2016: After General Counsel of PNC and his agents, representatives, nominess and affiliates (including as it turned

out my mother’s lawyers, then elder lawyer, Carol Sikov Love a known affiliate of Robert Bernstien and my
mother’s other lawyer, Chase McClister 1) who together affirmed, adopted, and ignored blatantly retaliatory
and illegal conduct by PNC resulting in ther utterly indefensible violations of Pennsylvania’s POA law, 2

allowed his agents, representataives, and others known and not known retaliate against me for having asserted my
rights to assist my mother and seeking to ensyure she was not a victim of then criminal investigation of PNC known
as “Operation “ by allowing my disabled brother to engage in all manner of misconduct including taking out
significant cash withdrawals not consistent with my mother’s pattern of conduct at a time she had just learned of her
diagnosis and when her sons had just suffered consecutive strokes.

August 2016: My disabled brother and mother moved all her money out of a dollar bank account we established
toghere and then with malice reported me not my brother who was obviously engaging in financial exploitation of
my mother to protective services allowing my brother to take control of all her financial needs going forward. His
control over my mother’s accounts was overt and rife with red flags pre-and post-PNC that should have triggered
some protection for her but her own elder lawyer let her be preyed upon. No one did their duty.

From 2016 through the summer of 2020: EvE periodic statement infer that the alleged monthly assessment
charges were paid to the following: Arnhem & Neely AchDebit 200707 095039. Upon information and belief,
Citizens Bank conspired with the undislosed control persons of 5600 to process Account Recievable Conversion as
preauthorized ACHdebits without any legal basis to do so whatsoever. See events of this past week for detail. 3

This past weekend, I learned for the first time that at all relevant times, members of the control group of CB
conspired with the undisclosed persons of 5600 Munhall to defraud any tenant who was fraudulently to pay monthly
assessments or anything else to the illegitimate HOA. Specifically, at all relevant times Citizens processed the
monthly assessment as if it were a Electronic Funds Transfer properly authorized by the payee/bank customer by
mandatory notice and agreement thereof. At no time, was any payment to my the control group d/b/a Arnhem
Neely a covered payment under the EFC. At best, the co-conspirators the papered what are apparently at best
Account Receivable Conversion payments (i.e., using a voided check for a one-time transaction) as if it were a
properly authorized, legitimate ECF transaction. This ongoing misconduct cannot have occurred absent intent to
circumvent the financial system nor could it have happened absent active complicity on all sides of the transaction at
all relevant times.4

2
Both attoneys’ which I assisted my mother in retaining to protect her from my disabled brothers potentioan
financial exploitation at least violated the RPC in turning a blind eye to illegal, abusive conduct that foreseeably and
utlimtely caused, triggered, and aggravated my mother’s subsequent financial losses which are immendse and each
violaton of law,, rule, or regulation satisfies the standard for negligence per se. Specifically, my mother was in a
protected class who her lawywers had a duty to protect as did all financial institutions pursuant First, she was a
disabled, senior citizen thus she was at all relevant times a person in a protected class

both of whom had undisclosed conflicts and conspired with those that preyed upon my mother. e

is evidence of gross negligence per se both with respect to a director and officer breach of fiduciary duties as well
as for the purposes of a wrongful death suit. See a
3

4
See e.g., 12 CFR Part 1005 (Regulation E) , Section 103 Comments, CFPB.
https://www.consumerfinance.gov/rules-policy/regulations/1005/Interp-3/; see also,
https://files.consumerfinance.gov/f/201511_cfpb_compliance-bulletin-2015-06-requirements-for-consumer-
authorizations-for-preauthorized-electronic-fund-transfers.pdf viewed, Jan. 24, 2021; See also
https://wallethub.com/edu/ach-payment/11932
Aug Moved

August 12, 2019: Brother took EvE to Citizens to open a joint account. My mother is and was then industbaly
noticeably cognitively impaired and was 89 years old. My brother is noticeably impaired, yet Citizens apparently
did not hesitate to open a joint account transferring $18K from my motehr’s sole control to my brother as a joint
account holder. At no time was I party to this and in fact was unaware of the joint account until at least one-year
after the fact. I was amazed that Citizens’ did not treat this as red flag when I learned about it given that such
conduct is a well-known indicator of elder fraud.

Since at least early 2020: Large unusual charges for Amazon and other products that were not remotely consistent
with my mother buying habit and those credit card expenses were paid by my brother using my mother’s account.
Inddeed even after my mother’s death my brother was able to move $3,000 out of her bank account – not the joint
account -- to pay off his and my other’s brothers $3K credit card bill using my mother’s credit card. Not once to
my knowledge did anyone at Citizens or PNC point fingers at anyone other than me – a longtime public servant and
prosecutor as compared to my disabled brothers who were wholly supported by my mother and had not worked in
more than two-decades. L

Sept. 28, 2020: Obtained Ltr. of Admin. Short Form Certificate a

Sept. 29, 2020: Contacted Citizens Bank and spoke to Fahran Z. at the Squireel Hill branch. I notified him
that my mother died and I needed to close her accounts. I also stated that I thought I would probably open an estate
account with CB for simpliclty. He did not close her account on Sept. 29. Rather, he insisted records proving my
role and my mother’s death. I did not yet have an EIN given that I had just been appointed the Agent the day
before. As of at least that date, Citizens had constructive knowledge of my mother’s death and was mandated to
enter a DNE code to inform SSA of the death of its beneficiary. See Greenbook at p.

Oct. 1, 2020: Fahran and I exchanged several emails, where I successfully transmitted the death certificate and
short-form certificate but Fahran insisted that I must personally bring an original copy to the bank before anything
could be done. I also attempted to close the credit card account assoicateed with my mother’s checking account but
Fahran insisted that it would have to wait until I was able to personally appear. See emails, Fahran to Uve, Subject
Hi.

Oct. 2, 2020, Emailed Fahran with yet another pdf copy of the required papers because he claimed that the previous
copies were not legible. See Oct 2, 2020 Email -- Subject Here’s a better copy of the letter of Admin.

Oct. 4, 2020, my disabled brothers appeared at Citizens Bank without a letter of Admin or anything else and were
permitted to withdraw the passbook savings account by 2/3rds including a ½ each of the improperly deposited SSA
payment for October 2020.

Oct 5, 2020: I was able to personally appear at the Bank. Jay Luzer who I understand to be the branch manager,
told me that a second post-death social security payment had been deposited to my mother;s account on Oct. 4 and
that he told my brothers’ that they would have to pay back the estate or SSA.
The credit card was closed that date but I was told that I must contact another third party to obtain copies of the
credit cards statements which I required as my mother’s fiduciary. At no time was I offered nor did I ever see until
Jan. 24, 2020 a version of CB’s “Agreement and Disclosure Booklet” which by omission demonstrates that all
subsequent debits by fraudulent means were not even an option on that account and were processed by complicit
bank representatives as part of conspiracy with the control group of Imperial House.

