recorded case no. 15-10167 lancaster county court of common pleas complaint re caterbone v...
DESCRIPTION
Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015TRANSCRIPT
![Page 1: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/1.jpg)
IN THE COURT OF COMMON PLEAS OF LANCASTER COUNTY
CIVIL DIVISION
STANLEY J. CATERBONE :and :
:ADVANCED MEDIA GROUP : CASE NO. _________
Plaintiffs ::
v. ::
HOTEL BRUNSWICK :
and ::
ROGER FITZWATER, JR., :WOODCREST AUDIO :
and
THE JAMES STREET INVESTMENT DISTRICTand :
:THE LANCASTER FILM COMMISSION :
and ::
THE LANCASTER FILM COMMISSION :HONORARY BOARD MEMBERS :SENATOR GIBSON ARMSTRONG :CHARLES SMITHGALL :GLENN ROBINSON :LARRY ALEXANDER :MICHAEL O'DAY :BRAD HEPFER :TIMOTHY MARSDEN :
Defendants :
TO THE HONORABLE, THE JUDGES OF SAID COURT:
AND NOW comes Complainant, Stanley J. Caterbone, as pro se, and respectfully avers as follows:
Petitioner, Stanley J. Caterbone, resides at 1250 Fremont Street, Lancaster, PA, 17603, and Advanced
Media Group, Petitioners. The Complainant will also file a Motion for Leave In Forma Pauperis Status.
Petitioner files a civil complaint against the DEFENDANTS named in the above caption on this 20th
day of November, 2015.
_____________________________
Date: November 20, 2015 Stanley J. Caterbone, Pro Se LitigantAdvanced Media Group1250 Fremont StreetLancaster, PA [email protected]
CATERBONE v. Lancaster Film Commission, et.a., Page 1 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 1 of 198 Monday, November 23, 2015
![Page 2: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/2.jpg)
TEMPORARY INJUNCTION FOR RELIEF
Until this said Court is instructed to enforce either Civil Preliminary Emergency Injunction in cases
no. 08-13373, Preliminary Emergency Injunction for Relief of December 28, 2009 or Preliminary
Emergency Injunction for Relief Case No. 15-06985 the Complainant will suspend all activities of this case
due to the following:
AFFIDAVIT
I, Stanley J. Caterbone, Targeted Individual or TI, residing at: 1250 Fremont Street, Lancaster,
Pennsylvania, 17603, do hereby state that I am at least 18 years of age, that I am a citizen or a legal
resident of the United States of America, that I am of sound mind, and that I am the person whose
signature follows on this Affidavit. The purpose of this document is (1) to advise Congress as well as state
and local officials of organized stalking and electronic and mind manipulation torture being committed
against me and (2) to request a state, local, or Congressional investigation and hearing on the use of
remotely-operated directed energy attacks and mind control technologies on Americans in this country.
Our Government is responsible for protecting its citizens from elements that covertly harass,
torment, murder, and cause victims to commit suicide through organized stalking and remote electronic
torture. Yet, unbiased research indicates that certain elements of Government either engage in these
activities or protect those who perform them. I seek the complete dismantling of any officially-sanctioned
covert Government torture programs, the passage of legislation specifically outlawing that high-tech
torture, and the full prosecution of any person, regardless of his rank or position, who has violated my civil
rights and my most basic human rights. The assaults on my mind and body have been occurring for 24
year(s) and include, but are not limited to the following victimization's:
1.Blanketing my dwelling and surroundings with electromagnetic energy. Bombarding my body
with debilitating electronic and mind manipulation effects. Directed Energy Weapons Causing Severe Pain
to Body and Brain. Began in at least 2005 and still continuing, with complaints to Freedom From Covert
Harassment and Surveillance, FFCHS in 2009, and in cited in various state and federal court cases over
the past several years. Attacks causing severe artificial pain most likely from Directed Energy Devices
synchronized with telepathic harassment and organized stalking and harassment have been logged and
reported to law enforcement and medical professionals since 2008. Prior to 2008 the attacks were
experienced and reported to medical professionals but the sources were not known. Also reported attacks
of pain to a family physician, emergency room personnel and psychiatrists.
2.Invading my thoughts via remote sensing technologies.I Was sent an autonomous email in 1998
introducing the term remote viewing. Various technologies and tactics are being used to create
“emotional signatures” that induce various emotional states; a systematic complete hacking of my mind.
CATERBONE v. Lancaster Film Commission, et.a., Page 2 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 2 of 198 Monday, November 23, 2015
![Page 3: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/3.jpg)
3.Making me mentally “hear” others' voices through the microwave hearing effect. Synthetic
and/or Mental Telepathy. First started to experience telepathy/synthetic telepathy in 2005 with full-time
24/7 connection during the same time to present. When full-time telepathy started a male conducted
interrogations lasting several hours at a time concerning a wealth of subjects including ISC/CIA
Knowledge. Cannot disconnect from continuous conversations at all times with one female person. The
handlers know everything I know and experience in real time. During 2006 and 2007 have been telepathic
with some 10 or more persons, both male and female for short durations. Can recall most conversations
and subject matter with identities of who they said they were. Interrogation type harassment is still being
used telepathically to harass and for some sleep deprivation. Made first complaints to DARPA, the FBI,
and U.S. Senator Arlen Specter in 2007. Some conversations by the persons that are telepathic with me
elude to some program similar to the DARPA datalog program where they record your entire life.
Everything that you try to do on a daily basis is subject matter for conversation and harassment.
Interference with thought, harassment, and interrogation is used often times with electromagnetic weapon
attacks to the brain or body.
4.Depriving me of sleep due to neurological intervention. Mostly Experienced Sleep Deprivation
Techniques during periods of time in 2008 to 2010. Mostly with attacks of pain from Directed Energy
Weapons to back, neck, head (brain); and heart on a few occasions; and with harassment from telepathy.
5.Introducing poisonous gas and radiation toxins into my home. First experienced toxic gases
(Chloroform?) in heavy doses in 2006-2007. Made complaints to the Lancaster City Police Department
and the Southern Regional Police. Experienced attacks that would cause dizziness at home, in automobile
and in public. Was informed it was being released through a distribution system the size of fishing line.
To counter attacks used cotton in nostrils and gas mask. In 2009 experienced attacks of what is said to be
sleeping gas, when attacked could not open eyes. Took Pictures during some attacks.
6.Having me stalked en masse on foot and in vehicles. vandalizing my home and/or car. Gang
Stalking or Organized Stalking began in 1987 and continues today. It includes strangers using gestures
such as finger under eye; various forms of harassment; and public mobbing. Complaints have been filed
in 1987; 1992;1998 and 2005 to 2010. Complaints were made to various public officials and local, state,
and federal agencies as mental duress. The terms organized stalking, gang stalking, targeted individual,
etc., was not learned until a few years ago. The organized stalking and harassment followed in several
states, some while traveling from Lancaster, Pennsylvania to California. Tracking technologies may have
been used and most likely are still being used. Police were involved in most places.
7.Tapping (Bugging) my phones. Complaints of phone tapping/tampering were made to New Jersey
Bell in 1987 with a service call to Stone Harbor, New Jersey to check lines and phones. The same was
done by a Bell Atlantic repairman in Conestoga, Pennsylvania in 1998. In 2004 a complaint with a report
number was filed with the Pennsylvania Attorney General Office in Pittsburgh, Pennsylvania (Agent Amy
Zelnick) regarding interference with phone calls and impersonations by perps intercepting and rerouting
CATERBONE v. Lancaster Film Commission, et.a., Page 3 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 3 of 198 Monday, November 23, 2015
![Page 4: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/4.jpg)
calls. Computer Hacking complaints were filed to local authorities in the County of Lancaster and the
Cyber Crime unit of the Federal Bureau of Investigation in 2005 to 2010.
8.Blacklisting me in the labor market. Filed complains of employment discrimination with the
Pennsylvania Attorney General in 2006 and the Lancaster County Human Relations Commission in 2008.
9.Workplace mobbing. Experienced in 1987 at Financial Management Group, Ltd., American Helix of
High Industries in 1991 and Pflumm Contractors, Inc., in 1997/1998, and in the Federal, State, and Local
Courts. Filed complaints and logs as mental duress and harassment. Was forced out of all 3 organizations
as a result of the mobbing and harassment.
10.Public Mobbing. Public type mobbing and organized stalking and harassment was perpetrated heavily
in the years 2005 to 2010 in the following places: The Lancaster County Courthouse, The Lancaster
County Public Library, the Pennsylvania Career Link, and the Millersville University Library and University
Offices. I was given suspicious and illegal “No Trespass” Notices in some 18 public places in Lancaster
County in the years 2005 to 2009 without just cause. I was complaining of stalking and harassing in most
all of those public places. The Lancaster County Public Library and the Millersville University took away
my access to a computer after my personal computers were vandalized and/or hacked inoperable. Fulton
Bank took away my safe deposit box. Others included my church of worship, various bars and restaurants
and one attorneys office. Complaints have been filed regarding the same in courts and with various
authorities.
11.Attempted Murder. Experienced with an attempt of vehicular homicide in 1991 after National News
Media reported ISC/CIA-NSA connection of “Arms to Irag”. The incident involved a vehicle changing
lanes and direction and heading directly toward me in the wrong direction running me off the road,
narrowly missing a tree. I Filed the incident in federal courts and used as a motion to seal federal case
no. 05-2288 in 2005 in the United States District Court for the Eastern District of Pennsylvania.
12.Pet Killing. Cat was killed in 2005 with complaints to the Lancaster County Humane Shelter and the
Southern Regional Police Department.
13.Illegal Entries of Home/Properties. First in 1987 in Stone Harbor, New Jersey, then again in 1991;
1997-1998; and most serious in 2005 to 2010. Filed Police Reports and insurance claims, most with the
Southern Regional Police Department of Conestoga, Pennsylvania , State Farm and Harleysville Insurance
Companies.
14.Illegal Repossessions. Airplane in 1987 containing legal and business files. Home/Property and
Contents in 2006 also containing legal and business files and documents.
CATERBONE v. Lancaster Film Commission, et.a., Page 4 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 4 of 198 Monday, November 23, 2015
![Page 5: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/5.jpg)
15.Physical Assaults. One attack and filed complaint with police report in Los Osos California in 2005 and
numerous in the City of Lancaster, including on November 19, 2015; reported to the Manheim Township
Police at about 1:00pm. Police reports were filed and obtained for most
16.False Arrests. Experienced 7 in 1987 and more than 22 in 2005 and 2006 in the Commonwealth of
Pennsylvania Lancaster County Court of Common Pleas. The false arrests were charges that were all
dismissed prior to court hearings.
17.False Imprisonments. Spent 7 to 10 days in Lancaster County Prison in 1987 with all charges
dismissed and again for some 60 days in 2006 with all charges dismissed. The 60 Days of imprisonment of
2006 was triggered with a false report of missing a bail supervision meeting, which was confirmed to be
false in court; however bail was maliciously and purposefully reinstated as secured instead of unsecured.
The appropriate appeal was filed which secured my release after some 60 days of false imprisonment.
There were no charges that resulted in any convictions.
18.Psychiatric Abuses with False Suicide Allegations from Perpetrators/Stalkers. One in 1987
resulting in a forced hospitalization for several hours by police in Stone Harbor, New Jersey. And one
again in February of 2005 resulting in police restraining me in my home and abusing me. This one was a
fraudulent and phony email sent to police by a perp. The Southern Regional Police had to vacate after the
email was proven to be a fraud. Again in 2009, 2010, and 2015.
19.Vandalism to Property. First in 1987 in Stone Harbor, New Jersey, then again in 1991; 1997-1998;
and most serious in 2005 to 2010. Filed Police Reports and insurance claims, most with the Southern
Regional Police Department of Conestoga, Pennsylvania and Harleysville Insurance Company. 3
computers have been rendered inoperable since 2005 along with various electronics equipment; dvd
recorders; printers; household items; appliances; etc., Most insurance claims have been paid. In the past
years a wave of purchased items, online and in stores, were received broken or the wrong item and all
had to be returned. Some included items to secure my property, and others included computer related
items, others were household and clothing items. Last report to the Lancaster City Police on November 19,
2015 to Officer Sgt. Cosmore.
20.Gas Lighting. The illegal entering of home and causing psychological duress by moving items and or
hiding items. First reported in 1998 to the Conestoga Police and continued to present. Clothing was also
manipulated and altered. The term “gas lighting” was only learned in 2010, although it was reported to
police as harassment by neighbors of friends. The daily draining of my hot tub was also used as a
psychological warfare tactic and used to run up utility bills. Numerous complaints were made to police in
2008 to 2010.
CATERBONE v. Lancaster Film Commission, et.a., Page 5 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 5 of 198 Monday, November 23, 2015
![Page 6: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/6.jpg)
21.Thefts of Property. Not Yet Completed.
22.Vandalism to Car/Truck. Since 2005 have experienced years of gas siphoning, battery outages,
letting air out of tires, and wetting of inside of floor mats as psychological warfare tactics by perps and
stalkers. Made numerous complaints the Lancaster City Police Department.
23.Toxic Chemical Causing Running Nose. Experienced on regular basis in 2009 when in public places.
Was not in conjunction with cold/flu symptoms. Research states it is a tactic used in organized stalking.
Heavy doses in the fall of 2015.
24.Computer Hacking. Computer Hacking complaints were filed to local authorities in the County of
Lancaster and the Cyber Crime unit of the Federal Bureau of Investigation in 2005 to 2010. Numerous
complaint numbers have been secured. Complaints of cell phone hacking was also reported in 2010.
Websites and blogs were regularly hacked and sometimes taken off-line. Electronic calenders, court
documents, and financial records were often hacked causing many problems of the years, including having
to withdraw civil complaints. Filed documentation in U.S.C.A. Case No. 15-3400 as EXHIBIT.
25.Cyber Stalking. Most in 2005 to 2010, and 2015. Complaints to Microsoft legal counsel, Yahoo
Message Board, and the FBI Cyber Crime Unit.
26.Interference/Delay/Theft of U.S. Mails. First reported to U.S. Postmaster of mail tampering and
illegal changing of address in 1987. In 2008 to 2009 have made several more complaints to the U.S.
Postmaster Inspector General who claim to have begun investigations. Some caused missed court
hearings and other missed appointments and or meetings. Made Complaints during U.S. District Case No.
14-02259 and U.S.C.A. 15-3400 through November 20, 2015.
27.Electromagnetic Weapons Causing Severe Muscle Spasms/Cramps. First experienced in 2006 to
present. One experience in 2006 was while I was in my hot tub and the pain and cramp was so severe in
my left calf muscle (you automatically bend over to rub it out, which placed my head underwater) I had to
crawl out of the hot tub before almost drowning.
28.Electromagnetic Weapons Causing Sexual Stimulation. First experienced in 2005.
29.Forced Hospitalizations. Forced Hospitalizations in 1987 (2) one for 6 hours and one for 5 days;
2006 one for 3 days; 2009 one for several hours while in intensive care for emergency surgery; and 2010
one for 8 days. Filed complaints to Citizens Commission for Human Rights in 1991 and 2008.
CATERBONE v. Lancaster Film Commission, et.a., Page 6 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 6 of 198 Monday, November 23, 2015
![Page 7: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/7.jpg)
30.Manipulation and Theft of Documents. Numerous thefts and manipulation of all legal and business
documents both in paper and in electronic format have occurred since 1987. Microfiche/Microfilming
began in 1987 and other measures to secure documents have been ongoing to present. Numerous
complaints have been filed with law enforcement since 1987.
CATERBONE v. Lancaster Film Commission, et.a., Page 7 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 7 of 198 Monday, November 23, 2015
![Page 8: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/8.jpg)
CIVIL COMPLAINT
INTRODUCTION
CATERBONE and ADVANCED MEDIA GROUP have suffered irreparable harm to it’s reputation and to
it’s efforts to continue it’s business operations while as a petitioner in a Chapter 11 Reorganization
Plan filed on May 23, 2005 in the United States Bankruptcy Court for the Eastern District as case
no. 05-23059.
CATERBONE and ADVANCED MEDIA GROUP were also continuing a decade long investment in
projects located in the Downtown Lancaster Investment District that have been maliciously
sabotaged with ease due to the gross abuse; negligence; and abuse of process of the Lancaster
City Bureau of Police coupled with the false arrests and the malicious prosecutions. Three main
projects include a UPS Shipping and Copy Store (CATERBONE retains an exclusivity agreement with
UPS); Excelsior Place Business Plan; and the Downtown Theater at Hotel Brunswick1. CATERBONE
and the ADVANCED MEDIA GROUP have been an active advocate and supporter of the Downtown
Lancaster Convention Center and the revitalization of Downtown Lancaster and have demonstrated
a record of support and advocacy through its meeting and communications with major
stakeholders, public officials, and attendance at public meetings. In November of 2007,
CATERBONE and the Advanced Media Group went public with their Downtown Lancaster
investments and business plans that were culminated over the past 9 years. The Advanced Media
Group also formerly and publicly introduced their Downtown Lancaster Action Plan2 via handouts,
websites, and blogs; and began meetings and negotiations with major stakeholders, City of
Lancaster Public Officials, Developers, and investors.
CATERBONE has formerly applied to be on the Lancaster Convention Center Authority Board of
Directors in 2007 and has petitioned for a seat on the Lancaster County Government Study Group
in 2006.
The PLAINTIFF, Stanley J. Caterbone (CATERBONE), alleges that the City of Lancaster and the
Lancaster City Bureau of Police and others colluded to deliberately ignore CATERBONE’S
complaints, an abuse of process, in an effort to retaliate, subvert, interrupt and deter current and
ongoing litigation and civil complaints against several major businesses and government agencies
with headquarters in the City of Lancaster and the Commonwealth of Pennsylvania. Those would
include the Lancaster General Hospital; High Industries (not Penn Square Partners and the
Lancaster County Convention Center); Fulton Bank and Fulton Financial Corporation; a Wachovia
Bank branch (pending); Lancaster Newspapers; the County of Lancaster; the Lancaster County
Prison; the Hotel Brunswick (pending); James Street Investment District (pending); Aurora Films;
Haverstick Films (pending); and the Lancaster City Bureau of Police. The City of Lancaster and the
1 A description and narrative can be seen on the Advanced Media Groups blog “Journey of a Whisleblower” at www.
2 The Downtown Lancaster Action Plan can be viewed on the Advanced Media Groups blog “Journey of a Whisleblower” at www.
CATERBONE v. Lancaster Film Commission, et.a., Page 8 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 8 of 198 Monday, November 23, 2015
![Page 9: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/9.jpg)
Lancaster City Bureau of Police are derelict in their duties in forcing CATERBONE to litigate for
duties and services due CATERBONE that are mandated in the bylaws of the City of Lancaster.
CATERBONE also alleges that the Lancaster City Bureau of Police were used to retaliate, subvert,
interrupt and deter other litigation and civil complaints against other police departments, namely
the Southern Regional Police Department, the Manheim Township Police Department, the East
Lampeter Police Department, the Millersville Boro Police, the Avalon Police Department and the
Stone Harbor Police Department. CATERBONE alleges that Southern Regional Police Chief John
Fiorill used is official capacity as President of the Red Rose Chapter of the Fraternal Order of Police
to help accomplish these civil torts.
CATERBONE alleges that by ignoring his complaints the Lancaster City Police Bureau of Police gave
the green light, or approval, for others to continue a long and successful period of harassment,
thievery, property damage, computer and electronic hacking, deletion and manipulation of court
related documents, records and evidence, mail fraud, eaves dropping, invasion of privacy, criminal
trespass, and the like. These activities are so intense that they have taken on the characteristics
of a hate crime.
CATERBONE alleges that the gross abuse and gross negligence defamed his name and that of his
company, ADVANCED MEDIA GROUP, which discredited his reputation in an effort to diminish
credibility in the courts; to thwart any reprimands by oversight agencies; and to disrupt and thwart
any possible business relations and operations of ADVANCED MEDIA GROUP. This has resulted in
direct and immediate financial loss, loss of time, and loss of income.
CATERBONE had complained of abuse of process to state and federal law enforcement regarding
the situation, including U.S. Senator Arlen Specter’s office. CATERBONE had also visited the
Federal Bureau of Investigation (FBI) in both Harrisburg and Philadelphia for help and intervention.
CATERBONE also had personal meetings with Lancaster City Mayor Rick Gray in Lancaster City Hall
on at least 4 occasions to find a solution to the problems and for help to mediate the problems and
or resolve the conflicts. The resulting pain and suffering, as well as loss and destruction of
property and financial loss that CATERBONE was undergoing was unprecedented.
In November of 2007, CATERBONE and the Advanced Media Group went public with their
Downtown Lancaster investments and business plans that were culminated over the past 9 years.
The Advanced Media Group also formerly and publicly introduced their Downtown Lancaster Action
Plan via handouts, websites, and blogs; and began meetings and negotiations with major
stakeholders, City of Lancaster Public Officials, Developers, and investors.
CAUSES OF ACTION
On March 18, 2008 CATERBONE went to the Hotel Brunswick in Downtown Lancaster to continue
take measurements of the Movie Theater for his continued efforts of a business and development
plan. (The Brunswick Movie Theater, or Eric, had been closed since 1995. CATERBONE and
Advanced Media Group had an agreement with the Owner of the Brunswick, Hamid Zahedi, to
make a formal proposal and offer for leasing the site. CATERBONE had begun discussions in 2006.)
CATERBONE v. Lancaster Film Commission, et.a., Page 9 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 9 of 198 Monday, November 23, 2015
![Page 10: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/10.jpg)
CATERBONE noticed that the United States Department of Justice Office of Trustee was conducting
hearings for Chapter 11 petitioners in the Presidential Room of the Hotel Brunswick3.
CATERBONE thought maybe Dave Adams, the trustee for the United States Department of Justice
Office of Trustee might be conducting the hearings4. CATERBONE had gone to the Presidential
Room and had a discussion with the person administering the Bankruptcy Hearings.
The following day CATERBONE received a disturbing email from Mr. Barry A. Solodky, Esquire, of
Blakinger, Byler & Thomas, P.C., 28 Penn Square, Lancaster, PA 17603. CATERBONE had known
Mr. Solodky since the 1980’s and had even solicited him to review his bankruptcy matters before
the Appllent filed his Chapter 11 case on May 23, 2005. The following email exchanges detail the
incident and the false reports and allegations from a member of Blakinger, Byler & Thomas, P.C.:
Subject: Date: Thu, 20 Mar 2008 08:18:00 -0400From: [email protected]: [email protected] Hi Stan,Hope this note finds you well. Yesterday afternoon I had to attend some bankruptcy meetings on behalf of some clients. While there the Trustee told me about an event which concerned her. She showed me your
3 CATERBONE had not received ORDERS from his United States Third Circuit Court of Appeals Case No. 08-3054 for his appeal of an issue in his Chapter 11 Case No. 05-23059. CATERBONE alleged that the ORDERS were stolen or never mailed from the clerk of courts.
4 Sometime in February of 2008 by way of computer hacking or misconduct within the staff of the Clerk ofCourt of the Third Circuit Court of Appeals, CATERBONE was erroneously and maliciously placed onelectronic email distribution with no paper copies for all of his ORDERS for all of his cases, which at thattime numbered four (4), without the knowledge of CATERBONE. After receiving one of the email alertsand ORDERS CATERBONE personally visited the Clerk of Court for the Third Circuit and was told by staffthat it was just a new courtesy copy. The staff did not notify CATERBONE that his cases would not beeligible for paper copies of ORDERS. CATERBONE was alleging since February that his ORDERS werebeing stolen in the U.S. mails, and only received information in April on the bottom of a copy of a letterattached to an ORDER for Case No. 3054 that he was switched to electronic email distribution with nopaper copies. This makes no sense since, filing as pro se, CATERBONE is not eligible to file any electronicdocuments in any U.S. or Pennsylvania Courts without a Pennsylvania Bar License. On several occasionssince February 2008, CATERBONE was not able to open the Third Circuit electronic ORDERS on the firstattempt, which denied CATERBONE access or knowledge of the Third Circuit ORDERS with no way ofretrieving them again. CATERBONE was not even able to respond or know how the United States ThirdCircuit Court of Appeals had ruled or what ORDERS were handed down, which also denied CATERBONEany chance to follow court mandated responses in a timely fashion. On May 29, 2008 at approximately9:15 am CATERBONE called Ms. Charlene Ciscaden, case manager for the U.S. Third Circuit of Appealsthat manages CATERBONE’S cases from his cell phone (717) 669-2163). Ms. Ciscaden stated thefollowing:
o 1. Motion for Extension of 07-4475 GRANTED on May 22, 2008o Motion for Extension of 07-4474 GRANTED on May 27, 2008o The U.S. Third Circuit Court of Appeals has no electronic email address for me.o Stan J. Caterbone/Advanced Media Group was never taken off of paper copies for any U.S.
Third Circuit Court of Appeals ORDERS, MOTIONS, or ANY COMMUNICATIONS.o All ORDERS, MOTIONS, and COMMUNICATIONS have been sent via 1st Class U.S. Postal
Service.
CATERBONE v. Lancaster Film Commission, et.a., Page 10 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 10 of 198 Monday, November 23, 2015
![Page 11: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/11.jpg)
card and told me what happened. In fact she said she almost considered calling the police because of the incident. I assured her you were not the type of person that would do anything inappropriate. I did want you to know she is not an employee of the Dept. of Justice or the Bankruptcy Court; she is a private panel trustee just as I was for 33 years. If for some reason you have issues with the bankruptcy system she is not a person who should be hassled as she has nothing to do with your case. I'm sending this only because I don't want there to be any further incidents which might cause her concern or the Federal marshals will get involved and I know they can be nasty. Needless to say I don't want to see anything to you which would cause you any problems. I am sure I will bump into you soon. Have a nice Easter.
Barry A. Solodky, EsquireBlakinger, Byler & Thomas, P.C.28 Penn SquareLancaster, PA 17603(717) 509-7273
14. CATERBONE’s Response to Mr. Barry A. Solodky’s email:
RE: Meeting wih the Dept of Justice.From: Stan Caterbone ([email protected])Sent: Sat 3/22/08 8:36 AMTo: Barry A. Solodky ([email protected])
Cc: FBI, Field Office ([email protected]); Landis, Detective Michael([email protected]); [email protected]
Bcc:
March 22, 2008
Re: Meeting With Department of Justice
Barry Solodky,
First, I would have responded earlier, however, your email found it's way into my junkemail.
Secondly, as an officer of the court, you better be careful about spreading lies about meand fabrications about events that did not happen. By the way, a copy of this will godirectly to the Federal Bureau of Investigation Philadelphia Field Office and DetectiveMichael Landis of the Lancaster County District Attorney Office. Who do you think you aretalking to?
Thirdly, here is what transpired. The day before I received an ORDER from the Third CircuitCourt of Appeals, which was purposely postmarked 10 days after the Clerk filed and datedthe Mail to copy to myself. The ORDER was for a no response to a Show Cause ORDER,which someone had stole from my mail, which I never received. The Third Circuit case wasan appeal from my Chapter 11 bankruptcy.
Now, on Wednesday morning I made plans to go to the Hotel Brunswick and take somemeasurements in the Movie Theater, which I am in the middle of a development plan. Asusual, I walked into the lobby on the street level adjacent to the parking garage and sawthe easel with the notice that the "Department of Justice" was holding bankruptcy hearings. I was told a few years ago earlier in my Chapter 11 that they often hold hearings inLancaster, at the Brunswick or at the Hotel on Manheim Pike. As soon as I saw the sign I
CATERBONE v. Lancaster Film Commission, et.a., Page 11 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 11 of 198 Monday, November 23, 2015
![Page 12: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/12.jpg)
figured I would see if Joe Adams, my Trustee from the Philadelphia Office of theDepartment of Justice Office of Trustee that handles my case, was here.
So, as I usually do, I went to the office of Kevin, the Hotel Brunswick General Manager toget the key to the movie theater, as per our agreement with Hamid, the owner of the HotelBrunswick. He was not in his office, and the Desk Manager had to page him. I asked himwhere the Department of Justice was holding the hearings, and told him I needed to talk tosomeone there, while he was trying to locate Kevin, the General Manager. I told him Iwould be right back.
I went to the Presidential Room where they were holding meetings. When I arrived,the Trustee, or what private panel trustee, was conducting a meeting with a Spanishwoman, who had a young girl for a translator. I patiently waited by the wall as you walk inuntil the entire interview was over. After the private panel trustee dismissed the woman, Iapproached her and asked her if she was from the Department of Justice Office of theTrustee, and she responded that she was a private panel trustee. I simply told her that Ihad a problem with someone obstructing justice with my Third Circuit case and asked her ifJoe Adams was in her office. She said she was not from the Philadelphia Office. I gave hermy card and some woman kept trying to talk and interfere. I just calmly left. I went tomeet Kevin, the General Manager, he opened the movie theater and I spent approximately1 hour taking measurements of the existing floor plan.
There was no incident to speak of. Any incident was a lie, regardless of the person thatkept interfering with our conversation that was trying to cause problems. It was not me,you fool.
I would suggest that you provide this email to the person that told you that fabricated lieand anyone else that you communicate with regarding your so called version of an"incident". Follow this link and you may read why people like you lie about these incidents.
Now, you have a nice Easter Weekend. And by the way, I am a supporter of Senator Clinton andI do volunteer my services, just in case you were wondering.
Advanced Media GroupStan J. Caterbonewww.amgglobalentertainmentgroup.com
On April 22, 2008 the Plaintiff, Stan J. Caterbone (CATERBONE) visited the office of the owner of
the Hotel Brunswick, Hamed …… (HAMED) to discuss the reasons for the delay in delivering the
business plan and development plan for the Downtown Theater at Hotel Brunswick, as promised.
Upon entering the office, HAMED claimed to have sent CATERBONE a letter notifying he was no
longer allowed on the premises because CATERBONE allegedly disrupted a meeting.
CATERBONE responded by first stating that CATERBONE never received such a letter.
CATERBONE then responded that CATERBONE never disrupted a meeting, nor did CATERBONE ever
here of any such incident except the email from Attorney Barry Solodky.
CATERBONE put HAMED on notice that CATERBONE would summon authorities and “handle” the
situation. CATERBONE assumed that the HOTEL BRUNSWICK and HAMED were leaked some of the
preliminary business and development plan from CATERBONE’S computer and wanted the theater
project for themselves or another party, as with the LANCASTER FILM COMMISSION, and the
JAMES STREET BUSINESS DISTRICT.
CATERBONE immediately went to the Office of Lancaster City Mayor Rick Gray to report the
incident.CATERBONE v. Lancaster Film Commission, et.a., Page 12 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 12 of 198 Monday, November 23, 2015
![Page 13: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/13.jpg)
CATERBONE had direct talks and personal meetings with both Pennsylvania Senator Gibson
Armstrong and Pennsylvania House of Representative Michael Sturla regarding obtaining grants for
funding some of the theater project because of the independent film strategy. Both were
optimistic, although the staffer (Mr. Thompson) for AMRSTRONG noted that someone had
approached ARMSTRONG about a movie theater downtown, and immediately put down
CATERBONE’S efforts and the location and site.
CATERBONE had also talks and negotiations with HAMED for the corner storefront of Chestnut and
Queen Streets for the UPS/FEDEX Copy Store.
In 2008 CATERBONE had several discussions with Mary Haverstick of Haverstick Films to discuss
the possibility of working together on the Downtown Theater at Hotel Brunswick. CATERBONE had
known Mary Haverstick since the 1980’s.
Ms. Haverstick was very interested in supporting the project and a future meeting was being
scheduled to begin formal discussions.
On --------------- CATERBONE had a meeting with Aurora Films in their office on North Queen
Street in Lancaster, Pennsylvania.
On ---------------- CATERBONE had a meeting with Mr. Jay Ingram, Executive Director and founder
of the Lancaster Film Commission.
On ---------------- CATERBONE signed an agreement with Roger Fitzsimmons, owner and operator
of Woodcrest Audio to work on the project.
On --------------- CATERBONE signed an agreement with Jeff Lefevre regarding the development of
the Excelsior Place building on East King Street, in Downtown Lancaster.
CATERBONE v. Lancaster Film Commission, et.a., Page 13 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 13 of 198 Monday, November 23, 2015
![Page 14: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/14.jpg)
CAUSES OF ACTION BY DEFENDANTS
HOTEL BRUNSWICKHAMED ……………….
ROGER FITZWATER, JR., WOODCREST AUDIO
THE JAMES STREET INVESTMENT DISTRICT
THE LANCASTER FILM COMMISSION
THE LANCASTER FILM COMMISSION HONORARY BOARD MEMBERSSENATOR GIBSON ARMSTRONGCHARLES SMITHGALLGLENN ROBINSONLARRY ALEXANDERMICHAEL O'DAYBRAD HEPFERTIMOTHY MARSDEN
Collusion to Commit Fraud; Libel; Civil Conspiracy; Harasment; Civil Rights Violations; RICO Violations;Anit-Trust Violations; Theft of Property; Unjust Enrichement; Violations of Intellectual Property Rights.
Damages
Loss of reputation and credit; humiliation; and mental suffering discomfort; injury to health; loss of time;economic loss due to business and litigation interruption; loss of opportunity; legal fees and punitivedamages.
Plaintiffs seeks jury trial and damages in excess of $100,000.
CATERBONE v. Lancaster Film Commission, et.a., Page 14 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 14 of 198 Monday, November 23, 2015
![Page 15: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/15.jpg)
CAUSES OF ACTION BY DEFENDANTS
CAUSES OF ACTIONS IN COMPLAINT
Barratry, in criminal and civil law, is the act or practice of bringing repeated legal actions solely to harass.Usually, the actions brought lack merit. This action has been declared a crime in some jurisdictions. For example, in the U.S. states of California, Pennsylvania, and Virginia, barratry is a misdemeanor. [1] In England and Wales the offence was abolished in 1967.
Malicious prosecution is a common law intentional tort. While similar to the tort of abuse of process, its elements include (1) intentionally (and maliciously) instituting or pursuing (or causing to be instituted or pursued) a legal action (civil or criminal) that is (2) brought without probable cause and (3) dismissed in favor of the victim of the malicious prosecution. In some jurisdictions, "malicious prosecution" is reserved for the wrongful initiation of criminal proceedings, while "malicious use of process" refers to the wrongful initiation of civil proceedings.
Criminal prosecuting attorneys, as well as judges, are normally protected, by doctrines of prosecutorial immunity and judicial immunity, from tort liability for malicious prosecution.
The mere filing of a complaint cannot constitute an abuse of process. The parties who have abused or misused the process, have gone beyond the mere filing of a lawsuit. The taking of an appeal, even a frivolous one, is not enough to constitute an abuse of process. The mere filing or maintenance of a lawsuit, even for an improper purpose, is not a proper basis for an abuse of process action.
Abuse of process is a common law intentional tort. It is to be distinguished from malicious prosecution, another type of tort that involves misuse of the public right of access to the courts.
The elements of a valid cause of action for abuse of process in most common law jurisdictions are as follows: it is the malicious and deliberate misuse or perversion of regularly issued court process (civil or criminal) not justified by the underlying legal action. "Process" in this context is used in the same sense asin "service of process," where "process" refers to an official summons or other notice issued from a court. The person who abuses process is interested only in accomplishing some improper purpose that is collateral to the proper object of the process and that offends justice, such as an unjustified arrest or an unfounded criminal prosecution. Subpoenas to testify, attachments of property, executions on property, garnishments, and other provisional remedies are among the types of "process" considered to be capable of abuse.
Vexatious litigation is legal action which is brought, regardless of its merits, solely to harass or subdue an adversary. It may take the form of a primary frivolous lawsuit or may be the repetitive, burdensome, and unwarranted filing of meritless motions in a matter which is otherwise a meritorious cause of action. Filing vexatious litigation is considered an abuse of the judicial process and may bring down sanctions on the offender.
A single action, even a frivolous one, is not enough to raise a litigant to the level of being declared vexatious. Roy L. Pearson, Jr., an Administrative Law Judge in the District of Columbia, who sued a dry-cleaner for $54 million for allegedly losing a pair of his trousers, is sometimes claimed to be a vexatious litigant; however, he does not have a history of frivolous action like the parties normally considered vexatious.[citation needed
In criminal law, fraud is the crime or offense of deliberately deceiving another in order to damage them – usually, to obtain property or services unjustly. [1] Fraud can be accomplished through the aid of forged objects. In the criminal law of common law jurisdictions it may be called "theft by deception," "larceny by trick," "larceny by fraud and deception" or something similar.
Fraud can be committed through many methods, including mail, wire, phone, and the internet (computer crime and internet fraud).
CATERBONE v. Lancaster Film Commission, et.a., Page 15 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 15 of 198 Monday, November 23, 2015
![Page 16: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/16.jpg)
Fraud, in addition to being a criminal act, is also a type of civil law violation known as a tort. A tort is a civil wrong for which the law provides a remedy. A civil fraud typically involves the act of intentionally making a false representation of a material fact, with the intent to deceive, which is reasonably relied upon by another person to that person's detriment. A "false representation" can take many forms, such as:
A false statement of fact, known to be false at the time it was made; A statement of fact with no reasonable basis to make that statement; A promise of future performance made with an intent, at the time the promise was made, not to
perform as promised; A statement of opinion based on a false statement of fact; A statement of opinion that the maker knows to be false; or An expression of opinion that is false, made by one claiming or implying to have special knowledge
of the subject matter of the opinion. "Special knowledge" in this case means knowledge or information superior to that possessed by the other party, and to which the other party did not have equal access.
In law, defamation (also called vilification, slander, and libel) is the communication of a statement that makes a false claim, expressively stated or implied to be factual, that may harm the reputation of an individual, business, product, group, government or nation. Slander refers to spoken comments, while libel refers to any other form of communication such as written words or images. Most jurisdictions allow legal actions, civil and/or criminal, to deter various kinds of defamation and retaliate against groundless criticism. Related to defamation is public disclosure of private facts arises where one person reveals information which is not of public concern, and the release of which would offend a reasonable person.[1] "Unlike libel or slander, truth is not a defense for invasion of privacy."[2]
False light laws are "intended primarily to protect the plaintiff's mental or emotional well-being."[3] If a publication of information is false, then a tort of defamation might have occurred. If that communication isnot technically false but is still misleading then a tort of false light might have occurred.[3]
Slander and libel
The common law origins of defamation lie in the torts of slander (harmful statement in a transitory form, especially speech) and libel[4][5] (harmful statement in a fixed medium, especially writing but also a picture, sign, or electronic broadcast), each of which gives a common law right of action.
"Defamation" is the general term used internationally, and is used in this article where it is not necessary to distinguish between "slander" and "libel". Libel and slander both require publication.[6] The fundamental distinction between libel and slander lies solely in the form in which the defamatory matter is published. If the offending material is published in some fleeting form, as by spoken words or sounds, sign language, gestures and the like, then this is slander. If it is published in more durable form, for example in written words, film, compact disc (CD), DVD, blogging and the like, then it is considered libel.
Criminal defamation
Many nations have criminal penalties for defamation in some situations, and different conditions for determining whether an offense has occurred. ARTICLE 19, Global Campaign for Free Expression, has published global maps [2] charting the existence of criminal defamation law across the globe. The law is used predominantly to defend political leaders or functionaries of the state. In Britain, the Italian anarchistErrico Malatesta was convicted of criminal libel for denouncing the Italian state agent Ennio Belelli in 1912.While, in Canada, though the law has been applied on only six occasions in the past century, all of those cases involve libellants attached to the state (police officers, judges, prison guards). In the most recent case, Bradley Waugh and Ravin Gill were charged with criminal libel for publicly accusing six prison guardsof the racially motivated murder of a black inmate (http://netk.net.au/Canada/Canada15.asp. In Zimbabwe, "insulting the President" is, by statute, (Public Order and Security Act 2001) a criminal offense.
CATERBONE v. Lancaster Film Commission, et.a., Page 16 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 16 of 198 Monday, November 23, 2015
![Page 17: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/17.jpg)
Defenses
Even if a statement is derogatory, there are circumstances in which such statements are permissible in law.
Truth
In many legal systems, adverse public statements about legal citizens presented as fact must be proven false to be defamatory or slanderous/libel. Proving adverse, public character statements to be true is oftenthe best defense against a prosecution for libel and/or defamation. Statements of opinion that cannot be proven true or false will likely need to apply some other kind of defense. The use of the defense of justification has dangers, however; if the defendant libels the plaintiff and then runs the defense of truthand fails, he may be said to have aggravated the harm.
Another important aspect of defamation is the difference between fact and opinion. Statements made as "facts" are frequently actionable defamation. Statements of opinion or pure opinion are not actionable. In order to win damages in a libel case, the plaintiff must first show that the statements were "statements of fact or mixed statements of opinion and fact" and second that these statements were false. Conversely, a typical defense to defamation is that the statements are opinion. One of the major tests to distinguish whether a statement is fact or opinion is whether the statement can be proved true or false in a court of law. If the statement can be proved true or false, then, on that basis, the case will be heard by a jury to determine whether it is true or false. If the statement cannot be proved true or false, the court may dismiss the libel case without it ever going to a jury to find facts in the case.
In some systems, however, notably the Philippines, truth alone is not a defense.[7] Some U.S. statutes preserve historical common law exceptions to the defense of truth to libel actions. These exceptions were for statements "tending to blacken the memory of one who is dead" or "expose the natural defects of one who is alive." [8]
It is also necessary in these cases to show that there is a well-founded public interest in the specific information being widely known, and this may be the case even for public figures. Public interest is generally not "that which the public is interested in," but rather that which is in the interest of the public.[9]
[10]
See also: Substantial truth
Privilege and malice
Privilege provides a complete bar and answer to a defamation suit, though conditions may have to be met before this protection is granted.
There are two types of privilege in the common law tradition:
"Absolute privilege" has the effect that a statement cannot be sued on as defamatory, even if it were made maliciously; a typical example is evidence given in court (although this may give rise todifferent claims, such as an action for malicious prosecution or perjury) or statements made in a session of the legislature (known as 'Parliamentary privilege' in Commonwealth countries).
"Qualified privilege" may be available to the journalist as a defense in circumstances where it is considered important that the facts be known in the public interest; an example would be public meetings, local government documents, and information relating to public bodies such as the policeand fire departments. Qualified privilege has the same effect as absolute privilege, but does not protect statements that can be proven to have been made with malicious intent.
CATERBONE v. Lancaster Film Commission, et.a., Page 17 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 17 of 198 Monday, November 23, 2015
![Page 18: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/18.jpg)
Other defenses
Defenses to claims of defamation include:
Truth is an absolute defense in the United States as well as in the common law jurisdictions of Canada. In some other countries it is also necessary to show a benefit to the public good in having the information brought to light.
Statements made in a good faith and reasonable belief that they were true are generally treated the same as true statements; however, the court may inquire into the reasonableness of the belief. The degree of care expected will vary with the nature of the defendant: an ordinary person might safely rely on a single newspaper report, while the newspaper would be expected to carefully check multiple sources.
Privilege is a defense when witness testimony, attorneys' arguments, and judges' decisions, rulings, and statements made in court, or statements by legislators on the floor of the legislature, or statements made by a person to their spouse, are the cause for the claim. These statements aresaid to be privileged and cannot be cause for a defamation claim.
Opinion is a defense recognized in nearly every jurisdiction. If the allegedly defamatory assertion is an expression of opinion rather than a statement of fact, defamation claims usually cannot be brought because opinions are inherently not falsifiable. However, some jurisdictions decline to recognize any legal distinction between fact and opinion. The United States Supreme Court, in particular, has ruled that the First Amendment does not require recognition of an opinion privilege.
Fair comment on a matter of public interest, statements made with an honest belief in their truth on a matter of public interest (official acts) are defenses to a defamation claim, even if such arguments are logically unsound; if a reasonable person could honestly entertain such an opinion, the statement is protected.
Consent is an uncommon defense and makes the claim that the claimant consented to the dissemination of the statement.
Innocent dissemination is a defense available when a defendant had no actual knowledge of the defamatory statement or no reason to believe the statement was defamatory. The defense can be defeated if the lack of knowledge was due to negligence. Thus, a delivery service cannot be held liable for delivering a sealed defamatory letter.
Claimant is incapable of further defamation–e.g., the claimant's position in the community is sopoor that defamation could not do further damage to the plaintiff. Such a claimant could be said to be "libel-proof," since in most jurisdictions, actual damage is an essential element for a libel claim.
In addition to the above, the defendant may claim that the allegedly defamatory statement is not actually capable of being defamatory—an insulting statement that does not actually harm someone's reputation is prima facie not libelous.
Special rules apply in the case of statements made in the press concerning public figures. A series of courtrulings led by New York Times Co. v. Sullivan, 376 U.S. 254 (1964) established that for a public official (orother legitimate public figure) to win a libel case, the statement must have been published knowing it to be false or with reckless disregard to its truth, (also known as actual malice).
Under United States law, libel generally requires five key elements. The plaintiff must prove that the information was published, the plaintiff was directly or indirectly identified, the remarks were defamatory towards the plaintiff's reputation, the published information is false, and that the defendant is at fault.
The Associated Press estimates that 95% of libel cases involving news stories do not arise from high-profile news stories, but "run of the mill" local stories like news coverage of local criminal investigations ortrials, or business profiles. Media liability insurance is available to newspapers to cover potential damage awards from libel lawsuits.
CATERBONE v. Lancaster Film Commission, et.a., Page 18 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 18 of 198 Monday, November 23, 2015
![Page 19: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/19.jpg)
Defamation and freedom of speech
Defamation laws may come into tension with freedom of speech, leading to censorship or chilling effects where publishers fear lawsuits, or loss of reputation where individuals have no effective protection against reckless or unfounded allegations. Article 10 of the European Convention on Human Rights permits restrictions on freedom of speech which are necessary for the protection of the reputation or the rights of others[11].
Jurisdictions resolve this tension in different ways, in particular in determining where the burden of proof lies when unfounded allegations are made. The power of the internet to disseminate comment, which mayinclude malicious comment, has brought a new focus to the issue. [12]
There is a broader consensus against laws which criminalize defamation. Human rights organizations, and other organizations such as the Council of Europe and Organization for Security and Co-operation in Europe, have campaigned against strict defamation laws which criminalize defamation.[13][14] The EuropeanCourt of Human Rights has placed restrictions on criminal libel laws because of the freedom of expression provisions of the European Convention on Human Rights. One notable case was Lingens v. Austria (1986).
United States
Main article: United States defamation law
The origins of US defamation law pre-date the American Revolution; one famous 1734 case involving JohnPeter Zenger established some precedent that the truth should be an absolute defense against libel charges. (Previous English defamation law had not provided this guarantee.) Though the First Amendmentof the U.S. Constitution was designed to protect freedom of the press, for most of the history of the UnitedStates, the Supreme Court neglected to use it to rule on libel cases. This left libel laws, based upon the traditional common law of defamation inherited from the English legal system, mixed across the states. The 1964 case New York Times Co. v. Sullivan, however, dramatically changed the nature of libel law in the United States by establishing that public officials could win a suit for libel only if they could demonstrate publishers' "knowledge that the information was false" or that it was published "with recklessdisregard of whether it was false or not". Later Supreme Court cases dismissed the claim for libel and forbade libel claims for statements that are so ridiculous to be clearly not true, or are involving opinionated subjects such as one's physical state of being. Recent cases have addressed defamation law and the internet.
Defamation law in the United States is much less plaintiff-friendly than its counterparts in European and the Commonwealth countries, due to the enforcement of the First Amendment. In the United States, a comprehensive discussion of what is and is not libel or slander is difficult, because the definition differs between different states, and under federal law. Some states codify what constitutes slander and libel together into the same set of laws. Criminal libel is rare or nonexistent, depending on the state. Defenses to libel that can result in dismissal before trial include the statement being one of opinion rather than fact or being "fair comment and criticism". Truth is always a defense.
Most states recognize that some categories of statements are considered to be defamatory per se, such that people making a defamation claim for these statements do not need to prove that the statement was defamatory.
CATERBONE v. Lancaster Film Commission, et.a., Page 19 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 19 of 198 Monday, November 23, 2015
![Page 20: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/20.jpg)
IN THE COURT OF COMMON PLEASOF LANCASTER COUNTY, PENNSYLVANIA
PROTHONOTARYCIVIL COVER SHEET
Note: CAO SCHEDULING COVER SHEET MUST BE ATTACHED,IF AN EVENT NEEDS TO BE SCHEDULED.
PLEASE TYPE OR PRINT LEGIBLY ALL INFORMATION REQUESTED.PLEASE LIST NAMES, ADDRESSES AND SOCIAL SECURITY NUMBERS
OF ADDITIONAL PARTIES ON A SEPARATE SHEET.
DO NOT STAPLE THE COVER SHEET TO THE PLEADING ZIPCODES ARE REQUIRED & INFORMATION MUST MATCH PLEADING
CASE ID:
PLAINTIFF'S NAME VS DEFENDANT 'S NAMESTANLEY J. CATERBONE Lancaster Film Commission, et.al.,Pro, SeADDRESS: ADDRESS:1250 Fremont St, Lancaster, PA 17603 TELEPHONE #: 717-669-2163 TELEPHONE #:
SSN#200-46-0959 SSN#
TYPE OF ACTION: Jury Trial Demanded: NoArbitration: Yes
Name of Firm and Filing Attorney OR Filing Party, Address, TelephoneNumber, AOPC Number Firm:
Filing Attorney/Party: Stanley J. Caterbone AOPC #Address: 1250 Fremont Street,City: LancasterTelephone Number: 717-669-2163Fax Number:
Signature: /S/ Stanley J. Caterbone
CATERBONE v. Lancaster Film Commission, et.a., Page 20 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 20 of 198 Monday, November 23, 2015
![Page 21: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/21.jpg)
CERTIFICATE OF SERVICE
CATERBONE v. Lancaster Film Commission, et.a., Page 21 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 21 of 198 Monday, November 23, 2015
![Page 22: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/22.jpg)
https://www.scribd.com/stan5j.5caterbone
Stan J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
(717)669-2163
PRESS RELEASE
Saturday, July 4, 2015
Lancaster, Pennsylvania, Advanced Media Group and Stan J. Caterbone Proposed ORGANIZED
STALKING AND DIRECTED ENERGY WEAPONS HARASSMENT BILL to Pennsylvania House of Representative Mike Sturla (Lancaster, Pennsylvania) and City of Lancaster Mayor Richard Gray.
The draft legislation is the work of Missouri House of Representative Jim Guest, who has been working on helping victims of these horrendous crimes for years. The bill will provide protections to
individuals who are being harassed, stalked, harmed by surveillance, and assaulted; as well as protections to keep individuals from becoming human research subjects, tortured, and killed by electronic frequency devices, directed energy devices, implants, and directed energy weapons.
Stan J. Caterbone has been a victim of organized stalking since 1987 and a victim of electronic and direct energy weapons since 2005. He has also been telepathic since 2005. Stan J. Caterbone will help introduce measures that also pertain to remote viewing; mental telepathy and synthetic
telepathy in more detail. Personal accounts of his pain and torture are also filed in various United States federal and state courts. We are urging you to contact your local representatives and support our efforts to pass this
legislation. Below you will find the listings of Pennsylvania State Representatives.
For More Information Please Contact Us At: [email protected] and visit our library of
documents at https://www.scribd.com/stan5j.5caterbone
_________________________________________________
The draft of the legislation can be found on the following page:
Page 1CATERBONE v. Lancaster Film Commission, et.a., Page 22 of 70 Friday, November 20, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 22 of 198 Monday, November 23, 2015
![Page 23: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/23.jpg)
District OfficeSecond StreetKing City Mo.660-535-6664
To Whom It May Concern,
This letter is to ask for your help for the many constituents in our country who are being affected unjustly by electronic weapons torture and covert harassment groups. Serious privacy rights violation and physical injuries have been caused by the activities of these groups and their use of so-called non-lethal weapons on men, women, and even children.
