center& around fee-p l m that fowed on
the tax aspects and conoerns of individuals while they pertained to the
clients investmenk and werall financial situation. While at ID6, Stan
was one of the leading planners in the nation to utilize fee based
plannirq at its inception. He was one of the tap producers in centtal
Rennsylvania, an3 ranked rnnnter 5 in the nation in his class. He also had
closed one of the biggest estate planning cases in the division.

f
i

In January 1985, Stan left I13S and became ird@ent


to provide a
better product line for his clients and to escape the pqxietary
s very creative and has developed a sbmq practice
environment. He i
ammg physicians.

Stan has dwelaped a variety of professid networks thmu@xut the


country with rqaxd to the various Sports Professionals that he works
with. He is currently working on a joint venture with fornrer Chief
Financial Officer and Vice President of jloubledav Fu?Aishina m,
Richard E. Madigan. He i
s lookhg to Stan to help him manage an annudl
inamne of $7 million fron the 20 Professional Athletes that he auwrtly
IMMges.

Stan has helped to develop the Central m l v a n i a Chapter of the


Internaticmal Association of Financial Planning, and had organized and
nieeting with Alexandria
attracted nwre than 100 m a t oattend a
Amstrong, one of the more pnahlnent Financial P1arvm-s in the nation, who
is cxlrrently the National President of the IMP. He is also a mPmber of
the Estate Planning Council of the Instiof Certified Financial
P l m . Stan is currently a Certified Contract Advisor of the National
Fwtbdll League Players Association an3 the NBA. Stan will be an
Exative Vice President respnsible for professional networking and
market*
and sate of the fiscal and negotiating functions.

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Page: 188

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Fbb Kauffman is wrrmtly the National Sales Manager, at large, for


FSC Seolrities (brporation. FSC is a b r o k e r M e r with a 1200 planner

sales force. It raised wer 600 million dollars of investment capital in


1986. Bob's respnsibilities include dweloping a ccanpany-amd
distribution system wi-~er&y FSC pralucts and services are delivered to the
pblic-at-large Umqh FSC Financial Service Centers. E& is also
reqmnsible for recruiting pmven financial planners thrcqhout the natior.
for Financial Senrice Corporation. He also contributes to the strategic
planning of sales for FSC m i t i e s Corporation..
Bob began his career with a financial subsidiary of the American
Wress Corporation in 1976 upon his graduation frcan Millersville S t a t e
College in Mill-ille,
Zknnsylvania. In his f a r years of direct
selling to the plblic, he became the y q e s t perscm in the a m p n y to
achieve multi-million dollar praluction status at the age of 25. Bob then
began to take on additional assxiates as he began to huild his practice
in Lancaster, PP-mqlvania. In j u s t two years, his pzlctice had gru.m to
12 representatives handling wer $12 million dollars a year in annual
investnmts and managing in ex-s
of $60 million dollars of client
mnies. W e building this operation, Bob continued to be the leading
producer in his office and the region.

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.

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Document: 003112132545

Page: 189

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

BICGFAWY OF M I ( H P S . M. HAKIZEIT. AFP

Mike Hartlett is a r r e n t l y an irdepdent financial planner and heads his


om l d firm
Financial Plannbq Bnsultants. Mike is a licensed
m i t i e s principal and fully a l i e searrities broker. He has
ccanpleted the Oertified Financial Planning program with the College for
Financial Planning and currently holds an Associate Financial Planner
designation. He w i l l m i v e the Certified Financial Planner designation
in Feb1987.

--

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.

Mike has an extensive knmledge of corporate retirement plans ard pension


prograns and has excelled in retirement planning f o r individuals. He
auxlucts financial plin several large fancaster &mty
corporations and is active in prancrting financial planning in fancaster

-'a'.
Mike currently m g e s i n excess of $14 million in c l i e n t assets.

Mike is carmLitted to deliver* the highest quality p1armis-g sewices to


his clients. He beliwes that m
r
n
l attention and sexvie are the key
t o a strong client/planner relationship.
Mike w i l l sewe as Executive Vice President of Financial Manag&
Group,
Ltd. He w i l l be in charge of operations and serve as chief financial
offi-.

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Document: 003112132545

Firrancia. Securities, Inc.

Page: 190

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

............... .?he Broker Dealer

Em Advisory, ........................

..The Registered Investment Advisor

.......The Insumme Agency


In=. .............?he Acamting Finn

Financial Savims Insurance Agemy


EM; Acmmting Sezvices,

Financial tbrtqages Services, Inc. ........?he


Wealth MaMgement Semi-,

..

..........The

Financial PlarPling &msultants, Inc. ......We

Mortgage Bmkmqe Firm

Portfolio MaMger
Financial Pla-

&

Market Timer

Finn

mmTE FmG (In Hause)


Eager Real Estate

........................Redl Estate Services

O'my ti smith .............................Legal

Counsel for Business

&

Xeal Estate

.........Legal cavrsel for Estate Planning


W e l l Associates, Inc. .................. .Property 6 Casualty Servicrs
Pro Financial harp, Inc. .................Servicc5 for Profe55ional Athletes
Shirk, Reist, Wagenseller

&

Shirk

Please note that the W e f i n s are currently wrler nqotiations and have given
ve.rhl amnnitment for affiliation.

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Date Filed: 11/18/2015


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In re:

July 31. 1986

Financial Management Group. Ltd.


Draft Offering Memorandum

Mr. Stanley J. Caterbone


255 Butler Avenue
Lancaster. PA
17601
Dear Stan:

I have now reviewed the draft Offering Memorandum for Financial


Management Group, Ltd. which I received several days ago, and my connnents
follow.
The cover page indicates that stock will be sold at two different
prices, but it should include reference to the fact that the lesser priced
shares will be offered to persons who will affiliate with one or more of the
subsidiaries. This can be done by a brief notation on the cover, together
with a cross-reference to the section in the Memorandum where is subject
will be discussed more fully. There should be a rather full discussion
somewhere in the document indicating the qualifications and requirements
pertaining to persons who desire to become affiliated, and as we discussed,
this also should be incorporated into a form of agreement or agreements
which should be attached as an exhibit. In this connection, should people
who affiliate and later terminate be required to sell their stock back to
the corporation?
than shares of
the cover page should clear1
clear on that point, and co
The Memorandum should be much more descriptive in outlining the
proposed activities of each of the subsidiaries. In that connection, I
suggest with respect to each subsidiary the following information:

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Case: 15-3400

Document: 003112132545

Page: 192

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Mr. Stanley J. Caterbone


July 31. 1986
Page 2
Reference to the fact that the subsidiary has not yet
1.
begun business, as well as the date by which it is reasonably
anticipated that some business activities will begin.
Xore detailed information on just what each subsidi2.
ary will do.

,-

.2

Likewise, where applicable, more spec1fic information


3.
as to licenses and regulatory requirements (if any) which must be
met and continually observed by the subsidiary.
A discussion identifying the directors and officers
4.
and also who will manage its business operations. If formal
arrangements have been made with specific persons, so indicate;
if the business will be operated by an employee or independent
contractor yet to be designated, give details, including the
terms of employment that are expected for any such person.

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.
,.

'?'

2'

With respect to the use of proceeds, you should consider a further


breakdovn of at least some of the components "working capital" category for
which $187,000 is allocated which is a relatively large amount. Among other

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 193

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Mr. Stanley J. Caterbone


July 31. 1986
Page 3
thoughts, you might refer to the lease obligation (and any other present or
contemplated contractual-obligations), wages for secretaries and the like.
and professional expenses (e.g.. legal and accounting).
As discussed, and in relation to the use of proceeds. you will have to
with the matter of the salaries to be paid to key management personnel.
I note your disclosure that each will receive a salary not exceeding
$60,000. but that raises the possibility that virtually all of the vorking
capital could be used for that purpose. If I were a prospective investor. I
rant additional infomation, as I would be concerned about the potenof a large part of the proceeds to pay salaries. I would also ask
to what extent revenues generated by the businesses would be able to pay
part or all of the salaries. Perhaps one approach, if agreeable, would be
to disclose that not more than half (for example) of the salaries paid
during the two years would be from proceeds of the offering.
Under the "Business" discussion, you make reference to legal services
as o m k e fiel-ds of activity for the corporation. You will want to
check with legal c2mae-l wvho would be involved, but I am doubtful that under
cal standards your corporation can offer legal services.

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.

With reference to "Management", you need to identify the Board of


Directors. Also, you should indicate whether management will provide
time services, and if not, what approximate percentage of their time is
,expected to be devoted to the organization's business.

v-

'

iI
I!

The biographical summaries, in my view, should be toned down in order


to be somewhat more "matter of fact" in tone. In this section, as in the
rest of the document, you must be able to support each fact that is stated.
and some of the disclosures are a bit vague. An example is the reference to
Bob Kauffman "handling o7er $12,000,000 of investment ponies per year" and
having "an asset base of up to $60,000,000". Also, while you do indicate
the functions each of the three of you will have. I think it would be useful
to be a bit more specific.
With respect to "Certain Transactions', you must be sure to disclose
fully any arrangement or situation pnrsuant to which any director or officer will have dealings directly or indirectly with the corporation. For
example, if any
will continue to be retained by your present employer

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OW

Page 192 of 806


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JD*HDistrict
s . owrn
US District Court For The Eastern
of Pennsylvana

Section 3189 Federal False Claim


O. Act
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003112132545
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In Re:

August 7. 1986

Financial Management Group. Ltd.


Our File No: 11489-001-5

Stanley J. Caterbone. Executive


Vice-President
Financial Management Group. Ltd.
1755 Oregon Pike
Lancaster. PA 17601
Dear Stan:

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

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Stanley J. Caterbone. Executive


Vice-President
August 7. 1986
Page 2

that it is permitted to estimate these emounts, although in the supplemental


filings the estimates should be revised to reflect actual figures.
Please review this document closely. as it is my strong suggestion
that the document should be complete and ready for filing before I leave
for vacation. You will then be in a position to file the five copies
directly with the SEC as soon as the first sale has occurred. Your signature
should go at the end of the form vhere indicated, but please do not date
the form.
Sincerely.
McNEES. WALLACE 6 NURICK

WJJ: jp

Enclosures

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MCNEES. WALLACE & NURICK


ATTORNEYS AT LAW
100 PINE STREET
P. 0.BOX 1166

HARRISBURG. PA. 17108-1166


T c ~ r w o ~(717)
r 232 - ~ o O O

August 11. 1986

In Re:

Financial Uanagement Group. Ltd.


Our File No: 11489-001-5

Mr. Stanley J. Caterbone


Financial Management Group, Ltd.
1755 Oregon Pike
Lancaster. PA
17601

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.

As an initial matter, as you are aware no sales may occur until


the materials have been "cleared" by the Pennsylvania Securities
Commission. That will occur initially via a telephone call from the
Cornmission staff to our office, at which point we will advise you.
Thereafter, the staff will send a letter of confirmation. Alternatively.
as we have discussed, it may be necessary to deal with one or more staff
coments before clearance can be obtained.
At the point clearance has been obtained, you may distribute copies
of the Offering Memorandum subject to the numerical limitations of Section
203(d) and regulations thereunder. As we discussed, the Memoranda should
be numbered consecutively, and the number and name of the recipient
of each copy should be recorded in your records and written on the
upper-right hand comer of the Memorandum in the spaces provided.

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Mr. Stanley J. Caterbone


August 11. 1986
Page 2

Under ~ e A n s ~ l v a n iSae c u r i t i e s Commission regulations, you a r e required


t o keep t h i s type of record; s p e c i f i c a l l y , you must maintain a l i s t
showing ( i ) t h e name and address of each o f f e r e e , ( i i ) t h e name of t h e
person making t h e o f f e r , and ( i i i ) t h e d a t e t h e o f f e r i s made. As we
previously discussed, t h e numerical r e s t r i c t i o n s a r e t h a t a maximum of
90 o f f e r s and 35 s a l e s may be made t o Pennsylvania r e s i d e n t s i n any
t v e l v e month period.
The foregoing r e l a t e s only t o o f f e r s and s a l e s made i n Pennsylvania.
and i n t h e w e n t you intend t o make any o f f e r s o r s a l e s elsewhere. it
v i l l be necessary f o r a review t o be made of t h e applicable s t a t e "blue
skyw s e c u r i t i e s law. C e r t a i n of such s t a t e s t a t u t e s permit a small
number of o f f e r s and/or s a l e s t o be made without requiring any f i l i n g s ,
while o t h e r s t a t e s r e q u i r e f i l i n g s t o be made e i t h e r before o r a f t e r
o f f e r s o r s a l e s a r e made. I n a l l events, you should be very a l e r t t o
t h i s matter, and determine s t a t e s e c u r i t i e s law requirements before
approaching prospective i n v e s t o r s i n o t h e r j u r i s d i c t i o n s .
As f a r a s f e d e r a l s e c u r i t i e s laws a r e concerned, a s ve have discussed
i t v i l l be necessary t o f i l e Form D with t h e S e c u r i t i e s and Exchange
Commission not l a t e r than 15 days a f t e r t h e i n t i t i a l s a l e is made i n
t h e offering. We must r e l y on you t o a l e r t us vhen such i n i t i a l s a l e
has occurred, a s of course we have no independent means of knowing vhen
t h a t has occurred. Accordingly, please c a l l Mike Jarman o r me a s soon
a s t h e f i r s t s a l e a c t u a l l y occurs.

Section 203(d) of t h e Pennsylvania S e c u r i t i e s Act p r o h i b i t s "public


media advertisement" and "aIass mailing" i n connection with t h e s o l i c i t a t i o n
of investors. Similarly. SEC Regulation D, vhich i n e f f e c t provides
t h e exemption from f e d e r a l r e g i s t r a t i o n upon vhich r e l i a n c e i s being
made, p r o h i b i t s "any form of general s o l i c i t a t i o n o r general advertising".
including published o r broadcast ads o r n o t i c e s and seminars whose attendees
have been i n v i t e d by any general s o l i c i t a t i o n o r advertising.

As t h e o f f e r i n g continues, t h e o f f e r i n g materials must be updated


by supplement o r amendment t o advise i n v e s t o r s of m a t e r i a l changes
a f f e c t i n g any of t h e disclosures.
I hope t h i s general o u t l i n e v i l l be of use, and of course i f you
have any questions o r need any f u r t h e r information, please l e t us know.
Sincerely,

BY
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August 19, 1986

Mr. Joseph Lyden


Pennsylvania Securities and Exchange C m i s s i o n
333 Market Street

Harrisburg, PA

17101

Dear Mr. Lyden:

Enclosed is the edited offering memorandum for the Financial Management


Group, Ltd. Please note that we are in the process of assming the RIA
of Bravero Financial Services of Lewisburg.

If you have any further questions please call.

Sincerely,

SJC/mld
Enclosure

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LAW OFFICES

O'DAY0

SMITH

243 NORTH DUKE SIKEET

LANCASTER, PA 17602

2QO4 NORTH BROAD STREET

MICHAEL P. O ' M Y
EDWARD H. SMlTH

PHIUDELPHLh.PA IS121
1215b763-5280

17171 393-4001

T I M O M A. IAN-

005 WEST MAIN STREET

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

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I h W OFFICES

O'DAY0 SMITH
243 u o n T n DUKE STREET

LANCASTER, PA 17602

2004 NORTH BROAD STREET


MIlADELR(IA.PA 19121
I215b763.5280

,717) 393--1

eo5 VEST

MAIN m E E T

MOUNT JOI. PA 175%


lfVb653-0131

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.,

R e g i s t r y S t a t e m e n t i n t r i p l i c a t e and check i n t h e amount o f

$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

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MICHAEL P. O'DAY
EDWARD H. SMITH
Document:
003112132545
A. UNU
TIMOTHY

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

243 NORTH DUKE STREET


LANUSTER, PA 17642
3934CQ1

Page: 201

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Date Filed: 11/18/2015

805 WEST MAIN STREET

August 22, 1986

MOUNT JOY. PA 17552


U3-9131

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

- ---

~ r o f e s s i o n a ls e r v i c e s r e : F i n a n c i a l Management Group. L t d . . and


s u b s i d i a r y c o r p o r a t i o n s , including: ~ o n s u l t a t i o n sand advice;
preparation and f i l i n g of A r t i c l e s of Incorporation f o r F i n a n c i a l
Management Group, L t d . and nine s u b s i d i a r y c o r p o r a t i o n s ; prepar a t i o n and placement of l e g a l n o t i c e s .
Costs: 1 ) F i l i n g f e e s t o Corporation Bureau
nine c o r p o r a t i o n s a t $75 each '
$675 .OQ
2) Legal Notices ( s e e a t t a c h e d i n v o i c e s )
402.05
Financial
3 ) Corporation o u t f i t
76.32
Management Group, L t d .
4 ) Additional s t o c k c e r t i f i c a t e s
Finan45.76
c i a l Management Group, L t d .
T o t a l Costs
Total f e e s and c o s t s
Less c o s t s r e t a i n e r
Balance Due.

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LAW OFFICES

O'DAY 0

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

2001 NORTH BROAD STUEET


PnllADELPtllh.PA 10121
121517L1J.51BO

005 VEST MAIN STREET


Y O U M JOY. PA 17552
1717,653-9131

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 ,

O ' D A Y & SMITH

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
..

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FINANCIAL MANAGEMENT GROUP, LTD.


(a Pennsylvania Business Corporation)

TO:

Financial Management Croup, Ltd.


1755 Oregon Pike
Lancaster, Pennsylvania 17601

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

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such knowledge and experience in financial, tax and business matters as to


enable him or it to utilize the information made available in connection
with the offering of the Shares to evaluate the merits and risks of the
prospective investment and to make an informed investment decision with
respect thereto. The undersigned recognizes that the Shares as an investment involve significant risks.

(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.

(d) The undersigned understands that no federal or state agency has


made any finding or determination as to the fairness of this investment.
(e) The undersigned realizes that the Shares are being purchased by
the undersigned solely for purposes of investment for the undersigned's own
account and not for the account of any other person and not for distribution, assignment or resale to others and the undersigned represents that no
other person has a direct or indirect beneficial interest in such Shares.
(f) The undersigned realizes that he or it may not be able to sell
or dispose of the Shares as there will be no public market available. The
undersigned agrees not to sell or otherwise transfer the Shares unless they
are registered under the Act, and under any applicable securities laws, or
an exemption or exemptions from such registration are available.
(g) All information which the undersigned has provided to the
Company concerning himself or itself, his or its financial position and his
or its knowledge of financial and business matters, is correct and complete
as of the date set forth on the signature page hereof.

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PENNSYLVANIA PURCHASER STATEMENT

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- PENNSYLVANIA INVESTORS ONLY.

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.

To accomplish this withdrawal, a purchaser need only send a letter or


telegram to the Company indicating his or its intention to withdraw. Such
letter or telegram should be sent and postmarked prior to the end of the
aforementioned second business day. It is prudent to send such letter by
certified mail, return receipt requested, to insure that it was received.
If the request is made orally, a written conformation that the request has
been received should be requested.

ACCREDITED INVESTOR STATUS:

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,

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(iii) any deduction claimed for depletion under Section 611 of


the Code, and (iv) amounts contributed to an IRA or Keogh
retirement plan).

I have an individual net worth, or my spouse and I have a


combined net worth, in excess of $1,000,000. ("Net worth" means
the excess of total assets at fair market value, including home,
home furnishings and automobiles, over total liabilities.)
2.

ACCREDITED INVESTOR STATUS:

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.

A bank, as defined in Section 3(a)(2) of the Securities


Act of 1933, whether acting in an individual or a fiduciary capacity.

2.

An insurance company, as defined in Section 2(13) of the


Securities Act of 1933.

3.

An investment company registered under the Investment


Company Act of 1940.

4.

A business development company, as defined in Section


2(a)(48) of the Investment Company Act of 1940.

5.

A small business investment company licensed by the U.S.


Small Business Administration under Section 301(c) or (d)
of the Small Business Investment Act of 1958.

6.

An employee benefit plan within the meaning of Title I of


the Employee Retirement Income Security Act of 1974 and
the investment is made as a plan fiduciary, as defined in
Section 3(21) of such Act, and the entity is a bank,
insurance company or a registered investment adviser, or
has total assets in excess of $5 million.

7.

A private business development company as defined in


Section 202(a)(22) of the Investment Advisers Act of 1940.

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8.

An organization described in Section 501(c)(3) of the


Internal Revenue Code, with total assets in excess of $5
million.

9.

An entity in which all of the equity owners and accredited


investors and meet one of the criteria for individual
accredited investors listed above.

If you checked (g), please complete the following part of


this question:

10.

(a)

List all equity owners:

(b)

What is the type of entity?

(c)

Attach a copy of your resolutions or other evidence


of the entity's authority to make this investment.

(d)

Have each equity owner respond individually to the


accredited investor criteria tests listed above.

An entity which is subscribing to purchase at least


$150,000 of securities, which amount is no more than 20%
of the net worth of the entity.

This Subscription Agreement constitutes the entire agreement between


the parties hereto with respect to the subject matter hereof and may be
amended only by a writing executed by all parties hereto.
This Subscription Agreement shall be binding upon the parties hereto
and their respective heirs, legal representatives, successors and assigns
and shall be enforced, governed and construed in all respects in accordance
with the laws of the Comonwealth of Pennsylvania.
The undersigned further represents and warrants that the residence set
forth below is his true and correct residence. The undersigned understands

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and agrees t h a t t h i s subscription is made s u b j e c t t o the condition t h a t the


Company s h a l l have the r i g h t t o accept o r r e j e c t i t i n whole o r i n p a r t .

Individuals:
P r i n t o r Type Name

Signature

Date

Soc. Sec. No.

P r i n t o r Type Name

Signature

Date

Soc. Sec. No.

Residence Address
J o i n t Tenancy

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Print or Type Name

Taxpayer I.D. No.

Date

Signature

Print or Type Name and Indicate T i t l e


or Position with Entity

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ive. if

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Purchaser ~e~resentat-ivehas read this Subscription Agreement, and to


the best of Purchaser Representative's knowledge, all of the information,
warranties and representations made by Subscriber in this Subscription
Agreement are correct.

Print or Type Name

Address

Taxpayer I..

No.

Date

Signature

Print or Type Name and Indicate Title


or Position with Entity
ACCEPTED FOR THE COMPANY BY:

Stanley J. Caterbone, Secretary and


Executive Vice President
Dated:

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1986

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

"05L5 I " 0 S C " ~ t l C


*".*"I
L..CllCCI)
,.l**C,*
MIUS. _I".
6 . T"O*.l
lDLLCl
D O U L D I).WAIICL
IICMARD n. L c r r v r m
J . ,*O*AS
"LMIIILR
CLIDC W I L I N T l l C
s. .in*c SMITH

Document: 003112132545

Page: 211

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

MCNEES.WALLACE & NURICK


ATTORNEYS AT LAW
100 PINE STREET
P. 0.SOX 1 1 6 6

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

lrrcr*o*r (717) 232-BOO0

..

*.

Mr. Stanley J. Caterbone. Secretary


and Executive Vice President
Financial Management Group. Ltd.
1755 Oregon Pike
Lancaster, PA 17601
Dear Stan:
Enclosed is a copy of the Subscription Agreement prepared for use in
connection with the limited offering you now are conducting. I have reviewed
the document, and it appears to be in good order and does not contain reference
to warrants. Of course, you should review the document to be sure you deem
it suitable.
We sent Form D to the Securities and Exchange Commission by certified
mail. return receipt requested. on August 27, 1986. As you are aware, such
filing is a requirement of the exemption from registration under federal
securities law, and one or more additional filings will be required as well.
as we previously discussed. In general, the requirements are that another
filing must be made every six months while the offering continues, and not
later than 30 days after the last sale of stock. As you will have this
information, and we will not, it will be your responsibility to stay on top
of these future filing requirements. For your use, an extra blank copy of
Form D is enclosed, which you can photocopy in order to provide additional
copies for use.
Sincerely.
WALLACE 6 NURICK

BY
WJJ/sg
Enclosures

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Jamouneau

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100 south Street. post m i c e

Page: 212

BOX

486

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Harrisburg. PA 17408

Telephone 1747) 238-6715

COMMITTEE ON LEGAL
ETHICS AND PROFESSIONAL
RESPONSIBILITY
Chairrnon
M#Ch.,F A a,:>*
Vice Choirman
.lom-~
'j "=:%*?"

PBA Liaison
,%.IC
;=: :ae,

September 19, 1986

PERSONAL AND CONFIDENTIAL


Keneim L. Shirk. Jr.. Esciuire
Shirk, Reist, wagensellei and Shirk
P.O. Box 1552
Lancaster, Pennsylvania 17603-1552
Dear Ken:

This letter is in reply to your inquiry of August 6, 1986


which inquiry enclosed a copy of the 'Charter Business Plan for
The Financial Management Group, Ltd.' dated July 1, 1986. You
have requested advice concerning the ethical implications for a
lawyer associating with The Financial Management Group, Ltd.
Briefly, in review of the materials which you provided,
seeks to position
The Financial Management Group, Ltd. ('FMG')
itself as a "major provider and servicer of financial products
and advice in the closely-related fields of investments,
financial consultation, mortgage banking, life insurance,
property and casualty insurance, taxes, law, and real estate..
It is the intention of FMG to retain in-house legal and real
estate professionals to assist financial planners in rendering
advice to clients, in the words of the Plan, .without fear of
losing the client to outside interests.'
Identified as part of
the "Support Services' which FMG intends to provide to clients,
is so-called 'professional networking' described by FMG as the
use of "in-house affiliates in law, accounting, tax", etc., to
serve clients and their related financial needs. The FMG
proposals specifically identify so-called 'affiliate firms'
which include a real estate entity and two law firms, one of
whom is identified as 'Legal Counsel for Business b Real
Estate' and the other firm is identified as .Legal Counsel for
Estate Planningg. A true and correct copy of the Charter
Business Plan of FMG is attached hereto and incorporated herein
as Exhibit "A".

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Kenelm L. Shirk, Jr., Esquire


September 19, 1986
Page 2

At the outset of our evaluation, certain points should be


made clear. First, a lawyer is entitled to engage in
businesses other than the practice of law provided that the
lawyer keeps such enterprises entirely separate from the
lawyer's independent practice of law. One of the problems
which an 'affiliatedg lawyer may face in associating with any
such financial services provider is the importance under the
Code of Professional Responsibility of maintaining the lawyer's
independent professional judgment on behalf of a client where,
for example, it may be argued that the lawyer can be said to
benefit because the tendering of advice may give rise to the
purchase of financial service products from FMG. Under those
circumstances, the lawyer may be subject to charges of
conflicts of interest arising under DR 5-101 which provides, in
pertinent part, that: "a lawyer shall not accept employment if
the exercise of his professional judgment on behalf of his
client will be or reasonably may be affected by his own
financial, business, property, or personal interests.'
Of equal concern is the ethical requirement prohibiting
in-person solicitation of a prospective client with whom the
attorney does not enjoy a present or former attorney-client
relationship. There appears to be a likelihood that FMG will
directly solicit, on an in-person basis, clients with whom your
law firm has no present or past attorney-client relationship
which may subject you to the charge that PMG has done for you
indirectly what you are prohibited from doing directly.
Certainly, we cannot opine that there is no risk of violation
based on the foregoing assumed facts.
Additionally, one must take care to avoid any ownership
interest in PMG mindful of the prohibition contained in DR
5-107 that a lawyer shall not engage in the practice of law for
profit if a non-lawyer owns any interest therein. Accordingly,
compensation for legal services rendered should be made on a
fee for service basis or other objective format, avoiding any
possible charge of joint ownership of the venture.

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Kenelm L. Shirk, Jr., Esquire


September 19, 1986
Page 3

.............................

It is also important that the confidentiality of


information developed during the course of the client
rtprssentatisn by your lax fir3 be held secret and confidentiai
in accordance with DR 4-101. Accordingly, disclosure of the
estate planning needs of clients should be done with the
express written consent of the client, particularly where a
charge may later be made by a disgruntled client that such
information was misutilized in order to induce the client to
purchase financial services products sold by FMG (on which FMG
may be entitled to commissions or fees). Moreover, to the
extent FMG earns such fees or commissions, full disclosure of
FMG's interest in the sale of such financial services products
should be made by the attorney pursuant to the attorney's
independent obligation to provide the client with competent
advice and a duty of loyal representation.
As you may sense, this brief reply to your inquiry
identifies only some of the ethical problems which may exist in
connection with the proposed structure.
It is not intended, by this letter, however, to
discourage such enterprises. To the contrary, it is believed
that, carefully structured, lawyers are free to participate in
such ventures. Should you require a more detailed opinion, we
request that you provide us with specific questions about
proposed courses of conduct so that we may be responsive to
them.
Should you have any questions concerning this preliminary
reply, please contact me. I remain
Sincerely,

pdh
Enclosure

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Kenelm L. Shirk, Jr., Esquire


September 19, 1986
Page 4

.............................

Caveat: Each person requesting an opinion from this Committee


must be informed that this not an official opinion of the
Disciplinary Board of the Supreme Court of Pennsylvania and
that any opinion rendered will be afforded only as much weight
as the reviewing authority may choose to give it.

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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 ,

I r e c e i v e d your l e t t e r d a t e d O c t o b e r 29, 1986 w h i c h accompanied


t h e Compaq c o m p u t e r w i t h a v i d e o m o n i t o r .
I also received the
S o f t b r i d g e system.
I assume you i n t e n d t o k e e p t h e :
E p s o n m o d e l FX-286
HP l a s e r j e t

dot matrix printer

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

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Advisory, Inc.
m m w m w
IN',.'

*"N"Gr*E*r

OID",.

Eden Park 11. 1755 Oregon Pike

Lancarter, PA 17601

717-569-4100

LID

STANLEY J. CATERBONE
PRESIDENT

December 31, 1986

Mr. Thomas TucKer


221 Lincoln Way East
Chambersburg, PA 17201
Dear Tom:
Attached are updated R.I.A.
Kits for your use.
Please
note that we amended the ADV to include Asset Monitoring
and also changed the client agreement to include Market
Timing. Please discard your previous kits.
If you have any questions or concerns, please call
Sincerely,

Stanley J. Caterbone
President
SJC: lmk
CC

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Section 3189 Federal False Claim Act

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Executive Vice-President
Stanley Caterbone
Acts as Marketing Officer, Supervision of Registered Investment
Advisor, Supervision of Computers and Word Processing,
Insurance Product Selecsion
1.

Manages all Advertising - Radio and Newspaper, Seminars


and Corporation promotion

2.

Manages computer and word processing, letter and proposal


generation, Insurance proposals, Software review, IFS System,
data input, hardware and software maintenance

3.

Manages Registered Investment Advisor, Compliance with NASD


laws for R.I.A., set up and maintain files and review plans

4.

Supervision of casewriters, coordination of efforts

5.

Supervises computer technician, oversees the above functions

6.

Advise on hardware acquisitions for all reps and train all


reps in the use of all network software

7.

Acts as Corporate secretary, keeps corporate minutes and


issues stock certificates

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Page: 219

Date Filed: 11/18/2015

Jerry Ehvem, President


Registered R e p r e ~ n t a t i

"tnnovarton m ~ l n o n c ~ srralegres"
al
.

Bennington Financial Group, Inc.


21 South Fourth Smec
Levusburg. PA 17837
7 17-513-3118

January 5, 1987

Pcnsionr

dn , fkt

Financial Management Group, Inc


1755 Oregon Pike
Lancaster, Pa. 17601

heft

Ikfind Contribution
P d t Sharing

ATTENTION:

Kmuglis

Dear Stan:

IRA'S

STAN CATERBONE

I have received the programs that I wrote to you


about on November Zlst, and I want to thank you very much
for the quick service. 1.expect that they will be very
helpful. !

Auet Manngrment

I was wondering if there is a manual that explains


these programs and how to best utilize them. If such a
guide exists, I would very much appreciate receiving a
copy of it.
I also need instructions for loading the
programs on my computer. I have a Leading Edge computer
with a fixed disk, which is compatible with the IBM P.C.;
therefore,
I need to know the proper method to use to
install and run the programs on this type of system.

Oil & Gas

If you have any questions regarding the above,


please don't hesitate to give me a call.

Emphyrr &n&t
Plans .

I'm looking forward to hearing from you soon.

Employee Communicption

Booklets

Thank you for your help.

L n t e Planning
College Funding m

Charitabk Giving

Foun&tlonr

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Securiticr Tmnsactions through ~ S C
Sccu;irics Corporation

*.~-~L~
.,A=..

Wednesday, November 18, 2015

A Rrgirrcmd BrokcrlD?lcr

''
1
10/19/2006
2 .

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 220

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

K. L SHIRK, SR. (1915-1956)

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

I N REPLY REFER TO:

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:

Dr. and Mrs. Vlilliam Umiker

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

Third
Circuit
15-3400 17522-2014
EPHRATA,
PENNSYLVANIA
717-733-2588
Property
of Advance Media 117-626-2404
Group

4 0 2 SOUTH BROAD STREET


PagePENNSYLVANIA
219 of 806 17543-2602
LITITZ.
717-626-2775
Page 2165
of 2953

2 5 0 MAPLE AVENUE

Wednesday,
November
18, 201517566-132C
QUARRWILLE.
PENNSYLVANIA
717-786-1123
10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400 Document: 003112132545


S t a n l e y J. C a t e r b o n e

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Section 3189 Federal False Claim Act

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~ 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

new l a w ( a b o u t two y e a r s o l d ) a r e b r o a d e r a n d t h e y may w a n t t o know


about t h a t .
Thank y o u .
Sincerely,
SHIRK, -3EIST, WAGENSELLER AND SHIRK

Third Circuit 15-3400


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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

COMMONWEALTH OF PENNSYLVANIA

ROBERT M. IAM
Chairmin
I

Page: 222

DICKTHORNBURGH
Governor

FREDERICK H. PLANK
Commi~sioner
LORI HEISER
Commissioner

--

--

Pennsylvania Securities Commission


333 Market Street
Harrisburg, PA 17101-2209
Telephone: (717) 787-8061

January 13, 1987


Stanley J. Caterbone, President
F M G Advisory, Inc.
1755 Oregon Pike
Lancaster, PA 17601
ADVISER APPLICANT:

DATE OF FILING:

F M G Advisory, Inc., (FKU)


1755 a e g o n Pike
Lancaster, PA 17601
Septenher 25, 1986

Dear M r . Caterbone:

This w i l l a c b l e d g e receipt of your'sutmission on December 18. 1986, in


response t o our letter dated October 24, 1986. In this respect, before
f u r t h e r consideration can be given, it w i l l be n e c e s s a q t o provide the
following:

1. Effective date of Applicant's r e g i s t r a t i o n with t h e U.S.


Securities and Exchange Cemnission under Section 203 of the
Investmnt Advisers A c t of 1940.

2.

Reference is made t o t h e disclosure on Schedule F f o r 'Item 8(C)'


wherein it s t a t e s "A potential c o n f l i c t of interest rnsy arise
from t h e fact the Financial Management Group, Ltd., w h i c h ow^
a l l the outstanding stock of the Applicant, a l s o has an i n t e r e s t
in a f f i l i a t e d ~ a n p a n i e swhich o f f e r products m services similar
In this respect, p r w i d e
t o those t h a t might be r e c m n d e d . '
an opinion as t o why these ' a f f i l i a t e d canpanies" have not been
i d e n t i f i e d under question 8.C., Fonn ADV-Part 11. AmMd
Form ADV if appropriate.

3.

With reference t o Financial Management Group, Ltd. (-)


p r w i d e a detailed and mnprehensive description of the nature
and scope of EMGL's plan of business and t h e relationship, if
any, between this e n t i t y and t h e Applicant.
With respect t o Robert E. Kauffman and Michael M. H a r t l e t t , who
are individuals with control and l i s t e d as Vice R e s i d e n t and
Secretary, respectively, p r w i d e an opinion as t o why their
educational and business background has not been disclosed an
Schedule F under question 6, Form ADV-Part I f . .

4.

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1109 STATE OFFICE BUILDING. PHILADELPHIA. PA 19130-4088:Tele~hone215-560-20

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

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Page: 223

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Stanley J. Caterbone
F M G Advisory, Inc.
3&1uuy.13, 1987
Page 2

5. With respect t o the f a c t t h a t Messrs Caterbone, Kauffman and


H a r t l e t t are registered representatives with FSC Securities
Corporation (FSC), p r w i d e an undertaking signed by an officer
of FSC, s t a t i n g that F5C has reviewed and has no objection t o
the follwing:
a.

The Applicant's plan of business, method of


operation, (including but not limited t o f e e
s t r u c t u r e ) as we11 as c o n f l i c t of interest disclosure, s e t forth i n Applicant's Form AW as
f i l e d with this agency;

b.

The tenns, conditions and disclosure s e t f o r t h i n


t h e Applicant's proposed investment advisory cont r a c t (s)/agree~r~=nt
(s); and

The inv&tment advisory a c t i v i t i e s of the above


namsd individuals, as disclosed in t h e Applicant's
Fonn AW, while registered as agents f o r FSC.
After review of t h e Schedule D f o r Michael Hartlett, it is noted
t h a t Mr. Hartlett is a planner f o r Financial Planning Consultants
(FFC), Lancaster, Pa. In this respect, p r w i d e a detailed
the duties and
description bf FPC's plan of business to incl*
r e s p o n s i b i l i t i e s of Michael Hartlett as a planner f o r that firm.
Fbrnish specimen w p i e s of a l l f o m of contracts and/or agreem t s t o be used by the Applicant f o r its investment adviser
c l i e n t s i n Pennsylvania.
Reference is m d e t o the disclosure cn Schedule F f o r
" I t e n 13(B)' wherein it indicates t h a t the Applicant w i l l &
cash payrents t o s o l i c i t o r s . I n this respect, amend Form ADVPart I1 in order t o p r w i d e an affirmative response t o question
13.B.

c.

6:

7.

8.

..

In t h e event a canplete response t o the information requested above is not


received within t h i r t y (30) days frcxn receipt of this l e t t e r , t h e application
rnay be placed before t h e Ccmnission so that it m y consider issuing a Denial
f o r Abandonment Order pursuant t o Section 602.022 of the Pennsylvania
Securities A c t of 1972.

Paul M. Schwartz, ~ c t i n kDirector


~ i v i s i o nof Licensing

CERTIFIED W

Third Circuit
15-3400
RETURN
RECEIPT
Property of Advance Media Group

REQUESTED

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Bob Kauffmn,

Mike M e t t , and

Page: 224

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

S t a n Caterbum

Frow: Qrolyn D Royer

As you Iomw, I have f u l l f i l l e d the initial step in my 1987 plan by obtahhg


my series #24 lisc. lherefore a t this time I feel I shcdd recap my g a d s as
W as the time table for the inP,lementation. I am basing much of the time
table on information that has am to liqht since I passed my test on m&y,
1/12/87, and as always Upaates and champs can be expsct&.

Pr*

Goal: lb E?e m
i
n
t
e
d President of FIG Emker/D=aler

Secondary Goal: To Continue To


SupplanerM Perscolal Earnings.

In The Year 1987.

Fursue A Firm Client Base An3 -te

I reaffirm my primary goal w i t h the


that the firns desire a t the
present time is that I work on my prsmal production and pit the B/D
Presidency cn hold until such time as I am notified by the firm that this goal
f i t s the corporation goals and objectives.

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

stress my camnitment to this goal is for the betterment of the


corporation as a whole, while a t the same time, this amnnitment will give me
great perscnal satisfaction.

sincerely m t t e d ,

Carolyn D Royer

I
Third Circuit 15-3400
Property of Advance Media Group

Page 223 of 806


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

P.O. BOX 601 1

ROCKV'

Page: 225

MD 20850

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

(301) 738.6500

j/\Y 13 E ~ J

CANDIDATE QUALIFICATION EXAMINATION SCORE REPORT


CANDIDATE:

CRD #

ROYER, CAROLYN DELLER

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

failed and wishes to retake this examination should


complete page one of Form U-4 and return it to the CRD, P.O.Box 6011, Rockville, MD 20850. A $50.00
examination fe

. .

BROKER DEALER #

7461

FSC SECURITIES CORPORATION


250 PIEDMONT AVE NE STE 1900
ATLANTA, GA 30365
ATTN:
Third Circuit 15-3400
Property of Advance Media Group

Page 224 of 806


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DENISE M. PROPES
Wednesday, November 18, 2015
10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 226

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Institutional Investors of America, Inc.