October 5, 2020, Successfully transmit executed so-called Preauthorization From per Robert Guise and Bill Larrow
which attaches the executed Form, EIN, the Letter of Admin., and a voided check per request a copy of which was
previously provided in September 2020. While preparing this summary, I noticed for the first time that the PreAuth
Form provided to me by Bob Guise and Bill Larrow, Financial Mangan apparently utilized a form it had in
connection with the Control Groups own account with Citizens. Specifically, the RJ Community Mgt. Form
describes the preauthorization as allowing for RJW aka “Company to initiate debit entries to the account indicated
below at the Depository Financial Institution identified below “Citizens Bank … and to debit the same to such
account for …collection of assets. Furthermore, it is entitled “ACH Authorization for Direct Payments” which
together with the voided check means that the bad actors used a badly revised Direct Deposit Form to effect the
unlawful ACH debits. There is no plausible basis to believe anvthing else and it appears that the co-conspirators
simply transferred money from the Estate Account to their own personal accounts held at Citizens Bank in its role as
Depository Financial Institution.5

Oct. 7, 2020: As directed by Jay L, I contacted the local head office and spoke to a John Owens, as part of my
ongoing attempt to obtain copies of my mother’s account statements with Citizen’s including the credit card
statemtents. Per his direcetion, I faxed the Short form cert, the ltr. of Admin .to CB Customer Advocacy at
888.727.0016, requested a complete copy of my mother’s statements from 2016 to the present. To date, I have
never received either the statements or even a response.

Nov. 13, 2020: Robert Guise calls me apro pros of nothing and makes false and deceptive representations to obtain
medical information he is not entitled to. Because I had never before received a call from Mr. Guise, I was surprised
and immediately asked if there was an issue with the monthly assessment to which he assured me there was not. See
Exhibit Phone Reocrd.

Nov. 16 or 17, 2020: I realize for the first time that no debit was made on 0ct or Nov. 5, 2020 and because I the
HOA Board was overtyly harassing me led by the President Arthur Goldberg and Robert Bernstein, both of whom
are trained attorneys who were inexplicably grossly violated Fair Housing Act and related laws without any concern
for even plausible deniability at about the same time that I realized that I and my mother before me were obstructed
from any opportunity to participate in mandatory votes for among the things the BOD and also had been deprived to
see the financials or any other material records including the basic rules of the complex even after multiple requests

11/23/2020: Email to William Larrow, financial manager and Robert F, Guise, Jr. the alleged property
representative Imperial House then d/b/a Rj Community Management attaching a copy of the successful fax of
October 9, 2020, which included the death certificate (for third time), the Short Form Cert., and the Form of
Preauthorization I was required to execute by Mr. Guise by fraud, deceipt, and misrepresentation. It was neceasssry
for me to contact them once I recognized that the scheduled payments for what I believed were legitimate monthly
HOA assessments for Oct, and Nov. 15, respectively, were never deducted. See attached, a redacted version of the
so-called presuthorization form which directed me to also provide a voided check. 6 See Exhibit Form and voided
check. On Sunday, January 24, 2021, I learned for the first time that

(1) the form in and of itself is utterly insufficient as a matter of law to prove
preauthorization to either the originating or receiving bank, Citizens
(best guesss – PNC is the other banking entity involved);;
(2) the fact that I was required to provide a voided check was an enormous
red flag in and of itself because such checks are only accesptalbe for a
one time electronic check conversion NOT a reoccurring preauthorized
debit which must be initiated an authorized by the client directly; and
(3) that the check is a business account check which is not and has not ever
been eligible for any kind of check conversion whatsoever.

6
I believed then and now that the BOD was attempting to create a false appearance of my status as member not in
good standing for purposes of blocking any legitimate complaint to the Attorney General’s office. In the email, I
wrote: ‘ Bill, attached is a copy of the fax I successfully transmitted to your attention on Oct. 9. As recently as
Nov. 13, 2020, Bob assured me everything was fine with the new account HOA monthly auto-debits. However,
this weekend I realized that neither the Oct. or Nov. 15, 2020 payments have been debited nor processed. I do not
understand what the issue but will you please resolve it forthwith. I do not want to incur any penalties on behalf of
the estate for reasons beyond my control. Please confirm of this email, its attachment, and that you will process
the outstanding monthly HOA payments at your very earliest convenience. If you require additional information,
please do not hesitate to contact me.
 Specifically, it contains an “on-us” symbol which CB knew at all
relevant times precluded any debit from the estate account.

On or about Nov. 22, 2020: Bill Larrow, Financial Manger of the alleged propery management co. aka control
group cemailed and said that the dealy was due to new electronic program of some sort.

Nov. 26, 2020: I was forced to follow-up again with Larrow and Guise again. because the withdrawal had yet to be
processed.

On November 28, 2020, a date even remotely close to the preauthorized date of the 5 th of the month, banking staff
processed a transfer to the illegimate transferee despite knowing that because the estate account is a business
account, it is and was always ineligible for ARC debits but concealed their knowledge and intentionally or
knowingly obstructed my ability to detect the fraud by inartfully descfribeing the transaction as follow, Imperial
House Condo dues

The rules protecting business accounts that were blatantly violated are in plaace to protect fiduciary funds such as
estate account and for the express purpose of providing business customer tools to ombat ACH debit fraud to their
business customers. 7 At no time, has Citizens ever protected this estate or my mother;s account before me from any
impperoper or illegal financial fraud. The only person who is blocked from accessing estate funds is the only
person legallyt entitled to access such funds – me.

On or about December 1, 2020: Ltr. from Citizens Bank dated Nov. 23, 2020, Re.:: Important Information about
U.S. Treasury Direct Deposits. Executed by Saundra Paolo, Case No. 93804, ACH Operations. Unbeknowst to me
at the time, the letter was rife with materially false, unfair, and deceptive representations all intended to shift
Citizens’ liabilty for its failure to comply with rules, regulations, and contracts to the Estate by deciept although
none of that was known to me until recently. In the letter, Ms. Pauolo falsely and baselessly representented that my
mother’s closed checking account had been frozen pending restitution from the Estate to CB. The letter referenced
a Notice of Reclamation and claimed that the Estate owed money to Citizens Bank in the amount of $3,018 and it
also made a materially false representation that I was the sole owner or beneificiary of my mother’s closed account.
During my mother’s lifetime, I had no interest whatsoever in that account. And before it was closed my brothers
took two thirds of the funds in the account on Oct. 1 including the two-third SSA deposit on that date. To describe
income to me that I never had or possessed in a certification to Treasury or the SSA is inaccurate and could result in
complications for me in my personal capacity

On or December 2, 2020: I contacted Ms. Paulo directly because I was concerned that even the empty account
being frozen could somehow give the appearance that I was not properly acting as agent for the Estate, etc. I was
assured that was not the case but that I should pay ASAP. I also reported that the letter inaccurately ascribed
financial interests to me that I did not have. . I was assured that was not the case which gives me no compfort
whatsoer.

On or about December 5, 2020: Pennsylvania DOS sent me a REV 1543 from which contained information it
received from Citizens Bank – again falsely ascribing income to me that I never had. Specifically, the information
provided to the DOS is that I am the beneficiarly or sole account holder of the joint account held by my mother and
brother during her lifetime which passed 100% to my brother upon her death. Citizens is mandated by law to send
the correct information to the DOS which would have then properly notified the owner of account – my brother. He
has personal income tax obligations, I do not. I had no contact with anyone at Citizens Bank until after my
mother’s death. From 2016 through 2020, the bank interacted with my brother routinely and obviously with my
mother on occasion. There is no plausible defense for what appears in retrospect to have been intentionally false

7
Such tools include ACH Debit Bloch which prohibits all ACH debit withdrawals from the account; ACH Debit
Filters. Only ACH debit transactions that match criteria you set based on payee, dollar amount, etc., are permitted;
ACH Positive Pay. Allows accountholder to review ACH debit requests before they are paid.
certifications as part of the conspiracy to defraud my mother and now her estate while simulaneoulsy retaliating
against me for reasons well-beyond the four corners of this correspondence.. The error goes the DOS calculation of
my personal income tax when it should have rightly been sent to the owner of the account who could properly fill it
out for taxation purposes. He must pay income tax on what is now his account. It appears that both false
certifications were made on or about the same date.

