judge mary mclaughlin 05-2288 amendment to complaint october 15 2007 important

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Stanley J. Caterbone Advanced Media Group 1250 Fremont Street Lancaster, PA 17603

UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA _____________________________________________________________________

Stanley J. Caterbone : PLAINTIFF : : v. : CASE NO. 05-2288 : CASE NO. 06-4650 : Lancaster County Prison, et al. : : : :

AMENDMENT TO COMPLAINT AND MOTION FOR CONTINUANCE

AND NOW on this 15th, day of October, 2007, I, Stanley J. Caterbone, PLAINTIFF, Pro Se

Litigant, do hereby file before the Courts an AMENDMENT to the above case. The PLAINTIFF

requests the Court to grant an additional 60 days to further amend this complaint and to amend

and/or dismiss case no. 06-4650 on or before December 15, 2007, at the time of the next

amendment to this complaint. The PLAINTIFF also seeks clarification from the Court per the rules

of original service; otherwise the PLAINTIFF will service all defendants, both original and the

additional defendants per the 120-day rule after the filing of the next amendment to this

complaint. The PLAINTIFF will also meet with the Federal Bureau of Investigation on October 15,

2007 at the time of this filing to report activities, which have prevented the PLAINTIFF from

completing this amended complaint per the order of July 25, 2007.

Date: October 15, 2007 Stanley J. Caterbone, Pro Se Litigant

1250 Fremont Street Lancaster, PA 17603 [email protected] http://www.amgglobalentertainmentgroup.com/

Advanced Media Group of 63 10/12/2007

DEFENDANT’S LIST

LANCASTER COUNTY PRISON LANCASTER COUNTY SHERIFF DEPARTMENT COMMONWEALTH NATIONAL BANK, MELLON BANK FULTON BANK SOUTHERN REGIONAL POLICE DEPARTMENT MANHEIM TOWNSHIP POLICE DEPARTMENT AVALON POLICE DEPARTMENT STONE HARBOR POLICE DEPARTMENT AMERICAN HELIX TECHNOLOGY CORPORATION DAVID D. DERING THE HIGH GROUP PETER PENEROS SCOTT ROBERTSON (X) RIC FOX, ATTORNEY ROBERT CHERCICOFF, ATTORNEY PLANNERS SECURITIES GROUP YOLANDA CATERBONE (X) STEVE CATERBONE (X) PHIL CATERBONE (X) MICHAEL CATERBONE (X) COPELLO AND FOLEY LAW FIRM LEW SCHWELLER, ATTORNEY DR. LEVINE, PSYCHIATRIST ANDREW APPEL, ATTORNEY APPLE, YOST & SORENTINO LAW FIRM LANCASTER AVIATION, INC., CHUCK SMITH FINANCIAL MANAGEMENT GROUP, LTD., ROBERT F. KAUFMAN MICHAEL HARTLETT

ROBERT R. LONG (X) JAMES WARNER BURDETTE TOMLIN HOSPITAL CRAIG RUSSELL, ATTORNEY RUSSELL, KRAFT, GRUBER, AND HUBER, LAW FIRM LARRY SIGLER, MANHEIM TOWNSHIP POLICE DEPARTMENT LARRY MATHIAS, MANHEIM TOWNSHIP POLICE DEPARTMENT NANCY ARMENT (X) STACY WALTERS (X) LANCASTER NEWSPAPERS, INC. SOUTHERN REGIONAL HOSPITAL, FORMER SAINT JOSEPH HOSPITAL ROBERT BEYER, ATTORNEY (X) JOSEPH RODA, ATTORNEY MARY LYNN DIPAOLO (X) MAGISTERIAL DISTRICT JUSTICE MURRAY HORTON MICHAEL MCDONALD, ATTORNEY JOHN DEPATTO LT. MADENSPACHER, MANHEIM TOWNSHIP POLICE DEPARTMENT DR. AL SHULZ, PSYCHIATRIST REGIONAL MEDICAL CENTER, ST JOSEPH HOSPITAL LANCASTER NEWSPAPERS, INC. PFLUMM CONTRACTORS, INC. DAVID PFLUMM (X) PAMELA SUE PFLUMM

KERRY EGAN OFFICER ROBERT FEDOR, SOUTHERN REGIONAL POLICE SGT. ROBERT BUSSER, SOUTHERN REGIONAL POLICE LANCASTER GENERAL HOSPITAL DR. EMILY PRESSLEY


Judge Mary McLaughlin ORDER of July 25, 1987:

“AND NOW, this 25th day of July 2007, upon consideration of the plaintiff's Motion for

Continuance (Doc, No. 56) and defendant Mannheim Township's opposition thereto (Doc. No. 57), IT IS

HEREBY ORDERED that the said motion is GRANTED, the plaintiff shall have until October 15, 2007, to

amend his complaint: If the plaintiff does not do so, this case will be dismissed, with prejudice, The

Court will not grant the plaintiff any more time extensions for the filing of his amended complaint.”

I) INTRODUCTION – Not Complete

II) JURISDICTION: Not Complete

1. Count I - 18 U.S.C. § 1961 through 18 U.S.C. 2. Count II - § 1968, RICO; 31 USCS 3. Count III - § 3729-33 Federal False Claims Act; 4. Count IV - extortion, 5. Count V - defamation of character, 6. Count VI - slander, 7. Count VII - wrongful interference with business relations, 8. Count VIII - wrongful interference with contracts, 9. Count VIIII - breach of contract 10. Count X - a plea for an accounting; 11. Count XI - deceptive and fraudulent practices 12. Count XII - breach of fiduciary duty 13. Count XIII - unfair competition 14. Count XIIII - tortuous interference with business relationships 15. Count XV - unjust enrichment 16. Count XVI - a pattern of racketeering in violation of the Racketeering Influenced and

Corrupt Organizations Act (“RICO”), 18 U.S.C. § 1961 et seq. 17. Count XVII - “illegal retaliation” 18. Count XVIII - “unlawful discrimination” 19. Count XVIIII - intentional infliction of emotional distress 20. Count XX - wrongful repossession 21. Count XXI – trespass to person 22. Count XXII – civil conspiracy 23. Count XXIII – violation of due process 24. Count XXIIII – conspiracy to commit fraud 25. Count XV – loss of liberty 26. Count XVI – false imprisonment 27. Count XVII – false arrest 28. Count XVIII – collusion 29. Count XVIIII – false statements 30. Count XXX– trespass to property 31. Count XXXI – conversion 32. Count XXXII – replevin 33. Count XXXIII - breach of contract arising out of the alleged repossession 34. Count XXIV – assault 35. Count XXXV – battery


36. Count XXXVI - malicious prosecution 37. Count XXXVII - malicious abuse of process claims arising out of the charges and arrest 38. Count XXXVIII – mail fraud

III) HISTORY OF COMPLAINT – Not Complete

IV) AMENDED COMPLAINT – Not Complete

1. Legal Arguments and issues of the Statute of Limitations and Time Barred Causes of

Actions that support that justice has been denied and due process subverted thus granting

relief to the PLAINTIFFS:

a. (“RICO”), 18 U.S.C. § 1961 et seq.; A claim may be barred by the statute of

limitations if you discovered or reasonably should have discovered your injury four

or more years ago.

b. Civil RICO claims are not subject to a statute of limitations. Congress failed to

include a statute of limitations when it passed the RICO Act, but the United States

Supreme Court has remedied that oversight and imposed a four-year statute of

limitations on all civil RICO claims.

c. Civil Rico's statute of limitations begins to run when the victim discovers or

reasonably should have discovered its injury. Once a victim is aware or should be

aware of its injury, the victim has four years to discover the remaining elements of

its claim and bring suit. A victim cannot sit on its rights and refrain from filing suit

in the face of known injuries.

d. There are several equitable doctrines that may toll or suspend the running

of the statute of limitations. If a defendant fraudulently conceals facts that

are essential to the victim's ability to purse its rights, the running of the

statute of limitations may be tolled.

e. Acts of duress, such as "if you sue me, I'll kill you," may toll the running of

the statute of limitations.

f. All tolling doctrines are based upon whether it is fair, under the

circumstances, to bar the victim's claims on the basis of the running of the

statute of limitations.

g. If a defendant engages in a new pattern of racketing, that causes new and

independent injuries, a new limitations period may apply to those new and

independent injuries.

2. The Racketeer Influenced and Corrupt Organizations Act (commonly referred to

as RICO), 18 U.S.C. § 1961 et seq.;: RICO is a United States federal law which provides for

extended penalties for criminal acts performed as part of an ongoing criminal organization.

RICO was enacted by section 901(a) of the Organized Crime Control Act of 1970, Pub. L.

No. 91-452, 84 Stat. 922 (Oct. 15, 1970). RICO is codified as Chapter 96 of Title 18 of the


United States Code, 18 U.S.C. § 1961 through 18 U.S.C. § 1968. RICO addresses long-

term, not one-shot, criminal activity. Not only must a RICO claim be based upon criminal

activity, but the criminal acts must constitute a "pattern" of criminal activity.

a. A single criminal act, short-term criminal conduct, or criminal actions that bear no

relationship to each other will not give rise to a RICO claim. The United States

Supreme Court has ruled that criminal actions constitute a "pattern" only if they are

related and continuous.

b. In order to be "related," the criminal acts must involve the same victims, have the

same methods of commission, involve the same participants, or be related in some

other fashion. A pattern may be sufficiently continuous if the criminal actions

occurred over a substantial period of time or posed a threat of indefinite duration.

c. The former patterns are referred to as closed-ended patterns; the latter patterns

are referred to as open-ended patterns.

d. Accordingly, even if you have been injured by a criminal act, you will not have a

RICO claim unless that criminal act is part of a larger pattern of criminal activity.

CAUSES OF ACTIONS

3. Lancaster Aviation arrange for the selected aircraft to be flown in from the Midwest to be

inspected by PLAINTIFF. Pete Wolfson of Lancaster Aviation conducts the meeting, as an

official agent of Lancaster Aviation. Commonwealth Bank has approved the financing of

$97,000 for the purchase. The additional $25,000 required is not yet available. Pete

Wolfson insists that the plane must be purchased before being flown back to the Midwest.

Pete Wolfson requests a post-dated check from PLAINTIFF for the remaining balance.

PLAINTIFF refuses, citing that the remaining funds must be liquidated from the Keystone

Mutual Fund, and the exact receipt of the moneys is not guaranteed, and could take up to

10 days. Pete Wolfson agrees not to deposit the check until PLAINTIFF confirms that the

funds have been received and deposited in order to cover the check for the remaining

$25,000. PLAINTIFF makes sure that Pete Wolfson has the authority to make the

arrangement, and Pete Wolfson agrees. The purchase of the airplane was also subject to a

pre-purchase inspection by Lancaster Aviation. Lancaster Aviation also advises PLAINTIFF

to have his airplane included in their Fleet Insurance plan. PLAINTIFF also advises

Lancaster Aviation that he would like to offer the airplane to his business associates for

use in order to subsidize the costs and maintenance.

4. Chuck Smith, president of Lancaster Aviation, later discloses to PLAINTIFF that he had

deposited PLAINTIFF’s pre dated check for $25.000, without the confirmation by PLAINTIFF

that the funds had been transferred from accounts. PLAINTIFF had argued with Pete

Wolfson, the salesman for Lancaster Aviation, that he did not want to give them a post

dated check, however Chuck Wolfson insisted. Now, Chuck Smith had told PLAINTIFF that


Pete Wolfson did not have the authority to complete the transaction. However PLAINTIFF

reminded Chuck Smith that he was acting as an agent for Lancaster Aviation, and that was

not material to this dispute.

5. Lancaster Aviation and Commonwealth Bank engaged in Count IV - extortion, defamation

of character, slander, wrongful interference with business relations, wrongful interference

with contracts, obstruction of justice, trespass to person, unfair competition, fraud,

conspiracy, embezzlement, breech of contract and several violations in lender liability; in

later repossessing the aircraft on July 1, 1987 with no advanced notice and no reason or

cause. Commonwealth Bank was the mortgagor on the property of Olde Hickory, which

the PLAINTIFF had a loan commitment of $5 million to refinance that property. Lancaster

Aviation will deny the PLAINTIFF’s airplane to provide service to a scheduled charter by

Jim Bly of Source Management of Virginia on June 27, 1987. The PLAINTIFF had an

agreement for $300.00 per hour and an estimated 6-hour charter planned.

6. On June 23, 1987 Larry Resch, an executive of both International Signal & Control,

Plc,.(ISC) And United Chem Con visits PLAINTIFF at Financial Management Group, Ltd.,

headquarters in Lancaster, as scheduled to discuss business opportunities. Larry Resch

explains "we had to fly Carl Jacobson out of the country early this morning" as the reason

for his not being able to attend the meeting as planned. Larry Resch discusses possible

strategies to rescue Chem Con’s Minority 8A Set-aside contracts, and solicits financing for

new facility. PLAINTIFF becomes annoyed the context of the conversation, especially the

lack Of disclosure, and discusses allegations of wrongdoing by Guerin and International

Signal & Control, Plc, and the relationship to United Chem Con. After evaluating the

financial statements, PLAINTIFF also suggests there is approximately $15 to $18 million in

missing funds.

7. Mr. Larry Resch failed to inform the PLAINTIFF of his association and position with

International Signal & Control, Plc., while the PLAINTIFF formally began his whistle blowing

activities on International Signal & Control, Plc..

8. On June 23, 1987, at 2:00 pm immediately following the meeting with International Signal

& Control Executive, Mr. Larry Resch, the PLAINTIFF has his locks changed to his office by

Russell Locksmith of Lititz, in order to secure confidential personal and business files in

light of the current internal power struggle between himself, Michael Hartlett and Robert

Kauffman, and given the conversation with Mr. Larry Resch of International Signal &

Control, Plc., a few hours earlier.

9. The Plaintiff was a personal guarantor of a 5 year lease agreement with the Developer,

Fishcer Spounagle, Ltd., for the offices of Financial Management Group, Ltd., at 1755

Oregon Pike, Lancaster, Pennsylvania, that began in 1986 and did renew until 1991.

10. Robert Kaufman, President of FINANCIAL MANAGEMENT GROUP, Ltd., and other


FINANCIAL MANAGEMENT GROUP, Ltd., executives burglarize PLAINTIFF's office removing

confidential personal and business tiles. Some of the mortgage banking and other

business files have yet to be found. Kauffman and Robert Long illegally issue FINANCIAL

MANAGEMENT GROUP, Ltd., stock certificates to Peter Peneros and Scott Robertson.

Robert Long signs the stock certificates as Secretary of FINANCIAL MANAGEMENT GROUP,

Ltd., when PLAINTIFF was acting Secretary, and was the only person duly authorized to

issue FINANCIAL MANAGEMENT GROUP, Ltd., stock certificates. PLAINTIFF learned of the

burglary by Robert Kauffman, President, in a telephone conversation while at Stone

Harbor, NJ; Kauffman inadvertently mentioned that the stock certificates were issued,

however, with all documents at risk of being stolen, PLAINTIFF did not mention the

incident, in hopes to first recover any potentially stolen business and personal files.

11. Financial Management Group, Ltd., executives engaged in obstruction of justice, in unfair

competition, wrongful interference with contracts, trespass to person, criminal trespass,

forgery, undo influence, conspiracy, embezzlement, Count IV - extortion, mental duress,

slander, defamation of character, wrongful interference with business relations, and

violated several bylaws of Financial Management Group, Ltd.,

12. On May 20, 1987, the PLAINTIFF and Attorney Ric Fox, of Harrisburg, Pennsylvania, draft

the legal Letter of Intent for investors of Power Productions I, which the PLAINTIFF was

general partner. The PLAINTIFF had several interested parties some which have made

verbal commitments, including Norris Boyd and Dave Cook, an executive of Turkey Hill

Minit Markets.

13. On June 29, 1987, the PLAINTIFF received patent research materials from patent attorney

Joel S. Goldhammer, of the prominent Philadelphia law firm Siedel, Gonda, Goldhammer &

Abbot regarding the "Digital" Movie, and the national franchising of Financial Management

Group, Ltd.,. PLAINTIFF had retained the services of Siedel, Gonda, Goldhammer, and

Abbot in order to investigate all relevant matters concerning the technology,

merchandising, and marketing of the "Mutant Mania" project, and the use of the "Power

Station" label. Research was required for the merchandising of consumer electronics,

professional audio/visual digital mixing consoles, and the "Power Station Digital Movie

System (PSDMS)”, as created by PLAINTIFF in the proposal for SONY Corporation of

Japan.

14. On May 11, 1987, the PLAINTIFF invested and paid Scott Robertson, executive vice

president of Financial Management Group, Ltd., $2,000 dollars from a personal account for

an advance for work on mortgage banking projects and the “Digital Movie”. On the same

day the PLAINTIFF paid film producer Marcia Silen, of Flatbush Films, Hollywood,

California, an advance of $750.00 for a cash advanced for work with the “Digital Movie”

project.


15. The PLAINTIFF was executor producer of the project, general partner of Power Productions

I, the investment group, and named in the “Mutant Mania” budget to receive a salary of

$100,000. In addition the PLAINTIFF had agreements to receive royalties on all revenues

associated with both the distribution of the film and video release and all branding of the

merchandise from the project.

16. Financial Management Group, Ltd., it’s officers and employees, along with other

Defendants including but not limited to Commonwealth National Bank (Mellon Bank)

(Mellon), Fulton Bank, the Manheim Township Police Department engaged in unfair

competition, wrongful interference with contracts, trespass to person, criminal trespass,

forgery, undo influence, conspiracy, embezzlement, Count IV - extortion, mental duress,

slander, defamation of character, obstruction of justice, wrongful interference with

business relations, and other anti trust violations pertaining to the “Digital Movie” project.

17. The PLAINTIFF, on behalf of Financial Management Group, Ltd., began research and

discussions with corporate attorney, Jeff Jamanou of the law firm McNesse, Wallace and

Nurick regarding franchising the concept of Financial Management Group, Ltd, on a

national scale and considerations for a stock split. The PLAINTIFF handled all legal

endeavors of Financial Management Group, Ltd.,

18. Beginning in April of 1987, Financial Management Group, Ltd, officers and executives

engaged in a pattern of unfair competition, wrongful interference with contracts, trespass

to person, obstruction of justice, criminal trespass, forgery, undo influence, conspiracy,

embezzlement, Count IV - extortion, mental duress, slander, defamation of character,

wrongful interference with business relations, and other anti trust violations.

19. On June 18, 1987, the PLAINTIFF and Randy Grespin, corporate attorney for The Life

Underwriters Group, fly to Atlanta, Georgia, to visit with executives of Planners Securities

Group, a nationally known Broker Dealer, and joint venture partner that was in the midst

of a deal in which Financial Management Group, Ltd., had negotiated an equity interest.

The PLAINTIFF had initially consulted with both Kauffman and Hartlett concerning the trip,

however when both disagreed, The PLAINTIFF questioned why the PLAINTIFF was the only

principal to personally visit the operations of Hibbard Brown & Company, which lead the

PLAINTIFF his decision to terminate the ill fated merger.

20. Planners Securities Group, was regarded as the most successful Broker Dealers in the

financial planning community, and included several former presidents of the national board

of the International Association of Financial Planners. The company had previously been

recruiting Financial Management Group, Ltd.,., and offering an attractive equity interest.

Randy Grespin agreed to reimburse $600 to The PLAINTIFF for the expense and use of his

aircraft.

21. The PLAINTIFF had the following agenda for the trip and meeting:


a. Visit and discuss the joint venture and merger with Financial Management Group,

Ltd., and evaluate the various departments necessary to administer Financial

Management Group, Ltd.,'s., stock transactions and private real estate offerings.

b. Discuss and evaluate the opportunities of utilizing insurance products from Randy

Grespin's firm, and all matters related to the structuring of business.

c. Familiarize Greg Burie, a personal friend and recruitment of The PLAINTIFF’s who

was also visiting from Florida to consider opening a Florida office for Financial

Management Group, Ltd..

d. Conduct an extensive and thorough due diligence investigation of the stability,

efficiency, and security of the operations, in order to prevent a similar situation that

facilitated the previous termination of the recent Hibbard Brown & Company deal.