I am asking you to play a role in helping these victims and also stopping the massive movement in the use of Veri-chip and RFID technologies in tracking Americans.
Long before Veri-chip was known we were testing these devices on Americans, many without their knowledge or consent.
There are new revelations of the cancer risk besides the privacy and human rights problems with the use of Veri-chip and RF signals. I am asking for your help in stopping these abuses and aiding those already affected.
Sincerely,
Rep. Jim Guest
May 21, 2009
Capitol OfficeState Capitol
Jefferson City Mo.573-751-0246
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 23 of 198 Monday, November 23, 2015
![Page 24: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/24.jpg)
Organized Stalking and Directed Energy Devices and Weapons Bill
Section 1. Short Title -
This bill may be cited as the “Organized Stalking and Directed Energy Devices and Weapons
Bill”””
Section 2. Findings and Purpose
A) Findings
1) The constitution guarantees the right of the people to be secure in their person. The Declaration
of Independence asserts as self-evident that all men have certain inalienable rights and that among
these are life, liberty, and the pursuit of happiness.
2) As Supreme Court Justice Louis Brandeis wrote in 1928, “the framers of the Constitution sought
"to protect Americans in their beliefs, their thoughts, their emotions, and their sensations." It is for
this reason that they established, as against the government, the right to be let alone as "the most comprehensive of rights and the right most valued by civilized men.“
3) The first principle of the Nuremberg Code states that with respect to human research, the
voluntary consent of the human subject is absolutely essential. The Nuremberg Code further asserts that such consent must be competent, informed, and comprehending.
4)There are current regulations implementing the obligations of the United States to adhere to
Article 3 of the United Nations Convention Against Torture and other Forms of Cruel, Inhumane or Degrading Treatment including all terms that are Subject to any reservations, understandings, declarations, and provisions contained in the United States Senate resolution of ratification of the
Convention.
B) Purpose
To establish regulations and penalties for those who use any type of electronic frequency devices,
directed energy devices, implants, surveillance technology, and directed energy weapon to
purposefully cause any of the following: stalking, harassing, mental or physical harm, injury, harmful surveillance, torture, diseases, and death to any United States citizen.
Section 3. Organized Stalking
If two or more persons willfully, maliciously, and repeatedly follow or willfully and maliciously
harass another person and who make a credible threat with the intent to place that person in reasonable fear for his or her safety, or the safety of his or her immediate family, they are guilty of the crime of organized stalking, punishable by imprisonment in a county jail for not more than one year, or by not more than one thousand dollars ($ 1,000), or by both that fine and imprisonment,
or by imprisonment in a federal prison.
If two or more persons violate subdivision (a) when there is a temporary restraining order,
injunction, or any other court order in effect prohibiting the behavior described in subdivision (a) against the same party, they shall be punished by imprisonment in the state prison for two, three,
or four years.
For the purposes of this section, "harass" means engages in a knowing and willful course of
conduct directed at a specific person that seriously alarms, annoys, torments, or terrorizes the
person, or damages his personal property or possessions and that serves no legitimate purpose. * * *
Page 2
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 24 of 198 Monday, November 23, 2015
![Page 25: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/25.jpg)
For the purposes of this section, "course of conduct" means two or more acts occurring over a
period of time, however short, evidencing a continuity of purpose. Constitutionally protected
activity is not included within the meaning of "course of conduct."
For the purposes of this section, "credible threat" means a verbal or written threat, including that
performed through the use of an electronic communication device, or a threat implied by a pattern
of conduct or a combination of verbal, written, or electronically communicated statements and conduct, made with the intent to place the person that is the target of the threat in reasonable fear for his or her safety or the safety of his or her family, or personal property or possessions and made with the apparent ability to carry out the threat so as to cause the person who is the target
of the threat to reasonably fear for his or her safety or the safety of his or her family or personal property or possessions. It is not necessary to prove that the defendant had the intent to actually carry out the threat. The present incarceration of a person making the threat shall not be a bar to
prosecution under this section. Constitutionally protected activity is not included within the meaning of "credible threat."
For purposes of this section, the term "electronic communication device" includes, but is not limited
to, telephones, cellular phones, computers, video recorders, fax machines, pagers or synthetic telepathy devices.
The sentencing court also shall consider issuing an order restraining the defendant from any
contact with the victim, that may be valid for up to 10 years, as determined by the court. It is the intent of the Legislature that the length of any restraining order be based upon the seriousness of the facts before the court, the probability of future violations, and the safety of the victim and his
or her immediate family.
For purposes of this section, "immediate family" means any spouse, parent, child, any person
related by consanguinity or affinity within the second degree, or any other person who regularly
resides in the household, or who, within the prior six months, regularly resided in the household.
Section 4. Punishment for threats
Any person or persons who willfully threatens to commit a crime which will result in death or great
bodily injury to another person, with the specific intent that the statement, made verbally, in
writing, or by means of an electronic communication device, is to be taken as a threat, even if there is no intent of actually carrying it out, which, on its face and under the circumstances in which it is made, is so unequivocal, unconditional, immediate, and specific as to convey to the person threatened, a gravity of purpose and an immediate prospect of execution of the threat, and
thereby causes that person reasonably to be in sustained fear for his or her own safety or for his or her immediate family's safety, shall be punished by imprisonment in a federal prison not to exceed one year..
For the purposes of this section, "immediate family" means any spouse, whether by marriage or
not, parent, child, any person related by consanguinity or affinity within the second degree, or any other person who regularly resides in the household, or who, within the prior six months, regularly
resided in the household.
"Electronic communication device" includes, but is not limited to, telephones, cellular telephones,
computers, video recorders, fax machines, pagers or synthetic telepathy devices
Obscene, threatening or annoying communication
(a) Every person or persons who, with intent to annoy, telephones or makes constant contact by
means of an electronic communication device with another and addresses to or about the other person any obscene language or addresses to the other person any threat to inflict injury to the
person or any member of his or her family, or any property or personal possessions is guilty of a misdemeanor. Nothing in this subdivision shall apply to telephone calls or electronic contacts made in good faith.
Page 3
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 25 of 198 Monday, November 23, 2015
![Page 26: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/26.jpg)
(b) Every person or persons who makes repeated telephone calls or makes repeated contact by
means of an electronic communication device with intent to annoy another person at his or her residence, is, whether or not conversation ensues from making the telephone call or electronic contact, is guilty of a misdemeanor. Nothing in this subdivision shall apply to telephone calls or
electronic contacts made in good faith.
(c) Every person or persons who makes repeated telephone calls or makes repeated contact by means of an electronic communication device with the intent to annoy another person at his or her place of work is guilty of a misdemeanor punishable by a fine of not more than one thousand
dollars ($ 1,000), or by imprisonment in a federal prison for not more than one year, or by both that fine and imprisonment. Nothing in this subdivision shall apply to telephone calls or electronic contacts made in good faith. This subdivision applies only if one or both of the following circumstances exist:
(1) There is a temporary restraining order, an injunction, or any other court order, or any
combination of these court orders, in effect prohibiting the behavior described in this section.
(2) The person or persons makes repeated telephone calls or makes repeated contact by means of
an electronic communication device with the intent to annoy another person at his or her place of work, totaling more than 10 times in a 24-hour period, whether or not conversation ensues from making the telephone call or electronic contact, and the repeated telephone calls or electronic
contacts are made to the workplace of an adult or fully emancipated minor who is a spouse, former spouse, cohabitant, former cohabitant, or person with whom the person has a child or has had a dating or engagement relationship or is having a dating or engagement relationship.
(d) Any offense committed by use of a telephone may be deemed to have been committed where
the telephone call or calls were made or received. Any offense committed by use of an electronic communication device or medium, including the Internet, may be deemed to have been committed
when the electronic communication or communications were originally sent or first viewed by the recipient.
(e) Subdivision (a), (b), or (c) is violated when the person acting with intent to annoy makes a
telephone call requesting a return call and performs the acts prohibited under subdivision (a), (b), or (c) upon receiving the return call.
(f) If probation is granted, or the execution or imposition of sentence is suspended, for any person
or persons convicted under this section, the court may order as a condition of probation that the person participate in counseling.
(g) For purposes of this section, the term "electronic communication device" includes, but is not
limited to, telephones, cellular phones, computers, video recorders, fax machines, pagers or synthetic telepathy devices.
Section 5. Assault and battery with an electronic or directed energy weapon
Any person or persons who in the course of organized stalking and harassment, commits an assault
upon the person of another with an unauthorized directed energy weapon shall be punished by
imprisonment in a federal prison for two, three, or four years or by a fine not exceeding ten thousand dollars ($10,000).
For the purposes of this section the term directed energy weapon is defined as any device that
directs a source of energy (including molecular or atomic energy, subatomic particle beams, electromagnetic radiation, plasma, or extremely low frequency (ELF) or ultra low frequency (ULF) energy radiation) against a person or any other unacknowledged or as yet undeveloped means of
inflicting death or injury; or damaging or destroying, a person (or the biological life, bodily health,
Page 4
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 26 of 198 Monday, November 23, 2015
![Page 27: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/27.jpg)
mental health, or physical and economic well-being of a person via land-based, sea-based, or space-based systems using radiation, electromagnetic, psychotronic, sonic, laser, or other energies
directed at individual persons or targeted populations for the purpose of information war, mood management, or mind control of such persons or populations; or by expelling chemical or biological agents in the vicinity of a person.
Page 5
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 27 of 198 Monday, November 23, 2015
![Page 28: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/28.jpg)
Richmond council passes resolution supporting ban on space-based weapons
May 20, 2015FacebookTwitterMore9 comments
The Richmond City Council passed a resolution Tuesday supporting a ban on space-based weapons after a lengthy discussion over whether individuals are being psychologically and physically harmed by exotic government-patented attacks from high in the sky.
Councilmember Jovanka Beckles, a member of the Richmond Progressive Alliance (RPA), introduced the resolution, saying it begins to address concerns of a Richmond resident who claims she’s been targeted by “remote transmission” from space-based weaponry. Others claiming to have suffered physical and psychological attacks traveled from around the country to speak at Tuesday’s council meeting. One speaker claimed to have been zapped multiple times right before his testimony at council.
The resolution supports the Space Preservation Act and Space Preservation Treaty permanently banning “space-based weapons,” even though the legislation first introduced by Rep. Dennis Kucinich in 2001 has never gained traction in Congress. It appears that Richmond is the first municipality in the U.S. to take up this lofty issue in more than a decade. In 2002, the City of Berkeley passed a similar resolution supporting the ban.
Conspiracy theorists believe the resolution is a step toward ensuring secret weaponry such as chemtrails, which are trails left in the sky by high-flying aircraft that supposedly emit a chemical or biological agent, can no longer target unwitting citizens. For RPA members on the council, the resolution is also an anti-war initiative.
RPA members on council, Gayle McLaughlin and Eduardo Martinez, also voted in favor of the resolution. Vice Mayor Jael Myrick and Councilmember Nat Bates were the final two yes votes, although Bates claimed he was confused by the discussion.
“I’m going to support the resolution for the simple reason that we have voted on a lot of
Page 8
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 28 of 198 Monday, November 23, 2015
![Page 29: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/29.jpg)
dumb ideas,” Bates said.
Mayor Tom Butt voted no, saying he believes the conspiracy theory behind space-based weapons is above the heads of city leaders and has taken time away from more pressing city matters such as the budget deficit, potholes, and crime. Butt has complained in the past about the RPA attempting to hijack council sessions to push a radical agenda regardless of whether the issues are important to Richmond residents.
The mayor also pointed to a signed 1967 treaty banning the militarization of space.
The other dissenting vote came from Councilmember Vinay Pimple, who pointed out that supporting a limitation on the ability of the U.S. to defend against attacks from long-range missiles might not be wise.
Pimple disputed what he called “knee-jerk” reactions from RPA members who depicted President Ronald Reagan’s proposed space-based anti-missile program of 1983, known as the “Star Wars” initiative, as inherently evil. The Cold War initiative was intended to defend against USSR missiles during the Cold War and was shelved not for the project’s moral ambiguity but its perceived effectiveness, Pimple said.
The idea behind Star Wars, Pimple said, “is you can knock out someone’s weapons long before they enter your air space. The U.S. used Patriot missiles to knock out Iraqi Scuds targeting Israel and Saudi Arabia, he added.
RPA members, however, argued that this issue is not just about war but about the individuals in the U.S. who believe governments are using futuristic weapons in space for the purpose of inflicting pain and mind control. Martinez argued that they may very well be telling the truth. He recalled a science fiction novel he wrote a paper on during college that predicted truths 20 years in advance.
“It’s easy for me to see that things which are wrong can happen because we have the wrong mindset,” Martinez said.
Myrick said he supported the resolution because he doesn’t support war.
“The weaponization of space…is something I think is extremely immoral and we should not be as a nation engaging in,” Myrick said. “Maybe some wars are unavoidable, that may be true. But whatever we can do to get our country away from that mindset…..that’s why I support this resolution.”
Amy Lee Anderson, a “targeted individual” who brought the matter to Beckles’ attention, was thankful that the council took up the issue.
“No where in the United States, no targeted individual can get this support,” Anderson said. “We just needed one person, one city. Because of that, you all our heroes. We are dying within because the technology is so sophisticated. It’s hard for someone who has no experience to fathom it, it’s so sophisticated.”
Related posts:
1. Richmond councilmember pushes city resolution banning ‘exotic’ space-based weapons
2. Dirty bomb drill in Richmond alarms conspiracy theorists, including Alex Jones
Comments
1. C’mon Richmond Standard….your bias is showing!
Page 9
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 29 of 198 Monday, November 23, 2015
![Page 30: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/30.jpg)
Stan J. CaterboneADVANCED MEDIA GROUP
1250 Fremont StreetLancaster, PA [email protected]
717-669-2163
October 10, 2015
Federal Whistleblower and
Targeted Individual (Victim) of U.S. Sponsored Mind Control
Executive Summary©
Updated on October 10, 2015
I remain,
Stan J. Caterbone
PRIVILEGED AND CONFIDENTIAL: Stan J. Caterbone, Pro Se Litigant, and the Advanced MediaGroup are victims of U.S. Sponsored Mind Control and has been engaged in litigation in bothFederal and State courts seeking financial remedies and a resolution of his Civil Liberties andhis Constitutional Rights. In 1987 Stan J. Caterbone, while managing the financial firm the hefounded, Financial Management Group, Ltd., Stan J. Caterbone became a Federal Whistleblowerwhen, as a shareholder, he claimed fraud and misconduct within the international arms dealerand local start-up International Signal & Control, Plc., Some 4 years later ISC was indicted andplead guilty to the 3rd largest fraud in U.S. history, some $1 Billion and selling arms to Irag viaSouth Africa. In June of 2015 Stan J. Caterbone became the Movant in the U.S. District Courtfor the Eastern District of Pennsylvania case No. 5:14-cv-02559-PD for the Habeus CorpusPetition of Lisa Michelle Lambert. The case is now before the U.S. Third Circuit Court ofAppeals, Case No. 15-3400.
Page 1 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 30 of 198 Monday, November 23, 2015
![Page 31: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/31.jpg)
ADVANCED MEDIA GROUPADVANCED MEDIA GROUP, LTD.,
&STAN J. CATERBONE
Federal Whistleblower (Federal False Claims Act Violation in 1987 re ISC)Targeted Individual of U.S. Sponsored Mind Control
and Directed Energy Devices and Weapons
EXECUTIVE SUMMARY
copyright 2009
“Ya know what, I am beginning to analyze this War on Terror and am having difficulty understandingit all. To me the most effective fundamental fight against Extreme Terrorism is to reduce the motive; or theHatred Against America. No one seems to talk about that subject. How do we reduce that Hatred TowardsAmerica and the West?
See, from my perspective, my situation is very disturbing. I mean we have the United States Torturing Me, aU.S. Citizen for no good or valid reason. I have warned EVERYONE about using my situation to feed thisHATRED towards America.
Low and behold a week or so ago I have had several Muslims sign up as Followers to mywww.scribd.com/amgroup01 online webspace, which I use to post documents. The following being the mostprominent IKWAN Scope, "The Largest Muslim Brotherhood's Scope on the Web":
http://ikhwanscope.net/main/
There have also been several Muslim individuals who signed up as followers around the same time, a weekor so ago. They have also signed up as followers on my www.twitter.com/StanCaterbone webspace.
You must understand, I am a VERY Patriotic Person and live a very patriotic life - I believe in theU.S. Constitution and Our Founding Father's vision for America; I support Our Military and ourTroops; I believe in the Rule of Law; I am a Practicing Catholic, and have been my whole life; IBelieve in the TRUTH; I believe in Right v. Wrong; Good v. Evil; and finally I believe in God. Whatdo you believe in?”
Posted on the Yahoo Fulton Bank Stock Message Board, January 7, 2010
Date Updated: October 10, 2015
Date Completed: July 28, 2009Date Initiated: July 8, 2009
Stan J. CaterboneAdvanced Media [email protected]
Page 2 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 31 of 198 Monday, November 23, 2015
![Page 32: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/32.jpg)
UDATE OF SEPTEMBER 27, 2015
In 2015 Stan J. Caterbone and Advanced Media Group had to again return to local,
state, and federal courts. Again the obstruction of due process, the local gang stalking, torture,
trespass, thefts, and the like began in earnest. From the fabricated Petition for Involuntary
Psychiatric Commitment of April 2010 by Detective Clark Bearinger, until January of 2015, Stan J.
Caterbone and Advanced Media Group had been in seclusion and in a state of rehabilitation and
rest due to the forced medication by Fairmount Behavioral Hospital and Dr. Silvia Gratz. The
psychotropic drugs reduce your motor skills and put you in an extreme state of confusion. By
the end of the summer of 2010 every social media site, including the
www.amgglobalentertainmentgroup.com website was taken off-line due to the intimidation and
coercion by Detective Clark Bearinger.
In May Stan J. Caterbone had again endured the “Attacks” and “Torture” from the
employees of the Lancaster County Courthouse, and the Lancaster County Government Building.
Then soon after the Residents of Lancaster County engaged in a massive Organized Stalking
Campaign. In addition an extreme Computer Hacking Campaign was initiated and executed in
an effort to again SILENCE Stan J. Caterbone and Advanced Media Group. And Again, the
Lancaster City Police Department took the lead role. As usual Stan J. Caterbone summoned state
and federal authorities for help and assistance, including direct communications with the White
House, the Federal Bureau of Investigation, the Pennsylvania Attorney General's Office and
Kathleen Kane, The Pennsylvania State Police, the Pennsylvania General Assembly, several U.S.
Congressmen, and of course the Lancaster County District Attorney's Office. Since August 1,
2015 the Geek Squad had performed diagnostics and repairs six (6) times due to computer
hacking. On at least 2 occasions the entire hard drive had to be wiped clean and restored.
On June 23, 2015 Stan J. Caterbone was named MOVANT in the 2014 Habeus
Corpus Petition by Lisa Michelle Lambert, Case No. 14:02559 in the U.S. District Court
for the Eastern District of Pennsylvania after filing an Amicus on the case. Judge Paul
Diamond was presiding since it's filing in 2014. However, the Petition was not able to
be granted and the case was stalled on jurisdictional law based on new and compelling
evidence, or lack there of. The Amicus was filed to cure that deficiency with direct
witness corroboration to the Prosecutorial Misconduct and Innocence of Lisa Michelle
Lambert. In fact a working theory was filed that suggested that the East Lampeter
Police Department engaged in a strategy of “Entrapment” that lead to the unfortunate
murder in 1991. This, would of course, allow a wrongful death claim to be filed by the
Show family. The case is now before the Third Circuit Court of Appeals, Case No. 15-
3400. There are three (3) questions that the Third Circuit may rule on; whether to free
Page 3 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 32 of 198 Monday, November 23, 2015
![Page 33: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/33.jpg)
Lisa Michelle Lambert, or grant her her Habeus Corpus, and whether to grant Summary
Judgment to Stan J. Caterbone in all civil actions in both state and federal courts.
Two weeks later, on July 9, 2015, Detective Clark Bearinger filed another fabricated
Petition for Involuntary Psychiatric Commitment. And again Stan J. Caterbone endured 7 days in
the Fairmount Behavioral Hospital in Philadelphia. However, this time there was no
MANDATORY Treatment Program Ordered by the Lancaster County Court of Common Pleas.
So Stan J. Caterbone continued filing in the courts for assistance and resolution. In August, in a
desperate attempt to stop the local torture campaign, another Emergency Injunction was filed in
the Lancaster County Court of Common Pleas. On August 6, 2015 Stan J. Caterbone went so far
as to undertake a Professional Polygraph Test administered by Bonnie Lee of Polygraph Solutions
of West Chester, Pennsylvania. The test ended up being 4 grueling hours of torture and a scam of
$600.00.
On July 9th , 2015 a Private Criminal Complaint was filed against Detective Clark Bearinger,
Officer Williams, Officer Binderup, and 2 unidentified patrolman. The Complaint contained
allegations of torture and abuse at every moment of contact. The Lancaster City Police
Department were so desperate for retaliation from the Amicus filing in the Lisa Michelle Lambert
case, that they actually broke the door in of 1250 Fremont Street in order to execute the
fabricated 302 petition. The Complaint was denied by the Lancaster County District Attorney on
August 8th . The Complaint is now under a Petition for Review by the Lancaster County Court of
Common Pleas.
On August 17, 2015 another Emergency Injunction for Relief was filed in the Lancaster
County Court of Common Pleas, Case No. 15-06985. The Injunction was heard by Judge Jeffrey
Wright, who dismissed it as frivolous. An appeal, MD 1561, is pending in the Superior Court of
Pennsylvania.
In addition, by September 26, 2015 Stan J. Caterbone had been granted Electronic Filing
Privileges in the local, state, and federal courts. This should alleviate the fraud and abuses of the
U.S. Postal Service and the computer hackers.
In 2015 Stan J. Caterbone identifies a trend that suggests that the Lancaster County
community-at-large was subject to either community targeting or community hypnosis. The
community targeting theory is supported by experts Jullianne McKinney, Cheryl Welsh, and Dr.
John Hall. The community hypnosis theory is supported by direct personal relationships with the
Amazing Kreskin, Samuel P. Caterbone and Stan J. Caterbone.
Page 4 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 33 of 198 Monday, November 23, 2015
![Page 34: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/34.jpg)
In September of 2015 Stan J. Caterbone begins to digitize a library of approximately 45
audio cassette tapes from his father, Samuel P. Caterbone. The tapes range in date from 1971 to
1996. The tapes prove an identical targeting campaign against both Samuel P. Caterbone and
Stan J. Caterbone. In addition the tapes confirm that Steven P. Caterbone, brother of Stan J.
Caterbone, was most likely a target dating back to the early 1960's. In addition, the death of
Samuel P. Caterbone on July 20, 2001 was confirmed to be that of murder, not natural causes.
In the early 1990's Dr. Phillip Caterbone, brother, had been solicited by the National
Institute of Health, or NIH in Washington, D.C., for a fellowship to research and catalog a study to
find a genetic marker for depression in the CATERBONE family. Phil interviewed all living
descendants and relatives of my father, Samuel P. Caterbone, Jr., and took blood samples. I am
alleging that this was a deliberate act to continue the cover story of mental illness to distract and
provide plausible deniability for any linkage to U.S. Sponsored Mind Control.
Page 5 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 34 of 198 Monday, November 23, 2015
![Page 35: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/35.jpg)
HISTORY
In 1987 Stan J. Caterbone went public with allegations of fraud within International Signal
and Control, or ISC as they were commonly referred. After discussions with ISC and United
Chem Con officials (an ISC/James Guerin straw company), and as a shareholder of record since
1983 of ISC, Stan J. Caterbone had a meeting with an ISC executive on June 23, 1987, which
resulted in a 22 year legal odyssey. The discussions involved a joint venture with his company,
Financial Management Group, Ltd., or FMG, Ltd., but ended in disclosure of his recent public
allegations of fraud. Four years later, ISC founder and chairman James Guerin, and other officials
and companies pleaded guilty to a $1 Billion Dollar Fraud and export violations including the
selling of arms through South Africa to Iraq and Sadaam Hussein. However, money, power,
influence and public corruption had been used to cover-up the activities and Federal False Claims
Act violations of Stan J. Caterbone for the next eighteen years. There ensued a total blockade of
all United States Courts for all redress and remedy available in accordance with federal, state, and
local laws. This included recovery of his business interests; intellectual property; real estate;
personal and business real property; his unblemished and impressive reputation; and his most
valuable asset - the ability to produce income. This might be legally referred to as the Right-To-
Work under federal statutes. Notwithstanding, Stan J. Caterbone has never made a bad
investment or developed a business that did not make a profit over the next 22 years. This
includes two real estate properties that were illegally seized through foreclosure proceedings.
Since 1987 Stan J. Caterbone has been a prisoner and enemy of the state. ISC was a
Department of Defense (DOD) Contractor and a partner with United States Intelligence Agencies
since it's beginings in the early 1970's. One of it's first contracts was Project X with the National
Security Agency or NSA of Ft. Meade, Maryland.
In summary, the following are facts and part of the public record regarding INTERNATIONALSIGNAL & CONTROL OR ISC:
Once the third (3rd) largest employer in the County of Lancaster, Pennsylvania, withover 5,000 employees.
James Guerin, founder and CEO was once the largest philanthropist to charitableorganizations in the County of Lancaster, Pennsylvania.
The ISC/Ferranti Scandal was the third (3) largest white-collar fraud within the UnitedStates as of 1992.
Page 6 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 35 of 198 Monday, November 23, 2015
![Page 36: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/36.jpg)
The following are some of the public officials and politicians associated with ISC:George H.W. Bush, former U.S. President, and Director of the Central Intelligence
Agency (CIA).
Robert Gates, former Director of the Central Intelligence Agency (CIA) and currentSecretary of Defense.
Bobby Ray Inman, former Board of Directors if ISC, former Director of the NSA, andcurrently associated and directly involved with Mind Control Research organizations.
Alexander Haig, former U.S. Secretary of State, and ISC lobbyist and Board ofDirectors?
Joseph McDade, former Pennsylvania House of Representative and Chair of theAppropriations Committee who was later investigated for the United Chem Conscandal.
Carlos Cardoen/Cardoen Industries, a joint venture partner with ISC and armsmerchant for the cluster bomb who eventually sold to Iraq and other Middle EasternCountries under U.S. sanctions.
ISC was credited with the design of the cluster bomb, and has patents filed in the U.S.Patent Office.
In 1987 ISC completed the merger with the 3rd largest defense contractor of GreatBritain, Ferranti International; who paid $1 billion dollars for ISC and all of it'ssubsidiaries.
ABC News/Financial Times aired 3 episodes on ABC Nightline with Ted Koppelregarding the ISC/CIA defense weapons; technologies; and cluster bombs to Iraqstory and lead into the allegations that then nominee for the Director of CIA RobertGates was involved with ISC and the selling of arms to Iraq.
ABC News 20/20 aired a story on the ISC/CIA efforts to sell cluster bombs to SaadamHussein and Iraq on February 1, 1991 days after the start of the Persian Gulf War I,with the initial bombing raid destroying a cluster bomb factory built in Iraq byCarlos Cardoen.
On July 1st and 2nd of 1987 Stan J. Caterbone solicited the legal counsel of LancasterAttorney Joseph Roda for counsel regarding, FMG, Ltd., International Signal &Control (ISC); Commonwealth Bank, etc., and was billed for his services. JosephRoda did absolutely nothing but refute Stan J. Caterbone's claims and would notbelieve him.
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas),Lancaster Attorney Joseph Roda represented William Clark, ISC's in-house legalcounsel, and never mentioned any conflict to Stan J. Caterbone in 1987.
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas), JamesGuerin deposited $1.75 million dollars into an escrow account at Fulton Bank,Lancaster, County.
Page 7 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 36 of 198 Monday, November 23, 2015
![Page 37: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/37.jpg)
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas),Christopher Underhill of Harman, Underhill & Brubaker, represented JamesGuerin. In 2005 Christopher Underhill represented the Manheim Township PoliceDepartment (05-cv-2288 U.S. District Court for the Eastern District ofPennsylvania) CATERBONE v. Lancaster County Prison, et. al.,.
In Clark v. Guerin (CI-1990-0074 Lancaster County Court of Common Pleas),Philadelphia Attorney Joseph Tate represented James Guerin and ISC, and in 2007Joseph Tate represented Scooter Libby during his federal prosecution by U.S.Special Prosecutor Fitzpatrick.
THE MANIFEST OF A COVER-UP
Not only did the allegations of fraud within ISC have to be silenced at a time when merger
negotiations were ongoing with Ferranti, but all of the fraud; extortion; public corruption;
burglaries; civil rights violations; anti-trust and intellectual property right violations; lender
liability torts; false arrests; false imprisonments; as well as other civil and criminal activities had
to be covered up and buried in bureaucratic red tape. Information and findings are still being
uncovered and discovered to this day. Contrary to popular belief, up until 1996 a grand jury
investigation into ISC was still ongoing. It is not known whether it has closed or not. All of these
activates constitute a RICO crime due to the pattern and organization of the perpetrators. The
pattern and source of the activities can be traced back to 1987, with subgroups changing over
time, but still engaging in the same practices. The following plan of action was followed in order
to perpetrate the cover-up:
Totally discredit Stan(ley) J. Caterbone and any and all allegations in every waypossible.
Fabricate a history of mental illness.
Fabricate a criminal record.
Attach his character and honesty with rumors and propaganda.
Extort and maintain his net worth to $ zero or load him with debts.
Keep him out of any profession and or occupation when and where possible.
Totally isolate him and disenfranchise him from his friends, colleagues, and familyinto a life of solitaire.
Somehow persuade the community of Lancaster County to buy into this plan ofaction through money, favors, etc.,
Always keep attorneys and anyone remotely involved with the legal communityaway at times when efforts for justice are pursued.
When attempts to enter the U.S. legal system arise, isolate, harass, and extortany monies and/or possessions of value.
Page 8 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 37 of 198 Monday, November 23, 2015
![Page 38: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/38.jpg)
Change the history of events and the truth.
THE COURTS AND THE UNITED STATES LEGAL SYSTEM
For 18 years, (from 1987 until 2005) it has always been fairly easy to keep these issues
from court dockets and judges. During these years Stan J. Caterbone had solicited at least
twenty attorneys, some from large firms with national recognition in their respective fields of
specialties. Attorneys from New York City to Santa Barbara and San Diego California were visited
and consulted as well as a group of ex FBI agents who specialized in white collar crime that are
now globally recognized. However, the money and influence of persons and entities that wanted
these issues silence always prevailed. The issues were so complex and convoluted, and involved
such high profile politicians and U.S. agencies, it was far easier to state that there was no case, or
their were no claims that would result in remedy or redress. Between the Republican Party and
the Department of Defense, the CIA and the NSA, there was not an attorney that could not be
influenced. The obstruction of justice and due process in this case is most likely unprecedented in
nature and in malice.
However in 2005 that all changed when Stan J. Caterbone appeared as a pro se litigant
representing himself, without any counsel, in the United States District Court for the Eastern
District of Pennsylvania in CATERBONE v. The Lancaster County Prison, et. al., or case no. 05-cv-
2288. This case is still not settled and has been withdrawn by plaintiff Stan J.
Caterbone in October of 2008 after a successful ruling in the U.S. Third Circuit Court of
Appeals (07-4474) in September of 2008. The case will be continued upon the security
of evidence and the cease and desist of obstruction of justice and due process. On May
16, 2005 at the Federal Courthouse in Philadelphia, Stan J. Caterbone filed the case under seal.
One week later in the United States Bankruptcy Court for Eastern Pennsylvania in Reading,
Pennsylvania, again appearing as pro se, Stan J. Caterbone filed a petition for protection under
the Chapter 11 Bankruptcy Code, in case no. 05-23059.
These acts of entering the United States legal system with these issues triggered yet
another round of attempts to keep these cases from the courts and judges - Organized Stalking
with Directed Energy Devices and Weapons, built on a foundation of mental telepathy or total
Mind Control.
Page 9 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 38 of 198 Monday, November 23, 2015
![Page 39: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/39.jpg)
REMOTE VIEWING; ORGANIZED STALKING; DIRECTED ENERGY DEVICES AND
WEAPONS.
Organized stalking and harassment began in 1987 following the public allegations of fraud
within ISC. This organized stalking and harassment was enough to drive an ordinary person to
suicide. As far back as the late 1980's Stan J. Caterbone knew that his mind was being read, or
"remotely viewed". This was verified and confirmed when information only known to him, and
never written, spoken, or typed, was repeated by others. In 1998, while soliciting the counsel of
Philadelphia attorney Christina Rainville, (Rainville represented Lisa Michelle Lambert in the Laurie
Show murder case), someone introduced the term remote viewing through an email. That was
the last time it was an issue until 2005. The term was researched, but that was the extent of the
topic. Remote Viewers may have attempted to connect in a more direct and continuous way
without success.
In 2005 the U.S. sponsored mind control turned into an all-out assault of mental
telepathy; synthetic telepathy; and pain and torture through the use of directed energy devices
and weapons that usually fire a low frequency electromagnetic energy at the targeted victim.
This assault was no coincidence in that it began simultaneously with the filing of the federal action
in U.S. District Court, or CATERBONE v. Lancaster County Prison, et. al., or 05-cv-2288. This
assault began after the handlers remotely trained Stan J. Caterbone with mental telepathy. The
main difference opposed to most other victims of this technology is that Stan J. Caterbone is
connected 24/7 with a person who declares that she is Interscope recording artist Sheryl Crow of
Kennett Missouri. Stan J. Caterbone has spent 3 years trying to validate and confirm this person
without success. Most U.S. intelligence agencies refuse to cooperate, and the Federal Bureau of
Investigation and the U.S. Attorney's Office refuse to comment. See attached documents for
more information.
In 2006 or the beginning of 2007 Stan J. Caterbone began his extensive research into
mental telepathy; mind control technologies; remote viewing; and the CIA mind control program
labeled MK ULTRA and it's subprograms.
Page 10 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 39 of 198 Monday, November 23, 2015
![Page 40: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/40.jpg)
FAMILY HISTORY
If you listen to the propaganda machine and the community of Lancaster County,
Pennsylvania, including professionals, the family history of Stan J. Caterbone goes something like
the following:
Father, Samuel Caterbone, Jr., Schizophrenic who ran out on his family
because of nervous breakdowns while trying to run a small dry cleaning
business. He traveled the world looking for the Blessed Mother Mary and
Space Aliens. He ended up living in government subsidized housing broke
and with a severe mental illness.
Brother, Samuel A. Caterbone, suffered from the very same illness has his
father, Schizophrenia, who finally killed himself trying to live in California.
Brother, Thomas W. Caterbone, suffered from the very same mental illness as
his brother, Stan J., Bipolar Mood Disorder, who ran a lawn business and
finally committed suicide at an early age.
Stan J. Caterbone, suffered from Bipolar Mood Disorder, or Manic Depression and
had a nervous breakdown in 1987 trying to compete in the financial services
industry. When he has his nervous breakdowns, he always threatens to sue
everyone in court and is deeply paranoid in thinking the whole world is
against him. He always spends all of his money during his fits of mania and
has delusions about his success as a businessman.
The Family History was formulated back in the 1960's when Samuel Caterbone, Jr.,
father of Stan J. Caterbone, became engaged in a black budget mind control program that began
during his service in the United States Navy as a radioman and air gunner. Samuel Caterbone,
Jr., was most likely a direct product of MK ULTRA or one of it's subprograms. His brother, Samuel
A. Caterbone, was most likely part of the LSD experiments of MK ULTRA. Stan J. Caterbone is
most likely part of a program sponsored by the Department of Defense Agencies, such as DARPA
or the Defense Intelligence Agency (DIA). The facts of Stan J. Caterbone's intimate discussions
with both his father and brother over the years before they died, the totality of documents that
were preserved in their estate, including service records; letters; official court papers; high school
documents; and the like - all will prove that they were in fact part of MK ULTRA or one of it's
subprograms.
Page 11 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 40 of 198 Monday, November 23, 2015
![Page 41: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/41.jpg)
The following are the facts and the real record of the family history:
Samuel P. Caterbone, Jr., (Father) served in the Navy from 1943 to 1946 and
graduated with honors from Air Gunners School in Jacksonville, Florida. He was an exceptional
student/athlete while attending Lancaster Catholic High School, participating in the band as well
as sports. He was also his senior class secretary/treasurer. After the Navy, he went on to build a
successful dry cleaning business, which he is credited with inventing a filtration system for the
solvents. He also developed a very good investment in real estate along the Manheim Pike,
owning several properties. By his own writings and from his personal accounts to me, he was
definitely a remote viewer or data miner for some U.S. Agency with telepathic abilities. His
viewing is documented to have begun back in the early 1970's. He also suffered from organized
stalking, and was considered an enemy and prisoner of the state. Back in the 1960's, he was a
world traveler, this is documented by his passports. Samuel P. Caterbone, Jr., may have been a
covert carrier for someone in intelligence. Samuel P. Caterbone, Jr., had his mental health history
laced with electro shock therapy. Electro Shock Therapy Experiments is another subprogram of
MK ULTRA. In addition, and especially disturbing is his criminal record with the Lancaster City
Police Department and the Lancaster County Court of Common Pleas. In 1973 Samuel P.
Caterbone, Jr. was convicted of forging a 2 checks from the Caterbone Cleaners, Inc., checking
account. The one check to Joe the Motorists Store at the Manor Shopping Center was never
entered into evidence, it was for a total of $70.00. The other check was made out to Lancaster
Attorney James Coho for $200.00 with "divorce proceedings" written in the memo. This was his
only criminal record. Samuel P. Caterbone, Jr., was sentenced to one year probation by President
Judge William Johnstone. However, on August 29, 1973 after nine months, Judge Johnstone
wrote an ORDER releasing him from probation and ordering him to "leave the vicinity of the
County of Lancaster, Pennsylvania". The President Judge of Lancaster County Court of Common
Pleas literally threw my father out of Lancaster County for forging 2 checks from his own
corporation. In 1987 I was arrested for stealing my own files from my own company, Financial
Management Group, Ltd., You can research the life of Candy Jones and Kate O'Brien to learn more
on this topic. Samuel Caterbone, Jr., has left enough writings and documentation to know that his
life fits the model for targeted individuals, complete with economic ruin, isolation, disenfranchised
from family and friends, and of course a fabricated mental illness history. You can view most of
his record online. On or about May 18, 2001 Samuel P. Caterbone Jr., finally received an
inheritance from his mother's (Mary Caterbone) estate. The check was for some $70,000.00.
The estate was probated in November of 2000. Some two weeks later, on Memorial Day Weekend
of 2001, he had called me to come to New York City to help care for him. He was in perfect
health until this time. In a matter of six (6) weeks he had succumbed to lung cancer. As per
Julianne McKinney, former intelligence officer for the U.S. Army and victim activist of U.S.
Sponsored Mind Control, the weapons are lethal enough to kill and “the one thing that I worry
Page 12 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 41 of 198 Monday, November 23, 2015
![Page 42: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/42.jpg)
about is that of dying of cancer” (paraphrase). There is no doubt now that my father's death was
a murder, not natural.
Samuel A. Caterbone, (Brother) served in the United States Air Force in 1968 to 1970.
In 1991, Stan J. Caterbone accused the United States Government of using his brother, Samuel
A. Caterbone for part of the LSD experiments on mind control, or MK ULTRA. A notarized letter of
October 23, 1991 was sent certified mail to the California Attorney General on the subject matter,
with a return letter from the California Attorney General on January 14, 1992. By his own
admission before his death, Samuel A. Caterbone disclosed to Stan J. Caterbone of the "bad LSD"
trips while in the Air Force. Since his death of December 25, 1984, Stan J. Caterbone and others
questioned the classification of suicide, and made allegations of foul play that was ultimately
responsible for his death. Finally in a meeting in Santa Barbara, California with the Santa Barbara
Public Guardian's Office, an office admitted that the death was more likely due to foul plan than
suicide. Samuel A. Caterbone was also an exceptional student and athlete while attending
Lancaster Catholic High School. After playing varsity football as a sophomore, he had an
unfortunate accident while deer hunting the following November. While in the woods in
Bellefonte, Pennsylvania, his hunting pants caught fire trying to stay warm. It left him in the
Lancaster General Hospital for months, going through painful skin grafts and isolation. The
hunting accident interrupted his athletic career and scared his legs for life. The Schizophrenia
diagnosis was a combination of LSD flashbacks and organized stalking and harassment.
Thomas P. Caterbone, (Brother) had an unfortunate transaction at Fulton Bank that set
a course of action that resulted in a suicide. Although diagnosed with Bipolar Disease and Manic
Depression -- embezzled and extorted monies were most likely the reason for his suicide in 1996.
Fulton Bank was involved in a fraud that took $72,000 from a real estate settlement closing and
lead to his total financial ruin and collapse in June of 1995. The funds were never recovered and
Fulton Bank is a defendant for a wrongful death claim in the United States District Court for the
Eastern District of Pennsylvania in CATERBONE v. Lancaster County Prison, et. al., 05-cv-2288.
FULTON BANK triggered a severe and lethal death blow to Thomas P. Caterbone, and as of this
day has refused to acknowledge any wrongdoing or remorse. Thomas P. Caterbone was also an
exceptional athlete. Playing for Lancaster Catholic High School, Franklin and Marshall College, the
Harrisburg Patriots, and even the Philadelphia Eagles. Tom also coached football at J.P. McCaskey
and Franklin and Marshall College. Thomas P. Caterbone had a very successful lawn and
landscaping business before joining forces with John DePatto of United Financial Services and
selling residential mortgages. John DePatto was the former head of Parent Bank, owned by
James Guerin and ISC. Parent Bank, owned by ISC also foreclosed on 2323 New Danville Pike,
Conestoga, Pennsylvania in 1988, which was owned by Stan J. Caterbone. Thousands of dollars
of equity was extorted in the process, despite still being short sold for a profit to Mr. Keith
Page 13 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 42 of 198 Monday, November 23, 2015
![Page 43: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/43.jpg)
Kirchner, an executive of Lancaster Newspapers and former graduate of Lancaster Catholic High
School.
Stan J. Caterbone is a remote viewer (at least one way in), is telepathic, and a
federal whistleblower with an exceptional entrepreneurial record in spite of all of his adversaries
and their assaults. In spite of the U.S. Sponsored mind control and torture, he has endured and
will prevail. Legally, Stan J. Caterbone has been able to preserve his claims, and progress his
legal challenges and claims through both the federal and state court system appearing pro se,
without the aid or expense of additional legal counsel. Some of his claims and briefs will most
likely be landmark decisions in years to come. Stan J. Caterbone was a 2-Sport MVP at Lancaster
Catholic High School, in both football and track. Stan J. Caterbone never received less than a B
grade in his four years of high school and had an 87+ average. Stan J. Caterbone excelled in
computer technologies, taking his first full term course in 1975, while in high school and
continuing into college at Millersville University, graduating with a degree in business
administration in 1980. Stan J. Caterbone excelled profoundly at building his companies, first
beginning with Financial Management Group, Ltd., then working with Tony Bongiovi of Power
Station Studios and the "Digital Movie"; then building Advanced Media Group, Ltd.. Over the
years, despite the illegal seizures and foreclosures, Stan J. Caterbone has amassed a portfolio of
impressive real estate deals that have always paid off in profits, no matter how or when they
were sold. The same was true of his businesses. Financial Management Group, Ltd., was a
$20,000 dollar investment in 1986 and was still sold for approximately $100,000 two years later,
despite the false arrests and the extortion of most of it's real value and equity.
The mental health history and the criminal records were completely fabricated, and a
close review and investigation into the actual court records and hospital records can prove that in
very short fashion. There are TWO (2) ways to quickly dispute the Mental Health History and
Record:
One - Review the word "Delusional; delusions; etc.,; every instance of the word
used by mental health professionals, and the false reports by friends and family were associated
with facts, and matters of the official record, the complete opposite of the meaning of the word
"delusional". And they still exist to this very day.
Two - Review the 3 Fabricated Suicide Allegations of the following dates: August
10(?), 1987 at Burdette Tomlin Hospital (Cape May County New Jersey); February 18th(?), 2005
by Kerry Egan and the Southern Regional Police Department; and July 19, 2009 for the 302
Commitment by the Lancaster City Police Department at Lancaster General Hospital.
The Criminal Record is very similar, since 1987 Stanley J. Caterbone has had 31 false
arrests; formal charges and convictions dismissed prior to court proceedings or won on summary
appeals in the County of Lancaster, Pennsylvania; most of which Stan J. Caterbone appearing as
Page 14 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 43 of 198 Monday, November 23, 2015
![Page 44: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/44.jpg)
pro se (representing himself). These have resulted in civil complaints filed in 2008 in CATERBONE
v. The County of Lancaster, Pennsylvania in U.S. District Court for the Eastern District of
Pennsylvania.
THE PUBLIC RECORD
The Public Record is comprised of court filings and exhibits in U.S. Federal Courts;
Pennsylvania State Courts; and the Lancaster County Court of Common Pleas. In all some 40,000
pages of documents are now filed and electronically scanned or microfilmed in prothonotary
offices. In addition in both the U.S. Federal Courts and the Lancaster County Court of Common
Pleas there are more than 11 hours of audio recordings; some 3,000 scanned images; and
several video broadcasts of the ISC News broadcasts all stored on a CD-ROM and filed as an
exhibit to some of the law suits filed by Stan J. Caterbone and Advanced Media Group, as
plaintiffs. Stan J. Caterbone has over 100 court docket sheet numbers in federal, state, and local
courts.
There are also Pennsylvania Unemployment Compensation records; Department of Welfare
and Lancaster County Assistance Office records; Local Real Estate Tax records; Lancaster County
Tax Assessment records; Social Security Administration Benefits records; Lancaster Catholic High
School transcripts; Millersville University transcripts; all for Stan J. Caterbone, in addition to his
court filings.
For Samuel A. Caterbone, my brother, there are United States Air Force service
records; Lancaster Catholic High School transcripts; Millersville University transcripts; Social
Security Administration records; Santa Barbara County Guardian and Public Defender records;
and papers and documents persevered from his estate.
For Samuel P. Caterbone, my father, there are United States Naval records, Lancaster
Catholic High School transcripts; Social Security Administration records; Lancaster County
Assistance Office records; Local Real Estate Tax records; Lancaster County Tax Assessment
records; Samuel Caterbone Cleaners, Inc., corporate records; Real Estate Deeds and Mortgages;
Lancaster County Court of Common Pleas civil and criminal records; and of course papers and
documents persevered from his estate
PUBLIC WEBSITE ADDRESSES OF INTEREST:
www.amgglobalentertainmentgroup.comwww.freedomffchs.comhttps://www.scribd.com
Page 15 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 44 of 198 Monday, November 23, 2015
![Page 45: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/45.jpg)
DOCUMENTS ATTACHED FOR REVIEW
** It is important to note that as of this writing, Remote Viewing has recently
been commercialized by corporate America, and certain Fortune 500 companies are
using Remote Viewers as consultants for trend analysis and market forecasts. This is
often the evolution of most technologies born out of the U.S. Department of Defense.
Top Secret experiments and the resulting technological advancements can stay
secretive for so long. This has recently been used in a NBC story of the Television
drama "Medium" this last season. On July 9, 2008 I had recorded an AM radio live
broadcast on WHAN Coast to Coast with a guest that was one of the leading Physicist
turned Remote Viewer and expert that testified to this same notion.
Dated: July 28, 2009Stan J. CaterboneAdvanced Media [email protected] following are no longer in service:www.advancedmediagroup.wordpress.comwww.scribd.com/amgroup01www.facebook.com/scaterbonewww.twitter.com/StanCaterbonewww.mcvictimsworld.ning.com/profile/StanJCaterbonehttp://ww w.youtube.com/advancedmediagroup
Page 16 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 45 of 198 Monday, November 23, 2015
![Page 46: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/46.jpg)
September 7, 2009
Stan J. CaterboneAdvance Media Group1250 Fremont StreetLancaster, Pennsylvania 17603
Derrick RobinsonFreedom From Covert Harassment and SurveillanceP.O. Box 9022Cincinnati, Ohio 45209Phone 1-800-571-5618Fax 1-866-433-4170email: [email protected]
Re: Is County of Lancaster, Pennsylvania Ground Zero for Organized Stalking andCovert Surveillance?
Derrick,
My pleasure. Derrick, I was trying to get group rates at our new Lancaster Convention CenterMarriot Hotel last week, just as a little fact finding mission. I have a theory that I would like tosend your way. I thought it would be very fruitful to bring some TI's together for a conference,unless you think the exposure would be harmful.
I believe that they try new models for harassment; organized stalking and surveillance on mehere in Lancaster. Remember, Lancaster is now one of the most "Watched Communities" in thecountry. "With those cameras, the Safety Coalition will operate and monitor 165 cameras acrossLancaster City — making Lancaster the most watched city of its size in the nation." See articleattached, Watching you: City to add 105 more cameras.
I believe that Lancaster may be ground zero for some of the models of organized stalking andharassment that we TI's experience and wanted to get some reaction from Lancaster. Somehistory on the Lancaster Convention Center. Dale High of High Industries is the lead partner in ournew convention center/hotel. It is first class all the way. Now in the late 1980's I was a jointventure partner with Dale High in American Helix Technology Company/Advanced Media Group.American Helix was a cd manufacturer and I and my company Advanced Media Group was theCD-ROM division of American Helix. I was one of a handful of CD-ROM manufacturers in thedomestic United States back then. Also in 2005 I filed a civil action against the lead hotel, theEden Resort Inn, for trying to block the development and building of the Hotel/Convention Center,see attached.
Now, some history about Lancaster and the intelligence community. Back in the 1980's there wereseveral defense contractors located in Lancaster, the main being International Signal & Control,which I, of course, blew the whistle on a billion dollar fraud and arms to Iraq.
Click here for an overview of ISC.
Click here to see t he Lancaster Newspapers Archives regarding International Signal & Control, orISC.
Click here to view the live video of the WGAL-TV News Broadcast of October 31, 1991 the eveningof the ISC indic tments. The U.S. Department of Justice and other U.S. Agencies held a PressConference in the Philadelphia Federal Courthouse to announce the indictments and $ BillionDollar Fraud.
Page 17 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 46 of 198 Monday, November 23, 2015
![Page 47: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/47.jpg)
Click here for Part 2 of the WGAL-TV 8 Broadcast.Now politically, Lancaster is and has always been predominately Republican. Lancaster is one ofthe oldest cities in the country and our courthouse was one of the first in this country. Lancasterhas one of the oldest fraternities of the Masons. Lancaster and the George W.Bush administrationhas a close and very "interesting relationship". George H. Bush had a very close relationship withISC, and of course the NSA and CIA all had a very "close" relationship with International Signal &Control, or ISC. The following are some transcripts for Ted Koppel and ABC News Nightlineregarding ISC and Arms to Iraq and the intelligence community. The transcripts are contained inmy Amicus for Case No. 2006-cv-2160 filed in the Eastern District of Michigan, Southern Division.
Now, Robert Gates, presently the Secretary of the United States Defense Department, and hisrelationship to Lancaster. First of all, the attached video is the authentic transcript of RobertGates' confirmation hearing in September of 1991 for the Director of the Central IntelligenceAgency (CIA). If you fast forward to approximately 9:00:00 you will see the back and forthquestions from Senator Murkowski to Robert Gates regarding the allegations by several membersof the U.S. Senate Select Committee on Intelligence regarding his alleged involvement with ISCand the Arms deals with Carlos Cardoen and the shipping of cluster bombs through South Africaand on to Iraq. Of course, he denied all of the allegations.