Financing.Investments & Advisors
iUlan D. Dannsli
Managing General Parhler

January 20, 1987


HONORARY CHAIRMAN

Gm.s. Moon

,)

CHAIRLLINoFrnEmARD
* a d w. I-h

Mr. Stan Caterbone


Financial Management Group
1775 Oreqon Pipe

DIRECTORS

~~~~~.~
~

k.
v*. P&n(
k t x hB=+.NYC

Re:

*. I..
oyimy.

C u U

Fo-.

ur. A

CAYIW I-. co.


hrnbnvdca

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.

In reference to the above captioned subject, enclosed


please find a synopsis of our lending programs. We
are very interested in business in your part of the
Country. I will also be in a position to do some
other business with you through the bank we just
purchased in 60-90 days.
Very truly yours,

Allan D. Dannatt
President
ADD/slh
Enclosure

Third Circuit 15-3400


Property of Advance Media Group

Page 225 of 806


777 North Eldridge Page
Parkway.
2171 ofSuite
2953 730

Wednesday, November 18, 2015


Houston. Texas 77079
10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 227

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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%

Fived Rates a l s o available a t 325 basis pints wer c

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

Similar terns available f o r m i n i wx&mses,


homes and ACLF f a c i l i t i e s .
Forwarrl,
available.

q,
open-ended

hotels, mobile home parks, nursing

and covered construction


Maxmm loan to value of 809.

loans are also

W e are a r n m t l y seeking t o plrchase $500 million in


Sale Leasebacks
p r q e r t i e s nationwide leased to nationally listed public corporations w i t h good
credit ratings. Leases r r p ~ s tbe NNN with a minimJm of a 10 year tenn. Mininnnn
cash h
t
$5-$500111.

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
Third Circuit 15-3400
Property of Advance Media Group

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Page: 228

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Planning Consultants
Oregon Pike Lamaster, PA 17601 717-569-1100

ROBERT E. KAUFFMAN
PRESIDENT

January 20, 1987

Hibbard Brown & Co., Inc.


7855 Walker Drive
Suite 6 2 0
Greenbelt, Maryland 20770
Dear Pete:
I have discussed our visits with the other two partners and the
initial reactions have been favorable. I am going to give you my
interpretations of our meeting along with some minor changes my
partners would like to see. Hope to hear from you soon.
A.

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.

Third Circuit 15-3400


Property of Advance Media Group

Securities Transactions thmugh FSC Securities Corporati-n


Page 227BmkerIDtaler
of 806
Wednesday,
A Registered
Member
NASD
Member SIPC
Page
2173 of 2953

November 18, 2015


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

c.

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 229

Date Filed: 11/18/2015

Stock
-

F M G i s to receive a 20 percent interest i n HB Inc. a s recognition


of its production to the bottom line equity value of HB Inc.
10 percent based upon a preThis number may be adjusted
determined production schedule over the next five years.

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.

i s to receive the stock at n o charge.

Divorce Planning
1.

Should F M G volume drop below two million in volume, HB Inc.


would have the right to sever relations from F M G and buy back
stock earned at book value.

2.

Should F M G leave HB Inc. any time within five years (unless


sale o f HE Inc. occurs sooner), F M G rould also leave with
HB Inc. any equity attributed to i t s o w n business. F M G
would retain both equity and overwriting on direct relationships
they referred t o HE Inc.
Example:

3.

leaves producing 4 million after 4 years


Referred shops produce 2 million

FMG

a.

FMG

retains 1/3 o f 10 percent share or 3.3 percent o f stock

b.

FMG

retains 2 percent overwriting o n 2 million or $40,000

If our relationship survives five years, we would set the


earned equity percentage attained and reconfirm other
agreements.

Third Circuit 15-3400


Property of Advance Media Group

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 230

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

MINUTES OF THE 1/26/87 MEETING OF


THE BOARD OF DIRECTORS
The

Board

of

Directors

meeting

Oregon Pike, Lancaster, Pennsylvania


January, 1987.
PRESENT :
Robert E. Kauffman

on

was
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
Third Circuit 15-3400
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Case: 15-3400

Document: 003112132545

Page: 231

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

I t was agreed upon that the election of t h e additional

Board

of

Directors

at 4:00 p.m.

would

take

place

on

February

4,

1987

This would involve a one ( 1 ) year term.

The Meeting was adjourned.

Third Circuit 15-3400


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Case: 15-3400

Document: 003112132545

Page: 232

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Qxative Finance Campany


P.O. Box 4412
Lancaster. PA 17604

Hi* Ascciates, LTD.


Tom Kyle

1861 William Pem Way


Iaraster, PA 17601
February 3, 1987
Dear Tom:

,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

W e may be reached a t the following nlrmber; (717) 569-5555

Third Circuit 15-3400


Property of Advance Media Group

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. I \

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

TO: BaARD OF D l X C l D E

FINANCJAL IGmGmm GEmP,

Page: 233

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Em.

RE: WKER DEALER WWGER


A t this time I feel it is appropriate t o preserrt the Boazd of Directors w i t h an
qdate & reiteration of my godl to
the Broker DBaler Branch of F h c i a l

Management

c;ruop, m.

As i n i t i a l l y stated in my meim dated 12/30/86 & presented to the Principals a t


FMG, I would like to pusue establishing a strang, organized locdl situation to
clear our c u r r a t brokerage b u s h e s .

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

cbngirq our a x r s e fran the plrsuit of an FMG broker dealer.

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.

If this dkection is to continue and/or to plrsue a strang aperation here a t


Financial Mmagemxtt Group I am requesting that I be considered for this
position.
'Ihank Y o u for your time and consideration.

sincerely Sukmitted,

Third Circuit
15-3400D
Carolyn

Royer

Property of Advance Media Group

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 234

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

MINUTES OF THE 2 / 1 0 / 8 7 MEETING OF


THE BOARD OF DIRECTORS

The Board of Directors meeting was held at 1755


Oregon Pike, Lancaster, Pennsylvania on the 10th day of
February, 1 9 8 7 , at 4:25 p.m.
PRESENT:
Robert E. Kauffman
Stanley J. Caterbone
Michael M. Hartlett
Robert Long, Jr.
P. Alan Loss
constituting a quorum of the Board.
The Meeting was called to session by Michael Hartlett
and minutes recorded by Stanley Caterbone.
TOPICS DISCUSSED
Robert Kauffman asked for input regarding his letter
to Carolyn Royer.
The Board unanimously suggested that
the said letter be rewritten with more positive style and
softer tones.
The letter to Lynn Wood regarding the securities
problems was addressed and the following issues are to be
resolved by FSC:
a. direct entries
b. wireless mutual fund transactions
c. increased payout to our group
1. 8 0 % as of 1 / 1 / 8 7
2. 9 0 % in the future
1

Third Circuit 15-3400


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 235

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

The topic of the purpose of the visit from Don Aultman


and Steve Franklin was discussed:
a. inform Robert Kauffman of his release from FSC
contract
b. make Robert Kauffman an offer for a position
with FSC
The financial position of company was discussed
and it was recognized that revenues are lagging by as much
as eight (8) weeks.
The company is operating at a deficit
and the following solutions were mentioned:
a. Hire additional, better qualified people
b. Negotiate better margins
c. Use new product
1. local syndication
2. insurance contracts
Broker Dealer subject was discussed
a. Hibbard Brown offer was looked at and we decided
t? persue in more detail.
b. The deal with
Integrated Recourses was not
looked upon as being a possible alternative.
Robert R. Long adjourned the meeting at 6:30 p.m.
until February 11, 1987 at 4:00 p.m. to continue to discuss
the offer by Hibbard and Brown.

Third Circuit 15-3400


Property of Advance Media Group

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Case: 15-3400

Document: 003112132545

Page: 236

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

COLUbBIA ASSET MANAGEMENT CORP.


IXVESTbENT BANKERS

TWINING OFFICE CENTER


715 TWINING ROAD SUITE 116
DRESHER. PA 19025

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.

I f this is handled to our satisfaction, I would b e


pleased to submit additional properties for your clients
cc-nsideratinn.

Leonard M. Shendell

Third Circuit 15-3400


Property of Advance Media Group

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Case: 15-3400

Document: 003112132545

Page: 237

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

MINUTES OF THE 2/11/87 MEETING OF


THE BOARD OF DIRECTORS

The Board of Directors meeting was continued at 1755


Oregon Pike, Lancaster, Pennsylvania on the 11th day of
February, 1987 from the previous Board Meeting held on
the 10th day of February, 1987. Meeting held at 3:40 p.m.
PRESENT:
Robert E. Kauffman
Stanley J. Caterbone
Michael M. Hartlett
Robert Long, Jr.
P. Alan Loss
constituting a quorum of the Board.
I

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
Third Circuit 15-3400
Property of Advance Media Group

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Document: 003112132545

Page: 238

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Mr. Peter Hillard gave a brief history of B/D


At present there are sixty ( 6 0 ) representatives, intentions
of adding forty (401 in the next three (3) months.
$10 million by year end
The Board approved the loan of $10,000 to Gail Turner
for the start up costs of her office.
The
5:30 p.m.

Third Circuit 15-3400


Property of Advance Media Group

Meeting

was

adjourned

Page 237 of 806


Page 2183 of 2953

by

Robert

E.

Kauffman

at

Wednesday, November 18, 2015


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Case: 15-3400

Document: 003112132545

Page: 239

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

February 1 3 , 1987

Stanley 3. Caterbone
Financial Management Group
1 7 5 5 Oregon Pike
Lancaster, PA 17601
Re:

Carter Manor Associates

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

Third Circuit 15-3400


) Property of Advance Media Group

Page 238 of 806


Wednesday, November 18, 2015
REAL ESTATE DEVELOPMENT I BUSINESS ACOUISITIONS
Page 2184 of 2953

1681 Crown Avenue 1 PO Box 8200 i Lancasler PA 17604 11717) 395-7100

,>.

10/19/2006

'

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 240

BARRY L . SCHUTTLER and ASSOCIATES

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

5501 TWIN KNOLLS ROAD SUITE 101 COLUMBIA, MARYLAND 2104


BALTIMORE 995-4084
WASHINGTON 621-566
COLUMBIA 992-3446

February 13, 1987

Again my apologies!

I can place the order for you for the tabs if


you are having problems locating a reasonable
price on ther?. What you may want to do, if
you plan on ?reducing Plans immediately, i s
to take some of ours and we will replenish when
your order is completed.
Feel free to call should you have additional
questions.

Third Circuit 15-3400


Property of Advance Media Group

Page 239 of 806

Wednesday, November 18, 2015

SECURITIES OFFERED T H R O U G H FSC SECURITIES CORPORATION


Page 2185 of 2953
A REGISTERED BROKER DEALER
MEMBER NASD/SIPC

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 241

Date Filed: 11/18/2015

Meet the Specialists


in Helping You Prepare for
Your Financial Independence.

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*

ROBERT R UYIO. JR.


Spsllll*

The Finincia1 Management Group Specialists are experienced


professionals with the knowledge and resources available in ONE

- - .Maximize your wealth

A. Tax Planning & Prepamtion B. Financial Planning


C. Estate Planning
D. Retirement Planning

.Minimize your taxes


-Improve your investment

IRA'S, KEOGH'S
E. Investment Analysis. Implementation & Management
F. Insurance Analysis, Planning & Implementation
G. Legal Services
H. Real Estate Services

coordinate your personal and

business financial planning

A B C D E F G H

A
..

-.."a.--

"I.*

Eden Park 11,1755 O w o n P l b


L d n ~ s l e rPA
, 17601

(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
Third Circuit 15-3400
Page 240 of 806
Wednesday, November 18, 2015
Property of Advance Media Group

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Case: 15-3400
ROBERT M. LAM
ch.innan

Section 3189 Federal False Claim Act

Document: 003112132545 Page: 242


Date Filed: 11/18/2015
COMMONWEALTH OF PENNSYWANIA
NANCY L. DIANA
ROBERT P. CASEY
secrasry
Governor

FREDERICK H. PUNK
Commissioner

EUOTT KLElN
Chid Car-

Pennsylvania Securltler Commluion


333 Market Street
Harrlrburg, PA 17101-2209
Telephone: (717) 7876061

S t a d e y J. Giterhme, President
F M G Advisory, Inc.
1755 OrPike
Lancaster, PA 17601
IWESBENT AWISER APPLICANT:

P M G Advisory, Inc. (=)


1755 OrPike

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

1. Attached is a ccpy of a letter dated October 24, 1986 wherein w e requested


rtain infornation w i t h r e s p e d to Fm;'s application. To date, question 18 of
our October 24, 1986 l e t t e r has not been answered. I n this respct, furnish a
of those permns who will provide investmnt advice in FWuqlvania to
nclude, i f not previously filed, a ccropletd Schedule D of Fonn AW for each
such individual. This infornation is requested with reference to yan
affimmtive r e s p m e to question 17.A.(4), Form AW-Part I wherein you indicate
Em; enploys "10 or m x e persons" w l n p e r m i n w s t m n t &vimry fmctions.

&

2.

Reference i s nade to y a ~ rrespnse to qmstion 1.A.. Form ALYV-Part 11. The


responses, as presented, accamt for only 80%of m's Mal advisory billings.
W r d Form AW to -de
d i s c l e u r e as to &at -titutes
the r-iniq
20%.

3.

W i t h reference

4.

An affirmative respome to question 2.G.. Porn AW-Part 11 requires disclosure


on s&edule F. A m r d Schedule F accordimly.

to your affirnative response to q u e s t b 1.A. (8). Form AW-Part


I1 an3 the required disclosure on Shedule F, it appears that the information,
as presented, dces not povide a descripticn of the timing services of FMG. . .
W d Schedule F to include a description as required. The description s b l d
include, a t a mininum, any fees M d . 1 are d-arged to the c l i e n t w i t h respect to
timing, i.e., a witchiq fee.

Third Circuit 15-3400


OFFICES

"\

Property of Advance Media Group

1109 STATE OFFICE


BUILDING,
PHILADELPHIA.Wednesday,
PA 191304088;
Telephone
Page
241 of 806
November
18, 215-56C-205
2015
806 STATE OFFICEPage
BUILDING.
PITTSBURGH. PA 15222-1210; Telephone 412-565-5003
2187 of 2953
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Case: 15-3400

Document: 003112132545

Page: 243

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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.

With reference to Section I1 of FM;'s "CLPXT AGREFMWT" wherein it states,


"'Ihe client m y authorize FM; Pdvisary, Inc. to i n i t i a t e wit*
of
as to why this
imrestmnts between W s .
to question 12.A.,
information build not require an
R., C., o r D, Porm AIN-Part 11.

. .-,

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

An affirmative response to question 13.A.. mrm AW-Part I1 requires disclosure


Amenil Schedule F accordingly.
-

on Schedule F.

After review of the Shedule D for Mid-ael M. Flartlett, the follcwhq


discrepancies are noted:

a.

Schedule D reflects M r . H a r t l e t t w i l l becane a CFP in 3/87.

b.

Item 6 on Schedule F reflects Mr. Hartlett received his Certified Financial


Planner designation in the eprirg of 1985.

c.

Schedule D reflects Mr. Hartlett is a vice president of PMG Advisory, Inc.

d.

I t e m 6 on Schedule F reflects "Mr. H a r t l e t t w i l l serve as secretary of FMG


Pdvisory, Inc.

In view of the abwe, it w i l l be necessary to amend the appropriate docments in


order to reflect accurate and consistent inform?itim.
8.

Attached i s a aipy of our l e t t e r dated January 13, 1987 wherein we reqwsted


additional information with respect to m's ~ p l i c a t i m . As of this date, a
response to the follaving questions hks not keen received:
a.

vherein we requested an a p M m as to why certain "affiliated


mnpanies" had not been identified under question R.C., Form AW-Part 11.
(X1estirn 2

W i t h respect to PMG's "CLIISNT -",

it is noted that page 2 states, " I t is


undentccd that representatives of
M s o r y , Inc., mC Securities mrporation or other affiliated c a p n i e s , including the abwe-Mmed representative,
w i l l receive a share of that anmission, in addition to the abwe intrduction
fee." In this respect, it i s the opinion of staff that these affiliated
ccrrpanies should be nisclosed under R.C., Form AW-Part 11.
Third Circuit 15-3400
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F M G Advisory, Inc.
February 24, 1987
page 3
b.

m e s t i o n 3, wherein we requested informtion on Financial MaMgement Grmp,


Ltd. (m).In this respect, it is noted that ymr response on February
20, 1987 states,
Financial MaMgem?nt Graap, Ltd. i s a canpany prwidiw
financial services to individuals and small business. Financial
M n a g a e n t Group, Ltd. ams a l l of the cutstam%ng stock of Fm;
Advisory, Inc. Financial M a n a g m t Grmp, Ltd. pmvides
insurance an3 securities products to its clients a d is a x r e n t l y
using I332 Securities as its registered broker-dealer.

I n addition to prwidiq securities products t o its clients, it is noted


that the Shedule Ds f o r Messrs. C a t e r h e , K a u f m , and Hartlett r e f l e c t
under question #6, BUSINESS BAQ(-,
that FM;L i s a "financial plannirq"
firm. I n vied o the above information, provide an ophim as t o v h y F?GL
i s not registered under the Pennsylvania S e a x i t i e s A c t of 1972.

c.

Question 6, requested information w i t h respect to Financial Planning


Consultants (FPC), Lancaster, PA. Inasrmch as PPC i s referenced on M r .
FhrUett's Schedule D, as subnitted on Deenker 18, 1986, ard on Schedule
F, a s sulmitted on Febmiry 20, 1987, urder i t e m 6 (Michael Miles
H a r t l e t t ) , BIlSINESS BA(XGJDU?lD, it i s requested that Mr. Hartlett provide,
v i a *m;, a detailed description of F'FC's plan of tusiness to include the
duties ard responsibilities of Michael Hartlett as a p l m r for t h a t firm.

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.

f l w l d ycu need any additional infornation and/or c l a r i f i c a t i o n , please feel free t c


call m direct a t (717) 787-5675.
requested abcnre i s not received
I n the event a mnplete response to the infoma*
w i t h i n s i x t y days fran receipt of this letter, the application m y be placed before
the C a n & & . oso
n t h a t it nay consider issuing a Denial f o r M o r m n t O r d e r
pursuant to Section 602.022 of the Pennsylvania Securities A c t of 1972.
Very t r u l y yaas,

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

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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

FBI Pro.bes Kugel


Contracts with
N.Carolina Cities
Several Towns Unhappy with Delays;
Kugel Says He'll Fulfill Pacts
Lancasler developer

Owen Kugel, whose rev~taliration succea in domtom

lancaster helpcd him land


%imilsr confram in at least

seven states, is bein inverti.

Bald by, t k , ~ e d e r a fBureau


Of Investlgatron for downtown
revitalization pro'eets in
North Carolina. FBf omcia;
sav.
Robert Pence, in charge
OrNorth Carolina FBI opera.
tiotb. said (he investiflahen
centers on whether Kugel's
OK Assmiales firm based
here is involved in -mail
fraud, wire fraud or any other
typeofrraud.,,
lle added thal Ule use of
interstate racilities, as well as
the use of funds in interstate
eom,yeree,wouldbr studied.
I can confirm that we

Third Circuit 15-3400

Property of Advance Media Group

are looking into the matter to


determine if an federal laws
have been vioited:. added.

Daniel Womiak, a senior FRI


agent a t Ute bureau's GWM.
boro. N.C.. omce today.
omcials in a t least flve
North Camlina cities sa
they.re dissatisilied w i d
Kugel's prfarmanee on the
contracis and each has asked
him to returnhis w,mfee.
Kugel this mornin& tm
the New Era that he has been
aware of the investigation for
several w e d s and that he is
y p e r a t i n g with authorities
100 percent, in the interest
of &etttg It wrapped up
quie ly
"We know" the outcome
"can on1 be successful from
our standipo' ~nt."he said.
Kuge s a d he did not

know how the FBI got in.


volved in the situation. EX.
Plainin the contracts, he
said i f
d w t ( foum
thmugh on contract pmmis.
es. '.we give the money
back."
On the advice of dis attnr.
W .Alvin B. Lewis Jr.
Kugel wwld not discuss thd
status of the develo
Pro*
underway in

Carolina.

?%h'

Pence said the investiga.


t i ~ began
l
about M days ago.
But Kugel's former vice pres]dent. who arranged the
North Carolina contracts and

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Page: 246

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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.

T h i s follows up o n o u r 17 F e b r u a r y meeting a b o u t 112ortgage


Financing f o r o u r upcoming development projects.

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

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'

Page: 247

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Date Filed: 11/18/2015

'
.
.

I--

In
u-

n DrDw

newsletter
MARCH 24,1987

Third Circuit 15-3400


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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

6 Month
1 Year
2 Year
3 Year
4 Year
5 Year
7 Year
10 Year

Other 0 ' s Available


10 Year Zero Csupon $500
olll Mark if interested.

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

Cleanvataer, Florida has joined FIG.


in Florida and was a tap p
w a t ICE, and FSC.

Tcan mrked

As of early today, he reahed a negvtiated accord with n i k k m d - a


of Wash. D.C. to be an: new b-er.
We w i l l finalize our
agreement x + b a we have final contracts and have ampleted our due
diligence on their amp2ury.
Please keep an: offices as dean and neat as pcesible, it says the
right things to cur clients.
m

Third Circuit 15-3400


Property of Advance Media Group

Qooked Oak Rmmacy, Inc.


is a soall d
t
y dnag store with
prsonal service.
Prescription piclaq .and delivery service to our
office is available for ycur wnvience. Also those who are in a
hurry and tiant wmethirg different they have delicia sandwiches by
Kelly's Deli.
They are lccated just a short distance f m our
office in Qwlced OakVillage. Store h m are 9 to 6 weekdays and
9 to 1 on Saturday. mir @one mm$er is 560-1710.

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Page: 249

Date Filed: 11/18/2015

MINUTES O F THE 3 / 2 6 / 8 7 MEETING OF


THE BOARD OF DIRECTORS

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.

Perpetual override f o r r e p s introduced outside

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.
Third Circuit 15-3400
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orgar~izatiorl

a.m.

a t Dempsey's

t o 10:OO a.m.

a t Dempsey's

t o 1O:OO

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Case: 15-3400

C.

Document: 003112132545

Agree t o b r i n g

Page: 250

Satellites

J e r r y Bavero

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

to

Board

Keetings:

Richard Podlasek

Tom T u c k e r

R i c h a r d Volpe

The M e e t i n g was a d j o u r n e d by R o b e r t Long a t 12:45 p.m.

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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

March 26. 1987

Mr. Robert E. Kauffman


Financial Management Group, Ltd.
1755 Oregon Pike
Lancaster. PA 17601
Dear Bob :
Steve Franklin, Don Aultman, and others have brought to my attention their
recent correspondence and conversations with you concerning your present
status, and that of others. vith our Company.
I

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.

Your Employment Agreement vith the Company specifically provides


that you would not engage the services of any of our representatives
into any other brokerldealer without giving us 90 days notice (the
purpose of which obviously vould be to allow us to talk with these
representatives).

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Mr. Robert E. Kauffman


March 26, 1987
Page 2

3.

Said employment also specifically provides that no such change


should be made with respect to representatives outside the Lancaster
MFA, for a period lasting through September 30, 1989, or two years
following termination of your employment.

4. During this time, as an employee of the company, you owed FSC a


strong duty not to solicit other FSC HFAs into your Lancaster MFA in
order to join your program with a competitive brokerldealer.
5.

Your duties to FSC included an obligation not to accept an extension


of your salary while in Lancaster after you had begun to solicit our
representatives to leave FSC.

We expect to hold you strictly accountable for these obligations, through


legal action if necessary.
Meanwhile, we plan to continue talking to our representatives currently under
contract, whose relationships with us we value highly. Whatever decisions
they may be in the process of making, should be made on the basis of all the
facts so that careers are not unfairly prejudiced. At the same time, we would
welcome an orderly and businesslike termination process in your case, and
others who may choose to join you, leaving all to engage in competition,
fairly and in good faith.
We hope that, after studying this letter carefully, you vill not proceed
rashly.
We need to know from you before April 1st whether we can disengage without
further hostility on your part, or whether we will be compelled to take legal
I
act ion.
-

Yours sincerely,

/ ~ o h n B. Keeble

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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

March 26, 1987

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

F i r s t , we want you t o know t h a t you a r e a valued r e p r e s e n t a t i v e of t h i s


Second, we want a f u l l
Company, and want v e r y much f o r you t o s t a y w i t h us.
o p p o r t u n i t y t o d i s c u s s t h e s i t u a t i o n w i t h you t o avoid any p o s s i b l e
misunderstanding. And p a r t i c u l a r l y we want you t o h e a r our s i d e of t h e
s i t u a t i o n w i t h r e s p e c t t o Bob Kauffman.
We have w r i t t e n Bob today s t a t i n g our p o s i t i o n w i t h regard t o him, and e n c l o s e
a copy of our l e t t e r , s o t h a t you may be advised of t h a t p o s i t i o n . We would
welcome a c a l l from you confirming your d e c i s i o n t o remain w i t h u s o r
e x p r e s s i n g any concerns t h a t you may have w i t h r e g a r d t o Bob Kauffman's p l a n s .
We w i l l continue our e f f o r t s d u r i n g t h e next few d a y s t o c o n t a c t you.
W
e would l i k e v e r y much a c o n t i n u i n g , p r o d u c t i v e and c o r d i a l r e l a t i o n s h i p w i t h
you f o r many y e a r s t o come.
We apologize f o r t h e form of t h i s l e t t e r , but w e r a n o u t of time.
Yours s i n c e r e l y ,

John B. Keeble

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Property of Advance Media Group

Stephen G. F r a n k l i n

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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

JOHN M. C I C A L A SR.
DEVELOPER

22nd & Boardwalk


North Wildwood N.J. 0 8 2 6 0
December 1 2 , 1 9 8 6
Dear P r o p r i e t o r :
Due t o y o u r e x c e l l e n t r e p u t a t i o n a s a s u c c e s s f u l member o f New
J e r s e y ' s S o u t h S h o r e b u s i n e s s c o m m u n i t y , we a r e d e l i g h t e d t o
i n v i t e you t o p a r t i c i p a t e i n a n e x c i t i n g new v e n t u r e : SEAPORT
VILLAGE.

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.

According t o r e c e n t demographic s t u d i e s , t h e number o f a f f l u e n t


s i n g l e s , c o u p l e s and f a m i l i e s v i s i t i n g North Wildwood e a c h summer
i s r a p i d l y i n c r e a s i n g - along w i t h t h e i r p e r c a p i t a spending.
The o t h e r p i e r s i n t h e a r e a a r e a l l Amusement P i e r s . T h u s ,
S e a p o r t V i l l a g e i s a f i r s t of i t s k i n d - and a n a t u r a l s i t e f o r
t h e r e l o c a t i o n o r e x p a n s i o n of y o u r b u s i n e s s .
T h u s f a r we h a v e a p p r o a c h e d B e n e t t o n , S w a t c h , A t h l e t e ' s F o o t ,
Gimmee J i m m i e s Cookies and Banana R e p u b l i c , a s w e l l a s a s e l e c t
g r o u p of l o c a l b u s i n e s s e s s u c h a s y o u r s t h a t would b e b e s t s u i t e d
t o o u r c o n c e p t and would have t h e g r e a t e s t c h a n c e o f s u c c e s s .
S i n c e r e n t a l s p a c e i s l i m i t e d , we w i l l a c c e p t r e s e r v a t i o n s on a
f i r s t - c o m e , f i r s t - s e r v e d b a s i s . An a r c h i t e c t u r a l r e n d e r i n g of
S e a p o r t V i l l a g e i s e n c l o s e d f o r your f u r t h e r i n f o r m a t i o n .

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.

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erely,
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li

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 255

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Planning Consultants
Omgon Pike &nuster, M 17601 717-569-4100

ROBERT E. KAUFFMAN
PRESIDENT

Mr. Jahn B. Keeble

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

Bncezning your points, allm me t o respand.


1.

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.

I am open to a period of time


yau could solicit whawer you
want to stay withFSC. I cannot coerce representatives to join
with me anyway.

3.

I did not s o l i c i t -tatives

t o leave FSC while under salary

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

-.

and myself work that out.


I also appreciate your interest i n a
peaceful tzansition as per our phme conversation.

R.E. Kauffman

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Sccvrfties r r a n n n i o n r t h m q h FSC Securities C-ration


2200 ofB2953
APage
RnJstcmd
rok~rl~ler
Member NASD
Member SlPC

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 256

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Planning Consultants
Omgon Pike &nuster, M 17601 717-569-4100

ROBERT E. KAUFFMAN
PRESIDENT

Mr. Jahn B. Keeble

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

Bncezning your points, allm me t o respand.


1.

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.

I am open to a period of time


yau could solicit whawer you
want to stay withFSC. I cannot coerce representatives to join
with me anyway.

3.

I did not s o l i c i t -tatives

t o leave FSC while under salary

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

-.

and myself work that out.


I also appreciate your interest i n a
peaceful tzansition as per our phme conversation.

R.E. Kauffman

Third Circuit 15-3400


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Sccvrfties r r a n n n i o n r t h m q h FSC Securities C-ration


2201 ofB2953
APage
RnJstcmd
rok~rl~ler
Member NASD
Member SlPC

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case:p
15-3400
,nfL Document: 003112132545

For

1142 ELIZABETH AVENUE

BOX 4665

Page: 257

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LANCASTER. PENNSYLVANIA

17604

17171 397-6174

April 9, 1987

Mr. Robert Kauffman, President


FINANCIAL PLANNING CONSULTANTS
1755 Oregon Pike
Lancaster, PA 17601
Dear Mr. Kauffman:
First, I would like to express my thanks for the co-operation and excellent
service rendered by Harry E . Radcliffe, a member of your orgainzation. The
response Harry has given to my specific goals has been extremely satisfying.
Due to Harry's display of concern and manner of handling my personal investments, I made the introduction to Mrs. Patti M. Rottmund.
Mrs. Rottmund is the owner of Conestoga Fuels, Inc.. Currently the company
and Mrs. Rottmund are searching for an accounting f i n to assist in the
management of the corporate money. Due to Mr. Radcliffe's patience and
ability to explain financial matters to Patti Rottmund, we had been considering utilization of Financial Planning Consultants to aid in Conestoga
Fuels, Incorporated's financial planning.
-

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.

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Case:p
15-3400
,nfL Document: 003112132545

For

1142 ELIZABETH AVENUE

BOX 4665

Page: 258

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LANCASTER. PENNSYLVANIA

17604

17171 397-6174

April 9, 1987

Mr. Robert Kauffman, President


FINANCIAL PLANNING CONSULTANTS
1755 Oregon Pike
Lancaster, PA 17601
Dear Mr. Kauffman:
First, I would like to express my thanks for the co-operation and excellent
service rendered by Harry E . Radcliffe, a member of your orgainzation. The
response Harry has given to my specific goals has been extremely satisfying.
Due to Harry's display of concern and manner of handling my personal investments, I made the introduction to Mrs. Patti M. Rottmund.
Mrs. Rottmund is the owner of Conestoga Fuels, Inc.. Currently the company
and Mrs. Rottmund are searching for an accounting f i n to assist in the
management of the corporate money. Due to Mr. Radcliffe's patience and
ability to explain financial matters to Patti Rottmund, we had been considering utilization of Financial Planning Consultants to aid in Conestoga
Fuels, Incorporated's financial planning.
-

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.

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Document: 003112132545

Page: 259

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Management Group, LTD

TO:

Bavero
Schuttler
Volpe

April 14, 1987

Cur next board of di.re3mr-s meeting will be held on Tuesday,


May 5, 1987, at m y ' s Restaurant. We would like you to attend if
at all pssible.
If rut, please discuss the topics at hand with
Mike, Stan or me prior to the meeting.
At that meeting we plan:
1. An uplate of Fm; f m inception

a. budget review
b. goal achievmt analysis
2. A discussion of Profit Participation Plan in the form of

stock bonuses for prcducers


3. A

discussion of corporate legdl advice concerning the


formation of a separate ccwparnl to function nationally

4.

A discussicm of any newsworthy plans naw in developent such


as
private
take-down
-ps
and
illmmme
relationships

R.E. Xauf?imn

a: s. Qterbone

M. Hartlett
R. Long
A. Loss

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11, 1755 Oregon Pr*e

Date Filed: 11/18/2015

Advisory

TO:
FROM :
DATE:

Section 3189 Federal False Claim Act

Page: 260

Lancaster, PA 17601

717-569-4100

Representatives
Stanley Caterbone
April 21, 1987
FMG

Attached please find the billing procedure that will be used


by the FMG Advisory and Accounting.
Please submit this form to Lynn and a statement will be sent
to .the client.

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Date Filed: 11/18/2015

newsletter
A P R I L

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1 9 8 7

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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

t h e Planning Department has received a plan


and R i M ~ e r m n - - C o n g r a t u l a t i o n s . If
h m to use our plan, they would be mre than
--Stan Qterkone

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
-

New Off ice Potential


W e have begun talks w i t h a m j o r Redl Estate finn in York PA that w i s h e s us to
sydicate a new building in the dmarea. They are very interest4 in

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

Real Estate Fruiects


I have secured a source
million and above.
Any
refinancing such projects
available.
C a l l me i f
states. -Stan Qte?&one

--

of mortaaae funds f o r lame real estate miects. 2


anyi
n
in f'L-iaiking'or
m y be good .-p
'Ihere are finders fees
you need any more information. Available in all
persons having

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

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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Meetins

A brief reminder that an office meeting is s&eduled for 8:30-10:OO AM i n our


conference rwm this Wednesday April 15th, and also in two weeks on Wednecry
April 29th. -Bob Kauffman

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

in the IF'S W i t v Pool are

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in all capitdl letters, rather than

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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

MINUTES OF THE 4/16/87 MEETING OF


THE BOARD OF DIRECTORS

The Board

of

Directors Meeting was held at

the

offices of McNees, Wallace and Nurick, 1 0 0 Pine Street,


Harrisburg, Pennsylvania on the 16th day of April, 1987.
PRESENT :
Robert Long
Robert Kauffman

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.
'

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The

Document: 003112132545

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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

followir~g topics will be consj.dered

for shareholder

vote within the next thirty days:


Formation of FMG National Inc.
Directors Liability
Exemption of By Laws for above
Closing current offering

A 5:l

Stock Split

~ e % f r eJamouneau
y
advised on subjects of the R.I.A.
%

P. Alan Loss adjourned the meeting at 10:15

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a.m.

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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LICENSED REAL ESTATE BROKER

P. 0.BOX 2300. PINELAND, FLORIDA 33945

PHONE (813) 283-106'

April 29, 1987

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

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Date Filed: 11/18/2015

May 2, 1987
I

of this dmmmt is to recollect a l l activities that I've been


involved w i t h i n Financial Planning and the formation of Financial Ma~gement
G r m p , to verify and doarment seine of the activities that I've been involved in
to date.
WpupOSe

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.

First of a l l , I started in the Financial Plback in 1982. After


getting out of the amtracting kusiness I took six weeks and traveled across
the country and came back and decided to get into the financial services
Being that several relatives have had dealings w i t h IDS, Investors
industry.
Diversified -ices,
I called the local branch in
upon finding the
manager Mmed R & e r t Kauffinan. Bab spent -time
withme, decided he w i s h e d
to hire me, and that began the process.
I was actually licensed in 1982 for securities and l i f e and was p t under the
mnagement of Bob Kauffman. Shortly thereafter, I would say probably in Jwe
or July, Bab was pmmDted and took a division in Tampa, Florida. Myself and
)three o r four other individuals who were under m g e m e n t decided that w e
wanted to fom a g r w p together so w e talked to anather district manager,
Staren H. and decided that, i f he would allm, we kcdd like to plt an office
together w i t h him.
A t this time w e did not have an office and he was mrkjng
out of a sndll office in Millersville. 'Ihe people who were with me was myself,
Mike Hartlett and Alan Loss. The three of us were very, very large producers,
especially Mike and Alan.
The three of us were probably larger than Steve's
district a t that time, so a t that point we located an office a t 255 Wer
Avenue, we walked under Staren H. district which increased his inmme by a t
least 30% to 40% pthat -&ion.

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

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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.

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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.

1985 I had became w i n t e d w i t h my business l i f e , not


learning
lonely being hkprk3ent and I became frustmted. I knew that
no one in Lancaster was doing a very high quality m i c e rqardbg Financial
laming and Financial Services.
Tb me, lancaster seemedtobeahighly
By

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.

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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

lancster and Cerrtral PA.

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.

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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 .

Fall of 1985, before our initial meeting, a f t e r I &idea


that I was not goin g
t o relocate in Atlanta, I began to look for other options in
One of
those were t h a t a couple people pt me in tmd w i t h several banks. One was
Joe S. with -th
National Bank and another was Meridian Bank. Both of
those irdividuals received
calls fmn peoplekl I did business w i t h
stating that I was looking for s a n & h g
ard asking that they give me an
btemiew. None of them !could wen goive me an interview. I received a letter
fmn C c m k m e d t h s
t
a
m t h a t they had no pasitions c p a a t this time, but
they would keep my ram on f i l e .
Fmm Meridian, I don't believe I wen
received a letter.
aLis is oneof t h e r e a s o n s t h a t I d o n f t h a v e v e r y ~
respect for banks, or people whowork inbanks. I d o n f t w i s h t o d w e l l into
this subjed, but because of several of these eposides I just don't have mch
respect for bankers, o r banks what so ever.

-.

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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.

Back in Februaq 1986, I became g o d friends w i t h Mary Lynn D i F o l c a , Kevin's


sister ard Mike's wife. We were always g c d friends, but back then when Kevin
left, we
very close because I spent alot of tim with them. Mary Iynn
was a t the time, 30 years old with three children, and she was always very tied
dam with the kids, basically a housewife. She never really had a job, never
worked.
I t w a s h a r d forherbecauserrmtof her other frienlswerecutworking
and had 01-eers. I a s k e d h e r i f s h e W d l i k e t o M p m e o u t f o r a f e w h o u r s
a we& doing general clerical an3 typing. She was very excited. I tho~@tit
was a chance for me to get S(II*~thirqs done ard I liked Mary Lynn alot d we
got along and I thx&t it was a chance for me to get a few extra things done.
I took her on in February and before too long she was working 30 hours a week.
She had a babysitter lined up for the kids, ard it was very encanraging for me
to see her do this because it gave her the confidence for the f i r s t time that
she could do spnethhq other than just have children. She was having a great
time and I was having a great time and.= enjoyed working with Baeh other. A t
that time, Bob invited .Mike and I down to the annual confererms in !Iwsm,
Arizorn ard w i t h the conferenoe amangments we were allawed to take saneone,
such as your spouse. I asked Mary Iynn i f she wanteA to go and I don't believe
she was ever on a plane before and she asked Mike and he said it waild be good
for her t o meet scme of these peqle and get: involved w i t h a career. We ended
up d a m a t Tucson ard that was i n A p r i l 2 a n d w e s p e n t f m o r f i v e d a y s
there.
Upon meeting Bob ItoldhimIwasbringingMaryLynnoutandIhew
from the start that this was a sore spot. First of a l l she was married d he
couldn't urdershtd what she was doing cut there w i t h me. Semnl of a l l he
didn't appreciate the whole s i b t i a n when he met her he said scauethbq to the
effect that she looked very young.
After the secand day w e were a l l g c d
ard she was getthq a l a q very w e l l w i t h W and Pam. In fact, Pam
friends
confided things in her that I kmm Pam never told anyone. It looked as thcaigh
they liked, or a t least pretmxkd to like Mary Lynn and so anyway we all had a
Bcb, myself, andMikespent&of
w r t i m inindividualprivate
good time.
meetings trying t o pt this deal together and work cut the details -idly
with FSC.

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.
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into the building, they wmld not a l l m Mary Iynn to be back in my


haever, Nancy A. 's desk was right ma& up against Mike's door. lhis
start& all the problem w i t h Mary Lynn. She saw that and she wished to work
for me, and they were not goiiig to let her. It just started problem fmn day
one and it had a tmmxdms impact on the relationship between me, Mike and
Bob.
'Ibis was the straw that broke the camels back as f a r as cur relationship
was wncen-ed.
Ever sincethathKpenedwestoFpedcamunicating. matwas
the f i r s t m e i n trying to rescind m y i n p r t a n d m y o m t m l s o f a r a s t h e
campany was c0ncxm-d.
As f a r as the staff was ooncerned they had a feeling
that the staff should be treated as dirt and made this urderstxm3 many times to
me
this is against a l l my philasophy of life. For months, because of this
attitude, Mere were problems with the staff. It was because of this t h a t the
staff didn't respect them, and it was just a formths.
We w e d

section,

July and August, Bab w a s still d m in Atlanta and I was doing


the work i n lancaster. Fmn J a n u a ~
until
~
Januray I took one day off
for Memrial Day, one day for July 4th, one day for labor Day and cme day for
'Ihanksgiving.
Mike H a r t k t t took off two of three becks, leaving m e to tend
the shop.
I was always the care doing all the work, recruiting, stock
offering,labor m a t t e r s , drew up all the amtmcts, drew up the offering
w i t h the help of the attorney. It was fiwry t h a t I was the only one
raising the mney
probably 808 of the furls. I was the only care of the
principals who had outsiders investing i n the canpany. Ihe most they did: Bob
Kauffman raised $5,000 frun his father in law, so not d y did I pit my cwn
mney i n I risked that of my clients. But they w e r e willing to a a q t t h a t up
front.
A carple times it came down to either me getting the m m q fmn my
clients o r us not having the financial a b i l i t y to pay off sane of the capital
resources that we had.
W i n g June,

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.

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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

the nomy, d t e d lnost of the people, p t the offering


together, pit the ampter system tcgether, workedwithall the
ampter softwa??=, and a c t u d l l y . came up with the name Firnncial Management
(;mup and the idea of having a l l the subsidiaries doing different things. My
involvement was very deep, pmbably deeper than anyone in the organization.

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 .
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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

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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.

is May 4 t h a t 4:30 a.m. and there is no d a b t inmyminlwith the articles


in Rolling Stone that we have the money for the m i e . lhat project in itself
w i l l pmbably p t us in the forefront of the n
e
industry within
It

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.

L e t me go back to an earlier developlwt a m c e m h g the E!mker+er.


We of
course thought in the begthat we would becarre ax own broker/dealer.
However, after long, bard discussion, we were to the pint of getting a license
for brokerldealer, we decided we did not have the admhktmtive capacity to
N f i l l what we waild need to a-lish
the broker/dealer. Back in Nwember,
-,
Bcb started soliciting other -/dealer,
l c o k h ~for
~ three things;
service, high pay cut, and
equity.
We knew that we had t o own our
brolerldealer kusiness.
'Ihere were two players that we came a
m one was
Iiikkml-m cut of wshhqhl DC and the other was Financial P l a m e ? s Group
which really involves sane of the premier financial planners of the cumtry,
B i l l I b q l e r , Wayne Webster, so on and so forth.

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.

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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
-

the transformation of licensing fmpn FSC to Hilhxd-Bnmn and we


prcbably had 60% to 70% of the in house w l e to FSC, Alan Inss, Scott
Robertsan, Rich Bravenuan, Keith Waters, R x M Dellinger, Kazly Radcliffe, along
with Barry Schuttler and sapne of the other satelites. A t this point Tan 'I\uner
was free ard clear and he was looking for scsne direction. By the week of A p r i l
19th
Tcm was up v i s i t k g with Bob all week seeking that direction and he was
also visiting w i t h Hibbard Bnmn so it looked l i k e Tan wculd also b e a m
involved.
We began

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

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EXPANDED EOAIlD METIKG


May 5, 1987

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

~~

Week article on conveniexe Wtxies largest


1. S t a n graJth in5mtry for next ten years. Financial Management Group is
a wnvenience i d w t z y .

Mortgage Ebmkerage contacts leading to distressed properties


symiication pxsibilities. Ccmercial -y
located from insumwe
Accamt
fram
$2,000,000 and up.
capmies and Savings and Ioans.
2.

3.

Eawie.

4.

McCormick.

Raise $4,000,000.

Tony Bongiwi.

Sports figure fjnancial planning

in retum for

agents contracts.
Service

B.

IFS. DyMtwownedby IFS. Barry Schuttlers IFS enhancement.


wants to design a system which would coordinate all three of
the above. ISIS developent w e l l under way. XM Ray reports c q y
w r i t e mrk done for llEkrsanal BrokerI1 software. C o s t approximate
$10,000 per site. $100 per month maintain fee for s a t e l l i t e distri1.

Stan

bution.
C.

T h i n g Service; Ken Ray


1. Monitors mutual M offering switch protections done for both
stocks and mutual funds. 1/2 of 1% fee charge.

1. Express the p t e n t i a l for linking Dynatax t o IFS for benefits of


coordinating tax preparation an3 client review.
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1.

ming w e l l .

Good

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profit scurce.

1. mkhg book for us to cutline licensing procedures,


a ~ l i c a t i a n s ,insurance canpany information.

A.

Bab Kauffmn raises question: Shcmld F h i a l Mmgement


be
~withachievingequitycninsurancebusinessinex~e
for v o l m ? Shaild we limit the nrmber of c a p a n i s ?
1. ShGild we ,py htere&d in reinsmame program.
risks.

a.
b.

2.

Down side

Limit planners -on


of objectivity.
harder to s e l l FIG i n the firture because of latent
l i a b i l i t y &e to losses extending fnmn lass of business
and adverse insumme risk.

Mi.&

VoteOutcoPne-Notto~auSel~e~with~hSXaXx2.

Retain cur objectivity.

1. Eemett W i l 1 k m - s prqject.

1.6 million needed.

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.

Third Circuit 15-3400


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Barry has a m t a n t , attorney, mortgage broker, insurance


agency an3 real estate a f f i l i ates....nwving along well.

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a.

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W e are lwkhg to develop a Harrishmg office which could


include F e t e r Labella, Davidwn and Valencia and a miscellanecxls grarp of brakers caning fnxn E.F. Hutton and Merrill
Lynch.

b.

3.

A.

Frojected time frame six months away.


for offices.

Olrrently looking

Reading, FFmSylMnia
a.

Rich Podlasek. Close to recruiting Bob Caukins. Reports


of a large grcllp of
.I people m t l y w i t h Hackett
-/Dealer.

a.

Jerry try*

to recruit Bab JWmxe and Ben Clements

Report on trip to HBC

1. Barry Schttler; no problems e m z m t a d thus far that he h m s


of.
2. Jerry Bmrero; HBC staff is themajorpmblemarea. IXle
Diligence L&prbmt is very week. Pmducb
to be available
kut is light.
3. KenRay; H B C l a c k s ~ i e w e d t r a d e r s . OaYzrnedabartHBC
being unable to serve the brokers business. Wants a detailed
p-of
howtorectify~~ctradingpmblemswithatimeframe
for capletion.

4. Questicm. ShaildwestaywithHBCorreapencnxsearchfor
alternatives?

a.

Third Circuit 15-3400


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Decision. Tu work
inthreemonths.

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K E N N E PROPERTY
~Y
CORPORAT~ON
A Subsidiaw of Kennedy Health Cars Foundation

May 6, 1987

Mr. Stan Caterbone


1755 Oregon Pike
Lancaster, Pennsylvania 17601
Dear Stan:
This correspondence is to address our previous conversations
regarding the refinancing of some commercial real estate that I
am currently managing for Kennedy Property Corporation. At that
time, you had requested information on each of the buildings so
as to determine the feasability of this endeavor.
Of the four properties listed, three are owned by Kennedy
Property Corporation and the fourth is owned by Professional
Medical Management, Inc. Both companies are subsidiaries of the
Kennedy Health Care Foundation.
Enclosed you will find a description on each property. This is
accompanied by the current lease schedule for each property and
an income statement for Kennedy Property Corporation.
If after reviewing this package you believe that favorable fixed
terms can be provided, please contact me at your earliest
convenience.
Sincerely,

Michael Lawson
Property Manager
ML/~
Enclosures

Third Circuit 15-3400P.O.Box 1015 ' 100 Egg Harbor


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MICHAEL LAWSON
Property Manager
P.O. rn 101s
im E Q nubor
~
M.
1wmn.Il..
WJ mot1

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Richard P. Sllva, CLU


Regonal D~rector

May 12, 1987

Mr. Stan Caterbone


Financial Management Group, Ltd.
Eden Park I1
1755 Oregon Pike
Lancaster, PA
17601
Dear Stan:
Per our conversation I think it is important that I shift the responsibility for contact to you. As I stated my time is as valuable as yours
and I cannot justify continual contact without a reciprocal effort.
Should you choose to access Alexander Hamilton Life as a general agent
for maximum support and compensation I will be more than happy to discuss this with you, however I do not feel that we should pursue any
conversation until you are in a position to make a definitive commitment.

Richard P. Silva, CLU


jah

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In atterdance: Mike Hartlett


Bab Kauffman

m m

Alan Loss
Absent:

Stan Caterbone
Concern wer relationship with Hib$ard

W O N :

I.

BraJn

Corp.

as a Ebmkr/Dealer.

Should Financial Management Group (FM;) be affiliated with them.

p5TING OPENED BY BDB IGWmMAN


A.

LDok a t all d o n s .
1.

Wty. Hihbard BImm Corp. (HBC) waild offer 20%ownership in


the Bmker/Dealer and 24%of UCC. (The parent). 'Ihe UCC stock
is to be used for national recruiting who would not be directly
awned by FIG, kR FM; would have partial clwnership.

3.

High degree of input into w r p r a t e decisions.


sst on the board.

4.

We waild have a

'Ihey inlicated that they should be able to service our

business.
B.

Risk i f we leave HBC.


1.

'Ihe core of planning shqs in the n a t i d wrpbratian auild be


i n danger due to their decision to stay where they are as

opposed to mning w i t h FM;.


2.

3.
C.

'ItyO

R k e n t h l loss of revae. FM; could lose $1,000,000 in G U if


Schutler,
(as an individual), Rdlasek, and Tucker would
not cane along. lhis wnuld result in a loss of reverrue of at
least $5,000 per month, $60,000 per year.

of leverage when M i n g w i t h a &oker/Dealer.


risks i f we stav w i t h HBC.

1.

'Ihey do not service our business - we wculd lose people due to


poor servics and lack of responsiveness.

2.

We would not build our hiness as fast as we would like to.

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!Be board aarees to divide the issues into

1.

mvoteonwheulertostaywithHBC.

2.

Tu loak a t other &oker/bder

two rarts.

@CUE.

Are we m i n g fozward o r backward and is the Broker/Dader


going to help help us o r hurt us and for
lcmg?

Bob Long;

Bob K a u f m ; Can we continue cur tusiness day to day? Y e s . But it


w i l l r q u i r e mre of a x daily inpt and personal managenm-lt.

BobKauffman; mlathashappenedinthelasttendaystochan@the
boards decision t h a t ms reached in the extended
dated May 5, 1987.

Alan Ioss;

Gave perspective of joint meeting in Maryland. Was


amcemed about the lack of cammication between Fete
Hibbard and Rick Fwcm. H e f e l t there was alot of
disorginization w i t h HEC but ci-~a positive note he feels
like they wanted to work things cut.

E3Zb Umg;

Indicated that he sees the securities area as k i n g the


focal point of our pmblem. He doesn't perceive there
to be a servicing pmblan w i t h M u t u a l FU%~.S,Annuities,
etc.

Alan

Again poses w o n ; Do we have other alternatives to a


Braker/Dealer?

k6.S;

Bob Kauffman; Y e s , we have Planner Securities C;roup (PSG), Financial


Service Corporation (FSC), an3 Integrated Rsowces.

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;

Mike Iiartlett; Basic question is where are our priorities? Do we want

.
Bob KaufBnm:

maxinun service o r maxinun equity participation.

reason for o w choice of HEC was in direct response


to our stock brokers not wanting to leave Secwities

(Xlr

setuemerrt Cow. (SSC)

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What is

mostimportant.

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Management Group, LTD


,

111-

Omgon Pike Lancashr, M 17601 717-569-5555

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.

wfw you are finished

I lock forxmd to hearing frcw ycu.

Stanley J. cat333xme

President
SJC: lmk

cc: file
Robert J. BeNer, Jr.

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BENNET WILLIAMS / SYNDICATION

11. Services and functions of FtG, Ltd.