The PLAINTIFF left the meetings with very optimistic and impressive findings, that

only left more questions as to the decision of Kauffman and Bartlett to affiliate with

Hibbard Brown & Company, knowing that the Atlanta group had been aggressively

pursuing talks of a merger since the inception of Financial Management Group,

Ltd.,., On the return flight home, The PLAINTIFF confided to Randy Grespin,

requesting legal advise, regarding the recent problems and his allegations of

misconduct by Financial Management Group, Ltd.,., President Robert Kauffman.

Randy Grespin advised The PLAINTIFF to take some time and seek legal counsel.

22. On June 18, 2007, after arriving at the corporate offices of Upon entering the offices of

Financial Management Group, Ltd., Robert Kauffman pulls The PLAINTIFF into his office

and abruptly shouts "Who is running this corporation, me or you?". The PLAINTIFF quickly

answers "I don't give a damn who runs this company. as long as it's run right, and for the

right reasons!" The PLAINTIFF immediately left the office.

23. On June 18, 1987, later in the evening, Robert Kauffman, President visits the home of the

PLAINTIFF and engaged in a contractual dispute when the PLAINTIFF refused to agree to

approve the new contract and salary increase of Robert Kauffman, President,. Robert

Kauffman, President, engaged in retaliatory and activities, including fraud, Count IV -

extortion, libel, defamation of character, obstruction of justice, and conspiracy.

24. June 22, 1987, The PLAINTIFF hires Todd Dellinqer, a planner in Financial Management

Group, Ltd.,., to help administrate the daily activities of his personal clientele and to

perform administrative duties necessary due to the amount of time The PLAINTIFF is

conducting business out at the office, allowing The PLAINTIFF to focus attention on the

Strategic Planning, and allowing him to better manage his time. The PLAINTIFF sends a

memo to client and shareholder Dr. William Umiker that introduces his new assistant, in

addition to information regarding his pension accounts.

25. FINANCIAL MANAGEMENT GROUP, Ltd, Board of Directors meet to vote on PLAINTIFF's


request and demand to ratify the recent joint venture agreement/contract with Hibbard

Brown & Company, after PLAINTIFF learned of dire inefficiencies within Hibbard Brown &

company, and the "Born Again" relationships of Kauffman, that placed an unprecedented

amount of risk to FINANCIAL MANAGEMENT GROUP, Ltd.,. PLAINTIFF voted by telephone

from the Chicago Airport, in the midst of his travel to Palm Springs and Hollywood

California. The Board also voted to negotiate and approve a deal with the Planners

Securities Group, of Atlanta, GA. PLAINTIFF had won the votes of Alan Loss and Robert

Long, overturning the decision of Robert Kauffman, President, and Michael Bartlett and

officially terminating the agreement. This vote, in and above itself, took control of the

Board of Directors from Kauffman and Bartlett, and put the power of the Board in the

direction of PLAINTIFF. This will eventually lead to the Coup conspired by Kauffman and

Hartlett to find a way to get PLAINTIFF out of the corporation.

26. On January 20, 1987, the PLAINTIFF and Al Dannatt, a principal and managing partner

with the commercial mortgage banking company Institutional Investors of Houston, Texas,

consummate a joint venture agreement where the PLAINTIFF will market and solicit clients

on the eastern part of the regional for commercial mortgages with a lending authority of

$3 to $100 million dollars. The agreement also calls for the PLAINTIFF to develop other

joint venture proposals and business transactions with a bank the Institutional Investors

was in the process of purchasing. The PLAINTIFF in turn would began to offer the joint

venture to members of Financial Management Group, Ltd., to offer finder fees to both

Financial Management Group, Ltd., and any members of Financial Management Group,

Ltd., which referred clients and projects.

27. The PLAINTIFF alleges that the following revenue sources:

a. Financial Planning Fees and Commissions

b. Financial Management Group, Ltd., Management Salary

c. Mortgage Banking Business

d. Real Estate Limited Partnerships (Dave Schaad, Jim Bly, Dave Cook)

e. Pension Fund Portfolio Management (Harsco, Inc., of Harrisburg)

f. Life Insurance Joint Venture Agreements

g. Personal Real Estate Investments

h. Air Charter Services

i. Reorganize Gamillion Film Studios

j. Equity Interests in Financial Management Group, Ltd.,

have the following violations Count IV - extortion, defamation of character, slander,

wrongful interference with business relations, wrongful interference with contracts,

trespass to person, unfair competition, fraud, conspiracy, embezzlement, breech of

contract


28. On June 25, 1987, Financial Group Executives burglarized the PLAINTIFF’s office and

began to extort the PLAINTIFF business interests in the Institutional Investors joint

partnership. Up to that point in time, the PLAINTIFF had developed a pipeline in excess of

$100 million in projects, a firm commitment for a satellite office in Hollywood, California,

and a commitment for a $5 million second mortgage on the Olde Hickory Properties, of

Lancaster, County. The PLAINTIFF was able to offer more attractive financing

arrangements than that of the local commercial lending institutions, including Fulton Bank

and Commonwealth Bank. Both banks would eventually engage in anti-trust violations.

29. On June 29, 1987, The PLAINTIFF visits with Dave Schaad, President of the York based

real estate firm of Bennett Williams, Inc., The PLAINTIFF was finalizing plans to secure

financing of a $2.5 million office complex for the new headquarters of Bennett Williams, as

well as 3 or 4 additional anchor tenants. The PLAINTIFF had been working with Dave

Schaad for the past 3 months, along with Scott Robertson. The PLAINTIFF had previously

discussed the deal with Dave Cook, and executive and former owner of the Turkey Hill

Convenience Stores. Dave Cook indicated a serious interest in providing the entire $2.5

million investment. The above deal would have provided over $150,000 of fees upon

settlement to The PLAINTIFF upon settlement. Prior to the meeting, Dave Schaad had

indicated by telephone, that Robert Kauffman had invited himself to the meeting, without

prior consent or notice to The PLAINTIFF, During the meeting, The PLAINTIFF disclosed the

current criminal activities within the principals of Financial Management Group, Ltd., being

facilitated by Robert Kauffman himself.

30. In June of 1987, Jill Carson, a Fulton Bank Branch Manager libeled and slandered the

PLAINTIFF in notifying Mr. Chuck Smith, owner operator of Lancaster Aviation, the Plaintiff

was bankrupt and had no liquid funds, which was totally fabricated. At the time of this

infringement and at least until August 8, 1987, the PLAINTIFF’s credit rating as reported

by the Lancaster Credit Bureau was perfect, with all creditors “paid in full within 30 days,

as agreed”. The credit report included 22 creditors. Being that the PLAINTIFF was a

customer, borrower, and a client in good standing with Fulton Bank, this amounts to

defamation of character, slander, wrongful interference with business relations, wrongful

interference with contracts, trespass to person, unfair competition, fraud, conspiracy,

embezzlement, breech of contract.

31. On July 1, 1987, the PLAINTIFF retained the counsel of Mr. Joseph F. Roda, Esq., of

Lancaster, to arrange for a meeting to discuss the recent events and Coup attempt by

Kauffman and Hartlett that included several criminal and security violations. The

PLAINTIFF visits with Mr. Joseph F. Roda, Esq. and describes the incidents in detail,

including the "Digital Movie", ISC, and all related activities. Mr. Joseph F. Roda, Esq.

instructs The PLAINTIFF to have all of the files copied and arranges for the return of all


Financial Management Group, Ltd., corporate files. The PLAINTIFF had questioned Mr.

Joseph F. Roda, Esq. for a legal opinion as to his right of any moneys in Financial

Management Group, Ltd., checking accounts that he was authorized to sign for. Mr.

Joseph F. Roda, Esq. advised that The PLAINTIFF had no right to any funds. All checks

were returned to Financial Management Group, Ltd., along with all other documents.

32. The PLAINTIFF advises Mr. Joseph F. Roda, Esq. that he is in fear that someone is

deliberately orchestrating all of the recent incidents, which were quite extraordinary and

extremely criminal and have been coming from all directions. The PLAINTIFF advised Mr.

Joseph F. Roda, Esq. that he would like to take all of his files to Stone Harbor, New Jersey

for safekeeping while he pursued his legal recourse. The PLAINTIFF also explained that he

would feel safer leaving Lancaster until these circumstances were brought under control.

33. Mr. Joseph F. Roda, Esq., failed to provide any advocacy representation; colluded with

Financial Management Group, Ltd.,; failed to inform the PLAINTIFF of any conflicts of

interests with current clients (Mr. William Clark, in house legal counsel for International

Signal & Control, Plc.,); was negligent in not reviewing the hundreds of documents the

PLAINTIFF delivered and for not identifying causes of actions, which United States District

Judge Mary McLaughlin identified from similar documents in June of 2006; was negligent

in not believing the PLAINTIFF detailed account of the Commonwealth National Bank

(Mellon Bank) wrongful repossession, may have conspired to cover-up the PLAINTIFF’s

Federal False Claims Act against International Signal & Control, Plc,.

34. Mr. Joseph F. Roda committed fraud in invoicing the PLAINTIFF for services rendered,

without any actual benefit afforded to the PLAINTIFF.

35. The Defendants conspired to discredit the PLAINTIFF with a massive campaign of libel,

slander and deceit when immediately following the meeting with International Signal &

Control, Plc., meeting of June 23, 1987 the following contracts were terminated without

cause:

a. Planners Securities Group, Ltd., NASD Series 22 Securities License

b. Planners Securities Registered Representative Agreements

c. William O. Umiker Executor of Estate

d. Michael T. Caterbone Power of Attorney

36. On July 3, 1987, at approximately 12:00 am, Victor Miasnikowcs, owner operator of Romar

Aviation (Currently Venture Jets, Inc.) calls The PLAINTIFF to notify him that his aircraft

was reposed some hour earlier, and locked in the hanger of Lancaster Aviation, with all of

his personal and business files on board. Victor only would say that Commonwealth Bank

had taken part in the repossession, with no reasons given. The first payment of the loan

agreement with Commonwealth National Bank (Mellon Bank) was not due until July 25,

1987 and the $25,000 cash deposit for the airplane was now officially extorted from the


PLAINTIFF. There was no money due to Commonwealth National Bank (Mellon Bank). The

PLAINTIFF also becomes quite suspicious, after learning a few weeks earlier that his efforts

to provide a refinance of some $6 million to Boyd Wilson Properties, was more favorable

than the existing or proposed financing arrangements now place with Commonwealth

National Bank (Mellon Bank), which not only has a lender relationship with The PLAINTIFF,

but is also a competitor for his mortgage banking activities. It was also known that The

PLAINTIFF's lending authority was larger and more competitive than most of the local

banking community. The PLAINTIFF now becomes in fear for his life due to this incident,

and all other unexplained incidents in the preceding days and weeks.

37. Commonwealth Bank engaged in an illegal repossession, conversion, replevin, trespass,

fraud, breach of fiduciary duty, and/or breach of contract arising out of the alleged

repossession, Count IV - extortion, lender liability, interference with business contracts

and relations, civil conspiracy, fraud, and violated anti-trust and lender liability laws.

38. On July 4, 1987 at approximately 9:00 am in the morning, The PLAINTIFF calls his

attorney Mr. Joseph F. Roda, Esq., under emotional duress from the previous conversation

with Victor and the repossession of his aircraft with all documents on board; Mr. Joseph F.

Roda, Esq. responds "Stan, you have to quit fabricating these allegations, it is July 4th,

what do you want me to do. This conversation reaffirms a conspiracy theory within

Lancaster to ruin him, and supports his efforts to leave Lancaster with his files to solicit aid

and support from legal and law enforcement authorities to suppress the conspiracy. The

PLAINTIFF realizes that the documents were authentic proof and evidence of all of his

allegations, and most importantly all of his business activities for the past 5 or more years.

The loss of the files would have devastating consequences for his life.

39. Mr. Joseph F. Roda committed fraud in invoicing the PLAINTIFF for services rendered,

without any actual benefit afforded to the PLAINTIFF.

40. On July 4, 1987, at approximately 9:30 am, after the disturbing phone, The PLAINTIFF

drives to the Cape May County Airport to solicit the services of a pilot to fly to Lancaster to

retrieve his files. Brad Donahue accepts the job, and agrees to a $200 tee, and an

additional $200 it there are any difficulties in obtaining the files. The PLAINTIFF provides

Brad Donahue with all documentation showing legal title to the aircraft in the event

authorities are notified. The PLAINTIFF gives explicit instructions to notify the police in the

event personnel will not return all of the files. Brad Donahue arrives a few hours later, with

boxes of files. Brad Donahue briefly describes an encounter at Lancaster Aviation, and

demands payment of $400 as agreed. An invoice is signed by all parties as proof of

payment and the activity, and $400 in cash is paid to Brad Donahue. Pilot Dave Austin, of

the Cape May County Airport witnesses the transactions and the event.

41. In the following weeks, Dave Austin, would later disclose to The PLAINTIFF that Brad


Donahue was killed in a mysterious "Air-Accident", while over water, with an unexplained

and questionable flight chart.

42. The PLAINTIFF solicits the legal services of Ric Fox, a Harrisburg attorney that has

prepared legal documents for the "Digital" Movie. Rio Fox flies his aircraft to the Cape May

County Airport, and arrives at The PLAINTIFF's house accompanied with another attorney

Robert Chercicoff. All of the recent activities were detailed and described concerning

Financial Management Group, Ltd.,; the "Digital Movie"; and the illegal repossession of the

aircraft. The PLAINTIFF questioned Mr. Fox and his associate of any relationship with

Commonwealth Bank, which headquarters were also in Harrisburg, and both gave a very

ambiguous answer. The meeting ended with both attorneys failing to recognize or admit to

any wrongdoing by any and all related parties, and further demanding a $2,000 retainer

fee to look further into the matters. The PLAINTIFF suspects the conspiracy theory again,

especially in light of the acknowledged relationship with Commonwealth Bank, and an

indirect relationship with Robert Kauffman, through Life Underwriters of Harrisburg, a joint

venture arranged by The PLAINTIFF some months earlier. By July 5, The PLAINTIFF had

already made two legitimate attempts to solicit legal aid for the unexplained events and

circumstances, both of which were maliciously sabotaged.

43. Ric Fox and Robert Chercicoff engaged in conspiracy, collusion, interference with business

contracts, interference with business relations, and had attempted to thwart and cover-up

the PLAINTIFF’S Federal False Claims Act complaint.

44. On July 6, 1987, In an effort to document the conspiracy theory, PLAINTIFF requests Tom

Caterbone to call Robert Kauffman, President, to inquire about the status of his affairs, and

to tape the conversation. Tom Caterbone identifies himself as John Green, a client of

PLAINTIFF's and Robert Kauffman, President, states the following: "PLAINTIFF has moved

his office to Stone Harbor, NJ.. he is not taking care of business, and I need to see to it

that his clients are taken care of for the time being.. he has been spending a lot of money,

an airplane, a place at the shore, and he seems to think that he is too important for his

traditional clientele.. There is some history of mental disorders in his family history.. I

can't come right out and say that that is what's going on,.... I wish Stan would get some

professional help.. However for the time being, Stan is not taking care of business, and I

need to be concerned for his clients.”

45. On July 6, 1987, PLAINTIFF telephones Dr. Al Schulz, psychiatrist at St. Joseph Hospital,

and client of PLAINTIFF's in order to thwart the allegations of insanity. Dr. Al Shulz had

disclosed that several persons, including Mary Lynn Dipaolo and Jere Sullivan had called

him concerning PLAINTIFF's behavior and activities.

46. From the allegations, Dr. Shulz advised that PLAINTIFF was suffering from illusions of

grandeur, and prescribed Lithium treatment, and to return to Lancaster for consultation.


PLAINTIFF insisted that the allegations were purely fabricated, and that no one had any

legal right to interfere with his business and or legal affairs, let alone his confidential

medical records.

47. On July 6, 1987, PLAINTIFF contacts David Drubner, of Boston, Ma, a friend of PLAINTIFF's

brother’s Mike, and an attorney. During the conversation, David Drubner questions

PLAINTIFF about "taking some medication", and supports the allegations of insanity.

48. On July 17, 1987 PLAINTIFF travels to Hollywood, California to meet and visit with Ted

Gamillion and Gamillion Studios (Film Studio), and Marcia Silen of Flatbush Films. Ted

Gamillion had previously solicited the consulting of PLAINTIFF in order to help reorganize

the financing of the film studio, after earlier arrangements in North Carolina had gone

sour. PLAINTIFF had spent several days visiting and touring the studio. Ted Gamillion

agreed to allow PLAINTIFF to represent the studio in order to secure the required

financing. Ted Gamillion provided PLAINTIFF with substantial amounts of confidential

financial, legal, and tax documents for the project.

49. During the visit, Marcia Silen had disclosed to PLAINTIFF that Scott Robertson had made

allegations of insanity about him (PLAINTIFF) to persons at Power Station Studios and and

Flatbush Films.

50. In the following days, PLAINTIFF had made numerous telephone calls to local, state, and

federal authorities, for intervention and help regarding all of the preceding events and

circumstances. The following is a brief description of each: Manheim Township Police

Department, responded "what bank branch repossessed your aircraft"; Pennsylvania State

Senator Gib Armstrong, responded, "I will call the Pa Attorney General's Office and have

them call you; the Federal Bureau of Investigation (FBI), the Philadelphia-based field

office; U.S. Representative Robert Walker (R-Pa), a detailed and explicit conversation with

Mrs. Robert Walker, who would only advise PLAINTIFF to put his situation in writing and

submit it to the Congressman in his Washington, D. C. office. In addition: David Wouls

(Executive Vice President of the Lancaster chamber of Commerce & Industry), PLAINTIFF

talked at length, and in detail, making allegations of misconduct with members of the

same; National Association of securities Dealers (NASD), in Washington, D.C., PLAINTIFF

discussed the securities related violations. And also: the Securities & Exchange

Commission (SEC), also in Washington, D.C., and discussed securities laws violations; the

Pennsylvania Securities Commission, of Harrisburg, Pa, discussed the implications of

PLAINTIFF's illegal lock-out, and his legal and formal positions, including incorporating

officer of Financial Management Group, Ltd., PLAINTIFF received no support or follow-up

communications concerning all of the above requests, despite his apparent emotional

duress, and extreme situation.

51. On July 2, 1987, The PLAINTIFF negotiates with Romar Aviation to provide pilot; storage;


and insurance with his aircraft after many very questionable occurrences at Lancaster

Aviation, just a few hundred feet away. The PLAINTIFF secures insurance and pays

$1,000 to Romar Aviation for the flight to Stone Harbor and insurance, which was

conducted by Victor M. of Romar Aviation. In addition, at the referral of Victor, The

PLAINTIFF calls Sam Goode, of Sam Goode Assoc., to bind insurance for the aircraft. Sam

Goode Binds the insurance and instruct The PLAINTIFF to mail a payment of $750. The

conversation took place in Romar Aviation, at the time the $1,000 was paid to Victor. The

PLAINTIFF loads his aircraft with all of his personal and business files to be transported to

the Cape May County Airport, just a few miles outside of Stone Harbor, in the morning of

July 4.

52. In July and August of 1987 Mr. Robert Kauffman, President, had several meetings with

Millard Johnson, client of PLAINTIFF since 1982, in efforts to coerce Millard Johnson to

provide false statements to a bonding company that a legitimate loan from Millard Johnson

to the PLAINTIFF was instead an act of embezzlement of $25,000 of funds that were

transferred to the PLAINTIFF for an investment. Mr. Millard Johnson testified in person on

September 29, 1987 before Mr. Howard Eisler of the Pennsylvania Securities Commission

in a recorded interview and attested to the preceding. Mr. Millard Johnson refused and

notified Mr. Robert Kauffman that his attempt was a serious crime.

53. Mr. Kauffman and Mr. Michael Hartlett, a principal and partner of Financial Management

Group, Ltd., contracted with an insurance company on June 29, 1987 an errors and

omissions insurance policy for corporate officers of Financial Management Group, Ltd., in

an effort to collude, conspire, and defraud that insurance company of a claim, while at the

same time committing slander, libel, and conspiracy to extort the PLAINTIFF’s stock

holdings, and all other business interests.

54. On July 24, 1987, Michael M. Hartlett sends a letter to all creditors of Financial

Management Group, Ltd., informing them that stated the following: “The PLAINTIFF is no

longer an officer of the corporation; he was removed from office on July 1, 1987; he had

been purchasing items under Financial Management Group, Ltd., and obtaining corporate

discount and rates; and formally notifying them that The PLAINTIFF had never had the

right to purchase items through Financial Management Group, Ltd., or make corporate

commitments on behalf of Financial Management Group, Ltd., or contract or in any way

obligate Financial Management Group, Ltd.,.”