Robert Gates also has relatives that live in Lancaster County, if fact he attended a wedding here afew months ago, on May 3, 2009 at St. John Neuman Catholic Church in Manhiem Township,Lancaster County. His wife has a niece that lives in Manheim Township.
Now, I'll give you the ABC News Nightline May 23, 1991 excerpt regarding ISC and the NSA,National Security Agency:
"It all started legally, if covertly, back in 1974. That's when the National Security Agency, a super-secret U.S. Intelligence unit asked ISC to help complete project X, a chain of electronic listeningposts based at South Africa's Simonstown Naval Station. South Africa was using these posts tofollow Soviet submarine traffic off of the Cape of Good Hope. To ensure secrecy, ISC and the NSAmade sure shipments could not be tracked back to them. They created a company called GammaSystems Associates. In fact, this company was nothing more than a post office box at John F.Kennedy Airport. Gamma was a cut-out. ... But this sanctioned covert operation was stopped in1977 when President Carter, a strong opponent of South Africa's apartheid regime, told U.S. firmsto stop any military-related business with Pretoria. But ISC continue shipping electronics, somecivilian, some military, to South Africa. The in the early 1980's, South Africa began to intensify itsefforts at ballistic missile development. For ISC, that was a golden opportunity because on of itstop executives was a man named Clyde Ivey, an American electronics expert who has been thefather of South Africa's missile program. Ivey had extraordinary contacts in the nations defensestructure. Begining in 1984, federal investigators say, senior ISC exeutives, including Ivey, beganregular contacts with CIA officials." You can read the rest. The entire transcript of the May 23,1991 ABC News/Nightline broadcast.
Now remember, George H. Bush was director of CIA. "He served in this role for 357 days, fromJanuary 30, 1976 to January 20, 1977.[22] The CIA had been rocked by a series of revelations,including those based on investigations by Senator Frank Church's Committee regarding illegaland unauthorized activities by the CIA, and Bush was credited with helping to restore theagency's morale.[23] In his capacity as DCI, Bush gave national security briefings to JimmyCarter both as a Presidential candidate and as President-elect, and discussed the possibility ofremaining in that position in a Carter administration[24] but it was not to be," according toWikipedia.
Now, lets get to Bobby Ray Inman, former Navy, Director of the National Security Agency (NSA),former Director of International Signal & Control (ISC), and currently part of the Mind Controlindustry. The following appears on the Welcome page of my website:
Page 18 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 47 of 198 Monday, November 23, 2015
![Page 48: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/48.jpg)
"S.A.I.C. involvement in 1993 American Para psychological Association meeting arrangements, viatheir 'Cognitive Sciences Laboratory'. Science Applications International Corporation is a big timedefense contractor, has held the largest number of research contracts of any defense contractor.Bobby Ray Inman (ISC Board of Directors) is on its board of directors, among others."by John Porter, CIA Program on Mind Control copyright 1996. In 1994, after Bobby Ray Inmanrequested to be withdrawn from consideration as Bill Clinton's first Defense Secretary, his criticsspeculated that the decision was motivated by a desire to conceal his links to ISC. Inman was amember of the so-called "shadow board" of the company which was allegedly either negligent orapproved the exports." by Wikipedia on International Signal and Control, (ISC).
Now, lets list the former Navy personnel:George H. Bush, former President of the United States, former Director of CIA.James Guerin, President and Founder of International Signal & Control.Bobby Ray Inman, former Director of the National Security Agency (NSA) and Director ofInternational Signal & Control, (ISC).My father, Samuel P. Cateronne, Jr.His father, Samuel J. Caterbone, Sr.George Noory, of Coast to Coast Radio (just anecdotal, nothing assumed or alleged).George W. Bush flew with the Navy.James CrossI will Finish later and add more.
Next we get to Jim Guerin's attorney back in 1989 through at least 1992. His name was JosephTate, of Philadelpha. This link will take you to a document regarding Joseph Tate, James Guerinand Joseph Roda, Esq., of Lancaster, my former attorney who said I fabricated everything back in1987. The document contains a letter of September 12, 2005 from Special Prosecutor PatrickFitzgerald regarding Scooter Libby, Former Vice President Dick Cheney's Chief of Staff. the letterinvolves Scooter Libby's Grand Jury Indictment for leaking Covert CIA Operative Valerie Plameand eventually outing her.
Now in Austin Texas in July of 2005 I was detained by 2 Agents from The Defense IntelligenceAgency. I was merely visiting a Military Museum, that had old and vintage helicopters andairplanes. near where my brother, Dr. Phillip Caterbone lived. I was visiting on my way toCalifornia. While inside the museum 2 Agents from the Department of Defense DefenseIntelligence Agency escorted me outside to my Honda Oddesey and interrogated me making meconfirm that I was visiting and staying with my brother. They caused a problem for my brother'sMedical Practice by shaking up one of his secretaries. The reviewed my court documents forCATERBONE v. Lancaster County Prison, et. al., Case No. 2005-cv-0288 filed in the U.S. DistrictCourt for the Eastern District of Pennsylvania. The demanded that I stay off all military basesbefore releasing me.
In 2006 I was telepathic with an older NSA executive on many occasions who wanted to meet meat the Clipper Stadium who told me he wanted to rent a facility in Lancaster for a trainingexercise. I told him to to and see Dale High and the High Group for space at the GreenfieldIndustrial Park. He said he was retiring and that our discussions were keeping him a few weekslonger than expected. We had intimate discussions of my history and the Chesapeake Bay Area.We also discussed Sheryl Crow, and he told me his wife was a fan. I turned him on to her newalbum, Wildflower, and he said she liked it. We had to disengage because he was being harassedby other telepathic assailants.My former secretary (Susan Bare) at Pflumm Contractors, Inc., where I was controller and washired to rescue the company from near bankruptcy in 1993, told me that her husband, Ross Bare,who grew up just some 10 or so doors from me, worked for the NSA. She disclosed this soonafter I hired her in 1994 or 1995.
I will finish later and add to this allegation. This is a work-in-progress.
Page 19 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 48 of 198 Monday, November 23, 2015
![Page 49: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/49.jpg)
Stan J. CaterboneAdvanced Media Groupscaterbone@live.comwww.amgglobalentertainmentgroup.comwww.advancedmediagroup.wordpress.comwww.scribd.com/amgroup01www.facebook.com/scaterbonewww.twitter.com/StanCaterbonewww.mcvictimsworld.ning.com/profile/StanJCaterbonehttp://www.youtube.com/advancedmediagroup
Page 20 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 49 of 198 Monday, November 23, 2015
![Page 50: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/50.jpg)
AFFIDAVIT
BE IT ACKNOWLEDGED, that Stanley J. Caterbone, Financial Management Group, Ltd.,
FMG Advisory, and and all affiliates, Pro Financial Group, Ltd., Advanced Media Group, Advanced
Media Group, Ltd., Global Entertainment Group, Ltd., Power Productions I, Radio Science
Laboratories, Ltd., of Lancaster County, Pennsylvania, the undersigned deponent, being of legal
age, does hereby depose and say under oath as follows:
I am now convinced that the situation surrounding my litigation and all factors attributed
to my financial and professional demise bore out of the fact that my Father, Samuel P. Caterbone
was a victim of U.S. Sponsored Mind Control, in the truest sense of the words. The
whistleblowing activities of 1987 either were a coincidence or I was set up in the very beginning
by Pennsylvania State Senator Gibson Armstrong (former stock broker) in 1983 when he solicited
me to purchase the ISC stock. The preceding would have been the perfect cover story for my
demise; that I was involved in a fraud. Following this analysis would lead one to conclude that
the collateral damage from the activities of my financial ruin always left my fellow businesses in
financial ruin, for example Robert Kauffman and Michael Hartlett, partners, and the shareholders
and affiliated professionals of Financial Management Group, Ltd., Tony Bongiovi and Power Station
Studios, Jim and Lynn Cross as Cross Microwave Consultants, Dave Dering, Scott Robertson, and
James Boyer as American Helix/High Industries, Ralph Mazzochi and Gallo Rosa Restaurant;
Pflumm Contractors, Inc., Mike Caterbone's AIM Wholesaler's Business, Dr. Phillip Caterbone, D.O.
And associated Primary Care Practices of Austin, Texas, Sam Lombardo and Ralph Mazzochi as
S.N. Lombardo Associates for Lancaster Avenue Project, Sheryl Crow Singer Songwriter, my
immediate family, friends, and relatives.
Following this analysis would lead one to concur that the legal and financial remedies
would only be reconciled by the above named parties enjoining my civil litigation. This AFFIDAVIT
is to be considered a legal and binding document to accomplish that remedy.
Page 21 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 50 of 198 Monday, November 23, 2015
![Page 51: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/51.jpg)
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 51 of 198 Monday, November 23, 2015
![Page 52: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/52.jpg)
���������������� ��������������� ���� ��
��� ���� ��������� ��
���
��������������� ����������������������������������������������������� � �������!"�#��
����������������������������
��
�$�%�&'������$&()*%& ��(*��&��+$+��$*(��,��(+�+%����-�(�&��.+��+��/0+$-.(�0%/%*$1�2+�$'�
�,3!�$*����3�������,/��/�,3!����!�"�$�� ����$4�� �1����5�� 4��/�.� �� �/�.����� �����,/�#/�,3!����,��1��2�6�78�6�( ������1����5�� 4��/�.� �� �/�.����� �#���,/�#/�,3!���##�9���������6��� �4�8�1��#�%�66��� ��/�0��4��7��9���,/�#/�,3!���#����)��6�:�1����5�� 4��/�.� �� �/�.����� �����,/�#/�,3!���#!���6�(���:�1����5�� 4���/.� �� �/.����� �"���,/�#/�,3!���#,����$48��):�2�678�$�;����*�.� ���<�#�%�66��� �/�0��4��7��"���,/�#/�,3!���#,##���2�6�78�6�2 �*8��������1��#�%�66��� �/0��4��7��!���,/�#/�,3!���#,##���2�6�78�6�2 �*8��������1��#�5�� 4��/�.� �� �/�.����� �3����/��/���"����3�=����#�==����.� ��6:��������12�� ����6�%�� �1�0��4��7��>��7�����?��,����/��/���"����3�=�#,�"�==��9�$48��*8����� 1��@�� ������*8����� �0��4��7��>��7�����?�������/��/���"����3�=��!�,�==��!�-�� ����1�������(����+������4������0��4��7��>��?�������/�#/���!����3�1����%����;����*�����������������0��4��7��>��7�����?�������/�#/���!����3�1#������A��6������0��4��7��>��7�����?��9����/�#/���!����3�=�"����==����������(���� 4�2��������/�����&���.� �� ��>��7�����?�������/�#/���!����3�1����%����;����*�����������������0��4��7��>��7�����?��"����/�#/���!����3�1#������A��6������0��4��7��>��7�����?��!����/�3/���!���!��=���9#�==���.���04�6�*�������� ��*�(��;��%������6�:��3����/�3/���!���!��=��!3"�==���*��A4�0/*�(@B���������( ��%������6�:��,���9/#�/���!����3�=����#�==�9/�.� �����������-�C���� /�4: ��*88�%������6�:�������9/#�/���!����3�=����!�==��/�*� ��������-��47�: �%������6�:�������9/#�/���!�#/��3�=��!�,�==�#�-�� ����1���� �*8���������0/%������������ �%�66��� ������9/#�/���!���!��=�#����==��/�.� ����$�88��������6�.����%������6�:�%�66��� ��#����/��/���!������3�=����9�( � ��� �/*�4���7�&�8����3/�9/���"�D9!!�������9����/��/���!�#�����3�=�,�3�==����;�(�/�66/&���*88�0����3/�9/���"�D9!!�����%�66��� �������/�,/���!���!��=���9#�==���.���04�6�*�������� ��*�(��;��%������6�:��"����/��/���!���!��=�#!�9�==����6 �.�������3/�9/���"�%�66��� ��!����/��/���!�!��=�#3���==��E�.2+F����+��/+����8�.��������86:�%�66��� ��3���!/�#/���3�$(����3#�1�3�.������2����� �� �����:���� :6�������������6����,���!/�#/���3�$(����3#�1�3�.2+��4����:����.*$�����6�8�6�������:���
Page 23 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 52 of 198 Monday, November 23, 2015
![Page 53: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/53.jpg)
�)6��G�!��,3!��-�(�&��.+��+��&.�*2$�*��!��-�(�&.�(&.�G�����*2$-&(%�(&�+*%����*�+�&��-�(�&��.+��+��&.�*(�*A&($2(%&.�*%����&����++�/����6�+�8��������+� ����������������6�&�4�� �����:��)�����6������8���8 ����6�( ��� ���6��:�>�,3#?��
�&$-+�����*%�+.&(�$+*%��
�&��>&�4���6���� ������� ?�!1������� ������ ����������� �� ����� ��� �������� ��������� � �� ���� ���������� �� ��������� ���������������� ������ ���� ������� �� ����� ��� ��������� � �� ���� �� ����� �� �� � ������ �� � �� ���������������� ������ ���������������������� ������ �� �������������� �������������������� �� � ��� �������� ��� � �������� �� �� ���� �� ���� !"� ��������� ���� ���� �� ������ �� � ������������� ����� ��� � ���������������������� �� �������������� ����� ���������� ����� ��������������� �������������� ��������������������������������������������#������������� ������� ������������ ������������� �������� ����������� ������������ ����������������� ������������ �������������������.�������������6���������$����������%�������������������� ���������� �� �������� ���������������� &'�� ������#��(����������������� ������������������� ������ �������������� ��������������� ���9��������������=�3#�� ��� @�������������� ���'�� ������#������������(���������������������� ��������������������������������������)���� � �*(� ���� ���� ��������� ������ ���� �� ��������� � � ��� ����������� ������ ���� ��������� ���� ���+�� ���������+ ����!(����������� �������������������������� ��������������� �������� ���������F����0���8�6�2 ��8�����6�������� H���� ��8���� H���6 �� ���9�������������=�3#����#���������������� ��������� �� ��������������'�� ������#����������(������ ������� ���������������������������� ������ ��������� �*(������ �������� ��������������������������� �������� ������� �!(��,������ ���������������� ���������� ��������������� ����)������ �-(�������������� ��������������� ����� ��������� �������� �.(����� �� ���������������������������������� �������� ������� ����"(����������������-������*B��66:�>������,,9? ��88B��>�,,"?��/���������'�� ������#���+�� ���������+����������0�������� ������������������1���� ����������������������,�������� ��������� ��������������������������������������(�2�� �������������� ���������� �� ��� ����� ���� �������������������� �����,������� ������� ������� �*(�3��������� �������������������������� ������������ ��� �������� ��������� ������������������������������� ����� �����������������������������4� ������������� ��� � � ��!(�3�������������� ����� ����� �������� ����������������� ���������������� �� ��� ������� �� ������������������ ������������ ������������ ������ ���������������� �� ��������������
Page 24 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 53 of 198 Monday, November 23, 2015
![Page 54: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/54.jpg)
www.amgglobalentertainmentgroup.com
www.advancedmediagroup.wordpress.com
www.scribd.com/amgroup01
www.facebook.com/scaterbone
www.twitter.com/StanCaterbone
www.mcvictimsworld.ning.com/profile/StanJCaterbone
http://www.youtube.com/advancedmediagroup
Stan J. Caterbone
Advanced Media Group
1250 Fremont Street
Lancaster, PA 17603
ILLEGAL NO TRESPASS NOTICES AGAINST STAN J. CATERBONE AND ADVANCED MEDIA GROUPViolations of Public Accommodations Law re Discrimination
and Anti-Trust Violations with False Statements to Authorities
September 27, 2015
Work-In-Progress
Community Stalking and Organized Libel/Slander Campaign Strategy – Issue a few every
year to support false arrests; false imprisonment; fabricated mental illness history. In addition to
isolate by prohibiting entrance to major entertainment venues with good live music. Prohibit from
defending against the lies and slander in public to a minimum. Also, destroy history of strong
Christian values and church attendance on a weekly basis by keeping away from church. The
Millersville University Graduate Studies No Trespass Notice was accommodated by the denial of
entitled benefits of LETA Job Training Education Course of the Paralegal program at HACC during
the same time period.
1. David Pflumm Properties by David Pflumm – Served by State Constable in June of
2005, original not signed by David Pflumm
2. Eden Resort Inn, by Drew Anthon, Owner – Sent via 1st Class Mail in 2005.
3. Barley Snyder, LLC Lancaster Office, by Shawn Long, Esq., Attorney representing
Fulton Bank in 2006 – Sent via 1st Class Mail
4. Lancaster Newspapers, Inc., by Steve Weaver, Manager in 2006, No Notice,
Corraborated by Jack Buckwalter, Chairman and CEO and George Warner, Atty with Barley
Snyder, LLC, No Formal Notice, allowed to reenter in 2015.
5. Ruby Tuesday, Manor Shopping Center, Lancaster, by Manager and Lancaster City
Police in 2006, No Formal Notice, allowed to reenter in 2015.
6. Alley Kat Restaurant and Bar, Lancaster by Bartender Ms. Santinello, Brett Stabley,
and Lancaster City Police, No formal Notice in 2006
7. Village Nightclub, Lancaster by George in 2008, No Formal Notice
8. Marion Court Restaurant, Lancaster, by Security Personnel, corroborated by Michael
Geesey, in 2008, No Formal Notice, allowed to enter in 2015.
9. Valentinos Cafe, Lancaster, by Jeanine, Bartender,in 2008, corroborated by John
Valentino, Owner, No Formal Notice
10.Brunswick Hotel, Lancaster, by Staff Employees, in 2008, No Formal Notice
11.Lancaster County Library and Duke Street Business Center, by Executive Director in
March of 2009, by 1st Class Mail
12.Anne Bailey's Restaurant and Bar, Lancaster, by Manager in 2009, No Formal Notice
13.Millersville University Graduate Studies and Millersville University, Millersville, by
Lori Austin, Judicial Affairs, via Certified Mail in June of 2009.
Page 25 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 54 of 198 Monday, November 23, 2015
![Page 55: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/55.jpg)
14.TGIF Friday's, Lancaster, by Manager, in January of 2010, No Formal Notice
15.Lucky Dog Restaurant and Bar, Lancaster, by Robert Donnelly, in January of 2010, No
Formal Notice
16.Saint Mary's Catholic Church, Lancaster, by Don Spica, Usher and Lancaster City Police
Department in Feb of 2010, No Formal Notice
17.O'Halloran's Bar, Lancaster, March 25, 2010 by Male Staff Employee. No Formal Notice.
18.Fulton Bank, Fulton Financial Corporation, March 26, 2010 by Susan Follmer, Security
Officer.
19.Tobias Frog Restaurant and Bar, August 8, 2015 by Owner of Establishment, reason
was for complaining of harassment and stalking.
20. Millersville University, July 9, 2015, served notice by Millersville University Police
Chief Pete Anders, for negotiating a civil rights complaint with Assistant to the President,
Debra Hoeckler
21.Village Nightclub, July of 20015, by George..........., Owner, tried to enter several times,
with no reason and no written notice.
22.Lucky Dog Bar, August of 2015, met Abby and Keagan Pflumm outside, went inside and
was told by bartender to leave and not come back.
23.Barley Snyder, LLC Lancaster Office, receptionist Ms. Woods refused to let me
communicate with Attorney George Werner, who in 2011 entered appearance in 05-2288
for Fulton Bank in U.S. District Court.
24.Wennerstrom Property Management Company, June 2015, went to complain
regarding harassment, threats, etc., at 1252 Fremont Street and told to leave building.
Dated: September 27, 2015
Page 26 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 55 of 198 Monday, November 23, 2015
![Page 56: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/56.jpg)
Page 27 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 56 of 198 Monday, November 23, 2015
![Page 57: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/57.jpg)
Page 28 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 57 of 198 Monday, November 23, 2015
![Page 58: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/58.jpg)
Page 29 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 58 of 198 Monday, November 23, 2015
![Page 59: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/59.jpg)
AFFIDAVIT
I, Stanley J. Caterbone, Targeted Individual or TI, residing at: 1250 Fremont Street,
Lancaster, Pennsylvania, 17603, do hereby state that I am at least 18 years of age, that I am a citizen or a legal resident of the United States of America, that I am of sound mind, and that I am the person whose signature follows on this Affidavit. The purpose of this document is (1) to advise Congress as well as state and local officials of organized stalking and electronic and mind
manipulation torture being committed against me and (2) to request a state, local, or Congressional investigation and hearing on the use of remotely-operated directed energy attacks and mind control technologies on Americans in this country. Our Government is responsible for protecting its citizens from elements that
covertly harass, torment, murder, and cause victims to commit suicide through
organized stalking and remote electronic torture. Yet, unbiased research indicates that
certain elements of Government either engage in these activities or protect those who perform them. I seek the complete dismantling of any officially-sanctioned covert Government torture programs, the passage of legislation specifically outlawing that high-tech torture, and the full
prosecution of any person, regardless of his rank or position, who has violated my civil rights and my most basic human rights. The assaults on my mind and body have been occurring for 24 year(s) and include, but are not limited to the following victimization's:
1. Blanketing my dwelling and surroundings with electromagnetic energy. Bombarding my body with debilitating electronic and mind manipulation effects.
Directed Energy Weapons Causing Severe Pain to Body and Brain. Began in at least 2005 and still continuing, with complaints to Freedom From Covert Harassment and Surveillance, FFCHS in 2009, and in cited in various state and federal court cases over the past several years.
Attacks causing severe artificial pain most likely from Directed Energy Devices synchronized with telepathic harassment and organized stalking and harassment have been logged and reported to law enforcement and medical professionals since 2008. Prior to 2008 the attacks were experienced and reported to medical professionals but the sources were not known. Also reported
attacks of pain to a family physician, emergency room personnel and psychiatrists.
2. Invading my thoughts via remote sensing technologies. Was sent an autonomous email in 1998 introducing the term remote viewing. Various technologies and tactics are being
used to create “emotional signatures” that induce various emotional states; a systematic complete hacking of my mind.
3. Making me mentally “hear” others' voices through the microwave hearing effect.
Synthetic and/or Mental Telepathy. First started to experience telepathy/synthetic telepathy
in 2005 with full-time 24/7 connection during the same time to present. When full-time telepathy started a male conducted interrogations lasting several hours at a time concerning a wealth of subjects including ISC/CIA Knowledge. Cannot disconnect from continuous conversations at all
times with one female person. The handlers know everything I know and experience in real time. During 2006 and 2007 have been telepathic with some 10 or more persons, both male and female for short durations. Can recall most conversations and subject matter with identities of who they said they were. Interrogation type harassment is still being used telepathically to harass and for
some sleep deprivation. Made first complaints to DARPA, the FBI, and U.S. Senator Arlen Specter in 2007. Some conversations by the persons that are telepathic with me elude to some program similar to the DARPA datalog program where they record your entire life. Everything that you try to do on a daily basis is subject matter for conversation and harassment. Interference with
thought, harassment, and interrogation is used often times with electromagnetic weapon attacks to the brain or body.
Page 30 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 59 of 198 Monday, November 23, 2015
![Page 60: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/60.jpg)
4. Depriving me of sleep due to neurological intervention. Mostly Experienced Sleep Deprivation Techniques during periods of time in 2008 to 2010. Mostly with attacks of pain from
Directed Energy Weapons to back, neck, head (brain); and heart on a few occasions; and with harassment from telepathy.
5. Introducing poisonous gas and radiation toxins into my home. First experienced toxic gases (Chloroform?) in heavy doses in 2006-2007. Made complaints to the Lancaster City
Police Department and the Southern Regional Police. Experienced attacks that would cause dizziness at home, in automobile and in public. Was informed it was being released through a distribution system the size of fishing line. To counter attacks used cotton in nostrils and gas
mask. In 2009 experienced attacks of what is said to be sleeping gas, when attacked could not open eyes. Took Pictures during some attacks.
6. Having me stalked en masse on foot and in vehicles. vandalizing my home and/or
car. Gang Stalking or Organized Stalking began in 1987 and continues today. It includes
strangers using gestures such as finger under eye; various forms of harassment; and public mobbing. Complaints have been filed in 1987; 1992;1998 and 2005 to 2010. Complaints were made to various public officials and local, state, and federal agencies as mental duress. The terms
organized stalking, gang stalking, targeted individual, etc., was not learned until a few years ago. The organized stalking and harassment followed in several states, some while traveling from Lancaster, Pennsylvania to California. Tracking technologies may have been used and most likely are still being used. Police were involved in most places.
7. Tapping (Bugging) my phones. Complaints of phone tapping/tampering were made to New Jersey Bell in 1987 with a service call to Stone Harbor, New Jersey to check lines and phones. The same was done by a Bell Atlantic repairman in Conestoga, Pennsylvania in 1998. In 2004 a
complaint with a report number was filed with the Pennsylvania Attorney General Office in Pittsburgh, Pennsylvania (Agent Amy Zelnick) regarding interference with phone calls and impersonations by perps intercepting and rerouting calls. Computer Hacking complaints were filed to local authorities in the County of Lancaster and the Cyber Crime unit of the Federal Bureau of
Investigation in 2005 to 2010.
8. Blacklisting me in the labor market. Filed complains of employment discrimination with the Pennsylvania Attorney General in 2006 and the Lancaster County Human Relations Commission in 2008.
9. Workplace mobbing. Experienced in 1987 at Financial Management Group, Ltd., American Helix of High Industries in 1991 and Pflumm Contractors, Inc., in 1997/1998. Filed complaints and logs as mental duress and harassment. Was forced out of all 3 organizations as a
result of the mobbing and harassment.
10. Public Mobbing. Public type mobbing and organized stalking and harassment was perpetrated heavily in the years 2005 to 2010 in the following places: The Lancaster County
Courthouse, The Lancaster County Public Library, the Pennsylvania Career Link, and the Millersville University Library and University Offices. I was given suspicious and illegal “No Trespass” Notices in some 18 public places in Lancaster County in the years 2005 to 2009 without just cause. I was complaining of stalking and harassing in most all of those public places. The Lancaster County
Public Library and the Millersville University took away my access to a computer after my personal computers were vandalized and/or hacked inoperable. Fulton Bank took away my safe deposit box. Others included my church of worship, various bars and restaurants and one attorneys office. Complaints have been filed regarding the same in courts and with various authorities.
Page 31 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 60 of 198 Monday, November 23, 2015
![Page 61: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/61.jpg)
11. Attempted Murder. Experienced with an attempt of vehicular homicide in 1991 after National News Media reported ISC/CIA-NSA connection of “Arms to Irag”. The incident involved a
vehicle changing lanes and direction and heading directly toward me in the wrong direction running me off the road, narrowly missing a tree. I Filed the incident in federal courts and used as a motion to seal federal case no. 05-2288 in 2005 in the United States District Court for the Eastern District of Pennsylvania.
12. Pet Killing. Cat was killed in 2005 with complaints to the Lancaster County Humane Shelter and the Southern Regional Police Department.
13. Illegal Entries of Home/Properties. First in 1987 in Stone Harbor, New Jersey, then again in 1991; 1997-1998; and most serious in 2005 to 2010. Filed Police Reports and insurance claims, most with the Southern Regional Police Department of Conestoga, Pennsylvania , State Farm and Harleysville Insurance Companies.
14. Illegal Repossessions. Airplane in 1987 containing legal and business files. Home/Property and Contents in 2006 also containing legal and business files and documents.
15. Physical Assaults. One attack and filed complaint with police report in Los Osos California in 2005 and one in the City of Lancaster. Police reports were filed and obtained for both.
16. False Arrests. Experienced 7 in 1987 and more than 20 in 2005 and 2006 in the Commonwealth of Pennsylvania Lancaster County Court of Common Pleas. The false arrests were charges that were all dismissed prior to court hearings.
17. False Imprisonments. Spent 7 to 10 days in Lancaster County Prison in 1987 with all charges dismissed and again for some 60 days in 2006 with all charges dismissed. The 60 Days of imprisonment of 2006 was triggered with a false report of missing a bail supervision meeting, which was confirmed to be false in court; however bail was maliciously and purposefully reinstated
as secured instead of unsecured. The appropriate appeal was filed which secured my release after some 60 days of false imprisonment. There were no charges that resulted in any convictions.
18. Psychiatric Abuses with False Suicide Allegations from Perpetrators/Stalkers. One in 1987 resulting in a forced hospitalization for several hours by police in Stone Harbor, New
Jersey. And one again in February of 2005 resulting in police restraining me in my home and abusing me. This one was a fraudulent and phony email sent to police by a perp. The Southern Regional Police had to vacate after the email was proven to be a fraud.
19. Vandalism to Property. First in 1987 in Stone Harbor, New Jersey, then again in 1991; 1997-1998; and most serious in 2005 to 2010. Filed Police Reports and insurance claims, most with the Southern Regional Police Department of Conestoga, Pennsylvania and Harleysville Insurance Company. 3 computers have been rendered inoperable since 2005 along with various
electronics equipment; dvd recorders; printers; household items; appliances; etc., Most insurance claims have been paid. In the past years a wave of purchased items, online and in stores, were received broken or the wrong item and all had to be returned. Some included items to secure my
property, and others included computer related items, others were household and clothing items.
20. Gas Lighting. The illegal entering of home and causing psychological duress by moving items and or hiding items. First reported in 1998 to the Conestoga Police and continued to present. Clothing was also manipulated and altered. The term “gas lighting” was only learned in
2010, although it was reported to police as harassment by neighbors of friends. The daily draining of my hot tub was also used as a psychological warfare tactic and used to run up utility bills. Numerous complaints were made to police in 2008 to 2010.
Page 32 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 61 of 198 Monday, November 23, 2015
![Page 62: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/62.jpg)
21. Thefts of Property. Not Yet Completed.
22. Vandalism to Car/Truck. Since 2005 have experienced years of gas siphoning, battery outages, letting air out of tires, and wetting of inside of floor mats as psychological warfare tactics by perps and stalkers. Made numerous complaints the Lancaster City Police Department.
23. Toxic Chemical Causing Running Nose. Experienced on regular basis in 2009 when in public places. Was not in conjunction with cold/flu symptoms. Research states it is a tactic used
in organized stalking.
24. Computer Hacking. Computer Hacking complaints were filed to local authorities in the County of Lancaster and the Cyber Crime unit of the Federal Bureau of Investigation in 2005 to
2010. Numerous complaint numbers have been secured. Complaints of cell phone hacking was also reported in 2010. Websites and blogs were regularly hacked and sometimes taken off-line. Electronic calenders, court documents, and financial records were often hacked causing many problems of the years, including having to withdraw civil complaints.
25. Cyber Stalking. Most in 2005 to 2010. Complaints to Microsoft legal counsel, Yahoo Message Board, and the FBI Cyber Crime Unit.
26. Interference/Delay/Theft of U.S. Mails. First reported to U.S. Postmaster of mail tampering and illegal changing of address in 1987. In 2008 to 2009 have made several more complaints to the U.S. Postmaster Inspector General who claim to have begun investigations. Some caused missed court hearings and other missed appointments and or meetings.
27. Electromagnetic Weapons Causing Severe Muscle Spasms/Cramps. First experienced in 2006 to present. One experience in 2006 was while I was in my hot tub and the pain and cramp was so severe in my left calf muscle (you automatically bend over to rub it out, which placed my head underwater) I had to crawl out of the hot tub before almost drowning.
28. Electromagnetic Weapons Causing Sexual Stimulation. First experienced in 2005.
29. Forced Hospitalizations. Forced Hospitalizations in 1987 (2) one for 6 hours and one for 5 days; 2006 one for 3 days; 2009 one for several hours while in intensive care for emergency
surgery; and 2010 one for 8 days. Filed complaints to Citizens Commission for Human Rights in 1991 and 2008.
30. Manipulation and Theft of Documents. Numerous thefts and manipulation of all legal and business documents both in paper and in electronic format have occurred since 1987.
Microfiche/Microfilming began in 1987 and other measures to secure documents have been ongoing to present. Numerous complaints have been filed with law enforcement since 1987.
Page 33 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 62 of 198 Monday, November 23, 2015
![Page 63: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/63.jpg)
Statement: I have been a Targeted Individual, TI, and Victim since 1987. In 1987 I blew the whistle (public Allegations and Complaints to State and Federal Authorities of Fraud during merger
negotiations with British Defense Contractor Ferranti International) on an international defense contractor named International Signal & Control, or ISC, who was selling arms (Everything from Telemetry Systems to Cluster Bombs) to Iraq via South Africa and was convicted of a $1 Billion dollar Fraud in 1992 by the United States Attorney and several other federal agencies. See
ABC/News 20/20 and Nightline in 1991. They were founded and headquartered in my hometown of Lancaster, Pennsylvania. I was a shareholder and was solicited by a top ISC Executives (Convicted as a Mastermind of the Billion Dollar Fraud) to help finance some of their operations through an affiliate called United Chem Con. ISC was a Department of Defense (DOD) Contractor
and a partner with United States Intelligence Agencies since it's beginnings in the early 1970's. One of it's first contracts was Project X with the National Security Agency or NSA of Ft. Meade, Maryland. Former Secretary of the Navy, Bobby Ray Inman was on the Board of Directors of ISC
and was also on the Board of Directors of Science Applications International Corporation, or SAIC. SAIC was a huge defense contractor that was the recipient of the Defense Intelligence Agency, or DIA, program on Remote Viewing, which SAIC named Project Stargate. It was reported that Bobby Ray Inman declined the nomination for Secretary of Defense under the first Clinton
Administration because of the ISC and Trecor scandals. In the early 1990's I was a subcontractor on a project for the Defense Advanced Research Project Agency, or DARPA, with the National Institute of Standards and Technology, or NIST called TIMIT. The project developed speech
corpora for the development of computer based speech recognition systems. I was also involved in the bidding of other Department of Defense contracts dealing with information technologies. In 1998 I was stalked and approached by an employee of the National Security Agency, or NSA in York, Pennsylvania who said my problems were not with the NSA, but the “good ole boys”. In
2005 I was detained by 2 Defense Intelligence Agency, or DIA officers in a museum on a military base in Austin, Texas and was questioned and interviewed regarding my civil actions filed in federal court for several hours. I was released and told to stay off of all military bases. My brother, a Family Physician in Austin Texas had to verify my travel plans and the fact that I was
staying with him prior to my release. My father alleged he was part of U.S. Navy experiments in the 1940's and experienced
synthetic telepathy in the 1970's, 1980's and 1990's as outlined in memos and documents he had authored; and from my personal conversations with him prior to his death. Ms. Amy Fuchs of the Disclosure Project confirmed that he was most likely given an ET experience via synthetic telepathy. He died in 2001 in New York City of cancer. My brother was in the U.S. Air Force in the
late 1960's and I allege was a victim of the LSD experiments relating to MKULTRA in the late 1960's and a victim of murder (Suspicious Suicide with tainted medical reports) in Santa Barbara California in 1984; Notarized Complaints were filed to the California Attorney General in 1991. He
made a declaration type statement prior to his death that he got “bad LSD” while in the U.S. Air Force. Organized stalking and harassment began in 1987 following the public allegations of fraud
within ISC. As far back as the late 1980's I thought that my mind was being read, or "remotely viewed". During the times that legal Counsel and attorneys were solicited in 1987, 1991, and 1997 Organized Stalking and Harassment and other forms of attacks experienced by Targeted Individuals were severely increased. In 2005 the U.S. sponsored mind control turned into an all-
out assault of mental telepathy; synthetic telepathy; and pain and torture through the use of directed energy devices and/or electromagnetic weapons. This assault was no coincidence in that it began simultaneously with the filing of the federal action in U.S. District Court, of CATERBONE v.
Lancaster County Prison, et. al., or 05-cv-2288. This targeting has ruined every aspect of my life.
Page 34 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 63 of 198 Monday, November 23, 2015
![Page 64: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/64.jpg)
Some Perspectives “The calculated and technological entry into another person’s mind is an act of monumental bar-barism which obliterates– perhaps with the twiddling of a dial – the history and civilization of man’s mental development. It is more than an abuse of human rights, it is the destruction of
meaning. For anyone who is forced into the hell of living with an unseen mental rapist, the effort to stay sane is beyond the scope of tolerable endurance. The imaginative capacity of the ordinary mind cannot encompass the horror of it. We have attempted to come to terms with the experi-ments of the Nazis in concentration camps. We now have the prospect of systematic control au-
thorized by men who issue instructions through satellite communications for the destruction of societies while they are driving new Jaguars and Mercedes, and going to the opera.” "On the Need for New Criteria of Diagnosis of Psychosis in the Light of Mind Invasive
Technology"by Carole Smith
Global Research, October 18, 2007; Journal of Psycho-Social Studies, 2003.
“People have no comprehension of how lethal only one aspect (aside from the obvious of driving
the victim completely insane) of telepathy technology can be in disrupting and ruining an individ-ual's life through the sabotaging of his/her daily activities. Everything an individual does begins with a momentary thought. From the split second that thought is learned by the person on the
other end (telepathically) - the individual's right to privacy is not the real threat or loss. The real lethal weapon is the advantage in disrupting or preventing the individual from accomplishing whatever he/she is going to do before they actually do it. With a simple cell phone call or instant message, the “Advanced Team” is in place to subvert; sabotage; manipulate; propagandize;
smear; disrupt; or even prevent the task or activity from being accomplished in any successful manner. The perps are skilled at creating scenarios that are covertly arranged to simulate every-day occurrences to make the victim at fault for the loss or failure. Imagine the consequences when these activities have legal and financial implications. With telepathy technology the need for
tracking and surveillance technology is greatly diminished and may even become obsolete. This is not merely “Mind Invasive” Technology, as Carole Smith so eloquently wrote – this is “LIFE Inva-sive” Technology”. Say Goodbye to any true sense of capitalism and free enterprise in the not to
distant future – unless of course someone stops these illegal and disastrous technology transfers and leaks”. Stan J. Caterbone
Organized or Gang Stalking
“A system of organized psychological terror tactics used against a person who has become an en-emy of an individual or a government. Subtle but effective techniques of stalking by multiple indi-
viduals and psychological intimidation and manipulation are used to slowly but surely drive the target to make complaints to authorities who will see the complaints as bogus because of the methods used against the target. As a result, the target gets labeled as mentally ill.
There are as many stalking tactics as there are targets as the multistalkers will tailor the stalking to the individuals habits and individual personality. Some common examples or organized stalking are: following the target on foot, by car and public transportation, crowding the target's space in a public place, murmuring insults under the breath so only the target can hear, sitting in the car
outside the target's residence, starting "fights" in public with the target, doing "skits" on the street which involves information only the target should know but has been found out via surveil-lance of the target, stealing and vandalism of the target's possessions.”
Organized Stalking Website
“Organized Stalking is a form of terrorism used against an individual in a malicious attempt to reduce the quality of a person’s life so they will: have a nervous break-down, become incarcer-
ated, institutionalized, experience constant mental, emotional, or physical pain, become home-less, and/or commit suicide. This is done using well-orchestrated accusations, lies, rumors, bogus investigations, setups, framings, intimidation, overt or covert threats, vandalism, thefts, sabo-
tage, torture, humiliation, emotional terror and general harassment. It is a “ganging up” by mem-bers of the community who follow an organizer and participate in a systematic “terrorizing” of an individual.” Mark M. Rich
Page 35 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 64 of 198 Monday, November 23, 2015
![Page 65: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/65.jpg)
The acts described above violate many laws aimed at protecting Americans. Some of these laws
include but are not limited to the following: 10 USC 921, Article 121 -- Larceny and wrongful appropriation
10 USC 920A, Article 120a -- Stalking
18 2340 USC -- Torture
18 USC 241 -- Conspiracy against rights of sovereign, free, God created, spirit and soul
beings
18 USC 213 -- Illegal Surreptitious entry
18 USC 242 -- Deprivation of rights under color of law
18 USC 35 -- Imparting or conveying false information
18 USC 1117 -- Conspiracy to Murder
18 USC 1111 -- Murder
18 USC 1905 -- Disclosure of information generally
42 USC 1983 -- Civil action for deprivation of rights
42 USC 1985 -- Conspiracy to interfere with civil rights
31 USC 5328 -- Whistleblower protections
18 USC 1512 -- Engaging in misleading conduct
18 USC 1503 -- Intimidating a witness/victim
18 USC 1512 -- Tampering with a witness/victim
18 USC 1513 -- Retaliation against a witness/victim
18 USC 1510 -- Obstructing a criminal investigation, conflict of interest roles in
government
18 USC 1509 -- Impeding due exercise of rights by attempting to prevent, obstruct,
impede and Interfere with same
18 USC 1622 -- Subordination of perjury by procuring another to commit perjury
(Optional) I have attached a personal message _______ (check).
AFFIRMATION
I affirm that the statements in this Affidavit concerning my torture and the results of that torture are true and correct. I further affirm that those statements are based on my own direct knowledge, personal experience, research, and known and published historical fact.
Affiant (signature) ______________________________________ Name (print): __________________________________________ Date: _________________________________________________
State of __________________________ County of _____________________________
Sworn before me this _______ day of _______________________, 20__ ________________________________, Notary Public Exp.: ______________________
Stamp & Seal: Freedom From Covert Harassment & Surveillance. All rights reserved. Copyright © 2010 (This is an amended
form of the original Affidavit of September 2010 from Freedom From Covert Harassment & Surveillance.)
Stan J. Caterbone
Stan J. Caterbone
June 19, 2015
Pennsylvania
Lancaster
19 June 15
Stan J. Caterbone - I was a notary from '94-'98 Don't Know When
SJC
Page 36 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 65 of 198 Monday, November 23, 2015
![Page 66: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/66.jpg)
THE ADVANCED MEDIA GROUP Page 35 of 41 06/10/2007
Page 37 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 66 of 198 Monday, November 23, 2015
![Page 67: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/67.jpg)
THE ADVANCED MEDIA GROUP Page 36 of 41 06/10/2007
Page 38 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 67 of 198 Monday, November 23, 2015
![Page 68: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/68.jpg)
Page 39 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 68 of 198 Monday, November 23, 2015
![Page 69: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/69.jpg)
Page 40 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 69 of 198 Monday, November 23, 2015
![Page 70: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/70.jpg)
Page 41 of 41 Saturday, October 10, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 70 of 198 Monday, November 23, 2015
![Page 71: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/71.jpg)
Lancaster Film Commission http://lancasterfilmcommission.com/
1 of 1 10/7/2006 4:08 PM
Jay Ingram - Executive Director
Home
About Us
Services
Gallery
Contact Us
The Lancaster Film Commission is a non-profit organization of artists and art patrons who dedicate themselves to the promotion and expansion of film, television and video production in the Greater Lancaster, Pennsylvania area. Incooperation with the State of Pennsylvania Film Commission and the other local film commissions in the Southeastern section of our state we will develop a solid rapport with production companies in this area and the major film making cities on both coasts. With the goal of bringing productions into Lancaster we will offer all needed services i.e. scouting, permits, names and contact information of local professionals, including production individuals and companies, plus talent libraries. We will have updated databases listing businesses which support productions by offering reduced rates and percentage discounts. We are a service organization.
Our second goal is community goodwill. We will work to enhance theentertainment and community relations and strive to unite them in a productive capacity which will benefit all.
Thirdly we will support and encourage Independent productions, with contests and festivals which will include film and video grants. There will also be a yearly FilmFestival, each October, which will include film and video projects (major and minor) with celebrity presenters and participants.
© 2006 Lancaster Film Commission. All rights reserved.
Advanced Media Group Page 15 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 71 of 198 Monday, November 23, 2015
![Page 72: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/72.jpg)
Lancaster Film Commission http://lancasterfilmcommission.com/about.cfm
1 of 1 10/7/2006 4:06 PM
Jay Ingram - Executive Director
Home
About Us
Services
Gallery
Contact Us
The Lancaster Film Commission will attract and assist film and digital productions.The film industry generates over $30 billion outside the Los Angeles area and production companies are always searching for new and supportive areas to set up shop. LFC will also push for involvement by local businesses and the local filmand video professionals who would like to extend their credits. The positive impacton Lancaster will be financially as well as artistically strong.
THE LANCASTER FILM COMMISSION IS
Jay Ingram - Executive DirectorJames Manley - Projects Coordinator & Media Manager
HONORARY BOARD MEMBERS
Senator Gibson ArmstrongCharles SmithgallGlenn RobinsonLarry AlexanderMichael O'DayBrad HepferTimothy Marsden
Left to right are Jay Ingram, Charlie Smithgall and Senator Gib Armstrong
© 2006 Lancaster Film Commission. All rights reserved.
Advanced Media Group Page 16 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 72 of 198 Monday, November 23, 2015
![Page 73: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/73.jpg)
Lancaster Film Commission http://lancasterfilmcommission.com/services.cfm
1 of 1 10/7/2006 4:07 PM
Jay Ingram - Executive Director
Home
About Us
Services
Gallery
Contact Us
The Lancaster Film Commission offers assistance in many areas, including:
Handling and channeling of all city department requestsCommunication with local businessesFree production guideLicensing aide and informationLabor relationsLocation scouting and photo filesWebsite with all up-to-the-minute film news24-hour database hotlineFilm intern programOrganization of premieres of local filmsFilm writing competitionFilm FestivalsCommunity relationsYouth programLFC support tournamentsSponsored student film projects
© 2006 Lancaster Film Commission. All rights reserved.
Advanced Media Group Page 17 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 73 of 198 Monday, November 23, 2015
![Page 74: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/74.jpg)
Lancaster Film Commission http://lancasterfilmcommission.com/gallery.cfm
1 of 2 10/7/2006 4:08 PM
Jay Ingram - Executive Director
Home
About Us
Services
Gallery
Contact Us
Virtual Location Tours
These are a sampling of locations in the Lancaster area, viewable in 360 degree QuickTime virtual reality panoramas.Click on any image below to see samples. If you need QuickTime go here. Additional scouting locations can use this technique through Fulmedia Interactive.
Countryside
Lancaster's Amish Country
Downtown Lancaster
Various locations in downtown lancaster.
Advanced Media Group Page 18 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 74 of 198 Monday, November 23, 2015
![Page 75: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/75.jpg)
Lancaster Film Commission http://lancasterfilmcommission.com/gallery.cfm
2 of 2 10/7/2006 4:08 PM
film festival
the first annual lancater film commission film festival will be held dec. 2, 2006. all categories are accepted - short films, long films, documentaries, etc. Fees are 25 dollars per film. Send check anddvd to lancaster film commission - 3714 nolt road -lalndisville - PA - 17538
© 2006 Lancaster Film Commission. All rights reserved.
Advanced Media Group Page 19 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 75 of 198 Monday, November 23, 2015
![Page 76: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/76.jpg)
Lancaster Film Commission works to reel in productions
By Olenchek, ChristinaPublication: Central Penn Business Journal Date: Friday, May 12 2006Subject: Economic developmentYou are viewing page 1
Jay Ingram was already lending his writing, producing and acting skills to the movie "Rave On" when filming arrived in Lancaster in late 2004. He soon discovered that there would be more to do as he tried to make sure things went smoothly for the cast and crew.
"I had to do everything," said Ingram, a Hollywood veteran whose career includes stints on television shows such as "LA Law," "Magnum,
Ads by Google
TV Commercial ProductionExperienced Producers, Here 24/7Call Studio Center for your projectStudioCenter.com
Creative Media ProductionROI w.Effective, Dynamic MultimediaNational Top 100 Production Teamwww.mazurmediacom.com
S.R. Film & Video Prod.:30 Spots, Corporate, MarketingDVD/CD Copies, Film Transferwww.SR-Pro.comP.I." and "Another World. " 'I had to find caterers. I had to find lodging."
What Lancaster needed, Ingram told then-Mayor Charlie Smithgall, was a film commission to help attract productions to the area and help people working on those productions connect with local businesses. Smithgall agreed, and the Lancaster Film Commission was formed in August 2005, with Ingram as its director.
The nonprofit group has spurred about $1 million of economic activity through the projects it has been able to attract during the past nine months, Ingram said. These projects include an episode of "Dateline NBC" and a photo shoot featuring fashion photographer Peter Lindbergh. Ingram believes bringing in more projects could provide many opportunities for businesses in the Lancaster area.
"We have a chance of making this community a place where a lot of films are made," he said.
Despite his organization's aim, Ingram's job is not necessarily a glamorous one. He is the commission's only employee, running the organization out of his home in East Hempfield Township. He spends his time connecting production companies coming to Lancaster with caterers, car-rental businesses and hotels willing to provide discounts. He takes pictures around the county to send to people interested in the area. He spends many hours on the phone.
"It's a sales job," he said.
Advanced Media Group Page 20 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 76 of 198 Monday, November 23, 2015
![Page 77: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/77.jpg)
So far, about $35,000 has been poured into the commission's work. Some of that money has come from Ingram himself, while other funds have come from the Pennsylvania Department of Community and Economic Development.
Ingram wants to build on the past support the community has shown for the movie business, support forged when the Harrison Ford movie "Witness" was partially filmed in Lancaster County in the early 1980s. Lancasterhas a variety of environments - old houses, new houses, urban areas, rural areas - that could attract film, television and video productions, Ingram said. It is close to major metropolitan areas like New York City and Philadelphia, too.
Distinctive Affairs Catering in Lancaster provided breakfast and lunch for the Lindbergh photo shoot. The experience was an enjoyable one for the company, manager Brenda Hess said.
"It went well. They were very nice," she said. "If they would call again, we would help them out."
The commisson's efforts could mean more opportunities for college students to gain valuable work experience in Lancaster County, said Dirk Eitzen, head of the film and media-studies program at Franklin Marshall Collegein Lancaster. Many of the students at F&M and other institutions are looking for internships and ways to help out with productions.
"If (the commission) succeeds, of course it's beneficial for students," Eitzen said. "There are eager students here."
More people are becoming aware of the economic benefits that film and television projects bring to the state, said Jane Saul, director of the Pennsylvania Film Office. Such projects generated $249 million in business activity in 2005, according to statistics from the Harrisburgbased office.
While Philadelphia and Pittsburgh continue to attract the bulk of productions, some smaller areas are joining Lancaster and forming film commissions. There is a film office in Scranton, as well as one that covers the Pocono Mountains region. Regional offices offer production companies links to local businesses that the state sometimes cannot provide, Saul said.
"Having regional offices is something that we welcome, she said. "It's a great help."
Ingram predicts big things for the Lancaster Film Commission. Several film productions expected to come to the Lancaster area could provide between $5 million and $12 million in additional economic activity during the summer, he said. Any businesses interested in becoming part of a database of companies willing to assist the commission can e-mail Ingram at [email protected].
Bright lights, little cities
Parts of several movies have been filmed in the midstate. Movies, followed by their Central Pennsylvania filming locations, include:
"Rough Cut" Harrisburg, Lancaster
"Girl, Interrupted" Harrisburg, Hanover, Cumberland County
"The Altoona Riding Club" Lancaster, Lebanon and Franklin counties
"Lucky Numbers" Harrisburg
Advanced Media Group Page 21 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 77 of 198 Monday, November 23, 2015
![Page 78: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/78.jpg)
"8 Millimeter" Harrisburg
"For Richer or Poorer" York County
"Major League II" Harrisburg
"Gettysburg" Gettysburg, Adams County
"Mannequin" Harrisburg
"Witness" Lancaster County
SOURCE: PENNSYLVANIA FILM OFFICE
Despite his organization's aim, Ingram's job is not necessarily a glamorous one. He is the commission's only employee, running the organization out of his home in East Hempfield Township. He spends his time connecting production companies coming to Lancaster with caterers, car-rental businesses and hotels willing to provide discounts. He takes pictures around the county to send to people interested in the area. He spends many hours on the phone.
"It's a sales job," he said.
So far, about $35,000 has been poured into the commission's work. Some of that money has come from Ingram himself, while other funds have come from the Pennsylvania Department of Community and Economic Development.
Ingram wants to build on the past support the community has shown for the movie business, support forged when the Harrison Ford movie "Witness" was partially filmed in Lancaster County in the early 1980s. Lancasterhas a variety of environments - old houses, new houses, urban areas, rural areas - that could attract film, television and video productions, Ingram said. It is close to major metropolitan areas like New York City and Philadelphia, too.
