Documenti di Didattica
Documenti di Professioni
Documenti di Cultura
AND ADMINISTRATION OF
MANAGEMENT GROUP, Ltd.,.
STOCK WAS IN THE LOCKED
NO CORPORATE BUSINESS
STAN J. CATERBONE.
IT WAS THIS ACTIVITEY THAT GAVE STAN CATERBONE THE AUTHORITY, POWER, AND
FIDUCIARY RESPONSIBILITY TO REMOVE ALL CORPORATE FILES AND DOCUMENTS OF
FINANCIAL MANAGEMENT GROUP, Ltd., AND FMG ADVISORY, INC., THAT WERE WELL
WITHIN THE RULES, LAWS, AND REGULATIONS OF PENNSYLVANIA SECURITIES
COMMISSION. THE CAPACITY OF EXECUTIVE VICE PRESIDENT, SECRETARY,
SHAREHOLDER, AND INCORPORATOR OF FINANCIAL MANAGEMENT GROUP, Ltd.,
AS PRESIDENT, SECRETARY, AND INCORPORATOR OF FMG ADVISORY, AS
PRESIDENT, OWNER, AND INCORPORATOR OF PRO FINANCIAL GROUP, Ltd., AND
AS GENERAL PARTNER OF POWER PRODUCTIONS I, AND FINALLY AS THE
FOUNDER OF ALL THE PRECEDING.
THE AIRPLANE. THE ILLEGAL REPOSESSION OF THE AIRPLANE DEMONSTRATES THE
DESPERATE ACTS OF CRIMINAL CONSPIRACY THAT CONFRONTED STAN J. CATERBONE.
FIRST, COMMONWEALTH NATIONAL BANK DID NOT NOTIFY STAN J. CATERBONE OF THE
REPOSSESION UNTIL 4 DAYS LAYTER, AND BY REGULAR MAIL.
SECONDLY, THERE WAS ADEQUATE INSURANCE FOR THE AIRPLANE, PROVIDED BY
LANCASTER AVIATION AND ROMAR AVIATION.
THIRDLY, TO IMPLY THAT FLYING THE AIRPLANE TO FLORIDA WAS A BREACH
OF CONTRACT IS PROPOSTEROUS.
AND LASTLY, DEMANDING THAT THE AIRPLANE MUST REMAIN ON THE PREMISES
OF LANCASTER AVIATION WITHOT PRIOR DISCLOSURE DURING THE SIGNING OF THE
LOAN AGREEMENTS WOULD VIOLATE MANY RIGHTS OF THE BORROWER.
HOWEVER, MOST DAMAGING, AND MOST INCRIMINATING, IS THE FACT THAT STAN J.
CATERBONE HAD SECURED FINANCING OF $5,000,000 AT MORE COMPETIVIE TERMS
THAN COMMONWEALTH NATIONA BANK. THIS WAS WAR.
THIS ILLEGAL REPOSESSION WAS THE FIRST TIME ANY CREDITOR HAD EVER
TAKEN ANY ACTION AGAINST STAN J. CATERBONE. THIS UNJUSTIFIED AND
ILLEGAL ACT WAS INSTRUMENTAL IN SPREADING A FLOURISH OF RUMORS AROUND
THE BUSINESS COMMUNITY, CLIENTS, AND CREDITORS OF STAN J. CATERBONE THAT
FINANCIAL HARDSHIP AND DIFFICULTITIES WERE THE CAUSE OF ANY PENDING AND
FUTURE PROBLEMS THAT WERE CONSPIRED AGAINST STAN J. CATERBONE.
IRONICALLY, EVEN UP TO AND INCLUDING AUGUST 8, 1987, (23 DAYS AFTER
THE REPOSESSION)THE CREDIT REPORT OF STAN J. CATERBONE AS REQUESTED
BY STAN J. CATERBONE OF THE LANCASTER CREDIT BUREAU, WAS IMPECABLE,
AND HAD REPORTED THAT ALL ACCOUNTS ARE "PAID WITHIN 30 DAYS, OR AS
PROMISED".
THE SUICIDE. ONE OF THE MOST INFLUENTIAL AND MOST DAMAGING ARSENOL
AGAINS STAN J. CATEROBNE, WAS THE INSANITY ALLEGATIONS. INITIATED BY
ROBERT KAUFFMAN ON JULY 6, 1987, THESE ALLEGATIONS WOULD EVENTUALLY GIVE
THE RIGHT OF WAY FOR ALL CRIMINIAL AND ILLEGAL OFFENSIVE STRIKES THAT
WOULD BE FURTHER USED TO REDUCE STAN J. CATERBONE TO NOTHING, LITERALLY.
IN ONLY A FEW WEEKS, THESE ALLEGATIONS HAVE RUINED AND DESTROYED ANY
AND ALL BUSNIESS OPPORTUNITIES OF STAN J. CATERBONE. THE ALLEGATIONS
WERE SPREAD AS FAR WEST AS HOLLYWOOD, CALIFORNIA, SPECIFICALLY GAMILLION
STUDIOS AND FLATBUSH FILMS, AND AS FAR SOUTH AS HOUSTON, WHICH WAS THE
HEADQUARTERS OF INSTITUTIONAL INVESTORS.
THE MOST FRUSTRATING, HUMILIATING, AND FRIGHTENING EXPERIENCES OF ALL WAS
ON AUGUST 12, 1987, WHEN STAN J. CATERBONE WAS LITERALLY ARRESTED BY THE
STONE HARBOR POLICE AT THE POLICE STATION, WHICH INCENDENTLY WAS WHERE
STAN CATERBONE HAD VISITED IN ORDER TO INVESTIGATE INVASION OF PRIVACY
LAWS, AND HANDCUFFED, TRANSPORTED, AND ADMITED TO THE BURDETTE TOMLIN
HOSPITAL FOR PSYCHIATRIC EVALUATION OF THE CHARGES OF SUICIDAL TENDENCIES.
IRREGARDLESS OF NO EVIDENCE, IT TOOK OVER 3 HOURS TO CONVINCE HOSPITAL
PERSONELL THAT STAN J. CATERBONE HAD NO NEVER DISPLAYED ANY SUCH
TENDENCIES TO ANYONE.
THIS EVENT WAS JUSTIFIED BY IN ANONOMOUS PHONE CALL TO THE STONE HARBOR
POLICE THAT STAN J. CATERBONE WAS "GOING TO THE BEACH TO KILL HIMSELF
WITH A GUN". IT SEAMED INMATERIAL THAT STAN J. CATERBONE DID NOT OWN OR
POSSES A GUN. THIS WAS A NIGHTMARE.
THE SECOND VISIT TO THE HOSPITAL OCCURED ON SEPTEMBER 9, 1987, THE DAY
THAT BAIL WAS SECURED FOR THE RELEASE FROM THE LANCASTER COUNTY PRISON
FOR THE CRIMINAL CHARGES OF THE FINANCIAL MANAGEMENT GROUP, Ltd.,
BURGLARY.
IN ACCORDANCE WITH THE CONDITION FOR BAIL THAT REQUIRED THAT STAN J.
CATERBONE ADMIT HIMSELF VOLUNTARILY TO ST. JOSEPH MENTAL HEALTH UNIT,
STAN J. CATERBONE RELUCTUNTLY AGRRED, FOR NO OTHER REASON THAN TO GET
THE HELL OUT OF PRISON. THIS CONDITION WAS EVEN CONFIRMED AND INSISTED
UPON BY THE CRIMINAL ATTORNEY REPRESENTING STAN J. CATERBONE.
NO ONE WOULD EXPLAIN TO STAN J. CATERBONE HOW THIS COULD NOT
BE CONSTRUED AS AN INVOLUNTARY COMMITMENT, AND WHY THIS WAS BEING
IMPLEMENTED. AFTER FIVE DAYS OF PRISON, AND FOUR DAYS OF THE HOSPITAL,
THE EMOTIONAL AND PSYCHOLOGICAL TORTURE THAT WAS CONSTANTLY BEING
INFLICTED HAD FINALLY BECOME UNBEARABLE.
THE PRISON. THIS WAS THE WORST FIVE DAYS OF LIFE FOR STAN J. CATERBONE.
THE POWER AND THE DESTRUCTIVENESS OF THE CONSPIRACY HAD FINALLY BECOME
REAL. STAN J. CATERBONE WAS PHYSICALLY AND VERBALY ABUSED BY THE
MANHEIM TOWNSHIP POLICE DURING THE ARREST, AND DURING EVEN DURING HIS
IMPRISONEMNT AT LANCASTER COUNTY PRISON.
AND THE MOST UNBELIEVABLE AND UNFOREGIVING OF ALL IS THE FACT THAT IT
IS EASILY PROVEN THAT STAN J. CATERBONE WAS ARRESTED, INCARCERATED, AND
ABUSED FOR BURGLARIZING HIS OWN PROPERTY, STEALING HIS OWN PROPERTY, IN
A COMPANY THAT HE HAD MORE LEGAL RIGHT TO THAN ANYPERSON ON THIS EARTH.
IN ADDITION, THE EVENTS THAT LEAD TO HIS ARREST DURING THE NIGHT OF
SEPTEMBER 3, 1987 WERE EVEN MORE BIZZARE. A FEW DAYS PRIOR, STAN J.
CATERBONE HAD REACHED HIS HUMAN THRESHOLD FOR EMOTIONAL AND PSYCHOLOGICAL
ANQUISH. THE FEAR OF THE COSPIRACY HAD REACHED MONUMENTAL PROPORTIONS,
AND RESULTED IN THE ACUTAL FEAR FOR HIS LIFE. THERE WERE ALREADY SEVERAL
VIOLATIONS OF INVASION OF PRIVACY AND PERSON WHICH SUPPORTED THIS. IN A
DESPERATE PLEA FOR HELP, A LETTER WAS WRITTEN AND DELIVERED TO DIANE
SAWYER OF "60 MINUTES". BY THIS TIME ALL CONVENTIONAL SOLICITATIONS TO
LOCAL, STATE, AND FEDERAL AUTHORITIES PROVED FRUTLESS.
KNOWING THE THREAT AND THE FRUSTRATION THAT STAN J. CATERBONE HAD PROVED
TO INFLICT UPON THE CONSPIRATORS, HE SET UP A MEETING WITH SEVERAL
EXECUTIVES OF THE FINANCIAL MANAGEMENT GROUP, Ltd., WITH THE EXCEPTION
OF MIKE HARTLETT AND ROBERT KAUFFMAN. THE MEETING WAS SCHEDULED WITH
ALAN LOSS FOR FRIDAY, SEPTEMBER 4, AT THE OLDE HICKORY INN. ON THUSDAY,
STAN CATERBONE CHARTERED A FLIGHT FROM CAPY MAY, NEW JERSY, TO LANCASTER
WITH ROMAR AVIATION. THERE WAS A CREDIT WITH ROMAR THAT PAID FOR THE
FLIGHT. STAN CATERBONE HAD ALSO MADE AN APPOINTMENT AT THE OFFICE OF
UNEMPLOYMENT SECURITY FOR THAT AFTERNOON. NOT BEING ABLE TO PRODUCE AN
INCOME WAS A HUGE PROBLEM BY THIS TIME.
STAN CATERBONE HAD ARRANGED TO BE PICKED UP AT THE LANCASTER AIRPORT BY
MARYLYNN DIPAOLO AT ABOUT 2:00 PM. THEY WERE TO HAVE DINNER AT THE
DIPAOLO RESIDENCE. THE TONE OF THE CONVERSATION BY MARYLYNN DIPAOLO WAS
EXCEPTIONALLY DEFENSIVE AND AGGRESSIVE TOWARD STAN J. CATERBONE. IT WAS
EVEN MORE DISTURBING TO FIND THAT MARYLYNN WAS ONE OF THE LAST ALLIES
STAN CATERBONE HAD. THE CONVERSATION WAS DIRECTED AT INTEROGATIONS OF
ALLEGATIONS THAT WERE TOTALLY ABSURD. NOT BEING EMOTIONALLY OR
PSYCHOLOGICAL ABLE TO WITHSTAND THE CONFRONTATION, STAN J. CATERBONE ASKED
02/
CURRENT SITUATION
CURRENT SITUATION
CURRENT SITUATION
The l986 Tax Act threatens to reduce the need for tax planning,
and tax qualified plans. Rather than seek shelters and other relief,
investors will be likely to pay tax, and invest savings, thereby
increasing the need for asset management and the creation of
wealth Through equity investment.
COMPANY STRATEGY
Market products that are structured with lower up-front costs
and stable ongoing management renewals in order to build
revenue from service over a period of time. This will gradually
replace the heavy emphasis on new sales and give rise to a truly
responsive service oriented business.
4.
CURRENT SITUATION
Charitable organization
Counseling center
Current Situation
Current Situation
Current Situation
Current Situation
Current Situation
free
Company Approach
Planners will be free to deliver the highest quality products from
among thousands of sponsors so as to work exclusively for the
benefit of the client. The planner may choose top industry
performers, solid and sizeable companies and a variety of
"niche" products to fill every client need.
2.
Current Situation
Current Situation
Current Situation
Seminar Presence - -
2}
3}
4}
5}
6}
7}
8}
9}
10}
Stock will be offered to the public at $5.00 per share until the
office opens on August 1, 1986. It is our plan to raise
$300,000 which will cover the start-up costs of furnishing the
office, capitalizing the Registered Investment Advisor and
Broker-Dealer, and funding any shortfall in operating revenues
for at least one year.
It is our intention to avoid borrowing monies if at all possible.
We believe that it is best to pay in advance and that a debt-free
status keeps monthly obligations to a minimum, thus reducing
business risk and increasing profitability. We are, likewise,
committed to low management incomes for all
principals/planners who will continue to generate personal
income from sales.
Our initial price will be discounted in order to recognize the
importance of several types of investors in our business. First,
investors who purchase in excess of 5,000 shares are
important because of our limit of 35 investors in the offering
each year.
Without sizeable investors, we will not be able to meet our
target of raising $300,000. Additionally, investors who will also
generate revenue for the business through financial services
marketing provide double value for our firm. Consequently,
we will offer shares at 3.50 to any major investor or producing
investor. If any investor proves to be both major and
producing, his price will be $2.50.
Our estimate of stock value, given recent takeover prices in the
industry, would place the stock value at $5.60 after one year and
$l0.67 after three years. That price would be 3.5 times book value
which increases with each stock purchase. Purchases of some companies
have been based not on book value but rather on gross
commission income. The going price the last several years
has been a dollar for dollar price. Using that figure stock value
would be $l0.00 in one year, and $13.33 in three years.
Financial Service Corporation, a company reforming in l978,
is valued at $25 million dollars just eight years later. The
potential in this business is obvious, yet there are no
guarantees. This is a start-up business venture and suitable
only for long-term, equity investors.
It is our plan to build aggressively in several areas, but to
concentrate in Pennsylvania. We see a special opportunity
with a three to five year window when banks will get into our
business through acquisitions as they continue to lose assets
through their limited banking functions. Should a great
opportunity to sell occur, we would consider it at that time.
Our continued personal planning business could give us the
luxury of cashing our investment and remaining in business.
However, it is much more likely that we will hold our
investments until retirement or pass it on to future
generations.
Our specific issue restricts sales to another party for one year
and also limits repurchases to intrastate parties.
FINANCIAL HIGHLIGHTS
* Actual Statistics as of May 30, 1987
1987
1988
1989
May '87
SALES (Millions)
CAPITAL
54.00 M
78.10 M
100.00 M
80.00 M
Commissions
(GCI)
2.70 M
3.40 M
5.00 M
3.50 M
Affiliate
Earnings
0.30 M
0.60 M
1.00 M
0.50 M
Total Gross
Revenues
3.0Z M
4.00 M
6.00 M
4.00 M
Net Revenue
Less Commission
0.76 M
1.01 M
1.52 M
N/A
Manpower
(Professionals)
37
43
50
48
Hires
10
12
14
14
Retention
90%
85%
85%
95%
SALES FORCE
Average Sales
(Per Professional)
$81,081
$107,500
$120,000
$85,000
1988
1989
MAY '87
Revenue
3.000
4.000
6.000
4.000
Net Revenue
0.760
1.010
1.800
N/A
Retained
(Profits)
0.210
0.275
0.501
N/A
Return on
Equity
70.0%
53.9%
66.6%
N/A
Capital Base
0.300
0.510
0.785
N/A
Book Value
Beginning of Year
0.300
0.480
0.725
0.300
Book Value
Per Share
1.600
1.810
3.050
4.000
Book Value
End of Year
0.480
0.725
1.526
N/A
Shares
Outstanding
Value/Share
(at 3.5 x book)
300,000
400,000
450,000
245,000
$5.60
$6.34
$10.67
$14.00
$10.00
$13.33
$17.00
Traditional
$10.00
(at 1 x Total Gross Revenue)
CONTINGENCY PLANS
Corporation..
Bob began his career with a financial subsidiary of the
American Express Corporation in 1976 upon his graduation
from Millersville State College in Millersville, Pennsylvania. In
his four years of direct selling to the public, he became the
youngest person in the company to achieve multi-million dollar
production status at the age of 25. Bob then began to take
on additional associates as he began to build his practice
in Lancaster, Pennsylvania. In just two years, his practice had
grown to l2 representatives handling over $l2 million dollars a
year in annual investments and managing in excess of $60
million dollars of client monies. While building this operation,
Bob continued to be the leading producer in his office and the
region.
Bob was then promoted to division manager of the West
Coast. In that position, He tripled the size of the sales force
and increased volume over 500% in a period of 2 years. His
division of American Express handled over $l00 million dollars
of investor monies.
Bob was then asked to take over the largest operation in the
southeast, located in Atlanta in l984. With over 60 financial
planners, handling an excess of $200 million dollars of
investor's monies, Bob again moved his territory into the top
echelon of the company.
With FSC since l985, Bob has opened the first three
company-owned offices and now supervises an excess of 75
employees. His operations now rank 4th in all FSC related
planning operations. Bob brings to Financial Management
Group, Inc. l0 years of experience in the financial
planning industry in both sales and sales management. He is
a member of the International Association of Financial Planners
and is in the process of completing the course work for
Certified Financial Planners designation. Bob is a frequent
speaker at both corporation and business financial planning
functions and has been quoted frequently in local and national
media publications. He continues to handle investments for
select clients.
Bob will serve as president, chairman of the board and will be
the largest stockholder. His experience in managing and
developing large financial service organizations will provide
the leadership and expertise necessary to insure the growth
we envision.
BIOGRAPHY OF MICHAEL M. HARTLETT, AFP
Mike Hartlett is currently an independent financial planner and
heads his own local firm - - Financial Planning Consultants.
Mike is a licensed securities principal and fully a licensed
securities broker. He has completed the Certified Financial
Planning program with the College for Financial Planning and
currently holds an Associate Financial Planner designation.
He will receive the Certified Financial Planner designation in
February 1987.
Mike began his Financial Planning career five years ago with
IDS a subsidiary of American Express. During his career with
IDS he was among the firm's top planners. He was on the
Presidents Advisory Council for IDS in 1985 and from a field
of over 5,200 IDS planners, finished among the top 66 financial
planners in the country. In 1983 and 1984 he was among the
top three in IRA/Qualified Plan Production. In September,
1985 he left IDS to form his own financial planning firm.
Mike has an extensive knowledge of corporate retirement plans
and pension programs and has excelled in retirement planning
for individuals. He conducts financial planning seminars in
several large Lancaster County corporations and is active in
promoting financial planning in Lancaster County.
Mike currently manages in excess of $14 million in client
assets. Mike is committed to delivering the highest quality
planning services to his clients. He believes that personal
attention and service are the key to a strong client/planner
relationship.
Mike will serve as Executive Vice President of Financial
Management Group, Ltd. He will be in charge of operations
and serve as chief financial officer.
FINANCIAL MANAGEMENT GROUP, LTD. (Exhibit A)
Financial Securities, Inc. ................The Broker Dealer
FMG Advisory, Inc. ........................The Registered Investment
Advisor
Financial Services Insurance Agency .......The Insurance Agency
FMG Accounting Services, Inc. .............The Accounting Firm
Financial Mortgages Services, Inc. ........The Mortgage Broker
Wealth Management Services, Inc. ..........The Portfolio
Manager & Market Timer
Financial Planning Consultants, Inc. ......The Financial Planning
Firm
AFFILIATE FIRMS (In House)
Berger Real Estate ........................Real Estate Services
O'Day & Smith .............................Legal Counsel for Business
& Real Estate
Shirk, Reist, Wagenseller & Shirk .........Legal Counsel for
Estate Planning
Lovell Associates, Inc. ...................Property & Casualty
Services
Pro Financial Group, Inc. .................Services for Professional
Athletes
*
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DI= ****************************************************************
TI=\FMG, Ltd., RULE 144, REG D DRAFT OFFERING
IM=010P01.CPR
DA= July 31, 1986
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES 3
SU= SUMMARY: Correspondence from Jeff Jamouneau of McNeese,
Wallace, and Nurick, in regards to the requirments and advice
to Stan Caterbone with regards to his efforts of
writing the Offering Memorandum for Financial Management
Group, Ltd., to raise the initial capital by way of a
Regulation D, Rule 144, Private Placement Offering,
registered with the Pennsylvania Securities and
Exchange Commission.
IM=010P02.CPR
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IM=010P03.CPR
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TI=\FORM D REG 144 CORRESPONDENCE
IM=011P01.CPR
DA= August 7, 1986
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
2
SU= SUMMARY: Letter from Jeff Jamouneau to Stan Caterbone
regarding filing procedures for the FMG Ltd, Regulation D, Rule
144 Offering Memorandum, filed with the Pennsylvania
Securities Commission.
IM=011P02.CPR
DI= PAGE 2
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TI=\SALE OF FMG, Ltd,. STOCK
IM=012P01.CPR
DA= August 11, 1986
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
2
SU= SUMMARY: Letter from Jeff Jamnouneau to Stan Caterbone
addressing the requirements for the actual sale of the FMG, Ltd,.
stock pursuant to Section 203(d) of the Pennsylvania
Securities Act of 1972 with respect to the Pennsylvania
Securities Commission.
IM=012P02.CPR
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TI=\OFFERING MEMORANDUM LEGAL DOCS (PA SEC)
IM=013P01.CPR
DA= August 19, 1986
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
1
SU= SUMMARY: Letter from Stan Caterbone to Joseph Lyden, of the
Pennsylvania Securities and Exchange Commission.
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TI=\LEGAL FEES FOR FMG, Ltd., FORMATION
IM=014P01.CPR
DA= August 22, 1986
AT= CORRESPONDING AUDIO TRACKS: 01/02/07/08
PA= PAGES:
1
SU= SUMMARY: Letter for the legal fees for the set up and
formulation of FMG, Ltd., to Stan Caterbone from Tim Lanza, of
O'Day and Smith, of Lancaster PA. Invoice also includes fees
for the formation of all subsidiaries.
DI= ****************************************************************
TI=\FMG Ltd., REGISTRATION WITH PA SEC
IM=015P01.CPR
DA= August 25, 1986
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
1
SU= SUMMARY: Letter to the Commonwealth of PA, Department of
IM=035P02.CPR
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TI=\SHENDEL REQUEST FOR FINANCING
IM=036P01.CPR
DA= February 10, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A letter requesting financing for several projects.
Leonard Shendell is an investment banker, with several
different firms, located in Dressher PA. A few projects
were seriously considered. Esbestos contamination
had ruined one deal.
DI= *************************************************************
TI=\FMG, Ltd., BOARD MINUTES OF 02/11/87
IM=037P01.CPR
DA= February 11, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
2
SU= SUMMARY: Mr. Peter Hibbard is introduced by Robert Kauffman
as a representative of Hibbard Brown, a broker dealer from
Washington, D.C. Kauffman aggressively pursues a merger
of FMG, Ltd., with Hibbard Brown. Stan Caterbone is
skeptical of the deal. After decisions are made to
accept deal, Stan Caterbone is dissatisfied with the
performance and administration, visits with Hibbard Brown
and demands the deal is rescinded. Stan Caterbone then
flies to Atlanta, to do a deal with Koegler Morgan.
IM=037P02.CPR
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TI=\FISHER/SPONOUGLE CO. REQUEST FOR FINANCING
IM=038P01.CPR
DA= February 13, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
1
SU= SUMMARY: Martin Sponaugle of Fisher, Sponaugle Investment
Group, which is the owner and landlord for 1755 Oregon Pike,
headquarters for FMG, Ltd.,. Marty Sponaugle had
requested financing for several projects.