55. Mr. Michael M. Hartlett engaged in slander, libel, defamation of character, conspiracy to

commit fraud, conspiracy to commit Count IV - extortion, interference with business

relations, and interference with business contracts.

56. On July 7th, 1987, the PLAINTIFF contacts the law firm of Capello & Foley, of Santa

Barbara, California. The PLAINTIFF had conducted research (American Bar Association


Journal) in "Lender Liability", which had became a very popular legal issue, where banks

participate in illegal activities resulting in the financial ruin of it's borrowers. The

PLAINTIFF intended to file suit against Commonwealth National Bank (Mellon Bank) for the

illegal and unjustified repossession of his aircraft. The PLAINTIFF discussed the case briefly

with Diane Campell that day, and The PLAINTIFF made arrangements to deliver supporting

documents to the office in Santa Barbara the following week, while visiting with Gamillion

Studios, in Hollywood.

57. On July 8, 1987, A formal notification of the termination of The PLAINTIFF's Registered

Representative Securities license with the Planners Securities Group Inc., of Atlanta, GA is

received, with a "cc: Robert Kauffman".

58. Planners Securities Group, Inc., engaged in conspiracy to commit Count IV - extortion,

conspiracy, fraud, libel, defamation of character, slander, Count IV - extortion,

interference with business relations, interference with business contracts, and had violated

several anti-trust violations.

59. No explanation was provided, or any reasons for the termination. The PLAINTIFF’s reprisal

for disclosing criminal activities to the proper authorities is that he will illegally loose his

privilege to sell securities without any merit.

60. On July 8, 1987, The PLAINTIFF's brothers, Steve, Phil, Mike, and Tom, arrive

unexpectedly and uninvited at the residence of The PLAINTIFF's in Stone Harbor, NJ, and

refuse to leave until The PLAINTIFF agrees to take Lithium and return to Lancaster to

undergo treatment by Dr. Al Schulz, for mental illness.

61. Steve Caterbone, Phil Caterbone, Mike Caterbone, and Tom Caterbone had engaged in

conspiracy, libel, slander, defamation of character, conspiracy to commit Count IV -

extortion, interference with business relations, interference with business contracts,

invasion of privacy, and civil trespass.

62. On July 9th, 1987, The PLAINTIFF receives a notice by regular 1st class mail from

Commonwealth National Bank (Mellon Bank) regarding the repossession of 9 days prior.

The following reasons are given for the repossession: Failure to provide adequate

insurance; Removal of aircraft from Lancaster Aviation; Intended plan to fly aircraft to

Florida without prior written notice.

63. Commonwealth National Bank (Mellon Bank) engaged in violations of lender liability by not

providing advanced notice of the repossession with any opportunity for the PLAINTIFF to

cure any legitimate deficiencies in the lending agreements.

64. On July 10, 1987, the PLAINTIFF receives a formal notarized notification from Dr. and Mrs.

William Umiker of Financial Management Group, Ltd., removing The PLAINTIFF as the

former Trustee for their Estates.

65. On July 10, 1987, Mr. Robert Kauffman also sends a personal letter to all of The


PLAINTIFF’s clients informing each and every one “ that he has moved to Stone Harbor,

NJ; that he may not handle investments at all; and that people close to The PLAINTIFF had

requested that he, Robert Kauffman, personally service his clientele.

66. Robert Kauffman engaged in Count IV - extortion, fraud, libel, slander, defamation of

character, conspiracy to commit Count IV - extortion, interference with business relations,

interference with business contracts, invasion of privacy, and civil trespass, and violated

several anti-trust statutes.

67. On July 15, 1987 the PLAINTIFF travels to Boston, Massachusetts to research lender

liability and other legal matters in a law library of Suffolk Community College.

68. On July 16, 1987, the PLAINTIFF travels to New York, from Boston, MA, to visit with Bob

Walters of Power Station Studios, to discuss the allegations of Blackmail, and to find out

who is involved, including Scott Robertson and Power Station Studios.

69. On July 17, 1987, the PLAINTIFF travels to Hollywood, California to meet and visit with

Ted Gamillion and Gamillion Studios (Film Studio), and Marcia Silen of Flatbush Films. Ted

Gamillion had previously solicited the consulting of The PLAINTIFF in order to help

reorganize the financing of the film studio, after earlier arrangements in North Carolina

had gone sour. The PLAINTIFF had spent several days visiting and touring the studio. Ted

Gamillion agreed to allow The PLAINTIFF to represent the studio in order to secure the

required financing. Ted Gamillion provided The PLAINTIFF with substantial amounts of

confidential financial, legal, and tax documents for the project. During the visit, Marcia

Silen had disclosed to The PLAINTIFF that Scott Robertson had made allegations of

insanity about him (The PLAINTIFF) to persons at Power Station Studios and at Flatbush

Films.

70. The PLAINTIFF discusses the illegal repossession and other related matters, however

during the conversation, becomes suspicious when Bob Walters and Tony Bongiovi disclose

that the "Digital" Movie project is suddenly suspended until a later time.

71. On July 21, 1987, At 2:30 pm The PLAINTIFF visits the law firm of Capello & Foley, in

Santa Barbara, California, and delivers 3 large blue binders for Diane Cambell and attorney

Barry Capello to review, concerning his allegations of dire violations of lender liability with

specific regards to the illegal repossession of his aircraft by Commonwealth National Bank

(Mellon Bank). The PLAINTIFF research the law firm of Capello & Foley at the Suffolk law

library and learned that it was the leading law firm in the nation leading the way in

violations of lender liability litigation.

72. The law firm of Capello & Foley and the PLAINTIFF had numerous communications,

although there was never any commitment for representation by Capello & Foley, it is

alleged that the law firm engaged in conspiracy, collusion, interference with business

contracts, interference with business relations, and had attempted to thwart and cover-up


the PLAINTIFF’S Federal False Claims Act complaint by not acting in good faith with the

solicitation of the PLAINTIFF.

73. On July 24, 1987 The PLAINTIFF conducts a three (3) hour meeting at his residence in

Stone Harbor, NJ, with attorney Lew Schweller regarding legal action concerning all events

and activities of the prior days and months. The PLAINTIFF also gives Lew Schweller a

$500.00 retainers fee, for his representation.

74. Lew Schweller engaged in conspiracy, collusion, interference with business contracts,

interference with business relations, and had attempted to thwart and cover-up the

PLAINTIFF’S Federal False Claims Act complaint.

75. On July 24, 1987, Attorney Joseph Roda invoices The PLAINTIFF $527.00 for the time and

services of July 1 & 2, 1987.

76. On July 30, 1987, The PLAINTIFF had paid $600 to Dr. Levine, a Psychiatrist from North

field, New Jersey, for an objective evaluation of his mental state of mind, in order to prove

the fabricated allegations of 'insanity". Dr. Levine had conducted a 2-hour meeting in his

residence in Stone Harbor, NJ, and required The PLAINTIFF to complete the Minneapolis

Multiphase Personality Inventory (MMPI). The PLAINTIFF completed the test, and

immediately returned it to Dr. Levine. After several weeks without any communications

from Dr. Levine, The PLAINTIFF had called for the results. Dr. Levine had explained that

he had conducted telephone interviews with members of The PLAINTIFF's family, without

notice or consent, in addition to the original request of The PLAINTIFF to conduct an

objective and confidential examination. In addition, Dr. Levine prescribed Lithium drug

therapy, and disclosed a diagnosis of Bi-Polar Mood Disorder.

77. Dr. Levine engaged in Count IV - extortion, conspiracy to commit fraud, defamation of

character, slander, libel, and obstruction of justice.

78. On August 6, 1987, the law firm of Appel, Yost & Sorentino, of Lancaster, Pa., sends a

formal notice to The PLAINTIFF, demanding the return of a facsimile machine leased from

the ACM Company of Lancaster, Pa. Attorney Appel advises The PLAINTIFF that it is the

property of Financial Management Group, Ltd., and should be returned at once or legal

action will follow.

79. Appel Yost & Sorentino and Attorney Appel engaged in fraud, collusion, libel, slander,

defamation of character, conspiracy to commit Count IV - extortion, interference with

business relations, interference with business contracts.

80. On August 7, 2007 the PLAINTIFF receives a Credit Report from the Credit Bureau of

Lancaster County as requested. The credit report up to the date of August 1, 1987 verifies

and confirms that his credit report was excellent, without any blemishes. The history of all

accounts was "paid within 30 days, or as agreed".

81. On August 8, 1987, John M. Wolf, Executive Vice President of Commonwealth National


Bank (Mellon Bank) sends The PLAINTIFF a formal letter advising that the repossession of

July 2, 1987 was both lawful and appropriate, and declines to accept a settlement of $5

million for lender liability violations.

82. On August 10, 1987, the PLAINTIFF receives a facsimile from the Board of Directors of

Financial Management Group, Ltd., signed by Robert Long as “The FMG Board of Directors”

threatening to file criminal charges for "embezzlement (we have checks to prove it),

burglary, employee theft, corporate opportunity and slander against our firm".

83. Financial Management Group, Ltd., engaged in obstruction of justice, in unfair competition,

wrongful interference with contracts, trespass to person, criminal trespass, forgery, undo

influence, conspiracy, embezzlement, Count IV - extortion, mental duress, slander,

defamation of character, wrongful interference with business relations, and violated

several bylaws of Financial Management Group, Ltd.,

84. On August 12, 1987, Yolanda Caterbone, mother of The PLAINTIFF, Steve, Phil, Mike, and

Tom Caterbone, all brothers, arrive unexpectedly and uninvited to the residence of The

PLAINTIFF in Stone Harbor. After several requests for the visitors to leave the premises

are denied, several brothers refuse to let The PLAINTIFF leave the premises. The

PLAINTIFF flees, and the brothers chase after him. The PLAINTIFF runs into a neighbors

house to ask to use the telephone to phone the police. However, after realizing that he is

scaring the occupants, he flees to the Stone Harbor Police Department, a few blocks away,

in an effort to obtain a restraining order and to lawfully have the unwanted persons vacate

his residence and personal property. Officer Steve Conners and Officer Henry Stanford

refuse the request, and hold The PLAINTIFF in custody. After some 30 minutes, the

officers, accompanied by Steve and Tom Caterbone, place The PLAINTIFF into a Police

Cruiser and proceed to the Burdette Tomlin Hospital, in Stone Harbor. Upon arriving, The

PLAINTIFF is interrogated and questioned extensively about a "gun". A hospital staffer

then accuses The PLAINTIFF of an attempted suicide and keep him in custody for 4 or

more hours. An extensive mental health evaluation is performed by another hospital

staffer. The PLAINTIFF is given an ultimatum of signing a contract in order to be released

form the hospital, the contract stated: "I Stanley J. Caterbone will not take my life tonight

or at anytime".

85. Yolanda Caterbone, Steve Caterbone, Phil Caterbone, Mike Caterbone, Tom Caterbone

engaged in invasion of privacy, civil trespass, obstruction of justice, wrongful interference

with contracts, trespass to person, criminal trespass, forgery, undo influence, conspiracy,

embezzlement, Count IV - extortion, mental duress, slander, defamation of character,

wrongful interference with business relations; and engaged in psychiatric abuse.

86. The Stone Harbor Police, James Warner (Current Executive Director of the Lancaster

County Solid Waste Management Authority) and Burdette Tomlin Hospital engaged in


obstruction of justice, wrongful interference with contracts, trespass to person, criminal

trespass, forgery, undo influence, conspiracy, embezzlement, Count IV - extortion, mental

duress, slander, defamation of character, wrongful interference with business relations and

engaged in psychiatric abuse.

87. On August 13, 1987, the PLAINTIFF At approximately 9:30 am, The PLAINTIFF returns to

the Burdette Tomlin Hospital to obtain a formal copy of the incident the preceding night.

After some arguments1 hospital officials provide explicit records of the event, including the

following summary: "Stan was brought to the ER (emergency room) by two brothers and

police. Police received a phone call from Jim Warner, (872-9081, friend staying at the

Conestoga residence of the PLAINTIFF), who told them he believed ‘Stan planned to take a

gun, go to the beach & kill himself’. Client denied any such statement, thoughts or plans.

He has legal and difficult times, financial deals which have fallen through; license to do

financial planning (his business) revoked; repossessed material goods (airplane); being

blackmailed; and several major financial deals (in which he had invested personal funds)

fall through-but NO PROBLEMS! Denied any Depression”.

88. On August 14, 1987, the same family members again arrive unwanted at the residence of

The PLAINTIFF in Stone Harbor, NJ. After another confrontation, similar to the incident of

two evenings before, The PLAINTIFF fleas to the Avalon Police Department for another

attempt to get a restraining order. However, en route, just a few blocks from the Avalon

Police Station, an Avalon Police cruiser pulls The PLAINTIFF over and arrests him for the

following violations:

a. Driving Beyond the speed limit.

b. Driving an unregistered vehicle (all required registration materials were in

Lancaster, PA)

c. Containing an empty beer can in his vehicle (which was at .1 east three days old)

89. In addition, the Avalon Police Department repossessed his car and locked it in the Avalon

Police Department compound, which was his only means of transportation and

communication by car phone.

90. Again, Yolanda Caterbone, Steve Caterbone, Phil Caterbone, Mike Caterbone, Tom

Caterbone engaged in invasion of privacy, civil trespass, obstruction of justice, wrongful

interference with contracts, trespass to person, criminal trespass, forgery, undo influence,

conspiracy, embezzlement, Count IV - extortion, mental duress, slander, defamation of

character, wrongful interference with business relations; and engaged in psychiatric abuse.

91. The Avalon Police Department engaged in false arrest, false imprisonment, false

statements, civil conspiracy, malicious prosecution and/or malicious abuse of process

claims arising out of the charges and arrest; and (2) civil rights claims under 42 U.S.C. §

1983, arising out of the Department's actions or inactions during court scheduled hearings


in 1987.

92. On August 24, 1987, Robert Kauffman sends a letter to Millard Johnson, The PLAINTIFF's

client, regarding his previous intentions of paying the $25,000 demand note of The

PLAINTIFF to Millard Johnson. Robert Kauffman had previously promised to pay the debt

to Millard Johnson during a meeting. Robert Kauffman, told Millard Johnson to contact the

Financial Management Group, Ltd., attorney, Craig Russell in order to file legal claim, and

formally disclosed that he would: “ no longer handle any discussions concerning Stanley J.

Caterbone”. In the last paragraph, Robert Kauffman discloses "attorney Mr. Patterson, no

longer represents the Caterbone family regarding his pending bankruptcy or

guardianship". The PLAINTIFF never gave any legal jurisdiction or rights to any family

member, has never filed for bankruptcy, was not bankrupt, or even knew of an attorney

named Mr. Patterson.

93. Robert Kauffman and Craig Russell engage in conspiracy to commit fraud, libel, slander,

defamation of character, conspiracy to commit Count IV - extortion, and false statements.

94. On September 1, 1987, in an attempt to resolve issues, The PLAINTIFF calls Financial

Management Group, Ltd., board member P. Alan Loss and requests a meeting with Robert.

long and Scott Robertson to explain allegations of misconduct of Robert Kauffman and

Michael Hartlett and the illegal lockout of The PLAINTIFF. P. Alan Loss agrees and a

meeting is set for September 4, 1987 at 10:00 am in the aide Hickory Inn, a mile away

from Financial Management Group, Ltd., The PLAINTIFF requests that the meeting be in

the strictest of confidence.

95. On September 3, 1987, Attorney Joseph Roda sends The PLAINTIFF a letter requesting

payment of $525.48 in outstanding legal tees for the meetings of July 1 & 2 and copying

charges.

96. The PLAINTIFF calls Victor of Romar Aviation (no charge) to schedule a charter flight from

Cape May County Airport to the Lancaster Airport for September 3rd at approximately

2:00 pm, the day before the meeting with Financial Management Group, Ltd., executives.

97. On September 3, 1987, Robert Kauffman calls detective Larry Sigler of the Manheim

Township Police Department to report an alleged Terroristic threat made two days prior,

on September 1, 1987, by The PLAINTIFF between the hours of 9:00 and 1 pm noontime.

Detective Larry Sigler issues a warrant for the arrest of The PLAINTIFF with District Justice

Murray Horton that was issued at about the same time as the arrival of The PLAINTIFF at

Romar Aviation.

98. On September 3, 1987, Larry Sigler and the Manheim Township Police Department engage

in false imprisonment, false arrest, malicious prosecution and/or malicious abuse of

process claims arising out of the charges and arrest in September 1987; and (2) civil

rights claims under 42 U.S.C. § 1983, arising out of the Department's actions or inactions


in July and September 1987, and January 1991.

99. On September 3, 1987, At approximately 3:00 pm Mary Lynn Dipaolo picks The PLAINTIFF

up at Romar Aviation for a scheduled visit and dinner. After The PLAINTIFF becomes

annoyed at Mary Lynn Dipaolo's unjustified allegations, The PLAINTIFF borrows her car to

go home to his residence in Conestoga and to go play basketball.

100. On September 3, 1987, at approximately 7:00 pm, upon leaving the playground, he is

approached by Nancy Arment, Financial Management Group, Ltd., secretary, who is

elaborated and crying, asking "why are you doing this?".

101. Nancy Arment of Financial Management Group, Ltd., engaged in harassment and

conspiracy to commit Count IV - extortion.

102. On September 3, 1987, At approximately 9:00 pm, in an attempt to recover additional

stolen personal and business tiles, The PLAINTIFF proceeds to the offices of Financial

Management Group, Ltd., where he is greeted by employee Stacy Waters and allowed to

enter the building. The PLAINTIFF insists that Stacy Walters accompany him throughout

the building as he recovers files in the offices of Robert Kauffman, Michael Bartlett, and

Robert Long. In addition retrieving a Back-Up (Financial Management Group, Ltd., records

and communications) copy of the computer system which he integrated. Upon leaving,

The PLAINTIFF temporarily disconnect the systems which he had integrated and developed

for Financial Management Group, Ltd., which fall under intellectual property rights. Stacy

Walters assists The PLAINTIFF in loading the tiles in his automobile, and The PLAINTIFF

kisses Stacy Walters goodbye, and awaits for her safe return to the building until leaving.

103. Stacy Walters engaged in criminal trespass, conspiracy to commit Count IV - extortion,

undo influence, mental duress, slander, defamation of character, and wrongful interference

with business relations.

104. On September 4, 1987, after midnight, upon entering his residence, the PLAINTIFF is

taken into custody by the Conestoga Police, and requests that the files that he had taken

out of the offices of Financial Management Group, Ltd., be taken along to prove his rights

to the property, and his position within the company. The PLAINTIFF was then taken to

the jurisdiction of Manheim Township Police, at Where the New Danville Pike meets South

Prince Street, where he is arrested and taken into custody.

105. On September 4, 1987, at approximately 2:00 am, The PLAINTIFF is arraigned before

District Justice Richard R. Reeser for the following charges: Terroristic threats; burglary;

unlawful restraint; unlawful use of computers; theft by unlawful taking; robbery; and

criminal mischief.

106. Bail is set at $20,000 and The PLAINTIFF is placed in the Lancaster County Prison. He was

not permitted to post real estate for bail.

107. The Manheim Township Police Department, Detective Larry Mathias and the Lancaster


County Prison engage in (1) assault, battery, false imprisonment, false arrest, malicious

prosecution and/or malicious abuse of process claims arising out of the charges and arrest

in September 1987; and (2) civil rights claims under 42 U.S.C. § 1983, arising out of the

Department's actions or inactions in July and September 1987, and January 1991.

108. September 5, 1987 - The Lancaster New Era and the Lancaster Intelligencer Journal report

the alleged crimes, reporting that The PLAINTIFF is an ax-employee; that Financial

Management Group, Ltd., sustained $60,000 because of his actions; and that he

threatened 2 female employees.

109. The Lancaster Newspapers, Inc., engaged in libel, slander, defamation of character,

conspiracy to commit fraud, conspiracy to commit Count IV - extortion, conspiracy to

commit obstruction of justice.