Distinctive Affairs Catering in Lancaster provided breakfast and lunch for the Lindbergh photo shoot. The experience was an enjoyable one for the company, manager Brenda Hess said.
"It went well. They were very nice," she said. "If they would call again, we would help them out."
The commisson's efforts could mean more opportunities for college students to gain valuable work experience in Lancaster County, said Dirk Eitzen, head of the film and media-studies program at Franklin Marshall Collegein Lancaster. Many of the students at F&M and other institutions are looking for internships and ways to help out with productions.
Jay Ingram was already lending his writing, producing and acting skills to the movie "Rave On" when filming arrived in Lancaster in late 2004. He soon discovered that there would be more to do as he tried to make sure things went smoothly for the cast and crew.
"I had to do everything," said Ingram, a Hollywood veteran whose career includes stints on television shows such as "LA Law," "Magnum,
Ads by Google
Advanced Media Group Page 22 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 78 of 198 Monday, November 23, 2015
![Page 79: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/79.jpg)
TV Commercial ProductionExperienced Producers, Here 24/7Call Studio Center for your projectStudioCenter.com
Creative Media ProductionROI w.Effective, Dynamic MultimediaNational Top 100 Production Teamwww.mazurmediacom.com
S.R. Film & Video Prod.:30 Spots, Corporate, MarketingDVD/CD Copies, Film Transferwww.SR-Pro.comP.I." and "Another World. " 'I had to find caterers. I had to find lodging."
What Lancaster needed, Ingram told then-Mayor Charlie Smithgall, was a film commission to help attract productions to the area and help people working on those productions connect with local businesses. Smithgall agreed, and the Lancaster Film Commission was formed in August 2005, with Ingram as its director.
The nonprofit group has spurred about $1 million of economic activity through the projects it has been able to attract during the past nine months, Ingram said. These projects include an episode of "Dateline NBC" and a photo shoot featuring fashion photographer Peter Lindbergh. Ingram believes bringing in more projects could provide many opportunities for businesses in the Lancaster area.
"We have a chance of making this community a place where a lot of films are made," he said.
Despite his organization's aim, Ingram's job is not necessarily a glamorous one. He is the commission's only employee, running the organization out of his home in East Hempfield Township. He spends his time connecting production companies coming to Lancaster with caterers, car-rental businesses and hotels willing to provide discounts. He takes pictures around the county to send to people interested in the area. He spends many hours on the phone.
"It's a sales job," he said.
So far, about $35,000 has been poured into the commission's work. Some of that money has come from Ingram himself, while other funds have come from the Pennsylvania Department of Community and Economic Development.
Ingram wants to build on the past support the community has shown for the movie business, support forged when the Harrison Ford movie "Witness" was partially filmed in Lancaster County in the early 1980s. Lancasterhas a variety of environments - old houses, new houses, urban areas, rural areas - that could attract film, television and video productions, Ingram said. It is close to major metropolitan areas like New York City and Philadelphia, too.
Distinctive Affairs Catering in Lancaster provided breakfast and lunch for the Lindbergh photo shoot. The experience was an enjoyable one for the company, manager Brenda Hess said.
"It went well. They were very nice," she said. "If they would call again, we would help them out."
The commisson's efforts could mean more opportunities for college students to gain valuable work experience in Lancaster County, said Dirk Eitzen, head of the film and media-studies program at Franklin Marshall College
Advanced Media Group Page 23 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 79 of 198 Monday, November 23, 2015
![Page 80: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/80.jpg)
in Lancaster. Many of the students at F&M and other institutions are looking for internships and ways to help out with productions.
"If (the commission) succeeds, of course it's beneficial for students," Eitzen said. "There are eager students here."
More people are becoming aware of the economic benefits that film and television projects bring to the state, said Jane Saul, director of the Pennsylvania Film Office. Such projects generated $249 million in business activity in 2005, according to statistics from the Harrisburgbased office.
While Philadelphia and Pittsburgh continue to attract the bulk of productions, some smaller areas are joining Lancaster and forming film commissions. There is a film office in Scranton, as well as one that covers the Pocono Mountains region. Regional offices offer production companies links to local businesses that the state sometimes cannot provide, Saul said.
"Having regional offices is something that we welcome, she said. "It's a great help."
Ingram predicts big things for the Lancaster Film Commission. Several film productions expected to come to the Lancaster area could provide between $5 million and $12 million in additional economic activity during the summer, he said. Any businesses interested in becoming part of a database of companies willing to assist the commission can e-mail Ingram at [email protected].
Bright lights, little cities
Parts of several movies have been filmed in the midstate. Movies, followed by their Central Pennsylvania filming locations, include:
"Rough Cut" Harrisburg, Lancaster
"Girl, Interrupted" Harrisburg, Hanover, Cumberland County
"The Altoona Riding Club" Lancaster, Lebanon and Franklin counties
"Lucky Numbers" Harrisburg
"8 Millimeter" Harrisburg
"For Richer or Poorer" York County
"Major League II" Harrisburg
"Gettysburg" Gettysburg, Adams County
"Mannequin" Harrisburg
"Witness" Lancaster County
SOURCE: PENNSYLVANIA FILM OFFICE
Advanced Media Group Page 24 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 80 of 198 Monday, November 23, 2015
![Page 81: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/81.jpg)
Advanced Media Group Page 25 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 81 of 198 Monday, November 23, 2015
![Page 82: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/82.jpg)
RE: Iformation of Master Training ProgramFrom: Stan Caterbone ([email protected]) Sent:Mon 2/25/08 7:54 AMTo: jay ingram lfc ([email protected])
Can you give me a time when you will be in today?
"Well, there's an even greater right, and that's the right of life, liberty and to live crime-free."Craig Stedman, Lancaster County District Attorney
January 3, 2008Lancaster Intelligencer Journal
Advanced Media GroupStan J. Caterbonewww.amgglobalentertainmentgroup.com Visit Our Blog For Journey of a WhistleblowerVisit Our Blog For Research Into ESP - Mental Telepathy & The U.S. Governments ActivitiesVisit Our Video Biography
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct and fraud within International Signal & Control, Plc. of Lancaster, Pa. (ISCpleaded guilty to selling arms to Iraq via South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend our reputation and the truth without the aid of law enforcement and the media, which would normally prosecute and expose public corruption. We utilize our communications to thwart further libelous and malicious attacks on our person, our property, and our business. We continue our fight for justice through the Courts, and some communications are a means of protecting our rights to continue our pursuit of justice. Advanced MediaGroup is also a member of the media. Reply if you wish to be removed from our Contact List. Number 7.
From: [email protected]: [email protected]: Re: Iformation of Master Training ProgramDate: Mon, 25 Feb 2008 06:47:09 -0500
Give a call first to make sure I'm here.
Jay
892-3844
----- Original Message -----
From: Stan Caterbone
To: jay ingram lfc
Sent: Sunday, February 24, 2008 9:17 PM
Subject: RE: Information of Master Training Program
Advanced Media Group Page 26 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 82 of 198 Monday, November 23, 2015
![Page 83: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/83.jpg)
I'll stop by your office for a visit on Nolt Road, unless there is another location. I look forward to some classes.
Thank You.
"Well, there's an even greater right, and that's the right of life, liberty and to live crime-free."
Craig Stedman, Lancaster County District AttorneyJanuary 3, 2008
Lancaster Intelligencer Journal
Advanced Media GroupStan J. Caterbone
www.amgglobalentertainmentgroup.com Visit Our Blog For Journey of a WhistleblowerVisit Our Blog For Research Into ESP - Mental Telepathy & The U.S. Governments ActivitiesVisit Our Video Biography
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct and fraud within International Signal & Control, Plc. of Lancaster, Pa. (ISC pleaded guilty to selling arms to Iraq via South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend our reputation and the truth without the aid of law enforcement and the media, which would normally prosecute and expose public corruption. We utilize our communications to thwart further libelous and malicious attacks on our person, our property, and our business. We continue our fight for justice through the Courts, and some communications are a means of protecting our rights to continue our pursuit of justice. Advanced Media Group is also a member of the media. Reply if you wish to be removed from our Contact List. Number 7.
From: [email protected]: [email protected]: Re: Iformation of Master Training ProgramDate: Sun, 24 Feb 2008 16:51:38 -0500
Hi Stan,
Simply put, the Master Program entails any and all aspects of film making. From the origination of an idea to the writing, rewriting, casting, directing, producing and marketing.
A person who is interested in one or more of the aspects, signs up and takes courses at their own rate of speed. Cost is nominal.
Best regards,
Jay Ingram
----- Original Message -----
From: Stan Caterbone
Advanced Media Group Page 27 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 83 of 198 Monday, November 23, 2015
![Page 84: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/84.jpg)
Sent: Sunday, February 24, 2008 10:21 AM
Subject: Iformation of Master Training Program
Could you please send me information on your Master Training Program?
Please visit some of my film experience by clicking here.
"Well, there's an even greater right, and that's the right of life, liberty andto live crime-free."
Craig Stedman, Lancaster County District AttorneyJanuary 3, 2008
Lancaster Intelligencer Journal
Advanced Media GroupStan J. Caterbone
www.amgglobalentertainmentgroup.com Visit Our Blog For Journey of a WhistleblowerVisit Our Blog For Research Into ESP - Mental Telepathy & The U.S. Governments ActivitiesVisit Our Video Biography
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and publicly discredited since 1987 due to going public (Whistle Blower) with allegations of misconduct and fraud within International Signal & Control, Plc. of Lancaster, Pa. (ISC pleaded guilty to selling arms to Iraq via South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced todefend our reputation and the truth without the aid of law enforcement and the media, which would normally prosecute and expose public corruption. We utilize our communications to thwart further libelous and malicious attacks on our person, our property, and our business. We continue our fight for justice through the Courts, and some communications are a means of protecting our rights to continue our pursuit of justice. Advanced Media Group is also a member of the media. Reply if you wish to be removed from our Contact List. Number 7.
Advanced Media Group Page 28 of 142 Thursday, November 5, 2015 ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 84 of 198 Monday, November 23, 2015
![Page 85: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/85.jpg)
Page 1 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 29 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 85 of 198 Monday, November 23, 2015
![Page 86: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/86.jpg)
RE: Meeting wih the Dept of Justice.From:Stan Caterbone ([email protected])Sent: Sat 3/22/08 8:36 AM
To: Barry A. Solodky ([email protected])
Cc: FBI, Field Office ([email protected]); Landis, Detective Michael ([email protected]);[email protected]
Bcc:
Owings, Lisa ([email protected]); [email protected];
[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected]; [email protected];
[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];[email protected]; [email protected]; [email protected];
[email protected]; [email protected] 22, 2008
Re: Meeting With Department of Justice
Barry Solodky,
First, I would have responded earlier, however, your email found it's way into my junk email.
Secondly, as an officer of the court, you better be careful about spreading lies about me and fabricationsabout events that did not happen. By the way, a copy of this will go directly to the Federal Bureau ofInvestigation Philadelphia Field Office and Detective Michael Landis of the Lancaster County District
Attorney Office. Who do you think you are talking to?
Thirdly, here is what transpired. The day before I received an ORDER from the Third Circuit Court ofAppeals, which was purposely postmarked 10 days after the Clerk filed and dated the Mail to copy to
myself. The ORDER was for a no response to a Show Cause ORDER, which someone had stole for mymail, which I never received. The Third Circuit case was an appeal from my Chapter 11 bankruptcy.
Now, on Wednesday morning I made plans to go to the Hotel Brunswick and take some measurements in
the Movie Theater, which I am in the middle of a development plan. As usual, I walked into the lobby onthe street level adjacent to the parking garage and saw the eisel with the notice that the "Department ofJustice" was holding bankruptcy hearings. I was told a few years ago earlier in my Chapter 11 that theyoften hold hearings in Lancaster, at the Brusnwick or at the Hotel on Manheim Pike. As soon as I saw the
sign I figured I would see if Joe Adams, my Trustee from the Philadelphia Office of the Department ofJustice Office of Trustee that handles my case, was here.
So, as I usually do, I went to the office of Kevin, the Hotel Brunswick General Manager to get the key to
the movie theater, as per our agreement with Hamid, the owner of the Hotel Brunswick. He was not in hisoffice, and the Desk Manager had to page him. I asked him where the Department of Justice was holdingthe hearings, and told him I needed to talk to someone there, while he was trying to locate Kevin, theGeneral Manager. I told him I would be right back.
I went to the Presidential Room where they were holding meetings. When I arrived, the Trustee, or whatprivate panel trustee, was conducting a meeting with a Spanish woman, who had a young girl for atranslator. I patiently waited by the wall as you walk in until the entire interview was over. After the
private panel trustee dismissed the woman, I approached her and asked her if she was from theDepartment of Justice Office of the Trustee, and she responded that she was a private panel trustee. Isimply told her that I had a problem with someone obstructing justice with my Third Circuit case andasked her if Joe Adams was in her office. She said she was not from the Philadelphia Office. I gave her
my card and some woman kept trying to talk and interfere. I just calmly left. I went to meet Kevin, theGeneral Manager, he opened the movie theater and I spent approximately 1 hour taking measurements ofthe existing floor plan.
Page 2 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 30 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 86 of 198 Monday, November 23, 2015
![Page 87: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/87.jpg)
There was no incident to speak of. Any incident was a lie, regardless of the person that kept interferingwith our conversation that was trying to cause problems. It was not me, you fool.
I would suggest that you provide this email to the person that told you that fabricated lie and anyone elsethat you communicate with regarding your so called version of an "incident". Follow this link and you mayread why people like you lie about these incidents.
Now, you have a nice Easter Weekend. And by the way, I am a supporter of Senator Clinton and I dovolunteer my services, just in case you were wondering.
"Well, there's an even greater right, and that's the right of life, liberty and to live crime-free."
Craig Stedman, Lancaster County District Attorney
January 3, 2008
Lancaster Intelligencer Journal
Advanced Media Group
Stan J. Caterbone
www.amgglobalentertainmentgroup.com
Visit Our Blog For Journey of a WhistleblowerVisit Our Blog For Research Into ESP - Mental Telepathy & The U.S. Governments ActivitiesVisit Our Video Biography
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered, defamed, and publicly discredited
since 1987 due to going public (Whistle Blower) with allegations of misconduct and fraud within International Signal & Control, Plc. ofLancaster, Pa. (ISC pleaded guilty to selling arms to Iraq via South Africa and a $1 Billion Fraud in 1992). Unfortunately we areforced to defend our reputation and the truth without the aid of law enforcement and the media, which would normally prosecuteand expose public corruption. We utilize our communications to thwart further libelous and malicious attacks on our person, our
property, and our business. We continue our fight for justice through the Courts, and some communications are a means ofprotecting our rights to continue our pursuit of justice. Advanced Media Group is also a member of the media. Reply if you wish tobe removed from our Contact List. Number 7.
>
Page 3 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 31 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 87 of 198 Monday, November 23, 2015
![Page 88: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/88.jpg)
Subject: > Date: Thu, 20 Mar 2008 08:18:00 -0400> From: [email protected]
> To: [email protected]> > Hi Stan,>
> Hope this note finds you well.> > Yesterday afternoon I had to attend some bankruptcy meetings on behalf of some clients. While therethe Trustee told me about an event which concerned her. She showed me your card and told me what
happened. In fact she said she almost considered calling the police because of the incident.> > I assured her you were not the type of person that would do anything inappropriate. I did want you toknow she is not an employee of the Dept. of Justice or the Bankruptcy Court; she is a private panel
trustee just as I was for 33 years. If for some reason you have issues with the bankruptcy system she isnot a person who should be hassled as she has nothing to do with your case.> > I'm sending this only because I don't want there to be any further incidents which might cause her
concern or the Federal marshals will get involved and I know they can be nasty. Needless to say I don'twant to see anything to you which would cause you any problems.> > I am sure I will bump into you soon. Have a nice Easter.
> > > Barry A. Solodky, Esquire> Blakinger, Byler & Thomas, P.C.
> 28 Penn Square> Lancaster, PA 17603> (717) 509-7273> E-mail: [email protected]
>
>
>
>
Page 4 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 32 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 88 of 198 Monday, November 23, 2015
![Page 89: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/89.jpg)
www.amgglobalentertainmentgroup.com [email protected]
Investors and/or interested deveopers please respond via email.
Advanced Media Group's (8) Year Investment into Downtown Lancaster, The Lancaster Convention Center & Our UPS STORE Concept.
ADVA�CED MEDIA GROUP’S (8) YEAR I�VESTME�T I� DOW�TOW� LA�CASTER
This weekend at the Party that Mayor Rick Gray hosted on Friday night in the Dome, we were discussingthe needs for retail establishments in Downtown Lancaster. He had told me that the James StreetImprovement District had done a retail assessment of the current retail space and a needs analysis ofneeded retail spaces that would compliment the already existing retail space. I have been investing time
and energies to the revitalization of Downtown Lancaster for the past 8 years.
I informed Rick that I have an exclusive agreement for a UPS Shipping/Copy Store in
Downtown Lancaster, and he thought it was a great fit and a great idea for Downtown
Lancaster. Advanced Media Group would also add services such as scanning, imaging, and
records management services that would attract an additional market to the concept.
I am an ardent advocate for the Downtown Lancaster Convention Center and in April of 2005 we sued theLancaster County Hoteliers for refusing to pay the Tourism Excise Tax. We are still continuing our effortsfor the Excelsior Place Development on East King Street.
We currently have a signed Non Disclosure Agreement with Realtor Jeff Lefevre and Caldwell Banker forthe Excelsior Place Property.
I also had authored the Development Plan for the S.N. Lombardo Development on 626 West CharllotteStreet in May of 2007.
In 2005 I had worked closely with Joe Pinto, the former General Manager for the Lancaster Barnstormersand the Clipper Stadium; drawing on my experience working with Tony Bongiovi and Power StationStudios in New York for our "Digital Movie". I was trying to help the Clipper Stadium locate and contractmusic acts for a Summer Concert Series. I had begun talks with Sara McLachlan and hope that when
Sara McLachlan returns on tour the Clipper will be one of her concerts.
I had talks with Clair Brothers in Lititz (In 1987 Gene Clair was considering an investment into my"Digital Movie with Tony Bongiovi) to try to help attract some acts to the Stadium. Unfortunately, when I
had met with Randy Patterson of the Redevelopment Authority, which owns the Stadium, I learned thatconcerts were not a top priority for them or the Barnstormers.
Maybe that will change before next Spring. And of course, Sheryl Crow is a shareholder of AdvancedMedia Group, so someday maybe she might come around. I was also trying to convince Joe Pinto of the
merits of a country concert or two, and we all know by now what Country Music means to LancasterCounty.
My family had various successful investments in Downtown Lancaster over the past 50 years. My fathersfirst Dry Cleaners (Sam Caterbone Cleaners, Inc.,) was on the corner of Plum and Orange Streets before
expanding and moving to Manheim Pike in the early 1960’s. My Uncle Dominic (Mickey) Roda was theproprietor for Garvins Beauty Salon, in the former Garvins Department Store, which later moved acrossthe street to the Lancaster Parking Garage on East King Street. My other Uncle Benjamin Roda operatedRoda’s Beauty Salon on East King Street. And I had an office for SJ Caterbone Painting and Renovating’
Page 5 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 33 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 89 of 198 Monday, November 23, 2015
![Page 90: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/90.jpg)
on the corner of Walnut and Marshall Streets.
Here is my resume and below is my website for your information. You may also visit my Video Biography
by clicking here.
We do have a very successful track record for vision in our 25 year history of entrepreneurship.
Sincerely,
Stan J. Caterbone
Advanced Media Group
Stan J. Caterbone
www.amgglobalentertainmentgroup.com
Visit Our BlogVisit Our Video Biography
Notice and Disclaimer: Stan J. Caterbone and the Advanced Media Group have been slandered,defamed, and publicly discredited since 1987due to going public (WhistleBlower) with allegations of misconduct and fraud within International Signal& Control, Plc. of Lancaster, Pa. (ISCpleaded guilty to selling arms toIraq via South Africa and a $1 Billion Fraud in 1992). Unfortunately we are forced to defend ourreputationand the truth without the aid of law enforcement and the media,which would normally prosecute and expose public corruption. We utilize ourcommunications to thwartfurther libelous and malicious attacks on our person, our property, and ourbusiness. We continue our fightforjustice through the Courts, and some communications are a means of protectingour rights to continue our pursuit of justice. AdvancedMedia Group is also a member of the media. Reply if you wish tobe removed from our Contact List.
Page 6 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 34 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 90 of 198 Monday, November 23, 2015
![Page 91: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/91.jpg)
www.amgglobalentertainmentgroup.com
mailto:[email protected] Blog: http://advancedmediagroup.wordpress.com/
Research Bog: at: www.advancedmediagroupresearch.wordpress.com Video Biography at: http://www.youtube.com/profile?user=advancedmediagroup
Stanley J. Caterbone Advanced Media Group 1250 Fremont Street Lancaster, PA 17603
Advanced Media Group’s Downtown Lancaster Revitalization
Action Plan
Advanced Media Group has been working with Downtown Lancaster developers and the James Street Investment District to facilitate this action plan.
Project 1 – Excelsior Place on East King Street
In 1998 Advanced Media Group had developed a comprehensive plan for the revitalization of the Excelsior Place Historic Property (Sprecher Brewery) located 1 block from the proposed Downtown Lancaster Convention Center. We had planned a unique entertainment complex comprised of a Pub, an upscale restaurant in the lower catacomb, and a nightclub in the first floor. We had also developed and designed a state-of-the-art video conferencing facility to compliment the Convention Center. We have joined in the talks and discussions with principals, stakeholders, and taxing authorities concerning the present proposals and the future of the revitalization of Downtown Lancaster and the Convention Center.
Advanced Media Group/Project Hope filed a Civil Action in the Court of Common Pleas of Lancaster County against Drew Anthon and the Eden Resort Inn (Lancaster County Hoteliers) for their attempts to withhold the Tourism Tax and Hotel Tax that supports the Downtown Lancaster Convention Center. The City of Lancaster supported the civil action. We also proposed an alternative plan to move the Convention Center to the Hotel Brunswick and Lancaster Square to all of the major stakeholders.
In 2007 Advanced Media Group signed a Non Disclosure Agreement with a local real estate firm to continue the advancement of the Excelsior Place Business Plan.
Project 2 – UPS/MBE Copy Store or FedEx/Kinkos Copy & Print Store
Advanced Media Group has an exclusive agreement for a UPS Shipping/Copy Store or a FedEx/Kinkos in Downtown Lancaster. There is no such service currently serving the needs of downtown businesses and it is a vital component for the Lancaster County Convention Center. In 1998 Advanced Media Group had contacted Mail Box Etc., and began initial franchise due diligence. However when the Lancaster County Convention Center was stalled, Advanced Media Group also put the project on the back burner. In 2005 Advanced Media Group negotiated for the exclusive right of first refusal to move the UPS Store at Stone Mill Plaza to downtown Lancaster.
Page 7 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 35 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 91 of 198 Monday, November 23, 2015
![Page 92: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/92.jpg)
The UPS/MBE Franchise is ranked number 4 among all franchises and number one in the shipping-postal store categories by Forbes.
Advanced Media Group would also add services such as scanning, imaging, and records management services that would attract an additional market to the concept. The UPS/MBE Franchise is ranked number 4 among all franchises and number one in the shipping-postal store categories by Forbes. Advanced Media Group is currently studying several site locations, including storefronts at the Brunswick Hotel, and a possible East King Street site. Advanced Media Group would like to cater to the many legal firms that conduct business in the Lancaster County Courthouse.
In 1990 Advanced Media Group developed and copyrighted the AMG Legal Systems Prototype which was a digital search and retrieval application designed to help legal firms deal with the complexities of organizing and filing court cases.
Advanced Media Group has specialized in records management and has a vast knowledge base and experience in optical publishing and records management. This service would allow firms to convert and store records off-site in a secure location with state-of-the-art retrieval services.
Typical Desktop Publishing services and binding services would also be offered.
Project 3 – Downtown Lancaster Movie Theater
A downtown Lancaster Movie Theater is vital to support the Lancaster County Convention Center and the Downtown Lancaster Revitalization at large.
Advanced Media Group has been performing due diligence on reopening the movie theaters at the Hotel Brunswick for the past 18 months. A recent site survey confirms that the movie theaters are in perfect operating condition and negotiations with local business leaders are continuing. The Brunswick movie theater has 2 screens with approximately 500 seats per screen.
Project 4 – Big Box Retail in Downtown Lancaster
Advanced Media Group has been attempting to help facilitate the attraction of a big box retailer for Downtown Lancaster. In 2006 Advanced Media Group had discussions with the owner of Bulova Technologies regarding the development of that building to a retail store. The Advanced Media Group has contacted the Corporate development teams of the Hard Rock Café and Best Buy Electronics Stores.
In 2005 Advanced Media Group had talks with former Mayor Charlie Smithgall in attempts at trying to lure a Cabelas or a Pro Shops to the site.
Advanced Media Group Stan J. Caterbone www.amgglobalentertainmentgroup.com Visit Our Blog at: www.advancedmediagroup.wordpress.com Visit Our Video Biography at: http://www.youtube.com/profile?user=advancedmediagroup Visit Our Research Blog at: www.advancedmediagroupresearch.wordpress.com
Page 8 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 36 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 92 of 198 Monday, November 23, 2015
![Page 93: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/93.jpg)
THEATER AT HOTEL BRUNSWICK
OPEARATING BUDGETAdvanced Media Group
March 28, 2008
% of Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1
Account Descriptions Sales Nov-09 Dec-09 Jan-10 Feb-10 Mar-10 Apr-10 May-10 Jun-10 Jul-10 Aug-10 Sep-10 Oct-10 Nov-10
SALES
Gross Sales Forcast 49,500 119,731 97,356 95,606 95,606 95,606 99,981 128,975 155,100 151,919 151,919 151,919 155,169
Theater 1
Theater 2
Performances
Concessions 52.00% 32,175 77,825 63,282 62,144 62,144 62,144 52,990 68,357 82,203 80,517 80,517 80,517 82,239
Trailers 12.00% 4,950 11,973 9,736 9,561 9,561 9,561 11,998 15,477 18,612 18,230 18,230 18,230 18,620
Advertisers 17.00% 7,425 17,960 14,603 14,341 14,341 14,341 16,997 21,926 26,367 25,826 25,826 25,826 26,379
Theater Rentals 18.00% 4,950 11,973 9,736 9,561 9,561 9,561 17,997 23,216 27,918 27,345 27,345 27,345 27,930
Sales - Misc 1.00% 0 0 0 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000
Total Sales 100.00% 49,500 119,731 97,356 96,606 96,606 96,606 100,981 129,975 156,100 152,919 152,919 152,919 156,169
COST OF GOODS SOLD
Distribution Fees 36.00% 11,583 28,017 22,781 22,372 22,372 22,372 19,076 24,608 29,593 28,986 28,986 28,986 29,606
Food & Beverage 43.00% 2,129 5,148 4,186 4,111 4,111 4,111 5,159 6,655 8,003 7,839 7,839 7,839 8,007
24.00% 1,782 4,310 3,505 3,442 3,442 3,442 4,079 5,262 6,328 6,198 6,198 6,198 6,331
34.00% 1,683 4,071 3,310 3,251 3,251 3,251 6,119 7,893 9,492 9,297 9,297 9,297 9,496
Total C.O.G.S. 17,177 41,547 33,783 33,175 33,175 33,175 34,434 44,419 53,416 52,321 52,321 52,321 53,440
GROSS PROFIT 32,324 78,185 63,574 63,431 63,431 63,431 66,548 85,556 102,684 100,598 100,598 100,598 102,729
GROSS PROFIT MARGIN 65.30% 65.30% 65.30% 65.66% 65.66% 65.66% 65.90% 65.82% 65.78% 65.79% 65.79% 65.79% 65.78%
OPERATING EXPENSES
Payroll & Related Expenses
Wages 21.16% 20,856 20,856 20,856 20,856 20,856 20,856 30,000 30,000 30,000 30,000 30,000 30,000 30,000
Management Salaries 8.51% 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833
Payroll Taxes 3.08% 3,600 3,600 3,600 3,600 3,600 3,600 4,083 4,083 4,083 4,083 4,083 4,083 4,083
Insurance, Work. Comp. 0.81% 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029
Insurance, Health 1.25% 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595
Total Payroll Related 35% 37,914 37,914 37,914 37,914 37,914 37,914 47,541 47,541 47,541 47,541 47,541 47,541 47,541
Direct Operating Expenses
Supplies 1.24% 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578
Outside Services 0.49% 618 618 618 618 618 618 618 618 618 618 618 618 618
Trash Removal 0.58% 741 741 741 741 741 741 741 741 741 741 741 741 741
Total Direct Operating 3.46% 2,937 2,937 2,937 2,937 2,937 2,937 2,937 2,937 2,937 2,937 2,937 2,937 2,937
12/26/2009 Page 1 of 6
Page 9 of 38
Advanced M
edia Group Theater at H
otel Brunsw
ick, Decem
ber 26, 2009Advanced Media Group Page 37 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 93 of 198 Monday, November 23, 2015
![Page 94: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/94.jpg)
THEATER AT HOTEL BRUNSWICK
OPEARATING BUDGETAdvanced Media Group
March 28, 2008
% of Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1 Year 1
Account Descriptions Sales Nov-09 Dec-09 Jan-10 Feb-10 Mar-10 Apr-10 May-10 Jun-10 Jul-10 Aug-10 Sep-10 Oct-10 Nov-10
Indirect Operating Expenses
Advertising & Promotions 3.10% 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954
Repairs & Maintenance 0.50% 642 642 642 642 642 642 642 642 642 642 642 642 642
Telephone (In-Utilities) 0.19% 247 247 247 247 247 247 247 247 247 247 247 247 247
Utilities 2.49% 2,500 2,500 2,500 2,500 2,500 2,500 3,500 3,500 3,500 3,500 3,500 3,500 3,500
Water & Sewer 0.40% 512 512 512 512 512 512 512 512 512 512 512 512 512
Cable 0.04% 48 48 48 48 48 48 48 48 48 48 48 48 48
Office Exp. & Supplies 0.48% 614 614 614 614 614 614 614 614 614 614 614 614 614
Miscellaneous 0.38% 486 486 486 486 486 486 486 486 486 486 486 486 486
Travel Expense 0.25% 313 313 313 313 313 313 313 313 313 313 313 313 313
Licenses 0.16% 210 210 210 210 210 210 210 210 210 210 210 210 210
Dues & Subscriptions 0.10% 125 125 125 125 125 125 125 125 125 125 125 125 125
Contributions 0.29% 375 375 375 375 375 375 375 375 375 375 375 375 375
Miscellaneous Taxes (DID) 0% 167 167 167 167 167 167 167 167 167 167 167 167 167
Total Indirect Operating 9% 10,193 10,193 10,193 10,193 10,193 10,193 11,193 11,193 11,193 11,193 11,193 11,193 11,193
Non-Operating Expenses
Rent 3.93% 0 0 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000 5,000
Legal & Accounting 0.59% 755 755 755 755 755 755 755 755 755 755 755 755 755
Insurance, Property & Liability 0.34% 429 429 429 429 429 429 429 429 429 429 429 429 429
Misc General & Administrative 0.33% 417 417 417 417 417 417 417 417 417 417 417 417 417
Debt Service 0.79% 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000
Total Non-Operating 5.97% 2,601 2,601 7,601 7,601 7,601 7,601 7,601 7,601 7,601 7,601 7,601 7,601 7,601
Total Expenses 28,860 28,860 33,860 33,860 33,860 33,860 35,860 35,860 35,860 35,860 35,860 35,860 35,860
NET PROFIT -21,321 24,540 4,930 4,787 4,787 4,787 -2,724 16,285 33,412 31,327 31,327 31,327 33,457
NET PROFIT MARGIN -43.07% 20.50% 5.06% 4.95% 4.95% 4.95% -2.70% 12.53% 21.40% 20.49% 20.49% 20.49% 21.42%
12/26/2009 Page 2 of 6
Page 10 of 38
Advanced M
edia Group Theater at H
otel Brunsw
ick, Decem
ber 26, 2009Advanced Media Group Page 38 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 94 of 198 Monday, November 23, 2015
![Page 95: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/95.jpg)
THEATER AT HOTEL BRUNSWICK
OPEARATING BUDGETAdvanced Media Group
March 28, 2008
% of
Account Descriptions Sales
SALES
Gross Sales Forcast
Theater 1
Theater 2
Performances
Concessions 52.00%
Trailers 12.00%
Advertisers 17.00%
Theater Rentals 18.00%
Sales - Misc 1.00%
Total Sales 100.00%
COST OF GOODS SOLD
Distribution Fees 36.00%
Food & Beverage 43.00%
24.00%
34.00%
Total C.O.G.S.
GROSS PROFIT
GROSS PROFIT MARGIN
OPERATING EXPENSES
Payroll & Related Expenses
Wages 21.16%
Management Salaries 8.51%
Payroll Taxes 3.08%
Insurance, Work. Comp. 0.81%
Insurance, Health 1.25%
Total Payroll Related 35%
Direct Operating Expenses
Supplies 1.24%
Outside Services 0.49%
Trash Removal 0.58%
Total Direct Operating 3.46%
Year 1 YEAR 1 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2
Dec-10 FYE Jan-11 Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-11 Aug-11 Sep-11 Oct-11 Nov-11
138,294 147,969 147,969 147,969 146,656 170,781 187,844 187,844 187,844 178,094 159,531 159,531
73,296 850,350 78,423 78,423 78,423 77,728 90,514 99,557 99,557 99,557 94,390 84,552 84,552
16,595 174,411 17,756 17,756 17,756 17,599 20,494 22,541 22,541 22,541 21,371 19,144 19,144
23,510 250,283 25,155 25,155 25,155 24,932 29,033 31,933 31,933 31,933 30,276 27,120 27,120
24,893 242,407 26,634 26,634 26,634 26,398 30,741 33,812 33,812 33,812 32,057 28,716 28,716
1,000 11,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000
139,294 1,528,450 148,969 148,969 148,969 147,656 171,781 188,844 188,844 188,844 179,094 160,531 160,531
26,386 306,126 28,232 28,232 28,232 27,982 32,585 35,841 35,841 35,841 33,980 30,439 30,439
7,136 74,997 7,635 7,635 7,635 7,567 8,812 9,693 9,693 9,693 9,190 8,232 8,232
5,642 60,068 6,037 6,037 6,037 5,984 6,968 7,664 7,664 7,664 7,266 6,509 6,509
8,464 82,418 9,056 9,056 9,056 8,975 10,452 11,496 11,496 11,496 10,899 9,763 9,763
47,628 523,609 50,960 50,960 50,960 50,508 58,817 64,693 64,693 64,693 61,335 54,943 54,943
91,665 1,004,841 98,008 98,008 98,008 97,148 112,964 124,150 124,150 124,150 117,758 105,589 105,589
65.81% 65.74% 65.79% 65.79% 65.79% 65.79% 65.76% 65.74% 65.74% 65.74% 65.75% 65.77% 65.77%
30,000 323,424 32,000 32,000 32,000 32,000 32,000 32,000 32,000 32,000 32,000 32,000 32,000
10,833 130,000 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833 10,833
4,083 47,067 4,083 4,083 4,083 4,083 4,083 4,083 4,083 4,083 4,083 4,083 4,083
1,029 12,351 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029 1,029
1,595 19,142 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595 1,595
47,541 531,983 49,541 49,541 49,541 49,541 49,541 49,541 49,541 49,541 49,541 49,541 49,541
1,578 18,930 18,930 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578 1,578
618 7,413 8,523 710 710 710 710 710 710 710 710 710 710
741 8,896 8,896 741 741 741 741 741 741 741 741 741 741
2,937 35,240 36,349 3,029 3,029 3,029 3,029 3,029 3,029 3,029 3,029 3,029 3,029
12/26/2009 Page 3 of 6
Page 11 of 38
Advanced M
edia Group Theater at H
otel Brunsw
ick, Decem
ber 26, 2009Advanced Media Group Page 39 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 95 of 198 Monday, November 23, 2015
![Page 96: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/96.jpg)
THEATER AT HOTEL BRUNSWICK
OPEARATING BUDGETAdvanced Media Group
March 28, 2008
% of
Account Descriptions Sales
Indirect Operating Expenses
Advertising & Promotions 3.10%
Repairs & Maintenance 0.50%
Telephone (In-Utilities) 0.19%
Utilities 2.49%
Water & Sewer 0.40%
Cable 0.04%
Office Exp. & Supplies 0.48%
Miscellaneous 0.38%
Travel Expense 0.25%
Licenses 0.16%
Dues & Subscriptions 0.10%
Contributions 0.29%
Miscellaneous Taxes (DID) 0%
Total Indirect Operating 9%
Non-Operating Expenses
Rent 3.93%
Legal & Accounting 0.59%
Insurance, Property & Liability 0.34%
Misc General & Administrative 0.33%
Debt Service 0.79%
Total Non-Operating 5.97%
Total Expenses
NET PROFIT
NET PROFIT MARGIN
Year 1 YEAR 1 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2 Year 2
Dec-10 FYE Jan-11 Feb-11 Mar-11 Apr-11 May-11 Jun-11 Jul-11 Aug-11 Sep-11 Oct-11 Nov-11
3,954 47,445 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954 3,954
642 7,710 642 642 642 642 642 642 642 642 642 642 642
247 2,965 247 247 247 247 247 247 247 247 247 247 247
3,500 38,000 3,500 3,500 3,500 3,500 3,500 3,500 3,500 3,500 3,500 3,500 3,500
512 6,144 512 512 512 512 512 512 512 512 512 512 512
48 571 48 48 48 48 48 48 48 48 48 48 48
614 7,367 614 614 614 614 614 614 614 614 614 614 614
486 5,833 486 486 486 486 486 486 486 486 486 486 486
313 3,756 313 313 313 313 313 313 313 313 313 313 313
210 2,521 210 210 210 210 210 210 210 210 210 210 210
125 1,500 125 125 125 125 125 125 125 125 125 125 125
375 4,500 375 375 375 375 375 375 375 375 375 375 375
167 2,000 167 167 167 167 167 167 167 167 167 167 167
11,193 130,311 11,193 11,193 11,193 11,193 11,193 11,193 11,193 11,193 11,193 11,193 11,193
5,000 60,000 10,200 10,200 10,200 10,200 10,200 10,200 10,200 10,200 10,200 10,200 10,200
755 9,065 755 755 755 755 755 755 755 755 755 755 755
429 5,149 429 429 429 429 429 429 429 429 429 429 429
417 5,000 417 417 417 417 417 417 417 417 417 417 417
1,000 12,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000 1,000
7,601 91,214 12,801 12,801 12,801 12,801 12,801 12,801 12,801 12,801 12,801 12,801 12,801
35,860 1,312,356 109,884 76,564 76,564 76,564 76,564 76,564 76,564 76,564 76,564 76,564 76,564
22,394 216,094 -11,876 21,444 21,444 20,584 36,400 47,586 47,586 47,586 41,194 29,025 29,025
16.08% 14.14% -7.97% 14.40% 14.40% 13.94% 21.19% 25.20% 25.20% 25.20% 23.00% 18.08% 18.08%
12/26/2009 Page 4 of 6
Page 12 of 38
Advanced M
edia Group Theater at H
otel Brunsw
ick, Decem
ber 26, 2009Advanced Media Group Page 40 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 96 of 198 Monday, November 23, 2015
![Page 97: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/97.jpg)
THEATER AT HOTEL BRUNSWICK
OPEARATING BUDGETAdvanced Media Group
March 28, 2008
% of
Account Descriptions Sales
SALES
Gross Sales Forcast
Theater 1
Theater 2
Performances
Concessions 52.00%
Trailers 12.00%
Advertisers 17.00%
Theater Rentals 18.00%
Sales - Misc 1.00%
Total Sales 100.00%
COST OF GOODS SOLD
Distribution Fees 36.00%
Food & Beverage 43.00%
24.00%
34.00%
Total C.O.G.S.
GROSS PROFIT
GROSS PROFIT MARGIN
OPERATING EXPENSES
Payroll & Related Expenses
Wages 21.16%
Management Salaries 8.51%
Payroll Taxes 3.08%
Insurance, Work. Comp. 0.81%
Insurance, Health 1.25%
Total Payroll Related 35%
Direct Operating Expenses
Supplies 1.24%
Outside Services 0.49%
Trash Removal 0.58%
Total Direct Operating 3.46%
Year 2 YEAR 2
Dec-11 FYE
181,469 2,003,500
96,178 1,061,855
21,776 240,420
30,850 340,595
32,664 360,630
1,000 12,000
182,469 2,015,500
34,624 382,268
9,364 103,381
7,404 81,743
11,106 122,614
62,498 690,005
119,971 1,325,495
65.75% 65.77%
32,000 384,000
10,833 130,000
4,083 49,000
1,029 12,351
1,595 19,142
49,541 594,493
1,578 36,283
710 16,336
741 17,051
3,029 69,670
12/26/2009 Page 5 of 6
Page 13 of 38
Advanced M
edia Group Theater at H
otel Brunsw
ick, Decem
ber 26, 2009Advanced Media Group Page 41 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 97 of 198 Monday, November 23, 2015
![Page 98: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/98.jpg)
THEATER AT HOTEL BRUNSWICK
OPEARATING BUDGETAdvanced Media Group
March 28, 2008
% of
Account Descriptions Sales
Indirect Operating Expenses
Advertising & Promotions 3.10%
Repairs & Maintenance 0.50%
Telephone (In-Utilities) 0.19%
Utilities 2.49%
Water & Sewer 0.40%
Cable 0.04%
Office Exp. & Supplies 0.48%
Miscellaneous 0.38%
Travel Expense 0.25%
Licenses 0.16%
Dues & Subscriptions 0.10%
Contributions 0.29%
Miscellaneous Taxes (DID) 0%
Total Indirect Operating 9%
Non-Operating Expenses
Rent 3.93%
Legal & Accounting 0.59%
Insurance, Property & Liability 0.34%
Misc General & Administrative 0.33%
Debt Service 0.79%
Total Non-Operating 5.97%
Total Expenses
NET PROFIT
NET PROFIT MARGIN
Year 2 YEAR 2
Dec-11 FYE
3,954 47,445
642 7,710
247 2,965
3,500 42,000
512 6,144
48 571
614 7,367
486 5,833
313 3,756
210 2,521
125 1,500
375 4,500
167 2,000
11,193 134,311
10,200 122,400
755 9,065
429 5,149
417 5,000
1,000 12,000
12,801 153,614
76,564 1,642,092
43,407 373,408
23.79% 18.53%
12/26/2009 Page 6 of 6
Page 14 of 38
Advanced M
edia Group Theater at H
otel Brunsw
ick, Decem
ber 26, 2009Advanced Media Group Page 42 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 98 of 198 Monday, November 23, 2015
![Page 99: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/99.jpg)
Not Inclusive - Shared Costs To Be Determined ALTERNATECAPITAL REQUIREMENTS BUDGET FUNDING
LOBBY
Paint
Concession Counters & Displays
Popcorn Machines
Food Displays
Carpet Restoration
Lobby Subtotal $0.00
TICKET BOOTH & OFFICE
Ticket System
Office Furnishings
Ticket Booth & Office Subtotal $0.00
THEATER 1
Curtains
Theater Seats
Floor Lighting
Floor Painting/Carpeting
Sound System
Theater 1 Subtotal $0.00
THEATER 2
Curtains
Theater Seats
Floor Lighting
Floor Painting/Carpeting
Sound System
Theater 2 Subtotal $0.00
STAGE
Sound System
Lighting
Stage
Moveable Partition
Backstage Setup
Stage Subtotal $0.00
Projection Room
Projector 1
Projector 2
DLP Projector 1
DLP Projector 2
Page 15 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 43 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 99 of 198 Monday, November 23, 2015
![Page 100: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/100.jpg)
Racks
Painting
Floor Paint/Carpeting
Projection Room Subtotal $0.00
2ND FLOOR OFFICES
Computer Systems
Desk and Counters
Office Supplies
Legal - Registration/Agreements
Design - Logo/Stationary/Business Cards
Printers/Calculators/IPOD/Iphone
2nd Floor Subtotal $0.00
Total Costs $0.00
Page 16 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 44 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 100 of 198 Monday, November 23, 2015
![Page 101: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/101.jpg)
Strong Cinema Products Equipment QuotationA wholly-owned subsidiary of Ballantyne of Omaha
4350 McKinley Street, Omaha, NE 68112 USA Quote No.: QSTSRF_10908TEL: +1 (402) 453-4444; FAX: +1 (402) 453-7238 Date: 1/8/08WEB: www.strong-cinema.com; EMAIL: [email protected] Customer Request: 1/8/08
Prices Good For: 90 daysDEALER (Exporter): SHIP TO (Project): Customer Account No.:Roger Fitzwater 2 screens Req'd Date of Shipment:717-278-4199 Method of Transport: [email protected] Goods Terms: TBA
Freight Terms: FOB OmahaHandling/Duties Agent:
Line Unit LIST Unit TotalItem Quant Unit Order No. Description Price (US$) Net (US$) Net (US$)
Film Equipment1 2 EA SIMSYS3/RS Simplex Millennium II 35mm Projector: $13,430.00 40% $8,058.00 16,116.00
w/ Two-Lens Manual Turret w/ New Analog LED Visible red readers Change over Unit Synch Motor 110/220V, 60Hz.
2 2 SET FGS-35 35mm Upper & Lower Film Guidance system $260.00 40% $156.00 312.00
XENON CONSOLE SYSTEM:3 2 EA HLIIA-HR3 Strong Highlight II Console System 3000 watts $9,935.00 40% $5,961.00 11,922.00
5 2 EA PREWIRE Projector Prewired $475.00 40% $285.00 570.00
6 2 eCNA100-C1 Strong eCNA100 console mount automation with Single termination board(394321-2K) Failsafe included
$3,160.00 40% $1,896.003,792.00
7 3 EA LTIX3000WH 3000 watts Xenon bulbs $1,050.00 50% $525.00 1,575.00
PLATTER SYSTEM:8 2 EA 2464160 35SCDC-3 35mm 3 Deck platter w/ 2 Payout Assy $6,450.00 45% $3,547.50 7,095.009 1 EA 2465004 AP Make-Up Table $1,330.00 45% $731.50 731.50
10 1 EA 2468278 SP-35 35mm tape splicer $800.00 45% $440.00 440.00
LENSES11 2 EA ISCO ISCO Lens FLAT (Sizes to be determined) $860.00 1,720.0012 2 EA ISCO ISCO Lens SCOPE (Sizes to be determined) $1,962.00 3,924.00
File: QSTS RF_10908 Page 1 of 2
Page 17 of 38
Advanced M
edia Group Theater at H
otel Brunsw
ick, Decem
ber 26, 2009Advanced Media Group Page 45 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 101 of 198 Monday, November 23, 2015
![Page 102: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/102.jpg)
13 2 EA SR-70B Basic Sound Rack with Power strip, fan, rack panel and prewire $1,000.00 2,000.00
14 6 EASC-322
2-way, 2x15", bi-amp screen channel, consists of DCS HF-63 and DCS LF-3215 components $1,227.50
7,365.00
15 2 EASB-7218
Cinema subwoofer, dual 18" 1500 W transducers, 101 dB sensitivity
$1,067.25 2,134.50
16 20 EASR-110B
Cinema surround loudspeaker, 10" 2-way, 95°H x 85°V, 94 dB sensitivity
$266.00 5,320.00
17 20 EAQM-SW
Side wall quick-mount for DCS-SR-18, SR-26, SR-46 and SR-110B
$17.30 346.00
18 2 EADCA 3022
2 channels, 625 watts/ch at 8O, 1050 watts/ch at 4O, 1500 watts/ch at 2O for Subwoofer
$1,165.25 2,330.50
19 6 EADCA 1622
2 channels, 350 watts/ch at 8O, 600 watts/ch at 4O, 800 watts/ch at 2O for Stage
$776.50 4,659.00
20 4 EADCA 2422
2 channels, 475 watts/ch at 8O, 825 watts/ch at 4O, 1200 watts/ch at 2O for Surrounds
$974.00 3,896.00
Total FOB Omaha NE 76,248.50
All Prices are FCA Origin or Ballantyne of Omaha. Please allow 4-6 weeks lead time on major equipment orders.50% due with order.
File: QSTS RF_10908 Page 2 of 2
Page 18 of 38
Advanced M
edia Group Theater at H
otel Brunsw
ick, Decem
ber 26, 2009Advanced Media Group Page 46 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 102 of 198 Monday, November 23, 2015
![Page 103: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/103.jpg)
Published on April 15, 2008, Lancaster New Era (PA)
Walk This Way
Get ready for a sea change,'' says Rick Gray. Lancaster's enthusiastic mayor is talking about how thedowntown will look next spring, when the first visitors arrive at the Lancaster County Convention Centerand Marriott Hotel on Penn Square.
If all goes as planned, the difference will be dramatic. Sidewalks, lighting, benches and trash receptacleswill be standardized by then to unify the downtown streetscape. And new street trees will be planted.
Click for complete article, (1046 words)
Article 4 of 2121, 677490000000.1109609
Published on April 13, 2008, Sunday News (Lancaster, PA)
The future that wasn't
Believe it or not, it was once a nice place. Not long ago, there was news about the partial demolition of the
east side of Lancaster Square, that desolate, windswept plaza surrounded by the hulking, windowlessBulova building on one side and the Hotel Brunswick on the other, all connected by a creepy, abandoned,multilevel concrete walkway.
It's all so ... so ... Soviet. And so sad. But it wasn't always that way. I remember.When Lancaster Square went up around
Click for complete article, (524 words)
Article 5 of 2121, 677490120008.080013.1109609
Published on April 13, 2008, Sunday News (Lancaster, PA)
The Future That Wasn't
Believe it or not, it was once a nice place. Not long ago, there was news about the partial demolition of theeast side of Lancaster Square, that desolate, windswept plaza surrounded by the hulking, windowlessBulova building on one side and the Hotel Brunswick on the other, all connected by a creepy, abandoned,multilevel concrete walkway.
It's all so ... so ... Soviet. And so sad. But it wasn't always that way. I remember.When Lancaster Square went up around
Click for complete article, (527 words)
Published on February 27, 2008, Intelligencer Journal (Lancaster, PA)
Lancaster Square could see start of overhaul as soon as summer
City officials said Tuesday that plans to demolish portions of Lancaster Square are being finalized and
pieces of the concrete eyesore could start coming down this summer. The proposed work would occur onthe east side of the square - between the Hotel Brunswick and the Bulova building - and likely wouldinclude demolition of the pedestrian walkway that spans North Queen Street, the stairwell and planter onthe south side of the square and the removal of the roof around the second-floor
Page 19 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 47 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 103 of 198 Monday, November 23, 2015
![Page 104: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/104.jpg)
Click for complete article, (320 words)
Published on August 30, 2007, Intelligencer Journal (Lancaster, PA)
Lancaster Square: It's a dirty job, but ...
Maybe Mike Rowe would be up for the job. You might know him as the wisecracking host of "Dirty Jobs"on the Discovery Channel. One week he's picking up roadkill; the next he's feeling inside a cow for a fetus.Rowe shows us the people who do these jobs, and he rolls up his sleeves, holds his nose and tries thework himself.
Well, we have a job in Lancaster he should try.It's not catching the acid vandal. I'm afraid
Click for complete article, (593 words)
Published on January 21, 2007, Sunday News (Lancaster, PA)
Budget to build
Up until now the convention center project on Penn Square has been much on "Big talk, little action." Nextmonth that should change, says the executive director of the Lancaster County Convention Center
Authority.