FtG I and Bennet Williams
111. Structure of Syndication

IV.
V.

Costs of Syndication +Financial S e


4krwd-t d :lIh m s
Financial Senrice Center

Third Circuit 15-3400


Property of Advance Media Group

m6.

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center

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

SCOPE OF

Section 3189 Federal False Claim Act

Page: 292

Date Filed: 11/18/2015

m s m

The following is a proposal to Bennet Williams, Inc. to pmvide the


syndication and marketing of the 1.5 million office building to be constructed
i
n downtown York, PA.
This proposal is an attempt to describe the role and
function of Financial Management Group, LTD (FMG), the Syndicator, Bennet
Williams, Inc. the General Partners and FMG I the Limited Partnership.
The purpose of the project is to raise the necessary capital
approximately 1.5 million (excluding syndication fees) and to m g e the
partnership through its, tirety until it is dissolved. As per previous
prcceeds
conversations, the b u i l g i l l be fumle3 conpletely f- pwithout using and debt, 'ch will provide a steady stream of income, projected
to be between 9% - 12%,dth the possibility of refinaxing the project around
the seventh year i
n order to return the original capital back to the investors.
L-

that

FMG will also consider developing a Financial Sexvice Center, similar to


wkj,
r-n.~ts & - > k c * .
WLCI'LC B - L +
U:((?-I WilL b C

icka d d i
yorh.

Third Circuit 15-3400


Property of Advance Media Group

:<

~ I G Y C I

'

JCQ,C

-b-u.rj/lw c r p , n

Page 291 of 806


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eY

7)

~ A L Q~

-J-

( l Ci

U L S ~ ~ C T

~ j $ ~6,~r1 1 n c s r

Wednesday, November 18, 2015


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

11.

Document: 003112132545

FUNCTION OF

BENNGT WILmmE

Page: 293

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

- mE GENEmL PARmEE

(G.P.)

The General Partner (GP) w i l l be responsible f o r the folliwing:

A).

B).

C)

D).

Development - The G.P. w i l l be responsible f o r a l l development


involved in the project.
construction

- The G.P.

w i l l be r e s p n s i b l e f o r all construction

phases associated w i t h the project.

Leasing All leasing r e q m n s i b i l i t i e s w i l l be of the G.P.


The
G.P. w i l l have the task of obtaining 100% occupancy of t h e building
in a reasonable and timely fashion. The G.P. w i l l also be
r e s p n s i b l e f o r determining the f a i r market value of the space
and f o r a t t r a c t i n g a t t r a c t i v e tenants w i t h favorable leasing
agreements t o maintain a favorable and healthy cash flaw.

Management - Tne G.P. w i l l be rspmsible f o r the rcanagement of


both tenants and the building in order t o obtain maximum

appreeiati-+the-proje&-forAuhrcprofib
fukre

Third Circuit 15-3400


Property of Advance Media Group

/I'

r c c : A ; o - yiven

Guersbte

Page 292 of 806


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\ n co me
~ C . , - . O ~ C L

co cd;

h o e 5-

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

11.

Document: 003112132545

FUNCTION OF

BENNGT WILmmE

Page: 294

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

- mE GENEmL PARmEE

(G.P.)

The General Partner (GP) w i l l be responsible f o r the folliwing:

A).

B).

C)

D).

Development - The G.P. w i l l be responsible f o r a l l development


involved in the project.
construction

- The G.P.

w i l l be r e s p n s i b l e f o r all construction

phases associated w i t h the project.

Leasing All leasing r e q m n s i b i l i t i e s w i l l be of the G.P.


The
G.P. w i l l have the task of obtaining 100% occupancy of t h e building
in a reasonable and timely fashion. The G.P. w i l l also be
r e s p n s i b l e f o r determining the f a i r market value of the space
and f o r a t t r a c t i n g a t t r a c t i v e tenants w i t h favorable leasing
agreements t o maintain a favorable and healthy cash flaw.

Management - Tne G.P. w i l l be rspmsible f o r the rcanagement of


both tenants and the building in order t o obtain maximum

appreeiati-+the-proje&-forAuhrcprofib
fukre

Third Circuit 15-3400


Property of Advance Media Group

/I'

r c c : A ; o - yiven

Guersbte

Page 293 of 806


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\ n co me
~ C . , - . O ~ C L

co cd;

h o e 5-

Wednesday, November 18, 2015


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 295

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

'Ihe follaiing is a description of the structure of the partnership. ?he


Partnership w i l l be registered by the Securities and Exchange Carranission a s a
Private Placement Regulation D, W e 144 Offering. ?his w i l l limit the number
of investors t o 35.
A

Bennet Williams Inc.

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 :

Third Circuit 15-3400


Property of Advance Media Group

75%
75%of N e t Proceeds
88% of: a h go- )-+a acb-l d e v c l y ~ c ~ t .

Page 294 of 806


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Case: 15-3400

Document: 003112132545

Page: 296

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

IV. COST AND FEES

m , ~ t d . w i l l receive
of the
-,1;?n~associated with

capital raised in order to perfom the


the project.
This includes all legal,
accounting a n d m & % i n g fundions needed.

necessary

cd ;,la f l c o c L - ~
w i l l go in;*

y a c

77

/jlThis means approximately 88%of the-&capital


This
includes
a
l
l
legal,
accounting,
printing, wketing, e+mc of
W
i
p
u -(
b " ' & & @ ~ i ~ -h-tt,r;,
ht-io. $(\L pJrLVM
W:LI
hC
-the ' * o l t i ' u ~ ~ k e ~a~,IbU~ Je ~ ,,?L ~~ ~ " ~ b - j .
11' I

Third Circuit 15-3400


Property of Advance Media Group

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Case: 15-3400

Document: 003112132545

Page: 297

FEiANCIAL SERVICE

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

cmmm

Financial Management Group,


will
t o develop a Financial
Service Center similar t o the lancaster Office in the building being
syndicated.
FMG has develop a N1 Service Financial Center that provides a l l
of
the relative services necessary t o manage the financial a f f a i r s of
individuals,
businesses and institutions.
The Center w i l l include the
following sevices:
1.

Financial Planning

2.

Investwrit and Portfolio Management

3.

Accounting and Tax Preparation

4.

R e a l Estate Services

5.

Legdl Services

6.

msrance services

7. Inves-t

and Mortgage Banking

Financial Management Group, LTD w i l l structure the Center similar t o that


of the Iancaster location w i t h the exception t h a t Bennet W i l l i a m s w i l l have a
role in the formation and the operation of the Center. F E w i l l provide the
recruiting and m g e m e n t of the operation and w i l l use the current system
that have keen developed and used in Lancaster.
me ownership w i l l be
structurd among FMG, Bennet W i l l i a m s , and the other Major Players that wish t o
get involved.
Enclosed is an original Business Plan that outlines the concept
in
m e
detail.

Third Circuit 15-3400


Property of Advance Media Group

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Case: 15-3400

Document: 003112132545

Page: 298

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

HIBBARD BROWN

&COMPANY,INC.

May 11, 1987

Mr. Stan Caterbone


Financial Management Group, Ltd.
Eden Park I1
1755 Oregon Pike
Lancaster, Pennsylvania 17601
Dear Stan:
It appears as though we keep missing each other on the
phone. This is a short note just to advise you that I am sending
up a list of the standard items that we request when we do due
diligence on a private placement.
The reason for my wanting to contact you before sending this
list is that at the present time I am unsure of the structure and
nature of the offering.
I would like you to provide me with the
following:
1. Who is the General Partner?
2. Has counsel for the partnership been chosen? (If not, I
would prefer to make a recommendation to insure speed in
completion of the documents.)

3.
What is the structure of the offering (public, private,
Reg D, 504, 5 or 6)?
4.

Has an independent accountant been obtained?

5.

Is it your intention to take down the whole deal?

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

Third Circuit 15-3400

M e n h ~ rSlfC

Property of Advance Media Group

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Document: 003112132545

Page: 299

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

7855 Walker Drive


Suite 620
Greenbelt. Mayland 20770
(301)220.0111

May 11, 1987

Mr. Stan Caterbone


Financial Management Group, Ltd.
Eden Park I1
1755 Oregon Pike
Lancaster, Pennsylvania 17601
Dear Stan:

I was unable to reach you today by phone, but felt immediate


communication was important enough to enclose this short note in
a Federal Express package already being sent to your offices.
I

I became fully aware of your proposed date to have the York


Private Placement on the street at our joint meeting Friday of
last week.

Having put together several private placements, I am sure


that we can meet this deadline, if we coordinate our activities.

I look forward to hearing from you as soon as possible.


Sincerely,

President

Third Circuit 15-3400


Property of Advance Media Group

UNIVERSAL

"."

Page 298 of 806


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Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 300

Page 299 of 806


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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 301

Page 300 of 806


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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 302

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

May 14, 1987

Mr. Peter Kit$ard


~Brown&Ccnpvvly

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

Third Circuit 15-3400


Property of Advance Media Group

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Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 303

Page 302 of 806


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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 304

Page 303 of 806


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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 305

SC'IDCO PRODUCTS GO.-4Contmued)


mlas!.c

Consumer Video RWUZUh v . (I)

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

~.l.r:

.-

.87CO1I

Coml%nen!alFtbre Drum (1)


R?. mtr. 18% P--.v

0M.lo":

.
I t M I I

Consumer S.kLhv. (1)


15 E-.
Rd

10" V.P. 4 G.n W.)


-t,.

l e a . Packaging. Inc. (1)


P C 00. AB
C d r r mm a 9
1.1. -73-35
F'rCl,"*Ssnrt*e
-Is
G M Sum i. t n Urn,

-.

kt--

-.

PVVM.1007652
T*: 10l.360.Ym

*Suam(RnJ

.I-

(I)

(rdo"2l

R.,I,O.d

s.1.c:

4011

fa"" O r r &x. O l h x l

D. M. D".ry

R. C G - % ~ .

0 Wax 428
SUI.rmlk. m: 2 8 6 n
'*I. 701412.7424
wart. P W
4

So3 line RaGlroed Cornpan

P.O. Boa 530. MO Soo ~ r r L %


Mnnrmb. MN 5 % ~
Tm: 6 1 1 . 3 ~ 7 d w o
w
a
r su.:%,7.030.000
EW. 7 x 0

.tMI1

Paper Stak Dealer.. Inc. (1)

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

R.. SU.

em

Usnena. GA -7
F h . sums

5.1.c: 3079
7 C C.mm

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

m.511

0b.r

a,m

~o.,Oom

SORG PRINTING CO.


~
111 8 t h Avo.
New York. NY 10011
Tel.: 212-741-6600
~

L Narrih.1

NY

SOR W O T C )

CCmpDnent PIOM~IS Lhv. ()I


9 w 57m sr

.(MI5

.. -. ....

E m 490

9s.: 166.544.272

-OX.

~r r a . NV I ~ I S
li.nn F m IR.rI

F,scaI Yearend: 5131186


mnun of Fwmlal. Cqmrsle. m
~eg.1
uments aria Forms
S.1.C: 2751: 3555: 2752
Galben B Soro n7nm ad
-., I
Roy A. Cardi;(&es.)
Harold Cmney I E x w V P . 6 SKI

Boc

l .no

Johnh MonNUI

Sow Magnetic RoduOI Co. (1)


t.-

SONV CORPORATION OF AMERICA


(Wholly-Owned Sub. of Sony Corp.. Tokyo.

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

S.I.C.: 3679: 3651: W:


5065
N n o Ohga (Uun Bd.)
Kenp T s v a (Chm 6 -1
EJT 0111cer)
Nw' Vander Dusren (Rar 6 Chel Opn, On-)
V ~ z h a dE a r (EIBC. V P.&)
Flben h l l s n (Exec V P)
Kocht Twnda (Exec. V.P.+s.
6 E m )
John Slerr. (Sr V P - H v m n RewnrcnJ
J Ph8l.p SUci 19
. VPJ
Kennelh Nees ( V P 4
. Sec)
Chns Wab. N P G M . Refs 1
F.a.l* LEMn W P 6 Gen Cnnrrer)

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-.
~

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.)

r S e x Mlg. Co.. Inc. (I)


51.
EhaDClh NJ O7X16
T*. 201.3552110
C1.c~
2651

.'"(U1

107 1,-l

C o m r n u ~ ~ ~ at M
, . )s

Third Circuit 15-3400

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-)

mlrrr,

Y a u a b TUV*I W.P. 6 dma;.)

Property of Advance Media Group

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

Page 304 of 806


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(100%)

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Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 306

Page 305 of 806


Page 2251 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 307

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

socpe of Pmject

m k e t i r g and Distrikution

Financial Prcposdl

amtracts

Third Circuit 15-3400


Property of Advance Media Group

Page 306 of 806


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

'Ibny m i m i

Date Filed: 11/18/2015

is about to undertake one of the

and F t x e r Station

~roiectsin the entertairmrent irdusby that the Business World

mast

has wer seen.

Ihe fascirratbq elements of

A).

Wical Overtcn=s

B).

~ 1 o g y

.
D).
C)

this project are as follows:

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

all of the abwe elaoents tog-

have a vezy s t r a g and paJerN entity.


' of the largest ard mDst visible

Section 3189 Federal False Claim Act

Page: 308

Naw, prt the abwe elements in o m

htertairmrent

W i e s available ---the

-.

We want to pcsitim Scmy as the primier ~a~


EsuipPent
Vi&o

of P r o f e s s i d

in both the RemrdIndustryardalsotheTbeatricaland

B3ushy as s e l l as Television arrd Pay T.V..

In additicm and even uore

inportant we waiid like to credit Scny w i t h omtrihtiq in the develcpnent of

the Scny-

Digital

Ren,rdiq System that w i l l recoFprized

World by way of several different medium e q c s u s .

the

lhis will have

effeds in the bay of jmreasd sales in both the C l x m m e r m level as well

as the Professianl E n v i s m e n t .

Third Circuit 15-3400


Property of Advance Media Group

Page 307 of 806


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 309

Date Filed: 11/18/2015

In the f o l l d q paragraFhs I w i l l address the abzwe elements an3 pmve

to-rt

thepcrtential for this project.

wa,s developed to help Wmy

'Ihe m v i e

in

Marts

the

hdustry to captxre ather k d w b y ' s that are

- theatrical, televisicn an3 cable, video,

aanplimentary

rmsic

mi6 take his mtive ard &us

el&cs

aocanplishents in both -logy

Wmy's. track reond ard

of

Because
~

an3 nusical prducticn

aE

Dmy has used the s a nusical


~
format for their f i r s t a l k m as he used

hasI
sold nine millicn alhms thus far
for Bn Jwi, *&

- Bon Jovi!

of his latest band French

film already will have appeal t h r u q h the fed-

Lick.

intennticenl film ard

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

the timirg of the a l h x m - w b i d l w i l l

the two sbaild anl w i l l ccnpliment ane another vezy

'Ib further the mrktzbility of the picture he w r a p d

profitably!

horror script

'Ib add

the

okritiffil"

Minfluencing the audiences.

the f i r s t wvie ever w i t h a

finther to the project, Tcny w i l l

digital sand txack fran set to theatre arrl video.


mst

this into a

- w i d e s t mrketability due to intennticanl d k k i h t i c n - an3

that will plwerrt

an

aaninate the

anyme else 190% of

This tectylology a l e wmld

the total budget just for the s a d prrducticn.

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

Third Circuit 15-3400

the te&nicdl

r l i s t r ~ a nsbaild be pxerful

mrventianl
deals.
Property
of Advance Media Group

Page 308 of 806


Page 2254 of 2953

arr3 the

elacne

in even the

'

the
,
nost

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

lmxEmxz AND

Section 3189 Federal False Claim Act

Page: 310

Date Filed: 11/18/2015

DlsTmmrION

Ncw lets take this project and look at it with 5-:

to biu e1eQmt.s:

a ) . Video
b)

T h e vi-

utren

yrxl

D i g i t a l r6mrd.k~ard playiq

inaustry is a 56 billion dollar

'

' ,'

y that

is in need of product.

lmk a t the patentidl for a prcduct that w i l l be the first a d a d

prduct that will canpliment the fast paced


w i t h a rmsical

-re

~~Fsltertainmet

that m y have emmgh d t s of its am-ym

have an

arnazirg p b m t i a l for d i s t r M m ! !

- )

D i g i t a l an3 D i s c Irduslq has p

mrdi.rq ard playing in due time.

m to be the fuhrre standard for


Because of its newness, there are nore

m l e wfao have yet to hear the digital sm-d. Because of the visibility and

exposure that will cane fron this project-this

a u l d be the first time ever

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-.

Third Circuit 15-3400


Property of Advance Media Group

Page 309 of 806


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Case: 15-3400

W
e a

Document: 003112132545

Page: 311

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

d likesmytocarnait fifteenmillion f o r t h r e e t o fcur future products

that will follm t h e s a n r e f o m t a s t h e ~ ~ ~ s o t h a t ' l t m y ~


sCply

w i l l p i t i o n tharselves as the picmeer ard leaders in the

-.

lhis

will mt allcu onpsitim t o gain assets to the marketplaoe until ue are a l l

fkmly situated ard profitable.

We w i l l also assist in any way possible in the

of the theatrical

an3 video distriialtim.

Third Circuit 15-3400


Property of Advance Media Group

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 312

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

a 60 scxrd spot in the beginning of the video, ve will do


.Smy

d its r m t r W c m s to the Digital lY&stry and the differa-ce be-

a m v e n t i d and digital recordirq.

I.

The

spot will be a ~xzme-my w i t h nusic fmn Rpncfi Lick inthe

&
-

'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

cur pint the

pmrzss by uhid-l the FURE SaMD IS develcpaa. To


"Differern= '&st"

will be used.

'Ihe

mnreie

M?NCP1 will be pmnoted as

the~FeatmeFilmtousethisSystem.

11.

WEW#I

We w i l l
Sciy

a mxdmxlking canpign us-

rarket a N1 line of

the v i c b , (similar to Wp (amet),

KMGSlNTCN

w.

will offer a l m k d g e t h t profitable disc player to a l l

the video.

?he offer w i l l

be a t wholesale pri-.

of

Ihe reason for

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!

Far Scny it w i l l a-tically


tedYlical aazmplkhmmts

inskute that Scny is -ible

fran the view of the audiervz

for TcPry's

- drich lby will

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
-

We w i l l alsn develcp a -60" scxrd spat to be used on telwision to p

p t i m project for both

Third Circuit 15-3400


Property of Advance Media Group

Saty ard Tcmy

m the

Eaqiovi.

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Case: 15-3400

m. we

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 313

Date Filed: 11/18/2015

will also include s a y EquipnerrtinthePSlMSSystemsthatwillbe

n e w to convert the Theatres to the New Sand System.


T%atres

We w i l l amvert the

Free if the lheatre d t s to d-wdrq the next'MReElXNGIOVI

SSXKTIW.

This will give us a guaranteed ccPhirrued sqasure ard w i l l give

us guaranteed distritution for both

Say

Software an3 m j w i as.

We

will recwer the true casts of ecNA~7t


fran distrihtion profits frcrm the

films.

N.

We w i l l prochvm a 60 seaad stard alone cnmexial for television, cable

arrl theatre that will be used to pramte the project before the release of

mtant Mania.

--

eg\; A 60 seaad spot utilizing the follubq elements


1

a.

Frencfi \lick

b.

Rmx Station r e o o facility


~

c.

Sony8s r m t r i t u t m s to the mmufacturer of the equip=& to prcduce

thescum3.

A spat

'Ihismay sim~"~thedifferenoe**.

R-errfi Lick recording in Rxer Staticn for the -Mania

h e .

W e warld like to

to yu.~the Say/psa--give

"Now sit back ard let UE J a w i f

ycll

hpxt cn w h t it is.

he&- the difference."

p
t warld you rather listed to when 1-

to feature film: video, cable

or television.
Third Circuit 15-3400
Property of Advance Media Group

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Case: 15-3400

Document: 003112132545

Page: 314

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

ImFaLWJISING DEAL

Scmy will private label a "Tay E!mqiwinor

Statim line of e&prent:

a ) . Wevisim
b).

-S

ccnpahlent

c). Disc Player


d)

ViaeD Player

'Ihe above package w i l l include a free video

rebate f u l l price back to

--

of Mutarrt Wwda of whi&

Say

will

distritution.

' ' l b y arrl Stan will m i v e credits for complete line:

'lbtd will

be negotiated aftex we have an idea of Smy margins.

We want

touakeucmeyonlyif Sonymakesnmq!

W e w i l l also provide a m a r k e m package for a l l retail artlets that i


s naw

-m.

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Property of Advance Media Group

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Case: 15-3400

Document: 003112132545

Page: 315

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

xwxive nQeditswon all video, theatrical, telwisicn, and

cable ~ ~ / s C SystemT
n y

l i n y ard Stan will also ~ v e ~ t s c n a l l s y s t a n s u s i n g ~


sold to other film stw3ic6

- Also to be e

d after w
i
n
s are figured.

the x e s a q quiprmt in all shdios. We w i l l pmvide a one day seminar to

thirty cp2J7ators of the largest theatre

Third Circuit 15-3400


Property of Advance Media Group

-.

Page 314 of 806


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Case: 15-3400

I.

Document: 003112132545

Page: 316

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

to help pxduce the spat

am3willallwreimbursaaentforcmlytruecostswithn>mkeup
e
.
x
l
wa l l of Tony's time ~&

11.

w i l l be free.

Rwet Staticn ard Rwet Productims I will receive a negotiated

w-

age of pzpfits fran all profits gwerated from the m x d m d i z i n g

e~

of the Scllypmdcck ard the sale thatmay result to other film st&ios
UtilizhqScllyequipoerRintheINSSystem.

m.
-\

W e will receive three sets of a full entertainment system

- 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

wets for theatrical, video, cable, and telwision qnticaticms.

We

willprcmiSenottOeventalkto~else~uefeelthatScnyis

not gokg to offer a fair and reasamble deal. W e w i l l give Scny a 5%

margin to gain a cmpetitive edge.

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='=F=F'==
m

Thy

Document: 003112132545

Page: 317

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

of the abave and all aspects of this Dedl is to let the

entities involved maximize their profits for their m

in film an3 nusic prakcticsl d

Scmy

distrihutim of both equiprent a d

e talents;

in mnufacturirq and wentxally


and later video and film

m m m .

Wid side mrkethg available after this pi*

thruqh chamrld anl =ia.

S a y w i l l b e o n m x d t s of the filmmrldwide BUS?

Rwer Staticm Digital to be shared with BIXS?

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Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 318

JOINT VEKPURE PAKTICIPATICN

AM)

Date Filed: 11/18/2015

C~RIBVTICN

The undersigned, intending to be l e g a l l y b o d , i n consideration o f h i s


&ssicn

as a p a r t i c i p a n t in the j o i n t v e n t u r e t o be known a s "POWER PRO-

DUCTIONS I" md r e c e i p t o f a p r o f i t / l o s s d i s t r i b u t i o n share o f

% of

such j o i n t venture, hereby d e c l a r e s ard ackmwledges h i s i n t e n t to p a r t i c i p a t e


i n such j o i n t venture and hereby m e n a n t s and agrees to contribute the sun of

t~ t h e c a p i t a l of such j o i n t venture, which sum s h a l l c o n s t i t u t e

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

s h a l l receive f u l l repayment o f i t s investment from


MVPRNIA PROWCTIONS, I N C .

b e f o r e the d i s t r i b u t i o n o f

any p f i t s to any party. Thereafter, t h e j o i n t venture


s h a l l r e c e i v e 50% o f t h e p r o f i t s from such motion
p i c t u r e , o f which 85% s h a l l be d i s t r i b u t e d to t h e

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Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 319

Date Filed: 11/18/2015

non-managing j o i n t v e n t u r e r s ( i n c l u 6 i i - q t h e unders i g n e d ) and 15% s h a l l b e d i s t r i b u t e d to S t a n l e y J.


C a t e r b o n e a s t h e Ranaging J o i n t V e n t u r e r o f Power
P r o d u c t i o n s I. The j o i n t v e n t u r e s h a l l have a r i g h t o f

first r e f u s a l to finance t h e next movie p r o d u c t i o n o f


MUl'ANIA PROWCTICNS , TNC. and/or 'XNY EXNGIOVI

The Lndersigned a g r e e s t h a t he w i l l execute an3 d e l i v e r a counterc o u n t e r p a r t o f t h e j o i n t v e n t u r e agreement (which s h a l l be c o n s i s t e n t with t h e


a b o v e g e n e r a l u n d e r s t a n d i n g ) and t h a t h e w i l l execute and del'iver all docw n t s required f o r t h e j o i n t venture to elect n o t to bF! t a x e d a s a p a r t n e r ship.
Contemporaneous w i t h the execution o f t h i s L e t t e r o f I n t e n t , t h e undersigned is c o n t r i b u t i n g 10% o f h i s t o t a l agreed c o n t r i b u t i o n , or $

'-)
-

W i t h i n f i f t e e n (15) dzys f r a n t h e d a t e hereof, time being o f t h e essence, t h e


-

undersigned s h a l l c o n t r i b u t e t h e 90% balance, or $

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.

I f s u c h n e g o t i a t i o n s , d e l i v e r y , and execution &e not m p l e t e d within

t h i r t y (30) days a f t e r the f u l l c o n t r i b u t i o n is m d e , the e n t i r e c o n t r i b u t i o n ,


with all i n t e r e s t earned thereon, s h a l l be returned to t h e undersigned without

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 ,

i n t e r i m i n v e s t m e n t and management, and ultimate investment or r e t u r n o f a l l

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.

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Case: 15-3400

Document: 003112132545

Page: 320

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

The u n d e r s i g n e d h e r e b y a u t h o r i z e s and e n p k e r s S t a n l e y J. Caterbone to


n e g o t i a t e , e x e c u t e , and d e l i v e r a l l documents n e c e s s a r y or r e q u i r e d t o
implement t h e j o i n t v e n t u r e plr~oseand to take all o t h e r a c t i o n s and n q o t i a t e , e x e c u t e and d e l i v e r a l l o t h e r documents n e c e s s a r y or d e s i r a b l e t o
implement or e f f e c t u a t e the j o i n t v e n t u r e p r p s e .

SIGN
(L.S.) Date: W y

tWE:

-,1987

PRINP
NAME:

STREET

F.

ADDRESS:

STATE:

CITY:

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ZIP:

Wednesday, November 18, 2015


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Document: 003112132545

Page: 321

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

RICHARDC. FOX,PC.
ATTORNEYS AT LAW

1015 ROBERTS VALLEY ROAD

HARRISBURG,PENNSYWANIA inlo
RICHARD c

mx*

('ADMllTED ALSO M R W

May 20, 1987

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.

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250 .OO
8.95

Wednesday, November 18, 2015


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Case: 15-3400

Document: 003112132545

Page: 322

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

FLATBUSH
FIlMS,INC,
May 21, 1987

Mr. Stan Caterbone


Financial Management Group
1755 Oregon Pike
Lancaster, Pa. 17601
Dear Stan:
At your request I've investigated the requirements of the Completion Bond.
Bert Schneiderman of Worldwide Completion Services in New York
has given me a figure of 5$%, excluding contingencies, with a
50% No Claims Bonus. Since Bert also owns BonBon Payroll Service
he has agreed to waive the payroll fee if we use their bonding
service.
Requirements: They need copies of the budget and/or production
board, resumes for the director and producers as well as copies
of their contracts and any other production agreements which
have been completed.
Further they need to know when we will commence principal photography, editing location and if we intend to have a distribution
deal up front.

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.

I understand you're going to Wildwood this weekend. We need to


house a crew of about 60-80, production offices, catering service.
We'd like to get as many free extras as possible and need high
quality promo type giveaways. For screen credit, of course. If
you have any such contact we'll need mutant dolls (500?) and if
you can help bring down location costs that would be great. I'm
talking about beaches, amusements, the pier, parking facilities.
Probablv k 7 ~ ' l . jh?r,-?:e t h ? t '- '.-; r e:.:t w e e k m e n w e czn talk in ..
- 1

person.
Third Circuit 15-3400
Property of Advance Media Group

4334 STERN
AVE..
H E806
RMAN
Page
321S of
1818)
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Page: 323

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Leave f o r New J e r s e y i n t h e morning. D i s c u s s


s c r i p t and budget.
Meet Mayor o f Wildwood and b r i n g him a s y n o p s i s
o f s c r i p t which h e h a s r e q u e s t e d .
M e e t w i t h Steve Garelick, t h e P r o d u c t i o n Coordin b t o r o f t h e N e w J e r s e y F i l m Commission.
Look a t l o c a t i o n s .

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

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c c : Media
S t Group
an Caterbone
Rarhara

PO+-T<

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Management Group, LTD


Oregon Pike

Lancarter. PA 17601

717-569-5555

Table O f Contents

)
.

Section I

Financial MaMgement

Section I1

The Project

Section 111

Distribution and Structure

Section IV

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Bart>ara Peters: D i r e c b r / W r i t e r / P r m h c e r

Barbara has directed many prograros such as "Matt Hcuston"! "Falcnn


an3 Iacey', , "Misfits", "-erst',
and l'Remulgton
Steele" to name a few. The film Barbara direct63 that convince3 Tony t o
hire her for this production was "Hummids Frau The Deepw. Mrmanoids w a s
made in 1978 for $ 980,000 ($ 20,000 under w
e
t and f a r days ahead of
schedule) and gmssed over $28 million in danestic and foreign theatrical
Sales. T h i s was
a period in time when the video market was in its
early stages of ~~~~t. A film released today that would gross $ 28
million i n 1978 dollars has wen greater putential for a much highex gross
w i t h the strong video market that is available now. What i n p m Tony
the most with E?a&aa1s
direction of IEsMnoids was her a b i l i t y to bring a
high degree of quality to a film on SG& a limited hdget.
Crest1', " C a q n q

6urw

Peter H o c k : Stunt Coordinator/Actor/Wmtmn


Peter's &ts
include f i l m such as, - 1
Places", "Stepford
Wives", "To K i l l A Cop", " G h c s t Bustersw, "FX", and a host of other Films,
Broadway, Musicals and Television Shows.
?here are many factors which mnixibute to a projects success. If you
w e r e t o take a cross section of themovie industzy to find w h i c h types of
projects w e r e most likely t o succeed, you waild find that w i e s in the
two to four million dollar range have rmch greatex chances of success than
wies in the ten to fifteen million dollar range. T h e reasons for this
are quite simple. A movie in the two to four million dollar range is a
hi@ enough budget t o produce a quality film but limiting the r i s k t o the
investor since it needs less of the market share to prcduce a profit.

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.

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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.

It is a very naturdL progression for a recording studio such as Fuder


Station t o evolve into an entertainment ccsnplex vhich includes the
production of films. Ewder Station currently has financing in place f o r a
$ 3.5 million video mix studio to be built next t o the recording studio.
Distrjlxltion ccwpanies are constantly looking for new scures of prcduct
to market. W i t h Bongiari's track record in the entertainment industry,
any product that carries the Bongiwi label should create a bic?dq
situation w i t h the distributors.
Advanced p b l i c relations work is cun-ently being done to set the stage
for negotiations w i t h the distribution companies. "BilIlxxmlt1, lVarietyll,
and "Box Office" have a
w
l
agreed to do articles on Bongiovi and the
mie. On April 30, ABC w i l l be airing a radio talk s h w w i t h Bongiovi
that w i l l air on 2300 stations to a total listening awiience of uver six
million people. "Fame, Fortune, and Romnce" have also agreed t o give

network 'N average.

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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.

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Mependently praiuced motion pictures are a better investment tcday

than ever before.

1) Irmeased FBrkets: T h e r e is much wider distribution of motion


p i d a r e s today than ever before (i.e. Pay TV, Cable TV,
videmassettes, satellite transmissions, etc. )
I P r e s a l e 1 contracts which bind the buyers (i-e. networks, pay W ,
foreign distributors, etc. ) to specific payments a t a future date,
this insuring return of capital and, in same cases, a profit before
the film is released.

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

out of the pmducerls end.

Ihe producer secures the services of a director, principal actors,

and a writex.
Presale Deals:

me producer can negotiate presdle (preproduction) arrangements w i t h


distrilmto~~
networks,
,
pay TV, merchandisers, etc. Whereas such
a?=rarqements can minimize the d-ide
risk, they can also mit
the eventual profitability of the film.
Risk Fadors:
It is very d i f f i c u l t t o d e t a m b e exactly how much of a r i s k one runs

in financing a theatrical film. Adequate statistics are hpssible


to find. S h a n ~ Sexvices
t
of b s Angeles a four-year-old study w h i c h
revealed that 60% of a l l films released make money. This study,
hwever, did not include long range TV syndication (foreign and
domestic) revenues, and w a s made before Pay TV and video cassettes
lxmnks significant additional markets. chmical Bank of New York
reports that they have never l o s t money on film financing.

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Another risk is the possibility that no distributor will want to


release the picture. That is why some independent producers include
a provision for distribution financing in their investment
agreemnts. If worse comes to worst, producers can distribute the
film themselves. (Notable exanples are "Billy Jack" and "Benjil*.)

There may be prcduction catastrophes that will delay or cancel


production once it is under way. m-oduwill carry various forms
of insurance (including completion bonds) to at least repay whatever
funds have already been spent.

If a distribution arrangement has not already been made, the producer


now secllres such an arrarqement. If the picture is good, it is
possible to negotiate a much better deal than could have been done
earlier. On the other hand, the prducer owld have trouble securing
the kind of distribution cormnitment wanted. The main factors here
are haw rmch money the distributor is willing to ccmunit to selling
the picture, haw much influence the producer can have on the
marketing e g n , and the distribution fee. Sametimes small
distributo~sare able to give more time and attention to independent
pictures atid offer better terms, but the producer may have to provide
some digt-xihtion expmses.
Cut of gross damestic box office receipts, the exhibitor (retailer)
usually subtxacts his fixed costs and then receives 10%. Out of the
remining 90% gross film rentals received by the distributor
(wholesaler), he usually recoups all or part of his asts plus a
distribution fee of 20-35%' then passes the reston to the
producer/investor. Terms of distribution deals vary wnsiderably.

Box office d p t s , hawever, only account for a part of the


prcduoer/investorls revenues. As the enclosed figures &ow, the
ancillary markets are at least as significant as the domestic theatre
box offie. TV syndication, for instance, can continue to bring in
revenues for the next twenty years.
Demand for met:

W y ' s supply comes nmhere near to matching real demand. At the


present time, there are over 18,000 theatres in the United States.
It can readily be seen that roughly 400 films prcd1.1~4
and rated last
year did nut begin to meet their needs. 'Iheatres are campelled to
shm any type of film they can obtain to keep their doors open.

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To date, independent producers are respnsible for 72% of all films


made world-wide. The domestic figure is 62%. me inaependent
producer has three primary options regarding distribution. These

include the sale of the film cutright to a major national


distributor, their merchandising of the film by the production
mmpany i t s e l f , or the use of smaller regional mb-dktr&utors who
may p m t e the film i n their respective geqrapkicdl areas.
Distribution of films often relies on a l l three methods to one degree
or another.
Another market, television, can consume nearly every film that has
been, or is p-tly
being p r o d u d . If each of the three mtmrks
would show only one film per night, they wald need wex 1,000 films
per year. In Lns Angeles area alone, there are nearly 10,000 films
aired each year in a combination of local and network viewing time.
Many films are sham time and time again because there are no llew
films to replace them.

1
. .

. .

Today, virtually every film of quality has residual value in


television, either by outright sale o r by term licensing. me l a t t e r
is preferable since it allows the production company t o retain
ownership of the negative. me time lag between theatre release and
TV sale has dimhished fram seven years to an average of 18 mths.
However, sane major features such as "The Wizl' have heen sold to TV
before ccwpleting a f u l l year in theatrical release. me trend seems
to be taward purchase of 'fresh' films, and the outlets a p p a r
willing to pay the higher costs involved
Because of the great demand and the outrageously c a p e t i t i v e attitude
that penades the networks, handsome deals are being consunnnated
before the production has been ampleted and then, by preamangenent
its
with the producers, hold the film until it has -let&
theatrical run.

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APPENDIX

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Breakeven for Limited Fartners:


Based on grass revenues of $ 11,200,000 collected fmm 1st and 2nd
t h e a t r i d runs

1st run t i c k e t costs of $ 6.00


2nd run ticket costs of $ 5.00

$ 300.00 G r c s s per show

$ 300.00 per show X 1000 houses

$ 300,000 Gross

$ 300,000 X 14 days

= $ 4,200,000 Gross

50 people per show

x $

6.00

2nd Run
50 people

per show X $ 5.00

$ 250.00 per shm X 2000


$ 500,000 X 14 days

= $25O.OOGrosspershow

hauses

$ 500,000 Gross

$ 7,000,000 Gross

Total 1st Ibvl

Total 2nd Ibvl


Total

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Forcast A

Total Box

office Gms

$ 11,200,000

15%F~~ me.,-

1,680,000

g 520 000

2,856,000

6,664,000

Less : jy,"em Capital

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.

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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.

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Forecast B

M~15% F~~ meatres

--

Motion Picture Profits

$ 23,800,000
$

Less 30% Distribution Fee

4,200,000

7,140,000

$ 16,660,000

T.V., Cable and Video Net

-------

$ 14,000,000

Less : Investors Capital

F?xducers Split @ 50%

$ 10,670,000

Investment Companies' IWxm

$ 10,670,000

Less : General Partners split @ 15%


Investors Return

4,000,000

1,600,500

9,069,500

These are onlv proiections and are for i n f o m t i o ~ lm x c e s onlv. An


investment made. based solelv on these ~roiectionswould be unadvisable as
actual cerformanoe could vary qreatlv.

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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.

fashioned profit: an ideal solution for


post tax-reform era.
The key here is undersranding how
much the industry has changed. The
tyranny and fickleness of box-office
receipts is no longer. More people
around the world are viewing more
films than ever before. but not necessarily in the theatres. Consider, for
example, that there are only about 300
feature films made every year, of
which about half could be considered
"major." Now, compare that with the
number of movies a cable outlet, like
Home Box Office,
shows in a single
duy. Eight? Then.
take a look at the
shelve?;o f your locxl
3

ucts to & financed, and [he second


the structuring of the deal.
in wlecting the pn)duct, success
u s ~ J [ l y found in tilinking small, ~h
larger [he budget in a film, the great,
[he risk,
[he $50 ,,,illion antic
pdted blockbusters and seek out. ir
stead, the more modest undenJkint
of smaller, ambitious film produc
tion sources. A,,
example i
Island Pictures, a
small, in
dependent film production and di>
tribution conlpany for which, la,

-,

N d guile a btochburrcr: lslund3 - N o M . y ' s Fool.' slurrim>


h'osunnu Arqurtlr und Eric Robens. wrr u more modrmrc succerr
e ~ will1
m Pulil2er Prtm winning phyw(yhr 5elh Henley uniting. Phok

muriesy lsland Pichrres.

video rental store, year, a $7.4 million equity placement


a n d the crowds was arrsngrd. lsland Pictures is an rflooking them over, ficient operation - unlike some of
and you begin to the more notorious larger Hollywood
understand the di- studios - and it knows how to
mensions of growth.
recognize quality.
Of course, just as not every piece of
Litrle known lsland Pictures capreal estate is a great investment, every tured a great deal of anention in 1985
movie isn't bound to turn a profit. with two extraordinary films - "Kiss
But, there are two factors that h ~ v e of the Spider Woman" and "Trip to
proven ro be the critical difference in Bountiful." It was the first time in hiscreating a sound investment vehicle. tory that one production house could
of the prod- Wednesday,
ThePage
first 336
is the
claim creditNovember
for both 18,
the 2015
Best Actor
of selection
806

Success o m a shoesrrlmg: ~mducer/dix~clor


spike Lru fcmrler) turned

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)

and a Mule Filmwohs.

When the motion picture industry


was first examined as an investment
vehicle a few years ago, the expeclaj tion was that there was potential for
tax deferment. Wh;lt was found, however, was a surprisingly rich source of
income
for investors from good, oldThird Circuit
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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

l h e i n f o m t i o n s e t f o r t h herein w a s obtained from sources which w e


believe reliable, but w e do not guarantee its accuracy. Neither the
information nor any opinion expressd constitutes a s o l i c i t a t i o n by us of
the pwchase o r sale of any securities o r cmmtxlities. 'Ibis package is
f o r informational puzposes only, to gain an indication of interest in this
project. Financial Mamgement Group Ltd. does not endorsed and has not
been contracted by mer Station to p-te
this projed. Any questions
regarding i n f o m t i o n contained herein should be W e d t o Stanley J.
Caterbne o r Scott Rokertson.

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1
In
u-

n u m w

newsletter

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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

euplayees please park in back of ccmplex f o r o m client's convenience.


&
FMGl
J
?his means both you and me. -ROEBU! XAUFEMAN

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

My sincere congratulations to our top prcducers and award w i n n e r s .

--ram

KAUFFMAN

Win A Wiv lb San Fancisco


% w i l l be sprmring a t r i p to San Francisco for a R-iday, Saturday, Sunday,
and Monday i n September. The contest w i l l run on a business sutPnitted basis
fmm May 15 through August 15. Your g w l for t h e t r i p w i l l based on your first
quarter total with d i n minimunrS.
IfyourfirstauarterGCIwas
0 - 20,000 then vour seal is 20,000
20,000 - 29,999
30,000 - 49,999
50,000 - 74,999
75,000 - 99,999
99,999 +

G c d

Luck. See you in San Rrancisco!

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30,000
50,000
60,000
70,000
80,000

--ROEBU! KAUFEMAN

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= -7
-

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-'_'
FMG Advisory

m
=
I

Eden Park 11. 1755 Oregon Pike

Lancarler, PA 17607

717-5694100

XUL * I . L T I M Z N T L l W . L1D

May 28, 1987


Ms. Dore c. Valavanes
Shirk, Reist, Wagenseller and Shirk
Post Office Box 1552
Lancaster, PA 17603
Dear Dore:
Enclosed are the completed files on the Umiker's Power of
Attorney.
I have been extremely busy and would like you
to distribute the copies to those involved.
Thank you so much for your help with this.
Sincerely,

SJC: lmk
CC

encl

Third Circuit 15-3400


Property of Advance Media Group

Page 340 of 806


Page 2286 of 2953

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 342

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

May 29, 1987


Ms. Ellen Libman

Pcwer Station, Inc.


441 West 53rd S e e e t
N e d York, N.Y. 10019
Gear Ellen:

L e t ' s try it again. This time w e are scheduled t o leave IDSAngeles


on Thursdzy, Jdii 4 & i ret3 Ias Arzjdes cz TJ&-,
Z&w 9. 3.e
follaJing is a rough s c h d l e .

m & Y

Arrive atout 3:OOR.I. Please l e t us laww the exact


f l i g h t information as w n as possible so we can
arrarrge *rt
transportation here. Let us Iuxw
if sureone w i l l pick us up in New York o r i f we
M
d arrange tr-rtation
to F a e r Station.
Also let: me -1
what btel we w i l l be hoked a t
in New Y a k so we can leave t h a t information here.
W e ' l l corne to Power Station for any discussion
regarding the s c r i p t &/or budget.
Barbara and I have a dinner meeting with a Director
of Photqraphy.

Ieave for Ned Jersey in the mrning. M e e t w i t h


Steve Gorelick, the hrcduction Coordinator of the
New Jersey Film Carmission. Look a t locations.

in New Jersey. Meet the rep


fmm Maury's Pier to discuss location costs.
Check out btels for crew ard cast.
last m i n u t e d e t a i l s in New Jersey.
Leave for New York a n x d m n .

3-Y
Y-

S t a n Caterkon-e arrives

Meetas a t P a e r Station for findl discussions


about s c ~ i p t ,budget, oatracts, etc.
Additional ueetins in r r p r n i q if necessary.
Ieave New York a p ~ o x i m t e l y4PM to arrive Los
Angeles a b u t 9R.I.
\

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
Third Circuit 15-3400
Property of Advance Media Group

%7=ds,

Arlene
PageA
341
806
Wednesday, November 18, 2015
4334 STERN
m..of
SHERMAN
OAKS.CA 91423
Page 2287
of 2953
10/19/2006
(8161
995-3417

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 343

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

FlATBUSH
FILMS,NC,
May 29, 1987

Mr. Stan Caterbone


554 Berkley Avenue
Stone Harbor, N.J.
Dear Stan:
I'm enclosing a first draft of the screenplay, complete with
typos and a couple of other errors. (For instance, Kennie
Queens is also Kenny Peterson.)
This
well
very
talk

should give you sufficient time to study the script as


as the budget, which I'm also enclosing. It would be
helpful if you could have notes prepared which we can
about when Barbara and I are in New Jersey next week.

&
rlene

Third Circuit 15-3400


Property of Advance Media Group

,avidson

4334 STERN Am..SHERMAN OAKS. CA 91423


Page 342 of 806
Wednesday, November 18, 2015
1818) 995-3417
Page 2288 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 344

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

TIME
S Y S T E M S
MONTH

Third Circuit 15-3400


Property of Advance Media Group

,-d u g

Page 343 of 806


Page 2289 of 2953

YEAR

1487

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 345

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

RICHARD L. TRUMP
P.O. BOX 557
SKIPPACK. PA 19474
Bus. (215) 489-2447

June 3, 1987

Mr. Stan Catcrbone


Financial Management Group
1755 Oregon Pike
Lancaster, PA 17601

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:

1401 Rising Wind Court


Silver Spring, MD 20904

Please let me know if there are any problems with having


the certificate issued.
Sincerely,

&,&
&zU/&@
Rick Trump
RLT/tpp
Enclosure

Third Circuit 15-3400


Property of Advance Media Group

Pagethrough
344 ofHibbard
806
Wednesday,
November 18, 2015
Securities Transactions
Brown & Company,
Inc.
2290 of 2953
10/19/2006
APage
Registered
BrokerfDealer
Member NASD & SlPC

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 346

Page 345 of 806


Page 2291 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 347

Date Filed: 11/18/2015

June 1 2 . 1 9 8 7

Mr. Stan Caterbne

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

you because it w i l l a l l start ha-

so quickly, We'll inmdiately have a


NaJ York office, per d i m , hotel an3 contracted fees for Barbara and myself.
W e ' l l hire a casting director, p d w t i o n manager, production coordinata~a d
location manager, get the mutant effects started and begin hiring key personnel.
If p check the m e t p ' l l see the a c M m m h r of weeks of aployment
for crew. mere w i l l be legal fees for preparing mntracts. During those +XJ
weeks ~ ' 1 twpefully
1
do rmst of the castiq.

Third Circuit 15-3400


Property of Advance Media Group

4334 STERN
AVE.,
SHERMAN
Page
346
of 806 OAKS.CA 91423
Wednesday, November 18, 2015
(818)
Page 2292 of995-3417
2953
10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 348

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

w i n g the eight weeks of pre-producLLion in N w Jersey w e ' l l be mrkixg


w i t h the art director, c o s m e designer, s e t decvrator, building s e t s ,
tying d m locations, e t c .
A week before shooring the f u l l crw w i l l be prepping.

a r r i v e ~ a tabout t h a t tire ard


e n t i r e shootinq period.

hill

The editor w i l l

be working on a rough cut during the

A t the close of p d u c t i o n Barbara, the editor and I w i l l m e back to


New York f o r a three mnth editirq period a t the end of w h i c h we w i l l

deliver the finished film, incllxlinq distributor's requirements ard t h e


MPAA ratinq.

As you can see this w i l l be very tricky but I s t i l l think we can do it


i f Barbara an3 I are in New York no l a t e r than June 28.
Hope this helps.

Regards,

cc: Tony Bongiovi


Barbara P e t e r s

Third Circuit 15-3400


Property of Advance Media Group

Page 347 of 806


Page 2293 of 2953

Wednesday, November 18, 2015


10/19/2006

PERSONAL FINANCIAL STATEMENT


US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 349

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

IMPORTANT: Read these dlrsctions baton cornpletlng this Statement.


,

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-

SOURCES OF INCOME FOR YEAR ENDED

Do yw nave a w

, me 01 ereculor

Are yw a partner or olllcer m any otter venlure? 11 so aercrlbe

ml-

Are you mlgatea IO pay Ymony cnda w r p w l or separate rnalntenance


paymenls? 11 so aescrme

.*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

Income tax selllea lnrougn (date)


Are you a delenoant in any rut's or kgal acl6ons7

As onaor~erCD-make, or guarantor?

On leases or cmlraclr7

S
S
S
S

L-1

cla~ms

OlMr specoal aebl


w n l 01 15-3400
cmtsned mcome tax loens
Third MCircuit

Property of Advance Media Group

739 REV 3/78

Perma1 DlWl accounls carved a1

Have you ever men declarea b a h p t ? IIw, aerclb?

Page 348 of 806


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Wednesday, November 18, 2015

(COMPLETE SCHEDULES AND SIGN ON REVERSE SIDE)

10/19/2006
n -Y

US District Court For The Eastern District of Pennsylvana


Section 3189 Federal False Claim Act
SCHEDULE A U.S. GOVERNMENTS h MARKETABLE SECURmES

Case: 15-3400

Document: 003112132545

NumDn 01Shares
a Face V a f w (BaMsl

Page: 350

Descr~ptm

Date Filed: 11/18/2015


Ale Thaw

In Nam 01

Marha
Valw

Piedpea?

SCHEDULE B NON-MARKETABLE SECURITIES


Descr~plm

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

SCHEDULE D REAL ESTATE OWNED


1

Dale
AcqusreO

Tdle I"

Address 6 Type
01Rwuly

Name 0 1

Market
vale

MMQaX

MOU
Y
II

SCHEDULE E LIFE INSURANCE CARRIED. INCLUDING N.S.L.I. AND GROUP INSURANCE


Om- 0 1
PMcy

Name 01
Insur-e Ccm~4-y

Benefr~ary

Face

Amml

Cam Surrna

Po1.c~

Value

L-I

I
t

SCHEDULE F BANKS OR FINANCE COMPANIES WHERE CREDIT HAS BEEN OBTAINED

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

Slgnalure (Olner Party)


S S No

Date Sognea

Third Circuit 15-3400


Property of Advance Media Group

19-

Page 349 of 806


Page 2295 of 2953

Dale ol 0u:n

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 351

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

June 15, 1987


Mr. Stanley Caterbone
FINANCIAL MANAGEMENT GROUP LTD
1755 Oregon Pike
Lancaster, Pennsylvania 17601
Dear Stan:
It was good speaking with you - - at last - - after our message
go round. Enclosed are the materials you requested. I expect that
this should reach you by Wednesday.
As I indicated to you, Hunterdon County is the area I have tareeted
for development in New Jersey. InteretaLc 78 was completed this
year and tied Hunterdon County into a 25-35 minute commute to many
major corporate centers in New Jersey, i.e. Morristown. Princeton
and New Brunswick. After completing a survey of the area, I am
satisfied with the resulting information. I have been dealing with
local brbkers with a view towards locating both residential and
commercial sites for development, several properties are under negotiation
at this time. These projected investments are well leveraged and
offer impressive cash-on-cash returns.

I look forward to discussing these opportunities with you.

SW:wc
Enclosures
Via Express Mali

Third Circuit 15-3400

0
C O Group
U N T Y
Property1of 2
Advance
Media

Page 350 of 806


R O A D

IPage
E 2296
N A ofF2953
L Y

Wednesday, November 18, 2015


N l

O I h 7 O

2 0 1

5 610/19/2006
8 h 8 7 5

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 352

PLAN

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

DIXX

UEEINGS
-T

RIINNG-

El 4101

RtY 1-85

Third Circuit 15-3400


Property of Advance Media Group

WNTU
P*YSEAL
S.R,lU*L
-MIL"

PRlNTED IN US

Page 351 of 806


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 353

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LAW O F F I C E S

SEIDEL,GONDA, GOLDHAMMER& ABBOTT,P. C.


PATENT A N D TRADEMARK A T T O R N E Y S
S U I T E 1800 T W O P E N N C E N T E R P L A Z A

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

Mr. Stanley J. Caterbone


FMG Advisory, Inc.
Eden Park I1
1755 Oregon Pike
Lancaster, PA 17601
RE:

Service Mark Search f o r


"FINANCIAL MANAGEMENT GROUP"
Our File: 7351-G

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

Third Circuit 15-3400


Property of Advance Media Group

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

Page 352 of 806


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Case: 15-3400

Section 3189 Federal False Claim Act

Document: 003112132545 Page: 354


Date Filed: 11/18/2015
SEIDEL,GONDA, G O L D H A M M E R& ABBOTT; I? C.

Mr. Stanley J. Caterbone

22 June 1987

-2-

a f a i r argument t h a t "FINANCIAL MANAGEMENT GROUP" i s merely suggestive, not


descriptive.
The more difficult problem arises in respect t o t h e f a c t t h a t t h e r e a r e
others using "FINANCIAL MANAGEMENT GROUP" o r slight variants thereof. See
for example California s t a t e registration No. 14070 f o r "THE FINANCIAL MANAGEMENT
GROUP". S e e also t h e listing of four companies under t h e n a m e "FINANCIAL
MANAGEMENT GROUP" in California, Louisiana and Oregon. Moreover, t h e r e a r e
"FINANCIAL MANAGEMENT GROUPS" listed in t h e telephone book for Atlanta, Georgia
and Chicago, Illinois. Whether o r not these o t h e r users remain in business, and whether
o r not they o f f e r services competitive with yours, i s nearly impossible t o evaluate on
t h e limited f a c t s available from t h e report. Thus, t h e risks exist t h a t should you e n t e r
into one o r more of these companies geographical market areas, they may a s s e r t a claim
of prior rights.
If, on t h e o t h e r hand, you will not a s a practical m a t t e r be trading in these
market a r e a s f o r t h e foreseeable future, then I recommend proceeding with a n application
t o register t h e mark. If w e are successful in obtaining such registration, then your
right t o use t h e mark can ultimately become incontestable if not f o r t h e prior users
market areas, then f o r t h e r e s t of t h e United States.
Please f e e l f r e e t o call m e if you have any questions concerning t h e
foregoing.
With kindest personal regards, I a m
Sincerely yours,
SEIDEL, GONDA, GOLDHAMMER & ABBOTT, P.C.

5. 2
3 c~4?J,0~Ym

. GOLDHAMMER

--*-\

\
.

JSG:md
Enclosure

Third Circuit 15-3400


Property of Advance Media Group

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 355

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

STANLEY CATERBONE
Eden Park 11, 1755 Oregon Pike Lancaster, PA 17601
569-4 10 0

June 22, 1987

Dear Dr. Umiker:


Just a brief note to let you know you
should be receiving the distribution from
your IRA'S with IDS in several weeks.
Please call us when the money comes in
so that we know everything is in order.
Also, due to the growth of FMG and my
duties, I have found it necessary to hire
a Director of Client Affairs, Todd Dellinger.
Todd will
handle
any tactical details
of your accounts, while I will continue
to
look after
the strategic planning.
More details later.
Any questions, please call myself or Todd.
Thanks,

Third Circuit 15-3400


Property of Advance Media Group

Page 354 of 806