DI= ************************************************************
TI=\BARRY SCHUTTLER RELIGIOUS ALLEGATIONS
IM=039P01.CPR
DA= February 13, 1987
IM=046P02.CPR
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TI=\J. KEEBLE (FSC) LETTER TO ALL REPS
IM=047P01.CPR
DA= March 26, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
01
Format
Mixing
3.
4.
5.
II.
1.
2.
3.
4.
5.
6.
2 = $l80,000,000
III. Film/Video
IV.
V.
VI.
l.
2.
3.
4.
l.
Needs help
a. Low profits
b. Beta Bust
2.
3.
4.
5.
Creation - 4/11/87
11:00 - 1:00 a.m.
Stan 98%
1% Scott - Call Ron Gell
Research Sony
1% Marcia - Sony give 4 million
Raise 15 Million
Call Head of video distribution
Merchandising - Hang Ten Off/Kodak
/Sony Difference test visa add in
DI= **************************************************************
TI=\KAUFFMAN CONGRATS TO S. CATERBONE
IM=052P01.CPR
DA= April 13, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/
PA= PAGES:
1
SU= SUMMARY: Congratulations letter from Robert Kauffman to Stan
Caterbone on his commissions of $86,466.11 for the
fiscal year ended March 30, 1987. FMG, Ltd, had
accumulated $815,000 in Gross Commission Income (GCI)
for the first quarter, which can be extrapolated to
offices of
PA. The agenda
of FMG, Ltd,.
Barry Schuttler,
IM=056P02.CPR
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TI=\USEPPA PROJECT CORRESPONDENCE
IM=058P01.CPR
DA= April 29, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04//07/08
PA= PAGES:
1
SU= SUMMARY: Letter from John Klemish regarding real estate
investment on Useppa Island, Pinnland, FL.
DI= ************************************************************
TI=\MAY 2, 1987 FMG, Ltd., MEMO TRANSCRIPT BY S. CATERBONE
DA= MAY 2, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
SU= {THE FOLLOWING IS THE AUTHENTIC TRANSCRIPT AS TRANSCRIBED
BY LYNN KREIDER OF FMG, Ltd., ON OR ABOUT MAY 10, 1987.}
We all have seen broker/dealers being bought and sold for very
sizable amounts of money, usually in the vicinity of $l of equity for
$l of gross commission income. We began to see that we were seeing
anywhere from $l million of gross commission income per year with the
group that we had. In the group was Ken Ray and some very creative and
talented people.
Throughout our meetings and discussions which were very long,
durable and tiresome. From December to May I probably spent
every other evening with Bob in Atlanta trying to put this deal together.
Let me go over a couple of other things that had happened up to
that time that I'd like mentioned in this document, before I forget. Back
in the summer of l985, I was contacted by John Philips from Blue Ball
National Bank. Because of my visibility with the local chapter of the
IAFP John wanted to call me and look at the options of Blue Ball
National Bank become involved in Financial Planning. John called a
meeting with me and I believe he was looking for someone to head a
Financial department with inside Blue Ball National Bank or contract
with someone outside. I had l-l/2 hour with John and his
subordinate, whom I can't remember his name, I believe it was Joe. He
was the vice president of the trust department, I believe. Anyway after
the meeting they did not have the faith or the confidence that I was the
right person or they didn't believe that this was really what they
wanted to do. But I have never heard from them since.
Fall of l985, before our initial meeting, after I decided that I was not
going g to relocate in Atlanta, I began to look for other options in
Lancaster. One of those were that a couple people put me in touch
with several banks. One was Joe S. with Commonwealth National
Bank and another was Meridian Bank. Both of those individuals
received phone calls from people I did business with stating that I was
looking for something and asking that they give me an interview. None of
them would even give me an interview. I received a letter from
Commonwealth stating that they had no positions open at this time,
but they would keep my name on file. From Meridian, I don't believe I
even received a letter.
This is one of the reasons that I don't have very much respect for
banks, or people who work in banks. I don't wish to dwell into this
subject, but because of several of these episodes I just don't have
much respect for bankers, or banks what so ever.
During this time that I was looking for something to do, I had a
meeting with Owen K. Owen K. was looking for someone to raise his equity
for his rehab projects and his syndications. I had one meeting with
Owen and one with Ed Pontius and apparently they hired someone who
essentially what happened is that Owen ran into a lot of trouble and
a few months ago I was given Owen's name and he wanted me to
raise both debt and equity for him. Whereas one year ago he wouldn't
even continue any conversations with me. I believe this gives you an
indication that a lot of the people in this community are very close
minded and narrow minded and unless you are a member of the
Country Club or the Hamilton Club, or unless you come from a
family of wealth, you don't receive very much attention or consideration
and you are really just another person on the street. Most of the people
in this community whom I am referring to do not have the business
thought it was a chance for me to get some things done and I liked
Mary Lynn a lot and we got along and I thought it was a chance for
me to get a few extra things done.
I took her on in February and before too long she was working 30
hours a week. She had a babysitter lined up for the kids, and it was
very encouraging for me to see her do this because it gave her the
confidence for the first time that she could do something other than
just have children. She was having a great time and I was having a
great time and we enjoyed working with each other. At that
time, Bob invited Mike and I down to the annual conference in
Tucson, Arizona and with the conference arrangements we were allowed to
take someone, such as your spouse. I asked Mary Lynn if she wanted to
go and I don't believe she was ever on a plane before and she
asked Mike and he said it would be good for her to meet some of these
people and get involved with a career. We ended up down at Tucson
and that was in April 2 and we spent four or five days there.
Upon meeting Bob I told him I was bringing Mary Lynn out and I
knew from the start that this was a sore spot. First of all she was
married and he couldn't understand what she was doing out there
with me. Second of all he didn't appreciate the whole situation when he
met her he said something to the effect that she looked very young.
After the second day we were all good friends and she was getting
along very well with Bob and Pam. In fact, Pam confided things in her
that I know Pam never told anyone. It looked as though they liked,
or at least pretended to like Mary Lynn and so anyway we all had a
good time. Bob, myself, and Mike spent most of our time in individual
private meetings trying to put this deal together and work out the
details especially with FSC. I think it was back at this time we
realized that Bob was probably going to resign from management and
commit and come up to Lancaster. I think one of the reasons why Mary
Lynn and I became very close was that she reminded me so much of my
mother in the way that she handled her kids, family and I became
infatuated with that. I liked her a lot. What happened was that Mike
and Bob resented the fact that we had so much fun while we
worked. We got work done, but we went out to lunch for an hour or
so and we really enjoyed things. To them that had no place in
business. For me, as long as I got my work done, I felt
better about my work and it worked out for the best. This was a
problem and will come up later.
During the Spring of 1986 when we were putting this together I had
the opportunity to move across the hall and get additional space from
another tenant. I was going to sub-let. I did this so it would give
Mike and I additional space and give operations more space so we could
get additional people before the people was done. I moved into 12 by
18 office with reception room and I had 3 or 4 additional offices.
Nancy was working for the tenant that I was subletting and she didn't
have a job and she asked me if there was anything she could do.
Mike wanted to hire her and I said let's just try it part time with no
commitments on either side to do anything permanent when we
move in and she began part time. So we now had Mary Lynn, Nancy and
Nancy A. That was the beginning of the staff problems. The staff
was always going to have staff problems in the beginning and I can't
Labor Day and one day for Thanksgiving. Mike Hartlett took off two of
three weeks, leaving me to tend the shop. I was always the one doing
all the work, recruiting, stock offering,labor matters, drew up all the
contracts, drew up the offering memorandum with the help of the
attorney. It was funny that I was the only one raising the money probably 80% of the funds. I was the only one of the principals who
had outsiders investing in the company. The most they did; Bob
Kauffman raised $5,000 from his father in law, so not only did I put
my own money in I risked that of my clients. But they were willing to
accept that up front. A couple times it came down to either me
getting the money from my clients or us not having the financial ability
to pay off some of the capital resources that we had.
During September we began to have problems with Mary Lynn and the
staff and me. This was the beginning of them trying to reduce and
dilute my control of the company as far as input was concerned. It
was a very emotional and draining experience after all the work I did to
put this all together to find those two were trying to push me out. It
reached the point in October or November where they actually asked
me if I wanted to "get out." They indicated that I was not right for
management, management was not right for me, that I wasn't having
fun and all this and that. Most of that was due to their action as far
as their trying to dilute me and weaken my confidence. They
constantly made fun of me in front of all the other planners at meetings
and it was just ugly.
They also tried to interrupt my relationship with Mary Lynn
which was nothing more than a very personal, deep friendship.
No one knows this, but the trauma was so heavy that I went under
the care of a psychologist at St. Joseph Hospital, beginning November
and I was suffering a severe case of depression.
Because of
schizophrenia being found in my family, I was not afraid to go seek
psychological counseling. I was on medication for three months. In
September they had it in their minds that they were going to get rid of
Mary Lynn. And they tried every opportunity, finally in November a week
before Thanksgiving, they fired Mary Lynn. Without cause, for no reason,
other than they just wanted her out and felt she was incapable of
whatever.
It actually reached the point where Bob and Mike went around
politicking the brokers to support them that Mary Lynn was not
doing her job which was not true. She had the complete support of all
the brokers. Maybe at times there was a case where someone was
unhappy with her performance, but in general it was a ploy, a plot,
fabricated by Mike and Bob.
After their attempt to buy me out and get rid of me so far as my
control and my interest, I held out reluctantly often times wondering if
I were going to give in and by Christmas I decided I would stick it out.
There were not other alternatives, but the money they offered me to get
out was $2,50 a share which comes out to $100,0000. I wanted no parts
of it, so by January I decided to stay.
Bob had
worried
slack.
beating
After
I spent time and effort and I believed in so much of what I'd done,
they were trying to take this away from me and get me out of the
picture.
and
in. Scott asked me to go up to New York with him to talk about the
project and I asked what it was. He indicated it was a movie. I was
very reluctant and hesitant to do this because movies to me, tax
shelters, scams, not very economic type investment. Me being very
conservative was not attracted, but I decided to go anyway just to
get out of town, more or less just to get away.
When I got up there I was totally amazed at the caliber and the
people who we were associating with. What I found out was that we were
working with the leading recording studio in the world. There
credentials, their accomplishments were phenomenal- they were just it.
I'm not going to spend a lot of time of this because just the bottom
line is what is important here. After seeing the project when I looked
at what Tony was doing, and from a business perspective there were
just so many elements in this project that were just truly amazing to me
so far as distribution and marketing and risk and everything else.
Bottom line was a product that was worth 15 to 20 million dollars being
made for 4 million with the ability to be one of the leading movie, video
projects of the years.
First of all you have the leading recording studio in the world working
on the sound for the project that was going to include a follow up of
Tony's previous band who was Bon Jovi who was already one of the
hottest thing in music as far as album sales. Then you have the fact
that he was going to digitize the recording which was never done
before in the movie industry at a time when the video market is just
going bananas. Not only that, but the label that signed the band owns
MTV.
You put all this together and you've got a phenomenal business with
a lot of opportunity.
Seeing this, I committed myself to the project not knowing who,
where or how we were going to raise 4 million dollars but I believed in
the project so much. I guess because I saw a lot of the same elements
used in FMG in this project, and even more. I got instincts when I
raised money for FMG I was still very concerned with the risk
elements to my investors but when I looked at this project the risk was
even less. Less risk, more protection with this project so I believed
in this project.
We spent seven or eight weeks developing the packaging the product
for the investors, things have happened during that time that fell into
place perfectly - the article in Rolling Stone, the marketing. It is May
4th at 4:30 a.m. and there is no doubt in my mind with the articles
in Rolling Stone that we have the money for the movie. That project
in itself will probably put us in the forefront of the entertainment
industry within eight weeks. It is mind boggling as far as what can
come of this, but the project is done, we did something, we did not use
FMG, they will receive no split. I guess what I'm saying is that because
of the way Bob and Mike treated me or pushed me to go out and do
things, that did not involve FMG and I did not feel that they did not
deserve to become a part of these things. From the beginning I knew
FMG was going to get their piece.
Let me go back to an earlier development concerning the
Broker/Dealer. We of course thought in the beginning that we would
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DI= *************************************************************
TI= FMG, Ltd., BOARD MINUTES OF 05/05/87
IM=060P01.CPR
DA= May 5, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/06/07/08
PA= PAGES:
3
SU= SUMMARY: Stan Caterbone updates activities of following:
FMG, Ltd., and convenience industry; Mortgage Banking
Business Activities and Availability of Funds;
Movie Project w/Tony Bongiovi & Power Station;
FMG Advisory, Inc.; and the Insurance business;
Ken Ray and Jere Bavero report problems encountered
at Hibbard Brown during visit. Barry Schuttler ("Born
Again") "NO PROBLEMS".
IM=060P02.CPR
DI= PAGE 02
IM=060P03.CPR
DI= PAGE 03
DI= ************************************************************
TI=\GAMILLION STUDIOS OF HOLLYWOOD REQUEST FOR FINANCING
IM=061P01.CPR
DA= May 6, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/05/06/07/08
PA= PAGES:
2
SU= SUMMARY: Letter to Financial Management Group, Ltd., from
Marcia Silen's (Producer of Flatbush Films) Becky Austin,
requesting financing assistance for Gamillion Studios of
Hollywood CA. Stan Caterbone meets with Ted and Mary Gamillion
in Hollywood CA, to discuss financial alternatives, and
leaves with several documents pertaining to subject.
Stan Caterbone also meets with Becky Austin to discuss
mortgage and investment banking business in Hollywood CA.
IM=061P02.CPR
DI= PAGE 02
DI= ************************************************************
TI=\HAMILTON LIFE SOLICITATION
IM=062P01.CPR
DA= May 12, 1987
AT= CORRESPONDING AUDIO TRACKS: 07/08
PA= PAGES:
1
SU= SUMMARY: Letter to Stan Caterbone from Alexander Hamilton
Live soliciting a contract for various insurance products.
DI= ************************************************************
TI=\FMG, Ltd., BOARD MINUTES OF 05/13/87
IM=063P01.CPR
DA= May 13, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/07/08
PA= PAGES:
5
SU= SUMMARY: Board Meeting set by Stan Caterbone to rescind the
deal previously consummated with Hibbard Brown & Company.
Caterbone refused to let the relationship of Robert
Kauffman and Peter Hibbard compromise the financial and
legal well being of Financial Management Group, Ltd.,.
By overturning the recent Board Decision, Stan Caterbone
had for the first time gained complete control of the
Board of Directors, of which will motivate the further
criminal actions of Hartlett/Kauffman/Peneros/Long/
Robertson. Stan Caterbone later visits with Bill Koegler
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DI= ************************************************************
TI=\KENNEDY PROPERTIES REQUEST FOR FINANCING
IM=064P01.CPR
DA= May 6, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
2
SU= SUMMARY: Letter to Stan Caterbone from Kennedy Property
Corporation, of Turnervill NJ, requesting for
financing and mortgage assistance for several projects.
IM=064P02.CPR
DI= PAGE 02
DI= ************************************************************
TI=\BENNETT WILLIAMS PRELIMINARY SYNDICATION PROPOSAL
IM=065P01.CPR
DA= May 11, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
Stan
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TI=\STAN CATERBONE AND RANDY GRESPIN VISIT PLANNERS SECURITIES GROUP
IM=332.CPR
DA= May 18, 1987
AT= AUDIO TRACKS: /ALL
PA= PAGES: 01
SU= SUMMARY: The Planner Schedule outlines the charter flight schedule
of Stan Caterbone's plane, and his flight log to Atlanta, Georgia.
After Stan Caterbone directed FMG, Ltd., to rescind the illegitimate
and current merger with the Hibbard & Brown Company, Stan Caterbone
decided to personally visit the Broker Dealer of William Koegler, of
Atlanta, GA. Stan Caterbone was familiar with Bill Koegler's operation
because of his work with the International Association of Financial
Planners (IAFP). Many of the planners that served as National Chairmen
of the IAFP were part of Bill Koeglers group. Bill Koegler also was
a with John Keeble at FSC, in Atlanta. Stan Caterbone was well aware
of the quality of products and services that they had to offer.
Stan Caterbone also invited attorney Randy Grespin to accompany him in
an effort to work on the affiliation of The Underwriters Group of
Harrisburg for possible insurance product. Stan Caterbone had been
working with the president, Tony Pascotti, on a number of different
projects.
Randy Grespin had agreed to pay Stan Caterbone for 1/2 of the charter
costs for the use of Stan Caterbone's plane. Stan Caterbone would
receive approximately $600.00 from The Underwriters Group for the
charter service.
The meetings were very productive, and it is here that Stan Caterbone
made a personal evaluation that the Planners Group would be the best
firm to develop a merger/acquisition on the grounds of service, support,
and reputation.
This meeting set the groundwork for the proceeding merger acquisition
deal with Bill Koegler.
Immediately upon the return, Robert Kauffman made an announced visit to
the residence of Stan Caterbone outraged and yelling "Who is running this
company?" Stan Caterbone replied " I don't care who is running this
company, as long as it is for the right reasons".
Bob Kauffman then asked Stan Caterbone to approve his new management
contract, which included undeserving financial elements. Stan Caterbone
quite emphatically opposed to having Robert Kauffman being compensated
on business that was the direct and exclusive results of Stan Caterbone's
efforts.
This set the stage for Robert Kauffman to find a way to get rid of
Stan Caterbone, no matter what it would take.
DI= ************************************************************
INTRODUCTION
SONY'S ROLE
PRODUCT DEVELOPMENT
MARKETING AND DISTRIBUTION
APPENDIX
INTRODUCTION
Tony Bongiovi and Power Station Studio are undertaking a
project that has the potential of revolutionizing the entertainment
industry. In the next few pages of this proposal, I will outline the
elements involved and how Sony can participate in this
landmark event.
The technology of the recording industry has been advancing by
leaps and bounds. We have seen the advances from monaural
long playing record to stereo record to compact disc. Now we
are seeing tape systems that use digital rather than analog
signals appear, matching the quality of compact discs. What
has happened to the theatre's? The audio portion of a film, is
as responsible for the sensations one experiences at a motion
picture as the visual, yet many theatre's are still
equipped only for mono sound. Why is this? We feel there are
two basic reasons.
1> The relative high cost of upgrading a theatre to be able to
incorporate the advanced technologies of the audio industry.
2> The lack of proper equipment for the film industry to
produce high quality digital audio tracks.
These two problems should not be addressed separately. There
is little motivation for upgrading until the product is available and
even less motivation to produce a product that can not be
heard.
Tony Bongiovi and Ed Evans at Power Station in New York,
have now made it possible to address these problems
simultaneously. Their creation of the new "Power Station Digital
Movie Sound" (PSDMS), will not only enable the film industry to
produce the highest quality audio tracks for film, but will also
allow theatre's to upgrade their existing sound system at a
minimal cost.
To introduce this revolutionary new sound, Bongiovi is in the
process of producing a film entitled "Mutant Mania", which is a
science fiction action horror film, shot in a small ocean resort
town in New Jersey. This film has many elements that make it
perfect for the introduction of PSDMS. The most prevalent of
these being the heavy music score by Bongiovi's latest band
"French Lick". Producing bands is definitely one of Bongiovi's
fortes. Bongiovi was instrumental in creating "Bon Jovi" who is
probably the strongest force in the rock and roll circuit today.
"Bon Jovi's" third album "Slippery When Wet", has sold more
copies in a short period of time than any other band in history.
Another is the fact that this is a horror film. The use of audio in
horror films is important to create tension, fear, excitement etc..
Using a horror film also lessens the influence the critics have on
the audience.
By the large this film will stand on it's own merits.
PSDMS, and you have a potential block buster event.
Now add
exhibition.
Inside every video tape that is sold, a coupon may be placed to
promote Sony products.
A full line of quality equipment may be SONY/POWER STATION
labeled for consumer use to enhance marketability of Sony
entertainment products.
Sony Video Software Corporation will receive right of first refusal
on all contracts for video and theatrical distribution. We will
allow Sony a preferred 5% margin under any other distributor for
a competitive edge.
TIMING
Timing is crucial in a project that touch so many different areas.
MARKETING AND DISTRIBUTION
Most of the industry by their own admission is at least two years
away from an effort to upgrade the sound in movie theatres.
With the SONY/PSDMS system, other companies may adapt
easily and economically to produce products with digital movie
sound. With companies adapting to this process, the future
should see the prominence of the SONY/PSDMS insignia much
the same as you see the Dolby insignia today. This will act as
a constant reminder to the public that Sony truly is a pioneer of
advanced audio visual technologies.
Sony will receive exposure in the professional market place by
having the SONY/POWER STATION equipment used in theatres
and studios to produce the SONY/PSDMS sound.
The video industry is a 56 billion dollar industry that is in need
of product. When you look at the potential for a product that
will be one of the first feature films to compliment the fast paced
VCR/Stereo Entertainment components, with a musical score
that may have enough merits of its own, you have an amazing
potential for distribution.
The Digital and Disc Industry has proven to be the future
standard for recording and playing. Because of the relative
newness of the digital format, there are more people who have
yet to experience the digital sound. With the high exposure that
will come from this project, this could be the first time ever
people hear digital. How many people? 1 - 10 - 50 - 100
million?
What will be their first reaction?
Who's name will they think of first?
PRODUCT DEVELOPMENT
Bongiovi and Evans at Power Station have developed a
revolutionary hybrid mixing console to penetrate the video post
Stan Caterbone left the conference early in order to meet with Marcia
Silen, one of the producers for Flatbush Films. Stan Caterbone had
disclosed the original draft for the SONY joint venture proposal.
Stan Caterbone and Marcia Silen collaborated on the proposal and
Marcia Silen said "Stan, you are a genius".
Stan Caterbone also visited with Becky Austin, Marcia Silen's sister, and
discussed the mortgage banking business. Becky Austin was a paralegal for
one of the more active law firms specializing in Real Estate in Beverly
Hills. Becky and Stan discussed a strategic alliance that would result in
the development of an office in Beverly Hills for the loan portfolio of
Institutional Investors. Al Dannatt was consulted, and a future meeting
between Stan Caterbone, Becky Austin, and Al Dannatt was agreed upon either
in Houston, Texas, or Beverly Hills, CA. Becky Austin was very experienced
in the Beverly Hills real estate business, and had a great of connections
that would have been required to pursue such a business.
Marcia Silen had tried to schedule a meeting between Ted Gamillion of
Gamillion Studios, and Stan Caterbone, however schedules were not
permitting. The meeting would later take place on July 21, 1987.
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TI=\DIGITAL MOVIE LETTER OF INTENT
IM=073P01.CPR
DA= May 19, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
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SU= SUMMARY: Letter of Intent for Joint Venture Participation and
contribution for the "Digital" movie. Norris Boyd of
Boyd Wilson, shareholder and client of FMG, and owner of
Olde Hickory Properties, to which Stan Caterbone had
produced a $5,000,000 loan, of which Noris Boyd had
specifically noted that the terms were better than those
of Commonwealth National Bank, which was holding the
existing paper, which totaled more than 12,000,000, of
whom repossess Stan Caterbone's plane, 15 days before any
monies due, had agreed to invest in the movie.
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TI=\W. UMIKER ESTATE PLANNING
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DA= May 28, 1987
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SU= SUMMARY: Letter to Dore Valvanes regarding the Power of
Attorney of Dr. William Umiker.
DI= ************************************************************
TI=\FLATBUSH FILM DRAFT SCREENPLAY OF DIGITAL MOVIE
IM=323.CPR
DA= May 29, 1987
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PA= PAGES:
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TI=\BUSINESS WEEK
IM=331.CPR
DA= June 1, 1987
AT= AUDIO TRACKS:
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SU= SUMMARY:
"SONY'S CHALLENGE"
04/05/08/09
produced
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DA= June 13, 1987
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SU= SUMMARY: Documents are in part of application for a line of
credit to Farmers First Bank, by Stan Caterbone. Pete Richter
of Farmers First was handling the loan application. Stan
Caterbone had applied for a line of credit, pledging his
stock in Financial Management Group, Ltd. for collateral.
However Michael Hartlett refused to provide any financial
information of Financial Management Group, Ltd., to either
Farmers First, or to Stan Caterbone, which according to
the bylaws and the articles of incorporation is in
violation of shareholder rights to inspect the books!
