Recorded - 15-03984 Habeus Case DECLARATION Re Findings of Facts 1998 - Original Claim Filed in United States Eastern District of Pennaylvania in Case No. 05-2288 on May 16, 2005

8/16/2019 Recorded - 15-03984 Habeus Case DECLARATION Re Findings of Facts 1998 - Original Claim Filed in United States …

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Plaintiff’s Findings Of Facts Page 1 of 76

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF

PENNSYLVANIA

STANLEY J. CATERBONE, :

County of Lancaster, Pennsylvania :

: V. :

:

COMMONWEALTH OF PENNSYLVANIA, :

ATTORNEY GENERALof PENNSYLVANIA :

PENNSYLVANIA SECURITIES COMMISSION :

PENNSYLVANIA DEPARTMENT OF LABOR & INDUSTRY :

DISTRICT ATTORNEY of LANCASTER COUNTY :

COUNTY OF LANCASTER, PENNSYLVANIA :

LANCASTER COUNTY PRISON :

COUNTY OF LANCASTER, PENNSYLVANIA :MANHIEM TOWNSHIP POLICE DEPARTMENT, : CIVIL ACTION


STEINMAN ENTERPRISES, INC., OF :


STONE HARBOR POLICE DEPARTMENT, :

COUNTY OF CAPE MAY , NEW JERSEY :

AVALON POLICE DEPARTMENT, :

COUNTY OF CAPE MAY, NEW JERSEY :

COMMONWEALTH NATIONAL BANK : NO.

(i.e. MELLON BANK) :COUNTY OF DAUPHIN, PENNSYLVANIA :

AFFIDAVIT OF STANLEY J. CATERBONE

STATE OF PENNSYLVANIA :

:

COUNTY OF LANCASTER : ss

I, Stanley J. Caterbone being duly sworn according to law, make the following affidavit concerning the

years during which I was maliciously and purposefully mentally abused, subjected to a massive array of

prosecutorial misconduct, while enduring an exhaustive fight for the sovereignty of my constitutional rights,

shareholder rights, civil liberties, and right of due access to the law. I will detail a deliberate attempt on my

life, in 1991, exhibiting the dire consequences of this complaint.. These allegations are substantiated

Case 5:15-cv-03984-JCJ Document 58 Filed 05/31/16 Page 1 of 76

05-2288

May 16, 2005, Filed and Recorded In Person at Clerk of Courts in Federal Courthouse, Philadelphia, Pennsylvania


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through a preponderance of evidence including but not limited to over 10,000 documents, over 50 hours of

recorded conversations, transcripts, and archived on several digital mediums. A “Findings of Facts” is

attached herewith providing merits and the facts pertaining to this affidavit. These issues and incidents

identified herein have attempted to conceal my disclosures of International Signal & Control, Pls.,.

However, the merits of the violations contained in this affidavit will be proven incidental to the existence of

any conspiracy.

The plaintiff protests the courts for all remedial actions mandated by law. Financial considerations would

exceed $1 million.

These violations began on June 23, 1987 while I was a resident and business owner in Lancaster County,

Pennsylvania., and have continued to the present. These issues are a direct consequence of my public

disclosure of fraud within International Signal & Control, Plc., of County of Lancaster, Pennsylvania, which

were in compliance with federal and state statutes governing my shareholder rights granted in 1983, when

I purchased my interests in International Signal & Control., Plc.. I will also prove intentional undoinfluence

against family and friends towards compromising the credibility of myself, with malicious and self servingaccusations of “insanity”. I conclude that the courts must provide me with fair access to the law, and most

certainly, the process must void any technical deficiencies found in this filing as being material to the

conclusions. Such arrogance by the Courts would only challenge the judicial integrity of our Constitution.

1. The activities contained herein may raise the argument of fair disclosure regarding the scope of law

pertaining to issues and activities compromising the National Security of the United States. The Plaintiff

will successfully argue that due to the criminal record of International Signal & Control, including the

illegal transfer of arms and technologies to an end user Iraq, the laws of disclosure must be forfeited by

virtue that “said activities posed a direct compromise to the National Security of the United States”.; the

plaintiff will argue that his public allegations of misconduct within the operations of International Signal &Control, Plc., as early as June of 1987 ; demonstrated actions were proven to protect the National

Security of the United States.. The activities of International Signal & Control, Pls., placed

American troops in harms way. The plaintiff’s actions should have taken the American troops out of

harms way causing the activities of the International Signal & Control, Plc., to cease and desist. .

All activities contained herein have greatly compromised the National Security of the United States, and

the laws of jurist prudence must apply towards the Plaintiff’s intent and motive of protecting the rights of

his fellow citizens. Had the plaintiff been protected under the law, and subsequently had the law

enforcement community of the Commonwealth of Pennsylvania, and the County of Lancaster administer

justice, United States troops may have been taken out of harms way, as a direct result of ceasing theoperations of International Signal & Control, Plc., in as early as 1987.

2. The plaintiff will successfully prove that the following activities and the prosecutorial misconduct were

directed at intimidating the plaintiff from continuing his public disclosures regarding illegal activities within

International Signal & Control, Plc,. On June 23, 1998, International Signal & Control, Plc was

negotiating for the $ billion merger with Ferranti International, of England. Such disclosures threatened

the integrity of International Signal & Control’s organization, and Mr. James Guerin himself, ,

consequently resulting in adverse financial considerations to all parties if such disclosures provided any



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reason to question the integrity of the transaction, which later became the central criminal activity in the in

The United States District Court For The Eastern District Of Pennsylvania

3. The plaintiff will prove that undoinfluence was also responsible for the adverse consequences and

fabricated demise of his business enterprises and personal holdings. The dire consequences of the

plaintiff’s failed business dealings, will demonstrate and substantiate financial incentive and motive.Defendants responsible for administering undoinfluence and interference in the plaintiff’s business and

commercial enterprises had financial interests. The Commonwealth of Pennsylvania as a taxing

authority, Lancaster County had a great investment who’s demise would facilitate grave consequences

to it’s economic development. . Commonwealth National Bank (Mellon) would have less competition in

the mortgage banking business and other financial services, violating the lender liability laws. The

Steinman Enterprise’s, Inc., would loose a pioneer in the information technologies industries, and would

protect the public domain from truthful disclosure. The plaintiff will also provide significant evidence of

said perpetrators violating common laws governing intellectual property rights.

4. Given the plaintiff’s continued and obstructed right to due process of the law, beginning in June of 1987and continuing to the present, the plaintiff must be given fair access to the law with the opportunity for

any and all remedial actions required under the federal and state statutes. The plaintiff will successfully

argue his rights to the courts to rightfully claim civil actions with regards to the totality of these activities,

so described in the following “Findings of Facts”, regardless of any statute of limitations. Given the

plaintiff’s genuine efforts for due process have been inherently and maliciously obstructed, the courts

must provide the opportunity for any and all remedial actions deserving to the plaintiff .

5. Under current laws, The plaintiff’s intellectual capacity has been exploited as means of discrediting the

plaintiff’s disclosures and obstructing the plaintiff’s right to due process of the law. The plaintiff has

always had the proper rights under federal and state laws to enter into contract. The logic and reasontowards the plaintiff’s activities and actions are a matter of record, demonstrated in the “Findings of

Facts”, contained herein..

The plaintiff will argue and successfully prove that the inherent emotional consequences to all of the

activities contained herein, have resulted in Post Traumatic Stress Syndrome. The evidence of the stress

subjected to the plaintiff , will prove to be the direct result of the activities contained herein, rather than

the exhibited behavior of any mental deficiency the plaintiff may or may not have. The courts must

provide for the proper interpretations of all laws, irrespective of the plaintiff’s alleged intellectual

capacity. The plaintiff successfully argue that his “mental capacity” is of very little legal consequence, if

any; other than in it’s malicious representations used to diminish the credibility of the plaintiff .