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Case: 15-3400

Document: 003112132545

Page: 356

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

DATE:

JUNE 23, 1987

10:OOam

PLACE:

FINANCIAL MANAGEMENT GROUP, LTD


1755 OREGON PIKE
LANCASTER, PA 17601

SUBJECT:

SCHEDULED MEETING O F STAN


CATERBONE, LARRY RESCH,
AND CARL JACOBSON O F ISC AND
UNITED CHEM CON

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.

Third Circuit 15-3400


Property of Advance Media Group

Page 355 of 806


Page 2301 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 357

PLAN

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

TtME %PEN1

arm
WET-

RlWC-

Third Circuit 15-3400


Property of Advance Media Group

Page 356 of 806


Page 2302 of 2953

SPIURU-

l V P l RmP

ULNW
RnSCII

rWLI

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana


( i T H O Y A 5 Y1LLFR
DOMALO R. W A I S F L
R I C H A R D Q. LEFEVER
-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
Section 3189 Federal False
Claim Act

MCNEES,WALLACE
NURICK
Document: 003112132545
Page: 358 &Date
Filed: 11/18/2015

Case: 15-3400

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

MARY JANE FORBES


JEFFREY B CLAY
DAVID
LLLPPlNGEii
NEAL 5 . W F 5 T
BRUCE A TLLDMAN
T R A H I L I N A MILLS. J R
YICHALL
OUCIROW
BiUCF D 8ACLCY
BARBAR* 5 . LAHOE
STEPHEN A. M W W C
DAN* 5 . SCIOUTO

ATTORNEYS AT LAW

19.2-1967

100 P I N E STREET
P. 0 B O X 1166

~~

1923-8959

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

June 23, 1987

*.w*ris,JI1.

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..

FMG Advisory, Inc. - Pennsylvania Investment


Advisor Application
Our file: 11489-001-5

Stanley J. Caterbone, President


Financial Management Group, Ltd.
1755 Oregon Pike
Lancaster, PA
17601
Dear Stan:
I am enclosing a form of letter I propose to send to
Mr. Schwartz, and in case any changes in the application
are needed I also am returning executed Form ADV which you
recently sent to me.

.4
9

\..
4
Wd

Please review the draft response letter very closely


and give me any comments. In connection with your review,
please consider the following points:
1. With respect to Item 1, Form ADV indicates that
10 or more persons will perform investment advisory functions,
and I note that you have included additional Form D's. However,
there appear to be only nine such forms attached. You also
should prepare a separate list that names such persons.
2. With respect to Item 5, the explanation given on
Schedule F with reference to question 12.B. has not been
changed, although as was pointed out by Mr. Schwartz and
as we agreed, the information given is garbled and should
be revised.

3. With respect to Item 7, Mike's Schedule D should


be revised in accordance with the information given in my
letter, which of course is taken from Mr. Schwartz' letter.

Third Circuit 15-3400


Property of Advance Media Group

Page 357 of 806


Page 2303 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 359

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Stanley J. Caterbone, President


June 23, 1987
Page 2

The clarifications should include the information you gave


me concerning his status as a Certified Financial Planner,
and also should relate to his corporate positions with Ltd.
and Advisory, Inc.
Please look this over and call me at your early convenience.
When you and I are agreed on all changes, you should return
the application and I will see that it and the transmittal
letter are filed promptly with the Commission.
Sincerely,
McNEES, WALLACE & NURICK

WJJ: jp
Enclosure

Third Circuit 15-3400


Property of Advance Media Group

Page 358 of 806


Page 2304 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 360

Date Filed: 11/18/2015

Lo&L

INVOICE

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

Telephone: (717) 394-3757

Customer's
Order No.

Phone
No.

sold TO

F*G

Address

Ed-,

PJVISO.-U

&,*

.Sn<- 1755

*~
1987

C'hrtq-p)C'

TERMS: Net 30 Days. A 1 %%Finance Charge or 18%Annual Rate Of Interest will be


added to all invoices over 30 days and each 30 days thereafter.
Rec'd. By

Third Circuit 15-3400


Property of Advance Media Group

Page 359 of 806


Page 2305 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 361

Page 360 of 806


Page 2306 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 362

Page 361 of 806


Page 2307 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 363

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LANCASTER AVIATION, INC.


LANCASTER MUNICIPAL AIRPORT P.O. BOX 375 LITITZ, PA 17543 717-569-5341

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.

H y d r a u l i c power pack f l u i d l o u and s l i g h t l e a k a t f i t t i n g ,


t i g h t e n e d f i t t i n g and s e r v i c e d pouer p a c k .

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

A d j u s t baggage door c a t c h e s t o c l o s e more t i g h t l y .


R e p l a c e l e f t f u e l s t r a i n e r s e a l and r e f o r m b o u l i n
seal area.
R e p l a c e t a i l n a v i g a t i o n l i g h t lamp.
R e p l a c e r i g h t t a x i l i g h t lamp.

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.

Remove oxygen b o t t l e , ( a d j a c e n t equipment h a d t o be r e moved t o g a i n a c c e s s ) . P r o v i d e neu u e i g h t and b a l a n c e


t o r e f l e c t b o t t l e removal.

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

Third Circuit 15-3400


Property of Advance Media Group

Page 362 of 806


Page 2308 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 364

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 363 of 806


Page 2309 of 2953

Total

$ 775.20

Labor
Parts
7a r

$ 574.20

Total

$1430.36

775.20
00.96

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 365

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LANCASTER AVIATION, INC.


LANCASTER MUNICIPAL AIRPORT P.O. BOX 375 LITITZ. PA 17543 717-569-5341
June 2 9 , 1987
X n r , Stanley J . Caterbone
F i n a n c i a l Hanagement Group, 1 n c . J
1 7 5 5 Oregon P i k e
Lancaster. P A 17601
Dear S t a n ,
Thank y o u f o r t h e r e p l a c e m e n t check i n t h e amount of S 2 5 . 0 0 0 . 0 0 , u h i c h
u a s h a n d - d e l i v e r e d t o d a y t o r e p l a c e your p r e v i o u s l y r e t u r n e d c h e c k . Ue
s i n c e r e l y r e g r e t h a v i n g had t o i n s i s t o n immediate payment, b u t I
b e l i e v e t h a t our i n i t i a l l i m i t a t i o n s and u n d e r s t a n d i n g s u e r e c l e a r .
I have e n c l o s e d summaries of i n v o i c e s f o r e x p e n s e s y o u have i n c u r r e d
t h r o u g h t h e u s e and m a i n t e n a n c e o f your a i r c r a f t . I n t h e c a s e of t h e
m a i n t e n a n c e uork o r d e r l e t t e r , y o u w i l l n o t e t h a t S 2 0 8 . 3 4 i n c r e d i t s
u e r e i s s u e d . The a s s o c i a t e d e x p e n s e s were more f a i r l y a s s i g n e d t
a i r c r a f t s a l e s d e p a r t m e n t . Your p r e s e n t b a l a n

(.-

-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

Your a i r c r a f t i s nou i n s u r e d o n ~ a n c a s t e r w ' fs l e e t p o l i c y .


Uhen t h e a i r c r a f t i s removed f r o m our p r e m i s e s , i t w i l l b e removed f r o m
t h a t p o l i c y . Uhen we r e c e i v e our s u b s e q u e n t b i l l i n g f o r a i r c r a f t
i n s u r a n c e , ue u i l l s e n d y o u a C O P Y o f t h a t p a r t of t h e b i l l u h i c h d e a l s
w i t h your a i r c r a f t , and ue u i l l i n v o i c e y o u f o r t h o s e premium d o l l a r s .
That p r o b a b l y u i l l n o t o c c u r b e f o r e h u g u s t 31. Y o u u i l l need a i r c r a f t
i n s u r a n c e . I have t a k e n t h e l i b e r t y of e n c l o s i n g t h e c a r d s of t u o
a b s o l u t e l y r e p u t a b l e b r o k e r s , and recommend them t o y o u e q u a l l y .
Ue u i l l r e l e a s e t h e a i r c r a f t t o y o u or t o your a g e n t s uhen your ~ o s t
r e c e n t l y p r e s e n t e d check h a s c l e a r e d , and uhen t h e c h a r g e s o u t l i n e d
above have been p a i d .
1 s i n c e r e l y r e g r e t t h e d i f f i c u l t i e s ue have e x p e r i e n c e d i n our b u s i n e s s
r e l a t i o n s h i p . I f ue can be o f any h e l p i n m e e t i n g your f u t u r e a v i a t i o n
n e e d s , p l e a s e c a l l u p o n us.
Sincerely yours,

SHITH
Vice P r e s i d e n t and G e n e r a l Hanager

C.H.

Third Circuit 15-3400

Property of Advance Media Group

Page 364 of 806


Page 2310 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 366

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

C..

;.

:.:

.. .. . .
~, ~:

Third Circuit 15-3400


Property of Advance Media Group

Page 365 of 806


Page 2311 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

I 12th Year- No.35,315

Document: 003112132545

METROPOLITAN

Page: 367

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LANCASTER, P A . . FRIDAY. JANUARY 5 . l!

I The Ferranti fraud


(

Officials describe an international charade of 'cardboa


companies,
accounts,
a non-existent
conti
Third Circuit 15-3400 secret bank
Page
366 of 806
Wednesday, November 18, 2015
Property of Advance Media Group

Page 2312 of 2953

10/19/2006

Case: 15-3400 Document:


003112132545
Page:
368
Date
11/18/2015scam
Jacobson
gets
jail for
role
inFiled:
bribe

US District Court For The Eastern District of Pennsylvana

Section 3189 Federal False Claim Act

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

After the rcnrenrc r o s an^


naunced by US. nlrlr~rtc o u n
Judge Pebr K L?isurp, h c o b MRUlrned to hi. wrfe and fnends
mthecounmamnnd gave* brief
&andsmile.
Jacobson. who told the judge
be wan "a.hrmrd
of my a c ~
llone." recelved two months m a
minimum-security prtson for
Passing along 180.m in bribe
money to a Navy oillcial who
pmmrsod to steer contracts to
ChcmCon.
For the Wedtech charge. ~n
which he was the nliddicmrn lor
1 il1S.WO bnDe. Jacobson R"ivcd a Ulrae-year rvrpended
~nfenceandproh8tron.
Lri.?re o m r e d Jarubron to
Lurnhnmsclf inonJune27tts11n
thcprironlerm
Jacobson, 47.1% the brother-inA---

Third Circuit 15-3400


Property of Advance Media Group

Page 367 of 806


Page 2313 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 369

Page 368 of 806


Page 2314 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Section 3189 Federal False Claim Act


In the Court of Common
Pleas Date
Document: 003112132545
Page: 370
Filed: 11/18/2015

of Lancaster County, Pennsylvania

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

..............................

Law O f f i c e s o f Ranck & R a n c k , P . C . ,


I. You are ordered by the Court to come ~ O & P ( R % M W ~ X X ~ & X ~ R ~ X & E W ~ .
Duke & C h e s t n u t S t r e e t .
on Wednesday,

J u l y at
1 5 , 1987

10

Lancaster, Pennsylvania - - - - - - - - - o'clock,

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)

Dated: .......Ju neBQ.,..


1 9 8 . 7. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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

....

Pror

Box 1 5 2 4

If witness
is to producc daumcnlr. cic.. add iddntionrl w m
r a p h rcrdiw
And b r i q with you . . :' Wednesday,
[rpccih what daumcnir,
and. if svbpocru
is addmud
Third10-Circuit
15-3400
Page
369 of"2.806
November
18, 2015
thanone person. whkh wilnnr ir l o producc 1hcm.l

Property of Advance Media Group

Page 2315 of 2953

10/19/2006

7 P 1

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 371

Date Filed: 11/18/2015

M
of
Phone
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W C D JO SEE TOU
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Third Circuit 15-3400
Property of Advance Media Group

-w ,
I

Page 370 of 806


Page 2316 of 2953

' "2

Wednesday, November 18, 2015

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545
Erne / / . q'T

db-d
Section 3189 Federal False Claim Act
Date Filed: 11/18/2015
Date
Time &

To
Page: 372

D~h4e'$oq Were Out


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Third Circuit 15-3400


Property of Advance Media Group

8/3- y 7 2 -LmNWH
68m
NUMBER

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CALLED TO SEE YOU
WANTSTO SEE mu
RENRNED YOURCALL

Message

Time

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l
I

Page 371 of 806


Page 2317 of 2953

322 -/2&

Phone

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Message

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400
Date

9.10

Document: 003112132545

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Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 375

Page 374 of 806


Page 2320 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


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Document: 003112132545

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Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 377

Page 376 of 806


Page 2322 of 2953

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Date Filed: 11/18/2015

Wednesday, November 18, 2015


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US District Court For The Eastern District of Pennsylvana

----

Case: 15-3400

Document: 003112132545

SERVING
Section 3189 Federal
False Claim Act

PENNsYLvANtb
Date Filed:CENTRAL
11/18/2015

Page: 380

M E M B E R FDIC

LANCASTER. PENNSYLVANIA 17604

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
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$
----Case: 15-3400

0
Document: 003112132545

US District Court For The Eastern District of Pennsylvana

SERVING

Page: 381

Section 3189 Federal False Claim Act

CENTRAL PENNSYLVAN\A

Date Filed: 11/18/2015


MEMBER FDIC

LANCASTER, PENNSYLVANIA 17604

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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ACCOUNT NO.

0556-0114t

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Wednesday, November 18, 2015


10/19/2006

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US District Court For The Eastern District of Pennsylvana

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Document: 003112132545

Page: 382

Section 3189CENTRAL
Federal SERVING
False
Claim Act
pENNsyLvAN,b

Date Filed: 11/18/2015

hiENitiH F 3 I C

LANCASTER, PENNSYLVANIA 17604

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LANCASTER PA 17603-3416

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100.00
317.00
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203
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Page 381 of 806


Page 2327 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

----

Case: 15-3400

----

Document: 003112132545

SERVING
Section 3189 Federal False Claim
Act
PENNSYLVA

CENTRAL
Date Filed: 11/18/2015

Page: 383

M t M R E R FUlC

LANCASTEA. PENNSYLVANIA 17604

STANLEY J CATERBCNE
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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0602

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ACCOUNT NO.

INDICATES

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NET S E R V I C E CHARGE'
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I : T I V I T Y CHARGES SUMMARY
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1 41,
UNOS TRANSFER TO
ACCOUNT
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Third Circuit 15-3400
Property of Advance Media Group

5.5'
5.5'

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4.8'
Page 382 of 806
Page 2328 of 2953

Wednesday, November 18, 2015


10/19/2006

B'hlton

US District Court For The Eastern District of Pennsylvana

- --

Case: 15-3400

-------

Document: 003112132545

Page: 384

Third Circuit 15-3400

CENTRAL PENNSYLVANIA
MEMBER F O C

LAMCASTER, PENNSYLVANIA 17604

MICHAEL CATERBONE
STAfuCEy J CATERBCNE
2 5 5 B U T L E R AVE
CANCASTER PA 176Cl-6308

Property of Advance Media Group

Section 3189 Federal False Claim Act

SERVING
Date Filed: 11/18/2015

Page 383 of 806


Page 2329 of 2953

1057
0'202

DIRECT I N Q U I R I E S To
717-291-2591

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 385

Section 3189 FederalSERVING


False Claim Act

Date Filed: CENTRAL


11/18/2015
PENNSYLVANIA
M E V E E R FDIC

----

LANCASTER, PENNSYLVANIA 17604

MICHAEL CATERBONE
STAhCEY J CATERBCNE
255 BUTLER AVE
LANCASTER PA 176C1-6308

OG02
1057

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717-291-2591

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Third Circuit 15-3400


Property of Advance Media Group

Page 384 of 806


Page 2330 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

--

Case: 15-3400
----

Document: 003112132545

-, J

Section 3189 Federal False Claim Act

Page: 386

LANCASTER, PENNSYLVANIA 17604

CATERBONE ASSOCIATES
1 3 5 5 9PEGCN P I K E
LI~~CASTER
PA 1 7 6 0 1

1C57
OOC2

Date Filed: 11/18/2015

DIRECT I N G U I R I E S TC
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5 - 2 7 - 8 7 To 6-30-87
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ACCOUNT NO.

F. !.l N l.
)

t D E S C R I P T I O N OF A C T I V I T Y

REFERENCE

Third Circuit 15-3400


Property of Advance Media Group

9901-462t

BALANCE

bMOUNT

5-25-07

dL3IPrNIIIG ePLaucE
tU?Ji;S T R A N S t E H T l i
A.C-CBU NT
556-GL18O
FUNDS TRANSFER TO
ACCGUNT
550-cl180
1UTEG.iST CREDIT

4,168- 1
4 , 167.2

3.954.6
17.06

Page 385 of 806


Page 2331 of 2953

6-30-87

3,971.7

Wednesday, November 18, 2015


10/19/2006

FARMERS Page: 387


FIRSTWK

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545
P O . BOX

102. LITITZ. PA 17543

S J CbTERJONE 4ScCOIATES
1755 TRES3N P t Y E
L A N C A S T E R PA i7601

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

CIJSTOVFR NUMBER
0232102500
PAGE
1
4-30-87
TO
5-29-87

-----

..............................................................................

' 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
Third Circuit 15-3400

Property of Advance Media Group

Page 386 of 806


Page 2332 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 388

Page 387 of 806


Page 2333 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 389

Date Filed: 11/18/2015

6
PWNSIAPPOINTMENTS

I 1Z

Third Circuit 15-3400


Property of Advance Media Group

RESULTSIEXPENSESIETC

--

- ---

Page 388 of 806


Page 2334 of 2953

- -

MESSAGES RECEIVED
-

--

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 390

Page 389 of 806


Page 2335 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 391

Page 390 of 806


Page 2336 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Section 3189 Federal False Claim Act

Sun Filed:
Tues Wed
~ ~ % ~ B Page:
/FOR
~ 392
T [ Date
E M~o n 11/18/2015

Document: 003112132545

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Property of Advance Media Group

AEV 185

Page 391 of 806


Page 2337 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 393

Page 392 of 806


Page 2338 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

PLAN
Page: 394

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

a~la
WET-

--

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Third Circuit 15-3400


Property of Advance Media Group

Page 393 of 806


Page 2339 of 2953

MNIAL

R("ScAL
SR~ITUIL

mML"

.-

--

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 395

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

/ FBI ties Guerin to illegal military sales


1 Agent charges that arms were shipped to South Africa

114LhYear-No. 35,427

METROPOLITAN

Third Circuit 15-3400


Property of Advance Media Group

LANCASTER.PA.. WEDNESDAY. MAY IG.14YU

Page 394 of 806


Page 2340 of 2953

~s$m.-k
~

Wednesday, November 18, 2015


10/19/2006

~Pri, ~

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 396

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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.

F a i l u r e to provide adequate insurance coverage:

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,

" A d d i t i o n a l P r o v i s i o n s " o f Agreement.

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.

Third Circuit 15-3400

Page 395 of 806

Property of Advance
Media Group National Bank. ContinentalPage
2341York.
of 2953
The Commonwealth
Square.
Pa. 17405

Wednesday, November 18, 2015


(7171 8 4 8 - 1 5 3 1

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 397

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

c. Covering normal and usual losses and damages


required under Paragraph 7, "Additional Provisions" of Agreement.
2. Removal of the plane from the business premises of
Lancaster via ti on, Inc. to the business premises of Romar
Aviation, without informing Bank in writing pursuant to Paragraph
3 of "~dditionalProvisions" of Agreement.

3. Immediate and eminant intended removal for an indefinite


period of the airplane without prior written notice to Florida
without informing Bank in writing pursuant to Paragraph 3 o f
"Additional Provisions" of Agreement.
As a result of the defaults, Bank has exercised its remedies
under the Agreement to:

1, Accelerate the entire amount of principal and interest


to be payable over a period of time so that all principal and
interest is now immediately due and payable, thus abrogating the
amortization schedule set forth in the ~greement.
2.

T o take possession of the aircraft.

Furthermore, Bank intends to liquidate the collateral after


July 27, 1987, if you do not pay in full the amount owed to the
Bank by July 24, 1987.
The amount owed is:
Gross Balance
Interest to 7/7/87
Dealer Reserve

$94,000.00
695 -28
15.60

Total

$94,710.88 plus all costs of


repossession, storage
removal, maintaining
and insuring.

To prevent the sale, you must pay the above-mentioned amount


in cash, certified check, treasurer's check, cashier's check or
money order by 5:00 p.m. DST, Friday, July 24, 1987. Please
contact the following person for the exact amount:
.Larry W. Snyder
150 South 43rd Street
P.O. Box 1010
Harrisburg, PA 17108
(717) 561-3549
The disposition and sale of the airplane will occur:
1.

At any time after Monday, July 27, 1987, at 9:00 a.m.

DST.

Third Circuit 15-3400


Property of Advance Media Group

Page 396 of 806


Page 2342 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 398

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

At the premises of Lancaster Aviation, Inc. at Lancaster


Airport, RD # 3 , Lititz, Lancaster Pennsylvania.
2.

The sale and deposition will be by either public or private


sale and will be conducted in accordance with the requirements of
Section 9-504 of the Uniform Commercial Code as adopted in
Commonwealth of Pennsylvania.
Any proceeds resulting from the sale or disposition of the
aircraft will be applied as follows:
1. Costs of repossession, retaking, storing, holding,
insuring, maintaining, securing and preparing for sale and
selling of airplane as well as reasonable counsel fees.

2. Then to all principal and interest due under the


Agreement.
In the event the disposition or sale does not satisfy the
entire indebtedness, you will be obligated f6r any-deficiency and
the Bank will take the appropriate legal action to collect the
deficiency.
Very truly yo

IS,

pmd+?

Larry W. Snyder
Manager
Consumer Loan Collections
LWS/mjb

cc:

J. Robert Baker, Collection Dept., File

Third Circuit 15-3400


Property of Advance Media Group

Page 397 of 806


Page 2343 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 399

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

THE PLANNER'S SECURITIES GROUP,

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.

cc : Bob Kauf fman

Third Circuit 15-3400


Property of Advance Media Group

Page 398 of 806


Page 2344 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 400

Page 399 of 806


Page 2345 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

ACTIVBF$E%
FOR Page:s u401
n
onDate
Tues W
Document: 003112132545
Filed:
Onel 11/18/2015

US District Court For The Eastern District of Pennsylvana

Section 3189 Federal False Claim Act

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

lC8rcle

Page 400 of 806


Page 2346 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 402

Page 401 of 806


Page 2347 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 403

Date Filed: 11/18/2015

July 10, 1987

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

Dear Messrs. Caterbone and Kauffman:


Notice is hereby given to you that I hereby cancel Trust
Agreement dated October 17, 1986, of which I, WILLIAM 0. UMIKER,
was Settlor, and of which Stanley C. Caterbone was Trustee and
Robert F. Kauffman was Alternate Trustee.

('j

I will be calling to make arrangements to return any and


all assets in your possession to me.

<~.

Thank you for your many courtesies in this matter.


Respectfully yours,

WILLIAM 0. UMIKER
COMMONWEAL~HOF-PENNSYLVANIA)
COUNTY OF LANCASTER

)
)

SS:

#*
A

ON THIS, the lo* day of


, 1987, before
peared WILLIAM 0. UMIKER,
me, the undersigned officer, personally
known to me (or satisfactorily proven) to be the person whose name
is subscribed to the within Letter of Cancellation, and acknolcledged
that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and
notarial seal.

(SEA
My Commission Expires:
Third Circuit 15-3400
Property of Advance Media Group

Page 402 of 806


Page 2348 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 404

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Dear Messrs. C a t e r b o n e and Kauffman:

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 .

Thank y o u ' f o r your many c o u r t e s i e s i n t h i s matter.


Respectfully yours,

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

m e , t h e u n d e r s i g n e d o f f i c e r , p e r s o n a l l y appe r e d NORA A. UMIKER,


known t o m e (of s a t i s f a c t o r i l y p r o v e n ) t o b e t h e p e r s o n whose name
i s s u b s c r i b e d t o t h e w i t h i n L e t t e r o f C a n c e l l a t i o n , and acknowledged
t h a t s h e 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 .
I N WITNESS WHEREOF, I h a v e h e r e u n t o s e t my hand and
n o t a r i a l seal.

(SEI

Third Circuit 15-3400


Property of Advance Media Group

Page 403 of 806


Page 2349 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

From the &sk of

Document: 003112132545

...

Page: 405

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

ROBERT 0. ACKERMAN

Third Circuit 15-3400


Property of Advance Media Group

519 CENTRAL AVE.

Page 404 of 806


Page 2350 of 2953

HIGHLAND PARK, IL 60035

(312)433-4500

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 406

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

PLANNER'S SECURITIES
CONSULTING SERVICES

Planner's Securities Consulting Services offers the independence


and expertise to help the client:

1. Develop an INVESTMENT PLAN

2. Determine the criteria for selection of an INVESTMENT


MANAGER

3. Evaluate investment managers, presenting only


those who can meet investment plan's needs
4. Monitor these investment managers' performances
within customer set parameters

5. Monitor monthly detail reports


Our structured approach saves a plan's sponsor, trustees or
individuals time and effort and allows them to retain control over
asset management.

Third Circuit 15-3400


Property of Advance Media Group

Page 405 of 806


Page 2351 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 407

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

d the. account, hrdudlng tush. as shown on fhe lnltlal and


gUatW oppratsd a cutodlan bank octhrity 4
..Th;e maw
auement tee k d e t e c m i n e d - m tto the f o l m scheduk
.

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)

5 of 1%of Maket Value

Fees are prepoyable quatecly. @ d e m g emay be &ed


allocated per ciient )nmuctlons

Third Circuit 15-3400


Property of Advance Media Group

Page 406 of 806


Page 2352 of 2953

and

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Section 3189 Federal False Claim Act

INVESTMENT
MANAGER
Document:
003112132545
Page: 408
Date Filed: 11/18/2015

Case: 15-3400

Dataform

Name

.(

Address

614 LANDIS AVENUE

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

SEE ATTACHED FEE SCHEDULE

z Manage:

Equity
Only

Capital Markets Used: Stock lxl


I
Real Estate
Equity
Asset Mix in All
jEqJy Accounts as of

Telephone
Contact
Name
Contact
Name

CUMBERLAND ADVISORS, PTY.

Mutual Funds Managed:

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

CUMBERLAND GROWTH FUND

- In-HouseCo-Mingled Funds: .

Special Services (check one):

Active

Passive

NIA

Minimum Account
Size (specify):

Bond lmmunization/Bond Dedication


Municipal Bonds
Socially Sensitive (if asked, will not invest in "sin" stocks)
Convertible Preferreds
-

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.

Third Circuit 15-3400

Property of Advance Media Group

Page 407 of 806


Page 2353 of 2953

Wednesday, November 18, 2015


10/19/2006

1 1 u v c 3I MEN I MANAtikH
Section 3189 Federal False Claim Act
Document: 003112132545 Page: 409
Date Filed: 11/18/2015

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Name

Dataform

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

Date Founded 1973

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

Bond Immunization/Bond Dedication

Socially Sensitive (if asked, will not invest in "sin" stodts)

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

Third Circuit 15-3400


Property of Advance Media Group

Page 408 of 806


Page 2354 of 2953

Wednesday, November 18, 2015


10/19/2006

INVESTMENT
MANAGER
Document:
003112132545 Page:
410
Date Filed: 11/18/2015

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Section 3189 Federal False Claim Act

Dataform
(818) 247-5330

Telephone
(213) 245- 7 4 6 1
Contact
Name
Richard A. Snyders
Contact
1 Name

Name

Van Deventer & Hoch


420 North Brand Boulevard, Suite 405
Address Glendale, CA 91203

cin//State/zip
Ownership

Date Founded

Chemical New York Cor~oration

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

Feestructure 2% first $100,000; 1% next $200,000; 3/4% next $200,000:

2/3% all over $500,000


Manage:

Equity
Only

Capital Markets Used: Stock


Real Estate
Equity
Asset Mix in A l l
in/ Accounts as of
n/a
Mutual Funds Managed:

In-House Co-Mingled Funds:

Balanced
Accounts
Corporate
Bond

Fixed
Cash
Income
Management
Other:
Government
International
Bond
Cash [XI
Securities

Futures

Options

Max Equity

Other:
%

Min. Equity

none

none

Special Services (check one):

Active

Passive

N/A

Minimum Account
Size (specify):

I3

Bond Irnmunization/Bond Dedication

[7

Municipal Bonds

Ed

I3

0
0

Socially Sensitive (if asked, will not invest in "sin" stocks)


Convertible Preferreds

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-

01986 Richud Schimarth &ksoda(es. m.~ h Infanutbn


s
prov~ed
m h is obtained fmm the lnvwtmnr manager named herem
"d prblidy
.MIlabb wrcw mnd b belle& to be rel&e.
mrepresentabon
a wanamy k Wednesday,
made as to its accuracy
aampkrtemtss.
Third .Circuit
15-3400
Pagebul
409
of 806
November
18, 2015
Property of Advance Media Group

Page 2355 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400
Van Deuenier
81 Hoch

Section 3189 Federal False Claim Act

Document:
411 California
Date Filed:
11/18/2015
4.0 North003112132545
Brand Boulevard Page:
~1enda.k.
9120)
(213) 247-5330/24;

Id

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

pINIMUM ANNUAL FEE:

$2,000 PER YEAR

Note: No start-up or termination charses

II
I

Third Circuit 15-3400


Property of Advance Media Group

Page 410 of 806


Page 2356 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 412

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

..

.
.'

.'*

- -._%

- ----.-!---.;
=.L
L.1;

--.

-__

PENSION A N D PROFIT SHARING COLLECTIVE INVESTMENT FUND

REPORT O N EXAMINATIONS OF FINANCIAL STATEMENTS


for the years ended December 31, 1986 and 1985

Third Circuit 15-3400


Property of Advance Media Group

Page 411 of 806


Page 2357 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 413

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

To the Board of Directors


~ari-isburg,Pennsylvania
We have examined the statements of assets and liabilities
of the
Pension and Profit Sharing Collective Investment Fund
as of December 31. 1986 and 1985, including the portfolio of investments as of December 31, 1986, and the related statements of operations and changes in net assets for the years then ended. Our
examinations were made in accordance with generally accepted auditing standards and, accordingly, included confirmation of investments
held for the account of the fund by the custodians, and such tests of
the accounting records and such other auditing procedures as we considered necessary in the circumstances.
.In our opinion, the financial statements referred to above
present fairly the financial position of the
Pension and Profit Sharing Collective Investment Fund as of December 31, 1986 and
1985, and the results of its operations and the changes in its net
assets for the years then ended, in conformity with generally
accepted accounting principles applied on a consistent basis.
We have also previously examined. in accordance with generally accepted auditing standards. the financial statements of the
fund for each of the three years in the period ended December 31,
1984; and we expressed unqualified opinions on those financial statements.
In our opinion, the financial information set forth in Note 4
to the financial statements for each of the five years in the period
ended December 31, 1986, is fairly stated in all material respects
in relation to the financial statements from which it has been
derived.

March 19. 1987

Third Circuit 15-3400


Property of Advance Media Group

Page 412 of 806


Page 2358 of 2953

Wednesday, November 18, 2015


10/19/2006

,f&Q15-3400
Case:

L,76

',."-

US District Court For The Eastern District of Pennsylvana

Document: 003112132545

Page: 414

I . . . -.
Section
.. . , . 3189
:.-::r-Federal False;..Claim
. .?.-Act
Date Filed:
11/18/2015
:
'
?
,

PENSION AND P R O F I T S H A R I N & ' " , . COLLECTIVE INVESTMENT FUND


...

-&:% ;
I v , - ! . ! : , 2 .:$?
.uI
h

"//...,.
! .

... . _...

STATEMENTS O F A S S E T S AND L I A B I L I T I E S

December 31, 1986 and 1985

ASSETS:

Investments at value (cost


$126,174,490 and $125,472,567,
respectively)
Cash
Accrued interest and dividends
receivable
Total assets
LIABILITIES:
Income due participants for month
of December 1986, payable
January 1, 1987 at rate of
$.697 per unit and for month
of December 1985, payable
January 1, 1986 at rate of
S.800 per unit
Accrued expenses
Total liabilities
NET ASSETS
Net assets are represented by:
Funds applicable to 1,093,410 units
outstanding, equivalent to
$131.00 per unit in 1986,,and
to 1,174,423 units outstanding
equivalent to $121.81 per unit
in 1985:
Consisting of:
Amounts invested by
participating trusts
Accumulated gain on securities
sold o r redeemed
Unrealized appreciation
of investments
Excess of accumulated redemption
value of units redeemed
over participants' cost
Undistributed net investment
income

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

See accompanying notes to financial statements.


Third Circuit 15-3400
Property of Advance Media Group

Page 413 of 806


Page 2359 of 2953

Wednesday, November 18, 2015


10/19/2006

'

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 415

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

PENSION AND PROFIT SHARING


COLLECTIVE INVESTMENT FUND
STATEMENTS OF OPERATIONS
for the years ended December 31, 1986 and 1985

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

See accompanying notes to financial statements.


Third Circuit 15-3400
Property of Advance Media Group

Page 414 of; 8063


Page 2360 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 416

..:..,: ,;;,;.
:. ;...*..--. 'e P,.-.->.
Date Filed:
11/18/2015
. ... Section 3189 Federal False Claim Act
:t..:<!.;

PENSION AND PROFIT SHARING..COLLECTIVE INVESTMENT FUND


:
- 1

-.:.\

.i-

;i;\:2:<z,:,

STATEMENTS-OF CHANGES IN NET ASSETS


for the years ended December 31, 1986 and 1985

FROM INVESTMENT ACTIVITIES:


Net investment income
Distribution of net investment
income to participants
Net realized gain from
security transactions
(Decrease) increase in
unrealized appreciation
of investments
Increase in net assets
derived from invest,
ment activities

FROM PARTICIPANT UNIT TRANSACTIONS:


Net proceeds from sales of units
(94,412 and 131,674 units,
respectively )
Paid for units redeemed (175,427
and 132,950 units, respectively)
Decrease in net assets
derived from participant
unit transactions
Increase in net assets

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

See accompanying notes to financial statements.


Third Circuit 15-3400
Property of Advance Media Group

Page 415 of 806


Page 2361 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 417

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

NOTES TO FINANCIAL STATEHENTS, C o n t i n u e d

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
:

..-.

December 31, 1986

fioney market funds


Bonds, debentures
and notes:
U.S. and foreign
governnent
obligations
Corporate bonds,
notes and convert ible debentures
Carmen and preferred
stocks
Insurance group
annuity contracts

4,427,800

35,103,995
$

Value

Cost

4,427,800

6,399,600

39,445,939

5,049,732

_ _ _-

Decanber 31, 1985

Value

Cost

/,

.:
.. .

5,774,937

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,

P u r c h a s e s and sales of s e c u r i t i e s o t h e r t h a n United S t a t e s


Government o b l i g a t i o n s a g g r e g a t e d 5 3 6 , 9 7 1 , 2 8 1 and $34,885,320
i n 1 9 8 6 , a n d $23,754,759 a n d $ 2 2 , 6 3 8 , 0 9 3 i n 1985, r e s p e c t i v e l y .
P u r c h a s e s a n d s a l e s o f U n i t e d S t a t e s Government o b l i g a t i o n s ,
o t h e r t h a n s h o r t - t e r m T r e a s u r y b i l l s , a g g r e g a t e d $887,762 and
$ 3 0 0 , 0 0 0 i n 1 9 8 6 a n d $887,761 a n d 5 1 , 0 0 0 , 3 4 9 i n 1 9 8 5 , r e s p e c t i v e l y .

Continued
6
Third Circuit 15-3400
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Page 416 of 806


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Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 418

Page 417 of 806


Page 2363 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 419

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

compeator's purchase before Far;


b Penrod was invited ta pardciregained control as CEO.
pate in the secret plan, but refused,
The Texas Court of Appeals sa
prompting the banks to retaliite by
thatFarah lenders went too far in co
attempting to destroy Penrod
trolling Farah management. " A
Far from conceding any points.
though the lenders may have be
the banks denied the charnes. and
to exerdre ledIimate le6
fled counterdauns seeking payment
tighuorto
jw&ble busin;
of about $1.5 b i o n borrowed by the
interests." the court said. 'their cc
I Hunt com~anies.and moved for -sumduct fail& to comport with the sta
mary judgkent on the claims.
dards of fair play.. .. [Farah] was en
The lender Liability theow of the
tled to have its atfain managed
Hunts' lawsuits is a Gent phe~UIecompetent directors and office
non Lender liability hrst athacted
..
widespread attention in 1984, when
The court also upheld a frd
the Texas Court of Appeals afXmed
daim based on a bank's wa?lings tf
the result (although it reduced the
it w u l d declare the loan m defa
$18.9 million award to $18.6 million)
- in S m National Bank of El Aw v.
when in fact the bank either had ma
no decision on the maaer. or d ~ dI
Farah Manufacturino Co.. 678
plan to call the Loan
S.W2d 661.
The court also upheld a dun
'At that tine,
was
daim based on the warnings ti
decided, we really thought it was a
hrah would be bankrupt and p
fairly isolated event:' said Mawy
lodred the next day if Farah were
Poscover of Donohue, Comfeld & Jen- A A Bany Cappello, B e Santa
kins in S t Louis "Now there are liter- Barbara. Calif., attorney who won a d e d as CEO.
ally stacks of lender liability cases multimillion dollar judgmd agaimt
DUTY OF GOOD FAITH
co&
in And it isn't just going one Eonk of America.
- /'
fdthough no separate daim T
way--a few of them are good cax law
~ in- made for breach of good faith,
for the lenders. IimitinR
- the scow of of lender l i a b i i c o n h u and
terferine in a boborrower's affairs not cowt discused good faith in its or
I their Liabilitv."
A. c airy Cappello, a Santa d w - k t h a borrower in good iaith: ion,saying a thrGat made in bad i;
. can be considered duress and that
Barbara Calif.. attornes. who won a and mirre~resentationand fraud
lenders should have acted in gt
m u l d i o n dbllar j u b e n t against
Bank of America in a lender liability MANAGEMENT CHANGE CLAUSES faith rather than making the false.
The Famh case dealt with bank misleading warnings.
suir. said he r e c M about 10 phone
The good faith theory got a
.
calls a 4from borrowers who interference, duress and haud
The dispute centered on W h boost in a 1985 decision. ILMC.
would l i e him to represent
Cappello says the big increase in h r a h s bid tn become CEO of Farah Inc v. I N i n g nust ca. 757 F2d
a clothing manufac- (6th Cu.), upholding a $7.5 mil
these lawsuits may be caused by sw- Manera1 factors. including a poor econ- turer. A management change clause in jury award that included puni
omy. and publicity about large judg- the Ioan ageement gave any two damages.
W C . a food broker in Kr
banks veto power ow any change in
ments.
Many lawsuits are' brought by thehemamgementofFarah,if We. Tenn,alleged its bank faile
fanners who fell victin~to the farm they considered the change. "for any advance funds under a loan ag
airis. he said Farmers who borrowed reason whatsoever, to be adverse to ment. The Sixth Circuit said the c
heavily when the value of their land . t h e interests of the banks." Anv galion of good faith implied in rn
was h@ are now suing their banks change that occurred despite th;. .contract covered by the U.C.C.
when the banks call the loans or insist banks'objections could be treated as a posed a duty on the bank to give
-lice before discontinuinn financ
default
on chanxes
.
. . .. . . . .
--.. in
-. the farmers' mananemerit. The weak economy also a
izk : The lenders, basing their author- :even though the bank h& a dis
the
--- banks. sourrim them to call loans 'ity on that clause. told company dim- ,.tionam r i a to make advances.
Since M.C. the good faith
they would 'COntinLe to hold in more ..:. tdrs that hrah w i s Unacceptable, and 'i.*.,
. :..%..,.
.....:.:if he were elected CEO, the banlcs " ory has been the &is Gf many l e
times. -.:, ..:....
liabiity lawsuits. focusing prim
'When there's good &es, 'the ' .would bankrupt Farah Man. .
on rhe e s t a b w e n t of a cours
banks work with their borrowers, roll and padlock it the next day.
Under the management of two dealing bemeen the bank and
over the loans, work it o r g 5nd another lender for them" C a ~ w l l osaid . lender-backed CEO's. the comoanv's borrower that the b o w e r expec
"But when times are &ugh' h u h got :position in the market dete&rat& . continue despite stnct enforcer
some banks in the country that are in .;and hrah assets were -sold to pay :provisions in the loan agreement
e : v * ~ ~ hottest
e
new area of le
financial trouble. and thev mom ore-ii?interest and reduce the-outstandinn ...
cipitaudy a@& the borkwr." >-.-27~~.bbility
on the loans. Some equipment :liabiity b a widerung of the breac
: . F a d and the cases that f o l
said to hnh competitors, M i t h e duty of good faithand nd t
:
lowed established three orimarv areai one of the Farah lenders 6nancinn the 'rim"said Ca~wilo.a Darmer in

Famh

__

'

. .

'

~~

I1

~~

Third Circuit 15-3400


Property of Advance Media Group

2-

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Case: 15-3400

Document: 003112132545

Page: 420

t sounds like an episode from legal theories such


!-sa
"Dallas."A group of hard-nosed Muciarv resvonsibiIity -na
bankers embark on a secret plan .>me with a buslnesto bankrupt two Texas energy compa- accountable for unfairnenies owned by a family of billionaires, lban or nustakes m
-a
e managemqt decisions
in order to aain control of offshore oil

'

Wheeling and dealing, the banks


k a confuiential
~
information to the
energy companies' cornpentors and
hold off on r e s t r u m the loans
unhl they can work the best possible
terms.
But this isn't a soap opera, and it
h't Bobby and JR Ewmg The sons
of the lace oil billionaire KL Hunt,
Nelson Bunker, Lamar and W h
Herbe- have sued 23 banks and lendinn institutions chan!in~ that the
banks manipulated &ir-loan m c a conspiracy to destroy taro
Hunt-owned energy companies and
create an oligopoly wer oBhore drill-

Though it is not likely to break


new gmund in legal theory, the drama
inherent in this Texas-size ($138 billion m c h n e d damages) &suit has
drawn public attention to an emerging
I set of I d oroblems fa- the bankmg and hding communir;. The Hunt
brothers' Lpwsuit embodies v i r h d y
enry known theory inmrpora(ed
der the umbrella of lender liability.

I
I'

.o I

- \ /I

fi
I

I
Lender liability uses traditional cion, bad faith, breaCh of fiduciary
V I

BY DEBRA CASSENS MOSS

I
I-

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

un;

Debm C a m Moss. a lawyer,


is a repolterfor the ABA JoumaL

duty, breach of conthct, fraudulent


misrepresentation, and violation of
the Sherman Antitrust Act, the Bank
Holding Company Act, and RICO.
The lawsuits indude allegations
that:
The banks controUed Penrod
.- Plaintiffs' lawyers hail recent and Placid's affairs to their own adlender liability iudnnents as an h- vantage. and delayed loan restructurp o m t curb i; th; power of credi- ing to-force the companies ta agree to
tors. The other side-banks and E- unremnable terms, such as a pay~ c i a linstitutions-foresee huge ment schedule that could not be met
losses for banks and as a result, more and a pledge of additional assets as
collateral
cautious lendinn wlicies.
.Many of the banks @anted
Another qt%ion is whether, as
critics charge, these suits are 6led pri- concessions and gay: better c&it
marily m 'stallii tactic to give the terms to other customers. some of
them Penrod and Placid competitors.
plainth% time to raise funds.
W Several banks promised to reThe Hunts' lawsuit w originally
fled as w.separate suits, and then nrucrure Penrod's loan before Februconsolidated The 6rst suif filed in ary 1986. but intended to break that
US. Dihict Court in Dallas last June. promise.
Some Placid creditors disaccuses the banks of crying to destroy
w Company closed con6dential information to pothe Hunts' Penrod D
and- Placid
O'i Comoanv. Its& $3.6 tential bidders for property that
Placid w attempting to seU to pay
biion in damages.
he second suit, ~ ~ b ey d
. k A ~ off its debts, and "sabotaged" efforts
Drilling and Placid Oil in July. charges bv Placid to refinance its debt with anthat the same banks engaged in a oiher bank
.The banla drafted a secret
price-fixing scheme to control offshore oil drilling and seeks $102 bil- plan in March 1986 to m a t e and control an offshore oil drilling oligopoly.
lion
By exercising certain creditors' rights.
the banks wodd determme which
THE THEORIES
The lawsuits p m c k on a litany borrowers would survive, and obtain
of Lender Liability theories: wrongful ownership interests in those compacontrol, domination. economic coer- nies.
~

~~

~~

. -~

.
. .- -.:
. . .. ....
.:-.
Herbert Hunt,
.. ... ....
bit,and Nelson .
. .
Bunker Hunt
;:.:. :.....;::

4 William

charge that

. .

; !,&.;:.+,,j

..banks hove con-

.L.~~..:::*

spired to destroy <


:.;
(heir energy ;.:-:
.:r,.
. ....
.
com~ania. ;.,..--.. :.
I.

.BA JOURNAL.I .MARCH !, ,1987


.a
..
.
.
,=. .>.

Third Circuit 15-3400


Property of Advance Media Group

Page 419 of 806


Page 2365 of 2953

.. .

.. ....'-......
~

...~

..

Wednesday, November 18, 2015


10/19/2006

... .~

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 421

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Banking
Malpractice?

In August. 1984 a Texas court issued a


decision which shockd b a n k c o a s t - t m t .
In State Nar Bank v F a d M&. Ca.' two
Texas Court of Appeals upheld a S19 million
jury verdict against a group of fuwdal institutions for fraud durcSS. and inklltioflal intCt'fermcc
a
oorporalc powas. The
found that while
'endas may
to protectl~timstelegalrjghu
and
business intcfstS
conduct failed to
wagh'ng the
of fair phX.
Of Ihe ha
utility of their respctive conduct. Justice Shulte
decided that
bendis daivcd from
pamining the Icndm' interfamce
-I'y
upcacd thereby the harm to
from." By installing incompetent managanent
and pmmting the election of competent managmenS the ladm
Liable for all
damage the borrower suffered. including lost
profits.
A year later, wen again
when thc Sixth C-it
Cou* of appeal upheld
a 7.5 million d o h jury v&ft b.scd on a
lender's r d d to advance funds up to a
borrowerPscredit limit KM.C ca xNing
T~~ a . 3 the
found that the d-ion
by
a loan officer to cut ORfinancing with no prior

mntaau
.-

..

C?

i ~'
...

~678SW2d661,UIUCCRS764(19(U.T~A~ppU
Puo).

Third Circuit 15-3400

ScpumkrOrro6cr I986

Property of Advance Media Group

Page 420 of 806


Page 2366 of 2953

notice "'amounted to a unilateral decision on hi


part to wind up thecompany":This constituted
's dutv of enmllaiLb
of e
a b-h
performanccw--t,
.ultimately resulted in the comvanv's collamc as
a viable -b
Sinv 1984, judgments against bank have
been coming in thick and fast, with more caxs
k i n g filed every day. With the advent of lender
liability law. it h clear that the days of the
one-sided balance of power between banks and
are ova, While lender liability a an
for years,
of to* law bar been in
it has only recently been applied extensively to
obtain relief for borrowers. Lender liability is
quickly changing traditional notions about the
rights of banks, and is setting new standards
a b u t legitimate conduct between banks and
borrowen.
T h e new standards are often being xt in a
spectacukr way in the form of multi-million
dollar judgments which include large punitive
damage awards. Last summer in California.
apple farmers and the owner of a apple dehydrating plant in which the farmers had invested
obtained a 47 million dollar jury verdict against

.,

,Id,.
690,
3757 F2d 752 (1985. CA6 Tcnn).
4 Id. at 763.

Wednesday, November 18, 2015

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document:
003112132545
.
.

Page:
i-i 422

A B.y Cappello is managiog partner of a SanIa Barbara.

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

dealing or "bad faith breach". This tort is


grounded in the Uniform Commercial Code's
requirement that all commercial transactions be

California law firm. A member

mnn
encouraged by the bank to make terrain busi-

million. which included


court to a total of 66
and the rcmaind
represent one of the most far-reaching decisions
yet in the area of lender liability.

Duress

A third theory of recovery in thew caws is

example. if facts which should be kdxlowd to


Bad Faith Breach
arc true. or promises are m d e with no intention
One of the broadest basa for liability is
du&may be present.
breach of the covenant of good faith and fair Banks have also been found liable for supplying
false or misleading information to third panics
ll-J-'
"
of
who make credit inquiries about a customer.
Supaior Coun No. 112439.
epcomer. a.v M W ~ Flnvac CO., M) NM 680. threatening to call a loan due before the bank

459 PZd 842 (1969).


?Far&, lupn. u 686.

'UCC I-ZOI(19).

Third Circuit 15-3400


Property of Advance Media Group

Page 421 of 806


Page 2367 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 423

Page 422 of 806


Page 2368 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 424

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Financial Management Group Ltd.


Eden Park 11,1755 Oregon P l k e
800-211-8567

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

Dear B i l l and Dattie:

I wculd like to inform you that Stanley J. Ca-ne


w i l l no longer
be servicing Financial. MaM.gem~t Group, Ltd. c l i e n t s in the -ter
area.

r,
w

Stanley has w e d his o f f i c e to Stone Harhr, N. J. ard is pusuing


WsineSS interests fmm that location. I have been informed that for the
near future Stan w i l l not serve c l i e n t s in Iancaster and may not handle
invesbrmts at all.

Fecple clc6e to Stan have asked wz to personally service his clients


until Stan can bring h i s other b u s i m s interests to a cl-.
~e
recognize t h i s separation m y be perrnanent as Stan has indicated a desire
to relocate.
As I rwiewed Stan's f i l e s , I m i z e d mmy people &o I
m e t while I trained and supervised Stan beginning in 1980. Other; 1 met
as a D i s t r i c t Nanager w i t h I E when they were my p x s o ~ clients.
l
I'm
looking forward to gettirq reacquainted and hope you'll continue to allow
Financial Management Gnxrp and myself to serve your invesbwnt needs.
I plan to call you within tke next two months concerning these
matters.
Should ym desire to discvss any issue prior to my call, please
feel free to a m t a c t me a t 569-4100 or 1-800-322-1128.

Rcbert E. X a u f m .
President

Third Circuit 15-3400


Property of Advance Media Group

Sec~rltlcsOffercd through Planner's Serurltlcr Group. Inc.


A Reglncrcd BrokerlDealer
SlPC
Member NASD
Page 423 of Member
806
Wednesday,

Page 2369 of 2953

November 18, 2015


10/19/2006

Case: 15-3400 Document:


003112132545
Page:
425
Date
11/18/2015scam
Jacobson
gets
jail for
role
inFiled:
bribe

US District Court For The Eastern District of Pennsylvana

die

Section 3189 Federal False Claim Act

e
ld
o
$
ila
o
ll"
U
,m
l ugh
u
r.fd
h
tm"gh

frad
~ m e ~ r e c r i n diwuafitying
p.
his"phltoUle1unds.
They areehargLog.mlClar(iis
nOtenUUedtoUammey h e c a w
he sllegodlr used extortim and

Of his to^ employees and r TY


bmadcaoter who workcd as s
mRsUhsnl 101 ISE. Gucrin LesLtfiedst (hetime.
Clark r a ~ "he
d had information
concerning i i l e ~ a shipments
l
to
SouUIAlrica. intorrnrtion on manipnlstingdala having to do with
01- audibm, information eoneorninp payoffs of tarctgn ofrici816, i n f ~ r m a t i o n caneernlng
midending UIe auditom ot the
eorplNtion:'Guc"nteatified.
GUctin said hc aid Clark II
mlUion and agmc81o psy more
beeauee he feared thc attorney's
ntlegrtlons, whether true o r not.
wouldwrerk his plans to a b t r ~ n
eritlcslly MededLundnforhir dctcnspemplre
Mter he "suceuibpd to blackmn4.:Cwrin had asid, "it bothered me'grestiy !I gnawed a t me

Jacobson's sentenc
btrastanwriiW
OaugWendrh
eu

Farmcr Cnned C h e m ~ o n
~ i e r l d e nJaines
l
0 . chr#st,an.
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'

Third Circuit 15-3400


Property of Advance Media Group

Page 424 of 806


Page 2370 of 2953

Wednesday, November 18, 2015


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 426

Eden Park 11, 1755 Oregon Pike


5 6 9 4 1 00

,
i..

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Lancaster, PA 17601

.,

Third Circuit 15-3400


Property of Advance Media Group

Page 425 of 806


Page 2371 of 2953

... .
Wednesday,
November 18, 2015

7 2'r-J

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 427

Date Filed: 11/18/2015

STANLEY CATERBONE
Eden Park 11, 1755 Oregon Pike
569-4100

Third Circuit 15-3400


Property of Advance Media Group

Page 426 of 806


Page 2372 of 2953

Lancaster, PA 17601

6c

Wednesday, November 18, 2015


10/19/2006

--

US District Court For The Eastern VALORE,


District of Pennsylvana
McALLISTER,

Case: 15-3400

3189 Federal False Claim Act


WESTMORELAND, GOULD, VESPER Section
& SCHWARTZ
Document: 003112132545
428
Date Filed: 11/18/2015
A PROFCIClOhALPage:
COf\mR*nON

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

Third Circuit 15-3400


Property of Advance Media Group

Page 427 of 806


Page 2373 of 2953

Wednesday, November 18, 2015


10/19/2006

--

US District Court For The Eastern VALORE,


District of Pennsylvana
McALLISTER,

Case: 15-3400

3189 Federal False Claim Act


WESTMORELAND, GOULD, VESPER Section
& SCHWARTZ
Document: 003112132545
429
Date Filed: 11/18/2015
A PROFCIClOhALPage:
COf\mR*nON

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

Third Circuit 15-3400


Property of Advance Media Group

Page 428 of 806


Page 2374 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Document: 003112132545
ACTIVITIES
FORPage: 430

Case: 15-3400

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015


Thur Fri sat
T ~ m eEsriActual

TS4101

185

Third Circuit 15-3400


Property of Advance Media Group

Page 429 of 806


Page 2375 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

h 8 ADqebSr

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 431

Date Filed: 11/18/2015

QL 90067

FEB 1

::mA~.Culcrr'b

SEE REVERSE
SIDE FOR
INSTRUCTIONS

s
t&--.
......-..

~-

FICTITIOUS BUSINESS NAME STATEMENT


THE FOLLOWING PERSONIS) IS (ARE) DOING BUSINESS AS:
lFictitious B&ess

1.

AUDIO SERVlcBs/mBarr sowD aooIOs

,- Street Address Cltb & State of P r ~ n c ~ pplace


al
of B u s ~ n e r s ~Cal~forp~a
n
2.

-1

Full name a e g l s t r a n t

ZIPCode

1137 north k c a d d e n Place, Lam Angrlem, CA

...

--

Name(~)

90038

( ~corporation
f
show state of ~ncorporat~onl

I
"side-

"ress

City

State

Zip Code

madden Place, La6 Angelas, CA 90038


&
Full name of Registrant
(if corporation - show state of incorporation)

1137

lQorth

Res~denceAddress

1 (1

City

State

--

bullname of Registrant

ZiPGde

(if corpaatlon . show state of inmporatio")

I
i

Residence Address

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...

City

State
-

Full name of Registrant

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.efile - Statement expire


December 31.<*

File No.

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C&~I?*;(

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on &re indiuted by file sump a b

---Cwnty

IHEREBY CERTIFY THAT THIS COPY IS A CORRECT COPY


OF THE ORIGINAI.STATEMENTOL1 FILE I N M Y OFFICE.
!

7.

2 4

a'%>

ry.
1

THE15-3400
L m ANGELES DAILY Y)URI\IAL
Third Circuit
c.uus+n( ,am
Property of

210 South & r w S t r r t . P 0 110. Yo16


Advance
Media
L a AGroup
W k . Wltc.",. Oa)+l
T*.pho12131 6252141

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. . . . . . .-.

Signature & Title

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-L.

Corporation Name

7-

6. New Fict~tiousBusineu
Name Statement

c,N~v(

I f Registrant a corporation r@ below:

-(

Signed

,F