110. The entire arrests and reports fail to acknowledge that The PLAINTIFF is an individual

lessee of the property, and in accordance with law, still holds all of his offices of PING,

Ltd., and is the founder of the company. The above incident further facilitates the ongoing

conspiracy, and publicly discredits The PLAINTIFF in every way, financially, professionally,

and most importantly conveniently supports the continued allegations of insanity.

111. On September 6, 1987, all attempts to post bail are denied. Robert Beyer appears for

visitation at the Lancaster county prison, completely unexpectedly and unsolicited. Robert

Beyer offers his services and representation with regards to only defending the criminal

charges.

112. On September 9, 1987, The PLAINTIFF is given an ultimatum by the Lancaster county

prison authorities, Robert Bayer, Yolanda Caterbone, and Mary Lynn Dipaolo of posting the

required bail only if The PLAINTIFF voluntarily admits himself into the Psychiatric Unit of

St. Joseph Hospital, or remains in the Lancaster County prison.

113. The PLAINTIFF is released from Lancaster County prison, and immediately escorted to St.

Joseph Hospital and admitted into the Psychiatric Unit.

114. On September 9, 1987, Yolanda Caterbone, Robert Beyer, and Mary Lynn Dipaolo engage

in conspiracy to commit fraud, false statements, and conspiracy to commit Count IV -

extortion, obstruction of justice, and false imprisonment.

115. On September 15, 1987, The PLAINTIFF questions the legality of the ultimatum for posting

bail, and upon learning that it is unlawful, arranges for his discharge - Upon his discharge,

the St. Joseph Hospital administrators learn that Financial Management Group, Ltd., had

terminated his health insurance, and demand payment of $3, 064.60 for the six days of

hospitalization. The PLAINTIFF is not able to pay, and leaves the hospital and returns to

his residence of Conestoga, PA.

116. St. Joseph Hospital engaged in collusion to commit fraud, Count IV - extortion, libel,

slander, and defamation of character, false imprisonment, obstruction of justice, and false


statements.

117. On September 15, 1987, The PLAINTIFF receives an invoice from St. Joseph Hospital for

$3,064.00.

118. On September 16, 1987, The PLAINTIFF receives a call from Howard Eisler, an Investigator

for the Pennsylvania Securities Commission who requests a meeting with The PLAINTIFF.

A meeting is scheduled for September 29, and The PLAINTIFF arranges for Robert Beyer

and Millard Johnson to attend.

119. On September 21, 1987, ISC and the British Ferranti firm agree in principal to merge,

creating what appeared to be a $1.5 billion defense/electronics conglomerate, after six

months of negotiations.

120. On September 22, 1987,The PLAINTIFF and James Warner settle on the real estate deal,

of 433 w. Marion Street, which The PLAINTIFF had sold to James Warner, at a distressed

price, which still yielded a profit. The profits of the transaction were paid directly to Millard

Johnson, with The PLAINTIFF getting none of the proceeds. Millard Johnson’s funds were

extorted by Commonwealth National Bank and Lancaster Aviation.

121. The parties engaged in Count IV - extortion of funds, collusion to commit fraud, and civil

conspiracy.

122. On September 25, 1987, Art Kerst visits The PLAINTIFF at his residence and accuses him

and his cousin of being connected with the Mafia, and conspiring together, in order to

provide the financing of the $50 million shopping center in Florida, that was originally

owned by the Fisher/Sponougle Group, and diverting the profits of the deal away from him

(Art Kerst) and the Fisher Sponougle Group.

123. The PLAINTIFF becomes infuriated, not only at the absurd allegation, but the timing, when

in fact The PLAINTIFF had bean fighting for his life for the past 4 months, and to even

consider such activities would be insane.

124. On September 29, 1987, Howard Eisler conducts a meeting at the Residence of The

PLAINTIFF, with all parties consenting to have the meeting recorded by The PLAINTIFF.

125. Howard Eisler was not able to provide a believable explanation of what he was

investigating or why he had contacted The PLAINTIFF. The PLAINTIFF explains all of the

circumstances regarding his prior meeting with ISC/Chem Con executive Larry Resch, and

details his allegations of wrongdoing of James Guerin/ISC/Chem Con6 and the discussions

of that meeting on June 23, 1987, with ISC executive Larry Resch. The PLAINTIFF also

discloses his ISC stock holdings, and his relationships with ISC and Chem Con associates.

126. Howard Eisler, the Pennsylvania Securities Commission, and the Commonwealth of

Pennsylvania engaged in a cover-up, obstruction of justice, public corruption, collusion and

conspiracy to commit Count IV - extortion.

127. Millard Johnson testifies to Howard Eisler during the meeting regarding a previous meeting


in August with Robert Kauffman, where Robert Kauffman tried to persuade Millard Johnson

to fabricate a story that a legitimate personal loan of $25,000 to The PLAINTIFF in June of

1987, was instead intended for investment and embezzled by The PLAINTIFF. Robert

Kauffman wanted Millard Johnson to support this story to authorities. The PLAINTIFF

spent more than 4 hours explaining and detailing all of his allegations and business

activities including how he founded and built Financial Management Group, Ltd.,; his

mortgage banking activities; the illegal repossession of his aircraft; all of the fabricated

arrests; and the chronology of events after the June 23 meeting with ISC executive Larry

Resch. Howard Eisler ended the meeting and requested copies of documents from The

PLAINTIFF.

128. On September 1987, Scott Robertson, begins work with American Helix founder, David

Dering, to secure financing for the venture and manufacturing facility to manufacture CD

Audio & CD-ROM Compact Discs, an extension of the "Digital" technologies activities of The

PLAINTIFF.

129. David Dering solicited Financial Management Group, Ltd., to provide help in securing the

necessary $5 million of capital required .for the venture. David Dering was referred to

Financial Management Group, Ltd., by Norris Boyd (Financial Management Group, Ltd.,

shareholder) and Bob Fogarty, who had previously been working with The PLAINTIFF on

various financing arrangements. It was The PLAINTIFF that elected to allow both Scott

Robertson and Rob Long to participate in the venture capital markets. Scott Robertson

would later conduct negotiations with High Industries, Inc., to provide the entire $5 million

financial package. Scott Robertson also was named executive Vice President of American

Helix Technology Corporation, and would resign from Financial Management Group, Ltd., in

order pursue the venture on a full time basis.

130. David Deering, Scott Robertson, and Financial Management Group, Ltd., engaged in

collusion and conspiracy to commit Count IV - extortion, and violated several anti-trust

violations.

131. James Boyer, formerly the lead recording engineer for Billy Joel, was also recruited to form

the principals of American Helix, consisting of Dave Dering, Scott Robertson, and James

Boyer In mid December of 1990, David Dering will confirm the above formation of

American Helix to The PLAINTIFF, after The PLAINTIFF alleges violations at the 1934

Sherman Antitrust Act, concerning his activities in the digital technologies industries, and

the undo influence by Scott Robertson, Robert Long, and High Industries, as well as

criminal conspiracy, of all parties concerned in the destruction of his business affairs that

began in June at 1987.

132. On October 2, 1987, District Justice Murray Horton conducts a preliminary hearing for all

criminal charges against The PLAINTIFF. Attorney Robert Beyer refuses to discuss any


issues regarding his individual lease of the Financial Management Group, Ltd., offices, or

any issues resulting in the illegal activities of anyone other than The PLAINTIFF District

Justice Murray Horton orders The PLAINTIFF to defend all of the criminal charges in the

next term of criminal court in Lancaster County. The PLAINTIFF ordered to be bound over

for the next term of criminal court of Lancaster County and remain free on bail.

133. District Justice Murray Horton engaged in obstruction of justice, collusion and conspiracy

to commit Count IV - extortion, public corruption, and violated several anti-trust violations

134. On October 4, 1987, The PLAINTIFF meets with high school classmate and attorney Mike

McDonald at The PLAINTIFF's residence, to discuss legal action and recourse against all

involved. Mike McDonald accepts the case, and The PLAINTIFF provides all of the relevant

information and documentation.

135. Mike McDonald will engage in negligence, and collusion to commit Count IV - extortion.

136. On October 12, 1987, The PLAINTIFF travels to New York city to the offices of Intercon

Special Services (white collar crime detective agency) in order to attempt to obtain

assistance in all of the circumstances. Intercon Special Services, which is staffed with ax

FBI agents, estimates that the services would cost at least $25,000.

137. On October 16, 1987, The PLAINTIFF survives a near death collision on the New Danville

Pike, when a driver ran through a stop sign at the intersection of Long Lane, while

traveling at a speed of 45 mph. The driver hit The PLAINTIFF's Jeep Cherokee directly in

the passenger’s door, sending The PLAINTIFF in a free tall, spinning a full 180 degrees and

landing upside down in a field, facing the opposite direction. The PLAINTIFF was trapped in

the car, while a passerby attempted to brake the windshield to get him out. The

PLAINTIFF's car was completely demolished, and he sustained a whiplash. The PLAINTIFF

was now without any means of transportation, in addition to all of his other mitigating

circumstances.

138. On October 18, 1987, The Unemployment Compensation Review Board formally and

officially decides against a claim for benefits by The PLAINTIFF and cites misconduct and

wrongdoing as the reasons; states that the PLAINTIFF managed the day to day operations,

and used the false arrests as the reason to deny benefits.

139. The Pennsylvania Unemployment Office of the Department of Public Welfare committed

fraud, and were negligence in providing benefits.

140. On October 27, 1987, Lancaster Aviation files a civil suit with District Justice Murray

Horton for alleged unpaid bills of some $5,000.

141. In late October or early November, The PLAINTIFF was driving in the Southern end of the

County, in Conestoga, when he noticed a vehicle following closely. It was about 9:00 pm

in the evening, and the roads were deserted in this rural area. The PLAINTIFF began

turning, not going in any particular direction. The ensuing vehicle kept following, and The


PLAINTIFF quickly found himself in a high-speed car chase, that lasted at least 30 minutes.

Finally, The PLAINTIFF arrived near Millersville, and was able to loose the vehicle.

142. On November 9, 1987, The PLAINTIFF visits with Parent Federal Savings and Loan's

president, John Depatto, to discuss him problems in meeting his current mortgage

payments. John Depatto immediately disclosed to The PLAINTIFF that foreclosure

proceedings have officially begun, and that the full loan of approximately $110,000 is

immediately due. The PLAINTIFF stands up from the conference table and declares, "You

tell Mr. James Guerin he is in trouble", and abruptly walks out of the offices.

143. John Depatto engaged in collusion to commit Count IV - extortion, and conspiracy to

commit fraud.

144. On November 11, 1987, The PLAINTIFF meets with representatives of Tabor Community

Services, of Lancaster, Pa, in order to formally apply for assistance to the Pennsylvania

Homeowners Emergency Mortgage Fund, in order to subsidize his monthly mortgage

payments, in an effort to avoid becoming homeless. The PLAINTIFF supplies Tabor

community services with financial data and supportive documents relating to his

circumstances, which must be found to be out of the applicants control in order for

financial assistance.

145. On November 18, 1987, ISC-Ferranti settlement takes place with Guerin becoming the

deputy chairman of Ferranti and exchanges his is million shares of ISC stock for over 32.2

million shares of Ferranti stock.

146. On November 19, 1987, The PLAINTIFF contacts attorney Jeff Jamounou of McNeese,

Wallice, and Nurick, who The PLAINTIFF retained as legal counsel for the security law, and

demanded a legal opinion as to the offices that The PLAINTIFF formerly held, including his

Financial Management Group, Ltd., Board of Directors seat. Jeff Jamounou disclosed that

he no longer represented Financial Management Group, Ltd., in that capacity, and that

Craig Russell was the attorney now handling issues such as that.

147. On November 23, 1987, A Referees Decision by the unemployment Compensation Review

Board upholds a recent decision to deny The PLAINTIFF from collecting any benefits, again

citing misconduct and wrongdoing. The PLAINTIFF calls Howard Eisler, of the Pennsylvania

Securities Commission and demands an explanation for not returning to obtain any

documents as promised in the meeting of September 29th. The phone call was recorded.

148. On November 25, 1987, The PLAINTIFF receives a letter from the Pennsylvania Securities

Commission, Howard Eisler, citing a misunderstanding and lack of communication, and

now requests that The PLAINTIFF submit a written complaint of all allegations discussed in

the meeting of September 29, 1987.

149. On November 30, 1987, The PLAINTIFF fears that the conspiracy now involves local and

state authorities, and delivers 9,079 documents to the Good Sheppard Industrial Services,


of Allentown, PA to be transferred to microfiche in order to preserve the authenticity of the

documents.

150. The PLAINTIFF feared that an attempt would be made to destroy all incriminating

evidence, and given the number of documents, and the lack of money, their safekeeping

was becoming at great risk.

151. For security reasons, and to remain anonymous, The PLAINTIFF uses the Global

Entertainment Group, Ltd., company for the transaction with the Good Sheppard Industrial

Services company.

152. On November 26, 1987 , The PLAINTIFF visits the Pennsylvania State Police barracks in

Lancaster, to file a formal complaint to the White Collar Crime Division. The PLAINTIFF was

treated as if he was making the entire story up, and received no help.

153. On December 1, 1987, In continuing the efforts of the intervention of authorities, The

PLAINTIFF visits the PA State Capitol building and personally delivers documents to the

offices of: Pennsylvania Governor Casey; the Pennsylvania Securities Commission; and

Financial Management Group, Ltd., attorney Jeffrey Jamounou of McNeese, Wallice, &

Nurick, all of Harrisburg, PA. During the same day, at a press conference being held by

Mark Singleton, The PLAINTIFF approaches State Senator Sib Armstrong and Sen.

Armstrong refused to talk and literally ran away in the middle of the State Capitol.

154. On December 4, 1987, Financial Management Group, Ltd., holds its first annual

shareholders meeting, for the year ended June 30, 1987, at the Treadway Resort Inn

(Eden Resort Inn owned by Drew Anthon). In an effort to promote propaganda against

The PLAINTIFF, and to support the fabricated allegations of insanity, Financial

Management Group, Ltd., president hired armed security personnel to guard the doorways

of the meeting, insinuating that the meeting was under a threat of violence, and to

collaborate his recent allegations of Terroristic threats, which The PLAINTIFF was

previously arrested and awaiting trial.

155. Financial Management Group, Ltd., engaged in libel, slander, and defamation of character.

156. On December 17, 1987, The United States Postal Inspector acknowledges receipt of formal

complaint from The PLAINTIFF regarding executives from Financial Management Group,

Ltd., illegally changing or address; opening of confidential personal and business mail; and

withholding and possibly destroying confidential personal and business mail at The

PLAINTIFF's leased property of 1755 Oregon Pike, Lancaster, PA, also the headquarters of

Financial Management Group, Ltd.,.

157. On January 15, 1988, the PLAINTIFF drives to San Diego, California, and meets with

attorney Sandra Gray, and International Signal & Control, Plc., uses his dire illegalities and

to find access to due process of the law. In an effort to avoid the political consequences

of obtaining legal counsel, The PLAINTIFF thought that it would be easier to find adequate


and effective counsel from out of state. In addition, The PLAINTIFF needed some time

away from his persecutors.

158. On January 26, 1988, the Pennsylvania Homeowners Emergency Mortgage Assistance

Program formally and officially denies The PLAINTIFF of benefits citing the following: "

Applicant was terminated from job Financial Management Group, Ltd.,), therefore was not

suffering from circumstances beyond his control".

159. On March 14, 1988, The PLAINTIFF is served notice by Lancaster Constables regarding

Parent Federal .Guerin' Bank) v. The PLAINTIFF Mortgage Foreclosure of his residence at

2323 New Danville Pike, Conestoga, PA.

160. On May 1988, The PLAINTIFF is forced to sell his residence, and subdues to the undo

influence that he was responsible for all circumstances, and moves to Florida with his

brother.

161. On October 23, 1988 the PLAINTIFF, destitute, without a personal residence, automobile,

or any income, and with accumulated debts of more than $65,000 from all related

incidents in the 1987 "Blackmail", sells his Financial Management Group, Ltd., holdings to

Robert Kauffman and is given $72,000 in proceeds at settlement. This by and of itself will

be proven to be Count IV - extortion. Robert Kauffman was in fear of The PLAINTIFF

exercising his large voting rights in the upcoming Financial Management Group, Ltd.,

annual shareholders meeting, which included the election off Financial Management Group,

Ltd., Board of Directors. The PLAINTIFF had approximately 19% of the outstanding shares

of Financial Management Group, Ltd., and had the potential to vote someone of his

selection to a Board seat. Scott Robertson had solicited the deal for both parties, and

acted as negotiator for both.

162. On November 23, 1988 the PLAINTIFF completes a management-consulting proposal for

Scott Robertson, Tony Bongiovi, and American Helix for Power Station Studios of New

York. Scott Robertson had solicited the PLAINTIFF to New York to review the current

management and to author a proposal to help Tony Bongiovi manage the recording studio

and all special projects. The PLAINTIFF spent time in New York and interviewed the Power

Station management team and personnel. The Digital Movie, “Mutant Mania” project had

already been terminated in 1987.

163. On March 13, 1989, Scott Robertson, cofounder and executive vice president of American

Helix Technology Corporation, a wholly owned subsidiary of High Industries, Inc., of

Lancaster, Pa, recruits The PLAINTIFF for marketing help. The PLAINTIFF accepts a weekly

consulting contract, with no long-term commitment, in light of his efforts with Radio

Science Laboratories, Inc., Scott Robertson wanted The PLAINTIFF to help develop the new

and emerging CD-ROM business, which was essentially "Digital" technologies. American

Helix was one of 10 domestic manufacturing facilities located in the continental U.S., for


the production of CD-Audio International Signal & Control, Plc., (CD's or Compact

International Signal & Control, Plc.,), and one of only a few CD-ROM manufacturers.

164. On April 17, 1989, the PLAINTIFF incorporates Radio Science Laboratories, Inc., to further

his interest in microwave technologies, and the telecommunications industry. The

company is a venture with James & Lynn Cross, both capable design engineers with over

30 years experience. The company was trying to secure financing for the development of a

manufacturing enterprise for Low Noise Amplifiers, or LNA's as they are commonly

referred.

165. On July 8, 1989, William A. Clark, Guerin's former top INTERNATIONAL SIGNAL &

CONTROL, PLC., attorney, sues Guerin for $2 million, the balance Clark claims is owed him

in a $2.75 million settlement (over an employment dispute) accepted by Guerin in March.

Joe Roda is legal counsel for William Clark. Joe Roda was the first attorney that The

PLAINTIFF had gone to for help, who told The PLAINTIFF to “quit fabricating things”.

166. On July 19, 1989, The PLAINTIFF, Scott Robertson, and American Helix agree on a one

year employment contract, which American Helix will never fulfill in its entirety, and will be

terminated in the following April.

167. On October 10, 1989, British Labor unions urge Ferranti to drop all INTERNATIONAL

SIGNAL & CONTROL, PLC., related companies, claiming job loss in Scotland alone could

exceed 8,000 workers.

168. On October 16, 1989 , A 1987 report commissioned by Sebastian de Ferranti surfaces

showing that the company bearing his family's name was cautioned not to merge with

INTERNATIONAL SIGNAL & CONTROL, PLC., by Lazard Brothers. Ferranti chairman, Sir

Derek,Alun Jones comes under tire by stockholders who demand his resignation during the

company's annual meeting in London.

169. On October 24, 1989 , Scotland Yard joins the U.S. in the Guerin probe. Federal agents

will travel to London in January to coordinate the investigation.

170. On November 1989, Ferranti begins firing INTERNATIONAL SIGNAL & CONTROL, PLC.,

executives still within the company.

171. On December 1, 1989, Ferranti sues Guerin and three former INTERNATIONAL SIGNAL &

CONTROL, PLC., executives, including Larry Resch, for $198 million each, claiming all of

INTERNATIONAL SIGNAL & CONTROL, PLC., worth was a sham built on bogus contracts.