6. The plaintiff will demonstrate that the following incidents of illegal prosecutions were purposefully

directed at intimidating the plaintiff from further public disclosure into the activities of International

Signal & Control, Plc., consequently obstructing the plaintiff’s access to due process of the law. Due

to the fact that these activities to which the plaintiff’s perpetrators were protecting were illegal activities,

the RICO statutes would apply.

To this day, the plaintiff has never been convicted of any crime with the exception of 2 speeding



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tickets. The following report identifies 34 instances of prosecutorial misconduct during the prosecutions

and activities beginning on June 23, 1987 and continuing to today.

7) Given the preponderance of evidence associated with this affidavit, the courts must conclude that In The

United States District Court For The Eastern District of Pennsylvania, Federal Judge Stuart Dalzall’s

findings of April 14, 1997, in the Lisa Lambert case identifying acts of Prosecutorial Misconduct, now, by virtue of this affidavit, now discloses evidence of a bona fide pattern of prosecutorial misconduct, in

the Commonwealth of Pennsylvania and in the County of Lancaster. Criminal law must now determine if

these disclosures would warrant investigations of a possible criminal enterprise. This affidavit is of

material interest to the Lambert case, for the very fact that this affidavit compromises the very same

integrity of the court, which would tip the scales of justice even further from the peoples deserving rights..

In the truthfulness of this affidavit, The Commonwealth must concede Lisa Michelle Lambert to balance

the scales of justice, which no other act could accomplish. The Commonwealth must yield the criminal

culpability of Lisa Michelle Lambert to the superior matter of restoring the integrity to the courts; by it’s

own admission of wrongdoing, assuring the peoples of it’s commitment to administer equalities of justice,not inequalities of justice. Balancing the scales of justice. Anything less, would take the full scope of

jurisdiction out of the boundaries of our laws, negating our democracy and impugning the Constitution

of the United States.. The plaintiff must be restored to whole to so that justice may be restored to the

Commonwealth of Pennsylvania and to the County of Lancaster.

A. August 11, 1987 Stone Harbor (New Jersey) Police Department (2) - The plaintiff had been literally chased

by family members when the plaintiff wanted to obtain a restraining order to keep his family members from

obstructing his access to the law, and invading his home. The Stone Harbor Police Department detained the

plaintiff against his will, and later transported the plaintiff to Burdette Tomlin Hospital, giving no explanationto the plaintiff . The Burdette Tomlin later disclosed that someone from Lancaster called the Stone Harbor

Police Department and stated that the ‘plaintiff had a gun and was going to the beach to kill himself”. This

whole incident was fabricated in efforts to illegally detain the plaintiff , and further facilitate the alibi of

insanity. The plaintiff was detained for 4 hours in the Hospital, and was not released until he signed a

“suicide agreement”. The hospital report casts any doubt into the plaintiff ’s truths, and goes to insinuate

that plaintiff activities of the “digital movie”, are illusions. The plaintiff later found the phone numbers of

the Pennsylvania, Maryland, Delaware, and New Jersey State Police Department’s in his home in Conestoga,

PA. The handwriting of the individual, matches an official of the Lancaster County Solid Waste Department,

who at the time was negotiated a bond issue for the Lancaster County Incinerator with an attorney named

Stephen Spinello, of Lancaster, the same attorney responsible for negotiating the ISC and Ferranti merger at

the very same time.

B. August 14, 1987 Avalon (New Jersey) Police Department (5) - Family member again invade the privacy of

the plaintiff at his residence in Stone Harbor. The plaintiff flees the house, and this time drives to the

Avalon Police Department, one mile north of the Stone Harbor Police Department. An Avalon Patrol car pull



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the plaintiff over while en route. The plaintiff tries to explain the circumstances, and his desire for a

restraining order. The Avalon Policeman commands the plaintiff from his car, proceeds to frisk the plaintiff ,

and searches his entire vehicle, again not providing any explanation. The policeman conf is cates an “old” dry

empty bear can and a vile of muscle relaxes (plaintiff had a stiff back) from the car, and handcuff the plaintiff

and take him to the Avalon Police Department. The plaintiff , without the opportunity for any explanation is

charged with the following offenses: A) SPEEDING (F-1) B) OPEN ALCOHOLIC CONTAINER IN

VEHICLE C) UNREGISTERED VEHICLE (NEW JERSEY DEALER MAILED REGISTRATION MATERIALS

TO CONESTOGA, PA ADDRESS BY MISTAKE D) FAILURE TO EXHIBIT DRIVER’S LICENSE. The

Avalon Police Department impounded the plaintiff ’s vehicle. All of the Police Officers were verbally

abusive, laughing at the plaintiff trying to defend himself, and trying to get a restraining order.

C. July 14th, 1987 Pennsylvania Attorney Generals Office (1) The plaintiff phone the Pennsylvania Attorney

General’s Office and talked to Attorney General Bodan, and reported the crimes and requested intervention,

of which the plaintiff was told that nothing he said fall within the jurisdiction of the Pennsylvania Attorney

General’s Office, obstructing justice, and potentially facilitating and protecting the criminal enterprises of

Mr. James Guerin.

D. September 3, 1987 Manhiem Township (Pennsylvania) Police Department (3) - The plaintiff arranged for

a charter flight with Romar Aviation, to a destination of the Lancaster County Airport, for a scheduled

meeting with 2 Board of Directors from Financial Management Group, Ltd., the following morning, September

4, 1987. As the plaintiff was in flight, the Manhiem Township Detective, Detective Sigler, filed a charge of

TERRORISTIC THREATS (M1 ) against the plaintiff . The warrant for arrest will dis close that the

“Terroristic Threats” actually were reported two days later, with no recollection of time except with the time of

9:00 am and 12:pm. There was also no disturbance reported, and no one from FMG, Ltd., had admitted calling

the Manhiem Township Police Department. This arrest warrant was totally fabricated. obstructing justice,

and potentially facilitating and protecting the criminal enterprises of Mr. James Guerin

E. September 3, 1987 Manhiem Township (Pennsylvania Police Department (6) -The plaintiff was arrested for

A) BURGLARY (F-1) B) CRIMINAL MISCHIEF (F-3) C) UNLAWFUL RESTRAINT (H-1) D)

UNLAWFUL USE OF COMPUTER (F-3) E) THEFT BY UNLAWFUL TAKING (F-3) F) ROBBERY (F-1).The plaintiff , unknowing of the arrest warrant for Terroristic Threats filed early that day, visited his office at

Financial Management Group, Ltd., (FMG) later that same day to try to find any remaining business files that

were missing since his plane was repossessed. . Upon being let into the building by a cleaning girl, the

Plaintiff quickly asserted his rights to the property, which he was a rightful leaseholder and Officer of FMG,

and proceeded to gather documents. The plaintiff kissed the girl goodbye and ensured her safe return into

the building. obstructing justice, and potentially facilitating and protecting the criminal enterprises of Mr.



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James Guerin The plaintiff was illegally arrested for stealing his own files from his own building.