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TI=\WEINSTEIN DEVELOPMENT REQUEST FOR FINANCING
IM=088P01.CPR
DA= June 15, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
1
SU= SUMMARY: Letter from Susan Weinstien, of Tenefly NJ requesting
financing of both debt and equity for real estate project
in the rapidly growing Hunterdon County, New Jersey,
which is in the I-78 Corridor outside New York City.
Susan was referred by Tony Bongiovi and Bob Walters.
DI= ************************************************************
TI=\PLANNERS SECURITIES -- FMG, Ltd., ACQUISITION
IM=089P01.CPR
DA= June 18, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
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SU= SUMMARY: Planner Schedule outlining trip to Atlanta in Stan
Caterbone's plane with Randy Grespin of (TUG) The
Underwriters Group to propose deal with the Broker
Dealer of William Koegler, The Planners Security Group.
TUG was paying $250 per hour for 1/2 of trip. Stan
Caterbone recommended that FMG, Ltd., to a deal with
the Planners Group, instead of Hibbard Brown.
When
Stan Caterbone arrived back in Lancaster, Robert Kauffman
demanded an explanation as to "Who is running this show?"
Stan said "I don't care who, as long as its done right!"
DI= ************************************************************
TI=\FMG, Ltd., PATENT RESEARCH
IM=090P01.CPR
DA= June 22, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
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SU= SUMMARY: Letter from Joel Goldhammer of Seidel, Gonda,
Goldhammer, & Abbott, P.C., of Philadelphia to Stan Caterbone
IM=090P02.CPR
DI= PAGE 02
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TI=\UMIKER MEMO
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DA= June 22, 1987
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PA= PAGES:
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He went
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DA= June 29, 1987
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PA= PAGES:
1
SU= SUMMARY: A letter from Chuck Smith of Lancaster Aviation to
Stan Caterbone, demanding payment for the repairs of the
previous invoice, fuel, and pilot services. More
importantly, Chuck Smith acknowledges that he as
taken the liberty of repossessing the aircraft, which was
why Jim Bly of Source Capital was unable lease the plane
from Stan Caterbone. However Stan Caterbone had an
unsecured line of credit with Lancaster Aviation, and
had no financial interest in the aircraft at the time of
repossession. He also verifies that the plane is insured.
DI= ************************************************************
TI=\JUNE PLANNER SCHEDULE OF S. CATERBONE
IM=099P01.CPR
DA= June 29, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Stan Caterbone has a meeting at the headquarters
of Bennett Williams, of York PA, with Dave Schadd and
Bob Buehler. Stan Caterbone was about an hour late
for the meeting, and arrived at about 12:00pm. Stan
Caterbone had discussed the pending real estate deal and
specifically the interest of Dave Cook. Stan Caterbone
also discussed the seriousness of his partners recent
actions, specifically the break-in of his office. Bob
Kuaffman had made previous arrangements to sit in on
meeting, uninvited, and without Stan Caterbone's invite!
DI= ************************************************************
TI=\W. UMIKER CHECK TO LANCASTER AVIATION
IM=100P01.CPR
DA= June 29, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A copy of the check from Dr. William Umiker made
payable to Lancaster Aviation in the amount of $25,000. After
Chuck Smith had knowingly deposited a post dated check
from Stan Caterbone that did not have sufficient funds,
Stan Caterbone had called Dr. William Umiker to loan the
funds until the monies were received from Keystone
Mutual Funds, in the account of Millard Johnson. Dr.
Umiker was repaid the following day, when the funds were
received from Keystone, as expected. This was another
attempt by Chuck Smith to discredit Stan Caterbone.
DI= ************************************************************
TI=\SUBPOENA FOR S. CATERBONE IN CASE VS. H. FISCHER
IM=101P01.CPR
DA= June 30, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
SU= SUMMARY: Copies of all cash accounts for Stan Caterbone, that
indicate that on July 1, 1987, Stan Caterbone had cash
balances of $15,134.10. This is quite contrary to what
the banks were indicating by their malicious actions
toward both a borrower and competitor.
IM=103P02.CPR
DI= PAGE 02
IM=103P03.CPR
DI= PAGE 03
IM=103P04.CPR
DI= PAGE 04
IM=103P05.CPR
DI= PAGE 05
IM=103P06.CPR
DI= PAGE 06
IM=103P07.CPR
DI= PAGE 07
IM=103P08.CPR
DI= PAGE 08
DI= ************************************************************
TI=\PLANNER SCHEDULE OF S. CATERBONE RE: J. RODA
IM=104P01.CPR
DA= July 2, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: After learning the actions of several FMG, Ltd.,
persons in burglarizing the office of Stanley J. Caterbone,
Executive Vice President, Secretary, Incorporator, and
Tenant, of Financial Management Group, Ltd,. and
President, Incorporator, and Secretary of FMG Advisory,
and President, Incorporator, and Owner of Pro Financial
Group, Ltd., and Proprietor of Creative Finance, and
General Partner of Power Productions I, Stan Caterbone
had the fiduciary obligation and responsibility to
preserve and protect the interests of the above entities.
DI= ************************************************************
TI=\ROMAR AVIATION
IM=105P01.CPR
DA= July 2, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
3
SU= SUMMARY: Receipt and cancelled check drawn on Fulton Bank,
from Romar Aviation, confirming payment for pilot, gas, and
insurance. Stan Caterbone had decided that it would be in the best
interest of all concerned to move his files to Stone
Harbor NJ, where he could begin to inspect the records of
all of the companies that were headquarter at the
1755 Oregon Pike, Lancaster PA. However, the airplane
was conveniently repossessed with all documents held as
hostage. Stan Caterbone had instructed Romar Aviation to
store the aircraft on their premisses, because of all the
games that Lancaster Aviation, of which Stan Caterbone
IM=117P02.CPR
DI= PAGE 02
IM=117P03.CPR
DI= PAGE 03
IM=117P04.CPR
DI= PAGE 04
IM=117P05.CPR
DI= PAGE 05
IM=117P06.CPR
DI= PAGE 06
DI= ************************************************************
TI=\SOLFOLK LIBRARY RESEARCH MATERIALS RE:LENDER LIABILITY
IM=118P01.CPR
DA= July 15, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
6
SU= SUMMARY: On July 14, Stan Caterbone and Michelle Hodge, personal
friend, and one of few persons to believe Stan Caterbone
traveled to Boston, MA. Stan Caterbone had decided that
Boston would offer one of the better Law Libraries for
research, and would provide for a nice trip to get away
from all of the conspiracy going on. Stan Caterbone had
conducted research on the topic of lender liability, and
specifically the circumstances which constitute fair
play, illegal repossession, and anti trust with specific
his mortgage banking business. Enclosed are samples.
IM=118P02.CPR
DI= PAGE 02
IM=118P03.CPR
DI= PAGE 03
IM=118P04.CPR
DI= PAGE 04
IM=118P05.CPR
DI= PAGE 05
IM=118P06.CPR
DI= PAGE 06
DI= ************************************************************
TI=\KUAFFMAN LETTER TO BILL JOHNSON RE: S. CATERBONE
IM=119P01.CPR
DA= July 16, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Robert Kauffman had sent a letter to Millard Johnson,
as well as all of the clients of Stan Caterbone. Robert
Kuaffman had alleged that Stan Caterbone will not be
servicing Financial Management Group, Ltd., clients in
the Lancaster area, and "may not handle investments
at all". Robert Kauffman had also reported that Stan
Caterbone had moved his office to Stone Harbor, NJ.
Stan Caterbone has yet to learn motivation for such
incriminating statements, that could be construed as
freud in and of themselves.
DI= ************************************************************
TI=\TITLE:
SOURCE CAPITAL LETTER RE: BENNET WILLIAM SYNDICATION
IM=129P01.CPR
DA= July 24, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
10
SU= SUMMARY: A letter to Jim Bly, of Source Capital, of McLean VA
from Stan Caterbone along with the syndication deal for
the Bennett Williams project. Dave Cook and previously
expressed interest in the project, however a few days
prior, Dave Cook had informed Stan Caterbone that it
"would be better if I did not associate with you". Stan
Caterbone was about all out of business contacts that
were not convinced that he embezzled monies and was
insane.
IM=129P02.CPR
DI= PAGE 02
IM=129P03.CPR
DI= PAGE 03
IM=129P04.CPR
DI= PAGE 04
IM=129P05.CPR
DI= PAGE 05
IM=129P06.CPR
DI= PAGE 06
IM=129P07.CPR
DI= PAGE 07
IM=129P08.CPR
DI= PAGE 08
IM=129P09.CPR
DI= PAGE 09
IM=129P10.CPR
DI= PAGE 10
DI= ************************************************************
TI=\HARTLETT LETTER TO CREDITORS RE: S. CATERBONE
IM=130P01.CPR
DA= July 24, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Letter from Michael Hartlett, Executive Vice President
of FMG, Ltd., to Oblenders, of Lancaster PA informing
Oblenders that "Stanley J. Caterbone is no longer an
officer of our corporation." "He was removed as
Executive Vice President on July 1, 1987". "This letter
serves notice that Stanley J. Caterbone never has had the
right to: 1) Purchase items for or through FMG.
2) Make Corporate commitments on behalf of FMG
3) Contract for or any way obligate FMG Ltd."
A third grader would be smarter than this.
DI= ************************************************************
TI=\SHIRK LETTER RE: BANKRUPTCY MATERIALS
IM=131P01.CPR
DA= August 5, 1987
IM=CR2.CPR
DI= PAGE 2
IM=CR3.CPR
DI= PAGE 3
IM=CR4.CPR
DI= PAGE 4
DI= ************************************************************
TI=\MMPI EVALUATION
IM=135P01.CPR
DA= August 7, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
8
IM=137P02.CPR
DI= PAGE 02
DI= ************************************************************
TI=\TITLE:
KAUFFMAN LETTER TO S. CATERBONE RE: SHUT-OUT
IM=137P01.CPR
DA= August 10, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
DI= PAGE 02
DI= ************************************************************
TI=\BILL JOHNSON DEMAND NOTE WITH S. CATERBONE
IM=142P01.CPR
DA= August 21, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A copy of the Confession of Judgement for the note
of $25,000 with Bill Johnson for the loan to Stan Caterbone
for the purchase of the aircraft. This note was paid in
full by July 31, 1988 by Stan Catebone.
DI= ************************************************************
TI=\KAUFFMAN LETTER RE: PATTERSON GUARDIANSHIP
IM=143P01.CPR
DA= August 24, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A letter from Robert Kauffman to Millard Johnson
a message that Bill Jonson had left for Robert Kauffman.
Robert Kauffman had earlier tried to persuade Bill
Johnson to provide testimony that the $25,000 that
Bill Johnson had loaned to Stan Caterbone, was
actually monies that Bill Johnson had given to Stan
Caterbone to invest, and Stan Caterbone had actually
embezzled the monies. Bill Johnson almost threw Robert
Kuaffman through the window. Robert Kauffman then told
Bill Johnson that FMG was responsible for the debt.
DI= ************************************************************
TI=\LEGAL ISSUES PERCEIVED BY S. CATERBONE
IM=144P01.CPR
DA= August 25, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
14
SU= SUMMARY: Stan Caterbone had formalized legal actions against
all those that were obvious members of the conspiracy.
Notice should be taken that persons from FMG, Ltd, and
the banks have completely diverted attention away from
James Guerin and ISC.
IM=144P02.CPR
DI= PAGE 02
IM=144P03.CPR
DI= PAGE 03
IM=144P04.CPR
DI= PAGE 04
IM=144P05.CPR
DI= PAGE 05
IM=144P06.CPR
DI= PAGE 06
IM=144P07.CPR
DI= PAGE 07
IM=144P08.CPR
DI= PAGE 08
IM=144P09.CPR
DI= PAGE 09
IM=144P10.CPR
DI= PAGE 10
IM=144P11.CPR
DI= PAGE 11
IM=144P12.CPR
DI= PAGE 12
IM=144P13.CPR
DI= PAGE 13
IM=144P14.CPR
DI= PAGE 14
DI= ************************************************************
TI=\SYDER FUNERAL HOME DEAL WITH SCOTT ROBERTSON
IM=145P01.CPR
DA= August 26, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A contract between Scott Robertson and Stan
Caterbone for the sharing of income received from the account
of the Chip Snyder & Associates Funeral Trust Accounts.
Chip Snyder and his family had recently vacationed in
Avalon, NJ. Chip Snyder was a friend of Stan Caterbone's
and was quite curious as to what was going on. Stan
Caterbone had described the real circumstances and events
and Doreen Snyder had actually begun to throw up after
hearing the truth. Scott Robertson in the middle of
trying to get Chip Snyder to transfer the account to FMG.
DI= ************************************************************
TI=\LETTER TO DIANE SAWYER OF 60 MINUTES BY S. CATERBONE
IM=146P01.CPR
DA= August 28, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A letter to Diane Sawyer from Stan Caterbone in
efforts to receive some kind of help regarding the conspiracy and
blackmail. By this time, all conventional methods of
pleading for help from local, state, federal, and even
legal authorities have been exhausted and have proven
fruitless, not to mention exhausting.
DI= ************************************************************
TI=\FEDERAL EXPRESS INVOICE TO 60 MINUTES
IM=147P01.CPR
DA= August 28, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A Federal Express Invoice to Stan Caterbone
confirming the receipt of a letter delivered overnight to Diane
Sawyer of CBS 60 Minutes, accepted by D. Parker.
DI= ************************************************************
SU= SUMMARY:
TO THEFT" and
AT FIRM" were the reports
Era, and the Lancaster Intelligencer
Family. Articles read as
TIME:
10:00 AM
PLACE:
PERSONS:
<STAN CATERBONE> I still am the minor one <HOWARD EISSLER> yes, the Financial Management
Group -there is about 50 names I am dealing with here
and they are all very similar so I have to be --- Financial
Management Group Ltd. filed for 202B exemption. Now
all the security sold in PA had to be registered. Some
securities are exempt but you have to apply the
detention type of thing. It is a registration, not a
registration that __________ so the 203D exemption was
filed for. Of course we have added the security
statement - explanation of where the money is going to
be spent, how it is going to be run, who runs the
corporation and all that sort of thing. Now under the
umbrella of this Financial Management Group there is a
whole (now I am repeating what is in the 203D which I
spent some time Friday reading) - there is about 15, 14 I guess under that there is about 5 other corporations
which are going to be an insurance agency, an
investment advising agency, a group <STAN CATERBONE> now a lot of these things have
not come about. Well we simplified it.
<HOWARD EISSLER> What do you mean simplified it?
<STAN CATERBONE> They are operating but because
of the accounting procedures they would have been a
There is a report
<STAN CATERBONE> Right, that's what is coming up <HOWARD EISSLER> to explain how much money was
raised and where it was spent with the idea then of
protecting investors. The idea of the _________ your are
limited to like 35 investors. You can't sell to 105 - you
Is
The
manager in IDS.
of religious
find this guy
find FMG
<HOWARD EISSLER> Is that what they are going after in the form of loans?
<STAN CATERBONE> Yes.
He
offering memorandum.
<HOWARD EISSLER> Maybe this is why the 203D they're dragging their feet on this.
<STAN CATERBONE> They don't know what to do. I
did all that legal work; they don't know how to do it.
<HOWARD EISSLER>This offering memorandum we
are talking about - I just copied this. This is just happens
to be page 9 and 10 because the type of information that
is in it. That is the only thing we do not have a copy
here of. Well, we have a copy in the office if you need
one. It is public information; there is no problem with it.
<STAN CATERBONE> So are the books public - I got
thrown in jail for trying to get them.
<HOWARD EISSLER> Well, we will try to resolve this;
it is not going to happen overnight.
Who is Kauffman connected with here.
<STAN CATERBONE> He called up everybody I know
and told them I left the company; told them I was
stealing money from clients; told them I was mentally
insane. I was doing business everywhere. I was doing
business with the Japanese; I was doing business with
the President of Sony; I was doing business with High
at New York, Boston, Houston. Everybody all over the
country heard that I was insane. Everybody.
I've been 4 months without money. I haven't paid a bill since June
30. What do I do? No one believes me. I tried going to
the unemployment office. Do you know what they did?
When I was in the hospital, that was over $3,000. They
called up the insurance carried and told them to
terminate me - my hospitalization. I have nothing. The
only thing I have is what is in this house.
Well, Kauffman comes up here from Atlanta, and he's a
born-again Christian, so he comes together with a group
up here somehow. You see, he's hiring born-again
people... Jehovah Witnesses. Hartlett is a Jehovah.
There were more Jehovah Witnesses than there was
anybody.
<HOWARD EISSLER> But Hartlett was somebody you
brought in though, wasn't he?
<STAN CATERBONE> Well, what happened was I put
everything together. But would it not be right to say that
Hartlett would be your person as opposed to Kauffman's
person. Well, it is those two against me. They are the
two that are trying to take the company from me. See,
I controlled everything. Everyone went with what I said
because I did things that were right for business and
do. All they did, was send me bills. I didn't even want
to send a letter to everyone explaining the situation until
I got a competent legal counsel to tell me what is right,
what is wrong, and what to do. I went to 3 attorneys and
they tell me there is no violation - and I'm in jail for 5
days for what they did to me 3 months previous.
<ROBERT BEYER> Even according to FMG, Stan was
with the company until July 1,
<HOWARD EISSLER> is that right?
_________________
<ROBERT BEYER> Here are 2 certificates, June 25th,
signed by Bob Long, Secretary.
<STAN CATERBONE> I was the Secretary, I was a
Board Member. And, this is April 24th, 1987 SemiAnnual Report in which someone - forged my name. I
never even saw that. They never even had an Annual
Shareholder's Meeting; they never let people examine
the books that have wanted to.
<HOWARD EISSLER> Of course, all of this would boil
down to their getting money from somewhere, extracting
money. Either they are cheating somebody and putting
it in their pockets or taking exorbitant salaries - is
business that good that it could stand that?
<STAN CATERBONE> We are paced to do $4,000,000
GCI (Gross Commission Income) a year, that's a lot of
money passing through your hands.
<HOWARD EISSLER> Now the people that are
____________, doesn't it affect those people?
skeptical of what's happening?
Are they
If you are no
I can't get at
42,000 shares. Stock certificates wouldn't _____________ In June of 1987, he bought 2,000 shares
of stock. Now the signature that is forged on yours is
the secretary. It should have been yours, but there is
nothing wrong with the certificate as such - aside from
the secretary signing the certificate?
<STAN CATERBONE> There is something shady about
that stock deal too. You see this is a year, not quite a
year.
<HOWARD EISSLER> Would this be part of the of 203
offering?
<STAN CATERBONE> Yes, everything is.
part of the 203D.
All stock is
I was
Atlanta?
<STAN CATERBONE> No, this is now. That's why they
wanted him to liquidate his mutual funds so he could
manage it for him.
<HOWARD EISSLER> They wanted you to liquidate
your mutual funds?
<BILL JOHNSON> I told him that I was a little unhappy
with the performance of the mutual funds that I had; he
wanted me to liquidate it and go into the stock market
and let him work it for me.
<HOWARD EISSLER> He was going to act as your
financial planner?
<BILL JOHNSON> I would imagine, yea, broker, buy
and sell stock.
<HOWARD EISSLER> Have they acted as financial
planners? - Now there license has not been approved
yet. Is the one that you <STAN CATERBONE> there is over $100,000 of our RIA
fees that they have collected last year - illegally.
<HOWARD EISSLER> Did you say RIA?
Investment Advisor.
Registered
Who is registered
He
Advisory.
<HOWARD EISSLER> O.K., now wait a minute - let me
see, FMG Advisory comes in yet.
<STAN CATERBONE> They threw me out of the
Financial Management Group; they never mentioned
FMG Advisory which I was President of.
<HOWARD EISSLER> Is this the one that applied to oh, alright, you're using the initials FMG, that's Financial
Management Group?
<STAN CATERBONE> Right.
it would be consistent.
I set up an umbrella so
I have a
Right there,
<STAN CATERBONE> I'll tell you what it takes. ----that's exactly right, but they didn't have a Board of
Directors Meeting. No, the shareholders must vote on
the Board. Shareholders must vote and approve, and
shareholders must exempt people on the Board.
Shareholders have to vote to remove someone from the
Board. Yes, but the Board of Director would be elected
for a year to two years, whatever the situation would be.
So that corporate officer would be there for that entire
period. The three of us were elected to the board for a
period of 3-5 years. The initial Board members -this was
one of Kauffman's move to gain control over a one-year
term. Me, Kauffman, and Hartlett were 3-5 year terms.
<HOWARD EISSLER> When did that take place?
<STAN CATERBONE> We did that back in June of 86
when we started the company.
<HOWARD EISSLER> Your only connection with the
company now is the fact that?
<STAN CATERBONE> I have no connection. They will
not let me - and I have personal belongings in that office,
and they owe me money.
<HOWARD EISSLER> That is something that you two
are going to iron out. See, my involvement is criminal
charges - that's how I am involved. And my involvement
is going to be the mishandling of investor's money.
Well, all of these other financial management groups are
100% stock holders - FMG Advisory Inc - 100%
stockholders?
<STAN CATERBONE> Yea, what it is, the shareholders
own Financial Management Limited; Financial
Management Limited owns all the other subs.
<HOWARD EISSLER> O.K., 100% - there is no other
involvement?
<STAN CATERBONE> That's right.
<HOWARD EISSLER> Financial Management Group's
Semi Annual Report - I think there would be some
financial information <STAN CATERBONE> that's right, they won't give it to
anybody - not even me.
<HOWARD EISSLER> You had mentioned that there
are offices throughout the country. How are those
people connected here?
<STAN CATERBONE> Shareholders and they are
They
at local banks.
<BILL JOHNSON> I have the utmost confidence in
Stan. Mr. Kauffman tried extremely hard to shake that
confidence.
<STAN CATERBONE> He tried to shake up my own
family. He had my own family believing. Do you want
to know something. In August, I was on my way to
Hollywood to the film studio and to see some legal
clients I was working with one day - that night I come
back to my house to get a night's rest. I get thrown in jail.
I go to the police station to get a restraining order
against my family that didn't understand what was going
on - I get retained in the police station for two hours, get
taken to a hospital. That day, someone called the Stone
Harbor police and said I had a gun and was running to
the beach to kill myself. This thing is ugly.
<BILL JOHNSON> As a matter of fact, I would believe
I am the only one left to believe Stan is still sane. Well,
I caught on real quick. I don't believe he had anyone to
talk to except me.
<STAN CATERBONE> I didn't. I could talk to him every
other day since April; someone had to believe what was
going on. I have tapes - I have a tape of Bob Kauffman
July 3 telling a, supposedly client of mine - it was actually
my brother - that I was mentally ill, spending money that
I shouldn't been, and wasn't taking care of my clients.
<BILL JOHNSON> He told me the same thing. - that
Stan had wasted away somewhere between $45,000 and
$70,000 of his own money, just throwing it away on
frivolous things.
<STAN CATERBONE> Every minute I have ever spent
and every dollar I have ever spent, I've made money on
anything. I got my brothers in pro football - held my own
free agent camp. And, they were both picked up last
week, as a matter of fact. I was involved in that too.
Right there.
<HOWARD EISSLER> I thought I heard - is he
connected with the Eagles?
<STAN CATERBONE> Eagles and Dolphins.
<HOWARD EISSLER> I just heard it on the news - one
of those things - I heard the name mentioned, it is not
that common a name, and I heard the name mentioned
in the newscast of the NFL strike and it was like - what
was that, but it was too late. That Thursday, right after
I called you, was when I got the call.
<BILL JOHNSON> Stan held his own free agent camp
<ROBERT BEYER> Chemcon is the big local minorityheld corporation that was doing a lot of defense
contracts - it was associated with ISC. They went under
last Spring, beginning of the summer, and there was a
lot of criminal allegations made, none of them
substantiated.
<STAN CATERBONE> And I was connected with that.
They sent a Board Member in to see me a week before
this happened. Why, I don't know.
<HOWARD EISSLER> Is this Lancaster based.
<STAN CATERBONE> Yes, Jim Christian owned it now I hear rumors that I was tied to ISC and I am close
to several people in that organization. Why they sent
someone to California to see me, I don't know. They
won't answer me.
<HOWARD EISSLER>
ISC
___________,
He is really
to give me.
Yea, well they mentioned the things that you had taken,
a couple of items, that they had given back and allowed
you to have them. They gave all the files back to FMG
before we were involved and then he gave me the
personal correspondences, but they kept his camera.
Apparently, Stan was doing the policeman's work when
he was in there the night he was accused of burglarizing
the place. He took pictures of all his files in their office
and they said they had better keep that.