~~~

1 This statement was filed with the County Clerk of


- .
. . . . . .
-

111 corporatlon show state of lncorporat~onl

Zip Code

c-

Page 430 of 806

......... ,_.__-....

Y)URNAL
OF COMMERCE
- REVIEW
Wednesday,
November
18, 2015

**-.I.

210 h

Page 2376 of 2953


- -

~~

L.U(.II*I."

>el7

m s . .strrl.
~ r.o eo. wx
10/19/2006
~
Wlt--"l.
. ~
sM11
.

.-

to File U.S. mdivldual lncqms ,Tak


~et$ih',
.. Federal False Claim Act
Section 3189
.

r r T-R
Court
.*klUS
I- District
Lnr.
,0, For The Eastern District of Pennsylvana
. .
Case:
15-3400 l loon1
Document:
003112132545
Page:
Your riot nam. and l n a t ~ a(if
mum. d s a Or* spouse'. turn wd InlUaO

'
r

I . . . . '

. .

GOM ~ u o n l
.
.
....

Wd

f
Ressnt homo address (Number and ~l,?naWik
' ~ . n m . b aw ,v d w

r:

city. t a m or port ouca. stat*. snd z ~ ~ c o d .


C UCVEri C l T y
Cr(~

///3'/
r

MARY

I _
432b s l nome
Date Filed: 11/18/2015

'

' '

cdcerc/cnwd

:, , +

'

<.

3003 y

/g.

':

.. . : .
. . ~

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
t h mOuat
ShoWlUn
.
,
,
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
bt
p.
'?.:.
.,.
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
. yder I&.&
. + ' : ;.. -

1. mausst
an autornatoc 2.rnontlj eltensoon 01 tln~e'untllJune.15. 1SZ. In whlch
to file F o m 1040 for tho-lender
.
..
,.
w hwal year return until .................... 1................-.- L
.
.
:
.
.
19--.
fw th. .tar. year beginning
A
. . .. . .
and ending ............................................... 19........)<

. -.-....-...-...--.

,.

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'
'

:~.1981,.. .

. . . . . I . .

.,.

.lo I
;l Total income tar liability for 1981 (You n). e s t i ~ t thla
e .ino~nL).
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
,

LI.

........... .......

95 1.981estimated tax payrnwta (include 1980 ov&&nt


1: Other payments (sea instruction E)
)I,

Totai (add l i n n 2.3, and 4)

,bawd u icredit).

. .

..............

..........................

G lncome tax balance due (subtract line 5 fmrn line

1). Pay In full with mlr form

..:.....

,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
l,liny--'i

. . . . . . . . . . . . . .

m . .~

(Aimtruciion fot

., . . . . . . . . . . . ... . .
-.

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u b . w c M i w b r t h i l n m a m d ~ m ~ d ~ r l t + ? a ~ ~ ~ ~ * . m & ~ h & i r ~
. .~ . ~. . ~ ' * ~ ~ * ~ .

.ignature and Verification


I If R e p a r d by Teapayer.-Undu
puraltles ofperluy, Ideclen that Ihave bumlnd'thla form, lndudinp eccMnpnylng schadula
.!a
StdtcllIents, and to the best of my knowledge and bllef. it Is truo, corn(..ndcomplete.

.
IfPrepared by Someone Other Than ~w:&Und.rp.d.y,a of pwfuy, I
I h& &mi&
rrwnpanying schedules and statemants and to Ui. best of my I&i n d bollof. .kbtiuq- ai+,. .dd
. .
buthorized to prepre this form; and that Iam: . '

,.

hymt

pwd cause. MY relationship toihetar&y6rand th.'iwii+v@;tli,


...
.. ...

Third Circuit 15-3400


Property of Advance Media Group

..

.; . .

&

..

t&yuannot
. . .

Page 431 of 806


Page 2377 of 2953

*\,,

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,

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mernbor In &modstandlng of the bar of th.
court .@ (spdfy luWls(l4n)
. :
. ? .
ceitified pubnic accountant qualifiql to p m c t b In (*panjurId)_
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
y
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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. . . . . . . . .. . ..