F. September 3, 1987, Manhiem Township Police Department (3): At the precise time that the plaintiff was

released into custody from the Conestoga Township Police, The Manhiem Township Police immediately used

unnecessary physical abuse upon the plaintiff by first placing shackles around the plaintiffs hands and legs

together, then smashing his head into the car door, and further forcing and wrestling the plaintiff , made every

attempt to cooperate, especially consider that the Conestoga Policeman allowed the plaintiff to sit in the front

seat, without handcuffs. The Manhiem Township Police refused the plaintiff request to know what he was

being arrested for. The Manhiem Township Policeman refused, and intentionally threw papers on the floor

of the cruiser in front of the plaintiff , laughing that he would be unable to pick it up or read it because of the

plaintiff ’s shackles. After arriving at the Police Station, Detective Larry Mathias refused to take a statement

from the plaintiff or tell the plaintiff why he was arrested. After several hours, the plaintiff was again

thrown into the police cruiser, where the driver intentionally drove at high rates of speed, and curving tocause the plaintiff to be thrown around the back of the cruiser, again unable to protect himself because of

the shackles . The victim was given no rights to provide testimony that would have immediately resulted in

his release. The plaintiff was never afforded the opportunity to contribute to the record of his any of his

prosecutions. The prosecutorial misconduct was again obstructing justice, and potentially facilitating and

protecting the criminal enterprises of Mr. James Guerin

A. .

F) September 4, 1987, Lancaster County Prison (1): The plaintiff was refused to make a phone

call, and when he was given a phone privilege, the phone would not connect to an outsideline. The plaintiff was verbally abused and generally mistreated.

G) September 5, 1987, The Lancaster County District Attorney’s Office (2): Attorney Robert Byers appeared

at the Lancaster County Pr ison to offer his services to the plaintiff , however the plaintiff never called or

mention to anyone Mr. Robert Byers. The plaintiff questioned his sudden interest in his affairs, and who had

called Mr. Byers.

H) September 9, 1987, The Lancaster County District Attorney’s Office (2):The plaintiff ’s bail was granted on

the illegal condition that the plaintiff admit himself into the St. Joseph Psychiatric unit until released by the

Hospital. After 7 days, the plaintiff learned that this condition was not legal, and immediately discharged

himself. St. Joseph Hospital would not release the plaintiff until he accepted full liability for the $3,029.00

charge. St. Joseph Hospital refused to accept the plaintiff ’s insurance information, stating that it was no

longer in force, which the plaintiff disputed. Another demonstrated act of inflicting financial hardship and

mental duress by providing false claims to the plaintiff that his bail was falsely protected on his entering St.

Joseph Hospital.



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I) September and October 1987, The Lancaster County District Attorney’s Office (1): The Lancaster

District Attorney refused any and all attempts by the Plaintiff to dis cuss the dire issues of his pending

charges. The plaintiff was extensively “shut out” of the Lancaster Attorney’s Office despite the

overwhelming abundance of evidence that the plaintiff could provide proving his innocence, and the

illegalities of the arrests. obstructing justice, and potentially facilitating and protecting the criminal

enterprises of Mr. James Guerin

J) September 29, 1987, The Pennsylvania Securities Commission (3): See the following “Findings of Facts”,

page 43.

A. J) November , 1987, The Pennsylvania Attorney General’s Office (1): See the following “Findings of

Facts”, 46.

B. K) November , 1987, The Pennsylvania Securities Commission (1): See the following “Findings of

Facts”,. Tape.

L) March 24, 1988, The Lancaster County District Attorney’s Office (1): See the following “Findings of

Facts, page 48.

A. M) May 27, 1991, Stone Harbor (New Jersey) Police Department See the following “Findings of Facts”,

page 63).

Stanley J. Caterbone, Plaintiff

Sworn to and subscribed

Before me this day

of , 1998

Notary Public

Notary Public of :

My commission expires:



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FINDINGS OF FACTS

(The activities and incidents contained herein will substantially support the allegations of the plaintiff , while

also attesting to the integrity of all claims filed by the plaintiff regarding his claims of violations of intellectual property rights. All of the following are essential for the purpose of intellectual property rights regarding the

plaintiff’s claim to enterprises engaged in the financial services industry and the information technologies

arena..

THE YEAR

1983

September 1983 - Pa. State Senator Gib Armstrong, former stock broker of individualSecurities of Lancaster, solicits Stan Caterbone. to purchase the offering of

(ISC) International Signal & Control, Plc, stock.. Stan Caterbone purchases

1,000 shares of ISC stock .



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THE YEAR

1985

Jan 9, 1985 - Stan Caterbone terminates his affiliation with Investors Diversified Services (IDS), of

Minneapolis, MN and forms his own independent financial advisory firm, S.J.

Caterbone Associates, of Lancaster, PA.

NOTES: At the advise and recommendation of Alexandria Armstrong, Stan Caterbone visited

Financial Services Corporation (FSC), of Atlanta, Ga, and affiliates with the broker

dealer the previous November.

Stan Caterbone transfers his registered representative's license several days after his

brother's death. IDS executive Jack Campana telephoned Stan Caterbone afterlearning of his plans, and tried to intimidate him by threatening legal action, in the

event he continued to service his existing clients.

Stan Caterbone also introduced Robert Kauffman to the Atlanta-based firm, while

leading a large IDS division in Atlanta, and making in excess of $250,000 annually.

FSC will eventually recruit Robert Kauffman as an executive, promoting him to

national sales manager at large, charged with recruiting representatives and offices

throughout the country.

After his leaving (IDS), and upon educating many other financial planners of the

merits of an Independent Broker Dealer, the following former associates of IDS will

leave and eventually become affiliated with his firm of FMG, Ltd., over the next 2

years: Robert Kauffman; P. Alan Loss; Daniel Moyer; Harry Radcliffe; Jim Werst;

Michael Hartlett; Daniel Moyer; Rich Podlasceck; Tom Turner; Rick Volpe; Gail

Turner; as well as others.

March 30, 1985 - Stan Caterbone conducts the Eastern Regional Free Agent Camp (ERFAC), in

Lancaster Pa. The first ever-video-taped professional football free agent camp

attracted players (45) from as far away as Hawaii and California. The camp was

organized to give players access to the scouts of all three professional football

leagues, National Football League (NFL), United States Football League (USFL),

and the Canadian Football League (CFL). The ERFAC was a pioneer because of

its strategy of having players attend one camp, and submitting a video tape of the

camp to all of the teams in the leagues , with no charge to the individual teams.

The Washington Post wrote a full page story in it's Sunday edition, and tried to

accuse Stan Caterbone of profiting off of the dreams of young athletes. Actually,



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that was precisely why Stan Caterbone organized the camp, after being wasting time

and money on conventional camps in trying to secure a professional football contract

for his brother, Mike Caterbone. Free agent camps are considered successful if only

one player lands a contract, and even extraordinary if the player lands a career.

In the following months, Stan Caterbone will negotiate a contract for MikeCaterbone; who will go on to load the Canadian Football League in scoring, and be

named Player of the week by Lite Beer, and featured during the traditional Sunday

afternoon broadcast. Mike Caterbone played for three seasons before joining the

Miami Dolphins of the NFL.

The Eastern Regional Free Agent Camp full filled its primary mission, despite loosing

some $3,000.

Stan Caterbone's career in the film industry has officially began as writer, producer,

director, and technician.

April 20, 1985 - Stan Caterbone incorporates Pro Financial Group, Ltd., a company composed of

accountant Robert Long, attorney Timothy Lanza, accountant Michael Smoker,

broker dealer FSC, and others to provide financial services to professional athletes

in an organized and coordinated effort. This was Stan Caterbone's attempt at a

concept which will later form the foundation for Financial Management Group, Ltd.,

or FMG, Ltd.

June 1985 - Stan Caterbone conducts a marketing and feasibility survey with Marketing

consultant Jeffrey Johnston, for the concept of the business which later will evolveinto Financial Management Group, Ltd., The study was conducted by

interviewing several area local physicians of substantial income and wealth for their

input and feedback of having one firm manage and administer all of their respective

financial, legal, accounting and related affairs.



