Amended Complaint Oct '07

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
amgroup01@msn.com
http://www.amgglobalentertainmentgroup.com/

ORIGINAL 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

AMENDED DEFENDANT'S LIST

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 –

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.