<STAN CATERBONE> This is June 30th. It is my files
in their office. That's the night I left.
<HOWARD EISSLER> Who's taking the pictures?
<STAN CATERBONE> A friend of mine.
<HOWARD EISSLER> You were with someone? This
was 3 o'clock in the morning. Oh, you weren't arrested
on the premises, were you?
<STAN CATERBONE> No, but this is when I was in the
office. This is when they stole my files out of my locked
doors.
<ROBERT BEYER> He was arrested September 3rd I
believe it was <STAN CATERBONE> this is June 30th.
<ROBERT BEYER> They don't know he was in there
then, I guess.
<HOWARD EISSLER> These aren't the films that you
are talking about?
<STAN CATERBONE> No, the films he is talking about
I took of my files again in their office, and attorneys say
they didn't do anything wrong - explain why I was in jail
for 5 days.
This is the stock certificate book here,
<HOWARD EISSLER> this big black book?
<STAN CATERBONE> Yea.
<HOWARD EISSLER> You are still connected with the
company here?
<STAN CATERBONE> This is June 30th. The funny
thing is, even the second one is not breaking in - well,
the girl left me in and she's a friend of mine.
<ROBERT BEYER> He is still President and at the time
_____________
I didn't
I took
It happened
scared because I
officer of that corporation.
was going on, I was scared.
in all --------------END
IM=159P11.CPR
DI= PAGE 11
IM=159P12.CPR
DI= PAGE 12
IM=159P13.CPR
DI= PAGE 13
IM=159P14.CPR
DI= PAGE 14
IM=159P15.CPR
DI= PAGE 15
IM=159P16.CPR
DI= PAGE 16
IM=159P17.CPR
DI= PAGE 17
IM=159P18.CPR
DI= PAGE 18
IM=159P19.CPR
DI= PAGE 19
IM=159P20.CPR
DI= PAGE 20
IM=159P21.CPR
DI= PAGE 21
IM=159P22.CPR
DI= PAGE 22
IM=159P23.CPR
DI= PAGE 23
IM=159P24.CPR
DI= PAGE 24
IM=159P25.CPR
DI= PAGE 25
IM=159P26.CPR
DI= PAGE 26
IM=159P27.CPR
DI= PAGE 27
DI= *************************************************************
TI=\RUSSELL, GRUBER & HUBER TRESPASS NOTICE TO S. CATERBONE
IM=160P01.CPR
DA= October 2, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
3
SU= SUMMARY: A trespass notice from Financial Management Group,
Ltd., to Stan Caterbone noticing that Stan Caterbone is not
licensed nor privledged to enter or remain on the
premisses at Financial Management Group, Ltd., 1755 Oregon
Pike, Eden Park II, Manheim Township, Lancaster,
Pennsylvania, which premisses are the sole and exclusive
property of Financial Management Group, Ltd.,. signed by
attorney Christine Housner for Craig Russell.
IM=160P02.CPR
DI= PAGE 02
IM=160P03.CPR
DI= PAGE 03
DI= ************************************************************
TI=\ATTY. MCDONALD CONFERENCE
IM=161P01.CPR
DA= October 4, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
2
SU= SUMMARY: A copy of actual notes taken by Mike McDonald
during a meeting with Stan Caterbone, at 2323 New Danville Pike,
Conestoga PA, at the request of Stan Caterbone. Stan
Caterbone became suspicious of the lack of aggressive
legal actions taken by attorney Robert Byers concerning
the legal issue of Stan Caterbone's lease agreement,
Unsubstantiated and paperless termination, interests in
companies headquarter at 1755 Oregon Pike, that was the
solely owned by Stan Caterbone, as well as others. Mike
McDonald was of no help either.
IM=161P02.CPR
DI= PAGE 02
DI= *************************************************************
TI=\ARRAIGNMENT FOR MANHEIM TOWNSHIP CRIMINAL CHARGES
IM=162P01.CPR
DA= October 5, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Waiver of Arraignment for the criminal charges of
theft, criminal mischief; and unlawful use of computers.
trial was scheduled for the January, 1988 term.
was scheduled to begin 14 days from November 25, 1987.
Attorney Robert Beyer had filed the document.
DI= ***************************************************************
The
18
19
PAGE
1
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PAGE
1
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INDEX TO WITNESSES
DIRECT CROSS REDIRECT
6
20
30
34
41
50
54
57
58
60
66
68
70
71
72
WITNESS
STACY LYNN WATERS
ROBERT E. KAUFFMAN
DANIEL ANTHONY BERGER
LARRY G. MATHIAS
JUNE KEMPER
LARRY C. SIEGLER
RECROSS
3l
l
51
7l
P R 0 C E E D I N G S
MR. BEYER: Good afternoon, Your honor.
THE DISTRICT JUSTICE: Good afternoon. We
have two Criminal Complaints charging the Defendant
Stanley J. Caterbone, here at the moment.
The charges were read at this time.
DETECTIVE MATHIAS: I understand Detective
Siegler, he is enroute.
THE DISTRICT JUSTICE: we can't proceed on
that until he is here, but we certainly can proceed on
the other. Do you have a copy of both charges?
MR. BEYER: Yes. I want to bring something to
both your attention in case I misheard it. When you
were referring to the first Complaint I think you said
it was your number 202. I don't have a number on the
first Complaint but my second complaint says 202. I
want it so we are straight.
THE DISTRICT JUSTICE: They all have the same
number.
MR. BEYER: Okay.
THE DISTRICT JUSTICE: All right. Do you have
a copy of the one filed by Detective Mathias?
MR. BEYER: Yes. And I waive that reading,
Your Honor.
THE DISTRICT JUSTICE: All right. Who is our
PAGE 4
1
2
3
4
5
6
7
8
9
10
11
12
first witness?
DETECTIVE MATHIAS: First, Your Honor, we
would like to dismiss the robbery charge. In consulting
with the District Attorney's Office, I was directed that
that would be the proper thing to do in this case.
THE DISTRICT JUSTICE: In other words, you're
going to withdraw the robbery?
DETECTIVE MATHIAS: Correct.
THE District JUSTICE: And not pursue that.
Cross it off, everyone on their Complaint. And who is
the District Attorney who authorized that?
DETECTIVE MATHIAS: District Attorney Totaro.
13
14
15
l6
17
18
19
20
21
22
23
24
25
they?
PAGE 5
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l6
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24
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PAGE 6
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Q
A
Q
A
Q
A
Q
A
Q
A
Q
A
couldn,t
It was Stan Caterbone?
Stan Caterbone.
Is Stan Caterbone known to you?
yes.
Is that person in the courtroom now?
Yes.
Would you point to that person?
Pointing.
That would be the person seated next to
counsel?
Yes.
Okay. How long have you known Mr. Caterbone?
About a year-and-a-half.
15
16
17
18
19
20
21
22
23
24
25
Q
A
Q
A
Q
A
PAGE 7
1
He went into Mike Hartlett's -2
Q
Mike Hartlett?
3
A
His office.
4
Q
As a result of what happened that night with
5
Mr. Caterbone, were the police called? As an end result
6
of that happened, whatever you're going to tell us right
7
now, were the police notified?
8
A
Yes.
9
Q
Okay. Did you provide the police with a
10
statement?
11
A
Yes.
12
THE DISTRICT JUSTIcE: can you say when were
13
the police notified? Like a year later
Or that very
14
night? Or do you know when?
15
A
I didn't notify the police
16
BY DETECTIVE MATHIAS:
17
Q
They were notified within an hour or two of
18
what you are talking about now?
19
A
Yes.
20
DETECTIVE MATHIAS: Okay. The reason I'm
21
asking, Your Honor, is she provided a statement and I
22
think it is a very complicated case and I would like to
23
introduce her statement so she has it with her.
24
THE DISTRICT JUSTICE: The police were
25
notified almost immediately then, is what you are
PAGE 8
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
saying?
DETECTIVE MATHIAS: The police were notified
within a reasonable time frame of the crime.
THE DISTRICT JUSTICE: Now she stopped that
Stan went into Mike's office.
DETECTIVE MATHIAS: Right. She supplied us
with a statement. I have it here. I'd like to have it
there. That's what I'm trying to get at.
THE DISTRIcT JUSTICE: Show it to him. Do you
have a copy?
MR. BEYER: I don't have a copy. I think the
proper way would be for her to be able to refresh her
recollection with this statement, but I don't believe
she could sit there and read from it.
DETECTIVE MATHIAS: She already has reviewed
it. I think she would like to have it with her in case
there is something about dates or times, et cetera. It
18
19
20
21
22
23
24
25
PAGE 9
1
to the witness.
2
DETECTIVE MATHIAS: 0kay.
3
BY DETECTIVE MATHIAS
4
Is this the statement that you given to
5
the police and to me, as a matter of fact, on the date
6
of this incident?
7
A
Yes.
8
Q
I want you to have that so you have it there
9
with you for your reference if you need it. Now would
10
you continue. What happened that evening, if you can
11
explain?
12
A
0kay. Then he had a screwdriver. He pried
13
open Mr. Hartlett's desk.
14
Q
When Stan came to the building you said you
15
left Stan Caterbone into the building?
16
A
Yes.
17
Q
And then you said he went into someone else's
18
office? Or some office?
19
A
Yes.
20
Q
How did he get into that office?
21
A
It was open.
22
Q
Okay. At any time did he go into any offices
23
that weren't open that he had no right to be in?
24
A
None that were not open.
25
Q
Did he go into any offices that were locked?
PAGE 10
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
A
Q
A
Q
A
Q
A
Q
A
Q
No.
At any time did he go in?
To the basement, but that was the only one
that had to be unlocked. The hallway that we were in
was locked.
I see. How did he get into the hallway?
I had the keys and he got them out of your
hands and unlocked it.
He took the keys from you*
Yes.
You didn't give them to him?
No.
If he would have asked you for the keys,
would you have given in?
MR. BEYER: I object. That's speculative.
DETECTIVE MATHIAS: Okay.
THE DISTRICT JUSTICE: Somebody is going to
ask the question. Did he forcibly take them from you
Yes.
THE DISTRICT JUSTICE: Go ahead.
21
22
23
24
25
BY DETECTIVE MATHIAS:
Q
After he took the keys from you?
A
Yes.
Q
What happened?
A
Then we went -- well, we walked around and he
PAGE 11
1
showed me some things that he had in a bag, papers.
2
Q
What were they that he showed you?
3
A
That he had in a bag with him.
4
Q
That he had with him?
5
A
Yes.
We went into an office, he showed me
6
these things.
They were papers of charges that he had
7
against Financial Management Group and I don't remember
8
the other things.
And then we went to Mr. Hartlett's
9
room -- office.
10
Q
Explain if you can -- what we want you to
11
understand, see, some if the people here don't have any
12
idea what happened that evening at all and we are trying
13
to explain the story to them so they understand that
14
happened.
15
A
Okay .
16
Q
Okay .
Now he went into Mr. Hartlett's
17
office?
18
A
Yes.
19
Q
That happened there?
20
A
Then he took out a screwdriver and he pried
21
open the desk and started taking files out.
22
Q
He did?
23
A
Yes.
24
Q
Did he remove an thin
from those desks?
25
A
The files.
PAGE 12
1
Q
What happened to those files?
What did he do
2
with those files?
3
A
He carried them with him as we went to
4
another office and then we took the files out to the car.
5
car.
6
Q
Okay.
You're saying he took the files to his
6
vehicle,
7
his car?
8
A
Yes.
9
THE DISTRIcT JUSTICE: He or We?
10
A
He.
I was with him but, I mean, he carried
11
the stuff.
I was with him the whole time.
12
THE DISTRICT JUSTICE: You went out to his
13
car?
14
A
Yes.
He had me -- he had my arm.
15
BY DETECTIVE MATHIAS:
16
Q
What do you mean?
He forced you to go with
him?
17
him.
18
MR. BEYER:
I object to the form of the
19
question.
20
THE DISTRICT JUSTICE: Well, just tell the
21
young lady to tell us exactly what happened.
22
23
24
25
DETECTIVE MATHIAS:
Yes.
BY DETECTIVE MATHIAS:
Q
You said you went to the car with him?
A
Yes.
PAGE 13
1
Q
Why did you go to the car with him?
2
A
Because we didn't
o to the car right
3
Mr. Hartlett's office.
First we went to Mr. Kauffman's
4
office.
He took pictures of some files and took
5
more files.
We went into the computer room. He took a
6
disk.
And when I went to use the phone
then he took
7
my arm 'cause he didn't want me to call anyone.
Then he
8
had me with him the rest of the time and then I
9
accompanied -- was with him when he went out to the car.
10
Q
You said you went to call someone
11
A
Yes.
The police.
12
Q
Why were you going to call the police?
13
A
Because, I mean, I was told that he was not
14
to be in there.
And he was taking files.
15
Q
What happened then?
16
A
Then he came out and he took me by the arm
17
and took me back to the office with him.
18
Q
He took you back?
If you would have
19
wanted to leave, could you leave?
20
MR. BEYER:
I object to that it's speculative too.
21
THE DISTRICT JUSTICE:
Rephrase it.
22
BY DETECTIVE MATHIAS:
23
Q
Why didn't you leave?
24
A
Why didn't I leave?
Because he had my
25
arm.
PAGE 14
1
Q
And he wouldn't allow you to leave?
Is that
2
what you are saying?
3
A
No.
he didn't want me to go call anyone
4
Q
So, you didn't call the police?
5
A
No
I didn't.
6
Q
What happened then?
7
A
Then, well we had to make two trips out to
8
the car to take files out and then he wanted to go down
9
to the basement and so we went down there and I didn't
10
know I even had a key that unlocked it, but he unlocked
11
it.
Then he ripped out some phone lines. We went back
12
upstairs and we went into the computer room and he
l3
ripped -14
THE DISTRICT JUSTICE:
Did she say cut?
15
A
No. He ripped them out, just ripped them
16
out.
17
THE DISTRICT JUSTICE: You said ripped
18
phone lines?
19
A
Yes.
And we went up to the computer
20
room and he turned the key on the computer. I don't
21
know if it turns it off or what it does. I don't know.
22
And he tore some other things out of the wall there.
22
then we went to another office. He ripped some -- tore
24
some lines out from an ADP machine and then --
25
PAGE 15
1
A
It is what stock brokers use for their
2
quotes.
I don't know what all it does.
3
THE DISTRICT JUSTICE:
Did she say again
4
what he did to that?
5
A
He tore some of the cords out from it.
6
THE DISTRICT JUSTICE:
Electrical cords?
7
A
Yes.
8
THE DISTRICT JUSTICE:
Okay.
9
BY DETECTIVE MATHIAS:
10
Q
While this was going on, while this occurred
11
with Stan Caterbone being in the office areas, were you
12
scared?
13
A
I was scared to a point twice. The first
14
time was in Mr. Kauffman's office and he had my arm and
15
I was just kind of fighting to get away and trying to
16
get him to stop and just to leave. And he just -- he
17
said that I was putting up pretty much of a fight.
He
18
threatened to knock me out.
19
And then the second time was when we went down
20
to the basement and I was scared because it was dark
21
but he said that if he was going to do anything to me he
22
would have done it by then.
23
Q
If you would have wanted to leave?
24
A
Yes.
25
Q
While Mr. Caterbone was going into these
PAGE 16
1
offices, could you have left?
2
A
No.
3
Q
Why?
4
A
Because he had a Hold of my arm. Not always
5
tight, but when I did try to get away, then he did grab
6
it tighter.
It didn't hurt me or anything.
7
Q
So, he held you?
Is that what you are
8
saying ?
9
A
Yes.
10
Q
At what point did you finally get free?
11
A
when he -- when he was leaving
out at his
12
car.
13
Q
Can you explain?
14
A
He had my keys and -- and so he had to give
15
them back but he made me go out with him and then he
16
gave me my keys back and then he made sure got back
17
in the office okay and he left.
18
Q
Is there anything you would like to say about
19
what has happened here that I haven't asked you that you
20
just want to make a comment about this whole story,
21
this whole incident?
22
A
No.
23
DETECTIVE MATHIAS:
One moment.
I have
24
two questions.
25
BY DETECTIVE MATHIAS:
PAGE 17
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10
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12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q
One, you said that you saw him tearing things
out of the phone downstairs?
A
Yes.
Q
You saw this with your own eyes?
A
Yes.
Q
Okay.
And who did that property belong to;
do you know?
A
I don't know. I guess it belongs to whoever
owns the building.
Q
Okay. You said he had taken a disk out of a
computer upstairs.
A
from a file, yes.
Q
Actually removed it from the computer?
A
No.
It was in the file.
Q
What happened to that disk; do you know?
A
H took it with him. I don't know what
happened.
Q
To the car?
A
Yes.
Q
And you said he removed items from disks
in the offices, one of those desks he had actually
opened with a screwdriver.
He took things and he took
them with him as well?
A
Yes.
Q
In his car?
PAGE 18
1
A
Yes.
2
Q
And left.
When he left you to come back in
3
and watched that you safely returned to the building, he
4
actually left with those items?
5
A
Yes.
6
DETECTIVE MATHIAS:
I have no more
questions.
7
THE DISTRICT JUSTICE:
Before you go ahead,
8
clarify something for me.
The Defendant didn't have you
9
by the hand all the time from the moment you let him in
10
the door -11
A
No.
12
THE DISTRICT JUSTICE:
-- until he finally
13
released you outside to go back into the office and
14
assisted out or whatever?
Is there a reason why you
15
didn't walk out the door?
Or call the police?
Or do
16
something?
17
A
Because until that I was just trying to get
18
him -- I wanted him to just leave and I was Just trying
19
to talk him out of taking things.
20
THE DISTRICT JUSTICE:
Go ahead.
21
DETECTIVE MATHIAS:
You do bring up the
poinT.
22
THE DISTRICT JUSTICE:
I wanted clarification
23
here.
Did he have her by the hand all the time?
24
BY DETECTIVE MATHlAS:
25
Q
After Stan grabbed your arm or held your
arm,
PAGE 19
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8
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14
15
16
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18
19
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22
23
24
25
PAGE 20
1
q
At one time you worked for FMG, didn't you?
2
A
Yes.
3
Q
What position did you have at FMG?
4
A
I was a receptionist.
5
Q
When did you start working there?
6
A
July of last year.
7
Q
Of '87?
8
A
Yes.
9
Q
And who hired you ?
10
A
Mike Hartlett.
11
Q
Did you work with Stan there?
12
A
I worked for Stan.
I did some things for
13
him.
14
Q
And you and Stan were pretty good friends,
15
I believe ?
16
A
He talked once in a while.
17
Q
And you went down to the shore to visit him
18
at his house?
19
A
No
I didn't go down
20
him.
I saw him there once.
21
Q
All right.
when did you terminate your
22
employment with Financial Management Group?
23
A
I think July this year, '87.
24
Q
And why did you terminate that employment?
25
A
Because my mom had a cleaning business and
PAGE 21
1
she needed help and I was going to work for her.
2
Q
There was a point when you were told Mr.
3
Caterbone wasn't allowed in that building - is that
4
5
6
7
8
9
10
11
12
13
14
15
l6
17
18
19
20
21
22
23
24
25
accurate?
A
yes.
Q
Who told you that?
A
Mike Hartlett.
Q
Did you know when he was officially removed
as an executive or anything like that? Or you were Just
following Hartlett's orders?
A
Yes.
He told us that he was removed as
executive.
Q
Hartlett told you that?
A
Yes.
Q
All right.
Now
when Stan knocked on
window that evening I think your initial reaction was
you were glad to see him? is that a fair statement?
A
Yes.
Q
And you had never had any trouble with Stan
before that?
A
No.
Q
And when he first came in the door did he
have something with him?
A
I don't remember.
I guess he had the blue
bag.
**
PAGE 22
1
Q
Okay.
He was carrying that with him in his
2
hand?
3
A
Yes.
4
Q
Would it be safe to say that Stan was rather
5
excited that night?
6
A
Yes.
7
Q
And he wanted to show you a lot of things in
8
the building?
9
A
Yes.
10
Q
And he was taking you around from office into
11
office saying, look at these files in this office, look
12
at these files in that office?
13
A
Yes.
14
Q
And, in fact, he told you look, that Kauffman
15
is now in my office and here are all his files.
He
l6
showed you that, didn't he?
17
A
Yes.
18
Q
And, you had also been aware that Kauffman
19
had all the locks changed on his office, didn't you?
20
A
I had thought that Stan had the locks
21
changed.
The outside of the doors, yes, the locks were 22
changed.
23
Q
But, you're aware that before Stan took his
24
business operations to New Jersey that he had the locks
25
changed on his own office?
PAGE 23
1
2
3
4
5
A
Q
A
Q
yes.
But then Kauffman had them rehanged, I
guess right?
Not that I know of.
Okay.
Did you guys go in that office?
6
7
8
9
10
11
12
l3
14
15
l6
17
18
19
20
21
22
23
24
25
A
A
A
Q
A
Q
A
Q
A
Q
A
Q
A
PAGE 24
1
2
3
4
Q
A
Q
5
6
7
8
9
10
11
12
13
14
15
l6
17
18
19
20
21
22
23
24
25
A
Q
A
Q
A
Q
A
Q
A
Q
A
Q
A
about it.
Q
Yes.
Had it been locked?
No.
So, if that door was unlocked it was unlocked
before you got there that evening?
I unlocked it when I got there.
And where did you get your set of keys?
I have them for cleaning for Mr. -- I think
it is Mike.
Stan gave me a key to his door.
Stan gave you a key to his office?
Yes.
All right.
Now, as he is going from office to
office picking up files, what was he doing with them?
Taking them.
Where was he putting them?
He held them in his hands and then Just
Mike's, just Mr. Hartlett's files.
Was he carrying them.
He was carrying them.
Now, he was carrying those and also carrying
his Blue bag.
I don't remember if he had sat it
somewhere or if he had it with him.
Okay.
can you estimate how much he had
taken
from Mr. Hartlett's office in terms of size?
About like that much.
And that's what he was carrying with him?
Yes.
Now, how long do you think Stan was in the
building that day?
It was not quite an hour.
Almost an hour.
You were aware that Stan and the partners in
the business were having a problem between them
you?
Yes.
And you were aware that Stan felt as though
the company had taken many things that belonged to
him
I didn't know what the situation was. I thought
that it had calmed down and that it was pretty
much over by that time.
But you're aware that Stan felt that most of
the stuff in there was his?
I didn't know what -- I mean nobody talks
I didn't know what was going on.
He was saying it that night?
PAGE 25
1
A
That night, yes, he felt
2
his.
3
Q
And your desire was to try
4
taking anything because you didn't thing
5
right?
6
A
I didn't know and I didn't
7
8
9
10
11
12
l3
14
15
l6
17
18
19
20
21
22
23
24
25
Q
A
Q
PAGE 26
1
Q
Okay.
You indicated there were two points
2
when you were kind of scared.
3
A
Yes.
4
Q
The one was going do*n to the basement and
5
it was dark, right?
6
A
Right.
7
Q
Had you ever been down in the basement.
8
before?
9
A
No.
10
Q
And when was the other one?
11
A
When we were in Bob's office and I was trying
12
to get him to quit and to leave and I was trying to get
13
my arm from him and he Just said that I was putting up
14
a fight and that he would knock me out and I didn't now
15
if he was serious.
16
Q
From your experience with Stan, you were
17
pretty sure he wasn't serious, he wasn't going to knock
18
you out, weren't you?
19
A
I didn't know because of the things I had
20
been told about Stan.
People had said, you know, that
21
I didn't know what to expect.
22
Q
But, I guess your initial answer was you
23
weren't sure if he was serious or not?
24
A
I wasn't sure.
25
Q
All right.
when you made the first trip to
PAGE 27
1
the car, what did he take with him?
2
A
The first trip?
He took files.
3
Q
Was the trash can involved in that first
4
trip?
5
A
I don,t remember.
6
Q
Okay.
If he took files, was he carrying
7
in one hand?
them
8
9
10
11
12
l3
14
15
l6
17
18
19
20
21
22
23
24
25
A
Q
Yes.
What about his blue bag?
A
I don't remember what happened to the blue
bag.
I really don't.
I don't know if he had sat it
down, picked it up on the way out or what.
Q
And you went out to his car with him?
A
Yes.
Q
Did he put the stuff in the car?
A
Yes.
Q
And where were you when he was putting
the
stuff in the car?
Just standing there watching him do
it?