December 8, 2020: I mailed the check to CB at ROP, Rhode Island.

December 18, 2020: I emailed Fahran Z. at CB attaching the From REV 1543 and a copy of joint account
statement telling him that they need to correct the form and to please forward the emal and its attachments to Jay
Luzier. I did not receive any response.

On or about, December 23, I resent the email to Fahran and again requested he forward the email and its
attachments to Jay because I did not have his email.

On December 9, 2020 the second alleged ACH debit in the amount of $561 was posted to the account as “Imperial
House HOA dues” absent any identifying information regarding the payee or transaction numbers, etc. Today
January 24, 2021, I learned that such description is impermissible. Citizen’s Bank must identify the payee not just
refer to alleged reason for the payment and I also understand today that even if a ACR debit was permissible it could
have debited the account once –Oct. 2020 and that it would have to be processed on the same date. However, I did
and could not know any of this at the time absent substantive research which I since been forced to do.

On Dec. 29, 2020: Bill Larrow as the agent of the corrupt control group of the Imperial House Condiminm left at
my door a letter on RJ Community Letterhead that unbeknownst to me contained false and deceptive representations
meant to induce detrimental reliance on the legitimacy of RJ Deveol and its failure to tiemly process the then-
unknown fraudulent assessment charges. Sepcificlaly, he wrote,

Re.: “Dues Payments”

As an owner on Direct Debit payments through RJ Community Mgmt’s office,8 you do

not need to do anything have to do anything. Payments will continue to be processed on
the 5th of each month.

This letter contained materially false and misleading representations re: the entity making
unlawful debits and the date of the debits and is materially inconsistent with the language of the
Form Documment that I was required to execute entitled, “ACH Authrorizaito Agreeement for
ACH Payments.” See infar at Oct. 9, 2020 for detail as to my discovery that this Form is in fact a
badly revised altered veriosn of a Direct Deposit Form indicating that the Control Group of
Imperial have an account with Citizens Bank to which all unlawful debits are transferred
explaining the timing of the most recent illegal debit from the estate account of Friday, January 21,
2021, supra.

On or about that same date, Fahran replied ignoring my instructions and writing that I should just fill out the form
and send it to DOS.

December, 2020: I realized that the alleged HOA assessments were not debited on the 5 th of October or November.

January 7, 2021: Farhan responded with a stand-alone email providing Jay’s email address.

January 7, 2021: Also on that date, as I was searching for confirmation that the January assessment payment has
occurred as scheduled on Jan. 5 (it had not), I recognized for the first time that the check mailed to CB ROP per the
threatened freeze on a closed account, which I confirmed as being delivered on Dec. 8, 2020, had yet to be cashed.
Accoridngly, I began to research the issue to understand the consequences of delay. And I subsequently learned
that the the December 8, demand letter was materially false, misleading, in breach of CB’s contract with treasury

8
and required CB staff to make false certifications to treasury and SSA. And I also found that (1) Citizen’s had a
nondiscretionary duty to send the copy of the reclamation notice to me which was not done.

And that further, they were not to contact me at all. By law and regulation because CB’ Bank did not timely enter a
DNE no later than Oct. 1, 2020, it was responsible to pay the money to SSA. And then and only then, Citizen’s
would be required to send me a copy of Notice of Reclamation which would be issued by SSA. Then my brothers
and I would have been responsible for paying that money as directed by the SSA assuming we owed it which is
unlikely because the contract with SSA demands that the staff enter the DNE immediately upon any reaosnlabe
notice of death and the failure to do results in strict liability for the bank.

Accoringly also on January 7, 2021,

First, I contacted Saundra Paulo and with her permission taped an approximate 26 minute call. To her credit, she
basically that there was no excuse for the CB non-compliance with the laws and its own contract. However she did
not have authority to take action. See See audio tape available upon request to any independent investigative
authority.

Next, I spoke to a Lynn M. who was identified as Saudra’s supervisor and with her permission, I audio taped this a
23 minumte call which speaks for itself. Of material importance that after she told me that there would be an
investigation but that the persons conducting such investigation (i.e., the Chairman’s Office staff) would not contact
me for perhaps as long as two weeks. Accordingly, I explicitly instructed Lynn not to cash the $3,016 check until
after I spoke with the Chairman’s Office given that Citizen’s Bank effectively tried to transfer its own liabity to the
estate using unfair, fraudulent, and deceptive tactics due to its own noncompliance. During both calls, I referrnced
the pending CFPB lawsuit describing conduct not dissimilar to what I was experiencing. I suggested that they
properly and timely address my legitimate concerns on multiple levels

By COB that same date, I saw that after ignoring the check for more than one month, Lynn pushed through the
check so fast that it immediately posted to my online account in blatant disregard that I withdraw my authorization
for CB to cash the check.

Also on Jan. 7, 2021, Fahran graced me with a response to the latest follow-up email sending Jay’s email address.

Jan. 11, 2021, I emailed Jay L. writing in relevant part:

The False Certification to Dept. of Revenue

I originally reached out to your branch regarding inaccurate info to the Pennsylvania Dept. of Revenue for the
reasons described in the attached Rev 1543. [Representations to the Dept. of Revenue as either the owner or
beneificiary of the joint are false] Such representation is inaccurate and could result in negative, personal financial
consequences for me personally. I am certain that the official form submitted to the Dept. of Revenue requires
certification of that the statements contained therein are materially accurate, complete, and truthful. I am once
again requesting that CB submit a corrected form to my bother and the Dept of Revenue and the estate as required.
joint account held by my mother and brother is and was held by my brother by operation of the law on the day my
mother died. As I wrote in the email to Fahran, the Estate will pay its fair share. However, , CB may not describe
me as the beneficiary or joint account holder on that account because such representation is inaccurate, could result
in negative, personal financial consequences for me personally, and because the Department of Revenue likely
requires certification that the statements contained therein are materially accurate, complete, and truthful. I am
once again requesting that CB submit a corrected form to my bother and the Dept of Revenue and the estate as
required. [To date, that has happened and absent threat of legal or regulatory action, it will not happen because I
have stumbled upon a long-term conspiract to defraud at least certain of the owners at 5600 Munhall including my
mother and now her estate.]

The Fraudulent Reclamation Scheme

This past week, I became aware of another problematic transaction relating to my mother’s account and to the
Estate Account. I spoke to Saundra and her supervisor Lynn M. at the ROP Rhode Island on Friday and with
Saundra’s and Lynn’s permission taped the calls. Based on the Green Book and other regulatory information, your
local branch should have initiated the DNE as soon as you all were aware of my mother’s death which was
indisputably [Oct. 1] the week before I was able to personally get to your office on Fridday, Oct. 9. There was no
legal basis [or justification] for demanding repayment from the estate nor using deceptive language inferring
freezes and holds on EvE or estate related accounts. This conduct appears to consititute UDAAP in the context
of imposing the bank’s liability under its contract with Treasury to the Estate using deceptive and misleading
language and omitting material facts.