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THE YEAR

1986

March 1986 - Stan Caterbone requests a meeting with John Depatto, President of Parent Federal

Savings and Loan (owned and operated by James Guerin's Parent Industries holding

company), for a residential real estate loan for the property at 2323 New Danville

Pike, Conestoga, Pa.

NOTES: Stan Caterbone also discusses the formation of Financial Management Group, Ltd.,

and any possible joint venture activities that may exist between the two financial

services organizations, with specifics to mortgage banking opportunities.

June 12, 1986 Stan Caterbone & Mike Caterbone (Joint Title) settle on the real estate deal, with a$100,000 loan from Parent Federal.

June 19, 1986 Stan Caterbone incorporates Financial Management Group, Ltd., (FMG, Ltd.,)

and 12 other subsidiary corporations to form a multi-faceted financial services [inn.

The firm would offer: securities brokerage; portfolio in management; financial

planning; insurance & risk management; tax planning; accounting S tax preparation;

estate planning; financial advisory; legal services; real estate services; mortgage

brokerage; venture capital.

June 22, 1986 Stan Caterbone submits the first draft of the Offering Memorandum to securities

attorney Jeff Jamoneau of the law firm McNeese, Wallace & Nurick, or Harrisburg

in preparation for riling the necessary regulatory requirements to secure financing for

FMG, Ltd., under a Regulation D, Rule 144 Offering Memorandum. The offering

allowed approximately $500,000 to capitalize FMG, Ltd.,

NOTES: The three principals decide on the following offices: Robert Kauffman is elected

President of FMG, Ltd.,; Michael Hartlett the Executive Vice President and

Treasurer; Stan Caterbone the Executive Vice President, Secretary, and also form

the Board of Directors -

Stan Caterbone is also President and Treasurer of FMG Advisory, Inc., the

firm to be incorporated as the Registered Investment Advisor with the Pennsylvania

Securities Commission, which Stan Caterbone will also administer and manage.

Augusts 1, 1986 - Financial Management Group, Ltd., (FMG) occupies and formally opens its

headquarters containing 20,000 sq. ft. of office space in the Eden Park complex

owned by the Fisher/Sponougle Group of Lancaster.



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August 14, 1986 - Stan Caterbone; and Michael Hartlett; and Robert Kauffman; as individuals; and

Financial Management Group, Ltd., sign a five (5) year individual lease with personal

guarantees for the office space with Fisher/Sponougle Group, Ltd.,

August 21, 1986 - FMG, Ltd., holds its first official and formal shareholders meeting.

October 6, 1986 - Robert Kauffman signs a demand note and borrows $10,000 from FMG, Ltd.,

Scott Robertson signs a demand note and borrows $20,000 from FMG, Ltd.,.

November 1986 - In late 1986, Stan Caterbone sustained a take-over attempt by partners Robert

Kauffman and Michael Hartlett, in order to take full control of FMG, Ltd.,. Several

employees were innocently fired in order to weaken Stan Caterbone’s control and

respect within the corporation.

NOTES: While in Baltimore, visiting a satellite office, Robert Kauffman and Michael Hartlettterminated Mary Lynn Dipaolo, a close personal friend and assistant, which caused a

serious problem in the trust of the principals, not to mention emotional duress.

Stan Caterbone would later visit his client, Dr. Al Schulz, because of his emotional

duress and stress caused by the illicit takeover attempts of Robert Kauffman and

Michael Hartlett. Stan Caterbone will discuss the behavior of his partners as causing

severe stress.

Mike and Marylynn Dipaolo will personally hold Stan Caterbone responsible for the

firing, and continue to subject him to persecution for allegedly not standing up toRobert Kauffman and Michael Hartlett, despite his efforts for reinstatement, and

Stan Caterbone's advise to seek legal counsel concerning the wrongful termination.

The Dipaolo's refused to seek legal counsel.

Several FMG, Ltd., executives, including Alan Loss, Scott Robertson, and Bob

Long, engaged in private meetings concerning the mistrust of both Robert Kauffman

and Michael Hartlett. Stan Caterbone, was the most trusted and respected principal

of the firm, and was constantly caught in the middle of the principal/associate

confrontations.

November 1986 - Abe Diffenbach, the acting manager of Lancaster's Shearson/American Express

stock brokerage office, contacts Stan Caterbone and asks him to consider hiring

Peter Peneros, a very large producer, who was apparently having difficulties with

the NASD.

Peter Peneros met with Stan Caterbone and discussed his problems, and it was

revealed that other firms did not want to get involved. Robert Kauffman consented

and hired Peter Peneros, who later joined and became FMG, Ltd's., largest personal



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producer.



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THE YEAR

1987

January 20, 1987 - Al Dannatt & Institutional Investors, of Houston, requests Stan Caterbone to marketand develop a portfolio of real estate projects in the East for mortgages, with an

extraordinary lending criteria of $3 to $100 million authority, with attractive and

competitive terms and rates from Institutional Investors' lending authority.

Al Dannatt also discloses to Stan Caterbone that he is in the process of acquiring a

bank, which will also be available for business with him.

NOTES: Stan Caterbone decides to fight and not accept any offers from Kauffman to give up

his equity in FMG, Ltd., and aggressively pursues the other peripheral businesses he

established in the original business plan, with emphasis on the mortgage bankingactivities. Stan Caterbone also agrees to include Scott Robertson and Robert Long

in the mortgage banking activities.

Stan Caterbone agrees to provide FMG, Ltd., with the normal profit splits of

peripheral business, but limits the involvement in order to minimize risk against

undoinfluence of Kauffman and Hartlett.

January 26, 1987 - The FMG, Ltd., shareholders elect Alan Loss and Robert Long to the Board of

Directors, increasing the original Board of Caterbone, Hartlett, and Kauffman to five

directors. Stan Caterbone had campaigned for both Alan Loss and Robert Long,

while Robert Kauffman and Michael Hartlett cast votes to others.

February 5, 1987 - Carolyn Royer writes a formal notice and complaint to FMG, Ltd., president Robert

Kauffman and Michael Hartlett regarding her recent fulfillment of passing her NASD

examine for a Registered Principal, which was agreed by both Kauffman and

Hartlett, to give her a salaried position of managing and administering the stock

broker's activities for FMG, Ltd., whom both would later deny.

NOTES: This would later load to the resignation of Carolyn Royer, despite the efforts of Stan

Caterbone to keep both Kauffman and Hartlett to their word and previous

agreements.

February 3, 1987 - Stan Caterbone offers his mortgage banking loan portfolio to High Industries Inc,

and High Associates at the request of Robert Long, FMG, Ltd., in-house

accountant, who also a former employee and accountant of High Industries Inc.,

February 4, 1987 - Stan Caterbone receives a letter from Owen Kugel, principal of OK Properties, to

secure financing for several historical rehabilitation properties, and offering and



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finders fee of $433, 592 upon financing.

February 11, 1987 - The FMG, Ltd., Board of Directors agree at the request and advise of Robert

Kauffman to loan $10,000 to Gail Turner (daughter of Tom Turner) of Minneapolis,

Mn, to capitalize an FMG, Ltd., satellite office in Minneapolis.

February 19, 1987 - Scott Robertson solicits Stan Caterbone to visit Power Station Studios and Tony

Bongiovi, of New York, for assistance in securing financing for a movie. Stan

Caterbone cites concern for the risk associated with motion picture investments,

however later decides to at least visit the studio. Discussions were also held in

securing financing for New York real estate deals for the mortgage banking activities

which had recently begun.