A
When he was putting it in the car, I was
standing there.
Q
Okay.
A
He had -- I was with him when he went out.
Q
He wasn't still holding you out at the car
was he?
PAGE 28
1
A
No, not out at the car he was not.
2
Q
You could have ran there if you wanted to,
3
but at that point you weren't really afraid of him?
4
A
I guess I could have.
5
Q
And, then you went back in with him for the
6
second trip?
7
A
Yes.
8
Q
And the second trip he took everything else
9
that he hadn't taken on the first trip I take it?
10
A
Yes.
11
Q
And then he gave your keys back?
12
A
Yes.
13
Q
And he waited to make sure you could get
14
back into the buildings safely because it was dark outside?
15
A
Yes.
16
Q
And, in fact, I think the two of you might
17
have kissed goodbye?
Or a peck on the cheek? See you
18
later?
Take care?
19
A
There was a peck on the cheek.
20
Q
Okay.
21
MR. BEYER:
Thank you, Stacy.
22
DETECTIVE MATHIAS:
Recross this for a second.
23
MR. BEYER:
Redirect.
24
DETECTIVE MATHIAS:
Called redirect?
25
MR. BEYER:
Yes.
PAGE 29
1
DETECTIVE MATHIAS:
Thanks.
2
REDIRECT EXAMINATION
3
BY DETECTIVE MATHIAS:
4
Q
You commented on the first trip to the car
5
you could have ran, you said I guess.
The question was
6
asked of you, could you have run.
You said I guess?
7
A
I suppose I could have at that time.
I mean
8
he had more things to get and I stayed with him to see
9
what he was doing.
10
Q
Why didn't you run?
11
12
13
15
16
17
18
19
20
21
22
23
24
25
A
wasn't going
PAGE 30
1
taking place is to determine whether or not you were in
2
fear of being harmed by Stan Caterbone and whether or
3
not you were being unlawfully restrained by him, meaning
4
you could not leave of your own free will.
Do you
5
understand?
6
A
Yes.
7
Q
The question I have is, could you have
one
8
and today, as you sit here, do you feel and believe that
9
you could have left and do you feel that -- or do you
10
feel that you were being unlawfully restrained by Stan
11
Caterbone?
12
A
While we were in the building I didn't think
13
I could have left.
I don't think I could have left.
14
When I was out at the car, by that time it was all over
15
and my main concern was that he didn't leave with the
16
keys.
17
RECROSS-EXAMINATION
18
BY MR. BEYER:
19
Q
were you in fear for your life?
20
A
For my life?
21
Q
Yes.
22
A
No.
23
MR. BEYER:
Okay.
No more questions.
24
THE DISTRICT JUSTICE:
If at the car at the
25
first trip when he was using both of his hands to put
PAGE 31
1
stuff into his vehicle, if you did flee -- how much do
2
you weigh?
3
A
Ninety pounds.
4
THE DISTRICT JUSTICE:
So he is bigger
5
lot bigger, a lot faster, could easily overtake you?
6
A
Yes.
7
THE DISTRICT JUSTICE:
Did that thought
8
to you at all?
9
A
Yes.
10
THE DISTRICT JUSTICE: It did?
11
A
Yes.
I mean, I knew he was bigger than I was
12
and I wasn't going to -13
THE DISTRICT JUSTICE:
The thought did
14
15
16
17
18
19
20
21
22
23
24
25
occur
to you that if you did try to flee, if he wanted to stop
you it would be rather easy?
A
Yes, if he wanted to stop me, yes.
THE DISTRICT JUSTICE:
Is that one
things that prevented you from fleeing there? Or is it
Just the keys?
A
Well, yes, he could easily have -THE DISTRICT JUSTICE:
I mean, is that one
of the factors?
A
Yes.
BY MR. BEYER:
Q
Were you afraid at this point?
Or you wanted
PAGE 32
1
your keys?
2
A
At this point he had done what he was going
3
to do, I felt, and I wanted the keys so he couldn't go
4
back in.
5
Q
Through your experience knowing Stan
6
personally all this time, were you afraid for your life?
7
from him?
8
A
I was not afraid for my life.
9
MR. BEYER:
Thanks.
10
THE DISTRICT JUSTICE:
That's all.
Thank
you.
11
Do you want her to stay in the courtroom?
12
MR. BEYER:
I have no obJection to her being
l3
dismissed.
14
THE DISTRICT JUSTICE:
She can leave.
Do
15
you want to go back to work or whatever?
Thank you.
l6
17
ROBERT E. KAUFFMAN, called as a witness,
18
being duly sworn or affirmed, was examined and testified
19
as follows:
20
THE DISTRICT JUSTICE:
Robert E. Kauffman.
21
Two F,s?
22
Q
**** * *******.
23
THE DISTRICT JUSTICE:
Two N's?
24
A
One N.
25
THE DISTRICT JUSTICE:
You may go ahead.
PAGE 33
1
DIRECT EXAMINATION
2
BY DETECTIVE MATHIAS:
3
Q
Mr. Kauffman, would you please Give Your
4
address and your business, what is your vocation?
5
A
1755 Oregon Pike, Lancaster.
6
Q
Is that your business address?
7
A
Business address and we are in the Financial
8
services business, investment sales.
9
Q
Okay, sir.
Could you explain to those
10
present what occurred on or about the third and fourth
11
of September, 1987?
12
A
Well, I got a call late at night from Karen
13
Loss, the wife of one of our representatives, about
14
eleven-thirty at night.
She explained to me that she
15
16
17
18
19
20
21
22
23
24
25
PAGE 34
1
Stacy, Allen Loss was there and I was asked to assess
2
the damage and Stacy went around with me and told me
3
what Stanley had done while on the premises primarily
4
and I relayed that information to the detectives and
5
that was it, as far as that night was concerned.
6
BY DETECTIVE MATHIAS:
7
Q
You said damages.
What had occurred at
8
your business?
9
A
Well --10
MR. BEYER: I object to that. I think he can
11
testify to what he observed.
12
DETECTIVE MATHIAS:
Right.
13
BY DETECTIVE MATHIAS:
14
Q
What did you observe?
What did you see?
15
A
First thing that I saw was first place we
16
went was to my office and I noted there were some files
17
missing.
Second place I believe was the computer room
18
where a key was missing to our main file server and it
19
was explained to me that -20
MR. BEYER:
I object to that.
21
THE DISTRICT JUSTICE:
Does he understand
22
about hearsay?
23
DETECTIVE MATHIAS:
24
BY DETECTIVE MATHIAS:
25
Q
You can only testify to what you saw.
PAGE 35
1
A
Okay.
2
Q
Or what you know for a fact.
3
A
All right.
4
THE DISTRICT JUSTICE:
Not what was
5
explained to you.
6
A
Got you.
I saw that there were -- the wires
7
had been pulled out of the wall in the computer room,
8
that a key was missing to the mind frame of our computer
9
system, that our ADP, or Quotron equipment as it is
10
called, was tampered with, that our computer system was
11
down in all the rooms and that they had been dislodged
12
probably -- well, at that point in time we felt broken -13
I was ushered into Mike Hartlett's office where I saw
14
that the desk was broken into, that some files were
15
missing, that I was then taken downstairs where a
16
basement door had been opened and I saw that wires had
17
18
19
20
21
22
22
24
25
PAGE 36
1
were three or four -- as you tool at a phone system, you
2
see three or four large panels with hundreds of wires
3
what I knew was -- that there was several hundred of
4
those wires pulled out and that our phones were in fact
5
dead.
That's all I know.
I'm not a technician.
6
Q
Were there any items stolen from your office?
7
A
From my office, what was missing was about
8
twenty-five odd files, I would imagine, and some papers
9
from my desk.
Nothing much other than that, that I
10
could recall.
11
Q
Where are computers in your business?
12
A
Yes.
13
Q
Were these computers tampered with or
14
damaged?
15
A
Well there were essentially, what I recall
16
from that night with -- that our two backup tapes had
17
been taken, which contained all of our information, data
18
on thousands of clients and that from looking at the
19
main computer system and the key being missing, et
20
cetera, I could only assume that had also been
21
tampered with and what we had feared was that we may
22
have lost our entire data base and there may have been
23
some irreparable damage to the main computer frame.
24
Q
As a result of these computers having been
25
tampered with, was the operation affected?
Did it
PAGE 37
1
interfere with normal operations then?
2
A
Well, the very next day, essentially we were
3
without the service whereby we quote stock and bond
4
prices for the best part of the day, which I'm sure did
5
cause us some revenue damage.
6
We also were without a phone system till
7
somewhere around noon, which can also be a problem.
But
8
I was surprised at how quickly they were able to restore
9
service in both of those cases.
The backup tapes that
10
enable us to operate our internal computer systems were
11
recovered very quickly and that enabled us to pretty
12
much run our operation without a whole lot of problem.
13
Q
Was there a monetary loss to the company or
14
to you personally as a result of these damages that you
15
were seeing?
Or these changes?
16
A
There is no question that there were.
We got
17
a -- we have a repair bill in our phone system.
18
Q
What was that? do you know?
19
20
21
22
23
24
25
A
I believe I saw a seven hundred thirteen
dollar bill for that one.
We had the people from ADP come to our office
to restore our Quotron equipment.
We don't have a bill
from them yet but it is two hundred fifty dollars when
the
walk on the premises and then goes from there as
to how long it takes them to fix it.
And they were there
PAGE 38
1
all day long.
I would suspect that bill would be
2
Fifteen hundred dollars or more.
3
We were able to recover, as I said, the backup
4
tapes but they were worth an awful lot of money to us,
5
would take several thousand man hours to restore the
6
data that is contained on our main computer system.
7
Q
Where did you recover these tapes?
8
A
I recovered them from the Manheim Township
9
Police about 3:00 a.m.
10
Q
On what date- do you know?
11
A
It would have been that same night.
12
Q
Sir, do you know a Stanley caterbone?
13
A
Yes, I do.
14
Q
Is Stanley Caterbone privileged to be in your
15
business after closing hours?
16
A
No, he's not.
17
Q
Was he privileged to be in your business on
18
the date of this offense?
19
A
No, he was not.
20
Q
Did Stan Caterbone have any right to enter
21
into your office or any other office of FMG?
22
A
No, he didn't.
23
Q
Did he have any right to remove any items
24
from that business?
25
A
No, he didn't.
PAGE
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
39
Q
Did he have any right to alter or interfere
with your normal operating procedures when it came to
the computer system?
A
No, he didn't.
Q
Did he have any right to destroy any property
within your business?
A
No, he didn't.
Q
To the best of your recollection or
knowledge, did he have keys or was he capable of
entering into your business after closing hours?
A
No, he didn't have keys. The locks were
changed over two months earlier and Stan was not even a
key.
Q
At one time did he have a key to the
business?
A
At one time he did.
Q
Why would he have a key to the business?
A
Well, at one time he was involved in the
business as an officer, director of the company and he
was also a sales representative for us.
Q
When would he have changed from having
22
23
24
25
PAGE 40
1
Q
Of 1987?
2
A
That's correct?
3
DETECTIVE MATHIAS:
I have no further
4
questions of this witness.
5
CROSS-EXAMINATION
6
BY MR. BEYER:
7
Q
As you have been testifying on direct
8
examination you have been referring to a small piece of
9
paper on your lap.
May I see that, please?
10
A
I don't know.
There is nothing on it, but
11
you may see it.
12
THE DISTRICT JUSTICE:
Are they Just notes
13
to refresh your memory?
14
A
That's correct.
15
MR. BEYER:
There are several dates and
16
names on there.
17
THE DISTRICT JUSTICE:
Dates to refresh your
18
memory?
19
Q
That's correct.
20
THE DISTRICT JUSTICE:
It is quite all right
21
to have them.
He is allowed to see them also.
22
BY MR. BEYER:
23
Q
When did you first start working for
24
Financial Management Group?
25
A
August lst of 1986.
PAGE 41
1
Q
How did you come to work for Financial
2
Management Group?
3
A
It was a -- I made a decision to join
4
Financial Management Group several weeks before that.
5
I had spoken with both Stan and Mike Hartlett over a
6
period of months before that about beginning an
7
investment services firm in Lancaster.
8
Q
And when you say in Lancaster, I assume that
9
you were somewhere else at the time?
10
A
That's correct.
11
Q
You were in at Lancaster that day?
12
A
Correct.
l3
Q
And, through your past business relationships
14
with Stan and maybe Mr. Hartlett, you were brought to
15
Lancaster or you came to Lancaster to engage in
16
business with them? is that accurate?
17
A
Correct.
18
Q
And that business was known as Financial
19
Management Group?
20
A
Correct.
21
Q
And when did that incorporate?
22
A
August lst.
23
Q
Of 1986?
24
A
To the best of my knowledge.
25
PAGE
1
2
3
4
5
6
7
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9
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11
12
13
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15
16
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18
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PAGE
1
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20
21
22
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24
25
42
A
Q
A
And upon
parent firm.
Q
What is the Parent firm?
A
Financial Management Group, Limited.
Q
Right. What's the corporate setup in terms
of persons and offices of the parent firm, Financial
Management Group, Limited?
A
Parent firm, I'm the president of the firm.
At that time Stan and Mike were -- equally had a
position Just below mine. Their title was executive
vice president. Mike reported to me on part of their -the business operations and Stan on another part.
Q
All right. In October of 1986, there was a
public offering made is that accurate?
A
Correct.
Q
And what was the name of that entity?
A
Financial Management Group, Limited.
Q
And in that entity you again are president?
A
Correct.
Q
And you were a shareholder of sixty thousand
shares?
A
Correct.
Q
And Mr. Caterbone was a shareholder of forty
43
thousand shares?
A
Correct.
Q
And to the best of your knowledge -THE DISTRICT JUSTICE: Excuse me one second.
Go ahead. Public offering in October of -MR. BEYER: 1986.
BY MR. BEYER:
Q
And Mr. Caterbone at that time was executive
vice president. He had forty thousand shares and to
our knowledge, he still maintains those shares at this
time?
A
correct.
Q
Who is the secretary of Financial Management
Group, Limited?
A
I believe it was Stanley.
Q
And when did he stop being secretary of
Financial Management Group, Limited?
A
The -- he ceased being -- he ceased being an
officer at our regular Monday morning meeting which
would have been the following Monday. I believe that
would have been July 6th.
Q
So up through July 6th, Mr. Caterbone was the
executive vice president and secretary of Financial
Management Group, Limited?
A
correct.
PAGE 44
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Q
And in June of '87 he was also holding that
Position officially?
A
June of '87?
Yes.
A
Correct.
Q
Now, when was the last ti*e you had a board
of directors meeting* go prior to September 4th?
A
Our board meets on an ever Monday morning
basis and has since its inception of August of, 1986.
Q
Did you have a shareholders' meeting prior to
September of 1987?
A
No, We didn't.
Q
Who attended the meeting in July in which Mr.
Caterbone was removed as a board member?
A
Robert Long, Allen Loss, myself, Mike
Hartlett.
Q
And it was the decision of those persons who
you Just named that Mr. caterbone would be removed as
executive vice president and as secretary is that an
accurate statement?
A
What we were advised by our legal counsel.
I'm not asking you that. I'm asking you if
that decision was made by those persons present at that
time?
A
Decision was made to remove him as an officer
PAGE
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2
3
4
5
6
7
8
9
10
11
12
l3
14
15
l6
17
18
19
20
21
22
23
24
25
45
of the corporation at that time by those people.
Q
All right. Now, again you indicated Mr.
Caterbone still has fort thousand shares of your stock
to the best of your knowledge?
A
To the best of my knowledge.
Q
And, as late as August of 1987, am I correct
in saying that you offered Mr. Caterbone two dollars and
fifty cents per share of that?
A
That's an oversimplification of what the
arraignment was. It was a complicated -- it was a
complicated arrangement
Q
In terms of stock per dollar price that's
accurate, correct? Regardless of the other things
around it, price per share of stock is that correct
A
That is the price that we offered on that
day.
Q
Okay. Now, the inability for you to quote
the stocks and bond prices on September 4th was as a
result of the ADP and not the computer machine, correct?
A
That's correct.
Q
And, in fact, you found out that your
computer wasn't damaged as a result of what happened
that night isn't that correct?
A
That is substantially correct.
Q
In fact, you back up your information every
PAGE 46
1
single day, which is on the commuter. It anything would
2
have been lost it would have only been for a day?
3
A
That's not entirely correct in that what we
4
5
6
7
8
9
10
11
12
l3
14
15
16
17
18
19
20
21
22
23
24
25
PAGE 47
1
thousand dollars, maybe eight and change?
2
A
Correct.
3
MR. BEYER: I request to show this to the
4
witness, the lease for the remise.
5
THE DISTRICT JUSTICE: Go ahead.
6
BY MR. BEYER:
7
Q
I'm showing you what we will call Defendant'
8
Exhibit No. 1. Are you able to identify that?
9
A
Sure.
10
Q
Would that appear to be the lease for the
11
premises which you are occupying right now?
12
A
Sure is
13
Q
And the same premises which were being
14
occupied on September 4th of 1987?
15
A
Sure.
16
Q
And the name of the lease as individuals is
17
who?
18
A
Hartlett, Caterbone and myself.
19
Q
Mr. Caterbone is in fact listed as an
20
individual as the lessee of this property, is that
21
accurate?
22
A
Well, I'm -- here again, I'm not a scholar
23
but I will say that it was evident that three of us
24
signed for the corporation and there was a personal pass
25
through to our personal assets should the corporation
PAGE
1
2
3
4
5
6
48
not have been able to pay the rent. I do, as myself, I
mean I don't consider that as an individual that I have
any claim to that space. It is a corporate lease.
Q
Right. however, you will agree that you
would be individually responsible if in fact that
business failed?
7
8
9
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Q
A
that?
A
Oh, yes he is responsible.
should something happen to our bossiness he is
Q
Are you familiar with that
signature?
A
Oh, yes.
Q
Mr. Kauffman I'm showing your financial
marked Financial Management Group, Ltd,
1987 the time during which you told us that Mr.
Caterbone was in fact executive vice president of your
corporation. As a board member, would you please tell
me who signed his name to this?
A
Looks like his signature to me
Q
Are you saying you don't know who signed
that Are you saying it is your understanding he signed it?
PAGE 49
1
it?
2
A
It was definitely my understanding he signed
3
it. That looks like his signature to me.
4
MR. BEYER: Thank you, Mr. Kauffman.
5
DETECTIVE MATHIAS: Is that all the questions
6
you have?
7
MR. BEYER: That's all.
8
DETECTIVE MATHIAS: May I redirect?
9
THE DISTRICT JUSTICE: Go ahead.
10
REDIRECT EXAMINATION
11
BY DETECTIVE MATHIAS:
12
Q
Did Stan Caterbone have any right to enter
13
into your office or remove any item from your office,
14
from your property?
15
A
No.
16
Q
At any time, even as a partner would he have
17
had a right to do that?
18
A
Well, the answer to that is, you know, I -- I
19
certainly don't have the ability to go in and destroy
20
things that belong to the corporation, nor do I have the
21
ability to remove things that belong to the corporation
22
from the premises and, you know, that would be -23
Q
You say able to?
24
A
I mean the right.
25
Q
Okay. You don't have the right?
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A
No.
Q
Just by good judgement? Or you don't have the
right because of some written law?
MR. BEYER: I obJect to that.
A
I think it is a different legal issue, but we
have responsibilities to the corporation as officers of
the corporation which would prevent me from doing that.
There is certainly nothing on the remise that is
outside of my personal office and my personal files that
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PAGE 51
1
Q
You have been in the same office?
2
A
I mean of '87.
3
Q
1987?
4
A
Correct.
5
Q
Who had that office before you?
6
A
St
did
7
Q
In fact, he had the locks changed so no one
8
could go in there. However, you had them changed *ga*n
9
so that you could use that office* is that accurate?
10
A
That's incorrect. He had left keys with
11
several staff people and the lock is the sam* as the one
12
Stanley has changed that I use. In fact, have the same
13
keys.
14
Q
Upon your agreement that Mr. caterbone no
15
longer works for you, you took over his office* is that
16
accurate?
17
A
It is kind -- that's an oversimplification
18
but it's not a degree of -- I mean, it is accurate. We
19
turned my office into a conference room to better
20
utilize the space and since Mr. Caterbone was not
21
returning, I used his office.
22
Q
You bring up one thing. You were first
23
alerted to this by Mrs. Loss?
24
A
we -- well, the break-in on September 3rd,
25
that is correct.
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Q
And isn't it true that you were also aware
that Mr. Caterbone had called a meeting for the 4th of
September to include Allen Loss, Bob Long, himself, Scot
Robertson... in fact, everybody other than you and Mr.
Hartlett and you were aware of that? isn't that right?
A
I was -- I'm going to say, yes and I was not
aware of all those -- I was aware of all those names.
Q
You were aware that the meeting was called.
You weren't asked to attend?
A
Yes. It didn't surprise me 'cause Stan
hasn't spoken to me since the day he left.
MR. BEYER: Thank you.
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54
Financial Management Group.
Subsequently, after a period of time, I
a roached Stan, asked him what exactly happened, why he
did what he had done. You know, I guess we had an
exchange of words to the effect I felt he was acting
very stupidly as far as handling whatever grievance he
mi *t have with Financial Management Group and
subsequently he left and from there I left shortly
thereafter.
I left Cousteau's myself and immediately went
out to the office of Financial Management Group to see
what had taken lace and in fact, notified the police
that he had, if they had not already been notified.
Q
I'm a little bit confused. Did Stan
Caterbone actually tell you he had done something?
concerned.
Thank you
Go back to business.
16
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A
Yes. He admitted through our conversation
that he had done this.
Q
Done what?
A
That he had gone in, taken files of which he
supposedly had in the car. He had, you know, torn out
computer lines to sabotage the office.
Q
Did he actually use the word sabotage?
A
No, but, you know, in fact, you know, a
business of that nature, to destroy their computer
network would be.
PAGE 55
1
Mr. BEYER: I object to that. That's
2
speculative.
3
BY DETECTIVE MATHIAS:
4
Q
You know Stan Caterbone?
5
A
Yes.
6
Q
Is he here now?
7
A
Yes.
8
Q
Would you please point to him?
9
A
Doing same.
10
DETECTIVE MATHIAS: Seated next to counsel.
11
BY DETECTIVE MATHIAS:
12
Q
Has any mention made concerning an air lane?
13
A
Yes. At one time Stan had, to the best of my
14
knowledge, purchased an aircraft from Lancaster
15
Aviation. Subsequently, to the best of my knowledge, I
16
understand it was repossessed due to failure of payment
17
and he has mentioned to Harry Lutz, who was a friend of
18
mine, that he was guest bartender, you know, he was
19
bartending that evening and he had requested Harry to
20
steal the plane for him.
21
Q
For any specific reason? What were they
22
going to do with this plane?
23
A
He felt it was -24
MR. BEYER: I obJect to that. He doesn't know
25
what he felt. If he knows something he can state it.
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BY DETECTIVE MATHIAS:
Q
Did Stan Caterbone actually make a comment to
you that he was oin to take this plane?
A
I don't know that it was -- that subject was
never directly mentioned to me by Stan.
DETECTIVE MATHIAS: Fine.
MR. BEYER: Thank you.
CROSS-EXAMINATION
Q
Mr. Berger, you also have an association with
Financial Management Group?
A
That is correct.
Q
How long have you had that association?
A
On and off for--the last approximately twelve
months.
Q
Who was the first person to get you involved
with Financial Management Group?
A
Stan.
Q
Okay. And this conversation at Cousteau's
19
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PAGE 57
1
A
No.
2
THE DISTRICT JUSTICE: Do you know who did?
3
A
I believe it was the young lady that was
4
cleaning the offices that evening.
5
THE DISTRICT JUSTICE: Okay. Thank you.
6
That,s all
7
8
A
No, I don't.
9
MR. BEYER: Thank you. He may be excused.
10
I'm finished. You can leave' Thank you.
11
DETECTIVE MATHIAS: I,m the next witness. Do
12
you want me to stay here or go up there?
13
THE DISTRICT JUSTICE: If you have thousands
14
of papers that you have to constantly refer to by going
15
back and forth, then, why, your request is granted. If
16
you don't, then everybody should use the witness chair
17
in the proper court of criminal law.