172. On April 1990, The American Helix Board of Directors, lead by S. Dale High/High

Industries, vote to terminate Scott Robertson of American Helix, continue the financing of

the CD-ROM business which The PLAINTIFF was directly managing. The joint venture

agreement with Network Technologies, or Washington, D.C., had lost an estimated

$450,000 in the past 9 months, and the technologies, which were to be delivered, had

proven to be worthless. Scott Robertson had solicited, negotiated, and administer the


deal, The PLAINTIFF had raised serious concerns at to the capabilities of the technologies,

the business, and Network Technologies, early in the project. High Industries then

conducted several meetings with The PLAINTIFF to purchase the business, however, The

PLAINTIFF had told the executive in a meeting on Good Friday, that he was solely

responsible for any business that was left, and any there was no real value. High

Industries agreed to pay The PLAINTIFF his weekly consulting tee only until June 30, in

hopes of negotiating an agreement to keep American Helix in the CD-ROM business, which

was only feasible with The PLAINTIFF, because of his knowledge and expertise in "Digital"

technologies.

173. On May 5, 1990, the PLAINTIFF is awarded his first government contract for CD-ROM

technologies with the National Institute of Standards and Technologies (NIST), of

Gaithersburg, Maryland. NIST is the technology arm of the federal government, similar to

the National Institute of Health (NIH), of Bethesda, Maryland. Because of the technological

complexities of the project surrounding the UNIX system environment, Phillips DuPont

(PSO) was the only other competitor in the U.S.. Computer Scientist, John Garofolo, will

coordinate the project, which is responsible for the research and development of speech

recognition systems for the Defense Advanced Research Projects Agency Information

Science and Technology Office (DARPA-ISTO) The Automated Speech Recognition Group,

will supervise the project for MIST. The group will develop CD-ROM'S containing speech

corpora for the scientific I community, including: Massachusetts institute of Technology

(MIT); Texas instruments (TI); SRI International; and other academic institutions.

174. On May 21, 1990 the PLAINTIFF and American Helix Technology Corporation, represented

by David D. Dering, sign an agreement authorizing the PLAINTIFF and Advanced Media

Group to continue all CD-ROM activities and to market the services to the markets-at-

large.

175. On October 1, 1990 the PLAINTIFF and American Helix Technology Corporation,

represented by David D. Dering, sign another agreement authorizing the PLAINTIFF and

Advanced Media Group to continue all CD-ROM activities with an agreement for payments

from all activities. The PLAINTIFF was afforded office space, secretarial, office supplies,

marketing materials, and the continuation of all support personnel of American Helix

without expense to the PLAINTIFF. The PLAINTIFF was entitled to represent all CD-ROM

services to the markets-at-large. The PLAINTIFF was to be paid on all replication,

premastering, and mastering charges to the clients. All other services were billed directly

by the PLAINTIFF. The contract and agreement will continue until the negotiation of

another agreement is reached and agreed upon. Both David D. Dering and the PLAINTIFF

have signed and executed the agreement. The agreement was dated and signed on

November 2, 1990. All previous invoices and work by the PLAINTIFF was grandfathered


into this agreement.

176. On October 11, 1990, Department of Justice claims proceeds from the sale of his Naples

home after paying the $600,000 outlined in his guilty plea agreement to the Justice

Department. Ferranti has asked the court to assist in collecting over $189 million from

Guerin, an amount awarded the firm by a British court when it said Guerin failed to

convince the court he had nothing to do with the 31 billion fraud. The PLAINTIFF begins to

organize. all relevant documents, stored in some 30 boxes, regarding all circumstances

involving the "1987" blackmail and criminal conspiracy, in hopes of finally resolving all

outstanding issues, by taking action tar legal recourse. In response from the effects of

Post Traumatic Stress Syndrome, The PLAINTIFF had rescinded efforts for due process

immediately after loosing his home and businesses. In similar matter of being

“brainwashed”, The PLAINTIFF was fearful of pursuing due process of the law in fear of

continuing reprisals, intimidation, and retaliation. However, upon the public disclosure of

the Federal courts indictments into illegal ISC activities, the PLAINTIFF began to review his

case, and find distinct and substantiated activities associated directly to his disclosure of

fraud within ISC.

177. On January 9, 1991 Lt. Madenspacher of the Manhiem Township Police Department call

The PLAINTIFF at his lab/office in him home at approximately 2:00 pm. Lt. Madenspacher

explains that he had received a copy of the letter to the Department of Defense, that

Detective Larry Mathias had forwarded to him. Lt. Madenspacher questioned his motives of

the letter and stated: "What are you going to do.. We (Manhiem Township Police

Department) just don't want to see a multi-million do00000000023llar law suit come down

our way.." The PLAINTIFF responded, "You know that I was an individual leassee of that

property, and in addition I had never resigned any offices or my Board of Director's seat

of Financial Management Group, Ltd., .. You also know that I had met with Larry Resch of

ISC on June 2S, 1987, and that I made allegations of misconduct.." Lt. Madenspacher

responded, "We were forced into that (the arrests of The PLAINTIFF on Sept. , 1987), we

were caught between a rock and a hard place, we were forced into that". Lt.

Madenspacher then changed the subject to "Digital" technologies, and described the

activities of the police department of using the same in the telephone surveillance of

criminal suspects. Lt. Madenspacher then requested to meet with The PLAINTIFF. The

PLAINTIFF agreed, however due to his current busy schedule, confirmed he would contact

him later to schedule a meeting.

178. On January 10, 1991 The PLAINTIFF sends a letter to Lt. Madenspacher of the Manheim

Township Police Department, to schedule a meeting for Thursday, Jan. 17th at 3:00 pm, at

his office at American Helix Technology Corporation, at the Green field Corporate Park.

The PLAINTIFF requested a response only if the time was in conflict of his schedule.


179. ON January 17, 1991 Lt. Madenspacher fails to show up for the scheduled meeting with

The PLAINTIFF at Amen can Helix, and never contacted him before that date to change the

meeting, or called to apologize for not being able to keep the prior commitment.

180. On January 18, 1991 The PLAINTIFF sends documents concerning the Blackmail" of 1987

to several reporters of the Lancaster Newspapers,: Tim MeKeele; Earnest Schriber; and

Thomas Planner. Tim MeKeele also received a tape with some excerpts of the September

29, 1987 meeting with the PA Securities Commission, where The PLAINTIFF discusses

allegations of misconduct against J. Guerin and ISC.

181. On January 19, 1991 the PLAINTIFF, Al Thornburg, with Dave Dering. On Saturday

morning, THE PLAINTIFF went to the American Helix facility to pick up some computer

hardware. Upon attempting to unlock the side door entrance with his 24-hour access

security card, the door would not unlock. Assuming something may have been wrong with

the security system, THE PLAINTIFF drove to the residence of Al Thornburg (former SONY

DADC engineer from Terre Huette, Indiana), the engineer for American Helix. THE

PLAINTIFF asked Al to drive over to see if his access card was operable. The PLAINTIFF

and Al Thornburg entered the building with Al Thornburg's access card and found that his

access card was inoperable throughout the building. Al then said, "Stan, your locked out".

THE PLAINTIFF said, "I was in here until 5: 00pm last evening and my access card worked

fine. THE PLAINTIFF proceeded to pick up the tape back-up and said "Let's go. I don't

want to be arrested for burglary, like I was 3 years ago. I don't know what the Hell is

going on".

182. As the PLAINTIFF and Al Thornburg left the computer room, Dave Dering appeared. This

was quite unusual, since Al Thornburg and the PLAINTIFF often work on Saturdays, and

Dave Dering had not been in the plant on a Saturday for the past few months. THE

PLAINTIFF said to Dave "Dave, why am I locked out?" He said "talk to Jim Boyer". The

PLAINTIFF, quite emphatically said, "why am I locked out?". "Stan, you'll have to talk to

Jim". THE PLAINTIFF said, "Dave, you are the president, my contract is with you, not Jim

Boyer". Dave said "Now, Stan, just calm down. This isn't a conspiracy against The

PLAINTIFF." THE PLAINTIFF told Al “I'm getting out of here. The PLAINTIFF and Al

Thornburg left the building, and Al was especially suspicious of the events and especially

why suddenly Dave Dering showed up at the building on that particular Saturday, only

moments after we arrived at the building.

183. On January 21, 1991 The PLAINTIFF Faxed a letter to David D. Dering, afraid of the

"LOCKOUT" and the lack of any events or activities that would explain such a drastic and

damaging action of American Helix citing Dave Dering in breach of the PLAINTIFF’S

business agreement and in conspiracy to eliminate or sabotage the PLAINTIFF’S business

and reputation. The fax also contained a cc: to High executives, that was never sent.


184. On January 22, 1991 the PLAINTIFF and Dave Dering Dave Dering had a telephone

conversation; "Stan, how did you get in here last night?". Stan "Dave, what are you

talking about?, I won't go near that building, the last time I went back into my own

building after being illegally locked out, I ended up in jail". Dave Dering " How did you get

in here and steal your fax?". The PLAINTIFF replied, “Dave, why would I want to steal the

fax that I wrote?" Dave Dering "You have caused a big problem. You put me in a difficult

position — I don't know if I can rectify things with the 'High's' and especially Allon Lefevre.

I always went to bat for you — how do I trust you?" A meeting was set up for 6:00 pm

later that day.

185. January 22, 1991 the PLAINTIFF met with Dave Dering and he gave three (3) reasons for

the "LOCKOUT", although never willing to engage in any real conversations relating to

those issues:

a. The computer system went down, causing a problem in the security system.

b. Jim Boyer did not reinstall the PLAINTIFF’S access identification number for the

security system.

c. Jim Boyer was to talk to the PLAINTIFF on Friday, the day before the Lockout,

concerning eliminating your access to the facility.

186. Dave Dering said "Jim Boyer said that he can take over the CD-ROM business — no

problem". Dave Dering talked about trust and who to trust. Dave Dering reluctantly

agreed to continue the business relationship and adhere to the agreements, however' only

on an arms length basis. THE PLAINTIFF was no longer allowed in the building except

during normal business hours. THE PLAINTIFF was no longer to have a private office.

187. Dave Dering never addressed the issues or the circumstances that preceded the

"LOCKOUT", and never addressed the reasons as to why there was any reason to modify

the agreement concerning my business American Helix that was established back in June

of 1990. There were no disputes, activities, or conversations that gave any indication

that American Helix, Dave Dering, or Jim Boyer intended to change or modify our

relationship.

188. On January 24, 1991: The PLAINTIFF met with Allon Lefevre (Executive Vice President of

High Industries responsible for overseeing all subsidiaries). The PLAINTIFF called a

meeting Allon Lefevre to discuss the following:

a. The R.R. Donnelly merger and acquisition of American Helix.

b. The "LOCKOUT".

189. Allon Lefevre asked questions regarding the PLAINTIFF’S contact with R.R. Donnelly and

Barry Click (President of R.R. Donnelly GeoSystems, former MAPQUEST). THE PLAINTIFF

quickly made it clear that Barry Click contacted the PLAINTIFF in December after seeing

the PLAINTIFF’S advertisement in the CD-ROM Enduser magazine, published by Linda


Helgerson. Barry Glick was elated to see someone in the local area that was involved with

CD-ROM technologies and asked to visit with the PLAINTIFF. Allon asked many questions

about Donnelly and Barry Click. THE PLAINTIFF made it clear that during the visit, and

from the discussions regarding the strategic plan of Donnelly, THE PLAINTIFF suggested

that there might be an opportunity for a merger or acquisition with American Helix. THE

PLAINTIFF also discussed the capabilities for the facility to be a dedicated CD-ROM

manufacturing facility. THE PLAINTIFF notified Allon Lefevre that Barry Glick was awaiting

a call from the PLAINTIFF the next day concerning the appropriate contact to discuss the

subject of an acquisition. Allon assured the PLAINTIFF that the High's would not contact

Donnelly directly and would await a call from Barry Click.

190. Regarding the "LOCKOUT" THE PLAINTIFF gave the three reasons that Dave Dering had

provided during our meeting a few days before to Allon Lefevre. THE PLAINTIFF told Allon

that after "THE PLAINTIFF had built a strong foundation for the CD-ROM business —

everybody suddenly wants it back, six months ago, nobody wanted anything to do with it,

not to mention the capital that THE PLAINTIFF had invested in it".

191. Allon Lefevre was only concerned with why THE PLAINTIFF had sent the Fax. "Why did

you send the Fax? I just don't understand why you sent the Fax". Allon was not

concerned with or wanted to discuss the issue of why THE PLAINTIFF was "LOCKED OUT".

Allon asked the PLAINTIFF the problems surrounding American Helix and what solutions

THE PLAINTIFF thought could help restore the company to stability. THE PLAINTIFF

discussed the lack of systems, the lack of a strong business foundation, and most

Importantly the lack of management. He asked the PLAINTIFF about Dave Dering and

THE PLAINTIFF responded, "Dave Dering is an engineer, not a manager, he has no real

management skills". Allon then asked me how to approach the meeting with Donnelly.

THE PLAINTIFF suggested that they just sit and listen to their ideas. THE PLAINTIFF asked

Allon to assure me that this meeting would be kept confidential between the two of us. He

said "THE PLAINTIFF will have to tell Dave sooner or later, and that he was not gong to get

in the middle of the two of us".

192. February 15, 1991 the PLAINTIFF met with Jim Tritch & Allon Lefevre. Allon Lefevre had

requested a meeting to be certain that THE PLAINTIFF was not representing the High's or

American Helix. THE PLAINTIFF had told Allon that THE PLAINTIFF was not concerned with

the merger issue, that the Advanced Media Group was continuing discussions with Barry

Click on various information technologies, which were strictly my business. THE PLAINTIFF

also informed him that Barry Click had told me "Stan, we are quite honestly more

interested in you rather than the facility or American Helix". THE PLAINTIFF also informed

Allon that Barry asked if THE PLAINTIFF would make a trip the Chicago, the corporate

headquarters to discuss the technologies and specifically the manufacturing technologies


of CD-ROM.

193. THE PLAINTIFF made it perfectly clear that the two (2) contacts for a merger or acquisition

that THE PLAINTIFF had provided to the High's were contacts that approached the

PLAINTIFF. THE PLAINTIFF also notified Lefevre and Tritch that Dave Dering had

requested the PLAINTIFF to look for a joint venture partner as far back as November. THE

PLAINTIFF also made it perfectly clear that THE PLAINTIFF would not solicit any leads:

unless THE PLAINTIFF was to be compensated. Alien Lefevre suggested that it may help

the PLAINTIFF to look for contacts, and THE PLAINTIFF quite emphatically restated my

contentions that THE PLAINTIFF would not do any work without compensation.

194. Jim Tritch acknowledged that THE PLAINTIFF was the only person responsible for the

development of the CD-ROM business, and the only person with any real technical

expertise in information technologies and CD-ROM, and that neither American Helix nor

High Industries had the capabilities to manufacture CD-ROMs without the PLAINTIFF. Jim

Tritch also admitted that the Advanced Media Group, Ltd., would have to be a purchased

separately in the case of any merger or acquisition of American Helix. Jim Tritch also

stated that in his initial meeting with Donnelly that they like me and wanted to continue to

work toward a business relationship. Both Allon and Jim stated that they would like to

continue to work with me in the CD-ROM business.

195. On February 15, 1991 American Helix conducted a Staff Meeting. Through an employee

that was present during the meeting, THE PLAINTIFF had learned that Dave Dering "spent

20 minutes "slimming", or slandering and defaming the character of the PLAINTIFF, and

called the PLAINTIFF “a RUNAWAY EX-CONVICT THAT WOULD END UP IN JAIL SOON".

Dave Dering also told the group that THE PLAINTIFF had almost ruined the company, and

THE PLAINTIFF should not be trusted. THE PLAINTIFF was also informed the previous day

that David Dering was telling persons that the reason that THE PLAINTIFF was out of town

in December was because "THE PLAINTIFF was on the run from authorities".

196. The PLAINTIFF was in Captiva, Florida, scanning documents and indexing the CD-ROM

“AMG Legal Prototype Disc” concerning the ISC “Cover-UP”.

197. On January 19, 1991 High Industries American Helix illegally and without notice locks The

PLAINTIFF out of his office and the facility of American Helix, who was currently under a

joint venture agreement with The PLAINTIFF and his Advanced Media Group, Ltd., for his

digital technologies business. This "Lock-Out" was similar to that of Financial Management

Group, Ltd., on July 1, 1987. Again conveniently when The PLAINTIFF had raised issues

and allegations involving Guerin and ISC.

198. On January 21, 1991 In fear and confused about his involvement, and in respect to the

massive fraud of the ISC/Ferranti merger, The PLAINTIFF sends a package to Ferranti’s

legal counsel in England by way of United Postal Service' Overnight International Delivery


Service (Tracking Number 1773 0619 670).The PLAINTIFF was in fear that a potential

"Cover-Up" by U.S. authorities, and specifically the Lancaster community, would place his

life in danger, and wanted to insure that the information concerning his knowledge of ISC

misconduct before the lSC/Ferranti merger, and his disclosure to local, state, and federal

authorities in the summer of 1987, at least would be received by Ferranti, reducing the

possibility of someone terminating his life in order so that these circumstances would not

be used as an asset in the present Ferranti Legal efforts.

199. On Jan 22, 1991In an effort to support his allegations of misconduct and the allegedly

threatening activities of The PLAINTIFF, American Helix president Dave Dering has all of

the locks in the building changed by a professional locksmith, which is nothing more than

an act of propaganda. Later that day, The PLAINTIFF and David Dering meet. David

Dering resolves to only allow The PLAINTIFF in the building during normal business hours,

and does not allow him to occupy his own office. The PLAINTIFF has never been given any

reason why he was locked out in the first place.

200. On February 1, 1991 ABC News 20/20 features the story "Weapons Sales to Iraq" about

the ISC/Cardoen cluster bomb technology and how it got to Saddam Husain.

201. On Feb 17, 1991 The PLAINTIFF receives a letter from Sandra K. Paul, of the Citizens

Ambassador Program, a division of People to People International, notifying him that he

has been selected to participate in the upcoming Printing and Publishing Delegation to the

Soviet Union and Eastern Europe in the coming August. People to People International is a

nonprofit organization started by the late Dwight D. Eisenhower to facilitate the

communications of experts from various professions throughout the world. The objective

of the delegation was to exchange ideas, information, and technologies of the printing and

publishing industries with American counterparts in the Soviet Union, and various Eastern

European countries.

202. On February 22, 1991 Federal prosecutors seize $800,000 from Clark, claiming he was

privy to information about ongoing criminal acts within ISC that generated the tainted

cash.

203. On February 1991 In an American Helix staff meeting, with all employees present, but The

PLAINTIFF, president David Dering had spent approximately 20 minutes alleging that The

PLAINTIFF almost ruined his company, and that he "is a runaway ex-convict, that will end

up in jail very soon". Engineer Al Thornburg, immediately following the meeting, disclosed

the above discussion.

204. On May 23, 1991 At approximately 2:00 pm, Jay Curtis, (appearing as a Department of

Defense contractor, who had recently solicited the services of The PLAINTIFF and his

Advanced Media Group, Ltd., to provide engineering in the development of "Digital"

simulation and training applications for various U.S. Military Logistics bases) had called


The PLAINTIFF. The following is synopsis of the conversation: "Because of your recent

discussions concerning your knowledge and information about the ISC Scandal, and an

alleged "Cover-Up", I had to do a background check on you, to insure against any

problems when including you in by proposal to the U.S. Department of Defense...

Everyone backs up your story, and is looking over your documents now, including the CIA,

IRS, SEC, FBI, Scotland Yard, Attorney General, the British M-4, and others. They are all

verifying and confirming your "cover-up" allegations.. They don't know what to tell the

Press and Media "I also know that you submitted documents to Mr. Thomas Flannery of

the Lancaster Intelligencer Journal". "How did you know about the CIA and its involvement

with ISC, how did you know that, and what do you know?" Jay Curtis kept pushing The

PLAINTIFF on the CIA issue, and what he had known and how he knew, The PLAINTIFF

kept telling him that the whole situation was to emotional, and that he was afraid for his

life. The PLAINTIFF had to eventually tell Mr. Curtis that he could not discuss this

anymore. He abruptly changed the subject and hung up on Mr. Curtis. The PLAINTIFF

immediately went to a friend’s house, and disclosed that fact that he was in fear for his

life. He quietly sat on the steps with his friend, Abby (2 years old). Later that night, his

friend Dave Pflumm would take him to the corner bar for a few drinks, while unknowing to

The PLAINTIFF, Ted Koppel was disclosing the story of the CIA’s involvement with ISC.

Several hours later, Ted Koppel broke the story about the CIA and ISC's covert operations

to sell arms to Iraq.