By way of representative example, I have not and did not ever receive a mandatory copy of the original reclamation
notice sent to Citizens …. The last thing I said before hanging up with Lynn was that, CB should not cash the check
until a full investigation of my complaint is instituted and completed At a bare minimum, under these facts at least
the October 9, 2020 auto-debit is and has been at all applicable times the debt of CB not the Estate. Her response
was to push that check through by COB the same day…. Arguably, this conduct crosses the line into fraudulent
conduct given my instruction. If the conduct was not by a Citizen’s employee,, I would have dispute this charge as
fraudulent from the outset. And I do dispute it . I have a fiduciary duty to the estate. And, you and Citizen’s
arguably have a fiduciary duty to the Estate or at least a basic duty of good faith and fair dealinge. I don’t know
that I can justify leaving the estate account with Citizens but to do otherwise would enormously complicate things.
I appreciated your help very much when we set up this account but none of the latter passes the sniff test. It also
seems very poorly timed given the CFPB investigation of your back for UDAAP albeit in another context. What is
contact information for your Compliance Officials? Can you fix this and will you investigate how and why this
happened? As a former regulator and law enforcement official, I am not okay with false certifications. Hopefully,
you are not okay with that either. See email of this date, attaching and attachments. 9

January 12, 2021: After not receiving any answer, I resent the email and Jay did not respond albeit not in writing
so that he could apparently lie with abandon given subsequent events. At the time, I wholly believe that Jay was an
honest and decent person and therefore trusted what he had to say to the estate;s detriment.

January 13, 2021: Jay and I connected on the phone. By now, the harrassment and retailoatroy conduct in my
home had escalated to the point that the corrupt control group co-conspirators threatened and continue to threaten
me with exhoribinat fines for violating Rules which do not exist or which are unenforceable as a matter of law and
fact because the allegations are fictious, and because the substantive conduct is protected and to charge any punitive
fine or fee is explicitly prohibited and state law but nonetheless I take the threats seriously and recognized that the
criminals could just arbitrarily withdraw out of my account based upon what I then believed to be a legitimate
preauthorization that would so authorize. Today, I know that absent ciriminla complicity the Bank could not
process any of the alleged debits absent violation of law, regulation, and statute for multiple reasons, primarly
because the voided check and related form did not and could not be accepted by the bank as permitting a monthly
debit. First, because the nature of the transaction on the payees side is an ARC transaction and there was no
acceptable form of authorization that could be or was provided to the bank by either me or even the payee and
because as a business account, the account was entitely ineligible for such a transaction from the outside. And the
checked carrie on its fact the symbol designating as ineligible. None of these transactions could be processed absent
complicity from the receiving bank – Citizens. And there are multiple checks and balances on all sides of the
transaction requiring a series of actions to accept whatever is is the payee used to effect the withdrawals which were
false identified on al period statements or online records as “AchDebits” when this description is materially false.

9
Attaching oth letters at issue and what is typically known as the “Green Book, Chapter 5” titled, Reclamation at
https://www.fiscal.treasury.gov/reference-guidance/green-book/chapter-5.html as well as SSA Procedure
Operating Manual (POM) GN 02408.000 Stop Payments and Reclamations
https://secure.ssa.gov/poms.nsf/lnx/0202408000!OpenDocument&Click= Each of which together and explicitly
describe each step of the process which was ignored in my caes even after notice. Given what I know today, in my
view this constitutes another instance of a predicate RICO act or theft as well as fraud and deceit, and malicioius
retaliaton all of which constitutes at bare minimum a UDAAP.
.

protected under multiple federal and state laws, of which I have no notice without any substantive or procudureal
due process

made amterially fasle statements about me to others in the building and collaboratively lied and concealed material
facts all the while threatenting me with outragesous fines for violations of Rules which they refused to provide a
copy of, defamed me publically, communicated personal medical information about me to neighbors I do not even
know in violation of all manner and then made up a fictitious rule violation which in and of itself violated the FHA
and the HRA state law, to make yet another false claim of unlawful debt in the amount of $100 per day 10.

Jan. 24/25, 2020: Citzens for the first time blocks my ability to make an Atm debit – for no legitimate purpose
whasoever other than to harass me in retalitaton for asseting my rights and threatening to expose the long-term (in
my view) criminal conspiracy to aid-and-abett a decades long schedme to defraud senior citizen who sadly trusted in
their local bank to not defraud them. applied only against me for retaliatory, baseless reason this past weekend at a
time, Citizens knows that I have no choice but to move my money and am not likely to want to write any checks out
of the account. In taking this action, Citizens’ is engaging at best in UDAAP.

** Our funeral direetor represented he informed social securitiy of my mother’s death so I was shocked to find that
not just one but two paynents were dep

and that he told my brothers that they and now I would

10
And the President of the fictioucs HOA associaton was and is personally harrasisng, threatenting, and attempting
to extort me which did not make sense until learned that he is and was an active co-conspirator of the myriad of the
manipulative trading that were the taregets of my longterm invstigaiotn of organized crime on Wall Street which
was so successful that I was harraseed and bullied out of my job, lsot everything and have been subject to ongoing
retaliatory harrassment and reacketeering including by governmental official ever since. And the cherry on top is to
learn that as a consequience of corruption inside my former agency, that a criminal who would have been shut down
and millions of investors losses been saved but for the fact that memberso of his control also include certain corrupt
insiders at the SEC and elsewhere.
They knew or should have known.
200

October 2005: Under cover of letter dated,

2007: Upon purchase in fee simple by cash, EvE is provided a white binder that was given to the seller in

The entire purchase was rotten at the core and involved the exact conduct described in a myriad of class actions
across the country.

And my mother had no idea that she walked into a criminal enterprise controlled on at least a local level by Jeff
Ackerman, Silk, Stewart, Ed Zehfuss, Robert Guise, In fact, neither she nor anyone is this building who is not
complicit necessarily even even head of those inidividuals.

At all relevant times, my mother had no idea that the so-called HOA BOD had no legitimate authority or control
over the building or her property; nor did she ever know that the entity then d/b/a A & N was for all intents and
purpose the control group of the Condiminiym – not a separate, paid independent contract property management
company. And the representation to her, to me, to the public on the Website for 5600 Imperial House are materially
false in every possible respect. At no time, did these people have any authority for charging anyone anything.

What does the monthly condo fee cover?

The monthly condo fee is comprised of two components, a proportionate share of the cost to operate the building
(based on a unit owner approved operating budget for recurring day-to-day expenses), and a share of the costs
necessary to fund a capital improvement reserve (long range) budget. Operating expenses include:

 the cost of domestic water and sewage.

 all common area landscaping and snow removal.
 association employee wages and benefits, including related payroll taxes and insurance.
 association liability insurance.
 common element fire insurance.
 year-end audit (or financial review) costs.
 attorney/legal fees relative to association business.
 elevator service.
 maintenance and operation of swimming pool, exercise room/equipment, separate saunas for men and
women, public restrooms, maintenance and upkeep of party room and maintenance and upkeep of two
guest rooms -- both available to any unit owner in good standing, subject to payment of a per diem rental
fee.
 common area lighting.
 common element heating and cooling.
 common element decorating.
 the counsel, financial administration of a professional manager.

e.g..

o whom my mother and now her estate have

2006: SEC Cendant likely without outdisclosing likely liability for the class actions lawsuits, uses a fraudulent spin-
off scheme to dumps its liabilities while dumping restricted stock as free trading stock into the martket for profit and
to cover its losses for illegal conduct in violation of Section 5 of the Secruites Act. 11

Specifically, a legitimate spin-off is a corporate distribution of another corporation's securities that are owned by the
distributing corporation and are distributed pro rata to the distributing corporation's shareholders by a one-time
distribution normally takes the form of a dividend paid by the distributing corporation."12 In the context of
registration under the 1933 Act, the spin-off has often been compared to a stock dividend.' A stock dividend is a pro
rata distribution of a corporation's own stock to its shareholders.' Public information must be reported in a A
registration statement is a form containing detailed information that the issuer must file with the SEC. 13

Moreover, a spinoff may only14: Stock may be distributed in an unregistered “spin-off” 15transaction if certain
conditions are met16. Among other things,