When the authority's new budget is unveiled, the public will see evidence that the embattled project iswell under way, said David Hixson, because the majority of the authority's spending in fiscal 2007-08 willgo toward actually
Click for complete article, (1337 words)
Published on December 24, 2006, Sunday News (Lancaster, PA)
Authority started marketing work on project in 2003
Dan Logan doesn't just live his job. He eats and sleeps it, too. And that's a good thing, because Logan,president and owner of Growth Business Development, Medford, N.J., makes a living as a consultant tothe hospitality industry.
For several years, Logan, once vice president of operations for the Hotel Brunswick, has worked with theLancaster County Convention Center Authority and others in the local tourism and hospitality industries to
develop a plan to market
Click for complete article, (1496 words)
Published on August 3, 2006, Intelligencer Journal (Lancaster, PA)
Two squares beat as one
The fortunes of Lancaster Square are tied to those of Penn Square, according to the owner of Hotel
Brunswick. Hamid Zahedi wrote Wednesday that his hotel, based at Lancaster Square, could be renovatedto "four-diamond/four-star" quality, and its two-story concrete annex transformed into "two or threerestaurants ... plus entertainment for persons in their 30s and older."
Zahedi outlined his vision Wednesday in a letter to Lancaster County
Click for complete article, (724 words)
Page 20 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 48 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 104 of 198 Monday, November 23, 2015
![Page 105: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/105.jpg)
Published on August 2, 2006, Intelligencer Journal (Lancaster, PA)
Move convention center 1 block away
TO THE EDITOR: Now that there is some type of finality to the controversy of the convention center, Iwould like to make a suggestion to the county, Penn Square Partners and anyone involved with thedowntown convention center idea. I have been relating this idea to numerous friends over the past sixmonths, and every one of them has thought it to be an excellent idea.
I think the convention center concept is a great idea. However, the cost and scope of the "former"
Click for complete article, (326 words)
Article 125 of 2121, 677490000000.873631
Published on August 2, 2006, Lancaster New Era (PA)
Convention center needed Lillian G. Bennett Lancaster
Editor, New Era: Lancaster needs a convention center, not a Plan "B."
Look what good things happened to Covington, Ky., an excellent example of a new discovery for people
who want to know about this country.Lancaster County not only has country but the city to offer visitors.How many people know that this is the oldest inland city in our country that opened up the West? Howmany know that Thaddeus Stevens and James Buchanan battled it out politically here
Click for complete article, (405 words)
Article 126 of 2121, 677490000000.872402
Published on July 30, 2006, Sunday News (Lancaster, PA)
FAN MAIL Days until I let my Lancaster Newspapers subscription expire: 53.
Jim Mertz, Ephrata
CONVENTION CENTER, HOTEL PROJECTIn an article published over a year ago on your editorial pages, I asked:"Is the downtown situation so unpromising that we need to do 'something', no matter how great thesubsidy, how much is put at risk, and how questionable the prospects for success?"
I then went on to describe several alternative
Click for complete article, (2091 words) Published on June 26, 2006, Intelligencer Journal (Lancaster, PA)
Claims downtown boat may leak
TO THE EDITOR: I would like to respond to J. Herbert Zug's letter ("Raising questions on downtown plan,"Intell, June 20).
Zug uses the analogy "a rising tide lifts all boats" unless the boat has a hole in it. He asserts that those inopposition to the proposed convention center and hotel project are in the boats with the leaks.Unfortunately, it is Zug's argument that is doomed to sink. His letter takes liberty
Page 21 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 49 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 105 of 198 Monday, November 23, 2015
![Page 106: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/106.jpg)
Click for complete article, (417 words)
Article 137 of 2121, 677490000000.857213
Published on June 23, 2006, Intelligencer Journal (Lancaster, PA)
Great divide laid bare at convention center mtg.
A steady stream of people at Ephrata Public Library stood behind a microphone stand Thursday night,waiting for a chance to vent their feelings about the controversial hotel/convention center proposed fordowntown Lancaster. Some criticized the project. Others spoke in favor of it.
Whether people were "right" or "wrong," it was clear Thursday night the community remains stronglydivided over the project.
More than 60 people attended the
Click for complete article, (886 words)
Published on May 5, 2006, Intelligencer Journal (Lancaster, PA)
County study takes dim view of center
Developers of the proposed downtown convention center/hotel should consider "downsizing" the project or
finding an "alternate use for the site." If the current project is built as proposed, it will lose $1.3 millionper year.
So says the executive summary of a feasibility study of the $139.8 million project completed by PKFConsulting at the request of the Lancaster County commissioners.The summary was presented by PKF partner Dave Arnold
Click for complete article, (713 words)
Published on December 25, 2005, Sunday News (Lancaster, PA)
Ed Flick exemplifies the spirit of Christmas
Judy A.
Strausbaugh Ed Flick's office at Fulton Bank overlooks Penn Square, where all kinds of people traverse.It's one of Flick's favorite views because he likes people.Saturday morning, he was near his office helping people less fortunate have a Merry Christmas.
For the fourth straight year, the longtime banking executive volunteered to help fill and distribute 1,200boxes of food for Lancaster County Project for the
Click for complete article, (751 words)
Article 185 of 2121, 777415
Published on December 19, 2005, Intelligencer Journal (Lancaster, PA)
Rep. Pitts leads fight to derail slots parlor
A developer of the proposed slot-machine parlor in downtown Lancaster said Sunday more developmentsrelated to the project could be announced as early as this week.
Page 22 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 50 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 106 of 198 Monday, November 23, 2015
![Page 107: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/107.jpg)
Also, local leaders and U.S.Rep.Joseph Pitts are expected to convene today at Lancaster County Courthouse with the aim of developing
strategies to kill the $150 million project proposed for the Bulova Technologies building."To develop a consensus on a game plan and to work together" is how
Click for complete article, (773 words)
Article 186 of 2121, 777659
Published on December 19, 2005, Lancaster New Era (PA)
The Bulova building: Casino or federal courthouse?
The downtown Lancaster building where two local attorneys want to open a slots parlor is also among theU.S. government's favored sites for a new federal courthouse, officials said today.
"It's my understanding that people in the federal government are focusing on the Bulova building as thebest-suited site for a courthouse," Mayor-elect Rick Gray said this morning.
"My understanding is that it's along the way with
Click for complete article, (611 words) Published on November 9, 2005, Intelligencer Journal (Lancaster, PA)
Lancaster elects Gray as mayor
Election Day was Gray's day in Lancaster city.
Democratic challenger Rick Gray defeated two-term incumbent Mayor Charlie Smithgall Tuesday by 1,323votes, based on unofficial results."There's going to be a new day in Lancaster," Gray told a cheering crowd gathered in a Hotel Brunswickballroom.
"Now we have the real task ahead of us — the task of governing."A defeated and tired-looking Smithgall
Click for complete article, (948 words)
Article 206 of 2121, 761167
Published on November 9, 2005, Intelligencer Journal (Lancaster, PA)
Democratic ticket sweeps into City Council, takes 2 row offices
Lancaster city Democrats celebrated a sweep of City Council and two row offices Tuesday, upsetting astrong Republican ticket that included three two-term incumbents.
"We're going to bring civility back to City Council," newly elected City Councilwoman Kendra Saunders saidTuesday night at an election-night gathering in a ballroom at Hotel Brunswick.
The victory by Saunders, Louise Williams, Tim Roschel and Jose Urdaneta means, starting in January,
Click for complete article, (629 words)
Article 207 of 2121, 761414
Published on November 9, 2005, Lancaster New Era (PA)
Page 23 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 51 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 107 of 198 Monday, November 23, 2015
![Page 108: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/108.jpg)
Gray's stunning win highlights big day for local Democrats How did he pull it off?
As Rick Gray emphasized late Tuesday night, today is a new day in Lancaster.
With chants of "Sweep! Sweep! Sweep!," jubilant Lancaster City Democrats Tuesday night celebrated the
ousting of Republican Mayor Charlie Smithgall, all four Republicans on City Council, and Republican controlof the city controller and treasurer offices.Gray, the Democratic mayoral candidate, rode a wave of change to an overwhelming victory.He took 58 percent of the vote in his
Click for complete article, (1005 words) Published on October 21, 2005, Intelligencer Journal (Lancaster, PA)
Maybe Lancaster Square needs an exorcism
I've begun to wonder whether a curse has been placed on Lancaster Square.
Could it be that the ghosts of the original Brunswick Hotel, the old Lancaster YMCA and the Grand Theater— flattened by the wrecking ball in the 1960s to make way for so-called progress — have gotten back at
us for our folly?When it comes to Lancaster Square, it's almost eerie the way we can't get our act together. The paralysisis maddening,
Click for complete article, (648 words)
Article 219 of 2121, 751343
Published on October 18, 2005, Intelligencer Journal (Lancaster, PA)
City, county take new looks at Lancaster Sq.
Lancaster city and county officials, recently at odds over projects in the city, are separately pushing for
new plans to revamp the east side of Lancaster Square, which has been widely criticized for being littlemore than a concrete eyesore.
Mayor Charlie Smithgall said Sunday he has asked Hunter Interests Inc. of Maryland to submit a revisededition of its 2002 Lancaster Square Master Plan and expects to hear from it this week.Hunter's original vision was to put the
Click for complete article, (810 words)
Article 220 of 2121, 751605
Published on October 18, 2005, Lancaster New Era (PA)
What's in store for Lancaster Square?
Lancaster City and county officials — who have been sharply divided on Penn Square — are both setting
their sights on Lancaster Square.
Lancaster Mayor Charlie Smithgall has asked Hunter Interests Inc., a Maryland consultant, to revise its2002 Lancaster Square Master Plan. He expects an answer this week.Meanwhile, county administrator Don Elliott says he has asked Franklin & Marshall College to surveycounty residents about what they would like to
Page 24 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 52 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 108 of 198 Monday, November 23, 2015
![Page 109: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/109.jpg)
Click for complete article, (364 words)
Published on October 13, 2005, Intelligencer Journal (Lancaster, PA)
Bankruptcy filers need not go for broke
Though it may come as a surprise to some, the new bankruptcy law that takes effect Monday does notallow bankers to collect a pound of flesh from debtors.
In fact, attorneys and bankers say the new law will seriously impact at most 10 percent of people filing for
Chapter 7 bankruptcy — the most common type of bankruptcy filing in Lancaster County.Chapter 7 offers debtors a clean slate and complete relief from their debts.But fears that the Bankruptcy Abuse Prevention
Click for complete article, (889 words)
Published on October 2, 2005, Sunday News (Lancaster, PA)
Build on success to revitalize city
Robert E. Field
In planning for the future it is important to avoid mistakes of the past; and building on current successesis less risky than pursuing untested concepts. With the proposed convention center/hotel, it is especially urgent that we avoid the mistakes that led tothe failure of Lancaster Square, or we may go down the same disastrous road.
The reasons for that failure, as given by former mayor and guest columnist Art Morris on Aug. 18, werevery wide of the mark.When
Click for complete article, (796 words)
Article 225 of 2121, 744309
Published on October 1, 2005, Lancaster New Era (PA)
Host Resort has new owner
A Florida company with a track record of remodeling its holdings has bought the Lancaster Host Resort &
Conference Center for an undisclosed price.
Milestone Hospitality acquired the Lincoln Highway East property Sept. 23, according to a letter from themotel's departing management company.The 39-year-old motel in East Lampeter Township is a cornerstone of the county's tourism industry.With 330 rooms, it's the county's
Click for complete article, (328 words)
Published on September 22, 2005, Intelligencer Journal (Lancaster, PA)
Smithgall reopens campaign center at Brunswick forrun-up to the election
Touting his record as a crime fighter and job creator, Mayor Charlie Smithgall officially reopened hiscampaign headquarters Wednesday at the Brunswick Hotel.
Page 25 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 53 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 109 of 198 Monday, November 23, 2015
![Page 110: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/110.jpg)
Surrounded by his family and 25 supporters, the Republican mayor said, if re-elected, he would continueto put pressure on criminals, push economic development and work hard to create more jobs."Eight years ago, I ran for mayor because I believed that the city was headed in the wrong direction,"
Smithgall
Click for complete article, (416 words)
Published on July 26, 2005, Intelligencer Journal (Lancaster, PA)
Senate panel OKs funds for Lancaster Square, city garage
Lancaster Mayor Charlie Smithgall’s plan to put the historic Rocky Springs Carousel in Lancaster Squaregot more federal support Monday. The U.S. Senate Appropriations Committee voted to include $200,000
for the rehabilitation of Lancaster Square in its version of the Departments of Transportation, Treasury,Judiciary, Housing and Urban Development, and Related Agencies Fiscal Year 2006 Appropriations bill,U.S. Sen. Arlen Specter said Monday. The Pennsylvania Republican said the
Click for complete article, (482 words)
Published on July 13, 2005, Lancaster New Era (PA)
The Brunswick’s new Taste
THE WEEKLY DISH By E. Martin HulseJIM SWITZENBERG AND RON PFEIFFER have brought a new taste totown. Taste at the Brunswick (151 N. Queen St., Lancaster, 397-4800) will open for dinner Friday with“eclectic city food,” says Switzenberg, director of operations for Taste Catering, which recently partnered
with the Brunswick Hotel, owned by Hamid Zahedi. Tim Olivett, a Tavern on the Green and Moshulu alum,was hired as chef, which returns the Hempfield graduate to the
Click for complete article, (728 words)
Published on May 22, 2005, Sunday News (Lancaster, PA)
New look,hours for Brunswick eatery
The restaurant and bar in the historic downtown Hotel Brunswick is receiving a facelift.
Since the hotel was bought by Hamid Zahedi in February, the lounge and bar was closed and the
restaurant was only open for breakfast, mainly for hotel customers.The lounge and bar reopened this weekend to the public with new paint and carpeting, and will becompletely renovated within the next two weeks with a new bar, dining and lounge furniture. Additionally,lunch and brunch are expected to open
Click for complete article, (254 words)
Article 255 of 2121, 10238724
Published on May 18, 2005, Lancaster New Era (PA)
Library tax rejected; mayor, supporters prevail in cityCity impact? Fall campaigns will target revitalization
Russ Miller called Luis Mendoza last night in hopes of burying the hatchet.
Page 26 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 54 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 110 of 198 Monday, November 23, 2015
![Page 111: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/111.jpg)
The city GOP chairman said the party must reunify after Mayor Charlie Smithgall handily defeatedchallenger Mendoza by nearly a two-to-one margin in Tuesday's primary election.Smithgall earned 65 percent of Republican votes.
"Luis has been a good Republican in the past and I hope we can get everyone on board working for avictory in November," said Miller.United the
Click for complete article, (808 words) Published on April 20, 2005, Intelligencer Journal (Lancaster, PA)
Brunswick owner seeks to revive movie house
The new owner of the Ramada Inn Brunswick is proposing to revitalize a portion of Lancaster Square into amovie/performing arts theater.
But before Hamid Zahedi of New York begins, he wants to see more people invest in entertainmentattractions downtown, said a consultant during a press conference Tuesday on the square.
Thomas DePaul of the DePaul Group of Lancaster said he was hired by Zahedi to develop the project at theformer Eric Theater, located next to the Brunswick.DePaul
Click for complete article, (413 words)
Article 266 of 2121, 10235702
Published on April 19, 2005, Intelligencer Journal (Lancaster, PA)
Turn W&S into an IMAX theater
TO THE EDITOR:
It's hard to believe that the proposed convention center for Penn Square is still being considered. Can't
Penn Square Partners read? Common knowledge makes it clear that the convention center business is amess, "plagued by a taxpayer-funded burst of expansion and a continuing dearth of customers." To enticebusiness, convention center managers are giving space away.I suggest that anyone who wants an honest appraisal of the
Click for complete article, (209 words)
Article 267 of 2121, 10235539
Published on April 17, 2005, Sunday News (Lancaster, PA)
Teaching retailers to capitalize on convention center
A national small-retailing expert plans to tell Lancaster city store owners how they can do more than just
scratch their niche.
John Ogden, a professor at Kutztown University's Small Business Development Center and a publishedconsultant on retail marketing, will visit Tuesday morning at the request of the Downtown InvestmentDistrict Authority.Kelly Withum, who became director of the DID about three months ago, said the organization is
sponsoring Ogden's visit
Click for complete article, (633 words)
Page 27 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 55 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 111 of 198 Monday, November 23, 2015
![Page 112: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/112.jpg)
Article 268 of 2121, 10235545
Published on April 17, 2005, Sunday News (Lancaster, PA)
Following faith, D.R.E.A.M.S.Entrepreneur who overcame hard times seeks to boost women, minority businesses.
An entrepreneur relatively unknown in Lancaster wants to introduce his venture by helping other smallbusinesses showcase what they have to offer.
Macajah Lee Brown Jr. is organizing the Women & Minority Business Expo, set for 4 to 10 p.m. April 28 atthe Brunswick Hotel, 151 N. Queen St.
Brown, 45, is founder of D.R.E.A.M.S. Minority Business Network, a one-man operation that looks forpartners who share his desire to boost entrepreneurial opportunities for women, blacks,
Click for complete article, (594 words) Published on March 22, 2005, Lancaster New Era (PA)
Shaub accuses Henderson of attempting to kill hotel project
Lancaster County Commissioner Pete Shaub accused fellow Commissioner Molly Henderson this morning ofattempting to snuff out hope for a Penn Square hotel and convention center.
Henderson presented motions this morning that would direct county attorneys to look for alternatives tothe $129 million Marriott hotel and meeting center planned for the former Watt & Shand building.
That project remains on life support as lawmakers attempt to advance a compromise tax arrangement
Click for complete article, (433 words)
Article 280 of 2121, 10232443
Published on March 17, 2005, Lancaster New Era (PA)
What about the Brunswick?
The new owners of Hotel Brunswick are trying to take advantage of the apparent failure of the planned$129 million Penn Square hotel and convention center.
Hamid Zahedi, whose real estate partnership purchased the aging Brunswick in January, has suggestedconvention center planners now turn their attention to his Lancaster Square property, two blocks north."All I am saying is if they're so hell-bent on having a convention center, this is another
Click for complete article, (514 words)
Hotel Brunswick aims to meet rising expectationsFirst renovated rooms in $4 million project ready to open this month. Lancaster New EraPublished: May 04, 2007
12:40 EST
• Article
• Photos
• Related
• Share It
Page 28 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 56 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 112 of 198 Monday, November 23, 2015
![Page 113: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/113.jpg)
Link Tags
By TIM MEKEEL
The complete text of this article is no longer available online.
Recent PostsShowing 5 most recent comments out of 16 total TalkBack comments about this articleView full comments | Comment on this article
At least they are finally going to get smart and move the check in and lobby to the first floor, queen andchestnut corner. This hotel never had any street presence. One has to look hard to even know that it'sthere! Who knew it had a pool?
They've had a high visible location, and never utilized it! seems like now they will. Hopefully it will spillover to the rest of the square.
kwf1817QUOTE(kwf1817 @ May 6 2007, 09:14 PM) At least they are finally going to get smart and move the check in and lobby to the first floor, queen andchestnut corner. This hotel never had any street presence. One has to look hard to even know that it's
there! Who knew it had a pool?
They've had a high visible location, and never utilized it! seems like now they will. Hopefully it will spillover to the rest of the square.
This was an integral part of the late 1960s "Urban Renewal" plan. The expectation was that people wouldwalk INSIDE the "mall" from the parking garages to the shops.
When the current Brunswick was built, a big chunk of the first floor was taken up by an open public
walkway between Chestnut St. and Lancaster Square; this was not enclosed until many years later. Retailstores were supposedly of a higher value than a hotel lobby, and indeed there was a bank in theBrunswick building on N. Queen St. near Chestnut for a number of years. The "shopping mall" betweenthe Brunswick and the Hess Dept. Store at Queen and Chestnut was expected to be the pedestrian artery
(these "shops" still exist, being used as meeting rooms for the Brunswick). The second and third level ofthe "shopping mall" included a large movie theater, later divided into two (this still exists, it is stillvacant).
Originally there were three pedestrian levels connected and surrounding Lancaster Square on all foursides. There was also parking on the roof level, and it WOULD HAVE BEEN possible to drive from the DukeSt. garage over to the Prince St. garage at the top level! (I don't think it was ever implemented). Ofcourse this ended when the west side of the "concrete monstrosity" was demolished a few years after it
was completed. The Duke St. ramp to this parking level remained for many years, but was laterdemolished to add a few street-level spaces next to the Duke St. parking garage. There are still lines forparking spaces visible (from inside the Brunswick) on the roof of the movie theater above the "shoppingmall" on the east side of Lancaster Square.
The designers of this project actually expected the second level to be nearly as busy as street level. Thepoint is, the Brunswick was designed by "urban planners" who thought they knew better than people whowalk the streets. Of course, as we know now, what was once one of the three busiest commercial blocks in
Lancaster City is now a concrete wasteland (and yes, that DOES include Binns Park).
FYI, the Brunswick was originally designed to have two more floors than it does now. Rather thanredesigning the entire building, the top two floors were simply deleted. The structure is strong enough to
add these additional floors.
Page 29 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 57 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 113 of 198 Monday, November 23, 2015
![Page 114: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/114.jpg)
Artie SeeIt’s time for a little research. Someone needs to pull out the last set of rah-rah articles run in the LNPwhen this fine establishment last went from the Hotel Brunswick to the Ramada Brunswick. I do not recall
the year but I certainly recall the content. The owner at the time was going to spend $XX million dollarsthen to bring it up to par and turn it around. LNP printed everything that the owner wanted them to printwhether it made any logical sense or not. What happened, more bankruptcy, more managementcompanies, and more trouble? When the mortgage holder finally got tired of the never ending cycle, they
cut their losses, ate half the debt, and go that “asset” off of their books to the current owner. Not only didthis story run then but I am sure that it ran in simlar fashion previous to that. What do we have now,more of the same…outrageous claims by owners trying to make themselves look good and a newspapermonopoly that does not even ask questions. Let me suggest a couple. How many dollars per room is
allegedly being spent? How many dollars per room is the national average for new construction of a hotelsuch as the Brunswick? What is the difference? How or why could someone substantiate the current claimsfor what is merely cosmetic work, no bricks or mortar? I guess it is probably too much to ask though sinceLNP was not willing to ask the same questions about the CC & hotel, why would they ask or do any
research for this one?
enlightened176
QUOTE(Artie See @ May 7 2007, 06:32 AM)
This was an integral part of the late 1960s "Urban Renewal" plan. ..... Of course, as we know now, whatwas once one of the three busiest commercial blocks in Lancaster City is now a concrete wasteland (and
yes, that DOES include Binns Park).
Artie: Thanks for posting the historical facts of design-intent of this property. Interesting.
Hamid only paid $15 thousand/room for many reasons. 37 years of failure. How sad.
from the article: The Hotel Brunswick stands on a site that has been the location of a lodging facility since
the long-gone Hofnagle Hotel opened there in 1776. The current hotel opened in 1970. It was acquired bya partnership led by Hamid Zahedi in 2005 for $3.4 million, according to newspaper files.
DimBulb
I was able to confirm that the Brunswick is indeed closed, except for a few rooms on weekends. Most ofthe rooms are currently gutted.
The newspaper article is wrong.
Articles Tagged: Brunswick Hotel
• Photos
• Video
• Map
• Articles
WHERE LANCASTER BURIED ITS NORTH QUEEN MISTAKE 2008-05-04 00:21:00CHIP SMEDLEY, Staff
Future explorers traipsing through the brickyards off Harrisburg Pike might believe they've discovered theruins of an ancient temple. They will encounter massive columns jutting out of the ground. Delicatelycarved stone capitals that topped those columns, freed by soil erosion, peek ......
Downtown high-rise could cost $25M
Page 30 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 58 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 114 of 198 Monday, November 23, 2015
![Page 115: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/115.jpg)
2008-03-20 12:16:00BERNARD HARRIS, StaffPlans for what could be a 10-story or more office, retail, museum, residential and parking garage building
in downtown Lancaster received initial approval Wednesday night. The plans for the proposed building, onthe former Empire TV parking lot at North Queen and East Chestnut streets, would......
Lancaster Square could see start of overhaul as soon as summer
2008-02-27 01:41:00JENNIFER TODD, StaffCity officials said Tuesday that plans to demolish portions of Lancaster Square are being finalized andpieces of the concrete eyesore could start coming down this summer.The proposed work would occur on
the east side of the square — between the Hotel Brunswick and the Bulova buildin......
City businessman's killing sparks forum 2008-01-04 01:44:00
P.J. REILLY, StaffJose Urdaneta has been a Lancaster city councilman for the past two years.During that time, he has beenfrustrated by the general lack of interest many city residents have in getting involved in theircommunity.Thursday night was an exception, he said.The 50 people who turned......
Can candidates dance? You be the judge 2007-10-18 03:16:00JEFF HAWKES, Staff
Latin music blasted from the nightclub's speakers, and dance instructor Oscar Restrepo, swivelingsmoothly, called out a cadence.Four middle-aged couples on the dance floor stepped and turned to theup-tempo beat.Rick Calderon had opened his Rumbha nightclub, next to Hotel Bruns......
Lancaster Square: It's a dirty job, but … 2007-08-30 02:39:00JEFF HAWKES, StaffMaybe Mike Rowe would be up for the job.You might know him as the wisecracking host of "Dirty Jobs" on
the Discovery Channel. One week he's picking up roadkill; the next he's feeling inside a cow for a fetus.Rowe shows us the people who do these jobs, and he rolls up his sleeves, holds hi......
Hotel Brunswick checks in with downtown upgrades
2007-05-13 00:06:00JUDY A. STRAUSBAUGH, Political writerDevelopers of the $170-million convention center and hotel going up at Penn Square plan a kick-offcelebration this month. Meanwhile, renovation of a landmark hotel in downtown Lancaster is a towering
example of the revitalization momentum created by the convention-center project, say local eco......
Hotel Brunswick aims to meet rising expectations 2007-05-04 12:40:00
TIM MEKEELAround the Hotel Brunswick, Kevin Bergman sees a city on the rise. Now it's time for the hotel to join thatmovement. The Queen and Chestnut streets landmark has started a renovation costing more than $4million to invigorate the property. "It's no secret that our product......
14 seek convention center board seat 2007-03-21 01:28:00Dave Pidgeon, Staff
Fourteen hopefuls have lined up to serve on the Lancaster County Convention Center Authority board,among them one of the project's fiercest adversaries — Ronald Harper Jr.At least half the candidatesseeking the seat have expressed opposition to the convention center and hotel p......Columbia resident was Ford aide
2006-12-27 14:13:01Tom Murse
Page 31 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 59 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 115 of 198 Monday, November 23, 2015
![Page 116: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/116.jpg)
“His voice went ‘Boom, boom, boom.’ He didn’t need a microphone. He was a champion,” remembersKilmer, who is 80 and lives at St. John’s Herr Estate in Columbia. “I had never heard him like that before,”Kilmer said in an interview this morning. “I said, ‘That man over there is not the man behind......
Witness nabs suspect 2006-12-09 01:34:00Brett Hambright
A 30-year-old Lancaster city businessman chased and caught a man who was trying to rob a womanThursday afternoon, police said.
Matthew Bryant, a salesman for Select Security, was working in his second-story office at 150 N. Queen
St. when he heard the woman's cry for help....A 3-hour bickering brouhaha 2006-08-03 13:46:43
By Jack BrubakerBut the problem wasn’t the heat, it was the rigidity. The individual county commissioners, as well as theirpacks of ardent supporters, have developed deeply entrenched positions on the proposed downtownconvention center/hotel and other subjects. So on Wednesday morning they talked at — not w......
What about the Brunswick? 2005-03-17 14:05:27Tom Murse
Hamid Zahedi, whose real estate partnership purchased the aging Brunswick in January, has suggestedconvention center planners now turn their attention to his Lancaster Square property, two blocks north.“All I am saying is if they’re so hell-bent on having a convention center, this is another op......
New owner for Brunswick 2005-01-05 14:27:11Bernard Harris And John M. SpidaliereA real estate partnership headed by Hamid Zahedi, a northern New Jersey shopping center owner, is
expected to close on the 221-room hotel at the corner of Queen and Chestnut streets Jan. 31. Zahedi,reached at his New York office this week, said he plans to renovate the 35-year-old hotel, but his......
Brunswick buy is out for now; 'timing' cited
2004-07-20 13:12:56John M. SpidaliereBut that doesn’t necessarily mean it won’t buy the Lancaster Square hotel months from now. With thethreat of a new lawsuit in the air, four members of the authority voted unanimously to terminate
negotiations with the Massachusetts holding company that owns the Ramada Inn Brunswick Hotel, 151N.......
Authority drops Brunswick deal
2004-07-20 11:18:47P.j. Reilly"That deal is dead," said Dave Hixson, executive director of the authority.
Calling the move a "business decision," Ted Darcus, chairman of the authority board, said the authoritywants to focus all its efforts on building a convention center in Penn Square.
"We didn't want......
Convention Center Authority likely to buy Brunswick 2004-07-14 13:50:54John M. SpidaliereBut the executive director of the Lancaster County Convention Center Authority will wait to make that
recommendation for Monday. “It appears from a community standpoint it would be the best course,’’ saidHixson. The authority will consider extending the due diligence period to buy the Lancast......Reaction: Brunswick move is unrealistic
Page 32 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 60 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 116 of 198 Monday, November 23, 2015
![Page 117: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/117.jpg)
2004-06-03 15:12:02Bernard Harris
"I don't think it could be successful,'' Armstrong, a state senator who represents Lancaster City, said of aproposal by the Lancaster County Convention Center Authority to buy the Brunswick Hotel in LancasterSquare and possibly to build a convention center there.
"That's not a first-cla...AV Specialist has launched a new regional version of the magazine covering the Islamic Republicof Iran. The magazine uses much of the same editorial and advertising material that appears inthe Middle East edition but the Arabic content is replaced with Farsi content and an additional
section provides news and information on technologies and productions specifically relevant toIran. Local content is managed by Pejman Ghorbani, a young Iranian filmmaker based in Tehran.The magazine is distributed through the Nashravaran Journalistic Institute in Tehran and isavailable on subscription - as well as through newsstands and specialist retail outlets in Iran.
“The indigenous film industry in the Islamic Republic of Iran is booming and home-grownprogramming dominates local cinema and television,” explains publisher Kevan Jones. “Over thelast few years we’ve seen a growing interest in our magazine from readers within the IslamicRepublic of Iran and our new regional version reflects the importance of this market within the
Middle East region.”
Much of the editorial content in this new version has been commissioned from local journalistsand is specifically relevant to the region. “For many years Iran has been isolated by language,
culture and political intrigue,” says Nima Abu-Wardeh, a well-known media professional in theMiddle East and presenter of the BBC’s weekly Middle East Business Report. “Despite this, theIranian economy is buoyant and the country is playing an increasingly important role in thecommercial activity of the Middle East. Equally important, Iran has a well-established culture of
cinema and film production that’s hungry for information on the latest video technologies. AVSpecialist’s new Farsi-language edition is likely to provide real value to film and TV professionalsin the Republic.”
The first issue features several international manufacturers of film and TV production technologykeen to expose their products in this fast-growing market. “The television and pro-video marketsin Iran represent a significant portion of our revenues in the Middle East but we’ve often found itdifficult to communicate with our customers in the Republic,” says Robin Hood from Panasonic
Broadcast in the Middle East. “AV Specialist’s new Farsi edition provides us an opportunity to reachour customers and address them in a manner that’s uniquely relevant to them.”
The Nashravaran Journalistic Institute is confident that the latest offering from AV Specialist will be
a resounding success in the Iranian market. “AV Specialist is the first and only broadcast andpro-AV magazine to be distributed in the Islamic Republic of Iran,” says Hamid Zahedi, managingdirector of the Institute. “It provides information that’s just not available through any othersource and the fact that the magazine includes Persian content makes it uniquely relevant to our
market.”
For US companies, trade with Iran is still off-limits but a powerful ‘anti-sanctions’ lobby hasemerged in the US and the publishers are hopeful that the US trade embargo will soon be
relaxed. “The US Dept. of Treasury does not prohibit the export of publications or informationalmaterial to Iran,” explains Kevan Jones, “and even though the trade embargo remains in place,the Iranian market presents an interesting opportunity for US manufacturers who see free tradeas the inevitable outcome of US foreign policy.”
The first copies of the new Farsi-language version appeared in June 2005 but the publishers areplanning a major launch to coincide with the Tehran Short Film Festival taking place from 15-20November.
Published on August 3, 2006, Intelligencer Journal (Lancaster, PA)
Page 33 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 61 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 117 of 198 Monday, November 23, 2015
![Page 118: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/118.jpg)
Two squares beat as one
The fortunes of Lancaster Square are tied to those of Penn Square, according to the owner of Hotel
Brunswick. Hamid Zahedi wrote Wednesday that his hotel, based at Lancaster Square, could be renovatedto "four-diamond/four-star" quality, and its two-story concrete annex transformed into "two or threerestaurants ... plus entertainment for persons in their 30s and older."
Zahedi outlined his vision Wednesday in a letter to Lancaster County
Click for complete article, (724 words)
Article 2 of 17, 677490000000.874098
Published on August 3, 2006, Lancaster New Era (PA)
A 3-hour bickering brouhaha
Lancaster County government approached total meltdown Wednesday - one of the hottest days of theyear. But the problem wasn't the heat, it was the rigidity.
The individual county commissioners, as well as their packs of ardent supporters, have developed deeply
entrenched positions on the proposed downtown convention center/hotel and other subjects.So on Wednesday morning they talked at - not with - each other for nearly three hours.Jane Albright of East Lampeter
Click for complete article, (791 words)
Article 3 of 17, 812695
Published on March 10, 2006, Lancaster New Era (PA)
Fireworks essential for downtown event
Will "Celebrate Lancaster!" the city's popular Fourth of July celebration that's held downtown, end with a
bang or a whimper this year? That's a question for Mayor Rick Gray, who is studying whether the loud andrumbling fireworks finale risks serious damage to historic homes, churches and other buildings or is aparticularly dangerous fire hazard.
A number of people think it is both.They're primarily from the
Click for complete article, (512 words)
Article 4 of 17, 807912
Published on February 28, 2006, Intelligencer Journal (Lancaster, PA)
Fireworks under fire
For the past eight years, Independence Day in Lancaster has meant vendors in the streets, open-air shows
downtown and fireworks over the Greist Building.
For some, however, it also has meant falling embers, rattling windows and structural damage.Lancaster city residents tonight will get the chance to debate the merits of the annual fireworks display."The public ought to know about the attendant problems," Mayor Rick Gray said of the city's annual
Page 34 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 62 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 118 of 198 Monday, November 23, 2015
![Page 119: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/119.jpg)
Click for complete article, (542 words)
Article 5 of 17, 802337
Published on February 15, 2006, Lancaster New Era (PA)
Will fireworks move — again?
Within a few months of taking office eight years ago, Lancaster's new Mayor Charlie Smithgall announcedplans for a Fourth of July celebration that would light up the sky.
The dazzling fireworks display — at six times the cost of the annual Long's Park concert event — could beseen from suburbs a dozen miles away.But it was the estimated 20,000 people who came downtown that were the most important to Smithgall.
His goal was to bring
Click for complete article, (860 words)
Article 6 of 17, 777415
Published on December 19, 2005, Intelligencer Journal (Lancaster, PA)
Rep. Pitts leads fight to derail slots parlor
A developer of the proposed slot-machine parlor in downtown Lancaster said Sunday more developmentsrelated to the project could be announced as early as this week.
Also, local leaders and U.S.Rep.Joseph Pitts are expected to convene today at Lancaster County Courthouse with the aim of developing
strategies to kill the $150 million project proposed for the Bulova Technologies building."To develop a consensus on a game plan and to work together" is how
Click for complete article, (773 words)
Article 7 of 17, 752947
Published on October 21, 2005, Intelligencer Journal (Lancaster, PA)
Maybe Lancaster Square needs an exorcism
I've begun to wonder whether a curse has been placed on Lancaster Square.
Could it be that the ghosts of the original Brunswick Hotel, the old Lancaster YMCA and the Grand Theater— flattened by the wrecking ball in the 1960s to make way for so-called progress — have gotten back at
us for our folly?When it comes to Lancaster Square, it's almost eerie the way we can't get our act together. The paralysisis maddening,
Click for complete article, (648 words)
Article 8 of 17, 751343
Published on October 18, 2005, Intelligencer Journal (Lancaster, PA)
Page 35 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 63 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 119 of 198 Monday, November 23, 2015
![Page 120: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/120.jpg)
City, county take new looks at Lancaster Sq.
Lancaster city and county officials, recently at odds over projects in the city, are separately pushing for
new plans to revamp the east side of Lancaster Square, which has been widely criticized for being littlemore than a concrete eyesore.
Mayor Charlie Smithgall said Sunday he has asked Hunter Interests Inc. of Maryland to submit a revisededition of its 2002 Lancaster Square Master Plan and expects to hear from it this week.Hunter's original vision was to put the
Click for complete article, (810 words)
Article 9 of 17, 729333
Published on August 26, 2005, Lancaster New Era (PA)
A green gem sparkles in center city
Wearing a knowing smile, John Hershey stood amid a crowd of about 300 people this morning for the
official opening of Lancaster’s Binns Park. The fountain he and his team at Derck & Edson, the Lititzarchitectural firm, designed bubbled and hummed nearby. “I feel like an expectant father,” said Hershey.“It is exciting after years of planning to come to this point.” The crowd of dignitaries and city and county
Click for complete article, (801 words)
Article 10 of 17, 719830
Published on August 8, 2005, Lancaster New Era (PA)
The signs they are a-changin’
Quantifying the oft-mentioned economic development created by Clipper Magazine Stadium isn’t easy, but
Lisa Riggs has a suggestion. Riggs, director of the James Street Improvement Project, said you can seethings are looking up in the northwest section of the city simply by, well, looking up. “If nothing else, signsabove businesses in the area, like “A Homerun Location,” “Slugger’s Pizza,” and
Click for complete article, (1282 words) Published on July 13, 2005, Lancaster New Era (PA)
The Brunswick’s new Taste
THE WEEKLY DISH By E. Martin HulseJIM SWITZENBERG AND RON PFEIFFER have brought a new taste totown. Taste at the Brunswick (151 N. Queen St., Lancaster, 397-4800) will open for dinner Friday with
“eclectic city food,” says Switzenberg, director of operations for Taste Catering, which recently partneredwith the Brunswick Hotel, owned by Hamid Zahedi. Tim Olivett, a Tavern on the Green and Moshulu alum,was hired as chef, which returns the Hempfield graduate to the
Click for complete article, (728 words)
Article 12 of 17, 10239134
Published on May 22, 2005, Sunday News (Lancaster, PA)
New look,hours for Brunswick eatery
Page 36 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 64 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 120 of 198 Monday, November 23, 2015
![Page 121: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/121.jpg)
The restaurant and bar in the historic downtown Hotel Brunswick is receiving a facelift.
Since the hotel was bought by Hamid Zahedi in February, the lounge and bar was closed and the
restaurant was only open for breakfast, mainly for hotel customers.The lounge and bar reopened this weekend to the public with new paint and carpeting, and will becompletely renovated within the next two weeks with a new bar, dining and lounge furniture. Additionally,lunch and brunch are expected to open
Click for complete article, (254 words)
Article 13 of 17, 10235743
Published on April 20, 2005, Intelligencer Journal (Lancaster, PA)
Brunswick owner seeks to revive movie house
The new owner of the Ramada Inn Brunswick is proposing to revitalize a portion of Lancaster Square into amovie/performing arts theater.
But before Hamid Zahedi of New York begins, he wants to see more people invest in entertainmentattractions downtown, said a consultant during a press conference Tuesday on the square.Thomas DePaul of the DePaul Group of Lancaster said he was hired by Zahedi to develop the project at theformer Eric Theater, located next to the Brunswick.
DePaul
Click for complete article, (413 words)
Article 14 of 17, 10232443
Published on March 17, 2005, Lancaster New Era (PA)
What about the Brunswick?
The new owners of Hotel Brunswick are trying to take advantage of the apparent failure of the planned$129 million Penn Square hotel and convention center.
Hamid Zahedi, whose real estate partnership purchased the aging Brunswick in January, has suggestedconvention center planners now turn their attention to his Lancaster Square property, two blocks north.
"All I am saying is if they're so hell-bent on having a convention center, this is another
Click for complete article, (514 words)
Article 15 of 17, 10225298
Published on January 9, 2005, Sunday News (Lancaster, PA)
CATCHING UP ON THE NEWS
SUNDAY
Jan. 2 - Richard M. Scott, a World War II fighter pilot and a former mayor of Lancaster, died at 86. Scottwas shot down in combat and escaped from a German prisoner of war camp. He led the move to bringminor-league baseball back to Lancaster. A memorial service Thursday was attended by hundreds.MONDAY
Jan. 3 - James H. Guerin, sentenced in 1992 for his admission that he ran a $1.14 billion contract scam
Page 37 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 65 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 121 of 198 Monday, November 23, 2015
![Page 122: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/122.jpg)
and $50 million smuggling ring involving his business, ISC, and its
Click for complete article, (380 words)
Article 16 of 17, 10225024
Published on January 6, 2005, Intelligencer Journal (Lancaster, PA)
Brunswick to change hands
The Ramada Inn Brunswick will soon have a new owner.
Hamid Zahedi, a northern New Jersey shopping center owner, said he and a group of partners are close tofinalizing a deal for the 221-room hotel. He said the purchase price is less than $3 million.The tax assessment on the 1-acre property is $4.25 million, but Zahedi said the hotel requires significant
renovation, and the purchase price reflects the condition of the building."We'll have to fix
Click for complete article, (155 words)
Article 17 of 17, 10224984
Published on January 5, 2005, Lancaster New Era (PA)
New owner for BrunswickNew York businessman buying Lancaster Square hotel, plans renovations.
The Ramada Inn Brunswick will soon have a new owner.
A real estate partnership headed by Hamid Zahedi, a northern New Jersey shopping center owner, isexpected to close on the 221-room hotel at the corner of Queen and Chestnut streets Jan. 31.
Zahedi, reached at his New York office this week, said he plans to renovate the 35-year-old hotel, but hisplans for the hotel and its annex along Lancaster Square are still undetermined."A lot of our plans are in limbo, because
Click for complete article, (846 words)
Page 38 of 38
Advanced Media Group Theater at Hotel Brunswick, December 26, 2009Advanced Media Group Page 66 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 122 of 198 Monday, November 23, 2015
![Page 123: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/123.jpg)
Advisory, Inc. 11, 1755 Oregon Pike Lancaster, PA 17601 717-569-4100
FINANCIAL Y A I U l i E M E N I GIOUC 1 1 0
STANLEY J. CATERBONE PRESIDENT
By: stan caterbone
ADVANCED MEDIA GROUP Page 1 of 76 05.03.2007
Advanced Media Group Page 67 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 123 of 198 Monday, November 23, 2015
![Page 124: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/124.jpg)
ADVANCED MEDIA GROUP Page 2 of 76 05.03.2007
Advanced Media Group Page 68 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 124 of 198 Monday, November 23, 2015
![Page 125: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/125.jpg)
TABLE OF CONTENTS
SONY JOINTcVENTURE PROPOSAL
"SONY CHALLENGE"
SONY JOINT VENTURE STATISTICS
INVESTOR MARKETING MATERIALS
LEGAL DOCUMENTATION
SCREEN PLAY (1 ST DRAFT)
ADVANCED MEDIA GROUP Page 3 of 76 05.03.2007
Advanced Media Group Page 69 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 125 of 198 Monday, November 23, 2015
![Page 126: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/126.jpg)
THE DIGITAL MOWE
A Joint Venture Proposal for
The Sony Organization
Developed by: Stan J. Caterbone
Representing:
Tony Bongiovi
Power Station Studios
Flatbush Films
Garnillion Studios
Advanced Media Group, Ltd.,
beated in May ~f 1987 t
ADVANCED MEDIA GROUP Page 4 of 76 05.03.2007
Advanced Media Group Page 70 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 126 of 198 Monday, November 23, 2015
![Page 127: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/127.jpg)
SONY CORPORATION
INTRODUCTION
SONY'S ROLE
TIMING
MARKETING AND DISTRIBUTION
PRODUCT DEVELOPMENT
FINANCIAL STRUCTURE
ADVANCED MEDIA GROUP Page 5 of 76 05.03.2007
Advanced Media Group Page 71 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 127 of 198 Monday, November 23, 2015
![Page 128: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/128.jpg)
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
ADVANCED MEDIA GROUP Page 6 of 76 05.03.2007
Advanced Media Group Page 72 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 128 of 198 Monday, November 23, 2015
![Page 129: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/129.jpg)
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. Now add PSDMS, and you have a potential block buster event.
How does Sony fit into all of this?
SONY'S ROLE
What we are seeking to do, is establish a distribution route in which the message of Sony's new technology and its benefits can be more easily and directly passed on to the consumer.
Picture a one or two minute commentary at the beginning of the movie and home video, demonstrating the difference between the quality of theatrical sound now and the new SONY/PSDMS sound. This does two things. First, by demonstrating the difference in quality of the new sound, you reinforce in the audiences mind that it is much better, which as you will hear, there is little doubt. Secondly it reinforces in the audience that Sony truly is a pioneer of advanced innovative technologies.
In addition to the commentary, Sony will receive credits on the film, ie. SONY/PSDMS. We will include in the copyright agreement that Sony equipment must be used to be SONY/PSDMS.
ADVANCED MEDIA GROUP Page 7 of 76 05.03.2007
Advanced Media Group Page 73 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 129 of 198 Monday, November 23, 2015
![Page 130: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/130.jpg)
Sony's name will also be strategically placed throughout the film. This may be done in the form of billboards, advertisements, or Sony equipment being utilized.
A commercial may be developed for n/ promoting both the film and Sony's contributions to advanced audio techniques in the film industry. This could be done as a joint venture between Sony and the distribution company for the theatrical and video 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.
MARKETING1 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
ADVANCED MEDIA GROUP Page 8 of 76 05.03.2007
Advanced Media Group Page 74 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 130 of 198 Monday, November 23, 2015
![Page 131: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/131.jpg)
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? I need to buv a Disc Plaver!
Who's name will they think of first? SONYIPSDMS!
PRODUCT DEVELOPMENT
Bongiovi and Evans at Power Station have developed a revolutionary hybrid mixing console to penetrate the video post production market. This console was developed to enable engineers to produce high quality audio tracks for the film industry as well as the recording industry. This new console utilizes an automation system that can be used by both industries. This new console is especially atractive to the film industry, as it will greatly reduce production costs since mixing costs in a recording studio are much less. At present the console that is being used is a bastardized system that utilizes components from many different pieces of equipment, from a number of different companies, of
ADVANCED MEDIA GROUP Page 9 of 76 05.03.2007
Advanced Media Group Page 75 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 131 of 198 Monday, November 23, 2015
![Page 132: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/132.jpg)
which Sony is one. Because we already have a working model of this console, it would take very little time for a finished product to be manufactured that could carry the SONY name.
The other piece of equipment that is essential to the PSDMS process, is the box that enables the laser disc to automatically read the synchronization track encoded on the film. This piece of equipment can be produced at an extremely low cost. It is this low cost and the fact that the theatres will not have to replace their present projectors that make digital movie sound a reality in 1988.
We feel that with consumers demanding the same quality audio at theatres, as they have become accustomed to with their home entertainment systems, theatre owners will have little problem investing the nominal amount of dollars involved, to upgrade their theatres for digital audio. This investment could be as low as $1000. With the cost being so low, the distribution company may want to consider bearing the burden of this cost, if the theatre owners agree to show Bongiovi's next three films.
FINANCIAL STRUCTURE
SONY will commit four million dollars for the production of Bongiovi's film to be released in 1988.
We would like SONY to commit fifteen million for three to four future products that will follow the same format as the first, so that Bongiovi and SONY will position themselves as the pioneer and leaders in the industry. This will not allow competition to gain access to the marketplace until we are all firmly situated and profitable.
Sony will only pay for expenses to produce 60 second spots. Tony and Power Station will utilize any and all services to help produce the spot and will allow reimbursement for only true costs with no mark up including all of Tony's time which will be free.
ADVANCED MEDIA GROUP Page 10 of 76 05.03.2007
Advanced Media Group Page 76 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 132 of 198 Monday, November 23, 2015
![Page 133: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/133.jpg)
Power Station and Power Productions I will receive a negotiated percentage from all revenues generated from the merchandizing campaign of the SONY/POWER STATION products and the sale that may result to other film studios utilizing Sony/POWER STATION equipment in the PSDMS System.
We will receive four deluxe entertainment systems - Television, VCR, Stereo, Etc. that is top of the line to help during the production of the film.
The purpose of the above and all aspects of this Proposal is to let the separate entities involved maximize their profits for their respective talents; Bongiovi in film and music production and Sony in manufacturing and distribution of equipment and merchandise and later video and film distribution.
ADVANCED MEDIA GROUP Page 11 of 76 05.03.2007
Advanced Media Group Page 77 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 133 of 198 Monday, November 23, 2015
![Page 134: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/134.jpg)
I THE MIGHTY YEN AND FIERCE COMPETITION ARE FORCING IT INTO NEW MARKETS
here he is, sitting on the floor of the spark that has made the company his office with three remote con- synonymous with the success of postwar trols in his hand, listening to a Japan: innovation, shrewd marketing,
Beethoven symphony a t high volume. and quality. As executives repeatedly He recorded the symphony from a dash in for consultations, Morita patient- broadcast of a recent Vienna Philhar- ly explains why one set of speakers he's monic concert in Tokyo, and now he's checking out doesn't quite have the Sony putting the tape to good use. As much sound. as he likes music, Akio Morita likes try- Sony. The very name speaks volumes
I ing out new stereo gear even better. about the company. It comes not from a Morita is 66, and the last flecks of Japanese word that foreigners might
I black long ago vanished from his silver find W u l t to pronounce, but from hair. Although he's spending less time sonus, the Latin word for sound, fine
@ these days in his cluttered, wood-paneled tuned for Japanese tongues. The name chairman's office a t Sony Corp., it's symbolizes the company's origins in its " clear that Morita still provides much of pioneering tape recorders and transistor
64 BWSINES W N E 1,1987' '
radios. I t also has come to signify the international orientation among so many mightjly successful Japanese companies. Some 70% of Sony's sales come from
1 outside Japan. ~ D E DOWN. Recently, though, Sony has become one of the most visible sym- bols of trouble in Japan. Like other Jap anese companies in businesses ranging from autos and steel to electronics and computers, Sony's world has been turned upside down. The dramatic rise of the yen has cramped its ability to compete in export markets. Protectionist sentiment is growing in the U. S. and
COVER STORY
ADVANCED MEDIA GROUP Page 12 of 76 05.03.2007
Advanced Media Group Page 78 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 134 of 198 Monday, November 23, 2015
![Page 135: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/135.jpg)
back like never before. Far East compet- itors, such as Taiwan and South Korea, are exploiting their lower costs, and U. S. and European companies are achieving efficiency gains and improve- ments in quality.
The high yen--endaka in Japanese- is slamming the nation's exporters two ways. Foreign competitors with costs d e nominated in dollars or French francs have more room to undercut Japanese companies on prices, and a dollar's worth of sales is worth less in yen. Mea- sured in dollars, Sony's U. S. sales rose 24% last year. Measured in yen, they were down 11%. "The falling dollar has produced a nearly 50% tax on us," com- plains Morita.
Overall, the numbers tell a disappoint- ing story. Worldwide sales slipped ?%, to $82 billion, in the fiscal year that ended last October, while earnings from opera- tions fell a stunning 75%. Earnings de- clined another 56% for the five months ended in March from a year earlier. Archrival Matsushita Electric Industrial Co., by contrast, endured a more man- ageable 44% drop in operating earnings last year.