18
19
LARRY MATHIAS, called as a witness
20
being duly sworn or affirmed, was examined and testified
21
as follows:
22
DIRECT TESTIMONY
23
DETECTIVE MATHIAS: I'm Detective Larry
24
Mathias of the Manheim Township Police Department*,
25
employed as an investigator and was so employed on the
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4th of September, 3rd and 4th of September, 1987 as a
sworn law enforcement officer of Manheim Township.
On that date at approximately -- on the 3rd of
September at approximately lO:30 p.m., our police
personnel were dispatched to MFS, located at 1755 Oregon
pike
MR. BEYER: Let the record show I think he
meant FMG.
A
Okay. Financial Management Group -concerning an unlawful entry to the building and a theft
of properties from the building. In going to that
location it was confirmed and appeared that items had
been moved and in speaking with all the witnesses who
had previously testified, subsequently Stanley caterbone
was arrested.
On that evening at a proximately three o'clock
items were seized from him on the 4th of September and
were items believed to have been the property of this
organization.
Based on all the information, Stanley
Caterbone was charged by me.
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the acts were committed and that these sections and the
requirements of these sections, specifically the
computer, that's a new one. That's one that I have
never brought before.
I believe that Stanley Caterbone did interfere
with the normal operating procedures of that operation
and I do believe that he did remove from that
organization property that he was not entitled to
regardless of his position with that company.
I do believe that he entered into that
building in an unlawful way and I do believe that he
committed a crime while he was there and I believe he
unlawfully restrained a young lady against her will, all
said acts to have occurred in Manheim Township.
CROSS-EXAMINATION
BY MR. BEYER:
Q
Detective Mathias, in terms of the actual
custody of Mr. Caterbone, am I accurate in stating a
different police department was dispatched to pick him
up?
A
Correct.
Q
That would have been the Pequea Township or
Conestoga Township?
A
That is correct.
Q
And to the best of your knowledge, at the
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time he was apprehended, did he ask permission to go to
his house to bring certain items?
A
I believe he did.
Q
In fact, he brought loads of files to the
police department to indicate to you what he had
taken and to try to explain.
A
I know that a lot of items -- several items
were brought to the police station. I didn't personally
inventory those items. I'm not sure what was brought.
Q
To the best of your it was his
incentive to bring them to you?
A
Yes, it was, yes.
MR. BEYER: Then
questions.
DETECTIVE MATHIAS:
prosecution.
MR. BEYER: Your honor I have a demurrer.
DETECTIVE MATHIAS: Do you want to their
case now? Or before we move on with that?
THE DISTRICT JUSTICE: Let's settle this one
first. Then we have to go to Detective Siegler's
hearing.
MR. BEYER: Your honor, I think I will try to
address them in the order that they are in the
25
Complaint.
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61
undisputed that Mr. Caterbone as, well as Kauffman and
Hartlett are individuals on the lease of the premises in
which he is accused of burglary in .
The lease is a nine thousand dollar a month
leasehold which Mr. Kauffman has told us each individual
could be or is individually responsible for should the
business fold. In common law, an individual who has
such a leasehold does have a privilege to enter those*
premises.
While there would not be an excuse for n
theft that would have occurred therein, had it occurred
a burglary would be an improper prosecution to follow
with there because of the obvious leasehold interests
that he not only had but still does have in those
premises.
Consequently, we would feel that the burglar
would need to be dismissed against Mr. Caterbone for
those reasons.
THE DISTRICT JUSTICE: We will take them one
at a time so we don't et all confused. Now burglar
there is a demurrer saying that number one, he has a
right to be there and therefore he could break down the
door, Jimmy a window or something but he didn't do an
of those things at all. He was led into the building by
this young lady and from then on he never broke a door
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down or smashed a window or anything- is that correct?
DETECTIVE MATHIAS: No. he forcibly removed
the keys and then that entitled him to make entries to
these other rooms.
MR. BEYER: That's not accurate. He was led
into the building by the girl.
DETECTIVE MATHIAS: He was left into the
building by that young lady at the door.
THE DISTRICT JUSTICE: That's right.
DETECTIVE MATHIAS: Then he took the keys n
that's how he gained access to several offices.
MR. BEYER: She said the only place that keys
needed to be used were the basement and he had the key -he knew the key was there. He had the key. All the
offices were empty or were open and she stated that
specifically and even still, the guy was a leasehold on
the building.
THE DISTRICT JUSTICE:
to be decided.
MR. BEYER: I think we offered the evidence
and shown it through the witness who admitted it.
THE DISTRICT JUSTICE: Your context
disregarding the leaseholder privilege that the
that he used the key to go to the basement after he was
allowed in the building constitutes burglary?
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her in safely.
She also admitted a goodbye kiss. Under the
circumstances, I'm sure that this does not amount to an
unlawful restraint under the meaning of the Crimes Code.
I don't know that's going to be debated by the other
side.
DETECTIVE MATHIAS: No comment on that.
MR. BEYER: I will not offer a demurrer at
this time to a theft or the computer charges and only in
terms of the criminal mischief that I would point out
that damage is an element of that offense because of
grading and I don't know that the element has been
satisfied
And they would be the only demurrers I would
have to these charges, specifically towards the burglary
and unlawful restraint.
THE DISTRICT JUSTICE: Do you want to rebut
the criminal mischief demurrer that there is no damage,
no value?
DETECTIVE MATHIAS: I think there is clearly a
cost factor.
MR. BEYER: I withdraw the criminal mischief
demurrer.
THE DISTRICT JUSTICE: Something here has to
have value. the telephones.
PAGE
1
MR. BEYER: I withdraw that demurer. I think
2
he said se*en fifteen.
3
THE DISTRICT JUSTICE: All right. If we have
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PAGE 66
1
Q
Were you so employed in the first of
2
September, 1987?
3
A
Yes.
4
Q
In that capacity?
5
A
Yes.
6
Q
Did you receive any type of phone call other
7
than a normal business phone call on that date?
8
A
I thought it was, yes.
9
Q
And about what time did that happen?
10
A
I think between about ten ten-thirty. in
11
that area. At the time I notified somebody but I didn't
12
write it down. I think it was at that area.
13
Q
And what was the extent of the phone call
14
that you received?
15
A
The party answered and he didn't give a
16
name. They Just said, if I were you I would not stay in
17
that building today. And a comment was, why. And they
18
hun up.
19
Q
All right. I would like to read to you what 20
would I be correct in saying that, I would advise you
21
all to get out of the building if you value your safety?
22
MR. BEYER: I obJect to that.
23
THE DISTRICT JUSTICE: On what basis?
24
MR. BEYER: First of all, it is not a
25
question. Second of all, she stated what was said on
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67
the phone. The detective putting stuff into evidence
that's not no basis or foundation from a witness.
THE DISTRICT JUSTICE: Agreed.
BY DETECTIVE MATHIAS:
Q
Mrs. Kemper, do you want to tell me again
what the caller said?
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A
I answered the phone. No name. Party said
to me, if I were you I would not stay in that building
today and I asked why and they hung up.
Q
Okay. Do you recognize or did you recognize
the caller?
A
Yes.
Q
Who was that caller?
A
Stanley Caterbone.
Q
And do you see him in the courtroom?
A
I don't know Stanley, but I assume this
gentlemen over here is Stanley.
Q
But you recognized his voice?
A
Yes, I recognized his voice.
DETECTIVE MATHIAS: Thank you.
have nothing 21
further.
CROSS-EXAMINATION
BY MR. BEYER:
Q
How do you recognize his voice?
A
Because he called frequently.
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Q
And you have talked to him before?
A
He identified himself on occasions and on one
occasion it was more -- it was another comment made to
me.
Q
How long have you worked for Financial
Management Group?
A
Since July l5th.
Q
Of 1987?
A
That's correct.
Q
And, after you got this phone call you
notified someone else in the building?
A
Yes, I did, immediately.
Q
Did you call the police?
A
I didn't, no.
Q
Do you know whether they did the same day?
A
I think so.
Q
Did you evacuate the building?
A
No. I was scared.
Q
Did you evacuate the building?
A
No.
MR. BEYER: Thank you.
DETECTIVE MATHIAS: One other question, Your
Honor.
REDIRECT EXAMINATION
BY DETECTIVE MATHIAS:
Q
Mrs. Kemper, after you got the phone call and
you hung up the phone, what did that phone call mean to
you?
A
I was afraid
Q
Afraid of what?
A
I was afraid that there was a bomb or
something in the building. That's what entered -that's what I thought.
DETECTIVE MATHIAS: Thank You.
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somebody must have called?
A
I think Bob Kauffman called, but I don't know
that.
THE DISTRICT JUSTICE: You got this call and
then a little while later there is a Policeman or
detective there?
A
He came and they wanted my statement.
RECROSS EXAMINATION:
BY MR. BEYER:
Q
This was September lst that the call came in?
A
September lst, yes.
Q
Might the policeman not have come until
September 3rd?
A
I really can't answer. I thought it was the
same day. I can't answer that.
MR. BEYER: That's okay. I have no obJection
to this lady being excused, going about her business.
THE DISTRICT JUSTICE: Thank you. That's all.
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Mr. Kauffman concerning the phone call that Mrs. Kemper
had just testified to. I immediately went to the
building and I searched the building. I was unable to
find anything and based on the information that I had
received from Mrs. Kemper, I filed a charge of
terrorIstic threats, Crimes Code Section 2706.
MR. BEYER: I will stipulate to that stuff
THE DISTRICT JUSTICE: You don't
all that.
A
It was signed
September, 1987 -THE DISTRICT JUSTICE: Any questions?
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PAGE 72
1
A
That's correct.
2
Q
Okay. So if there is a discrepancy the
3
statement which was taken from her would be most
4
accurate?
5
A
That's correct.
6
MR. BEYER: All right? Thank You.
7
THE DISTRICT JUSTICE: That's aLL.
8
MR. BEYER: Judge -- I assume you're finished?
9
DETECTIVE MATHIAS: Yes.
10
MR. BEYER: I have a demurrer.
11
(Mr. Beyer presented oral argument
12
to the court on behalf of the Defendant.)
13
THE DISTRICT JUSTICE: No rebuttal?
14
DETEcTIVE MATHIAS: No, sir.
15
THE DISTRICT JUSTICE: I don't think a crank
l6
phone call is enough, even on a prima facie basis to
17
constitute a terroristic threat charge and the demurrer
18
will be allowed and that one will not be returned to
19
court. The others will.
20
The Defendant is continued on his bail and he
21
is ordered to be bound over for the next term of court
22
on the charges previously outlined.
23
(The proceeding was concluded
24
at this time.)
25
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REPORTER'S CERTIFICATE
I HEREBY CERTIFY that I was present upon the
hearing of the above-entitled matter and there reported
stenographically the proceedings had and the testimony
produced; and I further certify that the foregoing
is a true and correct transcript of my said
stenographic notes.
DI= ***********************************************************
TI=\SIR SPEEDY PRINTING INVOICE FOR DOCUMENTS
IM=163P01.CPR
DA= October 5, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Invoice from Sir Speedy Printing Center, 301 N.
Queen St Lancaster, PA, for the duplication of 1103 images billed
to the law firm of Arnold, Beyer & Homsher for Stan
Caterbone, client.
DI= ************************************************************
TI=\FARMERS FIRST BANK ATTEMPTED EMBEZZLEMENT
IM=164P01.CPR
DA= October 7, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Copy of a check to Stan Caterbone for $138.45
drawn against FSC Agency, Inc. for insurance commissions due.
Stan Caterbone proceeded to the Park City Shopping Center
in Lancaster, and attempted to first cash the check at
Farmers First Bank. The tellers acted suspicious and
walked away from the counter, and refused to cash the
check, and ever more amazing is the fact that the teller
had actually tried to keep the check. Stan Caterbone
immediately became load, and demanded the check back at
once. Hamilton Bank also refused to cash the check.
DI= ************************************************************
TI=\FMG, Ltd., vs. S. CATERBONE RE: FURNITURE
IM=165P01.CPR
DA= October 9, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
2
SU= SUMMARY: A letter from attorney Robert Beyer to attorney
Christine Hausner, representing Craig Russell, regarding the
charges of FMG, Ltd., filed against Stan Caterbone. It
looks as though the furniture and other incidental
personal artifacts is far more important than the illegal
criminal charges filed with malicious motives against
Stan Caterbone.
IM=165P02.CPR
DI= PAGE 02
DI= ************************************************************
TI=\TITLE:
INTERCON INVESTIGATION SERVICES
IM=166P01.CPR
DA= October 10, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
3
SU= SUMMARY: Resume and services of Intercon Special Services,
Inc., of New York, NY. Stan Caterbone had traveled to New
IM=166P02.CPR
DI= PAGE 02
IM=166P03.CPR
DI= PAGE 03
DI= ************************************************************
TI=\CAPELLO & FOLEY RETURN PACKAGE
IM=167P01.CPR
DA= October 10, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: The address label from the package of 3 Binders that
the law firm of Capello & Foley sent to Stan Caterbone. In
July, Stan Caterbone had traveled to Santa Barbara, CA
to attempt to retain Barry Capello, a leading specialist
in lender liability, who is often published in law
journals.
DI= ************************************************************
TI=\MARION STREET REAL ESTATE SALE
IM=168P01.CPR
DA= October 12, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/07/08
PA= PAGES:
2
SU= SUMMARY: Letter from James D. Warner, currently of 433 West
Marion Street, Lancaster, PA to Robert Byers, attorney
of Stan Caterbone. Jim Warner had purchased the property
of 433 W. Marion Street from Stan Caterbone.
IM=168P02.CPR
DI= PAGE 02
DI= ************************************************************
TI=\HAMILTON VISA CARD
IM=169P01.CPR
DA= October 28, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Collection letter from Corestates Bank, Hamilton
Bank to Stan Caterbone regarding a delinquent balance of $3,559.
Most of the charges were sustained after Stan Caterbone
suffered a loss of income, on July 1, 1987.
DI= ************************************************************
TI=\PARENT FEDERAL SAVING APPRAISAL
IM=170P01.CPR
DA= October 28, 1987
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY:
DI= ************************************************************
TI=\MOBILE HOME PURCHASE INVOICE
IM=183P01.CPR
DA= January 14, 1988
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A sales receipt from Mellott Bros., Trailer Service, of
Willow Street, PA to Stan Caterbone for the purchase of
a 1972 Open Road Mobile Home, for $5,000. Stan Caterbone
was preparing to travel to California for another attempt
at retaining competent legal council.
DI= ************************************************************
TI=\PA HOMEOWNER'S EMERGENCY ASSISTANCE DENIAL
IM=184P01.CPR
DA= January 26, 1988
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A Rejection notice from the Housing Finance Agency,
Homeowners Emergency Assistance Program, issued to
Stan Caterbone. The Homeowners Emergency Assistance
Program is designed to provide mortgage payments to
persons suffering financial hardship beyond their
control. They cited the fact that "mortgagor was
terminated from job" as a contributing factor for
denial.
DI= ************************************************************
TI=\LANCASTER AVIATION vs. S. CATERBONE CIVIL SUIT
IM=185P01.CPR
DA= February 4, 1988
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Chuck Smith files a civil suit in the court of Murray
R. Horton, District Justice, for $3,411.81. Of which most
or all were illegitimate charges.
DI= ************************************************************
TI=\PARENT FEDERAL SAVINGS vs. CATERBONE FORECLOSURE
IM=186P01.CPR
DA= March 14, 1988
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
2
SU= SUMMARY: Action in Mortgage Foreclosure against Stanley J.
Caterbone and Michael T. Caterbone filed by Parent
Federal Savings and Loan, owned by James Guerin, for the
residence of Stan Caterbone, located at 2323 New Danville Pike,
Conestoga, PA
17516
IM=186P02.CPR
DI= PAGE 02
DI= ************************************************************
DI= PAGE 05
IM=192P06.CPR
DI= PAGE 06
IM=192P07.CPR
DI= PAGE 07
IM=192P08.CPR
DI= PAGE 08
IM=192P09.CPR
DI= PAGE 09
DI= ************************************************************
TI=\GREENFIELD ASSOCIATES EMPLOYMENT SOLICITATION
IM=193P01.CPR
DA= January 12, 1989
AT= CORRESPONDING AUDIO TRACKS: 01/02/04/05/06/07/08
PA= PAGES:
3
SU= SUMMARY: Letter to Richard E. Blouse, President of Greenfield
Associates, a subsidiary of High Industries, from Stan Caterbone
requesting interview for employment considerations. Also
attached is a resume of Stan Caterbone.
IM=193P02.CPR
DI= PAGE 02
IM=193P03.CPR
DI= PAGE 03
DI= ************************************************************
TI=\S. CATERBONE CREDIT REPORT OF AUGUST 8, 1989
IM=194P01.CPR
DA= August 8, 1989
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
4
SU= SUMMARY: A copy of a Credit Report for Stan Caterbone, on
August 8, 1989 substantiating the damaged credit worthiness
from the activities surrounding June and July of 1987.
IM=194P02.CPR
DI= PAGE 02
IM=194P03.CPR
DI= PAGE 03
IM=194P04.CPR
DI= PAGE 04
DI= ************************************************************
TI=\AMERICAN HELIX vs. ADVANCED MEDIA GROUP, Ltd., CD-ROM BUSINESS
IM=309.CPR
DA= May 21, 1990
AT= AUDIO TRACKS: /05
PA= PAGES: 01
SU= SUMMARY: Dave D. Dering, President of American Helix, provided written
documentation and verification that Stan Caterbone and the Advanced
Media Group, Ltd., will be given the opportunity to take possession of
the information technologies (CD-ROM) business and continue to grow
that business with all equity reverting to Stan Caterbone.
High Industries had recently elected to discontinue the capitalization
of this business, including the consulting fees then being paid to
DI= PAGE 03
DI= ************************************************************
TI=\"AMERICAN HELIX & STAN CATERBONE BUSINESS AGREEMENT"
IM=308.CPR
DA= November 2, 1990
PA= PAGES: 01
SU= SUMMARY: Stan Caterbone had made fruitless attempts to solidify
an agreement with American Helix and High Industries in order to
receive compensation for the CD-ROM business. Stan Caterbone was
conducting business since June, without any compensation or agreements.
Finally, on November 2, 1990, the following agreement was signed.
This agreement was breached on January 12, 1991. For no reason or
more importantly explanation, Stan Caterbone was again "LOCKED OUT"
of his place of business, and his business.
David D. Dering, gave no reason or explanation, other than the
implementation of a smear campaign to diminish any respect or credit
that Stan Caterbone had developed with clients, and employees, including
High Industries. Rumors of and Slanderous remarks were again launched
in order to justify the actions of David Dering and James Boyer.
DI= ************************************************************
TI=\DISC MAGAZINE COLUMN FORMAT FOR AUTHORS
IM=197P01.CPR
DA= October 22, 1990
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
3
SU= SUMMARY: A facsimile from Linda Helgerson, publisher of several
CD-ROM (Digital Technologies), and considered one of the most
influential persons in the CD-ROM Industries, to Stan
Caterbone outlining procedures and formats for the
submission of technical articles for the new DISC
magazine, a technical journal for the CD-ROM industry.
Stan Caterbone was selected to submit monthly articles
for the Disc Magazine. Stan Caterbone has developed
a respectable working relationship with Linda Helgerson.
IM=197P02.CPR
DI= PAGE 02
IM=197P03.CPR
DI= PAGE 03
DI= ************************************************************
TI=\ASSISTANT SECRETARY OF DEFENSE LETTER
IM=198P01.CPR
DA= October 23, 1990
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: A letter to Congressman Robert Walker from Dave
Gribbin, the Assistant Secretary of Defense, Legislative Affairs,
regarding the inquiry by Stan Caterbone regarding the
procurement procedures concerning the $2.5 Million
contract with the Department of Defense, Defense Mapping
Agency. The contract was protested by Phillips Dupont
IM=201P02.CPR
DI= PAGE 02
DI= ************************************************
TI=\"ESCAPING THE UNIX TAR PIT" ARTICLE BY S. CATERBONE
IM=202P01.CPR
DA= November 18, 1990
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
9
SU= SUMMARY: A copy of the article written by Stan Caterbone and
John Garofolo Computer Scientist of the National Institute of
Technology, of Gaithersburg, Maryland submitted for
the January issue of DISC magazine. Stan Caterbone had
successfully completed development of the most aggressive
CD-ROM project for NIST, sponsored by the Defense
Advanced Research Projects Agency Information Science
and Technology Office (DARPA-ISTO). The project was
so difficult, that only Stan Caterbone and Phillips
Dupont had competed for the contract. Stan Caterbone
was awarded the governmental contract in June of 1990. The
project required the production of UNIX TAR files, which are
considered unconventional in the CD-ROM industry. The article
was written to inform the industry of potential problems that
developers and specifically manufactures may encounter.
JANUARY "DISC" '91 Magazine
Published by: Helgerson Associates
Falls Church, VA
"Escaping the UNIX Tar Pit"
Producing CD-ROMs in the UNIX Environment
Written by:
Stan J. Caterbone
Director of CD-ROM Technologies for
American Helix Technology Corporation
and Director of Advanced Media Group, Ltd.
1857 Colonial Village Lane
Lancaster, PA 17601.
Phone: (800) 525-6575
Fax: (717) 392-7897
John S. Garofolo
Computer Scientist
National Institute of Standards and Technology
Technology Building, Room A-216
Gaithersburg, MD 20899
Phone: (301) 975-3193
Email: john@ssi.ncsl.nist.gov
Just when things are going smoothly, and we begin to feel a
little too comfortable and too confident with CD-ROM
technology, someone or something puts us in our place -- and
Worse yet, because the tar format does not guarantee that
directories and files are stored in any particular order, an entire
tar file must be scanned to extract any subset of files contained
in it. If the tar-extraction process aborts before the end of the
tar file is reached, the entire process must be restarted from the
beginning to insure that all files are loaded.
These constraints require that special efforts be placed in
preparing backup tapes and even second backup tapes during
production. This is one area of risk where the insurance is well
worth the effort, and is within one's control. Many of the other
pitfalls are not as easy to anticipate or avoid.
One of the more frustrating problems encountered while
downloading the TIMIT tar file was that of the overhead created
while extracting the 18,900 small transcription files. To illustrate
this point, during the downloading of the 632-megabyte tar file,
containing the 25,241 TIMIT files, the process aborted on 650-,
850-, and 1200-megabyte partitions due to insufficient disc space!
On UNIX systems, the physical file block size can be modified
when formatting a disk. Although the ISO-9660 standard
supports different sector sizes, the individual operating systems
used in the premastering process may present problems. For
example, MS-DOS 3.31 does not allow any modifications to
sector size. Fortunately, MS-DOS 4.0 is more forgiving.
The TIMIT tar file contained 18,900 transcription files of under
2Kb each. A premastering system running DOS 3.31 with a
16Kb sector size would require over 300 megabytes of disk
storage for these files which actually amount to less than 32
megabytes of data. This results in disk overhead of 1 order of
magnitude! However, by switching to DOS 4.0, the sector size
can be reduced to as little as 512 bytes. This significantly
reduces the overhead being used by the DOS partition. It is
therefore important to adjust the sector size to accommodate the
size of the database files to be downloaded. To maximize disk
usage, the sector size should be set high when premastering a
database with a few large textual files. But when a database
(such as TIMIT) contains many small files, the sector size should
be greatly reduced. Likewise, it is also important to allow for
this kind of overhead on the CD-ROM itself. Although CDROMs are generally created with a 2Kb sector size, the sector
size can be reduced on the ISO-9660 image in the premastering
phase to as little as 512 bytes. By decreasing the sector size on
the TIMIT ISO-9660 image to 512 bytes, potential disc overhead
was reduced by about 32 megabytes.
Finally, a hidden source of potential problems lies within the
implementation of the utility used to extract the tar file. There
are currently a number of tar utilities that have been written and
are in use today. Many of these utilities are very suboptimal in
speed and efficiency. The time required for downloading a tar
file can become critical when extracting large numbers of files.
Therefore, using the right tar implementation is a must.
IM=204P01.CPR
DA= November 20, 1990
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
3
SU= SUMMARY: Letter to Contracting Officer William M. Nelson of the
Defense Mapping Agency from Stan Caterbone outlining his
responses to the deficiencies of the DMA $2.5 Million
Contract.