Robert Kauffman finalizes joint venture deal and agreement with Hilibbard Brown &

Company, the Broker Dealer from Washington, D.C., All FMG, Ltd., Registered

Representative's licenses are terminated from Financial Services Corporation (FSC)of Atlanta, GA, Kauffman's former employer.

March 10, 1987 - Investors Diversified Services (IDS), formally terminates Tom Turner, the largest

Divisional Manager in the country, earning in excess of $700,000 per year, for his

religious overtones in his office.

NOTES: Tom Turner is a close personal friend of Robert Kauffman's, and he and his daughter

become affiliated with FMG, Ltd.,. FMG, Ltd., will later loan $10,000 to Gail

Turner facilitated by Robert Kauffman.

Stan Caterbone becomes concerned because of the religious ties between Robert

Kauffman, Tom Turner, and Barry Schuttler, all FMG, Ltd., affiliates.

March 24, 1987 - In the FMG, Ltd., Newsletter, Robert Kauffman officially announces that Tom

Turner, of Minneapolis, Mn, has officially joined FMG, Ltd., and will begin building

offices in the same.

March 26, 1987 - The FMG, Ltd., Board of Directors, at the request and advise of Robert Kauffman,

vote to approve a loan of $25,000 to Hibbard Brown & Company, of Washington,

D.C.,

In addition the Board votes to have Stan Caterbone pursue the legal issues of

restructuring FMG, Ltd., in order to pursue the national franchising of the

organization, and to provide a means to transfer the equity of FMG, Ltd., to the

same.

March 26, 1987 - John Keeble, President of Financial Services Corporation (FSC), officially cite

Robert Kauffman for breaching their current employment contract by transferring the



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licenses to Hibbard Brown & company. FSC sends all licensed representatives of

FMG, Ltd., a letter stating their position and these allegations against Robert

Kauffman.

NOTES: Stan Caterbone becomes infuriated at the recent events due to the fact that he has

insisted as far back as the Spring of 1986 that Robert Kauffman disclose to all of the principals of FSC that Stan Caterbone and FMG, Ltd., are planning to eventually

apply for their own Broker Dealer License, or acquire an interest in another through

a joint venture, both of which would mean the termination in the relationship and

agreement with FSC.

It has become apparent that Kauffman was not only receiving compensation from

FSC, and FMG, Ltd., but was actually conducting business that was in a conflict of

interest to either FSC, or FMG, Ltd., either of which would ultimately add risk to the

value of FMG, Ltd., stock, and increase the potential liability for litigation to FMG,

Ltd.,

April 1987 - Stan Caterbone directs and coordinates a joint venture deal with the Life

Underwriters Group, of Harrisburg and FMG, Ltd., for the insurance business of

FMG Insurance, Inc., which Stan Caterbone presides. The joint venture was also to

evaluate and analyze of FMG, Ltd., to enter into the reinsurance business, another

strategy to acquire equity.

April 9, 1987 - Robert Kauffman receives a formal complaint from the president of Conestoga

Fuels, Bradley S. Singer, with regards to the services of accountant Robert Long in

the preparation of his 1986 taxes. Mr. Singer cites the negligence of Mr. RobertLong in not delivering the services as promised, and not responding to his calls. Mr.

Singer also alleges that FMG, Ltd., is not delivering the services that it promotes, and

states that FMG, Ltd., is not able to provide financial advise on both a personal and

corporate level.

April 14, 1987 - The FMG, Ltd., Newsletter announces that Stan Caterbone is offering his mortgage

banking services to all FMG, Ltd., affiliates, and that loans in excess of $2 million are

available for real estate ventures. Stan Caterbone also announces the plans to

develop an FMG, Ltd., satellite office in the York, Pa, area, through a joint venture

with the Bennet Williams real estate firm. It is also announced that the new RennetWilliams office complex will be the first private real estate syndication for FMG,

Ltd.,

April 16, 1987 - The FMG, Ltd., Board of Directors meeting is held at the law offices of McNesse,

Wallace and Nurick, of Harrisburg, with corporate attorney Jeffrey Jaouneau

present. The Board discussed the relationships of Tom Turner and Barry Schuttler

with specific regards of how to transfer equity of FMG, Ltd., to their interests

through a restructure.



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The reorganization and restructure of FMG, Ltd., was also discussed with the

considerations to vote on the preceding matters and a 5:1 stock split within the next

30 days.

April 18, 1987 - Stan Caterbone personally visits the headquarters of Hibbard Brown & company,outside Washington, D.C., en route to a tour day vacation in Captiva Island, 71.

Mike Dipaolo was also present.

Stan Caterbone wanted to discuss the present problems encountered with the

securities trading of his brokers, specifically Peter Poneros, was an exceptionally

large volume producer. Stan Caterbone also wanted to perform some sort of due

diligence on the firm, which he had previously scorned both Robert Kauffman and

Michael Bartlett for not personally visiting the offices prior to reaching the decision to

sign and consummate the joint venture agreement.

NOTES: Stan Caterbone became infuriated at the response by Pete Hibbard and his

subordinates after learning that they did not know a problem existed, while persons

at FMG, Ltd., were under the impression that the staff at Hibbard Brown & Co.

were acting to rectify and resolve the problems.

Stan Caterbone also become disappointed to find that the firm was nothing more

than empty offices, with little if any staff.

Stan Caterbone transcribes an extensive diary of events of the formation,

development and progress of Financial Management Group, Ltd., in response to therecent problems caused by President Robert Kauffman, and in preparation for any

potential legal litigation that may arise in the future.

NOTES: Stan Caterbone wanted to insure against Robert Kauffman misrepresenting the facts,

as he has demonstrated in the past. In addition, Stan Caterbone wanted to protect

and preserve all of his interests, which were instrumental in the success of FMG,

Ltd.,

It was known that Kauffman and Hartlett very much resented the accomplishments

and respect of Stan Caterbone within FMG, Ltd.,, despite their lack of commitmentin the early development of FMG, Ltd.,. Stan Caterbone assumed more risk, and

contributed more efforts than either of the other two principals in the beginning days

of the company.

May 5, 1987 - "Expanded" FMG, Ltd., Board of Directors Meeting is held that includes

additional FMG, Ltd., satellite office principals: Richard Volpe (Phil.); Barry

Schuttler (Siver Springs, Md.); Jerry Bavero (Camp Hill); and Ken flay (ISIS).



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FMG, Ltd, Board of Directors meet to vote on Stan Caterbone's request and

demand to ratify the recent joint venture agreement/contract with Hibbard Brown &

Company, after Stan Caterbone learned of dire inefficiencies within Hibbard Brown

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

unprecedented amount of risk to FMG, Ltd.,. Stan Caterbone voted by telephonefrom 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.

NOTES: Stan Caterbone had won the votes of Alan Loss and Robert Long, overturning the

decision of Robert Kauffman 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 Stan Caterbone.This will eventually lead to the Coup conspired by Kauffman and Hartlett to find a

way to get Stan Caterbone out of the corporation.

May 14, 1987 - Robert Kauffman sends a formal letter of apology to Pete Hibbard, president of

Hibbard Brown & Company, of Washington, D.C. for the recent action of the

FMG, Ltd., Board of Directors to ratify the previously accepted joint venture

agreement.

Robert Kauffman acknowledges his efforts in trying to convince the FMG, Ltd.,

board to continue with the agreement, and also states his position that this action will be regretted by all in the future.

May 15, 1987 - Stan Caterbone travels to Hollywood, CA, directly from Palm springs, to meet with

Marcia Silen, of Flatbush Films, the film producer of "Mutant Mania", the "Digital

Movie". Stan Caterbone discloses his outline and strategies for the SONY proposal

which Marcia Silen calls "genius and brilliant". Additional strategies are discussed for

the project.