205. Immediately following the conversation with Mr. Jay Curtis regarding the CIA and ISC, The

PLAINTIFF packed a suitcase and confidential information assets, in preparation to leave

Lancaster, in total and legitimate fear for his life.

206. On May 23, 1991 ABC News/Nightline and Ted Koppel feature the first in a series of

stories, relating to CIA knowledge of a covert operation to supply munitions to south Africa

implemented by ISC and Carlos Cardoen. The story featured Lancaster and ISC. The

report ties Guerin to the National Security Agency project in the 1970’s. ABC News, the

Financial Times of London, and the Lancaster Intelligencer News investigated the report.

Tom Flannery of the Lancaster Intelligencer Journal appeared on the program and was

given credits on the show.

207. On May 24, 1991 The Lancaster Intelligencer Journal reports on the above story. At

approximately 1:30 pm, The PLAINTIFF drives out of Lancaster, en route to a safe haven,

and stops at a convenience store and reads the early edition of the Lancaster New Era,

learning for the first time of ABC News/Nightline story about ISC and the CIA the evening

before, just hours after his conversation regarding the same to Jay Curtis.

208. On June 7, 1991 The PLAINTIFF is again arrested by the Stone Harbor Police. After

passing several sobriety tests, and two Breathalyzer tests, The PLAINTIFF is placed in a jail


cell, and refused to be released. Several hours later, The PLAINTIFF is cited for

outstanding arrests warrants of Avalon, NJ, dated back to August 14, 1987, by an officer

of the Avalon Police department who suddenly appeared. Both arresting officers demanded

$340.00 for the posting of bail. The PLAINTIFF requested that the required cash be

retrieved from his car, located just a few blocks away. The Avalon police officer responded

by saying, "we can't let you go to your car, you may have a gun in there". The PLAINTIFF

was immediately escorted to the cape May county Prison, fingerprinted and processed.

209. On June 8, 1987 The PLAINTIFF calls Mike Orstein, Lt. of the Stone Harbor police patrol,

and requests that he retrieve the required cash from his car, and post the required bail. At

approximately 2:30 pm, The PLAINTIFF is released on bail. On June 11, 1991 The

PLAINTIFF left the Stone Harbor Marina at approximately 12:30 am en route to Lancaster,

Pa, to retrieve some files concerning the ISC cover-up. Upon driving north on Route 47

(the normal route to Lancaster), approximately 10 miles outside the Cape May county

Courthouse, The PLAINTIFF noticed a car following him closely. Suspicious, The PLAINTIFF

decreased his speed from 55 mph to 35 mph, in order for the car to pass him. However,

the car remained directly behind, adjusting the speed accordingly. In an effort to elude the

car, without raising suspicion, The PLAINTIFF gradually increased his speed, while also

increasing the distance between the cars, resulting in the loss of his taillights to the

ensuing vehicle - Because of the winding road, The PLAINTIFF looked for an abrupt turn-

off, in hopes of dashing the eluding vehicle, by loosing sight of his taillights. There was

little or no traffic on the route during the early morning hours, and The PLAINTIFF stopped

at an intersection, and noticed that the headlights of the ensuing vehicle were not visible

in his rear view mirror, meaning that his taillights were also not visible to the ensuing

vehicle. Immediately upon pulling from the intersection, The PLAINTIFF noticed a narrow

dirt road that lead into a field of small trees, the perfect place to sit for the ensuing auto to

pass him, unnoticed. The ensuing vehicle pulled to the intersection, and continued north

on route 47, in the direction of Lancaster. The PLAINTIFF sat in his vehicle a few minutes,

until continuing on his travel, north on Route 47. Approximately five (5) minutes later, a

car traveling in excess of SS mph, approached The PLAINTIFF, traveling south on the same

road (2 lanes).As the two cars approached each other, and approximately 30 yards from

reaching each other, the approaching vehicle drove directly into the lane of The PLAINTIFF,

with its high beams on, and continued straight for his vehicle, or what appeared to be a

head-on-collision. The PLAINTIFF drove off of the berm of the road, missing a line of trees

by less than 12 inches (eluding a life threatening disaster), and passed the vehicle that

was still in the north bound lane, heading south. The PLAINTIFF, shaking and sweating

furiously, noticed the cars brake lights go on, and the car apparently turned around, and

began pursuing The PLAINTIFF again. The PLAINTIFF drove as fast as he could to Route


55, hoping to find traffic in order to hide and loose the pursuing car. The PLAINTIFF

arrived in Lancaster, at approximately 3:00 am, and again noticed a car sitting in the

parking lot of the vacant "Sportsman's Den", at the intersection of the New Danville Pike

and Prince Streets. Upon driving west on Hershey Avenue, The PLAINTIFF noticed the car

following him. In an effort to identify the license plate, The PLAINTIFF made a few turns in

the area of Hamilton Watch, and followed the car heading north on S. West End Avenue.

The car was a late model, gold or tan, Cougar or possibly a Buick Park Avenue. The

PLAINTIFF watched the car increase his speed, and finally changed directions and

proceeded to his residence, and parked a few blocks away, and walked through the woods,

to his apartment in the Hershey Heritage complex. The PLAINTIFF then used a flashlight,

in order not to reveal his presence, and returned to his vehicle, sometime in the early

morning, during daylight.

210. On June 10, 1991 two independent U.S. courts uphold a $189 million award by Britian's

High Court against ISC executives Shireman and Larry Reach for their role in the fraud.

Ferranti makes its first open statement against Guerin saying a similar decision is expected

to uphold the High Court's decision against him.

211. On June 19, 1991 - The PLAINTIFF leaves Stone Harbor, in constant fear for his life, and

remains in seclusion, in various parts of the Eastern Seacoast, spanning from Captiva

Island, Florida, to Boston, MA, in order to prepare an official request for a Congressional

Investigation of all related matters.

212. On Jul 11, 1991 The PLAINTIFF files an official request C300 pages) for a Congressional

Investigation into all of the ISC and preceding issues with U. S. Representative Robert

Walker CR-Pennsylvania), and Speaker of the House, U. S. Representative Thomas Foley.

Overnight Mail Service of the United States Post Office, outside of Baltimore, Maryland,

sent both requests.

213. On July 12, 1991 The PLAINTIFF returns to his home, in Lancaster, PA, at approximately

1200 pm, after remaining in seclusion immediately following the phone conversation of

May 23, 1991 with Jay Curtis, regarding the CIA and ISC. ABC News/NightLine features it's

second story about Lancaster's ISC and Arms to South Africa and Iraq.

214. On July 18, 1991 U.S. Representative Robert Walker sends a letter to The PLAINTIFF

relating to his request for a Congressional Investigation into all of his allegations of

misconduct and criminal wrongdoing regarding his alleged ISC/Fraud "cover-up". The

letter said : "Thank you for your recent letter and information on International Signal &

Control corporation. I appreciate your thinking of me; however, since this case is before

the courts, it is unethical for me to interfere with the judicial process. If you think I may

be of assistance with other matters, please feel free to contact me".

215. On July 25, 1991 Christian is released from prison after serving two years and a day for


his role in the Chem Con fraud and toxic waste dumping.

216. On August 1, 1991 The PLAINTIFF receives a notice of a warrant for his arrest by the

Stone Harbor (NJ) Municipal Court, regarding summons #081370. The PLAINTIFF called

the Court Clerk, Pam Davidson, to explain the circumstances. The Court Clerk refused to

identify herself, and did not have time to listen to his explanation. She then questioned

why he (The PLAINTIFF) wanted to write to the Judge to explain. The PLAINTIFF writes a

formal letter to Judge Peter M. Tourison, of the Stone Harbor Municipal Court explaining

his allegations of misconduct, and the issues surrounding his recent arrest of June 7th, and

all of the arrests dating back to August of 1987. The PLAINTIFF had described in detail his

assertions and evidence that the arrests were conveniently orchestrated while he was

seeking legal recourse for the alleged ISC "Cover-Up'. The PLAINTIFF also explained his

fear for not returning to the Stone Harbor Municipality, in light of the fabricated arrests,

and other questionable incidents. The PLAINTIFF requested another means of settling all

outstanding frivolous traffic violations, other than appearing in Stone Harbor Municipal

Court.

217. On August 8, 1991 Stone Harbor Municipal Court Judge, Peter M. Tourison, sends The

PLAINTIFF an official letter acknowledging receipt of his previous letter and explanations.

Judge Tourison concluded his notice by demanding that The PLAINTIFF appear in Court, as

scheduled, "to have this matter taken care of in the proper manner

218. On August 13, 1991 Ferranti announces it has recovered $650,000 hidden by Guerin in a

number of Swiss Hank accounts. Ferranti also announces a fiscal 1991 loss of $282 million.

The PLAINTIFF responds to Judge Tourison letter of August 8, and discloses the recent

attempt on his life, the past June, just outside or Stone Harbor, and states that because of

the apparent criminal conspiracy within the same municipality, The PLAINTIFF formally

notifies the Judge that he refuses to return to Court, as requested.

219. On August 15, 1991 Guerin and Cardoen are shown to have been deeply involved in a

failed $100 million arms procurement plot linked to the infamous Iran-Contra scandal.

220. On August 16, 1991 The PLAINTIFF receives a formal notice and demand from American

Helix President David D. Dering, for the return or equipment, currently in the possession of

The PLAINTIFF, and notice of the termination of the business agreement, dated October 1,

1990 between Stan J. Caterbone and American Helix Technology Corporation. The

PLAINTIFF receives a facsimile from Mike Hess (former ISC engineer who frequented S.

Africa and who solicited The PLAINTIFF in late 1989 for work), and refuses to sign a non-

disclosure agreement with The PLAINTIFF and the Advanced Media Group, Ltd., as

requested to continue a further relationship considering the recent activities from the May

23rd phone call and the national media publicity regarding the ISC Scandal.

221. On August 19, 1991 The PLAINTIFF sends a letter to attorney Timothy Lanza via the


Lancaster Bar Association, and asks for an explanation as to his misrepresenting to The

PLAINTIFF for the past month that his order for Advanced Media Group, Ltd., stock

certificates were ordered, when in fact The PLAINTIFF verified with authorized personnel of

the H. Burr Kein company that the order was never placed. Timothy Lanza had personally

disclosed to The PLAINTIFF on several occasions that he was awaiting the delivery of the

certificate kit via UPS. The PLAINTIFF responds to the previous letter of David D. Dering,

and his request for the return of American Helix equipment, currently in the possession of

The PLAINTIFF. The PLAINTIFF formally notifies David Dering that the equipment will be

held as collateral, according to statutes of the Pa. Uniform Commercial Credit code, that

the equipment will not he returned until the past due invoice {# 1018), of the Advanced

Media Group, Ltd., of July 12, 1991 for $4,914.00, which was due upon receipt according

to their business agreement, was paid in full.

222. On August 29, 1991 A federal judge dismisses Christian's $93 million suit against Guerin,

but Christian vows to re file the suit.

223. On September 13, 1991 ABC News/Nightline features another story about ISC, the CIA,

and Arms Deals, in preparation for the beginning of the-Confirmation Hearings of George

Bush's nomination or the Director of the Central Intelligence Agency, Robert Gates, which

begins just three days away, by the Senate Intelligence Committee.

224. On September 16, 1991 The first day of the Robert Gates' Confirmation Hearings brings

questioning by Senator Murkowski, of the Senate Intelligence Committee, about

knowledge of the ISC operations by Robert Gates. Gates, whose candor about Iran-Contra

resulted in his 1987 withdraw when nominated for the same slot by then President

Reagan. In a less-than sincere line of questioning, Robert Gates denies any knowledge of

ISC, Guerin, or Carlos Cardoen, including any operations to sell munitions to Iraq or south

Africa. In addition, he denies any knowledge of any CIA involvement in the same.

225. On September 19, 1991 The PLAINTIFF visits the office of Senator Bill Bradley (D-New

Jersey), in the Hart Office Building, Washington, D.C., and delivers documents, tapes, and

a video, all relating to his allegations of an alleged "Cover-Up" regarding the ISC Scandal.

The materials were taken by assistant Jackie Widrow, who signed a receipt.

226. On September 21, 1991 The PLAINTIFF delivers a contract for the consulting services he

has agreed to provide to J. Oman Landis, in order to insure against any wrongdoing, and

especially in light of Mr. Landis' assertion the previous Friday that "you (The PLAINTIFF)

are taking a break (from business) to rest your mind". This assertion conveniently

supports the alibi of mental insanity, that has been made by numerous persons, including

Mr. Landis' friends, the High's, who wholly own American Helix Technology corporation.

Several hours after delivering the contract to Mr. Landis, and after beginning to work, as

outlined in the contract, Mr. Landis called The PLAINTIFF into his office and said "there


were some developments over the weekend, why don't you continue on your normal

duties of driving (limousines), this has nothing to do with the contract that you asked me

to sign".

227. On September 25, 1991 The PLAINTIFF mails a cover letter and accompanying materials

to attorney Howard Corny, of New York city, as previously discussed, via UPS regular way

service.

228. On October 1, 1991 The PLAINTIFF receives a facsimile from David Dering, President of

American Helix, formally charging The PLAINTIFF with charges of 16,730.00. David Dering

also demands that the equipment be returned, and upon receipt, American Helix would

forgive $11,816.00 ($16,730 - $4914)(Caterbone's invoice) of unpaid charges to The

PLAINTIFF and or the Advanced Media Group, Ltd.,

229. On October 1, 1991 The PLAINTIFF sends by certified mail, a copy of a recent complaint

(filed Sep. 6, 1991) to the New Jersey Department of Motor Vehicles, and a demand for

the title to his boat, and again allegations of criminal wrongdoing by the Stone Harbor

Marina, for not delivering title, given the bill of sale was satisfied on June 10, 1991, and a

fee for the title was paid as well.

230. On October 1, 1990 The PLAINTIFF personally meets with Ted Koppel, of ABC

News/Nightline, at the Washington National Airport, at approximately 5:30 pm. The

PLAINTIFF questioned Ted Koppel if he knew a Mr. Jay Curtis, and why he was questioned

about the CIA's involvement with the ISC affairs, just hours before the broadcast. Ted

Koppel denied any knowledge of Mr. Jay Curtis, and stated that Thomas Flannery was

involved in the broadcast by the Financial Times of London. The letter of August 28, 1987

to Diane sawyer was also mentioned. Ted Koppel requested the phone number of The

PLAINTIFF, and said that he would contact him later, due to his present time constraints,

and asked, "what do you want, and what is the story line?" The PLAINTIFF responded,

"Justice and protection, someone is trying to cover me up, and someone already made

attempts on my life... someone keeps getting information from me, while I'm left sitting in

Lancaster like a sitting duck".

231. On October 2, 1991 The PLAINTIFF responds by facsimile, to the Oct. 1, correspondence,

to David D. Dering. The PLAINTIFF requested supportive documentation regarding the

suspicious charges of $16,730.00 as declared, in order to consider the request for the

return of the equipment. David C. Dering responds by facsimile, demanding for The

PLAINTIFF to meet him at the Holiday Inn, in Lancaster on Friday, Oct 4th, with the

equipment in his possession, and states that he will deliver the required supportive

documentation of the charges as requested.

232. On October 2, 1991 The PLAINTIFF responds by facsimile to Ted Koppel, as to his

question concerning the "story line".


233. On October 27, 1991 The PLAINTIFF writes a letter to Sandra Woods, Associate Managing

Editor, of the Philadelphia Inquirer, regarding the recent feature story, "What went wrong

in America" The PLAINTIFF describes his experience and present situation regarding the

ISC scandal, and cites corruption as the cause of the present dire and destitute

circumstances controlling his life.

234. On October 31, 1991 Guerin and 19 others, including Larry Reach, are indicted on 75

criminal counts by the Philadelphia based grand jury.

235. On October 31, 1991 Laura McQueen, administrator for the New Jersey Department of

Motor Vehicles, called The PLAINTIFF at approximately 3:30 pm, to notify him that she

was trying to sort out the problem with his complaint regarding title to his boat. Ms.

McQueen acknowledged that the Stone Harbor Marina had submitted an application for a

title, apparently dated on or about June 10, however the identity of the boat did not match

that of The PLAINTIFF’s. Ms. McQueen also admitted that there seemed to be evidence of

wrongdoing, but denied to state whether the matter was presently being investigated. Ms.

McQueen also stated that the title in question was being microfiche, and that within a few

days, they should be able to trace the title, and resolve the problem.

236. On October 31, 1991 Robert Clyde Ivy, Terrance Faulds, Wayne Radcliffe, Gerald Schuler,

and Thomas Jaslin enter a not guilty pleas to all charges handed down by the Philadelphia

grand jury.

237. On November 24, 1987 Robert Shireman, ISC financial executive pleads his guilt in the

ISC $billion fraud and scandal. Anthony Stagq, ISC executive in charge of Singapore

operations, pleads guilty in the Arms Export violations.

238. On November 27, 1987 ISC Executive Larry Resch pleads guilty to his role in the massive

contract fraud in the Ferranti/ISC merger of November, 1987.

239. On December 3, 1991 Philadelphia grand jury hands down a "superseding indictment",

clarifying the money-laundering portion of the charges. The indictment states that

between November of 1986 and June of 1989, Guerin looped $450 million through phony

bank, vendor, -and customer accounts to give the appearance several of the bogus ISC

contracts were real. The preceding information also allows for the possibility of an

indictment of William Clark, and possibly his attorney Joseph Roda. The largest of the fake

contracts was the Pakistan Missile deal, in which Larry Resch was charged and indicted by

the grand jury for managing.

240. On December 3, 1991 Mike Hess, a former ISC engineer that also has done work for The

PLAINTIFF, visits The PLAINTIFF to deliver all materials in his possession which is the

property of the Advanced Media Group, Ltd., The PLAINTIFF and Mike Hess engage in an

argument when Mike Hess becomes annoyed at The PLAINTIFF’s continued caution and

suspicion of Mike Hess's real motives and agenda for the relationship. The PLAINTIFF had


witnessed several incidents of inconsistencies with the attitude of Mike Hess, with specific

respect regarding The PLAINTIFF's efforts for justice and legal recourse concerning the

affairs of 1987. The PLAINTIFF admitted in several occasions that he will never trust

anyone, especially given his former association with ISC, and most importantly his

activities and travel to South Africa.

241. On December 4, 1991 The PLAINTIFF calls the Citizens Commission of Human Rights, after

seeing the organization featured on the Murray Povich Show, and talks to Roy Griffen. The

organization's mission is to investigate abuses within the mental illness profession. Roy

Griffen requests information, and agrees to investigate his allegations. The PLAINTIFF

states that he will Federal Express a copy of this chronology.

242. On December 5, 1991 At approximately 10:00 am, The PLAINTIFF sent a package of

information via Federal Express (tracking number 9734766S93) to: Roy Griffen, Citizens

Commission for Human Rights, 6362 Hollywood Blvd., Los Angeles, CA 90028, (800) 869-

2247. The package was received at 9:56 am (PST) by L. Mezkerlsl, at the front desk.

243. On December 5, 1991 At approximately 4:52 pm, James Guerin pleads guilty to eight (B)

grand jury indictments of October 31. The indictments are as follows: Criminal

Conspiracy, Violation, Arms Export Control Act Violation, Comprehensive Anti-Apartheid

act. Money Laundering, Securities Fraud, Filing False Income Tax Return, Aiding and

Abetting the Commission of crime. Sentencing is scheduled for February 25, 1992, with a

minimum of 14 years, and a maximum of Life in prison.

244. On December 4, 1991The PLAINTIFF receives uninvited visitors at his residence, cousin

Sam Miller family, who in September left him stranded in Florida. They conveniently need

a place to stay, while visiting in Lancaster, and purposely cause distractions to his efforts

for legal recourse.

245. On December 11, 1991 The PLAINTIFF finally requests that Michelle and Jason Miller

vacate his residence.

246. On December 20, 1991 The PLAINTIFF receivers a notice from the Internal Revenue

Service regarding a discrepancy in income reported on his 1989 Federal Income Tax

Return. The items in question were his "disability income" from Monarch life insurance

and American Helix "non-employee income".