11
The Securities Act of 19331 regulates corporate distributions of securities for value to the investing
public. The Act requires corporations to register with the Securities and Exchange Commission (SEC)
those securities that are issued to the public. The fundamental purpose of the Act was to replace an
attitude of "buyer beware" with a philosophy of full disclosure.4 President Franklin D. Roosevelt stated
that the federal government has an obligation "to insist that every issue of new securities to be sold in
interstate commerce shall be accompanied by full publicity and information." To ensure that full
publicity accompanies every issue of new securities, sections 5(a) and (c) 6 of the 1933 Act make it
unlawful for any person to sell a security by means of instruments of transportation or communication in
interstate comnmerce.
12

13
See sections 6 and 7 of the 1933 Act, 15 U.S.C. §§ 77f-77g (1976); schedule A of the 1933 Act, 15
U.S.C. § 77aa (1976). 8. See section 8, 15 U.S.C. § 77h
14
SEC v. Capital Gains Research Bureau, Inc., 375 U.S. 180 (1963). The Supreme Courtvstated that full
disclosure is the common purpose of the Securities Act of 1933, 15 U.S.C. §§ 77av77aa (1976); the
Securities Exchange Act of 1934, 15 U.S.C. §§ 78a-78hh (1976); the Public Utility
Holding Company Act of 1935, 15 U.S.C. §§ 79 to 79z-6 (1976); the Trust Indenture Act of 1939,v15
U.S.C. §§ 77aaa-77bbb (1976); the Investment Company Act of 1940, 15 U.S.C. §§ 80(a)(l)-(52) (1976);
and the Investment Advisers Act of 1940, 15 U.S.C. §§ 80(b)(l)-(21) (1976). 375 U.S.vat 186. In Capital
Gains Research Bureau, the Court considered a violation of the InvestmentvAdvisors Act of 1940. The
full disclosure language was applied singularly to the 1933 Act in In re Caesars Palace Sec. Litigation,
360 F. Supp. 366,

15
The distributed stock can represent ownership in either a subsidiary of the distributing corporation or a
separate corporation. See SEC v. Datronics Eng'rs Inc., 490 F.2d 250 (4th Cir.1973), cert. denied, 416
U.S. 937 (1974); SEC v. Stem-Haskell, Inc., [1973 Transfer Binder) FED.
SEc. L. REP. (CCH) 94,065 (S.D.N.Y. 1973); SEC v. Harwyn Indus., 326 F. Supp. 943 (S.D.N.Y. 197
1); Bromberg, Corporate Liquidation and Securities Law-Problems in the Distribution of Portfolio
Securities, 3 B.C. INDUS. & COM. L. REv. 1 (1961); Comment, Securities Regulation: Corpo.rate Spin-
Offs as a Device for Public Distribution Without Registration, 42 U. COLo. L. REv. 11
(1970).
16
 1. the shares distributed by a parent company in the “spin-off” must have been held for at
least two years;
2. the “spin-off” must be for a valid business purpose; the shares must be “spun-off” pro rata
to the parent’s shareholders;
3. the parent shareholders may not provide consideration for the “spun-off” shares; and
4. the parent provides adequate public information about the spin-off and the subsidiary to its
shareholders and to the trading markets. via an approved registration statement.
For those who control the corporate entities in a spinoff, the value received is in the creation of a,

“[t]he spurious creation of a market whether intentional or incidental

constituted a violation of the registration [and antifraud] provisions of Sections 5 of the
Ssecurities statutes [and 10-b and rule 10b-5 thereunder]. . Each of the issuers
by this wide spread of its stock became a publicly held corporation. In this
process and in subsequent sales the investing public was not afforded the
protection intended by the statutes. Further, the market and the public
character of the spun-off stock were fired and fanned by the issuance of
shareholder letters announcing future spin-offs, and by information statements
sent out to the shareholders.”

See SEC v. Datronics Engineers, 490 F.2d 250 (4th Cir. 1973)(re’d on other grounds)(holding that corporate spin
offs of securities to its stockholders violated statutes relating to sale of unregistered securities and prohibiting use of
manipulative devices, and case was remanded to see if an injunction should issue.)17see also,

Six provisions provide for accompanying note 61 infra. 24. Six provisions in the 1933 Act protect against violations
of the Act (that is, they protect the purchaser against loss). Sections 20 and 24, 15 U.S.C. §§ 77t, 77x (1976), apply
to all violations of the 1933 Act. Section 17(a), 15 U.S.C. § 77q(a) (1976), forbids fraud "in the offer or sale of any
securities." Fraud requires damages or potential for damages, i e., value flowing from the shareholders in the context
of spin-offs. Section 17(b), 15 U.S.C. § 77q(b) (1976), involves value to the corporation, forbidding the
publication of advertisements describing securities without disclosure of that value. The other two
The two sections of the Secruitiy Act that specifically provide the recovery to be received from registration
violations address only the value flowing from the shareholders: Section 12, 15 U.S.C. § 771 (1976), states that a
person who sells an unregistered security shall be liable for the "consideration paid for such security,"or damages if
the purchaser no longer owns the security18

The SEC rarely files spin-off cases in federal district and typically only after public outcry forces a reaction. In each
instance, the sale of unregistered securities has been only marginally described by the SEC given the abundant
nature of related-fraudulent conduct by the time the SEC typically is forced to intervene. Cases include, Only four
cases have interpreted section 5 in spin-off transactions. See SEC v. Datronics Eng'rs, Inc., 490 F.2d 250 (4th Cir.
1973), cert. denied, 416 U.S. 937 (1974); SEC v. Stern-Haskell, Inc., [1973 Transfer Binder] FED. SEC. L. REP.
(CCH) 94,065 (S.D.N.Y. 1973); SEC v. Harwyn Indus., 326 F. Supp. 943 (S.D.N.Y. 1971); SEC v. LesStuds Corp.
[1970-1971 Transfer Binder] FED. SEC. L. REP. (CCH) 1 92,866 (S.D.N.Y. 1970) and my investigation SEC v.

17
Thus,, “each of these spin-offs violated § 5 of the Securities Act, in that Datronics caused to e carried
through the mails an unregistered security 'for the purpose of sale or for delivery after sale'. Datronics was
actually an issuer, or at least a co- issuer, and not exempted from § 5 by § 4(1) of the Act, 15 U.S.C. §
77d as 'any person other than an iss.
18
The measure of damages is the value lost by the purchaser (value given up minus value received on a
disposition). Section 1 (e) assesses the same measure of damages for a false statement in a registration
statement under that section. 15 U.S.C. § 77k(e) (1976). All these provisions are generally directed at
protecting the value flowing from the shareholder. See Duke L.Rev. Registration of Stock Spin-offs and
the Secruites Act of 1933, Vol.1980:965.
Spongetech Delivery Systems, Inc. as well as related criminal cases. Criminal convictions arose out of the Stem-
Haskell spin-off. United States v. Rubinson,543 F.2d 951 (2d Cir.), cert. denied, 429 U.S. 850 (1976). 26. 490 F.2d
250 (4th Cir. 1973), cert. denied, 416 U.S.. 850 (1976); see also US v. Benjamin, (holding that a criminimal
prosecutors burden to “ establish the essential elements of knowledge and willfulness as to a conspiracy to sell
unregistered securities via a fraudulent spinoff scheme. The prosecutor need only prove that either (1) defendants
knew or (2) they that they deliberately closed their eyes to, the necessity for registering the S-H stock before selling
it. United States v. Benjamin, 328 F.2d 854, 861-63 (2 Cir.), cert. denied, 377 U.S. 953 (1964).19

Per Benjamin, it is safe to say that absent a boda fide dividend in unregistered unregistered securities, the
stockholders who neither control the corporation which declared the dividend, see Sections 2(11) and 15, nor act in
concert with persons who do have such control, receive restricted stock albeit illegally unlegended which never
loses its restricted character and thus all resales of such securities do not come within any exemption provided by
Section 4(1) and, as innocent stockholders are defrauded as are all subsequent buyers of the distribution of
unregistered stock.