An additional meeting with Becky Austin, a known real estate professional in the

Hollywood area, is held. Stan Caterbone discusses a possible joint venture todevelop a Hollywood office for the mortgage banking activities, and Becky Austin

indicates her interest to pursue the venture. Additional plans are made to meet with

Al Dannatt of Institutional Investors in Houston, Texas at a later date.

Stan Caterbone also contacts Ted Gamillion, owner and operator of Gamillion

Studios (a successful "mini-major" film studio), of Hollywood Studios, who has

solicited his services through Becky Austin and Marcia Silen, for the refinancing and

a restructuring of his studios. Plans are made for a future visits to the Studios at a



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later time, due to scheduling problems at that time.

May 16, 1987 - Stan Caterbone directs his administrative assistant, Lynn Kreider, to confidentially

transcribe his diary of May 2, 1987 into the word processor for future reference,

without the knowledge of any persons.

May 18, 1987 - Stan Caterbone completes the first draft of the SONY proposal and the "Digital

Movie" in order to secure the financing of the project.

FMG, Ltd., sponsors and conducts a seminar titled "Medical Malpractice Risks" at

the St. Joseph Hospital for all attending Physicians and hospital staff. Scott

Robertson bad requested Stan Caterbone to coordinate the efforts because of his

relationship with Hospital Administrators, and his many clients that included many

Hospital physicians. Stan Caterbone bad also worked with the Hospital's Human

Resource Department on other similar projects.

The seminar included an attorney from the local law firm of Barley, Snyder, &

Cooper, that presented information regarding legal and financial exposure in the

event of medical malpractice suits, and an executive from Crown Life Insurance

describing new products that help alleviate some financial exposure. Robert

Kauffman, presented information about FMG, Ltd., its progress, and services, and

Alan Loss acted as moderator.

NOTES: In addition, Stan Caterbone directed the professional filming of the seminar,

and also a marketing video, which included demonstrations and talks by the head

of various departments within FMG, Ltd., as well as demonstrations of variouscomputer technologies utilized and designed by FMG, Ltd. Stan Caterbone had

intended to edit the video, and use it for marketing and recruiting in the franchising of

the company.

The seminar attracted approximately 50 persons, including Dr. William Umiker

(FMG, Ltd., shareholder) and Dr. Albert Schulz Psychiatrist), both Stan

Caterbone's clients. The seminar was considered a success.

May 18, 1987 - Robert Kauffman signs and notarizes the agreement for the stock option agreement

and joint venture with the Planners Securities Group, of Atlanta, Ga; as Robert Longagain signed as the FMC, Ltd., Board of Directors, rather than Stan Caterbone,

Secretary of FMG, Ltd., as common practice, policy, and law.

NOTES: Again, Stan Caterbone would not approve this contract, on the basis of a clause,

conveniently included, that would have provided that the 10 % stock option was only

vested under the conditions that Robert Kauffman remain as president of FMG, Ltd.,

Upon the termination, resignation, or any other departure, FMG, Ltd., would loose



23/76


all interests in the accumulated stock options earned over the next seven (7) years.

Stan Caterbone would not approve such a contract because of the conflict of

interests with respect to the above clause, which yielded Robert Kauffman the power

to hold his position of Presidency, as a financial hostage, if his performance was not

within the expectations of all shareholders, or if he engaged in activities of misconduct

or wrongdoing. The only way the stock option agreement was fully vested upon thedeparture of Robert Kauffman before the seven year schedule, was if convicted of a

felony, which yields the potential for many abuses and conflicts of interests on his

part that would still subject the FMG, Ltd., shareholders to the loss of the stock

options upon his departure.

May 20, 1987 - Attorney Ric Fox submits the legal "Letter of Intent for Joint Venture Participation

and Contribution" for Power Productions I to Stan Caterbone for securing

investments and financing of "Mutant Mania", the "Digital" Movie. Stan Caterbone

was the General and Managing Partner responsible for managing the investment fund.

The invoice was paid by FMG Advisory, Inc., in which Stan Caterbone wasPresident and managed the daily operations.

NOTES: Stan Caterbone had previously held a meeting with Noris Boyd and Robert Long, at

FMG, Ltd., whereby Noris Boyd had verbally committed to investing approximately

$250,000 into the venture.

May 21, 1987 - Again Robert Kauffman has Robert Long sign for his Employment Agreement with

FMG, Ltd. ,as representing the Board of Directors, which should have been signed

by the Secretary of FMG, Ltd., Stan Caterbone.

NOTES: Stan Caterbone also disputed this contract as proposed by Robert Kauffman, mainly

due to the increased financial incentives and salary increases to Robert Kauffman.

Stan Caterbone especially disputed a 3% profit incentive on all FMG, Ltd.,

businesses paid as a bonus to Robert Kauffman. Stan Caterbone objected to

Robert Kauffman being paid bonuses on businesses that Stan Caterbone had

personally developed, managed, and was responsible for managing the daily

operations, including: the mortgage banking activities; FMG Accounting; the

insurance business; and FMG Advisory, which Stan Caterbone was elected and

remained President.

Stan Caterbone also disputed the increase in monthly salary of $5,000 to $7,000, as

instituted by Robert Kauffman, himself.

May 26, 1987 - In the FMG, Ltd., Newsletter, Michael Hartlett officially announces the appointment

of Jon Gruber and Craig Russell, principals in the law firm of Russell, Kraft, Gruber

and Huber to join FMG, Ltd., and occupy an office in the FMG, Ltd., headquarters.



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NOTES: The above announcement was done without prior notice or consent of Stan

Caterbone, which was against present company policy regarding important and

sensitive matters of that nature. The same said law firm would later represent FMG,

Ltd., and take all legal action against Stan Caterbone in the following months.

May 27, 1987 - Arlene Davidson, of Flatbush Films, finalizes and completes the first draft of theworking budget 0£ the "Digital" Movie and mails it to Stan Caterbone in preparation

for the meeting in Stone Harbor in the upcoming weeks.

May 29, 1987 - Associate Producer Arlene Davidson encloses the first draft of the screenplay to

Stan Caterbone in Stone Harbor, NJ. Barry Schuttler's office manager, Audrey,

discloses during a meeting with Stan Caterbone to educate her on how to recruit and

build the satellite office, that Fete Hibbard, president of Hibbard Brown &

Company, is also (Kauffman, Turner, Schuttler) ,a "Born Again" Christian, and that

he is trying to convert her.

Mike Dipaolo submits a proposal to Stan Caterbone to join the FMG Accounting

group with Robert Long.

June 6, 1987 - Flatbush Film producers: Marcia Silen; Arlene Davidson; and Director Barbara

Peters travel from Hollywood, CA, to visit with Tony Bongiovi and other producers

at Stan Caterbone's residence in Stone Harbor, NJ, for their first production

meeting. Flatbush Film personnel spent several days in New York at Power Station

Studios, before traveling to the New Jersey Shore, the location for the filming of the

movie.

June 8, 1987 - Stan Caterbone sells 1,000 shares of ISC stock.

June 9, 1987 - Stan Caterbone submits an application for a loan in the financing of the aircraft to

John Wolfe, Executive Vice President of Commonwealth National Bank, and

delivers it to him at Lancaster Aviation.

Stan Caterbone also submits a request for a $100,000 line of credit with the

Farmers First Rank, where all FMG, Ltd., accounts are held. Stan Caterbone offers

his FMG, Ltd., holding as collateral.

NOTES: Stan Caterbone requested the financial records and statements from Michael

Bartlett, the FMG, Ltd., Treasurer, who was responsible for the accounting.