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 433

Page 432 of 806


Page 2378 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

BROUT&

Page: 434

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

'

E n c l o s e d i s ttie o r i g i n a l and o n e c o p y o f t h e County o f L o s A n g e l e s B u s i n e s s


S t a t e m e n t a s o f Marcti 1. 1982.
The o r i g i n a l s h o u l d b e s i g n e d b y you a n d p o s t m a r k e d o n or b e f o r e A p r i l 30. 1982.
Mail to:
County o f Los A n g e l e s
Office of t h e Assessor

dPFF.) 4

@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

Third Circuit 15-3400


Property of Advance Media Group

Page 433 of 806


Page 2379 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 435

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

VALORE, McALLISTER, CZIESTMORELAIID,


QOULD. VESPER & SCHWARTZ

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

MAINLAND PROFESSIONAL PLAZA


535 TILTON ROAD
NORTHRELD. N] 08225
(a91645-1 i l l

P.O. BOX 311

. 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

Third Circuit 15-3400


Property of Advance Media Group

Page 434 of 806


Page 2380 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 436

Page 435 of 806


Page 2381 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545
Page: 437
JOSEPH F. RODA. P.C.

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

ATTORNEYS AT LAW
301 C4PHER BUILDING

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

July 22, 1987

Mr. Stanley J. Caterbone


554 Berkley Road
Stone Harbor, NJ 08247
Dear Stan:
Enclosed is our statement for services and costs for
July 1, 1987 through July 7, 1987, and an itemization of the
services and costs involved.

Joseph F. Roda

JFR: dlb
Enc.

Third Circuit 15-3400


Property of Advance Media Group

Page 436 of 806


Page 2382 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 438

Date Filed: 11/18/2015

JOSEPH F. RODA. P.C.


301 C I P H E R BUILDING. 36 E. KING 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

J u l y 22, 1987

CATERBONE

ITEMIZED PROFESSIONAL SERVICES


Date
7/1/87

Attorney
JFR

JFR
JFR

Third Circuit 15-3400


Property of Advance Media Group

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

Page 437 of 806


Page 2383 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 439

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

July 22, 1987

FOR PROFESSIONAL SERVICES RENDERED:


~ i the
r
period July 1, 1987
through July 7, 1987:
COSTS ADVANCED:
Copying costs
Long distance telephone

$74.48
1.00

TOTAL COSTS ADVANCED:


TOTAL PROFESSIONAL SERVICES AND
COSTS ADVANCED:

Third Circuit 15-3400


Property of Advance Media Group

Page 438 of 806


Page 2384 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 440

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

14 GREENFIELD ROAD, LANCASTER, PA 17602 PHONE (717) 392-0641

July 2 3 , 1987

Mr. Stanley J. Caterbone


554 Berkley Road
Stone Harbor, NJ 08247
Dear Mr. Caterbone:
On July 14, 1987 we learned you have relocated to Stone Harbor. Until this
morning, I was unable to reach you to discuss the matter of the computer
lease running with us.
you know prior to June, 1987, your credit history with us was execellent
with all obligations paid current. However, we now find the lease is two
months in arrears, with both the June 1 and July 1 rentals being outstanding.
In addition we learned the computer is actually in the shop at Dunlap and
Kerst with an unpaid repair bill of $524.00 levied against it.

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.

Third Circuit 15-3400


Property of Advance Media Group

Page 439 of 806


Page 2385 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 441

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 440 of 806


Page 2386 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 442

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Management Group, LTD


,,".K,.,

WAMCMC".

G..O",

,,o

STANLEY J. CATERBONE
EXECUTIVE VICE PRESIDENT

554 Berliley Road

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

Third Circuit 15-3400


Property of Advance Media Group

Page 441 of 806

Wednesday, November 18, 2015

Securltl~sOffcred through Planner's Securnler Group. Ine.


Page 2387 of 2953
A Reglitered BrokcrlDealer
Member StPC
Member NASO

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

I.

Document: 003112132545

Servioes and f u n c t i o n s of SourWilliams.


111. S t r u c t u r e of S y n d i c a t i o n

V.

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Scope of B u s i n e s s

11.

IV.

Page: 443

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

Third Circuit 15-3400


Property of Advance Media Group

Page 442 of 806


Page 2388 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Section 3189 Federal False Claim Act

Page: 444

Date Filed: 11/18/2015

sWswpE..a...~~-~.~.s2

is a

follwing

The
,

Document: 003112132545

syndication

and

Im.

The

of

to

Bennett

Williams,

Im.

to provide

the

marketing of the 2.6 million o f f i e building to b e constructed

i n downtown York,
function

pr-1

This prqms-a1 is an attecrpt to describe t h e role and

PA.

Swrce Capital

along w i t h the relationships of Bennett Williams,

and the Investor/I-tors.

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

rcapital /approximately 2.6

syndication f e e s ) and to mange the partnership t h r w g h its


dissolved.

is

As per previous conversations, t h e building

m n p l e t e l y from partnership proceeds w i t h t using debt, which

a steady stream of inccme, projected to be between 12%

the p o s s i b i l i t y of refinancing t h e p r o j e c t around t h e =nth

15%w i t h

year i n order to

return the o r i g i m l capital back to the investors.

R1G w i l l

which

also consider developing a F i ~ r C i a S


l e w i c e m n t e r , similar t o that

e x i s t s i n Lamaster.

responsible

for

the

1-

While Bennett Williams w i l l be the major t e n a n t and

up,

f%2 w i l l

consider also a i d i n g i n t h a t pr-

through w n s i o n of t h e i r business to York.

Third Circuit 15-3400


Property of Advance Media Group

Page 443 of 806


Page 2389 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 445

Date Filed: 11/18/2015

I.: DELI% E . B F T T . ..WIUI.W.-zTK GU'E~...~~~E~..IG..~?.,.)


T k Gewral Partner (GP) will be responsible for t k following:

a).

Development

The G.P.

will be r-nsible

for all dsvelcpwnt

involved in t k project.

b).

Construction - The G.P.

will be r q n s i b l e for all construction

pbses associated with the project.

c).

Lait-g - All leasing responsibilities will be of the G.P.


G.P.

The

will have the task of obtaining l a occupancy of the building

i n a reasomble and timely fashion. The G.P.

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.

will be m n s i b l e for the managsent of

both tenants and the building in order to obtain maximum

income and future appreciation given favorable eoomnic oonditions.

Third Circuit 15-3400


Property of Advance Media Group

Page 444 of 806


Page 2390 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 446

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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).

The Syndicator w i l l be r e n s i b l e f o r a l l legal


and a-nting

services rezdsd to register the partnership with

the a p p r w r i a t e regulatory authorities i n order to solicit


investors.

b).

Prospectus - The Syndicator w i l l be reqmnsible f o r the development

to be used to solicit investors.

and prmhction of the pr-tus

c).

Marketing

- The Syndicator

w i l l be responsible f o r the marketing

and s o l i c i t a t i o n of investors i n order to r a i s e the necessary


capital to f i m n c e the project.

d).

Distribution of ~ r o c e e d s- The Syndicator w i l l be responsible f o r


a-nting

and reporting functions necesrary to provide investors

w i t h the progress and performance of the Partnership.

The

Syndicator w i l l be r w n s i b l e f o r the reporting regulations of the


Interm1 Revewe Service f o r

both Investors and the G.P.

The

Syndicator w i l l a l m be responsible f o r U7e distribution of p

both &ring operation and upon sale w r e f i ~ n c i n gof the project.

Third Circuit 15-3400


Property of Advance Media Group

Page 445 of 806


Page 2391 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Partnership

will

be

Pla-nt

Page: 447

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Private

Document: 003112132545

T k

r e g i s t e r e d by t k Securities and Exckr@ Carmisrion a s a

-lation

D, Rule 144 Offering.

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.

Bennet Williams Inc. - General P a r t n e r

. .

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 :

ES% of c a s h goes i n t o actual development

Third Circuit 15-3400


Property of Advance Media Group

of Net P r c c e d s

Page 446 of 806


Page 2392 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 448

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

(gipl-hlwill receive ~ r o x i m t e l y 8% of the capital raie&

in

the necessary services associated with the project.

This

order to perform

imludes all legal, accrxlnting and marketing fees needed.

Bennett-Williams will receive a 3%G.P. developnent fee for pltting the project
together (building design, construction %pervision

The
.

Broker/Dealer

(if

...etc.).

needed) will receive a 1% syndication fee for

registration

partnership.

and

preparation of financial disclosure

This means approximately a8% of

j' iltilding

the capital raised will go into the actual

and grand. This ircludes all 1-1,

of the partmrship.

documents for the

aoaunting, printing, marketing,

With this ratio, the program will be among the most

marketable anywhere in the country.

Third Circuit 15-3400


Property of Advance Media Group

Page 447 of 806


Page 2393 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

FiMnCial
Center
has

Document: 003112132545

to

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LTD. w i l l a t t e c r p t to &welop a F i M I X i a l Service

M a ~ m n t . Grcup,

similar

Page: 449

the L a n c a s t e r Office i n t h e b u i l d i n g b e i n g vndicated.

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

The Center w i l l i n c l u d e the f o l l o w i n g services:

1. F i r e n c i a 1 Planning

Finamial
the

2.

Investment and P o r t f o l i o Management

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

w i l l s t r u c t u r e the C e n t e r similar to that of

LTD

with

the

e x c e p t i o n that Bennett Williams w i l l have a

f o r m a t i o n and the o p e r a t i o n s o f the Center.

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

m n g MG, B e n n e t t W i l l i a m , and the other Major P l a y e r s who wish to

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.

Third Circuit 15-3400


Property of Advance Media Group

Page 448 of 806


Page 2394 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

following

The

of

Document: 003112132545

will

the

be

Date Filed: 11/18/2015

Firms have exprezsed very s t r o n g and f a v o r a b l e i n d i c a t i o n s

i n t e r e s t to s i g n lorg term 1-

this

Section 3189 Federal False Claim Act

Page: 450

premier

agreements f o r -ace.

office

q ~ c elocated

P l e a s e be aware t h a t

i n Downtown York, and mt

irrportantly w i l l be the Only O f f i c e S>acz with on site parking.


will

be

rented

for

$30.00

Parking spa-

p e r month, and t h i s is t h e f a i r market v a l u e , n o t

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

Bennet W i l l i a m s is t h e l a r g s t Real E s t a t e Firm i n the York area,

is one of the L a r i Q t i n C e n t r a l Pennsylvania.

Dave %had is the P r e s i d e n t

and can be reached a t (717) 843-5551.

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

Third Circuit 15-3400


Property of Advance Media Group

3 1 , 5 0 Square F e e t

'

Page 449 of 806


Page 2395 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 451

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

WSH FLOW

WRD COSTS
WISITImi
CCNSTRUCTIa'l
4% CONTINGENCY FEE

$1.960,00CI.O(i

31,000 32. FT. @ $10.00


9,033 SQ. FT. @ $6.00
108 PARKIW SPACES e m/m.

$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

Third Circuit 15-3400


Property of Advance Media Group

$ 1 ~ , 0 ~ k l . ~

$m,oi3o.ix

C ; W ON CAW RETURN

15

$ZB,KKl.Oi,

$Z,~~R,GXJ.IX)

Page 450 of 806


Page 2396 of 2953

Wednesday, November 18, 2015


10/19/2006

,,,,,,,,

. ....
"
"
.......................
..................... <\,,,,,$
:<r,~
CBrl L J D C O b I o
minimam-rccurlly
nrlran filr
I ,I
,
, ,
ir
.II,.,l,
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.

,,

Case: 15-3400

.
~,B,,>~

,,
Document: 003112132545
cl,,,~

Page: 452

Date Filed: 11/18/2015


,

,,,

FBI accl
.......-

I Christian angered I

""...*.

The FBI agent said he i n t e r


viewed numemvr 1SCerocut:rea
ol mnversationr h?
who told h ~ m
which Clark rhowcd full koowld y e of the company's allegedly
illepalactivilies.
The agent raid. 10. instance,
that James Deirrh, a former ISC
financial off~cinl,b d recalled a
Fpnve"aariominwhichc~arksaid
Those (ISC1 people have &
worry. thole pemple are oing to
,*(I,
lames G U ~ C , "
knw
what i t leelsUketoberaped."
Aecordirll to ~ e i t r e h .c l a n
also referred to other ISC olllciald Joseph H. Zilligen. R.Clyde
Ivy. andTerry Faulds an"criminals and r m a W in nvmemur
ennvcmation.theFBIaeentraid.
Thomas Mills, another ISC
linrnelal official. told the F B I
agent !hat in 1988 he observed
Clark spending "an unusual
number of hours a, the phatoc*
w i n g machine."
including
nigh* and weekends. O'CdIaChansaid.
Mills told the sgcm that when
sumrone elre cntered the photocopy mom. Clark memed "very
dratvrbcd and agitated" s t not

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

"

Gucrln has malnlained br


mOOtha that Clark lorced h i m to
sign the severance pay deal with
thceats Of C X W S U R concerning
a b e d wrongdo"
by IS$.$%
PlOYep9. ' ~t B p r d l m i n ~ r yh?aring+acre
nn i s " o c , , r r , n <a,,, hiF I.*.,.

Third Circuit 15-3400


Property of Advance Media Group

Page 451 of 806


Page 2397 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 453

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Management Group, LTD


A2"

M.urr*t*rr.a*

717-5694100 ~ 5 2 1 - 8 5 6 7 SOO-322-1118 (PA only)

lro

MICHAEL M. HARTLETT, CFP


EXECUTIVE VICE PRESIDENT

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

He w a s was63 as Fxecutive V i c e Fresident on July 1, 1987. W e have been


informed that Mr. Qterbne has keen plrchasitq items under FM; Ltd's name and
obtaining cur Brporate discount and rates.

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

kchael M. Iiartlett, CFP


Executive V i c e President

Third Circuit 15-3400


Property of Advance Media Group

Page 452 of 806

Wednesday, November 18, 2015

omnd chmqh mannofa i . N I * k s GIOUP Iffi

A R.p-

M r lPage
D . .2398
h of . 2953
rYrmb.r

S I K

M-b..

NASD

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 454

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

132 E. CHESWUT STREET

LANCASTER,

WILLIAM J PELHAN
BARBARA RElST DILLON

PENNSYLVANIA17603-1552

AREA CODE 717


LANCASTER-394-7247
AKRON.859-I742

August 5 , 1987

IN REPLY REFER TO:

C0127 WOlDV CAT

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.

T h i s p a c k e t i s complete i n terms o f what you need t o process a b a n k r u p t c y t h r o u g h o u r f e d e r a l c o u r t system.


W e , i n c l u d i n g S t e p h e n R . G i b b l e and m y s e l f , a r e g i v i n g no
a d v i c e t o you i n t h e c o u r s e of s e n d i n g vou t h i s m a t e r i a l .
It is
our basic, very s t r i c t policy i n t h i s o f f i c e , t o n o t give l e g a l
a d v i c e t o any c l i e n t , new o r f a m i l i a r , u n l e s s we are f u l l y informed.
o f and f a m i l i a r w i t h t h e p r e c i s e , d e t a i l e d f a c t s o f t h e case, upon
which we c a n b a s e a competent o p i n i o n .

You had mentioned t o m e and t o Stephen G i b b l e t h a t you


wanted t o c a l l S t e p h e n G i b b l e from t i m e t o t i m e t o a s k him l e g a l
I do not
q u e s t i o n s and s o l i c i t l e g a l a d v i c e a s you f e l t n e c e s s a r y .
t h i n k t h a t t h i s i s a w i s e way f o r you t o h a n d l e t h e s i t u a t i o n , S t a n .
P l e a s e f o r g i v e m e f o r g i v i n g you p r a c t i c a l , n o n - l e g a l a d v i c e , when
you have n o t a s k e d f o r i t . However, I a d v i s e you as a f r i e n d t h a t
it i s b e t t e r t h a t you s e e k t h e o p i n i o n o f C a l i f o r n i a a t t o r n e y s , when
you a r r i v e t h e r e , a s t o p r o c e s s i n g t h e bankruptcy p e t i t i o n , o r s i m p l y
as t o q u e s t i o n s you m i g h t have from t i m e t o t i m e . Given t h a t t h e y
w i l l a l s o know your e n t i r e s i t u a t i o n , b e c a u s e of t h e l i t i g a t i o n t h e y
may b e h a n d l i n g f o r you, t h e r e w i l l b e no i s s u e s t h a t a r e o v e r l o o k e d .

OTHER OFFICES
107 WEST MAIN STREET
EPHRATA. PENNSYLVANIA 17522-2014
717-733-2588
Third
Circuit 15-3400717-626-2404

Property of Advance Media Group

402 SOUTHBROAD STREET


LITITZ. PENNSYLVANIA 1 7 5 4 3 . 2 6 0 2
7 1 7of
- 6 2806
6-2775
Page 453

Page 2399 of 2953

250 MAPLE AVENUE


WARRWILLE, PENNSYLVANIA 17566-132C
Wednesday, November
18, 2015
717-786-1123

.10/19/2006
? 3 1

US District Court For The Eastern District of Pennsylvana

Case: 15-3400 Document: 003112132545


Mr. Stanley J. Caterbone
August 5, 1987
Page Two

Page: 455

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

'

It would be extremely dangerous for us, and unfair to you!, ,d


to advise you in this situation when we do not have the information
that is necessary. I feel that it would be very hard for you to communicate all of that over the phone to Stephen Gibble.

I:

I do not mean to imply that we are not happy to send you


these forms out of courtesy to you for the many kindnesses and courtesies which you have extended to us in the past. We very much
appreciate that courtesy and kindness and want to reciprocate. But
we do not want to create an unwise attorney/client relationship.

Again, it is very distressing to hear of your misfortune,


and I sincerely hope that you are able to resolve these problems in
the future, and that, with patience and support, you will be able to
rebuild and succeed.
With every best wish, I am
Sincerely,
SHIRK, REIST, WAGENSELLER AND SHIRK

By:

Third Circuit 15-3400


Property of Advance Media Group

Page 454 of 806


Page 2400 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 456

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

FAX: 0 1 1 8 1 ~ 5 5 0

B i l l T e l l , President PD2 I-tries


Oshaka, Japan

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

If you can gst me a n R-Dat for the S t u d i o , please also g t me a box of 90


miruete blanck tapes, the b e s t q m l i t y available.

cc: T. G a n i l l i o n

Third Circuit 15-3400


Property of Advance Media Group

Page 455 of 806


Page 2401 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 457

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Commonwealt

National Bank

A Mellon ~ a n k ~ ' " ~ " ~ ' ~

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 .

Should e i t h e r you o r your a t t o r n e y wish t o d i s c u s s t h i s matter f u r t h e r ,


f e e l f r e e t o , c a l l e i t h e r myself a t (717)295-3362, o r a t t o r n e y J a c k 3
' . Ream,
who i s r e s p r e s e n t i n g t h e bank i n t h i s matter. He c a n b e r e a c h e d a t (717)
I m i g h t remind you t h a t t h e bank i s i n t h e p r o c e s s o f s e l l i n g
843-8968.
t h e a i r c r a f t . However, s h o u l d you be i n t e r e s t e d i n redeeming t h e a i r c r a f t
p r i o r t o t h e time t h e bank e n t e r s i n t o a n a g r e e m e n t t o s e l l i t , or i f you
d e s i r e t o r e f e r a p o t e n t i a l buyer t o t h e bank as you h a v e i n d i c a t e d i n
c o n v e r s a t i o n s w i t h bank p e r s o n n e l , p l e a s e c o n t a c t e i t h e r M r . Ream o r m e
a t t h e numbers p r e v i o u s l y m e n t i o n e d , i m m e d i a t e l y .
Very t r u l y y o u r s ,

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

Third Circuit 15-3400

Page 456 of 806

The Commonwealth
Pa. 17603
Property of Advance
Media Group National Bank, 28 Venn square;
Page Lancarter.
2402 of 2953

Wednesday, November 18, 2015


1717) 393-5601

10/19/2006

MINNESOTA
MULTIPHASIC
PERSONALITY
INVENTOR'
US District Court For The Eastern District
of Pennsylvana
Section 3189 Federal
False Claim Act
Case: 15-3400

Document: 003112132545
458
S.R. Hathaway and Page:
J.C. McKinley

Date Filed: 11/18/2015

GROUP FORM TEST BOOKLET


& L q J .

-=-

J / / ,7

Third Circuit 15-3400


Property of Advance Media Group

Page 457 of 806


Page 2403 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 459

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Published by: The University of Minnesota Press


Distributed by: National Computer Systems, Inc.
P.O.Box 1416
Minneapolis, Minnesota 55440
0

MINNESOTA MULTIPHASIC PERSONALITY INVENTORY


CoovriahP
,. THE UNIVERSITY OF MINNESOTA
1943. Renewed 1970. This Test Booklet 1982 All tights resewed.
Disbibuted Exclusivelv by NATIONAL COMPUTER SYSTEMS. INC.
Under ljcen& horn m e University of Minnesota
*'Minnesota Multi~hasicPersonalty Inventow" and "MMPI"
are lradernalks-ownedby The university Minnesota

.,

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

Printed in the United States at America

Third Circuit 15-3400


Property of Advance Media Group

Page 458 of 806


Page 2404 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Section 3189 Federal False Claim Act

Document:
003112132545
Page: O
460
DateBOOKLET.
Filed: 11/18/2015
DO
NOT MAKE
ANY MARKS
N THIS

Case: 15-3400

1. I like mechanics magazines.

2. 1 have a good appetite.

'i)

4 4

3. 1 wake up fresh and rested most mornings.

4. I think I would like the work of a libra5ian.

23. 1 am troubled by attacks of nausea and


vomiting.

24. No one seeks to understand me.<

.5. 1 am easily awakened by noise.

22. At times I have fits of laughing and crying


that I cannot control.

C,

/'

6. 1 like to read newspaper articles on crime. \

/-

25. 1 would like to be a singer.

26. 1 feel that it is certainly best to keep my


mouth shut when I'm in trouble.

7. My handsand feet are usually warmenough.

27. Evil spirits possess me at times.


8. My dail; life is full of things that keep me
interested.

- \

/j/

28. When someone does me a Wrong I feel I


should pay him back if I can:just for the
principle of the thing.

9. 1 am about as able to work as I ever was.


10. There seems to bea lump in my throat much
6
of the time.
I
11. Apersonshould try to unqerstand hisdreams
and beguided by or take yarning from them.
12. 1 enjoy detective or mystery stories.
13. 1 work under a great deal of tension.

3
.

)(

e .

15. Once in a while I think of things too bad to


talk about. /j
16. 1 am sure I get a raw deal from life.
17. My father was a good man.

fi
\

peculiar and strange experiences.


34. 1 have a cough most of the time.

35. If people had not had it in for me I would


have been much more successful.
36. 1 seldom worry about my health.

/C
/
\

19. When I take a new job. I like to be tipp doff


on who should be gotten next to.

/
\

18. 1 am very seldom troubled by constipation.

20. My sex life is satisfactory.

31, 1 have nightmares every few nights.

32. 1 find it hard to keep my mind on atask orjob.

14. 1 have diarrhea once a month or more.

29. 1 am bothered by acid stomach several tin&


a week.
/
30. At times 1 feel like swearing. [

&

37. 1 have never been in trouble because of my


sex behavior. (
'

38. During one period when I was a youngster


I engaged in petty thievery.
39. At times I feel like smashing things.

21. At times I have very much wanted to leave


home.

40. Most any time I would rather sit a d dayaream than t o do anything else.

Go on to next page
Third Circuit 15-3400
Property of Advance Media Group

Page 459 of 806


Page 2405 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

41. 1 have had periods of days:~eeks, or months


when I couldn't take care fthings because I

Page: 461

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

60. 1 do not read every ditorial in the newspaper every d a d

couldn't "get go
nig
..

61. 1 have not lived the right kind of life.

42. My family does not like the work I have


chosen (or the
intend to choose for
my life work).

.-

43. My sleep is fitful and disturbed.

time my head seems to hurt all


over.

45. 1 do not always tell the truth.

46. My judgment is better than it ever was.

.c

47. Once a week or oftener I feel sudd nly hot


all over. without apparent cause.

63. 1 have had n o d i f f i c u l t ~ n or


g holding
my bowel movement.

64. 1 sometimes keep on at a


lose their patience with me.
65. 1 loved my father.7

66. 1 see things or animals or p F l e aro'und#f:


glSt
that others do not see.

67. 1 wish Ico Id be as happy as oth&


be.

49. It would be
thrown away.

all laws were

L Ce
W

seem to

68. 1 hardly ever feel pain in the back of the neck.

health as most

/C

69. 1 am very strong1


myown sex.

50. My soul sometimes leaves my body.

c?

&w

48. When I am with people I a


hearing very queer things.

51. 1 am in just as
(
,. ~ .
of my friends.

62. Parts of my body often have feelings like


burning, tingling, crawling, or like "going to
sleep."
7
0G
m I f 6f i

ttracted by members of

1.7
-

70. 1 used to lik2>rop-the-handkerchief.

71. 1think agreat many people exaggeratetheir


52. 1 prefer to pass by school friends. or people Iknow but .have not seen for a - ng time.
unless they speak to me first.

i'

misfortunes i n order to gain the sympathy


and help of others
72. 1 am troubled by discomfort in the pit of my
stomach every few days or oftener. F

53. A minister can cure disease by

k-

putting his hand on your head.


73. 1 am an important person.

54. 1 am liked by most people who know me<l


55. 1 am almost never bothered
the heart or in my chest.

palns over
p
'
\

56. Asa youngster I was suspended from school


one or more times for cutting up. /

/
57. 1 am a good mixer./\

74. 1 have often wished I were a girl. (Or if you


are a girl) I have never been sorry that Iam a
girl.
75. 1 get angry sometimes.

76. ~ o soft the time 1 feel blue.

77. 1 enjoy reading love stories.

58. Everything is turning outjust liketheprophets of the Bible said it would.

/
)

59. ihave often had to take orders from someone


who did not know as much as I did. /

78. 1 like poetry.

79. My feelings are not easily hurt.


80. I sometimes tease animals.

f-

<

Go on to next page
Third Circuit 15-3400
Property of Advance Media Group

Page 460 of 806


Page 2406 of 2953

Wednesday, November 18, 2015


10/19/2006

//

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

81. 1 think I would likethe kind of worka forest


ranger does.

Page: 462

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

101. 1 believe women ought t p & v e as niuct


sexual freedom as men: f - ,
& 0,

82. 1 am easily downed in an argument.

102. My hardest battles are with myself.

83. Any man who is able and willing to work


hard has a good chance of succeeding.

103. 1 have little or no trouble with my muscle:


twitching or jumping.

84. Thesedays I find it hard not to give up hope


of amounting to something.

104. 1 don't seem to care what happens to me.

>,

..

.. >. .... .

..

hen I am not feeling well I an


85. Sometimes I am strongly attracted by the
personal articles of others such as shoes.
gloves, etc.. so that I want to handleorstea
them though I have no use for them.

106. Much of the time I feel as


something wrong or evil.

86. 1 am certainly lacking in self-confidence.

107. 1 am happy most of the time.

87. 1 would like to be a florist.

108. There seems to be a fullness ' my head o


nose most of the time.

(I;

88.

cross.

yI d 9

/
1 usually feel that life is worth while. \

89. It takes a lot of argume o convince most


people of the truth.
I

109. Some people are so bossy that I feel like


doing the opposite of what they request
even though I know they are right. /Z
a

90. Once in a while I put off u


what I ought to do today.

tomorrow

111. 1 have never done anything dangerous f o ~


the thrill of it.

91. 1 do not m ~ n dbeing made fun of<

2 . I would like to be a n u s

110. Someone has it in for me.

112. 1 frequently find it necessarytostand u p f o ~


what-l think is right.<

93. I think most people would lie'to get aheaclf


113. 1 believe i n law e n f o r c e m e n t . 7

94. 1 do many things which I regret afterwards


(I regret things more
more often than
others seem to).
/
95. 1 go to church almost every wee/\
96. 1 have very
my family.

arrels with members of

97. At times I have a strong urg


thing harmful or shocking.
,.

0
..

. ....
:i
*-

do some-

98. 1 believe in the second coming of Christ. 1


99. 1 like to go to parties and
where there is lots of loud fun.
100. 1 have met problems so full of possibilities
that I have been unable to make up my
mind about them.
.f,'

114. Often I feel as if the


about my head.

were a tight banc

>

115. 1 believe i n a life h e r e a f t e r : T

/P"

116. 1 enjoy a ra
on it.

-r'

or game better when I be

117. Most people are honest chie


fear of being caught.
118. I n school I was sometime
principal for cutting up.

sent to thc

119. My speech is thesame as always (not fastel


or slower, or slurring; no hoarseness). (
120. My table manners are not quite as good a'
home as when I am out in company.

Go on t o next pagl
Third Circuit 15-3400
Property of Advance Media Group

Page 461 of 806


Page 2407 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

201. 1 wish I were not so shy.

Page: 463

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

222. It is not hard for me to ask help from my


hough I cannot return the

202. 1 believe I am a condemned person.

P
: 7/h-wsor ,
:
Tifib
'i=
223. 1 very much like huntin

203. If I were a reporter I would very


to report news of the theater.

224. My parents have often objected to the kind


of people 1 went around with.

204. 1 would like to be a journalist.

225. 1 gossip a little at times.

205. At times it has been impossible for me t o


keep from ealing or shoplifting something.

226. Someof my family have hab~tsthat bother


and annoy me very much-

206. 1 am very religious (more than most people).<

227. 1 have been told that I walk during sleep.

7
like to flifl. f

207. 1 enjoy many


recreation.
1
2 0 I

ferent kinds of play and

-p

210. Everything tastes the same.


21 1. 1 can sleep during the day %not

229. 1 should like to belong to several clubs or


lodges.
/

at night.

231. I like to talk about sex.


I

?m

f=

216. There is very little love and companionship


in my family as compared to other homes.

P
P

e particularly to see

then get over it soon.


pendent and free

es are nearly all in sympathy with


237 me.
My

&I$

219. 1 think I would like the work of a b 11 in


contractor.

238. 1 have periods of such great restlessness


that I cannot sit long in a chair.

220. 1 loved my mother.

239. 1 have been disappointed in lov

221. 1 like science.

240. 1 never worry about my looks.

Third Circuit 15-3400


Property of Advance Media Group

F=

<

235. 1 have been


from family rule.
236. 1 brood a great deal.

T?P

234. 1 get mad easily

myself worrying about

218. It does not bother


animals suffer.

3.

233. 1 have at times stood in the way of people


who were trying to do something, not
because it amounted to much but because
of the principle of the thing.

214. 1 have never had any breaking out o n my


skin that has worried m e . 4
J
215. 1 have used alcohol excessively.

217. 1 frequently fin


something.

232. 1 have been inspired to a program of life


based on dut- which I have since caref lly
f0llOWBdr(
3 6 >
&
B

Ci

230. 1 hardly ever notice my heart pounding and


I am seldomshort of breath<

e more likgachild than a

213. I n walking L am very careful to-step over


sidewalk cracks.
t

228. At times I feel that I can make up my mind


with unusually great e a s e / r

209. 1 believe my sins are unpardonable.

212. My people tre


grown-up.

IAJ (

Page 462 of 806


Page 2408 of 2953

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Wednesday, November 18, 2015

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

441. 1 like tall women.

Page: 464

459. 1 have one or more bad habits which areso

strong that it is no use in fighting against


them.

'42. 1 have had peri ds in which I lost sleepover

worry.

460. 1 have used alcohol moderately (or not a

because oihers feel that I


about it in the right way.

444. 1 do not try to correct

not going

--

461. 1 find it hard to set aside a task that I have

undertaken, even for a short t

ple who express

an ignorant belief.

462. 1 have had

hen I was young

7"
I

463. 1 used to like hopscotch.

464. 1 have never seen a vision.

447. 1 am often inclined to g o out of my way to

465. 1 have several times had a hange of heart

about my life work<


466. Except by a doctor's orders I never take

drugs or sleeping powder<

448. 1 am bothered by people outside. o n

cars. in stores, etc.. watching me.

-i

portant (such as automobile licenses, etc.).


468. 1 am often

I am so crossand

469. 1 have often found people jealous of my

451. My worries seem to


into a crowd of lively

good ideas, just


thought of them first
1

'p

452. 1 like to poke fun at people.

470. Sexual things disgust me.

453. When I was a child I didn't

471. In school my marks

member of a crowd or gang.

bad.
auite reaularlv
-

454. 1 could be happy living all alon

talk of the group I belong to.


474.
456. A person shouldn't be punished for break-

&

ing a law that he thinks is unreasonable.

475. When I am cornered I tell that portion

the truth which is not likely to hurt me.

uld never taste

476. 1 am a special agent of God.

458. The man who had most to do with me


when Iwas a child (such as my father, step-

(-

[/
1 have to urinate no more often than ottiers. 4

473. Whenever possible Iavoid being in acrowd.

455. 1 am quite often not in o n the

an alcoholic drink.

portment were

472. 1 am fascinated by fire.

in the woods or mountains.

457. 1 believe that a person

grouchy.

of a ciowd.l(

467. 1 often memorize numbers that are not im-

gatherings just to be with

446. 1 enjoy gambling for small stakes.

wina p c ~ s o m e o n who
e has opposed
me.

starting or holding

my urine.

445. 1 wasfondof exciteme


(or in childhood).

all).

443. 1 am aDt to Dass uo somethina I want to do

(-1

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

father, etc.) was very strict with me.

477. If I were in trouble with several friends who

were equally to blame. I would rather


the whole blame than to give them
Go on to next page

Third Circuit 15-3400


Property of Advance Media Group

Page 463 of 806


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Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

555. 1 sometimes
to pieces.

that I am about to go

Page: 465

562. The one to whom I was most attached and


whom I most admired as a child was a
woman. (Mother, sister, aunt, or other

556. I am very careful about my manner of d r e s s r


/>

"Oman.'

557. 1 would like to be a private secretary.

P
pried

558. A large number of peo


sexual conduct.
559. 1 have often been
of the night.
560. 1 am greatly both
put things.

Third Circuit 15-3400

T-ories betterthan romantic

stories.

are guilty of bad


564. 1 am apt to pass up something I want to do
when others feel that it isn't worth doing.
in the middle
565. 1 feel like
high place.

when I am o n a

by forgetting where I

561. 1 very much like horseback riding.

Property of Advance Media Group

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

566. 1 like movie love scenes.

/
1

Page 464 of 806


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Wednesday, November 18, 2015


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

W*W,II

YIUS,*I*I

Document: 003112132545

Page: 466

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

n Park II. 1 1 5 9 O r w o n PI*.


U n c a e r , PA 1Ywr
1694100 1 0 0 - S l $ J S L 7
U 1 D i n - i I 2 4 [PA o n w

ROBERT E. KAUFFMAN
PRESIDENT

Mr. stanley C
554 BerEley
Stone

mad
New Jersey

08247

Dear Mr. CaWe,

the Board of D i r e s t o m , are in ramipt of y~


rn back to the oorpcaation.

note offer-

to sell shares or

A l l u i me to first a&9ress the easy points of your pro-1:


1. William Um&x does mt, at this

-,

never cuqmw~teany ex-staff

desire to cash out h i s

2.

We w i l l

3.

We w i l l not give you 0% share of Trl: stmk for nostalgic


reasons as we dd rat want any dissident stcckholders in our
Alture. Flhen we buy s M c , it will be the entire ammt.

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

psaple for any reason.

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,

will mibe the price by:

1.

m
' e build up of any debt,

2.

'me continued d e f m t i o n of our corporate nan!e will reduce

costs, interests and penalties

its value
3.

Dur time

penaingbjnlauptcy

Third Circuit 15-3400


Property of Advance Media Group

ask in c l e a l i q with either -pr

Page 465 of 806


Page 2411 of 2953

your

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 467

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

have che~=& to prwc it), bLPglJTY.

,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 ,

any a l e of sta2k will also n q u k e an agreanent


kMch settles any
all

not to &fans= cur firm and a covenant


claims aguinst the corporation.
Stan,

our skirrurte is that toclay you would raceive ahout

$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

Fincuwial Mwagemcnt &cup, I A A .

Third Circuit 15-3400


Property of Advance Media Group

Page 466 of 806


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Wednesday, November 18, 2015


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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 468

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Financial Management Group Ltd.

ROBERT

E. KAUFFMAN

PRESIDENT

M r . Stanley J. Qterimne
554 *?Hey RCx5.1
Stone Harbor, New Jersey 08247
Dear Stan:

We have been advised by our legal counsel not to personally


any matters m q a r d h g your past affiliation and stock
prqcsal with our firm.
dxxms

Henceforth, s h a d ycu desire t o d h m s any ma-,


please have
awrneys contact cur attorneys R u s s e l l Krafft G n b e r & H u b e r at
(717) 569-5383, as we will rm l q e r deal with you on any matters at
any time.

your

R.E.

Third Circuit 15-3400


Property of Advance Media Group

Page 467 of 806

Kauffman

Wednesday, November 18, 2015

Sccvrltln Offered through ~1anncr.sSecurltln Group i n r


Page 2413 of 2953
A Regln~ed
BmkerlDealer
Member SlPC
Membcr NASD

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 469

Specialists in Radio Communications


309 East White Horse Pike Absecon, N.J. 08201

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PLEASE PAY FROM THIS INVOICE. N O OTHER STATEMENT WILL BE RENDERED

Third Circuit 15-3400


Property of Advance Media Group

Page 468 of 806


Page 2414 of 2953

Wednesday, November 18, 2015


10/19/2006

OC!

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

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Third Circuit 15-3400


Property of Advance Media Group

Page 469 of 806


Page 2415 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

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Wednesday, November 18, 2015

Page 2416 of 2953


EMERGEWCY
~ Q O MADMISSION RECORD

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 472

Date Filed: 11/18/2015

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Page 471 of 806


Page 2417 of 2953

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Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Angina

0 Psychiatric lll?err
0 Allergy.

2 Perm. Pacemaker
0 CHF

0 Diabetes
0 Hypertension

Ei E P ~ ~ ~ P S V

M.I.

Othet Heart Cond8cion

0 Pulma>ary Condation
J

0Trauma
0 Psycho Service
Notilacd
Notification
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TREATMENT I N PROGRESS O N ARF


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CPR

Medical

CVA

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Chronic Lung Osrorder

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

REASON FOR ER VISIT Weight

PAST HISTORY

Page: 473

L/ 1i 4.4j$-

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-.

Airway: Oral: InNbatedSize:

Visual Accuity

0s

Rcr~rmdcd
Family
Social Service

0I V
0 Monitor

OD

Police

0
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Clergy

0S

A""eb

nMental Health
-

Orugr

Backboard
Phila. Collar
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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-

-K e t
rot

Ph

0Cap GI"
OCul~re
DISCHARGE PLANNING

0Smial Service

0Cart Care

0 Wound Care

0 Head Trauma

X43AYS

nER Inrt.
Third Circuit 15-3400
Property of Advance Media Group

Page 472 of 806


Page 2418 of 2953

Wednesday, November 18, 2015


CHA7T

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 474

Date Filed: 11/18/2015

. . .1 S : . i : c s Exmination (Circle or enter appropriate r e s p n s e s )


..., ..

1. ;:-zc:rmce
a.

and Behavior

Thin, (herweight,

Pnysical Characteristics:
2

Looks older, Looks younger, Effeminate, I.


Ill a t ease, Healthy, Sickly,
I

Other:

Dress/Graxing:

b.

ticulous, Disheveled,

Ina$propriate/bizarrz.
Other:
c.

b a t o r Activity:

Dystonic, Graceful, Clumsy,

Tics, R q e t i t i v e m v m t s , Posturing, Facial grimaces, Trcmrs,


Rigid, Relaxed, R e t a d & , m a t i v e .

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.

Affect (outwad n-anifestation of r r d ) :


Incongruent, Full range, Constricted

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 :

Third Circuit 15-3400


Property of Advance Media Group

Page 473 of 806


Page 2419 of 2953

IP.

mphoric, Elevated &thymic ("n&nral)


./

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 475

Date Filed: 11/18/2015

~ ; ~ s a i rw
r dh ~ ~ ( 5t~ ~s: : : : .

O;l~ei-:

b.

Tn,ic$t.

Process:

Ov?r&straction,

Dtclusively ~a::'.:

(:.Y : :

(unrclatecl thouqhts), f l i g h t n i iC:.;.2:

s&-related

ideas)

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(kehaviors) , Phobias, Row.

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s
content) : O
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2.

I%illucinstions (describe and specify contcntl:

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Auditory, Olfactory, Custdtory, Tactile@

Third Circuit 15-3400


Property of Advance Media Group

kw4.

h r k d LU.*
Page 474 of 806
Page 2420 of 2953

r.:

2?*,k

vJ-

Czlusions (specify content) : Extern1 co:;t :.?:,

Wednesday, November 18, 2015


10/19/2006

~4
~

crl.

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

4.

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 476

Date Filed: 11/18/2015

Scnsorim:
,.
a.

Orientation:

Orientcd to:

perform 7's, 3's.


Ot!!?r:

c.

I.'m-oqf: recent:

In-paired,

Pamte:

Inpaked,

i+!,,,i of I(nok:lcd-je: F z l w averag?, Averag

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e.
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rcc
& l o t average, i

age,

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f . J u 2 q ~ ~ x t?ppropriate,
:
O t i k r:

5.

Insicht:,
Ph?Li'i~i!llncss and attributes

ness

hiit

tp internal causation, Amnits ill-

.-

-..

accepts no responsibility for participating in i t s

trmtwxt.
Other :
111.

Substance Abuse Ilistory:


a.

b.

Current drug/alcohol Use


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...

Previous Drug/Alcohol Treatnent:

Third Circuit 15-3400


Property of Advance Media Group

Page 475 of 806


Page 2421 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

c..