IM=203P02.CPR
DI= PAGE 02
IM=203P02.CPR
DI= PAGE 03
DI= ************************************************************
TI=\CONGRESSMEN ROBERT WALKER'S DISCLOSURE
IM=205P01.CPR
DA= December 6, 1990
AT= CORRESPONDING AUDIO TRACKS: 01/02/03/04/05/06/07/08
PA= PAGES:
1
SU= SUMMARY: Letter to Congressman Robert Walker from Stan
Caterbone citing his concern that he has not received the pricing
schedules of Phillips Dupont and SONY as previously
promised, especially considering his submission to
the deficiency responses that were filed on November 20,
1990. In addition, he disclosed that he would be raising
issues concerning the events of '87 by the following post script -"P.S. the summer of '87. Unfortunately, this will involve
many of your constituents, in fact you may want to
inquire to Mrs. Walker regarding our telephone conversation in
July of '87. I mean no harm, and appreciate your integrity and
support."
DI= ************************************************************
TI=\GRIEVANCE LETTER TO DMA CONTRACTING OFFICER NELSON
IM=330.CPR
DA= December 23, 1990
SU= December 23, 1990
FROM:
TO:
Department of Defense
Defense Mapping Agency
ATTN:
Subject:
DMA700-90-0011 Contract
And, what took you 3 years to figure out, I, James Christian, Ferranti
International, and the British Government, have suffered and continue
to suffer the consequences for your misconduct and corruption.
Consequently, I have produced a CD-ROM which contains over 500 authentic
documents and over 30 minutes of recorded audio conversations to
substantiate and confirm the above. All on one little shiny silver
platter!
And now, after three years, I find myself again playing your
"Fucking Games".
In another perspective, I have studied and tried to understand the
circumstances and motives of the Persian Gulf Crisis, and more
importantly the motives of Saddam Hussain, and quite honestly
I don't believe a God Damn thing you say.
In conclusion, after 3 lonely years of "HELL" I have finally
formulated an opinion that would seem to make some kind of sense
out of this bizarre nightmare:
"CORRUPT SYSTEMS, GOVERNMENTS, AND INSTITUTIONS WILL BREED
NOTHING BUT CORRUPT MEN."
Take your God Damn contract and Go To Hell!
Regretfully,
Stanley J. Caterbone
Director, Advanced Media Group, Ltd.,
ENCLOSURES
cc:Captain Wright, Defense Mapping Agency
Stanley O. Smith, Brigadier General, USAF, Chief
of Staff
Dave Gribben, Assistant Secretary of Defense,
Legislative Affairs
Congressman Robert Walker, U.S. Congress
James Christian, Loretto State Prison
Sir Derek Jones, Chairman, Farranti International,
PLC.,
Tony Bongiovi, Power Station Studios
Marcia Silen, Flatbush Films
IM=307P02.CPR
DI= PAGE 02
DI= ************************************************************
TI=\OLD HICKORY LOAN PROPOSAL BY S. CATERBONE
DA= May 25, 1987
PA= PAGES:
3
2.
3.
4.
Loan Portfolio
a. Description
b. Value, terms
5.
FMG Ltd.
SJC:lmk
cc: S. Robertson
B. Long
A. Dannatt
DI= ***********************************************************
TI=\David R. Schadd Letter
DA= May 11, 1987
AT= CORRESPONDING AUDIO TRACKS:01/02/03/04/05/06/07/08
SU= May 11, 1987
David R. Schod, President
Bennett Williams, Inc.
30 East King Street
Post Office Box 1364
York, PA 17405
Dear Dave:
Enclosed is a proposal for your syndication. Please go over its
contents and when you are finished reviewing, we should get
together to discuss the project in person. I will be away until the 18th of
May.
I look forward to hearing from you.
Sincerely,
Stanley J. Caterbone
President
SJC:lmk
cc: file
Robert J. Behler, Jr.
DI= ***********************************************************
TI=\BENNET WILLIAMS SYNDICATION
DA= June 15, 1987
AT= CORRESPONDING AUDIO TRACKS:01/02/03/04/05/06/07/08
SU= BENNETT WILLIAMS/SYNDICATION
I.
Scope of Business
II.
III.
IV.
V.
I.
Structure of Syndication
Costs of Syndication - Bennett Williams Financial Center
Financial Service Center
SCOPE OF BUSINESS
FUNCTION OF BENNETT
a).
b).
c).
building
The
and
II.
FMG, Ltd. will be responsible for the following services and factors:
a). The Syndicator will be responsible for all legal
and accounting services needed to register the partnership with the
appropriate regulatory authorities in order to solicit
investors.
b). Prospectus - The Syndicator will be responsible for the
development and production of the prospectus to be used to solicit
investors.
c). Marketing - The Syndicator will be responsible for the
marketing and solicitation of investors in order to raise the
necessary capital to
finance the project.
d).
This
the
This means approximately 88% of the capital raised will go into the
actual building and ground. This includes all legal, accounting, printing,
marketing, of the partnership. With this ratio, the program will be among
most
Financial Planning
2.
3.
4.
5.
6.
7.
will
have a role in the formation and the operations of the Center. FMG will
provide
the recruiting and management of the operation and will use the current
systems that have been developed and used in Lancaster. The ownership
will be structured among FMG, Bennett Williams, and the other Major
Players who wish to get involved. Enclosed is an original Business Plan
that
outlines the concept in more detail.
DI= ***********************************************************
TI=\ABC 20/20 BROADCAST: "MADE IN THE USA?"
DA= February 1, 1991
AT= AUDIO CONVERSATIONS: 02/05/07/09
SU= <HUGH DOWNS>: In Gulf war military briefings, allied commanders
love to showcase the performance of sophisticated U.S. weaponry.
Everything from smart bombs to Patriot missiles have bolstered
the allies' performance, but 20/20 has learned that federal
investigators are inquiring now whether Iraq itself may have
of a U. S.-style technology. It's feared that cluster bombs of a
type originally designed and produced in this country, may be used
against American forces. Tonight, in a 20/20 investigation, Lynn Sherr
asked whether and how Saddam Hussein got his hands on technology
"Made in the USA."
<LYNN SHERR, ABC News>: These aircraft are delivering some of
the deadliest conventional weapons ever built. They are called
"cluster bombs" and the earliest version was used by the American
military in Vietnam. They are so vicious that when Israel used them
against civilians in Lebanon in 1982, it created a serious rift of
in relations with the United States. The bombs have been sold to
many countries considered friends of the United States, but now the
technology and the bombs themselves are also in the hands of Saddam
Hussein. ABC News defense consultant Anthony Cordesman.
<ANTHONY CORDESMAN, Defense Analyst>: By and large, they can be 10.,
sometimes 100 times more lethal in killing exposed targets than a
conventional, very large high-explosive weapon.
<SHERR>: This is the story of how this deadly weapon designed for the
U.S. military made its way from this country to Iraq and how America
soldiers may now face the devastation from thousands of cluster bombs
if a ground war breaks out in the PersiAn Gulf. Federal officials
believe Saddam Hussein got his arsenal through a lethal combination-bureaucratic foul-ups in the U.S. government and simple greed.
Her's how the cluster bombs work.
An artillery, an airplane or a
rocket-launchers And the bombs toward their targets. Each bomb carries
hundreds of smaller bomblets, something like hand grenades. Cluster bombs
be used against ground troops or tanks and can even scatter mines to lie
dormant for days. The shrapnel can rip through the bodies of anyone or
anything in its way, causing massive casualties among destruction in
these buildings in Lebanon after a cluster bomb attack.
How did Iraq obtain the cluster bombs and the technology to make
their own? It was incredibly simple. Investigators believe it began
with International Signal & Control, a government contractor with
5,000 employees based in Pennsylvania which designed key components of
clusters and built them through a subsidiary in California. 20/20 has
learned federal investigators believe ISC provided the technology -- that
is the plans for the cluster bomb to this man, Carlos Cardoen, a Chilean
arms dealer. Authorities think he used the plans to build the cluster
bombs in Chile. Then he shipped them to Iraq.
What's wrong with all this? If the cluster bomb technology actually
left the county, that is illegal without U.S. government permission, which
investigators say ISC never got. It is also illegal for a foreigner like
Cardoen to take sub plans out of the United States without a license,
which sources tell us he never obtained.
The man who opened the door to Iraq for Cardoens operation was this
man, Nasser Beydoun. He is a Lebanese-born middle man for Cardoen
who is based in the United States. Beydoun traveled frequently to Baghdad
and arranged for the sale of cluster bombs and other military hardware to
Saddam Hussein's army. In this first television interview, he told us
about the business of dealing in deadly weapons.
<NASSER BEYDOUN, Arms Dealer>: I can sell you a knife to peel an apple.
If you cut somebody's throat with it, it's your business. Weapons do
not kill. Who is behind it kill.
<SHERR>: With slick promotional videos, Cardoen marketed his arms
throughout the world, but Arab countries were most favored.
<VIDEO ANNOUNCER>: Each one of the bomblets of the cluster bomb is
multi-purpose and has an incendiary, anti-personnel and anti-armor
effect.
<SHERR>: This letter from Cardoen authorized Beydoun to sell cluster bombs
to Saddam Hussein during his war with Iran. It says Cardoen's company
is "willing to take its share in helping Iraq in this time of need. We
can provide you with our cluster bombs at the lowest possible price."
According to these contacts, the sale of cluster bombs to Iraq was an
extremely
lucrative business. February 24., 1984-- 3,000 cluster bombs sent to
Saddam Hussein's army, worth $21 million. A few months later, another
3,000 bombs, another $21 million. The supplies of cluster bombs
eventually totalled more than $400 million. In fact, Beydoun is suing
his former boss for commission payments.
According to Beydoun, Cardoen not only sold the bombs produced in Chile to
Saddamm Hussein, he even set up a factory near Baghdad so the Iraqi
president could mass-produce his own cluster bombs. That was one of the
first targets of the American military when the attack against Iraq
began, but it's unknown whether the plant is totally out of commission.
<MR. BEYDOUN>: He set up a factory for manufacturing of the cluster
bomb and later a stage for the fuses and this is a complete project.
I mean, it's complete form the raw material to the finished product
because the strategy of Iraq is to have control over the weaponry that
they have put in their strategy.
<SHERR>: Federal investigators are trying now to bring Carlos
Cardoen to trial, but why didn't they find out about him sooner?
He's been selling cluster bombs to Iraq for nearly a decade. The
U.S. Patent Office knew about Cardoen back in 1986, but they
apparently didn't tell anyone else in the federal government about
him.
In a move that apparently went unchecked at the tip levies of the
U.S. government, Cardoen applied for his own U.S. patent on cluster
bombs in 1986. Based on some changes over previous designs, he received
the patent two years later. Getting the patent is not illegal, but at a
time when U.S. shipments of arms to Cardoen's home country of Chile were
banned, as were all sales to Iraq, why didn't the Patent Office raise any
questions about this foreigner dealing in U.S.-style arms? Experts
say bureaucratic infighting regularly causes such lapses. The
Department of Commerce, State and Defense are supposed to control arms
sales an communicate with one another.
<MR. CORDESMAN>: Even today, the same squabbling goes on every day
between Commerce, State, and Defense and at the same time, the
administration can never agree on what kinds of laws can be passed
to correct this.
<SHERR>: Carlos Cardeon declined a 20/20 request to speak on camera.
In an interview last year, he declined he had done anything wrong.
<CARLOS CARDOEN, Arms Dealer>: And as long as a human being is a person
that -- is an animal that needs to defend himself, weapons are going
to exist. I think that that is wrong. As a human being, I believe
that weapons are wrong, but they are a fact and we have to live with
the facts.
<SHERR>: The former head of ISC, James Guerin, who dealt with the
Chilean, said he did not provide anything to Cardoen to build weapons,
but Nasser Beydoun tells another story.
<MR. BEYDOUN>: I believe that Dr. Carlos Cardeon got the technology
of the cluster bomb from the Untied States.
<SHERR>: Questions about the cluster bombs come at a time when
attention is being focused on how many American-designed weapons
ended up in the hands of Saddam Hussein. Senator John McCain.
<SEN. JOHN McCAIN, (R) Arizona>: They're's not just one Saddam Hussein on
this globe, there's lots and lots of them who, as we speak, are attempting
to acquire the technology to give them this capability of weapons of
mass destruction because its a way to gain victory on the cheap.
<SHERR>: McCain has introduced legislation that would severely penalize any
any companies or countries that sell weapons illegally, or harbor arms
dealers.
<SEN. McCAIN>: But to provide the kinds of weapons that we have to
many nations throughout the world, which are clearly offensive in nature
clearly fare exceed their requirments to defend themselves, is frankly
unconscionable and must be brought to a stop.
<SHERR>: Basically, what you're saying is, "Hit them in the
pocketbook."
<SEN. McCAIN>: Hit them in the pocketbook and public exposure. No
Corporation or nation like to be branded a nation that is involved in
illicit traffic.
<SHERR>: But Public pressure and economic sanctions will not shield
American soldiers if Saddam Hussein uses the cluster bombs he already
has.
<SEN. McCAIN>: And if there is one good thing that may have come out
of this Persian Gulf was, it is to dramatically heighten the awareness
of the people of the world and the American people of how dangerous
this proliferation of weapons of mass destruction can be.
<DOWNS>: God, those things are vicious.
indictments yet, Lynn, on this?
any
<SHERR>: No, Hugh, no indictments yet. Carlos Cardoen has not been
indicted, even though federal agents raided his headquarters office in
Miami and U.S. Customs agents took a number of documents, but-- no
indictments yet, but there are investigations that are going on.
<DOWNS>: If these things are dropped from airplanes and we have air
supremacy, as has now been said by our leader, is there much to worry
about for our troops?
<SHERR>: We're told yes, because you don't need an airplane to drop a
cluster bomb. They can also be used on rocket-launchers and on unguided
missiles, both of which Iraq has. And incidentally, we talked about
that bomb factory. Even if it was badly damaged -- the cluster bomb
factory that he already has -- we're told that in three to six months
it can be operation again and anyway, he likely has a big stockpile.
<DOWNS>: We, of course, have these weapons also, but I don't understand,
that's called by something different.
<SHERR>: Yeah. If you're listening to a Pentagon briefing, don't
listen for the term "cluster bombs". They're calling them
"area denial weapons"
<DOWNS>:
<WALTERS>: Well, next, preparing American pilots for air combat aver
Iraq. Stone Phillips went to a Nevada Air Force Base-- dress rehearsals for
actual battle conditions. [COMMERCIAL]
DI= ************************************************************
10/12/91
1987 RECORDED AUDIO CONVERSATIONS "SELECTIVE CONVERSATIONS"
CD-ROM
TRACK
TITLE
DATE
PERSONS
BEGIN/END
TIME
_______________________________________________________________________
1
PA SEC I
09/29/87
ISC ALLEGATIONS
Howard Eissler
0000/0792 1 11 min
Bill Johnson 0-16-01 11-51-40
Robert Byers
Stan Caterbone
Sandra Gray
02/24/88
Sandra Gray
0793/1230
9.5 min
Stan Caterbone 11-51-58 20-14-00
Lanc. Aviation
07/10/87
Chuck Smith
1236/1467
3 5 min
Stan Caterbone 20-14-08 25-11-06
Dave Drubner
07/07/87
Dave Drubner
1470/1581 4 2.5 min
Stan Caterbone 25-11-10 27-43-26
Avalon Police
08/27/87
Avalon Police
Stan Caterbone
Gamillion
Studios, Inc.
07/21/87
Ted Gamillion
0435B/0671B
4 min
Stan Caterbone 52-26-15 56-57-00
Marcia Silen
Family
07/26/87
Stan Caterbone
Steve Caterbone
Phil Caterbone
Mike Caterbone
Tom Caterbone
1967 End A
Robertson
07/12/87
Scott Robertson
Stan Caterbone
0000B/0434B
Power
07/16/87
Station Studios
Bob Walters
0672B/0940B
5 min
Stan Caterbone 56-57-10 61-01-10
10
PA SEC II
10/28/87
Howard Eissler
0942B/1041B
3 min
Stan Caterbone 61-53-10 64-48-10
11
PA ATTORNEY
GENERAL OFFICE
10/28/87
12
NBC EXPOSE
01/21/91
Tom Brokow
"CORDEON ILLEGAL ARM SALES"
1582/1960
23 min
27-43-32 52-56-03
11 min
13
ABC 20/20
"MADE IN THE USA"
ISC FEATURE STORY
02/01/91
Barbara Walters
Lynn Sherr
Hugh Downs
11 min
STAN J. CATERBONE
(AS OF JULY 1,
1987)
DATE ESTIMATED PRESENT
LOST
VALUE
07/01/87
$140,000
Stanley J. Caterbone
07/01/87
$56,000
50,000 Shares of
$759,394
Financial Management
Stanley J. Caterbone
07/01/87
$500,000
Mortgage Banking
Stanley J. Caterbone
07/01/87
N/A
"MUTANT MANIA"
Stanley J. Caterbone
$6,751,000
Digital Movie & Tony Bongiovi
07/01/87
$4,000,000
Navaho "CHIEFTAIN"
$173,123
Airplane
Stanley J. Caterbone
07/01/87
$121,000
Stanley J. Caterbone
09/03/87
$350,000
VALUE
ASSET
OWNERSHIP
'91
N/A
Activities
______________________
___________
TOTALS
$490,000
$5,317,000
$9,381,338
IM=PORT.CPR
DI= PAGE 02
DI= ************************************************************
TI=\STAN CATERBONE NOTES OF NEGOTIATIONS WITH AMERICAN HELIX & HIGH, INC.
DA= April, 1990 to February 1991
SU= Legend: David D. Dering - President, Board of Directors, American Helix
Allon Lefever
Jim Tritch
- Board of Directors, American Helix
Executive Vice President, High Industries
<April, 1990:
Dave
Dave Dering "Stan, how did you get in here last night?".
Stan "Dave, what are you talking about?, I won't go near that building,
the last time I went back into my own building after being illegally
locked out, I end up in jail".
Dave Dering " How did you get in here and steal your fax?".
Stan "Dave, why would I want to steal the fax that I wrote?"
Dave Dering "You have caused a big problem. You put me in a difficult
position -- I don't know if I can rectify things with the 'High's' and
especially Allon Lefever. I always went to bat for you -- how do I
trust you?".
A meeting was set up for 6:00pm later that day.
DI= **********************
SU= <January 22, 1991: Stan Caterbone with Dave Dering>
Dave gave three (3) reasons for the "LOCKOUT", although never willing
to engage in any real conversations relating to those issues:
1. The computer system went down, causing a problem in the security
system.
2. Jim Boyer did not reinstall my access identification number for
the security system.
3. Jim Boyer was to talk to you on Friday, the day before the
lockout, concerning eliminating your access to the facility.
Dave said "Jim Boyer said that he can take over the CD-ROM business
-- no problem".
Dave talked about trust and who to trust. Dave reluctantly agreed to
continue our relationship, however only on an arms length basis. I
was no longer allowed in the building except during normal business
hours. I was no longer to have a private office.
Dave Dering never addressed the issues or the circumstances that
preceded the "LOCKOUT", and never addressed the reasons as to why
there was any reason to modify the agreement concerning my business
American Helix that was established back in June of 1990. There were
no disputes, activities, or conversations that gave any indication
that American Helix, Dave Dering, or Jim Boyer intended to change or
modify our relationship.
DI= **********************
SU= <January 24, 1991: Stan Caterbone with Allon Lefever>
Stan Caterbone called a meeting Allon Lefever to discuss the following:
1. The R.R. Donnelly merger and acquisition of American Helix.
2. The "LOCKOUT".
Allon asked questions regarding my contact with R.R. Donnelly and Barry
Glick. I quickly made it clear that Barry Glick contacted me in
December after seeing my advertisement in the CD-ROM Enduser magazine,
published by Linda Helgerson. Barry was elated to see someone in the
local area that was involved with CD-ROM technologies and asked to
visit with me. Allon asked many questions about Donnelly and Barry
Glick. I made it clear that during our visit, and from the discussions
regarding the strategic plan of Donnelly, I suggested that there may be
an opportunity for a merger or acquisition with American Helix. I also
discussed the capabilities for the facility to be a dedicated CD-ROM
manufacturing facility. I notified Allon that Barry was awaiting a
call from the next day concerning the appropriate contact to discuss
the subject of an acquisition. Allon assured me that the High's would
not contact Donnelly directly and would await a call from Barry Glick.
Regarding the "LOCKOUT" I gave the three reasons that Dave Dering had
provided during our meeting a few days before. I told Allon that after
"I had built a strong foundation for the CD-ROM business -- everybody
suddenly wants it back, six months ago, nobody wanted anything to do
with it, not to mention the capital that I had invested in it".
Allon Lefever was only concerned with why I had sent the Fax. "Why did
you send the Fax? I just don't understand why you sent the Fax". Allon
was not concerned with or wanted to discuss the issue of why I was
"LOCKED OUT".
Allon asked me the problems surrounding American Helix and what solutions
I thought could help restore the company to stability. I discussed the
lack of systems, the lack of a strong business foundation, and most
importantly the lack of management. He asked me about Dave Dering and
I responded "Dave Dering is an engineer, not a manager, he has no
real management skills".
I was also informed the previous day that David Dering was telling
persons that the reason that I was out of town in December was because
"I was on the run from authorities".
<February 21, 1991: NIST Project "Training Discs" (3 Disc Set)
The 3-Disc CD-ROM replication project for the National Institute of
Standards & Technology (NIST) was to be manufactured and shipped to
the DARPA Conference in Pacific Grove, California. The remaining
Stamper was to arrive from Disc Manufacturing Inc., by Federal Express.
The Mastering was scheduled for a 7-Day Turnaround, which should have
delivered all 3 stampers by Tuesday. CD ..1403 was already replicated
and a disc was submitted to John Fiscus at NIST several days before to
confirm and validate the integrity of the data by administering a byte
to byte comparison between the CD-ROM disc and the in-house database.
This is the most stringent and most accurate of any quality assurance
tests for CD-ROMs. Because of the complexity of the data, and the
UNIX operating system, this test is critical.
American Helix had replicated CD ..1403 and was beginning to run CD ..1404
when the controller board for the Mettalizer computer system brought
production to a halt. The stamper from Disc Manufacturing had arrived
that morning as anticipated, however it was still 2 days late.
The shipment of the NIST project was contingent upon the completion of
the inserts and tray cards from Golden Rule.
I required a 4-day
turnaround for the printing, I notified all production managers that
replication production would not begin until I received confirmation
from Golden Rule on Thursday morning that 20 sets of printed materials
had been shipped to the DARPA/NIST Conference in Pacific Grove, California.
The production requirements called for 20 completed sets to be shipped
to the DARPA/NIST conference on Friday.
<February 21, 1991>
On Thursday morning I confirmed that Golden Rule would meet the shipping
deadline that day. This 4-day turnaround was the second time that we
had successfully completed a less than 5-day turn for printed materials,
which on average takes the Audio group considerably longer.
However, a short time later I received a call from John fiscus of NIST
notifying me that the data from CD ..1403 had failed the validation test.
I immediately performed several diagnostics, and had found that although
the directory structure of the CD-ROM was complete, there seemed to be
data that was not physically located on the disc, although the file byte
count displayed the correct amount of data.
I immediately notified the production personnel at American Helix that
the NIST project would be put on hold until further notice. John Fiscus
had agreed to try to contact John Garofolo at the conference in order
to notify him that the shipment would not be arriving on Friday.
After evaluating the disc and the stamper, I had made a preliminary
diagnosis that the cause of the problem was result of a bad ISO 9660
8mm tape submitted by NIST, or a problem in converting the data to another
medium during the mastering process at Disc Manufacturing Inc.,. After
evaluating the quality control specifications of both the disc and the
stamper, it was highly unlikely that the CD-ROM disc contained data
that was not identical to that of the stamper or master.
I called Leon Whidbee, the engineer at Disc Manufacturing Inc., that
same day to notify him of the problem, and to immediately begin
diagnostic procedures in order to continue production and to deliver
product to NIST ASAP.
I explained the problem to Leon Whidbee, and he immediately explained that
he did not use the 8MM ISO 9660 tape to drive the mastering system as
expected. Leon Whidbee explained that the block size and the record
length of the tapes were not what he likes, and he had to down load that
tape to another format. I mentioned that I originally suspected a problem
in the conversion process, however I thought that a reoccurring problem
with the new 8mm system required the conversation to a 1630 tape.
Leon the attributed the problem to the fact that the file specs were not
within their parameters. I quickly asserted and made it perfectly clear
that I will not assume any responsibility or accountability in any
problem that occurred due to the file conversion. If the file was not
within the required specifications, Disc Manufacturing Inc., had the
responsibility to notify me so that I could have provided a new tape
that was within specifications required by DMI, Inc., I notified Leon
that DMI, Inc., must assume all financial responsibility if the problem
was the result of the conversion.