2007: See https://www.nar.realtor/legal-case-summaries/hyland-v-homeservices-of-america-inc-antit Class

action: n June 28, 2007, Kentucky federal court issued a number of rulings in a class action lawsuit alleging that
various real estate entities illegally conspired to fix commission rates. Below is a brief discussion of the lawsuit, and
then a summary of the June 28, 2007 rulings/ The lawsuit alleged that the Plaintiffs directly or indirectly paid a
fixed commission rate to their brokers, depending on whether they were buyers or sellers of real estate. The parties
acknowledge that only the listing broker received a commission from the transaction and the listing broker then paid
a portion of the commission to buyer’s representative .

Motions to Dismiss filed by Cendant Corp NRT Inc., Coldwell Banker Real Estate Corp. (“CBREC”),…. In 2007
Cendant was the parent of NRT and CREC, while CBREC was the controlled franchisee. per the Court opinion.
After considering these four motions to dismiss, the court dismissed NRT20 from the lawsuit but allowed the

19
In finding that prosecutors met that burden, the court stated that the careful examination of the
voluminous record satisfies it that the jury's verdict as to each appellant was supported by overwhelming
evidence of their knowledge and willfulness, including evidence of furtive and roundabout dealings;
evidence that two different lawyers had warned Chester and Rubinson that the spin-off sales would be
illegal;21 evidence that appellants laundered their stock through National solely to circumvent the
registration requirements; evidence that appellants were sufficiently familiar with those requirements to
alert them to the illegality of their scheme; evidence that appellants used nominees to conceal the fact that
National's stock dividends were going to control persons; and evidence that the persons who arranged for
the spin-off of S-H stock were the same ones who received and sold that stock,”. Us. v. Benjamin at ___.
Almost all illegal spinoffs will reveal identical facts because it is impossible for an illegal spin-off to
occur absent complicit gatekeeprs and a myriad of market professionals.

20
NRT argued that the court lacked personal jurisdiction over it, as the Plaintiffs had not alleged
sufficient facts to support the court’s exercise of jurisdiction. he Plaintiffs argued that NRT was subject
to jurisdiction in Kentcky because one of its subsidiaries conducted business in the state. Looking at other
cases, the court found that a parent/subsidiary relationship was insufficient to confer jurisdiction over a
parent. Instead, a party must allege that the parent is consistently engaging in business within the state.
Since the Plaintiffs had failed to make these kinds of allegations against NRT, the court dismissed NRT
from the lawsuit.
litigation to proceed against the other defendants rejecting Cendant’s argument that . The remaining defendants all
argued that they were not directly engaged in any of the transactions at issue and so should be dismissed from the
lawsuit. Cendant is the parent company of NRT [and] CBREC, nd CBREC are franchisors. 21

Cendant’s 10-K furnished to SEC for year ending 12/31/2006, disclosed the following: We own or have rights to
use the trademarks, service marks and trade names that we use in conjunction with the operation of our business.
Some of the more important trademarks that we own or have rights to use that appear in this Annual Report include
the CENTURY 21®, COLDWELL BANKER®, ERA®, THE CORCORAN GROUP®, COLDWELL BANKER
COMMERCIAL®

21
Cendant argued that the Plaintiffs had failed to allege facts that could hold Cendant liable in this case,
while the Century 21 and CBREC both argued that they did not control the day-to-day activities of their
franchisees and the franchisees were not their agents.

The court looked at the standard for evaluating motions to dismiss in antitrust cases. In antitrust cases, the
U.S. Supreme Court has stated that dismissals prior to allowing the parties discovery should be granted
sparingly. Using that standard, the court ruled that the Plaintiffs had sufficiently alleged a conspiracy
against all three defendants and so allowed the allegations to proceed to the discovery phase of litigation.
Appendix Salse of Unregsiterd Securirtes wrongful death

2. Joint Motion to Dismiss Based on Kentucky Rebate Ban and Statute of

Sale CH See Moherl v, NAR, Reology…Keller Williams, et al.

Basic theory:

 The MLS is a required for any brokerage who wants to be in business;

 The MLS is controlled by local Associations, who have to abide by NAR’s rules and policies, including the
Buyer Broker Commission Rule;
 The four named brokerages/franchise companies require that their agents and franchisees belong to NAR;
  The Buyer Broker Commission Rule forces sellers to pay for the buyer broker’s commissions;
 The interaction between NAR, the local Associations, the local MLSs, and the defendant
brokerages/franchises (and I’m going to assume many more defendant brokerages and franchises will be
added to the list at some point) constitute a conspiracy in deeds and words;
 That conspiracy keeps brokerage commissions high — between 5 and 6% — which harms home sellers.

The lawsuit wants damages (of course) but importantly:

That the Court award Plaintiff and the Class a permanent injunction, under Section 16 of the Clayton Act, enjoining
Defendants from continuing to require sellers to pay the buyer broker and from continuing to restrict competition
among buyer brokers

Case: 1:19-cv-01610 ND Ill. (2019) Mom victim of same conduct. National Association of Realtors, RE/MAX
Holdings, Keller Williams Realty, HomeServices of America and Realogy Holdings as co-defendants. NAR, with
1.3 million members, is the largest trade group in the industry. The four realty companies named as defendants are
behemoths: franchiser Keller Williams has approximately 180,000 agents in the United States and Canada;; Realogy
includes among its brands Better Homes and Gardens, Century 21, Coldwell Banker Real Estate and ERA;
HomeServices is a Berkshire Hathaway affiliate and includes among its companies regional powers such as
Long & Foster Real Estate and Edina Realty. (2015 to Present)

and four of the largest realty companies have been accused of a conspiracy to systematically overcharge home
sellers by forcing them to pay commissions to the agents who represent the buyers of their homes. The 2019 class
action focuses on a rule it says has been imposed by the NAR. The rule requires brokers who list sellers’ properties
on local multiple listing services (MLSs) to include a “non-negotiable offer” of compensation to buyer agents. That
is, once a home seller agrees in a listing to a specific split of the commission, buyers cannot later negotiate their
agents’ split to a lower rate. That requirement, the suit alleges, “saddle[s] home sellers with a cost that would be
borne by the buyer in a

CONTROL PERSONS OF THE FRANCHISORS DESIGNED AND HAVE PARTICIPATED IN THE

CONSPIRACY

Defendant Franchisors orchestrated and have participated in the conspiracy alleged herein in three ways: (1) they
have required their franchisees (and the agents employed by those franchisees) to comply with NAR rules including
the Buyer Broker Commission Rule; (2) their executives have supervised NAR’s operations including NAR’s
adoption, maintenance, and enforcement of the Buyer Broker Commission Rule; and (3) their franchisees have
influenced local realtor associations that adopted and enforced NAR’s rules, including the Buyer Broker
Commission Rule.