Document: 003112132545

i;;lcx~ltI.*icr?l

Third Circuit 15-3400


Property of Advance Media Group

data:

Page: 477

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

(e.9. h i s t o q of diabetes, cardiac pm05lc~s)

Page 476 of 806


Page 2422 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400
V.

Document: 003112132545

Page: 478

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Current Ik-dication (Specify dosage and last dose)

F * ~ : h J b+Sk\b
\

q%w

5 . Provisional Diagnostic Impression (Dm111)

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DATE

Third Circuit 15-3400


Property of Advance Media Group

Page 477 of 806


Page 2423 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

--D 4 i C

.illERAP I ST

Document: 003112132545

Page: 479

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

1:SIITAL HEALTH S E R V I C E S OF CAFE t<AY COUiITY I I!:.


PROGRESS NOTES
Clicnt ' s

n /

/?

Third Circuit 15-3400


Property of Advance Media Group

Page 478 of 806


Page 2424 of 2953

fl

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 480

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Court told attorney Clark


z-/ to stop ISC 'crooks'
tried
7-90
.

,-

by Tim Mekeel
and Ernest Schreiber
hew Era Slafl Wr ters

had removed, theFBI agent said.


O'Callaghan's testimony came
in a federal court hearing over
the settlement of a severance
PHILADELPHIA - The for- deal for Clark.
mer top attorney a t International
Clark signed the deal with GueSignal & Control regularly did
the right thing when he encoun- rin and his personal holding comtered wrongdoing inside the com- pany, Parent Industries Inc.
pany, an FBI agent conceded Gcerin later established a $2 million escrow account to cover payhere Wednesday.
ment of the deal.
William A. Clark, formerly
But on March 28, the U.S. AtISC's vice president and general torney's Office won a federal
counsel, tried to steer ISC execu- court order freezing the account
tives away from illegal actions and blocking the payouttoClark.
and made "extra efforts" to asThe federal prosecutors arsist federal investigators, said gued that Guerin earned the
Special Agent Gerard O'Cal- money through racketeering and
laghan.
fraud, so the money was forfeitUnder cross-examination by able to the government.
Clark's lawyer, O'Callaghan conClark likewise was not entitled
firmed that Clark even hired an to it, since he knew that it was
outside law firm to advise ISC fi- earned by criminal schemes, and
nancial officers on how to re- he used that knowledge to extort
spond to questionable ISC con- the deal from Guerin, the protracts they had uncovered.
secutors said.
Clark went as far as to replace
In the two-day hearing, the
incriminating documents that U.S. Attorney's Office is seeking
ISC founder James H. Guerin to extend the freeze by 90 days.

Third Circuit 15-3400


Property of Advance Media Group

Page 479 of 806


Page 2425 of 2953

Clark wants to liftthe freeze, and


get his $1.76 million share of the
escrow account.
Judge Thomas O'NeiU did not
indicate when his ruling will
come.
Wednesday Aorning ~ u n
O'Callaghan, in response to questions by Assistant U.S.Attornej
Robert E. Goldman. relatine nu
merous times when ~ l a r re
6
ferred to Guerin and his col
leagues a s "criminals ant
crooks."
But in the afternoon, unde
cross-examination by Clark's at
torney Charles D. Sheehy, thc
FBI agent confirmed other as
pects of Clark's conduct.
It was Clark who called to Gue
rin's attention the illegality o
reimbursing ISC employees wh
attended a fund-raiser for presl
dential candidate Alexande
Haig, saidO'Callaghan.
It also was Clark who made a
"extra effort" to supply a gran,

See CLARK, Page A4

Wednesday, November 18, 2015


10/19/2006

I * o d . r l r a YURICIPa I R A I H I C I .

US District Court For The Eastern District of Pennsylvana

MUNiClf'ALCase:
COURT
OF BOROUGH
15-3400
Document:
OF A 003112132545
VALON
Address:

Page: 481

<m196>716 - l l l . < r r ..I. P W ~ C ~ U

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

DEFENDANT'S COPY

M u n i c i p a l Building, 3100 D u n e Drive


Avalon, N. J. 08202

I TO

Stanley J. Caterbone
2323 New Danville Pike
Conestoga, PA 17516-36

The records of this court indicate that


a complaint charging you with

0.p.e.e....df.oho1.....coLLt.i%i.n.e.K
....i.n....!!

in this court on the

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.

COURT APPEARANCE IS MANDATORY.

. at

7:30 p.m.

...................................................

lf you wish

VIOLATION CANNOT BE PAID THRU VIOLATIONS BURE

NOTE: Canadian Residents Please Send U. S. Currency.


IF YOU FA11 TO APPfAR OR PAY THE PRESCRIBED PENALTY:
RESIDENTS OF NEW JERSEY: (1) A warrant will be isssued for your arrest; (2) you may be subject to contempt of court and additional
penalties, and (3) you may be subject to possible revocation of your driving privilege by the Director of the Division of Motor Vehicles.
NON-RESIDENT MOTORISTS: (1) Your driving privilege in New Jersey may be revoked, (2) your own Commissioner of Motor Vehicles
requested to take action against you, and (3) a warrant may be issued for your arrest should you be found in this State.

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
......................................................

"

(Jude or Court Clerk)

Office Houn:

Mon. thrv Fri, 8:3O a.m. t o I p.m. 8 2 t o 4 p.m.


.............................

(609) 967-4457
(609) 967-8200
Telephone: .........................................................................................................................................................

(Please
return
this Notice and your Summons when making
A receipt will be sentWednesday,
to you only if November
your payment
accompanied I
Third
Circuit
15-3400
Page payment.
480 of 806
18,is2015
a
self-addressed
envelope.)
- - Property of Advance Media Group
Page 2426 of 2953
10/19/2006

1 4 0

US District Court For The Eastern District of Pennsylvana

Case:
15-3400
Document:
003112132545
MUNICIPAL
COURT
OF BOROUGH
OF AVALON
Address:

Section 3189 Federal False Claim Act

Page: 482

Date Filed: 11/18/2015

DEFENDANT'S COPY

M u n i c i p a l Building, 3100I D u n e Drive


Avalon, N. J. 08202

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

The records of this court indicate that


a complaint charging you with

......................

VIOlAT1ON(S)
SECTION

39: 3-17

VIOLATION
DATE IL TIME

8-14-87

SEX

8:42 p.m.
was filed in this court on

failure. to ...exhibit....d r i u e r ! ...~license


(ViolrHon)

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

STONE HARBOR COURT - at


Wt.1

-.!.3~..~.&
.......... If you wisl

to plead not guilty, you must notify this court at least 3 days priw to the new court date.

COURT APPEARANCE IS MANDATORY.

VIOLATION CANNOT BE PAID THRU VIOLATIONS BUR1

NOTE: Canadian Residents Please Send U. 5. Cumncy.

IF YOU FAIL TO APPEAR OR PAY THE PRESCRIBED PENALTY:


RESIDENTS OF NEW JERSEY: (1) A warrant will be isssued for your arrest; (21 you may be subiect to contempt of court and additional
penalties, and (3) you may be subject to possible revocation of your driving privilege by the Director of the Division of Motor Vehicles.
NOW-RESIDENT MOTORISTS: (1) Your driving privilege in New Jersey may be revoked, (2) your o m Commissioner of Motor Vehides
requested to take action against you, and (3) a warrant may be issued for your arrest should you be found in this State.
PARKING OFFENDERS- Residents and Non-Residents: In addition to the consequences listed above, a civil judgment may be entered
against you.
BY ORDER OF THE JUD6E

George B. Neidig. Jr.

Office Hours
Telephone:

Moa. thru Fri,

8:3O

Mary A. Monk:

a.m. ta 1 p.m.& 2 to 4 p.m.

(609) 967-4457

Third
Circuit
15-3400
Page 481
of 806
Wednesday,
18, is2015
(Please
return
this Notice and your Summons when making
payment..
A receipt will be sent
to you only ifNovember
your payment
accompvlied
Property
of Advance Media
Group
a salfuddressed
envelope.)

Page 2427 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

15-3400
Document:
003112132545
l.iUNlClPALCase:
COURT
OF BOROUGH
OF AVALON
Address:

Date

Page: 483

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

DEFENDANT'S COPY

M u n i c i p a l Building, 3100 Dune Drive

11-12-87
.............................................................................................

Stanley J. Caterbone
2323 New Danville Pike
Conestoga, PA 17516-36

DATE

The rewrds of this court indicate that

(L

TIME

a complaint charging you with ...........................sp.e.e.ding


....45....mp.h....in . 25..
mph . zone....

............... was filed in this court on th,

(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

12-2-87 -STONE HARBOR COURT

at

7;30 p.m -......


: If you wisl

(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.

IF YOU FAIL TO APPEAR OR PAY THE PRESCRIBED PENALTY:


RESIDENTS OF NEW JERSEY: (1) A warrant will be isssued for your arrest; (21 you may be subject ta contempt of court and additional
penalties, and (3) you may be subject to possible revocation of your driving privilege by the Director of the Division of Motor Vehicles.
NON-RESIDENT MOTORISTS: (1) Your driving privilege in New Jersey may be revoked, (2) your own Commissioner of Motor Vehides
requested to take action against you, and (3) a warrant may be issued for your arrest should you be found in this State.

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

...................................................

(ludne or Court Clem

Third
Circuit
15-3400
Page 482
of 806
Wednesday,
18, is
2015
(Please
return
this Notice and your Summons when making
payment
A receipt will be sent
to you only November
if your payment
accompanied
Property
of Advance Media
Group
a selfsddrened
envelope.)

Page 2428 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

MUNICIPAL
COURT
OF BOROUGH
Case:
15-3400
Document:
O F A003112132545
VALON
Address:

Section 3189 Federal False Claim Act

Page: 484

Date Filed: 11/18/2015

DEFENDANT'S COPY

M u n i c i p a l Building, 3100 Dune Drive


Avalon, N. J. 0 8 2 0 2

Date

TO

........................................ 11-.9 -81

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

The records of this court indicate that


a complaint charging you with

having
..... an unregistered vehicle

d in this court on thc

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.

COURT APPEARANCE IS MANDATORY.

VIOLATION CANNOT BE PAID THRU VIOLATIONS BURE

NOTE: Canadlan R e d d e n h Please Send U. S. Currency.

IF YOU FAIL TO APPEAR OR PAY THE PRESCRIBED PENALTY:


RESIDENTS OF NEW JERSEY: (1) A warrant will be isssued for your arrest; (21 you may be subject.to contempt of court and additional
penalties, and (3) you may be subject to possible revocation of your driving privilege by the Director of the Division of Motor Vehicles.
NON-RESIDENT MOTORISTS: (1) Your driving privilege in New Jersey may be revoked, (2) your own Commissioner of Motor Vehides
requested to take action against you, and (3) a warrant may be issued for your arrest should you be found in this State.
PARKING OFFENDERS-Residentsand Won-Residentr: In addition to the consequences listed above, a civil judgment may be entered
against you.
BY ORDER OF THE JUDGE

George B. Neidig, Jr.

Mary Monks
.........................................................................

(ludic or Coo* Clerk)

Third
Circuit
15-3400
Page 483
of 806
Wednesday,
18, is2015
(Please
return
this Notice and your Summons when making
payment.
A receipt will be sent
to you only ifNovember
your payment
accompanied
Property
of Advance Media
Group
a self-addressed
enve1ope.J

Page 2429 of 2953

10/19/2006

I ,

US District Court For The Eastern


District of Pennsylvana
VALORE,
McALLISTER.

Case: 15-3400

Section
3189 Federal False Claim Act
WESTMORELAND, GOULD. VESPER &
SCHWARTZ

h PROILSSII1NAL COiJQRAnOS
Document: 003112132545
Page: 485
-

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

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

o f

this b i L L

x*wX.x3c-xxx**xw*crx.*

Page 484 of 806


Page 2430 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern


District of Pennsylvana
VALORE.
McALLISTER.

Case: 15-3400

MR.

S T A N L E Y .J

3189 Federal False Claim Act


WESTMORE~AND,GOULD, VESPER &Section
SCHWARTZ
Document: 003112132545
Page: 486
Date Filed: 11/18/2015
A PROF~SSIOSAL 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

TELEF'I.iONE CONFERENCE W I T H S. CATEREmNE


P R E P A R A T I O N O F L E T T E R TO S. CATERHONE
TELEPHONE CONFERENCE W I T H S. CATERBONE.
O U T S I n E O F F I C E CONFERENCE W I T H S.
CATERBONE, I N C L U D I N G T R A V E L
TELEPHONE CONFERENCE W I T H J. HEHAN.
TELEPHONE CONFERENCE W I T H YOI-AND6 ANXI
P H I L CATERBONE.
TELEPHONE CONFERENCE W I T H S. CATERNONE
TELEPHONE CONFERENCE W I T H G. N E I D I G ;
R E V I E W O F DOCUMENTS; CONFERENCE W I T H R.
M C A L L I S T E R AND A . B O N G I O V A N N I RE: C H O I C E
OF COURTS^ TELECONFERENCE WITH
n.
CAMPBELL AND S. CATERBONE
L E G A L RESEARCH RE: K I I V E R S I T Y
J U R I S D I C T I O N AND VENUE: CONFERENCE W I T H
S. CATERBONE; TELECONFERENCE W I T H T.
LANZA
TELEPHONE CONFERENCE WITH G . N E I L I I G
(O'HARA ATTORNEY?+ P. C A T E R H O N E t GI
N E I D I G AND S. CATERHONE
T O T A L HOURS
FOR S E R V I C E S RENnERED
BALANCE DUE

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.

Third Circuit 15-3400


Property of Advance Media Group

Page 485 of 806


Page 2431 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 487

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Twenty-five
...........
lJous??d,,Se~enH

x.

..

(Stanle~_J~-!terbohe_L

............................

EXPLANATION OF RIGHTS IN CONNECTION WITH SIGNING OF


INSTRUMENT CONTAINING CONFESSION OF JUDGMENT, AS
REQUIRED BY OPINION OF SUPREME COURT OF THE UNITED STATES
RE:

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

1. The undersigned certify that the Income of the undersigned,


or conjugal (husband-wife) income with both spouses executing the '
document, is at least $10,000.00 annually.
...
.ti
~.
.<.
+

2.

The undersigned clearly and specifically unaerstand that by


signing the note above referred to, containing a Confession of Judgment clause:

4:

.;&

(a) We and each of us authorize the Prothonotary or Deputy


Prothonotary to enter a judgment against the undersigned, or either
of us, at its discretion and in its favor without notice and without
declaration of default for non-payment, which entry will give the
holder a lien as security for payment upon the real property (including
the home) owned by the undersigned at the time of entry, and a lien
on personal property owned by the undersigned at the time it is given
to the Sheriff for executiofi.
(b) We and each of us waive all right to notice and to have
an opportunity to be hear4 prior to the entry of the judgment on the
Court records, understanding that the only method to challenge this
judgment would be by proceedings in Court to open or strike it which
proceedings would result in substantial attorneys fees which the
undersigned would have to pay.
(Without such 'clause containing a
Confession of Judgment the holder would have to file suit against the
undersigned which would give the undersigned an opportunity for a
hearing which the undersigned does not have by reason of the Confession,
i

3 . The undersigned acknowledges receipt of a copy of this affidavit


and certifies that after reading and fully understanding it, the
. undersigned have signed this affidavit intentionally, understandingly
being willing to sign such
and voluntarily waiving all the above r!ghts,
note despite the consequences set forth above.

:
!

Affirmed to and Subscribed


(

before me this

eel

J / day

.+
.c
.j

,
Third Circuit 15-3400
Property of Advance Media Group

1
Page 486 of 806
Page 2432 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 488

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Financial Management Group Ltd.

ROBERT E. KAUFFMAN
PRESIDENT

Mr.

Millard Johnson

3450 Duff Avenue


Lancaster, PA 17601

Dear Bill :

I am sorry that I was not in the office last Thursday


or Friday to accept a telephone call.
I did, however,
receive your message that you were going to take some
kind of "action".
In order for Financial Management Group to be successful,
!I:ve returned to the full time work of building the
flrm.
We are referring all questions regarding Stanley
J. Caterbone to our counsel Craig Russell of Russell,
Kraft, Gruber and Huber (569-5383).
Should your counsel
need to speak wlth us, he may call Mr. Russell.
(1 have been told that Mr. Patterson no longer represents

the Caterbone family and no action is pending on their


;behalf concerning Stanley.
Best regards,

Robert E. Kauffman
President

REK: lmk
CC

Third Circuit 15-3400


Property of Advance Media Group

Page 487 of 806

Wednesday, November 18, 2015

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

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 489

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

F i n a c i a l Management Group, LTD.


1755 Oregon Pike
L a m a s t e r , PG
17601
(717) 569-5555
Robert Kauffman, P r e s i d e n t
Mickel N. mrtlett, E x e c u t i v e V i c e P r e s i d e n t
P. Alan Loss, Board of Directors
R o b e r t Long, Board of D i r e c t o r s
P e t e r Peneros, Broker

._-.
-

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

Third Circuit 15-3400


Property of Advance Media Group

Page 488 of 806


Page 2434 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

- -

Document: 003112132545

Page: 490

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 489 of 806


Page 2435 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 491

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Ckce Smith, Execxltive Vice President


Pete Wolfson, Sal-n

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

Third Circuit 15-3400


Property of Advance Media Group

Page 490 of 806


Page 2436 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 492

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Farrcers F1-t Bank


L l t r t z , PA 17512

Pete Richter, Pkrmger of La-ter


Glenn Nelsn, President

Shcpping Center Branch

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'

Third Circuit 15-3400


Property of Advance Media Group

Page 491 of 806


Page 2437 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Hunllton Bank
Oregon Plke
Lamaster, PA

Document: 003112132545

Page: 493

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

17601

Chris Izzo, Loan Officer


Corestates, Credit Card M n i n i s t r a t o r

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

Third Circuit 15-3400


Property of Advance Media Group

Page 492 of 806


Page 2438 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 494

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 493 of 806


Page 2439 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 495

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 494 of 806


Page 2440 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 496

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Avalon Police DeparWnt


Avalon, NJ
08247

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

Third Circuit 15-3400


Property of Advance Media Group

Page 495 of 806


Page 2441 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 497

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 496 of 806


Page 2442 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 498

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 497 of 806


Page 2443 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 499

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 498 of 806


Page 2444 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 500

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

Third Circuit 15-3400


Property of Advance Media Group

Page 499 of 806


Page 2445 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 501

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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-

Third Circuit 15-3400


Property of Advance Media Group

Page 500 of 806


Page 2446 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 502

Page 501 of 806


Page 2447 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 503

Page 502 of 806


Page 2448 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

B I L L TO: :S J CgJEEf#EAIZSOCIATES
HARBOR,
TRACKING NOS
REFERENCE

08247

PAC
DAl
ACCOUNT NO.

I N V O I C E NO. 6 - 2 5 0 - 7 3 1 9 7

SENDER'S AME AN0


ACCOUNT A ~ R E S S

1 SHIPPED

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

SENDER A C T I V I T Y SUMMARY
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

Page: 504

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

RC-M-1279 9/05 FEC Repragraphics

Third Circuit 15-3400


Property of Advance Media Group

Page 503 of 806


Page 2449 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545
JOSEPH

F. Page:
RODA.505
P.C.

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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 .

Third Circuit 15-3400


Property of Advance Media Group

Page 504 of 806


Page 2450 of 2953

Wednesday, November 18, 2015


10/19/2006

..--

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--

. "..,..,," ,...

"..,,...

JUSTICE
US District Court For The DISTRICT
Eastern District
of Pennsylvana
Case: 15-3400
MAGISTERIAL
DISTRICTDocument:
NO{;>14> 003112132545

., -.,. ~ , ,

Section 3189 Federal False Claim Act

Page: 506

Date Filed: 11/18/2015

_ 7--I
ox;'y.&gaw

. ----i N C l O E N T NUiilEER UCR NO.

.,..__
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

>*

i;tii:t5 July 1958

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

DutlCfKM dr UoOU 1 %pi,

~&&&"k
County on or about

parIicip(1n11. plucc illnr

tlulvtsr

Lrrc, r r p r u r i n l rhr ;,u?r,l,ofuhovr rl<,,ir#danr/:

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 . ...

.-

s o ~ t d r r3 , 19 157, I certify the compluint has .6een-p~o&b~'cbrnpleted a


/ 'D NOW, on this date
. , <
h i e d , and that there is probable cause for the issuance of process.
. - . ,. .. .. 8

Third Circuit 15-3400


Property of Advance Media Group

Page 505 of 806


Page 2451 of 2953

Wednesday, November 18, 2015


10/19/2006

Clark, Guerin

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 507
-

Continued from Page One

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

K-17-9a

After Guerin and asso-

jury that is investigating ISC


ciate Michael A. Peck
with documents that other ISCofficials balked at sending, be'purged' a file containcause they were too damaging,
ing documents revealthe agent confirmed.
After Guerin and associate Miing wrongdoing by
chael A. Peck "purged" a file
United Chem-Con, it
containing documents revealing
wrongdoing by United Chemwas Clark who reproCon, it was Clark who reproduced and replaced
duccd and replaced those items,
O'Callaahan said.
those items, O'Cal( ~ u e r y nowned 20 percent of
Chem-Con. Twelve others have
laghan said.
been charged with wrongdoing in
a defense contract fraud there.)
~- invest.
Clark also sent the grand. jury shareholders- to
So they went to Clark for help.
one of his memos, which quotes
ISC executive Donald Peterson wondering what liability they
as saying that ISC and Chem-Con miaht face. Clark in turn went to
exchanged false invoices to ~ e i s l e r .
"We are doubtful that the con"make sales look better and collect proper payments from the duct of Deitch or Liddick to the
present date could result in perDefense Department."
sonal,
civil or criminal liability,"
Peterson
said
he,
Guerin
and
:
i fellow ISC executive CarlDreyer Kessler replied.
"However, (they) can and
took part in the scheme, which
should scrupulously avoid particwas started in 1978.
The scheme also served to ipation in the making of misleadmake ISC appear to be a bigger ing representations to parties
company when it went public in outside the company." he said in
his response.
1982,according to the memo.
ISC financial officers "should
While Clark was aware of these
exercise great caution in the
x::~~4~
activities,
~ . : ~ u he
~ was not a p a r t of
, Guerin's inner circle, said O'Cal- months ahead. They should continue to raise questions, should
laghan.
'
Guerin himself told the agent consider documenting their acthat he did not rely onClark's ad- tions and should scrupulously
vice and excluded Clark from avoid acts which would indicate
sensitive discussions - actions complicity," Kessler advised.
which frustrated and irritated
the attorney.
Along that line, Clark told ISC
colleagues that he gave advice to
keep the company clean, but
Later discovered that his advice
was not followed, the agent
testified.
A striking example of Clark's
efforts was his contact with a
Washington, D.C., law firm for
advice on handling- auestionable
.
ISC contracts.
~ response
The ~ e b r u a r1988
from attorney Judd L. Kessler,
submitted to the court as evidence, reveals how the questionable contracts caused internal
j turmoil.
The letter recounts how James
Deitch, then controller of ISC
Group Inc., and Michael Liddick,
then its treasurer, had apI' proached Clark for advice.
They long had suspected that
ISC's financial portrayals were
"less than accurate."
I Their feelings were fueled by
an August 1987 letterPage
from 506
ISC's
Third Circuit 15-3400
of 806
Wednesday, November 18, 2015
; outside auditors (Peat Marwick),
Property of Advance Media Group
Page
2452
of
2953
10/19/2006
in which the auditors criticized
~

~~

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~ o r n p l m n nruuanurrs

LGII'

US District Court For The Eastern


District
of Pennsylvana
DISTRICT
JUSTICE

Case: 15-3400

Document: 003112132545
;;-1-02

IMAGISTERIAL DISTRICT NO.

Page: 508

81

vtnrr v a r $ ~ c ~ p i l n f s

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

<,;;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%&:
-

( i , ~ t ~ r r r ~ ~ ~ ~ r r ~ p ~ r r i c i p o , ~ t s . p ~ u c ~ ~ t ~ t r i r , r ~ r r ~ ~ ~ ~ ~ z r r u . r c p c v r i , ~ ~ i ~ ~ ~ r ~ u r r ~ ,r, I~. :r. ~ ~ ~ b


<:

Criniriul ;::iticl-iiei (P-5)


iis:ll~rilul !iesl;ruinf ( i i - 1 ) IJnltiwful l l ~ e3 P Cu~;iputar (
3 'I'lmft Uy
i
i
' - 3 )
l i o b b u r y (2-1 )

(2) The acts committed by the accused were:@

1)

21- Surglury- Acuuard did u o l x u l u l l y rutsr u b u i l d i n g o r occupied


s t r u c t u r e o r ~;,epiraZe:y tjecured cr n c c c ~ i e dp o r t i o n t k ~ e r c o f , t o w l t : o
1
, t h e property of 2 i n i i n c i n l Hgt. Group 1755 O r e ~ o n2k. I.tinctie$er
l./tc71, ti?e prersise ul; t h e t i u e n o t beitid open t o the p u b l i c o r uJ11cL trtc
+ccubeci was no
sed o r ~ r i v i ' red t o enter, t r i t h t h e i n t m t t o conzl
r c ~ ; u ~ ~ ~ x ~ i - : l C
~ r i s i n a l &~shief tirid T%eft and $p,erof..: C~kiiuter.
.'.
5 i d i t i t r r l t i o n a l l y o r r e ~ k l e ~ t~l ~
;

O C;ur:t

'

pa/
~

as T o entl;in,jrr PerLiufi

02 jiI.Opcr:y.

uachine, 'telephone Breadbox, (


(

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
. . .

---

.;

, 19 1 , ,~ I certify the complaint h;qs been properly -.cop~pleted


a
-.ep
.,
verified, and t l ~ a there
t
is probable cause for the issuance of process.
,'
,
'

Third Circuit 15-3400


Property of Advance Media Group

Page 507 of 806


Page 2453 of 2953

I'

'-

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Count Case:
#:dG
n l a w f u lDocument:
R e s t r a 003112132545
i n t - A c c u s e d dPage:
i d u 509
n l a w f uDate
l l ySection
and3189
kFederal
n o w iFalse
n g lClaim
y rAct
estr:
15-3400
Filed:
11/18/2015
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?

Use o f Computer-Accused d i d a m s , m r , damage o r dc


cornouter swstem. c o m ~ u t e rn e t w o r k , computer S o f t w a r e , cornputt
e o f , w i t ; t h e ' i n t e n t t o i n t e r u p t . ths
ye o r t : x e c u t e a n y scheme
v i c e s by means o f f a l a e
, t o TIC a c c u s e d d i d

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 )

Count #6- Robbery-accused d i d , i n t h e c o u r s e o f c o n m i t t i n g a c r i m e , t h e l


by u n l a w f u l t a k i n g , b u r g l a r y , Unlawful Use of Computer, t h r e ~ . t e n a n o t h e r
o r i n t e n t i o n a l l y p u t her i n f e a r o f immediate s e r i o u s b o d i l y i n j u r y , t o
a c c u s e d d i d thseaten t o knock o u t S t a c y L Waters when s h e t r i e d t o r e s i s
n i s e f f o r t s t o commit t h e a b o v e l i s t e d cr.irnes.
S e c t i o n 3701 ( a - I - i i )

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

Third Circuit 15-3400


Property of Advance Media Group

l I s x u t ~ 2A~ ~ ~ h o r ~ r v ~

Page 508 of 806


Page 2454 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

RECEIVED FROM

Caterbone, Stanley Joseph

Four hundred a'hd sixty-ty-------,,

. .L.,.;'

(,

! I

. ,

Document: 003112132545

/'

t$,

,,
'~-.

Third Circuit 15-3400


Property of Advance Media Group

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

%,.

THE SUM OF

90/100----------

------------,------------L---~-~--~~

/: i
.<
-(*;

. ..
DOLLARS

.',

..

INMATE SIONANRE

Page: 510

COMMlTlNG OFFICER SIGNATURE

Page 509 of 806


Page 2455 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

+.

Page: 511

,,,, .I
./
1755 Oregon .

Conestoga Man Linked to Theft

.. .
I
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'

Document: 003112132545

meht Group Ltd.,


Pike, lost an estimated

$60 Wo-as

.I

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

1.
I

i'

,'

EX-~orkei,Charg&d
In Bvrglgry
.
at Firm
,

The suspect also was served a i


warrant, for terroristic threats in
a case snvolving another female ;
employee of the firm. Caterbone,
a former employee of the coppa- . '
ny, was committed to prison,in
lieu of f20,W bail.

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

:.

'A:

Third Circuit 15-3400


Property of Advance Media Group

Page 510 of 806


Page 2456 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400
D

Document: 003112132545

'

NAME :

,',--

,.

BLOCK:

ATURE:

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

CELL :
,

Page: 512

DATE :

~-

.
!.

ANYONE DESIRING TO COMMUNICATE WITH THE FOLLOWING STAFF MEMBER OR AGENCIES, INDICATE
BY PLACING AN "X" ON THE APPROPRIATE L I N E . REMEMBER ONLY ONE (1) CHECKED PER REQUEST.
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
I N THE DESIGNATED REQUEST BOX. ONLY EXCEPTION GIVE MEDICAL REQUEST DIRECTLY TO THE MEDICAL
TECHNICAN DURING SCHEDULED MEDICATION TIME.

MEDICAL DEPT. - S I C K CALL:


(DESCRIBE THE MEDICAL PROBLEM: WHETHER TREATED BEFORE, BY WHOM?
EDUCATIONfTREATMENT PROGRAM:
(EG.,

GED, ABE, SELF HELP WORKSHOP, ETC.

WELFARE GRANT:
(MUST HAVE 50.00 OR LESS I N PRISON ACCOUNT TO BE ELIGABLE, MUST SUBMIT TWO WEEKS PRIOR
TO D E F I N I T E RELEASE DATE, ALSO WRITE YOUR DATE OF BIRTH AND SOCIAL SECUqITY N W E R ) . .
SUPPLY OFFICER:

( L I S T ITEM NEEDED S I Z E ) :

- , I

SPANISH SERVICES COORDINATOR:


L o s q u e necesitan a y u d a d e c u a l q u i t e r clase y no s a b e n i n g l e s deben d e m a r c a r esta
l i n e a y echar l a p e t i c i o n e n l a caja d e s i g n a d a p a r a s o l o c o t u d e s ( R e q u e s t s ) .
PRoBATIoNIPARoLE:
PUBLIC DEF. &./Mrs.:
RECREATION DIR.:
VOCATIONAL DIR.:
BAIL ADMINISTRATOR:
WORK RELEASE:
CLASSIFICATION COMMITTEE:
OTHER (PLEASE SPECIFY):

:
QEN
DEPUTY WARDEN:
DIR. OF TREATMENT:
ASSOC. WARDEN:
COUNSELOR:
OFFENDER DEV. SER.:
CHAPLAIN :
VISITATION:

AGE :

NAME :

RELATIONSHIP :
YOUR REQUEST (COMPLETE INFORMATION) PLEASE PRINT
I

Third Circuit 15-3400


Property of Advance Media Group

Page 511 of 806


Page 2457 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 513

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

AGENCY :

PERSON ANSWERING REQUEST:

DATE:

ANSWER:

Third Circuit 15-3400


Property of Advance Media Group

Page 512 of 806


Page 2458 of 2953

Wednesday, November 18, 2015


10/19/2006

uu~rr'-u

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400
/

(PLEASE PRINT)Page: 514


Document: 003112132545

Section 3189 Federal False Claim Act

1
Date Filed: 11/18/2015

/]

ANYONE DESIRING TO COMMUNICATE WITH THE FOLLOWING STAFF MEMBER OR AGENCIES, INDICATE
BY PLACING AN'"Xm' ON THE APPROPRIATE LINE. REMEMBER ONLY ONE (1) CHECKED PER REQUEST.
I I F ?IORE THAN ONE L I N E I S CHECKED, THE REQUEST WILL BE RETURNED UNANSWERED. I T I S IMPORTANT
1 THAT YOU GIVE A COMPLETE EXPLANATION.
(PROVIDE ALL NEEDED INFORMATION) AS TO THE
I REQUEST YOU ARE SUBMITTING. T H I S WILL ALLOW A FASTER ANSWER. YOU ARE TO PLACE THE REQUEST
I I N THE DESIGNATED REQUEST BOX. ONLY EXCEPTION GIVE MEDICAL REQUEST DIRECTLY TO THE MEDICAL
1 TECHNICAN DURING SCHEDULED MEDICATION TIME.
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(DESCRIBE THE MEDICAL PROBLEM: WHETHER TREATED BEFORE, BY WHOM?

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TO DEFINITE RELEASE DATE, ALSO WRITE YOUR DATE OF BIRTH AND SOCIAL SECURITY NUMBER)
SUPPLY OFFICER:

GED, d B E , SELF HELP WORKSHOP, ETC.

( L I S T ITEM NEEDED S I Z E ) :

SPANISH SERVICES COORDINATOR:


Los que n e c e s i t a n ayuda de cualquiter c l a s e y no saben i n g l e s deben de marcar e s t a
l i n e a y echar l a p e t i c i o n e n la c a j a designada para solocotudes (Requests).
PROBATIONJPAROLE:
PUBLIC DEF. M r . / M r s . :
RECREATION D I R . :
VOCATIONAL D I R . :
BAIL ADMINISTRATOR:
WORK RELEASE:
CLASSIFICATION COMMITTEE:
OTHER (PLEASE SPECIFY):

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Third Circuit 15-3400


Property of Advance Media Group

Page 513 of 806


Page 2459 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 515

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

REQUEST CONTINUED:

PERSON ANSWERING REQUEST :

IL

AGENCY :

ANSWER:

Third Circuit 15-3400


Property of Advance Media Group

DATE:

Page 514 of 806


Page 2460 of 2953

Wednesday, November 18, 2015


10/19/2006

K E q U E > l kUKM

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IrLLYfiUL

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

(PLEASE PRINT)Page: 516


Document: 003112132545

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

I'

..., . jr.i.r ,i -

NAME:

ANYONE DESIRING TO
WITH THE FOLLOWING STAFF MEMBER OK AGENCIES, INDICATE
BY PLACING AN "X" ON THE APPROPRIATE LINE. REMEMBER ONLY ONE (1) CHECKED PER REQUEST.
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
I N THE DESIGNATED REQUEST BOX. ONLY EXCEPTION GI& MEDICAL REQUEST DIRECTLY TO THE MEDICAL
TECHNICAN DURING SCHEDULED MEDICATION TIME.

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(EG.,
1

GED, ABE, SELF HELP WORKSHOP, ETC.

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(MUST HAVE 50.00 OR LESS I N PRISON ACCOUNT TO BE ELIGABLE.
SUPPLY OFFICER:

MUST SUBMIT TWO WEEKS PRIOR

( L I S T ITEM NEEDED S I Z E ) :

SPANISH SERVICES COORDINATOR:


Los que necesitan ayuda de cualquiter c l a s e y no saben i n g l e s deben de marcar e s t a
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Third Circuit 15-3400


Property of Advance Media Group

Page 515 of 806


Page 2461 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

REQUEST CONTINUED:

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Page: 517

,PA

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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Property of Advance Media Group

Page 516 of 806


Page 2462 of 2953

Wednesday, November 18, 2015


10/19/2006

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

NAME:

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(PLEASE PRINT)
Document: 003112132545
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: IF MORE THAN ONE LINE IS CHECKED, THE REQUEST WILL BE RETURNED UNANSWERED. IT IS IMPORTANT
: THAT YOU GIVE A COMPLETE EXPLANATION. (PROVIDE ALL NEEDED INFORMATION) AS TO THE
1 REQUEST YOU ARE SUBMITTING. THIS WILL ALLOW A FASTER ANSWER. YOU ARE TO PLACE THE REQUEST
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(EG., GED, ABE, SELF HELP WORKSHOP, ETC.

WELFARE GRANT:
(MUST HAVE 50.00 OR LESS IN PRISON ACCOUNT TO BE ELIGABLE, MUST SUBMIT TWO WEEKS PRIOR
TO DEFINITE RELEASE DATE, ALSO WRITE YOUR DATE OF BIRTH AND SOCIAL SECURITY NUMBER)
SUPPLY OFFICER: (LIST ITEM NEEDED SIZE):

SPANISH SERVICES COORDINATOR:

Los que necesitan ayuda de cualquiter c l a s e y no saben i n g l e s deben de marcar e s t a


l i n e a y echar l a p e t i c i o n en l a c a j a designada para solocotudes (Requests).

DEPUTY WARDEN:
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YOUR REQUEST (COMPLETE INFORMATION) PLEASE PRINT

Third Circuit 15-3400


Property of Advance Media Group

Page 517 of 806


Page 2463 of 2953

Wednesday, November 18, 2015


10/19/2006

I ~ P ~ L Y L K Ar L
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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

54ANLE

NAME :

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Date Filed: 11/18/2015

CELL:

DATE:

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(PLEASE PRINT)
Document: 003112132545
Page: 519

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ANYONE DESIRlNG TO COMMUNICATE WITH THE FOLLOWING STAFF MEMBER OH AGENCIES, INDICATE
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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
I N THE DESIGNATED REQUEST BOX. ONLY EXCEPTION GIVE MEDICAL REQUEST DIRECTLY TO THE MEDICAL
TECHNICAN DURING SCHEDULED MEDICATION TIME.

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TO DEFINITE RELEASE DATE, ALSO WRITE YOUR DATE OF BIRTH AND SOCIAL SECURITY NUMBER)
SUPPLY OFFICER:

( L I S T ITEM NEEDED S I Z E ) :

SPANISH SERVICES COORDINATOR:


L o s que necesitan ayuda de cualquiter c l a s e y no saben i n g l e s deben de marcar e s t a
l i n e a y echar l a p e t i c i o n en l a c a j a designada para solocotudes (Requests).

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Page 518 of 806


Page 2464 of 2953

Wednesday, November 18, 2015


10/19/2006

GENERAL PURPOSE REQUEST FORM

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

NAME:

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.ATURE:

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Document: 003112132545
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ANYONE DESIRING TO COMMUNICATE WITH THE FOLLOWING STAFF MEMBER OR AGENCIES, INDICATE
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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
I N THE DESIGNATED REQUEST BOX. ONLY EXCEPTION GIVE MEDICAL REQUEST DIRECTLY TO THE MEDICAL
TECHNICAN DURING SCHEDULED MEDICATION TIME.
MEDICAL DEPT. - S I C K CALL:
(DESCRIBE THE MEDICAL PROBLEM: WHETHER TREATED BEFORE, BY WHOM?
EDUCATION/TREATMENT PROGRAM:
(EG.,

GED. ABE, SELF HELP WORKSHOP, ETC.

WELFARE GRANT :
(MUST HAVE 50.00 OR LESS I N PRISON ACCOUNT TO BE ELIGABLE, MUST SUBMIT TWO WEEKS PRIOR
TO D E F I N I T E RELEASE DATE, ALSO WRITE YOUR DATE O F BIRTH AND SOCIAL SECURITY NUMBER)
SUPPLY OFFICER:

( L I S T ITEM NEEDED S I Z E ) :

SPANISH SERVICES COORDINATOR:


Los que necesitan ayuda de cualquiter c l a s e y no saben i n g l e s deben de marcar e s t a
l i n e a y echar l a p e t i c i o n en l a c a j a designada para solocotudes (Requests).
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PROBATION~PAROLE:

W~,,L)EN:
DEPUTY WARDEN:
D I R . OF TREATMENT:
ASSOC. WARDEN:
COUNSELOR:
OFFENDER DEV. SER.:
CHAPLAIN :
VISITATION:

PUBLIC DEF. Mr./Mrs.:


RECREATION DIR.:
VOCATIONAL DIR.:
B A I L ADMINISTRATOR:
WORK RELEASE:
CLASSIFICATION COMMITTEE:
OTHER (PLEASE S P E C I F Y ) :

NAME :

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YOUR REQUEST (COMPLETE INFORMATION) PLEASE P R I N T

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US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 521

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

REQUEST CONTINUED:

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AGENCY :

PERSON ANSWERING REQUEST:


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Page 520 of 806


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Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 522

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

THE VILLAGE OF OLDE HICKORY


VILLAGE SQUARE OF OLDE HICKORY
OLDE HICKORY RACQUET CLUB
BOYDfWILSON BUILDING
OREGON PIKE
MANHEIM TOWNSHIP
LANCASTER COUNTY, PENNSYLVANIA
for

BOYD/WILSoN COMPANY

MARY L. CLINTON
APPRAISAL ASSOCIATES, INC.
PRESIDENT
DATED:

Third Circuit 15-3400


Property of Advance Media Group

SEPTEMBER 1, 1985

Page 521 of 806


Page 2467 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

.,.

Document: 003112132545

. ..,
.. . .. .-

Page: 523

430 WEST CHESTNUT STREET

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

LANCASTER, PENNSYLVANIA 17603

October 2 3 , 1985

BoydfWilson Company
208 Oregon Pike
L a n c a s t e r , PA 17601
ATTN: Dale Witmer
RE:

The Olde Hickory Complex

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)

Location Trends. The V i l l a g e of Olde Hickory and t h e surrounding developing


a r e a i s an a t t r a c t i v e r e s i d e n t i a l d i s t r i c t . I am o f t h e o p i n i o n t h a t i t
w i l l maintain i t s p r e s e n t s t a t u s o r g r a d u l l y improve.

(2)

I e s t i m a t e t h e e s t a b l i s h e d Net Income imputable t o a l l t h e f r a c t i o n s of t h e


V i l l a g e of Olde Hickory a t $1,324,333 p e r annum.