However despite the legal entitlement, Michael Bartlett and Robert Kauffman

refused to allow access of all financial records to Stan Caterbone.

Ironically, even though Stan Caterbone's past efforts were known to be responsible

for the success and the formation of the organization, Stan Caterbone will never have

or had, the privilege to review any financial records of the firm, even as of the date of



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this report (1991).

June 10, 1987 - Stan Caterbone prepares a financial capsule of Financial Management Group, Ltd.,

bases on his original projects contained in his business plan of one year earlier.

After gathering the analytical in formation based on capital raised, and productionfigures, Stan Caterbone reported that FMG, Ltd., was at least two (2) years ahead

of its original projections in almost every category, even though FMG, Ltd., was a

month away from its 1st Birthday.

The following is a synopsis of that report which illustrates the highlights:

Capital Raised: $80 million

Professionals: 60

Staff: 13

Satellite Offices: 12Stock Value: $13-$17 per share

(before the 5:1 stock split and not including the 10% interest in the Planners

Securities Group, stock, recently acquired)

June 12, 1987 - Lancaster Aviation arrange for the selected aircraft to be flown in from the Midwest

to be inspected by Stan Caterbone. 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. Theadditional $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 Stan Caterbone for the remaining balance. Stan Caterbone

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 Wclfson agrees not to deposit the check until Stan Caterbone confirms that the

funds have been received and deposited in order to cover the check for theremaining $25,000. Stan Caterbone 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 Stan Caterbone to have his airplane included in their Fleet

Insurance plan. Stan Caterbone 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.



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The papers are signed and the settlement is made during the initial inspection.

June 15, 1987 - Stan Caterbone receives the production schedule and itinerary for the "Digital"

(Mutant Mania) Movie from Arlene Davidson, Associate Producer (Flatbush Films),

of Hollywood, CA.

NOTES: Flatbush Films has begun to direct all communications and efforts to Stan Caterbone

directly, and have begun to look to him for direction, after lack of communication

and several misunderstandings in dealing directly with Tony Bongiovi and others at

Power Station Studios.

Stan Caterbone suddenly finds himself in the middle of resentment by Scott

Robertson and others because of the respect from the Hollywood people concerning

the directing of the movie.

June 17, 1987 - Stan Caterbone receives materials from New York bases Real Estate developer,Susan Weinstein, for considerations in securing financing for development of the

fastest growing section of New Jersey, the "1-78 Corridor". This section of New

Jersey was attracting many professionals who worked in New York city, mainly due

to it's 35 minute commute, and it's rural setting.

June 18, 1987- Stan Caterbone and Randy Grespin, corporate attorney for The Life Underwriters

Group (TUG), fly to Atlanta, Ga, to visit with executives of Planners Securities

Group (PSG), a nationally known Broker Dealer. Stan Caterbone had initially

consulted with both Kauffman and Bartlett concerning the trip, however when both

disagreed, Stan Caterbone questioned why he was the only principal to personallyvisit the operations of Hibbard Brown & Company, which lead to his decision to

terminate the ill fated merger.

NOTES: The company in Atlanta, was the 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 FMG, Ltd., and offering an attractive equity interest.

Randy Grespin agreed to reimburse $600 to Stan Caterbone for the expense and

use of his aircraft.

NOTES: Stan Caterbone had the following agenda for the trip and meeting:

1. Visit and discuss a possible joint venture and merger with FMG, Ltd., and

evaluate the various departments necessary to administer FMG, Ltd's., stock

transactions and private real estate offerings.

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

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



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3. Familiarize Greg Dune, a personal friend and recruitment of Stan Caterbone’s

who was also visiting from Florida to consider opening a Florida office for FMG,

Ltd.,

4. 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. Stan Caterbone 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 FMG, Ltd., On the return flight home, Stan Caterbone confided to

Randy Grespin, requesting legal advise, regarding the recent problems and his

allegations of misconduct by FMG, Ltd., President Robert Kauffman. Randy

Grespin advised Stan Caterbone to take some time and seek legal counsel.

Upon entering the offices of FMG, Ltd., after arriving in Lancaster, Robert Kauffman

pulls Stan Caterbone into his office and abruptly shouts "Who is running this

corporation, me or you?". Stan Caterbone quickly answers "I don't give a damn

who runs this company. as long as it's run right, and for the right reasons!" Stan

Caterbone immediately left the office.

Later that evening, Robert Kauffman appears at the residence of Stan Caterbone, for

the first time, unannounced and completely out of character of Robert Kauffman.

Robert Kauffman and Stan Caterbone have a dispute over the renewal of their

respective new contracts. Stan Caterbone refuses to approve Robert auffman's new

contract due to clauses that provide him with profits on businesses that tan

Caterbone has developed and will manage. Robert Kauffman also refuses to give

Stan Caterbone an additional increase of his salary of $3,000 per month, while

wanting to increase his salary from $5,000 to $7,000 per month. Both salaries did

not include commissions from their respective clients.

June 22, 1987 - Stan Caterbone hires Todd Deliinqer, a planner in FMG, Ltd., to help administrate

the daily activities of his personal clientele and to perform administrative duties

necessary due to the amount of time Stan Caterbone is conducting

business out at the office, allowing Stan Caterbone to focus attention on the Strategic

Planning, and allowing him to better manage his time.

Stan Caterbone sends a memo to client and shareholder Dr. William Umiker that

introduces his new assistant, in addition to information regarding his pension accounts.

June 1987 - Guerin’s brother-in-law, Carl I. Jacobson, is targeted by a federal task force and



28/76


grand jury investigating massive Department of Defense contract fraud and

corruption within United Chem Con and the York-based Wedteck Corporation.

June 23, 1987 - Carl Jacobean flees the U.S. in the early morning for Santiago, Chile, in what

will ultimately be a failed attempt to avoid a federal subpoena similar to

those served to other United Chem Con associates. Romar Aviationprovided the flight.

June 23, 1987

10:00 am Larry Resch visits Stan Caterbone at FMG, Ltd., headquarters in Lancaster, as

scheduled. Larry Resch explains that "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

Setaside contracts, and solicits financing for new facility.

Stan Caterbone becomes annoyed the context of the conversation, especially the

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

the relationship to Chem Con. After evaluating the financial statements, Stan

Caterbone also suggests there is approximately $15 to $18 million in missing funds.

2:00 pm Stan Caterbone has his locks changed to his office by Russel Locksmith of Lititz, in

order to secure confidential personal and business tiles in light of the current internal

power struggle between himself, Michael Hartlett and Robert Kauffman, and given

the conversation with Mr. Larry Resch a few hours earlier.

June 25, 1987 - Robert Kaufman, President of FMG, Ltd., and other FMG, Ltd., executives

burglarize Stan Caterbone'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 FMG, Ltd., stock certificates to Peter

Peneros and Scott Robertson. Robert Long signs the stock certificates as Secretary

of FMG, Ltd., when Stan Caterbone was acting Secretary, and was the only person

duly authorized to issue FMG, Ltd., stock certificates.

NOTES: Stan Caterbone learned of the burglary by Robert Kauffman in a telephone

conversation while at Stone Harbor, NJ; Kauffman inadvertently mentioned that thestock certificates were issued, however, with all documents at risk of being stolen,

Stan Caterbone did not mention the incident, in hopes to first recover any potentially

stolen business and personal files.

June 27, 1987 - Jim Bly of Virginia based Source Capital, is scheduled to use the aircraft of Stan

Caterbone, for approximately 6 hours of flight time at $300.00 per hour. However,

Jim Bly is denied the flight by Lancaster Aviation, who repossess the aircraft and



29/76


refuses to allow the plane to leave the ground, without any knowledge by Stan

Caterbone.