247. On December 23, 1991 The PLAINTIFF responds to the IRS letter and submits a copy of

the chronology of this conspiracy, along with the entire audio transcript (2 - 90 minute

cassettes) of his meeting of September 29, 198? with the Pennsylvania Securities

Commission and requests assistance in his ordeal. The correspondence was sent via

'Return Receipt Requested" in order to insure proof of delivery. The PLAINTIFF sends an

updated chronology to Roy Griffen of the Citizen's Commission for Human Rights.

248. On December 28, 1991 The PLAINTIFF sends a formal notice to attorney Howard Cerny,


245 Park Avenue, New York, informing him to return the previously submitted information

and tapes regarding this case, and also informing him that he no longer wishes to discuss

these issues with him or any member of his firm.

249. On December 30, 1991 The PLAINTIFF travels to the U.S. 9:50 am courthouse in

Philadelphia, PA, and personally delivers the chronology and a copy of the "1987"

Pennsylvania Securities Commission meeting to Chief Judge Bechtle, who is presiding over

the ISC court preceding. At 10:00 am The PLAINTIFF visits the U.S. Attorney Generals

office in the same building and files a formal complaint, "Criminal Conspiracy to "cover-up"

the International Signal a Control scandal. The proper form is filed with the clerk.

Assistant U. S. Attorney General Gray asks The PLAINTIFF to briefly describe his

complaint. The PLAINTIFF gives Gray the chronology along with the tapes. The PLAINTIFF

briefly describes the meeting of June 23, 1987 with Larry Resch, the nay 23, 1991 phone

call from Jay Curtis, the arrests by Manheim Township, and the attempts on his life. Agent

Gray took notes, and said he is not familiar with the case, but would personally see that

the information is passed to the proper authorities involved in the case. During the

conversation, Mr. Gray asked the exact same question that was asked by both Joe Roda

and Investigator Eisler of the Pennsylvania Securities Commission) "But you did not work

for them (ISC), you were not involved with them?" The PLAINTIFF gave this response to

all questions by Mr. Gray: It's all in there (the chronology), all of the information and

events".

250. On January 6, 1992 The PLAINTIFF sends a copy of the criminal conspiracy chronology and

a complete audio transcript of the PA SEC meeting of 1987 to the legal counsel of the

Pennsylvania Securities Commission via Certified Mail Return Receipt Requested: P825

695 935.

251. On January 8, 1992 At a "Town Meeting" in Columbia, Pennsylvania held by U. S. Senator

Arlen Specter, The PLAINTIFF personally delivers a copy of the criminal conspiracy

chronology to Anon Specter after the meeting and asks Arlen Specter to read the letter,

Mr. Specter replied, " I will do that".

252. On January 9, 1992 The PLAINTIFF receives the Return Receipt from the Pennsylvania

SEC, signed by Sharon F. Heinspach on January 8, 1992.

253. On November 8, 1997 the PLAINTIFF solicits Attorney Matt Samley, of the law firm of

Xelkallis, Reese and Pugh (Pflumm Contractors Corporate Attorney and David Pflumm’s

Attorney), to provide a legal opinion as to the circumstances involved in the cover up. Mr.

Samley quickly asks if anyone had called Stan Caterbone about the issues. Mr. Samley

agrees to review the documents and will provide a legal opinion of any criminal and

prosecutorial misconduct.

254. On November 23, 1997 - the PLAINTIFF delivers materials to Mr. Samley and also sends


via Federal Express the same materials to Christina Rainville, of Shnader, Harris, Lewis,

and ……. With a letter requesting a legal opinion from Ms. Rainville. Stan Caterbone had

read the biography of Ms. Christina Rainville parts of which were published as part of a

story for the Lisa Michelle Lambert murder trial and was impressed with her experience in

the litigation of securities violations, software and computer cases, entertainment, and of

course the wide array of allegations of prosecutorial misconduct in the Lancaster County

District Attorney’s Office and the East Lampeter Police Department. The PLAINTIFF knew

he needed someone that was not afraid to challenge and take on the “Lancaster

Establishment”.

255. On December, 8, 1997 - Ms. Pam Pflumm call Dr. Albert Shultz regarding the behavior of

the PLAINTIFF.

256. On December 15, 1997 - the PLAINTIFF telephones Jim Christian to again confirm that he

did not have knowledge of his meeting with Mr. Larry Resch. Jim Christian began

threatening the PLAINTIFF from public disclosure of these issues, he said “you have to

forget about it. Your life will be worse off than it is now, you better just forget it……”

257. In December of 1997 The PLAINTIFF had made a journal of all of the mental and

psychological duress that the employees of the firm of Pflumm Contractors, Inc., had

engaged. The PLAINTIFF 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 the PLAINTIFF’S relationships with

all employees involved, including Mr. David Pflumm. Prior to these incidents the

PLAINTIFF was credited with saving the company from near bankruptcy (1993) and

leading the company to the highest level of profitability, marketability, financial stability,

and respect in the 20 year history of the company. Pflumm Contractors, Inc. was

generating over $4 million dollars per year in revenues.

258. On January 14, 1998 The PLAINTIFF visits with Fr. Edward Lavelle for advice and guidance

concerning his situation. the PLAINTIFF only asked that Fr. Lavelle call Mr. David Pflumm,

and ask he and is key employees refrain from inflicting any additional mental duress upon

his person Fr. Lavelle refuses unless he is told to do so by Dr. Al Shulz. He offers no

further assistance. 1:00 pm A few hour later, the PLAINTIFF visits Dr. Al Shulz for his

quarterly appointment. Immediately upon entering the appointment, and before the

plaintiff will speak any words, Dr. Al Shulz will contemporaneously accuse the plaintiff and

declare: “Stan, you are very sick. You are not well! You need to take additional

medications”. The recorded transcript will prove the horrid implications of these

conversations.


259. On February 20, 1998 the PLAINTIFF is forced to vacate his position of Controller of

Pflumm Contractors, Inc., due to the purposeful and intentional infliction of mental duress,

perpetrated as a direct reprisal against the PLAINTIFF’S rightful pursuit of due process of

the law concerning all issues contained herein.

260. On April 21, 1998 The Pennsylvania Department of Labor and Industry will again illegally

deny the Plaintiff of his legitimate claim for Unemployment Compensation Benefits, which

again is an act of reprisal against his rightful pursuit of fair access to the law, and his

disclosures of the incidents contained herein. The Pennsylvania Department of Labor and

Industry’s 1987 rulings against the Plaintiff have been also proven to be in err, which

conveniently and intentionally subjects the Plaintiff to financial hardship and mental

duress, all purposefully hindering the Plaintiff’s right to access the law. The record of the

plaintiff’s claim for Unemployment Compensation Benefits is corrupted.

261. On November 25, 2004, Thanksgiving day, the PLAINTIFF was inside his residence with

the doors locked. At approximately 11:30 am Dave Pflumm, Lizzy Pflumm, and Keagan

Pflumm began knocking on the back patio door. The PLAINTIFF did not want to accept the

visitors and would not answer the door. The visitors had not been at the residence for at

least 4 or 5 months and the PLAINTIFF had not been to the residence of the Pflumm’s

since July of 2002. After the unwanted visitors would not leave, the PLAINTIFF went

downstairs to the back bedroom hoping they would leave. Lizzy Pflumm and Keagan

Pflumm then began banging on the lower daylight door and the front door. The PLAINTIFF

then began lifting weights. After approximately 20 minutes Keagan and Lizzy Pflumm

appeared inside the back bedroom. The PLAINTIFF quickly questioned them how they got

into the residence of the PLAINTIFF. Keagan Pflumm said he used a credit card to open

the back patio door. They both said that their father, Dave Pflumm was upstairs sitting at

the PLAINTIFF’S kitchen bar. They walked upstairs and the PLAINTIFF immediately

questioned Dave Pflumm as to how they broke into the PLAINTIFF’s residence. Dave

Pflumm responded that “I have keys, everyone has keys to your house”. The visitors

stayed for about an hour before leaving. This incident has been reported to the Southern

Regional Police Department and the PLAINTIFF had questioned the Southern Regional

Police Department if the incident was ever investigated. The PLAINTIFF never received a

response.

262. On December 15, 2004 Plaintiff sends a complaint to Agent Sarsfield of the Pennsylvania

Attorney General’s Office in Pittsburg regarding illicit telephone activities. The PLAINTIFF

made complaints and amended the formal Verizon Customer Relations Complaint number

C-006142-2004, which was made pursuant to the Pennsylvania Do Not Call statute. The

complaint alleged that his telephone calls were often being intercepted, misdirected, or

impersonated. The PLAINTIFF also made complaints of harassing calls from “Out of the


Area” caller identification that were occurring several times a day with no response after

answering. The PLAINTIFF has had endured these activities for years.

263. On February 12th, 2005, Pamela Pflumm invited the Plaintiff for dinner after the Plaintiff’s

return from a trip to Florida on the same day. Pamela Pflumm was attending to the

Plaintiff’s cats and mail during his trip to Florida at his residence at 220 Stone Hill Road,

Conestoga, Pennsylvania.

264. On February 12th, after dinner, Pamela Pflumm’s asked the Plaintiff to drive her and a

boyfriend of Abby Pflumm to Kegel’s Restaurant to pick up Abby Pflumm from work. The

boyfriend of Abby Pflumm and Keagan Pflumm entered the rear seats of the Plaintiff’s car

and the boyfriend held a green tennis ball in his hand and aggressively put in the Plaintiff’s

face and said “I found a tennis ball in your back seat”. The Plaintiff drove down the

driveway and Keagan Pflumm and Abby Pflumm’s boyfriend made a comment about the

Plaintiff’s car audio system that was previously vandalized. The Plaintiff became upset,

turned around and told Pamela Pflumm to drive herself to pickup up Abby Pflumm from

work. When the Plaintiff arrived back home at his residence, the green tennis ball that

hangs from the Plaintiff’s garage to align his parking, was suspiciously missing and was

reported stolen that night to the Southern Regional Police Department.

265. On February 17th, 2006, as the Plaintiff drove down Main Street, in Conestoga, while the

Plaintiff noticed a four-wheeler driving in the horse pasture of the Plfumm Property. The

Plaintiff stopped and questioned the unknown persons because it was a school night and

Pamela Pflumm was residing at the residence alone without her husband. No member of

Pflumm family was on the scene at that time. The Plaintiff did immediately vacate the

property as soon as a member of the Pflumm household walked out of the house indicated

that the persons on their property did have permission. A few months previous to these

incidents, Mr. David Pflumm separated from his wife and was not living at the residence.

The Plaintiff was called upon by Pamela Pflumm on several occasions to help her around

the house and property.

266. On February 17, 2005, at approximately 2:20am Officer Fedor of the Southern Regional

Police Department abruptly entered the Plaintiff’s home, awakening the Plaintiff, and

falsely accused the Plaintiff of harassment for driving on the residence of David and

Pamela Pflumm. Pamela Pflumm calls the Plaintiff during the altercation with Officer Fedor

on the Plaintiffs cell phone.

267. Immateriality after the altercation with Officer Fedor, the Plaintiff wrote a letter and sent it

the Chief Fiorill (formerly of the Lancaster City Police Bureau) of the Southern Regional

Police Department.

268. At 1:00 pm on February 17, 2005 the Plaintiff did visit the Lancaster County District

Attorney’s Office and requested to meet with District Attorney Donald Totaro. The Chief of


Detectives, Mr. Michael Landis (Former Chief of the Lancaster City Police Bureau)

conducted a meeting in a conference room where the Plaintiff complained about the

conduct of the Southern Regional Police Department and the harassment of the Officer and

clearly stated that the Plaintiff was preparing a Federal Civil Action (05-2288) and was

concerned about obstruction of justice, anit-slapp, and civil rights violations concerning

Federal Civil Action 05-2288 which was filed a few months later on May 16, 2005 in the

United States District Court for the Eastern Court of Pennsylvania.

269. On February 18,2005 the Plaintiff did meet with the Chief of the Southern Regional Police

Department, Chief Fiorill, at the precinct located at 3284 Main Street, in Conestoga. The

meeting was initiated by request of Chief Fiorill. Officer Robert Busser (formerly of the

Pennsylvania State Police) was outside Chief Fiorill’s office listening to the meeting.

270. At the meeting of February 18th, 2005, Chief Fiorill did libel and slander the Plaintiff by

stating that “I don’t believe anything that you say”, regarding the incidents of the week of

February 17th and the allegations contained in Federal Civil Action 05-2288.

271. At the meeting of February 18th, both Chief Fiorill and Officer Robert Busser did libel and

slander the Plaintiff by stating that the Plaintiff was “nuts” and questioned the Plaintiff’s

mental health. This assault on the Plaintiff’s mental health was done to discredit the

Plaintiff’s allegations in the Federal Civil Action 05-2288.

272. At the meeting of February 18th, Officer Fiorill disclosed that he had called the Plaintiff’s

brother, Mike in Plantation Florida (who has been residing in Florida for the past 18 years),

to discuss the incidents without permission, thus violating the Plaintiff’s civil rights and

privacy rights.

273. At the meeting of February 19th Officer Robert Busser threatened and assaulted the

Plaintiff by taking his nightstick and raising it up in a position to strike the Plaintiff on the

head. Chief Fiorill grabbed Officer Robert Busser’s forearm just in time to stop him from

hitting the Plaintiff.

274. Both Officer Busser and Chief Fiorill demanded the Plaintiff out of the office, thus violating

his civil rights, and placing the Plaintiff in harms way of future threats, harassment, and

numerous criminal activities.

275. On February 18th, 2005, the Plaintiff visited the establishment of the Alley Kat Bar and

Restaurant, located on Lemon Street, Lancaster, Pennsylvania from approximately

10:00pm until 11:30pm. The Plaintiff had a brief conversation with Ms. Kerry Egan

immediately before leaving to proceed directly home.

276. On February 19th, 2005, at approximately 5:00am, Officer Fedor pounded on the Plaintiff’s

front door to awaken him. The Plaintiff refused to open the door and let the Officer in due

to the preceding incidents and went into his bathroom and called the Pennsylvania State

Police. The Pennsylvania State Police refused to answer the plea for help to intervene in


the altercations with the Southern Regional Police Department.

277. Approximately 20 minutes later, Officer Fedor and Pamela Pflumm illegally entered into the

residence of the Plaintiff by breaking and entering.

278. Officer Fedor stated he was responding to a 911 call about an attempted suicide. The

Plaintiff tried to tell Officer Fedor that he did not know what he was talking about. Officer

Fedor handcuffed the Plaintiff and was physically abusive by pushing and shoving the

Plaintiff directly in front of the Plaintiff’s loveseat and handcuffing the Plaintiff. Officer

Fedor asked him why he sent an email to Kerry Egan threatening to commit suicide.

Pamela Pflumm was standing in front of the Plaintiff’s back door. The Plaintiff kept trying

to tell Officer Fedor that he came home and was sleeping all night. The Plaintiff and

Officer Fedor kept arguing about an incident that never occurred. Officer Fedor violated

several civil rights of the Plaintiff.

279. Officer Fedor stated the Kerry Egan made a call to 911 at approximately 4:00 am and

stated that she received an email from the Plaintiff early that morning with a threat to

commit suicide. The Plaintiff called Comcast cable during the altercation to try to get an

activity list of the Plaintiff’s online activities to prove that the Plaintiff did not send any

email to Kerry Egan. Officer Fedor slandered and libeled the Plaintiff by not believing his

account. The Plaintiff kept asking why Pamela Pflumm was summoned to the Plaintiff’s

home and received no explanation. The Plaintiff did not see Pamela Pflumm before that

she entered the residence with Officer Fedor.

280. It was later determined that there never was an email, and the Southern Regional Police

Department never withdrew their allegations of mental health issues.

281. On April 5, 2006 Officer Buzzer did knowingly and willing falsely imprison Plaintiff and

maliciously attack plaintiff and accompanied several police officers in theft of a white

envelope containing approximately $743.00 in cash in a police chase from the Conestoga

Wagon Wheel Restaurant in Conestoga to Duke Street in Millersville, Pennsylvania, via

Kendig Road.

282. On April 5th, 2006, Officer Fedor did make false statements to authorities in the 302

petitions to Lancaster General Hospital and to Crisis Intervention of Lancaster,

Pennsylvania with regards to the incarceration of the Plaintiff in the Psychiatric ward from

the period of April 5th to April 10th, 2006.

283. On April 5th, 2006, Officer Busser did harass, threaten, and physically abuse the Plaintiff

in the apprehension that took place on South Duke Street, Millersville, Pennsylvania and

did knowingly draw his weapon upon the Plaintiff without any threat, merely to incite

public attention to the Plaintiff that defamed his character, and slandered his name.

284. All of the preceding acts of retaliation by the Southern Regional Police Department were a

direct result of undo influence upon the Plaintiff and his attempts to remedy causes of


action that have been disclosed in the Federal Civil Action 05-2288, and the Federal False

Claims Act filed in the United States District Court for the Eastern Court of Pennsylvania.

285. On April 5th, 2006, Defendants did falsely imprison Defendant at Approximately 3:15 EST

at the emergency intake unit of the Lancaster General Hospital, Duke Street, Lancaster

County, Pennsylvania.

286. On April 5th, 2006, upon request, staff of the Lancaster General Hospital failed to produce

any official documentation to support the apprehension of the Plaintiff or the holding of the

Plaintiff in said facility.

287. The Defendants did open locking cell and plaintiff again asked for documentation, plaintiff

walked out of the holding cell, and not documentation was produced, agent for defendant

picked plaintiff up and literally threw plaintiff back into holding cell.

288. Between 3:30pm and 7:15pm Dr. Riley examined plaintiff by asking the following

questions:

a. Do you drink alcohol?

b. Do you take drugs?

c. May I listen to your heart and drugs?

The preceding examination took under 2 minutes and was not near sufficient for the

requirements as outlined in the 302 petition, whether legal or not.

289. Mental Duress: Agents, employees, and staff of the Lancaster General Hospital did engage

in planned and occasional events to inflict, cause, and provoke extreme mental duress.

290. Agents, employees, and staff did obstruct justice and cause plaintiff to suspend, neglect,

and or cease all activities relating to CA 05-0288 and TMT 05-23059 in an overt attempt to

interfere with Plaintiffs constitutional right to due process.

291. Agents, employees, and or staff did subject Plaintiff to a life threatening environment when

patient William X was intentionally given a ball point pen immediately after Angela X

administered a drug, and William X stood 1 foot away from Plaintiff and held ball point pen

as a knife. Plaintiff had to immediately remove himself from the immediate area.

292. Agents, employees, and or staff subjected Plaintiff to further harm by condoning and

further provoking situation. As of April l0th, 2006, Plaintiff is still falsely imprisoned.

293. Agents, employees, and or staff did take from Plaintiff’s possession a white bank envelope

containing Seven Hundred and Forty-Three dollars ($730.00), which was not included in

Plaintiff’s Possession Form.

294. On July 23rd, 2006 PLAINTIFF speaks with Governor Ed Rendell at a Campaign Speech at

Binns Park, in Downtown Lancaster, and requests his assistance in his Civil Rights

Obstruction of Justice Complaint filed a few weeks earlier in the Office of Attorney General.


295. On October 14th, 2006 PLAINTIFF files a RICO complaint in the United States District Court

against Shawn Long, attorney for Fulton Bank, MDJ Leo Eckert, Commins, Simms, Case

No. 4650.

296. On October 17th, 2006 PLAINTIFF attends a Bail Supervision (of the Lancaster County

Sheriff’s Department) Intake meeting at the Bail Administrators Office in the Lancaster

County Courthouse. PLAINTIFF serves the Lancaster County Sheriff’s Department, the

Lancaster County District Attorney’s Office, and the Lancaster County Public Defenders

Office Civil Actions. The Lancaster County Public Defenders Office literally took the

Certificate of Service signing sheet from PLAINTIFF and PLAINTIFF immediately told Judge

Joseph Madenspacher about the incident while he walked to the Bus Terminal to go the

Office of MDJ Commins. The document was never returned even after several emails to

the contrary by the Public Defender, Mr. Karl.

297. On October 20th, 2006 PLAINTIFF files a Federal False Claims Act for Whistle-Blowing

against ISC in the United States District Court For The Eastern District of Pennsylvania,

Case No. 06-4734.

298. On October 26th, 2006 The Pennsylvania Superior Court received a Brief for the Appeal

Challenging the Fulton Bank Judgment of June 29, 2006.