The franchisors and the franchisees are both managed by the control persons of the franchisor or parent. And the
control persons of the franchisor are also members of gatekeeping associations
brokerage franchisors in the country, have actively participated in the management and operation of NAR. NAR’s
board of directors promulgated the rules in NAR’s Handbook and in its Code of Ethics, including the Buyer
Broker Commission Rule, and many of those rules were developed and drafted by NAR’s Professional Standards
Committee. Senior executives of Defendant Franchisors have served on NAR’s governing board of directors. For
example, both Ronald J. Peltier, the Executive Chairman of HomeServices of America, and Nancy Nagy, CEO of
Berkshire Hathaway HomeServices KoenigRubloff Realty Group, currently serve as directors of NAR, and Bruce
Aydt, Senior Vice President and General Counsel of Berkshire Hathaway HomeServices Alliance Real Estate, is
the former Chair of NAR’s Professional Standards Committee. executives from Defendant Franchisors, the four
largest real estate brokerage ranchisors in the country, have actively participated in the management and
operation of NAR.
 NAR’s board of directors promulgated the rules in NAR’s Handbook and in its Code of Ethics, including the
Buyer Broker Commission Rule, and many of those rules were developed and drafted by NAR’s Professional
Standards Committee. Senior
Defendant Franchisors implemented the conspiracy by requiring that their franchisees in the geographic areas in
which the Covered MLSs operate, and elsewhere, and the agents employed by those franchisees, comply with
NAR’s rules, including the Buyer Broker Commission Rule. Franchise agreements between Defendant Franchisors
and their franchisees located in the areas in which the Covered MLSs operate, and throughout the United States,
require those franchisees and their agents to (1) comply with NAR’s Code of Ethics; (2) join and comply with the
rules of the local realtor association; and (3) participate in and comply with the rules of the local MLS, which
include the mandatory provisions of NAR’s Handbook on Multiple Listing Policy. 22

22
For example, the franchise agreement between Defendant RE/MAX and a RE/MAX franchisee in Las
Vegas states: “You agree that you and each of your Sales Associates will join and remain a member in
good standing and comply with the by-laws and rules and regulations of a local Board of REALTORS©
(or comparable organization) and, where available, you will become and remain a participant in a board
owned multiple

Appendix I – Unregistered Sales of Securities from 1992 to the present.’

To understand the corporate of the related entities (i.e., Reology, NRT, CBRE, , one must start at the
beginning. Specifically, if one runs a search on sec.gov EDGAR tool and scrolls to the very first filing,
. That the Court award Plaintiff and the other members of the Class damages and/or restitution in an amount to be
determined at trial;

D. That the Court award Plaintiff pre- and post-judgment interest;

E. That the Court award Plaintiff his costs of suit, including reasonable attorneys’ fees and expenses;
F. That the Court award Plaintiff and the Class a permanent injunction, under Section 16 of the Clayton Act,
enjoining Defendants from continuing to require sellers to pay the buyer broker and from continuing to restrict
competition among buyer brokers; and
G. That the Court award such other relief as the Court may deem

one sees that this company was previously an entity controlled by another company because the first
filing is not a registration but rather a Statemnet of Beneficial Onwnership. (

While public records including Enforcement Actions by the SEC tell a slightly different story, the SEC
filings furnished by the control groups is indistubale record of the corporate evolution. To understand the
corporate of the related entities, one must start at the beginning. Specifically, if one runs a search on
sec.gov EDGAR tool and scrolls to the very first filing, one sees that this company was previously an
entity controlled by another company because the first filing is not a registration but rather a Statemnet of
Beneficial Onwnership.

And clicking on the first filing identifies the parties and the entity at issue. See Sec Edgar at
https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0000891104&type=&dateb=&owner=include&start=80&count=40
demonstrates that the first filing for this entity is a Stmt Ben. Owership. Accordingly, if one clicks on
that filing, one then sees the controlling party at that time, namely Putnam Investments d/b/a as HFS.

1995: In a Form 8-k furnished to the Commission by the control group of Putnam d/b/a HFS, announcing
a merger with Coldwell Banker, the following information is contained regarding Coldwell Banker:

Before September 1993: Coldwell Banker Residential Holding Company and Subsidiaries) is described
in the 1995 Form 8-K as being wholly owned through a subsidiary of through a subsidiary of Sears,
Roebuck and Co. ("Sears"). These operations are referred to as the "Predecessor." See
ttps://www.sec.gov/Archives/edgar/data/891104/0000950136-96-000241.txt (The accompanying
consolidated statement of operations for the nine months ended September 30, 1993, reflects the
operations of theCompany prior to the Acquisition when the Company was wholly owned by Sears).

Oct. 5, 1993: The Fremont Group, Inc. acquired the stock of predecessor company (vs. its current
identiy for merger purposes) Coldwell Banker Residential Holding Company and Subsidiaries).
In approximately 1993, Sears Roebuck spun off. See id.

PUTNAM INVESTMENTS INC d/b/a HFS

The control group begins the first phase of a pump and dump aka violations of Section 5 for simplicyt.
InitiaL Group creates and shell and starts selling stock.

The applicable corporation is as follows:

Feb. 2, 1994, Putnam Investments d/b/a HFS filed a Schedule 13=G identifying the control groups of the
HFS to be Marsh & McLennan Companies, Inc. and Putnam Investments, Inc. Specifcially as follows:

Address of HFC aka Issuer's Principal Executive Offices:

339 Jefferson Rd., Parsippany, NJ 07054

Item 2(a) Item 2(b)

Name of Person Filing: Address or Principal Office or,

if none, Residence:

Putnam Investments, Inc. One Post Office Square

("PI") Boston, Massachusetts 02109
on behalf of itself and:

Marsh & McLennan Companies, Inc. 1166 Avenue of the Americas

("MMC") New York, NY 10036

Putnam Investment Management, Inc. One Post Office Square

("PIM") Boston, Massachusetts 02109

*The Putnam Advisory Company, Inc. One Post Office Square

("PAC") Boston, Massachusetts 02109

Citizenship: PI, M&MC and PIM are corporations

organized under Delaware law. The citizenship of
other persons identified in Item 2(a) is designated
as follows:

* Corporation - Massachusetts law

** Voluntary association known as Massachusetts
business trust - Massachusetts law
Item 2(d) Title of Class of Securities: Common

Item 2(e) Cusip Number: 440912103

<PAGE>
Item 3. If this statement is filed pursuant to Rules 13d-1(b), or
13d-2(b), check whether the person filing is a:

(a)( ) Broker or Dealer registered under Section 15 of the Act

(b)( ) Bank as defined in Section 3(a)(6) of the Act

(c)( ) Insurance Company as defined in Section 3(a)(19) of the

Act

(d)( ) Investment Company registered under Section 8 of the

Investment Company Act

(e)( X ) Investment Adviser registered under Section 203 of the

Investment Advisers Act of 1940

(f)( ) Employee Benefit Plan, Pension Fund which is subject to

the provisions of the Employee Retirement Income Security
Act of 1974 or Endowment Fund; see (Section
240.13d-1(b)(1)(ii)(F)

(g)( X ) Parent Holding Company, in accordance with Section

240.13d-1(b)(ii)(G)

Name/Title: Frederick S. Marius

Assistant Vice President and Associate Counsel

Date: January 26, 1994

Executed Freerick S. Marius

Assistant Vice President and Associate Counsel
The assumption is that the control persons of MMC and Putnam have decided to try to take a shell
company of some sort public. And it appears that during the time period 1994 through May 1996, the
control group distributed large blocks to itself and its affiliates in unregistrered transaction when there
was no exemption or safe harbor available

Next, one simply returns to the HFS Edgar filing list and looks for a Registration Statement which will
contain the most accurate facts relevant to potential sales of unregeistered securities.