NOTES: Chuck Smith, president of Lancaster Aviation, later discloses to Stan Caterbone that

he had deposited Stan Caterbone’s pre dated check for $25.000, without the

confirmation by Stan Caterbone that the funds had been transferred from accounts.Stan Caterbone had argued with Pete Wolfson, salesman, that he did not want to

give them a post dated check, however Chuck Wolfson insisted. Now, Chuck

Smith had told Stan Caterbone that Pete Wolfson did not have the authority to

complete the transaction. However Stan Caterbone reminded Chuch Smith that he

was acting as an agent for Lancaster Aviation, and that was not material to this

dispute.

June 29, 1987 - Stan Caterbone receives 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 FinancialManagement Group, Ltd.,. Stan Caterbone had retained the services of Siedel,

Gonda, Goldhammer 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 Stan

Caterbone in the proposal for SONY Corporation of Japan.

In addition, Stan Caterbone had retained the law firm to research the private label of

"Financial Management Group, Ltd.”, in preparation of reorganizing and marketingthe organization in the national marketplace. Stan Caterbone had requested the

patent research while President of FMG Advisory, Inc., and authorized payment

from the companies account, which Stan Caterbone had exclusive authority.

June 30, 1987 - Stan Caterbone visits with Dave Schaad, President of the York based real estate

firm of Bennett Williams, Inc., Stan Caterbone 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. Stan Caterbone had been

working with Dave Schaad for the past 3 months, along with Scott Robertson.

NOTES: Stan Caterbone 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 Stan Caterbone 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 Stan



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Caterbone, During the meeting, Stan Caterbone disclosed the current political

problems within the principals of FMG, Ltd., being facilitated by Robert Kauffman

himself.

July 1, 1987 - Stan Caterbone, assisted by James Warner, remove all personal and business files

from the premises of FMG, Ltd., after Stan Caterbone had learned of the burglary.

NOTES: In an effort to conceal the incident to FMG, Ltd., personnel and shareholders to

avoid a devastating and potential crisis, the above attempt to restore the files was

done at approximately 1:00 am. while the office was vacated. Stan Caterbone had

found several confidential business files (mortgage banking) in the offices of Robert

Kauffman and Robert Long, that were the exclusive property of Stan Caterbone. In

an effort to document the theft, Stan Caterbone took photographs of the files in the

offices of the two executives, before he removed them.

Stan Caterbone had prepared to take the files to the attorney office of Joe Roda onthe following morning.

July 1, 1987 - Stan Caterbone phones Joe Roda from the home of Mary Lynn Dipaolo to arrange

for a meeting to discuss the recent events and Coup attempt by Kauffman and

Hartlett that included several criminal and security violations.

Stan Caterbone visits with Joe Roda and describes the incidents in detail, including

the "Digital Movie", ISC, and all related activities. Joe Roda instructs Stan

Caterbone to have all of the files copied and arranges for the return of all FMG,

Ltd., corporate files.

Stan Caterbone had questioned Joe Roda for a legal opinion as to his right of any

moneys in FMG, Ltd., checking accounts that he was authorized to sign for. Joe

Roda advised that Stan Caterbone had no right to any funds. All checks were

returned to FMG, Ltd., along with all other documents.

Stan Caterbone advises Joe Roda 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. Stan Caterbone

advised Joe Roda that he would like to take all of his files to Stone Harbor, NJ forsafekeeping while he pursued his legal recourse. Stan Caterbone also explained that

he would feel safer leaving Lancaster until these circumstances were brought under

control.

July 2, 1987 - In an effort to continue all efforts and business activities, Stan Caterbone visits the

Office Works, owned and operated by High Industries, to purchase a printer while

staying in Stone Harbor. FMG, Ltd., had an open account, which Stan Caterbone

authorized, as an officer of FMG, Ltd.,. The Office Works demands cash payment



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and refuses to put the purchase on credit.

Stan Caterbone 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. Stan Caterbone secures insurance and pays

$1,000 to Romar Aviation for the flight to Stone Harbor, which was conducted byVictor M. of Romar Aviation. In addition, at the referral of Victor, Stan Caterbone

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

Goode Binds the insurance and instruct Stan Caterbone to mail a payment of $750.

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

Victor. Stan Caterbone 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.

NOTES: Stan Caterbone was not aware of the relationship of Romar Aviation with Guerin

and ISC, especially the previous flight or Carl Jacobson to Chile by Romar Aviation just a few days before, the same day of his meeting with Larry Resch of ISC.

July 4, 1987 - At approximately 12:00 am, Victor calls Stan Caterbone 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 was not due until July 25, 1987. There was no money due to

Commonwealth National Bank.

Stan Caterbone 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, which not only has a lender relationship with

Stan Caterbone, but is also a competitor for his mortgage banking activities.

It was also known that Stan Caterbone's lending authority was larger and more

competitive than most of the local banking community.

NOTES: Stan Caterbone now becomes in fear for his life due to this incident, and all

other unexplained incidents in the preceding days and weeks.

July 4, 1987 - At approximately 9:00 am in the morning, Stan Caterbone calls his attorney Joe

Roda, under emotional duress from the previous conversation with Victor and the

repossession of his aircraft with all documents on board; Joe Roda 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



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supports his efforts to leave Lancaster with his files to solicit aid and support from

legal and law enforcement authorities to suppress the conspiracy.

NOTES: Stan Caterbone 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.

At approximately 9:30 am, after the disturbing phone, Stan Caterbone 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.

Stan Caterbone provides Brad Donahue with all documentation showing legal title to

the aircraft in the event authorities are notified. Stan Caterbone 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.

NOTES: In the following weeks, Dave Austin, would later disclose to Stan Caterbone that

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

unexplained and questionable flight chart.

July 5, 1987 - Stan Caterbone 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 Stan Caterbone's house accompanied

with another attorney Robert Chercicoff.

NOTES: All of the recent activities were detailed and described concerning FMG, Ltd.,; the

"Digital Movie"; and the illegal repossession of the aircraft. Stan Caterbone

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.

Stan Caterbone 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



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arranged by Stan Caterbone some months earlier.

By July 5, Stan Caterbone had already made two legitimate attempts to solicit legal

aid for the unexplained events and circumstances, both of which were maliciously

sabotaged.

July 6, 1987 - In an effort to document the conspiracy theory, Stan Caterbone requests Tom

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

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

Stan Caterbone's and Robert Kauffman states the following:

"Stan Caterbone 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 iswhat'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.”

July 6, 1987 - Stan Caterbone telephones Dr. Al Schulz, psychiatrist at St. Joseph Hospital, and

client of Stan Caterbone'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 Stan Caterbone's behavior and activities.

From the allegations, Dr. Shulz advised that Stan Caterbone was suffering fromillusions of grandeur, and prescribed Lithium treatment, and to return to Lancaster

for consultation.

Stan Caterbone 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.

July 6, 1987 Stan Caterbone contacts David Drubner, of Boston, Ma, a friend of Stan

Caterbone's brother’s Mike, and an attorney. During the conversation, David

Drutner questions Stan Caterbone about "taking some medication", and supports theallegations of insanity.

July 6, 1987 - In the following days, Stan Caterbone 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:

Manhiem Township Police Department, responded "what bank branch

repossessed your aircraft"; Pennsylvania State Senator Gib Armstrong,



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responded, "I will call the Pa Attorney General's Office and have them call you; the

Documents

Recorded - 15-03984 Habeus Case DECLARATION Re Findings of Facts 1998 - Original Claim Filed in United States Eastern District of Pennaylvania in Case No. 05-2288 on May 16, 2005