For Sony, endaka is like a drought that follows a plague of locusts. The challenges facing Morita and his hand- picked president, former opera singer Norio Ohga, have become even more daunting than they already were. BETA ~ O C K . Competition m consumer electronics is brutal. After coming up with such hits as W i n TVS and Wallanan tape players, Sony watched the hottest market of the 1980s,pass it by. The company dung to its Betamax videorecorder fmmaturhile +hp the world switched to VAS. That s s was costly, and the experience helped embolden competitors. They no longer wait to see whether Sony's innovative products suceeed. Rivals that took about two years to come up with their own U. S. versions of the Walkman now r e spond to new Sony products in months. And the rising quality of competitors' products has narrowed the advantage that once permitted the company to build a successful advertising campaign around the simple phrase: "It's a Sony." To make matters worse, some of the most troublesome competitors are in South Korea or other Asian countries where costs are lower.
Sony has fought back. Shortly after becoming president in 1982, Ohga set a goal of reducing Sony's dependence on consumer electrbnics by getting 50% of sales from nonconsumer products by 1990, compared with 15% a t the time. Ohga has also served notice that execu- tives a t Sony factories must cut manu- facturing costs beyond the 10% annual reductions of recent years. 'We need quantum leaps in cost reduction," he
COVER STORY
... A STROW6 YEN ERODES EARNINGS.. . ' i i
... AND DlVERSlFlCATlOH IS OFF SCHEDULE
35
- - - - 10- - - - - -
NONCONSUMER PRODUCTS - '- AS PERCENT OF TOTAL SALES 0
'82 '83 '84 '85 '86
g 3 g d
$ 2 8 e $ k
3 -1
J
BUSINESS WEEKIJUNE 1,1987 6S
L J DATA. M l l Y CQI.
says. To reduce its vulnerability to fluc- tuations in the yen and to become more responsive to its customers, Sony is ex- panding its substantial manufacturing operations overseas. And Sony clings al- most defiantly to one. of the company's most distinguishing characteristics: a re- search and development budget that amounts to about Wo of sales. Rival Mat- susfiita spends only 4%.
Even for a company as innovative as Sony, the changes are not coming easily. "Our people are working very hard," says Morita. And all 'that hard work is carrying Sony into some unfamiliar ter- ritory, where the risk of missteps is
high. The company's push into noncon- sumer areas, such as computers and im- age processing, has been such tough go- ing that Sony will not meet its timetable for diversification.
Other changes Could be even more traumatic. In some areas, Sony is aban- doning its time-honored, go-it-alone phi- losophy. I t is sharing its technology with other companies, for example, in an ef- fort to create industry standards for new products and to avoid another Beta- max. Sony is also becoming more of a street fighter. I t is pushing harder for larger shares of the markets for prod- ucts, even if it means paring profit mar-
ADVANCED MEDIA GROUP Page 13 of 76 05.03.2007
Advanced Media Group Page 79 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 135 of 198 Monday, November 23, 2015
![Page 136: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/136.jpg)
the company has avoided any serious damage from the cross-fire between To- kyo and Washington. Its semiconductors
pany, which has 701 employees, is one among a host of small regional s& chief are legion. Even though Congress brewers in Japan. Morita & Co. also in April rejected a oneyear ban on the makes miso, a fermented soybean ultrahigh-fidelity digital tape recorders paste used in soups and sauces, and recently introduced in Japan, legislators shogu, or soy sauce. Under the man- are likely to accomplish the same objec- agement of Kyueaemon Morita, the tive by other means. Congress is daw- business provided a comfortable life dling over legislation to require that the for his son Akio and three other chil- new products be equipped with devices dren in Nagoya, an industrial city 224 that prevent them from duplicating mi southwest of Tokyo. tapes or records, a provision sought by
As the eldest son, Akio was expected the recording industry. Richard L. to take over Morita & Co. Instead, af- Sharp, president of Circuit City Stores ter World War 11, Morita, then 25, Inc., isn't expecting digital tape ma- threw in his lot with business novices chines to be in his stores for a t least a Masaru Ibuka and Tamon Maeda to year, as Sony and other manufacturers start Tokyo Tsushin Kogyo, or Tokyo await a clear reading on the legislation. Telecommunications Engineering Co. Despite Sony's woes, Morita is as ea- Unable to get a bank loan for their ger and enthusiastic as ever. He man- struggling company, the trio turned to ages to sound upbeat about both the Akio's father, who repeatedly provided company's functional-looking, high-per- money through Morita & Co. in return formance Profeel Pro TV, which is sell- for stoek in the new venture. ing well, and the 8mm handheld video AT worn r e ~ o ~ a ~ T K evolved into camera, which is struggling. "This year Sony. And Morita & Co., with Akio's we will recover our profits, and next brother Kuzuaki a t the helm, has seen year will be a much better year," he some modest transformations of its says. Most analysts agree that Sony has
a t least halted the slide that has
COVER STORY
ADVANCED MEDIA GROUP Page 14 of 76 05.03.2007
Advanced Media Group Page 80 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 136 of 198 Monday, November 23, 2015
![Page 137: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/137.jpg)
- -- - -
ers, and by the time he left for Berlin to study voice, Morita signed him on as a consultant. After rebuffing several en- treaties by Morita to forsake his opera career for a full-time position at Sony, Ohga finally relented in 1959. Before b e ing named president, however, he served a 23-year apprenticeship that included running Sony's tape recorder division and a record company joint venture with CBS Inc. ow THE STUMP. Ohga's growing author- ity allows Morita more freedom for the ambassadorial role he loves so much. He spends about a third of his time a t Sony these days. The rest is devoted to trips overseas for such things as speechmak- ing or promoting his book, Made in Ja- pan, and to his ceremonial functions in Japan. Last year he became a vice-chair- man of Keidanren, the Japacese federa- tion of economic organizations.
For all his outside activities, Morita still makes sure he gets involved in the crucial decisions a t Sony. When it came time to price the portable compact disk player, for example, Morita decreed that it be priced a t less than 50,000 yen, about $200 a t the time. Even though the player cost more than that to make then, Morita correctly anticipated that the low price eventually would generate enough sales to provide the volume production that would trigger economies of scale-- and profits. The episode shows how Sony is now pursuing market share more diligently. I t is also an example of how Sony is responding to its experience with Betamax, the world's first home videorecorder. This high-profile product laid bare the company's strengths and its weaknesses.
As conceived, Betamax was a classic- iflustration of Sony's founding philoso- phy of looking for new markets where bigger, wellestablished companies were not a threat. The company correctly foresaw the immense latent demand for a machine that could make and play back home videotapes. But then it ceded the market to others by refusing to yield when the VHS format, -first developed by Victor Co. of Japan, provided longer r e cording times and gradually became the industry standard. Sony still insists that its Beta recorders provide a superior pic- ture. But a shrinking number of custom- ers-currently about 5% of all buyers- are buying Beta. MlDuFe CRISIS? Some analysts think Be- tamax goes a long way toward explain- ing the new directions a t Sony. "The Beta experience was so searing, so threatening, that it forced a major revi- sion in the way the company positions itself," says James C. Abegglen, a To- kyo-based management consultant. One example: Sony has relaxed its tradition of sticking to the expensive, high-profit end of the market by coming out with a
COVER STORY BUSINESS WEEKfJUNE 1,198797 ADVANCED MEDIA GROUP Page 15 of 76 05.03.2007
Advanced Media Group Page 81 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 137 of 198 Monday, November 23, 2015
![Page 138: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/138.jpg)
ing," says Neil Vander Dussen, presi- dent of Sony Corp. of America.
The efforts in the U. S. and around the world are producing some pieces of Sony's vision of the future. Sony was the first Japanese company with a pow- erful 32-bit desktop computer, which is the heart of its engineering workstation. It has quickly become a major producer of full-feature telephones in Japan. Sony also has taken the lead with the 3%-in. floppy disks and drives that are bidding to replace 5%-in. disks as standard equipment on computers.
Perhaps the most impressive marriage of video with the computer is what Sony calls interactive video. Sterling Drug Inc.'s Winthrop Pharmaceuticals unit uses a van with a customcrafted version to provide simulated demonstrations of how its products work. The system lets a doctor "treat" a patient with heart failure. The doctor sees his patient going to the emergency room, while the sys- tem provides the patient's case history
one of the reasons and vital signs. The patient's recovery depends on the doctor's response to on- screen questions and choices.
sales, executives now concede their time
ers of the disks themselves.
sharing technology and 2 P
e E
.8 BVSlNESS WEEKIJUNE 1,1987 COVER STORY
ADVANCED MEDIA GROUP Page 16 of 76 05.03.2007
Advanced Media Group Page 82 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 138 of 198 Monday, November 23, 2015
![Page 139: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/139.jpg)
Such a move would send a strong sig- nal that Sony has reached a new, more mature phase of development after rid- ing the crest of Japan's postwar econom- ic miracle. In essence, Sony's tradition of searching for gaps is another way of seeking market niches-a classic ap- proach for young companies. To keep growing, bigger companies must also learn to defend their existing markets while broadening their product line. Mastering new skills is never easy. But Morita, now an inveterate skier, didn't even try the slopes until he was 60. There's no reason Sony can't accomplish a similar feat in the business world.
By Larry Armstrong in Tokyo, with Christopher Power and G. David Wallace in New York
a strong yen. Even though having large overseas sales makes Sony more vulner- able than most Japanese industrials, it is already among the most international of companies. Foreigners own 23% of its stock, which is traded on 23 exchanges around the world. Sony also moved early and fast into local manufacturing. It makes TV sets in Bridgend, Wales, as well as in San Diego. It makes compact disks in Terre Haute, Ind., and in Salz- burg, Austria. All told, 20% of Sony's manufacturing is overseas. I t aims to increase that to 35% by 1990. Such glob- alization will help Sony earn its revenues and pay its bills in the same currency, rather than paying workers in yen and logging sales in a depreciating dollar. While the yen was appreciating 50%
against the dollar since September, 1985, Sony was able to raise prices only about 15% in the U. S.
Moving plants overseas is only the first step. The more difficult task will be to integrate planning and research and design internationally, too. But if an in- ternational staff is any measure, Sony is well along in the integration process. Of 7,000 employees in the U. S., for exam- ple, only 150 are Japanese. Sony, virtual- ly alone among Japanese companies, has stuck to a policy of giving the top job in its foreign operations to a local national. Before long, it may become the first ma- jor Japanese company to name a for- eigner as a director. A leading candidate is Jack Schmuckli, the head of Sony's European operations.
1 I I 11 # z
O ' E R STORY BUSINESS WEEKIJUNE 1,1987 68
I
E 5
lion of the 27 million Walkrnans it has made, prices run from a plain-vanilla , playback-only model for $32 to a souped-up $449.95 version that boasts tapedeckquality sound and records as well as plays.
Sony has used its image as a technol- ogy leader to gain a hammerlock on the lucrative premium end of the mar- ket. Walkman is the only portable ste reo offered by the tony L. L. Bean mt- alog. Emphasizing that it is "made by Sony in Japan, like 'Mercedes Benz, made in Germany"' gives Walkman "intangible added value," says Ohsone, now audio group director. punno FOR KEEPS. All Walkman products are manufactured in Japan. And despite the soaring yen, Walkman production is the exception to Sony's strategy to move more production overseas. Even though the soaring yen squeezed profits, Sony says it still made money on the $432 million worth of Waikmans it sold last year. One rea- son: a decision four years ago to create a low-price model specifically for the U. S. That forced Sony to automate production drastically and design a new model that cut more than 90% off production costs partly by integrating the playing mechanism onto the printi ed circuit board. The basic $32 Walk- man has become Sony's bestiselling model in the U. S.
Analysts think Walkman's go-go gears are coming to an end. But Sony disagrees. "Of the 4 billion people in the world, we estimate we could reach 600 million," says Ohsone. That may be an overstatement But then, as long as Sony keeps gripding out new versions, there seems to be no shortage of peo- ple eager to tune in.
By Amy B m in Tokyo
OHSOWE: EVERYTHING FROM A $32 BOX tO A
0 f all the problems besetting Sony, the two most frustrating are how to deal with copycat
competitors and how to mute the im- p a d of the rising yen on manufadur ing costs. But Sony has shown it can rise to the challenge. Its experience with the Walkman is proof of that
After Walkman's debut in July, 1979, Sony was not about to bask in the new product's almost instant success. With- in months, Sony audio engineer Kozo Ohsone was heading a team trying to come up with a better Walkman. Oh- sone carved a block of wood that was 25% smaller than the okiginal design and gave it to his engineers as a model. The engineers grumbled, but they buckled down. By February, 1981, Sony was shipping thousands of Walk- mans that were smaller, sounded betr ter, and had nearly 50% fewer parts than Walkman I.
$450 RECORDER WlIM T- SOUND
Sony continues to dominate the $1.3 billion buslness with a 30% share of personal tape players sold worldwide. The reason: "It has been more inven- tive than the others," says stock ana- lyst Alan BeU of Salomon Brothers Asia Ltd. Walkman firsts include Dolby noise reduction in 1982 and a rechargeable battery in 1986.
Sony's inventiveness shows in more than technology. To keep Walkman fresh and to make it appealing to more customers, Sony churns out new mod- els to suit virtually every taste and wallet. So far it has introduced about 100. Headed for the beach? Take the solar-powered, waterproof Walkman. Tennis, anyone? Here's an ultralight radio-only model that attaches to a sweatband. Want concertihall sound? Slip on the oversize headphones of a deluxe Boodo Khan. In the U. S., where Sony has sold more than 13 mil-
ADVANCED MEDIA GROUP Page 17 of 76 05.03.2007
Advanced Media Group Page 83 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 139 of 198 Monday, November 23, 2015
![Page 140: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/140.jpg)
STATISTICS FOR SONY DEAL
1. Power Station
I. Bon Jovi - Tony's creation 1% - $1 Million in 1987 in Revenues
a. Format b. Mixing
Sold 9 million albums in 6 months
2. Power Station - Hiah Tech Award - Last 4 Years
Best in World By Peers!
3. 4 - 5 Grammys in 1987 Recorded there Steve Winwood
Others: Jagger,, B. Joel, Springsteen, Diana Ross, Madonna, J. Lennon, on and on.
4. Tony - Multi Track Recording
Defied Theory Designed Sound - Voyeger Produced Star Wars Album - Mixed
5. French Lick - MTV may sign Free Promotion
II. Technology
1. First Video, film, tv in digital. All first for full entertainment
2. Kodak and Mitsubish - Not till end of Decade
3. Dolby - Sony/PSDMS - $10,000 per license to any tv, film, video, etc.
4. Only mix board that will mix albums/video's
Sell to all recording and film studios $300,000 - $500,000 per
console.
5. Sony spends 9% of gross revenue on R & D
9% of billions 2 = $180,000,000
6. Put Sony 5 years ahead of strategic plan
Disc players - Only 23% of consumers currently own a disc player.
First time to hear for how many?
ADVANCED MEDIA GROUP Page 18 of 76 05.03.2007
Advanced Media Group Page 84 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 140 of 198 Monday, November 23, 2015
![Page 141: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/141.jpg)
Filmpideo
1. 23,000 theaters to sell system
2. First will sell movie and video
Add French Lick
3. Top Gun - sold 9 million @ $30.00 - $60.00 per video
$270,000,000 +
4. Horror International Fihn $20 - $60,000,000
Pay N, Cable, N - ?
IV. Commercial - 180 Sec Commentary
Sony - $4,000,000 - $8,000,000 for commercial
Visa Demonstration $2 Million - $6 Million
Pepsi Paid $8,000,000 60 Second in front of "Top Gun" video.
V. Merchandise - Private Label
Power Station Beach Line
In movie, free by original designer and owner - "Hana Ten" swim wear
Power Station Electronics Line/Sony
Best recording in world - is it good?
Beach Accessories
Promotion in movie, video, N
Sell all of above
Video - Mail Order, Stores
VI. Sony
I. Needs help
a. Low profits b. Beta Bust
2. Best name electronics Manufacture
ADVANCED MEDIA GROUP Page 19 of 76 05.03.2007
Advanced Media Group Page 85 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 141 of 198 Monday, November 23, 2015
![Page 142: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/142.jpg)
3. Film and video distribution (new)
4. Willing to work together
a. Share tech
b. Joint venture
c. Horizontal distribution
5. Horror Elements and PIS name already international
Deal would involve:
I. Retail electronics division
2. Professional electronic
3. Film distribution
4. Video distribution
Star Wars - $2 Billion in 10 Years from all revenues
30% - 50% = $600,000,000
Tony said 50/50
All costs - $4 Million
New - Film studio?/with Sony
Deal worth 100,000,000 Now??
Would Kodak or Mitsubish like deal?
Will Sony let this deal go to competition?
No - Beta
PERFECT ENDING: Profits and Respect
ereation - 411 1/87 ' 11 :00 - 1:00 a.m.
Stan 98%
1% Scott - Call Ron Gell
Research Sony
ADVANCED MEDIA GROUP Page 20 of 76 05.03.2007
Advanced Media Group Page 86 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 142 of 198 Monday, November 23, 2015
![Page 143: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/143.jpg)
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
ADVANCED MEDIA GROUP Page 21 of 76 05.03.2007
Advanced Media Group Page 87 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 143 of 198 Monday, November 23, 2015
![Page 144: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/144.jpg)
Technology
Beyond the Bijou SOPHISTICATED FILM TECHNOLOGIES
AND FUTURISTIC FORMATS ARE REDEFINING THE NATURE OF COHTEMPORARY MOVIE THEATERS.
BY JIM PETTIGREW JR.
ADVANCED MEDIA GROUP Page 22 of 76 05.03.2007
Advanced Media Group Page 88 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 144 of 198 Monday, November 23, 2015
![Page 145: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/145.jpg)
I n a world that at times seems defined by incompatibility, there is one inter-
est which most of us have in common - a passion for the movies. And this love of the cinematic fantasy world shows no signs of dissipating. Different trends may appear, such as the VCR explosion, but upon examining the world of con- temporary cinema, one fact becomes readily apparent - the movies are not going away. Neither, according to indus- try leaders, are those esteemed hideouts of escapism - the theaters.
Though movie theaters are here to stay, there is a great deal of debate cur- rently going on inside the showcase, or exhibition end, of the film world. Some of it concerns topics such as changing image, and a considerable amount of the debate relates directly to technology.
The path of events that set the stage for this situation contains a number of key elements.
Beginning in the early 1970s. the movie-theater industry in the U.S. slowly slipped into what may be called a technical rut. There were tremendous ad- vances in home-audio technology, but the exhibition business did not really keep up.
There was also a trend toward "multi- plex" cinema facilities - not an inher- ently weak mpketing idea - but their early manifestation didn't prove tenibly successful. The first multicinemas were cramped, had very small screens, and ambient sound many times bled over from next door.
In the spring of 1977, George Lucas produced a film that would have a revo- lutionary impact on the exhibition indus- . -
try. It was released to theaters carefully picked for certain technical standards. Besides the well-known special effects and cinematography, Star Wars boasted a soundtrack in Dolbya stereo. It was played over an advanced audio system filled with new designs, including a "subwoofer" that
The film also brought fresh attention to the large-frame 70mm format. This expensive but vastly superior process had been used in earlier landmark movies (Lawrence of Arabia, Patron) but had fallen out of favor in Hollywood.
With a new audio standard established by the Lucas blockbuster, the cinema in- dustry moved into the 1980s - and a whole, new set of business realities,
coupled with a feverishly expanding foreground of technological develop ments.
Clearly, the industry had to adapt and change. The situation was brought to a head by the growth of home video, but that trend was only a part of the whole arena. Faced with this challenge, the the- ater industry began what is now a recog- nizable set of changes to "remainstream" itself. (The latest studies, incidentally, show a kind of reverse effect from the home-movie phenomenon; it's actually sending patrons back to theaters, seeking favorite titles in full-blown film environ- ments.)
Fromthtprojtcbknroomtothcbox oflke, technology is IntWating the d m house. Developed by Douglas Tnrmbull, opposite, Showscan@, equipped with a c o m w e d motion control system and 70mm fllm, amazed audiences at Expos '85 and '86. Above, computerized ticketing and central-data systems, like thou dewdoped by Pacer Coqxxaion, are also coming into the pkture.
SKY May 1987 23
ADVANCED MEDIA GROUP Page 23 of 76 05.03.2007
Advanced Media Group Page 89 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 145 of 198 Monday, November 23, 2015
![Page 146: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/146.jpg)
Zl33 Oak Industrial Dr. N.E. Grand Rapids, MI 49505 Ton-Free 1-800-253-0882
I'd k e to know more about Tenyberry award jewelry programs. Our company logo or my business card is attached. Please send free sample artwork and a no-obligation quote on an: Award Ring Program EmblemJewelry Program
17 Please call - I have some questions.
Name
Title
Address
CitylStatelZip
Telephone Number
24 SKY May 1987
ALP TWX-INSTALLED SYSTEMS UNDERGO RIGID GERIIFICRPC6N APCD ARE THEN TESTED EVERY SIX WBHTHS ao ENSURE QUALITY ADHERENCE.
Accompanied by an advanced audio Today, the theater repositioning proc- design from THX Sound Systems, a ess takes a number of poses, including
division of Lucasfilm Ltd., an entire film better s o u n k _sensible design, rests on a platter and feeds through a -cleaner halls. a y m overall push to
projector without the projectionist having reenergize the "experience" vital to to use two ~rdectors. moviegoing. "Theater companies are
building at record numbers, by the way," notes Glenn Berggren, vice president of Optical ~adiationCor~oratidn of Azusa, California, one of the world's largest suppliers of theater equipment. "They want to make them better, not only as op- erations are concerned - breakdowns, etc. -they'd also like to have an effective theater that lets the public know they're modem, better than the ones built five, ten years ago."
Theaters are now utilizing com- puterized ticketing and central-data sys- tems, such as those developed by Pacer Corporation of Bothell, Washington. The integrated Pacer system instantane- ously gathers all sales data for the cash- intensive business, compiles it, and the information is uploaded nightly by auto- matic modem to central offices. "Our
ADVANCED MEDIA GROUP Page 24 of 76 05.03.2007
Advanced Media Group Page 90 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 146 of 198 Monday, November 23, 2015
![Page 147: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/147.jpg)
system opens up the possibilities of cred- it-rard and off-site ticket purchasing,"
s Keith Myers, Pacer's marketing v president. "This may reach a whole different segment of affluent consumers - r-d even influence the kind of movies tt are made. "
nis trend is well characterized by numerous showcases across the country. @ example is the General Cinema c, plex inside Merchants Walk, a north 4-.mta mall. There, Cinema One fea- tures an advanced audio design from T < Sound Systems, a division of L asfilm Ltd. in San Rafael, Califor- nla. "Patrons don't really articulate it," exvlains theater manager Steve Crisp, s' ~ i n g off the loudspeaker system and + lrily insulated walls, "but they know wnat they want in a film experience torlay, and sound is verv i-" .
6 e healthy sign that experts point to i: le influence exerted by firms such as THX Sound Systems and the Theatre A1;:nment Program (TAP), both compo- 7 ts of Lucasfilm Ltd. All THX-in- s led systems undergo rigid certifica- tion and are then tested every six months tc nsure quality adherence. TAP vigor- a ly encourages high standards and d rogue between suppliers and theaters.
"We are targeting theater managers a ' personnel with seminaft," says Kim- t: ly Strub, marketing director of the 1 ..:ater Operations division at Lucas- film. 'These will help them answer ques- t IS about film presentation - sound- t~ :ks, how they're made. Lots of times pople will have questions about how films are made, and the only people that t' y have to turn to are the theater per- s ~nel. We're trying to make sure they are informed and can answer public ollestions - and also realize how impor- t t their roles are in the film chain."
Zurrently, amid the film exhibitors' concerted push to modernize, there is an aP-elerating debate in both the equip r nt and showcase fields about what t hnical form the near future will take. The issues must be set in context within
-rowing array of spectacular new tech- 1 ogy, film formats, and even new ap- I laches to the filmic experience.
Two of the central topics now being (' Sated with increasing fervor in the in-
SKY May 1987 25 ADVANCED MEDIA GROUP Page 25 of 76 05.03.2007
Advanced Media Group Page 91 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 147 of 198 Monday, November 23, 2015
![Page 148: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/148.jpg)
ONE SYSTEM U'PELIZES 7OMM FILM, A VERY LARGE
SCREEN, AH EXTREMELY FAST FILM SPEED AT 60
FRAMES PER SECOFJD, AND DIGITAL SOUND.
dustry include film speed, expressed in frames-per-second (fps) and film format (frame size, coupled with larger screens). A third topic is the increasing impact of high-grade video and its even- tual manifestation - high-definition tele- vision (HDTV) - and how the two indus- tries will affect each other.
For decades, the standard film speed in the theater industry has been 24 fps. At this srxed. a relativelv low ~roiection- light ievel' must be iaintainkd iten-16 foot-candles) to prevent an annoying sensation called "flicker." There are now several proponents who are urging that film speeds be raised, so that higher light levels may be possible. Faster fps rates, they point out. also make for richer im- agery. better color, and heightened spe-
cial-effects possibilities - as well as de- creasing industry headaches such as "comet-tailing" and blurring.
The 35mm filrn format has also been the industry standard for decades. Numerous industry leaders are quick to point out its obvious obsolescence. The 70mm filrn size, they note, offers much more than a 100-percent improvement in cinematographic possibilities. "Most people, including large film manufactur- ers, do not really understand how much detailed information can be put on 70mm film," asserts Optical Radiation's Berg- gren, "and shown back on the screen."
A central point. in an overall sense, that brings these debates into focus is that there is an already-existing arsenal of nevlt cinema systems. Each camp points inarguably to the future, and each system is now offering spectacular new cinema- tic exrxriences.
s o h e of the new formats first debuted in what the industry calls "special- venue" theaters - noncommercial, muse- um, and other educational halls. Cur- rently the granddaddy of these is the IMAX@/OMNIMAX@ system, now amazing audiences at Washington, D.C.'s Smithsonian, Boston's Mugar OMNI
Theater at the Museum of Science, Chicago's OMNIMAX Theater (located in the Henry Crown Space Center at the Museum of Science and Industry), the OMNI Theater at the Fort W o ~ h Muse- um of Science and History, and the Sci- ence Museum of Minnesota in St. Paul - among others. Several of these "space"
I I 26 SKY May 1987 ADVANCED MEDIA GROUP Page 26 of 76 05.03.2007
Advanced Media Group Page 92 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 148 of 198 Monday, November 23, 2015
![Page 149: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/149.jpg)
leaters were designed by the architec- ~ r a l firm of Hammel-Green and Ab-
rahamson of Minneapolis, which esti- ~ated that 20 million people attended IMNIMAX theaters around the world in 985.
The heart of the IMAX system is a nique projection approach; the large-
format images are projected through a fish-eye lens onto a 76-foot dome, which washes the screen with an enormous pic- ture. The screen is tilted toward the audi- ence at a 30-degree angle, which creates a stunning wraparound effect.
Showscan@ is another radically new film system with breathtaking sensory experiences. Developed by special-ef- fects wizard Douglas Trumbull (Srar Wars, Star Trek; director of Silent Run- ning and Brainstorm) Showscan has amazed audiences at Expos '85 and '86; the Vancouver theater in Canada re- mained open after the fair, and 50,000 people saw the Showscan presentation in January of this year. The corporation is currently opening special-venue theaters in Los Angeles and several other cities in the U. S., Australia, and New Zealand.
Showscan utilizes 70mm film, a very large screen. an extremely fast film s g e d at 60 fbs, and digital sound. While developing the process, Tmmbull ran extensive tests at various film speeds, utilizing participants at California uni- versities. For several years in the 1970s, Tmmbull was also head of Future Gen- eral, an experimental department at Paramount Studios.
Atlanta's independent filmmaker, VanDerKloot Film and Television, extensively utilizes computers and high-grade video in current production work.
Even though Showscan is currently confined to special-venue theaters, the corporation clearly has plans to move into the box-office market. "We don't have an announcement yet, but we're very close," says marketing director Cindy Porter. "We're confident that when an announcement is made, a fea- ture film will be out within two years."
Currently, the leader in the race to bring stunning new technology into the first-mn film market is FuturVision 3*, a division of FuturCinema Inc. in New York. The brainchild of former Kodak executive Eric Knutsen, this proc- ess utilizes large-screen (wall-to-wall, floor-to-ceiling) 70mm, a sophisticated digital audio system, and runs at 30 fps.
For several months, Knutsen and FuturVision have had ties with Loews, a
HOW TO PURCHASE ONE OF EUROPE'S
A thousand years of myth and his- tory await you with$ a day's drive from Stuttgart-in any one of the most technologically advanced automobiles ever to come from Mercedes-Benz. Choose from among fourteen models.* And embark on the driving odyssey of your life. Traveling the Continent at your leisure, saving money en route-on trains, taxis, and rental car costs. See your authorized dealer. Then see the sights of Europe-and bring one of them home. Send coupon at right for our free color brochure.
'subject to availability
Send coupon to: Name a I Mercedes-Benzof I ~ o r t h ~merica. ~nc. , A d k
I Marketing Communications city ' I Division, lne Mercedes Drive, Zip
8 1987 Mercedes-Benz of N A , Inc.. Montvale. NJ DSMY 87
SKY May 1987 27 ADVANCED MEDIA GROUP Page 27 of 76 05.03.2007
Advanced Media Group Page 93 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 149 of 198 Monday, November 23, 2015
![Page 150: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/150.jpg)
Architectural Antique Auction
Saturday & Sunday Starts 10:00 a.m.
Rare Uk Size Grecian Bronze
Over 1200 Unique I t e m s will be sold
Several of the best handcarved panelled roomspailable Bronze walls & formal enbyways Carved wood embellishments Chandeliers Magnificent mantels Saloon & home back bars Marble statuary
As Always - No Minimum - No R e s e n e Complimentary M e t and Drinks
For lrnrnedlate 1nformatIon or Brochure
(Reader Survey Cards Delay Process) call or write
5070 Peachtree Industrial Blvd. Atlanta, aA 30341 (404) 457-1905
28 SKY May 1987
a BIG SELLING PQIHT TO FIRST-RUN THEATERS IS &OMPARATIWE EASE OF COMPATIBILITY AND COST-EFFECPIVEPBESS.
The lW@ system is a unique projection cally bypasses house audio and goes to approach where large format images are our processing equipment. So, there's projected t h ~ a a fish* kns 0- virtually no set-up time." 1 a 76-foot dome.
major theater chain (his system is now being showcased at Loews Tower East, a prestigious Manhattan screening room). At presstime, Knutsen was pre- paring to announce an agreement with a second major chain.
Besides its audiolvisual sorcery, one of FuturVision's big selling points to first-run theaters is comparative ease of compatibility and cost-effectiveness. Working with Optical Radiation Corp., Knutsen has developed his system so that it can be integrated into existing theater hardware - and still offer the dazzling filmic experiences that all aggressive chains are now scrutinizing.
One aspect of FuturVision is digital audio, said to be comparable to CD q al- ity (actual CDImovie presentations
-d audio is taken from the
I +still in the future). With this ' film and fed to a Knutsendesigned proc- essor, which then sends audio signals to an upgraded house system.
"Now," Knutsen says, "the projec- tionist can walk into the booth and flip two switches. One automatically changes screen brightness from low level to a much higher level for our film, and at the same time changes film speed from 24 to 30. The second switch automati-
until recently, the film-production community and the exhibitorltheater equipment industries have viewed each other as barely tolerable neighbors, forced to get along, but with little mean- ingful dialogue between the two camps. Now, though, in the face of this starburst of new technology, the two industries are working together, insiders point out, to achieve the common goal of a truly realistic cinematic experience, and the subsequent fiscal rewards.
Bill VanDerKloot, owner of VanDer- Kloot Film and Television in Atlanta, one of the premier independent filmmak- ers in the south, has a keen eye on these and other developments. His firm exten- sively utilizes computers and high-grade video in current production work. "Today," he points out, "stereo sound- tracks are mandatory, even for low- budget films, not the case just ten years ago. People have become very sophisti- cated in their technical tastes for film.
"I am just incredibly excited about what the future has to offer," VanDer- Kloot concludes. "The more like reality we can make the dreams that we create on film, the more fascinating and fantas- tic films will be."
Contributing editor Jim Pettigrew Jr. is based in Atlanta, Georgia. Q
ADVANCED MEDIA GROUP Page 28 of 76 05.03.2007
Advanced Media Group Page 94 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 150 of 198 Monday, November 23, 2015
![Page 151: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/151.jpg)
Management Group, LTD Oregon Pike Lancaster, PA 17601 717-569-5555
w m w m p w
Table O f Contents
Section I
Section I1
Section I11
Section IV
~inancial Management Group
The Project
Distribution and Structure
ADVANCED MEDIA GROUP Page 29 of 76 05.03.2007
Advanced Media Group Page 95 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 151 of 198 Monday, November 23, 2015
![Page 152: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/152.jpg)
Power Station w a s formed in 1977, in partnership w i t h Tony Bongiovi and Bob W a l t e r s . Pcrwer Station, within a short period of time established i tself as the premiere reconhg faci l i ty i n the world. The studios success t o a larye degree is due to Bongiovils tmmerdous creative talents in the fields of studio design, prduction and en-t. The abi l i ty t o anticipate what the public a t larye wants to hear and to create a format that will p&ce a highly marketable product.
Bongiwil s creative genius became most evident with his recent success producing the band *IBon Joviu, A f 3 x years of work dweloping their talent and structuring the format for their music, ItE3on Jwit* rapidly became one of top bands in the world.
Bongiwils most recent project is a bard called I1French LiW, which he brought into the studio approximately two years ago. You may have heard French Lick's music in Ron Hawardls p-ction of Gung-Ho. French Lick's music and talent have been developed alo~lg the same format as "Ban Joviu and have recmtly been s h e to the major recom labels. Contracts should be finalized w i t h Quantum Medium in a few weeks. Quantum M e d i u m is a division of MCA, owned by the same people tha t own
-\ EWV. Fren& Lick is wholly owned by Power Station, along with the i r f i r s t \.- * album, which gives Bongiwi the abi l i ty to use any and all the songs from
the album in the mwie.
By placing the bard in the movie and having the music score written by the band, we are able t o take advantage of marbting potential mnnally not available ta other prductions. The music video for the band w i l l be shot a t thed- time as the mavie an3 w i l l primarily be scenes from the movie. 'Ihe release of the video w i l l be +.inwl to pramate the opening of the movie. ?he release of the songs off the first album w i l l also be coordinated to pramate the mwie. W fully urdershnd the marketing potential the band brings to the project, picture what gross receipts a t the box office would look like i f I*Bon JoviI1 were appearing in a movie this year (Any movie) . If F'rench Lick does one tenth as w e l l as Bon Jwi, this mwie is a -teed hit.
During Bongiwi ' s work on "S ta r W a r s 1 * , **Apocalypse Naw" and llGung-holl, he w a s able t o rclake many of the contacts necessary to form the extremely talented group of artists that are essential for a production t o be successful.
ADVANCED MEDIA GROUP Page 30 of 76 05.03.2007
Advanced Media Group Page 96 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 152 of 198 Monday, November 23, 2015
![Page 153: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/153.jpg)
peters: ~irector/Writer/Prducer has directed many programs such as t W a t t Houston", "Falcon
Cres t t t , tfGigney and Law, tWisfitsw, ~tBerrengersn, and tlRemington SteeleN t o name a few. The film Ehrbara dire&& that convinced Tony t o hire her for this pxduction w a s tWunmoids Frow The Deeptt. Humanoids was made i n 1978 for $ 980,000 ($ 20,000 d e r budget and four days ahead of schedule) and grossed aver $28 million in d-ic and foreign theatrical Sales. Tixis w a s during a period in time when the video market w a s in its early stages of d e v e l w t . A film released today that would gross $ 28 million in 1978 dollars has even greater potential for a much higher gross with the strong video market that is available naw. What impressed Tony the w i t h Baxbarats djrection of Humnoids w a s her abil i ty to bring a high degree of quality to a film on such a l i m i t e d W g e t .
Peter Hock: Stunt ~ ~ t o r / A c t o r / s & m h m Peter8 s d t s include films such as, Trading Placestt, gtStepford
Wives", 'To K i l l A Capw, "Ql& Bustersw, "FX', and a host of other Films, Broadway, -ids ard Telwision Shcm.
p, L There are many factors which contribute to a projects success. If you
w e r e t o take a mcs section of the movie h3ustry t o find which types of projects w e r e most likely to s u m , yau wauld find that movies in the two t o four million dollar range have much greater chances of success than movies in the t a t o fif teen million dollar range. The reasons for th i s are qui,. simple. A movie in the two t o four million dollar range is a high enough budget to pmduce a quality film h x t limiting the r i sk t o the investor since it needs less of the market share to p&ce a profit.
Horror mwies, frran the investors point of view are the safest type of movie to finance. H o r r o r mies have an almsst cultist fo1lmi.q. The type of audience that attenl homr mies rarely w a i t to see what the critics have t o say about the movie. mere is a fascination w i t h gore that this audience would rather see than have described t o them. The overseas market for movies of this genre are tremendous. In almost all cases the gross revenues fram the theatre, w i l l be greater overseas than in the damestic (US and Canada) market. ?his especially holds t rue for horror movies.
ADVANCED MEDIA GROUP Page 31 of 76 05.03.2007
Advanced Media Group Page 97 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 153 of 198 Monday, November 23, 2015
![Page 154: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/154.jpg)
Over the last few years, w e have hen seeing a trend for movies t o have a much heavier music score than in the past. The feelings that can be invoked in an audience from audio are sometimes as great or greater than the visual aspects of a film. W i t h Bongiovi's experience and past track record, we are assured of having one of the best quality sound tracks t o a movie ever Me. 'Ibis production could very well revolutionize the movie inctustry i n tha t this will be the first time that the sound track w i l l be total ly digitized fram the set to the theatre or home video. What this means is that the quality of the sound, which is typically extremely poor in a mvie theatre or hone video cassette, w i l l now be tremendously crisp. T h i s new m i e sourd will be similar t o the quality you would aqect froan a laser disc. Normally the costs involved t o produce a m i e wit31 this type of s a n d track would greatly increase the budget to a point where the project would have an increased element of risk. With Power Station, w h i c h W d y has in place state of the art equipnmt, some of w h i c h can be found in only one or two other studios in the world, this sourrd track can be produced for a fraction of the costs that another produckion ccanpany would have to pay. l h i s greatly reduces the r i sk t o the investor to be able t o prcduce state of the art audio at a fraction of the costs.
It is a very natural progression for a recording studio such as mer Station to evolve into an enterbbmmt cmplex w h i c h includes the production of films. Pcrwer Station currently has financing in place fo r a $ 3.5 million video mix studio t o be fsuilt next t o the recon3i.q studio. D i s - t r i l p t i o n companies are constantly looking for new sources of product to market. With Bongiovils track record in the entertairrment industry, any p&ct that mies the Bongiovi label should create a bidding silxntion w i t h the distributors.
Advanced plblic relations w o r k is currently being done t o set the s tage for negotiations with the distribution campanies. l l B i l l h a r d l t , 'VarieWt1, and "Box Officetq have W d y agreed t o do art icles on Bongiovi and the nmvie. On April 30, ABC w i l l be airing a radio talk show w i t h Boriyiari that w i l l air on 2300 stations to a total listening audience of over six million people. "Fame, Fortune, and Romance" have also agreed t o give network T V coverage.
ADVANCED MEDIA GROUP Page 32 of 76 05.03.2007
Advanced Media Group Page 98 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 154 of 198 Monday, November 23, 2015
![Page 155: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/155.jpg)
The home video market has rapidly been changing the potential mwie profits for the industry. A Nighbare On Elm Street w a s made for w e l l under two million dollars and has earned New Line Cinema more than $24 million a t the domestic box office. I n addition, af ter a short video release, this production has sold over 3 million cassettes. In the past videos w e r e sold only t o video'rental stores for approximately $70 apiece. Recently the price has been lmered t o expand the market t o the general public. The video rental stores won't disappear, but they may became more like record stores that also rent their albums. A l l of this translates into more profit potential for prcducer and investor.
It is an extremely rare opportunity t o be able to get in on the ground floor in an offshoot of an already well established entertainment company. Any investor willing to back this project w i l l have f i r s t right of refusal on any future projects. ?he pe.rcentages w i l l remain the same for a t least the first two projects.
ADVANCED MEDIA GROUP Page 33 of 76 05.03.2007
Advanced Media Group Page 99 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 155 of 198 Monday, November 23, 2015
![Page 156: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/156.jpg)
Independently prduced motion pictures are a better investment today than ever before.
1) Increased Markets: There is much wider distribution of motion pictures today than ever before (i.e. Pay Tv, Cable TV, videoassettes, satellite tmnsmissions, etc. )
2. 'Presale' contracts which bind the buyers (i.e. networks, pay Tv, foreign distributors, etc.) t o specific payments a t a future date, this insuring return of capital and, in sane cases, a profit before the film is released.
Investment structure:
The producer and investor form a limited partnership for the purposes of prottucing one or more motion pictures. The investor receives 100% of the net profits until remupent, after w h i c h the s p l i t is 50-50. 0 Profit participation of o ~ e s s (actors, director, writer, etc. ) canes out of the p&cerls end.
The pq3uce.r secures the services of a director, principal actors, and a w r i t e r .
Presale Deals:
The producer can negotiate presale (preproduction) arrangements with distributors, networks, pay TV, merchandisers, etc. Whereas such ar~angements can minimize the downside risk, they can also inhibit the eventual profitability of the film.
Risk Factors:
It is very difficult to determine exactly how much of a r isk one runs in financing a theatrical film. Adequate s ta t i s t ics are hpssible t o find. Shannat Services of Los Angeles a four-year-old study w h i c h revealed that 60% of all f b released make money. This study, however, did not include long range TV syndication (foreign and domestic) revenues, and w a s made before Pay TV and video cassettes became significant additional markets. Chemical Bank of New York
r reports that they have never lost mney on film financing. ' \.
-.
ADVANCED MEDIA GROUP Page 34 of 76 05.03.2007
Advanced Media Group Page 100 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 156 of 198 Monday, November 23, 2015
![Page 157: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/157.jpg)
Another r isk is the possibility that no distributor w i l l want t o release the picture. That is why some independent producers include a provision for distribution financing in their investment agreemmts. I f worse comes t o worst, producers can distribute the film themselves. (Notable examples are ''Billy Jacktt and ttBenj it'. )
There may be production catastrophes that w i l l delay or cancel pmduction o n e it is under Producers w i l l carry various forms of insuranoe (including completion bonds) t o a t least repay whatever funds have already been spent.
If a distribution amaqement has not already been made, the producer now secures such an arrangement. I f the picture is goad, it is possible to negotiate a much better deal than could have been done earlier. On the other hand, the producer could have truuble securing the kind of distribution commitment wanted. The main factors here are hcw much money the distributor is willing to c o m m i t to sell ing the picture, h m much influence the producer can have on the mrletiq ~ m p a i g n , and the distribution fee. Sanetimes smll distributors are able t o give more time and attention t o indeperdent pictures and offer better terms, but the producer may have to provi.de same - W o n expexes .
C u t of gmss domestic box office receipts, the exhibitor (retailer) usually subtracts his fixed costs and then receives 10%. Cut of the ranainjng 90% gmss film rentals received by the distributor (wholesaler), he usually recoups all or part of his costs plus a distribution fee of 20-35%, then passes the rest on t o the producer/hwestor. Terms of distribution deals vary considerably.
Ebx office reoeipts, however, only account for a part of the producer/investorls revenues. A s the enclosed figures show, the ancillary markets are a t least as significant as the daoestic theatre box office. T V syndication, for instance, can continue t o bring in revenues for the next twenty years.
Demand for P r d ~ c t :
TWayts supply comes nowhere near to mtching real demand. A t the present time, there are over 18,000 theatres in the United States . It can readily be seen that roughly 400 films produced and rated last year did not w i n t o m e e t their needs. Theatres are canpelled t o show any type of film they can obtain to keep their doors open.
ADVANCED MEDIA GROUP Page 35 of 76 05.03.2007
Advanced Media Group Page 101 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 157 of 198 Monday, November 23, 2015
![Page 158: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/158.jpg)
To date, independent producers are responsible for 72% of a l l films mde world-wide. The domestic figure is 62%. The independent producer has three primary options r- distribution. These include the sale of the film outright to a major national distributor, their merchandising of the film by the production company i t se l f , o r the use of smaller regional sub-distsibuto~~ who my promote the film in their respective geographical areas. Distribution of films often relies on a l l three methods t o one degree or another.
Another market, television, can consume nearly every film that has been, or is presently being produced. If each of the three networks would show only one film per night, they would need over 1,000 f i l m s per year. In ks Angeles area alone, there are nearly 10,000 f i l n ~ ~ aired each year in a ambination of local and network viewing time. Many f i l m s are shown time and time again because there are no new fibs to replace them.
Today, virtually every film of quality has residual value in television, either by outright sale or by t e n n licensing. Tke latter is preferable since it all= the production company to retain
'p of the negative. The t i m e lag between theatre release and ~ h a s d i m i n i ~ e d f r o m s e v ~ y e a r s t o a n a v e r a g e o f 1 8 m n t h s . Hwever, scnne major features such as ffThe Wizft have been sold to TV before completing a full year in theatrical release. The trend seems to be toward prchase of 'freshf films, and the outlets appear willing to pay the higher costs involved
I
Because of the great demand and the outrageously ccanpetitive att i tude that pemades the networks, handsame deals are being consummated before the production has been q l e t e d and then, by p-ement w i t h the producers, hold the film until it has completed its theatrical run.
ADVANCED MEDIA GROUP Page 36 of 76 05.03.2007
Advanced Media Group Page 102 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 158 of 198 Monday, November 23, 2015
![Page 159: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/159.jpg)
ADVANCED MEDIA GROUP Page 37 of 76 05.03.2007
Advanced Media Group Page 103 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 159 of 198 Monday, November 23, 2015
![Page 160: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/160.jpg)
Breakeven for Limited Parhers:
Based on gross revenues of $ 11,200,000 collected fm 1st and 2nd theatrical runs
1st run ticket costs of $ 6.00
2nd run ticket costs of $ 5.00
1st Run
50 people per shed x $ 6.00
$ 300.00 per shaw X 1000 houses
$ 300,000 X 14 days
A
2nd Run
50 pea~le per show X $ 5.00
$ 250.00 per shod X 2000 houses
$ 500,000 X 14 days
TotalIstm
Total 2nd Run
Total
= $ 300.00 G r o s s per show
= $ 300,000 G r o s s
= $ 4,200,000 G r o s s
= $ 250.00 G r o s s per show
= $ 500,000 G r o s s
= $ 7,000,000 G r o s s
ADVANCED MEDIA GROUP Page 38 of 76 05.03.2007
Advanced Media Group Page 104 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 160 of 198 Monday, November 23, 2015
![Page 161: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/161.jpg)
Forcast A
Total Box Off ice G r o s s - - - $ 11,200,000
Less 15% For Theatres ----- - $ 1,680,000
Motion Picture Profi ts -- $ 9,520,000
Less 30% Distribution Fee - $ 2,856,000
$ 6,664,000
L e s s : Investors Capital --------- $ 4,000.000
N e t Profi t ---- $ 2,664,000
Producers Split @ 50% -- $ 1,332,000
Invesbmt Company R e t u m $ 1,332,000
Less : General Partners Split @ 15% . $ 199,800
Investors Return $ 1,132,200 a
These are only proiections and are for informational ~uposes only. Any investment made, based solely on these proiections would be unadvisable as actual P e r f o m c e could varv meatly.
ADVANCED MEDIA GROUP Page 39 of 76 05.03.2007
Advanced Media Group Page 105 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 161 of 198 Monday, November 23, 2015
![Page 162: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/162.jpg)
Forecast B
Forecast B is based on a total box office gross of $ 28 million
A film that produces a theatrical gmss of $ 28 million can be expect& to gross at least that much from W , Cable and video markets. Depending on how distribution agreements are negotiated we can expect 50% to be net profits.
ADVANCED MEDIA GROUP Page 40 of 76 05.03.2007
Advanced Media Group Page 106 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 162 of 198 Monday, November 23, 2015
![Page 163: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/163.jpg)
Forecast B
Total Box O f f i c e Gross ----------- $ 28,000,000
B s 15% For Theatres - - - - - - - - I - - - - $ 4,200,000
Motion Picture Profi ts ----- $ 23,800,000
TpCC 30% Distribution Fee $ 7,140,000
$ 16,660,000
T.V., Cable and V i d e o N e t -------- $ 14,000,000
Total N e t -------- $ 25.340.000
TpCC : Investors Capital $ 4,000,000
N e t Profit ---------- $ 21,340,000
m c e x s Spl i t @ 50% $ lo., 670,000
Invesbent Companiest Return $ 10,670,000
L e s s :,General Partners Spl i t @ 15% $ 1,600,500
Investors Return $ 9,069,500
These are only proiections and are fo r informational txlnxses only. An invesmt made, based solely on these ~ m i e c t i o n s would be unadvisable as actual p e r f o m c e could v a r ~ sreatly.
ADVANCED MEDIA GROUP Page 41 of 76 05.03.2007
Advanced Media Group Page 107 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 163 of 198 Monday, November 23, 2015
![Page 164: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/164.jpg)
You Oughta Be In Pictures!
1 by Alan Talansky I
Success on a shoestring: Producer/director Spike Lee (center) turned video rental store, a paltry $ 175,000 procluctiun bltdget for "She's Gt~ttu Hum It' itklo u and the crowds $7 milliotr grcw.itr(: suprise hit. Co-stun-jolrn Cutrurlu Terndl (left) cord I Redmotrl Hick (n(:/rt, wiill i re utz tire w t PMto courtesy Forty k e s looking them overt and a Mule Filmworks. and you begin to
understand the di-
; ' j
l l mensions of growth.
When the motion picture industry Of course, just as not every piece of was first examined as an investment real estate is a great investment, every
T here's esplosive growth occur- fashioned profit: an ideal solution for ucts to be financed, and the second is ring in the motion picture indus- 3. post tax-reform era. the structuring of the deal. try, and growth should always be The key here is understsnding how 1, selecting the product, success is music to any investor's ears. "But nluch the industry has chsnged. The usually found in ~ 1 , ~ movies?" YOU say? It's time to put tyranny and fickleness of box-office larger the budget in a film, the grcatcr
aside your images of Tinschonrn and receipts is no longer. More people the fink. the $50 ,-,,illion "Heaven's Gate," and to take another around the world are viewing more pdted blockbusters and seek out. in- look at an industry with some new, films than ever before, but not neces- stead, the more modest undenakings sound investment potential. sarily in the theatres. Consider, for smaller, ambitious film produc-
, vehicle a few years ago, the expecta- movie isn't bound to turn a p-ofi;. 1 tion was that there was potential for But, there are two factors that have : I tax deferment. What was found, how- proven to be the critical difference in
ever, was a surprisingly rich source of creating a sound investment vehicle.
I income for investors from good, old- The first is the selection of the prod-
There's risk in any investment, of example, that there are only about 300 tion sources. A,, excellent exan,ple is course, even in real estate - the in- feature films made every year, of Island Picture-, a relatively in- vestment area on which many firms which about half could be considered dependent film production and dis- :I I originally buiit their reputation and -major.- NOW, compare that with the tribution company for which, last success. In real estate, it's a matter of number of movies a cable outlet, like how carefully you assess a variery of Home Box Office,
1 influential factors and how you struc- shows in a single ture the deal. Motion pictures are day. Eight? Then, much the same. You've got to look take a look at the
shelves of ytwr l t x ~ l
Not quite a blockbustec lslund's "Nobodv's Fool. " s t a r r i t ~ ~ Karannu Arquellr und Eric Roberts, wus a more morlrrute success. e m with Pulitzer Prize winrringpIrrywnght tkfh Henley wri~ing. Photo courtesy I S M Pictures.
year, a $7.4 million equity placement was arranged. Island Pictures is an rf- ficient operation - unlike some of the more notorious larger Hollywood studios - and it knows how to recognize quality.