Between Feb. 2, 1994 and May 5, 1996, multiple Sch 13 G forms filed identitiving the then control
group of Putnam d/b/a HFS. See https://www.sec.gov/cgi-bin/browse-edgar?
action=getcompany&CIK=0000891104&type=&dateb=&o

At all relevant times, HFS control persons are waiting for the right partner to try to go public which is the
utlitmatte goal in all these scams.
May 8, 1996: Merger announced at HFC filings in a form Form 8-K press release announcing a merger
with Coldwell Banker which then describes the public view of Coldwell Bankers Historical corporate
evolution and slips in what is alleged to be the consolidated financial records of all entities. Co-
Conspriators and members of the control group now include Deloitte Touche and Coopers & Lybrand.
See https://www.sec.gov/Archives/edgar/data/891104/0000950136-96-000241.txt

On May 9, 1996: The control Group furnishes the Commission with a Prospectus under Form 424B5
(not a registration statement), In relevant part, the Prospectus discloses that,
OF THE 15,000,000 SHARES OF COMMON STOCK BEING OFFERED,
12,000,000 SHARES ARE BEING OFFERED IN THE UNITED STATES AND
CANADA BY THE U.S. UNDERWRITERS AND 3,000,000 SHARES ARE BEING
OFFERED OUTSIDE THE UNITED STATES AND CANADA BY THE
INTERNATIONAL UNDERWRITERS. SEE "UNDERWRITERS." ALL SHARES OF
COMMON STOCK OFFERED HEREBY ARE BEING SOLD BY THE COMPANY. THE
COMPANY'S COMMON STOCK IS LISTED ON THE NEW YORK STOCK
EXCHANGE UNDER THE SYMBOL "HFS." ON MAY 7, 1996, THE REPORTED
LAST SALE PRICE OF THE COMMON STOCK ON THE NEW YORK STOCK
EXCHANGE WAS $55 3/4 PER SHARE.

And the shell company, HFS, which on May 7, 1996 had no known business operations is now described in
the Prospectus as:

HFS Incorporated ("HFS" or the "Company"), formerly named Hospitality

Franchise Systems, Inc., is the world's largest franchisor of hotels and residential
 real estate brokerage offices. The Company operates nine national hotel franchise
systems: Days Inn(Registered Trademark), Ramada(Registered
Trademark) (in the United States), Howard Johnson(Registered Trademark),
Super 8(Registered Trademark), Travelodge(Registered Trademark) (in North
America), Park Inn International(Registered Trademark) (in the United States and
Canada), Villager Lodge(Registered Trademark), Knights Inn(Registered
Trademark) and Wingate Inn (Service Mark) (managed by the Company on
behalf
of a partnership). In the aggregate, these franchise systems consist of
approximately 5,200 properties and 482,000 hotel rooms worldwide. The
Company also operates the CENTURY 21(Registered Trademark) and Electronic
Realty Associates(Registered Trademark) or ERA(Registered Trademark) real
estate brokerage franchise systems, which it acquired on August 1, 1995 and
February12, 1996, respectively. The Century 21 and ERA systems are the world's
largest and fourth largest franchisors, respectively, of residential real estate
brokerage offices ….

HFS) was created as an affiliate of the Blackstone Group, a private equity firm, as a vehicle to acquire
hotel franchises.[1] It was led by Henry Silverman, a Blackstone partner and former CEO of Days Inn.
[2] It began in 1990 by buying Howard Johnson's and the U.S. rights to the Ramada brand from Prime
Motor Inns for $170 million.[2][3] In 1992, HFS bought the Days Inn franchise out of bankruptcy for
$290 million.[4] This purchase made HFS the largest hotel franchisor in the world, with its brands
licensed to 2,300 hotels.[5]

1992 Blackstone took Hospitality Franchise Systems public in a December 1992 IPO.[6] HFS was among
the fastest growing companies of its size in the 1990s and the company's stock rose from its IPO price of
$4 per share to $77 per share in 1998.

In 1993, HFS purchased the Super 8 brand, franchised to 1,000 motels, for $125 million,[7][8] and
bought the 61-hotel Park Inn brand.[9] The company made a brief foray into the casino industry, but then
spun off that business in November 1994 as National Gaming.[10] In 1995, HFS launched a new hotel
brand, Wingate Inn.[11]
In or about 1994, , Hospitality Franchise Systems expanded into the real estate business.[12]Silverman
hoped that HFS's skills at franchise management would bring success in fields outside of hospitality.[13]

In August 1995, it acquired Century 21, a franchised chain of brokerages, from MetLifefor $200 million.
[14] The company changed its name to HFS Inc. the same month, to reflect its broadened scope.[15]
[13] This was followed the next year with the acquisition of Electronic Realty Associates for $37 million,
[16] and Coldwell Bankerfor $740 million, making HFS the largest franchisor of real estate brokerages in
the U.S.[17]service, for up to $825 million.[22][23]

1996 National Realty Trust was formed inwhen Cendant, (then HFS Inc.) purchased Coldwell Banker
Corporation. The trust was responsible for the nearly 400 brokerage offices that had been acquired in the
Coldwell Banker purchase as well as continuing to acquire offices and renaming them with one of
Cendant's brand names (Coldwell Banker, ERA and Century 21).[2]

August 1997, Cendant and Apollo Management formed the current company – NRT LLC as a joint
venture operation leading to Acquisitions in Northern and Southern California as well as
in Cincinnati, Ohio.

1997 Silverman led HFS into what would prove a disastrous merger with CUC International, a direct
marketing company that operated discount membership programs like Shoppers Advantage and Travelers
Advantage

1997: HFS and CUC underwent a reverse merger and named the surving company Cendent
Corporation (publicized as "merger of equals" on, to form Cendant Corporation.[26][27] Accordingly,
the controls groups composition as the controlled entities merged, For example, Silverman announced he
would reduce his day-to-day involvement with the company and assume the company's chairmanship in
preference of CUC's founder and CEO Walter Forbes.

In January 1998, Cendant purchased Jackson Hewitt, a franchised chain of tax preparation offices, for
$480 million.[28][29] 1998, Apollo and Cendant controled entity, NRT expanded to intrastate market
Accounting ScandalEdit
April 1988.

Just months after the merger, in April 1998 Cendant uncovered massive accounting improprieties at CUC
which resulted in one of the largest financial scandals of the 1990s. At the time, Vice Chairman E. Kirk
Shelton was reported to have inflated the company's revenue by $500 million over a period of three years.
He had reported a 1997 net income of $55.4 million when the true 1997 result was a net loss of $217.2
million. As these irregularities in the books of Cendant were discovered in early 1998, an audit committee
set up by Cendant's Board of Directors launched an investigation and discovered that the former
management team of CUC, including its top executives Walter Forbes and Kirk Shelton, had been
fraudulently preparing false business statements for several years. [citation needed] When this report was
released to the public, the resulting damage to the market value for the company was approximately $14
billion, with their stock tumbling from a high of $41 down to nearly $12. At the time, this fiasco was the
largest case of accounting fraud in the country's history.

After the accounting scandal was uncovered, Silverman and the Cendant board forced Forbes’ resignation
and Silverman assumed the CEO post.

ost-scandalEdit
1998 Following the fraud, Cendant began selling businesses to reduce its debt and repair the financial
damage caused by the accounting scandal.[30] I. the company sold Hebdo Mag, a publisher of classified
advertising publications, for $450 million to a management buyout group.[31][32]In 1999 it sold its
consumer software division, Cendant Software (consisting of Blizzard Entertainment, Davidson &
Associates, Knowledge Adventure, and Sierra On-Line), to French publisher Havas for $770 million.[31]
[33]

In 2000, NRT set a "real estate industry record, surpassing $100 billion in closed sales volume" and
acquired Fred Sands Realtors, a $5 billion company based in Los Angeles.[3] By the end of the year,
NRT had acquired over 150 companies.