(3)

C a p i t a l i z e d Value f o r both income flows which computes a t $13,000,000


per annum. T h i s i s p r e d i c a t e d upon t h e t o t a l e a r n i n g s o f $1,324.333 p e r
annum c a p i t a l i z e d a t an o v e r a l l r a t e of 10.14%.

I n my o p i n i o n , t h e market v a l u e of t h e premises i n t h e c u r r e n t market is:


THIRTEEN MILLION DOLLARS

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,

Mary15-3400
L. C l i n t o n
Third Circuit
p
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Property of Advance Media

Page 522 of 806


Page 2468 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 524

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

INCOME APPROACH

VILLAGE OF OLDE HICKORY:

DEFINITION: T h i s approach d e a l s with t h e p r e s e n t worth and f u t u r e p o t e n t i a l


b e n e f i t s of t h e p r o p e r t y . This i s g e n e r a l l y measured by t h e n e t income which
a f u l l y informed person i s warranted i n assuming t h e p r o p e r t y w i l l produce d u r i n g
t h e remaining u s e f u l l i f e . A f t e r comparison with investments of s i m i l a r t y p e and
c l a s s , t h e n e t income i s c a p i t a l i z e d i n t o a value e s t i m a t e .
The g r o s s and n e t income g e n e r a t e d by t h e c u r r e n t r e n t s f o r t h e y e a r 1985 a r e
d i v i d e d as f o l l o w s :

Residential
Commercial Income
Golf & Swimming

Annual Gross Income

Annual Net Income

$2,224,766

$1,072,465

275,714

204,182

93,310

(11,870)

Racquet Club
Total

(Expense r a t i o i s 52% of g r o s s ( i n c l u d i n g vacancy & bad debt allowance).

The r e s i d e n t i a l income o f $2,224,766 p e r annum averages $89.31 p e r room p e r month.


The l e a s e s have a 1 y e a r term with t e n a n t s absorbing a l l o f t h e i r e l e c t r i c a l charges
which i n c l u d e s e l e c t r i c h e a t i n g , a i r c o n d i t i o n i n g and h o t w a t e r .
Management e x p e c t s a t u r n o v e r of 30% t o 35% i n t h e r e s i d e n t i a l u n i t s d u r i n g 1985.
This would i n c r e a s e t h e r e n t r o l l m a t e r i a l l y a s shown on t h e following s c h e d u l e o f
Monthly Rates e f f e c t i v e September 1, 1985.

A 3% allowance f o r vacancy and bad d e b t s was considered a p p r o p r i a t e due t o t h e f a c t


t h a t t h e r e i s g e n e r a l l y a w a i t i n g l i s t f o r new c o n t r a c t s .
COMMERCIAL RENTALS:
Rentals f o r t h e shopping c e n t e r , t h e f o u r o f f i c e s i n t h e former s t o n e farmhouse and
3 r e t a i l and o f f i c e u n i t s i n t h e Boyd/Wilson Building aggregates $275,714 p e r annum
( s e e schedule of b a s e r e n t a l s ) . A 5% vacancy and bad debt d e d u c t i o n appears a p p r o p r i
based on p a s t h i s t o r i c a l r e c o r d s .
The r e n t a l o f f i c e ( U n i t 6 ) does n o t c o n t r i b u t e any r e n t . I have a p p l i e d a r e n t a l o f
$6.75 p e r s q . i t . which i s i n t h e lower h a l f of t h e r e n t r o l l range which computes
I
1
t o $9,072 annually.
The income from t h e Golf and Swim Club which we have taken from t h e l a s t s t a t e m e n t
of e a r n i n g s i s $93,310 p e r annum and m i s c e l l a e o u s income approximates $5,000 p e r y e a r

CHESTNUT

Third Circuit
15-3400
Page 523 of 806STREET, IANCASTER,
Wednesday,
November 18,
2015
xP
P a S a 1 ~ S S O C S . ~ S 430 WEST
PENNSYLVANIA
116m
Property of Advance Media Group

Page 2469 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 525

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

INCOME APPROACH

REAL ESTATE TAXES CONTINUED:

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

See Summary o f Assessed Valuations f o r The V i l l a g e of Olde Hickory Complex.

i i.

Net Income imputable t o t h e premises based upon t h e c u r r e n t r a t e s i s e s t i m a t e d


a t $1,324,333 per annum.

Third Circuit
& 15-3400
mSisrl

Property of Advance Media Group

Page
524 of 806 STREET, LANCASTER,
Wednesday,
November 18,178m
2015
assoeiat~s430 WEST
CHES&UT
PENNSYLVANIA
Page 2470 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 526

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

COST APPROACH

DEFINITION: The c o s t approach t o value c o n s i d e r s t h e value of t h e s u b j e c t l a n d


as i f i t i s v a c a n t , t o t h i s f i g u r e i s then added t h e d e p r e c i a t e d replacement c o s t
o f t h e improvements on t h e p r o p e r t y . The f i r s t s t e p i n t h i s approach i s t o e s t i m a t e
b a r e l a n d v a l u e . The n e x t s t e p i s t o e s t i m a t e t h e replacement c o s t of t h e s u b j e c t
improvements. The Marshall Swift V a l u a t i o n S e r v i c e i s used f o r t h i s purpose.
D e p r e c i a t i o n i s determined and e s t i m a t e d and then deducted from t h e c o s t new t o
a r r i v e a t a d e p r e c i a t e d accrued d e p r e c i a t i o n v a l u e . To t h i s f i g u r e t h e v a l u e o f
t h e l a n d a s i f unimproved i s then added. The d e p r e c i a t i o n deductions were f o r
p h y s i c a l wear and t e a r .

1.

The 54 townhouse b u i l d i n g s , Nos. 1 t o 54 have been valued on t h e c o s t b a s i s


o f $42.00 p e r s q . f t . o f t h e b u i l d i n g s which were e r e c t e d i n 1969 and 1970.
This t o t a l s $15,953,280. A 30% p h y s i c a l d e p r e c i a t i o n was deducted t o r e f l e c t
t h e wear and t e a r and a 15% f u n c t i o n a l obsolescence deduction r e p r e s e n t s t h e
s t r u c t u r a l age a s w e l l a s f u n c t i o n a l obsolescence items such a s f i r e p l a c e s
and f l o o r p l a n s .
The d e p r e c i a t e d p r e s e n t worth of t h e townhouses i s $12,170,430.

2.

B u i l d i n g Nos. 55 t o 57 would be t h e Wedgewood Buildings e r e c t e d i n 1971 have


a n e s t i m a t e d c o s t of $45.00 p e r s q . f t . o r $4,175,550. A 30% p h y s i c a l d e p r e c i a t i o n was deducted t o r e f l e c t t h e wear and t e a r and a 15% f u n c t i o n a l o b s o l e s c e n c e
d e d u c t i o n r e p r e s e n t s t h e s t r u c t u r e age a s w e l l a s f u n c t i o n a l obsolescence i t e m s
such a s f i r e p l a c e s and f l o o r p l a n .

3.

The shopping c e n t e r which h a s a g r o s s a r e a of 23,051 s q . f t . I have valued a t


$44.00 p e r s q . f t . f o r a t o t a l o f $1,014,244. This s t r u c t u r e was e r e c t e d i n
1972 and t h e d e p r e c i a t i o n deducted r e p r e s e n t e d 20% p h y s i c a l wear and t e a r and
10% f u n c t i o n a l obsolescence w i t h regard t o f l o o r p l a n and f i r e p l a c e s a s w e l l a s
t h e s t r u c t u r a l components o f t h e b u i l d i n g .

4.

I n J u l y 1974, t h e Olde Hickory Racquet Club was e r e c t e d which h a s a g r o s s s q u a r e


f o o t a g e of 70,569 s q . f t . Based on t h e c u r r e n t c o n s t r u c t i o n i n d e x e s , t h e Racquet
Club and a l l i e d f a c i l i t i e s c o s t $38.00 p e r s q . f t . o r $2,681,622. The d e p r e c i a t i c
deducted from t h i s s t r u c t u r e was 25% f o r p h y s i c a l wear and t e a r and 10% t h a t
r e f l e c t s t h e o b s o l e t e f l o o r p l a n , hallway d e s i g n and s i m i l a r a m e n i t i e s .

5.

The Boyd Wilson b u i l d i n g has j u s t been e r e c t e d i n 1984 and c o n t a i n s a g r o s s


s q u a r e footage o f 12,240 s q . f t . a t an e s t i m a t e d c o s t o f $45.00 p e r s q . f t . T h i s
I have d e p r e c i a t e d t h i s s t r u c t u r e a t a nominal f i g u r e of 5%
t o t a l s $550,800.
t o r e f l e c t minimal wear and t e a r .

The o t h e r b u i l d i n g s have s i m i l a r deductions based on t h e i r age and f u n c t i o n a l u t i l i t y ,


See a t t a c h e d suarmary.

&pdiSd
Third Circuit
15-3400
Property of Advance Media Group

a S S 0 ~ l a e S430 WEST
CHES~NUT
PENNSYLYANtA
178m
Page
525 of 806STREET, LANCASTER.
Wednesday,
November 18,
2015
Page 2471 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 527

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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

DEPRECIATION & OBSOLESCENCE:


Physical

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-

DEPRECIATED COST OF THE IMPROVEMENTS:

$15,908,414

ESTIMATED LAND VALUE:


~ e s i d e n t i a lAcreage: 86.88
Shopping Center:
4.591
Racquet Club:
4.279
Boyd/Wilson Building: 4.25
T o t a l Land Value

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 =

TOTAL ESTIMATED VALUE BY THE COST APPROACH:

306 000

$2,812,560

2,812,560
$18,720,974

Rounded $18,700,000

I 1:

Third Circuit
15-3400
Page
526 of 806 STREET. UNCASTER,
Wednesday,
November 18,l7bd
2015
&~pmsal
assocIaIS. 430 WEST
CHESTNUT
PENNSYLVANIA

Property of Advance Media Group

Page 2472 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 528

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

WEDGEWOOD
Layout of Each Building
1st - 3rd Floors

4/4's, 415 with 2 Baths, Each Floor


TOTALS
Per Building

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

Each Total Each Total Each Total


-

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

, .

Wedgewood
Townhouses
TOTALS :

Rooms

,
9

,,

p p ~ i s aa sls o c i a ~ s430 WEST


PENNSYLVANIA
Third Circuit~15-3400
PageCHESTNUT
527 of 806 STREET, UNCASTUI,
Wednesday,
November 18,17603
2015
Property of Advance Media Group

Page 2473 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 529

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

THE VILLAGE OF OLDE HICKORY


TOWNHOUSES:
The Burgess House which i s a luxury type house c o n s i s t s o f 61 b a s i c type h o u s e s ,
some w i t h c o u r t y a r d s and some without c o u r t y a r d s . The e x t e r i o r s a r e b r i c k and
s t o n e with some c o n c r e t e p a t i o s on t h e grade l e v e l . F e n e s t r a t i o n i s wood double
hung w i t h aluminum s t o r m windows and wood s h u t t e r s . Entrance doors a r e s o l i d
c o l o n i a l design and roos a r e p i t c h e d a s p h a l t s h i n g l e with g u t t e r s and l e a d e r s .
The Burgess u n i t s and t h e Haymarket u n i t s a l l have 6 rooms with 2.5 b a t h s . The
f l o o r s a r e c a r p e t e d and t h e d i n i n g a r e a s a r e provided with a c h a n d e l i e r . Walls
and c e i l i n g s a r e of s h e e t r o c k c o n s t r u c t i o n . T y p i c a l grade f l o o r c o n t a i n s a
l i v i n g room and d i n i n g a r e a , c o a t c l o s e t i n t h e f o y e r with composition f l o o r i n g
and a k i t c h e n with s i m i l a r f l o o r i n g and s t a i n l e s s s t e e l s i n k w i t h formica countert o p s , and a General E l e c t r i c 4 b u r n e r range, General E l e c t r i c dishwasher, and a
General E l e c t r i c c l o t h e s washer and d r y e r . The k i t c h e n s a l s o have wood cupboards and General E l e c t r i c r e f r i g e r a t o r s . The powder room has a composition
t i l e f l o o r i n g , enameled i r o n washbasin w i t h formica t o p , low tank t o i l e t , and
medicine c a b i n e t . Carpeted wood s t a i r s with wrought i r o n r a i l i n g l e a d s t o t h e
2nd f l o o r .
The 2nd f l o o r i s c a r p e t e d throughout and c l o s e t space i s e x c e l l e n t . The r e a r
bedroom h a s a double wardrobe c l o s e t with louvered metal doors. There i s a l s o a
s i n g l e louvered h a l l c l o s e t and a p r i v a t e bathroom with composition t i l e f l o o r i n g ,
t i l e jumbers and b u i l t - i n tub w i t h shower, low tank t o i l e t , enameled i r o n washb a s i n with formica t o p and s l i d i n g medicine c a b i n e t . The f r o n t h a s two bedrooms,
one s m a l l and one s l i g h t l y l a r g e r . Wardrobe c l o s e t s a r e i n each bedroom. The
r e a r bedroom a l s o h a s a s e p a r a t e washbasin w i t h medicine c a b i n e t . The e n t i r e
house i s h e a t e d and a i r c o n d i t i o n e d by e l e c t r i c i t y , with a u n i t of General E l e c t r i c
manufacture l o c a t e d i n a shed a d j o i n i n g t h e r e a r t e r r a c e . Heated and c h i l l e d a i r
a r e d i s t r i b u t e d by d u c t and f o r c e d a i r c i r c u l a t i o n . There a r e r e g u l a r 3 bedroom
s i x roomhouses and t h o s e w i t h t h e f i r e p l a c e which a r e d e s c r i b e d a s a luxury u n i t .
A 1 1 houses have a f o l d i n g door i n second f l o o r h a l l c e i l i n g s which l e a d t o t h e
a t t i c . The a t t i c i s h e a v i l y i n s u l a t e d and can be used f o r s t o r a g e purposes where
t h e roof beams a r e covered. Water p i p i n g i s copper throughout.
I understand t h a t
t h e 3 bedroom Deluxe Burgess Houses a r e u s u a l l y on t h e end of a b u i l d i n g . There
a r e 54 b u i l d i n g s c o n t a i n i n g t h e 328 townhouses which have 1,752 rooms, 133 f i r e p l a c e s
and 65 c o u r t y a r d s . The townhouses a r e i n S e c t i o n s I, II and 111 of The V i l l a g e o f
Olde Hickory.

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

CHESTNUT

~ 15-3400
p p d i s a la s s o c i a ~ s430 WEST
PENNSYLVANIA
178m
Third Circuit
Page 528 of 806STREET, UNCASTER,
Wednesday,
November 18,
2015
Property of Advance Media Group

Page 2474 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 530

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

THIS VALUATION IS CONTINGENT UPON THE FOLLOWING


UNDERLYING ASSUMPTIONS AND CONDITIONS:
This appraisal. is to be used in whole and not in part. No part of
it shall be used in conjunction with any other apprai'sal.
Possession of this report or a copy thereof, does not carry with
it the rights of publication nor may it be used for any purpose by
any but the client for whom it was made, without the consent of
the appraiser and the client.
The appraiser is not required to give testimony or attendance in
court by reason of this appraisal, unless arrangements have been
previously made therefore.
This appraisal covers the property as described in this report and
the areas and dimensions as shown herein are assumed to be
correct. The appraiser has made no survey of the property and
assumes no responsibility in connection with such matters. Any
sketch or identified survey of this property included in this
report are only for the purpose of assisting the reader to
visualize the property.
The information furnished in this report by others is believed to
be reliable, but no responsibility for its accuracy is assumed.
(
The appraiser assumes no responsibility for matters of a 1-egal
nature effecting this property or the title thereto, nor does the
appraiser render any opinion as to the title which is assumed to
be good and marketable. The property is appraised as though under
reasonable ownership and competent management.
Any distribution of the valuation in this report between land and
improvements applies o n l y under the existing program o f
utilization. The separate valuation for land and building must
not be used in conjunction with any other appraisal and are
invalid if so used.
The appraiser assumes that there is no hidden or unapparent
conditions of the property subsoil, or structures which would
render it more or less valuable.
The appraiser assumed no
responsibility for such conditions or for engineering which might
be required to discover such factors.
The appraiser's duties pursuant to his employment to make the
appraisal are completed upon delivery and acceptance of the
appraisal report. All conclusions set forth in the appraisal
report were prepared by the appraiser whose signature appears on
the appraisal report. No change of any item in the appraisal
report shall be made by anyone other than the appraiser, and the 1
appraiser shall have no responsibility for any such unauthorized
change.

Third Circuit&tpdiSd
15-3400
Property of Advance Media Group

.ssOC~.~S

430 WEST
H EofS806
~ ~ USTRE=,
T
LANCASTER,
PENNSYLVANIA
PageC529
Wednesday,
November 18,I78m
2015
Page 2475 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 531

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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.

Third Circuit&15-3400
p~tS.l
Property of Advance Media Group

d
INC.

PageCHES~NUT
530 of 806 STREET, L4NCASTER.
Wednesday,
November 18,,7603
2015
a ~ S 0 ~ l .430
e ~WEST
PENNSYLVANIA
Page 2476 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 532

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

RESUME OF MARY L. CLINTON


1968

1971

1971 to Present
1978 to Present
1982 to Present
APPRAISAL EDUCATION

Licenced Real Estate Salesperson, State


of Pennsylvania
Licenced Real Estate Broker, State of
Pennsylvania
President, Appraisal Associates, Inc.
Vice-president, Hershey/Clinton &
Associates

REAL ESTATE COURSES COMPLETED:


1.
2.
3.
4.

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

APPRAISAL COURSES COMPLETEDA.1 .R.E.A.

COURSES:

1. I-A Basic Appraisal Principals, Methods and Techniques


2. I-B Capitalization Theory and Techniques
3. I1 Urban Properties
4. Standards of Professional Practices
5. Valuation Analysis and Report Writing
6. Capitalization Theory and Techniques Part I1 (refresher)
SEMINARS:
1. Attended the Residential Appraisal Seminar conducted by
A.I.R.E.A.
2. Attended the Solar Xorkshop Seminar for the Financial
Community sponsored by H U.D.
3. Attended Valuation of Matrimonial Assets Under Equitable
Distribution conducted by A.S.A.
4. Attended Introduction to Machinery and Equipment
Valuation conducted by A.I.R.E.A.

I
I

Third Circuitxpp&iSal
15-3400
Property of Advance Media Group

.sscW~~US
430 WEST
CHESTNUT
PENNSILVAN1A
178m
Page
531 of 806STREET,LANCASTER,
Wednesday,
November 18,
2015
Page 2477 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 533

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

REAL ESTATE ACTIVITIES:

President of the Greater Lancaster Board of Realtors


Director of the Greater Lancaster Board of Realtors
Past President of the Lancaster Chapter of Women's Council
Member of the National Associate of Realtors
Member of the Pennsylvania Association of Realtors
Honored at 1977 Leaders Luncheon by the Lancaster YWCA
Arbitrator for the National Academy of Conciliators Honored
Recipient of the Realtor of Year Award - 1981
Recipient of Dorothy M. Slaugh Award - 1981
DESIGNATIONS AND AFFILIATIONS

,,

.
,

ASA

!,
,,

!T
.,

SCV

CRP

CRV

RMU

ICA
MA1

!
I
.,

Y-1)
F:
.,

I .

Senior Member of the International Organization Real


Estate Appraiser
Candidate of the American Institute of Real Estate
Appraiser #M 81 1577
Candidate of the American Society of Appraisers
International Institute of Values
International Institute of Valuers
Senior Certified Valuer
National Association of Certified Real Property
Appraiser
Certified Real Property Appraiser
National Association of Review Appraisers
Certified Review Appraiser
National Association of Review Appraisers and Mortgage
Underwriters

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

Third CircuitKppl~is.1
15-3400
PageC532~
of 806
November 18,17603
2015
associaes 430 WEST
~ STREET,
~ TUNCASTER,
k Wednesday,
~ PENNSYLVANIA
Property of Advance Media Group

Page 2478 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 534

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

PARTIAL LIST OF FINANCIAL INSTITUTION CLIENTS


Bank of Lancaster County
Commonwealth National Bank
Dauphin Deposit Bank
Farmers First Bank
Fulton Bank
Hamilton Bank
New Holland Farmers National Bank
First Federal Savings & Loan
Heritage Savings Association
Lancaster Federal Savings & Loan
Parent Federal Savings Bank
State Capital Savings & Loan
York Federal Savings & Loan
Bell Savings & Loan Association
Brokers Mortgage Service
Central Mortgage Company
Chase Home Mortgage Company
Clarion Mortgage Company
Colonial Mortgage Service Company
Horst Financial Services
Jersey Mortgage Company
Lomas and Nettleton
Meridan Mortgage Corporation
Northwest Mortgage Company
The Kissell Company

,
&p&isnl
Third Circuit 15-3400
Property of Advance Media Group

CHESTNUT

associaf5s 430 WEST


PENNSYLVANIA
7a
Page 533 of 806 STREET, IANCASTER,
Wednesday,
November 18,12015
Page 2479 of 2953

10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 535

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

PARTIAL LIST OF APPRAISAL AND CONSULTANT CLIENTS


MARY L. CLINTON
Armstrong World Industries
Cutler-Hammer
R.R. Donnelly and Sons Company
DuPont Company
Employ ee Transfer Corporation
Executrans, Inc.
Homequity
Howmet Aluminum Corporation
Investors Relocation Group, Inc.
Merrill Lynch Relocation Management, Inc
Oscar Mayer and Company
Packaging Corporation of America
Philadelphia Electric Company
Relocation Realty Services Corporation
Relocation Resources
TransAmerica Relocation Services, Inc.
Westvaco
Avco Financial Services
Dial Consumer Discount Company
Federal Housing Administration
Federal National Mortgage Association
Lenders Services, Inc.
Record Data of Pennsylvania, Inc.
Veterans Administration

Third Circuit 15-3400


Property of Advance Media Group

Page 534 of 806


Page 2480 of 2953

Wednesday, November 18, 2015


10/19/2006

--

ICHARGEISI.

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

I DATE OF

CHAR,

Section 3189 Federal False Claim Act

Page: 536

Date Filed: 11/18/2015

- .
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
$
?0.0C0.00

'[

N E X T COURT ACTION

Ldilians of Release (aside fmm appearing a1 court when required:)


DATE

AND TIME

LOCATION

S r ~ t .14, 1487 10:130

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(

FOR THE ENTIRE

DISPOSITION

OF ANY

OISCHARGE THE ABOVE-NAME0 DEFENDANT FROM CUSTODY If


DETAINEO F O R NO OTHER CAUSE THAN. THE
. ABOVE STATED.
Given under m y hand a n d the'official Seal o f this Court.

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.

Bring Cash Bail Receipt t o Clerk o f Court.

A N D F I N A L DISPOSITION OF T H E CASE
this

FOR

IN

T
. -?
;
..

THE

. .
.

9ch

'

4n

O n behalf o f the defendant by:

Refund o f all other types o f bail w i l l be made p r o m p t l y aftel


2 0 days following final disposition. (Pa.R.Cr.P. 4 0 1 5 ( a I l

A P P E A R A N C E OR B A I L B O N D

Other

l[.i<=nse
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

I hereby c e r t i f y t h a t sufficient bail has been entered


p

SECURITY O R SURETY ( I F A N Y )
a s u r e t v Company
professional Bondsman
ORealtv
Cother

4 ' ~ n c ~ s c r r?A.

E D Xk iEiE5%%4 J W SbT%'iCE CU.


Alfred0 %rchf0, 529 Cherry S t . ,
r.Vw-e 6 .4ddrrsr o f S u r e r ~ 1Reading, PA
14602

(attach addendum, i f necessary)

2205
-

a Detention Center

TO:

11

i;:-

tjj-

.;
a

..

L.,.

,1

Septcsber

dgy o f

-- .

..

/
.f
::
,.I .,- ,~.'
. .:
. .. .
;

(Clerk ufCourr or Isruing Aurl8orityl

'

, 1:
I'

,:&

-------

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 ($
).

commonwealth o f Pennsylvania the sum o f

SEE REVERSE SIDE FOR B A l L COND~T~ONS

CERTIFICATION OF COUNTER INDEMNITY AND PREMIUM

(Applicable Only When Surety Is A Corpor:


Indiana
turnberman's Insurance Co.
1.400.00
11 3 hereby certify that the amount paid by said Principal to said Surety for bail in the above matter is S

>:

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:

\I

ir

- .
' .

.j

#'

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
.
e n l ~ o l s u c hjudgment except thorein which apetition to openorvacate the judgment hasbeenfileda"dkmainrundirpbred of:

Oated:

Se3tenbe~

!!

. 1 9 8 7
/PrincipsU

'

\ lSureryl ;. / ,.

M U S T BE SIGNED I N PERSON
B Y T H E APPROVED AGENT

1
i

(!

$GN4;iREO

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.

The followinga~knowledgementis also applicable


if Percentage Cash Bail is used.
: THIS B O NSIGNED
~
ON September
9, 1 9 3
at
iiev Holland.
PENNSYLVANIA.

Signature of Surety ( M y v ~ o n d s m a n .Bail Agency. o r private


indiuidual or organration). Excepb when defendanr is releared on his

'

.
Third Circuit 15-3400

Page 535 of 806

I r * Property
In case of
corporate
surew
hail. Power of A nornev muzr Page 2481 of 2953
of Advance
Media
Group

Sursry No. or
Proferrional Bondrmon
License
& Erpirntic
Wednesday,
November
18, No.
2015

n race nf P n r r ~ n r s n or l r h

R = i l r 10/19/2006
r n,--;-=,

O-;,

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 537

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

ST. JOSEPH HOSPITAL AND HEALTH CARE CENTER


LANCASTER,

PENNSYLVANIA

INPATIENT MENTAL HEALTI1 UNIT


P A T I E N T

Third Circuit 15-3400


Property of Advance Media Group

G U I D E

Page 536 of 806


Page 2482 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 538

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

T h e following guidelines have been established in order that


a s a f e and congenial environment can be provided for all patients

within the Inpatient Mental Health Unit.


and

if y o u h a v e ' q u e s t i o n s ,

Please read the guidelines

ask t h e staff t o respond t o y o u r

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

Visitors may be received during the following hours:


Monday, ~ e d n e s d a y , Friday

7:00 p.m.

8:00 p.m.

Saturday and Sunday


T h e n u m b e r o f v i s i t o r s should be limited t o 4 p e r
patient at any one time. Children under the age of 13 may be
a l l o w e d t o v i s i t w i t h patients in the Atrium and at t h e
discretion of the charge nurse.
Visitation is permitted in the Atrium, South Unit, or
West Unit.
For patients with ground privileges, visitation
i s permitted within the Hob-Nob. Acute care patients may be
v i s i t e d o n t h e A c u t e C a r e Unit.
W h e n a p p r o v e d by t h e
patient's
psychiatrist and when accompanied by a staff
member, Ac
are Unit patients may receive visitors in t h e
Atrium.
111.

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.

Third Circuit 15-3400


Property of Advance Media Group

Page 537 of 806


Page 2483 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 539

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

G r o u n d P r i v i l e g e s are each day during the following


hours:

NOTE:

T h e visitation and ground privileges a r e i n effect


o n l y during t h o s e t i m e s when t h e patient(s) a r e not
i n treatment activities.
P a t i e n t s a r e expected t o
conduct themselves and their behaviors based o n
a c c e p t a b l e socialization standards.
A l l p a t L e n t s are a s k e d t o s i g n o u t at t h e n u r s i n g
s t a t i o n when leaving the Unit.

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

P h o n e calls may b e m a d e or received any t i m e during t h e


w e e k between t h e h o u r s o f 7:00 a.m. and 11:30 p.m. a s long a s
they do not interfere with o t h e r activities. Each p h o n e call
s h o u l d b e limited t o 10 m i n u t e s s o t h a t other patients m a y
make and receive calls.
A c c e p t a b l e t e l e p h o n e behavior is expected a s a courtesy
t o o t h e r s and a s a demonstration o f one's
abilfty t o
c o m m u n i c a t e i n a r e s p o n s i b l e manner.

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.

Third Circuit 15-3400


Property of Advance Media Group

Page 538 of 806


Page 2484 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 540

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

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.

PATIENT BILL OF RIGHTS AND G R I E V A N C E PROCEDURE


E a c h p a t i e n t w i l l r e c e i v e a c o p y o f t h e P a t i e n t B i l l of
R i g h t s w h i c h i s Addendum I t o t h e P a t i e n t G u i d e a n d i s
a t t a c h e d t o t h e P a t i e n t Guide.
The P a t i e n t B i l l o f R i g h t s
p r o v i d e s f o r t h e p a t i e n t i n f o r m a t i o n a b o u t your r i g h t s and
p r i v i l e g e s while a p a t i e n t a t S t . Joseph Hospital.
The G r i e v a n c e and Appeal Procedure s h o u l d be handled o n
an informal basis with t h e s t a f f if possible.
Any p a t i e n t s ,
o r t h o s e h e l p i n g t h e p a t i e n t , may i n i t i a t e a c o m p l a i n t
o r a l l y or i n writing
and t h e complaint w i l l be handled
t h r o u g h t h e t r e a t m e n t team l e a d e r o r t h e Program Manager o f
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 w i t h i n 48 h o u r s o f
T h i s d e c i s i o n may b e a p p e a l e d
r e c e i p t of t h e c o m p l a i n t .
w i t h i n 10 d a y s t o t h e M e d i c a l D i r e c t o r o f M e n t a l H e a l U
S e r v i c e s o r t h e Directo-r o f M e n t a l H d t h / S u b s t a n c e w e
Services.
l f a n a p p e a l is s t i l l r e q u e s t e d , t h e g r i e v a n c e
must be s u b m i t t e d t o t h e P r e s i d e n t o f S t . Joseph H o s p i t a l and
t o t h e C o u n t v MH/MR A d m i n i s t r a t o r .

Third Circuit 15-3400


Property of Advance Media Group

Page 539 of 806


Page 2485 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

VIII.

Document: 003112132545

Section 3189 Federal False Claim Act

Page: 541

Date Filed: 11/18/2015

MEALS/FOOD
Approximate Hours:

Breakfast
Lunch
Dinner

7:15 a.m.
12:OO noon
5 : 1 5 p.m.

You are responsible to be present at the scheduled meal


times except when medical tests interfere.
M e n u s e l e c t i o n f o r t h e f o l l o w i n g day s h o u l d be m a d e
during the breakfast hour.
If your selection is not
completed during that time, you will receive a regular house
tray for all three meals.
Foods should be eaten in the dining area only unless
staff permission is received.
Foods kept in the bedrooms
should be with staff permission.
F o r safety purposes, glass bottle containers are not
allowed on the unit.
Soda cans are also not allowed on the
unit. Soda and juices should be poured into papercups.
Foods brought from home or from friends will be examined
by s t a f f , labeled, and put in t h e pantry a r e a f o r s a f e
keeping and storage.
Pantry access is available during the following hours:
9:30
10:OO a.m. and 8:00
8:30 p.m.
Foods ordered from outside the hospital should be
o r d e r e d b e f o r e 9:00 p.m. and must be o r d e r e d by a s t a f f
member.

TV AND RADIO
. TV and radio are allowed when not interfering with other

Ix.
\.

therapeutic unit activities.


As a courtesy t o others, the
hospital stereo should not be turned above "3" in volume.
Because of fire/safety regulations, all personal stereo/
r a d i o e q u i p m e n t must be approved by h o s p i t a l m a i n t e n a n c e
prior to use, unless it is battery operated.

X.

BEDROOM AND LIGHTS OUT


Monday through Thursday and Sunday lights are out at
11:OO p.m. t o e n s u r e an opportunity f o r plenty o f rest.
Friday and Saturday lights should be out at 1:00 a.m.
R o o m s should be kept neat and clean.
Beds are t o be
made prior to morning group.
Linens are changes on
Wednesdays and Saturdays. Patients should not visit in other
patients' rooms unless invited and with the permission from
the staff.

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.

Third Circuit 15-3400


Property of Advance Media Group

Page 540 of 806


Page 2486 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

XV.

Document: 003112132545

Page: 542

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

FORMER PATIENTS' VISITS TO T H E INPATIENT M E N T A L HEALTH


SERVICE

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.

Third Circuit 15-3400


Property of Advance Media Group

Page 541 of 806


Page 2487 of 2953

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Third Circuit 15-3400


Property of Advance Media Group

Document: 003112132545

Page: 543

Page 542 of 806


Page 2488 of 2953

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Wednesday, November 18, 2015


10/19/2006

US District Court For The Eastern District of Pennsylvana

Case: 15-3400

Document: 003112132545

Page: 544

Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

i
nd Health Care Center
Direct Dial Number: 291-8163

September 25, 1987

To:

Stanley Caterbone
2323 New Danville Pike
Conestoga, Pa. 17516

Amount Due:

$3,064.60

Account Number:

081609802

Enclosed i s a copy of your hospital b i l l f o r services from 9-9-87


to
9-15-87
The amount of the b i l l i s $ 3,054.50 , and i t i s your responsibility t o see that the hospital i s paid i n f u l l .

Full payment i s due w i t h i n 30 days. I f you would l i k e t o s e t up payment


arrangements f o r a period of 6 months, you must c a l l our o f f i c e within
10 days.
I f you have any insurance coverage o r Medical Assistance information t h a t
will help pay a l l o r part of t h i s b i l l , please contact our o f f i c e immediately w i t h the necessary information.
Sincerely,

7);,L7c
DRB@LA

Patient Accounts Representative


St. Joseph Hospital

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CARING AND CURING SINCE 1883


Page 543
of 806
250 College
Avenue.
Lawaster. Pn 17604Wednesday, November 18, 2015
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-----I-

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,--

-I-

,-AMY(

".YLIU*I

c-.

llD

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Section 3189 Federal False Claim Act

Date Filed: 11/18/2015

Financial Management Group, LTD


Eden Park 11, 1755 Oregon Plke Uncastcr, PA 17601
7 1 7 - 5 6 9 4 1 0 0 800-521-8567 800-322-1128 [PA only)

.NLEY J. CATERBONE

EXECUTIVE VICE PRESIDENT

Capello & Foley


831 State Street
Santa Barbara, CA
Attn: Diane Carrbell

Dear Diane:

As per our previovs conversation,

emlozed i s the brief awry of my

care! I want to t b n k the law f i r m of Capello & Foley'for a l l of t h e i r help!

Regretfully,

Emlollre
:

Barry Capello

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S=rurHler Offered threuph PI.+er's


Se~u1ItIe1Group. Inc.
Page 2490Mlmber
of 2953 SlPC
A R=plitertd BrokerlDealir
h3.rnb.r
NASD

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RECORDED TRANSCRIPT WITH

THE PENNSYLVANIA SECURITIES


AND EXCHANGE COMMISSION
"JAMES GUERIN AND ISC OPERATIONS"
~97''

Subject:

Quotes from a recorded transcript between Stanley J. Caterbone and


Howard Eisler, Agent of the Pennsylvania State Securities and Exchange
Commission. This transcript was recorded with the approval of all present
parties.

Date of
Conference:

September 6 1987

Place
of
Conference:

0
0

2323 New Danville Pike


Conestoga, PA 17512

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."

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" 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."

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"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."

" Wasn't there some allegations about a tie to Wedteck?" (Defence

Howard Eisler

Contractor of New York)


Stan Caterbone Stan Caterbone

(I

Stan Caterbone Stan Caterbone

'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."

" I sold it when things started to hit the

"

N
"

iust did a multimillion dollar merger with a company in London.


They probably think this is going to cover their tracks.',

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 -

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"I was framed and set up...-....."


"I don? know maybe Jim Christian doesn't have the money. Maybe Guerin
has it or somebody else"

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/?

$.fibne of

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the items in the column (newspaper column) is the reporting of your

- 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

- there is about 50 names I am dealing

- yes, the

with here and they

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

so the 203D exemption was filed for. Of course we have

added the security statement

- explanation of

where the money is going to be spent, how

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

these things have not

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

- the only one that's

separate distinction is the IRA.

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

selling securities or dealing with

Now that came in under your name ...at

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

- the offering memorandum was done last August because that's

when

I started raising the money. August of 1986 is when I did the initial filing for the
offering memorandum

- the

144

Coming up this October is the 203D. 15 months

after conception. Alright, yea. There is a report that is due a year after
that's what is coming up

- Right,

- to explain how much money was raised and where it was

spent with the idea then of protecting investors. The idea of the

your are

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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

memorandum. Then a year after it is raised, or a year after

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
are stock certificates in here in force with names on them that

, 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

- when Financial Management Group limited applied for

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
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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

18-25 - that was sold as a result of the public offering.

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

. Were those funds all

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.

They never showed anyone the books to this day. I got

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

and Brown out of DC.

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

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- I went down there after about 3 weeks of

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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.

- all the former IFP presidents.

International Association for Financial Planners

- the big guys.

Now, in

ISP?

So, I swing everything

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

- I had my lock changed in my office for

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

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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

and that you are

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

'

what they have done to me.


Again, t h e r a y 1 am getting this

- I didn't

know anything to start with

- I just

haven't

to make inquiry a t the police office and one said that you were taken
not.

I was

See, that was all started by Kauffman. He actually h e had meetings

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

prices. It was $5 a share. Was 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

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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

- it was a big system.

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

- in the form of loans?

Yes. And, how much

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

- I was running the local chapter of

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

- provides services in mortgage backing,

investment backing, insurance, real estate, taxes, lending, portfolio management,

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everything. I had it researched legally by a leading patent law firm in Phila. It is


definitely the most innovative in the country. There is not a firm in the country
offering all the services that we offer.
Now, just up the street from your place

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.

Before I left, I was working on

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

and all. FMG


told me that they were responsible f o r the money because Stan was an officer of the

company and that they would

Then, after several me

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

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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

- they're dragging their feet on this.

They don't know

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

copied this. This is just happens to be page

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.

I have nothing. The only

thing I have is what is in this house.


Well, Kauffman comes up here from Atlanta, and he's a born-again Christian, so he
comes together with a group up here somehow. You see. he's hiring born-again people ...
Jehovah Witnesses. Hartlett is a Jehovah. There were more Jehovah Witnesses than
there was anybody. But Hartlett was somebody you brought in though, wasn't he? Well,
what happened was I put everything together. But would it not be right to say that
Hartlett would be your person as opposed to Kauffman's person. Well, it is those two
against me. They are the two that are trying to take the company from me. See, I
controlled everything. Everyone went with what 1 said because I did things that were
right for business and right for people. I treated people fairly and honestly. People
respected me more than anybody.

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Did Kauffman in the initial offering that you had, the preorganizational offering - each
of you put up $20,000

- did Kauffman put up 20?

He got more stock; he never paid the

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

- he was conniving from day one.

When we put this thing together, I

was in the middle constantly between Kauffman and Hartlett. In fact, a t one time
Kauffman was going over an idea

- this was over a year ago before we moved

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

- yea, spent 5 years.

But now they've picked up your contacts really, so to speak? Exactly right. They are
acting as mortgage bankers, etc. The whole bit

- everything I put into place,

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

in jail for 5 days

for what they did to me 3 months previous.


Even according to FMG, Stan was with the company until July 1, is that right?

Here are 2 certificates, June 25th, signed by Bob Long, Secreta~


I wasn't Secretary, I was a Board Member. And, this is April 24th. 1987 Semi-Annual
Report in which someone

- forged my name.

I never even saw that. They never even

had an Annual Shareholder's Meeting; they never let people examine the books that have
wanted to.

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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

- is business that good that it could stand that?

We are paced to do

$4,000,000 PC1 a year, that's a lot of money passing through your hands.

, doesn't it affect those people? Are they

Now the people that are

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

- open all my mail, then send i t to me in bunches 10

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

- who says, I am no longer associated

with them. The Post Office doesn't know

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.

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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

Scott Robinson, for instance, bought

42,000 shares. Stock certificates wouldn't

In June of 1987, he bought

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

'

- someone for Bob Kauf f man

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

shares. If they can't get at you to sign the shares

-- why couldn't

they get me? I was

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

even know how to d o any of that

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.

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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

But he is from Lancaster? Yes, but he was working in

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

sort of swimming trying to

get everybody straight. It's not easy, believe me. Time is one thing that I have a lot
of

- so do I.

I can't d o anything else, what can I do?

Did you ever hear of a


some outfit

or

organization? Some years ago, there was

- New Environmental Technology - Remember when that was floating around.

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
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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

- illegally.

last year

- Now there license has not

- there is over $100,000

been approved yet.

of our RIA fees that they have collected

Did you say IRA? Registered Investment Advisor. Do you want to

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

- and I think he is very

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

know it was there. Now I am still President of

FMG Advisory. O.K., now wait a minute

- let me see, FMG Advisory comes in yet.

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

- oh, alright, you're

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?

but not with the

Right

But, now, during this time

- from the time they are in business, from August of

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
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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 question is about that long and

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

they get lost or whatever. You can attach it to

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

exactly right, but they didn't have a Board of Directors

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

- this was one of

Kauffman's move to gain

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

.
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Your only connection with the company now is the fact that? I have no connection.
They will not let me

- and I have personal

belongings in that office, and they owe me

money. That is something that you two are going to iron out. See, my involvement is
criminal charges

- that's

how I am involved. And my involvement is going to be the

mishandling of investor's money.


Well, all of these other financial management groups are 100% stock holders
Advisory Inc

- FMG

100% stockholders? Yea, what it is, the shareholders own Financial

Management Limited; Financial Management Limited owns all the other subs. O.K., 100%

there is no other involvement? That's right.

- I think there would be some


give it to anybody - not even me. You

Financial Management Group's Semi Annual Report


financial information

- that's

right, they won't

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.

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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

Your money is invested through

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

- but he still owns the stock?

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.

I had no money - 5 days without food

- 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