Little known Island Pictures cap- tured a great deal of attention in 1985 with two extraordinary films - "Kiss of the Spider Woman" and "Trip to Bountiful." It was the first time in his- tory that one production house could claim credit for both the Best Actor
ADVANCED MEDIA GROUP Page 42 of 76 05.03.2007
Advanced Media Group Page 108 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 164 of 198 Monday, November 23, 2015
![Page 165: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/165.jpg)
The information set forth herein w a s obtained fnan sources w h i c h we believe reliable, but we do not guarantee its accuracy. N e i t h e r the information nor any opinion apressed constitutes a solicitation by us of the purchase or sale of any securities or cammodities. 'Ibis package is for informational purposes only, to gain an indication of interest in th i s project. Financial Management Group Ltd. does not endorsed and has not been contracted by Wer Station to promote this project. Any questions regardug information contained herein should be direckd t o Stanley J. Caterbone or Scott Robertson.
ADVANCED MEDIA GROUP Page 43 of 76 05.03.2007
Advanced Media Group Page 109 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 165 of 198 Monday, November 23, 2015
![Page 166: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/166.jpg)
ADVANCED MEDIA GROUP Page 44 of 76 05.03.2007
Advanced Media Group Page 110 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 166 of 198 Monday, November 23, 2015
![Page 167: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/167.jpg)
I. wty Financing with Limited -D
a. UnlimitedMmrberof Investors b. Small units of $5,000 to $25,000 per unit c. Share 50% of profits w i t h Limited Partners d. Time constraints as follows:
1. 90 day for regulatory app- to solici t securities 2. 30 - 60 days to raise 2 - 4 million
11. Equity Financing w i t h General Partners
a. Smallnumberof investors b. No time constraints t o raise funds c. Large uni ts $1 to $4 million units d. Share 50% of profits w i t h General Partners e. Very difficult because of the poor economic reputation of film
b3ustry w i t h r qxds to investors.
111. Debt Financing with General Partners
a. Sam= as above b. Costs are 50% interest per year: For every $1 million, it w i l l cost
a t least $500,000 in guaranteed interest payments.
IV. F're Sell Distr-ion Contracts
a. W of m t i v e Control b. Share 60% to 80% of profits w i t h Distribution Ccarpany c. upside potential d. Litt le damside risk
v. DebtwithLineof Credit
a. Need collateral - redL estate, inventory or accounts receivables b. Very cheap 8% - 11% per year for i n t e r s t c. N o t h constraints d. No loss of creative control
ADVANCED MEDIA GROUP Page 45 of 76 05.03.2007
Advanced Media Group Page 111 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 167 of 198 Monday, November 23, 2015
![Page 168: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/168.jpg)
ANALYSIS
The follawing Analysis shows how the different forms of financing conpare to one another under the most important variables to us:
1. Creative Control 2. Time parameters 3. Costs
I used three economic sceneries as to the net results of the project:
1. A of 1 Million Dollars 2. A Profit of 15 Million Dollars 3. A Profit of 100 Million Dollars
Alternatives Time Creative Cost Of LDss Of Prof it Profit Of - Corrtrol Financing $1 Million of $15M of $100M
1.1 Equity 90-180 Same with Limited Days mss
II* )Equity 30-180 MOZ with General Days Loss
I
111. ) Debt with 30-180 S ~ T E Generals Days Less
N. ) Pre Sell 30-180 Distribution Days
V. ) Line of 5 - 30 Credit mYs
None Inst
50% of No lhss $7.5 M $50 M. Prof its
50% of No bss $7.!34 $50 M Prof its
50%-100% No Lr>ss $3.0 M $3.0 M Interest m e s
60%-80% NO LOSS $10.5M $70 M of Profits
8%-11% Refinance $440,000 $440,000 Interest Wlilding or or Payments with 30 year less less
note with $9523/Mo. payment @11%
ADVANCED MEDIA GROUP Page 46 of 76 05.03.2007
Advanced Media Group Page 112 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 168 of 198 Monday, November 23, 2015
![Page 169: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/169.jpg)
1. Story $ 5,000
2. Treatment 35,000
3. Director 50,000
4. M o m 110,000
5. ArleneandEhrbara, N.Y. 50,000
6. Finance Costs 200.000
$ 450,000
Line of Credit $ 250,000
Stan's Investor 250,000
The above gives us 60 days to receive funds froan Sony and Visa for the spot in the beginning of the video.
n-Lis gives us a chance to get money without using the line of credit.
ADVANCED MEDIA GROUP Page 47 of 76 05.03.2007
Advanced Media Group Page 113 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 169 of 198 Monday, November 23, 2015
![Page 170: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/170.jpg)
THE MI-ITANT FRO.-IEC:T IIAY 27, 1 i/:37
__--____--_________-------------------------------------- I I t TOTALS I
_-_---_-_-_--__-_---------------------------------------; STORY O I I 5;0(:10.00 : C:SINT I NU I TY AND TFi'EATMENT * I
I 3.1(75(:1 . (:](:I : F'ROKIUCEK o I I 1 15054. 00 : D 1 RECTOR 3+ 1 2250(2(11. (I)(:) : I
OAST I I 38&,,212. (10 :
B I T S I I 521.00:
EXTRAS AND STAND-INS I I 122253. C)O : I I t
I I I I
----------------,-----------------------#---------------'
TOTAL ABOVE THE L I N E I a 8E8&.YCl. 00 1
----------------------------------------a---------------;
I I I 1
I I I I
I I I I
PRODUCTION STAFF SALARIES I a 1Y255S. 00 :
PRCfDtlC:T I ON OPERAT I NG STAFF I I 58295&..00 1 SET DESIGNING I
8 Z051cS5.00: SET OPERATING EXPENSES I
I 26t5.858. C)O 1 LOCAT I ON I
I 543:395.00 : TESTS AND RETAKES 8 I 20750. OC) : CUTTING/FILM/LAEORATORY I I .- -3~-4244. -. (:)(I : MClS 1 C I I 161409.00: SI~I-IND _ 1 I 184359.00: PLIEL I C I T Y 1 I 1 1
MISCELLANEOUS I I 19121.00: INSURANCE/TAXES/LICENSE5; k FEES 8 I 31 1381. 00: GENERAL OVERHEAD I
I 3580(1. C)(] : I I I
1 I I
-----------------------------------------;---------------t
TOTAL BELOW THE L I N E * I 2c5c,5 16.00 : ----------------------------------------;---------------t
----------------------------------------;---------------t
TOTAL ABOVE b FELQW THE L I N E 1 I 37472(1)&. 00 : ----------------------------------------;---------;=----: ----------------------------------------1---------------;
TOTAL FINANCE CHGS/CClNTINGENCY /BONDS 1 I &*46750.00 : ----------------------------------------;---------------t
GRAND TCfTCIL a 4393956.C)C) 1 ........................................ --f-------
* tlOES NOT INCLUDE c:2"'' f ::r>ENIY
ADVANCED MEDIA GROUP Page 48 of 76 05.03.2007
Advanced Media Group Page 114 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 170 of 198 Monday, November 23, 2015
![Page 171: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/171.jpg)
F'AGE 1
STORY: I [lAYS/WEEt::S : RATE I I TClTAL '------------I---------------;-------------.
4. STiIIKY F'l-lRC:HASE 1 : 5(:)0<).()0 1 5<100. 00 P. T I TLE PI-1HC:HASE I I
I I : U C:. M 1 SCELLANEiII-1::; EXPENSE I I I I : O
I I I I I I
-----------------------------------I------------l---------------;--------------
TlIlTAL STORY: I I a I : 50(:,C). 00 -----------------------------------'----'------------:---------------;-------------- Cl3NT I NU I TY AND TREATMENT: a I I I I I
I I I I I I
A. WR I TERS : 1 : 30000.00 : 3000O.O~) B. SECRETARIES AND TYPISTS I 8 1 I : O EB. PAYROLL TAXES - B (15.8%) a 1 8 I : O C. XEROX EXPENSE 1 .IS : 200.00 : 3000.00 I?. RESEARCIH EXPENSE I I a I : 1650.00 E. MISCELLANEOUS EXPENSE 8 I 8 I I I
I I I I I I
----------------------------'------------;---------------a-------------.
TOTAL CONTINUITY AND TREATMENT: I I 1 I : 3465(1). (](I -----------------------------------'------------;---------------;------------- PHODIJCER : I I I a t a
? & 7 e m ~ G I I I I I I
A. S ROEINSON/S a I I I : 0 I I I I : 0
B. ASSOCIATES (ARLENE) : 1 : 100000.00 : 10~l000.00 BE. BARBARA PEETEKS (DEFERRED) I I I o : 0
I C. SECRETARIES : 26 : 500.00 : 13000.00 C:C. PAYROLL TAXES - C: (15.8%) a I 0 : 2054.00 D. MISCELLANEOUS EXPENSE I I I : 0
I I I I I I
-----------------------------------~------------~---------------~-------------.
TOTAL PRC1DUC:ER : I I a I : 1 15c)54.00 -----------------------------------;------------;---------------t-------------
D I REC:TilR: I I I I I I
I I I
I I I
A. 11 I RECTOR : 1 : 200000. 00 --I 1 20006C). 00 B. SECRETARIES I I 8 I O EB. PAYROLL TAX - P ( 15.8%) I I 1 8 : 0 C. HEALTH b WELFARE/PENSION 12.5% : I I : 25(]0(].()(] D. MISCELLANEOCIS EXPENSE 1 a I I : i)
I I I
I I I
-----------------------------------;------------1---------------;-------------
TOTAL D I RECTIIIR I I I I : 225~1(:1(:).0(:) -----------------------------------'------------;---------------1-------------
cAST : I I I I I I
C:OL HEMSLEY (P/DY : 5 : 10c)0.(1(:) : 5000. R I C K (P /DY) : 34 : 1000.00 : 34(:)c)(]. 00 .-IERKY ( P / t lY ) : 15 : 1000.00 : 15000. (30 V T C ( r n . / r ~ ~ ) I I .-, A%s -, : I (1) 0 (1) . (3 (11 : 2:30(:)0. (:I(:! 5 T h N ( F / t fY ) : zk, : ~ C ) Q ( : I . ~ I ~ : 2k.0i10.i~c) t::ATIE ( P / D Y ) : 11 : 1 (1) (1) <I . (1) (11 : 1 1 00 (1) . (1) (1) GARREN (F' /DY) 7 : 523.00 : 3675. 0~:) --IRCt:' ( P / D Y ) : 5 1 525. (:I(:) : 2(;25.(:)(1)
. - . --- -.-. . , ?.F .-. ,-. ADVANCED MEDIA GROUP Page 49 of 76 05.03.2007
Advanced Media Group Page 115 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 171 of 198 Monday, November 23, 2015
![Page 172: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/172.jpg)
MATTHEW AP'A MR X (F' /DY) 5 T H BOND MEMBER ( P / D Y ) LII~II:: t::LEIN ( F / t l Y ) BARNEY ( P / D Y ) .-IE:I-;;SIE (P/DY ) r::ORRI E ( P/DY ELID (P /DY) 1::HARLIE (P /DY 1 ANNIE (F/DY ) I:rl'i L!-lN!:iRIN (F' /DY) lz*;4t.l (P/L!Y) !:.Ers!+!'< <f:8i[!y; I:.; lt.~I:~l: r.., i ( ,ras-tx TI.,-\ 1' \
- . . , - . - I : J. L r- I I I
,-!v,,,l::El:; .-.- i i .*,: 1.; :-Ir: '. ' .. i .- . ,
~.:;I>LLE[.~ (:(.{&*:.,'rEFi - - .- plat.; ( t : - l iCr I \ r-iA\,' )
r.-.. p! . ' . z.;%; l-k:!~:;;:=;c ! ::.;-F,; [,!;q..f :! l l t i 9 k A J /
':;:C:>!'yt:'".' I "2 " ,.-.,-,-8--l, ;; L.12 i.!{:,',' :
EL!'{ (FfjJ< Llf;y') - . .- , - ,L , L, .I 3 -a .,' p-lr.; (i:.Er.* ,-, i-!{-,.,' ,:
;)E; ',/ L..'l..-c n . . ( pk-!.L . . .LI \ : \ :I:# ':' ? . . . ; - 7 . :. " '""
A . . ,-- \ L . * . , i ? : ;;;i\.;:; :f;'?'AFF WC!MAf;! ( ;-'Z:f: i:A\,' ',
L a .
.. ,-." ,I : .,- .:.,-<l-,.t, -.... tk:- (. !.,L::, L!t.%,%! j
Li;., ;< ;-: 1 r,i i-, 1 ,L 2: ; :..;I.,.- -. . >:&!''\ j
.i \ ! 1: 1.; ... ? &. .- - ( FEE c!A'y ) P.. . , .. . id:;= ,-' - &... * ::: ( p k.l< LlG %:' .i
-. ELE?,(zHc[l BF;; 1 x:!; 1 ; C:*FIf;: LI;?~',' ELEACHEtr ERA 1: r..]::: 2 ( PElI; C-IA';' )
BLEF;IZHEU SK;iIN:S 3 ( P E R trAY) FLERC:HED F R 6 I N S L! (PEK tlHY ) Cl:fA!sT Gl-lARD (PER DAY ) F R I L L Y G I R L (PER DAY)
?, MRS. QUEEN ( PER ! DAY 1 HANDSOME TEENAGER ( F'ER EIAY ) GIANT ULTRIMA GUARD ( PER DAY CRlJDE BOY'S ISATE ( PER DAY ) CORPSE OFFICER 1 ( PER DAY BARRICADE C:OP 1 (PER DAY) MUTANT S I T E CIIP ( PER DAY ) t::ERR '5 S 1 DEK 1 C:F:: C:IIIF' ( PER DAY )
HEALTH k WELFfiRE (11%) FAYROLL TAXES (15.8%) OVERTIME CAST ( 5 % )
STI-lNTS : Bl3QT DRIVER 11 I VER CHARLIE I N TANK G I R L PULLED FR R I D E BOY PULLED FR H I D E CREEP PULLED FR R I D E CHARLIE & BARNEY F IGHT STAN FEATS COL H
HEALTH & WELFARE/F'ENSI ON ( 1 1 % ) PAYROLL TAXES ( 15.8% ) l l T STLINTMEN (5% 1
ADVANCED MEDIA GROUP Page 50 of 76 05.03.2007
Advanced Media Group Page 116 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 172 of 198 Monday, November 23, 2015
![Page 173: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/173.jpg)
C:IIIAC:H I NG ( V O I C:E/STUNT IZOCIRD/ETI: ) : : 20 I
HEALTH h WELFARE ( 1 1 % ) I 4
FAYROLL TAXES ( 15. :::% ) 4 I
!:IT STI-INT COr3R ( 5% , , I
i1:AST 1 NG D I RErI:T!]R 4 t
IZAsT I NG SIJPPL I E::; ( 5% ) I 8
MISCELLANEOUS , I t t
I I I I
4 <I (11 . (1) (1) : E:-:C)(:)O.i)c] : ::::3 (1) . (:)(I) : 1264. O i ) 1 4 4 4 . (11 (1)
1 5 (1) (:) . (1) (1) : C.0(:)0 . (:I(:) : :300 , 00 : (1) : 0
,--------------(-------------.
TOTAL CAST I I I I 1 380211.7(:)
-------------------------------'------------'---------------i-------------
F I T S : I I I I I I
KCINN I NG TEENAGER ( P/ISY ) : 1 : 150.00 : 150. 00 DANCING GIRL ( P / D Y : I : 150.00 : 150.00 FRILLY MClM : 1 : 150.00 : 150.00
I I I 1 : O
HEALTH ?A WELFARE/PENSION I I I I : 0 PAYROLL TAXES (15.8%) I 1 1 1 : 71. OVERT I ME I I I I : 0
I I I I : 0
F I T T I N G CHARGES 1 8 1 I : 0 I I I I : 0
-----------------------------------;------------;---------------;------------- TOTAL BITS: a a I I i 521.10 -----------------------------------'------------;---------------;------------- EXTRAS: I I 1 t I I
SEE PRELIMINARY BOARD : 1400 : 35. 00 : 45000.00 I I I I I 0
OVERTIME ( 2 HRS) 1400 : 13.13 1 18375.00 OVERT1 ME ( 1 ADD HR 1 : 700 : 6.57 : 4539.00 F I T T I N G FEE a a 8 1 : 0 PAYROLL TAXES ( 15.8% I I I 1 1 11271.89 SERVICE FEE ( 10% ) I 1 t I : 1334.59
I I I I : (1)
EXTRA ADJUSTMENTS (DRIVE T O ) . : 1400 : 5;. 00 : 70(:)0.00 I I I I 0
STAND-INS ( 4 X 46 DAYS) : 160 : 77.00 : 15520.00 PAYROLL TAXES ( 15.8%) 8 I a I 1 2452.16 HRW STAND- I N S (NUN UNION I I I 8 0 FClX LUNCHES - EXTRAS 1400 : 4.00 : 5600. 00
I I I I : 0
-----------,-----------------------I------------l---------------_:-------------
TOTAL EXTRAS AND STAND-INS 4 I 1 t : 122252.64 -----------------------------------I------------~---------------~-------------
I , I I 1 I
I I I
I I I
-----------------------------------:------------;---------------o-------------
GRAND TOTAL ABOVE THE L I N E 4 I I 8 : :28:368'3. 44 -_----_---_--__-___-----------------------------------------------------------
ADVANCED MEDIA GROUP Page 51 of 76 05.03.2007
Advanced Media Group Page 117 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 173 of 198 Monday, November 23, 2015
![Page 174: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/174.jpg)
. . . . 1 , - . , , , . , . I
. . ! , -. .I ; : - , r . -
. . . . I . ... . -
. , , . , I .. . , . : $ 1 . : - , 0 . 4 < . , , ,
. . i l . . . . . . : . a , \ : - 8 . . ,..- . , . . I
s,:, , . I ! , : .,!> : . . . : , , , - . ~. .
.'\.::, t ' .F , , : . ! i , ' ;- ; ; ! . .. . ' - ;. 1. , '-%I.; , ,.+:!:k 8 .: A: . . . : .'?? ';; 11: . (1) (1) ; . I : : :5 f14 . (-) ,
1 ~ . , : I I . , , . ' .. .
. , ., . . . . . , .,.,:..:. i j.'F i::..' >;IL:.-[: j I . (-): . .
. , ;:,-;-,; ;;;l;,:;-!;,-!-;!~:. _,I I. <i . : s ; . . : ~ . , ; b ! ~ i i : , . j 11: 2 7 (1) (1) (2 (1) : 297(:)C). i:~! - -
: '_ ., I _ . ;- ;::;.;;c:;-!;y 1~ ; !.-:>; ;:L:F- (!:*Fcr< i&Et.: ) I I- - I=, 0
I .-# I 4 1 (1) . (1) (1) : :=:?:::(I) - (1) ( I ' , . , I 1 , /;.:,.: .; I
. I . . . L Ll 1 \?:!::TI:I&' ( (PER WEEK ) I 1 (1) : 1 8 (1) (11 . (1) (1) I 1 ::: (1) . (1) I ErD. ZND 2 N T ! At1 (PER WEEK) I I .=. *-+ a t 1 7 (:I (1) . (3 [:I I 1 3/-. (:I(;) . 01
,=a I t E . TrNrl Art PRODI-IC:I ON F E E ( PER WEEK ) : --* I 329.00 : 2r5~:2 . (1): F. Ll11C:fiT I CIN MANAGER ( PER WEEK ) I I 16: 1000. (30 : 1 4Oc:)O. (111 G. !:;CR I F'T :i;IIF'EKV I ::;OR ( PER [IAY ) a 43: 235.00 : li)l(:15. (111
I . F'RODI-IC:T I ON C:I-\IIIRD I NATOR ( P R ClAY : A 1 I 1-30. ( ~ 3 : 1 1 59(:) . (1) I .-I. TEC:HN I C A L AIIV I SOH ( PER DAY I
a 10: 300.00: 2: o (1) (1) . (1) ! K. NI-IRSE ( P E R D A Y ) I
I 1 (2 ! 175. (30 : 175(1). (111
L. LI:IC:AT I ON AI-Itl I TOR ( PER WEEK) 1 I 121 13(:)0. 00 : 156()(:, . (111 M. WELFARE/TEAC:HER ( P E R D A Y ) I 1 .-I L I t 200.00 : 4t70. (111 N. N I G H T PREMIUM ( 5 D A Y S ) - 5 0 % I
I .5: 1 175.00 1 537.51 N. I I IVERTIME ( 5 % ) 4 I I 1 1 t * ? l k 8 y . 4: -----------------------------------:------------;---------------a--------------
TOTAL PRI:IDUI_~T I ON STAFF: I I I I I I 1 ' 3 2 5 5 7 . 9 -----------------------------------;------------1---------------1--------------
PROKII-ICT I ON OPERAT I NG STAFF: I 1 1 I t I
A. C:AMERAMEN I I I I I I . D I RECTOR OF PHOTOGRAPHY ( P/WK : 9 : 3000.00 : 2 7 (1) 0 (3 . (1) CAMERA OPERATOR ( 5; ( P /DAY 8 1 51 : 340.00 : 1 7 3 4 0 . (1)' KEY 1 S T A S S I S T A N T ( P / D A Y ) I I 51: ~ - 3 5 . 0(11 : 11935. (11 F ?
1 S T A S S I S T A N T ( P / D A Y ) I I 41: 235. O(7 : 9r5,C:5. 0
2 N D A S S I S T A N T ( P / D A Y ) I I 41: - 220.00: Q(320, i) VTR PLAYBACK ( ? / D A Y ) q 5 : 275.00 : 1275. (3 S T ILL PHI~TI IC~RAPHER ( P / 3 H DAY) : 10: 150. 00 : 1 %(:)(:I . (1) EXTRA CAMERA OPERATORS I I a I I I . (1) N I G H T PREMIUM ( 5 D A Y S ) - 5 0 % I I . c 4 I I 9(25(] . (30 : 4 5 2 5 . (7 O. T. CAMERA CREW ( 10% I I I I I I E: 24, E: . (11 M 1 SC:ELLANEI]I-I!E; I I I I I I
-----------------------------------#------------*---------------*--------------
TCITAL CAMERA S T A F F I I I I 1 I '9 (I)y 4 ::: . (11 -----------------------------------I------------~---------------l--------------
E . SfIlI-IND DEPARTMENT I I I t I 1 . (1; M I X E R (F ' / t IAY) I I 41: 275. 00 1 11275. (1; RECIIIHDER I I -4
I I - I . (-1
FCICIM PERSON ( P / D A Y I I 41: 235.00: 9/- . --.-,.-I '3 c . (-1 - 11:AELE PERSON ( P / D A Y 1 I 41: 235. (:I(:) : '?6:35. (1) IZAELE FtIlOM PERSCIN I t I I I I . (11 RAD 1111 PERSCIN I I I I I I . (: N I G H T PKEM I LlM ( 5 D A Y S - 5 0 % I I . c LU 1 8 3725.00 : 1 8k.2. 5 O.T. SlIlI-IND C:REW (1(11%) I I I I I I 324(:1. 7 M 1 :~;(~:ELLANEIIII-I:I-; I I I t I I
-----------------------------------'------------#----- I --- TIIITAL S1:fUNEl S T A F F I I I I I I 356.4:::. I: -----------------------------------;------------s----------- * 1:. WAR~IROFE IIlEPARTMENT I a I I a I . (1
WARDROBE LIES i GNER ( P/WK ) I 12: 1 /500 .00 : la32(:)(:). '
L.!,c)F;rr~f~;GC7 I21 ".'CK, I I I I , 3
W[IlMEI\I .':3 CJ&Rfiti!ilr*E 1 S T (P/K lAY) I I 51: 235. a(:, : 1 1 .?:::.y (.
ADVANCED MEDIA GROUP Page 52 of 76 05.03.2007
Advanced Media Group Page 118 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 174 of 198 Monday, November 23, 2015
![Page 175: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/175.jpg)
G. SET DF;ES:-:ING DEF'AKTHENT I 4 I I I . (1
:SET [IEIZI:IK'ATIS~~ ( F'/ [IAY ) I .-, .-, c I 51: L .-. .-, . (1) (1) : 1 1 *.;/::: 5 (:
ASST SET [IEC:I:IRPTI:IR ( /='/DRY ) , t 51: 2 2(:1 . (](:I : 1 1220. (:
[lRES:::/RE[IRE:f;S/STF( 1 KE 4 8 I a I I . C
DRES::;/REDRESS/STR J tc:E I I I , I I . (1 [IRE:S:I;/RE[I~E!:;::;/STR 1 KE 1 I I
I I I . (: DRAPERY PERSON I I I
I I I . r r3REENSPERSl:lN I I I
I I I . (: GREENSPERSON I I I
I I I . i NIGHT PREMILIM ( 5 DAYS) -50% I
I .51 2275.00 : 1 137. .? i t . T. SET DRESSING C:REW ( 10%) I I I
I I I 24:1:4. 1 M I SC:ELLANEl:lUS I I I
I I I
-----------------------------------I------------~---------------~--------------
TOTAL SET DRESSING STAFF I I I I I I 2 6 7 7 6 . 7
-----------------------------------:------------1---------------;--------------
H. ELECTRICAL DEPARTMENT I I I I I I . (1
GAFFER (P/DGY 1 I 1 43: 235.00 : 101 05. (1
BEST BOY ( P / D A Y ) t 1 41: 222). 00 : 5~(:)2(:) . (1
ELEC CIF'ERATINC; LABISR ( P/DAY I I 41: 210.00: 161t:). (
ELEC OPERATING LABOR (P/DAY I I 41: 210. 00 : 86. I(:). c
ELEC OPERATING LABOR (P/DAY I I I I I I .I
GENERATOR OPERATOR ( P/DAY ) 1 I 41: 220.00 : 9c)2(:). (
GENERATOR OPERATOR I I I I I I .
ELECTRICAL R I G G I N G / S T R I K I N G I I I I I I . t
ELECTRICAL R 11313 I NG/STRI k< I NCi I a I I I I . (.
FAN OPERATOR I I I I I I . (.
N I GHT F'REM I 1-IM ( 5 DAYS ) =50% I C I I . .-I I 5475.00 : 27:::7. F
O.T. E L E C T R I C DEPARTMENT (10%) : I I
I . I 4 8 1 0 . :
M 1 SCELLANEI~IJS I I I I I I
-----------------------------------'--------------;---------------:-------------.
TOTAL ELECTRICAL STAFF I I 1 c-, - I I I 4LY12. ;
7 -----------------------------------1------------;---------------1--------------
I. S P E C I A L EFFECTS I I I I I I . (
SP F X CIXtRDI NATOR (P /DAY I I 10: 305. (20 : 1:: (1) 5 (1) . (
SF' FX OPERATING LABOR (P /DAY) : 10: 3<15.c)0 : 3(:15(:). (
:3P F X OPERATING LABOR (P/DAY : 1 0 : 3(:)5.0cJ : .I. (-1 5 (11 . ( .- -
!Z;FECIAL F X OPERATING LABOR I 1 I I I I . (
DESIGN I NG $< DRAFT 1 NlIi LABI3R I I I I I I . (
ElESIGNING .9< DRAFTING LABClR I I I I I I
1
C1:lNSTRUC:T 1 GIN tf R I 1 2 c I N I ~ LABOR : 5 : 100. C1.Q: 5 (:I (1) . ( C:ONSTRUCTION fq R I G G I N G LABOR : I I
I I .' N I GHT PREM I l lM ( 5 DAYS 1-50% I C I
t . .-I 1 1525. (I(] : 762. 111. T. SF'E1:IAL FX ElEPAHTMENT 10% : 6 I
a I 1 0 4 1 . M 1 SCELLANElIlIJS 1 I I
I I I
-----------------------------------;------------;---------------;------------- TOTAL S P E C I A L F X STAFF I I I
I I I 1 1 4 5 3 . -----------------------------------'------------:---------------;------------- J. SET STANDBY OPERATORS I I I
I I I
CARPENTER ( F / D A Y ) I I 1 (11 : 250.00 : .TC - - .-I (-1 (-1 .
CARPENTER ( P / D A Y ) I I 1 (:I : .-, .> c .-. . (j o : .>.:a c
L .-- .-a (1 . EXTRA CARPENTER LABOR I .-. 1
I -1. I 100. 00 : ::: (1) (1) . NIGHT PREMIUM ( 5 DAYS) -50% I E 8
I . .-I I 1250.09 1 /- '7 C -. 6 .-' . TI. T . SET z;TAwryrE!v ~ I F E R ~ ~ T I ~ I H S 1(5% : I 1 I I 577. 1 :!: 11. EL L & Pi 1'11 i-I .=, , I I
I t
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -~--- - - - - - - - - -*- - - - - - - - - - - - - - -*- - - - - - - - - - - - -
ADVANCED MEDIA GROUP Page 53 of 76 05.03.2007
Advanced Media Group Page 119 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 175 of 198 Monday, November 23, 2015
![Page 176: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/176.jpg)
7. .
TIIITAL :SET S / F l3F'EKF;T I PIIIi : i ;TAFF 8 I /.352. .5( ----------------------------------- ------------ I__---_----_-_--(-_----- - I . :SET STANDBY F'A I NTER5; f I
I I I . I
P A I N T E R (F ' /DAY) .=, I .- - ,La 8 .:: s (1) , (1) : ::: (1) 4 C) . (1) (
F'A I N T E R I I I . (1) (
EXTRA F A I N T E R L A B I ~ R .-I I I i I 1 0 (1) . (1) (1) : 3 1 ) (11 . 0 (
13. T. SET STANDBY F'fi INTER::: 10% : I .- 3 I I JL4. (I)(
M I SC:ELLANEIIII-IS 4 I I I I _ _ _ _ _ _ _ _ _ _ _ _
TOTAL SET S / B F A I N T I N G STAFF , I I I I I 356.4. (I)(
-----------------------------------l------------~---------------~--------------.
L. S E T WATCHMEN I I I I I I . (I)(
WATCHMON ( P / D A Y ) , 45: 150. (10 : 675(:). (:I(
WATCHMAN I I I I I I (I)(
EXTRA WATCHMAN LAESR I I I I I I . (111
0. T. SET WATCHMAN I I I 8 I I &75.0(
MISCELLANEOUS I I I I I I
-,---------------------------------~------------~---------------~--------------- TOTAL S E T WATCHMEN S T A F F I I I
I I I 7425. (:I( ,----------------------------------I------------'---------------*--------------.
M. F IREMEN/POLICEMEN I 1 I I I I 0 1
F I R E M A N (P /DAY) I I 1 o : 30o. CIO : 3000. (11.
F I R E M A N I I I I I I . V
POLICEMAN (P /DAY) I I 4 0 : 250.00 : 1 C I O C ) ~ . CI
POLICEMAN ( P / D A Y ) I I 20 : 250. oo : 5000. c:
P O L ICEMAN 1 I I I I I . 0
P O L ICEMAN I I I I , I . 0 1
EXTRA F I R E / P O L I C E LABOR I I I I I I (1).
0. T. F IREMEN/POLICEMEN ( 10%) I I I I I I 1 S Of:) . (1:
MISCELLANEOUS I I I I I I
-----------------------------------I------------'---------------l--------------
TOTAL FIHEIPOLICE STAFF I I I I I I 1 9::: 0 0 . C! -----------------------------------I------------'---------------l--------------
0. WRANGLERS t a 1 t I I . (-1 1 SPCA MAN I I I
I I I . (-1
HEAD WRANGLER ( P / D A Y ) I I I I 1 I . (-1
WRANGLER I I I I . (1:
WRANGLER * I I I I (11.
T R A I N E R I I I I I I . Ci
EXTRA A N I M A L LABOR I I I I . (-1
O. T. WRANGLERS ( 1 0% 8 I I I I . C .
MISCELLANEOUS I I I I
-----------------------------------'------------'---------------i--------------
T O T A L WRANGLER S T A F F I I I I I I . 0
............................................................................... P. TEAMSTERS (NOTE: 1 MAN F'ER ! ! ! ) : (NOTE: . 5 / W : 1 WHOLE WEE/::) :
CAMERA ( P/WK I I 1 0 : 22(:)(:) . 0(:) : 225)(:)0 . (11
G R I P (F/Wt<) I I I I I I . C'
ELECTRII: (P/WK I I I I I I . (1;
S E T C:IIINTRI-ICT I GIN ( F/Wt< ) I 1 3 .-a I I 1 &.(:I0 . a(:) : 4:3[)0. (1 ART DEPT (P/WK) I , 3 . 4 : 1 &.(:I(:). (:I(] : 1:344(:). c PROP ( P/WEEK 1 I I 8 . 4 : 1600. OC) : 13440. (: WAHDHIIIBE (F/WK I a Z.4: 1 &.(:I(:). O ( j : 1344(:). 1: MAKE-UP (P/WK I , 5:. 4 : 1 Gc:)O. 00 : 13440. i HONEYWAGON ( P/WK ) I
a 3 . 4 : 1 &(:)(:I . (:)a : 1344(:: '
HONEYLJAGCIN (F ' /G ! ! I ) t .: C. t t 1 6.00 . (1) (1) : "-j ::: r - .
:3F'EC.iAL F X (P/Wt:::) a 2. 4 : 1 /. <I (1 . (1) (1) : .-I .:.s~ ,-., 4 (-) . 1-
F'ICt:::-I-IF' $:ERVICE (F'/Wt:::) I I 9 : 1 /-. 1:) (1) . (1) (1) : 1 44(3(3 . (;I N 1 GHT 1 l-1141 ( 5 EIAY:; ) -s(:)% . L- --I I I 1 1:: 4 (1) C) - (1) (1) : &7(:)0. (:,
O. T . TEfiM:3TER:3 ( 10% 1 a 1 I 4 1.2374. (:; ADVANCED MEDIA GROUP Page 54 of 76 05.03.2007
Advanced Media Group Page 120 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 176 of 198 Monday, November 23, 2015
![Page 177: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/177.jpg)
10. SET r:ONI=;TRIJi:T I ClN : DAY!:;/WEEKS : RATE I I TOTAL -----------------------------------I------------*---------------~-------------.
A. PRODI-KT I O N DESIGNER (P /WK) I - I 1 6 : 20(:)(:). 1 320(:)(:). I
AA. ART DIRECTOR I I I I 1 I . I
F . ASST ART DIRECTOR I I 8 I I I . (
C:. S;k,'ETcH A R T I S T I I I I I I - 1
D. DRAFTSMAN ( P / D Y 1 I 2 : 2 5 ~ j . ( j O : 4(:)(:) . (
E. SET SUPERVISOR ( P / D Y ) I I 15: 250. OC) : 3750. I I I I 4 I I . [
F. MISC: FX/BLt IGS/ t IRESSINGS: I I I I I I I
1. MUTANT F X (sea + sore e t c ) I I 1 : 1 1 lcs~ro. 0 0 : 1 1 1 (1)(1)0 . (
2. BANDSTAND I I 1 : 1 o<) (1) 0 . (:I C) : 1 C) (11 (1) 0 . :
3. P I E R I I 1 : 5 (1) (3 (1) . (1 (1) : 5~:) (1) 0 . (
4. SHOOT I NG GALLERY I I 1 : 500. (:to : 500. . 5. CASTLE OF TERROR I
I 1 : .5000. i)(j : 5 (1) (1) (:) . : 6 . V I C ' S O F F I C E I I 1 : 50 (1) . 0 0 : 5 (:I 0 . 7. CONTAM I NATED BEACH I
I 1 : 5 (1) (1) . (1) (1) : 5 (1, (1) . , 8. E;HER I FF STAT I ClN I
I 1 : 5 i)(:l • (1) : c - - La (-) (-1 .
9 . DCiC KLEII \J 'S I I 1 : 30 (I)(:) . (I)(] : :30(1)(1). I 10. K T L V NEWS S T A T I O N I
I I : 1 ooo. 00 : 1 . 11. R I C E ' S APT I -
I 1 : 300(:). : 3 (1) (:I (1) . ' 12. LlLTR I MA INSTI TI-ITE I
I 1 : 5000 . : 5 (1) (1) . ! 13. D I V E R ' S HOUSE I
I 1 I 500.00 : 500. ! 14. M O L L I E ' S FAR I
I 1 : 500. ()(I) : 5;c)O. i
1 5. PI-ITLER HOl-ISE I I 1 : :I;(:)(:)(:) . (10 : :3(j00. c
10. C:HARLIE'S I2ABIN I I 1: 80(1)(1). 00 : S 0 ( 3 0 . 1
1 7 . BARNEY'S HfIiI-I:SE I I 1 : 20(1). ( j O : Zc)(:). 1
13. ROLLER CCiASTEF\: I I 1 : SO(:). : 50(:). : 1 9 . WRECKED PLANE I
I 1 : 5(:) (110 . (:)(:I : 5 (1) (1) (1) . : -. - LC). C:lIINTF;'CILLERf RRlIlH I I 1 : 50(:). ()a : c .-I (-1 - (1) . , 21. MUTANT FX MAN H%W ( P / D Y 1 I I a>,= 4 1 8 13 1 . (:)(I) : 2 t s : 3 5 .
R I GG I NG G R I P LABOR ( P/Wt< 1 I I 8: 400.O.Q: 2: 2 (1) (11 .
:E;TF; 1 I:: 1 NG I I I I I I
BQC:K 1 NGS I I I I I I
IIiREENS I I I 8 a I
-----------------------------------I------------*----------------l-------------
TOTAL S E T CONSTRUCT I 11iN I I I I I t 2(:)5 185. -----------------------------------l------------;---------------l-------------
1 1. S E T OFERATING EXPENSES: a I I I a a
I I I I I I
A. C:AMERA E12UI FMENT RENTALS I I C- I;. 1 I 5 (1) (1) (1) . (1) (1) : 4 0 (1) (:I (1) . I3 . C:AMERA EI;!I-I I PMENT PI-IRCHASES I I a=s C. I I - '70 - 0 . (1) (1) : 1 t.(:)i) . C:. VTR F'LAYEAC:K RENTAL a I 1 : 1 5 0 (j . (1) (1) : 1 5 0 (11 . 1 . IZAMERG CRANE RENTALS I I 1 : 2 (:)(I)(] . (](I) i 2 0 (1) (1) . E. WARDRI:IEIC PI-1RC:HA:E;ED I I 1 : 3(>(:)(:)(:) . (:I(:) : 3 (1) (1) (1) (1: F . [,!&Z 7;.:.,- . . , , L , ,t-t:.-; ;,k;iTp,Lz; I I .-. cs , I c - .-I (-1 (-1 - . (1) Q : 4 r_1 (:? ,:. . G. WARtfROBE MA I NTENANCE I , :> -. , I 4 (1) (1) . (1) (1) : 33:)(:). H. G R I P Ef;!U I PMENT RENTED I 1 a=- .-. t t 2 (11 (1) (1) . (1) (1) : 1 6. (1) .C,0 0 . . I . PROF' EC.!.!r-l I F'MENT RENTED 1 .=, I
I t 5 (1) (1) . (1) (1) : 4 0(:)(:) . , I C.C.I-IC..:- C.1 IC-I-.UA.?CT, ! .=a , 1 C; 1-1 1 3 i-11-1 ! 1 .?(-I [-)I-) .
ADVANCED MEDIA GROUP Page 55 of 76 05.03.2007
Advanced Media Group Page 121 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 177 of 198 Monday, November 23, 2015
![Page 178: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/178.jpg)
t-.. . PKLII-'::. FiENlEIl L. ~ROFS-LI:IS::; RND LIQMAII;E-~% , M. :I;C!l-INB El;!I-I I PMENT RENTED t\l. WALt::I E TALI:::IES RENTEL1 111. Nl-1R:I;EKY F'URI::HASE[I AND RENTED : f . MAt:zE-l-lF' Fl-lRCHA:I;ES t
G!. HA I RDFtE::::3 I NG PI_IRC:HA::;E:3/RENTAL::; : R. ELECTR I C:AL EI;!I_IIPMENT RENTALS ; S. ELECTRICAL EQll I PMENT F'I_~RI::HA::;ED : T. GASOLINE-RENTAL VEHICLES ( 1 0 x 2 ) : U. ~3ENERATOFi RENTALS ( GAS ONLY I
V. SPECIAL F X RENTALS/PURC:HASES 1 I
W . PROP TRUCE RENTAL I I
X 1. WARTIROBE TRUCK RENTAL I 1
XZ. SET DRESSING TRUCE RENTAL I 1
X 3 . SET CONTSTRUCTION TRUCK RENT : X4. HONEYWAGON 1 1 t
X 5 . HONEYWAGON 2 , I X 6 . MAKE-UP THAILOR RENTAL 1 t
Y. PICTURE VEHICLE RENTALS: I I
Y1. BARNIE'S BOAT (P /DY) 1 8
Y 2 . CHARLIE'S BOAT (P/DY I a
Y3. DIVER'S BOAT (P /DY) I I
V4. COAST GUARD BOAT (P/DY) 1 I
Y5. RICK'S CAR (P/DY) 1 I
Y 6 . AMBULANCE (P/DY) I I
Y7. PAM'S CAR (P/DY) I I
Y8. JESSIE'S CAR ( P / D Y ) I I
Y9. PICK-UP TRUCK (P/DY) 1 I
Y10.POLICE CAR (P/DY) I a
Y11-BARNEY'S ROVER (P /DY) I I
- Y IZ .POLICE WAGON (P/DY) t 1
Y13.STAN'S CAR (P/DY) I I
Y1S. C. GUARD CAGE (P/DY) I I
Y16.VIC'S BOAT (P /DY) - 1 I
Z - CAMERA BOAT RENTAL (F'/DY) 8 I
ZZ. MISC RENTALS/PUHCHASES ( 5 % ) 1 I
I I
-----,----,-,----,-----------------* I --------
TOTAL SET OPEHATI ON EXPENSES: t I
-----------------,-----------------'-I------
12. LOCAT I O N : # #
A. AIRFARES (NY-LA) B. HOTEL-DIR/PRODUCER-NY ( P/MO 1 C. MEALS (PD 2 X 1 7 X 7 ) EIIR/PFC'OD NY C1. MEALS (PD 2 X 1 7 X 7 ) DIH/PROD N J D. LOCATION S I T E S RENTAL: D l . BANDSTAND AREA (P /DY) D2. A I R F I E L D (P /DY) D3. P I E R (P /DY) D4. BOAT R I D E (P/DY) D5. SHOOTING GALLERY (P/DY ) DG. CASTLE OF TERROR (P /DY) D7. V I C ' S OFFICE (P /DY) D8. CONTAMINATED BEACH (P/DY) D9. SHER I FF STAT I ON ( P/DY rl10. DOC t<LEINNS (P/DY) D11.KTLV NEWS STATION (P /DY) F 1 2. THE DOCyI.::: ( F'.;DY )
D13. R I O K ' S APARTMENT ( P / D Y ) D14.ULTRIMA INSTITLITE (P/LIY) D15.DIVER'!s Hlrrl-lSE (F'/EIY) D1G.I IOLLIE FEES F A R ,(F/KlY)
1:. I ._. I 2 (:I (1) (11 . (1) (11 : 8 I
81. I a _ * , 1 (1) (1) (1) . (1) (1) : c=o I I - . I /1,(:)(1,. : .-, I .-. 6 2 (1) (1) (1) . (1, (1) : 8x8 9 .-* , 2 5(:, . 00 :
1 _ I 6 2 .y (1) , (1) (1) ; 1-1 I 'I' I 4 (1) 0 (1) . (:I (1) : 3 1 , t .-' I
c - - ,I (-I() . ()(:I :
2 (1, : ::: (1) 0 (1) : 4 (1) : :;: (:I . 0 (1) :
.3 I
.L I 3(:)00. <I(:, : S : 45(:). <)(I : 1 '1 I .-. , 700. c)o : 0 1 .-a I 450. 00 : cu I L* 4 4 5 0 . 0 0 1 :3 : 2000.00 : .-I I i I 2()0(3 . (10 : 3 : 700.00 :
1 I I I
1: 300. (10 : 1: 100.00 : 2 1 300.00 : '-, I i l 400. 00 : 1: 100.00: r. I L' 1 400. 00 : 5 : 200.00: 1: 100. 00 : 1: 100.00: c. 1 .-. 1 200.00 : 1: 100.00 : 1: 2(:)c). 00 : --, I L I 1 (:)(I. 00 : 1: 400. 00 : 2: 20(:). 00 : .-a I 2 I 500.00 :
I I I I
I I I I
.----'---------------I-
I I I I
.----:---------------I-
I I I I
I I I I
10: 1.5;k.O. 00 : 4 : 1 1 (1) (1) (1) . (j (1) :
3C.C' I &&.em 1 100. 00-I_ .>.>q I L.-.C I 75.00 :
I I I I
C I .-I I 200 . ()(:I : I : - 400 . 00: 8 : 1 000. 00 : 1: 75(:). 00 : 1: 5(:)(?. (10 :
10: 75(1). (10 : 1 : 300. 00 : 4 : 150(:). 00 : .-, 1 i 1 10(:)5) . 00 : c I .-I I E:(:)0 . 00 : 1 ; 55)(j. ( jc) :
<r I i l 1 S(:)c). 00 : C I C' t 750. (I)() : C I .-I , 15(:)0. (:)(:I : :3 : 50 (3 . (11 (1) : 1 ! I (->(-I (-> I - > (-1 !
ADVANCED MEDIA GROUP Page 56 of 76 05.03.2007
Advanced Media Group Page 122 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 178 of 198 Monday, November 23, 2015
![Page 179: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/179.jpg)
t l17. El-ITLER HI:IILI::;E ( F/DY ) t
[IlE:. IIHARLIE":_: [ :ADIN ( P / D Y ) I:119. C:HARLIE":i; [ICIC:~::: (P/[ IY) D31. 1_7lIlNTR1]LLER .':f; Rr:ll:lPl ( F / [IY t121. ROLLER ClIlASTER ( F'/DY ) I
I
E. OFFICE RENTAL-WILDWOOtI(P/DY 8 8
E l . OFFIIZE El2IlIPMENT (F ' /WP: ) , E2. E D I T RM RENT-W 1LtlWOi1t1 ( P/DY ) I
I
F. CAR RENTALS-2 C? 8 NO I I
G. BUS RENTALS (CREW-ROUND T R I P ) : GI. M I N I VANS ( 6 VEH C? 2 NO) I
I
H. L A TO NY DRIVER-HOTEL h FD/DY : I. SUNDRY EMPLOYEES ( 6 PA/ 10 WK') : J. EDITORIAL EQUIP-WILDWOOD (F ' /MO): K. GRATUITIES (P/WK) I
1
L. SCOUTING ti PRE-PRODUCT ION I I
M. PERMITS I I
N. CREW ENTERTAINMENT I I
0. OTHER - I D L E SUN ( S X 5 5 ) I I
P. OTHER - CREW HOTEL I I
Q. OTHER - CREW P.D. (60x56) I I
R. OTHER - I D L E SAT (8x55) I I
S. OTHER - WILDWOOD PHONE (F'/WK) : T. MISCELLANEOUS I I
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - I - - - - - - -
h
TOTAL LOCATION EXPENSES: I I
-----------------------------------I-------
13. TESTS AND RETAKES: A. TESTS/RETAKES- 1 DAY EA :
3 D I R OF PHOTOG (P/ I lY CAM OPER (P /DY) MIXER (P/DY) BOOM (P/DY GAFFER (P /DY) KEY GRIP (P /DY) PROPMASTER ( P/ t lY ) WARDROBE (P /DY) MAKE-UP/HAIR (P /DY) SCRIPT (P /DY> PAM (P/LIY) R I C E (P /DY) OVERT I ME ( 10% >
E. IJNDERWATER PHOTOGRAFHY: 4 ROUND T R I P TO FLORIDA M I A M I HOTEL ( 4 X 2 ) PER DIEM ( 2 X 2) CAR RENTAL (P /DY) CAMERA RENTAL (P /DY> INCIDENTALS (P /DY) UNDERWATER D I R PHOTO ( P/DY ) UNDERWATER c7AM AS:3T ( P/DY ) E:.ECTF:IC: (P / t rY ) ELECTRIC ( P / D Y ) ELECTRIC: (P/DY > GRIP ( P / D Y ) GRIP ( P / ~ I Y )
1 (1) (1) (1) . (1) (1) : ::: (:) (1) (:I . (:) (:
7 5 (1, . (1) (1) : 2 2 5 (1) . (1) (: :> 0 (1) (1) (1) : 1:: (1) (1) . (1) C 2(j0. (:)(:I : .- (I) c:, . (1) (1
1 (:)(:)(:) . 00 : :I: (1, (1) (1) . (1) (: I
- . I . C)(.
8(3. (110 : 9/-.(1)(1). OC 450. (ji) : 7650. (:I(:
40. 0(? : .-a c C. ..I C) . (1) (:
650.00 : 1 (1) 4 (11 (1) . (1) (: 1 150. 00 1 1 1 5 0 . 0 i 8C)C). 00 : 96(:)(:) . 0(: 150. 00 : 2 1 c10. a(: 250.00: 15(:)(?0. (I(:
1900. 00 : 4275. (I( 500.00 : 50(?0. 0(.
1500.00 : 3000. (I( 200.00: :34(:)0. OC
1000.00 : 100C)O. O( 90.00 : F. 1 . J J 3960(1. o( 4 - ~ : ? ~ , ' : . 104(+0C);-[)C 40.00 1 10400(:). 90. 00 : 396C)(?. 0:
900.00 : 15300. (1 e l ( ! I I . i.
--------------;-------------- I I 543:335. (1;
--------------(--------------
I I
I I
I I . (1.
600.00 : 12(:)0. 0 340.00 : k.30. 0 275.00 : 550. (1) 235.00 : 4 7 (1) . (11 235.00 : 470. (7 235.00 : 4 70 . 0 235.90: 470. O 235. 0(:) : 4 7 (1) . (1' 235. oo : 4 70 . (1) 235.001- 4 7 (:I . 0 55(1). 00 : 55(:). [ >
550.00 : 55~1. c; I I 682. c> I I . C'
6.00. 00 : 2400 . (1) 100. 00 : 3(:)(:) . (11 50. (I(:, : 2C1@. (1 50. (10 : 1 (:I(:) . (1.
500. 90 : 1 (1) (1) . cj
2(:)(:). <)(I : 4(:)0. (:. 5 (1) 0 . (1) c1 : 10(I)O. (I! 500. 0 C ) : 1 (1) (1) (1: 1-
23:). (:)(I : .-n c/ : ,- 2:3 (1) . (I) o : 5(-(>. .. 2::: (1) . (1) 0 : 54.0 . (1; .'. C' (-) . (1) (I) 1 L ' - a - 5 6. (1) . (1; .-. .- L -1: (I) . (I) (I) : 3/.(1) . (1;
- - . .-, . ADVANCED MEDIA GROUP Page 57 of 76 05.03.2007
Advanced Media Group Page 123 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 179 of 198 Monday, November 23, 2015
![Page 180: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/180.jpg)
:3AFTEY 11 I VER ( F ' / l I Y ) I .-I I t L I 2:E:C) . (y) (1) r 5 6. (1) . (1) (1)
.:I I - -
lIlN 1I:fiMERA [I I VER ( F'/ DY ) I .L , (11 (1) ; 7 k. (1) . (1) (1) /:::IT FEE ( F L A ) I
6 20 : 5 (1) . (1) (1) : 1 0 0 (I) . (:)(:I ClVERT I ME ( FLA- l O % ) 4 L
I I 4.6 ::: . (:) (1) N 1 :~;C:ELL+?NEI~II-I~ I I I . 0 (1) , F 1 LM tc F'F;I:IC:ES;S ( :SEE ~ C I S T ) I I I I . (:)(:I
TI~ITRL TE:Z;TS AND RETAKES: I I I I I @ 2 (1) 7 5 (1) . (1) (1) - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - I - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - ' - - - - - - - - - - - - - - -
I I I t I I
I I I , I I
-----------------------------------'------------;--------------- --------------- TOTAL SET LlESIGN/LOCATION/TESTS: I I I
I I I 103&.&.87. 5C) ................................................................................