Leon Whidbee said that he would try to load the initial data in order to
diagnose the problem further. However, Leon, again expressed concern
that he was busy with other projects. I tried to inform him that this
was for a federal contract, and that we must find the problem ASAP in order
fulfill the requirements of the contract. He assured me that he would
at least load the data tomorrow, friday, and wanted the results of
the validation tests for the remaining discs.
<February 22, 1991>
On Friday, John Fiscus had confirmed that the second disc passed the
validation test. I notified him that the third and last disc was
finished, and that I would submit that disc for testing, by way of
overnight mail for delivery on Monday. I had called Leon Whidbee and
notified him that the second disc passed inspection and the third disc
would be inspected on Monday. He had not yet begun to begin any
diagnostics into the problem.
On Monday afternoon, I had called Giselle Venscel at Disc Manufacturing
Inc, (DMI) concerned because of the lack of cooperation or the lack
concern for a problem that exposing us to default on a federal government
contract. Giselle immediately gave the same old story song and dance about
not calling her, and that I should not be calling Leon. I again tried
to explain that I cannot be expected to discuss technical specifications
with a customer service person, and put my company at risk by having
expecting that person to first understand what I am talking about, and
second, interpreting that information to a qualified technical engineer.
That makes no sense at all. In addition, I see no one concern about the
real issue -- the bad data tapes.
In the middle of the conversation, Leon Whidbee called on the other line.
He finally had loaded the tapes, and I gave him the location of the data
that was missing. He did acknowledge that on the NIST ISO 9660 tape, that
there was evidence that the data was present. He then requested that I
submit a sample disc for further evaluation. I again suggested that He
immediately begin to produce the new tapes so that we can get the disc
manufactured. I explained that we should worry about the accountability
with the problem at a later time, after the client is take care of.
Later that day I received a call from John Fiscus, he requested that I
submit another disc for verification for the CD ..1402. I said he
would receive it tomorrow by Federal Express.
I faxed a request to Donna, the receptionist at American Helix, to
prepare the Federal Express label to the NIST laboratory. I prepared
a package for shipment to DMI.
At approximately 4:30 pm, on Monday, Donna phoned me and informed me that
Sheri Diebler and David Dering had revoked all Federal Express privileges
and postage privileges of Stan Caterbone and any CD-ROM activities. I
emphatically explained to her that these deliveries were required to
fulfill a Federal Contract with NIST, and that this action will provide
unfortunate risk for default of that contract.
THE PARCELS DID NOT GO OUT TO DMI, OR NIST, AS REQUIRED.
<February 26, 1991>
On Tuesday, I arrived at American Helix, and was immediately met by
David Dering. I immediately questioned him about why the Fed Ex packages
were not allowed to go out. He said, "Stan, you do not have and you never
had Federal Express or Postage privileges, they were not part of our deal".
I said " Dave, I have been Federal Expressing packages and using Postage
for the past 10 months, and that was part of our deal, what are you
talking about?, You have NIST quite upset, we you are holding up that
Job". Dave went into a song and dance about his budget, only after
becoming nervous when I challenged the fact that I have always been
using the Federal Express and the Postage at American Helix. He assured
me that both packages will be Federal Expressed immediately.
<February 27, 1991>
On Wednesday I talk to Giselle of DMI, Inc., to see if the production
of the stamper was started. She notified me that it won't start until
Leon Whidbee receives the sample disc. I said "What does that have to
do with the production of the new stamper?, why should NIST have to
wait until you find out who is responsible for the problem, let's just
take care of the client first, isn't that our job?. I finally said
"OK Giselle, when I get the stamper, I'll finish the job, I quite
fighting you people, Goodbye!!"
I later found out that the sample disc that was supposed to be mailed
overnight, was really shipped 2nd day air.
<February 28, 1991>
On Thursday, after arriving home from Washington, D.C., Dave Dering
asked about the NIST job, I said Dave, NIST is quite upset, and I am
not spending my time, playing silly games with people. When I get the
stamper, I'll finish the job, until then, I have more important matters
to tend to, because it doesn't matter how well I do my job.
Later, John Garafolo, of NIST called to discuss allegations of default
on CONTRACT 43NANB110167. I informed John, that American Helix is the
contractor, and you should discuss these issues with Dave Dering. I
cited several situations and actions by Dave Dering and American Helix
that continued to compromise my business, my reputation, and most
importantly the NIST Contract:
1. Unjustified and Illicit
2. Defamation of Character
3. Obstruction of Business
DI= **********************
TI=\ADVANCED MEDIA GROUP, Ltd.,
DA= February 13, 1991
SU= SUMMARY:
DONNELLY GEOSYSTEMS AND ADVANCED MEDIA GROUP, Ltd.,
STRATEGIC ALLIANCE
PRELIMINARY DRAFT
STRATEGIC PLAN
DEVELOPED BY:
STAN J. CATERBONE
STRATEGIC PLAN
1.
To pursue the development of information applications
utilizing the various digital technologies such as CDROM, Interactive Video Disc (IVD), Digital Video
Interactive (DVI), etc., for the non-traditional businesses
of Donnelly GeoSystems, and other R.R. Donnelly
divisions.
2.
To compliment the already existing information and
telecommunications efforts of R.R. Donnelly by
integrating the development of the above information
applications for specific niche markets that would result
in value added products and services utilizing the
already existing information assets of R.R. Donnelly.
3.
To specifically develop information applications from
end to end and to provide the additional support
necessary and required to take those respective
productions and services to the market at large.
4.
To provide and implement the necessary marketing
research and strategies to effectively develop a new
business of consumer and retail related businesses
involving the respective information applications.
5.
To research and develop new technologies for the
telecommunications businesses that would integrate the
information asset.
4.
To conduct market research and indications of interest
for the respective prototype.
5.
To evaluate the feasibility and the interest of both R.R.
Donnelly GeoSystems and the Advanced Media Group,
Ltd., for continuing the a relationship for the purpose of
pursuing the strategic plan.
DI= *****************************************************************
TI=\ADVANCED MEDIA GROUP, Ltd., CAPABILITIES AND CLIENT LISTING
IM=AMG.CPR
DA= February 17, 1990
AT= AUDIO TRACKS: /ALL
PA= PAGES: 11
SU= SUMMARY: The corresponding images will illustrate the
global efforts of the Advanced Media Group, Ltd., including:
HONG KONG; UNITED KINGDOM; CANADA; SOUTH AMERICAN; BRAZIL;
AUSTRALIA; AUSTRIA; SPAIN; GREECE; and SOUTH AFRICA.
The following is the "Capabilities Statement" used in
the marketing efforts of Stan Caterbone's Advanced Media Group, Ltd.,
Stan Caterbone developed the business in "Digital and Information
Technologies" after American Helix and High Industries elected to
discontinue the business after investing almost $ 1 million and
not being able to develop any real business.
Stan Caterbone was the only person responsible and the only person
with any real technical expertise in CD-ROM technology. In six
months Stan Caterbone surpassed the amount of revenues that American
Helix produced in 18 months. Stan Caterbone also completed one
of the most technical projects for the National Institute of Standards
and Technology (NIST). Phillips DuPont and Stan Caterbone were the only
firms to compete on the project because of its level of difficulty and
its required expertise.
Stan Caterbone was able to cause a fierce competition for the $2.5
million Department of Defense contract (DMA007-900-0011). Ironically
the two other competitors were the very same companies that had
been responsible for the development of CD-ROM, SONY (DADC) and
Phillips DuPont (PDO). Incidently, the procurement is currently under
investigation for possible misconduct after several grievances filed
by Stan Caterbone.
IM=AMG1.CPR
DI= PAGE 2
IM=AMG2.CPR
DI= PAGE 3
IM=AMG3.CPR
DI= PAGE 4
IM=AMG4.CPR
DI= PAGE 5
IM=AMG5.CPR
DI= PAGE 6
IM=AMG6.CPR
DI= PAGE 7
IM=AMG7.CPR
DI= PAGE 8
IM=AMG8.CPR
DI= PAGE 9
IM=AMG9.CPR
DI= PAGE 10
IM=AMG10.CPR
DI= PAGE 11
CAPABILITIES:
AMERICAN HELIX TECHNOLOGY CORPORATION
BACKGROUND
AmericanHelix was funded by High Industries, Inc., of
Lancaster, PA, in 1987. As a wholly owned subsidiary of the High
companies, AmericanHelix is joined by more than 40 companies
managed and operated by the $250 million a year conglomerate. High
Industries, Inc., currently serves the steel, precast/prestressed concrete,
and commercial/industrial construction industries; as well as operating
in industrial, commercial, and residential real estate, cable TV, food
services, management consulting and development, hospitality services,
communications and other related services.
AmericanHelix is situated in the 500 acre Greenfield Corporate
Center, graced with aesthetically pleasing architecture, beautiful
landscaping, broad walkways, fountains, and ponds. AmericanHelix
contrasts the contemporary rural setting with its illuminating high-tech
facility. The Advanced Media Group, LTD., which provides
information technologies, also operates an office in downtown
Washington, D. C., close to the government agencies.
AMERICAN HELIX SERVICES
AmericanHelix employees over 40 workers in its headquarters
and manufacturing facility. In the first quarter of 1990, the company
completed its first expansion, which doubled the output capacity of the
plant. AmericanHelix has the ability to produce more than 3.6 million
CD'S per year.
AmericanHelix provides services for the CD technology
industries. The state-of-the-art CD manufacturing facility was
completed in December of 1988. The facility features a unique 3rd
generation monoline processing module, designed and engineered by
David D. Dering, founder and president. This extremely automated
facility was designed and engineered with the objective of increasing
manufacturing yields through increased performances from its quality
techniques and processes. The facility manufactures both CD-AUDIO
AND CD-ROM discs.
MANUFACTURING
The CD manufacturing facility features a 10,000 class clean room for
CLIENT LIST
National Institute of
Standards & Technology (NIST)
Groller Electronic Publishing
E. Giovanetti
Dialcom
Vaghi Periodicles
Clahritas
Advanced Systems Development
Compaq Computers
Applied Optical Media Corp.
Commodore Business Machines
DRI/McGraw Hill
Meridian Data
Pennsylvania Blue Shield
INFO ONE International
University of Montana
National Technical Info Svc
Rochester Institute of Technology
NEC
Amp, Incorporated
Parkway School District
Hitachi Systems Division
Department of Commerce
Mathew Bender Co., Inc.
Nortek Computers, Ltd.,
University Microfilm International
Bell Atlantic
Aspen Systems Corporation
Microsoft CorporationRon Giordano
Arther AndersonAtlantic Beach Realty
PC Solutions Plus(609) 368-7023
Capitol RecordsMovie Real Estate
Digital Audio Disc Corporation (SONY)
Ingram Customer Systems
University of Hawaii at Manoa
National Bibliographic Service
International Business Machines (IBM)
Veterans Administration
DI= ************************************************************
TI=\PROFESSIONAL ASSOCIATES AND CLIENTS OF STAN CATERBONE
21093
Len Shendell
Columbia Asset Management
Twining Office Center
715 Twining Road
Dresher PA
19025
Jeff Springer
Diversified Investment Asso.
16 South Calvert Street
Suite 400
Baltimore MD
21202
Sal Belluardo
John G Berg Asso.
1 Logan Square
Suite 1105
Philadelphia PA
19107
Jeff King
National Properties Inc.
150 East Swedesford Road
Wayne PA
19087
Bob Fields
Manor Group
1377-C Spencer Avenue
Lancaster PA
17603
Mr.Rosenblatt
Max Gomburg
Gomburg Associates
995 Greentree Road
Pittsburgh PA
15220
Joel & Mimi Baron
Baron
601 East Chestnut Street
Lancaster PA
17602
RELATING TO THE ACTIVITIES OF THE DIGITAL FILM ("MUTANT MANIA")
Gene Clair
Clair Bros Studios
Lititz, PA
Sound Production
Barbara Peters
Arlene Davidson
Marcia Silen
Flatbush Films
4334 Stern Ave.
Sherman Oaks, CA 91423
(818) 995-3417
Movie Producers
Rhema
Video Service
Philadelphia, PA
(215) 738-3751
Movie Production
Tony Bongiovi
Bob Walters
Ellen Lipman
Power Station Studios
New York, NY
Movie Partners
Ted Gammilion
Mary Gamillion
Gamillion Studios
1137 N. McCadden Pl.
Hollywood, CA
90038
Mike Wolfe
Commonwealth Bank
(717) 780-3092
Loan Officer, Airplane
Mr. Cohouet
Mellon Bank
(412) 234-5000
Discussed Law Suit
regarding reposssession
ATTORNEYS AT LAW
Joseph Roda, PC
301 Cipher Building
36 E. King Street
Lancaster, PA
17602
(717) 397-3791
Robert D. Beyer
Arnold, Beyer, Homsher
110 E. King Street
Lancaster, PA
17602
(717) 394-7204
Lewis J. Schweller
Valore, McAllister,
Westmorland, Gould,
Vesper & Schwartz
Mainland Professional
535 Tilton Road
Northfield, NJ
08255
(609) 645-1111
Rick Fox, Attorney
Underwriters Group
Progress Ave
Harrisburg, PA
Jeff Jamounou
McNesse, Wallice & Nurick
Front Street
Harrisburg, PA
Barry Cappello
Diane Cambell
Coppello & Foley
831 State Street
Santa Barbara, CA
(805) 564-2444
Mike McDonald
Lancaster, PA
93101
17604
Joel Goldhammer
Sidel, Gonda, Goldhammer & Abbot
Philadelphia, PA
(215) 568-8383
Kerry Steigerwalt, ESQ.
5450 Kirkwood Dr. K-3
San Diego, CA 94521
Sandy Gray
c/o Kerry Steigerwalt
San Diego, CA
AUTHORITIES
Intercon Special Svc.
Frank Garrity
60 E. 42nd Street
Suite 1045
New York, NY
(212) 370-4430
Gib Armstrong
(717) 786-862
Cris Mele
Attorney General Office
(717) 782-4482
Corporate Acconting Office
P.O. Box Drawer 671
Dunkirk, NY
14048
11/25/87 Return
972386104
85 B48 10
Lancaster Chamber of Commerce
Dave Wouols
Lancaster, PA
State Police
Lincoln Hwy East
Lancaster, PA
Lancaster Police
N. Queen Street
Lancaster, PA
Governor Robert Casey
Harrisburg, PA
Federal Bureau of
Investigation, (FBI)
Fred Martin
(717) 232-8686
Pennsylvania Attorney General's Office
Detective Boden
Admitted Partners had a
Power of Attorney, talked
to him in July
PERSONAL REFERENCES (Witness to Activities of '87)
Linda Davis Vega
Orlando, Fl
Tuesday Barnette
431 S. Plum Street
Mount Joy, PA
(717) 653-4570
Rob Clark
West Palm Beach, FL
Maggy Brodesser
Cape May, NJ
(609) 886-6035
(609) 886-2782
Mike Orstein
York College
York, PA
(717) 560-0627
Tammy
Cape May, NJ
(609) 884-3425
Rudolph Valentino
(717) 299-1473
Ric Obrect
Calico Cat
Stone Harbor, NJ
(717) 394-8320
Bill Johnson
Lancaster, PA
(717) 285-3685
Michelle Hodge
Middletown, DE
(302) 378-4762
(609) 465-7924
CLIENTS OF STAN CATERBONE FOR FINANCIAL ADVISORY SERVICES
Dr. William Umiker
1350 Hillcrest Road
Lancaster, PA
17603
(717) 394-9936
Millard Johnson
Duff Ave.
Lancaster, PA
717) 285-3685
Richard Elson
East Petersburg, PA
Dickie Coho
Lancaster, PA
RELATING TO THE ACTIVITIES OF DIGITAL TECHNOLOGIES
David D. Dering
James Boyer
American Helix
1857 Colonial Village Lane
Lancaster, PA 17601
(717) 392-7840
Allon Lefever
Jim Tritcsh
High Industries, Inc.
William Penn Way
Lancaster, PA
17601
Linda Helgerson
Helgerson Associates
Publishers
510 N. Washington St.
Falls Church, VA 22046
(703) 237-0682
Steve Swan
Data Development
42 Flagler Ave
Stuart, FL 34995
(407) 288-7226
Gil Bowen
Data Development
19th & L Street, N.W.
Washington, DC
(202) 785-8822
Slavek R. Rotkiewicz
American Bankers Bond
New York, NY 10004
(212) 943-4202
Tom Vreeland
Amy Kovarick
Ann Richards
NETWORK TECHNOLOGIES
Springfield, VA
(703) 866-9000
Marshall Mathews
Terry Harple
Ferranti International
Lancaster, PA
(717) 285-7151
Charles Bauer, Sr.
Skip Strovel
B&B Information & Image
8325 Marlboro Pike
Upper Marlboro, MD
(301) 735-3690
Lucy Griffen
Joan Gervino
American Bankers
Association
1120 Connecticut Ave. N.W
Washington, DC 20036
(202) 663-5491
Dr. William Sailer
Trinity Church
205 N. Railroad St.
Myerstown, PA 17607
(717) 866-5775
Mike Kawahara
Commodore Computers
1200 Wilson Drive
West Chester, PA 19380
(215) 431-9452
Mike Grubbs
Tandy Electronics
Houston, TX 76102
(817) 390-3693
Lloyd E. Lewis
Library of Congress
Washington, DC
20541
(202) 707-1308
Dave Benfer
EXXON Production Research
3120 Buffalo Speedway
Houston, TX
77252-2189
Ed Bauergard
Amp, Inc.
2909 Fulling Mill Rd
Middletown, PA
(717) 986-7455
Harry Needleman
Labott Anderson
NASA Library
Washington, DC
Thomas Thiel
Scott
Kathey McKosky
Advanced Systems Development
Arlington, VA
Ken Rudolph
American Helix
Lancaster, PA
Kenneth Clark
Bell Atlantic
Democracy Blvd
Bethesda, MD 20817
(301) 493-3541
Carmen J. Martin
Ford New Holland
500 Diller Ave
New Holland, PA
(717) 355-1638
17557
Wayne Landis
PC Solutions
159 Windy Hill Road
Duncannon, PA 17020
(717) 834-9227
Jan L. Kloiber
Arthur Anderson
69 West Washington St.
Chicago, IL 60602
(312) 507-2548
Bruce Kline
Mike Hess
Miracle Concepts
Lancaster, PA
(717) 299-7382
Leroy J. Tuscher, Ph.D.
Lehigh University
111 Research Drive
Mountain Campus
Bethleham, PA
18015
(215) 758-3231
Earl H. Horton, Ed.D.
Superintendant
Hempfield School District
Landisville, PA 17538
(717) 898-5560
Cogressman Robert Walker
House of Representatives
Washington, D.C. 20515
Dave Gribbin
Assistant Secretary of Defense
Washington, D.C. 20301
OSD # 19043
William M. Nelson
Contracting Officer
Defense Mapping Agency
Department of Defense
3200 S. Second St.
St. Lois, MO 63118
(314) 263-8502
Stanley O. Smith
Brigadier General,
US AIR FORCE, CHIEF OF STAFF
Department of Defense
Defense Mapping Agency
Fairfax, VA
22031
John Garofolo, C.S.
Dr. David Pallet, Ph.D
Sandy Ressler
NIST (NATIONAL INSTITUTE OF STANDARDS & TECHNOLOGY)
Gaithersburg, MD
(301) 975-3193
Alan Hamerslee
Gisele Vencel
Leon Whidbee
Ash Pawha
Wan Segemiller
Disc Manufacturiing, Inc
1120 Cosby Way
Anahiem, CA
(714) 630-6700
Lance Buder
Sylvester Pufek
Optical Media Int'l
Los Alamos, CA
Bill Tufte
Standard Technology, Inc.,
6116 Executive Blvd
Rockville, MD 20852
(301) 770-2800
Pat Tomes
Paul A. Will
National Association of Clock Collectors
514 Poplar Street
Columbia, PA 17512
(717) 684-8261
Michael Morgatta
Technomic Publishing
continued
IM=2.CPR
DI= "THE FERRANTI FRAUD", continued
IM=3.CPR
DI= "THE FERRANTI FRAUD", LARRY RESCH, continued
IM=4.CPR
DI= "THE FERRANTI FRAUD", continued"
IM=38.CPR
DI= "GUERIN IS EXPECTED TO TESTIFY" (Roda)
DI= January 8, 1990
IM=36.CPR
DI= "GUERIN ARRIVES TO TESTIFY ON $2.75-MILLION DISPUTE" (Roda)
DI= January 9, 1990
IM=39.CPR
DI= "GUERIN SUED FOR SECRET TAPES" (Roda)
DI= January 10, 1990
IM=37.CPR
DI= "GUERIN SUED FOR SECRET...."
continued
IM=40.CPR
DI= "RECORDS SEIZED AT LOCAL HOME AID PROBE OF GUERIN-SOUTH AFRICA
(JACOBSON)"
DI= January 23, 1990 (BELGIUM, NEW YORK)
IM=5.CPR
DI= PAGE 5 "GUERIN: CLARK SAID HE COULD PUT ME IN PRISON FOR 50 YEARS"
DI= January 24, 1990
IM=6.CPR
DI= PAGE 6 "ILLEGAL CONTRIBUTIONS TO HAIG ALLEGED"
DI= January 24, 1990
IM=7.CPR
DI= PAGE 7 "HAIG DONATIONS", "FERRANTI SUES", "KEITH MARTIN"
DI= January 24, 1990
IM=8.CPR
DI= "HAIG DONATIONS", continued
IM=327.CPR
DI= "U.S. AGENT CHARGES GUERIN DIRECTED WORLDWIDE FRAUD"
DI= May 15, 1990
IM=10.CPR
DI= "JACOBSON GETS JAIL FOR ROLE IN BRIBE SCAM"
DI= May 16, 1990
IM=11.CPR
DI= "FBI TIES GUERIN TO ILLEGAL MILITARY SALES"
DI= May 16, 1990
IM=13.CPR
DI= "CHRISTIAN ANGERED BY JACOBSON'S SENTENCE"
DI= May 16, 1990
IM=14.CPR
DI= "COURT TOLD ATTORNEY CLARK TRIED TO STOP ISC 'CROOKS'"
DI= May 17, 1990
IM=15.CPR
DI= "CLARK, GUERIN", continued
IM=16.CPR
DI= "GUILT IS ADMITTED BY GUERIN COMPANY", PARENT INDUSTRIES, INC.,
DI= May 18, 1990
IM=19.CPR
DI= "GUERIN COMPANY GUILTY"
DI= May 18, 1990
IM=17.CPR
DI= "JUDGE TELLS GUERIN TO PAY $189 MILLION"
DI= June 18, 1990
IM=18.CPR
DI= "GUERIN LOSES CASE", continued
IM=32.CPR
DI= "FBI LINKS GUERIN TO S. AFRICAN ARMS SALES" (Jacobson)
DI= July, 1990
IM=20.CPR
DI= "PROBERS FINDING ISC'S S. AFRICAN TIES WERE CLOSE", ED SYSTEMS
DI= January 14, 1991
IM=21.CPR
DI= "ISC:CLOSE TIES TO SOUTH AFRICA PROBED", continued
IM=22.CPR
DI= "GUERIN vs. CLARK 'BLACKMAIL' TAPES REVEALED"
DI= February 7, 1991
IM=23.CPR
DI= "'BLACKMAIL'", continued
IM=24.CPR
DI= "LANCASTER AVIATION FILES FOR BANKRUPTCY"
DI= February 9, 1991
IM=25.CPR
DI= "GUERIN BREAKS SILENCE OVER '20/20' REPORTING"
DI= February 3, 1991
IM=27.CPR
DI= "STORY: DEALS BY ISC SENT IRAQ BOMBS, BUT GUERIN DENIES SALES"
DI= February 2, 1991
IM=29.CPR
DI= "JUDGE DELAYS HEARING IN GUERIN-CLARK DISPUTE OVER CASH"
DI= February 9, 1991
IM=STOCK.CPR
DI= "MANAGER ACQUITTED OF LYING IN SALE OF FERRANTI STOCK"
DI= February 14, 1991
DI= ************************************************************
TI=\IMPLICATED PERSONS EXEMPLIFYING MISCONDUCT AND IMPROPRIETIES
DA= February 17, 1991
SU= IMPLICATED PERSONS AND OR ENTITIES
COMMONWEALTH BANK,
MIKE WOLF