299. October 30th, 2006 The Pennsylvania Superior Court sends a letter to PLAINTIFF

requesting (7) more copies of the brief, which PLAINTIFF will not receive until January 4th,

2007. An amended complaint to PLAINTIFF’s Southern Regional Police Department Civil

Action, Case No. 06-3401, is due in the Court of Common Pleas of Lancaster County on

exactly this date. An Unsecured Bail Bond was revoked by Officer Adam Cramer of the

Southern Regional Police Department and (2) Bench Warrants were issued for the Arrest

of PLAINTIFF by Adam Cramer of the Southern Regional Police Department and MDJ Leo

Eckert, Jr.. PLAINTIFF filed the Amended Complaint and mailed it from the Bausman Post

Office Substation, and did not go to the Lancaster County Courthouse in fear it would not

get filed. At 2:20pm (2) PA Constable arrest and apprehend the PLAINTIFF at 1250

Fremont Street, Lancaster, PA, and take him to Magisterial District Justice Eckert’s Office

on the (5) Bench warrants for summary citations and then COMMITT The PLAINTIFF to the

Lancaster County Prison, stating that an Indigent Hearing will be held within 10 days, and

challenges the PLAINTIFF’S Indigent status and his Superior Court Cases. Magisterial

District Justice Eckert complains to the PLAINTIFF about being named a Defendant in

Federal Case No. 06-4650, and remarks that the PLAINTIFF may have to be taken to

Dauphin County Prison for suing all of the District Justices in Lancaster County. He also

said “You are not even close to getting to the Superior Court”.

300. On November 1st, 2006 PLAINTIFF appears before Judge Paul K. Allison who reinstates his

Bail Bond as Secured, which required PLAINTIFF to post $5,000 to get out of the Lancaster


County Prison instead of just signing an Unsecured Bail Bond, which should have

happened, and is not released from the Lancaster County Prison, as expected.

301. On November 6th, 2006 PLAINTIFF files his first Appeal for Reconsideration to the ORDER

of Judge Paul K. Allison to Reinstate the Bail Bond as Unsecured, and Release him from

Lancaster County Prison.

November 20th, 2006 The United States District Court for the Eastern District of

Pennsylvania records 28 U. S. C. §2241 Habeas Corpus Petition Case No. 06-5138

(Challenging the Detainer and Imprisonment) filed from the Lancaster County Prison on

November 14th, 2006. This case is still

302. On November 30th, 2006 Judge Paul K. Allison Denies PLAINTIFF’s Appeal to Reinstate Bail

as Unsecured.

303. On November 8th, 2006 PLAINTIFF is transported to Magisterial District Justice Leo H.

Eckert, Jr., and signs a document that was missed on October 30th, 2006, and is not given

an Indigent Hearing as promised.

304. On December 2nd, 2006 PLAINTIFF files an Appeal to Judge Paul K. Allison ORDER of

November 30th, 2006.

305. On December 4th, 2006 the Lancaster County Sheriff’s Department is ORDERED to

transport PLAINTIFF to both residences, 1250 Fremont Street, and 220 Stone Hill Road to

obtain files and evidence for a Trial, as a Pro Se Litigant and representing himself on the

East Lampeter Township summary citations. There were no Sheriff Sale Posting on 220

Stone Hill Road, and both residences look fine.

306. On December 5th, 2006 The Lancaster Intelligencer Journal publishes the Story “The Next

Sound You Hear…” regarding former business partner Tony Bongiovi, which is central to all

of the litigation in the United States District Courts. The worlds of pro audio and consumer

electronics were bridged at New York City's Avatar Studios in December, where Bongiovi

Acoustics unveiled the Digital Power Station car radio. Demonstrated by audio icon Tony

Bongiovi (pictured) in Avatar’s Studio A (former Power Station Studios), the patent-

pending technology being manufactured by JVC made a very impressive debut.

307. On December 6th, 2006 Honda Financial repossess a Honda Odyssey stored at the St.

Dennis Towing Company’s facility from August 31, 2006; the Honda was take because of

the illegal repossession of the drivers license and there were no funds available for the tow

that was just a few blocks away. The Honda was protected under the pending Chapter 11

Bankruptcy Petition and was conveniently taken while incarcerated. The PLAINTIFF had

talked to Honda Financial in August and there was no problem with the lease, even though

the PLAINTIFF had not made a payment since May of 2005. The St. Dennis Towing

Company was charging $25.00 per day, and has never filed or sent the PLAINTIFF an

invoice for the storage, which is very suspect.


308. On December 8th, 2006 PLAINTIFF files a Writ of Mandamus against Magisterial District

Justice Leo H. Eckert, Jr, and Mary Commins for the fraudulent activities leading to the

false imprisonment of October 30th, 2006, and Bench Warrants.

309. On December 12th, 2006 PLAINTIFF files for Continuances in all of the following Civil

Complaints in the Commonwealth Court of Common Pleas of Lancaster County,

Pennsylvania: CI-06-07330; CI-06-08742; CI-06-08490; CI-06-07376; CI-06-07188; CI-

06-06658; CI-06-04939; CI-06-03403; CI-06-03401; CI-06-03349.

310. On December 13th, 2006 The Lancaster County Sheriff’s Department (Maluskus) and Chief

John Fiorill tried to get PLAINTIFF to change his address to the Lancaster County Prison

and Judge Perezous refused to get ORDER PLAINTIFF to comply with the demand and

Judge Perezous CONTINUED the Appeal Hearing because PLAINTIFF did not have any files

to conduct a Trial.

311. On December 20th, 2006 The Lancaster County Sheriff’s Department (Hiem & N/A-names

given by Sheriff Simone) refused PLAINTIFF to wear his suit into the courtroom, or take

his files into the Pre-Trial Conference before Judge Farina, which caused PLAINTIFF to

forget to discuss material motions for the Trial, and caused the PLAINTIFF to be defamed

by appearing in a Lancaster County Prison uniform before the Court and in front of 20 or

so other people in the Courtroom.

312. On December 20th, 2006, while in the Lancaster County Prison, the Lancaster County

Sheriff’s Department and Fulton Bank conduct a Sheriff Sale for 220 Stone Hill Road,

Foreclosure CI-06-02271, with NO notification before or after the SALE to PLAINTIFF; and

sold the property to Central Penn Settlement Company of Akron, Pennsylvania.

313. On December 28th, 2006 Judge Paul K. Allison overturned his previous ORDER and Granted

PLAINTIFF his Appeal ORDER and signed the Unsecured Bail ORDER and the RELEASE from

Lancaster County Prison.

314. On December 29th, 2006 PLAINTIFF is RELEASED from Lancaster County Prison, and walks

to the Lancaster County Courthouse to report to Court Administration and the

Prothonotary Office to get a print out of all of the Civil Dockets for all cases in Civil Court,

including the Fulton Bank Foreclosure and finds out for the first time that the Sheriff Sale

on December 20th took place. PLAINTIFF retrieves a check for $19.34 from Attillio Grossi,

which is all the funds has available for food, and all other necessities.

315. On January 2, 2007 PLAINTIFF files and records (4:09pm) a Petition To Set Aside Sale for

220 Stone Hill Road, Conestoga in the Pennsylvania Court of Common Pleas of Lancaster

County and personally serves Fulton Bank and the Lancaster County Sheriff’s Department.

316. January 4th, 2007 At 1:15pm PLAINTIFF visits 220 Stone Hill Road and finds 2 unidentified

individuals on his property loading the entire contents of 220 Stone Hill Road onto 2

Penske moving trucks, to an unidentified location, and is ordered off the Property for


Trespassing. The 2 individuals said they were from Noble Real Estate Company. Mr.

Joseph Caterbone accompanied him as a witness and driver. PLAINTIFF takes several

pictures of the individuals and the Penske Trucks. At 1:35pm PLAINTIFF retrieves his mail

from the Conestoga Post Office from dating back to October 25th, 2006 up to the present

and temporarily forwards mail to 1250 Fremont Street, Lancaster, PA. PLAINTIFF visits the

Lancaster County Sheriff’s Office and speaks to Lt. Lancaster and Mr. Bergman about the

incident at 220 Stone Hill Road and is told that Southern Regional Police have already

responded, and would not give any information about the incident. At 3:00pm PLAINTIFF

attends the Trial for Criminal Case No. CP-36-CR-0003179-2006 (Fleeing & Eluding filed by

Sgt. Busser of Southern Regional Police Department on April 5th, 2006) in Courtroom 1 of

the Lancaster County Courthouse and moves for a Motion for a Continuance due to the

incident at the property at 220 Stone Hill Road an hour before. The Honorable Judge

James P. Cullen Denies his Motion.

317. On January 5th, 2007 At 8:30am PLAINTIFF files and records an Addendum to the Petition

To Set Aside Sale for 220 Stone Hill Road, Conestoga in the Pennsylvania Court of

Common Pleas of Lancaster County and personally serves Fulton Bank and the Lancaster

County Sheriff’s Department regarding the theft of all of his personal possessions,

including business files of Advanced Media Group, and all Legal files and evidentiary assets

for all pending litigation. At 9:00 am the Lancaster County District Attorney Deborah

Muzereus moves for A Continuance in the Trial for Criminal Case No. CP-36-CR-0003179-

2006 and the Honorable James P. Cullen Grants a Continuance until the February Trial

Schedule.

318. On January 7th , 2007 PLAINTIFF files a claim with Harleysville Insurance Homeowners

Policy HOAI 93468 for the theft of his personal possessions and the property at Stone Hill

Road. PLAINTIFF files for a Change of Venue for the Hearing scheduled for January 18th,

2007 in Intercourse before Magisterial District Justice Leo H. Eckert, Jr.. PLAINTIFF does

not have all of his evidentiary files and no transportation because of the illegal revocation

of his Red Rose Transit Authority Monthly Bus Pass.

319. On January 8th, 2007 PLAINTIFF files an Emergency Petition for Food Stamps and other in

the Pennsylvania Court of Common Pleas of Lancaster after his Food Stamps and Red Rose

Transit Authority Monthly Pass was illegally terminated, thus leaving him without food and

transportation for all court preceding. PLAINTIFF files for a Continuance for Summary

charges by District Justice Leo H. Eckert Jr., a Defendant in U.S. District Civil Action 06-

4650, scheduled for January 18th, 2007., again for not having access to all of his

evidentiary files and without transportation. PLAINTIFF files and sends his Brief to the

Superior Court of Pennsylvania Case No. 1463 MDA 2006 for the challenge to Fulton

Bank’s 220 Stone Hill Road Foreclosure, via U.S. Postal Priority Mail Return Receipt No.


0306 2400 003 1072 4451; the request stated: “Other - We need 7 copies of this brief,

also all copies need to be bound on the left like a book and if you use staples they must be

covered with tape”. PLAINTIFF borrows $50.00 from Joseph Caterbone for food, paper,

and postage for the Superior Court Brief.

320. On January 9th, 2007 PLAINTIFF files for Continuance in all of his pending Civil Actions

before the United States District Courts for the Eastern District of Pennsylvania; 05-2288;

06-4650; 06-5138; 06-4734; 06-CV-4154; 06-5117; 06-2236; 05-23059BKY. PLAINTIFF

files for a Change of Venue and Continuance for Summary Citations (TR-0008735-2006;

TR-0008578-2006; TR-0008721-2006; TR-0008503-2006; TR-0007528-2006) Scheduled

for a Hearing on January 23, 2007 before District Magistrate Richard H. Simms, a

Defendant in U.S. District Civil Action 06-4650. PLAINTIFF receives a Notice to Change the

Hearing Scheduled for January 18th, 2007 from Magisterial District Justice Leo H. Eckert,

Jr. to Isaac Stoltzfus of Intercourse. PLAINTIFF Petitions the Pennsylvania Court of

Common Pleas of Lancaster County to vacate the Bail Supervision Ordered by Magisterial

District Justice Mary Commins on October 10th, 2006. The Bail Supervision was without

merit or cause.

321. January 10th, 2007 PLAINTIFF reports a theft of the Digital Recorder used containing an

authentic and original audio recording of the incident for the Case No. CP-36-CR-0003179-

2006 (Fleeing & Eluding filed by Sgt. Busser of Southern Regional Police Department on

April 5th, 2006) to Officer Cole of the Lancaster City Police Department who responded at

approximately 10:25pm to 1250 Fremont Street and filed the incident as Case No. 0701-

014878.

322. January 11th, 2007 The Honorable Judge James P. Cullen Orders PLAINTIFF’s Petition to

vacate the Bail Supervision as Denied Case No. 4771-2006. PLAINTIFF writes the

following in an email to the Red Rose Transit Authority: “I am having a problem with my

monthly passes. I have not received my January Monthly Pass, and my forwarded mail

has not been received from 220 Stone Hill Road, Conestoga. Today, your driver Dave on

the 3 8th Ward/Park City 8:35 bus made me pay him for the fare. Some drivers let me on

with my December Pass and my Letter of Acceptance from September of 2006. I never

received a termination letter, and on January 5th, filed an Emergency Petition against the

Lancaster County Assistance Office to have all benefits that have been terminated,

reinstated. What is the status of my Monthly Pass? Below is an excerpt from the Civil

Action, Case No. CI-07-00150 in the Court of Common Pleas of Lancaster County,

Pennsylvania. The Petitioner has not received his January Red Rose Transit Authority

January Monthly Bus Pass, sponsored by the RRTA and the Lancaster County Assistance

Office. The Petitioner did receive his December Monthly Bus Pass, and complained to the

Red Rose Transit Authority Terminal Station on Queen Street, Lancaster, Pennsylvania, on


January 5th,2007. The staff worker told the Petitioner that his Monthly Pass was “deleted”

because he was incarcerated. The Petitioner explained that the Red Rose Transit Authority

Monthly Bus Pass was issued for a (2) year period. The incarceration was not valid and I

was released upon the Success of my Appeal, which was signed by the Honorable Judge

Paul K. Allison on December 28th, 2007.” The PLAINTIFF, in the Pre-Trial Conference

moves for a Continuance for 0004771-2006 before Judge Ashworth and it is GRANTED.

323. January 12th, 2007 PLAINTIFF receives the following email from Ms. Gail Parenteau, of

Bongiovi Acoustics: “What is Advanced Media Group? It is our policy not to open

unsolicited attachments. What's your tel. no. I've been with Tony since 1986 and neither

of us remembers what this is. I've highlighted your type-os in red below”. PLAINTIFF

responds with the following email to Ms. Gail Parenteau: “I (Financial Management Group,

Ltd.,) was at Power Station from February until July in 1987 working extensively with

Tony, Ellen, and all of the Producers from Flatbush Films in Hollywood. Tony named me

Executive Producer of the project, and that is in the budgets. Now, are you really

associated with Tony, or are you covering for someone? I have still photos, audio recorded

meetings with Bob Walters (Co-Owner of Power Station Studios), business plans for

"Mutant Mania", Tony's Digital Movie, with budgets, screenplays, joint venture

agreements, Patent and Copyright materials for Power Station Studios and Tony. I also

have documents for the Pier in Wildwood, which Tony owned. I personally authored many

of these materials with Tony, at his request. I spent many days and nights working at

Power Station on this project. I had a Navajo Chieftain twin turbo prop that I flew to Power

Station for some of my meetings, the other times me and Scott Robertson drove. I even

have another management consulting proposal that I developed for Tony in 1989, when he

wanted me to restructure Power Station from top to bottom. If, you were not privy to

these projects, then maybe you should at least talk to Tony. I was just providing a

professional courtesy to Tony, especially, since I have admitted many documents

pertaining to my claims in the United States District Court for the Eastern District of

Pennsylvania. Tony is not a Defendant in my claims. I have authored a Joint Venture

Proposal for Sony, which details the Power Station Digital Music System, and I have

noticed what Tony is doing. I will not call, for security reasons, I cannot tell who is on the

other end. You can have a legal representative or Tony forward correspondence to:

PLAINTIFF, 1250 Fremont Street, Lancaster, PA 17603”.

324. January 13th, 2007 PLAINTIFF visits the Red Rose Transit Authority Terminal at Queen

Street again attempting to get his January Monthly Bus Pass, which he thinks is missing in

the mail. PLAINTIFF borrows $20.00 from Richard Hobday, for food, postage, and paper;

and ride home from the Lancaster County Courthouse. PLAINTIFF receives a letter and a

Distribution Schedule from the Lancaster County Sheriff’s Office that states: “On


December 20,2007 your property located at 220 Stone Hill Rd. was sold at Sheriff Sale to

a third party buyer, Central Penn Property Services, Inc. for $156,000.00. Attached, you

will find a Schedule of Distribution, which we are required to do. On this schedule you will

see that there is a balance of proceeds to be paid to you, Stanley J. Caterbone. You, the

defendant, will receive this balance of $17,306.80, however, you have served Sheriff

Bergman with a petition to set aside the sale (PARCP 3132). Please note that we, the

Sheriffs Office, do not have a dated and signed copy by the court of your petition. At the

advice of our solicitor, the distribution of any payouts regarding this property will not be

made until the matter is resolved.” Fulton Bank and the Lancaster County Sheriff’s

Department embezzle over $50,000 in Fees, Costs, and the Distribution of Sale associated

with the Sale Proceeds of 220 Stone Hill Road, Conestoga, PA. The Praecipe-Writ of

Execution filed on July 31sth, 2006 by Fulton Bank for Foreclosure Case No. CI-06-02271

stated: “FILED. WRIT ISSUED. AFFIDAVIT OF NON-MILITARY SERVICE. PRINCIPAL:

$88,568.53; INTEREST TO 03/02/2006 AT A RATE OF $14.56 PER DIEM: $4,442.96;

NEGATIVE ESCROW BALANCE: $1,096.38; LATE CHARGES: $317.20; ATTORNEYS' FEES:

$3,000.00; TOTAL: $97,425.07. FILED BY SHAWN M. LONG, ESQ”. PLAINTIFF receives a

letter from the Superior Court of Pennsylvania regarding the Fulton Bank Foreclosure

Challenge, notifying him that “AND NOW, this fourth day of January, 2007 the appeal in

this matter is DISMISSED for failure to file a brief.” This DISMISSAL is highly suspect

considering that the Superior Court placed no time conditions on receiving the additional

(7) Copies and it was received several days AFTER PLAINTIFF had already mailed the

required (7) Copies and fulfilled the obligations to the Superior Court, thus furthering the

fact that Fulton Bank and the Sheriff’s Office of Lancaster County held an illegal sale on

December 20th, 2006. PLAINTIFF receives DENIED on an ORDER from Change of Venue

and Continuance for the Hearings for January 18th, 2007, signed by Judge Dennis

Reinaker of the Pennsylvania Court of Common Pleas of Lancaster County, Pennsylvania.


325. Fulton Bank – Tommy, 1991 Check Error

2005 – Fulton Bank Project Hope Freeze Account, Gift Certificate, false arrests, Scouts Trail Count

IV - extortion, Slander, Libel

2006 – False Arrests, Comcast Cable, 4650, False Imprisonment, Civil Rights Complaint,

2007 – Computer Hacking, Lancaster City Police, Human Relations Complaint, Judge Cullen

Date: October 15, 2007 Stanley J. Caterbone, Pro Se Litigant



CERTIFICATE OF SERVICE – WILL SERVICE ALL DEFENDANTS WITHIN 120 DAYS.

I hereby certify that a true and correct copy of the Amended Complaint has been served

this 14th day of October 2007, by first class mail, Postage prepaid, or by electronic mail upon, or

by hand deliver to:

United States District Court for the Eastern District of Pennsylvania Clerk of Court 600 Market Street, Room Philadelphia, PA 19106 Stuart A. Weiss, Esquire 817 East Landis Avenue Vineland, NJ 08360 George M. Gowen, 111, Esquire Cozen O'Connor 1900 Market Street Philadelphia, PA 1 9103 Howard L. Kelin, Esquire Kegel, Kelin, Almy & Grimm 24 North Lime Street Lancaster, PA 17602 Hartman, Underhill & Brubaker, LLC 221 East Chestnut Street Lancaster, PA 17602 Stephanie Carfley, Esquire Attorneys For Defendant Fulton Bank 126 East King Street Lancaster, Pa 17602-2893 Robert W. Hallinger Appel & Yost LLP 33 North Duke St Lancaster, Pa 17602

______________________________ Date: October 14, 2007 Stanley J. Caterbone, Pro Se Litigant



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judge mary mclaughlin 05-2288 amendment to complaint october 15 2007 important

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