................................................................................ 14. IZUTT ING F I L M LABORATORY : tlAYS/l-JEEES : I TOTAL RATE I
--,--------------------------------~------------l---------------~---------------
I I I I I I
4. EDITOR (P/WK) t I 24 : 2400. 00 : 576.(:)0. (I(. E. ASST EDITOR (P/50 HR WK) I I 24 : 1000. 0(1) : 24(j(?O. (I(. C. SOUND CUTTER (P /50 HR WK) I
I 10: 1425. OC) : 1425(1). (I)( D. MIASIC CUTTER ( P / 5 0 HR WK a I :2 : 1425.00: 1 14(1)(j. E. NEGATIVE CUTTER (P/REEL) 8 a 1 (1) : 53:). (10 : ec d .-I (-1 - (-1 - . (1) ,:
I I I I I I . (1)i:
F. NEGATIVE P I X RAW STOCK ( F / F T ) : h --. . 3 ~ 6 : 120000. (20 : 39 1 ~ ( 5 . 0 ; : G. NEGATIVE SOUNI! RAW STOCK ( F i / F T ) : .025 : 1 4(1(1(:)(:) . o(j : 350(1). Oi.. H. TRANSFER F I L M TO VIDEO (P /HK) : c -1 I I Zz(1) (:)(I) : lzz(). (:)i, I. DEV ACTION (NO TAX P / F T ) C! 65% : 1257 : 7:30(:)0. (30 : 1 (j(j38. /,(: J. XFER SOUND (NO TAX P / F T ) @ 65% : . (-I.-. - - I I 9 1 000. 06 : 2730. (:I(:' E. PRINT ACTION(12( I )Kx05%)- INCL TAX: .:3375 : 7:3000. 00 : 24325. (:)(I;
L . F'R I NT SOl-lND ( 1 46K:<&5% > -I NCL TAX : (j &a%. -3 c. I I 1(1)(30. o(5 1 345:::. ( jC: M. MAGSTR I PE-PRODUCT I CiN P/REEL I I 1 0 : :3 0 . (:) ; 3 (1) (1) . (1) (: N. MACiSTR I PE-SCORE.~IDUEB I Nla/P/REEL : 10: :EX:) . 00 : E: (1) (11 . (1) c; 1 . I NTERNEGAT I VE a I 1.11: '.?50(:), (10 : 1 (11 5 4 5 . c:) (1: P. I NTERPOS I T I VE a a 1.11 1 C/5(:)0. 0(j : 10545. (I(:' 3. hNSWER PRINT ( INOL TAX) I I 1: 1 (:)(:I (:)(I) . 00 : 1 ocjOc:). (:)(I: R. CI:IMPI:ISITE CHECK PT ( INCL TAX ) : .- ? . .::A5 : 75(:)0. 510 : - 3(3E:7 . st:. :=7. FADE/DISSOLVE/DUPE/FINE GRAIN : 4C) : 13;). tj(:) : 60 00 . c:, (1: T. T ITLES-MAIN k END a I 1: 1 2(j(jo . (:I(:) : 1 2 (1) (1) 0 . (1) (I. 1-1. PROclECT ION-W ILDWOlSD ONLY-NC@LAE : :3 : 2(j (1) . C) (1) : 1 6 0 (1) . (1) (1: V. CI:I[I I NG-SYNC SOUND P / F T I I 1.5: -5'500. 00 : 14250. (:I(:. W . CClDING-W I L D TRACE P / F T t 6 1.5: c ~ e .. .-I(-)(-) - - . C)(] : 1 4 25(j . (:I(:: X. MOV I OLA RENTAL ( P/WK I I 24 : 150. 00: .- .:: 6 00 . (I) (I Y. REELS % LEADER (P/WK) 1 I -24 : 5(j . (j (3 : 1 2 (2 (1) . (1) -1 Z . C:UTT 1 NG ROOM !::llPPL 1 ES I I 24; 1 3 1 ) . (1) (1) : ::: 6. (1) (1) . i t r:
AA. STOIZK SHOTS I I 1: 3 (1) (1) (1) . 0 (1) : :3 0 (1) (1) . (1) EB. /:::EM h SUPPLY RENTAL I a 15: 1 y j0 . : 2:3 5 (1) (1) . (1) (1; CC. ED I TORIAL CREW OVERT I ME ( 10%) : 1 1 1 1 1 1275. (:)(:I
I I I t I I * (I)!T'
-----------------------------------'------------*---------------'-------------- 7- - -- -\ , . . I 1-1 i iz:!-!TT 1 :<::;, 1 - : , , L , - .Is;;& 7 .11fi)' : I a .=..:*q . ,. . --..:.,q - - Li . i
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ' - - - - - - - - - - - - ; - - - - - - - - - - - - - - - l - - - - - - - - - - - - - - -
ADVANCED MEDIA GROUP Page 58 of 76 05.03.2007
Advanced Media Group Page 124 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 180 of 198 Monday, November 23, 2015
![Page 181: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/181.jpg)
_____- -____________- - . - - - - - - - - - - - - - - ' - I - - - - - - - - - -~ - - - - - - - - - - - - - - - ' - - - - - - - -_
I I I
1 5 . MI-1;:; 1 11: : I I < 1
I 0 0 I
A. FF\'ENII:H L I C:/:::-l::l~l:~;T TlIl C:lIlMF'LETE : 1 I 1 2 (1) (1) (1) (:I (:I : I 2 (1) (11 (:) (1) . (11 B. I_II\I~IER:~C:IIIRE-I~:I~I:~T TI] C:l:lMF'LETE I I 1 I :::(:I (1) (11 (1) . (:) (1) : :3 (1) (1) (1) (1) , (11 C. TRANSFER.:; I I . (1)::: : 1 5 (1) (1) . (1) 1 4 5 (1) . (1) [I. :sTIIIC:t:x (TAX 1NC:LIJDED) I I . U s - . - 1- .:. .-a '2 .. I I 1 5 (1) (1) (1) . 0 (1) : .a .. c.-, .-I.> . c .-t
E. ED IT INO (P/REEL) I I 1 0 : 1 (1) (1) (1) . 00 : 1 (:)(1)(1)(:) . (1)
F. M I :f;rZELLANElSUS ( 5% ) I I I I I a . (-) I I I I I I . (-1
----,------------------------------*------------*---------------;-------------- TOTAL MI-IS1 C:: I I I I I I 1rCa140:_:. 5 -----------------------------------;------------l---------------'--------------
I I I I I I
1 (-. . ::;ilUND : I I I I t I
I I I I I I
A. Dl-ISBING ROOM RENTAL I I 22; 20(j. 05, : 4 4 0 (1) . E. LABOR FOR PRE-DUB, ETC (HHS) t 18: 4 C) (1 . c) : 7 2 (1) (11 . (1) C. LAPIIR FOR DUB ( 3 MIXER/30 HR) : 90 : /; (1) (11 . c j (1) : 54(:)(30. (1) D. F'OWER STATION @ ADD 50% I I I
I I I .-* .Xs-/ A a-m C* (-1 - (1) . i) E. SOUNF FX PACKAGE (P/REEL I I 1 0 : z[;)(j(:) . (1) f-1 : 5 (1)(:) (1) (11 . (1) F. STOCK (PRE-DUB P/ROLL INCL TX) : 101 26.4.3 : 24.t.. c Y
I . STOCK (DUE P/ROLL I N C L TX) I I 10: 63. 5'[3 : c.:35' . (1.
H. ADR, LClOPI NG, NARRATICIN (P/HH) I I 36 : 250. @(I : 9(1) . (1
I . !STOCK ( RENTAL I I 10: 215. (30 : 250. c
J. TRANSFERS (P/HH) I I 15: 75.00 : 1125. c K. STOCK INCLIJEIING TAX I . C)2(s.b : 3 (1) (3 (1) (3 . (1) (1 : 798. 0
, L. L ~ I C ~ P ELI I TOR:?; I I 1: .-. .:. .-, s= (1) (1) . (1) 0 : 35 CHI . (1) M . WALLA GROUP I 1: :3(j(j(:). 00 : 3 C 1 0 (1) . 0 N. FOLEY (SOILNTI FX/HR) I
I 45: 2 5 (3 . (1) (11 : 1 1250. CI 0. STOCK (RENTAL) - 1 1 10: .-, L c -1 . (:)C) : 2 5 (3 . (11 P. TRANSFERS ( HOURS I I 15: 75. 00 : 1125. (3 I!. STOCK INCLUDING TAX a I .02&.4 : 3(:)(:)(5 (1) . o(:) : 7.33. c:
; R. FOLEY WALKERS (HRS) I I 36: L O . 0~:) : 2 1 6, (1) . (1) S. DUPE TRANSFER I
I 3 : 7 5 . (1) (1) : 6. (1) (1) . (I! T. STOCK 1NC:LUtIING TAX I I .026G : 3:) 0 (1) 0 . (1) (3 : 7 a- 9 #-, c. . (-! ..
11. SCREEN I NG ( F/HR ) I I 8: .-I (-1 - . (1)~:) : 4 (11 (1) . (:! I I I I 1 I . C!
-----------------------------------;------------1---------------*--------------
TCITAL SI:ICIN[I: I I I I I 1 :34359. ::: -----------------------------------+---------;---------------a--------------
I I I I I I
I I I- I I I
-----------------------------------;------------s---------------t--------------
GRAND TOTAL CI_ITTING/FILM/LAB I 1 I I I I /.7*5"39 1 . 9 ...............................................................................
ADVANCED MEDIA GROUP Page 59 of 76 05.03.2007
Advanced Media Group Page 125 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 181 of 198 Monday, November 23, 2015
![Page 182: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/182.jpg)
17. F'l-1tLIC:ITY: : G!I-/ANT I TY I RRTE I I T 111 T ii L
I I 8 I
A. AKIVERT 12; I NG I I I I I I . (.
E. 1-IN I T F'I-IBL I C: I TY F'ER::;l:lN I I I I 1 I . (:
C:. ENTERTAINMENT I I I I I I . (1
[I. TRA[IE/NEWSPAPER SUBSCR 1 PT IONS : I I I I . i E. PI-1BLIC:I TY ST I L L S SALARIES I a 1 I I I . (: F. PI-IFL I C: I TY ST I L L S St-IPPL I ES/EQI_I I P : I I I I . (. 13. F'I1FLIII:I TY ST1 LLS LAB CHARCiES I I 1 1 t I . (. H. S T I L L GALLERY RENTAL/EXPENSE : I I I I . (: I. TRAILER I 1 I 8 I . 1: .-I. PRESS PREVIEW EXPENSE 1 8 1 I 1 I . (. I:::. SUPPL IES/PnSTAC;E/EXPRESS t I 1 8 1 a . i L . MI SI:ELLANEIII-IS I I I I I I . i M. OTHER I I I I I I . i N. OTHER 0 I t I t I . (: 0. OTHER I I a I 1 1 . (:
I I I I I I . (1
TOTAL PUBLIC I TY: 1 a I I 4 I . ( -----------------------------------;------------;--------------- -
I I I I I I
18. MISCELLANEOUS I I a I 4 8
I I I I
A. VACATION ALLOWANCE (DGA) I I .a7292 1 B. RETROACTIVE WAGE CONTINGENCY : I I a , . t C. SI-INDRY UNCLASS I F I E t I EXPENSE 1 1 8 I 4 1
D. CIIISTS IN SUSPENSE ( E PEETERS) : 1 : ( 50 , oo(:). (I(:) ) , I I . . E. SET COFFEE a I 8: k. CI . O C ) : 4 ::: (11 0 . ( F. WATER .% .ICE I I S : 6 (1 (1 . (3 (:I : 4:30 (1) . ( 13. OTHER I I I a I I . (. H. OTHER a t a I a I . (. I ; OTHER 0 I 8 1 1 t . (1
I I I I I I . C
TI~TAL M I SlZELLANEl:lU!:: : I I I I I I 19121 mi
I I I
I I I
1 F/. 1 NSURANC:E/TAXE!E;/L 1 CENSE/FEE!Z: : I I I I
CAST 1 N!slJRANC:E NEGATIVE 1NSURAblrI:E L I FE I N:XIRANCE M I SC:ELLANEI~I-I!~ 1 NSI-IRANCE I::OMF' Zc PI-IELIC: L I A B I L I T Y INS S1:rCIkL :3ECI-IR 1 .rY T&X F'ERSONAL PRlItPERTY 1 NSLIRANIZE W1IlRk::ER .':f; C:I]WFENSAT 1 IIIN TAX 1I:IltIE C:ERT I F I C:ATE - MPAA CITY TFiX AND LICENSE 1-INEMPLI:I\'MENT TAX ( I T A T E IINEMF'LIIYPIENT TAX ( FED) HZrW/F'ENS I ON-NAFET ( F'/EIY ) F'ENyZ; I ON F'LAN-C!IIi# ( 5 . 7(:):3% )
. (.
. (
. ( 7.5 (1) (:) (1) . (
. (. &.&,27:3. ?.
. ( 43:::45. :-
:::(:I ( I ) ( I ) . I . (
-=, 4 7.~ -2 .-. _ j.-. . 1
7 4 1 5 . '. 74(:)91:) . ;
7 4 5:::
ADVANCED MEDIA GROUP Page 60 of 76 05.03.2007
Advanced Media Group Page 126 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 182 of 198 Monday, November 23, 2015
![Page 183: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/183.jpg)
1 F'AYROLL :!;ERVIC:E ( WA IVELI ) I I
N. NI::;~::ELLANEI:II-I::: I I
1-1. CITHEK t , F'. OTHEFi I I
I:!. OTHER I I
I
. 4.
I I I I a . c ----------------:------------:---------------:--------------
TOTAL IN:SI-IF(ANCE/TAX /L IC:ENSE/FEES: i I 1 I - 4
. -; 1 1 ::- .=: 1 . .: - -I._ L
- - --------------------I------------:---------------:--------------
I I
20. GENERAL 1:lVERHEAD: I I
A. F L A T C:HARGE I I
E. C:CIHF'ORATE OVERHEAD EXPENSE I I
C. CASTING O F F I C E S A L A R I E S I I
D. ENTERTAINMENT-EXECUTIVES , t I
E. TRAVEL EXPENSE-EXECUTIVES I I
F. S F F I C E RENTAL AND EXPENSE/P MO I F1. O F F I C E RENTALS/SUPPLIES/P WK : G. AUDITClR I I
H. T IMEKEEPER I I
I. SECRETAKI ES 8 I
.-I. PUBL I i: RELATIONS HEAD I I
1::. P U B L I C RELATIONS SECRETARY I I
L. LEGAL FEES ( P / H R ) I I
M. FOSTAGE/TELEPHONE/P W E I I
N. CIJST1:lMS BROKERAGE I I
O. GENERAL OFF I C E OVERHEAD e I
P. F I L M S H I P P I N G a I
r T. OTHER a I
1-1. OTHER 0 I
V. ClTHER I I
I I I I I . O -----------------------------------:------------:---------------;-------------- TOTAL GENERAL OVERHEAD: I I I I I --< .C "
I & -1,:. (I(:) . .; -----------------------------------,------------:---------------:--------------- I I I 1 I I
21. F INANCE I I I I
A. S ROE I I .05: 4 0 (1) 0 0 0 0 . (1 0 : 206 :)00. (I( I
I I .a275 1 4000000. 00 : 1 1 )(IC)C). (11,
C. Cl~lMPLET I O N Bi:lNu-Nl:l C L A I M S I .c)275:(4(~[~o[:)[:)(:).i)~:)) : t . o( I
n. CONT 1 NGENCY I I .l: :33/.7.5[:)2. 00 : 33/-.75[:). 2: I I I I
I
-----------------------------------o------------:---------------:--------------.
GRAND TOTAL BELOW THE L I N E I I I I I I I(:) 11(-).52 . 9;
__------------------------ ---------- ---___-------------------------------------- / 7'-
ADVANCED MEDIA GROUP Page 61 of 76 05.03.2007
Advanced Media Group Page 127 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 183 of 198 Monday, November 23, 2015
![Page 184: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/184.jpg)
May 21, 1987
Mr. Stan Caterbone Financial Management Group 1755 Oregon Pike Lancaster, Pa. 17601
Dear Stan:
At your request I've investigated the requirements of the Comple- tion Bond.
Bert Schneiderman of Worldwide Completion Services in New York has given me a figure of 5+%, excluding contingencies, with a 50% No Claims Bonus. Since Bert also owns BonBon Payroll Service he has agreed to waive the payroll fee if we use their bonding service,
Requirements: They need copies of the budget and/or production board, resumes for the director and producers as well as copies of their contracts and any other production agreements which have been completed.
Further they need to know when we will commence principal photo- graphy, editing location and if we intend to have a distribution deal up front.
I spoke to Jerry Vandersonde and Bill Hudson of DeWitt Stern In- surance in Los Angeles, who were recommended by Worldwide. Since I couldn't show him a budget or a script we did some educated guessing and came up with a figure of approximately $75,000. The Production Package policy should include: General liability, cast insurance, negative film, faulty stock and camera processing, props, sets, wardrobe, rented equipment, extra expenses, third party property damage, non-owned auto, Errors and Ommissions including a one year bond and a minimum workmen's comp policy for anything that is not covered by workmen's comp.
I understand you're going to Wildwood this weekend. We need to house a crew of about 60-80, production offices, catering service. We'd like to get as many free extras as possible and need high quality promo type giveaways. For screen credit, of course. If you have any such contact we'll need mutant dolls (500?) and if you can h ~ l p brinq dow? lor~'<cn costs that would be great. I'm tzikrng about beaches, aricsezents, the pier, parking facilities. p:-ob~L T Y - 3 h?~?!'= f5=* 1 pkr SCII .
ADVANCED MEDIA GROUP Page 62 of 76 05.03.2007
Advanced Media Group Page 128 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 184 of 198 Monday, November 23, 2015
![Page 185: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/185.jpg)
FLAT
M s . E l l e n Libman Power S t a t i o n , I n c . 4 4 1 b 7 e s t 5 3 r d S t r e e t N e w York, N . Y . 10019
Dear E l l e n :
B a r b a r a and I h a v e mapped o u t a s k e l e t o n s c h e d u l e f o r o u r t r i p t o N e w York and I t h o u g h t I ' d s e n d i t o f f and see i f i t works f o r e v e r y o n e e lse . By t h e way, w e ' v e d e c i d e d t o s t a y i n N e w York u n t i l Tuesday i n s t e a d o f Monday a s o r i g i n a l l y p l a n n e d .
Thur sday A r r i v e a b o u t 3:OOPM. You have t h e e x a c t t i m e s i n c e y o u ' v e booked o u r f l i g h t s . P l e a s e l e t u s know i f someone w i l l p i c k u s u p o r i f w e s h o u l d t a k e a t a x i .
W e ' l l come t o Power S t a t i o n an? g i v e you and Tony c o p i e s o f t h e s c r i p t and b u d g e t which we 'd l i k e you t o r e a d Thursday n i g h t .
B a r b a r a and I h a v e a d i n n e r m e e t i n g w i t h a Direc- t o r o f P h o t o g r a p h y .
F r i d a y Leave f o r N e w J e r s e y i n t h e morn ing . D i s c u s s s c r i p t and b u d g e t . Meet Mayor o f Wildwood and b r i n g him a s y n o p s i s o f s c r i p t wh ich h e h a s r e q u e s t e d . Meet w i t h S t e v e G a r e l i c k , t h e P r o d u c t i o n C o o r d i - n h t o r o f t h e N e w J e r s e y F i l m Commission. Look a t l o c a t i o n s .
- S a t u r d a y S t a n C a t e r b o n e a r r i v e s i n New J e r s e y . Meet t h e Sunday r e p f rom M a u r y ' s P i e r t o d i s c u s s l o c a t i o n costs.
Check o u t h o t e l s f o r c r e w and c a s t .
Monday L a s t m i n u t e S e t a i l s i n N e w J e r s e y . Leave f o r Mew York a r o u n d noon.
Tuesday M e e t i n g s a t Power S t a t i o n f o r f i n a l d i s c u s s i o n s a b o u t s c r i p t , b u d g e t , c o n t r a c t s , e t c .
Tuesday A f t e r n o o n - Leave N e w York a p p r o x i m a t e l y 4 F Y t o a r r i v e Los A n g e l e s a b o u t 9PM.
I ' l l t a l k t o you a g a i n b e f o r e w e l e a v e i n p l a n n i n g y o u r s c h e d u l e s .
4334 STERN M.. SHERMArd OAKS. C A 91
cc: S t a n C a t e r b o n e (616) 905-3C;7 B a r b a r a P e t e r s ADVANCED MEDIA GROUP Page 63 of 76 05.03.2007
Advanced Media Group Page 129 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 185 of 198 Monday, November 23, 2015
![Page 186: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/186.jpg)
M s . Ellen Libmn Power Station, Inc. 441 West 53rd Street NAJ York, N.Y. 10019
FIATBUSH
D e a r Ellen:
F
Let's t r y it again. This time we are scheduled to leave Los Angeles on Thursdzy, 3~12 4 =id r2tu.m t3 L3s Arigsles cii T~esZa-;. , 2.,z?e 9. 3.e f o l l m h g is a rough schedule.
LMS, NC.
Friday
Arrive a b u t 3:OOPM. Please l e t us know the exact f l ight information as soon as possible so we can arrange aAprt transprtat ion here. L e t us h o w if sa-neone will pick us up in New York or if we should arrarge t r ampr ta t ion to Power Station. Also l e t m e krvJw what hotel we w i l l be booked a t in New York so we can leave that information here.
We'll ccrne to Power Station for any discussion r e g a r m the scr ipt and/or budget.
Barbara and I have a dinner meeting with a D i r e c t o r of Photography.
Leave for New Jersey in the ~mrning. Meet with Steve Gorelick, the Production Coordinator of the New Jersey Film Carmission. Look a t locations.
Saturday Stan Caterbne arrives in New Jersey. Meet the rep -Y £ r a n Maury's Pier to discuss location costs.
Check out hotels for crew ard cast. -
Iast minute detai ls in New Jersey. Ieave for New York a m u d m n . Meetings a t P a e r Station for final discussions about script, budget, mtracts, etc.
Additional meetins in mrning if necessary. W v e New York appr-tely 4R.I to arrive Los Angeles about 9R1.
Please l e t m hxx if y m have any additions or changes. I 'll probably talk to w u again on Wrday.
wards, cc: S t a n Caterb31le
Barbara Peters Arlene 4334 STERN AVE., SHERMAN OAKS. CA 91423
(818) 995-3417 ADVANCED MEDIA GROUP Page 64 of 76 05.03.2007
Advanced Media Group Page 130 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 186 of 198 Monday, November 23, 2015
![Page 187: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/187.jpg)
FLATBUSH F IMS, NCl
June 1 2 , 1987
Mr. Stan Caterbone Financial Management Group 1755 Oregon Pike Lancaster Pa. 17601
Dear Stan:
As you requested here's a schedule for Project 441 (mrking t i t le):
P F E - P r n C r I O N June 28-Julv 11, 1987 New York July 12-Sep't 5 , . 1987 New Jersey 8weeks
New Jersey
POSFPRODUCTION Nwenber 1-January 30,1988 New York
8 5 day weeks
In order to still get the film made this season we've got to speed everythug up. W e originally planned four weeks of pre-production in New York lxlt that's rn longer possible. If we start June 28 we've got only ten weeks to get the mutant effects going a d then w e ' l l have to schedule mutant scenes later in the film i f they aren' t ready.
This schedule also takes us to October 31 for the end of the shoot, which means we've got to schedule exteriors f i r s t , leaving the interiors for later in the wen t of bad weather.
S i x e we're on such a t igh t schedule I can't really break down the costs for you because it w i l l a l l start happnhg so quickly. W e ' l l imnediately have a New York office, per dim, btel and coneacted fees for Barbara and myself. W e ' ll hire a casting director, production manager, prduction coordinator ard location manager, get the mutant effects started a d begin hiring key personnel. I f p check the m e t you'll see the actual number of weeks of employrent for new. There w i l l be legal fees for pcepariq contracts. Wing those tm weeks we' ll hopefully do mst of the casting.
4334 STERN A N . , SHERMAN OAKS. CA 91423 (818) 995-3417
ADVANCED MEDIA GROUP Page 65 of 76 05.03.2007
Advanced Media Group Page 131 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 187 of 198 Monday, November 23, 2015
![Page 188: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/188.jpg)
IXlring the eight weeks of pre-production in N e w Jersey we'll be m r m with the art director, costane designer, s e t decorator, building sets , tying d m locations, e tc . A week before shooting the f u l l crw w i l l be prepping. The editor w i l l arrive a t about that lime and w i l l be mrlung on a rough cut during the entire shooting period.
A t the close of production Barbara, the editor an3 I w i l l m e back to New York for a three mnth editing period a t the en3 of which we will deliver the finished film, includmg distr ibutor 's requirements an3 the MPAA rating.
As you can see this w i l l be very tricky but I still think we can do it i f Barbara ard I are in New York no la te r than June 28.
Hope this helps.
cc: Tony Bongiovi Barbara P e t e r s
ADVANCED MEDIA GROUP Page 66 of 76 05.03.2007
Advanced Media Group Page 132 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 188 of 198 Monday, November 23, 2015
![Page 189: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/189.jpg)
Advisory, Inc. r C- 11. 7755 Oregon Pike Laocaster, PA 17607 777-569-4100
ftYAWCUI NANICrMtUI U O U P LID
STANLEY J. CATERBONE PRESIDENT
May 29, 1987
Mr. Joel ~oidhammer Sidel, Gonda, Goldhammer, Abbott 2 Penn Center Suite 1800 Philadelphia, PA 19102
Dear Joel:
I received the enclosed correspondence regarding Power Station Studio. I have yet to have a chance to review this, however, I thought it might be helpful. Please keep all of this on file as confidential and please do not make any communications with anyone until I learn more about the situation.
Power Station does not know that I have you working on this yet.
Good Luck. a
Sincerely,
Stanley J. Caterbone
SJC:lmk CC encl
ADVANCED MEDIA GROUP Page 67 of 76 05.03.2007
Advanced Media Group Page 133 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 189 of 198 Monday, November 23, 2015
![Page 190: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/190.jpg)
LAW O f FICES w- --- L
SEIDEL, GON DA, GOLDHAMMER & ABBOTT, P. C. PATENT A N D T R A D E M A R K A T T O R N E Y S
SUITE 1800 TWO P E N N C E N T E R P L A Z A
PHILADELPHIA. PA. 19102
ARTHUR H. SEIOEL
JOEL S. GOLDHAMMER MICHAEL P. ABBOTT - GREGORY J. LAVORGNA
DANIEL A. MONACO
RO9ERT H. HAMMER Ill
THOMAS J. DURLING
STEPHEN J. MEYERS AMANDA LAURA N Y E *
NANCY A. RU9NER
SCOTT J . FIELDS
2 5 J u n e 1987
TELEPHONE:(PIB) 5 6 8 - 8 3 8 3 -
TELEX: 8 4 5 - 2 1 6
CABLE: SIPAT
T E L E C O P I E R . ( P I S I 568- 5 5 4 9
G R O U P I , I 1 6 1 1 1 -
EDWARD C. GONOA
( 1 9 3 0 - 1 9 8 5 ) - OF COUNSEL
SYLVIA A. GOSZTONYI STANLEY H. ZEYHER
* D C 6 NY BARS ONLY
M r . S t a n l e y C a t e r b o n e FMG A d v i s o r y , I n c . Eden P a r k I1 1 7 5 5 Oregon Avenue L a n c a s t e r , PA 1 7 6 0 1
R E : Power S t a t i o n Our F i l e : 7351-G
D e a r S t a n :
C I h a v e n o w r e c e i v e d t h e r e s u l t s o f a s e a r c h p e r t a i n i n g t o t h e a b o v e s u b j e c t . I h a v e a l s o r e v i e w e d t h e f i l e f o r w a r d e d w i t h y o u r l e t t e r o f May 2 9 . T h e f o l l o w i n g i s my a n a l y s i s a n d e v a l u a t i o n o f t h e r i g h t t o u s e "Power S t a t i o n " a s - d e f i n e d be low.
A s I u n d e r s t a n d t h e s i t u a t i o n , y o u r b u s i n e s s c l i e n t , Power < t a t i o n S t u d i o , h a s , s i n c e 1 9 7 7 , o p e r a t e d a r e c o r d i n g s t u d i o w i t h a w i d e l y r e g a r d e d r e p u t a t i o n f o r p r o v i d i n g h i g h q u a l i t y r e c o r d i n g s e r v i c e s u s i n g s t a t e o f t h e a r t e q u i p m e n t . The e n c l o s e d r e p o r t r e v e a l s t h a t Power S t a t i o n s t u d i o h a s r e g i s t e r e d t h e t r a d e m a r k "Power S t a t i o n " f o r s o u n d r e c o r d i n g s t u d i o s . ( S e e Reg. No. 1 , 4 3 3 , 3 2 8 r e g i s t e r e d March 1 7 , 1 9 8 7 . ) You h a v e a s k e d m e to i n v e s t i g a t e t h e p o s s i b i l i t y o f Power S t a t i o n e x p a n d i n g t h e u s e o f i t s mark i n t o m e n ' s a n d women's c l o t h i n g i n c l u d i n g b e a c h w e a r ; a n d f o r a u d i o a n d v i d e o e l e c t r o n i c s f o r c o n s u m e r s a n d p r o f e s s i o n a l s . I h a v e a s s u m e d t h a t t h i s l a t t e r c a t e g o r y i n c l u d e s r a d i o s , t e l e v i s i o n r e c e i v e r s , v i d e o c a s s e t t e r e c o r d e r s , a u d i o r e c o r d e r s , c o m p a c t d i s c p l a y e r s , t u r n t a b l e s , a m p l i f i e r s , r e c e i v e r s , t u n e r s , c o n t r o l p a n e l s , m i x i n g b o a r d s a n d c o n s o l e s , among o t h e r t h i n g s .
B a s e d upon t h e r e s u l t s o f t h e e n c l o s e d s e a r c h , i t is my o p i n i o n t h a t i t would b e i n a d v i s a b l e f o r Power S t a t i o n , I n c . t o u s e i t s mark f o r c l o t h i n g a s a f o r e s a i d . The b a s i s f o r my
ADVANCED MEDIA GROUP Page 68 of 76 05.03.2007
Advanced Media Group Page 134 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 190 of 198 Monday, November 23, 2015
![Page 191: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/191.jpg)
M r . S t a n l e y C a t e r b o n e
- ~A
2 5 J u n e 1 9 8 7
o p i n i o n i s R e g i s t r a t i o n No. 1 , 4 3 1 , 2 4 2 r e g i s t e r e d M a r c h 3 , 1 9 8 7 f o r "Power S t a t i o n " . The r e g i s t r a n t c l a i m s a f i r s t d a t e o f u s e o f A p r i l 3 , 1 9 8 6 f o r w o m e n ' s c l o t h i n g i n c l u d i n g s w i m w e a r a n d o t h e r g o o d s a s l i s t e d .
A l t h o u g h y o u r c l i e n t h a s a s t r o n g r e p u t a t i o n , a n d a l t h o u g h i t h a s p r i o r i t y o f u s e f o r t h e m a r k , t h i s r e g i s t r a n t h a s a s t r o n g p o s i t i o n f o r a r g u i n g t h a t i t h a s s u p e r i o r r i g h t s f o r women's c l o t h i n g . One would n o t o r d i n a r i l y a s s o c i a t e c l o t h i n g i n a n y way w i t h r e c o r d i n g s t u d i o s e r v i c e s . T h u s , y o u r c l i e n t ' s r i g h t s i n i t s m a r k d o n o t a p p e a r t o d o m i n a t e t h o s e o f t h e r e g i s t r a n t ' s . A c c o r d i n g l y , u s e o f t h e Power S t a t i o n mark f o r women's ( o r m e n ' s ) c l o t h i n g would i n v o l v e a s i g n i f i c a n t r i s k o f b e i n g a c c u s e d o f t r a d e m a r k i n f r i n g e m e n t .
Use o f t h e P o w e r S t a t i o n m a r k f o r c o n s u m e r a n d p r o f e s s i o n a l a u d i o a n d v i s u a l e l e c t r o n i c e q u i p m e n t raises some i s s u e s , b u t o n t h e w h o l e I am o f t h e o p i n i o n t h a t i t i s p e r m i s s i b l e . A g a i n , I a s s u m e , a s I h a v e b e e n i n f o r m e d , t h a t t h e P o w e r S t a t i o n s t u d i o i s w e l l k n o w n a n d d o e s h a v e a g o o d r e p u t a t i o n f o r i ts e x i s t i n g s e r v i c e s . G i v e n t h a t , i t s movement i n t o e l e c t r o n i c e q u i p m e n t s h o u l d b e p e r m i s s i b l e . Here t h e g o o d w i l l a s s o c i a t e d w i t h i t s c u r r e n t s e r v i c e s c a n b e more r e a d i l y e x t e n d e d t o a u d i o v i s u a l e l e c t r o n i c e q u i p m e n t .
T h e s e a r c h r e v e a l s t h a t M a n v i l l e C o r p o r a t i o n ' s Ken C a r y l Ranch is t h e owner o f t h e mark "Power S t a t i o n " f o r b a t t e r y o p e r a t e d e m e r g e n c y e l e c t r i c a l power s u p p l y u n i t s . S e e Reg. N o . 1 , 0 4 0 , 3 9 8 r e g i s t e r e d May 2 5 , 1 9 7 6 a n d c l a i m i n g a f i r s t d a t e o f u s e o f November 2 3 , 1 9 7 0 . I n my o p i n i o n , a u d i o v i s u a l e l e c t r o n i c e q u i p m e n t c a n b e c o n s i d e r e d t o b e s u f f i c i e n t l y u n r e l a t e d t o e m e r g e n c y e l e c t r i c a l power s u p p l y u n i t s t o a v o i d a l i k e l i h o o d o f c o n f u s i o n e v e n t h o u g h t h e m a r k s a r e i d e n t i c a l .
I r e a c h t h e s a m e c o n c l u s i o n r e g a r d i n g t h e p e n d i n g a p p l i c a t i o n by E l e c t r i c a l C o n d u c t o r s , I n c . f o r a m u l t i p l e o u t l e t p o w e r s t r i p .
A c l o s e r q u e s t i o n is r a i s e d by G o u l d ' s S u p p l e m e n t a l R e g i s t e r r e g i s t r a t i o n f o r P o w e r S t a t i o n f o r m i n i a n d m i c r o c o m p u t e r s . G o u l d ' s mark is r e g i s t e r e d o n t h e S u p p l e m e n t a l R e g i s t e r u n d o u b t e d l y b e c a u s e " P o w e r S t a t i o n " a s a p p l i e d t o c o m p u t e r e q u i p m e n t i s c o n s i d e r e d t o b e d e s c r i p t i v e . A S u p p l e m e n t a l R e g i s t e r r e g i s t r a t i o n h a s n o n e o f t h e p r o c e d u r a l b e n e f i t s o f a P r i n c i p l e R e g i s t e r r e g i s t r a t i o n . M o r e o v e r , i f G o u l d ' s u s e of t h e mark is l i m i t e d t o a p a r t i c u l a r m a r k e t w h i c h
ADVANCED MEDIA GROUP Page 69 of 76 05.03.2007
Advanced Media Group Page 135 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 191 of 198 Monday, November 23, 2015
![Page 192: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/192.jpg)
M r . S t a n l e y C a t e r b o n e
A
25 J u n e 1 9 8 7
is d i s t i n c t f r o m y o u r c l i e n t s , t h e r e d o e s n o t a p p e a r t o b e a l i k e l i h o o d o f c o n f u s i o n . T h u s , G o u l d may b e s e l l i n g i t s c o m p u t e r s i n t o a s p e c i a l i z e d c o m m e r c i a l m a r k e t i f i t is p r e s e n t l y s e l l i n g c o m p u t e r s a t a l l .
Nex t I c a l l y o u r a t t e n t i o n t o t h e f a c t t h a t s e v e r a l r a d i o s t a t i o n s h a v e a d o p t e d a n d a r e u s i n g t h e t r a d e m a r k " T h e P o w e r S t a t i o n " i n v a r i o u s c i t i e s t h r o u g h o u t t h e U n i t e d S t a t e s . C o n c e i v a b l y , t h e s e r a d i ' o s t a t i o n s c o u l d o b j e c t t o t h e i n t r o d u c t i o n o f c o n s u m e r e l e c t r o n i c s i n t o t h e i r m a r k e t a r e a on t h e g r o u n d t h a t t h e u s e o f t h e same mark i m p l i e s s p o n s o r s h i p by them. I n o t e t h a t a l l o f t h e s e m a r k s were r e c e n t l y r e g i s t e r e d , a n d I s u s p e c t t h a t a l l o f t h e s e r a d i o s t a t i o n s a r e r e l a t e d o r commonly owned. I a l s o s u s p e c t t h a t t h e a d o p t i o n o f t h i s ark may b e o f r e c e n t v i n t a g e . T h u s , y o u r c l i e n t i n a n y n e g o t i a t i o n w i t h t h e s e p e o p l e would h a v e t h e a d v a n t a g e o f b e i n g a p r i o r u s e r , a n d t h e r e l a t i o n s h i p b e t w e e n r e c o r d i n g s e r v i c e s a n d e l e c t r o n i c e q u i p m e n t o n t h e o n e h a n d a n d r a d i o s t a t i o n s e r v i c e s a n d e l e c t r o n i c e q u i p m e n t o n t h e o t h e r h a n d i s a t l e a s t c o - e q u a l . T h u s , y o u r c l i e n t s h o u l d h a v e t h e d o m i n a n t p o s i t i o n .
I n v i e w o f t h e f o r e g o i n g , i t i s my o p i n i o n t h a t The Power S t a t i o n s h o u l d n o t a d o p t o r u s e "Power S t a t i o n " f o r m e n ' s a n d women 's c l o t h i n g , b u t i t may a d o p t a n d u s e t h e m a r k f o r p r o f e s s i o n a l a n d consumer e l e c t r o n i c s a s d e s c r i b e d a b o v e w i t h t h e u n d e r s t a n d i n g t h a t t h e m a t t e r is n o t e n t i r e l y w i t h o u t d o u b t a n d i s s u e s c o u l d a r i s e . I t i s , h o w e v e r , my o p i n i o n , b a s e d upon t h e f a c t s p r e s e n t l y a v a i l a b l e t o m e , t h a t T h e P o w e r S t a t i o n , I n c . s h o u l d p r e v a i l i f t h o s e i s s u e s a r i s e .
I f y o u h a v e a n y q u e s t i o n s c o n c e r n i n g t h e f o r e g o i n g , p l e a s e f e e l f r e e t o c a l l m e .
W i t h k i n d e s t p e r s o n a l r e g a r d s ,
S i n c e r e l y y o u r s ,
SEIDEL GONDA, GOLDHAMMER & ABBOTT, P. C.
JOEL S . GOLDHAMMER
JSG:mp E n c l .
ADVANCED MEDIA GROUP Page 70 of 76 05.03.2007
Advanced Media Group Page 136 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 192 of 198 Monday, November 23, 2015
![Page 193: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/193.jpg)
JOINT Vf%TUilE PAKTICIPATICft AND CQflMBUTIQU
The unders igned , in tending to be l e g a l l y bound, i n considera t ion o f h i s
adInissim as a p a r t i c i p a n t in the j o i n t v e n t u r e to be known as "PWER PRO-
DUCTIONS I" an3 r e c e i p t o f a profit/loss d i s t r i b u t i o n share of % o f
such j o i n t venture, hereby dec la res ard aclcmwledges h i s i n t e n t to participate
i n such j o i n t venture and hereby covenants and agrees to a n t r i b u t e the sun of
$ to t h e c a p i t a l of such j o i n t venture, which sum s h a l l c o n s t i t u t e
h i s i n i t i d c a p i t a l account i n such j o i n t venture.
T h i s L e t t e r of I n t e n t is e n t e r e d i n t o by t h e unders igned upon t h e
following general under stand ing :
Power P r o d u c t i o n s I w i l l be a j o i n t v e n t u r e to be
formed under t h e l aws of P e n n s y l v a n i a , having t h e .,
s p e c i f i c purpse to inves t (loan) its funds to MUTANIA
PRODUCTIONS, INC. to f i n a n c e such c o r p o r a t i o n ' s
p r o d u c t i o n o f a mot ion p i c t u r e . The j o i n t v e n t u r e
s h a l l r e c e i v e f u l l repayment o f its inves tment from
MUTAXIA PRODUCTIONS, I N C . b e f o r e the d i s t r i b u t i o n o f
any p r o f i t s to any party. Thereaf ter , t h e j o i n t venture
s h a l l r e c e i v e 50% o f t h e p r o f i t s from s u c h m o t i o n
p i c t u r e , o f which 85% s h a l l be d i s t r i b u t e d to t h e
ADVANCED MEDIA GROUP Page 71 of 76 05.03.2007
Advanced Media Group Page 137 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 193 of 198 Monday, November 23, 2015
![Page 194: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/194.jpg)
mn-managing joint v e n t u r e r s ( inc lud ing t h e under-
s i g n e z ) and 15% s h a l l be d i s t r i b u t e d t o S t a n l e y J.
Ca te rbone a s t h e Eanaging J o i n t Venturer o f Power
P r o d u c t i o n s I. Tbe j o i n t venture s h a l l have a r i g h t of
f i r s t r e f u s a l to finance the next movie p r o d u c t i o n o f
MUTANIA PRWKTIONS, INC. and/or ' I W Y BONGIOVI .
Tfte ckdersigned qrees t h a t he w i l l execute and d e l i v e r a counter-
counterpar t o f t h e j o i n t venture agreement (which s h a l l be c o n s i s t e n t with the
above g e n e r a l u n d e r s t a n d i n g ) and t h a t h e w i l l execute and del'iver dl doc-
unents required far t h e j o i n t venture to elect not to be t a x e d a s a p a r t n e r -
sh ip .
Contemporaneous w i t h t h e execution o f t h i s Letter o f I n t e n t , the under-
r-3 signed is cmntributing 10% of h i s total agreed c o n t r i b u t i o n , or $ . 3 w i t h i n f i f t e e n ( 1 5) days f r a n t h e d a t e hereof, time being o f t h e essence, t h e
- undersigned s h a l l m n t r i b u t e t h e 90% balance, or $ . Such c o n t r i-
b u t i o n s h a l l b e h e l d by Stanley J. Caterbone a t i n t e r e s t , pending campletion
of alL nego t ia t ions ard execution ard d e l i v e r y of iii documents w i t h MuTA~IA
PRODUCTIa~S, INC.
I f such n e g o t i a t i o n s , d e l i v e r y , and execution are mt m ~ l e t e d wi th in
t h i r t y (30) days a f t e r the f u l l con t r ibu t ion is made, the e n t i r e con t r ibu t ion ,
w i t h all i n t e r e s t earned thereon, s h a l l be returned to t h e d e r s i g n e d without
demand. Stanley J. Caterbone shal l ' be r e s p o n s i b l e f o r c o l l e c t i o n , receipt,
i n t e r i m i n v e s t m e n t and management, and ul t imate investment or r e t u r n of al l
f d s m t r i b u t e d , and s h a l l be t h e Managing J o i n t V e n t u r e r o f t h e j o i n t
venture.
ADVANCED MEDIA GROUP Page 72 of 76 05.03.2007
Advanced Media Group Page 138 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 194 of 198 Monday, November 23, 2015
![Page 195: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/195.jpg)
The u n d e r s i g n e d h e r e b y a u t h o r i z e s and anpokers S t a n l e y J. Caterbone to
n e g o t i a t e , execute, and d e l i v e r a l l documents n e c e s s a r y or r e q u i r e d t o
implement t h e j o i n t v e n t u r e purpse and to t ake all other a c t i o n s an3 n q o t i -
ate , execute and d e l i v e r a l l o t h e r documents n e c e s s a r y or d e s i r a b l e t o
implement or e f f e c t u a t e t h e j o i n t v e n t u r e pnpose.
SIGN
NAME: (L.S . ) Date: May ,1987
NAME:
q ADDRESS:
CITY: STATE: ZIP:
I
ADVANCED MEDIA GROUP Page 73 of 76 05.03.2007
Advanced Media Group Page 139 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 195 of 198 Monday, November 23, 2015
![Page 196: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/196.jpg)
RICHARD C FOX' ('ADMn'TED ALSO FLORIDA)
RICHARD C. FOX, PC. ATTQRNEYS AT LAW
1015 ROBERTj VALLEY ROAD HARRISBURG, PENNSYLVANIA inlo
May 20, 1 9 8 7
M r . S t a n l e y J. Ca te rbone FMG Advisory , I n c . Eden Park 11, 1755 Oregon ' p i k e L a n c a s t e r , PA 17601
F o r P r o f e s s i o n a l S e r v i c e s r endered i n c o n n e c t i o n w i t h Power P r o d u c t i o n s I , i n c l u d i n g confe rence , p r e p a r a t i o n o f L e t t e r o f I n t e n t , and e x p r e s s m a i l i n g , .and fol low-up t e l e p h o n e check.
P r o f e s s i o n a l Fee 8
UdP.S.
ADVANCED MEDIA GROUP Page 74 of 76 05.03.2007
Advanced Media Group Page 140 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 196 of 198 Monday, November 23, 2015
![Page 197: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/197.jpg)
Ted Gotnillion, President
ADVANCED MEDIA GROUP Page 75 of 76 05.03.2007
Advanced Media Group Page 141 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common PleasPage 197 of 198 Monday, November 23, 2015
![Page 198: Recorded Case No. 15-10167 Lancaster County Court of Common Pleas COMPLAINT re Caterbone v Brunswick-Fitzwater-Lancaster Film COMPLAINT November 23, 2015](https://reader033.vdocument.in/reader033/viewer/2022042500/5695d2bb1a28ab9b029b84ba/html5/thumbnails/198.jpg)
Gomillion: mini-major in the heart of O N F OF; the rtlo\r inlereclirlg "\tarc~ol-the-art" facrlit~es in l iol l !uood IS rlie (;ornrllron St~rdro\, Ireaded h \ lilrn ~r~t lurtr ! veterarl Ted (iomrllion.
The cry-hurlding cortiplex prov~de\ otle o l the mort techr~o- logically ad~anccd courid \\age\ alorig with a 46-IIIIII burldrng contalnrng officec and editing \uites
The sound stage hac a 45-foot- wide. floor-to-ceilrng \creen. ceare 150 people and i e one o l the few re-recording ctagec arourid the world that 1s capahle of handling any type o f f i lm format. including 70mrn six- track discreet. or video.
Cor~~plen~er~trr~g the \ophr\tr- cated projection sy\teni 15 an equally advanced cout~d and dubbing syctem which provides flexibilitv and extremely accurate reproductron for re-recording or playback of anv eound format.
"We provide e\ery \errice. frorii pre-production. cound stage connectlone, location \ I ~ c > o t i n g and a l l p o \ t - production. In other words, we prorrde all cervicec and facilitiec as the major jtud~oc around town, hut at 3 fractiori of the co\t. That's why we corned the
By Ron Krueger
phrase ' n~ in i - rna jo r ' . " \ard Gon~rllron rn dctcr~hing his \I\I~IOS.
(;omillron production chief Adan1 (‘buck added tliar, "Al l they hare to do IS L.ortle in wrth a scrrpt and they can *alk out of here wrth a lir~rshed production. We have done work l o r cotnpaniec l'rorti all around the world, I ta ly, Mexico. The Philrppinet. the UK and rtlany tnore."
Ciomillion al\o taid. "LVc rake great prrde 111 our wtirk. e\pec~allv nur looprr~g facrlity lor foreign lilrnc."
(iornillion'c experience in the film industry cpanc 3 0 years ar~d r t~c ludes experience 111
product ron and post -production at hl(;M. Drcney. rodd A - 0 . C'olu~tihia. Warner. lInlrer5al. Paramout~t and 20th ('enturq Fox.
The executi\c f i lni-milker spent seven years at the Fox Studior, earned t w o Peahody Award\ for excellence, and was rnvolved with such notable productions as "Rally Round The Flag Pole". "State 1-arr". "let 's blake Lore". "F la~ i i~ng Star" and "Way Way Out ".
<iomillron also cpent time on \uch T V \eriec as "fhe Monroes". "Follow The Sun", and "Jessie James".
Ted Gomillion wac the firct to develop a mobile sound stlldio, a specla1 trarler urlrt that 15
equipped to project "dailies" and provide orr-locatior~ "loop- rng".
"Our unrque units hare proven to be a ver) valuable aceet arid have become a lucrati\e \ource o f revenue." \ard (iomil l ior~, who offered that the units habe been ured or1 Tiltnc such as Sam Peckinpah'c "Jr Ronner" ; "Ge t -Away" ; ( i t ) l d u y ~ l ' \ " ( i ra \ \ t iopper" . "The Cir~ccon~ (;ango; Harhrn Strercand'c "The blaln E\er~t" : " T o o 1 ate r h e I i e r o " ; "Grizzly Adarns" arid "Tom Horn". The round units have also been used by such television shows as "Canney & Lacev" and - .
"C'hipc" The (joniillion Studioe facrlr-
tles are SO coniplete that each 01 r r c prc>ductron ollicec can he (u\t about uced to live In while production i c in progress. kach I\ equ~pped u i th a hart1 and kitchen area and there ic also R rectarrratlt and cater ing f ~ ~ c i l r ~ v . Addit~onally, a \nu l l exerchc room complete urth rauna.
Hollywood weightr and jacurr~ ts a\ailahle lo production execirtl\es u o r k ~ r ~ g long hours.
-<iornillion own5 all of II\
burldrngc and tand, uhlch are o n McC'adden Place In I lol lyuood w ~ t h ~ n a short distance from nlarl) nlajor labc, sound stagec. Set and co \ tume rer l ta l companies and an excellent breu of the world famou\ "t4olly- mood" cigr~ which trtr in a \lately poeirron high in the tlolly\rood Hil l \.
The latect connection thar entrepreneur (i01111111011 ha\ jet up to round out hi\ lacllit) I\
called I'oct I'ro ( oriiplerror~ IIIL., *I11ct1 I\ 21 l r r l~ l r l~ lr lg k l l l l l ~ ~ l l l l \
v.III gi\c u\ a conlpic~c ;Irrarlpe- rllerlt
Good investment "Any film\ that hake had
major filming completed and ue feel that there i c a eood invest- - nient, our new financial agrec- metlt will give Ciomillion the opportunity of linichrng the p o s t - p r o d u c t i o n . " caid Gomillion.
"We \\rII ccir~lrr~rrc to cxpar~ll and add Inore properr\, hrrt ;]I
rhe moment. ire oller O I I ~ ot the I i r~cr t '~IIII~I-\IIIL~I~I\' ITI the hu\ine\\ and rrght III the r ~ l ~ ~ i d l e 01 Clollvwood."
ADVANCED MEDIA GROUP Page 76 of 76 05.03.2007
Advanced Media Group Page 142 of 142 Thursday, November 5, 2015
ENTERED AND FILED
PROTHONOTARY’S OFFICE
LANCASTER, PA
***Electronically Filed***
Nov 20 2015 06:18AM
Andrew Gamber
CI-15-10167
CI-15-10167 Lancaster County Court of Common Pleas Page 198 of 198 Monday, November 23, 2015